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HomeMy WebLinkAbout98-02780 I E 1. 3 y . - fgLt- Sx._ ? S { li 1 A Is 1. 3 • ??3 SS? f ' fF? F y 1 ? ? ' f 1 v ? A , p +?II i - Mlq? r C 1 !_ t f 1 4 A f;y 5 5 a4 F f %? _ 3 I:l 1 ?Tl A Awl r i 1 1 I 4ti, TODD ALLEN JEWELL, t IN THE COURT OF COMMON PLEAS OF plaintiff t CUMBERLAND COUNTY, PENNSYLVANIA ?E V0 t CIVIL DIVISION • LAW t No, 98 - 2780 CIVIL TERM i '' CASANDRA ANN JEWELL, t Defendant i IN DIVORCE :y ORDER OF COURT . AND NOW,'.ilils day of Dvccathor, 2003, the economic claims raised In the proceedings having been resolved In accordance with a Marriage Settlement Agreement dated December 23, 2003, the appointment of the Master Is vacated and counsel can file a proeciPe fix; transmitting the record-to . the Court requesting a final decree In divorce. BY THE CO RT, go; John H, BrolWos, Esgl, Attorney ibr Plaintiff (orkVIVe^? t ; Carol 11'Lindsay, Esq„ Attorney for Defendant cud: tA6,11 of r 'rr 4i t= t ? 1};?1 „, IN . A THIS Ill AN AGREEMENT made this vg 2day of December, 2003, by and between Todd Allen Jewell of 110 Westgate Drive, Mt. Holly Springs; PA 17065.2004, horoino#tor referred to as I{usband, AND Casandm Ann Jewell of 299 Holsors,Lane, Carlisle, PA 17013, hereinafter . refbrrac? to as Wi%;, WHEREAS 1, Husband"and Wife wore married on February .27, 1988 In 6611ing Springs, Cumberland ' County, PonnsylVanial and , Husband'and Wife, have throe children, Amber M, Jewell, born August 10, 1988; C,hyann R, Jewell, born November 18, 1996t and Kaltlyn N, Jewell, born November 18,1996s- and 3, Various difteroncos have arisen between Husband and Wife, whereby they have been tivingseparato and apart; and A, The partlos were separated May 28, 1998, 51 "Husband and ,Wife have agreed to maintain separate and permanent domictles and to live apart <rom each othert NOW, THEREFORE, for and in exchange of mutual considerations, and intending to be bound by the provisions hereof, Husband and Wife agree as fbllows; 1. Husband waives all-of his right, title, and Interest in real property and any claim fbr improvements to the property owned by Wife's father at 299 Haisers Lane, South Middleton Township, Carlisle, Pennsylvania, and releasos WifV9 father and mother of any claim relating to the property, Wife agrees to assume and to payy, any sums dua'prlbr to, at the time of, and attar the data of this Agreement and all judgments, Ilons notes, and other encumbrances claimed by her parents, relating to said property existing and/or recorded on the date of this Agreement and to Indemnify, save, and hold harmless Husband against any and all claims, causes of actions, suits, or,litigt4ticn for money owed, damages, indirect or consequential, Including legal &as, arising out of, failure of Wife to' comply with the above conditions, 2., Husband and Wife have agreed between themselves on distribution of pbrsonal props owinW by the parties; each conveying to the other all of his or her right, title, and Interest throe n, In rotum fbr his contributions to the improvement of the residence, Wife conveys to Husband all , ofhet right, title, and'interest in the Yard Man snow blower and John Deere riding mower, Each pasty t'eIM68 each other of any claim or right to the vehicles owned by the other party in the past and at the time of this Agreement, MARITAL SETTLEMENT AGREEMENT 3. II-ad party rolohms rho other of tiny olaim In alto orcdII otirds, dobts, and obligations of the other: Neither Husband nor Wife shrill contract, Inour, or be rosponaiblo ibr any debt or liability for which the other party In rosponoiblo and shall htdomulfy and save harmloss tho other party fl'om any such claims or demands made against him or her by reason of the orodit;curds, debts; or obligations As betwoon the partlos, Bach will maintain In his or her awn name credit cards and similar =,' ,aooounts, , A, Husband will prepare a QDRO according to the terms of which Wife would receive one. half of the marital portion of Husband's pension, the oovorturo fraction being comprised of a numerator which WIN number of months botwaon the data of the partios' marriage FebNary 27, " 1988 or Husband's data of hire, whichever Is later and'tho data of their separation,: May 2811 998, 'attd"a denominator which shall be the months of service of Husband'with his employer, The QDRO will call for Wilt to retain her Interest in Husband's pension In thoovenrof his death or her death and she shall be a surviving spouse to the extent of her Interest In Husband's pension, S, Husband and Wife will maintain all Ilfo insurance policies In oxistonco as of the date of this Agreement which policies insure his or her life and shall maintain the premiums thorcon, Husband shall designate Wife as the benofloiary of his life insurance policies to the extent'of his alimony obligation as her interest may appear pursuant to this Agreement, Husband will name as a beneftolaty fbr, the remainder of the death boneflt of his insurance policies a trustee, and Wife will maintain her insurance. policies on her life and will name a trustee for the benefit of the poles' throo children as more particularly set out on Exhibit A attached horeto, being the provisions for a trust which each party will incorporate Into his or her will within 30`doys of the date of this Agreement, Exhibit A In Husband's will shall be amended to add thereto a provision, . that will require the trustee to pay to the Guardian of the children, so long as they have not attained 18 years of age and graduated from high school, an amount equal to the support•paymont payable by Husband-to Wife, Indexed for the:cosfof living, The parties shall maintain life Insurance policies until the youngest of the parties' children attains 23 years of ago, From time to ilmo, upon the request of each party to the other, each shall provide to the other proof ihat the' 110, Insurance policies. remain In full force and effect, the premiums,paid, and that the benoflolary designations remain as set out in this paragraph, The trust provision shall.provido1br thp.trustde to ,pay to the ohildton or the custodian of the children an amount aquivolont to the last Dbmestlo ,.-.. Relations Order entered, In the Domestic Relations case, 6, Wife will be responsible to maintain and pay for her own health, medical, dental, and - ` hospitalization Insurance and programs, 7. Husband and" Wife will Ric separate tax returns for all levels of government, Huehyoatiati a mutually agreed date, Husband and Wife will evaluate the inoome tax situation and,agree oat" the child doduolions to be taken by each party, If a mutual agreement cannot be roaohed, Otte „, f ?t deduction (Amber Jewell) will be taken by hlusband and two deductions (Chyann Nttd Kalt,N t Jewoll),shall be taken by Wife,_ I- K >,r ? - ??i u e> r r a u 1 ?I r ai it i r?' TODD ALIEN JEWELL t IN THE COURT OF COMMON PLEAS OF !'lahttiff i . PERRY COUNTY, PENNSYLVANIA v t CIVIL DIVISION'-LAW CAI, ANN JEWELL i NO, 98- R.130 CIVIL TERM Defendant t ` i IN DIVORCE I _- " wrnm?rm mh tlli i'FNh AND CLAIM Rl(iHTSI . ME; '. LAWYER'S FEES OR EXPENSES, BEFORE A DIVORCE OR'ANNULMENT IS GRANTED, YOU MAY LOSE THE RLCi11T TO CLAIM ANY OF THEM, YOU SHOULD TAKE THIS PAPER TO YOUR :LAWYER AT ONCE, IF YOU'UO A NOS' HAVE A. LAWYER OR GANNOT'AFFORII ONE, Ci0 TO OR TELEPHONE HELP, ? ` PYou have been Nuod in Court, If you wlNh to defend against the claims Not forth In the "` ' ' following pagoti,. you must take prompt aotion. You are warned tllst if you fall to do go, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Cburtr A judgment may a1Na bo entered against you for any atitor claim or relief I•?duaNtad in those papers by the Alaintiffr . you may laNa money or property ar athpr rights' . ; .r • Important to you, including.custody or visitation of your children, When the grounds for divorce iN Indignities or itretrlavablo breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Arothattotary's'C?fflpa at the Perry. County Cnurthausa, Carlisle, Pennsylvania, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, A1VI$iCON.OF PROPERTY, :'...THE OFFICE SET FORTH BELOW TO FIND OUT VVk1EItE YOU CAN GET LECiAI. _ GRJMBEIif?ANp tX?tItVI'Y:BAti ASSOCIATION .. 2 -,LIBEIYPY 'AVEN(JE CARt.IBT,U PA 1707,3 ' 1W , ' '717 249 3166 TODD ALLEN JEWELL I IN THE COURT OF COMMON PLEAS OF P1411101T I CUMBERLAND COUNTV;'PENNSYLVANIA t v t`' CIVIL DIVISION - LAW CASANDRA ANN JEWELL t NO, 98-21W-) CIVIL TERM Defendant t IN DIVORCE COMPLAINT Plaintiff Todd Allen Jewell, by his attorney, Hrotdos & Gilroy, P,C„ sets forth the following: 1, Plaintiff Todd Allen Jewell Is an adult Individual residing at 299 Halserd Lane, Carlisle,, Pennsylvania 17013, 2. Defondant.Casandra Ann Jewell is an adult individual residing at 299 Helsgrs Lane, Carlisle, Pennsylvania 17013r 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of, Pennsylvania for at least six months immediately previous to the filing of this complaint, 41, The parties were married on February 27,' 1988 in Boiling Springs, Cumberland County, Pennsylvania, r, In accordance with Section 3301(a) of t11e Divorce Code, the marriage between tltq , P008 Is Irretrievably broken, r„ „ 6, Thero'have been no prior actions for divorce or annulment between thq pip4,'lq or any other jurisdiction, 7, Plaintiff has been advised that counseling is available and that Plaintiff nt#y i' R- ? Wkil ikk ?. right to request that the Court require the partles.to participate in coon illhg,'.. i 4t "; s l Y" t r 4,f 1-" PTY 1 IT I; l ZJ ? ' `' •j Y? .!Y . ill i ?l qL? I_ i .. n Y I•(!" 1 1 T e J y 1 l?11. 1 • . ?' , '. M lvl.,F I:' _ 1 .. .:,, .4p 1{, ,M _ • 1„l ri TODD ALLEN JEWELL* t IN THE COURT OF COMMON PLEA& OF Plaintiff I CUMBERLAND COUNTY, PENNl9YLVANI4 V, t CIVIL DIVISION - LAW t NO 98 • 2780 CIVIL TERM 6 CAl AN 1A ANN JEWELL, t °. ; Defendant r ,. t IN DIVORCE I: . PLAIITIFFIS AFF'IDAVIT,OF-CONSENT AND WAIVER OP NOTICE r OF INTENTION TO REil)VEST ENTRY OF DIVORCE DECREE I UNDER §3301(0) OF THE DIVORCE CODE 1,11 A Complaint In Divorce under Segtlon 3301(o) of the Divorce Code was flied on May,1 S, c `131 , 2, Defendant acknowledged receipt and accepted service of the Complaint on or obaut May ,20, 1998, 3, .' An Amended Complaint In Divorce under Section 3301(o) of the Divorce Code was flied,. oit October 31, 20000 A.' '• De%fiddht acknowledged receipt and accoptanco,of aerOoo through her attorney of the Amended Complaint on or about November 1, 2000, $, The marriage of Plalnuff and Defendant Is irretrievably broken and ninety days have Iapse c'd om the'date ofthe tling of the Camplaintl .: b, I oonaent to the entryof a flnel chorea in divorce without notice, 7. 1 ,understand that I may Icsa rights concern ing alimony,'divlsion of property, lawyer's tbos ; f or oxp6naos if l do• not olAim thom bofbro a divoroo is gr4hted, I understand that I will not be divorced until a Divorce Decree Is entered by the Court and that a copy of the Deoree Twill be sent to me'Immediately after It Is flied pith tho Prothonotary, ". 91 I have,beon advised of the aVallabillt of marriage counseling and understq':a tl.at I may request that the Court require counseling, I do not request that the,Court require oounseling, E{' I vorify that the statements made In this affidavit arc true and correct, I understand that fklsa statements herein era mado subject to the penaltiea of Is Pa,C,S, saot19nA90 4 tit to ' unsworn tklsifloation to authoritlos,r Datet _L1r7L ?- .,_. dan' ew hint n ? , n m , ,i lie 9. it r • ? r _ ... r !1 ? 1 7o- = M i1 i.. l i TODD ALLEN JEWEL L, t IN THE .COUIt' OF COMMON PLEAS OF Plaintiff I CUMBERLAND. COUNTY, POMYLVANIA r. r r Vey t CIVIL ACTION LAW t ,. t CAOANARA ANN JEWELL, t NO, 98 - 2780 CIVIL ter. Defendant t IN DIVORCE CONFERENCE WITH COUNSEL AND THE PARTIES "' TOt John J, Braudos , Counsel for Plaintiff Todd Allen Jewell Plaintiff Carol J, Lindsay Counsel for Defendant Casandra Ann Jewell , Defendant °.. A conference has been scheduled at the office of the DiVorce Master,, 9 North Hanover street, Carlisle, Pennsylvania, an the 11th day of July, 2001' at 200 0,m, , ' °._ With counsel and the parties . to discuss the outstanding economic issues to'determine if there is a basis of settlement of claims, If issues remain after the ,.; conference, a hearing will "be scheduled at another date ,.. ` ,. .Vary truly yours, fi : •r. r ? - Date of Noticei J 3 E, Robert Flicker, II •;. une"1 , 2001 Divorc® Master r v TODD ALLIENIMLU; t IN THE COURT OF COMMON PLEAS OF Plaintiff r CUMBERLAND COUNTY, PRNNSY4VANIA W. t CIVIL DIVISION - LAW CASA,NDRA'ANN 4EWEL1., i NO, 98.2780 CIVIL TERM Defendant i IN DIVORCE PLAIN FF, _ +S ADD?I?M m0 PRI?.TRIAI; AND OTHER M?MQRA? N sw During the pro-trial oanforonco, counsel for the Wife indicated that Husband during the oariy years of marriaga took training and developed his skills as a computer tochnioian, whereas " the WIN was prevented from improving her education and training and earning capability because of her care of tho children, Counsel for Plaintiff obJcatod that this was a now argument of Defendant's counsel and ,. that the hots of the early years of marriage and the educational and training Issues were more bomplex; It was only a period:of apprgximatoly one year that this issue arose, Husband had ono yoar'of A two-year program at Thompson Institutor He stopped.sohooling for one year and did not complete schooling since he had to work to maintain the family. During the first year, he had'a wife and child in a trailer. When ho'raturnad to sohooiw jo hold three jobs: at a record store, the Lobster House, and Festival Poodsr i'. During-these years, when the parties lived 6a house purchased bythp father o f Wifm,' "WIN ts family was only a short distance away, it was and still Is cdequAte babyslttln$ and,.. ayoara, from. d a sister and the mother. F 4 r' ; 'r i Husband oontinu usly and persistently encouraged with to take claasas, even At a'W, ,? z , r ;= school'. P; / 1, i try I?? ? ? ,. - ,+ . r. .. _ r is 1(ei4P ;t;Y??f.• I I :.. ,. TODD ALLEN JEWELL, t IN THE COURT OF COMMON PLBAS Gf' plaintiff t CUM13ERL,AND COUNTY, PENNSYLVANIA t V8 t CIVIL ACTION LAW , t NO, 98 2780 Civil' CASANDRA ANN JEWNLL, t Defendant t IN DIVORCE ' ZMSCHMpULjn PR E-IJEARJUn C QNFBB MNC3 'TOt John J, Sraudos Counsel for Plaintiff Carol J. Lindsay , Counsel for Defendant A Pre-hearing conference has been scheduled At the g Office of the Divorce Maste r, 9 North Hanover Street, Carliale, Pennsylvania, on the 13th day of June, 2001, at 9130 a.,m,, at which time we will review the pre-trial ., statements previously filed by counsel, define issues, identify witnesses, explore the"possibility of settlement and, if necessary, schedule a hearing; E Very'txuly. yours, . Dats'of Notioet 5/21/01. ;:D; Robert'glioker, IT .Divorce Master F_, . p J ?.I r+41 oil 'U I r I. i TODD" ALLEN, JEWELLe' 1 IN' THE COURT Or COMMON PLEAS OF Plaintiff 1 CUMBERLAND COUNTY, PF±NNSYLVANIA . NO. 98 - 2760'CIVIL CASANDRA ANN JMWZLL, t Defendant 1 IN DIVORCE.. TOt John H+ Hroujoa , Attorney for Plaintiff Carol J, Lindsay , Attorney for Defendant DAM Tuesday,: November 71 2000 ` rr n , r: CERTIFICATION I certify that discovery is complete as to, the claims for which the Master has been appointed, OR IF DISCOVERY IS NOT COMPLETEt (a1„ Outline what information is required that is not complo e.ih order to prepare the case for trial and indicate whether there are any outstanding interrogetoriea or discovery motions, . „" 1. I• (b) Provide approximate date when discovery will be oompiexa and indipate.what action is being taken to ad olete diacovery'i DATE COUNSEL FOR PLAINTIFF ( ) . COUNSEL FOR DEFENDANT O NOTEI PRETRIAL DIRECTIVES WILL NOT BE ISSUED•FOR THE { R'I'LING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE . CERTIFIED THAT DISCOVERY I$ COMPLETE, OR OTHERWISE' AT.THE MASTERIS DISCRETION, AFTER RECEIVING THIS'DOCUMFINT FROM BOTH COUNSEb " OR APARTY TO. THE ACTION IF NOT REPRESENTED aY _•- COUNSEL,:INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL, , STATEMENTS WILL BE ISSUED AT THE MASTER'IS DISCRETION HOWEVER,- IF BOTH COUNSEL, OR A y' PARTY Not REPRESENTED, CERTIFY'THAT DISCOVERY IS. COMPLETE, & DIRECTIVE TO FILE PRETRIAL, .