HomeMy WebLinkAbout99-00964
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though no signatures have been affixed.
Following the completion of the agreement and
upon the Master receiving a completed agreement, he will
prepare an order vacating his appointment and counsel will
then be in a position to file a praecipe transmitting the
record to the Court requesting a final decree in divorce. Ms.
Lindsay.
(A discussion was held off the record.)
MS. LINDSAY:
1. Husband will pay to wife $25,000.00 within ten (10)
days of today by a payment through counsel in full
satisfaction of any obligation which he may have for equitable
distribution.
2. Husband will pay to wife alimony in the amount of
$900.00 per month commencing November 1, 2001, and continuing
each month thereafter for sixty (60) months. That alimony is
non-modifiable in term or amount and shall not be terminated
except upon the death of a party. Alimony will be paid
through the Domestic Relations Office of Cumberland County,
Pennsylvania.
The parties will cooperate to so advise Domestic
Relations immediately so that the wage attachment currently in
effect for spousal support will be modified effective November
1, 2001. In the event that it is not modified because of a
wage attachment and in November wife receives more than
$900.00 per month, she will promptly, within five (5) days of
receipt, refund that money to husband through counsel.
In the event that the parties can make a determination
that husband has a credit or that, in the alternative there is
an arrearage on the present spousal support order, the amount
of the credit will be reduced from the $25,000.00 payable in
the paragraph above or the amount of the arrearage added to
$25,000.00 payable in the paragraph above.
3. Husband will maintain insurance on his life with wife
as beneficiary in at least the amount of the unpaid alimony
called for in this order. Husband may reduce the amount of
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death benefit of the insurance as the alimony reduces.
Husband, within thirty (30) days of the date of this
agreement, will provide proof that there is life insurance in
the unpaid amount of initial alimony and from time to time, as
she may request, husband will provide proof that the insurance
is still in place and the premiums are paid.
4. Notwithstanding the fact that the parties have signed
affidavits of consent which will be signed and filed today or
tomorrow, they will not file a praecipe to transmit the record
until on or after December 1, 2001, to accommodate wife's
health insurance needs.
5. Nevertheless, commencing this date, husband will no
longer be responsible for un-reimbursed medical services
provided to wife after this date. He will, however, forward to
wife any reimbursement checks which he may receive on account
of services rendered to her. He will send those checks
within seven (7) days of receipt. Additionally, husband will
provide through counsel notice that he receives from his plan
of wife's exceeding the plan limits and he will, furthermore,
do nothing to interfere with her attempt to obtain
reimbursement for her exceeding the plan limits through his
health insurance plan so long as the parties are married.
6. Each of the parties will maintain their own financial
accounts, including the retirement benefits, as their own
separate property. In addition, the parties will retain any
other property that they have in their present possession at
this time.
7. Each party will be solely responsible for attorney fees
incurred in the course of this litigation.
8. Within ten (10) days of the date of this agreement,
wife will mark the lawsuit which she filed against husband in
the Court of Common Pleas of Cumberland County, Pennsylvania,
to the number 2000 Civil 8055 as settled and discontinued with
prejudice.
9. 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, statutory allowance, widow's
allowance, right of intestacy, right to take against the will
of the other, and right to act as administrator or executor in
the other's estate. Each will at the request of the other
.' .-. __ .I:"
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MRS. BROWN: Yes.
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MS. SUMPLE-SULLIVAN: And are you willing to
accept this in settlement of these claims?
MRS. BROWN: Yes.
MS. SUMPLE-SULLIVAN: And are you doing this
voluntarily?
MRS. BROWN: Yes.
MS. SUMPLE-SULLIVAN: And is there anything
today, I mean, are you having any kind of medical issues or
anything like that that you believe might be preventing you
from understanding what is going on here? Any kind of
medication or anything that you don't understand what's going
on today?
MRS. BROWN: No.
MS. LINDSAY: Mr. Brown, you've heard the
terms of the agreement as I have set them out today?
MR. BROWN: Yes, ma'am.
MS. LINDSAY: Did I recite correctly your
understanding of the terms of this agreement?
MR. BROWN: Yes, ma'am.
MS. LINDSAY: Are they acceptable to you
today?
MR. BROWN: Yes, ma'am.
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II
JAMES M. BROWN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL TERM - LAW
: NO. 99 - 964 CIVIL TERM
: DIVORCE
vs.
SUSAN DAPP BROWN,
Defendant
AFFIDAVIT OF CONSEm:
1. A Complaint in Divorce under !!l 3301 (c) of the Divorce Code was filed on
February 18, 1999.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety
days have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final Decree in Divorce after service of notice of
intention to request entry of the Decree.
I verify that the statements made in this Affidavit are true and correct to the best
of my knowledge, information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to
authorities.
!iLl<J(l~ f~W;/ i!hLruc-rJ
Susan Dapp Brown, Defendant
Date: /1)- 9 -1) I
JAMES M. BROWN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL TERM - LAW
: NO. 99 - 964 CIVIL TERM
V5.
SUSAN DAPP BROWN,
Defendant
: DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
!l3301lc) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2, I understand that I may lose rights concerning alimony, division of
property, lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a Divorce Decree is entered
by the Court and that a copy of the Decree will be sent to me immediately after it is
filed with the Prothonotary,
I verify that the statements made in this Affidavit are true and correct to the best
of my knowledge, information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to
authorities.
Date:
I /
rown, Defendant
!tLCj_()/
,
JAMES M. BROWN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Vs.
NO. 99 - 964 CIVIL
SUSAN DAPP BROWN,
Defendant
IN DIVORCE
RE:
Pre-Hearing Conference Memorandum
DATE:
Friday, July 20, 2001
Present for the Plaintiff, James M. Brown, is
attorney Carol J. Lindsay, and present for the Defendant,
Susan Dapp Brown, is attorney Barbara Sumple-Sullivan.
The parties were married on December 5, 1996, and
according to husband separated December 20, 1998. Wife avers
that the parties separated January 15, 1999. The month
difference in the date of separation allegations does not seem
to be significant but counsel can determine how they want to
approach the date of separation issue if they have a
disagreement about which date to use.
There are no children to this marriage.
has two children to a prior relationship.
Wife
A divorce complaint was filed on February 18,
1999, raising grounds for divorce of irretrievable breakdown
of the marriage. The parties will sign and file affidavits
of consent and waivers of notice of intention to request entry
of divorce decree so that the divorce can be concluded under
Section 3301(c) of the Domestic Relations Code. The
complaint did not raise any economic claims.
On March 31, 1999, wife filed a petition raising
economic claims of equitable distribution, alimony, alimony
pendente lite and counsel fees and costs.
Husband is 38 years of age and resides at 9100
Spring Way, Upper Marlboro, Maryland 20774 where he lives
alone. He is a union steamfitter/welder and according to an
income tax record that we have available today, his income for
the last year was nearly $90,000.00 gross. He is currently
paying support to wife in the amount of $1,300.00 per month.
The support calculation according to wife's attorney was based
on an income of $68,000.00 gross per year so there may have to
be some adjustment to the support payment that husband is
making after a review by the Domestic Relations Office.
Husband has not raised any health issues. Husband is directed
to file a current income and expense statement to be prepared
a week prior to the hearing to be scheduled.
wife is 48 years of age and resides at 16
Columbia Drive, Camp Hill, Pennsylvania with her mother and
brother. She is a high school graduate and has been
determined to be disabled and is receiving social security
disability in the amount of $664.00 per month. The nature of
her disability is an unstable mental condition. There is an
issue as to whether or not wife has any ability to make some
contribution for her own support and attorney Lindsay is going
to determine how she wants to approach that issue if it is an
issue that she feels needs to be developed.
The assets in this case are essentially minimal
since it was a short-term marriage. We have an issue
regarding whether or not the non-marital real estate where
husband resides in Maryland has increased in value or
decreased in value. We also have a pension that husband is
involved with through the Steamfitters. Counsel are probably
going to have the pension valued since the marriage was fairly
short to determine if husband may want to consider the option
of buying out wife's interest in the pension rather than
getting involved in a QDRO which would result in probably a
very small monthly payment to wife when husband ultimately
retires.
There are some savings and checking accounts;
there does not appear to be any dispute over household
tangible personal property. The pretrial statements also do
not show any marital debt.
With respect to the alimony claim, however,
there have been substantial allegations made regarding
husband's alleged misconduct. We are going to schedule a
separate hearing on that issue and counsel are directed to
provide each other a list of witness a month prior to the
hearing with a short statement as to what each witness will
testify to. Attorney Lindsay indicated that she would also
like to have a statement of the allegations that wife is going
to make regarding husband's misconduct. That statement should
probably be prepared by the end of August 2001 and provided to
attorney Lindsay. The list of witnesses, however, can wait
for an additional month as previously noted to be provided one
month prior to the hearing. Attorney Lindsay has also asked
that she be permitted to address marital misconduct issues
that may be raised against wife by husband in the testimony.
She will also do a statement setting forth issues which she
intends to raise. In any event, counsel are obliged to
provide each other a list of witnesses that they are going to
. --.. -.....
use at the hearing.
In addition to the marital misconduct
testimony, counsel are going to determine whether they need to
have real estate experts to address the question of whether or
not the real estate in Maryland has increased or decreased in
value.
Attorney Lindsay is going to determine also
whether she wants to take depositions of medical caregivers
for wife. If there is to be testimony on the question of
whether wife has some ability to contribute to her own
support, we will hear that testimony as well at the time of
the hearing.
Finally, there is an issue regarding the date
of separation as previously addressed in this memorandum and
counsel will be able to present testimony on that issue at the
hearing. It appears, as this testimony will develop, that we
need to first determine when the parties separated before we
get into some of these other matters so that it makes sense to
the Master to have the testimony on the date of separation
first at which time the Master will make an on the record
finding so that counsel can then proceed with the other
testimony immediately thereafter.
The Master will allow each counsel to go on the
record, if they wish, to make any statements as to what they
may need or will prepare in preparation for the first hearing.
Attorney Lindsay.
MS. LINDSAY: I would like to have a
statement from Ms. Sumple-Sullivan, and I would be happy to
provide her one, as to the rationale for the date of
separation that Mrs. Brown alleges. She could provide one for
me that her client does by way of being able to prepare for a
date of separation determination if we cannot stipulate to
tha t.
MS. SUMPLE-SULLIVAN: I was just interested
-- I just got handed a packet of information this morning -_ I
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"'~. .'JAMEs M. BROWN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL TERM- LAW
NO. 99 - 964 CIVIL TERM
SUSAN DAPP BROWN,
Defendant
DIVORCE
MOTION IN LIMINE
NOW COMES James M, Brown, by and through his counsel, Saidis, Shuff,
Flower & Lindsay and moves this Honorable Court as follows:
1. The parties hereto are husband and wife having been joined in marriage on
December 5,1996, and separated on or about December 20, 1998.
2. The parties are scheduled for a hearing before the Divorce Master on October
9,2001, at which hearing the Divorce Master will take testimony regarding the date of
the parties' separation and marital misconduct.
3. Respondent has advised that she intends to provide testimony regarding
allegations of marital misconduct which took place prior to the parties' marriage and
subsequent to their separation.
4. In civil cases, as in criminal cases, evidence of other acts which reflect on the
character or behavior of a party is generally inadmissible. Pennsylvania Rule of
Evidence 404. West Pennsylvania Practice, Pennsylvania Evidence Section 404-11.
5. None of the exceptions to the Rule are relevant in the instant case since
motive, opportunity, intent, preparation, plan, knowledge and identity or absence of
mistake or accident are not at issue but only the acts complained of.
..' - -. .~.-
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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
April 19, 2001
Carol J. Lindsay
Attorney at Law
SAlOIS, SHUFF, FLOWER & LINDSAY
26 West High Street
Carlisle, P A 17013
Barbara Sump Ie-Sullivan
Attorney at Law
549 Bridge Street
New Cumberland, P A 17070
RE: James M. Brown vs. Susan Dapp Brown
No. 99 - 964 Civil
In Divorce
Dear Ms. Lindsay and Ms. Sump Ie-Sullivan:
I am in receipt of counsels' letters regarding a request for me to proceed and most
recently Ms. Lindsay's letter saying that counsel have agreed that I should go ahead. I
am going to go ahead on the basis that there are no discovery issues outstanding and that
we are not going to get involved in discovery matters at the pre-hearing conference. I do
not want to see pretrial statements saying, for instance, "to be ascertained" or "unknown".
A divorce complaint was filed on February 18, 1999, raising grounds for divorce
of irretrievable breakdown of the marriage. No economic claims were raised in the
complaint.
On March 31, 1999, a petition raising the economic claims of equitable
distribution, alimony, alimony pendente lite, and counsel fees and expenses was filed by
the Defendant.
In accordance with P.R.C.P. 1920,33(b) I am directing each counsel to file a
pretrial statement on or beforc Monday, May 21, 200 I. Upon receipt of the pretrial
statements, I will immediately schedule a pre-hearing conference with counsel to discuss
v.
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JAMES M. BROWN
SUSAN DAPP BROWN
NO.
99 .. 964
CIVIL ACTION - LAW
IN DIVORCE
ORDER AND NOTICE SETTING HEARING
TO: James M. Brown , Plaintiff
Carol J. Lindsay , Counsel for Plaintiff
Susan Dapp Brown , Defendant
Barbara Sumple-Sullivan , Counsel for Defendant
You are directed to appear for a hearing to take
*
testimony on the outstanding issues in the above captioned
divorce proceedings at the Office of the Divorce Master, 9
Hanover Street, Carlisle, Pennsylvania on the 9th
of October 2001 at 9:00 a.m., at
North
day
which
place and time you will be given the opportunity to present
witnesses and exhibits in support of your case.
Hoff r, President JUdge
Date of Order and
Notice: 7/20/0 I
By:
Divorce Master
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
TELEPHONE (717) 249-3166
* TESTIMONY WILL BE LIMITED TO THE ISSUES ADDRESSED IN THE PRE..
HEARING CONFERENCE MEMORANDUM ON JULY 20, 200 I.
JAMES M. BROWN
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
99 - 964
NO.
SUSAN OAPP BROWN
CIVIL ACTION - LAW
IN DIVORCE
ORDER AND NOTICE SETTING HEARING
TO:
James M. Brown
Carol J. Lindsay
Susan Oapp Brown
Barbara Sumple-Sullivan
Defendant
, Counsel for Defendant
, Plaintiff
, Counsel for Plaintiff
You are directed to appear for a hearing to take
testimony on the outstanding issues in the above captioned
divorce proceedings at the Office of the Divorce Master, 9
Hanover Street, Carlisle, Pennsylvania on the Hili
of November 2001 at 9:00 a.m., at
North
day
which
place and time you will be given the opportunity to present
witnesses and exhibits in support of your case.
Pres iden t Judge
Date of Order and
Notice: 7/20/01
By:
Divorce Master
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
TELEPHONE (717) 249-3166
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Label
(See
instructions
on page' B.)
Use the IRS
lebel.
Otherwise,
please print
or type, .
Presidential
flBcllon Campaign ~
See a e 18. ,.
23 IRA deduction (see page 2B) . . , . .
24 Student loan interest deduction (see page 26) . . .
25 Medical savings account deduction. Attach Fonn 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 28)
29 Keogh and self-employed SEP and SIMPLE plans
30 Penalty on early withdrawal of savings. . . . . .
31a Alimony paid b Recipi!lnt's SSN ~ 17'1 i 1/1{ i S q 13
, 32 Add lines 23 through 31a.. ,....
33 Subtract line 32 from line 22. This is our adjusted gross in como
For Disclosure, Privacy Act. and Paperwork Reduction Act Notice, see page 54.
Filing Status
Check only
one box.
Exemptions
tf more than six
dependents,
see page 19.
Income
Allach
Copy B of your
Fonns W.2 and
W.2G here.
Also attach
Fonn(s) l099.R
If tax was
withheld.
If you did not
get a W.2,
see page 20.
Enclose, but do
not staple, any
payment. Also.
please use
Fonn 1040-V.
