HomeMy WebLinkAbout98-01211_1.
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IN THE COURT OF COMMON PLEAS
OF CUMBERLANDCOUN'ry
STATE
J. GASKILL, II
VERSUS
RONALD L. GASKILL,
Defendant __-_
N p 98 - 1211 CIVIL TERM
DECREE IN
DIVORCE
AND NOWT Zfd IT IS ORDERED AND
Susan J. Gaskill PLAINTIFF,
DECREED THAT _ _ _---._---- '-'
AND Ronald L^Gaskill DEFENDANT,
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
The attached Property Settlement Agreement is hereby incorporated, but
not merged, into this Decree in Divorce.
BY THE CO
ATTEST: aim- J'
_ PROTHONOTARY
E OF PENN A.
?s ayo h
J./
PROPERTY SETTLEMENT AGREE FNT
THIS AGREEMENT, made this ]?)I .L day of I ° _ 2002, by and
between RONALD L. GASKILL, hereinafter called "Husband", and SUSAN . GASKILL,
hereinafter called "Wife"
WITNESSETH;
WHEREAS, Husband and Wife were legally married on April 12,1975;
WHEREAS, two children were born of this marriage. Jody Gaskill, date of birth August 21,
1976, and Jennifer Gaskill, date of birth June 16, 1980;
WHEREAS, differences have arisen between Husband and Wife in consequence of which
they desire to live separate and apart fi•om each other; and
WHEREAS, Husband and Wife desire to settle and determine their rights and obligations.
NOW THEREFORE, in consideration of the premises and covenants contained herein, it is
agreed by and between the parties hereto that:
1. SEPARATION.
It shall be lawful for each party at all times hereafter to live separate and apart from each
other at such place as he or she from time to time shall choose or deem fit. The foregoing provision
shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of
the causes leading to their living apart.
2. INTERFERENCES.
Each party shall be free from interference, authority and control by the other, as fully as if
he or she were single and unmarried, except as may be necessary to carry out the provisions of this
Agreement. Neither party shall molest or attempt to endeavor to molest the other, or in any way
harass or malign the other, nor in any other way interfere with the peaceful existence, separate and
apart from the other.
3. DIVISION OF PF, SONAL PROPERTY.
The parties have divided between them to their mutual satisfaction, persona] effects,
household goods and furnishings and all other articles of personal property which have heretofore
been used in common by them, and neither party will make any claim to any such items which are
now in the possession or under the control of the other. Should it become necessary, each patty
agrees to sign any title or documents necessary to give effect to this paragraph, upon request.
4. EQUITABLE DISTRIBUTION.
Counsel for Wife, John J. Connelly, Jr., Esquire, is escrow agent for an account established
for the benefit of the parties at M&T Bank, having a principal balance of approximately $22,222,14
as of the last statement from M&T Bank dated December 2001. Upon the execution of this
Agreement, Wife shall receive, in the form of equitable distribution, the balance in the escrow
account. In addition, Wife shall be solely responsible for the payment of taxes or any capital gains
or any interest generated by the account since its inception.
5. MEDICAL INSURANCE.
Husband agrees that he shall continue to carry Wife on his medical coverage until the
parties secure a Decree in Divorce as referenced in Paragraph 25 hereof. Husband further agrees
that he will fully cooperate with Wife in her effort to secure medical coverage after February 1,
2002, The delay in securing medical coverage until after February 1, 2002 will permit Wife to
secure coverage that excludes any pre-existing conditions of Wife. Husband's cooperation in
this matter shall include the execution of any documents necessary to provide Wife with COBRA
coverage through Husband's current employer. From the date of the Divorce Decree, Wife shall
be solely responsible for her medical coverage including the cost or any other expenses related
thereto, It is anticipated that the Divorce Decree will be entered within the month of February
2002,
6. LIFE INSURANCE,
Should Wife decide to purchase life insurance on Husband's life in order to insure
payments under the terms and conditions of this Agreement in the event of Husband's death,
Husband agrees that he shall submit to any physical at Wife's expense or provide any information
necessary to secure coverage. Wife shall be solely responsible for the cost of any application or
premiums on the said policy.
Husband shall retain as his sole and separate property, his 401k plan with his former
employer as well as any other retirement type plans presently in existence in his name individually,
Wife hereby expressly relinquishes, waives and disclaims all of her rights, title and interest in and
to any pension plan, retirement plan, 401(k-) plan, IRA, Keough, SEP-IRA, deferred compensation,
employee benefit plan or any other plan or benefit of similar nature owned or controlled by
Husband or by any other person for the benefit of or on behalf of Husband. Wife further promises,
covenants and warrants that she will execute any and all documents necess<ay to sever her interests
in any of the aforesaid plans and to effectuate the purposes of this paragraph,
8. ALIMQMl. -
Presently Husband is currently paying to Wife in the form of alimony pendente lite, the sum 4
Of $1,302.00 per month, payable on a semi-monthly basis pursuant to a wage attachment. Husband t
agrees that he shall continue said payments in the form of alimony for an indefinite period of time.
Husband and Wife agree that either party may file for modification of the said alimony payment
based on a change in circumstances of either party. Wife further agrees that payment is not subject
to modification based on the income or earning capacity of Husband's future spouse, and such
income may not be considered for alimony payments thereof The said payments shall terminate
upon the earlier of the death of either party or Wife's remarriage or cohabitation. Pursuant to an
Order of Court dated October S, 2001, arrearage on the Alimony Pendente Lite Order was set at
$2,379.36. Husband has appealed the Order as to the amount of the arrearage,
Husband shall secure an audit through the Domestic Relations Office to make a
determination as to the actual amount of his arrearage. Wife agrees to fully cooperate in the said
audit and provide any information which will assist in completing an audit and establishing an
accurate arrearage figure. Upon establishment of the arrearage figure, an amotmt shall be paid on
the arrearage in order to pay off the arrearage of record, said amount to be agreed upon by the
parties or set by the court through the Domestic Relations action.
All such payments by Husband to Wife shall be deemed alimony, as defined in Section 71
(b) (1) (A) of the Internal Revenue Code as amended, and as said Section is amplified by the
provisions of the Tax Reform Act of 1984 and Tax Reform Act of 1986, and any future laws or
regulations related thereto. Payments from Husband, when received by Wife, shall be deductible in
the year of payment by Husband pursuant to Section 215 of the Internal Revenue Code, as
amended, or any similar future laws or regulations thereto, and shall be includable in the year of
receipt in the gross income of Wife pursuant to Section 71 (b) (1) (A) of the Internal Revenue Code,
as amended or any similar future laws or regulations thereto.
9, Ap -LICARILITY OF TAX LAW TO PROPERY TRANRFLRC,
The parties hereby agree and express their intent that any transfer of property pursuant to
this Agreement shall be within the scope and applicability of the Deficit Reduction Act of 1984
(hereinafter the "Act"), specifically, the provisions of said Act pertaining to the transfers of
property between spouses and former spouses. The parties agree to sign and cause to be filed any
elections or other documents required by the Internal Revenue Service to render the Act applicable
to the transfers set forth in this Agreement without recognition of gain on such transfer and subject
to the carry-over basis provisions of the said Act.
10, BREAC .
If either party breaches any provision of this Agreement, the other party shall have the right,
at his or her election, to sue for damages for such breach. The party breaching this contract shall be
responsible for the payment of legal fees and costs incurred by the other in enforcing his or her
rights under this Agreement, or seeking such other remedy or relief as may be available to him or
her. The parties specifically acknowledge that they are entitled to utilize the remedies as set forth in
the Divorce Code of 1980, as amended.
11. EI1 • . DIS ..OS1JR .
Husband and Wife each represent and warrant to the other that he or she has made a full and
complete disclosure to the other of all assets of any nature whatsoever, and of all other facts relating
to the subject matter of this Agreement to which such party may reasonably require to make an
informed decision regarding this Agreement,
12. ADD_IDONAL INSTRUMENT.
Each of the parties shall on demand execute and deliver to the other any deeds, bills of sale,
assignment, consents to change of beneficiary on insurance policies, tax returns and other
docwnents and do or caused to be done any other act or thing that may be necessary or desirable to
the provisions and purposes of this Agreement. If either party fails on demand to comply with this
provision, that party shall pay to the other all attorneys' fees, costs and other expenses reasonably
incurred as a result of such failure.
13. WIFE'S DEBTS-
Wife represents and warrants to Husband that since the parties' separation she has not and in
the future she will not contract or incur any debt or liability for which Husband or his estate might
be responsible and W& shall indemnify and save Husband harmless from any and all claims or
demands made against him by reason of debts or obligations incurred by her,
14. HUSK ND'S XIM.
Husband represent!; and warrants to Wife that since the parties' separation he has not and in
the future he will not contract or incur any debt or liability for which Wife or her estate might be
responsible and Husband shall indemnify and save Wife harmless from any and all claims or
demands made against her by reason of debts or obligations incurred by him.
15. WAIVE, S OF CLAIMS AGAINST ESTAU, S.
Except as otherwise provided herein, each party may dispose of his or her property in any
way, and each 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 property or the
estate of the other as a result of the marital relationship, including without limitation, dower, curtsy,
statutory allowance, 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 each will, to the
request of the other, execute, acknowledge, and deliver any and all instruments which may be
necessary or advisable to carry into effect this mutual waiver and relinquishment of all such
interests, rights and claims.
16. REP E .NTATION.
It is recognized by the parties hereto that Husband is represented by Courtney L, Kishel,
Esquire, and Wife is represented by John J. Connelly, Jr., Esquire. It is fully understood and agreed
that by the signing of this Agreement, each party understands the legal impact of this Agreement
and further acknowledges that the Agreement is fair and reasonable and each party intends to be
legally bound by the terms hereof.
17. YOLUNT.ARY EXECUTION.
'Me provisions of this Agreement are filly understood by both parties and each party
acknowledges that this Agreement is fair and equitable, that it is being entered into voluntarily and
that it is not the result of any duress or undue influence.
18. ENTIRE AGREEMEN C,
This Agreement contains the entire understanding of the parties and there are no
representations, warranties, covenants or undertakings other than those expressly set forth herein.
19. PRIOR AGREEMENT.
It is understood and agreed that any and all property settlement agreements which may or
have been executed prior to the date and time of this Agreement are null and void and of no effect.
20. MODIFICATION AND WAIVER.
Any modification or waiver of any provision of this Agreement shall be effective only if
made in writing and executed with the same formality as this Agreement. The failure of either
party to insist upon strict performance of any of the provisions of this Agreement shall not be
default of the same or similar nature.
construed as a waiver of any subsequent
21. b'i4_VLRN1NGJ"'
This Agreement shall be governed by and shall be construed in accordance with the laws of
the commonwealth of Pennsylvania.
PAJ ' coVCN?T
22. INDF.Pj;ND ,NT SE
It is specifically understood and agreed by and between the panics hereto that each
paragraph hereof shall be deemed to be a separate and independent covenant and agreement.
2;, yQID I& s.
If any term, condition, clause, or provision of this Agreement shall be determined or
declared to be void or invalid in law or otherwise, then only that term, condition, clause or
provision shall be stricken from this Agreement and in all other respects this Agreement shall be
valid and continue in full force, effect and operation.
24, *'*''''nv &PART of DTCRLLr-
It is the intention of the parties that this Agreement shall survive any action for divorce
which may be instituted or prosecuted by either party and no order, judgment or decree of divorce,
temporary, final or permanent, shall affect or modify the financial terms of this Agreement, other
than modification of alimony, pursuant to Paragraph 8 this Agreement. This Agreement shall be
made a part of, but shall not merge with, any such judgment or decree of final divorce.
25. D"RCLACIM,
The parties agree that they will execute all documents necessary to finalize the divorce
action including, but not limited to, the withdrawal of any claims pending under said action,
indexed to number 98-1211, in the Court of Common Pleas, Cumberland County, Pennsylvania, as
well as Affidavits of Consent and Waivers of Counseling and Waivers of Notice of Intention to
Request Entry of a Divorce Decree on February 1, 2002 at which time the documents shall
immediately be processed and the divorce finalized, The purpose of extending the final Decree is to
permit Wife to be eligible for medical insurance coverage without a pre-existing condition.
'7
26. DOME! STIC RELATIONS CU 1 HF COMMONWEALTH-OF-
Except yIA•
as specifically provided in this Agreement, each party waives any claim they may
have against the other under the Domestic Relations Code of the Commonwealth of Pennsylvania
including, but not limited to, alimony, alimony pendente lite, counsel fees, costs and equitable
distribution of marital property.
IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have
hereunto set their hands and seals the day and year first above written,
C?
