HomeMy WebLinkAbout99-03390f
MYERL E. SEIBERT,
Plaintiff
V.
PATRICIA A. SEIBERT,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
NO. 99- 3 3 9 o CIVIL TERM
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in Court. If you wish to defend against the claims set forth in the following
pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed
without you and a decree of divorce or annulment may be entered against you by the Court. A
judgment may also be entered against you for any other claim or relief requested in these papers
by the Plaintiff. You may lose money or property or other rights important to you, including custody
or visitation of your children.
When the grounds for divorce is indignities or irretrievable breakdown of the marriage, you may
request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office
at the Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S
FEES OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY
LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (717) 249-3166
MYERL E. SEIBERT, IN TI-IE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. NO. 99- 33g0 CIVIL TERM
PATRICIA A. SEIBERT, : IN DIVORCE
Defendant
COMPLAINT UNDER SECTION 3301(C) OR (D)
OF THE DIVORCE CODE
Plaintiff, Myerl E. Seibert, by 1-tis attorney, Lindsay D. Baird, Esquire, sets forth the following:
Plaintiff, Myerl E. Seibert, is an adult individual residing at 423 Shippensburg, Road, Newville,
Cumberland County, Pennsylvania.
2
Defendant, Patricia A. Seibert, is an adult individual residing at 418 First Street, Carlisle,
Cumberland County, Pennsylvania.
3
The parties were married on November 6, 1971, in Carlisle, PA.
4
Plaintiff and Defendant have lived continuously in the Commonwealth of Pennsylvania for at least
six months prior to the commencement of this action.
5
This action is not collusive.
6
There have been no prior actions for divorce or annulment in this or any otherjurisdiction within the
knowledge of the Plaintiff.
i
i
7
In accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is
irretrievably broken.
8
Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request
that the Court require the parties to participate in counseling.
WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced
from the Defendant.
mdsay D. Baird, Esquire
Attorney for the Plaintiff
37 S. Hanover Street
Carlisle, PA 17013
717 - 243-5732
I.
I verify that to the best of my knowledge and belief, the statements made in the
foregoing document are true and correct. I understand that false statements herein are
made subject to the penalties of I8 Pa.C.S.§4904 relating to unsworn falsification to
authorities.
Myerl ugene ' ibert, Plaintiff
MYERL E. SEIBERT, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. NO. 99- CIVIL TERM
PATRICIA A. SEIBERT, IN DIVORCE
Defendant
NOTICE
If you wish to deny any of the statements set forth in this Affidavit, you must file a counter-
affidavit within twenty (20) days after this Affidavit has been served on you or the statements will
be admitted.
AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE
The parties to this action separated on or about May 1997 and have continued to
live separate and apart for a period of at least two (2) years.
2. The marriage between the parties is irretrievably broken.
I understand that I may lose rights concerning alimony, division of property, lawyers
fees or expenses if I do not claim them before a divorce is granted.
I verify that the statements made in this Affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom
falsification to authorities.
1999 ? 'fal?-_
Date T ERL E. SEIBERT, Plaintiff
MYERL E. SEIBERT,
Plaintiff
v
PATRICIA A, SEIBERT,
Defendant
COUNTER-AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE
Check either (a) or (b) :
2. Check either (a) or (b) :
_ (b) I wish to claim economic relief which may include alimony, division of
property, lawyer's fees or expenses or other important rights.
(a) I do not oppose the entry of a divorce decree.
(b) I oppose the entry of a divorce decree because
(Check (i), (ii) or both) :
(i) The parties to this action have not lived separate and apart for a period
of at least two (2) years.
(ii) The marriage is not irretrievably broken.
(a) I do not wish to make any claims for economic relief. I understand that
I may lose rights concerning alimony, division of property, lawyers's fees or
expenses if I do not claim them before a divorce is granted.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
NO. 99- CIVIL TERM
IN DIVORCE
I verify that the statements made in this counter-affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to unswom
falsification to authorities.
Date
1999
PATRICIA A SEIBERT, Defendant
NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not Nvish to
matte any claim for economic relief, you need not rile this counter-affidavit.
?^ `? A
?f `Jj '^
M .-?
i
q re
N
n
??:)
N
Q
c?
? n?,
?,:? ?.
?Eid
?' ?
? r
CIS2
O
m U
? v
Q
r 4
??
MYERL E. SEIBERT,
Plaintiff
V.