Adjusted
Gross
Income
Oepal1mont 0' tho Treasury-Internnl Rel/enue Service
U.S. Individual Income Tax Return
~@99
ILl' IRS Use C)'lly 00 nOl 'MIte or SUlcle In 1M SPIce.
I 1999, ending OMS No. 1545.0074
Your .oelal aecurtty number
578 :~2 ,0'/13
Spouse's soclals&curlty number
/79 i4L{ig9/3
.. IMPORTANT! ..
You must enter
your SSN(s) above,
Yes No Note. Checking
.Yes- will not
Change your tax or
reduce your refund.
For the year Jan. 1-0ec. 31. 1999. or other lax year beginning
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If a joint return, does your SpOuse want $3 to go to this fund? .
Single
Married filing joint return (ev~n if only one had income)
Married filing separate relurn. Enter spouse's social security no. above and full name here, ..
Head of household (with qualifying person). (See page 18.) If the qualifying person is a child but not your dependent,
enter this child's name here. ~
Qualifying widowlerl with dependent child (year spouse died.. 19 I. ISee page lB.)
Yourself. If your parent (or someone else) can claim you as a dependent 011 his or her tax} No. 01 boxes
return, do not check box 6a. '. . . . . . . . . . . . . . . chackad on
b 1:0 Spouse. . . , , . . , , . , . , , . . , . , . . . , . . ::::,d y~:r
c Dependents: (2) Dependent's (3) D,epenqenrs 14~ d qua,litymg children on fic
' last nam, social security number relatlOnshrp to eh,!d lor child tax who:
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10
11
12
13
14
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17
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19
20a
21 '
22
Total number of exemptions claimed
Wages. salaries. tips. ete, Attach Form(s) W.2 .
Taxable interest. Attach Schedule B'if required
Taxaexempt interest. DO NOT include on line 8a .
Ordinary dividends. Attach Schedule 8 if required
Taxable refunds, credits, or offsets of state and local income taxes (see page 21)
Alimony received . . . . . . . . . . . . . ,
Business income or (loss). Attach Schedule C or C.EZ . . . .
Capital gain or (loss), Attach Schedule 0 If required. If not required. check here ~ 0
Other gains or (losses). Attach Form 4797. . . , . . . . , , . . . .
Total IRA distributions. ~I - LJ b Taxabie amount Isee page 22)
Totafpensions and annuities ~ - U b Taxable amount (see page 22)
Rental real estate, royalties. partnerships, S corporations, trusts, etc. Attach Schedule E
Farm income or (loss), Attach Schedule F . . . , .
Unemployment compensation .
Social security benefits . 120a 1 I' b ~ax:mi~ a;ou~t (~ ;ag~ 24i
Other income. List type and amount (see page 24) ....................................
Add the amounts in the far right column for lines 7 through 21. This is your total Income ....
23
24
25
2B
27
28
29
30
31a
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9
10
11
12
13
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17
18
19
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21
22
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18
37
28
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63 459 30
/37813/
, ~
Cat. No. 12600W
.
Foon 1040 (19991
Tax and
Credits
Standard
Deduction
for Most
People
Single:
54.300
Head of
household:
$6.350
Married filing
jointly or
Qualifying
widow(er):
$7.200
Married
filing
separately:
$3.600
Other
. Taxes
Payments
Refund
Have it
directly
deposited! ... b
See pege 48
and fill In 86b, ~ d
66c. and 66d, 67
Amount 68
You 'Owe
Sign
Here
. Joint return?
See page 18,
Keep a copy
for your
records.
Paid
Preparer's
Use Only
34
358
36
Amount from line 33 (adjusted gross income) . , , . . . . . . . . .
Check if: 0 Vou were 65 or older, 0 Blind; 0 Spou.e was 65 or older, 0 Blind.
Add the number of boxes checked above and entor the total here. .. ... 358
b If you are married filing separately and your spouse Itemizes deductions or
you were a dual.status alien. see page 30 and check here . . . . . .... 3Sb 0
Enter your ttemlzed doductions from Schedule A, line 28. OR standard deductlof'l
shown on the left, But see page 30 to find your standard deduction if you checked any
box on line 358 or 35b or if someone can claim j'ou as a dependent , ,
Subtract line 36 from line 34 , , . . . .
If line 34 is $94.975 or less. multiply $2,750 by the total number of exemptions clelmed on
line 6d. If line 34 is over $94.975, see the worksheet on page 31 for the amount to enter.
Taxable income, Subtract line 38 from line 37. If line 38 is more than line 37, enter -0-
Tax (see page 31). Check il any tax is from e 0 Form(s) 8814 b 0 Form 4972 . ~
Credit for child and dependent care expenses. Attach Form 2441 41
Credit for the elderly or the disabled. Attach Schedule R . 42
Child tax credit (see page 33) . . 43
Education credits. Attach Form 8863 . . 44
Adoption credit, Attach Form 8839, . . 45
Foreign tax. credit. Attach Form 1116 if required . 46
O1her, Check If from a 0 Form 3800 b 0 Form 8396
00 Form 8801 d 0 Form (specify) 47
Add lines 41 through 47, These are your total credits . , . , .
Subtract line 48 from line 40. If line 48 is more than line 40, enter -0- .
Self-employment tax. Attach Schedule SE .
Alternative minimum 'tax. Attach Form 6251
Social security and Medicare tax on lip income not rep.orted to employer, Attach Form 4137
Tax on IRAs, other retirement plans, and MSAs. Attach Form 5329 if required
Advance earned income credit payments from Form(s) W-2 .
Household employment taxes, Attach Schedule H. ,
Add lines 49 through 55, This is your total tax.
Federal income tax withheld from Forms W-2 a.nd 1099
1999 estimated tax payments and amount applied from 1998 return.
Earned income credit. Attach Sch. EIC if you have a qualifying child
Nontaxable earned income: amount , . ~ 1 I I
and type ~ ........,......................_m.............., 59a
Additional child tax. credit. Attach Form 8812 . 60
Amount paid with request for extension to file (see page 48) 61
Excess social security and RRTA tax. withheld (see page 48) 62
O1her payments, Check if from a 0 Form 2439 b 0 Form 4136 63
Add Jines 57, 58, 59a, and 60 through 63. These are your total payments . ~
If line 64 is more than line 56, subtract line 56 from line 64, This is the amount you OVERPAID
Amount of hne 65 you want REFUNDED TO VOU, , . . . . ~
~
48
49
00
51
52
53
54
55
56
1/'11,7/
Pogo 2
q
37
38
39
40
41
42
,43
44
45
48
47
48
49
50
51
52
53
54
55
56
57
58
59a
b
/0 Zbg
!iSOD
322'1/
b 2.3'1
Do
63
00
60
61
62
63
64
65
66a
Routing number
Account number
Amount of line 65
I
ou wanl APPLIED TO YOUR 2000 ESTIMATED TAX ~
o
b "23'1
00
b 23'1
00
If Une 56 is more than line 64. subtract line 64 from line 56, This is the AMOUNT YOU OWE,
For details on how to pay, see page 49, . . , .. ." ....
69 Estimated tax. penalty, Also include on line 68 . 69
Under penalties 01 pef)ury, I declare that I have examined thiS return and accompanying schedules and statements, and to the best of my knowledge and
belief, they are true, correc!. and complete, Declaration 01 preparel' (other than taxpayer) is based on alllnfonnation O! which preparer has any knowledge.
~ Your" nalUre 2- tv]. R~ 1'1
,. Spo e Slgnalure II a JOint return, 80TH must sign
I 27z%c
Your OCcupation
5 feam f:-Her
Date
Spouse's occupation
Prepi3rer's
signature
Firm's name (or yours ~
If self-employed} and
address
'U.S. GCMlfnmenl PTlnbng Qrhcc: 1999 - 45&063
Date
Check II
selr-employed 0
@ Prlntod on rocrcJ<<J fnf'IJr
Preparer'S SSN or PTlN
EIN
ZIP code
Fonn 1040'(1999)
'.
SCHEDULES A&B Schedule A-Itemized Deductions
(Fonn 1040)
(Schedule B Is on back)
Oe~r1mCtll ollhe T/l.8Sury
Inllmll RltVIflU8 Serviee {Pj ... Attach to Form 1040. .. See Instructions for Schedules A and B (Fonn 1040).
Nllme{sl.!hown on Form 1040
Jqmes M, Bruwn
Medical
and 1
Dental 2
Expenses 3
4
Taxes You 5
Paid 6
(See 7
page A.2,) 8
9
Interest 10
You Paid 11
(See
page A'3,)
Note.
Personal 12
interest is
not
deductible. 13
14
Gifts to 15
Charity
If you made a 16
gift and got a
benefit for it, 17
see page A-4. 18
Casually and
Theil Losses 19
Job Expenses 20
and Mosl
Other
Miscellaneous
Deductions
21
(See 22
page A.5 for
expenses 10
deduct h"e.)
23
24
25
26
Other 27
Miscellaneous
Deductions
Total 28
Itemized
Deductions
OMB No. 1545.0074
Caution. Do not include expenses reimbursed or paid by olhers.
Medical and dental expenses (see page A-l) .
Enter amount Irom Form 1040. line 34. 2
Multiply line 2 above by 7,5% (,075), . . , 3
Subtract line 3 from line 1, If line 3 is more than line 1, enter .0-
State and local income taxes . 5
Real estate taxes (see page A-2). . . . . . " 6
Personal property taxes. . . . . , , . . .. 7
Other taxes, List type and amount ~ ..........,.........
Add 'Iintis '5' thrO"' 'h 's':":" ':..:.....'.:..:.'.:..:...:..:...,
Home mortgage interest and poinls reported to you on Form 1098
Home mortgage interest not reported toyou 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 ~
~@99
Attachment
Sequence No, 07
Your aoclalaecurtty number
5'78 : gZ :0413
-
77.5Q
LI {'21 2€
................................................................
................................................................
................................................................
11
Points not reported to you on Form 1098. See page A-3
for special rules, , . , . . . . . , . . " 12
investment Interest. Attach Form 4952 if required. (See
page A-3,) , , . , , . , . , . , , . " 13
Add iines 10 through 13, . , . , , , . . . ,
Gifts by cash or check. If you made any gift of $250 or
more, see page A-4 , , , . . . . . , . . .
Other than by cash or check, If any gift of $250 or more.
see page A-4. You MUST attach Form 8283 If over $500
Carryover from prior year .
Add lines 15 throu h 17. . , , . , . . . . .
-
725'Q 08
-
Casuaity or theft loss(es). Attach Form 4684, (See page A'5,)
Unreimbursed employee expenses-job travei, union
dues. jOb education, etc, You MUST attach Form 2106
or 2106-EZ if required, (See page A.S,) ~ .........,.....
................................................................
................................................................
Tax preparation fees , , . . . . , . , . , .
Other expenses-investment, safe deposit box, etc, List
type and amount ~.............................,........,..
................................................................
-
Add lines 20 through 22, , , . .
Enter amount from Form 1040. line 34, 24
Multiply line 24 above by 2% (,02) " .,. 25
Subtract line 25 from line 23, If line 25 is more than line 23. enter -0.
Other--from list on page A-6, List type and amount'" ..............................
...............................................................................................
ts Form 1040, line 34, over $126,600 (over $63.300 if married filing separately)?
~. No. Yourdeduclion is not limited, Add the amounts in the far right cOlumn}
for lines 4 through 27. Also, enter this amount on Form 1040. line 36. ,~
o Yes. Your deduction may be limited. See page A.6 for the amount to enter,
--.
For Paperwork Reduction Act Notice, see Form 104{) instructions.
Cat. No. 126132
'Schedule A (F~rm 104/)) 1999
Schedules MB (Form 1040) 1999
Name{s) shown on Fonn 1040. Do nol enter namo and socIal security number If snOW" on other siOe.
7a At any time during 1999, did you have an interest in or a signature or other authority over a financial
account in a foreign cau~try, such as a bank account, securities account, or other financial
account? See page 8-2 for exceptions and fiiing requirements for Form TO F 90-22.1 . . . ,
b If "Yes." enter the name of the foreign country ~ ...................................._..................
8 During 1999, did you receive a distribution from, or were you the 'grantor of, or transferor to, a
forei n trust? If "Yes," au ma have to file Form 3520, See pa e 8-2 . . . , . ,
For Paperwork Reduction Act Notlco, see Form 1040 Instructions. Schedule B (Form 1040),1999
@ Prln.'ed OIl t'KYcJed p~ 'U.S. Government Prlnlmg OHice: 1999 _ 4*063
Part I
Interest
(See page B.1
and the
instructions for
Form 1040.
line Sa.)
Note, If you
received a Form
1099.INT, Form
1099,010, or
substitute
statement from
a brokerage firm,
list the firm's
name as the
payer and enter
the total interest
shown on that
form.
Part II
Ordinary
Dividends
(See page B-1
and the
instructions for
Form 1040.
line 9,)
Note. If you
received a Form
1 099-DIV or
substitute
statement from
a brokerage firm.
list the firm's
name as the
payer and enter
the ordinary
dividends shown
on that form.
Part III
Foreign
Accounts
and Trusts
(See
page B-2,)
OMS No. 1545.0074 Page 2
Your 100181 lecurlty number
Schedule B-Interest and Ordinary Dividends
Note. If au had over $400 in taxable interest. au must 'also compiete Part '".
1 List name of payer. If any interest is from a seller-financed mortgage and the
buyer used the property as a personal residence, see page 8-1 and list this
intere~t firsJi Also, s~w /:1at ~uYe~' SO'ttl ser,rity number and address ..
..)q."J.....~.(l.'f'q.~ ,.....JM(y.!!.1}rf......M.~r.'?:!!.~L..................:
......r:1. Cfw.L .~. e.(r/...,.J:f? .!....'i\iJ!.Ql!.........,........................,
"fJ(]t~r:. h.r..., t.v.~ (JBHe.. -t ~r. V.! ,~.r;......,.."...,......,................
...., .qr.r...$, .., .'iI.V.I. flg ~li' .<1.(1"'.,.............,....":..,, .....,........... _....
.... C.h}!!. Y. .y., S;./:1.~ 5.~" ,0 Mk......,.........."..,....,...,........,............,
Allactlmenl
Sequence No 08
Amount
....................................................................................
1
............................................................................
.................................................................-.
.........................................................
.........................................................................
..................................................................................
........................................................................................--..
2 Add the amounts on line 1 . . . . . . . . . . . , . . . . ,
3 Excludabie interest on series EE and I U.S. savings bonds issued after 1989
from Form 8815, line 14. You MUST attach Form 8815 . " . . . .
4 Subtract line 3 from line 2. Enter the result here and on Form 1040. line 8a ~
Note. If you had over $400 in ordinary dividends, au must aiso complete Part III.
5 List name of payer, Include oniy ordinary dividends, If you received any capital
gain distributions, see the instructions for Form 1040, line 13 ~ ................
2
3
4
-
losS ('6
Amount
..... ..................................................................................--.
:::::::::::::..::::::"::::::::::::::::::::::::::::::::::::::::::;:;C:::::::::::::::
........................... .................................. ..........................-
5
......... .................................................................................-
..... ....................................................-................................-
6 Acid 'iti~ a';;c;~;'is 0';' iin';' 5:.E,;i,;;.iti~;oiaiii,;;E; a,;,i '~;" Fci;;n'1'6;i6: 'Ii,;~ '9":' ~ 6
You must complete this part if you (a) had over $400 of interest or ordinary dividends: (b) had a foreign
account; or (c) received a distribution from, or were a grantor of, or a transferor to. a foreign trust.
"
a Control number
,). ~,r
OMB No. 1545.000a
Copy C For EMPLOYEE'S RECORDS
(See Nolice to Emplo ee on back or Cop' B.)
