HomeMy WebLinkAbout00-06130
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"''''iIi''''''''''''''''''''''''''''''''''''~''''''~
IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
STATE OF
JANICE E. MILLER
VERSUS
ROLAND J. MILLER
AND NOW,
DECREED THAT
PENNA.
No.
00-6130
DECREE IN
DIVORCE
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Janice E. Miller
AND
Roland ,:J. Miller
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
, PLAINTIFF,
, DEFENDANT,
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE:
YET BEEN ENTERED;
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
N/A
The settlement transcript dated September 18, 2003, executed by
the parties is attached hereto and incorporated herein for
enfmrcement purposes only pursuant to Section 3105 of the
Pennsylvania Divorce Code.
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By
ATTEST:
PROTHONOTARY
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JANICE E. MILLER,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 00-6130 CIVIL TERM
ROLAND J. MILLER,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record together with the following information, to the Court for entry
of a divorce decree:
1. Ground for a divorce: irretrievable breakdown under Section 3301 (c) of the
Divorce Code.
2. Date and manner of service of the Complaint: UPS Deliverv - 9/8/00.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by Section 3301 (c) of
the Divorce Code: by the Plaintiff 09/18/03, by the Defendant 09/18/03.
(0) (1) Date of execution of the plaintiffs affidavit required by Section 3301 (d) of
the Divorce Code:
(2) Date of service of the plaintiff's affidavit upon the Defendant:
4. Related claim pending: All claims settled at Conference before Divorce
Master on 9/18/03.
5. Complete either (a) or (b)
(a) Date and manner of service of the notice of intention to file praecipe to
transmit record, a copy of which is attached, if the decree is to be entered under section
3301 (d) of the Divorce Code:
(0) Date Plaintiffs Waiver of Notice in ~ 3301 (c) Divorce was filed with the
Prothonotary 09/18/03 Date Defendant's Waiver of Notice in ~ 3301 (c) was filed with the
Prothonotary 09/18/03.
C~/,;I~
Chanes Rector, Esquire
Attorney for the Plaintiff
Date: 11/11/03
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JANICE E. MILLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Vs.
NO. 00 - 6130 CIVIL
ROLAND J. MILLER,
Defendant
IN DIVORCE
THE MASTER:
Today is September 18, 2003.
This is the date set for a conference between counsel and
the parties. Present in the hearing room are the Plaintiff,
Janice E. Miller, and her counsel Charles Rector, and the
Defendant, Roland J. Miller, and his counsel Sanford A.
Krevsky.
This action was commenced by the filing of a
complaint in divorce on September 7, 2000. The complaint
raised grounds for divorce of irretrievable breakdown of the
marriage and the economic claims of equitable distribution,
alimony, alimony pendente lite, and counsel fees and costs.
The parties have signed affidavits of consent
and waivers of notice of intention to request entry of
divorce decree so that the divorce can be concluded under
Section 3301(c) of the Domestic Relations Code. The
affidavits and waivers will be filed with the Prothonotary
by the Master's office.
After negotiations today, which have
continued from prior conferences between the parties, the
Master has been advised that an agreement has been reached
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with respect to the outstanding economic issues. An
agreement is going to be placed on record in the presence of
the parties. The agreement as placed on the record will be
considered the substantive agreement of the parties not
subject to any changes or modifications except for
correction of typographical errors which may be made during
the transcription. The agreement will be sent around to
counsel and the parties for review to make correction of
typographical errors and then affix their signatures
affirming the terms of settlement as stated on the record.
It is understood that the agreement as stated on the record
will be considered the agreement of the parties when they
leave the hearing room today and will not be subject to any
substantive changes or modifications and will be binding
upon the parties even though they do not subsequently sign
the agreement affirming the terms of settlement.
Upon receipt by the Master of a completed
agreement, the Master will prepare an order vacating his
appointment. The agreement will be sent to counsel, as
indicated, to review for typographical errors and then
counsel will be responsible for obtaining the parties'
signatures and returning the document to the Master so that
the Master can then proceed to vacate his appointment and
allow the parties to file a praecipe transmitting the record
to Court requesting a final decree in divorce. Mr. Rector.
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MR. RECTOR:
1. The parties agree that wife shall receive as her
separate assets the following:
Her 401(k) plan with J.C. penneys;
All escrow proceeds currently held for the benefit of
the parties at Commerce Bank;
Her joint 1st Union account;
Her Harris Bank savings account;
Her Harris Bank checking account;
The proceeds received following the sale of the van.
Husband waives any and all interest he may in the
assets awarded to wife.
2. Husband shall receive as his separate assets the
following:
His Teamsters retirement plan, except that portion to
be segregated for a QDRO for the benefits of wife which will
be outlined below;
His American Express account;
Any monies currently held by him in the New Cumberland
Federal Credit Union.
Wife waives any and all interest she may in the assets
awarded to husband except for the Teamsters retirement plan
which shall be distributed as follows:
The parties agree that wife shall receive as her
portion of said Teamsters plan the sum of $58,091.00 and any
and all appreciation which may accrue on the account in
proportion to the amount to be received by wife. A QDRO
shall be prepared by Harry Leister, FSA, to facilitate this
distribution. Husband shall at his cost supplement any
additional fee required by Harry Leister for the completion
of this QDRO and counsel for the parties shall exchange the
QDRO and communicate that to the funds administrator without
delay. The parties acknowledge that Plaintiff, Janice E.
Miller, has utilized the service of Harry Leister previously
for the preparation of a draft QDRO and has satisfied that
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bill. To the extent that any additional costs are incurred
by Mr. Leister, husband agrees to pay any additional costs
that may be due and owing to Mr. Leister. By way of
clarification, most of the QDRO which has already been
drafted will be complemented by the new amounts negotiated
by the parties. We anticipate that any additional costs
will be nominal.
MR. KREVSKY:
Should the full payment be able to be effected through
another vehicle other than a QDRO such as a rollover to an
IRA then the parties authorize the most expeditious,
efficient way to approach that.
MR. RECTOR:
3. Wife waives her entitlement to alimony as part of this
settlement now and in the future. The parties acknowledge
that there is a current order of alimony pendente lite
docketed at 6130 Civil Term of the Domestic Relations
Office. Wife's receipt of alimony pendente lite shall cease
as a matter of law upon the date of the issuance of the
decree in divorce in this case.
4. Wife likewise waives her counsel fee claim.
5. Except as herein otherwise provided, each party may
dispose of his or her property in any way and each party
hereby waives and relinquishes any and all rights he or she
may now have or hereafter acquire under the present or
future laws of any jurisdiction to share in the property or
the estate of the other as a result of the marital
relationship including without limitation, statutory
allowance, widow's allowance, right of intestacy, right to
take against the will of the other, and right to act as
administrator or executor in the other's estate. Each will
at the request of the other execute, acknowledge, and
deliver any and all instruments which may be necessary or
advisable to carry into effect this mutual waiver and
relinquishment of all such interest, rights, and claims.
MR. RECTOR: Mrs. Miller, you've heard me
recite the negotiated agreement on the record, do you have
any questions about what you've heard?
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MRS. MILLER: No.
MR. RECTOR: Are you in agreement with it?
MRS. MILLER: Yes.
MR. RECTOR: You understand as the Master
pointed out to you that having heard that agreement on the
record today, even if the transcript is not signed we have a
binding contract as we sit her today, do you understand
that?
MRS. MILLER: Yes.
MR. RECTOR: Are you satisfied with my
representation in this case?
MRS. MILLER: Yes.
(A discussion was held off the record.)
MR. KREVSKY: Mr. Miller, you've heard the
summary of the terms of the marital settlement agreement
from Mr. Rector, did you understand everything he said?
MR. MILLER: Yes,
MR. KREVSKY: Did you also understand the
comments that were made by the Master and myself concerning
the agreement?
MR. MILLER: Yes.
MR. KREVSKY: Do you understand also that the
terms of the agreement as outlined this morning will be
binding on you and Janice even if it's not signed right now?
MR. MILLER: Yes.
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MR. KREVSKY: And that subsequently if it is
signed by counsel, that would also bind you?
MR. MILLER: Yes.
MR. KREVSKY: Again, as Mr. Rector has
indicated, have you and I had ample opportunity to review
what you believe are the assets and debts of your estate?
MR. MILLER: Yes.
MR. KREVSKY: Do you believe -- are you
satisfied that your wife either to you or through her
attorney has made full disclosure to you of the assets and
liabilities of the estate?
MR. MILLER: Yes.
MR. KREVSKY: And would you agree not to --
if there was something that was missing, do you agree to be
bound by the terms of the agreement nonetheless?
MR. MILLER: Yes.
MR. KREVSKY: And regarding your satisfaction
or dissatisfaction with my services, are you satisfied with
my services?
MR. MILLER: Yes.
I acknowledge that I have read the above
stipulation and agreement, that I understand the terms of
settlement as set forth herein, and that by signing below I
ratify and affirm the agreement previously made and intend
to bind myself to the settlement as a contract obligating
myself to the terms of settlement and subjecting myself to
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the methods and procedures of enforcement which may be
imposed by law and in particular Section 3105 of the
Domestic Relations Code.
WITNESS:
Charles Rector
Attorney for Plaintiff
Sanford A. Krevsky
Attorney for Defendant
DATE:
Janice E. Miller
Roland J. Miller
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JANICE E. MILLER,
Plaintiff
V.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00- f.:,/J6 eOl'( T~
ROLAND J. MILLER,
Defendant
CIVIL ACTION - LAW
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 following 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 of divorce or annulment may be
entered against you by the court. A judgment may also be entered against you for any
other claim or relief requested in these papers by the Plaintiff. You may lose money or
property of other rights important to you, including the 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 at the Office of the Prothonotary.
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, PA 17013
717-249-3166
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JANICE E. MillER,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. txJ - (,/.30 CU:.1'.'~
ROLAND J. MillER,
Defendant
CIVil ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the Plaintiff, Janice E. Miller, by and through her attorney,
Charles Rector, Esquire, and respectfully represents as follows:
1. Plaintiff is Janice E. Miller (SS # 200-36-8051), an adult individual,
currently residing at 1071-15 Lancaster Blvd., Mechanicsburg, Cumberland County,
Pennsylvania, 17055.
2. Defendant is Roland J. Miller (SS # 181-42-7553), an adult individual,
currently residing at 925 Shetters lane, Camp Hill, Cumberland County, Pennsylvania,
17011.
3. Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for a period of six months (6) immediately preceding
the filing of the Complaint.
4. Plaintiff and Defendant were married on September 30, 1978, in
Mechanicsburg, Cumberland County, Pennsylvania.
5. There have been no prior actions for divorce or for annulment between
the parties.
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6. The Plaintiff and Defendant are both citizens of the United States of
America.
Count I - Divorce
7. The allegations of Paragraphs 1 through 6 are incorporated herein by
reference and made a part hereof.
8. This action is not brought through collusion between the Plaintiff and
Defendant. but in sincerity and truth for the reasons set forth within.
9. The marriage is irretrievably broken, and the parties are proceeding
under Section 3301 (c) of the Divorce Code. In the alternative, Defendant has offered
such indignities to Plaintiff, the innocent and injured spouse, as to render her condition
intolerable and her life burdensome.
10. Plaintiff has been advised that counseling is available and that Plaintiff
may have the right to request that the Court require the parties to participate in
counseling.
WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce decree
dissolving the marriage between Plaintiff and Defendant.
Count II - Eauitable Distribution
11. Paragraphs 1 through 10 of this Complaint are incorporated herein by
reference as if set forth at length.
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12. The parties have acquired, during the course of the marriage and prior to
separation, property, both real and personal, which they own jointly or which was
otherwise purchased so as to constitute marital property within the definition and scope
of Section 3502 of the Divorce Code.
WHEREFORE, Plaintiff requests your Honorable Court to enter an Order
distributing the marital property owned by the parties.
Count III - Spousal SUpDort and/or Alimony
Pendent Lite and Permanent Alimony
13. The allegations in Paragraph 1 through 12 are incorporated herein by
reference and made a part hereof.
14. Plaintiff is unable to sustain herself during the course of this litigation.
15. Plaintiff lacks sufficient property to provide for her reasonable needs and
is unable to sustain herself adequately through appropriate employment.
16. Plaintiff requests this Honorable Court to enter an award of spousal
support and/or alimony pendente lite in her favor pursuant to Section 3701 of the
Divorce Code.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an
award of spousal support and/or alimony pendente lite until final hearing and thereupon
to enter an order of alimony in her favor pursuant to Section 3701 of the Divorce Code.
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Count IV- Counsel Fees. El(penses and Costs of Suit
17. The allegations of Paragraphs 1 through 16 are incorporated herein by
reference and made a part hereof.
18. Plaintiff has retained an attorney to prosecute this action and has agreed
to pay him a reasonable fee.
19. Plaintiff has incurred and will incur costs and expenses in prosecuting this
action.
20. Plaintiff is not financially able to meet the expenses and costs of
prosecuting this action or the fees to which her attorney will be entitled in this case.
21. Plaintiff requests this Honorable Court to enter an award of interim
counsel fees, costs and expenses until final hearing and thereupon such additional
counsel fees, costs and expenses as deemed appropriate.
WHEREFORE, Plaintiff respectfully requests that, pursuant to Sections 3702 of
the Divorce Code, the Court enter an Order directing Defendant to pay Plaintiff's
reasonable counsel fees, costs and expenses.
RESPECTFULLY SUB
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I verify that the statements made herein are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904,
relating to unsworn falsification to authorities.
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J Janice E. Miller
Date: 9/7i!;JOo()
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JANICE E. MillER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 00-6130 CIVil TERM
ROLAND J. MillER,
Defendant
CIVil ACTION - LAW
IN DIVORCE
PROOF OF SERVICE
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JANICE E. MILLER,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00 - 6130 CIVIL
ROLAND J. MILLER,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was
filed on Septernber 7,2000.
2. The rnarriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of the filing of the Complaint.
3. I consent to the entry of the final Decree in Divorce after service of notice
of intention to request entry of the decree.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING
AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE
STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18
PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO
AUTHORTIES.
DA:rU-103
ROLAND J. MILL R
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JANICE E. MILLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00 - 6130 CIVIL
ROLAND J. MILLER,
Defendant
IN DIVORCE
WAIVER OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 33011CI 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 alirnony, division of
property, lawyer's fees or expenses if) do not clairn 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 with the Prothonotary.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING
AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE
STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18
PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO
AUTHORTIES.
~O~
DATE:
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JANICE E. MILLER,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00 - 6130 CIVIL
ROLAND J. MILLER,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was
filed on September 7,2000.
2. The rnarriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of the filing of the Complaint.
3. I consent to the entry of the final Decree in Divorce after service of notice
of intention to request entry of the decree.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING
AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE
STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18
PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO
AUTHORTIES.
9/;?/'D5
DATE:
QwEV/L.L'0-
c/ ANICE E. MILLER
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JANICE E. MILLER,
Plaintiff
VB.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00 - 6130 CIVIL
ROLAND J. MILLER,
Defendant
IN DIVORCE
WAIVER OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301lCI OF THE DIVORCE CODE
1. I consent to the entry of a fmal decree of divorce without notice.
2. I understand that I rnay lose rights conceming alimony, division of
property, lawyer's fees or expenses if I 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 irnmediately after
it is fIled with the Prothonotary.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING
AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE
STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18
PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO
AUTHORTIES.
9hl?/O 3
DATE:
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,/'/ ANICf E. MILLER
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Law Offices
of
Charles Rector, Esquire, P.e.
1104 Femwood Avenue, Ste. 203
Camp Hill, PA 17011-6912
www.charlesrector.com
Tammy S. Faust
Paralegal
(717) 761-8101
Fax (717) 761-2161
November 3, 2003
E. Robert Elicker, II, Esquire
Office of Divorce Master
9 North Hanover Street
Carlisle, PA 17013
Re: Miller v. Miller
No. 00-6130 Civil Term
Dear Mr. Elicker:
Enclosed please find an original and one copy of the parties' fully executed
Settlement Transcript in the above-referenced matter. Once the appointment of the
Divorce Master is vacated, I will finalize the divorce.
Thank you for your assistance in this matter. If you have any questions, please
feel free to contact me.
Very truly yours, .... ...--.,
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Charles Rector
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Enclosures
cc: Jan Miller
Sanford Krevsky, Esquire
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OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240-6535
E. Robert Elicker, II
Divorce Master
Traci do Colyer
Office Manager/Reporter
West Shore
697-0371 Ext. 6535
September 18, 2003
Charles Rector
Attorney at Law
1104 Fernwood Avenue,
Camp Hill, PA 17011
Sanford A. Krevsky
Attorney at Law
Suite 203 KREVSKY & ROSEN
1101 North Front Street
Harrisburg, PA 17102
RE: Janice E. Miller vs. Roland J. Miller
No. 00 - 6130 Civil
In Divorce
Dear Mr. Rector and Mr. Krevsky:
Enclosed is a draft of the agreement which you put on
the record on September 18, 2003. Please review the draft for
any corrections with the understanding that no substantive
changes can be made.
After you have reviewed the draft, give us a call so we
can make appropriate corrections. We will send the corrected
original to the Plaintiff's attorney for signature who then can
transmit the original to the Defendant's attorney for
signature. When I receive a signed copy of the document, I
will then obtain a Court order vacating my appointment.
Thank. you for your continuing cooperation in bringing
this matter to settlement.
Very truly yours,
E. Robert Elicker, II
Divorce Master
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~ JANICE E. MILLER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
vs.
CIVIL ACTION - LAW
00 - 6130
NO. CIVIL
19
ROLAND J. MILLER
IN DIVORCE
Defendant
STATUS SHEET
DATE:
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JANICE E. MILLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00 - 6130 CIVIL
ROLAND J. MILLER,
Defendant
IN DIVORCE
TO: Charles Rector
Attorney for Plaintiff
Sanford A. Krevsky , Attorney for Defendant
DATE: Tuesday, August 26, 2002
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
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(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
DATE
COUNSEL FOR PLAINTIFF
COUNSEL FOR DEFENDANT
NOTE:
PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
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II
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JANICE E. MILLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - LAW
NO. 00 - 6130 CIVIL
ROLAND J. MILLER,
Defendant
IN DIVORCE
CONFERENCE WITH
COUNSEL AND THE PARTIES
TO: Charles Rector
Janice E. Miller
Counsel for Plaintiff
, Plaintiff
Sanford A. Krevsky
Roland J. Miller
, Counsel for Defendant
Defendant
A conference has been scheduled at the Office of
the Divorce Master, 9 North Hanover Street, Carlisle,
Pennsylvania, on the 23rd day of May 2003, at 9:00 a.m.,
with counsel and the parties to discuss the outstanding
economic issues to determine if there is a basis of
settlement of claims. If issues remain after the
conference, a hearing will be scheduled at another date.
Very truly yours,
Date of Notice:
March 31, 2003
E. Robert Elicker, II
Divorce Master
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Law Offices
of
Charles Rector, Esquire, P.C.
1104 Fernwood Avenue, Ste. 203
Carnp Hill, PA 17011-6912
www.charlesrector.com
Tammy S. Faust
Paralegal
(717) 761-8101
Fax (717) 761-2161
July 18, 2003
E. Robert Elicker, II, Esquire
Office of Divorce Master
9 North HanoVer Street
Carlisle, PA 17013
Re: Miller v. Miller
No. 00-6130 Civil Term
Dear Mr. Elicker:
My client has directed that I re-Iist this matter for a Master's Hearing. I request a
second pre-hearing conference with the clients present.
