HomeMy WebLinkAbout01-05989
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PEN NA.
THOMAS E. PALLIS
Plaintiff
No.
2001-5989
VERSUS
RACHEL S. PALLIS
Defendant
DECREE IN
DIVORCE
AND
NOW'~~
'~IT IS ORDERED AND
~
DECREED THAT
Thomas E. Pallis
. PLAINTIFF,
AND
Rachel S. Pallis
. DEFENDANT.
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHIC;H HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
None: The terms of the Marriage Settlement Agreement of"
September 23, 2004 are incorporated but not merged into the
Decree in Divorce..
/
BY
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PROTHONOTARY .
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SAlOIS
SHUFF, FLOWER
& LINDSAY
ATTORNEYS'AT'LAW
26 W. High Street
Carlisle. PA
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THOMAS E. PALLlS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: CIVIL ACTION -LAW
: NO. 2001-5989 CIVIL TERM
RACHEL S. PALLIS,
Defendant
: IN DIVORCE
PRAFCIPE TO TRANSMIT RFCORD
To the Prothonotary:
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) 3301 (eJ)(1)
of the Divorce Code. (Strike out inapplicable section).
2. Date and manner of service of the complaint: Acceptance of Service by
Rebecca Hughes, Esquire on behalf of the Plaintiff signed October 22, 2001 and filed with the
Prothonotary on October 31,2001 (copy attached)
3. (Complete either paragraph (a) or (b)).
(a) Date of execution of the affidavit of consent required by
Section 3301 (c) of the Divorce Code: by the Plaintiff
September 23, 2004: by the Defendant September 23, 2004.
4. Related claims pending: None' The terms of the Marriage ~ett'ement
Agreement of ~eptemher n :>004 ::Ire incorporated hut not merged intn the
ner.rAp. in Divnrr.e
5. Complete either (a) or (b).
(a) Date and manner of service of the notice of intention to file
praecipe to transmit record, a copy of which is attached:
(b)
Date Plaintiff's Waiver of Notice in 3301(c) Divorce was filed
with the Prothonotary: September fill-, 2004.
Date Defendant's Waiver of Notice in 3301(c) Divorce was filed with
the Prothonotary: September 04.
Carol J. Lindsa)l Es ire
Supreme Court 693
Said is, Shuff, Flower & Lindsay
26 West High Street
Carlisle PA 17013
Phone: 717.243.6222
Attorney for Defendant
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vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
NO. 2001-5796 CIVIL TERM
THOMAS E. PALUS,
Plaintiff
RACHEL S. PALUS,
Defendant
IN DIVORCE
MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT made this Z3~ay of September, 2004 by and between
RACHEL S. PALUS, (hereinafter referred to as "WIFE") and THOMAS E. PALUS,
(hereinafter referred to as "HUSBAND").
WITNESSETH:
WHEREAS, HUSBAND and WIFE were lawfully married on August 26, 1993;
and
WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen
between the parties, and the parties hereto are desirous of settling fully and finally their
respective financial and property rights and obligations as between each other,
including, but not limited to the settling of all matters between them relating to the
ownership and equitable distribution of real and personal property, the settling of all
claims and possible claims by one against the other or against their respective estates,
and the equitable distribution of property and alimony for each party.
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The parties hereto agree and covenant as follows:
1.
It is the intent and purpose of this Agreement to set forth the respective rights
and duties of the parties while they continue to live apart from each other.
2.
The parties have attempted to divide their matrimonial property in a manner
which conforms to a just and right standard, with due regard to the rights of each party.
It is the intent of the parties that such division shall be final and shall forever determine
their respective rights. The division of existing marital property is not intended by the
parties to constitute in any way a sale or exchange of assets.
3.
Further, the parties agree to continue living separately and apart from the other
at any place or places that he or she may select as they have heretofore been doing.
Neither party shall molest, harass, annoy, injure, threaten or interfere with the other
party in any matter whatsoever. Each party may carry on and engage in any
employment, profession, business or other activity as he or she may deem advisable for
his or her sole use and benefit. Neither party shall interfere with the uses, ownership,
enjoyment or disposition of any property now owned and not specified herein or
property hereafter acquired by the other.
4.
The consideration for this contract and agreement is the mutual benefit to be
obtained by both of the parties hereto and the covenants and agreements of each of
the parties to the other. The adequacy of the consideration for all agreements herein
contained is stipulated, confessed, and admitted by the parties, and the parties intend
to be legally bound hereby.
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Each party to the Agreement acknowledges and declares that he or she,
respectively:
(1) Is represented by counsel of his or her own choosing, or if not
represented by counsel, understands that he or she has the right to
counsel: HUSBAND is represented by Rebecca R. Hughes, Esquire of
Salzmann, Hughes & Fishman, P.C.; WIFE is represented by Carol
Lindsay of Said is, Shuff, Flower & Lindsay;
(2) Is fully and completely informed of the facts relating to the subject
matter of this Agreement and of the rights and liabilities of the parties;
(3) Is entering into this Agreement voluntarily after receiving the advice of
counselor after choosing not to consult an attorney;
(4) Has given careful and mature thought to the making of this
Agreement;
(5) Has carefully read each provision of this Agreement; and
(6) Fully and completely understands each provision of this Agreement,
both as to the subject matter and legal effect of each provision.
This Agreement shall become effective immediately as of the date of execution.
5.
It is the purpose and intent of this Agreement to settle forever and completely the
interest and obligations of the parties in all property that they own separately, and all
property that would qualify as marital property under the Pennsylvania Divorce Code,
Title 23, Section 3501 (a), and that is referred to in this Agreement as "Marital Property",
as between themselves, their heirs and assigns. The parties have attempted to divide
their Marital Property in a manner that conforms to a just and fair standard, with due
regard to the rights of each party. The division of existing Marital Property is not
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intended by the parties to constitute in any way a sale or exchange of assets, and the
division is being effected without the introduction of outside funds or other property not
constituting a part of the marital estate.
It is the further purpose of this Agreement to settle forever and completely any
obligation under the Pennsylvania Divorce Code relating to spousal support or alimony.
6.
Each party represents and warrants that he or she has made a full and fair
disclosure to the other of all of his or her property interests of any nature, including any
mortgage, pledge, lien, charge, security interest, encumbrance, or restriction to which
any property is subject. Each party further represents that he or she has made a full
and fair disclosure of all debts and obligations of any nature for which he or she is
currently liable or may become liable. Each further represents and warrants that he or
she has not made any gifts or transfers for inadequate consideration of Marital Property
without the prior consent of the other.
Each Party acknowledges that, to the extent desired, he or she has had access
to all joint and separate State and Federal Tax Returns filed by or on behalf of either or
both Parties during marriage.
7.
PERSONAL PROPERTY: The parties agree that the personal property has
been divided to the parties' mutual satisfaction with the exception of the following items
which the WIFE is desirous of obtaining and HUSBAND is agreeing to relinquish to
WIFE: fishing rod and tackle, chandelier, and 2 framed Bully Hill prints. The parties will
cooperate in transferring these items over to WIFE. With the exception of the above,
WIFE hereby waives all right, title and interest which she may have in any personal
property of the HUSBAND. HUSBAND likewise waives any right, title and interest
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which he has in the personal property of WIFE. Henceforth, each of the parties shall
own, have and enjoy independently of any claim or right of the other party, all items of
personal property of every kind, nature and description and wherever situated, which
are then owned or held by or which may hereafter belong to HUSBAND or WIFE with
full power to HUSBAND or WIFE to dispose of the same as fully and effectually, in all
respects and for all purposes as if he or she were unmarried. Within ten (10) days as
of the date of this agreement HUSBAND will pay to WIFE $500.00. Within forty-five
(45) days of the date of this agreement HUSBAND will pay to WIFE an additional
$1,500.00.
8.
DOMESTIC RELATIONS: The parties acknowledge that the support order has
been entered by the Office of Domestic Relations and that WIFE has sought a hearing
de novo. WIFE will withdraw her request for a hearing de novo, with HUSBAND'S
concurrence, on the condition that HUSBAND pay to WIFE for the support of their two
children through the Office of Domestic Relations $711.00 per month effective the date
WIFE filed the Petition for Support. It is hereby agreed to that the parties, absent a
material change in circumstances, shall not petition the Domestic Relations Office for a
modification in child support for one year from the date of this Agreement. HUSBAND
waives any claim that monies paid to him as a part of his computer business are not
includable in income for support and in any future support orders, income earned by
HUSBAND in this manner shall be considered a portion of his annual income. WIFE
shall hereby forever waive any right to alimony and alimony pendente lite effective as of
the date of execution of this Agreement and any payments or obligations related thereto
shall end as of the date of this Agreement. Further, WIFE covenants and agrees to
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withdraw any appeal filed with respect to any obligation of HUSBAND through Domestic
Relations which is currently pending as of the date of execution hereof.
9.
AUTOMOBILES: WIFE hereby waives all right, title and interest in any vehicle
that HUSBAND currently owns or may own in the future, and agrees to execute all
documents necessary to transfer title of any jointly titled vehicles that HUSBAND may
own within thirty (30) days of this Agreement. HUSBAND shall hold WIFE harmless for
any and all liability associated with the use and purchase of any vehicle he may own,
and shall be solely responsible for all insurance and other financial responsibility
associated with said vehicle. HUSBAND hereby waives all right, title and interest in any
vehicle that WIFE currently owns or may own in the future, and agrees to execute all
documents necessary to transfer title of any jointly titled vehicles that WIFE may own
within thirty (30) days of this Agreement. WIFE shall hold HUSBAND harmless for any
and all liability associated with the use and purchase of any vehicle she may own, and
shall be solely responsible for all insurance and other financial responsibility associated
with said vehicle. Within ten (10) days of the date of this agreement HUSBAND will pay
to WIFE $500.00 on account of a loan incurred by the parties to WIFE's parents for the
purchase of a vehicle.
10.
MARITAL DEBTS: It is understood and agreed that during the marriage, the
parties acquired a significant amount of debt, and that since the date of separation,
HUSBAND has paid the following debts independent from any contributions from
WIFE:
a.
b.
c.
d.
Belvedere Medical Center
Pagenet Paging
Cavalry Investment (Mobil)
Certified Services Inc. (Vision Care Associates)
$ 30.00
$ 240.00
$ 425.00
$ 134.00
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e. Credit Management Inc. (PCCA Emer. Med.)
f. Discover Financial Services
g. FCNB
h. Ford Motor Credit
i. Harvard Collection (Commonwealth Edison)
j. Harvard Collection (Jewel Osco)
k. Household Finance (This End Up)
I. Macy's West
m. Nordstrom FSB
n. Peerless Credit (Belvedere Medical)
o. Sears
p. WFNB I Limited
$ 140.00
$ 2,806.00
$ 1,886.00
$ 7,502.00
$ 86.00
$ 61.00
$ 3,887.00
$ 219.00
$ 645.00
$ 161.00
$ 995.00
$ 167.00
HUSBAND hereby agrees to assume these debts without contribution from WIFE
toward the payment of the same.
It is understood and agreed WIFE is responsible for payment of the following
debt:
a.
b,
c.
d.
Renaissances Reality
Household Finance Loan
Vehicle Loan to WIFE's parents
WIFE's Student Loan
$ 2,040.00
$ 5,115.44
$ 1,400.00
$ 6,000.00
WIFE hereby agrees to assume these debts.
It is further mutually agreed by and between the parties that WIFE shall assume
all liability for and pay and indemnify the HUSBAND against all debts incurred by WIFE
after the date of separation. WIFE represents and warrants to HUSBAND that since
the parties' marital separation she has not contracted or incurred any debt or liability for
which HUSBAND or his estate might be responsible and WIFE further represents and
warrants to HUSBAND that she will not contract or incur any debt or liability after the
execution of this Agreement, for which HUSBAND or his estate might be responsible.
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WIFE shall indemnify and save HUSBAND harmless from any and all claims or
demands made against him by reason of debts or obligations incurred by her.
HUSBAND shall assume all liability for and pay and indemnify the WIFE
against all debts incurred by HUSBAND after the date of separation. HUSBAND
represents and warrants to WIFE that since the parties' marital separation he has not
contracted or incurred any debt or liability for which WIFE or her estate might be
responsible and HUSBAND further represents and warrants to WIFE that he will not
contract or incur any debt or liability after the execution of this Agreement, for which
WIFE or her estate might be responsible. HUSBAND shall indemnify and save WIFE
harmless from any and all claims or demands made against her by reason of debts or
obligations incurred by him.
11.
INSURANCE AND EMPLOYEE BENEFITS: The parties agree that any life
insurance policies on the life of HUSBAND or WIFE or any other employee benefits,
including but not limited to retirement, profit sharing or medical benefits of either party,
shall be their own.
12.
BENEFITS. STOCK AND BANK ACCOUNTS WIFE agrees to waive all right,
title and interest which she may have in the savings or checking or any other bank
accounts of HUSBAND and likewise HUSBAND agrees to waive all right, title and
interest which he may have in the savings or checking or any other bank accounts of
WIFE.
13.
DIVORCE: The parties both agree to cooperate with each other in obtaining a
final divorce of the marriage immediately upon execution hereof. It is agreed that the
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parties will execute and file the consents necessary to obtain the divorce. Any party
who fails to cooperate with obtaining the Divorce shall pay all the costs and legal fees of
the party who is seeking the divorce.
14.
BREACH: If either party breaches any provisions of this Agreement, the other
party shall have the right, at his or her election, to sue for damages for such breach or
seek such other remedies or relief as may be available to him or her, and the party
breaching this contract shall be responsible for payment of legal fees and costs
incurred by the other in enforcing their rights under this Agreement.
15.
ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at
the request of the other, execute, acknowledge and deliver to the other party any and
all further instruments that may be reasonably required to give full force and effect to
the provisions of this Agreement.
16.
VOLUNTARY EXECUTION: The provisions of this Agreement and their legal
effect have been fully explained to the parties by their respective counsel, are fully
understood by both parties, and each party acknowledges that the Agreement is fair
and equitable, that it is being entered into voluntarily, and that it is not the result of any
duress or undue influence. It is the parties' intent that this Agreement does not merge
with the Divorce Decree, but rather shall continue to have independent contractual
significance. Each party maintains his or her contractual remedies or any other
remedies provided by law or statute. Those remedies shall include, but not be limited
to, damages resulting from breach of this Agreement, specific enforcement of this
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Agreement and remedies pertaining to failure to comply with an order of court or
agreement pertaining to equitable distribution, alimony, alimony pendente lite, counsel
fees and costs as set forth in the Pennsylvania Divorce Code or other similar statutes
now in effect and as amended or hereafter enacted.
17.
ENTIRE AGREEMENT: This Agreement contains the entire understanding of
the parties and there are no representations, warranties, covenants or undertakings
other than those expressly set forth herein.
18.
APPLICABLE LAW: This Agreement shall be construed under the Laws of the
Commonwealth of Pennsylvania.
19.
PRIOR AGREEMENTS: It is understood and agreed that any and all property
settlement agreements which mayor have been executed prior to the date and time of
this Agreement are null and void and of no effect.
20.
WAIVER OF CLAIMS AGAINST ESTATES: Except as herein otherwise
provided, each party may dispose of his or her property in any way, and each party
hereby waives and relinquishes any and all rights he or she may now have or hereafter
acquire, under the present or future laws of any jurisdiction, to share in the property or
the estate of the other as a result of the marital relationship, including without limitation,
dower, courtesy, statutory allowance, widow's allowance, right to take in intestacy, right
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to take against the Will of the other, and right to act as administrator or executor of the
other's estate, and each will, at the request of the other, execute, acknowledge and
deliver any and all instruments which may be necessary or advisable to carry into effect
this mutual waiver and relinquishment of all such interests, rights and claims.
IN WITNESS WHEREOF, the parties hereunto have set their hands and seals
the day and year first above written.
(SEAL)
(SEAL)
RACHEL S. PALLlS
11
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COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, this 03 /lCi day of
.x:t pi: ftrl.../c. 0 ~ _, 2004, a Notary Public, in and for the Commonwealth of
Pennsylvania and County of Cumberland, RACHEL S. PALUS, known to me (or
satisfactorily proven) to be the person whose name is subscribed to the within Marriage
Settlement Agreement, and acknowledges that she executed the same for the
purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
NOTARIAL SEAL
MERLENE J. MARHEIiKA. NOTARY PUBLIC
CARLISLE. CUMBERLAND COUNTY. PA
MY COMMISSION EXPIRES JUNE 8. 2006
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
APPEARED
BEFORE
ME,
)3 d- day
of
this
, 2004, a Notary Public, in and for the Commonwealth of
Pennsylvania and County of Cumberland, THOMAS E. PALUS, known to me (or
satisfactorily proven) to be the person whose name is subscribed to the within Marriage
Settlement Agreement, and acknowledges that he executed the same for the purposes
therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and off' ial seal.
