HomeMy WebLinkAbout00-02084
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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STATE OF
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CHRISTOPHER M. UMBERGER,
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Plaintiff
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VERSUS
YOLANDA R. UMBERGER,
Defendant
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PENNA.
No. 2000-2084 Civil
IN DIVORCE
DECREE IN
DIVORCE
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~t;{ 3
AND NOW,
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DECREED THAT
CHRISTOPHER M. UMBERGER
, PLAINTiFF,
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AND
YOLANDA R. UMBERGER
, DEFENDANT,
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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;
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NONE.
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AT
PROTHONOTARY
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CHRISTOPHER M. UMBERGER,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000- 2084 CIVIL TERM
YOLANDA R. UMBERGER,
Defendant
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: irret~ievable breakdown under Section 3301(c) 3301(6)(1) of
the Divorce Code. (Strike out inapplicable section).
2. Date and manner of service of the complaint: Acceptance of Service signed by
Judith Calkin, Esquire, Attorney for Defendant.
3. (Complete either paragraph (a) or (b)).
(a) Date of execution of the affidavit of consent required by Section
3301 (c) of the Divorce Code: by the Plaintiff March 15,2001 filed;
by the Defendant March 7, 2001 filed.
(b) (1) Date of execution of the Plaintiff's affidavit required by Section
3301(d) of the Divorce Code:
(2) Date of service of the Plaintiff's affidavit upon the Defendant
4. Related claims pending: None
5. Complete either (a) or (b).
(a) Date and manner of service of the notice of intention to file praecipe
to transmit record, a copy of which is attached:
(b) Date Plaintiff's Waiver of Notice in 3301(c) Divorce was filed with
the Prothonotary: 3/30/01
Date Defendant's Waiver of Notice in 3301(c) Divorce was filed with the
Prothonotary: 3/30/01
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CHRISTOPHER M. UMBERGER,
Plaintiff
VS.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 00 - ;;cPt CIVIL TERM
IN DIVORCE
YOLANDA R. UMBERGER,
Defendant
NOTICE
yoU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following pages, you must take prompt action. You are warned that if you fail to do so, the case may
proceed without you and a decree of divorce or annulment may be entered against you by the Court. A
judgment may also be entered against you for any other claim or relief requested in these papers by the
Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of
your children.
When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may
request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at
the Cumberland County Court House, Carlisle, Pennsylvania, 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES
OR EXPENSES BEFORE A DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE
THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW
TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
FLOWER, FLOWER & LINDSAY, P.C.
Attorneys for Plaintiff
By:
D.m~J 1-m
Carol
ID#
11 East High Street
Carlisle, PA 17013
(717) 243-5513
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CHRISTOPHER M. UMBERGER,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 00 - UJ rl CIVIL TERM
IN DIVORCE
YOLANDA R. UMBERGER,
Defendant
COMPLAINT IN DIVORCE
CHRISTOPHER M. UMBERGER, Plaintiff, by his attorneys, FLOWER, FLOWER &
LINDSAY, P.C., respectfully represents:
1. The Plaintiff is Christopher M. Umberger, who currently resides at 48 Buttonwood Lane,
Carlisle, Curnberland County, Pennsylvania, where he has resided since 1997.
2. The Defendant is Yolanda R. Umberger, who currently resides at 164 Cedar Lane,
Carlisle, Cumberland County, Pennsylvania, where has resided since March 17,2000.
3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of
Pennsylvania for at least six months immediately prior to the filing of this Complaint.
4. The Plaintiff and Defendant were married on August 30, 1997, at Curnberland County,
Pennsylvania.
5. That there have been no prior actions of divorce or for annulment between the parties in
this or in any other jurisdiction.
6. The Plaintiff avers that she/he is entitled to a divorce on the ground that the marriage is
irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce
Code.
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7. Plaintiff has been advised of the availability of marriage counseling and of the right to
request that the Court require the parties to participate in marriage counseling, and does not request
counseling.
WHEREFORE, Plaintiff requests the Court to enter a decree of divorce.
FLOWER, FLOWER & LINDSAY, P.C.
Attorneys for Plaintiff
By:
Date:
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arol J. Linds ,Esquire
ID # 44693
11 East High Street
Carlisle, PA 17013
(717) 243-5513
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VERIFICATION
I, the undersigned, hereby verify that the statements made herein are true and correct.
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904,
relating to unsworn falsification to authorities.
a~~~
. Christopher M. berger
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CHRISTOPHER M. UMBERGER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V5.
CIVIL ACTION - LAW
NO. 2000- 2084 CIVIL TERM
YOLANDA R. UMBERGER,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under, 3301 (c) of the Divorce Code was filed on April 12, 2000.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from
the date of filing and service of the Complaint.