1 W,~ge5, lips. other compensation 2 Federal Income lax withheld.
b Employer identification number
',' 1,:','1' ',.
c Employer's name. address. and ZIP code
I'{ ,';'1 JiI.r;.;,J' l j ij'4 ~'. i"J,' :,> ''''fit: )j.~/\'f' l "t~
fJ'~:~' l:OF~'.:'I'H;~\Nli' f,ANi':
1\':l"~:\'JI.!,i'" M;\,f{\I,:',.NP :':08"d)
I,. .,' ~.. ~ . '.' '. '. I'
....,'....1 ,'" , ,
3 Social securily wages 4 Social security Lax withheld
';(,"" ,',., .... , .;
,5 Medicare wages and Ups 6 Medicare tax withheld
." "J', ',,".' ~
7 Social security tips a Allocated lips
9 Advance Ere payment '0 Dependent care benefits
r; :~. (,
" Nonqualified plans '2 Benefits included iI' box 1
'3 See instrs. for box 13 14 Other
~ Employee's social security number
a Employee's name, address, and ZIP code
.J;:.'lI.:'; tof i Cll~[':IJ lil:O~N
:,lllJ() ::iPlt t Nt; w.n
UI:'II1-:H ~1.';'~ l,HUUO
~w
:-: i.l .,. .; ~::
15Stalulory
employee
Deceased
PenSIon
plan
legal
rep,
Deferred
compensation
"',6 Slate Employer's stale I,D. no,
..,..",l"..,.,.,.,..,.....,.".......
I
17 SIal! Wilges, lIps,elC.
18 Slale income la~ 19 locality name 20 local wages, tips, etc, 21 Loc.al income t1J):
-;'",,'
.................. ............... ..........._i':i:... ......h...<;.~:.:....
I . ~
.~
.~~,~t~.
.'~, ~ W-2
" II ".' , ~'.,I
I , I ..~ I ~ :
Department of the Treasury Internal Revenue Service
This informatIon IS being furnished 10 Ihe Internal Revenue Service. If you are
reqUIred to file a lax rei urn. a negligence penalty or other sanctIon may be
Imposed on you if thiS income is laxlIble and you fall to report n.
Wage and Tax
Statement
1999
L __ _ _ _ _ _ _ _ _ _ __ _ _ _ _ __ _ ._ _~ _ _ _. _ _... __ __ _._ __ __. _ _ __ _
:H
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'9;
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I CenUel numbcf
Copy B To Be Flied With Employoe' 5
FEDERAL Tax Return -
Wilge~. IIO!'. olher compcnS<llIon 2 Fcdor,'llncom~ lilIC WllMhJ)!
39662.54 6020.29
SOC181 SCCuflty wages . Socml 5ccurlty t<l~ wllhhelr
40404.82 2505.1~
5 MedlCilrlJ wnges and Ups 6 Medicare tax wIlhhela
40404.82 585.8:
Social <,eeuflty tipS 8 AIloc.,ted tipS
9 AcIvancp. tiC pttymenl 10 Dep(!nd~nl eMf! Mnefil<,
11 Nonquahrled plans 112 Bencfus Included In box ~
13 See Instrs for box '3 " Other
D 742.28 0080097506
L 497.25
OMB No 1545.0008
b Employer identlficalion number
52-1318895
c Employer's name, address, and liP code
NOYES AIR CONDITIONING
16761 OAKHONT AVENUE
GAITHERSBURG MD 20877
d Employee's social security number
578-82-0413
e Employee's name, address. and ZIP code
JAMES M BROWN
H'"
9100 SPRING WAY
UPPER MARLBORO HD 20772
i
1551alU1OfY
cm~oyee
DeceJsed
PenSion
If
LeQal
rep
Deferred
~pensallon
21 Local IncClml! l.ll
~
12-.3
16 Stalt Employer's stale J.D. no.
..~~, ,l~.~.~,~.~. ~.~,~, ..,." "" ,..,
20 Local wages. lip!.. el'
17 Stale wages, tlp~, el' 16 Slale Itlcomc lax I 19 locality name
"..3.9.6,~.~,:,~,~ ,..y7,29:..1l..,......"..
~W.2
Wage and Tax
Statement
Department of the Treasury-Internal Revenue Serl
ThIs Information is being lumisned to the lnlemat Revenue Ser,.,'lc
1999
~-~------------------------------------------------~------------------------------------------------
Wig", tl~, olher camp.
15244,41
5oei.laKurity w.ge1J
15244.41
2 ede,. Income tAll wrt e
2846.01
Social aeeurrty t.x withheld
945,15
Medicare tax withheld
221 ,04
Wageo. tips, other compo
15244.41
i.1 security w.g"
15244.41
Fed.r.l income tax wlthh.lc:
2846.01
Soci.1 HCurlty tax wlthh.lc:
945.15
Medlc:ue lax withheld
221.0
3
5
15
.. Control Number
000064 2PF
Employ., uu ontv
A 26
e Employer'. n.rne, .ddrns. .nd ZIP eocIe
COMBUSTIONEER CORP.
2345 CRYSTAL DRIVE
ARLINGTON VA 22202-1367
b EmPISl!f'. FED 10 number d EmplOrt~'a SSA number b
2-1690175 78.82-0413
7 Socill aecurrty lips " Allocated tJpa 7
I
dv.nc. p'yment 10 Dependent cue benefitll I' Adv.nce Ele poIym.nl
11 onqu. , p.nli "
13 5" inlltra.lor box '3 "
leg.I~Jl.
I O!lerraicom)l.
IOelemdcorr
JAMES M BROWN
9100 SPRING WAY
UPPER MARLBORO,MD 20772
JAMES M B OWN
9100 SPRI WAY
UPPER M LBORO MD 20772
16 Sllle Employer'l atllelO no. 17 Sllte Wig", tipS, e1c.
MD 0555966 8 15244.41
111 Stlteineomet... 19 LocIUtynlme
1048,45
20 Locll Wig", ttpa, lie. 21 Locll Income !..Ix
17
19
20l
21
MD.Slalo Roloronco c~y
- 2 Wago and Tax 1 ~99
Statement loll! No lr.d-OOOI
Q@
... 88
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;::)iJi:
IIltOWN
REGULIIR
VACATION
SICK
TOTAl HOURS
] 01l8. 4.0
: OVERTIME . '':::'HoUDAY
SPECIAL
40.00
,40.00
..,'...
"~"~--"''''r^X[C;2\ViiMHO'il~(~''~''.''':-, ~:,' ,
FICA STATE Whi TAX GO~N!ON....~~ '~'.i: ''';~~',:''i:~''':;~'''~.-''''"
"D'RAL~~ T~.6,~". ,.~.~:E,"ST.,T^" '~;:,; ;1~~;~'!~~~'~~~~ ...:~;:" .~:'-~':.~: :,/; :, ,;,;
169. ~ I, ..:d"., " ._.....,"._""....~'k.....,""">~.~.'-h'.,'~'_., foll,f' ~()/1 <
~..,':OTYw,.,.,.T..Qr..7":......~"!..,.:~'.:;!-!OONISH..~"" .........~.M".._....... 'u. "--. '. __~ r~
'.' " ',,.,.. .. ';;J~' ,.._...,.~-~"".,.~;;'~~1(~~~1:~,j " '''''''''~'"~"",,
.:-:::-:~~~~'~~~:7.~.r:~:;~~ "t'~,.'?' ~ .... l. _ ....". _._ :'.k. ~*~:~~~;~:,;...:.~ ;:....:-~:.';....,~
CROSS PAY
] Ollll. 40
TOTAL TAXES W/H
J....,"".
.........~......,
?b?.b3
TO!^1.0TH.ERT~ ~.
" 1!t\\j'lImlD.'
. .J,':~t~l~~'~!
. ~ ..,;... ....~,'._...
TOTAL VO~ ~~g.~.
?'69.66--'.,
NE'TrAY
".': ,.,::~:.#;.)~!
. -- - - - - - - - - -- - - - -... - - - - - - - - ~ - -
.~-----
.'
- -... -.- -- -.
-.-.--. -'-
. NOYES AIR CONDITIONING CONTRACTORS, INC.
--.-----
· ,MPLOYEE HOURS
NUMBER
IlEGU~R OVERTIME HOLIDAY SPECIAL REGULAR V~CATIO" SICK
00131 40.00 30.00 1068.40
SCCiAL SECURITY NUMBER VACATION SICK TOTAL HOURS OVERTIME HOLIDAY :;PECIAL
578-82-0413 70.00 1202.10
CHECK DATE 08/23/99
CHECK NO,131O&S 4 2 5
EARNINGS
SHIFT WO
160.40
TAXES
GROSS PAY
2430.ge
FICA
STATE WITH CITY'IITTH SAv.aCND lOAN SICK PAY
110.88 5.00
smE 'OTALUXES SA', ,,=, 401-K GARNISHH
MO 824 . 78 48 . 62 269 . 66
'-------.--.-..-..
DEDUCTIONS
".---.-....--..--.
185.97
TOTAL DEOUCTlCN~
I=ECERAL.....ITH.
527.93
323.2E
TOTAL DEOUCTED ~A;(::
824.7E
GROSS
40404.82
FICA
YEAR TO DATE
FEO. WITH. TAX
ST~TE WITH.TAX
STATE TAX
PAY PERIOD
NET PAY
3091.08
6020.29
1729.19
CITY WITH. TAX
MO
08/22/99
1282.,84
401K
742.28
00
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JAMES D, FLOWER
jOI'IN E, SLlKE
ROBERT C. SAIDIS
GEOFFREY S. SHUFF
JAMES D, FLOWER, jR,
CAROLj. LINDSAY
jOHNNA j, KOPECKY
KARL M, LEDEBOHM
JOSEPH L. HITCHINGS
THOMAS E, FLOWER
LA IV OFFICES
SAIDIS, SHUFF, FLOWER & LINDSAY
A PROFESSIONAL CORPORATION
26 WEST HIGH STREET
CAI{L1SLE, PENNSYLVANIA 17013
TELEPHONE: (717) 243-6222. FACSIMILE: (717) 243-6486
EtvtAIL: ultorney@ssfl.law.col11
www.ssfl.)nw.rol11
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WESr SHORE OFFICE:
2109 MARKET STREET
CAMP HILL, PAI7011
TELEPHONE: (717)737-3405
FACSIMILE, (717)737-3407
REPLY TO CARLISLE
April 9, 2001
E. Robert Elicker, II, Esquire
9 North Hanover Street
Carlisle, PA 17013
RE: Brown v. Brown
No. 99-0964 Civil Term
Dear Mr, Elicker:
This letter is in response to Barbara Sumple-Sullivan's letter of April 4, 2001.
The Brown marriage lasted two years. We respectfully suggest that an increase in
value of pre-marital real estate owned by Mr. Brown and his pension is diminimus and
does not justify the cost of an appraisal. If Ms. Sumple-Sullivan believes it is, let her
petition the Court. Mrs. Brown does not, preferring to collect $1,000.00 per month
instead. If we move this matter to a hearing, these evidentiary matters will be resolved
one way or another. As Barbara was candid enough to admit at our pre-hearing
conference before Judge Oler, the marital estate here is $7,000.00, approximately. I
ask you to set a hearing date.
Very truly yours,
SAIDIS~SHUF~' F WER & LINDSAY
Y /
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Carol J. 'a
CJUljb
cc: James M, Brown (w/enci)
Barbara Sumple-Sullivan, Esquire
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LAW OI'l'I"HS
BAHBARA SUMPLE-SULLIVAN
~,,,u BRIDGE snmET
NEW CmIllElll.ASIl. PHNSSYLVASIA 17070-1901
PII()~E (717) 77-1.-144:'1
FAX (717) 7H..70:'lO
October 4, 2000
E. Robert Elicker, II, Esquire
Divorce Master
9 North Hanover Street
Carlisle, P A 17013
Re: James M. Brown v. Susan D. Brown
lSD~..2.:9..MLCllmb.erland~C.o_lUlt~
Dear Divorce Master Elicker:
Enclosed for filing is my response to your Certification concerning discovery.
/
Barbara Sumple-Sullivan
BSS/ld
Enclosure
cc: Carol J. Lindsay, Esquire (w/enclosure)
Susan D. Brown (w/enc1osure)
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LAW OI'FIGBS
BARBARA SUMPLE-SULLIVAN
"40 DRIDc;E STREET
NEW CUHDERJ.A.,(D, PENNSYL\'A.'(IA '7070-1031
PHONE (717) 774.144G
FA.'.: (717) 77.l.70G(l
January 30, 200 I
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Hand Delivery
Prothonotary's Office
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
Re: Brown v. Brown
llI!.c.kc..tNo.....2.2.::.2MLCumb.e.rlaruLCJrnn.t;
Dear Sir/Madam:
Enclosed please find an original and one (I) copy of Response of Defendant to Rule to Show
Cause for Special Relief to Compel Discovery.
Thank you for your assistance.
Barbara Sumple-Sullivan
BSSlld
Enclosures
ee:
The Honorable J. Wesley Oler, Jr. (w/enel)/
Carol 1. Lindsay, Esquire (w/enel)
Ms. Susan Dapp Brown (w/enel)
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LAW OFFICES
THIS IS A TRUE CORRECT COPY
OF THE ORIGINAL
-#;
BARBARA SUMPLE-SULLIVAN
549 BRIDGE STREET
NEW CUMBERLAND. PENNSYLVANIA 17070.1931
PHONE (717)774.1445 .<
FAX (717)774.7099
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tcmporary job for the week ending Dccember 6, 1998, It is asscncd that said conditions arose bcfore
the parties' separation, It is funher aven'ed that the physical and mental hcalth situation of the
Respondent became further exasperated when Petitioner assailed Respondent in a shopping mall
parking lot after the panies' separation,
5, Admitted in part. Denied in part. It is admitted that Petitioner has sought copies of
the Respondent's psychological and psychiatric records, It is averred that said request was in the
fonn of a general, open ended release which would empower counsel for Petitioner access to every
confidential record between Respondent and her treating Psychiatrist and Psychologist. It is
admitted that said broad and general request was rejected, It is admitted that the copy of the letter
of November 14,2000 is a true and correct copy of the response to counsel for Petitioner. It is
denied that Respondent will prohibit any and all types of discovery by the Petitioner. Respondent
would have no problem in allowing Petitioner to depose the treating physicians of the Respondent
wherein relevant issues as to her current psychological position can be placed of record. Respondent
has provided periodic updates to Petitioner's counsel and Domestic Relations Office concerning her
inability to work,
6. Denied, It is denied that full disclosure of every medical record of Respondent is
necessary for Petitioner to prepare for his case.
7. Denied. Paragraph 7 is denied as a conclusion of law to which no responsive
pleading is due, It is averred that Respondent objects to the breadth of the requests by the Petitioner
as the Petitioner's attempts to reasonably deduce her current psychiatric conditions,
-2-
Barbara Sumple.Sulli\'an. Esquire
Supreme Coun #32317
~49 Bridge Street
Ne\\' Cumberland. PA 17070
(717) 774-1445
Counsel for Defendant
JAMES M. BROWN,
Plaintiff
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 99-964 Civil Tem1
SUSAN DAPP BROWN,
Defendant
: Divorce
CERTIFICATE OF SERVlCE
I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true
and correct copy of the RESPONSE OF DEFENDANT TO RULE TO SHOW CAUSE FOR
SPECIAL RELIEF TO COMPEL DISCOVERY, in the above-captioned matter upon the
following individual, by United States first-class mail, postage prepaid, addressed as follows:
Carol 1. Lindsay, Esquire
Saidis, Shuff, Flower & Lindsay
26 West High Street
Carlisle, P A 17013-2956
DATE: January 30, 2001
/
~b'" '.m,l,-,.l""'. ",q.ire
549 Bridge Street
New Cumberland, P A 17070-1931
(717) 774-1445
Supreme Court J.D. 323 I 7
Attorney for Defendant
,
..
JAMES M. BROWN,
Plaintiff
I,
, ,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LA W
SUSAN DAPP BROWN,
Defendant
NO. 99-0964 CIVIL TERM
ORDER OF COURT
AND NOW, this 5'h day of February, 2001, upon consideration of Plaintiffs
Motion To Compel Discovery and of Defendant's Response to Rule To Show Cause for
Special Relief To Compel Discovery, a discovery conference is scheduled in chambers of
the undersigned judge for Monday, March 19, 200 I, at 9:00 a.m., in Courtroom No. I,
Cumberland County Courthouse, Carlisle, Pennsylvania.
