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HomeMy WebLinkAbout98-00680 t~ \1 :~ .. ~ ~ \l, ~' . ,:"{ I ....;'. ~,'. ~.. I,,'" .:," ( ii f \. l~ - '. ~ , " CJ " t:;) C.>o -J I u.. ~ ~ , I , , 3, ~ ;/ Furthcr, the partics lIgrce 10 continue living scparulcly and apllrl from thc othcr at any place or placcs that he or she mllY selcct as they hllvc hcrctofore bccn doing. Neithcr party shllll molest, harass, annoy, injure, thrcatcn or intcrferc wilh thc other party in any matter whatsocvcr. Each party !nay carry on and cngagc in any cmployment, profession, business or othcr activity as hc or she may dcem advisable for his or hcr sole usc and bcnefit. Neither party shall intcrfcre with the uses, owncrship, enjoymcnt or disposition of any property now owncd and not spceified hcrein or propcrty hereafter acquircd by thc other, 4, The consideration for this contract and lIgrcement is the mutual bencfitto be obtained by both of the partics hcreto and the covenants and agrecmcnts of caeh of the parties to the other. The adcquacy of the consideration for all agrcements herein containcd is stipulatcd, confessed, and admitted by the partics, and the parties intend to be legally bound hereby, Each party to the Agreement acknowledges and dcclares that he or she, rcspectively: (I) is reprcscnted by counsel of his or her own choosing; (2) is fully and completely informed of the faets relating to the subjcct mattcr of this Agreemcnt and of the rights and liabilities of the parties; (3) cnters into this Agrcement voluntarily aftcr receiving the advice of counsel; (4) has given careful and mature thought to the making of this Agreement; (5) has carefully read each provision of this Agreement; and (6) fully and completcly understands each provision of this Agrcement, both as to the subjcct matter and legal effect. This Agrcement shall becomc cffectivc immediately as of the date of execution, 2 5. It is the purpose and intcnt of this Agrccmcnt to settle forevcr and complclcly the intercst and obligations of the parties in all propcrty thatthcy own scparately, and all propcrty that would qualify as marital propcrty under the Pennsylvania Divorce Codc, Title 23, Scction 401 (e), and that is referrcd to in this Agrcement as "Marital Propcrty", as betwccn thcmselves, thcir hcirs lInd assigns, The parties havc attempted to dividc their Marital Property in a manner that confonns to a just and fair standard, with due regard to thc rights of caeh Party, The division of existing Marital Property is not intendcd by the partics to constitutc in any way a sale or exchange of assets, and the division is being cffeetcd without thc introduction of outside funds or othcr property not constituting a part of thc marital cstate. It is the furthcr purpose of this Agrcementto scttle forcver and completely any obligation under the Pennsylvania Divorce Code relating to spousal support or alimony, 6, Eaeh party represcnts and warrants that hc or she has made a full and fair disclosure to the other of all of his or her property interests of any naturc, including any mortgage, pledge, Iicn, eharge, security intercst, encumbrance, or rcstriction to which any propcrty is subjcet. Each party further reprcsents that he or she has made a full and fair disclosure of all debts and obligations of any nature for which he or she is currently liable or may become liable, Each further rcprescnts and warrants that he or she has not made any gifts or transfers for inadcquate considcration of Marital Property without the prior conscnt of the other. Each Party acknowledges that, to the extcnt desircd, hc or she has had acccss to all joint and separate State and Federal Tax Returns filcd by or on bchalf of cithcr or hoth PlIrtics during marriage, 3 7, REAL ESTATE: The parties agrce that WIFE will convcy her intcrcst in the marital property locatcd at 400 Petcrsburg Road, Cumbcrland County, Carlisle, Pcnnsylvania 17013. HUSBAND agrces to refinance the mortgage into his own name and to pay WIFE the sum of Eighty Five Thousand lInd no/IOO ($85,000,00) Dollars. Upon payment of the sum of Eighty Five Thousand and no/IOO ($85,000,00) Dollllrs WIFE lInd HUSBAND ah'l"ce to execute the dccd as well as the documents nccessary to complete the divorcc . 8. SUPPORT: HUSBAND will not provide child support or spousal support. The existing Order for alimony pendentc lite will cnd upon the cntry of the final Divorce Decree or January 15, 2000, whichever first occurs provided that WIFE has received that payment set forth in paragraph seven (7) of the Agrcement. If WIFE has not yet reccived said payment, the alimony will continue until she receives it. 9, PERSONAL PROPERTY: The parties agree that the personal property shall be dividcd as follows: HUSBAND shall receive the following items: a, The personal propcrty in his possession; b. His bank accounts; c, Any Life Insurance Policy; d, His IRA retirement account; and e, His 40 I (k) savings plan and pension from PPG Industries, Ine, 4 WIFE shall rcceive the following itcms: a, The pcrsonlll property in hcr current possession; b, Hcr bank accounts; c, The term life insurance policy upon the life ofthc WIFE; d, Her retirement account; and e, Her401(k) savings plan and pension from Giant Foods Storcs, Inc, The WIFE hereby waives all right and title which she may have in lIny personul propcrty of the HUSBAND. HUSBAND likcwise waives any interest which he hils in the pcrsllnul property of the WIFE, Henceforth, each of the parties shall own, have and cnjoy indcpcndenlly of any claim or right of the other