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HomeMy WebLinkAbout00-08196 )!:C(:::~_::~;:i'::!::.::!;;::;:!3E~::-:~!::e(:~::c~;:::::!::.::!;:-;::<Ci{':C:<.~}:c()__~;:;:::!::c(:~!a::( :,:!::.:{:~!>>X)>>::!;::)::.>~::t!>>::~;:::::!::.::!;:::::!::C!~}~%!::.g!"A~!::.>~~::.>;x~!~r:~!::c!;;:::~3~Z~!::.>tY\1 ~ i x I ... ~ ~,'.:.'... .. ti X i ~ IN THE COURT OF COMMON PLEAS ~ ~ I ~ ,l ~ ~.~ ~ ~ i t,:,>>:..):+:~.>>:. ~.~ * ~.~ ~ ~.~ ~ h ~ ;..~ ~ ~'S I ~.~ ~ ~ ~.~ ~ ~ ~ ~.~ ~ ~l ~ ~ ~.~ ~.~ ~ i ~.~ ~~~ ~ . '.. ."< ~ ~ ~ ~ ~ ~.~ ~ ~ ;", ~ ;"S ~ v ~ ;..~ ~ ~~~ ~ ~) I l-, ~ ~.. (':..:c().>>::~:,::.::.>:,:):+::(::~::.::~;.::::.::.::.;:.:"';::~. ::'::.::()::.::(::~::.::'-.:}r+::(::~::.::~<:::.;::.::~:.::,':'::"':::..::.::O;::)::.::.,,::::.::.~ OF CUMBERLAND COUNTY STATE OF PENNA. .....Bohby.R.....Har.t. N o. ......9..9..-::~.l~.6 ................., 19 Versus Marie P. Hart DECREE IN DIVORCE AND NOW, ' . , , . , D.d b~c.r. . ./ Q. . ., ., w. ZC>P~ it is ordered and decreed that.... ~.~r:~y,,~:. ~.a.~~"."...".,..,.,."........" plaintiff, and. . . . . ., . ,~?i.r.i,~, P.., ,I:l?i;t',t. .. . , .. .. ... . .. . .. .. , .. .. .. . .. . , ., 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; The Property Settlement Agreement of August 23, 2002, is .. . :,:nacnEid' heiit6' 'arid. i"ric6i:'p'ora't"e'd. iilto' th.fs' Decree. 'foi:'.' . , ,. .. , ." !=.n.~Qj:'>=.~II)li!P:t, .P\l:rP,QSO'I3. .QuJ.y. ,P\l:r.s,\:lq,n:t. .to. S.~ctip,n, 31.0.5. of"...." the Pennsylvania Divorce Code. ., c B y The /,C JU/ t : . ..... 0' .f/l../.<l.-z Attest: '/1 mm --?o'~- Prothonotary '1"" _.' r.' ~ 'I "''''111 !'1 _ \ .-~,,' -"ii'" ,.-,,"---~-~ -'--'~~'-""-"~~''''" I ~";'~ "_"' C'_"'" .-, ~,__ \',l;~' ---" ,-- ,','I' -. ., ~.~- ~ H i I ~ n ~ ~t~ ~ i ~l ~.s ~ ~ ~ I i ~ f'i ~ ~.~ ~~s ~ I ~.~ * ~ ~.~ t~ ~ ".~ ~ '"._0 ~ $-" ~.s , N ~ ~ ~ ".~ ~ $ ~ ~.~ '--' ~ '.' ;,; ~ ~.~ J. ~ ~.~ $ ~ ~.' ~ ~.~ ~I!IlM.lilill~~~IIII1lI~~"-~~M~NIl~'-" IilIllllllllii-' ~,' "",,,J.T,I - "_',r c<^, '"'_.",.,,~,_._~ /tJ -It? ,tt2 /1) , /0001 .. "-. -lllIII-' ~ '"", -, " ,,'. , w- ~~~,:J;"~4:h ~ ;~ 7Z;' ~..4 f /~~ jj; BOBBY R. HART, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 00-8196 CIVIL TERM MARIE P. HART, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record together with the following information, to the Court for entry of a divorce decree: 1, Ground for a divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2, Date and manner of service of the Complaint: Acceptance of Service - 11/21/00. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the Plaintiff 8/23/02, by the Defendant 8/23/02, (b) (1) Date of execution of the plaintiff's affidavit required by Section 3301(d) of the Divorce Code: (2) Date of service of the plaintiff's affidavit upon the Defendant: 4. Related claims pending: All related claims have been withdrawn, 5. Complete either (a) or (b) (a) Date and manner of service of the notice of intention to flie praecipe to transmit record, a copy of which is attached, if the decree is to be entered under section 3301 (d) of the Divorce Code: (b) Date Plaintiff's Waiver of Notice in ~ 3301(c) Divorce was filed with the Prothonotary 8/26/02 Date Defendant's Waiver of Notice in ~ 3301(c) was filed with the Prothonotary 8/26/02. CnOA)Wcflio/ Charles Rector, Esquire Attorney for the Plaintiff Date: 10/3/02 < -'1 '-~r-""',~-~:-~-',,";-I--"--"-~,"):<r" ,~",,.-~ ''''''' ~-, -"! 1':'~,_;""~~ 7, ,'=',~~" :r",il',~;,,; ,- -, ". ~,.""",, -., f~:" ." .. -~-,-,"' 'ill [!l!I ......' ',..,......'..."..".."'" . ,,' ~ r- ~" .' -, H'~ ~, ,.",___," ..~_, ""'1'~~..iaV9""1~,~rl!~R";.~l'n$~!\..,lllil~~~~l1iIiJm~l1!li~~~~!lIl!~~. _>~ ,.' ,,' ~ _'" f_",~~ g g -ore rnr'"' z:i-~ :zC ~~~- ~c,J -j>.-.., -r:.-;J' ,~.! &~( , J>c':: -7 ~~ ...c, - C'..:> N :::;) (-') ..-I I .~- I ~ .. ,"'''t'I' () -n .~:j ',:,-::D '-';;,~~ :~y '-:~~.g .......:} ~i~~ :P -< r:;; ? (]'\ BOBBY R. HART, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00 - 8196 CIVIL MARIE P. HART, Defendant IN DIVORCE ORDER OF COURT AND NOW, this ~~ day of (!JChblA ) 2002, the economic claims raised in the proceedings having been resolved in accordance with an agreement dated August 23, 2002, the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. BY THE COURT, .J. cc: Charles Rector Attorney for plaintiff Robert J. Mulderig Attorney for Defendant ~~ /0.0.3.0,4,.; ~. , ,~~=,.". - . .. ~~ . ',<--<. _,,_, __,__.J._ I'!"-^' ~" "r ~~~~~ilt~!liltm@}"H~!,i1J!l~itiiill.~~_ff~iIii-':4"\1k'1-'~,"1~t;1:!.W'=''''' 'r '_djf~&,,;'i'-' '1" .- ~~., i-~J_,~,.;:~n,,l!J,,-".._, ~n 1] _ - ~-:,~L~,r:!1JJ1.fllnIL~.'~~d"'_w . _~ ,_"~~'" ," >' '_'.",', '" ,~.' ~_~ ..'... OF F\Lr:[\-{)i=HCE ".::': -...' -",J._!!".,Y',1lY -, ".. "",1 )"f ',k\ j -"', ~ " "'\" I ",'__;-, "\" 1 . '>l T " ~Jl 9: :J2 02 OC - t.. H CU~iH~r.{Li>.{) (';OUNTY ;PEi'~NSYi.V.~rN~ w'r- 'm ~-- ,-' .. '\'" ,", "',.,J_ " ~";,.;"., Iii! ~ - ~, . ,r1 _ ,__ " ~(Q)[f2>V BOBBY R. HART, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 00-8196 CIVIL TERM MARIE P. HART, DEFENDANT CIVIL ACTION - LAW IN DIVORCE TRANSCRIPT OF PROCEEDINGS AGREEMENT BEFORE: LISA BRUAW, REPORTER NOTARY PUBLIC DATE: AUGUST 23, 2002, 9:47 A.M. PLACE: LAW OFFICES OF CHARLES RECTOR 1104 FERNWOOD AVENUE SUITE 203 CAMP HILL, PENNSYLVANIA APPEARANCES: LAW OFFICES OF CHARLES RECTOR, ESQUIRE, P.C. BY: CHARLES RECTOR, ESQUIRE FOR - PLAINTIFF TURO LAW OFFICES BY: ROBERT J. MULDERIG, ESQUIRE FOR - DEFENDANT ALSO PRESENT: BOBBY R. HART MARIE P. HART n_" l' - .- "'lI .-r '", -, -~ 2 1 MR. RECTOR: Present today are the parties and 2 their respective counsel. And it is their intention to 3 fully and finally resolve their divorce case and the 4 related economic claims in all respects. I am dictating 5 this agreement on the record. We are foregoing the need 6 to have a written property settlement agreement. 7 This is to say that once I have completed 8 dictating the agreement, counsel and I may have some 9 discussions during this dictation or afterwards. But we 10 will, nonetheless, enforce the agreement following the 11 completion of the dictation. I want to be clear about 12 that to both the parties' and counsel. And I would say to 13 listen very carefully to what we're about to say. All 14 right. 15 Folks, you have the right to conduct 16 depositions in your case and to otherwise proceed to a 17 master's hearing and to avail yourselves of the rights in 18 court. By settling this case today you are waiving your 19 rights to proceed to trial to a master's hearing to court. 20 And this agreement that we are now hearing will be 21 the full and final settlement. 22 You were married on June 8th of 1968. And you 23 are agreeing today to finalize the divorce case. I have 24 prepared the necessary affidavits to accomplish that. By 25 way of the asset distribution, I will now outline for you 'd. ~~ 3 1 the distribution that has been reached by way of agreement 2 in this case. 3 (1) The real estate known and numbered as 1785 4 GoodHope Road, Enola, Pennsylvania, shall become the 5 property of husband. A deed will be prepared for the 6 parties to sign. And wife will cooperate in signing that 7 deed upon request. 8 (2) We know through the exchanging of 9 interrogatories that there were two IRAs with Members 1st. 10 Husband shall retain those IRAs. 11 (3) Each of the parties participates in a 12 deferred compensation plan; husband with Wert, w-e-r-t, 13 Bookbinding, Inc. and a profit sharing plan. And wife 14 with the company formerly known as Merck-Medco with a 401K 15 plan through Fidelity Investments. The parties hereby 16 agree to waive any interest each may have in the other's 17 pension plans and to retain their pension plans in their 18 name. 19 (4) The parties acknowledge that they have 20 previously separated all of their furnishings and personal 21 property. And each of the furnishings and personal 22 property items currently in their possession shall become 23 their own. 24 (5) The parties' vehicles are as follows: 25 husband shall retain all right, title, and interest in and '-~, ,.. __ _._1__, ~'" ,~_ , " ~"" 4 1 to the 1995 Madza pickup truck and the 1995 Buick Park , 2 Avenue. Wife shall retain all right, title, and interest 3 she has in the 1991 Buick Park Avenue. 