HomeMy WebLinkAbout01-5925STEPHEN ZIMMERMAN
PLAINTIFF VS
KIM ZIMMERMAN
DEFENDANT
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY PENNSYLVANIA
CIVIL ACTION -DIVORCE
NO.
>t 2001- ~ a S
wlnTicF TO DEFEND
You have been aced m court. If you wish to defend against the claims set forth
in the following pages, You moat take action arance personally or by attorney caDdpfd°sg m d
entering a written appe set forth against You. You are
notice are served, by our ~~~ or objections to the claims
writing with the court Y roceed without you and a decree of divorce or
warned that if you fail to do so the case the court. A judgme~rt maY ~°O ~ C°~~ agemst
annulment maY be entered agai°at Y m these Papers by the plaintiff. You may lose
you for any other claim or relcef requested ~ custody or visitation of your
money or property or other rights important to you, including
children. own of the
When the ground for divorce is indignihea or irretrievable breakd
ou may re4~ °sarna~ counaeGng. A list of marriage counselors is available in
at the Brat floor in the Dauphin Court Courthouse, Front and
marriage, y
the Office of the Proth burg PennaYlvsmis.
Market Streets, Harr-
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
ORPANNULMENWT 1 RGRANTED YOU MAY LOSE THE RIGHT TO
CLAIM ANY OF THEM.
YOU SHOULD T~-xE TH[S P`U'ERTO YOUR LAWYER ?-T ONCE. IF
YOU DO NOT HAVE A LAWYER OR CANNOT AFFO~ Off' GO TO
OR TELEYHO~~ YOU~AN GET LEGAL AEL ,rO ~D OUT
Dauphin County Lawyer Referral Service
213 North Front Street
Harrisburg, PA 17101
(717)232-7536
STEPHEN ZIMMERMAN : IN THE COURT OF COMMON PLEAS
PuuNriFF :CUMBERLAND COUNTY PENNSYLVANIA
VS
CIVIL ACTION -DIVORCE
KIM ZIMMERMAN
DEFENDANT NO. s 2001 -s9a5
COMPLA_1NT IN DIVORCE
AND NOW, comes the Plaintiff, Stephen Zimmerman, by his attorney, Gail Guida
Souders, Esquire, and pursuant to Section 3301 (d) of the Pennsylvania Divorce Code, seeks to
obtain a Decrce in Divorce from the Defendant, Kim Timmerman, upon tbe grounds set forth:
COUNTI
DIVORCE
1. Tbe Plaintiff, Stephen Zimmerman, is an adult individual residing at 15 Wayne
Road, Camp Hill, Pennsylvania, 17011.
2. The Defendant, Kim Zimmerman, is ao adult individual residing at 6303 Brandy
Lane, Mechaoicsburg,Pennaylvania 17050.
3. P1aiMiff has bcen bona fide resident of the Commonwealth of Pemaylvania for at
least sia (ti) months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on October 20,1979 in
Mechanicsburg, Pennsylvania.
5. Plaintiff has been advised of the aveilabifity of counseling and that Plaintiff may
have the right to request that the Court require the parties to participate in
counseling and does not request the same.
6. There have bem no prior actions of divorce or snnuhnwt between the parties in
this or any other jurisdiction.
7. Tbe Plaintiff and Defendant are both citizens of the United States of America.
8. The Defendant is not an active member of the Armed Services of the United
States.
9. The parties have two children Kristen D.O.B. 4/24/87 and Shawn D.O.B. 1/23/89.
10. The Plaintiff avers that the grouuda on which the action is based are:
(b) That the marriage is irretrievably broken under 23 Pa. Const. Stet. § 3301(d).
(b) The parties have been separated since June 10,1999.
11. The plaintiff requests this Honorable Court to enter a Decree of Divorce.
WHE1tEFORE, Plaintiff requests your Honorable Court enter a Decree as
follows dissolving the marriage between the parties.
/gespecttully submitted
/ C~
Gail Guida Souders
Attorney for Plaintiff
Guida Law Offices
503 North Front Street
Harrisburg, PA 17101
Supreme Court H1 # 68740
I verify that the statements made is this Complaint are true and correct. I
understand that false statements herein are made subject to the penalties of 18
Pa.C.S. § 4904, relating to unsworn falsification to authorities.
DATE:~O /5 ~~
PI.A TFF
ATTORNEY ~ R PLAINTIFF
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STEPHEN ZIMMERMAN
Plaintiff .
v.
HIM ZIMMERMAN
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -DIVORCE
NO.O1 - 5925
PRAECIPE TO ENTER APPEARANCE
To the Prothonotary:
Please enter the appearance of the Family Law Clinic on behalf of Kim Zimmerman, the
Defendant, in the above-captioned matter.
Date: U b I
GINA M. CARNES
Certified Legal Intern
L. HENNING
THOMAS M. PLACE
ROBBRT E. RAINS
Supervising Attorneys
FAMILY LAW CLII~]IC
45 Norkh Pitt Street
Carlisle, PA 17013
(717)243-2968
C O n
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STEPHEN ZIMMERMAN
Plaintiff
v.
KIM ZINIlVIERMAN
Defendant
Iri THE COURT OFO~ n'IM ENN y~VANIA
CUMBERLAND
CIVII. ACTION -DIVORCE
NO.O1 - 5925
CERTIFICATE OF SERVICE
I, Gina M. Carnes, certified legal intern at the Family Law Clinic, hereby certify that I am
serving a true and correct copy of the Praecipe to Enter Appearance on Gail Guida Souders,
Esq. , at Guida Law Offices, 503 North Street, Harrisburg, PA 17101, by depositing a copy
of the same in the United States mail, this 26`s day of October, 2001.
Gina M. Carnes
Certified Legal Intern
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
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In the Court of Conunon Pleas of Ctrtnberland County, Pennsylvania
Phone: Fax:
Plaintiff Name: Stephen Zimmerman
Defendant Name: xim Zimmerman
Docket Number: D~ _ 5925
PACSES Case Number:
Other State ID Number:
Please Wore: All corrccpondence must include the PACSES Case Number.
Income and Expense Statement
THIS FORM MUST BE FILLED OUT
(If you aze self-employed or if you aze salaried by a business of which you are owner in whole or part, you must
also fill out the Supplemental Income Statement which appears on page two of this income and expense
statement.) r /
INCOME STATEMENT OF K1 Y~ g1 mrt'I~mQYI , pe~~ev~dt~rl-~- I Pei-h over
Section I: Income and Insurance
INCOAtE:
Employer vv eto ~-wr f
Address IM SOr\ Yt.
Type oC Work ht Lr'
Payroll No.$~jy2 Gross Pay per Pay Period S
Itemized Payroll lkdunions: A~IPVAAO.
Federal Withhold' S Social Security S U(p [-Deal W e Tax S 1 , $O
State Income Tax S 3. I a1 Retiremem S Sav' ands $
Credit Union 5 Irfe htsutanre 5 Heahh ImonrKe S
e t taCG S S
Other Deductiorm (specify) s s
Ner Pay per Pay Period S 1 (J~ • (D {
OTHER (Fill in Appropriate Colttmn)
INCOME WEEK MONTH YEAR
Interest S 5 $
Dividends
Pension
Amuit
Social Security
Rents
Royalties
Ex nsc Account
Gifts
Unem lovment
Workmen's
Cum ensation
Other
Other
TOTAL S S S
TOTAL INCOME S
PROPERTY Ownership '
OWNED DESCRIPTION VALUE H W J
Checking Accounts S
Savings Accounts
Credh Union
StockslBonds
Real Estate
Other
TOTAL IS Q
* H=Husband; W=Wife; f=Joint
Form [N-008
Sen~ice Type Worker [D
~.~ttklJ rrrrwn l6 { 21 ~ O l -{-6 I ~ 19 ~02
Income and Expense Statement
PACSES Case Number
Coverage "
INSURANCE
COMPANY
POLICI' k
H
W
C
Hospital
C
Bl A-e.-iv1a, C~'UtAS1OW'~'S~ ~ / /
ue
ross
Other
Medical
Shi
ld
Bl ~~~~~ Ch~bGIY~~.~S~ / `~ ~/
ue
e
Other
Healdt/Accident
Disability Income
Dental / 1,. 11 ~
~-~ lY1 LISG r$~
/
l/
V
Other
* H=Husband; W=Wife; C=Child
Section II: Supplerttental Income Statement
a. This Cortn is to be fdkd out by a person
(1) who operues a busineas or practices a profession, or
(2) who is a member of a partnership or joint venms, or
(3) who is a shueholder in and is salaried by a closed corporation or similar entity.
b. Attach to this atatemem a copy of the following documents relating to Ne panrcrsh~, joint venture, busircss, profession,
corpors[ion or similar emiy:
(1) the most ¢cem Federal Income Tax Return. and
(2) the most recem Profa and Loss Statement
c• Name of business:
Address and telephorc nuodter:
d. Namre of busuress (c me)
(I) panrcrship
(2) joint venture
(3) prokasion
(a) closed wryontion
(5) other
c. Name of accountam, convolkr or oNer person in charge of financial records:
f. Annual income from busioess:
(l) How often is mwme texived?
