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Home My WebLink About03-0277 TERRY E. HILL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Defendant : CIVIL ACTION - LAW : NO, 03, ';271 : IN DIVORCE CIVIL TERM v. BOBBIE J. HILL, NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take pfompt action. You are warned that if you fail to do so, the case will proceed without you and a decree of divorce or annulment may be entered against you for any claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling, A list of marriage counselors is available in the Office of the Prothonotary at Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association Two Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 TERRY E. HILL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW BOBBIE 1. HILL, Defendant : NO. 03 - c2 11 : IN DIVORCE CIVIL TERM COMPLAINT IN DIVORCE COUNT I NO FAULT 1. Plaintiff is Terry E. Hill, an adult individual currently residing at the Cumberland County Prison, Cumberland County, Pennsylvania, Prior to his incarceration, Plaintiff resided at 59 Glenndale Drive, Mechanicsburg, Cumberland County, Pennsylvania for approximately one (1) year and four (4) months, 2. Defendant is Bobbie J, Hill, an adult individual currently residing at 59 Glenndale Drive, Mechanicsburg, Cumberland County, Pennsylvania. Defendant has resided at this address for approximately one (1) year and four (4) months. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4, Plaintiff and Defendant were married on April 29, 2000, in Cumberland County, Pennsylvania. 5, There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies, 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9, The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of the filing of this Complaint, consent to this divorce, WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S, Section 3301 (c) of the Domestic Relations Code. COUNT II EQUITABLE DISTRIBUTION 11, Paragraphs 1 through 10 are incorporated herein by reference as if set forth in their full text. 12, Plaintiff and Defendant are joint owners of various items of personal property, furniture, and household furnishings acquired during their marriage which are subject to equitable distribution. 13. Plaintiff and Defendant are j oint owners of real estate located in Cumberland County, which was acquired during their marriage and which is subject to equitable distribution. 14. Plaintiff and Defendant have incurred debts and obligations during their marriage which are subject to equitable distribution, WHEREFORE, Plaintiff requests your Honorable Court to enter a decree equitably dividing the parties' property and equitable apportioning the debts incurred by the parties. Respectfully submitted, ___..'' . fl () ~ 1,) ,,~ Wendy 1. F. Gre a, Attorney for Plai . GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, P A 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE:~\- \~-()~ ~~~ TERRY E. L, Plamtl f ~~ J ^ ~ (~ c~ ~"" o _ r ~J' ~ ~ . `_ Z~ ,;Tfi it r Cl,J e, ,, -r.J ' c-t ::4 _t r~ ~ ~'. W ~ ~ ~ t--' ~7 ; T `mil \N r t; j =_'~ ~ ~ [- Q =~ r~ ~ _ ~ ~ ~° (o ~ ~' ~= ,Q :_ ~. In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION BOBBIE J. HILL ) Docket Ntnnber 03-277 CIVIL Plaintiff ) VS. ) PACSES Case Number 758105280 TERRY E. HILL ) Defendant ) Other Stale ID Number ORDER TO VACATE BENCH WARRANT - DEFENDANT AND NOW, this 6TH DAY OF JULY, 2005 it is hereby Ordered and for the arrest of Directed that the warrant issued on JUNE 28, 2005 TERRY E. HILL , 235-11-0610 is vacated. ("')0 ."". !i~ iIi ~~~ V' :b-,~g] .' r--= ~,C'), I cr ~ -.I BY THE COURT: ~.~~ / JUDGE Date Bench Warrant Number: Service Type M Form EN-049 Worker 1D 21400 In the Court of Common Pleas of CUMBERLANlI> County I Pennsylvania DOMESTIC RELATIONS SECTION 13 N, HANOVER ST, P.O. BOX 320, CARLISLE, PA, 17013 Phone: (717) 240-6225 Fax: (717) 240-6248 JULY 6, 2005 Plaintiff Name: BOBBIE J. HILl, Defendant Name: TERRY E. HILL Docket Number: 03-277 CIVIL PACSES Case Number: 758105280 Other State ID Number: Please note: AU correspondence must include the PACSES Case Number. APPLICATION TO VACATE BENCH WARRANT - DEFENDANT The Domestic Relations Section requests that the Bench Warrant issued on JUNE 28, 2005 for TERRY E. HILL , Social Security Number235-11-0610 be vacated for the following reasons: Defendant appeared this date, posted a $700.00 payment and was served with a Notice to appear before the Court on August 1,2005 Bench Warrant Number: Service Type M Form EN-S19 Worker ID 21400 ,; ',~ ';'-: (") ~;; ':':;," '"'(Jt,}' n1fTi ~/) U"J,.' . -< r.' """ "f:C') ~O )"'c:: ?; -< :':-!: t '; r::'0...~," \;:'.1 ~ = "'" ~ ,- I 0' ~ :r!, ,., ~l!l ~6 =?-ri ";!:;:!) ':.-., ~1: f" S ~ '< '"" :x r ,. N In the Court of Common Pleas of CUMBERLANlD County, Pennsylvania DOMESTIC RELATIONS SECTION BOBBIE J. HILL ) Dockllt Number 03-277 CIVIL Plaintiff ) VS. ) PACSES Case Number 758105280 TERRY E. HILL ) Defendant ) Other State ID Number ORDER OF COURT Legal proceedings have been brought agaiIIIst you alleging you have wilfully disobeyed an Order of Court. 1, If you wish to defend against the claim set forth iJn the following pages, you may, but are not required to, file in writing with the Court your defenses or objections, 2. You, TERRY E. HILL , Respondent, must appear in person in court on AUGUST 1, 2005 , at 1 : 30PM , in COURT ROOM 4 CUMBERLAND CO COURTHOUSE, 1 COURTHOUSE SQUARE, CARI,ISLE, PA. 17013 IF YOU DO NOT APPEAR IN PERSON, THE COURT MAY ISSUE A WARRANT FOR YOUR ARREST AND YOU MAY BE COMMI'ITED TO JAIL. 3. If the Court (mds that you have wilfully failed to comply with its order you may be found to be in contempt of court and committed to jail, fined, or both, Service Type M Form EN-528 Worker ID 21204 HILL v. HILL PACSES Case Number: 758105280 YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFF1CE SET FORTH BELOW. TIDS OFF1CE CAN PROVIDE YOU WITH INFORMATION ABOUT IllRING A LAWYER. IF YOU CANNOT AFFORD TO lURE A LAWYER, TIDS OFF1CE MAY BE ABLE TO PROVIDE YOU WITH THE INFORMATION ABOUT AGENCmS THAT MAY OFFER LEGAL SERVICES TO ELIGffiLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990, For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. BY THE COURT: 7' ;>' ~ Date of Order: .-; / vi b So JUDGE Page 2 of2 Form EN-528 Worker ID 21204 Service Type M () s; ..:..~. \)l~ \T!rr Z:T: 7r (j~ ;); f: }€t~ z :< , "" = = <.n <- c:: r- , en -0 3: x:- ~ ~ m:D "TI Frio -0 c16 --Iwr, ::I::n On 2m o ~ .n -< N TERRY E. HILL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. BOBBIE J. HILL, CIVIL ACTION - LAW NO. 03-277 CIVIL TERM IN DIVORCE Defendant AFFIDAVIT OF SERVICE AND NOW, this 2.-~y of January, 2003, comes Wendy J. F. Grella, Esquire, counsel of record for Plaintiff, Terry E, Hill, and states that a true and attested copy of a Complaint in Divorce was sent to Defendant, Bobbie 1. Hill, at 59 Glendale Drive, Mechanicsburg, Cumberland County, Pennsylvania, by certified mail, restricted delivery, return receipt requested, A copy of said receipt is attached hereto indicating that service was made on January 22,2003. ~) 6~ Wendy 1. F. Grel Attorney for Plai GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, P A 17013 (717) 243-5551 (800) 347-5552 Notarial Seal - .. -.. Ka~isa J. Lehman, Notary Public ,I Carlisle Bora, Cumberland County My Com~~~::.':'.:.~s Aug. 25, 2003 I (") CJ C c c.-.;: ;-....... 'l) t.-c ~,.:. nl C~ -7 Z 0) (j~~ CO - ~ ~- ,-; )-"';.. , "--7 ff.__ i:-:. > c: ?:;j ~n :0 ~, (]"\ -~, Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: ~I:::b:~ 2J. \.--\.. \ \ " :'--1 G\ c:t"\ck_~ ~VL mCLC~~, L'"'..,,6~\ffi IIO~D D. Is delivery address different from ~em 1? If YES, enter delivery address below: 2. Article Number (Transfer from service labelj PS Form 3811, August 2001 3. Service Type .l([ Certified Mail 0 Express Mail o Registered 18[ Return Receipt for Merchandise o InSured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) Yes [ Domestic Return Receipt <;;~I.:,~ 1 02595~02.M.1 035 ('- CO rn CJ Postage rn ..n CO lJ1 ~ Certified Fee ...0 Return Receipt Fee CJ . ndorsement ~eqUired) o estricted Dellve/)! Fee o (Endorsement Required) CJ ,." lJ1 ru Total Postage & Fees ,." CJ CJ C'- Ilasa ( ( { ,. ~ I ~ i; o V ;gV~;_. -;J - ~:~ ';~ ~} r;= ~';i_--':~ L-,-- ~;.C ..- -') -- ) I ! c w :..0'- ;-V ctJ (_;1 (I' :..':J -< TERRY E. HILL, Plaintiff/Respondent : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No: 03-277 CIVIL TERM BOBBIE J. HILL, Defendant/Petitioner CIVIL ACTION - LAW : IN DIVORCE PRTTTTON FOR RRT,ATRD l;T,ATMS PURSUANT TO PA.R.l;.P. 1920.15(h) AND NOW, comes the Defendant, Bobbie J. Hill, by and through her attorney, Jeanne B. Costopoulos, Esquire, and respectfully represents as follows in support of this Petition: 1. The Petitioner is the Defendant above-named. 2. The Respondent is the Plaintiff above-named. 3. The Petitioner and Respondent were married on April 29, 2000. 4. Respondent has filed a Complaint for Divorce to the above caption and number on January 17, 2003. l;OTTNT T RRQTTF.ST FOR AT ,TMONY, A [.[MONY PENDENTE [.[TE., AND/OR l;OlTNSRT, FF.RS PIJRSUANT TO SRl;TION 3702 OF THR DWORl;R l;ODR 5. Paragraphs one (1) through eight (4) are incorporated herein by reference as though fully set forth. 6. The Petitioner is the dependent spouse and lacks sufficient property to provide for her reasonable means and is unable to support herself completely through appropriate employment. 7. Petitioner requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. 8. Petitioner has hired an attorney and may need to hire an accountant, appraiser, or other expert during the pending divorce litigation and does not have the funds necessary to pay said fees. WHEREFORE, Petitioner requests this Honorable Court to enter and award counsel fees, costs, and expenses as are deemed necessary and appropriate, to enter an award of alimony pendente lite, and to enter an award of reasonable alimony upon fmal hearing and permanently thereafter. RESPECTFULLY SUBMITTED: Dmed: ;ML e B. Costopoulos, Esquire ATTORNEY FOR PETITIONER 5000 Ritter Road, Suite 202 Mechanicsburg, P A 17055 Phone: (717) 790-9546 Supreme Ct. ID No. 68735 TERRY E. HILL, PlaintifflRespondent : TIlE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : No: 03-277 CIVIL TERM BOBBIE J. HILL, Defendant/Petitioner : CIVIL ACTION - LAW : IN DIVORCE VF:RTFTCA TTON I, Bobbie J. Hill, verify that the statements made in the foregoing Petition for Related Claims are true and correct to the best of my knowledge, information, and belief. 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. Dated: /1:-3 J '{)3 ~dt'~ Bobbie J. Hil~ TERRY E. HILL, Plaintiff/Respondent : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No: 03-277 CIVIL TERM BOBBIE J. HILL, DefendantJPetitioner : CIVIL ACTION - LAW : IN DIVORCE CERTIFICA TE OF SERVICE I, Jeanne B. Costopoulos, Esquire, hereby certify that I am this day serving a copy of the foregoing document upon the person, and in the manner, indicated below, which service satisfies the requirements of the P A Rules of Civil Procedure by depositing a copy of the same with the United States Post Office at Mechanicsburg, Pennsylvania, through first class mail, prepaid, and addressed as follows: Wendy J. F. Grella, Esquire GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, P A 17013 BY: ~ --- Jeanne B. Costopoulos, Esquire AITORNEY FOR PETITIONER 5000 Ritter Road, Suite 202 Mechanicsburg, P A 17055 Phone: (717) 790-9546 Supreme Ct. ill No. 68735 Dated: 1!?//tJ3 lOG 'it ~ --Lv ~ ?J ~f' ~ o ~o :tJC It:~ - :n r'~ ~ () c: <.' -oGi rnp\ --T1 ~~= (f) ,> -< -'- \CO ::iP..., '2 '... -,., ( ) )>e: Z ~ C> W ...., ;....., c::J ~ I c......: 'j~ .. ~.T~ ~. ...._, .'~.' ;~ ::~ (~;: ;2-;;')2'-) ~.~~~ rn :~ -~-"", ~ '-!? :::> {n JERRY E. HILL, Plaintifl7Respondent : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : No: 03-277 CIVIL lERM BOBBIE J. lllLL, Defendant/Petitioner : CIVIL ACTION - LAW : IN DNORCE DF.FF.NDANT'S pF.TmON FOR CONFF.RF.NCF. OR HF.ARlNG RF.GARDlNG AT ,TMONY PF.NDF.NTF. T ,ITF. AND NOW, comes the Defendant, Bobbie J. Hill, by and through her attorney, Jeanne B. Costopoulos, Esquire, and respectfully represents as follows in support of this Petition: 1. The Petitioner is the Defendant above-named 2. The Respondent is the Plaintiff above-named. 3. Defendant/Petitioner filed a Petition for Related Claims on February 3,2003 which contained a request for alimony pendente lite. 4. Defendant/Petitioner desires that a conference or hearing be held to address her alimony pendente lite claim. WHEREFORE, Defendant respectfully requests that a conference or hearing be scheduled regarding her request for alimony pendente lite. RESPECTFULLY SUBMITlED: -7 /, -----.. Dated: 2(2/103 Jeanne B. Costopoulos, Esquire AITORNEY FOR PETITIONER 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Phone: (717) 790-9546 Supreme Ct ID No. 68735 -' JERRY E. HITL, Plaintitl7Respondent : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No: 03-277 CIVIL TERM BOBBIE 1. HlLL, DefendantlPetitioner : CIVIL ACTION - LAW : IN DNORCE CRRTTFTCA TR OF SERVICE I, Jeanne B. Costopoulos, Esquire, hereby certifY that I am this day serving a copy of the foregoing document upon the person, and in the manner, indicated below, which service satisfies the requirements of the P A Rules of Civil Procedure by depositing a copy of the same with the United States Post Office at Mechanicsburg, Pennsylvania, through first class mail, prepaid, and addressed as follows: Wendy J. F. Grella, Esquire GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, P A 17013 BY: //Z- -- Dated: z(211 if 3 Jeanne B. Costopoulos, Esquire ATTORNEY FOR PETITIONER 5000 Ritter Road, Suite 202 Mechanicsburg, P A 17055 Phone: (717)790-9546 Supreme Ct ID No. 68735 .~ <::1 S: l}!-''-'' S~! t.~::: ~: --,' r_-= ( .., - ?;( .' S~ :...~ ,j -.:, (.:) G.J .., i'1 (..7J /'...) .,:-. ::!2 .,.-ili." (-, .....f (..) 'l-~ ~;?I...~ i{n -..... =< ... In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION BOBBIE J. HILL ) Docket Number 03-277 CIVIL Plaintiff ) vs. ) PACSES Case Number 758105280 TERRY E. HILL ) Defendant ) Other State ID Number ORDER OF COURT You, TERRY EDWARD HILL plaintiff/defendant of 125 OAK FLAT RD, NEWVILLE, PA. 17241-9467-25 APRIL 8, 2003 at 1: 30PM for a hearing. are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013- before a hearing officer of the Domestic Relations Section, on the You are further required to bring to the hearing: I. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. verification of child care expenses, and 4. proof of medical coverage which you may have, or may have available to you 5. infonnation relating to professional licenses 6. other: Service Type M Form CM-509 Worker ID 21006 \. HILL V. HILL PACSES Case Number: 758105280 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: 3 -/0 -63 ,:., ~ ~ /' JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP: CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Service Type M Page 2 of2 Fonn CM-509 Worker ID 21006 0 0 C) C (..J ,1 ~. ~'>:'"' "'0 U ~~ .,:;'f\'I , fT1 1- ;::.J ....'7 "J ~.