Susan J. Gaskil
WITNESS:
Courtney L. Kis el, Esquire
COMMONWEALTH OF PENNSYLVANIA
ss,
COUNTY OF C'U r'A-Y-C 1 C4. (4'
On this, the 22T?- day of _ l A 00,KK J 2002, before me, a Notary Public,
personally appeared Ronald L. Gaskill, (mown to me to be the person whose name is subscribed to
the within Property Settlement Agreement and acknowledged that he executed the same for the
purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and officiul seal.
NOTARY PUBLIC
ANAL SEAL
pRUNoSKE. Pd*
PA
?? 13 2042 nn
F
COMMONWEALTH OF PENNSYLVANIA
ss,
COUNTY OF ?L1L ?k J
On this, the J day of 2002, before me, a Notary Public,
I
personally appeared Susan J, Gaskill, known 2metlo'bethe person whose name is subscribed to
the wititin Property Settlement Agreement and acknowledged that she executed the same for the
purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
NOTARY PUBLIC
FN0 TARIAL SEAL
Koster, N otary Public
elstown,County of Dauphin
sion Expires Fob, 9, 2004
SUSAN J. GASKILL,
Plaintiff
vs.
RONALD L. GASKILL,
Defendant
IN THE; COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 98 - 121.1 CIVIL
IN DIVORCE
ORDER OF COURT
AND NOW, this ?.)_ day of
the economic claims raised in the proceedings having
been resolved in accordance with a property settlement
agreement dated February 13, 2002„ the appointment of the
Master is vacated and counsel can file a praecipe
transmitting the record to the Court requesting a final
decree in divorce.
BY THE COURT,
cc: John J. Connelly, Jr.
Attorney for Plaintiff
..'-?Ourtney L. Kishel
Attorney for Defendant
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pRO xrY nITLEM DMAGRE r+.NT
THIS AGREEMENT, made this L day of 2002, by and
between RONALD L. GASKILL, hereinafter called "Husband", and SUSA J. GASKILL,
hereinafter called "Wife".
WITNESSETH:
WHEREAS, Husband and Wife were legally married on April 12, 1975;
WHEREAS, two children were born of this marriage. Jody Gaskill, date of birth August 21,
1976, and Jennifer Gaskill, date of birth June 16, 1980;
WHEREAS, differences have arisen between Husband and Wife it. consequence of which
they desire to live separate and apart from each other; and
WHEREAS, Husband and Wife desire to settle and determine their rights and obligations.
NOW THEREFORE, in consideration of the premises and covenants contained herein, it is
agreed by and between the parties hereto that:
1. SEEAi2ATION.
It shall be lawful for each party at all times hereafter to live separate and apart from each
other at such place as he or she from time to time shall choose or deem fit. The foregoing provision
shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of
the causes leading to their living apart.
2. INTF E , NMI -
Each party shall be free from interference, authority and control by the other, as fully as if
he or she were single and unmarried, except as may be necessary to carry out the provisions of this
Agreement. Neither party shall molest or attempt to endeavor to molest the other, or in any way
harass or malign the other, nor in any other way interfere with the peaceful existence, separate and
apart from the other,
3, j?VI?ION OF PEI2S?INAE P1tOPERTY.
The parties have divided between them to their mutual satisfaction, personal effects,
household goods and furnishings and all other articles of personal property which have heretofore
been used in common by them, and neither party will make any claim to any such items which are
now in the possession or under the control of the other. Should it become necessary, each party
agrees to sign any title or documents necessary to give effect to this paragraph, upon request,
4. ES EMAD • DISTRBII io-
Counsel for Wife, John J. Connelly, Jr„ Esquire, is escrow agent for an account established
for the benefit of the parties at M&T Bank, having a principal balance of approximately $22,222,14
as of the last statement from M&T Bank dated December 2001. Upon the execution of this
Agreement, Wife shall receive, in the fonn of equitable distribution, the balance in the, escrow
account. In addition, Wife shall be solely responsible for the payment of taxes or any capital gains
or any interest generated by the account since its inception.
$, MUKAL INSURANCE.
Husband agrees that he shall continue to carry Wife on his medical coverage until the
parties secure a Decree in Divorce as referenced in Paragraph 25 hereof. Husband further agrees
that he will fully cooperate with Wife in her effort to secure medical coverage after February 1,
2002, The delay in securing medical coverage until after February 1, 2002 will permit Wife to
secure coverage that excludes any pre-existing conditions of Wife. Husband's cooperation, in
this matter shall include the execution of any documents necessary to provide Wife with COBRA
coverage through Husband's current employer. From the date of the Divorce Decree, Wife shall
be solely responsible for her medical coverage including the cost or any other expenses related
thereto. It is anticipated that the Divorce Decree will be entered within the month of February
2002.
6. LIFE NS IRAN "G.
Should Wife decide to purchase life insurance on Husband's life in order to insure
payments under the terms and conditions of this Agreement in the event of Husband's death,
Husband agrees that he shall submit to any physical at Wife's expense or provide any information
necessary to secure coverage. Wife shall be solely responsible for the cost of any application or
premiums on the said policy.
7. $T-TIIEMI! NT.
Husband shall retain as his sole and separate property, his 401k plan with his former
employer as well as any other retirement type plans presently in existence in his name individually.
Wife hereby expressly relinquishes, waives and disclaims all of her rights, title and interest in and
to any pension plan, retirement plan, 401(k) plan, IRA, Keough, SEP-IRA, deferred compensation,
employee benefit plan or any other plan or benefit of similar nature owned or controlled by
Husband or by any other person for the benefit of or on behalf of Husband. Wife further promises,
covenants and warrants that she will execute any and all documents necessary to sever her interests
in any of the aforesaid plans and to effectuate the purposes of this paragraph.
g. SIMONY.
Presently Husband is currently paying to Wife in the form of alimony pendente lite, the sum
of $1,302.00 per month, payable on a semi-monthly basis pursuant to a wage attachment. Husband
agrees that he shall continue said payments in the form of alimony for an indefinite period of time.
Husband and Wife agree that either party may file for modification of the said alimony payment
based on a change in circumstances of either party. Wife further agrees that payment is not subject
to modification based on the income or earning capacity of Husband's future spouse, and such
income may not be considered for alimony payments thereof. The said payments shall terminate
upon the earlier of the death of either party or Wife's remarriage or cohabitation. Pursuant to an
Order of Court dated October 5, 2001, arrearage on the Alimony Pendente Lite Order was set at
$2,379.36. Husband has appealed the Order as to the amount of the arrearage.
Husband shall secure an audit through the Domestic Relations Office to make a
determination as to the actual amount of his arrearage. Wife agrees to fully cooperate in the said
audit and provide any information which will assist in completing an audit and establishing an
accurate arrearage figure. Upon establishment of the arrearage figure, an amount shall be paid on
the arrearage in order to pay off the arrearage of record, said amount to be agreed upon by the
parties or set by the court through the Domestic Relations action.
All such payments by Husband to Wife shall be deemed alimony, as defined in Section 71
(b) (1) (A) of the Internal Revenue Code as amended, and as said Section is amplified by the
provisions of the Tax Reform Act of 1984 and 'fax Reform Act of 1986, and any fixture laws or
regulations related thereto. Payments from Husband, when received by Wife, shall be deductib:e in
the year of payment by Husband pursuant to Section 215 of the Internal Revenue Code, as
amended, or any similar future laws or regulations thereto, and shall be includable in the year of
receipt in the gross income of Wife pursuant to Section 71 (b) (1) (A) of the Internal Revenue Code,
as amended or any similar future laws or regulations thereto.
9, AP UCAMITY OF - .10 PROPERY TRANSFERS.
The parties hereby agree and express their intent that any transfer of property pursuant to
this Agreement shall be within the scope and applicability of the Deficit Reduction Act of 1984
(hereinafter the "Act"), specifically, the provisions of said Act pertaining to the transfers of
property between spouses and former spouses. The parties agree to sign and cause to be filed any
elections or other documents required by the Internal Revenue Service to render the Act applicable
to the transfers set forth in this Agreement without recognition of gain on such transfer and subject
to the carry-over basis provisions of the said Act,
10, BREACH.
If either party breaches any provision of this Agreement, the other party shall have the right,
at his or her election, to sue for damages for such breach. The party breaching this contract shall be
responsible for the payment of legal fees and costs incurred by the other in enforcing his or her
rights under this Agreement, or seeking such other remedy or relief as may be available to him or
her. The parties specifically acknowledge that they are entitled to utilize the remedies as set forth in
the Divorce Code of 1980, as amended.
11. EL r nlsrt.OSI -
Husband and Wife each represent and warrant to the other that he or she has made a full and
complete disclosure to the other of all assets of any nature whatsoever, and of all other facts relating
to the subject matter of this Agreement to which such parry may reasonably require to make an
informed decision regarding this Agreement.
12. ADDITIONAL INSTRUMENT.
Each of the parties shall on demand execute and deliver to the other any deeds, bills of sale,
assignment, consents to change of beneficiary on in:,urance policies, tax returns and other
documents and do or caused to be done any other act or thing that may be necessary or desirable to
the provisions and purposes of this Agreement. If either party fails on demand is comply with this
provision, that party shall pay to the other all attorneys' fees, costs and other expena°s reasonably
incurred as a result of such failure,
13. WIFE'S DI'1 -
Wife represents and warrants to Husband that since the parties' separation she has not and in
the future she will not contract or incur any debt or liability for which Husband or his estate might
be responsible and -Wjk shall indemnify and save Ilusband harmless from any and all claims or
demands made against him by reason of debts or obligations incurred by her,
14. H SSBA SYS DEBTS.
Husband represents and warrants to Wife that since the parties' separation he has not and in
the future he will not contract or incur any debt or liability for which Wife or her estate might be
responsible and Ilusbarid shall indemnify and save Wife harmless from any and all claims or
demands made against her by reason of debts or obligations incurred by him,
15. W.MN•llZ OF C1,AIMdS AGAINST + SLAT I S.
Except as otherwise provided herein, each party may dispose of his or her property in any
way, and each 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 property or the
estate of the other as a result of the marital relationship, including without limitation, dower, curtsy,
statutory allowance, 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 each will, to the
request of the other, execute, acknowledge, and deliver any and all instruments which may be
necessary or advisable to carry, into effect this mutual waiver and relinquishment of all such
interests, rights and claims,
lb. REPRESENTATION.
It is recognized by the parties hereto that Husband is represented by Courtney L. Kishel,
Esquire, and Wife is represented by John J. Connelly, Jr., Esquire. It is fully understood and agreed
that by the signing of this Agreement, each party understands the legal impact of this Agreement
and further acknowledges that the Agreement is fair and reasonable and each party intends to be
legally bound by the terms hereof.
17. VUI_LT?TARY EXECLJTIO,ly.
The provisions of this Agreement are fully understood by both parties and each party
acknowledges that this Agreement is fair and equitable, that it is being entered into voluntarily and
that it is not the result of any duress or undue influence.
18. ENTIRE A = EEM ,NT.
This Agreement contains the entire understanding of the parties and there are no
representations, warranties, covenants or undertakings other than those expressly set forth herein,
19. PRIOR AGREEMENT.
It is understood and agreed that any and all property settlement agreements which may or
have been executed prior to the date and time of this Agreement are null and void and of no effect.
20. MODIFICATION AND WAIVER.
Any modification or waiver of any provision of this Agreement shall be effective only if
made in writing and executed with the same formality as this Agreement. The failure of either
party to insist upon strict performance of any of the provisions of this Agreement shall not be
construed as a waiver of any subsequent default of the same or similar nature.
21, GOVERNING LAW.
This Agreement shall be governed by and shall be construed in accordance with the laws of
the Commonwealth of Pennsylvania,
22. INDEPENDENT SEPARATE COVENANTS.
It is specifically understood and agreed by and between the parties hereto that each
paragraph hereof shall be deemed to be a separate and independent covenant and agreement.
23, VOID ..ASI,?,
If any term, condition, clause, or provision of this Agreement shall be determined or
declared to be void or invalid in law or otherwise, then only that term, condition, clause or
provision shall be stricken from this Agreement and in all other respects this Agreement shall be
valid and continue in full force, effect and operation.
24, ENTRY AS PART OFD . R
It is the intention of the parties that this Agreement shall survive any action for divorce
which may be instinsted or prosecuted by either party and no order, judgment or decree of divorce,
temporary, final or permanent, shall affect or modify the financial terms of this Agreement, other
than modification of alimony, pursuant to Paragraph 8 this Agreement. This Agreement shall be
made a part of, but shall not merge with, any such judgment or decree of final divorce.
