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Home My WebLink About01-5961 - ERIC S. KROH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 0\ - $91./ elu~l~~ TAMMI S. KROH, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree of Divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the office of the Prothonotary . IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Cumberland County Bar Association Two Liberty Avenue Carlisle, PA 17013 (717) 249-3166 . . ERIC S. KROH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 01- Sql.J C~u,'l 'T~ TAMMI S. KROH, Defendant CIVIL ACTION - LAW DIVORCE COMPLAINT COUNT 1 - DIVORCE AND NOW comes Plaintiff, ERIC S. KROH, by his attorney, Kathy M. Shughart, and files this Complaint, based upon the following: I. Plaintiff, ERIC KROH, born July 30, 1965, is an adult individual and national of the United States of America, who currently resides at 604 A Herrin Lane, Enola, Cumberland County, Pennsylvania. 2. Defendant, TAMMI S. KROH, born October 17, 1967, is an adult individual and national of the United States of America, whose last known address is 604 A Herrin Lane, Enola, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant were married on October 28, 1989 in Summerdale, Cumberland County, Pennsylvania. 4. The parties have three minor children. Justin M. Kroh, born December 6, 1986; Jared A. Kroh, born June 20,1990; and Cassidy J. Kroh, bom September 22,2000. 5. Plaintiff and the parties' minor children have been bona fide residents of this Commonwealth for at least six (6) months immediately prior to the filing of this Complaint. 6. Defendant is not presently a member of the Armed Forces on active duty. Plaintiff is not presently a member of the Armed Forces on active duty. 7. There are no pending actions in divorce or annulment in this jurisdiction or in any other jurisdiction brought by either Plaintiff or Defendant above-named. - - 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. Plaintiff avers that the marriage is irretrievably broken. 10. The parties have been living separate and apart. At a subsequent time, Plaintiff may submit an Affidavit that the parties have lived separate and apart for at least two (2) years. WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. DATE: I 10 ...\1...,0 \f\r::,- U----' Kathy M. Shu , Esquire Supreme Court ID #39779 27 South Arlene Street Post Office Box 6315 Harrisburg, P A 17112-0315 (717) 540-8511 ERIC S. KROH, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. TAMMI S.KROH, Defendant : CIVIL ACTION - LAW : DIVORCE VERIFICATION .. I, ERIC S. KROH,verify that the avel,'lIlents made in the within foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904, relating to unswom falsification to authorities. DATE: {o - 11-0 I ~~ 10 () ~'i - - _ 0 ~ - ...oJ CI) ~ >ofQ. ..... lrt~ .CI) c' C' fit ,0. rEV) r~ ~ J 8 0 :oS: - CfJFR g ~,:z:l --., Jq~:- ~ ~C) """ ;2:00 :.0 )> ~ ~ C,.) ~ ::; 0'1 ~ ~ 6 !i? .::-;1 .ni;Jl _-CJcn dD 1',6 ',5~ (jn1 g -< ItJ I- '" 0:: c 0 >- \0 ~ <( " oJ ~ '" J: ~ 0 - ~ - M ::::> Cl " ~ " u.J~2 -' z - ~ 0"; ::l I- ~ M 00 QC5 6~ J: " 00 ~ 6 :c 0 f+-, ,0 c... r')'::> en ,. I- ~ . J ..l._ W W 0 cj ~ ~t~ 'c. ;;:! Z w 00 1.0 ~( Cl) :E ~ z 0 (( ~ ,), . 0 0 ~ U.jl... .1,2: I- " 0: :J E:!";~ n:::Z >- I- 0 CD J-- u.Ju,J J: " . (J) w Q:!n.. l- . ir 0 w '" <( (( u. S ~ < c> 0 () J: . , ERIC S. KROH, Plaintiff IN THE COURT OF COMMON PLEAS OF C~ERLAND COUNTY, PENNSYLVANIA v. NO: 01-5961 CIVIL TERM TAMMI S. KROH, Defendant Civil Action - Law Divorce ACCEPTANCE OF SERVICE I hereby acknowledge that I was served a copy of the Complaint filed in the above-captioned Divorce action this07iJ t:b day of (9 C:to ~ ,2001. ~~\~ Tammi S. Kroh, Defendant '"t" 0 0 C) c.: -, , s: z -rj 0:.1 C> .'1-; mni to.:;::: I~~~ Z:n I i' 4r;:- CO '-( (jJ ". _ -<L_ -, s;) Gel v -- : '- P C) zO ----0 ':? , '" Pc: ~.j, Z 0 1~ =< ::0 ".., -< .Jr._ -. ERIC S. KROH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 01-5961 CIVIL TERM TAMMIS.KROH, Defendant CIVIL ACTION - LAW DIVORCE PETITION TO WITHDRAW AS COUNSEL Kathy M. Shughart, Esquire, counsel of record for ERIC S. KROH, Plaintiff in the above-captioned matter, petitions the Court to withdraw as counsel and in support thereof avers as follows: 1. The Plaintiff in the above-captioned matter is ERIC S. KROH, an adult individual residing at 604A Herrin Lane, Enola, Cumberland County, Pennsylvania. 2. The Defendant in the above-captioned matter, TAMMI S. KROH, is represented by Maria P. Cognetti, Esquire. 3. Petitioner is Kathy M. Shughart, Esquire, counsel of record for Plaintiff, ERIC S. KROH. 4. Plaintiff notified Counsel that he would be retaining new counsel, and on or about July 21,2003, the Plaintiff picked up his file and signed a Release terminating the attorney/client relationship with Kathy M. Shughart, Esquire. A copy of said Release is attached hereto and incorporated by reference herein as "Exhibit A". ,. 5. To date, an appearance has not been entered by new counse1. 6. Neither Plaintiff nor Petitioner desires for the attorney--client relationship to continue. WHEREFORE, Kathy M. Shughart, Esquire, respe(;tfully requests this Honorable Court to issue a Rule upon Plaintiff, ERIC S. KROH, to show cause why Kathy M. Shughart, Esquire, should not be permitted to withdraw as (;ounse1. Respectfully submitted, 17112 ." RELEASE I, Eric S. Kroh, hereby acknowledge that I have received my entire file from Kathy M. Shughart, Esquire, this ;;;. r ST day of July, 2003. Further, I hereby confirm that I wish to terminate the attorney/client relationship with Kathy M. Shughart, Esquire. ~~r# ~r "EXHIBIT A" .' VERIFICATION I, Kathy M. Shughart, Esquire, verify that the statements made in this Petition to Withdraw as Counsel are true and correct. I understand that false statements herein are made subject to the penalties of Pa. C.S. 4904 relating to unsworn falsification to authorities. / / VJ;,.