HomeMy WebLinkAbout01-06446
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
SHERRY L. HAIR
VERSUS
RICKY L. HAIR
AND NOW,
PENNA.
No.
6446
2001
DECREE IN
DIVORCE
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, "Z-<:>6'3, IT IS ORDERED AND
DECREED THAT
SHERRY L. HAIR
, PLAINTIFF,
AND
RICKY L. HAIR
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAiMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
.
NONE
By THE COURT:
d
o~
ROTHONOTARY
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SHERRY L. HAIR,
; IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
v.
: NO: 2001-6446
: CIVIL ACTION - LAW
RICKY L. HAIR,
: IN DIVORCE
Defendant.
PRAECIPE TO TRANSMIT THE RECORD
TO THE PROTIIONOTARY:
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(d) of the
Divorce Code. (Strike out inapplicable section.)
2. Date and manner of service of the Complaint: November 20, 200 I, by certified mail,
restricted delivery, return receipt requested.
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 Plaintiff: 08/12/03
By Defendant: 07/18/03
(b) (1) Date of Execution of the Plaintiff's Affidavit required Section
3301(d) of the Divorce Code:
(2) Date of service of the Plaintiff's Affidavit unto the Defendant:
4. Related claims pending: None
5. Indicate date and manner of service of the Notice of Intention to File Praecipe to
Transmit the Record, and attach a copy of said Notice Section 3301( d) (I )(i) of the
Divorce Code:
agner, Esq.
Attorney for Plaintiff
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SHERRY L. HAIR,
Plaintiff
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 01 - 6446 CIVIL
RICKY L. HAIR,
Defendant
IN DIVORCE
ORDER OF COURT
AND NOW, this /2)f1v day of !Lv %,u,r ,
2003, the economic claims raised in the proceedings having been
resolved in accordance with a marriage settlement agreement
dated July 18, 2003, the appointment of the Master is vacated
and counsel can file a praecipe transmitting the record to the
Court requesting a final decree in divorce.
BY THE COURT,
cc:
P. Richard Wagner
Attorney for Plaintiff
Douglas G. Miller
Attorney for Defendant
. ~ f_;;l.7-03
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MARRIAGE SETTLEMENT AGREEMENT
TIDS AGREEMENT made this I~fh day of
SHERRY L. HAIR, (hereinafter referred to as "WlF
2003, by and between
and RICKY L. HAIR, (hereinafter
referred to as "HUSBA...~D").
WITNESSETH:
'WHEREAS, HUSBAND and ~ were lawfully married on June 28, 1997, in New
Kingston, Cumberland County, Pennsylvania, and separated on or about June 25,2001; and
WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between
the parties and it is the intention of HUSBAND and WIFE to liveseparare and apart for the rest
of their natural lives, and the panies hereto are desirous of settling fully and finally their
respective financial and property rig.':Its and obligations as b.etween each other. inc:1uding, 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 estares, and the equitable distribution of property and
alimony for each party.
The parties hereto agree and covenant as follows:
1.
The parties intend to maintain separate and pennanent domiciles and to live apart from
each other. It is the inrent and purpose of this Agreement to set forth rhe respective rights and
duties of the parties while they continue to live apart from each other.
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2.
The parties have attempted to divide their matrimonial property in a manner which
confonns to a just and right standard, with due regard to the rights of each party. It is the intent
of the pa.rtJes 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, profe~sion, 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 legal)y bound hereby.
Each party to the Agreement acknowledges' and declares that he or she,
respectively:
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(1) Is represented by counsel of his or her owu choosing, or if not represented by
counsel, understands that he or she has the right to counsel: WIFE is represented
by P. Richard Wagner, Esquire, of Man eke, Wagner, Tully & Spreha; HUSBAND
is represented by Douglas O. Miller, Esquire of Irwin, McKnight & Hughes;
(2) Is fl.l!!y 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 tbis 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 ofIhis 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 pu:rpose 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 401 (e), 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 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.
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It is the fi..lrther 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 fuli 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
man:iage.
7.
REAL ESTATE: WIFE agrees to waive all right, title and interest which she may have
in the marital property located at 1343 West Trindle Road, Carlisle, Cumberland County,
Pennsylvania, 17013 and any improvements thereon to HUSBAND and releases all claims which
she may have regarding said real estate in accordance with rhis paragraph. HUSBAND agrees to
pay any outstanding payments on any mortgages on said property, as well as all real estate taxes,
insurance, and any maintenance and repair costs, and hold WIFE harmless from any 0 bligations
on said payments and indemnify her if any claim is made against her.
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8.
SlJ"PPORT: Following the execution of this Agreement, it is the mutual desire of the
parties that HllSBAND will not be required to pay spousal support, alimony, alimony pendente
lite, or any other financial support to WIFE, and that WIFE will not be required to pay spousal
support, alimony, alimony pendente lire, aT any other finaTJdal support to HUSBAND. It is
recognized that HUSBAND is currently paying alimony pendente lite to WIFE through an order
with the Cumberland County Domestic Relations Office. The parties agree that HUSBA.c'lD
shall remain respons.ible for the payment to WIFE of any arrearage amounts existing on June 30,
2003. Any charges or withholdings from HUSBAND occurring after June 3D, 2003 shall either
be credited to the arrearage amoWJt existing on June 3D, 2003, or, in the event there is no
arrearage amount, refunded to HUSBAND:
9.
PERSONAL PROPERTY: The parties agree that with the exception of dinette set in
the dining room of the marital residence, the personal property has been divided to the parties'
mumal satisfaction. WIFE shall retrieve the dinette set from HUSBAND within thirty (30) days
of the date of this Agreement, and HUSBANl) agrees with suffi~ient advance notice to make the
marital residence available at a reasonable time for that purpose. WIFE hereby waives all right,
title and interest which she may have in any other personal property of the HUSBA..1\jl>.
HUSBAND likewise waives any right, title and interest which he has in the personal property of
"WIFE. Subject to the above exception, each of the parties shaH own, have and enjoy
independently of any claim or right of the other party, all items of personal property of eveI)'
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 HUSBAI.\1l or WIFE to
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dispose of the same as fully and effectually, in all respects and for all purposes as if he or she
were unmarried.
10.
AUTOMOBILES: WIFE hereby waives all right, title and interest in any vehicle that
HUSBAND currently owns or may own in the furure, 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, particularly that 1993 Ford Explorer being used by WIFE. 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.
11.
MARITAL DEBTS: It is further mutually agreed by and between the parties that MFE
shall assume all liability for and pay and indemnify the HUSBA..l\'D against all debts incurred by
WIFE after the date of separation. WIFE represents and warrants to HUSBAND that since the
parties' marital separation she ha s no t contracted 0 r ine urred a ny de bt 0 r liability for which
HUSBAND or his estate might be responsible and WIFE further represents and warrants to
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HUSBAND that she will not contract or incur any debt or liability after the execution of this
Agreement, for which HUSBAND or his estare might be responsible. "'lFE 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 a.'1d i11demnify the WIFE
against aU debts incurred by HUSBAND after tbe dale 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 debr or liability after the
execution of this Agreement, for which WIFE or her estate might be responsible. HUSBAND
shall indemnify and save "''IFE harmless from any and all claims or demands made against her
by reason of debts or obligations incurred by him.
12.
INSUR<\.NCE 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.
Not\vithstanding the above, HUSBAND agrees to equally divide with WIFE his Individual IRA
with Legg Mason Wood Walker, Inc., Account # 360.70800, which as of June 30, 2001, was
valued at $18,954.74. One-half aftbat valuation is $9,477.37, and to effectuate the division, the
parties agree that WIFE andlor her legal counsel shall prepare the necessary QDRO or other
paperwork with such language and in such manner as may be required by the account manager.
HUSBAND agrees to execute all documents necessary !O effectuate the above division_
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T-Ol1 P.Gl1/015 F-38r
13.
BENEFITS. STOCK Ai\]) BAJ."fK ACCOUJ'iTS: WIFE agrees to waive all right, title
and interest which she may have in the savings or checking or any otha!- bank accounts of the
HUSBM"D and likewise HUSBA."iD agrees to waive all right, title and interest which he may
have in the savings or checking or any other bank accounts of WIFE.
14.
DIVORCE: The parties both agree to cooperate with each other in obtaining a fmal
divorce of the marriage. It is agreed lhar the parties will execute and file the consents necessary
to obtain the divorce. MY 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.
15.
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 hi:ri1 Or her, and the party breaching this conrract shall be
responsible for payment of legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
16.
ADDITIONAL L"'lSTRUMENTS: Each of the parties shaU from time to time, at the
request of the other, execute, acknowledge and deliver co the other party any and all further
ins1:rurnents that may be reasonably required to give full force and effect to the provisions of this
Agreement.
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17.
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' int ent that t his Ag reement do es no t merge with t he Divorce Decree, b ut r ather shall
continue to have independent contractual significance. Each party maintains his or her
contracrua1 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 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 Permsylvania Divorce Code or other similar statutes now in
effect and as amended or hereafter enacted.
18.
ENTIRE AGREEMENT: This Agreement contains the entire understanding of the
parties and there are ~o representations, warranties, covenants or undertakings other than those
expressly set forth herein.
19.
APPLICABLE LAW; This Agreement shall be construed under the Laws of the
Commonwealth of Pennsylvania
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20.
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 orre null and void and of no effect.
21.
PAYMENT OF COSTS: Each party shall be responsible for their ovm attorneys fees
and costs incurred in the settlement of the divorce and economic issues surrounding this divorce.
22.
WAIVER OF CLAIMS AGAL~ST 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, statutoIy allowance, widow's
allowance, right to take in intestacy, right to take against the Wi1!.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.
[THE REMAThTDER OF THIS PAGE HAS BEEN INTENTlONALL Y LEFT BLA.,,"'iK]
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IN WITNESS WHEREOF, the panies hereunto have set their hands and seals the day
and year first above written.
WITNESSES:
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SHERRY If Am
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RICKY . HAIR
(SEAL)
yUA'~ Y"0?h//L~
(SEAL)
COMMONWEALTH OF l?ENNSYL V AN1A
: 58:
COUNTYOF _
PERSONALLY APPEARED BEFORE M:E, this ~ _ day of
------'
2003, a Notary Public, in and for. the Commonwealth of Pennsylvania' and( County of
Cumberland, SHERRY L. HAIR, known tome (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.
II
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COMMOJ.";"'WEAL Tff OF PENNSYL VAJ.VIA
; 58:
COUNTYOFCUMrnERL~~D
J:J-R
PERSO:NALLY APPEARED BEFORE ME, this E day of ~
a NataIy Public. in and for the Co=onwealth of PennsYIV~ and Clcounty of
2003,
Cumberland, RICKY L. HAIR, lmown to me (or satisfactorily proven) to be the person whose
name is subscribed to the within Marriage Settlement Ag reement, a nd a clmowledges t hat he
executed the same for the purposes therein contamed.
IN Vi<'1TNESS WHEREOF, I have hereunto set my hand and official seal.
Notarial Seal
Martha L. Noel, NolBlY Public
Carlisle Bora, Cumberland County
My Commission Expires SepL 18, 1003
Member, Pennsylvania Association of Notaries
12
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SHERRY L. HAIR,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
Plaintiff,
v.
: NO. 01 - t..1.f4b
Ct'u~C ~'v)
: CIVIL ACTION - LAW
RICKY L. HAIR,
: IN DIVORCE
Defendant.