BY THE COURT,
Carol .I. Lindsay, Esq.
26 West High Street
Carlisle, PAl 70 I 3
Attorney for Plaintiff
0,1
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Barbara Sumple-SuIlivan, Esq.
549 Bridge Street
New Cumberland, PAl 7070
Attorney for Defendant
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tcmporary job lor thc wcck cnding Dcccmbcr 6, 1998. It is asscrtcd tlmt said conditions arosc bcforc
thc parties' separation. It is furthcr averred that thc physical allllmcntal hcalth situation of thc
Rcspondent bccame furthcr cxaspcrated whcnPctilioncr assailed Rcspondcnt in a shopping mall
parking lot aftcr the partics' scparation.
5. Admittcd in part. Dcnicd in part. It is admittcd that Pctitioncr has sought copics of
thc Rcspondcnt's psychological and psychiatric rccords. It is avcrrcd that said rcqucst was in thc
form ora gcncral, opcn cndcd relcasc which would cmpowcr counsel for Pctitioncr acccss to cvcry
confidcntial rccord bctwccn Rcspondcnt and hcr trcating Psychiatrist and Psychologist. It is
admittcd that said broad and gcncral rcquest was rcjcctcd. It is admittcd that thc copy ofthc Icttcr
of Novembcr 14,2000 is a truc and correct copy of thc rcsponsc to counscl for Petitioncr. It is
denied that Respondcnt will prohibit any and all types of discovcry by thc Pctitioncr. Respondent
would havc no problem in allowing Petitioncr to deposc thc treating physicians of the Respondent
whcrein relcvant issucs as to her current psychological position can bc placcd of rccord. Rcspondcnt
has provided pcriodic updatcs to Petitioner's counscl and Domestic Relations Officc conceming her
inability to work.
6. Denicd. It is dcnicd that full disclosurc of evcry medical rccord of Respondent is
necessary for Petitioncr to prcparc for his casc.
7. Dcnied. Paragraph 7 is dcnicd as a conelusion of law to which no rcsponsivc
plcading is duc. It is avcrrcd that Rcspondcnt objccts to the brcadth of the requcsts by thc Pctitioner
as thc Pctitioncr's attcmpts to rcasonably dcducc hcr currcnt psychiatric conditions.
-2-
Brown Production of documonts
tjb
January B, 2001
JAMES M. BROWN,
Plaintiff/Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V5.
: CIVIL TERM - LAW
: NO. 99 - 964 CIVIL TERM
SUSAN DAPP BROWN,
Defendant/Respondent
: DIVORCE
CERTIFICATE OF SERVICE
AND now, this
;;
day of
2001, I, Carol J, Lindsay, Esquire, of the law fir
LINDSAY, P,C., Attorneys, hereby certify that I served the within Petition to Compel
Discovery this day by depositing sarne in the United States Mail, First Class, Postage
Prepaid, in Carlisle, Pennsylvania, addressed to:
Barbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070-1931
SAIDIS, SHUFF, FLOWER & LINDSAY, P.C.
Attorneys for Plaintiff
squire
SAlOIS,
SHUFF &
MAS LAND
ATI'ORNEYS'AT'l.AW
26 W. High Street
Carli,le. PA
- '
V chicles.
The parties' vehicles arc non-marital.
Accounts.
Harris Savings Bank Joint Checking Account No. 50042738
Plaintiff received monies.
5,064.48
Harris Savings Bank Joint Savings Account No. 560010148
Plaintiff received these monies.
19,165.61
NCFCU Account No. 065925: Defendant's premarital account
Balance as of 12/31/98 $70.03
Balance as of 6/30/96 64.73
Increase in value during marriage
Minimal
Andrews FCU Account No. 578820413: Per Plaintiff's Answer to
Interrogatory No. 12, this account was jointly owned with Defendant.
Savings Account:
Checking Account:
581.07
1,232.72
Andrews FCU Account No. 22050363
Savings Account
Checking Account
Plaintiff has not provided the requested statements. These values have to
be confirmed.
1,232.72
580.41
Estimated earnings on marital proceeds from all marital accounts since DOS
$27,875.01 @ 5% per annum = $116.07 per month @ 28 months
3,249.96
Plaintiff's Retirement Benefits
The increase in value must be determined, Plaintiff vested in 1996.
to be determined
John Hancock Life Insurance - Plaintiff
Increase in value
873.51
In summary the marital estate is as follows:
Increase in value of real estate (estimated 6%)
Joint Harris Savings Account
Joint Harris Checking Account
Increase in Defendant's pre- marital NCFCU Account No. 065925
Increase in Plaintiff's Andrews FCU Account No. 578820413
Joint Andrews FCU Account No. 578820413
Savings Account:
Checking Account:
$8,220.00
19,165.61
5,064.48
Minimal
None
581.07
1,232.72
-3-
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N. Documentation of cost of non-reimbursed medical cxpenses will be provided prior
(0 trial.
Information requested from Plaintiff to be used as exhibits by Defendant:
A. Copy of current pay stub:
B. Copy of 2000 federal and state tax return including all schedules and W-2s;
C. Documentation of the COBRA cost;
D. Date of separation statements for Andrews FCU account no. 22050363.
Wife reserves the right to identify additional exhibits upon receipt of Husband's exhibit list
and pending Husband's complete response to Wife's Interrogatories and request for Production of
Documents.
VI. INCOME INFORMATION
Defendant is disabled and unable to work. She relics upon the support paid by Plaintiff in
the amount of $1,300.00 per month pursuant to the Order dated May 22. 2000. On April 16,2001,
the Social Security Administration determined that Defendant was disabled and awarded Defendant
the sum of $644.00 per month in disability benefits, A copy of said Order and Social Security
Notice are included above as exhibits.
Plaintiff's current income infonnation is requested as well as a copy of his 2000 Tax Return
with all attachments.
VII. EXPENSEJNFORMATION
See attached Income and Expense Statement marked as Exhibit "B" which was filed in the
parties' related support action. An updated Statement will be provided prior to trial so as to include
Defendant's ever increasing unreimbursed medical expenses and other treatments required for her
present condition. Defendant is in the process of determining what will be covered by Medicare and
by the present insurance coverage.
Defendant requests that Plaintiff provide the cost for COBRA coverage so this too can be
included in Defendant's Expenses.
VIII. PENSION VALUE
The marital portion of Plaintiff's pension has yet to be determined. Defendant is financially
unable to obtain same. Plaintiff is in a far superior financial situation in that he carns in excess of
$60,000 per year. In the event that the marital portion is not valued, Defendant requests this
Honorable Court 10 equitably divided the marital portion and award Defendant 60% of the increase
of this asset.
-5-
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'Social S~curityddministration ) .,
Retirement, Survivors and Disability' Insurance
Notice of Award
Office of Central Operations
1500 Woodlawn Drive
Baltimore, Maryland 21241-1500
Date: April 16, 2001
Claim Number: 179-44-8913HA
SUSAN D BROWN
16 COLUMBIA DR
CAMP HILL, PA 17011-7635
1",111..,111"""11,.,111.,.1,11",,11,.1.1,,,.11.11..,,1,11
You are entitled to monthly disability benefits beginning November 1999.
The Date You Became Disabled
We found that you became disabled under our rules on December 15, 1998.
Our records show that you became disabled on December 15, 1998. By law, we
can pay benefits no earlier than 12 months before the month of filing. Since you
fIled for benefits on November 14, 2000, monthly payments will begin
November 1999.
What We Will Pay And When
. You will receive $10,648.00 around April 22, 2001.
. This is the money you are due for November 1999 through March 2001.
. Your next payment of $644.00, which is for April 2001, will be received on
or about the second Wednesday of May 2001.
. After that you will receive $644.00 on or about the second Wednesday of
each month.
. These and any future payments will go to the financial institution you
,selected. Please let us know if you change your mailing address, so we can
send you letters directly.
The day we make payments on this record is based on your date of birth.
Enclosure(s):
Pub 05-10153
C
See Next Page
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179.44-8913HA
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Your Benefits
The following chart shows your benefit amount(s) before any deductions or
rounding. The amount you actually receive(s) may differ from your full beo.efit
amount. When we figure how much to pay you, we must deduct certain
amounts, such as Medicare premiums. We must also round down to the nearest
dollar.
Beginning
Date
Benefit
Amount
Reason
November
December
December
1999
1999
2000
$608.10
$622.60
$644.30
Entitlement began
Cost-of-living adjustment
Cost-of-living adjustment
Other Social Security Benefits
The benefit described in this letter is the only one you can receive from Social
Security. If you think that you might qualify for another kind of Social Security
benefit in the future, you will have to me another application.
Your Responsibilities
The decisions we made on your claim are based on information you gave us. If
this information changes, it could affect your benefits. For this reason, it is
important that you report changes to us right away.
We have enclosed a pamphlet, "When You Get Social Security Disability
Benefits...What You Need To Know." It will tell you what must be reported and
how to report. Please be sure to read the parts of the pamphlet which explain
what to do if you go to work or if your health improves.
A state or other public or private vocational rehabilitation provider may contact
you to talk about their services. The rehabilitation provider may offer you
counseling, training, and other services that may help you go to work. To keep
getting disability benefits, you have to accept the services offered unless we
decide you have a good reason for not accepting.
You do not have to wait to be contacted about vocational rehabilitation services.
You can contact the nearest state vocational rehabilitation office directly and let
them know that you are interested in receiving services.
179-44-8913HA
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Page 3 of 5
If you go to work, special rules can allow us to continue your cash payments and
health insurance coverage. For more information about how work and earnings
may affect disability benefits, you may call or visit any Social Security office.
You may wish to ask for any of the following publications: .
· Social Security - Working While Disabled...How We Can Help (SSA
Publication No. 05-10095).
· Social Security. If You Are BIind--How We Can Help (SaA Publication
No. 05-10052).
· How Social Security Can Help With Vocational Rehabilitation (SSA
Publication No. 05-10050).
If You Disagree With The Decisions
If you disagree with the decisions, you have the right to appeal. A person who
did not make the first decision will decide your case. We will review those parts
of the decisions you disagree with and will look at any new facts you have. We
may also review those parts of the case that you believe are correct and may
make them unfavorable or less favorable to you.
About The Appeals
If you disagree with the nonmedical decisions we made on your case, the appeal
is .called a reconsideration. Some examples of nonmedical decisions are the
amount of your payment, and the month your payment starts. You will not meet
with the person who decides your case. .
If you disagree with the disability (medical) decision made by the state, the
appeal is called a hearing. Some examples of medical decisions are the date your
disability started or whether you are still disabled.
If You Want To Appeal
.. You have 60 days to ask for an appeal.
· The 60 days start the day after you receive this letter. We assume you got
this letter 5 days after the date on it unless you show us that you did not
' get it within the 5-day period.
· You must have a good reason if you wait more than 60 days to ask for an
appeal.
· You have to ask for an appeal in writing. We will ask you to sign- a form
SSA-561-U2, called "Request for Reconsideration," or a form HA-501,
called "Request for Hearing." Contact one of our offices if you want help.
If You Ask For A Reconsideration And A Hearing
If you ask for both a reconsideration and a hearing, we will process the hearing
first, even if you made the reconsideration request first. When we make our
decisions, we will send you letters explaining our decisions on both the
reconsideration and the hearing.
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179-44-8913HA
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How The Hearing Process Works
After we send your case for a hearing, an Administrative Law Judge (AW) will
mail you a letter at least 20 days before the hearing to tell you its date, tirp.e and
place. The letter will explain the law in your case and tell you what has to be
decided. Since the AW will review all the facts in your case, it is important that
you give us any new facts as soon as you can.
The hearing is your chance to tell the ALJ why you disagree with the decisions in
your case. You can give the AW new evidence and bring people to testify for
you. The ALJ also can require people to bring important papers to your hearing
and give facts about your case. You can question these people at your hearing.
It Is Important To Go To The Hearing
It is very important that you go to the hearing. If for any reason you can't go,
contact the ALJ as soon as possible before the hearing and explain why. The
AW will reschedule the hearing if you have a good reason.
If you don't go to the hearing and don't have a good reason for not going, the
AW may dismiss your request for a hearing.
Things To Remember For The Future
Because we expect your health to improve, we will review your case in
March 2002. We will send you a letter before we start the review. Based on
that review, your benefits will continue if you are still disabled, but will end if
you are no longer disabled.
IT You Have Any Questions
We invite you to visit our website at www.ssa.gov on the Internet to fmd general
information about Social Security. If you have any specific questions, you may
call us toll-free at 1-800-772-1213, or call your local Social Security office at
1-717-782-3400. We can answer most questions over the phone. If you are deaf
or hard of hearing, you may call our TTY number, 1-800-325-0778. You can also
write or visit any Social Security office, The office that serves your area is
located at:
SOCIAL SECURITY
555 WALNUT STREET
HARRISBURG, PA 17101
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SUSAN D. BROWN,
Plaintiff
V.
TN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DOMESTIC RELATIONS SECTION
CIVIL ACTION - SUPPORT
JAMES M. BROWN,
Defendant NO. 80 SUPPORT 1999 (DR 28,304)
ORDER OF COURT
AND NOW, this 22nd day of May, 2000, the parties
having reached an agreement on this appeal by wife from a
support order entered following a Domestic Relations
conference, IT IS ORDERED that the support shall remain in the
amount of $1,300.00 a month effective November 17, 1999, with
husband to provide wife medical insurance and pay 75 percent of
all nonreimbursed medical expenses. 'This medical reimbursement
shall include treatment for any mental health services.
By the Court,
"
Michael R. Rundle, Esquire
Special Counsel for D.R.O.
Barbara Sumple-Sullivan, Esquire
For Plaintiff
Carol J. Lindsay, Esquire
For Defendant
Sheriff
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SUSAN DAPP BROWN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
vs.
: CUMBERLAND COUNTY, PENNSYL VANIA
: NO. 99- 759;;- CIVIL TERM
JAMES MICHAEL BROWN,
Defendant
: PROTECTION FROM ABUSE
NOTICE OF HEARING A1~D ORDER
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed
against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In
particular, you may be eviCted from your residence and lose other important rights.
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A hearing on this matter is scheduled on the ~ day of December, 1999, at /.' ~ f .m.,
in Courtroom No. ~ of the Cumberland County Courthouse, Carlisle, Pennsylvania
You MUST obey the Order that is attached until it is modified or terminated by the court after
notice and hearing. If you disobey this Order, the police may arrest you. Violation of this order may
subject you to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or
up to six months in jail under 23 Pa.C.S, 96114. Violation may also subject you to prosecution and criminal
penalties under the Pennsylvania Crimes Code. Under federal law,' 18 U.S.C. 92265, this Order is
enforceable anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto
Rico. If you travel outside of the state and intentionally violate this Order, you may be subject to federal
criminal proceedings under the Violence Against Women Act, 18 U.S.C. 92261-2262.
Yon should take this paper to your lawyer at once. You have the right to have a lawyer represent
you at the hearing. The court will not, however, appoint a lawyer for 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 can get legal help. If
you cannot find a lawyer, you may have to proceed without one.
CUMBERLAND COUNlY BAR ASSOCIA nON
2 Liberty Avenue, Carlisle, Pennsylvania 17013
Telephone Number: (717)249-3166
AiVIERICANS 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 availabJe 10 qis~ph:d individuals having business before the court, please contact our office.
All arrangements must be 1I1~~e ~t le~st 72 AI'4rs ~rior to any hearing or business before the court. You must
attend the scheduled conference or hearing.
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Defendant is enjoined from damaging or destroying any property owned jointly
by the parties or owned solely by Plaintiff. .
Defendant is to refrain from harassing Plaintiff's relatives.
(8) 8. A certified copy of this Order shall be provided to the police department where
. Plaintiff resides and any other agency specified hereafter:
Lower AIlen Township Police Department
(8) 9.
