HomeMy WebLinkAbout99-04198CJ
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
ROSE MARY WADIINGER
11 No. Q9_41QR riv;1 Term-
VERSUS
EDWARD F. WADLINGER
DECREE IN
DIVORCE
AND NOW, Nov"-4u. .Z/ , 7(101 , IT IS ORDERED AND
DECREED THAT ROSE MARY WADLINGER PLAINTIFF,
EDWARD F. WADLINGER
AND DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED; None,
The terms of the Separation and Property Settlement Agreement dated
October 26, 2001, are incorporated, but not merged, with this
Divorce Decree and are encorceable pursuant to 21 Pa§ 3105.
BY THE C RT:
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PROTHONOTARY
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SEPARATION AND PROPERTY SETTLEMENT AGREEMENT
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This Agreement, made this 4 day of Dafo bev 2001, by and
between EDWARD F. WADLINGER, of Mechanicsburg, Cumberland County,
Pennsylvania, hereinafter referred to as "Husband," and ROSE MARY
WADLINGER, of Lemoyne, Cumberland County, Pennsylvania, hereinafter
referred to as "Wife."
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on August 24, 1974,
at Harrisburg, Dauphin County, Pennsylvania; and
WHEREAS, there were two (2) children born of the marriage, both of whom
are emancipated; and
WHEREAS, the parties separated April 8, 1997; and
WHEREAS, certain differences have arisen between the parties, as a result of
which they have decided to separate, and are desirous therefore of entering into an
Agreement which will distribute their marital property in a manner which is
equitable and will provide for their mutual responsibilities and rights growing out of
the marriage relationship; and
WHEREAS, the parties hereto, after being properly advised by counsel, or
having had the opportunity of being properly advised by counsel, understand the
legal impact of this Agreement and execute this Agreement intending to be legally
bound by the terms of this Agreement.
NOW, THEREFORE, in consideration of the above recitals and the following
covenants and promises mutually made and mutually to be kept, the parties
heretofore, intending to be legally bound and to legally bind their heirs, successors
and assigns thereby, covenant, promise and agree as follows:
1. SEPARATION: The parties agree to live separate and apart from one
another at such places as he or she may from time to time choose or deem fit.
2. INTERFERENCE: Each party shall be fi•ee from intereference, authority
and contact by the other, as fully as if he or she were single and unmarried, except
as may be necessary to carry out the provisions of this Agreement. Neither party
shall molest the other nor attempt to endeavor to molest the other, nor compel the
other to cohabit with the other, nor in any way interfere with the peaceful existence,
separate and apart from the other.
3. WIFE'S DEBTS: Wife represents and warrants to Husband that since the
date of this Agreement she has now, and in the future she will not, contract or incur
any debt or liability for which Husband or his Estate might be responsible and shall
indemnify and save Husband harmless for any and all claims or demands made
against him by reason of debts or obligations incurred by her.
4. HUSBAND'S DEBTS: Husband represents and warrants to Wife that
since the date of this Agreement he has not, and in the future he will not, contract or
incur any debt or liability for which Wife or her Estate might be responsible and
shall indermnify and save Wife harmless from any and all claims or demands made
against her by reason of debts or obligations incurred by him.
5. MUTUAL RELEASE: Subject to the provisions of this Agreement,
each party waives his or her right to alimony and any further distribution of property
inasmuch as the parties hereto agree that this Agreement provides for an equitable
distribution of their marital property in accordance with the Divorce Code of 1980.
Subject to the provisions of this Agreement, each party has released and discharged,
and by this Agreement does for himself or herself, and his or her heirs, legal
representatives, executors, administrators and assigns, release and discharge the
other of and from all causes of action, claims, rights or demands whatsoever in law
or equity, which either of the parties ever had or now has against the other, except
any or all cause or causes of action for divorce and except in any or all causes of
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action for breach of any provisions of this Agreement. Each party also waives their
right to request marital counseling pursuant to Section 202 of the Divorce Code.
6. E UITABLE DISTRIBU'T'ION OF MARITAL PROPERTY: The
parties have attempted to distribute their marital property in a manner which
conforms to the criteria set forth in Section 401 of the Pennsylvania Divorce Code,
and taking into account the following considerations: the length of the marriage; the
fact that it is the Wife's first marriage and the Husband's first marriage; the age,
health, station, amount and sources of income, vocational skills, employability,
estate, liabilities and needs of each of the parties; the contribution of each party to
the education, training or increased earning power of the other party; the opportunity
of each party for future acquisitions of capital assets and income; the sources of
income of both parties, including but not limited to medical, retirement, insurance or
other benefits; the contribution or dissipation of each party in the acquisition,
preservation, depreciation or appreciation of the marital property, including the
contribution of each spouse as a homemaker; the value of the property set apart to
each party; the standard of living of the parties established during the marriage; and
the economic circumstances of each party at the time the division of property is to
become effective.
The division of existing marital property is not intended by the parties to
constitute in any way a sale or exchange of assets; and the division is being effected
without the introduction of outside funds or other property not constituting marital
property. The division of property under this Agreement shall be in full satisfaction
of all marital rights of the parties.
A. MARITAL HOME: The parties hereto mutually agree that the marital
home was subject to a foreclosure and disposition was made pursuant to said
foreclosure. Sheriff's Sale occurred on or about June 7, 2000, at which time both
parties were dispossessed of any right, title and interest in said property.
Each party waives, releases and discharges against the other any claim for
mortgage contributions, dissipation of marital assets, tax contributions and/or
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insurance contributions, as a result of said foreclosure, it being the intent of the
parties that each waives, releases and relinquishes any and all claim or cause of
action as against the other on account of said foreclosure.
Wife expressly waives her claim for rental value of said marital home during
the time that the Husband resided there after separation.
B. PERSONAL PROPERTY: The parties hereto agree that the remaining
personal property accumulated during the marriage has been or will be satisfactorily
divided between the parties. Each party agrees that upon receipt and possession of
said items of personal property that that personal property will become the sole and
exclusive property of the person in whose possession the property is vested.
The parties agree to release, relinquish and discharge any and all right, title
and interest in the property in the other's possession.
7. ALIMONY: Husband and Wife agree that both parties shall waive now
and forever any and all claim, cause of action or alimony as against the other.
The parties acknowledge that currently the Husband is paying alimony
pendente lite through the Court of Common Pleas of Cumberland County,
Pennsylvania at Docket No. 99-4198.
The parties agree that upon the execution of this Agreement, Wife shall
terminate the alimony pendente lite claim and that Husband and Wife both agree
that each waives as against the other any claim for spousal support or alimony
pendente lite.
The parties agree that an Order for APL was entered at No. 99-4198 Civil for
alimony pendente lite to which the Husband filed an appeal. The parties agree that
Husband shall withdraw that appeal and that Wife is entitled to payments under that
Order up to and including the date of the execution of this Agreement.
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8. WAIVERS OF CLAIMS AGAINST ESTATES: Except as herein
otherwise provided, each parry may dispose of his or her property in any way, and
each party hereby waives and relinquishes any and all rights he or she may now
have or hereafter acquire, under the present or future laws of any jurisdiction, to
share in the property or the estate of the other as a result of the marital relationship,
including without limitation, dower, curtesy, statutory allowance, widow's
allowance, right to take in intestacy, right to take against the Will of the other, and
right to act as administrator or executor of the other's estate, and each will, at the
request of the other, execute, acknowledge and deliver any and all instruments
which may be necessary or advisable to carry into effect this mutual waiver and
relinquishment of all such interests, rights and claims.
9. SUBSEQUENT DIVORCE: Wife has filed a complaint in divorce in
Cumberland County at No. 99-4198 Civil. Husband and Wife each agree to sign an
affidavit of consent and an affidavit waiving counseling to be filed in said divorce
action. In the event such divorce action is concluded, Husband shall be entitled to
receive a copy of the Decree in Divorce for the normal fee charged (to be paid by
Husband) by the Prothonotary and shall not be assessed any costs of the proceeding.
In the event such divorce action is concluded, the parties shall be bound by all the
terms of this Agreement, which shall be incorporated by reference, but not merged,
into the Divorce Decree, but shall in all respects survive the same and be forever
binding and conclusive upon the parties.
10. BREACH: If either party breaches any provision of this Agreement, the
other party shall have the right, at his or her election, to sue for damages for such
breach, or seek such other remedies or relief as may be available to him or her, and
the party breaching the contract shall be responsible for payment of legal fees and
costs incurred by the other in enforcing his or her rights under this Agreement
whether the result is obtained by litigation or amicable resolution.
11. ADDITIONAL INSTRUMENTS: Each of the parties shall from time
to time, at the request of the other, execute, acknowledge and deliver to the other
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Party any and all further instruments that may be reasonably required to give full
force and effect to the provisions of this Agreement.
12. VOLUNTARY EXECUTION: Husband and Wife acknowledge the
provisions of this Agreement are fully understood by both parties, Each party
acknowledges that the Agreement is in all respects fair and equitable, and it is
entered into voluntarily and knowingly, and not as the result of any duress or undue
influence.
13. ENTIRE AGREEMENT: This Agreement contains the entire
understanding of the parties and there are no representations, warranties, covenants
or undertakings other than those expressly set forth herein. Husband and Wife
acknowledge and agree that the provisions of this Agreement with respect to the
distribution and division of marital and separate property are fair, equitable and
satisfactory to them based upon the length of their marriage and other relevant
factors which have been taken into consideration by the parties. Both parties hereby
accept the provisions of this Agreement with respect to the division of property in
lieu of and in full and final settlement and satisfaction of all claims and demands that
they may now have or hereafter have against the other for equitable distribution of
their property by any court of competent jurisdiction pursuant to Section 401(d) of
the Divorce Code or any other laws. Husband and Wife each voluntarily and
intelligently waive and relinquish any right to seek a court order determination and
distribution of marital property, but nothing herein contained shall constitute a
waiver by either party of any rights to seek the relief of any court for the purpose of
enforcing the provisions of this Agreement.
14. DISCLOSURE: Husband and Wife each represent and warrant to the
other that he or she has made a full and complete disclosure to the other of all assets
of any nature whatsoever in which such party has in interest, the sources and
amount of the income of such party of every type whatsoever and of all other facts
relating to the subject matter of this Agreement.
