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Home My WebLink About01-1506 FX L , , , , , , , , , , , , , , . . , . . , , . , . , . , . . , . , . , . . , . . , . . . '" I, , , . , ,. i '''''J'' 'I. ~',,' -.i' '-.>fJ. ;f; '" :Ii Of. , , :Ii '" "':+: . :Ii;+; Of. ;ti :Ii "'Of. IN THE COURT QF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ARNOT,n ji'ORRR~ Plaintiff VERSUS NINA FORBES Defendant AND NOW,----J~ PENNA. No. 2001-1506 Civil Term DECREE IN DIVORCE 'f, J' 7.' " ,.A,'" . ~63 ,IT IS ORDERED AND DECREED THAT ARNOLD FORBiES , PLAINTIFF, AND NINA FORBES , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTliON OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None. , , , , ATTEST' ~ : &- ( ~ PROTHONOTARY ;t;'t::+:;+; '" ;1;;1': ,.,;t;:+:",,,, . .. . .. . . . ,j;, . .'-"~'-~'-', :1::;+;"'..., . , . , , , , , . . . . , , , . , , , . , . . , . . . . , , , , , , , . . . . . . , . . . , , , , . , . , . . . . , , . . . . J. . , . , . . , . , , , . , . . . . . . . . . . . . . . . , . . . , , . :+: :+;;t';+,'''' '.' ,~'~,~ .,. ~ " """'-=> " ......",..... i~~~I~ilili:wh~_-."'''''''....."'''''''~,;~~_--.;~~ ~:.s y.:f .~,'~- ~ ~p ;Z~3'*/~ !7lJ fLz' '7- ~r~ ~4:?.7 T"'? '. .- ~ ~ . ~-~, ~-,-~~~~. ..,~ ~.._~".. .,- ,~" Co. 5'7 ['0 .__9 .., , '-- .-' ~l: I I I . , --.:Jil ., 0~&0~ , ARTHUR K, OILS DIANE M, OILS ATTo'kNEYS AT LAW 1 017 NO~~H FRONT STREET HARRISBURq. PENNSYLVANIA 17102 PHONE: (717) 233,8743 FAX: (717) 233-2567 , IMay 28, 2003 Office of Prothonotary Cumberland County Courthouse One Courthouse Square Carlisle, PAl 70 13 RE: Arnold Forbes vs. Nina Fbrbes No. 2001-1506 Civil Te~ COPy Dear Sir or Madam: Enclosed are an original and one coPY of a Praecipe to be filed in your office. Copies of the same have been served upon The Honorable Edward E. Guido and Maria P. Cognetti, Esquire, the attorn~y for the Defendant, Nina Forbes. I have enclosed a self-addressed, sta~ped envelope for return of the clocked-in I; copy. Thank you for your assistance in this kIatter. I IVery truly yours, I Diane M. Dils DMD/daf Enclosures cc: /The Honorable Edward E. Guido Maria P. Cognetti, Esquire ~, -' ~" ~~. .~ - '. '.' -. 1~; : :~'~~:~':~~'~I;-~7..~~~t~_"J~.~..:_~~_~~ '._~"~'~"~'~~~~. LS ..~_. I 7172332567 P.02 0~&0~ , ATIO~NEYS AT LAW 1017 NOFrliH FRONT STREET HARRIS6URG,jPENN5YlVANIA 17102 PHONE: (711) ~33-8743 FAX: (117) 2J;jo2~e7 ARTHUR K. OILS CIANE M, DllS May 21, 2003 Via facsimile - 240-6462 The Honorable Edward E. Guido Cumberland County Courthouse One Courthouse Square Carlisle, PAl 70 13 I RE: Amold Forbes vs, Nina Fprbes Docket No. 2001-1506 I DR. No. 31681 PASCES No, 176104477' Dear Judge Guido: I represent Arnold Forbes; Nina Forbcs is represented by Mana P. Cognetti. Esquire. A Hearinjl; is scheduled before your Honorable Court for Wcdnesday, May 28, 2003, at 8:45 a.m. in connection with a Petition to Terminate Alimony l>endente Lile. This is notification to your Honorable Court that this matter has been resolved belween the parties through counsel and I will be filing a Praecipe to Withdraw the Petition to Terminate APL, and I will also be procccding to finalize the divorce action. However, this paperwork will not be completed until next week and therefore, 1 wanted to notify your Honorable Court that there is no need fur the Hearing on May 28, 2003. I spoke with your office this date confirming the same, Thank you for your assistance in this matter, .--' DMD/daf 00: Maria P. Cognetti, RlIquire (via facsimile - 909-4068) ~- n.: . . , . . , ,j' 0__ ",",', . ,~ '~fIi;j",.,;t:'0.i, MAY-21-2003 03:44 PM .. .,':II:l..u.:::.::-..!.l...:~..==-,-., - -...-.....".l..' , -:1 t/(J -'1, ytc2 .? I,L,S.=E I LS 7172332567 P.01 Q5~ &. q]iI& ATTORNEYS AT LAW ,0,7 NORTH FRONT STRfi:l HARRI51lU/lG, PENNG'I'WAN1^ 17102 ARTHUR~, UI~S PHONE: (717) 233-8743 DI^NE M, DII.S ~AX, (717) 2~~'2~e7 ~OV}j;R SHEET FOR TELECOPIER MESSACES TO: Cht"~_A.L'- 6<.J.-,,2..~ ~~ d, /i RE: ~L~ FROM: Diane M. Oils, Esqllire PHONE: 717-232-9724 FAX: 717-233-2567 NOTE; TOTAL PAGES INCLUDING THE COVER SHERT I::.>Z.....- tf6twj 4ftKt/ {hI Hd. 4 .c;' ;::;'''hi>t'A:,c", c t..-'~-'- c,.",;t, ", - <<;,.."h" _f ./P",' ~... r ",,~'v'~' ~~ ~. :l<. REC"'<O .\~ ,,: ;L~ "y7.:F'" "-1/// ~, "., , MARIA P. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIRE, .', ' Attorney J.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 .,,!,; Attorneys for Defendant ARNOLD FORBES, Plaintiff v. : IN THE COURT OF C0M110N PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . ' I,: NO.2001~1506CMi TERM NINA FORBES, Defendant : CNlL ACTION - LAW : IN DIVORCE AFFIDA Vii' OF ACCEPT ,\NCE OF SERVICE , , " , ' , . , , ' - ' . ,'_ ,,'- :".:.:..', I,',,' ",,', -,: ' I, MARIA P. COGNETtI;E8QUIRE, d()hereby acknowledge and accept service ofa , '...," '. "I .,'. '.'", ' , " .' , , . I . i' . .', . true and correct copy of the Complaint in Di~orce directed to my client, Nina Forbes, on February 20, 2002, pursuant to P,:~syl"aniaRule of Civil Procedure No. 402(b), Date: March 25, 2002 .,',"...-- 'By: J'" 210 Graridview Avenue, Suite 102 Camp Hill, PA17011, TelephoneN()'.(717) 909-4060 Attomey for Plaintiff .",-, ~ " j -'<._J - ---_'ttM'-.ii;lL~:Ut',: , , ARNOLD FORBES, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA No. ,2001-/S"Of- CI'C);["'-/~ CIVIL ACTION - LAW IN DIVORCE NINA FORBES, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS YOU HA VB 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 be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT 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 Bar Association 2 Liberty Avenue Carlisle, P A. 17013 (717) 249-3166 1-800-990-9108 - ,,-,,-I j'- "',,~ . '~ --.;;; . . - '" . - -. lll~-~,i ARNOLD FORBES, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. ,2001- JS"bl.." ~ I~ NINA FORBES, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDIIR SECTION 3301 (c) OF THE DIVORCE ICODE 1. The Plaintiff is Arnold Forbes, an adult individual who currently resides at I P.O. Box 309, Dillsburg, York County, Pennsylvania 17019 and whose I social security number is 175-40-1742. 2. The Defendant, Nina Forbes, is an adult individual, whose current address is 1132 Gettysburg Pike, Mechanicsburg, Cumberland County, Pennsylvania 17055, and whose social security number is unknown . 3. Plaintiff and Defendant were married in June or July 1999, in Camp Hill, Pennsylvania. ", .~ ,-"'~,.:""'" >-','. , n':~~, . 4. Plaintiff and Defendant have resided in the Commonwealth of Pennsylvania for a period of at least six (6) months prior to this filing. 5. Defendant is not a member of the Armed Services of the United States or its allies. 6. Plaintiff is a citizen of the United States and Defendant is a citizen of the United States. 7. There has been no prior action for divorce filed in any jurisdiction. 8. Plaintiff has been advised of the availability of marriage counseling, and has waived said right. 9. There are three minor children born of the marriage; namely, Arie1 Forbes, born 4/14/95, Natasha Forbes, born 8/30/96 and Sabrina Forbes, born 6/16/98. 2 -.- -, . ~ jJt'.ltltalitl!iJi'iJ I 10. Plaintiff avers that the grounds on which this action IS based are: I (a) That the marriage is irretilievab1y broken. i I WHEREFORE, P1aintif~ respectfully requests your Honorable Court to grant a Decree in Divorce. B: Diane M. Rupich, Esquire 1017 North Front Street Harrisburg, PA 17102 (717) 232-9724 J.D. No. 71873 Date: J/lVjo / 3 -,. ~-......., ~" "" ,J, . '-'~-'~-- " . VF.RIFICATION_ " \..~, , ,: I verify that the statements made in Ihis , ~OMPLAINT IN DIVORCE are true and correcl, I understand Ihi!>1 tilb.e lilulemelllli herein ure made liubjcct to &be penal lies of 18 Pa. e.s. Seclion 4904 relulin~ to unliwOOl fulliiticillion to '"~rities. Da&o: March 14, 2001 , , , , """-11:1 ~ ,,- , '-I -,-, ~. "i ARNOLD FORBES, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 2001-1506 NINA FORBES, Defendant CNIL ACTION - LAW IN DNORCE PRAECIPE TO THE PROTHONOTARY: Please reinstate the Complaint in Divorce Under Section 330l(c) of the Divorce Code for service upon the Defendant. Respectfully submitted, Diane M. Rupich, Es re 1017 North Front S et Harrisburg, P A 17102 (717) 232-9724 J.D. No. 71873 Date: /0)0/ ~~I!fi.!*~i!l1fij4-illlL~~,1'4,;"pg,-,j,,~Mffii!i1fu~~;*i~(jjtli!.~~~~1,5'_:I!\<iiJ;'f-titJ,"d-~r&i-4!