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Home My WebLink About01-03293 - SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS-AT-LAW 26 W. High Street Carlisle, P A J, .'," " '. "~,~ ~ ,"^ r"', ,,; . '^ ,,' " - - ",' 'lG-';, 'J't'" ,;',-,;,',. '".-~. "i(;;. , ' DENISE M. DEW, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVil ACTION - lAW NO. 01- .];<93 Plaintiff vs. CIVil TERM WilLIAM H. DEW, Defendant IN DIVORCE NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: C r I J. Lindsay, Esquire 10 ~4693 26 West High Street Carlisle, PA 17013 (717) 243-6222 II -.i>. DENISE M. DEW, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 01- 3;Z 93 . CIVIL TERM Defendant : IN DIVORCE Plaintiff vs. WILLIAM H. DEW, COMPLAINT DENISE M. DEW, Plaintiff, by her attomeys, SAlOIS, SHUFF, FLOWER & LINDSAY, respectfully represents: 1. The Plaintiff is Denise M. Dew, who currently resides at P. O. Box 1542, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is William H. Dew, who currently resides at 404 Evergreen Road, New Cumberland, York County, Pennsylvania, where he has resided since 1996. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 30, 1997 at New Cumberland, Pennsylvania. 5. That there have been no prior actions of divorce or for annulment between SAlOIS the parties in this or in any other jurisdiction. SHUFF, FLOWER & LINDSAY 6. The Plaintiff avers that she/he is entitled to a divorce on the ground that the ATIORNEYSIAT'LAW 26 W. High Street Carlisle, P A marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code. II SAlOIS SHUFF, FLOWER & UNDSAY ATrORNEYS-AT-LAW 26 W. High Street Carlisle. PA ,'., ,,-,>~~ ~ 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. Date: 1/4./112"2 J UP/ II SAlOIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: ",'~ SAlOIS SHUFF, FLOWER & LINDSAY AlTORNEYS'AT'UW 26 W. High Street Carlisle, PA "- , ' ,', , , ' ",~', I' ''''~.''';~'~~'i'}f " c 1-' ~ -~'" "'i,-", -, -"', 1 "'c '~_' ,_ VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. ~1nJ.Q;./J} Denise M. Dew Date: 1Y1tut I R, /) 00 I II SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS-AT-LAW 26 W. High Street Carlisle. P A - ^ --~-',-'" '-, '- """~'~' r'" 'I "_ ..:, ' -, ~ ,:,,: i ',--.c ',",,~, ,;"';,c,-,,,,:.,.',;,,<'''!,k;;:';',,;,;>,< ,--'-->-':;",2;,',,--; ',0'" ','.-, ",',,~ ',"' , "~,~,:,i>'i, DENISE M. DEW : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 41-3293 CIVIL TERM Plaintiff V5. WILLIAM H. DEW, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under !'l3301 (c) of the Divorce Code was filed on May 30, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. ~ in f).uJ Denise M. Dew, Plaintiff Date: 1/2-d fJ'7 I I t ~~~~I~_4ti!~ji1~'iI;:~;i"NliJ;~m!l.~~~g.i:I.J:i;i._iaIlilI00li&i~ [iIt'1llD " ~ I II " II II (') CJ 0 C W -n ;r: ,- ~::;:! vl:Cl :<::llJ- mr'c Z , i .'""'" --;;;-",- " r';:::;' ....__.J, Z f" N ."::-i iil ~~~~ 0:> . ,. C) ~C) :> ;!~~ >C' 7' ~ - ---0 is 9i~G "l>c: z -,,; -' ~ -< c- <.~ ~~ ,t? .~ ~ ~~,~'~,L- ~: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DENISE M. DEW, Plaintiff CIVIL ACTION - LAW vs. NO. 01-3293 CIVIL TERM WILLIAM H. DEW, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 30, 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 of divorce after service of notice of intention to request entry of the decree. 4. My social security number is: 268-68-9128. I verifY that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ./I~(1~r- William H. Dew, efendant DATE: /-/1- 0.1' ~ilf~~~W~!illii'illi;'i'1iN.!ifH."'1i'!:>'~i __ '_~mH(ll'"'iit'M"t9t!h'h",t,(;'S",,:',j,:r,f',;':" "'id","'~b,_c,'<0,'f'l1'iilfj'li'<1i#iiij,,*,ii~1lm1lIlOll1iill</iijll*@\,",,",,-.~t.~~'''''I~'~''"!7''aI~!!i._ ~".a jj).N 2 1 2003 I ~~ "~A10~_~fl"'._'" MIL- u_. (") 0 0 c: W -T! S '- -< -oO:J "'" ~1~ p1 mrn :z: Z::r:i N --"en Z~: ."-'0 ~"". O:J ;.~ I '-:'10 !<cj :> ,-r" ""r' 3: ~~,~ 2: ~-' 5>2 ~ ,-' --, ~ 55 .r:- -< SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS-AT.LAW 26 W. High Street Carlisle. P A DENISE M. DEW : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. '1-3293 CIVIL TERM IN DIVORCE Plaintiff V5. WILLIAM H. DEW, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER !i3301Ccl OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. ~'m DI.lJ Denise M. Dew, Plaintiff Date: !/2{ /0" , , ;,"'~. _'L"'''''''~.bHlillWillliillNi#l!~m~~~~M-~~~__~1~;WtM~,_i!fi~$~,~''IIMIifillaililM [1 -," o C. 2" -ocr.~ rnt1"\ Z',-; "':;;C" Jt!_ -';.-' if>-. -<'.",,::,- <;20 ~;(J ~~CJ J?C "7 ~ ~~ "-' ...., ,- 'C'. ..,-,"" ~- \"J 0) ." iA , o -"1(\ :po :% B .' ~g -\b,'" -~JC "~),{l., __"..4, ._ I, ;~0 /,__\f\ 9, ),7 ~ - ,r;:- ,', . , ~- "-' ",",- , -- ,-,~V IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DENISE M. DEW, Plaintiff CIVIL ACTION - LAW vs. NO. 01-3293 CIVIL TERM WILLIAM H. DEW, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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 ofthe decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in the foregoing are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. DATE: //7-03 cillf~/c4d!u- William H. Dew ~~,tJ]4'1ffi'&,lfik4'lc~,,'iA,,;c',M; !"'J';Mc!,j!f,I'>'Jft;{j~~'~",,~,,>d:Bi~tf,;1""-,io,;','t,,",r&"'~'~'Hf"~l~1\~'i-;.11'8"~,,,..~iII!l~~IlIi!~~;~illJ./;~o"&1't~,t~!!illtr Ui,Hf -"~""o "~~ " ~ ~, ~, () 0 0 C W '-n s: , .-l '- i~ ""0 eo :.;:.;.:w mrn :;;e:; Z:T' N Z~ CO G0~ "_..:'iC) ::.(--?-. kCJ ".. ::::.-}\ ?fO :Jj: ()6 2m 'C\ ~ 0 5>c. .=-l Z - ~ ~ .r:- SAInIS SHUFF, FLOWER & LINDSAY ATIORNEYS.AT-LAW 26 W. High Street Carlisle, PA ~~. , ~~ " DENISE M. DEW, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 01- 3.)93- CIVIL TERM Defendant : IN DIVORCE Plaintiff vs. WILLIAM H. DEW, AND now, this CERTIFICATE OF SERVICE /~ dayof"", ~. ,2001, I, CAROL J. LINDSAY, Esquire, of the law firm of SAlOIS, SHUFF, FLOWER & LINDSAY, Attorneys, hereby certify that I served the Defendant, WilLIAM H. DEW, on June 4, 2001, with the Complaint in Divorce by Certified Mail, Restricted Deliver, Addressee Only, Return Receipt Requested, addressed to: William H. Dew 404 Evergreen Road New Cumberland, PA 17070 and proof thereof, the signed Return Receipt Card, is attached hereto. SAlOIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By / II SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS'AT-LAW 26 W. High Street Carlisle, P A .... .0 DENISE M. DEW, Plaintiff V5. WILLIAM H. DEW, Defendant ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01- IN DIVORCE CIVIL TERM PROOF OF SERVICE f. . bo'~pl';;t~"-i'f~~r{2;' a~~rirAI~~' ~~mpi'et~ ' 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 mail piece, or on the front if space permits. 1. Article Addressed to: \J..)\ \\\a..N'\ ~~ 4D>-\ ~ ~ ~ ~lJ.A'l\-~, ~fI... \1.0"10 ;) ~ c. Sig~~7 u X :td:<< m., L"""--- D. Is delivery address different from Item 1? If YES, enter delivery address below: 3. ~erv,Type l:WCertified Mail o Registered o Insured Mail o Agent D Add_ DYes D No o Express Mall o Return Receipt for Merchandise DC.D.D. 4. Restricted Delivery? (Extra Fee) ~ 2. Article Number (Copy,from service labeQ ~_1(~~~e' f!::C:- '"'''""An '11, Jllly 1999 Domestic Return Receipt . II ~N1_.oo",,- '_'" "-,""-~",,,-,,,--,..;;i1" "" ~,- ,c' ',' I"~ , , n",(JI- ..3.:Lf3 SEPARATION AND PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT made and entered into this J.Jlday of 12fk ~- , 2002, by and between WILLIAM H. DEW, of New Cumberland, Pennsylvania, party of the first part, hereinafter referred to as "Husband," and DENISE M. DEW, of Mechanicsburg, Pennsylvania, party of the second part, hereinafter referred to as "Wife." WITNESSETH: " ri; WHEREAS, the parties hereto are husband and wife, having been married on June jd, 1997 in New Cumberland, Pennsylvania; and WHEREAS, certain differences have arisen between the parties as a consequence of which they intend to live separate and apart from each other during the rest of their natural lives; and WHEREAS, the parties desire to confirm their separation and desire to enter into an agreement for the final settlement of their property and affairs; and WHEREAS, the parties intend to dissolve their marital status by means of a divorce pursuant to Section 330l(c) of the Divorce Code of Pennsylvania. NOW, THEREFORE, in consideration of the foregoing and in further consideration of the covenants and promises hereinafter mutually to be kept and performed by each party hereto, as well as for other good and valuable considerations, it is agreed as follows: 1 "',<, ,'\'.0. " ~ ,~,~ ~",'--'_" ~ " - 1__~ '; '.""- h--"".~ 1. SEPARATION. It shall be lawful for each party at all times hereafter to live separate and apart from the other party, at such place or places as he or she from time to time may choose or deem fit. 2. NONINTERFERENCE. Each party shall be free from interference, authority and control, direct or indirect, by the other in all respects as fully as if he or she were single and unmarried. Each may, for his or her separate use or benefit, conduct, carry on and engage in any business, occupation, profession or employment which to him or her may seem advisable. Neither party shall molest, harass, disturb or malign the other or the family of said other, nor compel or attempt to compel the other to cohabit or dwell with him or her. 3. MUTUAL RELEASES. Husband relinquishes his inchoate intestate right in the estate of Wife, and Wife relinquishes her inchoate intestate right in the estate of Husband, and each of the parties hereto by these presents, for himself or herself, his or her heirs, executors, administrators or assigns, does remise, release, quitclaim, and forever discharge the other party hereto, his or her heirs, executors, administrators or assigns, or any of them, of and from any and all claims, demands, damages, actions, causes of actions, or suits at law or in equity, of whatsoever kind or nature, for or because of any matter or thing done, omitted, or suffered to be done by said party prior to and including the date hereof; except that his release shall in no way exonerate or discharge either party hereto from the obligations and promises made and imposed by reason of this Agreement, and 2 ,."", ~~ . . ....~" ~........,~~ '-"''''~ shall in no way affect any cause of action in absolute divorce which either party may have against the other party. 4. MARITAL PROPERTY. The parties hereto acknowledge and agree that they acquired various assets and debts during their marriage, whether the same were held jointly or individually by the parties hereto, including but not necessarily limited to: (a) Wife's 1997 Jeep Cherokee, titled in names of both Husband and Wife, having a value of approximately $8,762.00 at the time of separation and encumbered by a loan of $4,657.10 at Allfirst Bank, account number 0000158331; (b) A joint checking account at Allfirst Bank, account number 0088232180, having a value of $4,064.00 at the time of separation; (c) Husband's savings account at Belco Federal Credit Union, having a value of $20, 193.48 at the time of separation; (d) Husband's checking account at Belco Federal Credit Union, having a value of$15,000.00 at the time of separation; (e) Wife's account at Members 1st Federal Credit Union, the marital component of which had a value of$1,198.70 at the time of separation. 3 _,.ri "" ~ > , ~ (f) Wife's savings bonds received from Rite Aid Corporation, having a value of $30.08 at the time of separation; (g) The parties' pet dog, obtained during the marriage, having a monetary value of approximately $350.00; (h) Wife's 40 1 (k) retirement fund with Power Packaging, Inc., having a value of$397.06 at the time of separation. (In addition, Wife had a 40 I (k) retirement plan with Prudential Investments, obtained through Rite Aid Corporation, which declined in value by $2,501.84 during the marriage.); (i) Wife's Individual Retirement Account (IRA) with Allfirst Bank, having a value of$3,711.80 at the time of separation; G) Husband's 401(k) Quaker Oats Retirement Plan for Hourly Employees, which had a total value of $104,742.12 as of March 31, 2001; (k) Household goods, contents, furniture and furnishings located in the marital home; (I) Husband's and Wife's personal effects and possessions; (m) Marital debts incurred by Wife, which include her First USA Bank, N.A., account number 4417121027552697 in the amount of $4,801.95, her Capital One account number 4121741410442854 in the amount of $1,115.99, and her Kohl's account number 029-2522-463 in the amount of$5IO.15. In addition, Wife brought into the marriage a debt 4 ~ .