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AND NOW, . . . .J:~l)\lP.J::Y. . . ..~. 'i. . . . . . . " u. ~OP.~, it is ordered and
decreed that .......... NA'fHAN. .K. . SY.BRANnT. . . . . . . . . . . . . . . . " plaintiff,
and. . . . . . . . . . . . . .~~C!l.E.I,r,~. P... . S;l~~~~P.T. . . . . . . . . . . . . . . . . . . " defendant,
are divorced from the bonds of matrimony.
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The court retains jurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet
been entered;
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MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT, made this es+h- day of........ C' 0 ",,-b1J\ , 200l, by and
between RACHELLE D. SYBRANDT (hereinafter called "Wife") and NATHAN K.
SYBRANDT (hereinafter called "Husband").
WITNESSETH:
WHEREAS, Husband and Wife were married on May 21, 1999; and
WHEREAS, There have been no children born of this marriage; and
WHEREAS, the parties hereto desire to fix and determine by this Marital Settlement
Agreement the rights and claims that have accrued to each of them in the estate and real and
personal property of the other by reason of the marriage, and all economic rights of every kind
and description arising from the marital relationship, including but not limited to present and
future rights of inheritance, support, maintenance, alimony, payment of counsel fees and
equitable distribution and to accept the provisions of this Agreement in lieu of and in full
discharge, settlement and satisfaction of all such rights and claims.
NOW, THEREFORE, in consideration of the premises and of the marriage, and in further
consideration of the mutual promises and undertakings hereinafter set forth, each intending to be
legally bound hereby, the parties agree as follows:
1. SEPARATION. It shall be lawful for each party at all times hereafter to live
separate and apart from the other party at such place as he or she may from time to time choose
or deem fit. The foregoing provisions shall not be taken as an admission on the part of either
party of the lawfulness or unlawfulness of the causes leading to their living apart.
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2. INTERFERENCE. Each party shall be free from interference, authority and
contact by the other, as fully as if he or she were single and unmarried except as may be
necessary to carry out the provisions of this Agreement.
3. WIFE'S DEBTS. Wife represents and warrants to Husband that as of the date of
separation she has not incurred, and in the future she will not contract or incur, any debts or
liability for which Husband or his' estate might be responsible and shall indemnify and save
harmless Husband from any and all claims or demands made against him by reason of debts or
obligations incurred by her. Any and all loans, and/or debts and charge accounts, and all medical
bills, presently in Wife's name alone shall be Wife's sole and separate responsibility for payment
thereof, and Wife agrees to indemnify and save harmless Husband from any loss he may sustain,
including attorney fees, as a result of any default in payment by Wife.
4. HUSBAND'S DEBTS. Husband represents and warrants to Wife that as of the
date of the separation he has not incurred, and in the future he will not contract or incur, any debt
or liability for which Wife or her estate might be responsible and shall indemnify and save
harmless Wife from any and all claims or demands made against her by reason of debts or
obligations incurred by him. Any and all loans, and/or debts and charge accounts, presently in
Husband's name alone shall be Husband's sole and separate responsibility for payment thereof,
and Husband agrees to indemnify and save harmless Wife from any loss she may sustain,
including attorney fees, as a result of any default in payment by Husband.
5. EOUITABLE DISTRffiUTION. Husband and Wife acknowledge and agree that
the provisions of this Agreement with respect to the distribution and division of marital and
separate property are fair, equitable and satisfactory to them based on the length of their marriage
and other relevant factors which have been taken into consideration by the parties. Both parties
hereby accept the provisions of this Agreement with respect to division of property in lieu of and
in full and final settlement and satisfaction of all claims and demands that they may now have or
hereafter have against the other for the equitable distribution of their property by any court of
competent jurisdiction pursuant to Section 3502 of The Divorce Code or any other laws.
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Husband and Wife voluntarily and intelligently waive and relinquish any right to seek a court
ordered determination and distribution of marital property, but nothing herein contained shall
constitute a waiver by either party of any rights to seek the relief of any court for the purpose of
enforcing the provisions of this Agreement.
6. DIVISION OF PERSONAL PROPERTY. ACCOUNTS AND VEHICLES. The
parties have divided between them, to their mutual satisfaction, the personal effects, bank
accounts, household furniture and furnishings and all other articles of personal property which
have heretofore been used by them in common.
The parties expressly agree that Wife shall be entitled to exclusive ownership of the 2001
Subaru currently in her possession, and that Husband shall relinquish any and all interest he may
have in same. Husband agrees to be solely responsible for payment of the balance of the loan
thereon to PSECU in the approximate amount of $16,825.00, and shall indemnify and save
harmless Wife from any loss she may sustain, including attorney fees, as a result of any default
in payment by Husband. Wife agrees to be solely responsible for payment of all other expenses
affecting such vehicle. Wife agrees to indenmify, reimburse and save harmless, and forever
defend Husband from any loss he may sustain, including attorney fees, as a result of any default
in payment by Wife. Husband shall be entitled to exclusive ownership of the 1995 Buick
currently in his possession, and that Wife shall relinquish any and all interest she may have in
same. Husband agrees to be solely responsible for payment of any and all encumbrances, and all
other expenses affecting such vehicle. Husband agrees to indenmify, reimburse and save
harmless and forever defend Wife from any loss she may sustain, including attorney fees, as a
result of any default in payment by Husband.
The parties further agree to execute any vehicle titles, Powers of Attorney or other
documents necessary to give this Paragraph full force and effect, within fifteen (15) days upon
request of either party.
7. PENSIONS AND EMPLOYMENT BENEFITS. Husband and Wife are the
owners of certain pension plans and/or retirement plans and/or employee stock or savings plans,
which they have accumulated during the course of their past and/or present employment. It is
3
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hereby specifically agreed that Husband and Wife each shall forever relinquish to the other his or
her right, title and interest in said pension plans and/or retirement plans and/or employee stock or
savings plans, as well as all other employment benefits, of the other. Specifically included
herein are all benefits to which Husband is entitled through his employment with Penn National
Gaming. The parties agree to execute any and all documentation necessary to effectuate the
terms herein contained.
8. ALIMONY. Husband shall pay directly to Wife the sum of $775.00 per month as
alimony, commencing October 1, 2001, and continuing on or before the first day of each month
thereafter for a period of twenty (20) months, at which time it shall terminate. Thus, the Order
for alimony pendente lite dated March 6, 200l in the Court of Common Pleas of Cumberland
County shall terminate effective September 30, 2001.
Husband's obligation for alimony shall terminate in the event of Wife's death or
remarriage. Alimony shall otherwise not be subject to modification by either party.
For income tax purposes, alimony specifically shall be a deductible expense for Husband
and includable as income for Wife.
The parties acknowledge that the alimony provision set forth herein may be payable and
enforced through the Domestic Relations Office of Cumberland County or any other court
having appropriate jurisdiction upon request of either party.
9. WIFE'S AUTOMOBILE ACCIDENT. Husband hereby waives any and all
claims to an award secured by Wife as a result of the lawsuit she filed because of her automobile
accident in August 2000. Husband agrees to sign any releases required by Wife's attorney in
that lawsuit as well.
10. COUNSEL FEES. Husband and Wife agree to be solely responsible for payment
of his or her attorney fees in connection with this Agreement and the pending divorce action
between the parties.
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ll. HEALTH INSURANCE. Husband agrees to maintain health insurance coverage
on behalf of Wife until such time as a final decree in divorce has been issued. Post-divorce,
Husband shall cooperate with Wife's efforts to obtain health insurance under the COBRA law.
l2. FINANCIAL DISCLOSURE. The parties acknowledge that each has disclosed to
the other the full extent of his or her income, assets, liabilities, holdings and estates and that, in
reliance on the full disclosure, each forever waives any right to set aside said Agreement, or to
defend against its enforcement or any portion thereof based upon the absence of such disclosure
by the other party, or based upon any claim that it is inequitable, unconscionable or does not
make a reasonable provision for one or the other of them.
13. SUBSEOUENT DIVORCE. Nothing herein contained shall be deemed to
prevent either of the parties from maintaining a suit for absolute divorce against the other in any
jurisdiction, nor to bar the other from demanding any such suit.
l4. NO-FAULT DIVORCE. Both parties agree to execute an Affidavit of Consent
and Waiver of Notice of Intention to Request Entry of a Divorce Decree to facilitate entry of a
divorce decree pursuant to Section 3301( c) of the Divorce Code contemporaneously with
execution of this Agreement. Husband shall be responsible for finalizing the divorce, and shall
provide Wife with a certified copy of the final decree in divorce after it has been issued by the
court.
15. BREACH. If either party breaches any provisions of this AgreeqJ.ent, the other
party shall have the right, at his or her election, to sue for damages, including attorney fees, for
such breach, or seek such remedies or relief as may be available to him or her respectively.
16. ADDITIONAL INSTRUMENTS. Each of the parties shall from time to time, at
the request of the other, execute, acknowledge, and deliver to the other party any and all further
instruments, including Deeds and other real estate-related documents, titles, pension documents,
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or other documents that may be reasonably required to give full force and effect to the provisions
of this Agreement.
17. VOLUNTARY EXECUTION. The provisions of this Agreement and their legal
effect have been fully explained to Husband by Max J. Smith, Jr., Esquire, attorney for Husband.
Each party acknowledges that the Agreement is fair and equitable, that it is being entered into
voluntarily, and that it is not the result of any duress or undue influence.
l8. WAIVER OF CLAIMS AGAINST ESTATE. Except as herein otherwise
provided, each party may dispose of his or her property in any way, and each party hereby
waives and relinquishes any and all rights he or she may now or hereafter acquire, under the
present or future laws of any jurisdiction, to share in the property or the estate of the other as a
result of the marital relationship, including, without limitation, dower, curtesy, statutory
allowance, widow's allowance, right to take property against the Will of the other, and the right
to act as administrator or executor of the other's estate, and each will, at the request of the other,
execute, acknowledge and deliver any and all instruments which may be necessary or advisable
to carry into effect this mutual waiver and relinquishment of all such interest, rights and claims.