~- ;.~ (f) -< ,I' r::: c --0 ? C ~ L- C > f~ Ii! ....~.; " :.:> ;[~ :.0 -( 0::> .< In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION BOBBIE J. HILL ) Docket Number 03-277 CIVIL Plaintiff ) vs. ) PACSES Case Number 758105280 TERRY E. HILL ) Defendant ) Other State ID Number ORDER OF COURT You, BOBBIE JO HILL plaintiff/defendant of 59 GLENDALE DR, MECHANICSBURG, PA. 17050-1546-59 ....'--, '-.:/ 1;,._...._) are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3C1104_:'"'13 o before a hearing officer of the Domestic Relations Section, on the . ~,"J APRIL 8, 2003 at 1:30PM for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. verification of child care expenses, and 4. proof of medical coverage which you may have, or may have available to you 5. infonnation relating to professional licenses 6. other: Service Type M Fonn CM-509 Worker ID 21006 HILL V. HILL PACSES Case Number: 758105280 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: 3-1 0 - 0 ') 7'~~ JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY A'ITEND THE HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP: CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Worker ID 21006 Service Type M V. IN THE COURT OF COMMO PLEAS OF CUMBERLAND COUNTY, P NNSYLVANIA : DOMESTIC RELATIONS SE BOBBIE J. HILL, Plaintiff TERRY E. HILL, Defendant PACSES NO. 528105142 3 SUPPORT 2003 TERRY E. HILL, IN THE COURT OF COMMO PLEAS OF Plaintiff/Respondent: CUMBERLAND COUNTY, P NNSYLVANIA V. DOMESTIC RELATIONS SE BOBBIE J. HILL, PACSES NO. 758105280 Defendant/Petitioner: 03-277 CIVIL TERM INTERIM ORDER OF COURT AND NOW I this 9th day of April, 2003, upon consideration f the Support Master's Report and Recommendation, a copy of which is attach d hereto as Exhibit "A", it is ordered and decreed as follows: A. In the case docketed to 03-277 Civil Term for the period f February 1, 2003 through April 13, 2003 the Husband shall pay to th State Collection and Disbursement Unit for transmission to the ife as alimony pendente lite the sum of $382.00 per month. B. Effective April 14, 2003 the Husband shall pay as alimon pendente lite the sum of $305.00 per month. C. The Husband shall pay to the State Collection and Disbu sement Unit an additional sum of $50.00 per month on arrearages until p id in full. D. The Husband shall provide health insurance coverage 0 the Wife. E. The Wife's complaint for spousal support docketed to 3 upport 2003 is withdrawn without prejudice. .. \.J'N\-II'l ' 1">~ I ~ 1::1,~ VI 1//\/\01\1'1_1,..... v.' 'nr,,-, '~! ,."..,,"';.''''r'll"\ I J\ ;1...,' r 'i"~~'r~,\i'ill\-' , '/ . (' ,,,, I '" 'IJ ".~) 6 ~,~ ~'J d ~~. , ,.,. The parties are hereby advised that they may file written e ceptions to the Support Master's Report and Recommendation within ten (10) da s of this order. Exceptions shall conform with the requirements of Rule 1910.12( , Pa. R.C.P. If written exceptions are filed by any party, the other party may file xceptions within ten (10) days of the date of service of the original exception . If no exceptions are filed within ten (10) days of this interim order, this rder shall then constitute a final order. /9. Kevin A. Hess, J. Cc: Bobbie J. Hill Terry E. Hill Bradley L. Griffie, Esquire For the Plaintiff Jeanne B. Costopoulos, Esquire For the Defendant DRO BOBBIE J. HILL, Plaintiff v. IN THE COURT OF COMMO PLEAS OF CUMBERLAND COUNTY, P NNSYLVANIA : DOMESTIC RELATIONS SE TERRY E. HILL, Defendant PACSES NO. 528105142 3 SUPPORT 2003 TERRY E. HILL, IN THE COURT OF COMMO PLEAS OF Plaintiff/Respondent: CUMBERLAND COUNTY, PEl NSYLVANIA V. DOMESTIC RELATIONS SE BOBBIE J. HILL, PACSES NO. 758105280 Defendant/Petitioner: 03-277 CIVIL SUPPORT MASTER'S REPORT AND RECOMMENDA ION Following a hearing held before the undersigned Support Mas. er on April 8, 2003, the following report and recommendation are made: FINDINGS OF FACT 1. The Plaintiff in the case docketed to 3 Support 2003 is obbie J. Hill, who resides at 59 Glendale Drive, Mechanicsburg, Pe . nsylvania. She is also the Defendant in the case docketed to 03-2 7 Civil Term and will hereafter be referred to "the Wife." 2. The Defendant in the case docketed to 3 Support 2003 is Terry E. Hill, who resides at 125 Oak Flat Road, Newvi Ie, Pennsylvania. He is also the Plaintiff in the case dock ted to 03-277 Civil Term and will hereafter be referred to as "the Hus. and." 3. The parties are husband and wife but currently reside s parate and apart. 4. On January 2, 2003 the Wife filed a complaint for spou al support to the case docketed to 3 Support 2003. 5. On February 3, 2003 the Wife filed a claim for alimony endente lite to the case docketed to 03-277 Civil Term. 6. A consolidated hearing was scheduled before this Mast r for April 8, 2003. 7. The parties reached an agreement on all outstanding i sues prior to the taking of testimony. DISCUSSION A recommendation will be entered based upon the agreem nt of the parties. RECOMMENDATION A. In the case docketed to 03-277 Civil Term for the period 0 2003 through April 13, 2003 the Husband shall pay to the Collection and Disbursement Unit for transmission to the alimony pendente lite the sum of $382.00 per month. February 1 , tate ife as B. Effective April 14, 2003 the Husband shall pay as alimony'pendente lite the sum of $305.00 per month. C. The Husband shall pay to the State Collection and Disbur ,ement Unit an additional sum of $50.00 per month on arrearages until pa d in full. D. The Husband shall provide health insurance coverage on e Wife. ~rVl ~ 8 i 2oe? Date \\~ ~J2Q QL Michael R. Rundle Support Master c~ E. The Wife's complaint for spousal support docketed to 3 Su port 2003 is withdrawn without prejudice. In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION 13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013 Defendant Name: TERRY E. HILL Member ID Number: 7219100741 Please note: All correspondence must include the Member ID Number. ORDER OF ATTACHMENT OF UNEMPLOYMENT COMPENSATION BENEFITS Financial Break Down of Multiole Cases on Attachment Plaintiff Name STEPHANIE D. HILL BOBBIE J. HILL PACSES Case Number 323105022 758105280 Docket Number 01003 S 2002 03-277 CIVIL $ ~ $ $ ~ $ Attachment Amount/FreQuency 300.00 jMONTH 432. 00 ~MONTH / / % '/ / / TOTAL ATTACHMENT AMOUNT: $ 732.00 Now, by Order of this Court I the Department of Labor and Indusuy, Bureau of Unemployment Compensation Benefits and Allowances (BUCBA), is hereby directed to attach the lesser of $168.92 per week, or 50 %, of the Unemployment Compensation benefits otheIwise payable to the Defendant, TERRY E. HILL Social Security Number 235-11-0610 , Member ID Number 7219100741 . BU CBA is ordered to remit the amount attached to the Department of Public Welfare (DPW). DPW shall forward the amount received from BUCBA to the Domestic Relations Section of this Court for support and/or support arrearages. If the Defendant's Unemployment Compensation benefits are attached by another Court or Courts for support and/or support arrearages, DPW may reduce the amount attached under this Order so that the total amount attached does not exceed the maximum amount subject to garnishment pursuant to 15 U.S.C. ~ 1673 (b)(2) and 23 Pa. C.S.A. ~ 4348 (g). This Order shall be effective upon receipt of the notice of the Order by the BUCBA and shall remain in effect until the Defendant's entitlement to Unemployment Compensation b(mefits, under the Application for Benefits dated MAY 5, 2002 is exhausted, expired or deferred. BUCBA shall comply with this Order, unless it is amended or vacated by subsequent Order of this Court. All questions, challenges or obligations to this Order shall be directed to the Domestic Relations Section of this Court. BY THE COURT - . APR 1 0 .~ ~" /9. ~ #65... 4.. Date of Order: JUDGE Service Type M Form EN-530 Worker ID $IATT C;E/0 () c- ';:?;: t:/T ~9 -< !:_': r ~~:-:~. !S (~~i r'-'", '- -. 3 " :if;; ;t:: :a; ;fjfli"l$Y!;t,U :~'.::::, c *l - "'~ ORDER/NOTICE TO WITHHOLD INCOME FOR: SUPPORT ,.hI /003 S 2tP~>- . f,n' - Q Original Order/Notice State Commonwealth of Pennsylvama M/lrf'> ,~;;? 3/tJ!;orlr Co./City/Dist. of CUMBERLAND rt..tL.'>, - :::r _ 77 eJ/ @ Amended Order/Notice Date of Order/Notice 04/09/03 W, ~... t:2 or ~D Terminate Order/Notice Tribunal/Case Number (See Addendum for case summary) !/}C!rf 5 ~"5""8'/~5'"/!l7 RE: HILL, TERRY E. Employee/Obligor's Name (Last, First, Mil 235-11-0610 Employee/Obligor's Social Security Number 7219100741 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, Mil EmployerNVithholder's Federal EIN Number EDWIN L HElM CO PO BOX 2247 HARRISBURG PA 17105-2247 See Addendum for dependent names and birth dates associatE'd with cases on attachment. ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 682.00 per month in current support $ 50.00 per month in past-due support Arrears 12 weeks or greater? Qyes @ no $ 0 . 00 per month in medical support $ 0 . 00 per month for genetic test costs $ per month in other (specify) for a total of $ 732.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 168.92 per weekly pay period. $ 337.85 per biweekly pay period (every two weeks). $ 366.00 per semimonthly pay period (twice a month). $ 732.00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee'sl obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #10 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: P A SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, HarrisbUlrg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NiUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. Service Type M ~lO_ :TH~?:, ~ ~ ""ft, J'I,,~D Ut AJ~ffi "'1}-'''7f:ffff oMi! No.: 0970-01S4 4.. Date of Order: .;:x;DbG Form EN-028 Worker ID $IATT C;L>/(P "g-lfii ifl,.,rt:t)~a Vi ~,J\;~I\-!AS;\!N::Jd IUJ\J:iCY"t ~-' -\ ;:~c"!\!:lJ L I :[J r 9 i ,~; '.~ ~r ..Ir, .:J........ ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If !:;hecked you are required to provide a copy of this form to your ~mployee. If YOl,lr employee works in a state that is different from the state that issued this order, a copy must be provided to your employee even if the box is not checked. 1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned businesses located on a reservation that choose to withhold in accordance with this notice. 2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income, Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withhold ing. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor, 4. * Repolting the ray date/Date of 'Nithholding. You must report the paydate/date of vvithholding vvhen sending the payment The paydate!date of vvithholding is the date on vvhicn an ,ount vvas vv ithheld from the employ~~e's vvages. You must comply with the law of the state of the employee's/obligor's principal place 'of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 5. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment You must honor all Orders/Notices to the greatest extent possible, (See #10 below) 6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below, WITHHOLDER'S ID: 2312659240 EMPLOYEE'S/OBLlGOR'S NAME: HILL , TERRY E. EMPLOYEE'S CASE IDENTIFIER: 7219100741 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay, If you have any questions about lump sum payments, contact the person or authority below, 8, Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 10. * Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 USe. 91673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 11. Additional Info: * NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us Service Type M Page 2 of 2 Form EN-028 Worker 10 $IATT OMB No.: 0970-01 S4 ADDENDUM Summary of Cases on Attachmen! Defendant/Obligor: HILL, TERRY E. PACSES Case Number 323105022 Plaintiff Name STEPHANIE D. HILL Docket Attachment Amount 01003 S 2002 $ 300.00 Child(ren)'s Name(s): DOB /10/85 PACSES Case Number 758105280 Plaintiff Naml~ BOBBIE J. HILL Docket Attachment Amount 03-277 CIVIL $ 432.00 Child(ren)'s Name(s): DOB o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the el1lployee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff NamE~ Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. o If checked" you are required to enroll the child(ren) identified above in any health insurance coverage available through the ernployee's/obligor's employment. PACSES Case Number Plaintiff Name PACSES Case l\lumber Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. If checked, you are required to enroll the child(ren) above in any health insurance coverage available the elTlployee's/obligor's employment. Service Type M Addendum Form E N-028 Worker 10 $IATT OMB No.: 0970-0154 ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT . O~-/, ;003.$~?- o Original Order/Notice State Commonwealth of Pennsylvama ,'Jj-Jt~<i <; 3,'1 ~ ItJ 5 (J.,};) ~ . Co./City/Dist. of CUMBERLAND r' .' -:A \C; Amended Order/Notice Date of Order/Notice 04/14/03 2>#, olt't7.3 -0277 CII.I/6) Terminate Order/Notice Tribunal/Case Number (See Addendum for case summary) /jJjct;.E.s- 7S-t'/~./jf; RE: HILL, TERRY E. EmployerNVithholder's Federal EIN Number Employee/Obligor's Name (Last, First, Mil 235-11-0610 Employee/Obligor's Social Security Number 7219100741 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, Mil EDWIN L HEIM CO PO BOX 2247 HARRISBURG PA 17105-2247 See Addendum for dependent names and birth dates associatE'd with cases on attachment. ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 805.00 per month in current support $ 50 . 00 per month in past-due support Arrears 12 weeks or greater? (X) yes 0 no $ 0.00 per month in medical support $ 0 . 00 per month for genetic test costs $ per month in other (specify) for a total of $ 855.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 197.31 per weekly pay period. $ 394.62 per biweekly pay period (every two weeks). $ 427.50 per semimonthly pay period (twice a month). $ 855.00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #10 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. Date of Order: N"K 1 5 .. A. 4... Service Type M ;:rv)jrot=.. Form E N-028 OMB No.: 0970-01S4 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If ~hecked you are required to provide a copy of this form to your employee. If your employee works in a state that is ditterent from the state that issued this order, a copy must be provided to your employee even if the box is not checked. 1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned businesses located on a reservation that choose to withhold in accordance with this notice. 2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority, If there are Federal tax levies in effect please contact the requesting agency listed below. 3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion ofthe single payment that is attributable to each employee/obligor. 4. * Repolting the raydate/Date of Vv'itl,liolding. You must report the paydate/date of vvithholding vvhen sending tlie payment Tlie paydate/date of vvitliliolding is tlie date on vvMich amount vvas vvitl.l,eld from the employf~e's vvages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 5. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/l\Jotice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment You must honor all Orders/Notices to the greatest extent possible. (See #1 0 below) 6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S ID: 2312659240 EMPLOYEE'S/OBLlGOR'S NAME: HILL, TERRY E. EMPLOYEE'S CASE IDENTIFIER: 7219100741 DATE OF SEf'ARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 7, Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs, 10. * Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.s.c. S 1673 (b)l; or 2) the amounts allowed by the State of the em ployee's/obl igor's principal place of employment The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 11. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Worker ID $IATT Service Type M OMB No,: 0970-0154 ADDENDUM Summary of Cases on Attachment Defendant/Obligor: HILL, TERRY E. PACSES Case Number 323105022 Plaintiff Name STEPHANIE D. HILL Docket Attachment Amount 01003 S 2002 $ 500.00 Child(ren)'s Name(s): TERRY.A.HILL DOB /10/85 PACSES Case t~umber 758105280 Plaintiff Name BOBBIE J. HILL Docket Attachment Amount 03-277 CIVIL $ 355.00 Child(ren)'s t~ame(s): DOB If checked, you are required to enroll the child(ren) above in any health insurance coverage available through the employee's/obligor's employment. If checked, you are required to enroll the child(ren) above in any health insurance coverage available through the employee's/obligor's employment. Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Nam~~ Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name If checked, you are required to enroll the child(ren) above in any health insurance coverage available through the employee's/obligor's employment. o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Docket Attachment Amount $ 0.00 Child(ren)'!; Name(s): DOB If checked, you are required to enroll the child(ren) above in any health insurance coverage available through the employee's/obligor's employment. If checked, you are required to enroll the child(ren) above in any health insurance coverage available the employee's/obligor's employment. Addendum Form EN-Ol8 Worker ID $IATT Service Type M OMB No.: 0970-0154 SC'.3:.'n.ned IJ (Ii ~ (/5 ., fS ~k~ :3 ... '" :,; ~-:.~ ) c ..:.-:~ U) ~-] -<; Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TERRY E. HILL, v. NO. 03-277 CIVIL TERM Defendant CIVIL ACTION - LAW IN DIVORCE BOBBIE J. HILL, PETITION TO WITHDRAW AS COUNSEL AND RULE TO SHOW CAUSE AND NOW, comes Petitioner, Bradley L. Griffie, Esquire, and the law firm of GRIFFIE & ASSOCIATES and Petitions the Court as follows: 1. Your Petitioner is counsel of record for the above-named Plaintiff, Terry E. Hill, with a business address of 200 North Hanover Stre'lt, Carlisle, Cumberland County, Pennsylvania, 2. Your Respondent is the above-named Plaintiff, Terry E. Hill, an adult individual currently residing at 125 Oakflat Road, Newville, Cumberland County, Pennsylvania. 3. Petitioner has been representing Respondent in the above captioned divorce proceedings. 4. On numerous occasions, Petitioner has advised Respondent that he must schedule appointments with Petitioner and provide infonnation to Petitioner in order for Petitioner to assist Respondent in advancing the divorce proceedings. 5. Petitioner has repeatedly advised Respondent that he must pay his current outstanding bill with Petitioner and provide Petitioner with a retainer in order to compensate Petitioner for past servIces and provide the necessary retainer to provide future services in order to advance the divorce proceedings. 6. Respondent has failed and refused to provide payment for services rendered, has failed and refused to provide the required retainer, and has failed and refused to maintain communication with Petitioner or schedule appointments with Petitioner to allow Petitioner to appropriately advance the divorce proceedings, WHEREFORE, Petitioner requests your Honorable, Court to enter a Rule upon Respondent to show cause, if any she has, as to why Petitioner should not be permitted to withdraw as counsel in this matter. Respectfully submitted, 7 ffie, Esquire FFIE & ASSOCIATES 200 North Hanove:r Street Carlisle, P A 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verifY that the statements made in the foregoing document are true and correct I understand that false statements herein are made subject to the penalties of 18 Pa.c'S. Section 4904, relating to unsworn falsifications to authorities. DATE:---1Qj II.. f 6') ~ L. GRIFFIE, ESQUIRE TERRY E. HILL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO. 03-277 CIVIL TERM BOBBIE 1. HILL, Defendant : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE I, Bradley L. Griffie, Esquire, hereby certify that I did, the Ji!!!day of October, 2003, cause a copy of the Petition to Withdraw as Counsel and Rule to Show Cause to be served upon Plaintiff and Defendant's attorney of record by first class mail, postage prepaid at the following addresses: Jeanne B. Costopoulos, Esquire The Executive Offices at Rossmoyne 5000 Ritter Road, Suite 202 P.O. Box 779 Mechanicsburg, PA 17055 Terry E. Hill 125 Oakflat Road Newville, PA 17241 DATE: /6/1 b! /)) . , ,~re E & ASSOCIATES 200 North Hanover Street Carlisle, P A 17013 (717)243-5551 (800)347-5552 C) c: , , ~') :J ., L' '.) <0 Plaintiff ''f' OCT 1 7 2003 ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TERRY E. HILL, v. : NO. 03-277 CIVIL TERM Defendant CIVIL ACTION - LAW IN DIVORCE BOBBIE J. HILL, ORDER OF COURT AND RULE TO SHOW CAUSE AND NOW, this 2 z.~ day of Ochk , 2003, upon presentation and consideration of the within Petition, a Rule is hereby issued upon the Plaintiff, Terry E. Hill, to show cause, if any he has, as to why Petitioner, Bradley L. Griffie, Esquire, and the law firm of GRIFFIE & ASSOCIATES should not be permitted to withdraw as counsel in this matter. Rule returnable Z- 0 days after service by first-dass mail, postage prepaid upon Plaintiff at his last known address. BY THE COURT, hrry E. Hill, Plaintiff .//4- J. Cc: "..Bradley L. Griffie, Esquire, Petitioner ~ ..-1eanne B. Costopoulos, Esquire Attorney for Defendant \-iil. ".,..ii,'" _I (",_,'~_ I.l,-l \,,;';,,111,\,:,.\1'1.::-,.1 ,,. """"OJ >' ~j I SIJ :01 S2 J.JO Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TERRY E. HILL, v. : NO. 03-277 CIVIL TERM Defendant CIVIL ACTION - LAW IN DIVORCE BOBBIE J. HILL, PETITION TO MAKE RULE ABSOLUTE AND NOW, comes Petitioner, Bradley L. Griffie, Esquire, and the law firm of Griffie & Associates and petitions the Court as follows: 1. Petitioner filed a Petition to Withdraw as Counsel and Rule to Show Cause, which resulted in the entry of an Order of Court dated October 22, 2003, a copy of said Order being attached hereto and incorporated herein by reference as Exhibit" A." 2. A true and attested copy of the Petition and Order of Court and Rule to Show Cause was forwarded to the Respondent, Terry E. Hill, by correspondence dated October 28, 2003 to his last known address. 3. A true and attested copy of the Order of Court and Rule to Show Cause and the Petition was forwarded to Jeanee B. Costopoulos, Esquire by correspondence dated October 28, 2003. 4. In excess of thirty-five (35) days has passed since the forwarding of the Petition, Order of Court, and Rule to the Respondent and no response has been filed. WHEREFORE, Petitioner requests your Honorable Court to enter an Order making the Rule absolute and permitting Petitioner to withdraw as counsel for Plaintiff in the above- captioned matter. Respectfully submitted, ~ Date . G . fie, Esquire FFIE ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: 121'1/0:> Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA TERRY E. HILL, v. : NO, 03-277 CIVIL TERM Defendant CIVIL ACTION - LAW IN DIVORCE BOBBIE 1. HILL, CERTIFICATE OF SERVICE I, Bradley L. Griffie, Esquire, hereby certify that I did, the Lf'7^ day of December, 2003, cause a copy of Petitioner's Petition to Make Rule Absolute to be served upon Defendant's attorney of record and Respondent by first class mail, postage prepaid at the following addresses: Jeanee B. Costopoulos, Esquire The Executive Offices ofRossmoyne 5000 Ritter Road, Suite 202 P.O. Box 779 Mechanicsburg, P A 17055 Terry E. Hill 125 Oakflat Road Newville, PA 17241 DATE: 1~'1h)~ ~qUire ney for Defendant GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 OCT 1: 2003, 't Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TERRY E, lULL, v. : NO, 03-277 CIVIL TERM Defendant : CIVIL ACTION -- LAW : IN DIVORCE BOBBIE ll-IILL, ORDER OF COURT AND RULE TO SHOW CAUSE AND NOW, this ~ day of (C)c.tobeL_, 2003, upon presentation and consideration of the within Petition, a Rule is hereby issued upon the Plaintiff, Terry E. Hill, to show cause, if any he has, as to why Petitioner, Bradley 1. Griffie, Esquire, and the law fiml of GRIFFIE & ASSOCIATES should not be permitted to withdraw as counsel in this matter. Rule returnable rlO days after service by first-~lass mail, postage prepaid upon Plaintiff at his last known address. BY THE COURT, . ~ ~dOf)tV J. Cc: Bradley 1. Griffie, Esquire, Petitioner Terry E. Hill, Plaintiff Jeanne B. Costopoulos, Esquire Attomeyfor Defendant EXHIBIT I "A'l -o~ ",";-j '7 :x; z:t;: ~t; ~2 ~ C') W ':::1 'rJ C-) , u; C) --n .c..4 '\;'i/' -..." I ~ I ::;f:r:' ~,) .-J --:1 ~T-l ;:'.~?!5 oin ~ :0 -< " -'. Cd .0 Plaintiff DEC\r$ 2003 IN THE COURT OF COMMON PLEAS 01 CUMBERLAND COUNTY, PENNSYLVANIA TERRY E. HILL, v. NO. 03-277 CIVIL TERM BOBBIE J. HILL, Defendant CIVIL ACTION - LAW IN DIVORCE ORDER OF COURT AND NOW, this II~ day of ))~ , 2003, upon presentation and consideration of the within Petition, the Rule previously issued upon the Plaintiff, Terry E. Hill, to show cause as to why Petitioner, Bradley L. Griffie, Esquire, and the law firm of Griffie & Associates should not be permitted to withdraw as counsel in this matter is hereby made absolute. Upon filing of appropriate Praecipe, Petitioner may withdraw as counsel for the Plaintiff in this action. By the Court, 44- J. Cc: vBradley L. Griffie, Esquire Petitioner vferry E. Hill Plaintiff vfeanee B. Costopoulos, Esquire Attorney for Defendant I~'~ 7 I' ~'~,cl ~ ll-lJ-([) , GF" :''':'. f"iT/\RY OJ [r:'(~ j ; I,: 02 C' '>iF :.i.., ,', .. .,~' i' r,,{ Ulli''-',_l Ji,.rd ,;,j ~~,.....'..;l '\j I PENNSYLVANiA I I I TERRY E. HILL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 03-277 CIVIL TERM Defendant : CIVIL ACTION - LAW : IN DIVORCE BOBBIE J. HILL, PETITION TO MAKE RULE ABSOLUTE AND NOW, comes Petitioner, Bradley 1. Griffie, Esquire, and the law firm of Griffie & Associates and petitions the Court as follows: n......f-~+-~....~~_ ~1~...1 _ n_4-:"-~___ .L_ "T~.LL -1___ TERRY E. HILL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 03-277 CIVIL TERM BOBBIE J. HILL, Defendant CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Pursuant to the Court's Order of December 11,2003, making my Petition to Withdraw as Counsel Absolute, please withdraw my appearance previously entered in the above captioned matter on behalf of the Plaintiff, Terry E. Hill. Respectfully submitted, Date:~ ~re ,. ~I' ~~~~OC:ATES 200 North Hanover Street Carlisle, P A 17013 (717) 243-5551 (800) 347-5552 , (') ..... c =- (') = ;;0:'" ,... -11 <::I :I! rq C") rnJ~ -Om m :0<:;:' ~c, -0 , -r. -",- ~Ii _...t". ;:20 ~ (,'<;) ~.5m ---~ :~:--J ....... !"j ,~. :D c..; -< i TERRY E. HILL, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : No: 03-277 CIVIL TERM BOBBIE J. HILL, Defendant : CIVIL ACTION - LAW : IN DIVORCE NOTTC'R TO nRFF,Nn ANn C'I .AIM Rlr.HTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you, and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children, When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counsdors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ON]&:, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHE:RE YOU CAN GET LEGAL HELP. Cumberland County Bar Associlltion 32 South Bedford Street Carlisle, P A 17013-3308 (717) 249-3166 TERRY E. HILL, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : No: 03-277 CrVIL TERM BOBBIE J. IDLL, Defendant : CIVIL ACTION - LAW : IN DIVORCE COTlNTRR('J ,4 1M TN mvo"~ IlNllRR 1",",01(J:) OR 1","'01 (d) OF THE mVORCF. COOE AND NOW, comes the Defendant, Bobbie J. Hill, by and through her attorney, Jeanne B. Costopoulos, Esquire, and avers the following in support of this Counterclaim in Divorce: I. The Plaintiff, Terry E. Hill, is an adult individual who is believed to reside at 125 Oakflat Road, Newville, Cumberland County, Pennsylvania 17241. 2, The Defendant, Bobie J. Hill, is an adult individual who currently resides at 59 Glendale Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Counterclaim. 4, The Plaintiff and the Defendant were married on April 29, 2000 in Cumberland County, Pennsylvania. COITNT I - OIVORCE 5. The prior paragraphs of this Counterclaim are incorporated herein by reference thereto. 6, The marriage is irretrievably broken. 7. The parties have been living separate and apart since December 27,2002. 8. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 9. The Defendant has been advised that counseling is available and that the Defendant may have the right to request that the court require tne parties to participate in counseling. 10. There are no dependent children from this marriage. II. This action is not collusive. WHEREFORE, the Plaintiff respectfully requests this Honorable Court to grant the Defendant relief from the bonds of matrimony and order a Decree in Divorce, Count IT - Rquitahlp. ni~trihlltinn ofMsnital Prnpp.rty Pun,uln. tn fi~~O'2 nfthp nivnr~p. Cnilp. 12. The prior paragraphs of this Counterclaim are incorporated herein by reference thereto. 13, During the marriage of the parties, they acquired real and personal property, which constitutes marital property under the Divorce Code. 14. This Honorable Court is authorized by the Divorce Code to equitably divide, distribute or assign the marital property and liabilities between the parties in such proportion as the Court deems just after consideration of all relevant factors. WHEREFORE, the Defendant respectfully requests this Honorable Court to enter an order of equitable distribution of marital property pursuant to ~3502 of the Divorce Code. Dated: RESPECTFULLY SUBMITTED: rl3!tv , ~---- Jeanne B. Costopoulos, Esquire..............., 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 P A Supreme Court ID No. 68735 Telephone: (717) 790-9546 Fax: (717) 790-6019 ATTORNEY FOR DEFENDANT TERRY E. IllLL, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : No: 03-277 CIVIL TERM BOBBIE J. IllLL, Defendant : CIVIL ACTION - LAW : IN DIVORCE VFRTFTCATTON I, Bobbie J. Hill, verifY that the statements made in the foregoing Counterclaim are true and correct to the best of my knowledge, information, and beli,~f, 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. Dated: ~ ~M ' (ffIj~ Bobbie J. Hill ~ (') C ? ~Hfi ;:2: ~:,Li .