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 in divorce or annulment may be entered
against you by the Court. Ajudgment may also be entered against you for another claim or relief
requested in these papers by the Plaintiff. You may lose money or property or other rights
important to you, including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is available in the
Office of the Prothonotary, 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 HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELPo
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
Carlisle, PA 17013
(717) 249-3166
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SHERRYL. HAIR,
Plaintiff,
. IN THE COURT OF CO.MMON PLEAS
. CUMBERLAND COUNTY, PENNSYL VANIA
.NO 01 - 1..44-6 Clu:l 't-~
v.
. CIVIL ACTION - LAW
RICKY L. HAIR,
. IN DIVORCE
Defendant.
COMPLAINT IN DIVORCE
AND NOW, comes the Plaintiff, Sherry 1. Hair, by and through her
attorneys, Mancke, Wagner, Hershey & Tully, and files the following Complaint in
Divorce:
1. The Plaintiff, Sherry 1. Hair, is an adult individual currently residing at
7075 Carlisle Pike, No. 135, Carlisle, Cumberland County, Pennsylvania.
2. The Defendant, Ricky 1. Hair, is an adult individual currently residing at
1342 W. Trindle Road, Carlisle, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant have both been bona fide residents of the
Commonwealth of Pennsylvania for at least six (6) months prior to the filing of this
Complaint.
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4. Plaintiff and Defendant are husband and wife having been married on June
28, 1997, in New Kingston, Cumberland County, Pennsylvania.
5. There were no children born unto the marriage.
6. There have been no prior actions of divorce or annulment between the
parties in this or any other jurisdiction.
7. Neither Plaintiff nor Defendant are members of the Armed Forces of the
United States or any of its Allies.
8. Plaintiff has been advised of the availability of counseling and that she has
the right to request that the Court require both parties to participate in counseling.
9. Plaintiff avers as grounds on which this action is based are:
A. That the marriage is irretrievably broken pursuant to ~330l(c) of
the Divorce Code; and
B. That as of June 25, 2003, the parties will have lived separate
and apart for a period of at least two (2) continuous years
pursuant to ~ 330l(d) of the Divorce Code.
WHEREFORE, Plaintiff prays this Honorable Court to enter a Decree in
Divorce.
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COUNT I
EQUITABLE DISTRIBUTION
10. Paragraphs 1 through 9 above are incorporated herein by reference and
made a part hereof.
11. During the marriage, Plaintiff and Defendant have acquired various items
of marital property, both real and personal, which are the subject of equitable
distribution under ~401 of the Divorce Code of 1980.
COUNT II
ALIMONY PENDENTE LITE.
COUNSEL FEES. COSTS AND EXPENSES
12. Paragraphs 1 through 11 above are incorporated herein by reference and
made a part hereof.
13. By reason of this action, Plaintiff will be put to considerable expense in
the preparation of her case in the employment of counsel and the payment of costs.
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14. The Plaintiff is without sufficient funds to support herself and to meet the
costs and expenses of this litigation and unable to appropriately maintain herself
during the pendency of this action.
15. The Plaintiff s income is not sufficient to provide for her reasonable
needs and pay her attorneys' fees and the cost of this litigation.
16. The Defendant has adequate earnings to provide support for the Plaintiff
and to pay her counsel fees, costs and expenses.
COUNT III
ALIMONY
17. Paragraphs 1 through 16 above are incorporated herein by reference and
made a part hereof.
18. Plaintiff lacks sufficient property to provide for her reasonable needs.
19. Plaintiff is unable to sufficiently support herself through appropriate
employment.
20. Defendant has sufficient income and assets to provide continuing support
for the Plaintiff.
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WHEREFORE, Plaintiff prays this Honorable Court:
A. Enter a Decree in Divorce;
B. Compel the Defendant to pay alimony pendente lite to the Plaintiff;
C. Compel the Defendant to pay alimony to the Plaintiff;
D. Equitably divide all property, both real and personal, owned by the
parties;
E. Compel the Defendant to pay the Plaintiff's counsel fees, costs and
expenses and the costs and expenses of this action; and
F. Grant such further relief as the Court may deem equitable and just.
Respectfully submitted,
Mancke, Wagner, Hershey & Tully
P. Richar Wagner, Esquire
3103
2233 North Front Street
Harrisburg, P A 1711 0
(717) 234-7051
Attorneys for Plaintiff
Date: 1/1/0/
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VERIFICATION
I verify that the statements made in the foregoing
document are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S.
section 4904, relating to unsworn falsification to authorities.
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SHERRY L. HAIR,
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
v.
: CUMBERLAND COUNTY, PENNSYLVANIA
: CML ACTION - LAW
: 2001 -6446
CIVIL TERM
RICKY L. HAIR,
Defendant
: IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
November 13, 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: S//2/ ~3
I
,2003
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SHERRY L. HAIR,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
v.
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: 2001-6446
CIVIL TERM
RICKY L. HAIR,
Defendant
: IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
November 13,2001.
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 fmal decree in divorce.
4. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses ifI 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:
'l~rt
,2003
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SHERRY L. HAIR,
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: 2001 -6446
CIVIL TERM
RICKY L. HAIR,
Defendant
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a fmal Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
3.; I understand that I will not be divorced until a divorce decree is entered by the Court
and that acopy 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. 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: ff 11:1-/ t?,:;
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,2003
SH~RI ~
Plaintiff
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SHERRY L. HAIR,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: 2001-6446
CIVIL TERM
RICKY L. HAIR,
Defendant
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if! 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 1:he
Prothonotary.
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:
1-10
,2003
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RICKY . HAIR
Defendant
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
v.
NO:
2001-6446
CIVIL ACTION - LAW
RICKY L. HAIR,
IN DIVORCE
Defendant.
CERTIFICATE OF SERVICE
I, Debra K. Spinner, Secretary in the law firm of MANCKE,
WAGNER and SPREHA, do hereby certify that on this date a copy of
the COMPLAINT IN DIVORCE was served upon the following person and
in the manner indicated below, which service satisfies the
requirements of the Pennsylvania Rules of Civil Procedure, by
depositing the same in the United States mail, Harrisburg,
Pennsylvania, certified, restricted delivery, return receipt
requested, and addressed as follows:
Mr. Ricky L. Hair
1342 W. Trindle Road
Carlisle, PA 17013
By ilkJ-<. w.~)
Debra K. Spin~er, Secretary
MANCKE, WAGNER & SPREHA
2233 North Front Street
Harrisburg, PA 17110
P. Richard Wagner, Esquire
Attorney for Plaintiff
DATE: 11/20/01
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Date: 01/10/2002
Fax Transmission To: ANTHONY BOSAK
Fax Number: 717-243-5990
Dear ANTHONY BOSAK:
The following is in response to your 01/10/2002 request for delivery information on
your Certified item number 70001670000211354694. The delivery record shows that this
iternllV!lS deliv~r~d on 11/20/2001 at 11 :47 AMin CARLISLE, PA 17013. The scanned image
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Wife's SS#:
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191-46-2254
198-54-8513
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SHERRY L. HAIR,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: 2001 -6446 CIVIL TERM
RICKY L. HAIR,
Defendant
: IN DIVORCE
ORDER OF COURT
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AND NOW, this / q11J day of )rn(Jj~ , 2003, upon consideration of the
attached Petition to Terminate Alimony Pendente Lite, a hearing is hereby scheduled for
(1-l.MJ.., I (
, 2003 in Courtroom # L at II! O'V o'clock A .M. in the
Cumberland County Courthouse, Carlisle, Pennsylvania.
By the Court,
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SHERRY L. HAIR,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CML ACTION - LAW
: 2001 -6446 CML TERM
: IN DIVORCE
v.
RICKY L. HAIR,
Defendant
PETITION TO TERMINATE ALIMONY PENDENTE LITE
AND NOW, comes the Defendant, Ricky L. Hair, by and through his attorneys, IRWIN,
McKNIGHT & HUGHES, Esquires, and files this Petition to Terminate Alimony Pendente Lite
making the following statement:
1. The Plaintiff is Sherry L. Hair, and the Defendant is Ricky L. Hair.
2. The Plaintiff filed for divorce on November 13,2001 and simultaneously filed for
alimony pendente lite.
3. Up unto the end of February, 2003, the Plaintiff made no effort to move the
equitable distribution portion of the divorce along to a conclusion.
4. On or about February 24, 2003, 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. To date, the Plaintiff has not provided a signed Affidavit of Consent nor has she
or her legal counsel responded to the February 24, 2003 correspondence.
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6. The Plaintiff is receiving alimony pendente lite to support the expenses of the
divorce proceedings, however, is refusing to allow the matter to be litigated or
even to negotiate a settlement of the issues involved.
WHEREFORE, the Defendant, Ricky L. Hair, 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:
Douglas
60 West omfret Street
Carlisle, Pa 17013
717-249-2353
Supreme Court I.D.# 83776
Attorney for the defendant,
Ricky L. Hair
Date: March I C( , 2003
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Exhibit "A"
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LAW OFFICES
IRWIN McKNIGHT & HUGHES
ROGER B. IRWIN
MARCUS A. McKNIGHT. III
JAMES D. HUGHES
REBECCA R. HUGHES
DOUGLAS G. MILLER
WEST POMFRET PROFESSIONAL BUILDING
60 WEST POMFRET STREET
CARLISLE, PENNSYL VANIA 17013-3222
(717) 249-2353
FAX (717) 249-6354
E.MAIL: IMHLAW@SUPERNET.COM
February 24, 2003
P. RICHARD WAGNER, ESQUIRE
MANCKE, WAGNER, HERSHEY & TVLL Y
2233 NORTH FRONT STREET
HARRISBURG, PA 17110
RE: HAIR v. HAIR
No. 2001 - 6446, In Divorce, Cumberland County
Dear Rich:
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HAROLD S. IRWIN (1925~1977)
HAROLD S. IRWIN. JR. (1954-1986)
IRWIN, IRWIN & IRWIN (1956-/986)
IRWIN, IRWIN &McKNIGHT (1986-1994)
1RWIN, McKNIGHT &HUGHES (1994- )
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I have not received any response from you with regard to my previous correspondence.
Accordingly, in . the interest of keeping this matter moving forward, enclosed with this
correspondence please find the Affidavit of Consent and Waiver of Notice forms for your
client's review and signature. In the event that I do not receive these signed documents by
Wednesday, March 12,2003, so that this matter may proceed to the Divorce Master, I will be
advising my client to file a Petition to Terminate APL. I trust that such actions will not be
necessary and that this matter will proceed with all deliberate speed.
Very truly yours,
mwm.McKN1;Z;:'
Doug! G. Miller
DGM:tds
Enclosure
cc: Ricky Hair
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CERTIFICATE OF SERVICE
I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy
of the foregoing document upon the persons indicated below by fIrst class United States mail,
postage paid in Carlisle, Pennsylvania 17013, on the date set forth below:
P. Richard Wagner, Esquire
Mancke, Wagner, Hershey & Tully
2233 North Front Street
Harrisburg, P A 17110
Date: March 14, 2003
IRWIN, McKNIGHT & HUGHES
~ tfA:A
Douglas Miller, Esquire
Supreme Court LD. No. 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Attorney for Defendant,
Ricky L. Hair
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r~ THE COURT OF COMMON PLEAS OF
CmiBERL-\ND COUNTY, PENNSYLVANLI.
SHERRY L. HAIR,
Plaintiff
vs.
