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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
DONNA N. FEALTMAN,
Plaintiff
NO. 2000-8044
CIVIL
VERSUS
GUERN W. FEALTMAN,
Defendant
.
.
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DECREE IN
DIVORCE
AND NOW,
f0DIJ S.
.
, 2004" IT IS ORDERED AND
DECREED THAT DONNA N. FEALTMAN
, PLAINTIFF,
.
.
GUERN W. FEALTMAN
, DEFENDANT,
AND
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;
.
.
THE MARRIAGE SETTLEMENT AGREEMENT DATED OCTOBER 22, 2004 IS
HEREBY INCORPORATED INTO THIS DECREE IN DIVORCE.
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By THE CO~
ATTES
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PROTHONOTARY
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1'Li:J. on. ?04V
MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT made this~ day of (f)~ ,2004, by
and between GUERN FEALTMAN, (hereinafter referred to as "Husband")
and DONNA N. FEALTMAN, (hereinafter referred to as "Wife").
WITNESSETH:
WHEREAS, the Husband and Wife were lawfully married on
November 16, 1979; and
WHEREAS, differences have arisen between Husband and Wife in
consequence of which they intend to live apart from each other; and
WHEREAS, Husband and Wife desire to settle and determine their
rights and obligations; and
WHEREAS, the parties hereto have mutually entered into an
agreement for the division of their jointly-owned assets, the
provisions for their liabilities and provisions for the resolution
of their mutual differences, after both have had free and ample
opportunity to consult with their respective attorneys, and the
parties now wish to have that agreement reduced to writing; and
NOW, THEREFORE, the parties intending to be legally bound
hereby do covenant and agree as follows;
1. SEPARATION
It shall be lawful for each party at all times hereafter
to live separate and apart from the other party at such place or
places as he or she may from time to time choose or deem fit. The
foregoing provisions shall not be taken as an admission by either
party as to the lawfulness or unlawfulness of the causes leading to
their living apart.
2. INTERFERENCE
Each party shall be free from interference, authority,
and contact by the other as fully as if he or she were single and
unmarried except as maybe necessary to carry out the provisions of
the agreement. Neither party shall molest the other nor attempt to
endeavor to molest the other, nor compel the other to cohabit with
the other, or in any way harass or malign the other, nor in any way
interfere with the peaceful existence, separate and apart from the
other.
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3. DIVISION OF PERSONAL PROPERTY
The parties have equitably divided between them to their
mutual satisfaction the personal affects, household furniture and
furnishings and all other articles of personal property which
heretofore have been used by them in common. Husband agrees to pay
wife $500.00, payable bi-weekly at $100.00, full payment must be
completed by December 31, 2004.
4 . AUTOMOBILES
Each party is to keep their respective vehicles. Husband
shall have all right and title to his vehicles. He shall maintain
insurance on his vehicles and be responsible for all maintenance,
liens and other payments related thereto. Husband shall indemnify
and hold Wife harmless for all matters related to his vehicles.
Wi fe shall have all right and title to her vehicles and shall
maintain insurance on her vehicles and be responsible for all
maintenance. Wife shall indemnify and hold Husband harmless for
all matters related to her vehicles.
5. DIVISION OF REAL PROPERTY
The real estate owned by the parties has ben sold and the
deficiency was paid by the Husband.
6. FINANCIAL ACCOUNTS, STOCKS, BONDS AND INVESTMENTS
The parties have equitably divided their respective
financial accounts and other investments. Each party shall
maintain their separate accounts and investments and hereby release
any interest they may have in the other's accounts or investments.
7. MARITAL DEBTS
Husband shall be responsible for all debts solely in his
name and Wife shall be responsible for all debts solely in her
name. Each party agrees to indemnify and hold the other harmless
for any debt for which they are responsible for pursuant to this
Agreement. Husband has no further obligation on the former joint
Consumer Credit account. Wife shall have sole responsibility for
the payments on the account and take the necessary action to remove
Husband from the account. Husband agrees to remove Wife from the
DAFCU account as quickly as possible.
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8. PENSION AND RETIREMENT ACCOUNTS
Husband and Wife shall maintain their separate pension
and/or retirement accounts. Husband agrees that, through a QDRO,
Wife shall receive a prorated amount of his Federal monthly
pension/retirement determined under the following formula:
Husband's monthly benefit
X a coverture fraction with the numerator being 17
years and the denominator being the total number of
years of service credited to Husband at the time of
his retirement.
