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HomeMy WebLinkAbout00-04460 SEP 1 4 2606 CHERYL K. TRITT, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V NO. 00-4460 RONALD C. TRPTT, CIVIL ACTION - LAW Defendant/Respondent IN DIVORCE ORDER AND NOW, this day of 2006, upon petition of Cheryl K. Tritt, Plaintiff Petitioner herein, a rule is hereby issued upon the Defendant/Respondent, Ronald C. Tritt, to show cause why if any of the relief requested should not be granted. Rule returnable on 2006 at : ?{ S A M. in courtroom ti , Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. J. ,chard L. Webber, Jr. Attorney for Plaintiff /Petitioner Richard Wagner Attorney for Defendant/Respondent x WEIGLE & ASSOCIATES. RC. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 l?> y I C7 rtf C :: ? C\j :: Ln qkW N ? J 4 CHERYL K. TRITT, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA v NO. 00-4460 RONALD C. TRITT, CIVIL ACTION - LAW Defendant/Respondent IN DIVORCE PETITION FOR SPECIAL RELIEF_ AND NOW, comes the Plaintiff/Petitioner, Cheryl K. Tritt, by and through her attorneys, Richard L. Webber, Jr., Esquire, and Weigle & Associates, P.C, and avers the following: 1. Plaintiff/Petitioner is Cheryl K. Tritt (hereinafter "Wife'), of 24 Mt. Rock Road, Newville, PA 17241. 1 Defendant/Respondent is Ronald C. Tritt (hereinafter "Husband"), of 67 Kutz Road, Carlisle, PA 17015. 3. The parties were married on July 11, 1987 and separated on May 30, 1998. 4. On June 27, 2000, Wife filed a Complaint for Divorce. 5. Wife was employed by the Big Spring School District as a Principal for the Plainfield Elementary School. 6. Wife became eligible for full retirement effective July 1, 2006, having been employed as a teacher for 35 years in the Commonwealth of Pennsylvania teachers system. 7. Wife and Husband presently have health insurance coverage through Wife's former employer, the Big Spring School District. 8. Prior to Wife's retirement, the total cost to Wife to provide insurance coverage for both Husband and Wife was $947.70/year. 9. The total current monthly insurance premium to insure Wife and Husband is $689.65 ($333.46 for Wife and an additional $356.19 for Husband), payable in quarterly installments of $2068.95 each. 10. On or about January 1, 2006 Husband became eligible for Medicare insurance coverage. 11. On or about June 13, 2006 Wife discussed with Husband the amount of the increased health insurance premium. WEIGLE & ASSOCIATES. P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17251-1397 12. During the same conversation mentioned in Paragraph 11 above, Husband indicated to Wife that he no longer desired to be insured through Wife's health insurance plan, effective July 1, 2006. 13. By prior Order dated October 8, 2003, which amended the Order dated September 19, 2003, Wife is required to maintain health insurance coverage for Husband. 14. Wife believes that Husband may be eligible for some form of supplemental insurance in addition to Medicare. 15. To date, the undersigned counsel has been unable to resolve this issue with P. Richard Wagner, attorney for husband. WHEREFORE, Plaintiff/Petitioner respectfully requests that the Court vacate the prior Orders dated September 19, 2003 and October 8, 2003, effective July 1, 2006, plus any other appropriate relief Respectfully submitted: Dated: q13 / r 0? WEIGLE & ASSOCIATES, P.C. Richard L. Webber, Jr., Esquire Attorney ID #49634 126 East King Street Shippensburg, PA 17257 717-532-7388 WEIGLE & ASSOCIATES. P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to authorities. Date: Sir Cheryl K. Vitt WEIGLE & ASSOCIATES. P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSSURG, PA 17257-1B97 _? .? >? ._ n N o ? - n ?3 ? ?' cn rte; ? mr '+? T ? -? ?.] ? ?r JT?(?1 - ? `3 11 ? iV c' c.: S? CHERYL K. TRITT, Plaintiff V. RONALD C. TRITT, Defendant IN THE COURT OF. COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 00-4460 CIVIL TERM ORDER OF COURT AND NOW, this 8 h day of October, 2003, upon request of Marcus McKnight, III, Esq., attorney for Plaintiff, the prior order of court dated September 19, 2003, is hereby amended to reflect that restoration of health benefits to Defendant through Plaintiff's place of employment (Big Spring School District) shall be effective July 1, 2002. In all other respects, the prior order shall remain in full force and effect. BY THE COURT, /Marcus McKnight, III, Esq. Attorney for Plaintiff J i/P. Richard Wagner, Esq. Attorney for Defendant :rc 10.04 -6.3 AO CHERYL K. TRITT Plaintiff/Respondent V. RONALD C. TRITT Defendant/Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No: 00-4460 :CIVIL- LAW :DIVORCE DER AND NOW, this [ `+ day of 2003, upon petition of RONALD TRITT, a rule is hereby issued upon the Respondent, Cheryl Tritt, to show cause why if any of the relief requested should not be granted. In the interim, Respondent is directed to restore Petitioner to health benefit plan through Respondent's place of employment i.e. the Big Springs School District. BY THE COURT: t l 4 `?Ih!Hi1?,lSNN?d L.Z:Z I.tJ Rd35ZO 7?7?.Lr??1u , CHERYL K. TRITT Plaintiff/Respondent V. RONALD C. TRITT Defendant/Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No: 00-4460 :CIVIL- LAW :DIVORCE PETITION FOR RELIEF AND NOW, comes the Petitioner, RONALD C. TRITT, by and through hIS attorney, P. Richard Wagner, Esquire, and avers the following: 1. Your Petitioner, Ronald C. Tritt, is the Defendant in the above-captioned divorce action. 2. The Respondent, Cheryl K. Tritt, is the Plaintiff in the above-captioned divorce action. 3. The parties have health benefits through the Respondent's place of employment, the Big Springs School District. 4. Without notification to the Petitioner herein, and without consent of the Petitioner herein, Respondent unilaterally removed the Petitioner from the health insurance provided through the Respondent's place of employment, the Big Springs School District. 5. As a result of that removal, Petitioner has now incurred considerable medical expenses as a result of several strokes that have occurred immediately after the removal from health coverage. 6. The Petitioner believes, and therefore avers, that the Petitioner will continue to suffer irreparable harm by not being added to the health insurance program of the Respondent. 7. Petitioner herein was covered by the Respondent's health program since their date of marriage, July 11, 1987, up until the time he was unilaterally removed by the Respondent WHEREFORE, Petitioner requests that the Court to direct that the Respondent shall restore the Petitioner herein to the health benefit program through her place of employment. RESPECTFULLY SUBMITTED: P. R' and Wa er, Esquire I. . #: 2310 233 N Front Street urg, PA 17110 717-234-7051 DATE: September 17, 2003 I verify that the statements made in the, foregoing document are true and correct. I understand that false statements herein are made.subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. C alLd` - -DATE: ??' c I'> "'j r ifs{ ? I C" - -r, « rt P _ ? _ rt , V L u? JERRY A. WEIGLE Associates JOSEPH P. RUANE RICHARD L. WEBBER, JR. Of Counsel THOMAS L. BRIGHT WEIGLE & ASSOCIATES, P.C. Attorneys-at-Law 126 EAST KING STREET SHIPPENSBURG, PENNSYLVANIA 17257-1397 TELEPHONE (717) 532-7388 or (717) 7764295 FAX (717) 532-5289 weiel eassociates(a, eart'bli nk.net April 24, 2006 E. Robert Flicker, II, Divorce Master for Cumberland County 9 North Hanover Street Carlisle, PA 17013 RE: Tritt v. Tritt No. 00-4460 In Divorce Dear Mr. Elicker: As you will recall, I represent the Plaintiff, Cheryl K. Tritt. P. Richard Wagner (attorney for Mr. Tritt) and I met with you on Monday, April 10, 2006. In particular, we discussed Mrs. Tritt's present employment of the Big Spring School District, her retirement account, her intention to retire and other miscellaneous issues. At the conclusion of the conference, you requested that I provide you with a status report. Today, I forwarded a letter to Mr. Wagner and indicated my client's intention to retire as of June 30, 2006, as well as her preference as far as the retirement plan options. In addition, I forwarded a letter to Conrad Siegel requesting that the retirement account be re-evaluated in light of the issues raised in their letter to Mr. Wagner dated February 14, 2006. 1 have been informed that the new evaluation can be completed in the near future. In the event that Mrs. Tritt does retire, there will be an issue as to the increased cost of health insurance coverage. Both parties are presently covered under her plan. I have also requested that Mr. Wagner provide me with additional information concerning Mr. Tritt's anticipated income as well as various items of marital debt that Mr. Tritt claims to have paid. In the event that Mrs. Tritt does in fact retire effective July 1, 2006, the monthly retirement 'check as well--'as contributions would not be available for 12 weeks. If the parties are unsuccessful in negotiating a settlement, perhaps there would be time to conduct a hearing prior to the availability of the funds. E. Robert Elicker, II, Divorce Master April 24, 2006 Page 2 Mr. Wagner and I will attempt to negotiate a temporary resolution so that Mrs. Tritt may retire. In addition, the new retirement valuation will hopefully further the negotiation process. Sincerely, WEIGLE & ASSOCIATES, P.C. Richard L. Webber, Jr., Esquire RLW/paf Cc: P. Richard Wagner, Esquire Cheryl K. Tritt JERRY A. WEIGLE Associates JOSEPH P. RUANE RICHARD L. WEBBER, JR. Of Counsel THOMAS L. BRIGHT WEIGLE & ASSOCIATES, P.C. Attorneys-at-Law 126 EAST KING STREET SHH'PENSBURG, PENNSYLVANIA 17257-1397 TELEPHONE (717) 532-7388 or (717) 7764295 FAX (717) 532-5289 weialeassociates(aearthl i nk.net September 1, 2006 E. Robert Elicker, II, Divorce Master for Cumberland County 9 North Hanover Street Carlisle, PA 17013 RE: Tritt v. Tritt No. 00-4460 In Divorce Dear Mr. Elicker: As you will recall, I represent the Plaintiff, Cheryl K. Tritt. P. Richard Wagner, attorney for Mr. Tritt, and I met with you on Monday, April 10, 2006. In particular, we discussed Mrs. Tritt's employment of the Big Spring School District, her retirement account and the need to have it re-evaluated, her intention to retire effective July 1, 2006 and other miscellaneous issues. At the conclusion of the conference, you requested that I provide you with a status report. I forwarded a letter to you dated April 24, 2006. Mrs. Tritt did in fact retire effective July 1, 2006. In addition, we have received a new valuation of her retirement account. The parties have not reached a final resolution of the outstanding issues. On behalf of my client, I am therefore requesting that a conference be scheduled with you, counsel and both parties. Sincerely, WEIGLLE&?ASSOCIATES, P.C. Richard L. Webber, Jr., Esquire RLW/paf Cc: P. Richard Wagner, Esquire Cheryl K. Tritt CHERYL K. TRITT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 00 - 4460 CIVIL RONALD C. TRITT, Defendant IN DIVORCE CONFERENCE TO: Richard L. Webber, Jr. , Attorney for Plaintiff P. Richard Wagner , Attorney for Defendant A conference has been scheduled at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 10th day of April, 2006, at 1:30 p.m. Very truly yours, Date of Notice: 2/21/06 E. Robert Elicker, II Divorce Master JERRY A. WEIGLE Associates JOSEPH P. RUANE RICHARD L. WEBBER, JR. Of Counsel THOMAS L. BRIGHT E. Robert Elicker, II, Divorce Master for Cumberland County 9 North Hanover Street Carlisle, PA 17013 February 15, 2006 RE: Tritt v. Tritt No. 00-4460 In Divorce Dear Mr. Elicker: I represent the Defendant, Cheryl K. Tritt, in the matter referenced above. I have enclosed a true copy of a Praecipe indicating that Mrs. Tritt's prior counsel, Marcus A. McKnight, III, Esquire has withdrawn his appearance and that I have entered my appearance. My understanding is that there was at least one prior conference at your office with the attorneys only. It is my further understanding that a valuation of Mrs. Tritt's retirement account was to be performed. The valuation of Mrs. Tritt's account has been completed. That information was forwarded to P. Richard Wagner, attorney for Mr. Tritt. The parties have been unable to resolve the various economic issues. I am therefore requesting that a conference be scheduled Thank you for your attention to this matter. WEIGLE & ASSOCIATES, P.C. Attorneys-lit-Law 126 EAST KING STREET SHIPPENSBURG, PENNSYLVANIA 17257-1397 TELEPHONE (717) 532-7388 or (717) 776-4295 FAX (717) 532-5289 wei2teassociates(a,earthlink.net Sincerely, W78-r ASSOCIATES, P.C. Richard L. Webber, Jr., Esquire RLW/paf Enclosure Co: P. Richard Wagner; Esquire - Cheryl K. Tritt. CHERYL K. TRITT, Plaintiff v RONALD C. TRITT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2004-4460 CIVIL TERM a Doo IN DIVORCE PRAECIPE TO WITHDRAW APPEARANCE To the Prothonotary: Please withdraw my appearance in the above-referenced matter. IRWIN Dated: By: Z-/ V Marcu A. D Attorney fo 60 West Por. Carlisle, PA PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter my appearance on behalf of the Plaintiff, Cheryl K. Tritt. WEIGLE & ASSOCIATES, P.C. ?n li a D??oG (> Dated: By: Richard L. Webber, Jr., Esquir Attorney ID #49634 126 East King Street Shippensburg, PA 17257 (717)532-7388 WEIGLE & ASSOCIATES. P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17251-t597 f7 C v o Q - c++ 3 C- S ^. N -t 1'i L CA.) r tom' n ???di CHERYL K. TRITT, IN TIRE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW 2004-4460 CIVIL TERM RONALD C. TRITT, Defendant IN DIVORCE PRAECIPE TO WITHDRAW APPEARANCE To the Prothonotary Please withdraw my appearance in the above-referenced matter. IRWIN McKNI HT T$iT1 rv i ? 1 ? -a 1 :? Dated: By: =- Marcu A. Attorney fo Plainti :-. :yz c- 60 West Po et . eet' `-: E5 C Carlisle, PA 17013 PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter my appearance on behalf of the Plaintiff, Cheryl K. Tritt. WEIGLE && ASSOCIATES, P.C. Dated: . rlyl li4 7 a (?? ZUC} ? By:?/ Richard L. Webber, Jr., Esquiir Attorney ID #49634 126 East King Street Shippensburg, PA 17257 (717)532-7388 WEIGLE & ASSOCIATES. P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBVRG. PA 17aS7-1397 OFFICE OF DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEAS 9 North Hanover Street Carlisle, PA 17013 (717) 240-6535 E. Robert Elicker, 11 Divorce Master Traci Jo Colyer Office Manager/Reporter June 14, 2005 West Shore 697-0371 Ext. 6535 Marcus A. McKnight, III P. Richard Wagner Attorney at Law Attorney at Law IRWIN, & McKNIGHT MANCKE, WAGNER & SPREHA 60 West Pomfret Street 2233 North Front Street Carlisle, PA 17013 Harrisburg, PA 17110 RE: Cheryl K. Tritt vs. Ronald C. Tritt No. 00 - 4460 Civil In Divorce Dear Mr. McKnight and Mr. Wagner: Mr. Wagner has been writing and asking me to dispose of the above-referenced case in some manner. Obviously, the finalization of the matter would be through a hearing; however, without the discovery being complete I hesitate to convene a hearing and then end up with inadequate testimony to proceed to a conclusion. The issue has to do with Mrs. Tritt's pension and since Mr. Tritt is not apparently able to pay to have it valued and Mrs. Tritt will not cooperate, my only suggestion at this point is for counsel to ask the Court to intervene on the valuation matter. Mr. Tritt, as stated in Mr. Wagner's letter, apparently does not want to take a portion of the pension through a deferred distribution but is seeking an immediate offset. For that reason, the pension needs to be valued. Please advise as to what counsel intend to do regarding the, pension valuation, either by getting the Court's assistance or Mrs. Tritt's assistance. I would appreciate a response from Mr. McKnight as to his position on this matter as soon Mr. McKnight and Mr. Wagner, Attorneys at Law 14 June 2005 Page 2 as possible. We know Mr. Wagner's position. As you know, I do not want to begin a hearing without having adequate evidence available to conclude. Very truly yours, E. Robert Elicker, H Divorce Master JOHN B. MANCKE P. RICHARD WAGNER EDWARD F. SPREHA, JR. LAW OFFICES MANCKE, WAGNER & SPREHA 2233 NORTH FRONTSTREET HARRISBURG, PA 17110 May 26, 2005 Master Bob Elicker 1 Courthouse Square Carlisle, PA 17013 Dear Master Elicker: PHONE 01 71 2 3 47051 FAX 017) 2347080 The Tritt matter has been on hold for sometime pending a valuation of Mrs. Tritt's pension through her school district. Frankly, Mr. Tritt does not have the wherewithal to do that and unfortunately, Mrs. Tritt has not seen fit to have the pension valued, therefore, Mr. Tritt is in a position of being relegated to seeking a portion of her pension through a deferred distribution based upon an appropriate formula developed by the Supreme Court. With that in mind, it would be appreciated if you could schedule this matter at your earliest convenience for disposition. Your attention is appreciated. PRW/aar cc: Mr. Ron Tritt Sincerely, Rich d Wa er CHERYL K. TRITT, Plaintiff VS. RONALD C. TRITT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 00 - 4460 CIVIL IN DIVORCE RESCHEDULED CONFERENCE WITH COUNSEL AND THE PARTIES TO: Marcus A. McKnight, III Counsel for-Plaintiff Cheryl K. Tritt Plaintiff P. Richard Wagner Counsel for-Defendant Ronald C. Tritt Defendant A conference has been scheduled at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 5th day of April 2004, at 2:00 p.m., with counsel and the parties to discuss the outstanding economic issues to determine if there is a basis of settlement of claims. If issues remain after the conference;-a hearing will be scheduled at another date. Very truly yours, Date of Notice: E. Robert Elicker, II March 22, 2004 Divorce Master JOHN B. MANCKE P. RICHARD WAGNER EDWARD F. SPREHA. JR. "W OFFICES MANCKE, WAGNER & SPREHA 2233 NORTH FRONT STREET HARRISBURG, PA 17110 December 27, 2004 E. Robert Elicker, Esquire 9 North Hanover Street Carlisle, PA 17013 Re: Tritt v. Tritt Dear Mr. Elicker: PHONE C7171 2347051 FAX (717) 234.7090 You will recall that we had a conference in this matter some time ago wherein information was exchanged by and between the parties. The matter has proceeded no farther than the last conference, therefore,) would respectfully request that the matter be scheduled for a hearing. Your prompt attention is respectfully requested. r/ PRW/dks cc: Marcus McKnight, Esq. Mr. Ron Tritt LAW OMCES MANCKE, WAGNER & SPREHA 2233 NORTH FROM STREET JOHN B. MANCKE HARRISBURG. PA 17110 P. RICHARD WAGNER EDWARD F. SPREHA. JR. September 29, 2004 E. Robert Elicker, Esquire 9 North Hanover Street Carlisle, PA 17013 Re: Tritt v. Tritt No: 00-4460 Dear Mr. Elicker: PHONE 0171 2 3 47031 FAX 017) 2347080 The above-captioned matter was scheduled for a conference in April of 2004 which was productive but did not reach a resolution. In the interim, little if any progress has been made to bring this matter to a conclusion, therefore, I must respectfully request that you schedule a date for a Master's hearing that the above matter may be scheduled and brought to a conclusion. Your attention is appreciated. PRW/dks me ely, hard Wagner cc: Marcus McKnight, Esq. Mr. Ron Tritt JOHN B. MANCKE P. RICHARD WAGNER EDWARD F. SPREHA, JR. LAW OFFICES MANCKE, WAGNER & SPREHA 2233 NORTH FRONT STREET HARRISBURG. PA 17110 June 11, 2004 E- Robert Elicker, Esquire 9 North Hanover Street Carlisle, PA 17013 Re: Tritt v. Tritt Dear Mr. Elicker: PHONE (717) 2347051 FAX (717) 234-7060 Your records will reflect that we had a settlement conference on the above- captioned matter in March, however, the matter has not moved forward since that time. Accordingly, I would ask that you schedule a Master's hearing on this matter. Your attention is appreciated. --?7 Sincerely, PRW/dks cc: Marcus McKnight, Esq. Mr. Ron Tritt In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION RONALD C. TRITT - - _ ) Docket Number 00-4460 CIVIL Plaintiff ) VS. ) PACSES Case Number 119 105 9 91 CHERYL K. TRITT - - ) Defendant ) Other State ID Number ORDER AND NOW, to wit on this 3RD DAY OF FEBRUARY, 2004 IT IS HEREBY ORDERED that the Q Complaint for Support or Q Petition to Modify or ® Other COMPLAINT FOR APL --filed on NOVEMBER 26, 2004 in the above captioned matter is dismissed without prejudice due to: THE PARTIES MOVING AHEAD WITH THE DIVORCE PROCEEDINGS AND THE MATTER WILL BE RESOLVED WITH THE DIVORCE MATTER, PURSUANT TO AN AGREEMENT OF THE PARTIES. Q The Complaint or Petition may be reinstated upon written application of the plaintiff petitioner. DRO: RJ Shadday xC: plaintiff defendant P. Richard Wagner, Esquire Marcus McKnight, Esquire BY OURT „ 1 Gv,Cti, Edgar Bay ey JUDGE Service Type M Form OE-506 Worker ID 21005 0 L W 6m W tD G CHERYL K. TRITT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 00 - 4460 CIVIL RONALD C. TRITT, Defendant IN DIVORCE CONFERENCE WITH COUNSEL AND THE PARTIES TO: Marcus A. McKnight, III Counsel for Plaintiff Cheryl K. Tritt Plaintiff P. Richard Wagner Counsel for Defendant Ronald C. Tritt Defendant A conference has been scheduled at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 12th day of February 2004, at 9:00 a.m., with counsel and the parties to discuss the outstanding economic issues to determine if there is a basis of settlement of claims. If issues remain after the conference, a hearing will be scheduled at another date. Very truly yours, Date of Notice: E. Robert Elicker, II January 5, 2004 Divorce Master CHERYL K. TRITT, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - DIVORCE NO. 2000-4460 CIVIL TERM RONALD C. TRITT, IN DIVORCE Defendant/Petitioner Pacses# 119105981 ORDER OF COURT AND NOW, this 26a day of November, 2003, upon consideration of the attached Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shaddav on December 22. 