RICKY L. HAIR,
NO. 2001-6446
Ricky L. Hair
a master with respect to the
(X) . Divorce
( ) Annulment
( ) Alimony
( ) Alimony Pendente
~(QT!ON FOR APPO I::rn1::NT OF M..o\.STER
(Jl1._..... = =) (Derendantl,
follow~g. claims:
moves the court :0 appoint
Lite
( X)
( )
( )
( )
Distribution of Property
Support
Counsel Fees
Costs and E."(penses
and in support or the motion states:
(1) Discovery is cottrolete as to t~e claims(s) for which the
appointment df a \!laster ~!i1:equested.
(2) The defendant (has) ~ aDD eared in
(by his attorney, Dou",las G. Miller.
(3) The statu1:ory ground(s) for divorce (is)
the action c.~~...,..--<l..-:...~x')
,Esqui1:e).
(are) 1101 (e) "nd (d)-
(4) Delete the inapplicable parag1:aph(s) :
0e.) The action is not contested.
Qb) An ag1:eement has been reached with respect to the
foll~N-ing cla~:
(c) The action is contested with respect :0 the following
of property
The action (~) (does not L~volve) complex issues or law
claims :
distribution
(5)
or fact.
f:l:'tiVn1;1t:ion in Court
consents~to move this
Date: 'I/I'5/IJ:3
The hearillg is e:tpected to take 1/2 (ll.t!_~' (dayli).
Additional infor:na:tion, if any. relevant to the motion: Bv
on Anril 11. 2003. the narties have a",reed to sil!:tl the necessary
matter before the Master'". ~~ /1 A . ~NJ.
Attomey f :t~.'.:.~~
(Def e.'1dant)
.J7 ORDER APPOINTI:NG ~!ASTER Douglas G.M:j.l1er, Esquire. .
AJ.'ID NOW ~ 17 ,.1txI?J ' ('.~ ~..Ii-v EsquHe,
is a-ppointed !!I2.star--r..n.th res-pect -to' t:te rolloT,.1ing cla-i1'""~: ~_
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OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240-6535
E. Robert Elicker, II
Divorce Master
Traci .Jo Colyer
Office Manager/Reporter
West Shore
697-0371 Ex!. 6535
May 8, 2003
P. Richard Wagner
Attomey at Law
MANCKE, WAGNER, TULLY
& SPREHA
2233 North Front Street
Harrisburg, PA 17110
Douglas G. Miller
Attomey at Law
IRWIN, McKNIGHT & HUGHES
60 West Pomfret Street
Carlisle, PA 17013
RE: Sherry L. Hair vs. Ricky L. Hair
No. 01 - 6446 Civil
In Divorce
Dear Mr. Wagner and Mr. Miller:
Counsel have certified that discovery is complete. Therefore, I do
not anticipate having to deal with any discovery issues at the time of the
pre-hearing conference.
A divorce complaint was filed on November 13,2001, raising
grounds for divorce of irretrievable breakdown of the marriage and
further avers that as of June 25,2003, the parties will have lived
separate and apart for two years.
The complaint also raised econornic claims of equitable
distribution, alimony, alimony pendente lite, and counsel fees, costs and
expenses. The motion for appointrnent of Master, however, indicates
that the only issue is equitable distribution; however, since the cornplaint
has raised alimony and counsel fees claims, I will consider those to be
part of the proceedings.
In accordance with P.R.C.P. 1920.33(b) I am directing each counsel
to me a pretrial statement on or before Friday, June 6, 2003. Upon
w
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Mr. Wagner and Mr. Miller, Attorneys at Law
8 May 2003
Page 2
receipt of the pretrial statements, I will imrnediately schedule a pre-
hearing conference with counsel to discuss the issues and, if necessary,
schedule a hearing.
NOTE:
Very truly yours,
E. Robert Elicker, II
Divorce Master
Sanctions for failure to file the pretrial statements are set
forth in subdivision (c) and (d) of Rule 1920.33.
THE ORIGINAL PRETRIAL STATEMENT SHOULD BE FILED
IN THE MASTER'S OFFICE AND A COPY SENT DIRECTLY
TO OPPOSING COUNSEL.
FAILURE TO FILE PRETRIAL STATEMENTS AS DIRECTED
BY THE MASTER MAY RESULT IN THE MASTER'S
APPOINTMENT BEING VACATED.
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SHERRY L HAIR
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
CIVIL ACTION LAW
VB.
NO. 01-6446
CIVIL
19
RICKY L. HAIR
IN DIVORCE
Defendant
STATUS SHEET
DATE:
ACTIVITIES:
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SHERRY L. HAIR,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 01 - 6446 CIVIL
RICKY L. HAIR,
Defendant
IN DIVORCE
TO: P. Richard Wagner
, Attorney for Plaintiff
Douglas G. Miller , Attorney for Defendant
DATE: Friday, April 25, 2003
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
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.
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
DATE
COUNSEL FOR PLAINTIFF
COUNSEL FOR DEFENDANT
NOTE:
PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
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LAW OFFICES
IRWIN McKNIGHT & HUGHES
ROGERB.IRWIN
MARCUS A. McKNIGHT, III
JAMES D. HUGHES
REBECCA R. HUGHES
DOUGLAS G, MILLER
WEST POMFRET PROFESSIONAL BUILDING
60 WEST POMFRET STREET
CARLISLE. PENNSYLVANIA 17013-3222
(717) 249-2353
FAX (717) 249-6354
E-MAIL: IMHLAW@SUPERNET.COM
HAROLD S, IRWIN (1925-1977)
HAROLD S, IRWIN, JR, (1954-1986)
IRWIN, IRWIN & IRWIN (1956-1986)
IRWIN, IRWIN &McKNIGHT (1986-1994)
IRWIN, McKNIGHT&HUGHES (1994- )
May 1, 2003
E. ROBERT ELICKER, ESQUIRE
9 NORTH HANOVER STREET
CARLISLE, PA 17013
RE: HAIR v. HAIR
NO.: 01-6446
Dear Mr. Elicker;
Enclosed please find the requested Certification executed on behalf of the Defendant in
the above-referenced matter. It is my understanding that Attorney Wagner has also signed a
Certification on behalf of the Plaintiff in this matter. Thank you for your attention to the
enclosed.
Very truly yours,
IRWIN, McKNIGHT & HUGHES
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DGM:tds
Enclosure
cc: Ricky Hair (w/enc)
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SHERRY L. HAIR,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 01 - 6446 CIVIL
RICKY L. HAIR,
Defendant
IN DIVORCE
TO: P. Richard Wagner
, Attorney for Plaintiff
Douglas Gc Miller , Attorney for Defendant
DATE: Friday, April 25, 2003
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
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(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
'f hO/03
( DAtE
( )
(X)
COUNSEL
COUNSEL
NOTE:
PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY TF~T DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
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APH 2 6 2003
IRWIN/ McKNIGHT & HUGHES
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LAW OFFICES
MANCKE, WAGNER, TULLY & SPREHA
JOHN B. MANCKE
P. RICHARD WAGNER
WILLIAM T. TULLY
EDWARD F. SPREHA, .JR,
2233 NORTH FRONT STREET
HARRISBURG,
PA
17110
PHONE (717) 234~7051
FAX (717) 234-7080
April 28, 2003
E. Robert Elicker, Esquire
9 North Hanover Street
Carlisle, PA 17013
Re: Hair v. Hair
No: 01-6446
Dear Mr. Elicker:
Enclosed herein please find the Certification which I have executed regarding
the above-captioned matter.
Your attention is appreciated.
///
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Enclosure
cc: Douglas G. Miller, Esq. (w/encl.)
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SHERRY L. HAIR,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 01 - 6446 CIVIL
RICKY L. HAIR,
Defendant
IN DIVORCE
TO: P. Richard Wagner
, Attorney for Plaintiff
Douglas G. Miller , Attorney for Defendant
DATE: Friday, April 25, 2003
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
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(b) P~ovide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
IIj;sJo3
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/
DATE
C EL FOR PLAINTIFF
COUNSEL FOR DEFENDANT
NOTE:
PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
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SHERRY L. HAIR,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
RICKY L. HAIR,
Defendant/Respondent :
NO. 2001-6446 CIVIL TERM
IN DIVORCE
DR# 32003
Pacses# 205104790
ORDER OF COURT
AND NOW, this 26th day of September, 2002, based upon the Court's determination that Petitioner's
montWy net income/earning capacity is $2,105.29 and Respondent's montWy net income/earning
capacity is $2,294.64, it is hereby Ordered that the Respondent pay to the Pennsylvania State
Collection and Disbur~ement Unit, $76.00 per month payable montWy as follows; $76.00 for alimony
pendente lite and $0.00 on arrears. First payment due October 23,2002. Arrears set at $0.00 as of
Septebmer 26, 2002. The effective date of the order is August 23,2002
Failure to make each payment on time and in full will cause all arrears to become subject to immediate
collection by all of the means as provided by 23 Pa.C.S.~ 3703. Further, if the Court finds, after
hearing, that the Respondent has willfully failed to comply with this Order, it may declare the
Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not
limited to, commitment of the Respondent to prison for a period not to exceed six months.
Said money to be turned over by the P A SCDU to: Sherry L. Hair. Payments must be made by check
or money order. All checks and money orders must be made payable to PA SCDU and mailed to:
PASCDU
P.O. Box 69110
Harrisburg, PA 17106-9110
Payments must include the defendant's P ACSES Member Number or Social Security Number in order
to be processed. Do not send cash by mail.
DiVG J
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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
9-26-02 to: <
BY THE COURT,
Petitioner
Respondent
P. Richard Wagner, Esquire
Doug Miller, Esquire
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
l>ll, .t.etJ1-{P~ t'tPlL
State Commonwealth of Pennsvlvania /JA(!<;ES' dtJ(j /01./7'70
Co)City/Dist of CUMBERLAND f"7f
Date of Order/Notice 09/26/02 M.3:J1J6:]
Tribunal/Case Number '(See Addendum for case summary)
o Original Order/Notice
@ Amended Order/Nl?tice
o Terminate Order/Notice
EmployerlWithholder's Federal EIN N~mber
RE: HAIR, RICKY L.
EICHELBERGER CONSTRUCTION INC
PO BOX 459
124 W CHURCH ST
DILLSBURG PA 17019-1232
Employee/Obligor's Name (last, First, MI)
191-46-2254
Employee/Obli~or's SoCial Security Number
405300.0031
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with' cases on attachment)
Custodial Parent's Name (last, First, MI)
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.
$ 553.96 per month in current support
$0.00 per month in past-due support Arrears 12 weeks or greater? Oyes <R> 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 $ 553.96 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:
$ 127.84 per weekly pay period.
$ 255. 67'per biweekly pay period (every two weeks).
$ 276; 98 per semimonthly pay period (twice a month).
$ 553 .96 per monthly pay period.
REMITTANCE INFORMA TlON:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydateldate of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount The total withheld amount, and your fee, cannot exceed 55% of theeinployee'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).
If remitting by EH/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, pAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSfS MEMBER ID (shown
above as the Employee/Obligor's Caseldentifier)OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
bate of Order:
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Service Type M
B No.: 0970-0154
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Form EN-028
Worker ID $IATT
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o I(,-hecked you are required. to provide a Copy of this form to your employee. Ifyo~remployee works in a state that is
dltterent 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. 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 of the single payment that is attributable to each
employee/obligOr.
4. * Repal1illg tll~ PaydattiDate of Witlll.oldil Ig. Yau must lepol1 tl.e pc\ydatefdale of vvitlllloldihg vvl lell selldihg ti,e pay ll,ellL Tl.e
pardate/dal" "f ..itl,I,,,ldil,g is tl,e dale "" ..I,ich .n,,,u,,t..as ..itl,l,eld f,OI" the er,'plC>ree's ...ges. You must comply with the law of the
state oftheempJoyee's/pbligor'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 o!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 1D:2516777000
EMPLOYEE'S/OBLlGOR'S NAME: HAIR, RICKY L.