25. DIVOR ACTION.
The parties agree that they will execute all documents necessary to finalize the divorce
action including, but not limited to, the withdrawal of any claims pending under said action,
indexed to number 98-1211, in the Court of Common Pleas, Cumberland County, Pennsylvania, as
well as Affidavits of Consent and Waivers of Counseling and Waivers of Notice of Intention to
Request Entry of a Divorce Decree on February 1, 2002 at which time the documents shall
immediately be processed and the divorce finalized. The purpose of extending the final Decree is to
permit Wife to be eligible for medical insurance coverage without a pre-existing condition,
26. DOMESTIC RELAII NC CODE OFT E CQMMOMALTH OF
PENNSYLVANIA.
Except as specifically provided in this Agreement, each party waives any claim they may
have against the other under the Domestic Relations Code of the Commonwealth of Pennsylvania
including, but not limited to, alimony, alimony pendente lite, counsel fees, costs and equitable
distribution of marital property.
IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have
hereunto set their hands and seals the day and year first above written.
WITNESS:
G
Courtney L. Kis el, Esquire
J. C,onnNly, Jr., Esquire
Susan J. Gaskil
--
COMMONWEALTH OF PENNSYLVANIA
85,
COUNTY OF C;,, r?,,` t r" Cl t! ??
On this, the i- Lday of _??? V"\U 0 l ?_ 2002, before me, a Notary Public,
personally appeared Ronald L. Gaskill, known to me to be the person whose name is subscribed to
the within Property Settlement Agreement and acknowledged that he executed the same for the
purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ACS, t/Ql'Lt?
rte ) LlA A(5,
NOTARY PUBLIC
K::::1
S.S.
On this, the -/& day of - 2002, before me, a Notary Public,
personally appeared Susan J. Gaskill, known to me to be he person whose name is subscribed to
the within Property Settlement Agreement and acknowledged that she executed the same for the
purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
i
NOTARY PUBLI
NOTARIAL SEAL
City of Hummelstown County of Dauphin
My Commission Expires rob. 9 , 2004
TO You AHE NE HE FIY HOTIIIfD t0 HL
TIIE ENCLOSED WITHIN
TWENTY 1T DAYS HAKE VIFP OH
A LT JUUOME MT MAY TIE "I EN R'Nf0
AOAINSNS'r YOU.
By
SUSAN J. GASKILL,
Plaintiff
V,
RONALD L, GASKILL,
Defendant
To the Prothonotary:
LAW 01;1'1('IV
JAMES, SMITH, DURKIN & CONNELLY, LLP
R 0.. Box 690
HERSHEY, PENNSYLVANIA 17133.0590
WE NERERY CENrIFY THAT THE. WITHIN 15
A TRUE AND COHIIECT COPY OF TIIE
ORIGINAL FILED IN 51119 ACTION.
HY
AIIONN[Y IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 98 - 1211 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
PRAEQ TO TT ANSMI'T RFC.012D
'T'ransmit the record, together with the following information, to the Court for entry of a
Divorce Decree:
1. Ground for divorce: irretrievable breakdown under Section (XX) 3301(e) ( )
3301(d) of the Divorce Code.
2. Date and manner of service of the Complaint: June 22, 1998 by personal service on
the Defendant,
3• Complete either paragraph (a) or (b),
(a) Date of execution of the Affidavit of Consent and Waiver of Counseling
required by Section 3301(c) of the Divorce Code: by Plaintiff: February 13, 2002 by Defendant:
January 4, 2002.
(b) (1) Date of execution of the plaintiffs, Affidavit required by Serlion 3301(d) of
the Divorce Code:
(2) Date of service of the Plaintiffs Affidavit upon the Defendant:
4. Related claims pending: All claims of record have been resolved and settled pursuant to
a property Settlement Agreement dated February 13, 2002.
5. Date and manner of service of Notice of Intention to file Praecipe to
Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301(d)
of the Divorce Code:
or, date of execution of Waiver of Notice of Intention to Request Entry of a Divorce Decree
under Section 3301(c) of the Divorce Code: by Plaintiff: February 13, 2002; by Defendant:
January 4, 2002.
and, date of filing of the Waiver of Notice of Intention to Request Entry of a Divot-cc
Decree: Plaintiffs Waiver is being filed simultaneously with this Praecipe; by Defendant: January
16, 2002,
JAMES, SMITH, DURKIN Sc CONNELLY LLP
Date: A Dl - ??
J n J. Connell , Jr., rsquire
tto e for Pla, )tiff
O ce 13 650
Hershey, PA 17033
(717) 533-3280
PA I,D, No, 15615
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TO ...._._.._.__._.-__.._....___
YOU ARE HEREBY NOTIFIED TO PLCAD YO
THE ENCLOSED WITHIN
TWENTY 1201 DAYS OF SERVICE HEREOF OR
A DEFAULT IIIOOMENT MAY EE ENTERCC
AOAINST YOU
Er
glONNEY
SUSAN J. GASKILL,
Plaintiff
V.
RONALD L. GASKILL,
Defendant
LAW 019ICP
JAMBS, SMITH, DuRKIN & CONNELLY
I'. (). IRA 0511
HHRSIIFY, PENNSYLVANIA I1033-M50
WE IIEREDY CCRTIFY THAT 111[ WITHIN IS
A TRUE AND CORRECT COPY OF THE
ONIOIHAL FILED IN THIS ACTION.
ARONNFv
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. t4 L
CIVIL ACTION - LAW
IN DIVORCE
NOTICE
You have been sued in Court. If you wish to defend against the claims set
forth in the following papers, you must take prompt action, You are warned that if
you fall to do so, the case may proceed without you and a Decree in 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 theso 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 the Cumberland County Court House,
One Courthouse Square, Carlisle, Pennsylvania,
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Phone; (717) 249-3166
SUSAN J. GASKILL,
Plaintiff
V.
RONALD L. GASKILL,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
VLQMj QF AVAILABILITY OF Q UNSELJ
To the Within Named Defendant:
You have been named as the Defendant in a divorce proceeding filed in the
Court of Common Pleas of Cumberland County. This notice is to advise you that in
accordance with Section 3302(4) of the Divorce Code, you may request that the
Court require you and your spouse to attend marriage counseling prior to a divorce
decree being handed down by the Court, A list of professional marriage counselors
is available at the Office of the Prothonotary, One Courthouse Square, Carlisle,
Pennsylvania. You are advised that this list is kept as a convenience to you and you
are not bound to choose a counselor from this list, All necessary arrangements and
the cost of counseling sessions are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling
within twenty (20) days of the date on which you receive this notice. Failure to do
so will constitute a waiver of your right to request counseling.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO,
Prothonotary
i
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SUSAN J, GASKILL, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
t.
V. NO.
RONALD L. GASKILL, CIVIL ACTION - LAW
Defendant IN DIVORCE
CAIN-T-UNDER SECTl4N_a3-0-'1_
OF THE DIVORCE CODE
1. Plaintiff is Susan J, Gaskill, who currently resides at 3522 Beech Run
Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055,
2. Defendant Is Ronald L, Gaskill, whose last known address is 217 Glenn
Road, Camp Hill, Cumberland County, Pennsylvania 17011,
3, Plaintiff and Defendant have been bona fide residents in the S
Commonwealth for at least six months immediately previous to the filing of this I
Complaint,
4. Plaintiff and Defendant were married on April 12, 1975 In Milford,
Oakland County, Michigan.
5. There have been no prior actions for divorce or annulment between the
parties,
6. The Plaintiff is a citizen of the United States of America,
7. The Defendant is not a member of the Armed Services of the United
States of America or its Allies,,
8. The marriage is irretrievably broken, i
9. The Plaintiff has been advised of the availability of counseling and that
i._
the Plaintiff may have the right to request that the Court require the parties to
participate in counseling.
10, The parties to this action have been separated since November 17, 1996.
11. Plaintiff requests the Court to enter a Decree in Divorce,
COUNT II
COMPLAINT UNDER SECTION _ 3
OF THE DIVORCE CODE
12, Plaintiff avers that she is the innocent and injured spouse, and that the
Defendant has offered such Indignities to the Plaintiff so as to render her condition
intolerable and life burdensome,
13. This action is not collusive.
COUNT III
CLAIM FOR EQUITABLE DISTRIBUTION OF?_RITAL PROPERTY
QNDER 6ECTION 3,502 OF THE DIVORCE ODE
14. Plaintiff and Defendant are the owners of various personal property,
motor vehicles, bank accounts and insurance policies acquired during their marriage
which are subject to equitable distribution by this Court,
COUNT IV
CLAIM FOR ALIMONY UNDER SECTION 3701 OF THE DIVORCE CODE
15, Plaintiff is presently unemployed due to disability,
16, Plaintiff is unable to support herself through appropriate employment,
17. Plaintiff lacks sufficient property and income to provide for her reasonable
needs,
COUNT
CLAIMOR ALIMONY_FIILENTE LITE COUNSEL FEES AND EXPE SES
N E _SECTI N 702 OF THE 113110ORCE CODE
18. Plaintiff does not have sufficient funds to support herself and pay the
counsel fees and expenses incidental to this action,
19. Defendant is full and well able to pay Plaintiff alimony pendente
lite, counsel fees and expenses incidental to this divorce action,
WHEREFORE, the Plaintiff requests the Court to enter a Decree:
a. dissolving the marriage between the Plaintiff and Defendant;
b. equitably distributing all property owned by the parties hereto;
C. directing the Defendant to pay alimony to Plaintiff;
d. directing the Defendant to pay alimony pendente lite Plaintiff's counsel
fees and the cost of this suit; and
e, for such further relief as the Court may determine equitable and just.
Date;
Harrisburg, PA 17101
(717) 238-4776
PA I.D, No. 15615
JAMES, SMITH, DURKIN & CONNELLY
By:
John .Conn ly, Jr„ Esquire
Attor ey IIf?o??r PI 'ntiff
1.08=112 tNalnu Street ____
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VERIFICATION{
I verify that the statements made in this Pleading are true and correct, I I j
understand that false statements herein are made subject to the penalties of 18 Pa,
C.S. Section 4904, relating to unsworn falsification to authorities, j
g o3JCl.?i_? ?J v? l rll 1
Date;
-- Susan J, Gaskill, Plaintiff
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YOU AGE HEREBY NOTIFIED TO PLEAD TO
THE ENCLOSED WITHIN
1WENTY 1201 DAYS OF SERVICE arNEOF OG
A DEFAULT JUDOMENT MAY BE ENTrnEG
AGAINST YOU
BY .......
___.-_.
ArroRN[Y
SUSAN J. GASKILL,
Plalntiff
V.
RONALD L. GASKILL,
Defendant
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF RUCKS
NO, 98 1211 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
SS.
1
AND NOW, this, ,L, ,, day of 1998 personally
I
appeared before me, a Notary Public In and for the State and County aforementioned,
vi.ncent Dartt , who, being duly sworn according to law, deposes and
says that a copy of the Complaint in Divorce in the above-captioned action was
served on the Defendant, Ronald L. Gaskill, at 403 s Mai n Rrreel . APr.2oi rj_,
Doylestown ,Pennsylvania, on the 21st dayof June
1998, at 3:15 _ P. m. by personal hand delivery!-)
Sworn to and Subscribed to
before me this "rday
of =e=-, 1998.
p ,I
Notary PubliC
N01,001 9891
( Kathlann Aallaco, Notary Publlo
Doylestown tiara, Ducks County
O9gvnlsslnn L Yniros July 26, 1999
LAW OPPICE
JAMES, SMITH, DURKIN & CONNELLY
WE "EGEBY CE.RrIFY THAT THE WITHIN 10
A THUS AND CORRECT COPY OF THE
ORIGINAL FILED IN THIS ACTION.
P. 0. 110X 650
Artoxecv
HIiNSIII!Y, PENNSYLVANIA 17033-0630
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
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SUSAN ,I, GASKILL, : IN TI If? COURTOf COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 98 - 1211 CIVII, THRM
RONALD I,. GASKILL, : CIVIL ACTION - LAW
Defendant : IN UIVORCIi
PLAINTIFF'S AFFIDAV 'r )F C'ONSI?N.1,
AN 1) WAIVEIt 0Fk'-0JA I?LEYS
A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
March 5, 1998.
2. The marriage of the Plainti11'and Defendant is irretrievably broken, and ninety days
have elapsed from the date of both the filing and service of the Complaint.
3, 1 consent to the entry or a Baal decree ofdivorce alter service of Notice of Intention
to request entry of tile Decrec.