_1i-lfu-:".tillil~l~Pii~j'-""-~"""lilllii__llIiUifIliJilt@U.!ll'6~ "II!1!lI!:\II!!IIII"t,=_ ,~~ "." ~ ~=^-_."..,- o ~- .::;; -om rnr!'~ Z:L ZC ::Q ~T:.' kC:' ?:o ~C) ~c z ~ "__'i'_,,,.' . '0 ,.~"p='_ "', . . ,=) c:> n -. <.J "U --ci ;'0;, -''-f'"i 2,' --i ~ 5J -< ~,~-" tf! => (T> ,,- ., ,;. L. .-_, 1I::iLlJ'- ,..' 'c . .-~ -'lI -'-----~~ -"i\:;" ARNOLD FORBES, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. NO. 2001-1506 Civil Term NINA FORBES, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Please reinstate the above-captioned divorce action for service upon the Defendant. Respectfully submitted, BY: Date: February 12,2002 ~nA<"@\'lc,l'1H'MS+&'<:'!!'b,1Hi'Jk ')"<pi",,;~~,,~!_~',--4,"-'b."%"'ii!l"MI",,",~V,i<(,*/,jf,,,>-~,~A;),_if,;,~l'i;~;;i1~;~Jjjr;iMi'"'~~_iL__.&'Wti)~;1fi,MIlii-~\;;~i~iiUiHwltli:.i1tii Iilr~~'. ~~ _',0" " ~~ ,,,,, 0 ~ CI C t\.) -"~"I $~ ..." "T) (1'::' ~11 IT1....:.. -:0 Z:--..-, 7.:1" ~~~~ (.0 !;=C ~ J~c-~ 52 L:,..) ':;.1 !;- -, eN _.~.." '->~'~"''''""~-' '" -.-' lil:llfillllUIl --..- ":"-.o.l'''M'-'"_'.=,~.,. _~"",_-",c'",,,"l'_'_'__"',",,,,.:".l,~ MARIAP. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIRE Attorney LD. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Defendant ARNOLD FORBES, Plaintiff v. NINA FORBES, Defendant .,...1 __10_" ,~_ ,it"..,.-:,_ "~'__'_.",,, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001-l506 CNIL TERM : CNIL ACTION - LAW : IN DNORCE AFFIDAVIT OF ACCEPTANCE OF SERVICE I, MARIA P. COONETTI, ESQUIRE, do hereby acknowledge and accept service of a true and correct copy ofthe Complaint in Divorce directed to my client, Nina Forbes, on February 20, 2002, pursuant to Pennsylvania Rule of Civil Procedure No. 402(b). Date: March 25, 2002 MARIA P. COGNETTI & ASSOCIATES By: MARiA . C NETn, ESQUIRE Attomey LD. No. 27914 210 Orandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attomey for Plaintiff ~ "" -- ~-~ ~ -, -~.~..-.-." . ~ --~~'. - - -- . '\, J f Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ARNOLD FORBES, v. : NO. 2001-1506 Civil Term NINA FORBES, Defendant : CIVIL ACTION - LAW : IN DIVORCE DRS ATTACHMENT FORAPL PROCEEDINGS PETITIONER NAME NINA FORBES aJk!a NINA WILLS ADDRESS l132 Gettysburg Pike, Mechanicsburg, P A BIRTH DATE 2/25/75 SOCIAL SECURITY NUMBER. 553-51-4236 - HOME PHONE (717) 790-5553 , WORK PHONE nla EMPLOYER NAME None EMPLOYER ADDRESS nla - JOB TITLEIPOSITION nla DATE EMPLOYMENT COMMENCED nla GROSS PAY nla NET PAY nla OTHER INCOME nla ATTORNEY'S NAME Maria P. Cognetti, Esquire ATTORNEY'S ADDRESS 210 Grandview Avenue, Ste 102; Camp Hill, P A ATTORNEY'S PHONE NUMBER (717) 909-4060 ..~ "'f , RESPONDENT NAME ARNOLD FORBES ADDRESS 50 Chestnut Hill Road, Dillsburg, P A BIRTH DATE 4/17/49 SOCIAL SECURITYNUMBER 175-40-1742 HOME PHONE Unknown WORK PHONE Unknown EMPLOYER NAME KATSCO, Inc. - EMPLOYER ADDRESS Operates business out of residence JOB TITLEIPOSITION " - President/Owner - Builder/Developer DATE EMPLOYMENT COl\.1lY.lENCED Unknown GROSS PAY Unknown NET PAY Unknown OTHER INCOME Gambling winnings - Amount Unknown ATTORNEY'S NAME Diane Dils, Esquire - ATTORNEY'S ADDRESS I Ol7 North Front Street, Harrisburg, P A ATTORNEY'S PHONE NUMBER (717) 232-9724 MARRIAGE INFORMATION DATE OF MARRlAGE 2/14/99 PLACE OF MARRlAGE Camp Hill, P A DATE OF SEPARATION January, 2002 (may be disputed) ADDRESS OF LAST MARITAL HOME 1132 Gettysburg Pike, Mechanisburg, PA DESCRIPTION OF DOCUMENT Petition for Alimony Pendente Lite RAISING APL CLAIM DATE APL DOCUMENT EILED 4/22/02 ~~~lill ~ iIilj&..liim"'~';" .-"'~ "".- .;.....,e"""'li~-@!~~'iOIJN-.J"~""-= "" .. -, .~ "",- . 0 CJ ~?: c r,,) 5-:: no C! '_"J -,-J rn r."~ :7':1 r- 2: t r0 tJ 2:.: ~) u , r--' >,j, c. r-' C -, -" .j ~:::: ~:j " ~ ..> 7:~"- i:') ~:: "-,:.~ C> 0 Pl ~' ~ .--1 :)1 >- _..1 :n -< (7' -< ~ \:> ~ ~. ~i' _;",b., :~ _,~ ~ ~, ,,""".-,,--~ '~'--"~",,,~,,~ --,-- ~~~ -".' ">' . . - " ,_. '0 -,,< " '--" ~,.' '(1:' .' ~ . r . I MARIA P. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIRE Attorney J.D. No. 27914 210 Grandview A venue, Suite 102 Camp Hill, PA 17011 Telephone No, (717) 909-4060 Attorneys for Defendant ARNOLD FORBES, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 2001-1506 Civil Term NINA FORBES, Defendant CIVIL ACTION - LAW IN DIVORCE PETITION FOR ALIMONY PENDENTE LITE AND NOW comes Defendant, NINA FORBES a1k/a NINA WILLS, by her attomey, Maria P. Cognetti and petitions this Honorable Court for alimony pendente lite, and in support thereof, respectfully represents as follows: 1. By reason of this action, Defendant has incurred considerable expense in the preparation of her case and the employment of counsel and the payment of costs. 2. Defendant is without sufficient funds to support herself and to meet the costs and expenses of this litigation. 3. Defendant's income is not sufficient to provide for her reasonable needs and to pay her attorneys' fees and the cost of this litigation and she is unable to appropriately maintain herself during the pendency of this action. 4. Defendant lacks sufficient property to provide for her reasonable needs. 5. Defendant is unable to support herself through appropriate employment. , -~ ~ J' _ ~'. - ,~- '-,,---,,----. '>.-,,--' ~"" ~~:~- ri--! '.. 6. Plaintiff has adequate earnings to provide for the Defendant's support. WHEREFORE, Defendant prays this Honorable Court enter an Order awarding her alimony pendente lite. Respectfully Submitted: MARIA P. COGNETTI & ASSOCIATES Date: April 23, 2002 By: G ETTI, ESQUIRE . 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attomey for Defendant 1~ i,;~~ii:I~1il~I~ili!iJijlMik;ti'llftJfui61~i-lii~~~tI\WI;.r~~..liri>~*~!<*.!~~~~~' ;" '^'lI:lIIIiilIIiWiiiiI- -", t.~(l 'I .,~, ~~ '^,- , ~'^ ~ ,~ -" ~o. ~.~ rr >~. ..~'- (:) r.=\ ~ ~ '"'" ;::> " I '""() n-:: -T) rn rr> :';:J . Z ::,: N ;-1" Z ;--- ':-;Q en :i:_ C;"i ~:j~~j -< y c; -':J )-:; C ~r' '::-)~~ ;2: --"'~ ....\.-" )> 9 (~iT1 ,- ---'I '7 on ~ :'::'1 ,)'\ -'" -< -~ " ,",] ...,-. "', ARNOLD FORBES, PlaintifflRespondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NINA FORBES, DefendantJPetitioner NO,2001-1506 CIVIL TERM IN DIVORCE DR# 31681 PacseS# 176104477 ORDER OF COURT AND NOW, this I" day of May, 2002, upon consideration of the attached Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before RJ Shaddav on June 10,2002 at 10:30 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (I) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.1111) (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, George E, Hoffer, President Judge Mail copies on 5-1-02 to: Petitioner < Respondent Maria Cognetti, Esquire Diane Dils, Esquire I '- .l..tlA'J...~_<,,' ......~;......ti -" "f 1 J,'e Date of Order: May 1, 2002 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 ~!Oii~~~Ili>iMl!l!Iii!.~ii'illi'i~~:k""'j"It~I"'''-!:iW,~''''i1i<'!!'J'l'''4~:4Ol'<~",,",;';iN,ill:~J'"'-._' ,'~ """ili!ii1i~&',r"l$ ~~ ~~~-, < .,<,- ~ -",,"-'-~~ ~" ~ ,-,,>-,.~,- -"~.". .~ .<- ~~< ~lIlllil l.dH -- -1 "~~"'-', C) C> 0 C '" ~n /"' ,~ iJ g~; _'.:J,. :~ m -< ;-:i'~ >l 2~ j-"-= Z C. t 1"11 (/) :Z" ~~ y' ~~ C) Cl ~::! -;i )~-... , ---"- (~) (") ,:::::. C' ~;;. 5> :.,) 25 rn ~~~ --, ,;:- >; =2 :D (J1 -< ,- . " " >- , t , '" , - '.,,;.- ~, -:,-' ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT );;KIf d(tJCJ I-/:;--o {, (!I t//t.... State Commonwealth of Pennsylvania PI'/C.<;.fS I) ((; /01./1 f77 Co./City/Dist. of CUMBElU.AND 'f Date of Order/Notice 06/11/02 ,61C ,3-16, 71 Court/Case Number (See Addendum for case summary) o Original Order/Notice @ Amended Order/Notice o Terminate Order/Notice ) RE: FORBES, ARNOLD ) Employee/Obligor's Name (Last, First, MI) ) 175-40-1742 ) Employee/Obligor's Social Security Number ) 4589000115 ) Employee/Obligor'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 ARNOLD FORBES EmployerlWithholder's Name PO BOX 396 Employeri\Vithholder's Address DILLSBURG PA 17019-0396 See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMA nON: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 5,500.00 per month in current support $ 150.00 per month in past-due support Arrears 12 weeks or greater? Oyes <R> no $ 0.00 per month in medical support $ 0 . DOper month for genetic test costs $ per month in other (specify) for a total of $ 5.650.00 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: $ 1.303.85 per weekly pay period. $ 2.607.69 per biweekly pay period (every two weeks). $ 2.825.00 per semimonthly pay period (twice a month). $ 5.650.00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydateldate of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the the allowable amount. The total withheld amount, and your fee, cannot exceed 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). Ifremitting 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 YMENrS 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: E OW I9-Ie.J) vvi)&,c; Form EN-028 Worker ID $IATT Date of Order: JIJN 1 2 ?nn? Service Type M ..