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 true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11© (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you, IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, George E. Hoffer, President Judge Mail copies on Petitioner 11-26-03 to: < Respondent P. Richard Wagner, Esquire Marcus McKnight, Esquire I s Date of Order: November 22. 2003 A1 R. 1 Shadday, Conference Officer / 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 ° o c IN THE COURT OF COMMON, PLEAS OF C711MERLAND COUNTY, PM\MSTLVANL? CHERYL K. TRITT - G7 ,v 0 Plaintiff VS. -.0 r77 RONALD C. TRITT rr>`j N) N0. 2000-4460 {19 G MOTION FOR APPOtN `^_=T OF MASTER Cheryl K. Tritt (Plaintiff) (3ffi9zm42=), moves the court to appoint a master with respect to the followi=g claims: (x ) Divorce (x) Distribution of Property ( ) A=nt lmen*_ C ) Support (x) Alimony (x) Counsel Fees (x) Alimony Pendente Lite (x) Costs and Expenses and in support of the motion states: (1) Discovery is comp late as cc the ciai=s(s) for which tae appointment of a master is requested. (2) The defendant (has) k?==x=t) appeared in the action (7%axasxai±y) (by his attorney, P. Richard Wagner ,Esquira). (3) The staturor.7 ground(s) for divorce ? (are) irretrievably broken 3301(c) (4) Delete the inapplicable paragraph(s): (a)C.RSx#SC2S1@AxxA„Q1[c (b) An agreement has been reached with respect to the following claims: Divorce (c) The action is contested with respect to the following claims: Alimony, Alimony Pendente Lite, Distribution of Property, Counsel Fees & Costs (5) The action (involves) (does not involve) ccmpl=-x issues of law or fact. (5) The hearing is e:pectad to take 1 day (' ) (days) (7) Additional information, if any. relevant to the motion: ]ate: December 22, 2003 By: Irwin Tri*_t Aiv7i NorI is appoint=_d master with respect to By the Court: Ink"V6_7 c) / J CHERYL K. TRITT, Plaintiff VS. RONALD C. TRITT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 00 - 4460 CIVIL IN DIVORCE RESCHEDULED CONFERENCE WITH COUNSEL AND THE PARTIES TO: Marcus A. McKnight, III , Counsel for Plaintiff Cheryl K. Tritt , Plaintiff P. Richard Wagner Ronald C. Tritt Counsel for Defendant Defendant A conference has been scheduled at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 30th day of March 2004, at 1:30 p.m., with counsel and the parties-to discuss the outstanding economic issues to determine if there is a basis of settlement of claims. If issues remain after the conference, a hearing will be scheduled at another date. Very truly yours, Date of Notice: E. Robert Elicker, II February 12, 2004 Divorce Master IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PzN SYLVANIA CHERYL K. TRITT Plaintiff VS. RONALD C. TRITT No. 2000-4460 19 MOTION FOR APPOLVT:L`tT OF MASTER Cheryl K. Tritt (Plaintiff) (D49mmnt a master with respect to the following claims: (x ) Divorce (x ) ( ) Annulment ( ) (x ) Alimony (x ) (x) Alimony Pendente Lite (x ) and in support of the motion states: gmt), moves the court to appoint Distribution of Property Sunoort Counsel Fees Costs and Expenses (1) Discovery is complete as to the claims(s) for which the appointment of a master is requested. (2) The defendant (has) 9saaxao;10 appeared in the action (gassamaliT) (by his attorney, P. Richard Wagner _ ,Esqui.ra). (3) The staturory ground(s) for divorce (xi (are) irretrievably broken 3301(c) _ (4) Delete the inapplicable paragraph(s): (a) 'i:0asxa¢iG?Axsi?::?:txx (b) An agreement has been reached with respect to the following claims: Divorce -- (c) The action is contested with respect to the following claims: Alimony, Alimony Pendente Lite; Distribution of Property, Counsel Fees & Costs _ (5) The action (involves) (does not involve) complex issues of law or fact. (6) The hearing is expected to take 1 day (b==) (days). (7) Additional information, if any. relevant to the motion: Irwini ht ! r Date: December 22, 2003 By: (.? J Attorney for Tritt AN7i NO4i 1?L?? ,?L?i[o?a,i-?J+.•?Xa? Esquire, is appointed master with respect to the following claims: Z21E .. By the Co r /0S N C o° G.tl ? N CAD m J p G AIL 0 N -`-' ??.=; N N -C QD O D LAW OFFICES IRWIN & McKNIGHT WESTPOMFRETPROFESSIONAL BUILDING 60 WESTPOMFRETSTREET ROGER B. IRWIN CARLISLE, PENNSYLVANIA 17013-3222 MARCUSA. MCKNIGHT, III DOUGLASG. MILLER (717) 249-2353 FAX (717) 249-6354 E-MAIL: OFFICES@JMHLAW. COM December 23, 2003 E. ROBERT FLICKER, II, ESQ. OFFICE OF DIVORCE MASTER 13 NORTH HANOVER STREET CARLISLE, PA 17013 RE: CHERYL K. TRITT v. RONALD C. TRITT NO. 00-4460 CIVIL TERM IN DIVORCE Dear Mr. Elicker: HAROLD S. IRWIN (1915-1977) HAROLD S IRWIN, JR (1954-1986) IRWM. IRWIN & IRWIN (1956-1986) IRM IRWIN & McKNIGHT (1986-1994) IRWM, McKNIGHT & HUGHES (1994-2003) IRWIN & Mc MGHT (2003- J You have been appointed as Divorce Master in this case. I have enclosed a certified copy of the Order of Court by President Judge George E. Hoffer dated December 22, 2003. The parties have agreed to waive the normal pre-hearing procedures and have you schedule a settlement conference for the parties and their legal counsel. Thank you for your consideration of this request. Very truly yours, IRWIN A. M MAM/min Enclosure cc: Ms. Cheryl K. Tritt P. Richard Wagner, Esq. OFFICE OF DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEAS 9 North Hanover Street Carlisle, PA 17013 (717) 240-6535 E. Robert Elicker, 11 Divorce Master Traci Jo Colyer Office Manager/Reporter TO: John W. Purcell, Jr. Esquire Thomas S. Diehl, Esquire Michael J. Hanft, Esquire Jane Adams, Attorney at Law Samuel W. Milkes, Esquire Johnna J. Kopecky, Attorney at Law Mark D. Schwartz, Esquire FROM: E. Robert Elicker, II, Divorce Master DATE: Thursday, May 31, 2001 RE: Pretrial Statements Dear Ladies and Gentlemen: West Shore 697-0371 Ext. 6535 You were directed to file pretrial statements in cases which you have pending before me on or before Tuesday, May 29, 2001. Neither counsel have filed pretrial statements in the following cases: Antel vs. Antel, Bowman vs. Bowman, Thomas vs. Thomas, Tritt vs. Tritt. I am withdrawing the directive for the filing of pretrial statements in the above captioned cases. I do not intend to issue any further directives for the filing of pretrial statements in these cases. When counsel do finally get around to filing pretrial statements, I do not intend to schedule conferences on these cases until September or October 2001. OFFICE OF DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEAS 9 North Hanover Street Carlisle, PA 17013 (717) 240-6535 E. Robert Elicker, 11 Divorce Master Traci Jo Colyer Office Manager/Reporter April 23, 2001 West Shore 697-0371 Ext. 6535 Mark D. Schwartz, Esquire Michael J. Hanft, Esquire IRWIN, McKNIGHT & HUGHES 19 Brookwood Avenue, Suite 106 60 West Pomfret Street Carlisle, PA 17013-9142 Carlisle, PA 17013 RE: Cheryl K. Tritt vs. Ronald C. Tritt No. 00 - 4460 Civil In Divorce Dear Mr. Schwartz and Mr. Hanft: Mr. Schwartz has returned the certification document regarding discovery indicating that discovery is complete. Mr. Hanft has not returned the certification document; therefore, I am assuming that there are no outstanding discovery issues and that we will not be dealing with discovery matters at the pre-hearing conference. I reserve the right to exclude testimony if there are issues raised regarding discovery matters at the time of the conference. A divorce complaint was filed on June 27, 2000, raising grounds for divorce of irretrievable breakdown of the marriage. No economic claims were raised in the complaint. On February 15, 2001, the Defendant filed an answer and counterclaim. The counterclaim raised the economic issues of alimony pendente lite and counsel fees and expenses, equitable distribution and alimony. In accordance with P.R.C.P. 1920.33(b) I am directing each counsel to file a pretrial statement on or before Tuesday, May 29, 2001. Upon receipt of the pretrial statements, I will immediately schedule a pre-hearing conference with counsel to discuss i Mr. Schwartz and Mr. Hanft, Attorneys at Law 23 April, 2001 Page 2 the issues and, if necessary, schedule a hearing. Very truly yours, E. Robert Elicker, II Divorce Master NOTE: Sanctions for failure to file the pretrial statements are set forth in subdivision (c) and (d) of Rule 1920.33. THE ORIGINAL PRETRIAL STATEMENT SHOULD BE FILED IN THE MASTER'S OFFICE AND A COPY SENT DIRECTLY TO OPPOSING COUNSEL. FAILURE TO FILE PRETRIAL STATEMENTS AS DIRECTED BY THE MASTER MAY RESULT IN THE MASTER'S APPOINTMENT BEING VACATED. r CHERYL K. TRITT, : IN THE COURT OF COMMON PLEAS Plaintiff/Respondent, : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO: 00-4460 RONALD C. TRITT, : CIVIL-LAW Defendant/Petitioner. : DIVORCE PRAECIPE TO ENTER APPEARANCE To Curtis R. Long, Prothonotary: Please enter my appearance on behalf of the plaintiff/respondent, CHERYL K. TRITT, in the above captioned case. Respectfully submitted, IRWIN & cKNIGHT Wreu A. M 'ght, I , Esq. 60 Wes om et Street Carlisle, PA Supreme Court I.D. No: 25476 717-249-2353 Attorney for the Plaintiff/Respondent Cheryl K. Tritt Dated: October 8, 2003 CHERYL K. TRITT, : IN THE COURT OF COMMON PLEAS Plaintiff/Respondent, : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO: 00-4460 RONALD C. TRITT, : CIVIL-LAW Defendant/Petitioner. : DIVORCE CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached document was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: P. Richard Wagner, Esq. Mancke, Wagner & Spreha 2233 North Front Street Harrisburg, PA 17110 IRWIN & McKNIGHT By: Marcu4 A. Me h I I, Esquire 60 West Pomfret Street Carlisle, PA 17013 (717) 249-2353 Supreme Court I.D. No. 25476 Date: October 8, 2003 O G ? O ?`N? ? ?1 ? e? ? 7 C: ! " r L ?._ - T ; G ?' ? T 1 •-? ?- `-; C? r ]-? ?'' <_ . N ?? -? J CHERYL K TRITT Plaintiff/Respondent V. RONALD C. TRITT Defendant/Petitioner y IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No: 00-4460 :CIVIL- LAW :DIVORCE PETITION FOR ALIMONY PENDENTE LITE AND NOW, comes the Petitioner by and through his attorney, P. Richard Wagner, and requests the court to schedule a conference for purposes of seeking and securing alimony pendente lite as follows: 1. Your Petitioner is the Defendant in the above-captioned divorce action. 2. Your Respondent is the Plaintiff in the above-captioned divorce action. 3. On or about June 27, 2000, Respondent filed a divorce action to which the Petitioner herein filed an answer on February 15, 2001 and which under Count 1, Petitioner requested alimony pendente lite. 4. Petitioner herein requests for alimony pendente lite in Count 1 of his Answer be scheduled for a conference before the Domestic Relations Office of Court of Common Pleas of Cumberland County. . WHEREFORE, Petitioner herein requests the court to schedule a hearing before the Domestic Relations Office. RESPECTFULLY SUBMITTED: ?. Ric rd Wagner, Esquire . : 23103 2233 North Front Street Harrisburg, PA 17110 717-234-7051 DATE: October 6, 2003 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.. Section 4904, relating to unsworn falsification to authorities. DATE: jb-6,0 r- w 22 ?`\ ? iV yifl r CHERYL K. TRITT, Plaintiff/Respondent, V. RONALD C. TRITT, Defendant/Petitioner. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO: 00-4460 : CIVIL-LAW : DIVORCE RESPONSE TO PETITION FOR RELIEF AND NOW, comes the Respondent, Cheryl K. Tritt, by and through her attorneys, Irwin, McKnight & Hughes, Esquires, and makes the following statement in response to the Petitioner's Petition for Relief: 1. The Petitioner, Ronald C. Tritt, is the Defendant in the above-captioned divorce action, and the Respondent, Cheryl K. Tritt, is the Plaintiff in the above-captioned divorce action. 2. on or about September 17, 2003, the Petitioner filed a Petition for Relief requesting that he be covered under the Respondent's health insurance plan through her employer, the Big Spring School District. 3. The parties in this action were married on July 11, 1987, and separated May 30, 1998. 4. The Respondent maintained health insurance coverage for the Petitioner from May 30, 1998 through June 30, 2002. 5. On or about February of 2002, the health insurance company, Capital Blue Cross/Pennsylvania Blue Shield, requested a completed coordination of benefits form, specifically for the patient, Ronald C. Tritt, who is the Petitioner in this matter. The date of this form is February 16, 2002, and is attached as Exhibit "A" to this Response. I t 6. Through counsel for the Respondent, this coordination of benefits was forwarded to the Petitioner's attorney, who at that time was Michael J. Hanft, Esquire. 7. No response was received from Michael J. Hanft relative to the coordination of benefits, and the insurance company began denying benefits for the Petitioner based upon the lack of receiving the completed coordination of benefits form. 8. Attached as Exhibit "B" are several bills which the insurance company refused to cover due to the lack of completion of the coordination of benefits form. 9. In July, 2002, the Respondent's employer changed insurance company, and at the time that the Respondent enrolled, due to the lack of cooperation in receiving the coordination of benefits, the Respondent chose not to re-enroll the Petitioner for lack of cooperation on his end. 10. Additionally, at that time, the Petitioner was working at Blimpe (Hess Gas Station) on a full time basis, and due to his lack of response to her request for the completion of the coordination of benefits, the respondent assumed that he was receiving insurance benefits through his employer for whom he had been working full time since September, 1998. 11. Back in June of 1999, a similar situation occurred whereby the Respondent sent the coordination of benefits form directly to the Petitioner, and he delayed in getting this back to her. Attached as Exhibit "C" is a copy of a bill which was denied payment being based upon the Petitioner's failure to complete the coordination of benefits in 1999. 12. The only request to reinstate medical coverage that was received from the Petitioner or his attorney, Michael J. Hanft, was a letter from Attorney Hanft, dated October 15, 2002 directed to the Big Spring School District whereby he requested that the Petitioner be placed back on the coverage. A copy of this letter was sent to the Respondent's attorney, Rebecca R. Hughes. No correspondence was ever directed to the Respondent or her attorney S ? directly requesting that the Petitioner be placed back on the coverage. Attached as Exhibit "D" is the letter dated October 15, 2002, from Michael J. Hanft, Esquire, to the business manager of the Big Spring School District. 13. Due to the lack of correspondence by the Petitioner and/or his attorney in requesting coverage, the Respondent and her attorney assumed that coverage was being provided by the Petitioner's current employer. 14. Attorney for the Respondent, Rebecca R. Hughes, on May 1, 2003, as well as June 26, 2003, forwarded correspondence to the Petitioner's attorney stating that insurance coverage would be placed on the Petitioner retroactively in the event he would cooperate in negotiating for a final marriage settlement agreement since the parties had been separated at that point for five (5) years. Attached as Exhibits `B" are copies of the correspondence from the Respondent's attorney; no response was ever receivel 15. From the time the insurance was terminated through Big Spring School District and the present, there were other alternatives for the Petitioner to obtain insurance coverage from the Respondent such as asking for medical coverage through a letter directed to the Respondent or her attorney, filing at Domestic Relations and requesting insurance coverage, as well as filing a petition with this Court, which the Petitioner has delayed in doing up until this time. 16. Certainly, if medical bills were accruing on a regular basis, more correspondence and/or legal action should have been taken long before this time in an effort to mitigate the amount of uncovered medical bills and make the Respondent and/or her attorney aware of the problem. 17. The Petitioner must have recently cooperated in completing the coordination of benefits form requested by Blue Cross/Blue Shield dated February 16, 2002 (see Exhibit "A") because on or about September 18, 2003, the Respondent received payment for medical services rendered x 4 between 1/29/02 and 6/19/02. Attached as "Exhibit F" is a copy of the letter from Highmark Insurance and a copy of the checks issued which covered the various medical expenses during this time. The total amount of these checks have been forwarded to the Petitioner's Attorney so that the funds could be distributed to the various medical providers if they have not already been paid for by the Petitioner. WHEREFORE, the Respondent, Cheryl K. Tritt, respectfully requests that the Petitioner, Ronald C. Tritt, produce information relative to any medical insurance coverage he may have had since the date of separation, any possible insurance coverage he could have had with employers both past and present, as well as any opportunity to have received or receive social security medical assistance. Respectfully submitted, IRWIN, McKNIGHT & HUGHES Rebecca R. Hughes, Esqui e 60 West Pomfret Street Carlisle, PA 17013 Supreme Court I.D. No: 67212 717-249-2353 Attorney for the Respondent, Cheryl K. Tritt Dated: September 25, 2003 < s VERIFICATION The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unworn falsification to authorities. CH YL K. TAUT Date: Zs 2003 Capital B7ueCross Pennsylvania BlueShield tnaepanaent V,.?ns . W [b. Btu. cross ana Btu. SOlela association WWW P,O. Box 778988 Harrisburg, PA 17177-8908 TRITT CHERYL K 24 MOUNT ROCK RD NEWVILLE PA 17241-9413 Date: Patient: Contract Group No Claim No: Service: Provider: COMP 1 CENTER 02/16/2002 RONALD TRITT H197406112 0057170000 2204610021500 01/29/2002 EDGEPARK SURGICAL INC Your spouse's name: Your spouse's social security number: Is your spouse retired? © Yes ® No If yes, date of retirement / I Month Day Year Is your spouse employed? F-1 Yes O No If no, go to Section 2. If yes, complete the following: Your spouse's employment is: 0 Full time © Part time Name, address, and telephone number of your spouse's employer: Was your spouse offered health insurance by his/her employe? ® Yes ® No If yes, does the employer contribute toward the cost of the premium'? 1-1 Yes © No Name, address, and telephone number of spouse's employee's health insurance carrier: Is your spouse covered under his/her employer's health insurance carrier? © Yes ® No If no, go to Section 2. If yes, complete the following: Identification Number: Group Number: Effective Data: Month Day Year Type of coverage: (check each one that applies) Hospitalization © Medical/Surgical ® Dental © Vision ® Major Medical © Comprehensive Major Medical © Prescription Drug ? HMO ® PPO/POS Who is covered? ® Policyholder only ® Policyholder and spouse ® Policyholder and children ® Family a36 (6/1999)- (over please) THIS FORM SHOULD BE COMPLETED AND SIGNED BY THE POLICYHOLDER SECTION 2 41s this claim for a dependent child? ? Yes ? No If no, go to Section 3. If yes, complete the following: Natural/Adoptive Mother's birthdate: Natural/Adoptive Father's birthd_ate: Month Day Year Month Day Year Complete the rest of Section 2 only if this child's parents are single, divorced, or separated. Who has primary custody of this child? ? Mother ? Father ? Joint ? Guardian Has a court order established that one parent has primary responsibility for the child's health care expenses? ? Yes ? No If no, go to Section 3. If yes, complete the following: Name of Parent/Guardian with primary responsibility: Name, address and phone number of above parent's/guardian's employer's health insurance carrier: Identification Number: Group Number: Effective Date: Month Day Year Type of coverage: ? Hospitalization ? Medical/Surgical ? Dental ? Vision ? Comprehensive Major Medical ? Major Medical ,SECTiON Is this patient eligible for Medicare benefits? ? Yes ? No If no, go to Section 4. If yes, complete the following: Medicare health insurance claim number: Part A effective date: _/? Part B effective date: Month Day Year Month Day Year Are you or another family member covered by another health insurance policy? ? Yes ? No If no, go to Section 5. If yes, complete the following information: Name of family member with other health insurance: Relationship to you: Name, address and phone number of health insurance carrier: Identification Number: Group Number: Effective Date: Month Day Year Type of coverage: ? 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O W o i • O 5 b w 41 N41 m[V m O i 'W?' yN• ° ? m6 y <} OS N Ma O F o; Y P U1 i ,. CARLISLE HOSPITAL 246 PARKER STREET CARLISLE PA 17013 RETURN SERVICE REQUESTED CREOIT CARD PATENT LNTOR4LATION PLEASE CARD TIDE E.