party, all items of personal property of cvcry kind, nnlure lInd description and wherever situated, which arc then owncd or hcld by or which I11UY hcreuller belong to the HUSBAND or WIFE with full power to the HUSBAND or the WillE tll dispose: of same as fully and effcctually, in all respccts and for all purposes liS if he or shc wcre unmarried, Each party agrees that neither will incur obligations, liens or liabilitics onuccount of the other and that from the date of this Agreement, neithcr party shall contruet or incur ohligulions, liens or any liability whatsoever on account of the other, 10, AUTOMOBILES: a, WIFE agrecs to waive any and all intcrcst which she 1n1lY have inIlUSHANIl's motor vehicle, b. HUSBAND agrces to waive any and all intcrcst which he IIlUY huve in WIFE's automobile, 5 II. MARITAL DEBTS & BANKRUPTCY: Each party will be rcsponsible for their own dcbt incurrcd after the date of separation, HUSBAND will be solcly responsible tor all outstanding stllte, 10cllI and ledcral taxes and agrees to hold WIFE hannless and indemnifics after the date ofscparation, HUSBAND will bc solcly rcsponsiblc for all outstanding state, local and fcdcral taxes and agrees to hold WIFE hannless and indemnifics hcr for any claims regarding the outstanding income taxes, It is hercby understood and agrecd by and between the partics that their obligations pursuant to this agrcement shall not be affected by allY bankruptcy proeecding and shall not be dcemed to constitute or be a dischargeable debt of a bankruptcy. Both parties warrant that he/she has not herctotore institutcd any procceding pursuant to the bankruptcy laws nor are there any such proeccdings pending with respcet to himlher which have becn, initiatcd by others, 12, INSURANCE AND EMPLOYEE BENEFITS: Thc parties al,'I'ee that any life insurance policies exccpt as otherwise statcd herein on the life of HUSBAND or any other employce bencfits, including but not limited to rctirement, profit sharing or medical benefits of either party, shall be his own, WIFE waives all right, title and claim to HUSBAND's employee benefits. HUSBAND al,'I'ees to maintain the children on his employee health coverage after the entry of a Divorce Dccree. 13, BENEFITS AND BANK ACCOUNTS: WIFE agrees to waive all right, title and intcrest which she may have in the savings or checking or any other bank accounts of the HUSBAND. The HUSBAND al,'I'ecs to waive all interest whieh he has in the bank accounts of the WIFE. 6 14. DIVORCE: The Pllrtics both agrcc to cooperate with cach othcr in obtaining a final divorce of the marriage, It is agrccd that the partics will cxecute and file the consents ncccssary to obtain the divorce. Any party who fails to coopcrate with obtuining the Divorce shall pay all the costs and legal fees of the party who is sceking the divorce. Upon the completion of the payment to WIFE of the sum of Eighty Five Thousand and no/IOO ($85,000.00) Dollars, she agrces to sign and file the documcnts rcquircd to complete the divorce on the same day. 15, BREACH AND COUNSEL FEES AFTER DIVORCE: Thc parties ab'1'ee with respect to counsel fees ineurrcd after the divorce, as tallows: (a) In the event that future legal procccdings of any nature may be necessary for the interpretation or enforccmcnt of this Agrccment or any valid modifications hercof, the prevailing party shall be entitled to rcasonable counsel fces ineurred, (b) Reasonable counsel fecs hcreunder shall be defincd as reasonable hours cxpended at the thcn hourly rate of counsel for the prevailing party, (c) Such counsel fces shall extcnd to any indcpendent proceedings necessary to collect counsel fecs or to enforce any other judb'll1ent or dccree in connection with this Agreement. (d) Such counsel fees shall be payable as alimony so as to cOllstitute an exception to discharge in bankruptcy but shall not be deductible by the payor or taxable to the payee for income tax purposes, 7 16. INCOME TAX EXEMPTION: The Pllrties IIgree thllt WIFE will be entitled IOllse Christopher Rhine liS lIn incolllc lUX exclllPtion filr 1999 lInd lhcreatler. 17, ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at thc rcquest of the othcr, cxccute, acknowledge and deli vcr to the other purty any and 1111 furthcr instruments that may be rellsonllbly rcquircd to give filII force and cfTeetto the provisions of this A~,'rccmcnt. 18. VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effcct have been fully explained to the parties by their rcspcctive counsel, and eaeh party acknowledgcs that the Agreement is fair and cquitable, and that it is being entered into voluntarily, and that it is not the result of any durcss or undue influence. The provisions of this A!,'I'eement are fully understood by both parties and each pllrty acknowledges that the A!,>reement is fair and equitable, that it is being cntcred into voluntarily, and that it is not the result of any duress or undue influence. 19. ENTIRE AGREEMENT: This Agreement contains the entire understanding of the parties and there are no representations, warrantics, covcnants or undertakings other than those expressly sct forth herein, 8 ..... 20, APPLICABLE LAW: This Agrccl11cnl shull hc construcd undcr thc Luws of the Commonwealth of Pcnnsylvunia, 21. PRIOR AGREEMENTS: It is understood and lIgrccd that any and all property settlcmcnt agrecments which mayor havc bcen exccuted prior to the date and time of this Agreement are null and void and of no effcct. 