HomeMy WebLinkAbout98-02515
c.:!
....
~
~
~
~
~ "
,
~
"
.~
::l
..
CJ
.'ohoson, llumc, Stewart & Weidner
By: Koirston L. Wulsh
I,D, No, 7K243
301 Murkot Stroot
1',0, Box 109
LCl11oync, I'cnnsylvaniu 17043-0 I 09
(717) 761-4540
Attorlioys for Plaintiff
JOHN D, WOLFE.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
NO, 96-2515 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
Plaintiff
v,
TRACY A, WOLFE,
Defendant
WIT/ON FOR SPECIAL RELIEF.
Petitioner, John D, Wolfe, HUSBAND. by and through his attorneys, Johnson. Duffle, Stewart &
Weidner. presents this Petition for Special Relief and In support thereof avers as follows:
1, Petitioner Is John D, Wolfe, HUSBAND. who currently resides at 708 Hanover Manor,
Apartment D305, Carlis,e. Cumberlond County, Pennsylvania, 17013,
2, Respondent is Tracy A, Wolfe, WIFE, who currently resides at Post Offlr.e Box 48, Grantham.
Cumberland County, Pennsylvania, 17027,
3, The parties were married on or about September 20, 1994 in Jamaica. and were separated
on or about January 1, 1996,
4, There are no chlldrEln born of this marriage,
~ '
\'
~:
, {
I
,
f
,
t...
f'
5, HUSBAND Is requesting that WIFE be ordered to make the monthly mortgage payments on
the marital home, Including ali utilities, maintenance and general repair bills: In !he alternative, HUSBAND Is
requesting that he be granted exclusive possession of the marital home pending resolution of the divorce for
the following reasons:
A. The marital home is located at Post Office Box 48, Gralltham, Cumberland County,
Ponnsylvanla, 17027, and Is currently occupied by WIFE and her paramour,
B, On or about January 1. 1998, the parties separated and agreed that HUSBAND would
vacate the residence,
C, The parties also agreed that WIFE' would remain In the marital home and be solely
responsible for the monthly mortgage payments, and all other bills In connection with the home,
D, At that lime, the parties Intended to transfer the marital home to WIFE pursuant to the
divorce acllon pending WIFE's quallficallon for a loan, however, the parties later discovered that WIFE's
Income level prohibited such qualification,
E. From approximately January, 1998 to May. 1998, WIFE and her paramour have been
residing In the home and have been making timely monthly mortgage payments,
F, In approximately Fflbruary of 1998. WIFE filed for spousal support, and after a June
8, 199B hearing on the issue of enlillement, Judge Hess denied WIFE's request for spousal support,
G, WIFE has on several occasions, Informed HUSBAND through her counsel that she
would be willing to vacate the home, however, on each and every occasion has changed her mind at the
last minute,
H, Since approxlmfltely June of 1998, WIFE has failed to make the monthly mortgage
payments on the marital home and has represented to HUSBAND that she has no Intention of making any
future payments,
2
I. HUSBAND contributed to the mortgage in Juna, and paid It In full for the months of
July and August of 1998,
J, WIFE Is essentially a full time employee at Hampton Cleaners (35 hours per week)
and to the best of HUSBAND's knowledge. WIFE's live-In paramour Is also employed full time,
K. HUSBAND avers that WIFE does Indeed have the financial ability. with the assistance
of her paramour, 10 make the monthly mortgage payments, however, Is simply refusing to do so,
L. In the alternative, however, If WIFE Is financially unable to make the monthly
mortgage payments, HUSBAND has the financial ability to make such payments, and has offered on
numerous occasions to help wife to find alternative housing, and move himself back into the marital home.