• STATEMENTS WILL 'BE ISSUED IMMEDIATELY, THE CERTIFICATION DOCUMENT SHOULD BE`RETURNED TO THE MA$TER'S OFFICE WITHIN TWO (2) WEEKS 01 THE DATE SHOWN 'ON THE DOCUMENT . t • TODp ALLEN JEWSLL, r IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA- Vo, CIVIL ACTION DIVORCE : NO, 68.2780 CIVIL TERM CASSANDRA ANN JEWELL, Defendant IN DIVORCE , TO THE PROTHONOTARY; Please enter my appearanoe on behalf of the Defendant, Cassandra Ann Jewell, In the above naptloned osse, FLOWER, MORQENTHAL PLOWER 8, LINDSAY, P,C, Attorneys for Defendant By, V; QA. arol J,1 ndsay, Esquire Id#44 3 11 East High Street Carlisle, PA 17013 (717) 243.8613 601 '`" cA) J1 MW uI3NN3d M WOO 0411HIONno oYW, Wd i-AUN01) KI.P0 ?Jrl'IIa ' y?x .r BY 3 \ file; Ilb January 22, 2001 TODD ALLEN JBIWIll I IN THR COURT OF COMMON PLSAS OF Plaintiff i 'OUMOOIRLANO COUNTY, PONNSYLVANIA Vol _ CIVIL DIVISION - LAW 1 N0,-88.2780 CIVIL.TBRM OASANDRA ANN JBWfILL,. t Defendant r IN DIVORCE! NOTICE YOU HAVE ORIN SURD IN COURT If you wish to defend against the claims set forth In the following pages, you must take prompt action, You are warned that If you fall to do so, the oese„may proceed without you and a deoree of divorce or annulment -may be entered against you by the Court, A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff, You may lose money or property or. other rights Important to you, including custody or Visitation of your children. When the ground for 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, Carlisle, Pennsylvania, 17913, IF YOU DO NOT PILE A CLAIM FOR. ALIMONY, DIViBIQN OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 (717) 248.3198 SAIDIB It ?HUFFi FI OWF j ? et LINDSEY 66 18 W. NI h street WIN s, PA fllei Qb January 22, 2001 is 12, The answers to the paragraphs of the Qomplalnt 1 through 11 are Incorporated herein as if set out In full, Y 13. Defendant is without Income sufflolent to provide for her reasonable . needs or to pay the attorney's fees Incurred In the defense'of this case, ?;. WHEREFORE, Defendant prays this Honorable Oourt to enter a Decre I e n Divorce, divorcing Plaintiff from Defendant, equitably dividing the parties' property, awarding to defendant alimony and reasonabie'ott fe ornsy's es, SAIDIS, $HUFF, FLOWER & LINDSAYr Ppd. Attorneys for PlolntlH By: rol say, quire # 93 2 eat High Street Carlisle, PA 17013 Mot (717) 243.0222. F. sA1Drs SH11"t FLOWER , & L1tVp8EY , i i = i , S6 W, IIISh 81f611 _ ?u , WIN -PA Fes- r ? f ` ( ! • 4,72_+ =9 s i tllal iJq January 22, 2001 „ _ ., rOpD A6t.BN J?WBt,I?, ,. I IN THt'1 OOURT QR QOMMON PI,?A? GP ,, ' ? Pisltitiff 7 CUM?RRIANG.QpUNTY? PQNNBYI,VANIA ` r ve,.. t OIViI. pIVtBION ? LAW ; ? Nb, 68$780 OIVIL TERM , + -'oABANDRA ANN JtlW6t,hr r " Defendant r IN DIVORQ? •• ,,. ?:;' .' ? ?Rx1F I SATE, QF. ? ? Rvt c ? AND now, this ? ?,, ??.?- ;day of , '; 2001, I, Carol J. Llndaay, Esgralre, of the law firm Wr~R, ? SR ? IINpt3AY ' P,C„ Attarneya, hereby oertlfy that I served the'v?Ithln Answer, and Countar•Claim this .. day by deposlting same In the Unltad.States Mall, First Claea, Postage f repaid, In . ,. .r`f•: ' ?arliale Pennsylvania, addreeead'ko; • John H, BrotaJps, Esqulre , BROIJJOS ? 411,R0Y, P,C, , ??' ' A North Manover Street.: ' Carlisle, PA 17013 E_ SAIglB, aHUPp, RLOWBR 8, t,INC1t#AY, P,C, ,. . ? ?'• Aktorneya for Plaintiff ?' gy; • ra J, Lindsay, sgrafra 893_ 2 eat Hlah St?$et ) ' ? Carllale, PA 17013 , ` 1ti SAtI ? (717) 23.8222 8Ht1FF, Pt.OW6tt ? & I,INpALY ' ' ? ? . ,, qb Wi tll h Blreat ,. CIrf11?0i p? AI?1 Qb" Maroh 13, 2001 to reslde in the house, .Wife's.parents'pald the taxes and'ansurance, hlusband plaimp that he. Is entitled to oompeneetlon for some money he put Into finishing the basement In the house and a garage, ., Since theirseparatlan, wife has obtained port time employment once again, She epms $60 per hour at Chapel, Pointe Nursing Home' as a receptionist on ' ;. weekende when the children . are In their father's custody, that Is alternating weekends, In 1999, husband had a gross Income of $66,92614, In 2000, he had gross ti. Income of $87,011,5Q, AiA,attl s The assets,of the partlee,are comprised of the following; I ; a) 199$ Pontiac Montana (estimated equity $6,000,00) .' b) 1994 Pontiac Strand Am (estlmated.equlty$6;000,00)' b) John Deerq lawnmower d) Snowblower e) Vorioua accounts In banks, satisfactorily divided Furnlshinge, satisfactorily divided g). Wlfe's $1,000,00 Certifloate of Deposit, part of which Is non•madtal because It derives from a pension partially, earned prior to separation ' h) Husband's pension with the State 1?` lh N?NAARITAL4ASSETS; r ' The house In which wife reeldse belongs to her parents, Wli had lxtO she' POO k of Keystone Financial stook given to her' by her parents prior to her merrlp c , g ?iM1fl" w Y'ttL j..?\a •ilW{1!_ a 1 e 1 1 el4f.(. »lp\a...a64.i?Gf? 01°' qb ' March 10, 2001 „ IV, T WIT @88E8; '. ll =.. Wife anticipates none except for a pension appraiser a , V1 IhP?Y?1LN?8Bee; ; .` VIC! Wife will present the testimony of herself and also of her parents tb the extent needed to establish thelr ownerehlp of the' home in which Wife resides, vf, € e), Wife's Income and Expense statement' b) Husband's W2 form for 1888 o), peed to the home In which wife resides ' ' d) 4wsleal of Husband's pension s); .' a Such other exhibits as wife shall determine necessar and shall- id y prov e to oouneel In advance of the hearing, " k' VIC l lj; Wife some net Income of $260,00 per month, Attached hereto is a most ; ; recent pay stub, and her 1099 Federal Income Tax R t RA ?i e urn, ffi- VIII ; + " E 4, An,expenso statement will be provided ' , IX ' RRNBI{ N . : Husband's pension has been valued by Pension Appraleefe, (np,' tak ' a $22,773,28, Wife reservee the right to: have: that, appraisal .revlewed py ?a {4eia er In light of husband's becoming vested In the state `smpioyae, Rek.ittteift system Pension plan, ,. f e f, $ i €t fllei Gq Mrroh 13, 2001 :. ?- t 1 ' It I , X ,.NBgr It Wife olelms oounsel .fees` and will provide a statement of fees Inourred In kh h ., e e,. divorce aotlon prior to the hearlnp, XI, , So, for as wife knows,'It has been eatlafaotorily divided , Xlf ` MARIT uNmx f So for as wife IR aware, there Is no marital debt, ' ,I XNh ' P.E?4 , 1W liz- Wife seeks sixty (60%) peroent. of husbands pension and alimony in an amount sufflolent to provide for her reasonable needs,, 9AIbI8, BHUPF, P40WER A LINDSAY pA , Attorneys for Plaintiff I By arol, nq say, ure 3 t# 9 ? 2 eat Hlgh Street ?_ Oarlisle, PA 1:7013 ` (717)243.8222 E I. •? w,,.M,w.???,1?„1YkW Mme,. M. wugw wy.f?w?w.,,rMMwi f.« `. . •.+ •uv .«a.?.....?. 1 OHAPIL POINTS . ` `. 5 , 10 NO. PT - dMPLOVIINA MI OOIALIN URI NO, PIRIOD$44. p RIOR N ONION 0, 031306 RARNINO/ NAI NI ? ' RR NT AMOUNT YIIAR TODAN Q8 UOTIQ I DURRINT AMOUNT -1Ap TO RATE RESUOR 18008 100,00 131i1. fld' p?51' X00 ilA oil CIV?RTIM6 90 .00 37i,150 -.. FTEDERAl. 00 1 ,5 1S,, QIQK` , IW ht&? 13w Fm) fik. trO v5fa. Crt ' OTATIS Ali 00 . C9'+ 1.X10• G,91 M-r-ARG 1, kk4 &. lit E;. WV k 5 ? f,. is I. Rd PAY 1?.1b?1 , 11, 4 59 Oaf 0 6 ?tl, G,3 53. ' t50 , 5; _; QURRINTIIAgNINq! QURRDNTgppU0TI0N9 NAT PAY YDTIARNINOg YTDQIDUOTION4 ;`YTDNKT'RAY " , ? ep .. x}1.040 •Penmann1ol the dIvTreoeu nlnrnelnevonuenarvlo. 999In?, . Individual l Income Tax Return (eel meUOioniy-OOnolwnuo nipunlnnrpiae n the ' a n. I -060,31. 1091, of other tag volt b not tips, nth - OMB No. 1044.0074 ha bol our re nemi an n l lee nami our 1oa a efeur y m r n e Todd A Jew 11 218"60 1090 ?a?ruollons) 11 a o nt n um. "P-Viii rs name 400 n I6 ail name p9ll1i f i0! Nf t y nUm _ r theIRS 4 Caeandra ?A Jewell 17112.0932 }?$ ell, H oma•ddnu number an etrep).I you .ve'a „bo1,n!murudiwnu p,no, I IP?ORT ITI ppleiee print Hps8 8 M1,dland Or ve V9uf 80_nM 10p4e 9r type. M ty, totvrl ar po11 o IPe, 1 alit M x Woollf you have a Oren eteil. eQ x 1tr4ot 9nb a Mb, Holly Springs pA 17088 n a' ) np a n al NI n 4 yDU want o go tot r.fund7 . . (Sere ?ner AMEI.P q?olnl return, Is Your apoua/ wen1801d pa to title lundll .. , . x 1 1 Hats ' tilting BtatUb 2 Menisci filing joint refum (even it only one had lnaomil ' 10 nerve nee. e? a Mauled filing separate returns Inlet rppwap 'IN 40yo 11 4 Mead of household (with gvattlying person). lose Instructions,) It quslltying pafoglj 1rlf Alto but not Your dependent, Check only enter thls"ohiiq's name hires. one box. e auapl In widower) with depen en child Yeat.spauae a ea lee netrupl ns, . I Yaurseh,11 our parent (or someone life) can claim You as a dependent Ito or her tax e i b h hex ens f du b 2 Oxemptlone ox s , ... , .. ec retum, do not c ih8 ?nne n r e k ;. mo 1i pp ppopn,?sp+u1pft {n! ?9 uy a e en ante all l 1o Mnainreel I { a114y"u r1??lipnefMplQYGU ?1?11 wh r ui e? ? l - 9 l il . ( Li11N,M 1 nlni nine I W W .wllhyou ...a... we eW au 9et•, r tll n0 II Wllh .. ul?prewa i yy ? It more man six ann ewe a4tq err , e ? n ? t dependent., see Ineirucllona. n ewe au ar uu lfonq le i w e dent+ en k noPifitaradewyp Atld n ban n11rt g bava ?nio d Tol 1 number of exem tion$ Claimed . '... , . ? 10 income 7 Wages, $$leftist ups, eta. AhaOIl Form(s) Will ..... , . , . .. .. . ' D4 lolid ' Sa + .. . . `Be Taxable interest, ' Attach Schedule a II required , , .. , . ?ol YoUtPorm. b Tax-exempt Interest, 00 NOT Include on Ilse 8e .. ;, 9b 0 340 •2 and W20 9 Ordinary divldands, Attach Schedule 8 If required', .. .. ..+ here, AlIea 10 Taxable refunds, credits, of alleete of .tats and kcal income taxes (too Instructions) rmp) attach P 10e9•R I?tar .: Was wit he d t 1 Alimony received . , .. , . , .. 1 t 0 , 12 Susineas income or (loss), Attach 84hedulb 0 of 0.82 ...... . .... . . . • . , . 0 10. Oapll41 gain or (loss), Attach Schedule 011 required, II not required, oheek here w 16 ! (IQedes). Attach Form 4797 ......... , , . , . to Other gains Or a If you did not . b Taxable amount (see Ihet.) ei a W2. 104 Total IRA dlelnbullona . , .... .. , . l Bas Instructions.: 9 q,, b Taxable amount (see Inst,) tea Toie(pansionp A onnultlea '? . 11 Rental real aelate, royellle6,;panneiehipe; 8 corporations, Iruele, 6fo. Attach Schedule a . . Snoiose, but do. 18 perm income or (10481. Attach Sohedule'P , .. .. , . not staple any to Unampitiymenl OOmpenlat(on . • .. , , • . , , . ' + e 9e tt, loo, p pole 800141 Wwlly benefits . II goo I I b Taxable amount (sea inel.j. _ 1 1 Rot -- l p use Form 104o•v, . ft1 41hef income, Llei type and amnuAl.-toes instructions . T _ I. 4 w. a,I ` o r 6 2 Ad n n h 1 I n;f rlln r h I,rllsl Adjusted 2d IRA deduallOn (sae Instructions) • . + • .) • . „ y Qr089 ... 2A • " 91udsn1 loan Interest deduction (sea Instructions) , . Ahaoh Form 0003 • ... s account deduction Me' loot.aVin 28 Income , g . ; 28 Moving expensee•,Altach porn 3000 , ...... , , '. , . . 27 Ohe+hal( OI'sdf"employment tax, Attach Schedule 83 , . II'` 28 Self-employed hooll msuranoe deduction (see Insu folignal . _, " 24 Keogh and self-employed 8813 and situp is piano , , , • • • =, 00 Wally on early withdrawal of savings . '. , .. , , .'... 00 01a Alimony pall b Reo(pienl'o SBN 0 ,. 32 Add (Inds go through ata • • ..." . . .. . . : . .....:.. . . .... . . . 1. • f. A is §Wlittaot line 02 from ling 20, of Ti IMCOMI Cal. NO.f0I0S' % Inn flail norm io4o1 Qeal Todd A Jewell 216.60.1030 Pee a n4 Amnunr Imm 11nn 09 Innlutbul nmad Ine.nmel . . . . . . . . . . . . . . Credits 35s Oheok Ih LJ You were tl0 or older, ? Blind; ? spouse was so or older, ? Blind. Add the number of boxes checked (love and enter the total here , , , , , , , ? 3tla 0 ha d d 4n b II you are marrlpd filing s?pgrataly and your spouse Itemizes deductions or ? ou were a duel status ali n see Inpruollone and check her ? 36b ,i ' ` N e , y o 0 ?i f Oa gnt?u 11a lu er air r ItnI dMyation Iron S In ule A Iin 8 AN et d rd ; I lPtt, lie 111elruo?lons Io Iln oUr e?ania u l?On I?you ? e ? a ;i ! W jr, O ? ry ke 9n x orl d a ec Y 0t or II someone can a Im you as a aspen em , , , , 7,513 front line lr0 a1 b n B 1 ears 00 ,, 1 J Il p n a6Ae9 a of 11111 3 1%8x;700 p the 10 141 rlumbfr of exemptbne cl0lmad on ?In1 11ne g4 4 ovgr 41B7?, tlla the wo1Ne11eH In ills Instruction IOr the amount to enter 17, 750 ? n 30 Ta%eble Income, Subtract line 00 from line 37, II Iin 36 Is mgrs Than tine 07, gnter,0- 3 a ,A 7 3 I 113Qtl° r 40 Tex, Goo Instrifatlone. Oheok 11 any lax li from I Forme) 6014 b Fofm 4878 ? 41 Credit for child p dependent care expensed: Attach Pam 2441 Idl leh4 ° 43 Credit (Of the Olderly of the dleabled, Allaah Schedule R ; , , 4q Child lax oredll(set lnelryrotione) 44 Sdugallon gredll,t. Allaah Form 8883 48 Addooplbn Credit. Atlaoh Form 11,030 , , , , , , , , , ,, , , qa 40 Forrlpn to%ondh Atlaoh Form t 118 II required , , , , , `tj, 47 0 er Oheok If from M Form 3000 b Form 8388 O Norm $soI .d sperm (speoly?; _ 0' 'i 4 8 ' Add lines 41 through 47, These are your total oredlls , ::. ', , ; , ; , ; , , II , , ; , > 1,500 $1 ? Sultrildl line 48 from line 42.111102 46 Is more the n Ilge 40, Intl( io. rr Other 00 Self4employmenl tax, Atlaoh boheduie 88 Taxes $1, AllernallYa minlmoih In, Attach Form 6011 : , , ,'.., , , , , ,., ', :. , , , ,' 04 social security and Medlokro tax on tip income hot reported to employer, Attach Form 4137 63 . Tax on IRAs, other retirement plans, and MSAs, Attach Form 832811 required I I .I " --- 04 I Advance earned Income a,edll.paymenls from Form(s) Wag , r .., ... , , : ti I , 08 Household employment taxes. Attach Schedule H ::' 00 Addttn e48 hMU h$so T1110 ourlatal e% ,, , , , , , , ,., , " , ? 8 Payments 07 Federal Income lax withhold from .Forms W,a and 1088 off ' ore ,1800 estimated lax payments and amount applied from Igoe return JJ bee Settled 111oorgi credit! 'Attach 8ahed, 610 11 you have a qualltyln Child b Nontax bla eerned Inoomal amount?l 9 L , ?i , •, . 00 Addltional ahildlax oredlu•Attach gorm 0018 01' Amount paid with Form 4690 (reguesidor extension) , 00 Sxaeae social security and'ARTA wllhhold (eeq huctions) 03 Olhdr payments, Check if itom a Farm 0490 ben Form 4108 64 : Add Ilh00 07, 0$8 064, and 60 Ir rou h 63, These are Your total a m ettle , : if , : 44 , B , 0 01 e Refund so r , II line 641e more than line eq, eubtr4oi Ilne lisfrom line 04,Thte to th e amount yoYOVIRPAIV? '68 l you w I e6s Amount of Tina 66 you want gflFUNgsq TQ YOU Bee ? a ? b Roullfrg-number 1 ? C lypel © Qhookin3„Q Bavinda sn? ? d Account number 67 ' Amaun of Ilyd 66 you want ARPUloTO YOUR 1* a TIMATIO TAX Is. 1 7 Q Amount You Owe 06 II In tle 10 Moro than ilne,84, tWheat line 64 from line 08, .This Is the AMOUNT YOU OW11; Rt]fstalls on how to pay, sea Inelruatione ; , , , , , , , , ;, , , 4'. , , , 1 i l € , s,, .,1= sign u r nallia/ of p,rl AN I kml Ihia roam a le MO aiera iv: e n,llb ltlYOUr YOUrood upl 3 I Op Qom u Yl . p e M' X Q e icopy of - N'.. q nu 1 114'0 Intlelum, GOT talon rla; ' Aaif , o } Sa L, • • Va Nduse t a 5 Fold Preparer'e qb ' iw'I?164:e t tF +' Use Only i § All 11 .. T .., » 1, ;01411 i .l _"?.?w1 - 11 .0 o ni Ib uro Acquisitions o'Ca hal Asso sand Income o n; ant lives In the mate prov, ously ooeupio jointly by t to;parties, The parties made a dooislon to build a new home In 1990, Tito Father of Defendant oflltrod to build the (tome with rho holp afPlaintiff however, taking title It, the Fathor's name. Tho understanding was that the house was to be their house, Pay;nonts on noeounrof the mortgage and expenses Were made by Plaintiff and Dcflmdont; whereby oftor a period of time the house was to be conveyed to both pantos when they could finance the house, InIthot, the parties were capable of Onanoing the house Records were koiit Indicating the amount ofoontribution of matorials, Plaintiff asks the Maxtor to find that there was a resulting trust in the arrangement for construction of the home by the Pother and Plaintiff for the bonoflt of Plaintiff and pofondunt, All the elements ofa resulting truest are present; an agreement alboit vorbal; the intent to hold thlo' to the property for a period of time subject to a mortgage obtained by the Father; agreement for periodic monthly payments toward the cost and expenses of taxes and insurance of the house; an agreontont''for transfer of the property when Plaintiff and, Defendant were capable of flnonoing; and substantial contribution by the Plaintiff In construction of the home fit the Ibnu of sweat equity and by payment by both Plaintiff and Defendant of over $18,000 in labor and materials Ibr completion of the home. The home offeotively Is the property of bath parties under the resulting trust, with the property' title hold by the Father, : Consequontly,,tho equity In the house constitutes marital property And the Court is aakod to dotormino the equitable Interest of both parties. .rr Tho slgnifloanoo of the rosulting gust theory Is bhsod on unjust enrichment, Sinoe'the house is presently in the name of thc.Pathot of Dependant, the title will remain 16 the Father_ no action " need be brought In Common Pleas to Impose the equitable trust; 'the ivipstor Should eonslder.tho opportunity of the Defendant to reside in tho house subject to the contribution of the parties in sweat equity and In purchase of supplies; all of which combined is to give to the parties an,,,. equitable Intarost that can be used to oftact any distribution sot.by the Maxtor In the rotle6mr nt benefits, ; ?r In tho,gaga of Wolf y Wolf v John 8, Wolf and Oraoo Y Wolf (parents), 514 A2d 901 (P4 Super 1986), the court allowed Plaintiff husband to bring In the parents of the hasbandras adoitionp 'rr defendants for the purpose of dotermining if uniupt enrichment ocourrod and wtt¢ther a resulting trust could be tbund in favor of husband and wife, for the purpose of providing,wltb roimbursomont, far her contributions for lmprovomonta, The court tbund' a resultit,g trust; y ,r , I i a? In this present vase, Plaintiff has considered bringing to the parents as additibnal dotondants,, uw 71 '? has decided against that course in the Interest of avoiding a burden of opsts and`logal0?oot gtj p s {fr}1 " ; ' , on the grandparents of the children, Plaintiff does consider the evidence of 4uoli an agreo'ntbtlR' and relationship rolevant as on equitable consideration In distribution, • i1 1 ! {1 t i1 I }? ,??