> -"".. , o:j ";- ~;~. :.,'-'; J...::c' ,,:.. /...< .l>c; ~ '" = = ..,. :Do -0 ;;;0 N -' ~ X~ ~~ 9;J;l 0;-"; ~ -u ::r ~ .r- W ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Disl. of CUMBERLAND Date of Order/Notice 06/30/04 Tribunal/Case Number (See Addendum for case summary) o Original Order/Notice @ Amended Order/Notice o Terminate Order/Notice EmployerANithholder's Federal EIN Number RE: HILL, TERRY E. Employee/Obligor's Name (last, First, MI) 235-11-0610 Employee/Obligor's Social Security Number 7219100741 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, MI) EDWIN L HElM CO PO BOX 2247 HARRISBURG PA 17105-2247 ]xj ~;Y3.:J77 ('(?,Ie )1.1,,(',--::. -h'~.I'''''<2;?6 /'f(C:.c-.~- /~ C J-,~ v j)/:/ /O??}.:5 (;LOtlJ j-'Jk'S:';> 3;;. 3/6~c:.Y2- See Addendum far dependent names and birth dates associal'ed with cases on attachmen't. ORDER INFORMA nON: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 305.00 per month in current support $ 50.00 per month in past-due support Arrears 12 weeks or greater? Qyes @ no $ 0.00 per month in medical support $ 0 . 00 per month for genetic test costs $ per month in other (specify) for a total af $ 355.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 81.92 per weekly pay period. $ 163 . 85 per biweekly pay period (every two weeks). $ 177.50 per semimonthly pay period (twice a month). $ 355.00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's! obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #10 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (5CDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER 10 (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. . '. r,' 'I,! 'i:'?P ';.'", ",';JJ:.~'f~Lih<'JfHE COU~~ JUL - 1 200\ --___L / () 'l - 'r' Date of Order: .' ).;'PI//)./ f7 lie:': #9, / ~ Service Type M OMB No.: 0970-0154 '/O!)&./.'- Form E N-028 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If ~hecked you are required to provide a \Copy of this form to your employee. If your employee works in a state that is different from the state that issued this order, a copy must be provided to your employee even if the box is not checked. 1. We appreciate the voluntary compliance of Federally recognized indian tribes, tribally-owned businesses, and Indian-owned businesses located on a reservation that choose to withhold in accordance with this notice. 2. Priority: Withholding under this Order/Notice has priority over any other iegal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 3. Combining Payments: You can combine withheld amounts from more than one employee/obiigor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 4.* RepOlti"g tl" P.,d.t.m.te 6fWiU,I,I>lding. YI>" ",u.t'~po,t tl,~ pa,date/daM of ..itl,l,oldi"g ..I,~" ,~"di"g the pa,l"e"t. TI" I-'A1dAt~'dAM of n;II,I.old;,.g i$ tin:;; date VII yy!iid, AlllOUllt m!..3 yy;t1,L~ld ~()'II tL~ l",pIOy~{,'3 U'A~&. You must comply with the law of the state of the employee'slobligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 5. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support OrderlNotices due to Federal or State withholding limits,.you must follow the law of the state of employee'slobligor's prinCipal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #10 below) 6. Termination NotifICation: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S 10: 2312659240 EMPLOYEE'S/OBLlGOR'S NAME: HILL , TERRY E. EMPLOYEE'S CASE IDENTIFIER: 7219100741 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is empioyed in another State, in which case the law of the State in which he or she is employed governs. 9. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 10. * Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.c. 91673 (b)1; or 2) the amounts allowed by the State of the employee'slobiigor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 11. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at 17171 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 Form E N.028 Worker ID $IATT Service Type M OMB No.: 0970-0154 ADDENDUM Summarv of Cases on Attachmenll Defendant/Obligor: HILL, TERRY E. PACSES Case Number 758105280 Plaintiff Name BOBBIE J. HILL Docket Attachment Amount 03 -277 CIVIL $ 355.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Nam'~ Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB you are required to enroll the child(ren) in any health insurance coverage available employee'slobligor's employment. you are required to enroll the child(ren) in any health insurance coverage available employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Nam'~ Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB you are required to enroll the child(ren) in any health insurance coverage available employee's/obligor's employment. you are required to enroll the child(ren) in any health insurance coverage available ernployee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Ch ild(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name: Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB you are required to enroll the child(ren) in any health insurance coverage available employee's/obligor's employment. you are required to enroll the child(ren) in any health insurance coverage available ernployee's/obligor's employment. Addendum Form EN-028 Worker ID $IATT Service Type M OMB No.: 0970.Q154 C) ,...~ () c;::? C-.: ~ pn .x.- .. .. (...~ :-:;! e,l.__ ::!J n"t ~ d , - , , .. , ;r > (-.- c') ..,::; ::.:< r<' 0",\ In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION 13 N. HANOVER ST, P.O. BOX 320, CARl.ISLE:, PA. 17013 Phone: (717) 240-6225 Fax: (717) 240-6248 Defendant Name: TERRY E. HILL Member ID Number: 7219100741 Please note: All correspondence must include the Member ID Number. MODIFIED ORDER OF ATTACHMENT OF UNEMPLOYMENT BENEFITS Plaintiff Name BOBBIE J. HILL Financial Break Down of Multiple Cases on Attachment PACSES Docket Case Number Number: Attachment AmountlFreouencv 758105280 03 -277 CIVIL i 355.00 IMONTH j,;Z31{/5-Cf.} Ic'C.]~,' .fi:-,'}- 6 ~ / $ / $ % I ~ $ / TOTAL ATTACHMENT AMOIJNT: $ 355.00 Now, by Order of this Court, the Department of Labor and Industry, Bureau of Unemployment Compensation Benefits and Allowances (BUCBA), is hereby directed to attach the lesser of $ 81. 92 per week, or 50.0 %, of the Unemployment Compensation benefits otherwise payable to the Defendant, TERRY E. HILL Social Security Number 235-11-0610, Member 10 Number 72191 0 0 7 41 . BUCBA is ordered to remit the amount attached to the Department of Public Welfare (DPW). DPW shall forward the amount received from BUCBA to the Domestic Relations Section of this Court for support and/or support arrearages. If the Defendant's Unemployment Compensation benefits are attached by another Court or Courts for support and/or support arrearage, DPW may reduce the amount attached under this Order so that the total amount attached does not exceed the maximum amount subject to garnishment pursuant to 15 U.S.c. ~ 1673(b)(2) and 23 Pa. C.S. ~ 4348(g). This Order shall be effective upon receipt of the notice of the Order by the BUCBA and shall remain in effect until the Defendant's entitlement to Unemployment Compensation benefits, under the Application for Benefits dated MAY 5, 2002 is exhausted, expired or deferred. BUCBA shall comply with this Order, unless it is amended or vaeated by subsequent Order of this Court. All questions, challenges or obligations to this Order shall be directed to tbe Domestic Relations Section of this Court. BY THE COURT Date of Order: JUL - 1 2004 /~. /9.~ Kt.~ d.L I'} liE c:s. JUDGE Service Type M Form EN -034 Worker ID $IATT "-> C-::~ C--::) (_. , j". (.-) N en Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA TERRY E. HILL, v. : No. 03-277 CIVIL TERM Defendant : CIVIL ACTION- LAW : IN DIVORCE BOBBIE J. HILL, TO THE HONORABLE JUDGES OF SAID COURT: DRFRNDA NT'S MOTION TO C'OMPF,I. mSC'OVF.RV AND NOW COMES the Defendant, Bobbie J. Hill (hereinafter referred to as Wife), by and through her attorney, Jeanne B. Costopoulos, Esquire, and Diles the following Motion to Compel Discovery: 1. The above-captioned matter was originally commenced by Plaintiff (hereinafter referred to as Husband) on or about January 17,2003 by the filing of a no-fault divorce with one count for equitable distribution. 2. Wife filed a Petition for Related Claims on or about February 3, 2003, containing a request for alimony, alimony pendente lite, and counsel fees. 3. On or about April 9, 2003, alimony pendente lite was awarded to Wife in the amount of $382.00 per month from February 1, 2003 through April 13, 2003 and $305.00 per month from April 14, 2003 and thereafter. 4. On or about December 11, 2003, Bradley 1. Griffie, Esquire, was granted leave to withdraw as Husband's attorney. Husband has been acting pro se since that time and has not contacted Wife's attorney to discuss resolution of equitable distribution and other divorce related issues. 5. On or about April 27, 2004, Wife filed a no-fault Counterclaim in Divorce containing a count for equitable distribution. 6. As part of Wife's discovery and in order to properly devdop her claims against Husband, on or about May 10, 2004, together with Wife's Counterclaim in Divorce, Husband was served with discovery in the form of Defendant's Interrogatories to Plaintiff - First Set and Defendant's Request for Productions of Documents .- First Set. See attached Exhibit A, a copy of the letter sent to Husband with the countercl:aim and discovery requests, and Exhibit B, the certified mail receipt evidencing Husband's receipt of said discovery requests. 7. Husband has neither made nor filed any objections to Wife's discovery requests. 8. The discovery requested is necessary to the proper development and presentation of Wife's case. 9. Husband's conduct has been totally unjustified and has r'~quired this Motion to be filed. Further, Wife, based upon her counsel's usual, customary and reasonable charge, is obliged to pay her counsel the sum of$750.00 for the preparation of this Motion ($250.00) and the attendance at the hearing disposing of same ($500.00). WHEREFORE, Defendant respectfully requests that this Honorable Court enter an Order compelling the Plaintiff to provide responses to Defendant's Intt:rrogatories to Plaintiff - First Set and Defendant's Request for Productions of Documents - First Set within ten (10) days from the entry of such Order, and upon the Plaintiff's failure to do so within time allotted, to suffer sanctions to be imposed by further order of the Court, and furthe,r that the Plaintiff shall pay Defendant the sum of $250.00 for the preparation and filing ofthis Motion and an additional $500.00 in the event a hearing is necessary for disposition of this issue. Respectfully submitted, BY: DATED: 1(()!zo1 eanne B. Costopoulos, Esquire 5000 Ritter Road, Suite 202 Mechanicsburg, P A 17055 Phone: (717) 790-9546 P A Supreme Ct. 1D No. 68735 Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA TERRY E. HILL, v. : No. 03-277 CIVIL TERM BOBBIE J. HILL, Defendant : CIVIL ACTION - LAW : IN DIVORCE C'F,RTTFTC'ATF. OF SF.RVTC'l~ I, Jeanne B. Costopoulos, Esquire, hereby certifY that this day I served a copy of the attached Order of Court upon the person, and in the manner, indicated below, which service satisfies the requirements of the P A Rules of Civil Procedure, by depositing a copy of the same with the United States Post Office at Mechanicsburg, Pennsylvania, through first class mail, prepaid, and addressed as follows: Terry E. Hill 125 Oakflat Road Newville, P A 17241 .-/ BY: // Jeanne B. Costopoulos, Esquire 5000 Ritter Road, Suite 202 Mechanicsburg, P A 17055 Phone: (717) 790-9546 P A Supreme Ct. ill No. 68735 - DATED: 7;} lie rroy West Shore (717) 790-9546 East Shore (717) 221-0900 JEANNE B. COSTOPOULOS, ESQUIRE The Executive Offices at Rossmoyne 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055-6922 E-mail: jbclegal@p:ol.com Facsimile: (717) 790-6019 April 29, 2004 Terry E. Hill 125 Oakflat Road Newville, P A 17241 VIA RESTRICTED DELIVERY CERTIFIED MAIL NO. 700015300001 6001 8909 Dear Mr. Hill: As you are aware, I represent Bobbie J. Hill regarding the divorce action filed by you. I am herewith serving you a copy of the Counterclaim in Divorce, which I have filed on behalf of Bobbie 1. HilL I am also herewith serving you copies of Defendant's Interrogatories to Plaintiff - First Set and Defendant's Request for the Production of Documents - First Set. Be advised that you must provide me with your responses within thirty days of receipt. I have also enclosed a Marital Settlement Agreement. If acceptable, please initial each page and sign and date the last page of the Marital Settlement Agreement then return it to me in the enclosed pre-stamped envelope. If! rel;eive the signed Marital Settlement Agreement, I will no longer need you to complet,e the Interrogatories or Request for Production documents because the divorce case will be settled and all that will remain will be for us to complete the finalizing paperwork and request a judge to sign a Decree in Divorce. I advise you to review the enclosed agreement with an attorney of your choice. Please call if you have any questions or if your address changes. Sincerely yours, / ;..:::....--.-------- Jeanne B. Costopoulos, Esquire cc: BobbieJ. Hill File EXHIBIT A . Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mail piece, or on the front if space permits. 1. Article Addressed to: D. ~rr~ E. IIi /I 1'-5 Oa.kf1il..t- ~oJ }lewvt'I/~) P4. /7J.L(( 3. Service Type ..e:certiflod Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) ~ 000/ 'bfj( 19"1 2. Article (frans 102595-Q1-M-2509 EXHIBIT B z~ ~ ~c ~1 )>! ...., c::; C::,-) .r.- (..... c:: ,- U1 o -n .-\ :( -rl fI!;",,-;:;' -0 hI -'-ll::J (c., ! ~~{C) ," ~ f, -n f.~ -u N ., c....) o ()~il;,..! ~/ JUL 1 6 2004 .tJ' Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA TERRY E. HILL, v. : No. 03-277 CIVIL TERM BOBBIE J. HILL, Defendant CIVIL ACTION - LAW CUSTODY ORnFR OF rOTTRT AND NOW, this z.c. ~ day of 1~ , 2004, upon consideration of Defendant' s Motion to Compel Discovery, it is hereby Ordered that Plaintiff shall provide responses to Defendant's Interrogatories to Plaintiff - First Set and Defendant's Request for ~ (z-~? Productions of Documents - First Set within~) days of service of this Order. It is furtl~. ora.sFea tro:at Pla;nfifl" ch....'l }3a) B""K,lldc:tul tll~ SWll uf )L:)u.uu tor me plcpau.....hSB" /<,;1 fU1{1 filine- ofhP:T Motion within h'lleR~ (18) $)t3 af Jf,f y~",,,,, urdu:) OJ.d,",J.~ BY THI~ COURT: / ~f< ;1J;.L / J. '~:~/,.jriJ !12 :8 !'l~ 9;; -Inr 'IOOl IJ)JVI01"~!DH10b'd 3Hl .