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15. MODIFICATION AND WAIVER: A modification or waiver of any of
the provisions of this Agreement shall be effective only if made in writing and
executed with the same formality as this Agreement. The failure of either party to
insist upon strict performance of any of the provisions of this Agreement shall not be
construed as a waiver of any subsequent default of the same or similar nature.
16. DESCRIPTIVE HEADINGS: The descriptive headings used herein
are for convenience only. They shall have no effect whatsoever in determining the
rights or obligations of the parties.
17. INDEPENDENT SEPARATE COVENANTS: It is specifically
understood and agreed by and between the parties hereto that each paragraph hereof
shall be deemed to be a separate and independent covenant and agreement.
18. APPLICABLE LAW: This Agreement shall be construed under the
laws of the Commonwealth of Pennsylvania.
19. VOID CLAUSES: If any teen, condition, clause or provision of this
Agreement shall be determined or declared to be void or invalid in law or otherwise,
then only that term, condition, clause or provision shall be stricken from this
Agreement and in all other respects this Agreement shall be valid and continue in
full force, effect and operation.
20. AGREEMENT BINDING ON HEIRS: This Agreement shall be
binding and shall inure to the benefit of the parties hereto and their respective heirs,
executors, administrators, successors and assigns.
21. PENSION/RETIREMENT: Husband and Wife agree that the pension
of Husband shall be divided pursuant to a QDRO which shall be prepared by
Pension Appraisers, Inc.
The parties currently maintain an escrow account that represents a
reimbursement of monies, including taxes on the marital home, and from that escrow
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account, sums necessary for Pension Appraisers, Inc. to prepare a QDRO shall be
paid.
The balance of the escrow account shall be divided equally between the
parties.
The terns of the QDRO shall provide Wife with a fifty (50%) percent share
of the benefit Husband receives upon retirement multiplied by the fraction of the
years of service as the denominator over the years of marriage the numerator.
Husband and Wife agree that Wife's pension shall remain her sole and
exclusive property and that Husband relinquishes any claim, right, title or interest to
Wife's pension.
22. AUTOMOBILES: Husband and Wife agree that the automobile in the
possession of the party shall remain the automobile of that party, and each party
agrees to execute the necessary titles to provide the same.
IN WITNESS WHEREOF, the parties hereto have had the opportunity to
review this Agreement with legal counsel, and after having the opportunity to review
this Agreement with legal counsel, intending to be legally bound, have set their
hands and seals the day and year first above written.
Edward F. Wadlinger
Rose Mary i
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ?lUw??G!/I?C SS.
BE IT REMEMBERED that on th day of90 2001,
before me the subscriber personally appeared E WARD F. WADLINGER,
known to me (or satisfactorily proven) to be the person(s) whose name is subscribed
to the within Agreement and acknowledged that he executed the same for the
purposes therein contained.
WITNESS my h and seal the day and year aforesaid.
MARY NOTA131AL SEAL
THC:gFSA ?ATCS Notary Publla
Pay Ibmn°°r Twa.. UnuPh°1 County. PA
My Cn?ur?s Au A
Sus 'u. 2rrz
COMMONWEALTH OF PENNSYLVANIA
SS.
COUNTY OF&" ,6e,,},&,WL
BE IT REMEMBERED that on the /7#-day of lath54ek- , 2001,
before me the subscriber personally appeared ROSE MARY WADLINGER,
known to me (or satisfactorily proven) to be the person(s) whose name is subscribed
to the within Agreement and acknowledged that she executed the same for the
purposes therein contained.
WITNESS my hand and seal the day and year aforesaid.
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ROSE MARY WADLINGER, IN THE COURT OF COMMON PLEAS
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
V. No.99-4198 Civil Term
EDWARD F. WADLINGER, CIVIL ACTION - LAW
Defendant. DIVORCE
PRAECiPE TO TRANSMIT RECORD
To the Prothonotary:
Kindly transmit the record, together with the following information, to the court for entry of
a divorce decree:
Ground for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code
2. Date and manner of service of the Complaint: July 27, 1999 via United States mail,
postage prepaid and United States mail Certified Mail, Delivery Restricted to Addressee only.
3.
(a) Date of execution of the affidavit of consent required by § 3301(c) of the
Divorce Code: by Plaintiff October 17, 2001.
(b) Date of execution of the affidavit of consent required by § 3301(c) of the
Divorce Code: by Defendant October 26, 2001.
4. Related claims pending: none. The Settlement and Property Settlement Agreement
dated October 26, 2001 resolved all claims.
5.
(a) Date plaintiffs Waiver of Notice in § 3301(c) Divorce was filed with the
Prothonotary: November 6, 2001.
(b) Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the
Prothonotary: November 6, 2001.
6. (a) Defendant's social security number is: 175-40-6934.
(b) Plaintiffs social security number is : 191-42-7808.
Respectfully
, la
Date: r /
Melissa Peel Greevy, Esquire
I.D. No. 77950
214 Senate Avenue Suite 105
Camp Hill, PA 17011-2336
(717) 763-8995
Attorney for the Plaintiff
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ROSE MARY WADLINGER,
Plaintiff,
V.
EDWARD F. WADLINGER,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND
??COUNTY, PENNSYLVANIA
No. 99-. '119 _ 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
foregoing pages, you must take prompt action. You are warned that if you fail to do so, the case
may proceed without you and a decree in divorce or annulment may be entered against you by the
court. 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 other property or other rights important to
you, including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the Office of
the Prothonotary at:
Office of the Prothonotary
Cumberland County Court House
Carlisle, Pennsylvania 17013
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
ROSE MARY WADLINGER,
Plaintiff,
V.
EDWARD F. WADLINGER,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99- J19,P CIVIL TERM
IN DIVORCE
NOTICE OF AVAILABILITY OF O IN E fN
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed in
the Court of Common Pleas of Cumberland County. This notice is to advise you that in
accordance with Section 3302(d) of the Divorce Code, you may request that the court require you
and your spouse to attend marriage counseling prior to a divorce being handed down by the court.
A list of professional marriage counselors is available at the Domestic Relations Office, 13 North
Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to
you and you are not bound to choose a counselor from this list. All necessary arrangements and
the cost of counseling sessions are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling within
twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver
of your right to request counseling.
ROSE MARY WADLINGER,
Plaintiff,
V.
EDWARD F. WADLINGER,
Defendant,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99- LI CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE UNDER § 3301 (c) or § 3301(d) OF THE DIVORCE CODE
AND NOW, comes the Plaintiff, Rose Mary Wadlinger, by and through her attorney,
Melissa Peel Greevy, Esquire, respectfully represents:
The Plaintiff is Rose Mary Wadlinger, residing at 364A Market Street, Lemoyne,
Cumberland County, Pennsylvania. Plaintiff's Social Security Number is 191-42-7808.
2. The Defendant is Edward F. Wadlinger, residing at 217 Indian Creek Drive,
Mechanicsburg, Cumberland County, Pennsylvania. Defendant's Social Security Number is
175-40-6934.
3. Plaintiff and Defendant have both been bona fide residents of the Commonwealth
of Pennsylvania for a period of more than six months immediately preceding the filing of this
Complaint.
4. The parties were married on August 24, 1974, in Harrisburg, Dauphin County,
Pennsylvania.
5. The parties were separated on April 8, 1997.
6. There is one minor child of the marriage:
Bom: October 14, 1981 Age 17.
Theresa Lynn Wadlinger
7. Neither Plaintiff nor Defendant is in the military or naval service of the United
States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the
Congress of 1940 and its amendments.
8. There have been no prior actions of divorce or annulment between the parties.
9. The marriage is irretrievably broken.
10. Plaintiff has been advised that counseling is available and that Plaintiff may have
the right to request the court to require the parties to participate in counseling.
WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce,
divorcing Plaintiff and Defendant.
EQUITABLE DISTRIBUTION OF MARITAL PROPERTY
11. Paragraphs 1- 10 of this Complaint are incorporated herein by reference as if set
forth at length.
12. The Plaintiff and Defendant have legally and beneficially acquired certain real and
personal property during the marriage.
WHEREFORE, the Plaintiff respectfully requests your Honorable Court to equitably
divide all marital property.
ALIMONY
13. The Plaintiff incorporates herein by reference the allegations set forth in
Paragraphs 1 through 12, inclusive, of the Complaint, as if the same were set forth herein at
length.
14. Plaintiff lacks sufficient property and resources through her employment to
provide for her reasonable needs.
15. Plaintiff requires reasonable support to adequately maintain herself in accordance
with the standard of living established during the marriage.
WHEREFORE, Plaintiff respectfully requests that your Honorable Court enter an award
of alimony in her favor.
1 verify that the statements made in this Complaint are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. S. § 4904 relating to
unsworn falsification to authorities.
Date: e\\ $ \qq
Rose Mary i per - Plaint
Respectfully su itted:
Date:
Melissa Peel Greevy, Esquire
I.D. No. 77950
214 Senate Avenue Suite 602
Camp Hill, PA 17011-2336
(717) 763-8995
Counsel for Plaintiff
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ROSE MARY WADLINGER,
Plaintiff,
V.
EDWARD F. WADLINGER,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No.99-4198 Civil Term
CIVIL ACTION - LAW
DIVORCE
AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING
1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on July
9, 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 of divorce after service of intention to request
entry of the decree.
4. I have been advised of the availability of marriage counseling, and understand that I
may request that the Court require that my spouse and I participate in counseling. I further
understand that the Court maintains a list of marriage counselors in the Prothonotary's Office,
which list is available upon request. Being so advised, I do not request that the Court require that
my spouse and I participate in counseling prior to a divorce decree being handed down by the
Court.
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: Vt
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Rose Mary
Plaintiff
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ROSE MARY WADLINGER,
V.
Plaintiff,
EDWARD F. WADLINGER,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4198
CIVIL ACTION - LAW
IN DIVORCE
1. A Complaint in D'vor a under Section 3301(c) of the
Divorce Code was filed on ?
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. I consent to the entry of a final decree of divorce
after service of notice of intention to request entry of the
decree.
4. 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.
