HomeMy WebLinkAbout00-05412
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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PENNA,
STATE OF
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Mary M, Moran
Plaintiff
No. 00-5412 Civil Term
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VERSUS
Patrick T. Moran
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Defendant
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DECREE IN
DIVORCE
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jolJ( , IT IS ORDERED AND
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AND NOW,
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Mary M. Moran
, PLAINTIFF,
DECREED THAT
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Patrick T. Moran
, DEFENDANT,
AND
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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 A FINAL ORDER HAS NOT
YET BEEN ENTERED;
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None
The terms of the marital settlement agreement are
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incor orated but not
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ATTEST:
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d PROTHONOTARY
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MARY M. MORAN,
Plaintiff,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
CIVIL ACTION - LAW
PATRICK T. MORAN,
Defendant.
TillS AGREEMENT, made this
No. 00-5412 Civil Term
IN DIVORCE
MARITAL SETTLEMENT AGREEMENT
J-C\
II day of
LfUftt-
, 2001, by and between
MARY M, MORAN of Mechanicsburg, Pennsylvania, (hereinafter "WIFE") and PATRICK T.
MORAN of Mechanicsburg, Pennsylvania, (hereinafter "HUSBAND");
WITNESSETH:
WHEREAS, the parties hereto were married on August 16, 1969, in Kenosha,
Wisconsin; and
WHEREAS, a divorce action was filed by WIFE on or about August 3, 2000, in the
Cumberland County Court of Common Pleas at 00-5412 Civil Term; and
WHEREAS, difficulties have arisen between the parties and it is therefore their intention
to live separate and apart for the rest of their lives and the parties are desirous of settling
completely the economic and other rights and obligations between each other, including but not
limited to: the equitable distribution of the marital property; past, present, and future support;
alimony, alimony pendente lite, and in general, any and all other claims and possible claims by
one against the other or against their respective estates; and
NOW THEREFORE, in consideration ofthe covenants and promises hereinafter to be
kept and performed by each party and for other good and valuable consideration, the parties,
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intending to be legally bound hereby, the parties do h\:reby agreellS follows:
1. ADVICE OF COUNSEL.
The provisions ohhis agreement and their legal effect have been fully explained
to the parties by their respective counsel. WIFE is represented by Melissa Peel Greevy, Esquire.
HUSBAND is represented by Jeanne' B, Costopoulos, Esquire.
The parties further declare that each is executing the Agreement freely and
voluntarily having either obtained sufficient knowledge and disclosure of their respective legal
rights and obligations or, if counsel has not been consulted, expressly waiving the right to obtain
such knowledge, The parties each acknowledge that this Agreement is fair and equitable and is
not the result of any fraud, coercion, duress, undue influence or collusion.
2, DIVORCE ACTION.
The parties acknowledge that their marriage is irretrievably broken and that they
shall secure a mutual consent no fault divorce pursuant to g3301 (c) of the Divorce Code. The
parties agree to execute Affidavits of Consent for divorce and Waiver of Notice ofIntention to
Request Entry of a Divorce Decree concurrently with the execution of this Agreement.
This Agreement shall remain in full force and effect after such time as a final
decree in divorce may be entered with respect to the parties. The parties agree that the terms of
this agreement shall be incorporated into any Divorce Decree which may be entered with respect
to them and specifically referenced in the Divorce Decree, This Agreement shall not merge with
the divorce decree, but shall continue to have independent contractual significance,
3. DATE OF EXECUTION.
The "date of execution" or "execution date" of this Agreement shall be defined as
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the date upon which it is executed by the parties if they have each executed the Agreement on the
same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be
defined as the date of execution by the last party executing this Agreement.
4. MUTUAL RELEASES.
Each party absolutely and unconditionally releases the other and the estate of the
other from any and all rights and obligations which either may have for past, present, or future
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obligations, arising out of the marital relationship or otherwise, including all rights and benefits
under the Pennsylvania Divorce Code of 1980, and amendments excepts as described herein.
Each party absolutely and unconditionally releases the other and his or her heirs,
executors and estate from any claims arising by virtue of the marital relationship of the parties.
The above release shall be effective whether such claims arise by way of widow' s or widower's
rights, family exemption, or under the intestate laws, or the right to take against the spouse's will,
or the right to treat a life time conveyance by the other as testamentary, or all other rights of a
surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of
Pennsylvania, any state, Commonwealth, or territory of the United States or any other country.
Except for any cause of action for divorce which either party may have or claim to have,
each party gives to the other by the execution of this Agreement an absolute and unconditional
release from all claims whatsoever, in law or in equity which either party now has against the
other.
