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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
PATRICIt If. NORRIS,
PLAINTIFr
N 197-1484
O.
CIVIL nIX
VERSUS
lrIJltlY L. NORRIS,
DIrIDltlANT
DECREE IN
DIVORCE
AND NOW,
~ ~~ ':JO'hrr IS ORDERED AND
PATRla If. lilORRIS
DECREED THAT
, PLAINTIFF,
lfINDY L. HORRIS
AND
. DEFENDANT.
ARE DIVORCED FROM THE BONDS OF MATRIMONV,
THE COURT RETAINS JURISDICTION OF THE FOLLOWING C~AIMS WHICH HAVE
BEEN RAISED OF RECOr.D\IN THIS ACTION FOR WHICH A FINA~ ORDER HAS NOT
VET BEEN ENTERED; velAJ...
A PROPDTY SITTLBICZJlT AGRJ:IICDIT IS ATTAc:BIIl AIm IIA!lI A PAn' Damr ro.
PURPOSIS or INrORCIXINT.
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Bv THE COURT:
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ATTEST
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PROTHONOTARY
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PROPBRTY SBTTLRVRNT AGRBBMBNT
THIS AGRBBMBNT, dated the ~ day Of~. 206;;), by and
between PATRICK W. NORRIS, residing at 8117 Molly pitcher Highway, Shippensburg.
CUmberland County, Pennsylvania, 17257, Social Security Number 182-56-0078,
hereinafter called the "aulband", and WENDY L. NORRIS. formerly LAUTSBAUGH,
residing at 15 Scrafford Street, Shippensburg, CUmberland County, Pennsylvania,
17257, Social Security Number 209-46-0837, hereinafter called the "Wif.", who
agree as follows:
WIT H B S S B T B I
lIHBRJI!"Jl, the parties are Husband and Wife, having been married on September
4. 1982, in Denver, Denver County, Colorado. The parties separated January 24.
1997.
lIHBRBAS, there have been issue of the marriage, to wit, DAYSHA NICOLE
NORRIS, born April 27, 1985, hereinafter referred to as the Child.
WBKIBAB, diverse unhappy, and irreconcilable differences, disputes, and
difficulties have arisen between the parties, and it is the intention of Wife and
Husband to live separate and apart for the relt of their natural lives. and the
parties hereto are desirous of settling fully and finally their respective
financial and property rights and obligationl as between each other including,
without limitation by specification: the settling of all matters between them
relating to the ownership and equitable distribution of real and personal
property I the settling of all matters between them relating to the palt, prellnt
and future lupport, alimony and/or maintenance of Wife by KUlband or of lfulband
by Wife; the settling of all IIIItters between the relating to the palt, prennt
and future lupport and or lIIIintenance of the Child, the illlpl~tation of
custody/vi8itation arrange\llenta for the minor Child of the parti..; and in
general, the lettling of any and all clailll8 and pollibl. clailll8 by one againat
the other or against their relpective eltate..
t
NOW THBRBrORB, in consideration of the promises and of the mutual
promises, covenants and undertakings hereinafter set forth and for other good and
valuable consideration, receipt of which is hereby acknowledged by each of the
parties hereto, Wife and Husband, each intending to be legally bound hereby,
covenant and agree as follo~s,
1 AORBDDT NOT A BAR TO DlVORCIi PROCliBDlNOS
This Agreement shall not be considered to affect or bar the right of Wife
or Husband to a limited or absolute divorce on lawful grounds if such grounds
now exist or shall hereafter exist or to such defense as may be available to
either party. This Agreement is not intended to condone and shall not be deemed
to be a condonation on the part of either party hereto of any act or acts on the
part of the other party which have occasioned the disputes or unhappy differences
which have occurred prior to or which may occur subsequent to the date hereof.
The parties intend to secure a mutual consent, no-fault divorce pursuant to the
terms of Section 3301(c) of the Divorce Code of 1980 as amended by Act No. 1990,
206 effective 3-19-91.
It is specifically agreed, however, that a copy of this Agreement may be
incorporated, by reference, into a divorce judgment or decres. This
incorporation, however, shall not be regarded as a merger, it being the intent
of the parties to permit this Agreement to survive any such judgment. unless
otherwise specifically provided herein, and for this Agreement to continue in
full force and effect after 8uch time as a final decree in divorce may be
entered with respect to the parties. The parties agree that the tel1ll8 of this
Agreement shall be incorporated into any divorce decree which may be entered
with reapect to them for purpo8e. of enforcement only of any provisiona therein,
but shall 8urvive 8uch decree.
2 KPP.cr or D.OU. NO _oat
:2
That is, this agreement and all warranties and representations contained
herein shall survive the Divorce Decree and shall continue to be enforceable in
accordance with its terms. Except with regard to child support and child
custody, no court may change the terms of this agreement, and it shall be binding
and conclusive upon the parties. In the event of a reconciliation, attempted
reconciliation, or other cohabitation of the parties hereto after the date of
this agreement, this agreement shall remain in full force and effect in the
absence of a written agreement signed by both parties expressly stating that this
agreement has been revoked or modified.
) DISTRIBUTION DATI
The transfer of property, funds and/or documents provided for herein shall
take place simultaneously with the execution of this Agreement.
4 ADVICB OF COaNSBL
The provisions of this Agreement and their legal effect have been fully
explained to the parties by their respective counsel, Sally J. Winder, Esquire,
for Husband. and Ruby D. Weeks. Esquire, for Wife. The parties acknowledge that
they have received independent legal advice from counsel of their selection and
that they fully undprstand the facts and have been fully informed as to their
legal rights and obligations and they acknowledge and accept that this Agreement
is, in the circumstances, fair and equitable and that it is being entered into
freely and voluntarily, after having received such advice and with such knowledge
and that execution of this Agreement is not the result of any dursss or undue
influence and that it is not the result of any collusion or improper or illegal
agreement or agreements.
5 PIIWlCUL DIICLOSURI:
The parties confirm that each has relied on the .oostantial accuracy of the
financial disclosure of the other as an inducement to the execution of this
Agreement, and that Wife does not wish to exercise her right to have apprai8als
by experts as to the value of the various interests of Husband. Bhe understandll
that such appraisals would be necessary to fix the fair market value of these
interests for purposes of equitable distribution.
6 "~llllANTY or DISCLOSURB
The parties warrant and represent that they have made a full disclosure of
all assets and their valuation prior to the execution of this Agreement. This
disclosure was in the form of an information exchange of information by the
parties' attorneys and this Agreement between the parties is based upon this
disclosure.
7 oBTAJN'IHG INJ'ORKATJON ON rINANCBS
Each party acknowledges that they have been informed they may have the
right. as provided by statute and pennsylvania Rules of Civil procedure. to
obuin information regarding the parties' finances. Such information would
include, without limitation, their present and past incOllle; and the identity and
value of assets both presently owned and transferred previously. Such
information may be obtained by one or more of several methods including
depositions upon oral examination. written interrogatories, production of
documents or entry upon property for inspection. The parties agree to waive any
further discovery.
8 pUSOHAL R'tGIITS
wife and Husband may and shall. at all times hereafter. live separate and
apart. They shall be free from any control, restraint, interference or
authority. direct or indirect, by the other in all respects as fully as if they
were unmarried. They may reside at such place or places as they may select.
Each may, for his or her separate use or benefit, conduct, carry on and engage
in any business. occupation, profession or employment which to him or her may
seem advisable. However, each party shall malte best efforts to maintain
employment with comparable benefits and salary 8& they now bold or for which they
are in training.
9 NO MOLBSTATION
Husband and Wife shall not molest or interfere with each other, nor shall
either of them attempt to compel the other to cohabit or dwell with her or him,
by any means whatsoever. Neither party shall harass or be verbally or
physically abusive to the other.
10 MIITllAL RBLBASBS
Husband and Wife each do hereby mutually remise, release, quitclaim and
forever discharge the other and the estate of such other, for all time to come,
and for all purposes whatsoever, of and from any and all rights, title and
interest, or claims in or against the property (including income and gain from
property hereafter accruing) of the other or against the estate of such other,
of whatever nature and wheresoever situate, which he or she now has or at any
time hereafter may have against such other, the estate of such other or any part
thereof, whether arising out of any former acts, contracts, engagements or
liabilities of such other or by way of dower or curtesy, or claims in the nature
of dower or curtesy or widow's or widower's rights, family exemption or similar
allowance, or under the intestate laws, or the right to take against the spouse's
Will; or the right to treat a lifetime conveyance by the other as testamentary,
or all other rights of a surviving spouse to participate in a deceased spouse's
estate, whether arising under the laws of (al Pennsylvania, (b) any State,
commonwealth or territory of the united States, or (c) any other country, or any
rights which either party may have or at any time hereafter have for past,
present or future support or maintenance, alimony, alimony pendente lite, counsel
fees, equitable distribution, costs or expenses, whether arising as a result of
the marital relation or otherwise, except, and only except, all rights and
agreements and obligations of whatsoever nature ari8ing or which may arise under
this Agreement or for the breach of any thereof. It is the intention of Husband
and Wife to give to each other by the execution of this Agreement a full,
complete and general release with respect to any and all property of any kind or
nature, real, personal or mixed, which the other now owns or NY hereafter
acquire, except and only except all rights and agreements and obligations of
whatsoever nature arising or which may arise under this Agreement or for the
breach of any thereof.
11 DISTRIBUTION OP REAL ESTATE.
The marital residence was lost to foreclosure.
12 Di.tributioD of per.onal PrODertvl
The parties hereto mutually agree that they have effected a
satisfactory division of the furniture, household furnishings, appliances,
and other household personal property between them and they mutually agrep
that each party shall from and after the date hereof be the sole and
separate owner of all such tangible personal property presently in his or
her possesBion, and this Agreement shall have the effect of an assignment
or bill of sale from each party to the other for such property as may be
in the individual possession of each of the parties hereto.
The parties hereto have divided between themselves, to their mutual
satisfaction, all items of tangible and intangible marital property.
Neither party shall make any claim to any such items of marital property,
or of the separate personal property of either party. which are now in the
possession and/or under the control of the other. Should it become
necessary. the parties each agree to sign, upon request, any titles or
documents necessary to give effect to this paragraph. Property ahall be
deemed to be in the possession or under the control of either party if, in
the case of tangible personal property, the item is physically in the
posseDaion or control of the party at the time of the signing of this
Agreement and, in the case of intangible personal property, if any
physical or written certificate of insurance or other similar writing is
in the possession or control of the party. Husband and Wife shall sach be
deemed to be in the possession and control of his or hsr own individual
pension or other employee benefit plans or retirement benefits of any
nature with the exception of social security benefits to which either
party may have a vested or contingent right or interest at the time of the
signing of this Agreement, and neither will make any claim against the
other for any interest in such benefits.
From and after the date of the signing of this Agreement both
parties shall have complete freedom of disposition as to their separate
property and any property which is in their possession or control pursuant
to this Agreement, and may mortgage, sell, grant, convey, or otherwise
encumber or dispose of such property, whether real or personal, whether
such property was acquired before, during or after marriage, and neither
Husband nor Wife need join in, consent to, or acknowledge any deed,
mortgage, or other instrument of the other pertaining to such disposition
of property.
13 OeD.rall
(1) Husband hereby waives all interest in Wife's property including
but not limited to all accounts, certificates of deposit and securities.
(2) Wife hereby waives all interest in Husband's property
including but not limited to all accounts, certificates of deposit, and
securities.
14 IIOTOI VDICLKS.
With respect tot tbe motor vehicles owned by one or both of the parties,
they agree as follows:
(a) The 1992 Geo Metro titled .jointly., shall become and remain the sole
and exclusive property of wife.
(b) The 1991 Chevrolet Astro, titled .jointly., shall become and remain
sole and exclusive property of the Husband.
15 PILIIID IMvAluuaI.. AND APPRAIIDDft
The parties further acknowledge their understanding that they each have the
right to fUe Inventories and Appraisement with the Court and to require the
other party to do so. Such Inventories and Appraisement require a party to
indicate, under oath, information regarding all marital property in which either
party has an interest as of the date the action was commenced. Fully knowing the
same, each party nonetheless waives their respective rights to request additional
discovery be conducted, to file Inventories and Appraisement with the Court, or
to require the other party to do so.
l' APTIR-ACOUIRID PIRSONAL PROPIRTY
Each of the parties shall hereafter own and enjoy, independently of any
claim or right of the other, all items of personal property, tangible and
intangible, subsequently acquired by the other party.
17 DISTS.
Karital Debt.: Husband and Wife agree that the debts incurred by
Husband and Wife during the marriage to various charge accounts and other
outstanding loans shall be assumed by Husband for the existing balance at
the time of separation, and Husband agrees to hold Wife harmless of same.
lS WA1lRA!lTY AS TO IXISTING OBLIGATIONS.
Each party represents that they have not heretofore incurred or
contracted for any debt or liability or obligation for which the estate of
the other party may be responsible or liable except as may be provided for
in this Agreement. Each party agrees to indemnify or hold the other party
harmless from and against any and all such debts, liabilities or
obligations of every kind which may have heretofore been incurred by them,
including those for necessities, except for the obligations arising out of
this Agreement.
11 WARIlAlITY AS TO Pll'1'URB OBLIGATIONS.
Wife and Husband each covenant, warrant, represent and agree that each
will now and at all times hereafter .ave hannle.. and keep the other
indemnified from all debts, charges and liabilities incurred by the other
after the eXl'cution date of this Agreement, except as may be otherwise
specifically provided for by the terms of this Agreement and that neither
of them shall hereafter incur any liability whatsoever for which the
estate of the other may be liable.
20 ""IVIIR or SPOt1SAL St1PPORT. ALIMONY PENDENTE LITE. AND ALIMONY
The parties herein acknowledge that by this Agreement they have each
respectively secured and maintained a substantial and adequate fund with which
to provide themselves sufficient financial resources to provide for their
comfort, maintenance and support, in the station of life in which they are
accustomed. Wife and Husband do hereby waive, release and give up any rights
they may respectively have against the other for alimony, alimony pendente lite,
support or maintenance. It shall be from the date of this Agreement the sole
responsibility of each of the respective parties to sustain themselves without
seeking any support from the other party.