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 unsworn falsification to authorities.
DATE : Id
ward F. Wa linger
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ROSE MARY WADLINGER,
Plaintiff,
V.
EDWARD F. WADLINGER,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No.99-4198 Civil Term
CIVIL ACTION - LAW
DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if 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 by 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
unswom falsification to authorities.
Date: %C?\Sq 0 1 6) 11
Rose Mary c roger
Plaintiff
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ROSE MARY WADLINGER,
V.
Plaintiff,
EDWARD F. WADLINGER,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4198
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INUNTION TO
REQUEST ENTRY OF A DIVORCE! DECREE Th**1 u
SECTION 3301(c) OF THE nrvnvrr rnnc,
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. 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: /0-.2!o -O/
rd F. Wadlinger
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ROSE MARY WADLINGER, IN THE COURT OF COMMON PLEAS
Plaintiff, OF CUMBERLAND COUNTY,
PENNSYLVANIA
V.
CIVIL ACTION - LAW
EDWARD F. WADLINGER,
Defendant. No. 99-4198 Civil Term
IN DIVORCE
CERTIFICATE OF SERVICE
I, Melissa Peel Greevy, Counsel for Plaintiff in the above captioned matter, do hereby certify
that I have served the Defendant, Edward F. Wadlinger, with a true and correct copy of the Divorce
Complaint by placing same in the U.S. Mail, certified, restricted delivery, return receipt requested,
and postage prepaid. The Divorce Complaint was also placed in regular U.S. Mail on July 16, 1999.
The signed receipt indicating service was made on July 27, 1999 iis` attached hereto.
Date: 7 l49I 1 ?Ft 77
Melissa Peel Greevy, Esquire
214 Senate Avenue Suite 602
Camp Hill, PA 17011-2336
(717) 763-8995
Counsel for the Plaintiff
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
• +t+ a
ROSE 94ARY Wnsbl:p?6$.R -
No. 99-4198 Civil Term
VERSUS
EDWARD F WADTTNGER
DECREE IN
DIVORCE
AND NOW,
DECREED THAT ROSE. MARY WART TNrvt
AND
EDWAF
ARE DIVORCED FROM THE E
THE COURT RETAINS JUI
BEEN RAISED OF RECORD IP
YET BEEN ENTERED;
9.?
2001 , IT IS ORDERED AND
, PLAINTIFF,
, DEFENDANT,
OWING CLAIMS WHICH HAVE
rvr? WHICH A FINAL ORDER HAS NOT
None.The terms of the Separation and Property Settlemgnt
with this Divorce Decree, and are enforceable pursuant to 23 Pa.
C. S. § 3105.
BY THE COURT:
ATTEST:
j
il!
J.
PROTHONOTARY ',-,,
CORRECTION
Previous Image
Refilmed to Correct
Possible Error
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
aTS e
ROSE MARY WADLINGER
No. 99-9198 Civil Term
VERSUS
EDWARD F_ WAD .TN. R
DECREE IN
DIVORCE
AND NOW,
BY THE COURT;
DECREED THAT ROSE. MARV WADTTNC.FR PLAINTIFF,
AND EDWARD F. WADLINGER DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
None.The terms of the Separation and Property Settlemgnt
26, 206! is tilcor with this Divorce Decree, and are enforceable pursuant to 23 Pa.
C. S. § 3105.
9.?
ATTEST:
2001 , IT IS ORDERED AND
J.
PROTHONOTARY
ROSE MARY WADLINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99 - 4198 CIVIL
EDWARD F. WADLINGER,
Defendant IN DIVORCE
ORDER OF COURT
AND NOW, this day of a ei
2001, the economic claims raised in the proceedings having
been resolved in accordance with a separation and property
settlement agreement dated October 26, 2001, the appointment
of the master is vacated and counsel can file a praecipe
transmitting the record to the Court requesting a final
decree in divorce.
BY THE COURT,
cc: Melissa Peel Greevy
Attorney for Plaintiff
P. Richard Wagner
Attorney for Defendant
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ROSE M. WADLINGER, IN THE COURT OF COMMON PLEAS OF
Plaintilf(Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - DIVORCE
NO. 99-4198 CIVIL TERM
EDWARD F. WADLINGER, IN DIVORCE
Dcfendant/Respondcni DR# 28,992
Pacses# 713101496
ORDER OF COURT
AND NOW, this 18"' day of September, 2000, upon consideration of the attached Petition for
Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective
counsel appear before R.J. Shaddav on October 19 2000 at 10.30A.M. for a conference, at 13 N.
Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for
Alimony Pendente Lite be entered.
YOU are further ordered to bring to the conference:
(1) a true copy of your most recent Federal Income Tax Retum, including W-2's as filed
(2) your pay stubs for the preceding six (6) months
(3) the Income and Expense Statement attached to this order, completed as required by Rule
1910.11(0
(4) verification of child care expenses
(5) proof of medical coverage which you may have, or may have available to you
IF you fail to appear for the conference or bring the required documents. the Court may issue a
warrant for your arrest.
BY THE COURT,
George E. Hoffer, President Judge
Mail copies on Petitioner
9•18 00An: z < Respondent
P. Richard Wagner. Esquire
Melissa Greevy. Esquire
Date of Order: September 18. 2000
R. J, hadd y, onference Officer
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE A
REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET
LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVE.
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
?:
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C?„??tNNSYL\?? ?pNN
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the Court,
please contact our office at (717) 240-6225. All arrangements must be made at least 72 hours
prior to any hearing or business before the Court. You must attend the conference or hearing.
ROSE MARY WADLINGER,
Plaintiff,
V.
EDWARD F. WADLINGER,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-4198 CIVIL TERM
IN DIVORCE
SUBSEQUENT PETITION PURSUANT TO Pa. R. C. P. 1920.13
Plaintiff, by and through her counsel, Melissa Peel Greevy, Esquire, files this Subsequent
Petition pursuant to Pa. R. C. P. 1920.13., and avers in support thereof as follows:
1. This is a divorce action instituted by Plaintiff on July 9, 1999.
2. In addition to a divorce, Plaintiff requested equitable distribution and alimony.
3. The child support order for the minor child, docketed at 00820 S 1997, PACSES
No. 320100005, has been terminated due to the child reaching age 18 and graduating from High
school on or about June 6, 2000.
4. Plaintiff had filed a previous petition for APL, docketed at 99.4198 Civil,
PACSES No. 713101496ID28, 992 which was dismissed without prejudice on November 4,
1999 at Petitioner's request.
5. Plaintiff now requests a new date be scheduled for an APL conference.
CountI
Alimony pendente lite
6. Plaintiff incorporates herein by reference the allegations set forth in Paragraphs 1
through 5 inclusive, of the Subsequent Petition as if the same were set forth at length.
7. Plaintiff, whose social security number is 191-42-7808 employed at the
Commonwealth of Pennsylvania, Harrisburg, Pennsylvania and at Remax Realty and is earning an
approximate net monthly income of $1750 per month.
8. Defendant, whose social security number is 175-40-6934, is employed at the
Commonwealth of Pennsylvania, Harrisburg, Pennsylvania and is earning an approximate net
monthly income of $2363.00.
9. Plaintiff has insufficient income and assets to provide for her needs.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an order for
Alimony Pendente Lite.
Date: EJ 11, 7- 0 U V
VC
(Jkom
Melissa eel Greevy, Esquire
I.D. No. 77950
214 Senate Avenue Suite 105
Camp Hill, PA 17011-2336
(717)'763-8995
Counsel for Plaintiff
I verify that the statements made in this Petition are true and correct to the best of my
knowledge, information and belief. I understand that false statements made herein are made subject
to the penalties of 18 Pa. C. S. A. § 4904, relating to unsworn falsification to authorities.
g"II. 7_cnrZ? '
Date:
Rose Mary Wadli
T
CERTIFICATE OF SERVICE
And now this / IVAI day of 2000, I, Melissa Peel Greevy,
Esquire, do hereby affirm that a copy of the Subsequent Petition Pursuant to Pa. R. C. P. 1920.13
was served by United States mail this date upon counsel for the Defendant, addressed as follows:
P. Richard Wagner, Esquire
Mancke, Wagner, Hershey & Tully
2233 North Front Street
Harrisburg, PA 17110
Date• r
Melissa "Peel Greevy. Esquir
Counsel for Plaintiff
DR$ A'0'1'ACHMENT FOR APL PR0CCEDINC5
PI: I'1'I'IONI'.rt: Hose Marv Wadlinger
DOH: 05-06-49 _ SSN:_191-42-7808
AtNmus: 98A Herman Avenue. Lemoyne PA 17043
PHUNr:: 717-731-8997
A1'i'ORNCY: Melissa Peel Greevy, Esq.
PI'TITIONF.R'S IiNIIILOYMh.NT: (bmmonwealth of PA IIOW LONG: 7 Years
NF.TPAY: S1,750.00VER: Month JOBTITI.L': Purchasing Agent
O'T'HER INCOML (AMOUNT. SOURCr..): Rermx Part-Time
RRSPONUI?NT:. Edward F. Wadlinaer
DOB: 12-11-48 SSN: 175-40-6934
ADDRItSS: 216 Wdst Simpson Street, Mechanicsburg, PA 17055
PI IDNF: 717-791-1169
AITORNEY: P. Richard Wagner
RL''SPONDL•'N'I" S I'MI)LOYMENT: Commonwealth of PA IIOW LONG: 13 Years
Nr:'I' PAY :52.363.00 PLR: Month JOB TITL,F Administrative Officer
011ILR INCOME; (AMOUNT,SOURCE): May also have part-time income.
\VIIL''N MARRIED: 08-24-74 :wimRf:: Harrisburg, PA
DA1r:SI7rARA'1-I;D; April 8, 1997
WIII:RI': LAST' L.IVLDTOGGTHER: 217 Indian Creek Drive. Mechanicsburg. PA 17055
FOR DRS INFORMXHON ONLY
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75,
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ROSE MARY WADLINGER,
Plaintiff,
V.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-4198 CIVIL TERM
EDWARD F. WADLINGER, IN DIVORCE
Defendant.