~~ M. SHUGHART:, ESQUIRE . (') ':"~ () C - -" :~ -- .".. ,J CJ..' __~.l "" no, Z .>. 2: C (f) .' ._J -< r::; .~{.J -c.. 5:C' -'CI td ) )> -- L- ~':"'I :z: ::> ...,.,,,. =< :q (P -<. " . NO\' 1 2. 2003 ~ VI VS. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-5961 CIVIL TERM ERIC S. KROH, Plaintiff TAMMI S. KROH, Defendant : CIVIL ACTION - LAW : DIVORCE RULE TO SHOW CAUSE AND NOW, this ;- 1"1 day of ~ , 2003, upon consideration of the attached Petition to Withdraw as Counsel, a Rule is issued upon Plaintiff, ERIC S. KROH, to show cause why Kathy M. Shughart, Esquire, should not be permitted to withdraw as counsel. RULE RETURNABLE z-t> DAYS FROM SERVICE. BY THE COURT: /J) J. .~.-Jy ~6\~~<>) ~ V" \>:.\) ~" . . . V!\\!\f,\"1~SNN3d '\!\l,~r,'" ",liC1-','1'r,'r\" l\...Jil)\,."..} "" ....".,:.j(_,.,.-" V o \ : \ \ \1~ i1 \ lION SO )\cNJ.U>~\)!";l.-"-'c.>.. ::.J() 38L'l~;O'<I)'.\\J ~/ ~, ERIC S. KROH, Plaintiff v. TAMMI S. KROH, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTy, PENNSYLVANIA : NO. 01-5961 CIVIL TERM : CIVIL ACTION"_ LAW : IN DNORCE CERTIFICATE OF SERVICE I hereby certify that on this 17th day of November, 2003, a true and correct copy of the Petition to Withdraw as Counsel was served on the following person by United States Mail, postage Prepaid, addressed as follows: Maria P. Cognetti, Esquire 2 I 0 Grandview Avenue Suite 102 Camp Hill, P A 17011 Eric S.Kroh 604A Herrin Lane Enola, P A 17025 Respectfully submitted, / L/", M. h....,~U- I.D. No.3 779 27 South Arlene Street P.O. Box 6315 Harrisburg, PA 17112-0315 (717) 540-851 I (') ~c So ..O() rnn', :z :l~ Z\:: S2:'; r:; ~~- ~(' /-,-,;- j>'c. L. ;2" ':3 -'. o c.._> ?": c~ "'- o --n (~.::- rT1 \.0 'r .'~~ .~r') ;:srn -.-l 51 '< -0 ~ w MUuuTALSETTLEMENTAGlmEMENT BY AND BETWEEN ERIC S. KROH AND TAMMIS.KROH John 1. Connelly, Jr., Esquire JAMES, SMITH, DIETTERlCK & CONNELLY LLP P.O. Box 650 Hershey, PAl 7033 Telephone: (717) 533-3280 Counsel for Eric S. Kroh MARITAL SETTLEMENT AGREEMENT TillS AGREEMENT, made this IqJi day of c/;Jr A j 1..- , 2004 by and between ERIC S. KROH, of Cumberland County, PenllSylvania, an~ TAMMI S. KROH, of Cumberland County, Pennsylvania. WITNESSETH: WHEREAS, Eric S. Kroh (hereinafter called "Husband") currently resides at 604A Herrin Lane, Enola, Cumberland County, PennsylVania 17025; WHEREAS, Tammi S. Kroh (hereinafter called "Wife") currently resides at 137 Tory Circle, Enola, Cumberland County PennsylVania 17025; WHEREAS, the parties hereto are husband and wit:e, having been lawfully married on October 28, 1989; WHEREAS, the parties have lived separate and apart since on or about March 15,2002; WHEREAS, three children were born of the marriage between the parties, namely, Justin M. Kroh, born December 6, 1986; Jared A. Kroh, born June 20, 1990; and Cassidy J. Kroh, born September 22, 2000; WHEREAS, the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation, the settling of all matters between them relating to the ownership of real and personal property, the support and maintenance of one another and, in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. NOW THEREFORE, in consideration of these premises, and of the mutual promises, COVenants and undertakings hereinafter set forth, and for other good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged by each of the parties hereto, Husband and Wife, each intending to be legally bound hereby, COvenant and agree as follows: 1. PERSONAL RIGHTS. Husband and Wife may, at all times hereafter, live separate and apart. Each shall be free from all control, restraint, interference and authority, direct or 1 indirect by the other. Each may reside at such place or places as he or she may select. Each may, for his or her separate use or benefit, conduct, carry on or engage in any business, occupation, profession or employment which to him or her may seem advisable. Husband and Wife shall not molest, harass, disturb or malign each other, nor compel or attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with him or her. Neither party will interfere with the use, ownership, enjoyment or disposition of any property now owned by or hereafter acquired by the other. 2. ADVICE OF COUNSEL. Each party acknowledges that he or she has had the opportunity to receive independent legal advice from counsel of his or her selection. Husband has secured legal advice from John J. Connelly, Jr., Esquire, his counsel. Wife is unrepresented by counsel and has the right to have the Agreement reviewed by counsel of her choosing. Each party fully understands the facts and his or her legal rights and obligations, and each party acknowledges and accepts that this Agreement is, in the circumstances, fair and equitable, and that it is being entered into freely and voluntarily, and that the execution of tins Agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal agreement or agreements. In addition, each party understands the impact of the Pennsylvania Divorce Code, whereby the court has the right and duty to determine all marital rights of the parties including divorce, alimony, alimony pendente lite, equitable distribution of all marital property or property owned or possessed individually by the other, counsel fees and costs of litigation and, fully knowing the same, each party hereto still desires to execute this Agreement acknowledging that the terms and conditions set forth herein are fair, just and equitable to each of the parties, and waives his and her respective right to have the Court of Common Pleas of Cumberland County, or any other court of competent jurisdiction, make any determination or order affecting the respective parties' rights to alimony, alimony pendente lite, support and maintenance, equitable distribution, counsel fees and costs oflitigation. 