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PROPERTY AND SEPARATION AGREEMENT
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This Agreement made and entered this ..I~ day of Ul~~'U"::1. 200 J by and between
Blaine F. Shover, hereinafter referred to as Husband, and Cath ne Shover, also known as
Catherine Blaine, hereinafter referred to as Wife, witnesseth:
WHEREAS, the parties hereto are husband and wife, they having been married on or
about June 19, 1982 in North Carolina; and
WHEREAS, the parties hereto have ceased to cohabit together as husband and wife; and
WHEREAS, both and each of the parties hereto have been advised of their right to seek
legal counsel and that said legal counsel would explain to them their legal rights and the
implications of this Agreement and the legal consequences which may and will ensue from the
execution hereof;
WHEREAS, Wife acknowledges that she is thoroughly conversant with and accurately
knows the size, degree, and extent of the estate and income of Husband, and Husband
acknowledges that he is thoroughly conversant with and knows the size, degree, and extent of the
estate and income of Wife;
WHEREAS, each of the parties hereto in the negotiations leading to and in the exec.ution
of this Agreement have been represented by legal counsel and are aware of their respective legal
rights, Wife having been represented by Debra Denison Cantor. Esquire and Husband being
represented by Anne M. Shepard, Esquire.
WHEREAS, the parties hereto wish finally and for all time to settle and determine their
respective property and other rights growing out of their marital relation; wish to live separate
and apart; and, wish to enter into this property and separation Agreement.
NOW, THEREFORE, in consideration of the promises and mutual undertakings herein
contained, intending to be legally bound hereby, the parties do mutually agree as follows:
1. SEP ARA TION: The parties may and shall continue to live apart for the rest of their
lives. Each shall be free from interference, direct or indirect, by the other as fully as though
unmarried, Each may for his or her separate benefit, engage in any employment, business or
profession he or she may choose.
2. MUTUAL ESTATE WAIVER; It is the intention of the parties hereto that from and
after the date of this Agreement, neither shall have any spouse's rights in the property or estate of
the other, and to that end, both waive, relinquish and forebear their rights of dower or curtesy,
right to inherit. rights to claim or take a husband or wife's or family exemption or allowance, to be
vested with letters of administration or testamentary, and to take against any will of the other.
The parties further agree that they may and can hereafter, as though unmarried, without any
joinder by him or her, sell, convey, transfer, and/or encumber any and all real estate and personal
property which either of them now or hereafter owns or possesses and further agree that the
recording of this Agreement shall be conclusive evidence to all of his or her right to do so. And
the said Husband and Wife do hereby irrevocably grant, each to the other. should the exercise of
this power hereby given become necessary, the right nnd power to nppoint one or lIIore tim(ls lIny
person or persons, whom Husbnnd and Wife shnll designnte, to be the attorney in Iltcllbr the
other, in their name and in their stead, to execute and acknowledge any deed or deeds, releases.
quitclaims or satisfactions, under seal or otherwise, to enable either party hereto to alienate his or
her real or personal property. but without any power to impose personal liability Ibr breach of
warranty or otherwise. Each of the parties hereto further waive any right of election contained in
Chapter 22 of the Pennsylvania Probate, Estates and Fiduciaries Code.
3. DEBTS: a)Except as otherwise herein expressly provided, the parties shall and do
hereby mutually remise, release and forever discharge each other from any and all actions, suits,
debts, claims, demands and obligations whatsoever, both in law and in equity, which either of
them ever had, now has, or may hereafter have against the other upon or by reason of any matt(.r,
cause or thing up to the date of the execution of this Agreement.
b)ln the event that either party becomes a debtor in bankruptcy or financial reorganization
proceedings or any kind while any obligations remain to be performed by that party for the benefit
oflhe other party pursuant to the provisions of this Agreement, the debtor spouse hereby waives,
releases and relinquishes any right to claim any exemption (whether granted under state or federal
law) to any property remaining in the debtor as a defense to any claim made pursuant hereto by
the creditor spouse, and the debtor spouse hereby assigns. transfers, and conveys to the creditor
spouse an interest in all of the debtor's exempt property sufficient to meet all obligations to the
creditor spouse as set forth herein, including all attorney's fees and costs incurred in the
enforcement of this paragraph or any other provision of this Agreement. No obligation created by
this Agreelllent shall be discharged or dischargeable, regardless of federal or state law t.o the
contrary, and each party waives any and all right to assert than any obligation hereunder is
discharged or dischargeable. Thc failure of any party to meet his or her obligations under anyone
or more of the paragraphs herein, with the exception of the satisfaction of conditions precedent,
shall not in any way void or alter the remaining obligations or either of the parties.
c) Wife acknowledges Husband's payment of all mortgnge, and credit card payments from
the date of separation until April 200 I. Wife further acknowledges Husband's payment of the
home equity loan.from the date of separation to the date of execution of this Agreement.
Husband and Wife agree that the distribution of property in this Agreement reflects Husband
receiving credit for payment of Wife's portion of these debts, for Wife's withdrawal of funds
totaling $8,989.89 from the parties' joint checking account and for Wife's cashing of the car
insurance policy proceeds check totaling $4.707.25 which was payable to both parties. Husband
shall be reimbursed for his pOl1ion of this marital property through Wife's execution of the
documents referenced in Paragraph 8 below, which sets the alimony she will receive and which
remits the arrears 01'$1,996.05 currently existing on the spousal and child support order.
4. PERSONAL PROPERTY: The parties have undertaken an orderly disposition of their
personal property and that personal property currently in the possession of each shall hereafter be
deemed to be his/her sole and separate property, free and clear of any right, title, or claim of
marital property interest therein by the other.
(a) All the furniture, furnishings, household goods and appliances, fixtures and
appurtenances, books IInd works of IIrt, IInd other items of personal propel1y (except only
the items enumerllted in subdivision b next lhllowing) presently locnted in the hOl11e
formerly occupied by the parties IInd now occupied by the Wife shall constitute the sole
and exclusive property of Wife as to which property Husband hereby trllnsfers all his dght,
title and interest therein to Wife.
(b) Except for the piano and one set of china currently in the marital residence which Wile
shall provide to Husband within 10 days of Husband's request for them, each of the
parties shall hereafter own, have and enjoy. independently of any claims or right of the
other party, all items of real and personal property, tangible and intangible, now or
hereafter belonging to him or her and now or hereafter in his or her possession, with 11111
power to him or her to dispose of the same as HIlly and effectulllly, in all respects and fhr
all purposes, as though he or she were unmarried. As to all such property, each party
transfers all his or her right, title and interest therein to the other, respectively.
5. REAL PROPERTY: The parties hereto acknowledge and agree that they are owners
by the entireties of a certain improved tract of real estate situate in Shippensburg, Cumberland
County, Pennsylvania, more specifically described in Cumberland County Deed Book 34B, Page
377 and known as 7 .'. 9 South Prince Street. For and in consideration of the mutual covenants
and agreements herein contained in the body of this Agreement, Wife agrees to be solely lillble lor
the mortgage on said property and shall hold harmless Husband fr'om any claims related to said
property until Wife refinances the mortgage and home equity loan. Husband agrees pay the home
equity loan until Wife refinances the mortage and home equity loan on the marital residence. Wife
agrees to refinance said debts 60 days from the date of execution of this Agreement. Husband
agrees to waive all of his right, title and interest in said property upon the execution of this
Agreement. At the time of Wife's refinancing of said property, Husband shall execute any
necessary documents to effect said action.
6. DIVORCE: Wife has commenced an action for divorce fr'om Husband pursuant to
Section 3301(c) of the Pennsylvania Divorce Code (Irretrievable Breakdown) by the filing
ofa complaint on May 7, 1998. Both parties shall, at the time of the execution of this
Agreement, furnish Wife's attorney with affidavits evidencing their consent to the divorce
as well as their intention to waive notice of entry of decree. It is further agreed and
understood that any decree of divorce issuing in this matter shall reflect the fact that Wife
will bear the costs of same in her individual capacity.
(a) Each of the parties agrees that this Agreement represents a complete and final
agreement as to their respective property rights which arose from the marital relation and
therefore mutually waive any and all rights they may have under Section 3502 (Equitable
Distribution) of the Pennsylvania Divorce Code, Act No. 1980-26,
(b) This Agreement may be offered in evidence in the action for divorce and may be
incorporated by reference in the decree to be granted therein. Notwithstanding such
incorporation, this Agreement shall not be merged in the decree, but shall survive the same
and shall be binding and conclusive on the parties for all time.