PATRICIA A. SEIBERT,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
NO.99- 3SgO CIVIL TERM
IN DIVORCE
COUNTER-AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE
1. Check either (a) or (b) :
(a) I do not oppose the entry of a divorce decree.
(b) I oppose the entry of a divorce decree because
(Check (i), (ii) or both) :
(i) The parties to this action have not lived separate and apart for a period
of at least two (2) years.
(ii) The marriage is not irretrievably broken.
2. Check either (a) or (b) :
(a) I do not wish to make any claims for economic relief. I understand that
I may lose rights concerning alimony, division of property, lawyers's fees or
expenses if I do not claim them before a divorce is granted.
(b) I wish to claim economic relief which may include alimony, division of
property, lawyer's fees or expenses or other important rights.
I verify that the statements made in this counter-affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to unswom
falsification to authorities.
111 , 1999 zzz"
Date PA RICIA A EIBERT, Defendant
NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to
make any claim for economic relief, you need not file this counter-affidavit.
.:%
^-
i ?
P:
r 1.=:
UJ--
U
°" iJ ??
?.?.. .: G'.. 'l ?l
O ?-• r
i.7
??'; -7
1_ ? ..:.
i.
V C,l
(]? :J
U
MYERL EUGENE SEIBERT,
Plaintiff
V.
PATRICIA A. SEIBERT,
Defendant
To: Curtis Long, Prothonotary
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
NO. 99- 3390 CIVIL TERM
IN DIVORCE
PRAECIPE
Ott rl'G
Please do not the above outstanding civil case on October 22, 2002. The
parties in this case are currently working toward the resolution of outstanding issues in
their settlement.
Respectfully submitted,
Dated: October 17, 2002
!ndsay D. Baird Esquire
Attorney for the -Plaintiff
37 South Hanover Street
Carlisle, PA 17013
(717) 243-5732
i c a,
r ,
U U
MYERL E. SEIBERT, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
PATRICIA A. SEIBERT,
Defendant No. 99-3390 CIVIL TERM
ORDER OF COURT
AND NOW, this 22nd day of October, 2002, it
appearing that docket activity has occurred recently in the
above-captioned case, the case is stricken from the purge
list, and shall remain active.
By the Court,
Lindsay Dare Baird, Esquir
For the Plaintiff
Patricia A. Seibert
418 First Street
Carlisle, PA 17013
Defendant
Court Administrator
wcy
1 Cn
". W'esley 016r,) Jr., J.
e
h o k ce' 11w (.LeL-
I(-(q( -4 -flie
JR.)
_ 1
?. i {: ?
?..\/
?•t?i. .. ,• 1? 1
?"?_1 .? . _ i•1 .?, ???i ??•?
MYLR L ? . SE i BERT
V5
p?Rl (,1 ? A, SEI BER l
?°?-330
Case No.
Statement of Intention to Proceed
To the Court: ?"
?,-Tg wf t Su pF-R' ` intends to pros c wi t th ab ve c psi t d natter.
Q?u?. R .
Print Name_ OR R Sign Name
Date: 1 Q ?? Attorney for lJJerh14+1 Ni0t " . ? G ? ( 41
Explanatory Comment
The Supreme Court of Pennsylvania has promulgated new Rule of Civil Procedure 230.2 governing the termination of
inactive cases and amended Rule of Judicial Administration 1901. Two aspects of the recommendation merit
comment.
1. Rule ofcivil Procedure
New Rule of Civil Procedure 230.2 has been promulgated to govern the termination of inactive cases within the
scope of the Pennsylvania Rules of Civil Procedure. The terntinationof these cases for inactivity was previously
governed by Rule of Judicial Administration 1901 and local rules promulgated pursuant to it. New Rule 230.2 is
tailored to the needs of civil actions. It provides a complete procedure and a uniform statewide practice, preempting
local rules.
This rule was promulgated in response to the decision of the Supreme Court in Shop v. Eagle, 551 Pa. 360,710 A.2d
1104 (1998) in which the court held that "prejudice to the defendant as a result of delay in prosecution is required
before a case may be dismissed pursuant to local rules implementing Rule of Judicial Administration 1901"
Rule of Judicial Administration 1901(b) has been amended to accommodate the new rule of civil procedure. The
general policy of the prompt disposition of matters set fonh in subdivision (a) of that rule continues to be applicable.
II Inactive Cases
The purpose of Rule 230.2 is to eliminate inactive cases from the judicial system. The process is initiated by the
court. After giving notice of intent to terminate an action for inactivity, the course of the procedure is with the parties.