Very truly yours,
Charles Rector
CRltsf
cc: Sanford Krevsky, Esquire
Jan Miller
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JANICE E. MILLER,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL V ANlA
: NO. 00-6130
ROLAND 1. MILLER
Defendant
: CIVIL ACTION LAW - IN DIVORCE
PRE-TRIAL STATEMENT OF DEFENDANT
I. a.. PLAINTIFF'S BACKGROUND
1071-15 Lancaster Boulevard
Mechanicsbnrg, Pennsylvania 17055
Date of Birth: 7/30/54
Occupation:
A. Office Clerk at Penney's
(Note: Wife reports $249.00 per month at this position;
however, her paystub from October 2002 indicates her total
year to date income at approximately $5,000.00, therefore her
monthly pay would be approximately $500.00.
B. Real Estate Agent at Jack Gaughn Realtors.
b. DEFENDANT'S BACKGROUND
17 West Front Street
P.O. Box 3146
Shiremanstown, PAl 70 11
Date of Birth: 3/31/54
Occupation: Truck Driver through Exel Logistics
Due to increased costs of medical benefits, increases in Husband's
salary have been offset.
c. Date of Marriage: October 31, 1978
Date of Separation: July 2000
I
d.
Place of Marriage: Mechanicsburg, Pennsylvania
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e.
Children:
Nickolas Alan Miller:
Carly Jane Miller:
23 years old
l'l years old
f. Grounds for divorce: Marriage is irretrievably broken.
g. Issues to be resolved: Alimony, Alimony Pendente Lite, Equitable
Distribution and Assignment of Property, Support, Counsel fees, Costs and
Expenses.
II. PROCEDURAL HISTORY
9/7/00:
Divorce action commenced.
8/22/02:
Master appointed to resolve all outstanding issues.
III. INVENTORY AND APPRAISAL
.
Forwarded to the Court on November 13, 2002 on behalf of Defendant.
IV. WITNESSES
Lay:
a. Defendant
b. Plaintiff, as on cross
Expert:
Husband reserves the right to identify any expert witness should same
be needed to resolve any remaining dispute as to valuation of marital
assets.
V. EXEffRITS
Exhibits required to establish values will be provided at trial, if needed.
VI. INCOME INFORMATION
Forwarded to the Court on November 13, 2002 for filing; Copies of same
forwarded to opposing counsel and Master on November 13,2002.
"
VII.
EXPENSE INFORMATION
Forwarded to the Court on November 13, 2002 for filing; Copies of same
forwarded to opposing counsel and Master on November 13,2002.
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Vill. PENSION VALUE
Appraisals of both parties pensions have been conducted. Due to the
market changes, the more accurate figure reflects a $5,110.59 decrease in
the pension value.
IX. REAL ESTATE
Escrowed proceeds from the sale ofthe marital home Balance as of
December 31, 2002 was $33,214.38
Mrs. Miller was the realtor that sold the marital home. It is believed that
Mrs. Miller received commission from the sale ofthe home.
X. PERSONALTY
With the exception of the items outlined below, all items of personal
property have already been divided to the parties satisfaction but parties
reserve the right to present testimony regarding the value of furnishings
distributed to each party if necessary:
A. Bank accounts: it is believed that Wife has unreported assets in bank
accounts.
B. American Express Account should reflect a $12,000.00 total as
opposed to $5,086.00.
XI. PROPOSED ECONOMIC RESOLUTION
A. 60% split to Wife, 40% split to Husband relative to general matter
and 50% split to Wife, 50% split to Husband relative to pensions
(Division would include a Qualified Domestic Relations Order
relative to pensions).
B. Alimony payments will cease. *Wife has been receiving $48.00 per
week in Alimony Pendente Lite since September 10, 2000 for a total
amount received of approximately $6,096.00.
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C. Taxes to be filed as follows:
1. 2001 - capital gains, wife claimed both kids (@$700-800)
2. 2002 - husband - head of household ($1200);
3. 2003 and thereafter - file separate.
D. There shall be no alimony or counsel fees awarded to either party.
Respectfully submitted:
Krevsky & Rosen, P.c.
Ire
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JANICE E. MILLER,
Plaintiff
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 00-6130
ROLAND 1. MILLER
Defendant
: CIVIL ACTION LAW - IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this rr day Of~003, I, Susan N. Lenker, for the Law
Firm ofKrevsky & Rosen, P. c., hereby certify that a copy of the foregoing Pretrial Statement
was sent via Hand Delivery on the following:
CHARLES RECTOR, ESQUIRE
1104 FERNWOOD AVENUE
SUITE 203
CAMPHILL,PA 17043-0109
E. ROBERT ELICKER, IT, ESQUIRE
OFFICE OF DIVORCE MASTER
9 NORTH HANOVER STREET
CARLISLE, P A 17013
Susan N. Lenke
11 01 North Front Street
Harrisburg, P A 171 02
(717) 234-4583
J'
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JANICE E. MILLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - LAW
NO. 00 - 6130 CIVIL
ROLAND J. MILLER,
Defendant
IN DIVORCE
CONFERENCE WITH
COUNSEL AND THE PARTIES
TO:
Charles Rector
Janice E. Miller
Counsel for Plaintiff
Plaintiff
Sanford A. Krevsky
Roland J. Miller
, Counsel for Defendant
, Defendant
A conference has been scheduled at the Office of
the Divorce Master, 9 North Hanover Street, Carlisle,
Pennsylvania, on the 18th day of September 2003, at 9:30 a.m.,
with counsel and the parties to discuss the outstanding
economic issues to determine if there is a basis of settlement
of claims. If issues remain after the conference, a hearing
will be scheduled at another date.
Very truly yours,
Date of Notice:
July 24, 2003
E. Robert Elicker, II
Divorce Master
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.
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FROM Charles Rector. Esq.
PHONE NO. 717+761+2161
Jun. 04 2003 02:57PM P1
Law Offices
of
Charles Rector, Esquire, P.C.
1104 Femwood Avenue, Ste. 203
CampHiIl.PA 17011-6912
www.c:harlesrcctor.com
Tammy S. Faust
Paralegal
(717) 761-8101
Fax (717) 761-2161
June 4. 2003
Via fax (717) 240-7890
E. Robert Elicker, II, Esquire
Office of Divor,~ Master
9 North Hanover Street
Carlisle, PA 17013
Re: Miller v. Miller
No. 00-6130 Civil Term
Dear Mr. Elickler:
I confirm by this letter that I have reached comprehensive settlement of all
economic issues in the above-referenced matter with Sanford A. Krevsky. Esquire.
counsel for Mr. Miller, I therefore request that the hearing scheduled for Monday, June
9. 2003, be canceled and that the matter be continued generally, I expect that we will
have a fully executed settlement agreement within the next five (5) days.
I remain,
Very truly yours,
CV-'
Charles Reclor
CRltsf
cc; Sanford A. Kresky, Esquire
Jan Miller
HP LaserJ et 3330
HP LASERJET 3330
Jun-4-2003
14: i3
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Fax Call Report
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n v e n t
Job
Date
Result
134
6/ 4/2003
Time
14: 12:32
Type
Identification
Duration
Receive
717+761+2161
0:41
FROM: Char 1..5 Rector, Es'l,
PHJNEt-U. 717+761+2161
Jun.B4200JI'I2:S7PMPl
Law Offices
.f
Charles Rector, Esquire, P.c.
1I04FernwoodAvenue, Ste, 203
CampHilI,PA 17011-6912
\lIWW,chorl..."".ouom
Tammy S. Faust
Pll1'alegal
(717) 76]-SIOl
Fax (717)761-2161
June 4,2003
Via fax (717/ 240-7890
E. Robert Elicker, II, Esquire
Office of DivoreeMa5ter
9 North Hanover Slreet
Carllste,PA 11013
Re: MlHer v. Miller
No. 00-6130 Civil Term
Dear Mr. EUcker:
I confirm by thl$lelter 1ha\ I have reached comprehensive selUement of all
economic Issues In the above-referenced mallerwllh Sanford A. Krevsky, Esquire,
counsel for Mr. Miner. I therefore requesl that the heerin" scheduled for Monday, Ju.ne
92003 be canceled and tnalthe malter b&conllnued ganerally. leKpectlhatwewIl1
~vea;ullyeKecutedsettlemenlagreementwl(hinIhBnexlfive(5)d3y5,
I remain,
Very truly yours,
e,(i..,L.-.'
Charle5Reclor
CRllsf
cc; SanfordA.Kresky,c$quire
JanMiller
Pages
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JANICE E. MILLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - LAW
NO. 00 - 6130 CIVIL
ROLAND J. MILLER,
Defendant
IN DIVORCE
RESCHEDULED
CONFERENCE WITH
COUNSEL AND THE PARTIES
TO: Charles Rector
Janice E. Miller
Counsel for Plaintiff
, Plaintiff
Sanford A. Krevsky
Roland J. Miller
, Counsel for Defendant
, Defendant
A conference has been scheduled at the Office of
the Divorce Master, 9 North Hanover Street, Carlisle,
Pennsylvania, on the 9th day of June 2003, at 8:30 a.m.,
with counsel and the parties to discuss the outstanding
economic issues to determine if there is a basis of
settlement of claims. If issues remain after the
conference, a hearing will be scheduled at another date.
Very truly yours,
Date of Notice:
May 8, 2003
E. Robert Elicker, II
Divorce Master
101
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COUNSELORS AT LAW
1101 NORTH FRONT STREET
HARRISBURG, PENNSYLVANIA 17102-3324
Sanford A. Krevsky
Lawrence J. Rosen
David J. Schertz
Tel. (717) 234-4583
Fax (717) 234-3650
January 30, 2003
E. ROBERT ELICKER, II, ESQUIRE
OFFICE OF DIVORCE MASTER
9 NORTH HANOVER STREET
CARLISLE, PA 17013
Re: Janice E. Miller v. Roland 1. Miller (No. 00-6130)
'l$bos-1-
Dear M~icker:
As you know, I represent the interest of Roland J. Miller relative to the above-
referenced matter. Enclosed please find a copy of Mr. Miller's Pre-trial Statement
relative to this matter that was forwarded to the Cumberland County Courthouse for the
appropriate filing.
Additionally, this letter is a request that a Master's Hearing be scheduled. If
possible, please contact my office to coordinate the scheduling of a date for the Master's
Hearing to avoid any conflicts with my calendar.
Thank you for your attention and assistance. If you have any questions or require
anything further, please contact my office. I look forward to hearing from you; until
then, I am
Very truly yours,
'---"-.- r~
-
Sanford A. Krevsky
SAK:alr
Enclosure
pc: R. Miller
C. Rector, Esquire
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JANICE E. MILLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - LAW
NO. 00 - 6130 CIVIL
ROLAND J. MILLER,
Defendant
IN DIVORCE
NOTICE OF PRE-HEARING CONFERENCE
TO: Charles Rector
, Attorney for Plaintiff
Sanford A. Krevsky
, Attorney for Defendant
A pre-hearing conference has been scheduled at the
Office of the Divorce Master, 9 North Hanover Street,
carlisle, Pennsylvania, on the 31st day of March 2003, at
9:30 a.m., at which time we will review the pre-trial
statements previously filed by counsel, define issues,
identify witnesses, explore the possibility of settlement
and, if necessary, schedule a hearing.
Very truly yours,
Date of Notice: 2/5/03
E. Robert Elicker, II
Divorce Master
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OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle. PA 17013
(717) 240-6535
E. Robert Elicker, II
Divorce Master
Traci .10 Colyer
Office Manager/Reporter
West Shore
697-0371 Ex!. 6535
October 18, 2002
Charles Rector, Esquire
1104 Femwood Avenue, Suite 203
Camp Hill, PA 17011
Sanford A. Krevsky, Esquire
KREVSKY & ROSEN, P.C.
1101 North Front Street
Harrisburg, PA 17102
RE: Janice E. Miller vs. Roland J. Miller
No. 00 - 6130 Civil
In Divorce
Dear Mr. Rector and Mr. Krevsky:
Mr. Rector has retumed the certification document advising that
discovery is complete. The date of the document was August 30, 2002.
Mr. Krevsky by letter dated September 10, 2002, indicated that certain
matters needed to be completed in order to prepare the case for trial.
Those items were enumerated in his letter.
It is my opinion that adequate time has passed for counsel to have
the case ready for trial and to complete discovery; therefore, I am going to
proceed on the basis that there will be no outstanding discovery issues at
the time of the pre-hearing conference.
A divorce complaint was filed on September 7,2000, raising
grounds for divorce of irretrievable breakdown of the marriage and
indignities. My assumption is that the parties will sign affidavits of
consent. If that is not correct, please advise and I will immediately
schedule a hearing on the grounds of indignities or counsel should file a
3301(d) affidavit. The complaint also raised economic claims of
equitable distribution, alimony, alimony pendente lite and counsel fees
and expenses.
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Mr. Rector and Mr. Krevsky, Attorneys at Law
18 October 2002
Page 2
In accordance with P.R.C.P. 1920.33(b) I am directing each counsel
to file a pretrial statement on or before Friday, November 15, 2002.
Upon receipt of the pretrial statements, I will immediately schedule a
pre-hearing conference with counsel to discuss the issues and, if
necessary, schedule a hearing.
Very truly yours,
E. Robert Elicker, II
Divorce Master
NOTE:
Sanctions for failure to file the pretrial statements are set
forth in subdivision (c) and (d) of Rule 1920.33.
THE ORIGINAL PRETRIAL STATEMENT SHOULD BE FILED
IN THE MASTER'S OFFICE AND A COPY SENT DIRECTLY
TO OPPOSING COUNSEL.
FAILURE TO FILE PRETRIAL STATEMENTS AS DIRECTED
BY THE MASTER MAY RESULT IN THE MASTER'S
APPOINTMENT BEING VACATED.
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JANICE E. MILLER,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-6130 CIVil TERM
CIVIL ACTION - lAW
IN DIVORCE
ROLAND J. MILLER,
Defendant
MOTION FOR APPOINTMENTOF MASTER
Janice E. Miller, Plaintiff, moves the Court to appoint a Master with respect to the
following claims
( X ) Divorce
( ) Annulment
( X ) Alimony
( X ) Alimony Pendente Lite
( X ) Distribution of Property
( X ) Support
( X ) Counsel Fees
( X ) Costs and Expenses
and in support of the motion states:
1. Discovery is complete as to the claims for which the appointment of a
master is requested.
2. The Defendant has appeared in the action by his attorney Sanford A.
Krevsky; Esquire.
3. The statutory ground for divorce is 3301 (c).
4. The action is contested with respect to all the above claims.
5.
The action does\not involve complex issues of law or fact.
6. The hearing is expected to take one day.
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7. There is no additional information relevan
Date: 08/21/02
ORDER APPOINTING MASTER
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AND NOWY'~{J./ ;?.;J-, 2002, i:. ~Y"~-" ~,dtf
Esquire is appointed M ter with respect to the follOWing claims: fJL
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Law Offices
of
Charles Rector, Esquire, P.e.
1104 Fernwood Avenue, Ste. 203
Camp Hill, PA 17011-6912
www.charlesrector.com
Tammy S. Faust
Paralegal
(717) 761-8101
Fax (717) 761-2161
August 30, 2002
E. Robert Elicker, II, Esquire
Office of Divorce Master
9 North Hanover Street
Carlisle, PA 17013
Re: Miller v. Miller
No. 00-6130 Civil Term
Dear Mr. Elicker:
Enclosed please find confirmation that discovery has been completed in the
above-referenced matter.
V:~:)0
Charles Reclr
CRltsf
Enclosure
cc: Sanford Krevsky, Esquire
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JANICE E. MILLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00 - 6130 CIVIL
ROLAND J. MILLER,
Defendant
IN DIVORCE
TO: Charles Rector
Attorney for Plaintiff
Sanford A. Krevsky , Attorney for Defendant
DATE: Tuesday, August ~?, 2002
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
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(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
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COUNSEL F
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NOTE:
PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
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JANICE E. MILLER,
PlaintifflPetitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
ROLAND J. MILLER,
DefendantJRespondent
NO. 00-6130 CIVIL TERM
IN DIVORCE
DR# 29,883
Pacses# 072102644
ORDER OF COURT
AND NOW, this 25th day of September, 2000, upon consideration of the attached Petitiou for
Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective
counsel appear before R.J. Shaddav on October 17. 2000 at 9:00 A.M. for a conference, at 13 N. Hanover
St., Carlisle, P A 17013, after which the conference officer may recommend that an Order for Alimony
Pendente Lite be entered.
YOU are further ordered to bring to the conference:
(1) a true copy of your most recent Federal Income Tax Return, inclnding W-2's as filed
(2) your pay stubs for the preceding six (6) months
(3) the Income and Expense Statement attached to this order, completed as required by Rule
1910.11CQ
(4) verification of child care expenses
(5) proof of medical coverage which you may have, or may have available to you
IF you fail to appear for the conference or bring the required documents, the Court may issue a
warrant for your arrest.
BY THE COURT,
George E. Hoffer, President Judge
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Petitioner
Respondent
Charles Rector, Esquire
Date of Order: September 25, 2000
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND
REPRESENT YOU. 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 MAY GET
LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY A VB.
CARLISLE, PENNSYL VANIA 17013
(717) 249-3166
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JANICE E. MILLER,
Plaintiff
V.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. C6 - (,,/:16 (!'-od c..,-~
CIVIL ACTION - LAW
IN DIVORCE
ROLAND J. MILLER,
Defendant
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims set forth
in the following pages, you must take prompt action. You are warned that if you fail to
do so, the case may proceed without you and a decree of divorce or annulment may be
entered against you by the court. A judgment may also be entered against you for any
other claim or relief requested in these papers by the Plaintiff. You may lose money or
property of other rights important to you, including the 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 at the Office of the Prothonotary.
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, PA 17013
717-249-3166
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; IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO.
,;,
JANICE E. MILLER,
Plaintiff
ROLAND J. MILLER,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
COMPLAINT IN DIVORCE .
AND NOW comes the Plaintiff, Janice E. Miller, by and through her attorney,
Charles Rector, Esquire, and respectfully represents as follows:
1. Plaintiff is Janice E. Miller (SS # 200-36-8051), an adult individual,
currently residing at 1071-15 Lancaster Blvd., Mechanicsburg, Cumberland County,
Pennsylvania, 17055.
2. Defendant is Roland J. Miller (SS # 181-42-7553), an adult individual,
currently residing at 925 Shetters Lane, Camp Hill, Cumberland County, Pennsylvania,
17011.
3. Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for a period of six months (6) immediately preceding
the filing of the Complaint.
4. Plaintiff and Defendant were married on September 30, 1978, in
Mechanicsburg, Cumberland County, Pennsylvania.
5. There have been no prior actions for divorce or for annulment between
the parties.
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6.
The Plaintiff and Defendant are both citizens of the United States of
America.
Count I - Divorce
7. The allegations of Paragraphs 1 through 6 are incorporated herein by
reference and made a part hereof.
8.
This action is not brought through collusion between the Plaintiff and
Defendant, but in sincerity and truth for the reasons set forth within.
9. The marriage is irretrievably broken, and the parties are proceeding
under Section 3301 (c) of the Divorce Code. In the altemative, Defendant has offered
,
such indignities to Plaintiff, the innocent and injured spouse, as to render her condition
intolerable and her life bwdensome.
10. Plaintiff has been advised that counseling is available ,and that Plaintiff
may have the right to request that the Court require the parties to participate in
counseling.
WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce decree
dissolving the marriage between Plaintiff and Defendant.
Count II - Equitable Distribution
11. Paragraphs 1 through 10 of this Complaint are incorporated herein by
reference as if set forth at length.
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12. The parties have acquired, during the course of the marriage and prior to
separation, property, both real and personal, which they own jointly or which was
otherwise purchased so as to constitute marital property within the definition and scope
of Section 3502 of the Divorce Code.
WHEREFORE, Plaintiff requests your Honorable Court to enter an Order
distributing the marital property owned by the parties.