\P. D.1TE PAY THIS AMOUNT ACCOUN71WtIBER CARD HOLDER SIGNATLME 013931L PATIENT NAME RONALD C TRITT -- PATIENT NUMBER DISCHARGE / SERVICE DATE 6073985 04/05/99 CURRENT BALANCE BILLING DATE 6,132.30 06/14/99 AGREEMENT AMOUNT PAYMENT DUE DATE .00 07/_05/99 132 6 30 AMOUNT ? . , PAID HERE CHERYL C TRITT CARLISLE HOSPITAL MT ROCK RD 246 PARKER STREET NEWVILLE PA 17241 CARLISLE, PA 17013-3661 1 ?uTIIITUlO?nuu?InllT?ul11 6073985 1 01 1 0 9 11 CK ? PLEASE CHECK HERE AND SHOW NAME/ADDRESS CORRECTION ON flEVERSE SIDE nFTACH HFRF TO ASSURE PROPER CREOIT PLEASE WRITE YOUR PATIENT NUMBER ON YOUR CHECK AND RETURN UPPER PORTION WITH REMITTANCE DATE DESCRIPTION - QUANTITY AMOUNT 04/08/99 BLUE CROSS AUTO C/A I/P 1 2,084.99CR 04/08/99 IV START KIT 9345253 1 3.00 04/08/99 GRADUATE DISP 1 3.00 05/10/99 LATE CHARGE ADJUSTMENT - LAB 0/P 1 6.000R 06/11/99 BLUE CROSS AUTO C/A I/P 1 2,084.99 0 v 1 w r -? ° S ? Vl d S te.. W ' z cl- IMPORTANT MESSAGE RONALD CTITR ITTME WE HAVE BILLED YOUR BLUE CROSS PLAN FOR PATIENT NUMBER 6073985 YOUR RECENT SERVICES AT THE CARLISLE HOSPITAL.TO DATE WE HAVE NOT RECEIVED ACCOUNT SUMMARY PAYMENT.IN ORDER TO CONTAIN COST THE PREVIOUS HOSPITAL MUST EXPECT PAYMENT FROM YOU,IF BALANCE 6,132.30 THE BLUE CROSS PLAN FAILS TO PAY.IF YOU HAVE ANY QUESTIONS PLEASE CALL CHARGES 6.00 717-218-6833. PAYMENTS( OTHER 6 0008 ADJUSTMENTS . CURRENT YOU CAN NOW REACH US AT OUR NEW LOCATION DISCHARGEISERVICE BALCNNCE 6,132.30 DATE 04/05/99 PAYMENT AT 419 STONEHEDGE DR CARLISE PA.OUR NEW AGREEMENT MENT I DUE DATE 07/05/99 PtTE NUMBER IS717-218-8820. :_..p0 PAY I f F < 4 HANFT &KNIGHT, P.C. ATTORNEYS & COUNSELLORS AT LAW Steven Dart, Business Manager Big Spring School District 45 Mt. Rock Road Newville, Pennsylvania 17241 Re: Ronald C. Tritt Our File No. 1346.6 Dear Mr. Dart: Kr-??? m L-n VVII.LIAM A. ADDAMS MICHAEL J. HANFT GREGORY H. KNIGHT LINDSAY' GINGRICFI MACLAY' nuo noon ri'ro ?.v Mw' l?u rY October 15, 2002 EEC i 6 200 IRWIN, r'11:Ki? GH +, t?us? ? Please be advised that I represent Ronald C. Tritt. As you are aware, Mr. Tritt is currently married to Cheryl K. Tritt. As of today's date, Mr. Tritt and Mrs. Tritt have not been formerly divorced. A divorce action has been filed at docket number 2000-4460 Civil Term in the Court of Common Pleas of Cumberland County, but a divorce decree has not been entered by the Court. As I understand it, as such, Mr. Tritt's health insurance coverage through the School District should not have been dropped. Please accept this letter as Mr. Tritt's request that insurance coverage be provided retroactive to July 1, 2002, the date his coverage was stopped.. I trust this letter is self- explanatory. However, should you have any questions or wish to discuss this matter further, please do not hesitate to contact me. Very truly yours, MJH/ cc: Ronald C. Tritt Rebecca R. Hughes, Esquire F.\Itur Fo1<PFimn DocslGrnk:'_003\I3J66sd.Lxyd HANFT & KNIGHT, P.C. Michael J. Hanft 19 BROOKWOOD AVENUE SWIE 106 C:.-ISLE. PA 17013-9 14 2 717.249.5373 FAx 717.249.0457 W. I" FIANFrLAWF1 Rm.COXI LAW OFFICES IRWINMcKNIGHT & HUGHES ROGER B. IRWIV :LIARC0A. MCKVVIGHL (/I JAMES D. HUGHES REBECCA R. HUGHES DOUGLAS G. MILLER WEST POMFRET PROFESSIONAL BUILDING 60 WEST PO11FRET STREET CARLISLE, PEN,VSYLV LVIA 17013-3222 (717) 249-2353 FAX(717) 249-6354 E-MAIL: INHLAWZVSUPERLbFT COM May 1, 2003 HAROLD S. IRWIV (1925-197:) - HAROLD S IRWIN, JR. (1954-1986) 1RW1N,1R97N&1RfY1A' (1956-1986) IRWI .. IRWIV &.V XWGHT (1986-1994) 1R WIN, MCPVIGHT & HUGHES (1994- -) Facsimile 249-0457 and Regular Mail Michael Hanft, Esquire 19 Brookwood Avenue Carlisle, PA 17013 Re: Tritt v. Tritt Dear Michael: Jim recently told me that you and he had discussed the above-captioned case relative to the stalemate in which we seem to find ourselves. The last time we spoke about this case, Mr. Tritt was in your office and I had at that point told you that Mrs. Tritt is more than willing to put Mr. Tritt back on her insurance, make it retroactive back to the time that his insurance coverage stopped, but would only do so upon the signing of a Marriage Settlement Agreement whereby he would assume all responsibility for the home and all the liens associated with the same. Obviously, upon signing a Marriage Settlement Agreement, the parties would soon be divorced. Therefore, your client will have to obtain other health insurance coverage. At that time, you indicated you would talk to Mr. Tritt and that you would get back to me as to his position relative to this offer. To date, I have not heard anything from you. This offer is still outstanding, and Mrs. Tritt will make the insurance coverage retroactive as far back as she can. I am not sure if she can still make it retroactive back to June of last year, but if she is able and the insurance company is willing to do so, she also will cooperate in making the coverage retroactive. Again, once the parties are divorced, Mrs. Tritt cannot provide any further insurance coverage since the family policy will only cover family members. Therefore, your client will have to secure other insurance coverage for himself. Please advise if your client is wilting to proceed in this matter or if we have to litigate this before the Divorce Master. Very truly yours, IRWN, Mc-KNI HT & HUGHES Rebecca ghes RRH:tds cc: Cheryl Tritt . , LAW OFFICES IR MN McKNI GHT & HUGHES ROGER B. IRWIN IWARCUS A. MCKVIGHT. III JAMES D. HUGHES REBECCA R. HUGHES DOUGLAS G. MILLER WEST POMFRET PROFESSIONAL BUILDING 60 WEST POMFRET STREET CARLISLE, PENNSYLVANIA 17013-3222 (717) 249=2353 FAX (717) 249-6354 E-MAIL: IMHLAW@ SUPERNEr.. COM June 26, 2003 MICHAEL HANFT, ESQUIRE 19 BROOKWOOD AVENUE CARLISLE, PA 17013 RE: TRITT v. TRITT Dear Michael: HAROLD S. IR WIN (1925-1977) HAROLD S. IRWIN, JR. (1954-1986) IRWN IRWIN& IRWIN (1956-1986) IRWIN. IRWLV & McKNIGHT (1986-1994) IRWIV. MCKNIGHT & HUGHES (1994- ) On May 1, 2003, I contacted you via correspondence regarding the above-captioned case. You had previously expressed concern to Jim that your client did not have any health insurance. In my correspondence dated May 1, I again relayed to you my client's willingness to put Mr. Tritt back on her insurance as far back retroactively as she can if he will agree to sign a Marriage Settlement Agreement concluding this whole mess. It has been over two months since I heard from you relative to this matter. I do request that we move this along so that both parties can move on with their lives. Very truly yours, HUGHES 7RebeccaZ We RRH:clc cc: Cheryl Tritt ,, GHWRK B?.UE SHIELD MMn owdix V/ -Wlfie Not Cm and elm ShlddAi[or40on Camp Hilt, PA 17089 Ms. Cheryl K. Triti 24 MT Rock Rd. Newville, PA 17241 Dear Ms. Tritt: September 1 Patient Name: Contract Number: Date of Service: Claim Number: Inquiry Number: 8, 2003 Ronald Tritt 197406112 Various Various 03248694334 This is in responseto your inquiry concerning the claims listed below. Enclosed please find Check Number 0030004065, in the amount of 53,100.02 and Check Number 0030006084, in the amount of $400.00. We are issuing these payments to you because The Runout period under your old group coverage has expired for adjustments on the claims listed below: Claim 22046100215000 - DOS 1/29/2002 - charge was 51,556.67 for EDGEPARK SURGICAL INC at P 0 BOX 3509 RANCHO CUCAMGA CA 91729-3509. Claim 2211610807000 - DOS 4/22/2002 - charge was $111.00 for JAY A TOWNSEND at 100 SOUTH HIGH STREET NEWVILLE, Pa 17241-1409. Claim 2211610824000 - DOS 4/24/2002 - charge was 54.00 for JAY A TOWNSEND 100 SOUTH HIGH STREET NEWVILLE PA 17241-1409. Claim 2212110441400 - DOS 4/24/02 - charge was 5283.35 QUEST DIAGNOSTICS at PO BOX 5000, SOUTHEASTERN, PA 19398-5000. Claim 2214410984500 - DOS 5/21/2002 - charge was 5535.00 for MOFFITT PEASE LIM at 1000 N FRONT ST WORMLEYSBURG PA 17043-1034 Claim 2215211426000 - DOS 5/29/02 - charge was $950.00 for MOFFITT PEASE LIM. Claim 2217611372600 - DOS 6/19/2002 - charge was $60.00 for MOFFITT PEASE LIM. If you have any additional questions, please contact us at the number listed below. Sincerely, DALLAS E. AGERTON Customer Service Central Region 1-800-345-3806 •' r Lfl 'a- Er, rm O 1 O O O N ru c.0 a O rm M s O ILI trl cU O l O O O rm O 0 a CHERYL K. TRITT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 00 - 4460 CIVIL RONALD C. TRITT, Defendant IN DIVORCE ORDER OF COURT AND NOW, this ?/!.? day of T t'll 2002, pretrials having been directed to be filed on May 29, 2001, and no pretrials having been received from counsel or the parties, the appointment of the Master is vacated. BY THE COURT, G E ff r, J. CC: Mark D. Schwartz Attorney for Plaintiff Michael J. Hanft Attorney for Defendant C. ? 6. 21,a'- s d mm A& CHERYL K. TRITT VS. RONALD C. TRITT Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 00 - 4460 CIVIL NO. CIVIL 19 IN DIVORCE STATUS SHEET CHERYL K. TRITT, Plaintiff Vs. RONALD C. TRITT, Defendant TO: Mark D. Schwartz Michael J. Hanft IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00 - 4460 CIVIL IN DIVORCE , Attorney for Plaintiff , Attorney for Defendant DATE: Tuesday, January 20, 2001 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. DATE COUNSEL FOR PLAINTIFF ( ) COUNSEL FOR DEFENDANT ( ) NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. LAW OFFICES IRWIN McKNIGHT & HUGHES ROGER B.IRWIN MARCUS A. McKNIGHT. III JAMESD. HUGHES REBECCAR HUGHES AIARKD. SCHWARTZ DOUGLAS G. MILLER WEST POMFRET PROFESSIONAL BUILDING 60 WEST POMFREr STREET CARLISLE, PENNSYLVANIA 17013-3222 (717) 2494353 FAX (717) 249-6354 EMAIL: IMHLAW®SUPERNET.COM HAROLD S. IRWIN (1925-1977) HAROLD S. IRWIN, JR. (1954-1986) 1RWIN,1RWIN& IRWIN (19561986) IRWIN, IRWM&McKNIGHT (1986-1994) IRWIN, MCKMGHT & HUGHES (1994- ) February 8, 2001 E. ROBERT ELICKER, H, ESQ. DIVORCE MASTER'S OFFICE 9 NORTH HANOVER STREET CARLISLE, PA 17013 RE: Cheryl K. Tritt v. Ronald C. Tritt NO. 004460 In Divorce Dear Mr. Elicker: I am enclosing the Discovery Certification in the above-captioned case. If you have any questions, please do not hesitate to contact me. Thank you for your cooperation. Very truly yours, & HUGHES D. Schwartz, Esq. I%MS/min Encl. cc: Michael J. Hanft, Esq. Cheryl K. Tritt CHERYL K. TRITT, Plaintiff VS. RONALD C. TRITT, Defendant TO: Mark D. Schwartz Michael J. Hanft IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00 - 4460 CIVIL IN DIVORCE , Attorney for Plaintiff , Attorney for Defendant DATE: Tuesday, January 20, 2001 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. zoo e DATE COUNSEL' FOR PLAINTIFF (-"tCl COUNSEL FOR DEFENDANT ( ) NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. '°"s l???'sP ? ? 'e7is3aalac ,p?/{ t)1/(???w I Ilk ?d71_l E Cj ;?= TN THE COURT OF COMMON PLEAS OF CLIMBERLAND COUNTY, PENNSYLVANIA CHERYL K. TRITT, CIVIL ACTION - LAW IN DIVORCE Plaintiff VS. RONALD C. MITT, NO. 2000-4460 CIVIL TERK 19 MOTION FOR APPOOT= OF 3T95TER CHERYL K. TRITT (Plaintiff) OXOfc?), moves the court to appoint a master with respect to the following claims: ( X) Divorce ( ) Annulment ( ) Alimony ( ) Alimony Pendenta Lite and in support of the motion states: (X) Distribution of Property ( ) support ( ) Counsel Fees ( ) Costs and Expenses (1) Discovery is complete as to the claims(s) for which the appointment of a mas ter is requested. (2) The defendant (has) (WWWQ appeared in the action (personally) (by his attorney, MICHAEL S. HANFT ,Esquire). (3) The staturory ground(N.) for divorce (is) C gm) 3301(c) (4) Delete the inapplicable paragraph(s): (a) The action is not contested. (b) An agreement has been reached with r espect to the following claims: NONE (c) The action is contested with respect to the following Claims: DIVORCE. DT STRTRUTTON OF PROPERTY. (5) The action m3cses) (does not involve) complex issues of law or fact. i (6) The hearing is expected to takaONE- LF DAY sEhn? (days). (7) Additional information, if any. re evant ,tq the motion: Date: TANUARY R. 2001. S) ORDER APPOINTING MASTER AND NOW 11 19:? Esquire, is appointed master wi respect to tae following claz=s: U By the Ca *: L? d fF i k°: 1-9 Ol - -- IaceJ. rx ??ic ers?i?a F'\User Folder irm Do&l ndocs.OOMU6.6=swm twpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHERYL K. TRITT, Plaintiff/Counterclaim Defendant NO. 2000-4460 CIVIL TERM V. CIVIL ACTION - LAW RONALD C. TRITT, Defendant/Counterclaim Plaintiff IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annuhnent may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pa. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be bome by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHERYL K. TRITT, Plaintiff/Counterclaim Defendant NO. 2000-4460 CIVIL TERM V. CIVIL ACTION - LAW RONALD C. TRITT, Defendant/Counterclaim Plaintiff IN DIVORCE i ` ANSWER AND COUNTERCLAIM AND NOW, this `"C} dayofFebruary,2001, comes the Defendant/CounterclaimPlaintiff, RONALD C. TRITT, by and through his attorney, Michael J. Hanft, Esquire, of the LAW OFFICE OF MICHAEL J. HANFT, and files the following Answer and Counterclaim to the Plaintiff s/Counterclaim Defendant's Complaint and in support thereof avers as follows: ANSWER 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted 6. Admitted. 7. It is specifically denied that the marriage is irretrievably broken. To the contrary, by way of further answer, Defendant/Counterclaim Plaintiff avers that he has been the innocent and injured spouse and that Plaintiff/Counterclaim Defendant has offered such indignities to him as to render his condition intolerable and life burdensome. 8. After reasonable investigation, Defendant/Counterclaim Plaintiff is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph S. The same are therefore specifically denied. WHEREFORE, Defendant/Counterclaim Plaintiff requests this Honorable Court to dismiss Plaintiff s/Counterclaim Defendant's Complaint without cost to him. COUNTERCLAIM COUNTI REQUEST FOR ALIMONY PENDENTE LITE, COUNSEL FEES, COSTS AND EXPENSES UNDER SECTION 3702 OF THE DIVORCE CODE 9. The Counterclaim Plaintiff is RONALD C. TRITT, an adult individual, sui juris, who currently resides at 69 Kutz Road, Carlisle, Cumberland County, Pennsylvania. 10. The Counterclaim Defendant is CHERYL K. TRITT, an adult individual, sui juris, who currently resides at 24 Mt. Rock Road, Newville, Cumberland County, Pennsylvania. 11. Counterclaim Plaintiff is without sufficient assets and income to supporthimself, pay his attorney's fees and the costs and expenses of this action. 12. Counterclaim Defendant has sufficient earning capacity to support the Counterclaim Plaintiff and to pay the Counterclaim Plaintiff s attorney's fees and the costs and expenses of this action. 13. Counterclaim Plaintiff requests the Court to order the Counterclaim Defendant to support the Counterclaim Plaintiff during the pendency of this action and to pay Counterclaim Plaintiffs counsel fees, expenses and the costs of this action, pursuant to Section 3702 of the Divorce Code. COUNT II REQUEST FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502fa1 OF THE DIVORCE CODE 14. The averments in Paragraphs 9 through 10 inclusive of Counterclaim Count I are specifically incorporated by reference as though fully set forth hereinafter. 15. Plaintiff and Defendant have individually or jointly acquired real and personal property during the marriage, in which they individually or jointly have a legal or equitable interest, which marital property is subject to equitable distribution. 16. Plaintiffrequests the Court to determine and equitably distribute, divide or assign said marital property, pursuant to Section 3502(a) of the Divorce Code. COUNT III REQUEST FOR ALIMONY UNDER SECTION 3701 OF THE DIVORCE CODE 17. The averments in Paragraphs 9 through 10 inclusive of Counterclaim Count I are specifically incorporated by reference as though fully set forth hereinafter. 18. Counterclaim Plaintiff lacks sufficient property to provide for his reasonable needs. 19. Counterclaim Plaintiff is unable to sufficiently support himself through appropriate employment. 20. Counterclaim Defendant has sufficient property, assets, and income to provide continuing support for the Counterclaim Plaintiff. 21. Counterclaim Plaintiffrequests the Court to orderthe Counterclaim Defendant to pay alimony to Counterclaim Plaintiff pursuant to Section 3701 of the Divorce Code. WHEREFORE, Counterclaim Plaintiff prays your Honorable Court to enter an Order as follows: (a) Directing Counterclaim Defendant to pay Counterclaim Plaintiff alimony pendente lite, counsel fees, costs, and expenses arising out of this action; (b) Equitably distributing, dividing and assigning the marital property of the parties; (c) Directing Counterclaim Defendant to pay Counterclaim Plaintiff alimony; and (d) Granting such further relief as the Court may determine appropriate and just. Respectfully submitted, LAW OFFICE OF MICHAEL J. HANFT Michael J. Hanft, Efquire Attorney I.D. No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 (717) 249-5373 Attorney for Defendant/Counterclaim Plaintiff VERIFICATION The foregoingAnswer and Counterclaim is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the Answer and Counterclaim and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. Ro ald C. Tritt FAUs, FOldcr\Finn ibis\G.docs2001\134bbans .i.wpd CERTIFICATE OF SERVICE AND NOW, this 14th day of February, 2001, 1, Michael J. Hanft, Esquire, hereby certify that I have this day served the following persons with a copy of the foregoing document, by first class, United States Mail, postage pre-paid, addressed as follows: Mark D. Schwartz, Esquire IRWIN, McKNIGHT & HUGHES West Pomfret Professional Building 60 West Pomfret Street Carlisle, PA 17013-3222 Attorney for Plaintiff/Counterclaim Defendant LAW OFFICE OF MICHAEL J. HANFT L?? rJ P* Michael J. Hanft, squire Attorney ID No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 (717) 249-5373 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHERYL K. TRITT, Plaintiff VS. CIVIL ACTION--LAW No. 2000-4460 CIVIL TERM RONALD C. TRITT, Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Michael J. Hanft, Esquire, accept service of the Complaint in Divorce Pursuant to Section 3301(c) of the Divorce Code in the above-captioned matter on behalf of my client, Ronald C. Tritt, and I certify that I am authorized to do so. Date: J?? (c9P ?c3 c ?G?? 1 C Michael J. Hanft, Es 'wire Attorney ID No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 (717) 249-5373 Attorney for Defendant, Ronald C. Tritt F Wscr Fol&ffi= Dots\Gmdoa 000\13466 ccgt.svcw d f.J CHERYL K. TRITT, Plaintiff V. : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2000- LJYta<i 0VIL TERM RONALD C. TRITT, Defendant IN DIVORCE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree in divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 1-800-990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. CHERYL K. TRITT, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2000- g966 CIVIL TERM RONALD C. TRITT, Defendant IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(c) OF THE DIVORCE CODE NOW comes the plaintiff, Cheryl K. Tritt, by her attorney, Mark D. Schwartz, Esquire, and files this complaint in divorce against the defendant, Ronald C. Tritt, representing as follows: 1. The plaintiff is Cheryl K. Tritt, an adult individual residing at 24 Mt. Rock Road, Newville, Cumberland County, Pennsylvania 17241. 2. The defendant is Ronald C. Tritt, an adult individual residing at 69 Kutz Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were married on July 11, 1987 in Newville, Pennsylvania and separated on May 30, 1998. 5. There have been no prior actions of divorce or for annulment between the parties. 6. There were no children born to this marriage. 7. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 8. The plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WIYEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties. Respectfully submitted, IRWIN, eKNIG & YYUGIES By: Gt-- Mark D. Schwartz, Esquire, Attorney for Plaintiff, Cheryl Y-Tritt West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court Y.D. No. 70216 Date: June ?? 2000 VERIFICATION The foregoing Complaint in Divorce is based upon information which has been gathered by my counsel and me in the preparation of this action. I have read the statements made in this Complaint and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unworn falsification to authorities. C YL K. TRITT Date: June-A7, 2000 CHERYL K. TRITT, Plaintiff V. IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 24100- y960 CIVIL TERM RONALD C. TRITT, Defendant IN DIVORCE PLAINT'IFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. 1 understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verity that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: June 9, 2000 6 C ARYL K. TRITT w _ Q S1 ? V S.r c a C ? V? z`w zS ?n ? C s n CHERYL K. TRITT IN THE COURT OF COMMON PLEAS Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA V. : No: 00-4460 RONALD C. TRITT : CIVIL - LAW Defendant/Petitioner : DIVORCE PETITION FOR SPECIAL RELIEF Your Petitioner is the Defendant in the above-captioned divorce action. Respondent is the Plaintiff in the above-captioned divorce action. Respondent is gainfully employed with the Big Spring School District, having a significant and substantial income from her place of employment. Respondent also has through her place of employment a pension as a result of being an employee of the Big Spring School District. The Petitioner herein is on fixed income, as a result of a disability, whose income is limited. 6. The Petitioner herein has repeatedly requested the Respondent to provide a pension evaluation of Respondent's pension through the Commonwealth of Pennsylvania as a result of her employment with the Big Spring School District. 7. The Respondent has failed to cooperate in said requests. 8. The matter has been brought before the Master, Bob Elicker, who in a letter to both parties on June 14, 2005, noted that Court assistance would be necessary to have this matter go forward. 