19. INCORPORATION OF AGREEMENT FOR ENFORCEMENT. This
Agreement shall bind the parties hereto and their respective heirs, executors, administrators,
legal representatives and assigns. This Agreement shall survive a decree of divorce between the
parties in any jurisdiction and any other order which may be entered in accordance with this
Agreement. When a Decree of Divorce is entered in the Court of Common Pleas of Cumberland
County, Pennsylvania or in the event that a Decree in Divorce is entered in any other jurisdiction,
the parties agree to incorporate this Agreement in the Divorce Decree for purposes of
enforcement. It is the specific intent of the parties to be bound by the provisions hereof in lieu of
any other claim or order of support, maintenance, alimony, equitable distribution, counsel fees,
costs, maintenance of insurance, equitable relief or property settlement or with regard to any
other provision hereof. In the event that any final order of court is entered in any jurisdiction
with respect to the parties hereto which is contrary to the provisions hereof, then the rights and
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responsibilities of each of the parties hereto shall be relieved or adjusted to the extent necessary
to conform to this Agreement.
20. ENTIRE AGREEMENT. This Agreement contains the entire understanding of
the parties, and there are no representations, warranties, covenants or undertakings other than
those expressly set forth herein.
21. MODIFICATION AND WAIVER. A modification or waiver of any of the
provisions of this Agreement shall be effective only if made in writing and executed with the
same formality as this Agreement. The failure of either party to insist upon strict performance of
any of the provisions of this Agreement, shall not be construed as a waiver or any subsequent
default of the same or similar nature.
22. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for
convenience only. They shall have no effect whatsoever in determining the rights or obligations
of the parties.
23. IRREVOCABILITY. It is understood and agreed to by and between the
respective parties hereto that the property distribution and alimony provisions set forth in the
herein Agreement are IRREVOCABLE, except as provided herein, and that such distribution and
alimony provisions shall not be affected by any future change in circumstances of the respective
parties OR by other statutory or judicial alternatives which may be available to the respective
parties under prior, current or future laws of the Commonwealth of Pennsylvania or any other
jurisdiction. Except as provided herein, the parties hereby waive any respective rights to
financial support and/or alimony and/or pension or future expectancies each may respectively
have under prior, current or future laws or case decisions.
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IN WITNESS WHEREOF, the parties have hereunto set their hands and. seals the day
WITNESS
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vs.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO.2001-d~tf CivilTerm
: CIVIL ACTION - LAW
: IN DIVORCE
NATHAN K. SYBRANDT,
Plaintiff
RACHELLE D. SYBRANDT,
Defendant
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims
set forth in the following pages, you must take prompt action. You are warned that if you
fail to do so, the case may proceed without you and a decree of divorce or annuhnent may
be entered against you by the court. A judgment may also be entered against you for any
other claim or relief requested in these papers by the plaintiff. You may lose money or
property or other rights important to you, including custody or visitation of your .children.
When the ground for the divorce is indignities or irretrievable breakdown of
marriage, you must request marriage counseling. A list of marriage counselors is available
in the Office of the Prothonotary at
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA l7013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR
ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF
THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA l7013
(}fi!tp CJti!i1
MAX J. SMITH, JR., qurre
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
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NATHAN K. SYBRANDT,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 2001- ..l,/,/ Civil Term
RACHELLE D. SYBRANDT,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the Plaintiff, NATHAN K. SYBRANDT, by his attorney, MAX J.
SMITH, JR., Esquire, and seeks to obtain a Decree in Divorce upon the grounds hereinafter more
fully set forth:
l. The Plaintiff, NATHAN K. SYBRANDT, is an adult individual and citizen of the
United States of America, whose address is 35 Fort Street, Lemoyne, Cumberland County, Penn-
sylvania 17043.
2. The Defendant, RACHELLE D. SYBRANDT, is an adult individual and citizen of
the United States of America, whose address is 70 Station Road, Newville, Cumberland County,
Pennsylvania 17241.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six (6) months innnediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on or about May 21, 1999 in Cullowhee,
North Carolina.
5. Plaintiff avers that there are no children of the parties under the age of 18.
6. Neither Plaintiff nor Defendant is a member of the United States Armed Services.
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7. Plaintiff and Defendant have both been advised of the availability of marital
counseling and that each may have the right to request that the court require the parties to
participate in counseling.
8. Plaintiff avers that there has been no prior action for divorce or annulment of the
marriage filed by either party in this or any other jurisdiction.
WHEREFORE, Plaintiff prays your Honorable Court to enter a Decree of Divorce from
the bonds of matrimony.
Dated: January~, 2001
3Jl~~
James, Smith, Durkin & Connelly LLP
P.O. Box 650
Hershey, P A 17033
(717) 533-3280
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I verify that the statements made in this Complaint are true and correct. I under-
stand that false statements herein are made subject to the penalties of l8 Pa. C.S. Section
4904, relating to unsworn falsification to authorities.
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HT05.157REV.5-97 COMMONWEALTH OF PENNSYlVANIA
DEPARTMENT OF HEALTH
vrTAL RECORDS
STATE ALE NUMBER
RECORD OF
COUNTY ~I DIVORCE OR ANNULMENT STATE ALE DATE
Cumberland [R] (CHECK ONE) 0 .
HUSBAND
35 Fort
5. NUMBER
OF THIS
MARRIAGE 1
(Mlddfe) (Last) 2. DATE (Mon~1 (Day) (Yea<)
OF 12 14 1972
K. S brandt BIRTH
City, Bora. or Twp, County State 4. PLACE (State or Foreign Gauntly)
OF
Cumberland, PA BIRTH Minneso a
7. USUAL OCCUPATION
1. NAME
(First)
Nathan
StresterR.D.
3. RESIDENCE
BLACK
o
Sr. S stems administrator r rammer
WIFE
,. MAIDEN NAME (FllSt) (Middle) (Last) 9. DATE (Month) (Day) (Year)
Packer Rachelle Sybrandt OF 04 09 1970
D. BIRTH
10. RESIDENCE Street or R.D. City, Bora. or Twp. County State 11. PLACE (State or Foreign Country)
70 Station Road, Newville, Cumberland, PA OF Ohio
BIRTH
12. NUMBER r3. RACE 114. USUAL OCCUPATION
OF THIS . WH~E BLACK OTHER (Specify)
MARRIAGE 1 0 n Scenic artist
15. PLACE OF (County) (State or Foreign Country) 16. DATE OF (Month) (Day) (Year)
THIS Cullowhee North Carolina TH'S 05
MARRIAGE MARRIAGE 21 1999
17A. NUMBER OF rB. NUMBER O' DEPENDENT 18. PLAINTIFF 19. DECREEGAANTEOrO
CHILDREN THIS CHILDREN VNDER 18. HUSBAND WIFE OTHER (Specify) HUSBAND WIFE OTHER (Specify)
MARRIAGE 0 0 IXJ 0 0 IXJ 0 0
20. NUMBER OF HUSBAND WIFE SPUT CUSTODY OTHER (Specify) I 21. LEGAL GROUNDS FOR
CHILDREN TO N/A 0 0 0 0 DIVORCE OR ANNULMENT
CUSTODY OF Irretrievable breakdown
22 DATE OF DECREE (Month) (Day) (Yeer) 123. DAT~ REPORT SENT (Month) (Day) (Year)
TO VITAL RECQRDS
24. SIGNATURE OF
TRANSCRIBING CLERK
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NATHAN K. SYBRANDT,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 200l-244 Civil Term
RACHELLE D. SYBRANDT,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF COUNSELING
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
January 11, 2001.
2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety days
have elapsed since the date of filing and service of the Complaint.
3. I consent to the entry of a Final Decree of Divorce after service of notice of
intention to request entry of the decree.
4. I have been advised of the availability of marriage counseling and understand that I
may request that the Court require that my spouse and I participate in counSeling. I further
understand that the Court maintains a list of marriage connselors in the Prothonotary's Office,
which list is available to me upon request. Being so advised, I do not request that the Court
require that my spouse and I participate in counseling prior to a decree being handed doWn by the
Court.
I verify that the statements made in this Affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to
unsworn falsification to authorities.
Md-.-
RACHELLE D. S
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Plaintiff
: IN THE COURT OF COMMON.PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 2001-244 Civil Term
RACHELLE D. SYBRANDT,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
~3301(c) OF THE DIVORCE CODE
l. I consent to the entry of a Final Decree of Divorce without further 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 innnediately after it is filed. with the
Prothonotary.
I verify that the statements made in this Affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to
unsworn falsification to authOllties.
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NATHAN K. SYBRANDT,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO.200l-244
RACHELLE D. SYBRANDT,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this 12th day of January, 2001, I, MAX J. SMITH, JR., Esquire, Attorney
for Plaintiff, hereby certify that I have this day sent a copy of Complaint in Divorce by depositing
a certified copy of the same in the United States mail, postage prepaid, certified mail #7000 1670
0011 16999218 at Hershey, Pennsylvania, addressed to:
Rachelle D. Sybrandt
70 Station Road
Newville,PA 17241
Mailing and return receipt cards attached hereto.
q
MAXJ. SMITH,
LD. No. 32114
JAMES, SMITH, DURKIN & CONNELLY ILP
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
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NATHAN K. SYBRANDT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
CIVIL ACTION - LAW
VB.
NO. Ol _ 244
IN DIVORCE
CIVIL
19
RACHELLE D. SYBRANDT
DATE:
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Defendant
STATUS SHEET
ACTIVITIES:
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NATHAN K. SYBRANDT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 01 - 244 CIVIL
RACHELLE D. SYBRANDT,
Defendant
IN DIVORCE
TO: Max J. Smith
Attorney for Plaintiff
Marilyn K. zilli Attorney for Defendant
DATE: Monday, May 7, 2001
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
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(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
COUNSEL FOR PLAINTIFF
COUNSEL FOR DEFENDANT
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.
