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HomeMy WebLinkAbout00-00147 DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. WILLIAM R. SCHNEIDER, Defendant CIVIL ACTION - LAW NO. 2000.147 CIVIL TERM IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Plaintiff moves the court to appoint a Master with respect To the following claims: ( ) Divorce ( ) Annulment ( X) Counsel Fees ( XI Distribution of Property ( XI Alimony ( XI Costs and Expenses ( ) Support ( X) Alimony Pendente Lite and in support of the motion states: 1. Discovery is complete as to the claim(s) for which the appointment of a Master is requested. 2. The Defendant has appeared in the action by her attorney, P. Richard Wagner, Esquire. 3. The statutory ground for divorc,e is: 3301 (d) 4. Check the applicable paragraph(sl: ( I The action is not contested. I I An agreement has been reached with respect to the following claims: IX I The action is contested with respect to the above-marked claims. 7/ Date 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take _ hours j. day. 7. Additional information, if any, relevant~h;' mo';oo !VI)') 2.0iJc . <..~},~.~ a . Andes Attorney for Plaintiff k() AND NOW ~ ~2002, E. Robert Elicker, II, Esquire is appointed Master with respect to the above claims. t.~aJ1d l' /g'l<5 /1- /)./) -1[J [).. ~. Wqqn e, f!.. ./ Andes BY THE COURT, $J14rJ flJ. .,.. c::> ~ b; <:'> ..... (-:J 8~ 1,- ~S .,,- \1i:.k,~. 0: 03 ':'-:,;:" 0~ -r--< .,,, 0\ ('oJ ':~cz ;~.-' :;->' '..l..lW .....-'-" 0 (00- I :;::: ; ~.:; "'" 0 0 RLED-OFFICE OF THE PPOTHONOTpHY ..... ;. \ . ~ - "-.. -..... ~ ;-~ ~ \..i <~\~'-"".......,.,,/ . -:;- -..,j} 02 N0V22 AM 11: 33 CUMBERLAND COUN1Y PENNSYlVAHIA -;,.-.4 DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW WILLIAM R. SCHNEIDER, Defendant NO'~6-1i.{7 IN DIVORCE CIVIL TERM NOTICE TO DEFI;NQ Al'llOuCI.AJ!VI RI!;lI-m; You have been sued in court. If you wish to defend against the claims set forth in the foregoing pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree in divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, Pennsylvania 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 T .; DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. .;;'bV-O.. 1'17 CIVIL TERM WILLIAM R. SCHNEIDER, Defendant IN DIVORCE NOTICE OF AVAilABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. ., . DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. ;lO-VC" I'll CIVIL TERM WILLIAM R. SCHNEIDER, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, DOROTHY SCHNEIDER, by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is DOROTHY SCHNEIDER, who resides at 103 November Drive, Apartment 5, in Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is WILLIAM R. SCHNEIDER, who resides at 207 Pennsylvania Avenue in Camp Hill, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Common- wealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 9 April 1982 in Cove Lake in Tennessee. 5. There have been no prior actions of divorce or annulment between the parties. 6. This marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I -IRRETRIEVABLEBREAKDOWN 8. The Plaintiff requests this Court to enter a Decree of Divorce. WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to the Divorce Code of Pennsylvania. > " . COUNT II.. EQUITABLE DISTRIBUTION 9. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as marital property. COUNT HI .. ALIMONY 10. Plaintiff lacks sufficient property to provide for her reasonable needs in accordance with the standard of living of the parties established during the marriage. 11. Plaintiff is unable to support herself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 12. The Defendant is employed and enjoys a substantial income from which he is able to contribute to the support and maintenance of Plaintiff and to pay her alimony in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding Plaintiff from Defendant permanent alimony in such sums as are reasonable and adequate to support and maintain Plaintiff in the station of life to which she has become accustomed during the marriage. COUNT IV .. ALIMONY PENDENTE LITE 15. Plaintiff is without sufficient income to support and maintain herself during the pendency of this action. 16. Defendant enjoys a substantial income and is well able to contribute to the support and maintenance of Plaintiff during the course of this action. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her reasonable alimony pendente lite during the pendency of this action. ~ . COUNT V .. COUNSEL FEES AND EXPENSES 17. Plaintiff is without sufficient funds to retain counsel to represent her in this matter. 18. Without competent counsel, Plaintiff cannot adequately prosecute her claims against Defendant and cannot adequately litigate her rights in this matter. 19. Defendant enjoys a substantial income and is well able to bear the expense of Plaintiff's attorney and the expenses of this litigation. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay the legal fees and expenses incurred by Plaintiff in the litigation of this action. I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). DATE: 1/5"/ ;;'000 , I I.L~ ...Q..a.... ..:.J .. ='- DOROTHY SC EIDER ~~4 Attorney for Plaintiff Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 ,,.......,,... f , k~j i \" ; "........../: DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2000-147 CIVIL TERM WILLIAM R. SCHNEIDER, Defendant IN DIVORCE PRAECIPE TO THE PROTHONOTARY: I hereby enter my appearance on behalf of the Defendant, William R. Schneider. hereby accept service of the Divorce Complaint and acknowledge receipt of a copy of the same. Date: 1-3/- 2fJOO arbara Sumple Sullivan Attorney for the Def~ '7 Supreme Court ID #. '/ . "'- <:0 ~ c ti il}S- ~ ...:::- ~5 ~ ~i~ ~ f....t.:..'..> ''-i!; 0- Cti?: ge:- !~ ee,- C\J tU!~'_, C:-~", i e f5~ ~. ...." k. ro1:f! '" ""'- e;:, ~ <::> <:::> ... .. . SHERIFF'S RETURN - REGULAR CASE NO: 2000-00147 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SOlNEIDER DOROTHY VS SCHNEIDER WILLIAM R CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - DIVORCE was served. upon ~CHNEIDER WILLIAM R the DEFENDANT , at 0017:59 HOURS, on the 1st day of February, 2000 at. 207 PENNSYLVAINA AVE.. CAMP HILL, PA 17011 WILLIAM P. SCHNEIDER by handing to a-true and attested copy of COMPLAINT - DIVORCE together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So 18.00 9.30 .00 10.00 .00 37.30 Answers: ~~ ~." . ~~_..A""~1'~~ R. Thomas Kline Sworn and Subscribea to before 02/04/2000 SAMUEL L. ANDES ....--7 By: ~tOc e Deputy Sheriff . me this .;l.6~ day of- J,y;". A', c207rCJ A.D. (~. ~() 'n1..db, ~ ~~ /"-'1prothonotary / IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOROTHY SCHNEIDER, Plaintiff v. WILLIAM R. SCHNEIDER, Defendant DOROTHY T. SCHNEIDER, Plaintiff v. WILLIAM R. SCHNEIDER, Defendant DOROTHY SCHNEIDER, Plaintiff v. WILLIAM R. SCHNEIDER, Defendant AND NOW, this JL day of : NO.2000--m P{7 /' CIVIL ACTION - LAW : IN DIVORCE : NO. 00-146 : CIVIL ACTION - LAW : IN CUSTODY : DOCKET NO. 846 S 1990 : PACSESCaseNumber: 179101847 RULE ~ ,2000 on consideration of the Petition for Leave to Withdraw as Counsel, a RULE is issued on Plaintiff and Defendant to show cause, if any, why the Court should not grant the relief requested. ~ ')y The Rule is returnable within ~ days from the date of service hereof. ~ 0 t~\,\~ - BY THE COURT- / /~ J. \,\\..t.\}0fi'\Ct 0"[- 11'.':. i'?O\\"0\~O\f',R'i Ofll-\G\i \3 ~l'\ \: 34 CUMoWV\\,\D COlltni rCN~S<l\jPN\f', ,-,:~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA DOROTHY SCHNEIDER, Plaintiff v. : NO. 2000-147 : CIVIL ACTION -LAW : IN DIVORCE WILLIAM R. SCHNEIDER, Defendant DOROTHY SCHNEIDER, Plaintiff v. : NO. 00-146 : CIVIL ACTION - LAW : IN CUSTODY WILLIAM R. SCHNEIDER, Defendant DOROTHY T. SCHNEIDER, Plaintiff v. : DOCKET NO. 846 S 1990 : PACSES Case Number: 179101847 WILLIAM R. SCHNEIDER, Defendant PETITION FOR LEAVE TO WITHDRAW AS C;QliNSEL AND NOW, this~ 1:11, day of October, 2000, comes Barbara Sumple-Sullivan, Esquire, and files the within Petition for Leave to Withdraw as Counsel for the following reasons: 1. On or about January 17,2000, William R. Schneider, Defendant contracted with the law firm of Barbara Sumple-Sullivan, Esquire in connection with the above-referenced actions. 2. Pursuant to that representation, the litigation involving this case is continuing. 3. Despite numerous requests, William R. Schneider has refused to make payment to counsel as agreed or otherwise contact and cooperate with counsel regarding this matter. 4. Defendant has not been cooperative in providing requested information and has not fulfilled his obligations to Movant and it would be a hardship for Movant to incur additional time and expense incident in this representation. WHEREFORE, Barbara Sumple-Sullivan, Esquire, requests that she be withdrawn as counsel and that William R. Schneider, be ordered and/or directed to fmd another counsel. Respectfully submitted, DATE: October ll2000 Barbara Sumple-Sullivan, Ire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court LD. 32317 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOROTHY SCHNEIDER, Plaintiff v. : NO. 2000-247 : CIVIL ACTION - LAW : IN DIVORCE WILLIAM R. SCHNEIDER, Defendant DOROTHY T. SCHNEIDER, Plaintiff v. : NO. 00-146 : CIVIL ACTION - LAW : IN CUSTODY WILLIAM R. SCHNEIDER, Defendant DOROTHY SCHNEIDER, Plaintiff v. : DOCKET NO. 846S 1990 : PACSES Case Number: 179101847 WILLIAM R. SCHNEIDER, Defendant CERTIFICATE OF SERVICE I, BARBARA SUMPLE-SULLIV AN, ESQUIRE, do hereby certify that on this date, I served a true and correct copy of the PETITION FOR LEAVE TO WITHDRAW AS COUNSEL, in the above-captioned matter upon the following individuals by first class mail, postage prepaid, addressed as follows: Mr. William R. Schneider 207 Pennsylvania Avenue Camp Hill, PA 17011 Samuel L. Andes, Esquire 525 North Twelfth Street P.O. Box 168 Lemoyne, PA 17043 DATE: October n, 2000 I.. Barbara Sump Ie-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court J.D. 32317 >- ~ ,.- LtJQ -----Z).ti TL._.. t.l~ . C) ~-~ ~:~. ,- C5 en M' oi = "'" g~ -3s; .U~ Q~ '<:~2 <t. -' ~~. .ff cO , ;:,.\ c;::; 2; C> C> --_._-~-- " > : '-'_J:. _~_~ . ~. :..., '-" ~ ~ ~ .--.. - ~ 0.' ., ----c....ffi cr i~'. U. ~o ." :'i > --,- z <( > ::1 ..J :J t; tIl ::! Wl- -J U) ll. ~ ::lE " :J ~ . tIl ~ , ~ --.< ~ a: <( m a: <( m :-(;) 01 ;; S ,... 5 z <( ~ >- <Jl Z Z W 0.. ci z :5 0: W to ::!; ;J Q. ?: ~ '- '. \ NOV 0 9 2D9{. < IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOROTHY SCHNEIDER, Plaintiff v. : NO. 2000-147 : CIVIL ACTION - LAW : IN DIVORCE WILLIAM R. SCHNEIDER, Defendant DOROTHY SCHNEIDER, Plaintiff v. : NO. 00-146 : CIVIL ACTION - LAW : IN CUSTODY WILLIAM R. SCHNEIDER, Defendant DOROTHY T. SCHNEIDER, Plaintiff v. : DOCKET NO. 846 S 1990 : PACSES Case Number: 179101847 WILLIAM R. SCHNEIDER, Defendant r1M ~ER AND NOW, this L day of ,2000, It IS ORDERED, ADJUDGED and DECREED that: 1. The Rule to Show Cause is made Absolute; 2. The appearance of Barbara Sumple-Sullivan, Esquire, as counsel for the Plaintiff, William R. Schneider, in the above-stated action, is hereby. withdrawn. ~~4li 1:2.-']-00 RX3 RLED-OmCE OF THE PROTIjONOTARY 00 DEe -5 Ml 9: 34 CUMBERLAND COUNlY PENNSYLVANlJl. < '. '. " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA DOROTHY SCHNEIDER, Plaintiff v. NO. 2000-147 CIVIL ACTION - LAW IN DIVORCE WILLIAM R. SCHNEIDER, Defendant DOROTHY SCHNEIDER, Plaintiff v. : NO. 00-146 : CIVIL ACTION - LAW : IN CUSTODY WILLIAM R. SCHNEIDER, Defendant DOROTHY T. SCHNEIDER, Plaintiff v. DOCKET NO. 846 S 1990 PACSES Case Number: 179101847 WILLIAM R. SCHNEIDER, Defendant MOTION TO MAKR RULE ABSOLUTE AND NOW, thiS~ay of;f/~, 2000, comes Barbara Sumple-SulIivan, Esquire, and files the within Motion to withdraw for the following reasons: 1. Petitioner is Barbara Sumple-Sullivan, Esquire. 2. Respondents are William R. Schneider and Samuel L. Andes, Esquire. 3. On, Petitioner filed a Motion to Withdraw as Counsel for Client's Name. 4. On November IO, 2000, a Rule was issued, returnable within ten (IO) days, to show cause why Petitioner should not be allowed to withdraw as counsel in this case. A copy of said rule is attached hereto as Exhibit A and incorporated here unto is incorporated by reference herein. '. " 5. Copies of said Rule were served on Respondents by regular mail. Copies of said correspondence is attached as Exhibit B and incorporated by reference herein. 6. No objection has been filed to date. In fact, Samuel L. Andes, Esquire advised Petitioner that he has no objections to Petitioner's withdrawal. A copy of Attorney Andes' letter dated November 16, 2000 is attached as Exhibit C and incorporated by reference herein. 7. Having received no objection to date, Petitioner hereby requests leave to with draw as counsel for Defendant, William R. Schneider. WHEREFORE, Barbara Sump Ie-Sullivan, Esquire, requests that she be withdrawn as counsel of record. ara umple-Sulhvan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court J.D. 32317 . DATE: 1!-2J"- ;tfoO .' t' .. EXHIBIT "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA j I ! J DOROTHY SCHNEIDER, Plaintiff v. : I~'l : NO. 2000~ : CIVIL ACTION - LAW : IN DIVORCE WILUAM R. SCHNEIDER, Defendant DOROTHY T. SCHNEIDER, Plaintiff v. : NO. 00-146 : CNIL ACTION - LAW : IN CUSTODY WILLIAM R. SCHNEIDER, Defendant DOROTHY SCHNEIDER, Plaintiff v. : DOCKET NO. 846 S 1990 : PACSES Case Number: 179101847 WILLIAM R. SCHNEIDER, Defendant RIfLE ,.' .... AND NOW, tbi~ OfA. day of KYJ..Ar. . ~ . 2000 on consideration of the Petition - for Leave to Withdraw as Counsel, a RULE is issued on Plaintiff and Defendant to show cause, if any, why the Court should not grant the relief requested. The Rule is returnable within JQ........ days from the date of service hereof. BY THE COURT: ~ ~ ~3'OO ~? \\'\~ p J. '. , " EXHIBIT "B" " o o LAw OFFICES BARBARA SUMPLE-SULLIV.AN t5049 BRIDGE STREET NEW GUMBERL.A.ND. PENNSYLVANIA 17070-1931 paONE (717) 774-1443 FAX (717) 774--70:5>9 November 14,2000 Mr. William R. Schneider 207 Pennsylvania Avenue Camp Hill, PA 17011 Samuel L. Andes, Esquire 525 North Twelfth Street P.O. Box 168 Lemoyne, PA 17043 Re: Schneider v. Schneider Dear Mr. Schneider and Attorney Andes: 0\ ''. Enclosed constituting service on you is the Rule returnable within ten (10) days from the date of service. Barbara Sumple-Sullivan BSSfld Enclosure i'_;!;i'C,,;;~:"'''''''-''''''' . .._',....:....,e..=...- '.--V:~ '~.-_. ,~-..._." / IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA DOROTHY SCHNEIDER., Plaintiff v. : 1'-\1 : NO. 2000~ : CIVIL ACTION - LAW : IN DIVORCE WILLIAM R. SCHNEIDER., Defendant DOROTHY T. SCHNEIDER, Plaintiff v. : NO. 00-146 : CIVIL ACTION - LAW : IN CUSTODY WILLIAM R. SCHNEIDER., Defendant DOROTHY SCHNEIDER., Plaintiff v. : DOCKET NO. 846 S 1990 : PACSES Case Number: 179101847 WILLIAM R. SCHNEIDER., Defendant RULE .." ". fA AND NOW, tbi~~ day of tY. . - .2000 on consideration of the Petition for Leave to Withdraw as Counsel, a RULE is issued on Plaintiff and Defendant to show cause, if any, why the Court should not grant the relief requested. The Rule is returnable within ~ days from the date of service hereof. BY THE COURT: ~ ~3.0D ~~ \\'\~ J. ..... 1.1;.1 ~ c, "' EXHIBIT "e" '_. -_'-.....,..~..;'."'..:""v...,..-..-:':::. ." .~''''.-:'-~~~ '--.:;;';.~.:w--'-:--~.'_ - :~__~~. .., " " o o i. '. SA.MUEL L. ANDES ATTORNEY AT LAW ts2ts NORTH TWEmH STREET P. O. BOX 168 LEMOYNE, PENNSYLVANIA 17043 Tll:I.EPHONE ("1") "61'~361 16 November 2000 'AX (71") 761'1~:5 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 RE: Schneider Dear Barb: My client and I do not oppose your request for leave to withdraw as Mr. Schneider's counsel in the three pending actions. If and when you withdraw, please send me a copy of the final order and your praecipe so I will know the process has been completed. Sincerely, a~i.~ Samuel L. Andes ~ cc: Dorothy Schneider ".. . " .... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOROTHY SCHNEIDER, Plaintiff v. : NO. 2000-147 CIVIL ACTION - LAW : IN DIVORCE WILLIAM R. SCHNEIDER, Defendant DOROTHY SCHNEIDER, Plaintiff v. : NO. 00-146 : CIVIL ACTION - LAW : IN CUSTODY WILLIAM R. SCHNEIDER, Defendant DOROTHY T. SCHNEIDER, Plaintiff v. : DOCKET NO. 846 S 1990 : PACSES Case Number: 179101847 WILLIAM R. SCHNEIDER, Defendant VERIFICATION I, BARBARA SUMPLE-SULLIV AN, ESQUIRE, hereby certify that the facts set forth in the foregoing MOTION are tnie and correct to the best of my knowledge, information and belief, I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. ~4904 relating to unsworn falsification to authorities. I further aver that this Motion is not interposed for the purpose of delay. DATE: 11/(X../LCCx) rumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court LD. 32317 ..., .-, (~ f. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOROTHY SCHNEIDER, Plaintiff v. : NO. 2000-147 : CIVIL ACTION - LAW : IN DIVORCE WILLIAM R. SCHNEIDER, Defendant DOROTHY SCHNEIDER, Plaintiff v. : NO. 00-146 : CIVIL ACTION - LAW : IN CUSTODY WILLIAM R. SCHNEIDER, Defendant DOROTHY T. SCHNEIDER, Plaintiff v. ; DOCKET NO. 846 S 1990 ; PACSES Case Number; 179101847 WILLIAM R. SCHNEIDER, Defendant CERTIFICATE OF SERVICE I, BARBARA SUMPLE-SULLIVAN, ESQUIRE, do hereby certify that on this date, I served a true and correct copy of the MOTION TO MAKE RULE ABSOLUTE, in the above- captioned matter upon the following individual(s), by United States first-class mail, postage prepaid, addressed as follows: DATE: 11/0<9 ~D . , Samuel LAndes, Esquirc 525 Nort~ fth Street iZ<i Barbara Sump Ie-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Mr. William R. Schneider 207 Pcnnsylvania Avenue Camp Hill, PA 17011 ~ .U) C <'-.. ..:z: >--' 6 :::Y :<l; C'I n l'_l O~ ~~ ) , -::''"; f-- ~:::: .7_->j l)5- :~-! " cr, ~~~ C"-.J t..... c:: HHt: ~ 2:: ~- , , o. C.J <:::_1 C; <.) -[ _"t. . " ,\...-. .~ "' ~ '". ~ \ .-:;..'=;':- --1 -( -.--"" ~---"'-~- '--, cJ _\__ ,. ....J i!, " .i.- ,. , \ ~I 2:;-~-7'- ----------=-~, ,-~'_'-~"'"___'-,~~;o~=~-'-'-=- '. ~--=;"~~-'---=.:...--F.: ~.._-;-____'_T"--=-,,~ , ....' / , .J. _>(',i , '. <"--- '/ " ) " '! , 1..,- " --'_....;~~.-'-.~-.o"-=~'-'-. r. l. ,"-. z <( > ,3 :J (J) fa ill .0 -.! E 0.. o ::<: :J :J :J ill <t 0:: <( III 0:: <( III ,(- ~ -j' , ~j ~.~ '" 6 " o " <( Z I- <( ~ :i ~ >- ~ IJl ~ Z ~ Z c W " ll. m ~ " ~ Z m <( ..J 0: W m :E "::> U :;:: w z .~ " ,.N'OV 3 I) 20~ c ~- --" DOROTHY SCHNEIDER, Plaintiff vs. ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW WILLIAM R. SCHNEIDER, Defendant NO. 2000-147 CIVIL TERM IN DIVORCE NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counteraffidavit within twenty (20) 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 1. The parties to this action separated in late November, 1999, and have continued to live separately 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 if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: CJ ,...:t;;},1A / r;. Rood.... I >- co .~ :;:;;; C'": ,_. YJ~ N F5~ ,.)^- :;c O~ b.:~ "- C- .~:J :::>; r~lr..-: co::>- @t;. N <,,~ ._~ ~. :> .x: i:D u-~.;:.~ LLJ = LOo... ,.... z 2 U- N ;:) 0 0 0 . " .. --.---.---.-------.--- ._----_._._---------~------ .. . . . . .. ... . " '" ...':- , '.' '""C.' .'i ...: or:-' DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2000-147 CIVIL TERM WILLIAM R. SCHNEIDER, Defendant IN DIVORCE ORDER OF COURT AND NOW this ::;- day of r--c.ir...vJ ,2003, upon Plaintiff's Motion, we hereby direct Defendant, William R. Schneider to produce the documents and things described in the Plaintiff's Request for Production of Documents and Things which is attached to her Motion to Compel or to otherwise respond as required by the Pennsylvania Rules of Civil Procedure, all within 30 days of the date of service of a copy of this Order upon the Defendant. BY THE COURT, ~ ./Jd.