Count 11I- Spousal Support and/or Alimony
Pendent Lite and Permanent Alimony
13. The allegations in Paragraph 1 through 12 are incorporated herein by
reference and made a part hereof.
14. Plaintiff is unable to sustain herself during the course of this litigation.
15. Plaintiff lacks sufficient property to provide for her reasonable needs and
is unable to sustain herself adequately through appropriate employment.
16. Plaintiff requests this Honorable Court to enter an award of spousal
support and/or alimony pendente lite in her favor pursuant to Section 3701 of the
Divorce Code.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an
award of spousal support and/or alimony pendente lite until final hearing and thereupon
to enter an order of alimbny in her favor pursuant to Section 3701 of the Divorce Code.
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Count I~- Counsel Fees. EXDenses and Costs of Suit
17. The allegations of Paragraphs 1 through 16 are incorporated herein by
reference and made a part hereof.
18. Plaintiff has retained an attorney to prosecute this action and has agreed
to pay him a reasonable fee.
19. Plaintiff has incurred and will incur costs and expenses in prosecuting this
action.
20.' Plaintiff is not financially able to meet the expenses and costs of
prosecuting this action or the fees to which her attorney will be entitled in this case.
21. Plaintiff requests this Honorable Court to enter an award of interim
counsel fees, costs and expenses until final hearing and thereupon such additional
counsel fees, costs and expenses as deemed appropriate.
WHEREFORE, Plaintiff respectfully requests that, pursuant to Sections 3702 of
the Divorce Code, the Court enter an Order directing Defendant to pay Plaintiff's
reasonable counsel fees, costs and expenses.
-.
RESPECTFULLY SUB
Date:#
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I verify that the statements made herein are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904,
relating to unsworn falsification to authorities.
OUJ1J;# f JY( diu-.
.)' Janice E. Miller
Date: 9/1hou
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DR 30,034
PACSES ill 072102644
JANICE E. MILLER,
Plaintiff/Petitioner
vs.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: DOMESTIC RELATIONS SECTION
: CIVIL ACTION - LAW
ROLAND J. MILLER,
Defendant/Respondent
: NO. 00-6130 CIVIL TERM
ORDER OF COURT
AND NOW, this 17th day of October, 2000, based upon the Court's determination that
Petitioner's monthly net income/earning capacity is $1,201.19 per month and Respondent's monthly
net income/earning capacity is $2,521.17 per month, it is hereby Ordered that the Respondent pay to
the pennsylvania State Collection and Disbursement Unit, $228.00 a month payable weekly as
follows; $48.00 per week for alimony pendente lite and $4.62 per week on arrears. First payment due
next pay date at $52:62. Arrears set at $416.00 as of October 17,2000. The effective date of the
order is September 7,2000.
Failure to make each payment on time and in full will cause all arrears to become subject to
immediate collection by all of the means as provided by 23 Pa.C.S.g3703. Further, if the Court
finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare
the Respondent in civil contempt of Court and its discretion make an appropriate Order, including,
but not limited to, commitment of the Respondent to prison for a period not to exceed six months.
Said money to be turned over by the P A SCDU to: Janice E. Miller. Payments must be made
by check or money order. All checks and money orders must be made payable to P A SCDU and
mailed to:
PASCDU
P.O. Box 691 IO
Harrisburg, PA 17106-9110
Payments must include the defendant's P ACSES Member Nwnber or Social Security Nwnber in
order to be processed. Do not send cash by mail.
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Respondent to provide medical insurance coverage.
This Order shaIl become final ten days after the mailing of the notice of the entry of the Order
to the parties unless either party files a written demand with the Prothonotary for a hearing de novo
before the Court.
DRO: R. 1. Shadday
Mailed copies on
/lh11/-o0 to: <
BY THE COURT,
Petitioner
Respondent
Charles Rector, Esquire
Keirsten Davidson, Esquire
Edward E. Guido
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JANICE E, MILLER,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO, 00-6130 Civil Term
ROLAND 1. MILLER
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
TO CURTIS B. LONG, PROTHONOTARY:
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Please withdraw the appearance of the undersigned as counsel for the Defenimt, ;;:
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ROLAND J. MILLER, in the above-captioned matter. ;;- .
PRAECIPE FOR WITHDRAWAL OF APPEARANCE
Date: 1~t40 ~
ResP~1 ubmitted,
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Keirsten W. Davidson, Esquire
JOHNSON, DUFFIE, STEWART & WEIDNER
301 Market Street
P,O. Box 109
Lemoyne, P A 17043 - 0109
(717) 761-4540
PRAECIPE FOR ENTRY APPEARANCE
Please enter the appearance of the undersigned as counsel for the Defendant, ROLAND
J. MILLER in the above-captioned matter.
Respectfully submitted,
Sanford A. evslcY, sqUire
KREVSKY & ,PC
1 101 North Front Street
Harrisburg, P A 17102
(717) 234-4583
Atty. LD. 15560
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COUNSELORS AT LAW
1101 NORTH FRONT STREET
HARRISBURG, PENNSYLVANIA 17102-3324
(717) 234-4583 FAX (717) 234-3650
September 10, 2002
E. ROBERT ELICKER, II, ESQUIRE
OFFICE OF DIVORCE MASTER
9 NORTH HANOVER STREET
CARLISLE, PA 17013
Re: Millerv. Miller
No, 00-6130 Civil Term
Dear Mr. Elicker:
I represent the interest of Roland Miller relative to the above-referenced matter, I
am in receipt of your request of the status regarding Discovery in this matter. Towards
that end, the following has not been completed in order to prepare the case for trial:
1. Plaintiffs Income and Expense Statement;
2. Plaintiffs Inventory and Appraisement;
3. Plaintiffs Pre-trial Statement;
4. Defendant's Income and Expense Statement;
5. Defendant's Inventory and Appraisement;
6. Defendant's Pre-trial Statement.
Thank you for your attention. If you have any questions, please contact my office;
until then, I am
Very truly yours,
"-~
Sanford A. Krevsky
SAK:alp
pc: R. Miller
C. Rector, Esq,
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COUNSELORS AT LAW
1101 NORTH FRONT STREET
HARRISBURG, PENNSYLVANIA 17102-3324
Sanford A. Krevsky
Lawrence J. Rosen
David J. Schertz
Tel. (717) 234-4583
Fax (717) 234-3650
October 3 1,2002
E. ROBERT ELICKER, II, ESQUIRE
OFFICE OF DIVORCE MASTER
9 NORTH HANOVER STREET
CARLISLE, PA 17013
Re: Janice E. Miller v. Roland J. Miller (No, 00-6130 Civil- In Divorce)
Dear Mr. Elicker:
I am in receipt of your letter dated October 18, 2002 indicating that the Pre-trial
Statement relative to this matter is due on or before Friday, November 15, 2002, Upon
receipt of the Pre-trial Statement, you indicated you will schedule a pre-hearing
conference and thereafter, if necessary; sched~lea hearing.
I am in the process of finalizing Mr. Miller's Income and Expense Statement and
Inventory and Appraisal to supply to Attorney Rector and you. To date, I have not
received same from Attorney Rector on behalf of Janice Miller. I believe Ms. Miller's
documents are necessary in order for me to properly prepare a Pre-Trial Statement.
It is anticipated that the Pre-trial Statement will be filed and forwarded to you
prior to November 15,2002. Of course, if the necessary documents of Ms. Miller are not
submitted, it will be necessary to request an extension of the November 15, 2002
deadline. I will keep you abreast of same.
Thank you for your attention. If you have any questions, please contact my office;
until then) all'
,\,;, '
1;'
Very trylly yours,
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Sanford A, Krevsky
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SAK:alp
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R. Miller
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COUNSELORS AT LAW
1101 NORTH FRONT STREET
HARRISBURG, PENNSYLVANIA 17102-3324
Sanford A. Krevsky
Lawrence J. Rosen
David J, Schertz
Tel. (717) 234-4583
Fax (717) 234-3650
November 14,2002
E. ROBERT ELICKER, II, ESQUIRE
OFFICE OF DIVORCE MASTER
9 NORTH HANOVER STREET
CARLISLE, PA 17013
Re: Janice E. Miller v. Roland J, Miller (No. 00-6130)
Dear Mr. Elicker:
As youJmow, I represent the interest of Roland J. Miller relative to the above-
. .
referenced matter. Pursuant to the conversation you had with my staff, this letter is a
request for an extension of the deadline of November 15, 2002 to submit the Pre-trial
Statement relative to this matter. As my staff advised, to date, we have not received the
Income and Expense Statement and Inventory from Mrs. Miller's counsel.
Mr. Rector's staff indicates that in all probability, they will not be formally
submitting either the Income and Expense Statement or Inventory. I do not believe I can
effectively prepare the Pre-triaI Statement (specifically as it relates to a suggested
resolution) without same. Accordingly, this letter is a request that the deadline to submit
the Pre-trial Statement is extended for a period of time until the Income and Expense
Statement and Inventory is received from Mrs. Miller'sattomey or until such time as
counsel exchange the relevant information necessary to assess the value and of the
marital assets and debts.
This will also confirm that based on the contents of this letter as well as prior
request, there will be no adverse action against Mr. Miller due to. the Pre-trial Statement
not being submitted on November 15,2002.
.
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Page 2
Re: R. Miller
November 14, 2002
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Thank you for your attention and assistance. I look forward to hearing from you;
until then, I am
SAK:alp
pc: R. Miller
C. Rector, Esq.
Very truly yours,
~
Sanford A. Krevsky
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COUNSELORS AT LAW
1101 NORTH FRONT STREET
HARRISBURG. PENNSYLVANIA 17102-3324
Sanford A. Krevsky
Lawrence J. Rosen
David J. Schertz
Tel. (717) 234-4583
Fax (717) 234-3650
November 12,2002
E. ROBERT ELICKER, II, ESQUIRE
OFFICE OF DIVORCE MASTER
9 NORTH HANOVER STREET
CARLISLE, PA 17013
Re: Janice E. Miller v, Roland J. Miller (No. 00-6130)
Dear Mr. Elicker:
As you know, I represent the interest of Roland J. Miller relative to the above-
referenced matter. Enclosed please find a copy of an Income and Expense Statement
and Inventory under Rule 1920.33 for your file. The original and copies were
forwarded to the Cumberland County Prothonotary's Office for the appropriate filing and
a filed copy will be forwarded to you upon receipt.
To date, I have not received the Income and Expense Statement or Inventory from
Mrs. Miller's attorney, Charles Rector. If! am not in receipt of same within the next two
(2) days, it will be necessary for me to request an extension of the deadline of November
15,2002 for the Pre-trial Statement to be submitted. As the documents are required to
effectively prepare the Pre-trial Statement.
Thank you for your attention and assistance, If you have any questions, please
contact my office,
Very truly yours,
s~s~
Sanford A. Krevsky
SAK:alr
Enclosure
pc: R, Miller
C. Rector, Esquire
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JANICE E. MILLER,
Plaintiff
:IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 00-6130
ROLAND J. MILLER
Defendant
: CIVIL ACTION LAW - IN DIVORCE
INCOME AND EXPENSE STATEMENT
Income:
Employer: Exel Logistics
Type of work: Truck Driver/Jockey
Number of exemptions claimed for federal payroll withholdings taxes: 00
Gross pay per pay period $850.00 (weekly) Average +/-- Overtime
40 hours + 8 to 10 hours overtime
Itemized payroll deductions:
Federal Withholding $102,85
Local Wage Tax $ 8.53
Unemployment
Savings bonds
Life Insurance $ 6.24
Social Security $ 49.56
State Income Tax $ 22.37
Retirement
Medicare
Health Insurance 5 53.93
Other (SpecifY) $159.23 (Child Support)
(i.e. Child support)
Net pay per pay period $447.29
Household Income:
Names of all others in your household who have income.
1 None - Not Applicable
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Other Income:
Interest
Dividends
Pension
Annuity
Social Security
Rents
Royalties
Expense Account Gas
Unemployment
Workmen's Compo
Tips
Other
(NOTE: For two (2) weeks 08/14/02 to 09/04/02)
Expenses:
Home:
(Rent)
Utilities:
Electric & Heat
Sewage & Water
Telephone
Other: refuse collection
Taxes:
Real Estate
Occupational
Personnel
Medical:
Doctor
Dentist
Orthodontist
Hospital
Medicine- Non Prescription
Medicine- Prescription
Monthlv
Yearly
$ 50.00
$600.00
$400.00 (See Note) $800,00
Monthly
$600.00
Yearly
$7,200.00
$ 70.00
$ 840.00
$IIO,OO
$1,320.00
$ 15.00 (Average) $ 180,00
$ 25.00 (Average) $ 300,00
$ 5.00
$ 5.00
$ 60.00
$ 60,00
,
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Miscellaneous:
Memberships
Papers, publications
Entertainment
Cable TV
Vacation
Legal Fees
Contributions
Other: - Life Insurance Premium
- Travel to and From Work
- Food
- Clothing
- Xmas, Birthday, Etc
Child Care:
Auto for son, Nickolas Miller, a full-time
college student
Vehicle Maintenance
Vehicle Insurance
Automobile:
Year: 1988
Model: Chevrolet 8-10 Blazer
Insurance:
Maintenance:
Gas:
Credit Cards\Loans:
Roland Miller's cards
08/11/02 MasterCard ($400.00 Balance)
08115/02 CapitalOne ($1,586.01 Balance)
Nickolas Miller's, son, credit cards
08/01/02 Exxon, Mobil, & Master Card
($4,000.00 Balance)
$ 62.48 $ 749.46
$ 83.33 $1,000.00
($6,000,00 total)
$ 80.89
$ 65.00
$216.67
$ 50,00
$ 41.67
$ 970,68
$ 780.00
$2,600.00
$1,800.00
$ 500.00
$ 50.00
$ 83.33
$ 600.00
$1,000.00
$ 33.33
$ 41.67
$ 60.00
$ 400.00
$ 500.00
$ 720,00
$ 50.00
$100.00
$ 600.00
$1,200,00
$100.00
$1,200.00
TOTAL EXPENSES
-----------------------------------------------------
----------------------------------------------------
$ 2,398.00
$31,980.14
*Total yearly includes $6,000.00 attorneys fees.
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JANICE E. MILLER,
Plaintiff
:IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY PENNSYL VANIA
v.
: NO. 00-6130
ROLAND J. MILLER
Defendant
: CIVIL ACTION LAW - IN DIVORCE
VERIFICATION
I, ROLAND J. MILLER, verify that the facts set forth in the foregoing Income
and Expense Form, including all attachments thereto, are true and correct to the best of
my knowledge, information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to
authorities.
Date: tll., J 6)",
I I
~~
ROLAND J. MILLER
..
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JANICE E. MILLER,
Plaintiff
:IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-6130
ROLAND J. MILLER
Defendant
: CIVIL ACTION LAW - IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this ~ay oC~~~D,yL ,2002, I, Aimee L.
Paukovits, for the Law Office ofKREVSKY & ROSEN, P.C, hereby certifY that a copy
of the foregoing Income and Expense Statement was served upon the following by U,S.
First Class Mail:
CHARLES RECTOR, ESQUIRE
1104 FERNWOOD AVENUE
SUITE 203
CAMP HILL, P A 17043-0109
E. ROBERT ELICKER, II, ESQUIRE
OFFICE OF DIVORCE MASTER
9 NORTH HANOVER STREET
CARLISLE, P A 17013
llirt\~~ 'to rCI)I.l20ib
Aimee L. Paukovits
1101 North Front Street
Harrisburg, P A 17 102
(717) 234-4583
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JANICE E. MILLER,
Plaintiff
:IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 00-6130
ROLAND J. MILLER
Defendant
: CIVIL ACTION LAW - IN DIVORCE
INVENTORY
UNDER RULE 1920.33
Defendant, Roland J. Miller, file the following inventory and appraisement
of all property owned or possessed by either party at the time this action was commenced
and all property transferred within the preceding three years.
I verify that the statements made in this inventory and appraisement are true
and correct. I understand that false statements herein are made subject to the penalties of 18
Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
DATE: /1/ '1/ d)...
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ASSETS OF PARTIES
Plaintiff, Roland Miller, marks on the list below those items applicable to the case
at bar and itemizes the assets on the following pages. If an item has been appraised, a copy
of the appraised report is attached.
() I.
(X) 2,
() 3,
() 4,
(X) 5.
(X ) 6.
() 7.
() 8.
(X ) 9.
Real Property
Motor Vehicles
Stocks, bonds, securities and options
Certificates of deposit
Checking accounts, cash
Savings accounts, money market and savings certificates
Contents of safe deposit boxes
Trusts
Life Insurance policies (indicate face vaIue, cash surrender value, and current
beneficiaries)
() 10. Annuities
() I I. Gifts
( X) 12. Inheritances
() 13. Patents, copyrights, invention, royalties
() 14. Personal property
() 15. Business (list all owner, including percentage of ownership, and
officer/director positions held by a party with company)
() 16. Profit sharing plans
v1
Cont. Assets
Page 2)
(X )17.
( ) 18.
( ) 19,
( ) 20.
( ) 21.
( ) 22.
(X) 23.
( ) 24.
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Retirement plan, Individual Retirement Accounts
Disability payments
Litigation claims (matured and unmatured)
Military/VA benefits
Education benefits
Debts due, including loans, mortgages held
Household furnishings and personalty (include as a total category and attach
itemized list if distribution of such assets is in dispute)
() 25, Other
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JANICE E. MILLER,
Plaintiff
:IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYL V ANlA
v.
: NO. 00-6130
ROLAND J. MILLER
Defendant
: CIVIL ACTION LAW - IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this ~day of \21~,em~ ,2002, I, Aimee L. Paukovits,
for the Law Office of KREVSKY & ROSEN, P.C. hereby certifY that a copy of the
foregoing Inventory and Appraisement was served upon the following by U.S. First Class
Mail:
CHARLES RECTOR, ESQUIRE
1104 FERNWOOD AVENUE
SUITE 203
CAMP HILL, PA 17043-0109
E. ROBERT ELICKER, II, ESQUIRE
OFFICE OF DIVORCE MASTER
9 NORTH HANOVER STREET
CARLISLE, PA 17013
~d~~l~tRJtb
Aimee L. Paukovits
1101 North Front Street
Harrisburg,PA 17102
(717) 234-4583
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ORDERlNOnCETO\\:;ITHHOLD INCOME FOR SUPPORT
~: aJ -lel3'l> (?1'P/1. .
Slale Commonwealth of Pennsvlvania I1IcSES ()7;Z1();l/,"I~ @Original Order/Notice
Co./City/Dist. of CUMBERLAND ]>It. J()I)~" W, S iH)Oj) 0 Amended Order/Notice
Date of Order/Notice 10/17/00 t::ltI. t. t;'( 0 Terminate Order/Notice
Court/Case Number (See Addendum for case summary) ~t.~ 7(,tlt>H u:>
])Ie 3. 9V'l3
) RE: MILLER, ROLAND J.
EmployerlWithholder's Federal E1N Number ) Employee/Obligor's Name (Last, First, MI)
, ,
EXEL LOGISTICS ) 181-42-7553
EmployerlWithholder's Name ) Employee/Obligor's Social Security Number
501 W SCHROCK RD ) 9207100587
EmployerlWithholder's Address ) Employee/Obligor's Case Identifier
WESTERVILLE OH 43081- 8 966 ) (See Addendum for plaintiff names assoaated with cases on altadlmentJ
) Custodial Parent's Name (Last, First, MI)
)
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMA nON: This is an Order/Notice to Withhold Income for Support based upon an order for suppo~t
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.
$ 650.00 per month in current support
$ 40.00 per month in past-due support Arrears 12 weeks or greater? @yes 0 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 $ 690 .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:
$ 159.23 per weekly pay period.
$ 318.46 per biweekly pay period (every two weeks).