~ ,- j - ",-=,G';:;i " with Beneficial Finance Company, account number 3 711714-1 0- 500535-5, the balance of which was $5,557.73 at the time of separation; (n) Marital debts incurred by Husband, which include a loan from his Quaker Oats 40l(k) Retirement Plan for Hourly Employees in the amount of $35,000.00, his Shell Master Card account in the amount of $4,899.79, a joint Capital One account in the amount of$1,387.00 and an American Express account of $313 .00; (0) In addition to the above assets and debts, as itemized in paragraphs 4(a) through 4(n), above, the parties had certain other non-marital assets at the time of separation. These include Husband's 1994 Jeep Wrangler, which had a value of approximately $6,137. 5. DISTRIBUTION OF MARITAL PROPERTY. The parties hereto covenant and agree that the assets described in Paragraph 4, above, have been or are hereby being divided and distributed between them as follows: (a) Husband relinquishes and disclaims any and al ownershiP'~)lJe ~and interest in Wife's 1997 Jeep Cherokee, and fe agrees that W\~~ d sliall become and remain the sole and separate owner of same. Wife agrees to take responsibility for payment of all expenses and all debt in regard to said vehicle. Husband will execute a Power of Attorney on the same day as the date of this Agreement providing to Wife authority to transfer the 1997 Jeep Cherokee in her name only 5 ,',~~ ~ ^" "b L" ,,,,,,,,,-," "~, when she receives the title from the lender. Wife shall pay all costs related to transfer of the title; (b) Husband has received $1,701.00 and Wife has received $2,363.00 from the joint checking account at Allfirst Bank, account number 0088232180. Wife relinquishes and disclaims any and all ownership, right, title and interest to the monies received by Husband. Husband relinquishes and disclaims any and all ownership, right, title and interest to the monies received by Wife. (c) Wife relinquishes and disclaims any and all ownership, right, title and interest to Husband's savings account at Belco Federal Credit Union at the time of separation, and Wife agrees that Husband shall be and remain the sole and separate owner of same; (d) Wife relinquishes and disclaims any and all ownership, right, title and interest to Husband's checking account at Belco Federal Credit Union at the time of separation, and Wife agrees that Husband shall be and remain the sole and separate owner of same; (e) Husband relinquishes and disclaims any and all ownership, right, title and interest to Wife's marital and non-marital accounts at Members 1st Federal Credit Union at the time of separation, and Husband agrees that Wife shall be and remain the sole and separate owner of same; (1) Husband relinquishes and disclaims any and all ownership, right, title and interest to Wife's savings bonds received from Rite Aid 6 .'~~ " 0'" ""J Corporation, and Husband agrees that Wife shall be and remain the sole and separate owner of same; (g) Husband relinquishes and disclaims any and all ownership, right, title and interest to the parties' dog, known as Charlotte Swank Dew, and Husband agrees that Wife shall be and remain the sole and separate owner/proprietor of same; (h) Husband relinquishes and disclaims any and all ownership, right, title and interest to Wife's 401(k) retirement funds with Power Packaging, Inc., and with Prudential Investments, and Husband agrees that Wife shall be and remain the sole and separate owner of same; (i) Husband relinquishes and disclaims any and all ownership, right, title and interest to Wife's Individual Retirement Account (IRA) with Allfirst Bank, and Husband agrees that Wife shall be and remain the sole and separate owner of same; G) Husband and Wife agree that, on the same day as the date that he signs this Agreement, Husband shall execute a Qualified Domestic Relations Order (QDRO) that shall enable Wife to rollover $30,000.00 from Husband's 40 I (k) Quaker Oats Retirement Plan for Hourly Employees into a account held by Wife. Husband agrees that Wife shall be and remain the sole and separate owner of same. Wife agrees that Husband shall be and remain the sole and separate owner of all funds remaining in said 401(k) plan. In the event that the said rollover of $30,000.00 is 7 -0' . t ~' ,"" not accomplished by the QDRO Plan Administrator within forty (40) days from the execution of said QDRO and its approval by the Cumberland County Court of Common Pleas, husband shall immediately provide $30,000.00 in cash to wife. (k) Household goods, contents, furniture and furnishings that were located in the marital home have been divided by the parties to the mutual satisfaction of the parties. Among the items in the possession of Wife are: her bed, all plates, cups, table and chairs, china cabinet and contents, I of 2 night stands and a dresser, aforementioned purchased by Wife prior to marriage, and a washer/dryer, a power lawn mower, a TV and stand, two VCR's, silverware, pots and pans, a deep freezer and partial contents, a chair received from her aunt and uncle, a comer curio cabinet, a desk, desk top computer, digital camera, canned goods, a porch table with matching chairs received from her grandparents, and a small window air conditioner. Among the items in the possession of Husband are: his bed and a dresser purchased by husband prior to marriage, two TV's and two stands, canned goods, pots and pans, new laptop computer, printer, small kitchen appliances, small kitchen china cabinet, a VCR, a 5-disc CD player, home theater system, grill, wooden porch swing, porch lounge chairs, tools (electric, hand tools, power tools, and table saw), refrigerator/freezer and contents, stove, large sectional couch, two single beds, a small dresser, all collectible 8 ,.'. , ~'"' =,..,. NASCAR memorabilia, two hand-held scanners with headphones, one large window air conditioner, and the other night stand purchased by Wife prior to marriage. Husband relinquishes and disclaims any and all ownership, right, title and interest to items in the possession of Wife and agrees that Wife shall be and remain the sole and separate owner of same. Wife relinquishes and disclaims any and all ownership, right, title and interest to items in the possession of Husband and Wife and agrees that Husband shall be and remain the sole and separate owner of same; (I) Husband and Wife have divided their personal effects and possessions to their mutual satisfaction. At noon on the Saturday following the date of this Agreement, Wife's father will pick up at Husband's house,~rrt.. /JfD~ #.' ." IkJdMc\''''7} aULOj/"ol?"fa. t1f;~;il~OJ: personal affects of Wife still remaining thef(~, and Husband will have Hu'50V,:}tU4-S1 .^. ..~~~ them packed and ready to go. Husband relmqUlshes and disclaIms any m- ~~ vas i ~'/t;>0<z~!1 ! and all ownership, right, title and interest to personal effects and 5W~ h ~. d'z- i ~C'I-WvV. possessions in the possession of Wife and agrees that Wife shall be and remain the sole and separate owner of same. Wife relinquishes and disclaims any and all ownership, right, title and interest to personal effects and possessions in the possession of Husband and agrees that Husband shall be and remain the sole and separate owner of same; 9 . ~ "I ",. ,< ~ . ' (m) Husband and Wife agree that all debts incurred by Wife, including any and all brought into the marriage by Wife, shall be and remain the sole responsibility of Wife; (n) Husband and Wife agree that all debts incurred by Husband, including any and all brought into the marriage by Husband, shall be and remain the sole responsibility of Husband; (0) Husband and Wife agree that neither party shall make any claim in regard to non-marital property of the other party including non-marital property specified in paragraph 4(0), above. 6. EOUITABLE PROPERTY. This Agreement constitutes an equitable division of the parties' marital property. The parties have determined that the division of this property conforms with regard to the rights of each party. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets. 7. INCOME TAX RETURN. In the event that any federal income tax is owed for any years in which a joint federal income tax return was filed prior to the execution of this agreement, the parties hereby agree that each shall pay fifty percent (50%) of the amount owed. In the event that any federal income tax refund is due for any years in which a joint federal income tax return was filed prior to the execution of this agreement, the parties hereby agree that each shall be entitled to an amount equal to fifty percent (50%) of the total refund due. 10 ,~""- >-, , '. , 8. INDEMNIFICATION FOR PAST DEBTS. Except as otherwise provided in Paragraph 5, above, each of the parties hereto covenants and agrees to assume full responsibility for and to pay all debts and obligations of whatsoever kind or nature incurred individually by that party prior to the day and date of this Agreement, and each of the parties hereto hereby covenants and agrees to indemnify the other party and save him or her harmless from all liability or claim on account of said debts and obligations from and after the date hereof. 9. FUTURE OWNERSIDP OF PROPERTY. Each of the parties hereto may hereafter own and enjoy, independently of any claims or rights of the other, all items of personal and real property, tangible or intangible, hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively in all respects and for all purposes as though he or she were unmarried. 10. MUTUAL RELEASES. The parties acknowledge that under prevailing Pennsylvania law they each have certain possible fiscal rights, including but not limited to the following: spousal support, alimony pendente lite in the event of a divorce, permanent alimony subsequent to a divorce, recovery of counsel fees, costs and expenses in the event of a divorce, and equitable distribution of marital property. It is the intention of the parties hereto that all of the foregoing rights and remedies, with the exception of those otherwise provided in this Agreement, are hereby waived and forever released and that this Agreement shall have the effect ofa final Order of Court relieving each party of the obligation to the other for any and all of the foregoing possible rights and remedies. The parties have effected 11 w"',d~""-" " ~~ ~~ " . ~~':. : , ' , " an equitable distribution of their marital property and neither will seek further distribution by any action at law or in equity. 11. EFFECT OF DIVORCE DECREE. The parties covenant and agree that unless otherwise specifically provided herein, 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. 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 be incorporated in but shall not be merged into a decree, judgment, or order of divorce or separation. It is specifically agreed, however, that a copy of this Agreement or the substance of the provisions thereof shall be incorporated by reference into any 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 to forever binding and conclusive upon the parties. 12. INDEMNIFICATION FOR FUTURE DEBTS. Each ofthe parties hereby covenants and agrees with the other party not to make, incur or attempt to make or incur any debt or obligation for or on behalf of the other party hereto, or for which 12 ,,-.00.ilI - L...' ~ . ~;:. , " . .. the other party may be held liable, from and after the date hereof, and each of the parties hereto hereby covenants and agrees to indemnify the other party and save him or her hannless from all liability or claim on account of said debt or obligations from and after the date hereof. 