TillS ORDER SUPERSEDES ANY PRIOR PFA ORDER
o ANY PRIOR ORDER RELATING TO CHlLD CUSTODY
10. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL MODIFIED OR TERMINATED BY THIS COURT AFTER
NOTICE AND BEARING.
NOTICE TO DEFENDANT
Defendant is hereby notified that violation of this Order may result in arrest for indirect
crimina! contempt, which is punishable by a fine of up to $1,000.00 and/or up to six months injail.
23 Pa.C.S. 96 114. Consent of the Plaintiff to Defendant's return to the residence shall not invalidate
this Order, which can only be changed or modified through the filing of appropriate court papers for
that purpose. 23 Pa.C.S. 96113. Defendant is further notified that violation of this Order may
subject himlher to state charges and penalties under the Pennsylvania Crimes Code and to federal
charges and penalties under the Violence Against Women Act, 18 U.S.C. 99 2261-2262. Any
protection order granted by a court may be considered in any subsequent proceedings, including child
custody proceedings, under title 23 (Domestic Relations) of the Pennsylvania Consolidated Statutes.
NOTICE TO LAW ENFORCEMENT OFFICIALS
This Order shall be enforced by the police who have jurisdiction over the plaintiff's residence
OR any locations where a violation of this order occurs OR where Defendant may be located. If
Defendant violates Paragraphs 1 through 6 of this Order, Defendant may be arrested on the charge
of Indirect Criminal Contempt. An arrest for violation of this Order may be made without warrant,
based solely on probable cause, whether or not the violation is committed in the presence of law
enforcement.
Subsequent to an arrest, the law enforcement officer shall seize all weapons used or
threatened to be used during the violation of this Order OR during prior incidents of abuse.
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Weapons must forthwith be delivered to the Sheriff's office of the county which issued this O~der,
which office shall maintain possession of the weapons until further Order of this Court, unless the
weapon/s are evidence of a crime, in which case, they shall remain with the law enforcement agency
whose officer made the arrest.
BY THE COURT,
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Joan Carey
Maryann Murphy
Attorneys for Plaintiff
LEGAL SERVICES, me.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
TRUE copy FROM RECORD
In Tes1jmooy 'l'ihersol, \ Mra unto sst rrT'{ ~
. and the sool 01 said Gourt at C31i1~, fa.
Thl~ ~/A/- I,,~J_ a~:;j,~ ;~:
.. q Prothonotary
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Lower Allen Township Police have filed charges against Defendant for
terroristic threats as a result of the incident listed in paragraph 8, which oCcUred
on or about December II, 1999, involving Plaintiff. .
Defendant was convicted of simple assault in Maryland in or about 1993, for an
incident involving a dispute with a neighbor lady.
8. The facts of the most recent incident of abuse are as follows:
Approximate Date:
Place:
December II, 1999
Capital City Mall parking lot, Camp Hill, Cumberland
County, Pennsylvania
On or about December I I, 1999, Plaintifi; who was at the Capital City
M<ilI, was startled when she thought she saw Defendant, her estranged husband,
who lives in Maryland, and has no family, mends, or business that would bring
him to this area. When Plaintiff saw Defendant in a nearby sto're, he tried to
hide to avoid her seeing him. Fearing for her safety, Plaintiff telephoned her
mother from the Mall to advise her of Defendant' s presence and to tell her that
she was on her way home. Plaintiff left the Mall immediately, got into her car,
and as she locked the door, saw Defendant standing at the driver's side door.
Defendant yelled at Plaintiff saying, "Do you like spending other people's
money?", and as he got angrier, his face reddened, and he threatened Plaintiff
saying, "Do you remember my note that said, 'Do you want to die?' " (referring
to the October 15, 1999, incident below). When Plaintiff said to Defendant,
"Jim, you won't kill me.", he responded, "1 will kill you." Defendant proceeded
to unlock Plaintiff's car door with a key that she was unaware he had, opened the
door, stood in front of her preventing her from getting away from him, and
yelled, "So, you don't think I'll kill you?" When Plaintiff answered that she did
not think he would do such a thing, he screamed repeatedly, "I'll kill you. I'm
going to kill you." A man and woman who were nearby in the parking lot and
alarmed by Defendant's behavior, called to Plaintiff; and asked if she needed
help. When Plaintiff pleaded for them to call the police, Defendant ran back into
the Mall. The Lower Allen Township Police responded and searched for
Defendant, but were unable to locate him.
Defendant has become increasingly aggressive in his threats of violence
and alarming in his behavior toward Plaintiff since the parties' October 15,
1999, suppport hearing. The parties' up-coming support hearing scheduled
before Judge Bayley on Tuesday, December 21, 1999, has further exacerbated
Plaintiff's fear for her life.
9. Defendant has committed the following prior acts of abuse against Plaintiff:
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a) On or about October IS, 1999, after the parties' hearing on support
before Judge Bayley was over and the Judge had left the courtroom, Defendant
yelled at Plaintiffca1ling her white trash, in the presence of the parties' counse~
and Cumberland County Sheriff's deputies. When Plaintiff left the Courthouse
and went to her car, she found a note written by Defendant that said, "White
Trash" on one side, and on the other side, a threat saying, "Do you want to die?"
(See attached Exhibit A, incorporated hereto by reference). plaintiff
immediately advised her attorney of the note, and her attorney sent a letter to
counsel for Defendant regarding the same (see attached Exhibit B, incorporated
hereto by reference).
b) On or about January 15, 1999, Defendant threatened Plaintiff saying, "I
could become very, very violent right now,"
c)" On or about November 1, 1998, Defendant became angry, left the room,
and fearing for her safety, Plaintiff locked herself in the bedroom. Defendant
threatened to "bust" the door if Plaintiff did not open it. Plaintiff did not open
the door to Defendant. When she thought Defendant had left, Plaintiff left the
bedroom, and as she walked past the kitchen, he grabbed her by the wrist,
twisted her arm up behind her back and held her tightly by the wrist in that
position. Plaintiff sustained bruising and soreness about her wrist as a result of
this incident.
d) In or about late' summer 1998, Defendant forced Plaintiff to engage in
sexual relations with him despite her crying and her pleas for him to stop. After
Defendant got up from the bed, he said to Plaintifi; "Well, 1 got what 1 wanted."
When Plaintiff told Defendant that he had raped her, he threatened her saying,
"1 can do anything to you 1 want; you're my wife."
e) In or about 1994, Defendant screamed at Plaintiff repeatedly telling her
to get out, walked around the bed to where she stood, continued to yell at her,
causing her to bend backward over the bed until she got away from him.
Plaintiff left the bedroom, and as she stood at the top of the stairs, Defendant
shoved her down the staircase of approximately I 5 stairs. Plaintiff fell all the
way down the stairs to the ground floor, and as she lay on the floor, Defendant
made several attempts to pick her up and throw her out the door, and stopped
only when she pleaded that her ankle was injured. Plaintiff sustained swelling
about her head, and bruising and soreness about her head, shoulders, back, arms,
buttocks, and legs as a result of this incident.
f) In or about summer 1994, Defendant grabbed Plaintiff by the arms.
Plaintiff sustained bruising on both her arms as a result of this incident.
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o 9. Defendant is directed to pay temporary support for _ as follows: _' This Order for
support shall remain in effect until a final support order is entered by this Court, However; this
Order shall lapse automatically if Plaintiff does not file a complaint for support with the Court within
fifteen (15) days of the date of this Order. The amount of this temporary order does not necessarily
reflect Defendant's correct support obligation, which shall be detennined in accordance with the
guidelines at the support hearing. Any adjustments in the final amount of support shall be credited,
retroactive to this date, to the appropriate party.
dOlo. The costs of this action are waived as to Plaintiff and imposed on Defendant.
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( ~ 11. Defendanhh~ $125.00 to Plain.!!.[.as-eotilpensation for Plaintiff's out-of-
/~ losses, which are as follows:liaJ st:01having the locks on her vehicle re-keyed.
.1 The total amount of losses shall b mbursed to Plainti w ~O days of the entry of this
. Order. Payment shall b ile to Plaintiff in the form of a check or money order made
payable to Plaintiff ma:i ed to her residence.
o Plaintiff is granted leave to present a petition, with appropriate notice to Defendant, to
requesting recovery of out-of-pocket losses. The petition shall include an exhibit itemizing
all claimed out-of-pocket losses, copies of all bills and estimates of repair, and an Order scheduling
a hearing. No fee shall be required by the Prothonotary's office for the filing of this petition.
o 12. BRADY INDICATOR
o 1. The Plaintiff or protected person/s is a spouse, former spouse, a person who
cohabitates or has cohabited with Defendant, a parent of a conunon child, a child of that
person, or a child of Defendant.
o 2. This Order is being entered after a hearing of which Defendant received actual
notice and had an opportunity to be heard.
o 3. Paragraph I of this Order has been checked to restrain Defendant from
harassing, stalking, or threatening Plaintiff or protected person/so
o 4. Defendant represents a credible threat to the physical safety of Plaintiff or
other protected person/s OR
o The terms of this Order prohibit Defendant from using, attempting to use, or
threatening to use physical force against Plaintiff or protected person that would reasonablyebe e~pected to cause bodily injury.
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D On _ at _,m" Defendant may enter the residence to retrieve his/her clothing and
other personal effects, provided that Defendant is in the company of a law enforcement
officer when '5'Uch retrieval is made,
(8) 3. Defendant is prohibited from having Ai'lY CONTACT with Plaintiff at any
location, including, but not limited to, any contact at Plaintiff's current residence, and any
other residence she may, in the future, establish for herself, her school, business, and/or place
of employment. Defendant is specifically ordered to stay away from the following locations
for the duration of this Order:
Plaintiff's residence: 16 Columbia Drive, Camp Hill, Cumberland County,
Pennsylvania
(8) 4. Defendant shall not contact the Plaintiff by telephone or by any other means,
including third parties.
o
5.
Custody of the minor children, , shall be as follows: (or see attached Custody Order)
o 6. Defendant shall immediately turn over to the Sheriffs Office, or to a local law
enforcement agency for delivery to the Sheriffs Office, the following firearms and/or specific
weapons:
o 7. Defendant is prohibited from possessing, transferring or acquiring any other firearms
and/or specific weapons for the duration of this Order. Any firearms and/or weapons delivered to
the sheriff under Paragraph 6 of this Order or under Paragraph 6 of the Temporary Order shall not
be returned until further Order of Court,
(8) 8.
The following additional relief is granted as authorized by ~6108 of this Act:
This Order shall remain in effect until modified or terminated by the Court and
can be extended beyond its original expiration date if the Court finds that
Defendant has committed an act of abuse or has engaged in a pattern or
practice that indicates risk of harm to Plaintiff.
Defendant is prohibited from possessing any firearms and/or weapons in the
Slate of Pennsylvania.
Defendant is enjoined from damaging or destroying any property owned jointly
by the parties or owned solely by Plaintiff.
Defendant is to refrain from harassing Plaintiff's relatives.
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(8) 13. THIS ORDER SUPERCEDES ANY PRIOR PFA ORDER.
o ANY PRIOR ORDER RELATING TO CHILD CUSTODY.
(8) 14. All provisions of this Order shall expire one year from the date this Order is
entered.
NOTICE TO THE DEFENDANT
VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON
THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS
PUNISHABLE BY A FINE OF UP TO $1 ,000 AND/OR A JAIL SENTENCE OF
UP TO SIX MONTHS. 23 PA.C.S. S6114. VIOLATION MAY ALSO
SUBJECT YOU TO PROSECUTION AND CRIMINAL PENALTIES UNDER
THE PENNSYLVANIA CRIMES CODE. THIS ORDER IS ENFORCEABLE
IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA, TRIBAL
LANDS, U.S. TERRITORIES, AND THE COMMONWEALTH OF PUERTO
RICO UNDER THE VIOLENCE AGAINST WOMEN ACTION, 18 U.S.C.
S2265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY
VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL
PROCEEDINGS UNDER THAT ACT. 18 U.S.C. SS 2261-2262. IF
PARAGRAPH 12 OF THIS ORDER HAS BEEN CHECKED, YOU MAY BE
SUBJECT TO FEDERAL PROSECUTION AND PENALTIES UNDER THE
"BRADY" PROVISIONS OF THE GUN CONTROL ACTION, 18 U.S.C.
S922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS
OR AMMUNITION.
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NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who have jurisdiction over Plaintiff's residence OR any location where a violation
of this Order Occurs OR where Defendant may be located, shall enforce this Order. An arrest for
violation of Paragraphs I through 7 of this Order may be without warrant, based solely on probable
cause, whether or not the violation is committed in the presence of the police. 23 Pa.C.S. 96113.
Subsequent to an arrest, the police officer shall seize all weapons used or threatened to be
used during the violation of the Protection Order or during prior incidents of abuse. The Cumberland
County Sheriff's Department shall maintain possession of the weapons until further Order of this
Court, When Defendant is placed under arrest for violation of the Order, Defendant shall be taken
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PAGE 2
All comparable sales are settled to the best of my
knowledge. Verification has been made through Realtor, Luok
Reports, MLS, or the County Assessment Office.
I have chosen what are believed to be the best comparable
sales available from the market search. Adjustments in the "Market
Data Approach" are based on generally observable market trends and
not cost. Occasionally it is necessary to Use comparable sales
that occurred over 6 months prior to the appraisal date, have
individual adjustments exceeding 6\ of the comparable's sale
price, have net adjustments more than 10\ of the comparable's sale
price and that are located more than 3 miles from the subject.
Because the subject property can not be cornpared to "ideal"
comparable sales, I have chosen the best sales available from the
market search which meet investor underwriting standards but also
guidelines established by the Appraisal Institute.
GENERAL MARKET COMMENT
Every effort has been made to conform to FNMA Guidelines
and in most cases, an even stricter interpretation found common to
most investors in the secondary market.
Unless otherwise stated in this report, the existence of
haza~dous materials, which mayor may not be present on the
property, was not observed by me. I have no knOWledge of the
existence of such materials on or in the property. I, however, am
not qualified to detect these substances. The presence of
substances such as asbestos. urea-formaldehyde foam inSUlation. or
other potentially hazardous materials may affect the value of the
property. The value estimate is predicated on the assumption that
there is no such material on or in the property that would cause a
loss in value. No responsibility is assumed for such conditions.
or for any expertise or engineering knowledge required to discover
them. The client is urged to retain an expert in this field, if
desired.
J). l(a(":~"'4'''?_'
D. RAr-aENN NGS .
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~TChl AREA TABLE ADDEN....UM -
, .
'II_No: 96aS03
S Dor'llWI'/CI~"1 ~i .,'.'.
U I -BROWN . JAMES M.
8 PropwtY-'dd,n.
J !HOQ SPRING WAY
E C", eou,lly 01&1. ,liPCoct.
I C Upp R MARLBORO P MD 2G772
T ~ncl"
ANDREWS E ERAL CREDIT UNJON
I 16'
'2' 12'
I
M
P
R
0 4'
V
E
M Util, 1(1
E Room
N 22.2'
T
S
Fuhr Bed
S Kitchen Both Room
K 342
E
T a. a, 242
c
H Living
Bed
Roo" Room
8 i))!ii\:??U2Dii!i)i!i\!??W
I::::;:::;:::::::;:;:::::::;:::;:::;:::;:;:;:;:;:;:;:;:::;:;::::i
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LiViNG ~~EA CALCULATIONS
.,..' '. e~e~kd~Wn '.
;''':'~~n(::.s<7rj3~.Z5 .
;l2~25:>'''X: 24.25
Sublolall
299.69
S39.56.
28a.OO
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'90.00
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7.50
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SUPERVISORY APPRAISER'S CERTIFICATION: II. 'up.rvltory ."ltl"r .l,".d lho .pp'...., .."or'l, t!. ... .h. IOrtln..
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ADDRESS OF PROPERTY APPRAISED:
9100 SPRING WAY
UPPER MARLBORO HD 20772
,.