3. DISCLOSURE OF ASSETS. Each of the parlies hereto acknowledges that he or she is aware of his or her right to seek discovery including, but not limited to, written interrogatories, motions for production of documents, the taking or oral depositions, the filing of 2 inventories and all other means of discovery permitted under the Pennsylvania Divorce Code or the Pennsylvania Ru1es of Civil Procedure. Each of the parties :furtber acknowledges that he or she has had the oPPOrtunity to discuss with counsel the concept of marital property under Pennsylvania law and each is aware of his or her right to have the real and/or personal property, estate and assets, earnings and income of the other assessed or evaluated by the courts of this Commonwealth or any other court of cornpetent jurisdiction. The parties do hereby acknowledge that there has been full and fair disclosure to the other of his or her respective income, assets and liabilities, whether such are held jointly, in the name of one party alone or in the illlII1e of one of the parties and another individual or individuals. Each party agrees that any right to :further disclosure, valuation, appraisal or enumeration or statement thereof in this Agreement is hereby specifically waived, and the parties do not wish to make or append hereto any further enumeralion or statement. Specifically, each party waives the need for copies of bank statements, insurance policies, retirement plan statements or any other documentation. Each party Warrants that he or she is not aware of any marital asset which is not identified in this Agreement. The parties here:by acknowledge and agree that the division of assets as set fortb in this Agreement is fair, reasonable and equitable, and is satisfactory to them. Each of the parties hereto further covenants and agrees for himself and herself and his or her heirs, executors, administrators or assigns, that he or she will never at any time hereafter sue the other party or his or her heirs, executors, administrators or assigns in any action of contention, direct or indirect, and allege therein that there was a denial of any rights to full disclosure, or that there was any fraud, duress, undue influence or that there Was a failure to have available full, proper and independent representation by legal counsel. 4. MUTUAL CONSENT DIVORCE. It is the intention of the parties, and the parties agree, that by this Agreement they have resolved all ancillary economic issues related to the dissolution of their marriage and thus any divorce action witll respect to these parties shall be limited to a claim for divorce only. Husband has filed a Diivorce Complaint in the Court of Common Pleas Cumberland County, Pennsylvania, indexed to No. 01-5961. The parties agree that they will each execute an Affidavit of Consent and Waiver of Notice of Intention to Request Entry of Divorce Decree in order that counsel for Husband may finalize the divorce action in a timely 3 fashion. Upon completion of the divorce action, counsel for Husband shall supply Wife with a copy of the Decree. 5. EOUITABLE DISTRIBUTION. A. Real Estate The parties were previously the joint owners of a property located at 604A Herrin Lane, Enola, Cunrberland County, Pennsylvania. In May of 2002, Husband refinanced the said property and paid to Wife the sum of $8,000.00 representing her equitable distribution of the marital real estate. This payment to Wife took into account the assumption of significant debt which is more particularly set forth herein. Subsequent to the refinancing, Wife has transferred title to the aforementioned residence to Husband individually and agrees that she will make no further claim to the property. Husband agrees to indenrnify and hold Wife harmless on any obligations relating to the property which is now titled in his name individually. There is currently a mortgage against the property in Husband's name only in the approximate amount of$ I 42,000.00 payable to Wells Fargo. B. Fumishinl!:s and Personalty. The parties agree that they have divided by agreement between themselves all furnishings and personalty located in the Marital Residence, including all furniture, furnishings, antiques, jewelry, rugs, carpets, household appliances and equipment. Accordingly, Husband shall retain sole and exe1usive ownership of all furnishings and personalty currently in his possession, free and clear of any right, title, claim and/or interest of Wife and Wife shall retain all items of furnishings and personal property currently in her possession as her sole and separate property free and clear of any right, title, claim and/or interest of Husband. C. Motor Vehicles. At the time of the separation of the parties, Husband retained ownership of the 1994 Pathfinder which he has since traded. Wife retained ownership of the 2002 Cavalier which she also has traded for a new vehicle. Both parties shall retain the proceeds of the vehicles identified herein traded by the respective party. D. Life Insurance. Each of the parties are owners of life insurance policies through Prudential. The said policies are being retained by the individual who is the named owner including any cash values contained in the policies. 