13. TERMINATION OF PRIOR ORDER OF COURT. At the time of execution of this agreement, Affidavits of Consent, Waivers of Notice, and a Qualified Domestic Relations Order for the purposes of transferring funds from the Husband's Quaker 401 (k) Plan for Hourly Employees, Wife agrees to execute a joint motion by the parties or to concur in a motion by Husband requesting termination ofthe Order of Court of the Honorable J. Wesley Oler, Jr., dated April 15,2002, and all prior orders that provide injunctive relief in regard to this case. ,./11 ~~~Mw Further, the Wife agrees not to disclose to the court or to any. any violation or violations of said orders of court that occurred or may have occurred so long as husband provides for the transfer of funds as provided in paragraph 50), above. In the event that this provision is violated, Wife shall reimburse Husband for all legal fees related to Husband's defense and any fines or penalties imposed by the Court. 14. WAIVER OF ALIMONY. SPOUSAL SUPPORT, ALIMONY PENDENTE LITE. The parties acknowledge that each has income and assets satisfactory to meet his or her own reasonable needs. Each party waives any claim he or she may have against the other for alimony, spousal support or alimony pendente lite. Upon the execution and delivery of this Agr~ement, along with a Consent to the divorce by husband and an executed Power of Attorney empowering wife to 13 -"~ "~ '> . " ,l.. " '~" . ., ..; , ,. -, transfer title to the said 1997 Jeep Vin #IJ4FJ27S7VL563640, husband shall be relieved of any and all further obligation to provide support to wife. To that end, wife shall execute a letter or an agreement, at the time of execution of this Agreement, that shall direct the Domestic Relations Office to immediately discontinue its collection of support in behalf of wife, ift6ltlamg ~'aR"l!af'&gilE ~~? thtit HiaY 3bll be uwed by hu~bi:llld. Further, domestic relations shall be directed to return any funds that it has in its possession for wife, and wife agrees to return to husband any payments that she may receive as support subsequent to the -.) 4t/J execution of this Agreement, ~ ~ p~ #na.yy:?~7P-5:" 15. OTHER DOCUMENTS. Each of the parties hereto shall, from time to time, at the request of the other party, through counsel, execute, acknowledge and deliver unto said other party any and all further documents or instruments which may be reasonably required to give full force and effect to the terms and provisions of this Agreement. 16. DIVORCE. This Agreement shall not be construed to affect or bar the right of either Husband or Wife to an absolute divorce on legal and truthful grounds as they now exist or may hereafter arise. This Agreement is not intended to condone and shall not be deemed to be a condonation on the part of either party hereto of any act or acts on the part ofthe other party which have occurred prior to or which may occur subsequent to the date hereof. It is understood, however, that Wife will pursue an action in divorce pursuant to Section 3301(c) of the Divorce Code of Pennsylvania, on the grounds that the marriage is irretrievably broken, and that 14 "~ '.~" , 1, I , ,. . both parties agree to execute and file the appropriate affidavits of consent necessary to complete said action in divorce on the basis of mutual consent. Failure to file Husband's affidavit of consent and waiver of notice within five (5) days of its execution and receipt by Wife's attorney, or withdrawal of this affidavit shall render this agreement null and void. 17. SEVERABILITY. The waiver of any term, condition, clause or provision ofthis Agreement shall in no way be deemed or considered a waiver of any other term, condition, clause or provision of this Agreement, and if any provision of this Agreement is held to be invalid or unenforceable by a court of competent jurisdiction, all other provisions shall nevertheless continue to be in full force and effect. 18. BREACH OF AGREEMENT. In the event that either party breaches any provision of this Agreement, he or she shall be responsible for any and all costs incurred to enforce the Agreement, including but not limited to, court costs and counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election, to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. 19 . LAW OF PENNSYLVANIA APPLICABLE. Both parties covenant and agree that they have had ample and sufficient time to carefully and fully review the terms and provisions of this Agreement and to seek and obtain the advice and counsel of an attorney with respect to the same. Wife has engaged the services of Carol J. Lindsay, Esquire, and Husband has engaged the services ofG. Patrick 15 ,'. .=-~~ , ~.."'-" .' '" 'I' 'L . . I . . I ~ , O'Connor, Esquire, and each party has carefully reviewed the terms and conditions of this Agreement with his or her respective counsel. Both parties covenant and agree that they fully understand the facts upon which this Agreement is premised and based, that they believe this Agreement to be fair and equitable, that said Agreement is being entered into freely and voluntarily by each of them, and that the execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. 20. INTEGRATION. This Agreement constitutes the entire understanding between the parties and supersedes any and all prior agreements and negotiations between them. Both parties further agree that there are no covenants, conditions, representations or agreements, oral or written, of any nature whatsoever, other than those contained herein. 21. AGREEMENT BINDING UPON HEIRS. This Agreement shall be binding upon the parties hereto and their respective heirs, executors, administrators and asSignS. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have hereunto set their hands and seals the day and year first above written. 16 ~H . , / . i WITNESSETH: . ~(!~~~/l2f(SEAL) / William H. Dew J ~7rJiku- Denise M. Dew (SEAL) 17 . . I'" t ~~ " -- ~..l .u,i" ' ,"'_.~~~ ""' ~ ~ ~ -.~ - ' "M . . , . . l' ) "- . . COMMONWEALTH OF PENNSYLVANIA) : SS. COUNTY OF CUMBERLAND ) On this, the -1 5 .p, day ofCY c::k7>'L3 <<<< , 2002, before me, a Notary Public in and for the state and county aforesaid, the undersigned officer, personally appeared WILLIAM H. DEW, known to me (or satisfactorily proven) to be the person described in the foregoing instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. NOTARIAL SEAL WIlliAM L. GRUBB, NolIry Public Lower Allen Twp., Cumbel1and County My Commission Expires Aug. 13, 2005 G. )jl~ ,e bJi Notary Public (SEAL) COMMONWEALTH OF PENNSYLVANIA) : SS. COUNTY OF CUMBERLAND ) On this, the day of , 2002, before me, a Notary Public in and for the state and county aforesaid, the undersigned officer, personally appeared DENISE M. DEW, known to me (or satisfactorily proven) to be the person described in the foregoing instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. (SEAL) Notary Public "~ SAIDIS 1iUFF, FLOWER .. LINDSAY ATI'ORNEYsIAN..\1V a6 W.UIgh ~ t1rlisl., PA ~, Denise M. Dew, Plaintiff v. William H. Dew. Defendant . -" "0'- . aciii-:< . In the Court of Common Pleas Cumberland County, Pennsylvania Civil Action - Law No. 21-3293 In Divorce ADDENDUM l'O MARITAL SETTI.EMEN1' AGREEMENT The parties hereto agree to amend their Separation and Property Settlement Agreement of November II, 2002 in the following regard: 1. With regard to Paragrllph 5 (I) of tile Agreement Husband avers that he has no copies of videotape of Wife referenced in Paragraph 5 (I). In the event that Husband discovers such videotape, he win immediately destroy it. And in any ease, Husband will not pl1blish nor cause to be published any of the contents of said videotape. In tbe event that Husband publishes or causes to be published in any media any portion of such videotape, he will pay the Wife five thousand Ilnd 00/100 ($5,000.00) dollars of liquidated damages for a breach of her privacy. '" Wl~~kt6v ~~ J..~JYll,/)~'m /:Jeur- Denise M. Dew /~;;y:J.--o~ '-/(p/FA'## L William H. Dew ~~!~~Aii~'''~'i!.l'<C;;itA",AI'';l'"1h'''['lifi~ill;j!Hii'''1'''C:'',c'''M,~A,=",,'f <;;:"<,- '1~ I!lll. ~,_,~_ - ~ ,~,,,' ',",",' ",'''~,~,,' """, ,,,,,,."'c,"~,,,, '<"''''.1 ,-0'."'. ,_ ,~ " " ~ 1\~";,);,,,'""f!i,,'[jM~':l'/,;1'4-r,~i'MM~ ~<';'''~lli1tBl-''ll!a_:liIliiii~~'~''~~''''J ~ "'~ ~~ - ~,. ~,,_, ~r o C- o? I;~; ~. i~ C~ ?i :....) .;:-- "!ft, ,,-~, "',", C,..j '-'- c) ~; ,~ ,,; ,'33:, ~r., ~jl~ ~ ::0 -< . ~ l.." L~' ~'" , " ',~ ~j;" PG//L5'c .#! - ?;::t;7f1./ /faIn fT;t;L V$. In the Court of Common Pleas of Cumberland County, Pennsylvania No. ([1;/- 3 J-~:3 , Civil. I-9 ttJjU../4-1# /I. PEw P~.;.g/1d d uT fJrPlk~ " i!e~e~tI1 #t-f ~kr.(5KY?.. ~ hblulj i IZ~ ~~4'J.$A1.1 /J14".'Y1"~ a.~ ~ To Prothonotary 19 M~U:f/ ~~ ./ .!) Attorney f?r. Plaintiff C;-.. i~/(VcIL () UlJpJ(j p.... ; "- *,J~4j-,,,,,~,,,",rt,) j:;J!i<~,i ~ --+, ,,~;. :i~L..,,;ltJa~ "':'--1__,<,(,,,,,;1 o!,-,-<"""",;'~,j ';IH!'h",,,~,b,,,W';'" ")"L' ".",";,~,.. ,4.,,-,r.Kk-,,"" .' rll E''J-c(10'ICE r"'. ",. --- ~ .;; i- - ,Ji- I'~.':. r:,'" ",." ... I ,'I,. ,,-:.; J'-,ir]f\!/""'flR "-"-"" ", Y . '-." Q2 APFlI5 AN 9: "" "v CUM" .CJ~Hu\,':D Gill N7Y PcNNSYL\lAf\iiA~ ' nJX~' ~~ lHJJ ,,',^, "",:'C,["~'J<l'!fj;AA;.:!<il<<.l,.,,,:M.<l!;,ll&llU!il.~",M,.,"~~~~{[,~liPJlI!-,1'>'~~H~,,~,l'jr] :'l~--' "'~\iiiMM;Sd!iIi,.M"iill.illlm.~,~i No. Tenn, 19 _ VS. PRAECIPE Filed 19 , Atty. ~ ":"'"1 _.~ '''~~, """ In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION DENISE M. DEW ) Docket Number 01-3293 CIVIL Plaintiff ) vs. ) PACSES Case Number 730104027 WILLIAM H. DEW ) Defendant ) Other State ID Number ORDER AND NOW, to wit, on this 28TH DAY OF JANUARY, 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 JANUARY 24, 2003 ,due to: THE PARTIES'S SEP1\RATION AND PROPERTY SETTLEMENT AGREEMENT OF OCTOBER 15, 2002 DRO: RJ Shadday xc: plaintiff defendant Carol Lindsay, Esquire G, Patrick O'Connor, Esquire BY THE COURT: ,"- Edward E. Guido JUDGE Service Type M Form OE-504 Worker ID 21005 :]i!I& t' ~~".. ~ ~ ~ '. .,,"~ '~" r ^' - I}?! I DENISE M. DEW, Plaintiffi'Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE WILLIAM H. DEW, DefendantiRespondent NO. 01-3293 CIVIL TERM IN DIVORCE DR# 31214 PacseS# 730104027 ORDER OF COURT AND NOW, this 21" day of November, 2001, upon consideration of the attached Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shaddav on Januarv 11. 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 1910.11 to (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail tu 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 11-27-01 to: < Petitioner Respondent Carol Lindsay, Esquire G. Patrick O'Conner, Esquire ~.'-. ,'-1 "'" ,ro"." N,_",,", ""' )..~I,. _, ""rere= "'"'~ 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 ASSOCIA nON 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 ~' " " " - '-",' 1'[" 2"1, j ,I ' ~ !'" ... ",' ',,,;" -..... Pi; I: 5 CUMBi:HiJ!:O c..:OUNIY PENNSYLVlINIA ~ I-;m -,->""-"'''-~ "---:;m"Tjllf.",, """'~ ~,~aJl'@,~~~11Wlh-.%~~l~~~~f~f;!!?W~" '''\1i';;, i"'''''~''~'~.!: "01,;+';1"';':"" ';-";f.';:ji:f:?Il\~~~:fJ>!'!""P';'F~'iHil","l;l"'~""'"""l-,~I'F'''f'I'71W~''.e.'iMiW'''-"1Iij"'' ,=" SAlOIS SHUFF, FLOWER & LINDSAY A'ITORNEYSIATlLAW 26 W. High Street Carlisle, PA UI" -;;. . ,', "_'J_ "_n '-_-i__'_,,_-_~-'- ~ -, 'W',~, "l~ YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 liBERTY AVENUE CARLISLE, PA 17013 TELEPHONE: (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. Ail arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. II . ~, -~ ,-. ~ '. . .,.,n,- .--,. -" "'J~":;"':' oj ~,. -';;'~~.;..;-' -. ',-.'~ hr.. ,-,'--.c_;',,::' ~.- ,~",.,-~~~, "~' ~ ''--'~"''''i:--, .. DENISE M. DEW Plaintiff/Petitioner vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION. LAW : NO. 2'f:3293. CIVIL TERM ;)00\- ~p : IN DIVORCE WILLIAM H. DEW, Defendant/Respondent PETITION FOR ALIMONY PENDENTE LITE Now comes Denise M. Dew, by and through her counsel, SAlOIS, SHUFF, FLOWER & LINDSAY, and petitions this Honorable Court as follows: 1. The parties hereto are husband and wife, having been joined in marriage on June 30, 1997. 2. The parties separated on or about April 25, 2001. 