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2.
"
NATHAN K. SYBRANDT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 01 - 244 CIVIL
RACHELLE D. SYBRANDT,
Defendant
IN DIVORCE
TO: Max J. Smith
Attorney for Plaintiff
Marilyn K. zilli Attorney for Defendant
DATE: Monday, May 7, 2001
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 lS not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
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DATE
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COUNSEL FOR PLA TIFF (~
COUNSEL FOR DEFENDANT (
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NOTE:
PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY TlffiT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
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]AMEs SMrrn DuRKIN & CONNELLY UP
,
Max J. Smith, Jr.
mjsjr@jsdlegal.com
January 10, 2002
Office of Divorce Master
Attn: E. Robert Elicker, II, Esquire
9 North Hanover Street
Carlisle, P A 17013
In re: Sybrandt v. Sybrandt
No. 2001-244
In Divorce
Dear Bob:
Please be advised that I represent Nathan K. Sybrandt, Plaintiff in the above matter. The
Defendant, Rachelle D. Sybrandt, is not represented by counsel, although she had been
represented by Marilyn K. Zilli, Esquire. I have enclosed a copy of Ms. Zilli's letter to
me dated May 23, 2001 which indicates that she no longer represents Ms. Sybrandt, and
that all communication is to be forwarded to Ms. Sybrandt directly.
You had been appoinfed Master by Order dated May 2, 2001. In the meantime, the
parties have resolved the outstanding marital issues by agreement, and therefore I have
enclosed two fully executed copies oftheir Marital Settlement Agreement dated
December 5,2001 to assist you in revoking your appointment as Master. Plaintiffs
Consent and Waiver forms were filed on December ll, 2001 and Defendant's Consent
and Waiver forms were filed on January 9,2002, and a Praecipe signed by Ms. Sybrandt
withdrawing Counts IV, V and VI of her Counterclaim was also filed on January 9.
Accordingly, we respectfully request that the steps be taken to revoke your appointment
as Master so that we rp.ay proceed with the completion of the divorce.
Thank you for your killd attention, and please let me know if you need any additional
information.
Very truly yours,
'It ":""' DURKiN & CDNNELLY='
Max J. S~th, Jr. '.
MJS,Jr.:amk
Enclosures
cc: Nathan K. Sybrandt
Rachelle D. Sybrandt
C",~!,_~
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L A IV 0 I; r [ C E S
JS'}(
134 SirE AVENUE
HUMMELSTQWN, PA
17036
MAILING ADDRESS:
P.O. BOX 650
I-IFRSHFY, PA 17033
TEI__ 717533,3280
FAX 7175332795
INFO@,ISDU:::GAL.COM
GARY L. JAMES
MAX J. SMITH, JR.
KAREN DURKIN
JOHN J. CONNELLY, JR.
STEVEN A. STINE
SCOTT A. DIETTERICK
GREGORY K. RICHARDS
RICHARD L. DAHLEN
SUSAN M. KADEL
JARAD W. HANDELMAN
DONNA M. MULLIN
EDWARD P. SEEBER
NEIL W. YAHN
BERNARD A RYAN, JR.
OF COUNSEL:
ANDREW M. BARBIN
,--',,'
.
FETTERHOFF AND ZILLI
ATTORNEYS AT LAW
200 N. THIRD STREET - SUITE 800
P.O. BOX 1161
HARRISBURG, PENNSYLVANIA 17108-1161
WILLIAM A. FETTlSRHOFF
MARILYN C. ZILLl
May 23, 200l
TELEPHONE
717-232-7722
FAX
7' 7-233-4965
Max 1. Smith, Esquire
James, Smith, Durkin & Connelly, LLP
P. O. Box 650
Hershey, FA 17033
Re: Sybrandt v. Sybrandt
Dear Max:
Rachelle Sybrandt has informed me that she can no longer afford the services of an attorney
and has directed me to take no further steps on her behalf
Accordingly, please send all correspondence to Ms. Sybrandt directly.
Thank you for your attention.
r Very truly yours,
\ /~ /\ (.,",
V I .1.,
; ) ,\, '-7)7_l//l~,
Marilyn C. Zilli j
lrs
cc: Rachelle Sybrandt (with enclosure)
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NATHAN K. SYBRANDT,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 200l-244 Civil Term
RACHELLE D. SYBRANDT,
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 or other rights important to you,
including custody or visitation of your children.
When the ground for divorce is indignities or irretrievable breakdown of the marriage, you
may request marriage counseling. A list of marriage counselors is available in the Office of the
Prothonotary at
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA l7013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF PROPERTY, LAWYER'S
FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY
LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE TmS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HA VB 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 LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania l7013-3387
(717) 249-3166
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NATHANK. SYBRANDT,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 200l-244 Civil Term
RACHELLED. SYBRANDT,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
ANSWER TO DIVORCE COMPLAINT
WITH NEW MATTER AND
COUNTERCLAIM
AND NOW, comes Defendant Rachelle D. Sybrandt who files this Answer with New Matter
and Counterclaim to Plaintiff Nathan K. Sybrandt's Complaint in Divorce.
l. Admitted.
2. Admitted
3. Admitted.
4. Admitted in part; denied in part. The parties were married by a rector on May 2l,
1999. Their marriage certificate erroneously states the date as May 22, 1999. However, the parties
have been living as connnon-law husband and wife since December l, 1995.
5. Admitted.
-"~"-~ ~'."_V'" '_" ",- __'l''''," -. Y',"'_ "'-"o,:-,-,;;<:,)!'I -, 'c :'-'~_' <"U ,_~," _:"'; -~__ ,_ ,_ _ ~ - I'
6. Admitted.
7. Neither admitted nor denied. Defendant has filed her own Affidavit of Counseling.
(See attached.)
8. Admitted.
NEW MATTER
9. Defendant avers that the marriage is not irretrievably broken.
WHEREFORE, Defendant prays this Honorable Court to deny Plaintiff's request for a
divorce.
COUNTERCLAIM
COUNT I
Request for a Fault
Divorce under Section 3301(a)(6)
of the Divorce Code
lO. The prior paragraphs of this Complaint are incorporated herein by reference thereto.
ll. Plaintiff has offered such indignities to Defendant, who is the innocent and injured
spouse, as to render Defendant's condition intolerable and life burdensome.
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l2. The indignities include both physical and mental abuse.
13. This action is not collusive, as defined by Section 3309 of the Divorce Code.
WHEREFORE, ifa divorce is to be granted, Defendant respectfully requests that it be granted
to her, pursuant to Section 330l(a)(6) of the Divorce Code.
COUNT II
Request for a No-Fault Divorce
under Section
330Hc) oftbe Divorce Code
l4. The prior paragraphs of this Complaint are incorporated here by reference thereto.
lS. After ninety (90) days have elapsed from the date of the filing of the Complaint,
Defendant may file an affidavit consenting to a divorce. Plaintiff may also file such an affidavit.
WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days
have elapsed from the filing of this Complaint, Defendant respectfully requests the Court to enter a
decree of divorce, pursuant to Section 3301(c) of the Divorce Code.
COUNT ill
Reauest for a No-Fault Divorce under
Section 330Hd) oftbe Divorce Code
16. The prior paragraphs of this Complaint are incorporated herein by reference thereto.
l7. The parties have lived separate and apart since late December, 2000.
1<. " ~~,
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l8. At the time of hearing, Defendant may submit an affidavit that the parties have lived
separate and apart for at least two (2) years.
WHEREFORE, if the parties continue to live separate and apart, Defendant respectfully
requests the Court to enter a decree of divorce pursuant to Section 3301(d) of the Divorce Code.
COUNT IV
Reauest for Eauitable Distribution
under Section
3502 of the Divorce Code
19. The prior paragraphs of this Complaint are incorporated herein by reference thereto.
20. Plaintiff and Defendant have acquired property both real and personal during their
marriage from December l, 1995 until the present time.
2l. Plaintiff and Defendant have been unable to agree to an equitable distribution of said
property,
WHEREFORE, if the parties are ultimately divorced, Defendant prays for the entry of an
Order equitably distributing all of the aforementioned property.
- ""'-'-,_~ ,:"j{"--,-i-
COUNT V
Request for Alimonv Pendente Lite and Alimonv
under Sections
3701 and 3702 of the Divorce Code
22. The prior paragraphs of this Complaint are incorporated herein by reference thereto.
23. Defendant lacks sufficient property to provide for her reasonable needs and is unable
to sustain herself during the course of litigation.
24. Defendant requires reasonable support to adequately maintain herself in accordance
with the standard ofliving established during the marriage.
25. Defendant requests the Court to enter an award of alimony oendente lite until final
hearing and thereupon, if a divorce is granted, to enter an Order of alimony in her favor, pursuant to
Sections 370l and 3702 of the Divorce Code.
WHEREFORE, Defendant respectfully requests that pursuant to Sections 370l and 3702 of
the Divorce Code, the Court enter an Order directing Defendant to pay alimony pendente lite and,
if a divorce is granted, alimony.
COUNT VI
Request for Counsel Fees. Costs and EXDenses
under Sections 3104. 3313. and 3702 ofthe Divorce Code
26. The prior paragraphs of this Complaint are incorporated herein by reference thereto.
",-:-,~-- ,'> '_.'~,-
27. Defendant has retained Marilyn C. Zilli, Esq., to represent her in this matrimonial
cause.
28. Defendant is unable to pay the necessary counsel fees, costs and expenses and
Defendant is more than able to pay them.
29. Reserving the right to apply to the Court for temporary counsel fees, costs and
expenses prior to final hearing, Defendant requests that, after final hearing, the Court order Defendant
to pay Plaintiff's reasonable counsel fees, costs and expenses.
WHEREFORE, Plaintiffrespectfullyrequests that, pursuant to Sections 3 104, 3323 and 3702
of the Divorce Code, the Court enter an Order directing Defendant to pay Plaintiff's reasonable
counsel fees, costs and expenses.