and thereby take over the monthly mortgage payments,
M, HUSBAND does not have the financial ability to make the monthly mortgage
payments on the marital home, and also make the monthly rent payments on the apartment that he Is
renting since vacating the marital home,
N, If the monthly mortgage payment continues to go unpaid, both parties' flnanL1ial status
will deteriorate,
6, Pennsylvania Rule of Civil Procedure1920.43 entitled "Special Relief' provides as follows:
"At any time after the filing of the [divorce] Complaint, on Petition setting forth
facts entitling the party to relief, the Court may, upon such terms and
conditions as II deems just." 1, Issue Preliminary of Special Injunctions
necessary to prevent the removal, disposition, alienation or encumbering of
real or personal property" ,or 3, Grant other appropriate relief,"
7, Section 3323 (f) of the Pennsylvania Divorce Code provides that:
In all matrimonial causes, the Court shall have full equity power and
jurisdiction and may Issue injunctions or other orders which are necessary to
protect the Interest of the parties or to effectuate the purposes of this part and
may grant such other relief or remedy as equity In justice require against either
3
party or against any third person over whom the COllrt has Jurisdiction and
who Is Involved In or concerned with the disposition of the calise,
8, Section 3502 (c) of the PennsYlvania Divorce Code states that. "The Court may award,
during the pendency of the action or otherwise, to one or both of the parties, the right to reside In the marital
residence,"
9, It Is the PlIbllc Policy of this Commonweaith to make the law for dissolution of marriage
effective for dealing with the realities of matrimonial experience and 10 give the primary consideration 10 the
welfare of the family rather than the vindication of private rights or the punishment of matrimonial wrongs,
10, It is the Public Policy of this Commonweaith to mitigate the harm to the spouses as caused
by the legal dissolution of the marriage and to utilize available resources 10 deal with family problems,
WHEREFORE, HUSBAND respectfully requests this Court to order WIFE to immediately begin
making all mortgage and related payments In connection with the marital residence, and to continue to
make such payments irI a timely manner, Alternatively. HUSBAND respectfully requests this Court tc grant
him interim exclusive possession of the marital home pending the conclusion of the divorce proceedings,
JOHNSON. DUFFIE, STEWART & WEIDNER
:114411
r
,
r.,
.j
I
1.0.
j
'')
J
I
I j
! .
\
I
t
j
~
~
~..
r
4
7, The Plaintiff has been advised of the availability of marriage counseling and he may have the
right to request that the Court require the parties to participate In counseling,
WHEREFORE, the Plaintiff respet:lfully requests that your Honorable Court enter a decree of divorce
under Section 3301 (c) of the Divorce Code,
~1L-=-f.QjJJTABLEJ2JSIBlIlUIJQN
8, Plaintiff incorporates herein by reference, the allegations set forth In Paragraphs 1 through 7
Inclusive. of the Complaint as if the same were set forth herein at length,
9, Plaintiff and Defendant have legally and beneficially ;lcqulred certain real and personal property
during their marriage,
WHEREFORE, the Plaintiff respectfully requests that your Honorable Court equitably divide all
marital property,
JOHNSON, DUFFIE, STEWART & WEIDNER
:109736
BY:~ i)U HI-'1
Kelrsten L Walsh
I verify that the statements made in this Complaint are true and correct to the best of my knowledge,
Information and belief, I understand that false statements made herein are made subject to the penalties of
18 Pa, C,S.A ~4904, relating to unsworn falsification to authorities,
Date: L(.,.3 () - 't C6
/'J
a
John D, Wolfe
~ ~ I\l
.Q~\
~
1"2 C\l >~ ~
.... ,," \.l'- ~
~t" .. ;Z' '-... ""
C ("i .) " ~
~'~' (--.I :~.~
,)(") :'r: '-' ; '"
fLJ, {}..
\~ i' .. ~
?\ J J0 \:t'
.-,: i: ...... ,.s.,
II \ ~" ,. I'() ~
l['i >'". d(\J Cl
t.' ~ .;;" :.}U.. ~ ~
~; oN
l.t. ():l :;5 I'-l
0 en U ~ ~
l.x::::,
~ '-r'\'
-- ~
\...J
I
JOHN D. WOLFE,
PLAINTIFF
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
TRACY A. WOLFE,
DEFENDANT
NO. 98-2515
CER1:IFICATE 01<' SERVICE
I, Marcia M. Ziegler, Student Attorney, Family Law Clinic, hereby certify that I am
serving a true and correct copy of Praecipe to Enter Appearance on Keirsten Walsh, counsel for
John D. Wolfe, by depositing a copy of the same in the United States mail, First Class, postage
It.j/-. '1 I
prepaid, this iJ.L. day of , 'L( t'i.-
!
,199.(.
( . / J)/ ell J .-;7 ,
Illi/r 111- l'fSt',/,-._~
Marcia M. Ziegler '-]
Student Attorney
THE FAMILY LAW CLINIC
45 North Pill Street
Carlisle, PA 17013
(717) 243-2968
JOliN D. WOLFE,
PllllllllrflRespolldellt
IN 'J'IU: C()\IRT m COMMON PU;AS (W
CIIMn.;III,ANI) ('()\INTV,I'f:NNSVI,VANIA
VS.