(2) Gross income per pay period:
(3) Net inwme per pay period:
(4) Specified deductions, if any:
Pace 2 oC3 Fonn IN-008
Income and Expetlse Statement
Section III: Expenses
PACSES Case Numher
Imtruc[ions: Only show extraordinary expenses in dtis section udess you fdlcd ow Section II on peer iwo. The categories
in 1)OLD FONT are especially important for calculating child support. !f you are requesting Spousal Sup)wrt/APL or it
you assert your case carrot be determined according [o the guideliffi grids or formula, this section must be fully completed.
(Fill in Appropriate Column)
EXPENSES
WEEK
MONTH
YEAR
Home
Mungage/Ram S - S - S -
Maimm~arrce - -'~ -
Utilities - -
Electric S - S - S -
Gas -` - _
Oil -. __.. _.
Telephone - - --
Water - - -~~-
Sewer -
Em lovmeat - - -
Public Transpoa. f -' S - S -
Lunen - -
Taxes
Real estate S ---_- $ -'-- S
Personal Property - - -
Insurance
Hotrcowror's S - S -- S -
Automobde -
Life - -
Accidem -
Health -
Other - __
Aummobile
Payrrcnts 5 S - S -
Fuel ~ _ `
Repairs -
Medical
Doctor S S - S 5
Dentist - _.
Orthodontat - - -
Hospital - -"
Medicine -- - ~S
Pee a
(glasses, braces,
orth 'c
~-
-"
EXPENSES (Fill in Appropriate Column)
(continued) WEEK AfONTH YEAR
Education
Private School S - S -- S -
Parochial School - - -
College -- ~--
Religious - -
Petsonal
Clothing S - S - S S
Food - ~jD
Barber/ _ _
CRdh Payments
CRdh Card
Charge - - _.
Memberships - - -
Loans
CRdh Union s - 5 ~- S --
Miscellaneous
Household Help 5 - S - S -
Child tare _. -
Papers/books
a s -. _ _
Entena'uunem -- -. _.-
Pay TV -- -'. '--.
Vacation - _ --
Gifts 5 - -
Legalfees _ - _
Chartable _ __. -.
ther hdd --
Ahmoay
P _. _. _
Other
S - S - S -
Total WEEK MONTH YEAR
Expenses• S S (pS,D$ S
1 verify that the statements made in this Income and Expense Statement ate tme and correct. 1 understand that false
statements herein are subject to the criminal penalties of l8 Pa. C.S. § 4904, relating to unsworn falsifica~ton to authorities.
/ c~~
Date
Plaintiff or Defendant
Page 3 of 3 Form IN-008
Service Type Worker ID
~1/EIS MARKETS, INC. - PAYROLL
EMPLOYEE LOCATION & NAME EMPLOYEE NO. S
OCTAL SEC. NO. WK. END
oge t egaza tea a8 ea a
KIM A ZIMMERMAN 5 07/07/01
CONTROL N 010647
NRS/RATE/EARNINGS
22.00 6.50
9.00 7.50
TOTAL EARNINGS
FICA
MEDICARE
FED WITHHOLDING
PA STATE TAX
LOCAL TAX
OCC PRIVILEGE
143.00
67.50
zlo.go
13.05
3.05
4.61
5.89
2.11
.00
rAxes
DEDUCTIONS
TOTAL TAXES
TOTAL DEDUCTIONS
PAY
28.71
00
181
3208736.
.00
.00
a733.1a
293.46
68.62
47.14
132.52
47.35
10.00
.00
00
41)9,
EIS MARKETS, INC. - PAYROLL
N0
WK. END
5 6 6
.
SOCIAL SEC. 3 2 2 5
_
EMPLOYEE N0. 07;14/01
NAME
EMPLOYEE LOCATION &
s5az4
184 as as54
YEAR TO DATE
058 1
KIM A ZIMMERMAN
N C RRENT
EARNIN /TAXES/DEDU
N OF TIO
38
141 .00
O0
EXPLANATI HRS/RATE/EARNINGS 6.50
21.75 .
37.50 •
7,50
5.00 4q 12.02
CONTROL # 010688
TOTAL EARNINGS 178.88
11.09 304.55
71.21
TAXES FICA 2.59 47.14
MEDICARE
FED WITHHOLDING .00
5.01 137,53
49,14
PA STATE TAX 1,79 10.00
LOCAL TAX .00
OCC PRIVILEGE ,00
20.48
TOTAL TAXES
~
I p~DUCTI0N5
TOTAL OEC+~JCTYOY S .00
PAY I -1
WETS MARKETS, INC. - PAYROLL
EMPLOYEE LOCATION 8
. NAME EMPLOYEE N0. I SOCIAL SEC. NO.
KIM A 2IMMERMIJJ S542a ~+. 1aa 48 esga
EXPLANATION- F EARNIN S/TAXES/DEDUC71ONS~-'
HRS/RATE/EARNING$
CONTROL # 010740
17.50 6.50
5.25 7.50
70TAL L•ARNINOS
TAXES
FICA
MEDICARE
FED WITHHOLDING
PA STATE TAX-
LOCAL TAX
GCC PRIVILEGE
TOTAL TAXES
:~EOUOTIONS
~', TOTAL DEDUOTIOiu$
~~ .
i
:. END
08/04/0'.• I~
113.75
39.38
153.c3
9.49
2.22
.00
4.29
1.53
.00
t7.5;
...
3275794
.00
.CO
5367.78
332.81
77.82
49.57
150.29
5%`. 70
~J.00
.W
.00
F ,.
I J
WETS MARKETS, INC. - PAYROLL
EMPLOYEE LOCATION & NAME EMPLOYEE I
058 ~ 89424
KIM A ZIMMERMAN
HRS/RATE/EARNINGS
CONTROL # 010588
TAXES
DEDUCTIONS
OCTAL SEC. N0.
Asa as eega
22.75 6.50
5.25 7.50
TOTAL EARNINGS
FICA
MEDICARE
FED WITHHOLDING
PA STATE TAX
LOCAL TAX
DCC PRIVILEGE
TOTAL TAXES
TOTAL DEDUCTIONS
WEIS FAMILY PICNIC - SEPTEMBER 23, 2001
PICNIC SLIPS MUST BE RETURNED IMMEDIATELY
401(K) CHANGES DUE BY 9/74/07
AY
WK. END
08/29/01
147.88
39.38
787.26
11.67
2.72
7.12
5.24
1.87
.00
22.56
.00
764.70
~'~
3327001\
00
.00
585z.az
362.85
84.85
51.09
163.86
.58.54
10.00
73~.~9
00
127.
ARKETS, INC. - PgyROLL
PLOYEE LOCATION & NAME
058 1 EMPLOYEE NO• SOCIAL SEC. f
KIM A ZIMMERMAN 85424 184 48 8854
CONTROL X 010558 HRS/RATE/EARNINGS
TAXES
DEDUCTIONS
11.25 6.50
5'DD 7.50
TOTAL EARNINGS
FICA
MEDICARE
FED WITHHOLDING
PA STA 7E TAX
LOCAL TqX
OCC PRIVILEGE
707AL7AXES
WEIS FAMILY PICNIC TOTAL DEDUCTIONS
PICNIC SLIPS MUST BE RETURNEDRIMMEDIA~TELY
401(K) CHANGES DUE BY 9/14/01
.~ e~ 1, as
C. END
09/01/01
73.13
37.50
110.69
6.86
1.60
.00
3.10
1.11
.00
12.67
.00
a+ a6
3343340
.Op
.00
5963.05
369.71
86.45
51.09
166.96
59.65
10.00
743.86
OO
WETS MARKETS, INC. - PAYROLL
' EMPLOYEE LOCATION & NAME EMPLOYEE NO. SOCIAL SEC. NO. ~ WK. END
058 1 s542a tea 4e ea54 ' Oy/22/D, ~, 3 3 9 2 6 2 7
KIM A ZIMMERMAN
EXPLANATION OF EARNINGS/TAXES/DEDUCT IONS CURRENT YEAR TO DATE
_ _ _
- HRS/RATE/EARNINGS
CONTROL q 010661 14.00 6.50 91 .00 .00
4.25 '7.50 31 .88 ~ .00
TOTAL EARNIt;uS 122 .88 6334 .94
TAXES
FICA 7 .62 392 .77
MEDICARE 1 J8 91 .84
FED WITHHOLDING .00 51 .09 ~,
PA STATE TAX 3 .44 177 .37
LOCAL TAX 1 .23 63 .37
OCC PRIVILEGE .00 10 .OU
TOTAL TAXES 14 .07 786 .44
DEDUCTIONS.
,;;.TOTAL OF.,DL'7I0^!S . v0 , 00
I
i
,a.,. ~~ , , ~
"°A~' " NET PAY
108.
87
_ ._ 5548
.50
WEIS MARKETS, INC. - PAYROLL
EMPLOYEE LOCATION & NAME EMPLOYEE N0. SOCIAL SEC. P
058 1 85a2a t84 48 685a
KIM A ZIMMERMAN
NRS/RATE/EARNINGS
CONTROL p 010759
TAXES
14.25 6.50
5.00 7.50
TOTAL EARNINGS
FICA
MEDICARE
FED WITHHOLDING
PA STATE TAX
LOCAL TAX
OCC PRIVILEGE
TOTAL TAT'9S
DEDUCTIONS
T07AL DEDUCTIONS
DIREC: DEPOSIT IS AVAILABLE NOW. SEE SUPERVISOR.