EMPLOYEE'S CASE IDENTIFIER: 4053000031 DATE OF SEPARATION:
LAST KNOWN HOME. ADDRESS:
NEWE/rIPLOYER'S NAME/ADDRESS:
7. Lump Sum Payments: Youmayberequired 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 in.come 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 i;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 underState law for discharging an employee/obligor frpm employment,
refusing tp emplpy, or taking disciplinary action against any employee/obligor because of a support withhplding. 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)1; pr 2) the amounts allowed by the.State of the employee's/obligor's princip'al place of employment.
The Federallimitapplies 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 oryour agent areselVed with a copy of this order in the state that issued the order, you "'reto 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 (7171 240-6248 ' or
CARLlSLEPA17013 by internet
Page 2 of 2
Form EN-028
WorkerlD $IATT
Service Type M
OMB No.: 0970.0154
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ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: HAIR, RICKY L.
PACSES Case Number 205104790
Plaintiff Name
SHERRY L. HAIR
Docket Attachment Amount
01c6446 CIVIL$ 76.00
Child(ren)'s Name(s):
DOB
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bl~~~~~.~~~~~~~;~;~~~i;~~;~~~~il;~~'.~~.il~;;~~\ .i... ........... ."
identified ab'ove,jn any heatth insurance coverage available
through the emp.oyee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
'.':..'"
o If checked, you are required to enroll the ch ild (ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
o If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Service Type M
OMB No.: 0970-0154
Addendum
PACSES Case Number 401000062
Plaintiff Name
LOU A. HAIR
Docket Attachment Amount
1238 S 92 $ 4'77.96
Child(ren)'s Name(s):
~~~~Hll'~~}> .
DOB
. ..12/19/84.
'Ilr/i1I88
d;f~~~~~~d, you are req~ired to enro;l;h~child(r~~)>'"
identified above in any health ~nsuran'ce' coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
o If checked, you are required to enroll the child(ren)
identified above in any health 'insurance coverage available
through the employee's/obJigor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
b If checked, you are r~~ui;~t~~~;~;lt~~~~;I~ir~~)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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SHERRY L. HAIR,
P1aintiff/Petitioner
IN THE COURT OF COMMON PLEAS. OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
RICKY L. HAIR,
DefendantJRespondent
NO. 2001-6446 CIVIL TERM
IN DIVORCE
DR# 32003
PacseS# 205104790
DEMAND FOR HEARING
DATE OF ORDER: September 26,2002
AMOUNT: 76.00 per month
FOR: Alimony Pendente Lite
REASON(S):
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SHERRY L. HAIR,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
RICKY L. HAIR,
DefendantlRespondent
NO. 2001-6446 CIVIL TERM
IN DIVORCE
DR# 32003
PacseS# 205104790
NOTICE OF RIGHT TO REOUEST A HEARING
The parties are hereby advised that they have until October 6. 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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i-.n P 001/001 H i8
SHERRY _. <'-AIR,
IN THE COURT OF COMMON PLEAS
CL~BERLA}~ COUNTY, PENNSYLVANIA
PJ.a:":1tifr,
,.
., .
NO: 01-6446
CIVIL ACTION - LAW
RICKY L. HAIR,
IN DIVORCE
Defendant.
NOTICE OF INTENTiON TO RESI~E PRIOR NAME
NOTICE IS HEREBY GIVEN that the PLAINTIFF in che above
matter, being a p~rty to a'divorce ac~ion at the abD~e n~mber
filed on Novembey 13, 2001Jl11!nceci inter,ds to resume and
he~ea~ter use the prevlo~s name of SHERRY L. PATTON and 3i~es
t.~is Tdr=-r;::.en not.:.ce avowing___her ,inte:1cion in accordar:ce wich ::.he
pr()'I,-isions of the A~t: of. Ap::il 2, 1980, P.L" 23 P.S. ,_Section 702
',effect:.:.ve July:, 1980). '
Sherr~~ J J#~
TO BE KNOWN AS:
sher~~J! fcaltno
CO~OffiiEALTH OF PENNSYLVAl~IA
55.
C01~TY OF
O~ THE f}7 day c.c , 2082, before me., a
!':o~a!'''I P'..'.blic, pe~gcr.:a::"ly a,.... ared Sherry, L. Hai~, kncifm. to me tc
be tte ~erson whose ~a~e is subscribed to the w~chin do~ume~t and
a~know:::'edged ~ha~ she executed tr-'.e foregoing for tl:e p~rpaae
:~er~:n conta~neQ.
1K 101jI'rNESS
WHEREOFr
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In the Court of Common Pleas of CUMBERLAND County, Peunsylvania
DOMESTIC RELATIONS SECTION
SHERRY L. HAIR ) Docket Number 01-6446 CIVIL
Plaintiff )
vs. ) PACSES Case Number 205104790
RICKY L. HAIR )
Defendant ) Other State ID Number
ORDER OF COURT
You,
SHERRY LYNN HAIR
plaintiff/defendant of
7075 CARLISLE PIKE # 135, CARLISLE, PA. 17013-8897-75
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 10, 2002
at 1: 30PM for a hearing.
You are further required to bring to the hearing:
I. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed,
2. your pay stubs for the preceding six (6) months,
3. verification of child care expenses, and
4. proof of medical coverage which you may have, or may have available to you
5. information relating to professional licenses
6. other:
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Worker ID 21302
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HAIR
v. HAIR
PACSES Case Number: 205104790
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: 10 /30 (02-
7'~~
JUDGE
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND
REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD
ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU MAY GET LEGAL HELP:
CUMBERLAND CO BAR ASSOCIATION
2 LIBERTY AVE
CARLISLE PA 17013-3308-02
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of CUMBERLAND County is required by law to
comply with the Americans with Disabilities Act of 1990. For information about accessible
facilities and reasonable accommodations available to disabled individuals having business
before the court, please contact our office at: (717) 240-6225. All arrangements must be
made at least 72 hours prior to any hearing or business before the court. You must attend the
scheduled hearing.
Page 2 of2
Form CM-509
Worker ID 21302
Service Type M
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
SHERRY L. HAIR ) Docket Number 01-6446 CIVIL
Plaintiff )
vs. ) PACSES Case Number 205104790
RICKY L. HAIR )
Defendant ) Other State ID Number
ORDER OF COURT
You,
RICKY L. HAIR
plaintiff/defendant of
1343 W TRINDLE RD, CARLISLE, PA. 17013-9746-43
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 10, 2002
at 1: 30PM for a hearing.
Yon are further required to bring to the hearing:
1. a true copy of your most recent Federal Income Tax Return, including W-2s, :?~~ed,
."'" J
2. your pay stubs for the preceding six (6) months, '1.2:"1:-"1
3. verification of child care expenses, and . :;';=::
4. proof of medical coverage which you may have, or may have available to yo~~~;~
'--'-r-;-n
5. information relating to professional licenses _J -'.
6. other:
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HAIR
V. HAIR
PACSES Case Number: 205104790
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: 10[30 [02.
7.~~
,.
JUDGE
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND
REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD
ONE, GO TO OR TELEPHONE THE OFFICE SET FORm 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 individnals having business
before the court, please contact our office at: (717) 240-6225. All arrangements must be
made at least 72 hours prior to any hearing or business before the court. You must attend the
scheduled hearing.
Page 2 of2
Form CM-509
Worker 10 21302
Service Type M
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
SHERRY L. HAIR ) Docket Number 01-6446 CIVIL
Plaintiff )
vs. ) PACSES Case Number 205104790
RICKY L. HAIR )
Defendant ) Other State ID Number
ORDER OF COURT - RESCHEDULE A HEARING
You,
RICKY L. HAIR
of
1343 W TRINDLE RD, CARLISLE, PA. 17013-9746-43
are ordered to appear at DOMESTIC RELATIONS HEARING RM
DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13
on the 21ST DAY OF JANUARY, 2003
at 8: 30AM for a hearing. This date replaces
the prior hearing date of DECEMBER 10,2002 .
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. the Income and Expense Statement attached to this order as required by Rule 1910.11 (c).
4. verification of child care expenses, and
5. proof of medical coverage which you may have, or may have available to you
6. information relating to professional licenses
7. other:
Service Type M
Form CM-514
Worker ID 21302
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HAIR
V. HAIR
PACSES Case Number: 205104790
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: I d- ~ Od-
7'~~
JUDGE
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND
REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD
ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU MAY GET LEGAL HELP:
CUMBERLAND CO BAR ASSOCIATION
2 LIBERTY AVE
CARLISLE 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.
Page 2 of 2
Form CM-514
Worker ID 21302
Service Type M
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
SHERRY L. HAIR ) Docket Number 01-6446 CIVIL
Plaintiff )
vs. ) PACSES Case Number 205104790
RICKY L. HAIR )
Defendant ) Other State ID Number
ORDER OF COURT - RESCHEDULE A HEARING
You,
SHERRY LYNN HAIR
of
7075 CARLISLE PIKE # 135, CARLISLE, PA. 17013-8897-75
are ordered to appear at DOMESTIC RELATIONS HEARING RM
DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13
on the 21ST DAY OF JANUARY, 2003
at 8 : 3 OAM for a hearing. This date replaces
the prior hearing date of DECEMBER 10, 2002 .
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. the Income and Expense Statement attached to this order as required by Rule 1910 .11 (c).
4. verification of child care expenses, and ,
5. proof of medical coverage which you may have, or may have available to you
6. information relating to professional licenses
7. other:
Service Type M
FormCM-514
Worker ID 21302
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HAIR
v. HAIR
PACSES Case Number: 205104790
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: I d.lrW O~
7'~~
JUDGE
YOU HAVE THE RIGHT 1'0 A LAWYER, WHO MAY ATTEND THE HEARING AND
REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD
ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU MAY GET LEGAL HELP:
CUMBERLAND co BAR ASSOCIATION
2 LIBERTY AVE
CARLISLE PA 17013-3308-02
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of CUMBERLAND County is required by law to
comply with the Americans with Disabilities Act of 1990. For information about accessible
facilities and reasonable accommodations available to disabled individuals having business
before the court, please contact our office at: (717) 240-6225. All arrangements must be
made at least 72 hours prior to any hearing or business before the court. You must attend the
scheduled hearing.
Page 2 of 2
Form CM-514
Worker ID 21302
Service Type M
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SHERRY L. HAIR,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DOMESTIC RELATIONS SECTION
RICKY L. HAIR,
Defendant
PACSES NO. 205104790
NO. 01-6446 CIVIL TERM
INTERIM ORDER OF COURT
AND NOW, this 29th day of January, 2003, upon consideration of
the Support Master's Report and Recommendation, a copy of which is attached
hereto as Exhibit "A", it is ordered and decreed as follows:
A. The Defendant shall pay to the State Collection and Disbursement Unit
as alimony pendente lite the sum of $234.00 per month.
B. The Defendant shall pay an additional sum of $25.00 per month on
arrearages, if any, until paid in full.
C. The effective date of the Defendant's APL obligation is September 26,
2002.
D. Except as modified herein, the order of September 26, 2002, shall
remain in full force and effect.
The parties are hereby advised that they may file written exceptions to the
Support Master's Report and Recommendation within ten (10) days of this order.