If the patties do not wish to pursue the case, they will take no action and "the prothonotary shall enter an order as of
course temminatiug the matter with prejudice for failure to prosecute." if a puny wishes to pursue the matter, he or she
will file a notice of intention to proceed and the action shall continue,
a. Where the action has bear rera:iuaad
If the action is terminated when a party believes that it should not have been terminated, that party may proceed
under Rulc230(d) for relief from the order of termination. An example of such an occurrence might be the termination
of a viable action when the aggrieved party did not receive the notice of intent to terminate and thus did not timely file
the notice of intention to proceed
The timing of the filing of the petition to reinstate the action is important. If the petition is filed within thirty days of
the entry of the order of termination on the docket, subdivision (d)(2) provides that the court must grant the petition and
reinstate the action. If the petition is filed later than the thirty-day period, subdivision (d)(3) requires that the plaintiff
must make a show in to the court that the petition was promptly filed and that there is a reasonable explanation or
legitimate excuse Ixuh for the failure to file the notice of intention to proceed prior to the entry of the order of
termination on the docket and for the failure to file the petition within the shiny-day period under subdivision (d)(2).
B. Where the action has nor been terminated
An action which has not been terminated but e'hich continues upon the filing of a notice of intention to proceed may
have been the subject of inordinate delay. In such an instance, the aggrieved party may pursue the remedy of a
common law non pros which exits independently of tennination under Rule 230.2.
a
G-iu
o
O
o U
NOY 0 2 2007,4
MYERL E. SEIBERT, : IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
PATRICIA A. SEIBERT, NO.99-3390 CIVIL TERM
Defendant/Petitioner IN DIVORCE
QUALIFIED DOMESTIC RELATIONS ORDER FOR INTERNATIONAL
PAINTERS AND ALLIED TRADES INDUSTRY PENSION FUND
This Order is intended to be a Qualified Domestic Relations Order ("QDRO"), as
that term is defined in section 206(d) of the Employee Retirement Income Security Act
of 1974 ("ERISA"), 29 U.S.C. §1056(d) and section 414(p) of the Internal Revenue
Code of 1986 ("Code"), 26 U.S.C. §414(p). This QDRO is granted in accordance with
(applicable state domestic relations law citations), which related to marital property
rights, child support, and/or spousal support between spouses and former spouses in
matrimonial actions.
SECTION 1. IDENTIFICATION OF PLAN
This Order applies to benefits under the International Painters and Allies Trades
Industry Pension Fund ("Plan"). The Board of Trustees is the Plan Administer of the
Plan for purposes of ERISA. This Order shall be served upon the Plan at 1750 New
York Avenue, N.W., Suite 501, Washington, DC 20006-5387, Attn: Gary J. Meyers,
Administrator, for a determination of its status as a Qualified Domestic Relations Order
under 29 U.S.C. §1056(d)(3).
SECTION 2. IDENTIFICATION OF PARTICIPANT AND ALTERNATE PAYEES
a. Myerl E. Seibert is referred to as the "Participant". The Participant's
address is 111 Regency Woods North, Carlisle, Pennsylvania 17015. The Participant's
Social Security Number is 169-44-6747. The Participant's date of birth is July 30, 1952.
The Participant is not receiving benefits with respect to this Plan.
b. Patricia A. Seibert is referred to as the "Alternate Payee". The Alternate
Payee's address is 418 First Street, Carlisle, Pennsylvania 17013. The Alternate
Payee's Social Security Number is 182-46-1665. The Alternate Payee's date of birth is
May 28, 1955. The Alternate Payee is the spouse of the Participate.
SECTION 3. AMOUNT OF BENEFIT TO BE PAID TO ALTERNATE PAYEE
Starting at the time specified in section 5, the Plan shall pay to the Alternate
Payee an amount actually equivalent to the value of 30% of the Participant's accrued
benefit under the actuarial assumptions used by the Plan. The Participant's accrued
benefit shall be determined as of date of Divorce.
Page 1 of 5
4
SECTION 4. ACTUARIAL ADJUSTMENTS
The Plan may adjust the amounts payable to Participant or Alternate Payee to
assure that the total benefits paid to Participant, Alternate Payee and any Contingent
Alternate Payee under this Order do not have an actuarial value in excess of the
actuarial value of the benefits the Participant and a spouse or beneficiaries otherwise
would receive under the Plan and ERISA. All adjustments shall be calculated using the
actuarial assumptions of the Plan except as otherwise provided by applicable law,
including the Code. If the Plan adjusts the Participant's benefit after it approves this
Order, any reduction shall be applied by decreasing pro rata the Participant's and the
Alternate Payee's benefits/the value of the Participant's remaining accrued
benefit first/the value of the Alternate payee's interest first/specify another way.