CIVil, ACTION - I)IVORC.;
TRACY A. WOLFE,
Defelldlllll/Pellt iOller
NO. 'IH .2~1~ CIVIl, TERM
IN DIVORCE
I)R# 27H62
1'11('.0.# IJ2HIIIU29J
ORDER OF COllRT
AND NOW, Ihls1.71!l da)' of .A!lgl!1iL, IWH. 111'011 cOllsidefllllon orthe IIl1nehed Pelllloll for
Allmoll)' Pendente Lite and/or cOllllsel fees. ills hereb)' direcled Ihallhe parties alld their respective
eonnselnppellr before BLShllddill' on _Q'"tQQgLL\12~H_ at.IJLlU-,!m. for a cOllfercnce, nt t:l N.
Hllnover SI" Cllrl/sle. PA 1701.1, aftcr which Ihe confcrencc officcr ilia)" recommcnd thllt 1111 Order for
Alllllony Pendentc Lite be elltcrcd.
YOU arc furthcr ordered to bring 10 the cOllfcrellce:
(1) a lrue cop)' of )'onr 1II0St recellt Federallncollle Ta.s Retnl'l1, Inclllding W-2 's liS I1led
(2) )'onr pa)' slnbs for Ihe preceding st.s (()) months
(1) Ihe Incollle and Expense Stalemcnlutlached to Ihis order. completed as reqnired by' Rule
I~ 10.11(<1
(4) veril1calion of child carc expenses
(5) proof of lIIedical coverage which )'ollma)' havc. or lua)" have available 10 )'on
IF )'oolilil tn appear for the eonferencc or bring Ihe re(lnlrcd docullleuts. thc ('ourlmll)' issue II
WllfI'IUll for )'our IIr(esl.
BY THE COURT,
George E. HolTer, President Judge
ce: Petitioner IInd Respojl<lent
cc' Donllld Mllrrill.. Esq. i\f\C>.,JL...vl
cc, Klersleu Walsh, Esq. N<;:.'t>, -'--'I. ~;4L
Q ~1 'loa
Dille of Order AI!!ill~~Z,J.'!YH
J~~ .,r,~"ro ""~'];-
YOII IIAVE TilE RIGIITTO A I,AWVER, WHO MAV ATTEND TIlE CONFERENCE AND
REPRESENT YOII. IF YOIII)O NOT HAVE A LAWVER OR CANNOT An'ORD ONE. GO TO
OR TEI,EPHONE TilE OFFICE SE'I' FORTH BELOW TO FIND OIIT WHERE VOII MAY GET
LEGAl, IIEI,P.
CUMBERLAND COUNTY flAR ASSOCIATION
1 LIBERTY AVE.
CARLlSL.E, PENNSYLVANIA 17011
(717) H9-.11(,()
,~'
p.rl)
0: "\;
f,il f,\\c?1
.',\ \
~
'.
v
"
..
/'
JOHN D. WOLFE,
Plaintiff
: IN TIlE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION. LAW
: IN DIVORCE AND
: EQUITABLE DISTRIBUTION
TRACY A. WOLFE,
Defendant
: NO. 98-2515 CIVIL TERM
support thereof respectfully represents:
n U"
("' C'J c)
PETI110N FOR ALIMONY AND ALIMONY PENDF.NTF. L"1:.. hi,
Il/; I ,I
~ -, /j ).,",
The Defendant, TRACY A. WOLFE, by her couosel, the Family Law qiqic, f~~ this;!:!
, \ i
. "". le'-,
Petition for Allmony and Allmony Pendente Lite, pursuant to Pa.R.C.p. 0 192,0; 15,; and il\ i1
. - '.)
" L~) I i"1
:~', .',
" (~ :J'J
_J ~,
1. On April 30, 1998, Plaintiff, ]oho D. Wolfe, filed a Complaint for Divorce against
Defendant, Tracy A. Wolfe.
2. Defendant lacks sufficient property to provide for her reasonable needs and is unable
to sUpport herself through appropriate employment.
3. Defendant is employed at Hampton Cleaners for a rate of $9.00 per hour for
approxmiately 3S hours per week.
4. Defendant requires alimony so as to have reasonable support to adequately maintaio
herself in accordance with the standard of living established during the marriage.