X 35%
wife's benefit amount.
Example:
H's benefit X 17
Total years
X .35 = Wife's benefit
Wife shall be responsible for the preparation of the required
QDRO and shall be liable for all costs incurred for the QDRO.
Husband relinquishes all right and interest he may have in Wife's
pension or retirement accounts. The parties agree to cooperation
wi th each other to obtain all information required to secure a
QDRO.
9. SPOUSAL SUPPORT/ALIMONY/ALIMONY PENDENTE LITE
Husband currently pays Wife $128.77 bi-weekly for APL.
Husband agrees to the conversion of Wife's APL to alimony upon
issuance of a Decree in Divorce. The parties agree that Wife's
alimony shall terminate on December 31, 2004. After December 31,
2004, Husband's alimony obligation to Wife shall terminate.
Pursuant to the Divorce Code, alimony shall also terminate upon the
death of either party or the marriage of Wife. Except as provided
in this Agreement, each party hereby waives, releases, discharges
and gives up any rights either may have against the other to
receive support, alimony pendente lite or alimony.
10. FILING OF IRS RETURN
Husband and Wife shall file separate tax returns.
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11. DIVORCE
The parties agree to cooperate with each other in
obtaining a final divorce of the marriage that Husband has filed
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In the Cumberland County Court of Common Pleas, docketed at 2000-
8044 CIVIL TERM. Upon execution of this agreement the parties
shall sign and allow to be filed the documents necessary to obtain
an uncontested no-fault divorce.
12. ATTORNEY FEES
Each party shall be responsible for their respective
attorney fees and costs.
13 . INCORPORATION
This agreement is to be incorporated into any subsequent
Decree in Divorce.
14. CONTINUED COOPERATION
The parties agree that they will wi thin fifteen days
after the execution of this agreement, or request of the other
party, execute any and all written instruments assignments,
releases, deeds or notes or other writings as may be necessary or
desirable for the proper effectuation of this agreement.
15. VOLUNTARY AGREEMENT
The provisions of this agreement are fully understood by
both parties and each party acknowledges that the agreement is fair
and equitable, that it is being entered into voluntarily, and that
it is not the result of any duress or undue influence. Each
parties has had the opportunity to review this agreement and their
legal rights with an attorney.
16. WAIVER OF CLAIMS AGAINST ESTATES
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,
dower, curtesy, statutory allowance, widows allowance, right to
take in intestacy, right to take against the will of the other and
the right to act as administrator/executor of the other's estate.
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17. FULL AND FAIR DISCLOSURE
The parties hereby warrant that there has been full and fair
disclosure to the other of his or her income, assets and
liabilities, whether such are held jointly or in the name of one
party alone, and each party agrees that any right to further
disclosure, valuation, enumeration or statement hereof in this
Agreement is hereby specifically waived.
18 . BREACH
If either party breaches any provision of this agreement,
the other party shall have the right, at his or her election, to
sue for damages for such breach, and the party breaching this
contract shall be responsible for the payment of legal fees and
costs incurred by the other in enforcing their rights under this
agreement or for seeking such other remedies or relief as may be
available to him or her.
19. BINDING AFFECT
This agreement shall be binding upon the parties' heirs,
successors and assigns.
20. MODIFICATION AND WAIVER
Any modification or waiver of any of the provisions of
this agreement shall be effective only if made in writing and
executed with the same formalities as this agreement. The failure
of either party to insist upon strict performance of any of the
provisions of this agreement shall not be construed as a waiver of
any subsequent default of the same or similar nature.
21 . PRIOR AGREEMENTS
It is understood and agreed that any prior agreements
which may have been made or executed or verbally discussed prior to
the date and time of this agreement are null and void.
22. ENTIRE AGREEMENT
This agreement contains the entire understanding of the
parties and there are no representations, warranties, covenants or
undertakings other than those expressly set forth herein.
23. DESCRIPTIVE HEADINGS
The descriptive headings used herein are for convenience
only. They shall not have any binding affect whatsoever in
determining the rights or obligations of the parties.
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24. APPLICABLE LAW
This agreement shall be construed under the laws of the
Commonwealth of Pennsylvania.