4 Both parties agree that the vehicle 5 distribution that I have just outlined means that this 6 agreement operates as a bill of sale. To the extent 7 that -- although we don't think there are joint names on 8 the vehicles -- to the extent there would be a title that 9 has a joint name on it, for example, Mr. Hart, on your 10 vehicle you, Bob, would have the obligation of cooperating 11 to remove your name from your wife's vehicle. And, 12 likewise, Mrs. Hart, you would have the obligation of 13 removing your name from the title of your husband's 14 vehicle Mr. Hart. 15 The parties have identified various insurance 16 policies. By signing this agreement they are 17 acknowledging the right to continue those policies in 18 their own names and following the dictation of this 19 agreement to change beneficiaries from time to time as 20 they see fit. 21 Next, the parties also acknowledge in their 22 interrogatories that there are various credit card 23 obligations. They each agree to be responsible for those 24 credit cards in their individual names. They hereby 25 assert they have not used and will not use in the future '''Iff ,_, ~"'" ~~ ~" 5 1 any credit card obligations in joint names. 2 Next, husband acknowledges and agrees that in 3 consideration for the receipt of the real estate that he 4 shall pay to wife the lump sum payment of $60,000 within 5 30 days of today's agreement. The parties acknowledge 6 that husband will be receiving -- will be applying for and 7 receiving a home equity loan to facilitate that payment to 8 wife. 9 The parties acknowledge that that payment to 10 wife will be a non-taxable equitable distribution payment. 11 What that means, Mrs. Hart, is that you will not owe any 12 federal, state, or local taxes on the $60,000 you are 13 receiving. 14 The parties also understand that to the extent 15 that the mortgage company needs to see from you any 16 documentation regarding the agreement that he will provide 17 that to them. To the extent that they also require any 18 information from your wife that she is withdrawing her 19 claim and her interest in the property, Mrs. Hart, you are 20 agreeing to provide that to the mortgage company to 21 facilitate the loan. 22 By way of illustration, the mortgage company 23 might say we need proof that the deed, Mr. Hart, is in 24 your name. We would provide the signed deed to the 25 mortgage company. The parties understand, however, that ~I' P" ....1"'. .>. , O~=,_ 6 1 to the extent that the deed is signed by you, Mrs. Hart, 2 that if for any reason the mortgage company refuses the 3 loan, the parties understand that we are back to square 4 one. 5 By signing over on the deed, for example, and 6 by not receiving your money that doesn't mean that the 7 case is over. It means that this agreement that I'm 8 reciting will have no force or effect. Do you understand, 9 Bob? 10 11 MR. HART: Yes. MR. RECTOR: To the extent you don't get that 12 loan we have to begin the case allover again with 13 discovery, etc. On the other hand, if the mortgage 14 company were to say that we can't facilitate a payment of 15 $60,000 within 30 days but we can do it within 45 or we 16 can do it within 15, then the 30-day deadline that I've 17 indicated in the agreement may have some flexibility 18 depending on the parties' desire to get their money. 19 I think we can agree, however, that only 20 under very unusual circumstances that counsel would 21 discuss would the money be paid any later than 45 days. 22 Off the record. 23 (A discussion was held off the record.) 24 MR. RECTOR: Back on the record. Folks, this 25 will be the next number in this agreement that I've "~, .,...,., " ,~ I," ~- 7 1 recited on the record is the final equitable distribution 2 of your marital assets. 3 There will be no further distribution that will 4 be and can be after this dictation; no request by one or 5 the other for any assets that I have previously identified 6 belong to each of you. In addition, this agreement 7 constitutes a complete, full, and final waiver by each of 8 you against the other for alimony, alimony pendente lite, 9 counsel fees, costs, and any other claims that you each 10 may have against the other in a divorce case. All of 11 those claims are waived. The only agreement that we have 12 in existence at this time is what I have dictated on the 13 record. 14 And, finally, this agreement constitutes what 15 is called a mutual release. Both of you agree to mutual 16 release, quick claim, or forever discharge the other and 17 the estate of the other for all time to come and for all 18 purposes whatsoever from any and all rights, title, and 19 interest or claims in or against the property being 20 received by the other in this agreement or against the 21 estate of the other of whatever nature and whatsoever 22 situated which either of you now has or may have at any 23 time in the future whether arising out of former 24 contracts, former acts, engagements, or liabilities of 25 such other, or by way of what we call dower and curtesy or '''!_~-~ ~I ~, " 8 1 claims in the nature of dower and curtesy including but 2 not limited to widow's or widower's rights, family 3 exception or similar allowances or under the intestate 4 laws or the right to take against the spouse's will or the 5 right to treat a lifetime conveyance by the other as 6 testamentary or all other rights of a surviving spouse to 7 participate in the deceased spouse's estate whether 8 arising under the laws of this state or of any other 9 state. 10 It is the intention of both parties today to 11 give each other by listening to the dictation of 12 this agreement a full, complete, and general release with 13 respect to any and all property of any kind or any nature 14 real, personal, or mixed which the other now owns or may 15 hereafter acquire except only all rights and agreements 16 and obligations whatsoever arising under the terms of this 17 agreement. 18 The paragraph that I just recited to you deals 19 primarily with the current law in Pennsylvania regarding 20 what might happen if one of you were to predecease the 21 other. We have something called the right to take against 22 a spouse's estate. By agreeing to the agreement that 23 we've reached today you each may now prepare your own 24 wills and you may pass your estate along to whoever you 25 want. I would encourage you to do estate planning after , ""~-- .. ~ ."" .-,- 8 9 10 9 1 today. 2 By listening to this agreement today you are 3 each acknowledging that neither of you has a claim after 4 today against the other's estate in the event that the 5 other would predecease you. Bob, do you have anything 6 that you think is appropriate that we add or that we 7 provide clarification to at this point? MR. MULDERIG: Let's go off the record. (A discussion was held off the record.) MR. MULDERIG: Mrs. Hart, did you understand 11 the agreement that you listened to? 12 13 MRS. HART: Yes. MR. MULDERIG: Do you have any questions 14 concerning it? 15 16 MRS. HART: No. MR. MULDERIG: Are you making this agreement of 17 your own free will? 18 19 MRS. HART: Yes. MR. MULDERIG: Are you satisfied with the terms 20 of this agreement? 21 22 MRS. HART: Yes. MR. MULDERIG: And no one has forced you in any 23 way to agree to this? 24 25 ,., MRS. HART: No. MR. MULDERIG: And you have been advised by '" .., ,-, 10 1 your own counsel on this matter? 2 3 MRS. HART: Yes. MR. RECTOR: Mr. Hart, you've listened to the 4 agreement that's been dictated in this case? 5 6 7 8 9 10 MR. HART: Yes. MR. RECTOR: Do you understand this? MR. HART: Yes. MR. RECTOR: Do you agree with it? MR. HART: Yes, sir. MR. RECTOR: Do you have any questions about 11 it? 12 13 MR. HART: No, sir. MR. RECTOR: Folks, once this is transcribed I 14 will provide a copy, Mrs. Hart, to your counsel. I will 15 provide a copy to you too, Bob. 16 (The proceedings concluded at 10:06 a.m.) 17 18 19 20 21 22 23 24 25 . .,""" " II l I hereby certify that the proceedings and 2 evidence are contained fully and accurately in the notes 3 taken by me on the within proceedings and that this is a 4 correct transcript of the same. 5 8 Nolarial seal Lisa BNaw, Notary PullJi@ NMow Cumbe~.~d Boro, Cumllllrilftll@mJ1lI\I Y CommlsslOll expires Mill' 111,1YlIJ3' 6 7 9 lO II l2 l3 l4 l5 l6 l7 l8 19 20 2l 22 23 24 25 ~.. - - .~. , , -"..... I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations Code. WITNESS: , Robert Mulderig Attorney for Defendant .-i'. D)).I.TE: <t /tt/0.2 \"~ah.l':' / O. ~ t Marie P. Hart V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00 - ~19 b Cod y~ BOBBY R. HART, Plaintiff MARIE P. HART, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court, A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property of other rights important to you, including the custody or visitation of your children, When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Office of the Prothonotary. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO, OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 -^'. ~ '('-I' ., - ~~ ~~. . -- 'I BOBBY R. HART, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 011- J'/9f.> ~ -r~ V. MARIE P. HART, CIVIL ACTION - LAW COMPLAINT IN DIVORCE AND NOW comes the Plaintiff, Bobby R. Hart, by and through his attorney, Charles Rector, Esquire, and respectfully represents as follows: 1. Plaintiff is Bobby R. Hart (SS# 244-76-6108), an adult individual, currently residing at 1785 Good Hope Road, Enola, Cumberland County, Pennsylvania, 17025. 2. Defendant is Marie P. Hart (SS# 165-38-2320), an adult individual, currently residing at 2022 Market Street, Camp Hill, Cumberland County, Pennsylvania, 17011. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for a period of six months (6) immediately preceding the filing of the Complaint. 4. Plaintiff and Defendant were married on June 8, 1968, in Carlisle, Cumberiand County, Pennsylvania. 5. There have been no prior actions for divorce or for annulment between the parties. 6. The Plaintiff and Defendant are both citizens of the United States of America. -rl"-' ." ,- "', ., 'c ~ ~---' 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. Count I - Divorce 8. The allegations of Paragraphs 1 through 7 are incorporated herein by reference and made a part hereof. 9. Defendant has committed adultery. 10. This action is not collusive as defined by Section 3309 of the Divorce Code. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce decree pursuant to Section 31 02(a)(2) of the Divorce Code. Count 1\ - Eauitable Distribution 11. Paragraphs 1 through 10 of this Complaint are incorporated herein by reference as if set forth at length. 12. The parties have acquired, during the course of the marriage and prior to separation, property, both real and personal, which they own jointly or which was otherwise purchased so as to constitute marital property within the definition and scope of Section 3502 of the Divorce Code. WHEREFORE, Plaintiff requests your Honorable Court to enter an Order distributing the marital property owned by the parties. ," ~ ",- t-I-'" , " I' ,0' ~---. Count III - Spousal Support and/or Alimonv Pendent Lite and Permanent Alimonv 13. The allegations in Paragraph 1 through 12 are incorporated herein by reference and made a part hereof. 14. Plaintiff is unable to sustain himself during the course of this litigation. 15. Plaintiff lacks sufficient property to provide for his reasonable needs and is unable to sustain himself adequately through appropriate employment. 16. Plaintiff requests this Honorable Court to enter an award of spousal support and/or alimony oendente lite in his favor pursuant to Section 3701 of the Divorce Code. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an award of spousal support and/or alimony oendente lite until final hearing and thereupon to enter an order of alimony in her favor pursuant to Section 3701 of the Divorce Code. Count IV- Counsel Fees. Expenses and Costs of Suit 17. The allegations of Paragraphs 1 through 16 are incorporated herein by reference and made a part hereof. 18. Plaintiff has retained an attorney to prosecute this action and has agreed to pay him a reasonable fee. 19. Plaintiff has incurred and will incur costs and expenses in prosecuting this action. "(""""'l ~ I - T "1'1" " I ~ H" 20. Plaintiff is not financially able to meet the expenses and costs of prosecuting this action or the fees to which his attorney will be entitled in this case. 21. Plaintiff requests this Honorable Court to enter an award of interim counsel fees, costs and expenses until final hearing and thereupon such additional counsel fees, costs and expenses as deemed appropriate. WHEREFORE, Plaintiff respectfully requests that, pursuant to Sections 3702 of the Divorce Code, the Court enter an Order directing Defendant to pay Plaintiffs reasonable counsel fees, costs and expenses. RESPECTFULLY SUBMrrrED~----"-- ~) / I rles Rector, E 1104 Fernwood Camp Hill, PA 1 (717) 761-8101 i Date: II "'0/00 '}', ',"""-'" "1'1 ,., '1'_ ,I T~I I verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ~?w Bo R. Hart Date: / J . 2D..oO - ,I -," , , BOBBY R. HART, Plaintiff V. MARIE P. HART, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-8196 CIVIL TERM CIVIL ACTION.. LAW IN DIVORCE ACCEPTANCE OF SERVICE I, Robert J. Mulderig, Esquire, counsel for the Defendant, Marie P. Hart, accept service of the Divorce Complaint, received on November 21, 2000, and certify thaI I am authorized to do so. Date:~ -1'!'llI'_~ . '-:-'1',-' ,-, To ',., ' - - - > ,,-, -, "; ~"~~~i Ro . J. Mulderig, Esqui e 1""-'" ,~ IliI !'II....."" '.... ~ , "'i,.-'=>_ , ~ ~ PO '-liil~ c, C) .2 c: ;;~' - --.1 -0 ti .:-" m W'o'" ." - !':; L: I ",::.. ~!-J <0 ~~ ......:;, , , ,~ " f':? ,,' -< CO ""0"'" ,_.'_~';';""~<. ".~'" 1J,J,l .1iI_'lt"'?W~VII~mijmmjl>~~'l'fI.!tl$a1~J!-lfflffl~~~i"fl'l'/ll~~~ BOBBY R. HART, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 00-8196 CIVIL TERM MARIE P. HART, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Counterclaim in Divorce under Section 3301(c) of the Divorce Code was filed on December 4, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. 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 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 herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ff ~~t;/o~ \.,,1Yj rvu; / Q, ~/J t Marie P. Hart c.~ , I' - "~~~!"I;"',,,I-',., , ,-. h"---' ,~ ,"~~~_-- ~ , ,. '-- "',,,,,",<" ".'''''0'..,- ,"1'-,;"" ' 1- "'-""" ..^ ""..,,- .. ~ ".,., .-- ,,/-' -~~.-'" ' 'y-,.^ "-, ! ~I." ~... < ~~" - ----'!<^~ -'.' '__w .",~ ,- ',-",-",;""~,,,.--',,,,,-"~y"~ 0 ~'iT:~:}'~'~1l;"'-V 0 0 0 C N " s::: %>> '-I ~gJ ~ 5 PA ;!] z~- N -nTn en ,. CT> u~ ~:c: C) , C"-~ ;:;: .> -0 -j PC:; :J:: :C'-ri ;?; (j ~o Pc om ~ ....1 35 -< ,,_,",_, c _, "!~""f~'P;ll<1lQ"W~~~lom~f"\-';:ffl~~~.f~~#W,~~ilfI~i!!I!!I!~~'I!~"*,,f'"li1i!~Mr~~~~~~_~ BOBBY R. HART, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 00-8196 CIVIL TERM MARIE P. HART, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Counterclaim in Divorce under Section 3301 (c) of the Divorce Code was filed on December 4, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. 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 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 herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: B ;;1.3-o(t... ~h~ Bob y R Hart <,"'-~'~,'!l'IWd"_'" ,:"_ __, -~_o_ "" '"-~ ~. ^~ -"" '" -~--"' ' , -~ l!i'" ~_. '""..... ... ,/, ,,!1!11","" ~ - i I __~',r -~.--, H;,',-", ~~ ^"-"~ '" "-"~- "'-~, ~'V--"'~;-'-"'-~"'k"~-'jJtf~'"''''-'~< ~ !Tjf')Ij~lr!l~r~ J.':<("Y. (") '0 ~ C 1,,-> 3: ;Do "'Om ,-, c: ."l~ ~::t::' <;-} in;; 2:C 1'-> C/) , en :=.go ~6 ~6 )>0 " T:fj :J:: :s- ~o ':;i'(') ~ Om -./ ?5 -< "li\'II!I{g .. ~_"ll!!_,,, ~~';;'6m~i1l"~Fl'il_~~l:~i~)j'li!I~lni'0sr<J~~lj:ftm!"'''~~I'llilm~~~~~ . . BOBBY R. HART IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIV,IL ACTION LAW vs. NO, 00 - 8196 CIVIL 19 IN DIVORCE MARIE P. HART Defendant STATUS SHEET AD/I/O -z.- ,w~. -!_ ,_ '-cl"-r'~> ~ ". _. ___,_, _ _, .. , -, 1 .~. ~"" . BOBBY R. HART, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00 - 8196 CIVIL MARIE P. HART, Defendant IN DIVORCE TO: Charles Rector , Attorney for Plaintiff Robert J. Mulderig , Attorney for Defendant DATE: Wednesday, July 3, 2002 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. ."-1' . ,.~ ~,.v-- ,->'< ,--"- ' -,-'- . , , , < . (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. DATE COUNSEL FOR PLAINTIFF COUNSEL FOR DEFENDANT NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. , . !.. "",--"~d ":'_ _ ":" ;'! '_' 'F ,0~ .,.-, _-,' - ,_0--_'' '. -I'" - ""c;' , r, , , , ~~, Law Offices of Charles Rector, Esquire, P,C. 1104 Femwood Avenue, Ste. 203 Camp Hill,PA 17011-6912 www.charlesrector.com Tammy S. Faust Paralegal (717) 761-8101 Fax (717) 761-2161 September 30, 2002 T (ad Colyer . Office of Divorce Master 9 North Hanover Street Carlisle, PA 17013 Re: Hart v. Hart No. 00-8196 Civil Term Dear Traci: As per your request, enclosed please find the signed acknowledgment regarding the settlement transcript in the above-referenced matter. If you have any questions or need additional information, please do not hesitate to contact me. ~IYYOUrS, T~ Paralegal for Charles Rector, Esquire /tsf Enclosure I_;'/'-"~'"-S't:' --'.""','-"'.