~ '--',' "-~ ':"'>11' ED: . _ >-~~.aL MBNo.:0970-0154 ',.- ~ _ xpiration Date: 12/31/00 (0 -( ;)-0')- ,~"~ ~I," ~ J' ~_H" . " ~ I - ~ ..-. Li;,li;l -~. . -, " ;:, ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS t 0 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. Combi~ing Payments: You can combine withheld amounts from more than o~e 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.' Repol,i"g lI,e Pay dale/Date of Withl.oldi"g. I'M n,ust ,ep"', Il.e paydate"latc <lI ..ill,I,,,ldil,g ..I ,ell sel1d;",; t1,~ pay,,,,,,,t. TI,e pay dale/date of "itl ,1,oldi"g is tl ,e date 0" ..I,iel, ",,,"UI ,t ..as ..ithl,eld r,(',,,, lI,~ .'"pl"y"'" ..ages, 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 ord.., and forward the support payments. 4.' Employee/Obligor with Multiple Support Holdi~gs: If there is more tha~ o~e Order/Notice to Withhold I~come 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 empioyment. 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: 1754017420 EMPLOYEE'S/08L1GOR'S NAME: FORBES , ARNOLD EMPLOYEE'S CASE IDENTIFIER: 4589000115 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 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 govems unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 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 amounls 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 stat", that issued this order with respect to these items. Requesting Agency: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLlSLF 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 17171 240-6248 or by Internet @ Page 2 of 2 Form E N-028 Worker ID $IATT Service Type M , OMB No.: 0970-0154 Expiration Date: 12/31/00 " " ..., -~I '"' -'T I ADDENDUM Summary of Cases on Attachment Defendant/Obligor: FORBES, ARNOLD 176104477/ 3/& ~ / PACSES Case Number Plaintiff Name NINA A. WILLS Docket Attachment Amount 01-1506 CIVIL$ 3,250,00 Child(ren)'s Name(s): DOB o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's empioyment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB . S ;;~h~~~~~~;~~~;~;:qUired to enroll the child(re~) '. .... identified above in any health insurance coverage available through the employee's/obligor's employment. Addendum Service Type M OMB No.: 0970-0154 Expiration Date: 12/31/00 PACSES Case Number 357104230 Plaintiff Name NINA A. wrLLS Docket Attachment Amount 00107 S 2002 $ 2,400.00 Child(ren)'s Name(s): ~~~~~~'~J?;~~ES.> ' SABRINA,A. FORBES D08 , 04/14/9,5 '68/3:0/96 96/16198 o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee'sJobligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB 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): D08 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. Form EN-028 Worker ID $IATT ''''ii>l~!til!~!~i~4,!/1;IMilli~'iJl~li~iiri'l!',#4.!riJtli11",''''';$.l~'!.>'o0;'';l,,;;,j'''''''i'J-''",*,~:&tiri@~~Jtl6i!mIIiltlliOO~jllilii'llll!iliillllil;\11~1i1~' 1.0! -,- ~~, ".- -, = ~-- "~-11~-" iM.......,'~-""'_i'" .-' I 0 0 0 C N s:: " L.. :::i (p~ c: ,,-_::D Z ;":1 ;2; Zr;:: ---::Jh, (J),c,,, N 2~6 ~L ;<C -0 .....!! )j. ~:;;:-d 20 ::-x: C-"O ;1>0 w Oln ~ -i N ?o m -< . '"'''' "" IIiIEl ~ ....."'~~{ , , " ARNOLD FORBES, PlaintiIDRespondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NINA FORBES, DefendantJPetitioner NO. 2001-1506 CIVIL TERM IN DIVORCE DR# 31681 Pacses# 176104477 ORDER OF COURT AND NOW, this II th day of June, 2002, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $l,060.58 and Respondent's monthly net income/earning capacity is $13,951.79, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $3,250.00 per month payable semi-monthly as follows; $3,200.00 for alimony pendente lite and $50.00 on arrears. First payment due next pay date. Arrears set at $6,400.00 as ofJune 11, 2002. The effective date of the order is April 25, 2002. This order is based upon a child support order for three children in a shared custody arrangement. 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: Nina Wills. Payments must be made by check or money order. All checks and money orders must be made payable to P A SCDU and mailed to: PASCDU P.O. Box 69110 Harrisburg, PA 17106-9110 Payments must include the defendant's P ACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. .,J ~ , '-" N'^~.m< I I . Unreimbursed medical expenses that exceed $250.00 annually are to be paid 100% by the respondent and 0% by petitioner. The petitioner is responsible to pay the first $250.00 annually in unreimbursed medical expenses. Neither party to provide medical insurance coverage. This Order shall become final ten days after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary for a hearing de novo before the Court. DRO: R J. Shadday Mailed copies on 6-11-02 to: < BY THE COURT, Petitioner Respondent Diane Rupich, Esquire Maria Cognetti, Esquire Edward E. Guido J ,~~~iffi!!M<li-jr.fi~~~~i$njf~8~_"''li!<~I,,.'if'-':t,'&''ie,'i\<Jb;;.1'1!<e~.B';i:i'l&loi~Ji!~DUli/iIIIIIll~~~!!1iIf~"""" JJ.,.>,t~"~ ".,.-." -"-= --"^'--~~-- -~,--, . - . <, ~-<. ", ~'- , ~ .- ~ji" ""'" "-~~~Ilii;t~ ~"" "',f - , l , g c::> 0 N -n s:: , ~--1 -0 OJ C :~.~~ ---n ITIrn Z "fj; Z:D 3? z~ I" en .., e-.'" 2"'- \~.-<:. ( , ~i --". 0 .." ;c:ti K' ~o ~ ~)() ~~ tf: ~,rn :::, ~ N ~ 0"\ . ...-'-~"" ~-'. I -'i'lfi ARNOLD FORBES, PlaintifflRespondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS, CIVIL ACTION - DIVORCE NINA FORBES, DefendantIPetitioner NO. 2001-1506 CIVIL TERM IN DIVORCE DR# 31681 PacseS# 176104477 DEMAND FOR HEARING DATE OF ORDER: June 11, 2002 AMOUNT: $3,200.00 per month plus $50.00 on arrearages FOR: Alimony Pendente Lite REASON(S): Plaintiff's incom" ;" ""ht-,,n1-i,,"y 'ellll tq8R preseRted at the time of the support ~nference. Plaintiff did not have mfficient records to SDW business expenses paid. Plain- tiff now has verification of his expenses to present before your Honora~le Court. PARTY FILING DEMAND FOR HEARING: Arnold Forbes M. Dils, Attorney for Arnold Forbes /0 r R{l()~ Date ;J~~liiiIHji!!B~I:l1cli\J;;~-m<!,~.IiciBI'h'l''''''l>,W_~';~'~''M~A.'''';l;ik''''b''!d'i;S;;-,!JiJ""'~~M'_1iili~~~""'""~.-' Jli,~1W. ~~ ~ - .- ,,= "~ ..:Jill. r llLl' Yi.'!LI '"-..-W....... o co C t'0 -,.$: c- ..J OJ c= miT,',' ,- z- ~ 2 ~ ;'"0 0..: ""'~.:. r:: Ci ' ~..-~...;'" -=e 20 ->-2..' N ';Z' .. , _~ ;n ,-<, (;;l '" .- J I~ , -, ;-_~~,___ i,,- ~""_,_=:,1iL-,,,,-., _ _"'""..",,,~~__" ~ ._, _~_"",J_", 0," .,,-. __~.,,~~""-,:-"'_, _j___CJ_~ "'-"'''__'" ,..._ _Le_": ' __ _ , ,,__,C'''',' --,-',_,",___ ~" \\Ntsb~ly la\\'ICIifjllt Dire>:tory\WiIls- Nina\pleadings\Appeal- APL.wpd , 5-~5/02 .. DR31681 PACSES ID 176104477 ARNOLD FORBES, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : DOMESTIC RELATIONS SECTION : CIVIL ACTION - LAW NINA FORBES, Defendant : NO. 2001-1506 DEMAND FOR HEARING DATE OF ORDER: June 11,2002 AMOUNT: $3,200.00 per month alimony pendente lite. FOR: Nina Forbes REASON(S): I. Hearing Officer erred in attributing Defendant with an earning capacity. 2. Hearing Officer erred by failing to award Defendant childcare expenses/pre-school expenses. PARTY FILING DEMAND FOR HEARING: Nina Forbes, a/kIa Nina Wills, Defendant 6IJ~!o~ Date -"'. ~'"[,~ !."':';'-,,,,: - -ii' - ",,", ,"~- - - ,,'" - - ." \' 1.- " , , ,. I ,~, ;,j I > I In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION NINA A. WILLS ) Docket Number 01-1506 CIVIL Plaintiff ) vs. ) PACSES Case Number 176104477 ARNOLD FORBES ) Defendant ) Other State 10 Number ORDER OF COURT You, NINA A. WILLS plaintiff/defendant of 1132 GETTYSBURG PIKE, MECHANICSBURG, PA. 17055-5320-32 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the AUGUST 12, 2002 at 1: 30PM for a hearing. You are further required to bring to the hearing: I. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. verification of child care expenses, and 4. proof of medical coverage which you may have, or may have available to you 5. information relating to professionaIlicenses 6. other: Service Type M Form CM-509 Worker 10 21006 ,1.. .;..,""~.~"'- ''''''"f''' \'" '1 '. . , WILLS v. FORBES PACSES Case Number: 176104477 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing patemity. An appropriate order may be entered against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: ll~ 02- JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING 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 CO BAR ASSOCIATION 2 LIBERTY AVE CARLISLE PA 17013-3308-02 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of2 Form CM-509 Worker ID 21006 Service Type M ;k~ii.~~~.J:l)I,ill!~~i~~ij~J;;;;':'I'!I'-W>Nii,,"b;;4~_,;m_~~I1t-ww.:ti;L,.~ .........., _~Iiil_ ~~~ ~ -.t''''4:'" ~~~ () c- o? VGJ 52[:] Zr C/] ')>" ::<~: ~t::',;. P. ~r,< J>" r ;; , (:) .' \ o N '- c:::: r- o " ::~ ;:-;:-1-0 F" ~,__,fll '317 ~~~~ ,...de) om 0::' :$ -< en CJ -',I'~ - LJ - ""'"''''-....."..-.-.'.- - .~ ,,- - ,-~""'> , j In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION NINA A. WILLS ) Docket Number 01-1506 CIVIL Plaintiff ) vs. ) PACSES Case Nwnber 176104477 ARNOLD FORBES ) Defendant ) Other State ID Number ORDER OF COURT You, ARNOLD FORBES plaintiff/defendant of 50 CHESTNUT HILL RD, DILLSBURG, PA. 17019-9729-50 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the AUGUST 12, 2002 at 1: 30PM for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. verification of child care expenses, and 4. proof of medical coverage which you may have, or may have available to you 5. information relating to professional licenses 6. other: Service Type M Form CM-509 Worker ID 21006 Po ~ -~ ",..., "'..."'~~, . WILLS V. FORBES PACSES Case Number: 176104477 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing patemity. An approp11ate order may be entered! against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: 1 I ~ 02- JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING 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 co BAR ASSOCIATION 2 LIBERTY AVE CARLISLE PA 17013-3308-02 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Worker ID 21006 Service Type M ,({t';ftJi~li:i!;^.L. '.,,,_'~L' _m~~[,;t;,"j;-,,-j1.~+i~Wm;j1!,-ill';~J,\~'ai~~~""''''''' ill J J ~~ ~_. -~< n=' ~ ~ ~'-~""~_U. lilt . o ,,, '- (- ~ o C <,:, -of,:) fl\P" Z:;i.} Z~--, t!~':?: <;2") %Z2 Z '2 ~~~ - " , - Q, --' ':-r: -1\ ,"n;;::;;:. "f'll:n -,jU ';:+)(-.J ':--:-:~ -.- ,'c.:t) 'JC) Afn ,"", -, :;>- ~ iY' .~ :~ r;. - (? "'~".-""""'""-~ ~J. Ji . '" "~"" - ""'-"~' .~_._- ~" - J;;-", ~ ARNOLD FORBES, Plaintiff/Petitioner/Obligor IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. NO. 2001-1506 CIVIL TERM CIVIL ACTION - DIVORCE DR NO. 31684 PACSES NO. l76104477 NINA FORBES, Defendant/Respondent/Obligee ALIMONY PENDENTE LITE PETITION TO TERMINATE ALIMONY PENDENTE LITE AND NOW, this;Z day of April 2003, comes the Obligor, Arnold Forbes, by his Attorney Diane M. Dils and respectfully requests the following: 1. Your Petitioner is Arnold Forbes, the Defendant/Obligor, above-named who is represented by Attorney Diane M. Dils, whose office is located at 1017 North Front Street, Harrisburg, Pennsylvania 17102. 2. The Respondent is the Plaintiff/Obligee, Nina A. Wills, who is currently represented by Attorney Maria P. Cognetti, whose office is located at 210 Grandview Avenue, Suite 102, Camp Hill, Pennsylvania 17011. 3. On or about June 11, 2002, an Order was entered in the above-captioned matter wherein Arnold Forbes was ordered to pay to his wife the sum of $3,200.00 per month representing alimony pendente lite. -1''"'''''''''''''',",'',$'''- ~~"'" ,'",C ~::. '. ~ . I ~~- ~ "~~"...~ -"l'(~iIi!f.'L , 4. Since the entry of said Order, the Respondent, Nina Wills, has failed to cooperate in the divorce action filed by your Petitioner, Arnold L. Forbes, in the Court of Common Pleas of Cumberland County, Docket No. 2001- 1506, on March 15,2001. 5. Your Petitioner and the Respondent had previously entered into Separation Agreements in February 2001 and August 2001, specifically distributing all marital property and providing for child support payments. 6. Despite the fact that your Petitioner has complied with the provisions of the Marital Settlement Agreement, the Respondent has continually added additional requirements and has refused to sign a Marital Settlement Agreement. 7. The Respondent has failed to respond to correspondence for approximately four month periods of time, specifically, your Petitioner's counsel forwarded correspondence to the Respondent's counsel in November 2002, to which a response was received in March 2003. 8. One of the proposals set forth in the Marital Settlement Agreement prepared by your Petitioner's counsel in October 2002, provided for a lesser payment of alimony pendente lite from the date of the execution of the Agreement and finalization of the divorce until the Petitioner completed a new home to be built for the Respondent. 2 '-"o<.b"""'~" M ,~ -'~" . ~-~ ~~d ~ I -,_. '1rf .J.,~ 9. The fact that the Respondent would continue to receive alimony after the entry of a Decree in Divorce, the Respondent has failed to execute the Agreement and has failed to promptly respond, permitting the divorce to be concluded. 10. The Respondent is delaying the conclusion of the divorce action for the financial benefit to her. 11. The Respondent is not utilizing the payment of the alimony pendente lite for the purposes for which it was entered. 12. Your Petitioner is being held as an economic hostage as a result of the Respondent's failure to cooperate with her attorney and failure to reasonably pursue the finalization and conclusion of the divorce action. 3 '""'''--'"=","",''''''''-<l~' ..... """""'- '-"t;~~-, WHEREFORE, your Petitioner, Arnold Forbes, by his Attorney Diane M. Dils, respectfully prays your Honorable Court to terminate the alimony pendente lite immediately, and to Order a credit of the sum of $1,000.00 per month retroactive to October 15, 2002, pursuant to the terms of an agreed Marital Settlement Agreement which Respondent has refused to execute. Respectfully submitted, BY: iane M. Dils, Esquire 1017 North Front Street Harrisburg, PA 17102 (717) 232-9724 J.D. No. 71873 4 ,~-"""""""',."''''''''", '" ~- - . L - . - r ...........'"",'~ ~"""11\11, Vi_"""jj\C;;,",_ . VERIFICA TION The undersigned, Diane M. Dils, Esquire, hereby verifies and states that: 1. She is the attorney for Arnold Forbes. 2. She is authorized to make this verification on Arnold Forbes' behalf. 3. This verification is made by counsel pursuant to Pa.R.C.P., Rule 1024(c). 4. The statements set forth in the foregoing Petition to Terminate Alimony Pendente Lite, are true and correct to the best of her knowledge, information, and belief. 5. She is aware that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to worn falsification to authorities. Date: April 2, 2003 """",~",,,,,~"~L.__ ,~"""" ~ 1-- , . , . .~~ ~- --~',~' "'>-'-.~'lW,rf'*~""t_i CERTIFICATE OF SERVICE I, Diane M. Dils, Esquire, hereby certify that a true and correct copy of the within Petition to Terminate has been served upon the following individual by first class, United States mail, postage prepaid, by depositing same at the post office in Harrisburg, Pennsylvania, on theca day of April 2003, addressed as follows: Maria P. Cognetti, Esquire 210 Grandview Avenue, Suite 102 Camp Hill, P A 17011 Respectfully submitted, BY: ffbtfif}L- lane M. Dils, Esquire 1017 North Front Street Harrisburg, PA 17102 (717) 232-9724 J.D. No. 71873 Date: April 2, 2003 ;~c:;til~.""j,jb::jHiIo1j,&"[;f<1 ~",;!~,:"",,,,,",,:?i,,,,"Ptiilf'!&,,'li~,\b,;Mi<_;'1-:'''__'';__."'> '2"'.",,:';" "",-''':d';A'''-'''j''$iJ!lIW~~~~ (.' ~'\~ ,l .~-~ _''''_'' ~,"_~~ N """'~It:M~~~lltj~J,Ij;.-':- , n ,..>" ~0 ~-- " () ~ :""tti-( LDC--': ?5 !~~~-' ~C; .,;;;." r~ 2:~, -' 5s:P;? ;;:-- ...;j --' , ,.,-=~_. S:J ::> tv lilIt-'::::~t.l ~';i ! c:::-. c..) o -n ::-'{ fi'j;J1 -,') ';"'1 ~w :---/ -,';:" ::0 -< ~ "0 C:J I (..,) ...,~ :::t:: ,~'~'" ~""', ,'".._~~ , ~ , ~ " " - --...".. ~ -'-'1 ~ '~'''''''~if~!