4 E. Pension and Retirement Benefits. Husband is the owner of a 40 I (k) through his employer, Verizon Wireless, which shall remain his sole and separate property. At the time the parties separated, Wife did not have a pension plan. At the current time, she has pension benefits through her employer, Highmark, which shall be retained by her as her sole and separate property. F. Miscellaneous Property. As of the execution date of this Agreement, any and all property not specifically addressed herein shall be owned by the party to whom the property is titled; and if untitled, the party in possession. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property from each to the other. G. Property to Wife. The parties agree that Wife shall own, possess, and enjoy, free from any claim of husband, the property awarded to her by the terms of this Agreement. Husband hereby quitclaims, assigns and conveys to Wife: all such property, and waives and relinquishes any and all rights thereto, together with any insurance policies covering that property, and any escrow accounts relating to that property. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property from Husband to Wife. H. Property to Husband. The parties agree that Husband shall own, possess, and enjoy, free from any claim of Wife, the property awarded to him by the terms of this Agreement. Wife hereby quitclaims, assigns and conveys to Husband all such property, and waives and relinquishes any and all rights thereto, together with any insurance policies covering that property, and any escrow accounts relating to that property. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property from Wife to Husband. I. Marital Debt. Husband has assumed all marital debt of the parties including, but not limited to, Waypoint Visa, MBNA Visa, a home equity loan with Waypoint Bank which was paid off at the initial refinancing in May of 2002 and the personal loan at M&T Bank. Husband has paid off all marital debt with the exception of the balance on the Waypoint Visa 5 which currently is approximately $6,500.00. As to the unpaid Waypoint Visa balance, Husband agrees to indemnify and hold Wife harmless on the said obligation. J. Liability not Listed. Each party represents and warrants to the other that he or she has not incurred any debt, obligation or other liability, other than those described in this Agreement, on which the other party is or may be liable. A liability not disclosed in this Agreement will be the sole responsibility of the party who has incurred or may hereafter incur it, and such party agrees to pay it as the same shall become due, and to indemnify and hold the other party and his or her property harmless from any and all debts, obligations and liabilities. K. Indemnification of Wife. If any claim, action or proceeding is hereafter initiated seeking to hold Wife liable for the debts or obligations assumed by Husband under this Agreement, Husband will, at his sole expense, defend Wife against any such claim, action or proceeding, whether or not well-founded, and indemni~( her and her property against any damages or loss resulting therefrom, including, but not limited to, costs of court and actual attorney's fees incurred by Wife in connection therewith. L. Indemnification of Husband. If any claim, action or proceeding is hereafter initiated seeking to hold Husband liable for the debts or obligations assumed by Wife under this Agreement, Wife will, at her sole expense, defend Husband against any such claim, action or proceeding, whether or not well-founded, and indemnify him and his property against any damages or loss resulting therefrom, including, but not limited to costs of court and actual attorney's fees incurred by Husband in connection therewith. M. Warranty as to Future Oblil!ations. Husband and Wife each represents and warrants to the other that he or she will not at any time in the future incur or contract any debt, charge or liability for which the other, the other's legal representatives, property or estate may be responsible. From the date of execution of this Agreement, (:ach party shall use only those credit cards and accounts for which that party is individually liable and the parties agree to cooperate in closing any remaining accounts which provide for joint liability. Each party hereby agrees to indemnify, save and hold the other and his or her property harmless from any liability, loss, cost or expense whatsoever, including actual attorneys fees, incurred in the event of breach hereof 6 6. SUPPORT/ALIMONY. Except as provided below, Husband and Wife hereby expressly waive, discharge and release any and all rights and claims which he or she may have now or hereafter by reason of the parties' marriage to alirnony, alimony pendente lite, spousal support and/or maintenance or other like benefits resulting from the parties' status as husband and wife. Except as provided herein, the parties further release and waive any rights they may have to seek modification of the terms of this paragraph in a court of law or equity, it being understood that the foregoing constitutes a final determination for all time of either party's obligation to contribute to the support and maintenance of the other. There is currently a Support Order in place through the Court of Common Pleas, Cumberland County, Pennsylvania, indexed to PACSES No. 097104948 in the amount of $1,142.82 per month representing $386.84 per month in spousal support for Wife and $755.98 in child support for Cassidy J. Kroh. The child support payment for Cassidy takes into account the fact that Husband has custody of the parties minor children, Justin M. Kroh and Jared A. Kroh. This payment of child support also takes into account the daycare