3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request
entry of the Decree.
I verify that the statements made in this Affidavit are true and correct to the best of my knowledge,
information and belief. I understand that false statements herein are made subject to the penalties of 18
Pa.C.S. 4904 relating to unsworn falsification to authorities.
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Date: '3- 9 -0 I
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
S3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or
expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and
that a copy of the Decree will be sent to me immediately after It is filed with the Prothonotary.
I verify that the statements made in this Affidavit are true and correct to the best of my knowledge,
information and belief. I understand that false statements herein are made subject to the penalties of 18
Pa.C.S. 4904 relating to unsworn falsification to authorities.
Christopher M. Umberger,
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CHRISTOPHER M. UMBERGER,: IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs,
NO. 00-2084
CIVIL ACTION-IN DIVORCE
YOLANDA R. UMBERGER,
Defendant
A1<'J.4'WA VIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the
Divorce Code was f,iled on April 12, 2000.
2. The marriage of Plaintiff and Defendant is
irretrievably broken and ninety (90) days have elapsed from the
date of the filing and service of the Complaint.
3. I consent to the entry of a Final Decree in Divorce
after service of notice of intention to request entry of the
decree.
I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904, relating to
unsworn falsification to authorities.
Date:3{crj D{
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, olanaa R. Umberg
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-2084
CIVIL ACTION-IN DIVORCE
CHRISTOPHER M. UMBERGER,:
Plaintiff
YOLANDA R. UMBERGER,
Defendant
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER SECTION
3301 (e) OF THE DIVORCE CODE
1. I consent to entry of a final Decree of Divorce
without notice.
2. I understand that I may lose rights concerning
alimony, division of property, lawyer's fees or expenses if I do
not claim them before a divorce is granted.
3. I understand that I will not be divorced until a
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.
4. I verify that the statement made in this Waiver are
true and correct. I understand that false statements herein are
made subject to the penalties of 18 Pa.C.S. Section 4904, relating
to unsworn falsification to authorities. i
DATE: 81 ')' to)
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SHUFF, FLOWER
& LINDSAY
ATrORNEYSIIAT'JAW
26 W, High SITeel
Carlisle. PA
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CHRISTOPHER M. UMBERGER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000- 2084 CIVIL TERM
"s.
YOLANDA R. UMBERGER,
Defendant
IN DIVORCE
ACCEPTANCE OF SERVICE
I accept service of the Complaint in Divorce on behalf of Defendant. Yolanda
R. Umberger, and certify that I am authorized to do so, in the above captioned
rnatter.
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Date
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Judith A. Calkin, Esquire
2201 North Second Street
Harrisburg, PA 17110
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MAR 15 2002)
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000- 2084 CIVIL TERM
CHRISTOPHER M. UMBERGER,
Plaintiff
YOLANDA R. UMBERGER,
nlkla YOLANDA R. GARLINGER,
Defendant
IN DIVORCE
QUALIFIED DOMESTIC RELATIONS ORDER
LOWE'S COMEANIESEMPLOYE,E SAVINGS AND
INVESTMiENt PLAN (ESIPl
AND now this
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day of --M ~ ,-L
, 2002, upon
consideration of the Marital Settlement Agreement entered into by the parties,
pursuant to Sections 414(p)(1) and (2) of the Internal Revenue Code of 1954, as
amended, and upon the request of the parties for the entry of a Qualified Domestic
Relations Order, hereinafter QDRO, dealing with certain marital property and rights of
the parties herein, it is hereby ordered and directed as follows:
I. Findinas of Fact:
1. Plaintiff and Defendant were married on August 30, 1997 and divorced
on April 3, 2001. During their marriage, the parties acquired marital property, which
marital property included the benefit plan of Lowe's Companies Employee Savings
and Investment Plan and Trust (ESIP), hereinafter referred to as "Plan".
2. The term "Participant" means Christopher M. Umberger, Social Security
Number 204-48-1556, who is a participant in the Plan whose last known address is
P..Box 473, New Kingston, PA 17072.
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3. The "Alternate Payee" is the former spouse of the Participant,
Yolanda R. Umberger n/kla Yolanda R. Garlinger, Social Security Number 205-66-
8308 whose last known address is 237 N. 2nd Street, Wormleysburg, PA 17043,
4. The Administrator of the Plan is Lowe's Companies, Inc., hereinafter
referred to as the "Administrator".
5. Plaintiff and Defendant have agreed that Alternate Payee shall
receive from Participant's interest in the Plan $2,090.79 with any earnings or loss
thereon from August 31,1999.
