HomeMy WebLinkAbout98-06905
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IN THE COURT OF COMMON
PLEAS
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OF CUMBERLAND COUNTY
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STATE OF
PENNA.
RrnEE ELLI\ ANDEHSO'I,
PLflINTIFF
,,\ , " 98-6905 CIVIL
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JAMES NORRIS ANDEJlSO'I,
DEF'ENDANT
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AND NOW. ' "~, , ,- /, /12000,. it is ordered and i~
decreed that", ,Ren"'e, EHaAnoerson" ". plaintiff, l~
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and, "', James Norris Anderson defendant, I:
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are divorced from the bonds of matrimony,
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The court retains jurisdiction of the following claims which have
been raised of record in this action for which 0 fino I order has not yet
been entered;
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None
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(b) Dale Plaintiffs Waiver of Notice in ~ 3301(c) Divorce was filed with the
prothonotary: Octoher 23,2000
Date Defendant's Waiver of No lice in ~ 3301(c) Divorce was filed with the
prothonotary: Octoher 11. 2000
Dated: (~e,-" :..> I
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Susan Kay CandiE
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RENEE ELLA ANDERSON,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO.1(i - &906- CIVIL
CIVIL ACTION - LAW
VS.
JAMES NORRIS ANDERSON,
Defendant
ACTION FOR DIVORCE
COMPLAINT FOR NO-FAULT DIVORCE
UNDER 3301(c) OF THE DIVORCE CODE
1. The Plaintiff is RENEE ELLA ANDERSON, who currently
resides at 5011 Seneca Drive, Mechanicsburg, Cumberland County,
Pennsylvania, 17055, and has resided in Cumberland County for over
six (6) months.
2. The Defendant is JAMES NORRIS ANDERSON, who currently
resides at 5011 Seneca Drive, Mechanicsburg, Cumberland County,
pennsylvania, 17055, and has resided in Cumberland County for over
six (6) months. The business address which Mr. Anderson prefers
all mail to be addressed to is: 299 North Dunton #204, Arlington
Heights, Illinois, 60004.
3. The Plaintiff and Defendant have been bona fide residents
in the Commonwealth for at least six (6) months immediately
previous to the filing of this Complaint.
4. The Plaintiff and Defendant are husband and wife and were
lawfully married on December 27, 1969 at McGuire Air Force Base in
New Jersey.
5. Two (2) children were born of this marriage. Neither
children arc minors. one child is stili rosiding with the plaintiff
while attending school. however. there are no marl tal issues
involving this child.
6. Defendant was a member of the united States Air Force.
however. the amount of time served by the Defendant was only
approximately five (5) years and therefore no military benefits are
in existence. which are at issue as marital property in this
action.
7. There have been no prior actions of divorce or for
annulment between the parties except this complaint filed for
divorce.
8. Plaintiff and Defendant have been advised of the
availability of counseling, and of the right to request that the
Court require the parties to participate in counseling.
9. The marriage is irretrievably broken.
10. After ninety (90) days have elapsed from the date of
filing of this complaint, Plaintiff intends to file an affidavit
consenting to a divorce. plaintiff believes that Defendant may
also file such an Affidavit.
WHEREFORE, Plaintiff respectively requests if both parties
file affidavits consenting to a divorce after ninety (90) days have
elapsed from the date of filing of this complaint, this Honorable
Court enter a decree of divorce pursuant to Section 3301(c) of the
Divorce Code.
VERIFICATION
The undersigned hereby verifies that the facts averred in the
foregoing Complaint for Divorce are true and correct to the best of
her knOwledge, information, and belief.
This verification is made subject to the penalties of 18 Pa.
C.S.A. 54904 relating to unsworn falsification to authorities.
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R~ELLA ANDERSON
DATED: NOvember~, 1998
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RENEE ELLA ANDERSON,
PLAINTIFF
: IN Tin: COllin OF COMMON PU:AS OF
: CUMDEIU.MW COUNTY. Pf:NNSYLVANIA
V5.
: NO. 98-690!i CIVIL
: CIVIL ACTION - LAW
JAMES NORRIS ANDERSON,
DEFENDANT
: ACTION FOR DIVORCE
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AFFIDA VIT OF SERVICE CERT....IED MAIL
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF CUMBERLAND
Be it known, that on the 21 st day of December, 2000, before me, the subscriber, a
Notary Public, personally appeared SUSAN KAY CANDIELLO, who, being duly sworn
according to law, did depose and state as follows:
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\, I am an attorney licensed to practice law in the Commonwealth of Pennsylvania,
and I am employed by the law firm of Gates & Associates, p,c., Lemoyne, Pennsylvania_
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2, My law firm represents Renee Ella Anderson, Plaintiff in the above-captioned
matter_
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3, On December 10, 1998, a true and correct copy of the Complaint for No-Fault
Divorce Under 3301(c) of the Divorce Code was deposited for delivery with the V,S, Postal
Service in Camp Hill, Pennsylvania, being Certified/First Class Mail, restricted delivery, return
receipt requested, Article No, Z 124 051 376, and addressed to the Defendant, James Norris
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Anderson, at 299 North Dunton #204, Arlington Heights, IL 60004,
4, The return receipt card signed by the Defendant, James N, Anderson, showing a
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EXIIIBIT "A"
i -Con\Jlf..IC;"'" f ~0I2 for -**fionII Mme..,
i aComplalelteml 3, .1, and .b.
I . Pritt your MfM and addrnl on the revert. 01 thlt form 10 thai wtI can ,eturn IhI,
card 10 you.
Unach ltllt fonn to the front of the mailpec., (It on the badt If apace doH no!
I .e::!RefUm R<<eipf Requested. on 1M mallpi': ~w Itlt artide number.
ti -The Return RteelpC wi. shoW 10 whom the artlde was de~ Ind I.... date
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13. Mole Addressed to:
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I also will> 10 recaJvBIIle
following ..Nico. (101 an
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1. D Addr.....'. Addr... ~
2. fit Restrlcled Oellvooy j
~JII poslmast.r for f... -t
44. Article Number J
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4b. S.rvlc. Typ.