NET PAY
. END
10/06/01
92.63
37.50
130.13
8.07
1.89
.00
3.R4
1.:-0
.OU
ta.9o
00
t1g.23
3426375
.00
.00
6662.07
413.(15
96.59
53.67
186.53
66.64
10.00
626.48
00
LEIS MARKETS, INC. - PAYROLL
EMPLOYEE LOCATION & NAME EMPLOYEE NO. SOCIAL SEC. I
o5a 1 65aza 1aa 48 a65a
.KIM A ZIMMERMAN
HRS/RATE/EARNINGS
CONTROL N 010748 17.75 6.50
TOTAL EARNINGS
TAXES
FICA
MEDICARE
FED WITHHOLDING
' PA STATE TAX
LOCAL TAX
OCC PRIVILEGE
TOTAL TAXES
DEDUCTIONS
TC7AL ;tEDUCTIONS
DIRECT DEPOSIT IS AVAILABLE NOW. SEE SUPERVISOR.
PA
. END
10/13/01
115.38
115.38
7.15
1.67
.00
3.23
1.15
.00
13.20
:00
1oz.1a
3442943
.DD
6777.45
420.20
98.26
53.67
189.76
67.79
10.00
e39.6s
00
77
WETS MARKETS, INC. - PAYROLL
EMPLOYEE LOCATION & NAME EMPLOYEE NO. SOCIAL SEC. NO. WK. END
D58 85424 184 48 8854 ,G/2G/D, 3 4 5 9 37 7
KIM A 2IMMERMAN
HRS/RATE/EARNINGS
CONTROL # 010607 13.50 6.50 87.75 .00
5.00 7.50 37.50 .00
TOTAL EARNINGS 125.25 6902.70
TAXES
FICA 7.77 427.97
MEDICARE 1.82 100.08
FED WITHHOLDING .00 53.67
PA STATE TAX 3.51 193.27
LOCAL TAX 1.25 69.04
OCC PRIVILEGE .00 10.00
TOTAL TAXES 14.35 854.03
DEDUCTIONS
TOTAL DEDUCTIONS .00 .00
DIRECT DEPOSIT IS AVAILABLE NOW. SEE SUPERVISOR.
NET PAY I „0.90 I 6048.67
WETS MARKETS, INC. - PAYROLL
EMPLOYEE LOCATION & NAME EMPLOYEE NO.
058 ~ 85aza
KIM A ZIMMERMAN
CONTROL N 009885
HRS/RATE/EARNINGS
TAXES
DEDUCTIONS
'~OCIAL SEC. NO. WK. END
,ea ae 8854 "'D9/°' 3 4 9 0 8 3 0
17.50 6.50 .113 .75
5.25 7.50 39 .38 •00
.00
TOTAL EAiNINGS 153 .1
3
T~93.aa
FICA 9 49
MEDICARE 446.02
FED WITF.HOLDING 2 22 104.30
PA STA 7F. TAX 4 0O
29 53.67
LOCAL T;iX 201.42
OCC PRI'/ILEGE 1. 53 71.95
. 00 10.00
rorAL s„XES 17 53
. 887.36
TOTAL DEDUCTIONS I .00 I .00
NET PAY 195.60
6306.ae
WEIS MARKETS, INC. -PAYROLL
WEBS MARKETS, INC. - PAYROLL
EMPLOYEE LOCATION & NAME EMPLOYEE NO. SOCIAL SEC. NO.
058 1 -85424
KIM A ZIMMERMAN 184 48.8854
EXPLANATION OF EARNIN S/TAXES/DEDUCTIONS
CONTROL q 009372 HRS/RATE/EARNINGS
13.25 6.50
5.00 7.50
4.00 6.50
70TAL EARNINGS
TAXES
FICA
MEDICARE
FED WITHHOLDING
PA STATE TAX
LOCAL TAX
TOTALTAXES
DEDUCTIONS
UNITED FUND
TOTAL DEDUCTIONS
PART-TIME OPEN ENROLLMENT DEADLINE IS 1/18/02,
PAY
WK. END
01/05/02
86.13
37.50
26.00
148.63
9.26
2.17
.00
4..19
1.50
17.14
.50
•50
3630424
.00
.00
.00
323.39
20.05
4.69
.00
9.06
3.24
37.oa
1.00
1.00
WEIS MARKETS, INC. - PAYROLL
EMPLOYEE LOCATION & NAME EMPLOYEE NO. SOCIAL SEC. NO. WK. END
058 1 85424 184 488854 01/12/02
KIM A ZIMMERMAN
3644730
NRS/RATE/EARNINGS
CONTROL # 009295 12.50 6.50 81.25 .00
TOTAL EARNINGS 81.25 404.64
TAXES
FICA 5.04 25.09
MEDICARE 1.18 5.87
FED WITHHOLDING .00 .00
PA STATE TAX 2.28 11.34
LOCAL TAX .81 4.05
TDTAt TAXES 9.31 46.35
DEDUCTIONS
UNLTED FUND .50 1.50
TOTAL DEDUCTIDNS .50 1.50
PART-TIME OPEN ENROLLMENT DEADLINE IS 1/18/02.
PAY I ~1.aa
WEIS-MARKETS, INC. - PAYROLL
EMP TION & NAME
o5a t
KIM ~ ZIMMERMAN
CONTROL N 009182
.OYEE N0.
85424
HRS/RATE/EARNINGS
TAXES
DEDUCTIONS
OCIAL SEC. NO. I WK. END
taa ae sa5a of/t9/oz
11.25 6.50 73 .13
TOTAL EARNINGS 73 .13
FICA
MEDICARE 4 .53
FED WITHHOLDING 1 .06
PA STATE TAX
2 .00
.05
LOCAL TAX 73
TOTAL TAXES 8 37
UNITED FUND . 50
TOTAL DEDUCTIONS . 50
PaY 64.26
365.8958
.00
477.77
29.62
6.93
.00
13.39
4.78
54.72
2.00
2.00
421 , !15.
7,904.25 63.67
3 Social san:uriry wages 4 Social Security tan withheld
7,904.25 480. D7
5 Medicero xmges and tips 6 Medicare tae withheld
7, 9G4.25 114.59
a Control number Dept. Corp. Employer use only
D8BG3
c Employer's na e, addres; and ZIP code
71000 SAR
I~
~
SECOtJD
S
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ZIMMERMAN
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STEPHEN ZIMMERMAN IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA
~• CIVIL ACTION -DIVORCE
HIM ZIMbIERMAN NO.Ol - 5925
Defendant%Petitioner .
CERTIFICATE OF SERVICE
I, Jennifer Heverly, Certified Legal Intern, Family Law Clinic, hereby certify that I
served a true and conect copy of the Income and Expense Statement, with attached Payroll and
W2 Statements, upon Gail Guida Souders, Esq., at Guida Law Offices, 503 North Street,
Harrisburg, Pennsylvania 17101, by depositing a copy of the same in the United States mail this
`s` day of February, 2002.
Date 2 Jen ' everly
Ce ied Legal Intem
FAMILY LAW CLINIC
45 N. Pitt St.
Carlisle, PA 17013
717-243-2968
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STEPHEN ZIMMERMAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent :CUMBERLAND COUNTY, PENNSYLVANIA
v CIVII. ACTION -DIVORCE
KIM ZIMMERMAN,
Defendant/Petitioner NO. O1 - 5925
INVENTORY
OF
HIM ZIMMERMAN
Defendant files the following inventory of all property owned or possessed by either
party at the time this action was commenced and all property transferred within the preceding
three yeazs.
Defendant verifies that the statements made in this inventory are true and correct, to the
best of her knowledge, information, and belief. Defendant understands that false statements
herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to
authorities.
.//h
Defendant, im Zimmerman
ASSETS OF PARTIES
Defendant marks on the list below those items applicable to the case at baz and itemizes
the assets on the following pages.
(X) 1. Real Property
(X) 2. Motor Vehicles
( ) 3. Stocks, bonds, securities and options
( ) 4. Certificates of deposit
(X) 5. Checking accounts, cash
(X) 6. Savings accounts, money mazket and savings certificates
(X) 7. Contents of safe deposit boxes
( ) 8. Trusts
(X) 9. Life insurance policies (indicate face value, cash surrender value and current
beneficiaries)
10. Annuities
11. Gifts
12. Inheritances
( ) 13. Patents, copyrights, inventories, royalties
( ) 14. Personal property outside the home
( ) 15. Business (list all owners, including percentage of ownership, and officer/director
positions held by a party with company)
( ) 16. Employment termination benefits -severance pay, worker's compensation claim/award
( ) 17. Profit sharing plans
(X) 18. Pension plans (indicate employee contribution and date plan vests)
(X) 19. Retirement plans, Individual Retirement Accounts
( ) 20. Disability payments
( ) 21. Litigation claims (matured and unmatured)
( ) 22. Military/V.A. benefits
( ) 23. Education benefits
(X) 24. Debts due, including loans, mortgages held
(X) 25. Household furnishings and personalty (include as a total category and attach itemized list
if distribution of such assets is in dispute)
( ) 26. Other
MARITAL PROPERTY
Defendant lists all marital property in which either or both spouses have a legal or
equitable interest individually or with any other person as of the date this action was
commenced:
Item Description
Number Of Property
Home at 15 Wayne Road,
Camp Hill, PA 17011
1996 4-door sedan
Checking Account at
Commerce Bank
Checking Account at
at a local credit union
6 Savings Account
at a local credit union
Names of
All Owners
Stephen and Kim
Zimmerman
Stephen Zimmerman
Kim Zimmerman
Stephen Zimmerman
Stephen Zimmerman
7 Unknown contents of safe deposit box Stephen Zimmerman
9 Life Insurance Policy Stephen Zimmerman
1 g Pension Plan with employer, Stephen Zimmerman
Washington International
19 Retirement Account with employer, Stephen Zimmerman
Washington International
2g Household Furnishings Stephen and Kim
See attached itemized list Zimmerman
PROPERTY TRANSFERRED
Item Description Date of Consid - Person to whom
Number of Property Transfer eration Transferred
2 V W car 2001
LIABILITIES
Item Description Names of Names of
Number of Property All Creditors All Debtors
24
Home Mortgage
Stephen and Kim
Zimmerman
Defendant reserves the right to correct and/or supplement this Inventory to the extent that
she acquires additional information regarding assets and/or liabilities.