9. Petitioner believes and therefore avers that it is in the best interests of the parties to keep the divorce moving and that the Respondent be directed to provide the necessary funds in order to have her pension evaluated through Harry Leister. WHEREFORE, Petitioner requests the Court to grant relief as requested. Respectfully submitted: MANCKE, WAGNER & 5PREHA By P. Ric d Ye gner, Esquire ID # 1 ,23 SB 22 orth Front Street Harrisburg, PA 17110 (717) 234-7051 I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 1S Pa.C.S. ification to authorities. DA Section 4404, relating to uns7?1v-k TE: 1' Qt-0 N ? O ,; ?; ? ?- -? - C -;; '?? ? _? 't. T. ?J f i?,? v-' ;t ? ? ? - c.? 'i -?? ^`' -rte YECEIV ED AUG 042005 CHERYL K. TRITT Plaintiff/Respondent V. RONALD C. TRITT Defendant/Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No: 00-4460 CIVIL - LAW DIVORCE QRDER AND NOW, this g day of 2005, upon Petition of Ronald C. Tritt, a Rule is issued upon Cheryl K. Tritt to show cause why ' any, the relief should not be granted. Rule returnable C , oa.? r G° v Luc% it F-- .2 tV o N CHERYL K. TRITT, Plaintiff V RONALD C. TRITT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 20@4-4460 CIVIL TERM aovo IN DIVORCE PRAECIPE TO WITHDRAW APPEARANCE To the Prothonotary: Please withdraw my appearance in the above-referenced matter. IRWIN 1 Dated: By: L Marcu A. Attorney fo I 60 West Po Carlisle, PA. 1 PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter my appearance on behalf of the Plaintiff, Cheryl K. Tritt. WEIGLE & ASSOCIATES, P.C. Dated: ?G Lu. DoU6 By: __?J •.( °'? Richard L. Webber, Jr., Esquir Attorney ID #49634 126 East King Street Shippensburg, PA 17257 (717)532-7388 WEIGLE 6 ASSOCIATES, PC. - ATTORNEYS AT LAW - 126 EAST KING STREET - _°HIPPENSBURG. PA 17257-1397 r ' ?? - r _,_ ??: is-?? CHERYL K. TRITT, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V NO. 00-4460 RONALD C. TRITT, CIVIL ACTION - LAW Defendant/Respondent IN DIVORCE PETITION FOR SPECIAL RELIEF AND NOW, comes the Plaintiff/Petitioner, Cheryl K. Tritt, by and through her attorneys, Richard L. Webber, Jr., Esquire, and Weigle & Associates, P.C, and avers the following: 1. Plaintiff/Petitioner is Cheryl K. Tritt (hereinafter "Wife"), of 24 Mt. Rock Road, Newville, PA 17241. 2. Defendant/Respondent is Ronald C. Tritt (hereinafter "Husband"), of 67 Kutz Road, Carlisle, PA 17015. 3. The parties were married on July 11, 1987 and separated on May 30, 1998. 4. On June 27, 2000, Wife filed a Complaint for Divorce. 5. Wife was employed by the Big Spring School District as a Principal for the Plainfield Elementary School. 6. Wife became eligible for full retirement effective July 1, 2006, having been employed as a teacher for 35 years in the Commonwealth of Pennsylvania teachers system. 7. Wife and Husband presently have health insurance coverage through Wife's former employer, the Big Spring School District. 8. Prior to Wife's retirement, the total cost to Wife to provide insurance coverage for both Husband and Wife was $947.70/year. 9. The total current monthly insurance premium to insure Wife and Husband is $689.65 ($333.46 for Wife and an additional $356.19 for Husband), payable in quarterly installments of $2068.95 each. 10. On or about January 1, 2006 Husband became eligible for Medicare insurance coverage. 11. On or about June 13, 2006 Wife discussed with Husband the amount of the increased health insurance premium. WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSSURG, PA 17257-1397 12. During the same conversation mentioned in Paragraph 11 above, Husband indicated to Wife that he no longer desired to be insured through Wife's health insurance plan, effective July 1, 2006. 13. By prior Order dated October 8, 2003, which amended the Order dated September 19, 2003, Wife is required to maintain health insurance coverage for Husband. 14. Wife believes that Husband may be eligible for some form of supplemental insurance in addition to Medicare. 15. To date, the undersigned counsel has been unable to resolve this issue with P. Richard Wagner, attorney for husband. WHEREFORE, Plaintiff/Petitioner respectfully requests that the Court vacate the prior Orders dated September 19, 2003 and October 8, 2003, effective July 1, 2006, plus any other appropriate relief. Respectfully submitted: Dated: 3 ? r',) 4 WEIGLE & ASSOCIATES, P.C. By: Richard L. Webber, Jr., Esquire Attorney ID #49634 126 East King Street Shippensburg, PA 17257 717-532-7388 WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: 'X13 Ile (o &-mj t Cheryl K. tt WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 n..? < , ? _ r., ?3 ? `.' `„? ? ! J .' .i ?.Y __,? [?_ "?,: SEP 1 4 2006 r CHERYL K. TRITT, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V NO. 00-4460 RONALD C. TRITT, CIVIL ACTION - LAW Defendant/Respondent IN DIVORCE ORDER AND NOW, this day of 2006, upon petition of Cheryl K. Tritt, Plaintiff Petitioner herein, a rule is hereby issued upon the Defendant/Respondent, Ronald C. Tritt, to show cause why if any of the relief requested should not be granted. Rule returnable on? 3 2006 at 5 A M. in courtroom Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. J. chard L. Webber, Jr. Attorney for Plaintiff /Petitioner Richard Wagner Attorney for Defendant/Respondent WEIGLE & ASSOCIATES, PC. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 W rn 4 ck.4 CHERYL K. TRITT, Plaintiff/Petitioner V RONALD C. TRITT, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-4460 CIVIL ACTION - LAW IN DIVORCE ORDER t? AND NOW, this Ck day of M O%Jc.%\4tT , 2006, upon stipulation of Counsel for the parties, it is hereby ORDERED as follows: 1. Defendant/Respondent shall remain enrolled in the health benefit plan provided to Plaintiff/Petitioner through Plaintiff/Petitioner former place of employment i.e. Big Spring School District, pursuant to the prior Order dated October 8, 2003. 2. Plaintiff/Petitioner shall continue to pay the total premium for coverage for Plaintiff/Petitioner and Defendant/Respondent under the health benefit plan. 3. The issue concerning whether Plaintiff/Petitioner is to receive credit for payments made from July 1, 2006 toward the health benefit plan from July 1, 2006 shall be addressed in equitable distribution. 4. Plaintiff/Petitioner shall be eligible for pay status regarding her retirement benefits, which are administered by the Public School Employees' Retirement System (PSERS), subject to Defendant/Respondent's rights under equitable distribution. PSERS shall pay said benefits to Plaintiff/Petitioner, retroactive to June 10, 2006. 5. Plaintiff/Petitioner shall not be eligible to withdraw from PSERS any of her contributions or interest, until further Order of Court. BY THE COURT: li?k ? ? M.L. Ebert, Jr. J. Richard L. Webber, Jr. Attorney for Plaintiff /Petitioner P. Richard Wagner Attorney for Defendant/Respondent WEIGLE & ASSOCIATES. P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397 VA'I't d;?t :i?''J:'{ Z 1 •G ll,'.'V 6 A0 900Z fe d+. ii << i?: J IISHI JCS .f _ CHERYL K. TRITT Plaintiff/Respondent V. RONALD C. TRITT Defendant/Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :NO: 00-4460 CIVIL ACTION -LAW IN DIVORCE PETITION FOR ALIMONY PENDENTE LITE AND NOW, comes the Petitioner, RONALD C. TRITT, by and through his attorneys, Mancke, Wagner, Spreha & McQuillan, and files the following Petition For Alimony Pendente Lite: I . Your Petitioner is the Defendant in the above-captioned divorce action. 2. The Respondent is the Plaintiff in the above-captioned divorce action. 3. The Defendant/Petitioner is a dependant spouse and the Plaintiff/Respondent has earnings sufficient to provide support unto the Petitioner herein. 4. Petitioner requests the Court to enter an Order for alimony pendente lite. 5. The Petitioner has need and the Respondent has the ability to pay pending outcome of the divorce proceeding. 6. The Petitioner herein had on a prior occasion filed an action for alimony pendente lite, which said action was filed October 7, 2003, however, said action was not followed through with on the basis that the Respondent herein was going to provide an immediate resolution of the divorce action which has not been forthcoming. jr WHEREFORE, Petitioner requests the Court to schedule a hearing before the Domestic Relations Office on his Petition For APL. Respectfully submitted, Mancke, Wagner, Spreha & McQuillan . Richard Wagner, =Esquire I.D. #23103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Petitioner Date: 5 ?7 ;? ??' ? ?, f-; ?, 1 t , -_? .? c ?}? i1 }?' - .'..' -y ?-. ci ?? _ ?'- ' ?j? T ?- ;-? _, 1 '` - C,3 ? ?'. ?? ?,,g - CHERYL K. TRITT, THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 00-4460 CIVIL TERM RONALD C. TRITT, IN DIVORCE Defendant/Petitioner PACSES CASE NO: 119105981 ORDER OF COURT AND NOW, this 16th day of April, 2007, upon consideration of the Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shadday on June 14.2007 at 9:00 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 true copy of your most recent Federal Income Tax Return, including W2'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. BY THE COURT, Edgar B. Bayley, President Judge Copies mailed to: Petitioner Respondent P. Richard Wagner, Esq. Richard Webber, Esq. Date of Order: May 16, 2007 * t? &'Y Sh day, nference Officer / 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 ?; ? ?:;? t' ? -r _? j__ " °° ,... _ + 1 L.*i .. ?y L..? -.. ?..., .?? ?' r 1 CHERYL K. TRITT, Plaintiff/Respondent VS. RONALD C. TRITT, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 00-4460 CIVIL TERM IN DIVORCE PACSES Case Number 119105981 ORDER OF COURT AND NOW, this 14th day of June, 2007, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $1395.38 and Respondent's monthly net income/earning capacity is $2708.75, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $255.00 per month payable as follows: $255.00 per month for alimony pendente lite and $0.00 per month on arrears. First payment due: ON OR BEFORE June 30, 2007 in the amount of $397.52. Arrears set at $397.52 as of June 14, 2007. The effective date of the order is May 15, 2007. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C.S.§ 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the PA SCDU to: Ronald C. Tritt. 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 17106-9110 Payments must include the Respondent's PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. cc360 The monthly support obligation includes cash medical support in the amount of $250.00 annually for unreimbursed medical expenses incurred for each spouse. Unreimbursed medical expenses of the oblige that exceeds $250.00 annually shall be allocated between the parties. The party seeking allocation of unreimbursed medical expenses must provide documentation of expenses to the other party no later than March 31St of the year following the calendar year in which the final medical bill to be allocated was received. The unreimbursed medical expenses are to be paid as follows: 0% by Respondent and 100% by Petitioner. (x) Respondent () Petitioner () Neither party to provide medical insurance coverage. Within thirty (30) days after the entry of this Order, the (x) Respondent () Petitioner 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 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 considers 68% of the Respondent's retirement income. This Order further considers a downward deviation due to the Petitioner's additional assets from periodic death benefit payments, paid to the Petitioner from his first wife's death. This Order shall become final twenty (20) 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. Consented: Petitioner Respondent Petitioner's Attorney Respondent's Attorney BY T RT, Edgar B: - a ley, a J. Mailed copies on: June 15, 2007 to: Petitioner Respondent P. Richard Wagner, Esq. Richard Webber, Esq. DRO: R.J. Shadday m - tit t? ?: ' i . ( . . • _, .? 119105981 00-4460 CIVIL ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania CO./City/Dist. of CUMBERLAND Date of Order/Notice 06/15/07 Case Number (See Addendum for case summary) Employer/Withholder's Federal EIN Number PSERS PO BOX 125 HARRISBURG PA 17108-0125 O Original Order/Notice O Amended Order/Notice O Terminate Order/Notice RE: TRITT, CHERYL K. Employee/Obligor's Name (Last, First, MI) 197-40-6112 Employee/Obligor's Social Security Number 6374101254 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. $ 255.00 per month in current support $ 0.00 per month in past-due support Arrears 12 weeks or greater? Dyes ® no $ o . oo per month in current and past-due medical support $ o . oo per month for genetic test costs $ 0.00 per month in other (specify) for a total of $ 255.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 58.8 per weekly pay period. $ 117.(.9 per biweekly pay period (every two weeks). $ 127.50 per semimonthly pay period (twice a month). $ 255. 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 #9 on page 2). If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAMEAND 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 TH OURT: Date of Order: JUN 18 200j \ C'` EDGAR B. BAYLEY, JLNDGE DRO: R.J. SHADDAY Form EN-028 Rev. 1 Service Type M OMBNo.:0970.0154 Worker ID $IATT b 17.00* 0.0 • * z11 91 C5981 • 255•x c 7 ? - 50.35* ?55•x 12• 26•= ', 1 7.69* ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If hecke?l you are required to provide aSopy of this form to yourewloyee. If yotlr employee works in a state that is di erent rrom the state that issued this or er, a copy must be provi to your employee even if the box is not checked. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3.* Reporting the Paydate/Date of Withholding. You must report the paydate/date of wit' iholdii ir, vyl ien serldilig the payment. The paydate/date of withholding is the date on which ainountwas withheld from the employee'so vvages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2317391150 EMPLOYEE'S/OBLIGOR'S NAME: TR2TT, CHERYL K. EMPLOYEE'S CASE IDENTIFIER: 6374101254 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of. 1) the amounts allowed by the Federal Consumer Credit Protection Act (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. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11 Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 Service Type M If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 OMB No.: 0970-0154 Form EN-028 Rev. 1 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: TRITT, CHERYL K. PACKS Case Number 119105981 Plaintiff Name RONALD C. TRITT Docket Attachment Amount 00-4460 CIVIL$ 255.00 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): 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. PACKS 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. Addendum Form EN-028 Rev. 1 Service Type M Worker ID IATT OMB No.: 0970-0154 1 N T _ CD 7 ,:- C. ? -I to CHERYL K. TRITT v. RONALD C. TRITT Please accept this as Domestic Relations Office of hearing de novo. w .4 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE :NO. 004460 CIVIL TERM :IN DIVORCE :PACSES Case Number 119105981 of Appeal from the recommendation of the 14, 2007. Please accept this as a request for a RESPECTF*JLLY SUBMITTED: P ichar gner, Esquire : 23103 2233 North Front Street Harrisburg, PA 17110 717-234-7051 DATE: June 28, 2007 f') ? 1 T? -3- Y r {h?Y V -R In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION RONALD C. TRITT ) Docket Number 00-4460 CIVIL Plaintiff ) vs. ) PACKS Case Number 119105981 CHERYL K. TRITT ) Defendant ) Other State ID Number ORDER OF COURT YOU, RONALD C. TRITT plaintiff defendant p v 7067 CARLISLE PIKE, APT 11, CARLISLE, PA. 17015-8803-11 are ordered to appear at DOMESTIC RELATIONS HEARING RM ?rn -, n DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-30- 1 v7 l.+l before a hearing officer of the Domestic Relations Section, on the AUGUST 20, 2007 at 10:3 0AM 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-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income Statement and the appropriate Expense Statement, if required, attached to this order, completed as required by Rule 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. information relating to professional licenses 7. other: Form CM-509 Rev. 1 Service Type M Worker ID 21302 TRITT V. TRITT PACSES Case Number: 119105981 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest and/or enter an interim support order. If paternity is an issue, the court shall 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. Date of Order: 7--1-) -- j BY 7TOURT: W ,, \ G I JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE-HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. 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 Rev. Service Type M Worker ID 21302 ?.? ? ?? ?: y ? a .? _ ?: ?.. c.a ? ?? -; ? _';;. ?? ? .= 1??.. •' r? G; C? ,. N I' In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION RONALD C. TRITT ) Docket Number 00-4460 CIVIL Plaintiff ) vs. ) PACSES Case Number 119105981 CHERYL K. TRITT ) Defendant ) Other State ID Number ORDER OF COURT You, CHERYL K. TRITT plaintiff/defendant of 24 MT ROCK RD, NEWVILLE, PA. 17241-9413-24 are ordered to appear at DOMESTIC RELATIONS HEARING RM ° -2 ?, -? ^ rte-' DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-x13 before a hearing officer of the Domestic Relations Section, on the AUGUST 2 0, 2007 at 10 : 3 OAM for a hearing. L v cn W You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income Statement and the appropriate Expense Statement, if required, attached to this order, completed as required by Rule 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. information relating to professional licenses 7. other: Service Type M Form CM-509 Rev. 1 Worker ID 21302 'r -• TRITT V. TRITT PACSES Case Number: 119105981 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest and/or enter an interim support order. If paternity is an issue, the court shall 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. Date of Order: BY THE COURT: Q.,', W?C& JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE-HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. 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 Rev. I Service Type M Worker ID 21302 { N vd WII • CHERYL K. TRITT, Plaintiff/Petitioner V RONALD C. TRITT, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-4460 CIVIL ACTION - LAW IN DIVORCE PETITION FOR ENTRY OF STIPULATION AND NOW, comes the Plaintiff/Petitioner, Cheryl K. Tritt, by and through her attorneys, Richard L. Webber, Jr., Esquire, and Weigle & Associates, P.C, and avers the following: 1. Plaintiff/Petitioner is Cheryl K. Tritt (hereinafter "Wife"), of 24 Mt. Rock Road, Newville, PA 17241. 2. Defendant/Respondent is Ronald C. Tritt (hereinafter "Husband"), of 7067 Carlisle Pike, Apt. 11, Carlisle, PA 17013. 3. The parties were married on July 11, 1987 and separated on May 30, 1998. 4. On June 27, 2000, Wife filed a Complaint for Divorce. 5. Wife and Husband presently have health insurance coverage through Wife's former employer, the Big Spring School District. 6. By Order entered by the Honorable M.L. Ebert dated November 9, 2006, specifically, paragraphs 1 and 2, Wife is required to maintain health insurance coverage for Husband. 7. The parties have entered a Stipulation for Court Order, attached hereto relating to heath insurance coverage, and Petitioner desires that it be incorporated as an Order. WHEREFORE, Plaintiff/Petitioner respectfully requests that the Court enter an Order incorporating the terms of the attached Stipulation. Respectfully submitted: WEIGLE & ASSOCIATES, P.C. Dated: By: Richard L. Webber, Jr., Esquire Attorney for Plaintiff/Petitioner Attorney ID #49634 126 East King Street Shippensburg, PA 17257 717-532-7388 WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: ?' x--0/0 7 Cheryl K. ritt WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 HU6 CHERYL K. TRITT, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V NO. 00-4460 RONALD C. TRITT, CIVIL ACTION - LAW Defendant/Respondent IN DIVORCE STIPULATION FOR COURT ORDER Cheryl K. Tritt, Plaintiff%Petitiouer (Wife) and Ronald C. Ttitt, Defendant/Respondent (Husband) hereby agree and stipulate as follows- 1.. Wife shall pay directly to Husband the sum of $ 350.00 per month towards his health insurance coverage in lieu of Wife maintaining health insurance coverage for Husband through her prior employer, Big Spring School District.. 2. The Court may enter an Order as follows: ORDER AND NOW, this day of , 2007, upon consideration of the attached Petition and Stipulation for Court Order, paragraphs 1 and 2 of the Order of Court dated November 9, 2006 are hereby VACA`Y D. Plaintiff/Petitioner shall pay directly to Defendant/Respondent the sum of $350.00 per month towards his health insurance coverage effective July 1, 2007 and continuing the first day of each month thereafter, until the entry of a Decree in Divorce or further Order of Court. Big Spring School District shall terminate health insurance coverage for Defendant/Respondent Ronald C. Tritt, effective July I , 2007. Dcfendant/Respondent shall execute any documents required by the Big Spring School District in order to effectuate the tenns of this Agreement. Any issues relating to whether Plaintiff/Petitioner is to receive credit for payments made to Defendant/Respondent pursuant to this Order shall be addressed in equitable distribution, AU6. I? ZUUI 1Z:Z4NN1 W91919 & NSSOCIat?S OUzj XXzJr,--,7ff- 0- 1-6 7 Cheryl . Tri tt Plaintiff/Petitioner WEIGLE & ASSOCIATES, P..C.. /,77 By. Uc/ Richard L. Webber, Jr. Esq. Attorney for Plaintiff/Petitioner 126 East King Street Shippensburg, PA 1.7257 (717) 532-7388 N0-1d00 N- 4 Ronald C. Tritt Defendant/Respondent MANCKE, WAGNER, SPREHA AND MCQUILL4A j_ RjUwrcMagner, Esq. Attorney for Defendant/Respondent 2233 North Front Street Harrisburg, PA 17110 (717) 2347051 s- - ?. y rZ 11 `' re, .a ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 08/21/07 Case Number (See Addendum for case summary) 119105981 0Original Order/Notice 00-4460 CIVIL XQ Amended Order/Notice O Terminate Order/Notice Employer/withholder's Federal EIN Number PSERS PO BOX 125 HARRISBURG PA 17108-0125 RE: TRITT, CHERYL K. Employee/Obligor's Name (Last, First, MI) 197-40-6112 Employee/Obligor's Social Security Number 6374101254 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. $ 832. op per month in current support $ 5o . oo per month in past-due support Arrears 12 weeks or greater? Oyes () no $ 0. 