IN WITNESS WHEREOF, the parties set their hands and seals
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uern W. Fealtman
J/!;';e QHL2Y
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Date'
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N. Fealtman
Commonwealth of Pennsylvania
ss
County of C.l~A~
PERSONALLY APPEARED BEFORE ME, this /:J ~ay of O~, 2004,
a notary public, in and for the Commonwealth of Pennsylvania, Guern
W. Fealtman, known to me (or satisfactorily proven to be) the
person whose name is subscribed to the wi thin agreement and
acknowledged that he executed the same for the purposes herein
contained.
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No ary c8~";; OF PENNSYLVANIA
NolaIfaI Seal
l.eoIa M. Gould, Notary PublIc
ShIremanstnwn IloIo, Cumberland County
My Commission ExpInosApr. 29, 2008
Member, Ponnsylvonla Asaocliltlon or Notaries
State of North Carolina
County of
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ss
PERSONALLY APPEARED BEFORE ME, thisAiC.day of (}~ , 2004,
a notary public, in and for the state of North Carolina, Donna N.
Fealtman, known to me (or satisfactorily proven to be) the person
whose name is subscribed to the within agreement and acknowledged
that she executed the same for the purposes ere in contained.
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DONNA N. FEALTMAN,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERL1\ND COUNTY, PENNSYLVANIA
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v.
NO. 2000 - 8044 CIVIL TERM
GUERN W. FEALTMAN,
DEFENDANT
IN DIVORCE
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PRAECIPE TO TRANSMIT RECORD
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To the Prothonotary:
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Transmit the record, together with the following information,
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to the Court for the entry of a divorce decree:
1. Ground for divorce: irretrievable breakdown under Section
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3301(c) of the Divorce Code.
2.
Date and manner of service of the complaint: On November
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3.
Date of execution of the affidavit of consent required by
t;'
Section 3301 (c) of the Divorce Code: By Plaintiff, October 22,
2004; By Defendant, October 28, 2004.
4.
Related claims pending:
None
5. Date Plaintiff's Waiver of Notice in ~ 3301(c) divorce
was filed with the Prothonotary on October 28, 2004.
Date Defendant's Waiver of Notice in ~ 3301(c) divorce
was filed with the Prothonotary on October 28, 2004.
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Thomas D. Gould, Esquire
Attorney For Defendant
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DONNA N. FEAL TMAN,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2000- row
CIVIL TERM
GUERN W. FEAL TMAN,
Defendant
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims set forth in the foregoing
pages, you must take prompt action. You are warned that if you fail to do so, the case may
proceed without you and a decree in divorce or annulment may be entered against you by the court.
A judgment may also be entered against you for any other claim or relief requested in these papers
by the plaintiff. You may lose money or property or other rights important to you, including custody
or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you
may request marriage counseling, A list of marriage counselors is available in the Office of the
Prothonotary at:
Office of the Prothonotary
Cumberland County Court House
1 Courthouse Square
Carlisle, Pennsylvania 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR
EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO
CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone: (717) 249-3166
1
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DONNA N. FEAl TMAN,
Plaintiff
11')1 THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVil ACTION - lAW
NO. 2000- 'i6<f'f
CIVil TERM
GUERN W. FEAlTMAN,
Defendant
IN DIVORCE
NOTICE OF AVAilABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court
of Common Pleas of Cumberland County. This notice is to advise you that in accordance with
Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse
to attend marriage counseling prior to a divorce being handed down by the court. A list of
professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover
Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you
are not bound to choose a counselor from this list. All necessary arrangements and the cost of
counseling sessions are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling within twenty
days of the date on which you receive this notice. Failure to do so will constitute a waiver of your
right to request counseling.
2
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DONNA N. FEAL TMAN,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2000- if/) '1'1
CIVIL TERM
GUERN W. FEALTMAN,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, DONNA N. FEAL TMAN, by her attorney,
Samuel L. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is DONNA N. FEAL TMAN, an adult individual who currently resides at 417
Garden Drive, Mechanicsburg, Cumberland County, Pennsylvania.
2. The Defendant is GUERN W. FEAL TMAN, an adult individual who currently resides at
140 Lancaster Boulevard, Mechanicsburg, Cumberland County, Pennsylvania.
3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of
Pennsylvania for at least six months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on 16 November 1979 in Enola, Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. This marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may
have the right to request that the Court require the parties to participate in counseling.
COUNT I
8. The Plaintiff requests this Court to enter a Decree of Divorce.
3
II
WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to the
Divorce Code of Pennsylvania.