COMMONWi'ALTH OF PENNSYLVANIA
Notarial Seal
Jll"'Iueline L. Drawbaugh, Notary Public
South Mjddl~ton Twp,. Cumberland County
My CommiSSion Expires Aug. 14, 2007
Member, Pennsylvania Association of Notaries
12
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RACHEL S. PALLIS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2001- 591'1 CIVIL TERM
THOMAS E. PALLIS,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCEft
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in Court. If you wish to defend against the claims set forth in the
following pages, you must take prompt action. You are warned that if you fail to do so, the case
may proceed without you and a decree of divorce or annulment may be entered against you by the
Court. A judgment may also be entered against you for any other claim or relief requested in
these papers by the Plaintiff. You may lose money or property or other rights important to you,
including custody or visitation of your children.
When the ground for divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the
Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
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RACHEL S. PALLIS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 2001- 5'lN CIVIL TERM
THOMAS E. P ALLIS,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCEI
COMPLAINT IN DIVORCE
The Plaintiff, Rachel S. Pallis, through her attorney, Thomas S. Diehl, makes the
following Complaint in Divorce, and, in support thereof, avers as follows:
COUNT I-NO FAULT
1. The Plaintiff, Rachel S. Pallis, is an adult individual who currently resides at 46
Brian Drive, Carlisle, Cumberland County, Pennsylvania 17013.
2. The Defendant, Thomas E. Pallis, is an adult individual who currently resides at
46 Brian Drive, Carlisle, Cumberland County, Pennsylvania 17013.
3. The Defendant and the Plaintiff have been bona fide residents of the
Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this
Complaint.
4. The Plaintiff and the Defendant were married on August 26, 1993 in Sussex
County, New Jersey.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The Defendant is not a member of the Armed Forces of the United States of
America or its Allies.
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7. The Plaintiff has been advised of the availability of counseling and the right to
request that the Court require the parties to participate in counseling. Knowing this, Plaintiff
does not desire that the Court require the parties to participate in counseling.
8. Plaintiff and Defendant are citizens of the United States of America.
9. The parties' marriage is irretrievably broken.
WHEREFORE, the Plaintiff, Rachel S. Pallis, respectfully requests your Honorable Court
to enter a decree in divorce pursuant to 23 P.S. S 3301(c) ofthe Divorce Code.
COUNT II-ALIMONY PENDENTE LITE
10. Paragraphs 1 through 9 are incorporated herein by reference as if set forth in their
full text.
11. Plaintiff is unable to provide for or afford her counsel fees, expenses, and costs
during the pendency of this divorce action and through its resolutions.
12. Plaintiff is without sufficient property and otherwise unable to financially support
herself despite being employed.
13. Defendant is presently employed and receiving a substantial income and benefits,
and is able to pay for counsel fees, expenses, and costs as well as alimony and alimony pendente
lite for Plaintiff.
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WHEREFORE, the Plaintiff, Rachel S. Pallis, respectfully requests your Honorable Court
to enter an Order requiring Defendant to pay Plaintiff s counsel fees, expenses and costs, as well
as providing for payment of appropriate alimony and alimony pendente lite to Plaintiff.
Respectfully submitted,
Date:
10 - 1'7-81
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Tomas S. Diehl
Attorney for the Plaintiff
One West High Street, Suite 208
Post Office Box 1290
Carlisle, Pennsylvania 17013
(717) 240-0833
(717) 240-0893 - FAX
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VERIFICATION
I verifY that the statements made in this Complaint 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.
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Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
THOMAS E. P ALLIS,
v.
CIVIL ACTION - LAW
NO. 2001-5989 CIVIL TERM
RACHEL S. PALLIS,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT, WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE
1. A complaint in divorce under Section 3301(C) ofthe Divorce Code was filed on
October 17, 2001.
2.. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety
days have elapsed from tbe date of the filing of the Complaint.
3. I consent to the entry of a final decree in divorce without notice.
4. I understand that 1 may lose rights concerning alimony, division of property,
lawyer's fees or expenses if! do not claim them before a divorce is granted.
5. 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 .
6. I have been advised of the availability of marriage counseling and understand
that I may request that the court require counseling. I do not request that the court require
counseling.
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 ection 4904 relating to
unsworn falsification to authorities.
Date: 9ft~/?ool../
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THOMAS E. PALL/S,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2001-5989 CIVIL TERM
V5.
RACHEL S. PALL/S,
Defendant
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
UNDER 63301 reI OF THE DIVORCE CODE
AND WAIVER OF COUNSELING
1. A Complaint in Divorce under 93301 (c) of the Divorce Code was filed October 17, 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.
Date: q-2.'5-0Y
DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
6 3301 reI OF THE DIVORCE CODE
1. !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
\,>xpenses 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
Date: C\ - 2.'5 ~ cY-\
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RACHEL S. PALLIS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2001-5989
CIVIL TERM
THOMAS E. PALLIS,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
ACCEPTANCE OF SERVICE
I, Rebecca Hughes, Esquire, counsel for Defendant in the above-captioned matter, hereby
accept service of the Complaint in Divorce on behalf of Thomas E. Fallis, in full satisfaction of
the Pennsylvania Rules of Civil Procedure.
DATE: 10 -.22 -cJl
Rebecca Hughes, Esqui
Irwin, McKnight & Hug es
60 West Pomfret Street
Carlisle, Pennsylvania 17013
(717) 249-2353
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THOMAS E. PALLlS,
PLAINTIFF,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: NO: 2001-5989 CIVIL
RACHEL S. P ALLIS,
DEFENDANT.
: IN CUSTODY
ORDER OF COURT
AND NOW, this JJ.!!!... day Of~, 2002, upon agreement of counsel to reschedule
the previous custody hearing in this matter scheduled for April 24, 2002, the hearing is hereby
rescheduled for August 14, 2002, at q; 3 0 o'clockA-.M.
By the Court,
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PACSES In 301104045
vs.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: DOMESTIC RELATIONS SECTION
: CIVIL ACTION - LAW
RACHEL S. PALLIS,
Plaintiff/Petitioner
THOMAS E. PALLIS,
Defendant/Respondent : NO. 2001-5989 CIVIL TERM
ORDER OF COURT
AND NOW, this 15th day of January, 2002, based upon the Court's determination that Petitioner's
monthly net income/earning capacity is $1,581.00 and Respondent's monthly net income/earning
capacity is $3,023.31, it is hereby Ordered that the Respondent pay to the Pennsylvania State
Collection and Disbursement Unit, $395.00 per month payable bi-weekly as follows; $182.31 bi-
weekly for alimony pendente lite and $0.00 on arrears. First payment due next pay date. Arrears set
at $790.00 as ofJanuary 15, 2002. The effective date ofthe order is November 21,2001.
Collection on the retroactive arrears is held in abeyance until after demand for hearing time has past
and if there is a demand for hearing the abeyance will be continued until disposition ofthe support
master.
Failure to make each payment on time and in full will cause all arrears to become subject to immediate
collection by all of the means as provided by 23 Pa. C. S. ~ 3703. Further, if the Court finds, after
hearing, that the Respondent has willfully failed to comply with this Order, it may declare the
Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not
limited to, commitment of the Respondent to prison for a period not to exceed six months.
Said money to be turned over by the PA SCDU to: Rachel S. Pallis. Payments must be made by
check or money order. All checks and money orders must be made payable to P A SCDU and mailed
to:
P A SCDU
P.O. Box 69110
Harrisburg, P A 17106-911 0
Payments must include the defendant's P ACSES Member Number or Social Security Number in order
to be processed. Do not send cash by maiL
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Respondent to provide medical insurance coverage.
This Order shall become final ten days after the mailing ofthe notice of the entry of the Order to the
parties unless either party files a written demand with the Prothonotary for a hearing de novo before
the Court.
DRO: R J. Shadday
Mailed copies on
1-15-02 to: <
BY THE COURT,
Petitioner
Respondent
Thomas Diehl, Esquire
Rebecca Hughes, Esquire
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Edgar B. Bayley
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
M[ tJi-!ltj 8"1 C!it/lG
State Commonwealth of pennsvlvania ;01/&5 Jt) IIOtjt)(/";""
Co./City/Dist. of CUMBERLAND b
Date of Order/Notice 01/15/02 {( .31 ;;J..f",-
Court/Case Number (See Addendum for case summary)
o Original Order/Notice
o Amended Order/Notice
o T,erminate Order/Notice
) RE, PALLIS, THOMAS E.
) Employee/Obligor's Name (Last, First, MI)
) 148-76-6382
) Employee/Obligor's Social Security Number
) 2659100882
) Employee/Obligor's Case Identifier
) (See Addendum for plaintiff names associated with cases on aflammenO
) Custodial Parent's Name (Last, First, MI)
)
EmployerlWithholder's Federal EIN Number
NAVl:CP
EmployerlWithholder's Name
5450 CARLISLE PIKE
EmployerlWithholder's Address
PO BOX 2020
MECHANICSBURG PA 17055-0788
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMA nON: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 395.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes Q9 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 $ 395.00 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:
$ 91.15 per weekly pay period.
$ 182.31 per biweekly pay period (every two weeks).
$ 197.50 per semimonthly pay period (twice a month).
$ 395.00 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 paydateJdate of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on pg. 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer SelVice at 1-B77-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106.9112
IN ADDITION, PAYMENTS 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:
Date of Order: JAN 1 r; 2002
.,rt/ j)/pc
Fo m EN-028
Worker ID $IATT
SelVice Type M
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MB No.: 0970-0154
/ II _ piration Date: 12131/00
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If checked you are required to provide a copy of this form to your employee.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agenty 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. * RepOlt;llg tlte F' ayJatefDate of\N;U.I,oldil,5. '/01.1 llltlst k!-,vlt tile fJaydatb!Jaoc' of nitl,l,vldil,g nllell 3el.dil'6 tile payl (lei It. Tile
I-'a)dalet~&. of v~ith',o/J;dg :.5 dlt:' Jate VII vyI.kll CllIloUllt yy,H VvitLI.e:IcJ flV", lltel:I'lpJoret;'j m~ge5. You must comply with the Jaw of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4.' Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support
against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must
follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest
extent possible. (See 119 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: 2511954510
EMPLOYEE'S/OBLlGOR'S NAME: PALLIS , THOMAS E.
EMPLOYEE'S CASE IDENTIFIER: 2659100882 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should
have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs
unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Anti-diserimination: 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 Lirnits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.s.c. ~1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment
The ~ederallimit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State} Federal, local taxes; Social Security taxes; and Medicare taxes.
10.
"NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
Requesting Agency:
DOMESTIC RELATIONS SECTION
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 240-624B or
by Internet @
Page 2 of 2
Form EN-028
Worker 10 $IATT
Service Type M
OMB No.: 0970-0154
Expiration Date: 12/31/00
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ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: PALLIS, THOMAS E.
PACSES Case Number 301104045/81.215'
Plaintiff Name
RACHEL S. PALLIS
Docket Attachment Amount
01::s989 CIVIL$ 395.00
Child(ren)'s Name(s):
DaB
'.Bli~~~~t:~:;~~~;~.;~~~i;:~;~~~;~,I;~:~~il~i;~~i........i........... ........
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s);
DaB
..t5,;~~~~~~~:;~.~;;~;:~~:;~~':;~~r~il;~~~~il~(;:~;..'.....\\i............
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
'Elii~~;~~;~~~~~~;~;~~~i;:~;~:~;~';;~~~~ii~i;~~i'."'............i..........
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Addendum
Service Type M
OMB No.: 0970-0154
Expiration Date: 12131/00
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PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
...a,i.~~~~t~~,~~~~;~;:~~i;:J;~:~;~:':~:~~il;i;:.~i..'\........................
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
dli~~~~t:~~~~~;;:;:~~i;~~;~:~;~;,};~:~~~,~i;;~i}...
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
..d:i~~:~~;~,;;~..;;:;~~~:;:~:~:~;~,::~~~~.i,~i;:~;t...............i.
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Form EN-028
Worker ID $IATT
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
?J/I O!.5't}fc; CrVlL
State Commonwealth of Pennsylvania IM~,[)..3 (; / / tJ l.fb 1/'>
Co.lCity/Dist. of CUMBERLAND
Date of Order/Notice 01/25/02 bit ,9/ d-I ~
Court/Case Number (See Addendum for case summary)
o Original Order/Notice
o Amended Order/Notice
o Terminate Order/Notice
) RE: PALLIS, THOMAS E.
) Employee/Obligor's Name (Last, First Mil
) 148-76-6382
) EmployeeJObligor's Social Security Number
) 2659100882
) Employee/Obligor's Case Identifier
) (See Addendum for plaintiH names associated with cases on attachment)
) Custodial Parent's Name (Last, First, MI)
)
Employer/Withholder's Federal EIN Number
BAE SYSTEMS NORTH AMERICA
EmployerlWithholder's Name
1601 RESEARCH BLVD
EmployerNJithholder's Address
ROCKVILLE MD 20850-3173
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's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 395.00 per month in current support
$ 0.00 per month in pa?t-due support Arrears 12 weeks or greater? (X)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 $ 395.00 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:
$ 91.15 per weekly pay period.
$ 182.31 per biweekly pay period (every two weeks).
$ 197.50 per semimonthly pay period (twice a month).
$ 395.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's! obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on pg. 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER 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:
Date of Order:
clAN 4 (j 200Z
j) c
Form E 028
Worker ID $IATT
Service Type M
MAILED
/ - ;)/i-o)"
OMB No.: 0970-0154
Expiration Date: 12/31/00
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
D If checked you are required to provide a copy of this form to your employee.
1. Priority: Withholding under this OrderINotice has priority over any othe, iegai process under State Jaw 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. * Rt.~oltihg lL-.;; Paydd.~Date vi 'Nitl.I,OIJ:I,g. '.'-vtlllll:lst l<Jpolt tile: ....ayJatelJi:ll:e of vv;tl.l,vldh.g VVII~11 5elfdil.g tilL p...ylll~llt. Tile
l-'ayda~Jd.te of nitl.l.oldiIl6;~ tLe Jdtb 011 vvl.;,...I. idllOUllt vvaS vvilLl.dd n011l tLe elll""k,yc-e's ndgt:;5. You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4.' Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support
against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must
follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest
extent possible. (See #9 below)
S. Termination Notification: You must 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 ID: 2235379500
EMPLOYEE'S/OBLlGOR'S NAME: PALLIS. THOMAS E.
EMPLOYEE'S CASE IDENTIFIER: 2659100882 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
several1ce pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should
have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs
unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from
employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding.
Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is
employed governs.
9.' Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.S.c. 91673 (b)l; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes.
10.
'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with resped 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,
contad WAGE ATTACHMENT UNIT
by telephone at (71 7) 240-6225 or
by FAX at (717) 240-6248 or
by Internet @
Page 2 of 2
Form EN-D28
Worker ID $IATT
Service Type M
OMB No.: 0970-0154
Expiration Date: 12/31/00
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ADDENDUM
Summary of Cases on Attachment
PALLIS, THOMAS E.
Defendant/Obligor:
301104045!3r :J-IC:
PACSES Case Number
Plaintiff Name
RACHEL S. PALLIS
Docket Attachment Amount
01-5989 CIVIL$ 395.00
Child(ren)'s Name(s):
DOB
'.'BI;~~:~~:~:~~~~;:;:~~i::~:;:~:~rl:~:~~;I~;;~~)."'...t.......................
identified above in any health insurance coverage available
through the employee'slobligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
..tJ;;~~:~~:d,~~~~;:;:~~i;~~;~:~:~,;;~:~~.i;~;;~~;.....·
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
.bl;~~:~~:::.~~~~;:;;~~i;:~.:~..:~;~rr;~~~~ild(;~~;............i.. ."
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Addendum
Service Type M
OMS No.: 0970-0154
Expiration Date; 12/31/00
""""'M'f\c~'C"'1 ,~
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PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
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Dlf checked, yo~ a;e requir~d to enrollth~ child(ren) .
identified above in any health insurance coverage available
through the employee'slobligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s}:
DOB
d;;~~:~~:d;;;~~;~;:~~:;:~;~.:~;~il;~:~~il~i;:~;.
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
dl;~~:~~~~:;~~~;:;:~~;;;~:~~~:~:I;~;~~:ld!;;~;?
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Form EN-028
Worker ID $IATT
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
b;:l ~t!J159f?9 C71t//t....
State Commonwealth of Pennsylvania fJ)f(!c;z> -30110 7"0 vs-
Co.lCity/Dist. of CUMBERLAND,
Date of Order/Notice 03/12/02 oIl. J/~/5'
Court/Case Number (See Addendum for case summary)
o Original Order/Notice
@ Amended OrderlNotice
o Terminate Order/Notice
) RE: PALLIS, THOMAS E.