4. I have been advised of the availability of marriage counseling, and Understand that I
may request that the Court require that my spouse and 1 participate in cowiSCling. I further
Understand that the Court maintains a list of marriage counselors in the Prothonotaty's Office,
which list is available to me upon request, lacing so advised, l do not request that the Court require
that my spouse and I participate in counseling prior to it divorce decree being handed down by the
Court.
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,A, Section 4904, relating to
unswom falsification to authorities.
Date:
c' \ ll Y
Susan J. Gaskill, Plaintiff
_ are
f. ?,
SUSAN J, GASKILI„ : IN'rl IF, COURTOP COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, ITNINSYLVANIA
V. :NO. 98 -- 1211 CIVIL TOW
RONALD L, GASKILL,
Defendant
CiVII, ACTION - LAW
IN DIVORCE
AIVEIR 'I'ICI,' OF IN'I'EN'I'ION'I'O RI?QUI?S'r I?N'1'RY )( I? A 1)1VOI2(.'E
1. 1 consent to the entry oI'a lintel Decree of Divorce without notice.
2, 1 understand than I may lose rights concerning alimony, division of property,
lawyer's fees or expenses ii' l do not claim them before a divorce is granted.
3. 1 understand that I will not he divorced until a Divorce Decree is enteral by the
Court aind that a copy of the Decree will he sent to nc inunediatcly alter it is file([ With the
Prothonotary.
verify that the statements made in this Aflidavit arc true and correct, I understand that
false statements herein are made subject to the penalties of 18 Pa. C,S,A. Section 4904, relating to
unsworn falsification to authorities.
Datc: ,?--
Susan J. Ciaskill, Plamtit't
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTV, PF.NNSVLVANIA
SUSAN J. GASKILL, )
Plaintiff )
V. )
)
RONALD L. GASKILL )
Defendant )
NO. 98-1211 CIVIL TERM
IN DIVORCE
DEFENDANT'S AFFADAVIT UNDER SECTION 3301(d)
OF THE DIVORCE CODE
The parties to this action separated on November 17, 1996 and have continued to
live separate and apart for it period of at least two years.
2. The marriage is irretrievably broken.
3. 1 understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if 1 do not claim them before a divorce is granted,
I verify that the statements made in this affidavit are true and correct. I understand
that false statements herein are made subject to ih enalties of 18 Pa.C,S. §4904
relating to unsworn falisification to authorities
Date; _ % 04V Z
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IN THE COURT OF COMMON PLEAS
CUMIIERI.,AND COUNTY, PENNSYLVANIA
SUSAN J. GASKILL,
plaintiff ) NO. 98-1211 CIVIL TERM
v. )
IN DIVORCE
RONALD L. GASKILL )
Defendant )
DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. 1 consent to the entry of a final decree of divorce without notice.
2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if 1 do not claim them before a divorce is granted.
3. 1 understand that I will not be divorced until a divorce decree is entered by the Court
and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. 1 understand that
false statements herein are made subject to the}>enalties of 18 Pa. S. Section 4904 relating to
unsworn falsification to authorities. 1 7
Date,
R nald L, ;askill (Defendant)
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To LAW OFFICE
----- YOU ARE N[R[SY NOTIFIED TO PLEAD TO WE NCRCEV CERTIFY THAT THE WITHIN IS
_. A TRUE A CORRECT COPY or THE
THE [D 00 ---' JAMES, SMITH, DIJRKIN & CONNELLY!, :1 ?'
TWENTY I]01 DAVE OF SERVICE HEREOF EOF OR ? ORIGINAL FILED IN IN THIS S ACtION.
A DEFAULT JUDGMENT MAY SE ENTERED P. (I BOX 650
AGAINST YOU. DY - - -----
HERSHEY, PENNSYLVANIA 17133-0650 Anan4ev
`ATORNLY '
SUSAN J. GASKILL, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO, 98 - 1211 CIVIL TERM
RONALD L. GASKILL, CIVIL ACTION - LAW
Defendant IN DIVORCE
TO THE PROTHONOTARY:
Please withdraw the claims for Equitable Distribution, Alimony, Alimony Pendente
Lite, Counsel Fees, Costs and Expenses in the above-captioned divorce action,
JAMES, SMITH, DURKIN & CONNELLY LLP
Date: 3 "e) u J _ By:
J hn Conne , Jr„ Esquire
ttorn for PI 'ntiff l
POS fficel3ox 650
Hershey, PA 17033
(717) 533-3280
PA LD, No, 15615
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ti IN THE COURT O1 COMMON PLEAS OF
SUSAN J.GASKILL CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff CIVIL ACTION - 1AW
VS. : NO.9K- 1211 CIVI.I, 19
IN DIVORCE
RONALD L, OASKILL
Defendant
STA'CUS SIHs'E'1'
DATE: ACTIVITIES;
v-d
- L'-? lil?l X11 ?C`ll?S _
1 v('111?16 S `11a'1t /ysri> f?11??r/1`t11? ja{1
f 1 l l0 1? 1 Ctt? ?1J) I Y1'1. 4(1 s Z At9e
SUSAN J. GASKILL, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
Vs: NO, 98 - 1211 CIVIL
,
RONALD L. GASKILL, ;
Defendant ; IN DIVORCE
T0; John J. Connelly; Jr, Attorney for Plaintiff
Richard C. Gaffney Attorney for Defendant
DATE; Friday, June 29, 2001
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed,
OR IF DISCOVERY IS NOT COMPLETE;
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
['11
Y
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery,
DATE COUNSEL FOR PLAINTIFF ( )
COUNSEL FOR DEFENDANT ( )
NOTE PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF' PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR. OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING; THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION, HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RE'T'URNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
J4Ni(:5 $\II I I I IX ?.RKIN )NNI I I,r I.I I'
John J.('annully"Ir.
JJeJr(eJx[Ilugnl-cnm
Pobruary 15, 2002 iI
E. Robert Elicker, 111, Esquire
Cumberland County Divorce Master
9 North Hanover Street }
Carlisle, PA 17013
Re: Susan J. Gaskill v. Ronald L. Gaskill
`
No. 98 - 1211 Civil Term
i
Dear Mr. Elicker: iF.
Crow
Enclosed you will find two fully executed copies of the Property Settlement i";,t S MI I?
Agreement in the above-referenced matter, c????r?or? ,. J„_
J
YFvm
is HT A Im 111-f 11 ('K
It is my understanding you will have the Master's appointment vacated and will O;1;wfi, K. Pocrinnrv
Pocjo(,[
notify us when that is completed. I will then forward the necessary paperwork to finalize ,?" NI K115
the divorce action. of MA"
() ui.•wNI M,uiy
Fnsinno F'. S[.nnf:n
N, I[ W. Ywui
Very trui 'ours, HE FINAROA HIM Jn.
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,?t [,ouHS,ei
Atj[npr w NI HnBHi>1
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Johl J. Connelly, Jr. i
JJC;jlk
cc: Courtney L. Kishel, Esquire
Susan J. Gaskill
Enclosures [
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OFFICE OF DIVORCE MASTER
CUMBERLAND 000NI Y
COURT OF COMMON P1 FAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240-6535
E. Robert Elicker, 11
Divorce Master
Traci Jo Colyer
office Manager/Reporter
West Shore
6970371 Ext. 6535
October 8, 2001
John J. Connelly, Jr., Esquire
JAMES, SMITH, DURKIN Et CONNELLY
P.O. Box 650
Hershey, PA 170330650
Richard C, Gaffney, Esquire
2120 Market Street, Suite 101
Camp Hill, PA 17011
RE: Susan J. Gaskill vs. Ronald L. Gaskill
No. 98 - 1211 Civil
In Divorce
Dear Mr. Connelly and Mr. Gaffney:
Mr. Connelly indicated that he needed financial information from the
Defendant and that the discovery requested should take approximately sixty
days. Mr. Connelly's discovery certification document was dated July 9, 2001,
Mr. Gaffney has indicated that discovery is complete.
A divorce complaint was filed on March 5, 1998, raising grounds for
divorce of irretrievable breakdown of the marriage and indignities, I am going
to assume that grounds for divorce are not an issue and that the parties will
either sign affidavits of consent or have been separated for a period in excess
of two years.
The complaint also raised economic claims of equitable distribution,
alimony, alimony pendente late, and counsel fees and expenses,
In accordance with P.R.C.P. 1920.33(b) I am directing each counsel to
file a pretrial statement on or before Friday, November 2, 2001. Upon receipt
of the pretrial statements, I will immediately schedule a pre hearing
Mr. Connelly and Mr'. Gaffney, Attorneys at Law
8 October 2001
Page 2
conference with counsel to discuss the issues and, if necessary, schedule a
hearing.
Very truly yours,
E. Robert Flicker, II
Divorce Master
NOTE; Sanctions for failure to file the pretrial statements are set
forth in subdivision (c) and (d) of Rule 1920.33.
THE ORIGINAL PRETRIAL STATEMENT SHOULD BE FILED
IN THE MASTER'S OFFICE AND A COPY SENT DIRECTLY
TO OPPOSING COUNSEL.
FAILURE TO FILE PRETRIAL STATEMENTS AS DIRECTED
BY THE MASTER MAY RESULT IN THE MASTER'S
APPOINTMENT BEING VACATED,
JUL Z 6 20D?
SUSAN J. GASKILL, IN THE. COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs, s NO. 98 - 1.211 CIVIL
;
RONALD L. GASKILL, o
Defendant ; IN DIVORCE
T0; John J. Connelly, Jr. Attorney for Plaintiff
Richard C, Gaffney Attorney for Defendant
DATE; Friday,, June 29, 2001
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE;
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
SEE ATTACHED.
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(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery,
= ATTACHED.
WU? F DATE FOR PLAINTFF ` FOR DEFEND T (? i
NOTE; PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOV.ERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PART`i NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL, BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO ('l) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
Itc; Gaskill v, Oaskill
(a) _I.n order to complete discovery, the Dclbndant must supply existing financial
infirrmation including most recent lax returns, income inlormation and the status ol,existing
marital assets,
(b) Discovery of this information should take approximately sixty (GO) days.
JUL 1. 2 2001
SUSAN J. GASKILL, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO, 98 - 1211 CIVIL
RONALD L. GASKILL,
Defendant IN DIVORCE
TO: John J. Connelly, Jr. Attorney for Plaintiff
Richard C. Gaffney Attorney for Defendant
DATE: Friday, June 29, 2001 .
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE :
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions,
i
1
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery,
ATE C UNSEL FPLAINTIFF
NOTE:
COUNSEL F DEFENDANT ( vI
PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE; THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF' BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE; ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
SUSAN J. GASKILL,
Plaintiff ) NO. 98-1211 CIVIL TERM
V. )
IN DIVORCE.
RONALD L. GASKILL )
Defendant )
DEFENDANT'S MOTION
FOR APPOINTMENT OF MASTER
AND NOW, this 20°i day of June 2001, comes Ronald L. Gaskill, Defendant, by
and through his attorneys, TttE LAW Ot>riccs of RictiARD C. GAFFNEY, who moves the
court to appoint a master with respect to the following claims:
(X) Divorce (X) Distribution of Property
( ) Annulment O Support
(X) Alimony ( ) Counsel Fees
( ) Alimony Pendente Lite ( ) Costs and Expenses
and in support of this motion states:
1. Discovery is complete as to the claims for which the appointment of a master
is requested.
2, The plaintiff has appeared in the action by her attorney, John J. Connelly, Jr.,
Esquire.
3, The statutory grounds for divorce are 23 Pa.C.S. §3301(a), (c), and (d).
4. The action is contested with respect to equitable distribution of marital
property and alimony.
5. The action does not involve complex issues of law or fact.
6. The hearing is expected to take approximately one-half day,
Court to appoint a ??astcr
ectfully reyttcsts the
the pefcndant resp erty and alimony.
WNRprOR of the Prop
with respect to divorce, distribution
Submitted.
Respectfully
yhel, EsQuire
CourtneY for fcndant
pate Attorney f C. GAPFNGv
TNt: LAw OPFtcrs Op RicttARn
Suite 101
2120 Market Str 11011
Camp 13111, P 11.915.9033
Tcwhope'
Y
OF SrIMCF.
CFR'1'IFICATE
COPY of
cc ,"y that 1 am serving a true and correct
1 Kishel, Esquire, hereby " hire, couns
1, Courtney Connelly, Jr„ Gsq
Motion for APP el for plaintiff,
ointment of Master on John J hin County, PA 17033, by
whose office is located at P.O. pox 650, Hershey, pauP Prepaid, on this 20th day
depositing a copy of the same in the United Stales mail, postage
of June 2001, addressed as above,
IN THE COURT OF COMMON PLEAS
('UMBERLAND COUN'T'Y, PENNSYLVANIA
SUSAN if. GASKILL, )
Plaintiff ) NO. 98-1211 CIVIL TERM
)
V.