COUNT II - EQUITABLE DISTRIBUTION
9. During the course of the marriage, the parties have acquired numerous items of property,
both real and personal, which are held in joint names and in the individual names of each of the
parties hereto.
WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the
Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as
marital property.
COUNT III - ALIMONY
10. Plaintiff lacks sufficient property to provide for her reasonable needs in accordance with
the standard of living of the parties established during the marriage.
11. Plaintiff is unable to support herself in accordance with the standard of living of the
parties established during the marriage through appropriate employment.
12. The Defendant is employed and enjoys a substantial income from which he is able to
contribute to the support and maintenance of Plaintiff and to pay her alimony in accordance with
the Divorce Code of Pennsylvania.
WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding Plaintiff from
Defendant permanent alimony in such sums as are reasonable and adequate to support and
maintain Plaintiff in the station of life to which she has become accustomed during the marriage.
COUNT IV - ALIMONY PENDENTE LITE
13, Plaintiff is without sufficient income to support and maintain herself during the
pendency of this action.
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14. Defendant enjoys a substantial income and is well able to contribute to the support and
maintenance of Plaintiff during the course of this action.
WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her reasonable
alimony pendente lite during the pendency of this action.
COUNT V - COUNSEL FEES AND EXPENSES
15. Plaintiff is without sufficient funds to retain counsel to represent her in this matter.
16. Without competent counsel, Plaintiff cannot adequately prosecute her claims against
Defendant and cannot adequately litigate her rights in this matter.
17. Defendant enjoys a substantial income and is well able to bear the expense of Plaintiff's
attorney and the expenses of this litigation.
WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay the legal fees
and expenses incurred by Plaintiff in the litigation of this action.
I verify that the statements made in this Complaint are true and correct. I understand that
any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn
falsification to authorities).
DATE:
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~ Andes
Attorney for Plaintiff
Supreme Court ID 17225
525 North 12th Street
Lemoyne, PA 17043
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DONNA N. FEALTMAN,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2000 - 8044 CIVIL TERM
GUERN W. FEALTMAN,
DEFENDANT
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the
Divorce Code was filed on November 14, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of the
filing and service of the Complaint.
3. I consent to the entry of a Final Decree of Divorce after
service of notice of intention to request entry of the decree. I
acknowledge that pursuant to Rule 1920.42(e) I have waived the
requirement that I receive notice of intention to request entry of
",
the decree.
I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein are subject
to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
DATED:
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DONNA N. FEALTMAN,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2000 - 8044 CIVIL TERM
GUERN W. FEALTMAN,
DEFENDANT
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 330l(c) of the
Divorce Code was filed on November 14, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of the
filing and service of the Complaint.
3. I consent to the entry of a Final Decree of Divorce after
service of notice of intention to request entry of the decree. I
acknowledge that pursuant to Rule 1920.42 (e) I have waived the
requirement that I receive notice of intention to request entry of
the decree.
I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein are subject
to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
DATED:
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GUERN W. FEALTMAN
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DONNA N. FEALTMAN,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2000 - 8044 CIVIL TERM
GUERN W. FEALTMAN,
DEFENDANT
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(0) OF THE DIVORCE CODE
1. I consent to the entry of a final decree 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 this Affidavit are true
and correct. I understand that false statements herein are subject
to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
DATED:
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DONNA N. FEALTMAN,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY i PENNSYLVANIA
v.
NO. 2000 - 8044 CIVIL TERM
GUERN W. FEALTMAN,
DEFENDANT
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(0) OF THE DIVORCE CODE
1. I consent to the entry of a final decree 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 this Affidavit are true
and correct. I understand that false statements herein are subject
to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
DATED:
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DONNA N. FEAL TMAN,
PLAINTIFF
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2000-8044 CIVIL TERM
GUERN W, FEALTMAN,
DEFENDANT
IN DIVORCE
ACCEPTANCE OF SERVICE
GUERN W. FEAL TMAN, does hereby accept service of the Divorce Complaint filed
against him in this matter and acknowledges receipt of a certified copy of that Complaint.
Date: II /.;}o/?1~
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DONNA N. FEALTMAN,
Plaintiffi'Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
GUERN Q. FE ALTMAN,
DefendantJRespondent
NO. 00-8044 CIVIL TERM
IN DIVORCE
DR# 30496
Pacses# 896103125
ORDER OF COURT
AND NOW, this 9"' day of March, 2001, 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 R.J. Shaddav onADril4. 2001 at 9:00 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA
17013, after which the conference officer may reconunend 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 Income and Expense Statement attached to this order, completed as required by Rule
1910.IW
(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
3-9-01 to:
Petitioner
< Respondent
Samuel Andes, Esquire
Date of Order: March 9. 2001
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 AVE.