S. Defendant requires ao award of alimony pendente lite to adequately maintain herself
and remain on equal footing with Plaintiff, during the pendency of the divorce pr~ing.
6. The marriage has endured four years, during which time Defendant gave up
numerous occupational and educational opportunities in order to allow Plaintiff to keep his job
through several job transfers.
~.~ (7.;') '-
(~; 1.(: [.
t.;~, .. , ~;
,-, Q'l J.",
Wel ' ". ~
( 1.-
.'I( 1 '!',. )
I'...
(~HI "'-.; - i
,
d,r', (Y) ;,~
i./l
r/f. I ;
"'I '(r , I _-..I
r(: , ,UtI"
10, ~q: L/U...
/1. (fJ d
Ci (',1'
>' CI '-
q;; ('.1 t::
~ ..""
M "'j
},.I.", :~3~~
2".'
l..(: ~r:.;
f,l.:! fi... <)~
("),.
.(e! ".
Cll' ("I ~'. in
U.J I N ILo'
-, l~' ':.-1
u: ~i Uu ;alti
f.: t>: UJt:t..
~, ':
1.1~ (<:) :;1
u c.1' (,)
(g) Denied. Wife has been wllllng to vacate the home on several occasloos, but was
!lot financially able to afford a security deposit on a new apartment. Consequen!ly, an
agreement was made through counsel to furnish wife with money to assist In her moving out,
to be applied to any future equitable distribution agreement. When wife did find a suitable
apartment to move into, husband then refused to give her the money unless she agreed to forgo
hcr marital share of his pension, which she refused to do and, thus, was financially unable to
move out of the home.
(h) Denied. Wife has every Intention of making the mortgage payments and is making
a good-faith effort to do so. She has recently paid the mortgage through July, 1998.
(I) Admitted in part. Husband did contribute a partial mortgage payment in June, but
has not paid anything toward the July and August payments. Wife has paid for July, and August
and September are still outstanding.
(j) Admitted.
(k) Denied. Wife is not refusing to make the mortgage payments. On the contrary,
she is making a good faith effort to bling the mortgage up to date.
(I) Denied. Husband has not offen'.d to assist wife in securing alternate housing. After
reasonable investigation, Wife Is without knowledge or InfoTmation sufficleot to form a belief
as to the truth of the allegation about husband's financial ability to make the mortgage payme,nts,
which ailegation Is therefore denied.
(m) After reasonable lovestigation, Wife Is without knowledge or Information
sufficient to form a br.lief as to the truth of the allegation about husband's financIal ability to
make the mortgage payments and afford his own separate housing, which allegations arc there-
fore denied.
(n) After reasonable investigation, Wife is without knowledge or Information sufficient
to form a belief as to the truth of the allegation about the effect of parties' inablllty to make
mortgage payments on either's financbd status.
6. Admitted.
7. Admitted.
8. Admitted.
9. Denied, as a conclusion of law and argument.
10. Denied, as a conclusion of law and argument.
NEW MATI'ER
11. Plalntiffrealleges her answers stated above.
12. Wife Is the mother of a school-age child from a previous marriage,who has begun
a new school year. Wife is reluctant to move from the marital home while her child is in
school, as she wlll most likely be forced to move outside the school district the child curreotly
attends.
n. Husband has equal rights with wife to reside In the marital home if he chose to do
so. No one Is preventing him from living in the marital home.
14. Wife is currently making mortgage payments, and anticipates that she may be
financially able to bring the mortgage currenl by January, 1999.
IS. Husband has the ability to make some contribution to the mortgage and prevent any
negative Impact on the parties' credit.
~.
'c(;
I.
,
lil'-
en'
I','
t~t-I lC
I
L"
U
"_--,.1\
l..
I
I'
e..'
l[J '(,:,
b\
'f'"
..~.,
~"i
jl
.Johnson, ()uffic, Stewart & Welduer
By: Kcirstcn W. Davidson
J.D. No. 78243
301 Murkd Stroet
P. 0, Box \09
LCl11oync, Pcnnsylvania 17043-0109
(717) 761-4540
Attorncys for Plalnliff
JOHN D. WOLFE,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 98-2515 CIVIL TERM
Plaintiff
v.