) EmpJoyeelObHgor's Name (Last First, MI)
) 148-76-6382
) Employee/Obligor's Social Security Number
) 2659100882
J EmployeelObligor's Case Identifier
) (See Addendum for plaintiff names associated with cases on attachment)
) Custodial Parent's Name (Last, First, MI)
)
EmployerM'ithholder's Federal EIN Number
BAE SYSTEMS NORTH AMERICA
EmployerlWithholder's Name
1601 RESEARCH BLVD
EmpfoyerJ\iVithholder's Address
ROCKVILLE MD 20850-3173
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER lNFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 395.00 per month in current support
$ 100.00 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 $ 495.00 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:
$ 114.23 per weekly pay period.
$ 228.46 per biweekly pay period (every two weeks).
$ 247.50 per semimonthly pay period (twice a month).
$ 495.00 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 paydateJdate 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 (SCDUl 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.
Service Type M
MAILED
.5 -;3-0:;;"
.JV 6
Form EN-028
Worker ID $IATT
Date of Order: MAR 1 3 2002
OMIi No.: 0970.0154
c">IHdfian Date: 12/31/00
:1.'1'''"
""~.,.,. "
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If checked you are required to provide a copy olthis form to your employee.
1. Priority: Withholding under this OrderlNotice 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. * Rcj50rtitlg ti,e P dydate}Da.tc. ofW;t1,I,vldil,g. You IlIusl.q50lt tI,G paydate/e1aoc of yy;tl,I,oldil,g VVh~[1 selldil,g ti,e paYllle, It. TLe
!-,dyda'~e{datL of nitl,I,old;hg is 1I,~ date 011 vvh;d, alM)ullt m13 vvitl,l,eld Neill! tLG elllployec'& nages. You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support
against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must
follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest
extent possible. (See #9 below)
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: 2235379500
EMPLOYEE'S/OBl/GOR'S NAME: PALLIS, THOMAS E.
EMPLOYEE'S CASE IDENTIFIER: 2659100882 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should
have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs
unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from
employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding.
Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is
employed governs.
9. * Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.5.C ~1 673 (b)1; or 2) the amounts allowed by the State olthe employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxesi Social Security taxes; and Medicare taxes.
10.
'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
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 (71 7) 240-6225 or
by FAX at (717) 240-6248 or
by Internet @
Page 2 of 2
Form EN-028
Worker ID $IATT
Service Type M
OMB No.: 097Q.0154
Expiration Date: 12/31/00
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ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: PALLIS, THOMAS E.
PACSES Case Number 301104045 la/PlIo
Plaintiff Name
RACHEL S. PALLIS
Docket Attachment Amount
01::s9ii9 CIVIL$ 495.00
Child(ren)'s Name(s):
DaB
., ., " ".",
'''' ,... ........
.... ......., ......
.... ...............
, .... ..... ...'.. ,..
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....., ...........
tjifche~k.,d, \,ou 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):
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.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
dl/~~~~~~~~~;~;;~;~~~i;~ to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Addendum
Service Type M
OMB No.: 0970..Q154
Expiration Dale: 12/31/00
"-""~"'WI>c;.m:'q~ "~ _
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PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
dli~~~~~~~:~~~;;~;~~uired 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):
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.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
'..dli~~~~.~~~...~~'~";;~;~~~i;~~;;~~.;~II;~~~~:I~(;~~;.....
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Form EN-028
Worker ID $IATT
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RACHEL S. PALLIS,
PLAINTIFF,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLV
v.
THOMAS E. PALLIS,
DEFENDANT.
: NO. 2001-5989 CIVIL TERM
: IN DIVORCE
ORDER OF COURT
2002
AND NOW, this
day of June, 2002, upon consideration of the attached Petition
to Vacate Alimony Pendente Lite, a hearing is hereby scheduled for
in Courtroom #
at
0' clock _.M. in the Cumberland County Courthouse,
Carlisle, Pennsylvania.
By the Court,
J.
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FILED--cFF1CE
OF Tl-Ir:: pr)OJ.L!ONOTARY
02 JUN 10 PH /: S3
ClJt.ABEliU'ii"~D COUNTY
PENNSYLVAMA
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RACHEL S. PALLIS,
PLAINTIFF,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vi.
THOMAS E. PALLIS,
DEFENDANT.
: NO. 2001-5989 CIVIL TERM
: IN DIVORCE
PETITION TO VACATE ALIMONY PENDENTE LITE
AND NOW, comes the defendant, Thomas E. Pallis, by and through his attorneys,
IRWIN, McKNIGHT & HUGHES, Esquires, and files this Petition to Vacate Alimony Pendente
Lite making the following statement:
1. The plaintiff is Rachel S. Pallis, and the defendant is Thomas E. Pallis.
2. The plaintiff filed for divorce on November 21, 2001 and simultaneously filed for
alimony pendente lite.
3. Up unto the end of March, 2002, the plaintiff made no effort to move the
equitable distribution portion of the divorce along to a conclusion.
4. On or about April 10, 2002, the defendant, through his attorney, requested that the
plaintiff sign an Affidavit of Consent so that the matter could be brought before
the Divorce Master. Attached as Exhibit "A" is a copy of said letter and the
Consent provided to the plaintiff.
5. One month later, on May 10, 2002, the defendant, through his attorney, forwarded
an overall proposal for settlement. Attached as Exhibit "B" is a copy of said
letter.
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6. To date, the plaintiff has not provided a signed Affidavit of Consent nor has she
responded to either the May 10, 2002 correspondence or the April 10, 2002
correspondence.
7. The plaintiff is receiving alimony pendente lite to support the litigation expenses,
however, is refusing to allow the matter to be litigated or even to negotiate.
WHEREFORE, the defendant, Thomas E. Pallis, hereby requests that the Order for
Alimony Pendente Lite be vacated due to the plaintiff's unwillingness to move this matter to the
Divorce Master.
Respectfully submitted,
IRWIN, McKNIGHT & HUGHES
BY~~ :d
Rebecca R. Hughes, Esquire
60 West PomfTet Street
Carlisle, Pa 17013
717-249-2353
Supreme Court 1.0.# 67212
Attorney for the defendant,
Thomas E. Pallis
Date: Jun3
,2002
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LAW OFFICES
IRWIN McKNIGHT & HUGHES
ROGER B. IRWIN
MARCUS A. McK,VIGHT, III
JAMES D. HUGHES
REBECCA R. HUGHES
MARK D. SCHWARTZ
DOUGLAS G. i\flUER
WEST POMFRET PROFESSIONAL BUILDING
60 WEST POMFRET STREET
CARLISLE. PENNSYL VANIA 17013.3222
1717} 249-2353
FAX 1717} 249-6354
E-MAIL: IMHLAW@SUPERNET.COM
HAROLD S.lRWIN (1925-/977)
HAROLD S. IRWIN, JR. (1954-/986)
IRWIN, IRWIN&lRWIN (1956-1986)
IRWIN. IRWIN & McKNIGHT (J9R6-1994)
IRWIN, McKNIGHT & HUGHES (1994- )
April I 0, 2002
THOMAS S. DIEHL, ESQUIRE
1 WEST HIGH STREET
CARLISLE, P A 17013
FILE COpy
RE: PALLIS v. PALLIS
Dear Tom:
Please be advised that my client is anxious to settle the entire equitable distribution
portion of the above-captioned divorce. Toward that end, we are requesting that the enclosed
Consent be signed by your client so that we may proceed to the Divorce Master's office. If she
refuses to sign this, we will be petitioning to vacate her eligibility for alimony pendente lite for
failure to move this matter along.
Additionally we are requesting that, in the event your client is desirous of visiting my
client or the children at his home, that she first call and ask if it is an appropriate time for her to
visit. There have been instances in the past where it is has been an uncomfortable situation for
my client and for the children when Ms. Pallis stopped by my client's home. Therefore, please
counsel your client along these lines.
Thank you for your attention to these matters.
Very truly yours,
P~lU{:clc
cc: Thomas Pallis
Enclosure
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RACHEL S. PALLlS,
PLAINTIFF,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: NO: 2001-5989 CIVIL TERM
THOMAS E. PALLlS,
DEFENDANT.
: IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
October 17, 2001.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4. 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. .
I verifY that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsification to authorities.
Date:
,2002
RACHEL S. PALLlS
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LA W 0 FFICES
IRWIN McKNIGHT & HUGHES
ROGER B. IRWiN
MARClJS A. McKNIGHT. J!l
JAMES D, HUGHES
REBECCA R. HUGHES
DOUGLAS G. MILLER
WEST POMFRE7 PROFESSIONAL BUILDING
60 WEST POMFRET STREET
CARLISLE, PENNSYLVANIA 17013-3222
(717) 249-2353
FAX (717) 249-6354
E-MAIL: IMHLAW@SUPERNET.COM
HAROLD S./RWIN (1925-/977)
HAROLD5. IRWIN, JR. (1954-1986)
IRWIN, IRWfN & IRWIN (1956-1986)
IRWIN, IRWIN & .-\1cKNIGHT (/986-1994)
IRWIN. McKNIGHT & HUGHES (/994- )
May 10,2002
THOMAS S. DIEHL, ESQUIRE
1 WEST HIGH STREET
CARLISLE P A 17013
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RE: PALLlS v. PALLIS
Dear Tom:
On April I 0, 2002, I forwarded to you a consent for your client, Rachel Pallis, to sign so
that this divorce could move to the Divorce Master for litigation, To date, I have not received
the signed consent back from you. At this point, I can only assume that your client is unwilling
to sign the consent and move the matter to the Divorce Master. Therefore, I am preparing our
Petition to Vacate the Alimony Pendente Lite Order based upon her refusal to sign the consent.
Obviously, if she is unwilling to sign the consent and litigate this matter, she has no need for
APL. Quite frankly, there really are no assets in this matter to be litigated, only debt, all of
which my client is paying. If this matter is moved to the Divorce Master, Ms. Pallis would be
further behind financially because we would certair11y require her to pay some of the marital
debt.
In the alternative, my client is willing to settle all matters surrounding this divorce as
follows:
A. The parties shall agree that the personal property has been divided to their mutual
satisfaction;
B. Mr. Pallis will assume all marital debt and hold Ms. Pallis harmless for the same;
all debt acquired after the date of separation shall be the responsibility of the party
who acquired the same;
C. Both parties will cooperate in obtaining a final decree in divorce;
D. Custody of the two minor children shall be as follows:
I. The parties shall share legal custody of the minor children.
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2. The parties shall share physical custody of the minor children as follows:
a. Mother shall have custody every other weekend from Friday
through Sunday;
b. Mother shall have custody every Monday and Tuesday from after
work until 8:00 p.m., or, if Mother is not working and Father is
working, from 9:00 a.m. through 8:00 p.m.;
c. In the event Mother cannot exercise her Monday and Tuesday
custody periods, than two (2) other evenings during the week, to be
arranged one (1) week in advance and to follow the same time
frame as noted above;
d. Alternating holidays to include New Year's Day, Easter, Memorial
Day, Labor Day and Thanksgiving;
e. Christmas shall be split between the parties on an alternating basis
with Mother having December 24 at 12:00 p.m. through December
25 at 12:00 p.m. and Father having December 25 at 12:00 p.m.
through December 26 at 12:00 p.m. on even numbered years; the
parties shall alternate custody periods on odd numbered years;
f. During the summer months, each party shall enjoy one week of
vacation each month with notice of which weeks to be given
before the end of the school year.
E. Mr. Pallis will assume the full cost of the custody evaluation in the event the
custody matter is not litigated;
F. Mr. Pallis will continue to pay Alimony Pendente Lite through the end of
September, 2002.
Please review this proposal with your client at your earliest convenience. If I do not hear
from you by May 20, 2002, I will assume this is unacceptable and will file the Petition to Vacate
the Alimony Pendente Order.
Very truly yours,
RRH/bd
Cc: Thomas Pallis
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RACHEL S. PALLIS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2001-5989
CIVIL TERM
THOMAS E. P ALLIS,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE/CUSTODY
THOMAS E. PALLIS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2001-5796
CIVIL TERM
RACHEL S. P ALLIS,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
AND NOW, this ~
ORDER OF COURT
dayof )~ _
1
, 2002, the within Petition of
Counsel For Leave to Withdraw having been read, considered, and ordered filed, the Court
hereby orders that a Rule be and is issued upon the Respondent, Rachel S. Pallis, to show cause
why the Petitioner should not be permitted to withdraw as counsel, said Rule to be returnable
within "1
days of service of the date of this Order.
BY THE COURT:
1.
cc:
Thomas S. Diehl, Esquire, Petitioner
Rachel S. Pallis, Respondent
Rebecca R. Hughes, Esquire, Attorney for Thomas E. Pallis
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RACHEL S. PALLIS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2001-5989
CIVIL TERM
THOMAS E. PALLIS,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE/CUSTODY
THOMAS E. PALLIS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2001-5796
CIVIL TERM
RACHEL S. PALLIS,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
PETITION OF COUNSEL FOR LEAVE TO WTIHDRA W
Thomas S. Diehl, Esquire, hereby respectfully petitions this Honorable Court for Leave to
Withdraw Appearance as Counsel for the Plaintiff, Rachel S. Pallis, and in support, avers as
follows:
I. Petitioner is Thomas S. Diehl, Esquire
2. Respondent is Rachel S. Pallis.
3. Petitioner was retained by Respondent on or about October 12, 2001 to represent
her in the above-reference Divorce, and subsequent Custody matters.
4. Petitioner has undertaken such representation but is unable to continue for the
following reasons:
(a) Respondent lias failed to pay Petitioner's fees and costs as billed in
accordance with their fee agreement.
(b) Respondent has disregarded an agreement or obligation to Petitioner as to
fees and costs and withdrawal is allowed pursuant to Rule 1.16(b)(4) of
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the Rules of Professional Conduct.
(c) Petitioner's continued representation of Respondent has been rendered
unreasonably difficult by virtue of client's conduct, and good cause exists
therefore under Rule Ll6(b)(5) of the Pennsylvania Rules of Professional
Conduct for Petitioner's withdrawal of appearance in this case.
WHEREFORE, Petitioner, Thomas S. Diehl, Esquire, respectfully request leave to
withdraw his appearance for Respondent.
Respectfully submitted,
JUL 2 3 2002
omas S. Diehl
Attorney for the Plaintiff
One West High Street, Suite 208
Post Office Box 1290
Carlisle, Pennsylvania 17013
(717) 240-0833
(717) 240-0893 - FAX
Date:
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CERTIFICATE OF SERVICE
I hereby certifY this 23'd day of July 2002, that a true and correct copy of the foregoing
document was served on the following individuals
via certified mail, postage prepaid:
Rachel S. Pallis
207 Front Street
P.O. Box 34
Boiling Springs, P A 17007
via delivering a copy to Attorney Hughes' Courthouse mailbox:
Rebecca Hughes, Esquire
Irwin, McKnight & Hughes
60 West Pomfret Street
Carlisle, PA 17013
4L2D
B
Thomas S. Diehl, Esquire
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VERIFICATION
I verify that the statements made in the foregoing Petition are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4909
relating to unsworn falsification to authorities.
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Thomas S. Diehl, Esquire
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THOMAS E. PALLIS,
Plaintiff
: IN THE COURT OF COMMON PLEAS Ot\UG ~OZ
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 2001-5989
CIVIL TERM
RACHEL S. P ALLIS,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE/CUSTODY
ORDER OF COURT
AND NOW, this _ day of
2002, upon consideration
of the attached Petition, it is hereby directed that the Custody Hearing originally scheduled for
August 14,2002 at 9:30 p.m. is HEREBY CONTINUED.
It is further directed that the parties and their respective counsel appear before the
Honorable
, in Courtroom
at the Court of
Common Please, Cumberland County, Pennsylvania, on the
day of
, 2002, at
0' clock _.m. for a Custody Hearing.
BY THE COURT:
1.
cc: Thomas S. Diehl, Esquire
Rebecca Hughes, Esquire
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THOMAS E. P ALLIS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2001-5989
CIVIL TERM
RACHEL S. PALLIS,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE/CUSTODY
PETITION FOR CONTINUANCE
L The Petitioner is the above-named Defendant.
2. The Respondent is the above-named Plaintiff.
3. The parties are the parents of the children, Rowan Geraline Pallis, born February
7, 1996, and Jack Thomas Pallis, born May 5, 1999.
4. On July 19,2002 an Order was issued scheduling a custody hearing in this matter
for August 14,2002 at 9:30 a.m.
5. The Petitioner is represented by Thomas S. Diehl, Esquire, and the Respondent is
represented by Rebecca Hughes, Esquire.
6. Petitioner's counsel, Thomas S. Diehl, currently has a custody hearing scheduled
before the Honorable Judge 1. Wesley Oler on August 14,2002, which would conflict with this
matter as scheduled.
7. Petitioner's attorney has contacted Respondent's attorney, Rebecca Hughes,
Esquire, who indicates that she objects to a continuance.
8. The Petitioner would be unduly prejudiced should she have to obtain new counsel at
this late juncture; likewise the Petitioner asserts that she would be unjustly prejudiced if she should
attempt to proceed at this hearing without legal counsel.
