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Home My WebLink About02-5524LISA G. DIAZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND cOUNTY, PENNSYLVANIA IGO J. DIAZ, : CIVIL ACTION - LAW IN Defendant : DIVORCE NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that, if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counselling. A list of marriage counselors is available at: The Office of the Prothonotary, Cumberland County Courthouse, One Courthouse Square, Carlisle Pennsylvania 17101. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR IS ENTERED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAW~ER AT ONCE. IF YOU DO NOT ~AVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT W~ERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY COURT ADMINISTRATOR 4TH FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 MEYERS, DESFOR, SALI'ZGIVER & BOYLE 410 NORTH SECOND STREET · P.O BOX 1062 · HARRISBURG, PA 17108 (717) 236-9428 ° FAX(717) 236~2817 LISA G. DIAZ, Plaintiff VS. RODRIGO J. DIAZ, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(C) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Lisa G. Diaz, by and through her attorneys, Meyers, Desfor, Saltzgiver & Boyle and files the following Complaint in Divorce and in support thereof avers as follows: 1. Plaintiff is Lisa G. Diaz an adult individual who currently resides at 31 Nelson Drive, Carlisle, Pennsylvania, 17013. 2. Defendant is Rodrigo J. Diaz an adult individual who currently resides at 31 Nelson Drive, Carlisle, Pennsylvania 17013. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on December 31, 1996 at Mercersburg, Pennsylvania, Franklin County. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. The Defendant is not a member of the United States Army or 3 MEYERS, DESFOR, SAL'rZGIVER & BOYLE 410 NORTH SECOND STREET · p.O. BOX1062 · HARRISBURG, PA17108 (717) 236-9428 · FAX (717) 236-2817 9 o its allies. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request the court require the parties to participate in counseling, being so advised, Plaintiff waives that right. Plaintiff requests the Court to enter a Decree of Divorce pursuant to Section 3301(C) or 3301(D) of the Divorce Code. WHEREFORE, Plaintiff, Liaz G. Diaz, respectfully requests this Honorable Court enter a Decree in Divorce pursuant to Section 3301(C) or 3301(D) of the Divorce Code. COUNT I INDIGNITIES 10. Paragraphs one through nine of the Complaint are incorporated by reference as if fully set forth herein. 11. The grounds upon which this action is based are indignities pursuant to Section 3301(a) (6) of the Divorce Code. During the marriage, the Defendant has committed such indignities against the Plaintiff so as to make her life burdensome and intolerable. 12. Plaintiff requests the Court issue a decree in divorce based upon indignities pursuant to section 3301(a) (6) of the Divorce Code. WHEREFORE, this Honorable from the bonds Plaintiff, Liaz G. Diaz, respectfully requests Court to issue a Decree in Divorce divorcing her of matrimony pursuant to Section 3301(a) (6) of 4 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET · P.O. BOX 1062 · HARRISBURG, PA 17108 (717) 236-9428 * FAX (717) 236-2817 the Divorce Code. COUNT II EQUITABLE DISTRIBUTION 13. Paragraphs one through twelve of the Complaint are incorporated by reference as if fully set forth herein. 14. During the marriage, Plaintiff and Defendant have acquired various items of marital property, both real and personal, which are subject to equitable distribution under the Divorce Code. 15. Plaintiff requests that this Honorable Court equitably distribute all marital property pursuant to the Divorce Code. WHEREFORE, Plaintiff, Lisa G. Diaz, respectfully requests this Honorable Court equitably distribute all property, both real and personal, tangible and intangible, acquired by the parties during their marriage. COUNT III ALIMONY PENDENTE LITE, SUPPORT, COUNSEL FEES, AND EXPENSES 16. 17. Paragraphs one through fifteen of the Complaint are incorporated by reference as if fully set forth herein. By reason of this action, Plaintiff will be put to considerable expense in the preparation of this case in the employment of counsel and the payment of costs. 5 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET · PO. BOX 1062 · HARRISBURG, PA 17108 (717) 236-9428 · FAX(717) 236-2817 18. Plaintiff is without sufficient funds to support herself and to meet the costs and expenses of this litigation and unable to appropriately maintain herself during the pendency of this action. 19. Plaintiff's income is not sufficient to provide for her reasonable needs and pay her attorneys' fees and the costs of this litigation. 20. Defendant has adequate earnings to provide support and alimony pendente lite for the Plaintiff and to pay her counsel fees, costs and expenses. WHEREFORE, Plaintiff, Lisa G. Diaz, respectfully requests this Honorable Court compel the Defendant to pay Plaintiff alimony pendente lite, support, counsel fees, costs and expenses of this action. COUNT IV ALIMONY 21. Paragraphs one through twenty of the Complaint are incorporated by reference as if fully set forth herein. 22. Plaintiff lacks sufficient property to provide for her reasonable needs. 23. Plaintiff is unable to sufficiently support herself through appropriate employment. 24. Defendant has sufficient income and assets to provide continuing support and to pay alimony to the Plaintiff. MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET · PO. BOX 1062 · HARRISBURG, PA 171O8 (717) 236-9428 · FAX(717) 236-2817 WHEREFORE, this Honorable Plaintiff. Plaintiff, Lisa G. Diaz, respectfully requests Court compel Defendant to pay alimony to ~atherine A. Boyle, ~s~uire MEYERS, DESFOR, SAL~ZG~VER & BOYLE ~ Attorney I.D. ~76328 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717) 236-9428 Attorney for Plaintiff 7 MEYERS, DESFOR, SAL~ZGIVER & BOYLE 410 NORTH SECOND STREET · P.O BOX 1062 · HARRISBURG, PA 17108 (717} 236 9428 · FAX (717} 236-2817 yERIFICATION I, Lisa G. Diaz , verify that the statements made in this _ Complaint In Divorce are true and correct to the bes' of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. CoS. Section 4904, relating to unsworn falsification to authorities. Dated: 11/14/2002 (X) Plaintiff ( ) Defendant MEYERS, DESFOR, SALTZGiVER & BOYLE 410 NORTH SECOND STREET · P.O. BOX 1062 * HARRISBURG, PA 17108 (717} 236-9428 ° FAX {717) 236-2817 Lisa G. Diaz, Plaintiff Vo Rodrigo J. Diaz, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5524 CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE OF COMPLAINT IN DIVORCE I, John King, Esquire, counsel for Rodrigo J. Diaz, Defendant in the above-captioned matter, certify acceptance of service on behalf of Rodrigo J. Diaz of a time-stamped copy of the Complaint in Divorce filed by Plaintiff, Lisa G. Diaz on November 14 , 2002, and that I a~'~rized to do so. Date: I!,/;5-- /D ~ ~ / Jd~f~ King, EsqUire [ Friedman' & Ki~q/ I 600 North Second Street ~arrisburg, PA 17101 -Counsel for Defendant MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET · P.O. BOX 1062 · HARRISBURG, PA 17108 (717) 236-9428 · FAX (717) 236-2817 Lisa G. Diaz, Plaintiff Vo Rodrigo J. Diaz, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5524 CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF S~:RVICE I hereby certify that on this day of , 2002, a copy of the attached Acceptance of Service of Complaint In Divorce was sent VIA U.S. Mail, postage Prepaid, to: John King, Esquire Friedman & King 600 North Second Street Harrisburg, PA 17101 Attlorney for tB~eyl ff MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET · P.O. BOX 106'2 · HARRISBURG, PA 17108 (717) 236-9428 · FAX (717) ?.36-2817 Lisa G. Diaz, Plaintiff Rodrigo J. Diaz, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-5524 CIVIL ACTION - LAW : : IN DIVORCE CERTIFICATE ~F SERVICE I hereby certify on this ~[ day of ~ ,-~2 that the foregoing Request for Production o~Docume'nts ~s mailed, first-class, postage pre-paid to: Rodrigo J. Diaz c/o John King, Esquire Friedman and King, PC 600 N. Second Street Harrisburg, PA 17101 003, MEYERS, DESFOR, SAL'FZGIVER & BOYLE 410 NORTH SECOND STREET · P.O. BOX 1062 · HARRISBURG, PA 17108 (717) 236-9428 · FAX (717) 236-2817 Lisa G. Diaz, Plaintiff ro Rodrigo J. Diaz, Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-5524 CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that on this ~[~ day of ~ 2003, the original and two (2) copies of the attac~hed 0 Interrogatories were mailed, postage prepaid, to John King, Esquire, Friedman and King, PC, 600 N. Second Street, Harrisburg, PA 17101, being the attorney for the Defendant in this case. erine A. Boyle, ESQUIRE ~ Attorney for Plaintiff ~ 37 Lisa G. Diaz, Plaintiff Vo Rodrigo J. Diaz, Defendan~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5524 CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE certify that on this /~ day of ~ , I hereby 2003, a copy of Plaintiff's Response to Defendant's Request for Production of Documents was sent VIA U.S. Mail, postage prepaid, to: Rodrigo J. Diaz c/o John King, Esquire Friedman & King, PC 600 North Second Street Harrisburg, PA 1'7101 MEYERS, DESFOR, SAL'I"ZGIVER & BOYLE 410 NORTH SECOND STREET · P.O. BOX 1062 · HARRISBURG, PA 17108 (717) 236-9428 o FAX (717) 23(;-2817 Lisa G. Diaz, Plaintifl Vo Rodrigo J. Diaz, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5524 CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE i hereby certify that on this /~ day of ~ / 2003, a copy of the attached Plaintiff's Answers to Defendant's Interrogatories Addressed to Plaintiff was sent VIA U.S. Mail, )ostage prepaid, to: John King, Esquire Friedman & King, P.C. 600 North Second Street Harrisburg, PA ].7101 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET · P.O. BOX 10{~2 · HARRISBURG, PA 17108 (717) 236-9428 · FAX (71'7) 236-2817 Lisa G. Diaz, : Plaintiff : Rodrigo J. Diaz, : Defendant : IN THE COUS~T OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00C2E £~ 2003 ~°~'~-~ PACSES NO: 849105165 CIVIL ACTION - LAW IN SUPPORT PETITION FOR ALIMONY PENDENTE LITE AND NOW COMES, Plaintiff, Lisa G. Diaz, by and through her attorneys, Meyers, Desfor, Saltzgiver & Boyle, and files this Petition for Alimony Pendente Lite and in support thereof avers as follows: 1. Petitioner is Lisa G. Diaz, an adult individual currently residing at 504 Highland Court, Carlisle, Pennsylvania (hereinafter referred to as "Wife"). 2. Respondent is Rodrigo J. Diaz, and adult individual currently residing at 31 Nelson Drive, Carlisle, Pennsylvania (hereinafter referre~ to as "Husband"). 3. Petioner and Respondent are formerly husband and wife, having been married on December 21, 1996, separated on or about October 11, 2002. A Complaint in Divorce was filed on November 14, 2002. Said Complaint for Divorce contains a count requesting Alimony Pendente Lite. MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET · P.O. BOX 1062 · HARRISBURG, PA 17108 (717) 236-9428 * FAX(717) 236-2817 WHEREFORE, the Petitioner, Lisa G. Diaz respectfully requests this Honorable Court to grant her a conference for Alimony Pendente Lite proceedings. Respectfully submitted, & 5OYLE Attorney I.D. #76328 410 North Second Street P.C. Box 1062 Harrisburg, PA 17108 (717) 236-9428 Attorney for Plaintiff MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET · P.O. BOX 1062 · HARRISBURG, PA 17108 (717) 236-9428 · FAX(717) 2~I6-2817 Lisa G. Diaz, : Plaintiff : Rodrigo J. Diaz, : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00025--S-2003 PACSES NO: 849105165 CIVIL ACT]iON - LAW IN SUPPORT CERTIFICATE OF SERVICE 2002, I hereby certify that this ~ ~ on day of , a copy of the attached Petition for Alimony Pendente Lite was sent VIA U.S. Mail, postage prepaid, to: Rodrigo J. Diaz c/o John King, Esquire Friedman & King. PC 600 North Second ~{treet Harrisburg, PA 17101 MEYERS, DESFOR, SA/~ZGIVER & BOYLE 410 NORTH SECOND STREET · P.O. BOX 1062 , HARRISBURG, PA 17108 (717) 236-9428 · FAX(717) 2,<=6-2817 JUL-09-03 07:31 FRO~Cumberland County Domestic Relations 7172407775 T-SZ4 P.OO1/OOZ F-321 tN THE COURT OF COMMON PLEAS OF CUMBERLA/TD COUNTY, PENNSYLVANIA Lisa G. Diaz Plaintiff Rodri~o J. Diaz Defendan~ NO. 02-5524 CIVI~ ACTION - .~h.W IN DIVORCE DRS ATTACBq~NT FOR APL PROCEEDINGS NAME ADDRESS BIRTH DATE SOCI~J~ SECURITY N-0MBER HOME PHONE WORK PHONE EMPLOYER ND~4E EMPLOYER ADDP~ESS JOB TITLE/POSITION DATE EMPLOYM~/X~T COMMENCED GROSS PAY NET PAY OTHER INCOME ATTORNEY'S N~4E ATTOP~NEY'S A/~DPd~SS ATTORNEY'S PHONE NUMBER PETITIOIqER Lisa G. Diaz 504 Hiqhland Court, Carlisle. 8/23/64 205-60-2076 (717) 24~-~nnq (717)772-3736 ?enns?flvania Dep%. Of Revenue Strawberry Square, Harrisburq, Hearing Officer Has been there 3 1/2 year~ , U~kno~;n UnKnown None i Catherine A. Boyle. Esquire 410 N. Second St. ~arri~burg~ (717) 236-9428 JUL-09-03 OT:31 FROM-Cumberland County Domestic ~elations 717Z407775 T-6Z4 P.OOZ/OO2 F-3Z1 ADDRESS BIRTH DATE SOCIAL S~CURITY : HOME WORK PHONE EMPLOYER NAF~ EMPLOYER ADDRESS JOB TITLE/POSITION DATE EMPnOYI~FAqT COMI~51~CED GROSS PAY Ar~T PAY OTHER INCOM~ ATTORNEY'S NAME ATTOP4N~¥' S ADDRESS ATTORNEY' S PHONE NtrMBER RESPONDENT Rodri~o J. 2/19/65 Diaz Driv~:~ Carlisle, PA _ . 168-60-3538 (717)960-9860 (717} 783-9454 __ Pennsylvania Liquor Control BQa~ Northwest Office Building Capital & Forrester Sts., Harrisbu__] Deputy Counsel Has been there for 9 1/2 Yea~s. . ~ ~nknown ~, ..... ~, Unknown Unknown John King. Esquirfi . . 600 N, Second St, Harrisburg. PA . (717) 236-8000 MARRIAGE INFORMATION PI~kCE OP MAP~RIAGE DATE OF $EPA~RATION ADDRESS OF LAST MARZTAL DESCRIPTION OF DOCUMENT RAISING APL CLAIM December 21. 20~2 Mercersburg, October 11. 