ORDER APPOINTING MASTER
AND NOW, Za t.l7re,t`1!??7 .2000. /?i-?e t ?A<c/Gv Esquire, is
appointed master with respect to the following claims:_Q I
BY THE COURT:
J.
Lo;a"
A?3
ROSE MARY WADLINGER, IN THE COURT OF COMMON PLEAS
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-4198 CIVIL TERM
V.
EDWARD F. WADLINGER, IN DIVORCE
Defendant.
MOTION FOR APPOINTMENT OF A MASTER
Pursuant to Pa R P 1920,74
Plaintiff moves the court to appoint a Master with respect to the following claims:
(X ) Divorce (X ) Distribution of Property
( ) Annulment ( ) Support
(X ) Alimony ( ) Counsel Fees
(X ) Alimony Pendente Lite ( ) Costs and Expenses
and in support of the motion states:
(I) Discovery is complete as to the claim(s) for which the appointment of a Master is
requested.
(2) Defendant is represented in this action by his attorney, P. Richard Wagner,
Esquire. Plaintiff is represented by his attorney, Melissa Peel Greevy, Esquire.
(3) The statutory ground(s) for divorce are 3301(c), and /or 3301(d).
(4) The action is not contested.
(5) The action does not involve complex issues of law or fact.
(6) The hearing is expected to take one-half day.
(7) Additional information, if any, relevant to the motion: None.
31
Date
Me issa Peel Greevy, Esquire
I.D. No. 77950
214 Senate Avenue Suite 105
Camp Hill, PA 17011-2336
(717) 763-8995
Attorney for the Plaintiff
CERTIFICATE OF SERVICE
AND NOW, this c2O2A-a-, day of November, 2000, I, Melissa Peel Greevy, Esquire,
Counsel for Plaintiff hereby certify that a copy of the foregoing Motion for the Appointment of a
Master Pursuant to Pa. R. C. P. 1920.74 was served upon counsel for the Defendant via United
States Mail addressed as follows:
P. Richard Wagner, Esquire
Mancke, Wagner, Hershey &'I'ully
2233 North Front Street
Harrisburg, PA 17110
a,a??l?
Date: ll-
Me issa Peel Greevy, Esquire
I. D. No. 77950
214 Senate Avenue Suite 105
Camp Hill, PA 17011-2336
(717) 763-8995
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ROSE M. WADLINGER, IN THE COURT OF COMMON PLEAS OF
Plaintdff/Petitioncr CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - DIVORCE
NO. 99 -.1198 CIVIL TERM
EDWARD F. WADLINGER, IN DIVORCE
Defendant/Respondent DR# 28,992
Pacses# 713101496
ORDER OF COURT
AND NOW, this 12°' day of October. 1999, upon consideration of the attached Petition for
Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective
counsel appear before R.J. Shaddav on November d, 1999 at 10.,30A.M. for a conference, at 13 N.
Hanover St., Carlisle, PA 17013, alter which the conference officer may recommend that an Order for
Alimony Pendente Lite be entered.
YOU are further ordered to bring to the conference:
(1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed
(2) your pay stubs for the preceding six (6) months
(3) the Income and Expense Statement attached to this order, completed as required by Rule
1910.110
(4) verification of child care expenses
(5) proof of medical coverage which you may have, or may have available to you
I
IF you fail to appear for the conference or bring the required documents, the Court may issue a
warrant for your arrest.
BY THE COURT,
George E. Hoffer, President Judge
Mail copies on Petitioner
10112/99 to: < Respondent
Melissa Peel Greevy. Esquire
P. Richard Wagner. Esquire
Date of Order: October 12. 1999
/ , 7(
R. ] Shadday, Conference Officer
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND
REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET
LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVE.
CARLISLE. PENNSYLVANIA 17013
(717)249-3106
f _
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i ?.? :SiL':::G,1
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office at (717) 240-6225. All arrangements must be made at least 72 hours
prior to any hearing or business bef)w the Court. You must attend the conference or hearing.
ROSE MARY WADLINGER,
Plaintiff,
V.
EDWARD F. WADLINGER,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-4198 Civil Term
CIVIL ACTION - LAW
DIVORCE
SUBSEQUENT PETITION PURSUANT TO Pa. R. C. P. 1920.13
Plaintiff, by and through her counsel, Melissa Peel Greevy, Esquire, files this Subsequent
Petition pursuant to Pa. R. C. P. 1920.13, and avers in support thereof as follows:
1. This is a divorce action instituted by Plaintiff on July 9, 1999.
2. In addition to a divorce, the Plaintiff requested equitable distribution and alimony.
3. A conference for child support modification is scheduled for September 16, 1999
at 9:00 a.m.
4. Plaintiff now desires to make a claim for alimony pendente lite by this petition so
that a hearing may be scheduled on that claim for the same date as the child support conference.
CountI
Alimony Pendente Lite
5. Plaintiff incorporates herein by reference the allegations set forth in Paragraphs I
through 3, inclusive, of the Subsequent Petition as if the same were set forth at length.
6. Plaintiff, whose social security number is 191-42-7808, is employed at the
Commonwealth of Pennsylvania, Harrisburg, Pennsylvania, and at Remax Realty and is eaming
an approximate gross income of $29,095.
Defendant, whose social security number is 175-40-6934, is employed at the
Commonwealth of Pennsylvania, Harrisburg, Pennsylvania and is earning an approximate
income of $36036.
8. Defendant has historically had other part time income, thus, Plaintiff, believes and
therefore avers, Defendant may have additional income.
9. Plaintiff has insufficient income and assets to provide for her needs.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an order for
Alimony Pendente Lite.
Date: `/1117/
C
Melissa Peel Greevy, Esquire
I.D. No. 77950
214 Senate Avenue Suite 602
Camp Hill, PA 17011-2336
(717) 763-8995
Counsel for the Plaintiff
I verify that the statements made in this Petition are true and correct to the best of my
knowledge, information and belief. 1 understand that false statements made herein are made
subject to the penalties of 18 Pa. C. S. A. § 4904, relating to unswom falsification to authorities.
Date:
citct
Rose M Wadlin!!?
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APR-03-88 FRI 11;23 AM CAMS CT° DRO FAX .40. 717 240 3243 P. 02
DRS ATTACHMENT F012 APL P110CCFDINC5
PISrniom;R
upu: S_a_eo SSN. 181 42 'St?B
ADDRr:SS: 364 A Market Street Lemoyne. PA 17043
PIIONr,: 731-8997
AITORNLY:Melissa PPPI Craovyr F,c?
PL!1'11'I0fJP.R'S CMI'LOYMENT: Commonwealth of PA IIOW LONG: 6 yr
NETPAY:, $7g,9;PER: yr JOB TITLE: p,j TMyhaa4ngZ, gont
01+1ERINCOME(AMOUNT.SOURCE): Remax, par time 54449/ year
RESPONDENT; EDWARD F. WADLINGER
Upu: 12-11-48 SSN: 175-40-6934
AODRESS: 217 Indian Creek Drive, Mpohanirghurg., PA
111IUNE 710_4644
A170RNEY:_ R -Richard Wagner-, E6q
RLSPONIILNT'SUMPLOY MCNT: Commonwealth of PA IIOWLONG: 12 yr
NR'I'PAY: 6 PER:year JODTITIA: administrative officer
0111ERINCONIL(AMOUNT,SOURCE): ma.T also have part time income
WIIL'NMARK11:10-24-74 :WIIF.Rf:: Harrisburg, PA
DAI'CSCPARATED: April Ar 1997
WIII:Rr: I.AST LIVED'I'OGCTIIER:
FOR DRS INFORMA'no,x ONLY
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania j
DOMESTIC RELATIONS SECTION
ROSE M. WADLINGER ) Docket Number 99-4198 CIVIL
Plaintiff )
vS ) PACSES Case Number 713101496 /D28.992
EDWARD F. WADLINGER ) i
Defendant ) Odier State ID Number
ORDER
AND NOW, to wit on this 4TH DAY OF NOVEMBER, 1999 IT IS HEREBY
ORDERED that the 0 Complaint for Support or 0 Petition to Modify or ® Other
REQUEST FOR APL CONFERENCE filed on SEPTEMBER 10, 1999 in the above captioned
matter is dismissed without prejudice due to:
PETITIONER REQUESTING THAT SCHEDULED CONFERENCE ON THIS DATE BE CANCELLED.
0 The Complaint or Petition may be reinstated upon written application of the petitioner, if
filed within one year from date hereof.
BY THE COURT:
DRO: RJ shadday
xc: plaintiff
defendant
M. Greevy, Esq.
P. R. Wagner, Esq.
Form OE-506
Service Type M (? Worker ID 21005
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ROSE M. WADLINGER,
Plaintiff/Petitioner
Vs.
EDWARD F. WADLINGER,
Defendant/ Respondent
DR 28,992
PACSES ID 713101496
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
DOMESTIC RELATIONS SECTION
CIVIL ACTION - LAW
NO. 99-4198 CIVIL TERM
ORDER OF COURT
AND NOW, this 19's day of October, 2000, based upon the Court's determination that
Petitioner's monthly net income/earning capacity is $1,940.08 per month and Respondent's monthly
net income/earning capacity is $2,188.11 per month, it is hereby Ordered that the Respondent pay to
the Pennsylvania State Collection and Disbursement Unit, $150.00 a month payable bi-weekly as
follows; $45.69 bi-weekly for alimony pendente lite and $23.54 bi-weekly on arrears. First payment
due next pay date at $69.23. Arrears set at $297.00 as of October 19, 2000. The effective date of the
order is August 14, 2000.
Failure to make each payment on time and in full will cause all arrears to become subject to
immediate collection by all of the means as provided by 23 Pa.C.S.§ 3703. Further, if the Court
finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare
the Respondent in civil contempt of Court and its discretion make an appropriate Order, including,
but not limited to, commitment of the Respondent to prison for a period not to exceed six months.
Said money to be turned over by the PA SCDU to: Rose Wadlinger. Payments must be made
by check or money order. All checks and money orders must be made payable to PA SCDU and
mailed to:
PA SCDU
P.O. Box 69110
Harrisburg, PA 17106-9110
Payments must include the defendant's PACKS Member Number or Social Security Number in
order to be processed. Do not send cash by mail.