} x71 1 1 ? i . 1' • I 1 .r j ,F a J , ?i E ( j df CJ .: ts?t?i/ t s 4 1€;._\• - 1 I C.It ar Fyl taM t... yl,r t, to p11or 1119 fle4works on July 4°1. In.the event that the Monday holidays fall on Father's ' " Wookond,,thon pathor shall keep the children Sunday night 01401 1 , S The Christmas holiday shall be In two blocks which the parties shall i11tornate, Block A shall run trout Christmas Eva at 12,00 noon to Christmas Day at I$100 noon and Block B shall run front Christmas Day at 12tOO noon to Docomber 26, at 12100 noon, `Mother shall have Block A In oven numbered years and Block .B in odd numbered years, Fattier shall,havo Block A in odd numbered yours and Block B in oven numbered years; 6{ The parties shall split and alternate Thanksgiving, and Eastor from 9100 lam, to 211)0 p,m,.and 2100 pint, to 9100 p,m, 7, Now Year's shall be divided Into two blocks which shall be alternated by the partlos Block. A. shall run'from Now Yost's Eye at 60 pan, to 1100 noon, Now Year's Day and Block B shall run from Now Year's Day at 1100 noon to. January 2 at 12:00 noon, Mother shall have Block A In odd numbered years and Block B in evon numbered years, Fathor shall havo Blook A In even numbered years and Block B In add numbered years, ti, Mother shall have physical custody of the children on Mother's Day; Father shall have physical custody of the children on Father's Day. Custody shall' be from 9100 a,m, to 9100 pm, on those days, 9, Father shall have physical custody of, the children on'tholr birthdays'fbr four (A) hours on school days and six (6) hours on nan-school days, birthdays shall be considered a holiday, for transportation purposes, a Of Each parent sholl,bo entitled to vacation custody with the children for ton (10) days each year with no more than seven (7) days being consecutive, Each party ' shall provide the'other with at least thirty (30) days advance notice of their Integtto oxeroise vacation oustody, Each party shall inform the other pa?y of the dostination and a'Phgae number whore the children oan be reached if one is available, Aver night stays for Chyami and Kaitlyn shall be upon agreement of both parties, it, Each party shall provide prompt notice to the other party of any emergencies that arise in connection with the children while they pro in their custody, I if 12, For oxcltanges of oustody, all adults shall conduct the exchange in a oooperativo and civil manor w,tth concern for the children's well-being, t 13, both parents pledge to refrain from doing or saying anything which may estrange the children from the other parent, Inluro the opinion of the children as to the other parent, or hamper tho freo and natural development of tho children's love. and respeot fbr'the other parent, IM , 1 1 ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State hp/pgDtIVIVACle 0Original Order/Notice Ca,/Glty(D st, of o all" 0 Amended ArdarMwlca Date of Order/Nutice 03/20/05 ®Tarmlrple OMar/Nalico Ga a Number (See AXaduffi Case summary) RE, saw TO RD E, oyes r o er'r ra erp N um r Erne oY O Igor a Nhme Caar rn, M OFFICE OF CONTROLLER mP oyes ? sor s Social ecuB rr ty wrri r o/O HOU0111 OF RaFRIOWTATIVasa r //F!t S /9F9 s Q a_ . .. RM?0 l?ifksr$?9/ao/?7 mPoyeu LlfeerT?s w anTillet .MAIN'CAPITAL, SWO face Addendum /aplslnNHnamq HAARI89URd PA 17120»0001 9p P710 COW- ApeeclalMWRh""'ona#schmea0 h3rr S 709/ ol.% f? u't p anent a ame art, rr6 Mlr? 3 Sea Addendum for dependent names and birth dates ass0clated with cases on attachment, ORDER INFORMATION, This Is an Order/Notice to'Withhold Income for support based upon an order for support from CUMBURIM -;County, Commonwealth of Pennsylvania, By law, you are required to deduct these amounts from the above•named'employaefs/oblIgor,$ Income until further notice even if the Order/Notice Is not Issued by your state, b ?,_ ,, o 0o per month in current support E _o. ob per month In post-due support Arrears 12 weeks or greater? Oyes ® no $ o, oer month In current and past-due medical support $ on?Oo pper month for genetic test costs $ per month In other (specify) fora tote o , 0.00"par 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 withholds $ ----- o . a n per weeklyy pay period, $ . n, oo parblweekly pay period (every two weeks), $ p . no per semimonthly pay period (twicea month). $ n ,Doper monthly pay period,: REMITTANCE INFORMATION, You must begin withholding no later than the flrst'pay,period occurring fen.(10) working da s 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 cast 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 Informatlort Is ' needed (See #9 on page s). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU)'Employer Customer Service at 1-877.670.9880 for Instructions, ' 1. Make Remittance payable tot PA SCOU jr .1 Send check tot Pennsylvania SCDU, P.O. Dog 69112p Harrisburg, Pa 17:1069112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE P, CSES )MEMBRR Ip,tfii above as the Employee/Obligor's Case Identifier) OR, SOCIAL SECURITY NUMBER IN ORDER TCi. P1 Qgg?gO? ' DO NOT SEND CASH BY MAIL. ,Y.;1'I l COURT,' Ilk Date of amen MAR 3 0 2006' KEVrrv ? fr?ss ' Service Typa, M ' Form K0141 OMe Nod 097"131 WorkerlQ.. 'OTATT.! ;' ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS I hecl?e l ?o?aro r?a?rlra? to pr?ryIfla a arri of ?s feral to your m'doyno IIry mplogy1 la In n da(tn+ha?le d<I?aron ro le uu hat seua 111 s ease , cot mus bo rovl80T in YoIr 0411011 o ao ev n f ie ax Is nn c 1ec ed, 1, P?Iorityc Withholding under this Order/Nndco has priority over any other luggal process under state low agalnst ilia same Income. Federal tax levlos In effect before receipt of this order have prlority. If there are Pedaml lax Willi rt effect chain contact the requesting agency listed below, 2. Combining Payments You can combine withhold amounts from more than one amployeAlillgor's income Ina single payment to each agency requesting withholding, You must, however, separately Identify ilia portion of the single payment that It attributable to each empleyee%bllgoe 3, * Rnporungllte.pagdehdtaatevfWkhholdingt-%U-mushroportlhe paydate/dateofwithhokling when-sendl6e,the•haymghrTha .1019 9, n19 Ul1It,,Ur11V W"WiloU, * III 111U11101 F1969 UI 9111FROY111916 WRII IV.I10y1.1u 11111 1111111 IIVlIU1el Wllll 111 Wlll"ll yUU OI111111111IJIV1llalil Illtl._ withholding ardor and forward the support payments. V Empioyealobllgor with Multiple Support Holdlnsit if there Is more there one Ardor/Notlco to Withhold Income for Support agalnU' this employeelobligor and you are unable to honor all support Order/Nodces duo to Federal or State withholding llmlts, you must follow the law of the state of employee's/obllgor's principal place of employment You must honor all Orders/Notices to the greatest extent possible, (See #9 below) S, Termination NotlReallam You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the Information request and return a copy of this Order/Ntittce to. (110 Agency identified below, THE gMPLOY1E/011L14OR No LONCOR WORKS Pt7Rt 2360030200 RMPI OYEE'8/ogL10gR'S NAMNt?_ '11 a EMPLOYERS CASO IDENTIPIERI.,_eeg4x0 0 DATE OF SEPARATIONi LAST KNOWN HOMO ADDRgggr NEW RMPLOYER'S NAME/ADDRESSr . 6, Lump Sum Pa mentst You may be required to report and withhold from lump sum payments such as bonuses, tgtnmissions, or severance pay, It you have any questions about lump surd payments, contact the person or authorityhoiow, 7. Liability$ ](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, PennsylVanla State law govems'unless the obligor Is employed In another State, in which case the law of the State In which he or she is employed governs. 6. Antkliscriminatlom You are.subiect to a fine determined under State law for discharging an employeelobilgor from employment, refusing to employ, or taking dbclpllnary action against any employeelohl Igor because of a support.wlthholdingr Pennsylvania State law governs unless the obligor is employed In another State, In,which case the law of the State In which he or ilia Is employed goVoms, e,* Withholding Limin You may not withhold more than the lesser oft )) the amounts allowed by the Federal consumer Credit Protection Act 0 S U,CC, 81673 (b)1) or 2) the amounts allowed by Ilia Stale of the employeq's/obllgor's principal place of employmetltl l The Federal limit applies to the aggregate disposable weeklyeamings (ADWE). ADWE Is the net Income left after making mandatory deductions such as; State, Federal, local Woo Social Security taxan and Medicaro taxes, =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, hot withhold,more than the amounts allowed under the law of the state that Issued the order, , 10, Additional Intel *NOTEt If you or your agent are served with a copy of this order in law of the state that Issued thls order with respect to. these Items, ,.' 11-Submitted Byi if yat, Qt Sig B''ION c bomael y.t 0 n N• nnv enA s o .. ,. +"` 1,,, to he state that issued the k.? ORDERINOTICE TO WITHHOLD INCOME FOR SUPPORT State s _menWyel(h of_Penrwlvarnla Co,/Clly/Dlst, of 21RLAND Date of Order/Nollce oa a o6 Ctpee Number (See A d! t en um or care summary) Emp oyer l e er s BrB I um t, N11TC0* 90LtlTIONEI INC 5276 R TRINDkB RD 709106103 98-2780 CIVIL, kgl CHWnLL. mnnn A. MHOMNICOBURG DA 17060»3662 Q 00ginal Order/Noti(e O Amondod Order/Nollce Q Terminate QrderMoflco U COMM NMI'$Neme Icarli!Pit, MI) • See Addendum for dependent names andrb/rth'dafes associated with cases on attachment, ' L IF ORDER INFORMATION! Thls,ts an Order/Notice to Withhold Income for support based upon an order for support ; from CUMBBRAAND County, Commonwealth of Pennsylvania, By law, you are required to deduct these amounts from the above•namad employee's/Obligor's Income until further notice even If the Order/Notice Is not Issued by your State, E o, an per month In current support E o, oQ per month In`past due support Arrears 12 weeks or greater? Oyes 0 no $ o?oo per month in current and post-due medical support 5 . o , 00 per month,for genetic test costs ` Eper month In other (specify) for a tots o 0,00 per month to be forwarded to payee below, . You do not have to vary your pay cycle to be In compliance with the support order, if your pay cycle does not match the ordered support payment cycle, use the following to determine how much to witl hold) $ n. on perweekly pay period, $ 0,pp per biweekly pay period (every two weeks), $ _ a. og per semimonthly pay period (twice a month), $ _ n. 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 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/ obligpr'a aggregate disposable weekly earnings. For the purpose of the Ilmitatlon on withholding; the following Information Is . needed (See #9 on page 2). If remitting by EFT/EDh please call Pbnnsylvanfa State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1.877.6769580 for instructions, Make Remittance Payable tot PA SCDU Send check tot Pennsylvania SCIDU,,P.O, Box 49112,,Harrleburgr Pa 17106.0112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEPENDANTlS'NAMEAND1HE PACSES MEMBER /D (show" above as the Erdp/oyeolObfigor's'Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER To BE PROCESBEh, DO NOT,SEND CASH BY MAIL. . BY THE COU01. Date of Orden FEB „ 1 72006 IR . DROr R.J. 8hndday Kevin A aea, Ju Service Type M Farm EN-028 , PMBN9,Ie91eAI34 Worker ID BIATT - ? w ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS I 11tecl?afl ypla arere Iran to ?rp?I`lo a f:o?lya of Ihle fordour rlm,tlpyayoe, I( o`Ir emplo?alr elks In a state rha1 I{ ?i?filren loin he qat? Ihat ssu .c Ili Is or( o , , copy mus11460 I mvic ar tlo ur ai p oyoo ov n f II io box Is not choc Ad' t, Priorityi Withholding under this Onfor/Notica has priority poor any other legal process under Slate haw against ilia some income,. Federal tax levies In effect bofore receipt of this order havo priority, if there are Federal tax levles In effect please contact the requesllnlit agency listed below, 2, Combining Paymentst You can`combine withheld amounts from morn than one employoo%obllgor's Income In a single payglant to each agency requesting withholding, You must, however, separately Idonlify ilia portion of ilia single payment that Is attributable to aach employaNobligor, 3,+-ReportingihrrPayda"ata oflNithholdinggc--You tnust-reporklhoforti Mate of withhctldingwhon-mnding lho-poymnntr°The- paydatoMateofwlthholdinss•Isihodate-onwhleh•omountwarwlthhe d tram the ampployoe's wages; You must comply with Iho law of the state of the employee s/obllsells principal place of omploymenl with respect to the time perlods within which you must Implement the - withholding ordar and forward (lie support payments, A,* Employee/Obllgor with Multiple Support Hoidinttet If (here Is more than one Order/Notice to Withhold Income for support against this employeelobligo and you are unable to honor all support Order/Nptrces due to Federal or Slate withholding,ll{nl(s, you must fallow (ha raw of the slate of employee's/oblrgor's principal place of employment. YOU must honor all Orders/Norlces to ilia greatest extent possible. (See N9 below) S, Termination NotiRcatiom You must promptly nodfy the Requesting Agency when the.employee%6lrgor is no longer working for you. Please provide the Information requested and return e copy of this Order/Notice to the Agency Identlffed holow, THE IMPLOYEE/OPLIGOR NO LONGER WORKS FORT 232931136o EMPLOYEE15/011IIGOR'S NIMe, EMPLOYEE'S CASEIOENTII Rt.,, o DATE OF 91PARATIONt LAST KNOWN HOME ADDRISSI NEW EMPLOYER'S NAME/ADORESst 6, Lump Sum Pa mentsa You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay, If you have any quasllons about lump sum payments, contact the person or authority below, 7, Lrabllityi If you fail to withhold Income as the order/Notice directs, you are liable for both the accumulated amaytnt you should have withheld from the employee/obligor's Income and other penalties se( by Pennsylvania State law, Pennsylvania State law governs unless' ` the obligor It employed In another State, in which rase the law of the state In which he or she IS eptployed ggvems, a, AntWlscriminptlom You Are subject to aYlne determined under Stale law ford Ischorging an employee%obllgor from employment, refusing to employ, or taking disciplinary action against any employee/obligor becaus6of a support withholding,, -Pennsylvania State row' governs unless the obligor is employed in another State, In which case the law of the State In which he or she is employed govoms, . 9,• Withholding Llmitn You may not withhold more than the lesser oft 1) the amounts allowed by the Federal Consumer Credit Protection Act (IS U.S.C. 91673 (b)1) or 2) the amounts allowed by the State of the empjoyee's/obllgor's principal place of employment, The Federal limit applies to the aggregate dlsposable weekly earnings (ADWE), ADWE Is the not income left after. making mandatorydeductions such an Slate, Federal, local taxe9i Social Security laxesi and Medicare taxes,' For tribal orders, you may not Withhold more than the amounts allowed under the law of the issuing tribe, For tribal employers who receive estate order, you may not withhold more than the amounts allowed under the law of the state that Issued the order, 10. Additional Infol ,c "NOTE; If you or your agent are served with a copy of this order In the state that Issued the order, you art to follow the. law of the state that Issued this order with respect to these Items, 11. Submitted ByiT If you or your entpio ee/ohli or hays any ueatlona; DOME5TI R IATIq c c ? T contact WAGE A MR ? A__„ Cf INT UNIT VE I- by.talapphone at (717) 24UJ2B or CARLISLE E6 171111 by FAX at (71712411,62411 . or: , by Internet AM chi dsl -grt,atata,pa,Ua Service Type M Page 2 of 2 Form EN?028 - - OMB N01 09194131 Worker ID LTT ?t e ADUM UM 9llM11BlAC?1?1 pefendent/obligori jawa , TODD A. c?^t 7000003 1?lIQl?9t { "J9NIR+L ail ?l 90 OxVA 6 ; 060 Fhlldlran)'s Nama(4)i 000 chlld(ron)'s Namo(s)i DOB s` 4 I o t C. I utR;>iffk??