HomeMy WebLinkAbout00-07826
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IN THE COURT OF COMMON PLEAS
, OF CUMBERLAND COUNTY
~
STATE OF
DIANA M. SUHR,
Plaintiff
VERSUS
JOHN W. SUHR,
Defendant
AND NOW,
DECREED THAT
AND
PENNA.
NO.
2000-7826 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
DECREE IN
DIVORCE
.,...
2001 , IT IS ORDERED AND
/d-..,
DIANA M. SUHR
JOHN W. SUHR
, PLAINTIFF,
, DEFENDANT,
.
.
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
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The Marriage Settlement Agreement dated January 19, 2001 and signed by
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the parties is hereby incorporated into this Decree, but not merged.
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By THE CO~/L
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DIANA M. SUBR,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION -LAW
2000-7826 CIVIL TERM
JOHN M. SUBR,
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonola1y:
Transmit the record, together with the following information, to the court for entry of a divorce decree:
I. Ground for Divorce: irretrievable breakdown under Section 330 I (c) of the Divorce Code.
2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon
the defendant, John M. Suhr, on November II, 2000, by certified, restricted delivery mail, addressed to him at 20
Fairfield Street, Newville, Pennsylvania 17241, with Return Receipt Number 7099 3400 0018 4997 1704.
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 plaintiff: February 5, 2001; by defendant: February 5, 2001.
(b)(I) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code:
(b )(2) Date of filing and service of the plaintiffs affidavit upon the defendant:
4. Related claims pending: NONE.
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:
(b) Date plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonola1y: February 5, 2001.
Date defendant's Waiver of Notice in
Prothonola1y: February 5, 2001.
filed with the
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DIANA M. SUHR,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000- 7~ CIVIL TERM
JOHN W. SUHR,
Defendant
IN DIVORCE
NOTICE
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 in divorce or annulment may be entered against you by the
court. A judgment may also be entered against you for any other claim or relief requested in
these papers by the plaintiff. You may lose money or property or other rights important to you,
including custody or visitation of your children.
When the ground for divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the Office of
the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION 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, Peunsylvania 17013
717-249-3166
1-800-990-9108
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AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990, For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduled conference or hearing.
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DIANA M. SUHR,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000- 7 jj(, CIVIL TERM
JOHN W. SUHR,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
PURSUANT TO SECTIONS 3301(a)(6) AND 3301(c)
OF THE DIVORCE CODE
COUNT I
AND NOW comes the Plaintiff, Diana M. Suhr, by her attorneys, loon, McKnight &
Hughes, Esquires, and files this Complaint in Divorce against the Defendant, John W. Suhr, upon
the cause of action hereinafter set forth:
1.
The name of the Plaintiff is Diana M. Suhr and the name of the Defendant is John W.
Suhr.
2.
The Plaintiff is an adult individual who resides in Cumberland County, Pennsylvania; her
current address being 225 West North Street, Carlisle, Pennsylvania 17013.
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3.
The Defendant is an adult individual residing in Cumberland County, Pennsylvania, his
current address being 20 Fairfield Street, Newville, Pennsylvania 17241.
4.
The Defendant and Plaintiff have resided in the Commonwealth of Pennsylvania for at
least six months previous to the filing of this action in divorce,
5.
The Defendant and Plaintiff were married on June IS, 1996 in New Cumberland,
Cumberland County, Pennsylvania; and separated on September 2, 2000.
6.
There were no children born to this marriage.
7.
Pursuant to the Divorce Code, Section 330I(a)(6), the Plaintiff avers as the grounds upon
which this action is based that the Plaintiff is the injured spouse and that the Defendant has
offered such indignities to her as to render her condition intolerable and life burdensome,
8.
The Plaintiff avers that she has been advised of the availability of counseling and that said
party has the right to request that the court require the parties to participate in counseling.
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WHEREFORE, the Plaintiff demands judgment
a. Dissolving the marriage between the two parties;
b, Equitably distributing all property, both personal
and real, owned by the parties;
c. for legal fees and costs;
d. for alimony; and
e. for such further relief as your Honorable Court may deem
equitable and just.
COUNT II
9.
The averments of Paragraphs One through Six are incorporated herein by reference as
though fully set forth below.