$ 345.00 per semimonthly pay period (twice a month).
$ 690.00 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 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.
DRO: RJ Shadday
xc: defen:lant
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Form EN-028
Worker ID $IATT
Date of Order:
October 18, 2000
Service Type M
OMBNo.:0970-0154
Expiration Date: 12131/00
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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 contactthe 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.* RcpOl1illg tI.e r-ilydatc/DatG vf'NitLlloldil.5. '/ou lnust ICp,-"lll.e paydaWJah:, of Hitl.[,6IJ;lIg HLeh 3(."Jillg tIle pay I IICIlt. -=Fhe-
paydahdJah:, of vvitl.I.6IJ:hg is tI.e Ja.tt VII vvl.k.I. <=ilnv...ht Has vvitl.I"JJ flOl1l tI.l. l.ln~loyee's vvag('3. 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 10: 0428011600
EMPLOYEE'S/OBLlGOR'S NAME: MILLER. ROLAND J.
EMPLOYEE'S CASE IDENTIFIER: 9207100587 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. 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.
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)l; 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 taxesi and Medicare taxes.
10.
"NOTE: If you or your agent are served with a copy of this order in the state lhat issued the order, you are to follow the
law of the slate that issued this order with respect to these items,
Requesting Agency:
DOMESTIC RELATIONS SECTION
P.O, BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (7171 240-6225 or
by FAX at (7171 240-6248 or
by Internet @
Page 2 of 2
Form EN-028
Worker ID $Ij~TT
Service Type M
OMB No.: 0970-0154
Expiration Date: 12131!00
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ADDENDUM
Summary of Cases on Attachment
ROLAND J.
Defendant/Obligor: MILLER,
072102644/3PP3lf
PACSES Case Number
Plaintiff Name
JANICE E. MILLER
Docket Attachment Amount
00-6130 CIVIL$ 228.00
Child(ren)'s Name(s):
DOB
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[JII ch~~ked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
D If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
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
Service Type M
OMB No.: 0970-01S4
Expiration Date: 11131JOO
PACSES Case Number 769102486 /<<fi~3
Plaintiff Name I '
JANICE E. MILLER
Docket Attachment Amount
00646 S 2000 $ 462.00
Child(ren)'s Name(s):
",AR,J/{.:r, ..I1I.L.L.ER..
:':"';'::':':"""::::'.:',':",:':::':::',:::;:,:":-:.,"::::':::::::,:',:,:.::,"':..:,,:",: ',;",':, ':
d;fch~ck~d,;~~~;~ ;e~~i;~dt~ ~~roll the child(ren) .
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
D If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
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.
Addendum
Form EN-02e
Worker ID ,$IATT
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COUNSELORS AT LAW
1101 NORTH FRONT STREET
HARRISBURG, PENNSYLVANIA 17102-3324
Sanford A. Krevsky
Lawrence J. Rosen
David J. Schertz
Tel. (717) 234-4583
Fax (717) 234-3650
November 20, 2002
E. ROBERT ELICKER, II, ESQUIRE
OFFICE OF DIVORCE MASTER
9 NORTH HANOVER STREET
CARLISLE,PA 17013
Re: Janice E. Miller v. Roland J. Miller (No, 00-6130)
Dear Mr, Elicker:
. Pursuant to my letter to you of November 12, 2002, enclosed please find a copy of
the. InCQme and Expense Statement and Inventory relative to the above-referenced
matterthat was filed at the Cumberland County Courthouse on November 14,2002,
Additionally, this will confirm that the deadline to submit the pre-trial statement in
this matter has been extended indefinitely pending receipt of the Inventory and Income
and Expense Statement from Mrs, Miller's attorney, Charles Rector.
Thank you for your attention and assistance. If you have any questions or require
anything further, please contact my office; until then, I am
Very truly yours,
~
Sanford A. Krevsky
SAK:alr
Enclosure
pc: R. Miller
C. Rector, Esq.
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COUNSELORS AT LAW
1101 NORTH FRONT STREET
HARRISBURG. PENNSYLVANIA 17102-3324
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Sanford A. Krevsky
Lawrence J. Rosen
David J. Schertz
Tel. (717) 234-4583
Fax (717) 234-3650
November 12, 2002
CHARLES RECTOR, ESQUIRE
1104 FERNWOOD AVENUE
SUITE 203
CAMP HILL, PA 17043-0109
Re: Janice E. Millerv, Roland 1. Miller (No. 00-6130)
Dear Charles:
Enclosed please find a copy of an Income and Expense Statement and
Inventory under Rule 1920.33 for your file. The original and copies were forwarded to
the Cumberland County Prothonotary's Office for the appropriate filing and a filed copy
will be forwarded to you upon receipt.
As the Pre~trial Statement is due to Mr. Elicker on or before Friday, November 15,
2002, please forward or fax a copy of Mrs. Miller's Income and Expense Statement and
Inventory. In the event that I do not receive same prior to Thursday, November 14,2002,
it will be necessary to extend the due date for the Pre-trial Statement.
In the meantime, if you have any questions, please contact my office. I look
forward to hearing from you; until then, I am
Very truly yours,
Sanford A. Krevsky
SAK:alr
Enclosure
pc: R. Miller
R. Elicker, Esquire
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JANICE E. MILLER,
Plaintiff
:IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYL VANIA
v,
: NO. 00-6130
ROLAND J, MILLER
Defendant
: CIVIL ACTION LAW - IN DIVORCE
PRE-TRIAL STATEMENT OF DEFENDANT
I.
a.
PLAINTIFF'S BACKGROUND
1071-15 Lancaster Boulevard
Mechanicsburg, Pennsylvania 17055
Date of Birth: 7/30/54
Occupation:
A. Office Clerk at Penney's
(Note: Wife reports $249.00 per month at this position;
however, her paystub from October 2002 indicates her total
year to date income at approximately $5,000.00, therefore her
monthly pay would be approximately $500.00.
B. Real Estate Agent at Jack Gaughn Realtors.
b. DEFENDANT'S BACKGROUND
17 West Front Street
P.O, Box 3146
Shiremanstown, PA 17011
Date of Birth: 3/31/54
Occupation: Truck Driver through Exel Logisti~s
c. Date of Marriage: October 31,1978
Date of Separation: July 2000
d. Place of Marriage: Mechanicsburg, Pennsylvania
e.
Children: Nickolas Alan Miller:
Carly Jane Miller:
23 years old
15 years old
,
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f. Grounds for divorce: Marriage is irretrievably broken.
g. Issues to be resolved: Alimony, Alimony Pendente Lite, Equitable
Distribution and Assignment of Property, Support, Counsel fees, Costs and
Expenses,
II. PROCEDURAL HISTORY
9/7/00:
Divorce action commenced.
8/22/02:
Master appointed to resolve all outstanding issues.
III. INVENTORY AND APPRAISAL
Forwarded to the Court on November 13,2002 on behalf of Defendant.
IV. WITNESSES
Lav:
a. Defendant
b. Plaintiff, as on cross
Expert:
Husband reserves the right to identify any expert witness should same
be needed to resolve any remaining dispute as to valuation of marital
assets.
V. EXHIBITS
Exhibits required to establish values will be provided at trial, if needed.
VI. INCOME INFORMATION
Forwarded to the Court on November 13, 2002 for filing; Copies of same
forwarded to opposing counsel and Master on November 13, 2002.
VII. EXPENSE INFORMATION
Forwarded to the Court on November 13, 2002 for filing; Copies of same
forwarded to opposing counsel and Master on November 13, 2002.
VIII. PENSION VALUE
Appraisals of both parties pensions have been conducted.
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IX. REAL ESTATE
Escrowed proceeds from the sale ofthe marital home Balance as of
December 31,2002 was $33,214.38
Mrs. Miller was the realtor that sold the marital home, It is believed that
Mrs, Miller received commission from the sale of the home,
X.
PERSONALTY
All items of personal property have already been divided to the parties
satisfaction but parties reserve the right to present testimony regarding the
value of furnishings distributed to each party if necessary
XI. PROPOSED ECONOMIC RESOLUTION
A. 55% split to Wife, 45% split to Husband (Division would include a
Qualified Domestic Relations Order relative to pensions).
B, Alimony payments will cease, *Wife has been receiving $48.00 per
week in Alimony Pendente Lite since September 10, 2000 for a total
amount received of approximately $6,096.00,
C. Taxes to be filed as follows:
1, 2001 - capital gains, wife claimed both kids (@$700-800)
2. 2002 - husband - head of household ($1200);
3. 2003 and thereafter - file separate.
D. There shall be no alimony or counsel fees awarded to either party,
Respectfully submitted:
Krevsky & Rosen, P.C,
By:~_'
Sanford A. @y, Esquire
1101 North Front Street
Harrisburg, P A 17102
10# 15560
(717) 234-4583
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JANICE E. MILLER,
Plaintiff
:IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO, 00-6130
ROLAND J. MILLER
Defendant
: CIVIL ACTION LAW -IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this '3\~day 0~20C!A I, Aimee 1. Rasheed, for the Law Firm
of Krevsky & Rosen, P. C" hereby certify that a copy of the foregoing Pretrial Statement was
sent via first-class D.S, Mail, postage prepaid, on the following:
CHARLES RECTOR, ESQUIRE
1104 FERNWOOD AVENUE
SUITE 203
CAMP HILL, PAl 7043-0 109
E. ROBERT ELICKER, II, ESQUIRE
OFFICE OF DIVORCE MASTER
9 NORTH HANOVER STREET
CARLISLE, PA 17013
ili0{\GctP.~c~rko(~
Aimee 1. Rasheed
1101 North Front Street
Harrisburg, PA 17102
(717) 234-4583
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JANICE E. MILLER,
Plaintiff
:IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: NO. 00-6130
ROLAND J. MILLER
Defendant
: CIVIL ACTION LAW - IN DIVO~E 0
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INVENTORY
UNDER RULE 1920.33
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Defendant, Roland J. Miller, file the following inventory and appraisement
of all property owned or possessed by either party at the time this action was commenced
and all property transferred within the preceding three years.
I verifY that the statements made in this inventory and appraisement are true
and correct. I understand that false statements herein are made subject to the penalties of I 8
Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
DATE: ]I / 'i / 6~
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ASSETS OF PARTIES
Plaintiff, Roland Miller, marks on the list below those items applicable to the case
at bar and itemizes the assets on the following pages. If an item has been appraised, a copy
of the appraised report is attached.
() I.
(X) 2.
() 3.
() 4.
(X) 5.
(X ) 6.
() 7.
() 8,
(X ) 9.
Real Property
Motor Vehicles
Stocks, bonds, securities and options
Certificates of deposit
Checking accounts, cash
Savings accounts, money market and savings certificates
Contents of safe deposit boxes
Trusts
Life Insurance policies (indicate face vaIue, cash surrender value, and current
beneficiaries)
() 10. Annuities
() 11. Gifts
(X) 12. Inheritances
() 13. Patents, copyrights, invention, royalties
() 14. Personal property
() 15. Business (list all owner, including percentage of ownership, and
officer/director positions held by a party with company)
() 16. Profit sharing plans
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Cont. Assets
Page 2)
(X )17.
( ) 18.
( ) 19.
( ) 20.
( ) 21.
( ) 22.
(X) 23.
( ) 24,
'..,',."
Pension plans (indicate employee contributions and date plan vests)
Retirement plan, Individual Retirement Accounts
Disability payments
Litigation claims (matured and unmatured)
MilitaryNA benefits
Education benefits
Debts due, including loans, mortgages held
Household furnishings and personalty (include as a totaI category and attach
itemized list if distribution of such assets is in dispute)
() 25. Other
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JANICE E. MILLER,
Plaintiff
:IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 00-6130
ROLAND J, MILLER
Defendant
: CIVIL ACTION LAW - IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this ~day of D'1.lUY\~ ,2002, I, Aimee L. Paukovits,
for the Law Office of KREVSKY & ROSEN, P.C. hereby certify that a copy of the
foregoing Inventory and Appraisement was served upon the following by U.S, First Class
Mail:
CHARLES RECTOR, ESQUIRE
1104 FERNWOOD A VENUE
SUITE 203
CAMPHILL,PA 17043-0109
E. ROBERT ELICKER, II, ESQUIRE
OFFICE OF DIVORCE MASTER
9 NORTH HANOVER STREET
CARLISLE, PA POI3
(l\J'{\&Q 8 \\0 Q~b
Aimee L. Paukovits
1101 North Front Street
Harrisburg, PA 17102
(717) 234-4583
;~1
"" : t.
JANICE E. MILLER,
Plaintiff
v.
ROLAND J, MILLER
Defendant
. " ~," \ ~'
:IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYL VANIA
: NO. 00-6130
: CIVIL ACTION LAW - IN DIVORCE ;:::iF:
ZJ:
-;.>,--
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INCOME AND EXPENSE STATEMENT
Income:
Employer: Exel Logistics
Type of work: Truck Driver/Jockey
Number of exemptions claimed for federal payroll withholdings taxes: 00
Gross pay per pay period $850.00 (weekly) Average +/-- Overtime
40 hours + 8 to 10 hours overtime
Itemized payroll deductions:
Federal Withholding $102.85
Local Wage Tax $ 8.53
Unemployment
Savings bonds
Life Insurance $ 6.24
Net pay per pay period $447.29
Social Security $ 49.56
State Income Tax $ 22.37
Retirement
Medicare
Health Insurance $ 53.93
Other (Specify) ~159.23 (Child Support)
(i.e. Child support)
Household Income:
Names of all others in your household who have income.
1 None - Not Applicable
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Miscellaneous:
Memberships
Papers, publications
Entertainment
Cable TV
Vacation
Legal Fees
Contributions
Other: - Life Insurance Premium
- Travel to and From Work
- Food
- Clothing
- Xmas, Birthday, Etc
Child Care:
Auto for son, Nickolas Miller, a full-time
college student
Vehicle Maintenance
Vehicle Insurance
Automobile:
Year: 1988
Model: Chevrolet S- I 0 Blazer
Insurance: '
Maintenance:
Gas:
Credit Cards\Loans:
Roland Miller's cards
08/1 1/02 MasterCard ($400.00 Balance)
08/15102 CapitalOne ($1,586.01 Balance)
Nickolas Miller's, son, credit cards
08/01/02 Exxon, Mobil, & Master Card
($4,000.00 Balance)
,,,,,:,,,'~~,,,",
$ 62.48 $ 749.46
$ 83.33 $1,000.00
($6,000.00 total)
$ 80.89
$ 65.00
$216.67
$ 50.00
$ 41.67
$ 970.68
$ 780.00
$2,600.00
$1,800.00
$ 500.00
$ 50,00
$ 83.33
$ 600,00
$1,000.00
$ 33,33
$ 4 1.67
$ 60,00
$ 400.00
$ 500,00
$ 720.00
$ 50.00
$100.00
$ 600.00
$1,200.00
$100.00
$1,200.00
TOTAL EXPENSES
$31,980.14
*Total yearly includes $6,000.00 attorneys fees.
$ 2,398.00
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)
Other Income:
Interest
Dividends
Pension
Annuity
Social Security
Rents
Royalties
Expense Account Gas
Unemployment
Workmen's Compo
Tips
Other
(NOTE: For two (2) weeks 08/14102 to 09/04/02)
Expenses:
Home:
(Rent)
Utilities:
Electric & Heat
Sewage & Water
Telephone
Other: refuse collection
Taxes:
Real Estate
Occupational
Personnel
Medical:
Doctor
Dentist
Orthodontist
Hospital
Medicine- Non Prescription
Medicine- Prescription
';~:"';'-"~' ~
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Monthlv
Yearlv
$ 50.00
$600.00
$400.00 (See Note) $800.00
Monthlv
$600.00
Yearlv
$7,200.00
$ 70.00
$ 840.00
$110.00
$1,320.00
$ 15.00 (Average) $ 180.00
$ 25.00 (Average) $ 300.00
$ 5.00
$ 5.00
$ 60.00
$ 60.00
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\
JANICE E. MILLER,
Plaintiff
:IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY PENNSYLVANIA
v.
: NO. 00-6130
ROLAND J. MILLER
Defendant
: CIVIL ACTION LAW - IN DIVORCE
VERIFICATION
I, ROLAND J. MILLER, verify that the facts set forth in the foregoing Income
and Expense Form, including all attachments thereto, are true and correct to the best of
my knowledge, information and belief, 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: jl/,/6)"
I I
~ ~Jll
ROLAND J. MILLER
'''''''''''''''''","
- .
~""~"
"",~~ "--='---~~,.;,;'
.
JANICE E. MILLER,
Plaintiff
:IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 00-6130
ROLAND J. MILLER
Defendant
: CIVIL ACTION LAW - IN DIVORCE
CERTIFICATE OF SERVICE
\
AND NOW, this ~ay ocl\t\re.m~ '{L ,2002, I, Aimee L.
Paukovits, for the Law Office ofKREVSKY & ROSEN, P.C. hereby certify that a copy
of the foregoing Income and Expense Statement was served upon the following by U.S.
First Class Mail:
CHARLES RECTOR, ESQUIRE
1104 FERNWOOD AVENUE
SUITE 203
CAMPHILL,PA 17043-0109
E. ROBERT ELIC~R, II, ESQUIRE
OFFICE OF DIVORCE MASTER
9 NORTH HANOVER STREET
CARLISLE, PAl 70 13
~~~ '1-- rn\,~b
Aimee L. Paukovits
1101 North Front Street
Harrisburg, PA 17102
(717) 234-4583
""'--
JANICE E. MILLER,
Plaintiff
V.
ROLAND J. MILLER,
Defendant;
Date: ~.J.
.,-"',,,,'- ',--"" ';"
.' 'C~'"'~,~",",,",''''L "'.";'0 ",",. ',;.,~,
~--
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-6130 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
Income and Expense Statement
Of
,
'Plaintiff, Janice E. Miller
I
---,..,
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INCOME
Employer
Address
ERA Jack Gaughen
19 N. Baltimore Street, Dillsburg, PA 17019
Type of Work
Real Estate Sales Association (self employed)
Pay Period (weekly, biweekly, etc.)
Commission On.ly
Gross Pay for 2002:
$ 12,603.66
Itemized Payroll Deductions:
Federal Withholding
Social Security
Local Wage Tax
State Income Tax
Retirement
Savings Bonds
Credit Union
Life Insurance
Health Insurance
Other (specify) Expenses
$ 3,165.81
Net Pay for 2002
$ 9,437.85
OTHER INCOME
Week Month Year
(Fill in appropriate column)
Interest $
PART TIME JOB AT JCPENNEY
Dividends
Pension
Annuity
Social Security
Rents
Royalties
Expense Account
Gifts
Unemployment Compo
Workers' Compo
SUPPORT
$
$ 249.00
$
$ 690.00
TOTAL
$
$939.00
$
TOTAL INCOME
......
Home
Mortgage/rent
Taxes
Maintenance
Utilities
Electric
Gas
Oil
Telephone
Water/Sewer/Refuse
Employment
Public Transportation
Lunch
Taxes
Real Estate
Personal Property
Income
Insurance
Homeowners/Renters
Automobile
Life
Death
Health
Other
Automobile
Payments
Fuel
Repairs
Licenses/Registration
Auto Club
Medical
Doctor
Dentist
Orthodontist
Hospital
Medicine
Special Needs
, '~ ^
MONTHLY EXPENSES
$ 400.00
$ 165.00
$ 50.00
$ 140.00
$ 10.00
$ 12.50
$ 45.50
$ 41. 00
$ 109.00
$ 40.00
$ 75.00
$ 3.25
,"' '<,__ie,,:,;,.-, 'r" .';'
_].JoN'
~
, ",'~
.II' l.e,
Education
Private School
Parochial School
College
Religious
School Lunches
Books/Miscellaneous
Personal
Clothing
Food
Barber/Hairdresser
Personal Care
Laundry/Dry Cleaning
Credit Payments
Credit Card
Charge Account
Memberships
Hobbies
Loans or Debts
Personal Loan
Miscellaneous
Household Help
Papers/Books/
Magazines
Entertainment
Pay TV
Vacation
Gifts
Legal Fees
Charitable
Contributions
Religious Membership
Other Child Support
Alimony payments
Other
TOTAL MONTHLY EXPENSES
" ~~ ,,' ,
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"j;'!:l:UlilMi
$ 150.00
$ 50.00
$ 200.00
$ 10.00
$ 140.00
$ 75.00
$ 25.00
$ 40.00
$ 39.00
$ 80.00
$ 125.00
$ 250.00
$ 50.00
$2,295.25
..