5. FINANCIAL DISCLOSURE.
The parties represent and warrant that the disclosures each have made are truthful,
accurate and complete. The parties confirm that each has relied on the accuracy of the financial
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disclosure of the other as an inducement to the execution ofthis Agreement. Each party
understands that he/she had the right to obtain from the other party a complete inventory or list of
all property that either or both parties owned at the time of separation or currently and that each
party had the right to have all such property valued by means of appraisals or otherwise. Both
parties understand that they have a right to have a court hold hearings and make decisions on the
matters covered by this Agreement. Both parties hereby acknowledge that this Agreement is fair
and equitable, and the terms adequately provide for his or her interests, and that this Agreement
is not the result of fraud, duress, or undue influence exercised by either party upon the other or by
any person or persons upon either party.
6. SEPARATION-INTERFERENCE.
WIFE and HUSBAND may and shall, at all times hereafter, live separate and
apart. They shall be free from any interference, direct or indirect, by the other in all respects as if
fully as if they were unmarried, Each may, for his or her separate use or benefit, conduct carry on
and engage in any business, occupation, profession or employment which to him or her may
seem advisable. WIFE and HUSBAND shall not harass, disturb or malign each other or the
respective families of each other.
7. REAL PROPERTY.
The parties are joint owners of real property located at 73 White Oak Boulevard,
Mechanicsburg, Cumberland County, Pennsylvania HUSBAND shall convey via a deed, drafted
by his counsel and executed contemporaneously with.this Agreement, all of his right title and
interest in said property to WIFE free of all encumbraIlces. The parties agree that this transfer of
the Deed by HUSBAND shall be in partial satisfaction of WIFE'S equitable distribution in the
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marital estate, The parties further stipulate and agree that the value of this property is $194,000.
HUSBAND agrees to execute any and all documents to effect the transfer of his interest in said
property pursuant to this paragraph.
8. DEBTS.
HUSBAND represents and warrants to WIFE that since the filing of the Divorce he has
not and in the future will not, contract or incur any debt or liability for which WIFE or her estate
might be responsible, and he shall indemnify and save WIFE harmless from any and all claims
and demands made against her by reason of such debts or obligations incurred by him since the
date of said filing, except as otherwise set forth herein.
WIFE represents and warrants to HUSBAND that since the filing of the Divorce she has
not and in the future will not, contract or incur any debt or liability for which HUSBAND or his
estate might be responsible, and she shall indemnify and save HUSBAND harmless from any and
all claims and demands made against him by reason of such debts or obligations incurred by her
since the date of said filing, except as otherwise set forth herein.
The parties hereby agree to return any and all credit cards in their possession which bear
the name of the other. The parties agree that any debts incurred on said credit cards following
August 3, 2000 shall be the sole and exclusive responsibility of the party incurring the expense
and shall save harmless the other from any obligations or institution of suit thereunder.
9. RETIREMENT BENEFITS AND INVESTMENTS.
(a) HUSBAND and WIFE stipulate and agree that WIFE shall receive the following
assets of pension, retirement, saving and investment v~hicles, all of which are marital in nature,
SB Power Tool Company Savings Plan
$ 11461.81 as of March 30, 2000
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PNC Roth IRA 61532935
PNC Roth IRA 61532848
North Shore IRA 016-5030305
$ 4287.66 as ofJune 30, 2000
$3709.65 as ofJune 30,2000
$23,883.05 as of October 13, 2000
(b) HUSBAND and WIFE stipulate and agree that HUSBAND shall receive the
following assets of pension, retirement, saving and investment vehicles, all of which are marital
in nature.
MSDW IRA 508-114870
PNC Roth IRA 61534124
Stackpole 401 (K)
PNC Roth IRA 6153421 I
$6775.97 as of September 29, 2000
$31, 408.12 as of September 30, 2000
$21,214.00 as of September 20, 2000
$9481.12 as of September 30, 2000
(e) HUSBAND represents that the Morgan Stanley Dean Witter Online account had a
balance of$357,109.40 as of October 2,2000. HUSBAND agrees to convey to WIFE the amount
of $70,000 from his Morgan Stanley Dean Witter Online IRA Account to her PNC IRA account
number 5738-2793. WIFE specifically acknowledges that she is entering this equitable
distribution against the specific advice of her attorney.
10. ANNUITY.
HUSBAND is the annuitant of a Prudential Group Annuity Contract GA-8988, which is
marital property. HUSBAND and WIFE agree that the annuity benefit shall be divided via a
Qualified Domestic Relations Order which shall specifY that the monthly benefit shall be paid
50% to HUSBAND and 50% to WIFE, to be effective November 1, 2011. HUSBAND shall bear
the expense of the preparation of the Qualified Domestic Relations Order.
11. LlOUID MARITAL ASSETS.
The parties were joint owners of a checking account which the parties previously divided
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equally with shall each having received $800.00 which represents one half of the balance.
HUSBAND and WIFE each retained their individual checking accounts with each having
retained $1000.00 in marital funds.
12. INCOME TAX RETURNS.
The parties have heretofore filed certain joint income tax returns and the HUSBAND
represents and warrants to the WIFE that he has heretofore duly paid, or, in the case of the 2000
return, will pay all income taxes due on such returns; that he does not owe any interest or
penalties with respect thereto; that no tax deficiency is pending or threatened against him; and
that no audit is pending with respect to any such return.