22, VACATION OF INJUNCTION: The partics agree that the Order of Court dated February 23, 1998, which enjoins the HUSBAND from withdrawal from his employee benefit accounts at PPG, Industries, Inc., will bc immediately vacated. WIFE agrees to sign a Stipulation which vacatcs said Order, a copy of which is allaehcd hereto and marked as Exhibit "A." 23. WAIVER OF CLAIMS AGAINST EST A TES: Exccpt as herein otherwise provided, each party may dispose of his or her propcrty in any way, and cach party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the present or future laws of any jurisdiction, to share in the propcrty or the estate of the other as a result of the marital rclationship, including without limitation, dower, curtesy, statutory allowanee, widow's allowance, right to take in intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and cach will, at the request of the other, execute, acknowlcdge and deliver any and all instrumcnts which may be neccssary or advisable to carry into cffcct this mutual waiver and relinquishmcnt of all such intercsts, rights and claims, 9 COMMONWEAI,TII OF PENNSYLVANIA ss: COUNTY OF CUMBERL.AND PERSONAL.LY APPEARED BEFORE ME, this Ilnd.day of ~, /111 , a Notary Public, in nnd Ihr the Conunonwclllth of Pcnnsylvania and County of Cumberland, CATHY L.. RHINE, known to me (or satisfactorily provcn) to be the person whose name is subseribcd to the within Marriage Settlcmcnt Agrcement, and aeknowlcdges that she exccuted the same for the purposes thcrein contain cd. IN WITNESS WHEREOF, I have hcreunto set my hand and official seal. COMMONWEAL. TH OF PENNSYL. VANIA ~7~.w&C I Notarial Seal C Connie J, Trill, NOlary Public i Carlisle, Cumberland Counly : SS: ' ; \'1 Commission Expires Oct. 5, 2000 . ._.~--..._- --~-_.' COUNTY OF CUMBERL.AND PERSONAL.L. Y APPEARED BEFORE ME, this /4'11, day of pecein 6 VL . J 99CJ , a Notary Public, in and for the Commonwcalth of Pennsylvania and County of Cumberland, JONATHAN C. RHINE, known to me (or satisfactorily proven) to be the person whose name is subseribcd to the within Marriage Settlement Ab'TeCment , and aeknowledges that he exccuted the same for the purposcs thcrein containcd. IN WITNESS WHEREOF, I have hercunto set my hand and official seal. -J1r&f)o Y. 'iZMi.. Notanal Seal Martha L, Noel, Nolaly Public Canlsle Bcro, Cumberlai1d Col.rrtv My Commission Expires Sept, 18, 2llo3 Member, Pllnnsylvanla Assoctallan 01 Nolanes II ,\ EXHIBIT "A" . /' n c:> 0 c:: (;~" :;:'~ .,-; ;:R ii, ,:: ::'.1 ~;~) -- n~, ;~7 sl'_ t~"I-. N ...... 'I -.: :.:: ..;.~ (:] c.: f.~J ::.~ ~'.11.~1 "1::l-. \:-'U -..... .. ~- ;SO ~? ;,,~ ...~, c; ('.jfl1 2'..: "l :,:-t =<! :6 ,"-,) ~, '/'" (") a f) C C:J 'f! " - , \'i~~ .~,,,. :..;J nlp", ' - .,' "r' ;::":_1} "- ,.01_..1 " :~~' 1',) +-'1';") VI .. " .r..J -<:::: ~~~~ r:::.:c.t "J ,- :..:-.,.! ~=C) :1: ~,-~C"~ f::O r::l ~'c Orll ~: N ::;.J =<l ::1i -:. " . -'n (') 1;;; "U ~... n:Jf1? ~:J_i ene;:, ~... !;:(:i' '''' ~"'~; !f;Ci c:- 9 , <::> r=) o ,', :"~I}J ~ ;~. .1'1 .:~"O -.J.t ,-JU .,' ., r:5;~: -:-l) c.i I'f1 ;h! ~ -..; '- ~..., ~~.. ...... N - =--=~ -. ;s; i'\) '- CATHY L. RHINE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMIlERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION. LAW v. , ; NO, 98-I.c~O CIVIL TERM JONATHAN C. RHINE, Defendant : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defcnd against thc claims sct forth in the following pagcs, you must take prompt action. You are warncd that if you fail to do so, the casc may proceed without you, and a decrcc of divorcc or annulmcnt may be entered against you by the Court. Ajudgmcnt may also bc cntcrcd against you for any other claim or reliefrcqucsted in these papcrs by thc Plaintiff. You may lose moncy or property or othcr rights important to you, including custody or visitation of your children, Whcn the ground for the divorce is indignitics or irretrievable brcakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at CtJMBERI.AND COUNTY COURTHOUSE. CARLISLE. PENNSYLVANIA 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avcnue Carlislc, Pennsylvania 17013 Telephonc: 717-249-3166 WAYNE F. SHADE Atlomey II law $3 West Pomfret Street Carlisle. Pennsylvania 17013 lC~r~ Wayne . Shade Attorney for Plaintiff WAYNEF,SIIADE Attorney .tlaw 53 West Pomrrct Street Carlisle, PCMsylvania 17013 4. Plaintiff and Dcfcndant werc lawfully joined in marriagc on March 29, 1974, in Pcrry County, Pcnnsylvania. 5. Thc partics havc bccn living separate and apart sincc Dccember 2, 1997. 6. Plaintiff avers as thc grounds on which this action is bascd that Defendant has offered such indignities to the person of the Plaintiff, the innoccnt and injured spousc, as to render thc condition of Plaintiff intolerable and the life of Plaintiff burdensome. In the alternative, Plaintiff avers as the grounds on which this action is based that the marriage of the parties is irrctrievably broken. 7. There have been no prior actions for divorce or annulmcnt of this marriage in Pennsylvania or in any other jurisdiction. 8. This Action in Divorce is not collusivc. 9. Both parties to this Action in Divorce are Icgally capable of managing their own concerns. -2- WHEREFORE, PlllintifTdemlll1dsjudgment equitllbly distributing llllmarital property owned by the pllrties and such further relief liS the Court may deem equitable llnd just. COUNT III ALIMONY AND ALIMONY PENDENTE LITE 16, The averments of Paragraphs I through 13 inclusive above are incorporated herein by reference as though fully sct forth. WHEREFORE, Plaintiff demands judgment compelling Defendant to pay to Plaintiff alimony and alimony pcndente lite. COUNT IV COUNSEL FEES, EXPENSES AND COSTS 17. The averments of Paragraphs I through 13 inc1o.1sive above are incorporated herein by reference as though fully sct forth. WHEREFORE, Plaintiff demands judgment compelling Defendant to pay counsel fees, expenses and costs of Plaintiff. ~, C~ Wayne F~ Attorney for Plaintiff -4- n G':) ~_.,; <;.0 ,-., ";;";1 "'1 -., 0- ~ '..1" r-:-l .,J :.