IN DIVORCE
RONALD L. GASKILL
Defendant )
ORDER OF COURT
'ILL
AND NOW, this day of'. ` ?ta-- , 2001, Robert Flicker, Esquire, is
appointed master with respect to the following claims: Divorce, Fquitable Distribution of
Property, and Alimony.
By the Court:
j 11?n44^N
P .J.
SUSAN J. GASKILL, )
Plaintiff ) NO. 98-1211 CIVIL TERM
V. )
IN DIVORCE
RONALD L. GASKILL )
Defendant )
DEFENDANT'S MOTION
FOR APPOINTMI, NT OF MASTER
AND NOW, this 20"' day of,lune 2001, comes Ronald L. Gaskill, Defendant, by
and through his attorneys, fm;, LAW 0H ACES of RICHARD C, CAFFNFY, who moves the
court to appoint a master with respect to the following claims:
(X) Divorce (X) Distribution of Properly
( ) Annulment ( ) Support
(X) Alimony ( ) Counsel Fees
( ) Alimony Pendente Lfte ( ) Costs and Expenses
and in support of this motion states:
I. Discovery is complete as to the claims for which the appointment of a master
is requested.
2. The plaintiff has appeared in the action by her attorney, John .1. Connelly, Jr.,
Esquire.
3. The statutory grounds for divorce are 23 Pa.C,S. §3301(a), (c), and (d).
4. The action is contested with respect to equitable distribution of marital
property and alimony.
5. The action does not involve complex issues of law or fact,
6. The hearing is expected to take approximately one-half day,
WI IERFFORE, the Del'cndatit respectfully requests the Court to appoint a master
with respect to divorce, distribution of the property and alimony.
Respectfully Submitted,
Date; LLui u ? I t LL`:
? X---
Courtney L. shcl, Esquire
Attorney lbr 1 ?lcndant
'fill: LAW OFFICBS OI' RICIIARD C• GAFFNEY
Suite 101
2120 Market Street
Camp Hill, PA 17011
"Telephone: 717.975.9033 `
,1.
l?
I
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f
I
I
i
'
CER,m cA'm OF SERVICE,
I, Courtney L, Kishel, Esquire, hereby certify that I am serving a true and correct copy of
Motion for Appointment of Master on John J.Connelly, Jr., Esquire, counsel for Plaintiff,
whose office is located at P.O, Box 650, Hershey, Dauphin County, PA 17033, by
depositing a copy of the same in the United States mail, postage prepaid, on this 20th day
of June 2001, addressed as above.
l(
. t` ?24IZ4, J( e_ .
Courtney L. Ki,hel, Esquire
Attorney for Defendant
I
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t?.
-
1.1 I.I
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' _ ) .
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SUSAN J. GASKILL I IN THE COURT OF COMMON PLEAS OF
V : CUMBERLAND COUNTY, PENNSYLVANIA
RONALD L. GASKILL
: NO. 98-1211 CIVIL TERM
ORDER 211, COURT
AND NOW, this 7 14h day of OCTOBER, 1998, upon
consideration of the attached Motion to Stay Divorce Action, IT
IS ORDERED AND DIRECTED AS FOLLOWS:
(1) A Rule is issued against Defendant to show cause why the
requested relief should not be granted.
(2) Defendant shall file an answer to the Motion within
fifteen (15) days of service.
(3) The Motion shall be decided under Pa. Rule of Civil
Procedure 206.7.
(4) Any depositions shall be completed within thirty-five
(35) days of this order..
(5) Briefs shall be filed in chambers and argument shall be
held on FridA...
of the Cumberland County Courthouse, Carlisle, pa.
(6) Notice of the entry of this order along with a copy of
the Motion shall be provided to all parties by Plaintiff.
Jeannie E. Friday, Esquire By the ourt,
410 Old York Rd.
Jenkintown, Pa. 19046
CLJ2l.t d -ASlw?-t?
John J. Connelly, Jr., Es u a yy
P.O. Box 650 q Edward E. Guido, Judge
Hershey, Pa. 17033
:sld
f
v
IA
I
To LAW OFFICE
YOU ARE H[R[BY NOT 'VIED TO PLEAD TO
THE ENCLO490 WITHIN JAMES, SMITH, DURKIN & CONNELLY
TWENTY 1201 DAY[ OF SERVICE NFRT N
A DEFAULT JUDGMENT MAY OF ENTERED
AGAINST YOU P. O. BOX 650
By
ATTORNEY FIERSHR, PENNSYLVANIA 170370650
WE HEREBY CERTIFY TIIAT rH[ WITHIN H
A TRUE AND CDRMECT COPY OF THE w_
ORIOINAL PILED IN THIS ACr1IICT
• 11 ?I ?
BY ..
ATTORNEY
SUSAN J, GASKILL, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 98-1211 CIVIL
RONALD L. GASKILL, CIVIL ACTION - LAW
Defendant IN DIVORCE
ORDER
AND NOW, this day of 1998, upon consideration
of the foregoing Motion to Stay Divorce Action Filed by Plaintiff Pursuant to Pa,R,C,P.
1920,6, it is hereby ORDERED and DECREED that an Order is hereby entered directing
that the divorce action filed by Defendant, Ronald L. Gaskill, in Bucks County,
Pennsylvania be stayed pending final determination of the divorce matter in
Cumberland County, Pennsylvania,
BY THE COURT:
J. ?I
distribution:
Jeannie E. Friday, Esquire, 410 Old York Road, Jenkintown, PA 190461
John J, Connelly, Jr., Esquire, P.O. Box 650, Hershey, PA 17033
SUSAN J. GASKILL,
Plaintiff
V.
RONALD L. GASKILL,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 98-1211 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
MOTION TO STAY DIVORCE ACTION
FILED BY PLAINTIFF PURSUANT TO.PA.R.C.P. 1920.6
AND NOW COMES, the Plaintiff, Susan J, Gaskill, by and through her attorney,
John J, Connelly, Jr„ Esquire, and files the following Motion to Stay Divorce Action
Filed by Plaintiff Pursuant to Pa.R.C.P, 1920,6, and in support thereof, avers as
follows:
1. On March 5, 1998, Plaintiff, Susan J. Gaskill, filed a Complaint in Divorce
in the Court of Common Pleas of Cumberland County, Pennsylvania containing five (5)
counts averring that the marriage is irretrievably broken and the that the parties have
been separated since November 17, 1996.
2. The Defendant, Ronald I., Gaskill, avoided service of the Divorce
Complaint and said Complaint had to be reinstated on two occasions, on May 5, 1998
and again on June 17, 1998, and was subsequently served on the Defendant on June
22, 1998,
3, On March 24, 1998, Defendant, Ronald L. Gaskill, filed a Complaint in
Divorce in the Court of Common Pleas of Bucks County, Pennsylvania, alleging the
marriage is irretrievably broken,
4. Pennsylvania Rule of Civil Proceduro 1920.6 provides that "if, within
ninety (90) days of service of the Complaint, a second action is brought in another
county and one of the two counties is the county in which the last family domicile
was located and in which one of the parties continues to reside, the court of the
county of the last family domicile shall determine, based upon the purposes of the
Divorce Code, which of the two actions shall be stayed and which shall proceed".
5. The Cumberland County Court of Common Pleas retains jurisdiction to
determine which of the two actions shall be stayed and which shall proceed for the
following reasons;
A. Ronald L. Gaskill filed his Divorce Complaint in Bucks County within
ninety (90) days of service of Susan J. Gaskill's Divorce Complaint which was filed
in Cumberland County, Pennsylvania.
B. The last family domicile of the parties was 3522 Beech Run Lane,
Mechanicsburg, Pennsylvania 17055,
C. Susan J, Gaskill continues to reside with the parties' children at the
marital residence at 3522 Beech Run Lane, Mechanicsburg, Pennsylvania 17055.
D, Ronald L. Gaskill resided in Cumberland County, Pennsylvania until
February of 1998, when he moved to Doylestown, Bucks County, Pennsylvania,
E. With the exception of Ronald L. Gaskill's pension, all of the marital
estate is located in Cumberland County, Pennsylvania,
F. Ronald L. Gaskill's filing of a Divorce Complaint in Bucks County,
Pennsylvania will result in a waste of judicial time and facilities as well as increasing
the burden and expense to Susan J. Gaskill, who Is on disability. This is contrary to
one of the purposes of the Divorce Code which is to "effectuate economic justice
between the parties who are divorced, separatod...and to ensure a fair and just
determination in settlement of their property rights." 23 Pa.C.S.A. §3102(A)(6).
G. On April 20, 1998, counsel for Susan J. Gaskill, John J. Connelly,
Jr., Esquire, sent a letter to Defendant's counsel, Caron P. Graff, Esquire, advising the
Mr. Gaskill avoided service and that jurisdiction was clearly in Cumberland County,
Pennsylvania. As of the date of this Motion, Defendant has riot withdrawn his
Complaint in Divorce in Bucks County, Pennsylvania.
WHEREFORE, Plaintiff, Susan J. Gaskill, respectfully requests that your
Honorable Court enter an Order directing that the divorce action filed by Defendant,
Ronald L. Gaskill, in Bucks County, Pennsylvania be stayed pending final determination
of the divorce matter in Cumberland County, Pennsylvania.
Date: 1 I? ?1 11 K By:
Respectfully submitted,
JAMES, SMITH, DURKIN & CONNELLY
J
tt ney for Plaintiff
Post fice- ox 656,_._
Hershey, PA 17033
(717) 533-3280
PA I.D. No. 15615
VERIFICATION
John J, Connelly, Jr„ Esquire, represents that he is the attorney for the Plaintiff,
Susan J. Gaskill, In this case and is familiar with the facts concerning the parties, and
that due to the unavailability of the Plaintiff, he verifies that the statements made in
the foregoing Motion to Stay Divorce Action Filed by Plaintitf Pursuant to Pa.R.C.P.
1920.6 are true and correct. Ile understands that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification
to authorities.
Date; q ! , I
SUSAN J, GASKILL,
Plaintiff
V.
RONALD L, GASKILL,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 98-1211 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
CERTIFICATE OF SERVICE
I, John J, Connelly, Jr„ Esquire, of James, Smith, Durkin & Connelly, attorney
for the Plaintiff, Susan J. Gaskill, hereby certify that I have served a copy of the
foregoing Motion to Stay Divorce Action Filed By Defendant Pursuant to Pa.R,C,P.
1920.6 on the following on the date and in the manner indicated below:
PERSONAL HAND DELIVERY
Jeannie E. Friday, Esquire
Akbari & Graff
410 Old York Road
Jenkintown, PA 19046
DATE: I` _ By:
JAMES, SMITH, DURKIN & CONNELLY
Jo n J: Com elly, Jr., Esqu
Att rn?y for laintiff l
'Post Office box 650
Hershey, PA 17033
(717) 533-3280
PA I,D, No, 15615
9
r
TO LAW OFFICE
YOU ANL NLNL9Y NOTIPILOTO PLLAO TD
THE ENCLOSED WITHIN
TWENTY TY 120) DAYS OF SLAV CL HEREOF 1
HEREOF ON JAMES, SMITH DURKIN & CONNELLY HIM98Y CERTIFY
CONNECT THAT COTHE PYWITHIN THE
A DEFAULT JUOOML11P1?tKNT9!IED ?^, WIAINSFII,ED IN THIS ACTION.
AOAINLT YOU 11. O, BOX 650
NY
LY _?__?_ __._. ? ATTONNfYJ^ •^?
nDAUfY - HERS11EY, PENNSYLVANIA 17033-0650
SUSAN J, GASKILL, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 98 - 1211 CIVIL
RONALD L. GASKILL, CIVIL ACTION - LAW
Defendant IN DIVORCE
AECIPE
i
Please reinstate the above-captioned divorce action on behalf of the
Plaintiff, Susan J, Gaskill,
JAMES, SMITH, DURKIN & CONNELLY t
Date: By:
h J. C nn Ily, Jr., Esqui
A for ey fbr- laintiff \
10$=112 Walnut Street _
Harrisburg, PA 17101
(717) 238-4776
PA LD, No, 15615
1
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c,
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F
TO LAW OFFICE
YOU ARE HERESY NOTIFIED TO PLEAD TO WE HERESY CERTIFY THAT THE WITHIN 19
INS ENCLOSED WITHIN JAMES, SMITH, DURKIN & CONNELLY A TRUE AND CORRECT COPY OF THE
TWENTY 1201 DAYS O A[1ILVIC[ HEREOF OR A011Wrm...•PIL(D IN THIS ACTION.