This Order shall become final ten days after the mailing of the notice of the entry of the Order
to the parties unless either party files a written demand with the Prothonotary for a hearing de novo
before the Court.
DRO: R.1. Shadday BY THE COURT,
Mailed copies on Petitioner
M;W&, M to: < Respondent
tv Melissa Greevy, Esquire
P. Richard Wagner, Esquire
7 Hess J.
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7AIAi I
Form I U14UA Department of the Treasuy - Internal Revenue Service
dtav November ZWO,
1
Amended U.S. Individual Income Tax Return
? See separate Instructions OW M. 15/5.0091
This return Is for calendar year 2000 , or fiscal ear ended
Ymr 11s1 Mme MI Last Name Your SocW Security Number
Rose M Wadlin er 191-42-7808
Please It a Joint Rat=. Spouse's Fist Mme MI Last Mme Speuw's Srrclal Security Nunbrr
print
or Morro Nkress (nuroer and street or P.O. Box it mail M Not Delivered to You none A
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98 Herman Avenue p
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City, I. or Post ONice. II You Haw a Foreign Address. See Inshuclans. State ZIP Code
Lemo For Paperwork Reduction
yne oe 17nao era ursNe. ... l...,..sr......
A If the name or address shown above is different from that shown on the original return, check here .............................. . ?
B Has the original return been changed or audited by the IRS or have you been notified that it will be? .................. Yaa XQ No
C Filing status. Be sure to complete this line. Note. You cannot change from joint to separate returns after the due date.
On original return ? X Single Marred filing pint relun Marred filing separate stun Head of hi Mold oueupng widow(er)
On ths raw ? SiMle B Married filing pint return X Married filing separate ratan B Head of housahold• e euahying witbw(m)
• If the eueleying person n a child bud not You dependent, see irntructrons.
Use Part II on Page 2 to Explain an Changes
any A Original B Net change - c Correct
amount or as Amount of increase amount
Income and Deductio instruction
ns see ) Previously adjusted or (decrease) -
' s (see instructions) explain in Part II
1 Adjusted gross income (see instructions) .................. 1 32,143. 0. - 32 143'.
2 Itemized deductions or standard deduction (see instructions) .........:.. 2 4 400. 0. 4 400
3 Subtract line 2 from line 1 ......................... ....... 3 27,743. 0. 27,743.
4
5 Exemptions. If changing, fill in Parts I and II on page 2 ..... 4 2,800. 0. 2 800:
Taxable income. Subtract line 4 from line 3 :............... 5 24, 943. 0. 24.9
43.
6 Tax (see instructions). Method used in column C ... Tables _ _ _ 6 - 3,739. 0. 3,739.
Tax
Us- 7 Credits (see instructions) .......... 7 0. 0. 0.
biliy 8 Subtract line 7 from line 6. Enter the result but not less than zero ........ 8 3 739. 0. '3; 739.
9 Other taxes (see instructions) .......... .................. 9 0. 0. 0.
10 Total tax. Add lines 8 and 9 .............................. 10 3,739. 0. 3,739.
11 Federal income tax withheld and excess social security and
. RRTA tax withheld. If changing, see instructions ............ 11 3 423. 0. 3.423-
12 Estimated tax payments, including
Pay. amount applied from prior year's return .................. 12. 0. 0. 0.
mets 13 Earned income credit (EIC) .............................. 13 04 0. 0.
14, Additional child tax credit from Form 8812 ................. 14 0. 0. 0.
15 Credits from Form 2439 or Form 4136 ..................... 15 0 . 0. 0
16
17
Amount paid with request for extension of time to file (see instructions) ................
.............. 16 .
18 Amount of tax paid with original return plus additional lax paid after
T it was filed ......... .............. 17
otal payments. Add lines I1 through 17 in column C ............. ................... .............. 18 3,423.
Refund or Amount You Owe
19
' Overpayment, if any, as shown on original return or as previously adjusted by the IRS .. .............. 19
20 Subtract line 19 from line 18 (see instructions) ................... ................... .............. 20 3 423
21
Amountyou owe. If line 10, column C, is more than line 20, enter th
e difference and see i
nstructions ... 21 .
316.
22 If line 10, column C, is less than line 20, enter the difference ...... .................... ............. 72
23 Amount of line 22 you want refunded to you ..................... .................... ............. 23
24 Amount of line 22 you want applied to our estimated tax ..... 24 1
Sign Here der penallles of perluy. I declare that I have filed an original relun and that I have examined this amended return. in aw,no accompanying echedubi and
9slemenis, and to IM best of my knowledge and belief
this amend
d r
l
Joint return? ,
e
e
un a true. c
based on all ntormaton Of winch the preparer has any knowledge. orrect. and complete. Decara twn of preparcr (otter than taxp ayer) a
See malls. '
Keep a copy
for your
records. Your a Date
Spoide's Signature. It a Joint Return, Both Must Sign
Date
Preparer's
Signature ' Dal.
Check d selb Properties SSN or PTIN
'
Paid employed ..
Preparers Firma Mme Self - re cared
P
p
USeonl
Only (oryavaf _
_
_
_______________ _____ EIN
self
D
ass. and
Add ass. antl ________________________
2iP Cade _____
PMne Nn
BAA FDIA1812 Dnaroo Form 104OX (Rev. 11.2000)
, ,
See Form 1040 or 1040A instructions.
'A Onal number
it you are not changing your exemptions, do not complete this part.
If claiming more exemptions
com
let
li
2 of exemptions
reported or as
,
p
e
nes
5 - 31,
If claiming fewer exemptions, complete lines 25 - 30, previously adjusted
25 Yourself and spouse ...............
Caution. If your parents (or someone else) can
l
i
c
a
m you as a
de
endent
J
p
(even
they chose not to), you cannot claim an
exemption for yourself.
26 Your dependent children who lived with you ..................... • . 26
27 Your dependent children who did
t li
i
h
no
ve w
t
you due to divorce or separation ...... 27
28 Other de
endent
p
s .............................................. 28
29 Total number of exem
ti
Ad
^
p
ons.
d lines 25 through a
8 ..............
30 M
lti
l
th
n 29
u
p
y
e
umber of exemptins claimed on line 29 by the
amount listed below for the tax year you are amending. Enter
the result here and on line 4.
Tax Exemption But see the I
nstrections for line 411
• year amount the amont on Iina 1 Is over:
u
19000 99 $2,7850 $96,700 .
94
975
,
1997 93,400
• 2 650
90
900
,
31 Dependents (children and other) not claimed on original (or adjusted) r 30
eturn
:
Note. For tax years after 1997, do not complete column (e) below. For
column (d) below. tax y ear 1997, do not comp lete
(a) First name La t b D
B Net change I C Correct
number of
exemptions
s name () ependents
so
i
l
i (c)Depentlenl's (d) (e)
c
a
secur
ty relationship Number
. number to you va
«i'lo
of months
cmu la. lived in
our h
aoC ;r y
ome
Number of
your children
on line 31 who:
e lived with you.. ? r
L___I
P did not live.
with youldue to,
divorce or sep•
oration (see l
instructions) ... ? C
on line 31 not
P ?I
art 11 Explanation of Changes to Income, Deductions, and Credits
Enter the line number from page 1 of the form for each Item yyou are changing and give the reason for each change. Attach only
the supportingg forms and schedules for the Items changed. Il you do not attach the required Information, ypur Form 1040)( may
be returned. Be sure to Include your name and social security number on any attachments.
the
or
attach the schedule or form that
............•......:... .. ...:.......... ?
Divorce is not final and Attorney thought I should file married eventhou h we have been seperated for4years.
P Pre9idtftlttaf Election Cam al n Fund. Checking below will not increase our lax or reduce our refund.
If you did not previously want $3 to go to the fund but now want to, check here ............................. .. , , , , , , ? `
If a joint return and Your spouse did not previously want $3 to go to the fund but now want to check here ?
BAA
Form 7040X (Rev 11.2000) .-
FOIAIS12 0921/00
For
Label
(See Instructions.)
Use the
IRS label.
'Otherwise,
please print
ortype.
Presidential
Election
Campaign
(See iraeuctrrn.)
Filing Status
Check only
one box.
Exemptions
Department or the Treasury - Internal Revenue Service
Jan I-Dec 31, 2000, or other tax year beginnin
sl Name MI Last Na"
Last
or Post Oars. It You Have a
IRS use only - Do not mile or staple in Iles space
,20 01,18M, 15454)074
Your Sod.i Security Numbs
191-42-7808
Spouw's social security Nuedi
annhanl M. . Important!. A
You must enter your social
e security number(s) above.
110 Note: Checking 'Yes' will not change your tax or reduce your refund.
Do vou. or vour spouse if filing a joint return, want $3 to do to this fund? ....... ?
2
3
4
60
Spouse
Married filing joint return (even if only one had income)
Married filing separate return. Enter spouse's SSN above & full name here ...
Head of household (with qualifying person). (See instructions.) If the qualifying person is a child but not your
dependent, enter this child's name here ... P
Yourself. If your parent (or someone else) can claim you as a dependent on his or
her lax return, do not check box 5a ..............................................
:.....
b I I Spouse .............
c Dependents:
I number I to you
name
If more than
six dependents,
see instructions.
No.aid
F
1
and b .. 1
. No. of your ,
-
If
chadr.non
6e wbo:' .
chip a IHM ?
tax .
with you .. . .
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above .. .... .
Add number, -7
- an.r.d on 7
1 I
• v,v.u, uun,..m m.,.o,,, .,a,,,,? ...................................................
7 Wages, salaries, lips, etc. Attach Form(s) Al ...................................... .....
7
31 922.
Income Be Taxable interest. Attach Schedule B if required .... • ... "''.
...
I
Attach Forms bTax-exempt interest. Do not include on line 8a ............
' W-2andW2G 9 Ordinary dividends. Attach Schedule B if required ................................
9
13.
hem. Also attach
Forol1MR if 10 Taxable refunds, credits, or offsets of state and local income taxes (see instructions) .....
10
taxwaswithheld. 11 Alimony received .................................................................. 11 208.