13. AUTOMOBILES.
WIFE will retain the 2001 PT Cruiser, which is sole and separate property.
HUSBAND will receive the 2000 300m Chrysler, which is marital property. WIFE agrees to
transfer all of WIFE'S right, title and interest in and to that 300m Chrysler to HUSBAND,
subject to the outstanding chattel mortgage which HUSBAND has agreed to assume and pay, The
parties agree to maintain their vehicles and shall be solely responsible for all payments,
maintenance, insurance and other costs or fees related to their respective vehicles, Each party
agrees to indemnify and hold the other harmless for any and all liability related to their respective
vehicles, and to execute any and all necessary documents to effect the transfer of the title of each
vehicle as agreed above.
14. HOUSEHOLD GOODS AND PERSONAL PROPERTY.
The parties agree that they have distributed and are currently in possession of the
household goods and personal property which has been divided between them in a satisfactory
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and equitable manner. HUSBAND has provided a list household goods and personal property in
his possession, which he will retain as provided in the attached list.
15. ALIMONY.
The HUSBAND will pay to the WIFE, as nonmodifiable alimony, the snm of
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$1300 (one thousand three hundred dollars) each and every month, beginning with the month
following the date of this Agreement, payable by wage attachment, biweekly to terminate
Octo.l2.er 31, 2011, The alimony payments due from HUSBAND to WIFE shall terminate only
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upon the death of either party, WIFE'S cohabitation or remarriage. In addition, HUSBAND will
pay to WIFE 33% of the gross amount of any bonus received through his employment, due and
payable at the time that they are paid, HUSBAND agrees, as security for said payments to
maintain life insurance, insuring the life of HUSBAND with WIFE as full beneficiary in the
amount of $1 00,000 until HUSBAND'S age 65 or until the satisfaction of all payments due
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under Paragraph 15, which ever event is last.
For purposes of this Agreement, "cohabitation" is defmed as financial, social and sexual
interdependence where the WIFE and the person with whom she is living actually reside together
in the manner of spouses, assuming the rights and duties generally associated with a marriage
relationship. This definition is derived from Miller v, Miller, 352 Pa. Super, 432, 508 A. 2d 550
(1986), and shall be controlling on the parties regardless of changes in the statutory or case law
of Pennsylvania.
16, TAX CONSEOUENCES. It is the intention of the parties that timely payments
made under the terms of Paragraph 15 of this Agreement be treated as taxable income to WIFE,
and deductible to HUSBAND. The payments by the HUSBAND to the WIFE under Paragraph
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15 of this Agreement shall be treated as alimony for.taxpurposes only if made during the year
when due, Payments made in advance or in arrears shall not be taxable to WIFE or deductible to
HUSBAND. The parties agree that they shall file, in each year, tax returns which are consistent
with the terms of this Agreement.
17. COOPERATION.
WIFE and HUSBAND shall mutually cooperate with each other in order to carry through
the terms of the Agreement, including but not limited to the signing of doclUUents.
Contemporaneously with the execution of this Agreement, the parties will promptly sign
Affidavits of Consent, Affidavits Waiving Marriage Counseling, and Waivers of Notice oflntent
to Request Entry of A Divorce Decree, and all necessary doclUUents to effectuate the transfer of
the assets as described in this Agreement.
18. BANKRUPTCY OR REORGANIZATION PROCEEDINGS.
In the event that either party becomes a debtor in any bankruptcy or financial
reorganization proceedings of any kind while any obligations remain to be performed by that
party for the benefit of the other party pursuant to the provisions of this Agreement, the debtor
spouse hereby waives, releases and relinquishes any right to claim any exemption (whether
granted under Federal or State law) to any property remaining in the debtor as a defense to any
claim made pursuant hereto by the creditor-spouse as set forth herein, including all attorney fees
and costs incurred in the enforcement of this paragraph or any other provisions of this
Agreement. No obligation created by this Agreement shall be discharged or dischargeable,
regardless of Federal or State law to the contrary, and each party waives any and all right to asset
that obligation hereunder is discharged or dischargeable.
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The parties mutually agree that in the event of bankruptcy or financial reorganization
proceedings by either party in the future, any monies to be paid to the other party, or to a third
party, pursuant to the terms of this Agreement shall constitute support and maintenance and shall
not be discharged in bankruptcy.
19. ATTORNEY FEES. COURT COSTS.
Each party hereby agrees to be solely responsible for his or her own counsel fees, costs
and expenses. Neither shall seek contribution thereto from the other party except as otherwise
expressly provided herein.
20. ATTORNEYS' FEES FOR ENFORCEMENT.
In the event that either party breaches any provisions of this Agreement and the other
party retains counsel to assist in enforcing the terms thereof, the breaching party will pay all
reasonable attorneys' fees, court costs and expenses (including interest and travel costs, if
applicable) which are incurred by the other party in enforcing the Agreement, whether
enforcement is ultimately achieved by litigation or by amicable resolution. It is the specific
Agreement and intent of the parties that a breaching or wrongdoing party shall bear the obligation
of any and all costs, expenses and reasonable counsel fees incurred by the nonbreaching party in
protecting and enforcing his or her rights under this Agreement.