A DEFAULT JUD6MEH ENTERED -[)-.'BOX 650
AOAINRT YOU. EY ----
`ATiOAN[Y
SY erroRNiY HERSHEY, PENNSYLVANIA 17033.0650
SUSAN J. GASKILL, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v, NO. 98 - 1211 CIVIL
RONALD L, GASKILL, CIVIL ACTION - LAW
Defendant IN DIVORCE
PRAECIPE
Please reinstate the above-captioned divorce action on behalf of the
Plaintiff, Susan J. Gaskill,
JAMES, SMITH, DURKIN & CONNEL.LY
Date: By; *
l y, Jr., E
intiff
Atto
108-112 Walnut Street
Harrisburg, PA 17101
(717) 238-4776
PA I,D, No, 15615
ti
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`if ev?
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cys . (bill ('1;-,C.:fr,""-,
NANCY AKIIA NI. 4:N W.'
CA 144 IN I t ONA F'P, NNU. r '
,INANNIM.. R, MNIHNY. NNU.
' AIA11 A HM IT 1'NI I TO N Y IIA If
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410(11,11 YANK NIIAII
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IV 16. 1179.11 WIN
FAX 191IN 1179-NJ 71
November 5, 1998
VI F AND FIRST CLASS MAIL
#71.7-240-6462
The Honorable Edward Guido
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013-3387
Res Gaskill v. Gaskill
PACSES Case Number 901100370
Dear Judge Guido:
I'1111.AUNLPINA nMMICN,
WIIAAAAI PNNN IIUI IH4:
A01'IYU UIS
111111(III NN'1'NI IT AT
1'IIII.A„ PA 111103:1401
ly 1 M1I MIN-M1NM1II
Enclosed please find a time-stamped copy of our Praecipe to
Withdraw the Divorce Complaint in Bucks County in the above-
referenced case. Also enclosed is a copy of our letter dated
October 20, 1998 to the Prothonotary of Cumberland County.
Therefore, we request that the hearing in the above-referenced
matter scheduled before your Honor on November 13, 1998 be,
cancelled.
Respectfully submitted,
CARON P. GRAFF
CPG/je
Enclosures
cc: John J. Connelly, Jr., Esq.
Ronald Gaskill
AKBARI & GRAFF
BY: Caron P. Graff, Esquire Attorney for Plaintiff
Attorney I.D. No. 48043
410 Old York Road
Jenkintown, PA 19046 }.
(215) 572-6868
?t
IN THE COURT OF COMMON PLEAS OF BUCKS COUNTY, PENNSYLVANIA
FAMILY DIVISION
RONALD L. GIASKILL r NO. A0698-60998-D-22
403 South Main Street :
Apt. H-201 s
Doylestown, PA 18901 :. i
S.S. # 108-44-9142 s
Vs. s
s
SUSAN L. OASKILL :
3522 Beech Russ Lane s
Mechanicsburg, PA 17055 s
S.S. # 380-48-3598 s IN DIVORCE
PRAECIPE TO
WITHDRAW DIVORCE COMPLAINT i
TO THE PROTHONOTARY:
Kindly withdraw the Divorce Complaint filed in the above-
captioned matter on March 24, 1998.
RespecEfully submitted,
. 64?'? Aw& I
CARON P. GRAFF, IRE
Attorney for Pla !tiff
IY Vii.
AKBARI & G12AP'P
NANCY AKRARI, XSO.• LAW o1P.FI010
CARON P ORA". Ea, UO OLD YORK ROAD JA
- PI
LPIIIAOY'PICB,
JEANNIE C. FRIDMY, lraQ.
JKNKIN TOW N. PA I9046 U
M
WILLIAM PAWN IIOVB6
9V/TA 109
'Al1WA0MITTUL,W MR - (115) 5724190a 1919CH8RTNVTRT
. AUW AUMITTpL'M NJ Mp FAX Ig16167p.X?76 PIIII A., PA 1010"401
"'AlJl1 AOMITTL)TU DO Mp 1916166&6860
October 20, 1998
comer
Prothonotary
Court of Common Pleas of
Cumberland County
13 N. Hanover Street
Carlisle, PA 17013
Rat Gaskill v. Gaskill
PACSES Case Number. 901100370
Dear Sir/Madam:
Enclosed please find a time-stamped copy of our Praecipe to
Withdraw the Divorce Complaint in Ducks County in the above-
referenced case.
Very truly yours,
CAR ON P. GRAFF
CPG/je
Enclosure
CC: John J. Connelly, Jr., Esq,
Ronald daskill
CARON P. GRAFF, ESQUIRE
Attorney I.D. No. 48043
AKBARI & GRAFF
410 Old York Road
Jenkintown, PA 19046
(215) 572-6868
Attorney for Defendant
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
FAMILY DIVISION
SUSAN J. GASKILL
s
NO. 98-1211 CIVIL
V8.
RONALD L. OASKILL
i
s
s
s
s
s
s
N 0 T I C E
CIVIL ACTION - LAW
IN DIVORCE.
If you wish to deny any of the statements set forth in this
affidavit, you must file a counter-affidavit within twenty (20)
days after this affidavit- has been served on you or the statements
will be admitted.
DEFENDANT'S AFFIDAVIT UNDER SECTION 330l(d) OF THE DIVORCE CODE
I. The parties to this action separated in November, 1996,
and have continued to live separate and apart for a period of at
least two (2) years,
2, The marriage is irretrievably broken.
3. I understand that. I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim
them before a divorce is granted.
I verify that the statements made in this affidavit are true
and correct. I understand that false staments here?'n are made
subject to the penalties of. 18 Pa. C.S, Se tion 4904 relating to
unsworn falsification to authorities,
i
Date; 5 jl(,e -.GL
Ro iald L. Cas ill.
I
10
YOU ARE HEREBY NOTIFIED TO PLEAD TO LAW ONPICI4
THE ENCLOSED WITHIN JAMtS, SMITH, DURKIN& CONNELLY, LLP AETRUEE ANDS CORRECTTCOPYWOF ITHINTHE
TWENTY 1901 DAYS OF SERVICE HEREOF OP
A DEFAULT JUDOMENt MAY DG ENTERED , ORIGINAL FILED IN THIS ACTION
ADAINNY. YOU. P. G. BOX 6.SU '
By
-__.-11 -- AFIORNEY HERSHEY, PENNSYLVANIA I''M3-06511 AtTORNEv
SUSAN J. GASKILL, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
RONALD L. GASKILL,
Defendant
NO. 98.1211 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
PLAINTIFF'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF
THE DIYOBCFLSDE
1, Check either (a) or (b).
-_(a) I do not oppose the entry of a divorce decree.
X` (b) I oppose the entry of a divorce decree because
(Check (1), (H) or both);
- (i) The parties to this action have not lived separate and apart for a
period of at least two years,
01) The marriage is not irretrievably broken.
2. Check either (a) or (b);
_(a) I do not wish to make any claims for economic relief. I understand
that I may lose rights concerning alimony, division of property, lawyer's fees of
expenses if I do riot claim them before a divorce is granted,
_X_(b) I wish to claim economic relief which may Include alimony, division
of property, lawyer's fees or expenses of other important rights.
I verify that the statements made in this counter affidavit are true and correct,
I understand that false statements herein are made subject to the penalties of 19
Pa,C,S. 4904 relating to unsworn falsification to authorities,
Date: 1 LA i '•?:_Y???
Susan J. Gaskid, Plaintiff
NOTICE: IF YOU nn NOT WISH TO OPPOSE THE E T Y F A
FOB R?nNnQREEA NDcYOU DO _NOT WISH TO MAKE ANY CLRIM
s
r,
L,
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lrAblhti 5\II I1 I Jh RKIN & O NNITI 1" I.I'l,
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John L Connelly, Jr.
JkJr(vJ4dlega1 com
1
September 28, 2001 {
Traci Coyler
Office of (lie c I
Cumberland County Divorce Master
9 North Hanover Street
Carlisle, PA 17013
ri
Re: Gaskill v. Gaskill
Dear Traci: E
G.,r„ I J,,ra
klns J. $dmi, JR.
Mr. Gaskill's atton)cy has supplied the with the information I need and discovery KnnFrr[)JcIjri
JOHw J. Coping I.I r, JET
is now complete, Please schedule this matter at your earliest convenience. SN4Rr NI til,,r,rr,,,,
Srt v!mr A Sruir
JOHN J MCNALL 111
Very truly ours, Scorr A REM HEek
Om:merK RunwRin; r
RulFIARDI. Dmn.Frr f?
Sumn M KAN I_
J.urno W Finnn! aeon I
Dor;rv.i M. Nhw.irr ' I
6ownm?l' SF.[uerc
Jol J Connelly, Jr,
JJC,jlk
cc: Susau Gaskill
I
k"
JAMIiSSN11II I DURKIIN & CONNI'J LY I.LI'
l
John 1. Connelly, Jr.
' )JcJr(iijsdluynl.cunr
y
July It, 2001
1
I ;
E, Robert Elicker, III, Esquire
Cumberland County Divorce Master '
9 North Hanover Street
Carlisle, PA 17013
Re: Gaskill v. Gaskill
No. 98 - 1211 Civil Term
Dear Mr. Elicker:
Enclosed you will find the signed Discovery Certification in the above-referenced * I 1
NL?? J tirFF?.J?? t
matter. - h},nrn Dunkn?
Jbllt-,J COMNCLI Jn
BFLAItl J. Nl V II'Ll
jJn tru rs SrFVFrln Sn9:
y You ' Jowl j NI -hhu'F. Ill
Scorrn oin nnr.r.
pic;inw I DA, 11111
j
Su9-AN Ni. VA )I I
Connelly, Jr. Dni JIIA M Nu i.I III
- EOwnno P- SFeoen ?-
JJC jlk
I
Enclosure
1
'
i
i
IN TILE' COURT Of COMMON PLEAS
CUMBERLAND COUN'T'Y, PENNSYLVANIA
SUSAN J. GASKILL, )
Plaintiff )
V. )
RONALD L. GASKILL )
Defendant )
NO. 98-1211 CIVIL. TERM
IN DIVORCE
ENTRY OF APPEARANCE
To the Prothonotary of Said Court:
Please enter my appearance as counsel in the above-captioned matter for the
defendant, Ronald L, Gaskill.
Pa. ID# 81
of
7'he Law Offices of Richard C. Gaffney
2120 Market Street, Suite 101
Camp Flill, PA 17011
(717)975.9033
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1)R 25899
PACSES 11) 9011003711
SUSAN J. GASKILL, : IN'TIII: COURT OI' COMMON PLEAS
Plaintiff/Petitioner : CUMBERI AND COUNTY, PENNSYLVANIA
VS. DOMESTIC RELA'T'IONS SEC'T'ION
CIVIL ACTION - LAW
RONALD L. GASKILL,
Defendant/ Respondent NO. 98-1'211 CIV11, TERM
ORDER OF COURT
AND NOW, this 5" day of October, 2001, based upon the Court's determination that
Petitioner's monthly net income/earning capacity is $N/A and Respondent's monthly net
income/earning capacity is $N/A, it is hereby Ordered that the Respondent pay to the Pennsylvania
State Collection and Disbursement Unit, $1,302,00 per month payable semi-monthly as follows;
$1,302.00 for alimony pendente lite and $0.00 on arrears. First payment due on next pay (late.
Arrears set at $2,379.36 as of October 5, 2001. The effective date of the order is June 29, 2001.
This order is based upon an agreement of the parties. Ilusband is to offer a payment plan on
the retroactive arrears within five clays upon receipt ofthis order.
Failure to make each payment on timc and in full will cause all arrears to become subject to
immediate collection by all of the means as provided by 23 Pa.C.S.§ 3703. Further, if the Court
finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare
the Respondent in civil contempt of Court and its discretion make an appropriate Order, including,
but not limited to, commitment of the Respondent to prison for a period not to exceed six months.
Said money to be turned over by the PA SC'DU to; Susan J. Gaskill. Payments must be made
by check or money order. All checks and money orders must be made payable to PA SCDU and
mailed to:
PA SC'Dl1
11. 0. Box 69110
Harrisburg, PA 17106.9110
Payments must include the defendant's PACSES Mcmber Number or Social Security Number in
order to be processed, Do not send cash by mail.