3. Petitioner is without the ability to earn income sufficient to meet her reasonable needs and to pay attorney's fees. WHEREFORE, Petitioner prays this Honorable Court to order alimony pendente lite in an amount equal to the Pennsylvania State Support Guidelines and reasonable attorney's fees. SAlOIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff SAlOIS SHUFF, FLOWER & LINDSAY By: .------ A'ITORNEYSIATlLAW 26 W. High Stree, Carlisle, PA II ,~ w. ~" .. --., ",,- :'l'J-i'; OJ. :,: Ci:~ C: ;"'1"'," .,- '1-"')\'''' ....l~,....:..., L..r',: ..)\ :L'~ ~) pr:j\l)\(~\('1 \Ibr,(:'" . , ~ ~ ~v L-/,\I\(l-\ ~, _~~ _ "V"fI_~1~""", ", ;S_",,~.~!':f;U,,~~<f~r~~~1ij' ,~~'!'r-,._,,~~~I~~~~,li!jm~~~_~1 J SAlOIS SHUFF, FLOWER & LINDSAY A'ITORNEYSIAT.LAW 26 W. High Stree' Carlisle, P A ~- ^^ - ~~" ,., '~-,,,,,;'-,'. - '. ",,' ,-~ ;','.,~"..,c."_' '-i-', -_:';"'"~''-<__': _ 0 "':;, <,,,;_.~:-,';.i-,,'U~~~i'<,,- ;_.., ""~::: DENISE M. DEW Plaintiff/Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 21-3293 CIVIL TERM vs. WILLIAM H. DEW, Defendant/Respondent : IN DIVORCE CERTIFICATE OF SERVICE AND now, this day of 2001, I, Carol J. Lindsay, Esquire, of the law firm of SAlOIS, SHUFF, FLOWER & LINDSAY, Attorneys, hereby certify that I served the within Petition for Alimony Pendente Lite this day by depositing same in the United States Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to: G. Patrick O'Connor, Esquire 3105 Old Gettysburg Road Camp Hill, PA 17011 SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: Carol J. Lindsay, Esquire I D# 44693 26 West High Street Carlisle, PA 17013 (717) 243-6222 II .\; \ =- '." . ~~ ,. ~ ~~ V"~"_~' _='''vw''_ .,'~_ . c.ft:;;/J :-:::::> 5.-:/ '\' ~ ~ ,~~ '..! U I I c:. r"l? ~,;' .- C..; l~' '~, ':,,:- (''''\j ~i- r;'V j 'N\-.> " _I".),-',~, I '" h~'i\\\SYLV'/-\!\il/\ <, .~. " .,.,..,.~" '~'_m~'.. .-:> ~iilpI\!~'ff~~IIW!mfNi\i~~'~!H~.~.JW'@~I~iitil'lIlJ~_~I.~ -,",,--, '-, ~ ~ "~'!i~ ""~j;;:""~-';"':"~':~,"l-- ..... 10 DR 31214 PACSES In 730104027 DENISE M. DEW, Plaintiff/Petitioner vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION CIVIL ACTION - LAW WILLIAM H. DEW Defendant/Respondent NO. 2001-3293 CIVIL TERM ORDER OF COURT AND NOW, this 24th day ofJanuary, 2002, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $2,238.10 and Respondent's monthly net income/earning capacity is $2,695.05, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $250.00 per month payable semi-monthly as follows; $91.50 for alimony pendente lite and $33.50 on arrears. First payment due in the amount of$125.00 on next pay date. Arrears set at $549.00 as ofJanuary 24,2002. The effective date of the order is November 7, 2001. Husband is to pay forty percent (40%) of any and all net bonus( es) directly to wife within five days upon receipt of said bonusa and he is to send verification to wife and to the Domestic Relations Office within the same five days. Husband is to report to the Domestic Relations Office any raises that may occur in March 2002 and thereafter. 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.g3703. 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: Denise M. Dew. 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: PA SCDU P.O. Box 69110 Harrisburg, PA 17106-9110 Payments must include the defendant's P ACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. - , "' "~""-; ,. '" 1 Unreimbursed medical expenses that exceed $250.00 annually are to be paid 0% by the respondent and 100% by petitioner. The petitioner is responsible to pay the first $250.00 annually in unreimbursed medical expenses. Petitioner to provide medical insurance coverage. Within thirty (30) days after the entry of this order, the Petitioner shall submit written proof that medical insurance coverage has been obtained or that application for coverage has been made. Proof of coverage shall consist, at a minimum, of: 1) the name of the health care coverage provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims should be made; 5) a description of any restrictions on usage, such as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms. This Order shall become final ten days after the mailing of the notice of the entry ofthe Order to the parties unless either party files a written demand with the Prothonotary for a hearing de novo before the Court. DRO: R 1 Shadday Mailed copies on 1-24-02 to: < BY THE COURT, Petitioner Respondent Carol Lindsay, Esquire G. Patrick O'Connor, Esquire 1. Edward E. Guido ~~'lti]~~~liilli'&l:OifHnIlii1M'If-"",,ibMl",l\;gw.im~~~~.l.i''';;IillJi!;.; llaa;.;i';E,i:""W!).,illf4<;;m>!ii!l1e>It~jJml~!iI;I.ilillloo~~lIlll!lll;I,1 '""'-->.~ c ~"de-Ii/alIiI!' c~s~ )~ ~.~.,- "'" ~ " ,~".,~--"-~.-", . j - ,- _1IIlWlIllr ..- ...... t 0 Cl 0 C N " S c..... -va; )0> IilfT; Z :D ZX: , Zc; N -'\~rn CO..:_ to ~~6 --< ..::- ~c 2r".., -0 25 :ri :;u: L~":: -:;>.() ~;d r:- i:5m ~ '0 ~ (J"l :0 -< -...... _-...-.~ - -. ,"~'.~ iJil!ll ."",,~"~,; h.:...;"l i51~",_w,"_.;, - .. ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT )4., tJf-3M3 (7rf//L State Commonwealth of Pennsvlvania ., Co.lCity/Dist. of CUMBERLAND t114t!t;fr; 730/0<;0"'#-7 Date of Order/Notice 01/25/02 btC. 30-/<! Court/Case Number (See Addendum for case summary) o Original Order/Notice o Amended Order/Notice o Terminate Order/Notice ) RE; DEW, WILLIAM H. ) Employee/Obligor's Name (last, First, Ml) ) ) ) ) ) ) ) 268-68-9128 Employee/Obligor's Social Security Number 7375100880 Employee/Obligor's Case Identifier (See Addendum for plaintiH names associated with cases on attachment) Custodial Parent's Name (last, First, Mil EmployerlWilhholder's Federal EIN Number QUAKER FOODS & BEVERAGES EmployerM'ithholder's Name 321 N CLARK ST EmployerlWithholder's Address CHICAGO IL 60610-4714 See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMA TION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By iaw, you are required 10 deduclthese amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 183.00 per month in current support $ 67.00 per month in past-due support Arrears 12 weeks or greater? @yes 0 no $ 0.00 per month in medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ 250,00 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: $ 57 69 per weekly pay period. $ 115.38 per biweekly pay period (every two weeks). $ 125.00 per semimonthly pay period (twice a month). $ 250.00 per monthly pay period. REMITTANCE INFORMA nON: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding, You are entitled to deduct a fee to defray the cost of withhoiding. 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 disposabie weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on pg. 2). If remitting by EFT/EDI, please cail Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P,O. Box 69112, Harrisburg, Pa 17106.9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED, DO NOT SEND CASH BY MAIL. BY THE COURT: CDt.<)JQII!]) t; - JU ,bt,C Form EN-028 Worker ID $IATT Date of Order: JAN 2 8 20n~ Service Type M Mill.. .......OMBNO.:0970-0154 ~ExPi~tiooD""'213t/OO , [t..~~~ ~. J '" ,. ~, - -."'~..."'~~ -, ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If checked you are required to provide a copy of this form to your employee. r. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the singie payment that is attributable to each employee/obligor. 3. * RLpolt;!.g diG PAyJatelDatc vf'Nitl.l,oIJ;"g. Yeti l..tI!tt lepel1: tile l->aydateJdare vf nitl.l,old;1l5 nile!. ~e:IIJ;!.g till. payluo:;"t. TLe l-'ayJateldatb vf vvitl,lloIJ;"5 is tile.. dab:, vII vvl,id, ctlllOU!.t na.\ n;ll,l,eld flolnll,<= elllployeo:;';, vvages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.' Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federai or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S ID: 9901100173 EMPLOYEE'S/OBLlGOR'S NAME: DEW, WILLIAM H. EMPLOYEE'S CASE IDENTIFIER: 7375100880 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 liabie for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.' Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.s.e. !l1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 10. 'NOTE: If you or your agent are selVed with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Requesting Agency: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at /7171 240-6248 or by Internet @ Page 2 of 2 Form EN-028 Worker ID $IATT SelVice Type M OMB No,: 0970.0154 Expiration Date: 12131!OO Ji ADDENDUM Summary of Cases on Attachment Defendant/Obligor: DEW, WILLIAM H. PACSES Case Number 730104027/3(;)..rLf Plaintiff Name DENISE M. DEW Docket Attachment Amount 01::J2""93CIVIL$ 250.00 Child(ren)'s Name(s): -~- . " ~ DOS Elli~~~~~~J~;~'~~';~;:~~i;~~';;~~;~li;~~~~il~i;~~:..ii...,./...... identified above in any health insurance coverage available through the employee's/obligor's employment. \ PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOS ....................................................'...,.............'.............".'...'..........'.".'....'.....,'.'.......,.....,.,...., ,', ,',.,', ,.,.,.,.....,.,..., ," ""',,,,,,,,,,,... """""'" ""....." "',, "" "" ""... ""... ........ ......... :',';':':';':','::','::','::';':','::':':':':-:','::'::',.::.'.::.:.:.:.::.'.::.::.'.::.'.::.':.'.::.'.::.',:,"""':.""':"::"::"":"":":"':'..':'.'."':.':.,.,,'.,.:'..:,.,,'..,::.... 15If~h;~k~d:;~~;;~;~q~i;~dt~~~;~II.the child(r~n) .. 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): DOS .E5I;~~;~~;~;;~~.~;~;~~:i;~~;;~~;~il;~~~~:I~i;~~;/.."....."...".".....,.. identified above in any health insurance coverage avaliable through the employee's/obligor's employment. Service Type M - ~~ "l ~.1:l1!\m"iifu"j", ~ '" ~O" ~ PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOS ..Bli~~~~~:~:;~~,.;;~;~;~i;~~;~~~;~ri.;~~~~;;:i;~~:.)..... identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Chiid(ren)'s Name(s): DOS D If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOS D If checked, you are required to enroll the child{ren) identified above in any health insurance coverage available through the employee'sfobligor's employment. Addendum Form EN-028 Worker 10 $IATT OMB No.: 0970-0154 Expiration Date: 12131/00 . ,:~i:Ii~ir,t.m:~.i!1&$-j~,t'i"-'i:.:; 1'%"oE;j;b.:t."C;;I~,.;i2--'-';:I'-aH~.J-z,~M"~ii,lI-~r,;~""'~<,,, ,""""",~,'~"""f~i>&..""f.-,.,"U"';t0i",,~~iliiIii_Jlt~iiiliiYl;I'~!1i~~-..~~~"",~~"""'iSl'l! ".<". ,"~,,,.,,~. ~ ~. "'" ,. '" ~=" M, ~ ~ .. - ,~ () ~ ~~]' r:~<: ~::c) C~ ZI...i )>:(~ C ~ =< I~~ 10, " " o r'0 (- :'l;m '- .~ ,j '1 N '.0 -,;:,,;-" ~~ (:;-~:. '__l.' C2/" ~"-I J'> ~:O --< -0 =< c- ::;:, (]) - ...~""- ~, -- -.. ~-"-,---" - J..I ,'" "ct-' .!lM::~t~, --. .,,, ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT ~ ;1.001- ~d-e;3 (1fj//L I'm9ES 7~olt;tf{);;-7 Date of Order/Notice 09/03/02 "Dte.. ~ >/'1 Court/Case Number (See Addendum for case summary) o Original Order/Notice o Amended Order/Notice o Terminate Order/Notice State Commonwealth of pennsylvania Co./City/Dist. of CUMBERLAND ) RE: DEW, WILLIAM H. ) Employee/Obligor's Name (Last, First, MI) ) 268-68-9128 ) Employee/Obligor's Social Security Number ) 7375100880 ) Employee/Obligor's Case Identifier ) (See Addendum for plaintiff names associated with cases on attachment) ) Custodial Parent's Name (Last, First, MI) ) EmployerNvithholder's Federal EIN Number QUAKER FOODS & BEVERAGES EmployerlWithholder's Name 321 N CLARK ST EmployerMlithholder's Address CHICAGO IL 60610-4714 See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 183.00 per month,in current support $ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes @ no $ . 0.00 per month in medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ 183.00 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: $ 42.23 per weekly pay period. $ 84.46 per biweekly pay period (every two weeks). $ 91.50 per semimonthly pay period (twice a month). $ 183.00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding,-the fOllowing information is needed (See #9 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCOU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 iN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. SEP 4 2002 BY THE COURT: C :2 ~bwM~ ;=::f~ J1.Jl:J6.l: Form EN-028 Worker ID $II\.TT Date of Order: Service Type M (!)J!.I G:>. Jk("~ - ". ~~" - ".