CIVIL ACTION - LAW
IN DIVORCE
TRACY A. WOLFE,
Defendant
COUNTER-AFFIDAVlLV..NDER SECTION 3301(dlQE.IHE.DIVORCE CODE
1, Check either (a) or (b):
_ (a) I do not oppose the entry of a divorce decree.
_ (b) I oppose the entry of a divorce decree because
Check (i), (i1) or both:
__(I)
__(i1)
The parties to this action have not lived separate and apart for
a period of at least two years.
The marriage is not Irretrievably broken.
. 2. Check either (a) or (b):
_(a)
I do not wish to make any claim for economic relief. 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 wish to claim economic relief which may Include alimony, division of property,
lawyer's fees or expenses or other Important rights.
_(b)
I understand that In addition to checking (b) above. I must also file all of my economic claims with the
Prothonotary In writing and serve them on the other party. If I fall to do so before the date Slit forth on the
Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay.
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 18 Pa.C.S. Section 4904 relating to unsworn
falsification to authorities.
Date:
Tracy A. Wolfe, Defendant
NOTICE: If you do not wish to oppose the entry of a Divorce Decree and you do not wish to make
any claim for economic relief, you should not file this Counter-Affidavit.
: 134523.4
~ 10 .~
C-, t",
I..' , ,
C'J )
~',", ..:,1
,~(. ,I
fl. " :T:
..1..' t, .~ .
~l' (,~,
, '. ~. "4 "
J:I:J (',' I
!iY ;-, ,
.
f :Of:.
1.1 l', ~,
~) CJ , ,-;
JIl thc C01ll1 of' ClIIlllllClIl Picas of CIIMlmRI.ANI> COllllty, l'cllllsylv41llln
IlOMESTU: RI';I,ATIONS SIWTlON
1'RACY A, WOLFE ) DlI"k"1 Nundwl' 98-2515 CV
Pllllnllff )
VS, ) I'ACSES ellS" NUlllh"1' 92 81 002 93/027862
JOHN D, WOLFE )
Defendllnt ) Other SIIIIe If) NUlllhcl'
!;ONSENT ORDER
AND NOW, to wit, on this
2ND DAY OF AUGUST, 2000
IT IS HEREBY
ORl>ERED that the APL Orct€r
in this case hc 0 Vacated or 0 Susllended or
iii Terminated without prejudice,
effeetlvc
August 2, 2000
. due to:
PARTIES ARE RECONCILED,
ARREARAGES OWING TO THE PLAINTIFF IN THE AMOUN'f OF 463.68 ARE REMI'ITED.
DEFENDANT IS RESPONSIBLE TO PAY $25.00 IN PAST DUE SERVICE FEES. PAYMENT TO
BE MNJE TO: DOMESTIC RELATION SECTION, P,O. BOX 320, CARLISLE, PA 17013
WITHIN 5 DAYS OF RECEIPT OF THIS ORDER,
Consented:
JJlJ.<Uf.
Plaint ff (j
",
H.A...
")
-.-."
l/
JUl>GE
~ KevJn . ss
August 2. 2(0)
Date
'Yl~~y& M ~\ 11(70
Fnrm OE.503
Wnrkcr If) 21205
1';: 1.1:1 ~
.J~
i.--~ .. :::>~
1J.l~'~~ ";;"'7 (3
~,~(~' :t:: ( .~
1" '." 'I. Cl~
i'f '
'rJ(, r-- ..~
Cl;: I t~
Li_,'--
, <..~ ullll
LI ;:;J \fJ no.
""
" t::> '5
() 0 e:>
ORDER/NOTICE TO WIlHHOI.O INCOME FOR SUPPORT
,.1)1.'/ ()\' ~/, II, (11/ I(
Stale ,tlImm011Wllilllb. o' Pcnnsrl,vanlit ' ..)
Co.lCllylDlst. of ~UMElERLl\ND II/{ (of", r) ,J ~ IN, )'t '
f)aloofOreler/Nollco OB/18/00 -'./)J!. "J/:{{,.j.