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WHEREFORE, the Petitioner respectfully requests this Honorable Court to issue a
continuance rescheduling this matter.
Respectfully submitted,
AUG 0 6 2002
Dated:
Thomas S. Diehl, Esquire
Attorney for Defendant/Petitioner
One West High Street, Suite 208
Post Office Box 1290
Carlisle, Pennsylvania 17013
(717) 240-0833
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VERIFICATION
I verify that the statements made in this Petition 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.
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THOMAS E. PALLIS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2001-5989
CIVIL TERM
RACHEL S. P ALLIS,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE/CUSTODY
ORDER OF COURT
AND NOW, this _ day of
2002, upon consideration
of the attached Petition, it is hereby directed that the Custody Hearing originally scheduled for
August 14,2002 at 9:30 p.m. is HEREBY CONTINUED.
It is further directed that the parties and their respective counsel appear before the
Honorable
, in Courtroom
at the Court of
Common Please, Cumberland County, Pennsylvania, on the
day of
, 2002, at
0' clock _.m. for a Custody Hearing.
BY THE COURT:
1.
cc: Thomas S. Diehl, Esquire
Rebecca Hughes, Esquire
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AUG 0 r
THOMAS E. PALLIS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2001-5989
CIVIL TERM
RACHEL S. P ALLIS,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE/CUSTODY
ORDER OF COURT
AND NOW, this _ day of
2002, upon consideration
of the attached Petition, it is hereby directed that the Custody Heiuing originally scheduled for
August 14,2002 at 9:30 p.m. is HEREBY CONTINUED.
It is further directed that the parties and their respective counsel appear before the
Honorable
, in Courtroom
at the Court of
Common Please, Cumberland County, Pennsylvania, on the
day of
, 2002, at
0' clock _.m. for a Custody Hearing.
BY THE COURT:
J.
cc: Thomas S. Diehl, Esquire
Rebecca Hughes, Esquire
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THOMAS E. PALLIS,
PLAINTIFF,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: NO: 6989 CIVIL
RACHEL S. PALLIS,
DEFENDANT.
: IN CUSTODY
PRE-HEARING MEMORANDUM
1. HISTORY
The parties to this custody action are the natural parents of two minor children, , Rowan
Geraldine Pallis, born February 7, 1996, and Jack Thomas Pallis, born May 2, 1999. A custody
conciliation was previously held in this matter, and because an agreement could not be reached,
the parties have shared physical custody on a week on/week off basis. Additionally, the parties
agreed to submit themselves to a custody evaluation which was performed by Dr. Stanley
Schneider. Attached as Exhibit "A" is a copy of Dr. Schneider's report
II. WITNESSES
A. Thomas Pallis: will testifY regarding the care of the children both during the
marriage and since the date of separation.
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B. Pamela Saylor: mother of the plaintiff, will testify about the care of the children
both during the marriage and since the date of separation.
C. Dr. Stanley Schneider: will testify regarding the evaluation he performed on the
parties and the children.
Respectfully submitted,
By:
Re ecca R. Hughes, Esquir
60 West Pomfret Street
Carlisle, Pennsylvania 17013
Supreme Court I.D. No: 67212
717-249-2353
Attorney for the Plaintiff,
Thomas E. Pallis
Dated: 8-/3
.
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, 2002
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08/13/2002 13:30
71 77325375
GUIDANCE ASSOCIATES
PAGE 02
(;... GUIDANCE
. ASSOCIATES
'.ip~~NS\'LVANIA
v
MAIN OFfiCE
412 Erford Road
Camp Hill, PA 17011
Stanley E. Schneider, Ed.D.
Director
Camp Hili: (717) 732.2917
Henhey: (717) 533-4312
Carlisle: (717) 245.2289
Chambersburg: (717) 263.9392
FAX: (717) 732.5375
April 1 0, 2002
Thomas S. Diehl, Esquire
1 West High Street, Suite 208
P.O. Box 1290
Carlisle, PA 17013
Rebecca R. Hughes, Esquire
Irwin, McKnight & Hughes
16 W. Pomfret Street
Carlisle, PA 17013
Re: Pallis v. Pallis
Cumberland County Court of Common Pleas
No. 2001-5796, Civil Term
In Custody
Dear Attorneys:
I am sending you my findings and recommendations regarding custody of Rowan, age
six years, two months, and Jack, age two years, nine months.
The parents, Rachel and Thomas were interviewed at least twice and completed a
number of custody-related questionnaires and forms. These include Life History
Questionnaires, Parent Self-Report Data Forms, Child Management Questionnaires
and personality inventories (Minnesota Multiphasic Personality Inventory-2 (MMPI-2)).
The children were seen with each parent on separate occasions. Rowan was
interviewed and completed family drawings.
I reviewed a considerable amount of collateral data which included copies of court
orders in both Massachusetts and Pennsylvania, pleadings in both states, custody
conciliation summary report, attorney correspondence, hearing transcript of October
1999 regarding
Thorn's petition for special relief, Thorn's extensive electronic journals, personal diary,
logs, telephone records, assorted legal documents related to Rachel, bank
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Drug and Alcohol Treatment~
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correspondence, a letter from Debbie Kuhn, information related to Rowan and Jack
from daycarelKindergarteFl personnel, Rowan's current teacher, and numerous mental
health records reflecting Rachel's diagnosis, care and treatment. These records were
from the United States Naw, Doctors Durning and Nielson, Holyoke Hospital records,
Franco Psychological Asspciates, In Health Associates, Lori Hoggs therapy notes, Out-
Patient Behavioral Health Services, Chambersburg Hospital. Rachel has a major
depressive disorder, of a recurrent nature. She is currently in remission and is taking
an antidepressant, Celexa, 20mgs. The medication is helping her.
RACHEL: (Issues and findings)
Rachel is a twenty-nine year old Dental Assistant and certified Message Therapist. She
reports currently working as a dental assistant four days a week, Monday through
~ Thursday from 8:00 AM to 5:00 PM. She lives alone in a first floor, three-bedroom
home in Boiling Springs.
Both Rachel and Thom live in the same school district. This will allow the children to
attend the same school, regardless of which parent might assume primary physical
custody.
The current custody arrangement is alternating weeks with exchange on Mondays.
This was established as a result of the custody conciliation process in November 2001.
There is one prior separation for about three months in 1999. Rachel was hospitalized
for depression in Massachusetts. Thom took both children, without her consent and
relocated to Carlisle, PA. Rachel reports never being told by Thom directly that he was
leaving Massachusetts. She was not allowed, from self-report, to see the children.
Thom reportedly told Rachel that he was afraid she would try and take the children from
him.
Rachel's ultimate goal is to be primary physical custodian. She acknowledges Thom Is
a good parent. However, she would like one home for the children in an effort to
provide consistent routine, structure and stability for them.
One of Rachel's concerns relates to what she describes as Thom's fantasy concerning
the relationship of his "extended family" in the Carlisle area. These are individuals who
have close ties to Thom. However, they are not biologically related to Thom's mother
or the children. Rachel also raised a concern regarding Thom's family ignoring the
children during Rachel's weeks. She reports offering the paternal grandmother, who Is
very involved in the children's lives, contact with the children when they are with Rachel.
Rachel admits that her desire and preference is to live close to her family in New
Jersey.
If Rachel is awarded primary physical custody and remained in Pennsylvania, she
would support partial custody between Thom and the children to be every other
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weekend In addition to one or two week nights ovemight. She stated wanting the
children to live with her most of the time and repeatedly indicated that she has no
problems with Thom seeing the children as often as he wishes..
Rachel is aware of some of Thom's concerns regarding her as a parent. These Include
a concern about Rachel's discipline/control of the children as well as her treating
Rowan like a "short adult."
Rachel admits to being at a level of loneliness such that it causes her to call Thom at
times during e8ch week. She knows that "his reception is fine...J kinda use him to put
up shelves and to put up the Christmas tree."
Initially, Rachel admitted to being lonely and having little in terms of a support system in
Central Pennsylvania. Her friends, as well as family, are in New Jersey and she admits
that she and Rowan tend to talk openly. Thom expressed a concern about Rachel .
being fIXated on Rowan - for which there is no evidence.
Rachel's concerns about Thorn's parenting relate to his high level of structure and
discipline. She stated that, "he treats the kids like they are In boot camp...the kids are
too scheduled, too strict and too regimented." She understands the need for structure
but presents herself as the more flexible parent. Rachel has a chores chart and will
reward or punish by utilizing gold stars,
Rachel's presentation of her history with Thom is consistent with his. It is my
understanding that counsel is aware of the history so that it need not be presented
herein.
Rachel continues to talk about how she is addressing her being alone. She has joined
the local Civic League in Carlisle and is involved with two councils in her church. At this
writing, she identifies a male friend, Gregg, who is forty-two years old (she is twenty-
nine). Gregg, at this point, is not involved in the children's lives. Gregg lives in New
Jersey.
One of Rachel's concerns about Thom is his continuing concern about an Involvement
with Rachl;ll's personal life. She notes Thom reacting to men in her life. When Thom
was interviewed he denied same.
Regarding the children, Rachel admits to yelling at the children while they are in her
home. She could not really answer why she does this but did indicate that she may
have adopted some of her mother's behavioral characteristics. She said, "I am my
mother.. .we both are aggressive, loud and forceful. ..mother screamed at us..... She
admits that Thom does not yell at the children.
We discussed the possible outcome of the custody. Rachel continued to relate that she
would like to move closer to her family in New Jersey. She acknowledges the children
have a good relationship with the paternal grandmother here as welf as the maternal
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grandmother in New Jersey. She relates her belief that the children will make an easy
adjustment if she is allowed to relocate to New Jersey with them. In the event that the
children live with her in New Jersey she would promote an every-other-weekend contact
between Thom and the children.
Throughout my contacts with Rachel she indicated a preference for the children to
reside primarily in one home.
Rachel's experiences in her own family of origin were not terribly positive. She
described her mother as controlling, domineering and overbearing. Her father is noted
to be irresponsible and somewhat immature. From her description, it appears she had
a somewhat abusive mother and an absent father. Rachel stated that her mother was
loud and sometimes violent, with Rachel, indicating that "we were regularly hit and
things were frequently thrown." Things that she would change about her parents as
they were raising her were for her dad to be "more coherent and available. I'd make my
mom calm down and be less angry." Rachel likes her tendency to reach out and
experience life. She acknowledges that she does not trust easily, noting, "it takes me a
long time to feel safe with someone new." As she was growing, she really could not
depend on either biologicel parent to be there to confide in and talk with her. Often
times, she would turn to her maternal grandmother. As a child, Rachel also notes that
there is an extensive history of alcohol and possibly alcoholism In her family.
Rachel's job history reflects her working as a waitress, customer service
respresentative. medical assistant, assistant store manager and currently dental
assistant. She is also a Certified Massage Therapist. Educationally, she was an
average student in high school but lost some focus and direction in college. She did,
however, do well in technical school.
Rachel acknowledges major depression beginning in 1994, with her being subject to
psychological and psychiatric treatment since then. As noted, there are no current
impairments caused by her condition.
Rachel further notes that as she and her parents mature, their relationship becomes
stronger with one another. She reports having the support of her family, should she
receive primary custody of the children.
Rachel has had contact with the criminal justice system. Many years ago, while living in
Califomia, she was arrested for possession of mace. Those charges were dismissed.
She was also arrested for theft and forgery. That record also has been expunged.
Current stressors Rachel Identifies are money and parents, saying, "' try to respect
what they have to say while maintaining my own perspective." This is somewhat
inconsistent with the prior notation shared by Rachel regarcling a less-strained
relationship with her parents. She admits to continued loneliness and finally identifies
the disillusion of the marriage with Thom as her final stressor.
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There is no identifying drug or alcohol use. As hobbies she notes reading, crocheting
and watching movies.
Rachel presents a typical relationship with her child~n during her week. It should be
noted that the children are with the paternal grandmother or daycare on Mondays. It is
my understanding that typically, they are with their grandmother every Monday. There
is nothing particularly noteworthy about her weekly ~utine, Rachel spends as much
time as she can carve out in New Jersey with her friend Gregg, as well as her mother,
stepfather, and siblings.
The greatest obstacle Rachel identifies at this point in time Is with Thom, who she
describ's believing that, "I am a possession rather than a person: She would like
Thom to focus more about himself and the children end leave Rachel alone. She
correctly identifies that the only things she and Thom need to discuss at this point in
time should relate directly to the children.
Rachel sees the importance of working with Thorn in an appropriate and effective co-
parenting relationship. She believes that relationship can improve by keeping focused
on the ohildren and by maintaining a willingness to compromise with one another.
Rachel describes Rowan as a confident, intelligent, friendly and energetic youngster
who is also stubborn and often defiant. She sees Jack as a bold, funny, smart, gentle
and an independent youngster who is fearless and fresh. She believes that the children
will benefit as both parents continue to show unconditional love and support, Rachel
notes that she can gently correct the children's inappropriate behavior but also states
that she will yell and then give time-out or remove a privilege. DUring the course of data
collection, I loaned Rachel a video (1-2-3 Magicl), which she seemed to enjoy.
Regarding child management techniques, Rachel has a goOd sense as to what should
be done. For example, she will use explanation, time-out and removal of privileges.
She has a good value system and is able to impart appropriate and acceptable
behaviors to her children. However, she may be somewhat strained at this time in her
relationship with the children, given that her own personal life Is not settled.
Rachel's personality inventory was valid. Consistent with parents going through
custody evaluations, her profile was somewhat defensive with some reluctance to admit
to problems.
People with Rachel's profile create a good first impression, but tend to have many
interpersonal problems. Forming warm, intimate relationships can be difficult. Her
interpersonal problems seem to have their origin in a long history of Inadequate family
and social relationships. Socially, people with Rachel's profile are noted to be
gregarious, outgoing, and social Individuals with good social techniques.
Rachel endorsed items which share a common theme of rebelliousness or resistiveness
or a chafing under the constraints of authority, custom or propriety, Reactive defiance
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to demands m8de by others can be seen. People with Rachel's profile also evidence
characteristics usually seen as desirable: adventurousness, spontaneity, energy and
assertiveness. Even rebelliousness can serve important and highly positive social
functions in certain circumstances and situations. Her scales are consistent with an
Individual who is extroverted, energetic, and generally uninhibited-who may have some
impulsive tendencies.
Rachel has good ego-strength. There is no evidence in her profile of any major clinical
depression or significant anxiety, which would impair her parenting of the children.
Regarding anxiety, Rachel does admit that she is a high-strung person and also admits
to some continuing sleep difficulties. She reported some insomnia (Initial, middle, as
well as early-morning awakening). This is consistent with a depressive disorder.
Further, RaChel admits to internalizing a lot of her feelings and emotions. She also
admits to a history of suicidal ideation with no incidents noted in the last year or year-
and-a-half. Rachel seems sufficientty integrated at this point in her life so that if she is
not awarded primary physical custody, it is unlikely that she would engage in any
suicidal-related thinking/behavior.
THOMAS: (Issues and findings)
Thomas is a thirty year-old Information TeChnologist on contract with the US Navy
through BAE Systems. He needs to put in eighty hours In a two-week period. He has
flextime so long as those hours are fulfilled. He states that he works less on weeks that
he has the children.
Thom's goal is to be primary physical custodian. He would like the children to have a
"home base...8 stable setting~ and believes he is the parent who can provide more
stability, routine, rhythm, structure and appropriate discipline to the children. He states
not wishing to deny Rachel being with the children, but has a number of concerns about
Rachel. These include a history of multiple relations, emotlanallnstability, what he
describes as compulsive lying and behaviors, which from his perspective, put the
children secondary to her personal and social life. Thom also talked about Rachel's
dependent behavior upon him, citing many illustrations reflecting Rachel contacting
Thorn to come over to her home and spend time for what he believed to be spurious
reasons.
If he is awarded primary physical custody, Thorn would use his mother as a babysitter.
Currently, the children are with the paternal grandmother on Mondays of every week.
If awarded custody, Thom would promote every other weekend with Rachel.
Thorn presents himself as the parent who is spending more time with the children. He
takes Rowan to activities including Girl Scouts (Daisy's), the first and third WedneSdays
of each month. He is also an assistant scout leader for Rowan's troop. He also takes
her to Gymnastics on Tuesday afternoons. .
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In addition to Thom giving examples reflecting Rachel choosing to be with the children
when it is convenient for her, he talked about his perception of her being overwhelmed
when she has to care for the children for any length of time. He believes that she has
trouble dealing/handling/controlling the children. When the children are not compliant,
he relates that Rachel tends to repeat herself and will lose her COmposure if she finds
that her reasoning isn't effective. Thom presented detailed logs/diaries with examples
containing his experience with Rachel.
Thom could not identify any criticisms of his parenting of the children from Rachel. He
admits to being structured and routinzed. Thom's statements as well as his logs reflect
that he has the children for some hours to almost a full day on Rachel's weeks.