2002 31 Nelson Drive, Carlisle, PA Complaint in Divorce November 14, 2002 DATE APL DO~T FILED J, PA I, Lisa G. Diaz statements made in this VERIFICATIC,N , verify that the Petition for Alimony Pendente Lime are true and correct to the best of my knowledge, information and belief. I understand that fals~ statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: July 9, 2003 (X) Plaintiff ( ) Defendant MEYERS, DESFOR, SAL~ZGIVER & BOYLE 410 NORTH SECOND STREET · P.O. BOX 1062 · HARRISBURG, PA 17108 (717) 236-9428 · FAX(717) 2362817 LISA G. DIAZ, : Plaintiff/Petitioner : VS. : RODRIGO J. DIAZ, : DefendanffRespondent : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 2002-5524 CIVIL TERM IN DIVORCE Pacses# 830105650 ORDER OF COURT AND NOW, this 30th day of July, 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 on August 26t 2003 at 10:30 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (1) a tree copy of your most recent Federal Income Tax Return, including W_2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11© (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have 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. Mail copies on Petitioner 7-30-03 to: < Respondent Catherine Boyle, Esquire John King, Esquire Date of Order: July 30, 2003 BY THE COURT, George E. Hoffer, President Judge · J. Shadday, Conference YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 CC361 Lisa G. Diaz, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2002-5524 : PACSES NO: 830105650 : CIVIL ACTION - LAW Rodrigo J. Diaz, : IN DIVORCE Defendant : PRAECIPE TO WITHDRAWAL PETITION FOR ALIMONY PENDENTE TO THE PROTHONOTARY: On behalf of the Plaintiff, Lisa Diaz, please withdraw the Petition for Alimony Pendente Lite in regard to the above- referenced matter, without prejudice. Respectfully submitted, & BOYLE Attorney I.D. #76328 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717) 236-9428 Attorney for Plaintiff MEYERS, DESFOR, SALT~GIVER & BOYLE 410 NORTH SECOND STREET · P.O. BOX 1062 · HARRrSBURG, PA 17108 (717) 836-9428 , FAX(717) 23~-2817 Lisa G. Diaz, : Plaintiff : Rodrigo J. Diaz, : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND cOUNTY, PENNSYLVANIA NO. 2002-5524 PACSES NO: 830105650 CIVIL ACTION - LAW IN DIVORCE I 2003, CERTIFICATE OF SERVICE hereby certify that on this I~ day of ~, a copy of the attached Praecipe to withdraw Petition for Pendente Lite was mailed, postage prepaid, to Rodrigo J. Diaz c/o John King, Esquire Friedman & King. PC 600 North Second Street Harrisburg, PA 17101 MEYERS, DESFOR, SAL~I-ZGIVER & BOYLE 410 NORTH SECOND STREET · P.O. BOX 1062 · HARRISBURG, PA 17105 (717) 236-9428 · FAX (717) 236-2817 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION LISA G. DIAZ ) Docket Number Plaintiff ) vs. ) PACSES Case Number RODRIGO J. DIAZ ) Defendant ) Other State ID Number 02-5524 CIVIL 830105650 AND NOW, to wit on this ORDERED that the C) Complaint for Support or PETITION FOR APL filed on matter is dismissed without prejudice due to: ORDER 20TH DAY OF AUGUST, 2003 IT IS HEREBY O Petition to Modifyor (~)Other 7-30-03 in the above captioned the plaintiff withdrawing her Petition for Alimony Pendente Lite C) The Complaint or Petition may be reinstated upon written application of the plaintiff petitioner. DRO: RJ Shadday xc: plaintiff defendant John King, Esquire Catherine Boyle, Esquire BY THE COURT: Kevin A. Hess JUDGE Form OE-506 Sen, ice Type M Worker ID 21205 ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 09/12/03 Tribunal/Case Number (See Addendum for case summary) EmployerANithholder's Federal EIN Number CO~ONWEALTH OF PA C/O pAYROLL OPERATIONS ATTACHMENTS RESEARCH UNIT PO BOX 8006 ~ARRISBURG PA 17105-8006 C) Original Order/Notice (~) Amended Order/Notice C) Terminate Order/Notice DIAZ, RODRIGO J. Employee/Obligor's Name (Last, First, MI) ~' _ ~ Employe¢Obligor's S~ial Security Numar ~ .... -- Employe~Obligor's Case Identifier ~ (S~ A~endum for plaintiff Custodial Parent's Name (Last, ~irst, MI) See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUNBERL~'~13 County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the abovemamed employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 635.00 per month in current support $ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes (~) no $ 0.00 per month in medical support $ 0,00 per month for genetic test costs $ per month in other (specify) for a total of $ 635. O0 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: $ 14`6.54, per weekly pay period. $ 293.08 per biweekly pay period (every two weeks). $ 317.50 per semimonthly pay period (twice a month). $ 635. oo 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. BY THE COURT: OM8 NO.: 097C~0154 Date of Order: Service Type /~~~~FForm EN-028 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS [] If£hecke~d you are required to provide a ~:opy of this form to your~mp oyee f yogr employee syorks in a state that is dir[erent trom the state that issued this or~er, a copy must be proviclecl to your employee even if the box is not checked. 1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned businesses located on a reservation that choose to withhold in accordance with this notice. 2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of th is order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 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. $.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #10 below) 6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S ID: 2321722990 EMPLOYEE'S/OBLIGOR'S NAME: DIAZ, RODRIGO J. EMPLOYEE'S CASE IDENTIFIER:. '/?30101104 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law govems unless the obligor is employed in another State, in Which case the law of the State in which he or she is employed governs. 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 ora 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.S.C. §1673 (b)l; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 1 1. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717)~ or by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Service Type M OMB NO.: 0970-0154 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: DIAZ, RODRIGO J. PACSES Case Number 849105165 Plaintiff Name LISA G. DIAZ Docket Attachment Amount 00028 S 2003 $ 635.00 Child(ren)'s Name(s): DOB CHRISTOPHER GARLAND DIAZ 03/08/00 ~]lf checked, you are required to enroll the child(mn) identified above in any health insurance coverage available through the employee's/obligor's employment PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB [] If checked, you are required to enroll the child(mn) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ o.0o Child(mn)'s Name(s): DOB · [] If checked, you are required to enroll the child(mn) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ o.oo Chi]d(ren)'s Name(s): DOB : [] If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.oo Child(mn)'s Name(s): DOB []lf checked, you are required to enroll the child(mn) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB : []If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obiigor's employment. Addendum Form EN-028 Service Type M OMB No.: 0970-0154 Worker ID $IATT ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co.~City~Dist. of CUMBERLAND Date of Order/Notice 09/15/03 Tribunal/Case Number (See Addendum for case summary) EmployerA, Vithholder's Federal EIN Number COMMONWEALTH OF PA C/O PAYROLL OPERATIONS ATTACHMENTS RESEARCH UNIT PO BOX 8006 HARRISBURG PA 17105-8006 RE: DIAZ, RODRIGO J. C) Original OrdedNotice (~) Amended Order/Notice C) Terminate Order/Notice Ernployee/Obligor's Name (Last, First, MI) Employee/Obliger's Social Security Number Employee/Obliger's Case Identifier (S~ A~e~um ~r plaintiff ~mes ~, <~ ~ Custodial Parent's Name (Last, "irst, MI) See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CHMBERI.~2~ County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obliger's income until further notice even if the Order/Notice is not issued by your State. $ 488. oo per month in current support $ o. 00 per month in past-due support Arrears 12 weeks or greater? C)yes (~) no $ o. oo per month in medical support $ 0.00 per month for genetic test costs $ per month in other (specify) fo~r a total of $ 488. O0 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: $ 112.62 per weekly pay period. $ 225.23 per biweekly pay period (every two weeks). $ 244. O0 per semimonthly pay period (twice a month). $ 488. oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the fi rst pay period occurring ten (1 O) 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, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee~Obliger's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: Date of Order: Service Type M OMB NO: 0970-0154 Form EN-028 Worker iD $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER W~THHOLDERS · to rovideaco ofthsformtoyour~mpoyee, ifyo~remployee.worksin.astatethat, is [] If hecked you are required. P, ,. ~ PY~ ........ , ~, ...... ~,~,~d v 'emg~ovee even it the box ~s not checked. d ~erent from the state that ssuea tins oruer, ,~ ~upy ,,,,~t ~,~ ~, ..... ed to .ou . . 1. We appreciate the voluntae/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. , .......................... Yo,~ m~st ,~,o,, Lh~ m~yd-,~/d .... f ,,i~'lhold,,,~ ,,h~,,~md~g4hel:~me~ The 4. -Report,,,~ ,,,~, ay,~a,e,~,a .................. ~- _ ............ h-ld f;oi~; th~ 6u~.~.',c,v(~.'s wa§c;7 You must comply with the law of the state of the empJoyee'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/Ob got with Multiple Support Holdings: If there is more than one OrdedNotice to Withhold Income for Support against this employee/obligor and you are unable to honor ail 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 OrdedNotice to the Agency identified below· WITHHOLDER'S ID: 2321722990 EMPLOYEE'S/OBLIGOR'S NAME: DIAZ, RODRIGO J. EMPLOYEE'S CASE IDENTIFIER: 7730101~'04 DATE OF SEF'ARATiON: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 10.* Withholding Limits: You may not withhold more than the lesser of: 1 ) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. § 1673 (b)l; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income [e[t after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 1 1. 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 1 7013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone a'I (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 o~ No:0~70-ms~ ADDENDUM Summary of Cases on Attachment Defendant]Obligor: DIAZ, RODRIGO J. PACSES Case Number 849105165 Plaintiff Name LISA G. DIAZ Docket Attachment Amount 00025 S 2003 $ 488.00 Child(ren)'s Name(s): DOB [] If checked, you are required to enroll the child(ten) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.o0 Child(ren)'s Name(s): DOB : [] If checked, you are required to enroll the child(mn) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB [] If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case. Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB [] If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ! [] If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): Dog [] 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 Service Type M OMBNo:09700154 WorkerlD $IATT In the Court of Common Pleas of CUM~ERLAN~ County, Pennsylvania DOMESTIC RELATIONS SECTION LISA G. DIAZ ) Docket Number Plaintiff ) vs. ) PACSES Case Number RODRIGO J. DIAZ ) Defendant ) Other State ID Number 02-5524 CIVIL 830105650 ORDER AND NOW, to wit on this 12TH DAY OF SEPTEMBER, 2003 IT IS HEREBY ORDERED that the O Complaim for Support or O Petition to Modify or (~ Other ALIMONY PENDENTE LITE filed on AUGUST 25, 2003 in the above captioned matter is dismissed without prejudice due to: CONSIDERATION THAT HUSBAND HAS THE RESPONSIBILITY OF THE MORTGAGE ON THE MARITAL HOME UNTIL THE MARITAL HOME IS SOLD OR REFINANCED. © The Complaint or Petition may be reinstated upon written application of the plaintiff petitioner. DRO: RJ Shadday xc: plaintiff defendant Catherine Boyle, Esquir~ John King, Esquire BY THE COURT: Kevin A. Hess JUDGE Form OE-506 Service Type M Worker ID 21005 Lisa G. Diaz, Plaintiff Vo Rodrigo J. Diaz, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-5524 PACSES NO: 830105650 CIVIL ACTION - IJtW IN DIVORCE NOTICE OF APPEAL AND DEMAND FOR HEARING DE NOV© Date of Order: September 12, 2003 Amount of Order: Dismissed For the support of: Lisa G. Diaz Date of Request for Hearing: September 26, 2003 Sonference Officer: Rikki Shadday Reason for Demand for Hearing/Issues you plan to raise at the hearing: Inappropriate dismissal; Inappropriate consideration of ~quitable distribution and expense issues; incorrect ~alculations; no consideration of Plaintiff's expenses; inappropriate tax status. ~OU ARE REQUIRED TO NOTIFY THE OPPOSING PARTY AND ANY ATTORNEY INVOLVED THAT A REQUEST FOR A HEARING BEFORE THE COURT OF THIS ORDER IS BEING TAKEN BY PROVIDING THEM WITH A COPY OF THIS FORM. Name of party filing demand for hearing: Plaintiff, Lisa G. Garland & BOYLE Attorney I.D. #76328 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717) 236-9428 Attorney for Plaintiff MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET · P.O. BOX 1062 · HARRISBURG, PA 17108 (717) 236-9428 · FAX{717) 236-2817 Jisa G. Diaz, Plaintiff Vo ~odrigo J. Diaz, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-5524 PACSES NO: 830105650 : : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE I hereby certify on this ~ day of ~ 2003 that a copy of the foregoing Notice of Appeal and Demand for Rearing De Novo was sent via first-class mail, postage pre-paid LO: John King, Esquire Friedman & King 600 North Second Street Harrisburg, PA 17101 Attorney fo; Plain~i~qu~ MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET · P.O. BOX 1062 · HARRISBURGi PA 17108 (717) 238-9428 · FAX (717} 236-2817 In the Court of Common Pleas of CUMIIERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION LISA G. DIAZ ) Docket Number Plaintiff ) vs. ) PACSES Case Number RODRIGO J. DIAZ ) Defendant ) Other State ID Number 02-5524 CIVIL 830105650 ORDER OF COURT YOU, LISA GARIakND DIAZ 504 HIGHLAND CT, CARLISLE, PA. 17013-3923-04 plaintiff/defendam of are ordered to appear at DOMESTIC REIaATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the OCTOBER 27, 2003 at 9:00AM for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2~, aa 2. your pay stubs for the preceding six (6) months, ,~ co 3. verification of child care expenses, and 4. proof of medical coverage which you may have, or may have available to you 5. information relating to professional licenses 6. other: Form CM-509 Service Type M Worker ID 21302 DIAZ %'. DIAZ PACSES Case Number: 830105650 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP: CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225 · All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Service Type M Worker ID 21302 In the Court of Colnmon Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION LISA G. DIAZ ) Docket Number Plaintiff ) vs. ) PACSES Case Number RODRIGO J. DIAZ ) Defendant ) Other State ID Number 02-5524 CIVIL 830105650 ORDER OF COURT You, RODRIC-O JOSE DIAZ 31 NELSON DR, CARLISLE, PA. 17013-9337-31 plaintiff/defendant of are ordered to appear at DOMESTIC RELATIONS HEA/ZING RM DOMESTIC RELATIONS 0FC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the OCTOBER 27, 2003 at 9: 00aM for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return includine 2. your pay stubs for the preceding six (6) months, 3. verification of child care expenses, 4. proof of medical coverage which you may have, or may have available 5. information relating to professional licenses 6. other: Form CM-509 Service Type M Worker ID 21302 DIAZ v. DIAZ PACSES Case Number: 830105650 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: YOU HAVE THE RIGHT TO A LAWYER, WHO MAY' ATTEND THE HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP: CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: {7'17) 240-6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Service Type Iq Worker ID 21302 LISA G. DIAZ, Plaintiff VS. RODRIGO J. DIAZ, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO: 02-5524 CIVIL TERM : PACSES NO: 830105650 : : 1N DIVORCE PRAECIPE To the Prothonotary: I hereby withdraw the appearance that I previously entered on behalf of the Plaintiff, Lisa G. Diaz, in the above captioned case. Respectfully submi~ted, UCatherine A. Boyle,~ Esq 're 410 North Second Street ~' PO Box 1062 Harrisburg, PA 17108 (717) 236-9428 To the Prothonotary: Please enter my appearance on behalf of the Plaintiff, Lisa G. Diaz, in the above captioned matter. Respectfully submJ.tted, ]~/West Pomfret Street ~arlisle, PA 17013, (717) 243-0123 LISA G. DIAZ, Plaintiff VS. RODRIGO J. DIAZ, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 02-5524 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PRAECIPE To the Prothonotary: I hereby withdraw the appearance that I previously entered on behalf of the Plaintiff, Lisa G. Diaz, in the above captioned case. To the Prothonotary: Respectfully submitted, PO Box 1062 Harrisburg, PA 17108 (717) 236-9428 Please enter my appearance on behalf of the Plaintiff, Lisa G. Diaz, in the above captioned matter. Respectfully submi'~ted, Carlisle, PA 17013 (717) 243-0123 LISA G. DIAZ, plaintiff/Petitioner VS. RODRIGO J- DIAZ, Defendant/Respondent IN THE coURT OF COMMON pLEAS OF cuMBERLAND couNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 2002-5524 CIVIL TERM IN DIVORCE Pacses# 830105650 ORDER OF COURT AND NOW, this 19th day of Noveraber, 2003, based upon the Cou~t's determination that Petitioner's and Respondent's monthly net income/earning capacity monthly net income/earning capacity is SN/A to the pennsylvania State Collection and is SN/A, it is hereby Ordered that the Respondent pay as follows; $147.00 for alimony pendente Disbursement Unit, $147.00 per month payable monthly lite and $0.00 on arrears. First payment due next pay date. Arre~;s set at $311.7 l as of Novemcr 19, 2003. The effective date of the order isNovembcr 1, 2003 This Order is based upon the parties' Stipulation and Agreement of November 14, 2003. Husband is to pay Alimony Pendente Lite in the amount of $74 C 0 per month, effective August 25, 2003 through October 31, 2003. Effective November 1,2003, the Alimony Pendent¢ Lite is modified to $147.00 per month. Failure to make each payment on time and in full will cause all arrears to become subject to a (; S 3703. Further, if the Court immediate collection by all of the means as provided by 23 P . · .§ finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the PA SCDU to: Lisa G. Diaz. Payments must be made by check or money order. All checks and money orders must be made payable to PA SCDU and mailed to: PA sCDU P.O. Box 69110 Harrisburg, PA ![7106-9110 payments must include the defendant's PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. Unreimbursed medical expenses that exceed $250.00 armually are: to be paid 0% by the respondent and 100% by petitioner. The petitioner is responsible to pay the first $250.00 annually in unreimbursed medical expenses. Respondent to provide medical insurance coverage. Within thirty (30) days after the entry of this order, the Respondent shall submit written proof that medical insurance coverage has been obtained or that application for coverage has been made. Proof of coverage shall consist, at a minimum, of: 1) the name of the health care coverage provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims should be made; 5) a description of any restrictions on usage, such as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms. This Order shall become final ten days after the mailing of the 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 11-20-03 to: < P~itioner Respondent John King, Esquire Taylor Andrews, Esquire BY THE COURT, KevinA. Hess J. CC360 ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsv vanb Co./City/Dist. of CUMBERLAND Date of Order/Notice 11/19/03 Tribunal/Case Number (See Addendum for case summary) C) Original Order/Notice Q~) Amended Order/Notice C) Terrninate Order/Notice Employer/Withholder's Federal EIN Number CO~4ONWEALTH OF PA C/O PAYROLL OPERATIONS ATTACHMENTS RESEARCH UNIT PO BOX 8006 F~RRISBURG PA 17105-8006 RE: DIAZ, RODRIGO J. Employee/Obli§or's Name (Last, First, MI) 168-60-3538 £mployee/Obli§or's Social Security Number 7730101104 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, MI) See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: 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. $ 879. oo per month in current support $ 0.00 per month in past-due support Arrears 12 weeks or greater? C)yes (~) no $ 0. oo per month in medical support $ 0. o0 per month for genetic test costs $ per month in other (specify) for a total of $ 8'/9. O0 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: $ 202.8'~ per weekly pay period. $ ~,05.6q per biweekly pay period (every two weeks). $ 439.5n per semimonthly pay period (b/vice a month). $ 879.0 0.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 am 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, PAYMENTS 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 ~ THE CO~j.,~ Date of Order: NOV ~ 0 ~;~n.] ~.. Y"~' /~l. ~ Service Type M Form EN-028 OMB NO.: 0970-0154 Worker ID $TATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS If hecke you are required to provide a opy of this form to your m oyee. If yo r employee works in a state tha is [] difl~rent ~(~m the state that issued this o~dCeCr, a copy must be prov c~emoPto your emp~J~yee even if the box is not che~:lked. 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 nolice. 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. *-,R~po,~:,,-,~ t[',~ ?a dar-' ..... ~ .... '--~ · ~ra .................. th~ 6,n~-.Io);~6 $ ,,a~e~z You must comply with the law of the state of the employee's/obligor's princrpal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. · Employee/Obhgor w~th Mult pie Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible· (See #10 below) 6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S ID: 2321722990 ' EMPLOYEE'S/OBLIGOR,S NAME:. DZAg,~ RODR'r~O ~T. EMPLOYEE'S CASE IDENTIFIER: 77303.0~.3.04 DATE OF SEPARATION:. LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 10.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 11. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 1 7013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (71 7) 240-6225 or by FAX at ~3.ZL2_~ or by internet www.childsupporLstate.pa, us Service Type Page 2 of 2 Form EN-028 OMBNo.:O970q)154 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: DIAZ, RODRIGO J. PACSE$ Case Number 830105650 _Plaintiff Name LISA G. DIAZ Docket Attachment Amount 02-5524 CIVIL $-' 147.00 Child(ren)'s Name(s): DOB PACSES Case Number 849105165 _Plaintiff Name LISA G. DIAZ Docket Attachment Amount 00025 S 2003 $- 732.00 Child(ren)'s Name(s): DOB identified above in any health insurance coverage available through the employee's/obligor's employment. _PACSES Case Number Plaintiff Name pocket Attachment Amount $ 0.0o Child(ren)'s Name(s): DOB r-Jif Checked, you are required tO enroll the child(mn) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Casp Number Plaintiff Name Docket _Attachment Amount $ o.00 Child(mn)'s Name(s): DOB I--Ill checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ..P,ACSES Case Number Plaintiff Namp Docket Attachment Amount $ 0.0o Child(ren)'s Name(s): DOB 1-11f checked, you are required to enroll the child(mn) identified abow~ in any health insurance coverage available through the employee's/obligor's employment. ?ACSES Case Number .Plaintiff Name D~ocket Attachment Amount $ o.0o Child(ren)'s Name(s): DOB E]lf checked, you are required to enrol the child(ren) identified above in any hea th insurance coverage available through the employee's/obligor's employment. [] If checked ycu are required to enroll the child(ren) identified above in an~ health insurance coverage ava abl through the employee s/obhgor's employment, e Service Type M Addendum Form EN-028 OMBNo.:0970.0154 WorkerlD $IATT LISA G. DIAZ, V. RODRIGO J. DIAZ, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-5524 CIVIL : : CIVIL ACTION - LAW : IN DIVORCE INVENTORY OF RODRIGO J. DIAZ Defendant files the following invemory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Defendant, Rodrigo J. Diaz, verifies that the statements made in this inventory are true and correct. Defendant understands that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Rodrigo J. Di~, Defendant ASSETS OF THE PARTIES Defendant marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. (x) 1. (x) 2. ()3. ()4. (x) 5. (x) 6. ()7. ()8. ()9. () 10. ()il. () 12. () i3. (x) 14. ()15. ()16. () I7. (x)18. (x) 19. ()2o. ()21. ( ) 22. ()23. ( ) 24. (x)25. (x)26. Real Property Motor vehicles Stocks, bonds, securities and options Certificates of deposit Checking accounts, cash Savings accounts, money market and savings certificates Contents of safe deposit boxes Trusts Life insurance policies (indicate face value, cash surrender value and current beneficiaries) Annuities Gifts Inheritances Patents, copyrights, inventions, royalties Personal property outside the home Business (list all owners, including percentage of ownership, and officer/director positions held by a party with company) Employment termination benefits-severance pay, worker's compensation claim/award Profit sharing plans Pension plans Retirement plans, Individual Retirement Accounts Disability payments Litigation claims (matured and unmatured) Military/V.A. benefits Education benefits Debts due, including loans, mortgages held Household furnishings and personalty (include as a total category and attach itemized list if distribution of assets is in dispute) Other MARITAL PROPERTY Defendant lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced: Item Description Names of Number of Property All Owners 1. Marital Residence (proceeds from sale currently in escrow) 2. Residence - 625 E. York St., York, PA Plaintiff 3. Household furnishings and personalty Plaintiff/Defendant 4. 1998 Ford Escort Plaintiff/Defendant 5. 1995 Saturn SC2 Plaintiff/Defendant 6. Retirement (husband) Defendant 7. Retirement (wife) Plaintiff 8. Deferred Compensation Plan (husband) Defendant 9. Deferred Compensation Plan (wife) Plaintiff 10. Family Care Assistance Program Payout Plaintiff/Defendant 11. Joint Savings and Checking Accounts Plaintiff/Defendant 12. Wife's Saving and Checking Account Plaintiff 13. Patriot Credit Union Plaintiff/Defendant Plaintiff/Defendant NON-MARITAL PROPERTY Defendant lists all property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property: Item Description Reason for Number of Property Exclusion Partial Deferred Compensation Plan (husband) Earned and accrued Pre-marriage Item Number Description of Property PROPERTY TRANSFERRED Date of Consider- Transfer ation Person to Whom Transferred NONE Item Number Description of Property LIABILITIES Names of All Creditors Names of All Debtors NONE k/p:divorce\diaz.inv LISA G. DIAZ, V. RODRIGO $. DIAZ, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-5524 CIVIL : : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE I, John F. King, Esquire, hereby certify that on March q , 2004, I served a copy of the within Inventory of Rodrigo J. Diaz, by depositing same in the United States Mail, first class, postage prepaid, addressed as follows: Taylor P. Andrews, Esquire Andrews & Johnson 78 West Pomfi'et Street Carlisle, PA 17013-3216 FRIE~I-~-'N'~ KING, P.C. Jo~n F. King, Esq~ire~X.. ~ N. Second s~e~[ "~ · en~ouse Suite ~ _.~) P. O. Box 984 H~risburg, PA 17108 (717) 236-8~0 LISA G. DIAZ, Plaintiff VS. RODRIGO J. DIAZ, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 02-5524 CIVIL TERM CIVIL ACTION -- LAW Defendant : 1N DIVORCE INVENTORY OF LISA G. DIAZ Plaintiff files the following inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Plaintiff verifies that the statements made in this inventory are tree and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Lisa G. Diaz, Plaintiftt.~] ASSETS OF THE PARTIES, Plaintiffmarks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. (x) 1. (x) 2. (D 3. (~) 4. (x) 5. (x) 6. (__)7. (__) (.~ 9. O fid O (x) fid (x) fid (x) (x) fid (__) (__) (x) (x) Real property Motor vehicles Stocks, bonds, securities and options Certificates of deposit Checking accounts, cash Savings accounts, money market and savings ce~tificates Contents of safe deposit boxes Trusts Life insurance policies (indicate face value, cash surrender value and current beneficiaries) 10. Annuities 11. Gifts 12. Inheritances 13. Patents, copyrights, inventions, royalties 14. Personal property outside the home 15. Business (list all owners, including percentages of ownership and officer/director positions held by a party with company) 16. Employment termination benefits - severance pay, worker's compensation claim/award 17. Profit sharing plans 18. Pension plans (indicate employee contribution and date plan vests) 19. Retirement plans, Individual Retirement Accounts 20. Disability payments 21. Litigation claims (matured and matured) 22. Military/V.A. benefits 23. Education benefits 24. Debts due, including loans, mortgages held 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute) 26. Other MARITAL PROPERTY Plaintiff lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this ,,action was commenced: Item Description of Names of All Number Property Owners Marital Residence Proceeds Household Furnishings and other tangible personal property 1998 Ford Escort 1995 Saturn SC2 State Retirement State Retirement Deferred Compensation Deferred Compensation Family Care Assistance Program Payout Accrued vacation/personal time benefits Accrued vacation/personal time benefits Joint checking and savings accounts Wife's checking and savings accounts Patriot Credit Union account Plaintiff/Defendant Plaintiff/Defendant 3. Defendant 4. Plaintiff 5. Plaintiff 6. Defendant 7. Plaintiff 8. Defendant 9. Plaintiff/Defendant 10. Plaintiff 11. Defendant 12. Plaintiff/Defendant 13. Plaintiff 14. Plaintiff/Defendant NON-MARITAL PROPERTY Plaintifflists all property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property: Item Description of Reason for Number Property Exclusion Partial Deferred Compensation Plan Accrued by Defendant before DOM 2. Real Estate - 625 E. York St., Owned by Plaintiff York, PA before DOM Item Number Description of Property PROPERTY TRANSFERRED_ Date of Consideration Person to Whom Transfer Transferred None Item Number Description of Property LIABILITIES Name of All Creditors Names of All Debtors None LISA G. DIAZ, Plaintiff VS. RODRIGO J. DIAZ, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO: 02-5524 CIVIL TERM : CIVIL ACTION o LAW : : IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that on this date, April t ~'~, 2004, I mailed a copy of this Inventory to the following person at the following address by U.S. Mail, Certified mail, postage prepaid, return receipt requested, delivered to addressee only: John F. King, Esquire 600 North Second Street Penthouse Suite PO Box 984 Harrisburg, PA 17108 I verify that the statements made in the foregoing Certificate of Service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unswom falsification to authorities. ANDREWS & JOHNSON By:Tay~.~.~ At(orn)/ys fbr Plaintiff 78 ~ Pomfret Street Carlisle, PA 17013 (717) 243-{) 123 LISA G. DIAZ, RODRIGO J. DIAZ Plaintiff Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-5524 CIVIL TERM : : CIVIL ACTION - LAW : 1N DIVORCE PLAINTIFF'S PRETRIAL STATEMENT AS PER PA. R.C.P. 1920.33(b) 1. ASSETS. The marital assets are set forth on Exhibit 1 attached. It is believed that all values except those in shaded cells are agreed to by the parties. This has been established by prior correspondence. The parties disagree as to the valuation of the deferred compensation and the proper calculation of the vacation/sick/personal day employment benefit. Husband contends that the deferred compensation should be valued after deducting for taxes paid resulting from an early post-separation distribution. 