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7, RETIREMENT: Husband acknowledges that he has apprOldmalely $326,955 in his
T1AA.CREF retirement through his employer, Shippensburg University, $5,08lln his
Northwestern life Insurance policy, and 5558.50 in his savings account. Wife
acknowledges that she has $_ ,_ & ." in her Northwestern life insurance polley. The
parties agree that these fund& are marital. Husband agrees thai Wife shall receive 55% of
the mllrilal portion of Husband's retirement through TlAA.CREF account In the form of a
qualified domestic relations order. The marital portion shall be that amount which
accumulated from the date of the parties' marriage (June 19, 1982) until the date of the
parties' separation, (June 1997), Wife waives any right, title. and lntcrest in any other
savings, pension, 01' retirement of Husband's other than the 55% of the marital po/1ion of
Husband's TIAA.CREF. Husband waives all right, title, and interest in any savings,
pension, or retirement of Wife' s. Wife is onlitled to any increase in value 01' hel' marital
portion of the T1AA.CREF fund until such time as the Qualified Dllll1estic Relations
Order is entered. Husband agrees to have Wife remain as his death beneliciary until such
time as her share is segregated
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8. ALIMONY PENDENTE LITE AND ALIMONY: (a) Husband and Wile further
understand, acknowledge and ngree that he is currently under a Spousal Support Order to Wife in
the amount of $31 0 per month, payable through and collectcd by the Cumberland County
Domestic Office, Husband and Wife further stipulate and agree that Husband shall prepare at his
own expense a suitable Stipulation and proposed Order terminating the current Spousal Support
and replacing it with an Alimony Order, same to be collected through the Domestic Relations
Agency, payable in the amount. commencing the month of the parties' divorce and being adjusted
as follows: $$:~OO :e~1' ~~n~~h ;~~I~~~g2~~2~~~th Of_t~? ~~~~~~bd~~~~:~~~~~~e ~~~une 2002~
retirement)but 1I0t before he turns 65, or when Wife reaches 59 \f" whichever comes first.
b) the Order prepared by Husband will also remit any arrears currently owed by Husband
in Spousal Support and in Child Support,
(c) Husband and Wife stipulate and agree that they have exchanged earnings information.
tax records, and records relating to their income. and that based upon same, it has been
determined by and between the parties hereto that Wife is a fit and proper person for an award of
alimony. In determining the nature, amount, and duration of said alimony, both parties hereto
have made special reference to Husband's present and future earning capacity, Wife's present
state of employment, the relative contribution. as well as the parties respective medical and
emotional conditions, all of which have been disclosed to each party hereto by and through their
respective counsel. The parties have considered each and every clement set forth in Section 50 I
et seq. of Pennsylvania's Divorce Code in computing this alimony allocation.
(d) This determination of alimony is contractual in nature, but is modifiable hased on the
following circumstances:
I Wife cohabits with a person of the opposite sel( over the age of25, to whom she is
not related, or
2, Wife remarries. or
3. Wife or Husband die before the agreed-upon date of tenmination of alimony, or
4 Husband becomes disabled, Said disability to be verified by a medicul doctor.
Wife's alimony shall be reduced by the same proportion as Husband's net income
Is redUlled. lIusband IIcknowledges thllt htl hi covered by II disllbility Insurance
policy through his workplace. said disllbility insurance to PIlY no more than 60% of
his gross income ifhe become 100% disabled.
(e) Ifany of items 1,201' 3 listed in pllragraph Sed) above occur. then Wife's IIlimony shall
terminate the month the event occurs, regardless of when lIusbllnd discovers thllt the event
occurred. Wife shllll immediately reimburse Husband fbr payments made litleI' the month of the
occurrence of the event. For purposes of this section of the Agreement, cohllbiting shall cOI1.~ist
of either Wife or the person of the opposite sex staying lit the other's residence for fbrty (40%) of
the time in anyone month, The present Agreement, specifically the IImount of alimony or the
duration ofalimony, is Intended to reflect the actual equities existing as oftll/) dllte ofseparntion
of the parties, with ample reference being made to their respective contributions to the marital
estate and relative needs, and as such. is non-modifiable in nature for any rellson or purpose other
than those listed above in paragraph 8( d).
(OThe parties agree that the entire amount being paid to Wife pursuant to this paragraph is
a separate maintenance periodic payment, included and intended to be included within the income
of Wife within the meaning and intent of Section 71 of the United Slates Internal Revenue Code
of 1954, and is deductible from Husband's gross income pursuant to the provisions of Section
215 of the Internal Revenue Code of 1954. Wife agrees that all sllid payments shall be included as
income of the Wife in her applicable tax returns, and that she shall pay such taxes as may be
( ) JtI,.tXt~~I~~ ~~IS;:~!1I,~n~u1!<f.J (\~,III{l, lee I )ull(l) c,; ,,/1,1 c' "1'.>1 '/(IOrl<('I'./l1 fy.,d~ ( l<' ,.Ih ~b, '*(1 cot'''' 1.:+',"
9 f I '''',CliL/I'1<.1 fht.,ty.ro) (((:,,(,")h' ry'/w,j "'1"HII" pd/(lj <<11'/1) 1~)lf O<.,f/lt' prlrYYtALj-\'
polr.ll f'UOI )/A' - 9. COUNSEL FEES AND COSTS: Each patty agrees to be liable for their own
counsel fees and costs.
-(JS 10, EQUITABLE DISTRIBUTION: By this Agreement. the parties hllve intended to
effect an equitable distribution of their marital property. The parties have determined tbat an
equitable distribution of such property conforms to II just and right stllndard with due regard to
the rights ofl-lusband and Wife. The distribution of existing marital property Is not intended by
the palties to constitute, in any way, a sale or exchange of assets, and the distribution is being
effected without the introduction of outside funds or other property not constituting a part of the
marital estate.
11. APPLICABLE LAW: This Agreement shall be governed by the laws of the
Commonwealth of Pennsylvania.
12, MODIFICATION AND WAIVER: No modification or waiver of any of the terms
hereof shall be valid unless in writing and signed by both the parties, No waiver of any breach
hereof or default hereunder shllll be deemed a waiver of' any subsequent breach or default of the
same or similar nature.
13. BANKRUPTCY: The respective duties, covenants IInd obligations of each party
under this Agreement shall not be dischargeable by bankruptcy, but if any bllnkmptcy court
should discharge a party of IIccmed obligations to the other, this Agreement shall continue in full
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force and elTectthereafter as to any duties, covenants and obligations IIccrlling or to be performed
thereafter
14. RECONCILIATION: The parties shall only ellbct a leglllreconciliation which
supersedes this Agreement by their signed agreement containing a specific statement that they
have reconciled and that this Agreement shall be null and void; otherwise, this Agreement shall
remain in full force and ellect.Further, the parties may attempt a reconciliation which action if
not consummated by the aforesaid agreement, shall not affect in any way the legal ellbct of this
Property and Separation Agreement or cause IIny new marital rights or obligations to accrue.
15. ENFORCEABILITY AND CONSIDERATION: This Agreement shall survive any
action for divorce and decree of divorce and shall fbrever be binding and conclusive on the
parties, and independent legal action may be brought to enforce the terms of this Agreement by
either Husband or Wife until it shall have been fhlly satisfied and performed. Consideration for
this contract and Agreement is to be found in the mutual benefit to be obtained by both parties
hereto and the covenants and agreements of each of the parties to the other. The adequacy of the
consideration for the mutual undertakings herein set forth is stipulated, confessed and admilled by
the parties, and the parties intend to be legally bound hereby.
16. DUTY TO EFFECTUATE AGREEMENT: Each party shall, at any time and from
time to time hereafter, take any and all steps and execute, acknowledge and deliver to the other
party any and all further instruments and assurances that the other pr.rty may reasonably require
for the purpose of giving full force and elTect to the provisions of this Agreement. In addition. the
parties hereto agree that within ten (10) days of the date of submission by the other party, either
party shall sign any document necessary for the completion and elTectuation of the terms of this
Agreement. Any costs, including attorney's fees, necessitated by enforcement of this Agreement
shall be borne by the palty refusing to honor the terms and conditions of this Agreement.
17. NOTICES: Any and all notices given hereunder shall be in writing and shall be sent
by registered mail, return receipt requested:
(a) To the Husband at 226 East King Street, Shippensburg, PA 17257.
(b) To the Wife at 9 South Prince Street, Shippensburg, PA 17257.
(c )Ifeither party shall move they shall provide the other party with a forwarding address
for notification purposes.
18. WHOLE AGREEMENT: This Agreement constitutes the entire understanding of the
parties, It supersedes any and all prior agreements between them. There are no representations
or warranties other than those expressly herein set forth.