D R.glstered Jtl Certined
D Expr.ss Me/I 0 Insured .r
D R.lurn Recelpllor Merthandse 0 COO ~
7. Oat. of O.lIv.oy ::
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JAflliS NORRIS ANDERSON
299 NORTlI DUNTON 11204
!J/LWCTON lIEIGlIT'S IL
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5. Rec.lved By: (Print N91"~
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~ 6. Slgnatura: (Addressee r ~BtlI)_
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8. Addressee's Address (Only If requested
end (ee Is p.ld)
Domestic Return Receipt
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IU:NEE ELLA ANI>ERSO;\;.
Plainliff
: I;\; TilE COlJRT OF (,O:\l:\ION PLEAS OF
: ClIi\IIlERI.ANIl ('OllNTY.I.E....NSYI.\'ANIA
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CIVIL MTIO;\; . L\ W
9fl.(,11lI5 LlVIL TERM
.lAMES ;\;ORIUS ANI>ERSON,
1>(.fcnd:lIIt
(iii I>IVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
J. A complaint in di\'llr~e under Section 330 I (~) or the ()i\'or~e ('ode was filed on
December fl, 199fl.
2. The marriage or plaintiff and dctcllllant is irretrievably broken and ninety days have
elapsed from the date orthe tiling of the complaint.
3. I consent to the entry or a final decree in divorce,
4. I understand that I may lose rights concerning alimony, division of property. lawyer's
fces or expenses if I do not elaim them bctc)re a divorce is granted.
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I verity that the statements made in this at1idavit arc true and correct. I understand that
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tlllse statements herein made arc subject to the penalties of 18 Pa. C. S, Section 4904 relating to
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unsworn falsification to authorities.
Datc:
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,2000
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RENEE ELLA ANDERSON
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RENEE ELLA ANUERSO:'\:,
Plaintiff
: I:'\: TIlE COllIn OF COi\li\ION PLEAS OF
: Cl1i\IHERLMm COUNT\', ('ENNS\'I.V,\NIA
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CIVIL ACTION - LAW
911.6905 CIVIL TEIUI
.IAMES NORRIS ANDlmSON.
Ucfrndllnl
IN IlIVORCE
WAIVEI{ OF NOTICE OF INTENTION TO REQIJEST
ENTIW OF A I)IVORCE DECREE UNDER
SECTION 3301(r) OF TilE DIVORCE CODE
I. f consent to the entry of II Iinal Decree of Divorce without notice.
2. lunderstund that Imuy lose rights conccrning ulimony. division of property. lawyer's
fces or expenses if I do not e1uimthem bet()re u divorce is grantcd.
3. funderstund that I will not be divorccd until a divorce decrec is cntered by the Court
and that a copy of thc decrec will be sent to mc immediately uncI' it is tiled with the
Prothonotary_
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I verity that the statemcnts made in this atlidavit arc true and correct. I understand that
tlllse statements hcrcin made arc subjcct to thc pcnalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsitieation to authorities.
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RENEE ELLA A
Plaintiff
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RENEE ELLA MWERSO:O-:.
.'I..lnliff
: 1:0-: TilE COlJRT OF CO;\Ii\ION "LEAS OF
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: ClJi\tnERI.A:O-:1> COliNTY. PENNSYLVANIA
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CIVIL ,\CTIO:O-: -LAW
9H.(,l)05 CI\'II. TERi\1
JAMES NORRIS ANDERSON.
Il(.frlldllllt
IN I>IVORCE
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DEFENDANT'S AFFIDAVIT OF CONSENT
I. A complaint in divorce under Section 3301(c} of thc Divorce Code was lilcd on
December X. 1998.
2. The marriagc of plaintiff and defcndant is irrctrievably broken and ninety days have
elapsed Irom the date of the tiling of the complaint.
3. I conscntto the entry of a linal decree in divorce.
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4. I understand that I may lose rights conceming alimony, division of property, lawyer's
tees or expenses if I do not claim them belc.lre a divorce is granted.
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I verify that the statements made in this aftidavitare true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. S, Section 4904 relating to
unswom falsilication to authorities.
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Date: October 11th _.2000
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RENEE ELLA A;'IiI>ERSO:'li.
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: 1:'Ii TilE COllin OF CO:\J:\IO;'li PLEAS OF
: ('I'MIlERI.ANI> ('OllNT\'.I'Ei'\NSYI.V,\NIA
v.
CI\'II. ACTION. LA W
9H.()l)1I5 CIVIL TER:\I
.IAMES NORRIS ANI>ERS():'Ii.
I>rfrndllnl
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WAIVEI~ OF :'IiOTICE OF INTE:'IITIO:'ll TO REQUEST
ENTRY OF A DI\'ORCf: DEelum VNI)EI~
SECTION 3311\(r) OFTI/E J)\VORCE CODE
I. I consent to the entry of a tin..1 Decree of Divorce without notice.
2. I underst..nd th..t I may lose rights concerning alimony, division of propeny, lawyer's
fees or expenses if I do not claim them bell1Te a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Coun
and that a copy of the decree will be sent to me immediately atter it is filed with the
Prothonotary .
I verify that the statements made in this aflidavit arc true and correct. I understand that
false st..tements herein made arc subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn lalsitication to authorities.
Date: October 11 th ,2000
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RIS ANDERSON
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NOW. THEREFORE, ill cOllsidcflltioll ofthcse prcmiscs nnd ofthc mulllnl promiscs nml
undcrtakings hcreinafter set forth, nnd for other good and valuable consideration, receipt and
sufficiency of which is hereby acknowledged by each of the parties hereto. each intending to be legally
bound hereby, covenant, and agree as follows:
t. ADVICE OF COUNSEL.
