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IN THE COURT OF COMMON
OF CUMBERLAND COUNTY
STATE OF ~~l PENNA.
LOUISE E. WARD,
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No. . 9]~573L _____, 19
Plaintiff
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VAUGHN E. WARD, JR.,
. Defendant
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DECREE IN
DIVORCE
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AND NOW, .. .... ...&Jyt~ ~, .. ~ ~,. 19 ,~{" " it is ordered and
decreed that,,,,,.,,.,,, .Loll~~J!:. ,E'"WA,R[),,,..,,,,.,,,,,..... plaintiff.
and "........"",.",,, .. , .. " , IJ~UGH.N . E ,', ~~~P"...:r~" .'.. . ". defendant,
are divorced from the bonds of matrimony.
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The court retains jurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet
been entered;
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None,
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C "/l:tL
Prothonotary
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
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NO. 97.5737
IN DIVORCE
CIVIL TERM
LOUISE E. WARD,
Plai ntiff
vs.
VAUGHN E. WARD, JR.,
Defendant
QUALIFIED DOMESTIC RELATIONS ORDER
AND NOW, this ,2"...1 daYOf~t;;"ll'(
1998, upon the written
Stipulation of the parties filed with this Court, we hereby order and decree as follows:
1. The Plaintiff. Louise E. Ward is awarded, and the United Railroad Retirement
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I Board is directed to pay, an interest in the portion of Defendant, Vaughn E. Ward, Jr.'s
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benefits under the Railroad Retirement Act (45 U.S.C, 231, et seq) which may be divided
as provided by Section 14 of that Act (45 U.S.C. 231 m). Louise E. Ward's share shall be
computed by multiplying the divisible portion of Vaughn E. Ward's monthly benefit by a
fraction numerator of which is the number of years Vaughn E. Ward worked for a Railroad
employer during the period of the marriage (from 4 November 1967 through 31 January
1998), and the denominator of which shall be Vaughn E. Ward's total number of years
employed by a Railroad employer at retirement, and then dividing the product by two.
This decree is entitled to be a final decree, issued in accordance with the laws of the
Commonwealth of Pennsylvania and is intended to be a Qualified Domestic Relations
Order for purposes of federal income taxation. This Order provides for the division of the
Defendant's benefits under the Railroad Retirement Act, as distinguiShed from payments
under any private pension, and is intended to divide those benefits as marital property
and not to award s:Jousal support or alimony. This Order shall not be interpreted to
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divide Tier I of the Defendant's benefits under the Railroad Retirement Act and shall apply
only to the Defendant's non Tier I benefits.
2. The Plaintiff is directed to provide the Railroad Retirement Board with her
current address and to notify the Railroad Retirement Board of any change in her address
at any time in the future. The parties are directed to provide a certified copy of this Order
to the Railroad Retirement Board. All those notices should be sent to:
Deputy General Counsel
Railroad Retirement Board
844 North Rush Street
Chicago, IL 60611
The parties and the Railroad Retirement Board are hereby directed to comply with the
terms and provisions of this Order.
BY THE COURT,
,Ad.
J.
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LOUISE E. WARD,
Plaintiff
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
vs.
VAUGHN E. WARD, JR.,
Defendant
NO. 97.5737
IN DIVORCE
CIVI L TERM
STIPULATION AND JOINT MOTION
AND NOW come the above.named parties, the Plaintiff, Louise E. Ward and the
Defendant, Vaughn E. Ward, Jr., and represent to the Court that they have entered into a
Property Settlement Agreement which, among other things, disposes of a portion of the
Defendant's benefit in his Railroad Retirement Pension or Annuity, and jointly move the
Court to entered the attached Qualified Domestic Relations Order and stipulate that the
Court shall enter such Order to implement the terms of their Property Settlement
Agreement.
"t{u-,J. ~ 2AhJ1-
Vaughn E. ard, Jr.
Loui e E. Ward
LOUISE E, WARD, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND
) COUNTY, PENNSYLVANIA
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vs, ) CIVIL ACTION - LAW
)
VAUGHN E, WARD, JR., ) NO, 97 -5737 CIVIL TERM
Defendant ) IN DIVORCE
ACCEPTANCE OF SERVICE
The undersigned, Samuel L. Andes, states that he is an allorney-at-Iaw and that he has
been retained to represent the Defendant, Vaughn E, Ward, Jr., in this matter. He further
acknowledges that his client received, on 24 October 1997, a certified copy of the Divorce
Complaint in this matter and he hereby accepts that service on behalf on his client and
acknowledges receipt of the Complaint on that date.