21 RBTIRBIIBIIT Pt1JlI)S
A. The Husband, who has been employed by Raskas, Shippensburg,
Pennsylvania, has accumulated benefits in his retirement account. It is agreed
by the parties that the Wife shall waive any interest she may have in any of the
benefits, including retirement, which tbe Husband may have as a result of his
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employment.
B. The Wife, who is pl'esently not employed, does not have retirement and
other employee ben~fits.
22 DIVORCII
Husband and Wife agree that Husband has filed a Complaint in divorce
seeking a divorce on the basis of mutual consent. Husband and Wife botb agree
that both parties will execute the required Affidavits of Consent to be filed
with the Court to allow tbe Court to grant a divorce on the ba.is of 18\Itual
consent. Husband agrees to pay all counsel fees, COSU, and expense. incident
to obtaining the aforesaid divorce.
AND the partie. hereto .tate and agree that tbis Agreement .hall not in eny
way be construed al a collulive agreement.
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23 BREACH OF AGRBBMENT
If either party fails in the due performance of obligations under this
Agreement at their election, the non-breaching party shall have the right to sue
for damages for breach of this Agreement or to rescind same and seek such legal
remedies as may be available to them. The breaching party will be responsible
for actual legal fees and costs incurred by the non-breaching party necessary to
the enforcement of this Agreement.
24 LA" OF PBNNSYLVANIA APPLICAllLB
This Agreement shall be construed in accordance with the laws of the
Commonwealth of Pennsylvania which are in effect as of the date of execution of
this Agreement.
25 AGRlIIlBJIT BINDING ON BURS
This Agreement shall be binding and shall inure to the benefit of the
parties hereto and their respective heirs, executors, administrators, successors
and assigns.
26 SIlVDABILITY
If any term, condition, clause or provision of this Agreement shall be
determined or declared to be void or invalid in law or otherwise, then only that
term, condition, clause or provision shall be stricken from this Agreement and
in all other respects this Agreement shall be valid and continue in full force,
effect and operation. Likewise, the failure of any party to meet her or his
obligations under anyone or more of the paragraphs herein, with the exception
of the satisfaction of the conditions precedent, shall in no way avoid or alter
the remaining obligations of the parties.
21 INTGItATION
This Agreement constitutes the entire understanding of the parti.s and
supersedes any and all prior agreements and negotiations between thell. There are
no representations or warranties other than those expressly set forth herein,
28 NO WAIVER or DlrAl1LT
This Agreement shall remain in full force and effect unless and until
terminated under and pursuant to the terms of this Agreement. The failure of
either party to insist upon strict performance of any of the provisions of this
Agreement shall in no way affect the right of such party hereafter to enforce
the same, nor shall the waiver of any breach of any provision hereof be
construed as a waiver of any subsequent default of the same or similar nature,
nor shall it be construed as a waiver of any subsequent default of the same or
similar nature, nor shall it be construed as a waiver of strict performance of
any other obligations herein.
29 WAIVBR OR MODII'ICATION TO 81 IN WRITING
No modification or waiver of any of the terms hereof shall be valid unless
in writing and signed by both parties and no waiver of any breach hereof or
default hereunder shall be deemed a waiver of any subsequent default of the same
or similar nature.
30 IClITlJAL COOPIRATION
Each party shall, at any time and from time to time hereafter, take any and
all steps and execute, acknowledge and deliver to the other party any and all
further instruments and/or documents that the other party may reasonably require
for the purpose of giving full force and effect to the provisions of this
Agreement.
31 0TBIJl DOCllIIIIlTATIOlf
Wife and Husband covenant and agree that they will forthwith (and within
at least ten (10) days after demand therefore) execute any and all written
instruments, assignments, releases, satisfactions, deeds, notes, or such other
writings as may be necessary or desirable for the proper effectuation of this
Agreement, and as their respective counsel shall IllUtually agree shollld be SO
executed in order to carry out fully and effectively the tet'lllll of this Ag~._t,
32 TAX RBI'ORH ACT
The parties acknowledge that the Tax Reform Acts of 1994 and 1996, and all
amendments thereto, created dramatic changes in the tax law as it affects the
dissolution of marriages, including but not limited to the tax consequences of
support payments and all taxes associated with the division of property. Ruby
D. Weeks, attorney for the defendant, does not hold herself out as being an
expert in tax related matters and, therefore, has recommended that the parties
obtain competent tax advice from an independent source. By execution hereof, the
parties have acknowledged such recommendation and, if they so desire, have sought
and obtained advice with regard to matters of concern to them, as contemplated
herein.
]] nrrnn.PDlDIDfCY
The parties agree that the separate obligations contained in this agreement
shall be deemed to be interdependent. If any terms, conditions, clause or
provision of this agreement shall be determined by a court of competent
jurisdiction to be invalid or unenforceable, then the parties agree that the
agreement may be reviewed and renegotiated in order to fulfill as closely as
possible the purpose of the invalid provision. Notwithstanding any releases
contained herein, the parties intend that they may reinstate previously pleaded
economic claims to the extent permitted by the Divorce Code.
34 1AHDUP'l'Cr
In the event that either party becomes a debtor in any bankruptcy or
financial reorganization proceedings of any kind while any obligations remain to
be performed by that party for the benefit of the other party pursuant to the
provisions of this Agreement, the debtor spouse hereby waives, releases and
relinquishes any right to claim any exemption (whether granted under state or
federal law) to any property remaining in the debtor as a defense to any claim
made pursuant hereto by the creditor-spouse, and the debtor-epouse hereby
a..igns, transfers, and conveys to the creditor-spouse an intenst in all of the
debtor'. exempt property sufficient to meet all obligations to the creditor-
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Patrick W. NorriB,
Plaintiff
VB.
IN THB COURT or COMHON PLEAS or
CllMBBRLAND COllNTY, PENNSYLVANIA
CIVIL ACTION . LAW
IN Divorce
Wendy L. NorriB,
Defendant
N97-l484
CIVIL TBRM
PRAECIPB TO TRANSMIT RBCORD
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 Section (3301(c))
2. Date and manner of service of the complaint: Sent via US Mail Certified
Restricted Deliver Number P547 535 031 on March 28. 1997. service was acceDted on ADril
1. 1997
3.
Date of execution of the affidavit of consent required by Section
defendant
Mav
Code: by the plaintiff Mav 7.
7. 2002
Related claims pending:
2002
3301(c)
; by the
of the Divorce
4.
None.
Prooertv settlement aareement
attached to divorce comnlaint.
5. Date plaintiff's Waiver of Notice in 5 3301(c) Divorce was filed with
the prothonotary: Mav 22. 2002 .
Date defendant's Waiver of Notice in 5 3301(c) Divorce was filed with
the prothonotary: Mav 22. 2002.
@:.aS2~,_n<
Date: May 22, 2002
Ruby D.
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SALLY J, WINDER
AttcInIf1 et UlI>'
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PATRICK W. NORRIS.
IN TilE COURT OF COMMON PLEAS 0(<'
CUMBERLAND COUN1Y. PENNSYLVANIA
Plain.iff
\II
CIVIL ACTION - LAW
NIIl\IRF.R:
CIVil. TF.RM
WENDY L. NORRIS.
IN mVORCF.
Orrrndan. :
COMPI.AINT IN mVORCF.
'I
COMES NOW. the Plaintiff. PATRICK W. NORRIS. by and through his counsel.
SaUy J. WiDder. Esqui~. and represents as follows:
I, Plaintiff is PATRICK W. NORRIS. who currently resides at. and whose mailing
address is. 8117 Molly Pitcher Highway. ShippensburlC. Pennsylvania. since Jarnwy 10. 1997.
2, Defendant is WENDY L. NORRIS. who currently resides at.. and whose mailing
address is. IS Scrafford Street. Shippensbuqc. Cumberland County. Pennsylvania. since
May. 1993,
J Roth Plaintiff and Otfrndllnt ha~ heen bona fide ~idenh or the Commonwealth or
Pennsylvania for at Icast six months immediately previous to the fi1ing of this Complaint,
4 The PIaintiff and Defendant were married on September 04. 1982. at Denwr.
Colorado
S, TIleR ha\IC been no prior actions of divorte or for IIIIUIment bet ~:reG tile pII1ieL
6, The marria~e is irretrievably broken,
7, Plaintiff avers that he has been advised of the availability of counselin~ sessions for
both parties upon request of either party or by order of court. and that a list of qualified
professionals who provide such counselin~ service is available at the Domestic Relations Office
upon request. By the filin~ of this Complaint. the Plaintiff acknowled~es having been advised by
his attomev of record of the availability of counselin~ sessions and of a list of qualified
professionals, Plaintiff further avers that he has been advised that the choice of a qualified
professional sha1I be at the option of the Plaintiff and Defendant and need not be selected from the
list available upon request and. further. that arrangements for and the payment of the services of
the qualified professional shall be the responsibility of the parties and will not be included in the
docket costs of this proceedin~,
8. Plaintiff requests the Court to enter a decree of divorce,
Date' '3 1,). l \ ct 1
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SIlly J.6iDdU. Aftoracy for Plalatifr
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VF,RIFICATION
I verify that the statements made in this complaint are true and correct to the best of my .,
personal knowledge and belief I understand that false statements herein are made subject to the
penalties of 18 Pa, C.S. Section 4904. relati~ to unsworn falsification to authorities,
, Date 3~ .7l 97
J/~.~
PATRICK W. NORRIS
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PArIlICJt If. NORRII , I IN TIIB COURT 0' COIOlON PLEAa 0'
Plaintiff I CUMBBRLAND COUNTY. PBNJfIYLVANIA
I
".. I CIVIL ACTION - LAIf
I IN DIVORCE
WINDY L. NORIUI, I
Defend.nt I In-1Ut CIVIL TERM
NOTre. WI DRIP'DD &Jm MaIM RIOHTS
You have been .ued in Court. If you wi.h to defend again.t the claim. .et
forth in the following page., you mu.t take prompt action. You are warned that if
you fail to do .0, the ca.e may proceed without you and a decree of divorce or
annulment may be entered again.t you by the COUrt. A judgment may al.o be entered
again.t you for any other claa or reUef reque.ted in the.e papen by the
Plaintiff. You may lo.e money or property or other right. important to you,
including cu.tody or vi.itation of your children.
When the ground for divorce i. indignitie. or irretrievable breakdown of the
marriage, you may reque.t marriage coun.eling. A li.t of marriage coun.elor. i.
available in the office of the Prothonotary at the Cumberland county Court Rou.e,
Carli.le, Penn.ylvania, 17013.
IF YOU DO NOT 'ILl: A CLAIM FOR ALIMOllY, DIVISION 0' PROPERTY, LAWYER'S rlES,
OR IXPINSES BEFORE A DIVORCB OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO
CLAIM ANY or THEM.
YOU SROULD TAD THIS PAPIR TO YOUR LAWYER AT ONCE. IF YOU DO NOT MAVI A
LAWYIR OR CANIlOT AI'lORD ONI, GO TO OR TILIPHOIII THE OF'ICE SIT FORTH 8ILON TO FIND
OUT WHERE YOU CAN GIT LleAL HELP.
COurt Admini.trator, Fourth Floor
Cumberland COunty Court Rou.e
Carliele, Penneylvania 17013
Telephone. (717) 240-6200
1
PATRICK W. NORRIS, I IN THE COURT or COMMON PLEAS or
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
v.. . CIVIL ACTION - LAW
I IN DIVORCE
WENDY L. NORRIS, I
D.f.ndant . 97-14B4 CIVIL TERH
&..tnAvl~ or Maw. IAn. COUNSELING
I, WENDY L. NORRIS, being duly .worn according to law, depo.e and
nYI
1.
I have been advi.ed of the availability of marriage coun.e1ing and
under.tand that I may reque.t that the Court require that my .pou.e
and I participate in coun.eling.
2.
I under.tand that the Court maintain. a li.t of marriage counaelor.
in the Prothonotary'. Of~ice, which li.t i. available to me upon
reque.t.
.
3.
Being .0 advi.ed, I do not reque.t that the court require that ay
"
.
.pou.e and I participate in coun.e1ing prior to a divorce decr..
being handed down by the court.
I under.tand that fal.e .tatement. herein are made .ubject to the
penal tie. of 1S Pa. C.S. 54904 relating to unaworn fal.ification to autboritie..
Dated. LJ./1//97
I I .
Xt~~~~
WENDY L. S, Defenda
Sworn and .ub.cribed to
before _ thi.
of
day
, 19_.
Notary Public
CL.l.nte,(' (.,A t<< m
COUNT I - tNDtONtTr~R
3301 ,.\'" af ~h. Divorc. ~od.
7. par.gr.ph. 1 through 6 .re h.r.by incorpor.t.d by r.t.r.nc. and mad. . part
h.reot.
8. Th. av.rment. und.r thi. Count .r. not collu.iv..
9. Plaintift haa off.r.d .uch indigniti.. to D.t.ndant, the innoc.nt and
injured .pou.., a. to r.nd.r her condition intolerable and life burden.ome.
mmrr II - HOtJ'l:S'l' PO. ROUIT....TR Dtft1tlBUTION' 01' IlARI'l'AL PROPIN'I'Y
UNDD .RCTION' !i3!502 01' '1'111: DIva.C. ~DIt
10. paraqrapha 1 through 13 ar. hereby incorporated by r.f.r.nc. and mad. a part
h.reot.
11. The parti.. purchaa.d or oth.rwia. obtained during the cour.e ot their
marriage property which i. con.id.r.d "marital property".
12. Upon entry of a divorc. decree, .uch property .hould be divided equitebly aa
i. ju.t and proper.
13. Def.ndant i. requ..ting .xclu.ive po.....ion ot the marital re.idenc. and
Hu.band i. to make the mortgag. payment.
comr.r t II - cotJ1ISRL PEI:& _ ms-rs. R%......
14. Paragraph. 1 through 13 ar. h.r.by incorporat.d by r.t.r.nc. and mad. a
part h.reot.
15. D.t.ndant haa r.tain.d the ..rvic.. ot Ruby D. weeka, lequire, and the
eoun..l f..., co.te, and .xpen... for r.pre..lIt.tion ill thi. actlon will be
.ub.tantial .nd continuing.
16. D.f.nd.lIt. h without .utfici.nt tund., income, or ....t.. to pay neb
coull.el. f..., co.t.., and .Xpell....
3
17. D.f.ndant will need to r.tain the ..rvic.. of an apprai.er and oth.r .xpert.
with r.gard to thi. action.