21. WAIVER OF RIGHTS.
Both parties hereby waive the following procedural rights:
(a) The right to obtain an inventory and the appraisement of all marital and
non-marital property;
(b) The right to obtain and income and expense statement of either party;
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(c) The right to have all property identified and appraised;
(d) The right to discovery as provided by the Pennsylvania Ru1es of Civil
Procedure;
(e) The right to have the court make all determinations regarding marital and
non-marital property, equitable distribution, spousal support; alimony pendente lite, alimony,
counsel fees and costs and expenses.
22. VOID CLAUSES.
If any term, condition, clause or provision of this Agreement, shall be determined or
declared to be void or invalid in law or otherwise, then only that term, condition, clause or
provision shall be stricken from this Agreement, and in all other respects this Agreement shall be
valid and continue in full force, effect and operation.
23. APPLICABLE LAW.
This Agreement shall be construed under the laws of the Commonwealth of
Pennsylvania.
24, ENTIRE AGREEMENT.
This Agreement contains the entire understanding of the parties, and there are no
representations, warranties, covenants or undertakings other than those expressly set for herein.
25. CONTRACT INTERPRETATION.
For purposes of contact interpretation and for the purpose of resolving any ambiguity
herein, the parties agree that this Agreement was prepared jointly by the parties.
IN WITNESS WHEREOF, the parties hereto, have set their hands and seals of the day
first written above,
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This Agreement is executed in duplicate and in counterparts. WIFE and HUSBAND
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Witness
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Patrick T, Moran
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COMMONWEALTH OF PENNSYLVANIA
:ss.
COUNTY OF CUMBERLAND
On the No It..-day of 2001, before me, a Notary Public in and for the
Commonwealth of Pennsylvania, the dersigned officer, personally appeared Mary M. Moran,
known to me ( or satisfactorily prov to be one of the parties executing the foregoing
instrument, and she acknowledges the foregoing instrument to be her free act and deed.
IN WITNESS WHEREOF, I have hereunto set my hand an notarial seal the day and year
first above written.
COMMONWEALTH OF PENNSYLVANIA
());~~amt
Notary Public
My Co .
NOT RIALSEAL
HEIDI L. KASTEL, Notary Public
East Pennsboro Twp" Cumberland Co,
My Commission Expires June 9, 2003
COUNTY O~ PTf'):l<\.
. On the II~ day of ~ rV~ ,2001, before me, a Notary Public in and for the
Commonwealth of Pennsylvania, the undersigned officer, personally appeared Patrick T.
Moran, known to me ( or satisfactorily proven) to be one of the parties executing the foregoing
instrument, and he acknowledges the foregoing instrument to be his free act and deed.
:ss.
IN WITNESS WHEREOF, I have hereunto set my hand an notarial seal the day and year
first above written.
~~~~( ,~-v
Notary Public
My Commission Expires:
Notarial Seal
Sharon L. Relslnger, Notary Publlo
Harrisburg, Dauphin County
My Commlssloil Expires Jan. 19, 2004
em r, "nsy "IS SSOCia ar 9S
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MARY M. MORAN,
Plaintiff,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYL V ANlA
v.
CIVIL ACTION - LAW
PATRICK T. MORAN,
Defendant,
No. 00-5412 Civil Term
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Kindly transmit the record, together with the following information, to the court for entry of
a divorce decree:
1. Ground for divorce: irretrievable breakdown under S 3301(4) of the Divorce Code
2. Date and manner of service of the Complaint: August 12, 2000 via United States mail,
postage prepaid and United States mail Certified Mail, Delivery Restricted to Addressee only.
3.
(a) Date of execution of the affidavit of consent required by S 3301(c) of the
Divorce Code: by Plaintiff May 16, 2001,
(b) Date of execution of the affidavit of consent required by S 3301(c) of the
Divorce Code: by Defendant June 11,2001.
4. Related claims pending: none. The Marital Settlement Agreement dated June 11,
200 1 and filed with the court resolved all claims.
5.
(a) Date plaintiffs Waiver of Notice in S 3301(c) Divorce was filed with the
Prothonotary: June 14, 2001.
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(b) Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the
Prothonotary: June 14, 2001.
6.
(a)
Defendant's social security number is: 391-42-4250.
(b) Plaintiffs social security number is: 391-44-1836.
Respectfully submitted,
Date:
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LD, No. 77950
214 Senate Avenue Suite 105
Camp Hill, PA 17011-2336
(717) 763-8995
Attorney for the Plaintiff
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MARY M. MORAN,
Plaintiff,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
PATRICK T. MORAN,
Defendant.