Thorn denies using the children to get information about Rachel. He states that he
could, "care less about what she's doing." He does indicate, "she keeps trying to come
over to my house." Repeatedly, Thom referenced Rachel reportedly calling him when
she's lonely which occurs about two times per week.
Thom explained why he has his phone blocked. He relates his reasoning to bill
collectors who apparently are looking for Rachel.
Thom's experiences in his own family of origin were somewhat troublesome. He
describes his father as headstrong, stubborn and demanding. Apparently his parents
had a highly dysfunctional and. at times, volatile relationship prior to divorcing when
Thom was young. He recalls spending time in a shelter with his mother when he was
about age eleven. This was a very unpleasant and distressing experience for him.
Although he does not recall being criticized, he does recall being yelled at with his being
subject to some exclusion by being sent to his room without explanation. If he could
change things about how his parents related to him as he was maturing it would be to
"have them be more understanding and supportive." Thom has learned to be self-
sufficient and independent. His greatest period of personal growth and development
occurred during the time he was on active duty with the United States Navy. He
benefited from the structure, support, directlon and regimentation provided by the
Service. That period of time in his life assisted Thom in gaining a measure
independence and self-sufficiency. It helped compensate for the suggested absence of
both parents as he was growing. After the divorce he rarely saw his father. His mother
had to work long hours to support Thom and his brother.
Thom's earty educational history is somewhat fuzzy to him, He moved around quite a
bit but he does report attending three to four elementary schools. He completed his
senior year and graduated from high school when he lived with his father. He stated
"the whole time I attended school I felt that I never fit in. I felt this was a result of all the
moving around that I did." As noted, he felt that his time in the Navy, ''was my
awakening in life and I am thankful for joining the military." Combined experiences of
his time with his family and the time in the military has Influenced Thom's child
management techniques as well as his typical approach and orientation to things. He
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tends to be very orderly, somewhat compulsive in his approach and at times may be a
bit rigid.
Thorn states that he would like to co-parent with Rachel. He identifies the current
obstacles in their relationship as his lack of trust in Rachel's honesty and level of
responsibility. He did state that "I think the only thing that can improve this Is
communication with lots of feedback and in time I will be able to trust her." This is a
very positive, optimistic and forward-looking statement. He would like to work with
Rachel in an effort to provide the children "a stable and happy environment In which
they can grow up."
Thorn's discipline of the children is characterized by his being calm and firm but
cOn!listent. He also shapes positive behaviors by acknowledging, praising and
reinforcing them when they are engaging in behaviors he wishes them to continue.
Similar to Rachel, he would use an explanatory/educational approach initially and then
would introduce relevant punishment such as removal of privileges or time-out for two
to five minutes. Thom has acquired a good work ethic and a positive value system and
imparts this to the children.
Thorn's personality profile pattern suggests a very favorable presentation of self. He
presented socially approved answers, which are typically givBn by a person who is
concerned about how the personality findings might be used. Generally, individuals
with this profile tend to be somewhat defensive and reluctant to admit to problems.
Specific answers denote a trusting attitude, naive optimism, denial of negative feelings
about others and imply a need for affection. People with his profile tend to be clear-
thinking. They also tend to avoid other people because they may feel uneasy. They
are usually content being alone.
All of Thom's clinical scales were within normal limits. There are no personality traits
and characteristics noted in his profile that would be troublesome to his parenting.
Common characteristics in people with his profile include competitiveness,
persuasiveness, with a value on achievement, recognition, status and success. They
tend to be socially uncomfortable but will take social initiative and be verbally fluent.
His scores indicate a suppression of emotional material. Thorn's ego strength appears
strong. There are no Issues conceming anger management or temper control. His
answers indicate adherence to his value system. There is no evidence of any anxiety
or depression that would Impact his ability to parent children.
T~om's profile is also consistent with individuals who may make demands and plans
With expectations of others with a dislike when reciprocal demands are made on
themselves. They often times see themselves as mistreated with a reluctance to admit
to their own provocativeness. This may relate to some behaviors noted by Rachel.
MARGURITE PAMILLA SAYLOR (Pam)
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Margaruite (Pam) is the paternal grandmother of Rowan and Jack. She is a newspaper
editor for the Carlisle Sentinel and typically worl<stwelve-hour days but takes hours off
during her day so it is generally a typical workday, She currently lives with Carol Talley
and members of her "extended family." She has been with them since the late sixties.
Although Pam sees the children typically on Mondays, she does not report any regular
set of duties or responsibilities for the children. Monday is her day with the children
unless Thom or Rachel is available. There is no continuing strong relationship with
Rachel at this time.
Pam expressed some concems about Rachel's behavior mentioning Rachel stealing
Carol Talley's credit card and Rachel's hospitalization (1999). Pam admits to a
personal conflict in that as a newspaper editor, she is trained to look at both sides of an
issue but in this case, admits that her own bias may influence her.
Pam also q.uestions Rachel's truthfulnesAnd credibility. However, she is pleased that
Rachel has always fostered a relationship between herself and the children. There
were no specifics proffered regarding Rachel's credabillty issues.
Pam is concerned about the possibility of Rachel's Pliat suicidal ideation. She
questions if these might recur with no warning. She also sees Rachel as impatient.
She q.uestions Rachel's emotional stability and, consistent with Thorn, also describes
Rachel as self-focused.
Pam has not seen any neglect or abuse by either parent. Her biggest concern about
Thom asa parent is that he may be "a little too much of a parent...he may
overcompensate..." This appears to relate to Thom's efforts to perhaps compensate
for the lack of an appropriate parenting presence as a result of his parents
separation/divorce.
Pam is proud of how Thom supports Racltel and the children.
ROWAN AND JACK
The children were observed with each parent. Thom and the children were observed in
the waiting room. He had one child on each side while he read to them. In the
playroom Thom was on the floor playing with the children. He provided structure and
direction with a soft, attentive and focused manner. He was responsive to both children
and remained actively involved.
Thom taught the children how to play Hungry Hippos and insured that Jack would be
successful. He reinforced. He also taught Jack how to approach a construction-type
activity. He was creatively suggestive to both children,
Rachel seemed a bit uncomfortable with the observation. Initially, she was on the
couch watching as Rowan and Jack played with a marble game. Once told that it was
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okay for her to freely interact, she relaxed a bit and did get on the floor with the
children. She and Rowan played Connect Four and she was successful in engaging
both children, exercising direction and control. Rowan complained that the game was
"too hard.' Rachel encouraged her to continue and, they did. Rachel encouraged
independence. They played Candyland together. Rachel let Rowan direct/assist Jack
initially which set up some rivalry. She reinforced verbally. Jack eventually got
frustrated and threw game pieces on the floor. Rachel enforced the rule of putting one
thing away before doing another.
Generally, this was a highly verbally interactive time between mother and children.
Rachel mediated conflict (mild whining) between the'chlldren successfully.
Rowan was interviewed on separate occasions when brought in by each parent. There
is a preference by Rowan toward her father who she sees as yelling less and more
supportive in lending assistance. She identifies her father as the parent who can get
things settled down the best. Her mother's yelling was noted by Rowan regardless of
which parent accompanied her.
Letters were received from persons familiar with Rowan. Joy Griffith has known Rowan
since Rowan was In Ms. Griffrth's Childtime kindergarten class, She describes Rowan
as a sweet, kind, lovable little girl. Additional observations from Childtime Child Care
Center note no significant change in Jack's behavior since Thom and Rachel's
separation. An aide to Rowan's current teacher describes Rowan as a happy, well-
adjusted kindergartener who behaves beautifully in class. Rowan's current teacher
does not have any concem about Rowan's behavioral performance.
Both parents are to be commended for containing their own issues, disagreements,
perspectives and interpersonal behaviors. The children have apparently not been
Impacted or negatively affected to this point in time.
Both parents wish for the children to reside primarily, during the school week, in one
home. Based on my findings, observations, interviews, test results, review of
background information as well collateral data, I am recommending that parent to be
the father. Thom utilizes more appropriate child management techniques, has the
personality to continue to provide the structure, discipline and routine for the children, is
more settled in his personal and social life at this time, is emotionally more stable and
independent.
It is critical that Thom understand the need to keep Rachel frequently and actively
involved In the children's lives. She should be given the right of first refusal, that is, If
he is unavailable to be with the children, he is to contact Rachel first prior to identifying
his mother or any other substitute babysitter/caretaker. He states that he will ensure
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continuing contact between Rachel and the children. His being the primary physical
custodian will also ensure the children's continuing contact with other persons
significant in their liVes.
Stanley E. chne der, Ed.D, R, .E.
Psychologist
Registered Custody Evaluator
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THOMAS E. PALLIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
RACHEL S. PALLIS,
Defendant 01-5989 CIVIL TERM
IN RE: CUSTODY AGREEMENT
Proceedings were held before the
HONORABLE KEVIN A. HESS,
Cumberland County Courthouse, Carlisle, Pennsylvania,
Courtroom Number Four,
August 14, 2002.
APPEARANCES:
REBECCA HUGHES, ESQUIRE
For - the Plaintiff
THOMAS DIEHL, Esquire
For - the Defendant
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1 August 14, 2002
2 Carlisle, Pennsylvania
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4 (Whereupon, the proceedings were held
5 at 12:51 p.m.)
6 THE COURT: I understand at least for today there
7 is an understanding.
8 MS. HUGHES: That is correct, Your Honor.
9 THE COURT: Okay. I think you will have it read
10 into the record, and have it transcribed, but not in the form
11 of an order. We have to leave here with the understanding
12 that that is the Order of Court, so the mere fact that the
13 order is still in preparation is no reason to deviate from it.
14 Go ahead.
15 MS. HUGHES: Your Honor, the parties have agreed
16 to the following:
17 Both mother and father shall have shared legal
18 custody of the two minor children. Primary physical custody
19 shall be with the father. Mother shall have periods of
20 partial physical custody as follows:
21 Every other weekend from Friday after work until
22 Monday morning when mother shall take the children to
23 school
24 DR. SCHNEIDER: They didn't agree she will take
25 them to school. They will make sure they get to school. She
2
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1 may have to take them to school.
2 MS. HUGHES: -- until Monday morning when mother
3 will be sure to have the children at school or daycare,
4 whichever may apply.
5 Every Thursday evening from after work until
6 8:30 p.m., and following the father's weekend from Monday
7 after work until Tuesday morning, at which time mother shall
8 be sure to have the children either at daycare or school.
9 The first weekend of each month that is scheduled
10 to be the mother's shall be an extended weekend, which shall
11 begin Thursday evening after work through Monday morning.
12 And the week following the mother's weekend,
13 mother shall have Tuesday evening until after work until
14 8:30, as well as Thursday evening after work until 8:30.
15 Your Honor, Dr. Schneider now will provide
16 additional parts of the order.
17 DR. SCHNEIDER: Regarding the right of first
18 refusal, the parents agree that they will notify the
19 non-custodial parent if they cannot be with the child in
20 excess of three hours -- after a three-hour period of time.
21 If the non-custodial parent requests a temporary
22 modification in the schedule, such notification will be given
23 to the custodial parent a week in advance. I hope that is
24 clear.
25 If there is a temporary change in the schedule
3
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because of an emergency situation, the parents agree to make
up an equal amount of time within a 3D-day period, unless they
agree otherwise.
That's to cover -- for example, if the father may
be assigned to go out of state for work, he would like his
time made up, unless he says, Forget it. That is basically
what I heard them agree to. Correct?
MR. PALLIS: Yes.
DR. SCHNEIDER: Both parties agree in principle
that the children need to be with one another on an identical
schedule, as much as possible.
That relates to a discussion, which was very
brief, given the difference in age of a three-year-old and a
six-year-old. And they both want the children on a similar
schedule, regardless of their age. And with passage of time
they recognize that the children will introduce modifications
based on their commitments --
THE COURT: True.
DR. SCHNEIDER:
and developments as they grow
and mature.
Both parents agree to no display of affection with
a non-family third party, boyfriend/girlfriend, in front of
the children. Similarly, they agree to no adults outside of
family sleeping over at the custodial parents' home. So when
the children are there, no outsiders will sleep over, is the
4
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1 intent.
2 MRS. PALLIS: Family is okay.
3 DR. SCHNEIDER: Family is okay.
4 THE COURT: I'm sorry. I didn't hear that.
5 DR. SCHNEIDER: Family is okay.
6 In the event that there is no school on a Monday
7 following the mother's weekend, they both agree that the
8 children will be with their mother, if she is available for
9 that entire day.
10 Regarding holidays, the parents agree that
11 beginning this year, and every even year after this, the
12 children will be with the mother on Thanksgiving.
13 Thanksgiving is defined by the parents as beginning Wednesday
14 night after work until Monday morning.
15 Beginning this year 2002 and every even year
16 thereafter, the parents agree they will be with the father on
17 Christmas. The parents define Christmas as beginning by noon
18 on December 24th and ending by noon on December 26th. That
19 will allow travel time in the event mother goes to New Jersey
20 where her family resides to get them back in time.
21 They agree to alternate Easter on a similar annual
22 schedule. Easter is defined as beginning Saturday at noon and
23 ending Monday -- I wrote down Monday evening.
24 MR. PALLIS: I am not sure. I thought
25 DR. SCHNEIDER: Or Monday morning.
5
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1 MR. PALLIS: Rachel said she would get them back
2 to school.
3 DR. SCHNEIDER: Monday morning.
4 MRS. PALLIS: They are off school.
5 DR. SCHNEIDER: Just so they have off school
6 Easter Monday.
7 THE COURT: What year will it start with?
8 DR. SCHNEIDER: Who had it last year, if you
9 figure?
10 MR. PALLIS: I have them Christmas. How would
11 Easter fall as?
12 MRS. PALLIS: Let me see. I can tell you quickly
13 who had them Easter of this year.
14 DR. SCHNEIDER: Okay. There is no summer schedule
15 yet. The parents agree to meet with me in my office sometime
16 in February 2003 to work out two points: One, a summer
17 schedule; and secondly, to determine the kids' adjustment
18 the children's adjustment to the agreed-upon current weekend
19 per month to be expanded to two extended weekends per month.
20 You guys are better at this legal stuff than I am.
21 THE COURT: And the expectation being if it worked
22 otherwise unremarkedly, it will be automatically extended to
23 two per month.
24 MRS. PALLIS: Dr. Schneider, Tom had them this
25 past Easter.
6
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DR. SCHNEIDER: It will be --
THE COURT: Your meeting in Easter will occur
undoubtedly before that anyway.
DR. SCHNEIDER: We will be talking about summer
schedule.
THE COURT: No need to talk about Easter if you
don't have to.
DR. SCHNEIDER: Mother's Day with mother.
Father's Day with father. Birthdays wherever the kids are is
where they will be celebrating, whichever parents they are
with. Labor Day, whichever parent has the kids, keeps the
kids. Same with Columbus day. New Year's was omitted.
New Year's -- they agreed that New Year's will be
with the same parent who has them Christmas. New Year's is
defined by beginning noon December 31st until the next school
morning, whenever that is -- Monday or Tuesday, whenever it
is. Right?
MS. HUGHES:
Yes.
DR. SCHNEIDER: Regarding communication, I don't
know if it should be in the Court Order or not, but I at least
want it in the --
THE COURT: It is a common subject of Court
orders.
DR. SCHNEIDER: All right. Given their lack of
trust and inability to communicate, they both adopted the
7
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1 negotiation that emailing one another may be an appropriate
2 way to communicate.
3 And in that regard, Tom has offered and Rachel has
4 accepted his putting together a computer for the express
5 purpose of allowing her to have the computer to E-mail back
6 and forth.
7 THE COURT: Okay.
8 DR. SCHNEIDER: Is that right?
9 MR. PALLIS: Yes.
10 DR. SCHNEIDER: Rachel?
11 MRS. PALLIS: Fine.
12 DR. SCHNEIDER: If I might indulge the Court for a
13 moment.
14 (Discussion off the record)
15 DR. SCHNEIDER: Is there anything else?
16 MR. PALLIS: I think we've covered it all.
17 DR. SCHNEIDER: Do you understand what joint legal
18 custody means?
19 MRS. PALLIS: I think so.
20 DR. SCHNEIDER: You've got a physical schedule in
21 place. The only modification of that will be summer, and the
22 automatic expansion of that, Tom, assuming the kids do well
23 with the current extended time with Rachel. And you are going
24 to have to produce evidence that they are not. So the burden
25 is on you.
8
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MRS. PALLIS:
Right.
Did you say the first weekend is
3 mine?
4 DR. SCHNEIDER: Yes, the first weekend is the
5 expanded weekend.
6 THE COURT: When is that on the calendar?
7 MS. HUGHES: The first weekend that is scheduled
8 to be hers per month will be the extended.