10.
Plaintiff avers as the grounds upon which the Action in Divorce is based is that the
marriage of the parties is irretrievably broken.
II.
The averments of Paragraph Eight are incorporated herein by reference as though fully set
forth below.
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WHEREFORE, the Plaintiff demands judgment
a. Dissolving the marriage between the two parties;
b. Equitably distributing all property, both personal
and real, owned by the parties;
c. for legal fees and costs;
d, for alimony; and
e. for such further relief as your Honorable Court may deem
equitable and just.
Respectfully submitted,
By:
IRWIN, McKNIGHT & HUGHES
{
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Supreme Court I. D. No. 25476
Date: November 3rd ,2000
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VERIFICATION
The foregoing Complaint in Divorce is based upon information which has been gathered
by my counsel and me in the preparation of this action. I have read the statements made in this
Complaint and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A, Section
4904, relating to unsworn falsification to authorities.
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DIANA M. SUHR
Date: November 3rd .2000
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DIANA M. SUHR,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000- "7 J ;U. CIVIL TERM
JOHNW.SUHR,
Defendant
IN DIVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
The plaintiff, being duly sworn according to law, deposes and says:
1. I have been advised of the availability of marriage counseling and understand that I
may request that the court require that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the Prothonotary's
Office, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: November 3rd ,2000
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DIANA M. SUHR
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DIANA M. SUHR,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-7826 CIVIL TERM
JOHNW.SUHR,
Defendant
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
l. A complaint in divorce under Section 330I(c) of the Divorce Code was filed on
November 3, 2000.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4, I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses ifI do not claim them before a divorce is granted.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsification to authorities.
,2001
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DIANA M. SUHR -
Date: FEBRUARY 5
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DIANA M. SUHR,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-7826 CIVIL TERM
JOHN W. SUHR,
Defendant
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on
November 3, 2000.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4, I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if! do not claim them before a divorce is granted.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsification to authorities.
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Date: FEBRUARY 5
_,2001
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P' JOHN W. SUHR
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DIANA M. SUHR,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-7826 CIVIL TERM
JOHN W. SUHR,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice,
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if 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 immediately after it is filed with the
Prothonotary.
I verify that the statements made in tbis affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C,S, Section 4904 relating to
unsworn falsification to authorities.
Date: FEBRUARY 5
,2001
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DIANA M. SUHR
Plaintiff
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DIANA M. SUHR,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-7826 CIVIL TERM
JOHN W. SUHR,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses ifI do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court
and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verifY that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: FEBRUARY 5
,2001
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/ JOHNW.SUHR
Defendant
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DIANA M. SUHR,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-7826 CML TERM
JOHNW.SUHR,
Defendant
IN DIVORCE
DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT
The defendant, being duIy sworn according to law, deposes and says:
1. I have been advised of the availability of marriage counseling and understand that I
may request that the court require that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the Prothonotary's
Office, which list is available to me upon request.
3, Being so advised, I do not request that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down,
I verifY that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: FEBRUARY 5
,2001
(Ii
r JOHN W. SUHR
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DIANA M. SUHR,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-7826 CIVIL TERM
JOHN W. SUHR,
Defendant
IN DIVORCE
AFFIDAVIT OF SERVICE OF COMPLAINT
PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(i)
COMMONWEALTH OF PENNSYLVANIA
: SS:
COUNTY OF CUMBERLAND
NOW, Marcus A. McKnight, III, Esquire, being duly sworn according to law, does
depose and state:
1. That he is a competent adult and attorney for the plaintiff in the captioned action in
divorce.
2. That a certified copy of the Complaint in Divorce was served upon the defendant, John
W, Suhr, on November 9, 2000, by certified, restricted delivery mail, addressed to him at 20
Fairfield Street, Newville, Pennsylvania 17241, with Return Receipt Number 709934000018
4997 1704.
3. That the said receipt for certified mail is signed and attached hereto and made a part
hereof.
I verifY that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties f 18 Pa. C. S. Section 4904, relating to
unsworn falsification to authorities.