2. EXPERT WITNESSES. There is no apparent need for expert testimony, unless the parties retreat from a prior agreement as to the value of the personal property that was appraised by IBIS Appraisers, or their prior agreement as to the calculation of the coverture portion of each party's state retirement. 3. LAY WITNESSES. A. Harold Garland - Mrs. Lisa Diaz's father. He would testify as to the loans that have been made to Lisa Diaz since the marital breakup. These totaled $43,871.22 as of April 15, 2004. B. Custodians of billing records from Myers, Desfore, Saltzgiver & Boyle and from Andrews & Johnson, to establish the legal fees paid by Lisa Diaz incident to this divorce/custody action. 'l-hese totaled $30,282.84 to Myers, Desfore, Saltzgiver & Boyle from October 2002 through October 2003 and $7,731.12 to Andrews and Johnson from October 2003 to the present. 4. EXHIBITS: Exhibit 1 - the spreadsheet attached hereto as Exhibit 1 recording the values for the component parts of the marital estate that can be stipulated to. [the sheet may be altered to reflect the extent of the stipulations if they are different than now anticipated] Exhibit 2 - [if necessary] record of value of Rodrigo Diaz's Deferred compensation plan, either when cashed in or at current value. [this is not attatched because Plaintiff does not have a copy available]. C. Exhibit 3 - record of value of Rodrigo Diaz's Deferred compensation plan at the time of the marriage. D. Exhibit 4 - record of value of Lisa Diaz's Deferred compensation plan when it was cashed in. E. Exhibit 5 - record showing accrued vacation of Rodrigo Diaz at time of marriage. F. Exhibit 6 - record showing accrued vacation of Rodrigo Diaz at time of separation. G. Exhibit 7 - record showing accrued vacation of Lisa Diaz at time of separation. H. Exhibit 8 - Commonwealth of PA Pay schedule for 2004 [2002 version is attached] I. Exhibit 9 - Pay record for Rodrigo at time o:f marriage [used to calculate value of vacation benefit]. J. Exhibit 10 - Pay record for Rodrigo at time of separation [used to calculate value of vacation benefit]. K. Exhibit 11 - Pay record for Lisa Diaz for August 2003 [used to calculate value of vacation benefit - date of separation pay not available]. L. Exhibit 12 -Attomey bills for Lisa Diaz. M. Exhibit 13 - copy of PSECU note from Lisa Diaz representing other current debt. N. Exhibit 14 - copy of Sears bill representing current debt of Lisa Diaz. O. Exhibit 15 - copy of ledger of ongoing loans from Harold Garland to Lisa Diaz. [ledger as of April attached. This will be updated at time of hearing] Exhibit 18 and thereafter - Such records and reports as are necessary to establish values that Plaintiff now expects to be established by stipulation. [e.g. person property appraisal, escrow account statements, settlement sheets, retirement reports, bank statements, etc.] 5-6. INCOME/EXPENSES Plaintiff's income and expenses are as shown on the Income and Expense statement and pay record that she filed with the Cumberland County DRO in July 2003, though a new paystub will be provided at the Prehearing conference to update the salary to the current time. A copy of these records are attached hereto as Exhibit 16. DRO calculated Plaintiff's net income in September 2003 as $2,6(18.68. Defendant is also a state employee, and his net income was calculated in September 2003 as being $3,830.13 per month. Defendant pays child support and alimony pendente lite to Plaintiff in the amount of $732 and $74 per month respectfully. The stipulation for the support order referenced herein is attached hereto as Exhibit 17. 7. PENSION/RETIREMENT BENEFITS At the time of the separation both Mr. and Mrs. Diaz were state employees. By prior correspondence they have agreed that the present value of the marital portion of each of their retirements is as follows: A. Mr. Diaz - $58,002 B. Mrs. Diaz - $32,085 If this agreement does not continue for the Master's hearing there will be a need to secure the services of an actuary to value the retirements. 8. COUNSEL FEES/COST As noted above, Mrs. Diaz has incurred substantial counsel fees in this case. These obligations have caused her to go into significant debt and have affected her need for liquid assets to meet her obligations. Her fees paid through June 2004 total $38,013.96. Though Plaintiff is not privy to the information, she believes that Defendant has not incurred comparable fees. He is an attorney and is represented by a former classmate from law school. 9. TANGIBLE PERSONAL PROPERTY The parties have divided their personal property and they have had the personal property in each other's possession appraised by IBIS appraisers. It is expected that the value of the personal property will be agreed to as set forth on Exhibit 1. 10. MARTIAL DEBTS All marital debts have been paid. Plaintiff, Mrs. Diaz, has significant non-marital debt incurred since the separation. This has been detailed above. 11. PROPOSED RESOLUTION Plaintiff proposes that she be awarded $10,000 toward her attorney fees and that she be awarded 60% of the remaining marital estate with the most liquid assets possible transferred to her. Plaintiff also seeks alimony for an indefinite time at the same rate as her current alimony pendente lite. /T~tylo)'~r~}~ndrews, Esq. 7_(~_. e_st Pomfret Street Carlisle, PA 17013 (717) 243-0123 Supreme Court ID No. 15641 Office Chief Counsel I Deferred [Compensation q '/Program SECURE YOUR FUTURE. TODAY. THE COPELAND COMPANIES Fax:Ti7-787-8820 I,,,lli,,,lll.,.,hl,,i,i.,ll..11, J ,L,II,.,,II.,,II..II-! e.~##.e,,,e,ae.r,.-'.+.v.. AUTO 5'-'DIGIT 1705~ 00005~ql T00000031 RODRIDO J DIAZ 133 w. LOCUST STREET APT HEGHAN I GSBURG PA 170~5 ,lan 15 2004 11:50 P. 04 PAGE I TOTAL 12/31 ~E$Tt4EHT FUND ,Be TOTAl. TRANSFER DISTRIBUTIONS ~&IN/(~OB~) BALANCE [~IGNATION , NUMBER CONTRIBUTION , ~A'GROUP FUNDS EAFE EQUITY' INDEX lh65 EXTENDED MARKET FUND 1461 STOCK INDEX-FUND 0187 PLAN TOTALS 688.2~ .00 ,00 11,86 700,08 688.22 ,00 .00 ~6.~5 73q.q7 7oq.~1 .00 _ .oo, ~o.g8 770.39 Z,O85.B~ .Do ,00 11~.0~ 2,2oh. Dh PLEASE NOTE YOUR FOUR DIGIT FUND NUMBER FOR USE WITH THE OOPELAND AUTOMATED INFORMATION SYSTEM. CALL HELPLINE FOR MORE DETAILS. ## ERIOD SUMMARY ( f0101196 - f2/3flg; ) NYESTPIE~T 10/01 TOTAL PERIOD £SlONATIO~ RALANC~ CONTRIBUTION PA GROUP FUNDS EAFE EQUITY INDEX 323.q2 EXTENDED MARKET FUND TRANSFER DISTRIBUTIONS P~RIOD ' 12/31 .00 .00 6,08 700.08 .oo ,0o 28,31 7Sa.h7 STOCK INDEX FUND 3~.95 381-o9 .00 _ ,o0 as.b5 77n,39 PERIOD TOTALS 1.003 95 1.123.15 .00 .00 77.8~ 2,20q.gg )ETA/LEDTRANSACT/ONS (10/01/96 -12131/95 ) INVEBTMENT TRANSACTION __DATE DEBCRIPTION '"10102/~6 CONTRIBUTION :,~oT,~,~6---~-~o~-te~ ............. 10/02/96 CONTRIBUTION lO/15/96 CONTRIBUTION 10/15/96 CONTRIBUTION 10/15/96 CONTRISUT ION 10/~9/96 CONTRISUTION 10/29/~6 CONTRIBUTION 10/2~/96 COMTRIDUTION 11/I~/96 CONTRIBUTION 11/12/~6 CONTRIDUTION 11/12/96 6ONTRIBUTION FUND DOLLAR UNIT/SHARE UNITS/ NAME AMOUNT VALUE SNARES .... -~-X-T-ENO~-FrE:~---F't~'~D- 5~,'~94 .0000 .0000 STOCK INDEX FUND 5~.57 .0000 ,0000 EAF~ EQUITY INDEX ~.9~ ,0000 .0000 STOCK INDEX FUND 5~.57 .0000 .OODO EAF~ EQUITY INDEX D~,9~ .0000 ,0000 EXTENDED MARKET FUND ~2.9~ ,0000 .0000 ~TOOK INO[X FUND 5~.S7 .0000 .0000 EAFE E~UITY INDEX 52.9q ,0000 .0000 EXTENDED MARKET FUND 52.g~ ,0000 .0000 STOCK iNDEX FUND 5~.~7 .0000 .0000 ( PLEAS~ SEE NEXT PAGE ) of¢ice Chie{ Counsel o%,- I Deferred /Compensation '[Pro 'am S~c~t ~t m~z To~ Administered. Em'otlcd and Strvlccd hy THE COPELAND COMPANIES RODRIGO J DIAZ Fax:717-787-8820 J,~n 15 2004 11:51 P. 05 12/31/96 168-60-3 ~.t8 O1111142' 1-~00-,~zz-1327 PAOE 2 !TAILED TRANSACTIONS ( f0101198 - I2131196 ) 11/~2/96 CONTRiBUTiON 11/22/96 CONTRIBUTION 11/22/96 CONTRIBUTION 12/10/96 CONTRISOTION 12/10/96 CONTRIBUTION 1~/10/D~ OONTRIBUTION 12/23/96 CONTRIBUTION 12/25/96 CONTRIBUTION 12/2~/96 CONTRIBUTION ADMINISTRATIVE CHARGE EAFE EQUITY INDEX EXTENDED MARE£T FUND STOCK INDEX FUND EAFE EQUITY INDEX EXTENDED MARKET FUNO STOCK INDEX FUND EAFE E~UITY INDEX EXTENDED MARKET FUND STOCK INDEX FUND EAFE EQUITY rNDEX · _~OLLAA- U~[~!~HARE--__.'... UNITS/ AMOUNT VALUE SHARON 52.9~ ,0000 .0000 52.90 o0000 ,0000 5~.~7 .0000 .0ooo ~2.94 .0000 .0000, ~,9~ .0000 .0000 5~.~7 ,0000 .0000 ~z.~ .oo00 .0000 52.94 ,0000 ,0000 ~q.57 .0000 .0000 1.66 .0000 .0000 12/$1/96 12/31/96 ADMINISTRATIVE CHARGE EXTENDED ~AR~ET FUND 1.66 ,0000 ,0000 12 31 96 ADMINISTRATIVE CHARGE STOCK INDEX FUND 1.68 ,O00O ,00o0 ~¥ROLL CONTRIgUTIONS NOT YET POSTED BY THE APPROPRIATE ISSUERS TOTALED $ .00 RST M PAODQO0 ~7B E£ Office Chief Counsel Fax:717-787-8820 Jan 15 200d 11:51 P. 06 THE COPELAND COMPANIES Two Tower Center, P.O. Box 1063 East Brunswick, New Jersey 08818-t083 Tel: (908) 214-2000 FAX: (908} 214--2027 June 14, 1996 PENNSYLVANIA DCP 4720 OLD GETTYSBURG ROAD SUITE 407 MECKANICSBURG, PA 17055-9934 (800) 422:-1327 RODRIG0 J. DIAZ 212 BEACON DR HARRISBURG, PA 17112 Dear MR. DIAZ, Welcome Co the Deferred Compensation Plan offered through COMMoATwEALTH OF PEAT~SYLVANiA. Your ~nrollm~nt Forms and Partlcipat±on Agreement have been processed, and, as of July 12, 1996 you are enrolled in the Plan. The Copeland Companies is the servicing agent of your plan and it is our goal to assist you in buildin~ a secure ~inancial future. If you have any questions COncerning your deferred compensation plan or retirement planning in general, please do not hesitate to call your local office at (800} 422-1327. Please review your enrollment data below. If any of this information is incorrect, please call our local office personnel immediately. Sincerely, TA~ CODELAND COMPANIES Dennis ~_ Casey Vide President, Administra~ive 0p~rations Employer: COMS~0NWEALTH OF PENNSYLVANIA EfEective Date of Participation: July 12, Social Security.Nu/nber: 168-60-3538 Department ~umber: 026 Per Pay Amount: $ 160.4~ Investment Options Selec~eo: 33% EAFE ~QUITY INDEX 1996 Copeland Associates, In¢. Copelar~d Equities, Inc. Copeland Firlaneial Services, J~c. Office £hief Counse! Fax:717-787-8820 Jan 15 2004 11:52 P.07 ]~ THE COPELAND COMPANIES Two Tower Center, P,O. Box 1063 East Brunswick. New Jersey Tel: (908) 214-2000 FAX: (908) 214-2027 I~vestme~t Options Selected: 33% - EXTENDED ~3~RKET 34% - STOCK INDEX FUND 168-60-3528 Page 2 Copeland Assooiate$, Inc. CopeJand Equities. Inc. Co~eiand FinanciaJ Serv;ees, Jnc, ill gO 'd 00:8I £00~ 6~ O~88-ZSZ-Z~t.:xeJ Iasuno3 .~a,~q3 ao.~.~.~0 £O'd 00:8I £OOg 6g 3aCI O~.88-ZSZ-d_IZ:xezl i'~suno3 J-@,~q3 717-7~7-727~ BOARD OF ~PPE~L$ 05/05 1D/24/2003 i0:3~ 717-772-i459 OFF OF CHIEF COUNSEL PAGE 0! COMMONWEALTH OF PA - EMPLOYE STATEMENT PAY PERLOD ENDING: 11-15-96 PAY DATE: 11-27-96 VT#: 692600230000 DEPT: 026 CDC: 0S120 EHP#: 432043 POS#: 106744 SEN: 16N-60-3538 B/U: A3 PAY RANGE: 09 STEP: 3 LEVEL: O0 LIQUOR CONTROL BOARD CHIEF COUNSEL RODRIGO d DIAZ 133 WEST LOCUST ST.,APT. C-18 MECHANICSBURG PA 17055 HEALTH BENEFITS POS: CAPITAL BC/BS-SC REG LIFE INSURANCE HORKERS COMP SOCIAL SECURITY MEDICARE RETIREMENr STATE EMPLOYES RET SYS ALL BENEFITS LISTED AEOVE CONTINUE AT FULL VALUE. SERVICE CREDIT: 4 YR 7 PP GROESMiNusEARNINGSDEDUCTiONS I 1,616.25 r 3,,TTl. OO FED NTH TX S 02 187.65 SOC SEC TX 6.20000% 100.21 SOC SEC/HED l'X 1.45000% 23.44 PA 2.80000% 45.26 PA 21 804 1.00000% STATE EMP 5.00000% STATS NTH TX LOC MG TX-RES RET P/U CON FED MTH TX-ADD FAX OEF COHP ST EMP COMa AP NET EARNINGS: PLUS REIMBURSEMENTS 5,369.A7 80.81 1,988.53 25.00 600.00 9.31 223.44 967.96 REG SAL 75.00 21.B 1,616.25 !LEAVEXCT BALANCE LAST STATEMENT 198.39 384.51 .00 ACCRUAL THIS PP 4.33 3.75 .00 LV REPORTED THIS Pp ,00 1.00 .00 ADJUSIMENTS ,00 .00 .00 BALANCE THIS STMT 202.72 387.26 .00 MESSAGE CENTER: LOCAL NAGE TAX COUNTY/MUNICIPALITY: CUMBERLAND COUNTY FHT TAX GROSS: 1,374.99 HECMANICSNURG BONO WHAT: Pennsylvania Employees Benefit Trust Fund {PEBTF) Open Enrollment WHEN: December 2, 1996 through December 20, 1996 COVERAGE EFFECTIVE DATE: February 1, 1997 OPTIONS: Health Maintenance Organization (HMO). Point of Service (POS}, atnd Basic (Blue Cross/Blue Shield/Major Medical). For employes in the Philadelphia area only, a new Preferred Provider Organization (PPO) option will be offered. MAILINGS: You will receive material from the PEBTF regarding the Open Enrollment. You may receive material from the health care plans in your area Please READ AND SAVE TIlE MATERIAL. EMPLOYE MEETINGS: Meetings will be held only in the Philadelphia five county area. Those meetings will be held from December 2, 1996 through December 20, 1996. PEBTF-2 FORM: If you wish to transfer to another health care plan during the Open Enrollment. contact your local agency personnel office to complete a PEBTF-2 form. The earlier in the enrollment period that you complete the PEBTF-2 form, the less likely that there will be delays in your new coverage. QUESTIONS: Contact PEBTF at 1-800-522-7279 if you have any questions. COMMONWEALTH OF.PA - EMPLOYE STATEMENT PAY PERIOD ENDING: 08-18-02 PAY DATE: 08-30-02 VT#: 292600090000 DEPT: 028 CDC:~ 08120 EMP#: 632043 POS#: 109180 SSN: 168-60-3538 B/U: A3 PAY RANGE: 11 STEP: 5 LEVEL: O0 LIQUOR CONTROL BOARD CHIEF COUNSEL RODRtGO d DIAZ 31 NELSON DRIVE CARLISLE PA 17013 HEALTH BENEFITS POS: HEALTH ONE RET EMP HLTH PROG (REHP) ANN HED HOSP LIFE INSURANCE WORKERS COMP SOCIAL SECURITY MEDICARE TOTAL STATE PAID 8ENEFITS $ 571.41 SERVICE CREDIT: 10 YR i PP 7.50 Gi~OSS EARNINGS MINUS DEDUCTIONS FED NTH TX M OI SOC SEC TX 6.20000% SOC SEC/MED TX 1,45000u%/ STATE HTH TX PA 2,8000 LOC NG TX-RES PA 21 908 1.60060% RET P/U CON STATE EHP 66.~000% FEDNTH TX-ADD /oo2 FAH CARE DED FCAP PLAN YE ST EHP COMB AP J NET EARNINGS: PLUS REIMBURSEMENTS THIS PA~ ~:Bl 1,649.87 ',?AB :TO r~ATE 46,357.49 4,904.80 2,867.55 623.N6 1,298.02 542.37 2,897.39 450.00 3,333.2B 270,90 BALANCE LAST STATEMENT, 325.26 903,91 19.50 ACCRUAL THIS PP 4.33 3.75 .00 LY REPORTED THIS'PP 7.50 1.00 .00 ADJUSTM~TS .00 .00 BALANCE THIS STMT 906.66 19.~0 MESSAGE CENTER: L~AL WAGE FAMILY CARE BAL 3,333.28 CUMBERLAND COUNTY FRT TAX GROSS: 2002 State Employee DICKINSON THP. 2,280.03 ! EXHIBIT m Combined Appeal Your Support is truly "A Gift from the Heart" ¥ ¥ ¥ ¥ Are you a "Cruideline Giver"? Your SECA Coordinator can inform you how easy it is to become one! Statewide Kickoff: 09/04/2002 v End of Solicitation Period: 10/17/2002 (;ROSS EARRINGS 1,670.2~ 26,6~2.00 PAY PERIOD ENDING; 07-18-03 PAY DATE: 08-01-03 M[NUS DE~CTIONS VT~: 391800170000 DEPT: 018 ~C: 10310 FED NTH TX H 01 143.2~ 2,~.80 REVENUE BOARD OF APPEALS LOC NG TX-RES PA 21 001 1.6000~ 26.7~ 426.38 RET P/U CON STATE EHP 6.250~ 104.39 ~,665.74 UN DUES AFSCHE - 13 2456 25.05 399.72 504 HZGHLAND COURT ANN MED ~SP RET EHP HLTH PR~ (REHP) RET~REHENT STATE EMPLOYES RET SYS 8.35 TOTAL STATE PAZD BENEFZTS $ 515.78 SERVICE CREDZT: 8 YR 19 PP 07-18~3 ANNUAL 2.00 07-18~3 REG SAL 75.00 22.27 1,670.25 ACCR~LBALANCE TH~sLAST PpSTATEME~T 2~.79~.33 83.153.75 7.507'50 GENE~L NONSUPV 2,2~ CREO[T DAYS EXHI~ AT~ION PEB~-CO~D YO[R E~LO~ES: S~ ~e ba~ of ~is s~m~t for mo~ ~o~afion on ~e benefit ~g~ ~d ~e Pe~lv~a E~loy~ Ben~t T~st ~nd ~EB~) a~~ O~n Enro~ent ~c Open E~ollment will ~ held Au~st 4 ~ou~ 22, 2~ wi~ a coverage e~ve date of October 1, 2~3. ~d~on~ i~o~aU0n will ~ provid~ by · e PEBTF. Watch your m~ for impo~t PEBTF O~n E~ollment mate~s~ · ~e c~ges ~fe~nc~ ~ove a~ly to ~ PEB~over~ employes; however, for ~o~ employes whose ~ have not re~h~ a coH~ve b~gaini.g ~men~ cont~ua~0n of ~e new ~nefit levc~ is con.gent u~n a~men~ wi~ yo~ Attorney fees paid by Lisa Diaz to Myers, Desfor, Salzgiver, & Boyle: Date Amount paid 30-Oct-02 $250.00 6-Nov-02 $3,500.00 25-Nov-02 $3,500.00 6-Dec-02 $3,500.00 7-Jan-03 $65.10 $42.67 7-Feb-03 $5,189.08 9-Apr-03 $1,553.24 21-Apr-03 $1,000.00 29-Apr-03 $3,500.00 1-Ju~-03 $3,500.00 7-Aug-03 $450.00 5-Aug-03 $550.00 20-Aug-03 $900.00 29-Aug-03 $1,000.00 0-Oct-03 $1,782.75 Total to M,D,S & B: $30,282.84 Attorney fees paid to A&J: Total to A&J: Total attorney fees to date: 16-Oct-03 $2,000.00 5-Dec-03 $391.12 8-Jan-04 $495.00 20-Feb-04 $200.00 27-Feb-04 $400.00 15-Ma>04 $1,590.00 14-Ap>04 $885.00 1-Jun-04 $1,000.00 18-Jun-04 $770.00 $7,731.12 $38,013.96 Lisa Diaz 31 Nelson Drive Carlisle, PA 17013 Attention: RE: DATE Nov-05-02 Nov-06-02 Nov-07-02 Nov-12-02 Nov-13-02 Nov- 14-02 Nov- 15-02 Nov-18-02 Nov- 19-02 MEYERS, DESFOR, SAL TZGIVER & BOYLE 410 NORTH SECOND STREET P.O. BOX 1062 HARRISBURG, PA 17108 DESCRIPTION TC with client Fax~ 717-236-9428 717-236-2817 File #: 1nv #: HOURS AMOUNT 0.25" : ~ 41.25 Nov 20, 2002 3050 3309 Draft divorce/custody complaint 2.00 ~ 330.00 ~. CAB Office conference 0.25--~- 47.50 ~LAS Meeting with client; conference with LAS 1.50 -- 24Z50 ------CAB TC with client; review email; revise custody complaint TC with client; draft petition for special relief 1.00,.