Date: II S~~~ b.199k
s~llfl;~
Attorney for Defendant
Supreme Court 10 # 17225
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LOUISE E. WARD. ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND
) COUNTY, PENNSYLVANIA
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vs, ) CIVIL ACTION - LAW
)
VAUGHN E. WARD. JR., ) NO, 97-5737 CIVIL TERM
Defendant ) IN DIVORCE
PRAeCIPE
TO THE PROTHONOTARY;
Please withdraw all economic claims filed in this case on my behalf, including any and all
claims for alimony, alimony pendente lite, counsel fees and expenses, or equitable distribution,
My husband and I have reached agreement to settle all of these claims and I wish to have the
divorce concluded now that we have done so.
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~se E. Ward
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PI a intill'
IN TIlE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYL VANIA
NO. i7-1/3 7 (I-L~}~ ~.
LOUISE E. WARD,
v.
CIVIL ACTION - LAW
VAUGHN E. WARD,JR.,
Ddendant
DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. I I' you wish to ddend against the claims set forth in the
following pages, you must take prompt action. You are warned that if you fail to do sO,the case
may procccd withollt you and a decree of divorce or annulment may be cntered against you by the
court. A judgment may also be entercd against you for any other claim or relief requested in these
papers by the plaintiff. You may losc money or property or other rights important to you,
including custody or visitation of your children.
Whcn the ground for the divorce is indignities or irrctricvable breakdown of the marriage,
you may request marriage counseling. A list ofmurriage counselors is avuilable in the Office of
the Prothonotary at Cumberlund County Courthouse. One Courthouse Square, Carlisle,
Pennsylvunia.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HA VE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
Cumberlund County Courthouse, 4th Floor
Curlisle, PA 17013
(717) 240-6200
LOUISE E, WARD,
IN TIlE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
NO. 'I? )7 011 C(~J u-
Pl"inlill'
v.
CIVIL ACTION - LAW
VAUGHN E. WARD. JR.,
Defend"nt
DIVORCE
COMPLAINT
COUNT I- DIVORCE UNDER SECTION 3301(c)
OF THE DIVORCE CODE
I. Plaintiff is Louise E. W"rd, who currently reroides at 808 Wertzvillc Road, Enola,
Cumberland County, Pennsylvania. since June 10, 1997.
2. Defend"nt is Vaughn E. Ward, Jr,. who currently resides at 808 Wertzvillc Road,
Enola. Cumbcrland Counly, Pennsylvania. since June 10, 1997.
3. Plaintiff and Defendant havc been bona fide residents in the Commonwealth for at
least six months immediately previous to the filing of this Complaint.
4. Plaintiff"nd Defendant were married on November 4, 1967, <II Sunbury,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment betwecn Ihe parties.
6. The m"rri"ge is irretricvably broken.
7. Plainliffhas bcen advised that counscling is availablc and that Plaintiff may have
th:: right to rcquestthatthe court require the parties 10 participate in counsc1i1'1g.
8. Plaintiff requcsts the court to cnter a decrec of divorcc.
COlJNT II - EOlJlTAJlLE IHSTRIIUJTION
9. Pamgraphs I through H, ahove, are ineorpomled herein hy reference.
10. Pluintiffand Defendunt huve legully and heneficially acquired properly, both reul
and personal, during Iheir marriage unlillhe date of sepanHion, which properly is "marital
properly."
WHEREFORE, Plaintiffrequesls the Courllo equitably divide all marital properly.
COUNT III - AUI\10NY
11. Pamgraphs I through 10, above. .Ire incorporuted herein by referencc.
12. PlaintifT lacks sufficicnl properly 10 provide for her reasonable mcans and is unable
to support hersclfthrough uppropriute employment.
13. Plaintiff requires reusonuble support to adequutcly muintain hersclfin accordunce
with the standard of living cstablished during the marriage.
WHEREFORE, Pluintiffrequests Ihe Courlto enter un awurd of alimony.
(lc
Cindy E. Sh u
Attorney I.