~ .~ ",",a. ~"-ili -.' .L~,; -:~~ .~- '.rl -"}jli2il.!!~leiW' -"'. . ... ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If checked you are required to provide a copy of this form to your employee. f. Priority: Withhoiding under this Order/Notice has priority over any other legai process under State iaw against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3. * Repoltillg the laydcrtefDate orW;tl,l,oldil,g. '/ou nlust lepolt tile paydatefdate of vvitlll,old;1I5 vvheh sel,dil,g the payllle:lll. The pa,datefdole of "itl,l,oldi',g is d" dote 0" "I,id, ",MUlot "M "ithJ.dd hOI" II" elnplo,~e's "ages. You must comply with the law of the state of the employee's/obiigor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.' Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhoid Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of empioyee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy ofthis Order/Notice to the Agency identified below. WITHHOLDER'S ID: 9901100173 EMPLOYEE'S/OBLlGOR'S NAME: DEW , WILLIAM H. EMPLOYEE'S CASE IDENTIFIER: 7375100880 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may berequired 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 accumuiated 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 iaw of the State in which he or she is eniployeq governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obiigor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.' Withholding Limits: You may not withhoid more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.s.e. 91673 (b)l: or 2) the amounts allowed by the State ofthe employee's/obligor's principal place of employment. The Federai limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 10. 'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Requesti ng Agency: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATIACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by Internet @ Page 2 of 2 Form EN-028 Worker ID $IATT Service Type M OMS No.: 0970-0154 Expiration Date: 12/31/00 - ~~~ " k~. - I" '^ ~" . .~I.'@;: .. ADDENDUM Summary of Cases on Attachment Defendant/Obligor: DEW, WILLIAM H. PACSES Case Number 730104027/3/'>1 'I Plaintiff Name DENISE M. DEW Docket Attachment Amount 01-3293 CIVIL $ 183.00 Child(ren)'s Name(s): PACSES Case Number Plaintiff Name DOB Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB dl~~~~~~~:~~~a;~r~~~i;~~;~~nr~II;~~C~ il~;r:~) ,... .i identified above in any health insurance coverage available through the employee's/obligor's employment. b;;.~~~~~~~.~'.~~'~. ~;~;;~~i;:~:~:~r~I:;~:~~:I~;;:~)<'. i..... ,. identified abov'e in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB D If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. D If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ..bl;~~~~~:~:..~~~~;~;:~~i;~ ;~:~;;II;~:~hil~(ren)<. ' identifjed above in any health insurance coverage available through the employee's/obligor's employment. D If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. Addendum Form EN-028 Worker ID $IATT Service Type M OMB No.: 0970-0154 Expiration Date: 12/31/00 ~~j~.'k1':"'''';;B:,'I,"~;g;l*,j!-i',\il''''-<!li;#l!'i4ijf-4;Jimt_,,"-i:~%.",(',~"-&)'>J'''''~;i",.thJ,;,~,ill:''i,"-,"Alfllij'I,--';\,liMiii;li,,~1ilI~~~!l:iM <~ )~ ~.~~~~_. ."" ,-. ..',' < ~,.~. - '.'~~, , ~ .' ",.,,~,"~ . , ,V~ ~-' -- ,~ ~1iW:1II 0 0 C) C rv iJ <,I (/) ""1JU: ,., ~ .,-:! [!1F'. -0 ,";;-1 Z:r '!~ ZC I nnr;-:' S?~: ~ -'"0 .~ "'6 L .-) - r:c '-?ii :< . -u )> :t::: 5" zO -.-0 )>0 ~ arT! c ~ N ~ -< , . '.. ~ , ,>J*"_ _~V~" , ,,' ~, ~L ~_J" ~'<='-="--<l , . .. . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION Denise M. Dew, Civil Action--Divorce Plaintiff Defendant No. 01-3293 Civil Term In Divorce DR# 31214 Paces# 730104027 vs. William H. Dew, PRAECIPE TO DISCONTINUE SUPPORT To the Office of Domestic Relations: Please immediately discontinue permanllnt\y all collections of Alimony Pendente Lite or Uf.%{)'f- ~ &-w C/..o\%:<'(A/ S ~ Support)ftat ybu are making in Plaintiff's behalf, discontinue garnishments from the wages of the , ~ffn f'%:avt-~owV7&W~ ~ Defendant, ~ tetllliRat erts tG llffetlftlges in the event fhllt lIR)' ar-rearag@G af@ QU'R6g., by Defua~ the above captioned case. In the event that you have in your possession any funds that have been collected in behalf of Plaintiff, please return them immediately to the Defendant, William H. Dew, 404 Evergreen Road, New Cumberland, PA 17070. The purpose of this Praecipe is to satisfy terms of a Separation and Property Settlement Agreement executed on this /f day of October, 2002, that extinguishes Plaintiff's claim, that has not yet been collected by the Plaintiff, for alimony pendente lite or support for the past or for the future. J..Cku~.f ':!nJOeu r- Denise M. Dew, Plaintiff ,-' " Carol J. Lind ,Esquire Saidis, Shuff, Flower & Lindsay, P.C. Attorneys for Plaintiff 26 West High Street Carlisle, PA 17013 (717) 243-6222 ~~I~~:'*:lli'i1ik&.i1~~.a.~llii'.'"~M~&tr,0!il,'~~~lii;."";"';''''":'''~;;'k;f~,~~;~!.il*:.a~~~~ittill"@lM&'~"'-""~-~'''' .. .',.-" (, < ........ r) 0 ~ Cl ~ 0 ~ W """" [Rm ~ ~ Zrir :z::JJ :<l: ~ Il(,) C/j :to. N '" :-< ." .:;- s::; +- Fe ~ ?l... +- ~o :l:>> :x r;) '" ;SO 0 ~ 'f? :), =< J;:- ~ b ~ .,... ~ ~ E? --< ~ ~~ .'~<""-<""'-'- _-i: . !;f; :j'! "I::rJ r- -'-'jrn ~3? ,,",u )::;1 fio om :;;! ;:0 -< " SAlOIS SHUFF, FLOWER & LINDSAY A'ITORNEYS-ATlLAW 26 W. High Street Carlisle, P A ~<',C .J' -_ DENISE M. DEW Plaintiff/Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : No.421-3293 CIVIL TERM vs. WILLIAM H. DEW, Defendant/Respondent : IN DIVORCE AND NOW this ORDER OF COURT \!.~ day of _tc ~,~ L.l1 , 2002, upon consideration of the within Petition for Special Relief, a Rule is issued on William H. Dew to show cause why he should not be enjoined from borrowing against or liquidating his 401 (k) Plan, The Quaker Plan, or dissipating any marital asset pending equitable distribution. RULE returnable at a hearing set for the J.5 j!/6 _ day of ~ ' 2002, in Court Room No. / at the Court House in Carlisle, Pennsylvania, at Cf;3tJ cz...,.m. o'clock PENDING the hearing, Respondent is prohibited from dissipating any marital asset, and in particular, from borrowing against or liquidating any portion of his Fidelity 401 (k) Plan, The Quaker Plan. rf\~ ~A1l* t ~.()~.OJ- o By the Court, . Li tid..:>Oj 7 W LO JJt.b~ . J. tJ)v:J ~ ~A0 . II , _ _ t[ ~ " "-, '~<c",'''''' ~'~_.,'~' 0>' _""~_'~"'_ ~-"~"'-"_' ,,,,,,",,,,",,,,,,,-,<,~,-, ~ .=_ OF- ~-~ (12 F" ") \)... to i..iJ ':}ilv=rv '.'it PN "). I') ~J t:.. ~) ~ CUi..... I~~;'.!,,:'): ,,' :,"- PE/iNiN(\~ii/EUNTY ..1-\"\111 L_ ]IIiJ l.iIII1' _fl,f,~.~~~~~~iJl. ~~~~fJfflij~~' fII!rlt~~~~ , SAlOIS SHUFF, FLOWER & LINDSAY ATIORNBVS1ATlLAW 26 W. High Street Carlisle, PA - ""F~' -,-";"."",--,,'-- DENISE M. DEW Plaintiff/Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION. LAW : NO. ctl-3293 CIVIL TERM vs. WILLIAM H. DEW, Defendant/Respondent : IN DIVORCE PETITION FOR SPECIAL RELIEF Now comes Denise M. Dew, by and through her attorney, SAlOIS, SHUFF, FLOWER & LINDSAY, and petitions this Honorable Court as follows: 1 . The parties hereto are husband and wife, having been joined in marriage on June 29, 1997, and having separated on April 25, 2001. 2. The parties own no real estate. The significant marital asset is a 401 (k) Plan, the Quaker Plan, owned by Respondent. 3. Shortly before the parties' separation and without the knowledge or approval of Petitioner, Respondent borrowed from his 401(k) Plan $35,000.00, depositing that money into his Belco savings and checking accounts. 4. From the $35,000.00 so deposited, Respondent paid off approximately $6,000.00 in marital debt which was in his name only, and spent $10,000.00 for a Ford Mustang. The balance of the $35,000.00 has been spent as well, although Petitioner is not sure of the disposition of the balance of the assets. 5. At a conference on a Petition for Alimony Pendente Lite on January 24, 2002, Petitioner learned that Respondent had borrowed an additional $6,000.00 to $7,000.00 from his 401 (k) Plan. II SAlOIS SHUFF, FLOWER & LINDSAY A'ITORNEYS-ATlLAW 26 W. High Street Carlisle, PA ".",""" '~._-~ 0--"-"';;"::'''''''. _'I_' ,,,,j ii_'-,' ',,_ - '>:___""k.,~,_" L'"',_;;~v';;"'O";:' ,~l;);;';,--,;':,i;.;;"';;,,:'-';;C _"~~ ~_ 6. Petitioner believes and therefore avers that Respondent's continuously borrowing from the 401 (k) Plan impairs her ability to be paid in equitable distribution. WHEREFORE, Petitioner prays this Honorable Court to enter a Rule upon the Respondent to show cause why he should not be required to refrain from borrowing against or cashing in any parts of the his 401 (k) Plan, or from liquidating or otherwise dissipating any marital asset pending equitable distribution. SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff/Petitioner By: II SAlOIS SHUFF, FLOWER & LINDSAY A'ITORNEYSIATlLAW 26 W. High Street Carlisle. P A , '.--' ''''';i::: i i I I I VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. Date: II ~ mlfluu- Denise M. Dew //~'fJo;;" , SAlOIS SHUFF, FLOWER & LINDSAY A'ITORNEYS-AT-LAW 26 W. High Street Carlisle, PA , -1'1 , .." ,,~ " ,...---," , ~,,'" .,_. "'.,;"",",--- ',,:J.,--,~;..,;--;.:,,;,: ,,,"[("",', ~__"-'C~'_.~_''''''"~';''"-'' c"- "'-" DENISE M. DEW Plaintiff/Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 21-3293 CIVIL TERM vs. WILLIAM H. DEW, Defendant/Respondent : IN DIVORCE CERTIFICATE OF SERVICE AND now, this ~}1 day of FLOWER & 2002 Carol J. Lindsay, Esquire, of the law fir LINDSAY, Attorneys, hereby certify that I served the within Petition for Special Relief this day by depositing same in the United States Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to: G. Patrick O'Connor, Esquire 3105 Old Gettysburg Road Camp Hill, PA 17011 SAlOIS,. SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: quire II ~_~lJ!_il!;~~~~~~~~<;;,~~~_~~_~!ffflli~mjamj~lO~,,",-"m~"'iiljiiil_il ~s 1::.7::> ,.J~.L.~ -,~,'~~-~~,. ~ ,,~ _"A __V'_'~,~',"__~ "~, ,~. ~, ~ '" i,.",~' "~ ~- 0 0 C I\,) C) ,,$: , -<1 ill ~ " ..,~ 52121 ~tb ~~ ,'., ~l.' Zl~~ o- N , " (/) >'. ~~: ;:$;2 \.0 is::1...._J 'u (~ ..r~() Z' :11: ;~~ ;;.:;0 ry c z ~ o;;! c::; 50 -< fii[ ~, C~.~~. . ~. & .. ~- DENISE M. DEW, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner: CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 01-3293 CIVIL TERM WILLIAM H. DEW, Defendant/Respondent: IN DIVORCE IN RE: PLAINTIFF'S PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 15th day of April, 2002, upon consideration of Plaintiff's Petition for Special Relief, and following a hearing held on this date, it is ordered and directed as follows, pending further order of court: 1. Defendant shall not withdraw, borrow against or from, encumber, alienate, transfer, give away or, by any other act or omission, including the loss of his present employment, deplete, diminish or depreciate the assets of Defendant's 401(K) Plan (the Quaker Hourly Plan); 2. Defendant shall not withdraw, borrow against or from, encumber, alienate, transfer, give away or, by any other act or omission, deplete, diminish or depreciate the proceeds of any loans or withdrawals since April 1, 2001, against or from the said 401(K) Plan, or any account into which such proceeds were deposited. 3. Within 20 days of today's date, 'tiI ... ," '1 !,;::J o:~ T~~j.L~p;"(2~:'~},CI~, I .r'., ,1- '1-" 'T"R" "'..' . .;j '-,'.) ,/jlj Y 02 APR I 7 I: 29 0",.jpCCi ',.." "_' I..AJW''-'c,' ,J-"," ,. (;' '"Tr PENNS\V.\I~K!li;:1 j I ' ~. "''1',,-- _..,. ",~!iF'MI!.~, _!'''''''''F:'~ r}~_,~!qO~~~~~)'!Wj~""#"""L:I!t\\:m\*#Ji'jjI"lW!#~WJ!i~~~}\I,f'~o/.;,-'f?r@~'I~~~~~~~~_i!f -- , . ~, . ~,~-- ,,> ~ .