3
Home Furnishines still in residence:
A. Master Bedroom:
1. Queen Bed with Headboard
2. Dresser
3. Dresser with Minor
4. Nightstand
5. Lamp
6. 2 pair of green draperies
B. Children's Bedrooms
1. Single Bed with Drawers
2. Red, Caz-shaped Bed with Drawers
3. Dresser with mirror
4. Red and White Dresser
5. Wooden Toybox
6. Desk and Chair
C. Living Room:
1. Draperies on Bay Window
2. Computer
3. Love Seat
4. Couch
5. Recliner
6. 2Hexagon-shaped End Tables
7. Lamp
8. Large scenery Picture (mauve and blue)
9. Scenery Picture (canyon)
10 . Television
11 . VCR and video tapes
12 . Stereo and compact discs
D. Dinine Room
1. Tailored Blinds on two windows
2. Gold-framed Scenery Picture
3. 2 Animal Pictures
4. Television
5. Dining Room Table and Four Chairs
E. Kitchen:
1. Stove
2. Microwave
3. Refrigerator
4
4. Dishes
5. Eating and Cooking Utensils
6. Pots and Pans
7. Crystal - A Flask and 3 Glasses
8. Wok
9. Under-cupboard Can Opener
10. Crock Pot
11. Toaster
12. Glasses
13. Beer Stein from Germany
Miscellaneous:
1. Washing Machine
2. Dryer
3. Gas Grill
4. Patio Table with Umbrella and Four Chairs
5. Picnic Table
Home Furnishings no longer in Residence:
1. VCR and video tapes
2. Lamp
3. Books
5
STEPHEN ZIMMERMAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent :CUMBERLAND COUNTY, PENNSYLVANIA
~ :CIVIL ACTION -DIVORCE
KIM ZIMMERMAN,
DefendanbPetitioner NO. O1 - 5925
CERTIFICATE OF SERVICE
I, Jennifer Heverly, Certified Legal Intern, Family Law Clinic, hereby certify that I
served a true and correct copy of the Defendant's Inventory upon Gail Guida Souders, Esq., at
Guida Law Offices, 503 North Street, Harrisburg, Pennsylvania 17101, by depositing a copy of
the same in the United States mail this 25th day of February, 2002.
~'". r . _~
Jennifer everly
Certifie Legal Intern
FAMII.Y LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
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STEPHEN ZIMMERMAN
Plaintiff
v.
KIM ZIMMERMAN
Defendant
INCOME AND EXPENSE STATEMENT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
N0. 01-5925
CIVIL ACTION - LAW
IN DIVORCE
Attached hereto is the Income and Expense Statement of Defendant submitted
pursuant to Pa. R.C.P. No. 1920.31.
V C V v
Gail Guida Souders
Attorney for Plaintiff
THIS FORM MUST BE FILLED OUT
(If you are self-employed or if you are salaried by a business of which
you are owner in whole or in part, you must also fill out the Supplemental
Income Statement which appears on pages 8 and 9 of this Income and Expense
Statement.)
INCOME AND EXPENSE STATEMENT OF STEPHEN ZIMMERMAN
INCOME
Employer:WASI~sNGrol~l CTROLVP L2^rNS~R+NQA~~~ps0N,~/AI~IIL ~ 1~~ I~cT•r.
Address: ~~~ ~Q~r ~~~~' ~~C/I~~v xriJ47(~CJ~~~ I I 1 ~ ~ /~~2.7
Type of Work: SHS~PsNG Dzs~PA-~HE~
Payroll Number: ',~j~
Pay Period (weekly, biweekly etc.):
Gross Pay per Pay Period: $ ~ ZZb~~~
Itemized Payroll Deductions:
Federal Withholding $ `~r ' c56
Social Security ~ 2 'c 2"'
Local Wage Tax I I ~~~
~~~~
State Income Tax
Retirement
Savings Bonds
Credit Onion
Life Insurance
Health Insurance ,,(
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~~~~~~Other (specify) pp
16,"'~
Net Pay per Pay Period: $ -155.26
gs - w~
Other Income:
Week
(Fill
Interest
Dividends
Pension
,~Ly
Month Year
in Appr priate Column)
s s
Annuity
Social. Security
Rents
Royalties
Expense Account
Gifts
Onemployment Comp.
Workmen's Comp.
s I a ~ `lvo,t.
Total $ $ $ ~ 01 ~ '^""
TOTAL INCOME $ Q 55 . o"t 6 - Q5. ~ £~.KZ-`~
EXPENSES
Weekly ,Monthly Yearly
(Fill in Appropriate Column)
Home
Mortgage/rent $ $ 5 6~'~ 5 $ ,.~(
Maintenance ~ rJp ,-
Utilities ~f'
Electric ~p~ -~1 ,~~WQ~V~~
Gas ~ ~ p° 1~~' O
Oil
Telephone~l,C~ -
Water J V (1~
Sewer ~ ~ i t 5X~ .. ""' "U 3 ~ ~6'~'~
TRRS~
Employment
Public $ $ $
Lunch
Taxes
Real Estate $ $ $ I ~ `~~~ ~ ~~
Personal ~
Income
Insurance
Homeowners ^ ~ „( ~~I V
Automobile ~1 ~ T `~
Life $
Accident
Health
Other
Automobile
Weekly Monthly Yearly ~J"V""'"-_
(Fill in Appropriate Column)
s s ll~ 3
56.E ~ - ~-U'
Payments $ $ $
Fuel ,6 '"V~(~ I"~UW
~y Repair 3~- ~~~~.~~T~UU(9~~d
Medical~~ ~ 6 ~ V
Doctor $ $ $ ~)_
3-(~S'6 ~-tiuuz~ ~J~Q~,,
Dentist
Orthodontist
Hospital
Medicine ro~~pb- ~~1
Special needs (glasses, ~~ ~1,O.TV
braces, orthopedic
devices _ ~p ~/
Education QQn~x'~,(-~ ~~~ "'°
Private school $ $ $
Parochial school
College
Religious
Weekly Monthly Yearly
(Fill in Appropriate Column)
Personal
Clothing S ` a ,, $ $ ~ 2~~
Food 6 ~ ~f ~XIV W.~Q~J W_,(X~yV~~~~~,'~ .krQ~Q) ~/ww.q
Barber/hairdresser ~"~ ,~, ~nU~~VW
Credit payments (y h ~~
Credit card ~(J)Q/'~' ~ ~ ~~ 11J~~/.n~, 1lNYA'h°t~D~1
Charge accounpt ~. ~~~ "~~~
Memberships ^T.~O".d'-J\,~-- /~~~r/~/~~, l ~ 5 ~ y~/~,/
Loans I } 5~~ ""'-
Credit Dnion $ $ $
Miscellaneous
Household help $ $ $
Child care ~]r,[~ \" f/
Papers/books/magazines `^'`~/- /
Entertainment
Pay TV CIA~P+, ~~ ~ 1 w,~W+
Vacation \~
~ a~~~
Gifts
Weekly Monthly Yearly
(Fill in Appropriate Column)
Legal fees $ $ $
Charitable contributions
Other child support
Alimony payments
Other
TOTAL EXPENSES $ $ $
PROPERTY OWNED
Ownership* ~y
Description Value H W J Ac`~ ~T"
Checking accounts 1T ~~~ l ~~ ~ 1~~ 'J~
Savings accounts ~ !!/~ (`~
Credit Union ~ n~ r I~ J ~S"J~.~O~ {/"3 D I-~~
I verify that I have reviewed this form with my client and to the est of
my knowledge the answers herein are true and corre t
Gail Guida S uders
Attorney for Plaintiff
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GROUP UNIVERSAL LIFE FOR THE EMPLOYEES AND FAMILIES OF IBM
GROUP POLICY NUMBER; A28064-G
GROUP UNIVERSAL LIFE STATEMENT OF CASH VALUE
CERTIFICATE OWNER:
ZIMMERMAN, STEPHEN
15 WAYNE ROAD
CAMPHILL PA 17011
Insured's Name
Certificate Number
Basic Life Amount
Cash Value
Cash Value
as of 12/01/00
Premium Received"*
Total Expenses
Subtotal
Interest Credited
Cash Value Balance
as of 11/30/01
Certificate Loan Activity
Death Benefit Amount
as of 11/30/01**''`
Spouse/Domestic Partner
Employee
STEPHEN
0021526
72,000.00
Employee
OWNER NUMBER: 187-44-9576
STATEMENT PERIOD:
12/01/00 - 11/30/01
Spouse*
KIM ANN
0421497
60,000.00
Spouse"
67.80 50.20
168.39 125.10
224.52- 166.80-
56.13- 41.70-
2.72 2.00
14.39
NONE
10.50
NONE
72,014.39
60,010.50
•~~• "Premium Received" includes the Cash Accumulation contributions and
the Cost Of Insurance premium.