=10 3:)1:1:!0-0311:/ ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of penn!iOvlvania Co.lCity/Dist. of CUMBERLAND Date of Order/Notice 08/12/04 Tribunal/Case Number (See Addendum for case summary) RE: HILL, TERRY E. EmployerM'ithholder's Federal fiN Number -15ZID5a~ Q3-al1 c.ux2/ EDWIN L HElM CO PO BOX 2247 HARRISBURG PA 17105-2247 o Original Order/Notice @ Amended Order/Notice o Terminate Order/Notice Employee/Obligor's Name (last, First, MI) 235-11-0610 Employee/Obligor's Social Security Number 7219100741 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (last, first, MI) See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee'slobligor's income until further notice even if the Order/Notice is not issued by your State. $ 305.00 per month in current support $ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes @ no $ 0.00 per month in medical support $ 0 . 00 per month for genetic test costs $ per month in other (specify) for a total of $ 305.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 70.38 per weekly pay period. $ 140.77 per biweekly pay period (every two weeks). $ 152.50 per semimonthly pay period (twice a month). $ 305.00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydateldate of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot excped 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #10 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1_877-676-9580 for instructions. Make Remittance Payable to: PA seou Send check to: Pennsylvania seou, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INClUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURlrY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: f-' Date of Order: AUG 1 3 200; Service Type M OMS No.: 0970-0154 A. 4.. Form EN-028 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AN[)I OTHER WITHHOLDERS o If ~hecked you are required to prpyi(Je a (Copy of this form to your. employee. If yo~r employee works in.a state that iSd different from the state that issued thiS order, a copy must be proVided to your employee even If the box IS not checke . 1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned businesses located on a reservation that choose to withhold in accordance with this notice. 2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 4. * Report;lIg ll,~ F'a.yda.telDak. of 'Iv'ithhold;"g. YOl:. l"tJ~t l~pOJt tile paydatelde\t~ of yy;tLLoldil,g vvllell sehdiltg the Pa.YIII~lIl. TLe pa,dat,,:dat< of ..;lI,l,oldil ,g i, tI,e date 01, ..,,;<1, _",O""t ..os ..itl,l,eld flOn, ll,t (,,,>,10,..', .._ge,. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 5. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. ISee #1 0 below) 6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and retum a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S ID: 2312659240 EMPLOYEE'S/OBLlGOR'S NAME: HILL , TERRY E. EMPLOYEE'S CASE IDENTIFIER: 7219100741 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law govems unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 10. * Withholding Limits: You may not withhold more than the iesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act 11 S U.s.c. 91673 (b)l; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 11. Additional Info: * NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at [Z17l 240-6248 or by internet :vww.childsupport.state.pa.us Page 2 of 2 Form E N-028 Worker ID $IATT Service Type M OMBNo.:097()"()154 ADDENDUM Summary of Cases on Attachment Defendant/Obligor: HILL, TERRY E. PACSES Case Number 758105280 Plaintiff Name BOBBIE J. HILL Docket Attachment Amount 03-277 CIVIL $ 305.00 Child(ren)'s Name(s): PACSES Case Number Plaintiff Name DOB Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB IXIlf checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name P ACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Dockel[ Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB o If checked, you are required to enroll the ch i1d (ren) identified above in any health insurance coverage available through the employee'slobligor's employment. o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee'slobligor's employment. PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff ~Iame Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Docke! Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee'slobligor's employment. o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. Addendum Form E N-028 Worker ID $IATT Service Type M OMB No.: 0970-0154 ~~:-!, C ::1 r:'; n :? c:i ...., i:.::~ (I -Tr :~~:f (...) S~) U1 CUMBERLAND County, Pennsylvania In the Court of Common Pleas of Phone: (717) 240-6225 DOMESTIC RELATIONS SECTION 13 N. HANOVER Sf, P.O. BOX 320, CARLISLE, PA.17013 Defendant Name: TERRY E. HILL Member ID Number: 7219100741 Please note: All correspondence must include the Member ID Number. Fax: (717) 240-6248 MODIFIED ORDER OF ATTACHMENT OF UNEMPLOYMENT BENEFITS Plaintiff Name BOBBIE J. HILL Financial Break Down of Multifile Cases on Attachment PACSES Docket Case Number Number 75B~052BO 03-277 CIVIL TOTAL ATTACHMENT AMOUNT: $ Attachment Amount/Freauency 305.00 jMONTH 'l / / 'l I / / $ i $ $ i $ 305.00 Now, by Order of this Court, the Department of Labor and Industry, Bureau of Unemployment Compensation Benefits and Allowances (BUCBA), is hereby directed to attach the lesser of $ 70.38 per week, or 50. 0 %, of the Unemployment Compensation benefits otherwise payable to the Defendant, TERRY E. HILL Social S(:curiry Number 235-11-0610, Member ID Number 7219100741 . BUCBA is ordered to remit the amount attached to the Department of Public Welfare (DPW). DPW shall forward the amount received from BUCBA to the Domestic Relations Section of this Court for support and/or support arrearages. If the Defendant's Unemployment Compensation benefits are attached by another Court or Courts for support and/or support arrearage, DPW may reduce the amount attacht:(\ under this Order so that the total amount attached does not exceed the maximum amount subject to garnishment pursuant to 15 U.S.c. ~ l673(b)(2) and 23 Pa. C.S. ~ 4348(g). This Order shall be effective upon receipt of the notice of the Order by the BUCBA and shall remain in effect until the Defendant's entitlement to Unemployment Compensation benefits, under the Application for Benefits dated MAY 5. 2002 is exhausted, expired or deferred. BUCBA shall comply with this Order, unless it is amended or vacated by subsequent Order of this Court. All questions, challenges or obligations to this Order shall be directe<i to the Domestic Relations Section of this Court. BY THE COURT t.1I~ 1 3 C)Ml Date of Order: . . LUU~ /~. / Service Type M /9.AL JUDGE Form EN-034 WorkerlD $IATT Iv.< "::''-!C.3 c. ~~,'- S2 nneci ." ~'::-":;' S;~2 c: ~y; :,~! 1I1';iJ -Clrp ;IJyi >.1() ~~;;~~; :'"5n1 ::;:~ "-.~-! :t::,.';~ C.,. C;'") -J ~ -;:/. S';) c.n .C' In the Court of common Pleas of CUMBERLAND County, Pennsylvania DOMEsrIC RELATIONS SECTION 13 N. HANOVER ST, P.O. BOX 320, CARL1SLE, PI.. 17013 Phone: (717) 240-6225 Defendant Name: TERRY E. HILL Member ID Number: 7219100741 Please note: AU correspondence must include the Member ID Number. Fax: (717) 240.6248 MODIFIED ORDER OF ATTACHMENT OF UNEMl>LOYMENT BENEFITS Plaintiff Name BOBBIE J. HILL Financial Break Down of Multinle Cases on Attachment P ACSES Docket Case Number Number 758105280 03-277 CIVIL TOTAL ATTACHMENT AMOUNT: $ Attachment Amount/FreQuency 355.00 IMONTH 'l / / 'l I / / $ t $ $ t $ 355.00 Now, by Order of this Court, the Department of Labor and Industry, Bureau of Unemployment Compensation Benefits and A\1owances (BUCBA), is hereby directed to attach the lesser of $ 81 . 92 per week, or 50. 0 %, of the Unemployment Compensation benefits otherwise payable to the Defendant, TERRY E. HILL Social Security Number 235 -ll- 0 61 0 , Member 10 Number 7219100741 . BUCBA is ordered to remit the amount attached to the Department of Public Welfare (DPW). DPW shall forward the amount received from BUCBA to the Domestic Relations Section of this Court for support and/or support arrearages. If the Defendant's Unemployment Compensation benefits are attached by another Court or Courts for support and/or support arrearage, DPW may reduce the amount attached under this Order so that the total amount attached does not exceed the maximum amount subject to garnishment pursuant to 15 U.S.C. ~ 1673(b)(2) and 23 Pa. C.S. ~ 4348(g). This Order shall be effective upon receipt of the notice of the Order by the BUCBA and shall remain in effect until the Defendant's entitlement to Unemployment Compensation benefits, under the Application for Benefits dated AUGUST 29, 2004 is exhausted, expired or deferred. BUCBA shall comply with this Order, unless it is amended or vacated by subsequent Order of this Court. All questions, challenges or obligations to this Order shall be directed 110 the Domestic Relations Section of this Court. Date of Order: J ,10. V ~ BY THE COURT ~,,/ /~ ,,4.. JUDGE Service Type M Form EN-034 Worker 10 $IATT ,.- .:"! r~, ("'~, ~::. ,- ...,~, o ~ ~".> .J:- N ......., cO> = .r- C/) r..., -Q o -" ::;J FTiE;: """01_,,-. ."6 ?'-'") ~::l ~"" :7~ -,~I f~~~~ .' ~~ ~,o -< <:'11 ;'! In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION 13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013 Defendant Name: TERRY E. HILL Member ID Number: 7219100741 Please note: AU correspondence must include the Member ill Number. ORDER OF AITACHMENT OF UNEMPLOYMENT COMPENSATION BENEFITS Financial Break Down of Mulliple Cases on Attachment Plaintiff Name BOBBIE J. HILL P ACSES Case Number 758105280 Dockelt Number 03-277 CIVIL Attachment Amount/Freauency $ ! $ $ ! $ 305.00 jMONTH ~ / / % ! / / TOTAL AITACHMENT AMOllNT: $ 305.00 Now, by Order of this Court, the Department of Labor and Industry, Bureau of Unemployment Compensation Benefits and Allowances (BUCBA), is hereby directed to attach the lesser of $ 70.38 per week, or 50 %, of the Unemployment Compensation benefits othelwise payable to the Defendant, TERRY E. HILL Social Security Number 235-11-0610, Member ID Number 7219100741 . BUCBA is ordered to remit the amount attached to the Department of Public Welfare (DPW). DPW shall forward the amount received from BUCBA to the Domestic Relations Section of this Court for support and/or support arrearages. If the Defendant's Unemployment Compensation benefits are attached by another Court or Courts for support and/or support arrearages, DPW may reduce the amount attached under this Order so that the total amount attached does not exceed the maximum amount subject to garnishmem pursuant to 15 U.S.c. ~ 1673 (b)(2) and 23 Pa. C.S.A. ~ 4348 (g). This Order shall be effective upon receipt of the notice of the Order by the BUCBA and shall remain in effect until the Defendant's entitlement to Unemployment Compensation benefits, under the Application for Benefits dated AUGUST 29, 2004 is exhausted, expired or deferred. BUCBA shall comply with this Order, unless it is amended or vacated by subsequent Order of this Court. All questions, challenges or obligations to this Order shall be directed to the Domestic Relations Section of this Court. BY THE COURT Date of Order: SEP 1 4 2004 ):-. /?~ ~ A. +kJ.~, JUDGE Service Type M Form EN.530 Worker ID $IATT (") ....., = 0 c c.'" .'n <: .&- ",) (/) ,1 . , , rrl f~l -n --0 r _. .'J !Tj U1 ::.bc.'J C) (:l , "--l - .~ -\-, .., ~'~~ (~:? -~'.... S'~ --.' ./ :-~> =2 r.- TJ c.v :.< ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsvlvania Co./City/Oist. of CUMBERLAND Date of Order/Notice 09/16/04 TribunallCase Number (See Addendum for case summary) @Original Order/Notice o Amended Order/Notice o Terminate Order/Notice EmployerNVithholder's Federal EIN Number RE: HILL, TERRY E. Employee/Obligor's Name (last, First, Ml) 235-11-0610 Employee/Obligor's Social Security Number 7219100741 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (last, First, MI) EDWIN L HElM CO PO BOX 2247 HARRISBURG PA 17105-2247 DJ1 otn3-J77 ('/V/L P/l~5<;S 7~{)5).i{; See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's!obligor's income until further notice even if the Order/Notice is not issued by your State. $ 305.00 per month in current support $ 50.00 per month in past-due support Arrears 12 weeks or greater? 0 yes <Xl no $ 0.00 per month in medical support $ 0 . 00 per month for genetic test costs $ per month in other (specify) for a total of $ 355.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 81.92 per weekly pay period. $ 163.85 per biweekly pay period (every two weeks). $ 177 .50 per semimonthly pay period (twice a month). $ 355.00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydateldate of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's! obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #10 on pg. 2). If remitting by EFT/EOI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer SelVice at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. ~. 4.. Date of Order: SEP 1 7 200+ SelVice Type M ~f~J~1S~PV/ 7v~&G- Form EN-028 Worker 10 $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o I(~hecked you are required. to prpvi(le a ~opy of this form to you~ employee. If yo~r employee works in.a state that is dltterent from the state that Issued thIS order, a copy must be provided to your employee even If the box IS not checked. 1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian.owned businesses located on a reservation that choose to withhold in accordance with this notice. 2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 4.* R'polti"g II,e P,,~'I""D.t' ofWitl,I,<lI~i"g. \'ou ,,,",I "pe"t t;,e p.,d,fu,'~'l' <If ..itl,;,()ldil,g ..h." ,^"di"g t1,. p.,I"."t TI" pAyddtdda.~ of vvitLLoldihg i! tile dare 011 vvl.;d. al1lotull Has n;Lhltdd hom tl.{. ~"Iployee's YVago. You must comply with the law of the state of the employee'slobligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 5. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee'slobligor's principal place of employment You must honor all Orders/Notices to the greatest extent possible. (See #10 below) 6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S 10: 2312659240 EMPLOYEE'S/OBlIGOR'S NAME: HILL , TERRY E. EMPLOYEE'S CASE IDENTIFIER: 7219100741 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contad the person or .authority below. B. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. Anti-discrimination: You are subject to a fine determined under State iaw for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 10. * Withholding limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.c. ~1673 (b)l; or 2) the amounts allowed by the State of the employee'slobligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxesi Social Security taxesi and Medicare taxes. 11. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717\ 240-6248 or by internet www.childsupport.state.pa.us Service Type M Page 2 of 2 Form EN-02B Worker ID $IATT OMS No.: 0970-0154 ADDENDUM Summarv of Cases on Attachment Defendant/Obligor: HILL, TERRY E. PACSES Case Number 758105280 Plaintiff Name BOBBIE J. HILL Docket Attachment Amount 03=277CIVIL $ 355.00 Child(ren)'s Name(s): PACSES Case Number Plaintiff Name DOB Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB [XJ If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee'slobligor's employment. o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB If checked, you are required to enroll the child(ren) in any health insurance coverage available employee's/obligor's employment. o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee'slobligor's employment. PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. Service Type M Addendum Form E N-02B Worker ID $IATT OMS No.: 0970-0154 -'-c,:::!