19. CAPTIONS: The captions of this Agreement are inserted only as a mailer of
convenience and for reference and In no way definc, limit or describe the scope and intent of this
Agreement, nor in any way alTect this Agreement.
20. DATE OF EXECUTION: The "date of execution" or "execution date" of this
Agreement shall be defined as the date upon which it is executed by the parties if they have each
executed the Agreement on the same date, Otherwise, the "date of execution" or "execution
CATHERINE BLAINE,
Plaintiff
IN 'l'HE COURT OF COMMON PLEAS OF
CUMBERl,AND OClUN'l'Y, PENNSYLVANIA
NO. 98 - 2622 CIVIL
vs.
BLAINE F, SHOVER,
Defendant
IN DIVORCE
QRJ2IDLOF COURT
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AND NOW, this ,JP . day of /..1{1~4.{,J.-F
'"
2001, the economic claims raised in the proceedings having
been resolved in accordance with a post marital agreement
dated August 15, 2001, 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 'rHE COURT,
co;
Debra Denison Cantor
Attorney for Plaintiff
Anne M. Shepard
Attorney for Defendant
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PROPERTY AND SEPARATION AGIU'JiMENT
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This Agl'\lon\lllllll1ude and entored this, i:.' day 01'1,. III \ I,,, /. 200 (hy lIn(1 bt,twecn
Blaine F. Shover. hereinaller rct'enlld to liS Ilusband, and Catherine Shover, also known us
('lItherine HllIine. hereinllller referred to liS Wife. witnesseth:
WIlE R I-:t\S. the Pllrtie:; hereto are husband and wite, they having heennlllrried on or
about June 19. 1982 in North Carolina. and
WHEREAS. Ihe pllnies hl'relo have ceased to (;(lhahit together as husband and wife. and
WHEREAS. both and each of the parties hereto have been advised of their right to seek
legal counsel and that said legal counsel would e,",plain to themlheir legal rights and the
implications of this Agreement and the legal consequences which ll1ay and will ensue from the
execution hereof;
WHEREAS. Wife acknowledges that she is thoroughly conversant with and lIccurately
knows the size, degree. and extent of the estate and income of Husband, and Husband
acknowledges that he is thoroughly conversant with and knows the size. degree. and extent of the
estate anci income of Wife:
WHEREAS. each of the parties hereto in the negotiations leading to and in the execution
of this Agreement have been represented by legal counsel and are aware of their respective legal
rights. Wife having been represel1led by Debra Denison Cantor, Esquire and Husband being
represented by Anne M. Shepard. Esquire.
WHEREAS. the parties hereto wish tinally and tor all time to sell Ie and determine their
respectlvc propel1y and olher rights growing out of their marital relation: wish to live separate
and apart; and. wish to enter into this property and separation Agreement.
NOW. THEREFORE. in consideration of the promises and mutual undertakings herein
contained, intending to be legally bound hereby. the parties do mutually agree as tollows:
I. SEPARATION The parties may and shall continue to live apart for the rest of their
lives. Each shall be free from interference. direct 01' indirect. by the other as fully as though
unmarried. Each may for his 01' her separate benefit, engage in any employment. business 01'
pl'(jfession he 01' she may choose
2. MUTUAL ESTATE WAIVER: It is the intention of the parties hereto that f)'om and
lifter the date of this Agreement. neither shllll have any spouse's rights in thc property or estate of
the other, and to that end. both waive. relinquish and lorebear thei, rights of dower or curtesy,
right to inherit. rights to claim or take a husband or wile's or family exemption 01' allowance. to be
vested with leltel's ofadlllinistration or testamentary, and to take against any will of the other.
The parties further agree that they may and can hereafter. as though unmarried, without any
joinder by him or her. sell, convey, transter. and/or encumber any and all real estate and personal
property which either of them now or hereaner owns or possesses and further agree that the
I'e~ording of this Agreement shall be conclusive evidence to all of his or her right to do so, And
the suid Husbund und Wife do Iwreby il'l'evocubly gmnt, each to the other, should the excrcise of
this pOWer hereb,v given hecollle ne\:essllry, the righlllnd power to IIppoint OIW or more lillleS illlY
person or persons, whom Ilushulld ulld Wife shall designate, to he the allol'lleY illlael Illr the
other. in their nilme ilnd in their stl'ad. 10 e.xeeute and ackaowledge allY deed or deeds, re/eases,
quildaims 01' Sillistilelions, under seal or otherwise, to enable either pany Iwreto to aliellahl hh; 01'
her real 01' personal propertv, but withoulanv power 10 impose personlll liability Ihr 11I'\lach or
warrantv orotherwise Each orlllll parties hereto thrther waive any right ofe/eClltlll cOlllained in
Chapter 22 of the Pennsylvania Probate, Estates and Fiduciaries Code.
.1 DEBTS' a)Except as ollwrwise herein tlxpressly provided, the parties shall and do
hereby mutually remise. release and fhrever discharge each olher lilml any and all actions, suits,
debts, c/llims, demands and obligations whatsoever. both in law IInd in equily, which l,ither of
them ever had, now has. or may hereatler have againstthl' other upon or by reawn of any Illaller,
clIuse or thing up to the date of the execution of this Agreement
b)lnthe event that either party becomes a debtor in bankruptcy or financial reorganization
proceedings or any kind while any obligations relllain to be performed by thut party for the benent
(If the other party pursuallllo the provisions of this Agreemelll, tlw debtor spouse hereby waives,
releases and relinquishes any right to claim any exempli on (whether granled under statl' or federal
law) to any property remaining in the debtor as a defense 10 any claim made pursuant hereto by
the creditor spouse, and the debtor spol!se hereby assigns, tmnsfers, and conveys to the creditor
spouse an interest in all of the debtor's exempt property sufficient to meet all obligations to the
creditor spOUse as set forth herein, including all attorney's fees and costs incurred in the
entbrcement of this paragraph or any other provision of this Agreement No obligation created by
this Agreemelll shall be discharged or dischargeable, regardless of federal or state law to the
contrarv, and each party waives any and all right to assert than any obligation hereunder is
dischnrged or dischargeable. The fililurc of any party to meet his or her obligations under anyone
or more of thc paragraphs hcrein, with the exception of the satisfilction of conditions preccdent,
shall not in any way void 01' alt(~r thc remaining obligations or either of the parties.
c) Wile lIcknowledges Husband's payment of all mortgage, and credit cllrd payments ti'om
the date of separation until April 200 I. Wilc tlllthcr acknowledges Husband's payment of the
home equity loan f)'om the date of separation 10 the date of execution of this Agreement.
Husband and Wife agree that the distribution of property in this Agrecment reflects Husband
receiving credit Ibr paymcnt ofWilc's portion of these debts, for Wilc's withdrawal offlmds
totaling $8,98989 from the parties' joint checking account and for Wilc's cashing of the car
insul'i\nce policy proceeds check totaling $4,707.25 which wns payable to both parties. Husband
shall be reimbursed for his Portion of this marital propcrty through Wifc's execution of the
documents relerenced in Paragraph 8 bclow, which sets the alimony she will receive and which
remits the arrcars of $1,99605 currently existing onthc spousnl and dlild support order.
~ PERSONAl. PROPERTY The parties have undertaken ,"1 ordcrly disposition of their
personal property and that personal property currently inlhe possession of each shall hereatler bc
deemcd to he his/her sole and scparatc property. frce and clear of any right, title, or claim of
marital property intercst therein by the other.
(n) All the tlll'lllture, tilrnishings, household goods and appliances, tlxtures and
apPUrtenallcf.1s. books and works of art, and otlwr items of person III property (except only
the items enumerllled in suhdivision b ne.~l Il,IIowing) prest"llly located inlhe home
tbl'll1erl~' occupied by lhc parties and now occupied by the Wife shall constitute the sole
and exclusive prnpcrty of Wite as to which propel'll' Husband hereby transters all his right,
title and imerest therein 10 Wife
(h) Except for the piano and one set of china currently 111 the marital residence which Wife
shall providt. to Husband within 10 days of Husband's request f()f' them, each of the
panics shall hereiltlcr own, hilve and enjoy. independently ofilny claims or right of the
other pilrty, all items of relll and personal property, tilngible Ilnd intangible, now or
hereatler belonging to him or her and now or hereatler in his or her Possession, with full
Power to him or her to dispose of the same as fully and etTectually, in all respects and tor
all purposes, as though he or she were unmarried. As to all such property, each party
translers all his or her right, title and interest therein to the other, respectively.