The provisions of this Agreement and their legal effect have been fully explained to the parties
by counsel for the Plaintiff, Susan Kay Candiello, Esquire, of Gates & Associates, P.C, and by
counsel for the Defendant, Marcus A. McKnight, 111, Esquire, ofIrwin, McKnight & Hughes, Each
party acknowledges that he or she has received independent legal advice from counsel as they desire,
and that each fully understands the facts and has been fully informed as to their legal rights and
obligations, and each party acknowledges and accepts that this Agreement is, in the circumstances,
fair and equitable, and that it is being entered into freely and voluntarily, after having received such
advice and with such knowledge, and that execution of this Agreement is not the result of duress,
undue influence, any improper or illegal agreements,
2. PERSONAL RIGHTS.
The parties may at all times hereafter, live separate and apart, Each shall be free from all
control, restraint, and interference and authority, direct or indirect, by the other. Each may reside at
such place or places as they may select. Each may conduct, benefit from, carry on or engage in any
business, occupation, profession, or employment which to them seems advisable, They shall not
molest, harass, disturb, or mahgn each otl:er, or the respective families of each other, nor compel or
allempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with the
other, Neilher pany shall irllcrferc wilh thc IISC. owncrship, cnjoYl11cl1l or disposilionofany propeny
now owned by or hereallcr aequircd by the othcr
3. MUTUAL CONSENT DIVORCE.
The panics acknowledge that PlaintitT initiated an action in divorce on December 8, 1998 in
the Cumberland County Coun of Common Pleas docketed at No, 98-6905, It is the intention of the
panies that by this Agreement they have resolved all ancillary economic issues attendant 10 this
divorce action_ Therefore, both panies agree that, each shall sign and file a Waiver of Notice of
Intent to Request Entry of A Divorce and an Affidavit of Consent, with Susan Kay Candiello,
Esquire. counsel for Plaintiff, to be submitted to the coun with a Praecipe to Transmit Record, Vilal
Statistics fonn and any and all other documents necessary to precipitate the entry of a divorce decree_
4. EDUCATION OF' CHRISTOPHER ANDERSON.
Defendant agrees to be financially responsible for Christopher Anderson's undergraduate
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expenses. These expenses shall include, but not be limited to the following:
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A. Tuition;
B. Room and Board;
C, Books, Supplies, Laboratory Fees and any other expenses related to Christopher's
educational curriculum,
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EOlJlTABI,E J>ISTRlIJllTION
5. REAL PROPERTY
A. MARITAL PROPERTY:
The parties acknowlcdge they are the joint owners of that certain real property and all
improvem~nts thereupon located at SOIl Seneca Drive, Mechanicsburg, Cumberland County,
Pennsylvania, 17055 (hereinafter refcrred to as the "Marital Residence"), The parties agree Plaintiff
shall retain possession of and receive as her sole and separate property the Marital Residence. along
with any rights under any insurance policy thereon, and the responsibility for payment of any
outstanding indebtedness pertaining thereto and insurance thereon. Plaintiffshall indemnifY and hold
Defendant and his property harmless from any liability, cost, or expense, including allomey's fees,
incurred in connection with the marital residence,
Defendant agrees to cooperate and participate in the execution of all documents and all
procedures necessary to transfer the Defendant's full interest in the marital property to the Plaintiff.
B. COLORADO PROPERTY:
1. FILING 14 PARCEL 23 of SOUTH PARK RANCHES,
PARK COUNTY, COLORADO:
The parties acknowledge they are the joint owners of that certain real property and all
improvements thereupon located at Filing 14 Parcel 23 of South Park Ranches located in Park
County, State of Colorado, as per survey map recorded in the County Recorder's Office in Fairplay,
Colorado, (hereinafter referred to as the "Colorado I"), The parties agree Plaintiff shall retain
possession of and receive as her sole and separate property Colorado I, along with any rights under
any insurance policy thereon, and the responsibility for payment of any outstanding indebtedness
pertaining thereto and insurance thereon PlainlilT shall indemnify and hold Defendant and his
property harmless from any liability, cost, or expense. including attorney's f~'Cs, incurred in connection
with Colorado 1.
Defendant agrees to cooperate and participate in the execution of all documents and all
procedures necessary to transfer the Defendant's full interest in Colorado I to the Plaintiff.
2. 102 SALINA MOUNTAIN ROAD.
BOULDER COUNTY, COLORADO:
The parties acknowledge Defendant is the sole owner of that certain real property and all
improvements thereupon located at 102 Salina Mountain Road, Boulder County. State of Colorado,
(hereinafter referred to as the "Colorado 2"), The parties further acknowledge Colorado 2 was
purchased from the Defendant's inheritance from his father's estate during the parties' marriage. The
parties agree Defendant shall retain possession of and receive as his sole and separate property
Colorado 2. along with any rights under any insurance policy thereon, and the responsibility for
payment of any outstanding indebtedness pertaining thereto and insurance thereon. Defendant shall
indemnitY and hold Plaintiff and her property hannless from any liability. cost, or expense, including
allorney's fees, incurred in connection with Colorado 2.
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Plaintiff agrees to cooperate and participate in the execution of all documents and all
procedures necessary to transfer any marital interest which she may have in Colorado 2 to the
Defendant.
6. HOUSEHOLD AND PERSONAL PROPERTY_
The parties have agreed upon a partial division of their marital property, Attached at
Appendix "A" please find a list of some of the marital property which the Defendant has requested,
Defendant retains the right to request additional marital property still remaining in the marital
residence through December 31. 2000 l'laintilT has agreed \0 consider any additional requests for
marital property, All remaining marital property not identified on the list found at Appendix" A" and
not requested by the Defendant by December 3 I. 2000. shall be considered the property of the
Plaintiff,
PlaintilT shall receive the following twO (2) items of personal property to use and enjoy during
herlife, so long as she shall desire to do so, PlaintilTagrees ifshe should choose, for whatever reason
to no longer keep either or both of these twO (2) items for her own personal pleasure and use, these
items shall be returned to the Defendant or they may be given to one or both of her children: Brass
lamp with green shade, and sewing table,
Defendant agrees he shall be responsible for the removal ofthe marital property which he has
requested no later than December 31, 2000, Defendant has agreed to be responsible for the removal
and disposal of the copier in the garage. The parties further agree as of December 31, 2000, any and
all right, title, claim and interest in and to all of the marital property which the Defendant has not
requested and/or removed from the marital residence is transferred and assigned to the party in
possession of the property at that time, This Agreement shall constitute a sufficient bill of sale to
evidence the transfer of any and all rights in such property from one party to the other.