00 per month in current and past-due medical support $ o . 00 per month for genetic test costs $ 0. 00 per month in other (specify) for a total of $ 882.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 203.54 per weekly pay period. $ 407.08,per biweekly pay period (every two weeks). $ _ 441. go per semimonthly pay period (twice a month). $ 882. 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 #9 on page 2). If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: 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. BY T URT: Date of Order: AUG 2 2 2007 `r Tick V L)2? EDGAR B. BAYU DRO: R.J. SHADDAY Form EN-028 Rev. 1 Service Type M OMB No.: 0970-0154 Worker I D $ IATT 832 . C? x 7 ?? ? ? ,, ? Pa ?:. x ..ry ,,?. rt?* ? ^ ? u ?.i ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If heck you are required. to provide a opy of this form to your m loyee. If yo r employee works in g state that is diFerent from the state that issued this o er, a copy must be provic?edpto your emp?oyee even if the box is not checked. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employeelobligor'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. . 3.* RepOrtinr 11 avill it file paydate/date of withholding is the date on which amount wm withheld from the employee's wages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employeelobligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employeelobligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR. 2317391150 EMPLOYEE'S/OBLIGOR'S NAME: TRITT CHERYL K. EMPLOYEE'S CASE IDENTIFIER: 6374101254 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of. 1) the amounts allowed by the Federal Consumer Credit Protection Act 0 5 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. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Submitted By: If you or your employeelobligor have any questions, DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT 13 N. HANOVER ST P.Q. BOX 320 CARLISLE PA 17013 Service Type m by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 OMB No.: 0970-0154 Form EN-028 Rev. 1 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: TRITT, CHERYL K. PACKS Case Number 119105981 PACKS Case Number Plaintiff Name Plaintiff Name RONALD C. TRITT Docket Attachment Amount Docket Attachment Amount 00-4460 CIVIL$ 882.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available identified above in any health insurance coverage available through the employee's/obligor's employment. through the employee's/obligor's employment. PACSES Case Number Plaintiff Name ? 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. Docket Attachment Amount $ 0.00 ? 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) ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available identified above in any health insurance coverage available through the employee's/obligor's employment. through the employee's/obligor's employment. Addendum Form EN-028 Rev. Service Type ly Worker ID $IATT OMB No.: 0970-0154 C ? rv c.? 0 { CL3 ? 7 0 _ - I CHERYL K. TRITT, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA V. : DOMESTIC RELATIONS SECTION RONALD C. TRITT, PACSES NO. 119105981 Defendant/Petitioner DOCKET NO. 00-4460 CIVIL INDEX OF EXHIBITS Respondent's Exhibit No. 1 - Income statement Respondent's Exhibit No. 2 - 2006 federal tax return Respondent's Exhibit No. 3 - Retirement valuation Respondent's Exhibit No. 4 - Stipulation for court order i i CHERYL K. TRITT, Plaintiff/Respondent v RONALD C. TRITT, Defendant/Petitioner :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO. 00-4460 :CIVIL ACTION - LAW :IN DIVORCE Income Statement for Plaintiff Cheryl K. Tritt Section I: Income and Insurance Employer: Retired. See attached Exhibit A from PSERS dated July 2007. Address: Type of Work: Pay Period: Gross Pay per Pay Period: Net Pay per Pay Period: _ goal Other Income: (1) Dividends from Van Kampen $61.00 per year (2) Church Organist - income received in early 2007. See attached Exhibit B. Section II: Compan y Policy # Coverage H W C Hospital Blue Cross Keystone Health Plan Y VV80077497000 _ X Other _ Medical Blue Shield Other Health/Accident Dental Other WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 VERIFICATION I verify that the statements made in the foregoing Income Statement for Plaintiff Cheryl K. Tritt 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: J?--,0l b7 J'a Cheryl K. riff WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 l.U1Vl1V1UlNW1~AL1h Ur YtIN1NJYLVH1N1H PUBLIC SCHOOL EMPLOYEES' RETIREMENT SYSTEM July 2007 Toll-Free - 1-888-773-7748 (1-888-PSERS4U) Local-717-787-8540 Web Address: www.nsers.state.na.us Mailing Address PO Box 125 Harrisburg PA 17108-0125 CHERYL K TRITT 24 MT ROCK RD NEWVILLE PA 17241-0000 S.S. # XXX-XX-6112 Dear CHERYL K TRITT: Building Location 5 North 5th Street Harrisburg PA The amount of your monthly benefit from the Public School Employees' Retirement System (PSERS) will change effective July 31, 2007. For your information, the following is a breakdown of the payment you will receive shortly: Explanation July 31, 2007 Benefit Gross Benefit Amount $ 4,958.74 (-) Federal Withholding $ 1,075.27 (-) Health Insurance $ 0.00 (-) Tax Levy $ 0.00 (-) Child Support $ 255.00 Net Benefit Amount $ 3,628.47 ( + ) Non-taxable Premium Assistance $ 100.00 Adjusted Net Benefit $ 3,728.47 As a reminder, you will receive this type of benefit breakdown letter each time there is a change in the amount of your gross and/or net benefit amount. If you wish to access information about your benefit breakdown in other months when a change does not occur, you may do so on-line at the PSERS website www.psers.state.pa.us after establishing a secure Inter&ction member account by following the directions provided. If you have any questions, please contact the PSERS Member Service Center by calling toll-free 1-888-773-7748 (1-888-PSERS4U); Harrisburg local callers, please use 717-787-8540. For your convenience, the Member Service Center is staffed each business day from 7:30 a.m. to 5:00 p.m. To contact PSERS by e-mail, use the following address: ra-ps-contacl@slate.pa.us. J ubeie Sdwof &n pec#m' ,I`&tywment S yitern OL00061122390 First United Presbyterian Church 597 Em to ee SSN Status (Fed/State) Allowances/Extra Ghery,•K Tritt, 24 Mt Rock Road, Newville, PA 17241 197-40-6112 Married/Withhold Fed-2/0/PA-0/0 Pay Period: 12/16/2006 -12/3112006 Pay Date: 12/27/2006 Earnings and Hours Qty Rate Current YTD Amounts Salary 471.00 3,768.00 Taxes Current YTD Amounts Local Income Tax -7.77 -62.16 Social Security Employee -29.21 -233.62 Medicare Employee -6.83 -54.64 PA - Withholding -14.46 -115.68 -58.27 -466.10 Net Pay 412.73 3,301.90 First United Presbyterian Church, 111 Big Spring Ave., Newville, PA 17241 717-776-7525 First United Presbyterian Church 6092 Employee SSN Status (Fed/State) Allowances/Extra Cheryl K Tritt, 24 Mt Rock Road, Newville, PA 17241 197-40-6112 Married/Withhold Fed-2I01PA-0/0 Pay Period: 03/16/2007 - 03/31/2007 Pay Date: 03/3012007 Earnings and Hours Qty Rate Current YTD Amounts Music Director Salary 488.54 2,931.24 Taxes Current YTD Amounts Local Income Tax -8.06 -48.36 Social Security Employee -30.29 -181.74 Medicare Employee -7.08 -42.50 PA - Withholding -15.00 -90.00 Occup. Tax -10.00 -60.43 -372.60 Net Pay 428.11 2,558.64 First United Presbyterian Church, 111 Big Spring Ave., Newville, PA 17241 717-776-7525 ?r r ,? a 0 t Department of the Treasury-Internal Revenue Service 220 U.S. Individual Income Tax Return I (10) IRS Use Only-Do not write or staple in this space. 1_r%- n1 Anna ..B.>.., 1-1-i- 9nna -qi- 20 OMB No. 1545-0074 Label 8D S28 95 454390 Your social security number (See I M l instructions tai "L K TWIT on page 16.) R Spouse's social security number Use the IRS 24 MOUNT ROCK RD S 7 - : 3/ : ae 5 label. NEWYILLE PA 17241-9413 no. You must enter Otherwise, please print I& your SSN(s) above. e or type. Checking a box below will not Presidential change your tax or refund. Election Campaign Check here if you, or your spouse if filing jointly, want $3 to go to this fund (see page 16) ? ? You ? Spouse 1 ? Single 4 ? Head of household (with qualifying person). (See page 17.) If Filing Status 2 ? arried filing jointly (even if only one had income) the qualifying person is a child but not your dependent, enter Check only 3 P Married filing separately. Enter spouse's SSN above this child's name here. ? one box. and full name here. ? 5 ? Qualifying widow(er) with dependent child (see page 17) Exemptions If more than four dependents, see page 19. Income Attach Form(s) W-2 here. Also attach Forms W-2G and 1099-R if tax was withheld. If you did not get a W-2, see page 23. Enclose, but do not attach, any payment. Also, please use Form 1040-V. Gross fee-basis government officials. Attach Form 2106 or 2106-EZ Income 25 Health savings account deduction. Attach Form 8889. 26 Moving expenses. Attach Form 3903 27 One-half of self-employment tax. Attach Schedule SE . 28 Self-employed SEP, SIMPLE, and qualified plans . 29 Self-employed health insurance deduction (see page 29) 30 Penalty on early withdrawal of savings . 31a Alimony paid b Recipient's SSN ? 32 IRA deduction (see page 31) . . . , . . 33 Student loan interest deduction (see page 33) . 34 Jury duty pay you gave to your employer . . 35 Domestic production activities deduction. Attach Form 8903 36 Add lines 23 through 31 a and 32 through 35 . . . . 37 Subtract line 36 from line 22. This is your adjusted gross 6a Yourself. If someone can claim you as a dependent, do not check box 6a b ? spouse . . . . . . . . . . . . . . . . . . . . . c Dependents: (1) First name Last name (2) Dependent's social security number (3) Dependent's relationship to you (4) d qualifying child for child tax credit see page 19 d Total number of exemptions claimed 7 Wages, salaries, tips, etc. Attach Form(s) W-2 . . . . . . . . . . . 8a Taxable interest. Attach Schedule B if required . . . . . . . . . . b Tax-exempt interest. Do not include on line Sa . . . 8b 9a Ordinary dividends. Attach Schedule B if required . . b Qualified dividends (see page 23) . . . . . . . 9b 10 Taxable refunds, credits, or offsets of state and local income taxes (see page 24) 11 Alimony received . . . . . . . . . . . . . . . . . . . . 12 Business income or (loss). Attach Schedule C or C-EZ . . . . . . . . . 13 Capital gain or (loss). Attach Schedule D if required. If not required, check here ? ? 14 Other gains or (losses). Attach Form 4797 . . . . . . . . . 15a IRA distributions 15a b Taxable amount (see page 25) 16a Pensions and annuities 163 293 6? b Taxable amount (see page 26) 17 Rental real estate, royalties, partnerships, S corporations, trusts, etc. Attach Schedule E 18 Farm income or (loss). Attach Schedule F . . .. . . . . . . . . . . . 19 Unemployment compensation . . . . 20a Social security benefits 20a b Taxable amount (seepage 27) 21 Other income. List type and amount (see page 29) .................................... 22 Add the amounts in the far right column for lines 7 through 21. This is your total income ? 23 Archer MSA deduction. Attach Form 8853 . . . . . 23 Adjusted 24 Certain business expenses of reservists, performing artists, and For Disclosure, Privacy Act, and Paperwork Reduction Act Notice, see page 80. 24 25 26 27 28 29 30 31a 32 33 34 35 7 Sa 9a 10 11 12 13 14 15b 16b 17 18 19 21 22 on 6a and 6b No. of children on 6c who: • lived with you • did not live with you due to divorce or separation (see page 20) Dependents on 6c not entered above Add numbers onl lines above ? a:?X -0-7 VJ 36 income ? 37 O Cat. No. 113208 Form 1040 (2006) ?....... ,nen r9nnril Page 2 . . . 38 Amount from line 37 (adjusted gross income) T 38 3 ' . . . . . . . . . ax and 39a Check El You were born before January 2, 1942, El Blind. Total boxes Credits if: { ? spouse was born before January 2, 1942, ? Blind. I checked ? 39a Standard b If your spouse itemizes on a separate return or you were adual-status alien, see page 34 and check here ?39b Deduction 40 It ed deductions (from Schedule A) or your standard deduction (see left margin) . i 0 7 ?O for- z em btract line 40 from line 38 41 S 41 • People who checked any box on line u 42 If tine 38 is over $112,875, or you provided housing to a person displaced by Hurricane Katrina, 300 by the total number of exemptions claimed on line 6d multiply $3 e 36 Otherwise s e 42 360 - 39a or 39b or , , . e pag enter -0- If line 42 is more than line 41 Subtract line 42 from line 41 xable income 43 T 43 who can be claimed as a , . . a Check if any taxis from: a ? Form(s) 8814 b ? Form 4972 . . . e 36) x (see a 44 T 44 dependent, 34 . p g a Attach Form 6251 ative minimum tax (see page 39) 45 Alt 45 ^ . see page . . . . . . . . ern . . ? 46 Add lines 44 and 45 46 s • All others: . . . . . . . . . . . . Attach Form 1116 if required x credit i t 47 F 47 . . . Single or Married filing . . . . . ore gn a Attach Form 2441 endent care expenses hild and de dit f r 48 C 48 separately, $5 150 . p o re c Attach Schedule R or the disabled 49 Credit for the elderl 49 , . . y Attach Form 8863 tio credits 50 Ed 50 Married filing y or t . . . . . . uca n . Attach Form 8880 s contributions credit 51 Retirement savin 51 Qu l fying , . g Attach Form 5695 credits 52 Residential ener 52 widow(er), $10,300 . . . . gy . Attach Form 8901 if required e 42) a 53 Child tax credit (see 53 Head of g . p 54 Credits from: a E) Form 8396 b El Form 8839 c El Form 8859 `` 4 household, $7 550 55 Other credits: a ? Form 3800 b ? Form 8801 c ? Form 55 , These are your total credits . . 56 Add lines 47 through 55 . . . . . . . . 56 . 57 Subtract line 56 from line 46, If line 56 is more than line 46, enter -0- , . ? 57 . Attach Schedule SE ment t x lf- m l 58 S 58 . . . . . . . . . . . . . . oy a . e p e Other Attach Form 4137 and Medicare tax on tip income not reported to employer rit ial 59 S 59 . , . y oc secu Taxes etc Attach Form 5329 if required other qualified retirement plans 60 Additional tax on IRAs 60 , , . , box 9 ments from Form(s) W-2 a ed income credit 61 Adv 61 . . . . . . . , p y ance earn 62 Household employment taxes. Attach Schedule H . . . . . . . . . . . . 62 63 Add lines 57 through 62. This is your total tax . ? 63 64 Federal income tax withheld from Forms W-2 and 1099 64 s 1 . . Payments 65 2006 estimated tax payments and amount applied from 2005 return 65 rned income credit (EIC) 66a E If h 66a ave a you qual ifying chi, attach d EIC S h l . . a b Nontaxable combat pay election 1111- L66b urity and tier 1 RRTA tax withheld (see page 60) 67 Excess social se 67 u . c e e c Attach Form 8812 68 Additional child tax credit 68 , , , . , . 669 Amount paid with request for extension to file (see page 60) 69 - ments from: a ? Form 2439 b ? Form 4136 c ? Form 8985 70 Pa 70 . y 71 Credit for federal telephone excise tax paid. Attach Form 8913 if required 71 72 Add lines 64, 65, 66a, and 67 through 71. These are your total paym ents . ? 72 Q Q? This is the amount you overpaid subtract line 63 from line 72 73 If line 72 is more than line 63 73 . , Refund it? 74a Amount of line 73 you want refunded to you. If Form 8888 is attached, check here ? ? Di t d 74a rec epos ? c Type: ? Checking ? Savings See page 61 ? b Routing number and fill in 74b, 74c, and 74d, ? d Account number or Form 8888. 75 Amount of line 73 you want applied to our 2007 estimated tax ? 75 y? see page 62 ? For details on how to pay Subtract line 72 from line 63 ou owe Amount 76 Amount 76 , // _ , . . y Yeu Owe 77 Estimated tax penalty (see page 62) . . . . _._ ?77 Third Party Do you want to allow another person to discuss this return with the IRS (see page 63)? ? Yes. Complete the following. ? No Designee Designee's Phone Personal identification name ? no. ? ( ) number (PIN), ? - Sign Under penalties of perjury, I declare that I have examined this return and accompanying schedules and statements, and to the best of my knowledge and belief, they are true, correct, and complete. Declaration of preparer (other than taxpayer) is based on all information of which preparer has any knowledge. Here Joint return? You si ature Date Your occupation Daytime phone number p See page 17. / / G 7 X77 rre /7) Z--%.?4 Keep a copy Spouse's ature. If a joint return, both must sign. Date Spouse's occupation for your records. --- - - Paid Preparer's Date Check if signature self-employed El Preparer's Firm's name (or EIN Use Only ? yours if self-employed),, ,Hrot? ??H 71P -1. Phone no. Preparer's SSN or PTIN Form 1040 (2006) SCHEDULES A&B Schedule A-Itemized Deductions OMB No. 1545-D074 (Form 1040) raj O OO (Schedule B is on back) (S Department of the Treasury Internal Revenue Service (10) ? Attach to Form 1040. ? See Instructions for Schedules A&B (Form 1040). Attachment Sequence No. 07 Name(s) shown on Form 1040 V f Your social security number Imo. i Ckpv?el `fy Medical Caution. Do not include expenses reimbursed or paid by others. and 1 Medical and dental expenses (see page A-1) 1 (J Dental 2 Enter amount from Form 1040, line 38 2 Expenses 3 Multiply line 2 by 7.5% (.075). . . . . . . . 3 4 Subtract line 3 from line 1. If line 3 is more than line 1, enter -0-. 4 Q Taxes You 5 State and local income taxes 5 S . . . . . . . . Paid 6 Real estate taxes (see page A-3) 6 , . . . , 7 Personal property taxes (S 7 . . . . . . . . ee page A-3.) 8 Other taxes. List type and amount ?_____________________ ---------------------------------------------------------- 9 Add lines 5 through 8 . . . . . . . . . . . . . . . . . . . 9 17tD? l Interest 10 Home mortgage interest and points reported to you on Form 1098 10 W -71 You Paid 11 Home mortgage interest not reported to you on Form 1098. If paid (See to the person from whom you bought the home, see page A-3 page A-3.) and show that person's name, identifying no., and address ? 'r j Note 11 . ---------------------------------------------------------------- Personal 12 Points not reported to you on Form 1098. See page A-4 ' interest is for special rules 12 ? , . . . . . . . . . . . not deductible. 13 Investment interest. Attach Form 4952 if required. (See page A-4.) . . . . . . . . 13 14 Add lines 10 through 13 1.4 7a-' --- Gifts to 15 Gifts by cash or check. If you made any gift of $250 or 035 - ;i Charity more see page A-5 15 s , . . . . . . . . . . . . If you made a 16 Other than by cash or check. If any gift of $250 or more, gift and got a see page A-5. You must attach Form 8283 if over $500 16 benefit for it, 17 Carryover from prior year . . . . . . . . . . 17 ,< see page A-4. s( 18 Add lines 15 through 17 18 Casualty and Theft Losses 19 Casualty or theft loss(es). Attach Form 4684. (See page A-6.) . 19 Job Expenses 20 Unreimbursed employee expenses job travel, union ' 4 and Certain dues, job education, etc. Attach Form 2106 or 2106-EZ u Miscellaneous if required. (See page A-6.) ? 20 ----------------------------- Deductions 21 Tax preparation fees. . . . . . . . . 21 . (See 22 Other expenses-investment, safe deposit box, etc. List page A-6.) type and amount ?-------------------------------•--.. --• <r;? LL ---------------------------------------------------------------- 23 Add lines 20 through 22 . . . . . . 23 . . 24 Enter amount from Form 1040, line 38 24 25 Multiply line 24 by 2% (.02) 25 ' D 26 Subtract line 25 from line 23. If line 25 is more than line 2 3, en ter -0- 26 Other 27 Other-from list on page A-7. List type and amount ? ------------------------------ - Miscellaneous Deductions 27 Total 28 Is Form 1040, line 38, over $150,500 (over $75,250 if married filing separately)? Itemized ? No. Your deduction is not limited. Add the amounts in the far right column a Deductions for lines 4 through 27. Also, enter this amount on Form 1040, line 40. ? 28 / 7 ? Yes. Your deduction may be limited. See page A-7 for the amount to enter. 29 If you elect to itemize deductions even though they are less than your standard deduction, check here I- LJ For Paperwork Reduction Act Notice, see Form 1040 instructions. Cat. No. 1133OX Schedule A (Form 1040) 2006 Schedules A&B (Form 1040) 2006 OMB No. 1545-0074 Page 2 Name(s) h own on Form 1040. Do not Ehe4Y) 1!?.Tr name and social security number if shown on other side. Your social security number Attachmt Schedule B-Interest and Ordinary Dividends S eque ceNo. 08 1 List name of payer. If any interest is from a seller-financed mortgage and the Amount Part I buyer used the property as a personal residence, see page B-1 and list this Interest interest first. Also, show that buyer's social security number and address ? (See page B-1 ------ --- -- -------- --------------- ) and the (?31/IlYI 5--?lJUJ1/ _-- IlALC ---------------------------------------- C instructions for -------------------•--------------------•------------ •------------------------ ------ Form 1040, line 8a ) --------------------------------------------------------- - -------------------------------- . ----------------------------------------•--------------------------------------------------- ------------------------------------------------------------------------------------------ - 1 ---------- ------ -------------------------------- ------------------------•-------------- Note. If you received a Form 1099-INT Form -----•------------------------------------------------ ------------------------------------- , 1099-OID, or ------------------------------------------- ------------------------------------------------ substitute statement from a brokerage firm ----•----------------------------- ------ --------------- ---------------------------------- , list the firm's ---------------------------------------- -------------------------------------------------- name as the ----------------------------------•-----•-•-•------------•--------•---•-----•---•---•---.... payer and enter the total interest ---------------------------------------------------------------------- --------------------- shown on that 2 Add the amounts on line 1 . . . . . . . . . . . . . . . . . 