18. Pl.intiff i. financially able to provide for th... .xpen... of D.f.ndant.
mmrr tV - ALIMONY &lID ALtllOlIY PENDENTI: LID
19. Paragraph. 1 through lS are h.reby incorporated by r.f.renc. and mad. a part
h.r.of.
20. Def.ndant lack. .uffici.nt mean. of .upport at pr...nt to fully provide for
h.r r.a.onabl. need., de.pite the fact .he i. employ.d. Def.ndant requ..t.
an award of alimony pendent. lit..
21. D.f.ndant require. r...onabl. .upport to ad.quat.ly lIl4intain h.n.lf in
accordanc. with the .tandard of living ..tabli.h.d during the lIl4rriag..
22. Plaintiff i. financially able to provide for the r...onabl. n..d. of
D.f.ndant.
c::omrr v - OIILD CUSTODY
23. Paragraph. 1 through 26 are hereby incorporated by refu.nce and _d. a part
h.reof.
24. Th.r. wa. a child adopted during the marriage,
DAYSHA NICOLI NORRIS, born April 27, 1985.
25. Said child 18 pr...ntly in the cu.tody of h.r moth.r, WENDY L. NORRIS,
herein, who re.ide. at 15 Scraftord St....t, Shippen.burg, Cumberland COunty,
PeM.ylvania.
26. During the put five yeare, the child ba. re.ided with the following penon.
and at the following addr.....' Child ha. r..id.d with par.nt. f~ five
day. following h.r birth.
4
27. Defend.nt h.. not p.rticip.ted .. . p.rty or witne.., or in .nother
c.pacity, in oth.r litig.tion concerning the cu.tody of the child in thi. or
.nother Court.
28. Defend.nt h.. no inform.tion of . cu.tody proceeding concerning the child
pending in . Court of thi. Commonwe.lth or in any other Court in .ny other
juri.diction.
29. Defendant doe. not know of . per.on not . p.rty to the proceeding. who h..
phy.ic.l cu.tody of the child or cl.ima to h.ve cu.tody or vi.it.tion right.
with re.pect to the child.
30. E.ch parent who.e parental right. to the child have not been termin.ted and
the pereon. who b.ve phyaical cu.tody of the child h.ve been n&lll8d ..
partie. to thi. .ction. There.re no other pereon. who .re known to h.y. or
cl.ia . right to cu.tody or vi.it.tion of the child, to intervene.
31. The be.t intere.u and permanent welfare of the child and her phyaical,
.piritual, emotion.l and moral well-being will be .erved by gr.nting the
relief reque.ted.
32. Defend.nt reque.t. joint, .h.red leg.l cu.tody of the child, with phy.ic.l
cu.tody of the child to be with the IIIOther. Liberal vhit.tion of tbe cbUd
with the f.ther .h.ll be .. the Court deem. in the beet iRtere.te of the
child.
COUNT VI _ I........,.. .In'ra,.
33. par.gr.ph. 1 through 32 .re hereby incorporated by referenee and ude . part
hereof.
34. Defendant l.cke .ufficient ....n. of .upport .t pre.ent to pnwlde ....1__ _
life in.ur.nce coyer.;e on her.elf .nd the child.
5
35. Plaintiff i. financially able to carry health and life in.urance coverage
peraonally or through hia employer for her and to carry m.dical, d.ntal and
ey. in.uranc. cov.rag. peraonally or through hi. employer for the child.
WIIIUroU, Oef.ndant pray. that a jUdgm.nt b. .nUred in favor of the
O.fendant again.t the Plaintiff a. follow.,
a. A. to Count I, that a d.cre. in divorc. be .nt.red divorcing
Defendant from the bond. of matrimony b.tween the .aid plaintiff and
O.f.ndant.
b. A. to Count II, that this Court determine marital property and ord.r
an equitable di.tribution thereof with O.fendant retaining .ole
po.....ion of the marital re.idence with Plaintiff-Hu.band continuing
to pay the mortgage paymente.
c. A. to COunt III, that thie Court enter an award for preliainary and
int.rim coun..l f..e, coat. and expen.e. and to ent.r a final award of
coun..l f..., co.t., and .xpen....
d. All to COUnt IV, that Def.ndant be awarded alimony pend.nt. lite until
final h.aring and permanent alimony ther.after.
.. A. to court V. that joint, .hared legal cu.tody of the minor child,
OAYSHA NICOLI NORRIS, born April 27, 1985, be awarded with pIly.ieal
cu.tody of the child to be with the mother, and liberal vi.itation of
the child with the father .hall be a. the COUrt deem. in tbe be.t
int.r..t. of the child.
f. A. to Count VI, that Plaintiff be ordered to carry .-dlcel aa4 11fe
lneurane. coyerage eith.r pereonally or through hl. -.player Oft hl.
6
,
!
~
.
COIGIOIlWULTII or PEHJIIYLVAHIA
..
COIIIl'l'l' or CllxnJUIlD
The above named, WENDY L. NORRIS, being duly .worn according to law, depo.e.
and .ay. that the fact. contained in the foregoing Complaint are true and correct,
and the complaint i. not made out of levity or by collu.ion between her and the
.aid Plaintiff for the mere purpo.e of being freed and .eparated from each other,
but that it i. brought in .incerity and in truth for the cau.e mentioned in the
.aid An.wer to Plaintiff'. Divorce complaint.
.{) C2/1 ~(t
WINDY L. KORRI
Sworn and .ub.cribed to
before me thi. ~ day
of ~rl( { 19tt.
r;Ik" / If ~ L f?f7!7"""i(t.
Notary Pub ic
.
NOT AAlAL 5tAL
$KlIllF.l p, Cl-"Vi'.0GER. NOTARY PI,IUC
Celllale ....,,'1lI' eu...cer:...., eowhW
My Cam,..'ulon blll'" ..."'" 50 2110O
.
Patrick N. Norria,
Plaintiff
IN TBI: COURT OJ' COIDCON PLDS OJ'
ctJKBlRLAND COllNTY, PINNSYLVANIA
I
I
I
I
I
I
I
CIVIL TUX
va.
CIVIL ACTION - LAN
IN Divorce
Nendy L. Norria,
Defendant
1197-1484
AFJ'IDAVIT OJ' CONSIIn'
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code "'as fUed
on March 21, 1997.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(901 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.
4. I understand that I may lose rights concerning alilllOny. 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. 54904 relating to unawcrn falsification to authorities.
Dated: <;-7- Ci:::l
/Q~.-r~~ _.
t..-iatriCk N. Norrie, Defendant
Swcrn and subscribed to
before me thia ~ day
of h1n y , 20~
;"
Notary Publ1c
NOTARIAL SEAL
DE80flAH WARREN. NolIty Public
ShippenIbutg, Cumbertand CllUIlIy
My eom..-..... !'."""" Nov, a.,~
Patrick W. Norris,
Plaintiff
IN TBIi COURT or COIllCON PLIAS or
CllXIIIRLAND COUNTY, PIHNSYLVANIA
I
I
I
I
I
I
I
VS.
CIVIL ACTION - LAW
IN Divorcs
WencSy L. Norris,
Dafanc!ant
N97-1U4
CIVIL TIJJI
APJ'IDAVIT or CONSINT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed
on March 21, 1997.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the C<ilt'! 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.
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. .4904 relating to unsworn falsification to authorities.
Dated.
S-I-Od
~fb\~
-1tfl
e L. NO~' Defen nt
Sworn md subscribed to
bef~lIle this l day
of Ifh l' . 20~
-..-
CM:ll A. ""'*Jw. ...., ......
c...._~ 'II Jr--
.. ~ " a....o- -....
-...... 2lllD
-----..._--_.._~
Notary Public
E '(7;; .:.'~
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t::> -
Patdck W. Norris, I IN TIIB COURT OJ' COIllCON PLIWI OJ'
Plaintiff I CUIIIlIRLAJID COllNTY. PBllNSYLVAIfIA
I
vs. I CIVIL ACTION - LAW
I IN Divorce
Wendy L. Norris, .
DefencSant I NJ7-UU CIVIL TlIX
WAIVIR OJ' KOTICI: OJ' IHTDTION TO RBOUKST DlTRY
or DIVORCB DBcaaa Ulmn I 3301 (c) or Tn DIVORCB COD.
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
pl'Operty. lawyer'S fees 01' 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. I 4904 relating to unsworn falsification to authorities.
Ji?~~;::L~
>-07-0:2
Date.
/
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.
;-...- -,;
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..
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fc:
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-< 1::' ......
Patrick N. Korri.,
Plaintiff
IK TD COURT 0' COIIIIOK PLDS 0'
CIIJCIlIRLAml COllJlTY, PIKKSYLVAKIA
v..
CIVIL ACTIOK - LAlf
IN Divorce
Nendy L. Kord.,
Defendant
K97-U84
CIVIL TDIIl
NAIVER 0' IIOTICI: 0' INTIIITIOK TO DOUKST IKTRY
0' DIVORCI: DICRBI UHDIR I 3301 leI 0' TD DIVORCI: CODI
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. S 4904 relating to unsworn falsification to authorities.
Date:
5- 7- 0').
~t~~~~~
We y L. or ,f t
PATRICK W. NORRIS,
P1aintilT
: IN THE COURT OF COMMON
PLEAS OF
. CUMBERLAND COUNTY,
.
.
.
. CIVIL ACTION - LAW
.
.
.
. NUMBER: 97 - 1484 CIVIL TERM
.
.
.
. IN DIVORCE
.
PENNSYLVANIA
VI
WENDY L. NORRIS,
nefeodaot
ORDER OF COURT
AND NOW this 1ftl1 day of September. 2000, upon consideration of the
within Petition for Bifurcation and upon motion of Sally 1, Wmder, Esquire, it is
ORDERED AND DIRECTED that a Rule to Show Cause issue upon Defendant Weny L.
Norris returnable at a hearing scheduled for Courtroom 'No L 4th Foor, Cumberland
County Counhouse, Courthouse Square, Carlisle, Pennsylvania, on the d.)~ day of
~~
. 2000, at \. 30 o'clock? m., prevailing time, why
why an Order should not be entered bifurcating the Divorce action and entering a Divorce
Decree in this matter, and reserving jurisdiction in the Court u to any outstanding claims
for equitable diStribution of marital property. Service to be upon Defendant's Counsd,
Ruby Weeks, Esquire, by reguJar mail,
By the CllI1rt:
/,-
J.
PATRICK W. NORRIS,
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plain tilT
.
.
VI
: CIVIL ACI'ION - LAW C) c
. C Q n
; NUMBER: 97 - 1484 clmlnaA.1
;. ( ..',
t.-, .
- '-"~
r- .
WENDY L NORRIS,
: IN DIVORCE
Defendant
.
~ . (
-",
;~
-')
.....
(}1 -)
".
P~ONFORBWURCATION
UNDER DIVORCE CODE AND P.. R.C.P. 1920.52 &lid P.. R.c.P. 1920.43
COMES NOW the Plaintiff, PATRICK W. NORRIS, by and tlvough hisIber attorney,
Sally J. WiDder, and requests this Honorablc Court bifurcatc the abovc-captioncd matter based
upon the foUowing:
I. Plaintiff, PATRICK W. NORRIS, tiled the abovc-captioncd divorce matter March
21, 1997. The Plaintiffallcges as grounds for divorce a separation ofmorc than two (2) years
under Section 330 I (d). the parties having lived separate and apart since January 24, 1997.
2. Defendant filed no counter-aftldavit or answer contesting that period of separation or
the fact that the nwriage is irretrievably broken and not reconcilable.
3. The Defendant did file a response on a Counter-Affidavit by hand-writing as shown on
the original Counter-Affidavit tiled in this matter a copy of which il marked Exhibit .. A" attached
hereto and incorporated herein. claiming that she wou1d 101C insurance c:overI8c and requesting
that Plaintift'bc ordered to pay for these benefits until May 2002,
4, No Master's hearing has ever been requested by Defeodant for distribution of any
nwital assets or equitable distribution of nwital assetl, Defeodant although she filed various
c1aims and counts in her Answer and Coonte:tlaim has not pursued those matters with respect to
property claims, c:ounsel fees or costs,
S, Defendant has received all of the nwital personal property constitutina household
goods and fumishinss and destroyed many items which were to be distributed 10 Plaintiff.
,-,
. I
'., ;
~l
I'ATJUCK W. NOIUUS,
rlaintiff
: IN TilE COURT OF COMMON rLEAS OF
: CUMBERLAND COUN'1Y. rENNSYLVANIA
vs
: CIVIL ACTION - LAW
: IN DIVORCE
(')
r-
.-,
:
WENDY L NORRIS,
: NUMBER: 97 - 1484 CIVIL TERM
Befendant: ;T!
COUNTER-AFFIDA VIT UNDER SECTION ;-':
330t(d) OF TilE DIVORCE CODE .,'.:
I. Check cithcr (D) or (b): .~:; .
_ a) I do not opposc thc entry ofa divorce decrce. ri[:~.
." . -'~
v' _ b) I opposc the entry ofa divorce decree because (Cbeck (i), <1Q, ,-" ;.:
or both):
(i) The panics to this action havc notlivcd separate and apart for II
period of al lcast two years,
(ii) 111C ml\l'riage is not irretrievably broken, ,.. ...~ f~rtf!,LICI1 ''";,r
.,.. iii X....; II '..c. ;......~f..b:....~&r<t;t-1~ ",,.1luf buI~b ~l:,~..~
2. Check eitllCr (II) or (b): ,..,...... PI....,. ,
_ (a) I do not wish to make any claims for economic relief. I understand
that I may lose lights concerning alimony, division of property,
lawye,'s fees or e"pcnses if I do not c1l1illlthelll before II divorce is
granled.
'--
........
"
V(b) I wish 10 claim economic relief which may include alimony, division
ofpropcrly, lawyer's fees or eXJlenses or olher important risJus.
I verify Ihal tllC Slalmenls made in this counler-af1ldavil arc lrue and correct. I
undersland that false S1alffilCnls herein an: made subjecllo tllC penalties of II hC.S. Section
490<1 relating 10 IInS\YpIll r.,lsilicalion 10 DlltlKllities,
Dale: 1-.J. /- 00
I
NOTICE: If)'ou de nel wisb to lIppclS(' Ibe eull"1 ora dl"," deene"'", de...