CIVIL ACTION -LAW C' . L~
00- ~I..fl~ tut l~
No. Civil 2000
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims set forth in the
foregoing pages, you must take prompt action. You are warned that if you fail to do so, the case
may proceed without you and a decree in divorce or annulment may be entered against you by the
court, A judgment may also be entered against you for any other claim or relief requested in
these papers by the plaintiff. You may lose money or other 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:
Office of the Prothonotary
Cumberland County Court House
Carlisle, Pennsylvania 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone: (717) 249-3166
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MARY M. MORAN,
Plaintiff,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
CIVIL ACTION - LAW
PATRICK T. MORAN,
Defendant,
No,{J().S'1J.v Civil 2000
IN DIVORCE
NOTICE OF A V AlLABILlTY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed in
the Court of Common Pleas of Cumberland County. This notice is to advise you that in
accordance with Section 3302(d) of the Divorce Code, you may request that the court require you
and your spouse to attend marriage counseling prior to a divorce being handed down by the court.
A list of professional marriage counselors is available at the Domestic Relations Office, 13 North
Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to
you and you are not bound to choose a counselor from this list. All necessary arrangements and
the cost of counseling sessions are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling within
twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver
of your right to request counseling.
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MARY M. MORAN,
Plaintiff,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
PATRICK T. MORAN,
Defendant,
CML ACTION - LAW
S'II ;v
No.p(}o Civil 2000
IN DIVORCE
COMPLAINT IN DIVORCE UNDER ~ 3301 (c) or ~ 3301(d) OF THE DIVORCE CODE
Plaintiff, by and through her attorney, Melissa Peel Greevy, respectfully represents:
1. Plaintiff is Mary M. Moran, who currently resides at 73 White Oak Boulevard,
Mechanicsburg, Cumberland County, Pennsylvania, since December 7,1997,
2, Plaintiff's Social Security Number is 391-44-1836,
3. Defendant is Patrick T. Moran, who currently resides at 73 White Oak Boulevard,
Mechanicsburg, Cumberland County, Pennsylvania, since December 7,1997,
4. Defendant's Social Security Number is 391-42-4250.
5. Plaintiff and Defendant have both been bona fide residents of the Commonwealth
of Pennsylvania for a period of more than six months immediately preceding the filing of this
complaint,
6
The parties were married on August 16, 1969 in Kenosha, Wisconsin.
7.
There are no minor children of the marriage.
8.
Neither Plaintiff nor Defendant is in the military or naval service of the United
States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the
Congress of 1940 and its amendments.
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9. There have been no prior actions of divorce or armulment between the parties.
10. The marriage is irretrievably broken.
11. Plaintiff has been advised that counseling is available and the Plaintiff may have
the right to request the court require the parties to participate in counseling.
12. Plaintiff requests the court to enter a decree of divorce,
13. The parties may enter into a written agreement with regard to economic issues, In
the event that such an agreement is executed by the parties, the agreement may be incorporated
by the Court into the final Decree of Divorce.
WHEREFORE, Plaintiff requests that your Honorable Court to enter a Decree in Divorce,
divorcing Plaintiff and Defendant.
COUNT II
14. Paragraphs I through 13 of the Complaint are incorporated herein by reference as
though set forth at length.
15, Plaintiff avers that she is the innocent and injured spouse, and that Defendant has
offered such indignities to the Plaintiff so as to render her condition intolerable and life
burdensome.
16. This action is not collusive,
WHEREFORE, Plaintiff requests that your Honorable Court to enter a Decree in Divorce,
divorcing Plaintiff and Defendant.
COUNT III
EQUITABLE DISTRIBUTION
17. Paragraphs 1 through 16 of this Complaint are incorporated herein by reference as
though set forth at length.
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18,
Plaintiff and Defendant have acquired property, both real and personal, during
their marriage.
WHEREFORE, Plaintiff requests that your Honorable Court to equitably divide all
marital property,
COUNT IV
ALIMONY
19. Paragraphs 1 through 18 of this Complaint are incorporated by reference as if set
forth at length.
20. Plaintiff is employed as a part time sales clerk at Kohl's Department Store earning
approximately $6000 per year,
21. Defendant is employed at Stackpole Books earning a gross income in excess of
$80,000 per year,
22, Plaintiff has insufficient income and assets to provide for her reasonable needs
during the course ofthis litigation,
23. Plaintiff requires reasonable support to adequately maintain herself in accordance
with the standard ofliving established during the marriage.
WHEREFORE, Plaintiff requests that Your Honorable Court enter an order of alimony.
COUNT V
ALIMONY PENDENTE LITE/COUNSEL FEES AND EXPENSES
UNDER ~ 3702 OF THE DIVORCE CODE
24. Paragraphs I through 23 of this Complaint are incorporated by reference as if set
forth at length.
25. Plaintiff does not have sufficient funds to support herself and pay counsel fees and
expenses incidental to this action,
.
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26. Defendant is full and well able to pay Plaintiff counsel fees and expenses
incidental to this divorce action,
WHEREFORE, Plaintiff requests that Your Honorable Court enter an order for alimony pendente
lite, counsel fees, costs and expenses,
Plaintiff verifies that the statements made in this Complaint are true and correct. Plaintiff
understands that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat.