2 form. 3 Excludable interest on series EE and.l U.S. savings bonds issued after 1989. Attach Form 8815 3 - 4 Subtract line 3 from line 2. Enter the result here and on Form 1040, line 8a ? 4 Q 0 Note. If line 4 is over $1,500, you must complete Part III. Amount 5 List name of payer ? ------------------------------- - - --- --------------------------- Part II -------- - - ------------------------------------------------------------------------ Ordinary ------. ----------------------------------------------------------- (41 60 Dividends -------------------------------------------------------------------------------------------- (See page B-1 -------------------------------------------------------------------------------------------- and the instructions for --------------------- --------------- - -- -------------------------------------------------- Form 1040, line 9a.) ---------------------------•--------------------------------------- ------------------------ ---------------------------•------------•--------------------------------------------------- -------------------------------------------------------------------------------------------- ------------------- -----•••-•-----••----------------• Note. If you i d F 5 orm Y rece ve a 1099-DIV or ------------------- - --------------- - --------- - ------------------------------------------- substitute statement from ---------------- ------------ ------------------------------------- --------------------- b k fi a ro erage rm, list the firm's ---------------------------------------------------------- --------------------------- name as the -----•----•-------•-----------------•-----------.....--------------------------------------- payer and enter ---------------------------•---------------------------------------------------------------- the ordi nary dividends shown -----------------------------------------------------------------------------------•----- on that form. -------------------------------------------------------------------------------------------- 6 Add the amounts on line 5. Enter the total here and on Form 1040, line 9a : ? 6 G, / Note. If line 6 is over $1,500, you must complete Part III. You must complete this part if you (a) had over $1,500 of taxable interest or ordinary dividends; or (b) had Yes No Part III a foreign account; or (c) received a distribution from, or were a grantor of, or a transferor to, a foreign trust. Foreign 7a At any time during 2006, did you have an interest in or a signature or other authority over a financial } Accounts account in a foreign country, such as a bank account, securities account, or other financial account? and Trusts See page B-2 for exceptions and filing requirements for Form TD F 90-22.1. . . . . . . (See b If "Yes," enter the name of the foreign country ? ------------------------------------------------------ page B-2.) 8 During 2006, did you receive a distribution from, or were you the grantor of, or transferor to, a u.:. foreign trust? If "Yes," you may have to file Form 3520. See page B-2 For Paperwork Reduction Act Notice, see Form 1040 instructions. Schedule B (Form 1040) 2006 • SCHEDULE C Profit or Loss From Business (Form 1040) (Sole Proprietorship) ? Partnerships, joint ventures, etc., must file Form 1065 or 1065-13. Department of the Treasury _ _ _ _ _ ----- _ OMB No. 1545-0074 ,2006 Attachment _ _ Name of proprietor. Social security number (SSN) Ch t 19-/ i/0 ;6//;) A Principal busine or profession, i cluding product or service (see page C-2 of the instructions) B Enter code from pages C-8, 9, & 10 C?5 ? c ? U C Business name. If no separate business name, leave blank. D Employer ID number (EIN), if any _ E Business address (including suite or room no.) 10- _---- _------------------------------------------- _________ City, town or post office, state, and ZIP code i?tn l?t° VA F Accounting method: (1) Pte?C:ash (2) ? Accrual (3) ? Other (specify) ? ------- _----------------------- __rr__,,!?______-______ G Did you "materially participate" in the operation of this business during 2006? If "No," see page C-3 for limit on losses a es ? No H If you started or acquired this business during 2006, check here ? ? 1 Gross receipts or sales. Caution. If this income was reported to you on Form W-2 and the "Statutory employee" box on that form was checked, see page C-3 and check here . . . . . . 0, 0 1 T 2 Returns and allowances . . . . . . . . . . . . . . . . . . . . . . . . 2 3 Subtract line 2 from line 1 . . . . . . . . . . . . . . . . . . . . . . . 3 4 Cost of goods sold (from line 42 on page 2) . . . . . . . . . . . . . . . . . . 4 5 Gross profit. Subtract line 4 from line 3 . . . . . . . . . . . . . . . . . . . . 5 6 Other income, including federal and state gasoline or fuel tax credit or refund (see page C-3). . . 6 7 Gross income. Add lines 5 and 6 . ? 7 • Expenses. Enter expenses for business use of vour home only on line 30. 8 Advertising . . . . 8 -? 18 Office expense 18 9 Car and truck expenses (see . . . . 19 Pension and profit-sharing plans 19 „ page C-4) . 9 w 20 Rent or lease (see page C-5): . . . 10 Commissions and fees 10 a Vehicles machinery and equipment 20a 11 Contract labor (see page C-4) 11 , , , b Other business property 20b 12 Depletion . . . 12 . . , 21 Repairs and maintenance 21 13 D i ti d ti 179 . . 22 Supplies (not included in Part III) . 22 eprec a on an sec on expense deduction (not 23 Taxes and licenses . . . . 23 included in Part III) (see page C-4) . . . . 13 24 Travel, meals, and entertainment: a Travel 242 14 Employee benefit programs (other than on line 19). 14 . . . . . . . , b Deductible meals and entertainment (see page C-6) 2413 15 Insurance (other than health) 15 25 Utilities 25 16 Interest: -' . . . . . . . 26 Wages (less employment credits) . 26 a Mortgage (paid to banks etc.) 16a 27 Other ex enses (from line 8 on , b Other . . . . . . 1613 p 4 page 2) 27 services 17 Legal and professional 17 . . . . . . . . x r 28 Total expenses before expenses for business use of home. Add lines 8 through 27 in columns , ? 28 29 Tentative profit (loss). Subtract line 28 from line 7 , , , , , , , , , , , , , , , , 29 le 30 Expenses for business use of your home. Attach Form 8829 . . . . . . . . . . . . . 30 31 Net profit or (loss). Subtract line 30 from line 29. • If a profit, enter on both Form 1040, line 12, and Schedule SE, line 2, or on Form 1040NR, line 13 (statutory employees, see page C-6). Estates and trusts, enter on Form 1041, line 3. 31 l • If a loss, you must go to line 32. 32 If you have a loss, check the box that describes your investment in this activity (see page C-6). • If you checked 32a, enter the loss on both Form 1040, line 12, and Schedule SE, line 2, or on 32a UR"A'll investment is at risk. Form 1040NR, line 13 (statutory employees, see page C-6). Estates and trusts, enter on Form 1041, 32b ? Some investment is not line 3. at risk. • If you checked 32b, you must attach Form 6198. Your loss may be limited. For Paperwork Reduction Act Notice, see page C-8 of the instructions. Cat. No. 11334P Schedule C (Form 1040) 2006 Schedule C (Form 1040) 2006 Page 2 . ' • Cost of Goods Sold (see page C-7) 33 . " Method(s) used to ,? value closing inventory: a Ltd' Cost b ? Lower of cost or market c ? Other (attach explanation) 34 Was there any change in determining quantities, costs, or valuations between opening and closing inventory? If "Yes," attach explanation . . . . . . . . . . . . . . . . . . . . . . . . . . ? Yes ? No 35 Inventory at beginning of year. If different from last year's closing inventory, attach explanation 35 ::9-. 36 Purchases less cost of items withdrawn for personal use . . . . . . . . . . 36 QZ1 37 Cost of labor. Do not include any amounts paid to yourself . . . . . . . . . . . . . 37 38 Materials and supplies . . . . . . . . . . . . . . . . . . . . . 38 39 Other costs . . . . . . . . . . . . . . . . . . . . . . . . 39 -? 40 Add lines 35 through 39 . . . . . . . . . . . . . . . . . . . . 40 -? 41 Inventory at end of year . . . . . . . . . . . . . . . . . . . . 41 77 42 Cost of goods sold. Subtract line 41 from line 40. Enter the result here and on page 1, line 4 42 75:;?- Information on Your Vehicle. Complete this part only if you are claiming car or truck expenses on line 9 and are not required to file Form 4562 for this business. See the instructions for line 13 on page C-4 to find out if you must file Form 4562. 43 When did you place your vehicle in service for business purposes? (month, day, year) 10. ---- -----j--------- - 44 Of the total number of miles you drove your vehicle during 2006, enter the number of miles you used your vehicle for: a Business ____._______b Commuting (see instructions) __-??___-____ c Other ____ ?f D-U --- --------- ------ 45 Do you (or your spouse) have another vehicle available for personal use? . . . . . . . . . . . . . ? Yes P-No 46 Was your vehicle available for personal use during off-duty hours? . . . . . . . . . . . . . . Yes ? No 47a Do you have evidence to support your deduction? . . . . . . . . . . . . . . . . . . . Ida Yes ? No b If "Yes," is the evidence written? . ?es El No . . . . . . . . . . . . . ... . . . . . . . . . FOM Other Expenses. List below business expenses not included on lines 8-26 or line 30. ?ndn?lln ------------- ........................................... ------------------------------- ?y 5 ------------------------------------------- --------------- --------------------- --------------------------- ------ 48 Total other expenses. Enter here and on page 1, line 27 148 . " -1 Schedule C (Form 1040) 2006 040'v Payment Voucher OMB No. 1545-0074 Department of the Treasury Internal Revenue Service (10) ? Do not staple or attach this voucher to your payment or return. ?o0 6 1 Your social security number (SSN) 2 If a joint return, SSN shown second 3 Amount you are Dollars Cents on your return paying b check 7 z(?I ; ! /? o or money y order 4 You first name and initial Last name if a joint retu , spouse's first name and initial Last name Home aaoress (number na street) I Apt. no. ?? ? P) City, town or post office, state, apd ZIP code Cat. No. 20975C . C?p K..- RITT ?? WAYS..,: ?- ? 2 .. ` - ' 60-994-313 m 4, 3 O I? RdAD 0 LORD - ` ? ? 5 1 E ILf E ,}?t 17241, Ord i n, X71 2?6 ?3$g ,r ? - t _ ? >n? _ t r PA Y 20 ? i S-- _ f 4 41, o ADAMS "?OUtVTY AII?Y)ONAL'BANK F _ C,t=1lYSBUR?. P?NNSYLYANI,4' •4 , 1.03 1309945?; 018???515", 9l1' 26 - .; ¦ '. CORRECTED (if checked) Payer's Name. Street Address, City, State and ZIP Code 1 1 Cross Distribution OMB NO. 1545-0119 Distribution From 33223.56 Pensions, Annuities, Commonwealth of Pennsylvania -a Taxable Amount 200o / Proft-SharinfietPlans, Retirement or Public School Employees' Retirement System 33223.56 Insurance Contracts, etc. PO Box 125 Harrisburg, PA 17108-0125 Statements for COPY B 2b Total Distribution O Recipients of Payees Federal ID number Recipient's ID number 3 Amount in Box 2a eligible for capital 4 Federal Income Tax Withheld Report this gain election income on your 23-1739115 197-40-6112 .00 3325.71 return. n. if this 5 Recovered This Year form shows Add C' Stat A ZIP Code Federal Income Recipient s Name (first, puddle, last), Street Tess, lty, a an CHERYL K TRITT 24 MT ROCK RD NEWMILLE, PA 17241- Tax withheld in 7 Dist. Code 9a Your Total Dist Box 4, attach 2 0.00% this copy to your return. 9b Total Employee Contributions 0.00 This information D panniem or the Treasury - is being furnished lnta al 11-mue Service to the Internal Revenue Service. Form 1099-R a Gontiol number Safe, accurate, Visit the IRS website OMB No. 1545-0008 FAST! Use at www.irs.gov/erile. b Employer identification number (EIN) 1 Wages, tips, other compensation 2 Federal income tax withheld 2 3 - 144 14110 1 c Employer's name, address, and ZIP code 3 Social security wages 4 Social security tax withheld ESBYTERIAN CHURCH 3768.00 233.62 FIRST UNITED PR t it 6 M di 5 Medicare wages and tips care ax w e hheld 111 BIG SPRING AVE. 3768.00 54.64 NEWVILLE, PA 17241 7 Social security tips 8 Allocated tips d Employee's social security number 9 Advance EIC payment 10 Dependent care benefits 197-40-6112 e Employee's first name and initial Last name Suff. 11 Nonqualifed plans 112a See i nstructions for box 12 CHERYL K TRITT a 24 MT ROCK ROAD 13 emit planement Tsick pay hird-party C2b El ? NEWVILLE, PA 17241 14 other 12c d e 12d c e f Employee's address and ZIP code 15 state Employer's state ID number 16 State wages, tips, etc. 17 State income tax 18 Local wages, tips, etc. 19 Local income tax 20 Locality name _PA_I 9 9 9 9 9 9 9 9 3768.00 -_----- 115.68 --_---- 3 7 6 8.0 0- -------------- 62.16 W. -._Pen Wage and Tax Form Wr2 Statement Copy B-To Be Filed With Employee's FEDERAL Tax Return. This'infgrmation is being furnished to the Internal Revenue Service. 0 0 3 N +? Ito a m ? . N W `G x Q, f j m a m to N O to N, a 0% F 'O Nm N:. N i N C" v o 5n - ? e a? N Q N , m N n m f. ? N ? ? om ? b Z D ? N N o 0 m '? N Ya c m t r:r ,% m m N f1 lr W ?. n. r i_n' N p? A? 0 N <D 0. g a N ... d N 3 O1 ? ? ? ? CO ?7 M1 m ( N td y m J N H F O %0 CO , z fD J E? m A N J N N N 1 o O N p co, N io m° w a, ° W z (D o ?i m ? m c ?.." m B o ro m 3 0 m N N m Z y^ x N N tr 41 ? N o O v w c 7Z,, N ? r o X O J N N c O ro W M a U) 2006 Department of the Treasury-Internal Revenue Service . rr m 91 W m m a 09 ? m o n 11 LA) N ? m p _ IA o r A L C m F' «? A to +l to i N w p Ot 3 y m ?{ 0 N g 3 O H? CD rn td H Z H tp ? t 4 'd H N b y m ?' c H N ro 7d G? 'ji O w C1 m 3 <' N a a r 6 c1 ? N a ? m N n p 0 m w c y ti ? 4? o P m £ 4. m t W o a W w A. 3 N W m N ?a w ? cn m i, m m w_ o ? z m n G 3 ? 'o m ? 6 b m m G) ? O C a ? m m N w m x on 3 £ ?_ m 0 S a N ? ? E 0 y - Conrad Siegel A C T U A R I E S The Employee Benefits Company Conrad M. Siegel, F.S.A. Harry M. Leister, Jr., F.S.A. Clyde E. Gingrich, F.S.A. Ead L Mummert, M.A.A.A. Robert J_ Dolan, A.S.A. David F. Stirling, A.S.A. Robert J. Mrazik, F.S.A. David H. IOllick, F.S.A. Jeffrey S. Myers, F.S.A. Thomas L Timmerman, F.S.A. Glenn A. Hafer, F.S.A. Kevin A. Erb, F.S.A. Frank S. Rhodes, F.S.A., ACAS. Holly A. Ross, F.S.A. Janet M. Leymeister, CEBS Mark A. Bansalf, F.S.A. John W. Jeffrey, F.SA. Denise M. Polin, F.S.A. Thomas W. Reese, A.S.A. Jonathan D. Cramer, A.SA John D. Vargo, F.S.A. Robert M. Glus, A.S.A. Bruce A. Senft, CEBS Laura V. Hess, A.S.A. Vicki L Delligatti 501 Corporate Circle - P.O. Box 5900 - Harrisburg, PA 17110-0900 Phone (717) 652-5633 Fax (717) 540-9106 www.cooradsiegel.com May 8, 2006 Richard L. Webber, Jr., Esq. Weigle & Associates, P.C. 126 East King Street Shippensburg, PA 17257-1397 Re: Cheryl K. Tritt Dear Mr. Webber: MAY 1 0 2006 RESPONDENT'S7, EXHIBIT 3 You requested that we updated our November 7, 2005, report using the revised PBGC annuity actuarial assumptions effective January 1, 2006. We also received the official PSERS statement as of June 30, 2005, and have used the data shown on that statement. You provided us with the following information concerning Cheryl K Tritt: 1. Date of birth - September 10, 1949. 2. Date married - July 11, 1987. 3. Date separated - May 30, 1998. 4. Information provided by the Public School Employees' Retirement System as follows: a. Years of service - 33.99 (Class TD) as of June 30, 2005. b. Accumulated contributions plus interest - $105,869 as of June 30, 2005. c. Final average salary - $75,798 as of June 30, 2005. Currently, Cheryl K. Tritt is 56.6 years of age. The Public School Employees' Retirement System is a defined benefit pension plan. The pension benefit provided upon retirement is based upon the final three-year average salary and the years of service. You requested that we make calculations based upon Cheryl K. Tritt retiring effctive July 1, 2006 (then 56.8 years of age ). The figure that is marital property for divorce purposes for a defined benefit pension plan is the present value of the pension earned during the marriage. Conrad Siege! A C T U A R I E S Richard L. Webber, Jr., Esq. May 8, 2006 Page 2 The following table shows the pension benefit earned as of June 30, 2005, adjusted for retirement as of July 1, 2006, the present value of such benefit, the "coverture fraction" and the present value of the pension earned during the marriage: Present Value Pension Pension Present Value Coverture Earned During Benefit Pension Benefit Fraction Marriage Maximum single life annuity $867,086 .320 $277,468 of $5,367 Refund of contributions plus $886,916 .320 $283,813 interest & maximum single life annuity of $4,816 The pension benefit earned as of June 30, 2005, takes into account 16.02 years of service before the date of marriage and 7.08 years of service after the date of separation. Therefore, it is necessary to multiply the present value of the pension benefit by a "coverture fraction" in order to obtain the present value of the pension earned during the marriage. The numerator of the "coverture fraction" is 10.89 (the years from the date of marriage until the'date of separation) and the denominator is 33.99 (the years of service with PSERS as of June 30, 2005). Thus, the "coverture fraction" is 0.320 (10.89 divided by 33.99). The present value calculations are based upon the assumptions promulgated by the Pension Benefit Guaranty Corporation for annuity valuations except that mortality was not taken into account prior to the commencement of the pension. The interest rate is 5.9% per year for 20 years followed by 4.75% per year. The mortality is in accordance with the 1994 Group Annuity Mortality Basic Table for females with Projection Scale AA to 2016. In our opinion, the assumptions promulgated by the Pension Benefit Guaranty Corporation for annuity valuations are appropriate for the purpose of determining the present values. With best regards, Yours sincerely, H tarry . Leister, Jr., F.S.A. Consulting Actuary Jonathan D. Cramer, A.S.A. Consulting Actuary HML:JDC:kad nuo. I. cuui lz-C41m Weigle & Rsspciales R CITER17L K TRITT, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V NO. 00-4460 RONALD C. TRITT, CIVIL ACTION - LAW Defendant/Respondent IN DIVORCE STIPULATION FOR COURT ORDER. Cheryl K„ Tritt, Plaintiff/Petitioner ('Wife) and Ronald C. Tritt, Defendant/Respondent (Husband) hereby agree and stipulate as follows- l.. Wife shall pay directly to Husband the sum of S 350.00 per month towards his health insurance coverage in lieu of Wife maintaining health insurance coverage for Husband through her prior employer, Big Spring School District. 2., The Court may enter an Order as follows' ORDER AND NOW, this day of 2007, upon consideration of the attached Petition and Stipulation for Court Order, paragraphs 1 and 2 of the Order of Court dated Novemb(z 9, 2006 are hereby VACATED. Plaintiff/Petitioner shall pay directly to Dcfendant/Respondent the sum of $350.00 per rrtonth towards his health insurance coverage effective July 1, 2007 and continuing the f5rst day of each month thereafter, until the entry of a Decree in Divorec or further Order of Court. 'Big Spring School District shall terminate health insurance coverage for Defcndant(Respondent Ronald C. Tritt, effective July 1, 2007. Dcfendant/Respondent shall execute any documents required by the Big Spring School Distnet. in. order to cffoetuate the tenns of this Agreement. Any issues relating to whether PlaintiMPutitioner is to receive credit for payments made to Defendant/Rcspondent pursuant to this Order shall be addressed in equitable distribution $A-0-1 Ui I HUo. I, CUU! IL:L4NM Welo"IA & HSSOCIatBS ?I - ow'z s'- 167 Cheryl . Tritt P 1 aintiff/P eti ti on er WEIGLE & ASSOCIATES, P.,C 7 By. 17 Richard L. Webber, Jr. Esq. Attorney for Plaintiff/Petitioner 126 East Fang Street Shippensbur& PA. 1.7257 (717) 532-7388 NC? I?C^ F'? c Cb `- Ronald C. Tritt Defendant/Respondent MANCKE, WAGNER, SPREHA AND agner, Esq. Attorney for Defiendant/Respondent 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 r-> ^? --. _? -* - , ---i - ?? f r?,y-r? ,, , ??? - _ _..? - ?