7. AUTOMOBILES,
The parties agree Plaintiff shall retain possession of and receive as her sole and separate
property the 1990 Dodge Caravan, along with any rights under any insurance policy thereon, and the
responsibility for payment of any outstanding indebtedness pertaining thereto and insurance thereon.
Plaintiff shall indemnify and hold Defendant and his property harmless from any liability. cost, or
expense, including allomey's fees, incurred in connection with the automobile
The parties agree PlainliO'shall retain possession of and receive as her sole and separate
property the 1985 Ford Thunderbird Plaintiff agrees to hold the 1985 Ford Thunderbird for the
parties' son, Christopher, until such time as he is able to assume full responsibility for the automobile,
At which time. the Plaintiffagrecs to cooperate fully to have the title to the] 985 Ford Thunderbird
transferred to the parties' son, Christopher,
The Defendant agrees to assume full responsibility for payment of any outstanding
indebtedness pertaining to the 1985 Ford Thunderbird, The Defendant agrees he will consider being
responsible for or providing assistance with any repairs to the 1985 Ford Thunderbird, ifhe is first
consulted and his agreement obtained for the repairs, The Plaintiff agrees to be responsible for the
payment of automobile insurance for the 1985 Ford Thunderbird, along with any rights under any
insurance policy thereon, until such time as the parties' son, Christopher, shall assume full
responsibility for the 1985 Ford Thunderbird, including all outstanding indebtedness pertaining
thereto. Defendant shall indemnifY and hold Plaintiff and her property harmless from any liability,
cost, or expense, including allomey's fees, incurred in connection with the automobile, until such time
as the parties' son, Christopher, shall assume full responsibility for the automobile.
The Defendant agrees to relinquish all right and title to the 1990 Dodge Caravan, in
recognition of the fact he bas chosen to continue to use a leased automobile tbrough his employer.
8. PERSONAL LOANS AND DEBTS.
At the time ofthe separation the parties divided the responsibility for any joint debt which was
not attached to any real property, The parties also closed and/or had the other party removed from
I, Spreekels Industrics, Inc Industriall'wduCIS Group Pcnsion Plan for
Non-Union Employccs,
2, Amcrican ManufaclUring Corporation and Subsidiaries Pension Plan 1'-3
(Philadelphia Gear Industries); and.
3, John Crane Pension Plan
shall be divided equally (50/50) between the parties through the use of Qualified Domestic Relations
Orders, The parties recognize the Spreckels Industries and the Philadelphia Gear Industries pension
plans have closed and they will share the entire plan benefits equally (50/50), The parties further
recognize the Defendant is still employed with John Crane and therefore the benefits which the parties
will share equally (50/50) will only be those benefits from the commencement of the Defendant's
employment through December 3], 1998,
Plaintiff'hereby waives, relinquishes, and forever abandons any interest in and to the Spreckles
Industries, Inc. 40 I K account, also known as the Columbus-McKinnon. Defendant shall keep as his
sole and separate property the Spreckles Industries, Inc, 401 K or Columbus-McKinnon account in
the amount ofThirty-Five Thousand Three Hundred Eighty-Three Dollars and no cents ($35,383.00).
Plaintiff' hereby waives, relinquishes, and forever abandons any interest in and to the 401 K
John Crane retirement account. Defendant shall keep as his sole and separate property the 40 1 K John
Crane retirement account in the amount of Thirty- Two Thousand Nine Hundred Sixty-Five Dollars
and no cents ($32,965.00),
Defendant hereby waives, relinquishes, and forever abandons any interest in and to the IRA
account (account #360-70568) with Legg Mason Wood Walker which is solely in the Defendant's
name, in the amount of Seventy-Five Thousand Nine Hundred Fifteen Dollars and Forty-One Cents
($75,915.41) These monies shall be transferred into an IRA account with Legg Mason Wood
Walker, which is solely in the name of the I'llIintil1'
Defendant hereby waives, relinquishes, and forever abandons any interest in and to the IRA
account (account 11360- 70677) with Legg Mason Wood Walker which is solely in the Plaintil1's name
in the amount of Sixteen Thousand Five Hundred and Eighty.Five Dollars and Seventy-Five Cents
($16,585,75), Plaintiffshall keep these monies as her sole and separate property-
11. ALIMONY.
Defendant agrees to pay to Plaintiff the sum of Seven Hundred Dollars and no cents ($700,00)
from each of the Defendant's bi-weekly pay periods through June 30, 2002 and Six Hundred Fifty
Dollars and no cents ($650,00) from each of the Defendant's bi-weekly pay periods through June 30,
2003, at which time the Defendant's responsibility for providing any alimony to the Plaintiff will
tenninate, These alimony payments shall be allocated to the Plaintiff for tax purposes, for her
support and maintenance,
12. COUNSEL FEES. COSTS AND EXPENSES,
Defendant has agreed to be responsible for all legal fees, costs, and expenses incurred in
connection with the dissolution of this marriage.
13. MODIFICATION.
No modification. rescission, or amendment to this Agreement shall be effective unless in
writing signed by each party to this Agreement,
14. APPLICATION OF LAW.
All acts contemplated by this Agreement shall be construed and enforced under the laws of
the Commonwealth of Pennsylvania in effect as of the date of execution of this Agreement.
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RENEE ELLA ANDERSON,
Plaintiff
: IN TilE COlJRT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYLVANIA
vs.