Respectfully submitted,
~..:~,
Attorney for Defendant
200 North Third Street, Suite 800
Harrisburg, P A l710 1
717-232-7722
ill #23l79
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VERIFICA nON
I verif'y that the statements made in the foregoing document are true and correct to the best
of my knowledge, understanding, and belief. I understand that false statements herein are made
subject to the penalties of l8 Pa. C.S. ~4904 relating to unsworn falsification to authorities.
Date:
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v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 200l-244 Civil Term
NATHAN K. SYBRANDT,
Plaintiff
RACHELLE D. SYBRANDT,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF COUNSELING
I, Rachelle D. Sybrandt, being duly sworn according to law, depose and say:
1. I have been advised of the availability of marriage counseling and understand that I may
request that the Court require that my spouse and I participate in counseling.
2. I understand that the Court maintains a list of marriage counselors in the Domestic
Relations Office, which list is available to me upon request.
3. Being so advised, I do not request that the Court require that my spouse and I participate
in counseling prior to a divorce decree being handed down by the Court.
I understand that false statements herein are made subject to the penalties of l8 Pa. C. S.
~4904 relating to unsworn falsification to authorities.
Date: :J. - (; I - 0 I
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CERTIFICATE OF SERVICE
A true and correct copy of the foregoing document was delivered to the person or office listed
below by first class mail on the date indicated, as follows:
Max J. Smith, Esquire
James, Smith, Durkin & Connelly, LLP
P. O. Box 650
Hershey, PA l7033
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Marilyn C. ZilIi, Es. re
200 North Third Street
Suite 800
Harrisburg, P A 17l 0 1
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NATHAN K. SYBRANDT,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 200l-244 Civil Term
RACHELLE D. SYBRANDT,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AMENDED ANSWER
AND NOW, this -ED. day of February, 200l, Defendant Rachel1e D. Sybrandt
respectfully requests that the following language be substituted in the Answer with New Matter and
Courterclaim she filed February 2, 2001.
1. In the WHEREFORE clause of Count V; substitute the following language:
WHEREFORE, Defendant respectfully requests that pursuant to Sections 370l and 3702 of
the Divorce Code, the Court enter an Order directing Plaintiff to pay alimony oendente lite and, if a
divorce is granted, alimony.
2. In Count VI; substitute the following language:
28. Defendant is unable to pay the necessary counsel fees, costs and expenses and
Plaintiff is more than able to pay them.
29. Reserving the right to apply to the Court for temporary counsel fees, costs and
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expenses prior to final hearing, Defendant requests that, after final hearing, the Court order Plaintiff
to pay Defendant's reasonable counsel fees, costs and expenses.
WHEREFORE, Defendant respectfully requests that, pursuant to Sections 3104, 3323 and
3702 ofthe Divorce Code, the Court enter an Order directing Plaintiff to pay Defendant's reasonable
counsel fees, costs and expenses.
spectfully submitted,
~i
Marilyn C. Zilli, Esquir
Attorney for Defendant
200 North Third Street, Suite 800
Harrisburg, P A l710 1
7l7-232-7722
ID # 23179
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CERTIFICATE OF SERVICE
A true and correct copy of the foregoing document was delivered to the person or office listed
below by first class main on the date indicated, as follows:
Max J. Smith, Esquire
James, Smith, Durkin & Connelly, LLP
P. O. Box 650
Hershey, PA l7033
Date:
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Marilyn C. ZOO, ire
200 North Third Street
Suite 800
Harrisburg, PA l7101
(7l7) 232-7722
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NATHAN K. SYBRANDT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 01 - 244 CIVIL
RACHELLE D. SYBRANDT,
Defendant
IN DIVORCE
TO: Max J. Smith
Attorney for Plaintiff
Marilyn K. zilli Attorney for Defendant
DATE: Monday, May 7, 2001
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE: I"iY\C~ -
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
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NOTE:
PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
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I}l THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NATHAN K. SYBRANDT.
Plaintiff
vs.
RACHELLE D. SYBRANDT.
NO. 2001-:144
19
Nathan K. Svbrandt
a master with respect to the
(X) Divorce
( ) .~nulment
(X) Alimony
( X) Alimony Pendente
MOTION FOR APPOINTMENT OF MASTER
(Pbintiff) (~UflO,
following claims:
moves the court to appoint
Lite
(X)
( )
(X)
(X)
Distribution of Property
Support
Counsel Fees
Costs and Expenses
and in support of the motion states:
(1) Discovery is complete as to the claims(s) for which the
appointment of a master is requested.
her (2) The defendant (has) (~~llli) appeared in
(by lU attorney, Marilvn K. zilli
(3) The staturory ground(s) for divorce (~
breakdown and indiqnities
(4) Delete the inapplicable paragraph(s):
(a) The action is not contested.
(b) An agreement has been reached with respect to the
the action (~.~
,Esquire) .
(are) irretrievable
following claims:
(c) The action is contested with respect to the following
claims:
(5) The action (li.Jl'lI[oclxI1Jes) (does not involve) complex issues of law
or fact.
(~d (days).
motion:
(6) The hearing is expected to take
(7) Additional information, if any.
Date: April :1/,;. ?001
AND NOW M ~ J..
is appointed masts with
ORDER APPOINTING MASTER
,~~J E.~r1A..JLv,
respect to the follOWing claims:
Esquire,
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)AMEs SMffiI DuRKIN & CONNElLY liP
Max 1. Smith, Jr.
mjsjr@jsdlegal.com
May 22, 200l
Office of Divorce Master
Attn: E. Robert Elicker, II, Esquire
9 North Hanover Street
Carlisle, P A l7013
In re: Sybrandt v. Sybrandt
No. 2001-244
In Divorce
Dear Bob:
Enclosed please find the Certification of Discovery form which has been completed on
behalf of Nathan Sybrandt in the above matter. A copy is being furnished to opposing
counsel, Marilyn Zilli, along with a copy of this letter.
Thank you for your kind attention.
Very truly yours,
'~DmooN & CONNELLY LL'
Max J. Smith, Jr.
MJS,Jr.:amk
Enclosure
ec: Marilyn C. Zilli, Esquire w/enc
Nathan K. Sybrandt w/enc
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P.O, BOX 650
!-lERSHEY. F'A 17033
lH.7'7.533,3280
FAX ]".7.5332795
INFO@JSDLEGAL.COM
HARRISBURG OFFICE
108-112 WALNUT ST
HP-,RRISBURG, PA 17101
(717) 238-4776
GARY L. JAMES
MAX. J. SMITH, JR.
KAREN DURKIN
JOHN J. CONNELLY, JR.
STUART J. MAGDULE
STEVEN A. STINE
JOHN J. McNALLY, III
SCOTT A. DIETTERICK
GREGORY K. RICHARDS
RICHARD L. DAHLEN
SUSAN M. KADEL
JARAD W. HANDELMAN
DONNA M. MULLIN
EDWARD P. SEEBER
"
NATHANK. SYBRANDT,
PlaintiffiRespondent
IN THE CbURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DNORCE
RACHELLE D. SYBRANDT,
Defendant/Petitioner
NO. 01-244 CNILTERM
IN DNORCE
DR# 30426
PacseS# 854103042
ORDER OF COURT
AND NOW, this 7th day of February, 2001, upon consideration of the attached Petition for
Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel
appear before R.J. Shaddav on March 6,2001 at 9:00A.M for a conference, at 13 N. Hanover St.,
Carlisle, P A 17013, after which the conference officer may recommend that an Order for Alimony
Pendente Lite be entered.
YOU are further ordered to bring to the conference:
(I) a true copy of your most recent Federal Income Tax Return, including W-2's as filed
(2) your pay stubs for the preceding six (6) months
(3) the Income and Expense Statement attached to this order, completed as required by Rule
1910.111(;)
(4) verification of child care expenses
(5) proof of medical coverage which you may have, or may have available to you
IF you fail to appear for the conference or bring the required documents, the Court may issue a
warrant for your arrest.
BY THE COURT,
George E. Hoffer, President Judge
Mltij;~\)P~S on
:leS-Olto: ..
Petitioner
< Respondent
Marilyn Zilli, Esquire
Max Smith, Esquire
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R. J. stadday, Conference Officer
Date of Order: Febraury 7, 2001
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND
REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET
LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY A VB.
CARLISLE,PENNSYLVANIA 17013
(717) 249-3166
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NATHAN K. SYBRANDT,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 2001-244 Civil Term
RACHELLE D. SYBRANDT,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
PRAECIPE
TO THE PROTHONOTARY:
Please withdraw Counts IV, V and VI of the Counterclaim filed on behalf of the
Defendant, Rachelle D. Sybrandt, in the above matter, by former counsel, Marilyn C. Zilli,
Esquire.
Date: October f).5 , 2001
(il,J/k 0 ,~~fr
RACHELLE D. SYB T
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NATHAN K. SYBRANDT,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 2001-244 Civil Term
RACHELLE D. SYBRANDT,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
PLAINTIFF' S REPLY TO AMENDED ANSWER
AND NOW COMES the Plaintiff, NATHAN K. SYBRANDT, by his attorney, MAX
J. SMITH, JR., Esquire, and respectfully Reply's to Defendant's Amended Answer as
follows:
1. Neither admitted nor denied, as no response is required.
2. 28. Denied. Defendant is gainfully employed and therefore able to pay her counsel
fees, costs and expenses. It is further denied that Plaintiff is more than able to pay same.
29. Denied. Defendant is capable of paying her counsel fees, costs and expenses.
Denied. Defendant is capable of paying her counsel fees, costs and expenses.
Respectfully submitted,
Date: February l4, 200l
(1Al~
MAX J. SMITH, JR., squire
I.D. No. 32114
James, Smith, Durkin & Connelly LLP
P.O. Box 650
Hershey, P A 17033
(717) 533-3280
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r verify that the statements made in this Reply to Amended Answer are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section
4904, relating to unsworn falsification to authorities.