-nn81.:j o C-: ..... ....., = C~ ....- (/) p, -';) !'.) Cl o .) ..... f1i ;: ~~) -nfTl ;~~~~ {-~.) .r.- N TERRY E. HILL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 03-277 CNIL TERM BOBBIE J. HILL, Defendant : CNIL ACTION - LAW : IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE To the Prothonotary: Please enter the appearance of the undersigned as counsel for the Plaintiff in the above-captioned matter. Date: ~/;.&7' d~~ Gary~ Rothschild, Esquire Sup. Ct. LD. No. 62041 2215 Forest Hills Drive, Suite 35 Harrisburg, P A 17112 (717) 540-3510 '-0 ,~..:, :z2 o ~n :_L! V) :,,-'1 i.) r-.., N r:? C) C-, ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 10/27/04 Tribunal/Case Number (See Addendum for case summary) RE: HILL, TERRY E. Q Original Order/Notice Q Amended Order/Notice @ Terminate Order/Notice bRI ~S Employee/Obligor's Name (Last, First, Mil 235-11-0610 Employee/Obligor's Social Security Number 7219100741 Employee/Obligor's Case Identifier (See Addendum for plaintiff names , associated with cases 01/ attachment) c2PZJ 3 -;z. 7'7 ~ IIILCustodial Parent's Name (Last, First, Mil 7/?2}' J05;)-K'O EmployertWithholder's Federal EIN Number EDWIN L HEIM CO PO BOX 2247 HARRISBURG PA 17105-2247 See Addendum for dependent names and birth dates associatecJ with cases on attachment. ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's!obligor's income until further noltice even if the Order/Notice is not issued by your State. $ 0 . 00 per month in current support $ 0.00 per month in past-due support Arrears 12 weeks or greater? Qyes ~ no $ 0.00 per month in medical support $ 0 . 00 per month for genetic test costs $ per month in other (specify) for a total of $ 0.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 0.00 per weekly pay period. $ 0.00 per biweekly pay period (every two weeks). $ 0 . 00 per semimonthly pay period (twice a month). $ 0.00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed ~i5% of the employee's! obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #10 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbur:;ement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: P A SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NIJ'MBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. Date of Order: OCT 2 G 2004 ~ f"'; ;;"~-"./ E COURT: -~. A. ~~ ~ .7VJU- Form EN-028 Worker ID $IATT Service Type M OMS No.: 0970-0154 ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If c.hecked you are required to provide a copy of this form to your employee. If YO\.lr employee works in a state that is ditterent from the state that issued this order, a copy must be provided to your employee even if the box is not checked. 1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned businesses located on a reservation that choose to withhold in accordance with this notice. 2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 4. * Reporting the raydat~Date of Withholding. You must report the paydate/date of ...vithholding \i. hen sending the payment. The paydateldate of ..ithholding is the date on vvhich amount vvas withheld from the emplo'/ee's vvages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 5. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #10 below) 6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S 10: 2312659240 EMPLOYEE'S/OBlIGOR'S NAME: HILL, TERRY E. EMPLOYEE'S CASE IDENTIFIER: 7219100741 DATE OF SHJARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 8. liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law govems unless the obligor is employed in another State, in which case the law of the State in which he or she is employed govems. 9. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law govems unless the obligor is employed in another State, in which case the law of the State in which he or she is employed govems. 10. * Withholding limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.c. ~ 1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly eamings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 11. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at <717) 240-6225 or by FAX at LZ1ZU40-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Worker ID $IATT Service Type M OMB No.: 0970.()154 (') ~ 0 c:::> C c:;::> ., -- ..4- ~. '':'. :re -I n , I:n !" i Q ...~ f1" oti.'._ I ~? ::"~: N ~.~:lu rc ',--" -0 T:1j };~: \~ "\ ::r.: '=.~C) :::-c.CJ f'" rTl )- r" . W >~ ~ ( r) ~~T ...., ......1 -< CO -', TERRY E. HILL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 03-277 CIVIL TERM BOBBIE J. HILL, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE FOR WITHDRAWAL OF APPEARANCE To the Prothonotary: Please withdraw the appearance ofthe undersigm:d as counsel for the Plaintiff in the above-captioned matter. Date:~'5 ~, E,uire S p. ct. LD. No. ) ~ '1? GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, P A 17013 (717) 243-5551 .~,..\ -<~'. (.,) (:! - In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION BOBBIE J. HILL ) Docket Number 03-277 CIVIL Plaintiff ) vs. ) PACSES Case Number 758105280 TERRY E. HILL ) Defendant ) Other State ID Number PETITION FOR CONTEMPT - DEFENDANT TO THE HONORABLE, THE JUDGES OF SAID COURT: 1. Petitioner is CUMBERLAND County Domestic Relations Section. who resides at 2. Defendant is TERRY E. HILL 125 OAK FLAT RD, NEWVILLE, PA. 17241-9467-25 3. On APRIL 9, 2003 an order of support was entered by the Honorable Court directing Defendant to pay the sum of $ 355.00 his/her dependent(s). 4. Defendant has failed to comply with the order as entered by the Court by failing to: per month for the support of [Xl pay as ordered. [Xl provide information which was ordered. [Xl appear as ordered. IXI other: Failure to maintain employment, last payment was 2/12/05 from ue benefits. 5. The arrearages under the Order amount to $ 796 . 53 as of MAY 4, 2005 WHEREFORE, Petitioner prays that the Court issue an order directing the attendance of Defendant at a hearing of said Petition and hereafter to make an adjudication of contempt. I verify that the statements made in this Petition are true and correct to the best of my knowledge. I understand that false statements herein are made to the penalties of 18 Pa. C.S. !l 4904 relating to unsworn falsification to authorities. MAY 4, 2005 Date R. J. SHADDA Signature , " , " ".,...-. -'{J-- Service Type M Form EN.OO? Worker ID 21600 ~?~ si; 5:' -,':' ~ .,.n ,- , -<... 1 U"\ -', , ~," -... '-;:? ~ ,- 0' . .. . " In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION BOBBIE J. HILL ) Docket Number 03-277 CIVIL Plaintiff ) YS. ) PACSES Case Number 758105280 TERRY E. HILL ) Defendant ) Other State lD Number ORDER OF COURT Legal proceedings have been brought against you alleging you have wilfully disobeyed an Order of Court. 1. If you wish to defend against the claim set forth in the following pages, you may, but are not required to, file in writing with the Court your defenses or objections. 2. You, TERRY E. HILL , Respondent, must appear in person in court on JUNE 27, 2005 COURT ROOM 4 , at 1:30PM, III CUMBERLAND CO COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PA. 17013 IF YOU DO NOT APPEAR IN PERSON, THE COURT MAY ISSUE A ARRANT FOR YOUR ARREST AND YOU MAY BE COMMITTED TO JAIL. 3. If the Court finds that you have wilfully failed to comply with its order you may be ound to be in contempt of court and committed to jail, fined, or both. ervice Type M Form EN.528 Worker lD 21600 . ~...,.\ HILL V. HILL PACSES Case Number: 758105280 YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH THE INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND CO BAR ASSOCIATION 32 S BEDPORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. BY THE COURT: MAY 0 4 2005 ,?-A.4- Date of Order: JUDGE S rvice Type M Page 2 of 2 Form EN-528 Worker lD 21600 "" c~:l C:';'.:l C,n :..;-" --t.: , U'; ~\1 "'-"1' () '" :;"1 ;--tip) t.~ l~i C. -,-I ~~':~ c.,) 0' TERRY E. HILL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 03-277 CIVIL TERM BOBBIE J. HILL, Defendant CIVIL ACTION - LAW IN DIVORCE PETITION OF GARY L. ROTHSCHILD. ESQUIRE TO WITHDRAW APPEARANCE AS COUNSEL FOR PLAINTIFF Gary L. Rothschild, Esquire hereby respectfully petitions this Honorable Court for leave to withdraw his appearance as counsel for Plaintiff and in support thereof avers as follows: 1. Petitioner is Gary L. Rothschild, Esquire. 2. Respondent is Terry E. Hill, an adult individual who currently reside at 125 Oak Flat Road, Newville, P A 17241. 3. Petitioner was retained by Respondent on or about August 31, 2004, to represent Respondent as Plaintiff in a divorce matter. 4. Petitioner has undertaken representation but is unable to continue because Respondent has failed to pay Petitioner's fees as billed in accordance with their Representation Agreement and has not responded to Petitioner's correspondence. 5. Pursuant to the Representation Agreement entered into between the Petitioner and the Respondent, a copy of which is attached hereto as Exhibit "A", Respondent agreed to remit payment within thirty (30) days of receipt of Petitioner's billing. Petitioner reserved the right to terminate the representation if Petitioner's bills went unpaid and satisfactory payment arrangements could not be made. Date: (:,!; Ie s-- &/;&7 Gary . Rothschild, EsqUire Supr. Ct. I.D. No. 62041 2215 Forest Hills Drive, Suite 35 Northwood Office Center Harrisburg, P A 17112 (717) 540-3510 6. Presently, billings have been outstanding for more than thirty (30) days and the current outstanding balance is more than $750.00. 7. Petitioner has notified Respondent of the overdue account and that Petitioner would be withdrawing from this matter if Respondent's account was not brought current. 8. Petitioner has contacted Defendant's Counsel, Jeanne B. Costopoulos, Esquire, to determine if Defendant's counsel will concur in Petitioner's request to be permitted to withdraw as counsel to the Respondent. 9. On June 7, 2005 Defendant's Counsel verbally indicated that she did not oppose Petitioner's request to withdraw as counsel to the Respondent. WHEREFORE, counsel for Plaintiff respectfully requests this Honorable Court to grant the Petition to Withdraw Appearance and allow Gary L. Rothschild, Esquire to withdraw as counsel. Date: Vh/o"..s-- /7Vp CERTIFICATE OF SERVICE ~ AND NOW, this 1;/ day of June 2005, I, Gary 1. Rothschild, Esquire, attorney for Plaintiff, hereby certify that I served a copy of the within Petition to Withdraw Appearance as Counsel for Plaintiff and attached Rule this day by depositing the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Mr. Terry E. Hill 125 Oak Flat Road Newville,PA 17241 Jeanne B. Costopoulos, Esquire 5000 Ritter Road, Suite 102 Mechanicsburg, P A 17055 Gary . Rothschild, Esquire Supr. Ct. LD. No. 62041 2215 Forest Hills Drive, Suite 35 Northwood Office Center Harrisburg,PA 17112 (717) 540-3510 2215 Forest Hills Drive Suite 35 Telephone (717) 540-3510 Northwood Office Center Facsimile (717) 540-3512 Harrisburg, PA 17112 THE LAW OFFICES OF GARY L. ROTHSCIDLD August 30, 2004 Mr. Terry E. Hill C/O Cumberland County Prison 1101 Claremont Road Carlisle, PA 17013 RE: REPRESENTATION AGREEMENT Dear Mr. Hill, It wqs my pleasure to meet with your sister, Deb Neenan, today and discuss your situation. This letter is to serve as confirmation of my representation of you and clarification ofthe general basis upon which fees will be charged with regard to the divorce action which you have filed and related matters. I will bill you for my services at the hourly rate of$170.00. My time shall be charged at six (6) minute intervals, including, but not limited to time for incoming and outgoing telephone calls, negotiations and correspondence. I have requested a retainer in the amount of$ 1,500.00 which Deb paid today and which I have placed in my escrow account. There are certain services for which I charge flat fees, as outlined below. Additional time for other services, such as negotiations, discussing your case, etc. shall be billed hourly. If a Matrimonial Settlement Agreement is needed there will be a minimum fee of $ 500.00. Normally, the fee for drafting and finalizing the Matrimonial Settlement Agreement does not exceed three and one-half (3 Y2) hours. However, if the time needed to draft and finalize the Matrimonial Settlement Agreement exceeds three and one-half (3 Y2) hours the additional time shall be billed on an hourly basis. If a Support Conference is necessary my fee for preparation and attendance at a Support Conference is $ 300.00 plus travel time, at $ 100.00 per hour, if outside of Harrisburg. If your case proceeds to a hearing before a Common Pleas Judge, my fee for preparation and attendance at the Hearing will be at my hourly rate plus travel time, at $ 100.00 per hour if outside of Harrisburg. It is important that in any divorce matter that you maintain a detailed, written diary of events and changes which occur during the case. These can be extremely helpful during my representation of you. Time spent on your case shall include, but not be limited to, telephone conversations, drafting of documents, negotiations, legal research, court time, travel and other work performed on your behalf I shall maintain a detailed record of time spent on your case and forward a summary to you monthly. ;f/J II E><A,'f,d n Mr. Terrv E. Hill -2- AUl!ust 30. 2004 I may require some sums to be prepaid for costs to be incurred such as depositions, filing fees, appraisal fees and expert fees, if necessary. You agree to remit these sums as required and authorize me to advance these sums as I deem necessary. Although it is impossible to predict the course that your case will take I shall keep you fully informed as your case proceeds. I shall return your telephone calls promptly, generally the same day that you call, however, there may be occasions when a slight delay in returning a call may occur due to my preparing for or attending at a hearing for another client. I shall. send you a monthly statement of your account indicated time spent on your case. By ~igning this agrcea~cnl you agree to pay tlie monthly billings within 30 days of receipt and the outstanding balance at the completion of your case. You agree to pay interest on any amounts, which remain unpaid in excess of 30 days at the rate of 12% per annum. You understand that I may withdraw from the case, unless satisfactory payment arrangements can be made. If legal action is necessary to collect fees you agree to pay reasonable attorneys' fees and costs involved in such an action. By signing this agreement you acknowledge that I have made no guarantees as to the disposition of any phase of this matter or matters for which I have been retained. By signing below you also acknowledge receiving a copy of this agreement and that you agree to the terms and conditions set forth herein. If you have any questions regarding this agreement please contact me. If you would like to call me collect I will accept the charges. Otherwise, after I receive back this signed agreement, I shall call you at the prison to discuss your case and how you would like to proceed. If you understand and agree to the terms herein please sign the agreement below and return the original to me in the enclosed, self-addressed envelope. The copy is for your records. Vor; 'C'Y Y'=, , .IJ~ . Gary L Date:~--:3, \ -~~ 'o~,,~\~~~, Mr. erry E. I Enclosure Q ~ s~:; ..."; .