-;: , ARNOLD FORBES, PlaintiffIPetitioner/Ob ligor IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. NO. 200l-l506 CIVIL TERM CIVIL ACTION - DIVORCE DR NO. 31684 PACSES NO. 176104477 NINA FORBES, Defendant/RespondentlObligee ALIMONY PENDENTE LITE ORDER OF COURT AND NOW, this IO--r:/l day of April 2003, upon presentation and consideration of the within Petition to Terminate Alimony Pendente Lite, it is hereby ORDERED that a Hearing is scheduled on the ~ y-tl> day of':Zp#' /YJ/ty 2003, at $: 1/5 A-.M. in Courtroom #.5 of the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013, at which time all parties shall appear and be heard. The Honorable Edward E. Guido Distribution: ~aria P. Cognetti, Esquire, 210 Grandview Avenue, Ste. #102, Camp Hill, P A 170ll ".Diane M. Dils, Esquire, 1017 North Front Street, Harrisburg, PA 17102 .jt~~ 1') RKS OLJ-/{J-C8 i ~~-;':j~li:~~~!%dHiji<d,', j,!~~;,n'''<'l Li "r::",d1::jb';L~,,1."'>[,_,;.',"d. V:NV/\:-j).S0~N3d .:-.-,.' ," "'-;':"-!~2\1'\~n~) ~f~ "'~ ,,\ t1G n d ',j \rl c'n uCiiJ L,ij ",;.["c, "t'--cL'~'-'" ,;C, '-';'~'~"'_-!"",,,,jCU,,,~_IHl!IlilII.__~_wru~ii$~_~ijj~~'~ "~"" - -. . ~JlJr~ .......11Ii1M1 '11I1 , T _~~:;::,,,,,,,,,,,,,,".=,,,,,,",_"_,,,,,,"" "I I. ' "~. [, , - '-.=flih:'a" ARNOLD FORBES, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. NO.200l-l506 NINA FORBES, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDA V][T OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 15,2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S. S4904, relating to unsworn falsific Date: 5/d I /0.3 [u:" -"}';'I~~tll?{'~\lJli~fWii.y~'Ji..1iHIilW&1\l.i.!.;_1!-'jo;;j~~1,h;;;',J!'_'i,""'f:"<':~ _ ~~,," ~ H' _,o,-i,' :;("~~"_'-l--i:;+";-M:~i~~*"~""""'t&jJI[1!~~~Illll~~JiI~~iij;Jj! - .'- -~ >~ n " ".bJ 0 c C) ,-- t:""':' "i: ~ -00:; ,- fTlrT; X Z;X zc- j '");1\ ~~, P-") -,; j jt-, ,<C -';'''-'' --:' "-'1 ~O -~I :--7(") -0 i~m )>c: ~ ~ en 'Xi '< ,,,,,-,,,~._~,~ .' - - ~ I ~ . """-",~, -J ~~~- ;"""'-. , ARNOLD FORBES, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA VS. NO. 2001-1506 NINA FORBES, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree in Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S4904 relating to unsworn falsification to Date: S-/;)( /03 ~5~if\;l\Il$'iiliikl~i>tJ::MroYI:'i'~j'i0ill6 ~AL?{"N"';l!)T&ii1\i'W~".d,~", ,~i:,+ .-, .,. '-".; L. 'H'}l""""g"t'~~ll\jj._~~~ll~lll.flj~,i!ffi!~.:t_!il;Jlik: (") c: ;;;; "Ooj 52fT1 ::C. 2C" ~,,;.;; r:C"" ~ ' )>0 Zo )>c: Z ::;l , :" ~- 1IO itlln I c:) (.j :- '- ;;z: o -n "Ti r--::::= ,iTl F~i,;;;;y ~;j ~;~\ I j, ...-:;:'-n :~{~ ~-sm :.::; 5:J -< I f'O en ,'-;00.0 "','_.'0_ -,,,,-.,,,",,' ARNOLD FORBES, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA VS. NO. 2001-1506 NINA FORBES, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree in Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. g4904 relating to unsworn falsification to au Date: ..F /02 'l J(JJ , / i::'-~:--~~~i*~'1MNjjmfil'.!l!l.~~~~"*-iMi@.i{"-ii~ili.>i'l1i.jit"""~q,,,{;,"i~"-,k;i"ri:l!11~~ L~ciil* IXlOJl ,~ '<--.,. ~-j '~ - " ~ti.-llfm1"1--j ,,~,' -,~,.. T ',", "-'"", 0 0 0 c: W "I :c:- , -'Om ~ "-~-! rune '".... .-h;JJ Z:r z Z," ! -,~[[! CJ) ,t-: r'\..:, .,jL....- ~..<.:.. '_>,..L" ~c :.2 d~ ~c -0 ):>c: 3m :z: -, '1::--- =< m ~ ,," , ,~.~ ~--~;, ,";,1;;_'" ARNOLD FORBES, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA YS. NO. 2001-1506 NINA FORBES, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 15,2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the decree. I verifY that the statements made in this Affidavit are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S. g4904, relating to unsworn falsification to authorities. Date: S Ie? Y /60 , / ~~iildm~i1j'MmliJili~.<lliimM'fii>Wiiki"f!<I!ii~!~mi\!~~&~...jW<tt'~J<!,i~iii'J~i1:l;iiM--~ -I''''.i..':...'.:.;;....; n ',,,.;i" JJ1i_~~ --,.~i.riM~ .~=. ("} co 0 c: (,,) -r, s::: ':-.. ,-[ ""'Ow c:: L:J:1 nlrn Z Z':JJ "r'-- Zt; , -:-C1L.!:; ~..,c" 1'0 _cJ',o"' ,:)1- ~e -r:J -_:tU ------;, )>c:; ~S.... '5;;j Zc'i ,2_'1 ~C:: (J" Z ~ :;} (r> :Q ,,,,,",,-,,~' '- d "'~~t'- , ARNOLD FORBES, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. NO. 2001-1506 Civil Term NINA FORBES, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the Record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievably broken under Section (X) 3301(c) or ( ) 3301 (d) of the Divorce Code. (Check applicable section) 2. Date and manner of service of the Complaint in Divorce: By Affidavit of Acceptance of Service by Maria P. Cognetti, Esquire, on March 25, 2002, previously filed. 3. [Complete either Paragraph (a) or (b).] (a) Date of execution of Affidavit of Consent required by Section 3301(c) of the Divorce Code by Plaintiff, May 28, 2003; by Defendant, May 21, 2003. (b) Date of execution of Plaintiffs affidavit required by Section 3301 (d) of the Divorce Code: N/A; Date of service of Plaintiffs affidavit upon Defendant: N/ A. ~"'-=""'"-" , ".l 4. Date of service of Notice of Intent to Finalize under Section 3301(d) of the Divorce Code: N/ A; 5. Date of filing of Waiver of Notice of Intent to Finalize by Plaintiff: Simultaneously herewith; by Defendant: Simultaneously herewith. 6. Related Claims Pending: None BY: Diane M. Dils, Esquire 1017 North Front Street Harrisburg, P A 17102 (717) 232-9724 Attorney for (x) Plaintiff ( ) Defendant Dated: May 28, 2003 . ~!g,#jlillj@~<& 1i-W~"j4i~L1'~1k"'-"',',;li"(,i!j;w:"'i".r!i,J,tiG!i\:!il..":'rl-l1!,t~,,,1,,,!~,;,-,,,, ," , -j~",,~-.-,; ;"dU'<i:"i,g"1:I>~l"",~ I' ( ~1IIiIiI1i;_1Jil ~ ~, ,',~,_"__ _ ,.,,~.._~ ~,N~ :~~ ljdlll!llft,f~~ ",'-' 't-..;uL-liIIIlJIiU ..,,",< P"". rMmT>-'_:fk:_Bil "I 0 C) 0 c: {~.) "T);;S:: -1"1 '-- _,:;',1 mt:D fT1 ::::::: Z:x,; f:::;~ zr , 'Tjrn (f);:;" ('''.::' " -"1--' -<~;. ~5 ~C :PO " _-r. -'i Zci '-,,-.' (') :.?: 5>c: ...., iTl Z ''''-1 =< > cr, ::g ~~-'"'.~~~ ,~~ .~ , ~"~ I '_-'_~M""""" ~" ~"'."",,,-__ j , _~ -~" "4':"- ~ PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, is made this K~ay of May 2003, by and between: NINA A. WILLS, aka NINA FORBES, hereinafter referred to as Wife; --AND-- ARNOLD FORBES, hereinafter referred to as Husband; WITNESSETH: WHEREAS, Husband and Wife were lawfully married on February 14, 1999, in Camp Hill, Cumberland County, Pennsylvania; and WHEREAS, there are three children born of the marriage; namely Ariel Forbes, born 4/14/95, Natasha Forbes, born 8/30/96, and Sabrina Forbes, born 6/16/98. ,;; --~ r ,~, ~ lW I ~ ".". ~~"~"~'- - ~, ~,~ ,,~ ...... I~~~~~ -~ L; - """~..~ "'-'-" iL~_d,) ,. WHEREAS, diverse unhappy marital difficulties have arisen between the parties causing them to believe that their marriage is irretrievably broken, as a result of which they have separated and now live separate and apart from one another, the parties being estranged due to such marital difficulties with no reasonable expectation of reconciliation; and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including without limitation by specification: the settling of all matters between them relating to the ownership of real and personal property; and the settling of all matters relating to the custody and support of their minor children, and in general, the settling of any and all claims and possible claims by one against the other or against their respective estate, particularly those responsibilities and rights growing out of the marriage relationship. NOW THEREFORE, in consideration of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, the receipt of which is hereby acknowledged by each of the parties hereto, husband and wife, each intending to be legally bound, hereby covenant and agree !a~:I7's: JnitiaisWY 2 Initiais;!Jd- ,;I =~-~~,,~~ ~ , ~I = ~ -~'"" J "~ ~~Il~~ilIlIti!l"""'ll;.!tdl> ~ " " 1. SEPARATION. It shall be lawful for each party, at all times hereafter, to live separate and apart from the other, at such place or places as he or she may, from time to time, choose or deem fit. Each party shall be free from interference, authority or 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. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. Should a Decree, Judgment, or Order of separation or divorce be obtained by either of the parties in this or any other state, country or jurisdiction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be affected in any way by any such separation or divorce; and that nothing in any such Decree, Judgment, Order or further modification or revision thereof shall alter, amend or vary any term of this Agreement, whether or not either or both of the parties shall remarry, it being understood by and between the parties hereto, that this Agreement shall survive and shall not be merged into any Decree, Judgment, or Order of divorce InitialfJ{Jy' It is specifically agreed however, InitialSM or separation. 