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I verify that the statements made herein are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S, Section 4904,
relating to unsworn falsification to authorities.
/'-1
( '4fs;n~01U...
~nice E, Miller
Date: /1(; 9 / ~
l'ajl..-JlC:l..-fIt,.
"^" "~'~'~~k", :""'~"~.~-iwi,
IIlLp>:iIt'''Ur I WtlA I :J.loolt'aYL-neCKfpg...& I U I AL_lJKU:S:S~16Y.6b& Nt', I_PA Y~107.87
=-
JCPenney Associate Kiosk
Direct Deposit Advice
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Associate: Miller,Janice
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Payroll funds to cover your direct deposit account(s) will be available on payday I
advice date
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310 South Main Salt Lake City, Utah 84101
i BACK 1 r-OPTIO'NS..'; rPRINT'l ~:
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t t /3/024:56 PM
Label
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Use the IRS
label. H
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pie lyase print R City, town or post office, state, and ZIP code. If you haVi10reign address, see pa.ge 19.
orpe. Em'{ 'D
Presidential ~c{--I;AAj lc.S D(..( 12 A ?D!;;;~
Election Campaig~ ... . N9te. Checkin!;J '''Yes'' will flQt ch~l1ge' your t8K<?r, reckice YO~ r~fund,~, .
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1 Singie'., . . . ".:., c.' .' . '.
Filing Status. 2 . Mairiedfilingioint retulTl (even ff only onehad.incot!,e) : < .... . > .
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~" return, do not Check box 6a . . . , . .", ',' , . . . . . cheCked'on'
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9 "::Ordlnary dividendS.. Attach Schedule ~jf, reql!i~e~f
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12 Busin~~~ jnc:oIT!~"qr Qoss). ~tfacb ,~~hedul.~p 9r'c'-EZ .:~, i" " " ':' '
1~' ~apit?l gain ,~rJlo~).,c~ttac~ Sc~:ooul~'D if reqLiired~' If nQt requir.ed" check,~efe'""",, D'
1~ pthej.,gain~':,:or([oss6s).,AttachFbr'm:479,7,....".,.,.".., ~ ~'" .." . _,_. ."
~: r~=~~~;~~:s::~~~~~, t:j. H'U' B:~::::1~~=~:::~:::~:~
o' _ _< ''','' ":,',', " " , ',__ ,". ',:"'......',,"_,' ,:__ _" ;..,'.-' '.
17 ,Rerlt~l. re?tl e:~te" royaltieS, partr'!ersh.ips,'S'corp-oration~, trusts, etc. Attach S9he<;iule E,
18 ,:F~)n~meor(IOss).'AttaCh Scnedule"p'- ~;"
19 Ure:{jIployment,co"niperisatioil':, _;' d ,~'''>,- ~ , __'",___. .,..., . ,', '. c .' : __"", . . . "
2aaSociaisecuritY.beneftts ,12Oa 1 . .1 l.b.JaxaOJearnounUs""page2$)
.21" , . OtJier~np'om~. Li~ type ,and arry.6u~t (see page 27) ~.__."....,",_.____~kU_'.'________.___.
"'22' Add the amounts in the far, ri ht column for lines 7'through 21.}his Is ypurtotal income ....
23 . IRA deduction (see page 27) 0 . . 23
; ~4 .-Studerit,ioan int~re~t ~e~uction (see pag,e .?~)."., 0_, ., 24
25.' Archer MSAdeduCtlon. Attach FO(lTl 8853: . 25
,28 . tv1(Wing expe'n~. Attcich.'F?~, 3903.. , " 26 '
27 . One-half of self-emproyment t~~ Attach Schedule- SE 27
?8 ~,el~-employ'~d hear!h ins.~~C?e d(:!d~~~i9n (s~e, page ~O} . 28,
29" Self-employed SEP, SIMPLE, and qUalified plans . 29
,>,30: .'Penalty~m,ear1ywithdrawal of~vings 30,
"-31a Alimony paid b ~ecipient's SSN .... 31a
32 AcId lines 23, through 31a .
'33 Subtract llne"32'from' line 22. iriis is your adjusted grosS 'income
~~_,I?i_~~!~~~:~~,~rivacy Act, and Paperwork Reduction Act Notice, see page 72.
~'1 040
Check only
one box.
Exemptions
If more than six
dependents,
see page 20.
Income
Attach
Forms W-2 and
W-2G here.
Also attach
Fonn(s) 1099-R
if tax was
withheld.
If you did not
get a W-2,
see page 21.
Enclose, but do
not attach, any
payment. Also,
please use
F=orm 1040-V.
Adjusted
Gross
Income
,
DElIp'artmerrt of the- TreaSury-Internal Revenue ::Sarvlce
-. U.S~ Individual Income Tax R.eturn
,
,
~@Ol
. . .
, ".
, , "
IRS'Uso'OnlY-DO n6t Vmta or',~Ple.i~ this sP~. '
,20
(1)
,2001, ending
OMB, No_,1545-D074
Your social security number
;}co ~&! 'f,'O.s-/
l
A
B
E
l
For the year Jan. i-Dee. 31, 200.1, or other lax year beginning
Y r first name and initial Last name
{Y/ILUre.
Nrc.'C
If a joint return, spouse's first name and initial
Last name
Spouse's social security number',
Apt. no.
. . . Irnport~nt! '.A:.
-You"must, enter -'
. . your SSN(s) above;
You
:'.. ",,~ousa", cO
No DYesDNQ
;"'. ..DYes
I
:',~ :'
~
7
g' .
1.0
11.
.12
13
14.
15b
16b
17
18'
19
2Gb:
21<
22
(S -
..0 '"
32
33
IC)O'S'"
;;JD .0=-
Fann 1040(2001)
Cat. No. 11320B'
.'
.
. .
Tax and 'j,{,Ainount from line;l3 (adjusted gross income) . .' .. . .
Credits ;~.9n~~ if:.D You were 65 oroldei;:Dslind; Dspouse was 65 or oider,O Bijnd.
Standard ~-" ,:"'Add the number ,~f bo~es che~~ed' ~ve, and ~n~e~th~, tot~i, here ; )::..... 3,5a
'Deduction , i.}b.;,,'_ If y~U ~('e married 'filing separately arid your spouse,fteinizes' deducti,on$. of, ;", , :,,," "
for- ~.' 'you'w~~e,::rduaf-statusalfen,.s~epa~e31"aTJd,ch~~:h~re ~:.' .' "'" ~"'-~'35b"O
~h:~~~e a~~o' -'~f?)i~:<:I~,emiz~d ~edUytiQ~~ (fro,m 'Schedule, A) or you~ ~l1d~~d 'deduction (~eeJeft !TI?lrgi~) .,
. ~g~ ~~ J~~ or l "", ~',;:':"SuPtra..bt liJ1,e ~6 from Ji~e ,3:4 ,.,,' --" ," ," , : ,', ".' "', ' ,'" :..' ~",~_
who can be 8~: ''-,: :Jf line 34 ,hi;: $~9, -;:25 or 1~~;,}1JUlt;p'I,y $2.~piJ ,by, t~e,i.Qtal' n~:mb~r-'qf ,~~rf,Pti~ns ,claim~d on "
claimedasa '::,::,':;,:<,JjJii?',6d~,JfJj;,e34.js'o\1eY$9,9;725~;see.thewcifkSn'~:on'pa;ge,32, ,_ ' " " '" ",'
~:~~dg~n~1. 9: ""',~~'-raxabl~ "inc,ome. SUbt~~ct"lln~"38",frO~: I(~e ,37'::,:,I~ .'in~"3,~ is)rlOr~' -.th.~n: 'ri'n~ ,s,?;' enter
. All others:ci:,/1;~,t(see p~ge~3). Ch~bkjiaw;~~ frl'm'aC;tf9n1~)8a14iJJ.D~0ffi)4972
': ~~~~6 t ',.": :~:~temati~E:, mi~i~,~~' tcpt ()jl,ee -p-~ge,.~4). ,~~cii ',For~ ~2~,1 '. , ' .
Head of ,~,~',L~qd,JineS~O'~nd4:l..",:, ,;,':':'~.,", ',:, ,:,:"',:"',' .,,:.,:,."''':~' ','-43 --",-- "_J_'_~~~:::2"":..,_.
. ~~~:5e~O]d, ~~ ,F~reig~ ta,\:~redi~~ ~~~~tfu I4:~.rni" !,t1'.6 If r~q~lred "",: :,'~:::,", ' " 44 .
, Married filing ... ' :45,
':~~Iym ~
.. Qualifying ": ,,:"':46
:'; s~~g~(er), ". '~:ir.,.,< ',. ~::4'i
, Married ~,,'."I.' .~ "", ,.',,'., ".,,'.',-,'. ~'," " ',:',48
:; filing ," '~.:::,'c.:::: 49",
", separately, ,- ~,' ",.
. $3 ~OO
",,,.,: :,;c'sf
.,............,~'?"'.>;;.52...
.~~I.~~~t~:;~r[
"':':"""::'1':':: ::.,',.... '. .,.." :~':"::i:f~,::,
',"':, ".',' ";' ,?;:,~,),:'~'::"
~~ 11!~W~~~~,~~a';i
6Sc, and 6ad. l~,9 ':':ArnQUi'itbfJi,rie'67' ou-\"/a'nt '" liecho:" our2002'eStlmatedtilx ",. 139 ." '
Amount Wi9.::::""::':,~',Am:?~~~ i'o'~, 'o~~.':'silb~'(a'9f~in,~"6.~:troTr(!t~,~ ,p:e~", f:i?f :9,~t~,il~i o,n,:"~?W.,,t9j?~L~e;:,~P.:~2:,1'~;,j'.'
You Owe :1.1,.,,:-- ..,E.$tl1c:Lted t~x p.enalty."Also, melu.de on, hne,,7Q, ,'. ;',,: '~;,::';':'F':':"'.' ':'--'4 ",-:' ":",7.1
b~~~~:~ 1;~:~i:~'o:~i1~eW'aD~~h~.P~Sb'St~;~l~~l,~~~"~~~;~~;~)e,ij3~,t~:~!,e~:l~~~ii~~f.;~l~;;i~,
Sign ~i:-';::.::\l~per j)~h::iJties~of p'~,rLurY, f9,~c.1ar~ tl]at'. ~a.y~ ex~'nad' th.!,s 'retJm::~d, ~9~omp,any'iriQ ~~~,Ul8s~,j)~, st?tefri,en~; '.8rlP:to ;theJi:~~' 9(:PW,:kii~ied~,e:~ri;1. ;-:,?
Here kL~,~\':.~,--:hf[~~~~~!:~:r~ct, an~~~~e:e:~~~~l~~,~~tt~a~! ~~!!'~~.th~~--,~~~;~!~:!f::.!o.I!:,~~~:T~,~,,~~"J.~~~,~ ~r~l;!.~~~y~~_~9X~J~;;2';':4;
J . t tu ? ~t:,o Your signature Date Your occupation Daytime phone number k
om re m. ~' "
See page 19. ,.
Keep a copy Spouse's signatu~e, If a ioint retum, both must sign, Date Spouse's occupation
for your ,
records. ',0-:
Paid Preparers It.
;, signature ,.
Preparer's '
Firm's name (or ~
Use Only ~~ yours if self-employed),
~:':' address, and ZIP code
. . Page 2.,
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,Fo'."'.1...Q<l{)~".0~:9'
1)'."
Profit 'or Loss From Business
(Sole Proprietorship)
... Partnerships, joint ventures, etc., must file Form 1065 or Form 106&-B.
" Attachment
~ Attach to Form 1040 or Form 1041. ~ See Instructions for Schedule C (Form 1040). Sequence No. 09
Social security number (SSN)
~cZ7 S(p: 105/
B Enter code from ~.ages C-7 & 8
...
o Employer to numb~~JI;.l.M). if any
. -I I I I
~~:70~na~~~~:t ~r;;;~~i~~~~I;:'~ ~o;~o~~') ~ 'Oof~.;Lt;ldt2.r0;~~"00"~7'O'j~"""""'..' .........,,"...
Accounting method: (1) It'J, Cash (2) 0 Accrual (3) 0 Other (specify) ~ ...,,000000.00,,"00"0000."."00...."....00".
Did you "materially participate" in the operation of this business during 2001? If "No," see page C-2 for limit on losses . be Yes 0 No
If you started ,or acquired this business during 2001, check here. . . . . . . . . . . . . ..... 0
Income
~~.
~ I;,
,.
SCHEDULE C
(Form 1040)
Department of the Treasury
Internal Revenue ServIce (0)
Name of proprietor
JAtJ'L'Z:.-
~
lvi, u oE. (Z.
A
C
Principal busine r p~Ofe~jOn, ~~dlng p~ or service (see page C-1 of the instructions)
Business name. If no separate business name, leave blank.
E
F
G
H
1
Gross receipts or sales. Caution. If this income was reported to you on Form W-2 and the UStatutory 0
employee" box on that form was checked, see page C-2 and check here ..
Retums and allowances' . . . . . .
Subtract line 2 from line 1
Cost of goods sold (from line 42 on page 2)
2
3
4
5 Gross profit. Subtract line 4 from line 3 . . . . . . . .
6 Other income, including Federal and state gasoline or fuel tax credit or refund (see page C-3)
7
G!:,OSS income. Add lines 5 and 6 . ......
Expenses. Enter expenses for business use of
8 O;{
our home only on line 30,
8
9
11
12
13
30
15
16
29 Tentative proflt (i05S). Subtract line 28 from line 7
30 Expenses for business use of your home. Attach Form 8829
31 Net profit or (1055). Subtract line 30 from iine 29.
. If a profit, enter on Form 1040, line 12, and also on Schedule SE,line 2 (statutory employees,
see page C-5). Estates and trusts, enter on Form 1041, line 3.
. If a loss, you must go to line 32.
32 If you have a loss, check the box that describes your Investment In this activity (see page C~6).
. if you checked 32a, enter the loss on Form 1040, line 12, and also on Schedule SE, line 2
(statutory employees, see page C-5). Estates and trusts, enter on Form 1041, line 3,
. If you checked 32b, you must attach Form 6198.
for Paperwork Reduction Act Notice, see Form 1040 instructions. Cat. No. 11334P
OMS No. 1545-0074
~@01
1
2
3
4
4&3
c.I.( 37
5
6
(p37
~
Lj{(J37
7
19
20a
20b
21
22
23
I
24a
24d
25
26
30
27
26
rj:r
29
30
I
..
..
}
}
.,
31
32 ~~.
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SCHEDULE EIC
(Form 1040A or 1040)
Department of the Treasury
Internal Revenue Service (P)
Name(s) shown on return
Complete and attach to Form 1040A or 1040
only if you have a qualifying child.
OMS No. "1545-0074
Earned income Credit
Qualifying Child Information
~@IB1
Attachment
SequencE~ No. 43
Your SOCial security number
Before "au begin: See the instructions for Form 1040A, lines 39a and 39b, or Form HMO, lines 61a and 6lb,
.T to make sure that (a) you can take the E1C and (b) you have a qualifying child,
. If you take the EIC even though you are not eligible, you may not be allowed to take the credit for up
to 10 years. See back of schedule for details.
~ . It will take us longer to process your return and issue your refund if you do not fill in all lines that apply
Itdml!I for each qualifying child. .
. Be sure the child's name on line 1 and social security number (SSN) on line 2 agree with the c:hild's
social security card. Otherwise, at the time we process your return, we may reduce or disallow your
EIC. If the name or SSN on the child's social security card is not correct, call the Social Security
Administration at 1-800-772-1213.
Qualifying Child Information
Child 1
Child 2
1 Child's name First name Last name First name Last name
If you have more than two qualifying children, you U I'ckol.As..,<.,{'LLU ~ ;...{f LL:~
only have to list two to get the maximum credit.
2 Child's SSN
The child must have an SSN as defined on page 42
of the Form 1040A instructions or page 44 of the
Form 1040 instructioos unkss the child was born and
died in 2001. If your child was born and died io 2001 /27 !f.,(p ~3('c;
and did not have an SSN, enter "Died" on this line 02c0 !<ooj 7d4-0
and attach a copy of the child's birth certificate.
3 Child's year of birth Vear --l:- .2- -.f ~ Vear +- ~ g ~O
If born after 1982, skip lines 4a If born after 1982, skip lines 4a
and 4b; go to line 5. and 4b; go to line 5.
4 If the child was born before 1983-
a Was the child under age 24 at the end ~ Yes. D No. DYes. D No.
of 2001 and a student?
Go to'line 5, Continue Go to line 5. Continllf
b Was the child permanently and totally DYes. DNO. DYes. D Nlo.
disabled during any part of 2001?
Continue The child is not a Continue The child is not a
qualifying child. qualifying child.
5 Child's relationship to you
(for example, son, daughter, grandchild, SoYl ~- ,,, k-kr-
foster child, etc.)
6 Number of months child lived with
you in the United States during 2001
. If the child lived with you for more than half of 7~
2001 but less than 7 months, enter "7". months ~. months
. If the child was born or died in 200 1 and your Do not enter more tlum 12 months. Do not enter more tlum 12 months.
home was the child's home for the entire time he
or she was alive during 2001, enter "12".
~11
You may also be able to take the additional child tax credit if your child (a) was under age 17 at the end of 2001, (b) is
claimed as -your dependent on line 6c of Form lO40A or Form 1040, and (c) is a u.s. citizen or resident alien. ]:<'or more
details, see ihe instructions for line 40 of Form 1040A or line 63 of Form 1040.
For Paperwork Reduction Ac:t Notice, see Form 1040A
or 1040 instructions.
Cat. No. 20834G
Schedule EIC (Form 1040A or 1040) 2001
~
Form
8812
Additional Child Tax Credit
Department of the Treasury
Internal Revenue Service (1J
Name(s) shown on return
Complete and attach to Form 1040 or Form 1040A.
0i\N \ ~t. ~. v'-t LLE- (2..
... All Filers
1 Enter the amount from line I of your Child Thx Credit Worksheet on page 38 of the Form 1040 instructions
or page 37 of the Form 1040A instructions. If you used Pub. 972, enter the amount from line 8 of the
worksheet on page 3 of the publication ,...,
2 Enter the amount from Form 1040, line 48, or Form 1040A, line 31
3 Subtract line 2 from line 1. If zero, stop; you cannot take this credit
4 Enter your total taxable earned income. See the instructions on back
5 Is the amount on line 4 more than $10,000?
o No. Leave line 5 blank and enter -0- on line 6.
o Yes. Subtract $10,000 from the amount on line 4. Enter the result
6
/.scnv .
4
5
I 000 ()
Multiply the amount on line 5 by 10% (,10) and enter the resnlt
Next. Do you have three or more qualifying children?
Sil' No. If .line 6 is zero, stop; you cannot take this credit. Otherwise, skip Part II and enter the
snialler of line 3 or line 6 on line 13.
o Yes. If line 6 is equal to or more than line 3, skip Part II and enter the amount from line 3 on
lioe 13. Otherwise, go to line 7.