- DISTRIBUTION: J. Samuel L. Andes, Esquire (Attorney for Plaintiff) 525 North 12th Street, Lemoyne, PA 17043 >~~ ..:2.0 7~ 0-3 William R. Schneider (Defendant) 207 Pennsylvania Avenue, Camp Hill, PA 17011 q.~ BLED-OfFICE OF TI-,fc PROTHONOTARY D3 FEa -7 PH 2: 02 CUMBE.'iLAhf[] COUN1Y PENNsYL\~WiA > DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2000-147 CIVIL TERM WILLIAM R. SCHNEIDER, Defendant IN DIVORCE MOTION TO COMPEL AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, and moves the court to compel the Defendant to respond to Plaintiff's Request for Production of Documents and Things, based upon the following: 1. The moving party herein is the Plaintiff, Dorothy Schneider. The responding party herein is the Defendant, William R. Schneider. 2. The parties have been married for approximately twenty (20) years but have Jived separate and apart since November of 1999. This divorce action was commenced in January of 2000. 3. In December of 2002 Plaintiff, by her counsel, served upon the Defendant a Request for Production of Documents and Things in which he requested information about some of the significant marital assets and liabilities in the case and information about Defendant's income. A copy of the Request is attached hereto and marked as Exhibit A. 4. The Request was served upon the Defendant by regular mail on 16 December 2002 and was sent to him by certified mail on 17 December 2002. A copy sent by regular mail was not returned to sender and it is assumed Defendant received that copy. The copy sent by certified mail has not been returned but the green receipt card has not been returned either and Plaintiff's counsel believes that Defendant has simply failed to accept the certified service of that copy. 5. To date, Defendant has not made any response to Plaintiff's Request and has not provided the documents requested. 6. Plaintiff requires the information set out in her Request to properly prepare this case for litigation, settlement, or other disposition. Without that information the case cannot proceed in an orderly fashion. WHEREFORE, Plaintiff moves this court to enter the attached Order directing and compelling Defendant to produce the documents described in Plaintiff's Request for Production. ~~~~ ~nQ~ eIL.A~ Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 VERI FICA TION I verify that the statements made in this Motion to Compel are true and correct. I understand that any false statements in this Motion to Compel are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: ~ I~ 103 ~~ CERTIFICATE OF SERVICE I hereby certify that I served an original of the foregoing Motion to Compel upon the Defendant herein by regular mail, postage prepaid, addressed as follows: William R. Schneider 207 Pennsylvania Avenue Camp Hill, PA 17011 Date: 3 February 2003 {ltttuiilfn, Lt-IaL~ Amy M. H kins Secretary for Samuel L. Andes DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW WILLIAM R. SCHNEIDER, Defendants NO. 2000-147 CIVIL TERM IN DIVORCE REQUEST FOR PRODUCTION OF DOCUMEr~TS AND THiNGS TO: WILLIAM R. SCHNEIDER 207 Pennsylvania Avenue Camp Hill, PA 17011 You are requested, in accordance with Pa. R.C.P. 4009, to deliver to the office of the undersigned at 525 North 12th Street, Lemoyne, Pennsylvania, or otherwise make arrangements reasonably satisfactory to the undersigned, for his inspection or examination, copies of the following documents, articles, and things, within twenty (20) days of the date of this Request. For purposes of this Request, all computer records and information available on computer records or within computer programs, should be included within the Request for Production. That is, this Request is not limited to documents or "hard copies" of records, but should include computer records, tapes, disks, and other media as well as paper documents. 1. Copies of any statements you have which reflects the benefits you have earned in your pension or retirement plan with IBM. The documents should specifically include any documents showing benefits that you will be entitled to receive at any future date on which you are eligible to retire and 1 any documents which will confirm monies you withdrew from the plan up to this time. 2. Copies of your federal and state income tax returns for the years 2000 and 2001. 3. Copies of your last three paycheck stubs. 4. Copies of statements showing the balance in any bank accounts, mutual funds, stock accounts, or other accounts or assets you hold with any financial institution, showing the balance in those accounts as of 1 December 1999 and the present. 5. Copies of any and all appraisals you have of the residence at 207 Pennsylvania Avenue, Camp Hill, Pennsylvania, for any time in the past or at the present. 6. CopTes of statements showing the balance owed on any mortgage, home equity loan, or other debt which is secured by a lien against the residence at 207 Pennsylvania Avenue. The statements should show the balance owed on the liens both at the present time and as of 30 November 1999. 7. Copies of documents showing the present balance owed on any credit card or other debt owed at the time of separation which you claim to be a marital debt. Q~J'_ \eP~ Sal ~. Andes Attorney for Plaintiff Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 2 >- C) >- q;; l.f: Z ~. n Cl 3::;; ~-' -, ( -'""- c>;.z ~~ :c IL....._ -< >' 9;2, Q;;:, cE= u> S~ LU - rr:!:.U c::: ffiaJ F: w..' coo.. u... :i: a (") (5 = ,,,,,.,-oQ,,), In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION DOROTHY T. SCHNEIDER ) Docket Number 00-147 CIVIL Plaintiff ) VS. ) PACSES Case Number 870105473 WILLIAM R. SCHNEIDER ) Defendant ) Other State ID Number Order AND NOW to wit, this it is hereby Ordered JUNE 17, 2003 that: THE CONFERENCE SCHEDULED ON THIS DATE IS CONTINUED GENERALLY. AND MAY BE CALLED FOR RESCHEDULING BY EITHER PARTY. BOT!"! PARTIES ARE TO REPORT. TO THE DOMESTIC RELATIONS SECTION THE DISPOSITION OF AN OUTSIDE AGREEMENT ON OR BEFORE AUGUST 1, 2003. DRO: RJ Shadday xc: plaintiff d@fendant Sarruel Andes, Esquire Robert Lieberman, Esquire BY THE COURT: ~!:!. MAILED 1;-17.03 Service Type M JUDGE Form OE.OOl Worker ID 21005 C' fCf rp ...-.. ..", ~...... p.aU 'U.J2.-os ,'~~ ~ -f \ ~ ~ \- , . A- ~ ~ it \".~ "", -. <-.;;"~~ . ., b:. .$ ?: ~ , c--.:" Z. ~ ~ ::y~ ~ ~'2'. Q~ _.. u 0:'=-,.' ~_. >.. '_L~_ 0- .~.~ ~-~- C(r .." -;~ 0' LULl.. - LC.~ ~t_,~~ J,J "'" tj, .. - - i,::: ....., W- e') 3 - 0 0 ...-1 DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ) ) ) ) ) ) ] ) ) IN DIVORCE vs. CIVIL ACTION - LAW NO. 2000..147 CIVil TERM WILLIAM R. SCHNEIDER, Defendant ORDER OF COURT AND NOW this day of , 2003, upon consideration of the attached Motion for Sanctions, it appearing that the Defendant has not complied with our order of February 7, 2003, we hereby order and decree as follows: 1. The Defendant is directed to sign any authorizations, consents, or other documents prepared by Plaintiff's counsel to permit him to obtain information directly from any source regarding the marital assets in this case, and to otherwise cooperate with Plaintiff's counsel in any efforts necessary to obtain such information. 2. Plaintiff is awarded counsel fees in the amount of $500.00 to compensate her for the counsel fees she has incurred in an effort to obtain information which the Defendant has failed to produce in violation of our prior order. Defendant shall make payment of said sum directly to Plaintiff's attorney within twenty (20) days of the date of this order. 3. Plaintiff is awarded whatever counsel fees are reasonably incurred by her in attorney's continuing efforts to obtain the information requested from Defendant, including his efforts to obtain that information directly from any third-party sources. In the event that the parties cannot agree upon counsel fees, we will schedule an addit'onal proceeding to determine them. BY THE COURT, DISTRIBUTION: J. Samuel L. Andes, Esquire (Attorney for Plaintiff) 525 North 12th Street, Lemoyne, PA 17043 Robert B. Lieberman, Esquire (Attorney for Defendant) 500 North Third Street, Harrisburg, PA 17101 William R. Schneider (Defendant) 207 Pennsylvania Avenue, Camp Hill, PA 17011 _...i=~ DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2000-147 CIVIL TERM WILLIAM R. SCHNEIDER, Defendant IN DIVORCE ORDER OF COURT ~. M~U~~ AND NOW this ~ /) -G1 day of /11. ~ .. , 2003, u lit r ., g is hereby scheduled on the attached Motion for Sanct ons, to be held before the undersigned, in Court Room No. L( of the Cumberland Cour;J;):' Courthouse in Carlisle, Penni(lvania, commencing at :;J; 00 o'clock ....,t:2...m. on.1/!././/UJO/l-:/- the I q day of lA'J./Yl Jl _ 2003. BY THE COURT, DISTRIBUTION: J. Samuel L. Andes, Esquire (Attorney for Plaintiff) 525 North 12th Street, Lemoyne, PA 17043 Robert B. Lieberman, Esquire (Attorney for Defendant) 500 North Third Street, Harrisburg, PA 17101 , 4r~ .f.. ;U.. 0 ..3 William R. Schneider (Defendant) 207 Pennsylvania Avenue, Camp Hill, PA 17011 9-. FJ!_cD-OfTlCE OF 7r-:~ :::?t'F:.;:')f.)OTARY 03Hin20 AHI1:1l8 CUM8EFVi'!D COUNlY PENNSYLVANIA (") c::- o C c.: <" "n -g05 :li: :~:< '" EfJtIJ -< .. 1"':'::' ,.r,_,~_ ""7,,-- N -_~n .........,- ~,.J_:. ,..'1 --:y r:: C' ....1_, ---"\.,,,,. 0< ..." 'T. ;;:e,~ -;.;. ->...., ...G.-C ~~o $.~ '>? :';..; rM ...... ,-' :z: -t ~ "'" ~ <0 DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2000-147 CIVIL TERM WILLIAM R. SCHNEIDER, Defendant IN DIVORCE MOTION FOR SANCTIONS AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, and moves the court for sanctions in this matter, based upon the following: 1. The moving party herein is the Plaintiff, Dorothy Schneider. The responding party herein is the Defendant, William R. Schneider. 2. In December of 2002 Plaintiff served upon Defendant a Request for Production of Documents and Things to obtain information about the marital assets in the case. 3. When the Defendant did not respond to Plaintiff's Request for Production of Documents and Things, this court, on Plaintiff's Motion to Compel, ordered Defendant to produce the documents requested within thirty (30) days of the date of service of that order. That order was dated 7 February 2003 and was served upon the Defendant shortly thereafter. Attached hereto and marked as Exhibit A is a copy of said order. 4. In early March of 2003 Defendant retained an attorney, Robert Lieberman, Esquire, to represent him in this matter. On 7 March 2003, Plaintiff's counsel provided Mr. Lieberman with a copy of this court's order to compel dated 7 February 2003. 5. Since 7 March 2003, Mr. Lieberman has acknowledged receipt of this court's order to compel and has provided to Plaintiff's counsel a portion of the documents requested which are the subject of this court's order to compel. 6. Defendant has still not complied with this court's order of 7 February 2003 and has not provided to Plaintiff or her counsel the documents ordered by this court, including, without any limitation, documents relating to Defendant's 401 (k) Plan with IBM and =~ r--'- ""- !'. ~~'"~;,.,.-,. ~ ~~ ... ..-~ L ...~: - ~~-o..,.];::.~ . ,., various withdraws he has made from that plan since this time, together with information regarding the martial residence. WHEREFORE, Plaintiff moves this court to sanction the Defendant for his failure to comply with the court's order of 7 February 2003 by awarding Plaintiff the counsel fees she has incurred in this matter to date and counsel fees she will incur in obtaining the information which is the subject of that order. ~~-~~ Sam ndes Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 , VERIFICATION I verify that the statements made in this Motion for Sanctions are true and correct. I understand that any false statements in this Motion for Sanctions are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification .to authorities). Date: ~~ SAMUEL L. ANDES , CERTIFICATE OF SERVICE I hereby certify that I served an original of the foregoing Motion for Sanctions upon the Defendant herein by regular mail, postage prepaid, addressed as follows: Robert B. Lieberman, Esquire 500 North Third Street Harrisburg, PA 17101 Date: ~ I May 2003 .LunC61f14\?vttLfD Amy M Harkins Secretary for Samuel L. Andes ,.r"' ('") 0 a c::. W -n ::-?' ::.: .--1 -oi~ "'" ~2 r.; tE' " .....c: _'..J:1 ~~ '0 .<7 :;J 6 -<./ '~~. 0"'" ~....., "'" ....... ~.. :x ;;:0 :2::\"; ,. rn :Fe - g c.: 2; "" ~ =2. ...1 DOROTHY SCHNEIDER, Plaintifl)Petitioner IN THE COURT OF COM.MON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTiON - DiVORCE WILLIAM R. SCHNEIDER, Defendant/Respondent NO. 2000-147 CIVIL TERM IN DIVORCE Pacses# 870105473 ORDER OF COURT AND NOW, this 12ili day of May, 2003, upon consideration of the attached Petition for Alimony Pendente Lite andlor counsel fet::s, if is hereby directed .that the parties and their respectiv'e counsel appear before RJ. Shaddav on June 17. 2003 at 10:30 A.M, for a conference, at 13 N. Hanover St., Carlisle, P A 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: (1) a true copy ofyou(IR2~_~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 I9IO.ll~ (4) verification of child care expenses (5) proof of medical coverage which you may have,.or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a \varrant for your arrest. BY TilE COURT, George E. Hoffer, President Judge Mail copies on 5.12-03 to: < Petitioner Respondent Samuel Andes, Esquire Robert Lieberman, Esquire I!,'l~fl!::;m? YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE Ai"lD J REPRESENT YOU. IF YOU DO NOT HAVE ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP. Date of Order: May 12, 20er3 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 r::1EO-o~'"FICt= O~ Tf'~ -,r-;,,_ _ '/'" , -:: : '-'.', !.I,U.""'''.'f'j'1"4t:!y . " .~' 'I ~"l 031'!1t y I ~ Mf 9::?? CUh18i::.ffuNO COUNT'I' PE/VNSllVANlA .'" .~". P !3).) U '" .'~ .;", ., DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2000-147 CIVIL TERM WILLIAM R. SCHNEIDER, Defendant IN DIVORCE MOTION FOR HEARING ON REQUEST FOR ALIMONY PENDENTE LITE AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, and moves the court for a conference at the Domestic Relations Office and, if necessary, a hearing on her request for alimony pendente lite first raised in her complaint in this matter, a copy of which is attached hereto. S~QJ), Attorney for Plaintiff Supreme Court ID # 17225 525 N. 12th Street Lemoyne, PA 17043 (717) 761-5361 FLED-OFFICE OF THE f'"On-'ONOTARY 03NAY-7 AM 8:29 CUM8E8Ct\!~D 'CdUi'i'TY ' . PENNSYLVANIA r:CB t.Ll} J.;:'-..O S. .i d . 'i .~ ~ --, ,\ ii , ; " it :i i ., .! IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ;j DOROTHY SCHNEIDER, Plaintiff :j .' ., 'I " " q i vs. CIVIL ACTION - LAW NO. 70CD - J4-l CIVIL TERM .1 ;1 , WILLIAM R. SCHNEIDER, Defendant IN DIVORCE 'i I :1 l'llPTICE TO DEFEND AND CLAIM RIGliTS You have been sued inCQurt. If you wish to defend against the claims set forth in the foregoing pages, you must take prompt action. You are warned that if you fail to do so, the iJ case may proceed without you anda decree in divorce or annulment may be entered against :1 you by the court. A judgment may also be entered against you for any other claim or relief .1 ii requested in these papers by the plaintiff. You may lose money or property or other rights !I important to you, including custody or visitation of your children. :1 1 ! When the ground for the divorce isindignitiesor irretrievable breakdown of the , marriage, you may request marriage counseling. A list of marriage counselors is available in I the Office of the Prothonotary at: 11 II " ![ , il " Ii , , , I I I li H ii ;1 i: Ii I' rl II " ': Ii Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, Pennsylvania 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVEA LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Ii Ii Ii II Ii " (. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 it 'i :1 II II " .' II ! I , iI 'I H d :1 !! " . DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ) ) ) ) ) ) ) ) ) vs. CIVIL ACTION.. LAW NO. CIVIL TERM WILLIAM R. SCHNEIDER, Defendant IN DIVORCE NOTICLQ-E A V AII,.1\BILlTY OF C.ill.lNS.E1IN..G. TO THE WITHIN-NAMED DEFENDANT: I il the Court of Common Pleas of Cumberland County. This notice is to advise you that in I, Ii , , , You have been named as the Defendant in a Complaint in a divorce proceeding filed in accordance with Section 3302{d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this II list is kept as a convenience to you and you are not bound to choose a c.ounselor from this II!I list. All necessary arrangements and the cost of counseling sessions are to be borne by you , and your spouse. I If you desire to pursue counseling, you must make your request for counseling within " il twenty days of the date on which you receive this notice. Failure to do so will constitute a II II waiver of your right to request counseling. Ii ,I II .1 'I II I I ! I ., d ~ i ;1 Ii " d I " !l ~ I :1 :i 'i !I (' Samuel L. Andes, and makes the following Complaint in Divorce: I , I I II !I II I I )) \) " ii !I .1 Ii I. " ~ i " Ii " 'I DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ) ) ) ) ) ) ) ) ) IN DIVORCE vs. CIVIL ACTION - LAW NO. CIVIL TERM WILLIAM R. SCHNEIDER, Defendant .cOMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, DOROTHY SCHNEIDER, by her attorney, 1. The Plaintiff is DOROTHY SCHNEIDER, who resides at 103 November Drive, Apartment 5, in Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is WILLIAM R. SCHNEIDER, who resides at 207 Pennsylvania Avenue in Camp Hill, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Common- , I wealth of Pennsylvania for at least six months immediately previous to the filing of this I , , Complaint. 4. The Plaintiff and Defendant were married on 9 April 1982 in Cove Lake in Tennessee. 5. There have been no prior actions of divorce or annulment between the parties. 6. I II II may have the right to request that the Court require the parties to participate in counseling. Ii I' 11 I' i! ,I II ./ I , I II This marriage isirretrfevably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff COUNT I - IRRETBIEY A~LE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree of Divorce. WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to the Divorce Code of Pennsylvania. " >I \\ 11 COUNT II.c!:~lUITABLE DISTRIBUTlOtJI :i 9. During the course of the marriage, the parties have acquired numerous items of . . . ;j property, both real and personal, which are held in joint names'and in-the individual names ji of each of the parties hereto. WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the Defendant, to equitably divide the property, both real and personal, owned by the parties i, !i hereto as marital property. II Ii ;l :1 il " p I I i I I i , !I I' from Defendant permanent alimony in such sums as are reasonable and adequate to support COUNT III - tl,L1M,QNY 10. Plaintiff lacks sufficient property to provide for her reasonable needs in accordance with the standard of living of the parties established during the marriage. 11. Plaintiff is unable to support herself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 12. The Defendant is employed and enjoys a substantial income from which he is able to contribute to the support and maintenance of Plaintiff and to pay her alimony in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding Plaintiff and maintain Plaintiff in the station of life to which she has become accustomed during the marriage. COUNT IV - ALIMONY PENDENTE LITE II 15. Plaintiff is without sufficient income to support and maintain herself during the I pendency of this action. I 16. Defendant enjoys a substantial income and is well able to contribute to the support and maintenance of Plaintiff during the course of this action. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her reasonable alimony pendente lite during the pendency of this action. I II II 11 , I , I I I I I :1 matter. I ;1 18. Without competent counsel, Plaintiff cannot adequately prosecute her claims I Ii against Defendant and cannot adequately litigate her rights in this matter. I :1 19. Defendant enjoys a substantial income and is well able to bear the expense of II :! Plaintiff's attorney and the expenses of this litigation. a? () T 5 ~.f' .:!-<,$ ;2. 7$1 c;, .J I ~ ~ 'f/o.;i> , ,i WHEREFORE, Plaintiff prays this Honorable Cour order Defendant to pay the legal ! " I i! fees and expenses incurred by Plaintiff in the litigation of this action. i i1 I :! I il,. I verify that the statements made in this Complaint are true and correct. I understand " I' that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 , i I I (unsworn falsification to authorities). " 'I ,I ,\ ., i ;1 ; I II I I I I DATE: I I I I I II II , I ! II Ii J II I I . . . . . ~d COUNT V - COUNSI;!.....EE..E.S...8ND EXPENSES 1 7. Plaintiff is without sufficient funds to retain counsel to represent her in this DOROTHY SCHNEIDER Samuel L. Andes Attorney for Plaintiff Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 I ! d , DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2000-147 CIVIL TERM WILLIAM R. SCHNEIDER, Defendant IN DIVORCE MOTION FOR HEARING ON REQUEST FOR ALIMONY PENDENTE LITE AND NOW comes.the above-named Plaintiff, by her attorney, Samuel L. Andes, and moves the court for a conference at the Domestic Relations Office and, if necessary, a hearing on her request for alimony pendente lite first raised in her complaint in this matter, a copy of which is attached hereto. &~4 ue L. Andes Attorney for Plaintiff Supreme Court ID # 17225 525 N. 12th Street Lemoyne, PA 17043 (717) 761-5361 FilED-OFFICE OF -rr.:: P~OTHc)NOTARY 03MAY -111M 8: 29 CUM8EBLflND coutm PENNSYLWNIA CofY S€n t h D(2,O .. , . ~ .j II , ~!i ., ~ .\ d , ; " ., 'I :i I ! 'I I DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ., " ., q ,. " : ~ :I :1 I vs. CIVIL ACTION - LAW NO. 2000 - J4-7 CIVIL TERM .j WILLIAM R. SCHNEIDER, Defendant IN DIVORCE i :1 NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the foregoing pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and'a decree in divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief ;\ " requested in these papers by the plaintiff. You may lose money or property or other rights , ! important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in , the Office of the Prothonotary at: I II " Ii I. il I' II II il !I n II Ii jl n il i' r) Ii I! Ii Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, Pennsylvania 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Ii II I I, 1, Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 .'Iil :1 ,I ;1 II " ., 1 il i DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW " 'I :1 WILLIAM R. SCHNEIDER, :1 Defendant ~ i ! NO. CIVIL TERM IN DIVORCE l'illIIC..E...QF IW A!J..ABILlTLOU::_Q..Il!~LSfJ.Jl'LG. TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this , list is kept as a convenience to you and you ara not bound to choose a counselor from this II I' I I L " ii I I II I .1 'I II II I I i list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. '1 .;i II ... ~\ :t II 'I i Ii DOROTHY SCHNEIDER, :i Plaintiff 'I 'j :1 :l vs. d ~ ! :i " !I :\ WILLIAM R. SCHNEIDER. Defendant i ., Ii 1j '1 :/ :1 , ! Samuel L. Andes, and makes the following Complaint in Divorce: 1 1 I II II :1 I I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. CIVIL TERM IN DIVORCE COMPLAINT I.t-J DIVORCE AND NOW comes the above-named Plaintiff, DOROTHY SCHNEIDER, by her attorney, 1. The Plaintiff is DOROTHY SCHNEIDER, who resides at 103 November Drive, Apartment 5, in Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is WILLIAM R. SCHNEIDER, who resides at 207 Pennsylvania Avenue in Camp Hill, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Common- i I I wealth of Pennsylvania for at least six months immediately previous to the filing of this I I II II may have the right to request that the Court require the parties to participate in counseling. Ii II I' II II i , , I Complaint. 4. The Plaintiff and Defendant were married on 9 April 1982 in Cove Lake in Tennessee. 5. There have been no prior actions of divorce or annulment between the parties. 6. This marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff COUNT I -IRRETRIEVABLE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree of Divorce. WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to the Divorce Code of Pennsylvania. _Ii , , , I i! CilllNT II - EQUITABLEJll..S.IBllll1IlQJ'JI. :! 9. During the course of the marriage, the parties have acquired numerous items of Ii property, both real and personal, which are held in joint names and in the individual names ., q of each of the parties hereto. WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the D-efendant, to equitably divide the property, both real and personal, owned by the parties d :i hereto as marital property. Ii Ii I 'I !, il !, I I I I i I i i c.oUNT III - ALIMONY 10. Plaintiff lacks sufficient property to provide for her reasonable needs in accordance with the standard of living of the parties established during the marriage. . 11. Plaintiff is unable to support herself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 12. The Defendant is employed and enjoys a substantial income from which he is able to contribute to the support and maintenance of Plaintiff and to pay her alimony in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding Plaintiff from Defendant permanent alimony in such sums as are reasonable and adequate to support and maintain Plaintiff in the station of life to which she has become accustomed during the marriage. COUNT IV - ALllYIONY PENDENTE LITE 15. Plaintiff is without sufficient income to support and maintain herself during the pendency of this action. 16. Defendant enjoys a substantial income and is well able to contribute to the support and maintenance of Plaintiff during the course of this action. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her reasonable alimony pendente lite during the pendency of this action. II jl ,J ~ !i :( ~_o .. \\ " :r , --~ .c.oUNT v .. ~NQ....EXPENSES , .' ., :1 matter. , 17. Plaintiff is without sufficient funds to retain counsel to represent her in this ; ;1 :1 against Defendant and cannot adequately litigate her rights in this matter. I l\ 19. Defendant enjoys a substantial income and is :ell able to bear the ex,pense of I " Plaintiff's attorney and the expenses of this litigation. m () T 5 ~ ~.! ~ ;). 7 'It, I :1 I :;W:: ~< '1'/"'.;0> : :! WHEREFORE, Plaintiff prays this Honorable Cour order Defendant to pay the legal ! il i !I i ;1 I il I, Ii ,I 1 18. Without competent counsel, Plaintiff cannot adequately prosecute her claims fees and expenses incurred by Plaintiff in the litigation of this action. I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities!. DATE: DOROTHY SCHNEIDER i I I II II I i. II II II Samuel L. Andes Attorney for Plaintiff Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 I I I ,; .iF,,", ""'" --- DOROTHY T. SCHNEIDER, PlaintifffPetitioner IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE WILLIAM R. SCIINEIDER, Defendant/Respondent: NO. 2000-147 CIVIL TERM IN DIVORCE Pacses# 870105473 ORDER OF COURT AND NOW, this 17th day of July, 2003, based upon the Court's detennination that Petitioner's monthly net income/earning capacity is $N/A and Respondent's monthly net income/earning capacity is $N! A, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $776:00"per month payable monthly as follows; $776.QO for alimony pendente lite and $0.00 on arrears. First payment due the first pay date after august 1,2003. Arrears set at $0.00 as of July 17,2003. The effective date of the order is August 1,2003 This order is based upon an agreement of the parties through their counsel. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C.S.~ 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment ofthe Respondent to prison for a period not to exceed six months. Said money to be turned over by theP A SCPU to: Dorothy T. Schneider. Payments mustbc 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, PAl 71 06-9 I 10 Payments must include the defendant's P ACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. FlLfD-,JFRCE OF n.FE ;?I~V)if-!(Y\fOTARY 03 JUL 21 AM 8: 08 CU'Il'b"'Ci:.u"\"':'~ 'Y'i '''TY J..... '--1 1 '~...... VVi.Jtv i PENNSYLVANIA ~"")<:- p"",uu" _" ~ .,.. "" - This Order shaH become final ten days after the mailing ofthe 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 Mailed copies on 7..17..03'0: < BY THE COURT, Petitioner Respondent Robert Liebcnnan. Esquire Samuel Andes. Esquire ,. J. George E. Hoffer, PRESIDENT J. ._~~ ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsvlvania Co.!City/Dist. of CUMBERLAND Date of Order/Notice 09/26/03 Tribunal/Case Number (See Addendum for case summary) ~:sCHNErDER, wILtlAM R. EmployeelObllgor's Name CLast. First., MI) o Original Order/Notice @ Amended Order/Notice o Terminate'6rde';TNotice EmployerNlithholder's FederafEIN Number VERIZON SERVICES COR~Q~TION* C/O ATTN: GARN 2ND FL PAYROLL 7200 CHESTNUT ST UPPER DARBY PA 19082-3125 M/. Wto s 199tJ ~At!5'L5 /79/DI g',?,? 193-38-9270 Employee/Obligor's. Social Security Number 1151100455 EmployeelObfigor's Case Identifier (See Addendum for plaintiff nam@s associated with cases on attachment) Custodiaf Parent's Name (Last First,. MI) ~/,- dt)OD-/Cf7 ('/ v/ ~ Pm-Sf/!" g7D! D 9/7 '2, See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMA TlON: This is aD Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND C6unty, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's.lobligor's income unti I further notice even if the Order/Notice is not issued by your State. $ 776.00 per month in current support $- 0.00 per month in past-due support Arrears 12 weeks or greater? @yes 0 no $ 50.00 per month in medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ 826.00 per month to be forwarded to payee below. You:::do not have to \lary 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: $ Un 190.62 per weekly pay period. $ 381.23 per biweekly pay period (every two weeks). $ - 413.00 per semimonthly pay period (twice a month). $ 826.00 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 Oraer/Notice. Send payment within seven (7) working days of the paydate/date ofwithhoiding. You are entitled to deduct a fee to defray the cast of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's! obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following inf6nnation is needed (See #1 0 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania 5tate 'collections and Disbursement Unit (SCDUl Employer' Customer SerVice at '-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown abQve as the EmployeelObligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DQ NOT SEND CASH BY MAIL. ~~~RY THE 0 T Date of QrsJe"2 9 mal ~ 1 A /W"'\. ft _ j . ~6?-<:?J) J ~~. l-;{e C'U<lG.~ Form EN-028 ServiCe Type M -OMBNo.:0970-o154 Worker 10 $IATT ADDITIONAL INfORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o \f c.heck~d you are requ\rro to pro'{ide a t;Opyofthi~ f~rni'to your employee. Ifyol,lr.employee works in a state that is different from the state that issued this Order, a copy must be provided to your employee even If the box is no.tchecked. 1. We 'appreciate the voluntary compliance of F'ederally recognized Indian tribesi tribally-ownecfbusinesses, and Indian-owned businesses located on a reservation that choose to withhold in accordance with this notice. 2. Priority: Withholding under this OrderlNotice 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 prio'rity. If there are Federal tax levies in effect please contact the requesting agency listed below. 3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a singie payment to each agency requesting withholding. You must, however, separateiy identify the portion of the single payment that is attributable to each employee/obligor. . 4. *-Repooing the- Payd-atelBat~Wilhholdi, ,g. You.mustreporHhe paydate!date-ofwithhoktfng when-<enclingthepayrnent.. The- paydaleldate-ofwithholt:Hngis- the-date-on-wh;ci, au ,OUI ,I ..a, ;,itl,hetd-from-the-empi-oyee's-wages;- You must comply with the law of the state oUbe employee's/obligor's principai 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 errl'ployeeJobligor and you are unable to honor all support Order/Notice,s due to Federal or_S,tate withholding limits; you must follow the law...of the state of empioyee's/obligor's principal piace of employment. You must honor ali OrdersIN.otices to the greatest extent possible. (See #10 below) 6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please'provide the information requested and return a copy of this OrderlNotice to the Agency identified below. WITHHOLDER'S 10: 5213127730 EMPLOYEE'S/08L1GOR'S NAME: EMPLOYEE'S CASE IDENTIFIER: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: SCHNEIDER. WILLIAM R. 1151100455 DATE OF SEPARATION: 7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 8. Liability: If you faii to withhold incpme as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the e.mployee/obligor's inco'me and othe~ penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. AntHJiscrirninatiom You are subject to a fine determined under $.tate 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 Jaw governs unless the obligor is employed in anotFi.:..er-Sfafe; in whicb ease the law of the State in which he or ~he is employed govems. 10. * Withholding Limits: You may not Withhold more than the le.,erof:n the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.c. ,1673 (b) 1 ; or 2) the amounts allowed by the State of the employee's!obligor's prinCipal piace of employment. The Federallimlt applies to the aggregate disposable weekly earnings JADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local t:u.:.esi Social Security' taxes; and Medicare taxes. 11. Additionalln!o: 'NOTE: If you or your agent are selVed with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted 8y: DOMESTiC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLf PA 17013 If you or your employee/obligor have.any questions, contact WAGE ATTA(;HMENT UNiT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.chiidsupport.state.pa.us Page 2 of 2 Form EN-028 Worker lD $IATT SelVie.~Jype M OMBNo.:0970.0154 -.- ADDENDUM Summary of Cases on Attachment Defendant/Obligor: SCHNEIDER, WILLIAM R. PACSES Case Number 179101847 Plaintiff Name DOROTHY T. SCHNEIDER Docket Attachment Amount 84651990 $ 50.00 Child!ren)'s Name(s): JONATHAN L. SCHNEIDER ,:,:,:::" ,;,:.,:,:.:,::.::, ,:,:::::,:::::,;"!,:<~,:,:::.:,:,:.":,,.,,. ::....:', ',:.".,,:':',,'. DOB . 02l~M~~. PACSES Case Number 870105473 Plaintiff Name DOROTHY T. SCHNEIDER Docket Attachment Amount 00-1.47 CIVIL $ 776.00 Child(ren)'s Name!s): DOB ..,.....'.".'..;'.',': .,,:,,:.,,:::,:,::;,.,'.'.' ..,-,.,'.',',',','",'"",',",".',.,',.,,.',,'.' ."."''':',',:,,< ';'::';.";:',.", :'; ,.:,'".',', ,.; :~ :.:,:".; :', ,',"<"........,., ...., :. , : ,'; : .: : : : : : ;,;, ;,;, ;': :':',.','. ",:.:,:,' : ::' :,:: : : ' , :. . : ' :,'.' ',' ',.,' ,. ,.". :.-,.,'.' .":,,.',:, .: :,'. '.' .:., ,:.,.',', " o If checked, you are required to e~ron the child!ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ':;.; :.::; ;:; ';::., ':: :,,::,:: ;:'::::.~ ''',','''-:,nt. ".': ~xa;" ','. ::: :':::.~:::,~'::tn~, ,:i):;:,;,:;;:: '::<:): ~" :: .:':: :::::,;'; ';":.,< ::':;::;:;;:':::):;;;:::,?:y~,; o If checked, you are required to enroll the child!ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child!ren)'s Name!s): DOB Docket Attachment Amount $ 0.00 Child!ren)'s Name(s): DOB , , ,:":::; :.:';':':'::,:: .:,:: :' .:'~ .:C':':.,::.,:::" ... ..., .. .'. ; ,," .... ...:':" .-~ ': . . ......:";.;.:.;':;.::",::,:'.,':'.,':,:::;:t;::~,( .:.:::,;,c,:: ".;":,,,,:;.' {:LHi:~~;:;::;~:;:i~:;:'f:::.~::~:.:::::t:f;:'~ ~:~Y?::.t: :;:~: ::'i:'i:~ ;: ::;:; :' :.,.,:.':'i"':"":>.'."'.'.. . ..'".'" ';:':, ~;:;":"; '..,. . .. .',: '., :: :,:, :: : ,< :.:":"i::: . ,.,,: ',: ',',: ',; ':': ..", .,':' ..,:, ..,.,:.. <,:.,.:.:".. '.' . '0 If~h~~k~d,yo~ ;r~;~~~i';'d.;~ ~~;~II;;;~~hiid(;;~) .' identified above in any health insurance coverage available through the employee's/obligor's employment. ;":;,':;.,:"c i5;f'~i,~~k~d,;~~;;~;;~~i~dt~;~;~II;;;;~hild!;;~)' . identjfied above in any health insurance coverage available through the empJoyee's/obligor's employment. PACSES Case Number Plaintiff Name P ACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name!s): DOB Docket Attachment Amount $ 0.00 Child!ren)', Name(s): DOB :;:,:;::,.;:"",',...-,.,. ':.":>.': ',','",'.,,",".,". ., ...... .",-,-;".:,-.:.,.;.: ".""". .':,c.'."':'::.:::::',::".' 't;::~:/:;';j ;:'::!/U .'.n...".".....,'..,',".:.,',',':.'". """'''''''''''''"",:",.",.:. ". ""." . . "c ':,,: ': ~,;,::::; :':': .'.'.' ::::::f:::::'::::)::~::;::::,: t;:; :;::::~::: :;:;:::::) ":':.::::~::: ::,:::,::,,:,::;, };:.:'- ;,i':;',:'::{(:'i:t: Olf checked, you are requir~d to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obllgor's employment. 'D':i'i.~:h:;~'k~d>;~~":~;~: :~~:~'~'i ~~d':'~~:':~~:~~'i:i":th:~"'~h:ii'~n~~'~}' identified above in any health insurance coverage available through the employee's/obligor's employment. Addendum Form EN-028 Worker ID $IATT Service Type M OMB No.: 0970-0154 5=- 0' ~ ~o z .Q ~ r,!w r=: ~ <Y-; ~f x:8 <>- ~~I::>' -". ~ l~ fIt a '. ,. ,1<;f'r.'t:.t.:?- . :-'{?~'\~VJ-j.!'.'t.~. >tI~,:"':;;'>;?' en N <>- W en M o ORDERJNOTICE TO WITHHOLD INCOME FOR SUPPORT I Stafe Commhnwealth of Pennsylvania Ca}City/Dist. of CUMBERr..AND Date of Order/Notice 04/30/04 Tribunal/Case Number (See Addendum for case summary) o Original Order/Notice -=--@ Amended Order/Notice o Terminate,OrderfNotice RE: SCHNEIDER, WILLIAM R. Employee/Obligor's Name (last:.. First,. MI) 193-38-9270 Employee/Obligor's Social Security Number 1151100455 Employee/Obligor's Case Identifier (See Addendum for plaintiff name$ associated with cases on attachment) Custodial Parent's Name (Last, First Ml) EmployerNVithholder's Federal EIN Number. VERIZON SERVICES CORPORATION- C/O ATTN: GARN 2ND FL PAYROLL 7200 CHESTNUT ST UPPER DARBY PA 19082-3125 -- W ..[1)60- /'17 {lj VIC ~.> $'70/05073 See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support frain CUMBERLAND COunry,'Commonwealth of Pennsylvania. By Jaw, you are required to deducLtheJie amounts from the above-named employee'sfobligor'sincome until further notice even if the Order/Notice is no!, Issued by your State. $ 776.00 per month in current support $ 0.00 per month in past-due support . Arrears 12 weeks or greater? Oyes <Xl no $ 0.00 per month in medical support $ 0 . 00 per month for genetic test costs $ per month in other (spedfy) for a lotal of $ 776.00 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: $ 179.08 per weekly pay period. $ 358.15 per biweekly pay period (every two weeks). $ 388.00 per semimonthly pay period (twice a month). $ 776.00 per monthly pay period. REMITTANCE INFORMATION: Yo.llmust begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate!date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's! obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #10 on pg. 2). If remitting by EFTfEDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service aI1..877..676-9580 for instructions: Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the EmployeelObligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BYTHEmJA~ c;e'iJJ~~V r'~<p_J~ Form EN..028 OMS No.:0970..