~:--- 165.00 ~ CAB 1.00 ~ 165.00 ..... CAB Office conference 0.25 ~-~ 47:50 ~ LAS TC with constable; revise custody complaint and petition for emergency and special relief; letters to messenger service and sheriff Conference with CAB 3.50 -~-~' 577.50 0.25---'--' 56125 ' ~CAB -~' BDD TC with client (3x); TC with J. King (4x); letter to King; draft acceptance of service; conference with BDD; meeting with J. King; review agreement/petition TC with J. King (2x); review faxes; TC with client; review email; meeting with client; letter to J. King TC with King; TC with client; review petition 4.25 ~ 701.25 ~ CAB 2.75 ~-- 453.75 ~ CAB 0.75 ~,-- 123.75 ~-~ CAB Invoice #: 3509 Page 2 November 20. 2002 Totals DISBURSEMENTS Nov-06-02 Retainer State Street Copies In-House Photocopies Filing Fee Totals Total Fees, Disbursements Total Retainer Available Retainer Balance Previous Balance Previous Payments Q~,956 17.75 . Disbursements Receipts 3,500.00 19.53 5.95 411.00 ~*~36 48 ~"'~ $3,500.00 $3,500.00 $107.27 $0.00 $0.00 Balance Due Now $0.00 Lisa Diaz 31 Nelson Drive Carlisle, PA 17013 Attention: RE: DATE Nov-20-02 Nov-21-02 Nov-22-02 Nov-25-02 Nov-26-02 Nov-27-02 Dec-02-02 Dec-03-02 MEYERS, D ESFOR, SAL TZGIVER & BOYLE 410 NORTH SECOND STREET P.O. BOX 1062 HARRISBURG, PA 17108 Dec 10, 2002 File #: 3050 DESCRIPTION Conference with CAB ..~, ~ , Conference with BDD; review mail; letter to J. King; meeting with client Office conference Inv #: 3525 e~,(O / o 0.25 =~- ATTY 56.25~ BDD 2.50 ~ 412.50 ~ CAB 0.25 ---- 47.50 ~ LAS TC with client; draft answer to emergency petition Office conference 4.50 ..---- 742.50 .------- CAB 0.25 ~ 56.25 - BDD Office conference 0.25 ~ 41.25 ~ CAB Client conference; review letters (2) 0.50 ~ 95.00 .... LAS office conference with CAB; review file 1.50 ~ 285.00 ~ LAS Office conference with LAS 0.50 "-'" 82.50 .---- CAB Review file; prepare for heating; attend hearing Office conference with CAB 6.00 '~" 1,140.00 '~' LAS 0.25----~'' 47.50 ~ LAS Review email; review order (2x); TC with client; conference with LAS TC with client; letter to J. King 1.50 ~ 247.50 '"'- CAB 0.75 ~ 123.75 j CAB Invoice #: 3525 Page 2 Dec-04-02 Letter to D. Sunday; TC with client Totals DISBURSEMENTS Nov-20-02 Retainers Carried Forward Nov-25-02 Retainer Overnight Delivery Courier Expense Long Distance State Street Copies In-House Photocopies Postage Expense Travel Parking Totals Total Fees, Disbursements Total Retainer Available Retainer Balance Previous Balance Previous Payments December 10. 2002 0.75 123.75 Disbursements 14.97 40.00 10.00 24.06 t 9.95 17.61 21.60 0.50 48.69 CAB Receipts 107.27 3,500.00 $3,607.27 $3,607.27 $0.00 $0.00 $0.00 Balance Due Now $42.67 MEYERS, DESFOR, SAL TZGIVER & BOYLE 410 NORTH SECOND STREET P.O. BOX 1062 HARRISBURG, PA 17108: 717-236-9428 Fax: 717-236-2817 Lisa Diaz 31 Nelson Drive Carlisle, PA 17013 Attention: RE: File #: Inv #: Jan 16, 2003 3050 3576 DATE DESCRIPTION Dec-06-02 Review mail HOURS AMOUNT ATTY 0.25 ~ 41.25 '-- CAB Dec-11-02 Review mail 0.25 ------ 41.25 .----~-CAB Dec- 12-02 Review order 0.25 - ~ 47.50 .. _ LAS TC with client; letter to J. King 0.50 ~ 82.50 ----- CAB Dec- 16-02 Review order; TC with client 0.75 ~ 123 75 .-,,.*~'- CAB Dec-23-02 Review mail; TC with H. Diaz 0.50 ~ 82.50 .... CAB Jan-02-03 Prepare for meeting; review notes/file 1.25 . 206.25 - CAB Jan-03-03 Meeting with client; review diary 2.00 ~-- 330.00 ~- CAB jan-06-03 Jan-07-03 Jan-08-03 Review documents; review emails; prepare for conciliation Attend conciliation; TC with client; TC with J. ICing; review emails; draft interrogatories and request for documents Office conference 1.50 ~"'-"247.50 ~ CAB 4.50 ~742.50 ~ CAB 0.25 ~ 56.25 - BDD Office conference 0.25 ~ 41.25 -- 'CAB Review emails; email client; TC with client 0.50 ~' 82.50 -CAB Invoice #: 3576 Page 2 January 16. 2003 Jan-13-03 Review transcript; review email; emaiI client 1.25 ~ 206.25 ........ CAB Jan-14-03 Conference with law clerk 0.25 41.25 ~'--' CAB Receive assignment 0.25 18.75 SGLC Totals DISBURSEMENTS ~ ~$2 14.50 ( ,391.25 '" Disbursements Receip fs Dec- 16-02 Retainer 3,500.00 Jan-07-03 Retainer for fee for transcripts Facsimile Expense Long Distance State Street Copies In-House Photocopies Postage Expense Telephone Expense Miscellaneous Expense Totals Total Fees, Disbursements Total Retainer Available Retainer Balance Previous Balance Previous Payments Balance Due Now 1.50 5.00 4.40 11.20 6.75 5.00 65.10 65.10 $98.95 "~ $3,565.10 ( ; · $42.67 $42.67 $0.00 Lisa Diaz 31 Nelson Drive Carlisle, PA 17013 Attention: RE: DATE Jan- 15-03 Jan- 16 - 03 Jan- 17 - 03 Jan- 18-03 Jan-20-03 Jan-21-03 Jan-22-03 Jan-23-03 MEYERS, DESFOR, SAL TZGIVER & BOYLE 410 NORTH SECOND STREET P.O. BOX 1062 HARRISBURG, PA 17108 717-236-9428 Fax: 717-236-2817 ~ t ~,ab~ X/~ LO ~ File ~= Inv ~: DESC~PTION ~ TC with Snelson Feb 03, 2003 3050 3621 HOURS AMOUNaT ATTY Revise/draft interrogatories and request for documents; letter to King; review Order(DRO); review custody order; memo re: Dr. Snelson; review email; email client Revise discovery 2.50 .---~412.50 ~ CAB 0.50 ,- 82.50 CAB Research re: custody 1.00 ~ 75.00 ~ SGLC Revise discovery 0.50 ~ 82.50 ~ CAB Finalize discovery; letter to J. King; calculate support Office conference Office conference Review fax; TC with client 1.50 -- .247.50 "--'-"' CAB 0.25 56.25 '- BDD 0.25 ---"--- 41.'25 - ' - CAB 0.50 ~ 82.510 ~ CAB 0.75 ~ 56.25 ~ SGLC 0.7 . 5.00 ~ 375.00 ~ SGLC Research re: custody and memal health Review mail; letter to J. King Research re: parental rights Jan-24-03 Review mail; review email; email client 0.75 ~ 123.75 ~ CAB Invoice #: 3621 Page 2 February 3. 2003 Jan-27-03 Jan-28-03 Jan-29-03 Jan-30-03 Jan-31-03 Research and prepare memorandum re: parental rights TC with J. King (2x); review faxes; letter to J. King; email client Review email; TC with client TC with Dr. Wallin; review mail(3x) Memo re: Wallin; TC with client Review order Totals DISBURSEMENTS Jan-16-03 Retainers Carded Forward Facsimile Expense Long Distance State Street Copies In-House Photocopies Postage Expense Totals Total Fees, Disbursements Total Retainer Available Retainer Balance 4.50. "337.50 ~'"-"SGLC 1.00-~__ 165.00 .-.--- CAB 0.50 ~.. 82.50 ,--"~--CAB 0.75 .--- I23.75 ,~_._ CAB 0.50._..---- 82.50_ CAB 0.25 --------'41.25 ~ CAB 22.5{} ', $2,715.00 ~ Disbursements Receipts 3.00 5.00 13.57 17.50 9.91 ,074.90 $0.00 Previous Balance Previous Payments Balance Due Now $0.00 $0.00 Lisa Diaz 31 Nelson Drive Carlisle, PA 17013 MEYERS, DESFOR, SAL TZGIVER & BOYLE 410 NORTH SECOND STREET P.O. BOX 1062 HARRISBURG, PA 17108 717-236-9428 Fax: 717-236-2817 File #: Inv #: Feb 11,2003 3050 3637 Attention: DATE Feb-05-03 Feb-06-03 Feb-07-03 DESCRIPTION Review emails; TC with client Office conference Office conference Meeting with client; TC with J. King Totals DISBURSEMENTS Feb-07-03 Retainer Retainer payment from retainer State Street Copies In-House Photocopies Postage Expense Totals HOURS AMOUNT 0.25 ?----~ 4t.25 0.25 ~56.25 0.25 ~ _4).25 1.25 ~ 206.25 Disbursements 10.92 2.10 Receipts 5,189.08 -1,689.08 ATTY CAB BDD CAB CAB 2.45 Invoice #: 3637 Page 2 February I1. 2003 Total Fees, Disbursements Total Retainer Available Retainer Balance Previous Balance Previous Payments $360.47 $1,689.08 Balance Due Now $0.00 MEYERS, DESFOR, SAL TZGIVER & BOYLE 410 NORTH SECOND STREET P.O. BOX 1062 HARRISBURG, PA 17108 Lisa Diaz 31 Nelson Drive Carlisle, PA 17013 Attention: RE: DATE DESCRIPTION Feb- 10-03 Research Feb-l.l-03 Feb-12-03 Feb- 13-03 Feb-14-03 Feb- 18-03 Feb-19-03 Feb-21-03 Feb-24-03 Feb-25-03 717-236-9428 Fax: 717-236-2817 Apr23,2003 File #: 3050 Inv #: 3743 TC with J. King; review email; letter to J. King TC with Dr. Wallin; TC with client; conference with law clerk; review mail/records from Holy Spirit Hospital Receive assignment begin research Review documents Review email (2x); review documents; email client Review mail; letter to J. King; review faxes Office conference Revise questionaires; review faxes; TC with client; review emails (5x); emall client (2x) Office conference Review email Review emalls / review documents/letter to J King Review emails / cards/documents. Call client HOURS AMOUNT ATTY 4.00 ~' 0.00 --~ SGLC 0.75 ~ 123.75,~'~' CAB 1.50 ~ 247.50 ~ CAB 0.50 ~ 37.50 -~' SGLC 0.25 ~ 41.25. ~r- CAB · 0.75~---- 123.75 ~'~-- CAB 1.00 ~ 165.00 --~'" CAB 0.25 ---- 56.25 ~ BDD 2.00 ~-~7 330.00---~' CAB 0.25 ~_~ 41.25 -~..~ CAB 0.25 ~ 41.25 ~ CAB 0.50 82.50 ~.~ CAB 0.75 ~--123.75 _~.-~ CAB 'Invoice #: 3743 Page 2 April 23. 2003 Feb-26-03 Mar-04-03 Mar-06-03 Mar-07-03 Mar- 11-03 Mar-12-03 Mar-13-03 Mar-17-03 Mar- 18-03 Mar-19-03 Mar-20-03 Mar-21-03 Mar-25-03 Mar-26-03 Mar-27-03 Mar-31-03 Apr-01-03 Apr-02-03 REVIEW MAIL Office conference 0.25 ~ 41.25 ~, CAB 0.25 .~ 56.25 .,-~' BDD Office conference 0.25 -~" 41.25 ~...~- CAB Call Wallen; call client; review cases/research 1.50 ~ 247.50 .~ CAB Review H's Answers to rog go & reg for docs; review mail Review and revise letter; review Roggs request 1.50 ,,~-247.50 .~z CAB 0.50 _~ 95.00 ~ LAS Research concerning defenses to claim of adandonment or desertion Call attorney 3.00,,,~ 225.00 _~ SGLC 0.25 ~- 47.50 ~ LAS Review letter 0.25 .,.- 47.50 ~ LAS Review fax/mail; review Reg for Docs; letter to client Call J King; review fax 1.00 ~ 165.00 ~- CAB 0.50 ~.~ 82.50 ~ CAB Meeting with client 0.75 ,~- 123.75 ,,~ CAB Review mail/attachments; calculate support 1.25 ~ 206.25 ~ CAB Review mail 0.25 '==r 41.25 ~, CAB Review email (3x) Letter to client Office conference Office conference Meeting with client Office conference 0.50 ~'~:~' 82.50 --~-~' CAB 0.25 ~-'~ 41.25 -~= CAB 0.25 ~ 56.25 ' .BDD 0.25 ~ 47.50 ,.- LAS Prep exhibits for DRO; review abandomnent cases Attend DRO conf; review fax; letter to J. King; 1.00 ~"' 165.00 '~- CAB 3.00 ~ 495.00 CAB Letter to D. Frank 0.50 ~.: 82.50 --,,.- CAB review order; review email (3x); email client 0.75 123.75 ~ CAB Invoice #: 3743 Page 3 April 23. 2003 Apr-04-03 Apr-07-03 Apr-08-03 Apr-09-03 Apr-Il-03 Apr-16-03 Apr-17-03 Apr-21-03 Call client; review emall; email client Review email call client (2x); review emails; emaJl client; review/revise answers to Roggs and reg for docs Office conference Office conference Revise answer to reg for docs Prior divorce - call M Walker Review/review interrogatories; letters to prothonotary and King Review mall Review email Review emails; letter to King Totals DISBURSEMENTS Feb- 11-03 Retainers Carried Forward Apr-09-03 Client Paying Bill Retainer Apr-21-03 Retainer Facsimile Expense Long Distance State Street-Copies In-House Photocopies Postage Expense~ State Street Copies 0.50 ~-r 82.50 CAB 0.25 / 41.25 CAB 2.50---- 412.50 _..-- CAB 0.25 ~ 56.25 -----' BDD 0.25 ~-....- 41.25 _..___._,CAB 0.50 ~ 82.50 ~,~-- CAB 0.50 ----- 82.50 CAB 0.50- 82.50 --~-- CAB 0.25_,_.~ 41.25~-~--- CAB 0.25 ~ 41.~~'~ CAB 0.75 ~ 123.75 -~- CAB 38.~.0~ $5,468.75 Disbursements Receipts rf 53.2 ') 3.00 5.00 16.54 33.60 20.93 1,500.0~ 1,000.00 ~ 17.39 ' ~Invoice #: 3743 Page 4 April 23. 2003 Telephone Expense Travel medical records Totals Total Fees, Disbursements Total Retainer Available Retainer Balance Previous Balance Previous Payments 15.00 18.00 34.17 $163.~' ' $5,692.77 $5,632.38 $0.00 $0.00 Balance Due Now $0.00 Lisa Diaz 31 Nelson Drive Carlisle, PA 17013 MEYERS, DESFOR, SAL TZGIVER & BOYLE 410 NORTH SECOND STREET P.O. BOX 1062 HARRISBURG, PA 17108 717~236-9428 Fax: 717-236-2817 Jun 03, 2003 File #: 3050 Inv #: 3840 Attention: DATE Apr-23 -03 May-02-03 May-05-03 May-06-03 May-07-03 May-08-03 May-09-03 May-12-03 May-13-03 May-14-03 DESCRIPTION Revise letter to King; TC with client (2x) Review custody evaluation; review email (3x) Review mail/report; TC with client TC with client Office conference Office conference Review fax/mail Review custody evaluation; conference with CAB Review mail; prepare for meeting with client; review emails; conference with BDD Meeting with client; review mail; letter to J. King TC with client; review documents Letter to J. King Review fax HOURS AMOUNT ATTY 0.50 ~ 82.50 CAB 2.00 .-- 350.00 .--- CAB %~'"~ 0.50 ' ~ 87.50 CAB 0.25 ~ 43.75 ---- CAB 0.50 ~ 112.50 _.-.- BDD 0.50 ~ 87.50 ,.._ CAB 0.25 ~ 43.75 ~-- CAB 1.00 ----- 225.00 ~ BDD 1.25 ~ 218.75 --. CAB 1.25 ---- 218.75 --' CAB 0.25 --"' 43.75 ~ CAB 0.50 ___ 87.50 ~ CAB 0.25 ---- 43.75 ~ CAB Invoice #: 3840 Page 2 June 3. 2003 May-15-03 May-20-03 May-21-03 May-22-03 Jun-03 -03 Review mail; revise letter re: custody schedule Office conference Office conference TC with Sunday's office TC with J. King; review emails (3x); email to client (3x); review fax Review mail payment for prior divorce Totals DISBURSEMENTS Apr-23-03 Retainers Carded Forward Apr-29-03 Retainer Facsimile Expense Long Distance State Street Copies In-House Photocopies Postage Expense Totals Total Fees, Disbursements Total Retainer Available Retainer Balance 0.50 - 87.50 0.25 ---'- 56.25 0.25 ~ 43.75 0.25 ,~-~- 43.75 ~- 1.25 ~ 218.75 ~ 0.25 ~' 43.75 ~- 11.75 $2,280.71 ~ Disbursements Receipts CAB BDD CAB CAB CAB CAB CAB 3,500.00 34.50 5.00 5.09 16.80 8.47 $69.86 ~ $3,560.39 $2,350.57 $3,560.39 $1,209.82 Previous Balance Previous Payments Balance Due Now $0.00 $0,00 $0.00 Lisa Diaz 31 Nelson Drive Carlisle, PA 17013 MEYERS, DESFOR, SAL TZGIVI~TR & BOYLE 410 NORTH SECOND STREET P.O. BOX 1062 HARRISBURG, PA 17108 717-236-9428 Fax: 717-236-2817 Jul01,2003 File #: 3050 Inv #: 3891 Attention: DATE Jun-02-03 Jun-04-03 Jun-06-03 Jun-11-03 Jun- 12-03 Jun- 16-03 Jun- 18-03 Jun- 19-03 Jun-20-03 Jun-23-03 Jun-24-03 Jun-26-03 Jun-27-03 DESCRIPTION Review mail (2x); TC with J. King. Review mortgage assumption documents; letter to client; reeview email Review mail; letter to J. King Review emails (3x); prepare for meeting; meeting with client Review documents from Husband; letters to King (2); draft ansewr Review fax/mail; TC with J. King; TC with client Review fax Review mail Draft custody order; review email; email client; revise letter re: discovery Review fax; letter to client Review mail; revise custody agreement Review email; TC with King; email client; letter to King TC with client; letter tO J. King HOURS AMOUNT ATTY 0.75 --' 131.25 ~' CAB 0.75 '-'" 131.25 ~ CAB 0.50 87.50 ~ CAB 2.00 -----350.00 '~- CAB 2.50 ..,-- 437.50 ,.