5. REAL PROPERTY. The parties hereto acknOWledge and agree that they are owners
by the entireties of a certain improved tract of relll estate situate in Shippensburg, Cumberland
COUI1lY, Pennsylvania, more specit1cally described in Cumberland County Deed Book 34B, Page
377 and known as 7 - 9 South Prince Street. For and in consideration of the mutual covenants
and agreements herein contained in the body of this Agreement, Wife agrees to be solely liable for
the mortgage on said proper1y and shall hold harmless Husband from any claims related to said
property until Wife refinances the mortgage and home equity loan. Husband agrees pay the home
equity loan until Wife refinances the mor1age and home equity loan on the marital residence. Wife
agrees to refinance said debts 60 days from the date of execution of this Agreement. Husband
agrees to waive all of his right. title and interest in said property Upon the execution of this
Agreemelll. Atlhe time of Wife's retlnancing of said properly, Husband shall execute any
necessary documents to ellccl said action.
6. DIVORCE: Wife has commenced an action for divorce from Husband pursuant to
Section 3301(c) of the Pennsylvania Divorce Code (Irretrievable Breakdown) by the filing
ofa complailll on May 7, 1998. Both par1ies shall, at the time of the execution of this
Agreement, furnish Wile's allorney with affidavits evidencing their consent to the divorce
as well as their intention 10 waive notice of entry of decree. II is fimher agreed and
understood that any decree of divorce issuing in this malleI' shall rellect the fact that Wile
will bear the costs of same in her individual capacity.
(a) Each of the parties agrees that this Agreement represents a complete and final
agreement as to their respective property righls which arose from the marital relation and
therelore mutually waive any and all rights they may have under Section 3502 (Equitable
Distribution) of the Pennsylvania Divorce Code, Act No. 1980-26.
(b) This Agreemenlmay be oflcred in evidence in the action tor divorce and may be
incorporated by reference in the decree to be granted therein. Notwithstanding such
incorporation, this Agreement shall not be merged in the decree, bur shall survive the same
and shall be binding and conclusive on the parties for all time.
Wilb's alil110ny shllll he reduced hy Ihe SlIlIle PlOporliollus Ilusbllnd's nlll incollle
is reduced. Hushllnd lICkIlOwl\,"~(('s IhatlUl is \'oVell,,1 hI' a disahility insurUII\,e
policy Ihl'ough his wOl'kplace, said disahility iIlSIII"llI1\:\' 10 flay 1I01ll0l'e 111111I (]O"u 01'
his Mross illcollle ,I'11ll hellOnl<' 100"" disahled
(e) If any ofilellls 1,201' .I listed ill palUgraph Hid) alloV<' OCCIII', tllllll Witl,'s ulilllony shall
terminate the month the eVI,nl on'lIrs, regardless 01' 1III<'II1111shand disl'Ovcl's Ihat Ihe evont
oCculTed. Wife shall inulledialely l'eil11hursc IIl1shalld fill' paYlllllllls IIl11de alllH Ihe lIlonlh of the
Occurl'ence of the event For purposes 01'1111.1 s('('lioll ol'llw I\grcoll11'nl, cohuhiting shllll COIISisl
ofeithel' Wife 01' the pel'son ofthl' opposih' .II" sllIl'ing IIllhl' olhl'r's Il,sidencc fin flnty (4()Oo) of
the time in any oae momh The pl'esCnll\grl!I!IIIOlll, spl'cifkully Ihl' 11111011111 ofalilllony 01' the
duration of alimony, is inlended to refll'cl tlw IIcIUIIII'ljllili\lS exisling 11.1 oflhe dUle of separation
of the parties, with alHplv refbl'ence heing 11111111, 101lwir ll!slweliV<' l,onlrihuliollS 10 the marital
estate and relative needs, IIlId us SUdl, Ls 1I01HII'Hlillllhll'ln 11111111"<' Ihl 1I11Y rlHISOII or pUl'pose othel'
than those listed above in pUl'agl"llph H( d)
(t)The parties lIgrell Ihlll Ihe l'nlill' IlInounl hl1infl pllid to Wile pursuulll to this pllragraph is
a separate maintellance periodic pnYlIlenl, illdlllled ulld Itlll1ndcd 10 he included within the income
of Wife within the mellning and inllml OfSI'diol1 71 ofthl'United Slate.~ Inlernal Revenue Code
of 1954, and is deductible tl"olll I/ushand's glOss !tW(\llIe pursuulIllo thl' provisions of Section
215 of the Internal Revenue Codl' of I'I~'I Wile aflrees Ihatall said payments shall be included as
income of the Wife in her uppllcahlc la.\ lellunll, ilnd lhat she shall PllY such tllxes as may be
I reqlJired by such ,inclusio{n " ',' ,III, ' II "1 'I ( (( It. .,'{ f". ,(,I; (, ,". I , (\..'-' , -III . <.',: c, Ie., ."
(\ ) f" .( "I " , 1,'( " . "" ,'11 (i" .', (L I, t !" , "'" I,' ,', J 1 ' I' , 'I ' '" . '; " .
,J .. ,urJ<,,'.'1/'I'1 il("!\.,\l,'."I'f.' !'.'"':,"',I",,, II, 1,lIi" "',III,~',f{:',-fll' (""1'1-lll1*
(~II ' 0" . 9. COUNShL FH,',S I\ND ( (IS I S I',ach pllrty agrees to he liable for their Own
counsel fees lInd coSls.
- ~ S 10. IiQUIT AIIUi I)ISTlUIIIITION II, II"~, A,ro,,,,,,,,. ,'" p.n'" h,,, '''''''d,d '"
effect lInequitllble distribution of their 1I1llriluI property. Till! parlies have determined that an
equitable distribution of such properly con 1'0 rills to II jusland righl standard with due regard to
. the rights of Husband and Wife The distrihlllion of existing maritlll property is Ilot intended by
the parties to constitute. inllny IVUY, U ,\ale or IIxdlllllge ofassels, und till! distribution is being
effected without the introduction of lIulside filllds or olher property not cOllstituting II part of the
marital estate,
II APPLICABLE 1.1\ W This Awcl!nwnt shall be govlllllod by the laws of the
Commonwealth of Pennsylvaniu
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12. MODIFICATION I\NI> WAIVI-:H No llIodil]('(llion or waiveI' of allY of the lerms
hereof shall be valid unless in wliling and siwwd by hoth Ihe purlics No wlliver ofllny breach
hereof or detlllllt hereunder shall Ill' dl!ll/lwd II IVaiI'm of allY suhsequlmt hl'ellch or default of the
same or similur IHIIIIH'
1.1 IIANKIU I I'll 'Y Tit" lO'ilil'l"liw dUlil's, CO\'t)nanls IIl1d obligalions of each party
under this I\fll'l'\'llIlIlIl shall nol II(' disdlllll-ilJilhll' hI' hllnkruplcy, hUI if'lIny bankruptcy court
should disduuW' a pany ofal'l'llll'd ohligali<lIls 10 tlw ollwr, this Agreement shall continue in full
1)llllf/(/(i/I' ""Ii! 11,(1 I",,; 1/. i I/lill 1i1/11""J'llll") ICI~~lt"'. '-III"~
cV/,,;o'ilir',!ll, ,11'10/ 1I'I'li' :(,',.':!f/.d((./r!.-/I)I"
.'( ['(lli,( ,if III,'//II! ('\.()
force and effect thereafter as to any duties. covenants and obligations accruing or to be performed
thereafter
14. RECONCILlATIO:--i The parties shall only effect a legal reconciliation which
supersedes this Agreement by their signed agreement containing a specific statement that they
have reconciled and that this Agreement shall be null and void; otherwise, this Agreement shall
remain in filII force and eflect. Further, the parties may attempt a reconciliation which action if
not consummated by the aforesaid agreement, shall not affect in any way the legal effect of this
Property and Separation Agreement or cause any new marital rights or obligations to accrue,
15. ENFORCEABILITY AND CONSIDERATION: This Agreement shall survive any
action for divorce and decree of divorce and shall forever be binding and conclusive on the
parties, and independent legal action may be brought to enforce the terms of this Agreement by
either Husband or Wife until it shall have been fully satisfied and performed. Consideration lor
this contract and Agreement is to be found in the mutual benefit to be obtained by both parties
hereto and the covenants and agreements of each of the parties to the other. The adequacy of the
consideration for the mutual undertakings herein set forth is stipulated, confessed and admitted by
the parties, and the parties intend to be legally bound hereby
16. DUTY TO EFFECTUATE AGREEMENT: Each party shall, at any time and from
time to time hereafter, take any and all steps and execute, acknowledge and deliver to the other
party any and all further instruments and assurances that the other party may reasonably require
lor the purpose of giving full force and effect to the provisions of this Agreement. In addition, the
parties hereto agree that within ten (10) days of the date of submission by the other party, either
party shall sign any document necessary for the completion and effectuation of the terms of this
Agreement Any costs, including attorney's fees, necessitated by enforcement of this Agreement
shall be borne by the party refusing to honor the terms and conditions of this Agreement.