HT, III, ESQUIRE
Date:
FEBRUARY 5
,2001
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DIANA M. SUHR,
PLAINTIFF/PETITIONER
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
IVIL ACTION - LAW
IN DIVORCE
NO. 00-7826 CIVIL TERM
DR # 30226
PACSES # 699102848
JOHN W. SUHR,
DEFENDANT~SPONDENT
PRAECIPE TO WITHDRAW ALIMONY PENDENTE LITE
BY PLAINTIFF. DIANA M. SUHR
TO: Office of Domestic Relations:
The parties have settled all outstanding marital issues, Please withdraw the Petition for
Alimony Pendente Lite and cancel all payments including any wage attachments immediately.
Respectfully, submitted
mWlN, McKNIGHT & HUGHES
Date: January 30, 2001
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SOCIAL SECURITY INFORMATION SHEET
PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1 (a) (3) ALL DIVORCES MUST
INCLUDE THE PARTIES SOCIAL SECURITY NUMBER
PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE
PROTHONOTARY'S OFFICE
DATE: FEBRUARY 5. 2001
DOCKET NUMBER: 2000-7826 CIVIL TERM
PLAINTIFF~SS# 176-54-6916
NAME: DIANA M. SUHR
DEFENDANT~ SS # 210-58-7549
NAME: JOHN W. SUHR
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DR 30,226
PACSES ID 699102848
vs.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: DOMESTIC RELATIONS SECTION
: CIVIL ACTION - LAW
DIANA M. SUHR,
Plaintiff/Petitioner
JOHN W. SUHR,
Defendant/Respondent : NO. 00-7826 CIVIL TERM
ORDER OF COURT
AND NOW, this 27th day of December, 2000, based upon the Court's determination that
Petitioner's monthly net income/earning capacity is $1,343.10 per month and Respondent's monthly
net income/earning capacity is $3,414.73 per month, it is hereby Ordered that the Respondent pay to
the Pennsylvania State Collection and Disbursement Unit, $828.00 per month payable bi-weekly as
follows; $382.15 bi-weekly for alimony pendente lite and $0.00 on arrears. First payment due with
next pay date. Arrears set at $1,656.00 as of December 27,2000. The effective date of the order is
November 6, 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.~ 3703. 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: Diana M Suhr. 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 69110
Harrisburg, PA 17106-9110
Payments must include the defendant's P ACSES Member Number or Social Security Number in order
to be processed. Do not send cash by mail.
lli_l' .~ . ."'''''
,
This Order shall become final ten days after the mailing ofthe 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. J. Shadday
Mailed copies on
/-'2-0/ to: <
~
BY THE COURT,
Petitioner
Respondent
Marcus McKnight, Esquire
Jeanne Costopoulos, Esquire
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
I>a, 00 -7'6?/P (!I {II L-
Slale Commonweallhof pennsylvania jJffe.a:> (fl'l9IO~0f
Co.lCity/Dist. of CUMBERLAND ))fZ 8DJ-;r(p
Date of Order/Notice 12/27/00
Court/Case Number (See Addendum for case summary)
o Original Order/Notice
o Amended Order/Notice
o Terminate Order/Notice
) RE: SUHR, JOHN W.
) Employee/Obligor's Name (Last, First, MI)
) 210-58-7549
) Employee/Obligor's Social Security Number
) 6667100621
) Employee/Obligor's Case Identifier
) (See Addendum for plaintiff names associated with cases on attachment)
) Custodial Parent's Name (last, First, MI)
)
Employe.rlWithholder's Federal EIN Number
RITE AID CORPORATION
Employe.rlWi1hholder's Name
PO BOX 3165
Employe.rlWithholder's Address
HARRISBURG PA 17105-3165
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMA TION: 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'slobligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 828.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes <ID no
$ 0.00 per month in medical support
$ 0.00 per month for genetic test costs
$ per month in other (specify)
for a lolal of $ 828 . 00 per monlh 10 be forwarded 10 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:
$ 191.08 per weekly pay period.
$ 382.15 per biweekly pay period (every two weeks),
$ 414.00 per semimonthly pay period (twice a month).
$ 828 00 per monthly pay period.
REMITTANCE INFORMA TlON:
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 paydateJdate 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.