}?e($z. r? If h b??? u are raM9 d to enroll the chlld(ren? ntia ov qn any nInsurance coverage ava labla k. a .. , i( checked, you are rreq jlgW to enroll the chlld(renil I entif above In any ea t Insuran a coverage ava able p ? t rough the ampl0yee'Nobllgor'i employmont. ha employee's l roug /obligor's employment{ . b b2r um er am laAlpl 1??la " 2Q" AttechmentAmounl w t ?g n e 12afkttl ta e combnt o 0 00 .„ DOB : Chlld(ren)h Nameleh Chit d(ren)'s Namelgi DOB_ ((yy{{ Pkk$` S 0 ?:' } ik ti$f ; 2p $ £{pp1>)SS 9i IJZ. ? ' R r Fri " r. 1 § § 1 TODD ALLEN JEWELL, IN THE COURT OF, COMMON PLEAS PENNSYLVANIA CUMBERLAND COUNTY , Plaintiff OIVIL ACTION - LAW NO, 1998- 2780 OABANDRA ANN JEWELL, ; Defendant : IN DIVORCE .. PITITION F2R CQNIIMPT QE COURT AND A'?RNEY'8 FEEH „. AND NOW, comes Casandre Ann Jewell, by and through her counsel, 9el.dis, 8huff, Flower.4 Lindsay, and petitions this Honorable Court as follows; 1, The partles hereto were married on December 27, 1988 and entered Into a . Marital Settlement Agreement on December 23, 2003, By operation of law, the Agreement was incorporated but not merged Into the Decree In Divorce which was entered on January 2, 2004, The Decree In' Divorce noted that a Qualified Domestic Relations Order had not yet been entered, A copy of the parties' Agreement and the Decree In Divorce Is attached l hereto as Exhibit "A" i k 2. Paragraph 4 of the parties' Agreement called for Husband to prepare a QDRO to transfer to Wife one half of the marital portion of Husband's pension, 3. On January. 7, 2004 and January 29, 2004, the undersigned provided Respondent's gounsei with a reminder letter regarding the obligation to provide the QDRO. On July 28,"2006; a third reminder letter was sent, 4,' Respondent has failed of refused to provide the QDRO pursuant to his 9AlDIQ SHUM FLOWOR Agreement and Court Order, at LINDSAY 81 Upon information and belief, Respondent has. elected to begin receiving 36 W. M n eaat Carpi, PA payments under his pension plan and le, therefore, receiving payments due and owing to Petitioner as well as to himself, 6, Petitioner has Inourred attorney's fees In the preparation of this Petition and anticipates attorney's face at amanllolpaled hearing, „ WH9REFORE, Petitioner prays This Honorable Court to enter a Rule.upon the Respondent to show cause why he should not Immediately prepare, sign and file a Qualified Domesllo Relations Order required by paragraph 4 of his Agreement, why he should not pay Petitioner's attorney's fees and why he should not Immediately pay to petitioner her Interest In monthly pension payments to the extent that he Is receiving them, SAIDIS, SNUFF, FLO ER & LINDSAY Carol J, L n say squire Supreme C WD No, 4469 26 West Hlg Street . Carlisle, PA 17013 717.243,6222 SAibi9 .. 1 , .. MUM KLOWWt, & LINDSAY 26 W. "I h liffil Gdg PA le, b + 5- I I1 1,! e71 ? i xk? .i ?t 4 ,t r: , F ,`J S4A I A A A A A A A I I I Husband 'and Wifb have agreed betWe coed by the parties, paoh convoying to the c return fbr his contributions to the immovo interest he above conditions, of his or her, any claim or right td the vehicles owned by th cement, Each party reiaasoa the other of any claim In the credit cards, debts, and obligations of the other NolthorHusbond nnr Wife shall contract, Incur, or be responsible for any debt or Ilabllity . for which the other party Is rosponsIlite and shall htdamnlfy and sago harm loss the other party „ ftom any much claims or demands made agalnst him or liar by reason of the erodh cards, debts or " obligations, As between the parties, each will ntalntsin in ills or liar own name credit cards and similar accounts; 4, Husband will prepare a QDRO pcoording to the tcrnis of which Wife would raoolvo one- half of the marital portion of Husband's pension, the ooverturc ftootion being comprised of a" mmolator which is the number of months between the data of.the parties' marriage February 21, 1988 or Husband's data of hire, whichever is later and the data of their. separation, May 28, 1998, and a denominator which shall be the months of service of Husband with lils employer, The QpRO will call for Wife to retain liar Interest in Husband's pension In the event of Ills death or er death and she shall be a surviving spouse to the extent of her Interest In Husband's ponslon; her, 5. Husband and Wife will maintain all lifb insurance policies In existence as of the data of. this Agreement which pot loles insuro his or her IIN and'shalI maintain the prom Iums thoroon. Husband shall dcsignato Wife as the benoilolary of his life Insurance policies to the extant of his alimony obligation as her Interest may appear pursuant to this Agreement, Husband will name a$ a beneficiary for the remainder of the death bonotit of his, Insurance policies{ a trustee, and Wife will maintain her Insurance policies oti her life and will name a trustee for the benefit of the parties'. three children as more particularly sat out on Exhibit A attached horoto, being theT. provisions for a trust which each party will Incorporate Into his or her will within 30, days of the date of this Agreement, Exhibit A in Husband's will shall be'amended'to add thereto a provision ' that will require the trustee to pay to. the Ouardlan of the children, sc lopg as they have not attained .18 Years of age and graduated from high school, an amount equal to the support payment payable by Husband to Wife, Indexed for the cost of living, The parties shall maintain life Insurance policies until the youngest of the parties' children attainsI23 years of ago, From time to time, upon the request of each party to the other, each shall provide to the other proof that the life Insurance policies remain In Nil force and affi?et, the premiums paid, and that the beneficiary designations retrain as set out in this paragraph, The trust provision shall provide for the trustee. to pay to the children or the custodian of the children an amount equivalent to the last Domestic Relations Order entered in the Domestic Relations case, Wife will be responsible to maintain and pay for her own health, medical, dentate and' hospitalization Insurance and programs, 71 Husband and Wife will Ello'separate tax returns for ail levels of government; Each year at a mutually agreed date, Husband and Wife will evaluate the income tax situation and agree on the.ohild deductions to betaken by each party, If a mutual agreement cannot bo?reached, one, deduction (Amber Jewell) will be taken by Husband and two deductions (Chyann and Utly''n Jewell) shall be taken by Wife, V?k WX LAW GIU11CUS SAIDIS,,.SHUFF, FLOWER & LINDSAY A t'ItOPpe81UNAL CORPORATION F IL E ' 16 Wp8'' H101i 6TlipRT U.SUKU CAAW9LU, I'UNNSYLVANIA 17011 2109 R91rr TOUIPHONpi (717) 243. MI- PACelMIL01(717) 743.0490 CAMP MLL PA 17011 l1MA11.1 a 0MOY(0101-IMOam T0LOPMON14 1 7374401 WWWdlf.-I ,com 11ACSIMILAi 71 j731.5407 CAROL), LINDSAY BRIAN C. CAPPRITY tao?aonwmblla? 000900 V. DOUOLAS, III AGW Nw s"Mnwm THOMAS U. PLOWUR R11PU TO CARL•IFIL6 JACLYNOMITH' July 61 2005 ?,48M161. 227 and US tdAI John J 1oe, ?eqqu re H, , Brou SROLIJOS & GILROY, P,C, 4 North Hanover Street Oarlisla, PA `17013 f E; Jewell v, Jewell Door John; The petition for an Indresso In child support: oaused me to review the file and to note. that your Client did not provide a QDRO as, required by paragraph 4 of the partlee" marital settlement agreement, That agreement was reached on December 23, 2003 and`Is, I think you would agree, long overdue, If we do notreoelve an agreement within 14 days, I will file a petitlon to ask the court to hold him In contempt of court for his fallurs to abide by his agreement whloh Is entered as a court order, 1 will seek attorney's fees as well, Please anocurage Mr, Jewell to take care of thl matter Immediately, .' Very truly yours,, Saldis, Shuff, Plower & Lindsay Carol J, Llndsa CX18p t i 'i` C ... r.? ...-,' _. ,AI s _. :, .,. .., ..yes: •,p_w .?._..•_ .._._.. ra.rsi_..-. A._ ' r ? r r 1 W i?. r- Ilk LAND 01119(Y!F SAIDIS, FLOWER & LINDSAY A PROPUBSIONALCORPORA'1'ION 20 W118T IIIp11 writuirr 1101 IN U. HLIRU RO CARLIULU, PUNNbYLVANIA 17019 lAlNl16NLQW (? ll1, <)IiItISUI IW P, PLOWIBUIi, )It '' ULU1111aNU1(717)243.4222, PACSIMILUI(717)243,64bb 11tW(1AItKICIhIIthlltlil'I' • CAROL! LINDSAY UMAU,I nllortluyytDrfl•Inw,rum CAMP HILL, PA 17011 URIANC,CAhPRUY " t+'WW,rrI+IaW,cam TKUPHON11;(717)717.3409 GUORM , P. DOUOLAU, lfL PACfiIMILII,, (717)717.14(17 '1'PIOMAB M PLOW It h1ARYLOU MA1'Ae' ltlil?LY'ro t nel.!a!?y 9UZANNU C, I11xIINUAUOM February 28, 2008 YlLIMIM119 240 The Honorable J, Wesley Oler, Jr, ' Cumberland County Courthouse One Courthouse Square Carlisle, PA; 17013 Re; Jewell V. Jewell. . No, 1888.2780 ' Dear Judge Qler1 I represent Cassandra Ann Jewell, the Defendant In the captioned case which Is scheduled for a hearing before you on a Petition for Contempt of Court and Attorney's Fees, Todd Allen Jewell was represented by John Broulos, Esqulre, but advises To that he is no longer represented by Mr, Broujos, The Issue before the Court Involves the preparation and filing of a Qualified Domestic ' Relations Order, Mr, Jewell and I have spoken by telephone and reached an agresmenf os follows; 11 1 will seek a continuance of our Petition for Contempt and Attorney's Fees to a dale certain at least one month. hence; 2,. I will have the,propoaed Domestlu Relations Order, wrtiUh Mr, Jewell provided to me yesterday, reviewed by Harry Leleter, an expert In these matters, 3. Mr, Jewell will provide to me 'a complete accounting of the early rdtirement lump sum benefit he received when he left employment. with the State and its disposition as well ae ,any rather Information requlred to ascertain my client's Interest In the lump auhl and payments received by Mr, Jewell In the Interim and into the future, a Mr, Jewell will arrange for an Immediate payment, to 'my client, of the Interest In the pension to date and.uhtll the QDRO can be signed and Implemented by.SSRS, 8, mt. Jewell will pay for Me, Jewell's attorney's fees as we attempt to resolve this matter, not to,exceed.$700.00, TODD ALLEN JEWELL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. ; CIVIL ACTION -? LAW NO, 1988 - 2780 OASANDRA ANN JEWELL, i Defendant IN DIVORCE STlFULATIQN OF [)?E_: RA TI?9 AND NOW, this day of 01+ 2008, the parties hereto stipulate as follower 1. The partles are scheduled for an appearance before the Court of Common Pleas of Cumberland County on May 4, 2008 on a Petition for Contempt of Court and Attorney's Foes filed by the Defendant, Z The parties wish to resolve all outstanding issues as follows; a, Plaintiff will pay to Defendant $185,88 per month commencing May 2006 until said payment Is made directly to Defendant pursuant to a 'Quallfled Domestic Relations Order, b,, By Friday, May 12, 2008, plaintiff will pay to Defendant $2,239,37, o, By July 4, 2008, Plaintiff will pay to Defendant's counsel $1;417,80, d, Plaintiff will cooperate fully in the tranefer of IRA rollover of $14,348,55 with gains from April 1, 20015 pursuant to the Addendum to the parties Marital Settlement Agreement of May 4, 2008, 3, Defendant will advise the Court of Common Pleas that the hearing scheduled z& for this dale Is no longer necessary, Upon receipt of all of the payments set out herein, Defendant will withdraw the Petition, 26 West High StrMl Witness: CerUlle. PA LAoil TODD ALLEN JEWELL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V, CIVIL ACTION - LAW NO, 1998 2780 CASANDRA,ANN JSWELL; Defendant IN DIVORCE STIPUL TIO OR THE PARTIES AND NOW; this day of , 2008, the panlas hereto „ stipulate me follower 1, The parties are scheduled for an appearance before the Court of Common Plese .of Cumberland County on May 4, 2009 on a Petition` for, Contempt of Court and Attorney's Foes filed by the Defendant, 2. The parties wish to resolve all outstanding issues ae follows: a. Plaintiff will pay to Defendant $185,88 per month commencing May 2008 until sold payment Is made.dlreotly to Defendant pursuant to a Qualified " Domestic Relations Order, „b, By Friday, May 12, 2ooe, Plaintiff will pay,to Defandant $21230,37; o, Sy'July 412008, Plaintiff will pay to Defendant's oouniol $1,417,40;; 1 d, Plaintiff will cooperate fully In the transfer of IAA,roljnver bt'$14,3}4$A with pains from April 1, 2008 pursuant to the Addendum to the p0olps Maritot, Settlement Agreement of May 4, 2008,. „ . 'f I11 Defendant will advlee'lhe Court of Common NO that trip Ittd'r11tg4ij?Kir 1t ?, for this data Is no longer necessary, Upon receipt of all of the pay e;st dolt Kl??, a,f r , 44, AT" i n_ - {+ fL E9 ?:.t ;l Defendant will withdraw the Petltlan, 1.1i Ii W; '?lE W5, Witness: t{?`'- a ,i +1y - T ,'s 11?t? f Fy t 4' ; ! t? t +?(4th, € t base ra nn ow0, i 1 MA r9'iF-1?Y` - tE , . 717-737-1407 f3AID15 81•KJFF FLOWER 898 POIS MAY 04 '06 1 +Zi' Toula IrJ.LN J LL, ; IN THI COURT Of COMMON PLKAfi PlalntN CUMBIRLANO COUNTY, PONNt9YLVANIA hr. ONI4ACTION w LAW` Nt?,1ope 7sq 0ABANDRA ANN JgWSLL, Pefondsnt .: ; IN,t71VQRC* ,. 2g its =94' AND NOW, this day of . ;1010,; she parties hersta:" . 4 ?upul?te a? failowa• • , 1, Tho-purtlos are-apheduled for an pppearanoe bailors the Court of penman Plsaa of Cumberland County on May 4, 2004 on a Petition for Contempt of Court and ;,.. 0andsM, Atomsy's re" filed by the,17 . 2, The partlos wish to resolve all outstanding issues as follows; a, Plaintiff wIN pay to I?SfandaM i18l3st) per month aarnmerhdnp Mey ' 2008"un0l saki payment Is mado dlr*Wy to Defendant pursuant to a 04011led Domeatio Rolotions Order, Vol b4 6Friday, May 1121 ski, PlslntKfAll pay to De*Wsnt 02,239,371' o, 9y July, 4, 20M, 'Plsintiff will pay to 00fendant's .vounsel $1,417,00, d, Plaintiff will oappef to fully In the WOW of IRA rollover of 7$14,348.05 with pains from April 11 2005 puruusnt to the Adden;14m to the Pa* o Morltal tiaitHgrrhsM Agresmani of May 4, 2000. +1?{ Defendant will advise the Court of Cornmon Pleas that the hearing soheduMd • for this date la no longer necessary. Upon reoelpt of sU of the ps sat out'haroln, " petndantrwlll"wNhdrawlhe f?eUtlon, Witnpser t ,. r r -4F< 4• - I. il ;. an ra n . , t itr yl. r.#S sH i li it f. ?Vi _ ! 1 3x r- f • +- W. n ? •T1?1 ?. yyyy??? ' 4 c .t C f M 1 ? ? I 1 f I 'le r. 21- • d 1 i t- W" ? n r t. In t ,9 CQUrt of Coleman P10888 of ICIIpAUMppBER14ApNDNN Cotlntyo Pennsylvania 13 N,,HANOVK 9 ?I 0, X 320, CANDINI,R, PA, 17013 ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT t State . mtunra ltq u( Penn ylyanla 709106109 Q Udbinai order/NollcA Co./C filet, of 0 8HR 98-2780 CIVIL Q Amandad onledNollca Data of Order/Nutlce o6 19/08 (>? Tnrmtnala orilariNnlica Case Number (See A ei nWo- lpr cane summary) Res u To Cmn nynr tl ro ar s Pa ara W N Num Ter Gmn Dyne 0 Ipar'r Namn (tm1, FRE N6TCOMM POLUTION8 INC Null nynr o h arts f R041 Security um r 6076 N TR):NOI,,R Rdf? T MBOIiANI0198t1RG Vp 170b0-7590 nPuyn anrICASa tend nr (500 AdtRndum for 01111111 names 4114dated with cases on ar140men0 Custodial Parunl f amo .ad, l bill MI) "'- See Addendum far dependent names and birth dates associated with cases on attachment ORDER INFORMATIOM This Is an Order/Notice to Withhold Income for Support based upon an ardor for support from OOMaRRWO County, Commonwealth of Pennsylvania, By low, you are required to deduct these amounts from the above-named amployee's/ohllgor's Income until further notice even if the Order/Notico is not . Issued by your State, 5 q Igo ; per mb9th.fn current support ..., 4Q per month In past-due support Arrears 12 weeks or greaten Oyes 0 no $ "per per month In current and past-due medical support $ -,___"per month for genetic test costs $ per month In other (specify) for a 110114 O Vie, 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 wlthhoidl $ . 0. 