expense for Cassidy. Beginning June 1, 2004, Husband agrees to pay to wife the sum of $400.00 per month in alimony. Husband will take steps through his counsel to have the Support Order modified to delete spousal support and enter the Alimony Order as aforementioned effective June 1, 2004. The child support payment will remain $755.98 per month. In addition to the aforementioned child support, Husband will pay to Wife, within ten (10) days of receipt, 17.7% of any net bonus received by him from his employer. These payments shall be made to Wife directly and shall include documentation of Husband's gross bonus and his net bonus in order that Wife may confirm the 17.7% figure is accurate. Any provisions regarding the payment of bonus contained in the existing Order of Court shall be terminated and replaced by these provisions. The said alimony payments shall terminate upon the death of either party, Wife's remarriage or cohabitation. In addition, all alimony payments paid pursuant to this paragraph are to be deducted by Husband on his federal income tax returns and claimed by Wife as income on her federal income tax returns. 7 The child support and alimony payments shall bf: subject to modification or termination based on a change in circumstances, which would include, but not be limited to, the amount of the payment, daycare contribution, medical insurance contribution or percentage of bonus payments. In no event, shall the alimony award be modified to include any percentage of Husband's bonus. The percentage of bonus payments shall only apply to child support in the event of modification. 7. WAIVER OF INHERITANCE RIGHTS. Unless otherwise specifically provided in this Agreement, as of the execution date of this Agreement, Husband and Wife each waives all rights of inheritance in the estate of the other, /my right to elect to take against the will or any trust of the other or in which the other has an interest, and each of the parties waives any additional rights which said party has or may have by reason of their marriage, except the rights saved or created by the terms of this Agreement. This waiver shall be construed generally and shall include, but not be limited to, a waiver of all rights provided under the laws of Pennsylvania, or any other jurisdiction. 8. WAIVER OF BENEFICIARY DESIGNATION. Unless otherwise specifically set forth in this Agreement, each party hereto specifically waives any and all beneficiary rights and any and all rights as a surviving spouse in and to any asset, benefit or like program carrying a beneficiary designation which belongs to the other party under the terms of this Agreement, including, but not limited to, pensions and retirement plans of any sort or nature, deferred compensation plans, life insurance policies, annuities, stock accounts, bank accounts, final pay checks or any other post-death distribution scheme, and each party expressly states that it is his and her intention to revoke by the terms of this Agreement any beneficiary designations naming the other which are in effect as of the date of execution of this Agreement. If and in the event the other party continues to be named as beneficiary and no altemate beneficiary is otherwise designated, the beneficiary shall be deemed to be the estate of the deceased party. 9. RELEASE OF CLAIMS. A. Wife and Husband acknowledge and agree that the propertY dispositions provided for herein constitute an equitable distribution of their assets and liabilities pursuant to 8 S3502 of the Divorce Code, and Wife and Husband hereby waive any right to division of their property except as provided for in this Agreement. FUrlhermore, except as otherwise provided for in this Agreement, each of the parties hereby speciiCically waives, releases, renounces and forever abandons any claim, right, title or interest whatsoever he or she may have in property transferred to the other party pursuant to this Agreement or identified in this Agreement as belonging to the other party, and each party agrees never to assert any claim to said property or proceeds in the future. The parties have divided between them to their mutual satisfaction, personal effects, household goods and furnishings and all other articles of personal property which have heretofore been used in common by them, and neither party will make any claim to any such items which are now in the possession or under the control of the other. Should it become necessary, each party agrees to sign any title or documents necessary to give effect to this paragraph, upon request. However, neither party is released or discharged from any obligation under this Agreement or any instrument or document (~xecuted pursuant to this Agreement. Husband and Wife shall hereafter own and enjoy independently of any claim or right of the other, all items of personal property, tangible or intangible, acquired by him or her from the execution date of this Agreement with full power in him or her to dispose of the same fully and effectively for all purposes. B. Each party hereby absolutely and unconditionally releases and forever discharges the other and the estate of the other for all purposes from any and all rights and obligations which either party may have or at any time hl:rreafter has for past, present or future support or maintenance, alimony pendente lite, alimony" equitable distribution, counsel fees, costs, expenses, and any other right or obligation, economi.c or otherwise, whether arising out of the marital relationship or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, its supplements and amendments, as well as under any other law of any other jurisdiction, except and only except all rights and obligations arising under this Agreement or for the breach of any of its provisions. Neither party shall have any obligation to the other not expressly set forth herein. 