DRC: RJ Shadday
xc: defen:lant
BY THE COURT:
Date of Order: .Temmry 1 1ml
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Service Type M
OMB No.: 0970.0154
Expiration Date: 12131/00
.JU]:x;E
Form EN-028
Worker 10 $IATT
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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 we levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment
to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to
each employee/obligor.
3. * Repoltil,g diG PayJabdDctb:: of'NitLI.oldillg. '/6..:1 IlIy;,llepolt tLe paydate/date of YV:lI.IIVldillg vvl.eh 3erlJillg tile paylllent. TLt:;;
paydatelJc:.tt v( vvitl.l.oldh.g 15 tile date VII nl r;d. ,,-1!lOW.! vya3 vvitlll161J hallr tile el,lployee'3 vy&g~~. 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 OrderINotices 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. Piease provide the information requested and return a copy of this Order/Notice to the Agency identified below.
WITHHOLDER'S ID: 2319409410
EMPLOYEE'S/OBUGOR'S NAME: SUHR, JOHN W.
EMPLOYEE'S CASE IDENTIFIER: 6667100621 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) 1 ; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWEl. ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxesi Social Security taxesi and Medicare taxes.
10.
'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
Requesting Agency:
DOMESTIC RELATIONS SECTION
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (71 71 240-6225 or
by FAX at 17171 240-6248 or
by Internet @
Page 2 of 2
Form EN-028
Worker ID $IATT
Service Type M
OMS No.: 0970-0154
Expiration Date: 12131/00
,--~~' ,.,~
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ADDENDUM
Summary of Cases on Attachment
JOHN W.
Defendant/Obligor: SUHR,
699102848?O?dt/
PACSES Case Number
Plaintiff Name
DIANA M. BURR
Docket Attachment Amount
00=7'ii"26 cv $ 828.00
Child(ren)'s Name's):
DOB
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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
>tn;~~~~~:~:~~~;;:;~~~;;l~;~:~;~;i;~:t~~;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;;~~l~~~~:;~~:;;;;~~i;~~;~~~;~:;;~.~.'~~:;~i;~~;..'..t>..'..,.....'.
identified above in any health insurance coverage available
through the employee's/obligor's employment.
SelVice Type M
OMB No.: OS7j).1}1 S4
Expiration Date: 12/31/00
~~"^_~ 1 ,mill,"
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s}:
DOB
Bli~~~~~:J:~~~:;~;~;~i;;~;~:~;~:I;~~~~il~i;~~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
o 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.
P ACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
If checked, you are required to enroll the child(ren)
above in any health insurance coverage available
the employee's/obligor's employment.
Addendum
Form EN-028
Worker ID $IATT
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DIANA M. SUHR,
PlaintifflPetitioner
VS.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
JOHN W. SUHR,
.Defendant/Respondent
NO. 00-7826 CIVIL TERM
IN DIVORCE
DR# 30226
PacseS# 699102848
DEMAND FOR HEARING
DATE OF ORDER: December 27,2000
AMOUNT: 828.00 per month
FOR: Alimony Pendente Lite
REASON(S):
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DIANA M. SUHR,
PlaintifflPetitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
JOHN W. SUHR,
Defendant/Respondent
NO. 00-7826 CIVIL TERM
IN DIVORCE
DR# 30,226
Pacses# 699102848
ORDER OF COURT
AND NOW, this I't day of December, 2000, 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 on December 27.2000 at 10:30A.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:
(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) the lncome and Expense Statement attached to this order, completed as required by Rule
191O.l1iD
(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
~90pi~s on
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12'-'1::06(0:.
Petitioner
< Respondent
Marcus McKnight, Esquire
Jeanne Costopoulos, Esquire -:;tj L
Date of Order: December I, 2000 ~,fj-' . v. ~
l\'R, J. adda, C~nf;rence Offi~/ .
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 LffiERTY AVE.
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
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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 Avenue
Carlisle, Pennsylvania 17013
717-249-3166
1-800-990-9108
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the Court, please contact our
office. All arrangements must be made at least 72 hours prior to any hearing or business before the
Court. You must attend the scheduled conference or hearing.