00 per weekly pay period, $ " A. eo per biweekly pay period (every two weeks), $ ' o, o per semimonthly pay period (twice a month),, $ g,per monthly pay period, REMITTANCE INFORMATION( You must baalh withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notlre,. Send payment within seven (7) working days of the paydatoldate 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 fot,the , allowable amount:' The'total withhold amount, and your fee, cannot exceed 55% of the employea's/ obligor's aggregate dispposable weekly earnings, For,the purpose of the Ilmltatlon on withholding, the following information Is Headed (See #9 on page, 2), . If remitting by CPT/EDI, please call Pennsylvania State Collections and Disbursement U0 (SCDU),Employer Customer Service at 1.877.676.9580 far Instructions, Make Remittance Payable tot PA SCgU Send check tot Pennsylvania 5CDUr P.0, Pax 69112, Marr'isburg, Pa 17106.9112 IN ADDITION, PAYMENTS MUST INCLUDE THE bEFENDANT'S NAMEAND THE PACSES MEMBER 1 fshoon . above as the EmployW0611 jor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDEN TO BE PROs ?55ED; DO NOT SEND CASH, BY MAIL, BY THE COURTi„ Date of Order; JUN 2 0 2000 Y M. b,Jr„ D1101 R,d, 8hnr9dn Service Typo M PMONo0100.0134 Fdrm •02.6_ },° _u ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS I (c'hocl"al yno am mt u Ira to ?r`rYlfio a S•opy, of this rams to, o it 9m+eloyea. I( r mploYnq workts In a Iloilo 111416 11 rut (m n Isle Ilnl? Itlnl %Sit rill s un of, 1 co) must be rover ac to ceir ul 1 o eo uvl 11 (Ills lax Is Ilot Choc ML 1. Prlorilyl Withholding under this Or or/Nolico has priority over any other legal process under Stole low agalnst ilia sumo Income, federal lax lovlos In effect before receipt of this order have prlorlty. If there am Federal lax levies In affect please contact Ilia requesting agency listed below, 2, Combining Paymentu You can combine withhold amounts from mom than one emplo ae/abllgor's Income In a single payment to each agency requesting wllllholfting. You must, however, separately Identify the portion of ilia single payment that.is attributable to each ompioyeo/abllgor, paydateRdatelofwithholdlne-irthe dataomwh ch amount woe withha d ram the em floyee'rwagea You must comply with the law o ilia state of ilia employea'slobligor's principal place of omploymonl with respect to Ilia I me period/ within which you must Implement tile„ withholding order and forward the support paymanu, 4,1 Employee/Obligor with Multiple Suppart Holding If there is more then one Order/Notlea to Withhold Income for Support agalrut this employeelobllgar and you are linahlo to honor all saplfart order/Notices duo Io Federal or state withholding limits, you must fallow the law of the gate of employee'a!obligor's principal place of employment, You must honor all Orders/Noticas to 1110 greatest extent possible, (See NO below) 5, Termination Not(lCallam You must promptly notify the Requesting Agency when ilia amployeo/abldgor Is no longer working for you. Please provide the Information mquestod and return a co ly Wilds ortor/Notice Io the Agency identl(lod bolow, THE EMPLOYEE/OdLIGOp NO LONGER WO Kg PORt 2338311350 N"Di nVltloWn111 hoses kJAU111 . dElW n. TODD A.._ . LAST KNOWN HOME ADDRESS; NEW EMPLOYER'S, NAME/ADDRESgI 6, Lump Bum Psymentst. You may be required to report and withhold from lump sum paymentssuch'as bonuses, commisilons, or severance pay. If you have any questions about lump sum payments, contact the person or authority below, 7, Liebllilyt If ou fall to withhold Income as the order/Notice directs, you are Ilable, for both ilia accumulated amount you should have withhold from the omployaWobligor's Income and. other ponaltleii set by pennsylvanla 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 amployed'govems, 5. Antl-dlscrlmlivit ono Yqu are subject to a flea determined under slate law for discharging an employee%bllgor from employment refusing to employ, or taking disciplinary action against any employeelobllgor because of a support whhholddngc Pennoylvathla Sipte law governs unless the obligor,JR. employed In another Stale, in which case the low of the State In which he or she Is employed gnvems, 0.' Withholding Limit se You may not withhold more than the leaser oh 1) the amounts allowed by.the Federal Consumer-Colt Protection Act (15 11673 (b)lror 2) Ilia amounts allowed by the state of the employoe's/oblleor's principal place Plain loymar3L The Federal limit appllos to the oggrr#gale disposable weekly earnings WOWE), ADWE Ili the not Income loft after making loan alory r, deductions such rut Stale, Federal, local taxeu Social Security taxes; and Medicare taxes, For tribal orders, you may not withhold nrord, than the amounts allowed under the law o(Ihe Issuing tribe, For tribal employers who receive a state order, you r?Mdy nit N Ithltoio ttlgfd, ' Ilion the amounts allowed under Ilse low of the state that Issued the order, 10. Additional Itifiti 7. A. yr,•,' , IR ' I3it' ' ?i4 ,?d ,t C 1 d' { , _ ,,{ € 1H CI F {{ 6 NOTEi If you or your agent are served with a copy of this order. In the state that Issued the order, ygtt ??,t1p?1!t , law of the state that Issued this order. With respect to these Items, I I.Submltled Hyl if you or your emplo ee%bll ter ttv y' g11, .kt )< ?1? ``? pOM <TI - R 4ATI(?NS SECTION contact b tale hone at er ++ 1• PR S p.y. H? 32Q by PAX at ? ? or-!, , loll +ar ?" : CARLI$I,E_PA170]3 by Internetwww,cltldsUlRQd,Ekgtel IUe'l 's? -4 a'`f i?#,(??', M `+tillt Rage 2 of 3 Part ?N?Rb ', ; ,del ?' Service Type M W os+eluo.Ievroalec l? dN(dC.l? .11,?? +, ,, Summary of Catel-gn Difoodanf/obllsort ONWwGG, 0131) A. natakp8ios RACM Valp Wmbn JANhGG Dnck°t 00 is0 6IVIG- 0,00 Chlld(mn)'s Namu(s)I, DOB 0,00 ChIld(ron)'s Nome(a)I DOS If gh card, you are regt?led to enroll ilia chlld(ren? l bi Caqulrod to enroll ilia chlld(rom If chockod, you Are d above in any Itoollh insurance coveraga ova Inbl? I tlt a a I on11t{OU a 0vo n any has t r Insurance coverage ova on e ' Ihroug the Omployeo's/ohligor's omployment, s employment, fhrowg i the employoa's/obligor PTal Iu Wdjg 1iDt racket ACIjWgnt61>]fill01 Number hllff No Nnme ' 2101011(f Noma 22" ?UflGlllWonlAmount Q,00 a 0,00 Child'(ran)'sNamd(A DOD Chlld(ran)'sNamo(s)i DOB, at. r tfF; itiT ..r 3 r '• Sa.. gel' i .1 Y4 {.,?;3 it . ,. .: . r - .{. .. •+ N f <kw S3itK?5T4}Y fa ... .i, It chackko,d, you are required to enroll the chlld(ron11 IF nlif(`ed ahova In any he?aplth insurance coverage ovallol to t?] II checketh you aro t 111rod to onroll the chlld(r6h 1({7entlfled above ))n any health Insuranc0 cove CCago ova?iabla•. ' I ougn the amployao's/olSlIgor's employment. s emplaymantl IlVough the amployeo's/gbIIgor .. . ' } lalln I 1.10131 Pame ' p I Sr s ' ?ffi "• hmenl,A'_muunl ? ri I ?}? ?Naehma.,,,,,,,, ntAm'unt , , ? 1 . S Chlld(ranl's NQme(9)I DOB A Chlld(ron)'s Nhme(s)i' S}Sry?ii h e 1 vi4 ? r If ch0ck?sd, you aro requlied to enroll lira cltlld(ion 10n11f?ed above In any health Inauranca covgrago available t ?Iif checked, you aro p 1 f Identified above `?rt and Itt t?tr? ? rough rho employoo'a/abllgar'a empl0ymenlt y 1 llfor a & _ i thrauelt the OmploVaO s/o i .t Pddondum, ' Service Type M _ . -, Ohio Na a4704 164 3. 1 , ? qq P'l - r . I ? r r ,- ?M rFa v l vri ? ?q it r ' i- i Ir I b I I; TODD ALLEN JEWELL, Plaintiff V. CASANDRA ANN JEWELL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1998 - 2780 IN DIVORCE PETITION FOR CONTEMPT OF COURT AND ATTORNEY'S FEES AND NOW, comes Casandra Ann Jewell, by and through her counsel, Saidis, Shuff, Flower & Lindsay, and petitions this Honorable Court as follows: 1. The parties hereto were married on December 27, 1988 and entered into a Marital Settlement Agreement on December 23, 2003. By operation of law, the Agreement was incorporated but not merged into the Decree in Divorce which was entered on January 2, 2004. The Decree in Divorce noted that a Qualified Domestic Relations Order had not yet been entered. A copy of the parties' Agreement and the Decree in Divorce is attached hereto as Exhibit "A". 2. Paragraph 4 of the parties' Agreement called for Husband to prepare a QDRO to transfer to Wife one half of the marital portion of Husband's pension. 3. On January 7, 2004 and January 29, 2004, the undersigned provided Respondent's counsel with a reminder letter regarding the obligation to provide the QDRO. On July 26, 2005, a third reminder letter was sent. 4. Respondent has failed or refused to provide the QDRO pursuant to his SAIDIS SHUFF, FLOWER & LINDSAY ATr0RNEYS•AT•LAW 26 W. High Street Carlisle, PA Agreement and Court Order. 5. Upon information and belief, Respondent has elected to begin receiving payments under his pension plan and is, therefore, receiving payments due and owing to Petitioner as well as to himself. 6. Petitioner has incurred attorney's fees in the preparation of this Petition and anticipates attorney's fees at an anticipated hearing. WHEREFORE, Petitioner prays This Honorable Court to enter a Rule upon the Respondent to show cause why he should not immediately prepare, sign and file a Qualified Domestic Relations Order required by paragraph 4 of his Agreement, why he should not pay Petitioner's attorney's fees and why he should not immediately pay to Petitioner her interest in monthly pension payments to the extent that he is receiving them. SAIDIS, SHUFF, FLOWER & LINDSAY C err. carol J. Lindsay Esquire Supreme C u D No. 44 26 West High Street Carlisle, PA 17013 717-243-6222 SAIDIS SHUFF, FLOWER & LINDSAY ATTORMYS•AT•LAW 26 W. High Street Carlisle, PA Exhibit "A" IN THE COURT OFCUMB STATE OF Todd Allen Jewell, Plaintiff PENNA. No. 1998 2780 VERSUS Casandra Ann Jewell, Defendant DECREE IN DIVORCE AND NOW, ZLrl , IT IS ORDERED AND DECREED THAT Todd Allen Jewell , PLAINTIFF, r ` AND Casandra Ann Jewell , 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; Execution of a Qualified Domestic Relations order providing for distribution of a spousal retirement interest. BY THE COURT' / J `J J ATTEST ?? PROTHONOTARY COMMON PLEAS ND COUNTY MARITAL SETTLEMENT AGREEMENT day of December, 2003, by and between Todd THIS IS AN AGREEMENT made this rd Allen Jewell of 110 Westgate Drive, Mt. Holly Springs, PA 17065-2004, hereinafter referred to as Husband, AND Casandra Ann Jewell of 299 Heisers Lane, Carlisle, PA 17013, hereinafter referred to as Wife; WHEREAS 1. Husband and Wife were married on February 27, 1988 in Boiling Springs, Cumberland County, Pennsylvania; and 2. Husband and Wife have three children, Amber M. Jewell, born August 10, 1988; Chyann E. Jewell, born November 18, 1996; and Kaitlyn N. Jewell, born November 18, 1996; and 3. Various differences have arisen between Husband and Wife, whereby they have been living separate and apart; and 4. The parties were separated May 28, 1998. 5. Husband and Wife have agreed to maintain separate and permanent domiciles and to live apart from each other; NOW, THEREFORE, for and in exchange of mutual considerations, and intending to be bound by the provisions hereof, Husband and Wife agree as follows: 1. Husband waives all of his right, title, and interest in real property and any claim for improvements to the property owned by Wife's father at 299 Heisers Lane, South Middleton Township, Carlisle, Pennsylvania, and releases Wife's father and mother of any claim relating to the property. Wife agrees to assume and to pay any sums due prior to, at the time of, and after the date of this Agreement and all judgments, liens, notes, and other encumbrances claimed by her parents, relating to said property existing and/or recorded on the date of this Agreement and to indemnify, save, and hold harmless Husband against any and all claims, causes of actions, suits, or litigation for money owed, damages, indirect or consequential, including legal fees, arising out of failure of Wife to comply with the above conditions. 2. Husband and Wife have agreed between themselves on distribution of personal property owned by the parties, each conveying to the other all of his or her right, title, and interest therein. In return for his contributions to the improvement of the residence, Wife conveys to Husband all of her right, title, and interest in the Yard Man snow blower and John Deere riding mower. Each party releases each other of any claim or right to the vehicles owned by the other party in the past and at the time of this Agreement. 3. Each party releases the other of any claim in the credit cards, debts, and obligations of the other. Neither Husband nor Wife shall contract, incur, or be responsible for any debt or liability for which the other party is responsible and shall indemnify and save harmless the other party from any such claims or demands made against him or her by reason of the credit cards, debts or obligations. As between the parties, each will maintain in his or her own name credit cards and similar accounts. 4. Husband will prepare a QDRO according to the terms of which Wife would receive one- half of the marital portion of Husband's pension, the coverture fraction being comprised of a numerator which is the number of months between the date of the parties' marriage February 27, 1988 or Husband's date of hire, whichever is later and the date of their separation, May 28, 1998, and a denominator which shall be the months of service of Husband with his employer. The QDRO will call for Wife to retain her interest in Husband's pension in the event of his death or her death and she shall be a surviving spouse to the extent of her interest in Husband's pension. 5. Husband and Wife will maintain all life insurance policies in existence as of the date of this Agreement which policies insure his or her life and shall maintain the premiums thereon. Husband shall designate Wife as the beneficiary of his life insurance policies to the extent of his alimony obligation as her interest may appear pursuant to this Agreement. Husband will name as a beneficiary for the remainder of the death benefit of his insurance policies a trustee, and Wife will maintain her insurance policies on her life and will name a trustee for the benefit of the parties' three children as more particularly set out on Exhibit A attached hereto, being the provisions for a trust which each party will incorporate into his or her will within 30 days of the date of this Agreement. Exhibit A in Husband's will shall be amended to add thereto a provision that will require the trustee to pay to the Guardian of the children, so long as they have not attained 18 years of age and graduated from high school, an amount equal to the support payment payable by Husband to Wife, indexed for the cost of living. The parties shall maintain life insurance policies until the youngest of the parties' children attains 23 years of age. From time to time, upon the request of each party to the other, each shall provide to the other proof that the life insurance policies remain in full force and effect, the premiums paid, and that the beneficiary designations remain as set out in this paragraph. The trust provision shall provide for the trustee to pay to the children or the custodian of the children an amount equivalent to the last Domestic Relations Order entered in the Domestic Relations case. 6. Wife will be responsible to maintain and pay for her own health, medical, dental, and hospitalization insurance and programs. 7. Husband and Wife will file separate tax returns for all levels of government. Each year at a mutually agreed date, Husband and Wife will evaluate the income tax situation and agree on the child deductions to be taken by each party. If a mutual agreement cannot be reached, one deduction (Amber Jewell) will be taken by Husband and two deductions (Chyann and Kaitlyn Jewell) shall be taken by Wife, 8. Husband and Wife each hereby releases the other from any and all claims, or demands for alimony or support, which claims or demands may be based on Section 3701 of the Divorce Code or under any other provision of the law, except for the following: Husband agrees to pay alimony to Wife as follows: $500 per month for five years, 2004 through 2008, starting from the date of this Agreement. Payments to Wife shall be made through the Office of Domestic Relations of Cumberland County. No increase will be granted and alimony will cease immediately if Wife cohabits with another adult or remarries or dies. 9. Except as otherwise set forth herein, each party hereby releases the other from any and all claims or demands arising out of the party's right to equitable distribution of personal and real property under Section 3501 of the Divorce Code, or any rights or claims in the personal or real property in the possession of the other party arising under the law. 10. Each party releases the other from any and all claims or demands for counsel fees and expenses whatsoever, which claims or demands may be based on Section 3702 of the Divorce Code or under any other provision of the law. All remaining court costs up to and including the final decree of divorce will be paid by Husband. 11. Husband and Wife each hereby waives, releases and relinquishes any and all rights that he or she may now have or may hereinafter acquire as the party's spouse under the present or future laws of any jurisdiction, including the following: A. To elect and to take under any Will or Codicils of the other party now or hereafter B. To share in other party's estate in case of intestacy. C. To act as executor or administrator of the other party's estate 12. Wife hereby agrees to execute all necessary documents, pleadings or affidavits in order that Husband may proceed with obtaining a no-fault divorce. 13. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. If any provisions of this Agreement are held to be invalid or unenforceable, all other provisions shall continue to be in full force and effect. 14. The parties warrant and represent that they have made a full disclosure of all assets prior to the execution of this Agreement. 