Exceptions shall conform with the requirements of Rule 1910.12(f), Pa. R.C.P. If
written exceptions are filed by any party, the other party may file exceptions
within ten (10) days of the date of service of the original exceptions. If no
exceptions are filed within ten (10) days of this interim order, this order shall then
constitute a final order.
By the Court,
7'~~
Kevin A. Hess, J.
.
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cc: Sherry L. Hair
Ricky L. Hair
P. Richard Wagner, Esquire
For the Plaintiff
Douglas G. Miller, Esquire
For the Defendant
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SHERRY L. HAIR,
Plaintiff
V.
RICKY L. HAIR,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DOMESTIC RELATIONS SECTION
PACSES NO. 205104790
NO. 01-6446 CIVIL TERM
SUPPORT MASTER'S REPORT AND RECOMMENDATION
Following hearings held before the undersigned Support Master on
December 10, 2002, and January 21, 2003, the following report and
recommendation are made:
FINDINGS OF FACT
1. The Plaintiff is Sherry L. Hair, who resides at 7075 Carlisle Pike,
Number 135, Carlisle, Pennsylvania.
2. The Defendant is Ricky L. Hair, who resides at 1343 West Trindle
Road, Carlisle, Pennsylvania.
3. The parties are husband and wife, having married on June 28, 1997.
4. The parties separated on June 25, 2001.
5. On November 13, 2001, the Plaintiff filed a complaint for divorce
containing therein a claim for alimony pendente lite.
6. On August 23, 2002, the Plaintiff filed an action for spousal support
docketed to 750 Support 2002.
7. At the support conference held September 26,2002, the Plaintiff
withdrew her complaint for spousal support and requested that the
conference proceed on her claim for alimony pendente lite.
8. On September 26, 2002, an order was entered setting the Defendant's
obligation to pay alimony pendente lite at $76.00 per month effective
August 23, 2002, from which the Plaintiff has requested a hearing de
novo.
9. The Plaintiff has gross bi-weekly income of $1 ,268.00.1
10. The Defendant is employed as a construction superintendent by
Eichelberger Construction, Inc.
1 The parties stipulated to the Plaintiff's income.
Exhibit nAil
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. I .,
11. In 2001 the Defendant had annual earnings from employment of
$59,441.00.
12. In 2002 the Defendant had gross annual earnings from employment of
$52,659.53.
13. The reduction in the Defendant's income from 2001 to 2002 was not a
voluntary reduction of income on the part of the Defendant.
14. Superintendents at Eichelberger Construction are entitled to the use of
a company vehicle for business purposes.
15. Superintendents who do not have a company vehicle because of
unavailability are paid an additional $2.50 per hour as wages to
compensate for the use of their personal vehicle.
16. In 2002 the Defendant received a company vehicle in April.
17. The Defendant's gross income for 2002 includes $1,367.50 as vehicle
reimbursement for that portion of the year in which the company
vehicle was not available to him.
18. The Defendant's employer made a matching contribution to the
Defendant's 401 (k) plan in 2002 of $1,153.00.
19. The parties have no children together.
20. The Defendant is paying $477.99 per month as support for two
children to a prior relationship.
21. Pending their divorce both parties file federal tax returns as
married/separate.
DISCUSSION
The Defendant is not disputing entitlement to an award of alimony
pendente lite. The amount of alimony pendente lite is com~)Uted utilizing the
support guidelines in the same manner as spousal support.2
The parties stipulated that the Plaintiff had bi-weekly gross income of
$1,268.00. This equated to gross monthly income of $2,747.00. Filing her
2 See Pa. R.C.P. 1910.1(a) and Pa. R.C.P. 191O.16-4(a). See also Little v. Little, 47 Cumberland L.J. 131
(1998).
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federal tax return as married/separate, the Plaintiff has net monthly income of
$2,105.00.3
The Defendant's income is slightly more complicated. In 2002 he had
gross wages of $52.659.53. Of this amount the sum of $1,367.50 was paid to
him to compensate for the use of his personal vehicle prior to his receiving a
company vehicle in April, 2002. Superintendents such as the Defendant are
entitled to company vehicles for business purposes, and if a vehicle is not
available, they are compensated $2.50 per hour in addition to their normal wage.
Perquisites such as personal automobile expenses must be considered as
income for support purposes. Mascaro v. Mascaro, 803 A.2d. 1186 (Pa. 2002).
The company truck provided to the Defendant was for business purposes only,
although he did admit to driving 10 to 15 miles per week on personal errands.
This amount of personal use is considered negligible, and the company truck
provided to the Defendant will not be considered as income in this case.
However, the $1,367.50 actually paid to the Defendant prior to the receipt of the
company truck will be considered as income. Additionally the company paid
matching contribution to the Defendant's 401(k) plan, less a ten percent penalty
for early withdrawal, will be considered income for support purposes. Portuqal v.
Portuaal, 798 A.2d. 246 (Pa. Super. 2002). The Defendant's gross monthly
income for support purposes is calculated to be $4,475.00. Filing his federal tax
return as married/separate, he has net monthly income of $3,169.00.4
The calculation of the Defendant's alimony pendene lite obligation is
shown on Exhibit B. From the Defendant's net monthly income is deducted his
child support obligation to children of another relationships and the Plaintiff's net
monthly income. The difference is multiplied by 40% because the parties have
no dependent children together. The monthly obligation is $234.00.
The effective date of the Defendant's APL obligation will be September 26,
2002, the date on which the Plaintiff withdrew her spousal support complaint and
requested the support conference to proceed on her claim for alimony pendente
lite.
RECOMMENDATION
A. The Defendant shall pay to the State Collection and Disbursement
Unit as alimony pendente lite the sum of $234.00 per month.
B. The Defendant shall pay an additional sum of $25.00 per month on
arrearages, if any, until paid in full.
3 See Exhibit A for the deductions from her gross income.
4 See Exhibit A for the deductions from his gross income.
S See Pa. R.C.P. 191O.16-2(c)(2)
. l . I
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C. The effective date of the Defendant's APL obligation is September
26, 2002.
D. Except as modified herein, the order of September 26, 2002, shall
remain in full force and effect.
~""l ". """
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Michael R. Rundle
Support Master
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In the Court of Common Pleas of Cumberland County, Pennsylvania
Plaintiff Name:
Defendant Name:
Docket Number:
PACSES Case Number:
Other State ID Number:
Tax Year:
Sherry L. Hair
Ricky L. Hair
01-6446 Civil
205104790
1. Fling Status
2. Who Claims the Exem tions
3. Number of Exem tions
4. Monthl Taxable Income
5. Deductions Method
6. Deduction Amount
7. Exem tion Amount
8. Income MINUS Deductions and Exem tions
9. Tax on Income
10. Child Tax Credit
11. Manual Ad'ustments to Taxes
12. Federal Income Taxes
12 a. Earned Income Credit
13. State Income Taxes
14. FICA Pa ments
15. City Where Taxes Apply
$327.08
$250.00
$3,897.68
$793.87
$793.87
$125.29
$342.32
16. Local Income Taxes
$44.75
TOTAL Taxes
$1 306.23
SupportCa/c 2002
Exhibit nAil
1
$2,747.33
$327.08
$250.00
$2,170.25
$327.46
$327.46
$76.93
$210.17
--Select--
$27.47
$642.03
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Obligor's Net Monthly Income $3,169
Less Obligor's support, alimony pendente (478)
lite, or alimony obligations, if any, to children
or former spouses who are not part of this
action
Less Obligee's Net Monthly Income (2.105)
Difference $ 586
Multiply by 40%
x .4
Amount of Monthly APL
$ 234
Exhibit "B"
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Department of the Treasury - Internal Revenue Service
2001
, 040 u.s. Individual Income Tax Return I '99'
,
~ IRS Use Onlv - Do not write or stanle in this snace,
Label ForthevearJan.1-Dec,31 2001 or other tax vear beainnina endin" I OMS No. 1545..Q074
(5.. Your first name M.1. Last name Suffix , Your social security no.
instructions ,
RICKY L HAIR ,
on page 19,) , 191-46-2254
,
Use the If a joint return, spouse's first name M.1. Last name Suffix , Spouse's social security no,
,
IRS label. ,
,
Other- Home address (number and street)_ If you have a P. O. box, see page 19. IAPt no. A. IMPORTANT! A.
wlse, 1343 WEST TRINDLE ROAD You MUST enter
please City, town or post office State ZIP code vour SSN(s) above.
print or
type. CARLISLE PA 17013
NOTE. Checking "Yes" will not change your tax or reduce your refund. You
Do you, or your spouse if filin9 a joint return, want $3 to go to this fund? ~DYes [8]NO
Sin91e
Married filing joint return (even if only one had income)
Married filing separate return. Enter spouse's SSN above and full name here. ....
X Head of household (with qualifying person). (See page 19.) If the qualifying person is a child but riot your
dependent, enter this child's name here. ~ SSN:
5 Quali in widower with de endent child ear souse died ~ . See a e 19.
6a [8]vourself. If your parent (or someone else) can claim you as a dependent No. of boxes checked
Exemptions on his or her tax return, DO NOT check box 6a. . . . . .. .} on 6a and 6b
b 0 Spouse No. of your children
C on 6c who:
22 Add the amounts in the far rl ht column for lines 7 thro h 21. This is
23 IRA deduction (see page 27) . . . . . . . . . .
24 Student loan interest deduction (see page 28)
25 Archer MSA deduction. Attach Form 8853 . . . .
26 Moving expenses. Attach Form 3903
27 One-half of self-employment tax. Attach Schedule SE
28 Self-employed health insurance deduction (see page 30)
29 Self-employed SEP, SIMPLE, and qualified plans
30 Penalty on early withdrawal of savings
31 a Alimony paid b Recipient's SSN ~
32 Add lines 23 through 31a .
33 Subtract line 32 from line 22_ This is our ADJUSTED GROSS INCOME
For Disclosure, Privacy Act, and Paperwork Reduction Act Notice, see page 72. (HTA)
Presidential ~
Election Campaign ,..
Filing
Status
Check only
one box.
If more than six
dependents,
see page 20.
Income
Attach
Forms W-2
and W-2G here.
Also attach
Form(s)
1099-R if tax
was withheld.
If you did not get a
W-2. see page 21.
Enclose, butdo
notattach,any
payment Also,
please use
Form 1040-V
Adjusted
Gross
Income
Spouse
DYes DNO
1
2
3
4
First name:
Last name:
1
Dependents: (2) Dependent's (3) Dependent's (4) Vifqual.
social security number relationship ifyingchildfor
(1) First name Last name tOllQU child tax credit
CODY HAIR 169-70-4240 Son IXI
. 0
0
0
0
0
1
d
7
8a
b
9
10
11
12
13
14
15a
16a
17
18
19
20a
21
Total number of exemptions claimed . . . . .
Wages, salaries, tips, etc. Attach Form(s) W-2
TAXABLE interest Attach Schedule B if required
TAX-EXEMPT interest. DO NOT include on line 8a . 8b
Ordinary dividends. Attach Schedule B if required . . . .
Taxable refunds, credits, or offsets of state and local income taxes (see page 22)
Alimony received . . . . . . . . . . . . . . . . . . . . .
Business income or (loss). Attach Schedule C or C-EZ . .... .
Capital gain or (loss). Attach Sch. 0 if required_ If not required, check here ~ D
Other gains or (losses). Attach Form 4797 .. ........ ...
Total IRA distribullons ... ~ U b Taxable amount . .
Total pensions and annuilles . . ~ 0 b Taxable amount . .