Respondent to provide medical insurance coverage,
This Order shall become final ten days alter the mailing of the notice of the entry of the Order
to the parties unless either party tiles it written demand with the Prothonotary for a hearing de novo
before the Court,
DRO: R. J. Shaddav
Mailed copies on Petitioner
108.01 to: a Respondent -
John Connolly, Jr., Esquire
Joanne Prldoy, Esquire
BY THE COURT,
Kcv' A, lless J,
„-.
4 w
ORDER/NOTICE. O WITHHOLD INCOME FOR SUPPORT
State ..Cprnmonwealth pjpennsvly? O Original Order/NoWe
Co./City/Dist, of CUMBERLAND J 0 Amended Order/Notice
Date of Order/Notice 10/08/01 O lorminate 0rdor/Nulin
Court/Case Number (See Addendum for case summary)
F.mpioyerftilhholdor'u Federal EIN Nun0wr
AMERICAN FARM BUREAU FEDERATIO
Employer/Wilhholder's Name
225 TOUHY AVE
EmployerfWithholder's Address
PARK RIDGE IL 60068-4202_
l R6 GA$KILL1.- RONALD L. I Employee/0hh90r'ti Nam, flasl, FinN, Nth
108-44-9142
1 I mployee/Obligor's Social Serurlly Numlx-r
8421000024 _
1 Employee/Obligor', Case. Idenliflrr -'
I (See Addendum for plaintiff names associated with cases on attachment)
Custodial Parent'. Name (Last, First, Nil)
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.
$ 1, 302 . 00 per month in current support
$ o. 00 per month in past-due support Arrears 12 weeks or greater? Dyes 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 $ 1, 302 , 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:
$ Soo . 46 per weekly pay period.
$? 6oo. 92 per biweekly pay period (every two weeks).
$_ 651. oo per semimonthly pay period (twice a month).
$. 1. 302. oo per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the d of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are en ed to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for e
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 i
needed (See #9 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, PAYMENTS 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.
BY THE COURT:
Date of Order: OCT 8 2001
Service Type M Mj ?h.Rt
`
OVII4 i.? enTwi? J
Iq 1411 a II„In', Il,L4,11
Form EN-028
Worker ID $IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
? If checked you are required to provido a crgty of this font to your employee,
1. 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 Mafore rere.ipt of this order have priority, If there are federal tax levies in efface please contact the requesting
agency lined below.
2. Combining Payments, You can combine withheld amounts from nuee than one enployee/obligor's iw onw In a single payment
to each agency requesting withholding. YOU nowt, however, separately identify the portion of the single payntrmt that is attributable to
eu h employee/obligor,
7.' Reporting -the-Paydate/Datenf Withholding: You must report thepaydate/date. Mwithholding when sending the payment. 1'hr
paydate/date of withholding is the date on which amount was withheld from the employee's wages: 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.
4,' Employee/Obligor with Multiple Support Holdings: If them is more than one Order/Notice to Withhold Income for Support
against this employee/ohligor and you are unable to honor all support Order/Notices clue to Federal or State withholding limits, you must
follow the law of the state of employee's/obligor's principal place, of employntnnt. You must honor all Orders/Notices to the greatest
extent possible. (See #9 below)
5. 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 o copy of this Order/Notice to the Agency Identified below.
WITHHOLDER'S ID: 3607251600
EMPLOYFE'S/OBLIGOR'SNAME: _ OASKILL, RONALD L. EMPLOYEE'S CASE IDENTIFIER: 8421000024 ___ DATE Of SEPARATION:-
LAST KNOWN HOME ADDRESS: -_-
NEW EMPLOYER'S NAME/ADDRESS:
6. LUMP Stun Payrnents: You stay he required to report and withhold from lump stint payments such as honuses, commissions, or
severance pay, if you have any questions shout lump aunt payments, contact the person or authority below.
7, Liability: If you fail to withhold inconne as the Order/Notice directs, you are liable for tenth the acrtnnulated amount you should
have withheld from the employee/ohligor's income. and other penalties set by Pennsylvania Stale law. Pennsylvania State law governs
unless the obligor Is employed in another State, in which case the law of the Slate in which he or she is employed governs.
8. 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 tits obligor is employed in another State, in which rase the law of the State in which he or she Is
employed governs,
' 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 entployee's/ohligor's prim ipal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions WHIM: State, Federal, local taxes; Social Security taxes, and Nlecli(are taxes,
10.
'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.
Requesting Agency:
DOMESTIC RELATIONS SECTION
121, HANOVER ST
P.0, BOX 320 __
CARLISLE P 1A 7013 - -
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at L717) 240-6248 or
by Internet
Service Type M
Page 2 of 2
MAIN,. tinso.n ua
Iepimtlim lbtln, i1/il/nn
Form EN-028
Worker ID $IATT
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: DASKILL, RONALD L.
PACSES Case Number 9011oo3'1 o?,{!i PAGES Case Number
Plalntiff Name PlahLiti f Name
SUDAN J. aASKILL
Pw et Attachment Amount Docket Atlaehntenl Amount
1141 S 96 $ 1,302.00 $ 0.00
Child(ren)'s Name(s): DOB ChildheN'5 Name(s); DOB
JBINNIFBR S. GASKILL 06/16/110
?lf 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
pocket Attachment Amount
$ 0,00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above lit any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket. ttac ,mmAmount
$ 0.00
Child(ren)'s Name(s);
DOB
? If checked, you are required to enroll the ch'ild(ren)
Identified above in any health insurance coverage available
through the employee's/ohllgor's employment.
PAC$E$ Case Nt?iber
Plaintiff Name
Doc: e( ARat?hment / nmount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health Insurance coverage available
through the, employee's/ohligor's employment.
PACSES Use Number
Plaint'( Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s); DOB
? If checked, you are required to enroll the child(ren) _ ? If checked, you are required to enroll the child(ren)
dentified above lit any health insurance coverage available identified above in any health insurance coverage available
through the employee's/ohligor's employment. through the employee's/ohllgor's employment.
Addendum Form EN-028
Service Type M Worker ID $IATT
o?en>mr.nvmni;.1
tvpmlll nay:IIn100
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOSIESI'IC RELA'T'IONS SEC 10%
13 N. nANOVER SI', P.O. BOX Ro, CARLISLE, PA. 17613
Phones (717) 240.6225 Fax; (717) 240-6249
Defendant Name; RONALD L. GASKILL
Member ID Number: 8421000024
Please rule: All owrestmidenre nntvt Include the Ntunber ID Nunther,
MODIFIED ORDER OF ATTACHMENT OF UNEMPLOYMENT BENEFITS
Financial Break Down of Multiple Cases on Attachment
PACSES Docket IWChntc I Anlnunl/Trot e t
flalml" mq Cave ul her l`,lul»hc? ?! llienu
SUSAN J. nASKILL 901100170 14444-0-4@ - $ 1,302,00 /MONTH
??_?pr/ Plfi? ? l
s /
'fURU,KITACIIXIF:N'I'AMOU\11 S 1,30.'..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 $ 300.46
per week, or 50.0 %, of the Unemployment Compensation benefits otherwise payable to the Defendant,
RONALD L. QASKILL Social Security Number 108-44-9142 , member
ID Number 8421000024 . 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, S 1673(h)(2) and 23
Pa. C.S. § 4348(g).
This Order shall be effer''-
ne until the Per
Be (1
Benefits dated ?- ?NgyJ
BUCB.
All questions, ci
Court.
it of the notice of the Order by the BUCBA and shall remain in
loyinent Compensation benefits, under the Application for
listed, expired or deferred.
iss it is amended or vacated by subsequent Order of this Court.
r shall be directed to the Domestic Relations Section of this
BY THE COURT
Date of Order; OCT 91001 ? A4
JUDGE
Form FN-034
Service Type M Worker ID $IATT
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IN THE COURT OF COMMON PLEAS
CUNIRERLAND COU'NT'Y, PENNSYLVANIA
SUSAN J. GASKILL, )
Plaintiff )
V. )
RONALD L. GASKILL )
Defendant )
NO. 98-1211 CIVIL TERM
IN DIVORCE.
DR# 25899
PAUSES ID 901100370
DEMAND FOR HEARING
DATE Oh ORDER: October 5, 2001
AMOUNT: $1,302.00 per month; $2,379.36 on arrears
FOR: Alimony Pendente Lite
REASONS: Defendant. Ronald l,Gaskill. bas been iyinb the new ai octt nt of
$1,302.0 0 per niontb as was orclcred b the court, once be obtained new employment,
As such, the amount of arrears is in dis cp ate.
Party filing demand for hearing: Defendant/ Respondent
Ronald L. Gaskill
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Date:^ Signature:L&Ij ?Q JK. ?_
Courtney 1el, Esquire
Attorney for Respondent
Law Offices of Richard C. Gaffney
2120 Market Street, Suite 101
Camp I lilt, PA 17011
(717) 975-9033
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IN TILE COURT OF COMMON PLEAS
CUMHF.RLAND COUNTY, PENNSYLVANIA
SUSAN J. GASKILL, )
Plaintiff )
V, )
RONALD L. GASKILL )
Defendant )
NO, 98-1211 CIVIL TERM
IN DIVORCE,
DR# 25899
PACSES ID 901100370
CERTIFICATE OF SERVICE
1, Courtney L. Kishel, Esquire, hereby certify that I have served a true and correct
co?ry of the foregoing document to the following individuals via United States mail this
17" day of October, 2001 addressed to:
Mr. John Connelly, Esquire R. J. Shadday
James, Smith, Durkin, & Connelly Domestic Relations Section
P.O. Box 650 Cumberland County Court
Hershey, PA 17033 P.O. Box 320
Carlisle, PA 17013
Courtney L. s e , Esgt ire
Attorney 1D# 81509
Law Offices of Richard C, Gaffney
2120 Market Street, Suite 101
Camp Hill, PA 17011
(717) 975-9033
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IN T111V COURT OF COMMON PLEAS
CUMBh;RLAND COUNTV, PENNSVL.VANIA
SUSAN J, CASKILL., )
Plaintiff ) NO, 98-1211 CIVIL TERM
V, )
IN DIVORCE
RONALD L. GASKILL.
Defendant )
ORDER OF COURT
1k,
AND NOW, this S day of',._ -1 1lJL___, 2001, Robert !dicker, Esquire, is
appointed master with respect to the following claims: Divorce, fiquitable Distribution of
Property, and Alimony,
By the Court:
to Tostinmmy wtR;r x,1, I t F to .!tip r,.r my h,
r;f; Iftt1 of spit! l;tx?ri ai G?1111 w, f'a
Yilu_ :rday of
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RI(;IIAR1) C. GA 1:FN EY
October 30, 2001
Master Elicker
Cumberland County Domestic Relations
13 North Hanover Street
Carlisle, PA 17013
RE: Gasklll v. Gaskill
Cumberland County Court of Common Pleas
Docket No.: 98-1211
Dear Master Elicker:
Please be advised that at this time I am requesting a two-week extension on the
Pretrial Statement deadline, I have discussed this with Mr. John J. Connelly Jr., Esquire,
the plaintiffs counsel. It is believed that the parties may be able to negotiate a settlement
and may need additional time to do so. Accordingly, we are requesting that the pretrial
statements be due on November 16, 2001.
Should you have any questions concerning this extension, please feel free to
contact me at the number below.
Very Truly Yuufs,
THE LAW OFFICES OF QICi RLCrFNEY
Courtney L. Kish
ec: Mr. John J, Connelly, Jr., Esquire
Mr. Ron Gaskill
I O \I r i tiu:fl 1 . Si rn 101 I III Jr. I'LNN-I'Ik NIA 17011
Tla.el?IltlMl:: 717,97i.QOH • F,v( ?IhIILI: 717.97i,(h)i'1 0IhIIfRNI?T vr?C'W.ItctILA1?SCOMI
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
SUSAN J. GASKILL ) Docket Number 98-1211 CIVIL
Plaintiff )
vs, ) PACSES Case Number 901100370 /D25899
RONALD L. GASKILL )
Defendant ) Other State ID Number
ORDER
AND NOW, to wit, on this 15TH DAY OF MARCH, 2002 IT IS HEREBY
ORDERED that the support order in this case be O Vacated or QSuspended or
®Terminated without prejudice or Q Terminated and Vacated,
effective MARCH 1, 2002 , due to:
THE PARTIES' PROPERTY SETTLEMENT AGREEMENT OF FEBRUARY 13, 2002,
DR03 RJ Shadday
xc: plaintiff
defendant
John Comially, Esg.iin5
Courtney Kishel, EsclAre
Y, er+rn Arc•,,..
P S.