()154 Worker 10 $IATT Date of Order: MAY 0 3 20n.. Service Type M /' ADDITIONAL INfORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o \\ cr..ec.ked 'IOU are requjred, to pfovi.l)e a yopy of this form to your ~mployee. If YOl,.Jr employe~ works in a state that is different from the state that ISSUed thiS order, a copy must be provided to your employee even If the box is not checked. 1. We_appreciate the voluntary compriance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned busines-ses located on a reservation that choose to withhold in accordance with this notice. 2. Priority: Withholding under this Order/Notice has priority over an~Obther legai process under State law against the same income. Fed_eraJ tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contactthe 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 ag~ncy requesting withholding. You must, howeve~, separately identify the portion of the single payment that is attributable to each employee/obligor. 4.* Ro~6,t;..g t1,o ra,datofDate ofWill,;'<liding. Y<lU 11WSt1'epOrtlhe-P3Yrlateldat, dwitftOOlding'"I,e.. sel,dil,g t;.e pa,",,,..t. The- payddteiddte of wilhi,oldil,g is the date-on-whieh-amou..t ..as mthheltHo, " Ii ,e "",plo,ee', .vage>-: You must compiy with the law of the state oUhe employee's1obligor's principal prace 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 Withhoid Income for Support against this eniployee/obligor and you are unable to honor all support Order/Notices due to Federal or State withhoiding limits, you must follow the law of the state of employee's1obligor's principal place of employment. You must honor all Orders/Noticesto the greatest extent possible. (See #1 0 below) 6. Termination Notification: You must promptly notify the Requesting Agency when the employeeJobJigor is no longer working for you.- Please:-p-rovide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S 10: 52B127730 EMPLOYEE'SfOBlIGOR'S NAME: EMPLOYEE'S CASE IDENTIFIER: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: SCHNEIDER, WILLIAM R. 1151100455 DATE OF SEPARATION: 7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 8. Liability: If you faii to withhoid income as the Order/Notice directs, you are Iiabie for both the accumulated amount you should have withheld from the employeeJobligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the ohlJgor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/9brigor from employment refusioifto employ, or taking disciplinary action against any employeefobligor because of a support withholding. Pennsylvania State raw governs_unless, the obligor is employed in another State, in wllich case the law of the State in which he or she is employed governs. 10. * Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.c. 91673 (b)1 i or 2) the amounts allowed by the State of the employee's!obligor's principal place of employment The Federai limit applies to the aggregate disposabie weekly eamings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes.. 11. Additional Info: 'NOTE: if you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: DOMESTiC RELATIONS SECTiON 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by teiephone at (7171 240-6225 or by FAX at f7171 240-6248 or l:iyintemet www.childsupport.state.pa.us Page 2 of 2 Form EN..028 Worker ID $IATT Service' Type M OMS No.: Q970.(ll S4 I ADDENDUM Summary of Cases on Attachment Defendant/Obligor: SCIlNEIDER, WILLIAM R. PACSES Case Number 870105473 Plaintiff Name DOROTHY T. SCHNEIDER ~ Attachment Amount 00 -14.7 CIVIL $ 776.00 Child(ren)'s Name(,): PACSES Case Number Plaintiff Name DOB Docket Attachment Amount $ 0.00 Child(ren)', Name.<s): DOB .. ;'i;'~~::~~;:;~:::X~0:tt;~~;;;;;~r;1'ik,~;~:,::~:,~g<,~::t:n~~~jt~t,::::;~7:~~:::'f:'::;nf~ft~:t~~ ~,~ :;:,. ,; ,~,.:;~;.:;:ntif::*~,:,;f~.. ':'~;~',!.'~~: ,.""i.:,,:::!o,.:,::rt~r.:'::-"~~;:::::~<::;:l::~*'f.[~tf~~~M~~t: :,:x::'~%*~:::; .',,-::,":::(::':"':~:::;:: "',',.' :.:.:::-::::::.::",:-:":~",~.:.,,-':'t...:. ......,.,':'~:':"~~:.f~;~~~~~'.,'-',."..:..,':?~., o If cli~~l<ed, you are required to enroll the chj[di",~) . . identif100 above in any health insurance coverage available througl} the employee'sLobligor's employment. ~~?iy.::;~s:r.::::!::~::: '~,~,~:::,::::::<:::,<:::",,:<ii:::~::;~:::;:;:,,??-;S~::,,;::';>':: :::;;::~;;,:::::;:::::,::~:;~:::::::::::::::::::;<<::-::~8~::::r:::;;:-:;:~:~:::::;:~,~:):(:{ [] If checked, yo~"~";;<;;~:i;';;;to enroll the child(ren) identified above in any health insurance coverage available through the employee'slobligor's employment. PACSESCase Number Plaintiffl\lame PACSES Case Number Plaintiff Name ~ Attachment Amount $ 0.00 Child(ren)'s Name(s): POB Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ;..,.,..:.,:.:..,',......'.....'........::,.:','::'::::,:,c."::".;:;."."",,,-- ....,,:'?,.,~f::,-,::::~::':,:.::::::~:8:0::;-;.:::-~~~';."*:::t:::tf8":'(:':'y:,~;."'. . .._.~,._'.~~. ,'"~'''J.','.'.'.~.7.-.-~'"''' .',W""""",_",',.,.;...".:.;.:.,.".'.'"",, .., """."""~' Dlf~~~~k~,'~~u~r~';~~~i~;~;~;~;;;11 ;11~'~h:;d;;~~)'..' identified above in any health insurance coverage available through the employee's/obligor's employment ~y.";.::';.i~{:cit~:~!~:*;.:iffi~~~~~~~=~~~;~~;~;fi~~~tt~:':t~'~bf@&i;r~tt:t:t~f:f~Rnt~:r~:~W~':::~ o If checked, you are required to enroll the child(ren) identified above in an)'- 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 PACSES Case Number ~laintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB . ".,.,... . d[i~h~~ked,You ~re required to . the child(ren) identified above in any health insurance coverage available through .the employee's/obligor's employment. ~f.;~f.f.W~,r~:~":;:::-nl:~>;:;~1~~:~:m~:~'\:4V;'rmt:::::::::::,:,::-~~:::::::::::':":~':':~f~~::::::;::::;:::~:::::8::;:?:1;:b:~::,~:*~:. :::-:}:, Yjif~;;;~k~d:~~~ are ^;;q~i;~d ;;;;;;;;;~th~'~hi;d i;;;~)"'" ..' .. identified above in any health insurance coverage available thmugh the employee's/obligor's employment. Addendum Form EN..028 Worker ID $IATT Servic.e.Type M OIVlBNo.:0970-0154 P;;?lUu '2'0'5 ~ N >- 0 Z ~ "" 0 3~ wt5 ::c -7 "-.:>;r: ~8 0- O:::! ...:r ;;r 8: I ':'J~ ~j~ >- ixz ""'" IlJ~ x:: ~~ .<if:. ..:r 3 u... = 0 = c--.. . DOROTHY SCHNEIDER, Plaintiff ) ) ) ) ) ) ) ) ) vs. WILLIAM R. SCHNEIDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA OVILACTION - LAW NO. 2000-147 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed in 2000 and was served upon the Defendant within thirty days after it was filed. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and ~ervice of the complaint. 3. I consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330Hc) OF THE DIVORCE CODE 1. I consent to the entry of a fmal decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a divorceis granted. 3. I understand that I will not be divorced until a divorce decree is entered by the court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made In this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 490_4 relating to unsworn falsification to authorities. ,-1~" ;)tJOlJ; Dated: '.~ ~EIDER >- ~ wO 02 u:s;;.~ '_l.._ 00 ~g: -'cr:L.U FE !5 .p. if ..::I' = ~ ::::>:;!; 8~ E ~ :::..~ ~ -;z I ,5 ,-,-=",":!", Z:r5 ft :::;: B co :lC "'" ~ = = ..... DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000 - 147 - CIVIL TERM WILLIAM R. SCHNEIDER, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 10,2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of Notice of Intention to Request Entry of the Decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. g4904 relating to unsworn falsification to authorities. DATED: /0/31 lOG . a~ iZ>~ William R. Schneider, Defendant >- ~ o LUZ go !j-::c (:50 6'1: ,:,:\0- o:~ u.. o ~ .c; ~ ro ::> .... 0'" ':i ()?- m-. (~~ -c. ~ 'J2 .-:- ~ ;f-id] :Z:':DCL. -S _~ 5 -:o~ C,) DOROTHY SCHNEIDER, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA : NO. 2000 -147 - CIVIL TERM WILLIAM R. SCHNEIDER, Defendant CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree in Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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. DATED: !o/31 (Db ~ /Z..~ William R. Schneider, Defendant >- ~ wQ <'.):g< H=- 9- ~i?, l€~ ~ ~ ..:::- e;:, C:> .::t: "'" r:: ~ c;$" v~ -'"125 i..,,.J;~ :a. '~_ . '._-...:::::.: ...91!IW <,}..1Q ;g ::;; i'e a II . . DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW WILLIAM R. SCHNEIDER. Defendant NO. ~6 - 11./7 IN DIVORCE CIVIL TERM NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the foregoing pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree in divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle. Pennsylvania 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY. LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 II ... DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. .;< ()1J-O. 1'17 CIVIL TERM WILLIAM R. SCHNEIDER, Defendant IN DIVORCE NOTICE OF AVAilABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling. you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. ., . . DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. J-trtrO - IV1 CIVIL TERM WILLIAM R. SCHNEIDER, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff. DOROTHY SCHNEIDER, by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is DOROTHY SCHNEIDER, who resides at 103 November Drive, Apartment 5. in Camp Hill, Cumberland County. Pennsylvania. 2. The Defendant is WILLIAM R. SCHNEIDER, who resides at 207 Pennsylvania Avenue in Camp Hill, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Common- wealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 9 April 1982 in Cove Lake in Tennessee. 5. There have been no prior actions of divorce or annulment between the parties. 6. This marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I - IRRETRIEVABLE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree of Divorce. WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to the Divorce Code of Pennsylvania. II " . . COUNT II - EaUIT ABLE DISTRIBUTION 9. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the Defendant, to equitably divide the property. both real and personal, owned by the parties hereto as marital property. COUNT III - ALIMONY 10. Plaintiff lacks sufficient property to provide for her reasonable needs in accordance with the standard of living of the parties established during the marriage. 11. Plaintiff is unable to support herself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 12. The Defendant is employed and enjoys a substantial income from which he is able to contribute to the support and maintenance of Plaintiff and to pay her alimony in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding Plaintiff from Defendant permanent alimony in such sums as are reasonable and adequate to support and maintain Plaintiff in the station of life to which she has become accustomed during the marriage. COUNT IV - ALIMONY PENDENTE LITE 1 5. Plaintiff is without sufficient income to support and maintain herself during the pendency of this action. 16. Defendant enjoys a substantial income and is well able to contribute to the support and maintenance of Plaintiff during the course of this action. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her reasonable alimony pendente lite during the pendency of this action. \I !I" . COUNT V - COUNSEL FEES AND EXPENSES 1 7. Plaintiff is without sufficient funds to retain counsel to represent her in this matter. 18. Without competent counsel, Plaintiff cannot adequately prosecute her claims against Defendant and cannot adequately litigate her rights in this matter. 19. Defendant enjoys a substantial income and is well able to bear the expense of Plaintiff's attorney and the expenses of this litigation. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay the legal fees and expenses incurred by Plaintiff in the litigation of this action. I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). DATE: I / S- / "000 f , ~~ Attorney for Plaintiff Supreme Court 10 17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 ,., ., DOROTHY SCHNEIDER. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ., " 'I 'I il '1 :: ! :1 , , WILLIAM R. SCHNEIDER, Defendant vs. CIVIL ACTION - LAW NO. ;; Of.X) - /4--r CIVIL TERM IN DIVORCE 'I .1 I '/ )1 !I ~OTICE TO--'2EFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the foregoing pages. you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and'a decree in divorce or annulment may be entered against :\ you by the court. A judgment may also be entered against you for any other claim or relief i i\ requested in these papers by the plaintiff. You may lose money or property or other rights II important to you, including custody or visitation of your children. II II I, ii 'i il ;1 'I l! :j Ii I' II d l' I , I I Ii " iI Ii ;! i' II When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, Pennsylvania 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY. DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. ., i' d j! l' " ': i; Cumberland County Bar Association 2 Liberty A venue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 Ii Ii II II Ii I, i: Ii :i 11 'I ,\ ;1 DOROTHY SCHNEIDER. :! Plaintiff . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA q i .1 q 'i 1 :\ vs. CIVIL ACTION - LAW i: I :1 WILLIAM R. SCHNEIDER. ;\ Defendant q l' , ! I NO. CIVIL TERM IN DIVORCE NOTICLOF A V AILABILlT'LOF C_OUNS_E.Uf1LG, TO THE WITHIN-NAMED DEFENDANT: 1\ 11 You have been named as the Defendant in a Complaint in a divorce proceeding filed in \1 the Court of Common Pleas of Cumberland County. This notice is to advise you that in i, II accordance with Section 3302(d) of the Divorce Code, you may request that the court II I I require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. .You are advised that this I I list is kept as a convenience to you and you are not bound to choose a counselor from this II II list. All necessary arrangements and the cost of counseling sessions are to be borne by you I, and your spouse. If you desire to pursue counseling. you must make your request for counseling within I I, Ii \1 twenty days of the date on which you receive this notice. Failure to do so will constitute a II Ii II ./ II I I II I! waiver of your right to request counseling. 'j f :, U q :\ ii il ,i tl " I, DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA '; :1 !I 'i I' 'i " :l vs. CIVIL ACTION - LAW :i il II Ii WILLIAM R. SCHNEIDER. " :1 Defendant ;1 '1 d " 'i H NO. CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE \j AND NOW comes the above-named Plaintiff, DOROTHY SCHNEIDER, by her attorney, !' : Samuel L. Andes, and makes the following Complaint in Divorce: I I 1. The Plaintiff is DOROTHY SCHNEIDER, who resides at 103 November Drive. I I I 'I Apartment 5, in Camp Hill, Cumberland County, Pennsylvania. II 2. The Defendant is WILLIAM R. SCHNEIDER, who resides at 207 Pennsylvania 'I l' Avenue in Camp Hill. Cumberland County. Pennsylvania. i ! i 3. Both the Plaintiff and Defendant have been bona fide residents of the Common- I \ wealth of Pennsylvania for at least six months immediately previous to the filing of this i I iI Complaint. 4. The Plaintiff and Defendant were married on 9 April 1982 in Cove Lake in Tennessee. 5. There have been no prior actions of divorce or annulment between the parties. I II II may have the right to request that the Court require the parties to participate in counseling. Ii \l iI I! II ,I I I 1 I II 6. This marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff COUNT I - IRRETRIEVABLE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree of Divorce. WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to the Divorce Code of Pennsylvania. COUNT II - EaUIT ABLUll..STRIB~N 9. During the course of the marriage, the parties have acquired numerous items of property, both real and personal. which are held in joint names and in the individual names of each of the parties hereto. WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the Defendant, to equitably divide the property. both real and personal, owned by the parties i I, !i II Ii iI I :! I' II 'I l' I i I I I II I' I 1 I I I I I II I hereto as marital property. .CJWNT III - ALIMONY 10. Plaintiff lacks sufficient property to provide for her reasonable needs in accordance with the standard of living of the parties established during the marriage. 11. Plaintiff is unable to support herself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 1 2. The Defendant is employed and enjoys a substantial income from which he is able to contribute to the support and maintenance of Plaintiff and to pay her alimony in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding Plaintiff from Defendant permanent alimony in such sums as are reasonable and adequate to support and maintain Plaintiff in the station of life to which she has become accustomed during the marnage. COUNT IV - ALIMONY PENDENTE LITE 1 5. Plaintiff is without sufficient income to support and maintain herself during the pendency of this action. 16. Defendant enjoys a substantial income and is well able to contribute to the support and maintenance of Plaintiff during the course of this action. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her reasonable alimony pendente lite during the pendency of this action. 'I II 11 . : I I ~I ;j . ' .1 , \1 'I COUNT V - CJl.U.NS.ELE.E.E.ND....EXPENSES 1 7. Plaintiff is without sufficient funds to retain counsel to represent her in this 'I matter. :! 18. Without competent counsel, Plaintiff cannot adequately prosecute her claims j :1 :1 :1 against Defendant and cannot adequately litigate her rights in this matter. :1 :1 19. Defendant enjoys a substantial income and is well able to bear the expense of " Plaintiff's attorney and the expenses of this litigation. ~2 075 ~~'!3!<" t2 7 $ :i J :.G: ~ 9'/0>> ;i WHEREFORE, Plaintiff prays this Honorable Cour 0 order Defendant to pay the legal ;j I! fees and expenses incurred by Plaintiff in the litigation of this action. iI .\ :i :1 II I verify that the statements made in this Complaint are true and correct. I understand Ii Il that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 'I !, i (unsworn falsification to authorities). i I I I I I I I DATE: I I I I I h iI II II I' I! I! II .1 II I I DOROTHY SCHNEIDER Samuel L. Andes Attorney for Plaintiff Supreme Court 10 17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 I! :I ...~ CERTIFICATE OF SERVICE I hereby certify that I served an original of the foregoing Motion for Sanctions upon the Defendant herein by regular mail, postage prepaid, addressed as follows: Date: ~ fMay 2003 Robert B. Lieberman, Esquire 500 North Third Street Harrisburg, PA 17101 r ; ltro Amy M Harkins Secretary for Samuel L. Andes C. (~.:. r:: r:- .. ..J .......... In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION DOROTHY T. SCHNEIDER ) Docket Number 00-147 CIVIL Plaintiff ) vs. ) PACSES Case Number 870105473 WILLIAM R. SCHNEIDER ) Defendant ) Other State ID Number Order AND NOW to wit, this JUNE 17. 2003 it is hereby Ordered that: THE CONFERENCE SCHEDULED ON THIS DATE IS CONTINUED GENERALLY AND MAY BE CALLED FOR RESCHEDULING BY EITHER PARTY. BOTH PARTIES ARE TO REPORT TO THE DOMESTIC RELATIONS SECTION THE DISPOSITION OF AN OUTSIDE AGREEMENT ON OR BEFORE AUGUST 1, 2003. DRO: RJ Shad day xc: plaintiff defendant Sarruel Andes, Esquire Robert Liebe:rrnan, Esquire BY THE COURT: MAILED ~ -/7-03 ,. j . JUDGE Service Type M Form OE-OOl Worker ID 21005 h, t.J C. ~_\~. ..or::', f-n: ~~~. -"..r (!.