P. O. Box 267
Enola, PA 17025
(717) 732-7971
Dale: 10 - I tl - q 7
2
VERIFICATION
I wrify thatlhe statements mUlle in lhis Complaint are lrue and correct. I understand that
false statements herein are made subjecl to the penalties of 18 Pa. C.S. * 4904, relaling to
unsworn falsificalion to aUlhorities.
~f)W~ 0, t. 1ft ~Il!i d
L U E E. WARD
Dale:
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LOUISE E. WARD,
Plaintiff
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
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i 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
I October 17, 1997 and was served upon the Defendant on or about October 24. 1997.
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III h2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
I days ave elapsed from the date of filing of the complaint and the date of service of the
, complaint on the Defendant.
3. I consent to the entry of a final decree in divorce either after service of a Notice
I of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of
I Intention to Request Entry of the Decree,
I 4. I have been advised of the availability of marriage counseling and understand
,I that the Court maintains a list of marriage counselors and that I may request th~ Court to
I require my spouse and I to participate in counseling and, being so advised, do not
I request that the Court require that my spouse and I participate in counseling prior to the
II divorce becoming imal.
II I verify that the statements made in this Affidavit are true and correct and I
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I, understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
Ii Section 4904 relating to unsworn falsification to authorities.
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vs.
CIVIL ACTION, LAW
VAUGHN E. WARD. JR..
Defendant
NO. 97.5737
IN DIVORCE
CIVIL TERM
Af"FIDAVI'f OF CONSENT
15 ~~B
,~~ "..'ML f.
~WARD
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DATE
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LOUISE E. WARD.
Plaintiff
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION. LAW
w.
VAUGHN E. WARD, JR.,
Defendant
NO. 97.5737
IN DIVORCE
CIVIL TERM
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Saction 3301(c) of the Divorce Code was filed on
October 17,1997 and was served upon the Defendant on or about October 24,1997.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing of the complaint and the date of service of the
complaint on the Defendant.
3. I consent to the entry of a final decree in divorce either after service of a Notice
of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of
Intention to Request Entry of the Decree.
4. I have been advised of the availability of marriage counseling and understand
that the Court maintains a list of marriage counselors and that I may request the Court to
require my spouse and Ito participate in counseling and, being so advised, do not
request that the Court require that my spouse and I participate in counseling prior to the
divorce becoming final.
I verily that the ~tatements made in this Affidavit are true and correct and I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S,
Section 4904 relating to unsworn falsification to authorities.
15 July 199B
DATE
-~~( Id~rJ,
VAUGH . WARD. JR.
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LOUISE E. WARD,
Plaintiff
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION. LAW
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vs.
VAUGHN E. WARD, JR.,
Defendant
NO. 97.5737
IN DIVORCE
CIVIL TERM
WAIVER OE...NOTICE OF INTENTION TO REOUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301Cc) OF THE DIVORCE CODE
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II lawyer's fees, or expenses if I do not claim them before a divorce is granted.
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1. I consent to the entry of a final decree in divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
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.
understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904 relating to unsworn falsification to authorities.
15 July 199B
DATE
~~ (~v( f2r
VAUGHN .WARD,JR. )I
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LOUISE E WArm,
Plillfltiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs
CIVIL ACTION - LAW
NO 97-5737 CIVIL TERM
VAUGHN [ WARD. Jr~.
Defendant
IN DIVORCE
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ORDER OF COURT
%I,,' d
AND NOW this day of r~ ,2004. upon the
Petition of the Defendant and the written Stipulation of both parties, we Ilereby order and decree as
follows
I Tile Ouallfied Domestic Relations Order previously entered in tillS matter. and dated
September 22. 1998. is hereby vacated entirely
2 The Railroad Retirement Board is hereby directed to disregard the Oualified Domestic
Relations Order dated September 22. 1998 and PilY all Tier /I benefits to the Defendant. Vaughn E
Ward,Jr
3 The Defendant. Vaughn E Ward. Jr is directed to serve a copy of this Order upon the
Rilllroild Retirement Board.
BY THE COURT.