15. This Agreement shall bind the parties hereto, their respective heirs, executors, and assigns. 16. Husband and Wife each has had the opportunity to have legal counsel to represent each of them in the negotiation and preparation of this Agreement and has either been so represented or has voluntarily chosen not to be represented. Husband and Wife each has carefully read this Agreement and is completely aware, not only of its contents, but also of its legal effect. IN WITNESS WHEREOF, Husband and Wife hereto intending to be legally boun hereby have hereunto set their hands and seals the day and year first above written- WITNESS SX'by V /?.cr NN -? !T Casandra Ann Jewell EXHIBIT A Item Four: I appoint my * * Guardian/Trustee of any property which passes to any person under the age of 23 years and with respect to which I am authorized to appoint a Guardian/Trustee and have not otherwise specifically done so. Should s/he fail or cease to act as Guardian/Trustee, I appoint * * to act with the same rights, powers, and duties. Guardian shall establish separate guardianship accounts and shall have the power to use income from time to time for the beneficiary's education, including technical and vocational training and graduate school, travel, support, and welfare without regard to his or her parents' ability to provide for such education, travel, support, and welfare, or to make payment for these purposes, without further responsibility, to the beneficiary or to the beneficiary's parents or to any person taking care of the beneficiary. Guardian shall administer the account until the beneficiary becomes IS years of age, at which time the Guardian shall transfer the principal and income remaining in the separate guardianship account to my Trustee, being the same person as my designated Guardian, who shall then administer a trust account, of both principal and income and any other funds transferred to the accounts designated, for the beneficiary's education, including technical and vocational training and graduate school, travel, support, health, and welfare. When the guardianship or trust account is less than $10,000.00 or the beneficiary of the separate trust becomes 23 years of age, the share of the beneficiary remaining in the account shall be paid to the beneficiary in full and the guardianship or trust terminated. In the event of the death of any beneficiary after my decease and prior to reaching the age of 23 years, his or her share shall be distributed equally among his or her children, equally; otherwise to my surviving children or child, per stirpes, to be administered in accordance with the guardianship and/or trust provisions. No interest under this instrument shall be transferable or assignable by any beneficiary, or be subject during its life to the claims of creditors. Guardian and Trustee shall not be required to file accountings with any court. In the event that any provision of this will shall be interpreted to violate the Rule Against Perpetuities, then the remaining provisions of this will shall not be invalid. Trustee shall administer the trust and dispose of assets so as not to violate the rule, making distribution as required to a life or lives in being plus 21 years. LAW OFFICES SAIDIS, SHUFF, FLOWER & LINDSAY f/ A PROFESSIONAL CORPORATION / 1 26 bVEST HIGH STREET JOHN E. SLI]a CARLISLE, PENNSYLVANIA 17013 CAM FF E:' ROBERT C. SAIDIS TELEPHONE: (717) 243-6= - FACSIMILE: (717) 243-6486 ?109 MAR1?T ST ET GEOFFRL'Y S- SHUFF EMAIL: attorney dOssfl-law.com CAMP HILL, PA 17011 JAMES D. FLOWER, R wwwssfl-law com TELEPHONE: (717)737-3405 CAROL] LINDSAY . FACSIMILE'. (717)737-3407 MATTHEW J. ESHELMANI KIRK S. SOHONAGE THOMAS E- FLOWER tB..0 cmic,d oem,a,' LINDSAY GINGRICH MACLAY xfghu nip .muo.. JACLYN SMITH REPLY TO CARLISLE January7, 2003 John H. Broujos, Esquire BROUJOS & GILROY, P.C. 4 North Hanover Street Carlisle, PA 17013 RE: Jewell v. Jewell Dear John: I enclose a copy of my letter to DRO instituting the alimony portion of the marital settlement agreement. Would you please forward the Qualified Domestic Relations Order in this case so that we can finish that portion of the case off as well? Thank you for your help. Very truly yours, SAUS, SHUFF, FLOWER & LINDSAY, P.C. Carol J. Lin say CJUap Enclosure cc: Cassandra Jewell LAW OFFICES SAIDIS, SHUFF, FLOWER & LINDSAY A PROFESSIONAL CORPORATION 26 WEST HIGH STREET JOHN E. SLIKE CARLISLE, PENNSYLVANIA 17013 ROBERT C. SAIDIS TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486 GEOFFREY S. SHUFF EMAIL: attorney@ssfl-Iaw.com JAMES D. FLOWER, JR wwwssfl-law.com CAROL J. LINDSAY MATTHEW J. ESHELMANt KIRK S. SOHONAGE THOMAS E. FLOWER LINDSAY GINGRICH MACLAY JACLYN SMITH January 29, 2004 John H. Broujos, Esquire BROUJOS & GILROY, P.C. 4 North Hanover Street Carlisle, PA 17013 RE: JEWELL V. JEWELL Dear John: CAMP HILL OFFICE: 2109 MARKET STREET CAMP HILL, PA 17011 TELEPHONE: (717)737-3405 FACSIMILE: (717)737-3407 tBoard Certified Creditors' Rights Represe.oin. REPLY TO CARLISLE May we have the Qualified Domestic Relations Order which you were preparing for Todd and Casandra Jewell? Thank you for your help. Very truly yours, Saidis, Shuff, Flower & Lindsay Carol J. Lindsay, Esquire CJL: ahg Cc: Casandra Jewell LAW OFFICES SAIDIS, SNUFF, FLOWER & LINDSAY A PROFESSIONAL CORPORATION 26 WEST HIGH STREET JOHN E. SLIKE CARLISLE, PENNSYLVANIA 17013 ROBERT C. SAIDIS TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486 GEOFFREY S. SHUFF EMAIL: attorney®ssf]-law.com JAMES D. FLOWER, JR www.ssf]-law.com CAROL I. LINDSAY BRIAN C. CAFFREY GEORGE F. DOUGLAS, III MATTHEW J. ESHELMANT THOMAS E. FLOWER JACLYN SMITH July 6, 2005 VIA FACSIMILE 243-8227 and US MAIL John H. Broujos, Esquire BROUJOS & GILROY, P.C 4 North Hanover Street Carlisle, PA 17013 RE: Jewell v. Jewell Dear John: L L FFICE: 2109 M TREET CAMP HILL, PA 17011 TELEPHONE: (717)737-3405 FACSIMILE: (717)737-3407 tBO.d cmffir C,eano« Ri,hu Repmea lab. REPLY TO CARLISLE The petition for an increase in child support caused me to review the file and to note that your client did not provide a QDRO as required by paragraph 4 of the parties' marital settlement agreement. That agreement was reached on December 23, 2003 and is, I think you would agree, long overdue. If we do not receive an agreement within 14 days, I will file a petition to ask the court to hold him in contempt of court for his failure to abide by his agreement which is entered as a court order. I will seek attorney's fees as well. Please encourage Mr. Jewell to take care of this matter immediately. Very truly yours, Saidis, Shuff, Flower & Lindsay Carol J. Lindsay CJL:ap VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsifications to autho it,es. Carol J. Lindsa , Esquire Date: I1 9, (,1- SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA CERTIFICATE OF SERVICE I, Carol J. Lindsay, Esquire, of the law firm of SAIDIS, SHUFF, FLOWER & LINDSAY, hereby certify that on this date a copy of the attached document was served on the following individual(s), via first class mail, postage prepaid, addressed as follows: John H. Broujos, Esquire BROUJOS & GILROY, P.C. 4 North Hanover Street Carlisle. PA 17013 SAIDIS, SHUFF, FLOWER & LINDSAY Carol J. Lindsay, E: Supreme Court ID f 26 West High Stree Carlisle, PA 17013 717-243-6222 SAIDIS MUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA 2- ? Oi? „n I'D ri 1 T, ? l i -' 1 v Z?TEv NOV 0 s 2005 ,,, I v TODD ALLEN JEWELL, IN THE COURT O Plaintiff CUMBERLAND COUNTY. PENNSYLVANIA V. CIVIL ACTION - LAW NO. 1998 - 2780 CASANDRA ANN JEWELL, Defendant IN DIVORCE ORDER OF COURT AND NOW, this 'T rf? day of Nov e- rib6, 2005, upon consideration of the within Petition, a Rule issued upon the Respondent to show cause why he should not be held in contempt of this Court's Order of January 2, 2004 incorporating his Marital Settlement Agreement, required to pay attorney's fees and to pay to Petitioner that portion of his pension attributable to Petitioner, if any, which he is currently receiving. Rule returnable at a hearing set for the jAJ- day of Yrk46 , 200 6 , in Courtroom No. / of the Courthouse in Carlisle, Pensnylvania) -&t SAIDIS SHUFF, FLOWER & LINDSAY ATMRNEYS•AT•LAW 26 W. High Street Carlisle, PA ti BY THE COURT, r,? Y; (^? 1?±. `V 1?=._ (7i' r '"1 111_ ?- I I ?? }`?._ ? __ l- + __ ??)`^ ?14',i Y .r' ;? t? J L.? c '?^" G <-a ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of order/Notice 02/16/06 Case Number (See Addendum for case summary) Employer/Withholder's Federal FIN Number NETCOMM SOLUTIONS INC 5275 E TRINDLE RD MECHANICSBURG PA 17050-3552 218-60-1030 Employee/Obligor's Social Security Number 5824100040 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First. Mb 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. $ o. oo per month in current support $ 0.00 per month in past-due support Arrears 12 weeks or greater? Dyes ® no $ 0.00 per month in current and past-due medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ 0.0 o 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: $ o. 0o per weekly pay period. $ 0, Go per biweekly pay period (every two weeks). $ o. 0o per semimonthly pay period (twice a month). $ o . 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 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). 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: FEB 1 7 2006 DRO: R.J. Shadday Service Type m 709106103 O Original Order/Notice 98-2780 CIVIL 0 Amended Order/Notice O Terminate Order/Notice RE: JEWELL, TODD A. Employee/Obligor's Name (Last, First, NIP ,4 Kevin A ess, Judge Form EN-028 OMB No.: 0910A154 $IATT I ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If hecke? you are required to provide a opy of this form to your .employee. If yo r employeg works in a state that is diferent from the state that issued this or?er, a copy must be provided to your employee even if the box is not checked. 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 employee/obligor. 3.*-Repolmg-the-P ' :-You-musfmpartwhen-sendingthe-paymerrti he- pagdateldate-of-wlthhold}ng-mihe-date-on-whith-amount*rtas withheld-from thre-emplOgee`sw . 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. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2329311350 EMPLOYEE'S/OBLIGOR'S NAME: JEWELL, TODD A. EMPLOYEE'S CASE IDENTIFIER: 5824100040 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: 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. Antidiscrimination: 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 (15 U.S.C. §1673 01; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 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 amounts allowed under the law of the state that issued the order. 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. 1 I. Submitted By: DOMESTIC RELATIONS SECTION 13 N HANOVER ST P.O. BOX 320 CARLISLE PA 17013 Service Type M 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 OMB NO, 0970-0154 Form EN-028 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: JEWELL, TODD A. PACSES Case Number 709106103 Plaintiff Name CASANDPA A. JEWELL Docket Attachment Amount 96-2780 CIVIL$ 0.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ 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/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff 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) identified above in any health insurance coverage available identified above in any health insurance coverage available through the employee's/obligor's employment. through the employee's/obligor's employment. Addendum Form EN-028 Service Type M Worker ID $IATT OMB No, 09]0-0154 'y?M?.i??? rv?? ???? TODD ALLEN JEWELL, Plaintiff V. CASANDRA ANN JEWELL, Defendant NO. 98-2780 CIVIL TERM CIVIL ACTION - LAW IN RE: DEFENDANT'S PETITION FOR CONTEMPT OF COURT AND ATTORNEY'S FEES ORDER OF COURT AND NOW, this I" day of March, 2006, upon consideration of the attached letter from Carol J. Lindsay, Esq., attorney for Defendant, the hearing scheduled for March 1, 2006, is rescheduled to Monday, April 24, 2006, at 3:00 p.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. John H. Broujos, Esq. Attorney for Plaintiff Carol F. Lindsay, Esq. Attorney for Defendant Courtesy Copy: Todd A. Jewell 110 Westgate Drive Mount Holly Springs, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA A 17065-2004 :rc BY THE COURT, ,? ;? ?. `; JOHN E. SLIKE ROBERT C. SAIDIS JAMES D. FLOWER, JR CAROL J. LINDSAY BRIAN C. CAFFREY GEORGE F. DOUGLAS, III THOMAS F. FLOWER MARYLOU MATAS SUZANNE C. HIXENBAUGH LAW OFFICES SAIDIS, FLOWER & LINDSAY A PROFESSIONAL CORPORATION 26 WEST HIGH STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486 EMAIL: attomeyOsfl-law.com www.sfl-law.com February 28, 2006 Via Facsimile 240-6462 The Honorable J. Wesley Oler, Jr. Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Re: Jewell v. Jewell No. 1998-2780 Dear Judge Oler: CAMP HILL OFFICE. 2109 MARKET STREET CAMP HILL, PA 17011 TELEPHONE: (717)737-3405 FACSIMILES (717)737-4407 REPLY TO CARLISLE I represent Cassandra Ann Jewell, the Defendant in the captioned case which is scheduled for a hearing before you on a Petition for Contempt of Court and Attorney's Fees. Todd Allen Jewell was represented by John Broujos, Esquire, but advises me that he is no longer represented by Mr. Broujos. The issue before the Court involves the preparation and filing of a Qualified Domestic Relations Order. Mr. Jewell and I have spoken by telephone and reached an agreement as follows: 1. I will seek a continuance of our Petition for Contempt and Attorney's Fees to a date certain at least one month hence; 2. i will have the proposed Domestic Relations Order, which fvii. Jewell provided to me yesterday, reviewed by Harry Leister, an expert in these matters. 3. Mr. Jewell will provide to me a complete accounting of the early retirement lump sum benefit he received when he left employment with the State and its disposition as well as any other information required to ascertain my client's interest in the lump sum and payments received by Mr. Jewell in the interim and into the future. 4. Mr. Jewell will arrange for an immediate payment, to my client, of the interest in the pension to date and until the QDRO can be signed and implemented by SERS. 5. Mr. Jewell will pay for Ms. Jewell's attorney's fees as we attempt to resolve this rnatter, not to exceed $750.00. The Honorable J. Wesley Oler, Jr. February 28, 2006 Page 2 By copy of this letter, I am advising Mr. Broujos that tomorrow's hearing will no longer be necessary. I also enclose the proposed Order for a continuance. By copy of this letter, also, I am asking Mr. Jewell to call Ruth in your office to signal his concurrence with these arrangements. I have advised him that he may reach your chambers at 240-6531. Thank you for your help with this matter. Very truly yours, SAIDIS, LOWE INDSAY s Carol J. Lindsay, squire CJL/bes Enclosure cc: John H. Broujos, Esquire (via facsimile 243-8227) Todd Jewell (via email) TODD ALLEN JEWELL, Plaintiff V. CASANDRA ANN JEWELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 98-2780 CIVIL TERM IN RE: DEFENDANT'S PETITION FOR CONTEMPT OF COURT AND ATTORNEY'S FEES ORDER OF COURT AND NOW, this 17`? day of April, 2006, due to a conflict in the Court's schedule, the hearing scheduled for April 24, 2006, is rescheduled to Thursday, May 4, 2006, at 3:00 p.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, wJ'o'hn H. Broujos, Esq. I Attorney for Plaintiff /arol F. Lindsay, Esq. Attorney for Defendant 3 Courtesy Copy: ,Todd A. Jewell 110 Westgate Drive Mount Holly Springs, PA 17065-2004 o? :rc '? _ TODD ALLEN JEWELL, Plaintiff V. CASANDRA ANN JEWELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW NO. 98-2780 CIVIL TERM IN RE: DEFENDANT'S PETITION FOR CONTEMPT OF COURT AND ATTORNEY'S FEES ORDER OF COURT AND NOW, this 4t' day of May, 2006, upon request of Carol F. Lindsay, Esq., the hearing scheduled for May 4, 2006, is continued generally. Counsel is requested to notify the Court when an agreement is reached. BY THE COURT, J esley Ol r., ,,'?'odd A. Jewell 110 Westgate Drive Mount Holly Springs, PA 17065-2004 Plaintiff, pro Se ,P-arol F. Lindsay, Esq. . PC Attorney for Defendant \ w :rc .O CP MNVAIA%Ndd I 1 :Z Nd 9- AVN 9001 AbvicNOHIOW 3H130 30ti-f0-03D3 TODD ALLEN JEWELL, Plaintiff V. CASANDRA ANN JEWELL, Defendant AND NOW, this stipulate as follows: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1998 - 2780 IN DIVORCE STIPULATION OF THE PARTIES day of , 2006, the parties hereto The parties are scheduled for an appearance before the Court of Common Pleas of Cumberland County on May 4, 2006 on a Petition for Contempt of Court and Attorney's Fees filed by the Defendant. 