~- '"-J' ~~':: . Defendant shall disclose, upon verification in the customary form and supported by such written documentation as he is reasonably able to obtain, to Plaintiff's counsel the disposition, proximate and ultimate, of all withdrawals or loan proceeds from the said 401(K) Plan since April 1, 2001; 4. Within 20 days of today's date, Defendant shall disclose, upon verification in the customary form and supported by such written documentation as he is reasonably able to obtain, to Plaintiff's counsel what amount presently in the said 401(K) Plan is available to be rolled over into an account of Plaintiff if such an order were entered; and 5. Following the disclosure required under paragraphs 3 and 4 of this order, the court will entertain a motion by either party for a hearing on whether the injunctive aspects of this order should be terminated or otherwise modified. By the Court, Carol J. Lindsay, Esquire For the Plaintiff G. 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I ,-- 181 I I I~III .. " -", I>~>!I n n[n n I~ ~I~ ~ NCO........... ~ clm m , 0'" , '"01"'''' ctDbco9' '" 01'"'''' ~2::3~ CO ...."jlo 0 o ~I~ 32 ~~org; 3'roo (l)CJ'J3o %..E3'fg~ o.ro;;:~ !!:. 3 III Cf) C!i<:tl(ij_ o.2.o.!!:. 00.0(0 7" '" "'13 ~mw~ ,c............ ~ 0 ,vI"" o.....ow .....Noro _w.....o ~N ..... c 0 ~ 00 - w..... ~ W 0 ~ 0 '" o ~ 2 o w W '" o :: '" o io 00 :E ;;: " ~ " ;;; ~ !a. .. .~ - '" co '" o ())(]1.AW :rI:I~ CC:P-tXl(")t:O (I) = CtI =r Cll C;~OCll::l Ol:2.O~,c' (,,)("')Cf.lS'> g-::r~(Og n m -.llJ 0 ~ Q-r.5 g C rii S' tfl ;- a. '" '" ~ 0- 0," co~ 00< ~ 5' ~I<g 001> Olg rg I~ II ~ I ~ '" .0 o o o o ~~I ~.....I :""1' l~~, :..01 coo ,.. '" .", '" w o o c ~ ro "" o g. ~ !!. ? ~ 0- '" => m x " iil ~ ~ ~ illlIIIl!liMl 'lii""'~~~;lilij~~1JjMO!L~~' "'- ~ ;;; ia- :1;:J: <~ "'- _c c" " "" N@ lZ.. - '" --. '"~ ",,,, . .., o. 00 .9 ~-< "'''''' "''''::; -...J A_' t-t-t!. " " " " " ~ "0" n:1; ::.-, ro '" ~ => 0<0 ~- " " ro ' ~ '" '" o o o :2 " ~ II I.. I ~n ~m ~ II I -", ",n I 08 I 89- o=> -'" "'- 000 ijo -" 1J 2. ~ ~~ o => "'0 .." !,-", '" '" -- o (/) ;; " 3 " 3- "" '" " "" o ~ o ~ " m > r- m '" .... :; me " ~ " ~ '[ 0- => o - f oo!:n OO~?s- ~~$':a 00;;'" f'"C;>>Olll ZNN:.3 OY'cpN~ ....m~<o8c o te..... (I) tJ).....-....I1.:E ". <<>0 " => r;;- " ;; 3 ~:J: (/)1;;,> "0''" "C. (/) @ ;?I~ g~cn '" 0.;:;; .ga; '" < ~ '" w _ .=c 0" => i , ~ "' ~- ." o Cl o x ~ '" ... .'" s: " Q. ~ => o' ~ 0- = , ~ ." > ~ -- o '" '" " ;: C"l o ;C ;C m Z .... (/) ,~, .. FidelilyA Inveslnlenlson The Quaker 401 (k) Plan for Hourly Employees Retirement Savings Statement April 1 ,2001 - June 30, 2001 Social Security Number; 268.68.9128 #BWNFXTG WILLIAM H. DEW 404 EVERGREEN ROAD NEW CUMBERLAND, PA 17070 ENV#MG000972 MG 05161 X e.ll:' Customer Service Center: 1-800-414-4015 To make changes to your account or for questions about thi statement, call the toll.free customer service number. Representatives are avai[able 8;30 AM - 12:00 AM M.F. A Quaker Benefits Office Message investing means accepting ana important fact: most investments can go up and down in value regularly - sometimes by a lot w even over short-term periods. Be realistic about the potential for growth for your investments, and realistic about the risks. Over the last six years, stocks have pertormed unusuaily well with annual returns averaging about 20%. However. stocks have had historical average annual returns of approximately 11 % '*. Remember that the best investment strategy is to choose the right asset allocation of stocks, bonds and short-term investments and to invest for the long term. Call your plan's toll.free number or visit Fidelity NetBenefits(sm) to review your asset allocation so you can be sure it's meeting your long-term needs. *Ibbotson Associates, 2001 average annuai rate of return of stocks 1926-2000. Past pertormance is no guarantee of future resufts. Stocks are represented by the Standard & Poor's 500 Index (S&P 500 Index). The sap 5000 Index [s a registered service mark of The McGraw.Hill Companies. [nc., and is a widely rec09nized, unmanaged index of 500 U.S. common stocks. Fide[ity Investments Institutional Services Company, 82 Devonshire Street, Boston, MA 02109 Your Account Summary Your Asset Allocation Beginning Balance Loans loan Repayments Disbursements Change In Market Value Ending Balance $104,742.12 -35,000. on 2,176.44 .258.41 -4.621.97- $67,038.1~ . Stocks 99% o Short.term 1% Additional Information . Dividend & Interest $291.69 . Outstanding Loan Ba[ance $33,597.98 Loans are an assat of your account but are not included in your asset allocation. Your account is currently allocated among the asset classes specified above. Percentages and totals may not be exact due to rounding. Your Personal Rate of Return This Period -4.9% Yearto Date -4.7% Your Personal Rata of Return is calculated with the time-weighted formula. a formula widely used by financial analysts to calculate the invssbnent earnings of a portfolio. It reflects the results of your in.vestment selections as weU as any activity in the account There are other Personal Rata of Return formulas used that may yield different results. Remember that past patiormance is no guarantee of future results. PLAINTIFF'S .~EXHIBIT ti '2 . ..~/S,-6~' Please roaad this statement carefully. Any error must be reported to Fidelity Investments within 90 days. 0972 MG000972 0001 20010723 MG4K Fidelity Investments, PO Box 5424, Cincinnati, OH 45250-5424 268689128 Page 1 of4 ;2f~~~~~~M;~~~'&)!lf1i'~N-.I;Q_~~O:'~~!~"'''''6~~$'1~~l..L-d~;;!'::'*("f,~l):)"",;~,,,,~~~!l&~iW~iJia'ill. L'._"'_~~~ .~" ~.~,i:! "fT~_~_'_,":~,_ _:L The Quaker 401 (k) Plan for Hourly Employees Statement Period: 04/01/2001 to 06/30/2001 Social Security Number: 268-68-9128 /-' Your Account Activity Use this section as a summary of transactions that occured in your account during the statement period. Fidelity Quaker Activitv Retire Mmkl Common Stk Total Be9inning Balance $15,054.08 $89,688.04 $104,742.12 Loans -15,084.45 -19,915.55 -35,000.00 Loan Repayments 781.35 1,395.09 2,176.44 Disbursements 0.00 -258.41 -258.41 Change In Market Value 33.28 -4,655.25 -4.621.97 Ending Balance $784.26 $66,253.92 $67,038.18 Dividend & Interest $33.28 $258.41 $291.69 Market Value of Your Account Displayed in this section is the vaiue of your account for the statement period, in both units and dollars. Investment Units on 03/31/2001 Units on Price on Price on 06. 0/2001 03/31/2001 6/3 001 Market. Value on 03/31/200 Market Value on /3 001 St9'*,"1!\!"IDlii!!\!!iiMmi,ii,m, i;!'t'iIi!:;i'iiiI':;ii Quaker Common Stk 5,373.759 .,..,........,...,.,.,. ,.,,<>;:"...,_...._._,',.._._,n._. "'" "4:21'7:309 . ,\ f.';'''':':~:';r, . $1'6:69 . .. ::;~)M\::+~:WdHHhl!tw;::l:n:j$$.$MJ.l~Q4 tm~i ::i:~i:~~:m:W::_~~$li: $15.71 89,688.04 66,253.92 'i~~I~~~~il~Y~~ili:il!li" .;Mi', i'g:~g~~6~6"i;"""ii,iiIf~~1~~& "'i"i';i~,:i66 ",g'.ii"i;':&6.m i,,::i,ii,!ifI!~~:~~~,i:iiliii@ii!,i,m;$~~1~ As of Juno 30, 2001 you own 4217.309 units of Quaker Common Stock Fund. which equates in value to approximately 726.0704 shares of stock at $91.25 per share. Your Contribution Elections as of 07/23/2001 This section displays in which funds your contributions will be invested. Company Investment Pretax Match Fidelity Retire Mmkt 43% 0% Quaker Common Stk 57% 100% Total 100% 100% Company Contributions Pretax Match This Period $0.00 $0.00 Fidelity to Date $8,191. 71 $2.352.22 Your Loan Activity Loan Date Loan Amount Balance on Principal Repaid Balance on Interest Paid 04/0112001 This Period 06130/2001 This Period 04/12/2001 $35,000.00 $0.00 $1,402.02- $33,597.98 $774.42 Loan Totals: $0.00 $1,402.02- $33,597.98 $774.42 0972 MG000972 0001 20010723 MG4K Fidelity Investments, PO Box 5424, Cincinnati, OH 45250-5424 268689128 Page 2 of 4 ~,-""",,~~ ""","';~=>,"~,,""~W'" c'."',"",",,", ,,__~ ." _,c_'"",,~ _~"',,' " - ~" ~ ]-0, !JJ:;W , W lLLlAM H. OS 161 - THE'QlJAKER-4m-K1'LAN--- .PageTOt 1 View the current balance of your retirement savings plan account as well as details about your investments. ~. Investment Options ~t Asset Class Source Balances Total Market Value $47,163.74 As of Date: 03/28/2002 Outstanding Loan Balance $36,096.29 Balances To view historical performance, click on the investment's name. Investment Option by Asset Class Balance Shares NAV $ Change per or Units Share or Unit Stock Investments COMPANY STOCK PEPSICO CAPITAL STK $46.637.63 5,281.725 $8.83 + SO.07 Short Term Investments FIDELITY RETIRE MMKT $526.11 526.110 $1.00 $0.00 Balances and prices are subject to nightly account updates. PlAINTIFF'S I ~'BIT ':f.;Ls -c;).. /"J1<-<.. https://corporatebenefits403 .fidelity .comlnetbenefits/definedcontributionslbaIanceslfund 4/112002 Fidelity: Loans '. ;1:- ~~.... Page 1 of,3 01 iI1\h\,~~ Illj'\lll~ '1~'1 1~(4~ ,~~, l'AJ'~~l(trj."IHfl~ n .. . ..'j&A:bo#t"~~O<)S ......1', . ',", . ...,t4g~~~]'I\'.6~_~ , ... .-. . 1'h:tJ1 spon.So"sffi~"e~ .. ,SM. "Fiirids.'; Other Topics . The BasIcs Contributina to Your Plan Withdrawals Withdrawals Durina Retirement WhJ'.!.!.x.!I~J"llave You r JOQ Th= Statements II " " " 9/1&-)' Loans . Can I borrow from my 401(k)? .tIQ-'!LQ9~S-'!.l9.a!:L!J:on:!,.,,-4.oj!!stpJan.aC,CQ\!ut.w,QrK? II J='-QJ!!L~~n I borrQ..'l!!Lf.G2.!!1111Y..ADi(Js;l-Wm11. . How doe_s takina a loan affect the..Y.J:l/llLof mv accounj:.:{ II Are there taxes Q.r penalties involved wit.h..2 loan? . !i9J!LI.Qng"QQ.9-,Lil..ta.!s1l_tQ_llrQ<;Ii!ss,aJQa!l1. I( Are the inteLf}_~~lggij{.!l'lf!nts on lo~...1!3X' d~ductible? . .!iQ.1<1/ do I repay my 401 (k) plan account? II What~PJims to mv loan it' leave myemolover? III {:!~D_Lt~ke a loan fI9JD.JJJylBA1, Can I borrow from my 401 (k)? It depends on the provisions of your company.s retirement plan. Not ail plans allow for loans. Check with your benefits department, or cail your company's dedicated Fidelity telephone number to find out. Return to auestion list How does a loan from a 401(k) plan account work? When you take a loan from your 401 (k) plan account, you actually take money out of your account, with a promise to repay it. You pay your account back the amount you borrowed plus interest (a fixed rate determined at the time of the loan), through automatic deductions from your payor bank acount, or through coupon payments (as allowed by your plan). The interest you pay your account is not tax-deductible and is paid with after-tax dollars. As long as you repay your loan on time, you won't be subject to withholding taxes or penalties, as you would if you withdraw from your account before retirement. There are some additional things to keep in mind when considering taking a loan. First, check with your employer to find out what the rules are for repayment if you leave the company before repaying your loan in full. Many plans require prompt, full repayment. Not repaying your loan within the provisions of the plan can cause it to be in default, triggering tax consequences. Second, consider the possible long-term effects a loan can have on your account balance, Although a loan may be a practical option when you need financial assistance, you could miss out on the full growth potential of your principal over the long term. In other words, the money you take out of your account immediately loses its earning potential. And while you're paying interest on the loan, it's important to remember that the interest is coming out of your own pocket. Retum to Q.\le~liQnJisJ How much can I borrow from my 401 (k) plan? If your plan allows for loans (not all plans do), the most you can borrow is 50 percent of your vested balance or $50,000. minus your highest outstanding loan balance over the last 12 months -- whichever is less. Some plans may have more restrictions. so be sure to check with your benefits department. http://www.401k.comJ401klabolItlloans.htm 04/12/2002 ....~. 