9 C. Except as set forth in this Agreement, each party hereby absolutely and unconditionally releases and forever discharges the other and his or her heirs, executors, administrators, assigns, property and estate from any and all rights, claims, demands or obligations arising out of or by virtue of the marital relationship of the parties whether now existing or hereafter arising. The above release shall be, effective regardless of whether such claims arise out of any former or future acts, contracts, engagements or liabilities of the other or by way of dower, curtesy, widow's or widower's rights, family exemption or similar allowance, or under the intestate laws or the right to take against th,e spouse's will, or the right to treat .a lifetime conveyance by the other as testamentary or aU other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory of the United States, or any other country. D. Except for the obligations of the parties contained in this Agreement and such rights as are expressly reserved herein, each party gives to the other by the execution of this Agreement an absolute and unconditional release and discharge from all causes of action, claims, rights or demands whatsoever in law or in equity, which either party ever had or now has against the other. 10. PRESERVATION OF RECORDS. Each party will keep and preserve for a period of four (4) years from the date of their divorce decree all financial records relating to the marital estate, and each party will allow the other party access to those records in the event of tax audits. 11. MODIFICATION. No modification, rescission, or amendment to this Agreement shall be effective unless in writing signed by each of the parties hereto. 12. SEVERABILITY. If any provision of this Agreement is held by a court of competent jurisdiction to be void, invalid or unenforceable, the remaining provisions hereof shall nevertheless survive and continue in full force and effect without being impaired or invalidated In any way. 13. BREACH. If either party hereto breaches any provision hereof, the other party shall have the right, at his or her election, to sue for damages for such breach, or seek such other 10 remedies or relief as may be available to him or her. The non-breaching party shall be entitled to recover from the breaching party all costs, expenses and legal fees actually incurred in the enforcement of the rights of the non-breaching party. 14. WAIVER OF BREACH. The waiver by one party of any breach of this Agreement by the other party will not be deemed a waiver of any other breach or any provision of this Agreement. 15. NOTICE. Any notice to be given under this Agreement by either party to the other shall be in writing and may be effected by registered or certified mail, return receipt requested. Notice to Husband will be sufficient if made or addressed to the following: Eric S. Kroh 604A Herrin Lane Enola, P A 17025 and to Wife, if made or addressed to the following: Tammi S. Kroh 137 Tory Circle Enola, PAl 7025 Notice shall be deemed to have occurred Upon the date received by the recipient. Each party may change the address for notice to him or her by giving notice of that change in accordance with the provisions of this paragraph. 16. APPLICABLE LAW. All acts contemplated by this Agreement shall be construed and enforced under the substantive laws of th(~ Commonwealth of Pennsylvania (without regard to the conflict oflaw rules applicable in Pennsylvania) in effect as of the date of execution of this Agreement. 17. DATE OF EXECUTION. The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which the parties signed the Agreement if they do so on the Same date, or if not on the same date, then the date on which the Agreement Was signed by the last party to execute this Agreement. 11 18. EFFECTIVE DATE. This Agreement shall become effective and binding Upon both parties on the execution date. 19. EFFECT OF RECONCILIATION. COHABITATION OR DIVORCE. This Agreement shall remain in full force and effect and shali! not be abrogated even if the parties effect a reconciliation, cohabit as husband and wife or attempt to effect a reconciliation. This Agreement also' shall continue in full force and effect in the event of the parties' divorce. There shall be no modification or waiver of any of the terms hereof unless the parties in writing execute a statement declaring this Agreement or any term ofthis Agreement to be null and void. 20. HEADINGS NOT PART OF AGREEMENT. Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. 21. AGREEMENT BINDING ON PARTIES AND HEIRS. This Agreement shall bind the parties hereto and their respective heirs, executors, administrators, legal representatives, assigns, and successors in any interest of the parties. 22. ENTIRE AGREEMENT. Each party acknowledges that he or she has carefully read this Agreement; that he or she has discussed its provisions with an attorney of his or her own choice, and has executed it voluntarily and in reliance upon his or her own attorney; and that this instrument expresses the entire agreement between thf: parties concerning the subjects it purports to cover and supersedes any and all prior agreements between the parties. This Agreement should be interpreted fairly and simply, and not strictly for or against either of the parties. 