COllrl/Case Nlllnbm (SI'I' Addi'ndlim lor rdSI' .1II",n""y)
o (lrl~dll,11 Urllt1f/NoUt t'
o ^llll'Ildl'd (lrdl'r/Nolln'
@ h'rm"hllp (hd"r/Nnlhtl
EllIllloYl'r/Wilhholdt'r\ rl'dt'r.ll F.lN Nwnlll'f
CONSOLIDATED FREIOHTWAYS
fmpItIYI'rlWllhlwlhlt'r'" N.l"!i'
GLO CORPORATION OF DELAWARE
El1lllloYl'rlWlthht,ltll'r', AllIin'",
PO BOX 50B4
POR~ OR 97208-5q84
I KL WOl'~.i!.DfIN ~"
) Imploy(,t.'()hli~ur''i N<lIHl' (t,I'.I, !'Ir..l, 1\\11
I 286-66-5487
) r",pl~~:i(ihfj;tur\ \0( I,ll 't'( l"ll~' NUIIlIIl'f
I 1079100026
Imp!oy;t7/< lhllWlr\ Coli!' -Idl'flli'ill"
(.11'1' Ar/dfm!u", fo, pI.III/lff "''''1'' dJJo"ldlrd with ".... .11 ."."h"'M/)
('11~lodiill PMI'llI'" N,llll!' (1.\..\, l'ir..I, Mil
See Addl'ndum lor dependent ndmes dnd birth clatl's a"sociatl!d with c'asc's on attachment.
ORDER INFORMA liON: Tbls Is ill1 Ordor/Notlce 10 Wilhhold Income for Support b~sed upon ~n ordor for suppo,t
from CUMBERI.J\ND County, Commonweilllh of Pennsylv~nl~, By lilw, YOII ~re reqlllred 10 deductlhese
ilmounls frnmthe ~bove'named emllloyee's/obllgor's Income unlil further nollce evon If the Order/Nollce Is not
issued by your Slille,
$ 0,00 per monlh in current support
$ -------0:-00 PI" month In p~st.due supporl .\frears 12 weeks or gmillerl 0 yes @ no
$ 0,00 per monlh in medlc~1 suppo,t
$ ~per monlb for genetic lest costs
$ per month in other (specify)
for a lotal of $ 0.00 per month to be forwarded to payee below,
You do not have to v~'y vour pay cycle to be In compll~nce wilh the Sllpport order. If your p~y cycle does nol miltch
the ordered support p~yment cycle, use the following to dewnnlne how Illuch 10 wllhhold:
$ 0,00 per weekly PilY period.
$ .~per biweekly pay period (every Iwo weeks),
$ .Q....QQper semimonthly Il~y Ilerlod (Iwice il month),
$ 0,00 per monthly Il~y porlod.
REMITTANCE INFORMA TlON:
You must begin withholding no I~ter than Ihe first p~y period occurring Ion (101 working d~ys after Ihe dale of Ihls
Oreler/Nollce, Send p~yment wllhln seven (71 working d~ys 01 Ihe p~yd~le/dilte of wllhholdlng, You ~re entitled to
eleduct ~ fee to defr~y Ibe cosl of wllhhoidlng. Refer to tlw I~ws governing the work st~le of your employee for the
Ihe ~lIowable ilmount. Tbe lotal withheld ~mounl, ~nd your fee, Cilnnot excfled 55"10 of Ihe employee',/ obligor's
~ggreg~te dlspos~ble weekly e~rnings. For the purpose of the limitation on withholding, Ilw following Information Is
needed (See #9 on pg, 2),
If remllling by EFT/ED!, Illeilse c~11 Pennsylv~ni~ Slale Collections and Disbursement Unit (SCDU) Employer
Cuslom,,,' Service at 1-877.(,7(,.9580 for Instructions,
Make Remittance Payable to: PA SCOU
Send check to: Pennsylvania seou, P.O. Box 69112, Harrisburg, Pa 17106.9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBEIIID (shown
above as the Employee/Obligor'S Case Identifier) 011 SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL,
BY THE COURT,
DROl 1W Shi'dday
xc: defen:lal'"
'/1'lr"/,,,'( 'j~, e() "';J
Date of Order: Allgust 21, 2000
lIiivln A. ,~~ 4....JUOOE
y- Form EN.028
(1.\\II~i".:II'i7IHI1'j.1 Worker IlJ. $IATT
1.,lir.li"I,(I,IIP:1J'lliIJ\)
Service Type M
,
ADDITIONAL INFORMATION TO lMPWVfRS AND OHlER WlHiliOLOlRS
o If dlfH'kl!d Yllll tift' rt~qulrl'd 10 "rovld!' ,I (flPY of Ihl.. furm to ~'IIt1II'l1\plnyl't',
1, Priorhy: Withholding lltldnt lld'i Oldlil/Noli! I' 11th pdntlly ll\'f!t ,Iny flllWf 11'g,t11HCH ".... IItHIt'f Sldl/' I,l\\' IIHdlll'illhf' 'i.IIlW '"mllll!,
rt!dm.11 t.IX Il'vil!'t illl1i("<f Imfom HHldpt Ilf lhi.. old"r lhlvn priority. II thflft. .UI' 'pdl'I,lIt.l)( Il'vjl'~ ill ..H"l' plp,t'i!' (Olll.!{ I lilt, n'qUl'~ljllg
,lHmuy li..lml hl'low,
2, COl11hillJnK PtlYfllf!llI't: Y(HI t .111 mmhhll' \\'ilhludd ,lIlllltlllfoi (rulll IlHHI! llldllllllt' f'1l1plnYl'nfnhlig/Jr\ hllClIHP ill ,I ..llIgIl' IMYllllHll
10 fldCh .IJWIHY rtlqumlillH wlrhholdillM. YOlllllll,,1, hOWllVl't, 'iI'Pdlclh'ly IdfllllHy Ihl! WltllOIl of Illl' ..innll' I't1YIlII'Illlh.lll't .Illrihul.lhll' III
f!au'I'tll1lplllymt!(lhliW1r.