APPRAISER:
",.,,~, I). kCC<' dAJtll'A-r
n.",.: D. MY JENN1N~ /
O'I'."l>Id: MAY 31. ]99~
111I.C..llIInll"",:
""I'I.U"",,.: 02-172Q
111/.: l:m
Eaplr.llon 0.1. e' e.rllll""I",, or Uunn: 12/31/97
,u,n'lur.:
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FannI.MIlFotm 1004B6.93
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DDA009FM
JUSTHCA
---. Harris
~..AY}NG~ -
Savings Bank
Account Inquiry
~
Account Number 560010148
Short Name
BROWN JAMES M
6/07/9f:
16:41:03
.............................................................................. .
Nbr Debits:
Nbr Credits:
Date Btc TC
121098 INT 39
121198 INT 39
010799 004 20
010899 INT 39
Q11599 CLS 15
011599 CLS 16
Monetary Activity
o
o
Lst Strnt: 3/31/99
Nbr Enclosed: 0
Last Stmt Balance:
Current Balance:
Seq Nbr Description Check Nbr
INTEREST PD
INTEREST PD
7511410 DEPOSIT
INTEREST PD
4161140 CLS PD INT
4161140 CLOSING DR
F2=Fold/Unfold F3=Exit
F8=package Post Activity
F7=Non-Monetary
F10=Search Options
Tran Amount S
4.37 *
.02 *
19,048.65 *
4.51 *
4.37 *
19,165.61 *
.00
.00
Balance
108.06
108...08
19,156'.73
19,161.241::::-
.19,165.61
.00
F9=Teller/Merno Activity
F12=previous
.............................................................................. .
DDA009FM
. JUSTHCA
Harris Savings Bank
-'. DEMAND - Account Inquiry"
6/07/99
16:06:54
Account Number 500042738
Short Name
BROWN JAAES M
................. ..................................................................
Monetary Activity
!>lor Debits: 0 Lst Stmt: 2/10/99 Last Stmt Balance: .00
Nbr Credits: 0 Nbr Enclosed: 0 Current Balance: .00
Date Btc TC Seq Nbr Description Check Nbr Tran Amount S Balance
123098 001 90 7350120 CHECK 1203 7.30 * 5,760.94
123198 001 90 1082380 CHECK 1205 478.58 * 5,282.36
1095 .
010499 001 90 4920520 CHECK 49.42 * 5,232.94
010499 001 90 4230540 CHECK 1201 8.86 * 5,224.08
0~0599 001 90 8971760 CHECK 1206 77 .33 * 5,146.75
010599 001 90 8822590 CHECK 1099 75.00 * 5,071.75
010899 INT 39 INTEREST PD 4.73 * 5,076.48
010899 DCF 60 DEBIT MEMO 12.00 * 5,064.48 '~
F2=Fold/Unfold F3=Exit
F8=package Post Activity
F7=Non-Monetary
F10=Search Options
F9=Teller/Memo Activity
F12=Previous
...........................................................................,... .
NEW CUMBERLAND FEDERAL CREDIT UNION
P,O. BOX 658 . NEW CU1\IBERLAND, PA 17070
(717) 77J.7706' 1 (SOD) 716-2328
A TTE~- ION V I SA CRED IT CARD
USERS! EFFECTIVE 1i5/99, WE
ARE REDUCING OUR VISA RATE
FROM 13.2Y. TO 12.9Y..
Joint Owners
ACCOUNT NUMBER
065925 i
SOCIAL SECURITY ft I
179-44-8913,
STATEMENT PERIOD
From
SUSAN D BROWN
16 COLUMBIA DRIVE
CAMP HILL PA 17011
, . ...' ., '..,' " .. '\ ,:" . '.', r' '. ,'.' . ',:.."',: /.' '.' ':. ",',: " ': "', : "f ::'
TlIAJcSACr'lON G'fEnVt, ," . ~'. ,L,,',', " DE;SCRIPTlON' " ' ", ....,' AMOUNT"' '", '
.\' \1 DATE ,',', DAlE; , '. :,. ~ '.~ ,::~'.\, ,", " ~.-'.~.' ,'..: ';, '::. ", ,:.:." .'~' ,J' :.\"., " I . ,:
FtNANCE
CHARGE
1001 PREVIOUS BALANCE SI-PRIMARY SHARES
1031 DIVIDEND 18
ANNUAL PERCENTAGE RATE: 3.00
ANNUAL PERCENTAGE YIELD: , 3.04
1130 DIVIDEND 1
ANNUAL PERCENTAGE RATE: 3.00
ANNUAL PERCENTAGE YIELD: 3.04
1231 DIVIDEND 18
ANNUAL PERCENTAGE RATE: 3.00
ANNUAL PERCENTAGE YIELD: 3.04
.
1231 NEW BALANCE DIVIDEND IS CALCULATED
USING A DAILY BALANCE METHOD.
I
69?0
6918
6985
70 3.
I
i'
,
J
TOTAL DIVIDEND YEAR.TO.DATE
for ell savings excepllRA $livings.
Divid,nds shown, if over $10. will be reponed
to the Internal Revenue Service for this
calendar yeer.
"INDICATES EFFECTIVE DATE
2.07 TOTAL FINANCE CHARGE YEAR.T~TE
for Dllloanl.
(,
NOTICE: See reverse side for important information.
0300164
/..,~
1
, ,
NEW CUMBERLAND FEDERAL CREDIT UNION
P,O, BOX 658 . NEW CUMBERLAND, PA 17070
(7]7) 774.7706 . 1 (800l 716.2328
PLICATIONS FOR $500
,.~'~:S HOLARSHIP AWARD ARE
"'"'."1i ING ACCEPTED NOW, UNTIL
,"c' 8-02-96. WINNER WILL BE
ANNOUNCED ON 06-09-96.
Joint Owners
ACCOUNT NUMBER
SUSAN K DAPP
16 COLUMBIA DRIVE
CAMP HILL PA 17011
S.
065925
SOCIAL SECURITY ft
179-44-8913
STATEMENT P
From
. -QN"iITtcitvE' '. ~ I.;L.: ,.\ \ :', ';, ",.",", .' Q" ,: ..' ",
*oATE.......... ~:.....~' DATE_..............;.'_:;.._;..."'_.n-......._:.:..... ..::D.ES.CR1PT10N.....,.~._...~............_"..M...7"...,,~~._..'7:A~OUNT.~
. ,', \., '. . ", " '. r", '. .' \ ,
FINANCE
CHARGE
0401 PREVIOUS BALANCE SI-PRIMARY SHARES
0430 DIVIDEND 1
TH ANNUAL PERCENTAGE YIELD FOR 040196 TGl 043096 I 3.27.
0531 DIVIDEND I 1
TH ANNUAL PERCENTAGE YIELD FOR 050196 TGl 053196 I~ 3.34.
0630 DIVIDEND I i~
TH ANNUAL PERCENTAGE YIELD FOR 060196 TID 063096 3.25.
0630 NEW BALANCE DIVIDEND IS CALCULATED
USING A DAILY BALANCE METHOD.
0401 PREVIOUS BALANCE L2-NEW CAR - 60 MO
0411 PAYMENT 1
0411 PAYMENT 9786 106
NEW BALANCE-PERIODIC RATE .031506Y.
>> ANNUAL PERCENTAGE RATE 11.500Y. <<
j'--' T,
~ f./..<j ~~ N.l_ -+'
-, , . J .J fL., 14
-~ =:-'-"". ...,,,. ""-..-v u v
. J r::.u {t....c--+- ~ ;,2.,,_.
Cp
"
.r./" .....
,
, '
y,~ '-/A'.-;/
(/'
-)~:I' "~/./:"'!-",~
~-"',../ '-' ',~ -...
L.;
TOTAL DIVIDEND YEAR.TO-DATE 1.04 TOTAL FINANCE CHARGE YEAR-TOOATE
for .11 savings except IRA SlvingL for allloan5.
Divid.nds shown, If over $10. will be reportoo
10 th.lnternal Revenue Service for this NOTICE: See reverse side for important information.
Qllendar veer.
"INDICATES EFFECTIVE DATE
48.97
'"
( r'.
. Contribution Benefit Eligible -,sting
Year Hours Amount Credits Credits Service
............................................................... 00.........
1986 520.50 52.05 .306 .306 .00 12.43
----------------------------------------------------------------------------
1987 2054.00 544.10 1. 208 1.208 1. 00 138.92
1988 2174.50 434.90 1. 279 1.279 1. 00 147.09
1989 2056.00 640.05 1. 209 1. 209 1. 00 139.04
1990 2183.00 1382.80 1. 284 1. 284 1. 00 147.66
1991 2178.00 4322.40 1. 281 1.281 1. 00 147.32
1992 1956.00 3586.00 1.151 1.151 1. 00 132.37
1993 1644.33 1952.46 .967 .967 1. 00 111.21
1994 2070.50 4622.74 1.218 1. 218 1. 00 140.07
1995 2027.50 5081.52 1.193 1.193 1. 00 137.20
1996 2074.50 5525.40 1.220 1. 220 1. 00 140.30
1997 2198.00 6554.23 1. 293 1.293 1. 00 148.70
1998 2340.50 7630.03 1.377 1.377 1. 00 158.36
.999 2173.50 8105.00 1.279 1.279 1. 00 147.09
000 588.50 2283.38 .346 .346 .00 39.79
-----------------------------------------------------------------------------
1887.55
i
\
"---.-
...
oak Life Insurane .:~ompany
ni:ock Variable L1fr~'uranc. Company
. .
, ,
~ohn Hancock Placo
post Off1co Box 772
Boston, Massachusetts 02117
1.800.732.5543
1.617.572.1571 (Fax)
1.800.832.5282 (TOO)
Teresa Santacroce
Customer Service Representative
June 29. 2000
James M Brown
9100 Spring Way
Upper Marlboro, MD 20774-3535
RE: PNO 065487152
Dear Mr. Brown:
This is in response to your phone call requesting cash values as of the following dates:
Date 12/96 12/98
Basic Cash value 2470.75 3025.00
Dividends + Interest 581.76 856.02
Senlement Dividends N/A 45.00
Refund Prem 44.70 44,70
Net Cash Value $3097.21 $3970.72
We're here to help you with any questions you may have about your John Hancock
products. Our customer service representatives in Boston are ready to assist you between
the hours of 8:00 a.m. and 8:00 p.m. Eastern time, Monday through Friday, at
I-800-REAL LIFE (1-800-732-5543).
We look forward to hearing back from you, and hope that you are pleased with your John
Hancock products and services.
Sincerely,
7~S~
'j,-
...------.-..--..-- ..-
_...... _u. __
, .
'...... ..':-'.,
11Iwme and Expense SCatemelll
OTHER
INCO/vrE
Imerest
Dividends
Pension
Annuity
Social Security
Rents
Royalties
Expense Account
Gifts
Unemployment
Compensation
Workmen's
Compensation
IRS Refund
Other
Other
TOTAL
TOTAL INCOME
EXPENSES
Home
$
Maimenance
Utilities
Electric
Gas
Oil
Telephone
Service Type M
~---.~~ "'-'.'-"'--,
$
$
.'\
,
.-..
WEEK
$
WEEK
...... -....._-...
'1
,-,
, .
PACSES Case Numher 088100688
(Fill in Appropriate ColunUl)
MONTH
$
$
(Fill in Appropriate Column)
MONTH
$ 400.00 presently $
~
YEAR
$
$
YEAR
60.00 estimated for apt.
60.00 estimat~d for :.r.l apt
50.00
Page 2 of 6
',_ '_h ~ ,. ~_ ._ __~...._. -:~'_".'" _._"_ .._
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Fonn IN-OOB
Worker ID 21202
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Inwme and Expense SlaleJllelll
PACSES Case Numher 088100688
EXPENSES (Fill in Appropriale C"lunUl)
(continued) WEEK MONTH YEAR
Wal<r $ $ $
Sewer
Employment
Public Transponation $ $ $
Lunch
Taxes
Real Estate $ $ $
Personal Propeny
Income
Insurance
~ Renters $ $ unable to afford $
Automobile 39.56
Life
Accident
Health covered by Husband
Other
Automobile
Payments $ $ $
Fuel 65.18
Repairs 1,)~ nn
RPOistration/lnspe ction 10.00
Medical
Docmr' $ $ see attached $
Demi,l
Onhodomisl
Page 3 of 6
Fonn IN-008
Worker ID 21202
S<rvice Typ< M
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Income and Expense Statement
PACSES Case Numher 088100688
EXPENSES (Fill in Appropriate Cnlumn)
(continued) WEEK MONTH YEAR
Hospital
Medicine see attached
Special needs (glasses.
braces. nnhopedic
devices) Glasses 29.00
Education
Private School $ $ $
Parochial School
College
Religious
II $4.800 - $7100) Dlus =s of PC and prir
Persnnal
Clothing $ $ 30.00 $
Food 521.40
BarberlHairdresser 15.00
Credit Payments:
Credit Card 25.00
Charge Account
Memberships
.
Loans
Credit Union $ $ $
Catherine Kasoarv (mother ) CINe approx. $3200 unabl to make $50/rnc
,
,
Miscellaneous
Household Help $ $ $
Child Care
PaperslBooks/Magazine 20.00
Entertai liment unable to afford
Pay TV 1A nn
Vacalion unable to afford
ter
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payments
Page 4 of 6
Form IN-008
Worker ID 21202
Service Type M
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BARBARA SUMPLE-SULLIVAN
0,.).'1 DUIDGll STRmn
NEW ClJHlHWI.ASIl. I'J:NSSYI.vANIA 17070-1001
PIIONC (717) 774.144t\
FAX (717) 77....70:\U
May 16.2001
E. Robert Elicker, II, Esquire
Divorce Master
9 North Hanover Street
Carlisle, PA 17013
Re: James M. Brown v. Susan D. Brown
No.99-9641 Cumberland County
Dear Divorce Master Elicker:
Pursuant to your directive of April 19, 2001, enclosed please find Defendant's Pre-Trial
Statement.
Barbara Sumple-Sullivan
BSS/ld
Enclosure
cc: Carol J. Lindsay, Esquire (w/enclosure)
Susan D. Brown (w/enclosure)
.
ORDER/NOTICE TO WITHHOLD INCpME FOR SUPPORT
'Old. Q<}7t,.,'1 (i/{/(C
Slate ,Co~monwealth of Pennsylvania P Ii! '>.'; S O'i~ (oOt., f s:-
Co.lClty/Dlst. of CUMBERLAND 'I),,"
Date of OrderlNotice 11/06/01 U<:.... ;;;L Y "JOCj
Court/Case Number (See Addendum for case summary)
o OriglnJI Order/Nolice
@ Amen(lml Ordl!r/NoliCt!
o TerminJI{~ Order/Nolle.l
EmploYl!rM'lthholdcr's Federal EIN NumlX'r
COMBUSTIONEER CORPORATION
Employer/wilhholder's Name
645 LOFSTRAND LN STE A
EmploycrlWilhholcler's Address
ROCKVILLE MD 20850-1382
I RE: BROWN, JAMES M.
) Employee/Obligor's NJmc (Llsl, First, Mil
) 578-82-0413
) EmploYI!e/Obligor's Social Security Numlx!r
I 6881100186
) Employct'/Ohligor's CJ~e Identifier
) (See Addendum for plaintiff ndmf.'S assodated with cases on attachment)
) Custodial PJrenl's Name (last, Firsl, Mil
)
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See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania, By law, you are required to deduct these
amounts from the above-named employee'slobligor's income until further notice even If the Order/Notice is not
issued by your State.
$ 900.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? 0 yes @ 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 $ 900 . 00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 207.69 per weekly pay period.
$ 415.38 per biweekly pay period (every two weeks),
$ 450.00 per semimonthly pay period (twice a month).
$ 900.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydateldate of withholding. You are entitled to
dedud a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee'sl obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on pg. 2).