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NATHAN K. SYBRANDT,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 200l-244 Civil Term
RACHELLE D. SYBRANDT,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this 1 day of February, 2001, I, MAXI. SMITH, JR., Esquire,
Attorney for Plaintiff, hereby certify that I have this day sent a copy of Plaintiff's Reply to
Amended Answer by depositing a certified copy of the same in the United States mail, postage
prepaid, at Hershey, Pennsylvania, addressed to:
Fetterhoff and Zilli
Attn: Marilyn C. Zilli, Esquire
200 N. Third Street - Suite 800
P.O. Box 116l
Harrisburg, PA 17108-1161
@J)t~
MAX J. SMITH, JR., E . e
I.D. No. 32114
JAMES, SMITH, DURKIN & CONNELLY u.p
P.O. Box 650
Hershey, P A 17033
(717) 533-3280
O_'~., _ _'-_ ,,_,. "'___""'~'.," ,"_,__ _"o,___-~--, __<,_~__ ,'_," _,~. '_,. 'I~"y._~____q. _,-,F' "-'c'_,.,,.< '-,' I (
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NATHAN K. SYBRANDT,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 2001-244 Civil Term
RACHELLE D. SYBRANDT,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
PLAINTIFF' S REPLY TO COUNTERCLAIMS
AND NOW COMES the Plaintiff, NATHAN K. SYBRANDT, by his attorney, MAX
J. SMITH, JR., Esquire, and respectfully Replys to Defendant's Counterclaims as follows:
COUNT I
REOUEST FOR A FAULT DIVORCE UNDER
SECTION 3301(a)(6) OF THE DIVORCE CODE
10. Neither admitted nor denied, as no response is required.
11. Denied. It is denied that Plaintiff has offered such indignities to Defendant as to
render her condition intolerable and life burdensome. To the contrary, it is Defendant who has
committed indignities so as to render Plaintiff's condition intolerable and life burdensome.
l2. Denied. Plaintiff has not physically or mentally abused Defendant.
13. Admitted.
COUNT II
REOUEST FOR A NO-FAULT DIVORCE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
14. Neither admitted nor denied, as no response is required.
1111.1
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15. Admitted.
COUNT III
REOUEST FOR A NO-FAULT DIVORCE UNDER
SECTION 3301(d) OF THE DIVORCE CODE
16. Neither admitted nor denied, as no response is required.
17. Denied. The parties have lived separate and apart since November 6, 2000.
18. Denied. This is a conclusion of law to which no response is necessary.
COUNT IV
EOUITABLE DISTRIBUTION
19. Neither admitted nor denied, as no response is required.
20. Admitted.
21. Admitted.
COUNT II
ALIMONY PENDENTE LITE AND ALIMONY
22. Neither admitted nor denied, as no response is required.
23. Denied. Defendant has sufficient property to provide for her reasonable means
and to sustain herself during the course of this litigation.
24. Denied. Defendant is employed and is able to adequately support herself in
accordance with the standard of living established during the marriage.
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25. Denied. Defendant is able to provide for herself through her employment, and
therefore is not entitled to alimony pendente lite or alimony.
COUNT VI
COUNSEL FEES. COSTS AND EXPENSES
26. Neither admitted nor denied, as no response is required.
27. Admitted.
28. Admitted in part and denied in part. It is denied that Defendant is unable to pay
her counsel fees, costs and expenses. It is admitted that Defendant is able to pay them.
29. Denied. Defendant is capable of paying her counsel fees, costs and expenses.
WHEREFORE, Plaintiff prays this Honorable Court to:
(a) deny a divorce pursuant to Section 3301(a)(6) of the Pennsylvania Divorce
Code;
(b) grant a divorce pursuant to Section 3301 (c) of the Pennsylvania Divorce Code;
(c) equitably divide the marital property remaining between the parties;
(d) deny Defendant's request for alimony pendente lite and alimony;
(e) deny Defendant's request for counsel fees, costs and expenses;
'~;,-. ~- -, . , ~_Y_I> .~.-,,_., ,,"~,"'~".<<:;-~r"3""_-,. _! -, , '" '!_i_tt;~"'7_ . _~I~,"", , ._ e_.), ."'_~~'_; -
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(f) deny any and all other relief which has been requested by Defendant; and
(g) order such further relief as the Court may determine equitable and just.
Respectfully submitted,
Date: February l4, 2001
~-
I.D. No. 32114
James, Smith, Durkin & Connelly LLP
P.O. Box 650
Hershey, P A l7033
(717) 533-3280
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I verify that the statements made in this Reply to Counterclaims are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section
4904, relating to unsworn falsification to authorities.
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NATHAN K. SYBRANDT,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 2001-244 Civil Term
RACHELLE D. SYBRANDT,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
CERTIFICATE OF SERVlCE
AND NOW, this I~ day of February, 2001, I, MAX J. SMITH, JR., Esquire,
Attorney for Plaintiff, hereby certify that I have this day sent a copy of Plaintiff's Reply to
Counterclaims by depositing a certified copy of the same in the United States mail, postage
prepaid, at Hershey, Pennsylvania, addressed to:
Fetterhoff and Zilli
Attn: Marilyn C. Zilli, Esquire
200 N. Third Street - Suite 800
P.O. Box 116l
Harrisburg, PA 17108-1161
MAX~
I.D. No. 32114
JAMES, SMITH, DURKIN & CONNELLY lLP
P.O. Box 650
Hershey, P A l7033
(717) 533-3280
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NATHAN K. SYBRANDT,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 2001-244 Civil Term
RACHELLE D. SYBRANDT,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
PLAINTIFF'S AMENDED REPLY TO COUNTERCLAIMS
AND NOW COMES the Plaintiff, NATHAN K. SYBRANDT, by his attorney, MAX
J. SMITH, JR., Esquire, and respectfully amends his Reply to Defendant's Counterclaims as
follows:
COUNT IV
EOUIT ABLE DISTRIBUTION
20. Paragraph 20 of Plaintiff s Reply to Counterclaims filed on February 16, 2001
should be amended to read as follows:
Admitted, to the extent the parties have acquired property during their marriage from
May 21, 1999 to present. It is denied that the parties have been married since December 1,
1995.
PC',Y _".'--,'_' "~_~>,,,:'_,"_v"'r_ ~,~.-_" ~,'~",.__ ,- H ,~" ~<--,-"/_, _,_~n,,", d_ "','~", r"~,'_", "~'_." >_" 1.'?" ,
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COUNT V
ALIMONY PENDENTE LITE AND ALIMONY
(The Reply to Counterclaims filed on February 16, 2001, erroneously references Count
V, Alimony Pendente Lite and Alimony as Count II, and therefore the correction is noted
herein. )
Date: February 27,2001
Respectfully submitted,
M~~qillre
I.D. No. 32114
James, Smith, Durkin & Connelly LLP
P.O. Box 650
Hershey, P A 17033
(717) 533-3280
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FAX NO, 717 4592910
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NATHAN K. SYBRANDT,
Plaintiff
: IN THE COURT OF COMMON' PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 2001-244 Civil Term
RACHELLE D. SYBRANDT,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this 2-'7 day of Febrnary, 2001, I, MAX J. SMITH, JR., Esquire,
Attorney for Plaintiff, hereby certify that I have this day sent a copy of Plaintiff s Amended
Reply to Counterclaims by depositing a certified copy of the same in the United States mail,
postage prepaid, at Hershey, Peunsylvania, addressed to:
Fetterhoff and Zilli
Attn: Marilyn C. Zilli, Esquire
200 N. Third Street - Suite 800
P.O. Box 1161
Harrisburg, PA 17108-116l
MAX~~
LD. No. 32114
JAMES, SMITH, DURKIN & CONNELLY LLP
P.O. Box 650
Hershey, P A 17033
(717) 533-3280
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
:b;tl, O/~# {i/[//L
State Commonwealth of Pennsvlvania ;J/jef;f9 &5L/1D30V;7
Co.lCity/Dist. of CUMBERLAND
Date of Order/Notice 03/06/01 {)Ie tJo</d6
Court/Case Number (See Addendum for case summary)
@Original Order/Notice
o Amended Order/Notice
o Terminate Order/Notice
) RE: SYBRANDT, NATHAN K.
) Employee/Obligor's Name (Last, First, Mil
) 177 -68-0083
) Employee/Obligor's Social Security Number
) 3655100690
) 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
PENN WATIONAL GAMING INC
EmployerlWithholder's Name
825 BERKSHIRE BLVD
EmployerlWithholder's Address
WYOMISSING PA 19610-1247
'"'*'
See Addendum for dependent names and birth dates assodated with cases on attachment.
ORDER fNFORMA TfON: 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.
$ 312.00 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 $ 352.00 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 determ ine how much to withhold:
$ 81.23 per weekly pay period.
$ 162.46 per biweekly pay period (every two weeks).
$ 176.00 per semimonthly pay period (twice a month).
$ 352.00 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 10 (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
DRO: RJ Shadday
xc: defendant
MAILED
3/J-O/
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BY THE COURT:
JUIX;E
rm EN-028
Worker ID $IATT
Date of Order:
l'larch ~. 2001
Service Type M
OMB No.: 0970-0154
Expiration Date: 12J31JOO
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If checked you are required to provide a copy of this form to your employee.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contactthe requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment
to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to
each employee/obligor.
3.* RLp011i115lllc.. F'aydQ~'Datt v{'"Vitl.l.oIJiIl5. 'tOll llltlst le!-'v,t tLe lYciyJatc/date of vvitl.l.oIJil,g vvLelt ::>d,dillg tile paylllelll. TLe
payda1:t:/date of vvitl.l,oIJ:1I5 is tLt;; dati. 01. vvlliel. alllOul,t m15 vv;t1.I.eld null! tile e,uploye.:::.'s vvag('3. You must comply with the law of the
state of the emplayee's1obligor'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: 2322344730
EMPLOYEE'S/OBLlGOR'S NAME: SYBRANDT, NATHAN K.