Rental real estate, royalties, partnerships, S corporations, trusts, etc. Attach Schedule E . . . .
Farm income or (loss). Attach Schedule F. ..............
Unemployment compensation . . . . . . . . . . . . . . . . . . . .
Social security benefits . . . .~ b Taxable amount . -
Other income. List type and amount (see page 27) ._m______________________u_
$
____.___~~~~_____~______~________~______~__________~__~M_M_________._____________
. lived with you
. did not live with you due
to divorce or separation
Dependents on
6c not entered
above
Add numbers
entered on
lines above ....
o
56,520
84
9
10 206
11
12
13
14
15b
1Gb
17
18
19
20b
56810
ourTOTALlNCOME
23
24
25
26
27
28
29
30
31a
56,810
Form 1040 (2001)
RICKY L HAIR 191-46-2254
Amount from line 33 (adjusted gross income) . . . , . _ . . . .
Check If: Dyou were 65 or older, D Blind; D SPOUSE was 65 or older,
Add the number of boxes checked above and enter the total here
b If you are married filing separately and your spouse itemizes deductions,
or you were a dual-status alien, see page 31 and check here . , , . . . . . .... 35b 0
36 ITEMIZED DEDUCTiONS (from Schedule A) OR your STANDARD DEDUCTION (see left margin) .
37 Subtract line 36 from line 34 . .. ....... . . . .
38 If line 34 is $99,725 or less, multiply $2,900 by the total number of exemptions claimed on line
6d. If line 34 is over $99,725, see the worksheet on page 32 . . .. ........
39 TAXABLE iNCOME. Subtract line 38 from line 37. If line 38 is more than line 3knter -0- . .
40 TAX(seepg33). Check if any tax is from a DForm(s) 8814 bUForm4972 .
41 ALTERNATIVE MINIMUM TAX (see page 34). Attach Form 6251 . . .
42 Add lines 40 and 41 ..............
43 Foreign tax credit. Attach Form 1116 if required . .
44 Credit for child and dependent care expenses. Attach Form 2441 , ,
45 Credit for the elderly or the disabled. Attach Schedule R .
46 Education credits. Attach Form 8863 . . . .' . .
47 Rate reduction credit. See the worksheet on page 36
48 Child tax credit (see page 37) . ....
49 Adoption credit. Attach Form 8839 . . . . . . . . .
50 Other credits from: a D Form 3800 b D Form 8396
c DForm 8801 d DForm (specify)
51 Add lines 43 through 50. These are your TOTAL CREDITS
52 Subtract line 51 from line 42. if line 51 is more than line 42, enter -0-
53 Self-employment tax. Attach Schedule SE . . . . . .
54 Social security and Medicare tax on tip income not reported to employer. Attach Form 4137 .
55 Tax on qualified plans, including IRAs, and other tax-favored accounts, Attach Form 5329 if required .
56 Advance earned income credit payments from Form(s) W-2
57 Household employment taxes. Attach Schedule H . .
58 Add lines 52 throu h 57. This is our TOTAL TAX .
59 Federal income tax withheld from Forms W-2 and 1099 59
60 2001 estimated tax payments and amount applied from 2000 return . . 60
61a Earned income credit (EIC) . . . . . . . . . . . . . . 61a
b Nontaxable earned income . . . . ~
62 Excess social security and RRT A tax withheld (see page 51) .. 62
63 Additional child tax credit. Attach Form 8812 . . . . . . . . 63
64 Amount paid with request for extension to file (see p~e 51) .. 64
65 Other payments. Check if from a D Form 2439 b U Form 4136 . 65
66 Add lines 59 60 61a and 62throu h 65. These are our TOTAL PAYMENTS
Refund 67 If line 66 is more than line 58, sublractllne 58 from line 66. This is the amount you OVERPAID.
68a Amount of line 67 you want REFUNDED TO YOU . . . . . . _ . . .. .
Direct deposit? 1 231382241 I..... D' f)(1
See page 51 ~ b Routing number ... c Type: Checking ~ Savings
and fill in 68b, ~ d Account number I 208312 HA I
68c, and G8d.
69 Amount of line 67 u want APPLIED TO YOUR 2002 ESTIMATED TAX . ~ 69
Amount 70 AMOUNT YOU OWE. Subtract line 66 from line 58. For details on how to pay, see page 52
You Owe 71 Estimated tax enalt . Also include on line 70 . . . . .. 71
Third Do you want to allow another person to discuss this return with the IRS (see page 53)? DYES. Complele the following, DNO
Party Oesignee's Phone Personal identification
Designee name ~ no. ~ number (PIN) ~
Sig n Under penalties of perjury, I declare that I have examined this return and accompanying schedules and statements, and to the best of my knowledge and
Here belief, they are true, correct, and complete. Declaration of preparer (other than taxpayer) is based on all information of which preparar has any knowledge,
~ Your signature Date Your occupation Daytime phone no.
Joint return? CARPENTER
See page 19. S' t If a J'oint return, BOTH must sign. Date Spouse's occupation Home phone no,
Keep a copy pause 5 signa ure,
for your records
Preparer's
signature
Form 1040 2001
Tax and 34
Credits 35a
Standard
Deduction
for~
. People who
checked any
box on line
35a or 35b OR
who can be
claimed as a
dependent. see
page 31.
. All others:
Single. $4,550
Head of
household,
$6,650
Married filing
jointly or
Qualifying
widow(er),
17,600
Married filing
separately,
Other
Taxes
Paid
Pre parer's
Use Only
DBlind.
~ 35a
Check if
self-employed
EIN
Phone no.
ZIP code
Date
3/11/2002
Firm's name (or
yours if self-employed),
address, and ZIP code
PS TAX AND PAYROLL
52 SOUTH PITT STREET
CARLISLE
State P A
nillili
l,""~;:" "",;
Pa e2
56,810
.~
8,984
47,826
38 5800
39 42 026
40 7,026
41
42 7,026
600
600
6,426
51
52
53
54
55
56
57
~ 58
.~
6,426
12,251
12,251
5,825
5,825
Prepare~s SSN or PTIN
P00014279
23-2933778
717-245-8581
17013
Form 1040 (2001)
'-"
Internal Revenue Service 99
Name(s) shown on Form 1040
RICKY L HAIR
Medical
and
Dental
Expenses
SCHEDULE A
(Form 1040)
Department of the Treasury
Taxes You
Paid
(See
page A-2.)
Interest
You Paid
(See page A-3.)
Note.
Pe~onal
interest is
not
deductible.
Gifts to
Charity
If you made a gift
and got a benefit for
it see a e A-4.
Casualty and
Theft Losses
Job Expenses
and Most
Other
Miscellaneous
Deductions
(See
page A-5 for
expenses to
deduct here.)
Other
Miscellaneous
Deductions
Total
Itemized
Deductions
UtL
M\W:",Ji::,
Schedule A - Itemized Deductions
OMS No. 1545.0074
2001
Attachment Sequence No.
Attach to Form 1040. See Instructions for Schedule A Form 1040 . 07
Your social security number
191-46-2254
Name
3820
56,810
Caution. Do not include expenses reimbursed or paid by others.
1 Medical and dental expenses (see page A-2)
2 Enter amount from Form 1040, line 34. . 2
3 Multiply line 2 above by 7.5% (.075) .
4 Subtract line 3 from line 1. If line 3 is more than line 1 enter -0-
5 State and local income taxes .
6 Real estate taxes (see page A-2). . . . . . .
7 Personal property taxes . . . .
8 Other taxes. g1:1 m ___ _ _ _ ___ ___ ___ ___ _ _ _:p _ ___ _ _ __ ___ ___.1 9
-----------------------------------.-------:p-----------
9 Add lines 5throu h8 . . . . ------
10 Home mortgage interest and points reported to you on Form 1098
11 Home mortgege interest not reported to you on Form 1098. If
paid to the person from whom you bought the home, see page
A-3 and show that person's name, identifying no., and address
4,261
10
4,509
Address
TIN _ __ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ __ _ _ _ _ __ _ _ _ _ _ __ _ __ _ _ __ __ _ __ _ __ __ 11
12 Points not reported to you on Form 1098. See page A-3
for special rules . . . . . . . . . . . . . 12
13 Investment interest. Attach Form 4952 if required. (See
page A-3.) . . . . . . . . . . 13
14 Add lines 10 throu h 13 . . .. ....
15 Gifts by cash or check. If you made any gift of $250 or
more, see pageA-4 . . . . . . .
16 Other than by cash or check. If any gift of $250 or more,
see page A-4. You must attach Form 8283.1f over $500 . .
17 Carryover from prior year . . .
18 Add lines 15 throu h 17 . . .
3,820
155
155
19 Casualt or theft loss es . Attach Form 4684. See a
20 . Unreimbursed employee expenses - job travel, union
dues, job education, etc. You must attach Form 2106
or 2106-EZ if required. (See page A-5.)
-------------------------------------------:p-------.---------
.F.9gM f_1_q~ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _:p _ _ _ _ _ _ _ _ _ _ _ _ !,q~~
21 Tax preparation fees . . . . . . . . . . . .
22 Other expenses - investment, safe deposit box, etc. List
type and amount ________________________J_________________
-------------------------------------------:p-----------------
-------------------------------------------:p-----------------
1536
100
1,636
23 Add lines 20 through 22 ......
24 Enter amount from Form 1040, line 34 . 24
25 Multiply line 24 above by 2% (.02) . . . . . 25
26 Subtract line 25 from line 23. If line 25 is more than line 23, enter -0-
27 Other - from list on page A-6. List type and amount
$
-----------------------------------------.-----------------------$---------------
28 Is Form 1040, line 34, over $132,950 (over $66,475 if married filing separately)?
0No. Your deduction is not limited. Add the amounts in the far right coiumn
for lines 4 through 27. Also, enter this amount on Form 1040, line 36.
DYes. Your deduction may be limited. See page A-6 for the amount to enter.
1136
500
For Paperwork Reduction Act Notice, see Form 1040 instructions,
(HTA)
Schedule A (Form 1040) 2001
J"<
,'~,~ . '""'"
-.,
,'J
,I' L
"~
,
Form
2106
Employee Business Expenses
Department of the Treasury
Internal Revenue Service 9
Your name
RICKY L HAIR
See separate instructions.
Attach to Form 1040.
Occupation in which you incurred expenses
CARPENTER
Part I
Employee Business Expenses and Reimbursements
STEP 1 Enter Your Expenses
1 Vehicle expense from line 22 or line 29. (Rural mail carriers: See instr.)
2 Parking fees, tolls, and transportation, including train, bus, etc., that
did not involve overnight travel or commuting to and from work .
3 Travel expense while away from home overnight, including lodging,
airplane, car rental, etc. Do not include meals and entertainment .
4 Business expenses not included on lines 1 through 3. Do not include
meals and entertainment . . .. ......
5 Meals and entertainment expenses (see instructions)
6 Total expenses. In Column A, add lines 1 through 4 and enter the
result. In Column B, enter the amount from line 5 . . . . .
J
, ,.;'~
-', 2 ' , ~'\if~l'~.I!;
OMS No, 1545-0139
2001
Attachment Sequence No.
54
Social security number
191-46-2254
Column A
Other Than Meals
and Entertainment
Column B
Meals and
Entertainment
Note: If you were not reimbursed for any expenses in Step 1, skip line 7 and enter the amount from line 6 on line 8.