l' R~"nr'I"K th~ P..yd""./D"',, "I Wllhh"ldirm: V"" "'",' '''p''rt th" "..yd.II"/d..,,, 01 withh"ldi"g wi",,, ,""dil1/\ th.. !"'y",,,,,!.II,,,
pi,ydati'!/tfllt~ (If wllhhuldinR i1 th~ d.,f~ 1m whkh .InHHll1t W.l~ withlwld from tlw t!mplt'Y~'-'1 WilgM'I. Yrllllllusl ((Imply willi lh" 1.lw (Jf tlw
st<ltf~ of thf~ f~mploym~''i/ohIiHor''i prilH if'.11 pl.1( I' of "ll1ploYUl/!1l1 wilh fl'SplH I to llw lillll~ pl~riods within which YOlIlllll'lllmplf'llliHlIIIlf1
wlthhf,ldlllM (Ifdflf .Ind ((11w.lrd 11111 !tllp~l(lrl p.IYlllfllll'i.
4. f; Ell1plc)Y1w/Oh!igclr wilh Mllltiplf' SUPJ1tlrl t~(lldillH'i: If Ilu~n' i'i Ilhlff! II1.Ul (lilt. Ordf~r/N(lli{'I~ It I \it./1111IIClld Illt'(I/lll' f(lr SUI>f)lul
dRdlllst thhi f'fllploYf1f-~/ohljWJf dnd YOll 11m lHldhlp 10 honor .111 'iUpport Ordt~r/N(llln''i {hit! to ft'dm.ll or Sldll' withholding limit'l, you rnU'i1
follow the IJW of Ihe 'it,IlA of t!mploYt~i~ls/(lhliHor''i prindp.1l pl.1(1! of f~mpl(JynH1t\l. You IIlllst honor .III Ordt!r'i/Notil I!S 10 lilt! grt!.llpsl
nXln"t p"sslhl", (S"n #9 h"l"w)
5,
you.
Tmmhhltlon NoHfic,lttol1: Yflll 1l111r,t pr(lmptly Iltlli(y lllf' RI'qIH".ling AW~Il(,y I,VhPl1 tllt~ 1!lllpl(lyt'Pl<lhliW1r i~ Ill) I(JIlw~r \wHking fCH
Plf-~..ts<~ providp.llw in(ortll.llioll 1t\qllt!<;tmi illld rt!IlIrll.1 copy of lhi~ OHI1.rlNotifl' 10 tilt' Aguwy idt'nlifi/!d hdow.