} (: _, .::1- Ci' r"l e ..,f,' 0" ___J '."") u DOROTHY SCHNEIDER, Plaintiff ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA vs. CIVIL ACTION - LAW WILLIAM R. SCHNEIDER. Defendants NO. 2000-147 CIVIL TERM IN DIVORCE REQUEST FOR PRODUCTION OF DOCUMENTS AND THINGS TO: WILLIAM R. SCHNEIDER 207 Pennsylvania Avenue Camp Hill, PA 17011 You are requested. in accordance with Pa. R.C.P. 4009, to deliver to the office of the undersigned at 525 North 12th Street, Lemoyne, Pennsylvania. or otherwise make arrangements reasonably satisfactory to the undersigned, for his inspection or examination, copies of the following documents, articles, and things. within twenty (20) days of the date of this Request. For purposes of this Request, all computer records and information available on computer records or within computer programs, should be included within the Request for Production. That is, this Request is not limited to documents or "hard copies" of records, but should include computer records, tapes, disks, and other media as well as paper documents. 1. Copies of any statements you have which reflects the benefits you have earned in your pension or retirement plan with IBM. The documents should specifically include any documents showing benefits that you will be entitled to receive at any future date on which you are eligible to retire and 1 .'1 any documents which will confirm monies you withdrew from the plan up to this time. 2. Copies of your federal and state income tax returns for the years 2000 and 2001. 3. Copies of your last three paycheck stubs. 4. Copies of statements showing the balance in any bank accounts, mutual funds. stock accounts, or other accounts or assets you hold with any financial institution. showing the balance in those accounts as of 1 December 1999 and the present. 5. Copies of any and all appraisals you have of the residence at 207 Pennsylvania Avenue, Camp Hill, Pennsylvania, for any time in the past or at the present. 6. Copies of statements showing the balance owed on any mortgage, home equity loan, or other debt which is secured by a lien against the residence at 207 Pennsylvania Avenue. The statements should show the balance owed on the liens both at the present time and as of 30 November 1999. 7. Copies of documents showing the present balance owed on any credit card or other debt owed at the time of separation which you claim to be a marital debt. 2 o c: ~ -oO:J D:,1C~ ~."),' (S\:i~.c. o 0) -1\ \-T"1 OJ t r ,. ",,; ~ C~C; :i; (i)~ Y'C-: :~; L-- -_.~ -<. o --n .-\ :~..,.".. :.l~: (5 :r\ t? ~ II CERTIFICATE OF SERVICE I hereby certify that I served an original of the foregoing Motion to Compel upon the Defendant herein by regular mail, postage prepaid, addressed as follows: Date: 3 February 2003 William R. Schneider 207 Pennsylvania Avenue Camp Hill, PA 17011 ClI~lfn, lHtu~ Amy M. H klns Secretary for Samuel L. Andes VERIFICATION I verify that the statements made in this Motion to Compel are true and correct. I understand that any false statements in this Motion to Compel are subject to the penaltie: of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: ~ ~ 03 ~~ 6. Plaintiff requires the information set out in her Request to properly prepare this case for litigation, settlement, or other disposition. Without that information the case cannot proceed in an orderly fashion. WHEREFORE, Plaintiff moves this court to enter the attached Order directing and compelling Defendant to produce the documents described in Plaintiff's Request for Production. . CJ~~. (\,nQ~ ~I L. A~ Attorney for Plaintiff Supreme Court 10 # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2000-147 CIVIL TERM WILLIAM R. SCHNEIDER, Defendant IN DIVORCE MOTION TO COMPEL AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, ar moves the court to compel the Defendant to respond to Plaintiff's Request for Productior of Documents and Things, based upon the following: 1. The moving party herein is the Plaintiff, Dorothy Schneider. The responding party herein is the Defendant, William R. Schneider. 2. The parties have been married for approximately twenty (20) years but have lived separate and apart since November of 1999. This divorce action was commenced January of 2000. 3. In December of 2002 Plaintiff, by her counsel. served upon the Defendant a Request for Production of Documents and Things in which he requested information abol some of the significant marital assets and liabilities in the case and information about Defendant's income. A copy of the Request is attached hereto and marked as Exhibit A. 4. The Request was served upon the Defendant by regular mail on 16 December 2002 and was sent to him by certified mail on 17 December 2002. A copy sent by regular mail was not returned to sender and it is assumed Defendant received that copy. The copy sent by certified mail has not been returned but the green receipt card has not been returned either and Plaintiff's counsel believes that Defendant has simply failed to accept the certified service of that copy. 5. To date, Defendant has not made any response to Plaintiff's Request and has not provided the documents requested. ---" DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2000-147 CIVIL TERM WILLIAM R. SCHNEIDER, Defendant IN DIVORCE ORDER OF COURT AND NOW this -::; ~ day of r--c.1rnJ':J ' 2003, upon Plaintiff's Motion, we hereby direct Defendant, William R. Schneider to produce the documents and things described in the Plaintiff's Request for Production of Documents and Things which is attached to her Motion to Compel or to otherwise respond as required by the Pennsylvania Rules of Civil Procedure, all within '30 days of the datE of service of a copy of this Order upon the Defendant. BY THE COURT. DISTRIBUTION: J. Samuel L. Andes, Esquire (Attorney for Plaintiff) 525 North 12th Street, Lemoyne, PA 17043 >~~ ..J,01-(j3 William R. Schneider (Defendant) 207 Pennsylvania Avenue. Camp Hill, PA 17011 ~.~ \:/1 f\j\//\-jASN t.J3 d ^If\!r~(~<J (i" f. "~T--~::8tl~no C:U :2 lld L - 81:1 SO :30 3~);.J.:.1CI . I I " . . I I , I I il COUNT V - COUNSEL FEfS.ANtLEXPENSES ,I 17. Plaintiff is without sufficient funds to retain counsel to represent her in this ;1 !j matter. :1 18. Without competent counsel, Plaintiff cannot adequately prosecute her claims i ,I :i :1 against Defendant and cannot adequately litigate her rights in this matter. :\ 'I oj I '1 19. Defendant enjoys a substantial income and is well able to bear the expense of Plaintiff's attorney and the expenses of this litigation. ~2 075 ~~~ " ;l. 7 :\ I ~ ~ < Cf/oei'/ il WHEREFORE, Plaintiff prays this Honorable Cour 0 order Defendant to pay the lega ii fees and expenses incurred by Plaintiff in the litigation of this action. :1 '. jj il I verify that the statements made in this Complaint are true and correct. I understan< Ii that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 'I I' i (unsworn falsification to authorities). ; DATE: DOROTHY SCHNEIDER I I II II II I I I I II I Samuel L. Andes Attorney for Plaintiff Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 I I ! :1 . i COUNT II - EQUITABLE DISTRIBUTION .! i 9. During the course of the marriage, the parties have acquired numerous items of 'i property, both real and personal. which are held in joint names and in the individual names ;1 il of each of the parties hereto. WHEREFORE, Plaintiff prays this Honorable Court. after requiring full disclosure by th Defendant, to equitably divide the property, both real and personal. owned by the parties " :1 hereto as marital property. II ,I I' :1 !I !I II II I i I I I II I kOUNT III - ALIMONY 10. Plaintiff lacks sufficient property to provide for her reasonable needs in accordance with the standard of living of the parties established during the marriage. 11. Plaintiff is unable to support herself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 12. The Defendant is employed and enjoys a substantial income from which he is able to contribute to the support and maintenance of Plaintiff and to pay her alimony in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding Plaintit from Defendant permanent alimony in such sums as are reasonable and adequate to sup pOI and maintain Plaintiff in the station of life to which she has become accustomed during the marriage. COUNT IV ~ ALIMONY PENDENTE LITE I , I . I pendency of this action. I II 1 5. Plaintiff is without sufficient income to support and maintain herself during the 16. Defendant enjoys a substantial income and is well able to contribute to the support and maintenance of Plaintiff during the course of this action. WHEREFORE. Plaintiff prays this Honorable Court to order Defendant to pay her reasonable alimony pendente lite during the pendency of this action. 'I 1\ !I . i I I I ,i l! DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNT' PENNSYLVANIA 'i :i 'I Ii ,: 'I CIVIL ACTION - LAW vs. " 1 :\ H 1/ II WILLIAM R. SCHNEIDER. :1 Defendant : ~ 11 q ., H \\ jl ! NO. CIVIL TERr IN DIVORCE C-'lMPLAINIJ.NJ)IVO RCE AND NOW comes the above-named Plaintiff, DOROTHY SCHNEIDER, by her attorne1 Samuel L. Andes, and makes the following Complaint in Divorce: I I 1. The Plaintiff is DOROTHY SCHNEIDER, who resides at 103 November Drive. , I I II Apartment 5. in Camp Hill. Cumberland County, Pennsylvania. II 2. The Defendant is WILLIAM R. SCHNEIDER, who resides at 207 Pennsylvania Avenue in Camp Hill, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Common- I wealth of Pennsylvania for at least six months immediately previous to the filing of this , I I Complaint. 4. The Plaintiff and Defendant were married on 9 April 1982 in Cove Lake in II Tennessee. 5. There have been no prior actions of divorce or annulment between the parties. 6. This marriage is irretrievably broken. II II may have the right to request that the Court require the parties to participate in counseling Ii II :1 II II I I I I 7. Plaintiff has been advised of the availability of marriage counseling and the Plaint COUNT I - IRRETRIEVABLE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree of Divorce. WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to tl Divorce Code of Pennsylvania. I I I I .1 ;1 :1 DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEA OF CUMBERLAND COUNTY, PENNSYLVANIA ;1 i i' d 'I .\ vs. CIVIL ACTION - LAW i! I Ii WILLIAM R. SCHNEIDER, :l Defendant :\ I , i NO. CIVIL TER~ IN DIVORCE NOTIC-E-QEA V AJlABllIT'L-OF C..oUN5-E..lIN_G; TO THE WITHIN-NAMED DEFENDANT: I You have been named as the Defendant in a Complaint in a divorce proceeding filed i il the Court of Common Pleas of Cumberland County. This notice is to advise you that in il accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street. Carlisle, Pennsylvania. .You are advised that this II list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by YOl and your spouse. If you desire to pursue counseling, you must make your request for counseling withi I I, I' II twenty days of the date on which you receive this notice. Failure to do so will constitute a II I I I ,I II I I I I , I waiver of your right to request counseling. . .; DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNT' PENNSYLVANIA ., ;l 'I :i I' IJ '! ., ;1 i WILLIAM R. SCHNEIDER, Defendant vs. CIVIL ACTION - LAW NO. 20DD - J4-7 CIVIL TERI IN DIVORCE 'I ,I NOTICE TQJ)EFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in th foregoing pages. you must take prompt action. You are warned that if you fail to do so. thE case may proceed without you and, a decree in divorce or annulment may be entered agaim 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 i marriage, you may request marriage counseling. A list of marriage counselors is available in ! the Office of the Prothonotary at: II ;1 it q Ii Ii \' I' ,I ,. il '/1 Ii it !! i! j! il Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle. Pennsylvania 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY. LAWYER'~ FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. i' d II n ii Cumberland County Bar Association 2 Liberty Avenue Carlisle. Pennsylvania 17013 Telephone: (717) 249-3166 Ii II II II II jl II DOROTHY SCHNEIDER. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2000-147 CIVIL TERM WILLIAM R. SCHNEIDER, Defendant IN DIVORCE MOTION FOR HEARING ON REQUEST FOR ALIMONY PENDENTE LITE AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, and moves the court for a conference at the Domestic Relations Office and, if necessary. a hearing on her request for alimony pendente lite first raised in her complaint in this matter, a copy of which is attached hereto. ~~ Attorney for Plaintiff Supreme Court ID # 17225 525 N. 12th Street Lemoyne, PA 17043 (717) 761-5361 Ode of t u..s /.dO) \iIN'vi\lASi\IN3d ) ! ~Jn{'('\ ' '-'II-'r,"rno \..l..l .., I ; \), .' .'..-, ,.~ ,.-li' \; ..,J...., VI .. Z :8 ~.J\J t' - I Hi,l ('(I o " " .. ,\ ~ .. "d '_ .. ; ::0 DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2000-147 CIVIL TERM WILLIAM R. SCHNEIDER, Defendant IN DIVORCE ORDER OF COURT AND NOW this day of , 2003. upon consideration of the attached Motion for Sanctions, it appearing that the Defendant has not complied with our order of February 7. 2003, we hereby order and decree as follows: 1. The Defendant is directed to sign any authorizations, consents, or other documents prepared by Plaintiff's counsel to permit him to obtain information directly from any source regarding the marital assets in this case, and to otherwise cooperate wi~h Plaintiff's counsel in an efforts necessary to obtain such information. 2. Plaintiff is awarded counsel fees in the amount of $500.00 to compensate her for the counsel fees she has incurred in an effort to obtain information which the Defendant has failed to produce in violation of our prior order. Defendant shall make payment of said sum directly to Plaintiff's attorney within twenty (20) days of the date of this order. 3. Plaintiff is awarded whatever counsel fees are reasonably incurred by her in attorney's continuing efforts to obtain the information requested from Defendant, including his efforts to obtain that information directly from any third-party sources. In the event that the parties canno' agree upon counsel fees, we will schedule an addit:onal proceeding to determine them. BY THE COURT, J. DISTRIBUTION: Samuel L. Andes, Esquire (Attorney for Plaintiff) 525 North 12th Street, Lemoyne, PA 17043 Robert B. Lieberman, Esquire (Attorney for Defendant) 500 North Third Street, Harrisburg, PA 17101 William R. Schneider (Defendant) 207 Pennsylvania Avenue, Camp Hill, PA 17011 II DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2000-147 CIVIL TERM WILLIAM R. SCHNEIDER, Defendant IN DIVORCE ORDER OF COURT C><\ , ()Jl tJu r/u-/Yt./T AND NOW this :<. /) -tA day of /11 ~. , 2003, a \;t.Il('1~ is hereby scheduled on the attached Motion for SanctYons, to be held before the undersigned. in Court Room No. Y of the Cumberland County Courthouse in Carlisle. Pennsylvania, commencing at :); 00 o'clock -,t2-.m. on ,1)1//l/Jda:;-. the I q 11\ day of Y--' /'fl.ll _ 2003. - BY THE COURT, _./)~. /1 J / / / / J. DISTRIBUTION: Samuel L. Andes, Esquire (Attorney for Plaintiff) 525 North 12th Street, Lemoyne, PA 17043 Robert B. Lieberman, Esquire (Attorney for Defendant) 500 North Third Street. Harrisburg, PA 17101 . ~~ 5., .2.]..0..3 William R. Schneider (Defendant) 207 Pennsylvania Avenue, Camp Hill. PA 17011 ~ ,~, ), ,. (,~\\~s:"\d ,",\l\\'1i\1~c'\" ...,_.",",\') '..: ,,-' '. I ~"~,,, ~.,:- '. ,....... ':.:.["\\ ~. t:\J~~\\ ; :j \ ,-, ...~\ ,\ DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2000-147 CIVIL TERM WILLIAM R. SCHNEIDER, Defendant IN DIVORCE MOTION FOR SANCTIONS AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, an moves the court for sanctions in this matter, based upon the following: 1. The moving party herein is the Plaintiff. Dorothy Schneider. The responding party herein is the Defendant, William R. Schneider. 2. In December of 2002 Plaintiff served upon Defendant a Request for Production of Documents and Things to obtain information about the marital assets in the case. 3. When the Defendant did not respond to Plaintiff's Request for Production of Documents and Things, this court, on Plaintiff's Motion to Compel, ordered Defendant to produce the documents requested within thirty (30) days of the date of service of that order. That order was dated 7 February 2003 and was served upon the Defendant short thereafter. Attached hereto and marked as Exhibit A is a copy of said order. 4. In early March of 2003 Defendant retained an attorney, Robert Lieberman. Esquire, to represent him in this matter. On 7 March 2003, Plaintiff's counsel provided Mr. Lieberman with a copy of this court's order to compel dated 7 February 2003. 5. Since 7 March 2003, Mr. Lieberman has acknowledged receipt of this court's order to compel and has provided to Plaintiff's counsel a portion of the documents requested which are the subject of this court's order to compel. 6. Defendant has still not complied with this court's order of 7 February 2003 an has not provided to Plaintiff or her counsel the documents ordered by this court, includir without any limitation, documents relating to Defendant's 401 (k) Plan with IBM and various withdraws he has made from that plan since this time. together with information regarding the martial residence. WHEREFORE, Plaintiff moves this court to sanction the Defendant for his failure to comply with the court's order of 7 February 2003 by awarding Plaintiff the counsel fees she has incurred in this matter to date and counsel fees she will incur in obtaining the information which is the subject of that order. s.m&-~~ Sam ndes Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 VERI FICA TION I verify that the statements made in this Motion for Sanctions are true and correct. I understand that any false statements in this Motion for Sanctions are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: ~~ SAMUEL L. ANDES DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2000-147 CIVIL TERM WILLIAM R. SCHNEIDER, Defendant IN DIVORCE MOTION FOR HEARING ON REQUEST FOR ALIMONY PENDENTE LITE AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, an moves the court for a conference at the Domestic Relations Office and, if necessary, a hearing on her request for alimony pendente lite first raised in her complaint in this matte a copy of which is attached hereto. s~QJ2, Attorney for Plaintiff Supreme Court 10 # 17225 525 N. 12th Street Lemoyne, PA 17043 (717) 761-5361 :,:~:,; C~'. ..::~", f -r(1 e VI NV/\lJSNN:1d ) I N"t~,,"" iT, \:-:U::1~:I\inr"'\ \J~ l I"~:"~ J ';"-',- "_-~'-\;../ l f\.J 6<; :8 . 'I"!l ('Ol L - AliIl" C" f..H/I.C:," JO .~ - j DOROTHY SCHNEIDER, Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE WILLIAM R. SCHNEIDER, Defendant/Respondent NO. 2000-147 CIVIL TERM IN DIVORCE Pacses# 870105473 ORDER OF COURT AND NOW, this 12th day of May, 2003, upon consideration of the attached Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shaddav on June 17. 2003 at 10:30 A.M. for a conference, at 13 N. Hanover St., Carlisle, P A 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: (1) 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 191O.11~ (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, George E. Hoffer, President Judge Mail copies on 5-12-03 to: < Petitioner Respondent Samuel Andes, Esquire Robert Lieberman, Esquire /} -.4~.Ji~_ R. J. adday, Conference Officer (' I YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND J 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. Date of Order: May 12, 2003 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 ..-t -'a,. rT f'tE~ t;..1" VINV!\lASNN3d I I' tr,r',"" '.''"', '~'-'I~rD A ; \jj " i, ",' ',J..