Any increase shall be applied by increasing pro rata the Participant's and the
Alternate Payee's benefits/the value of the Participant's remaining accrued
benefit first/ the value of the Alternate Payee's separate interest first/specify
another way.
SECTION 5. START OF PAYMENTS TO ALTERNATE PAYEE
The Plan shall start payments to the Alternate Payee on at or after the earliest
retirement date of Participant under 29 U.S.C. §1056(d)(3)(E)(ii) under Plan payment
procedures including submission of a property completed application. The payments
shall be based upon employment from May 1979 until June 1997.
SECTION 6. END OF PAYMENTS TO ALTERNATE PAYEE
The Plan shall stop payments to the Alternate Payee at the death of Alternate
Payee.
SECTION 7. FORM OF PAYMENT
a. With respect to any payments after Participant retires, benefits shall be
paid in any form chosen by Participant which is not inconsistent with the term and
amount of payments to Alternate Payee required under this Order.
b. If Alternate Payee may and does elect payment before Participant retires,
the benefits payable to Alternate Payee shall be calculated as if the Participant
then retired with a joint & 50% survivor annuity for Participant and Alternate
Payee under the Plan based only on benefits actually accrued and without taking
into account any early retirement subsidy or supplement.
C. If the Participant subsequently retires, the benefit shall not be recalculated
so that the Alternate Payee also receives the amount paid before the Participant
retired and 30% of early retirement subsidy or supplement.
d. If a different form of payment is necessary to allow payment to Alternate
Payee at the time and in the amounts specified elsewhere in this Order, the Plan
shall treat this Order as an election of that form and adjust payments to
Page 2 of 5
2
Participant, Alternate Payee and any Contingent Alternate Payee accordingly.
SECTION 8. DEATH OF PARTICIPANT
Notwithstanding anything else in this Order, payments under this Order will stop
at the death of Participant except as to death benefits under the Plan, payment to an
Alternate Payee who is a spouse entitled to receive payment for the balance f her life or
payment to an Alternate Payee of Contingent Alternate Payee over a period certain
allowed by the Plan under this Order. If Alternate Payee is a surviving spouse who is to
be paid for her life after the death of Participant under a joint and survivor form of
payment, Alternate Payee shall continue to be treated as the Spouse of Participant with
respect to amounts payable under this Order.
SECTION 9. DEATH OF ALTERNATE PAYEE
a. If Alternate Payee dies before commencing benefits and section 2 of this
Order does not provide for an eligible Contingent Alternate Payee on the
Alternate Payee's death, the Alternate Payee's separate interest shall revert to
the Participant.
SECTION 10. SPOUSAL RIGHTS OF FORMER SPOUSE AS ALTERNATE PAYEE
If Participant dies before commencing benefits, and has no surviving spouse or
designated beneficiary at the time, Alternate Payee have the rights set forth below:
a. The Plan shall treat the Alternate Payee as the Participant's spouse for
purposes of the Participant's survivor annuity resulting from the accrued benefit
which remains with the Participant. The Alternate Payee's right to the spousal
survivor annuity shall apply to 50% of the survivor annuity resulting from the
accrued benefit which remains with the Participant.
b. the Plan shall treat the Alternate Payee as the Participant's spouse for
purposes of the Participant's pre-retirement survivor annuity resulting from the
accrued benefit in which the Participant retains a separate interest. The
Alternate Payee's right to the spousal pre-retirement survivor annuity shall apply
to 50% of the pre-retirement survivor annuity resulting from the accrued benefit
which remains with the Participant.
C. If Participant dies before commencing benefits and has no surviving
spouse or designated beneficiary at the time, the Plan Shall treat the Alternate
Payee as the Participant's beneficiary for purposes of any death benefit payable
on the death of Participant. The Alternate Payee's right to the death benefit shall
apply to 50% of the death benefit resulting from the accrued benefit which
remains with the Participant.
Page 3 of 5
SECTION 11. TAXES
Any payment under this Order to an Alternate Payee who is a spouse or
former spouse of Participant shall be reported and taxed as income to the Alternate
Payee rather than the Participant.