-- CAB 0.75 .131.25 ~ CAB 0.25 ~ 43.75 ~- CAB 0.25- 43.75 ..--- CAB 1.50 '"'-262.50 ~ CAB 0.50 ---' 87.50 _... CAB 0.75 .--. '131.25 '-" CAB 1.00 .... 175.00 ~-' CAB 0.75 -~'131.25 "-' CAB Invoice #: 3891 Page Totals DISBURSEMENTS Jun-03-03 Retainers Carried Forward Facsimile Expense Long Distance In-House Photocopies Postage Expense Telephone Expense Totals Total Fees, Disbursements Total Retainer Available Retainer Balance Previous Balance Previous Payments 2 July 1. 2003 12.25'-,~. $2,143.75 Disbursements 7.50 5.00 12.95 5.78 5.00 Receipts 1,209.82 $1,209.82 $0.00 $0.00 $0.o0 Balance Due Now $970.16 Lisa Diaz 31 Nelson Drive Carlisle, PA 17013 MEYERS, DESFOR, SAL TZGIVER & BOYLE 410 NORTH SECOND STREET P.O. BOX 1062 HARRISBURG, PA 17108 717-236-9428 ' Fax: 717-236-2817 Jul25,2003 File #: 3050 Inv #: 3933 Attention: DATE Jun-30-03 Jul-01-03 Jul-02-03 Jul-03-03 Jul-07-03 Jul-08-03 'Jul-09-03 Jul-10-03 Jul-11-03 Jul-14-03 Jul- 16-03 Jul-19-03 DESCRIPTION HOURS AMOUNT ATTY Review mail 0.25 ~ 43.75 -.-- CAB review fax/mail (2x); meeting with cliem 1.25 ~,..218.75 ~ CAB Review email; email client 0.25 " 43.75 .-- CAB Office conference 0.25 ~-' 47.50 ----- LAS letter to King; revise custody agreement; TC 1.00 ~ 175.00 .--' CAB with client Review fax (2x); TC with King (2x);TC with 1.75 ~ 306.25 ---- CAB client (3x) TC with client (3x); review mail/faxes (2x); 3.00 .~_ 525.00 CAB TC with King (4x); revise custody agreement; letter to King; meeting with client Draft petition for APL; letter to Prothonotary; review email; TC with client TC with J. King Review orders; letter to J. King and client Review order; review letter and information Review letter Review statements; review mail (2x); review order 1.25 ...-- 218.75 '~ CAB 0.25 ~ 43.75 ---'- CAB 0.50 ,--.- 87.50 ,..- CAB 0.50 ~ 95.00 ~ LAS 0.25 -'~ 47.50 '"'- LAS 0.75 - . 131.25 --- CAB Invoice #: 3933 Page Jul-21-03 Review email; TC with client Jul-22-03 Review email; letter to J. King Jul-25-03 payment of invoice for prior divorce action Totals DISBURSEMENTS Jul-10-03 Retainer Retainer payment from retainer Facsimile Expense State Street Copies In-House Photocopies Postage Expense Totals Total Fees, Disbursements Total Retainer Available Retainer Balance Previous Balance Previous Payments July 25.2003 0.75 , _131.25 CAB 0.75 .----~31.25 'i.00 187.17 13.75 $2,428.42 Disbursements 24.00 CAB CAB ~ceip ts~. 3,500.00 "~_-970.~ _~16 1.28 53.20 13.47 91.9 $2,529.84 $2,520.37 $2,529.84 $9.47 $970.16 $970.I6 Balance Due Now $0.00 Lisa Diaz 31 Nelson Drive Carlisle, PA 17013 Attention: RE: DATE Jul-29-03 Jul-30-03 Jul-31-03 Aug-04-03 Aug-05-03 Aug-06-03 Aug-07-03 Aug- 11-03 Aug-12-03 Aug-14-03 MEYERS, DESFOR, SAL TZGIVER & BOYLE 410 NORTH SECOND STREET P.O. BOX 1062 HARRISBURG, PA 17108 717-236-9428 Fax: 717-236-2817 Aug 15, 2003 File #: 3050 Inv #: 3994 DESCRIPTION Review email; TC with client; letter to King Review email; email client Review order Review order; review fax; TC with client; letter to agent Review mail Review email Review email Office conference Office conference Review mail Review email (2x) HOURS AMOUNT ATTY 1.00 175.00 --" CAB 0.25 43.75 ~ CAB 0.25 47.50 ~ LAS 1.25 "218.75 '-'- CAB 0.25 ~ 4~.75 ~- CAB 0.25 ---- 43.75 ~-- CAB 0.25 -- ' 43.75 '"'" CAB 0.25 ~ 56.25 '"-' BDD 0.25 .... 43.75 -"" CAB 0.25 ..... 43.75 ~ CAB 0.25 ~ 43.75 ~ CAB Totals DISBURSEMENTS 4.50 $803.75 Disbursements Receipts Invoice #: 3994 Jui-25-03 Aug-07-03 Aug-15-03 Page Retainers Carried Forward Retainer Retainer Long Distance State Street Copies In-House Photocopies Postage Expense Totals Total Fees, Disbursements Total Retainer Available Retainer Balance Previous Balance Previous Payments August 15.2003 5.00 2.97 4.55 4.11 $16.63 $1,009.47 $820.38 8 $0.00 $0.00 Balance Due Now $0.00 Lisa Diaz 31 Nelson Drive Carlisle, PA 17013 MEYERS, DESFOR, SAL TZGIVER & BOYLE 410 NORTH SECOND STPEEET P.O. BOX 1062 HARRISBURG, PA 17108 717-236-9428 Fax: 717-236-2817 File #: Inv #: Attention: DATE Aug-15-03 Aug-21-03 Aug-25-03 Aug-26-03 Aug-27-03 Aug-28-03 Sep-02-03 DESCRIPTION HOURS AMOUNT office conference 0.25 47.50 Review email; TC with client; letter to King; 1.00 175.00 conference with LAS Review email 0.25 43.75 Office conference 0.25 47.50 Review order; TC With client; f'malize order; 1.00 190.00 conference with attorney review order 0.25 0.00 TC with King (2x); revise I&E; prepare 1.75 306.25 exhibits; prepare for conference; TC with client (2x) Office conference 0.50 112.50 Attend support conference 2.50 437.50 Office conference 0.50 87.50 Review case; letter to Shadday 0.50 87.50 Review fax (2x) 0.75 131.25 Review mail (2x) 0.25 43.75 Sep05,2003 3050 4014 ATTY LAS CAB CAB LAS LAS CAB CAB BDD CAB CAB CAB CAB CAB Invoice #: 4014 Sep-03-03 Review email Page Totals DISBURSEMENTS Aug-15-03 Aug-20-03 Aug-29-03 Retainers Carried Forward Retainer Retainer Client Paying Bill Facsimile Expense Long Distance State Street Copies In-House Photocopies Postage Expense Travel Totals Total Fees, Disbursements Total Retainer Available Retainer Balance Previous Balance Previous Payments 2 September 5. 2003 0.25 43.75 CAB 10.00 $1,753.75 Disbursements 774.23 -- 10.50 5.00 6.79 6.65 7.39 9.00 Receipts I89.09-/ 900.0~ 1,000.00 $819.56 $2,089.09 $2,573.31 $2,089.09 $0.00 $0.00 $0.00 Balance Due Now $484.22 Lisa Diaz 31 Nelson Drive Carlisle, PA 17013 Attention: RE: DATE Sep-08-03 Sep- 10-03 Sep-11-03 Sep-12-03 Sep- 15-03 Sep-24-03 Sep-26-03 Sep-29-03 Oct-01-03 MEYERS, DESFOR, SAL TZGIVER & BOYLE 410 NORTH SECOND STREET P.O. BOX 1062 HARRISBURG, PA 17108 717-236-9428 Fax: 717-236-2817 Oct03,2003 File #: 3050 Inv #: 4064 DESCRIPTION HOURS AMOUNT ATTY TC with client; letter to King 0.50 87.50 CAB TC with King; TC with client; TC with Plank 0.75 131.25 CAB Review fax; draft I&A 1.25 218.75 CAB Review email 0.25 43.75 CAB TC with Plank; revise I&A 0.50 87.50 CAB Review mail 0.25 43.75 CAB TC with client (2x); TC with Shadday (DRO); 1.75 306.25 CAB draft request for de novo hearing (2x); review rules Review order/calculations 0.75 131.25 CAB Office conference 0.25 56.25 BDD Office conference 0.25 43.75 CAB Totals DISBURSEMENTS 6.50 $1,150.00 Disbursements Receipts Invoice #: 4064 Page 2 October 3. 2003 Facsimile Expense State Street Copies In-House Photocopies Postage Expense Telephone Expense Travel Totals Total Fees, Disbursements Total Retainer Available Retainer Balance Previous Balance Previous Payments 1.50 3.82 11.90 4.71 5.00 21.60 $48.53 $0.00 $1,198.53 $0.00 $0.00 $484.22 $0.00 Balance Due Now $1,682.75 Lisa Diaz 31 Nelson Drive Carlisle, PA 17013 Attention: RE: DATE Oct- 10-03 Oct- 15-03 Oct-16-03 Oct-24-03 Nov-03 -03 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET P.O. BOX 1062 HARRISBURG, PA 171011 717-236-9428 Fax: 717-236-2817 File #: Inv #: DESCRIPTION HOURS AMOUNT Review mail 0.25 43.75 TC with King 0.25 43.75 Review mail; letter to Andrews 0.50 0.00 Review praecipe 0.25 0.00 Review mail; letters to client and T. Andrews 0.50 0.00 Nov 04,2003 3050 4119 ATTY CAB CAB CAB CAB CAB Totals DISBURSEMENTS In-House Photocopies 1.75 $87.50 Disbursements 8.75 Receipts Totals $8.75 $0.00 · Invoice #: 4119 Page 2 November 4. 2003 Total Fees, Disbursements Total Retainer Available Retainer Balance $96.25 $0.00 $0.00 Previous Balance Previous Payments $1,682.75 $1,682.75 Balance Due Now $96.25 J* EIdANUEL MEYERS BRUCE D. DESF'OR LAURIE ^. SALTZGJVER LAW OFFICES MEYERS, DESFOR, SALTZGIVEr & BOYLE 4[o NORTH SECOND STREET P.O. BOX IO62 HARRISBURG, PA. 17108 (717) ~36-94~8 October 3, 2003 cbo'/le~rneyersdesfor, com Lisa G. Diaz 504 Highland Court Carlisle, PA 17013 RE: Lisa G. Diaz v. Rodriqo J. Diaz PACSES NO. 849105165 PACSES NO. 830105650 Dear Ms. Diaz: Enclosed herewith please find your current billing statements. The prior divorce action i~ c:urr~ntlv o~inq $%~.00. This must be ~aid in fuji. Your curre~ c[lvor~ ~ion is owin~ Please remit an a~t~onal retainer in t~e amoung or Thank you for your prompt attention to this matter. Very truly yours, Cbt±st±ha 5. Ko±m Accounting Department clk Enclosure Andrews & Johnson 78 West Pomfret Street Carlisle, PA 17013 23-2478086 Statement Date 11/4/2003 To: Lisa G. Diaz 504 Highland Court Carlisle, PA 17013 Amount Due Amount Enc. $-58.88 Date Transaction Amount Balance 09~30~2003 Balance forward I 0.00 10/13/2003 letter to client, letter to Atty. Boyle, letter to Atty King 90.00~ 90.00 10/14/2003 [ Review of documents, lette from Atty King, letter to 225.00 315.00 client, phone call with realtor 10/15/2003 Phone call from Atty King 45.00 360.00 10/16/2003 RETAINER RECEIVED -2,000.00 -1,640.00 10/16/2003 Letter from client; letter to Atty. Fried 105.00 -1,535.00 10/17/2003 Phone call with Atty King; phone call to Ibis Appraisal, 60.00 -1,475.00 phone call to client 10/20/2003 ! phone cail with Arty King, fax to Atty King re: Lisa's 120.00 -1,355.00 retirement 10/23/2003 Letter from Atty King, letter to DRO 60.00 -1,295.00 10/23/2003 Review of discovery documents, preparation of marital 675.00 -620.00 inventory spreadsheet, calculate coverture fraction of SERS, office conference with client 10/24/2003 Email from and to client 75.00 -545.00 10/27/2003 Review of appraisal, update spreadsheet, letter to Arty 150.00 -395.00 King, email to client re: signing of Deed 10/28/2003 Ibis Appraisal Service 135.00 -260.00 10/29/2003 Letter to Atty Boyle 60.00 -200.00 10/29/2003 Overnight mailing fee - original deed to settlement agent 6.12 -193.88 10/30/2003 Email from and to client; fax from Settlement Services 135.00 -58.88 and fax from Arty King, phone call to Atty King, fax to settlement agent CURRENT I 1-30 DaYS PAST 31-60 DAYS PAST 61-90 DDAuYES PAST OVER 90 DAYSI~ Amount Due DUE DUE --I PAST DUE -58.88 0.00 0.00 0.00 I 0.00 $-58.88 I Andrews & Johnson 78 West Pomfret Street Carlisle, PA 17013 23-2478086 Statement Date 12/I/2003 To: Lisa G. Diaz 504 Highland Court Carlisle, PA 17013 Amount Due Amount Eno, $391.12 Date Transaction Amount Balance 11/01/2003 Balance forward -58.88 11/03/2003 Phone calls to Pension Appraisers and PA SERS, email 120.00 61.12 to client 11/05/2003 Email from and to client; email to Atty King 75.00 136.12 11/05/2003 Additional email from client, revisions to spreadsheet, 150.00 286.12 letter to Atty. King 11/17/2003 Email fi'om and to client 60.00 346.12 11/17/2003 Additional email from client; email to Arty King 45.00 391.12 CURRENT I 1-30 DAYS PAST 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS / DUE DUE DUE PAST DUE Amount Due 391.12 0.00 0,00 0.00 0.00/ $39].12 I Andrews & Johnson 78 West Pomfret Street Carlisle, PA 17013 23-2478086 Statement Date 1/2/2004 To: Lisa G. Diaz 504 Highland Court Carlisle, PA 17013 Amount Due Amount Eno. $495.00 Date Transaction Amount Balance 12/02/2003 Balance forward 391.12 12/05/2003 Letter from Arty King, emall from client, letter to Atty 150.00 541.12 King, letter to client 12/08/2003 Letter from Atty King, fax from client, email from client 150.00 691.12 2 emails to client 12/12/2003 PMT -391.12 300.00 12/18/2003 Letter to Atty King, letter to Atty Boyle, email to client, 195.00 495.00 email re: Snelson records, preparation of Release, letter to client CURRENT 1-30 DAYS PAST 31-60 DAYS PAST 6%90 DAYS PAST OVER 90 DAYS DUE DUE DUE PAST DUE Amount Due 495.00 0.00 0.00 0.00 0.00 $495.00 Andrews & Johnson 78 West Pomfret Street Carlisle, PA 17013 23-2478086 Invoice Date Invoice # 2/3/2004 313 Bill To Lisa O. Diaz 504 Highland Court Carlisle, PA 17013 Description Amount 12/29/03 Review of material from client, e-mail to client, letter to Deborah Snelson 1/9/04 1/13/04 1/14/04 1/16/04 1/19/04 Letter from Atty King - analysis, letter to Atty King Revision to letter to Arty King Phone call from Arty King Letter from Atty King, e-mail to Arty King Office conference with client 90.00 225.00 60.00 60.00 60.00 105.00 Total $600.00 Bill To Andrews & Johnson 78 West Pomfret Street Carlisle, PA 17013 23-2478086 i Lisa G. Diaz 504 Highland Court :Carlisle, PA 17013 Invoice Date Invoice # 3/1/2004 323 Description Amount )date spreadsheets and analysis 300.00 flee conference with client, work on spreadsheets; letter to Atty. King; 375.00 Atty. King ,,mails from client, review sale policy; revise spreadsheets, revise letter to 120.00 tg nail from Atty King; e-mail to client; legal research re: exclusion of gain 225.00 talysis of proposal from Atty. King; e-mail to client; brief office 225.00 :e vdth client ~ter to Atty. King 195.00 one conference with and e-mail from Atty. King; analysis of proposal, 150.00 client Total $1,590.00 I2/13 2/16 e-mail to 2/18 Atty. Kinl 2/19 2/20 Anal, confi ;ence 2/23 Lette 2/27 Phor e-mail to cl Andrews & Johnson 78 West Pomfret Street Carlisle, PA 17013 23-2478086 Invoice Date Invoice # 4/1/2004 343 Bill To Lisa G. Diaz 504 Highland Court Carlisle, PA 17013 Description Amount 3/1/04 2 emails from and to client; email to Atty. King 120.00 3/3/04 email from Arty King and emalls to client 225.00 3/11/04 letter and email from Atty. King; review of Inventou; letter to client; 240.00 review of interrogatories and request for production of documents answers and letter to client 3/15/04 emall from and to client 90.00 3/18/04 review of records; compilation of attorney fees; email to client 120.00 3/25/04 phone call returned to Arty King 30.00 3/29/04 review of billing record from prior atty, emall to client 60.00 Total $885.00 I Andrews & Johnson 78 West Pomfret Street Carlisle, PA 17013 23-2478086 Invoice Date J Invoice 5/3/2004 349 Bill To Lisa G. Diaz 504 Highland Court Carlisle, PA 17013 Description Amount 4/9/04 preparation of inventory, emails to client; review records to update 405.00 interrogatories, email and letter to Atty. King 4/15/04 review of inventory and sheets totaling debt and fees; letter to Atty. King; 150.00 email to client, filed inventory 4/26/04 review of custody material 150.00 4/27/04 additional review of custody material and office conference with client 750.00 Total $1,455.00 Andrews & Johnson 78 West Pomfret Street Carlisle, PA 17013 23-2478086 Statement Date 6/1/2004 To: Lisa G. Diaz 504 Highland Court Carlisle, PA 17013 Amount Due Amount Enc. $770.00 Date Transaction Amount Barance 05/01/2004 Balance forward 0.00 05/03/2004 1NV#349 1,455.00 1,455.00 05/04/2004 Letter from Atty King; letter to Atty King 105.00 1,560.00 05/20/2004 Letter from Atty King; letter to client 45.00 1,605.00 05/24/2004 email from client; review of correspondence; email 105.00 1,710.00 exchange with client; research Christmas and New Years 05/27/2004 cma/1 to Atty King re: holiday vistitation 60.00 1,770.00 06/01/2004 PMT -1,000.00 770.00 CURRENT %30 DAYS PAST 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS -- DUE DUE DUE PAST DUE Amount Due 315.00 455.00 0.00 0.00 0.00 $770.00 Andrews & Johnson 78 West Pomfret Street Carlisle, PA 17013 23-2478086 Invoice Date Invoice 7/1/2004 372 Bill To Lisa G. Diaz 504 Highland Court Carlisle, PA 17013 Description Amount 6/7/04 Multiple emails; letter to Divorce Master 105.00 Total $1os.0o Hortsbur~, PA1110L7013 (BO0) 237-7328 O~atbn~de} we6slfe - http://www, psecu.