12 Business income or (loss). Attach-Schedule C or C.EZ .............................. 12
If you did not
13 Capital gain or (loss). Attach Schedule D if required, If not required, check here .... ? 13
yet a W2, see
Instructions. 14 Other gains or (losses). Attach Form 4797 ............................................ 14
15a Total IRA distributions ..... 15a b Taxable amount (see instrs) .. l5b
16a Total pensions & annuities 16a Is Taxable amount (see instrs) .. 161a
' 17 Rental real estates royalties, partnerships, S corporations, trusts, etc. Attach Schedule E .. 17
but do 18 Farm income or (loss). Attach Schedule F ............................................
Enclose 18
,
not attach, any 19 Unemployment compensation ....................................................... 19
payment. Also, 20a Social security benefits ...:. 120al J b Taxable amount (see instrs) .. 20b
please use
.
Form 10404. 21 Other income. List type & amount (see instrs)
21
_ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _
22 Add the amounts in the far right column for lines 7 through 21. This is your total income l 22 32,143.
.
Adjusted 24 ,nn ?C..... ror s..? ...........................
Student loan interest deduction (see instructions) ...........
Gross
25'
Medical savings account deduction. Attach Form 8853 .......
Income
Incom 26 Moving expenses. Attach Form 3903 .......................
27 One-half of self-employment tax. Attach Schedule SE .......
28 Self-employed health insurance deduction (see instructions) .
29 Self-employed SEP, SIMPLE, and qualified plans ...........
30 Penalty'on early withdrawal of savings .....................
31 a Alimony paid b Recipient's SSN .... ? ....
32 Add lines 23 through 31a ................................................................
33 Subtract line 32 from line 22 This is your adjusted gross Income .....................
Privacy Act, and Paperwork Reduction Act Notice, we instructions.
Form
FDIA0112 11107100
Tax and
Credits
F
Head of.
househod:
$6,450
Married filing
to""'' or
qualllym
widow(er?:
$7,350
Married filing
separately:
$3,675
• Amount from line 33 (adjusted gross income) .....
35a Check if: 0 You were 651older, ? Blind; 0 Spouse was 65/older,
Add the number of boxes checked above and enter the total h
36
37
38
39
40
41
42
43
44
45
46
47
48
49
So
Blind,
ere coons ...... ? 35aL
Is If you are married Min g separately and yyour spouse itemizes deductions
or you were a dual-status alien, see instructions and check here .. , ....,. .
Enter your itemized deductions from Schedule A, line 28, or standard deduction 356 C
shown on the left. But see instructions to find your standard deduction if you checked
any box on line 35a or 35b or If someone can claim you as a dependent ..,.. , .. .
Subtract line 36 from line 34 , .
. .................
................
line 34 is $96,700 or less, multiply 52,890 by Ihe total number of axemplions claimed on line 6d. If Itne 34
is over $96,700, see the worksheet in the instructions 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 instrs). Check if any tax is from a ? Form(s) 8814 b Q Form 4971 .....
Alternative minimum lax. Attach Form 6251 .......:.
Add lines 40 and 41 ......... . ...............
Foreign tax credit Atta hF .,...'•"•'
• c orm I l l6 if required ............
Credit for child and dependent care expenses. Attach Form 2441 . 43
.... , ....
Credit for the elderly or the disabled. Attach Schedule R .... . 44
. 45
Education credits. Attach Form 8863
......................
Child tax credit (see instructions) . . 46
...... ................
Adoption credit. Attach Form 8839 47
Other. Check if from .. a
e Q Form 8801
f ............
B Form 3800 b Q Form 8396 48
o
Form (specify)
Add lines 43 through 49. These are your total credits ....... 49
...
rac
ne 50 from line 42. If line 50 is more than line 42 enter •0 ............
52 Self•employment fax, Attach Schedule SE . . . : . ? 91
Other
Taxes ..e... . . .. . . .
53 Social security antl Medicare tax an tip inco.m not.mpor'.ed. to employer. Attach Form 4137
52
54 Tax on IRAs, other retirement plans, and MSAs. Attach Form 5329 if re
i
d
'
qu
re
...
55 Advance earned income credit payments from Form(s) W-2 ......... 54
........ . . .........
56 Household employment taxes. Attach Schedule H ......... 55
' ............................
57 Add lines 5156: This is ur total tax ..... ... . ..... 56
Pe menIt ... ,
58 Federal income tax withheld from Forms W2 and 1099
?
If you have a
qualifying ...... 58
59 2000 estimated tax payments and amount applied from 1999 return .. ... , . 59
60 3 423 .
child, attach
Schedule EIC a Earned income credit (EIC
) .................... .. 60a
r Is Nontaxable earned inc
?
. ome: amount .
and type . ?
_ _
61 Excess social sec_urity and RATA tax withh
ld
e
(see inslrs) 61
62 Additional child tax credit. Attach Form 8812
......... , . 62
63 Amount paid with request for extension to file (see instructions) , .
, , , ,
63
;
, , ,
64 Other payments. Check If from ..... a Q Form 2439
b Q Form 4136
.......
...............
64
65 Add lines 58, 59, 60a, and 61 lhrough'64
These a
.
re your
total Payments .......
Refund
66 If Tine 65 is more than line 57, subtract line 57 from line 65. This is the amount
•
Have it directly you overpaid ........
.67a Amount of line
66 you want refund
d t ......
66
deposited' See
instructions and
fill in 67b
67 ,
e
o you ................. ?
"' . • •67a
? Is Routing "
9 number ....... ? c Type: ?Checking 11 Savin
?
,
c,
and 67d
of Account number ...... . gs,
. 68 Amount of line 66 you want
app- ---lied to your 1001 estimated tax . ..
? 68
Amount .. ,
69 If line 57 is more than line 65
subtract li
6
You Owe ,
ne
5 from line 57. This is the amount you
owe. For details on how to pay, see instructions
.... .. . ..........................
70 Estimated tax penal . Also include on line 69 .
170 ..... ? 69
Here -
Under panall es of perlW. I eeclare That I have examines Ifus relwn and actom n
belief' Une?y are Irue. correct, and complete. De bratron of preparer tot ar hen a
a
n
s
o nil sta
rn e
t
o to
ai
of
m
Joint retuln7 xp
y
) I
based
llo
lter
n
Vwr, Spnatue Date which
grape
had,
See instructions. Ydx
eupelron
si Dayturq Rnrro Mmber
Keep a c0 1t
Dale S t t e em l o e e
Sporae's epnatue. II a Jo,nl Return, exam hLaI Sign
'
for our records. .
s Occupation
It, spolae
May o«uss ft FS IN
proeiparnsl er =below
(sa)?
Paid Prepanalreas it, Dale
Spur Prenavers
Preparef s
Us
O
l Fnm's nlame Self-prepared Chec4 1 sell empb
cwra,asu
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n
y set, empbyed), i> Subt
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1040
foyaaoo
T Detach Here and Mail With Your Payment Y
Form 1 04 -V Payment Voucher - 0hi8W.ISOM74
IIemal R'Olfll!$ONIa[O0(99) ? Do not staple or attach this voucher to your payment 2000
.
1 Enter the First Fm Letters of Yov Last Name 2 Enter Yov Social Smwity Nimoer 3 ErIMtM An mnt You An Pitying by CMek w
" Ord*
WAR 191-42-7808 ? S r 316.
4 If a bind Retun. Enter the Social Secvity $ Enter Your Nam
Manger SMnYn Second on not Return
Rose M WadlinRer
Enter Your Address
98 Herman Avenue Apt. A
Enter Yov City Slate ZIP Code
BAA
FDIA8601 10/24/00
?IPAl rG
ROSE MARY WADLINGER, IN THE COURT OF COMMON PLEAS
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
V.
EDWARD F. WADLINGER,
Defendant.
No.994198 Civil Term
CIVIL ACTION - LAW
DIVORCE
PRE-TRIAL STATEMENT OF PLAINTIFF, ROSE MARY WADLINGER
Plaintiff:
1. Name: Rose Mary Wadlinger
2. Address: 98-A Herman Avenue Lemoyne, PA 17043
3. Age: 51
4. Date of Birth: May 6, 1949
5. Health: Dental problems remain untreated, hypertensive cardiovascular
disease.
6. Occupation: Purchasing Agent
7. Employer: Commonwealth of Pennsylvania
Defendant:
1. Name: Edward F. Wadlinger
2. Address: 216 W. Simpson Street, Mechanicsburg, PA 17055
3. Age: 52
4. Date of Birth: December 1, 1948
5. Health: No health problems and/or issues have been raised.
6. Occupation: Administrative Officer
7. Employer: Commonwealth of Pennsylvania
Page 1 of 5
Minor Children of this Marriage:
None.
Marriage Information:
1. Date of Marriage:
2. Place of Marriage:
3. Date of Separation:
4. Date Action Commenced:
5. Issues Raised:
August 24, 1974
Harrisburg, Dauohin County, Pennsylvania
November 10, 1997
April 8, 1997
Divorce under § 3301 (c) or §3301 (d)
Equitable Distribution
Alimony Pendente Lite*
Alimony
*An APL order was entered on October 19, 2000 Defendant filed an appeal dated October 30,
2000.A hearing was set for January 8, 2001. However, by agreement of Counsel it was continued
generally and a decision was made to have the Divorce master address this issue in conjunction
with the other issues in this case.
A. Real Property
1. The marital home was foreclosed upon due to Defendant's failure to pay the
mortgage after June 1998. It was sold at Sheriff's sale on June 7, 2000.
B. Retirement
1• Plaintiff has a defined benefit pension via the PA State Employees Retirement
System The present value of the pension as of March 14, 2001 was $9524.26. This value reflects ,
a reduction for non-vesting.
Ft.
2. Defendant has a defined benefit s k
pension via the PA State Employees Retirement,'i s
System. The present value of the pension as of March 14, 2001 was $105,488.07.
' °'?
D. Subsequent to separation, until the sheriffs sale of the marital home on June 7, 2000
Defendant resided in the marital home, was employed full time, and maintained various
part time jobs, while claiming a gross income of $78,375.09 for the period of July 31,
1998 through May 31, 2000. He shared the home with the parties' minor child and
collected child support for her care. However, from July I, 1998 until the sale, the
Defendant did not pay the mortgage on the marital home. As a result, the proceeds at
time of sale were substantially diminished. Plaintiff, therefore claims that a debt exists
to her for Defendant's intentional dissipation of this marital asset.