"Islt 10 make an}' Clallll fllr cto...mlc rrlld', Je. aeed ... me .... Cll''l11.
Amda,'il.
E'I/',-I.,!- It
PATRICK W. NORRIS,
PlalntllT
IN THE COURT OF COMMON
PLEAS OF
. CUMBERLAND COUNTY,
.
.
.
. CIVIL ACflON - LAW
.
.
.
. NUMBER: 97 - 1484 CIVIL TERM
.
.
.
. IN DIVORCE
.
PENNSYLVANIA
v.
WENDY 1.. NORRIS,
Defendant
ORDER OF COURT
AND NOW this
day of September, 2000, upon consideration of the
within Petition for Bifurcation and upon motion of Sally 1, Wmder, Esquire, it is
ORDERED AND DIRECTED that a Rule to Show Cause issue upon Defendant, Weny L.
Norris returnable at a hearing scheduled for Courtroom .No
. 4th Foor, Cumberland
County Courthouse, Courthouse Square, Carlisle, Pennsylvania, on the _day of
. 2000, at
o'clock_m., prevailing time. why
why an Order should not be entered bifureating the Divorce action and entering a Divorce
Decree in this matter, and reserving jurisdiction in the Court as to any outstandi"l claims
for equitable diStribution ofmarilll property, Service to be upon Dcfeodant's full1sd..
Ruby Weeks, Esquire, by regular mail.
By the Court,
J.
Defendant occupied the marital real estate and refused to make any mortgage payments or pay
insurance and taxes which resulted in the property being foreclosed and taken at Sherift's sale.
6. Defendant is capable and qualified for full-time employment where medical benefits
would be available to her within 30 days of her employment. Should Defendant choose to remain
employed only part-time, she would be eligible for a PCMSylvania ACCESS card through the
Department of Public Welfare which will provide her adequate medical care.
7. Defendant is in good general health and has no chronic illnesses or conditions which
would require extraordinary or unusual expenses which she cannot aITord even without medical
insurance.
8. The issue of the divorce decree is not contested, only the request for ongoing medical
insurance for which Plaintiff does not have an obligation.
9. Entry of a divorce decree prior to final order of property distribution would not
disadvantage the Defendant.
WHEREFORE, Plaintiff prays this Honorable Court issue a rule to show cause and
schedule a hearing to determine that this matter should be bifurcated and a divorce decree
entered,
RespectfWJy submitted,
~~;;~W
,
'. ..
VERIFICATION
I verilY that the statements made in this Petition are trUe and correct to the best of my
pcrsona1 knowledge and belief. 1 understand that faIsc statements herein are made subject to the
penalties of 18 PI. C,S, Seaion 4904, relating to unsworn falsification to authorities.
Date: fJ""s.--t;(7
qJ,:/~-2
VPATiuCK W. NORRIS
r
~
l'ATRlCK W. NORRIS,
Plaintiff
: IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, rENNSYLV^NIA
t
,
f
,
.
vs
: CIVIL ACl'ION - LAW
WENDY 1.. NORRIS,
: NUMBER: 97 - 1484 CIVIL TERl\1
: IN DIVORCE
(":
r
, -,
I. Check either (a) or (b):
_ a) 1 do not oppose the entry of a divorce decree.
Defendant: ;;: '
COUNTER-AFFID^ VIT UNDER SECTION ;-,;
3JOI(d) OF TilE DIVORCE COIJE
r~...,
'".;':-.
....'1-
..- (-~
',-
J
v"" _ b) I oppose the entry ofa divorce decree because (Check (i), <it), I..;.
or both):
(i) l11C panies 10 Ihis aClion have not lived separate and apart fot a
period ofatleasl two years,
(ii) l11C marriage is not irretrievably broken. .. ...~ i..t''l!!,c..c~ \~ i,r
v iii :I ....;.1 1.:-- ;"'.....'~f..r.~."1::".:x-1a:r; t.,.1Wt bUI&.\<b ~l:,ol"ol
2. Check eilher (a) or (11): t' 10.&.. Pi....."" -- I
_ (a) I do not wish to make any claims for economic relief. I understand
thai I may lose rights concelll!ng alimony, division of property,
lawyer's fees or eltl'ellses if I do 1I0t claim Ihem before. divorce Q
granled.
..::
, .
.~
..
.
V (b) I \vish to claim economic relief which may include alimony, division
of pro pc ny, lawyer's fees or eltllCllSes or other important rights.
I verify that the statemcnts made in this counter-affidavit are true and correct. I
understand thai false slall'l1lCIllS hercinare made subject 10 tllC penalties of 18 Pa.C.S. Section
4904 relalillg 10 unswpm r.,lsilic.,liunto aUlhorities.
Uate:
1-.J./- 00
I
.,
NOTICE:
If you do uot wish to OPIIOSl' the entry or a dlyorce decree aDd JOU d....
\ybh 10 mllkt' IIn)' claim for <<ouomlc nllcr.you need not file tIa1I c...tft'"
,\ffidl\\, it.
r;~ I,: 1" I- A
PATRICK W. NORRIS,
. IN TilE COURT OF COMMON PLEAS OF
.
. CUMBERLAND COUN1Y, PENNSYLVANIA
.
.
.
. CIVIL ACfION . LAW
.
.
.
. NUMBER: 97 - 1484 CIVIL TERM
.
.
.
. IN DIVORCE
.
Plaintiff
v.
WENDY L. NORRIS,
Defendant :
COUNTER-AFFIDA VIT UNDER SECI10N
3301(d) OF TnE DIVORCE CODE
I. Check either (a) or (b):
_ a) I do not oppose the entry of a divorce decree.
V' ~ b) I oppose the entry of a divorce decree bec~llse (Check (i), (Ii),
or both):
(i) The panies to this action have not lived separate and apart for a
period of at least two years,
(ii)The marrilge is not irretrievably broken. ....~ ~rtf!.I.t(fI '~ir ..
0/ iii % ....;11 'o:e. ;"."~f"~~'1:;'~1~torlWt belte.{ib ~l:,~..~ ~
2. Check either (a) or (b): r 1toe.. "1~Ji" - I
- (a) I do not wish to make any claims for economic relief. I understand
that I may lose rights concerning alimony, division ofpropeny,
lawyer's fees or expenses if I do not claim them before a divorce is
granted.
V(b) I wish to claim economic rdiefwhich may include alimony, division
of propeny, lawyer's fees or expenses or other important rights.
I verilY that the statements made in this counter-afrKlavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 PI.C.5, Section
4904 relating to unsworn filsilication to authorities,
Date:
~~~ i\~iV>';'
WENDY L. NO RlS
7~/-oo
NonCE: Ir)'O. do not "Ish to oppost' llK-flltry .ra dlvorre dtl(m and fOIl d. Dot
"Ish to make an)' tlallD for ftOnolDk rdltf, )'ou uftd not Ilk this Co.ntfll'o
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PATRICIt W. IIORRIS, I III ~ COURT or COMIIOII PLEAS or
Plaiatiff/Petitioaer I CUMBERLAJID COtlll'rY, PEIIJlBYLVAIIIA
I
v. I CIVIL ACTIOII - LAW
I
I IlUNBER I 97-l4B4 CIVIL
WEllDY L. IIORRIS, I
Dafeadaat/Re.peadeat I III DIVORCE
DEI"EIfDIUIT-IlI!:SPONDEH'J" S IlI!:SPONBE TO
PETITION FOR SPECIAL RELlEr
To the Honorable, the Judge. of .aid Court, COIDes Now, WENDY L. NORRIS,
Defendant in Divorce and Re.pendent herein by and through her attorney, Ruby D.
Week., Z.quire, who repre.ent. and an.wer. this Petition for Special Relief a.
follow. I
1. Adlllitted.
2. Admitted.
3. Admitted in part. Petitioner moved from the marital residence January
24, 1997. She later learned that Petitioner had been engaging in an
extra-marital affair and had lied to her about many matter..
4.
Admitted in part and denied in part.
Re.pendent ha. provided
Petitioner the att.ched li.t (See li.t attached .. Exhibit A and made
e part hereof.) of penonal property he reque.ted.
Petitioner ie
att.mpting to piece me.l divide marital property. M.ny of the item.
Petitioner requ..te ar. marital property and not hie per.on.l or
..parat. property. Ther. are no item. of property urgently n.c....ry
for Petition.r to have until .uch time a. equitable di.tribution i.
aCCClllpliehed. Wife need. the l.wn mower and toola to maintain the yard
and home. For au.band to rec.ive the T.V. leav.. the Wife without on..
5. Admitted. S.. H.t .tt.ched .. Exhibit A .nd mad. a part hereof.
6. Denied. Hu.b.nd haa .lre.dy received item. of hie penond property,
... attached H.t wife added .xplanation. IIIllrked aa Ixhibit . anti
attached h.reto and made . part h.reof.
7. Denied. There ie no a..unnc. Huaband will be awarded reqIl.attld joiftt
marital property.
Vif. will abide by .ny decree of equitable
dietributlon awarding .uch property.
CClIGIClJIIlBAL 0.. PIIlHSYLVlIJfIA
I
I aa
I
COUIITY 0.. CIlJIIlDLAND
I WENDY L. NORRIS appeared before me, a Notary Public in and for the
Commonwealth and County aforeaaid, the underaigned, being duly aworn according
to law, depoaea and aaya that the foregoing DEFENDANT-RESPONDENT'S RESPONSE TO
PETITION "OR SPECIAL RELIEF are true and correct to the beat of my knowledge,
information and belief and are made aubject to the penaltiea of 18 Pa.C.S. 54904
relating to unaworn falaification to authoritiea.
Sworn to and aubacribed to
before me thia ~ 1'- day
of -f....... , 19.2:2.
)a.:r:,J. illy_
.....Ne>t l'uJ)lic
1IOTAF1\1. tIU.&.
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CWlCsl, !l:lr.:llJ;H, t1AlllEJtUI\1D co....
IIY CC'~QPlIlQ APllILq, 1011
TIME-LIFE SERIES BOOKS
JOINT
DARRYL' I COOJtllOOKS
IUIBlUfD RECEIVED 4-4-97
WILSON/WIZARD BEARSTONE WITH BOX
BUIBlUfD RECIIVED 4-4-97
35 HK CAMERA
JOINT
TV lIJfD VCR
JOINT WIn .. DAUOIITZR WILL U WIDOUT
A SIT IF IUSBlUfD RECEIVEI DII;
DAUOIITZR RECEIVED A SIT AS A GIn AIID
lIAS IT III ... aOOII
EXHIBIT "A"
~ ~
PATRICK W. 1I0RRIS I IN THI COURT 0.. COMMON PLlAS 0..
Plaintiff I CUMBERLAND COUIITY, PIIlHSYLVlIJfIA
I
vs. I CIVIL ACTION - LAW
I IN DIVORCE
WENDY L. 1I0RRIS , I
Defendant I 197-1484 CIVIL TERM
AFFIDAVIT OF SERVICE BY MAIL
PURSUANT TO PA R.C.P. 1920.4 tallll'ii\
COIGIOJllfIALD 0.. PIIlNSYLVlIJfIA .
. ss
COUIITY 0.. CUMBERLAND I
I, RUBY D. WEEKS, ESQUIRE. Attorney for Wendy L. Norris, being duly
sworn according to law. depose and say that a true and correct copy of the
Wendy L. Norris (Defendant)'s First Set Of Interrogatories to Patrick W.
Norris (Plaintiff) was served on sally J. Winder. Esquire, at 701 East King
Street, Shippensburg, Pennsylvania, 17257, by mailing the same to her by
certified mail, No. P433 103 219. on July 16. 1997, service wa. accepted on
July 17, 1997.
4w..Q \
Ruby D. Week., llquire
Sworn and subscribed to
before.;:: thia .JS:t!:. day
of '., . 1912..
~<#4''''
<./"itota hI
lIlITAlUl.IEAI.
TMM'IIICIIIUI!MIlI. __ -.:
CA--.t ~ ~\ool!ai.tc1L.tft~eo. __
1ft ( j T1 1lII__ AI'llL q,....
pAftICE W. IIOUII, I III 'rill COURT 0.. COMMOII PLIAB 0..
.1aiDtUf I CUMBEIlLAND COUNTY, PEJlIlIYLVlIJfIA
I
vs. I CIVIL ACTION - LAW
I III DIVORCE
WENDT L. IIOUII, I
Defendaat I 197-1484 CIVIL TEIUC
:::I::V:: :~ tlUVICE BY IlAIL
otI1l<<U CAP. 1920.& '.\Itllil\
CCIQIOIlMBALD 0.. 'EJlIlS'fLVAIIIA ·
I ss
COUNT'f 0" CUIU'-lJ'JID I
I. RUBY D. WEEKS. ESQUIRE, Attorney for WENT L. NORRIS, being duly sworn
according to law. depose and say that a true and correct copy of the PETITION
roR SPECIAL RILlE" PURSUANT TO Pa. R.C.P. 1920.43 and 23 Pa. C.S.A. 3323(f).
W&8 served on SALLY J. WINDER. ESQUIRE, at 701 East King Street. ShippensbUrg.
cumberland County, Pennsylvania. 1'25'. by piling the s_ to her by
certified mail, No. P 492 349 638, on June 25, 199'. service was accepted on
.tun. 2:6. 1t91.
~~.~~
SwOrn and .ubscr1be4 to
bef~ .. thi. J7f'- day
of ...... , 19.:J..].
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Notary lic
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CAIlUIU_l;U:\l.J~i,.,~o.Jco.,.
...,( CtIIllP111U_u._
I
/
PATRICK W. 1I0UII, I III DB COURT 0.. COMMOII P~ 0..
Plailltiff I CUMBERLAND COUIITY, PIIIJIIYLVlIJfIA
I
v.. I CIVIL ACTIOII - LAW
I III DIVORCE
WDDY L. NOUIS, .
Defendallt I 197-1484 CIVIL TERM
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SALLY J. WINDER. ESQUIRE 411.
701 EAST KING STREET C fleQ" ~ lIlI CarIIed
SHIPPENSBURG. PA 17257 C.....MII C -- f
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'AftICE W. IIOUII, I III TII& COURT or COIDlOJI PLIAI 0..