SECTION 12. COMPLIANCE WITH APPLICABLE LAWS
The parties to this Order intend that it comply with applicable provisions of ERISA
and the Code. Nothing in this Order shall require the Plan:
a. To pay any benefits not permitted under Code or ERISA;
b. To provide any type or form of benefit or any option not provided by the
Plan;
C. To pay total benefits with a value in excess of the value of the benefits the
Participant, Alternate Payee or any Contingent Alternate Payee otherwise would
receive under the Plan and ERISA in the absence of a divorce; or
d. To pay benefits to the Alternate Payee that are required to be paid to
another alternate payee under another QDRO that is in effect prior to this Order.
SECTION 13. RESERVATION OF JURISDICTION
The Court reserves jurisdiction to amend this Order to establish or maintain its status as
a QDRO under ERISA and the Code.
IT IS SO ORDERED:
_.,y hand
and the sue`""our ie, Pa.
This u ........
...........................
A Prothon
Mjre . Seibert, Participa
Y
tricia A. eib , Alternate Payee
Page 4 of 5 4
3"p'1
Date:
s.
1INVAlASNN3d
AiNnC,,! r r. n #3 iht?J
9 C -.01 WV £ I AON LODZ
AbViC3i` OHi d 3M Jo
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ON THIS, the 11"day of a4()hj-X , 2007, before me, the undersigned
officer, personally appeared Myerl E. Seibert, known to me (or satisfactorily proven)
to be the person whose name is subscribed to the within instrument, and acknowledged
that they executed the same for the purposes therein contained.
IN WITNESS WHEREOF, i hereunto set my hand and official seal.
-"
RMPILWOM
Mdov %uft f? (,-? "I J L
W w z ,zoio Ro in L. Sta , Notary Public
WW
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ON THIS, the day of (?C ?rbkk, , 2007, before me, the undersigned
officer, personally appeared Patricia A. Seibert, known to me (or satisfactorily proven)
to be the person whose name is subscribed to the within instrument, and acknowledged
that they executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
NOMM sE/IL
ROM L SWOM
Notary 1rbNc
CARLISLE 9M000FI, CUM MOM COMM
My COIfMflI W Dow Jw 27, =
3 1
?jl Robin L. Star , Notary Public
Page 5 of 5 5
?'?lfllit??li
YTOUOO 00,140 °tutit
_ Oros .tt nut, tt3,8.190POS 3,',etjgAl
px3 ?? vm
JIBE .t1RiA=. r:,v,
A?lS;,sF? J vi?BG?A
alldu4 y?eai?stl
010S tS ntA, Miigx3 xs tlmma yM
MYERL E. SEIBERT,
Plaintiff
V.
PATRICIA A. SEIBERT,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-3390 CIVIL TERM
IN DIVORCE
ACCEPTANCE OF SERVICE
I hereby accept service of the Complaint in Divorce on behalf of the Defendant,
Patricia A. Seibert, in the above-captioned a,Qtion and I certify tha"am authorized to do
so.
DATE: June 29, 1999 By:
Paul Bradford Orr, Esquire
Attorney for Defendant
?.? 1i ?•}
?
y
?.?X
"r
1 ?
.k ;
???
IA
??""; L _.
MYERL E. SEIBERT, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION -LAW
PATRICIA A. SEIBERT, NO.99-3390 CIVIL TERM
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) or (d) of the Divorce Code was
filed on June 4, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing and service of the Complaint.
3. 1 consent to the entry of a final decree of 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. 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: k`?b erl E. Seibert, Plaintiff
1
__i."
`
C C f
?
.. rd ,
MYERL E. SEIBERT, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
PATRICIA A. SEIBERT, NO.99-3390 CIVIL TERM
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) or (d) of the Divorce Code was
filed on June 4, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing and service of the Complaint.
3. 1 consent to the entry of a final decree of 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. 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: Mo `
atricia A. eibert, Defendant
L
c?
MYERL E. SEIBERT,
Plaintiff
V.
PATRICIA A. SEIBERT,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO.99-3390 CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER § 3301(c) & (d) OF THE DIVORCE CODE
1. 1 consent to the entry of a final decree of divorce without notice.
2. 1 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. 1 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. 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: 11156)07 / 4z4_
Pa icia . Seibert, Defendant
? f
r
F
?' ?
v
. ?: r
.) ?
.,
? .-'
j
??
? ?
'
?^ ??