IV. WITNESSES
A. Expert
1. Plaintiff expects to call and expert as to the valuation of the parties'
pensions.
B. Fact
1. Rose Mary Wadlinger
2. Edward F. Wadlinger
V. PROPOSED RESOLUTION
A. Equitable distribution: Plaintiff would receive one half of the balance of the
escrow account, via a QDRO to be prepared at Defendant's expense, the amount
of $57,608.14 from Defendant's pension, and Plaintiff would retain her pension.
Defendant would receive one half of the balance of the escrow account,
Defendant would retain $57,506.16 of his pension and the savings bond.
B. Alimony Plaintiff would receive alimony in the amount of $100.00 per month
for an indefinite term.
C. Alimony Pendente Lite Plaintiff would continue to receive APL until the Decree
is entered, at which time it would be converted to an Alimony award.
Page 4 of 5
D. Subsequent to separation, until the sheriff s sale of the marital home on June 7, 2000
Defendant resided in the marital home, was employed full time, and maintained various
part time jobs, while claiming a gross income of $78,375.09 for the period of July 31,
1998 through May 31, 2000. He shared the home with the parties' minor child and
collected child support for her care. However, from July 1, 1998 until the sale, the
Defendant did not pay the mortgage on the marital home. As a result, the proceeds at
time of sale were substantially diminished. Plaintiff, therefore claims that a debt exists
to her for Defendant's intentional dissipation of this marital asset.
IV. WITNESSES
A. Expert
Plaintiff expects to call and expert as to the valuation of the parties'
pensions.
B. Fact
Rose Mary Wadlinger
2. Edward F. Wadlinger
V. PROPOSED RESOLUTION
A. Equitable distribution; Plaintiff would receive one half of the balance of the
escrow account, via a QDRO to be prepared at Defendant's expense, the amount
of $57,608.14 from Defendant's pension, and Plaintiff would retain her pension.
Defendant would receive one half of the balance of the escrow account,
Defendant would retain $57,506.16 of his pension and the savings bond.
B. Alimony Plaintiff would receive alimony in the amount of $100.00 per month
for an indefinite term.
C. Alimony Pendente Lite Plaintiff would continue to receive APL until the Decree
is entered, at which time it would be converted to an Alimony award.
Page 4 of 5
D. Life Insurance Defendant would make Plaintiff the irrevocable beneficiary of a
Life Insurance policy in the amount of $50,000.
E. Divorce Grant Plaintiff a Divorce under § 3301 (d), if Defendant will not sign a
consent under § 3301 (c).
Respectfully d,
Date: 71061 l `Asp_
Melissa Peel Greevy, Esquire
I. D. No. 77950
214 Senate Avenue Suite 105
Camp Hill, PA 17011-2336
(717) 763-8995
Counsel for Plaintiff
Page 5 of 5
CERTIFICATE OF SERVICE
AND NOW, thisday of April, 2001, I , Melissa Peel Greevy, Esquire, Counsel for
Plaintiff, hereby certify that a copy of the foregoing Pretrial Statement was served upon counsel
for the Defendant via United States Mail addressed as follows:
P. Richard Wagner, Esquire
Mancke Wagner, Hershey & Tully
2233 North Front Street
Harrisburg, PA 17H 01
Date: ray ?
lvN 1 "1 Melissa Peel -Greevy, Esquire
214 Senate Avenue Suite 105
Camp Hill, PA 17011-2336
(717) 763-8995
s
Wdgole)f
ROSE MARY WADLINGER, : I N THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
V. : NO: 99-4198 Civil Term
EDWARD F. WADLINGER,
Defendant.
CIVIL ACTION - LAW
IN DIVORCE
DEFENDANT'S PRE-TRIAL STATEMENT
1. FACTS:
Husband, Edward F. Wadlinger, resides as 216 W. Simpson Street,
Mechanicsburg, Pennsylvania.
He was born December 11, 1948, and is employed with the Department of
Agriculture.
He was married to his wife, Rose, on August 24, 1974. Two children were
born of the marriage, each of whom are now emancipated. The younger child,
Theresa, resided with the Defendant in what was previously the marital home situate
at 217 Indian Creek Drive, Mechanicsburg, Pennsylvania, up until the time the home
was sold through foreclosure.
The parties were separated April 8, 1997.
11. ASSETS:
A. Pension of wife valued at $9,524.26;
B. Pension of husband valued at $105,480.07;
C. A bank account with proceeds from the foreclosure on the marital
home having a balance of approximately $5,200.00;
III. LEGAL ISSUES:
A. The parties have agreed that the Defendant's challenge to the APL
award that was previously given to Plaintiff at the Domestic Relations
Office would be an issue to be addressed by the Master as opposed to
taking the issue to appeal in front of a judge. The amount of the APL
is less than $100.00 per month.
B. Wife is raising as a legal issue the failure of the husband to pay the
mortgage on the marital home which resulted in foreclosure. The
period of time in which he did not pay the mortgage was a period of
-2-
time in which he and the youngest daughter resided in the home and he
was not receiving support for the daughter.
C. During the pendency of the foreclosure on the marital home, husband
had a buyer that would have generated a substantial profit for the
parties to divide; however, wife refused to participate thereby
preventing a sale at a profit, which thereafter resulted in a foreclosure.
V. INCOME:
A. See the attached 2000 Income Tax Return of Defendant;
VI. PENSIONS:
A. See the attached pension appraisal reports on both parties.
-3-
H. PROPOSED RESOLUTION:
A QDRO would be entered regarding the pensions and that wife's share be
reduced in proportion to the profit loss on the sale of the marital home for her failure
to participate in the sale of the marital home during the foreclosure process.
No alimony to be paid to wife and all parties be responsible for their own
legal fees.
Respectfully
& Tully
?.BY
P,R'chard Wagner, Esquire
2233 North Front Street
Harrisburg, PA 17110
(717) 234-7051
Attorneys for Defendant
Date: !?115'161
-4-
I, Debra K. Spinner, Secretary in the law firm of
MANCKE, WAGNER, HERSHEY, & TULLY, do hereby certify that I am
this day serving a copy of the foregoing document to the
following persons and in the manner indicated below, which
service satisfies the requirements of the Pennsylvania Rules of
Civil Procedure, by depositing the same in the United States
Mail, Harrisburg, Pennsylvania, with first class postage,
prepaid, and addressed as follows:
Melissa Peel Greevy, Esquire
214 Senate Avenue
Suite 206
Camp Hill, PA 17011
By * IOVAev
Debra K. Spinner, Secretary
MANCKE, WAGNER, HERSHEY & TULLY
2233 North Front Street
Harrisburg, PA 17110
P. Richard Wagner, Esquire
Attorneys for Defendant
DATE: `1 Q/
Z - o
?yy
Y W 6
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d
W D
3 Y = m
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Q w =
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WE DO "REST CERTIFY THAT tD
THE WITXIN IE A TRUE AND COR• • wRinexA x
RECT COPY OF THE ORIGINAL "W OFFICES MIX EMTY ]p PA.E FIIOY
PLED IN TM ACTION "RIMS Me A ?uooxew
Aawr.w
NY . MANCKE, WAGNER, HERSHEY&TULLY .80m
suar- r
L,
ROSE MARY WADLINGER,
Plaintiff,
V.
EDWARD F. WADLINGER,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-4198 Civil Term
CIVIL ACTION - LAW
DIVORCE
INVENTORY OF ROSE MARY WADLINGER
Plaintiff files the following inventory of all property owned or possessed by either parry at
the time this action was commenced and all property transferred within the preceding three years.
Plaintiff verifies that the statements in this inventory are true and correct. Plaintiff
understands that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904
relating to unsworn falsification to authorities.
Rose Mary Wadlin r,
.7'c
ASSETS OF PARTIES
Plaintiff marks on the list below those items applicable to the case at bar and itemizes the
assets on the following pages.
(x )1. Real property -proceeds of sale
(x )2. Motor vehicles
(x )3. Stocks, bonds, securities and options
( ) 4. Certificates of deposit
(x )5. Checking accounts, cash
(x )6. Savings accounts, money market and savings certificates
()7. Contents of safe deposit boxes
O8. Trusts
(x )9. Life insurance policies (indicate face value, cash surrender value and current
beneficiaries)
()10. Annuities
( )11. Gifts
012. Inheritances
()13. Patents, copyrights, inventions, royalties
()14. Personal property outside the home
()15. Business (list all owners, including percentage of ownership, and officer/director
positions held by a party with company)
()16. Employment termination bcnefits-severance pay, workers' compensation claim/award
()17. Profit sharing plans
(x) 18. Pension plans (indicate employee contribution and date plan vests)
( )19. Retirement plans, Individual Retirement Accounts
()20. Disability payments
()21. Litigation claims (matured and unmatured)
()22. MilitaryNA benefits
()23. Education benefits
()24. Debts due, including loans, mortgages held
(x )25. Household furnishings and personalty (include as a total category and attach itemized
list if distribution of such assets is in dispute)
( )26. Other
MARITAL PROPERTY
Plaintiff lists all marital property in which either or both spouses have a legal or equitable
interest individually or with any other person as of the date this action was commenced:
Item Description Names of
Number Propert All Owners
1. Personal Checking and Savings Rose Mary Wadlinger
Accounts
2. Personal Checking and Savings Accounts Edward F. Wadlinger
3. Savings Bond Edward F. Wadlinger and
Rose Mary Wadlinger
4. Pension Rose Mary Wadlinger
5. Pension Edward F. Wadlinger
6• 1995 Lumina Rose Mary Wadlinger
7. 1993 Plymouth Duster Edward F. Wadlinger
8. Ford vehicle Edward F. Wadlinger
9. Household Furnishings Edward F. Wadlinger and
Rose Mary Wadlinger
10. Commerce Bank Account Rose Mary Wadlinger
(Proceeds from sale of marital home,
tax rebate and insurance refund)
NON-MARITAL PROPERTY
Plaintiff lists all property in which a spouse has a legal or equitable interest which is
claimed to be excluded from marital property:
Item Description Reason for
Number of Propert y Exclusion
I • Checking and Saving accounts Post separation earnings
PROPERTY TRANSFERRED
Person
Item Description Date of to Whom
Number of Propert y Transfer Transferred Consideration
1. Marital home June 7, 2000 Crary and Sharon Morris $119,938.26
LIABILITIES
Item Description Names of Names of
Number Prope y All Creditors All Debtors
1. Car loan M & T Bank Rose Mary
Wadlinger
?I
c
r
1
y
CERTIFICATE OF SERVICE
AND NOW, this o2 day of November, 2000, 1, Melissa Peel Greevy, Esquire,
Counsel for Plaintiff hereby certify that a copy of the foregoing Inventory of Rose Mary
Wadlinger and Income and Expense Statement of Rose Mary Wadlinger were served upon
counsel for the Defendant via United States Mail addressed as follows:
P. Richard Wagner, Esquire
Mancke, Wagner, Hershey & Tully
2233 North Front Street
Harrisburg, PA 17110
Date: Z Oho
Melissa Peel Greevy, Esquire
I. D. No. 77950
214 Senate Avenue Suite 105
Camp Hill, PA 17011-2336
(717) 763-8995
ROSE MARY WADLINGER,
Plaintiff,
V.