~ ...,:<....11/ i' .....' '-' .. '",", . . , L~ :c " I Ii: ',i n '$ ~l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOROTHY SCHNEIDER, Plaintiff v. : NO. 2000-147 : CIVIL ACTION - LAW : IN DIVORCE WILLIAM R. SCHNEIDER, Defendant -------------------------------------------------------------------------------------------------------------------- DOROTHY SCHNEIDER, Plaintiff v. : NO. 00-146 : CIVIL ACTION - LAW : IN CUSTODY WILLIAM R. SCHNEIDER, Defendant -------------------------------------------------------------------------------------------------------------------- DOROTHY T. SCHNEIDER, Plaintiff v. : DOCKET NO. 846 S 1990 : P ACSES Case Number: 179101847 WILLIAM R. SCHNEIDER, Defendant ~ ~ER AND NOW, this ~ day of. , 2000, it is ORDERED, ADJUDGED and DECREED that: 1. The Rule to Show Cause is made Absolute; 2. The appearance of Barbara Sumple-Sullivan, Esquire, as counsel for the Plaintiff, William R. Schneider, in the above-stated action, is hereby withd awn. l~4U I~- 7-00 RX~ \11NV^1ASNN3d JJ.NnOO Oi\!'nH38V\lfl~ f]S :6 WV 9- :13000 Ao\!lCNCiiJ..C:,:\; _, .:10 3~)!j2~()-{]:rl ;,:i ~ " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOROTHY SCHNEIDER, Plaintiff v. : NO. 2000-147 CIVIL ACTION - LAW : IN DIVORCE WILLIAM R. SCHNEIDER, Defendant -------------------------------------------------------------------------------------------------------------------- DOROTHY SCHNEIDER, Plaintiff v. : NO. 00-146 : CIVIL ACTION - LAW : IN CUSTODY WILLIAM R. SCHNEIDER, Defendant -------------------------------------------------------------------------------------------------------------------- DOROTHY T. SCHNEIDER, Plaintiff v. : DOCKET NO. 846 S 1990 : PACSES Case Number: 179101847 WILLIAM R. SCHNEIDER, Defendant MOTION TO MAKE RULE ABSOLUTE AND NOW, this~ay of AI~ , 2000, comes Barbara Sumple-Sullivan, Esquire, and files the within Motion to withdraw for the following reasons: 1. Petitioner is Barbara Sumple-Sullivan, Esquire. 2. Respondents are William R. Schneider and Samuel L. Andes, Esquire. 3. On , Petitioner filed a Motion to Withdraw as Counsel for Client's Name. 4. On November 10, 2000, a Rule was issued, returnable within ten (10) days, to show cause why Petitioner should not be allowed to withdraw as counsel in this case. A copy of said rule is attached hereto as Exhibit A and incorporated here unto is incorporated by reference herein. .' " . 5. Copies of said Rule were served on Respondents by regular mail. Copies of said correspondence is attached as Exhibit B and incorporated by reference herein. 6. No objection has been filed to date. In fact, Samuel L. Andes, Esquire advised Petitioner that he has no objections to Petitioner's withdrawal. A copy of Attorney Andes' letter dated November 16, 2000 is attached as Exhibit C and incorporated by reference herein. 7. Having received no objection to date, Petitioner hereby requests leave to with draw as counsel for Defendant, William R. Schneider. WHEREFORE, Barbara Sumple-Sullivan, Esquire, requests that she be withdrawn as counsel of record. DATE: 1/- 2'> Afo cJ ara umple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court J.D. 32317 '. . EXHIBIT "A" ""~ ~~ ~ ~~ ~. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOROTHY SCHNEIDER, Plaintiff v. : 1 '1:1 : NO. 2000~ : CIVIL ACTION - LA W : IN DIVORCE WILLIAM R. SCHNEIDER, Defendant -------,._----------------------------------------------------------------------------------------------------------- DOROTHY T. SCHNEIDER, Plaintiff v. : NO. 00-146 : CIVIL ACTION - LAW : IN CUSTODY WILLrAM R. SCHNEIDER, Defendant -------------------------------------------------------------------------------------------------------------------- DOROTHY SCHNEIDER, Plaintiff v. : DOCKET NO. 846 S 1990 : P ACSES Case Number: 179101847 WILLlAM R SCHNEIDER, Defendant RULE ~ AND NOW, thi~~ day of K>>Ar: , , 2000 on consideration of the Petition - . ;.~ .. for Lea ve to Withdraw as Counsel, a RULE is issued on Plaintiff and Defendant to show cause, if any, why the Court should not grant the relief requested. The Rule is returnable within R days from the date of servi~ hereof. ;;; ~3'O t~ \\'\~ BY THE COURT: J. , . EXHIBIT IIBII o ", . , o LAW OFFICES BARBARA SUMPLE-SULLIVAN ~49 BRIDGE STREET NEW CUMBERLAND. PENNSYLVANIA 17070-1931 PHONE (717) 774-14~ FAX (717) 774-7009 November 14, 2000 Mr. William R Schneider 207 Pennsylvania Avenue Camp Hill, PA 17011 Samuel L. Andes, Esquire 525 North Twelfth Street P.O. Box 168 Lemoyne, P A 17043 Re: Schneider v. Schneider Dear Mr. Schneider and Attorney Andes: Enclosed constituting service on you is the Rule returnable within ten (10) days from the date of service. BSS/ld Enclosure .(;~~~~~ ,/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA D01~OTHY SCHNEIDER, Plaintiff v. ~ NO. 2000 k4~ : CIVIL ACTION - LAW : IN DIVORCE WILLIAM R SCHNEIDER, Defendant -------------------------------------------------------------------------------------------------------------------- DOROTHY T. SCHNEIDER, Plaintiff v. : NO. 00-146 : CIVIL ACTION - LAW : IN CUSTODY WILLrAM R SCHNEIDER, Defendant -------------------------------------------------------------------------------------------------------------------- DOROTHY SCHNEIDER, Plaintiff v. : DOCKET NO. 846 S 1990 : P ACSES Case Number: 179101847 WILLIAM R SCHNEIDER, Defendant RULE fA AND NOW, thi~~ day of " k}}.Ar: , . 2000 on consideration of the Petition for Lea \ e to Withdraw as Counsel, a RULE is issued on Plaintiff and Defendant to show cause, if any, why the Court should not grant the relief requested. 1be Rule is returnable within ~ days from the date of service hereof. BY THE COURT: ~ ~3'OC t~ \\'\~ J. EXHIBIT "e" ""-'" .' ".'~,:,;;.~'::i:t:l''':::: "-'~",,-,;:;:"~""_~\.-'<b_~'_'_.__. ~'_ __.-:..__ ~__.,--_~,' '~.;o~-, , '~----=.~:~_~.:.::_~.;.. _ . t: " . t, ~ o I~ \ . SAMUEL L. ANDES ATTORNEY AT LAW 525 NORTH TWELFTH STREET P. O. BOX 16B LEMOYNE, PENNSYLVANIA 17043 TELEPHONE (717) 761'15361 16 November 2000 FAX (717) 761-14315 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 RE: Schneider Dear Barb: My client and I do not oppose your request for leave to withdraw as Mr. Schneider's counsel in the three pending actions. If and when you withdraw, please send me a copy of the final order and your praecipe so I will know the process has been completed. Sincerely, ~i.~ Samuel L. Andes ~ cc: Dorothy Schneider .. ~. ~ '. .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOROTHY SCHNEIDER, Plaintiff v. : NO. 2000-147 : CIVIL ACTION - LA W : IN DIVORCE WILLIAM R. SCHNEIDER, Defendant -------------------------------------------------------------------------------------------------------------------- DOROTHY SCHNEIDER, Plaintiff v. : NO. 00-146 : CIVIL ACTION - LA W : IN CUSTODY WILLIAM R. SCHNEIDER, Defendant -------------------------------------------------------------------------------------------------------------------- DOROTHY T. SCHNEIDER, Plaintiff v. : DOCKET NO. 846 S 1990 : PACSES Case Number: 179101847 WILLIAM R. SCHNEIDER, Defendant VERIFICATION I, BARBARA SUMPLE-SULLIV AN, ESQUIRE, hereby certify that the facts set forth in the foregoing MOTION are true and correct to the best of my knowledge, information and belief, I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. ~4904 relating to unsworn falsification to authorities. I further aver that this Motion is not interposed for the purpose of delay. ra umple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court J.D. 32317 DATE: II/(%"'t/X)O .. t. 1. '. '.," IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOROTHY SCHNEIDER, Plaintiff v. : NO. 2000-147 : CIVIL ACTION - LAW : IN DIVORCE WILLIAM R. SCHNEIDER, Defendant DOROTHY SCHNEIDER, Plaintiff v. : NO. 00-146 : CIVIL ACTION - LAW : IN CUSTODY WILLIAM R. SCHNEIDER, Defendant DOROTHY T. SCHNEIDER, Plaintiff v. : DOCKET NO. 846 S 1990 : PACSES Case Number: 179101847 WILLIAM R. SCHNEIDER, Defendant CERTIFICATE OF SERVICE I, BARBARA SUMPLE-SULLIV AN, ESQUIRE, do hereby certify that on this date, I served a true and correct copy of the MOTION TO MAKE RULE ABSOLUTE, in the above- captioned matter upon the following individual(s), by United States first-class mail, postage prepaid, addressed as follows: DATE: /1/0;9 j;D . , Samuel L. Andes, Esquire 525 North fth Street . ,.- P.O. B 1 Le yn Mr. William R. Schneider 207 Pennsylvania Avenue Camp Hill, PA 17011 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court J.D. 32317 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOROTHY SCHNEIDER, Plaintiff v. : NO. 2000-147 : CIVIL ACTION - LAW : IN DIVORCE WILLIAM R. SCHNEIDER, Defendant DOROTHY SCHNEIDER, Plaintiff v. : NO. 00-146 : CIVIL ACTION - LAW : IN CUSTODY WILLIAM R. SCHNEIDER, Defendant DOROTHY T. SCHNEIDER, Plaintiff v. : DOCKET NO. 846 S 1990 : PACSES Case Number: 179101847 WILLIAM R. SCHNEIDER, Defendant PETITION FOR LEAVE TO WITHDRAW AS COUNSEL AND NOW, this~ 1fh day of October, 2000, comes Barbara Sumple-Sullivan, Esquire, and files the within Petition for Leave to Withdraw as Counsel for the following reasons: 1. On or about January 17, 2000, William R. Schneider, Defendant contracted with the law firm of Barbara Sumple-Sullivan, Esquire in connection with the above-referenced actions. " 2. Pursuant to that representation, the litigation involving this case is continuing. 3. Despite numerous requests, William R. Schneider has refused to make payment to counsel as agreed or otherwise contact and cooperate with counsel regarding this matter. 4. Defendant has not been cooperative in providing requested information and has not fulfilled his obligations to Movant and it would be a hardship for Movant to incur additional time and expense incident in this representation. WHEREFORE, Barbara Sumple-Sullivan, Esquire, requests that she be withdrawn as counsel and that William R. Schneider, be ordered and/or directed to find another counsel. Respectfully submitted, DATE: October n 2000 Barbara Sumple-Sullivan, 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court J.D. 32317 2 , . , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOROTHY SCHNEIDER, Plaintiff v. : NO. 2000-247 : CIVIL ACTION - LAW : IN DIVORCE WILLIAM R. SCHNEIDER, Defendant DOROTHY T. SCHNEIDER, Plaintiff v. : NO. 00-146 : CIVIL ACTION - LAW : IN CUSTODY WILLIAM R. SCHNEIDER, Defendant DOROTHY SCHNEIDER, Plaintiff v. : DOCKET NO. 846 S 1990 : PACSES Case Number: 179101847 WILLIAM R. SCHNEIDER, Defendant CERTIFICATE OF SERVICE I, BARBARA SUMPLE-SULLIV AN, ESQUIRE, do hereby certify that on this date, I served a true and correct copy of the PETITION FOR LEAVE TO WITHDRAW AS COUNSEL, in the above-captioned matter upon the following individuals by first class mail, postage prepaid, addressed as follows: Mr. William R. Schneider 207 Pennsylvania Avenue Camp Hill, PA 17011 Samuel L. Andes, Esquire 525 North Twelfth Street P.O. Box 168 Lemoyne, P" 17043 DATE: October n, 2000 ;/ Barbara Sump Ie-Sullivan, Esquire 549 Bridge Street New Cumberland, P A 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 -' r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOROTHY SCHNEIDER, Plaintiff v. WILLIAM R. SCHNEIDER, Defendant : NO. 2000-~ JJI7 /' : CIVIL ACTION - LAW : IN DIVORCE -------------------------------------------------------------------------------------------------------------------- DOROTHY T. SCHNEIDER, Plaintiff v. WILLIAM R. SCHNEIDER, Defendant : NO. 00-146 : CIVIL ACTION - LAW : IN CUSTODY -------------------------------------------------------------------------------------------------------------------- DOROTHY SCHNEIDER, Plaintiff v. WILLIAM R. SCHNEIDER, Defendant AND NOW, this K day of : DOCKET NO. 846 S 1990 : PACSES Case Number: 179101847 RULE dJ~ , 2000 on consideration of the Petition for Leave to Withdraw as Counsel, a RULE is issued on Plaintiff and Defendant to show cause, if any, why the Court should not grant the relief requested. ..... '), The Rule is returnable within ~ days from the date of service hereof. ~ 0 l~\,\i< 1. VlNVA1ASNN3d -"'lNn08 Qi\!\nH38VmO t;s : I i,ld S I (ION 00 AHvl00IC,.il,. DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2000-147 CIVIL TERM WILLIAM R. SCHNEIDER, Defendant IN DIVORCE PRAECIPE TO THE PROTHONOTARY: I hereby enter my appearance on behalf of the Defendant, William R. Schneider. hereby accept service of the Divorce Complaint and acknowledge receipt of a copy of the same. Date: 1-3/ - 2tJO 0 arbara Sumple Sullivan Attorney for the Def~ '7 Supreme Court 10 # / -: , o ?? 0[1,'1 m(: --,. -~ L.. .' Zr: en . ..:< ~ i:C) 5C c z ~ c) ':~J ..',.:-, I r. . ~,'" '} t..- ::;l CO iff DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. WILLIAM R. SCHNEIDER, Defendant CIVIL ACTION - LAW NO. 2000-147 CIVIL TERM IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Plaintiff moves the court to appoint a Master with respect to the following claims: ( ) Divorce ( ) Annulment { Xl Counsel Fees { Xl Distribution of Property ( X) Alimony ( Xl Costs and Expenses ( ) Support ( X) Alimony Pendente Lite and in support of the motion states: 1. Discovery is complete as to the c1aim(s) for which the appointment of a Master is requested. 2. The Defendant has appeared in the action by her attorney, P. Richard Wagner, Esquire. 3. The statutory ground for divorce is: 3301 (dl 4. Check the applicable paragraph(s): ( I The action is not contested. ( I An agreement has been reached with respect to the following claims: (X ) The action is contested with respect to the above-marked claims. .2/ Date 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take _ hours 1 day. 7. Additional information, if any, relevant~t this motion: N,ll1 LOtJ2 ,-~~TfJ::e~ ,f) Sa . Andes Attorney for Plaintiff AND NOW ~ 0f-.:1- 2002, E. Robert Elicker, II, Esquire is appointed Master with respect to the above claims. ~~~ 1 ' I'R'KS 1/ .~~ -'0 cSt ~. l..0qqneP-. /" n nAe.s BY THE COURT, f7J. 'IlN~^1^SNN34 ,UNn08 GN'fiH39V'tf'\O t:~ :\\ ~~ ZZ hON ZO ^\:l'1.LONCk\.;.,C~.;t"j ::H1. ~o ~)H~O-Q3^\\~ ,. . ..'1 , '/:-,_'1. ~ ADDENDUM Summary of Cases on Attachment Defendant/Obligor: SCHNEIDER, WILLIAM R. PACSES Case Number 870105473 Plaintiff Name DOROTHY T. SCHNEIDER Docket Attachment Amount 00-147 CIVIL $ 776.00 Child(ren)'s Name(s): PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB DOB If you are required to enroll the child(ren) above in any health insurance coverage available through the employee's/obligor's employment. Dlf 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 Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB DOB o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB DOB If checked, you are required to enroll the child(ren) above in any health insurance coverage available the employee'slobligor's employment. dlr~~~~~:~,~~~~~~;~~ir~~~~~~~II~~~~~il~(~:~)><< 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 OMB No.: 097().{)154 o ~~; ri'l ~f; ~~_:} , Zl.~ Si~ ~.:. t;~. C ,) ~~.f2 Pc -7 ~:::\ =< .3 r'~ t~t E', ,...., = ~ :x :t'1'" -< t J;:" -0 ::t: o -n ~-n I1'F -om ~oo ~-) L. c~o :r: ~~ (,;;; (") L':...rn ~ :?-: :Q w ., o N ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If c.hecked you are required to provide a (:opy of this form to your employee. If your employee works in a state that is ditterent from the state that issued this order, a copy must be provided to your employee even if the box is not checked. 1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned businesses located on a reservation that choose to withhold in accordance with this notice. 2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 4. * Reporting ti,e PaydatelDate of VVithholding. You must report the paydMeldate of withholding vvl,en sending the payment. The paydateldate of vvithholding is the date on vvhie" amount .'vas ....ithheld from the employee's vvages. You must comply with the law ofthe state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 5. * Employee/Obligor with Multiple Support Holdings: If there is more than one OrderfNotice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #10 below) 6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S 10: 5213127730 EMPLOYEE'S/OBLlGOR'S NAME: EMPLOYEE'S CASE IDENTIFIER: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: SCHNEIDER. WILLIAM R. 1151100455 DATE OF SEPARATION: 7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed govems. 9. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 10. * Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.c. 91673 (b)1; or 2) the amounts allowed by the State of the employee'slobligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 11. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: DOMESTIC RELATIONS- SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATIACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (7171 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Worker ID $IATT Service Type M OMB No.: 097().()154 ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT i o Original Order/Notice o Amended Order/Notice o Terminate Order/Notice State Commonwealth of Pennsylvania Co.lCity/Dist. of CUMBERLAND Date of Order/Notice 04/30/04 Tribunal/Case Number (See Addendum for case summary) ~:SCHNEIDER, WILLIAM R. Employee/Obligor's Name (Last, First, MI) Employer/Withholder's Federal EIN Number VERIZON SERVICES CORPORATION* C/O ATTN: GARN 2ND FL PAYROLL 7200 CHESTNUT ST UPPER DARBY PA 19082-3125 W, ..{P()(J- /'17 (I, V/L ~t) ?70/o9,L?3 193-38-9270 Employee/Obligor's Social Security Number 1151100455 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, Mil See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's./obligor's income until further notice even if the Order/Notice is not issued by your State. $ 776.00 per month in current support $ 0 . 00 per month in past-due support Arrears 12 weeks or greater? 0 yes <X) 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 $ 776.00 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: $ 179.08 per weekly pay period. $ 358.15 per biweekly pay period (every two weeks). $ 388.00 per semimonthly pay period (twice a month). $ 776.00 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 paydateldate of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #10 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: P A SCOU Send check to: Pennsylvania SCOU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER 10 (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. Date of Order: HAY 0 3 200'. Service Type M OMB No.: 0970-01S4 ADDENDUM Summary of Cases on Attachment Defendant/Obligor: SCHNEIDER, WILLIAM R. PACSES Case Number 179101847 Plaintiff Name DOROTHY T. SCHNEIDER Docket Attachment Amount 846:S:l99 0 $ 50.00 Child(ren)'s Name(s): .:rClN~THAN L. . SGHNE:IpEI( PACSES Case Number 870105473 Plaintiff Name DOROTHY T. SCHNEIDER Docket Attachment Amount 00-147 CIVIL $ 776.00 Child(ren)'s Name(s): DOB If checked, you are required to enroll the child(ren) above in any health insurance coverage available the employee's!obligor's employment. you are required to enroll the child(ren) in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB DOB o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB DOB :::".::-:::::.>:-"::,:;-::-:'";>;..:-.;.;:;::::::.;:-:::":::::::-::.::.:.::.:::::::.:>,..:.::".:...::::::":::::'..:::::::'-::::.:::"':::::::::::::'::::::::'::'.;";.::::.:-::::::::::::.::::::::::.:;:;::::";:;.::;:;:;:..;:::/;::;.;;:;:;.;..:;:::::;.;:-: . .....",........ "". ,...."" ,". ",", ......."... .... -"," .... ........ ............" .,.. ..........................................................-:.......... ........................'...............,......'........'..'.'....,.',.,.....,.'.. .......... .... .-:,..' " ............. ........ . . . .'. . . . '. . ..... '. . . . . . .. ... . .. ........ .. .. '.,..," .' ..... . .' . . o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. :;:~:;:~: ::~: ~ :~:~: ~::;~:~:: :~; ~ :::~. ~:::: :~:~:~ :~:::~: ::::::.:: :~::::: /> ::::.:::<< :~:::> ::}}\:: :~>~:~:::::: :~< <:: ::: ~::::;~:;::::: ;:( ::: \:)(/:~: ~:):~: ::: .)~ :::::; <:~ :;:? :,:: :;::;:.::::' .:: ':.> :: . '. .. ..,................... . . .. ." . .. .. ............ . . , . . .. ... ........ .. ..,............. .. o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's!obligor's employment. Addendum Form EN-028 Worker ID $IATT Service Type M OMS No.: 0970-0154 8 :?' J;;l .