3 ~ '" ~ la3<._'lIJ61k< , ,_I" j~ "_ '," - ""......- ~ ~ - irtl".'il,.-"'~ " that a copy of this Agreement or the substance of the provisions thereof, may be incorporated by reference into any Order of divorce, Judgment, or Decree. This incorporation, however, shall not be regarded as a merger, it being the specific intent of the parties to permit this Agreement to survive any Judgment and be forever binding and conclusive upon the parties. 2. EFFECTIVE DATE. The effective date of this Agreement shall be the "date of execution" or "execution date", defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 3. MUTUAL RELEASES. Husband and wife do hereby mutually remise, release, quit-claim or forever discharge the other and estate of such other, for all time to come, and for all purposes whatsoever, from any and all rights, title and interest, or claims in or against the estate of such other, or whatever nature and wherever situate, which he InitialS~ 4 Initials.:;1J ,- .. ---. , ".1'l.iI<t ~jil ~ ... or she now has or at any time hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements, or liabilities of such other or by way of dower or curtesy, of claims in the nature of dower or curtesy, or widow's or widower's rights, family exemption or similar allowance or under the intestate laws; or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary or all other rights or a surviving spouse to participate in a deceased spouse's estate, whether arising under the United States, or any other country; or any rights which either party may now have or at any time hereafter have for the past, present, or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is the intention of husband and wife to give to each other, by the execution of this Agreement, a full, complete and general release with respect to any and all property of any kind or nature, real, personal, or mixed, which the other now owns or m:y ~(fter acquire, except, and only except, all rights and agreements and Initial~ 5 Initialsft,d II> - ~ . ~~ -'-_t~~,- "'\ obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. 4. DISTRIBUTION DATE. The transfer of property, funds and/or documents provided for herein shall only take place on the "distribution date" which shall be defined as the date of execution of the Divorce Decree, unless otherwise specified herein. 5. MUTUAL CONSENT/ADVICE OF COUNSEL. Husband and wife acknowledge and understand the terms and conditions of this Agreement, and husband is represented by Diane M. Dils, Esquire, and wife is represented by Maria P. Cognetti, Esquire. Each party acknowledges that he or she has received or has been given an opportunity to receive independent advice from counsel of his or her selection and was fully informed as to his or her legal rights and obligations. Husband and wife acknowledge that they fully understand the facts as to their legal rights and obligations under this Agreement. Husband and wife aC~llS.e~e and accept that this Agreement is, under the circumstances, fair and Initi~ 6 Iml1alsL::f ..'. , " .~.L ~ J , ,; tIl..d ~" "-. 'i1t",,,,,%<b-, equitable and that it is being entered into freely and voluntarily, and that the execution of this Agreement is not the result of any collusion or improper or illegal agreement or agreements. 6. FINANCIAL DISCLOSURE. The parties confirm that each has relied on the substantial accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement. The parties acknowledge that there has been no formal discovery conducted in their pending divorce action and that neither party has filed an Inventory and Appraisement as required by Section 3505(b) ofthe Pennsylvania Divorce Code. Notwithstanding the foregoing, the rights of either party to pursue a claim for equitable distribution, pursuant to the Pennsylvania Divorce Code, of any interest owed by the other party in an asset of any nature at any time prior to the date of execution of this Agreement that was not disclosed to the other party or his or her counsel prior to the date of the within Agreement is expressly reserved. In the even~at either party, at any time hereafter, discovers such an undisclosed ,ru~4f' 7 Inill.lsM ~"~-. .' 1 ~~ J~ ~~ wlilillii~~"" .~ ~,~~~" "i",. asset, the parties shall have the right to petition the Court of Common Pleas of Cumberland County to make equitable distribution of said asset. The non-disclosing party shall be responsible for payment of counsel fees, costs, or expenses incurred by the other party in seeking equitable distribution of said asset. 7. DEBTS AND OBLIGATIONS. Husband represents and warrants to wife that since December 2001, he has not, 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 wife harmless from any and all claims or demands made against her by reason of such debts or obligations incurred by him since the date of said separation, except as otherwise set forth herein. Wife represents and warrants to husband that upon signing this Agreement, she will not contract or incur any debt or liability for which husband or his estate might be responsible and shall indemnify and save husband harmless from any and all claims or demands made against him by reason of such debts or obligations inc~~rer, except as otherwise set forth herein. InitiaVUY 8 InitialSM "~" 0' . , ~ p ~U_J~-_: ""1 A' iIU-~~,I, . 8. REAL ESTATE. Husband and wife hereby acknowledge that husband has built a new home for wife on 1 Yz acres of land situate on or near 50 Chestnut Hill Road, Dillsburg, York County, Pennsylvania. Husband hereby avers that the value of said home is in the approximate amount of $160,000.00 to $170,000.00. Husband and wife hereby agree that wife may occupy said home and shall be given access to said home upon execution of this Property Settlement Agreement and the necessary Consents for the divorce action to become finalized. Wife hereby agrees that said home shall not be sold without husband's written consent prior to the youngest child reaching the age of 18 years. Husband and wife hereby acknowledge that said restriction shall be placed in said Deed. Husband hereby agrees that said Deed shall be forwarded to the attorney for wife immediately upon a Decree in Divorce being entered. Wife, at that point, may record the Deed in the Recorder of Deeds Office of York County. Husband and wife hereby acknowledge that husband was the sole owner of real estate located at 417 South Lewisberry Road, Lewisberry, Pennsylvania, and that said real estate had been sold in August 2002. Wife hereby acknowledges that '0'4'1 9 Initials;L:::I ~-- ~"~...."~ >- " I ~J ' "~"liI"""'z;!l"),'_" . said real estate was owned by husband prior to marriage. The parties hereby acknowledge that, at that time, all arrearages due and owing to wife were paid. The parties hereby acknowledge that there is approximately 10 acres ofland located at 12 Mountain Road, Dillsburg, Pennsylvania, which are titled in the name of KATSCO, Inc., husband's corporation. The Deed to said property is not yet recorded. Husband previously agreed to build Wife's home on said real estate; however, husband has been denied approval by Carroll Township Authorities. Husband hereby states that prior to said property being approved for construction of homes and/or buildings, he will need to expend approximately $150,000.00 to $200,000.00 to prepare the land. Husband acknowledges that he is in the process of attempting to sell said real estate. Husband agrees that he will not sell said real estate to a partner, co-worker, or any other person, organization, corporation, etc., with whom he now has dealings, previously had dealing with, or intends to have dealings with in the future. Husband further agrees that if said real estate is developed to the point that residential homes may be built thereon within five (5) years after the sale of said real estate, and said development costs less than $150,000.00 to prepare the land, husband shall pay to wife the sum of $100,000.00 Initial~ 10 Initials .id~ ,-,.~,~",,~ -~ ~. ~,.""~~~ JlHL.