PlailltUf I CUlCBl:IlLAIID COUNT'f, PEJlIlIYLVlIJfIA
I
v.. I CIVIL ACTIOII - LAW
. III DIVORCE
lIIIlDT L. IIOUII, I
Defendallt I 197-1414 CIVIL TEIIII
APPtDAVr~ OP .RaVle. BY MAIL
PUR.u~ ~ P& R.C.Pa 1'2Q.4 la"lllli'
cotGtOIllllALTll 0.. PIIDIIYLVUIA I
. ..
-...uu.... & or ~1nI1' \lID I
I, RUBl D. WEIKS, ESQUIRE, Attorney for WENT L. NORRIS, being duly sworn
according to law, depo.e and .ay that a true and correct copy of the
DIPlNDANT-RlSPONDINT'S RlSPONSE TO PETITION FOR SPECIAL RILlE", wa. .erved on
SALLl J. WIRDER, ESQUIJlE, at 701 Za.t King Street, Shippen.burg, CUmberland
COUnty, Penneylvania, 1'257, by mailing the .ame to her by certified mail, No.
P 4'2 349 637, on June 25, 1997. Service wa. accepted on Jun. 26. 1997.
_D. g~~
Sworn and eub.cr ibed to
bef07 - thia ill!::.. day
of 'f'!..w , 19...17-
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PATRICK W. NORRIS
I'lainlilllRespondenl
IN Tilt: (:OURT OF COMMON PLF.AS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
('IVII. ACTION - J)lVORCE
W.:NIlV L NORRIS
Iklcndanl'I"'1 il i.mer
NO. '17 - loUU ('IVII. TERM
IN IlIVORn:
IlRH 1".J91
ORl)fo:R 010' COlIRT
ANI) NOW.lhls 18th day or~. 19%. upon considcrali.m orllle allach.... Pctilion lOr
Alim.my I\:ndenle Lile and/or counsel r...,.. il is hen"'y din:c1ed lhalth" panin and their rcspccti~"
counsel appear heron: IU. Shadda~.m Ma~ (0. 1'l'l7 al 9:00 H.m. for a conf~. at 13 N. lIano~er St..
Carlisle. I'A 17013. Hiler ",hich the (llIIlcn.'.we olrlC....llIay recommend Ihal an Order for Alimony
l\:ndt.'IIh/Lite he enlen.'\!.
YOU are funher ordcn:d 10 brin@ 10lhe COli fen 'lice:
II) alrue copy of your m.m recenl h/dcrallnc,,,"c Tn Relum. incfudinll W-2'u, filed
(2) your pay Slu'" ",r the pn.'C.'tlinll sis '''1 monlhs
(3) the Inc,,,"c and hfl'.'II'it: Statemenl allachN 10 Ihis ordt..... completed as mjUired by Rule
1910.lltl
(4) ~crirlClllitlll of child can: "spense.
(5) "",,,f of m.'tlical co~era@c which you may hne. or may have a~ailable 10 you
!
I
I
I
I
I
If you fail 10 sppear for Ihe confcn:nce or brilll! the mjUired documents. the Coun may issue.
WHrranl for your airel!.
ce: Ruby WccLs. Esq.
ce: Sally Windt..... bq.
Ill' TilE COURT.
lIamld E. Sheely. Pmidenl Judce
7}l.;JL~
R.J.. y. ConftImICC OI11ccr (j
Ualc of o"":r: ADriI 18. 1'l'l7
VOll HAVE THE RI(;HT TO A LAWYER. WHOE MAY AlTENDTHE CONFERENCE AND
REPRr.sENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFfORD ONE. GO TO
OR TELEPHONE THE OrnCE SET FORTH BEU1W TO FIND OUT WHERE YOU MAY GET
LE(;AL HELP.
......,...."..
'Y
nJlIRl AIlMINISIRATOR
1I1IIRIII II OOR
CUMIlt.R!.ANIH1J1JNIY OltlltlllOIlSE
CARUS!.L rtNNSY\.VANIA 17013
1717124lU>~
PATIlICIt W. 1I0UII, I III 'rU COURT 0.. COIGIOII PLDI 0..
P1aillt1ff I CUIlIIDLAND COUIITY, PIIlHIYLVlIJfIA
I
v.. I CIVIL ACTIOII - LAW
I III DIVORCE
WIIID'f L. 1lGU11, I
Defendallt I 197-1414 CIVIL T!IUC
.ftr~tOll ..,. a....." OP ALYIIftIIY. &L11ItWY PmlDEIftII: LIft.
mtJJrr eoBft. (!OUJIBRL nw8. BOUt'P..T" Dt8TRtBUTtQ..
awn l.mlD..... _In tKIP
1'0 DB 801l0UBLI, DB JUDGII 0.. lAID ~I
COIII:I 1lOIf, Defendant, WENDY L. NORRIS, by her attorney, Ruby D. W..k.,
I.quire, and .he re.pectfully repre.ent. thatl
1. Plaintiff i. PATRICK W. NORRIS, an adult individual re.iding at 8117 Molly
Pitcher Highway, Shippen.burg, Franklin County, penn.ylvania, 17257.
2. Defendant i. WENDY L. NORRIS, an adult individual re.iding at 15 Scrafford
Street, Shippen.burg, CUmberland County, Penn.ylvania, 17257.
3. Plaintiff and Defendant are hu.band and wife, having been married on
Septeeber 4, 1982. Plaintiff filed a eamplaint in Divorce on March 21,
1997.
.RmJRft PO. DrvYatOll OP paft..~
4. The partie. purcha.ed or otherwise obtained during the coure. of t.helr
..rriage property which i. con.idered "marital property".
5. Upon entry of a divorce decree, .uch property ehollld be divided efII&itably
.. 1& jll.t and proper.
rntIINtn. ....~ m~a .,...._.
5. Defendant, VIRD'f L. NOaAIS, ha. retained the eervicee of auby D. ......
I.quire, and the coun.el f..., coat., and e"pell..e for repnMlltatloa 1a
thie action will be ellb.tantial and continlling.
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cA JUH 1 8 1997
4. Petitioner has requested from Respondent informally and through Respondent's
counsel, the release of certain personal property from the marital home to Petitioner. The items
requested are items not necessaay for the maintenance of the marital home or for the parties minor child.
S. On May 18, 1997, certain items were given by Respondent to Petitioner by
Respondent setting these items out of the marital home am! Petitioner picking up boxes ofi(ems.
6. Respondent refused to provide or release personal property which is the
separate personal property of the Petitioner which was acquired by him prior to marriage, was
given to him as gifts during the marriage, or which are items particularly used by Petitioner and of
no use or substantial value to Respondent. These items which are listed on Exhibit" A" attached
hereto and incorporated herein by reference, are ordered to be delivered to Petitioner until any
further Order of Court or agreement resolving equitable distribution of marital assets pursuant to
the divorce action filed in this matter.
7. Petitioner believes and therefore avers that all of the personal property listed on
Exhibit" A" incorporated herein by reference, would be awarded to Petitioner in the event of any
Master's hearing dividing all marita1 assets and that the Respondent has no use for these particular
items other than to refuse to give them to Petitioner IS a tactic of annoying and aggravating
Petitioner and having the only intention of depriving the Petitioner of the use and enjoyment of
those things which were used primarily by him during the course of tile marriage.
8 Petitioner is not able to replace many of these items \)e<-~,,9(' they were
gifts or have particular importance or meaning to tile Petitioner Additiona11y. Petitioner believes
that other items of persona1 property may be damaged by Respondent if they arc not released to
him immediately
.,
.
9. Respondent. WENDY L. NORRIS. will sutTer no harm if the Court grants the
special relief requested.
10. Petitioner has no adequate alternate remedy at law.
II. Respondent is in possession and in control of the marital residence and has
damaged other items of the Petitioner by throwing them forcibly out of the residence.
12 Petitioner has attempted to obtain these personal property items previously by
request through Respondent's counsel and was told that Petitioner would receive what
Respondent fdt like giving him on May 18. 1997 and that he would not be advise of which items
he would receive until he appeared on May 18. 1997 to get them .
WHEREFORE. Petitioner respectfully requests this Court to issue a Rule to
Show Cause why the special injunctive rdief ordering that all personal property listed on ExJu'bit
. A. as attached to this Petition should not be returned to Petitioner immediately. Rule retumable
within ten (10) days of the Rule or at time of hearing as scheduled in the Rule to Show Cause.
Further ordering that Respondent shall take no action to ranove the personal property from
I 5 Sc:raft'ord SIn:et. Shippensburg, Pennsylvania, unless it is being released to Petitioner and that
Respondent shall be responsible and filWlCially liable for any damage occurrina to any personal
property listed on Exhibit . A' from the date of filing this Petition until there is any cIistriburion or
disposition of the property in the divorce action And order any other relicf'dll-ed appoopriate
by the Court as necessary and proper
RespectfWly submitted,
Date b J I" h~ 1 ,X(] # J u '-- JL~ )~
~ ~.A""'r.rPlaladlr
)
I
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Penon" property
aU camping equipment including stove, cookware, lantern, s1~g bags, tent
bar - refrigerator &: stand, shell lamps, g1uses, signs, advertisements, etc.
dragon stand
aU stereo equipment
hand tools, tool boxes, nuts, bolts, nails
I bookshelf
an assortment of pictures from beginning to present
Oriental rugs
mink blanket
non-sport cards
two (2) motorcycle helmets
gas grill
lawn tools
coolers
coDection of over 200 horror books that were on bar
car parts &: equipment
mugs
notarized copies of aU ofDaysha'. paperwork
civil war book
Tune-Life series books
Danyl's c:ookbooks
WilsonlWJZard bearatone with box
35 nun camera
TV and VCR
EXBI81T"A"
PATRICK W. 1I0UIS,
Plailltiff/ReSpondent
III THE COURT 0.. COMMOII PLIAS 0..
CUMBERLAND COUIITY, PIIlHSYLVANIA
v.
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.
CIVIL ACTION - LAW
NUMBER I
97-1484
CIVIL
WENDY L. IIOUII,
Defelldant/Petitionsr
AIID 1I0W this
"
1.1 day
OaDn or COURT'
of June, 1997, upon motion of Ruby D. Weeks,
I
Esquire, and in consideration of the within Petition for Special Relief, it ie
~ID 8Il4 DIRECTED that a Rule to Show Cause why the relief requested directing
Plaintiff to make regular monthly payment on the home equity loan should not be
granted. Rule returnable at a hearing scheduled for the 30th day of June, 1997,
I
at 2130 O'clock, p.m. in Court Room No.3, 4th floor, of the CUmberland COunty
~
COUrthouse, 1 South Hanover Street, Carlisle, Pennsylvania 1'013.
..
,;
Service shall be upon Sally J. Winder, Esquire, attorney of record for
Respondent, Patrick W. Norris.
By the Court,
J.
'ADlClt W. IIOUII,
.lalntlff/Respolldent
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.
I
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III 'rill COURT 0.. coMMOlI PLIU 0..
CUJCIIEIlLAND COUNTY, PEIIIIIYLVAIIIA
CIVIL ACTION - LAW
v.
Il\IIIBIIlI
'7-1484
CIVIL
WlXDY L, IOUII,
DefeIl4allt/petltiolle~
ORDft or t'!O~
AJlD", this
day of June, 1997, after hearing on the Defendant-
wife's Motion for spacial Relief, it is ordered and directed that the wife ehall
pay the firet mortgage each month and the Husband the heme equity loan until such
time .. equitable distribUtion is accomplished or the marital reeidence i. eold.
By the court,
J.
CCI Ruby D. Weeke, Eequ1.re
.aUy J. Winder, .equire
PATRICK W. 1I0RRIS,
Plaintiff/Respondent
III THB COURT or CONNON PLlAS 0..
CUMBERLAND COUNTY, PENNSYLVANIA
v.
.
.
I
I
.
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.
I
CIVIL ACTION - LAW
WEND'f L. 1I01UlIS,
DefeDdant/Pltitionlr
NUMBER.
97-1484
CIVIL
PRTITION JiOR .PR~Ia.,~ -'".tRIP PURStJAN'l' TO
Pa. R.e... 1920..] and 23 Pa. ~.S.A. ]]231~)
TO 'rill BOIIOIABLI, 'rill JUDGES 0.. SAID COURT.
CONIS liON, WENDY L. NORRIS, Defendant in Divorce and Petitioner by and
through her counsel, Ruby D. Weeks, Esquire, and petition. the Court for Special
Relief pureuant to Pa. R.C.P. 1920.43 and 23 Pa.C.s.A. 3323(f) and in support of
her Petition, represents as fOllows.
1. The Petitioner is WENDY L. NORRIS, who currently resides at, and
whose mailing address is, 15scraffordStreet,shippensburg,
~xmberland County, Pennsylvania, 17257.
2. The Respondent PATRICK W. NORRIS, who currently resides at, and
whose mailing address is, lllEastOarfieldStreet,Shippensburg,
Pennsylvania, 1'257.
3. The parties were married September 04, 1982, and have re.ided at 15
Scrafford Street, Shippensburg, Cumberland County, Pennsylvania,
frail 1993 until Petitioner IDOved from the marital residence January
24, 1997.
4. The Wife presently works three pert-time jobs cleaning I Agway,
Shippen.burg, Presbyterian Church, and for a private party, ..king
a IDOnthly net of $863.00.
5. The Hu.band 1. a sanitation-engineer with Resku ClIee.. with a
BCnthly net of $1,785.00 after a voluntary job changa witb the ....
employer. In 1996 the Husband's monthly ~et wa. $1.993.00.
6. The parties have payments for a first mortgage of $518.51 per month
through PNC Bank, and a second, home equity loan of $348.45 per
month through PNC Bank. The home equity loan consolidated joint
marital debt and the debt for the partie.' two vehicles.
7. Wife paid January, February, and March payments from funds provided
by Husband for this purpose. She used funds from a joint account
which she placed in an account in her name only, originally
$2,950.00, to pay 1996 joint, federal and local taxee ofl $611.00
federal, $318.1' local, a total of $929.17, and for the April and
May 199' mortgage payments of $518.51 each, leaving a balance of the
joint funds of $1,303.00 which Husband has directed she not use.
see attached letter from Sally J. Winder, Esquire dated May', 1997
attached hereto and made apart hereof.
She therefore, scraped
together the mortgage payment from her eeparate earnings for June.
The Husband arranged for an extension until July 1, 199' for payment
on the home equity loan and no payments have been made on that loan
since March because Wife is unable to do so.