` ? ? =? CHERYL K. TRITT, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA V. : DOMESTIC RELATIONS SECTION RONALD C. TRITT, : PACSES NO. 119105981 Defendant/Petitioner : DOCKET NO. 00-4460 CIVIL INTERIM ORDER OF COURT AND NOW, this 21st day of August, 2007, upon consideration of the Support Master's Report and Recommendation, a copy of which is attached hereto as Exhibit "A", it is ordered and decreed as follows: A. The Wife shall pay to the Pennsylvania State Collection and Disbursement Unit as alimony pendente lite the sum of $832.00 per month. B. The Wife shall pay to the Pennsylvania State Collection and Disbursement Unit the additional sum of $50.00 per month on arrearages. C. The effective date of this order is May 15, 2007. IMPORTANT LEGAL NOTICE PARTIES MUST WITHIN SEVEN DAYS INFORM THE DOMESTIC RELATIONS SECTION AND THE OTHER PARTIES, IN WRITING, OF ANY MATERIAL CHANGE IN CIRCUMSTANCES RELEVANT TO THE LEVEL OF SUPPORT OR THE ADMINISTRATION OF THE SUPPORT ORDER, INCLUDING, BUT NOT LIMITED TO, LOSS OR CHANGE OF INCOME OR EMPLOYMENT AND CHANGE OF PERSONAL ADDRESS OR CHANGE OF ADDRESS OF ANY CHILD RECEIVING SUPPORT. A PARTY WHO WILLFULLY FAILS TO REPORT A MATERIAL CHANGE IN CIRCUMSTANCES MAY BE ADJUDGED IN CONTEMPT OF COURT, AND MAY BE FINED OR IMPRISONED. PENNSYLVANIA LAW PROVIDES THAT ALL SUPPORT ORDERS SHALL BE REVIEWED AT LEAST ONCE EVERY THREE (3) YEARS IF SUCH REVIEW IS REQUESTED BY ONE OF THE PARTIES. IF YOU WISH TO REQUEST A REVIEW AND ADJUSTMENT OF YOUR ORDER, YOU MUST DO THE FOLLOWING: CALL YOUR ATTORNEY. AN UNREPRESENTED PERSON WHO WANTS TO MODIFY (ADJUST) A SUPPORT ORDER SHOULD CONTACT THE DOMESTIC RELATIONS SECTION. ALL CHARGING ORDERS FOR SPOUSAL SUPPORT AND ALIMONY PENDENTE LITE, INCLUDING UNALLOCATED ORDERS FOR CHILD AND SPOUSAL SUPPORT OR CHILD SUPPORT AND ALIMONY PENDENTE LITE, SHALL TERMINATE UPON DEATH OF THE PAYEE. A MANDATORY INCOME ATTACHMENT WILL ISSUE UNLESS THE DEFENDANT IS NOT IN ARREARS IN PAYMENT IN AN AMOUNT EQUAL TO OR GREATER THAN ONE MONTH'S SUPPORT OBLIGATION AND (1) THE COURT FINDS THAT THERE IS GOOD CAUSE NOT TO REQUIRE IMMEDIATE INCOME WITHHOLDING; OR (2) A WRITTEN AGREEMENT IS REACHED BETWEEN THE PARTIES WHICH PROVIDES FOR AN ALTERNATE ARRANGEMENT. UNPAID ARREARAGE BALANCES MAY BE REPORTED TO CREDIT AGENCIES. ON AND AFTER THE DATE IT IS DUE, EACH UNPAID SUPPORT PAYMENT SHALL CONSTITUTE, BY OPERATION OF LAW, A JUDGMENT AGAINST YOU, AS WELL AS A LIEN AGAINST REAL PROPERTY. IT IS FURTHER ORDERED THAT, UPON PAYOR'S FAILURE TO COMPLY WITH THIS ORDER, PAYOR MAY BE ARRESTED AND BROUGHT BEFORE THE COURT FOR A CONTEMPT HEARING; PAYOR'S WAGES, SALARY, COMMISSIONS, AND/OR INCOME MAY BE ATTACHED IN ACCORDANCE WITH LAW. PAYOR IS RESPONSIBLE FOR COURT COSTS AND FEES. The parties are hereby advised that they may file written exceptions to the Support Master's Report and Recommendation within twenty (20) days of this order. Exceptions shall conform with the requirements of Rule 1910.12(f), Pa. R.C.P. If written exceptions are filed by any party, the other party may file exceptions within twenty (20) days of the date of service of the original exceptions. If no exceptions are filed within twenty (20) days of this interim order, this order shall then constitute a final order. y Court, QkL A6 Edgar B. Bayley, J. Cc: Ronald C. Tritt Cheryl K. Tritt P. Richard Wagner, Esquire For the Plaintiff Richard L. Webber, Esquire For the Defendant DRO CHERYL K. TRITT, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA V. : DOMESTIC RELATIONS SECTION RONALD C. TRITT, PACSES NO. 119105981 Defendant/Petitioner DOCKET NO. 00-4460 CIVIL SUPPORT MASTER'S REPORT AND RECOMMENDATION Following a hearing held before the undersigned Support Master on August 20, 2007, the following report and recommendation are made: FINDINGS OF FACT 1. The Petitioner is Ronald C. Tritt, who resides at 7067 Carlisle Pike, Apartment 11, Carlisle, Pennsylvania; he will hereafter be referred to as "the Husband." 2. The Respondent is Cheryl K. Tritt, who resides at 24 Mt. Rock Road, Newville, Pennsylvania; she will hereafter be referred to as "the Wife." 3. The parties were married on July 11, 1987. 4. The parties separated on May 30, 1998. 5. The parties have no minor children. 6. On June 27, 2000 the Wife filed a complaint for divorce. 7. On October 7, 2003 the Husband filed a petition for alimony pendente lite. 8. By order dated February 3, 2004 said petition was dismissed without prejudice by agreement of the parties. 9. On May 15, 2007 the Husband again filed a petition for alimony pendente lite. 10. The Husband is 63 years of age. 11. The Husband is disabled by neuropathy as a result of chemotherapy treatment for cancer. 12. The Husband receives social security disability benefits of $1,219.00 net per month. 13. The Husband receives a monthly annuity of $199.83 per month. EXHIBIT "A" 14. This is the Husband's second marriage. 15. The Husband's first wife was killed in an automobile accident. 16. Since the filing of the divorce complaint the Husband has received a $25,000.00 lump sum payment in October, 2001 and a $57,000.00 lump sum payment in October, 2006, both as a result of an insurance claim resulting from his former wife's death. 17. When he filed his petition for alimony pendente lite in May, 2007 the Husband had $12,000.00 remaining from said lump sum payments. 18. The Wife has been providing health insurance coverage on the Husband through her prior employer, the Big Spring Area School District, at a cost of $350.00 per month since she retired in June, 2006. 19. In August, 2007 the parties executed a stipulation whereby the Wife would pay the sum of $350.00 per month directly to the Husband, and the Husband would be removed from the Wife's health insurance plan. 20. The Wife retired from Big Spring Area School District on or about July 1, 2006. 21. The Wife receives a monthly retirement benefit in the gross amount of $4,958.74. 22. The Wife is 57 years of age. 23. The Wife was employed as a music director/church organist by the First United Presbyterian Church in Newville, Pennsylvania from 1991 through 1998. 24. After the separation of the parties in 1998 the Wife performed said services for the church on a voluntary basis. 25. From September, 2006 through March, 2007 the Wife was again paid for her services to the church. 26. The Wife was receiving $488.54 bi-weekly prior to her terminating her employment with the church on or about April 1, 2007. 27. The Wife is again performing services for the church on a voluntary basis. 28. Both parties' tax filing status is married/separate. 29. The Husband has received a distribution of marital property of approximately $23,000.00 from the sale of the marital home and $18,000.00 from the sale of the business. 2 DISCUSSION "Alimony pendente lite" is defined as "an order for temporary support granted to a spouse during the pendency of a divorce or annulment proceeding." 23 Pa. C.S. Section 3103. It is designed to enable a dependent spouse to proceed with or defend the divorce action. Jayne v. Jame, 663 A.2d 169 (Pa. Super. 1995). Factors to consider in determining entitlement to an award of alimony pendente lite include the separate income and estate of the claimant, the ability of the other party to pay, and the character, situation and surroundings of the parties. Litman's v. Litman's, 673 A.2d 382 (Pa. Super. 1996). If a claimant is found to be entitled to an award of alimony pendente lite, the amount of the award is calculated pursuant to the support guidelines in the same manner as an award of spousal support. Little v. Little, 47 Cumberland L.J. 131 (1998). "[N]otwithstanding the equivalency of spousal support and APL for purposes of computation under the rules of civil procedure, a determination of entitlement in accordance with the traditional test remains a prerequisite to an award of APL." Clouse v. Clouse, 50 Cumberland L.J. 167, 171 (2001). The Husband is 63 years of age. He is disabled as a result of side effects from chemotherapy treatment. He is not gainfully employed. His income is limited to social security disability benefits of $1,219.00 net per month and an annuity of $199.83 per month. Since the filing of the divorce by the Wife in June, 2000 the Husband has received two lump sum payments on an insurance claim totaling $82,000.00, with the more recent payment of $57,000.00 received in October, 2006. Since the filing of the divorce complaint the Husband has also received distribution of marital property totaling $41,000.00. An earlier petition for alimony pendente lite filed on October 7, 2003 was dismissed without prejudice by agreement of the parties. The Husband had approximately $12,000.00 remaining when he refiled his petition for APL in May, 2007. The Wife was employed as an elementary school principal when the divorce action was commenced in 2000. She retired from that profession on July 1, 2006. She has since been receiving a monthly retirement benefit in the amount of $4,958.74. She also has had gainful employment since her retirement as a music director/organist for her church. Her bi-weekly gross salary was $488.54. She voluntarily terminated the paid position on April 1, 2007 and has since performed the services on a volunteer basis. The Wife has been providing health insurance coverage for the Husband at a cost of approximately $350.00 per month paid by her to her former employer, Big Spring Area School District. The parties have reached an agreement, however, whereby the Wife will cancel the insurance coverage and pay the $350.00 directly to the Husband. It is clear that the Husband is the dependent spouse. His total monthly income of $1,419.00 is significantly less than the Wife's retirement benefit of $4,958.00. The Husband's separate estate at the time of filing for APL was approximately $12,000.00. The divorce action has dragged on for more seven years with neither party solely responsible for the delay. The Husband now finds himself in need of financial assistance to continue the litigation.' The Wife has the financial ability to pay an award of alimony pendente lite. ' A hearing is scheduled before the Divorce Master later this year. 3 Consequently entitlement to the award is found to exist. A guideline calculation will be performed. The Wife has gross monthly income of $4,958.74 in the form of a retirement benefit. This is subject only to federal income tax. Filing her return as married/separate with this as her gross income would result in net monthly income for support purposes of $4,199.00.2 The Husband has net monthly income from social security and an annuity of $1,419.00. With the incomes as set forth above the Wife's obligation for APL under the guidelines is $1,112.00 per month.3 A support order calculated pursuant to the guidelines is presumed to be correct, but the presumption may be rebutted by evidence that the guideline amount is unjust or inappropriate under the circumstances of the case. Landis v. Landis, 691 A.2d 939 (Pa. Super. 1997). The guideline calculation does not take into consideration the fact that the Wife was paying $350.00 per month to provide health insurance coverage for the Husband at the time the petition was filed and by agreement is to pay him $350.00 per month directly effective July 1, 2007 in lieu of providing insurance coverage. In the opinion of this Master this justifies a downward deviation in the award. A recommendation is made that the Wife pay alimony pendente lite in the amount of $832.00 per month effective May 15, 2007.4 Money included in the party's income for support purposes may not also be labeled as a marital asset subject to equitable distribution. Rohrer v. Rohrer, 715 A.2d 463 (Pa. Super 1998). Because the Wife's entire monthly pension benefit has been utilized to calculate the APL obligation at the request of the Husband, he is precluded from "double dipping" in the division of marital property. RECOMMENDATION A. The Wife shall pay to the Pennsylvania State Collection and Disbursement Unit as alimony pendente lite the sum of $832.00 per month. B. The Wife shall pay to the Pennsylvania State Collection and Disbursement Unit the additional sum of $50.00 per month on arrearages. 2 See Exhibit "A" for the tax deductions from gross income. s See Exhibit "B" for the calculation. 4 The amount was determined by deducting $350.00 from the Wife's income and adding that amount to the Husband's income. With the adjusted incomes the guideline support obligation would be $832.00. See Exhibit "C" for the calculation. 4 C. The effective date of this order is May 15, 2007. Date Michael R. Rundle Support Master In the Court of Common Pleas of Cumberland County, Pennsylvania Tax Detail Report Plaintiff Name: Ronald C. Tritt Defendant Name: Cheryl K. Tritt Docket Number: 00-4460 Civil PACSES Case Number: 119105981 Other State ID Number: Tax Year: Current: 2007 Defendant Plaintiff 1. Tax Method 1040 ES 1040 ES 2. Fling Status Married Filing Separately Single 3. Who Claims the Exemptions ON gee 4. Number of Exemptions 1 1 5. Monthly Taxable Income $4,958.74 - 6. Deductions Method 7. Deduction Amount $445.83 $445.83 8. Exemption Amount $283.33 $283.33 9. Income MINUS Deductions and Exemptions $4,229.58 -$729.16 10. Tax on Income $759.37 - 11. Child Tax Credit - - 12. Manual Adjustments to Taxes - - 13. Federal Income Taxes $759.37 - 13 a. Earned Income Credit - - 14. State Income Taxes - - 15. FICA Payments - - 16. City Where Taxes Apply 17. Local Income Taxes - - TOTAL Taxes $759.37 - SupportCak 2007 EXHIBIT ".A" 1?3 0 Ti --4 T fin j-? a i jo III AUG 2 22007 CHERYL K. TRITT, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V NO. 00-4460 RONALD C. TRITT, CIVIL ACTION - LAW Defendant/Respondent IN DIVORCE ORDER ;h AND NOW, this 14 day of ?, 0 4 us, 2007, upon consideration of the attached Petition and Stipulation for Court Order, paragraphs 1 and 2 of the Order of Court dated November 9, 2006 are hereby VACATED. Plaintiff/Petitioner shall pay directly to Defendant/Respondent the sum of $350.00 per month towards his health insurance coverage effective July 1, 2007 and continuing the first day of each month thereafter, until the entry of a Decree in Divorce or further Order of Court. Big Spring School District shall terminate health insurance coverage for Defendant/Respondent Ronald C. Tritt, effective July 1, 2007. Defendant/Respondent shall execute any documents required by the Big Spring School District in order to effectuate the terms of this Agreement. Any issues relating to whether Plaintiff/Petitioner is to receive credit for payments made to Defendant/Respondent pursuant to this Order shall be addressed in equitable distribution. Xichard L. Webber, Jr. Attorney for Plaintiff /Petitioner /Richard Wagner Attorney for Defendant/Respondent WEIGLE & ASSOCIATES. P.C. - ATTORNEYS AT LAW - 126 MST KING STREET - SHIPPENSSURG, PA 17257-1397 BY THE COURT: ? i 71 In the Court of Common Pleas of Cumberland County, Pennsylvania P"" Plaintiff Name: Ronald C. Tritt Defendant Name: Cheryl K. Tritt Docket Number: 00-4460 Civil PACSES Case Number: 119105981 Other State ID Number: 1.Obli oes Monthly Net Income $4,199.37 2. Less All Other Support - 3. Less Obligee's Monthly Net Income $1,418.83 4. Difference $2,780.54 5. Less Child Support Obligation for Current Case - 6. Difference $2,780.54 7. Multiply b 30% or 40% 40.00% 8. Income Available for Spousal Support $1,112.22 9. Adjustment for Other Expenses 10. AMOUNT OF MONTHLY SPOUSAL SUPPORT OR APL $1,112.22 Prepared b : mrr Date: 8/21/2007 SupportCak 2007 EXHIBIT "B" In the Court of Common Pleas of Cumberland County, Pennsylvania (PM Plaintiff Name: Defendant Name: Docket Number: PACSES Case Number: Other State ID Number: Ronald C. Tdit Cheryl K. Tdit 00-4460 Civil 119105981 1.Ob1 or's Monthly Net Income $3,849.37 2. Less All Other Support 3. Less Obligee's Monthly Net Income $1,768.83 4. Difference $2,080.54 5. Less Child Support Obligation for Current Case - 6. Difference $2,080.54 7. Multiply b 30% or 40% 40.00% 8. Income Available for Spousal Support $832.22 9. Adjustment for Other Expenses - 10. AMOUNT OF MONTHLY SPOUSAL SUPPORT OR APL $832.22 Prepared b : mrr Date: 8/21/2007 SupportCak 2007 EXHIBIT "C" C'? ??- Q ? ? ? 4 a,•`_ Cy. t ,ir' r`" Cf3 4r CHERYL & TRITT, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA V. : DOMESTIC RELATIONS SECTION RONALD C. TRITT, PACSES NO. 119105981 Defendant/Petitioner : DOCKET NO. 004460 CIVIL PLAINTIFF/RESPONDENT'S (WIFE'S) EXCEPTIONS TO THE SUPPORT MASTER'S REPORT AND RECOMMENDATION TO THE HONORABLE, THE JUDGES OF THE SAID COURT: The Plaintiff/Respondent (Wife), Cheryl K. Tritt, by and through her attorneys, Richard L. Webber, Jr., Esquire, and Weigle & Associates, P.C., take the following exceptions to the Support Master's Report and Recommendation: 1. The Support Master erred in excluding the lump sum payments received by Husband totaling $82,000.00 (referenced in Findings of Fact, Number 16) for purposes of calculating Husband's monthly net income. 2. The Support Master erred in including in Wife's monthly net income calculation the portion of her monthly retirement benefit (32%) that is subject to equitable distribution. 3. The Support Master erred awarding alimony pendente lite to Husband where Husband received the lump sum payments referenced in Number 1 above and in Finding of Fact Number 16, WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 -1 and the distributions of martial property totaling $41,000.00 referenced in Finding of Fact Number 29. WHEREFORE, because the Support Master's Report and Recommendations is against the weight of law and evidence, it is respectfully requested that the court grant Plaintiff/Respondent's exceptions to the Support Master's Report and Recommendation as set forth above. Respectfully submitted, Date: ? 6/wo -;> i Richard L. Webber, Jr., Esquire Attorney for Plaintiff Attorney ID #49634 Weigle & Associates, P.C. 126 East King Street Shippensburg, PA 17257 717-532-7388 WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 . or CERTIFICATE OF SERVICE AND NOW, this I& day of September, 2007 I, Richard L. Webber, Jr., Esq., hereby certify that I have this day served the following person with a copy of the foregoing document, by depositing same in the United States Mail, First Class, Postage Prepaid, addressed as follows: P. Richard Wagner, Esquire Mancke, Wagner, Spreha and McQuillan 2233 North Front Street Harrisburg, PA 17110 Date: (?- 01 G? ?''j WEIGLE & ASSOCIATES, P.C. BY: 4 Richard L. Webber, Jr., Esquire Attorney ID #49634 126 East King Street Shippensburg, PA 17257 Telephone: (717)532-7388 WEIGLE & ASSOCIATES. P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 c ??Ke° s Pa?? eiQnd ?9- ryO{Q?y Y ?Y dw w t CHERYL K. TRITT, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA V. DOMESTIC RELATIONS SECTION RONALD C. TRITT, PACSES NO. 119105981 Defendant/Petitioner: DOCKET NO.Of 44 bO CIVIL PETITION FOR TRANSCRIPTION OF NOTES OF TESTIMONY AND NOW, comes the Plaintiff/Petitioner, Cheryl K. Tritt, by and through her attorneys, Richard L. Webber, Jr., Esquire, and Weigle & Associates, P.C, and avers the following: 1. Plaintiff/Petitioner is Cheryl K. Tritt (hereinafter "Wife"), of 24 Mt. Rock Road, Newville, PA 17241. 2. Defendant/Respondent is Ronald C. Tritt (hereinafter "Husband"), of 7067 Carlisle Pike, Apt. 11, Carlisle, PA 17013. 3. A hearing was held with respect to Husband's Petition for Alimony Pendente Lite on Monday, August 20, 2007 before the Support Master, Michael R. Rundle. 4. The Support Master prepared a Report and Recommendation dated August 21, 2007. 5. On Monday, September 10, 2007, Plaintiff/Petitioner filed Exceptions to the Support Master's Report and Recommendation. 6. Pursuant to Cumberland County Rule of Procedure 1910.12, Plaintiff/Petitioner requests that the notes of the testimony from the August 20, 2007 hearing be transcribed. WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 WHEREFORE, Plaintiff/Petitioner respectfully requests that the Court enter an Order for the hearing testimony to be transcribed. Respectfully submitted; WEIGLE & ASSOCIATES, P.C. Dated: r ?'?{ p B Y: Richard L. Webber, Jr., Esquire Attorney for Plaintiff/Petitioner Attorney ID #49634 126 East King Street Shippensburg, PA 17257 717-532-7388 WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 Aw VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dater Richard L. Webber, Jr., Esq. WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 172?-'y ' ?'i? 1 -? ? f`s -o ?? n ? o rs' x ? ? ?-- R-? Q Q ? ? ?-- °?- N 1??. ra O? ? ?- ?? o ? 3 .: i . t f SEP 1 3 1001 CHERYL K. TRITT, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA V. DOMESTIC RELATIONS SECTION RONALD C. TRITT, PACSES NO. 119105981 Defendant/Petitioner: DOCKET NO. W-4460 CIVIL ORDER OF COURT -0% NOW, this ?J day of S e jke.%? C C , 2007, upon consideration of the attached Petition, it is hereby ORDERED that the notes of testimony for the Support Master's hearing of August 20, 2007 be transcribed. The costs related thereto shall be paid in accordance with Cumberland County Rule of Procedure 1910.12(c). By the Court, J. X-chard L. Webber, Jr., Esq. Attorney for Plaintiff/Respondent ,,I :-chard Wagner, Esq. Attorney for Defendant/Respondent -D o , &S x14/50-7 Oopl-es rn?IclSc( 'r WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 MNVAIASNN3d m Nno,,) t¢; nu-t (tJ SO I£ wd E i d3S LODZ CHERYL K. TRITT, AN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v :NO. 00-4460 RONALD C. TRITT, :CIVIL ACTION - LAW Defendant :IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under §3301(c) of the Divorce Code was filed on June 27, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of Notice of Intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unworn falsification to authorities. Dated: -2--- If -() 7 .?