IiZlIIIII Certain Filers Who Have Three or More Qualifying Children
7
Enter the total of the withheld social security and Medicare taxes from Form(s)
W-2, boxes 4 and 6. If married filing jointly, include your spouse's amounts
with yours. If you worked for a railroad, see the instructions on back
1040 filers: Enter the total of the amounts from Form 1040, lines
27 and 54, plus any uncollected social security and
Medicare or RRTA taxes included on line 58.
1040A mers: Enter -0-,
8
9 Addlines7and8. . . . . . .
10 1040 mers: Enter the total of the amounts from Form 1040, lines
61a and 62.
1040A filers: Enter the total of the amount from Form 1040A, line
39a, plus any excess social security and RRTA taxes
withheld that you entered to the left of line 41 (see the
instructions on back).
11 Subtract line 10 from line 9, If zero or less, enter -0-
12 Enter the larger of line 6 or line II here. , . , .
Nex4 enter the smaller of line 3 or line 12 on line 13,
I'!'-IIITIJ Your Additional Child Tax Credit
7
}
8
M'"
~" ,.~.l.'" ,
". . ^ ~;t,.'$
9
10
"
OMS No. 1545-1620
~@01
Attachment
Sequence No. 47
Your social security number
6100 :3 tJ.. &,oS'l
1 (oeD
2 if
!.coo
,---e;.,,;,
::;tr~r
11
&~
13 This is your additional child tax credit
.. .. GJ
~
~....
Enter this amount on
Form 1040, line 63, or
Form 1040A, line 40.
For Paperwork Reduction Act Notice, see back of form.
Form 8812 (2001)
Cat. No.1 Q644E
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JANICE E. MillER,
Plaintiff
V.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 00-6130 CIVil TERM
: CIVil ACTION - LAW
: IN DIVORCE
ROLAND J. MillER,
Defendant
PLAINTIFF'S PRE.TRIAL STATEMENT
Date of Marriage: 09/30/78
Date of Separation: 7/00
I. ASSETS:
1. Escrowed proceeds from the sale of the marital home
Balance as of 10/31/02 (see attached Exhibit) $ 33,166,08
2. (W) 401 K Plan $ 6,594.00
3. Joint First Union Account (Value at separation) $ 900,00
4. Harris Bank Savings Account (Value at separation) $ 392.00
5. Harris Bank Checking Account (Value at separation) $ 362.00
6. Proceeds from the sale of Van $ 6,000.00
7. (H) Teamsters Retirement Approx. $130,122.00
8. (H) American Express Account $ 12,658.00
9. Joint American Express Account $ 5,086.00
10. New Cumberland Federal Credit Union Account $ 753.00
11. (H) Mutual Fund $ 2,421.82
'-'
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12. (H) Whole Life Insurance Policy
Approx.
$ 9,740.57
II. EXPERT WITNESS: None anticipated at this time. Plaintiff reserves the right to
call Harry Leister, F.SA, to update the value of Husband's Defined Benefit Plan
through the Teamsters Union and/or to supplement the Pre-trial Statement as
necessary.
III. FACT WITNESSES: None anticipated at this time other than the parties,
Plaintiff reserves the right to supplement her witness list as necessary,
IV. EXHIBITS: Various documents, including confirmation of balance in the parties'
escrow account, pension statements, bank statements, etc.. Plaintiff reserves the
right to supplement the Pre-trial Statement as necessary.
V. INCOME/EXPENSES: See Plaintiffs Income and Expense Statement.
VI. PENSIONS: Wife has a 401 K Plan and Husband has a Teamsters Retirement
Plan.
VII. COUNSEL FEES AND COSTS: Testimony and exhibits will be presented on the
issue of counsel fees and costs. Husband's previous counsel agreed to settle
the case and Wife spent additional attorneys fees and costs for preparation of the
settlement agreement and a pension valuation through Harry Leister, F.S.S.A.,
including the preparation of a Qualified Domestic Relations Order.
VIII. PERSONAL PROPERTY: Plaintiff believes that all items of personal property
have already been divided to the parties satisfaction but reserves the right to
present testimony regarding the value of furnishings set apart to each party, if
that becomes necessary.
...
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+'^' ' 0' <, """"~",,,:.u,:. '", ';. ,. ".'"~__.
"""'.
IX. MARITAL DEBTS: N/A.
X,
Date:
PROPOSED RESOLUTION: Wife requests a 65/35 distribution and indefinite
alimony. Wife is currently the beneficiary of monthly support (spousal and child)
in the amount of $699.00. Mrs. Miller earns a minimum income and her two part
time positions at JcPenney's and Jack Gaugen Realtors. Mr. Miller's current
earnings are approximately three times that of his Wife. In addition, he has
received a substantial inheritance during separation in the amoun
approximately $42,000.00.
BY:
II!H/b.J.
I ,
-
"?--
,
"~"
"'",' --' "
CERTIFICATE OF SERVICE
I, Charles Rector, Esquire, do hereby certify that on the 19th day of November,
2002, I caused a true and correct copy of the within Plaintiffs Pre-trial Statement to be
served upon the following counsel of record by depositing same in first class, United
States mail, postage paid, in Camp Hill, Pennsylvania:
Sanford A. Krevsky, Esquire
1101 N. Front Street
Harrisburg, PA 17102-3324
Date:
1,1,t/oJ
,
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'" ,",c.o- ~:G..,]"""""';'"
> wr~tli)
I verify that the statements made herein are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.c.S. Section 4904,
relating to unsworn falsification to authorities.
~M~
J9 . ce E. Miller
Date:
i I /;17 ldooi+-
.
,\~.-
'. ~
.
lOa,
Commerce
_Bank
Commerce Bank/Harrisburg N.A.
100 Senate Avenue
Camp Hill. PA 17011
888-937-0004
STATEMENT DATE
ROLAND J MILLER
JANICE E *MILLER'
CHARLES RECTOR ES~Ul:RE ESCROW AGENT
1104 FERNWOOD AVE STE 203
CAMP HILL PA 17011
10/31/0:2
0616226B'12
ACCOUlllT NO.
CYCLE-OS2
~~~~~J~5~~:N:; 09/30/02 ................ ~~~~~~G RA~3. :~:~::~
PLUS 1 DEPOSITS AND OTHER CREDITS ................... . 55.611
LESS 0 WITHDRAWALS AND OTHER DEBITS . . . . . . . . . . . . . . . . .00
CURRENT STATEMENT BALANCE AS OF 10/31/02 ......................... 33,166.011
NUMBER OF DAYS IN THIS STATEMENT PERIOD 31
---------------------------------------------------------------------------------~.-
*** SAVINGS ACCOUNT TRANSACTIONS ***
DATE DESCRIPTION
10/31 INTEREST PAYMENT
DEBITS
CREDITS
55.6B
*** BALANCE BY DATE ***
09/30 33,110.40 10/31
33,166.0B
PAYER FEDERAL ID NUMBER
INTEREST PAID YEAR TO DATE
23-2324730
632.72
*** INTEREST EARNED THIS STATEMENT PERIOD
DAYS IN PERIOD .........................
INTEREST EARNED ........... ... ..........
ANNUAL PERCENTAGE YIELD EARNED (APY)....
***
31
55.6B
2.00%
I\InT6=' SEE REVERSE SIDE: FOR IMPO~TANT INFqR~~TION
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JANICE E. MILLER
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: DOCKET NUMBER 00-6130
ROLAND J. MILLER
Defendant
: CIVIL TERM
ORDER OF COURT
AND NOW, this
day of
, 2003 IT IS HEREBY
ORDERED AND DECREED that a hearing relative to the Modification of Alimony
Pendente Lite be scheduled for the
day of
,2003, at
o'clock
a.m./p,m, in Court Room No._;
BY THE COURT:
Distribution:
Prothonotary
Domestic Relations Office
Sanford A. Krevsky, Esq, IIOI N. Front St., Hbg., PA 17102
Charles Rector, Esq. II04 Femwood Avenue, Suite 203, Camp Hill, PA 17043
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JANICE E. MILLER
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: DOCKET NUMBER 00-6130
ROLAND J. MILLER
Defendant
: CIVIL TERM
PETITION FOR MODIFICATION OF ALIMONY PENDENTE LITE
AND NOW, this d~ day of rrn }Jt.h
,2003, comes the
Defendant, ROLAND J. MILLER, by and through his attorneys, KREVSKY & ROSEN,
P.c. and moves Your Honorable Court to modifY the amount of Alimony Pendente Lite in the
above-captioned matter and, in support thereof, avers the following:
I, Based on the parties' saIaries, an Order of Court was entered on October 17, 2003
ordering Defendant pay $228.00, effective September 7,2000;
2. Since the Order of Court of September 7, 2000 was entered, Defendant had a
decrease in income;
3, Since the Order of Court of September 7, 2000 was entered, the costs of
Defendant's benefit package has increased;
4. Since the Order of Court of September 7,2000 was entered, it is believed that
Plaintiff had an increase in income.
5. Plaintiff has made no attempt to compromise her position for settlement.
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WHEREFORE, Defendant respectfully requests This Honorable Court to schedule a
hearing relative to the modification of the current Alimony Pendente Lite amount.
Respectfully submitted,
KREVSKY & ROSEN, P.C.
By:
Sanford Krevs y, Esquire
Attorney for De endant
1101 North Front Street
Harrisburg, PA 17102
ID #15560
(717) 234-4583
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JANICE E. MILLER
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: DOCKET NUMBER 00-6130
ROLAND J. MILLER
Defendant
: CIVIL TERM
AND NOW, thi~ay of ~C \\
,2003, I, Aimee L Paukovits,
for the Law Firm ofKREVSKY & ROSEN, P.C on behaIf of Defendant, ROLAND J. MILLER
hereby certifY that I have this day served a copy of the foregoing Petition in the above-captioned
matter, by First Class U.S. Mail on the following:
CHARLES RECTOR, ESQUIRE
I 104 FERNWOOD AVENUE
SUITE 203
CAMP HILL, PAl 7043
Wm~ tRRJu QrJ rrn
Aimee L Paukovits
110 1 North Front Street
Harrisburg, PA 17102
(717) 234-4583
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of pennsylvania
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 05/19/03
Tribunal/Case Number (See Addendum for case summary)
o Original Order/Notice
@ Amended Order/Notice
o Terminate Order/Notice
RE: MILLER,
EmployerlWithholder's Federal EIN Nu~be;/
f)I;:! r ~-~ao (!(Plt-
Jlthsrs 07 :7.../o7.?t/cr
/
EXEL LOGISTICS
570 POLARIS PKWY
DEPT 110
WESTERVILLE OH
43082-8029 b1( ~~ :J ~'>C{)
{te;?'C; 161/0:;J-~t,
ROLAND J.
Employee/Obligor's Name (Last, First, MI)
181-42-7553
Employee/Obligor's Social Security Number
9207100587
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania, By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State,
$ 650.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes <29 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 $ 650.00 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:
$ 150.00 per weekly pay period,
$ 300.00 per biweekly pay period (every two weeks).
$ 325.00 per semimonthly pay period (twice a month).
$ 650.00 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 S5% 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 (SeDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SeDU, 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.
DateofOrder:~
VV L>be
Form EN-028
Worker 10 $IAT'r
RY THE COURT'
Service Type M
OMB No.: 0970-0154
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
D I( checked you are required. to provi(le a Copy of this form to your employee, If yo~r employee works in a state that is
different 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 reservation that choose to withhold in accordance with this notice.
2. 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.
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. * Repoltillg tile raydul"t/Date of 'Nitl.l.old;"g. You I {lust lepolt tllI~ paydhte/date of vvithholdil,g vvl.eh selldihg tl.(. paYII.ellL. The
paydate/dat(. of vvitl.l.oldillg is tLe date 0.. vvL;d, unlow.t VVdS vvitl,Ldd f.olll UIC ell,ployee's VVdges. 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/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 #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 return a copy of this Order/Notice to the Agency identified below.
WITHHOLDER'S ID: 0428011600
EMPLOYEE'S/OBlIGOR'S NAME:
EMPLOYEE'S CASE IDENTIFIER:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
MILLER, ROLAND J.
9207100587 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 (1 5 U.s.c. ~1673 (b)l; 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.
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:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P,O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717) 240-6248 or
by internet www.childsupporl.state.pa.us
Page 2 of 2
Form EN-028
Worker ID $IJ~TT
Service Type M
OMS No.: 0970-0154
-
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ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: MILLER, ROLAND J.
PACSES Case Number 072102644
Plaintiff Name
JANrCE E. MILLER
Docket Attachment Amount
00-6130 CIVIL$ 208.00
Child(ren)'s Name(s):
DOB
PACSES Case Number 769102486
Plaintiff Name
JANICE E. MILLER
Docket Attachment Amount
00646 S 2000 $ 442.00
Child(ren)'s Name(s):
CARLY .J... MILLER.
DOB
.. q7/05/~6
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.., ,...... ...... .......
... ,...,,,, "..,........ ....
...... ,. ., ,.. ,... ....
.., ............. . .w, "...,
. d ifch~~k~d, y~~ a~~ required to enroll the chlld(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
D If checked, you are required to enroil 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
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
Addendum
Form EN-028
Worker ID l;IATT
Service Type M
OMB No.: 097Q.0154
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."'~'"'~iffiJ:y
-
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsylvania
CoJCity/Dist. of CUMBERLAND
Date of Order/Notice 05/05/03
Tribunal/Case Number (See Addendum for case summary)
o Original Order/Notice
o Amended Order/Notice
o Terminate Order/Notice
EXEL LOGISTICS
570 POLARIS PKWY
DEPT 110
WESTERVILLE OH 43082-8029
iJ># ~ ..(P/3~ 61//l.
fJ/1Cr;cc ~ 07 d./tJ;J.&~~
RE: MILLER, ROLAND J.
Employee/Obligor's Name (Last, First, MI)
EmployerMtithholder's Federal EIN Number
))k/. b V~ S' ~
j/lf8]f[; Jb'7/o.>y-Rc.
181-42-7553
Employee/Obligor's Social Security Number
9207100587
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMA TlON: 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.
$ 650.00 per month in current support
$ 20.00 per month in past-due support Arrears 12 weeks or greater? Oyes <R> no
$ 0.00 per month in medical support
$ 0 . DOper month for genetic test costs
$ per month in other (specify)
for a total of $ 670.00 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:
$ 154.62 per weekly pay period.
$ 309.23 per biweekly pay period (every two weeks).
$ 335.00 per semimonthly pay period (twice a month),
$ 670.00 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 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 ID (shown
above as the Employee/Obligor's CiiWl\IltafllllJlODft\l SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL. ~
S {fJ -0:3 BY THE COURl
Date of Order:
MAY - 6__
<
JVj)/P15
Form EN-028
Worker ID $IAT'r
~ E (.,UIDO
Service Type M
OMS No.: 0970-0154
;.~lt~'
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."
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" -
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
D I( checkefd you are required. to provi(le a copy of this form to you, employee, If your employee works in a state that is
ditterent rom 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 reservation that choose to withhold in accordance with this notice.
2. 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.
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.' R.p6lting tl,. PA,date/Dat. afWill ,1.6Idi"g, ',oM Iuds! rep6Ittl,~ p.,dateld.t. of ..ill,l,blding ..I ,e!, '" ,dil,g tI,e p',me! ,(. TI..
paydatefdate of yy;Ulholdil,g i3 tile date 01. yyllid, alllOtll1t yY(lS nill,held f101'h tile eI1l1516y~e'; m1ges. 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.
S.' 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 #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 return a copy of this Order/Notice to the Agency identified below.
WITHHOLDER'S ID: 0428011600
EMPLOYEE'S/OBlIGOR'S NAME:
EMPLOYEE'S CASE IDENTIFIER:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
MILLER, ROLAND J.
9207100587 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.s.c. 91673 (b)l; 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.
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.childsupportstate.pa.us
Page 2 of 2
Form EN-028
Worker ID $mTT
Service Type M
OMB No.: 0970-0154
~
.
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ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: MILLER, ROLAND J.
PACSES Case Number 072102644
Plaintiff Name
JANICE E, MILLER
Docket Attachment Amount
00-6130 CIVIL$ 208.00
Child(ren)'s Name(s):
DOB
PACSES Case Number 769102486
Plaintiff Name
JANICE E. MILLER
Docket Attachment Amount
00646 S 2000 $ 462.00
Child(ren)'s Name(s):
CARLY. .J. .. MILL.E.R .
DOB
9.7 1.0~186
[jl~~h~~~~~,y~~~;~r~q~ir~~;~ ~~r~II;~~~hild;;~n; ...... ..... y
identified above in any health insurance coverage available
through the employee's/obligor's employment.
blf~h~~k~~,;~uar~;e~~i;~~;~~~r~II;~~.~~il~(;~~;...... ....
identified above in any health insurance coverage availablle
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
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
Addendum
Form EN-028
Worker ID ~;IATT
Service Type M
OMB No.: 0970--0154
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JANICE E. MILLER,
Plaintiffi'Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
ROLAND J. MILLER,
Defendant/Respondent
NO. 2000-6130 CIVIL TERM
IN DIVORCE
Pacses# 072102644
ORDER OF COURT
AND NOW, this 24'h day of April, 2003, upon consideration of the attached Petition for Alimony
Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear
before RJ. Shaddav onMav 22.2003 at 9:00A.M. for a conference, at 13 N. Hanover St., Carlisle, PA
17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be
entered.
YOU are further ordered to bring to the conference:
"
(1) a true copy of your most recent Federal Income Tax Return, including W - 2' s as filed
(2) your pay stubs for the preceding six (6) months
(3) the Income and Expense Statement attached to this order, completed as reqnired by Rule
1910.11@
(4) verification of child care expenses
(5) proof of medical coverage which you may have, or may have available to you
IF you fail to appear for the conference or bring the required documents, the Court may issue a
warrant for your arrest.
BY THE COURT,
George E. Hoffer, President Judge
Mail copies on
4-24-03 to:
<
Petitioner
Respondent
Sanford Krevsky, Esquire
Charles Rector, Esquire
,j
.0',"'" ~ #
Date of Order: April 24, 2003 J-l .A 4!J{~
~', ,S d y, Conference office1'
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE ~D
REPRESENT YOU. 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 MAY GET
LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVE,
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
C/.' r C,
~~~~.j~~r~!f;M"'_",,,"1il;"~"~l<l~d"''',",,:~"-''iO,,;[jiilillj;:WL';,m'&!.~ill''J"~~";'!",/;+,,..iffi;'~<f~.\V~'I!'""'-'~'lR::_~~lli!iib1l I "'
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COUNSELORS AT LAW
1101 NORTH FRONT STREET
HARRISBURG, PENNSYLVANIA 17102-3324
Sanford A. Krevsky
Lawrence J, Rosen
David J, Schertz
Tel. (717) 234-4583
Fax (717) 234-3650
July 25, 2003
E. ROBERT ELICKER, II, ESQUIRE
OFFICE OF DIVORCE MASTER
9 NORTH HANOVER STREET
CARLISLE, PAl 70 13
Re: Janice E. Miller v. Roland J. Miller
Docket No. 00-6130 Civil Term
Dear Mr. Elicker,
I just received a copy of a letter sent by Charles Rector requesting that a Master's
Hearing be re-convened relative to the above-referenced divorce case. Before doing so, I
am requesting approximately three weeks to review certain discovery information. The
reasons are as follows:
I. We are close to a settlement, but I need to review and/or present to Charles
information regarding two matters:
a. The couple's bank accounts;
b. Mr. Miller's retirement account.
2. I am in the middle of preparations for several trial matters scheduled in
Dauphin County for the week of August 4th.
Once the trials and comparison of the accounts are complete, I believe we can
frame a settlement proposaL There would be no prejudice to Mrs, MWeras my client
continues to pay alimony pendente lite. Finally, I do not want the couple to incur
additional appointment charges or legal fees if settlement is appropriate.