23. MUTUAL COOPERATION. Each party shall, on demand, execute and deliver to the other any deeds, bills of sale, assignments, consents to I~hange of beneficiary designations, tax returns, and other documents, and shall do or cause to be done every other act or thing that may be necessary or desirable to effectuate the provisions arid purposes of this Agreement. If either party unreasonably fails on demand to comply with these provisions, that party shall pay to 12 the other party all attorney's fees, costs, and other expensl:s actually incurred as a result of such failure. 24. AGREEMENT NOT TO BE MERGED. This Agreement may be incorporated into a decree of divorce for purposes of enforcement only, but otherwise shall not be merged into said decree. The parties shall have the right to enforce this Agreement under the Divorce Code of 1980, as amended, and in addition, shall retain any remedies in law or in equity under this Agreement as an independent contract. Such remedies in law or equity are specifically not waived or released. IN WITNESS WHEREOF, the parties hereto set their hands and seals on the dates of their acknowledgments. ~!)IW~~ ~~~ -f4 ....- t'~, ~Croh .. · r{aInvli.S~roVj Tammi S. Kroh WITNESS 13 G r-:; ..j "" C? {.~ --1~- (-,.- c:: f"- o -1 .-< ;F'~ , 'r p, ~:;-) () '1", -q ;:;-~:; I'd U'l -C' -r ':'1 C::J -.j ~'n -, ERIC S. KROH, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-5961 CML TERM T AMMI S. KROH, DEFENDANT : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSEl'i1T 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 16, 2001. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of both the filing and service of the Complaint. 3. I consent to the entry of a final decree of divome after service of Notice of Intention to request entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE Df1vORCE 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! do not claim them before a divorcf: 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 above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. ~4904, relating to unsworn falsification to authorities. Date: 1-/!J -o'f EriC~:i:ft (" (',: c' ~"- " :=, '"<: "" = = J:" C- r- I:;':; o ., .-1 :r: rll~ -0 rn :JJCI C)L _-:;C) " (OS-d '~5f,~ :~~~ ::~ en "D -,.~ = -' ERIC S. KROH, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLMID COUNTY, PENNSYLVANIA v. : NO. 01-5961 CIVIL TERM TAMMI S. KROH, DEFENDANT : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on October 16, 2001. 2. The marriage of the Plaintiff and Defendant is :irretrievably broken, and ninety days have elapsed from the date of both the 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. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER !l3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final Decree of Divon:e 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 divore<~ 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 irmnediately after it is filed with the Prothonotary. I verify that the statements made above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. S4904, relating to unsworn falsification to authorities. Date: /f-/3-oLf 0YalJ1vn,-~'S k-ro/; Tammi S. Kwh, Defemdant ...., = = .0- S r- o -n ..... :1:" n'r-::. -oil"! :tJc;:' 06 --l___. :c-H ;~? (~ ~m CJl ;?: o -.l ERIC S. KROH, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-5961 CIVIL TERM TAMMI S. KROB, DEFENDANT : CML ACTION - LAW : IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of John J. Connelly, Jr., Esquire on behalf of the Plaintiff, Eric S. Kroh, in the above-captioned action. JAMES, SMITH, DIETTERJCK & CONNELLY Date: 1-/1; -Dlf ...~ = = ..c- '- c~ l"~::: o .., ::r1 ["'ll:n ,- -Gfl1 :'.10 ,,::),,1., ~;~ ~~hl "" ~2 en " ;::i: = --.J ERIC S. KROH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-5961 CIVIL TERM TAMMI S. KROH, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT ~:ECORD To the Prothonotary: Transmit the record, together with the following infonnation, to the Court for entry of a Divorce Decree: 1. Ground for divorce: irretrievable breakdown under Section (XX) 3301(c) () 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: October 26, 2001 by Acceptance of Service. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consl~t and Waiver of Counseling required by Section 3301(c) of the Divorce Code: byPlaintifJ: July 13,2004; Defendant: July 13, 2004. (b) (1) Date of execution of the Plaintiff's Affidavit required by Section 3301(d) of the Divorce Code: (2) Date of service of the Plaintiff's Affidavit upon the Defendant: 4. Related claims pending: All claims of record have been settled pursuant to a Marital Settlement Agreement dated May 19, 2004. . 5. Date and manner of service of Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301 (d) of the Divorce Code: or, date of execution of Waiver of Notice of Intention to Request Entry of a Divorce Decree under Section 3301 (c) of the Divorce Code: by Plaintiff: July 13,2004; by Defendant: July 13, 2004. and, date of filing of the Waiver of Notice of Intention to Request Entry of a Divorce Decree: Both Waivers are being filed simultaneously with this Praecipe. JAMES, SMITH, DIETTERRICK & CONNELLY LLP Jo connell:~r., Esquire A orn f6r Pl;l' iff Pos ce~: 50 Hershey, PA 17033 (717) 533-3280 PA J.D. No. 15615 Date: 7-/3 -DJ./. S"2 ~. - '> ....., <= = .r' ~- c.= .-~ o .." ....{ :L fn;g 'Tlm C.:19 (-)6 :~J:..;:.J S~ ?~~ y :::'.J -< (.J1 ~ =:.... C" 00 . . . . . . IN THE COURT OF COMMON PLEAS . OF CUMBERLAND COUNTY STATE OF ERIC S. KROH, PENNA. . ;t (;08~ ,1iJ~IT IS ORDERED AND . . . . . . . . . . . . . . . . . . . . . . . . . . Plaintiff No. 01 - 5961 CIVIL TERM VERSUS TAMMI S. KROH, Defendant . DECREE IN DIVORCE AND NDW'~ DECREED THAT Eric S. Kroh . If- AND Tammi S. Kroh ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; The attached Marital Settlement Aqreement dated May 19, 2004 . . . . Divorc . is hereby incorporated, but not merged, into this Decree in o . ~ ....,_ _ i . -.. ..