-J i ::~ N 1 1--- --p el, ",1"11 t:I: , "I.:J """ ~ ,L, ." b . '~ ~1J - (st g ... . '"oJ - 0 .. i1rJ 00 " ~':-l gs ." \V 13- , .f:" ~ ,:I . 1- .~. .. CATHY L. RHINE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW v. JONATHAN C. RHINE, Defendant : NO. 98-680 CIVIL TERM : IN DIVORCE AFFIDA VIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE COMMONWEALTH OF PENNSYL VANIA) ) SS: COUNTY OF CUMBERLAND ) I. A Complaint in Divorce under Section 3301(c) of the Divorce Code with Notice of Availability of Counseling was filed on February 5, 1998, and served on February 5, 1998. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a Final Decree of Divorce without notice. 4. W A YNU F. SIlADE Anomey at law 53 Wes! Pomrrcl Slrecl Carlislc,Pcnns)'h..nia 17013 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. .. '. . ,I . 5. I understand that I will not bc divorccd until a Divorcc Dccrcc is cntcrcd by thc Court and that a copy ofthc Dccrcc will bc scnt to mc immcdiatcly al1cr it is filcd with thc Prothonotary. 6. I have becn adviscd ofthe availability ofmarriagc counseling and of my right to counseling and understand that I may request that the Court require that my spouse and I participate in counscling. 7. I understand that the Court maintains a list ofmarriagc counselors in the Domestic Relations Office, which list is available to me upon request. 8. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree's being handed down by the Court. 9. 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. Section 4904 relating to unsworn falsification to authorities. Date: January 20, 2000 WAYNE F. SIIAOE Allomcyal Law '3 West J'omrrcl Street Carlisle. Pennsylvania 17013 ~~ ~ f21~ Cathy L. Rh e . . I . CATHY L. RHINE, Pla/nllff : IN TilE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW JONATHAN C. RHINE, Defendant 98-680 CIVIL TERM IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 5, 1998. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date ofthc filing ofthc complaint. 3. I conscnt to the entry ofa final decree in divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is grantcd. I vcriry that the statcmcnts made in this affidavit are true and correct. I understand that false statements hcrein madc are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: Januarv 20. 2000 0-/; t/ c 19Cr JONATHAN C. RHINE " C") c::> (') r,; 0 --q ., L. L1i-j"j ~.;.::: '7;-, 521'1> "i-:":':' -..'.' -,..C' N '-~'nl C2 .~ :;c.:.' . - ') L ~C) .::..c) :2 --"'-,", -,.- ..,~ -, 1 Jf:CJ - ~-2~~ ''''C' ~ e.jm :;.; c:: -./ ~ l~ "1:;. :.q -', , . . . 98-6811 CIVIL TERM CATIIY L. RIIINE, l'lnlnllff : IN TilE COURT OF COMMON PU:AS OF : CUMBERLAND COUNTY, PENNSYLVANIA Y. CIVIL ACTION - LAW JONATHAN C. RIIINE, Dcfendnnl IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The defendant, being duly sworn according to law, deposes and says: 1. I have bcen adviscd of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counsclors in the Prothonotary's Office, which list is available to me upon rcqucst. 3. Being so advised. I do not requcst that the court require that my spouse and participate in counseling prior to a divorcc dccree bcing handed down. I veriry that the statements made in this affidavit are true and correct. I undcrstand that false statemcnts hcrein made arc subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authoritics. Date: January 20. 2000 fJ1L c if cJ-- JONATHAN C. RHINE . . (') C> () ,.: c) ',. on \Jf;~ '- ."J LPn' ~,:" 7:n ..- " i2J zc.. ,"" n" ,.in oJ.:" ':10 ~C~. 'el- OO>:J ..-. ) );: _-l." l~O :::.: i:j:!1 -=C) t;-.) .,.~ :';'C: c''-j( % .7, ~ i" "t._ ~J .....:.: . . - . . :.:iI::I.1I'1-' J.:r::TUI~n I.l:~,ULA!, CASE 110: 1 ''''..'1..'., l'C.(.!?(1 P COMtlOllWEALTlI 'JF PEllll:;'iL\'MIIA: COUNTY OF CU1'!IJSIlLtd/ll RHINE CATHY L VS. RHINE JOllATllAN ,- WESLEY CQPI\ , Sheriff or Pl?put.y Shel-iff of CUI'lI3ERLANP Count.y. Pennsylv"n~a, who bO.1r.g dull' sworn tlccc'rding t.o law, says. the within COMPLAINT - PI\'nRcr:: upon RHINE JONATHAN C defendant. at 1519:00 HOURS, on lh.? 5th d"y of F'2bruary was 8E'rved , the 1998_ at 400 PETERSBURG RP. CARLISLE, PA 17013 COllnty, Pennsylvania. lol' handing to JOHATHAlI HHINE a true and attested copy of the COMPLAINT - PI VORCE and at thl? same timE' dirl?cting Jlis atll?ntion to the. contl.?nts tht2reof. , CUI18El,LMW J ) . \ , I Sheriff'::; Costs: Pock,>!: i nq Service . Affidavit Surchurge j < So an3wen.,j : ~.~ . /'--'l .' ,', " . ,"'..-.{-'.,:..;...~--, ..,,-,.... ~.,f"..:""'~ '.;'".~~>. ..'('. ~/' . - -.. Ihomos Kl~ne, ~11er~11 f i I l' \~ , il I' .. I:' (' 18. 'UO :1.72 .00 2.00 R. ~~3. 7.::. WAYNE SIIA[JE 1,"2/09/1998 by A:-+k~ Sworn and subscribed ~o before nl~ thi~.Q _L9_ dilY of 19_iL_ A'D~ g~-'-~-~~ r.=- -- "rTLJ4(,I- r r J t, uno 'I. ar '/ , . i , ' I{;: ; , ~;'.. > . ~ . , Of ... , " :.....', 'f' ;,.', ,,,,iril'~. '~'~f~!'\~ '\iw:{1~j'lrl', ~%i'~j~C"<'~". . " ,'i'.t" , '. Ii ... ~~ !~ -<fI> Z3: ~g B~ ~!6 ... ~ > ~~ ~ g-n ~J ~ .,~ Ij z:z:ngz' oP.~~ .... ~~>i~ Q~.B .8 . ~~ ~ . " '..t. ~ ~~~~ ,~~ ~~ ...~~ . < . ,~o..' . ~." ".,;.'< ,,;,-, .' C") \,0 0 ~ co .-n ri1 ~,o '"T1 . 'lJ ("T1 <~~j cu ij1:JJ I -:'1Fn . .. ri)).... ...' .