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Dlstnbutlon
~uise E Ward. now LOUise E Snell
300 Ridge Road, Lot 81. Etters, PA 17319
hughn E Ward, Jr
808 Wertzvllle Road, Enola. PA 17025
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(UMi'vl0t\J\VfAI.TH OF Pfr--JNSYLVANIA I
( 5S
CUiH'HY OF CUMl3Er~lAr--JU )
On [/lIS, tile R t'k day of :1'1-11.." .2004. before me. a Notary Public,
the underSigned officer. personally iJppeiJred Louise E Ward known to me lor satisfactory proven) ro be
tile person wllose name IS subscribed to tile wltllin instrument. and acknowledge tllat said person
executed the same for tile purposes tllerell1 contained
IN WITNESS WHEr<EOF. Illereunto set my Iland and offiCIal seal
/""',,... t~'.!-r/,t)
IY/j/f EN NO/,lii/A! Notary PCblic
I/ylfMOYNE ~{NFfLD, /fO:A!
"'" .r04l1lIs\igv~qx CllM8::~~U8L1C
"'-.!.!'/~ES AUa .,D CD.
. 17, l004
COMMONWEALTH OF PENNSYLVANIA )
( SS
COUNTY OF CUMBERLAND I
d{'l-.
On tillS. the /) day of J11l 'I .2004, before me, a Notary Public.
the uflclers'gfl,:d officer. personally iJprealed Vaugl'n F. Ward. Jr. known to me lor satisfactory fxoven)
to be tile person whose name is subSCribed to the witl11n instrument, and acknowledge that said person
executed tile same for the purposes tt1ereln contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
i~ c1~d2
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Notary Public
I OUISE E WARD,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs
CIVIL ACTION - LAW
NO 97-5737 CIVIL TERM
VAUGHN E WARD. JR.
Defendant
IN DIVORCE
PETITION TO VACATE QUALIFIED DOMESTIC RELATIONS ORDER
AND NOW comes Vaughn E Ward, Jr, the Defendant In the above-captioned matter, by his
attorney, Samuel L Andes, and petitions the court to vacate the QualiFied Domestic Relations Order
previously entered in thiS matter. based upon the follOWing
I The Petitioner herein IS the anginal Defendant, Vaughn E Ward. Jr, an adult individual
WI10 reSides at 808 WertlVllle Road In Enola, Cumberland County, Pennsylvania. I 7025
2 The Respondent herein IS the anginal Plaintiff, LOUise E Ward, now Louise E Snell an adult
rr.'dlVldual who reSides at 300 Ridge Road, Lot 81 In Etters, York County. Pennsylvania, 17319
3 The parties are formerly husband and Wife and were divorced by a tinal decree entered in
thiS case by thiS court on 22 September 1998
4 On 22 September 1998 this court. by the Honorable Kevin A Hess. entered a Qualified
Domestic Relations Order. upon the agreement of the parties. to divide and dlstnbute a
portion of Defendant's Railroad Retirement Board retirement benents.
5 Since the entry of the Quallned Domestic Relations Order. Defendant has become disabled
and started to receive disability pension benents from the Railroad Retirement Board. Because of the
Ouallned Domestic Relations Order entered In this case. a portion of his disability pension payments
Ilave been withheld. apparently for payment to the Plaintiff
6 Plaintiff does not deSire to receive any portion of Defendant's Railroad Retirement benents
at thiS time She IS content to receive whatever benents are awarded to her by federal law and by trle
regulations of the Railroad Retirement Board in effect at the time she reaches retirement age, if she is
eligible for such benefits
7 The Plaintiff and DefendDnt have agreed. that the Quailned Domestic RelatiOns Order
previously entered In thiS matter shall be vacated so that no portion of Husband's current retirement
benents Will be Withheld from him or paid to Plaintiff
WHEREFORE. DeFendant prilYS tillS court to vilcilte ItS OUilllfied Domestic Reliltlons Order
dilted 22 September 1998 ilnd enter tile order attJClledllereto to resolve tl"ilS matter
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ScUTIU LAndes
Attorney for Defendant
Supreme Court ID II 17225
525 North 12'" Street
Lemoyne. Pa 17043
(717) 761-5]61
I verity tll"t IIle II"tl'Jrll'l It I flklde Ifl tllll (/OCUrlll"nt ,Ire true drld COllect I U')(/erltdrtcJ tli"t drty
t,ihe It,lterneflts In tillS eJocurnent dre> IUbJ'-'ct to tile penilltlcs of 18 Pd C S 490-1 (url\worn
I. il\lt'Co.Illort to ilutlllJJltlt's)
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VAUGH WARD, JR
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