~-...~ .",- _.- ~." . '- .... "'v; , / " " '. / , - .... . .,. ~..J : . . . -~........... .,. '" . ~ .--,",,-, , / .... --: "- , 'J.. .'~":::- '0,' ,jo. , ..:..}" . -\" \:;.",- <::0.4......" 000000000000600000000 , ~ h tr=~. ,~( OTHONOTARY . . . . . . . . . . . . . . . . ~ z ~.~~ AC7''1(?,? ~ i? ~ ~ ~'PfJ ~C7,t!Je-3 -',' . ~ : ,-.',.,.....,' ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsvlvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 08/22/05 Case Number (See Addendum for case summary) o Original Order/Notice @ Amended Order/Notice o T€rminate Order/Notice EmployerNVithholder's Federal EIN Number RE, KROH, ERIC S. Employee/Obligor's Name (last, First, MI) 184-60-1960 Employee/Obligor's Social Security Number 5778101054 Employee/Obligor's Case IdentifIer (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (last, first, MO VERIZON WIRELESS C/O HR INNOVATIONS STE 1380 35 E WACKER DR CHICAGO IL 60601 ~I 9il"l !1 ~ ~S ()tJ7/0V9V~'( .fiJI ,PMsts ,;U~:)/ -59(;1 t! / .WL. <;90/675'97 See Addendum for dependent names and birth dates associated with cases on attachment. ORDER lNFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee'sfobligor's income until further notice even if the Order/Notice is not issued by your State. $ 1,155.98 per month in current support $ 0.00 per month in past-due support Arrears n weeks or greater? Oyes <Xl no $ 0 . 00 per month in current and past-due medical support $ 0 . DOper month for genetic test costs $ per month in other (specify) for a total of $ 1,155.98 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: $ 266 . 76 per weekly pay period. $ 533.53 per biweekly pay period (every two weeks). $ 577.99 per semimonthly pay period (twice a month). $ 1.155.98 per monthly pay period. REMITTANCE lNFORMA TlON: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee'sf obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1.877-676.9580 for instructions. Make Remittance Payable to: PA SCOU Send check to: Pennsylvania seou, 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 9se /d,enti~Q." a.~.~Qq{I.,.." ,. L SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. /,0""" Jl:;.<.c,,~i L ,,,,,,,jf,~ i-,;(3-(), 8YTHECOURT: Date of Order: r AUG 2 3 20D5~ &t)~ 5, (,L.JIl~6 7V t;; Form EN,028 Worker ID $IATT Servi ce Type M OMB No.: 097V-(J154 ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If ~hecked you are required to provide a copy of this form to your employee. If your employee works in a state that is ditterent from the state that issued this order, a copy must be provided to your employee even If the box is not checked. 1. Priority: Withholding under this Order/Notice has priority Over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3. * Rl;::!-'VIEllg tLe F'aydate/Ddte vf v\;'jtlrlroIJ;llg. YOll lIuBt lepOH tile payd.:.td'Jd'te of vvrtl,llvld;llg. Hlrell 5crrd;t1~ llle IJdyflJellt. The pdydateldate of vvr'lLI.old;1l5 ;::.ll,e date on vvl.;dl dll,O\Jlrt vv,B vv;tldleld flVlJl tl,e ellrployeo;:'~ 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 forvvard the support payments. 4. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and retum a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2233728890 EMPLOYEE'S/OBlIGOR'S NAME: KROH, ERIC S. EMPLOYEE'S CASE IDENTIFIER: 5778101054 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below, 7. liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he 01 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 ;s employed governs. 9. * Withholding limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (1 5 U.S.c. 91673 (b)l; or 21 the amounts allowed by the State of the employee's/obligor's principat 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. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Submitted By: 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'/2ML or by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Worker ID $IATT Service Type M OM6 No,: OQ70-01:,4 ADDENDUM Summary of Cases on Attachment Defendant/Obligor: KROH, ERIC S. PACSES Case Number 097104948 Plaintiff Name TAMMI S. KROH Docket Attachment Amount 009"27S 2002 $ 755.98 Child!ren)'s Name!s): DaB PACSES Case Number 880107597 Plaintiff Name TAMMI S. KROH Docket Attachment Amount 01::s96l" CIVIL $ 400.00 Child!ren)'s Name!s): DaB o If checked, you are required to enroll the child!ren) identified above in any health insurance coverage available through the employee's/obligor's employment. If you are required to enroll the child!ren) in any health insurance coverage available employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child!ren)'s Name\s): PACSES Case Number Plaintiff Name DaB Docket Attachment Amount $ 0.00 Child!ren)'s Name!s): DaB you are required to enroll the child!ren) in any health insurance coverage available employee's/obligor's employment. you are required to enroll the child!ren) in any health insurance coverage available 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): DaB Docket Attachment Amount $ 0.00 Child\ren)'s Name!s): DaB you are required to enroll the child(ren) in any health insurance coverage available employee's/obligor's employment. you are required to enroll the child(ren) in any health insurance coverage available the employee's/obligor's employment. Addendum Form EN,028 Worker ID $IATT Service Type M QMB No.: 097{H)154 o C-, -:0,.. ....' c.~~ '5\ .".- c.: Co) N +' :2 -'0 :;..;. ~ ..... ct: -n fnp -oPJ, -"J"-" bb ;.:~-}:, ,"') -'-~ ." ,., :7',rn o "".-\ '~ <;~:1 '< 'i? (..J1