If remitting by EFT/EDI, please cali Pennsylvania State Coiled ions and Disbursement Unit (SCDU) Employer
Customer Service at '-877-676.9580 for instructions,
Make Remittance Payable to: PA seDU
Send check to: Pennsylvania SeDU, P.O. Box 69112, Harrisburg, Pa 17106.9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BY THE COURT:
}:~:~ttj,,~\
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I'<l~'" .r.,~ ~"t'I: ,
~..l...k, db . MBNo.:0970.0154
//... 'I-Of ~prr<\tlonD~le:12fJl/00
Date of Order: NOV
7 2C~1
JVMt;
Form EN-028
Worker ID $IATT
Service Type M
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If checked you are required to provide" copy of this form 10 your employee,
1. Priority: Withholding under this Order/Notice has priority over .lIlY olher legal process under Stale law against the same income.
rederal tax levies in effect before receipt o(this order have priority. If.here are FederJI tax levies in effect please contact the requesting
lIBelley listed below.
2. Combining Pdyments: You Gill combine withheld amounts (rol11more 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
e"ch employee/obligor.
]. . -Reportintjlhe-P.yd.telB.te-ofWithholding;-Vou11'lu,t-reportthe-poyd.te/d.te-of-withholding-when-,ending-the-poyment,---'Fhe_
poydateld.te-of-withholding-i,-the-d.te-on-which-amount-w.s-withheld_from_the-employee's-w.ges-: YOll must comply with the law of rhe
state of the employee'slobJigor's principal place of employment with respect to the time periods within which you must implement the
withholding order "nd forward the support p"yments.
4,' Employee/Obligor with Mulliple Support Holdings: If there is more th"n one Order/Notice to Withhold Income for Support
against this employee/obligor and you ore unable to honor all support Order/Notices due to Feder"1 or State withholding limits, you must
follow the law of the Slate of employee's/obligor's princip"1 pl"ce of employment. You must honor "II Orders/Notices to the greatest
extent possible. (See #9 belowl
5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for
you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
WITHHOlDER'S ID: 5216901750
EMPLOYEE'S/OBLlGOR'S NAME: BROWN, JAMES M.
EMPLOYEE'S CASE IDENTIFIER: 6881100186 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should
have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs
unless the obligor is employed in anolher State, in which case the law of the State in which he or she is employed governs.
B. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from
employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding.
Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is
employed governs,
9.' Withholding Limits: You may not withhold more than the lesser of: lithe "mounts "lIowed by the Federal Consumer Credit
Protection Act (15 U.S,c. 91673 (b)l; or 2) the amounts allowed by the Stare of the employee's/obligor's principal place of employment.
The Federallimit.pplies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income leh "her m"king mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes.
10.
'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
Requesting Agency:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at {7171 240-6248 or
by Internet @
Service Type M
Page 2 of 2
Form EN-028
Worker ID $IATT
OMBNo.:0970-0154
hpitilt(onDill(,>:121Jl/00
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: BROWN, JAMES M.
PACSES Case Number 088100688 /J';{:XJ if
Plaintiff Name 'I '.
SUSAN D. BROWN
Docket Attachment Amount
99=-964"CIVIL $ 900.00
Child(ren)'s Name(s):
DOB
d li~I;~~ked,~~u are required to enroll the child(,en)
identified above in any health insurJnce coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
D If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
D If checked, you are required to enroll the child(renl
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Addendum
Service Type M
OMB No.; 0970-0154
[~plr~lion D~II': 12/31/00
PACSES Case Number
Plaintiff NJll1e
Docket Altachlllenl Amount
$ 0.00
ChiIJ(ren)'s Namets):
DOB
D If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
D If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
D If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Form EN-028
Worker ID $IATT
DOB
.-'.. _. .~...
OROER/NOTlCE TO WITHHOLD INCOME FOR SUPPORT
Slate Commonwealth of Pennsvlvania
Co'/City/Oist. of CUMBERLAND
Date of Order/Notice OS/27/03
Tribunill/Case Number (See Addendum for case summary)
6) Origin.ll Order/Nolin'!
o Amended Order/Notice
o Termin.llc Order/Notice
RE: BROWN, JAMES M.
EmployertWithholder's Federal [IN Number
MECCO INC
PO BOX 250
CLINTON MD 20735-0250
Dk!. /199-9(,,/( (l/I4L
jJt!C(;FC, {XI?; /M {; ff
I:mployec/OlJligor's Name (Lasl, First, Mil
578-82-0413
[mployee/Obligor's SociJI Securily Number
6881100186
[mplo~'('e/Obligor's Case ldentiiier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodi,ll Parent's Nilmc (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, Commonwedllh of Pennsylvania. By law, you are required to deduct these
amounts from the above.named empioyee's/obiigor's income until further notice even if the Order/Notice is not
issued by your State,
$ 900.00 per month in current support
$ 0.00 per month in past.due support Arrears 12 weeks or greater? Oyes @ no
$ 0.00 per month in medical support
$ 0 . 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 900.00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the foilowing to determine how much to withhold:
$ 207.69 per weekly pay period.
$ 415.38 per biweekly pay period (every two weeks).
$ 450.00 per semimonthly pay period (twice a month),
$ 900.00 per monthly pay period.
REMITTANCE INFORMATION: .
You must begin withholding no later than the first PdY 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'sl 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 (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SeDU
Send check to: Pennsylvania SeDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER 10 (shown
above as the Employee/Obligor's Case Identif.i~r) 9R,,~QCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL. : _J2..\.~. . . ~-_
5-,;L!.L!3 BYT,!WCOURT~~).
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(:c{)c.,F-I;~ I~. 61'7yO;'1 Ol/LX---f:
Form E N-028
Worker ID $IATT
MAY 2 8 2003
Dilte of Order:
Service Type M
OMIJNo.:fl'J7(]'[ll:;.1
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o I("heckell you are required 10 provide a copy o( Ihis fornllo your em/,Ioy"e. If YO\lr employee ;yorks in "sl"le Ih"t is
dil(ercnt lrom the state thai isslIed this oreler, i1 copy musl be providc! to your employee even If tile box is nol checked.
1. We appreciate the voluntary compliance of Fcdcr.llly r('cognized Indian tribes, tribillly-owned businesses, Jnel Indiiln-owncd
businesses located on a reservation thai choose to withhold in accordance with this notice.
2. Priority: Withholding under this Order/Nolice has priorily over "ny olher leg,,1 process under SI"le I"w againstlhe s"me income.
Federal tax levies in effecl before receipt of this order have priority. If there arc Federal tax levies in effect please conlacllhc requesting
"gency listed below.
3. Combining Payments: You can combine withheld amounts from more IhJn one employee/obligor's income in II single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment th.lt i~ attributable to each
employeelobiigor.
4. '-Reportlngihe-Pnyd"lelB"lc-ofWithholdiog:--Y ou-musl-report-lhe -paydnle/daleof wilhhold Ing when-sending Ihe p"ymenl,-The-
paydalcldnteofwilhholding'is-Ihe d"le onwhich-"mounl was-withheid-(rom-Ihe employee's-wages.- You musl comply wilh Ihe law of the
slate of Ihe employee's/obiigor's principal pi"ce of empioymenl wilh respecllo Ihe lime periods within which you must implementlhe
withhoiding order and forward Ihe support paymenls,
5.' Employee/Obligor with Multiple Support Holdings: If there is more Ihan one Order/Nolice 10 Withhold Income for Support against
Ihis employee/obligor and you are unable 10 honor all support Order/Nolices due 10 Federal or SI"te withholding iimits, you musl (ollow
the law of the sl"le of employee's/obligor's principai pl"ce of empioyment. You must honor all Orders/Nolices 10 Ihe gre"lesl exlenl
possible. (See #1 0 belowl
6. Termination Notificatioo: You musl promplly nOlify Ihe Requesling Agency when Ihe employee/obligor is no longer working for you.
Piease provide Ihe in(orm"lion requested "nd relum a copy of Ihls Order/Notice 10 Ihe Agency ideolified below,
WITHHOLDER'S 10: 5213075090
EMPLOYEE'S/OBLlGOR'S NAME: BROWN , JAMES M.
EMPLOYEE'S CASE IDENTIFIER: 6881100186 DATE OF SEPARATtON:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
7. Lump Sum Payments: You may be required 10 report and wilhhold from lump sum paymenls such "s bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
8. Liabilily: If you (aii 10 withhold Income "s Ihe Order/Nolice direcls, you are liable (or bolh the accumulaled amounl you should h"ve
wilhheld from Ihe employee/obligor's iocome and olher penallies sel by pennsylvaoia Slale I"w. Pennsylv"nia Slale law governs unless
Ihe obligor is employed in "nolher SI"le, in which case Ihe I"w of the Slale in which he or she is employed governs.
9. Anti-<liscrlrnination: You are subjecllo" fioe delermined under Slale law for discharging "n employee/obligor from employment,
refusing 10 employ, or laking disciplin"ry "cllon "g"insl any employee/obligor because o( a support withholding. Penosylvanla State law
governs unless Ihe obligor is employed In "nolher Slale, in which case Ihe iaw of Ihe Slale in which he or she is employed governs.
10.' Withholding Limits: You may not wilhhold more Ih"n Ihe lesser of: 1) Ihe amouols allowed hy Ihe Federal Consumer Credil
Protection Act (1 5 U.S.c. ~ 1673 (hll; or 21 Ihe amounls allowed by Ihe SI"te o( the employee's/obligor's principal place o( employment.
The Federallimil applies to Ihe aggreg"le disposable weekly earnings (ADWEI. ADWE is Ihe oel income left after making mandalory
deductions such as: State, feder"I, local taxes; Soci,,1 Securily laxes; "nd Medic"re laxes.
11. Additional Info:
'NOTE: If you or your agent are served with a copy of Ihis 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 al (717) 240-6248 or
CARLISLE PA 17013 by internet www.childsupport.stale.pa.us
Page 2 of 2
Form EN-028
Worker ID $IATT
Service Type M
OM) No.: O'J7().(Il_~~
ORDER/NOTICE TO WITHHOlD INCOME FOR SUPPORT
State Commo~lth of Pennsylvania
Co./Cily/Dist. of CUMBERLAND
Date of Order/Notice OS/21/03
Tribunal/Case Number (See Addendum for Cdse summary)
o Original Order/Notice
o Amended Order/Notke
@ TerminJtc Order/Notice
EmployerArVithholder's FcderJI EIN Number
Rl: BROWN, JAMES M.
COMBUSTIONEER CORPORATION
645 LOFSTRAND LN STE A
ROCKVILLE MD 208S0-1382
JJ!J. /11'1 .9t/1 (7 v/!.-
fJ}(!~$ Or'l/[)o&,f{
Employee/Obligor's Name (I.ilst, First, Mil
578-82-0<!l3
Employee/Obligor's Social Security Number
6881100186
Employ(>c/Obli8or'S Case Identiiier
(Sel> Addendum for plaintiff names
associilfed with cases on attachment)
Custodial Parent's Nurnc (last, First, MI)
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMA TION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the OrderlNotice is not
issued by your State.
$ 0.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? 0 yes <Xl no
$ 0 . 00 per month in medical support
$ 0.00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 0.00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 0.00 per weekly pay period.
$ 0.00 per biweekly pay period (every two weeks).
$ 0.00 per semimonthly pay period (twice a month).
$ 0.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed SS% 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 (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 10 (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL. :!"JRJil1LE:Q
-". .' Y THE COURT:~
. 5-,)-J.-06 / )(7~i
DateofOrder:~Y 222003 ( C \.- , >, /, .0,
G)c,,;J-~ 'e>/d4'.;;;Ci5.y:> ' I . \ ~trE
Form EN-028
Service Type M O....lB No.: O'17()./Il'i.' Worker 10 $IATT
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
D If ~heckeil you ~re required 10 prpvide ~ copy of Ihis form to your ,'m/,Ioyee. If YO\I( employe,! 'Yorks in ~ slole thot is
dll(erent trom the slale thai issuc( this order, a copy musl be provic!cc to your emp ayec cv(!n II the box is not checked.
1. We appreciate the voluntary compliance of Federally recognized Indil1n tribes, tribally-owned husinesses, ,me! Indian-owned
businesses located on a reservation that choose to withhold in i1tTord,mce 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 receipl of this order have priorily. If there are Feder~lt~x levies in effect please contact the requesling
agency listed below,
3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in il single payment to
each agency requesling withholding. You must. however, sep~r~tely identify the portion oi Ihe single payment th~t is allribut~ble 10 e~ch
employee/obligor.
4. "Reporting-the-Paydate/Date-of Wilhholding,-Y ou -musl-report-thepaydate/dale-o( wilhholding-when-sending-the-payment;-The-
paydale/dale-ofwithhol(ling'is-the daleon-whlch-amount-was-withheldfrom-the-employee"'wages~ You must comply with the law of Ihe
slale of the employee's/obligor's princip~1 place of employment with respecllo Ihe time periods within which you must implement the
withholding order and fOlWard the support payments.
5.' Employee/Obligor with Multiple Support Holdings: If Ihere is more than one Order/Nolice to Withhold Income for Support against
this employee/obligor and you are unable 10 honor all support Order/Notices due to Federal or SI~te withholding limils, you musl follow
the law of the state of employee's/obligor's principal place of employment. You musl honor all Orders/Notices to the grealest 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 Ihis Order/Notice to the Agency identified below.
WITHHOLDER'S ID: 5216901750
EMPLOYEE'S/OBLlGOR'S NAME: BROWN , JAMES M.
EMPLOYEE'S CASE IDENTIFtER: 6881100186 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 ~bout lump sum payments, contact the person or authority below.
8. liability: If you fail 10 wilhhold income as the Order/Notice directs, you are Ii~ble for both Ihe accumulated amount you should have
wilhheld from the employee/obligor's income and olher penallies set by Pennsylvania 51ale law. Pennsylvania State law governs unless
the obligor Is employed In another Slale, in which case the law of Ihe Slate in which he or she is employed governs.
9. Anti'lliscrimination: You are subject to a fine determined under Slate law for disch~rging an employee/obligor from employment,
refusing to employ, or taking disciplinary action against ~ny employee/obligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in anolher 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 Feder~1 Consumer Credit
Protection Act (15 U's,c. 91673 (bll; or 2) the amounts allowed by the Slale of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the nellncome le(t after m~king mandatory
deductions such as: Slate, 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 10 these items,
Submitted By: If you or your employeelobligor 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
OMB Nn.: (I'17().(llS-l
r.) ;.:11.1 U L
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsvlvania
Co.lCi.ty/Dist. of CUMBERLAND
O,ate of Order/Notice 12/26/03
'j ribunal/Case Number (See Addendum for case summary)
R[: BROWN, JAMES M.
EmploycrM'ilhholdcr's FcderJI EIN Number
MECCO INC
PO BOX 767
JESSUP MD 20794-0767
o Original Order/Notice
o Amended Order/Notice
@ Terminate Order/Notice
Employee/Obligor's Name (Last, First. MI)
578-82-0413
Employee/Obligor's Social Security Number
6881100186
Employee/Obligor's Case Identifier
. (See Addendum for plaintiff names
(]/1 /J.J / '(2 . associated with cases on attachment)
VI""'"- "'fW--/ /2LL,'L V Custodial Parent's Name (last, First, Mil
U6~ /(JDtlJ~8
See Addendum for dependent names and birth dates associated with cases on allachment.
ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee'slobligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 0.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Qyes @ no
$ 0,00 per month in medical support
$ 0 . 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 0.00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 0.00 per weekly pay period.
$ 0.00 per biweekly pay period (every two weeks).
$ 0.00 per semimonthly pay period (twice a month).
$ 0.00 per monthly pay period,
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the 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 EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SeDU, 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 IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
Date of Order: JAN 02 2004
Service Type M
OMB No.: 097().{)154
Form EN-028
Worker 10 $IATT
o
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o Iffihecked you are required to provi~e a copy of Ihis form 10 your "ml,loyee. If YO\" employee works in a slate Ihat is
di ere"t from the slale lhilt issued this order, i1 copy must be providc{ to your cmp ayec even If tile box is not checked.
