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GAY L. FOLTZ,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. tJ) ~~) ~:J~","
IN DIVORCE
VS.
CRAIG L. FOLTZ,
Defendant
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 annulment may be
entered against you by the court. A judgment may also be entered
against you for any other claim or relief requested in these papers
by the plaintiff. You may lose money or property or other rights
important to you, including custody or visitation of your children.
When the ground for the divorce is indignities or
irretrievable breakdown of the marriage, you may request marriage
counseling. A list of marriage counselors is available in the
Office of the Prothonotary at Cumberland County Courthouse,
Carlisle, Pennsylvania.
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.
Court Administrator
Fourth Floor
Cumberland County Courthouse
1 Courthouse Square
Carlisle, Pennsylvania 17013
(717) 240-6200
('?t-'l-~' . ~A:.()~~~ d'
Anthony . eLuca-;r--iS~:e / p:
113 Fron Street '
P.O. Box 358
Boiling Springs, PA 17007
GAY L. FOLTZ, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL AC'rION - LAW
.
. ~;,..y -r.;...-
CRAIG L. FOLTZ, . NO. r; '/- ..111
.
Defendant IN DIVORCE
COMPLAINT UNDER SECTION 3301 (cl
OF THE DIVORCE CODE
1. plaintiff is GAY L. FOLTZ, who currently resides at 1243
Goodyear Road, Gardners, Cumberland county, Pennsylvania, since
October 28, 1996.
2. Defendant is CRAIG L. FOLTZ, who currently resides at
2701 spring Road, Carlisle, Cumberland County, Pennsylvania, since
May 15, 1983.
3. plaintiff and Defendant have been a bona fide resident(sl
in the commonwealth for at least six months immediately previous to
the filing of this Complaint.
4. The Plaintiff and Defendant were married on November 25,
1971 at Kistler, Pennsylvania.
5. There have been no prior actions of divorce or for
annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised that counseling is available
and that Plaintiff may have the right to request that the court
require the parties to participate in counseling.
8. Plaintiff requests the court to enter a decree of
divorce.
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omBsllc RBlurn ece pI
GAY L. FOLTZ,
Plaintlff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
VS.
CRAIG L. FOLTZ,
Defendant
NO. 97-287 Civil Term
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under Section 3301 (c) of the
Divorce Code was filed on January 17, 1997.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety days have elapsed from the date of filing the
Complaint.
3. I consent to the entry of final decree of divorce.
4. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim
them before a divorce is granted.
I verify that the statements made in this affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to
unsworn falsification to authorities.
Date:
If l;.r-J17
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Gay L( oltz
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GAY L. FOLTZ, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
v . CIVIL ACTION - LAW
.
.
.
CRAIG L. FOLTZ, . NO. 97 - 2+6T- :J..P7
.
Defendant .
.
. IN DIVORCE
.
QUALIFIED DCMESTIC RELATIONS ORDER
WHEREAS, Craig L. Foltz (the "Participant"), and Gay L. Foltz, (the
"Alternate Payee") have agreed to the division of marital property,
which agreement provides for the entry of a Domestic Relations
Order (the "Order") to provide for the division and disposition of
the Participant's PP&L Employee Stock Ownership Plan (ESOP) and
Employee Savings Plan (ESP), which are maintained and administered
by PP&L, and to grant the Alternate Payee rights to such accrued
benefits of the Participant in such amounts and in the terms and
conditions prescribed in this Order and the Plan; and
WHEREAS, this Order is intended to be a Qualified Domestic
Relations Order (QDRO) as that term is defined in S414(P) of the
Internal Revenue Code of 1986 (the "Code"); and
WHEREAS, pursuant to the laws of the Conunonwealth of Pennsylvania,
this Order is intended to provide for a partial distribution of
Participant's ESOP and ESP as a martial property right of the
Alternate Payee.
NOW, THEREFORE it is hereby Ordered and Adjudged as follows:
1
Participant, Craig L. Foltz, date of birth September 21, 1949,
Social Security No. 168-36-6965, is a Participant on the
Pennsylvania Power & Light Company Employee stock Ownership Plan
and Employee Savings Plan.
2
The current and last known mailing address of the participant is
312 Juniper Street, Carlisle, Pennsylvania.
3
Gay L. Foltz, Plaintiff, date of birth 12/21/52, Social Security
No. 264-06-8061, the Alternate Payee, is a spouse of the
Participant and has raised claims for inter alia, equitable
division of marital property pursuant to the Pennsylvania Divorce
Code, 23 PA C.S. S3101 et seq.
4
The current and last known mailing address of the Alternate Payee
is 672 W. Louther Street, Carlisle, PA 17013.
5
This Order applies to the PP&L Employee Stock Ownership Plan (ESOP)
and PP&L Employees Savings Plan (ESP).
6
A portion of the Participant's accounts in the mentioned Plans are
marital property and subject to distribution by the court.
.
7
Alternate Payee shall receive 159.507 shares of PP&L stock from the
Participant's ESOP account.
8
Alternate Payee shall receive $16,078.21 from the Participant's ESP
account.
9
The distribution to Alternate Payee from the ESOP account and the
ESP account shall be made as soon administratively practical
following the Plan's determination that this Order is a Qualified
Domestic Relations Order.
10
Participant death shall have no effect on payment on Alternate
Payees benefit under the ESOP Plan and ESP Plan.
11
In the event the Alternate Payee dies before the Alternate Payee's
benefit is paid, the benefits shall be paid in accordance with the
applicable Plan's provisions regarding payment to beneficiaries,
including payments when no beneficiary is designated. The
Alternate Payee shall be entitled to name a beneficiary (or
beneficiaries) to receive the unpaid balance of the benefits. The
death of Alternate Payee before the Plan determines that this Order
is a Qualified Domestic Relations Order shall not affect the right
to Alternate Payee's beneficiaries to benefits from the Plan. For
purposes of this Order, the Alternate Payee's beneficiaries shall
be as follows:
.....~~"",.~.ll.i4~ "'I_._-"'-~-
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Name: Angela L. Baker
Address: 50 C1earview Drive, Car1.is1e, PA 17013
.
i
,
Sooia1 Seourity No. 176-64-5142
Name: Jared C. Foltz
Address: 510 N. Hanover Street, Carlisle, PA 17013
Sooia1 Seourity No. 176-64-5268
12
The parties shall promptly notify PP&L of any ohange in their
addresses from those set forth in this Order.
13
The Alternate Payee does not reoeive any portion of the
Partioipant's PP&L Company Retirement Plan.
Participant shall
retain sole ownership over the PP&L Company Retirement Plan.
14
This Court shall retain jurisdiotion to amend this Order as might
be neoessary to establish or maintain its status as a Qualified
Domestio Relations Order.
Dated this If,' day of .t
fi.d:
, 1998.
BY THE COURT,
00: Hubert x. Gilroy, Esquire
Anthony L. DeLuoa, Esquire
.///L.
~ 1/11/f'i.
..& 1f'_
GAY L. FOLTZ, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
.
.
v . CIVIL ACTION - LAW
.
.
.
CRAIG L. FOLTZ, . NO. 97-2187
.
Defendant .
.
. IN DIVORCE
.
STIPULATION
The parties to the above-captioned divorce action hereby stipulate
and agree that the Court may adopt and sign the attached Qualified
Domestic Relations Order pursuant to the Property Agreement
executed by the parties on November 19, 1997.
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