EMPLOYEE'S CASE IDENTIFIER: 3655100690 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
severa.nee pay. [fyou have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should
have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs
unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from
employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding.
Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is
employed governs.
9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.S.c. 91673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (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 selVed with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
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
SelVice Type M
OMBNo.:0970-01S4
Expiration Date: 12131/00
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ADDENDUM
Summarv of Cases on Attachment
Defendant/Obligor: SYBRANDT, NATHAN K.
854103042PO~~ PACSES Case Number
Plaintiff Name
PACSES Case Number
Plaintiff Name
RACHELLE D. SYBRANDT
Docket Attachment Amount
01-244 CIVIL $ 352.00
Child(ren)'s Name(s):
DaB
D Ifchecked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
D If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
"d,;~h~~~~~;;~.~~;~;~~~i;~~;~~~;~il;~~~~iidi;~~;.../i................ .
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Service Type M
Attachment Amount
$ 0.00
Child(ren)'s Name(s):
Docket
DOB
.'dl;~~~~~~~,;~~..~;~;;~~i;~~...;~;~r~II;~~{~~il~i;~~;..................?. .......
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
D If checked, you are required to enroll the chil(J(ren)
identified above in any health insurance coverage available
through the employee's/obligor's empioyment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Chiid(ren)'s Name(s):
DaB
EJI;~h~~~~d:;~~;;~;~~~i~~~...;~~~~~II;~~~~i:Ji;~~;'.'..i........... ..
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Addendum
Form EN-028
Worker 10 $IATT
OMS No.: 0970.0154
Expiration Date: 12/31/00
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DR 30426
P ACSES In 854103042
vs.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: DOMESTIC RELATIONS SECTION
: CIVIL ACTION - LAW
NATHAN K. SYBRANDT,
Plaintiff/Respondent
RACHELLE D. SYBRANDT,
Defendant/Petitioner
: NO. 01-244 CIVIL TERM
ORDER OF COURT
AND NOW, this 6th day of March, 200l, based upon the Court's determination that
Petitioner's monthly net income/eaming capacity is $l,049.27 per month and Respondent's monthly
net income/earning capacity is $2,964.57 per month, it is hereby Ordered that the Respondent pay to
the Pennsylvania State Collection and Disbursement Unit, $352.00 per month payable monthly as
follows; $3l2.00 per month for alimony pendente lite and $40.00 per month on arrears. First
payment due within ten days upon receipt of this order in the amount of$3l2.00. Arrears set at
$624.00 as of March 6,2001. The effective date of the order isFebruary 2, 2001.
Failure to make each payment on time and in full will cause all arrears to become subject to
immediate collection by all of the means as provided by 23 Pa.C.S.~ 3703. Further, if the Court
finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare
the Respondent in civil contempt of Court and its discretion make an appropriate Order, including,
but not limited to, commitment of the Respondent to prison for a period not to exceed six months.
Said money to be turned over by the P A SCDU to: Rachelle D. Sybrandt. 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, P A l7106-911 0
Payments must include the defendant's P ACSES Member Number or Social Security Number in
order to be processed. Do not send cash by mail.
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Respondent to provide medical insurance coverage for Wife.
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. J. Shadday
Mailed copies on
,1-13-07 to: <
~
BY THE COURT,
Petitioner
Respondent
Marilyn Zilli, Esquire
Max Smith, Jr., Esquire
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NATHAN K. SYBRANDT,
Plaintifli'Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
RACHELLE D. SYBRANDT,
Defendant/Petitioner
NO. 01-244 CIVIL TERM
IN DIVORCE
DR# 30426
Pacses# 854103042
DEMAND FOR HEARING
DATE OF ORDER: March6,2001
AMOUNT: $312.00 per month plus $40.00 per month on arrears
FOR: Alimony Pendente Lite
REASON(S):
The hearing officer assigned an p.rning ~.p.~i~y ~n Wifp nf
$7.50 per hour. Medical evidence now shows that Wife may be
incapable of hOlding any emolovment. She should therefore be
assigned a $0 earnina capacity whioh. would result in an
adjustment of the Order.
PARTY FILING DEMAND FOR HEARING:
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NATHAN K. SYBRANDT,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2001-244 Civil Term
RACHELLE D. SYBRANDT,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE FOR BILL OF PARTICULARS
TO THE PROTHONOTARY:
Enter a rule on Plaintiff, Nathan K. Sybrandt, to file a Bill ofParticu1ars within 20 days after
Service of the Rule, or suffer a judgment of mn pros, particularizing the grounds for divorce,
specifically:
1. providing dates, times and places where/when the alleged indignities took place;
2. describing in detail the specific acts alleged to have been committed by Defendant;
3.
__".."to~ ( -7Al/L...
Marilync.~ ~- .
Attorney for Defendant
RULE
AND NOW, this q..J-.{
day of May, 200 l, a Ru1e is entered on the Plaintiff as above.
~",-j;;;J ~ ~
Prothonotary
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DR 30,426
PACSES ID 854103042
vs.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNfY, PENNSYLVANIA
: DOMESTIC RELATIONS SECTION
: CIVIL ACTION - LAW
NATHAN K. SYBRANDT,
Plaintiff/Respondent
RACHELLE D. SYBRANDT,
Defendant/Petitioner
: NO. 01-244 CIVIL TERM
MODIFIED ORDER OF COURT
AND NOW, this 7th day of May, 2001, based upon the Court's determination that Petitioner's
monthly net income/earning capacity is $N/A per month and Respondent's monthly net
income/eaming capacity is $N/ A per month, it is hereby Ordered that the Respondent pay to the
Pennsylvania State Collection and Disbursement Unit, $600.00 per month payable monthly as
follows; $572.00 per month for alimony pendente lite and $28.00 per month on arrears. Arrears set at
$658.22 as of May 7, 2001. The effective date ofthe order is May l, 2001.
This order is based upon an agreement of the parties through their counsel and Wife
withdrawing her request for a hearing de novo.
Husband is to make payment of $28.00 per month on the retroactive arrears.
Failure to make each payment on time and in full will cause all arrears to become subject to
immediate collection by all of the means as provided by 23 Pa.C.S.~ 3703. Further, if the Court
finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare
the Respondent in civil contempt of Court and its discretion make an appropriate Order, including,
but not limited to, commitment of the Respondent to prison for a period not to exceed six months.
Said money to be turned over by the P A SCDU to: Rachelle D. Sybrandt. Payments must be
made by check or money order. All checks and money orders must be made payable to P A SCDU
and mailed to:
P A SCDU
P.O. Box 69110
Harrisburg, PA 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.
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Unreimbursed medical expenses that exceed $250.00 annually are to be paid 0% by the
respondent and lOO% by petitioner. The petitioner is responsible to pay thefirst$250.00 annually in
unreimbursed medical expenses. Respondent to provide medical insurance coverage. Within thirty
(30) days after the entry of this order, the Respondent shall submit written proof that medical
insurance coverage has been obtained or that application for coverage has been made. Proof of
coverage shall consist, at a minimum, of: 1) the name of the health care coverage provider(s); 2) any
applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims
should be made; 5) a description of any restrictions on usage, such as prior approval for hospital
admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage
contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms.
This Order shall become final ten days after the mailing of the notice of the entry of the Order
to the parties unless either party files a written demand with the Prothonotary for a hearing de novo
before the Court.
DRO: R. 1. Shadday
Mailed copies on
5-I<!b! to: <
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BY THE COURT,
Petitioner
Respondent
Max Smith, Jr., Esquire
Marilyn Zilli, Esquire
J.
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State Commonwealth nf pennsvlvania
Co.lCitY/Dist. of CUMBERLAND
Date of Order/Notice 05/07/01
Court/Case Number (See Addendum for case summary)
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
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o Original Order/Notice
@ Amended Order/Notice
o Terminate Order/Notice
) RE: SYBRANDT, NATHAN K.
) Employee/Obligor's Name (Last, First, MI)
) 177-68-0083
) Employee/Obligor's Social Security Number
) 3655100690
) EmployeefObligor's Case Identifier
) (See Addendum for plaintiff names associated with cases on attachment)
) Custodial Parent's Name (Last, First, MI)
)
Employer/Withholder's Federal EIN Number
PENN I'IATIONAL GAMING INC
Employer/Withholder's Name
825 BERKSHIRE BLVD
EmployerlWithholder's Address
WYOMISSING PA 19610-1247
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER lNFORMA 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.
$ 572.00 per month in current support
$ 28.00 per month in past-due support Arrears 12 weeks or greater? Oyes (jQ 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 $ 600.00 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:
$ 13 8.46 per weekly pay period.
$ 276.92 per biweekly pay period (every two weeks).
$ 300.00 per semimonthly pay period (twice a month).
$ 600.00 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 remilling 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 10 (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
DRO: RJ Shi3dday ~
xc: defendant ~
Date of Order: May 8, 2CXJl
BY THE COURT:
JIJ]x;E
Form EN-028
Worker ID $IATT
Service Type M
OMB No.: 0970-0154
Expiration Date: 1.2131100
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If checked you are required to provide a copy of this form to your employee.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment
to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to
each employee/obligor.
3.* Repoltihg tile PaydMDd.tt urV~'itl,I,6IJihg. You lllust lepolL lL6 tJtiydateldare of nitlllloldLI,5 nll"-" ;Jl;;;uJ;ll,5 t1I{. Pa.lll1ellt. Tile
jJ<\lJate!.::Iali. of nitLLoldhlg i::o lLe date 611 nllkll allloUI.t na.S vv;tllLelJ nol.. tl16 ehtplo)'ee's YVQ,5l;;;::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 forward the support payments.
4. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support
against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must
follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest
extent possible. (See #9 below)
S. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for
you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
WITHHOLDER'S ID: 2322344730
EMPLOYEE'S/OBLlGOR'S NAME: SYBRANDT, NATHAN K,
EMPLOYEE'S CASE IDENTIFIER: 3655100690 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6, Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should
have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs
unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from
employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding.
Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is
employed governs.
9.' Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.S.c. 91673 (b)l; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security 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
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (71 7) 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 Date: 12/31/00
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ADDENDUM
Summary of Cases on Attachment
SYBRANDT, NATHAN K.
,
Defendant/Obligor:
PACSES Case Number 854J.030421.3w;).{p
Plaintiff Name /....
RACHELLE D. SYBRANDT
Docket Attachment Amount
OJ.~CIVIL $ 600.00
Child(ren)'s Name(s):
DOB
d:;~~~~~:~;~~~;;~;~~:ired to enroll th~~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):
DOB
'::",'::.,:'::,:,',:"",::::::",:",,::',:::,::,":::'.::.":":':': ,::',:'::,::::,:'::,:: " ,,:",.::::..:, ,::,.:::.::.,"'::',':"',.:'::,::'::,::"',:"'.::,..:,:,.;.",::::,....:..:"'::::::.'.::':.
. DI;~h~~k~~;;~~:;~;~~~ir~d;~~~r~;I;h~~hild(;~~).. .... .....................
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
.....".. ...,................. ...............
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:.,........,.,'..,...,':..., ",...',..,.....:..'.,......:.:.. .......:...::..:..:..::..::.::..::.
Di;ch~~k~d,;~~~;~;~~~i;~d;; enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
SeNice Type M
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
................... .
.......... ........."
,,'.'.....::..::..:........,....,....'...:....:
................... .
bli~he~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.
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
bli~.~;~~:~~..~~.~~;~..;~~~i;~~:~~~;~;I;~;:~ild~;;~;i..........i...... .
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Addendum
Form EN-028
Worker ID $IATT
OMa No.: 0970-0154
Expiration Date: 12/31/00
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NATHAN K. SYBRANDT,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 2001-244 Civil Term
RACHELLE D. SYBRANDT,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF COUNSELING
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1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
January 11, 2001.
2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety days
have elapsed since the date of filing and service of the Complaint.
3. I consent to the entry of a Final Decree of Divorce after service of notice of
intention to request entry of the decree.
4. I have been advised of the availability of marriage counseling and understand that
I may request that the Court require that my spouse and I participate in counseling. I further
understand that the Court maintains a list of marriage counselors in the Prothonotary's Office,
which list is available to me upon request. Being so advised, I do not request that the Court
require that my spouse and I participate in counseling prior to a decree being handed down by the
Court.
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I verify that the statements made in this Affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to
unsworn falsification to authorities. :7
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NATHAN K. SYBRANDT,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 2001-244 Civil Term
RACHELLE D. SYBRANDT,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
~3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a Final Decree of Divorce without further notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed with the
prothonotary.
I verify that the statements made in this Mfidavit 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
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unsworn falsification to authorities.
Date:
12-/;; h"e/
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NATHAN K. SYBRANDT,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 01 - 244 CIVIL
RACHELLE D. SYBRANDT,
Defendant
IN DIVORCE
ORDER OF COURT
AND NOW, this
J,ftr
l'tf day of
2002, the economic claims raised in the proce
been resolved in accordance with a marital settlement
agreement dated December 5, 2001, 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,
Ge
cc: Max J. Smith, Jr.
Attorney for Plaintiff
Rachelle D. Sybrandt
Defendant
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MARITAL SETTLEMENT AGREEMENT
TillS AGREEMENT, made this S->'''' day of 11<1",,-,..,,,;/- ,2001, by and
between RACHELLE D, SYBRANDT (hereinafter called "Wife") and NATHAN K.
SYBRANDT (hereinafter called "Husband").
WITNESSETH:
WHEREAS, Husband and Wife were married on May 21, 1999; and
WHEREAS, There have been no children born of this marriage; and
WHEREAS, the parties hereto desire to fix and determine by this MaIital Settlement
Agreement the rights and claims that have accrued to each of them in the estate and real and
personal property of the other by reason of the marriage, and all economic rights of every kind
and description aIising from the marital relationship, including but not limited to present and
future rights of inheritance, support, maintenance, alimony, payment of counsel fees and
equitable distribution and to accept the provisions of this Agreement in lieu of and in full
discharge, settlement and satisfaction of all such rights and claims.
NOW, THEREFORE, in consideration of the premises and of the marria'ge, and in further
consideration of the mutual promises and undertakings hereinafter set forth, each intending to be
legally bound hereby, the parties agree as follows:
1. SEPARATION. It shall be lawful for each party at all times hereafter to live
separate and apart from the other party at such place as he or she may from time to time choose
or deem fit. The foregoing provisions shall not be taken as an admission on the part of either
party of the lawfulness or unlawfulness of the causes leading to their living apart.
.
2. INTERFERENCE. Each party shall be free from inte~erence, authority and
contact by the other, as fully as if he or she were single and unmarried except as may be
necessary to carry out the provisions of this Agreement.
3. WIFE'S DEBTS. Wife represents and warrants to Husband that as of the date of
separation she has not incurred, and in the future she will not contract or incur, any debts or
liability for which Husband or his' estate might be responsible and shall indemnify and save
harmless Husband from any and all claims or demands made against him by re}son of debts or
obligations incurred by her. Any and all loans, and/or debts and charge accounts, and all medical
bills, presently in Wife's name alone shall be Wife's sole and separate responsibility for payment
thereof, and Wife agrees to indemnify and save harmless Husband from any loss he may sustain,
including attorney fees, as a result of any default in payment by Wife.
4. HUSBAND'S DEBTS. Husband represents and warrants to Wife that as of the
date of the separation he has not incurred, and in the future he will not contract or incur, any debt
or liability for which Wife or her estate might be responsible and shall indemnify and save
harmless Wife from any and all claims or demands made against.heI by reason of debts or.
obligations incurred by him. Any and all loans, and/or debts and charge accounts, presently in
Husband's name alone shall be Husband's sole and separate responsibility for payment thereof,
and Husband agrees to indemnify and save harmless Wife from any loss she may sustain,
including attorney fees, as a result of any default in payment by Husband.
5. EOUITABLE DISTRIBUTION. Husband and Wife acknowledge and agree that
the provisions of this Agreement with respect to the distribution and division of marital and
separate property are fair, equitable and satisfactory to them based on the length of their marriage
and other relevant factors which have been taken into consideration by the parties. Both parties
hereby accept the provisions of this Agreement with respect to division of property in lieu of and
in full and final settlement and satisfaction of all claims and demands that they may now have or
hereafter have against the other for the equitable distribution of their property by any court of
competent jurisdiction pursuant to Section 3502 of The Divorce Code or any other laws.
2
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Husband and Wif~ voluntarily and intelligently waive and relinquish any right to seek a court
ordered determination and distribution of marital property, but nothing herein contained shall
constitute a waiver by either party of any rights to seek the relief of any court for the purpose of
enforcing the provisions of this Agreement.
6. DNISION OF PERSONAL PROPERTY, ACCOUNTS AND VEHICLES. The
parties have divided between them, to their mutual satisfaction, the personal effects, bank
accounts, household furniture and furnishings and all other articles of personal.rroperty which
have heretofore been used by them in common. _
The parties expressly agree that Wife shall be entitled to exclusive ownership of the 2001
Subam currently in her possession, and that Husband shall relinquish any and all interest he may
have in same. Husband agrees to be solely responsible for payment of the balance of the loan
thereon to PSECU in the approximate amount of $16,825.00, and shall indemnify and save
harmless Wife from any loss she may sustain, including attorney fees, as a result of any default
in payment by Husband. Wife agrees to be solely responsible for payment of all other expenses
affecting such vehicle. Wife agrees to indemnify, reimburse and save harmless, and forever
defend Husband from any loss he may sustain, including attorney fees, as a result of any default
in payment by Wife. Husband shall be entitled to exclusive ownership of the 1995 Buick
currently in his possession, and that Wife shall relinquish any and all interest she may have in
same. Husband agrees to be solely responsible for payment of any and all encumbrances, and all
other expenses affecting such vehicle. Husband agrees to indemnify, reimburse and save
harmless and forever defend Wife from any loss she may sustain, including attorney fees, as a
result of any default in payment by Husband.
The parties further agree to execute any vehicle titles, Powers of Attorney or other
documents necessary to give this ParagIaph full fOIce and effect, within fifteen (15) days upon
request of either party.
7. PENSIONS AND EMPLOYMENT BENEFITS. Husband and Wife are the
owners of certain pension plans and/or retirement plans and/or employee stock or savings plans,
which they have accumulated during the course of their past and/or present employment. It is
3
.
hereby specifically agreed that Husband and Wife each shall forever !elinquish to the other his or
her right, title and interest in said pension plans and/or retirement plans and/or employee stock or
savings plans, as well as all other employment benefits, of the other. Specifically included
herein are all benefits to which Husband is entitled through his employment with Penn National
Gaming. The parties agree to execute any and all documentation necessary to effectuate the
terms herein contained.
8. ALIMONY. Husband shall pay directly to Wife the sum of $77,5.00 per month as
alimony, commencing October 1, 2001, and continuing on or before the first day of each month
thereafter for a period of twenty (20) months, at which time it shall terminate. Thus, the Order
for alimony pendente lite dated March 6, 2001 in the Comt of Common Pleas of Cumberland.
County shall terminate effective September 30, 2001.
Husband's obligation for alimony shall terminate in the event of Wife's death or
remarriage. Alimony shall otherwise not be subject to modification by either party.
For income tax purposes, alimony specifically shall be a deductible expense for Husband
and includable as income for Wife.
The parties acknowledge that the alimony provision set forth herein may be payable and
enforced tlrrough the Domestic Relations Office of Cumberland County or any other court
having appropriate jurisdiction upon request of either party.