-
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Page 2
Janice E. Miller v. Roland J. Miller
Docket No, 00-6130 Civil Term
July 25, 2003
Accordingly, please do not move forward with the scheduling of a hearing until
approximately mid-August. I will be in touch with Charles and will advise you of our
status,
Thank you for your attention and assistance in this matter. Please confirm reciept
of this request with your response at your earliest convenience. If you have any
questions, please contact my office; until then, I am
Very truly yours,
... ~
Sanford A. Krevsky
SAK:snl
pc: R. Miller
C. Rector, Esq.
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COUNSELORS AT LAW
1101 NORTH FRONT STREET
HARRISBURG. PENNSYLVANIA 17102-3324
Sanford A, Krevsky
Lawrence J. Rosen
David J. Schertz
Tel. (717) 234-4583
Fax (717) 234-3650
July 24, 2003
CHARLES RECTOR, ESQUIRE
1104 FERNWOOD AVENUE
SUITE 203
CAMPHILL,PA 17011-6912
RE: Janice E. Millerv. Roland J, Miller
Docket No, 00-6130 Civil Term
In Divorce
Dear Mr. Rector:
I am in receipt of a letter from your office dated July 18, 2003 stating that you have
re-listed this matter to go before a Master's Hearing. This letter is a request for additional
time to review Ms. Miller's bank records and Mr. Miller's pension. Towards that end, I
am enclosing Mr. Miller's pension valuation. I should be prepared to make any necessary
suggestions regarding the Settlement Agreement within three (3) weeks. As you can see
from the enclosed correspondence to the Divorce Master, I have advised Mr. Elicker of
the case status.
Thank you for your attention and assistance in this matter. If you have any
questions, please contact my office; until then, I am
Very truly yours,
...~
Sanford A. Krevsky
SAK:snl
Enclosure
pc: R. Miller
R, Elicker, Esq. Master
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
,
State Commonwealth of Pennsvlvania
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 10/06/03
Tribunal/Case Number (See Addendum for case summary)
o Original Order/Notice
o Amended Order/Notice
o Terminate Order/Notice
RE: MILLER, ROLAND J.
IV1 ~ I . ~4 Employee/Obligor's Name (last, First, /viI)
U I ~ 1 181-42-7553
rA.. Employee/Obligor's Social Security Number
~ 9207100587
Employee/Obligor's Case Identifier
h 11 (-\ Jf1 (See Addendum for plaintiff names
V U - \fJ v{) associated with cases on attachment)
L,', V .t \ Custodial Parent's Name (Last, First, MI)
See Addendum for dependent names and birth dates associated with c2~ 11~?ci~ ldir 0 {D
ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support ~ t:
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.
$ 650.00 per month in current support
$ 0.00 per month in past-due support
$ 0.00 per month in medical support
$ 0.00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 650.00 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:
$ 150.00 per weekly pay period,
$ 300.00 per biweekly pay period (every two weeks).
$ 325.00 per semimonthly pay period (twice a month).
$ 650.00 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 ofthis
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 #1 a on pg. 2),
EmployerlWithholder's Federal EIN Number
EXEL LOGISTICS
570 POLARIS PKWY
DEPT 110
WESTERVILLE OH 43082-8029
Arrears 12 weeks or greater?
Oyes GQ no
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
~:::;~:~~:en:~ ;:~::I:::~a:: ~~~~ions. I ";i~ }~'W~t
---
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 NUMB ER to BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BY THE COURT:
Date of Order:
~, ~t'"
G U '\ 12)1)
OMB No.: 0970-0154
Form EN-a28
Worker ID $IAT'r
Servi ce Type M
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'> ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
D I((hecked you are required. to provi(ie a copy of this form to your employee, If yo~r employee works in a state that is
dIfferent 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 reservation that choose to withhold in accordance with this notice.
<
2. 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.
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 paymentthat is attributable to each
employee/obligor.
4, * Repoltilog II,e Paydate/D'le "fWitl ,I ,old;"g. '("u n,u,t ,epM tl,e paydat,,"'I... of ..itl,holdi"g ..I,e" ,,,,dilog tl,e Pilyl"C',L The
paydalD'dale of vvitl.l.olel;l,g is tLe dat.::. 011 vvnkL alllouhl m~.:> vvitLLeld rlOl1l lite elllployee's vvageti. 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/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law ofthe state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #10 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 return a copy of this Order/Notice to the Agency identified below.
WITHHOLDER'S ID: 0428011600
EMPLOYEE'S/OBUGOR'S NAME:
EMPLOYEE'S CASE IDENTIFIER:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
MILLER, ROLAND J.
9207100587 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.S.c. 91673 (b)l; 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 taxeSi 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 $I1lTT
Service Type M
OMB No.: 0970-0154
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ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: MILLER, ROLAND J.
PACSES Case Number 072102644
Plaintiff Name
JANICE E. MILLER
Docket Attachment Amount
00-6130 CIVIL$ 208.00
Child(ren)'s Name(s):
DOB
PACSES Case Number 769102486
Plaintiff Name
JANICE E. MILLER
Docket Attachment Amount
00646 S 2000 $ 442.00
Child(ren)'s Name(s):
CARLY.J. ..MIL.L.E.R
DOB
dli~~~:k~(2~~~:;~;~qUired to enroll the C~il~;~~i< .....
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
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's1obligor's employment.
Addendum
Form EN-028
Worker ID ~;IATT
Service Type M
OMB No.: 0970-0154
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
Sto<<e Commonwealth of Pennsvlvania
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 08/07/03
Tribunal/Case Number (See Addendum for case summary)
o Original Order/Notice
@ Amended Order/Notice
.0 Terminate Order/Notice
EXEL LOGISTICS
570 POLARIS PKWY
DEPT 110
WESTERVILLE OH 43082-8029
RE: MILLER, ROLAND J.
01 tI 0 t ~~ ~ Employee/Obligor's Name (last, First, MI)
OO.~I~O (.v'L
EmployerlWithholder's Federal EIN Number
Arrears 12 weeks or greater?
Oyes Q9 no
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 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 SCOU
Send check to: Pennsylvania SCOU, 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.
BY THE COURT:
AUS 0 8 2803
Date of Order:
uAlOV
Form EN-028
Worker ID $IAT~r
Servi ce Type M
OMB No.: 0970-0154
-'
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
D Ifchecked you are required to prpvide a copy of this form to your employee. If your employee works in a state that is
( different 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 iocated on a reservation that choose to withhold in accordance with this notice,
2. Priority: Withholding under this Order/Notice has priority over any other iegal 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.
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
empioyee/obligor.
4. * Ref)OItihg tlte F'aydatelDatc ofV/itLLoldillg. '(ou tIlUS! lepOlt tlte payd~date of yvitl,lloldil,g nheh 5elldihg tile: pClymeht. TLe
paydatefdalG of vvitl.l.oldhl.5;,j Lhe dcrte ,0[, yyl,icL ",IIIQUlll vvas vvitl.l.eld (10111 lite elllployee's yyA~!.. 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
withhold ing 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/obligor and you are unable to honor all support Order/Notices due 10 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 #10 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 requ~sted and return a copy of this Order/Notice to the Agency identified below.
WITHHOLDER'S ID: 0428011600
EMPLOYEE'S/OBUGOR'S NAME:
EMPLOYEE'S CASE IDENTIFIER:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
MILLER, ROLAND J.
9207100587 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, ortaking 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 (1 5 use 91673 (b)l; 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.
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:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
. P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717) 240-6248 or
by internet www.childsupport.state.pa.us
Page 2 of 2
Form EN-028
Worker ID $H'TT
Service Type M
OMB No.: 0970.0154
"
<~ ,i _____~~~
(
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: MILLER, ROLAND J.
PACSES Case Number 072102644
Plaintiff Name
JANICE E. MILLER
Docket Attachment Amount
00-6130 CIVIL$ 228,00
Child(ren)'s Name(s):
DOB
PACSES Case Number 769102486
Plaintiff Name
JANICE E. MILLER
Docket Attachment Amount
006468 2000 $ 442.00
Child(ren)'s Name(s):
CAI<IeyJ ,MILLER.
DOB
dlic~:C~~d, you arer~~~i;~~;~~~;~II;~~Chil~{r~~;i'."'.' .
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
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 availablle
through the employee's/obligor's employment.
Addendum
Form EN-Ol8
Worker ID ~:IATT
Service Type M
OMS No.: 0970-0154
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JANICE E. Mll.LER,
Plaintiffi'Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
ROLAND J. Mll.LER,
DefendantIRespondent
NO. 2000-6130 CIVll. TERM
IN DIVORCE
Pacses# 072102644
ORDER OF COURT
AND NOW, lhis 15th day of August, 2003, a petition has been filed against you, , to modify an
existing Alimony Pendente Lite Order. You are ordered to appear in person at lhe Domestic Relations
Section, 13 North Hanover Street, Carlisle, Pennsylvania, on September 23. 2003 at 9:00 A.M.. for a
conference and to remain until dismissed by lhe Court, If you fail to appear as provided in this Order, an
Order of Court may be entered against you.
You are further ordered to bring to lhe conference:
(I) a true copy of your most recent Federal Income Tax Return, including W-2's as filed
(2) your pay stubs for the preceding six (6) months
(3) lhe Income and Expense Statement attached to this order, completed as required by the Rule
1910.11.
(4) verification of child care expenses
(5) proof of medical coverage which you may have, or may have available to you
IF you fail to appear for the conference or bring lhe required documents, the Court may issue a
warrant for your arrest.
BY THE COURT,
George E. Hoffer, President Judge
Copies mailed
8-15-03 to:<
Petitioner
Respondent
Charles Rector, Esquire
Sanford Krevsky, Esquire
Date of Order: August 15, 2003
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTE THE CONFERENCE AND
REPRESENT YOU. 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 MAY GET LEGAL
HELP,
CUMBERLAND COUNTY BAR ASSOCIATION
2 LlBERTY AVE.
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
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JANICE E. MILLER,
Petitioner/Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-6130 CIVIL TERM
PAcSES NO. 072102644
ROLAND J. MILLER,
Respondent/Defendant
IN DIVORCE
PETITION FOR MODIFlCA nON
OF ALMINOMY PENDENTE LITE
AND NOW, comes the Petitioner, Janice E. Miller, by and throu9h her attorney, Charles
Rector, Esquire, and respectfully represents:
1. Petitioner is Plaintiff, Janice E. Miller.
2. Respondent is Defendant, Roland J. Miller.
3. On October 17,2000, your Honorable Court entered an Order against Respondent in
the amount of $48.00 per week for alimony oendente lite in favor of Plaintiff. A true and correct
copy of the Order is marked Exhibit "A," attached hereto, and made a part hereof,
4. Petitioner is entitled to an increase of this Order because of the following material and
substantial change[s) in circumstance[s):
a. Petitioner's involuntary decrease in income.
b, Respondent's increase in income,
WHEREFORE, Petitioner requests that the Court increase the existing order for alimony
oendente lite.
Date:W
RESPECTFULLY SUBMITTED>
D1~~'1
Charles Rector, Esquire
1104 Femwood Avenue, Ste. 203
Camp Hill, PA 17011-6912
(717) 761-8101
Attorney for Petitioner
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I verify that the statements made herein are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.c.S. Section 4904,
relating to unsworn falsification to authorities.
Qw~7i/;~
. Ice E. Miller
Date: <(; ~7 -03
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PACSES ill 072102644
JANICE E. MILLER,
Plaintiff/Petitioner
vs.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: DOMESTIC RELATIONS SECTION
: CIVIL ACTION - LAW
ROLAND J. MILLER,
Defendant/Respondent
: NO. 00-6130 CNIL TERM
ORDER OF COURT
AND NOW, this 17th day of October, 2000, based upon the Court's determination that
Petitioner's monthly net income/earning capacity is $'1,201.19 per month and Respondent's monthly
net income/earning capacity is $2,521.1 7 per month, it is hereby Ordered that the Respondent pay to
the Pennsylvania State Collection and Disbursement Unit, $228.00 a month payable weekly as
follows; $48.00 per week for alimony pendente lite and $4.62 per week on arrears. First payment due
next pay date at $52.62. Arrears set at $416.00 as of October 17, 2000. The effective date of the
order is September 7,2000.
Failure to make each payment on time and in full will cause all arrears to become subject to
immediate collection by all of the means as provided by 23 Pa.C.S.g3703. Further, if the Court
finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare
the Respondent in civil contempt of Court and its discretion make an appropriate Order, including,
but not limited to, commitment of the Respondent to prison for a period not to exceed six months,
Said money to be turned over by the P A SCDU to: Janice E. Miller. Payments must be made
by check or money order. All checks and money orders must be made payable to P A SCDU and
mailed to:
P A SCDU
P.O. Box 69110
Harrisburg, PA I 7 I06-9 11 0
Payments must include the defendant's PACSES Member Number or Social Security Number in
order to be processed. Do not send cash by mail.
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Respondent to provide medical insurance coverage.
This Order shall become final ten days after the mailing of the notice of the entry of the Order
to the parties unless either party files a written demand with the Prothonotary for a hearing de novo .
before the Court.
DRO: R. 1. Shadday
Mailed copies on
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Petitioner
Respondent
Charles Rector, Esquire
Keirsten Davidson~ Esquire
BY THE COURT,
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JANICE E. MILLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00 - 6130 CIVIL
ROLAND J. MILLER,
Defendant
IN DIVORCE
ORDER OF COURT
AND NOW, this
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day of
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2003, the parties and counsel having entered into an agreement
and stipulation resolving the economic issues on September 18,
2003, the date set for a conference, the agreement and
stipulation having been transcribed, and subsequently signed by
the parties and counsel, the appointment of the Master is
v8cated and counsel can conclude the proceedings by the filing
of a praecipe to transmit the record with the affidavits of
consent of the parties so that a final decree in divorce can be
entered.
BY THE COURT,
Ge
CC: Charles Rector
Attorney for Plaintiff
Sanford A. Krevsky
Attorney for Defendant
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JANICE E. MILLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Vs. NO. 00 - 6130 CIVIL
ROLAND J. MILLER,
Defendant IN DIVORCE
THE MASTER: Today is September 18, 2003.
This is the date set for a conference between counsel and
the parties. Present in the hearing room are the Plaintiff,
Janice E. Miller, and her counsel Charles Rector, and the
Defendant, Roland J. Miller, and his counsel Sanford A.
Krevsky.
This action was commenced by the filing of a
complaint in divorce on September 7, 2000. The complaint
raised grounds for divorce of irretrievable breakdown of the
marriage and the economic claims of equitable distribution,
alimony, alimony pendente lite, and counsel fees and costs.
The parties have signed affidavits of consent
and waivers of notice of intention to request entry of
divorce decree so that the divorce can be concluded under
Section 3301(c) of the Domestic Relations Code. The
affidavits and waivers will be filed with the Prothonotary
by the Master's office.
After negotiations today, which have
continued from prior conferences between the parties, the
Master has been advised that an agreement has been reached
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with respect to the outstanding economic issues. An
agreement is going to be placed on record in the presence of
the parties. The agreement as placed on the record will be
considered the substantive agreement of the parties not
subject to any changes or modifications except for
correction of typographical errors which may be made during
the transcription. The agreement will be sent around to
counsel and the parties for review to make correction of
typographical errors and then affix their signatures
affirming the terms of settlement as stated on the record.
It is understood that the agreement as stated on the record
will be considered the agreement of the parties when they
leave the hearing room today and will not be subject to any
substantive changes or modifications and will be binding
upon the parties even though they do not subsequently sign
the agreement affirming the terms of settlement.
Upon receipt by the Master of a completed
agreement, the Master will prepare an order vacating his
appointment. The agreement will be sent to counsel, as
indicated, to review for typographical errors and then
counsel will be responsible for obtaining the parties'
signatures and returning the document to the Master so that
the Master can then proceed to vacate his appointment and
allow the parties to file a praecipe transmitting the record
to Court requesting a final decree in divorce. Mr. Rector.
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MR. RECTOR:
1. The parties agree that wife shall receive as her
separate assets the following:
Her 401(k) plan with J.C. penneys;
All escrow proceeds currently held for the benefit of
the parties at Commerce Bank;
Her joint 1st Union account;
Her Harris Bank savings account;
Her Harris Bank checking account;
The proceeds received following the sale of the van.
Husband waives any and all interest he may in the
assets awarded to wife.
2. Husband shall receive as his separate assets the
following:
His Teamsters retirement plan, except that portion to
be segregated for a QDRO for the benefits of wife which will
be outlined below;
His American Express account;
Any monies currently held by him in the New Cumberland
Federal Credit Union.
Wife waives any and all interest she may in the assets
awarded to husband except for the Teamsters retirement plan
which shall be distributed as follows:
The parties agree that wife shall receive as her
portion of said Teamsters plan the sum of $58,091.00 and any
and all appreciation which may accrue on the account in
proportion to the amount to be received by wife. A QDRO
shall be prepared by Harry Leister, FSA, to facilitate this
distribution. Husband shall at his cost supplement any
additional fee required by Harry Leister for the completion
of this QDRO and counsel for the parties shall exchange the
QDRO and communicate that to the funds administrator without
delay. The parties acknowledge that Plaintiff, Janice E.
Miller, has utilized the service of Harry Leister previously
for the preparation of a draft QDRO and has satisfied that
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bill. To the extent that any additional costs are incurred
by Mr. Leister, husband agrees to pay any additional costs
that may be due and owing to Mr. Leister. By way of
clarification, most of the QDRO which has already been
drafted will be complemented by the new amounts negotiated
by the parties. We anticipate that any additional costs
will be nominal.
MR. KREVSKY:
Should the full payment be able to be effected through
another vehicle other than a QDRO such as a rollover to an
IRA then the parties authorize the most expeditious,
efficient way to approach that.
MR. RECTOR:
3. Wife waives her entitlement to alimony as part of this
settlement now and in the future. The parties acknowledge
that there is a current order of alimony pendente lite
docketed at 6130 Civil Term of the Domestic Relations
Office. Wife's receipt of alimony pendente lite shall cease
as a matter of law upon the date of the issuance of the
decree in divorce in this case.
4. Wife likewise waives her counsel fee claim.
5. Except as herein otherwise provided, each party may
dispose of his or her property in any way and each party
hereby waives and relinquishes any and all rights he or she
may now have or hereafter acquire under the present or
future laws of any jurisdiction to share in the property or
the estate of the other as a result of the marital
relationship including without limitation, statutory
allowance, widow's allowance, right of intestacy, right to
take against the will of the other, and right to act as
administrator or executor in the other's estate. Each will
at the request of the other execute, acknowledge, and
deliver any and all instruments which may be necessary or
advisable to carry into effect this mutual waiver and
relinquishment of all such interest, rights, and claims.
MR. RECTOR: Mrs. Miller, you've heard me
recite the negotiated agreement on the record, do you have
any questions about what you've heard?
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MRS. MILLER: No.
MR. RECTOR: Are you in agreement with it?
MRS. MILLER: Yes.
MR. RECTOR: You understand as the Master
pointed out to you that having heard that agreement on the
record today, even if the transcript is not signed we have a
binding contract as we sit her today, do you understand
that?
MRS. MILLER: Yes.
MR. RECTOR: Are you satisfied with my
representation in this case?
MRS. MILLER: Yes.
(A discussion was held off the record.)
MR. KREVSKY: Mr. Miller, you've heard the
summary of the terms of the marital settlement agreement
from Mr. Rector, did you understand everything he said?
MR. MILLER: Yes,
MR. KREVSKY: Did you also understand the
comments that were made by the Master and myself concerning
the agreement?
MR. MILLER: Yes.
MR. KREVSKY: Do you understand also that the
terms of the agreement as outlined this morning will be
binding on you and Janice even if it's not signed right now?