9 DR. SCHNEIDER: Starting with September?
10 MS. HUGHES: Starting with September, yes.
11 THE COURT: We all know what weekend, that is my
12 point. I need to say in the order commencing --
13 MS. HUGHES: Now, school starts August 26th. So
14 the question is if Rachel has the following weekend, does that
15 take us into September? I am trying to think, here.
16 THE COURT: The following weekend is the 29th,
17 30th, and 1st.
18 MS. HUGHES: Okay. So that --
19 THE COURT: Which is also Labor Day.
20 DR. SCHNEIDER: Labor Day they agree wherever they
21 are, is where the children are.
22 (Discussion off the record.)
23 MS. HUGHES: September 5th through the 10th, first
24 weekend, first extended weekend. September 5th through the
25 10th.
9
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2
THE COURT: I don't think she got your
3 conversations down so recap now for the record what the next,
4 let me say, three weeks looks like, just so we all understand.
5
MS. HUGHES: Rachel will return the children
6 Rachel, you have the children now; is that correct?
7
MR. PALLIS: Whatever you attorneys worked out.
8
MS. HUGHES: Beginning the week of August 19,
9 Rachel will have the children through August 26th. Father
10 shall have the children beginning August 26th, and that will
11 start the new schedule that we just went through. Therefore
12 mother will have Tuesday evening the 27th, and Thursday
13 evening the 29th from after work until 8:30.
14 Father shall have the weekend of the 30th through
15 September 1st. Mother shall have the evening of September 2nd
16 through September 3rd and also Thursday evening from after
17 work until 8:30 -- no, from after work until September 5th
18 through after work until September 10th -- no, September 9th.
19 I'm sorry.
20
THE COURT: I thought --
21
MS. HUGHES: This calendar starts on a Monday. I
22 am used to it starting on a Sunday. So mother shall have the
23 children then from Thursday, September 5th from after work,
24 until Monday September 9th, and that will be her first
25 extended weekend.
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1 THE COURT: Okay. And then --
2 MS. HUGHES: And it shall continue from then on.
3 MR. FALLIS: First weekend she has them in the
4 month.
5 THE COURT: Anything else?
6 DR. SCHNEIDER: Yes, I have two points.
7 Transportation. What about the custodial -- the parent
8 assuming custody will pick up?
9 MS. HUGHES: Have you been able to work that out?
10 DR. SCHNEIDER: It's not been an issue. Do you
11 want anything else in the court order?
12 MR. PALLIS: Ruann (phonetic) will be riding the
13 bus from my house. Whether she chooses to drop her off --
14 DR. SCHNEIDER: You don't want anything about
15 transportation. Okay. I have a request. I did not mention
16 to either of you, but it occurred to me, I would like to
17 receive copies of your E-mai1s so I can kind of track what is
18 going on, and not be surprised when we reconvene.
19 MRS. FALLIS: Courtesy copy them to you? Do you
20 want--
21 DR. SCHNEIDER: The question is, What is my E-mail
22 address. I don't know. If you could call my office.
23 MS. HUGHES: "Ask my secretary."
24 DR. SCHNEIDER: I know what it is at home, but my
25 office has -- I don't know what it is. I don't E-mail myself.
11
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1 But if that is okay with you guys, I would like to get
2 courtesy copies to track what is happening. Is that okay with
3 you?
4 MR. & MRS. PALLIS: Yes.
5 DR. SCHNEIDER: How long will it take?
6 MR. PALLIS: By the middle of September.
7 DR. SCHNEIDER: Is that acceptable?
8 MR. PALLIS: I will try to do it faster than that.
9 DR. SCHNEIDER: No later than September 15th?
10 MR. PALLIS: Sure. It will be much sooner than
11 that.
12
13
14 address.
15
16
17
18 would be
MRS. PALLIS: I don't have a choice in the matter.
MR. PALLIS: She has to provide the E-mail
THE COURT: Okay.
DR. SCHNEIDER: Thank you, Your Honor.
THE COURT: Well, thank you, Dr. Schneider. I
amiss if I didn't make a note on the formal record
19 here of your great help this morning in resolving this. I
20 don't think I can think of a case where you came in for one
21 purpose and stayed for another, but I am glad you did.
22 And I congratulate the parties on working out an
23 arrangement. It's not that I didn't feel like sitting and
24 listening to a custody case all day. Well, maybe I didn't,
25 but that is what they pay me to do, and I have no trouble
12
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1 doing that.
2 But the fact that you are able to settle the case
3 is important for other reasons. First of all, I am satisfied
4 that it's a general rule that if parties reach an agreement as
5 to a schedule, it is invariably better than something that I
6 would impose on you. It's always going to be better.
7 And secondly, and most importantly, it reflects
8 your ability to put your love of these children ahead of your
9 personal dislike for each other. And that is something you
10 are going to have to work at doing -- in the case of one of
11 these children
for another 15 years. And that is a heck of
,
,
12 a long time.
13 You think you've got problems now agreeing, wait
14 until you decide who is going to teach them to drive, and what
15 kind of sneakers you are going to buy, whether they are going
16 to be in the high school band. It gets more and more
17 interesting. Mr. Diehl, you have another case.
18
MR. DIEHL: I have to run down the hall briefly.
19
MS. HUGHES: Thank you, Your Honor.
20
(Whereupon, the proceedings concluded at
21
1:12 p.m.)
22
23
24
25
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CERTIFICATE
6 I hereby certify that the proceedings are contained
7 fully and accurately in the notes taken by me on the above
8 cause and that this is a correct transcript of the same.
10
11
9
12
13
14
15
}JJM._
16 The foregoing record of the proceedings on the hearing
17 of the within matter is hereby approved and directed to be
18 filed.
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19
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At""/' 3-1 [..0112.-
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A. Hess, J.
Judicial District
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RACHEL S. PALLlS,
PlaintifflPetitioner
VS.
THOMAS E. PALLlS,
Defendant/Respondent
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 2001-5989 CIVIL TERM
IN DIVORCE
DR# 31215
PacseS# 301104045
NOTICE OF RIGHT TO REOUESTA HEARING
The parties are hereby advised that they have until October 5. 2002 to request a hearing do novo
before the Court. File request in person or mail to:
Office of the Prothonotary
1 Courthouse Square
Carlisle, PA 17013
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RACHEL S. PALLlS,
PlaintifflPetitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
THOMAS E. PALLlS,
Defendant/Respondent
NO. 2001-5989 CIVIL TERM
IN DIVORCE
DR# 31215
PacseS# 301104045
DEMAND FOR HEARING
DATE OF ORDER: September 24,2002
AMOUNT: N/A
FOR: Suspension of Alimony Pendente Lite
REASON(S):
API. hQa no" be.cl'\ -pa..id. \'" o...C.6"do."",,-. wi\-!.. thL"OU'+
o~d,..~ d...~e.d I \.a\ ooz.. tll"~ha.d) M,/ .\in'!' f"O"t.....,,+ w.....Y=e..\"..d . ';"
lo.\c. M4..n.I.. ?"^1 M'I +lno.\ i"4y"'....+ WOIS ......c.&',,,..c:l i...m;d. ~.J>J,e...\"'... 2002..
1. ho..... Q.-\\l'lnlr.&.,d -the. VA scnu r...I'#''f+S'. lhlAl'\\..t"J. .
1\.,~ a......ou..+ oP '"'-... Q.l"r<<.Ar$ .s\-...~ \n '"-... o"c\c.ir " ~ .nCe> ..r..",t.
PARTY FILING DEMAND FOR HEARING:
~
ignature
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Date
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DR 31215
PACSES ID 301104045
vs.
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: DOMESTIC RELATIONS SECTION
: CIVIL ACTION - LAW
RACHEL S. PALLIS,
Plaintiff/Petitioner
THOMAS E. PALLIS,
Defendant/Respondent : NO. 2001-5989 CIVIL TERM
ORDER OF COURT
AND NOW, this 15th day ofJanuary, 2002, based upon the Court's determination that Petitioner's
monthly net income/earning capacity is $1,581.00 and Respondent's monthly net income/earning
capacity is $3,023.3 1, it is hereby Ordered that the Respondent pay to the Pennsylvania State
Collection and Disbursement Unit, $395.00 per month payable bi-weekly as follows; $182.31 bi-
weekly for alimony pendente lite and $0.00 on arrears. First payment due next pay date. Arrears set
at $790.00 as ofJanuary 15,2002. The effective date of the order is November 21,2001.
Collection on the retroactive arrears is held in abeyance until after demand for hearing time has past
and if there is a demand for hearing the abeyance will be continued until disposition of the support
master.
Failure to make each payment on time and in fun will cause all arrears to become subject to immediate
collection by all of the means as provided by 23 Pa.C.S.9 3703. Further, if the Court finds, after
hearing, that the Respondent has winfully 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 PA SCDU to: Rachel S. Pallis. Payments must be made by
check or money order. All checks and money orders must be made payable to P A SCDU and mailed
to:
PASCDU
P.O. Box 69110
Harrisburg, P A 17106-9110
Payments must include the defendant's P ACSES Member Number or Social Security Number in order
to be processed. Do not send cash by mail.
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Respondent to provide medical insurance coverage.
This Order shall become final ten days after the mailing of the notice ofth~ entry of the Order to the
parties unless either party files a written demand with the Prothonotary for a hearing de novo before
the Court.
DRO: R. J. Shadday
Mailed copies on
1-15-02 to: <
BY THE COURT,
Petitioner
Respondent
Thomas Diehl, Esquire
Rebecca Hughes, Esquire
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EdgarB. Bayley
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
RACHEL S. PALLIS ) Docket Number 01-5989 CIVIL
Plaintiff )
vs, ) PACSES Case Number 301104045
THOMAS E. PALLIS )
Defendant ) Other State ID Number
ORDER OF COURT
You,
plaintiff/defendant of
THOMAS EVANGELO PALLIS
46 BRIAN DR, CARLISLE, PA. 17013-4373-46
are ordered to appear at DOMESTIC RELATIONS HEARING RM
DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13
before a hearing officer of the Domestic Relations Section, on the
DECEMBER 13, 2002
at 8 : 3 OAM for a hearing.
You are further required to bring to the hearing:
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I. a true copy of your most recent Federal Income Tax Return, including W -2s, ;;'?f11
2. your pay stubs for the preceding six (6) months,
3. verification of child care expenses, and ."'_
4. proof of medical coverage which you may have, or may have available to yoti5~~"S
5. information relating to professional licenses .~ :~ c:s
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WorkerID 21302
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FALLIS
v. FALLIS
PACSES Case Number: 301104045
If you fail to appear for the conference/hearing or to bring the required documents, the
court may issue a warrant for your arrest or enter an order in your absence. If paternity is an
issue, the court may enter an order establishing paternity.
The appropriate court officer may enter an order against either party based upon the
evidence presented without regard to which party initiated the support action.
j
Date of Order: ~11-4l 02-
BY THE COURT:
Q:7J~~
.mnGE
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND
REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD
ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU MAY GET LEGAL HELP:
CUMBERLAND CO BAR ASSOCIATION
2 LIBERTY AVE
CARLISLE FA 17013-3308-02
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of CUMBERLAND County is required by law to
comply with the Americans with Disabilities Act of 1990. For information about accessible
facilities and reasonable accommodations available to disabled individuals having business
before the court, please contact our office at: (717) 240-6225. All arrangements must be
made at least 72 hours prior to any hearing or business before the court. You must attend the
scheduled hearing.
Service Type M
Page 2 of2
Form CM-509
Worker ID 21302
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
RACHEL S. PALLIS ) Docket Number 01-5989 CIVIL
Plaintiff )
vs. ) PACSES Case Number 301104045
THOMAS E. PALLIS )
Defendant ) Other State ill Number
ORDER OF COURT
You,
RACHEL S. PALLIS
plaintiff/defendant of
207 FRONT ST, PO BOX 34, BOILING SPRINGS, PA. 17007-0034-34
are ordered to appear at DOMESTIC RELATIONS HEARING RM
DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13
before a hearing officer of the Domestic Relations Section, on the
DECEMBER 13, 2002
at 8 : 30AM for a hearing.
You are further required to bring to the hearing:
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I. a true copy of your most recent Federal Income Tax Return, including W-2s, a~:,:fi. .:.!
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3. verification of child care expenses, and ..,
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4. proof of medical coverage which you may have, or may have available to you ;.C~-,
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5. information relating to professional licenses
6. other:
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Service Type M
Form eM-509
Worker ill 21302
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PALLIS
V. PALLIS
PACSES Case Number: 301104045
If you fail to appear for the conference/hearing or to bring the required documents, the
court may issue a warrant for your arrest or enter an order in your absence. If paternity is an
issue, the court may enter an order establishing paternity.
The appropriate court officer may enter an order against either party based upon the
evidence presented without regard to which party initiated the support action.
Date of Order: II 14 02
BY THE COURT:
Q7J'1~
,
JUDGE
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND
REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORl)
ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU MAY GET LEGAL HELP:
CUMBERLAND CO BAR ASSOCIATION
2 LIBERTY AVE
CARLISLE PA 17013-3308-02
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of CUMBERLAND County is required by law to
comply with the Americans with Disabilities Act of 1990. For information about accessible
facilities and reasonable accommodations available to disabled individuals having business
before the court, please contact our office at: (717) 240-6225. All arrangements must be
made at least 72 hours prior to any hearing or business before the court. You must attend the
scheduled hearing.
Service Type M
Page 2 of2
Form CM-509
Worker ID 21302
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RACHEL S. PALLIS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2001-5989
CIVIL TERM
THOMAS E. P ALLIS,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE/CUSTODY
THOMAS E. P ALLIS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2001-5796
CIVIL TERM II
RACHEL S. PALLIS,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
PRAECIPE TO WITHDRAW AND ENTER APPEARANCE
TO THE PROTHONOTARY:
Please withdraw the appearance of Thomas S. Diehl, Esquire, on behalf of Rachel 1.
Date: l':i -l, -O~
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Thomas S. Diehl, Esquire
One West High Street
Carlisle, Pennsylvania 17013
(717) 240-0833
Pallis, in the above-captioned cases.
TO THE PROTHONOTARY:
Please enter the appearance of Carol J. Lindsay, Esquire, on behalf of Rachel 1. Pallis in
the above-captioned cases.
Date: ) 2/} I 7(0 2-/
/ I
Carol J. LindsilY,
26 West Hig' Set, Suite 208
Carlisle, Pennsylvania 17013
(717) 243-6222
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v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2001-5989 CIVIL TERM /'
RACHEL S. PALLIS,
Plaintiff
THOMAS E. PALLIS,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE/CUSTODY
THOMAS E. PALLIS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2001-5796
CIVIL TERM
RACHEL S. PALLIS,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
PRAECIPE TO WITHDRAW AND ENTER APPEARANCE
TO THE PROTHONOTARY:
Please withdraw the appearance of Thomas S. Diehl, Esquire, on behalf of Rachel L.
Date: l~ - Co -O~
jj/J)
Pallis, in the above-captioned cases.
Thomas S. Diehl, Esquire
One West High Street
Carlisle, Pennsylvania 17013
(717) 240-0833
TO THE PROTHONOTARY:
Please enter the appearance of Carol J. Lindsay, Esquire, on behalf of Rachel L. Pallis in
the above-captioned cases.
Date: J 1/7 ( () 2--/
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Carol 1. Linds ,
26 West Hig Set, Suite 208
Carlisle, Pennsylvania 17013
(717) 243-6222
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DEe l'l 2002
RACHEL S. PALLlS,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 01-5989 CIVIL
: PACSES: 301104045/031215
Plaintiff
VS.
THOMAS E. PALUS,
Defendant : IN SUPPORT
PRAECIPE TO WITHDRAW APPEARANCE
TO THE PROTHONOTARY:
Please withdraw my appearance on behalf of the Plaintiff, RACHEL S. PALLlS, in the
above captioned case.
C;;W
THOMAS S. DIEHL, Esquire
One West High Street
Carlisle, PA 17013
(717) 240-0833
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance on behalf of the Plaintiff, RACHEL S. PALLlS, in the
above captioned case.
SAIDIS, SHUFF, FLOWER & LINDSAY
By:
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THOMAS E. PALLIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
RACHEL S. PALLIS,
Defendant 01-5989 CIVIL TERM
IN RE: CUSTODY AGREEMENT
Proceedings were held before the
HONORABLE KEVIN A. HESS,
Cumberland County Courthouse, Carlisle, Pennsylvania,
Courtroom Number Four,
August 14, 2002.
APPEARANCES:
REBECCA HUGHES, ESQUIRE
For - the Plaintiff
THOMAS DIEHL, Esquire
For - the Defendant
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1 August 14, 2002
2 Carlisle, Pennsylvania
3
4 (Whereupon, the proceedings were held
5 at 12:51 p.m.)
6 THE COURT: I understand at least for today there
7 is an understanding.
8 MS. HUGHES: That is correct, Your Honor.
9 THE COURT: Okay. I think you will have it read
10 into the record, and have it transcribed, but not in the form
11 of an order. We have to leave here with the understanding
12 that that is the Order of Court, so the mere fact that the
13 order is still in preparation is no reason to deviate from it.