~ mR1. Z~' 2;:':.' OJ'::': -C,- ~C; ~_.-. (. .' C) j>C~ 2: :< '0 o w 0') r., -0 N <'.0 o 11 --.1 ~I: . r; . .r:c 8 ._~ (~) - - - -~r, ;~J6 urn ~ ::? :'.,,) ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If \;.hecked you are required to provide a ~opy of this form to your ~mployee. If YOl,lr employee works in a state that is different from the state that issued this order, a copy must be provided to your employee even if the box is not checked. 1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned businesses located on a reservation that choose to withhold in accordance with this notice. 2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withhold ing. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 4. * Reporting the Paydate/Date of Withholding. You must report the paydateldate of withholding ~hen sending the payment. The pal'dateldate of ..ithholding is the date on ..hien amount ..as ..ithheld from the employee's ..ages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 5. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #10 below) 6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S 10: 5213127730 EMPlOYEE'S/OBlIGOR'S NAME: EMPLOYEE'S CASE IDENTIFIER: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: SCHNEIDER, WILLIAM R. 1151100455 DATE OF SEPARATION: 7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 10. * Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (1 5 U .5.c. S 1673 (b)l; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 11. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: DOMESTIC RELA TrONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATIACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Worker ID $IATT Service Type M OMB No.: 0970-0154 "~~tlif.)\1!~\~t~~~' ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT o Original Order/Notice @ Amended Order/Notice o Terminate Order/Notice State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 09/26/03 Tribunal/Case Number (See Addendum for case summary) ~:SCHNEIDER, WILLIAM R. Employee/Obligor's Name (last, First, MI) EmployerANithholder's Federal EIN Number VERIZON SERVICES CORPORATION* C/O ATTN: GARN 2ND FL PAYROLL 7200 CHESTNUT ST UPPER DARBY PA 19082-3125 193-38-9270 Employee/Obligor's Social Security Number 1151100455 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (last, First, MI) dRl 9tj~ 8 /996 ;?~5 /79/DI ~tj7 Mf, dtJOO -I L/7 (! f vi L ;J/j1S'Z~ g7{)/D9I72> See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 776.00 per month in current support $ 0 . 00 per month in past-due support Arrears 12 weeks or greater? ex> yes 0 no $ 50.00 per month in medical support $ 0 . 00 per month for genetic test costs $ per month in other (specify) for a total of $ 826.00 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: $ 190.62 per weekly pay period. $ 381.23 per biweekly pay period (every two weeks). $ 413.00 per semimonthly pay period (twice a month). $ 826.00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate!date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's! obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #10 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU , P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. ~.' ~. l?';:,t....~. 1fr~.. . ILfJJlY THE 0 Date of Orde. 2 9 _ -.C Service Type M j . E' 67UtU"t!- Form EN-028 Worker ID $IATT OMB No.: 0970-01 S4 .... DOROTHY T. SCHNEIDER, Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CML ACTION - DIVORCE WILLIAM R. SCHNEIDER, Defendant/Respondent : NO. 2000-147 CIVIL TERM IN DIVORCE Pacses# 870105473 ORDER OF COURT AND NOW, this 1 ih day of July, 2003, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $N/A and Respondent's monthly net income/earning capacity is $N/ A, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $776.00 per month payable monthly as follows; $776.00 for alimony pendente lite and $0.00 on arrears. First payment due the first pay date after august 1,2003. Arrears set at $0.00 as of July 17, 2003. The effective date ofthe order is August 1,2003 This order is based upon an agreement of the parties through their counsel. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C.S.s 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the P A SCDU to: Dorothy T. Schneider. 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, PAl 71 06-911 0 Payments must include the defendant's P ACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. t._"" ,~) t'~\ tC--r. \3' V!r\I\/<,\lA"S\!,i\~3d -c:O;"U18 EU:8 f (; IHJ f~O ... .... 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. ORO: R. J. Shadday Mailed copies on 7-17-03 to; < BY THE COURT, Petitioner Respondent Robert Liebennan, Esquire Samuel Andes. Esquire George E. Hoffer, ,. J. PRESIDENT J. . . DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW WILLIAM R. SCHNEIDER, Defendant NO. 2000-147 CIVIL TERM IN DIVORCE NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counteraffidavit within twenty (20) 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 1. The parties to this action separated in late November, 1999, and have continued to live separately 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 if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: O~LLA /b, ;}oac2.. I " ) ( ~') . ,... DOROTHY SCHNEIDER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. . NO. 2000 - 147 - CIVIL TERM WILLIAM R. SCHNEIDER, Defendant CIVIL ACTION - LAW IN DIVORCE STIPULATION FOR ENTRY OF COURT ORDER IT IS HEREBY STIPULATED AND AGREED by and between Plaintiff, Dorothy Schneider, represented by Samuel L. Andes, Esquire and Defendant, William R. Schneider, represented by Robert B. Lieberman, Esquire that a lump sum Alimony Order be entered in the amount of Fourteen Thousand Four Hundred ($14,400) Dollars, in connection with the above case, to be paid through and enforced by the Domestic Relations Office of Cumberland County at the rate of $400.00 per month effective June 1,2005. Husband shall receive credit for any payments received by the Domestic Relations Office in Cumberland County subsequent to June 1,2005. The payments shall be non-modifiable and shall terminate upon the death of either party and shall not be included in Wife's income nor deducted from Husband's income. ~f!-.~ William R. Schneider, Defendant ,a~.~o S elL. Andes, quire · Attorney for Plaintiff ~~.~ Robert B. Lieberman, Esquire Attorney for Defendant g ~ ~~l -"'s;: ~.~ KC! '):0 c; ~2 -7 ~ , .t., ~ ~ 6 ..c. N \D ~ C!? f') \..0 . ~ ~:o :B~ 0(-, ::;;i.f; ....-(1 0("5 z~ 0'" ~ ~ n DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. CIVIL ACTION - LAW NO. 2000-147 WILLIAM R. SCHNEIDER, Defendant IN DIVORCE JOINT MOTION FOR ENTRY OF QUALIFIED DOMESTIC RELATIONS ORDER AND NOW come the above-named parties, by their attorneys, and jointly move the court to enter the attached Qualified Domestic Relations Order to implement one of the provisions of the Separation and Property Settlement Agreement between them dated 3 October 2006. ~ Samuel L. Andes Attorney for Plaintiff ~~.~ Robert B. Lieberman, Esquire Attorney for Defendant Dorothv Schneider Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 2000-147 William R. Schneider Defendant IN DIVORCE CIVIL ACTION - LAW QUALIFIED DOMESTIC RELATIONS ORDER ffiM RETffiEMENT PLAN IT IS HEREBY ORDERED AS FOLLOWS: This Order is intended to serve as a Qualified Domestic Relations Order ("Order") by which a division and disposition of the Participant's benefit under the IBM Personal Pension Plan will be and is made according to the provision of Sections 401(a)(13) and 414(p) of the Internal Revenue Code of 1986, as amended ("IRC") and Section 206 of ERISA ("ERISA"). 1. William R. Schneider is a Participant in the IBM Personal Pension Plan (the "Plan"). Dorothy Schneider is the former spouse of the Participant and is the Alternate Payee as defined under IRC Section 414(p). 2. All notices and other communications by and to the Participant, the Alternate Payee and the Plan Administrator shall be mailed by first class mail, postage prepaid, to the following address: To Participant: William R. Schneider 207 Pennsylvania Avenue Camp Hill, PA 17011 SSN: 193-38-9270 Birth Date: May 19, 1955 To Alternate Payee: Dorothy Schneider 63 North 31st Street Camp Hill, PA 17011 SSN: 403-82-5674 Birth Date: June 19, 1954 , . QDRO Page 2 To Plan Administrator: IBM Personal Pension Plan c/o IBM QDRO Administration P.O. Box 550980 Jacksonville, FL 32255-0980 Any of the parties may designate another address for the purpose of receiving notices and communications pursuant to this Order by giving written notice to the other parties at the addresses then currently in effect. 3. The allocation and disposition of the Participant's benefit under the Plan relates to a provision of marital property rights and is in accordance with 23 Pa. C.S. ~3305 of the Commonwealth of Pennsylvania. The interest allocated by this Order is the Participant's accrued core. 4. The Alternate Payee is awarded under the dividing method as the Alternate Payee's separate property an amount equal to 37% of the Participant's accrued core benefit as of the date the Alternate Payee commences benefits. 5. (a) The Plan is ordered to pay directly to the Alternate Payee, in full satisfaction of the Alternate Payee's interest in the Plan as awarded herein, a monthly benefit commencing no later than the date the Participant commences benefits and continuing for the life of the Alternate Payee. The Alternate Payee shall have the option to elect one of the forms of payment offered by the Plan (with the exception of a joint and survivor annuity for a subsequent spouse) at the time of the Alternate Payee's commencement. (b) The Alternate Payee may commence receipt of benefits from the Plan on or after the earliest date on which the Participant would be able to commence receipt of benefits under the Plan by providing six months advance written notice to the Plan. The earliest date will be the date that the Participant would be eligible to receive core retirement benefits if the Participant had terminated employment (or reached earliest retirement date or vested rights income begins), whether or not the Participant actually elects to retire or begin receiving vested rights benefits. If this option is exercised, there will be an actuarial reduction in the Core benefit for the number of years and months that the Participant is under age 65 at commencement of payment to the QDRO Page 3 Alternate Payee. If this option is not exercised, the core payments to the Alternate Payee will commence when the Participant commences receipt of benefit payments. (c) If an option of early commencement of core benefits is exercised by the Alternate Payee, the Alternate Payee shall share proportionately in any early retirement subsidy made available to the Participant at the time of the Participant's commencement of benefits. 6. The Alternate Payee shall share in any possible postretirement plan improvements. If the Alternate Payee elects early payment, then, per Section 414(p)(4)(A) of the Internal Revenue Code and Section 206 of ERISA, the Alternate Payee is not allowed to share in any Plan improvements. 7. The Alternate Payee is the former spouse of Participant and is eligible for Pre- Retirement Spouse Protection (PRSP). The Alternate Payee will receive a PRSP benefit equal to 50% of the Alternate Payee's interest in the core benefit as awarded herein, reduced for joint and survivorship feature based on the ages of the Participant and Alternate Payee as the PRSP start date. There will be further reductions as specified in the IBM Retirement Plan if the PRSP benefit will be paid prior to the date the Participant could have received an unreduced retirement benefit. If the Alternate Payee commences benefits prior to the Participant's death, no PRSP shall be available. 8. The Participant and Alternate Payee shall each be responsible for his or her own Federal, state and local income and other taxes attributable to any and all payments from the plan which are received by Participant and Alternate Payee, respectively. The plan shall provide to Participant and Alternate Payee in accordance with its customary procedures such information as is normally provided to Participants in the plan with respect to the taxation of distributions from the plan. 9. This Court reserves jurisdiction over the parties and the Plan until such time as all obligations of the Plan to the Alternate Payee under this Order have been fully paid and discharged. I .. It. , . QDRO Page 4 10. No provision ofthis Order shall be construed to require the Plan, the Plan Administrator or any trustee or other fiduciary with respect to the Plan to take any action which is inconsistent with any provision of the Plan as now in effect or hereafter amended. 11. No provision in this Order shall be construed to require the Plan to (a) make any payment or take any action which is inconsistent with any Federal law, rule, regulation or applicable judicial decision; (b) provide any type or form of benefit, or any option, which is not otherwise provided under the provisions of the Plan and specifically authorized by this Order; (c) provide increased benefits (determined on the basis of actuarial value); or (d) pay benefits to any Alternate Payee which are required to be paid to another Alternate Payee under another order previously determined to be a Qualified Domestic Relations Order. 12. The undertakings and obligations of the IBM Personal Pension Plan as set forth in this Order are solely those of the Plan. Neither IBM Corporation, any of its subsidiaries or affiliated corporations, nor any officer, employee or agent of any of the corporations (other than the Plan Administrator) shall be deemed to have made any undertakings or incurred any obligations as a result ofthis Order. 13. Notwithstanding any other provision ofthis Order, in the event that the Participant, Alternate Payee or any other party claiming rights under this Order shall make any claim which the Plan Administrator shall determine to be inconsistent with the provisions of this Order or with any provision of the Retirement Equity Act of 1984, as amended, the Plan may forthwith cease making any further payments to any person whose rights under the Plan, in the sole judgment of the Plan Administrator, may be affected by such claim pending resolution of such claim or further order of this Court, and the Plan may also take such further action or actions as may be permittedaby law with respect to such claim and/or this Order. BY THE COURT: Date: SEPARATION AND PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, made this 3cd day of OcfAbe~r ,2006, by and between WILLIAM R. SCHNEIDER, now of Camp Hill, Cumberland County, Pennsylvania, hereinafter referred to as "Husband", -AND- DOROTHY SCHNEIDER, now of Camp Hill, Cumberland County, Pennsylvania, hereinafter referred to as "Wife", WITNESSETH: WHEREAS, Husband and Wife were lawfully married on April 9, 1982, in Cove Lake, Campbell County, Tennessee; and WHEREAS, two children were born of the marriage namely; BRIAN W. SCHNEIDER and JONATHAN L SCHNEIDER; and WHEREAS, certain differences have arisen between the parties as a result of which they have separated and now live separate and apart from one another and are desirous, therefore, of entering into an Agreement which is considered to be an equal division of all joint property and will provide for their mutual responsibilities and rights growing out of the marriage relationship. NOW, THEREFORE, in consideration of the premises and of the promises, covenants and undertakings hereinafter set forth, and for other good and valuable consideration, the receipt of which is hereby acknowledged by each of the parties hereto, Husband and Wife, each intending to be legally bound hereby, covenant and agree as follows: 1. SEPARATION. It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place as he or she may from time to time choose or deem fit. The foregoing provisions shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness ofthe causes leading to their living apart. Each party shall be free from interference, authority and contact by the other, as fully as if he or she were single and unmarried except as may be necessary to carry out the provisions of this agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 2. SUBSEQUENT DIVORCE. The parties hereby acknowledge that Wife has filed a Complaint in Divorce in Cumberland County, Pennsylvania, on January 10,2000 docketed to No. 2000-147 Civil Term claiming that the marriage is irretrievably broken under , the no-fault, mutual consent provision of Section 3301(c) of the Pennsylvania Divorce Code. Husband and Wife hereby express their agreement that the marriage is irretrievably broken and each express their intent, contemporaneously herewith, to execute any and all affidavits, waivers or other documents necessary for the parties to obtain an absolute divorce pursuant to Section 3301(c) of the Divorce Code. The parties hereby waive all rights to request Court-ordered counseling under the Divorce Code. Neither party to such action shall seek alimony or support contrary to the provisions of this Agreement. It is further specifically understood and agreed by the parties that the provisions of this Agreement relating to equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever, as contemplated by the Pennsylvania Divorce Code. -2- Should a decree, judgment, order of separation or divorce be obtained by either of the parties in this or any other state, country or jurisdiction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be effected in any way by any such separation or divorce; and that nothing in any such decree, judgment, divorce or order of separation or further modification or revision thereof shall alter, amend or vary any term of this Agreement, whether or not either or both of the parties shall remarry, it being understood by and between the parties hereto that this Agreement shall survive and shall not be merged into any decree, judgment, order of separation or divorce. It is specifically agreed, however, that a copy of this Agreement or the substance of the provisions thereof, may be incorporated into any divorce, judgment or decree. This incorporation, however, shall not be regarded as a merger, it being the specific intent of the parties to permit this Agreement to survive any judgment or decree and to be forever binding and conclusive upon the parties. 3. EFFECTIVE DATE. The effective date of this Agreement shall be the "date of execution" or "execution date", defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 4. DEBTS AND OBLIGATIONS. Husband represents and warrants to Wife that he has not, and in the future he will not, contract or incur any debt or liability for which Wife or her estate might be responsible, and he shall indemnify and save Wife harmless from any and all claims or demands made against her by reason of such debts or obligations incurred by him, except as otherwise set forth herein. -3- Wife represents and warrants to Husband that she has not, and in the future she will not, contract or incur any debt or liability for which Husband or his estate might be responsible, and she shall indemnify and save Husband harmless from any and all claims or demands made against him by reason of such debts or obligations incurred by her, except as otherwise set forth herein. 5. MUTUAL RELEASES. Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all causes of action, claims, rights or demands whatsoever in law or equity, which either of the parties ever had or now has against the other, except any and all cause or causes of action for divorce and except any or all causes of action for breach of any provisions of this Agreement. Further, each party does hereby remise, release, quitclaim and forever discharge the other and the estate of the other from any and every claim that each other may now have, or hereafter have or can have at any time, against the other, or in and to or against the other's estate, or any part thereof, whether arising out of any former contracts, engagements or liabilities of the other, or by way of dower or claim in the nature of dower, widow's rights, or under the intestate laws, or the right to take against each other's will, or for support or maintenance, or of any other nature whatsoever, except any rights accruing under this Agreement. 6. DIVISION OF HOUSEHOLD AND PERSONAL PROPERTY. The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances and other household personal property between them. The -4- parties mutually agree that Wife shall, from and after the date hereof, be the sole and separate owner of all such tangible personal property presently in her possession and that Husband hereby releases and relinquishes any right, title or interest he may have had in the past or now has in the tangible personal property in Wife's possession. The parties further agree that Husband shall, from and after the date hereof, be the sole and separate owner of all such tangible personal property presently in his possession and that Wife hereby releases and relinquishes any right, title or interest she may have had in the past or now has in the tangible personal property in Husband's possession. 7. VEHICLES. Wife shall retain possession and ownership of any vehicles presently in her possession, free and clear of any claim, right, title or interest in said vehicles on the part of Husband. Husband shall retain possession and ownership of any vehicles presently in his possession free and clear of any claim, right, title or interest in said vehicles on the part of Wife. 8. REAL ESTATE The parties acknowledge that they previously owned a marital residence located at 207 Pennsylvania A venue, Camp Hill, Cumberland County, Pennsylvania. Wife has executed a deed transferring all of her right, title and interest in and to the aforesaid marital residence to Husband. Husband shall assume as his sole obligation all of the expenses incident to the use of the aforesaid marital residence including, without limitation, any and all mortgage payments, liens, taxes, liability and fIre insurance, utilities, sewer, water, refuse collection, assessments, proper maintenance, repairs, additions and improvements and he further covenants and agrees to -5- indemnify and hold Wife harmless from any such liabilities, obligations or expenses or any claims or demands as a result hereof. 9. SEPARATE ASSETS. The parties hereby agree that, as to all assets not specifically mentioned herein which are presently titled in the sole name of one of the parties hereto or, if untitled, are presently in the sole possession of one or more of the parties hereto, the party not having title thereto or possession thereof hereby waives, releases, relinquishes and forever abandons any and all claims therein, and acknowledges that the party having title or possession of such items shall be the sole and exclusive owner thereof. 10. RETIREMENT AND PENSION PLANS. Each of the parties acknowledges that Husband has a pension plan through his former employment with IBM. The marital portion of the aforesaid pension plan shall be divided equally pursuant to the Qualified Domestic Relations Order prepared by Harry M. Leister of Conrad Siegel, Inc. The costs and expenses to prepare the Qualified Domestic Relations Order shall be shared equally between the parties hereto. 11. TRANSFERS SUBJECT TO EXISTING LIENS. Notwithstanding any other provisions in this document, all property transferred hereunder is subject to the lien or liens that may exist. The respective transferee of such property agrees to indemnify and save harmless the other party from any claim or liability that such other party may suffer or may be required to pay on account of such lien or encumbrance. 12. PROPERTY SETTLEMENT. Husband hereby agrees to pay to Wife lump sum alimony in the amount of Fourteen Thousand Four Hundred ($14, 400.00) Dollars. The aforesaid sum shall be paid through and administered by the Domestic Relations Office of -6- Cumberland County, Pennsylvania pursuant to the existing Order docketed to No. 846 S 1990. The aforesaid Order shall be payable at the rate of Four Hundred ($400.00) Dollars per month effective June 1,2005 and Husband shall receive credit against the aforesaid lump sum amount for any payments made through the Domestic Relations Office subsequent to June 1,2005. The payments shall be non-modifiable and shall not be included in Wife's income nor deducted from Husband's income. The payments shall not be treated by either party as alimony for income tax purposes and the payments received by Wife shall not be taxable to her for income tax purposes. 13. EQUITABLE DISTRIBUTION. By this Agreement the parties have intended to effect an equitable division of their jointly owned property. The parties have determined that an equitable division of such property conforms to a just and right standard, with due regard to the rights of each party. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division is being effected without the introduction of outside funds or other property not constituting a part of the marital estate. It is the intention of the parties to treat all transfers herein as non-taxable. 14. ADVICE OF COUNSEL. Husband and Wife declare that each has had a full and fair opportunity to obtain independent legal advise of his and her selections; that Husband has been independently representative by counsel Robert B. Lieberman, Esquire, and Wife has been independently representative by counsel Samuel L. Andes, Esquire. 15. ADDITIONAL INSTRUMENTS. Each of the parties shall, from time to time at the request ofthe other, execute, acknowledge and deliver to the other party any and all further instruments or documents that may be reasonably required to give full force and effect to the provisions of this Agreement. -7- 16. VOLUNTARY EXECUTION. Husband and Wife each represent and warrant to the other that he or she has made a full and complete disclosure to the other of all assets of any nature whatsoever in which such parties have any interest, the sources and the amount of the income of such party of every type whatsoever and of all the facts relating to the subject matter of this Agreement. 17. WAIVER OF RIGHTS. The parties hereto have been informed of their rights or have been advised to seek counsel to inform them of their rights under the Divorce Code, particularly the provisions for alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or expenses. Both parties agree that this Agreement shall conclusively provide for the distribution of property under the said law and hereby waive, release and relinquish any further rights they may respectively have against the other for alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or expenses. Each party may acquire either personal or real property in their own name. Any property so acquired shall be owned solely by the individual and shall not be subject to any claim whatsoever by the other party. 18. MODIFICATION AND WAIVER. A modification or waiver of any of the provisions of this Agreement shall be effected only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon the strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 19. ENTIRE AGREEMENT. This Agreement contains the entire understanding of the parties, and there are no representations, warranties, covenants or -8- undertakings other than those expressly set forth herein. 20. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 21. INDEPENDENT SEPARATE COVENANTS. It is specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and independent agreement. 22. BREACH. If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach or to seek such other remedies or relief as may be available to him or her and the party breaching this Agreement shall be responsible for payment of legal fees and costs incurred by the other in enforcing his or her rights under this Agreement or in seeking such other remedies or relief as may be available to him or her. 23. APPLICABLE LAW. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 24. VOID CLAUSES. If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. 25. AGREEMENT BINDING ON HEIRS. This Agreement shall be binding on and shall inure to the benefit of the parties hereto and their respective heirs, executors, -9- administrators, successors and assigns. WITNESS: ~k. ~~ /iltL IZ. )~.A--(SEAL) WILLIAM R. SCHNEIDER ~~SEAL) DOROTHY S HNEIDER 26. FINANCIAL DISCLOSURE. The parties confirm that each have relied on the substantial accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written. -10- . . COMMONWEAL TH OF PENNSYLVANIA Not:l~ COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL NANCY H. ALGER, Notary Public City of Harrisburg, Dauphin County My Commission Expires Feb. 17, 2010 ss. COUNTY OF DAUPHIN On this ~ day of OC--tD bu- ~oo~ ,~, before me, the undersigned officer, personally appeared WILLIAM R. SCHNEIDER, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that he executed the same for the purposes therein contained. * * * * * * * COMMONWEAL TH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Onthi~daYOf ~ Q)D:)LI ~ before me, the undersigned officer, personally appeared DOROTHY SCHNEIDER, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that she executed the same for the purposes therein contained. Clt~l[Yl.~ Notary Pu c NOTARIAL IIAL AIIf II. HMICIN8, NOTARY PUaJC UIIOYNEIORO., ~COUN1'Y MY 00I..8ION sn_ fEll. 4," -11- (') ~. "'t.1l:t:' rnrn ~ :r;: tl1 ';;,:~. .<. . ~; r~.> ? I'"~ bC';' 'P-e: -'7 !::l .-<. ~ jI.\fI...:~ .;. ~ueuQ; '(~lO\~ .1~1."6:~€;~'~ ..~.. ~ c::> d' ~ N \D ~ CP. v.> a ~ ~:n "]~ o :::?' - ""i ~'~'l <- (-J'I ::-~ ~ DOROTHY SCHNEIDER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 2000-147-CIVIL TERM WILLIAM R. SCHNEIDER, Defendant CIVIL ACTION - LA W IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under 3301 (c) 3301 (d) (1) of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of Complaint: February 1. 2000 bv Sheriff on Defendant. William R. Schneider. 3. Complete either paragraph (a) or (b). a. Date of execution of the affidavit of consent required by 3301 (c) ofthe Divorce Code: by Plaintiff October 3.2006; by Defendant October 31. 2006. b.(l) Date of execution of the affidavit required by 3301 (d) of the Divorce Code: (2) Date of filing and service of the Plaintiffs affidavit upon the respondent: 4. Related claims pending: None (withdrawn by Praecipe filed bv Plaintiffi 5. Complete either (a) or (b) a. Date and manner of service of the notice of intention to file Praecipe to transmit record, a copy of which is attached: b. Date Plaintiffs Waiver of Notice m 3301 (c) was filed with the Prothonotary: November 1. 2006. Date Defendant's Waver of Notice m Prothonotary: November 1. 2006. 3301 (c) was filed with the ~~.~ Robert B. Lieberman, Esquire Attorney for Defendant ~ at. ~ ~ ~R a ~~ 4iII:: ~iL ....., ;'.. ~e \D go ~ ::r::R "J:;>c; %~ 'Z C' --- y-e:: C!! ~ z ~ ~ N \.D DOROTHY SCHNEIDER, Plaintiff ) ) ) ) ) ) ) ) ) PRAECIPE vs. WILLIAM R. SCHNEIDER, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000-147 IN DIVORCE Please withdraw any and all economic claims previously raised in this matter on behalf of the Plaintiff, including, without limitation, claims for equitable distribution, alimony, alimony pendente lite, counsel fees, or the like. <-- ~\.~ '>eD -VA,(b Samuel L. Andes Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street P.O. Box 168 Lemoyne, P A 17043 (717) 761-5361 Date: '3 Oc-fohv 2UJfo ~ .~ ~ ~ ~:YJ ~ ~ ",~" '"9..' f,\ '" ~', W:P ~ .~, 'f:? (c Q) -:t:. .-'\'; 7r. ". ;"'") 1") ~~,., - '~1'fI ' 'r::;; '-' ~ b :L ," ~ J.;: "'--'\ cP ~ kt: \..-. .. ':2. yC: t"-'> ~ cP SHERIFF'S RETURN - REGULAR CASE NO: 2000-00147 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SCHNEIDER DOROTHY VS SCHNEIDER WILLIAM R CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County, pensylvania, who being duly sworn according to law, was served upon says, the within COMPLAINT - DIVORCE SCHNEIDER WILLIAM R the DEFENDANT , at 0017:59 HOURS, on the 1st day of February, 2000 at 207 PENNSYLVAINA AVE CAMP HILL, PA 17011 WILLIAM P. SCHNEIDER by handing to a true and attested copy of COMPLAINT - DIVORCE together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.30 .00 10.00 .00 37.30 Sworn and Subscribed to before me this .;l.stt.,2:.. day of j~ d01YV A.D. (I.. ~ {2 ~b~_J ~ I~thonotary I So AnS?~~! R. Thomas Kline 02/04/2000 SAMUEL L. ANDES ..; By: _~ //~/1< ~.. :/:7~ &Up. ~ ./ Deputy Sheriff . DOROTHY SCHNEIDER, Plaintiff ) ) ) ) ) ) ) ) ) vs. WILLIAM R. SCHNEIDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000-147 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed in 2000 and was served upon the Defendant within thirty days after it was filed. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary . I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. e.S. Section 4904 relating to unsworn falsification to authorities. ....3 ~ ;;1tJOu Dated: ,~ ~EIDER - ~ ~~ ~ = = c;..-' ~ .I!~ n1..!-l ,- -om :nCJ q{ll {.- ~-';- -j""1 .)B Om ,,-I :il -< :J'Y> :r: co C) .a;-. DOROTHY SCHNEIDER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 2000 -147 - CIVIL TERM WILLIAM R. SCHNEIDER, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) ofthe Divorce Code was filed on January 10, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of Notice of Intention to Request Entry of the Decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. DATED: 10/31 lOb . ~ 12->~ William R. Schneider, Defendant ~ o G ~ c:::> ~ -z:.\ ~ . \"" <;,~, ~:~ -<-. .". ~, -"" ~ .-\ "1:--n rnr=; :,?-,O i~~, ~~ -~ ';' ::..c::. Cf? o ~. DOROTHY SCHNEIDER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000 - 147 - CIVIL TERM WILLIAM R. SCHNEIDER, Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree in Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary . I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. DATED: to/?;! f Db ~/Z~ William R. Schneider, Defendant ~ (") ~ ~:~ !~ ,....;) = = 0'" o 11 ..... I." mp -nm ~~JO (-~~ .i~5 1'1'1 --I )> ::0 -< ~ -"""" ~ m .. a ,$:" it; it; it; it; it; it; it; it; it; it; it; it; it; it;it; it;it; it; it; IN THE COURT OF COMMON PLEAS STATE OF DOROTHY SCHNEIDER, Plaintiff VERSUS WILLIAM R. SCHNEIDER, Defendant AND NOW, DECREED THAT AND OFCUMBERLANDCOUNTY PENNA. No. 2000-l47-Civil Term DECREE IN DIVORCE ~Co o=r I.' 3Df.141 ,~(J(., IT IS ORDERED AND Dorothy Schnp.iop.r , PLAI NTI FF, William R. Schneider , 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 Th a ation and Pro ert Settlement A reement dated October 3 2006 is incor orated Decree in Divorce. ATTEST: PROTHONOTARY ,.; ,.; it; ,.; ;tl it; it; it; it;it;;tl ;tlit;;tl;tl;tl;tl;tl;tl ;tl;tl,.; ..1. ;tl it; if. ~'+; ff' if. Of. if. Of. ;+; ff' ;+; ff' ;+; ;+; ff' ;+; if. if. ~ g 2 "77j, ~ ~-U-'I ~ ~ ~~ ~-/'li} 'X7-( .el ~' ." ~.. , . . <f< '" OIl, .~ ~ . . State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 12/08/06 Case Number (See Addendum for case summary) ~10 )05*'73 00 - .<<4-i (.", L a Original Order/Notice a Amended Order/Notice @ Terminate Order/Notice ... ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT VERIZON GLOBAL NETWORKS INC* 7200 CHESTNUT ST UPPER DARBY PA 19082-3125 RE:SCHNEIDER, WILLIAM R. Employee/Obligor's Name (last, First, MI) 193-38-9270 Employee/Obligor's Social Security Number 1151100455 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (last, First, MI) EmployerM'ithholder's Federal EIN Number See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee'sfobligor's income until further notice even if the Order/Notice is not issued by your State. $ 0.00 per month in current support $ 0.00 per month in past-due support Arrears 12 weeks or greater? ayes ~ no $ 0.00 per month in current and past-due medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ 0.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 0.00 per weekly pay period. $ 0.00 per biweekly pay period (every two weeks). $ 0 . 00 per semimonthly pay period (twice a month). $ 0.00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee'sf obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If required by Pennsylvania law (23 PA C.S. ~ 4374(b)) to remit by electronic payment method, please call Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: P A SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: Date of Order: DEe 1 1 2006 ~ i_ ~\~~ - Form -028 Rev. 1 Worker ID $IATT Service Type M QMB No.: 0970-01 S4 ,c: ~ .... ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If. ~hecked you are required. to provic;Je a ~opy of this form to you~ employee. If YOl,lr employe~ works in.a state that is different from the state that ISSUed this order, a copy must be provided to your employee even If the box IS not checked. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withhold ing. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3. * Repoltillg ti,e PaydatelOate of Witl,I,olding. Yau ,,,ust report ti,e paydateldate of withl,oldil,g when sendir,g the pay" ,ellt. The paydateldate of witl,I,oldi, Ig is ti,e date 011 vvhich a",Oullt v.as ..ithl,eld from the ell,ployee's vvages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you 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 longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 5418855460 EMPLOYEE'S/OBlIGOR'S NAME: SCHNEIDER. WILLIAM R. EMPLOYEE'S CASE IDENTIFIER: 1151100455 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 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 Protection Act (1 5 U .S.c. S 1673 (b)1 i 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. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11.Submitted By: If you or your employee/obligor have any questions, DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT 13 N. HANOVER ST by telephone at (717) 240-6225 or P.O. BOX 320 by FAX at (717) 240-6248 or CARLISLE PA 17013 by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Rev. 1 Worker ID $IATT Service Type M OMS No.: 097().()154 , ~ ADDENDUM Summary of Cases on Attachment Defendant/Obligor: SCHNEIDER, WILLIAM R. PACSES Case Number 870105473 . Plaintiff Name DOROTHY T. SCHNEIDER Docket Attachment Amount 00-147 CIVIL $ 0.00 Child(ren)'s Name(s): DOB you are required to enroll the child(ren) in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB If checked, you are required to enroll the child(ren) above in any health insurance coverage available the employee'slobligor's employment. . PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB If checked, you are required to enroll the child(ren) in any health insurance coverage available employee's/obligor's employment. Service Type M Addendum OMB No.: 0970.{)154 PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB If checked, you are required to enroll the child(ren) in any health insurance coverage available employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB If checked, you are required to enroll the child(ren) above in any health insurance coverage available the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB If checked, you are required to enroll the child(ren) above in any health insurance coverage available the employee's/obligor's employment. Form EN-028 Rev. 1 Worker ID $IATT (') C -rll~L:\ r1~~ \ i "-:> . - .-:::;.. ; '(J) 2,;\,~ ;::' r-." c::> e:',.) c:r' CJ \-'1 ("") ~J::~ - - ~ .--1 ~-r\ rne -0\ ~: ;3,Ii _.......,-. --1~_ -1-1 :;~~~'~ -~ "cn :.<. -0 :> o c...n .- ....