",7-_~-,"5_' -, .",,,_~...., ","",'c'--,. ',_'" "':i\~- ~,_\- - c'''-'_ '_'_'_~'''~'~''''~___,,",'_~' _ ~_. . ~o,.~
DIANA M. SUHR,
Petitioner/Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
v.
CML ACTION - LAW
2000- tJ?)v, CIVIL TERM
JOHN W. SUHR,
llespondentnoefendant
IN DIVORCE
PETITION FOR ALIMONY PENDENTE LITE
AND NOW comes Diana M. Suhr, by and through her attorneys, Irwin, McKnight &
Hughes, and petitions this Honorable Court as follows:
1.
The petitioner/plaintiff is Diana M. Suhr, who currently resides at 225 West North Street,
Carlisle, Cumberland County, Pennsylvania 17013.
2.
The respondent/defendant herein is John W. Suhr who currently resides at 20 Fairfield
Street, Newville, Cumberland County, Pennsylvania 17241.
3.
Petitioner and respondent were married on June 15, 1996, in New Cumberland,
Cumberland County, Pennsylvania and separated on September 2, 2000.
"
4.
Petitioner is without the ability to earn income sufficient to meet her reasonable needs.
WHEREFORE, petitioner, Diana M. Suhr, respectfully requests that this Honorable
Court order alimony pendente lite in an amount equal to the Permsylvania State Support
Gtlidelines.
Respectfully submitted,
IRWIN, McKNIGHT & HUGHES
By:
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, P A 17013-3222
Supreme Court I.D. No. 25476
(717) 249-2353
Date: November 3rd ,2000
2
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VERIFICATION
The foregoing Petition for Alimony Pendente Lite is based upon information which has
been gathered by my counsel and me in the preparation of this action. I have read the statements
made in this Petition and they are true and correct to the best of my knowledge, information and
belief. I understand that false statements herein made are subject to the penalties of 18 Pa.
C.S.A. Section 4904, relating to unsworn falsification to authorities.
.~~~5LJ
DIANA M. SUHR
Date: November 3rd ,2000
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
DIANA M. SUHR ) Docket Number 'O'O'c"l'1l'!a\6/'ev
Plaintiff )
ys. ) PACSES Case Number 699102848 /D30,226
JOHN W. SUHR )
Defendant ) Other State ID Number
ORDER
AND NOW, to wit, on this
31ST DAY OF JANUARY, 2001
IT IS HEREBY
ORDERED that the support order in this case be 0 Vacated or Gi) Suspended or
o Terminated without prejudice or 0 Terminated and Vacated,
effective JANUARY 30, 2001 ,due to:
PLAINTIFF WITHDRAWING HER COMPLAINT FOR ALIMONY PENDENTE LITE. THERE IS NO
BALANCE DUE THE PLAINTIFF AND ALL ARREARS ARE REMITTED.
BY THE COURT:
DRO: RJ Shadday
xc; plaintiff
defendant
Marcus McKnight, Esquire
Jeanne Costopoulos, Esquire
$" .'/. .It..
Kevin Hess
JUDGE
MAILED
;;"-&-01
~
Form OE-504
Worker ID 21005
Service Type M
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsylvania ,~~_
Co.lCity/Dist. of CUMBERLAND PACSES 699102848
Date of Order/Notice 01/31/01 DR 30,226
Court/Case Number (See Addendum for case summary)
o Original Order/Notice
o Amended Order/Notice
@ Terminate Order/Notice
) RE: SUHR, JOHN W.
) Employee/Obligor's Name (Last, First, MI)
) 210-58-7549
) Employee/Obligor's Social Security Number
) 6667100621
) Employee/Obligor's Case Identifier
) (See Addendum 10, plaintiff names associated with cases on attachment)
) Custodial Parent's Name (Last, First, MI)
)
EmployerlWithholder's Federal EIN Number
RITE AID CORPORATION
EmployerlWithholder's Name
PO BOX 3165
EmployerlVVithholder's Address
HARRISBURG PA 17105-3165
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMA TION: 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'slobligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 0.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes Q9 no
$ 0.00 per month in medical support
$ 0.00 per month for genetic test costs
$ per month in other (specify)
fo r a total of $ 0 . 00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 0.00 per weekly pay period.
$ 0.00 per biweekly pay period (every two weeks).