~ " *1~~8- upon verification that the property has been approved for construction of homes. 9. PERSONAL PROPERTY. Except as set forth hereto, husband and wife have agreed that their personal property has been divided to the parties' mutual satisfaction and neither party will make any claims to the property possessed by the other, except as set forth hereto: None. 10. PENSION AND RETIREMENT. Husband and wife hereby acknowledge that neither party has a pension, retirement plan, IRA, 401(k), or any other employment related benefits. 11. ALIMONY PENDENTE LITE Husband and wife hereby acknowledge that currently there is an Order against husband for the payment of alimony pendente lite in the Court of Common Pleas of Cumberland County through the Cumberland County Domestic Relations Office, Docket No. 2001-1506, Civil Term, DR No. 31684, PACSES No. l761~~.zl--wherein husband is Court Ordered to pay to wife alimony pendente InitialsWY II ImlIalsjd "",~~.-.-.," ~ ; I "~-~ ~ ~~ -~, . t7al 94477, ';;herein husbttnfl is Cenwt Orden~d to pay t8 wife alimony peRaeRte l4:l. Husband and wife hereby acknowledge that upon payment to wife in the amount of $5,000.00, wife hereby agrees to terminate the alimony pendente lite Order and all arrearages due and owing thereunder. Husband hereby agrees to pay to wife the sum of said $5,000.00 upon execution of this Property Settlement Agreement and the necessary Consents for the divorce to become finalized. Husband further agrees that upon execution of the Property Settlement Agreement and the Consents by wife, notification shall be given to the Court of Common Pleas of Cumberland County, specifically, the Honorable Edward E. Guido, informing said Court that an Agreement has been reached and the Hearing scheduled for May 28, 2003, at 8:45 a.m. in Courtroom #5 of the Cumberland County Courthouse in connection with husband's Petition to Terminate Alimony Pendente Lite shall be cancelled and said Petition shall be withdrawn as a result of wife's agreement to notify the Cumberland County Domestic Relations Office to terminate the Order for alimony pendente lite and all arrearages. A copy of this Agreement being forwarded to the Domestic Relations Office of Cumberland County shall be sufficient for the Cumberland County Domestic Relations Office ,",~Iti 12 Initialstf;if ~~.~. ~ .....~" _t,t~ """,',L ~ '*~~ I > .~~ "' ~" ..i., ~'<.~~ "~ to terminate and waive all arrearages in connection with DR No. 31684, PACSES No. 176104477, being the docket number of the alimony pendente lite Order. 12. CHILD SUPPORT. The parties hereto acknowledge that there is currently a Child Support Order through the Cumberland County Domestic Relations Office, P ACSES No. ~ ~~OO. 357104230, DR No. 31439, wherein husband pays to wife the sum of $1,386.00 per month representing child support payments based on the parties' shared physical custody arrangement, which they are currently enjoying with their children. Husband and wife hereby acknowledge that husband shall pay to wife, directly through her attorney, the sum of $10,860.00 representing arrearages due and owing on said child support obligation at this time. Said payment of $10,860.00 shall be paid as follows: ~dq30.C>D (a) Sum of $1,430.00 shall be paid to wife's attorney simultaneously with the payment of $5,000.00 as set forth in Paragraph 11 above, upon receipt of the executed Property Settlement Agreement and Consents fI~,1 to finalize the divorce by wife. Said sum shall be held by the attorney Initia~l1J 13 Initials;f}:f 'ml~ijli~!I!!Si*;,,-- ","",~.._~". <~ ~<-'" - ~.......,.,.---"",> for husband and upon receipt of the executed Agreement and Consents; said sum shall be forwarded to the attorney for wife '5\Jr-r\ :\>-,'130,00 immediately. The 6!ilBllee of $5,-430.00 shall be paid to wife on or before Friday, May 30, 2003, with said payment being forwarded directly to wife's attorney. The parties hereto acknowledge that upon receipt of each payment, the Cumberland County Domestic Relations Office shall be notified by wife's attorney of said direct payments so that the appropriate credit is given to husband for the payment of child support by the Cumberland County Domestic Relations Office, (b) PACSES No. 357104230, docket number DR No. 31439. I\W Husband and wife hereby acknowledge their agreement that the sum ~ ~~(POO.OO f~/J/ of $2,380.00 per month shall not be decreased by husband, unless the V parties would mutually agree, or upon a substantial change in custody or circumstances. Husband hereby agrees that he will be solely responsible for 100% of all of the children's medical, dental, orthodontist, or psychological expenses. Husband and wife hereby acknowledge that husband will not be required to maintain health insurance on the children. InitialS~ Payments shall be made by husband directly to doctor, 14 Initial~ ,.'""~"""..."""= "~ - " ^ -" ~ ~ <"" ~~-~.. . I. '~~ ," .. ....-ho\t;"""""f"''''''''''-.'_ hospital, or any other person or entity furnishing said care. Within twenty days after receiving said bill by wife, wife shall transmit said bill to husband for payment. 13. LIFE INSURANCE. Husband hereby agrees that he shall acqmre and maintain a term life insurance policy on his life with a face value of not less than $300,000.00 for the benefit of the minor children. The children shall be listed as beneficiaries and wife shall be named the Trustee for the benefit of the children. Said term life insurance policy shall remain current and in full force and effect at least until the youngest child reaches age 18 years. Husband hereby acknowledges that he will provide verification of said term life insurance policy and copies of premium payments upon request of wife. Husband hereby acknowledges that he shall acquire said term life insurance policy within thirty (30) days of the signing of this Agreement. 14. WAIVEROF RIGHTS. The parties hereto fully understand their rights under and pursuant to the 15 February 12, 1998, Initial,4L Divorce Code, Initials ~' Act of 1980, No. 1980-26, as amended .'~"".,"k.--.;""..._,,_-._~6~ -' -- ._1 1. '""";'~"~L' "..~~....- =',,",,'IJlIK1;OIi><IU particularly the provisions for alimony pendente lite, spousal support, equitable distribution of marital property, attorneys fees, and expenses. Both parties agree that this Agreement shall conclusively provide for the distribution of property under the said law and the parties hereby waive, release and forever relinquish any further rights they may respectively have against the other for alimony, alimony pendente lite, spousal support, equitable distribution of marital property, attorneys fees, and expenses. 15. MUTUAL RELEASE OF CLAIMS. Except as otherwise stated in this Agreement, husband and wife each do hereby mutually remise, release, quitclaim and forever discharge the other, for all time to corne, and for all purposes whatsoever, of and from any and all rights, title and interests, or claims in or against the property (including income and gain from the property hereafter accruing) of the other or against the estate of each other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have; specifically including any rights which either party may have or at any time hereafter have for past, present, or future spousal support, or maintenance, alimony, alimony pendente lite, spousal lnitia]S~ ]6 support, equitable Initialsjd , """"""'" '. ~ ~< ~ ~ "' ' ~~-; distribution of marital property, attorneys fees, costs or expenses, whether arising as a result of the marital relation or otherwise. It is the intention of the husband and wife to give to each other by the execution of this Agreement, a full, complete, and general release with respect to any and all property of any kind or nature, real, personal, or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. 16. WAIVER OR MODIFICATION TO BE IN WRITING. A modification or waiver of any of the terms of this Agreement shall be effective only if in writing, signed by both parties, and executed with the same formality as this Agreement. No waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 17. MUTUAL COOPERATION. Each party shall, at any time and from time to time hereafter, take any and all st~~,1 d ecute, acknowledge and deliver to the other party, any an,d all future Initialtz4.~ r 17 Initialsfl;;( , ,.-<,.,,~~_~_ ~'..~,,,,,,,,-"'_~ .