17. NOTICES: Any and all notices given hereunder shall be in writing and shall be sent
by registered mail, return receipt requested:
(a) To the Husband at 226 East King Street, Shippensburg, PA 17257.
(b) To the Wife at 9 South Prince Street, Shippensburg, PA 17257.
(c )If either party shall move they shall provide the other party with a forwarding address
for notification purposes.
18. WHOLE AGREEMENT: This Agreement constitutes the entire understanding of the
parties. It supersedes any and all prior agreements between them. There are no representations
or warranties other than those expressly herein set forth.
19. CAPTIONS: The captions of this Agreement are inserted only as a matter of
convenience and for reference and in no way define, limit or describe the scope and intent of this
Agreement. nor in any way affect this Agreement.
20. DATE OF EXECUTION: The "date ofe);ecution" or "execution date" of this
Agreement shall be defined as the date upon which it is executed by the parties if they have each
executed the Agreement on the same date. Otherwise, the "date of execution" or "execution
9, The parties have lived separate and apart since May 1997 and continue
to live separate and apart as of the date of this Complaint.
10, The parties' marriage Is Irretrievably broken,
11, Plaintiff desires a divorce based upon the belief that Defendant will after
ninety days from the date of the filing of this Complaint, consent to this divorce,
WHEREFORE, Plaintiff requests your Honorable Court to enter a decree In
divorce,
COUNIll
~L1MONY, ALIMONY PENDENTE LITE, AND COUNSJ;.L FEES
12, Paragraphs 1 through 11 are Incorporated herein by reference as if set
forth In their full text,
13, Plaintiff Is unable to provide for, or afford her counsel fees, expenses
and costs during the pendency of this divorce action, and through its resolution,
14, Plaintiff Is without sufficient property and otherwise unable to financially
support herself and children,
15, Defendant is presently employed and receiving substantial income and
benefits and Is able to pay for counsel fees, expenses and costs, as well as alimony,
and alimony pendente lite for Plaintiff,
WHEREFORE, Plaintiff requests your Honorable Court to enter an Order
requiring Defendant to pay for Plaintiff's counsel fees, expenses, and costs as wall as
providing for payment of an appropriate alimony and alimony pendente lite for
Plaintiff.
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ATTOANEYS AT l.AW
2331 MAnKET STAEET
CAMP HIl.l., PA 17011"4642
11111 163.13V3
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CATHERINE BLAINE
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYl., VANIA
NO, 98.21>22
BLAINE F, SHOVER,
Defendant
CIVIL ACTION. LA W
IN DIVORCE
PRAECIPE
TO THE PROTHONOTARY:
Please amend the caption in this mattel' to the following:
Catherine J, Shovel', a/k/a Blaine v, Blaine F, Shovel'
Respectfully submitted,
REAGER
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CATHERINE BLAINE,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAN D COUNTY, PENNSYLVANIA
Plaintiff
: NO, 98,2622
BLAINE 1:1, SHOVER,
: CIVIL ACTION .. LAW
Defendant : IN DIVORCE
MOTION FOR APPOINTMENT OF' MASTER
AND NOW, this )11 day of _t\~\( \_~__, 2001, comes the undersigned
attorney for the plaintiff and certifies to the Court that the above action in Divorce is at issue;
that no issue has been directed by the Court to be tried by jury, and therefore respectfully moves
the COUlt for appointment of a Master. The following matters are at issue between the plaintiff
and the defendant:
( ,/ ) Grounds for divorce; (I) Alimony Pendente lite,
( ) Support; Counsel fees;
( ,/ ) Alimony; ( ) Paternity;
(,/ ) Equitable distribution of ( ) Custody;
property; ( ) Other.
Service of the complaint was made on the above named defendant on May 7,1998 by
certified mail.
An appearance on behalf of the defendant has been entered by Ann M, Shepard,
Esquire. The following attorneys have been interested in other matters arising between the
plaintiff and defendant: None. _~ 1
Contest is indicated,
.>0\1
Attorney for Plaintiff
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REAGER & ADLER, PC
ATTORNEYS AND COUNSELORS AT LAW
2331 MARKET SmEET
CAMP HIl.I., PENNSYI.VANIA 17011.4642
717.763.1383
TELEFAX 717 .730.7366
WEBSITE: RoagorAdlorPC.com
THEODORE A. ADLER t
DAVID W. REAGER
OHARLES E, ZALESKI
LINUS E. FENIOLE
DEBRA DENISON CANTOR
THOMAS O. WILLIAMS
SUSAN H. CONFAIR
~OANNE HARRISON CLOUGH
PETER L. LEONE
.................1.........................
Wtlhlr'S E.MaJl Add(68S; ddonl$on@oplx,nat
+Oorllllod Trllll SpoClallst
April 3, 2001
Office of the DiVorce Master
Attn: Tracy Colliel'
9 North Hanover Street
Carlisle,PA 17013
Re: Blaine v, Shover
No, 98,2622
Dear Tracy:
Enclosed please find a copy of Ron TlII'O's Praecipe to Withdraw Appearance whichI had in my
file, It is not a clocked in copy, however, If you need me to file a formal Entry of Appearance, I would
be happy to do so,
Very tru
DDC/ak
Enclosure
CATHERINE BLAINE,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
: NO, 98,2622
BLAINE F, SHOVER,
: CIVIL ACTION. LAW
Defendant : IN DIVORCE
QUALIFIED DOMI<::S'I'IC RELA'rIONS ORDER
AND NOW, this j-J _ day of C) ~ , 2001, it appears to the Court
as follows:
1. The parties hereto were husband and wife, seek this Order in conjunction with
a final decree of dissolution of marriage dated September 5, 2001 in that action pending
in this Court at the above number,
2. Blaine F, Shovel', SSN 182.34-6937, hereinafter referred to as "Participant", is
employed by Shippensburg University, is a participant in the Teachers Insuran(,e and
Annuity Association-College Retirement Equities Fund, hereinafter "TlAA-CREF" and has
the following annuities:
TIAA Retirement Annuity (ItA) Contract
CREF ItA Certificate
No, B020674.4
No, Q020674-1
Participant's current and last known mailing address is 226 King Street,
Shippensburg, PA 17257, His date of birth is 1O/26/t!2,
3, The Alternate Payee is Catherine Shovel', cunent and last known mailing
address is 9 South Prince Street, Shippensburg, PA 17257,
The Alternnte Payee's Socinl Security numbor i8 524,66,3929 and dnte of birth is
7/18/52,
4, To accommodate the marital/community property distribution between the
pm'ties
IT IS ORDERED, ADJUDICATED AND DECHEED AS FOLLOWS:
A. That th(J '1'IM.C1UW nnlluit:ios pl'oviously I'ofol'oncod al'o maritnl proporty:
B, Upon finalizut10ll of this Ordor Ilnd pUl'sunllt to tho torllls of suid annuitios, tho
cUl'l'ont vahuJH as of tho vnluntion date of the Participant's 'I'IAA-CREF annuity
IIOCllluullltions fill' the Murit.al Portion defined below shall bo awarded as the Alternnto
Payoo's sole and exclusive pl'operly to be applied to TIAA.CREF annuities subjoct to the
terms and limitations of said annuitios:
(Choose i or H)
ii. Marital portion if a percentagojs to be tl'llnsfel'red, and TlAA-CREF
is to calculate the acculllulation to be transferred, choose a or b
a) For annuities issued !J!.1&r. the marriage was ostablished:
acculllulations attributable to lH'emiums remitted from the
inception of tho contract through June 30, 1!l97, the date the
MHl'ital/Colllmunity Property interest ceased,
01', if not Hpocified, tho date of dissolution specified in paragraph (1),
TIM RA No, B020G74.4, 55%
CREF RA No, Q020674.1, 55%
Hi. Transfer Valves
The values actually transferred willroflect interim investment experience until the
transfer is recorded by TIM.CREF, The TIM Traditional accumulation will increase over
time, whereas the TlAA Real Estate and CREF acculllulations may increase 01' decrease,
reflecting the performancc of the underlying investments,
C, Conditions of division of anlluity contracts:
i. All ownel'ship and interest in the balance of the accumulationll not
transferred in all annuities issuod to the Participant by TIAA.CREF
will belong to the Participant,
ii. All ownership rights in the newly issued annuities will belong to the
Alternate Payee,
Hi. 'I'he beneficiary designation of the Alternate Payeo's annuities will be
his 01' her estate, unless a boneficiary designation is submitted
pursuant to the provisions of tho contracts, and accepted by TIM-
CREF, The Alternate Payee mtlst review the contract.s at illstlanco for
accuracy and inform TIAA,CREF of any change of addrells,
.