: NO. 98-6905 CIVIL
: CIVIL ACTION - LAW
JAMES NORRIS ANDERSON,
Defendant
: ACTION FOR DIVORCE
PETITION FOR OUALlFIED DOMESTIC RELATIONS ORDER
AND NOW, this -20 of ikcQ/V\>o h"--^--.... 2000 the Plaintiff, Renee Ella
Anderson, by and through her attorneys, Gates & Associates, P,C" avers the following:
1, The parties entered into a Marital Settlement Agreement indicating that the
Plaintiffwil\ be receiving a Qualified Domestic Relations Order (QDRO) in the Defendant's
pension;
2. The attached QDRO has been prepared for and reviewed by the parties and it is
appropriate for final Order of Court,
WHEREFORE, the Plaintiff respectfully requests this Honorable Court to execute the
attached QDRO in order to segregate her portion of the Defendant's pension,
Respectfully submitted,
GATES & ASSOCIATES, P,C,
Dated: ~),.". ~ 0 , 2000
c::::" ' .C:_
Susan Kay C ndi 110, Esquire
COl/llsel for [)Iain/iff
PA J.D. # 64998
1013 Mumma Road, Suite 100
Lemoyne, PA 17043
(717)73 1-9600
..
B. IIn:NTITIES:
I. PARTICIPANT: The Participant is the Defendant, JAMES NORRIS ANDERSON,
Mr. Anderson's social security number is (J<J9.38.2864, His birth date is December 2, 1946 and
his present address is 47110liday Harbour, Canandaigua. New York, 14424,
2. ALTERNATE PAYEE: The Alternate Payee is the Plaintiff. RENEE ELLA
ANDERSON, Ms, Anderson's social security number is 521-64-3645, Her birth date is March
14, 1947 and her present address is 5011 Seneca Drive. Mechanicsburg, Pennsylvania,
17055-2575, The Alternate Payee agrees to notify the Administrator of the Plan of any change in
address until all benefits payable to her hereunder have been paid,
3. PLAN: This QDRO applies to the Spreckcls Industries. 1nc, Industrial Products
Group Pension Plan for !l:on.Union Employees, (the "Plan"), Further, this Order shall apply to
any successor plan to the Plan or any other plan(s) to which liability for the provision of the
Participant's benefits described below are incurred, Any benefits accrued by the Participant under
a predecessor plan of the employer or any other defined contribution plan sponsored by the
Participant's employer, whereby liability for benefits accrued under such predecessor plan or other
defined contribution plan has been transferred to the Plan, shall also be subject to the terms of this
Order, Any changes in Plan Administrator, Plan sponsor, or name of the Plan shall not affect
Alternate Payee's rights as stipulated under this Order.
4. AWARD OF BENEFITS: The Plan Administrator is directed to identify FIFTY
Percent (50%) of the vested amount held in said Plan as of December 3 I, 1998, less any penalties
or taxes required to be withheld, provided that no part of the account, if any, previously allocated
to a prior spouse as an Alternate Payee, may be included in the amount being identified as the
property of the Alternate Payee under this Order. The Plan is a "Defined Benefits Plan", The
Participant is a Deferred Restricted Participant, the Alternate Payee is not. Under the Plan the
Participant may not choose to activate the Plan before the age of fifty-five (55) years, When the
Participant does choose to activate the Plan, the Participant may only choose from the following
options: Ten (10) year certain annuity; Life annuity; 50% joint with the right of survivorship; and,
100% joint with the right of survivorship, The Alternate Payee does not have the ability to
choose and/or alter the time of activation of the Plan, The Alternate Payee's interest in said plan
shall only be payable in a form permitted under the Plan and chosen by the Participant. The
Alternate Payee will not have a separate account in the Plan for accounting purposes, however the
Alternate Payee's portion of the Participant's account will remain at 50% including any future
earnings and losses orthe tmst subsequent to the date of this order, to the same extent as if the
Alternate Payee were a Deferred Restricted Participant.
The Alternate Payee shall be treated as a vested terminated Participant under the Plan only
for the purpose of receiving statements, reports, and/or summary plan descriptions at the time
and in any form permitted for vested terminated Participants under the Plan, and except as may
otherwise be provided in this Order. The Alternate Payee shall also designate beneficiaries for any
benefits payable after the death of the Alternate Payee The Alternate I'ayee shall execute any
forms required by the Plan Administrator
The Alternate Payee hereunder shall be deemed to be the distribute of any such benefit
received by her and shall include in her gross income, for the tax year of receipt, all retirement
benefits that she receives pursuant to this Assignment of Panicipanfs benefits and accordingly the
Panicipant shall not include such benefits in his gross income, The Alternate Payee shall be
treated as the sole distribute under the Internal Revenue Code Sections 72 and 402 of any
payment or distribution that is made to her under this Assignment of Benefits,
This assignment does not require the plan to pay benefits to an Alternate Payee which arc
required to be paid to another Alternate Payee under a prior Qualified Domestic Relations Order,
The Alternate Payee, or her attorney, shall deliver a copy of this cenified Order to the
Administrator for said Plan at Mechanical Products, 1824 River Street, Jackson, MI 49202. by
hand delivery or cenified mail, as soon as practicable after entry of this Order,
J IT IS FURTHER ORDERED that all provisions of the Judgment of Divorce entered on
D,H~H"" I U , 2001, not in contlict with the terms ofthi~,prder shall remain in
full force and effect,....-;?/
,
APPROVED FOR ENTRY:
sfi cf i!fJ Cf1tr.<.1
EE ELLA ANDERSON, Plaintiff
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Attorney for Plainll
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JA\,1ES NORRis ANDERSON, Defendant
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COMMONWEALTII OF PENNSYLV ANI"
COUNTY OF &~ r;- I (v,t I a.. ... ..c
On this, thedOf.L day of.ikCf..!:fl~, 2000. before me, a Notary Public for the
Commonwealth of Pennsylvania. the undersigned officer. personally appeared RENEE EI.LA
ANDERSON. known to me (or satisfactorily proven) to be the person whose name is subscribed
to the within instrument. and acknowledged that she executed the same for the purpose therein
contained,
SS
IN WITNESS WHEREOF. I have set my hand and notarial seal,
~UU';/. ..4A'~~/~
Notary Public ~
My Commission Expires:
J r !, : c' ro :11 .f";,~, II
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L.. !:,~:l' j;ll:~)._;~~~.i~ri.'(,~~~_?:~(2~.[
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ST ATE OF ILLINOIS
SS:
COUNTY OF (Let<..