Step 2 Enter Reimbursements Received From Your Employer for Expenses Listed in Step 1
7 Enter reimbursements received from your employer that were not
reported to you in box 1 of Form W-2. Include any reimbursements
re orted under code "L" in box 12 of our Form W-2 see instructions
Step 3 Figure Expenses To Deduct on Schedule A (Fonn 1040)
8 Subtract line 7 from line 6. If zero or less, enter -0-. However, if line 7 is greater
than line 6 in Column A, report the excess as income on Form 1040, line 7 8
Note: If both columns of line 8 are zero, you cannot deduct employee
business expenses. Stop here and attach Form 2106 to your return.
9 In Coiumn A, enter the amount from line 8. In Column B, multiply
line 8 by 50% (.50). (Employees subject to Department of
Transportation (DOT) hours of service iimits: Multiply meal
~enses by 60% (.60) instead of 50%. For details, see instructions.) . . . . .
UCheck this box for Employees subject to DOT hours of service limits.
7
1,536
1,536
10 Add the amounts on line 9 of both columns and enter the total here. Also, enter the total on
Schedule A (Form 1040), line 20. (Fee-basis state or local government officials, qualified
performing artists, and individuals with disabilities: See the instructions for special rules on
where to enter the total. . . . . . . . . . . . . . . . . . .
For Paperwork Reduction Act Notice, see instructions. (HTA)
10 1,536
Form 2106 (2001)
,W;;
Part II Vehicle Exnenses
Section A - General Information (You must complete this section if you (a) Vehicle 1 (b) Vehicle 2
are claimino vehicle exnenses.)
11 Enter the date the vehicle was placed in service 11 4/1/1992
12 Totai miles the vehicle was driven during 2001 12 25,213
13 Business miles included on line 12 13 2,600
14 Percent of business use. Divide line 13 by line 12 14 10.31%
15 Average daily roundtrip commuting distance 15
16 Commuting miles included on line 12 16
17 Other miles. Add lines 13 and 16 and subtract the total from line 12 17 22613
18 Do you (or your spouse) have another vehicle available for personal use? . . . . . . . . .0Yes
19 Was your vehicle available for personal use during off-duty hours? .... . . . . .[8JYes
20 Do you have evidence to support your deduction? . . . . . . . . . . .0Yes
21 If "Yes," is the evidence written? . . . . . . . . . . . .[KJYes
Section B - Standard Mileage Rate (See the instructions for Part II to find out whether to complete this section or
Section C.
22 Multi I line 13 b 341/2 cents .345
Section C - Actual Ex enses
23 Gasoline, oil, repairs, vehicle
insurance, etc. . . . .
24a Vehicle rentals . .
b Inclusion amount (see instructions)
c Subtract line :24b from line 24a . .
25 . Value of employer-provided vehicle
(applies only if 100% of annual
lease value was included on Form
W-2 - see instructions)
26 Add lines 23, 24c, and 25 .
27 Multiply line 26 by the
percentage on line 14 . .
28 Depreciation. Enter amount
from line 38 below . . . .
29 Add lines 27 and 28. Enter
total here and on line 1 .
Section D-Depreciation of Vehicles
for the vehicle.
~il ,..."~"""'~__'
,
Form 2106 (2001)
RICKY L HAIR
30a Enter cost or other basis (see
instructions) ....
b Enter the date the vehicle was
placed in service
31 Enter amount of section 179
deduction (see instructions) .
32 Multiply line 30 by line 14 (see
instructions if you elected the
section 179 deduction) . . . . . . .
33a Enter depreciation method,
either "200% DB", "150% DB" or "SL"
b Enter depreciation percentage
34 Multiply line 32 by the percentage
on line 33 (see instructions) . .
35 Add lines 31 and 34 . . . .
36 Enter the limit from the table in
the line 36 instructions . . .
37 Multiply line 36 by the percentage
on line 14 . . .
38 Enter the smailer of line 35 or
line 37. Also enter this amount
on line 28 above . . . .
-
I.",,,
- i 1. t'i$",1i;~f'ii1-i'~;,
1- ", ~"
",--I' ,-"
191-46-2254
Page 2
DNo
DNo
DNo
DNo
897
29
(Use this section only if you owned the vehicle and are completing Section C
30a
32
Form 2106 (2001)
,
_ HOtlRS
R OVERTIME
RATE
24.00
16.00
TE
":f
"'N.
"'~~~ P~R!~~'~~-r
. I
AMOUNT
DeSCRIPTION
20.50_
20.50
492.00 Vacl?ay
328 :0-:0 Holid"
11-25 \:0
12-01-02
.....-..--.-...-....--.....]
'I TOTAL PAY
_.___,_...._._u_____".._'_~
~~_.....~
82Q..00
r-....--........_-_......_.~...__......_-_.-_..._-.
H,~'...""''\,''"-'~___.'_,_, ,__, ".", i"
FEDWH
401k
;.._.
,DEOUCTlONS THIS PE~IOD
137.72 MED.
41. 00 "Fe'es'
11_84 FICA 50.64 PAWg
. 2:56 Ne"t:l:,rr" ---414--:-D -bent
22 :87. CV .
3 . '2.i chUcr
--------1
.. .8~.,2:6 "! DED1%~ONS i
"127.84
..
405.8B
~ .. . 'j...'4L'" ...
.._ .._....l-JET PAY
,'!
EMPLOYEE INFORMATION
..__"__._.,___""._..._.,,__~~.,,~.._.._~..____~~~:.~~~.T2!:~l::~_
.. ~_.
Ricky L-g"ir
191-46":z254
034
GROSS
'FWJ{
45-761. 21FlCA .
7:!Hj:L.95SWH'
33-96:7 (14 O:rK
1243.1iNEr'
2183.13
.23535.aO
_00
.o,=.,y
Eel
PAY
TO THE
ORDER
OF
EICHELBEllGEJJ Construction Inc.
.' 124 W. Church St. Pn Box 459 DillsbUfg. PA 17019-0459
I. ". .... ....... ,',
'i1~~~[t",'"' :\;'~~
. _Riclfy :&- }I~ir;; . _ ,
, 134:> West'Trindle'Road '
Carlisle, PA 17013
L
12-06-2002
Net.DD
PAYROLL
CHECI<'
208:112000
'414 :12
DATE
~.
--, CHECK NO.
AMOUNT
ff'':. j;:~':'",,'i 1. ". 1:' ~
414.12
414.12
.00 .
~''j1 '" ""fi' ~<
1fc,,",'''''. .# "'ffl t,
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NON-NEGOTiABLE
EICHELBERGER CONSTRUCTION INC,
'';
DEFENDANT'S
EXHIBIT
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Eichelberger Construction Inc
Employee Weekly Payroll Verification
System Date, 12
System Time:
Page 1
26-Z002
8:36 am
034 Ricky ~ Hair
Hire Date e-U-~994
Classification I GCe
Shop Rate
$:010.50
Filling Status S - 0
40111: Rate 5.00 %
Period
End Date 12-22-02
Company <:----- Posted Rates ---
Date Cert Job Pay Type Hours Rate Amount Cash Frg Fringes Pension S\F Class Base Supr Sub Fringe Total
Add, Total
02.246 1041.109 Suprn Add per Hr 27.60 S 008
12-16-02 X 02.246 1041.109 Field Wages 8.00 20.50 164,00 2,09 5.04 S Suprn 19,19 .69 19,88 7,13 27.01
12-17-02 X 02,246 ~04L109 Field Wages 8.00 20.50 164,00 2.09 5,04 S SUprn 19.19 .69 19.88 7.13 27.01
12-18-02 X 02.246 1041.109 Field Wages 8.00 20.50 164.00 2.09 5.04 S Suprn 19.19 .69 19.88 7.13 27.01
12-19-02 X 02.246 1041.109 Field Wages 8.00 20.50 164.00 2.09 5.04 S Suprn 19.19 -69 19.88 7.13 27.01
12-20-02 X 02.246 1041.109 Field Wages 8.00 20.50 164.00 2.09 5.04 S Suprn 19.19 -69 19.88 7.13 27.01
Time Totals 40.00 847.60
EMPLOYEE TOTALS
<:-----_._._....~-~--_._---
lJDita
Field 40.00
Field OT
Shop Hourly
Super/Forman Add
Truck
Vacation
Holiday
Wage Adjustments
Bonus
PAYS
-------------.-------->
Current YTD
820.00 39,520.85
169.13
41.00
27.60 1,610.94
1,367.50
1,968.00
1,209.50
141.69
5,423.12
<-.~-.~-..--.-.- DBDUCTIONS -------------->
."'""
Current
145.18
52,35
12,24
23.64
8A8
<------..-....
FWH
FICA
MED
SMa
Local
OPT
Taxable
803,39
844.39
844,39
844.39
847.60
YTD
9,188.65
3,179.98
743.70
1,436.05
514 .45
10.00
401K Match
Holiday
Disability Ins
Life Insurance
Health Insurance
COMPANY DINGES ___h_.______>
Per Hour CUrrent YTD
.5125 20.50 1153.06
.1428
.0578
1.3795
5.71
2.31
55.16
TOTAL DEDUCTXONS
TOTAL FRXNGliCS $2.0925 /Hour
$241.89 $15,012.83
DEDUCTIONS Pension AOl.50 7738.28
CUrrant YTD
41.00 2,306,13
3.21 154.08
127.84 5,946.08 PAID TINE Drr
2.56 119,12
BegiIlIling Used Available
$174.6~ $8,525.41
Vacation Hours 109.0 96.0 13.0
Personal Hours 16.0 .0 16.0
Sick Hours 40.0 .0 40,0
Current YTD
$431;'10 21,836.14
'I'O'I'AL TAXBS
'I'O'I'A~ EARNINGS
$847.60
$51,551.13
MISC.
401K
Dental
Domestic
Accounting Fees
NET FAY
4-LF\-\
L,\CUSTO>ll!llroR1"S\E"l_PR Eel hymn V.rJ.fi~~.,an.rpt
c
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),.-- 'I ~
State Commonwealth of Pennsvlvania
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 02/06/03
Tribunal/Case Number (See Addendum for case summary)
ORDER/NOTICE TO WITHHOlD INCOME FOR SUPPORT
bid. c2t)Cl/-("l/f({p (!/C')L
PI}{'sES 5(f)?/oI/790
o Original Order/Notice
@ Amended Order/Notice
o Terminate Order/Notice
Employer/\Nithholder's Federal EIN Number
RE: HAIR, RICKY L.
Employee/Obligor's Name (Last, First, MJ)
191-46-2254
Employee/Obligor's Social Security Number
4053000031
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
EICHELBERGER CONSTRUCTION INC
PO BOX 459
124 W CHURCH ST
DILLSBURG PA 17019-1232
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-namec;l employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 711.96 per month in current support
$ 25.00 per month in past-due support Arrears) 2 weeks or greater? G9yes 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 $ 736.96 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:
$ 170.07 per weekly pay period.
$ 340.14 per biweekly pay period (every two weeks).
$ 368.48 per semimonthly pay period (twice a month).
$ 736.96 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydateldate of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's! obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #10 on pg. 2).
If remitting by EFl/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.
Date of Order: FES
., 1093
/9.
4..
Service Type M 5~\{i;:,'~> ~~I tf m~, ~,!1'rJ
rlW.-V~lt." ~'~i'fXi~~';!w:',:;'~"~:iI'
2- J.()-=>,
OMB No.: 0970-0154
7CM4:=
Form EN-028
Worker ID $IATT
r.:,i
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t,
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~ "M..~-*'\JI>'E!t~)
.
" "
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o I(!;hecked you are required. to provi(fe a copy of this form to you(employee. Ifyouremploye~ works in a state that is
dltterent 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, tribaliy-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 ollhis 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 identifythe portion ollhesingle payment that is attributable to each
employee/obligor.