~~,l.~~~ ~~ ~- l~1W -~~ ....._".,'>,11_, instruments and/or documents that the other party may reasonably require for that purpose of giving full force and effect to the provisions ofthe Agreement. 18. AGREEMENT BINDING ON HEIRS. This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective legatees, devises, heirs, executors, administrators, successors, and assigns in the interest of the parties. 19. BREACH. If either party breaches any provision of this Agreement, the other party shall have the rights, at his or her election, to sue in law or in equity to enforce any rights and remedies which the party may have, and the party breaching this Agreement shall be responsible for payment of attorneys fees and all costs incurred by the other in enforcing his or her rights under this Agreement. 20. LAW OF PENNSYLVANIA APPLICABLE. This Agreement shall be construed in accordance with the laws of the COn~1th of Pennsylvania. InitialstzLj f 18 Initialf/4 ~."~~~.. ~ . j ." ~ .. ~iI' ~. "~ . ,~ -" _"""d",,",,'o';C,,"'_ . . 21. HEADINGS NOT PART OF AGREEMENT. Any headings preceding the text of the several paragraphs/provisions and sub-paragraphs hereof, are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. 22. DIVORCE. The parties hereto acknowledge that their marriage is irretrievably broken. The parties further agree to execute the necessary Affidavits of Consent and Waiver of Counseling, and Waiver of Notice ofIntent to Request Entry of Divorce Decree simultaneously with the execution of this Agreement. The parties further agree and acknowledge that this Property Settlement Agreement shall be incorporated into said Decree in Divorce; however, shall not merge therewith. Initial~ 19 InitialS) r:f ~,-.",~__,~...,.~ .~, L, '. . . - -. -1:.w_,;, IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. ~t?~ Witness / InitialS~ t" g~ jJ~oItn~~Es (SEAL) 20 Initiald ._'~ - "-~jl;!m!llim";c COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUlY\~p rbncL On this, the a J Public, the undersigned day of rn ~_, 2003, before me, a Notary officer, personal(J appeared NINA A. WILLS, AKA NINA FORBES, known to me or satisfactorily proven to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. i Notarial Seal M C . Ii ,_A.Sheriff,N$ryPubllc Y omrmss. on. ,'~io l.ebiiOOn i My Ccmmisl1Ion EJcpIIBio May 16, 2006 '-1 ~'''\I",. P8nnsyIvanIa I\SSOCIaIibn OfNolo!fes COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN On this, the /~'fL day of 4~ Public, the undersigned officer, personally appeared ARNOLD FORBES, known , 2003, before me, a Notary to me or satisfactorily proven to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have her set my hand and official seal. My commission Notary Public ~i!m_afJ.';J"l!i;'lfh'_(,::c,6ilL~~\J-ii~,;gJ#;jiJ!d2""-<'&i&i$'iiE1ilN.iE:Qi, ""~"X""j,,_'_l:i_'_~"_, ';'-',,';;i''':'''-'f''~',iJ;1~1~1- i(";"<-"'"~~'~!' "" .~ ~ , i , " ;- ~ .:' - ~ *~-k.Iiilm''i?':r~F~~~ '~.' "', ';.,."......'"" "~"",,-" ,-"-\' ';-.7(: "k "'{> jML:IiIi11iS:~ ~=~ <-'-""~--. , .' D j ~ (") C) 0 C C,) -n - ~g~,~-; '-.- .,-! c::: (+~-::n ~S:'; - I :f'~7~ I '-) _.~ ' ~f~ ~C) ~~J ~o -,-" -"-~ ~......-' , ~c.~:.. )-;--: -..{ -< 0"> :0 -< "'*'~..~ ~ - I .....er.,..i,Ia,"""'l. .~, .', , ARNOLD FORBES, Plaintiff IN THE COURT OF COMMONiPLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 2001-1506 NINA FORBES, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Please withdraw the Petition to Terminate Alimony Pendente Lite previously filed on behalf of the Plaintiff, Arnold Forbes, in the above-captioned divorce action. Respectfully submitted, Diane M. Dils, Esquire 1017 North Front Street Harrisburg, PA 17102 (717) 232-9724 LD. No. 71873 Dated: May 28, 2003 ~-~- " , . , ll!\-~ i"r"i . ,\, ", r CERTIFICATE OF SERVICE I, Diane M. Dils, Esquire, hereby certify that a true and correct copy of the within Praecipe has been served upon the following individual by first class, United States mail, postage prepaid, by depositing same at the post office in Harrisburg, Pennsylvania, on the 28th day of May 2003, addressed as follows: The Honorable Edward E. Guido Cumberland County Courthouse One Courthouse Square Carlisle, P A 17013 Maria P. Cognetti, Esquire 210 Grandview Avenue, Suite 102 Camp Hill, P A 17011 Respectfully submitted, BY: Diane M. Dils, Esquire 1017 North Front Street Harrisburg, PA 17102 (717) 232-9724 J.D. No. 71873 Date: May 28, 2003 .'" ' '. ~" " -"'''' " ~- ~ ,~~ ~#i;'- . In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION NINA A. WILLS ) Docket Number 01-1506 CIVIL Plaintiff ) VS. ) PACSES Case Number 176104477 ARNOLD FORBES ) Defendant ) Other State ID Number ORDER AND NOW, to wit, on this 12TH DAY OF JUNE, 2003 IT IS HEREBY ORDERED that the support order in this case be 0 Vacated or OSuspended or @Terminated without prejudice or 0 Terminated and Vacated, effective MAY 15, 2003 , due to: THE PARTIES' PROPERTY SETTLEMENT AGREEMENT OF MAY 15, 2003. THERE IS NO BALANCE DUE THE PLAINTIFF. DRO: RJ Shadday xc: plaintiff defendant Maria Cognetti, Esquire Diane Dils, Esquire BY THE COURT: ~'1~ Edgar B. Bayley JbDGE ~ .:,)# _/!>-O,? Service Type M Form OE-504 Worker ID 21005 i~_ml_~~!.i:r.l"i,;ij;'~i"",,#'~Ii;ri1~H:.ffif;MI~,j''tlM,TM:'-.t'' "i;'+"'-~-'o,,,.,,_,-,"d1H~~i'\'JG.j!~0i~~'mjJllWil~lllA!IIii!i!%f!j\Wtl!~IMl1lli'a~~"~W C~:.. .:1- ry (l- <,:r::p ~ "- ~"~.oo ~,.~'^ H ,~"' .h'", ., ~ .<. v~,- - .0'___' .. f 0 c:) 0 c::: '''' ? -0 ""U ~, ~= It] p.;~ .,-- 2'{ :~:!::. Zr'" .'.:::~,.; ;?);.- 0" " ,_:::: ~d ~ :::? ,$" C~: :}j 2: f~-_ " C) >- '..." c: (.,) n'l 2.: :J1 ~j -, -.( -_J ,:rJ -< f iIi!io; HI! ~'~.-~ - P-~~~_~t:i,n$P'""",,;,C . JUN 0 4 Z003 )f , ARNOLD FORBES, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. NO. 2001-1506 NINA FORBES, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Please withdraw the Petition to Terminate Alimony Pendente Lite previously filed on behalf of the Plaintiff, Arnold Forbes, in the above-captioned divorce action. Respectfully submitted, BY.~~Y DIane M. lIs, EsqUIre 10 17 North Front Street Harrisburg, PA 17102 (717) 232-9724 J.D. No. 71873 Dated: May 28, 2003 "W-,d1ofl.~~"~ "" .-- -~-~~ '." n . ~ 1lI'<iIif;'.:t,,iJ;o-c > CERTIFICATE OF SERVICE I, Diane M. Dils, Esquire, hereby certify that a true and correct copy of the within Praecipe has been served upon the following individual by first class, United States mail, postage prepaid, by depositing same at the post office in Harrisburg, Pennsylvania, on the 28th day of May 2003, addressed as follows: The Honorable Edward E. Guido Cumberland County Courthouse One Courthouse Square Carlisle, P A 17013 Maria P. Coguetti, Esquire 210 Grandview Avenue, Suite 102 Camp Hill, P A 17011 Respectfully submitted, BY~~ I Diane M. 'ils, squire 1017 North Front Street Harrisburg, P A 171 02 (717) 232-9724 J.D. No. 71873 Date: May 28, 2003 illll&@I~jh1;l0i8~M1."+)L~:ibL~,w;i;:{;'!';"_'!--'-o;:\i,:,"!:41rr"";m;~~tl!Ni;,!",,::*,.~,'j,,,,:~ 7_;(,~i'~"'k"-l~,-,,;.;:~,,;,,;,,',?j"',iM:::~~~FJl ~ ~ gUll 'IiIf~N~W~~lIiiffldl~''''''~'~-''': ",' - '~ijigjJlLIi~~"1 w;>"" -~ "~-""il:F I I , I I , i ! i ! i , I I I , i , !i I I I I , I i 0 Cl 0 ~ W ., S= -- urn ~- :::;:::: -I', n"lrn .- Z:J:J - ~:--:~ z'} I en -' co __~jO -<-' ~;1(~ < r-::'-' ~....~' .." -~"' "T! ~8 --,~ ,~~~ ~ 5>c: N Om Z w > ::.;! ::n (j\ -< , " ,i,~"",,",,""'" ,.,,",-, ~" <. .-. I h ~ '~'~-' I ARNOLD FORBES, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. NO. 2001-1506 Civil Term NINA FORBES, Defendant CIVIL ACTION - LAW IN DIVORCE ORDER OF COURT AND NOW, this 1I~ day of t:: 2003, upon presentation and consideration of the within Agreement, it is hereby ORDERED that the Agreement attached hereto, is incorporated herein and made an Order of this Court, said Agreement is dated May 15,2003. 1. Distribution: Maria P. Cognetti, Esquire, 210 Grandview Avenue, Suite 102, Camp Hill, PA 1707( . Diane M. Dils, Esquire, 1017 North Front Street, Harrisburg, PA 17102 ~ ~ q/.9,,0J , ~ttl!j~~;U~\',\i1N:,',ml'""'d~i!,t:t,,,jl",;L<i'ml''''"")));(tffi,;i,;;''JH.'~'i;,'10ii/- ,;t!"_-y.*'i:-;lJ..;;~;:,,,,*;.~illOOii~l!ilt ,- ~v ""'''-~,- ,~ ,-~,,- ~ - "','''-'-~''_. ,"" ^- --~ - ~- !lBIll6ll..IL....;,~AilIBliltl;.lr&-71~~~dl~!l;m-~'''~'"'''"' 'f- I!n'r "0 ~ I, ('." ACVi(j-'\!:"_i._ ,"', , , - - -:~7'i ;-;.l,-:.<i i,:"'U, dO ::Jvt:;1:ilj--G:r;U -~_. . ~- li!!!.lf;(~'~ J " .,...." I