Service Type M
BY THE COURT;
K An A. Hess J NUDGE
Norm OR-504
Worker ID 21005
SUSAN J. GASKILL, : IN THE COURT OF COMMON PLEAS
PLAINTIFF/RESPONDENT : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 98-1211 - CIVIL TERM
RONALD L. GASKILL, : PACSES ID 901100370
DEFENDANT/PETITIONER : DOMESTIC RELATIONS SECTION
PETITION OF RONALD L. GASKILL TO TERMINATE ALIMONY
1. Petitioner, Ronald L. Gaskill ("Ex-Husband"), is an adult individual who currently
resides at 3848 Wertz Drive, Woodbridge Virginia 22193.
2. Respondent, Susan J. Gaskill ("Ex-Wife"), is an adult individual who currently resides at
209 Ewe Road, Mechanicsburg, Pennsylvania 17055.
3. The parties were married on April 12, 1975.
4. On March 5, 1998, Ex-Wife commenced the above-captioned Divorce action by filing a
Complaint.
5. On February 13, 2002, the parties entered into a Property Settlement Agreement to settle
the economic issues arising from the separation and divorce. A true and correct copy of the
Agreement is attached here to and incorporated herein by reference as Exhibit "A".
6. On March 6, 2002, This Honorable Court, per The Honorable Kevin A. Hess, issued a
Decree in Divorce, which incorporated the Property Settlement Agreement. A true and correct
copy of the Divorce Decree is attached here to and incorporated herein by reference as Exhibit
«B»
7. Paragraph 48 of the Agreement requires Ex-Husband to pay to Ex-Wife alimony in the
sum of $1,302.00 per month.
8. Paragraph 48 provides:
The said payments shall terminate upon the
earlier of the death of either party or Wife's
remarriage or cohabitation.
9. Ex-Wife is currently cohabitating.
10. The alimony should be terminated pursuant to paragraph #8 of the Agreement.
WHEREFORE, Petitioner, Ronald L. Gaskill, urges This Honorable Court to terminate
the alimony.
By:
Respectfully
NEALON LA"I$'M, PC
James G. Nealon, III, Esquire
Attorney I.D. 446457
2411 North Front Street
Harrisburg, PA 17110
(717) 232-9900
Date: , o J tP
VERIFICATION
I, RONALD GASKILL, 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.A.
§4904 relating to unsworn falsification to authorities.
Date: M 7AC-0 '
TV- ,.,y
r OCT 74 pppg y
SUSAN J. GASKILL, IN THE COURT OF COMMON PLEAS
PLAINTIFF/RESPONDENT CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 98-1211 - CIVIL TERM
RONALD L. GASKILL, PACSES ID 901100370
DEFENDANT/PETITIONER DOMESTIC RELATIONS
RULE TO SHOW CAUSE
AND NOW, this /y` day of 47006 , 2009 upon consideration
of the Petition of Defendant, Ronald L. Gaskill, to Terminate Alimony, it is hereby ordered
that Rule is issued upon the Plaintiff, Susan J. Gaskill, to show cause, if any, that she may
have as to why the requested relief should not be granted.
Rule returnable Zo da)rafter service.
By the Court:
26,09 UC T 1 4 Pi i t
Ll.?;1J ul?'?4 i ?
A44,( J.
s. ?s?,c?
SUSAN J. GASKILL, IN THE COURT OF COMMON PLEAS
PLAINTIFF/RESPONDENT : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO.98-1211- CIVIL TERM
RONALD L. GASKILL : PACSES ID 901100370
DEFENDANT/PETITIONER : DOMESTIC RELATIONS SECTION
ANSWER TO PETITION OF RONALD L. GASKILL TO TERMINATE ALIMONY
1. Admitted
2. Admitted
3. Admitted
4. Admitted
5. Admitted that on February 13, 2002, the parties entered into a Property Settlement
Agreement to settle the economic issues arising from the separation and divorce.
Denied that a true and correct copy of the Agreement was attached here to and
incorporated herein by reference as Exhibit "A".
6. Admitted that on March 6, 2002, This Honorable Court, per The Honorable Kevin A.
Hess, issued a Decree in Divorce, which incorporated the Property Settlement
Agreement. Denied that a true and correct copy of the Divorce Decree was attached
here to and incorporated herein by reference as Exhibit "B".
7. Admitted
8. Admitted
9. Admitted.
10. Denied. The alimony should be continued due to Plaintiff/Respondent's permanent
disability status since 1997. Plaintiff/Respondent's disability is a direct result of
approximately 20 years of physical abuse that she sustained by Defendant/Petitioner in
which she has permanent nerve damage in her arms, hands and legs due to multiple and
repeated trauma caused by the Defendant to her head, neck and back.
Plaintiff/Respondent has endured eight surgeries performed at Johns Hopkins Hospital
to try to repair her spine and years of physical therapy to regain use of her arms and
hands as a result of the abuse she suffered and now has a spinal cord stimulator
implanted in her spine and is on several medications for pain management.
Plaintiff/Respondent has lived alone in her own apartment since 2000. In January, 2009,
Plaintiff/Respondent began having significant pain and weakness In her neck, arm, back
and leg. She was unable to care for herself for a period of about 5 weeks.
C.
Plaintiff/Respondent has not had health insurance since her divorce in 2002. Due in part
to mounting medical bills as well as trying to save for the future testing she needs,
Plaintiff/Respondent was not able to keep current with her rent payments and utility
bills. In May, 2009 her lease was terminated due to non-payment of rent and she had
until July 5, 2009 to find another place of residence. There was no money to pay for
another apartment at that point. Plaintiff/Respondent has been dating someone since
July, 2008 and although no plans of "cohabitation" or marriage were previously
discussed, Plaintiff's boyfriend offered for her to move into his house so that she could
get back on her feet financially as well as to save for future tests and treatments needed.
It was not Plaintiff/Respondent's choice to move out of her apartment at this time and as
soon as she is financially able, she will obtain another apartment and move out of her
boyfriend's house. Terminating alimony would be detrimental to Plaintiff's health as
she is already unable to pay for necessary testing and her health issues are going to be a
life long process that she would be in had she not suffered abuse from the
Defendant/Petitioner.
Respectfully submitted,
ar ?U?.o) e<? .?il
Susan J. Gaskill
209 Ewe Road
Mechanicsburg, PA 17055
(717) 737-1680
Date: ?D
VERIFICATION
I, Susan I Gaskill, 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.A. 4904 relating to unworn falsification to authorities.
Date: /b 11' ? kill
Susan J. Gas
THE ,rrli";
OF The P ,.ri.)a.-?_ NOTARY
2009 OCT 29 PM 3: 28
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SUSAN J. GASKILL, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 98-1211-CIVIL
RONALD L. GASKILL,
Defendant
IN RE: PETITION TO TERMINATE ALIMONY
ORDER
AND NOW, this 30' day of November, 2009, hearing on the def'endant's motion to
terminate alimony is set for Thursday, January 7, 2010, at 3:00 p.m. in Courtroom Number 4,
Cumberland County Courthouse, Carlisle, PA.
BY THE COURT,
Susan J. Gaskill, Pro Se
209 Ewe Road
Mec anicsburg, PA 17055
James Nealon, III, Esquire
For the Defendant
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SUSAN J. GASKILL, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 98-1211 -CIVIL
RONALD L. GASKILL,
Defendant
IN RE: PETITION TO TERMINATE ALIMONY
ORDER
AND NOW, this J* ~ day of January, 2010, after hearing, the court finding that the
plaintiff has engaged in cohabitation, albeit under very extenuating circumstances, we are
constrained to grant the petition in this case and, accordingly, the obligation to pay alimony
pursuant to Paragraph 8 of the agreement of the parties dated February 13, 2002, is VACATED.
See Lobaugh v. Lobaugh, 753 A.2d 834 (Pa.Super. 2000).
BY THE COURT,
'Susan J. Gaskill, Pro Se
209 Ewe Road
Mechanicsburg, PA 17055
ames Nealon, III, Esquire
For the Defendant
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SUSAN J. GASKILL,
Plaintiff/Petitioner
VS.
RONALD L. GASKILL,
Defendant/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 98-1211 CIVIL TERM
IN DIVORCE
PACSES CASE: 901100370
ORDER OF COURT
AND NOW to wit, this 8th day of February, 2009, it is hereby Ordered that the
Cumberland County Domestic Relations Section dismiss their interest in the above captioned
Alimony matter pursuant to the Order of January 8, 2010.
There is no balance due the Petitioner.
This Order shall become final twenty (20) 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's Office for a hearing de novo before the Court.
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DRO: R.J. Shadday
xc: Petitioner
Respondent
BY THE COURT:
Albert H. Masland,
J.
Form OE-001
Service Type: M Worker: 21005
ORDERINOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsylvania
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 02/08/10
Case Number (See Addendum for case summary)
Employer/Withholder's Federal EIN Number
AMERICAN FARM BUREAU FEDERATIO
STE 30OW
1501 E WOODFIELD RD
SCHAUMBURG IL 60173-5422
98-1211 CIVIL
0Original Order/Notice
OAmended Order/Notice
X@Terminate Order/Notice
OOne-Time Lump Sum/Notice
Employee/Obligor's Name (Last, First, MI)
108-44-9142
Employee/Obligor's Social Security Number
8421000024
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's/obligor's income until further n otice even if the Order/Name ij_4ot ,.?
issued by your State.
$ o. oo
per month in current child support `t7 t,, -rl
n?rr 1Tt _F
-ry
$ o.-00 per month in past-due child support Arrears 12 weeks or greater? jes n om
$ 0.00
per month in current medical support c!? r?
$ 0.00 per month in past-due medical support
$ o . oo per month in current spousal support
=%-y
$ 0. oo per month in past-due spousal support "' rv 'ern
$ enetic test costs
r month for
0.00 g
pe
$ o . oo per month in other (specify) N "c
$ one-time lump sum payment
for a total of $ o . oo 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 semimonthly pay period
(twice a month)
$ o . 00 per biweekly pay period (every two weeks) $ 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 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 #9 on page 2).
Pennsylvania law (23 PA C.S. § 4374(b)) requires remittance by an electronic payment method if an employer is
ordered to withhold income from more than one employee and employs 15 or more persons, or if an employer has
a history of two or more returned checks due to nonsufficient funds. Please call the Pennsylvania State Collections
and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. PA FIPS CODE
42 000 00
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS 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. _
BY THE COURT:
DRO: R.J. Shadday
Service Type M
OMB No.: 0970-0154
RE: GASKILL, RONALD L.
Form EN-028 Rev.5
Worker ID $IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
If heck! you are required to provide a copy of this form to your m loyee. If your employee works ina state thatis
di Brent rom the state that issued this order, a copy must be provic?edpto your employee even if the box is not chec ed
1. 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.
2. Combining Payments. You can combine withheld amounts from more than one employee/obligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employeelobligor.
3.* Reporting the Paydate/Date of Withholding: You must report the paydate/date of withholding when sending the payment. The
paydate/date of withholding is the date on which amount was withheld from the employee's wages. 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.
4.* 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 #9 below)
5. 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. 3607251600
THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : 0 THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: ED
EMPLOYEE'S/OBLIGOR'S NAME:GASKILL, RONALD L.
EMPLOYEE'S CASE IDENTIFIER: 8421000024
LAST KNOWN HOME ADDRESS:
LAST KNOWN PHONE NUMBER:
DATE OF SEPARATION:
FINAL PAYMENT AMOUNT-
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the 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.
8. 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.
9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (CCPA) (15 U.S.C. 1673 (b)); or 2) the amounts allowed by the State or Tribe of the employee's/obligor's principal place of
employment. Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes, Social
Security taxes, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is
supporting another family and 60% of the disposable income if the obligor is not supporting another family.However, that 50% limit is
increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State, you may
deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section.
Arrears greater than 12 weeks : If the Order information does not indicate whether the arrears are greater than 12 weeks, then the
employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts
allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser of
the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of the
CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amounts paid for health
care premiums in determining disposable income and applying appropriate withholding limits.
10. 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.
11. Send Termination Notice and
other correspondence to:
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
Service Type M OMB No.: 0970-0154
Form EN-028 Rev.5
Worker ID $IATT
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: GASKILL, RONALD L.
PACSES Case Number 901100370 PACSES Case Number
Plaintiff Name Plaintiff Name
SUSAN J. GASKILL
Docket Attachment Amount Docket Attachment Amount
98-1211 CIVIL$ 0.00 $ 0.00
Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
Service Type M
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
DOB Child(ren)'s Name(s): DOB
PACKS Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
DOB Child(ren)'s Name(s): DOB
Addendum Form EN-028 Rev.5
OMB No.: 0970-0154 Worker I D $ IATT