14 Go ahead.
15 MS. HUGHES: Your Honor, the parties have agreed
16 to the following:
17 Both mother and father shall have shared legal
18 custody of the two minor children. Primary physical custody
19 shall be with the father. Mother shall have periods of
20 partial physical custody as follows:
21 Every other weekend from Friday after work until
22 Monday morning when mother shall take the children to
23 school
24 DR. SCHNEIDER: They didn't agree she will take
25 them to school. They will make sure they get to school. She
2
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1 may have to take them to school.
2 MS. HUGHES: -- until Monday morning when mother
3 will be sure to have the children at school or daycare,
4 whichever may apply.
5 Every Thursday evening from after work until
6 8:30 p.m., and following the father's weekend from Monday
7 after work until Tuesday morning, at which time mother shall
8 be sure to have the children either at daycare or school.
9 The first weekend of each month that is scheduled
10 to be the mother's shall be an extended weekend, which shall
11 begin Thursday evening after work through Monday morning.
12 And the week following the mother's weekend,
13 mother shall have Tuesday evening until after work until
14 8:30, as well as Thursday evening after work until 8:30.
15 Your Honor, Dr. Schneider now will provide
16 additional parts of the order.
17 DR. SCHNEIDER: Regarding the right of first
18 refusal, the parents agree that they will notify the
19 non-custodial parent if they cannot be with the child in
20 excess of three hours -- after a three-hour period of time.
21 If the non-custodial parent requests a temporary
22 modification in the schedule, such notification will be given
23 to the custodial parent a week in advance. I hope that is
24 clear.
25 If there is a temporary change in the schedule
.
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1 because of an emergency situation, the parents agree to make
2 up an equal amount of time within a 30-day period, unless they
3 agree otherwise.
4 That's to cover -- for example, if the father may
5 be assigned to go out of state for work, he would like his
6 time made up, unless he says, Forget it. That is basically
7 what I heard them agree to. Correct?
8 MR. PALLIS: Yes.
9 DR. SCHNEIDER: Both parties agree in principle
10 that the children need to be with one another on an identical
11 schedule, as much as possible.
12 That relates to a discussion, which was very
13 brief, given the difference in age of a three-year-old and a
14 six-year-old. And they both want the children on a similar
15 schedule, regardless of their age. And with passage of time
16 they recognize that the children will introduce modifications
17 based on their commitments --
18 THE COURT: True.
19 DR. SCHNEIDER: and developments as they grow
20 and mature.
21 Both parents agree to no display of affection with
22 a non-family third party, boyfriend/girlfriend, in front of
23 the children. Similarly, they agree to no adults outside of
24 family sleeping over at the custodial parents' home. So when
25 the children are there, no outsiders will sleep over, is the
4
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2 MRS. PALLIS: Family is okay.
3 DR. SCHNEIDER: Family is okay.
4 THE COURT: I'm sorry. I didn't hear that.
5 DR. SCHNEIDER: Family is okay.
6 In the event that there is no school on a Monday
7 following the mother's weekend, they both agree that the
8 children will be with their mother, if she is available for
9 that entire day.
10 Regarding holidays, the parents agree that
11 beginning this year, and every even year after this, the
12 children will be with the mother on Thanksgiving.
13 Thanksgiving is defined by the parents as beginning Wednesday
14 night after work until Monday morning.
15 Beginning this year 2002 and every even year
16 thereafter, the parents agree they will be with the father on
17 Christmas. The parents define Christmas as beginning by noon
18 on December 24th and ending by noon on December 26th. That
19 will allow travel time in the event mother goes to New Jersey
20 where her family resides to get them back in time.
21 They agree to alternate Easter on a similar annual
22 schedule. Easter is defined as beginning Saturday at noon and
23 ending Monday -- I wrote down Monday evening.
24 MR. PALLIS: I am not sure. I thought
25 DR. SCHNEIDER: Or Monday morning.
5
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MR. PALLIS: Rachel said she would get them back
to school.
Monday morning.
They are off school.
Just so they have off school
DR. SCHNEIDER:
MRS. PALLIS:
DR. SCHNEIDER:
Easter Monday.
THE COURT: What year will it start with?
DR. SCHNEIDER: Who had it last year, if you
figure?
MR. PALLIS: I have them Christmas. How would
Easter fall as?
MRS. PALLIS: Let me see. I can tell you quickly
who had them Easter of this year.
DR. SCHNEIDER: Okay. There is no summer schedule
yet. The parents agree to meet with me in my office sometime
in February 2003 to work out two points: One, a summer
schedule; and secondly, to determine the kids' adjustment
the children's adjustment to the agreed-upon current weekend
per month to be expanded to two extended weekends per month.
You guys are better at this legal stuff than I am.
THE COURT: And the expectation being if it worked
otherwise unremarkedly, it will be automatically extended to
two per month.
MRS. PALLIS: Dr. Schneider, Tom had them this
past Easter,
6
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1 DR. SCHNEIDER: It will be --
2 THE COURT: Your meeting in February will occur
3 undoubtedly before that anyway.
4 DR. SCHNEIDER: We will be talking about summer
5 schedule.
6 THE COURT: No need to talk about Easter if you
7 don't have to.
8 DR. SCHNEIDER: Mother's Day with mother.
9 Father's Day with father. Birthdays wherever the kids are is
10 where they will be celebrating, whichever parents they are
11 with. Labor Day, whichever parent has the kids, keeps the
12 kids. Same with Columbus day. New Year's was omitted.
13 New Year's -- they agreed that New Year's will be
14 with the same parent who has them Christmas. New Year's is
15 defined by beginning noon December 31st until the next school
16 morning, whenever that is -- Monday or Tuesday, whenever it
17 is. Right?
18 MS. HUGHES: Yes,
19 DR. SCHNEIDER: Regarding communication, I don't
20 know if it should be in the Court Order or not, but I at least
21 want it in the --
22 THE COURT: It is a common subject of Court
23 orders.
24 DR. SCHNEIDER: All right. Given their lack of
25 trust and inability to communicate, they both adopted the
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1 negotiation that emailing one another may be an appropriate
2 way to communicate.
3 And in that regard, Tom has offered and Rachel has
4 accepted his putting together a computer for the express
5 purpose of allowing her to have the computer to Email back and
6 forth.
7 THE COURT: Okay.
8 DR. SCHNEIDER: Is that right?
9 MR. PALLIS: Yes.
10 DR. SCHNEIDER: Rachel?
11 MRS. PALLIS: Fine.
12 DR. SCHNEIDER: If I might indulge the Court for a
13 moment.
14 (Discussion off the record)
15 DR. SCHNEIDER: Is there anything else?
16 MR. PALLIS: I think we've covered it all.
17 DR, SCHNEIDER: Do you understand what joint legal
18 custody means?
19 MRS. PALLIS: I think so,
20 DR. SCHNEIDER: You've got a physical schedule in
21 place. The only modification of that will be summer, and the
22 automatic expansion of that, Tom, assuming the kids do well
23 with the current extended time with Rachel. And you are going
24 to have to produce evidence that they are not. So the burden
25 is on you.
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MR. PALLIS:
MRS. PALLIS:
Right.
Did you say the first weekend is
mine?
DR. SCHNEIDER: Yes, the first weekend is the
expanded weekend.
THE COURT: When is that on the calendar?
MS. HUGHES: The first weekend that is scheduled
to be hers per month will be the extended.
DR. SCHNEIDER: Starting with September?
MS. HUGHES: Starting with September, yes.
THE COURT: We all know what weekend, that is my
point. I need to say in the order commencing --
MS. HUGHES: Now, school starts August 26th. So
the question is if Rachel has the following weekend, does that
take us into September? I am trying to think, here.
THE COURT: The following weekend is the 29th,
30th, and 1st.
MS. HUGHES: Okay. So that --
THE COURT: Which is also Labor Day.
DR. SCHNEIDER: Labor Day they agree wherever they
are, is where the children are.
(Discussion off the record.)
MS. HUGHES: September 5th through the 10th, first
weekend, first extended weekend. September 5th through the
10th.
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2 THE COURT: I don't think she got your
3 conversations down so recap now for the record what the next,
4 let me say, three weeks looks like, just so we all understand.
5 MS. HUGHES: Rachel will return the children
6 Rachel, you have the children now; is that correct?
7 MR. PALLIS: Whatever you attorneys worked out.
8 MS. HUGHES: Beginning the week of August 19,
9 Rachel will have the children through August 26th. Father
10 shall have the children beginning August 26th, and that will
11 start the new schedule that we just went through. Therefore
12 mother will have Tuesday evening the 27th, and Thursday
13 evening the 29th from after work until 8:30.
14 Father shall have the weekend of the 30th through
15 September 1st. Mother shall have the evening of September 2nd
16 through September 3rd and also Thursday evening from after
17 work until 8:30 -- no, from after work until September 5th
18 through after work until September 10th -- no, September 9th.
19 I'm sorry.
20 THE COURT: I thought --
21 MS. HUGHES: This calendar starts on a Monday. I
22 am used to it starting on a Sunday. So mother shall have the
23 children then from Thursday, September 5th from after work,
24 until Monday September 9th, and that will be her first
25 extended weekend.
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1 THE COURT: Okay. And then --
2 MS. HUGHES: And it shall continue from then on.
3 MR. PALLIS: First weekend she has them in the
4 month.
5 THE COURT: Anything else?
6 DR. SCHNEIDER: Yes, I have two points.
7 Transportation. What about the custodial -- the parent
8 assuming custody will pick up?
9 MS. HUGHES: Have you been able to work that out?
10 DR. SCHNEIDER: It's not been an issue. Do you
11 want anything else in the court order?
12 MR. PALLIS: Ruann (phonetic) will be riding the
13 bus from my house. Whether she chooses to drop her off --
14 DR. SCHNEIDER: You don't want anything about
15 transportation. Okay. I have a request. I did not mention
16 to either of you, but it occurred to me, I would like to
17 receive copies of your emails so I can kind of track what is
18 going on, and not be surprised when we reconvene.
19 MRS. PALLIS: Courtesy copy them to you? Do you
20 want--
21 DR. SCHNEIDER: The question is, What is my email
22 address. I don't know. If you could call my office.
23 MS. HUGHES: "Ask my secretary."
24 DR. SCHNEIDER: I know what it is at home, but my
25 office has -- I don't know what it is. I don't email myself.
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2 courtesy copies to track what is happening. Is that okay with
3 you?
4 MR. & MRS. PALLIS: Yes.
5 DR. SCHNEIDER: How long will it take?
6 MR. PALLIS: By the middle of September.
7 DR. SCHNEIDER: Is that acceptable?
8 MR. PALLIS: I will try to do it faster than that.
9 DR. SCHNEIDER: No later than September 15th?
10 MR. PALLIS: Sure. It will be much sooner than
11 that.
12 MRS. PALLIS: I don't have a choice in the matter.
13 MR. PALLIS: She has to provide the email address.
14 THE COURT: Okay.
15 DR. SCHNEIDER: Thank you, Your Honor.
16 THE COURT: Well, thank you, Dr. Schneider. I
17 would be amiss if I didn't make a note on the formal record
18 here of your great help this morning in resolving this. I
19 don't think I can think of a case where you came in for one
20 purpose and stayed for another, but I am glad you did.
21 And I congratulate the parties on working out an
22 arrangement. It's not that I didn't feel like sitting and
23 listening to a custody case all day. Well, maybe I didn't,
24 but that is what they pay me to do, and I have no trouble
25 doing that.
12
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But the fact that you are able to settle the case
is important for other reasons. First of all, I am satisfied
that it's a general rule that if parties reach an agreement as
to a schedule, it is invariably better than something that I
would impose on you. It's always going to be better.
And secondly, and most importantly, it reflects
your ability to put your love of these children ahead of your
personal dislike for each other. And that is something you
are going to have to work at doing -- in the case of one of
these children
a long time.
for another 15 years. And that is a heck of
You think you've got problems now agreeing, wait
until you decide who is going to teach them to drive, and what
kind of sneakers you are going to buy, whether they are going
to be in the high school band. It gets more and more
interesting. Mr. Diehl, you have another case.
MR, DIEHL: I have to run down the hall briefly.
MS. HUGHES: Thank you, Your Honor.
(Whereupon, the proceedings concluded at
1: 12 p.m.)
13
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CERTIFICATE
5 I hereby certify that the proceedings are contained
6 fully and accurately in the notes taken by me on the above
7 cause and
8
9
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12
13
14
that this is a correct transcript of the same.
~0t~~~~
Lorra~ne K. Troutman, RPR
15 The foregoing record of the proceedings on the hearing
16 of the within matter is hereby approved and directed to be
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsylvania Dkt. 2001-5989 CIVIL
Co.lCity/Dist. of CUMBERLAND PACSES 301104045
Date of Order/Notice 09/24/02 DR 31215
Tribunal/Case Number (See Addendum for case summary)
RE: PALLIS, THOMAS E.
Employee/Obligor's Name (last, First, MI)
148-76-6382
Employee/Obligor's Social Security Number
2659100882
Employee/Obligors Case .Identifier
(See Addendum for plaintiH names
associated with cases on attachment)
Custodial Parent's Name (last, First, MI)
Ooriginal Order/Notice
o Amended Order/Notice
@' Terminate Order/Notice
EmployerllNithholder's Federal EIN Number
BAE SYSTEMS NORTH AMERICA
RM 118
600 MAIN ST
JOHNSON CITY NY 13790-1806
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'sfobligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 0.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes @ no
$ 0.00 per month in medical support
$ 0 . 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 0 . 00 per month to be forwarded to payee below,
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 0 . 00 per weekly pay period.
$ 0.00 per biweekly pay period (every two weeks).
$ 0.00 per semimonthly pay period (twice a month).
$ 0.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
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 #10 on pg. 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDUl Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCOU
Send check to: Pennsylvania SCOU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER 10 (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BYT
Date of Order:
9-25-02
Service Type M
Edgar B.
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. ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If~hecked you are requ,ired to prPllide a copy of this fotnl to your employee. Ifyouremploy~vvorks 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. 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: 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. l/there are Federal tax levies in effect please contact the requesting
agency listed beiow.
3. 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.
4.* RepOl1i"g tI,e r'ydaWDate ofWitl,l,olding. Yo" I"ust ,ep"" tI.e p'ydale!d.te of ..itl,l,olding ..I,e" se"dh,g tI,e p'y,,,6,,t. T1,e
p'ydale!date of ..ithh6Idh,g;; tl,e daoc 0', ..hich a",,,",,t..as ..ithl,dd flom the el"ployee's ..ages. You must comply with the law of the
state of the employee'slobligor'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
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'slobligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #10 below)
6. 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 10: 2235379500
EMPLOYEE'S/OBlIGOR'S NAME:
EMPLOYEE'S CASE IDENTIFIER:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
PALLIS , THOMAS E.
2659100882 DATE OF SEPARATION:
7. 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.
8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor/rom 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.
10. * Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.S.c. ~ 1673 (b)l; or 2) the amounts allowed by the State of the employee'slobligor'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.
11. 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.
Submitted By: If you or your employee/obligor have any questions,
DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT
13 N. HANOVER ST by telephone at (717) 240-6225 or
P.O. BOX 320 by FAX at (717) 240-6248 or
CARLISLE PA 17013 by internet
Page 2 of 2
Form EN-028
Worker ID 21005
Servi ce Type M
OMS No.: 097().()154
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
RACHEL S. PALLIS ) Docket Number 01-5989 CIVIL
Plaintiff )
VS. ) PACSES Case Number 301104045/D3l215
THOMAS E. PALLIS )
Defendant ) Other State ID Number
ORDER
AND NOW, to wit, on this
24TH DAY OF SEPTEMBER, 2002
IT IS HEREBY
ORDERED that the support order in this case be 0 Vacated or GVSuspended or
o Terminated without prejudice or 0 Terminated and Vacated,
effective AUGUST 19, 2002 , due to:
RULE 1910.16-4 (el AND THE PLAINTIFF HAVING A SUPPORT OBLIGATION DOCKETED AT
731 SUPPORT 2002 (PACSES C# 065104774) FOR THE PARTIES' TWO CHILDREN.
THE REMAINING BALANCE OWED TO THE PLAINTIFF IN THE AMOUNT OF $559.54 WILL BE
DIRECTED TO THE CHILD SUPPORT OBLIGATION AS CREDIT.
DRO: RJ Shadday
xc: plaintiff
defendant
Rebecca Hughes, Esquire
BY THE COURT:
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
RACHEL S. PALLIS ) Docket Number 01-5989 CIVIL
Plaintiff )
VS. ) PACSES Case Number 301104045
THOMAS E. PALLIS )
Defendant ) Other State ID Number
ORDER
AND NOW, to wit on this
30TH DAY OF MAY, 2003
IT IS HEREBY
ORDERED that the 0 Complaint for Support or 0 Petition to Modify or G9 Other
REQUEST FOR HEARING DE NOVO
filed on OCTOBER 7, 20 02
in the above captioned
matter is dismissed without prejudice due to:
PLAINTIFF NOT PURSUING THE MATTER AFTER AN AUDIT WAS COMPLETED IN FEBRUARY
2003.
o . !he Complaint or Petition may be reinstated upon written application of the plaintiff
petltlOner.