MR. MILLER: Yes.
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MR. KREVSKY: And that subsequently if it is
signed by counsel, that would also bind you?
MR. MILLER: Yes.
MR. KREVSKY: Again, as Mr. Rector has
indicated, have you and I had ample opportunity to review
what you believe are the assets and debts of your estate?
MR. MILLER: Yes.
MR. KREVSKY: Do you believe -- are you
satisfied that your wife either to you or through her
attorney has made full disclosure to you of the assets and
liabilities of the estate?
MR. MILLER: Yes.
MR. KREVSKY: And would you agree not to --
if there was something that was missing, do you agree to be
bound by the terms of the agreement nonetheless?
MR. MILLER: Yes.
MR. KREVSKY: And regarding your satisfaction
or dissatisfaction with my services, are you satisfied with
my services?
MR. MILLER: Yes.
I acknowledge that I have read the above
stipulation and agreement, that I understand the terms of
settlement as set forth herein, and that by signing below I
ratify and affirm the agreement previously made and intend
to bind myself to the settlement as a contract obligating
myself to the terms of settlement and subjecting myself to
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the methods and procedures of enforcement which may be
imposed by law and in particular Section 3105 of the
Domestic Relations Code.
WITNESS:
DATE:
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Janice E. Miller
VS.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V ANL~
DIVORCE CML ACTION . LAW
Roland J. Miller
NO. 00-6130
CENTRAL PENNSYLVANIA TEAMSTERS RETIREMENT INCOME PLAN 2000
QUALIFIED DOMESTIC RELATIONS ORDER
I. Identifying Information
1. The Participant is Roland J. Miller.
The Participant's Social Security number is 181-42-7553.
The Participant's address is P.O. Box 3146, Shiremanstown, PA 17011.
2. The Alternate Payee is Janice E. Miller.
The Alternate Payee's Social Security number is 200-36-8051.
The Alternate Payee's address is 1071-15 Lancaster Blvd., Mechanicsburg, PA 17055.
The Alternate Payee's date of birth is July 29, 1954.
3. The parties were married on September 30, 1978, and separated on July 19, 2000.
4. The parties have raised claims of equitable distribution of marital property pursuant to
the Pennsylvania Divorce Code.
II. Method of Dividing Participant's Benefits
1. The Central Pennsylvania Teamsters Retirement Income Plan 2000 shall pay to the
Alternate Payee a portion of the Participant's vested accrued benefit under the Plan.
The Alternate Payee shall receive $58,091.
2. The Fund shall separately account for the benefits awarded in Paragraph 1 of this
Section II as soon as administrable after this Order is determined to be a QDRO. The
Alternate Payee shall be credited with net income, loss or expense from the date this
Order is determined to be a QDRO.
3. The Alternate Payee may elect to receive payment from the Plan in any form in which
benefits may be paid under the Plan to the Participant (other than in the form of a joint
and survivor annuity).
4. The Alternate Payee may select a beneficiary to receive her benefits in the event the
Alternate Payee should die prior to receiving all of her benefits by filing a beneficiary
designation form with the Fund Office. In the event the Alternate Payee should die
prior to receiving benefits, the Plan shall pay benefits to a beneficiary selected by the
Alternate Payee on a beneficiary form provided by the Fund Office on request, or if no
beneficiary is selected, to the Alternate Payee's estate.
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5. The Alternate Payee may elect to receive payment from the Plan at the Participant's
earliest retirement age or, if earlier, at the earliest date permitted under the Plan. For
purposes ofthis paragraph, the Participant's earliest retirement age means the earlier
of (i) the date on which the Participant is entitled to a distribution under the Plan, or
(ii) the later of (a) the date the Participant attains age 50 or (b) the earliest date on
which the Participant could begin receiving benefits under the Plan if the Participant
separated from service.
III. Other Provisions
1. This Order is intended to constitute a qualified domestic relations order within the
meaning of Section 414(p) of the Internal Revenue Code of 1986, as amended and
Section 206(d) of the Employee Retirement Income Security Act of 1974, as amended,
and shall be interpreted in a manner consistent with such intention.
2. The Court shall retain jurisdiction to amend this Order to the extent necessary to
establish or maintain its status as a qualified domestic relations order.
3. It is recognized that the Alternate Payee may elect to connence receiving benefits
before the Participant retires. Ifthe Alternate Payee so requests, the Participant will
cooperate with the Alternate Payee in substantiating a claim or application to the Fund
and shall provide any documentation or information reasonably necessary to establish
their eligibility for benefits.
EXECUTED this /o~ day of rJ ~
,200.3.
Judge
CONSENT TO ORDER:
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsylvania
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 11/17/03
Tribunal/Case Number (See Addendum for case summary)
RE: MILLER, ROLAND J.
Employee/Obligor's Name (Last, First, M!)
o Original Order/Notice
@ Amended Order/Notice
o Terminate Order/Notice
EmployerMlithholder's Federal EIN Number
EXEL LOGISTICS
570 POLARIS PKWY
DEPT 110
WESTERVILLE OH 43082-8029
bt;, c2tXJo -(PI,3./) [71i/IL
PI9('C;'ic" 01:)./0d-& Vcr
181-42-7553
Employee/Obligor's Social Security Number
9207100587
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, Mil
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMA TlON: 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'sfobligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 650.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes (S) 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 $ 650.00 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:
$ 150.00 per weekly pay period.
$ 300.00 per biweekly pay period (every two weeks).
$ 325.00 per semimonthly pay period (twice a month).
$ 650.00 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 SS% of the employee'sf 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 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 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. ~., '....... . '.
." . It: THE COURT:
J~QV ). ~ NUl/I- I ,tJ?; .
E/Xuf./et) t
2Jl) j)t,e
Form EN-028
Worker ID $IAT'r
Date of Order:
Service Type M
QMBNo.:097Q-0154
,L~ ~
'c "~l!U~!
,
-
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o I(checkefd youhare required. to prpville a ,opy of this form to your employee. If your employee works In a state that Is
dIfferent rom testate 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 reservation that choose to withhold in accordance with this notice.
2. 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 piease 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 olthe single payment that Is attributable to each
employee/obligor.
4.* Repoltil,g 1I1e rayaAle/Date of'Nitl.ld>ldillg. You InlHllepal1 tile paydatelclatl of yvitl,lloldil,g yvLel, sehclillg tLe paylllellt. TLe
paydatddAle vf ywitl,l,oldh,g is tile datt 011 yvl,;(L allloullt yvA30 yvitl,l,eld flail I tile elllployi:e's m3,gG&. You must comply with the law of the
state olthe 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: 11th ere 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 folllow
the law of the state of employee's/obligor's principal place of empioyment. 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 return a copy of this Order/Notice to the Agency Identified below.
WITHHOLDER'S 10: 0428011600
EMPLOYEE'S/OBLlGOR'S NAME:
EMPLOYEE'S CASE IDENTIFIER:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
MILLER, ROLAND J.
9207100587 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 beiow.
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 uni,,,s
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 empioy, 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 iaw of the State in which he or she Is employed governs.
10.' Withholdi~g 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)l; 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.
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 Ily:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717) 240-6248 or
by internet www.childsupport.state.pa.us
Page 2 of 2
Form EN-028
Worker ID $Il\TT
Service Type M
OMB No.: 0970-0154
.
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ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: MILLER, ROLAND J.
PACSES Case Number 072102644
Plaintiff Name
JANICE E. MILLER
Docket Attachment Amount
00-6130 CIVIL $ 208.00
Child(ren)'s Name(s):
DOB
BI~.~~~~~:d~;~~~;:;~~~i;~~;~~~;~II;~;~~il~~~~;i.."." .,.'" "
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
D If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's!obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
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 769102486
Plaintiff Name
JANICE E. MILLER
Docket Attachment Amount
00646 S 2000 $ 442.00
Child(ren)'s Name(s):
(:A,RLY J. MIJ:.J:.llR. ,
DOB
" ,...9}/9V8.?
'.b;;~~~~k~~,;~~;r:;~~~.i;~;~ ;~;~II;~~~~ ;;~;;:~) '.'... ..,.. "
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
D If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's!obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
D If checked, you are required to enroll the child(ren)
identified above ilil any health insurance coverage available
through the employee's!obligor's employment.
Service Type M
OMB No.: 0970-0154
Addendum
Form EN-Ol8
Worker ID l;IATT
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HAS BEEN SCANNED.
ALL EARLIER
FILINGS TO THIS
CASE HA VE BEEN
MICROFILMED.
"I
JANICE E. MILLER,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
ROALND J. MILLER,
DefendantJPetitioner
NO. 00-6130 CIVIL TERM
IN DIVORCE
PACSES # 072102644
ORDER OF COURT
AND NOW to wit, this 25th day of January 2007, it is hereby Ordered that, pursuant to
the parties Final Decree of Divorce, the Order for Alimony Pendente Lite is suspended, effective
November 18,2003. There is no balance due the Petitioner.
BY THE COURT:
~
Edward E. Guido,
1.
DRO: R.i. Shadday
xc: Petitioner
Respondent
Marylou Matas, Esq.
.Marlin L. Markley, Esq.
Service Type: M
Fonn OE-OOl
Worker: 21005
,,~
PY$511
, .
Cumberlan? ~ounty Prothonotary's Office
Clvll Case Prlnt
Page
1
2000-06130 MILLER JANICE E (vs) MILLER ROLAND J
Reference No. . :
Case Type. ....: COMPLAINT - DIVORCE
Judgment......: .00
Judge Assigned: GUIDO EDWARD E
Disposed Desc.: GRANTED
------------ Case Comments -------------
Filed........:
Time......... :
Execution Date
Jury Trial. . . .
Disposed Date.
Higher Crt 1.:
Higher Crt 2.:
9/07/2000
2:34
0/00/0000
11/18/2003
********************************************************************************
General Index Attorney Info
MILLER JANICE E
1071-15 LANCASTER BLVD
MECHANICSBURG PA 17055
MILLER ROLAND J
925 SHETTERS LANE
CAMP HILL PA 17011
PLAINTIFF
RECTOR CHARLES
DEFENDANT
KREVS KY SANFORD
********************************************************************************
* Date Entries *
********************************************************************************
9/07/2000
9/26/2000
10/26/2000
10/26/2000
5/13/2002
8/22/2002
8/22/2002
11/14/2002
11/14/2002
11/21/2002
11/21/2002
2/03/2003
3/31/2003
4/25/2003
5/06/2003
- - - - - - - - - - - - - FIRST ENTRY - - - - - - - - - - - -
COMPLAINT - DIVORCE - 3 ADDL COUNTS - EQUITABLE DISTRIBUTION -
ALIMONY - ALIMONY PENDENTE LITE - COUNSEL FEES EXPENSES & COSTS OF
SUIT
-------------------------------------------------------------------
ORDER OF COURT - DATED 9/25/00 - IN RE PETITION FOR ALIMONY
PENDENTE LITE - HEARING BEFORE R J SHADDAY ON 10/17/00 AT 9:00 AM
AT 13 N HANOVER STREET CARLISLE PA HEARING BEFORE GEORGE E HOFFER
PJ COPIES MAILED 9/25/00
-------------------------------------------------------------------
ORDER - DATED 10/18/00 - IN RE NOTICE TO WITHHOLD INCOME FOR
SUPPORT - BY THE COURT EDWARD E GUIDO J COPIES MAILED 10/24/00
-------------------------------------------------------------------
ORDER OF COURT - DATED 10/17/00 - IN RE COURT'S DETERMINATION THAT
PETITIONER'S MONTHLY NET INCOME/EARNING - ORDER SHALL BECOME FINAL
TEN DAYS AFTER MAILING - BY THE COURT EDWARD E GUIDO J - COPIES
MAILED 10/24/00 BY DRO
-------------------------------------------------------------------
PRAECIPE FOR WITHDRAWAL OF APPEARANCE FOR DEFT BY KEIRSTEN W
DAVIDSON ESQ AND ENTRY OF APPEARANCE FOR DEFT BY SANFORD A
KREVSKY ESQ
-------------------------------------------------------------------
MOTION FOR APPOINTMENT OF MASTER BY CHARLES RECTOR ATTY FOR PLFF
-------------------------------------------------------------------
ORDER APPOINTING MASTER DATED 8-22-02 - E ROBERT ELICKER IS
APPOINTED MASTER WITH RESPECT TO ALL CLAIMS - GEORGE E HOFFER PJ -
COPIES MAILED AND ORIG PLACED IN FILE 08-23-02
-------------------------------------------------------------------
INCOME AND EXPENSE STATEMENT OF ROLAND J MILLER
-------------------------------------------------------------------
INVENTORY UNDER RULE 1920.33 - BY ROLAND J MILLER DEFT
-------------------------------------------------------------------
INCOME AND EXPENSE STATEMENT OF PLFF JANICE E MILLER - BY CHARLES
RECTOR ESQ
-------------------------------------------------------------------
PLAINTIFF'S PRE-TRIAL STATEMENT - BY CHARLES RECTOR ESQ FOR PLFF
-------------------------------------------------------------------
PRETRIAL STATEMENT OF DEFT - BY SANFORD KREVSKY ESQ
-------------------------------------------------------------------
PETITION FOR MODIFICATION OF ALIMONY PENDENTE LITE - BY SANFORD A
KREVSKY ESQ FOR DEFT
-------------------------------------------------------------------
ORDER OF COURT - DATED 4/25/03 - IN RE PETITION FOR ALIMONY
PENDENTE LITE OR COUNSEL FEES - IT IS HEREBY DIRECTED THAT THE
PARTIES APPEAR BEFORE R J SHADDAY ON 5/22/03 AT 9:00 AM FOR A
CONFERENCE AT 13 N HANOVER STREET CARLISLE PA - BY THE COURT
GEORGE E HOFFER PJ COPIES MAILED BY DRO 4/24/03
-------------------------------------------------------------------
ORDER - DATED 5/6/03 - IN RE NOTIC ETO WITHHOLD INCOME FOR SUPPORT
- BY THE COURT EDWARD E GUIDO J COPIES MAILED BY DRO
-------------------------------------------------------------------
, t
PY$511
,"
Cumberlanq ~ounty Prothonotary's Office
Clvll Case Prlnt
Page
2
2000-06130 MILLER JANICE E (vs) MILLER ROLAND J
Reference No. . :
Case Type.....: COMPLAINT - DIVORCE
Judgment......: .00
Judge Assigned: GUIDO EDWARD E
Disposed Desc.: GRANTED
------------ Case Comments -------------
9/07/2000
2:34
0/00/0000
11/18/2003
5/20/2003
5/22/2003
8/11/2003
8/11/2003
8/11/2003
9/18/2003
9/18/2003
9/18/2003
9/18/2003
10/09/2003
11/07/2003
11/10/2003
11/14/2003
11/14/2003
11/18/2003
11/18/2003
Filed. . . . . . . . :
Time......... :
Execution Date
Jury Trial. . . .
Disposed Date.
Higher Crt 1.:
Higher Crt 2.:
ORDER - DATED 5/20/03 - IN RE NOTICE TO WITHHOLD INCOME FOR
SUPPORT - BY THE COURT EDWARD E GUIDO J COPIES MAILED
-------------------------------------------------------------------
ORDER - DATED 5/22/03 - IT IS HEREBY ORDERED THAT THE PETITION TO
MODIFY FILED ON 4/24/03 IN THE ABOVE CAPTIONED MATTER IS DISMISSED
WITHOUT PREJUDICE DUE TO THE PETITIONER WITHDRAWING HIS REQUEST
FOR MODIFICATION OF THE ALIMONY PENDENTE LITE ORDER - BY EDWARD E
GUIDO J - COPIES MAILED 5/22/03 BY DRO
-------------------------------------------------------------------
PETITION FOR MODIFICATION OF ALIMONY PENDENTE LITE - BY CHARLES
RECTOR ESQ FOR PETITIONER
-------------------------------------------------------------------
ORDER - DATED 8/8/03 - IN RE NOTICE TO WITHHOLD INCOME FOR SUPPORT
- BY THE COURT EDWARD E GUIDO J COPIES MAILED
-------------------------------------------------------------------
ORDER OF COURT - DATED 8/15/03 - IN RE PETITION FOR MODIFICATION
OF ALIMONY PENDENTE LITE - BY R J SHADDAY CONFERENCE OFFICER -
COPIES MAILED 8/15/03 DRO
-------------------------------------------------------------------
AFFIDAVIT OF CONSENT - DEFENDANT
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIV DECREE-DEFT
-------------------------------------------------------------------
AFFIDAVIT OF CONSENT - PLAINTIFF
-------------------------------------------------------------------
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIV DECREE-PLFF
-------------------------------------------------------------------
ORDER - DATED 10/6/03 - IN RE NOTICE TO WITHHOLD INCOME FOR
SUPPORT - BY THE COURT EDWARD E GUIDO J COPIES MAILED
-------------------------------------------------------------------
ORDER OF COURT 11/07/03 APPOINTMENT OF MASTER IS VACATED AND
COUNSEL CAN CONCLUDE THE PROCEEDINGS BY FILING OF PRAECIPE TO
TRANSMIT AND AFFIDAVITS OF CONSENT OF THE PARTIES - FINAL DECREE
IN DIVORCE CAN BE ENTERED GEORGE E HOFFER P J
COPIES MAILED 11/07/03
-------------------------------------------------------------------
CENTRAL PENNA TEAMSTERS RETIREMENT INCOME PLAN 2000 QUALIFIED
DOMESTIC RELATIONS ORDER - DATED 11/10/03 - BY THE COURT EDWARD E
GUIDO J COPIES MAILED 11/12/03
-------------------------------------------------------------------
PROOF OF SERVICE OF DIVORCE COMPLAINT
-------------------------------------------------------------------
PRAECIPE TO TRANSMIT RECORD
-------------------------------------------------------------------
DIVORCE DECREE ENTERED BY EDWARD E GUIDO J
NOTICE MAILED
-------------------------------------------------------------------
ORDER - DATED 11/18/03 - IN RE NOTICE TO WITHHOLD INCOME FOR
SUPPORT - DATED 11/18/03 - BY THE COURT EDWARD E GUIDO J COPIES
MAILED
- - - - - - - - - - - - - - LAST ENTRY - - - - - - - - - - - -
********************************************************************************
* Escrow Information *
* Fees & Debits Beo Bal Pvmts/Adi End Bal *
*****************************************~******~*******************************
DIVORCE 35.00 35.00 .00
TAX ON CMPLT .50 .50 .00
SETTLEMENT 5.00 5.00 .00
MASTER'S FEE 125.00 125.00 .00
DIV PA SURCHG 10.00 10.00 .00
JCP FEE 5.00 5.00 .00
ADD'L COUNTS 10.00 10.00 .00
JCP FEE 5.00 5.00 .00
ADD'L COUNTS 10.00 10.00 .00
JCP FEE 5.00 5.00 .00
ADD'L COUNTS 10.00 10.00 .00
. .
PYS511
, l
Cumberlan? ~ounty Prothonotary's Office
Clvll Case Prlnt
Page
3
2000-06130 MILLER JANICE E (vs) MILLER ROLAND J
Reference No.. :
Case Type... . .: COMPLAINT - DIVORCE
Judgment......: .00
Judge Assigned: GUIDO EDWARD E
Disposed Desc.: GRANTED
------------ Case Comments -------------
JCP FEE
5.00
5.00
Filed. . . . . . . . :
Time......... :
Execution Date
Jury Trial. . . .
Disposed Date.
Higher Crt 1.:
Higher Crt 2.:
.00
------------
.00
9/07/2000
2:34
0/00/0000
11/18/2003
225.50
225.50
********************************************************************************
* End of Case Information *
********************************************************************************
TRUE COPY FROM RECORD
In Testimony whereof, I h(;re unt? set my hIIId
and the seal of said Court at Carhsle, PI. _
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