II. CONCLUSIONS OF LAW.
1. The divisional property as between Participant and Alternate Payee,
including the division of the Plan, is part of an equitable distribution of marital
property acquired by them during marriage, and further, is "incident to divorce".
2. This QDRO is appropriately entered by the Court under the Divorce
Code of Pennsylvania.
3. The Administrator of the Plan shall recognize the right of Yolanda R.
Umberger as Alternate Payee to demand division of the Plan to the extent set forth
hereafter.
4. Each party is hereby ordered an interest in and to the Plan, with
Alternate Payee's interest to consist of $2,090,79 together with earnings or any
earnings or loss thereon from August 31, 1999 previously credited to the
Participant's account. The Participant shall retain the balance of said account free
and clear of any further claim by the Alternate Payee. As of the date of this Order,
Lowe's Companies' Employees Savings Investment Plan (ESIP) shall set aside in a
separate account for the Alternate Payee $2,090.79 together with any earnings or
loss thereon from August 31, 1999 for the sole benefit of the Alternate Payee.
Nothing contained in this paragraph shall be construed to require any Plan or Plan
Administrator: (1) to provide to the Alternate Payee any type or form of benefit or
any option not otherwise available to the Participant of the Plan; (2) to provide to
the Alternate Payee increased benefits not available to the Participant; (3) to
require any distribution to the Alternate Payee before the earliest date that the
Participant is eligible to receive a distribution; and (4) to pay any benefits to the
Alternate Payee which are required to be paid to another Alternate Payee under
another Order determined by the Plan Administrator to be a Qualified Domestic
Relations Order (hereinafter calledQDRO) before this document is determined by
the Plan Administrator to be a QDRO.
5. In the event of the death of Participant, the Alternate Payee would be
entitled to receive the entire balance of the Alternate Payee account.
6. The Alternate Payee shall be entitled to receive the benefits specified
herein, only in accordance with law, and the terms of a Plan agreement. Alternate
Payee agrees to comply with all terms and conditions of the Plan now in effect or as
may hereafter be amended, not otherwise in contravention of the right of the
Alternate Payee to receive such payments as ordered herein. Alternate Payee
shall not be deemed a Participant in the Plan solely by reason of the receipt of this
Order by the Plan and its Administrator.
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7. No portion of this Order is intended to require the Plan to provide any
type or form of benefit or any option not otherwise provided under the Plan, nor
shall this Order require any distribution to the Alternate Payee before the earliest
date that Participant is eligible to receive a distribution. This Order shall not require
the Plan to provide increased benefits nor to make payments of benefits to an
Alternate Payee which are required to be paid to another Alternate Payee under
another Order previously determined to be a QDRO.
8. This Order is intended to be a QDRO as defined by the Internal
Revenue Code of 1954, as amended, and its provisions shall be administered and
interpreted in conformity with that act. This Court reserves jurisdiction to amend
this Order upon application of the parties if it is determined that it is invalid or does
not qualify as a QDRO so as to accomplish the intentions of the Court and of
Christopher M. Umberger and Yolanda R. Umberger n/k/a Yolanda R. Garlinger as
set forth herein.
9. The Plan Administrator, and their attorneys, agents and assigns, shall
take such steps as are necessary to effectuate the provisions of this QDRO, and
shall set aside for Christopher M. Umberger and Yolanda R. Umberger n/k/a
Yolanda R. Garlinger sole and separate property such amounts, but only such
amounts as may be necessary to effectuate the provisions of this QDRO.
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10. A filed copy of this QORO with original stamp or seal shall be
delivered to the Plan Administrator upon execution hereof.
CONCURRENCE:
Judith A. Calkin, Esqui
Attorney for Alternate Payee
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MAR 1 5 2002)
CHRISTOPHER M. UMBERGER,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000- 2084 CIVIL TERM
YOLANDA R. UMBERGER,
n/klal YOLANDA R. GARLINGER,
Defendant
IN DIVORCE
QUALIFIED DOMESTIC. RELATIONS ORDER
LOWE'S COMPANIES 'EMPLOYEE STOCK '
OWNERSHIP PLAN (ESOP\
AND now this IX i! day of --f111.J t-L , 2002, upon
consideration of the Marital Settlement Agreement entered into by the parties,
pursuant to Sections 414(p)(1) and (2) of the Internal Revenue Code of 1954, as
amended, and upon the request of the parties for the entry of a Qualified Domestic
Relations Order, hereinafter QDRO, dealing with certain marital property and rights of
the parties herein, it is hereby ordered and directed as follows:
I. Findinas of Fact:
1. Plaintiff and Defendant were married on August 30, 1997 and divorced
on April 3, 2001. During their marriage, the parties acquired marital property, which
marital property included the benefit plan of Lowe's Companies Employee Stock
Ownership Plan and Trust (ESOP), hereinafter referred to as "Plan".