¢om PAGE I I,,,lll,,,I..hl.ll,,ll,,Id.h.ll,,,I,,Ihl.l.,ll.h,II LISA g OIAZ 9563 BLUE SPRING RD MERCERSOURG PA 1725&-977-~ 3090~0~60Z076 ' ]~ ~ VI~A LOAN ' POST ~AN REFERENCE ~SCRZPT~ON AMOUNT 0~17 ~SH ADVANCE TRANSFER TO SHARE 04 5qo0.O0 YT~ FINALE CHAR~: YEAR TO OATE O. O0 0,82500~ O,OO 1,07500~ 2S.I& .~.~ 16087 (11/93) Jeet zge using the key. ..~qj~.,..:., mage ,~ Bin · ,,J~ ~ ~4~ 90t 17~ '~S~- HOLD [ ~G PANEL CUSTO~EF~' r oALE ~DI, I 50,f~T- I J B3 ~U~TOT~L I029.'~ TAX Of Z~3~ N EXHIBIT '*!UMBER DESCRIPT!OI'~ OF TRANSACT[OiX :A'FMENE/DE,3F( DESCRIPTION OF TRANSACTION ! ~[ D6SCRIPTIOi'J OF ~'RANSACT;C['I NUMBER DESCRIPTION OF TPC~h!SAGTION GROSS EARNINGS 1,670.25 33,333.00 PAY PERIOD ENDING: 09-12-03 PAY DATE: 09-26-03 MINUS DEDUCTZONS VT#: 391800370000 DEFT: 018 CDC: 10310 FED NTH TX M 01 143.29 3,019.96 SOC SEC TX 6.20000% 103.56 2,066.72 EMP#: 449034 POS#: 120977 SEN: 205-60-2076 SOC SEC/flED TX 1.z~5000% 2~*.22 483.36 B/U: A4 PAY RANGE: 08 STEP: 2 LEVEL: O0 STATE NTH TX PA 2.80000% 46.77 933.38 REVENUE BOARD OF APPEALS LOC NG TX-RES PA 21 001 1.60000% 26.72 533.26 UNEMP COHP TX .02000% .33 6.60 RET P/U CON STATE EMP 6.25000% 10A.39 2,083.30 UN DUES AFSCME - 13 2458 25.05 A99.92 LISA G D'rAZ 504 HIGHLAND COURT CARLISLE PA 17013 NET EARRINGS: 1,195.92 HEALTH BENEFITS #0 COVERAGE 235.00 ANN MED HOSP RET EMP HLTH PROG (REHP) 160.00 LXFE XNSURANCE 4.60 HORKERS COMP 25.0~ SOCIAL SECURITY 103.56 MEDICARE 24.22 RETIREMENT STATE EHPLOYES RET SYS 8.35 TOTAL STATE PAID BENEFITS $ 560.78 ........... ::T ;:::::r:::;:::::; ............................................................ ¥i:i:~:r:i:i::::::i~::i::::~iiiii~:ii:::rii:ii;;ii:;?:r;*;:::..:~::::¥:;: ::: :: ::: ............................... :::::::::::.::::: :::: ...... SERVICE CREDIT: 8 YR 23 PP 09-12-03 ANNUAL 3.00 0~-12-0~ REG RAL 75.00 22.27 I~B70.25 0~-12-03 SICK .50 0ALANCE LAST STATEHENT ~'.86 90.82 .00 GENERAL RONSUPV 2,284 CREDIT DAYS ACCRUAL THIS PP 4.33 3.75 .00 LV REPORTED THIS PP 3.00 .50 .00 EMP MILITARY DAYS 0 CREDIT DAYS ADJUSTMENTS .00 .00 .00 CREDIT DATE 09-12-03 BALANCE THIS STHT 6.19 94.07 .00 ........................ ~:::::~::: ~:~, ~: ~:: ::~i ~ .......................... MESSAGE CENTER: LOCAL HAGE TAX COUNTY/HUNICIPALITY: CUMBERLAND COUNTY CARLISLE BORO FNT TAX GROSS: 1~565.86 GREETINGS TO ALL COMMONWEALTH EMPLOYEES: I ask all of you to join in the Amedcan Cancer Society's "Making Strides Walk Against Breast Cancer" on October 4,. 2003 at 10 AM. This event is a five-mile non-competitive walk starting on Harrisburg City Island. It is designed to raise awarenes,% foster camaraderie and raise funds for breast cancer research, servi~s, patient education and advocacy. It takes determination, passion and conviction of people like you to truly make a difference in the battle against this devastating disease. In the past six years, 30 participating teams from various state agencies have raised over $100,000. Your involvement in this worthwhile endeavor symbolizes support and encouragement for the many survivors, commemorate contributes to finding a cure for breast cancer. Thank you for your continual efforts and g, EXHIBIT ~s baffle and fight to protect women's health, preserve families and save lives. For more inf American Cancer Society at 1-800-ACS-2345.~ //' EDWARD G. RENDELL, GOVERNOR OF PENNSYLVANIA In the Court of Common Pleas of Phone: (717) 240-6225 DOMESTIC RELATIONS SECTION 13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013 JULY 11~ 2003 Plaintiff Name: z, zsa G. DZaZ Defendant Name: RODRIGO J. DIAZ Docket Nttrnber: 0o025 s ~:003 PACSES Case Number: 849105165, Other State ID Number: Please note: All correspondence must include the PACSES Case Number. County, Pennsylvania Fax: (71.7) 240-6248 Income and Expense Statement THIS FORM MUST BE FILLED OUT (If you are self-employed or if you are salaried by a business of which you: are owner in whole or part, you must also fill out the Supplemental Income Statement which appears on page two of this income and expense . statement.) Section I: Income and Insurance INCOME: Employe~ Address Type of Work Payroll No. Gross Pay per Pay period $ i: g ~ fi. '~ ~ Pay Period (wkly., bi-wkly., etc.) Itemized Payroll Deductions: Federal Withholding Other Deductions (specify) Social Security $ I ty ~. '1 ~ Local Wage Tax Retirement $ I a q, %~1 Savings ~nds Li~ ~mnce [ $ l H~ ~nce $ $ $ $ Net Pay per Pay Period OTItER INCOME Dividends Annui9, Social Security Royalties Expense Account Gifts Unemployment Workmen's Compensation Other Other TOTAL TOTAL INCOME (Fill iu Appropriate Column) WEEK MONT~ YEAR $ $ $ Service Type M PROPERTY OWNED Checking Accounts Savings Accounts Credit Union Stocks/Bonds Real }Estate Other DESCKIPTION VALUE TOT~ ~ $ * H==Husband; W=Wife; J =Joint Ownership * Form IN-008 Worker ED 21208 Income and Expense Statement Section III: Expenses PACSES CaseNumber 849205165 Instructions: Only show extraordinary expenses ih tiffs section unless you filled out Section II on page two. The categories in BOLD FONT are especially important for calculating child support. If you are requesting Spousal SuppordAPL or if you assert your case cannot be determined according to the guideline grids or formula, this section must be fully completed. EXPENSES Home Mortgage/Rent U¢iities Electric Gas Telephone Employment Public Transport. Lunch Taxes Real estate $ Personal Property (Fill in Appropriate Column) WEEK MONTH YEAR Automobile Life Accidem - Health .... Other Automobile Fuel Repairs Medical Doctor ¢, o ':d O . I)en~t Orthodontist ~ - Hospital .. Special needs (glasses, braces, (Fill in Appropriate Column) EXPENSES (continued) WEEK MONTIt YEAR Education -- ' Private School $ $ $ - Parochial School ~ '" College Religious . Personal Cloth/ag $ Food ~, Barber/ Hairdresser Credit Payments Credit Card Charge ...... Memberships ' ' Loans ....... Credit Union $ $ $ Miscellaneous Household Help $ Child care Papers/books ....... Magazines Entertaimnent Pay'IV Vacation ....... Legal fees )~ ~5'7, ')~. 6 ', %-?, '.r".'~'.'~. Charitable ..a--- .~. Contributions r~-~, ~ 5 0_.~ c3~ ) 5 ~ D , Other Child Sunnort Alimony laments I' $ $ Total WEEK MONTH I verify that the statements made in this Income and Expense Statement are true and correct. I understand that false statements herein are subject to die criminal penalties of 18 Pa. C.S. § 4904, relating to s~_~rn falsification to authorities. ,--lffaintiff'~ r De fendant ~ 'h '~o~-008 Service Type M Worker ID 21208 LISA G. DIAZ, RODRIGO J. DIAZ, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 000-25-S-2003 PACSES Case No. - 849105165 IN SUPPORT STIPULATION AND AGREEMENT FOR ENTRY OF A SUPPORT ORDER AND NOW come the parties in the above-captioned matter, Lisa G. Diaz, Obligee, and Rodrigo J. Diaz, Obligor, who do stipulate to the.. following support obligation and who do agree to an entry of an Order of support containing those terms: 1. A child support order will be entered effective July 18, 2003 in the amount of $610.00 per month through October 31, 2003; Rodrigo J. Diaz, Obligor. 2. An order for the payment of alimony pendente lite will be entered effective August 25, 2003 in the amount of $74.00 per month through October 31, 2003; Rodrigo J. Diaz, Obligor. 3. An order will be entered effective November 1, 2003 for the payment of child support in the amount of $732.00 per month, and the payment of alimony pendente lite in the amount of $147.00 per month; Rodrigo J. Diaz, Obligor. EXHIBIT The parties, having reviewed the above with their respective legal counsel, John F. King, Esquire for Obligor, and Taylor P. Andrews, Esquire for Obligee, do hereby agree to the entrg.o.~,.~ Order for support containing the above stipulated-to terms. R~drigo J.'Diaz/ Date: [[/3 /0 ~ rfp:domestic\diaz, stp LISA G. DIAZ, RODRIGO J. DIAZ Defendant Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-5524 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that on this date, July 12, 2004 I mailed a copy of Plaintiff's Pretrial Statement as per Pa. R.C.P. (1920.33(b)) to the following person at the following address by U.S. Mail, postage prepaid and addressed to: John F. King, Esq. 600 North Second St. P.O. Box 984 Harrisburg, PA 17108 I verify that the statements made in the foregoing Certificate of Service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworu falsification to authorities. Carlisle, PA 17013 (717) 243-0123 10/04/2004 1 :21 #1B3 P.005/005 LISA G. DIAZ, Plaimiff RODKIGO J. DIAZ, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ' 5524 CIVIL 'NO 02- i CIVIL ACTION - LAW ; IN DIVORCE A~FFID~AVIT OF CONSENT- 1, A Complaim in Divorce u~der Section 3301(c) of thc Divorce Code was filed on November 14, 2002. 2. The marriage of Plaimiff and Defendant is irretrievably broken and ninety (90) days have elapsed f~om the dat~ of filing the Complaint, 3. I consent to the entry of a final decree of divorce after service of Notice of Intention to Request Entry of thc 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: 10/0zl/2004 12:21 #133 P.004/005 LISA 0. DIAZ, Plaintiff RODPdGO I. DIAZ, Defendant IN THE coURT OF COMMON PLEAS CUMBERLAND COUNTY, pENNSYLVANIA NO. 02-5~24 CIVIL CP~/IL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF II~ENTION TO REQUEST ENTRY OF A DE l, I consent to the entry of a final Decree of Divorce without notice. at I ma lose rights concerniag alimony, division of property, 2, I unders..tand, th )~ c a Divoltcc is granted. lawyer's fi:cs or cxp~nses Ill do not claun thembcfot 3, I understand that I will not be divorced until a Divorce Dccrcc is cnt~rcd by the Court, and that a copy of the Decree will be sent to me in, mediately after it is filed with thc 4, I verily mar m.,. , _.ao sublect to mc penaiu~ .... · · ' iel~tlng to unsworn falsificat~ol~ ~o auu~,~ Date: - 'II~-~ ?D. iifz, Defendant 10/04/2004 12:21 #132 P.002/005 LISA 0. DIAZ, Plaintiff RODRIGO ;I. DIAZ, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5524 CIVIL, GI~IL ACTION - [,AW : IN DIVORCE ~__FFIDAVIT OF cONSENT 1. A Complaint in Divorce under Section 3301(c)of the Divorce Code was filed on November 14, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and nines/ (90) days have :lapsed from thc date of filing the Complaint, 3, I consent to the entry of a final decree of divorce after sc/vice of Notice of Intention to Request Entry of the Decree. I velifY that the statements made in this Affidavit arc true and correct. 1 understand that false statementS herein are made subject to tile penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. DATED: Lisa ~ro~: 10/04/200~ 12:21 #133 P.002/005 LISA O. DIAZ, Plaintiff RODRIOO J. DIAZ, Defeudimt IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5524 CIVIL CIVIL ACTION - LAW : IN DIVORCE RCE DEC~E ~ER 1. I consen~ to ~e en~ of a final De;tee of Divor~ wi~ou~ notice. _ _ ~ ,~o~ I may lose ri~ts conce~; al~ony, division of pro. W, 2, I ~~+ -~a~ ~em~efore a Divoroe ~s grated lawyer's 3. I und;rs~nd ~t I wfli not be divorced ~ltl a Divorce Decree is eu~red by ~ Co~, ~d ~t a copy of ~ De~r~ w~l be sen~ to mu pro&ouo~, 4. I v;ri~ ~ ~e s~atements madu in ~is Affidavit are ~e a~d oD.eot, l uu~rst~d ~at false sm~ments here~ ~e made subject to relating to ~sworn fa~cation to au~orities. LISA G. DIAZ, Plaintiff vs. RODRIGO J. DIAZ, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 5524 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this ~ day of _ __ , 2004, the parties and counsel having entered into an agreement and stipulation resolving the economic issues on October 4, 2004, the date set for a pre-hearing conference, the agreement and stipulation having been transcribed, and subsequently signed by the parties and counsel, the appointment of the Master is vacated and counsel can conclude the proceedings by the filing of a praecipe to transmit the record with the affidavits of consent of the parties so that a final decree in divorce can be entered. BY THE COURT, CC: ~aylor P. Andrews Attorney for Plaintiff /ohn F. King Attorney for Defendant LISA G. DIAZ, Plaintiff VS. RODRIGO J. DIAZ, Defendant 2004. This IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 5524 CIVIL IN DIVORCE THE MASTER: Today is Monday, October 4, is the date set for a pre--hearing conference with counsel; however, both counsel had their clients appear so that we had a conference which included the parties. Present in the hearing room are the Plaintiff, Lisa G. Diaz, and her counsel Taylor P. Andrews, and the Defendant, Rodrigo J. Diaz, and his counsel John F. King. The parties were married on December 21, 1996. (The complaint the parties acknowledge was in error when it stated the date of marriage as December 31, 1996.) The parties were separated on November 14, 2002. They are the natural parents of one child who is four years of age and with whom the parties share custodial rights. The complaint in divorce was filed on November 14, 2002, raising grounds for' divorce of irretrievable breakdown of the marriage and indignities. Before the parties leave here today they are going to sign affidavits of consent and waivers of notice of intention to request entry of divorce decree so that the divorce can be concluded under Section 3301(c) of the Domestic Relations Code. The Master's office will file the affidavits and waivers with the Prothonotary office's. The complaint also raised economic claims of equitable distribution, alimony, alimony pendente lite, and counsel fees and expenses. The Master has been advised that after extensive negotiations this morning the parties have reached an agreement with respect to the outstanding economic issues. The agreement is going to be placed on the record in the presence of the parties. The agreement as placed on the record will be considered the substantive agreement of the parties not subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. The agreement as placed on the record will be considered the agreement when the parties leave the hearing room today. The Master's office will transcribe the agreement and send to counsel the draft; counsel and parties will make any corrections of typographical errors as required and then affix their signatures affirming the terms of settlement as stated on the record. When the Master receives a completed copy of the agreement, the Master will prepare an order vacating his appointment and counsel can then file a praecipe transmitting the record requesting that the Court enter a final decree in divorce. Mr. King. MR. KING: Thank you. After discussion with 2 counsel, the parties in this case hawa reached terms on distribution of the marital estate and have agreed to execute consents and waivers this afternoon. The terms of the agreement are as follows: 1. The Plaintiff, Lisa G. Diaz, wife is dropping her claim for alimony, alimony pendente lite, attorney fees and expenses. 