---- - - - -, -.,~---~ 'I -', 4'_1'_" Law Offices of Charles Rector, Esquire, P.C. 1104 Femwood Avenue, Ste. 203 Camp Hill, PA 17011-6912 www.charlesrector.com Tammy S. Faust Paralegal (717) 761-8101 Fax (717) 761-2161 September 6, 2002 E. Robert Elicker, II. Divorce Master 9 North Hanover Street Carlisle, PA 17013 Re: Hart v. Hart No. 00-8196 Civil Term Dear Mr. Elicker: Please be advised that the parties in the above-referenced matter have reached an agreement regarding all aspects of their divorce and related economic issues. Enclosed please find two (2) copies of the settlement transcript. Once your appointment as Master has been vacated, please forward a copy of the Order to me so we can finalize the divorce. Thank you for your assistance. If you have any questions, please feel free to contact me. Very truly Your~,. c'~) Charles Rekl CRltsf Enclosures cc: Bobby Hart Robert Mulderig, Esquire 'I - - ^. ""'I,. :"'.e:>' ,~':~, "'"""__,'1'", " ., , --, "., ' 1"1 . -- -- J"'" " -- , ~ " '- <,--, -- " ~ Law Offices of Charles Rector, Esquire, P.C. 1104 Femwood Avenue, Ste. 203 Camp Hill, PA 17011-6912 www.charlesrector.com Tammy S. Faust Paralegal July 18, 2002 E. Robert Elicker, II, Divorce Master 9 North Hanover Street Carlisle, PA 17013 Re: Hart v. Hart No. 00-8196 Civil Term Dear Mr. Elicker: (717)761-8101 Fax (717)761-2161 Enclosed please find my completed Certification regarding discovery in the above-referenced matter. If you have any questions, please feel free to contact me. V~;;SL C';rles RectJ " CRltsf Enclosure cc: Robert Mulderig, Esquire 'iff -- "I' ~;,,~, ',:'~~"I'f[.,'~";..;f"~"" "_,",,' , 'I !'.'~_ r- ",~ =r'~~~'l . "I'" .A /q ....-r; III /Drp/ BOBBY R. HART, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00 - 8196 CIVIL MARIE P. HART, Defendant IN DIVORCE TO: Charles Rector , Attorney for Plaintiff Robert J. Mulderig Attorney for Defendant DATE: Wednesday, July 3, 2002 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. Discovery not completed. j'! , , .,'. -' ."^I'~"'''''~''''''''^', ~, (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. Deposition scheduled August 23, 2002. 7-/0-/6 J. . DATE NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. -,- ',.'""'-"'- , ' -' "".'" ~"'~" ,. r r ' , ~ , '~~- I" ~.',- ''-C'" I'.: ~,' ",:,,:i':',' , BOBBY R. HART, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00 - 8196 CIVIL MARIE P. HART, Defendant IN DIVORCE TO: Charles Rector , Attorney for Plaintiff Robert J. Mulderig , Attorney for Defendant DATE: Wednesday, July 3, 2002 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. - ~,..... ,,- .~ , ~ '""l,."; r..! ~.T ' (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. '~E ( ) (~ NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. " " -' BOBBY R. HART, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :NO.00-8196 CIVIL TERM MARIE P. HART Defendant :CIVIL ACTION - LAW :IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Defendant, Marie P. Hart, moves the Court to appoint a Master with respect to the following claims: divorce, alimony, alimony pendente lite, distribution of property, counsel fees, costs and expenses and in support of the motion states: 1. Discovery is complete as to the claims for which the appointment of a Master is requested. 2. The Defendant has appeared in the action personally by her attorney, Robert J. Mulderig, Esquire. 3. The statutory ground for divorce is 3301 (c). 4. The action is contested with respect to the following claims: divorce, equitable distribution, alimony and counsel fees. 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take one day. 7. Additional information, if any, relevant to the Motion: None Respectfully Submitted TURO LAW OFFICES ~4~ Date ~~~. Robert J. ulderig, ESqUir~ 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Defendant /. -""'lI\l. '1 ''': '1'I'<,,,,,.,->:,,,??.r"".>."F',,''',~ ~" ..., ,'~"'" _ ,,' ~__,"" -"_ ,. ,,,",.. '" i!l '.-<~~> "",. '- ,"" ,. -,'~ ,- ~~..~~ ,~ "', '., ,- .~- '1~~',"",,"o;,."r~t~'C"l'""''''1''''' "~'nrn-']~r~" (') c:: ~};~; Z:;':~ ze- ~.s-_. ~i3 ~z '::2 C) {"..} r':':-::: N ;~=-,! :1] -, :11 ..... _= "'_""~' ;" ,~~,n ..,,,~,.,~Jfl!m~~~, _" '{, -",]1"" ,~cr_ F~-p~*"".",1I1JP~~-! "b~ij!!i~~-n;;'F''!i!\m''>W"B~W1''~~W.M'!~l'l~j!\f,\~i;ij:!!j~~~~~.: " ORDER APPOINTING MASTER AND NOW, this l.or day of ,2002, E. Robert Elicker, II, Esquire, is appointed Master with respect 0 t e following claims: divorce, alimony, alimony pendente lite, distribution of property, counsel fees, costs and expenses. BY THE COURT, ~. > 'i )~ , ~ ',' ~.:I" , '''. __, n, ~-:,' < '...,"o,""F,~~ '. A ':' ~ . -- I,.':': , .1. , - --- - - ~, J"" ~" <. f~j~~~lft~!_b~ll/l<l1i.~~M'"-'(~'lt:4l:1!,;\;MiEOW~~i_r;Joili,,.,.kjallial~ " ~ , <~. '!!iIiM~ "f?;:~'/'?~jU'.RY n-i IIH "'l.~ U"i'I_ - 1 'J: O? d .... CUrv'i!:i::.:l/].,'.~{~CnUiN'TY '" ,... ""'~"; '-' I r.lc:NI\~SYL'/llN&; !.' " .1> '~ '" '~ ~.t~J.~,U" ._'=l..J.]JJJlJllJ, J;",., ..,"" ITId ~, . t<,,~ '. ~~, ~ ",,~-,' ""'"., _ ~~ ., 'If'! ","" ..J-" ","~. ",:':' "C'::"1i\j ~ :;)-"'''''' - 'I".,n' ,.C,_' rf ~ BOBBY R. HART, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :NO.00-8196 CIVIL TERM MARIE P. HART Defendant :CIVIL ACTION - LAW :IN DIVORCE ANSWER AND COUNTERCLAIM 1. Admitted 2. Admitted 3. Admitted 4. Admitted 5. Admitted 6. Admitted 7, Admitted Count I - Divorce 8. Answers 1-7 are incorporated herein by reference and made a part hereof. 9. Denied, strictly. 10. Admitted WHEREFORE, Defendant requests this Honorable Court to dismiss the divorce decree pursuant to Section 3102(a)(2) of the Divorce Code. Count II - Equitable Distribution 11. Answers 1-10 are incorporated herein by reference and made a part hereof. 12. Admitted. WHEREFORE, Defendant requests this Honorable Court to xxx an Order distributing the marital property owned by the parties. ':,. -""",..r"",,--_.,.- rr Count III - Spousal Support and/or Alimony Pendent Ute and Permanent Alimony 13. Answers 1-12 are incorporated herein by reference and made a part hereof. 14. Denied. The Plaintiffs in come is $41,000.00. 15, Denied. It is alleged that the Plaintiff has sufficient property. See answer 14. 16, Statements made are a legal conclusion and deserve no response. WHEREFORE, Defendant respectfully requests this Honorable Court to dismiss the request for spousal support and/or alimony pendent lite in her favor pursuant to Section 3701 of the Divorce Code. Count IV - Counsel Fees, Expenses and Costs of Suit 17. Answers 1-17 are incorporated herein by reference and made a part hereof. 18. Admitted, 19. Admitted. 20. Denied. See answer 14. 21. Statements made are a legal conclusion and deserve no response. WHEREFORE, Defendant respectfully requests this Honorable Court to deny request for counsel fees, costs and expenses pursuant to Section 3702 of the Divorce Code. COUNTERCLAIM Count V - Divorce under 3301 (c) 22. Answers 1-21 are incorporated herein by reference and made a part hereof. 23. The parties' marriage is irretrievably broken. W"._ ~","'__ ,,--- r, 24. Defendant desires a divorce based upon the belief that Plaintiff will, after ninety days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Defendant requests your Honorable Court to enter a decree in divorce. COUNT VI ALIMONY, ALIMONY PENDENTE LITE AND COUNSEL FEES 25. Paragraphs 1 through 24 are incorporated herein by reference as if set forth in their full text. 26. Defendant is unable to provide for, or afford her counsel fees, expenses and costs during the pendency of this divorce action, and through its resolution. 27. Defendant is without sufficient property and otherwise unable to financially support herself. 28. Plaintiff is presently employed and receiving substantial income and benefits and is able to pay for counsel fees, expenses and costs, as well as alimony, and alimony pendente lite for Defendant. WHEREFORE, Defendant requests your Honorable Court to enter an Order requiring Plaintiff to pay for Defendant's counsel fees, expenses, and costs as well as providing for payment of an appropriate alimony and alimony pendente lite for Plaintiff. Respectfully Submitted TURO LAW OFFICES I ,1/1;; 7' foo Date I $II~' Robe . MUlderig, E~e 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Defendant " VERIFICATION I verify that the statements made in the foregoing Answer and Counterclaim are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S. 94904 relating to unsworn falsification to authorities. II /.;1.1 I tJO Date I I ~~.;, 0, yJ/?t Marie . Hart !if ("", '" "..,.t','~"..," J!,J_.,.I1,,~Il!iW"~~-l7'l_ . ~"I~ ~, ~-~"- ".,,,-- ',..,",.." "', '~','''M~''~'' ""'~""="n_Ii"'''''llr (") (:) 0 c: (:) .." ~ (:) .