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On this, the ~ day of (./ ( , 2000, before me, a Notary Public for the
State of Illinois, the undersigned officer, personally appeared JAMES NORRIS ANDERSON.
known to me (or satisfactorily proven) to be the person whose name is subscribed to the within
instrument, and acknowledged that he executed the same for the purpose therein contained,
IN WITNESS WHEREOF, I have set my hand and notarial seal.
"OFFICIAL SEAL"
JACQUELINE MARY HOOK
NOi'ARY PUGLlC, STATE Of ILLINOIS
MY COMMISSION EXPIRES 8/6/2004
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RENEE ELLA ANDERSON.
Plain tilT
: IN Tilt: COURT OF COMMON PLEAS
: OF Cl1MUERt.AND COUNTY.
: l'ENNSYt.\oANIA
VS.
: NO. 98-6905 CIVIL
: CIVIL ACTION - LAW
JAMES NORRIS ANDERSON.
Defendant
: ACTION FOR DIVORCE
PETITION FOR OUALlFIED DOMESTIC RELATIONS ORDER
AND NOW, this ':;0
of ,('k ( c,",^" l-Jjl~'- ,2000 the Plaintiff, Renee Ella
Anderson, by and through her attorneys, Gates & Associates, P,C" avers the following:
I, The parties entered into a Marital Settlement Agreement indicating that the wife
will be receiving a Qualified Domestic Relations Order (QDRO) in the Defendant's pension;
2, The attached QDRO has been prepared for and reviewed by the parties and it is
appropriate for final Order of Court,
WHEREFORE, the Plaintiff respectfully requests this Honorable Court to execute the
attached QDRO in order to segregate her portion of the Defendant's pension,
Respectfully submitted,
GATES & ASSOCIATES, P,C,
-",
Dated: f1.~6 ~(}2000
Susan Kay CanJliell< - Esquire
COlIl/seljar Pllxil/li
P A 1.0, # 64998
1013 Mumma Road, Suite 100
Lemoyne, PA 17043
(717) 731-9600
RENEE ELLA ANDERSON,
Plaintiff
: IN TilE eOlIRT OF COMMON PLEAS
: OF ClIJ\18.:RLANI) COIlNTY,
: PENNS\'LVA:liIA
V5.
: NO. 98-6905 CIVIl.
: CIVIL ACTION - LA W
JAMES NORRIS ANDERSON,
Defendant
: ACTION FOR DIVORCE
OUALlFIED DOMESTIC RELATIONS ORDER
{\ I. The parties to this action have entered into a Marital Settlement Agreement dated
~ (Ol\Ak \{)O.A ~ 0 _ ,2000, The Court inco!:)lorated the Marital Seulement Agreement
into the Decree of Dissolulion of Marriage dated lJe~' '- ;;L 7 ,2000_
2, This Order creates and recognizes the existence of an Alternate Payee's right to receive
a portion of the Participant's benefits payable under an employer sponsored defined contribution
plan which is intended to he qualified under Internal Revenue Code of 1986 ("Code") 940 I (a),
The Court intends this Order to be a Qualified Domestic Relations Order ("QDRO") within the
meaning of Code 9414(p) The Court enters this QDRO pursuant to its authority under the 23
P,C,S_A, 93502,
3, This QDRO applies to the American Manufacturing Corporation and Subsidiaries
Pension Plan P-3 ("Plan") Further, this Order shall apply to any successor plan to the Plan or any
other plan(s) to which Iiahility for provision of the Participant's benefits described below is
incurred, Any benefits accrued by the Participant under a predecessor plan of the employer or any
other defined contribution plan sponsored by the Participant's employer, whereby liability for
benefits accrued under such predecessor plan or other defined contribution plan has been
transferred to the Plan, shall also be subject to the terms of this Order. Any changes in Plan
Administrator, Plan sponsor, or name of the Plan shall not affect Alternate Payee's rights as
stipulated under this Order,
4, JAMES NORRIS ANDERSON ("Participant") is a participant in the Plan, RENEE
ELLA ANDERSON ("Alternate Payee") is the alternate payee for purposes of this QDRO.
5, The Participant's name, mailing address, Social Security number and date of birth are:
James Norris Anderson
47 Iloliday Harbour
Canandaigua NY 14424
Social Security No, 099-38-2864
Date of Birth 12/02/46
6, The Alternate I'ayee's name, mailing address, Social Security number and date of birth
arc:
Renee Ella Anderson
50 II Seneca Drive
Mechanicsburg, PA 17055-2575
Social Security No, 521-64-3645
Date ofBirth 3/14/47
The Alternate Payee shall have the duty to notify the Plan Administrator in writing of any
changes in this mailing address subsequent to the entry of this Order,
7. The Plan Administrator is directed to segregate to the account of the Alternate Payee
FIFTY percent (50%) of the vested amount in said Plan as of December 31, 1998, less any
penalties or taxes required to be withheld, provided that no part of the account, ifany, previously
allocated to a prior spouse as an Alternate Payee, may be included in the amount being allocated
to the Alternate Payee under this Order.
8. This QDRO does not require the Plan to provide any type or form of benefit the Plan
does not otherwise provide,
9, This QDRO does not require the Plan to provide increased benefits,
1 a. This QDRO does not require the Plan to pay any benefits which another order
previously determined to be a qualified domestic relations order requires the Plan to pay to
another alternate payee.