~.. Ul :06 r-~I::'- ~ \~ . ~,......., ~~ ~,., '3] 2ik~ ::l: c.)' ~-jo( ) - ,jnl .. ',"J -, :;~ ,,- (11 ;.II -< CATHY L. RHINE, PJaintiff v, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LA W JONA TI-lAN C, RHINE, Dcfcndant : NO. 98- C, ~e:. CIVIL TERM : IN DIVORCE ORDER OF COURT ~ AND NOW, this ~"'- day of Fcbruary, 1998, it is hcrcby ordcred, as follows: I PI' 'fr 11 o.pI...JlP,:,"'kl' . , " D 11 d Ii . amll s requcst or a rc Immary nJunctlOn cnJommg e cn ant rom , \;\.M withdrawing aAII PPl;) 1...il1l9tJi1l8. In9., as Garnioh..... ~m i'l' 'L.lthlg any ofDefcnJ"..I's employee benefit accounts at PPO Industries, Inc" other than Dcfendant's pcriodic normal payroll accounts, until further Ordcr ofthis Court is granted, 2, Plaintiffshall immcdiatcly file security in the amount of$I.OO with the Prothonotary in conformity with Pa.R.Civ.P, 1531(b)(I) or (2). 3. A hearing is set for \'l11 O)tc<...~ ,the q~ day of Febrnary, 1998, at /1.' ()O o'clock A..M., in Courtroom No. 2. of the Cumberland County Courthouse, Carlisle, Pennsylvania, to dctcrmine whether or not the Preliminary Injunction should bc continucd. WAYNE F. SIlAOI: Altomey.1 Law '3 West Pomrrcl Street Carlisle, Pemuyl\llnill 17013 Waync F. Shadc, Esquirc q &..c..:L :[. '1 S Attorney lor Plaintiff tl~ I / Jonathan C. Rhine, Pro Sc ,,~ ~ .. ,j~" J. PPO Industrics, Inc. ,"""....e~i ~ ;}-)~.9r 4, Plaintiffbelicvcs and thercforc avcrs that Dcfendant has approximatcly $88,000 in various cmployec bcnefit accounts at PPO Industrics, Inc" including, without limitation, employcc savings, stock and retiremcnt accounts, 5. Said cmployce benefit accounts taken together constitute the single most substantial marital asset of the parties. 6. Plaintiff believcs and thcreforc avers that serious criminal chargcs for child sexual molestation are about to be filed against Defendant herein by third parties. 7. Plaintiff believes and thereforc avers that Defendant may withdraw said accounts and flee the jurisdiction as a result of the aforesaid criminal allegations, 8. Plaintiff avers that she does not posscss or control sufficient marital property in order to avoid immediate and irrcparable injury and that she would be left with no mcans to recover her share of marital property in equitable distribution if an ex parte preliminary injunction were not issucd to prevent distribution of any of the employcc bcnefit accounts at PPO Industries, Inc., to Dcfendant. -2- employec bcncfit accounts at PPG lndustrics, Inc" othcr than Dcfendant's pcriodic payroll accounts until furthcr Ordcr of this Court. Respcctfully submitted, dleE~ Wayne F, hade Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff -4- Thc statcmcnts in thc foregoing Motion for Prcliminary Injunction arc bascd upon information which has bcen assemblcd hy my attorncy in this litigation, Thc languagc of thc statcmcnts is not my own. I have rcad thc statcmcnts; and to thc extent that thcy arc bascd upon information which I havc givcn to my counsel, thcy arc truc and eorrcct to thc bcst of my knowlcdgc, information and bclicf: I undcrstand that falsc statcmcnts hcrcin are madc subjcct to thc pcnaltics of 18 Pa,C,S, ~4904 rclating to unsworn falsification to authoritics. Date: Fcbruary 4, 1998 ~ ~ tJ.:.-.., Cathy L, me WAYNE F. SIIADE Attorney a' Law 53 Wesl Pomrm Stred Carlisle. PennsylvaniA 17013 I ,':\ : I , . , , c.\, CATHY L. RHINE, Plainti ff V. JONATHAN C. RHINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 98-0680 CIVIL TERM .DJillE R 0 F _~O_U.RI AND NOW, this 9th day of February, 1998, this matter having been called for a hearing on the request of plaintiff, Cathy L. Rhine, for the issuance of a preliminary injunction, and an ex parte preliminary injunction having been entered on February 5, 1998, and defendant, Jonathan Rhine having appeared without counsel, and having requested time to retain counsel, the motion of defendant for a continuance IS GRANTED. A hearing shall be conducted at 3:30 p.m. Monday, February 23, 1998, in Courtroom No.2, Cumberland County Courthouse, Carlisle, PennsYlvania. Pending said hearing, defendant, Jonathan C. Rhine, is enjoined and prohibited from withdrawing any of his employee benefit accounts at PPG Industries, Inc., other than defendant's periodic normal payroll accounts, until further order of court. This order is premised upon plaintiff filing security today in the amount of $1,00 with the Prothonotary in accordance with PennsYlvania Rule of Civil Procedure 1531(b)(1) or (2). By Wayne F. Shade, Esquire For Plaint! ff Jonathan C. Rhine, Pro se 400 Petersburg Road Carlisle, PA 17013 ~ ~/'ilq~. J,. of. / :prs . . "4 FER 2 3 1998 rP CATHY L. RHINE, Plaintifr : IN TIlE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW v. JONATHAN C, RHINE, Defcndant : NO, 98-680 CIVIL TERM : IN DIVORCE ORDER OF COURT AND NOW, this JY':.l day of Fcbruary, 1998, Plaintiff CATHY L. RHINE and Defendant, JONATHAN C, RHINE, being represented by their independently selected private counsel, respectively, Wayne F, Shade, Esquire, and Thomas S, Diehl, Esquire, of Griffie & Associates, and having stipulated and agrced with regard to the employee benefit accounts of Defendant at PPG Industrics, Inc" it is hcreby ordered and decreed, as follows: I. Defendant is enjoined from withdrawing any of his employce benefit accounts at PPG Industries, Inc., other than his periodic normal payroll accounts until further Order of this Court, 2. Security shall continue in the amount of$1 as posted. BY~' CO'") ~ . Edgar B, Bayley, J, Wayne F, Shade, Esquire Attorney for Plaintiff e' hA~Ot ~ .1./2.?JIQ8- ~ u-'--a .