ORIlERINOTlCE TO WITHHOlll INCOME FOR SIJPPORT
Stile .cwnnwnweallh "I Pennnlll4nJ,.
Co'/Cllyll>lsl. of elJ~.J\~IJlNIl__""_._"_..__._
Dall' of Ordm/Nnlln' 1 ~/29/05
C<lSfl Numhnr (S~ IIddtmdu,;,"for ('.ue summary)
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OA"lI'flllllil()ftlf1r/Nllli(u
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SHIPPENSBURO UNIVERSITY FOUNDA
1871 OLD MAIN DR
SHIPPENSBURO PA 17257..2200
KI: SHOVER I BlJlINE (,',
rl1lploY(ltI/OllliKor'~ NiIIllt' (I illl, flrsl, Mil
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fn,ilT(~yu(\/()IJliKi)r'S~~{)fi.11 SfH:urlty NUlllhor
0603100058
I mploy;.,,!()llliRor's {:'\'\(' ld(lnll(jpf
IS.. ~ddtndu," for pI.ln,lff n.me.'
,UJO(""'(I(I wit" ('dJ~J OIl ,".c:hm(mtJ
ClJ'ilodij"iliMI"H'S 'N-:;m;:(f:i:'iill!}l, M~
In;pioVf!(fWUhholdm'; redn,,,n"TN NIIH'J;m----.-~--
See Addendum for depl'ndellt lIames and birth dates associated with cases 011 attachmellt.
ORDER INFORMA nON: This Is iln OrderlNolimto Wllhholdlncome for Suppnrt base!d upon ,HI order for supporl
from CUMBERLAND County, Commonwe,lllh of Pnnnsylv,ml<1, By lilw, you illf' "!'quiredlo deduct these
amounts from the above-nam!'d employee's!obllgor's Inmm!' unlil furth", nollcn eVl'n If Ihn Ordnr/Nutlte Is not
IssuI,d by your Slilln,
$ 0 . 00 per month in c:urrenl support
$ 0.00 pl'r month In pilst-due Sllpport Amwsl2 w!'eks Dr gre<1t!'r? QYl" (jQ no
$ __---.lL.Q.Q.per month in current ,md P'lsl-due O1edlt<11 support
$ 0 .lUl,per month for gnnetlc: tnsl co;ts
$ per month In other (spm:lfyl
for a total 01 $ _~~Jl per month to be forwarded to payee below.
You do not have to vary your pay cycle to be In rompllancn with the support order, If your pay cycle does not match
thn ordered support payment cycln, use the following to determine how much to withhold:
$ 0 . 00 per weekly pay period,
$ 0 . 00 pl'r hiweekly P,lY period (every two weeks),
$ jL,,2Qper semimonthly pay period (twice a month),
$ 0 . 00 per monlhly P,lY period,
REMITTANCE INFORIv/A nON:
You must begin wllhholding no latN thiln the, first p,w period occurring tl'n (10) working d,lYs dfter thl' dale of this
Order/NolieI'. Send p,lym!'nt wllhln seven (7) working days of Ill!! payd<1te/dilte of wilhholdlng, You are entitled to
deduct a fee to defray the cost of wllhholding, Refer 10 the 1<11'.'; governing thl' work slain of your employee for the
allowable amount, The tot<11 withheld amount, and your fee, cannol e~ceed 55% of the employee's! obligor's
aggregate dlsposabln weekly earnings, For Ihe purpose of the limitation on withholding, the following Information Is
nt1eded IS!'!, #9 on IMge 2),
If remitting by EFTlED!, please c:all Pennsylv,lnla St,lte Collerllons and Dlshursnment Unit (SeDUl Employer
CustomClr Service <1tl-877-676-95BO for inslructions,
Make Remittance P~yable to: PA seDU
Send check to: Pennsylvania SeDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN A.DDfT/ON, PA. YMENTS MUST INCLUDE mE DEFENDA.NT'S NA.ME A.ND mE PA.CSES MEMBER ID (shown
above as the Employee/Obl/Bor's Case Identifier) OR SOCtA.L SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND C~SH BY MA./L. (t'~-
BY HE COUR :u
S.. __ ,d."" \ \, (AV\ \o~'"
Date of Order: DfG 3 Q 2fl85 _ '\ \ \
Eiw.ll' \::\ ~.i.l ,,\lL l } , \ll.uJl~_L '...
1'\ I '\ Form EN.028(\
Worker 10 $IATT
Service Type M
(IMIfNo (J'I/U,ftl'H
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ADDITIONAL INFORMATION TO EMPLOYERS ANI) OTHER WlTlutOll>ERS
o 1(/'lwrktI11 yotl jln' reljulr(l(llo P'I,YI\/t." I-OilY of thi" (orllllo your,lm'/,loy,'(l. If VOl" ('lIlploY(1~' Workli In iI q,l!P lhilt Is
(Ii {('wnllrolH 111(1 "Ial(l th,IlI'i'ilU'( Ih Ii Of( ('(, ,I fOpy /TIll'll hi' provlfh'( 10 your 1'1111' OYflf' (tVI'1I If till' hm:: l!'i nol dw('k(!d,
1, PrlorltYI WllhholdlllH urulm thi" ()rdpr/Nfllln' hjl~ prlmil~' IlVm ,lilY otlll'( IOJ{,IIIHlIHISIj undN St,lll' 1,IW dKilinslllw 'iilllH' IIl{,OfHt',
f(~dt!mlldl( It WillS ill ('(ft'rl hp(orP (pu.I,,1 of Ihh or<lpr hlIV(' priority. II tll(lrfl,Ht' 11'11('(,11',1.'( Il'vh", In ('ffl'tl "Itw,(' ("(Hllilrllhp (t'(IUrlslhlM
ilMllIlCY "'I"j h"low_
2. Combl"'nll Paymenhu You ("IUl rOfllhllln wilhl1l11d .11IIOtHll'i (rolll mow lhlll! OIW (!11l"I(lY(l(l/ohli~or\ IncofHl' in il slnHII' IMYflWflllo
0.1[11 aRt'my W(IU(l!ilhlK wUhlloldlllK, You "HlliL !lOWllV(lf, sI'JMrtll('ly Id(lflllly 1IJ(l !lmllon of IIH' slo"I(! pilYIfH'nt IIMII, dllrUlul,lhll1lo (~tl(:h
l!Infl'oy,'"/nbllg,,r,
l.' RnrmrtlnR thn P~yrl~lr/O~tr of Withholdlnr.' You mu" '"flort Ihr payda'r/datr of withholdlnr. whrn ,rndinM th" fI.,ymnnt, lhe
p~yrl~tr/d~tr 01 withhClldlnM I, th.. d~tr on whlrh amounl Wil' wilhlwld fmm Ihr ,'mllloy""" WiW". Youlllu,1 Ullllflly with IIw I.IW o( Ihr
slain of IIw omploYot"s/obIlKor\ prlnd".1l pl,lnl o( (ll1lpIOYflWUI willi ftIsppd 10 IIwllllw p(lrlod'i wUhin whkh you nwsllrnpllmwf1llhe
withhold 111M ord." ",,,I (oIW.mlllw "'flflorl P,lY""'''''.