II, The Plan shall distribute the amount designated in Paragraph 7 of this QDRO, as soon
as administratively feasible following the Plan Administrator's approval of this Order. If the Plan
does not permit an immediate distribution, the Plan shall pay such amount at the Participant's
earliest retirement age as defined by Code ~414(p)(4)(B) or at the retirement age elected by the
Participant, as allowed under the Plan,
12. Benefits are to be payable to the Alternate Payee in any form or permissible option
otherwise available to the Participant and alternate payees under the terms of the Plan, including,
but not limited to, a lump sum cash payment, The Alternate Payee shall execute any forms
required by the Plan Administrator.
13. On and after the date that this order is deemed to be a QDRO, but before the
Alternate Payee receives her distribution under the Plan, the Alternate Payee shall be entitled to all
of the rights and election privileges that are afforded to active participants, including but not
limited to, the rules regarding withdrawals and distributions, the right to name a beneficiary, and
the right to direct her Plan investments to the extent permitted under the Plan.
14, All payments made pursuant tolhis Order shall be conditioned on the certification by
the Alternate Payee and the Participant to the l'lan Administrator of such information as the Plan
Administrator may reasonably require from such parties
IS, It is the intention of the parties that a QDRO continue to qualify as a QDRO under
Code ~414(p), as it may be amended from time to time, and that the Plan Administrator shall
reserve the right to reconfirm the qualified status of the order at the time benefits become payable
hereunder.
16, In the event the Plan inadvertently pays to the Participant any benefits that are
assigned to the Alternate Payee pursuant to the terms of this Order, the l'articipant shall
immediately reimburse the Alternate Payee to the extent he has received such benefit payments
and shall forthwith pay such amounts received directly to the Alternate Payee within ten (10) days
of receipt.
In the event the Plan inadvertently pays to the Alternate Payee any benefits that are
assigned to the Participant pursuant to the terms of this Order, the Alternate Payee shall
immediately reimburse the Participant to the extent she has received such benefit payments and
shall forthwith pay such amount so received directly to the Participant within ten (10) days of
receipt,
17, In the event the Participant's benefits, or any portion thereof, become payable to the
Participant as a result of termination or partial termination, then the Alternate Payee shall be
entitled to commence her benefits immediately in accordance with the terms of this QDRO and in
accordance with the termination procedures of the Plan,
18, After payment of the amount required by this QDRO, the Alternate Payee shall have
no further claim against the Participant's interest in the Plan.
19. The Alternate Payee assumes sole responsibility for the tax consequences of the
distribution under this QDRO.
20. Until the Plan completes payment of all benefits pursuant to this QDRO, the Plan shall
treat the Alternate Payee as a surviving spouse for purposes of Code ~~ 401(a)(II) and 417, but
the Alternate Payee shall receive, as surviving spouse, only the amount described in Paragraph 7
of this QDRO, The sole purpose of this Paragraph 20 is to ensure payment to the Alternate Payee
in the event of Participant's death prior to payment by the Plan of the amount described in
Paragraph 7 of this QDRO. In the event of the Alternate Payee's death prior to the payment of
the benefits due to the Alternate Payee under this QDRO order, all benefits under this plan shall
go to the Participant.
21, The Plan shall treat this QDRO in accordance with Code ~4l4(p)(7), While the Plan
is determining whether this Order is a qualified domestic relations order, the Plan Administrator
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RENE": EI.I.A ANI>Jo:RSON,
1'luinlilT
IN TilE COURT 010' COMMON PU:AS
010' CUMIIERI.ANI> COUNTY.
PJo:NNSYI. VANIA
vs.
NO. 98-6905 CIVIL
JAMES NORRIS ANUEnSON,
l>crendunl
CIVIl. ACTION. LAW
ACTION Io'OR DIVORCE
fETITIQN FOR OVAI.lfIEO DOMESTIC RELATIONS ORDER
ANI) NOW, this ,.;(:) day of April. 2002, the Plaintiff, Renee Ella Anderson. by
and through her attorney. Susan Kay Candiello. Esquire. avers the following:
I. The parties entered into a Maritnl Settlement Agreement indicnting the Plaintiff
will be receiving a Qualified Domestic Relations Order (QDRO) in the Defendant's pension;
2. The attached QDRO has been prepared for and reviewed by the panics and it is
appropriate for final Order of COl/rt.
WHEREFORE, the Plaintiff respectfully, requests this Honorable Coun to execl/te lhe
attached QDRO in order to segregate her portion of the Defendant's pension.
Respectfully submitted,
LA W FIRM OF SUSAN KAY CANDIELLO, P.C.
Dated: April ,.2 ~. 2002
usan Kay Candiello
Coullsel for Plaillli
PA J.D. # 64998
5021 East Trindle Road
Suite 100
Mechanicsburg PA 17050
(717)796-1930
RENEE I<:U.A ANnl<:RSON.
1'llIintlff
IN TilE COURT ()J<' COMMON PLEAS
OF <.:lJMIIERLANn COUNTY,
PENNSYLVANIA
vs.
NO. 911-6905 CIVIL
JAMES NORRIS ANDERSON.
Defendant
CIVIL ACTION - LAW
A(.'TION FOR DIVORCE
OUAI.IFIED DOMESTIC REI.ATIONS ORDER
A. ORDER:
This order is intended to operate as a Qualificd Domestic Relations Order (QDRO) as
dcfincd and providcd for by the Retircment Equity Act of 1984. PL 98-397. If the Administrator
of thc Retirement Plan or Pcnsion Plan determines this QDRO does not so qualify, then the
parties shall immediately takc all steps necessary to cause the Administmtor to determine this
Order creates and recognizes the existence of an Alternate Payee's right to receive a portion of
the Participant's bcnefits payable under an employer sponsored defined benefit plan which is
qualified undcr ~501 of the Internal Revcnue Code of 1986, ("Codc"), and the Employment
Retirement Incomc Security Act of 1974 (ERISA). This Order is intcnded to constitute a QDRO
under 9414(p) of the Code and 9206(d) of ERISA. This Order is pursuant to the authority
granted in 23 P.C.S.A. 93502.