-1 ~ f'1 "'1- _ n r"ll .n ..,.,h I ''"0 .s;- 66 .,.~ . :;::::0 ~ -'~' II C5i5 Ig -:;;:.; arn :z .,.. );:! =< - ~ ."','~]~,'),;~:""',)i!!~~"'~!t~~,!";<;~W;"')"g--'i.,,>!il1':.;;;IW~S'fi<"'1~.~;jl~;;1~#!1@#W1"~!Wl!,1<f'li/I'~:ffi;~~f~!t~~~~,t' '; ! c'; "11 ::-~, r:r BOBBY R. HART, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :NO.00-8196 CIVIL TERM MARIE P. HART Defendant :CIVIL ACTION - LAW :IN DIVORCE CERTIFICATE OF SERVICE hereby certify that I served a true and correct copy of the Answer and Counterclaim upon Charles Rector, Esquire, by depositing same in the United States Mail, first class, postage pre-paid on the 14th day of December, 2000, from Carlisle, Pennsylvania, addressed as follows: Charles Rector, Esquire 104 Fernwood Avenue, Suite 203 Camp Hill, PA 17011 TURO LAW OFFICES ~~~ 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Defendant - I:l I" ""'_ -~~ .,o,.,,,~.. ~.^ '7": ,~,.''''',\"'1" "'c' ~~ .1.'- 0,0,"., .,r ~~,~ U!W!t~~f .-!.~, ~, ,. l"J.~.,,~"P" __l,~~~~W(Nls:~wc{"""r""'-'!~l'r"",,~\i' "'~~JlrM.T'''~I!l1!'ffi;'ffl'I<iJo!I#J<ffii!~,,#;,!\;;,j';;lilIg':'V''';[!;ffill~~~I~m~~!l-~J ",,'- -. 1'" jilf~tr"TII~'rl1f'!m~'t-n-':.i'il'r1t]'p'i~1';r{l,\r:"!tfi'OOw C) c:: """ -o~' nl-C;~ 2:[" _.:JJ ~S~- ;=:$i?;; " ~~ )>(- 2:' ""0 ~c:: ~ '-~ :,"' '''''''' ;~ ..-' ::-::J "', ,:.., \.1 '" f--'--' ,,_~L;' '::~(~) ~~';::: ~~;j;~ :() '-<: -~ .~ ~.'7' VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE BOBBY R. HART, PlaintifflRespondent MARJE P. HART, DefendantJPetitioner NO. 00-8196 CIVIL TERM IN DIVORCE DR# 30,350 Pacses# 855102972 ORDER OF COURT AND NOW, this 17th day ofJanuary, 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.I. Shaddav on Februorv 5. 2001 0110:30 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (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 191O.1I~ (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 tbe required documents, the Court may issue a warrant for your arrest. BY THE COURT, George E. Hoffer, President Judge ,:7S~~;<::i5pie.;b!i , ,:,t~t7;'O.l,tO:M:' Petitioner < Respondent Charles Rector, Esquire Robert Mulderig, Esquire --fi . ;4' 1...,1 '1'.';0 'v /:" /::.. /i, "V~~;ik,-", R. J. adday, Conference Officer Date of Order: January 17,2001 rr 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, PA 17013 (717) 249-3166 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. ~f BOBBY R. HART, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :NO.00-8196 CIVIL TERM MARIE P. HART Defendant :CIVIL ACTION - LAW :IN DIVORCE PETITION FOR ALIMONY PENDENTE LITE 1. The parties hereto are husband and wife, having been joined in marriage on June 8,1968. 2. The parties separated in or about October 1, 2000. Plaintiff filed a Complaint in Divorce on November 21, 2000. 3. Defendant is without the ability to earn income sufficient to meet her reasonable needs and to pay attorneys fees. WHEREFORE, Defendant requests your Honorable Court to enter an Order alimony pendent lite in an amount equal to the Pennsylvania State Support Guidelines. Respectfully Submitted TURO LAW OFFICES / ~!;~ Date' , n ------ , II. CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Petition for Alimony Pendente Ute upon Charles Rector, Esquire, by depositing same in the United States JT' -p Mail, first class, postage pre-paid on the ;J( day of. <fLt!e#1fili(. ,2000, from Carlisle, Pennsylvania, addressed as follows: Charles Rector, Esquire 104 Fernwood Avenue, Suite 203 Camp Hill, PA 17011 TURO LAW OFFICES r Robert J. M 28 South Pi Street Carlisle, PA 17013 (717) 245-9688 Attorney for Defendant UT' !III, "'-I '.~, ,,,"~"'" .J''fIr",~~" ..i ,-"~ - ~ '",,-,-- " r'''' ,.,'." _,_C',_", ""'-"f' ['~' ':", i'r'ft1~."'f'T(n;'-':ft<~i4l>'':;'t'1 ~Fi'"-~ 0 c-' ~; ~ C::. \.",' --,'~. CJ 'Tj l.JC;. r-nrT" "1 ,":.'! ~f~; ,~'') Cr.I"'~ "" ~ ,. r~ , '- _r> ."'\! ..:'~ ; ::?!: 5C;;~~~, ~~) ,,,-' =-~i " , r" :::~ , , _LL, _J. rmll'ilt!ilI!IlI_~~jl'ffi!i:>m:_j'f,"'''''',JWliL\Fj!\''-W~'''l\>_-:?:1"~,I';'~''iM~~~ll;_jfW'!j)lll*\'%'\fll!l~_J!llil!i'~'i'I;-j!!7"ll"'~'lfJ!~1!;~1"1<W!!ll\i~~~~~~; AN,,;/~:'.'; 'jMcf'i':;~,~.,,- DR 30350 PACSES In 855102972 vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : DOMESTIC RELATIONS SECTION : CIVIL ACTION - LAW BOBBY R. HART, Plaintiff/Respondent MARIE P. HART, Defendant/Petitioner : NO. 00-8196 CIVIL TERM ORDER OF COURT AND NOW, this 6th day of February, 2001, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $2,006.88 per month and Respondent's monthly net income/earning capacity is $2,488.95 per month, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $233.00 per month payable bi-weekly as follows; $89.08 bi-weekly for alimony pendente lite and $18.46 bi-weekly for arrearages. First payment due on Respondent's next pay date. Arrears set at $386.00 as of February 5, 2001. The effective date of the order is December 21,2000. 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, ifthe 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 PA SCDU to: Marie P. Hart. 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. ,',."^"- "'.~I" - ,s#'t~if,}'.,:{:'0I,.. This Order shall become final ten days after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary for a hearing de novo before the Court. DRO: R. 1. Shadday Mailed ciies on D/-fl,o to: < i:'i BY THE COURT, Petitioner Respondent Charles Rector, Esquire Robert Mulderig, Esquire Edward E. Guido ~ J, I ,!Il!l.~" r.. ,. "'.~1!"1 'r'. e ,~ -..."'" "ll._IW_~, "' ~>." ~ "' '"' ,"~ _","~-,"~-"'.'-"",,,,'''-~''''' ~.' - --r ~ ~ '."z;l:dJ8.j;N~L~t;;;::J%jXO ,. (") c ?2f -;::.? ,~:_' 05, -< r,::: ,'~ ;f;[5 .,.>--"c - 7 ~":J -<: '-'1 c." a r) 71 ..." r''"! ~J.:J I '0 "U ::::: .:....) ;:;:-1 :'0 -~ 1II>'lI!~~~~_~~mm~~~;,~~~!f,,,,!;,,t<";;;'-'''''-;-'''''~>''''''';'''-'''!'T_";""-''''''''J--''f.'"'''~<!~'''''~'tlr1!'--rs:~'~~,..'''''''l''''':'';''''')."""''';'''''''''''''fW'',1!',,*~~$1II:Iil~~1 . ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT .?>A::t- OO-rJI9& {/If/!L State Commonwealth of Pennsvlvania )Jlq(!X;f~ f'75" /DJ-/l7 J.. Co./City/Dist. of CUMBERLAND ^ Date of Order/Notice 02/05/01 Ute. 30 3.)0 Court/Case Number (See Addendum for case summary) @ Original Order/Notice o Amended Order/Notice o Terminate Order/Notice ) RE, HART, BOBBY R. ) Employee/Obligor's Name (last, First, MI) ) 244-76-6108 ) Employee/Obligor's Social Security Number ) 3364100627 ) Employee/Obligor's Case Identifier ) (See Addendum for plaintiff names assodated with cases on attachment) ) Custodial Parent's Name (Last, First, MI) ) EmpJoyerlWithholder's Federal EIN Number WERT BOOKBINDING INC EmployerlWithholder's Name C/O PAYROLL EmployerlWithholder's Address 9975 ALLENTOWN BLVD GRANTVILLE PA 17028-8709 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's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 193,00 per month in current support $ 40.00 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) for a total of $ 233,00 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: $ 53.77 per weekly pay period. $ 107.54 per biweekly pay period (every two weeks). $ 116.50 per semimonthly pay period (twice a month). $ 233.. 00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877.676-9580 for instructions. Make Remittance Payable to: PA seDU Send check to: Pennsylvania SeDU, P.O. Box 69112, Harrisburg, Pa 17106.9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL.~ m'lll''' v:n DRO: RJ Sbadday ~, BY THE COURT: xc: defendant ,9 -~ Form EN-028 Worker ID $IATT Date of Order: February 6, 2001 Service Type M OMB No.: 0970-0154 Expiration Date: 12/31/00 ,I~" 11d -'. ~ , ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS D If checked you are required to provide a copy of this form to your empioyee. 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.* RqJUlt;115l11C Pa.yJdtelDl!tte vf'NilI.l,vIJ;1I5. '/ou lllust lepoJttLe paydate!date of nitl.l.oldil,g nl.ell sehdh,g tile paylllcllt. TI.e paydate!date of ..itl,I,oldi',g i. lI,e d~te "10 ..I,iel, OI"o""t ..". ..itl,l,dd 116,'" tl,u:i,,~16ycC', ....ge.. 