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
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DONNA N. FEAL TMAN,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2000-8044 CIVIL TERM
GUERN W. FEAL TMAN,
Defendant
IN DIVORCE
MOTION FOR ALIMONY PENDENTE LITE
AND NOW comes the above-named Plaintiff, Donna N. Fealtman, by her attorney,
Samuel L. Andes, and moves the court to schedule a conference at the Domestic Relations
Office and, if necessary, a hearing before the Court on her claim for Alimony Pendente lite,
as raised in Count IV of the Divorce Complaint which she filed in this matter on 14
November 2000, a copy of which is attached hereto.
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Attorney for Plaintiff
Supreme Court ID # 17225
525 North 12th Street
Lemoyne, PA 17043
(717) 761-5361
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DONNA N. FEALTMAN,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2000-9i1'11f
CIVIL TERM
GUERN W. FEAL TMAN,
Defendant
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims set forth in the foregoing
pages, you must take prompt action. You are warned that if you fail to do so, the case may
proceed without you and a decree in divorce or annulment may be entered against you by the court.
A judgment may also be entered against you for any other claim or relief requested in these papers
by the plaintiff. You may lose money or property or other rights important to you, including custody
or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the I:l)arri,<ige, y_ou
may request marriage counseling. A list of marriage counselors is available in the ~ice 'Or the,':
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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.
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Office of the Prothonotary
Cumberland County Court House
1 Courthouse Square
Carlisle, Pennsylvania 17013
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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.
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Telephone: (717) 249-3166
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DONNA N. FEAL TMAN,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2000-
CIVIL TERM
GUERN W. FEAL TMAN,
Defendant
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court
of Common Pleas of Cumberland County. This notice is to advise you that in accordance with
Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse
to attend marriage counseling prior to a divorce being handed down by the court. A list of
professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover
Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you
are not bound to choose a counselor from this list. All necessary arrangements and the cost of
counseling sessions are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling within twenty
days of the date on which you receive this notice. Failure to do so will constitute a waiver of your
right to request counseling.
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DONNA N. FEALTMAN,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2000-
CIVIL TERM
GUERN W. FEALTMAN,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, DONNA N. FEALTMAN, by her attorney,
Samuel L. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is DONNA N. FEAL TMAN, an adult individual who currently resides at 417
Garden Drive, Mechanicsburg, Cumberland County, Pennsylvania,
2. The Defendant is GUERN W. FEAL TMAN, an adult individual who currently resides at
140 Lancaster Boulevard, Mechanicsburg, Cumberland County, Pennsylvania.
3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of
Pennsylvania for at least six months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on 16 November 1979 in Enola, Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. This marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may
have the right to request that the Court require the parties to participate in counseling.
COUNT I
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8. The Plaintiff requests this Court to enter a Decree of Divorce.
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WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to the
Divorce Code of Pennsylvania.
COUNT II - EQUITABLE DISTRIBUTION
9. During the course of the marriage, the parties have acquired numerous items of property,
both real and personal, which are held in joint names and in the individual names of each of the
parties hereto.
WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the
Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as
marital property.
COUNT III - ALIMONY
1 O. Plaintiff lacks sufficient property to provide for her reasonable needs in accordance with
the standard of living of the parties established during the marriage.
11. Plaintiff is unable to support herself in accordance with the standard of living of the
parties established during the marriage through appropriate employment.
12. The De'fendant is employed and enjoys a substantial income 'from which he is able to
contribute to the support and maintenance of Plaintiff and to pay her alimony in accordance with
the Divorce Code of Pennsylvania.
WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding Plaintiff from
Defendant permanent alimony in such sums as are reasonable and adequate to support and
maintain Plaintiff in the station of life to which she has become accustomed during the marriage.
COUNT IV - ALIMONY PENDENTE LITE
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14. Defendant enjoys a substantial income and is well able to contribute to the support and
maintenance of Plaintiff during the course of this action.
WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her reasonable
alimony pendente lite during the pendency of this action.
COUNT V - COUNSEL FEES AND EXPENSES
15. Plaintiff is without sufficient funds to retain counsel to represent her in this matter.
16. Without competent counsel, Plaintiff cannot adequately prosecute her claims against
Defendant and cannot adequately litigate her rights in this matter.