$ 0.00 per semimonthly pay period (twice a month).
$ 0.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate!date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee'sl 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/EDt, 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 10 (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:
DRO: RJ Shadday
xc; defendant d. -& -0
0(j
Februar:\' 1, 2001
Date of Order:
~. 44
. !less
.JUIX;E
Form EN-028
Worker 10 21005
Service Type M
OMS No.: 0970-0154
Expiration Date: 12/31/00
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If checked you are required to provide a copy of this form to your employee.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment
to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to
each employee/obligor.
3."" Repv, l; IIg ti,t!; l'aydGltdDate of\V;t\ll.vldillg. You IlItbt lc:pOlt tire:; I-'d)'dahdddte of vvitLLoldilig v\fl.d, ;:,,:;;hd;I'5 'eLl:: papllc:llt. 11.1::
paydAtelJah: of niU,Loldihg is tile date 01. vvl.klr al.,Otll,t HaS "vitl,I,eld hVII. tLe. el'll-'loyee's vvages. 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's1obligor'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.
WtTHHOLDER'S tD: 2319409410
EMPLOYEE'S/OBlIGOR'S NAME: SUHR. JOHN W.
EMPLOYEE'S CASE IDENTIFIER: 6667100621 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: t) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.S.c. 91673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxesj and Medicare taxes.
10.
"NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
Requesting Agency:
DOMESTIC RELATIONS SECTION
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 (17) 240-6248 or
by Internet @
Page 2 of 2
Form EN-028
Worker ID 21005
Service Type M
OMBNo.:0970-o154
Expiration Date: 12/31/00
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~
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: SUHR, JOHN W.
PACSES Case Number 699102848
Plaintiff Name
DIANA M. SUHR
Docket Attachment Amount
00=7'ii26 CV $ 0.00
Child(ren)'s Name(s):
DOB
.El:i~~~~~~~:';~~~;~;;;~:;;~;~:~;~:,;~~~~i,~;;:~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
Olf checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's1obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
ai;~~~~~~d:;~~~;~:;~~~i;:j;;~~r~";~:~~:'~;;:~;(
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Service Type M
PACSES Case Number
Plai ntiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
If checked, you are required to enroll the child(ren)
above in any health insurance coverage available
employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
b;;~~~~~;~:;~~~;:;:~~:;:~;~:~;;I:;~:~~il~;;:~;i'."'..,.................
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
~ Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
1S:;~~;~~:~:;~~~;~;~~~i;~~;~;~;~:i;~:~~ii~i;:~;.}
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Addendum
Form EN-028
Worker ID 21005
OMBNo.:0970.o154
Expiration Date: 12/31/00
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DIANA M. SUHR,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-7826 CIVIL TERM
JOHN W. SUHR,
Defendant
IN DIVORCE
NOTICE OF INTENTION TO
RETAKE AND USE PRIOR NAME
I, DIANA M. SUHR, hereby give notice, avowing my intention to resume and hereafter
use my prior surname, to wit: DIANA M. GUSTIC, in accordance with the provisions of the
Act of December 16, 1982, P.L. 1309, No. 295, Section 704(a) (54 Pa. C.S.A. 704(a). My
divorce, docketed to 2000-7826 Civil Term, was granted on February 8th
, 2001.
I verifY that the statements made in this document are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
IN WITNESS WHEREOF, I have hereunto set my hand and seal this
'lY'otMM aj' 2001.
qC/l-- day of
WITNESSED:
\,flh/Y .Lru_o( yJrJN)d~.J
~~J (SEAL)
DIANA M. SUHR
T~ KNO~ AS:(jJ
'~llltL (SEAL)
DIANA M. GUSTIC
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, this -* day of
a Notary Public, in and for the Commonwealth of Pennsylvania and County of C
DIANA M. SUHR, known to me (or satisfactorily proven) to be the person whose name is
subscribed to the within Notice of Intention to Retake and Use Prior Name, and acknowledges
that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
Notarlal Seal .
Martha L. Noel, Notary Public
Ctrllele BOlO, Cumberland County
My Oommllllon EKplres Sept. 18, 2003
eM t, nnlylvanle ASaOCIstion 01 Noterles
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