**" Death Benefit Amount is the sum of the "Basic Life Amount" and
current "Cash Value Balance" as of the date of death.
wiorz
GROUP UNIVERSAL LIFE FOR THE EMPLOYEES AND FAMILIES OF IBM
GROUP POLICY NUMBER: A28064-G
STATEMENT OF ACCOUNT AS OF 11/30/01
CERTIFICATE OWNER: OWNER NUMBER: 187-44-9576
ZIMMERMAN, STEPHEN
15 WAYNE ROAD STATEMENT PERIOD:
CAMPHILL PA 17011 12/01/00 - 11/30/01
Employee Spouse*
I. BENEFIT SUMMARY
Insured's Name STEPHEN KIM ANN
Original Effective Date 12/01/87 12/01/87
Certificate Number 0021526 0421497
Basic Life Amount 72,000.00 60,000.00
Accidental Death and Dismemberment Rider Yes Yes
Child Rider Yes None
~ 510,000 per eligible child)
II. MONTHLY COST SUMMARY Employee S ouse*
Rating Class Non-Smoker
Smoker
Term Insurance Cost 14.91 11.10
Administrative Expense Charge 1.00 1.00
Accidental Death and Dismemberment Rider Cost 1.80 1.80
Child Term Insurance Cost 1.00 0.00
Total Monthly Expense 18.71 13.90
III. ANNUAL COST SUMMARY Employee S ouse*
Term Insurance Cost 178.92 133.20
Administrative Expense Charge 12.00 12.00
Accidental Death and Dismemberment Rider Cost 21.60 21.60
Child Term Insurance Cost 12.00 0.00
TOTAL ANNUAL EXPENSE 224.52 166.80
PREMIUM RECEIVED
DURING STATEMENT PERIOD OF
12/01/00 to 11/30/01** 168.39 125.10
"* If you are participating in the Cash Accumulation Option the "Premium
Received includes your Cash Accumulation contributions and Cost Of
Insurance premium noted above.
THE GROUP UNIVERSAL LIFE PROGRAM IS OFFERED AND ADMINISTERED BY SEABURY &
SMITH, INC., AND UNDERWRITTEN BY METROPOLITAN LIFE INSURANCE COMPANY.
FOR UPDATED INFORMATION CALL OUR TOLL-FREE NUMBER 1-800-247-5628.
" Spouse/Domestic Partner
see reverse side
JV10~2
==
,_
._.__-
=-- -
NOTICE OF DEFERRED VESTED BENEFIT
INTERNATIONAL BUSINESS MACHINES CORPORATION
Social Security Number: 187449576
IBM Serial Number: 795854
A deferred vested benefit is payable to you under the terms of the IBM Retirement Plan. $458.00 is
payable to you on a Single Life Basis commencing the first day of the calendar month coincident
with or following your 65th birthday (i.e., the first of the month following your 65th birthday unless
your birthday is on the first day of the month in which case payments begin on that day) and
continuing thereafter for your lifetime.
You may elect to have the monthly vested rights benefit commence any month after attaining age
**62**. The vested rights benefit described above will be reduced if you elect to receive payment
earlier than age 65 or if you receive a joint and survivor annuity under the terms of the Plan. If you
are married, a 50% joint and survivor annuity will be automatically applied unless you complete the
Election of Retirement Date and Income Basis form choosing an alternate form ofpayment and you
obtain your spouse's approval, where necessary.
All payments are subject to the terms and conditions of the Plan to the extent allowed by law. The
vested rights benefits payable to you, or on your behalf, are obligations of the IBM Retirement Plan.
Date Issued: Sep 21 2001
RETIREMEN O BM SERIAL N MVESTED BEN EFIOTRNO TCE
BER. 795854
Age 65 Benefit: $ 458.00
I hereby certify that this notice was issued to me as a former IBM employee and that I will attain
age on as evidenced by the attached or previously supplied proof
of age. Payments of my vested rights income should commence on
(Year) and are to be sent to me at the address shown below until fu~1Ce(Month) 1,
My marital status is (check one): _ Marred _ Single Spouse Date of Birth
Signature
Address
THIS DEFERRED VESTED BENEFIT NOTICE SUPERSEDES ALL PRIOR DEFERRED
VESTED RIGHTS CERTIFICATES OR NOTICES.
STEPHEN ZIMMERMAN : IN THE COURT OF COMMON PLEAS
PLAINTIFF :CUMBERLAND COUNTY PENNSYLVANIA
VS
CIVIL ACTION -DIVORCE
KIM ZIMMERMAN ; NO.01-5925
DEFENDANT
CERTIFICATE OF SERVICE
I, Gaii Guida Souders, Esquire, Guida Law Offices, hereby certify that I served a true and
correct copy of the Plaintiff's Inventory upon Jennifer Heverly, Certified Legal Intern, 45
North Pitt Street, Carlisle, Pennsylvania 17013, by depositing a copy of the same in the
United States mail. ~ -- "'
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Guida Law Offices, P.C.
503 N. Front St.
Harrisburg, PA 17101
(717) 236-6440
Supreme Court ID #68740
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STEPHEN ZIMMERMAN : IN THE COURT OF COMMON PLEAS
PLAINTIFF :CUMBERLAND COUNTY PENNSYLVANIA
VS
CIVIL ACTION -DIVORCE
KIM ZIMMERMAN
DEFENDANT : NO. 01-5925
OF
STEPHEN ZIMMERMAN
Plaintiff files the following inventory of all property owned or possessed by either party at the time
this action was commenced and all property transferred within the preceding three years.
Plaintiff verifies that the statements made in this inventory are true and correct, to the best of his
knowledge, information, and belief. Plaintiff understands that false statements herein are made
subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsificat1',on to authorities.
Plain iff, Stephen Zimmennan
ASSETS OF PARTIES
Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets on
the following pages.
(X) 1. Real Property
(X) 2. Motor Vehicles
( ) 3. Stocks, bonds, securities and options
( ) 4. Certificates of deposit
(X) 5. Checking accounts, cash
(X) 6. Savings accounts, money market and savings certificates
(X) 7. Contents of safe deposit boxes
( ) 8. Trusts
(X) 9. Life insurance policies (indicate face value, cash surrender value and current
beneficiaries)
() 10. Annuities
() 1 I .Gifts
O 12. Inheritances
() 13. Patents, copyrights, inventories, royalties
O 14. Personal property outside the home
() 15. Business (list all owners, including percentage of ownership, and officer/director
positions held by a party with company)
() 16. Employment termination benefits-severance pay, worker's compensation claim/award
O 17. Profit shazing plans
(X) 18. Pension plans (indicate employee contribution and date plan vests)
(X) 19. Retirement plans, Individual Retirement Accounts
( ) 20. Disability payments
( ) 21. Litigation claims (matured and unmatured)
( ) 22. Military/V.A. benefits
( ) 23. Education benefits
(X) 24. Debts due, including loans, mortgages held
(X) 25. Household furnishings and personalty (include as a total category and attach
itemized list of distribution of such assets is in dispute)
O 26.Other
MARITAi. PROPERTY
Plaintiff lists all marital property in which wither or both spouses have a legal equitable
interest individually or with any other person as of the date this action was commenced:
Item Description Names of
Number of Property All Owners
1 House at 15 Wayne Road Stephen & Kim
Zimmerman
1996 Buick Skylark Stephen
(Purchased in October 2001) Zimmerman
Checking Account Stephen
Americhoice Credit Union Zimmerman
$0.00
6 Savings Account Stephen
Americhoice Credit Union Zimmerman
$1,989.00
Safe Deposit Box With Stephen & Kim
No Items of Value Exist In It Zimmerman
Life Insurance Policies Stephen
Zimmerman
a) Stephen-$72,000, Cash Value $14.39
Beneficiary-Earnest Zimmerman
b) Kim-$60,000, Cash Value $10.50
Beneficiary-Stephen Zimmerman
18 Pension Plan From IBM Stephen
Can Vest at 62 NO Value Until Then Zimmerman
19 IRA With Americhoice Credit Union Stephen
Value $3,579.22 Zimmerman
25 Household Furnishings Stephen & Kim
See Attached List Zimmerman
PROPERTY TRANSFERRED
Item Description Date of Consideration Person to whom
Number of Property Transfer Transferred
2 1988 V W Fox October 2001 Given Free James Slatt
For Parts
Item Description
Number of Property
24 Home Mortgage
$25,002.71
LIABILITIES
Names of
All Creditors
Names of
All Debtors
Stephen & Kim
Zimmerman
24 Pinnacle Health
$477.00
24 Holy Spirit
$221.00
24 Visa
$3,132.72
24 Mastercazd
$8,129.16
24 Holy Spirit
$150.00
24 Boscovs
$63.58
24 Sears
$23.95
Stephen & Kim
Zimmerman
Stephen
Zimmerman
Stephen
Zimmerman
Stephen
Zimmerman
Stephen
Zimmerman
Stephen
Zimmerman
Stephen
Zimmerman
Plaintiff reserves the right to correct and/or supplement this Inventory to the extent that he
acquires additional information regarding assets and/or liabilities.