4,' Employee/ObllKor wllh Multiple Support HoldlnK" Ii II...m I, Illorr Ihil" 0"" Ordrr/Nolll'l'lo Withhol" InCOlllll (or SUflflort aKaln,1
this milploy(~('/ohIlKm ltlle! YOlI,UO lHhlhl(, 10 honor dll supporl OrdN/Nolll'{ls <lu!' 10 rmlmlll or Stall1 withholding limits, you mllst follow
Ihr law of Ihr 'Iillr oi rmflloyrr',/ohIlMor', flrillelfl,,1 fll.,n' of "l1lfllllynll'''1. Youmusl honor ,111 Or",,,,/Noilcrs 10 tI... Mr"alrsl exl.'nl
flooslbl". (S.ll' #9 '",IowI
5, Termination Notification: Youmu,1 flrol1lfllly nolliy Ih" R"ql,,,sllng Ag""cy wl",nlh" ('l1lflloy",,/obllgor I, no lonM'" working for you,
Pleil'" provl"r Ihe In(ormallon mqueslrd and relunl a copy of Ihi, Or"",/Nolln'lo II... Ag""CY i"""lIil,," 1",low,
THE EMPLOYEE/OBliGOR NO LONGER WORkS FOR, 2320460930
EMPLOYEE'S/OBlIGOR'S NAME, SHOVEL BIJlINE F,
EMPLOYEE'S CASE IDENTIFIER, 0603100058 DATE OF SEPARATION,
LAST kNOWN HOME ADDRESS,
NEW EMPLOYER'S NAME/ADDRESS,
6. Lump Sum Payment" YOll may h" r"qulrrd 10 "'port .lfld wilhhold from lump sum pilynll'nl, sllch ilS bOnllS"S, commission" or
SeVer(Hlfe pay. If yuu hawl any qUf1stions aboullump slim p,lyrmlllls, conl(lcl tl\{' person or <luthorlty below.
7, Liability, I( YOll (ilillo wilhhold Income as Ih" Ordrr/Notice direcls, YOll am liable for bOlh Ihe ilCclImlllalrd ilmollnl you should bave
wilhh"ld (rom Ih" employee/obligor's Income and ollllOr penilllies s,,1 bl' P"nnsylvaniil Slale law, P"nnsylvilnia Slat" law governs lInless
the obligor I, employed in ilnolhm Slille, In which cilse Ihe law of II", Slille In which I", or ,h" is "mploy"d gov",,,,,
8, Antl-dl,crlmln~t1nn' You ilre subjecllo a flnr ,lel"'mim~1 undm Slale Iilw for (Ii,charglng an "mploy",,/obligor (rom employmenl,
refu,ing to employ, or lilklng disclplinal)' aclion ilgalnsl.,oy elllflloy",,/obllgor b",:ause of iI support wllhholdlng, Pennsylvanlil Slate Iilw
governs unl"ss the obligor is employ"d In ilnolh", Slalr, In wbich case Ih" law 0; Ihe Sial" In which ,'" or she is "'"ployed governs.
9.' Withholding Limit" YOllmilY nol wllhhold more Ihan Ihe lesser of, 1 I Ihe amollnts illlow"d by Ih" frderal Consumer Credit
Prolection ACll15 U,S,C, ~ 1673 (bll: or 21 Ih" ilmollnls allowed by Ih" Slilte o( tl", "mploy",,'s/obllgor's prlndpal plaer o( employment.
The federillllmit applies 10 Ihe ilggregale dlspo'ilble wrekly eilrnlng' (ADWE). ADWE is 111" nellncome Ir(t ilMer making mandalOI)'
dedllctions such as: Slate, Federal, 10cilI taxes: Social SeclIrlly Iilxrs: ilnel Medicilre lax",. for Iribal orders, YOll may nol wilhhold more
Ihan Ihe amollnls allowed under the law o( Ihe Isslllng Irlbe. [-or Iribal "mployers who mcelve a slale order, yoo milY not withhold more
than Ihe ilmounts allowed lIndrr Ihe Iilw of Ihe slille 1l1i111"'llld Ih" ordN,
10, Addltlonallnfo,_
'NOTE: If YOll or your agent are served with it copy of this order In the state thallssuedlhe order, you <lie to follow the
law of the slate that Issued this ordm with respeclto thtse items,
11, Submitted By:
POMESTIC RELATIONS SECTlOL_
13 N. HANOVER ST
1',0, BOX 320
~ARLlSLE PA 1701)
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by lelephone at (717) 240-6225 or
by FAX at (717) 240-6248 or
by internet www.chlldsuPPol1.stitle.pa.us
Service Type M
P"M" 2 of 2
Form EN-028
Worker ID $IATT
(J,\Hl NlI.: H'I!H.Ht',.!
OROER/NOTICE TO WITHHOlD INCOME FOR SUPPORT
Stale .t.umnumwJ:allh uf Pcruarlw1i...
Cu.lCily/DlsI, of 0L~AND _____
Dale' of Ord(,r/Nolln. 01/04/06
Cas~ Numhm (Sl'e Addelldulll for fase summary)
63610014 '7
98-267.2 CIVIL,
@(h1llllltll (hdl'r/Nntk{l
o AlTlondt'd ()rdt'r/Noti('(l
o Inrmillilll' ()fdl1f/Notlw
STA1'E SYS1'F;M OF HIOHEIl EDUCA1'I
c/o DIXON UNIVERSITY CIi:N'1'E1l
2986 N 2 ND S1'
HARRISBURG PA 17110-120),
KI: SHOVEIl, BIJlINE F,
l:ml,loYl'u!()WIR(lf'<' N,IfIl(' (1,,151, '.lrM, MI)
103-34-6937
InwloYl'(l/(Jbll)l(jr'~ SlIdill Stlntril.,. Numher
0603100058
~li)I(lY(lf'/()llliRor'::-'(:,H(1 Idt1lltHhlf
(s.. Addt>lIdum I... pl,/lItlff n,m..
duocl.lIf'd with ('."et: on dftdchmtntJ
(:ll~l()di,ll P,Ifl'flt\ NiUJl{' (Ll'~1. lirst, ~A/)
Employer.r\rVlthhnldm'~ rrdllr,IIIIN Numllf'r
See Addelldum for dependent names alld birth dates associated with fdses on attachmellt.
ORDER INFORMATION: This Is an Order/Notice lu Wlthhuld Income for Support bilst,d upon '111 ordm for support
from CUMBERLAND County, Comrnunwe<lllh of P11I1I1sylv,mlil. By 1,1W, yuu <Ire required to deduclthese
amounts from the <lbove-rMmed empluyee's/obllgor's Income unlll further notice even If the Order/Notice Is nol
Issued hy your Stiltl',
$ 660,00. per lTlonth In currenl support
$ 0 . 00 per month In JMSI.dlll' support Armors 1 2 wel'ks or gll',llerl () yes @ no
$ =--_ 0.0-0 per munlh In furwnt ilnd pilsl-due Illedlcal support
$ O. Q..Q.pt>r munth fur genetic test cosls
$ per month in olher (specify)
for il total of $ 66 0 . 00 per month 10 be forwarded to payee below.
You do not have to Vilry your pay cycle to he In compli,lllce with the support order. If your pay cycle does not match
the ordered support pi\ymenl cyrle, use th.. following to determine how much to withhold:
$ 152 ...JJ.. per we;'kly p"y period,
$ _~04, 62 per biweekly P<lY period (every two weeks),
$ :U~pt'r semimonthly p"y perlud (Iwice " month),
$ 660.00 pm munthly pay pmiud.
REMITTANCE INfORMATION:
You must begin Withholding no latm th"n the first p"y perlexl occurring ten (10) working d,ws after the d'lte of this
Order/Notice. Send paymenl within seven (7) working days of the pilydale/dille of withholding, You are entitled 10
deduct a fee 10 defray the cost of withholding, Refer to the laws governing thl' work stilte of your employee for the
illlowable amount, The lot'llwlthheld amount, "nd yuur fee, cilnnol exceed 55% of the employee's! obligor's
aggregate dispos"ble weekly eilrnings, For the purpose of the Iimitiltlon on withholding, the follOWing Information is
needed (See 1/9 on page 2),
If remitting by EFl/EDI, pllMse c,,1I Pennsylvania Stilte Collections and Disbursement Unit (SeDU) Employer
Customer Servictl at 1-877-676-9580 fur Instructions,
Make Remittance Payable to: PA seDU
Send check to: Pennsylvania SeDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN IIDDtTION, PA YMENTS MUST tNCLUDE THE DEFt'NDANT'S NAME AND THE PACSE.S MEMBER 10 (shown
above as the Employee/Obl/sor's Case tdentlfler) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL. ~
BY T COURT: ~
Date of Order: JAN 0 :) 2006 ..,c .,0'" \/ ~1 ~~
F.dgar B. Bayley, Ju'lge
Form E N.028
I"lorker ID $IATT
DROI R.J. Shadday
Service Type M
()M6N(I,'Il'llU,()11"
AIJDlTIONAllNfORMATlON TO EMPLOYERS AND OTHER WITHHOLDERS
o Ill'Iwrkl11 YOIl ,Ill' "''I"lr",1 to P'INII'" "I-OIIY of Ihl, form 10 YOll'. QIII/,Ioy..,,_ If YOI'r ('rllploy".. \yo,k, In ..1 ,lilt.. Ih.lll,
( I INl'IlIIHlmIIw 'ilil!('lIMllsSUl'( Ih Ii on (1(, il ropy lIlust ht' prOI,'UIII( 10 yom Pfllp OYf't' ('VPfl If lhl' hox IS llol dU'rkl1d,
" Priority' Wllhhnldln~ lIIHh'r Ihl, ()rdl'r/Nolln' h,,, prlorily ov"r ,lilY olhl'[ 1(%11 I HO("('" lIIHh', SI.II.. 100W ..~"Ir"1 th.. ,.IllII! Inron1l',
ftl(lllrlll tax 1(IVill'i Ifll!fftlll 11(1(01(' rf'('(llpt of lhb oHIN IMv(' priority, I( Ihml',Ht. rpdnr,IIIM\ I('vips In (I(((wl "It Wit! l'ontllflllw mqllt1sllnR
i'K(!Il('V Ilstmt hl.low.