4.' RepOltilo8 t1.~ Paydatc/Da!e a(Witl.l.aldil ,g. You must lepo,! !I,c paydateldate af ,,;11,1 ,,,ldiloS "I,elo ,,,,,d;"5 tl,e payl,,""t. The
j:}dyda.Lci'Jate of vvitl.l.old;lIg is tLe dab:. Oil vvL:d. anlouht vvM vvitLLeld noh, L1IC ellll-'Iuyee's YVages. You must comply with the law of the
state ollhe 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 ali support Order/Notices due to Federal or State withholding limits, you must foliow
the law of the state of employee's/obligor's principal place of empioyment. You must honor ali Orders/Notices to the greatestextent
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: 2516777000 -
EMPLOYEE'S/OBLlGOR'SNAME: HAIR, RICKY L.
EMPLOYEE'S CASE IDENTIFIER: 4053000031 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
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 ollhe State in which he or she is employed governs.
9. Anti-discrimination: You are subject to afine 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. 91673 (b)1 ;or 2) the amounts aliowed by the State ollhe employee's/obligor's principal place of employment.
The.Federallimitapplies 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:
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 (717)240-6248 or
by internet www.childsupport.state.pa.us
Page 2 of 2
Form EN-028
Worker ID $IATT
Service Type M
OMB No,: 0970.-0154
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ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: HAIR, RICKY L.
PACSES Case Number 205104790
Plaintiff Name
SHERRY L. HAIR
Docket Attachment Amount
01=644"6CIVIL$ 259.00
Child(ren)'s Name(s):
DaB
PACSES Case Number 401000062
Plaintiff Name
LOU A. HAIR
Docket Attachment Amount
12~92 $ 477.96
Child(ren)'s Name(s):
;~~~liA'~~/ ."
DaB
. . . . i~~~[i%~~
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.
Olf 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
Piaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
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/obiigor's employment.
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
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
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through the employee'sJobligor's employment.
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Ol! ~;;~~ked, you are required to enroll the child(ren) ."
identified above in any health insurance coverage available
through the employee'sJobligor's employment.
Addendum
Form EN-028
Worker ID $IATT
Service Type M
QMB No.: 0970-0154
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LAW OFFICES
JOHN B. MANCKE
P. RICHARD WAGNER
EDWARD F. SPREHA, JR.
MANCKE, WAGNER & SPREHA
2233 NORTI-I FRONT STREET
HARRISBURG. PA 17110
PHONE (717) 234-7051
FAX (717) 234-7080
June 6, 2003
E. Robert Elicker, Esquire
9 North Hanover Street
Carlisle, P A 17013
Re: Hair v. Hair
Dear Bob:
This will confirm my telephone conference with Tracey requesting that the
pre-trial statements for Friday not be necessary because the parties are close to an
agreement.
IT, for some reason, there is no agreement, then we will contact your office,
and we will contact you if we do have an agreement.
Your attention is appreciated.
//J
.
/
P.
,/
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PRW/dks
cc: Douglas G. Miller, Esq.
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State Commonwealth of Pennsylvania
Co.lCity/Dist. of ClJME\ERLAND
Date of Order/Notice 08/06/03
Tribunal/Case Number (See Addendum for case summary)
RE: HAIR, RICKY L.
~\(j-\lqo
D I -ld-lYro
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4Otoco 002
t 2.~<6 9. Q'2
o Ongmal Order/Notice
@ Amended Order/Notice
o Terminate Order/Notice
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
EmployerlWithholder's Federal EIN Number
Employee/Obligor's Name (Last, First, MI)
191-46-2254
Employee/Obligor's Social Security Number
4053000031
Employee/Obligor's Case Identifier
(See Addendum for plaintiH names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MO
EICHELBERGER CONSTRUCTION INC
PO BOX 459
124 W CHURCH ST
DILLSBURG PA 17019-1232
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.
$ 537.34 per month in current support
$ 48.52 per month in past-due support Arrears 12 weeks or greater? Oyes <X> 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 $ 585..86 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:
$ 135.20 per weekly pay period.
$ 270.40 per biweekly pay period (every two weeks).
$ 292.93 per semimonthly pay period (twice a month).
$ 585.86 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydateldate of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to t.he 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).
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 to (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
,~
BY THE COURT:
Date of Order:
AUG 0 7 2003
Service Type M
OMB No.: 0970-0154
Form E N-028
Worker ID $IATT
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1IIIl>'t:
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
D If checked you are required to provide a copy of this form to your. employee. If your employe~ 'Yorks in.a state that is
different rrom the state that issued this order, a copy must be provided to your employee even If the box 15 not checked.
r
,
1. We ilPpreciate the voluntary compliance of Federally recognized Indian tribes, triballY-Dwned 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 of the single payment that is attributable to each
employee/obligor.
4.*~t~~",,~p'ldateld.te <>f ..itl.l,oldil,g ..hen ,el,di""l"e payl''''''t. TI,e
payd.te/date of ..itl,l,oldil,g is lI,e date 01, ..I,iel, ""'O",,t ..a' ..itl,l,eld flom tl,,, e",ploy"e', ..ages. You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and fOlWard 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 #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.
WITHHOt.DfR'S ID: 2516777000
EMPLQYEE'S/OBlIGOR'S NAME: HAIR , RICKY L.
EMPLOYEE'S CASE IDENTIFIER: 4053000031 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
7. Lump Sum PaymentS: You may be required to report and withhold from lurnp 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 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. 91673 (b)1; 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 15 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 www.childsupport.state.pa.us
Page 2 of 2
Form EN-028
Worker ID $IATT
Service Type M
QMB No.: 0970-0154
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ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: HAIR, RICKY L.
PACSES Case Number 205104790
Plaintiff Name
SHERRY L. HAIR
Docket Attachment Amount
01-6446 CIVIL$ 259.00
Child(ren)'s Name(s):
DaB
PACSES Case Number 401000062
Plaintiff Name
LOU A. HAIR
Docket Attachment Amount
1238892 $ 326.86
Child(ren)'s Name(s):
DaB
you are required to enroll the child(ren)
in any health insurance coverage available
through the employee'slobligor's employment.
If
you are required to enroll the child(ren)
in any health insurance coverage available
employee'slobligor's employment.
PACSES Case Number
Plaintiff Name
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
you are required to enroll the child(ren)
in any health insurance coverage available
employee'slobligor's employment.
If checked, you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
If checked, you are required to enroll the ch i1d (ren)
in any health insurance coverage available
employee's/obligor's employment.
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
Addendum
Form EN-028
Worker ID $IATT
Servi ce Type M
OMB No.: 0970-0154
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SHERRY L. HAIR,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL V AN1A
Plaintiff,
v.
: NO: 2001-6446
: CIVIL ACTION - LAW
RICKY L. HAIR,
: IN DIVORCE
Defendant
PRAECIPE
TO THE PROTIlONOTARY:
Please withdraw Counts I, II, and ill of Plaintiff's Complaint
Respectfully submitted,
P.Ric
I _ 3103
2233 North Front Street
Harrisburg, P A 17110
(717) 234-7051
Attorneys for Plaintiff
Date: <gIN! ~3
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ORDER/NOTICE TO WITHHOLD I~COME FOR SUPPORT
State Commonwealth of Pennsylvania .R 0.5 i UnqOQorig~naIOrd~rINotice
Co.lCity/Dist. of CUMBERLAND [) .. . t.f(jb ~ 1l,)'~'An1eri~i!dQ'cler/!'lo!iCe
Date of Order/Notice 08/26/03 / to t!I. 0 TerminateOrderlNotice
Tribunal/Case Number (See Addendum for case summary)
EmployerlWithholder's Federal EIN Number
RE: HAIR; RICKY L.
Employee/Obligor's Name (last, First, MI)
191-46-2254
Employee/Obligor's Social Security Number
4053000031
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, Ml)
EICHELBERGER CONSTRUCTION INC
PO BOX 459
124 W CHURCH S'J:'
DILLSBURG PA 17019-1232
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.
$ 303.34 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
$ O. 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 303.34 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:
$ 70.00 per weekly pay period.
$ 140.00 per biweekly pay period (every two weeks).
$ 151.67 per semimonthly pay period (twice a month).
$ 303.34 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 (ost 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).
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/Oi:)/igor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BY THE COU
Date of Order: AlJ8 2 7 2003..-
Service Type M
OMB No,: 0970-0154
Form E N-028
Worker ID $IATT
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liliiU
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ADDITIC)NALINFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o Iflihecked you are re~uired to provide a copy of this form to your employee. If your employe~ \yorks in.a state that is
di erent from the stati, 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 lacated an a reservatio.rl that chaase to. withhald 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 of the single payment that is attributable to each
employee/obligor.
4. * Repo'ting tl,e Pa,date/Dateo(Withl,oldilog. \'0" 1,1u,t ,epolt tl,e pa,dale'date of ..itl,l,ddiJ,g ..I,en '''' ,dil1g II,,, pa,'ee! ,I. Th"
paydateldilte of vvitLt,oleJil,g,i5 the: dale 011 vvllkh ClllIOUl,t yv8.5 vvitlll,t':ld flOll1 tl.e elllployee/~ yyage5. You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
5. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
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 ID: 2516777000
EMPLOYEE'S/OBLlGOR'S NAME: HAIR, RICKY L.
EMPLOYEE'S CASE IDENTIFIER: 4053000031 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
7_ Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If yau have any questians abaut lump sum payments, cantact the persan or autharity belaw.
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 (1 5 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.
1 1. 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:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (7171 240-6248 or
by internet www.childsupport.state.pa.us
Page 2 of 2
Form E N-028
Worker ID $IATT
Service Type M
OMBNo.:0970.0154
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ADDENDUM
Summary 01 Cases on Attachment
DelendanlfObligor: HAIR, RICKY L.
PACSES Case Number 401000062
Plaintiff Name
LOU A. HAIR
Docket Attachment Amount
1238 S 92 $ 303.34
Child(ren)'s Name(s):
DOB
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[Jlf cl1e~k~cl, y~u~;e r~~~ir~d to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
P ACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
Service Type M
Addendum
OMB No.: 0970-0154
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
you are required to enroll the child(ren)
above in any health insurance coverage available
employee's/obligor's employment.
Form EN-028
Worker ID $IATT
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
SHERRY L. HAIR ) Docket Number 01-6446 CIVIL
Plaintiff )
VS. ) PACSES Case Number 205104790
RICKY L. HAIR )
Defendant ) Other State ID Number
ORDER
AND NOW, to wit, on this
26TH DAY OF AUGUST, 2003
IT IS HEREBY
ORDERED that the support order in this case be 0 Vacated or OSuspended or
Gi) Terminated without prejudice or 0 Terminated and Vacated,
effective
JULY 1, 2003
, due to:
THE PARTIES' MARRIAGE SETTLEMENT AGREEMENT OF JULY 18, 2003. THERE IS A
BALANCE OF $77.02 OWED TO THE PLAINTIFF AND WILL BE PAID OFF WITH THE CURRENT
WAGE ATTACHMENT AND THE DIFFERENCE WILL BE REFUNDED TO THE DEFENDANT.
DRO: RJ Shadday
xc: plaintiff
defendant
P. Richard Wagner, Esquire
IX>uglas Miller, Esquire
BY THE ~T:
/'" /9,
4..
Kevin A. Hess
JUDGE
i}JI~Ji:::'~
Service Type M
Form OE-504
Worker ID 21005
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