2. The parties wish to resolve all outstanding issues as follows: a. Plaintiff will pay to Defendant $185.66 per month commencing May 2006 until said payment is made directly to Defendant pursuant to a Qualified Domestic Relations Order. b. By Friday, May 12, 2006, Plaintiff will pay to Defendant $2,239.37. C. By July 4, 2006, Plaintiff will pay to Defendant's counsel $1,417.50. d. Plaintiff will cooperate fully in the transfer of IRA rollover of $14,348.55 with gains from April 1, 2005 pursuant to the Addendum to the parties Marital Settlement Agreement of May 4, 2006. 3. Defendant will advise the Court of Common Pleas that the hearing scheduled SA ILS, FLOWER & LINDSAY 26 West High Strea Carlisle, PA for this date is no longer necessary. Upon receipt of all of the payments set out herein, Defendant will withdraw the Petition. Witness: j Tod en Jewell / J C w asandra Ann Jewell TODD ALLEN JEWELL, Plaintiff V. CASANDRA ANN JEWELL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1998 - 2780 IN DIVORCE STIPULATION OF THE PARTIES AND NOW, this day of , 2006, the parties hereto stipulate as follows: 1. The parties are scheduled for an appearance before the Court of Common Pleas of Cumberland County on May 4, 2006 on a Petition for Contempt of Court and Attorney's Fees filed by the Defendant. 2. The parties wish to resolve all outstanding issues as follows: a. Plaintiff will pay to Defendant $185.66 per month commencing May 2006 until said payment is made directly to Defendant pursuant to a Qualified Domestic Relations Order. b. By Friday, May 12, 2006, Plaintiff will pay to Defendant $2,239.37. c. By July 4, 2006, Plaintiff will pay to Defendant's counsel $1,417.50. d. Plaintiff will cooperate fully in the transfer of IRA rollover of $14,348.55 with gains from April 1, 2005 pursuant to the Addendum to the parties Marital Settlement Agreement of May 4, 2006. 3. Defendant will advise the Court of Common Pleas that the hearing scheduled for this date is no longer necessary. Upon receipt of all of the payments set out herein, Defendant will withdraw the Petition. Witness: Casandra Ann ~ 717-737-3407 SAIDIS SHUFF FLOWER TODD ALLEN JEWELL, Plaintiff V. CASANDRA ANN JEWELL, Defendant 698 P02 MAY 04 '06 13:21 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1998 - 2780 IN DIVORCE STIPULATION 2E THE PARTIES AND NOW, this stipulate as fellows: day of 2006, the parties hereto 1. The parties are scheduled for an appearance before the Court of Common Pleas of Cumberland County on May 4, 2006 on a Petition for Contempt of Court and Attorney's Fees filed by the Defendant. 2. The parties wish to resolve all outstanding issues as follows: a. Plaintiff will pay to Defendant $185.66 per month commencing May 2006 until said payment is made directly to Defendant pursuant to a Qualified Domestic Relations Order. b. By Friday, May 12, 2t706, Plaintiff will pay to Defendant $2239.37. C. By July 4, 2008, Plaintiff will pay to Defendant's counsel $1,417.50. d. Piaintiff will cooperate fully in the transfer of IRA rollover of $14,348.55 with gains from April 1, 2005 pursuant to the Addendum to the parties Marital settlement Agreement of May 4, 2006. 3. Defendant will advise the Court of Common Pleas that the hearing scheduled for this date is no longer necessary. Upon receipt of all of the Pa1r jrLw set out herein, Defendant will withdraw the Petition. Witness: Ann ? N O 0 Gy `r 53 :E1 IC s ? ? c r - is P AW 4, TODD ALLEN JEWELL, Plaintiff V. CASANDRA ANN JEWELL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1998 - 2780 IN DIVORCE ORDER OF COURT AND NOW, this ;,, day of VIA 7 1 , 2006, upon consideration of the within Stipulation, the terms thereof are hereby made an Order of Court. BY THE COURT, , J. 06A FLOWER ? LINDSAY ATIOWEIS-ARLAW 26 West High Street Carlisle, PA 60:C lid 9 1 A VU 90OZ In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION 13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013 Defendant Name: TODD A. JEWELL Member ID Number: 5824100040 Please note: AD correspondence most include the Member ID Number. ORDER OF ATTACHMENT OF UNEMPLOYMENT COMPENSATION BENEFITS Financial Break Down of Multiple Cases on Attachment Plaintiff Name CASANDRA A. JEWELL PACSES Docket Case Number Number 709106103 98-2780 CIVIL $ TOTAL ATTACHMENT AMOUNT: $ 500.00 Attachment Amount/Freouencv 500.00 /MONTH / / 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 $115.3 8 per week, or 50 of the Unemployment Compensation benefits otherwise payable to the Defendant, TODD A. JEWELL Social Security Number 218-60-1030 , Member ID Number 5824100040 . BUCBA is ordered to remit the amount attached to the Department of Public Welfare (DPW). DPW shall forward the amount received from BUCBA to the Domestic Relations Section of this Court for support and/or support arrearages. If the Defendant's Unemployment Compensation benefits are attached by another Court or Courts for support and/or support arrearages, DPW may reduce the amount attached under this Order so that the total amount attached does not exceed the maximum amount subject to garnishment pursuant to 15 U.S.C. § 1673 (b)(2) and 23 Pa. C.S.A. § 4348 (g). This Order shall be effective upon receipt of the notice of the Order by the BUCBA and shall remain in effect until the Defendant's entitlement to Unemployment Compensation benefits, under the Application for Benefits dated MAY 14 , 2006 is exhausted, expired or deferred. BUCBA shall comply with this Order, unless it is amended or vacated by subsequent Order of this Court. All questions, challenges or obligations to this Order shall be directed to the Domestic Relations Section of this Court. BY THE COURT Date of Order: MAY 2 3 2006 h -L M. L. Ebert, Jr., OJUDGE DRO: R.J. Shadday Form EN-530 Service Type M Worker ID $ IATT 6 c? PT'T' r ' ? x. '? -c rnr- . ' ? - w ?? ,-, ?_, ? ?jam .- r_ W v? tLl K ORDERlNOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 06/19/06 Case Number (See Addendum for case summary) Employer/Withholder's Federal EIN Number NETCOMM SOLUTIONS INC 5275 E TRINDLE RD PA 17050-3552 218-60-1030 Employee/Obligor's Social Security Number 5824100040 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 notice even if the Order/Notice is not issued by your State. $ o . 00 per month in current support $ o. oo per month in past-due support Arrears 12 weeks or greater? Oyes ® no $ o. 00 per month in current and past-due medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ 0.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ o. oo per weekly pay period. $ 0. 00 per biweekly pay period (every two weeks). $ 0.00 per semimonthly pay period (twice a month). $ o. 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 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). 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: JUN 2 0 2006 DRO: R.J. Shadday Service Type m 709106103 O Original Order/Notice 98-2780 CIVIL O Amended Order/Notice O Terminate Order/Notice RE: JEWELL, TODD A. Employee/Obligor's Name (Last, First, MI) M. 4. Ebert, Jr., edge Form -028 OMB No, 0970-0154 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? Ifkheckl you are required to provide agopy of this form to yourgemployee. If yoyr employee works in a state that I's di erent rom the state that issued this or er, a copy must be provi to your emp oyee even if the box is not checked. 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 employee/obligor. 3. paydateidate of vy.ti flivid Ing is the date on whid, an Pow it wa,, withheld from tire eniployee'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. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2329311350 EMPLOYEE'S/OBLIGOR'S NAME: JEWELL, TODD A. EMPLOYEE'S CASE IDENTIFIER: 5824100040 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: 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 employeelobligor'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. Antidiscrimination: 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 (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 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 amounts allowed under the law of the state that issued the order. 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. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us Service Type M Page 2 of 2 OMB No.: 0970-0154 Form EN-028 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: JEWELL, TODD A. PACSES Case Number 709106103 Plaintiff Name CASANDEA A. JEWELL Docket Attachment Amount 98-2780 CIVIL$ 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/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available identified above in any health insurance coverage available through the employee's/obligor's employment. through the employee's/obligor's employment. Addendum Form EN-028 Service Type M Worker ID $IATT OMB No.: 09700154 t? L- S T. i? ' :-?- v7f C1 C.a _?o VID In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION 13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013 Phone: (717) 240-6225 Fax: (717) 240-6248 Defendant Name: TODD A. JEWELL Member ID Number: 5824100040 Please note: All correspondence must include the Member ID Number. ORDER TO VACATE ATTACHMENT OF UNEMPLOYMENT BENEFITS Financial Break Down of Multiple Cases on Attachment Plaintiff Name CASANDRA A. JEWELL PACSES Docket Case Number Number 709106103 98-2780 CIVIL TOTAL ATTACHMENT AMOUNT: $ 0.00 Attachment Amount/Frequency $ 500.00 MONTH / / The prior Order of this Court directing the Department of Labor and Industry, Bureau of Unemployment Compensation Benefits and Allowances (BUCBA), to attach $ o. o o or 5 0 % per week of the Unemployment Compensation benefits of TODD A. JEWELL , Social Security Number 218-60-1030 , Member ID Number 5824100040 is hereby vacated. This Order to Vacate shall be effective upon receipt of the notice of the Order by the Department and shall remain in effect until a further Order of the Court is filed. BY THE COURT Date of Order: ? . DRO: R. J. Shadday Service Type m -t ?? I V - M. L. Ebert, Jr. , JUDGE Form EN-035 Worker ID $ IATT TODD ALLEN JEWELL, PLAINTIFF V. CASANDRA ANN JEWELL, DEFENDANT : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL DIVISION -LAW : NO. 98-2780 CIVIL TERM ACTION IN DIVORCE PETITION FOR MODIFICATION OF A PARTIAL CUSTODY 1. The petition of Todd Allen Jewell respectfully represents that on November 20, 2001 , an Order of Court was entered for partial custody, a true and correct copy of which is attached. This Order should be modified because: Father is seeking additional visitation time with the children. WHEREFORE, Petitioner requests that the Court modify the existing Order for partial custody because it will be in the best interest of the children. jtv'6 (_ Petitioner I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. 10/3 ora ?D? 2-? Date boner r-40 f? C-n ^r1 -r ni TODD ALLEN JEWELL PLAINTIFF V. CASANDRA ANN JEWELL DEFENDANT AND NOW, Fr IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA 98-2780 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT November 03, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, December 12, 2006 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ jacqueline M. Verney, Esq. , VIy Custody Conciliator ? The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ?"? // ._?. t •. i'J j. +? '? 1 ..y'?? _?Fl i47 ? i "1 ....? COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Todd Allen Jewell Plaintiff CIVIL ACTION - LAW VS. NO. 98-2780 Casandra Ann Jewell IN DIVORCE Defendant STIPULATION FOR THE ENTRY OF "DOMESTIC RELATIONS ORDER" AND NOW, this 4jday of 1?r ;? , , 200 C , the parties, Todd Allen Jewell, Plaintiff and Casandra Ann Jewell, Defendant, do hereby Agree and Stipulate as follows: 1. The Plaintiff, Todd Allen Jewell (hereinafter referred to as "Member") is a member of the Commonwealth of Pennsylvania, State Employees' Retirement System (hereinafter referred to as "SERS") 2. SERS, as a creature of statue, is controlled by the State Employees' Retirement Code, 71 Pa. C.S. §§5101-5956 ("Retirement Code") 3. Member's date of birth is June 16, 1968, and his Social Security number is 218-60-1030. 4. The Defendant, Casandra Ann Jewell (hereinafter referred to as "Alternate Payee") is the former spouse of Member. Alternate Payee's date of birth is December 16, 1968, and her Social Security number is 171-62-0332. 5. Member's last known mailing address is: 110 Westgate Drive Mt. Holly Springs, PA 17065 6. Alternate Payee's current mailing address is: 299 Heisers Lane Carlisle, PA 17013 re) r ' 0-i F LU SO C=l L:-- G'? C JJ C°d t DRO Page 2 It is the responsibility of the Alternate Payee to keep a current mailing address on file with SERS at all times. 7. The Alternate Payee is entitled to a portion of the Member's benefits under the Plan as set forth below. The Plan is hereby directed to pay Alternate Payee's share directly to Alternate Payee. 8. The Member is currently receiving a monthly annuity for his lifetime pursuant to the terms of Option 1. The parties acknowledge that the Member's retirement option elections are final and irrevocable. 9. The Alternate Payee's share of Member's retirement benefit is 27.50% of the Member's gross monthly annuity as of the date SERS approves a Domestic Relations Order incorporating this Stipulation and Agreement plus 27.50% of any scheduled or ad hoc increase applied to the Member's gross monthly annuity after such date. 10. Payments to the Alternate Payee shall commence as soon as administratively feasible on or about the date SERS approves a Domestic Relations Order incorporating this Stipulation and Agreement. 11. Payments shall continue to Alternate Payee for the remainder of the Member's lifetime. 12. If the Member dies before the Alternate Payee, the Alternate Payee shall be paid 27.50% of any death benefit provided under Option 1. Member hereby nominates Alternate Payee as an irrevocable beneficiary to the extent of Alternate Payee's equitable distribution portion of Member's retirement benefit for any death benefits payable by SERS. This nomination shall become effective upon approval by the Secretary of the Retirement Board, or other authorized representative of the Secretary, of any Domestic Relations Order incorporating this Stipulation and Agreement. The balance of any death benefit remaining after the allocation of the equitable distribution portion payable to Alternate Payee and any other alternate payees named under other SERS-approved Domestic Relations Orders I)RO Page 3 ("Balance") shall be paid to the beneficiaries named by Member on the last Nomination of Beneficiaries Form filed with the Retirement Board prior to Member's death. If the last Nomination of Beneficiaries Form filed by Member prior to Member's death (a) predates any approved Domestic Relations Order incorporating this Stipulation and Agreement, and (b) names Alternate Payee as a beneficiary, then: (1) the terms of the Domestic Relations Order shall alone govern Alternate Payee's share of any death benefit, and (2) for purposes of paying the Balance via the last Nomination of Beneficiaries Form filed with the Retirement Board prior to Member's death, Alternate Payee shall be treated as if Alternate Payee predeceased Member. No portion of the Balance shall be payable to Alternate Payee's estate. 13. If the Alternate Payee dies before the Member, the Alternate Payee's share of the member's pension and any death benefit provided under Option 1 shall be paid to her estate. 14. Member shall execute and deliver to Alternate Payee an authorization, in a form acceptable to SERS, which will authorize SERS to release to Alternate Payee all relevant information concerning Member's retirement account. Alternate Payee shall deliver the authorization to SERS which will allow the Alternate Payee to check that she has been and continues to be named as a beneficiary for 27.50% of any death benefit provided under Option 1. 15. Alternate Payee may not exercise any right, privilege or option offered by SERS. SERS shall issue individual tax forms to Member and Alternate Payee for amounts paid to each. 16. In no event shall Alternate Payee have greater benefits or rights other than those which are available to Member. Alternate Payee is not entitled to any benefits not otherwise provided by SERS. The Alternate Payee is only entitled to the specific benefits offered by SERS as provided in this Order. All other rights, privileges and options offered by SERS not granted to Alternate Payee by this Order are preserved for Member. 17. It is specifically intended and agreed by the parties hereto that this Order: (a) Does not require SERS to provide any type or form of benefit, or any option not otherwise provided under the Retirement Code; bRO Page 4 (b) Does not require SERS to provide increased benefits (determined on the basis of actuarial value) unless increased benefits are paid to Member based upon cost of living or increases based on other than actuarial values. 