>J-t? Thomas S, Diehl, Esquire Griffie & Associates Attorneys for Defendant PPG Industries, Inc, FiLED-OFFICE 0= 'T"'e: ";':'~JI""""\"""/'\;"'Y , j . "';'." ...JIJ '1 CJa FEn 23 P/i I: .16 "lll,/lJ;' '.; '. I "i ".;'/" \; 'h.1.:... Ij.,~ ~ ,'I..."~.f'i I PEI\'i"I';S \'L~''(N); .' .. .~. CATIIY L. IUIINE l'lainllfl)\'elitillaer IN '1 liE COllin OF CO~IMON I'LEAS OF ClIMIIEIU.ANIl COllNTY,l'ENNSYLVANIA VS. CIVIL ACTION .IlIVOItCE .IONATIIAN C. IUIINE I)e l'endantlHesplllllleal NO. 1)8- (,811 CIVil, TEltM IN IlIVOnCE IlIW 27,511 I'acso," 2771111111'JII olunm 01' COlllrt' AND NOW. this 241h day III' Anri!. 199M. npon eonsiderationol'the auaehcd I'elitionllll' Alimllny I'endente Lite and/or ellnnsellees. it is hereby direeled thallhe parlies and their respeelive eonnsel appcar bell,re IU. Shadd a\' IIn Jnne 2. 199M at 111:311 a.m. Il,r a eonlerenee. at 13 N. Ilanllver St.. Cnrlisle. PA 171113. aileI' which Ihe conlerenee orncer may reconllllend thai an Order li,r Alimony Pendenle Lite be enlered. YOU arc Illrther ordered 10 bring lolhe conlerenee: (I) a true copy or yonI' most recenl Federal Income Tax Hetum. inclnding W-2's as liIed (2) your pay sllobs lill' the preceding six (6) months (3) Ihe Ineollle and Expense Slalelllelll aUaehed 10 this order. compleled as required by Hnle tlJllI.I I") (4) vcrilicntioll of child care expenses (5) pfUofufmcdical coverage which you mil)' have. or may have available to )'nu IF )'Oll fuillo appear fur the conference or bring the required documents. the Court may issue a wnrranl fur your arrest. cc: pelitioner and responden~ . (\. _\ ce: Wayne F. Shade. Esq. ~ cc: Murcns A. McKnight. 111. ESII. NW:I:J.. Dale or Onler: Aori! 2.1. IlJ9M " I ;ILliG'?; BY TilE COUHT. -l/eorge E. Ilofler. Presideot Jndge NJ. . . YOU IIAVE TilE I{IGIITTO A LAWYElt. WIIO MA Y ATT .NIl TIlE CONFEnENCE ANIl ItEI'I{ESENT YOU, IF YOU 110 NOT IIA VE A LA WYElt on CANNOT AFFOIUl ONE. G . ) on TELEI'1I0NE TilE OFFICE SET FOlnllllELOW TO FINIl OUT WIIEnE YOll MA Y GET LEGAL liEU'. COUHT ADMINISTHA'roH FOllHTl1 FLOOH CUMBEHLAND COUNTY COUHT IIOUSE CAHLlSLE.PENNSYLVANIA 171113 (717) 2411.621111 Filt:O-Ori:;CE 0.. TI'~ rN'1"' ,'" '~1''''''( j. .,': I'll I \.),\'.) h':"\ Sf.! r\P~ 211 I'll :)l ~i9 CU:k~,E~H.i ,~\U (>J";j{tY \."-1'1....(..'..... . t: 'I .~~; l.\' \\ ';'1 \ \' n _0 (') c: :;0 .n ~:;: :,"..;1. ::;J "', -:', fTlrn ,:~I .. :!l ~if .l1r- .nnl c-> :-JO ,') , ti;~ ^~~ir~ 2-::; .,- '~ ,;--, ',2,,:> ..~. r:.:: urn -, :.) t:'" -. .- ~ ...1 -.: .. , " I~i, ,. . n ,0 0 c 0) ." ~ '- ~ .,.,b' c::: ,:..:,:!l rnn1 -~ "'~ -t1F!j -/~n - :,:f~.. 0 -"'b 1 1)),:-. ,~ J 2ri :z.~" ;::r\ ~ .- 'J ;,On :-. , .... ';.,.Cl ~Cl ~-r-rn I :;:a c...~: Cf! 9 7.' r:- ~ 3. 0-- 0< j ~ t._ .' CATHY L, RIIINE. PlnintilT/Pclitioncr IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS, CIVIL ACTION - IlIVORO: JONATHAN C, RIIINE, DcfcndllntlRcspondcnt NO. 9N - 6NIl CIVIL TERM IN DIVORCE DRII 27~11 PncNcNII 277\l11l1l91l ORDER OF COURT AND NOW. this 23,,1 day of Jnnc. 1999. upon considcrntion ofthc 1I11nchcd Pctition for Alil1lony Pcndcntc Litc and/or connscl fccs. it is hcrcby dircclcd that thc partics nnd Ihcir respcclivc connsclnppcnr bcforc RJ. Shaddllv on J/lII' 22, 1999/1110:.10 A.M, for a confcrcncc. nt 13 N. Hnnovcr SI.. Carlislc. PA 17ll13. nncr which thc confcrcncc officer l1Iay rccol1ll1lcnd tllatnn Ordcr for Alil1lony Pcndcntc Litc be cntcrcd. YOU nre fnrthcr ordcred to bring to the confcrcnce: (I) atme copy of your 11I0St reccnl Fcdcrnllncol1lc Tax Retnrn. inclnding W-2's as filcd (2) your pay stubs for the prcccding six (6) 11I0l1lhs (3) the Incol1le nnd Expcnse Stalcl1lclllallacllcd 10 this ordcr. cOl1lplctcd as rcquircd by Rnle 1911l.11(f) (4) vcrilication of child care expcnscs (5) proof of mcdical covernge wllich yonl1lay have. or l1Iay have available to )'ou IF yon fnil to appcar for Ihc confcrcnce or bring Ihe reqnircd docul1lcllls. the Court l1Iay issne a warrant for )'onr nrrcsl. "- cc: Pctitioncr . ~ Rcspoudent (\~o::\ Wayne Slmdc. Esquire No\;'cJ< Marcus McKnighl. Esquire \ l \,v U> ;}o;rd Date of Ordcr: June 23. 1999 BY THE COURT. Gcorge E. HolTcr. Presidcnt Jndge . ./' / J}J / 1 . I.. /.f~J-' l.-Ll..u I -,.- I" \. ) R. h SlIadday. Confercncc Officcr YOU HAVE THE RIGHT TO A LAWYER. WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP, CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE. PENNSYLVANIA 171113 (717) 249-3166 '. I" : [T..(" ',r= ,'" ", ". '...~, _ J';~""~"I \ .. . '. )',...... 99 JU:l 7.:i (III E: :19 I~U' ,-, .' -" {'" "I~Y oJ 1'/1:..1.:. ,~.i-e \;..; ,~.U~~I" I ,....., l!-.'CV1 '\1" 1" t"'l:.IIWivll-,F-i\}\ .'.,~ '. " . ' 7, Defcndant's last known address is 400 Petersburg Road, Carlisle, Pennsylvania 17013. WHEREFORE, Petitioner requests that the Court confirm the existing Order for alimony pendentc lite in the amount of$585 per month effective June 14, 1999. I verify that the statements made in this Petition 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: June 18, 1999 ~14! ~ Wayne F. Shade Attorney for Petitioner W A YNEF. SIIADE Anomey Itl.lW 53 WC1t Pomrrcl Street C&llisle, Penns)'lvanil 17013 .~. DR 27,51 t CATHY L. RHINE, PLAINTIFF/PETITIONER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS CIVIL ACTION - LA W JONATHAN C, RHINE DEFENDANTIRESPONDENT: NO, 98- 680 CIVIL TERM Pacses# 277100090 ORDER OF COURT AND NOW, this 2nd day of June, 1998, based upon the Court's determination that Petitioner's monthly net income is $ 1529.00 per month and Respondent's monthly net income is $ 2992.00 per month, it is hereby Ordered that the Respondent pay to the Domestic Relations Section. Court of Common Pleas. $ 248.00 a month payable $ $248,00 Der month as alimony pendente lite, effective 4/16/98, This order is based UDon Rule 191O.l6-5m. Arrears set at $ 496.00 as of 612/98 , shall be payable at $ N/ A . First payment due on or before the fifth dav of each month, and each month thereafter, Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C.S.