S 4904, relating to unsworn falsification to authorities.
Date: 1....J / . (j()
~l~ntiff
Date: 1.;j 1- a cJ
'-~~~~ w-
Me Issa Peel Greevy, EsqUlre
LD. No. 77950
214 Senate Avenue Suite 105
Camp Hill, PA 17011-2336
(717) 763-8995
Counsel for Plaintiff
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MARY M. MORAN,
Plaintiff,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
CIVIL ACTION - LAW
P ATRlCK T. MORAN,
Defendant.
No. 00-5412 Civil 2000
IN DIVORCE
RETURN OF SERVICE
United States Mail
The undersigned makes the following return of service:
The Complaint was mailed to Patrick T. Moran on August 9, 2000 at 214 Senate Avenue
Camp Hill, P A 17011.
The signed receipt, indicating service was made on August 12, 2000, is attached.
SIGNATURE AND AFFIDAVIT
I, Melissa Peel Greevy, Esquire, certify that I am a competent adult not a party to the
action.
I verify that the statements made in this affidavit and return of service are true and
correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S.
'4904 rel""'g'9 =-~..., ~Ui.~ /2, ~
Date: C;' - ~ ~\
-I - c2 Of) 7J Melissa Peel Greevy, Esquire
Supreme Court I .D. 77950
214 Senate Avenue Suite 105
Camp Hill, PA 17011-2336
(717) 763-8995
Counsel for Plaintiff
.
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,
MARY M. MORAN,
Plaintiff,
v.
PATRICK T. MORAN,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
No. 00-5412 Civil 2000
IN DIVORCE
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f . Complete Items 1 and/or 2 iar additional services.
U) . CQmplete items 3, 4a, and 4b.
m . Print your name and address on the reverse of this form so that w:a.can return this
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~,_ . Attac~ this form to the front of the mailpiece, or on the back jf space does not
: permIt.
, . . Write MRetum Re~ipt. Requested" on the mal!piece below the article number.
.G: . The Return Receipt will show to whom the article was delivered and the date
~ delivered.
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MARY M. MORAN,
Plaintiff,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
CIVIL ACTION - LAW
PATRICK T. MORAN,
Defendant.
No. 00-5412 Civil Term
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on
August 3, 2000.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3, I consent to the entry of a final decree of divorce after service of intention to request
entry ofthe decree.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa,C.S. S 4904 relating to unsworn
falsification to authorities.
O~T~
Date: ~ /1. ;u,oJ
Patrick T. Moran
Defendant
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Plaintiff,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
CIVIL ACTION - LAW
PATRICK T. MORAN,
Defendant.
No, 00-5412 Civil Term
IN DIVORCE
W AlYER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if 1 do not claim them before a divorce is granted,
3. I understand that I will not be divorced until a divorce decree is entered by the Court
and that a copy of the decree will be sent to me immediately after it is filed by the prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa, C. S, S 4904 relating to
unsworn falsification to authorities,
Q~7/H_L
Patrick T. Moran
Defendant
Date: I)~ /~ 2-00)
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Plaintiff,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYL V ANlA
v.
CIVIL ACTION - LAW
PATRICK T. MORAN,
Defendant.
No, 00-5412 Civil Term
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under Section 3301(c) ofthe Divorce Code was filed on
August 3, 2000.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3, I consent to the entry of a final decree of divorce after service of intention to request
entry ofthe decree.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn
falsification to authorities.
Date: ..j-/t-jj
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Plaintiff,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
CIVIL ACTION - LAW
PATRICK T. MORAN,
Defendant.
No. 00-5412 Civil Term
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE
1. 1 consent to the entry of a fmal decree of divorce without notice.
2. 1 understand that 1 may lose rights concerning alimony, division of property, lawyer's
fees or expenses in do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court
and that a copy ofthe decree will be sent to me immediately after it is filed by the prothonotary.
I verifY that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C. S, S 4904 relating to
unsworn falsification to authorities.
Date: 5-/(prtJJ
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State Commonwealth of Pennsvlvania
Co.lCity/Dist. of CUMBERLAND
Date of Order/Notice 08/14/01
Court/Case Number (See Addendum for case summary)
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
lJiZ, CrY -5'(//,;1- {l/0L.
;J;J(!.!:[C; 09 ;}j () -3 & 7 ~
))1<- sot? (
o Original Order/Notice
o Amended Order/Notice
o Terminate Order/Notice
) RE: MORAN, PATRICK T.
) Employee/Obligor's Name (Last, First, MI)
) 391-42-4250
) Employee/Obligor's Social Security Number
) 9839100817
) Employee/Obligor's Case Identifier
) (See Addendum for plaintiff names associated with cases on attachment)
) Custodial Parent's Name (Last, First, MI)
)
EmployerlWithholder's Federal EIN Number
STACKPOLE BOOKS INC
EmployerlWithholder's Name
C/O KATHY BACHIK
EmployerlWithholder's Address
5067 RITTER RD
MECHANICSBURG PA 17055-6921
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER /NFORMA T/ON: 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.