17. Defendant enjoys a substantial income and is well able to bear the expense of Plaintiff's
attorney and the expenses of this litigation.
WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay the legal fees
and expenses incurred by Plaintiff in the litigation of this action.
I verify that the statements made in this Complaint are true and correct. I understand that
any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn
falsification to authorities).
DATE:
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Supreme Court ID 17225
525 North 12th Street
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DR 30496
PACSES In 896103125
DONNA N. FEALTMAN,
Plaintiff/Petitioner
vs.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNfY, PENNSYLVANIA
: DOMESTIC RELATIONS SECTION
: CIVIL ACTION - LAW
GUERN Q. FEALTMAN,
Defendant/Respondent
: NO. 00-8044 CIVIL TERM
ORDER OF COURT
AND NOW, this 4th day of April, 2001, based upon the Court's determination that Petitioner's
monthly net income/earning capacity is $2,069.37 per month and Respondent's monthly net
income/earning capacity is $2,913.67 per month, it is hereby Ordered that the Respondent pay to the
Pennsylvania State Collection and Disbursement Unit, $330.00 per month payable bi-weekly as
follows; $128.77 bi-weekly for alimony pendente lite and $23.54 bi-weekly on arrears. First payment
due on next pay date @ $152.31 bi-weekly. Arrears set at $458.00 as of April 4, 2001. The effective
date of the order is February 28,2001.
Husband is given credit in the arnount of $100.00 for direct payment to wife.
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.g 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: Donna N. Fealtman. 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, P A 17106-911 0
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.
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Husband to provide medical insurance coverage for wife.
DRO: R. 1. Shadday
Mailed copies on
1j.'(P-t>l to: <
Petitioner
Respondent
Samuel Audes, Esquire
Thomas Gould, Esquire
BY THE COURT,
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1. esley Oler, Jr.
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
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State Commonwealth of Pennsvlvania ;JJ4t!. ~5' 116" /03/:J-S-
Co./City/Disl. of CUMBERLAND 7 U' /.
Date of Order/Notice 04/04/01 j.e 00 V9 (P
Court/Case Number (See Addendum for case summary)
o Original Order/Notice
o Amended Order/Notice
o Terminate Order/Notice
) RE, FEALTMAN, GUERN W.
) Employee/Obligor's Name (Last, First, MJ)
)
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195-38-9539
Employee/Obligor's Social Security Number
EmployerlWithhoJder's Federal EIN Number
NAVY SHIPS PARTS CONTROL
EmployerlWithholder's Name
5450 CARLISLE PIKE BOX 2
EmpJoyerf\rVithholder's Address
MECHANICSBURG PA 17050-2411
5955100718
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names assodated 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.
$ 219.00 per month in current support
$ 51.00 per month in past-due support Arrears 12 weeks or greater? o yes @ 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 $ 330.00 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:
$ 76.15 per weekly pay period.
$ 152.31 per biweekly pay period (every two weeks).
$ 165.00 per semimonthly pay period (twice a month).
$ 310.00 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
dedud 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, ple;lse call Pennsylvania State Colledions and DisDursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instrudions.
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: R.1 lIbadday ~'
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Date of Order: April 5, 2001
BY THE COURT:
J.
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orm EN-028
Worker 10 $IATT
Service Type M
OMB 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. 'I: R-epoltil.g tl.e P.\ydatelDa.te of 'Nitl,lloldil,g. '/ou "lU&t lepolt tl,6 t-'oyd.\ti./Jal:t of nitl.l.oldil'5 nl.el, S61.d:..g tI.G /Joyll.ellt. TI.e
p.\yJabddatc v( nitI.LoIJ;'1l5 is t1,e Jate 01, nl.id. alllvUht n.\S n;lI.l.eld f1vll. tl.e c11It-'lvyee's YVo5es. You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support
against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must
follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest
extent possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for
you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
WITHHOLDER'S ID: 1690000043
EMPLOYEE'S/OBLlGOR'S NAME: FEALTMAN , GUERN W.
EMPLOYEE'S CASE IDENTIFIER: 5955100718 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 fron1 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. !l1673 (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 taxesi Social Security taxesi and Medicare taxes.
10.
"NOTE: If you or your agent are selVed 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.