Home Furnishin¢s Still In Residence
A. Master Bedroom:
1. Queen Bead With Headboazd
2. Dresser
3. Dresser With Minor
4. Nightstand
5. Lamp
6. Two Pair Of Green Drapes
7. Stereo and Compact Discs
B. Children's' Bedrooms:
1. Single Bed With Drawers
2. Desk and Chair
3. Dresser With Mirror
4. Caz Bed With Drawers
5. Dresser
6. Desk With Chair
7. Stereo
8. Stereo
C. Living Room:
1. Drapes On Bay Window
2. Sofa
3. Love Seat
4. Recliner
5. End Table
6. Computer (Children's)
7. Computer Desk (Children's)
8.Television
9. VCR
10. Lazge Scenery Picture
11. 3 Lamps
12. Surround Sound Receiver With Speakers
D. Dinin Rg oom:
1. Blinds On Two Windows
2. Table & Six Chairs
3. Large Gold Framed Scenery Picture
4. Two Animal Pictures
5. Television
E. Kitchen:
1. Stove
2. Microwave
3. Refrigerator
4. Dishes
5. Eating & Cooking Utensils
6. Pots & Pans
7. Radio/Cassette Player
8. Flask &Glasses-Crystal
9. Can Opener
10. Crock Pot
11. Toaster
12. Glasses
F. Miscellaneous:
1. Lawn Mower
2. Dryer
3. Washing machine
4. Vacuum Cleaner
G. Items Removed Form Residence:
1. Lamp
2. Books
3. VCR
4. 100 To 200 Video Cassette Movies
STEPHEN ZIMMERMAN : IN THE COURT OF COMMON PLEAS
PLAINTIFF :CUMBERLAND COUNTY PENNSYLVANIA
VS
CIVIL ACTION -DIVORCE
KIM ZIMMERMAN
DEFENDANT : NO. 01-5925
CERTIFICATE OF SERVICE
I, Gail Guida Souders, Esquire, Guida Law Offices, hereby certify that I served a true and
correct copy of the Plaintiff's Inventory upon Jennifer Heverly, Certified Legal Intern, 45
North Pitt Street, Cazlisle, Pennsylvania 17013, by depositing a copy of the same in the
United States mail.
Date: \ !) ~. !' VI ~ (?~~ l/7
Gail Guida Souders
Guida Law Of~'ices, P.C.
503 N. Front St.
Harrisburg, PA 17101
(717)236-6440
Supreme Court ID #68740
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Statement of Intention to Proceed
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Explanatory Comment
The Supreme Court of Pennsylvania has promulgated new Rule of Civil Procedure 230.2 governing the termination of
inactive cases and amended Rule of Judicial Administration 190]. Two aspects of [he recommendation merit
comment.
I. Rule ojcivil Procedure
New Rule of Civil Procedure 230.2 has been promulgated to govern the termination of inactive cases within the
scope of the Pennsylvania Rules of Civil Procedure. The termination of these cases for inactivity was previously
governed by Rule of Judicial Administration 1901 and local roles promulgated pursuant to it. New Rule 230.2 is
tailored to the needs of civil actions. It provides a complete procedure and a uniform statewide practice, preempting
local rules.
This rule was promulgated in response to the decision of the Supreme Court in Shop v. Eagle, 551 Pa. 360,710 A.2d
1104 (1998) in which the court held [hat "prejudice to the defendant as a result of delay in prosecution is required
before a case may be dismissed pursuant to local rules implementing Rule of Judicial Administration 1901."
Rule of Judicial Administration 1901(6) has been amended [o accommodate the new rule of civil procedure. The
general policy of the prompt disposition of matters set forth in subdivision (a) of that rule continues to be applicable.
II Inactive Cases
The purpose of Rule 230.2 is to eliminate inactive cases from the judicial system. The process is initiated by the
court. After giving notice of intent to terminate an action for inactivity, the course of the procedure is with the parties.
If the parties do not wish to pursue the case, they will take no action and "the Prothonotary shall enter an order as of
course terminating the matter with prejudice for failure to prosecute." If a party wishes to pursue the matter. he or she
will file a notice of intention to proceed and the action shall continue.
a. Where the action has been terminated
If the action is terminated when a party believes that it should not have been terminated, that party may proceed
under Ru1e230(d) for relief from the order of termination. An example of such an occuremce might be the termination
of a viable action when [he aggrieved party did not receive [he notice of intent to terminate and thus did not timely file
the notice of intention to proceed.
The timing of the filing of the petition to reinstate the action is important. If the petition is filed within thirty days of
the entry of [he order of termination on the docket, subdivision (d)(2) provides that the court must grant the petition and
reinstate the action. If the petition is filed later than the thirty-day period, subdivision (d)(3) requires that the plaintiff
must make a show in to the court that the petition was promptly filed and that there is a reasonable explanation or
legitimate excuse both for the failure to file the notice of intention to proceed prior to the entry of the order of
termination on the docket and for the failure [o file the petition within the thirty-day period under subdivision (d)(2).
B. Where the action has not been terminated
An action which has not been terminated but which continues upon the filing of a notice of intention to proceed may
have been the subject of inordinate delay. Tn such an instance, the aggrieved party may pursue the remedy of a
common law non pros which exits independently of termination under Rule 230.2.
Office of the Prothonotary
Cumberland County
Curtis R. Long
Prothonotary
Case # 01-5925 02-2154
NOTICE OF PROPOSED
TERMINATION OF COURT CASE
To: GAIL GUIDA SOUDERS ESQ
The court intends to terminate this case without further notice because
the docket shows no activity in the case for at least two years.
You may stop the court from terminating the case by filing a Statement
of Intention to Proceed. The Statement of intention to Proceed should be
filed with the Prothonotary of the Court at:
CUMBERLAND COUNTY PROTHONOTARY
ONE COURTHOUSE SQUARE
CARLISLE, PA 17013
717-240-6195
on or before October 25.2005.
Date
IF YOU FAIL TO FILE THE REQUIRED
STATEMENT OF INTENTION TO PROCEED, THE
CASE WILL BE TERMINATED
September 16, 2005
Date of [his Notice Ofd
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STEPHEN
VS
KIM ZIMMERMAN
MAN IN THE COURT OF COMMlON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
Defendant NO. 01-5925 CIVIL TERM
NOTICE
If you wish to deny any of the statements set forth in this
affidavit, you must file a counter-affidavit with in twenty days
after this affidavit has been served on you or the statements will
be admitted.
AFFIDAVIT UNDER
SECTION 3301 (d) OF THE
DIVORCE CODE
1. The parties to this action separated on June 10, 1999 and
have continued to live separate and apart for a period of at least
two years.
2. The marriage of plaintiff and defendant is irretrievably
broken.
3. 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.
I verify that the statements made in this affidavit are true aad
correct. I understaad that false statements herein are made
subject to the penalties of 18 Pa.C.S. § 4904 relating to unsvtorn
falsification to authorities.
DATE V.uJGIE} I'JSl-I ~ 2J°J~/~ S
3teplen Zimmerman
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STEPHEN ZIIVIMERMAN : IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLANDCOUNTY,PENNSYLVAMA
VS
CIVII, ACTION -DIVORCE
KIM ZIMMERMAN .
nEFENDANT NO. 01-5925 CIVIL TERM
CERTIFICATE OF SERVICE
I hereby certify that on October 18, 2001, I served a copy
of the Divorce Complaint upon Kim Zimmerman and in the manner
indicated below, which service satisfies the requirements of
Pennsylvania Rule of Civil Procedure. 403.
Service by U.S. Certified Mail to:
Gai Guida Souders, Esquire
Guida Law Offices, P.C.
111 Locust Street
Harrisburg, PA 17101
717-236-6440
Dated: August 18, 2006
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STEPHEN ZIMMERMAN
pLAINTIFF/RESPNODENT
vs
KIM ZIMMERMAN
DEFENDANT/PETITIONER
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -CUSTODY
NO. 01-5925 CIVIL TERM
I, Gillian Woodward, Legal Intern, ou behalf of my client, Kim Zimmerman, accept
service of the Notice of Intention to Request Entry of a Divorce Decree and Affidavit Under
Section 3301 (d) of the Divorce Code I certify that I am authorized to do so.