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: 23H675470 EMPLOYEE'S/OBlIGOR'S NAME: HART, BOBBY R. EMPLOYEE'S CASE IDENTIFIER: 3364100627 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 Jump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are iiable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.' Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.c. 91673 (b)l; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes, 10. 'NOTE: If you or your agent are seNed 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 (717) 240-6248 or by Internet @ Page 2 of 2 Form EN.028 Worker ID $IATT SeNice Type M OMB No.: 0970-0154 Expiration Date: 12/31/00 ,',I~' ~, ADD,ENDUM Summary of Cases on Attachment Defendant/Obligor: HART, BOBBY R. PACSES Case Number 855102972 /JOJSO Plaintiff Name MARIE P. HART Docket Attachment Amount 00-8196 CIVIL $ 233,00 Child(ren)'s Name(s); .- . DaB ... ... .. ... n." ", '...,'".,.,....,."., , . . . ..,. .. . . . .. . . "',....'... ....'...........'.. . . . . ." ......... [j If che~ked,you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s); DaB ,::\':::":",,",,,:.:'::::',:,'::':::::',:,::::,:':::::':':"(':':,::'"(":')::,,,,':,.::',:.:,:::,,,:::::,::::::::\,:::::t::.:::::.::::.,:::::::,:':::::::,::,::::,:,,:::.:::..:::,::::,:=:::,:: d I;ch~~k~d,y~~~;e;~~~i;~d ;~~~r~lltl1e ~hild(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); DaB ... ........ .... ',:.' ..',.:. '......':..,.".:,': ... ".., ..... df cl1~~k~d,;~u are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. Addendum SeNice Type M OMB No.: 0970-0154 Expiration Date: 12/31/00 -? e ~"" , "''I"I . ' ." PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s); DaB ..: :..:;',':,':,':;':,:"""':;":;':',"',::' :. ",',' :"':,":':::::,"::':;':,':"":":,": :.:,: ',',' d If ~h~~k~d,y~~~r~;equired to enroll the ~hild(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); DaB ...E1I;~~:~~:~:;~~..'~;:;:~~i;:~';~:~;~II..':~:~.~.;'~~;:~; .,... ...,...'".., '..' ,', identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s); DaB bl;~~~~~:d:;~~a;:;:~~i;:d to enroll the child(ren)< identified above in any health insurance coverage available through the employee's/obligor's employment. Form EN-028 Worker 10 $IATT ,. - "" ,U,t,w" ~ "" " -"- <~r~' , '..,'< ,~, -~.. ,~ ' ,~'~h".,. ,~~~ ~, () C t+1' {f/ :;;:..C:,j ;.:p' !;Dj~-, ;i,:~ ~-,".( J ~'""'c:' .:;.::: -, -< :.n ,-.. -, ;< . ~ c::: -.. ::~) ?r '::'~; I '.0 ."D :',J .~, ,\;~U~~'t~'~_'lT'_~~I!;lij)\IW.f;;'lnH!~~ml'll-Il'"'B''''-'~'-IA:;'',''''''"'''-' ,'",'i"'''',-'-, '''''''",' -'",<,.,r;,':SW","W1'!~n""'1"1mj!~'l!"-!F'Jj",,"'''}"--r*-,'''':''''''i'~'''~--~>''"''-!1i'!1~''':J!'5~~~~ 11' I il I; !i I I BOBBY R. HART, I! Plaintiff " I II v. MARIE P. HART Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO.00-8196 CIVIL TERM :CIVIL ACTION - LAW :IN DIVORCE NOTICE OF SERVICE OF DEFENDANT'S FIRST SET OF INTERROGATORIES TO PLAINTIFF TO: PROTHONOTARY SIR: Please be advised that on March 15, 2001, an original and two copies of the Interrogatories of Plaintiff, BOBBY R. HART, were served upon counsel for Plaintiff: Charles Rector, Esquire Law Office of Charles Rector, Esquire 1104 Fernwood Avenue, Suite 203 Camp Hill, PA 17011 by ordinary mail to the above address. Respectfully Submitted TURO LAW OFFICES 3)/J-;6/ Date Robert J. Iderig, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Defendant ... :i ;1 'I. t ~1 '" .~'" ,.' "~ ~~ ~' , ", '~\l,~,~~ ,~~~~iMlMl'!'II C~ .." ~- - ,"'-" '1~";" ", ""=,"' ~,,,,,, ""'~ ," -'. ,,'~ ' , '"',h" ~. (") C) C) C -n <" :1t: -oft) , ,wj mr-r, J';z- '-';~",,:iJ Z:n A' '~ &5r -::i~-;-? r,;" en ':';;" ~e'j ~ ~~C) :r~ . ---,.' -,', -~~ {~,? f~ zO .... ~>2 i'.:J (:~rq ~ :z ::,..) :;.: =< :1) _I -: ~,~"r:'rr_",w",__,.t'",,,~,,_JI~~l'f",l-f!!';i'~1'M~~"?fCMbW'I\;'>l'~1!"'"~i!M~~~,\1l~illl~IJlI~..44~ur~f ~,-,__i',' State Commonwealth of pennsvlvania Co./City/Dist. of CUMBERlJ\ND Date of Order/Notice 10/18/01 Court/Case Number (See Addendum for case summary) ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT J;;Rr 00 -7/9(,;, ed,?c ;J/fCtf'S' Y5J/OJ-..97,;}. ~ df.&3SV o Original Order/Notice @ Amended Order/Notice o Terminate Order/Notice )RE:HART, BOBBY R. ) Employee/Obligor's Name (Last, First, MI) ) 244-76-6108 ) Employee/Obligor's Social Security Number I 3364100627 ) Employee/Obligor's Case Identifier ) (See Addendum for plaintiff names assodated with cases on attachment) ) Custodial Parent's Name (Last, First, Mil ) Employer/withholder's Federal EIN Number WERT BOOKBINDING INC Employer/Withholders Name C/O PAYROLL EmployerlWithholder's Address 9975 ALLENTOWN BLVD GRANTVILLE PA 17028-8709 See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMA TlON: This is an Order/Notice to Withhoid 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. $ 193.00 per month in current support $ 0.00 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 $ 193 .00 per month to be forwarded to payee below. You do not have to vary your pay cycie 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: $ 44.54 per weekly pay period. $ 89,08 per biweekly pay period (every two weeks). $ 96.50 per semimonthly pay period (twice a month). $ 193.00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCOU Send check to: Pennsylvania SCOU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: Date of Order: OCr 1 9 7nOl Form EN-028 Worker ID $IATT Service Type M OMB No.: 0970.0154 Expiration Date: 12131/00 --'", 1 ~, ll'~ ?, ,- ^'- ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If checked you are required to provide a copy of this rorm 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 ta)( 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. * Repoltillg tile.. PaydMe/D~h:, ufVlitl.l.oldihg. ~/6t1llltl~t lepolt tile pay date/date of vvitLL6lJ;1I5 nlleh 3ehdillg tLG payllld Il. The p"lyJQbdJ.rte of nitl.IIOldillg: is tl.<;; date VII vvl.id. ad.oullt vvA& nitLI.clJ hOhl tLe eh,ployee's ndge.!o. 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 rorward 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 rollow 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. iermination 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: 2316675470 EMPLOYEE'S/OBLlGOR'S NAME: HART , BOBBY R. EMPLOYEE'S CASE IDENTIFIER: 3364100627 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 Jump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable ror 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. ~ 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 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 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 ID $IATT Service Type M OMS No.: 0970-0154 Expiration Dale; 12/31/00 :" I t1,"'7"'~ '" ADDENDUM Summary of Cases on Attachment Defendant/Obligor: HART, BOBBY R. 855102972;(3D~?t) / PACSES Case Number Plaintiff Name MARIE P. HART Docket Attachment Amount 00-8196 CIVIL$ 193.00 Child(ren)'s Name(s): DOB D If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB D If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee'sJobligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB '.dli.~~~~'~~~;"~~~;;~;~~~i;:~";~.~~;~;::~~~~il~i;~~;it..,.,../..... identified above in any health insurance coverage available through the employee's/obligor's employment. Addendum Service Type M OMB No.: 0970-0154 Expil'il.tion Date: 12/31/00 ,-"~~...... ~I . " PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB D If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB D If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Form EN-028 Worker ID $IATT ,- 0 0 0 c.: -n <'~ C") ::::;:J ~)G::; n ::.~::;: '--n r.p q~' --4 "':,~;f.3 -"-- ..~' i'''' ZC;~_, ':Q :c, w <""} , !<: c~: .'0 :'~j ~:;~ ~c ~~,. C)5 --"'" .L-C) C" c:srn Pc:: 7' ~ ::< 0 :Q 0 I " Ii " II " [j Ii Ii II 1'1 II ," I Ii !:i ~: " i I': Ii Ii _Ei~~~""~~ ",~ "'1, !flU_ ~,.~___Wlft,~~"~"i'J.'0'",,,,.;Y;j:"'n,,O'F"":''':;'''.''''''''-''';''''W~'7~\'?'f!1n"""f!f~-'''1ii!}:[''f,':ij,"""''if'''~'',",'''I'llIIJinf5l!1~111iQ1~~~ M " ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT );tfl ~bt?O - [J/9(.o (11 t//(.. State Commonwealth of pennsylvania !Mrlt.f )?S5 10;;1..