1, We app!eciale the voluntary compliance of federaily recognized Indian tribes, Iribally-owned businesses, and Indian-owned
businesses located on a reservation thaI choos(~ 10 withhold in accordance with this notice.
2. Priority: Wilhholding under this On..ler/Notice hilS priority over any other legtll process under Slale 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 amounls 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 Ihe single payment that is atlributable to each
employee/obligor.
4, '-Reporting-the-Paydate/eate-tJ~Withholding:-\'ou-mtlst-reportthe-paydate/date-of-withhold ing-when-sending-the-payrnent:-The-
paydate/date-o~withholding-is-the-date-on-which-amount-w"s-withheld-from-the-employee's-wagesc You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the lime periods within which you must implement the
withholding order and forward the support paymenls,
5.' Employee/Obligor with Multiple Support Holdings: If Ihere 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
Ihe law of the state of employee's/obllgor's principal place of employment. You must honor ail Orders/Notices to the greatest extent
possible. (See #10 below)
6, Termination Notification: You must promptly notify the Requesting Agency when Ihe employee/obligor is no longer working for you.
Please provide Ihe information requested and return a copy of this Order/Notice 10 the Agency identified below.
WITHHOLDER'S ID: 5213075090
EMPLOYEE'S/OBlIGOR'S NAME: BROWN. JAMES M.
EMPLOYEE'S CASE IDENTIFIER: 6881100186 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 authorily 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-discriminalion: 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 empioyed govems.
10.' Withholding Limits: You may not withhold more than the lesser of: 1) the amounls allowed by the Federal Consumer Credit
Protection Act (1 S U.s.c. ~1673 (b)l; or 2) the amounts allowed by the State of the employee'sJobligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes.
11. Additional Info:
'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these Items.
Submitted By:
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) 240-6.2:llL- or
by internet www.childsupport.state.pa.us
Page 2 of 2
Form EN-028
Worker ID $IATT
Service Type M
OMBNo.:097().(Jl:.4
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ORDER/NOTICE TO WITHHOlD INCOME FOR SUPPORT
State Commonwealth of Pennsvlvania
Co.lCitylDist. of CUMBERLAND
Date of Order/Notice 07/19/05
Clse Number fSee Addendum for case summary}
o Origin.!1 Ordpr/Notict'
o I\rnemlc{l Order/Notice
o 'erminate Order/Notice
KI: BROWN, JAMES M.
[mploycrNJithholdPr's 1.l'dpr.ll fiN Numll{'f
i)d 11q1. 9(, V at/Z/...
I'IIe~zS 05'iJIDo,,97
frnllloYCl'/Ohligor's Name (La51, first, Mil
578..82-0413
[rnploy('c/Obligor'!i Social Security Number
6881100196
I.mploYl'l'/OlJligor's Case ldl'ntilier
(5(1(> Adc1f>ndum (or plaintiff n.lm(l.~
.1Ssociat(ld witll C.1S('S on attdchm(lnt)
Cuslodi.ll Parent's Name (Last, First, MI)
CONSOLIDATED ENGINEERS
320 23RD ST S
STE 100
ARLINGTON VA 22202-3746
SERVICE
See Addendum for dependent names and birth d,ltes associ.lted with cases on att,lchment.
ORDER INFORMATION: This is an Order/Notice to Withhold Incomp for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By lilw, you ilre 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 Stilte.
$ 900.00 per month in current support
$ 0.00 per month in pilst-due support Arrears 12 weeks or greater? 0 yes 0 no
$ 0.00 per month in current ilnd past.due medical support
$ 0 . 00 per month for gpnetic test costs
$ per month in other (specify)
for a total of $ 900.00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 207.69 per weekly PilY period.
$ 415.38 per biweekly pay period (every two weeks).
$ 450.00 per semimonthly pay period (twice a month).
$ 900.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice, Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding, Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee'sl obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See 119 on page 2).
If remitting by EFT/EDI, pleilse call Pennsylvania Stilte Collections and Disbursement Unit (SCDU) Employer
Customer Sprvice 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 Clse Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL. ., '1:"-
.-.. ':; "7'CJ -"-J''''':~THE
. 11, 41,1 ,j,
'4 _' ~t:f1:i'...f'1"~~' ", -
.JUL 1 9 20as ?'~o-oi;- ."=---.,
Date of Order:
Service Type M
(l/.,A No.: OlJ7(J.()1~4
,J ~
Form EN-028
Worker ID $IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If. dwckrd you are r('Cjuired 10 provide ,I fOpy of this {orm 10 your PIl1/Jloyee. If YO~1f employee works in il slale lhell is
dl!ftlrcnl from the stelle Ih.ll issuelllhis Drller, iI ropy IIlllst he provid(ll to your ernplc)ye(' I!Vl'1l if the box is not checked.
1. Priurity: Withholding under this Order/Nolin! h,IS priority ov<,( ,my olher le~ill pron~ss under Slale law llgillnslll1e same income.
Fcd<!rallax levies in effccllJef()((' r(~(('ipl of Ihls onl('r IhlW priorily. Ii tlwrp ,Ire FederalltlX I('vies in e(fccl ple,lse [onl,I(1 the requesting
agency listed he low.
2. CombininJ; Payments: YOl! can combine wilhlH'ld .llllounls from Illorplhan one C'll1pJoy<,C'/ohligor's income in t1 single payrncnllo
each agency rcqucsling withholding. You IllUSt, however, separ.ltely identify the portion 01 the single payment that is illlrihulable to each
employee/obligor.
3. 'ReportingthePnydnte/Dnte of Withholding: Vnu must report the pnydate/date of withholding when sending the payment.. The
paydatC'/datc of withholding is the dale on which i.lmounl was \\'ithhcld from the employee's wages. You rnu~l comply with Ihe law of the
S{,llc of the employcc's/ohligor's principal place of employment with rcspcclto Ilw 'imp pl'riod!> wi/hill which y(W IUUsl implcmenllhe
withholding order and lorward the slIPportlJilymcnts.
4,' Employee/Obligor with Mulliple Support Holdings: If there is more than one Order/Noliee to Wilhhold Income for Support ngninst
Ihis employee/obligor and you arc unable to honor all ,upport Order/Notices due to Federnl or State withholding limits, you must lollow
the law 01 the Slnte 01 employee's/obligor's principnl place of employment. You musl honor all Orders/Notices to the greatesl ex lent
possible. (See #9 below)
5. Termination NotWenlion: You must promplly notily the Requesting Agency when Ihe employee/obligor is no longer working lor you,
Please provide the information requested and return a copy of this Order/Noti((~ to the Agency identified below.
THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 5417135510
EMPLOYEE'S/OBllGOR'S NAME: BROWN , JAMES M.
EMPLOYEE'S CASE IDENTIFIER: 6881100186 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Paymenls: You may be required to report and withhold from lump sum paymenls such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: tf you fail to withhold income n5 the Order/Notice directs. you are liable for both Ihe accumulated amount you should have
withheld (rom the employee/obligor's income dnd other penalties set by Penl15ylvania Stilte law. Pennsylvania State law governs unless
the obligor is employed in another State, in which Cilse the law of the State in which he or she is employed governs.
8. Anti-discrimination: You are subject 10 a line 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 Slate law
governs unless the obligor is employed in anolher Slate, in which case Ihe law 01 Ihe Slate in which he or she is employed governs.
9.' Withholding limits: You may nol withhold more Ihan the lesser of: 1) the nmounts allowed by Ihe Federal Consumer Credit
Protection ACI (15 U.S.c. ~ 1673 Ib)1; or 2) the nmounts allowed by the State of the employee's/obligor's principal plnc~ of employment.
The Federal limit applies to Ihe aggregnte dispolnble weekly earnings IADWEJ. ADWE is the /lei income left after making mandntory
deductions such as: State, Federal, local taxes; Social Security tnxes; and Medicare Inxes. For tribal orders, you may not withhold more
than Ihe amountl allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more
than the amounts allowed under the law of tile state that issued the order.
10. Additional Info:
* NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
1 1. Submitted By: If you or your employee/obligor have any questions,
DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT
'3 N. HANOVER ST by telephone at (717) 240-6225 or
P.O. BOX 320 by FAX at 171 71 240-6248 or
CARLISLE PA 17013 by internet www.childsupporI.Slate.pa.us
Page 2 of 2
Form EN-028
Worker ID $IATT
Service Type r~
ur.mNo.;{l'1711.1115.1
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
Stale Commonwealth of Pennsvlvania
Co./City/Dist. of CUMBERLAND
Dale of Order/Notice 08/22/05
Case Numher (See Addendum for mse summary)
o Original Order/Notice
o t\mencled Order/Notice
o l'ermin,11e Order/Notice
EmploycrANithholder's Fcc/cr.ll EIN NumllC'(
RE, BROWN, JAMES M.
W ;qc;c;.9(pc( ~r(//L
p~S Of?WDcJ&Q1
Employee/Ohligor's Name (l.lSt, First, Mil
578-82-0413
[mployc('/Obligor's Sodal Security Number
6881100186
Employee/Obligor's Case lclcntiiicr
(See Addendum for plaintiff names
.1Ssocialed with cases on attachme'lt)
Custodi.ll P.\r(~nl'5 N.lmr (I.asl. first. Mil
CONSOLIDATED ENGINEERS
320 23RD ST S
STE 100
ARLINGTON VA 22202-3746
SERVICE
See Addendum for dependent n,lmes ,wd birth dates associated with cases on "ttachment.
ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonweaith of Pennsylvania, By iaw, you are required 10 deduct these
amounts from the above-named employee'slobligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 0.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes @ no
$ 0.00 per month in current and past-due medical support
$ 0.00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 0.00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the foilowing to determine how much to withhold:
$ 0.00 per weekly pay period,
$ 0.00 per biweekly pay period (every two weeks).
$ 0.00 per semimonthly pay period (twice a month).
$ 0.00 per monthly pay period.
REIvI/TT ANCE INFORIvIA TlON:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Nolice. Send payment within seven (7) working days of the paydate/date of Withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount. and your fee, cannot exceed 55% of the employee'sl obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on page 2),
If remitting by EFl/EDI, please call Pennsyivania State Collections and Disbursement Unit (SCDU) Employer
Customer Ser/ice at 1-877-676-9580 for inslructions,
Make Remittance Payable to: PA SCDU
Date of Order:
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. ..m_
AUG 2 3 10;~ i;i:;;~ - ::~"'\ ~IA>"
Form EN-028
Worker ID $IATT
OM[lNo,:1I'J/IHll'>4
Service Type M
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If [hCrK<'d you tIre required to prllVidp..1 ropy of this form 10 your (~IllI)loyl'P. If YOllr employee "yorks in <l slale lhat is
different frollllhe stille thai issu('( this order, .1 copy !',lUsl hl' providc< to your ernp oy('(' even if t H' box is flol checked.
1. Priority: VVilhholding under this Order/Notice has priority over ,lilY other legal process under Slate law againsllhe same income.
Federal tax levies in cifccl before receipt or this order have priority. If Ihcrl' Me Fedcrallilx h~vies in effecl pleilsc contact the requesting
ogency lisled belnw.
2. Combining Payments: YOll can combine withheld amounts {rollllTlOre than one (,il1pIOYf'C/ohligor's income in a single payment to
each ilgcncy requesting withholding. You IllUSt. howevcr, sl'p<triltely identily the portion olth(' Single p<tymcntth<tt is <tllribul<tble to each
employee/obligor. .
3. '-Reporting the Poydale/Dole ofWilhhnlding: You mu't repnrt the poydole/dote of wilhhnlding when ,ending Ihe payment. The.
poydole/doleof wilhhnlding iSlhe d"le on which omounl wo, wilhheld irom Ihe employee', woges. You IllUst comply wilh Ihe low oi Ihe
slate of the employcc's/obligor's princip<tl place oi employment with respecl to the time periods within which you must implement the
withholding order and forw<trd the support (layments,
4.' Employee/Obligor with Muftiple Supporl Holding" Ii Ihere is more Ihon one Order/Nolice 10 Wilhholdlncome for Support ogoinsl
Ihis employee/obligor ond you ore unoble 10 honor oil support Order/Nolices due 10 Federol or 510le wilhholding limits, you musl iollow
the law of the slate of ernployee's/obligor's princip<tl pl<tce of employment. You must honor all Orders/Notices to the grc<ttcst extent
possible. (See #9 below)
5. Termination Notificolion: You musl promplly nOlify Ihe Requesling Agency when Ihe employee/obligor is no longer working for you.
Please provide the information requested ilnd return <t copy of this Order/Nolice to the Agency identified below.
THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 5417135510
EMPLOYEE'5/0BLlGOR'S NAME: BROWN , JAMES M.
EMPLOYEE'S CASE IDENTIFIER: 6881100186 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Poyments: Youmoy be required 10 report ond withhold irom jump sum poymenls such 0' bonuses, commissions. or
severance pay, If you have any questions aboutlurnp sum payments, contact the person or <luthority below.
7. Liabilily: If you fail 10 wilhhold incollle os the Order/Nolice direcl" you ore Iioble for bolh Ihe occumuloled omount you should hove
withheld from the employee/obligor's income and other penalties set by Pennsylvania Stdte law, Pcnnsylvi.llliJ StJte law governs unless
the obligor is employed in another Slate, in which case the IJW oi the State in which he or she is employed governs,
8, Anti-discrimination: You Jre subject to a iine determined under State law ior discharging an employee/obligor irom employment,
refusing 10 employ, or laking disciplinory aclion agoinsl any employee/obligor becouse oi 0 support withholding. Pennsylvanio 510te low
governs unless Ihe obligor is employed in onolher 5101e, in which cose Ihe law of Ihe 510le in which he or she is employed governs.
9,' Withholding Limits: You 1l10y nol withhold Illore Ihan Ihe lesser oi: 111he omounl' ollowed by Ihe Federal Consumer Credil
Proteclion ACI \15 U.S.c. 91673 (bll: or 2) Ihe amounls ollowed by Ihe 510le of Ihe employee's/obligor's principol ploce of employmenl.
The Federollimit opplies 10 Ihe oggregole dispo,,,hle weekly earnings (ADWEI. ADWE i, Ihe nel income lefl afler moking mondalory
deductions such as: State, Federal, local taxes; Social Security taxes; Jnd Medicare tJxes, For tribal orders, you may not withhold more
lhan the amounts ill lowed under the law oi the issuing tribe, For tribal employers who receive a state order, you may not withhold more
than the ,unounts aliowed under the law of the state that issued the order,
10, Additionollnfo:
'NOTE: If you or your agent are served with a copy of Ihis order in Ihe state that issued the order, you are to follow the
low af the state Ihot issued Ihis order wilh respeclla Ihesp ilems.
l1.Submittcd By:
DOMESTIC RELATIONS SECTION
13 N. HANOVEI~ ST
P.O. BOX 320
CARLISLE I'A 17013
If you or your employ,'e/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by lelephane al (7171 240-6225 or
by FAX at (7171 240-67411 or
by internet www.childsupport.slate.pa.us
Service Type M
Poge 2 af 2
Form EN.028
Worker ID $Il,TT
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
SUSAN D. BROWN ) Docket Number 99-964 CIVIL
Plaintiff )
vs. ) PACSES Case Number 088100688
JAMES M. BROWN )
Defendant ) Other State ID Numher
Order
AND NOW to wit, this
AUGUST 22, 2005
it is hereby Ordered
that:
THE DOMESTIC RELATIONS SECTION DISMISSES THEIR INTEREST IN THE ABOVE CAPTIONED
ALIMONY MATTER, PURUSANT TO THE DEMISE OF THE PLAINTIFF ON JUNE 4, 2005. THE
PACESES CASE IS CLOSED WITH A CREDIT OF $1,961.97.
DRO: RJ ShtldddY
BY THE COURT:
xc:
oetendant
Barbara Sumple-Sullivan, Esquire
Carol LindSay, Esquire
Ed_ a- ;Z~1~GE
Service Type M
Form OE-520
Worker ID 21005
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