2. The parties have agreed that the marital estate is valued at $172,160.00. The parties have also agreed that the marital estate will be divided 55% to wife and 45% percent to Defendant husband. Wife's 55% portion is valued at $94,688.00. In order to effectuate the division of the marital estate the parties have agreed that wife will receive $890.00 by way of tangible household personal property which wife has already received; $5,200.00 by way of deferred compensation from her employer; $403.00 in value for her vacation benefits accrued during the marriage; $1,164.00 from a savings account; $12.00 from a checking account; and $3,265.00 from a joint aocount held during the marriage. These items total in value $10,934.00. In addition to those distributions, wife will take $27,419.00 which is currently being held in escrow and constitutes the proceeds of the sale ,Df the marital residence. That distribution will take place within 15 days of today's date. In addition, wife will receive a value of $32,085.00 which is the value that has been agreed to between the parties to be placed upon her retirement accrued during the marriage. In addition, wife will receive from husband a cash payment within 15 days of today's date in the amount of Finally, there will be a QDRO giving over a portion of husband's retirement to wife valued at $21,719.00. That QDRO i~ to be prepared by wife through her counsel and will be executed by husband upon presentation for filing with the Court. Ail of these values add up to $94,688.00 which is the 55% division ~zhat has been agreed to between the parties. 3. Husband's portion of the marital estate which has been previously identified and agreed to is a 45% portion. That portion totals in value $77,472.00. In order to come up with that amount it has been agreed between the parties that husband will receive tangible household personalty in the amount of $2,945.00 and the personalty that husband receives and that wife has previously been identified as receiving has already taken place. There are no further actual division issues with personalty but rather these are amounts that have been agreed to by the parties as values of items that they have already taken. In addition, husband will retain a 1998 Ford Escort which the parties have agreed has a value of $2,600.00. In addition, husband will retain the balance of his retirement. The total value that was placed upon that for the purposes of this proceeding, was $58,002.00 so he will retain his retirement minus the $21,719.00 that is being removed by way of the QDRO in favor of wife. In addition, husband will retain the deferred compensation plan monies that were agreed to by the parties to value $22,021.00. In addition, husband will retain the cash pay-out of Family Care Assistance Program that the parties both enjoyed during the marriage which total amount was $4,375.00. In addition, husband will retain the accrued vacation benefits. Those benefits that were accrued during the marriage which value has been agreed to between the parties to be $7,394.00. Also, husband will retain $2,862.00 from a joint checking account; $1,500.00 from a joint savings account and $30.00 from a Patriot Credit Union joint account. These items that husband is retaining and the values that have been agreed to by the parties will total the $77,472.00 which is the 45% portion of the marital estate as valued and agreed between the parties today. 4. Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship including without limitation, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as achministrator or executor in the other's estate. Each will at the request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interest, rights, and claims. MR. ANDREWS: Just for clarification, at the outset you indicated the claims that 'would be withdrawn and you included in those claims alimony pendente lite. I would just suggest that the alimony pendente lite claim ends at the time of the entry of the divorce. MR. KING: That is fine. MR. ANDREWS: Mrs. Diaz, did you hear the terms of the agreement that were put .on the record by attorney King? MRS. DIAZ: Yes. MR. ANDREWS: And did you hear the preliminaries before that that were put on the record by Master Elicker? MRS. MR. have been put on the terms? MRS. MR. MRS. DIAZ: Yes, and I understood them. ANDREWS: Do you agree to the terms that record and agree to be bound by those DIAZ: Yes, I do. ANDREWS: Do you have any questions? DIAZ: No. 5 MR. KING: Mr. Diaz, did you as well hear the preliminary discussion and language that was placed on the record by Master Elicker and also the terms that I dictated here regarding the resolution of the distribution of this marital estate? MR. DIAZ: MR. KING: MR. DIAZ: MR. KING: those with me prior to coming MR. DIAZ: Yes, MR. KING: Are terms? regarding Yes, I did. Did you understand those? Yes, I did. Did you have any chance to discuss in here just now? I did. you in agreement with these MR. DIAZ: MR. KING: these terms? MR. DIAZ: Yes. Do you have any questions I have no questions at this time. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations Code. WITNESS DATE: Rodri~o J~ Diaz LISA G. DIAZ, Plaintiff VS. RODRIGO J. DIAZ, Defendant PRAECIPE TO TO THE PROTHONOTARY: : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO: 02-5524 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE TRANSMIT RECORD Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2 Date and manner of service of the complaint: accepted by Attorney John King on November 15, 2002 . the Date: November 14, 2002 and service 3. (a) Divorce Code: by the Plaintiff October 4, 2004 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in Prothonotary: Date Defendant's Waiver of Notice in Prothonotary: Date of execution of the affidavit of consent required by Section 3301 (c) of ; by Defendant October 4, 2004 Il .-' ( ~ O f ,2004 By: §3301(c) Divorce was filed with the §3301(c) Divorce was filed with the Ta~°,r/P' Andr78,West Pomfree~V~'~Ee;tq' Carlisle, PA 17013 (717) 243-0123 Supreme Court ID No. 15641 IN THE COURT OF COMMON PLEAS Lisa G. Diaz OF CUMBERLAND COUNTY STATE OF ,~~~ ,,. PENNA. Plaintiff NO. 02-5524 Rodrigo Je VERSUS Diaz Defendant DECREE IN DIVORCE AND NOW, DECREED THAT ~/~. Z- Lisa G. Diaz Rodrigo J. Diaz , ~ , It IS ORDERED AND , PLAINTIFF, AND , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE bEEN RAISED OF RECOrd IN ThIS ACTION for WhiCh A FINAL ORDER hAS NOT YET BEEN ENTERED; The parties Marital Settlement Agreement is incorporated herein but not merged with this Order. BYTHE .~URT: / PROTHONOTARY In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION LISA G. DIAZ ) Docket Number Plaintiff ) vs. ) PACSES Case Number RODRIGO J. DIAZ ) Defendant ) Other State ID Number 02-5524 CIVIL 830105650 ORDER AND NOW, to wit, on this 5TH DAY OF NOVEMBER, 2004 IT IS HEREBY ORDERED that the support order in this case be C) Vacated or C) Suspended or 1~) Terminated without prejudice or C) Terminated and Vacated, effective NOVEMBER 2, 2004 , due to: THE PARTIES' DECREE IN DIVORCE ON NOVEMBER 2, 2004. THERE IS A REMAINING BAI~ANCE OF $182.78 AND THAT SUM IS TO BE PAID IN FU~.r,L WITH THE CURRENT WAGE ATTACHMENT. Service Type M BY THE COURT: JUDGE Form OE-504 Worker ID 210 05 LISA G. DIAZ, Plaintiff VS. RODRIGO J. DIAZ, Defendant · 1N THE COURT OF COMMON PLEAS OF · CUMBERLAND COLrNTY, PENNSYLVANIA · NO: 02-5524 · IN DIVORCE STIPULATION AND AGREEMENT FOR ENTRY OF "DOMESTIC RELATIONS ORDER" AND NOW, this ~ day of December __, 2004, by the terms of this Stipulation and the parties Lisa G. Diaz, Plaintiff, and Rodrigo J. Diaz, Defendant, having been divorced by Decree dated November 2, 2004 of the Court of Common Pleas of Cumberland County, entered at the above referenced docket number, do hereby Stipulate and Agree as follows: 1. The Defendant, Rodrigo J. Diaz, hereinafter preferred to as "Member", is a member of the Commonwealth of Pennsylvania Employees' Retirement System, hereinafter referred to as "SERS". 2. SERS, as a creature of statue, is controlled by the State Employees' Retirement Code, 71 Pa. C.S. §§5101 - 5956 ("Retirement Code")· 3. Member's date of birth is February 19, 1965, and social security number is 168-60- 3538. 4. Member. 2076. 5. 6. 17013. The Plaintiff, hereinafter referred to as "Altemate Payee," is the former spouse of Alternate Payee's date of birth is August 23, 1964 and social security number is 205-60- Member's last known mailing address is: 71 Hillside Dr., Carlisle, PA 17013 Alternate Payee's last known mailing address is: 504 Highland Court, Carlisle, PA It is the responsibility of the Alternate Payee to keep a current mailing address on file with SERS at all times. 7. Altemate Payee's share of Member's retirement benefit shall be $21,719.00. 8. Member's retirement benefit is defined as all monies paid to or on behalf of Member by SERS, including any lump sum withdrawals or scheduled or ad hoc increases, but excluding the disability portion of any disability annuities paid to Member by SERS as a result of disability which occurs before Member's marriage to Alternate Payee or after the date of Member's and Alternate Payee's final separation. Member's retirement benefit does not include any deferred compensation benefits paid to Member by SERS. The equitable distribution portion of the marital property component of Member's retirement benefit, as set forth in Paragraph (7), shall be payable to Alternate Payee and shall commence as soon as administratively feasible on or about the date Member actually enters pay status and SERS approves a Domestic Relations Order incorporating this Stipulation and Agreement, whichever is later. 9. Member hereby nominates Alternate Payee as an irrevocable beneficiary to the extent of Alternate Payee's equitable distribution portion of Member's retirement benefit for any death benefits payable by SERS. This nomination shall become effective upon approval by the Secretary of the Retirement Board, or his authorized representative, of any Domestic Relations Order incorporating this Stipulation and Agreement. The balance of any death benefit remaining after the allocation of the equitable distribution portion payable to Alternate Payee and the alternate payee under any SERS-approved Domestic Relations Order ("Balance") shall be paid to the beneficiaries named by Member on the last Nomination of Beneficiaries Form filed with the Retirement Board prior to Member's death. a. If the last Nomination of Beneficiaries Form filed by Member prior to Member's death (a) predates any approved Domestic Relations Order incorporating this Stipulation and Agreement, and (b) names Altemate Payee as a beneficiary, then: (1) the terms of the Domestic Relations Order shall alone govem Alternate Payee's share of any death benefit, and (2) for purposes of paying the Balance via the last Nomination of Beneficiaries Form filed with the Retirement Board prior to Member's death, Alternate Payee shall be treated as if Alternate Payee predeceased Member. No portion of the Balance shall be payable to Alternate Payee's estate. b. In addition, Member shall execute and deliver to Alternate Payee an authorization, in a form acceptable to SERS, which will authorize SERS to release to Alternate Payee all relevant information concerning Member's retirement account. 10. The term and amount of Member's retirement benefits payable to Alternate Payee after SERS approves a Domestic Relations Order incorporating this Stipulation and Agreement depends upon which option(s) Member selects at retirement. Member and Alternate Payee expressly agree that Member may select any retirement option offered by SERS under the Retirement Code at the time Member files an Application for Retirement Allowance with SERS, provided that the option selected assures Alternate Payee of her or her estate's receipt of the share she is to receive as Alternate Payee as stated in paragraph 7 above regardless of the timing of the deaths of Member and Alternate Payee. 11. Alternate Payee may not exercise any right, privilege or option offered by SERS. SERS shall issue individual tax forms to Member and Alternate Payee for amounts paid to each. 12. In the event of the death of the Alternate Payee prior to the receipt of all payments payable to her from SERS under a Domestic Relations Order incorporating this Stipulation and Agreement, any death benefit or retirement benefit payable to Altemate Payee by SERS shall be paid to Alternate Payee's Estate to the extent of the Alternate Payee's equitable distribution portion of the Member's retirement benefit as set forth in Paragraphs 7 through 9. 13. In no event shall the Altemate Payee or her estate have greater benefits or rights than those which are available to the Member. benefit not otherwise provided by SERS. The Alternate Payee or her Estate is not entitled to any The Alternate Payee or her Estate is only entitled to the specific benefits offered by SERS as provided in this Stipulation and Agreement. All other rights, privileges, and options offered by SERS not granted to the Alternate Payee or her Estate by this Stipulation and Agreement are preserved for the Member. 14. It is specifically intended and agreed by the parties hereto that any Domestic Relations Order incorporating this Stipulation and Agreement: A. Does not require SERS to provide any type of form or amount of benefit or option not otherwise provided under the Retirement Code; and B. Does not require SERS to provide increased benefits (determined on the basis of actuarial value) unless increased benefits are paid to Member based upon cost-of-living adjustments or on other than actuarial values. 15. The parties intend and agree that the terms of this Stipulation and Agreement shall be approved, adopted, and entered as a Domestic Relations Order. 16. The Court of Common Pleas of Cumberland County, Pennsylvania, shall retain jurisdiction to amend any Domestic Relations Order based on this Stipulation and Agreement, but only for the purpose of establishing it or maintaining it as a Domestic Relations Order; provided, however, that no such amendment shall require SERS to provide any type or form of benefit, or any option not otherwise provided by SERS, and further provided that no such amendment or right of the Court to so amend will invalidate any existing Order. 17. Upon its entry as a Domestic Relations Order, a certified copy of this Stipulation and Agreement, and any attachment documents shall be served upon SERS immediately. The Domestic Relations Order shall take effect immediately upon SERS approval and the approval of any attendant documents by SERS, and shall remain in effect until further Order of Court. WHEREFORE, the parties, intending to be legally bound Agreement, do hereunto place their hands and seals. Date: ~~At~6mey for Alter~atE:ql~ayee Date: I t 'Ro~lfigo J. Di~, M~er Date: Authorization for the Release of Account Information to Alternate Payee I, Rodrigo J. Diaz, authorize the Pennsylvania State Employees' Retirement System ("SERS") to release to Lisa G. Diaz any and all information that she may request regarding my SERS benefits or retirement account. This authorization is granted under the terms of the Approved Domestic Relations Order entered by the Cumberland County Court of Common Pleas on , ,2004, at 02-5524, which names Lisa G. Diaz as Alternate Payee. A photocopy or faxed copy of this Authorization shall have the same force and effect as the original. Date Signature Rodrigo J. Diaz 168-60-3538 LISA G. DIAZ, Plaintiff VS. RODRIGO J. DIAZ, Defendant : IN THE COURT 'OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO: 02-5524 : IN DIVORCE AND NOW, this Agreement dated December __ Relations Order. ORDER _ day of .... '- the attached Stipulation and 2004 of the parties in this case is hereby entered as a Domestic CC: oay~lor P. Andrews, Esq., for Plaintiffx F. King, Esq.. for Defendant oV\O'0