??
MYERL E. SEIBERT,
Plaintiff
V.
PATRICIA A. SEIBERT,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
NO.99-3390 CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER § 3301(c) & (d) OF THE DIVORCE CODE
1. 1 consent to the entry of a final decree of divorce without notice.
2. 1 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. 1 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. 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: 11 J30)0-7 G
Myerl E. Seibe , Plaintiff
c? ?.
?J
xL ?j T _.
,,?'
C; ?.,.-
? t , ".' ,
v??_ ?
?,
?-- ?'"
???
MYERL E. SEIBERT,
Plaintiff
V.
PATRICIA A. SEIBERT,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
NO. 99-3390 CIVIL TERM
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the Court for entry of
a divorce decree:
1. Ground for divorce: irretrievable breakdown under Section 3301(c) or (d) of
the Divorce Code.
2. Date and manner of service of the complaint: June 29, 1999, via First Class
Mail to Attorney Paul Bradford Orr.
3. Date of execution of the affidavit of consent required by Section 3301(c) &
(d) of the Divorce Code: by the Plaintiff on November 30, 2007; by Defendant on
November 30, 2007.
4. Related claims pending: NONE
5. Date Plaintiff's Waiver of Notice in §3301(c) & (d) Divorce was filed with the
Prothonotary: November 30, 2007.
6. Date Defendant's Waiver of Notice in §3301(c) & (d) Divorce was filed with
the Prothonotary: November 30, 2007.
JIT' By: PS 014
Date: I I I
Paul Bradford Orr, Esquire
50 East High Street
Carlisle, PA 17013
(717) 258-8558
r-7
S1
r ?Y
NOV D 81007
MYERL E. SEIBERT, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION -LAW
PATRICIA A. SEIBERT, : NO.99-3390 CIVIL TERM
Defendant/Petitioner : IN DIVORCE
QUALIFIED DOMESTIC RELATIONS ORDER FOR INTERNATIONAL
PAINTERS AND ALLIED TRADES INDUSTRY PENSION FUND
This Order is intended to be, a Qualified Domestic Relations Order ("QDRO"), as
that term is defined in section 206(d) of the Employee Retirement Income Security Act.
of 1974 ("ERISA"), 29 U.S.C. §1056(d) and section 414(p) of the Internal Revenue
Code of 1986 ("Code"), 26 U.S.C. §414(p). This QDRO is granted in accordance with
(applicable state domestic relations law citations), which related to marital property-
rights, child support, and/or spousal support between spouses and former spouses in
matrimonial actions.
SECTION 1. IDENTIFICATION OF PLAN
This Order applies to benefits under the International Painters and Allies Trades
Industry Pension Fund ("Plan"). The Board of Trustees is the Plan Administer of the
Plan for purposes of ERISA. This Order shall be served upon the Plan at 1750 New
York Avenue, N.W., Suite 501, Washington, DC 20006-5387, Attn: Gary J. Meyers,
Administrator, for a determination of its status as a Qualified Domestic Relations Order
under 29 U.S.C. §1056(d)(3).
SECTION 2. IDENTIFICATION OF PARTICIPANT AND ALTERNATE PAYEES
CURTIS R. LONG
Prothonotary
i Cumberland County
One Courthouse Square
Carlisle, PA 17013
O THE I rK ?rc'C'N0TA;RY
70,07 NOV 26 PM 8: 30
vi
Mr. Myerl E. Seibert
423 Shippensburg Road
Newville, PP 177d1
NIXIE
A 9 If 0--n-
' ? ®wnarv
02 1A $ 00.58
0004631598 NOV15 20(
MAILED FROM ZIPCODE 1 701
vKr
171 CE 1 25 11J10/07
RETURN TO SENDER
INSUFFICIENT ADDRESS
UNAOLE TO FORWARD
:-49 Y y r ??.?•
JS
SC: 17013
*0119-00900-13-41
IN THE. COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
190
STATE OF PENNA.
MYERL E. SEIBERT,
No. 3390 of 1999
Plaintiff
VERSUS
PATRICIA A. SEIBERT,
Defendant
DECREE IN
DIVORCE
AND NOW,
lJtcewtbvr 116
2007, IT IS ORDERED AND
DECREED THAT MYERL E. SEIBERT
AND PATRICIA A. SEIBERT
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
, PLAINTIFF,
,DEFENDANT,
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
BY THE COURT:
PROTHONOTARY
---2 ?O- - el