18. The parties intend and agree that the terms of this Stipulation and Agreement shall be approved, adopted and entered as a Domestic Relations Order. 19. The Court of Common Pleas of Cumberland County, Pennsylvania, shall retain jurisdiction to amend any Domestic Relations Order incorporating this Stipulation and Agreement, but only for the purpose of establishing it or maintaining it as a Domestic Relations Order; provided, however, that no such amendment shall require SERS to provide any type or form of benefit, or any option not otherwise provided by SERS, and further provided that no such amendment or right of the Court to so amend will invalidate this existing Order. 20. Upon entry as a Domestic Relations Order, a certified copy of the Domestic Relations Order and this Stipulation and Agreement and any attendant documents shall be served upon SERS immediately. The Domestic Relations Order shall take effect immediately upon SERS approval and SERS approval of any attendant documents and then shall remain in effect until further Order of the Court. bRO Page 5 WHEREFORE, the parties, intending to be legally bound by the terms of this Stipulation and Agreement, do hereunto place their hands and seals. BY THE COURT Plain ' e er Defendant/Alternate Pa; V/0 5'e' Attorne for Plaintiff/Member Attorney for of an Alte ate Payee DEC 2 6 2006,ae ;,, TODD ALLEN JEWELL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 1998-2780 CIVIL ACTION - LAW CASSANDRA ANN JEWELL, . Defendant : IN CUSTODY ORDER OF COURT AND NOW, this Z rj day of 1 e f . , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A Hearing is scheduled in Court Room No. / , of the Cumberland County Court House, on the o?f& day of w , 2007, at 1?,() o'clock, -P-. M., at which time testimony will be taken. For purposes of this Hearing, the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the prior Order of Court dated November 20, 2001 shall remain in full force and effect. 3. The parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. 1 cc: odd Allen Jewell, pro se 110 Westgate Drive Mt. Holly Springs, PA 17065 ?ol J. Lindsay, Esquire, counsel for Mother BY THE COURT, za 17 ?70, i0i DEC 2 6 20060.,1 TODD ALLEN JEWELL, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 1998-2780 CIVIL ACTION - LAW CASSANDRA ANN JEWELL, Defendant/Respondent : IN CUSTODY PRIOR JUDGE: J.: Wesley Oler, Jr., J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Chyann E. Jewell November 18, 1996 Mother Kaitlyn N. Jewell November 18, 1996 Mother 2. A Conciliation Conference was held on December 21, 2006 with the following individuals in attendance: The Father, Todd Allen Jewell, pro se and the Mother, Cassandra Ann Jewell, with her counsel, Carol J. Lindsay, Esquire. 3. The Honorable J. Wesley Oler, Jr. previously entered an Order of Court dated November 20, 2001 providing for shared legal custody, Mother having primary physical custody and Father having alternating weekends, every Wednesday evening and alternating Thursday evenings. 4. Father's position on custody is as follows: Father seeks shared legal and partial physical custody, from Tuesday evening to Sunday evening on alternating weekends and alternating Wednesdays. Father maintains that the children have made friends in his neighborhood and have requested to spend more time with him and his new family. 5. Mother's position on custody is as follows: Mother seeks to maintain the status quo. Mother maintains that Father has not exercised the time he currently has under the Order of Court and that the girls have developmental and educational issues that Father does not appropriately consider or deal with. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing and continuing the prior Order of Court. It is expected that the Hearing will require four (4) hours. IA -AI -4 N( " Date ac eline M. Verney, Esquire Custody Conciliator S w TODD ALLEN JEWELL, Plaintiff V. CASANDRA ANN JEWELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 98-2780 CIVIL TERM ORDER OF COURT AND NOW, this 91h day of March, 2007, upon consideration of the attached letter from Todd A. Jewell, Plaintiff, and with no objection from Carol J. Lindsay, Esq., attorney for Defendant, the custody hearing previously scheduled in the above matter for March 28, 2007, is cancelled. BY THE COURT, odd A. Jewell 110 Westgate Drive Mount Holly Springs, PA 17065-2004 Plaintiff, pro Se /J. Lindsay, Esq. Attorney for Defendant , 1t 6e :rc '/ . 4?? () I dl?x '?? ? r.r^sr"^ "td, .?i_. _ sJ q? „?_ ??' ??t?? ?y? ;, ?' ?, ?-? =? i?. ?? r t ???; :a?t,? ?,C.' a - t-,i ?;.„; t._ March 6, 2007 The Honorable J. Wesley Oler, Jr. Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 RE: Jewell vs. Jewell No. 1998-2780 Dear Judge Oler: I represent myself, the Plaintiff and Petitioner, in the captioned case which is scheduled for a hearing before you on a Petition for Custody Modification. The purpose of my letter is to inform you that Ms. Jewell, the Defendant, and I have reached an amicable agreement. This agreement will not stipulate any modification to the current order. Based on this agreement, I have submitted the appropriate documents to withdrawal my petition. I respectfully request that the hearing scheduled before you on March 28, 2007, be cancelled. If you have any questions, please contact me directly. Thank you for your help in this matter. Best Reg S, Todd . Jewell cc: Casandra A. Jewell (via email) Carol L. Lindsay, Esquire, counsel for Mother Jacqueline M. Verney, Esquire -'e o=' `?d0 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION 13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013 Defendant Name: TODD A. JEWELL Member ID Number: 5824100040 Please note: All correspondence must include the Member 1D Number. ORDER OF ATTACHMENT OF UNEMPLOYMENT COMPENSATION BENEFITS Financial Break Down of Multiple Cases on Attachment Plaintiff Name CASANDRA A. JEWELL CASANDRA A. JEWELL PACSES Docket Case Number Number 379100107 1136 S 89 709106103 98-2780 CIVIL TOTAL ATTACHMENT AMOUNT: $ 1,551.00 Attachment Amount/Freauenc $ 1,051.00 /MONTH $ 500.00 MONTH $ $ / 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 $ 356.94 per week, or 50 of the Unemployment Compensation benefits otherwise payable to the Defendant, TODD A. JEWELL Social Security Number 218 - 6 0 -10 3 0 , Member ID Number 5824100040 . BUCBA is ordered to remit the amount attached to the Department of Public Welfare (DPW). DPW shall forward the amount received from BUCBA to the Domestic Relations Section of this Court for support and/or support arrearages. If the Defendant's Unemployment Compensation benefits are attached by another Court or Courts for support and/or support arrearages, DPW may reduce the amount attached under this Order so that the total amount attached does not exceed the maximum amount subject to garnishment pursuant to 15 U.S.C. § 1673 (b)(2) and 23 Pa. C.S.A. § 4348 (g). This Order shall be effective upon receipt of the notice of the Order by the BUCBA and shall remain in effect until the Defendant's entitlement to Unemployment Compensation benefits, under the Application for Benefits dated MAY 14 , 2006 is exhausted, expired or deferred. BUCBA shall comply with this Order, unless it is amended or vacated by subsequent Order of this Court. All questions, challenges or obligations to this Order shall be directed to the Domestic Relations Section of this Court. BY THE COURT Date of Order: FEB 112001 DRO: R. J. SHADDAY Service Type M -Ae- - - .* Ao? KEVIN A. HE , JUDGE Form EN-530 Worker ID $ IATT ` © ?1 [ - c_-a G7 T1 '^a _y ?_. ? E7"1 ? ..Mf I. ?M F? ? f ? .. ? ?, _yy.. V? W ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania 379100107 1136 S $9 Co./City/Dist. of CUMBERLAND Date of Order/Notice 02/01/08 Case Number (See Addendum for case summary) Employer/Withholder's Federal EIN Number CONTINENTAL ELECTRIC COOP SERV PO BOX 1266 212 LOCUST ST HARRISBURG PA 17108-1266 RE: JEWELL, TODD A. 98-2780 CIVIL O Original Order/Notice O Amended Order/Notice O Terminate Order/Notice Employee/Obligor's Name (Last, First, MI) 218-60-1030 Employee/Obligor's Social Security Number 5824100040 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 notice even if the Order/Notice is not issued by your State. $ 1, 551.00 per month in current support $ o. oo per month in past-due support Arrears 12 weeks or greater? Dyes ® no $ 0.00 per month in current and past-due medical support $ 0.00 per month for genetic test costs $ 0, 00 per month in other (specify) for a total of $ 1, 551.00 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: $ 357.92 per weekly pay period. $ 715.85_per biweekly pay period (every two weeks). $ 775.50 per semimonthly pay period (twice a month). $ 1, 551. 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 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). If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call Pennsylvania State Collections and Disbursement Unit (PA 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: FEB 11 2008 DRO: R. J. SHADDAY Service Type M KEVIN HESS, JUE)a F EN 028 Rev 1 OMB No.: 0970-0154 orm - Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If heck you are required to provide a opy of this form to your, m loyee. If yo employee orks in a state that is diferent from the state that issued this order, a copy must be provic?ec?to your emplr oyee even if t?1e box is not checked. 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 employee/obligor. 3.* Repo. ting the Paydat&Date ot Wit' hold -11%. T-LJU I I 11.1bl. MpUlt Lite Payuatelu licil il1C PQy111C111. I11c 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. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2518576800 EMPLOYEE'S/OBLIGOR'S NAME: JEWELL, TODD A. EMPLOYEE'S CASE IDENTIFIER: 5824100040 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: 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 employeelobligor'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. Antidiscrimination: 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 0 5 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 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 amounts allowed under the law of the state that issued the order. 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. Submitted By: If you or your employee/obligor have any questions, DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 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. 1 Worker ID $zATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: JEWELL, TODD A. PACSES Case Number 379100107 Plaintiff Name CASANDRA A. JEWELL Docket Attachment Amount 1136 S 89 $ 1,051.00 Child(ren)'s Name(s): DOB CHYANN ELIZABETH JEWELL 1118/96 ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number 709106103 Plaintiff Name CASANDRA A. JEWELL Docket Attachment Amount 98-2780 CIVIL$ 500.00 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/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available identified above in any health insurance coverage available through the employee's/obligor's employment. through the employee's/obligor's employment. Addendum Form EN-028 Rev. Service Type M Worker ID $IATT OMB No.: 0970-0154 a ? tip , 98-2780 CIVIL ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Penn ylvania 379100107 O Original Order/Notice Co./City/Dist. of CUMBERLAND 1136 S 89 O Amended Order/Notice Date of Order/Notice 02/14/08 O Terminate Order/Notice Case Number (See Addendum for case summary) RE: JEWELL, TODD A. Employer/Withholder's Federal EIN Number Employee/Obligor's Name (Last, First, MI) 218-60-1030 Employee/Obligor's Social Security Number CONTINENTAL ELECTRIC COOP SERV 5824100040 PO BOX 1266 Employee/Obligor's Case identifier 212 LOCUST ST (See Addendum for plaintiff names HARRISBURG PA 17108-1266 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 notice even if the Order/Notice is not issued by your State. $ o. o0 per month in current support $ o . oo per month in past-due support Arrears 12 weeks or greater? Oyes ® no $ 0.00 per month in current and past-due medical support $ 0.09 per month for genetic test costs $ o . 0o per month in other (specify) for a total of $ 0.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ o . o o per weekly pay period. $ o . 00 per biweekly pay period (every two weeks). $ o. oo per semimonthly pay period (twice a month). $ o. 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 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). If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call Pennsylvania State Collections and Disbursement Unit (PA 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 NAMEAND 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: }a Date of Order: FEB 14 2008 KEVIN A. SS, JUDGE DRD: R.J. SHADDAY Form EN-028 Rev. 1 Service Type M oMBNo.:0970-0,54 Worker ID 21205 ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If hecked you are required, to provide a copy of this form to your m loyee. If yo r employee works in a state tha is dii?ferent from the state that issued this order, a copy must be provicedpto your emproyee 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 employee/obligor. 3.* RepOrtiiir, the Paydate/Date of Withholding. You must repoit the paydate/date of withholding when sending, the payment. T le payd-at-"ate o"withholding is the date on which amount was withheld . 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. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2518576800 EMPLOYEE'S/OBLIGOR'S NAME: JEWELL, TODD A. EMPLOYEE'S CASE IDENTIFIER: 5824100040 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: 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. Antidiscrimination: 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 0 5 U.S.C. §1673 01; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 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 amounts allowed under the law of the state that issued the order. 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. I I. Submitted By: If you or your employee/obligor have any questions, DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT 13 N. HANOVER ST by telephone at (717) 240-6225 or P.O. BOX 320 by FAX at (717) 240-6248 or CARLISLE PA 17013 by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Rev. 1 Service Type M Worker ID 21205 OMB No.: 0970-0154 ADDENDUM Summary of Cases on Attachment Defendant/Obligor: JEWELL, TODD A. PACKS Case Number 379100107 Plaintiff Name CASANDRA A. JEWELL Docket Attachment Amount 1136 S 89 $ 0.00 Child(ren)'s Name(s): DOB CHYANN ELIZABETH JEWELL 11/18/96 KAITLYN NICOLE JEWELL 11/18/96 ?if checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's.employment. PACKS Case Number 709106103 Plaintiff Name CASANDRA A. JEWELL Docket Attachment Amount 98-2780 CIVIL$ 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/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 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/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB D if checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 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/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 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/obligor's employment. Addendum Form EN-028 Rev. 1 Service Type M Worker ID 21205 OMB No.: 0970-0754 C?o ? i ?- tli C7 1.3 , ' n In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION 13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013 Phone: (717) 240-6225 Fax: (717) 240-6248 Defendant Name: TODD A. JEWELL Member ID Number: 5824100040 Please note: All correspondence must include the Member ID Number. ORDER TO VACATE ATTACHMENT OF UNEMPLOYMENT BENEFITS Financial Break Down of Multiple Cases on Attachment Plaintiff Name CASANDRA A. JEWELL CASANDRA A. JEWELL PACSES Docket Case Number Number 379100107 1136 S 89 709106103 98-2780 CIVIL TOTAL ATTACHMENT AMOUNT: $ 0.00 Attachment Amount/Frequency $ 1,051.00 /MONTH $$$ 500.00 MONTH / / The prior Order of this Court directing the Department of Labor and Industry, Bureau of Unemployment Compensation Benefits and Allowances (BUCBA), to attach $ o. o o or -go % per week of the Unemployment Compensation benefits of TODD A. JEWELL , Social Security Number 218-60-1030 , Member ID Number 5824100040 is hereby vacated. This Order to Vacate shall be effective upon receipt of the notice of the Order by the Department and shall remain in effect until a further Order of the Court is filed. BY THE COURT Date of Order: FEB 15 2008 DRO: R.J. SHADDAY Service Type M ;J?'- .4 X4 KEVIN A. S, JUDGE Form EN-035 Worker ID $ IATT t i " r 1 ? d 7 ?: r. 1 r-n r,' x