This court shall and does reserve jurisdiction to make such modifications as may be
necessary to ensure that these provisions comply with the requirements of said law. The
assignment made hereby is made pursuant to this Court's jurisdiction and duty under the laws of
the Commonwealth of Pennsylvania to make property selllements in divorce actions in
satisfaction of marital rights.
B. IDENTITIES:
1. PARTICIPANT: The Participant is the Defendant, JAMES NORRIS ANDERSON.
Mr. Anderson's Social Security Number is 099-38-2864. His birth date is December 2, 1946 and
his present address is 12 Woodlake Road, Albany, New York, 12203.
2. AI. TERNA TE PAYEE: The Alternate Payee is the Plaintiff, RENEE ELLA
ANDERSON. Ms. Anderson's social security numbcr is 521-64--3645. Her birth date is March
14, 1947 and her present address is 5011 Seneca Drive, Mechanicsburg. Pennsylvania. 17055-
2575. The Alternate Payee agrees to notify the Administrator of the Plan of any change in
address until all benefits payable to her hereunder havc been paid.
3. PLAN: This QDRO applies to the Spreckels Industries. JIll'. Induslrinll'mducts
Group Pension Plnn for Non-Uniou Employees. (the "Plnn"). Fur1hl'r, this Order shall apply In
any successor plan to the Plan or any other plan(s) to which liahility fur lhe provision of lhe
Participant's benefits descrilll:d below nre incurred. Any Ill:nefils accroed by tbe l'ar1icillilnl
under a predecessor plan of the employer or any other defined conlribntion plan sponsored hy lhe
Participant's employer. whereby.liability for benefits nccrued under such predecessor plan or
other defined contribution plan has been transferred to the Plan. shnllnlso be suhjecl In the terllls
of this Order. Any changes in Plan Administrator, Plan Sponsor, or nallle of the Piau shall not
affect Alternate Payee's rights as stipulated under this Order.
4, AWARD OF BENEFITS: The Plan Administralor is direcled to sellregate III the
account of the Alternate Payee FIFTY Percent (50%) of lhe vested allloont held in said Phlnas of
December 31, 1998, less any penalties or taxes required to be withheld. pruvided 1111I1 no pnrlof
the account, if any. previously allocnted to a prior spouse ns an Allerrlllle Payee. lIIay be incllllkd
in the amount being identified as the proper1y of the Allernate Pnyee under lhis Order. The
amount herein allocated to the Alternate Payee shnll Ill: pnyahle 10 the Allcrnale payce allhe
earliest date allowable under the terms of the Plan. The Altentnte I'nycc's inleresl in said Plan
shall be payable in any form permitted under the Plan. If lhe Allernate Payee's benefits donol
permit immediate distribution, the Plan shall pay such amonntalthe Participant's earliest
retirement age as defined by Code ~ 414(p)(4)(B). The Allentale I'ayee's accouul shall he
segregated from the Par1icipant's account for accounting purposes and shall share in earninlls
and losses of the trust subsequent to the date of this order. lothe sallie extclIlas if lhe Allernate
Payee were a vested terminated Participant.
If the Alternate Payee's accoont balance is not to be distribllted imllledinlely. the
Alternate Payee shall be treated as a vested terminated Par1icipant under the Plnn, to receive nil
statements, reports nnd lor summnry plan descriptions nnd to clecl distributions at the lime and in
any fonn pennitted for vested terminated Pnrticipants under the Plnn, except al\ualified joillland
survivor annuity for the Alternate Pnyee and her subsequent spouse under Ihe Plan, and except as
may otherwise be provided in this Order. The Allernate Payee shnllalso desigllnte beneficinries
for any benefits payable after the death of the Alternate Payee. If the Plan allows Participants to
direct investment of account balances, the direction shall be avnilable to the Alternate Payee.
The Alternate Payee shall execute any forms required by the I'lnn Adlllinistrutor.
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The Alternate Payee hereunder shall be deemed to be the distrihllte of any such benefit
received by her and shall include in her gross income, for the tnx yenr of reccipt. all rctircmenl
benefits she receives pursuant to this Assignment of Par1icipllnt's bcnctils and uccordingly the
Participant shall not include such bencfits in his gross income. The Alternute Paycc shull bc
treated as the sole distribute under the (ntemul Revcnuc Code ** 72 and 402 of IIny payment of
distribution that is made to her under this Assignmcnt of Benctils,
This Assignment does not require the Plan to pay henetits 10 an Altcrnutc Paycc which
are required to be paid to another allcrnate payee under u prior Qnulificd Domcstic Relations
Order.
The Alternate Payee. or her IIttorney. shall deliver II copy of Ihis certified Order 10 the
Adminislrntor for said Plan al Mechaniclll Prodncts. Attention: Mark naker. I K24 River Slreet.
Jackson. MI 49202. by hand delivery or certified mail. as soon liS practicllbl,' lifter enlry of this
Order,
IT IS FURTHER ORDERI.;D all provisions of the Judgment of Divorce entered on
December 27.2000, not in connicl wilh Ihe lerms of this Order sl1ll11 remain in full force IInd
effect. ,/ ;:'
nv THE COURT
,/'
'1 (LJ11 (J<...
/1/ / J{/
. jfiopie.2> ma:,leJ.
lS ,{':J..9'O~ l ~
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF tl\.~\)es\o..l\d
SS:
On this, the J~~ day of ~ ' 2002, before me, a Notary
Public for the Commonwealth of Pennsylv nia, the undersigned officer, personally appeared
RENEE ELLA ANDERSON known to me (or satisfactorily proven) to be the person whose
name is subscribed to the within Qualified Domestic Relations Order, and acknowledged that she
executed the same for the purpose therein contained.
IN WITNESS WHEREOF, I have set my hand and notarial seal.
J!;.~,~ 1 ~ !L . I\\()J~
Notary Public
My Commission Expires:~ 1I )O)D05
Notarial Saal
Klmbariy R. Hanford, Notary Public
Mechanlcsburg 90<0, Cumballand COUnty
My Commlsalon Explras Apr. 4, 2005
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