$ 1,300.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes @ no
$ 0.00 per month in medical support
$ 0.00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 1,300 . 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:
$ 300.00 per weekly pay period.
$ 600.00 per biweekly pay period (every two weeks).
$ 650 00 per semimonthly pay period (twice a month),
$ 1,300.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
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 pg. 2),
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER JD (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT Sf NO CASH BY MAIL.
BY THE COURT:
Date of Order: AUG 1 Ii ?IIOl
E)JttY!/(!> c -
"'"v '13
Form EN-028
Worker 10 $IATT
ServiceType M ~
f1
OMBNo.:0970-0154
Expiration Date: 12/31/00
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If checked you are required to provide a copy of this form to your employee,
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect 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.* R;~I-"_'ltil,g tilt::; Paydate/Date of\\'::tl.l.oldihg. You !lItiS! lepvll tIle payJate/dah::: vi vvitLLvlJihg vv I 11:;1 I sehdill5 tile 1'8.1111(.111. TLc:
tJaydateldatt of vvillllr61dihg is tile dati:., vII vvl.i....L a.IIIQUllt vMS vvitl,l,dd h01l1 lIle eh1t-'lvyee's vva[!/..S. 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,
WITHHOLDER'S ID: 2317025790
EMPLOYEE'S/OBLlGOR'S NAME: MORAN , PATRICK T.
EMPLOYEE'S CASE IDENTIFIER: 9839100817 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. Ahti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from
employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding.
Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is
employed governs,
9.' Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U's,c. 91673 (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.
10,
'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
Requesting Agency:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contad WAGE ATTACHMENT UNIT
by telephone at (717) 240.6225 or
by FAX at (717) 240-6248 or
by Internet @
Page 2 of 2
Form EN-028
Worker 10 $IATT
Service Type M
OMB No.: 0970-0154
Expiration Date: 12/31/00
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PACSES Case Number
Plaintiff Name
MARY M. MORAN
Docket Attachment Amount
00::s4'i2 CIVIL$ 1,300.00
Child(ren)'s Name(s):
Defendant/Obligor:
09210367~~t1(71
ADDENDUM
Summary of Cases on Attachment
MORAN, PATRICK T.
PACSES Case Number
Plaintiff Name
DOB
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.
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
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
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.
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
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0,00
Child(ren)'s Name(s):
DOB
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
bl~~~~~~~d,;~~:;~;~~~ir~~~;~~;~II;~~~hild(r:~). ,.' ,',.. .'.. ....,,'
identified above in any health insurance coverage available
through the employee's/obligor's employment.
· dlf~~~~~:d:;~u~r~;:~~ired;~~~;ollt~~:~il~(ren) > ::(",
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Addendum
Form EN-028
Worker ID $IATT
SelVice Type M
OMB No.: 097Q-0154
Expiration Date: 12/31/00
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MARYM MORAN,
plaintiff
: THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: No, 00-5412
PATRICK T. MORAN,
Defendant
: CIVIL ACTION - AT LAW
: DNORCE
q.lT A T .nmm DOMESTIC' RET.A TIONS OR'Q)tR
IT IS HEREBY ORDERED AS FOLLOWS:
1. Pursuant to Section 414(p) of the Internal Revenue Code, as added by Public Law
98-397 (Retirement Equity Act of 1984) an amount equal to fifty percent (50%) of the value of
Defendant Patrick T. Moran's accrued vested interest in the Western Pension Plan for Salaried
Employees (the "Plan") as of November 1, 2011, shall be assigned to Plaintiff Mary M, Moran.
Name and Address of Participant:
Patrick T. Moran
301 Chestnut Street
Apt, #1714
Harrisburg, P A 17101
Date of Birth:
October 22, 1946
Social Security Number:
391-42-4250
Name and Address of Alternate Payee:
Mary M. Moran
73 White Oak Blvd,
Mechanicsburg, P A 17055
Date of Birth:
April 12, 1948
Social Security Number:
391-44-1836
The Participant and Alternate Payee have been married for more than one year,
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Percentage of Participant's
Accrued Vested Benefit
To Alternate Payee:
An amount equal to fifty percent (50%)
of the Defendant Patrick T. Moran's
accrued vested interest in the Western
Pension Plan for Salaried Employees.
Period of Payments Pursuant:
Lifetime ofthe alternate Payee, to
commence on December 1, 2011 as per
the agreement of the parties.
Earliest Retirement Age:
55 years of age.
Description of Plan to Which Order
Will Apply:
Western Pension Plan for Salaried
Employees
The judgment of the court incorporating this section shall constitute a Qualified Domestic
Relations Order (the "Order") within the meaning of Section 401 (a)(13) and 414(p) of the
Internal Revenue Code,
2, rOVF,NFNTS
a, This Order does not require the Plan to provide any type or form of
benefits, or any option, not otherwise provided under the Plan, and
b, This Order does not require the Plan to provide increased benefits
(determined on the basis of actuarial value), and
c. This Order does not require the payment of benefits to the Alternate Payee
under another Order previously determined to be a Qualified Domestic Relations Order.