~ 3703. Further, if the Court finds. after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Payments must be made by cash, check or money order, Cash payments must be made in person. All checks and money orders must be made payable to Domestic Relations Section and delivered or mailed to Domestic Relations Section, 13 North Hanover Street, P.O. Box 320. Carlisle, Pennsylvania. 17013, Each payment must bear your Domestic Relations number (Pacses# 277100090 ) in order to be processed. Respondent is responsible for service fees of 26.00 to be paid within N/ A as determined by the Domestic Relations Scction. .' This Order shall become final tcn days after thc mailing ofthc nOlice of the entry of the Order to lhe parties unless either party files a wrillen demand with the Prothonotary for a hearing de novo before the Court. Copies delivered to parties on Consented: t,-~.q~ Plaintiff.lpetitioner PlaintifflPetitioner's Allorney DefendantlRespondent DefendantlRespondent's Attorney DRO: R.J, Shadday cc: petitioner and respondent cc: Wayne F. Shade, Esq, cc: Marcus A, McKnight, Ill, Esq. J, TRUE COpy FROM RECORD In Testimony Wher50f,I hertl unto set my hand and the seal of said Court at Carlisle. Pa. This /0 f'> day' of ...JU/U>.. , 19 qg l A /)()" :0 M8/llJY\or".. ()A Prothonotary DR 27,511 PACSES ID 277100090 vs, IN '1'11I: COllRT 01' COMMON I'I.I:AS CllMIII:RI.AND COUNTY, P/:NNSY/.Y ANIA DOM/:S'I'lC R/:I.A'I'IONS S/:CTION CIVil. ACT/ON - LAW It ';i ) . , : 1 CATHY I.. RIIINI:, P]aintiff/Pctitioner JONATHAN C. R/HNl:" Dcfcndant/ NO. lJ8-1180 CIVIL T1:RM ORDER OF COURT AND NOW, this 23'd day of July, ]999, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $1,529.00 per month and Respondent's monthly net income/earning capacity is $2,992.00 per month, it is hereby Ordcred that the Respondent pay to the Domestic Relations Section, Court of Common Picas, $625.00 a month payable monthly as follows; $585.00 per month for alimony pendente lite and $40.00 on arrears. First paymcnt due on or before 8- 5-99 and on the 5th day of each month thereaftcr. Arrears set at $1,156.62 as of July 22, 1999. The effective date of the order is 6-10-99. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as proyidcd by 23 Pa.C.S.~ 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contcmpt of Court and its discretion makc an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Payments must be made by cash, check or money ordcr. Cash payments must be made in person. All checks and money ordcrs must be made payable to Domestic Rclations Section and delivered or mailed to Domestic Relations Section, 13 North Hanovcr Street, P.O. Box 320, Carlisle, Pennsylvania, /7013. Paymcnts must include the dcfendant's PACSES Member Number or Social Security Number in ordcr to be processed. Do not scnd cash by mail. After August 1, 1999 payments should be mailed to PA SCDU, P.O. Box 69110, Harrisburg, PA 17106. , Unreimburscd medical expenses that exceed $250.00 annually arc to bc paid 0% by the respondent and 100% by petitioner. The plaintil1'is responsiblc to pay thc first $250.00 annually in unreimburscd medical cxpenses. Rcspondent to provide medical insurance coveragc. Within thirty (30) days al1er the entry of this order, the Respondent shall submit written proof that medical insurance coveragc has been obtaincd or that application for coverage has been made. Proof of coveragc shall consist, at a minimum, of: 1) the namc of the health care coverage provider(sj; 2) any applicable identification numbers; 3) any cards evidencing coveragc; 4) thc address to which claims should be made; 5) a description of any restrictions on usage, such as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of the benefit booklct or coverage contract; 7) a dcscription of all deductibles and co-paymcnts; and 8) five copies of any claim forms. This Order shall become final ten days after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary for a hcaring de novo before the Court. Conscnted: Plaintiff/Petitioner Plaintiff/Petitioner's Attorney Defendant/Respondent Defendant/Respondent's Attorney DRO: R. J. Shadday Copies mailed Petitioner 'l-(),?-'ft} to < Respondent Waync Shade, Esq. Marcus McKnight, III, Esq. BY THE COURT, dL J. J. eslcy Oler, Jr. In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION CATHY L, RHINE ) Docket Number 98-680 CV Plaintiff ) YS, ) PACSES Case Number 277100090/27,511 JONATHAN C. RHINE ) Defendant ) O~ler Slale 10 Number Order AND NOW to wit, this FEBRUARY 3, 2000 it is hereby Ordered that: THE ABOVE CAPTIONED ORDER OF ALIMONY PENDENTE LITE IS TERMINATED, EFFECTIVE JANUARY 20, 2000, PURSUANT TO THE PARTIES' MARRIAGE SETTLEMENT AGREEMENT. THERE IS A REMAINING BALANCE OF $511.71 OWED TO PETITIONER AND $8,62 OWED TO THE DOMESTIC RELATIONS SECTION IN REMAINING SERVICE FEE. DEFENDANT IS TO CONTACT THE DOMESTIC RELATIONS SECTION WITHIN FIVE DAYS UPON RECEIPT OF THIS ORDER WITH A PAYMENT SCHEDULE FOR THE REMAINING BALANCE (S) . DRO: RJ Shadday xc: pIal ntHf defendant Wayne F, Shade, Esqu.1 re Marcus A. McKn.lght. III, Esquire BY THE COURT: J . JUDGE Service Type M .... " J ~f ~ 1.