8. At a May 6, 199', hearing Wife was awarded alimony pendente lite of
$43.00 per week plus $5.00 to arrears and child support of $69.00
per week plus $5.00 to arrears or a total of $524.60 per month, for
combined income from all sources of $1,387.60.
,. Wife listed total monthly expenses of $2,273.71, which included
peyment of the 1st and 2nd mortgages.
10. The marital residence has been listed for eale.
11. The Wife made-mortgage payment. from joint fund. she removed to an
account in her separate name since Husband wa. refusing to pay on
the mortgage or home equity loan, which also include paymente for
~her joint lIlllrital debta and Hullb8nd'. ear. He eontin\le. to refuse
t
~
to .gree to have her pay on the.e obligation. from t~e joint fund.
.nd Wife c.nnot afford to m.ke both p.yment..
12. If Wife'. credit i. ruined becau.e .he cannot p.y theae debt., it
re.idence .ince ahe will be unable to obtain credit.
t
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i
,
will be difficult for her to relocate her'. .nd the child'.
13. Hu.band .hould .t le..t be ordered to pay the home equity 10.n to
the extent I.id payment repre.ente money borrowed for the vehicle he
drive..
WIBRIPORI, Petitioner re.pectfully reque.t. this Court to i..ue . Rule to
Show C.u.e why the .peci.l injunctive relief ordering that Hu.band be directed
to pay the regular monthly payment on the home equity lo.n. Rule returnable
within ten (10) day. of the Rule or .t t~ of hearing .. .cheduled in the Rule
to Show Cau.., and to order .ny other relief deemed .ppropriate by the Court ..
nece...ry and proper.
D.te. r~"~1?
Re.pectfully .ubmitted,
s~ L~Q-
Ruby D. eek., I.quire
10 Welt High Street
C.rli.le, PA 17013
717-243-1294
eel Ruby D. Week., I.quire
S.lly J. Winder, I.quire
.-.
SAl.LY J. WINDER
AI/orneya/ Law
rJ ,'I lVrll :I:ii I).:j 1~9l
701 E. KING STREET
SlIIrI'ENSDURG. rA I72S7
TElF.rIlONE (7171 SJ2.947fi
FAX (717,532.3713
May 07, 1997
RUBY D. WEEKS, ESQ.
10 WEST 1IIG11 STREET
CARLISLE PA 17013 -1955
RE: NORRIS v. NORRIS
Dear Ms Weeks:
This letter is to advise you that your client. Wendy L. Norris is not authorized to make any
further payments from joint assets, that is. the balance ofS3,074.34 plus any additional
amounts received from your client from the PFS Shareholder Services account. Mr Norris
will not agree that any mortgage payments, home equity loan payments. or any other
expenses be paid from that balance. As requested at the support conference on May 06,
1997, please respond in writing to my last letter.
This letter will also serve as confinnation that Mr Norris may get his personal property
and items requested on Sunday. May 18, 1997. Ifany of those items are damased. then
Mr Norris may choose to pursue claims sgainst Mrs Norris.
Also, as your client is well aware, the registration for the van needs to be renewed. The
registration card was mailed to the ScnfTord Street address. Please have your client
provide to my client the signed registration application on or before May 09, 1997.
Otherwise, Mr Norris will either have to switch vehicles with Mrs Norris so that she can
take care ofthe registration or file a Petition witli the Court to require her signature on the
registration. Both alternatives seem ludicrous in light ofthe ease or providing the .
registration ronn and the past cooperation of Mr Norris in signing the registration renewal
for Mrs Norris on the Metro.
Iy yours,
\)UJ(~-
inder
xc: Patrick Norris
- ,....
PATRICK W. NORRIS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: DOMESTIC RELATIONS SECTION
Edgar B. Bayley, J.
V.
WENDY L. NORRIS,
Defendant
.
: PACSES NO. 946000056
: I N07'S't.;1484CIVII,;';!1'
',.. .... " '^ .. __.. .. .... '0 '. ".... .'.,~ .--' ........ ,_ .... __, '. ....
tmRlM ORDER OF COUBT
AND NOW, this 6th day of February, 2002, 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:
Our prior order of May 6, 1997, awarding alimony pendente lite is
terminated effective June 1, 2002.
The parties are hereby advised that they may file written exceptions to the
Support Master's Report and Recommendation within ten (10) 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 ten (10) days of the date of service of the original exceptions. If no
exceptions are filed within ten (10) days of this interim order, this order shall then
constitute a final order.
CC: Patrick W. Norris
Wendy L. Norris
Ruby D. Weeks, Esquire
DRO
PATRICK W. NORRIS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: DOMESTIC RELATIONS SECTION
: PACSES NO. 946??oo56
: NO. 97-1484 CIVIL
V.
WENDY L. NORRIS,
Defendant
SUPPORT MASTER'S REPORT AND RECOMMENDATION
Following a hearing scheduled before the undersigned Support Master on
January 29, 2002, the following report and recommendation are made:
FINDINGS OF FACT
1. The Plaintiff in this divorce action is Patrick W. Norris, who resides at
511 West King Street, Shippensburg, Pennsylvania.
2. The Defendant is Wendy L. Norris, who resides at 26 South Queen
Street, Shippensburg, Pennsylvania, and whose mailing address is
P.O. Box 144, Shippensburg, Pennsylvania.
3. The parties are husband and wife, having been married on September
4,1982.
4. This divorce action was filed on March 21, 1997.
5. The Defendant filed a petition for alimony pendente lite on April 17,
1997.
6. By order dated May 6, 1997, the Plaintiff was obligated to pay to the
Defendant the sum of $186.33 par month as APL.
7. On November 28, 2001, the Plaintiff filed a petition to modify his APL
obligation.
8. The Defendant is QJrrently residing with another man with whom she Is
having a sexual relationship.
9. The Defendant is amlf'ltly pursuing a Bac:helar's Degree in IOClaI wori(
at ShippensWg University. She began her studies in JIRJaty, 1998.
10. The Defendant anticipates graduating from ShippeNbu'g UrWwIlty on
May 11, 2002.
Exhibit "r."
11. The Defendant is serving an internship with Cumberland County
Children and Youth Services and is receiving a stipend of $680.00 per
month. This is her only source of income.
12.A condition of the Defendant's stipend is that she accept employment
with a county Children and Youth Service Office within 60 days of her
graduation.
13. The Defendant intends to become employed as a caseworker with a
Children and Youth Service Office and anticipates an annual income of
$27,000.00 per year.
14. The Plaintiff is employed at Raskas Cheese Products where his
average gross weekly income is $648.00.
15. The parties are the parents of one child, Daysha N. Norris, born April
27, 1985, who is currently placed in a drug rehabilitation center through
Cumberland County Children and Youth Services.
16. The Plaintiff is obligated to pay $69.00 per week for the support of said
child, and the Defendant is obligated to pay $35.00 per month for the
child's support
17. Before entering college the Defendant was a self-employed
housecleaner earning approximately $200.00 per week.
18. The Defendant is funding her education primarily through loans and
grants.
PISCUSSIQrj
Alimony pendente lite has been defined as "an order for temporary
support granted to a spouse during the pendency of a divorce or annulment
proceeding." MYsko v. ~usko, 54 Pa. 378, 380,697 A.2d. 255,256 (1997). One
of the primary differences between APL and spousal support is the effect marital
misconduct on the part of the dependent spouse will have on the award. A
dependent spouse who is guilty of martial misconduct forfeits her claim to
spousal support, while such a spouse is still eligible to receive APL. tlansoJn v.
t1anson. 177 Pa. Super. 384, 110 A.2d. 750 (1955). Therefore, the fact that the
Defendant in this case is now residing with and engaged in a sexual relationship
with another man does not provide a basis for immediate termination of the APL
order.
The law is clear, however, that an order of APL may be modified or
vacated by a change in circumstances, ~itmans v. Litmans, 449 Pa. Super. 209,
673 A. 2d. 382 (1996). The burden is on the party seeking to modify the order "to
.
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~
show by competent evidence that a change of circumstances justifies a
modificetion." l.itmans, 449 Pa. Super. at 223.
Graduation from college with the anticipated annual eamings of
$27,000.00 as opposed to earning $10,000.00 per year as a cleaning lady
qualifies as a change of circumstances that would justify a termination of the APL
order in this cese. The Defendant is scheduled to greduate on May 11, 2002.
She will be given until the end of that month to become employed in har chosen
field. Should, for some unforeseen reason, she not graduate on that date, she
may petition the Court for a reinstatement of the APL order.
x
~
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Our prior order of May 6, 1997, awarding alimony pendente lite is
terminated effective June 1, 2002.
~ll..QDJ...a ~_
Michael R Rundle
Support Master
PATRICK N. NORRIS
PACSES Member Number: 2888000026
CHECKS SHOULD BE MADE PAYABLE TO: DOMIlSTIC RBLATIONS SBCTION
AND SENT TO THE DOMESTIC RELATIONS SECTION AT:
P.O. BOX 320. CARLISLE, PA. 11013
This order of attachment for support is binding upon you until further notice and shall have
priority over any attachment, execution, garnishment or wage attachment under state or local
law except one relating to a prior support order. You must commence the attachment of the
defendant obligor's income as soon as possible but no later than fourteen days from the date
of the issuance of this Order of Attachment.
You are notified further that pursuant to law:
1. The defendant obligor has been notified that an order of attachment for support would
be issued.
2. WIllful failure to comply with this order may result in (i) your being Idjudged in contempt
of court and committed to jail or fined by the court; (il) your being held liable for any
amount not withheld or withheld but not forwarded to the Domestic Relations Section; and
(ill) attachment of your funds or property.
3. The al;fll('llment of income or the possibility thereof as a basis, in whole or in part. for the
disclwae of an employee or any disciplinary action against or demotion of an employee is
prohibited. Violation may result in (i) your being Idjudged in contempt IIld committed to
jail or fined by the court and (ii) an action against you by the employee for dam...s.
..... 1 of 4
F<<'8IIiN~
Worker ID UATl'
Service Type M
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PATRICK W. NORRIS
PACSES Member Numhcr: 2888000026
4. If there are in your employment one or more additional employees whose incomes are
subject to the Order of the Court of Common Pleas of CUMBERLAND County
for attaChment of support. you may combine the attaChment payments into a single
payment to the Domestic Relations Section and separately identify the portion attributable
to each obligor.
S. You must notify the Domestic Relations Section when the defendant obligor terminates
employment and provide the Section with the employee's last known address and the name
and address of the new employer, if known.
6. The UlarUnum amount of the attachment shall not exceed 50 II of the employee's
net income which is within the limits set in the Consumer Credit Protection Act, IS
U.S.C. 11673.
7. The term .income. as defined by law includes compensation for services, including, but
not limited to, wages, salaries. fees. compensation in kind, commiuions and similar
items; income derived from business; gains derived from dealings in property; interest;
rents; royalties, dividends. annuities; income from life insurance and endowment
contracts; all forms of retirement; pensions; income from discharge of indebtedness;
distn'butive share of partnership gross income; income in respect of a decedent; income
from an interest in an estate or trust; military retirement benefits; railroad employment
retirement benefits. soc:ial security benefits; temporary and permanent disability benefits;
worker's compensation and unemployment compensation.
..... 30(4
fonn EN.on
Worker 10 $IATT
Service Type M
, ,
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
Defendanr Name: PATRICK W. NORRIS
Member ID Number: 2888000026
PIoaw..... All r.......IIOIIdaIr. 0111II iorlotlr Illr .\1101"" ID :\'011I"".
RASKAS CHIlESE PRODUCTS OF PA
208 E DYICEMAN RD
SHIPPENSBURG PA 1'257-8700
A.'fENDED
ORDER OF A1TACHMF.NT OF IN(,O~
PIa_iff NaIM
IDDY L. 1IDQ18
IDDY L. 1IDQ18
n""........ Br-Ir Down 01 MaII'_ r~._ on AIta_ent
PACSES
C... N_r
111000042
'45000051
Docta
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J1 CV UIt
D-26392
D-26491
AIbdt~ AmnuIIIn:--~
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$ I
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TOTAL AnACH.\IE.'oT A\fOt.'llf'TI. U5.00
To: RASKAS CHusE PRODUCTS OF PA
Pursuant to the laws of the Commonwealth of Pennsylvania the income of
PATRIOt w. NORRIs . defendant obligor. SSN 182-56-0837
of:
111 E GARFIELD ST, SHIPPENSBURG, PA. 1'257-1905_11
is hereby attached to the following extent.
You are directed to pay to the OffICe of the Domestic Relations Section of the COUrt of
Common Pleas of ctlGERLl\ND Counry the sum of S 125.00 per
WEIIt from the income due the defendant obliJor. The attachment payment
must be sent to the Domestic Relations Section within ten days of the date the defendant
obligor is paid.
$mkc T)'JlC M
Form EN.()24
WOlter 10 21205
.~~ ?/e/qr W
.
PATRICK W. NORRIS
PACSES Member Number: 2888000026
CHECKS SHOULD BE MADE PAYABLE TO: DOMESTIC RELATIONS SECTION
AND SENT TO THE DOMESTIC RELATIONS SECTION AT:
P.O. BOX 320. CARUSLE, PA. 17013
This order of attachment for suppon is binding upon you until funher notice and shall have
priority over any attachment, execution, garnishment or wage attachment under state or local
law except one relating to a prior suppon order. You must commence the attachment of the
defendant obligor's income as soon as possible but no later than fourteen days from the date
of the issuance of this Order of Attachment.
You an: notified funher that pursuant to law:
I. The defendant obligor has been notified that an order of attachment for suppon would
be issued.
2. Willful failure to comply with this order may result in (i) your being adjudged in contempt
of COlIn and committed to jail or fined by the coun; (ii) your being held liable for any
amount not withheld or withheld but not forwarded to the Domestic Relations Section; and
(Hi) attachment of your funds or propeny.
3. The attachment of income or the possibility thereof as a basis, in whole or in pan, for the
discharJe of an employee or any disciplinary action against or demotion of an employee is
prohibited. Violation may result in (i) your being adjudged in contempt and committed to
jail or fined by the COlIn and (ii) an action against you by the employee for damages.