3. DEAffiOF AT,TFRNATE PAYF.E- PROVTSTONFOR DFsmNATTONOF
RENFFWTARY
a. The Participant and Alternate Payee may designate a beneficiary with
respect to their retirement benefits created and assigned herein prior to the benefits being in pay
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status, If not designated, the beneficiaries shall be the estates of Patrick Moran and Mary M.
Moran, respectively. However, once the benefits are in pay status, the parties' entitlement to
payments under the annuity ends upon their deaths.
4, TNTFNT)FD TAX TRFA'TMFNT OF mSTRTRlTTTONS OR P A VMFNTS
a. The Alternate Payee shall include all of the taxable portion of said benefits
if, as and when received in her gross income. For purposes of Sections 72 and 402(a)(9) of the
Code, the Alternate Payee shall be treated as the distributee of any distribution or payment made
to said Alternate Payee under this Order. Said benefits, when paid to the Alternate Payee, shall
not be taxable income to the Participant or a deduction on the Participant's income tax return.
5. MTSrm.T ,A NPOTTS pROVTSTONS
a. The Court retains jurisdiction to amend this Order, but only for the
purposes of establishing or maintaining its qualifications as a Qualified Domestic Relations Order
under the Retirement Equity Act; provided that no such amendment shall require the Plan to
provide any type or form of benefit, or any option, not otherwise provided under the Plan, and
further provided that no such amendment or the right of the Court to amend will invalidate this
Order as "qualified" under the Act.
b. A true! certified copy of this Order shall be served upon the Plan
Administrator forthwith. The Order shall take effect immediately and remain in effect until further
order of the Court.
c. The Court further retains jurisdiction to supervise and enforce the payment
of retirement benefits, as provided herein.
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APPROVED AS TO FORM:
Ie . Costopoulos
Att ey for par:Cir;t
Dated: I 1. !J.
Me . ssa eel Greevy
Attorney fOlf!!5te Payee
Dated: 7 ~
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsylvania
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 10/01/04
Tribunal/Case Number (See Addendum for case summary)
RE: MORAN, PATRICK T.
Employee/Obligor's Name (last, First, MI)
o Original Order/Notice
o Amended Order/Notke
(8) Terminate Order/Notice
Employeri\Vithholder's Federal EIN Number
IJiI. .;1(tJ() -5Y1a- ~1/
jJ~ts. ~90J..1~ ~7S-
391-42-4250
Employee/Obligor's Social Security Number
9839100817
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (last, First MI)
STACKPOLE BOOKS INC
5067 RITTER RD
MECHANICSBURG PA 17055-6921
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.
$ 0.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes @ no
$ 0.00 per month in medical support
$ 0 . 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 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:
$ 0 . 00 per weekly pay period.
$ 0.00 per biweekly pay period (every two weeks).
$ 0.00 per semimonthly pay period (twice a month).
$ 0.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's! obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #10 on pg. 2).
If remitting by EFl/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, PA YMENTS 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.
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Date of Order:
Service Type M
OMB No.: 0970-0154
Form EN.028
Worker ID $IATT
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ADDITIONAL INfORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
D If .;;hecked you are required to provide a copy of this form to your, employee, If your employee works in,a state that is
ditterent from the state that issued this order, a copy must be provided to your employee even If the box IS not checked.
1, We appreciate the voluntary compliance of Federally recognized indian tribes, tribally.owned businesses, and Indian-owned
businesses located on a reseNation that choose to withhold in accordance with this notice.
2. Priotity: 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. Ifthere are Federal tax levies in effect please contact the requesting
agency listed below,
3, 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.
4.' RepOlti"g the f'a,dat<liDate ofWilI,hold;"g, )'0" ,lwst ,""d,t II,,, pa,dal..'date of "itI,l,eoldi"8 "I,." sel,d;"g tl,. pay",,,,!. TI,c
payda:t~/dat-.;;:; of nitlll.oleJihg i~ t1.{. da~ 0.1. nl.;..::!. 31Mh:lht nM nitl.I.'C:lJ flChll lLe elllplOyeof'S YYdge5. 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,
5.' Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee/obligo, and you are unable to hono, 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 #1 0 below)
6. 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 retum a copy of this Order/Notice to the Agency identified below.
WITHHOLDER'S ID: 2317025790
EMPLOYEE'S/OBLlGOR'S NAME:
EMPLOYEE'S CASE IDENTIFIER:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
MORAN, PATRICK T.
9839100817 DATE OF SEPARATION:
7. 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.
8. 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,
9. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment,
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
10,' Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.5.c. ~ 1673 (b)l; or 2) the amounts allowed by the State of the employee's1obligor'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.
11. 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.
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
Worker ID $IATT
Service Type M
OMBNo.:0970-G154
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