` CHERYL . TRITT, Plaintiff WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 cil CT? CHERYL K. TRITT, JN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V :NO. 004460 RONALD C. TRITT, :CIVIL ACTION - LAW Defendant JN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER & 3301(c) AND & 3301(d) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unworn falsification to authorities. Dated: 7 CHERY . TRITT, Plaintiff WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 ca Z cn z ' 0 ct) C) C: Ln CHERYL K. TRITT, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V :NO. 004460 RONALD C. TRITT, :CIVIL ACTION - LAW Defendant :IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under §3301(c) of the Divorce Code was filed on June 27, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of Notice of Intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unworn falsification to authorities. Dated: q-1 E'o'? R'°- ? `- RONALD C. TRITT, Defendant WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 c.!'? '? ? ' ro -? ?% ? ?? ?? ? ? c..- ? tri CHERYL K. TRITT, aN THE COURT OF COMMON PLEAS OF Plaintiff .:CUMBERLAND COUNTY, PENNSYLVANIA v :NO. 004460 RONALD C. TRITT, :CIVIL ACTION - LAW Defendant JN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER & 3301(c) AND & 3301(d) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. 0- Dated: RROONNALD C. TRITT, Defendant WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 C5 * t r cn _. co ?' ? = tv a c`r% CHERYL K. TRITT, Plaintiff VS. RONALD C. TRITT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00 - 4460 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this day of 1 #1 60 400A.. 114 2007, the parties and counsel having entered into an agreement and stipulation resolving the economic issues on September 18, 2007, the date set for a Master's hearing, the agreement and stipulation having been transcribed, 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, 0a Edgar B. Bayley, P.J. cc: fichard L. Webber, Jr. Attorney for Plaintiff /. Richard Wagner Attorney for Defendant :?.. 4 O d ? C? ? - ? ? .? ?? c` Q ?' ? ,'? Ct? ?u ' r c,;, ?,.?. ti T G 16. CHERYL K. TRITT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 00 - 4460 CIVIL RONALD C. TRITT, Defendant IN DIVORCE THE MASTER: Today is Tuesday, September 18, 2007. This is the date set for a hearing in the above-captioned divorce proceedings. Present in the hearing room are the Plaintiff, Cheryl K. Tritt, and her counsel Richard L. Webber, Jr., and the Defendant, Ronald C. Tritt, and his counsel P. Richard Wagner. The complaint in divorce was filed on June 27, 2000, raising grounds for divorce of irretrievable breakdown of the marriage. With respect to the grounds for divorce, the parties have provided the Master with 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. On February 15, 2001, an answer and counterclaim was filed on behalf of the Defendant, husband raising economic claims of equitable distribution, alimony, and counsel fees and costs. The parties were married on July 11, 1987, 1 0 7 and separated on May 30, 1998. There were no children of this marriage. After considerable negotiations today, the Master has been advised that 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. When the parties leave the hearing room today they are bound by the terms of agreement even though there has been no signing of the agreement affirming the settlement. However, the Master has been advised that the parties and counsel are going to return later today after the agreement has been transcribed to review the agreement for typographical errors, make any corrections as necessary, and then affix their signatures affirming the agreement. Upon receipt by the Master of a completed agreement, the Master will prepare an order vacating his appointment and counsel can then file a praecipe transmitting the record to the Court. Mr. Wagner. MR. WAGNER: Thank you. Husband and wife agree as follows: 2 x 1. Wife has a pension through the Public School Employees' Retirement System having an approximate value of $850,000.00. Wife agrees to give onto the husband the approximate amount of $122,000.00 of accumulated contributions and interest on said pension. Upon receipt of that payment, the balance of the pension will become that of wife. Each party agrees to execute whatever documents are necessary to effectuate the same. 2. To the extent that there is any tax responsibility on the aforementioned payment of contributions and interest on to husband, husband shall be responsible for tax on same. The parties have been provided with a document from the Public School Employees' Retirement System indicating that the approximate contributions are $72,127.00 and the interest is approximately $43,339.00 which said interest would be subject to taxation. 3. Wife agrees to pay on to husband effective May 15, 2007, to the present the sum of $255.00 per month payable as alimony pendente lite. 4. From the effective date of the divorce in the future, the wife agrees to pay the husband in the form of alimony the sum of $832.00 per month which said payment will be subject to modification pursuant to the terms of the no-fault act specifically Section 3702 as it relates to the basis for modification. Both parties agree that alimony will terminate pursuant to the provisions of the code based upon the death of either party, cohabitation or remarriage of the recipient. 5. Whatever personal property is in the possession of that party shall become the personal property of that party and each agrees to waive, relinquish and discharge any right, title, or interest that the other may have in the personal property in the possession of that party. 6. Each party agrees to waive, relinquish, and discharge any further claims hereinbefore set forth for alimony pendente lite, support, or counsel fees. 7. Both parties warrant to the other that during the course of the marriage there were no debts incurred for which the other is responsible and to the extent that there is a marital debt for which the parties are responsible, each agrees to indemnify and save the other harmless on account of said debt. 3 8. The parties acknowledge that there is a small stock account known as Vankampen Investments with a total value of $5,175.95. Husband agrees to relinquish any and all right, title, and interest in said amount and further agrees to execute whatever documents are necessary to effectuate the same. 9. The parties acknowledge that wife's father is owed a sum of money of approximately $5,000.00 and said debt shall become the sole and separate obligation of wife and wife agrees to indemnify husband harmless on account of the same. MR. WAGNER: Ron, you were present when I made a phone call, were you not, to a tax consultant concerning the impact of the Public School Employees' Retirement System and you were present when we were advised what the consequence would be on the interest part; not the contribution part? MR. TRITT: Right. MR. WAGNER: Right. MR. WEBBER: Any tax consequences, including interest and any other consequences would be the responsibility of husband. MR. WAGNER: That's fine. MR. WAGNER: 10. Both parties agree that the order of August 24, 2007, as it relates to the health insurance is hereby vacated and invalidated. 11. Both parties agree that the pending appeal filed by wife to the recommendation of the Support Master is hereby withdrawn. 12. 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 4 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 administrator 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. WAGNER: Ron, you were present, were you not, when I read to the Master-and the court reporter the terms of the agreement? MR. TRITT: Yes. MR. WAGNER: Were you present to hear the modification as suggested by the Master and the modifications suggest by Mr. Webber? MR. TRITT: Yes. MR. WAGNER: At the present time, are you under the influence of any drugs or any medication or any physical or emotional condition that would prevent you from understanding what is going on today? MR. TRITT: No. MR. WAGNER: And having heard everything placed on the record, do you understand that, if acceptable to you, this becomes your agreement and forever, except for enforcement of the agreement, waive any and all claims that you may have against your wife? 5 MR. TRITT: Yes. MR. WAGNER: Having heard all that, is it your desire to have this entered as your agreement to resolve your divorce claims under the divorce code? MR. TRITT: Yes. MR. WEBBER: Mrs. Tritt, were you present when Mr. Wagner read the terms of the proposed agreement into the record including modifications that were added by the Master and myself? MRS. TRITT: Yes. MR. WEBBER: And are you under the influence of any drugs or alcohol today or any physical or -- MRS. TRITT: No. MR. WEBBER: Having heard the agreement as it was read into the record including the modifications, are you satisfied that that is, in fact, the final agreement between the parties and that any other issues that aren't already raised or dealt with in this agreement would be waived by you? MRS. TRITT: Yes. MR. WEBBER: And having heard all of the terms agreement and so forth, are you in agreement that this would become the final arrangement or agreement between the parties and that it would not be subject to the modification at any point in the future other than for enforceability 6 issues? MRS. TRITT: Yes. THE MASTER: Thank you. 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: <;? -?Illf /0 Richard L. Webber, Jr. Attornewfor Plaintiff IF ''r a-a1 .error- wagner ttorney for Defendant Chery . K. Tritt Ra ald C. Tri t 7 ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 09/28/07 Case Number (See Addendum for case summary) 119105981 O Original Order/Notice 00-4460 CIVIL O Amended Order/Notice O Terminate Order/Notice Employer/Withholder's Federal EIN Number PSERS PO BOX 125 HARRISBURG PA 17108-0125 RE: TRITT, CHERYL K. Employee/Obligor's Name (Last, First, MI) 197-40-6112 Employee/Obligor's Social Security Number 6374101254 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 riot issued by your State. $ o . oo per month in current support $ o . oo per month in past-due support Arrears 12 weeks or greater? Oyes ® no $ o . 00 per month in current and past-due medical support $ 0.00 per month for genetic test costs $ o . 00 per month in other (specify) for a total of $ 0.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ o. 0o per weekly pay period. $ o. oo per biweekly pay period (every two weeks). $ o . oo per semimonthly pay period (twice a month). $ 0. 00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: 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 UMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY T E OURT: Date of Order: SEA' 2 8 2007 ?° T ? _ Edgar B. Bayley, Judge DRO: R.J. Shadday Form EN-028 Rev. 1 Service Type M OMB No.; 0970-0154 Worker ID 21205 ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS di r employee works in a state that is ? If hhecked you are required to provide a copy of this form to yoursmployee. If you Brent from the state that issued this order, a copy must be provi edd to your employee even if the box is not checked. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3.* payment. Reporth ig tl ie PaydateA3ate of Withholding. YOU mWt repOrt the paydate/date of withholding when Selldillg tile The _ paydate/date of withholding is the date on Yvi rich amount was withheld from tire employee's vvages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) S. Termination Notification: You must promptly notify the Requesting Agency when the employeelobligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2317391150 EMPLOYEE'S/OBLIGOR'S NAME: TRITT, CHERYL K. EMPLOYEE'S CASE IDENTIFIER: 6374101254 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act 0 5 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. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 Service Type M If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 OMB No.: 0970-0154 Form EN-028 Rev. 1 Worker ID 21205 e ADDENDUM Summary of Cases on Attachment Defendant/Obligor: TRITT, CHERYL K. PACSES Case Number 119105981 Plaintiff Name RONALD C. TRITT Docket Attachment Amount 00-4460 CIVIL $ 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): 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 anv health insurance coverage available through the employee's/obligor's employment. Addendum Form EN-028 Rev. 1 Service Type M Worker ID 21205 OMB No.: 0970-0154 C/7 T K• if CHERYL K. TRITT, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 00-4460 CIVIL TERM RONALD C. TRITT, IN DIVORCE Defendant/Petitioner PACSES Case No: 119105981 ORDER OF COURT AND NOW to wit, this 28th day of September 2007, it is hereby Ordered that the Alimony Pendente Lite be terminated effective September 18, 2007 pursuant to an agreement of the parties. The Cumberland County Domestic Relation Section shall dismiss their interest in the above captioned matter. The case is closed with a credit in the amount of $112.48. BY THE COURT: TOO Edgar B. Bayley, J. DRO: R.J. Shadday xc: Petitioner Respondent P. Richard Wagner, Esq. Richard L. Webber, Jr., Esq. Fomi OE-001 Service Type: M Worker: 21005 Co CHERYL K. TRITT, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA V. : DOMESTIC RELATIONS SECTION RONALD C. TRITT, : PACSES NO. 119105981 Defendant/Petitioner : DOCKET NO. 00-4460 CIVIL PRAECIPE TO WITHDRAW PLAINTIFF/RESPONDENT'S (WIFE'S) EXCEPTIONS TO THE MASTER'S REPORT AND RECOMMENDATION To the Prothonotary: Please withdraw the Plaintiff/Respondent's (Wife's) Exceptions to the Support Master's Report and Recommendation filed in the matter referenced above, as the matter has been settled. Date: W?Z- /C 7 Respectfully submitted, WEIGLE & ASSOCIATES, P.C. By: Richard L. Webber, Jr., Esquire Attorney for Plaintiff/Responde Attorney ID # 49634 126 East King Street Shippensburg, Pa 17257 717-532-7388 WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 L"1 2 a CD CHERYL K. TRITT, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V :NO. 00-4460 RONALD C. TRITT, :CIVIL ACTION - LAW Defendant :IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under § 3301(d)(1) of the Divorce Code. 2. Date and manner of service of complaint: July 10, 2007, Acceptance of Service 3. Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by Plaintiff - September 18, 2007; by Defendant - September 18, 2007. 4. Related claims pending: None 5. Date Plaintiff s Waiver in § 3301(c) Divorce was filed with the Prothonotary: September 18, 2007. Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: September 18, 2007. WEIGLE & ASSOCIATES, P.C. Date: _T Richard L. Webber, Jr., Esquire Attorney for Plaintiff Attorney ID # 49634 126 East King Street Shippensburg, Pa 17257 717-532-7388 WEIGLE & ASSOCIATES. P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 L'7 r-?D d j c3 .; cz :x7 v M Nj IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. CHMYL R. TRITT Plaintiff VERSUS RONALD C. TRITT No. 00-4460 DECREE IN DIVORCE 2007 IT IS ORDERED AND AND NOW, oc4a, 0 A -, DECREED THAT CHERYL K. TRITT , PLAINTIFF, AND RONALD C. TRITT 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; 100"o in the transcript of the Divorce Master is incor y rence herein but shall not merge with this Decree. BY THE/COURT: ATTEST: J. ROTHONOTARY ? ?"„" ?°? ?? ???w?'??? ?? ? ?/ ?/ c ?. c?/ ?. 76 OV ?,RCOM A S • ? ? Cp C013141 . CL3I?ERL K. TRITT ffesponaent p ; 00-4460 CYIERYL plainti • 1? -LAW v . CIVIL ACT1O? ,01vom AI.,D C. TRI ndanvVetitioner DNS 0 ub ect gOI? Def IC ,?LA,TI t and the s I FAD ??sT ner and ResljOnden over Petit?° has 3u'isdict10' court WHEREAS, this tlvs Order shgi be a C°,irt intend that is used Order; and and the nderlt, mater of ?s Orde? r? gespo a QDgp) as that term gEA5, petitione referred to as getirement ? bons Order (hereinafter 9"14, as amended by the lifted Domestic Rela ome Security Act of Qua` ent Inc r the Employee getirem into the unae and hich is incOrP°m A ted ct of 1984 (EgiSA)? Divorce Master's Report w hall enter this Order• EQuity S, Pursuant to the Div ordered that t?s court s WI?REA it was tea October 9' 2007' Decree ii Divorce da S is 2 gock CTiply 1. DEFINTIipr1 terms sh?l apply.. address 4 Nit. current a SE Order the following who ose was born on September 10,1949 Asused in the participant Cheryl I?• X2Trig''41' whose shall meaai (a) pennsylvanie 1 goad Newville, 191-40-6112. is 7067 ial Security mmmber is whose current address whose s°c meaift 'aid C. Trirt' Payee shal1 11015, who was born on Alternate pay a' (b) 1 Carlisle' pennsylvani 1 Carlisle pike Apt. July 17, 1944, and whose Social Security number is 172-36-0905. The Alternate Payee is the former spouse of the Participant. th of Pennsylvania Public School Employees' Plan shall mean the Commonweal (c) Retirement Plan. appointed by the Board Administrator shall mean the plan Administrator as (d) Plan 'rectors of the Commonwealth of Pennsylvania. of DiSECTION 2: DATE OF MARRIAGE married on July 1 7 and were divorced on Alternate Payee were 1,198 ' Participant and October 9, 2007. ^? PAYEE OF BENEFIT TO BE PAID TO ALTERNA SECTION 3: AMOUNT following interest in the plan as sole and separate The Alternate payee is awarded the property: Plan shall be 1 ?% of the participant's vested account Alternate payee's interest in the interest (which is approximately $122,000.00)- balance of Participant contributions' together with OF PAYMENT TO ?,TEItNATE PAYE SECTION 4: TIMING AND FORM above may commence as able to the Alternate Payee as set forth in Section 3 Benefits pay elect to receive his e after the order is qualified* The Alternate Payee may soon as practicabl other distribution, in the form of an annuity or any payment in the form of a lump suln distribution form available under the Plan. -2- SECTION 5: DEATH OF ALTERNATE PAYEE Upon the death of the Alternate Payee prior to the receipt of distribution to the Alternate Payee, such benefits shall be distributed to the Alternate Payee's beneficiary on record or, if none, to the estate of the Alternate Payee. SECTION 6: DEATH OF PARTICIPANT In the event of the death of the Participant after qualification, but prior to the receipt of a distribution to the Alternate Payee, the Alternate Payee shall be entitled to the amount assigned under the QDRO. SECTION 7: MISCELLANEOUS (a) The Participant shall cause a copy of this Order to be served on the Plan Administrator. This Order shall remain in effect until a further order of this Court. Nothing contained in this Order shall be construed to require the Plan or Plan Administrator: (i) To provide to the Alternate Payee any type or form of benefit not otherwise available to the Participant under the Plan; (ii) To provide the Alternate Payee increased benefits not available to the Participant; or (iii) To pay any benefits to the Alternate Payee that are required to be paid to another alternate payee under another order determined by the Plan -3- Administrator to be a QDRO before this Order is determined by the Plan Administrator to be a QDRO. (b) The participant's account shall be reduced to reflect any payment pursuant to this QDRO and any subsequent payment to the Participant or to an Alternate Payee under a subsequent QDRO, shall reflect said reduction in the Participant's account. (c) A separate account will be established for each Alternate Payee to whom payments are due. (d) In the event Plan Administrator does not approve the form of this Order, then each party shall cooperate and do all things reasonably necessary to devise a form of Order acceptable to the Plan Administrator. (e) The Court retains jurisdiction to enforce, revise, modify, or amend this Order insofar as necessary to establish or maintain its qualification as a QDRO, provided, however, neither this Order nor any subsequent revision, modification, or amendment shall require the Plan to provide any form or amount of benefits not otherwise provided by the Plan. (f) In the case of conflict between the terms of this QDRO and the terms of the Plan, the terms of the Plan shall prevail. -4- (g) The Plan Administrator and the Alternate Payee may modify by written agreement any provision of this QDRO without further court approval so long as the change has no adverse effect on the Participant. The Plan Administrator may unilaterally modify any provision of this QDRO to the extent necessary to comply with applicable law. (h) The Alternate Payee shall hold the Plan (and its sponsor and fiduciaries) harmless from any liabilities that arise from following this QDRO, including all attorney fees that may be incurred in connection with any claims that are asserted because the Plan honors this QDRO. (i) To the extent that the plan pays to the participant any benefits that are payable to the Alternate Payee under the QDRO, the Participant shall be deemed to be constructive trustee holding the amount of such benefits in a constructive trust for the benefit of the Alternate Payee. The Participant is ordered to pay such amount to the Alternate Payee within thirty (30) days after the Plan notifies the Participant that the Participant has received amounts that are payable to the Alternate Payee. To the extent that the Plan pays to the Alternate Payee any benefits that are payable to the Participant under this QDRO, the Alternate Payee shall be deemed to be a constructive trustee holding the amount of such benefits in a constructive trust for the benefit of the Participant. The Alternate Payee is ordered to pay such -5- t . amount to the participant within thirty (30) days after the Plan notifies the Alternate Payee that the Alternate Payee has received amounts that are payable to the Participant. Submitted by: Richard Wagner, Esquire Mancke, Wagner, Spreha & McQuillan 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorney for Alternate Payee ?RFC?nop,?, l . l??\obeR, ?s?• J -6- - 1 f ? 1 wl ? t?1