1 - ~~ . - . " l. -.i!l"'~' ":-., ^'.:JJi" Fidelity: Loans Page 2 of3 . . ! Return to .QU..!i~!QH.JJ.SJ How does taking a loan affect the value of my account? First of all, the monay you borrow comes out of your own account, so your balance is reduced by the amount of your loan. But taking a loan has another, less visible, effect on your account over the long term. While a loan may be a practical option when you need financial assistance, over time you could miss out on the fuil potential value of your principal. In other words, the money yoy take out of your account is no longer working for you. and therefore, loses the potential t6 grow. Even if you repay a loan to your account and continue to invest in the plan. you still lose earnings potential for the loan amount while you're repaying it. Return to auestlon list Are there taxes or penalties involved with a loan? There aren.t taxes or penalties when you initially take a loan. Taxes or penalties only come into play if you leave your company, and/or if you don't repay your loan on time. If you decide to leave your ernployer, you must repay your loan in full within a certain amount of time. If you are under age 59 1/2 and you dO'not repay your loan within this certain time frame, the loan is then considered a withdrawal and you would have to pay a 10 percent early withdrawal penalty as well as current income taxes. Some employers treat loan defaults differently, and some charge fees for taking loans. Check with your benefits department or call your company's dedicated Fidelity telephone number for more information. Return to auestion list How 10.0.9 does it take to process a loan? This depends an yaur company's plan. It could take as little as three days, or as long as six weeks to process a loan check. Call your benefits office or your company's dedicated Fidelity telephone number for specifics on your plan. Return to Que.llTIon..USt Are the interest payments on loans tax deductible? No. Return to QueJ>.ij.oILlisl How do I repay my 401 (k) plan account? You repay the loan to your account through automatic deductions from your payor bank acount. or through coupon payments (as allowed by your plan). interest on the loan is also paid into your plan account so you are. in effect. paying back the interest to yourself. The intereslyou pay is not tax deductible and is paid with after-tax dollars. Return to .Qu,s.StioH..USt ) What happens to my loan if I leave my employer? If you have an outstanding balance on your loan and do not make arrangements to pay it back when you terminate employment, your loan will be considered in default and the outstanding balance would be treated as a taxable withdrawal. The provisions of your plan will outline the circumstances under which default occurs, so be sure to check with your benefits department. Return to Question list Can I take a loan from my IRA? No. Loans are not permitted from an IRA in any circumstances. http://www.401k.com/401klaboutlloans.htm 04/12/2002 """~~ ~ - "-- . : ; , - ,',-" --, -.,~ '; liii~" Fidelity: Loans Page 3 of3 . t Return to auestion list @Copyright1996-2002FMRCorp. All rights reserved, ImDortant Iflo<'ll infonTI<'Ition, A~ "In~E.III..,,~ http://www.401k.com/401k/about/loans.htm 04/12/2002 - .', -, u" l'~~"-i:::i '. I' .. DENISE M. DEW, Plaintiff, vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. Q1-3293 WILLIAM H. DEW, Defendant. IN DIVORCE DEFINED CONTRIBUTION (401 (k)) PLAN QDRO WHEREAS, the Court has by separate Order dated VA AlI.IF/LY J. ~. .d.t1I'J.1 granted Plaintiff and Defendant a Decree of Divorce which provides for a division of the marital estate and provides specifically for the assignment to the Plaintiff of a portion of Defendant's.benefit in the Plan (as defined herein); and WHEREAS, the parties hereby submit to the Plan Administrator an Order that satisfies the requirements of a Qualified Domestic Relations Order. NOW, THEREFORE, in consideration of the foregoing premises hereunder specified, Plaintiff and Defendant do agree, and the Court does order, as follows: (1) The parties and the Court intend this Order to constitute a "qualified domestic relations order" as defined in Section 414(p) of the Internal Revenue Code of 1986, as amended (the "Code"), and Section 206(d)(3) of the Employee Retirement Income Security Act of 1974, as amended ("ERISA"). (2) This Order applies to the following qualified plan (hereinafter the "Plan"): The Quaker 401(k) Plan for Hourly Employees. Unless otherwise defined in this Order, capitalized words shall have the meaning assigned under the Plan. (3) Plaintiff is hereby deemed an "Altemate Payee" within the meaning of Section 414(p)(8) of the Code and Section 206(d)(3)(K) of ERISA. Defendant is a participant in the Plan. (4) The name, mailing address, social security number and date of birth of Defendant, hereinafter referred to as "Participant," are: William H. Dew, 404 Evergreen ~ " . """ ,~"..., ;,0, !8:_ 'C ~ , Road, New Cumberland, PA 17070,55 #268-68-9128, DOS: 2/21/61. The name, mailing address, social security number and date of birth of Plaintiff, hereinafter referred to as. I 11055 cJrn'lC\.... "Altemate Payee", are: Denise M. Dew, P.O. Box 1542, Mechanicsburg, pJ(, 5S #161-58- 7070, DOS: 1/30/69. (5) From the Participant's account balance in the Plan, the Plan shall distribute to the Altemate Payee a single lump sum cash amount equal to $30,000.00 as soon as practicable following the determination that this Order is a Qualified Domestic Relations Order and in accordance with the terms of the Plan. (6) In the event any portion of the Participant's account balance assigned to the Alternate Payee under this Order is invested in the Brokerage Option, the Participant is hereby ORDERED to transfer, immediately, such portion assigned to the Alternate Payee herein into anyone (or any combination) of the PepsiCo Common Stock Fund, the Security Plus Fund, the International Equity Index Fund, the Mid Cap Equity-Index Fund, the Total U.S. Equity Index Fund, the Large Cap Equity Index Fund, the Bond Index Fund or the Small Cap Equity-Income Fund. (7)" In the event of Participant's death prior to payment to the Alternate Payee, the Altemate Payee shall be deemed a "surviving spouse" within the meaning of Section 414(p) (5) of the Code and Section 206(d)(3)(F) of ERISA with respect to the amount of benefit assigned to the Alternate Payee hereunder. Any designation of Alternate Payee as Participant's designated beneficiary is hereby revoked and canceled except to the extent needed to carry out this Order. (8) In the event of Alternate Payee's death prior to commencement of payment hereunder, the benefit shall be payable under the terms of this Order to her estate. (9) Upon the last payment of any distribution to Altemate Payee pursuant to this Order, the Alternate Payee shall have no further right, claim or interest in or upon the Plan or the Participant's account in the Plan. , . . -~ , , "'.......- .""'[' ....' . , (10) Notwithstanding anything in this Order to the contrary, in no event shall the Plan be required to (a) provide any type or form of benefit, or any option, not otherwise provided under the Plan, nor (b) provide increased benefits (determined on the basis of actuarial value by the Plan's actuary); nor (c) pay any benefits to the Altemate Payee which are required to be paid to another altemate payee under another order previously determined to be a Qualified Domestic Relations Order. (11) Because it is intended that this Order will qualify as a Qualified Domestic Relations Order, the provisions hereof shall be administered and interpreted in conformity with ERISA and the Code. The Court shall retain limited jurisdiction to amend this Order only for the purpose of meeting any requirements to create, conform, and maintain this Order as a Qualified Domestic Relations Order under ERISA and the Code, and either party may apply to the Court for such an amendment. (12) The Plan, its sponsor, contributing employer, fiduciaries and administrators shall not be responsible for any costs and expenses, including attomey's fees, incurred by the Participant or Altemate Payee in connection with obtaining or enforcing a determination that this Order is a Qualified Domestic Relations Order. AND NOW, this day Jf ~f -r' ~ rJ:-' 20. the foregoing is hereby ORDERED AND DECREED. SO STIPULATED: _ /.) ~,/a---- '-tZfdf'iJ.:II1W-! ( . -1/ William H. Dew ' S COURT J1nuum Du.u- Denise M. Dew Attest '~UHHH\\\"'",~''''',.','''.:'','''.'.''''''~''''''''' ",., ......,..... ..,. ..........n.... l~3 ').\..0 0\ ....1 TRUE COpy FROM RECORD In Testimony whereof. I h~r8 unto set my hand and the seal of said Court at Carlisle, Pa. This............ day of. ..........., prGltllQllQtaIV 'l!:, L{ l.iHtl:, , .., , . ~l_ " ,.~ ~ "'--,~ ~ ~, - ~" ^ <110_" , <,,' '.,.-- ~ "'~"' -~', 0: 01 rr'j~.!') "I... '.nr,-..J ,--, '" ',,""0 -'''''~''', ,,,,",,~-t;~J'A'''''{''',\l;;;'1'-';1;,jJ\'';''~'t''',""~'"""n!it~ IliIl1ll""~' \1'" -()CFiCF , '--"!"'~'- ! '1',,1 !!/'JRY .., "~" I \; ",19 g, 'l? r- r. .~'..... CUI~'i;~,:l;-i:;:...i~' ";~> \~'()UNTY d;:NN~YlVANiA ,,; tMllA!J~~~~N:_:f\;ij_~~!1"'-"i0<i!'-'''!1'~6Wi''';B.O'~'-,",''''''''~''i'l-:','liif"'JtlIiJO'1I'?}F'W,m~iJ'I;[i,\Il'l?~'t;,I';ii!i'!:~~:*i'Hi'\ =" .~ .... - ,~ '""f';;': ..' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Denise M. Dew, Plaintiff! Movant vs. Civil Action--Law No. 01-3293 Civil Term William H. Dew, Defendant/Movant In Divorce ORDER OF COURT AND NOW, this ~O tt. day of :\;>.h \l Pl 1 2.oe3 , 2fl92, upon consideration of the Motion to Terminate Injunctions, filed as a joint motion by both parties in the above captioned case, it is ordered and directed that all injunctive aspects of the Order of Aprill7, 2002, as well as of all injunctive aspects of previous Orders that may be applicable to the above case, are hereby terminated. By the Court, Ii( 1. esley Oler, Jr., J. l~ o:U- i't R~S 01-31-03 _f . )!lf~ n -"'-1 .....-I-_"V. ,'il,...!::L .-tJr't>;Cc Or:: "Ie 'c' 'C", .r'"^RY "J ,'i., . ':'-j'!"iUid 03 JAN 3 I Pi'! I: 13 CUM~EHLAI';D COUNTY PEMIlSYLVAN1A , ~ ""'~ ,~,."",~,,,,.....",~..-'!"I'!'~"" ,_qfi!~j~~1~~!~..~,ew-f~,oiU:';;:~T";;W'" "1:;)!""fr,;-:","P,H,':ql1!",..,-%~"j!Ri'R1IDFir",'illm1-~",.;;~~-;",f~';':111If~1'1l[!l'JfJ~i!,~~~~ ,~~=~ , , "' " " --~, ,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Denise M. Dew, Plaintiff! Movant vs. Civil Action--Law No. 01-3293 Civil Term William H. Dew, Defendant/Movant In Divorce MOTION TO TERMINATE INJUNCTIONS AND NOW, this _ day of , 2002, Denise M. Dew, by and through her counsel, SAIDIS, SHUFF, FLOWER & LINDSAY, and William H. Dew, by and through his counsel. G. Patrick O'Connor, Esquire, hereby moves this Honorable Court as follows: 1. The parties hereto are husband and wife, having been joined in marriage on June 29,1997, and having separated on April 25, 2001. 2. The plaintiff filed a Complaint in Divorce on May 30, 200 I. 3. Defendant filed a Petition for Special Relief on or about February 1,2002, in regard to defendant's Fidelity 40 I (k) Plan. 4. In response, this court issued an Order pending a hearing on February 1, 2002, and an Order on April 17 , 2002, subsequent to the hearing. Each Order contained injunctive aspects. 5. The parties hereto have resolved their differences and have executed a Separation and Property Settlement Agreement which provides for disposition of Defendant's 401(k) funds. ,~h " ~ " 0, " L~ -1l1~-, ;:! 6. Said Separation and Property Settlement Agreements provides that the parties will file a joint motion to terminate previous Orders providing for injunctive relief. WHEREFORE, movants pray this Honorable Court to terminate all injunctive aspects of the Order of April 17 , 2002, as well as those of all previous Orders that may be applicable to the above case. arol J. Li sa, Esquire Saidis, S ff, lower & ndsay, P.C. Attorneys or Plaintiff ID# 44693 26 West High Street Carlisle, PA 17013 (717) 243-6222 ~ . Patrick O'Connor, Esquire Attorney No. 64720 3105 Old Gettysburg Road Camp Hill, PA 17011 (717) 737-7760 Attorney for Defendant 0:' ~~~ ~~ . ~ ~, '-,~, .' VERIFICATION I, WILLIAM H. DEW, verify that the statements set forth in the foregoing document are true and correct to the best of my knowledge, information, and belief. I realize that false statements herein are subject to the penalties for unsworn falsification to authorities under 18 Pa.C.S. Sec. 4904. rd~dAv/~ WILLIAM H. DEW Date: IO~? 3 - c.) y .",,"' ~r. ~ -- ~ .~, , ~" 1<11; VERIFICATION I, DENISE M. DEW, verify that the statements set forth in the foregoing document are true and correct to the best of my knowledge, information, and belief. I realize that false statements herein are subject to the penalties for unsworn falsification to authorities under 18 Pa.C.S. Sec. 4904. ~rn fJwJ DENISE M. DEW Date: Mr~iitrR!l~~~~IWf!!jl~$.,;ji~;>"fu;M~!mii~t':'2Mii";-"\i.'k;W"'~!'J""'ili-~'d'z:C~''''J',,-~,i>;);diii$lW''1iilJ!tli:ili'~~~iS~~;iOO~' ,,,,",' I~ ~" ~- 4> ,~~" o C <<.... -ot~fj [lJ[l: .L...