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (71 7l 240-6225 or
by FAX at (717) 240-6248 or
by Internet @
Requesting Agency:
DOMESTIC RELATIONS SECTION
P.O. BOX ~20
CARLISLE PA 17013
Page 2 of 2
Form EN-028
Worker ID $IATT
SelVice Type M
OMB No.: 0970-0154
Expilation ~ate: 12131/00
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ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: FEALTMAN,
PACSES Case Number 896103125 ;;3-0$19&
Plaintiff Name '/ C
DONNA N. FEALTMAN
Docket Attachment Amount
00-8044 CIVIL$ 330.00
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
D If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s);
DOB
If checked, you are required to enroll the child(ren)
above in any health insurance coverage available
through the employee's/obligor's employment.
Service Type M
GUERN W.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s);
DOB
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t::Jli~h~~k~d,;~u ~r~;~~~i;~d to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s);
DOB
D If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s);
DOB
If checked, you are required to enroll the child(ren)
above in any health insurance coverage available
through the employee's/obligor's employment.
Addendum
Form EN-028
Worker 10 $IATT
OMB No.: 0970-0154
Expiration Date: 12131JOO
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
'bli O2J]JOo-96t;f( (l1f/1t..
State Commonwealth of Pennsvlvania ;J 1fC. <;.?) 'l' 9& I D 31 ,;). ~
Co.lCityfDist. of CUMBERLAND 6
DateofOrderfNotice 04/12/02 ~ 30 </9f.;,
Court/Case Number (See Addendum for case summary)
o Original Order/Notice
@ Amended Order/Notice
o Terminate Order/Notice
) RE: FEALTMAN, GUERN W.
) Employee/Obligor's Name (Last, First, MI)
)
)
)
)
)
)
)
195-38-9539
Employee/Obligor's Social Security Number
5955100718
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
EmployerlWithholder's Federal EIN Number
NAVY SHIPS PARTS CONTROL
EmployerlWithholder's Name
5450 CARLISLE PIKE BOX 2
Employer/Withholder's Address
MECHANICSBURG PA 17050-2411
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'sfobligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 279.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes (Xl no
$ O. ooper month in medical support
$ 0 . 00 per month 'for genetic test costs
$ per month in other (specify)
for a total of $ 279.00 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:
$ 64.38 per weekly pay period.
$ 128.77 per biweekly pay period (every two weeks).
$ 139.50 per semimonthly pay period (twice a month).
$ 279.00 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 paydatefdate 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 EFl/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania 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:
Service Type M
~NO"0970'01S4
- ~Ur;r. '-a,tion Date: 12/31/00
JUI. I::-
Form EN-028
Worker 10 $IATT
Date of Order: APR 1 5 2002
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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.* Rep05lti"s lI,e raydatefDate of.....;II,I,oldil,S. YO" ","st ,epOItll,e pAydatdJate of ..itl,l,oldi"S ..Len sel,di"s the payn,""l. TI,e
paydate!date of ..ill,h05ldi,,~ is lI,e date 0" ..hid, al"ou,lt ..as ..itl,I,,,ld flOI" II ,e ""ploy".', ..a~es. 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 retum a copy of this Order/Notice to the Agency identified below.
WITHHOLDER'S ID: 1690000043
EMPLOYEE'S/OBLlGOR'S NAME: FEALTMAN , GUERN w.
EMPLOYEE'S CASE IDENTIFIER: 5955100718 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-<Jiscrimination: 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. S 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.
10.
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
Requesting Agency:
DOMESTIC RElATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717\ 240-6248 or
by Internet @
Page 2 of 2
Form EN-028
Worker 10 $IATT
Service Type M
OMB No.: 0970-0154
Expiration Date: 12/31/00
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ADDENDUM
Summary of Cases on Attachment
PACSES Case Number
Plaintiff Name
DONNA N. FEALTMAN
Docket Attachment Amount
00-8044 CIVIL $ 279.00
Chiid(ren)'s Name(s):
Defendant/Obligor: FEALTMAN, GUERN W.
89610312S/30l/9c-
PACSES Case Number
Plaintiff Name
DOB
Attachment Amount
$ 0.00
Child(ren)'s Name(s):
Docket
DOB
.'2i:;~~~~~~~:~:~~;~..;~~i;;~;~~~;~II;~~~hild(r~~)'.'....,.. ." ,"
identified above in any health insurance coverage available
through the employee'slobligors 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/obiigor's employment.