<:-., ('i :';::' ,,~ ~.'~~~ ~ ~< ~ =' oJ' '- c:: :;Z': I co -0 ~~ -- ~ ~.... rl1r'" en 13<:? ~~~qi -J:-n (~O ::'-rn '2, db :::.:. N ., <.,) CJ:J , , RECEIVED JUN 092005 p1 TERRY E. HILL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 03-277 CIVIL TERM BOBBIE J. HILL, Defendant : CIVIL ACTION - LAW : IN DIVORCE RULE AND NOW, this I';{< day of 1- 2005, a Rule is hereby issued on Plaintiff to show cause, if any there be, why Plaintiff's counsel, Gary L. Rothschild, Esquire, should not be granted leave to withdraw as counsel. Rule returnable 2-0 days after service of this Order. BY THE COURT: Ai- J. ~-f J t rl ;1t ;0. 'P ~ ~ ......:."1'" .-. ':: l ~t Iv 2 I :8 !A'~ 91 t:nr SOOl ''''-'I ~",-, 'I.' IJ -'Hl::lO AfJV...l)l'tvrLJ.k 'J ~ ~, 38!:J:l0-031I:l T In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION BOBBIE J. HILL ) Docket Number 03 -277 CIVIL Plaintiff ) vs. ) PACSES Case Number 758105280 TERRY E. HILL ) Defendant ) Other State ID Number BENCH WARRANT - DEFENDANT AND NOW, this 28TH DAY OF JUNE, 2005 th,e Sheriff of CUMBERLAND County, or any constable, or police officer, or other law enforcement officer is hereby ordered to take TERRY E. HILL residing at 125 OAK FLAT RD, NEWVILLE, PA. 17241-9467-25 into custody for appearance before this Court. This Bench Warrant is issued because it appears that TERRY E. HILL has failed to appear, after notice, before the Court for a scheduled conference and/or hearing. We command you, the arresting officer, forthwith to conv,~y and deliver the party into the custody of the Court of Common Pleas of CUMBERLAND County, at ONE COURTHOUSE SQUARE, CARLISLE, PA 17013 for a hearing. Nmne: TERRY E. HILL SSN: 235-11-0610 Sex: M DOB: 02/06/61 Age: 44 years Height: 5 ft 09 inches Weight: 170 lbs Alias: Descriotive Information Race: w Eyes: GN Hair: BN Distinguishing features (scars. tattoos. facial hair, etc.): Telephone: (717) 691-0930 Last Known Employer: Service Type M Form EN-048 Worker ID 21005 HILL v. HILL PACSES Case Number: 758105280 Descriptive Information - Continu''lI Places Frequented: You are further commanded that if the Court is unavailablt:, the party may be held in the County Jail until the Court is opened for business, at which time the party shall be promptly conveyed and delivered into the custody of the Court at: ONE COURTHOUSE SQUARE, CARLISLE, PA 17013 for a hearing. The authority in charge of the County Jail shall notify the Sheriffs Office and the Director of the Domestic Relations Section forthwith that the party is being he:id pursuant to the Bench Warrant. Under no circumstances may the party be held in the county jail for more than seventy-two hours prior to hearing. Bail in this matter shall be set as follows: o No bail Stipulations - IX! Bail to be set in the amount of $ 700 . 00 o Bail to be determined by the district justice. Date BY THE ICOURT: ~. A. 4.- J Kevin y. Hess JUDGE June 28, 2005 Served by: Date and Time Served: Type of Service: Warrant Number: Page 2 of2 Fonn EN-048 Worker ID 21005 Service Type M >. c-, a; ..:r -<C (0 1- 0 ill? ::t: ~",,2C) ll- --,~-- a.. l?--F t )C} ro . .0 00: N LUO- -~ %LU ::5 , u-fS --, ~ uc> ",5 <= = (.) .,..... n \"~':';' ";.:1 - In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESI'IC RELATIONS SECTION BOBBIE J. HILL ) Docket Number 03-277 CIVIL Plaintiff ) VS. ) PACSES Case Number 758105280 TERRY E. HILL ) Defendant ) Other State ID Number Request for Bench Warrant and SuPOOrtinl! Affidavit 1. TERRY E. HILL did not appear for a conference andlor hearing on JUNE 27, 2005 which was scheduled by an Order of Court compelling this person's appearance, a copy of which is attached to this application. 2. The party received the Order of Court scheduling the conference and/or hearing in the following manner: Q9 (a) The Order of Court was served upon the party by ordinary mail with the return address of the court thereon; the mail was not returned to the court within fifteen (15) days after mailing; and at a date after the Order of Court was mailed, the United States Postal Service has verified that mail for the party was being delivered at the address to which the court order was mailed. o (b) The party signed a receipt indicating acceptance of the court order. o (c) An employee of the court handed a copy of thl~ court order to the party. The employee's affidavit of service is attached. o (d) A competent adult who is not a party to this action handed a copy of the court order to the party. The adult's affidavit of service is attached. 3. [i] This request for Bench Warrant is made within sixty (60) days following the party's failure to appear for the conference andlor hearing; and [i] I have reviewed the records of the Court and the Domestic Relations Section concerning this case, and attest that the party has not appeared for any domestic relations matter involving the same parties since the date upon which the party failed to appear in violation of the attached Order of Court. Service Type M Ponn EN-046 Worker ID 21005 HILL V. HILL PACSES Case Number: 758105280 4. In my capacity as hearing officer or conference officer, [ request that the attached Bench Warrant be issued against the party named on account of the party's failure to appear for a schedule conference and/or hearing in violation of an Order of Court. 5. I recommend that bail in this matter be set as follows: o No bail G9 Bail to be set in the amount of $ 700.00 o Bail to be determined by the district justice. The records of the Domestic Relations Section show that: IXI the party owes arrearages in the amount of $ 1,406.53 IXI the party has failed to appear for 1 hearings relating to this case. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the pena!t~'es f. 18 Pa. ('/).s. 'l4 relating to unsworn falsification to authorities. .~ . . , 4 j , . ~ - ~r-or cu. Date ticial Tit! Service Type M Page 2 of2 Form EN-046 Worker ID 21005 _. C:; -.l- ts UJ? C?'r, L.J.-'j::. IJ-r., C1C) 6"': tDi-l~ ;;;d\,iJ "-IE ~ n ..::r C0 :I:: 0.- co ('-l E; ~:"';i _.,'~ ~~) ""> t'3 c' c-J ,:J I ~-_... "j () _+ ,_", ("\ .::~\ L; - In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION 13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013 Phone: (717) 240-6225 Fax: (717) 240-6248 JULY 6, 2005 Plaintiff Name: BOBBIE J. HILL Defendant Name: TERRY E. HILL Docket Number: 03-277 CIVIL PACSES Case Number: 758105280 Other State ID Number: Please note: All correspondence must include the PA.CSES Case Number. Affidavit of Personal ServicE: I hereby certify that the above named defendant or his/her authorized ag~nt h~s been + personal~ served with the following ocume (s): i pf'+'~+ t.J/1-..~t/ , l:.Q;~. (\J~. I 0 by: . [~anding a copy to defendant~ /~ Ai 1!;(tfh1!€JL...:;1 [ ] handing a copy to an adult member of the family with whom he/she resides; or to an adult person in charge of such residence; [ ] handing a copy to the defendant's agent in charge of the defendant's place of business. [ ] handing a copy at the residence of the defendant to thl: clerk or manager of the place of lodging at which he/she resides. [ ] handing a copy to who accepted service on behalf of the defendant and certifies by signature he/she is authorized to do so. 'l-b -OS Date Served Service Type M Form EN.534 Worker ID 21400 BOBBIE J. HILL ) Docket Number 03-277 CIVIL Plaintiff ) vs. ) PACSES Case Number 758105280 TERRY E. HILL ) Defendant ) Other State ID Number Acceotance of Service <<2>-(...b5" I accept service of JJr~ R;r d - ;119"./.~ ~t i -4J U4 / 0 I certify that I am authorized to accept service on behalf of defendant. 'l-t -D~ DATE a ~~~ .S\\lIl , , Defendant 0'(, thorized Agent Service Type M Attachment to Form EN.534 Worker ID 21400 (') ~; -01'7": r; \ T ~ , ~:~, ,':,,-' ;?:t U~} '" f~:: .~:' " ~ ~ '- c:. r I -' ::::(' . '$~~ ~ , -0 :;:l': '-P. ~ ::e..,., rnF' ~.o9 :::jQ :.t:...-1 ()~ ;,~~ 9 ~ ~,) co - In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION BOBBIE J. HILL ) Docket Number 03-277 CIVIL Plaintiff ) VS. ) PACSES Case Number 758105280 TERRY E. HILL ) Defendant ) Other State ID Nwnber PETITION FOR MODIFICATION OF AN EXISTING SUPPORT ORDER 1. The petition of TERRY EDWARD HILL respectfully represents that on APRIL 9, 2003 , an Order of Court was entered for the support of BOBBIE JO HILL A true and correct copy of the order is attached to this petition. Service Type M Form OM-50 I Worker ID 21005 HILL V. HILL I'ACSES Case Number: 758105280 2. Petitioner is entitled to 0 increase (i) decrease 'fj;J termination 0 reinstatement o other of this Order because of the following material and substantial change(s) in circumstance: ,"'e. '\ e ~S'O~'\.S, ~ec: o.\)"Se.. S ~~. no..~ ~~ ~~\~ -1'~f.--e.s.'~~~'"~~'\-'~~~~\~"::.c."'c:'b.'3 ~\ ~~,,~~ s.~~ " ~.s<.~.S~S;;:-... ~ \ ~ s .L ""0-..'" " E:::r\'\)\~'~ ~,~ €.~ ~ ~ '\' ~-e.~~'L..~ ~~~~ ~"~<:.-e.. ~,<\~,~"' ~~.. WHEREFORE, Petitioner requests that the Court modify the existing order for support. ~~~~_ ~CL~~~~l-:~~ PetItl Attorney for Petitioner <"L\S-\="0~~-T\\\~ ~.. . .s.~.~-e.~~~~"W~~\..ti'J\ \~~ 1\~~~\s\::'~'\~ ~~ \\\\~ I verify that the statements made in this complaint 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. "t-~\~~ Date Service Type M Page 2 oi2 Form OM-50 I Worker ID 21005 ,~ C) r"-<) C"'C') '''''') ""_YI fS ~ ~ 4-. -\- '" v ~ o -n :,T' fTi71 r-- to_,: ~: i'0 en \J:) BOBBIE J. HILL, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION CIVIL ACTION - SUPeoRT 277 ~2003 C tV, L PAcSES NO. 758105280 TERRY E. HILL, Defendant IN RE: PETITION FOR CONTEMPT ORDER OF COURT AND NOW, this 1st day of August, 2005, on agreement of the parties, hearing herein is continued to the call of the Domestic Relations Office. It appearing that the defendant has paid on account of sums due the amount of $100.00. By the Court, Derek Clepper, Esquire Special Counsel for DRO .J4i Ron Turo, Esquire Assistant Public Defender :bg s~ ;:;~ :..;:; .-;-' m I (.",') (. ) Ltl ., "' 'IJ BOBBIE J. HILL, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE TERRY E. HLL, DefendantlPetitioner NO. 2003 - 277 CIVIL TERM IN DIVORCE P ACSES #758105280 ORDER OF COURT AND NOW, this 24th day of August, 2005, a petition has been filed against you, Bobbie J. Hill, to modify an existing Alimony Pendente Lite Order. You are ordered to appear in person at the Domestic Relations Section, 13 North Hanover Street, Carlisle, Pennsylvania, on September 21. 2005 at 9:00 A.M. for a conference and to remain until dismissed by the Court. If you fail to appear as provided in this Order, an Order of Court may be entered against you. You are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by the Rule 19IO.1l. (4) verification of child care expenses (5) proof of medical coverage which you may have. or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, George E. Hoffer, President Judge Copies mailed 8-24-05 to: Petitioner Respondent Jeanne Costopoulos, Esquire Date of Order: August 24. 2005 J!ha YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OIrr WHERE YOU MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 o s::. c_ Z -:J -, '-' ~..;) ~ :P- c:: '" N .J:"" -0 :r..: o ,1 :i'!,::n n,- -fjrn :;)9 ~~Cl ~::r: :..: 1 C);;;" ..? -- '.en 9. ~':> ~ ~ <.n In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION 13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013 Phone: (717) 240-6225 Fax: (717) 240-6248 Defendant Name: TERRY E. HILL Member ID Number: 7219100741 Please note: All correspondence must include the Member ill Nwnber. ORDER TO VACATE ATTACHMENT OF UNEMPLOYMENT BENEFITS Financial Break Down of Multiple Cases on Attachment Plaintiff Name BOBBIE J. HILL P ACSES Case Number 758105280 Docket Number 03-277 CIVIL Attachment Amount/Freauency $ ~ $ $ ~ $ 355.00 jMONTH ~ / / / ~ / / TOTAL ATTACHMENT AMOUNT: $ 0 . 00 The prior Order of this Court directing the Department of Labor and Industry, Bureau of Unemployment Compensation Benefits and Allowances (BUCBA), to attach $ 0.00 or 50 % per week of the Unemployment Compensation benefits of , Social Security Number 235-11-0610 , TERRY E. HILL Member ID Number 7219100741 is hereby vacated. This Order to Vacate shall be effective upon receipt of the notice of the Order by the Department and shall remain in effect until a further Order of the Court is filed. BY THE COURT Date of Order: SEP :~ ZQ~~, ~.~~ ./ JUDGE Service Type M Form EN.035 Worker ID $IATT Q <:'" '<,-, <;::; '3. c/> I"" --0 ~ q., ~~ :?,q Dq, '?-<) -0 ';?- C::f', ~ <2: ~ .~ 4? ~ ... -"j'"\\:' d}\.: .~~<< ' (,/,~ . ?::.c, -~\~-:' ------- In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION TERRY E. HILL, PlalntlfflRespondent VS. ) Docket Number 03 -277 CIVIL ) ) PACSES Case Number 758105280 ) ) Other State ID Number BOBBIE J. Hll..L, DefendantlPetitioner ORDER AND NOW, to wit. on this 19TH DAY OF OCTOBER, 2005 IT IS HEREBY ORDERED that the support order in this case be 0 Vacated or o Suspended or (i) Terminated without prejudice or 0 Terminated and Vacated, effective APRIL 15, 2005 . due to: THE MARITAL HOME GOING INTO FORECLOSURE AND THE MORTGAGE NOT BEING PAID SINCE APRIL 15, 2005, WIFE LEAVING THE MARITAL HOME ON OR ABOUT JUNE 15, 2005 AND HUSBAND BEING LAID OFF FOR ALMOST A YEAR. THERE IS NO BALANCE DUE WIFE. BY THE COURT: 7" ~ 4.. JUDGE Service Type M Form OE-504 Worker ID 21005 /) ~n ,~,,:;; ,- CJ ." BOBBIE J. HILL, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - DIVORCE TERRY E. HILL, Defendant : NO. CIVIL TERM 03-277 : PACSES NO. 758105280 APPF,AI, OF ORfiKR TFRMIN A TINe; A I.lMONV PKNfiRNTF I.lTR AND NOW, comes the Plaintiff, BOBBIE J. HILL, by and through her attorney, Jeanne B. Costopoulos, Esquire, and respectfully submits the following de novo appeal: 1. Defendant requested a modification conference following which an order dated October 19, 2005 was entered terminating the prior Order awarding alimony pendente lite to Plaintiff. This order is attached as Exhibit A. 2. Plaintiff hereby appeals the above-referenced order for the following reasons: Plaintiffleft the marital residence because it was foreclosed upon after Defendant failed to make timely support payment, the original APL order was not contingent upon Plaintiff making the mortgage payment, husband was not laid off but instead lost his job as result of being incarcerated, the arrears should not have been canceled. WHEREFORE, Defendant respectfully appeals the Order dated October 19, 2005 terminating APL and canceling arrears. DATE: II) /;/os BY: Respectfully submitted, ...