ScM..-c Type M
Pqe he 4
Foon EN'()28
Wlln.cr 10 21205
I ~
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PATRICIC W. NORRIS
PACSES Mcmhcr Numhcr: 2888000026
4. If there are in your employment one or more additional employees whose incomes are
subject to the Order of the Coun of Common Pleas of CUMBBRLAND County
for attachment of suppon, you may combine the attachment payments into a single
payment to the Domestic Relations Section and separately identify the ponion attributable
to each obligor.
S. You must notify the Domestic Relations Section when the defendant obligor terminates
employment and provide the Section with the employee's last known address and the name
and address of the new employer, if known.
6. The maximum amount of the attachment shall not exceed 55 " of the employee's
net income which is within the limits set in the Consumer Credit Protection Act, IS
U.S.C. 11673.
7. The term .income. as defined by law includes compensation for services, includilll, but
not limited to, wages, salaries, fees, compensation in kind, commissions aDd similar
items; income derived from business; gains derived from deallllls In property; Interest;
rents; royalties, dividends. annuities; income from life insurance aDd endowment
contracts; all forms of retirement; pensions; income from discharJe of indebtedness;
distributive share of pannership gross income; income in respect of a decedent; income
from an interest in an estate or trusl; military retirement benefits; ralll'Old employment
retirement benefits, social security benefits; temporary aDd permanent dlsabUIty benefits;
worker's compensation and unemployment compensation.
Strvkc Type M
Pqc 3 of 4
Ftlna BN-G2I
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PATRICK W. NORRIS
PACSES Member Numher: 2888000026
GENERAL INSTRUCTIONS
1. Employers may elect to deduct up to 2 % of the attachment amount for their costs. This
amount must not be deducted from the attachment. It must be paid from the employee's
net earnings after the income attachment deduction has been made.
2. Dates monies were withheld from the employees' pay must be provided on the payment
transmittal form to the Domestic Relations Office.
3. If you choose to make payments via an electronic funds transfer. instructions may be
requested from the Domestic Relations Office.
BY mE COURT:
/'
.,
Date of Order:
-''',ust 11. 1998
Edgar B.
JUDGE
Dl0. I.J. Shadda,
cc: defendant
So:l\'ke Type M
I'qI: 4 of 4
Form EN.()'lI
WortCl'IO 21205
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
Defendant Name: PATRICK W. NORRIS
Member 10 Number: 2888000026
....... JlGIc: AD corrapoadal<t 18111t _1IIc MaDbcr 10 SlIIDbcr.
RASItAS CHEISE PRODUCTS OP PA
208 I DYKEMAN RD
SHIPPBNSBURG PA 17257-8700-08
A.'lENDED
ORDER OF ATl'ACHMENT OF INCOME
1i'I...tvI.1 BrMk Down ar Muldole c..... on Atta""lIWftf
PIa'" Name
_ L. IIOIRIS
_ L. IIOUIS
PACSES
Ca. Number
:l{~ 39.). IUOOOOU
tilt. I/If , "10000..
Docl:d
l!l!IIIm
321 S "
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TOTAL AlTACHMENI' AMlHlNJ':' 112.00
To: RASItAS CHUSB PRODUCTS OP PA
Pursuant to the laws of the Commonwealth of Pennsylvania the income of
PATRICJ( If. NORRIS . defendant obligor, SSN 182-55-0078
of:
111 B OARFIBLD ST, SHIPPENSBUIlG, PA. 1'25'-1905-11
is hereby attached to the following extent.
You are directed to pay to the Office of the Domestic Relations Section of the Court of
Common Pleas of
County the sum of S 112.00
CtIMBIllLAND
per
IfBIK from the income due the defendant obligor. The attachment payment
must be sent to the Domestic Relations Section within seven business days of the date the
defendant obligor is paid.
Sanice Type M
Form SN.o1I
Worbr ID tun
PATRICK W. NORRIS
PACSES Member Number: 2888000026
4. If there are in your employment one or more additional employees whose incomes are
subject to the Order of the Coun of Common Pleas of CUMBERLAND County
for attachment of suppon, you may combine the attachment payments into a single
payment to the Domestic Relations Section and separately identify the portion attributable
to each obligor.
S. You must notify the Domestic Relations Section when the defendant obligor termin.t..,
employment and provide the Section with the employee's last known address and the name
and address of the new employer, if known.
6. The mnimum amount of the attachment shall not exceed 50 S of the employee's
net income which is within the limits set in the Consumer Credit Protection Act, IS
U.S.C. 11673.
7. The term "income" as defined by law includes compensation for services, includiDs, but
not limited to, wages. salaries, fees, compensation in kind, commiqions and timllar
items; income derived from business: gains derived from dealinp in property; interest;
rents; royalties, dividends, annuities; income from life insurInce and endowment
contracts: all forms of retirement; pensions; income from discharge of indebtedness;
distributive share of partnership gross income; income in respect of a decedent; iDcome
from an interest in an estate or trust; military retirement benefits; railroId employmeat
retirement benefits, social security benefits: temporary and permanent disability beneflts;
worker's compensation and unemployment compen..rion.
Service Type M
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In tbe Court or Common Pleas or CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
Defendant Name: PATRICK W. NORRIS
Member ID Number: 2888000026
~..... AD cornspoadeace mllll _ tile M..ber m Somber.
JlASItAS CHBBSB PRODUCTS 0'
208 B DYItBMAN RD
SHIPPINSBURG PA 1'25'-8700-08
JAN to 2000
A.'1ENDED
ORDER OF ATTACHMENT OF INCOME
If'I..........1 Break Down or Mold. r.... on Au_rInnHlf
P"CSD Docbl
P1aiBdff NltnII Cite Number tiIImIts:
IIDIlY L. lIOU1a Jl(,39~ .u....u 32' s n
--- -~'.;.lp.~"'".C''''",;''+..,.r,,:.,..~. ,," CYi,U84,',
.11-"-..1 AmnDIIIlf'... y
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TOrAL A1TACHMENT AlIIOt'ST. . 11'."
To: JlASItAS CHBBSI PRODUCTS or
Pursuant to the laws of the Commonwealth of Pennsylvania the income of
PATIl1CX W. NOBIS . defendant obligor, SSN 182-56-0071
of:
111 I GARrIBLD ST, SHIPPlllSBUIG. PA. 1'25'-1'05-11
is hereby attached to the following extent.
You are directed to pay to the Pa State Collection and Disbursement Unit the sum of
$ lIt.50
from the income due the defendant obligor. The
per
WlBIt
AltJl('hmttlt payment must be sent to the Pa State Collection and Disbursement Unit within
seven business days of the date the defendant obligor is paid.
CHECKS SHOULD BE MADE PAYABLE TO: PA SCDU
AND SENT TO:
Pennsylvania SCDU
P.O. Box 69112
Harrisburg. Pa 17106-9112
s.m.:. T)'pt M
Form EN-OlI
Worbt 10 $tATT
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JAN 2 0 2000
PATRICK If. NORRIS PACSES Member Number: 2888000026
PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES
MEMBER ID OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO
NOT SEND CASH BY MAIL.
This order of attachment for support is binding upon you until further notice and shall have
priority over any attachment, execution, garnishment or wage attachment under state or local
law except one relating to a prior support order. You must commence the attachment of the
defendant obligor's income as soon as possible but no later than fourteen days from the date
of the issuance of this Order of Attachment.
You are notified further that pursuant to law:
I. The defendant obligor has been notified that an order of attachment for support would
be issued.
2. Willful failure to comply with this order may result in (i) your being adjudged in contempt
of coun and committed to jailor fined by the court; (il) your being held liable for any
amount not withheld or withheld but not forwarded to the Domestic Relations Section; and
(ill) attachment of your funds or property.
3. The attachment of income or the possibility thereof as a basis, in whole or in part, for the
discl1ar&e of an employee or any disciplinary action against or demotion of an employee is
prohibited. Violation may result in (i) your being adjudged in contempt and committed to
jail or fined by the coun and (ii) an action against you by the employee for damages.
4, If there are in your employment one or more additional employees whose incomes are
subject to an attachment of support, you may combine the attachment payments into a
sinale payment to the Pa SCDU and separately identify the portion attributable to each
obligor.
5. You must notify the Domestic Relations Section or the Pa SCDU when the defendant
obligor terminates employment and provide the Section with the employee's last known
address and the name and address of the new employer, if known.
..... 2 of 3 Form EN .028
Servi<e Typt M Worlter to $IATT
.
.
.IAN 2 0 2lJI
PATRICK 91. NORRIS PACSES Member Number: 2888000026
6. The maximum amount of the attaChment shall not exceed 50 % of the employee's
net income which is within the limits set in the Consumer Credit protection Act, IS
U.S.C. S1673.
7. The term .income. as defined by law includes compensation for services. including. but
not limited to, wages. salaries, fees, compensation in kind. commissions and similar
items; income derived from business; gains derived from dealings in property; interest;
rents; royalties; dividends; sonuities; income from life insurance and endowment
contraCts; all forms of retirement; pensions; income from discharge of indebtedness;
distributive share of partnership gross income; income in respect of a decedent; income
from an interest in an estate or nust; militarY retirement benefits; railroad employment
retirement benefits; social security benefits; temporary and permanent disability benefits;
worker's compensation; unemployment compensation; other entitlements to money or
lump sum awards. without regard to source. including lottery winnings; income tax
refunds; insurance compensation or seulements; awards or verdicts; and any form of
payment due to and collectable by an individual regardless of the source.
~ENERAL INSTRUCTIONS
t. Employers may elect to deduct up to 2% of the attaChment amount for their costs. This
amount must not be deducted from the attaChment. It must be paid from the employee's
net earnings after the income attaChment deduction has been made.
2. If you choose to make payments via an electronic funds tranSfer. contact the Pa SCDU
Employer Customer Service at 1-877-616-9580.
...Date of Order: Jan\luy 21. 2000
Daol 1U Shadday
xc:. defendant
Servke Type M
JUDGE
FoI'III EN.m&
WorbflD StAn
EdlU B. Bayley
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Student Loan Servicing Center
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11/02100
LOAN DETAIL SHEET
Below is the pertinent information for the loan(s) referenced in the
enclosed letter I
LCWI P_AII: snfRD CURRINT PRINCIPAl: tz,'73."
CUS.INT ONNlR. KlYSTllNl 5 PAYOff INTlRfST. .....
DATI DISBURSID. .911212... LATI fll. .....
DAILY TNTf.Rfn ..... PAYOff AIICMIT: $2,.n. ..
lCWI I'ROGllAII: snfRD CUlRfNT PRINCIPAL. 15,'.....
CUlRlHT ONNlR. KlYSTllNl S PAYOf' INTlRfST. .....
DATI DISMMSID: 111.511.., LATI fll: .....
DAILY INTlRIS T ..... PAYOff A/IlUIT. 15.'.....
lCWI I'ROGllAII. S"fRO CUlRfNT PRINCIPAl. '2,~,...
CUDINT ONNlR. KIYSTONl S PAYOff INTlRIST I .....
DATI DIS8UIISlD. 1811911'" LATI fll. .....
DAIl Y I",UIST ..... PAVOff AIICMIT. tz,us...
lCWI I'ROGllAII. STnRO CUlRlIIT PRINCIPAl: 11,525."
CUI.lIIT ONNlR I KlYSTllNl 5 PAYOff INTIRfST. .....
DATI DIS8UIISlD. .2/11/19.. LATI fll: .....
DAIl Y INTlRIST ..... PA_f AIICMIT. 11,525."
TSX2QIPSD6BTPO
2D946DU7
MR
GDD29DD5060DODDD7
HELP WANTED
Full- Time Custodian .
3 p.m. to 11 p.m.
Previous Work Experience as a
Custodian is Preferred.
$6.00-$6.75 per Hour
Excellent Benefit Package.
DeadUne for Applications: August 4, 2000
Send Applications to:
Franklin County Career & Technology Center
2463 Loop Road
Chambersburg, PA 17201
. Attention: Bryan Pefley, Maintenance Supervisor
(717) 263-0933x217
Type of ~ork:
Shift:
Experience:
Walles:
JOB FAIR
Saturday, August 5 11:00 am - 2:00 pm
I HOFFMAN MILLS, INC.I
35 Springhouse Road
Shippensburg, PA 17257
Stop by Hoffman Mills on Sat. and enjoy a hot dog and
soda while exploring the possibilities of a career in the
textile business. lob opponunities exist in all areas. Work
for a company that promotes from within, offers you a
challenge and cares about their employees.
.In addition to great career opponunities, Hoffman
Mills provides superior health insllJ'lllCe coverage;
paid vacation and holidays, 401(lt) plan, life insurance
and a company paid retirement plan.
Uyou can't make the lob Fair, you can apply M. F from
6:30 am . S pm or call to make an appointment that fits
mJ.l.R schedule.
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ENTRY LEVEL POSITIONS
NO EXPERIENCE NEEDED
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On-lhe-job training ptClvidad at _ IlltP ~ _ledder. Excelllnt oppor1IftlIae lor
.CNWtime. Proc:Iuc:tion incenllve ~ p8icI "ef)' two _ to qualifIecl_ Pll) ,'c 11
Md dtug -. ,.quit-.!.
s-litalnclude:
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. EmpIoyer-paid family Slue Cn>uIBIue ShIekf major madlcaI -..lIflIr Illur
montha
. Disability Insurance &tl8r Ibl montha
. LIfe Insurance aft<< one yMt
. 40111<I matctllng plM &tl8r one yMt
Fry Communicationa prints, binds, Md malls _1.5 mIIon -'II ~ ..Md~" 1c~I'_
lor publts/l&rw Iltl8the Old Fenner'I AIrnanec, the JC ~ ~ Md1V GuIaa.
Come join .... winning tMml
~~o.:.. office or aand murne to:
Fry Inc.
Human ~ Dept.
BOO W..t Chun:h Road
NechenIcaIlurg. At. 17055
Fa: 717-781-1855
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Penn~lvania
CoJCity/Disl. of CUMBERLAND
Date of Order/Notice 10{15{01
Court/Case Number (See Addendum for case summary)
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o Original Order/Notice
@ Nneoded Order/Nolice
o Terminale Order/NOIK:e
EmployerlWilhholde(, Fede..1 EIN Number
RASKAS CHEESE PRODUCTS OF
EmployerIWilhholde(, N.me
208 E DYKEMAN RD
EmployerlWilhholde(, Add",..