<( 7 d- Co./City/Dist. of CVMBERLAND 'o~ r7J Date of Order/Notice OS/21/02 !JK... 6ltJ..:J.D v Court/Case Number (See Addendum for case summary) o Original Order/Notice o Amended Order/Notice o Terminate Order/Notice ) RE: HART, BOBBY R. } Employee/Obligor's Name (Last, First, MI) ) 244-76-6108 ) Employee/Ob.ligor's Social Security Number ) 3364100627 ) 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 WERT BOOKBINDING INC EmployerlWithholder's Name C/O PAYROLL EmployerMlithholder's Address 9975 ALLENTOWN BLVD GRANTVILLE PA 17028 8709 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's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 193.00 per month in current support $ 40.00 per month in past-due support Arrears 12 weeks or greater? Oyes @ no $ 0.00 per month in medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ 233.00 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: $ 53 .77 per weekly pay period. $ 107.54 per biweekly pay period (every two weeks). $ 116.50 per semimonthly pay period (twice a month). $ 233.00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's! obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: J: Date of Order: MAY 2 2 2002 Service Type M ~mf~~~t!!;J~!,~M.B ~o.: 097(M}154__ J~ .- ;)~ -- '----~";--,-..,~-"._lxplratlon Date; 12/31/00-" .,.,..____ 4J- < --"'----,~-..-., -,f'i'l!'!^ !r , ~I . III ~ w - 4 ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS D 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. Ilthere are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining P<lyments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that Is attributable to each employee/obligor. 3. * R-epolting tLe PaydatelDate of 'Iv'itkl,olding. '/51:1 must repcHt tll~ paydMe!d~ of ~vitLLoldil,g vvl.ell sehding tile pAYlllelll. TLe paydaleldale of ..itl,l,,,ldilog is the dale "A ..I,i(h amouAt ..as ..ithheld from tk c'"pl"yec', ..ages. You must comply with the law of the state of the employee'slobligor'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 Federaror 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: 2316675470 EMPLOYEE'S/OBLlGOR'S NAME: HART, BOBBY R. EMPLOYEE'S CASE IDENTIFIER: 3364100627 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 withheid 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 L1.S.c. ~1673 (b)l; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applie, 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. Requesti ng 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 ID $IATT Service Type M OMB No.: 0970-0154 Expiration Date: 12131/00 ''-~:'" .'T". ~'" '~I .. I' ~ ~~ ADDENDUM Summary of Cases on Attachment Defendant/Obligor: HART, BOBBY R. PACSES Case Number 855102972;GO~50 Plaintiff Name MARIE P. HART Docket Attachment Amount 00-8196 CIVIL $ , 233. DO Child(ren)'s Name(s): ;.-:r ~ 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. PACSES Case Number Plaintiff Name Docket Attachment Amount $ O. DO 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. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB t::J;;~~~~~~, ;~~~r~;~~~i;e~;~~~r;II;~~ ~hil~(;~~)'. < ....,.. ..' identified above in any health insurance coverage available through the employee's/obligor's employment. Addendum Service Type M OMB No.: 0970-0154 Expiration Date: 12/31100 "i~~-l"1 ''9 "1 , " 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. 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. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB .'2i;;~~~~k~~, ;~u~rer~~~i;~;o.'~~;~ii;~~~~il~;;en).... .,,' identjfied above in any health insurance coverage available through the employee's/obligor's employment. Form E N-028 Worker ID $IATT II' "w, ~",'"', -j;,~ !,.^~ ~ <' '~ W' ~ _ ~~~, Th'___ "'1 !l~~I!>ti~t~ffl'ROOH'l'!I!~~~if_"~l!l!'[tWI~"'~'~""", .. ~' .~ --~~,~ ,-,~" I" ,~- ..." () r~:- () C i~J " 1 -s: ::~ 'T) C--' ~;;:;>'! .::---' nl L:" -' ;::: - z L r-c) , ~ CJ " C(I r:: --,---. c,~ 5;; c. ,'~ ::J "'/ -- """""1-" ~,--- C) )>~~ C.y ,."", :n ::::; .,,<~ '" -""" :::;! :0 f'-") -< '"'(':""'''''''''''4''F",''i~UI{'"''?'','M''-'',f~''7~'';''''~'''F",,-,,,CF';'''''''''''1q'f!'*'I:N!il:l1,'(l~~~~ , ' ", ,.,--' -io , , ORDER/~._ f1CE TO WITHHOLD INCOME FOR SUPL.<T )X/ 2000- &,/9(" (l i t//C State Commonwealth of Pennsvlvania !))t.!9ES' 9~-'5 1(>;;I.17.) Co.lCity/Dist. of CUMBERLAND . Date of Order/Notice OS/29/02 i:K- dlO.3.5t) Court/Case Number (See Addendum for case summary) o Original Order/Notice o Amended Order/Notice o Terminate Order/Notice ) RE: HART, BOBBY R. ) Employee/Obligor's Name (last, First, MI) ) 244-76-6108 ) EmployeelObJigor's Social Security Number ) 3364100627 ) Employee/ObligOr's Case Identifier ) (See Addendum' for plaintiff ~ames associated with cases on attachment) ) Custodial Parent's Name (Last, First, Ml) ) . EmployerlWithholder's Federal EIN Number WERT BOOKBINDING INC EmployerlWithholder's Name C/O PAYROLL EmployerlWithholder's Address 9975 ALLENTOWN BLVD GRANTVILLE PA 17028-8709 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. $ 193.00 per month in current support $ 0.00 per month in past-due support Arrears 12 weeks or greater? 0 yes @ no $ 0.00 per month in medical support $ 0 . 00 per month for geneti c test costs $ per month in other (specify) for a total of $ 193.00 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 ordererl <"nnort payment cycle, use the following to determine how much to withhold: $ 4~ _ 54 per weekly pay period. $ , 8. OB;per biweekly pay period (every two weeks). $ 96.50 per semimonthly pay period (twice a month). $ 193.00 : 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 paydateldate 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 S5% 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/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCOU Send check to: Pennsylvania SCOU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: Service Type M , , " J: fJ''''91'</ t t. , ~MB No.: 0970.{l154 iI !)-~(),.,.,O~, .,~ Expiration Date: 12131/00 Tu'(,.ic' Form EN-028 Worker ID $IATT Date of Order: MAY 3 0 200z ~~~~' " 10' , ,I' '" " .~~, " ,,' , ''';:''000 ADDITIONAL I"'. JRMATlON TO EMPLOYERS AND OTHER,. iTHHOLDERS 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. * RepOlti"g II" ,"aydalelDate of Wilhl,oldiog. You n,u.t "pOI! 11.. pa,datl'idat. of "itl,l.oJd;',g ,,1,.1, se"di"g tl,. ""l,'e,,!. The p"da",'datc of ,,;tl,l.oldll,g i. Il,e date 0" ,,1,;<1, .."ount ,,^, ,,;II,l.dd fwnoll,. .n,plo,".'. "age.. You must comply with the law of the state of the employee's/obligor's principal place of employment wilh respect to the time periods within which you must implement the withholding order and fOlWard the support payments. 4. * EmployeelObligor with Multiple Support Holdings: if there is more than one OrderINotice to Withhold Income for Support againstthis employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholdinglimits, you musl follow the law ofthe state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly nolilY 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: 2316675470 EMPLOYEE'S/OBLlGOR'S NAME: HART , BOBBY R. EMPLOY~E'S CASE IDENTIFIER: 3364100627 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 employeelobligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law govems 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 (lischarging an employeelobligor from employment, refusing to employ, ortaking disciplinary action against any employee/ohligor 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 (1 5 U.S.c. ~1673 (b)l; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies,to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 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 ID $IATT Service Type M OMB No.: 0970-01 S4 Expiration Date: 12/31/00 -~,_Rl~1l'R>'~"':"t'~'1!~ll-~~,"',''',*''''''''~S0W"'!'':''''fIll~'''''W'i'!fm';~~1'i1'!!,';llr.8if,W!liHWilN';"" ,,',_,..c,_ """~,,,",,,,,,,,,,,,,,.",,.,, '~'"'''''''''A!<'-'?',''-C-''''' "-,,"",:'rl,,,,--,'~n;;T~1[-'" ,<rJ'1~>r>j~~~, ~ ...... . ADDENDUM Summary of Cases on Attachment Defendant/Obligor: HART, BOBBY R. PACSES Case Number 855102972;30;3.50 Plaintiff Name MARIE P. HART Docket Attachment Amount 00-8196 CIVIL$ Child(ren)'s Name(s): 193.00 DOB you are required to enroll the child(ren) in any health insurance coverage available through the employee'sfobligor'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'sfobligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB you are required to enroll the child(ren) in any health insurance coverage available employee's/obligor's employment. Addendum Service Type M OMS No.: 0970-0154 Expiration Date: 12/31/00 llb",,'1' TI PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB , If you are required to enroll the child(ren) above in any heaith in,surance coverage available the employee'sfobligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB you are required to enroll the child(ren) 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 you are required to enroll the child(ren) in any health insurance coverage available the employee's/obligor's employment. Form EN-028 Worker ID $IATT ", i , i: I , ,I 11 Ii Ii Ii il i; ii I' I i'l ji " 11 !i I; , I i' i, 'I I , ! ,,~ _1lI':I!