9. WIFE'S AUTOMOBILE ACCIDENT. Husband hereby waives any and all
claims to an award secUIed by Wife as a result of the lawsuit she filed because of her automobile
accident in August 2000. Husband agrees to sign any releases required by Wife's attorney in
that lawsuit as well.
10. COUNSEL FEES. Husband and Wife agree to be solely responsible for payment
of his or her attorney fees in connection with this Agreement and the pending divorce action
between the parties.
4
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11. HEALTH INSURANCE. Husband agrees to maintai:q health insurance covemge
on behalf of Wife until such time as a final decree in divorce has been issued. Post-divorce,
Husband shall cooperate with Wife's efforts to obtain health insurance under the COBRA law.
12. FINANCIAL DISCLOSURE. The parties acknowledge that each has disclosed to
the other the full extent of his or her income, assets, liabilities, holdings and estates and that, in
reliance on the full disclosure, each forever waives any right to set aside said Agreement, or to
defend against its enforcement or any portion thereof based upon the absence q.f such disclosure
by the other party, or based upon any claim thaUt is inequitable, unconscionable or does not
make a reasonable provision for one or the other of them.
13. SUBSEOUENT DIVORCE. Nothing herein contained shall be deemed to
prevent either of the parties from maintaining a suit for absolute divorce against the other in any
jurisdiction, nor to bar the other from demanding any such suit.
14. NO-FAULT DIVORCE. Both parties agree to execute an Affidavit of Consent
and Waiver of Notice of Intention to Request Entry of a Divorce Decree to facilitate entry'of a
divorce decree pursuant to Section 3301 ( c) of the Divorce Code contemporaneously with
execution of this Agreement. Husband shall be responsible for finalizing the divorce, and shall
provide Wife with a certified copy of the final decree in divorce after it has been issued by the
court.
15. BREACH. If either party breaches any provisions of this Agreement, the other
party shall have the right, at his or her election, to sue for damages, including attorney fees, for
such breach, or seek such remedies or relief as may be available to him or her respectively.
16. ADDITIONAL INSTRUMENTS. Each of the parties shall from time to time, at
the request of the other, execute, acknowledge, and deliver to the other party any and all further
instruments, including Deeds and other real estate-related documents, titles, pension documents,
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or other documents 'that may be reasonably required to give full force. and effect to the provisions
of this Agreement.
17. VOLUNTARY EXECUTION. The provisions of this Agreement and their legal
effect have been fully explained to Husband by Max J. Smith, Jr., Esquire, attorney for Husband.
Each party acknowledges that the Agreement is fair and equitable, that it is being entered into
voluntarily, and that it is not the result of any duress OI undue influence.
18. WANER OF CLAIMS AGAINST EST ATE. Except as herein otherwise
provided, each party may dispose of his or her property in any way, and each party hereby
waives and relinquishes any and all rights he or she may now or hereafter acquire, under the
present or fnture laws of any jurisdiction, to share in the property or the estate of the other as a
result of the marital relationship, including, without limitation, dower, curtesy, statutory
allowance, widow's allowance, right to take property against the Will of the other, and the right
to act as administrator or executor of the other's estate, and each will, at the request of the other,
execute, acknowledge and deliver any and all instruments which may be necessary or advisable
to carry into effect this mutual waiver and relinquishment of all such interest, rights and claims.
19. INCORPORATION OF AGREEMENT FOR ENFORCEMENT. This
Agreement shall bind the parties hereto and their respective heirs, executors, administrators,
legal representatives and assigns. This Agreement shall survive a decree of divorce between the
parties in any jurisdiction and any other order which may be entered in accordance with this
Agreement. When a Decree of Divorce is entered in the Court of Common Pleas of Cumberland
County, Pennsylvania or in the event that a Decree in Divorce is entered in any other jurisdiction,
the parties agree to incOIporate this Agreement in the Divorce Decree for purposes of
enforcement. It is the specific intent of the parties to be bound by the provisions hereof in lieu of
any other claim or order of support, maintenance, alimony, equitable distribution, counsel fees,
costs, maintenance of insurance, equitable relief or property settlement or with regard to any
other provision hereof. In the event that any final order of court is entered in any jurisdiction
with respect to the parties hereto which is contrary to the provisions hereof, then the rights and
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responsibilities of'each of the parties hereto shall be relieved or adjust~d to the extent necessary
to conform to this Agreement.
20. ENTIRE AGREEMENT. This Agreement contains the entire understanding of
the parties, and there are no representations, warranties, covenants or undertakings other than
those expressly set forth herein.
21. MODlFICATION AND WAIVER. A modification or waiver o! any of the
provisions of this Agreement shall be effective only if made in writing and executed with the
same formality as this Agreement. The failure of either party to insist upon strict performance of
any of the provisions of this Agreement, shall not be construed as a waiver or any subsequent.
default of the same or similar nature.
22. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for
convenience only. They shall have no effect whatsoever in determining the rights or obligations
of the parties.
23. IRREVOCABILITY. It is understood and agreed to by and between the
respective parties hereto that the property distribution and alimony provisions set forth in the
herein Agreement are IRREVOCABLE, except as provided herein, and that such distribution and
alimony provisions shall not be affected by any future change in circumstances of the respective
parties OR by other statutory or judicial alternatives which may be available to the respective
parties under prior, current or future laws of the Commonwealth of Pennsylvania or any other
jurisdiction. Except as provided herein, the parties hereby waive any respective rights to
financial support and/or alimony and/or pension or future expectancies each may respectively
have under prior, current or future laws or case decisions.
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IN WITNESS WHEREOF, the parties have hereunto set their hands and. seals the day
WIT SS
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
RAC!lELLE D. SYBRANDT ) Docket Number 01-244 CIVIL
Plaintiff )
VS. ) PACSES Case Number 854103042 ID30426
NAT!IAN K. SYBRANDT )
Defendant ) Other State ID Number
ORDER
AND NOW, to wit, on this
20TH DAY OF MARCH, 2002
IT IS HEREBY
ORDERED that the support order in this case be 0 Vacated or o Suspended or
~ Terminated without prejudice or 0 Terminated and Vacated,
effective OCTOBER 10, 2001 , due to:
THE PARTIES' MARITAL SETTLEMENT AGREEMENT OF DECEMBER 5, 2001.
DRO: RJ Shadday
xc: plaintiff
defendant
Max Smith, Esquire
Marilyn Zilli, Esquire
BY THE COURT:
JUDGE
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
)xl () /-j(tI)f {/(t//L
State Commonwealth of pennsv'vania,1c1crer ~/630V)
Co./City/Dist. of CUMBERLAND r/~1 X')
Date of Order/Notice 03/20/02 M'30V~
Court/Case Number (See Addendum for case summary)
o Original Order/Notice
o Amended Order/Notice
@ Terminate Order/Notice
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EmployerM'ithholder's Address
) RE: SYBRANDT, NATHAN K.
) Employee/Obligor's Name (Last, First, Mil
) 177-68-0083
) Employee/Obligor's Social Security Number
) 3655100690
) Employee/Obligor's Case Identifier
) (See Addendum for plaintiH names associated with cases on attachment)
) Custodial Parent's Name (last, First, MI)
)
EmployerM'ithholder's Federal E1N Number
PENN NATIONAL GAMING INC
EmployerM'ithholder's Name
825 BERKSHIRE BLVD
WYOMISSING PA 19610-1247-99
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 0.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes (Xl no
$ 0.00 per month in medical support
$ 0 . 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 0 . 00 per month to be forwarded to payee below,
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 0.00 per weekly pay period.
$ 0.00 per biweekly pay period (every two weeks).
$ 0.00 per semimonthly pay period (twice a month).
$ 0.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
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:
Service Type M
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- - 6J<jl'iration Date: 12131/00
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Form EN-028
Worker ID 21005
Date of Order: MAR 2 7 l:OOZ
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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 underthis Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. Ifthere are Federal tax levies in effect please contact the requesting
agency listed below,
2. Combining Payments: You can combine withheld amounts from more than one employee/obiigor'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. * Repe,'tihg tl,e Pa,date/Date e,f Witl ,I ,,,Idii ,g. Y"u ",ust lepe,,! d,e pa,datefdatc of ..it!.I,e,ldi"g "I,el, send;"g d,e pa,,,,eht. TI,c
pa,date/d.de <if ..it!.l,oldi"g i. tl,c date 6" ..I,kl, aiM",,! ..a. ..id,l,eld hOI" tl,e e",plo,~e's "&11"'. You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support
against this employee/obligor and you are unable to honor all support OrderINotices due to Federal or State withholding limits, you must
follow the law of the state of employee's/obligor's principal place of employment. You must honor all OrdersINotices 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: 2322344730
EMPLOYEE'S/OBLlGOR's NAME: SYBRANDT, NATHAN K.
EMPLOYEE'S CASE IDENTIFIER: 3655100690 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should
have withheld from the employee/obiigor'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 ofthe 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 Federai Consumer Credit
Protection Act (15 U.S.c. !j1673 (b)l; or 2) the amounts allowed by the State ofthe employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxesi Social Security 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 21005
Service Type M
OMS No,; 0970-0154
Expiration Date: 12131/00
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NATHAN K. SYBRANDT,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2001-244
RACHELLE D. SYBRANDT,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following infonnation, to the Court for entry of a
divorce decree:
1. Ground for divorce: irretrievable breakdown under Section (X) 3301 (c)
( ) 3301 (d) of the Divorce Code. (Check applicable section).
2. Date and manner of service of the complaint: Bv certified mail on January 19. 2001.
3. (Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by Section 3301 (c) of the
Divorce Code: by Plaintiff December 5. 2001 ; by Defendant January 2. 2002
(b)(1) Date of execution of the Plaintiffs affidavit required by Section 3301 (d) of the
Divorce Code:
; (2) date of service of the Plaintiffs affidavit upon the
Defendant:
4. Related claims pending: None
Attorney for (X) PI .
( ) Defendant
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