~ - ---- ---- - Jeanne B. Costopoulos, Esquire ATTORNEY FORPLAINTITF 3803 Gettysburg Road Camp Hill, P A 17011 Phone: (717) 920-2500 P A Supreme Ct. ID No. 68735 BOBBIE J. HILL, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - DIVORCE TERRY E. HILL, Defendant : NO. CIVIL TERM 03-277 : PACSES NO. 758105280 CF.RTTFWATF. OF SF.RVTCF I, Jeanne B. Costopoulos, E,,!uire, hereby certifY that a true and correct copy of the foregoing document was served upon the following the counsel of record via postage pre-paid first class mail: Gary L. Rothschild, Esquire 2215 Forest Hills Drive, Suite 35 Northwood Office Center Harrisburg, PAl 711 2 BY: ~--- , Jeanne B. Costopoulos, Esquire ATTORNEY FOR PLAINTIFF 3803 Gettysburg Road Camp Hill, PA 1701 I Phone: (717) 920-2500 P A Supreme Ct. ID No. 68735 DATE: /tJj;r! U5 E.)(\-\\B\\ A ------- In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION TERRY E. HILL, PlaintifflRespondent VS. ) Docket Number 03 -277 CIVIL ) ) PACSES Case Number 758105280 ) ) Other State 10 Number BOBBIE J. HILL, Defendant/Petitioner ORDER AND NOW, to wit, on this 19TH DAY OF OCTOBER, 2005 IT IS HEREBY ORDERED that the support order in this case be 0 Vacated or o Suspended or (i)Terminated without prejudice or 0 Terminated and Vacated, effective APRIL 15, 2005 ,due to: THE MARITAL HOME GOING INTO FORECLOSURE AND THE MORTGAGE NOT BEING PAID SINCE APRIL 15, 2005, WIFE LEAVING THE MARITAL HOME ON OR ABOUT JUNE 15, 2005 AND HUSBAND BEING LAID OFF FOR ALMOST A YEAR. THERE IS NO BALANCE DUE WIFE. BY THE COURT: 7'~~ ,I JUDGE Service Type M Form OE-504 Worker ID 21005 G' 1- t' >;'-. 0'0 (<:, -- ,..< -" r-' ::.~ ....---'., r:: CJ 1~: >J - In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION BOBBIE J. HILL ) Docket Number 03-277 CIVIL Plaintiff ) vs. ) PACSES Case Number 758105280 TERRY E. HILL ) Defendant ) Other State ID Number ORDER OF COURT You, BOBBIE J. HILL plaintiff/defendant of are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the DECEMBER 13, 2005 at 9 : OOAM for a hearing. You are further required to bring to the hearing: I. a true copy of your most recent Federal Income Tax Return, including W -2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. verification of child care expenses, and 4. proof of medical coverage which you may have, or may have available to you 5. information relating to professional licenses 6. other: Service Type M Form eM-509 Worker ID 21302 C) c- ---;; ....., ..~ C;~j en o "n -< T fiip --nfT~ ?,,~S:; 'iC1 ,__-I "S:cL: --7l,,1 jrn ~S ~~ - C) -,,-- o ---::J C) ill In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION BOBBIE J. HILL ) Docket Number 03-277 CIVIL Plaintiff ) vs. ) PACSES Case Number 758105280 TERRY E. HILL ) Defendant ) Other State ID Number ORDER OF COURT You, TERRY E. HILL plaintiff/defendant of 125 OAK FLAT RD, NEWVILLE, PA. 17241-9467-25 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the DECEMBER 13, 2005 at 9: OOAM for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. verification of child care expenses, and 4. proof of medical coverage which you may have, or may have available to you S. information relating to professional licenses 6. other: Service Type M Form CM-S09 Worker ID 21302 HILL v. HILL PACSES Case Number: 758105280 If you fail to appear for the conferencelhearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: ~ 7'~'~ , JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELlGmLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Service Type M Page 2 of2 Form CM-509 Worker lD 213 02 C) "'> 0 c.:::> C C':::J -n <.n ~ :? (:~. f'il -,., "0,_- 1= ~',"'" fTi (-~ 0 a , ""1 ~ 1 - ~ -'i ; Ti ., ~--;J t:J ~.;:) '.D "< TERRY E. HILL, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No: 03-277 CIVIL TERM BOBBIE J. HILL, Defendant : CIVIL ACTION - LAW : IN DIVORCE PR A F.ClPF, TO WTTHDR A W COIJNT I OF PFTlTlON FOR RF.1.A TF.D C1.A IMS AND COIJNT 11 OF COIJNTF,RC1.AIM IN mVORCF. TO THE PROTHONOTARY: Kindly mark both Count I of the Petition for Related Claims filed February 3, 2003, and Count II of the Counterclaim in Divorce filed April 27, 2004, withdrawn and dismissed. By: ~. ".--..... li:/;,&/ZiJz!5 Dated: eanne B. Costopoulos, Esquire Attorney for Defendant 3803 Gettysburg Road Camp Hill, PA 17011 Telephone: (717) 920-2500 PA S.Ct. ID No. 68735 -" ....., = = en Cl M <J N N (:J -n ...., :I:_ rn"':'.j -or:;:; :!'~O _:~ {l~ ?5~D ~'::$.:) (),.1 s;:;! ;n -< ....~"'" 5: L.J ..a:.:'~ ..------ TERRY E. HILL, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No: 03-277 CIVIL TERM BOBBIE J. HILL, Defendant : CIVIL ACTION - LAW : IN DIVORCE A FFTnA VTT OF SF,RVTCF TO THE PROTHONOTARY: On or about May IO, 2004, I, Teny E. Hill, Plaintiff the above case, accepted service of the Counterclaim in Divorce that was filed on April 27, 2004 at the above term and docket number. Date:\';:::r\ \I:l~~ ~>~!'~'~. Teny E. Hil o ~.;; i. ,...., C",.::;I c, <Oft c> ,-n c-:> ,,, r-.> :P" :3:,: ~ ~-n frlF -n \1', :,by ~>?i -;;-() t~fn c.:,::; "J:l '-< c..) -""" TERRY E. HILL, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No: 03-277 CIVIL TERM BOBBIE 1. HILL, Defendant : CIVIL ACTION - LAW : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE AND W ATVRR OF COTfNSF,LTNG I. A Counterclaim in Divorce under Section 3301(c) of the Divorce Code was filed on April 27, 2004. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date ofthe filing and service of the Counterclaim. 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 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. ---- Date: \~\~=% Signatur~~ ~ ~. Terry~ r-> c...^? ~ cP q, f' . <' ~ q, ~-;J;l I, Hire.. -:s;q (~} ~\ ')~) -"'f,-. :-~\ :-~.. ':0 :..< ~~ ..' - - .' (,,,) ~. - TERRY E. HILL, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No: 03-277 CIVIL TERM BOBBIE J. HILL, Defendant : CIVIL ACTION - LAW : IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT UNDER SECTION 3301 (c) OF THE DIVORCE CODE A NO W A TVRR OF COTJNSF,J ,TNG I. A Counterclaim in Divorce under Section 3301(c) ofth~ Divorce Code was filed on April 27, 2004. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Counterclaim. 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 verity 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. 94904 relating to unsworn falsification to authorities. Date: ~- SignanrreYEdl() ill XIJ1/ Bobbie J. Hill n c- ...., c.:::l t";:'::;' c...l'l c::J fTl " ~.) N ~ ...., ::r:::!J n1r=- -rim ~~~ ~i c ,,):::'J :: \~n ,:;.' "~-1 ~J :< ;:''''1> ::t: (..) .s;. TERRY E. HILL, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No: 03-277 CIVIL TERM BOBBIE J. HILL, Defendant CIVIL ACTION - LAW : IN DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE lJNDFR SF.CHON :HOl (I:) OF THF DTVORCF CODF I. 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 ifI 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. 4. I verifY that the statements 'llade in this Affidavit are trut: and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Dated: \f?; ,- \\;;:,-~ ,~ '-~ ~ Signature:\~\.,~\\ \\~ _ ~ Terry E. . () (~: ....' -= (::.::;J <;;..J'~ Cl p-i e, N N ~~ -'"," o -~, ::;:l ...__-r1 f'l,'r=: --om ..',0 C)(L ::;. >::,' ..~~~ ,;;'" .~ c..J ",- TERRY E. HILL, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No: 03-277 CIVIL TERM BOBBIE J. HILL, Defendant : CIVIL ACTION - LAW : IN DIVORCE DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE TTNOFR SRCTlON :n01(r) OF THR DTVORCF COOR I. 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! 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. 4. 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: 1;)/)1 jDS- I I ~7 1 Signature: · Bobbie 1. Hill (") r <;::; = 0." <:::1 on o i') N :;:''" - ...;.-.... 9. ~C -:S\t? :'J i.. .-::~: ~-' )'} -~:;} '_-~;,.C) t:s(i\ .'4 ~ - - (J - TERRYE. HILL, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No: 03-277 CIVIL TERM BOBBIE 1. HILL, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAFCIPR TO TRANSMIT RRCORO To the Prothonotary: Please transmit the record, together with the following information, to the Court for entry of a divorce decree: I. Ground for Divorce: Irretrievable breakdown under 23301(c) of the Divorce Code. 2. Date and Manner of service of the Counterclaim in Divorce: Personally accepted by Defendant on May 10,2004. See attached Affidavit of Service. 3. Date of execution of the Affidavit of Consent required by 2330I(c) of the Divorce Code: by the Plaintiff: 2/16/2005; by the Defendant: 12/13/2005. 4. Related claims pending: None. Date Plaintiff's Waiver of Notice in 23301(c) divorce was filed with the prothonotary: filed simultaneously with this Praecipe to Transmit Record. Date Defendant's Waiver of Notice in 23301(c) divorce was filed with the prothonotary: filed simultaneously with this Praecipe to Transmit Record. By: ~ --- eanne B. Costopou1os, Esquire --- Attorney for Defendant 3803 Gettysburg Road Camp Hill, P A 17011 Telephone: (717) 920-2500 PA S.Ct.lD No. 68735 Dated: I '1 Iz z h.<td5 r;l. ~ c:::> rn " "" N Q. -' -r::--c> fne -nr.!3. ~i) '1' ::?\() -:, -~I" -~>'::.. :Q '.~~O ;(-rO .J. _..-'\ 'v" ?:l. ~:~ ......~ - - c.i'" <JI ... TERRY E. HILL, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : No: 03-277 CIVIL TERM BOBBIE J, HILL, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAF.ClPF. TO TRANSMIT RF,CORO To the Prothonotary: Please transmit the record, together with the following information, to the Court for entry of a divorce decree: I, Ground for Divorce: Irretrievable breakdown under 2330I(c) of the Divorce Code, 2, Date and Manner of service of the Counterclaim in Divorce: Personally accepted by Defendant on May 10,2004, See attached Affidavit of Service, 3, Date of execution of the Affidavit of Consent required by 23301(c) of the Divorce Code: by the Plaintiff: 2/16/2005; by the Defendant: 12/13/2005, 4, Related claims pending: None, Date Plaintiff's Waiver of Notice in 2330I(c) divorce was filed with the prothonotary: filed simultaneously with this Praecipe to Transmit Record, Date Defendant's Waiver of Notice in 23301(c) divorce was filed with the prothonotary: filed simultaneously with this Praecipe to Transmit Record, Dated: I '1 Iz z h.<td5 By: ~POUIOS'~;; -- Attorney for Defendant 3803 Gettysburg Road Camp Hill, PA 17011 Telephone: (717) 920-2500 P A S,Ct. lD No, 68735 o c ...., =' ,=" cJ' o ,;-:' " N N :;:;'.- -- ~ ..... -:J:-n rI'F -nill ~;)'( '~L' -2~1, .~;~~ . -, ~::'1 ".,. ~:o :< t~' Ul TERRY E, HILL, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : No: 03-277 CIVIL TERM BOBBIE 1. HILL, Defendant : CIVIL ACTION - LAW : IN DIVORCE A FFlOA VIT OF SRRVlCF, TO THE PROTHONOTARY: On or about May 10,2004, I, Terry E, Hill, Plaintiff the above case, accepted service of the Counterclaim in Divorce that was filed on April 27, 2004 at the above term and docket number. Date:\;;r\ \,,~~ '0\'~'0 \i0~~. Terry E, Hi! o c r-' = ~ o \">'"1 n ,,,, N {:.1 Q. :1"", ',,1 ?': -0\1-\ -:.() '1 ,...... .~., -:-<~t---' ?~~~ :",~:; ?'n {.::::, ~~ - ~ -- - - ,.,.} :c --------- TERRY E, HILL, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : No: 03-277 CIVIL TERM BOBBIE 1. HILL, Defendant : CIVIL ACTION - LAW : IN DIVORCE PLAINTIFF'S AFFIDA VrT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE A NO W A IVRR OF COIJNSFJ.lN(; 1. A Counterclaim in Divorce under Section 3301(c) of the Divorce Code was filed on April 27, 2004, 2, The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Counterclaim, 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 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, 24904 relating to unsworn falsification to authorities, - Date: \~\'\s,~ Signatur~~~~~ Terry E, ' ~-, C.-:::l = CO' CJ .., r> N N o ., :j=!~ nl-w ,. ->:1m ~;:~\} 7:, ( i 'r~r, ::S~ ;;;~ :.0 -< "'" -;...~ C,,) TERRY E, HILL, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : No: 03-277 CIVIL TERM BOBBIE J, HILL, Defendant CIVIL ACTION - LAW : IN DIVORCE DEFENDANT'S AFFIDA VlT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE A NO W A IVRR OF COIJNSRI.INC: I, A Counterclaim in Divorce under Section 3301(c) of the Divorce Code was filed on April 27, 2004, 2, The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Counterclaim, 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 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, 24904 relating to unsworn falsification to authorities, Date: ~5 Signature~() ill fIJ/ Bobbie J. Hill o (".--: .-' c:.? CO ,_n o ... ("") ~.) N f" o .-n _-1 ::r:--r) rn F": fI'\ :'f;o '~)(1, -;,~" :ct:: '-: _:t"\ ~:::~rA C?, 2: ~ (..::> ~~ TERRY E. HILL, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : No: 03-277 CIVIL TERM BOBBIE J, HILL, Defendant : CIVIL ACTION - LAW : IN DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE lJNORR SF.CTTON llOt~~) OF THF. OIVORCE COOF, I, 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 , 4, I verifY that the statementS'TIade in this Affidavit are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa,C.S, 24904 relating to unsworn falsification to authorities, Dated: \0~- \~)-~ "-- ~~~ Signature:\,""\~,~l\. 'II. .~ Terry E, ' ...., ..::;;~ {:::.;;; I;J'1 o ", :J=l." [11- -OM -;)CJ .,-.., i ::i(,;? ::j~} f' -< o PI ("":J N N -'.,~ ::;:::: U J;.- TERRY E, HILL, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : No: 03-277 CIVIL TERM BOBBIE J, HILL, Defendant CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE IJNOF,R SF-CTlON :nOl (I') OF THF- mVORCF COOR I. I consent to the entry of a final decree of divorce without notice. 2, I understand that I may lost' rights concerning alimony, division of property, lawyer's fees, or expenses if! 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, 4, 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, 24904 relating to unsworn falsification to authorities, Dated: I'd..} J 1 )DS- I I Signature:y&da~ I Ilil Bobbie J, Hill ."..,-- (') cn ",., C:) C;) .;.n o PI " "-, N o -0 :j=!~ !"Ilp -a!Q :''''1' ~,~ ~:.l ~-; :;: "~f{, ::-.g '~- c.) .J-- if. ;f;f;f;fCf.;f.:+;i;;f:f.;f.;liif. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . AND i;if.:f.i;;f.;f.if.if. if.:f.if.Cf.;f.if.:f.if.if.:f.;f:f.;f.if.if.if.:+;if.:f.if.:f.if.:f.i;Cf.i;"'if.if.i;:f.if.;fif.;fif.:f.if.Cf.:+;:f.if.;fif.if.:f.;fif.if.if.if.if.~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~ ~ ;fif.~if. if.:f.if. :f.~if.~ ;fif. if.;t;if.if.;t;if.:f.~+';fif.~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA, TERRY E. HILL, Plaintiff NO. 03-277 CIVIL TERM VERSUS BOBBIE J. HILL, Defendant DECREE IN DIVORCE NO;;\)~ 2-1 ,..- 7.4b IT IS ORDERED AND DECREED THAT TERRY E. , PLAINTIFF, HILL AND BOBBIE J. , DEFENDANT, HILL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . :+',.,;f:;fif.;f ARE DIVORCED FROM THE BONDS OF MATRIMONY, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None. ;cJ ~L ATTC,T, ~ ~ ~ P;;;'T"ONOTA"T ... "''f if.;f'f;f if. if. if. if. ~ ~if. if. if. if. J, . ?7"Ts)t-O'(1 !.tt-tI ~ T:'~7~1A.I '""3?,ltOCY S>-Jr-nodoj-SQU ' (' Irttl of IJ3T~W 1"'\,:.Ic') J}'3'lcrr-<J3u ~Q/;,// .. ". ,.