SHIPPENSBURG PA 1'257-8700
'RE: NORRIS, PATRICK W. Q4j/lCCO(')"'1l "
EmployeelObligo(, N.me 11..1'1, Fi,,~ Mil
182-56-0078 q7 c.V ~
Employee/Obligor', Saci.) Securily Number
2888000026 f>~~
EmployeelObUgor's ClSe Identifier
ISH AddPnduD IrK pI.mIiH".",.. modllPd with CIJfl .... IltlchmenlJ
Cu~Iodi.11 P,uenl', N.me (u:~.. First, Mil
See Addendum for dependent names and birth dates assodated with cases on attachment.
ORDER INFORMA TION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from ClJMBBRLAND County, Commonwealth of Pennsylvania. By law, you are required to dedua these
amounts from the above-named employee'sfobligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 186.33 per month in current support
$ o. 00 per month in past-due support Arrears 12 weeks orgreaterl @yes 0 no
$ 65.00 per month in medical support
$ o. 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 251.33 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:
$ 58.00 per weekly pay period.
$ 116 00 per biweekly pay period (every two weeks!.
$ 125.67 per semimonthly pay period (twice a month).
$ 251.33 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period octurringten (10) working days after the date of this
Order/Notice. Send payment within seven In working days of the paydateldate of withholding. You are entitled to
deduo a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
the allowable amount. The total withheld amount, and your fee, cannot exceed 55"1. of the employee'sf obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See 19 on pg. 2).
If remitting by EFTIEDt, please call Pennsylvania State Colleaions and Disbursement Unit (SeDU) Employer
Customer Service at HI77-676-9580 for instruOions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Boll 69112, Harrisburg, Pa 17106-9112
tN ADDITION, rA YMENTS MUST tNCLUDE THE OEffNDANT'S NAME AND THE rACS6 MEM'E.,D fsholl'll
abo~ as the EmpIoyHlO6lilW's Case ldentiliff) O' SOCIAL SECUIlTY NUMIE. IN C>>DE' TO IE rlOCESSED.
DO NOT SEND CASH .r MAIL.
Date of Order:
OCT 1 6 2001
Sell/ice Type M
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If checked you .,e required to provide a ropy of this form to your employee.
1. Priority: Withholding under this OrderlNotice has priority over dny other legdl process under State law alldin.t Ihe same income.
Federalta. levies in effect before receipt of this order have priority. If there are Federalta. levies in effect plea.e contact the reque'ling
ageney listed below.
2. Combining Payments: You can combine withheld amount. ~om more than one employee/obligor'. income in a .ingle payment
to each ageney requesting withholding. You must, however, separately identify the portion of the .ingle payment that is anributable to
each employee/obligor.
3,- ~t^".t;HA dn::; fltl7d.1JOA~ o(VJithhold;ug. Vott1mnt~~paydateldate-of ~ithkold;'I"~ ~nd:lrA fhe..pa7".~IIt. T~-
pa,da(ddol~ o( n:d.l.old:IIA i! d.l! dalt 01. nl.;,I. "'..ownt .~.u n:d.nefd "vlllhf!n.plo,f!p.'~~: You must romply with the Liw ofthe
state of the employee'slobligor's principal place of employment with respect to the time periods wilh'n which you must implement the
withholding order aod forward the support payments.
4.' Employee/Obligor with Multiple Support Holdings: If there is more than one OrderlNotice to Withhold Income for Support
alldinst this employee/obligor aod you are unable to honor all support OrderlNotice. due 10 Federal or State withholding limits, you mu.t
follow the law of the slale of employee'slobligor's principal place of employment. You must honor all OrdersINotices to the greatest
e.rent possible. (See '9 below)
5. Termination NOlifiColtion: You mu.t promptly notify the Requesting ^seney when the employee/obligor is no longer working for
you. Please provide the information requested aod rerum a copy of this OrderlNotice to the ^seney identified below.
WITHHOLDER'S 10: 4314735100
EMPlOYEE'S/OBlIGOR"S NAME: NORRIS. PATRICIt W ,
EMPLOYEE"S CASE IDENTIFIER: 2888000026 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 OrderlNotice directs, you are liable for both the accumulated amount you should
have withheld from the employee/obligor's income aod other penalties set by Pennsylvania Stare law. Pennsylvania Stare law governs
unless the obligor is employed in another Sldre, in which case the law of the Sldre in which he or she is employed governs.
8. AntKliscrimin.ltion: You are subject to a fine derermined under Sl.lre law for discha'lling an employee/obligor from
employment, refusing to employ, or l.lking disciplinary action alldinstany employee/obligor because of a support withholding.
Pennsylvania Stare law governs unless the ohligor is employed in another Sldte, in which Cd'" the law of the Sldre in whkh he or she i.
employed governs.
9.' Withholding limits: You may not withhold more than the lesser of. 1) the amounts allowed by the Federal Consumer Credit
Protection Act (1 S U.S.C. 51673 (hI 1 , or 2) the amounts allowed by the Sl.lre of the employee'slobligor's principal place of employment.
The Federal limit applies 10 the aasregare disposable weekly earningslADWEI. ADWE is the nel income left alrer maldf1ll mandalory
deductions such iU: Stare, Fedtml, Iocalta.es, Social Security la.es; and Medic.tre ta.es.
10.
. NOTE: If you Of your ..,t are served with a copy of thi~ order in the ~tate that issued the order. you are to follow the
law of the ~tate that issued Ihi~ order with l5PKl to these item~.
Rl!Que~tin. ^seney:
DOMESTIC RELATIONS SECTION
13 N. HANOVER Sf
P.O. BOX 3M
aRLlSLE P." 17013
If you or your employeeloblilOf NIve any Questions.
contact WAGE ATTACHMENT UNIT
by telephone at l7171 24G-622S or
byFAXatl71712~411 or
by Internet .
~MCl! T)-pt' M
Page 2 of 2
Fonn EN'()28
Woricer 10 StATT
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
lIENDY L. NORRIS ) Duckel Number 9' c:v 1484
Plaimiff )
VS. ) PACSES Case Number 946000056
PATRICK W. NORRIS )
Defendant ) Other State ID Number ~lo~g I
PETITION FOR MODIFICATION
OF AN EXISTING SUPPORT ORDER
I. The petition of
PATRICK W. NORRIS
respectfully
represents that on MAY 6, 1997
. an Order of Coon was entered for the
lIENDY L. NORRIS
A true and correct copy of the order is allldled to this petition.
5ct'vlce T)1lC M
I'tlm'l OM.~1
Wilner 10 21205
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
li:/ j;/i 5' J'lr,'-;
State Commonwealth of PenMVlvania 1'Ik!<;'i~ r;1(.(i,{~.J
Co.lCity/Dist. of CUMBERLAND j)~ ,:;it.~ 9 )
Date of Order/Notice 05/17/02 ]:J)!J 97 ('tJ I'c;Y'/
Court/Case Number (Sff Addendum forcase summary) 1~'K'~'f ~ 'i'/(,.{ { 'iI. <;t.
/)K..'J l/ <11 I
) R[: NORRIS, PATRICK W.
) f mployf't'lObliROf'!t NoIfTle II 01\1. f int, Mil
I 182-56-0078
J (mpIOYfflObliRor's ~()(ial S"t-untv NumbN
) 2888000026
(mpl0'(t'e10bligor'!t C..", ktt"ntitit"r
ISH Addondum far pUlnlllf ........ wodIrod ..hh c.... on .rrKhmontJ
Cu~odi.lI poIrrnt'\ N.lrN' (I oIoJ, f ,r!lt Mil
o Original OrderlNoticf'
o Amended OrderlNotice
o TerminJtf' OrderlNOflce
EmployerlWilhholder'. Fede,.1 (IN Number
RASKAS CHEESE PRODUCTS
EmployerM'ithholder's Name
208 E DYKEMAN RD
EmployerlWithholder'. Addres.
SHIPPENSBURG PA 1'257-8700
Sff AddMdum fOf' fkpendenl names and birth dales associaled with cases on allachmenl.
ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support b.Ised upon an order for support
from CUMBERLAND County, Commonwl!alth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's1obIiRor's income until further notice even if the OrderlNotice is not
issued by your State.
S 485 . 3 3 per month in current support
So. 01) per month in polst-due support Arrears 12 weeks or Rreaterl (Xl yes 0 no
S 65.00 per month in medical support
S 0.00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 550.33 per month to be forwarded 10 payee below.
You do not have to vary your pay cycle 10 be in compliance with Iht> support order. If your poly cycle does not match
the ordered support polyment cycle, use the following 10 determine how much to withhold:
$ 12'.00 per weekly poly period.
S 254.00 per biweekly poly period (every two weeks!.
$ 275.1' per semimonthly poly period (twice a month),
S 550.33 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first poly period occurring ten (10) working days after the date of this
Order/Notice. Send polyment within seven (7) working days of the polydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws goveminR the work stale of your employee for the
the allowable amount. The total withheld amount, and your fee, ("annol exceed 55"10 of the employee's! obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding. the following information is
needed (See 19 on pg. 2).
If remitting by EHIEDI, please call Pennsylvania Stale Collections and Disbursement Unit {SCDUI Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. 8oll69112, Harrisburg, Pa 17106-9112
IN ADDITION. rA YMENTS MUST INCLUDE THE DEFENDANrs NAME AND THE rACSES MEMIE. 10 (sho_
abo.. as 1M EmpIo~s e.u.1dM1iIi<<) Olt SOCIAL SECUItITY NUMIEIt IN OItDEIt TO IE NOCESSED.
DO NOT SEND CASH IY!MIL.
IV THE COUIlT:
Dale of Order:
HAy 2 0 _
Service r~"j)e' M
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOlDERS
D If checked you are required to provide a copy of this form to youremployre.
1. Priorily: Withholding under this OrderINoIice has priorily over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priorily. If there are Federal tax INies 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, separalely Idl'l1lify Ihe portion of Ihe single payment that is anribuuble to
each employee/obligor.
J,' Rtpor1;"I~Payd~1lf'llilhhold;n.. VllU mu.t ,tport tt.paydate'd~ oI..ilhholdinK.mm ~~ par"",.t.Tt.
pard.lt/date of n;tl,I,old~;,~~...tridtamount..... ..ithheld from "'t'lIlpfoyfto'.~. You must comply with the law of the
slate of the employee'slobligor's principal place of employment with respect to the time pt'rio,b within which you must implement the
withholding order and fOIW"rd the support payments.
4.' EmployeeJObligor with Mukiple Support Holdings: If there is more than one OrderINotice to Withhold Income for Support
agillnst this employee/obligor and you are unable to honor all support Order/Notices due 10 Federal or St"le withholding limits, you must
follow the Iilw of the slate of employee'slobliger's principal place of employment. You must honor all OrdenlNotices to the gre"test
extent possible. (See .9 below)
5. Tennllliltion NotiflG1tion: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for
you. Please provide the infOmliltlon requested and retum a copy of this OrderINotlce to the Agency identified below.
W1THHOlDER'S 10: 4314735100
EMPLOYEE'SK>BlIGOR'S NAME:
EMPLOYEE'S CASE IDENTIFIER:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
NORRIS. PATRICK W.
288.000026 DATE Of SEPARATION:
6. Lump 5um Pi\yments: You ITIilY be required to report and withhold from lump sum payments such as bonuses, commissions. or
severance pay. tf you have "ny questions "bout lump sum payments, contact the person or authorily below.
7. Liolbllity: If you fail to withhold income as the OrderINotice directs, you are liable for both the accumulilted amount you should
have withheld from the employeeJobli&or's Income and other penahies set by Pennsylvania Stale law. Pennsylvania Slatt' law govems
un:ess the obligor is employed In "nether Stale. in which case the law of the Slate in which he or st. Is employed governs.
8. Anlkliscrimination: You "re .ubject 10 a fine determined under Slate law for discharxing an employee1obllgor from
employment. refusinllO employ, or laking disciplillilry iCIion agilinst any employee/obligor bt'cause of a support w~hholding.
Pennsylv"nlil Slate law governs unless the obligor Is employed in "nother SI"le, in ..tllch case the Iilw of the Slate in which he or she is
employed gOYflOS.
9.' Wilhholdinglimits: You ITIilY not withhold rnon> than the te.serof: 1} the "mounts ,,11owed by the Fed....1 ConsurnerCA'dit
ProIection Act lI5 U.5.C. ~167J (bll: or 2) the amounls ,,11owed by the Slate of the employee'slobli&or's principal place of employtMnt.
The Fed....llimit iljlplies 10 the "U"'8ilte dispowble wt'ekly eaminls (ADW!:!. ADW!: is the net income left "~,,, I1Iilking mandalOly
dedUC1ions sud1 "s: Stale. Federill, 1oc,,1 tax"" Social S<<urily tax"" and Mellicalt' taJles.
10.
. NOTE: If you or your ~I are serwd with a copy of this ordt't' in ttwo stille th.JI isSUE'll the ordt't'. you are to follow the
law of the slat. that i~ this Older with I't'Spect to 1'- itt'ms.
Rl'questinS A8fllCV:
OOMESTlC RELA lIONS SECTION
13 N. HANOVER Sl
P.O. BOX 320
CARLISLE PA 1701l
If you or your t'mployft>JoblillO' have any questions.
contact WAGE ATTACHMENT UNIT
by l\'1tophone ill 171 n 240-6225 or
by FAX al In]} 240-62.8 or
by Intl'met .
P.l\f' 2 of 2
Form EN'()28
Wmkl"r 10 SIA'I'T
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESI'IC RELATIONS SECTION
Defendant
) Docket Number 97 CV 1484
)
) PACSES Case Number 946000056/026491
)
) Other State 10 Number
WENDY L. NORRIS
Plaintiff
VI.
PATRICK W. NORRIS
PRDER
AND NOW, to wit, on this
10TH DAY OF JUNE, 2002
IT IS HEREBY
ORDERED that the support order in this case be 0 Vacated or OSuspended or
(i)Terminated without prejudice or 0 Terminated and Vacated.
effective MAY 29, 2002 . due to:
THE PARTIBS' FINAL DBCRBB IN DIVORCE ON MAY 29. 1002. THE CASB IS CLOSED WITH
A CREDIT OF $81.61.
, ~ J
o~ .
IK)I RJ ShaddAy
lCCl plaintiff
defendant
Rlby Weeks, Esquire
BY TIlE COURT:
E
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>> r- .'~f- .
.. ,-,
~ -.
0 ib
....
,