D If checked, you are required to enroll the chiid(ren)
identified above in any health insurance coverage available
through the employee's/obiigor'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
dl;~~~~~~~,~~~;;~;;~~i;~~;~;~;~;lthe child(ren) ".' .'...,..., .'"
identified above in any health insurance coverage available
through the employee's/obiigor's employment.
D If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee'sJobiigor's employment.
Addendum
Form EN-028
Worker ID $IATT
Service Type M
OMS No.: 0970-0154
Expiration Date: 12/31/00
, I,
~~ ,
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
DONNA N. FEALTMAN ) Docket Number 00-8044 CIVIL
Plaintiff )
vs. ) P ACSES Case Number 896103125
GUERN W. FEALTMAN )
Defendant ) Other State ID Number
ORDER
AND NOW, to wit, on this
7TH DAY OF FEBRUARY, 2005
IT IS HEREBY
ORDERED that the support order in this case be 0 Vacated or o Suspended or
(i) Terminated without prejudice or 0 Terminated and Vacated,
effective NOVEMBER 3, 2004 , due to:
THE PARTIES' DECREE IN DIVORCE ON NOVEMBER 3, 2005. THE ACCOUNT IS CLOSED
WITH A CREDIT OF $1024.06.
/
DRO: RJ Shad day
xc: plaintiff
defendant
JUDGE
Service Type M
Form OE-504
Worker ID 21005
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsvlvania
Co.lCity/Dist. of CUMBERLAND
Date of Order/Notice 02/07/05
Case Number (See Addendum for case summary)
OOriginaJ Order/Notice
o Amended Order/Notice
(8) Terminate Order/Notice
DFAS CLEVELAND CENTER"
C/O DFAS CODE L
GARNISHMENT OPS
PO BOX 998002
CLEVELAND OH 44199-8002
W. ~O-&'OW (IV
jJ)!/(!.~g 01(P/03/dIJ
RE: FEALTMAN, GUERN W.
Employee/Obligor's Name (Last, First, MI)
195-38-9539
Employee/Obligor's Social Security Number
5955100718
Employee/Obligor's Case Identifier
(See Addendum for plaintiff name.
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
EmployerlVVithholder's Federal EIN Number
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 support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's!obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 0.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes Q9 no
$ 0.00 per month in current and past-due medical support
$ 0.00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 0.00 per month to be forwarded to payee below.
You do not h<jve to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 0 . 00 per weekly pay period.
$ 0.00 per biweekly pay period (every two weeks).
$ 0.00 per semimonthly pay period (twice a month).
$ 0.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's! obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on page 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA 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.
Service Type M
OMS No.: 0970-01 4
~ IE-
Form EN-028
Worker ID $IATT
Date of Order:
.EEB - 8 2005
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
D If ~hecked you are required to prpvide a copy of this form to your employee. If your employee works in a state that is
ditterent from the state that issued this order, a copy must be provided to your employee even if the box is not checked.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law againstthe same income.
Federal tax ievies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employee/obligor.
3. * Repo.l;'lg ll.oc; r oyJotefDah:: vf\\,al.l.old;..g. Yvu .IIU::ll.epoll U\C tJoyJc:th:dJatt: of vv;U.I.old;115 vvl,cl' ::lel.d;l.g tI.e paY'I,oc;lll. TIlc
paydateldate vf vv;U.I.old;lIg;;;. lLoc; doh:: vII vvl.;c.I. dlllvulIl vvas vval.l.cIJ (.VII. lIlc clllplOyee'5 vvagt::l. 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)
S. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working foryou.
Please provide the information requested and return a copy ofthis Order/Notice to the Agency identified below.
THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2491016300
EMPLOYEE'S/OBLlGOR'S NAME: FEALTMAN, GUERN W.
EMPLOYEE'S CASE IDENTIFIER: 595510071B 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 ofthe 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 (1 S 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. For tribal orders, you may not withhold more
than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more
than the amounts allowed under the law of the state that issued the order.
10. Additional Info:
'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
11.Submitted By: If you Or your employee/obligor have any questions,
DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT
13 N. HANOVER ST by telephone at (717) 240-6225 or
P.O. BOX 320 by FAX at 17171 240-6248 or
CARLISLE PA 17013 by internet www.childsupport.state.pa.us
Page 2 of 2
Form EN-0l8
Worker ID $IATT
Service Type M
OMB No.: 0970.0154
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