2. The term "Participant" means Christopher M. Umberger, Social Security
Number 204-48-1556, who is a participant in the Plan whose last known address is P.
O. Box 473, New Kingston, PA 17072.
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3. The "Alternate Payee" is the former spouse of the Participant,
Yolanda R. Umberger, n/kla Yolanda R. Garlinger, Social Security Number 205-66-
8308 whose last known address is 237 N. 2nd Street, Wormleysburg, PA 17043.
4. The Administrator of the Plan is Lowe's Companies, Inc., hereinafter
referred to as the "Administrator".
5. Plaintiff and Defendant have agreed that 45.26 shares of Lowe's
Companies common stock in the Plan shall be awarded to Alternate Payee as
ordered herein.
II. CONCLUSIONS OF LAW.
1. The divisional property as between Participant and Alternate Payee,
including the division of the Plan, is part of an equitable distribution of marital
property acquired by them during marriage, and further, is "incident to divorce".
2. This QDRO is appropriately entered by the Court under the Divorce
Code of Pennsylvania.
3. The Administrator of the Plan shall recognize the right of Yolanda R.
Umberger as Alternate Payee to demand division of the Plan to the extent set forth
hereafter.
4. Each party is hereby ordered an interest in and to the Plan, with
Alternate Payee's interest to consist of 45.26 shares of Lowe's Companies, Inc.
common stock previously credited to the Participant's account. The Participant
shall retain the balance of said account free and clear of any further claim by the
Alternate Payee. As of the date of this Order, Lowe's Companies' Employees
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Stock Ownership Plan (ESOP) shall set aside in an Alternate Payee account 45.26
shares for the sole benefit of the Alternate Payee. Nothing contained in this
paragraph shall be construed to require any Plan or Plan Administrator: (1) to
provide to the Alternate Payee any type or form of benefit or any option not
otherwise available to the Participant of the Plan; (2) to provide to the Alternate
Payee increased benefits not available to the Participant; (3) to require any
distribution to the Alternate Payee before the earliest date that the Participant is
eligible to receive a distribution; and (4) to pay any benefits to the Alternate Payee
which are required to be paid to another Alternate Payee under another Order
determined by the Plan Administrator to be a Qualified Domestic Relations Order
(hereinafter called QDRO) before this document is determined by the Plan
Administrator to be a QDRO.
5. In the event of the death of Participant, the Alternate Payee would be
entitled to receive the entire balance of the Alternate Payee account.
6. The Alternate Payee shall be entitled to receive the benefits specified
herein, only in accordance with law, and the terms of a Plan agreement. Alternate
Payee agrees to comply with all terms and conditions of the Plan now in effect or as
may hereafter be amended, not otherwise in contravention of the right of the
Alternate Payee to receive such payments as ordered herein. Alternate Payee
shall not be deemed a Participant in the Plan solely by reason of the receipt of this
Order by the Plan and its Administrator.
7. No portion of this Order is intended to require the Plan to provide any
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type or form of benefit or any option not otherwise provided under the Plan, nor
shall this Order require any distribution to the Alternate Payee before the earliest
date that Participant is eligible to receive a distribution. This Order shall not require
the Plan to provide increased benefits nor to make payments of benefits to an
Alternate Payee which are required to be paid to another Alternate Payee under
another Order previously determined to be a QDRO.
8. This Order is intended to be a QDRO as defined by the Internal
Revenue Code of 1954, as amended, and its provisions shall be administered and
interpreted in conformity with that act. This Court reserves jurisdiction to amend
this Order upon application of the parties if it is determined that it is invalid or does
not qualify as a QDRO so as to accomplish the intentions of the Court and of
Christopher M. Umberger and Yolanda R. Umberger n/kla Yolanda R. Garlinger as
set forth herein.
9. The Plan Administrator, and their attorneys, agents and assigns, shall
take such steps as are necessary to effectuate the provisions of this QDRO, and
shall set aside for Christopher M. Umberger and Yolanda R. Umberger n/kla
Yolanda R. Garlinger sole and separate properly such amounts, but only such
amounts as may be necessary to effectuate the provisions of this QDRO.
10. A filed copy of this QDRO with original stamp or seal shall be
delivered to the Plan Administrator upon execution hereof.
By th~rt,
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CONCURRENCE:
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Judith A. Calkin, Esquire /
Attorney for Alternate Payee
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