Date ~ ` Z ,~~b~Q
G' 'an Woodward, Legal Intern
Dickenson Family Law Clinic
45 North Pitt Street
Carlisle, PA 17013
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STEPHEN ZIMMERMAN : IN THE COURT OF COMMON PLEAS
PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA
VS
CIVIL ACTION -DIVORCE
IQ1VI ZIMMERMAN
DEFENDANT NO.Ol-5925 CIVIL TERM
NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE
TO KIM ZIMMERMAN, Defendant
You have been sued in an action car divorce. You have failed t~ answer the
complaint or file a counter affidavit to the plaintiff s affidavit. Therefore, on or after
August 1, 2006, the plaintiff can request the court to enter a final decree in divorce.
If you do not file with the Prothonotary of the court an answer with your
signature notarized or verified or a counter affidavit by the above date, the court can
enter a final decree in divorce. Unless you have already filed with the court a written
claim for economic relief, you must do so by the above date or the court may grant
the divorce and you will lose forever the right to ask for economic relief. A
COUNTER AFFIDAVIT THAT YOU MAY FILE WITH THE PROTHONOTARY
OF THE COURT I5 ATTACHED TO THIS NOTICE.
UNLESS YOU HAVE ALREADY FILED WITH THE COURT A WRITTEN
CLAIM FOR ECONOMIC RELIEF, YOU MUST DO SO BY THE ABOVE DATE
OR THE COURT MAY GRANT THE DIVORCE AND YOU WILL LOSE
FOREVER THE RIGHT TO ASK FOR ECONOMIC RELIEF. THE FILING OF
THE FORM COUNTER-AFFIDAVIT ALONE DOES NOT PROTECT YOUR
ECONOMIC CLAIMS.
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 LEGL HELP.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
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STEPHEN ZIlI~IlVIERMAN IN THE COURT OF COMMON PLEAS
eLAUVTiFF CUMBERLANDCOUNTY, PENNSYLVANIA
VS
CIVIL ACTION -DIVORCE
KIM ZDI~IERMAN
DEFENDANT NO.Ol-5925 CPi3II. TERM
Counter-Affidavit under § 3301 fdl of the divorce code
1. Cl~k either (a) or (b):
~/ (a) I do not oppose the entry of a divorce decree.
^ (b) i oppose the entry of a divorce decree because (Check (i), (ii) or both):
^ (i) The parties to this action have not lived separate and apart for a
period of at least two years.
^ (ii) The marriage is not irretrievably broken.
2. Check either (a) or (b):
^ (a) I do not wish to make any claims for economic relief. 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.
^ (b) I wish to claim economic relief which may include alimony, division of
property, lawyer's fees or expenses or other important rights.
I understand that in addition to checking (b) above, I must also file all of my
economic claims with the prothonotary in writing and serve them on the other
party. If I fail to do so before the date set forth on the Notice of Intention To
Request Divorce Decree, the divorce decree may be entered without further delay.
I verify that the statements made in this affidavit aze true and correct. I understand that
false statements herein aze made subject to the penalties of 18 Pa.C.S. § 4904 relating to
unswom falsification to authorities.
DATE ~-~~2j,IQ( _
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Kim Zi erman
NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE
DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC
RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT.
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STEPHEN ZIMMERMAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. :CIVIL ACTION
IN DIVORCE
KIM ZIMMERMAN, NO. S - 2001-5925
Defendant
MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT is made this 3E day of ~p , 2006, between Plaintiff, Stephen
Zimmerman ("Husband"), and Defendant, Kim Zimmerman ("Wife").
WHEREAS, Husband and Wife desire to enter into an agreement as to all economic
issues between the parties, except child support which is docketed at Zimmerman v.
Zimmerman, Docket No. 01186-DR-OS, PAC5ES Case Number 022102256, and to have this
agreement made an Order of Court;
NOW, THEREFORE, Wife and Husband, each intending to be legally bound hereby,
agree as follows:
DIVORCE
The parties have lived separate and apart since June of 1999.
2. Upon fulfillment of the provisions contained herein, both parties shall promptly file all
necessary papers to finalize the divorce pursuant to Section 3301(c) or 3301(d) of 23 Pa.
C.S.
PERSONAL PROPERTY
Upon signing this Agreement, Husband shall grant Ryan Zimmerman access to the
marital residence at 15 Wayne Road, Camp Hill, Pennsylvania 17011, and shall allow Ryan
Zimmerman to take the dresser which Wife believes to be located in the bedroom of the marital
residence and deliver the dresser to Wife as her sole property.
4. Wife hereby assigns to Husband all of her rights in any other furniture, furnishings, rugs,
household equipment and appliances, pictures, books, works of art, and any other items of
tangible property of whatever nature which are presently located in the marital residence other
than the dresser specified in Paragraph 3. These items shall constitute the sole property of
Husband.
REAL PROPERTY
5. The parties jointly own real estate, the marital residence, located at 15 Wayne Road,
Camp Hill, Pennsylvania 17011.
6. The parties agree that Husband shall pay $20,000 to Wife in exchange for Wife releasing
and renouncing any further legal or equitable interest in said real estate upon receipt of payment
in full. Husband shall refinance and retitle said real estate in his own name. Husband shall
assume sole responsibility for any mortgages and any other debt associated with said real estate
upon refinancing and retitling it in his own name. The parties shall cooperate in executing any
legal papers to allow Husband to refinance the real estate in his own name and retitle it in his
own name. The parties agree that they shall fulfill al of th obli at' ns specified in this
a ~,~+, 3m~ ps3~23~~~6
paragraph by no later than Iv~q-1, 2006. Time sha 1 be o the essence.
RETIREMENT PLAN
7. Wife shall be entitled to one half of the fixed annuity of Husband's IBM Retirement Plan.
Wife's counsel, the Famiiy Law Clinic, shall assume primary responsibility for drafting a
Qualified Domestic Relations Order to submit to the court for its approval, and to submit to
Husband's employer's pension plan administrator.
8. Wife shall bear sole responsibility for paying any costs or expenses that may be incurred
in drafting, preparing, or filing said Qualified Domestic Relations Order.
MEDICAL INSURANCE COVERAGE
9. Husband shall continue to provide medical coverage for Wife until the entry of the
divorce decree.
AIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT
10. Husband and Wife do hereby waive, release, dischazge and give up any rights which
either may have against the other to receive alimony, alimony pendent elite, spousal support, or
other post-divorce maintenance or support. From the date of entry of the divorce decree, it shall
be the sole responsibility of each party to sustain himself or herself without seeking support from
the other, except this shall not affect child support which is docketed at Zimmerman v.
Zimmerman, Docket No. 0118b-DR-OS, PACSES Case Number 022102256.
REMEDIES
11. If either party breaches any provision of this agreement, the other party shall have the
right, at his or her election, to sue for damages for such breach, and seek any other remedy
allowed under Pennsylvania law.
BINDING ON PARTIES AND OTHERS
12. This agreement shall be binding on the parties and their respective heirs, executors,
administrators and assigns.
INCORPORATION
13. The parties intend this agreement to be incorporated, but not merged, into the divorce
decree. This agreement shall continue in full force and effect after such time as a final decree in
divorce may be entered with respect to the parties.
MODIFICATION TO BE IN WRITING
14. No modification or waiver of any of the terms hereof shall be valid unless in writing and
signed by both parties.
LAW OF PENNSYLVANIA APPLICABLE
15. This Agreement shall be construed in accordance with the laws of the Commonwealth of
Pennsylvania.
INTEGRATION
16. This Agreement constitutes the entire understanding of the parties and supersedes any
and all prior agreements and negotiations between them. There are no representations or
warranties other than those expressly set forth herein.
NO WAIVER OF DEFAULT
17. This Agreement shall remain in full force and effect. The failure of either party to insist
upon strict performance of any of the provisions of this Agreement shall in no way affect the
right of such party thereafter to enforce the same, nor shall the waiver of any breach of any
provision hereof be construed as a waiver of any subsequent default of the same or similar
nature, nor shall it be construed as a waiver of strict performance of any other obligations herein.
ADDRESSES OF PARTIES
18. As long as any obligations remain to be performed pursuant to the provisions of this
Agreement, each party shall have the affirmative obligation to keep the other informed of his or
her residence address, and shall promptly notify the other in writing of any change of address by
giving the new residence address.
19. Each of the parties has carefully read and fully considered this Agreement and all
of the statements, terms, conditions, and provisions thereof, and has consulted with
counsel prior to signing below.
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STEP EN ZIMMERMAN KIM ZI RMAN,
Plaintiff Defendant
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GAIL GUIDA-SOUDERS, ESQ.
Guida Law Offices, P.C.
111 Locust Street
Harrisburg, PA 17101
(717)236-6440
Attorney for Plaintiff
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Certified Legal Intern
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ROBERT E. RAINS
THOMAS M. PLACE
LUCYJOHNSTON-WALSH
ANNE MACDONALD-FOX
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
71?-243-2968
Attorneys for Defendant
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STEPHEN ZIMMERMAN
Plaintiff
V S.
KIM ZIMMERMAN
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-5925 CIVIL TERM
CIVIL ACTION -DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the Court for entry of a divorce
decree:
Grounds for divorce: irretrievable breakdown under Section Q 3301 c (X) 3301 d of the
Divorce Code (Check applicable code)
2. Date and manner of service of the complaint: October 18, 2001 by Registered Mail.
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: Plaintiff-July 13, 2006, Defendant-July 25, 2006.