DRO: RJ Shadday
xc: plain tiff
defendant
Carol Lindsay, Esquire
Rebecca Hughes, Esquire
MAILED
5~-tJ3
BY THE COURT:
~~~
Edgar B. Bayley JiJDGE
Service Type M
Form OE-506
Worker ID 21005
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SAlOIS
SHUFF, FLOWER
& LINDSAY
A'ITORNEYS'-AT'LAW
26 W. High Street
Carlisle. PA
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THOMAS E. PALLlS,
Plaintiff
DR 31215
PACSES ID 301104045
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: DOMESTIC RELATIONS SECTION
CIVIL ACTION - LAW
NO. 2001-5989 CIVIL TERM
vs.
RACHEL S. PALLlS,
Defendant
ORDER OF COURT
AND NOW, this
day of
, 2004, upon
consideration of the within Petition a rule is issued upon the Respondent to
show cause why his payment of alimony pendente lite should not be modified.
Rule returnable at a support conference scheduled for August 2nd, 2004 in the
Office of Domestic Relations at 9:00 o'clock a.m.
By the Court,
J.
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SHUFF, FLOWER
& LINDSAY
AITORNEYS'A'fI'LAW
26 w. High Street
Carlisle. P A
"
THOMAS E. PALUS,
Plaintiff
. DR 31215
PACSES ID 301104045
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: DOMESTIC RELATIONS SECTION
CIVIL ACTION - LAW
NO. 2001-5989 CIVIL TERM
vs.
RACHEL S. PALUS,
Defendanl
PETITION FOR MODIFICATION
OF ALIMONY PENDENTE LITE
NOW comes RACHEL S. PALUS, by and through her counsel, Saidis,
Shuff, Flower & Lindsay, and petitions this Honorable Court as follows:
1. On January 15, 2002 this Honorable Court entered an order for
alimony pendente lite. A copy of the order is attached hereto as
Exhibit "A".
2. Circumstances have changed so that an increase in the amount of
alimony pendente lite is warranted. These circumstances
included but are not limited to the fact that Respondent now has
custody of her children on a week on week off basis.
3.
A hearing on a Petition for Modification of child support is
scheduled in the Office of Domestic Relations on August 2, 2004.
The child support case is docket number 00731 S 2002, PACSES
number 065104774.
':(-.__ f __ , ",-: e'eN,,, ~<"""",_,;"^''''':e'1',.W''_,;,___1 ~,"=_~_",,,,,~, _J_.~."~,~",,_<',,",!_'!I'c",,, .. ,~~'''' _ir"',.",,";"'_. '_ "__ ~",,,,,,_ " ," ,;,>,,' ,< ~
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SAlOIS
SHUFF, FLOWER
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AITORNEYS-AT-LAW
26 W. High Street
Carlisle. P A
WHEREFORE, Petitioner prays this Honorable Court to increase her
alimony pendente lite and to schedule a hearing thereon at the same time as
the child support conference, August 2, 2004.
SAlOIS, SHUFF, FLOWER & LINDSAY
Attorneys for Qefendant
By:
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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.
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
f
State Commonwpalth of Pennsvlvania
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 08/03/04
Tribunal/Case Number (See Addendum for case summary)
RE: PALLIS, THOMAS E.
Employee/Obligor's Name (Last, First, MI)
o Original Order/Notice
o Amended Order/Notice
o Terminate Order/Notice
EmployerlWithholder's Federal ElN Number
148-76-6382
Employee/Obligor's Social Security Number
2659100882
, Employee/Obligor's Case Identifier
'J:fI t/lfO $ d&lJ7f (See Addendum for plaintiff names
.(),MrC(, ()f) 7f J(J&, tflfr;- associated with cases on attachment)
rlt"C;::"c Custodial Parent's Name (Last, First, MI)
Yd, C;,.DCJ1-stf ~q {I/l/lL
l)fl;t~s 3o/J6L/!Jl(S-
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's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 859.00 per month in current support
$ 21.00 per month in past-due support
$ 0.00 per month in medical support
$ 0.00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 880.00 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:
$ 203.08 per weekly pay period.
$ 406.15 per biweekly pay period (every two weeks).
$ 440.00 per semimonthly pay period (twice a month).
$ 880.00 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
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 #10 on pg. 2).
BAE SYSTEMS APPL. TECHNOLOGIES
1601 RESEARCH BLVD
ROCKVILLE MD 20850-3173
Arrears 12 weeks or greater?
o yes <X> no
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service aI1-877-676-9580 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, ,~-- i ~,rJ:1 ~~' L;~
AlI6 - 4 100\ ~-iv~1iflllf-~1~~
ci!G"he ;- l/LEY ~ VV~~I;:-
Form EN-028
Worker ID $IATT
Date of Order:
Servi ce Type M
OMS No.: 097().()154
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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 ifthe 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: 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.
3. 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 ofthe single payment that is attributable to each
employee/obligor.
4. * Repo,ti, ,g II,~ Pa,datelDate of Withl,,,ldi"g. ','ou I "ust ,epOlt tl,e pa,doteldate of ..;tl,l,oldi, ,g ..I,e" sendi"g t1,~ PO,I"""t. TI,~
po,dateldatc of ..itl,l,olding is II,~ date 0" ..I,id, an,ount ..." ..;11,1 ,eld 110'" tl ,e emplo,ee's ..ages. You must comply with the law ofthe
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
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 #1 0 below)
6. 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 10: 2224664210
EMPLOYEE'S/OBlIGOR'S NAME:
EMPLOYEE'S CASE IDENTIFIER:
LAST KNOWN "HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
FALLIS, THOMAS E.
2659100882 DATE OF SEPARATION:
7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. tfyou have any questions about lump sum payments, contact the person or authority below.
8. liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9. 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.
10.* Withholding limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.s.c. !i1673 (b)l; or 2) the amounts allowed by the State ofthe ernployee'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 taxesi and Medicare taxes.
11. 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.
Submitted By: If you or your employee/obligor have any questions,
DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT
13 N. HANOVER ST by telephone at (717) 240-6225 or
P.O. BOX 320 by FAX at (717) 240-6248 or
CARLISLE PA 17013 by internet www.childsupport.state.pa.us
Service Type M
Page 2 of 2
Form E N-028
Worker ID $IATT
OMBNo.:097(}.{)154
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ADDENDUM
Summarv of Cases on Attachment
Defendant/Obligor: PALLIS, THOMAS E.
PACSES Case Number 008106445
Plaintiff Name
RACHEL S. PALLIS
Docket Attachment Amount
00445 S 2004 $ 625.00
Child(ren)'s Name(s):
ROWAN S... PAJ,.J,.J:.S . ...
JAckii1:.jilil:ltlts ....
DOB
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PACSES Case Number 301104045
Plaintiff Name
RACHEL S. PALLIS
Docket Attachment Amount
01-5989 CIVIL$ 255.00
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's1obligor's employment.
D If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's1obligor'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
o If C~~C~~d,yo~~;~;~~~i;~;;~~roll the Child(ren)....
identified above in any health insurance coverage available
through the employee's/obligor's employment.
dli~~~c~~~:;~~are requir~~;~~~;~il;~;~hil~(r~n;:.. ....
identified above in any health insurance co~erage available
through the employee's/obligor's employment.
Service Type M
Addendum
Form EN-028
Worker ID $IATT
OMS No.: 0970-0154
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THOMAS E. PALLIS,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
VS.
CIVIL ACTION - DIVORCE
RACHEL S. P ALLIS,
Defendant/Petitioner
NO. 2001-5989 CIVIL TERM
IN DIVORCE
Pacses# 30 I1 04045
ORDER OF COURT
AND NOW, this 2nd day of August, 2004, based upon the Court's determination that Petitioner's
monthly net income/earning capacity is $1,480.67 and Respondent's monthly net income/earning
capacity is $3,023.31, it is hereby Ordered that the Respondent pay to the Pennsylvania State
Collection and Disbursement Unit, $255.00 per month payable weekly as follows; $255.00 for
alimony pendente lite and $0.00 on arrears. First payment due next pay date. Arrears set at $255.00
as of August 2,2004. The effective date of the order is August 2, 2004.
This Order is based upon the fact that the parties have a 50/50 custody arrangement and that
Respondent has an obligation for child support under C#0081 06445.
Failure to make each payment on time and in full will cause all arrears to become subject to
immediate collection by all ofthe means as provided by 23 Pa.C.S.!} 3703. Further, if the Court
finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare
the Respondent in civil contempt of Court and its discretion make an appropriate Order, including,
but not limited to, commitment of the Respondent to prison for a period not to exceed six months.
Said money to be turned over by the P A SCDU to: Rachel S. Pallis. Payments must be made by
check or money order. All checks and money orders must be made payable to P A SCDU and mailed
to:
P A SCDU
P.O. Box 69110
Harrisburg, P A 17106-911 0
Payments must include the defendant's P ACSES Member Number or Social Security Number in
order to be processed. Do not send cash by mail.
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Unreimbursed medical expenses that exceed $250.00 annually are to be paid as follows: 0% by
Respondent and 100% by Petitioner. The Petitioner is responsible to pay the first $250.00 annually in
unreimbursed medical expenses. Respondent to provide medical insurance coverage. Within thirty
days after the entry of this order, the Respondent shall submit to the Petitioner 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 addr4ess to which
claims should be made; 5) a description of any restrictions on usage, such as prior approval for
hospital admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or
coverage contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim
forms.
This Order shall become final ten days after the mailing of the notice of the entry of the Order to the
parties unless either party files a written demand with the Prothonotary for a hearing de novo before
the Court.
DRO: R. J. Shadday
Mailed copies on
8-4-04: <
BY THE COURT,
Petitioner
Respondent
Carol Lindsay, Esquire
Rebecca Hughes, Esquire
J.
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ATIORNEYS'AT'LAW
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THOMAS E. PALUS,
Plaintiff
vs.
RACHEL S. PALUS,
Defendanl
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: Civil Aclion - Divorce
: No. 2001-5989 Civil Term
: PACSES No. 301104045
DEMAND FOR HEARING
Date of Order:
August 2, 2004
$255.00 per month
AMOUNT:
FOR:
Alimony Pendente Lite
REASON(S):
The Office of Domestic Relations did not include Plaintiff's business income as well
as his wages in the support calculation.
PARTY FILING DEMAND FOR HEARING:
SAIDIS, SHUFF, FLOWER & LINDSAY
Attorneys for P'laintiff
By:
ire
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SAlOIS
SHUFF, FLOWER
& LINDSAY
ATTORNEYS-AT-LAW
26 W. High Street
Carlisle, P A
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THOMAS E. PALLlS,
Plainliff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: Civil Action - Divorce
: No. 2001-5989 Civil Term
vs.
: PACSES No. 301104045
RACHEL S. PALLlS,
Defendant
CERTIFICATE OF SERVICE
AND now, this I ~ day of th<0(. +
,2004, I,
Carol J. Lindsay, Esquire, of the law firm of SAIDIS, SHUFF, FLOWER & LINDSAY,
Attorneys, hereby certify that I served the within DEMAND FOR HEARING this day by
depositing same in the United States Mail, First Class, Postage Prepaid, in Carlisle,
Pennsylvania, addressed to:
Rebecca Hughes, Esquire
SALZMANN, HUGHES & FISHMAN, P.C.
95 Alexander Spring Road
Suite 3
Carlisle, PA 17013
SAlOIS, SHUFF, FLOWER & LINDSAY
Attorneys for intiff
By:
CarJ. ndsay, Esquire
ID#43
26 West High Street
Carlisle, PA 17013
(717) 243-6222
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
RACHEL S. PALLIS ) Docket Number 01-5989 CIVIL
Plaintiff )
vs. ) PACSES Case Number 301104045
THOMAS E. PALLIS )
Defendant ) Other State ID Number
ORDER OF COURT
You,
RACHEL S. PALLIS
plaintiff/defendant of
19 BRIAN DR, CARLISLE, PA. 17013-4326-19
are ordered to appear at DOMESTIC RELATIONS HEARING RM
DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13
before a hearing officer of the Domestic Relations Section, on the
SEPTEMBER 24, 2004
at 1: OOPM for a hearing.
You are further required to bring to the hearing:
1. a true copy of your most recent Federal Income Tax Return, including W -2s, as filed,
2. your pay stubs for the preceding six (6) months,
3. verification of child care expenses, and
4. proof of medical coverage which you may have, or may have available to you
5. information relating to professional licenses
6. other:
Service Type M
Form CM-509
Worker ID 21006
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PALLIS
V. PALLIS
P ACSES Case Number: 301104045
If you fail to appear for the conference/hearing or to bring the required documents, the
court may issue a warrant for your arrest or enter an order in your absence. If paternity is an
issue, the court may enter an order establishing paternity.
The appropriate court officer may enter an order against either party based upon the
evidence presented without regard to which party initiated the support action.
Date of Order:
~ -JS' --(J'i
BY THE COURT:
a?21~
JUDGE
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND
REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW. TIllS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGmLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND CO BAR ASSOCIATION
32 S BEDFORD ST
CARLISLE PA 17013-3302-32
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of CUMBERLAND County is required by law to
comply with the Americans with Disabilities Act of 1990. For information about accessible
facilities and reasonable accommodations available to disabled individuals having business
before the court, please contact our office at: (717) 240-6225. All arrangements must be
made at least 72 hours prior to any hearing or business before the court. You must attend the
scheduled hearing.
Service Type M
Page 2 of 2
Form CM-509
Worker ID 21006
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
RACHEL S. PALLIS ) Docket Number 01-5989 CIVIL
Plaintiff )
vs. ) PACSES Case Number 301104045
THOMAS E. PALLIS )
Defendant ) Other State 10 Number
ORl)ER OF COURT
You,
THOMAS EVANGELO PALLIS
plaintiff/defendant of
46 BRIAN DR, CARLISLE, PA. 17013-4373-46
are ordered to appear at DOMESTIC RELATIONS HEARING RM
DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13
before a hearing officer of the Domestic Relations Section, on the
SEPTEMBER 24, 2004
at 1: OOPM for a hearing.
You are further required to bring to the hearing:
I. a true copy of your most recent Federal Income Tax Return, including W -2s, as filed,
2. your pay stubs for the preceding six (6) months,
3. verification of child care expenses, and
4. proof of medical coverage which you may have, or may have available to you
5. information relating to professional licenses
6. other:
Service Type M
Form CM-509
Worker 10 21006
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PALLIS
V. PALLIS
PACSES Case Number: 301104045
If you fail to appear for the conference/hearing or to bring the required documents, the
court may issue a warrant for your arrest or enter an order in your absence. If paternity is an
issue, the court may enter an order establishing paternity.
The appropriate court officer may enter an order against either party based upon the
evidence presented without regard to which party initiated the support action.
BY THE COURT:
Date of Order: ?,-.).j -0 '1
JUDGE
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND
REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW. THIS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGmLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND CO BAR ASSOCIATION
32 S BEDFORD ST
CARLISLE PA 17013-3302-32
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of CUMBERLAND County is required by law to
comply with the Americans with Disabilities Act of 1990. For information about accessible
facilities and reasonable accommodations available to disabled individuals having business
before the court, please contact our office at: (717) 240-6225. All arrangements must be
made at least 72 hours prior to any hearing or business before the court. You must attend the
scheduled hearing.
Service Type M
Page 2 of 2
Form CM-509
Worker ID 21006
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
RACHEL S. PALLIS ) Docket Number 01-5989 CIVIL
Plaintiff )
vs. ) PACSES Case Number 301104045
THOMAS E. PALLIS )
Defendant ) Other State ID Number
ORDER
AND NOW, to wit on this 24TH DAY OF SEPTEMBER, 2004
IT IS HEREBY
ORDERED that the 0 Complaint for Support or 0 Petition to Modify or W Other
ALIMONY PENDENTE LITE
filed on AUGUST 2, 2004
in the above captioned
matter is dismissed without prejudice due to:
PURSUANT TO THE PARTIES' SETTLEMENT AGREEMENT. THE CREDIT OF $208.30 ON THIS
ACCOUNT WILL BE DIRECTED TO THE CHILD SUPPORT ACCOUNT UNDER C#008106445.
o . !he Complaint or Petition may be reinstated upon written application of the plaintiff
petitIOner.
xc: plaintiff
defendant
Carol J. Lindf'3ay, Esq.
Rebecca R. Lindsay, Esq.
BYT
CA1~
JUDGE
Service Type M
Form OE-506
Worker ID 21005
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