WITHHOLDER'S ID: 9414447970
EMPI.OYH'S/OBI.IGOR'S NAME: WOLFE , JOHN 0,
EMPI.OVEE'S CASE IDENTIFIER: __iQ.11100028 DII n OF SEPARATION
LAST KNOWN HOME ADDRESS: _______,
NEW EMPlOYER'S NiltvIUADDRESS:
6. LlIIllp Slim P,lymtmt..: YOllllhlY bf~ rt!quirt~d hI ft'porl ,llld withhold frollllllrnp 'illlll pdymfHII., such.ls hoou.,p'i, {'Olllllli.,slOIl'iI Of
SPVeri.HlCf~ p.iy. If you hdve .my qu~stt(J1l'i dhoul lump '1um ~MYI1lt'Il"', r(Jllld<~ Ihe pmson or dlllhodty ~mlow,
7. Ll.lhility: If YOll ftlll to withhold IIlWIlW "" tlH~ Grdm/Nolin' dlmrt"l YOll olft~ lii.lhlt-~ for both the .HTlIllllll.llt!C1 ,1n101I1lt YOll should
hdve withhHld from 11lP. fH1lploYP.t~/ohligor's ill('onw .md othf~r pp.Il.lltif-~" "'t~1 hV Penllsylv<lIlitl Sldlf~ 1.lw. Ppnmylv.lIli,1 Slellt! loIw gOVfHl\'i
unlf!ss the ohligor is tHnploYt!d ill "llull1t~r Sltltt~1 ill which Cd'iH Iht-1 Idw of tlw Sldll~ ill which Iw or 'lIlt-' 1<; mnploYt!d govern'i,
e. Anti.discrhnindtion: You dfH SUhjf'Ct to ,I fi,w (h!IHrmillt~d lIflclp.r St<lh! I.:tIN for dlsdhHging illl HmploYt!fl/obligor from
employmentl refusing to fHllpl('YI or tdkinA disciplinmy dction "Adinst .my t!mploYPfdohligor hf!(tlmt~ of 01 ~upport witllhnlding.
Pfmnsylvcmla Stale law governs unless Ihp. ohllgor is f!mpl(JYI~d In ,UlClI!wr SI,ltP, In which Cd"t' lhp l.lw of tht! Stdlf~ in which he or silo is
employed KCJVerns.
9.' Withholding Limits: You nlflY 1'101 withhold mOfe Ih.11l11w Itwip.r of: 1) Ihe dlllOUllt<; dllow,^~d hy !hl-l Ffldefoll COl\lillllWr Credit
Pmtection Aft (15 U.S.C, ~ 1673 (h)l; or 2) Ihl:~ ,UllOlIllts .lllowfld hy Ilw Sldlf~ of IhtH~lllploYt~p'~/(JhliAor'~ prillripdl pl.J('f-~ of tllllploYllwut,
The Federallilllll <lpplies tlJ Ihe ,IMAft1Adh~ dispO'illhle WHf~kly t1.unings (ADWC). ADWE i'i llw Iwt in('()Ilw It:fl <lhfll nldking 1l1.lnd,'lory
deductions sllch .IS: Slilll:>" ft~der,)l, locdl tdXP.Si SOddl St-lcurity t.1Xt~Si <mcl Mt-~dir.Hn tdXt~<;.
10,
'NOTE: If you or your agenl are served with a copy of Ihis order in the Slale Ihal issued !he order, you are 10 follow Ihe
law of the stale thai Issued lhis order wilh respect to Ihese ilems,
Requesting Agency:
!2QMfSTIC RELATIONS SECTION
P,O. BOX 320
~lISEE PA.l7013
If you or your employee/obligor hilve ilny queslions,
conlact WAGE ATTACHMENT UNIT
by lelephone at .l?J1U40.6225 or
by FAX ill [mu.4ll:b2~ or
by Internel @
Page 2 of 2
Form EN-02B
Worker If) $IATT
Service Type M
( l,\ \ 1\ ~~".: WI 10.(1 I 'il
I ~l'lf<lll"lI 11.111': I Jlj \1m)
\'1
I
~J'
,
Po.
j
I)
I
, J
I I
I
t
I
\
i
~
~
Ii
-"i'
.
>- r" >-
cy~ C' l--:;
I , . "
I , ()~ ) "\
I I )
) .-,
:':i: '.) ;_~1
1
L , '7 , fa
{'-, " ,
',I: ( ~,J , ,
, ,-- , .. (L "I
; L! 0..
;,::c "
\' C) --,J
C~ u ()
..,~ , ct"j i':
[:: li; .',"
, " ,
CO')
.
, , \ .,
C:l (J ~
!
, I '-i
: 'I U
c.:;-; ..!C:
('>d -.,'J
(,,,.I (j
'^
~
""""
i
.,.
~ ~
.~ \;':
~ S '
~a ~
" " Ci
",-, -G' <?
l __
L~ ~
E! ~ ~
C>.,~ \: _
6 ~ );
("" ~
~ I~ J!;
\J r-
K