(B) (1) Date of execution of the plaintiff s affidavit required by Section 3301 (d)
of the Divorce Code: July 13, 2006
(2) Date of Sling and service of the plaintiff s affidavit upon the respondent
filed: Filed plaintiff s affidavit on July 20, 2006;
Related claims pending: settled by written agreement on: May 30, 2006
4. (Complete eith (A r (B).)
(A) Date and manner of service of the notice of intention to file praecipe to
transmit record, a copy of which is attached: Service made to attorney on July
25, 2006
(B) (1) Date plaintiff s Waiver of Notice in § 3301 (c) Divorce was filed with the
Prothonotary:
(2) Date defendant's Waiver of Notice in § 3301 (c) Divorce was filed with
the Prothonotary:
.Attorney for (X) Pla tiff () ant
STEPHEN ZIMMERMAN
PLAINTIFF/RESPNODENT
vs
HIM ZIMMERMAN
DEFENDANT/PETITIONER
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -CUSTODY
NO. 01-5925 CIVIL TERM
I, Gillian Woodward, Legal Intern, on behalf of my client, Kim Zimmerman, accept
service of the Notice of Intention to Request Entry of a Divorce Decree and Affidavit Under
Section 3301 (d) of the Divorce Code I certify that I am authorized to do so.
Date ~~ Z~~~j~Q
Gillian Woodward, Legal Intern "
Dickenson Family Law Clinic
45 North Pitt Street
Carlisle, PA 17013
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
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S`i'~~Tcf1 ZIMM~RMAN
NO. 0~-5925 CIVIL TliRM
VERSUS
KIM ZIMM3iRMAN
DECREE IN
DIVORCE
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AND NOW, ,006 IT IS ORDERED AND
DECREED THAT Stephen "IilmIDermin
AND Klm Zim>~®rllQil
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
PLAINTIFF,
DEFENDANT,
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;
ATTEST: J.
PROTHONOTARY
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STEPHEN ZIMMERMAN, IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY,
:PENNSYLVANIA
v. :CIVIL ACTION -LAW
DIVORCE
EQUITABLE DISTRIBUTION
KIM ZIMMERMAN,
Defendant No. S-O1-5925
QUALIFIED DOMESTIC RELATIONS ORDER
This Order is intended to serve as a Qualified Domestic Relations Order ("QDRO") by
which a division and disposition of the Participant's benefit under the IBM Personal
Pension Plan will be and is made according to the provision of sections 401(a)(13) and
414(p) of the Internal Revenue Code of 1986, as amended, ("IRC") and Section 206 of
ERISA, as amended ("ERISA").
1. Stephen Zimmerman is a participant in the IBM Personal Pension Plan (the
"Plan"). Kim Ann Zimmerman is the former spouse of the participant and is the
Alternate Payee as defined under IRC Section 414(p).
2. All notices and other communications by and to the Participant, the Alternate
Payee and the Plan Administrator shall be mailed by first class mail, postage prepaid, to
the following addresses:
To Participant: Stephen Zimmerman
15 Wayne Road
Camp Hill, PA 17011
Social Security Number: 187-44-9576
IBM Serial Number: 795854
Birth date: 10/17/1954
To Alternate Payee: Kim Ann Zimmerman
6303 Brandy Lane
Mechanicsburg, PA 17050
Social Security Number: 184-48-8854
Birth date: 10116/1957
To Plan Administrator: IBM Personal Pension Plan
C/O IBM QDRO Administration
P.O. Box 24110
Jacksonville, FL 32241-4110
i
Any of the parties may designate another address for the purpose of receiving
notices and communications pursuant to this Order by giving written notice to the other
parties at the addresses then currently in effect.
3. The allocation and disposition of the Participant's benefit under the Plan relates to
a provision of the Pennsylvania Divorce Code, 23 Pa. Cons. Stat. §§ 3101 et seq., and is
in accordance with 23 Pa. Cons. Stat. § 3502 of the Commonwealth of Pennsylvania.
The interest allocated by this Order is the Participant's accrued Core benefit.
4. The Alternate Payee is awarded under the dividing method as the Alternate
Payee's separate property an amount equal to 50% of the Participant's accrued Core
benefit as of the date the Participant commences benefits.
5. The Plan is ordered to pay directly to the Alternate Payee, in full satisfaction of
the Alternate Payee's interest in the Plan as awarded herein, a monthly benefit
commencing no later than the date the Participant commences benefits and continuing for
the life of the Alternate Payee. The Alternate Payee shall have the option to elect one of
the forms of payment offered by the plan (with the exception of a joint and survivor
annuity for a subsequent spouse) at the time of the Alternate payee's commencement.
6. The Alternate Payee shall share in any possible post-retirement plan
improvements.
?. The Participant and Alternate Payee shall each be responsible for his or her own
federal, state, and local income and other taxes attributable to any and all payments from
the Plan which are received by the Participant and Alternate Payee, respectively. The
Plan shall provide to Participant and Alternate Payee in accordance with its customary
procedure such information as is normally provided to Participants in the Plan with
respect to the taxation of distributions from the Plan.
8. This Court reserves jurisdiction over the parties and the Plan until such time as all
obligations of the Plan to the Alternate Payee under this Order have been fully paid and
discharged.
9. No provision of this Order shall be construed to require the Plan, the Plan
Administrator, or any trustee or other fiduciary with respect to the Plan to take any action
which is inconsistent with any provision of the Plan as now in effect or hereafter
amended.
10. No provision in this Order shall be construed to require the Plan to (a) make any
payment or take any action which is inconsistent with any federal law, rule, regulation or
applicable judicial decision; (b) provide any type of form or benefit, or any option, which
is not otherwise provided under the provision of the Plan and specifically authorized by
this Order; (c) provide increased benefits (determined on the basis of actuarial value); or
(d) pay benefits to any Alternate Payee which are required to be paid to another Alternate
Payee under another order previously determined to be a Qualified Domestic Relations
. ~ .
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Order.
11. The undertakings and obligations of the IBM Personal Pension Plan as set forth in
this Order are solely those of the Plan. Neither IBM Corporation, any of its subsidiaries
or affiliated corporations, nor any officer, employee or agent of any of the corporations
(other then the Plan Administrator) shall be deemed to have made any. undertakings or
incurred any obligations as a result of this Order.
12. Notwithstanding any other provision of this Order, in the event that the
Participant, Alternate Payee or any other party claiming rights under this Order shall
make any claim which the Plan Administrator shall determine to be inconsistent with the
provisions of this Order or with any provision of the Retirement Equity Act of 1984, as
amended, the Plan may forthwith cease making any further payments to any person
whose rights under the Plan, in the sole judgment of the Plan Administrator, may be
affected by such claim pending resolution of such claim or further order of this Court,
and the Plan may also take such further action or actions as may be permitted by law with
respect to such claim andlor this Order.
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SO STIPULATED:
Stephen M.Li~merman, Participant Kim A. Zimme man, Alternate Payee
Date:. ~ 3 Z 3' 2~~ Date: o? -~ ~" -"~ 7
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Gail Guida Souders, Esq. sica D. Woodman-Hardy,
Guida Law Offices, P.C. ertified Legal Intern
111 Locust Street
~n
Harrisburg, PA 17101 "
(717) 236-6440 ROBER INS
Attorney for Plaintiff/ Participant THOMAS .PLACE
LUCY JOHNSTON-WALSH
ANNE MACDONALD-FOX
MEGAN RIESMEYER
KATE CRAMER-LAWRENCE
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717)243-2968
Attorneys for Defendant/ Alternate Payee
Date _~ ~ ~ ~~ ~=
AND NOW, this ~ ~ day of /Z~ ~ ,
this Stipulation is hereby approved as an ORDER o this Court. The parties are
directed to comply with all of the terms and conditions of the Stipulation.
THE COURT:
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STEPHEN ZIMMERMAN, IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY,
:PENNSYLVANIA
v. :CIVIL ACTION -LAW
DIVORCE
EQUITABLE DISTRIBUTION
KIM ZIMMERMAN,
Defendant No. S-Ol -5925
CERTIFICATE OF SERVICE
I, Jessica D. Woodman-Hardy, Certified Legal Intern, Family Law Clinic, hereby certify
that I served a true and correct copy of the Qualified Domestic Relations Order on Charles
Buckner, IBM Personal Pension Plan Administrator at P.O. Box 24110, Jacksonville, FL 32241-
4110, by depositing a copy of the same in the United States mail, certified, restricted delivery,
return receipt requested, postage prepaid. Service was complete upon receipt by Mr. Charles
Buckner, on the 23`d day of April, 2007 as evidenced by the attached green card (reference
number ?005 0390 0003 2632 5492.)
y/a~/~~-
ssica D. Woodman-Hardy
Certified Legal Intern
THOM ' M. PLACE L~~~ ~~
ROBERT E. RAINS
ANNE MACDONALD-FOX
MEGAN RIESMEYER
Supervising Attorneys
FAMILY LAW CLINIC
Counsel for Defendant
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
UNITED STATES POSTAL SERVICE Fitst-C~ss Mai
postage & Fees Paid
LISPS
Permit No. G-10
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item 4 if Restricted Delivery is desired.
^ Print your-name and address on the reverse
so that we can return the card to you.
^ Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
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D. is delivery ~erdCfldrMlf`ein i'!~^ Yes
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2• 7005 0390 ~f7d3 2632 5492
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