~I- ~ "-"-~ ,"' ~,~. "- .", HIiiI1Illt1i " JJ il!!Jl!'1jl/Mi~Ah""Wll'!mj'lW1)11'J'i~i')!l""''''110'!~1l!~ll!4'1<1'!, - ~" -., r" . .->'" J~~li!i;jJc'!",,,..-;"''''~'~'''.- , , () C) ~(; c::: ,-',.J ::~: -". " -'''' -C] ~!~i "= lTl --< .:;-~ " '/' j" :_-~) ~; - ~:::: c.:: -0 ~.-';,> , .~~ , ,- ).~~ ., --" :'~':J -< ....;,,;. ,<_"<,,,,'-,- . ""., ,,~, T""",Ff.l(" ,,,,,,,,'i'l"';'lo:)i'1,-;;;Y,,,,",~''',C. '''''':<''T-<P~I''lYWlq"':J;''H$l~~~~~ BOBBY R. HART, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-8196 CIVIL TERM MARIE P. HART, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO WITHDRAW TO THE PROTHONOTARY: Please withdraw Counts I, II, III IV and VI of Defendant's Answer and Counterclaim to the Complaint in Divorce in above-captioned matter. RESPECTFULLY SUBMITTED, Robe a. Mu derig, E Turo aw Offices 32 S. Bedford Street Carlisle, PA 17013 Attorney for Defendant Date: ?P.J!o"c- . , - '""~'I-~, - ~ -,"" " "'-,~ ,"',' , ,~,~ II I BOBBY R. HART, Plaintiff V. MARIE P. HART, Defendant TO THE PROTHONOTARY: : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO, 00-8196 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO WITHDRAW Please withdraw Counts I through IV of Plaintiffs Complaint in Divorce in above- captioned matter. Date: 4 .n ~J - ""I',r-,:""'" '~-'~, _-'- .,',-"," ,v' RESPECTFULLY SUB D, ,'~' ,,~~,'", y, 00 ~-'" , ,~ '1, -'I ~ ,,... . ~ State Commonwealth of pennsylvania , Co./City/Dist. of CUMBERLAND Date of Order/Notice 10/15/02 Tribunal/Case Number (See Aodendum for case summary) ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT &! ~ooo- fiN&, {J,/p'/G "",;JC)f-S ?~v/OA97'> ,b.l? ,50.350 o Original O~der/~otice " o Amended 6rded~?t,i:e ' @ Terminate Order/Notice RE: IlART, BOBBY R. WERT BOOKBINDING INC C/O PAYROLL 9975 ALLENTOWN BLVD GRANTVILLE PA 17028-8709 Employee/Obligor's Name (Last, First, MI) 244-76-6108' Employee/Obligor's Sodal Security Number 33641006,27 ' Employee/Obligor's Case Identifier (See Addendum for plaintiff names . associated with cases on attachment) Custodial Parent's Name (Last, First, MI) EmployeriW1thhold~r's Federal EIN Number 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 deductthese 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 $ o. ooper month in past'due support Arrears 12 weeks or greater? 'Oyes@ no $ , 0.00 per month in medical support $ 0 . 00 per month for genetic test costs $ per month in other (specify) for a total of $ 0.00 per month to be forwarded to payee below., You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 0 . 00 per weekly pay period. ' , $ o. ooper biweekly pay period (every two weeks). $ 0.00 per semimonthly pay period (twice a month). $ 0.00 permohthlypay 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 Tee, cannot exceed 55% of the ernployee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitationonWithholding,the following information is needed (See #1 0 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and DisbursementUnil (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: PennsylvitniaSCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MVSTlNCLUDETHE 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 MAl!. Date of order:--azf 17 20.;/2- , , ,';T'Lf:,D ," 11 .~ ::M IP' /0..... l.lMB No.: 0970-0154 Service Type M ..::rv~t,c Form EN-028 Worker ID $IATT ~. ~r {)/L" / G, '<'I " II, ,~. - , ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS Dlf ~hecked you arerequired to provide a Copy of this fOl111 to your employee. If youremployee works in a state that is d,itterent from the state that issued this order, a copy must be provided to your employee even if the box is not checked. 1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned businesses located on a reservation that choose to withhold.in accordance with this notice. 2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 3. C;:ombining Payments: You can combine withheld amounts from more than one employee/obligor's income in,a single paymenUo each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. ' 4. * Rep",ti, ,g tI,e Pa,dote/D.m ofWilhholding. Yournust lepM lI,e pa,date/d"'" of ..ill'[ ,oldilog ..hen'sendilog the pa""e..t. T;,e payda-tefdate of vvitlllloldil,g;3 tI,e dAte Oil vvhid, amaullt vva,5 vvitl,l,eld {,olll tlle elllploye~'3 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. 5. * Employee/Obligor with Multiple Support Holdings: If there is morethan one Order/Noticeto Withhold :,nCbrlle for Support against this employee/obligorand you are unable to honorallsupport.Order/Notices due to Federal or State withholding limits, you mu~tfollow the law of the state of employee's/obligor's principal place of employment. You, must honor all Ord,ers/Notices to the greiltes!extent possible. (See #10 below) , , 6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'SID: 2'316675470 ' EMPLOYEE'S/OBlIGOR~S NAME: HART ,BOBBY R. EMPLOYEE'S eASE IDENTIFIER: 3364100627 DATE OF SEPARA.TION: LAST KN()WN H,OME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 7. lump SumPilymenu;:, You may be required to report .nd withhold from lump sum payments such as bonuses,commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. ' 8. LiabiHty: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State laW, Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. Anti-discrimination: You "resubject to a fine determ.ined under State lawlor discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because,ofa support withholding. Pennsylvania State ,law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 10. * Withholding LiiTlib: You may notwithhold more than the le~serof: 1) the amourits~lIowed by the Federal Consumer Credit Protection Act (15 U.s.c. 91673 (b)l ;or 2) the amounts allowed by the State oftheemployee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net inc~me ieft after making mandatory deductions such as: State, Federal, local taxes; Social Security taxesi and Medicare taxes. 11. Additional Info: *NOTE:, If you or your agent are served with a copy of this order in the state that issued the order,you are to follow the law of the state that issued this order with respect to these items. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obi igor have any questions, contact WAGE, ATTACHMENT UNIT by telephone at (717) 240-6225 or ,by FAX ,at (717)240-6248 ,or .' by internet www.chi.ldsupport.state.pa.us Page 2 of 2 For"m EN-028 ,INorkerlD $IATT Service Type M OM,B NO.i 0970-0154 ';"''r",~'' 'i- ~~I "' ,-- ;->1 '. o c <'" ""0 ~..... mrr-p 2-1) zC' (f) .1-;'. ;:$;:" -:::::. '-,~ ~C) ~O S;;;; ~ I , i I ) ! I ;) J "I ;1 , " ,] :1 , ;! ~'Y ...,) r~ , _. C 1'.) a ,') '--I I'J W o .....'1 ,...; ,- "I,]J ";-<j;"n ~fJ9 ::,,,,~~ (:) T"'f ')~ 3~1 -... )~ -.~ ~J -( ~ , ~~'<lI~~!III!!JI~~~~~~""?,"~Mm'1!!);''!%H~'"w",'",~''n,,,r<'':]f'''''''i;r"'''''~;:;''''''''!''''''''T'"'~'';!,'jf$!'p;;j'!~~I""",!',",'!lllf'i''f''-'W';W!W.''''''':'''!1il'-fEf,'!'f'MI''I!J,J]I!!li!~~ " -= ";\' In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELA'lI'IONS SECTION BOBBY R. HART, ) Docket Number 00-8196 CIVIL Plaintiff/Respondent ) VS. ) PACSES Case Number 855102972/D30350 MAR1E P., HAR-T, ) Derenillmtpetitioner ) . Other State ID Number ORDER AND NOW, to wit, on this 28TH DAY OF OCTOBER, 2002 IT IS HEREBY ORDERED that the support order in this case be 0 Vacated or OSuspended or (i) Terminated without prejudice or 0 Terminated and Vacated, effective OCTOBER 10, 2002 ,due to: THE PARTIES DIVORCE DECREE OF OCTOBER 10, 2002. THERE IS NO BALANCE DUE THE PLAINTIFF. DRO: RJ Shadday xc: plaintiff defendant Charles Rector, Esquire Robert Mulderig, Esquire BY THE COURT: '~."~." ~f,~j " /I.I-f);) Service Type M Form OE-504 , Worker ID 21005 -'''''t<l'''''m'"'''~i -'.,' """"TI Of!! (p " . -. .l",,,,,",I(U~_""'~~~~~~~~'~iJiUJl ~; c~t ~ g~~ ;"""~ 1... _ ':--'- :5:~~ -" -< -- :::5 L,__ r:- :::> (Jl ::-=-, ~,-,. ?c. ::<, ,It!Iil!Y~ijWl',,,,,",'''"''''' ,",,,.f'". 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