-1:" I . '..::' .', i;it....h~lIl.d.,..,;.;,,) ).,- '7 -00 Form OE-OOI Worker ID 21005 " ~ .,; (') C. CJ r.:: c;:) '1} ;:,'=: ...,., "T.l (". 1 ,., "1-, rill'/": r:::1 -...., ol._. 'j I .- ~.~: ;" ,-. U;,',,: ....1 ;'T ~~- .';(.1 , : ,~ '. ./ ""0 :,;;. C" ~' c:: z -" 3. (~ ~J -;; ....l i,! (') 0 0 C l'~ ." ~ .." -[}h~ rrl ::~ m!.1: m :1:lp .,'_ ,.1.J 7"[' .'.~ll T1 0]..;;', <::) :.,0 '-II r::i':i ',':',f) ~f' ~ )::0 ~)r.~) 9? ~ .:.' I ,'1 -' -;7 ;:-1 ~ Ul c- _. :.'0 ...J -< , . JONATHAN C, RHINE PACSIJS Member Number: 1890100046 PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER lD OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED, DO NOT SEND CASH BY MAIL, This order of attachment for support is binding upon you until furthcr noticc and shall havc priority over any attachment, exccution, garnishment or wage attachment undcr statc or local law except one relating to a prior support order , You must commence the attachment of the defendant obligor's income as soon as possible but no later than fourteen days from the datc of the issuance of this Order of Attachment. You are notified further that pursuant to law: ), The defendant obligor has been notified that an order of attachment for support would be issued, 2, Willful failure to comply with this order may result in (i) your being adjudged in contempt of court and committed to jailor fined by the court; (ii) your being held liable for any amount not withheld or withheld but not forwarded to the Domestic Relations Section; and (Hi) attachment of your funds or property, 3, The attachment of income or the possibility thereof as a basis, in whole or in part, for the discharge of an employee or any disciplinary action against or demotion of an employee is prohibited. Violation may result in (i) your being adjudged in contempt and committed to jailor fined by the court and (ii) an action against you by the employee for damages, 4, If there are in your employment one or more additional employees whose incomes are subject to an attachment of support, you may combine the attachment payments into a single payment to the Pa SCDU and separately identify the portion attributable to each obligor. 5, You must notify the Domestic Relations Section or the Pa SCDU when the defendant obligor terminates employment and provide the Section with the employee's last known address and the name and address of the new employer, if known. Page 2 of3 Form EN-028 Worker ID $IATT Service Type M JONATHAN C, RHINE PACSES Melllher NUlIlher: 1890100046 6, The maximum amount of the attachment shall not exceed 55 % of the employee's net income which is within the limits set in the Consumer Credit Protection Act, 15 U,S,C, ~1673, 7, The term "income" as defined by law includes compensation for services, including, but not limited to, wages, salaries, fees, compensation in kind, commissions and similar items; income derived from business; gains derived from dealings in property; interest; rents; royalties; dividends; annuities; income from life insurance and endowment contracts; all forms of retirement; pensions; income from discharge of indebtedness; distributive share of partnership gross income; income in respect of a decedent; income from an interest in an estate or trust; military retirement benefits; railroad employment retirement benefits; social security benefits; temporary and permanent disability benefits; worker's compensation; unemployment compensation; other entitlements to money or lump sum awards, without regard to source, including lottery winnings; income tax refunds; insurance compensation or settlements; awards or verdicts; and any form of payment due to and collectable by an individual regardless of the source, GENERAL INSTRUCTIONS J. Employers may elect to deduct up to 2 % of the attachment amount for their costs. This amount must not be deducted from the attachment. It must be paid from the employee's net earnings after the income attachment deduction has been made, 2. If you choose to make payments via an electronic funds transfer, contact the Pa SCDU Employer Customer Service at 1-877-676-9580. Date of Order: February 17. 2000 DRO: RJ Shadday xc: defendant Service Type M J Page 3 0 - JUDGE Fonn EN-028 Worker 10 $IATT ~tH.;:1LED ~ t%J -""'" ~,,~ .' f: ~ ~ . , (") (~:l , co. (:.: , ." .." !' ~ '. ., ro', \ " :~ ~~. i ~) l ~ j V;; , '.'-, . ;.1';', -. i.~., ,_. .' ::'~ '~' "'j _.,~ ) ;;:) ". r--;. ~t (~ C) ~=-: ~. c: 3. co:> .< In the Court of Common Picas of CUJ\l1ImU.ANU County, Pcnnsylvllnlll UO:\lESTIC I{EI.ATIONS SECTION Dcfcndant Name: JONATHAN C. RHINE Mcmber ID Number: 1890100046 ('Il'use null': 1\11 rnrn~IHlI1dL'IU'l'lIIl1sllllrhllll' lhe ~fl1ullt'r In ~lIInlll'r. PP&G 535 PARK DRIVE CARLISLE PA 17013 ORDER - TERMINATION OF INCOME ATTACHMENT Financial Break Down or Mllltiole Cases 00 Allachment JlllIinlin'Namc CATHY L. RHINE I'ACSES ClISC Nllmhcr 277100090 40.00 IMONTH ~ / / ~ ~ / / Duckcl NUl1lhcr 98 -680 CV AUuchmcnt ^1l1tlllllll1~rcuucncv 027,511 $ ~ $ $ ~ $ TOTAI.ATTACIIMI,IiT AMOUIiT: $ 40.00 TO: PP&G AND NOW, this 28TH DAY OF FEBRUARY, 2000 the Income Attachment Order dated AUGUST 17, 1998 in the amount of $ 40.00 for JONATHAN C. RHINE , 142-42-1218 is hereby TERMINATED. Effective immediately, you are dirccted to cease all payments and collections from the income of Defendant which were authorizcd by said Order, BY THE COURT: Dale of Order: February 28, 2000 JUDGE Service Type M ~ Form EN-On Worker ID 21205 C") 0 ~ c CI ~<: :r.: :ji -0 cn :c. 9.293 ~O h'i~ :ze. I .om ~:t~ en ::'6 CI ~'"? :J '< ""tl -r:-' ~8 ::!l: 6:i:J .._(') 5>f;; z:- on1 ~ -i :::l ~ ~... -. .,.... '. "'..