2. CombJ"'".. Pavmtlnlil You rim ('omhlfw with/wId illllOllnh (rollllllOfII than o,w f'mploYf'fl/ohIlRor's Inconwlll i1 single pilYnwnllo
(Meh "Henry roqlloslhlK WUhllOldhlM. You llIll'il, hOWflVPr, 'Wpllr.lloly i<!f'ntlfy Ill(' portion of 11m Sill~d(1 pllynwnllhilll!l.lltrlhUlilhh. to (u'fh
employ.!.'/ohll~(".
J,' ReportlnR the P"yrl"te/Il"t. of Wlthholrllng: You mu,t (('port the p"ydalr/rI"tr of Withholding when ,rndlng th"ll"ymrnt_ The
payd,'tl'lrl,,'" of wllhholrllng I, the d"te on whirh "mount w", wlthhelrl fmm th.. "'oployr.-'s w"g,'" YOll """t comply with IllI! law of th..
stalE! of tho (!l11ploye(l\/(lhll~or'~ luhH:II'ill "la('(1 of (Ill1ployrmlfll with rnsJI(I('( lollH' limp pmlod'i within whlrh you rnul\llmplolllnllllhe
wlthholdh,~ onl", 'H"I fotwmd IIll' '''pport I"'Ylll"'*.
4.' fmployee/ObllKor with Multiple Support HoldlnK" If 11".,1' I, ""'n' tha" 01111 (l,d"r/Notin, to Wllhlwld I"conll' for SlIpport ,1galnst
this IlmploYI'../ohIlKor a"d you a", 1IIlilhl,' 10 honor ..11 "'PI""t Ord",/NolI! '" dll!' to I "d",al or St"t.. wllhholdlng IImi", YOll """I follow
the law of Iho sidle of C!lllploY(l("s/obllgor's principal plan' of olllploYIlWIlI, You ITlmt honor <Ill Onlers/Noticm to tlw greatesl extent
po",lble, ISe,' #9 h,.lowl
5, Termination Nollflcatlon: You mu" promplly nollfy II\(' R"'lu..'"ng A~'!Ilcy wh..n th.. ('mploy"../obllgor I, no longer working for you,
Please provide the Informallon m'l"esl..d ,w, ''''un';j copy of Ihl, Order/Nollce to the Ag",,,,y Idenllfled he low.
TliE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 9100009000
EMPLOYEE'S/OBlIGOR'S NAME: SHOVER. B~NE F.
EMPLOYEE'S CASE IDENTIFIER, 0603100058 DATE Of SEPARATION,
LAST KNOWN FIOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:__
6. Lump Sum Paymen'" You m,lY he m'lulred 10 rcporl 'H,d wllhhold from lump slim ,,,,ymenls 'uch a, honus.." comml"lo"" or
severance rew, If you have any qlwstions ,1hOllllump slim payments, cont,lct Ill(! person or iluthority l)(!low,
7, Liability: If you fall to withhold income a, Ihe Order/Nolic.. di",cls, you me liable for both tl", accumulaled amounl you shollld have
withheld from the employee/obligor's Income and olher penalties 'el hy Pennsylvania Stat.. lilw, p..nn'ylvanla Stale law governs unless
the ohllgor is employ",lln anollier 5lille, In which c..... Ihe law of II", Slale In whirh h.. or sh.. Is ..mployed goverII',
B. Antkll.crlmlnallon, YOl' are subJecllo il fine d..lermined lInder Slate law for (lI,charging an "'oployee/obllgor from employment,
refllslng 10 moploy, or lilklng disciplinary .lClion again,t any emllloyee/ohllgor h"co1l1,e, of a Sllpport wllhholdlng. Pennsylvania Stale law
governs lInl.." Ihe obligor Is ..mployed In anoll",r State, in which eme tl", law of the 51011.. in which he or ,h.. Is employ..d governs,
9,' Withholding Limits: YOll may nol wllhhold n"".. than till' le"er of: lllhe .1mOllnl, allowed hy Ih.. Fedefill Comllmer Credll
Protecllon Acll15 U,S.c. S 1673 (bll; or 21 the amounts allowed by Ih. Sial.. of Ihe employ"e's/ohligor's principal plac.. of employment,
The Federal limit applies to the aggregate dl'posahle w..ekly "arnlngs IADWEI. ADWE i, the nellncome left after making mandalory
deducllons such as: Slate, f..deral, local taxe,; Social 5eeurily Uxes; and M..dicarn tilxes. for tribal orders, you may nol wllhhold more
than Ihe "mounts allowed lInder Ihe law of the is,uing t,lbe. For tribal employers who'rccelve a ,'ate order, you may not wllhhold more
than the amounl' allowed lInrl... the law of Ihe 'Iilte that im,,,d th.. order.
10, Addlllonallnfm
'NOTE: If you or your a!lent .lie served with a copy of this order In the stdte that Issued the order, you are to follow the
law of Ihe stille that Issued this order with resped to these ilems,
11, Submitted By:
DOMESTIC RELATIONS SECTION
13 N, HANOVERll..-
W, BOX 320
CARLISLE PA 1701 J
If you or your (lmployee/ohllgor hdye any questions,
contact WAGE ATTACHMENT UNIT
by lelephone at (717) 240-6225 or
by FAX at 17171 240.6246 or
by internel www.chlldsllpporl.slale.pa.us
Servlc:e Type M
Pa!le, 2 of 2
Form EN-028
Worker ID $IATT
(),\1flNIl.:O'I/IHll'i,1
In the Court of Common Pleas of CUM81(RJ,ANIJ County, Pennsylvania
IJOMI,:S'I'IC RI(LA'I'IONS SI(C'I'ION
CA'fHERINE J. SHOVER ) Dockcl Numbcr 98..2622 CIVIL
l'lllitllit't' )
VS, ) PACSES Casc Numbcr 636100147
BLAINE F, SHOVER )
Dct'Clllllll1t ) Othcr Slalc II) Numbcr
~REDI.T..ARREARS
AND NOW. on this 15TH DAY OF FEBRUARY, 2006 IT IS HEREBY ORI>EREI>
that credit be given on the ahovll captioned case in the amount of $ 609,24
(i) is 0 is not an agreement of the parties to the credit.
. There
This credit is for:
\XI Direct Payments.
o Purchases made or services performed hy the Defendant on behalf of the Plaintiff or
children,
o Time children resided with the Defendant as agreed upon by parties. or addressed in a
partial custody order for the following time periods:
From to
From to
From to
o Other:
TWO PAYMENTS OF $304.62, EACH, WERE PAID DIRECTLY TO PLAINTIFF AND PAID BY
CHECK Nt~BERS 1606 AND 1615.
Plaintiff
Date
Defendant
Date
Service Typc M
BY THE COURT;
Q~1J'1\o' _
Edgar B. Bayley, -\:JuDGE
Form FI-002
WorkcrlD 21005
FES 1 ~j 2005
Date
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
CATHERINE J. SHOVER ) Docket Number: 98-2622 CIVIL
Plaintiff )
vs. PACSES Case Number: 6361QM_7
BLAINE F. SHOVER )
Defendant Other State ID Number: Ln- a ?
C-
Order
AND NOW to wit, this JANUARY 30, 2012 it is hereby Ordered that:
the Cumberland County Domestic Relations Sections dismiss their interest in
the above captioned aliomony matter pursuant to the parties' Marital Settlement
Agreement and the wife attaining the stipulated age of 59 1/2.
The alimony account is closed with no balance due.
a
o ^?
ac13 -r-
Mr a
rCr
2nd
n r''' D
6 r-
Service Tyoe M
BY THE COURT:
JUDGE
Form OE-520 02/11
Worker ID 21205