---,-__' zr' Cf) ~!?:, -< ~:!, r:c ~ zQ >~ L: ::2 ~."~r'~~' ., """"~--I C (-" a '-,j T~'" i:: .... T ';i"':~ ~:~ ~9 "-''i_J. .~..:! i._) :)::: ~-H ~::-() 6''11 -l ;p: ~ N OJ -" 5:; ".:' U1 " .,~ - L ~- ., , "" ~"^' :~;;i , .... State Commonwealth of Pennsvlvania Co./City/Disl. of CUMBERLAND Date of Order/Notice 01/28/03 Tribunal/Case Number (See Addendum for case summary) ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT J;Al. 0200/3)93 {ll{/Ie jJ/}(!.::;'i S Z:::;o / tY/o;r 7 o Original Order/Notice o Amended Order/Notice @ Terminate'Order/Notice EmployeriWithholder's Federal EIN Number RE: DEW, WILLIAM H. Employee/Obligor's Name (Last, First, Ml) 268-68-9128 Employee/Obligor's Social Security Number 7375100880. Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, MIl QUAKER FOODS & BEVERAGES 321 N CLARK ST CHICAGO IL 60610-4714 See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee'slobligor's income until further notice even if the Order/Notice is not issued by your State. $ 0.00 per month in current support $' o. 00 per month in past-due support Arrears 12 weeks or greater? Oyes @ no $ , O. oopermonlh in medical support $ 0 . 0 oJJer m6nthfor genetic test costs $ . per month in other (specify) for a total of $ 0.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the fOllowing to determine how much to withhold: $ 0 . 00 per weekly pay period. $0.00 per biweekly pay period (every two weeks). $ o. ooper semimonthly pay period (twice a month). $ 0.00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding nO.later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the 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 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 ofthe limitation on withholding, the fOllowing information is needed (See #10 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make RemittantePayable to: PASCOU Send check to: Pennsylvania SCOU, P.O. Box 69112, Harrisburg, Pa 17106-9112 INADDITION, PA YMENTS MUSTINCWDE 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 MAll, BY THE COURT: Jvj)C::,t:: Form EN-028 Worker ID $IATT Date of Order:--JAN ':2 QZOil3 EoW!'TteO 6, Service Type M !ITil1AILED,No.o97o-Q1S4 /-rJ9-c)j DIY {p ........... '."- -- LV. .,'...." [I :~, ",. .... 1 ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If.~hecked youhare requhired. to prpvi(Je a copy of this form to your employee. If your employee works in a state. that is dltterent from- testate t at--Issued this order, a copy must be provided to your employee even if the box is not checked. 1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned businesses located on a reservation that choose to withhold in accordance with this notice. 2. Priority: Withhoiding under this Order/Notice has priority over any other iegal process under State iaw 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 iisted below. 3. Combining Payments: You can co(l1bine withheld amounts from more th<!n one employe~obligor's income.in a singie payment to each <!genc;y requestirig withholpirig. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. . 4. * Re"0,lil1gtJ.,ra,datelDate ofWill,l,oldi"g. '(ou ",",t 1~,,6It tho pa,datefdate of ..it"holdil ,g ..1,~1o '"Iodilog II" "a,m", ,t. TI," paydMe!dAM of vvitLIIO!dillg i~ till; date 011 VVllicll allloulIL vvas vvitl.Ldd h01l1 tile ellltJloyee's vvages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 5. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against thisemployee!obligorand you are unabletohonor ailsupport Order/Notices dueto Federal or Statewithholding limits, you.must follow the law of the state of elTiployee'S/obligbr's principai place of employment. You must honor all Orders/Noti.ces to the greatest extent possible. (See #10 below) .' . . 6. Termination Notification: You must promptiy 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 10: 9901100173 . EMPLOVEE'S/OBUGOR'SNAME: DEW. WILLIAM H. EMPLOYEE'S CASE IDENTIFIER: 7375100880 DATE OF SEPARATION: LAST KNOWNHQMEAD.DRESS: NEW EMPLOYER'S NAME/ADDRESS: 7. Lump Sum PaYments:, You may be ;equired 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. 8. Liability: If you fail to withhold inc()me <!s the Order/Notice directs, you are liable for both the accumuiated amount you should have withheld from the employee/obligor's income .ndother penalties set by Pennsylvania State law. Pennsylvania State law govelTis unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. Anti-discrimination:You .are subject to a fine determined under State lawfor discharging an employee/obiigor from employment, refusing to employ; ortakingdisciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs' unless the obligorisemployed in another State, in which case the law of the State in which he or she is employed governs. 10. * Withholding Limits: You m<!y n~twithhold lTiore than the lesser of: 1) the amounts allowed by theFederal Consumer Credit Protection Act (15 U.S;C!j1673. (b)1; or 2) the amounts allowed by the State of the employee's/obligQr's principal placeof empioyment. 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. 11. Additional Info: *NOTE: if you or your agent are serVed with a copyolthis order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Su~rnitted By: .. . II you or youremployeelobligor.have any questions, DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT 13 N. HANOVER ST by telephone at (7171 240-6225 or .~,O. BOX320 by FAX at (717) 240-6248 or CARLlSLEPA 17013 . by internet www.childsupport.state.pa.us Page 2 01 2 Form EN-028 Worker.ID $IATT Service Type M OMBNo.:0970-01S4 :f~mll;i-il!~j~~~,,"J1~~ii~j;";';j,:;',j"~"'-"I~*'''!J>i1,'.~!<ir!ir<L'5i.il'''"iIo",-"""':::f."",,,,,,'S,",cl,,,_'~I:-,";'" ~",,~i$ii;;j:",Hht'i_""iii>N~~,,&~ja!Ql\}lIiU,_~~~ll"-rl~ ,:-:'l '"' I....'J .,-. ,-,.,-~ ~,. , ~-~.~~ ,~~, =-,~="' ~, r T ,~ .r- ~ " r () Cl r., C eJ ~-' ~ ~, ri2 t1.:r - .~ :0;-:" _11'1-1 ~~ ; ~ -:,'] Z::n ~~-~ W rn (::> .:~{~~ ,/ ~C) "-0 )> ~~~~ --~O ::y.;: ~e Pc C- Om Z ):;' ~ (n ~ fjf -~ ~"~-~. " -~ -~ -"'-, ' - ,'- - ,,> , . ~-, w "^ _ '~ ' >, - _', ',-..' , . :,--, ,,-- ,,' ,.;" ", .,..,',,;, ", -.' ,;, ~'-~;': - -..",,-,~ ~ . -"",1 . , , , .. KATHLEEN K. ZIMMERMAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CNIL ACTION - LAW v. : NO. 01-3321 CNIL TERM DONALD R. ZIMMERMAN, Defendant : IN DNORCE ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff, in the above matter, having been granted a Final Decree in Divorce on the 20th day of February, 2002, hereby elected to retake and hereafter use her former name of Kathleen Lewis Kohlhaas, and gives this written notice avowing her intention in accordance with the provision of 54 Pa.C.S.A. g704(a). Date: ~-'1-o~ 11au~Kj~~ Kathleen K. Zimme an TO BE KNOWN AS: ~:t4 {)JiJJJASJ()~ Kathleen Lewis Kohlhaas " c_ ,-,'. , ~ ,--" ,'"-' , ,--"" " ,~. _,-'';''~ """_'_0;' , - ,.-"",'"-,:-,-'", ", '. ',-",', ~--,' ',' - 4";___ - COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND AFFlDA VIT On the ~ day of ~u \M:\- personally appeared Kathleen K. Zimmerman, known to me to be the person whose name is , 2002, before me, a Notary Public, subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. NOTARIAL SEAL PATRICIA A. PA TION, Notary Public Lower Paxton Twp., Dauphin County M Commission Expires June 20. 2006 ~~_~_r~bi<i2lci~~"liaiiliIiMj@'-"~~"4i,,'~~~*JD~:~~""'~"';"lMI"i.~iJLl.Mfuil.-- ~i.' U,!lil ,', ~-"" ~ iQ. 0 ::) ~ ~ c " ~;: -;:yo 8 -olT r:: rnr'Ti '" z-c -.- -- ~ 21'''. \.0- ,,~, lU ~l~(' -'~; r) r:::c; -u "':J -.. -U 5C,1 .:;, cO; ...... '-' ~6 .-~.o:: \i"1 f' W u ~ ~c "~---I 7' ..,"", -l- ::i Iv ~ ~5" k'P ~~ -, - ~; '-l~'~ SAlOIS SHUFF, FLOWER & LINDSAY ATfORNEYS-AT-LAW 26 W. High Street Carlisle, PA ......""...;( ~< DENISE M. DEW : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 01-3293 CIVIL TERM Plaintiff V5. WILLIAM H. DEW, Defendant : IN DIVORCE NOTICE OF INTENTION TO RESUME PRIOR NAME NOTICE IS HEREBY GIVEN that DENISE M. DEW, Plaintiff the in the above matter, having been granted a Final Decree in Divorce on February 5, 2003, hereby intends to resume and hereafter use the previous name of DENISE M. SWANK, and gives this written notice avowing her intention in accordance with the provisions of the Act of April 2,1980, P.L., 23 P.S. 702, effective July 1,1980. '-) ~7nl(kJ- Denise M. Dew, Petitioner TO BE KNOWN AS: iJe,.,uhllYJ.l,17'1 AI' t ) Denise M. S~~'~~ COMMONWEALTH OF PENNSYLVANIA 5S. COUNTY OF CUMBERLAND ON this, the Ii day ~ 4..~ ' 2003, before me, a Notary Public, personally appeared DENISE M. DEW, tI a, DENISE M. SWANK, known to me or satisfactory 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. NOTARIAL SEAL ~ I<ANOIL LENKER, NOTARY PUBLIC CARLISLE BORa. CUMBERLAND COUNlY MYCOMMISSION EXPIRES FEBRUARY 20, 2005 . ;?' Notary Public . II L ,<:::;>t;,,::,~,__~,:;-,::~~Ml~~~k~~~j,''''''~~'7MIi1!~@i;~;J$.lt~'~it ..............,\,'"'" ~' ~~.i,'_ ,."",,~_q ~ - - -,-,",,"._',~ ~~- ~"' p- ~ . --illlllil< - ,~~ ~~,~ b';' .'._""",, --", -, ~'-, I ~ ~ (") 1 ~ -lq c '" -C'J ~ l:"Ji:i i~l fit;;' '~"-' & ":"-.-,. i"-..") 2';- "'- ell, C:' W "'- -'-. ~ -t ~ ~.~ ::':~ -:'---;-'1 !J --.0 .-: (:~) () s>c; 9 ~)fT~ .~".I \y~ Z -:,0 'p~ '--1 ::r.J -, '0 -< ~ ~ SAlOIS SHUFF, FLOWER & LINDSAY AlTORNEYS-A"'LAW 26 W. High Street Carlisle, PA DENISE M. DEW VS. WILLIAM H. DEW, To the Prothonotary: -," ,,- -,," .,' ',""','.' ",_,,',<,_i__ ;''''"'.-;y, -,~ ,k'---:,"-,_,,,,:-'__" "'-"~ :.;.-',..'C :"-;'x>~",: _' .,]"'_ _, -, ~':, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW NO. 01.3293 CIVIL TERM Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301 (c) 2201 (el)(1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Certificate of service filed June 18,2001. 3. II (Complete either paragraph (a) or (b)). (a) Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the Plaintiff January 23. 2003; by the Defendant January 17, 2003. (1) Dote ef 8)cocutian af tt-le Plaintilfs affidavit reEjlolir-od by Scali en 2291 (d) aftt-le DivorGe Ceele: (2) Dote ef service ef tt-le Plointilfs a#iaa'lit u~en the Defenelant: Related claims pending: None Complete either (a) or (b). (a) Dote ana A'lonner af serviss af tt-le netice af intention te file praecipe Ie IFSnsA'lit Fesara, a se~y of v:t-list-l is attast-led: (b) 4. 5. (b) Date Plaintiff's Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: January 28, 2003 Date Defendant's Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: January 28, 2003 i.i~~.~~I'~W~<k"'~'~~"l\Mt,,~:ojijf;iA"-eli&'~!>'''',I%~''''il-i.,,"~Mi~#<l;l~i,~~iIIi.i(~~"__1i: (';5 k~ -'''''~~r~, 'C~,.~,' ~" ~ ~ ~~" ~~ ,", ^ <',^ " -< 'w';';~o (") r- "'= VdJ' [p"'/ ;<::7 05,,!-c, ;:s;<.~' , -,-, 'ii,-, ::?c' ~(,) >:: <: :::;f c..., "- ,. ~L c:::, r..S :0 r:; ~ ;;,:~ c.J <::> :J;,. ~ - - f5~J ~ ;:0 '" " ~ .~ ,-,~ "~) ~-, 0" ".-:1~,~~,",-.~ ,'~H"-' -~;""".' -> ,;,d..;', "' .'-;<,: . ' . Of. Of. :t: :t::t: . .. . . ,., :t::f. :t: . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . PENNA. . STATE OF . DENISE M. DEW, . . Plaintiff No. 01-3293 CIVIL TERM . . VERSUS IN DIVORCE WILLIAM H. DEW, . Defendant . . DECREE IN DIVORCE . . AND NOW, f" lr".n..... S \ DENISE M. DEW , PLAINTIFF, , 700.3, IT IS ORDERED AND . . . DECREED THAT . . WILLIAM H. DEW , DEFENDANT, AND . ARE DIVORCED FROM THE BONDS OF MATRIMONY. . . THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . . . . . . NONE, ~he terms of the Separation and Property Settlement Agreement dated October 15, 2002, and the Addendum thereto dated January 29, 2003, are incorporated but not merged into this Decree in Divorce. . . . . . . . . ATTES . PROTHONOTARY . . :t: :t::t::t: . . J. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i, , i1 II [I " _ 'I!mII,1Il T ~ ,;J 7 0' , .....-) ,;} , 7 ") 't):> '"~^ ,~ ",.., ,-.'~,'~"w.'r_"-",_'_', ~"^" "'" ". .- ,~," ,~ -,'.',N ~~ , _",_"' , _ ,_:=~"" ,!MJliI'!!~a.~P~IIWf1'1l!I!Mj'$,!!~;;m;"':;f'nll~""~_'~~";'f!R'~~~!~'J"'''(I[l,~~rl.!I:n!'1~~~ ~_~<iU;!!1] (~/:~7 :'U~. ~~~~~ 77t'ticA jft~( :7'df ?I){~~