EDWARD F. WADLINGER,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-4198 Civil Term
CIVIL ACTION - LAW
DIVORCE
INCOME AND EXPENSE STATEMENT OF
Rose Mary Wadlinger
INCOME
Employer: Commonwealth of Pennsylvania, Department of Public Welfare
Address: Harrisburg, PA 17120
Type of Work: Purchasing Agent
Payroll Number:
Pay Period (weekly, biweekly, etc.): Biweekly
Gross Pay per Pay Period: $ 1122.75
Itemized Payroll Deductions:
Federal Withholding $ 122
79
Social Security .
Local Wage Tax 85.89
State Income Tax 11.23
Retirement 31.44
Savings Bonds 56.14
Credit Union
Life Insurance
Health Insurance
Other (Specify) Union dues 16.84
Net Pay per Pay Period: $798.42
Other Income:
Part time - Remax, avg. $90.83 Gross per month. This varies seasonally.
Interest
Dividends
Pension
Annuity
Social Security
Rents
Royalties
Expense Account
Gifts
Unemployment Comp.
Workmen's Comp.
alimony pendente lite
TOTAL INCOME
EXPENSES
Home
Mortgage/rent
Maintenance
Utilities
Electric
Gas
Oil
Telephone
Water
Sewer
Employment
Public
transportation
Lunch
Week Month Year
ljv.VV
Weekly Monthly Yearly
(Fill in appropriate column)
$ $550.00 $
75.00
60.00
100.00
Taxes
Real Estate
Personal property
Income
Insurance
Homeowners
Automobile
Life
Accident
Health
Other
Automobile
Payments
Fuel
Repairs
Medical
Doctor
Dentist
Orthodontist
Hospital
Medicine
Special needs (glasses,
braces, orthopedic
devices)
Education
Private school
Parochial school
College
Religious
Personal
Clothing/Drycleaning
Food
Barber/hairdresser
Credit payments
Credit Card
Charge account
Memberships -AAA
Loans
Credit Union
Miscellaneous
Household help
10.00
9.80
$50.00
$ $ 333.56 $
80.00
50.00
$100
$2000-$6000
_$100.00_
$100.00
$ $_150.00 $
125.00
_$200.00
$ 45.00
34.00
Child care
Papers/books/
magazines
Entertainment
Pay TV
Vacation
Gifts
Legal fees
Charitable
contributions
Other child support
Alimony payments
Other
11.00
10.00
28.88
$100
400.00
Total Expenses $_ $1768.44 $2953.80
PROPERTY OWNED
Ownership*
Description Value 1-I W J
Checking accounts Commerce Bank $ 349.44 X
Savings accounts Commerce Bank_ 6.00 X
Credit Union
Real estate
Other
Saving bond -x_
Total $_355.00_
INSURANCE
Coverage's
Policy
Company No. H W C
Hospital
Blue Cross Comm of PA 191427808 _x
Other _
Medical
Blue Shield Comm of PA _x -
Other
Health/Accident -- -
Disability Income
Other (Vision) PEBTF_ x
*H = Husband; W = Wife; J = Joint; C = Child
SUPPLEMENTAL INCOME STATEMENT
(a) This form is to be filled out by a person (check one):
[ ] (1) who operates a business or practices a profession, or
[ ] (2) who is a member of a partnership orjoint venture, or
[ ] (3) who is a shareholder in and is salaried by a closed corporation or similar entity.
(b) Attach to this statement a copy of the following documents relating to the partnership,
joint venture, business, profession, corporation or similar entity:
(1) the most recent Federal Income Tax Return, and
(2) the most recent Profit and Loss Statement.
(c) Name of business:
Address and
s
Telephone Number:
(d) Nature of business
(check one)
[ ] (1) partnership a
[ ] (2) joint venture
[ ] (3) profession
}
[ J (4) closed corporation
[ ] (5) other, sole proprietor
(e) Name of accountant, controller or other person in charge
of financial records: .
(f) Annual income from business
(l) How often is income received ?
-Monthly 'r4
(2) Gross income per pay period:
-approximately $ y
(3) Net income per pay period:
-Variable
(4) Specified deductions, il'any:
Verification
1, Rose Mary Wadlinger, verify that the statements made in the foregoing Income and
Expense Statement and Inventory 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: 44W /?
?pe1Rose Mary ??
' ?. -
.._.
J
? .)
VV
"
l ..i
...
J
ROSE MARY WADLINGER, IN THE COURT OF COMMON PLEAS ?? 11
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA k{/ ?V 1
V. No.994198 Civil Term
EDWARD F. WADLINGER, CIVIL ACTION - LAW
Defendant. DIVORCE
PLAINTIFF'S LIST OF EXHIBITS
I. Mortgage Foreclosure Action No. 99-284 Civil Tenn.
2. Schedule of Distribution, Sale No. 22, Writ No. 1999-284 Civil Term.
3. March 14, 2001 Pension Valuation on Plaintiff's Pension.
4. March 14, 2001 Pension Valuation on Defendant's Pension.
5. Commerce Bank Statement of March 20, 2001 for Account No. 0513231811.•
6. Discharge of Debtor for Edward F. Wadlinger, Case No. 99-03703RJW-1.
7. Discharge of Debtor for Rose M. Wadlinger, Case No.99-0461 IRJW-1.
8. Plaintiff's 2000 W-2 Wage and Tax statements.*
9. November 30, 1999 correspondence to opposing counsel.
10. May 19, 2000 correspondence to opposing counsel.
11. August 2, 2000 correspondence to opposing counsel.
12. Defendant's Answers to Plaintiffs Interrogatories dated January 11, 2001.
" Plaintiff expects to supplement these exhibits with the Master and opposing counsel
prior to the Master's conference with counsel.
Date: y/a hl n/
vy, Esq.
Me i Peel Gree
1. D. No. 77950
214 Senate Avenue Suite 105
Camp Hill, PA 17011-2336
(717) 763-8995
Respec y s miffed
FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248
TWO PENN CENTER PLAZA, SUITE 900
PHILADELPHIA, PA 19102
(215) 563-7000
GE CAPITAL MORTGAGE SERVICES, INC.
2000 WEST LOOP SOUTH, SUITE 1300
HOUSTON, TX 77242-0275
V.
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
NO. 9Q 1- aO4 l?Sxl41
CUMBERLAND COUNTY _
EDWARD F. WADLINGER :? -•
ROSE M. WADLINGER _
217 INDIAN CREEK DRIVE _
MECHANICSBURG, PA 17055
Defendant(s)
CIVIL ACTION - LAW _
MORTGAGE FORECLOSURE
NOTICE
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
You have been sued in Court. If you wish to defend against the
claims set forth in the following pages, you must take action
within twenty (20) days after this Complaint and Notice are
served, by entering a written appearance personally or by
attorney and filing in writing with the court your defenses or
objections to the claims set forth against you. You are warned
that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the court without further
notice for any money claimed in the Complaint or for any other
claim or relief requested by the Plaintiff. You may lose money
or property or other rights important to you.
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
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
We hereby certify the CARLISLE, 17013
(717) 249-3]1 166
within to be a true and
correct copy of the
ERMAN AND PHELA
original filed of record
MAN AND PHELAN ; ?ED
A COP
Y
EEDER ?r ? A FIN
FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248
TWO PENN CENTER PLAZA, SUITE 900
PHILADELPHIA, PA 19102
!9151 563-7000 -
GE CAPITAL MORTGAGE SERVICES, INC.
2000 WEST LOOP SOUTH, SUITE 1300
HOUSTON, TX 77242-0275
Plaintiff
V.
EDWARD F. WADLINGER
ROSE M. WADLINGER
217 INDIAN CREEK DRIVE
MECHANICSBURG, PA 17055 Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
NO.
CUMBERLAND COUNTY
CIVIL ACTION - LAW
MORTGAGE FORECLOSURE
NOTICE
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
You have been sued in court. If you wish defend against the
claims set forth in the following pages, you must take action
within twenty (20) days after this Complaint and Notice are
served, by entering a written appearance personally or by
attorney and filing in writing with the court your defenses or
objections to the claims set forth a-lainst you. You are warned
that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the court without further
notice for any money claimed in the Complaint or for any other
claim or relief requested by the Plaintiff. You may lose money
or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
FIND OUT WHEREONE, YOUOCATO OR N GETTLEGALOHELPTHE. OFFICE
HAV
BELOWRTOCANNOT
SETEFORTHLAWYER
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
rctcbyGenthe CARLISLE, PA 17013
Wp;' attueand (717) 249-3166
wlthtn tp u°1 oR the FILE ®? •
E,?ty
Corrnnt, Med, cf tcc pd
FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248
TWO PENN CENTER PLAZA, SUITE 900
PHILADELPHIA, PA 19102
f215) 563-7000
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
GE CAPITAL MORTGAGE SERVICES, INC.
2000 WEST LOOP SOUTH, SUITE 1300
HOUSTON, TX 77242-0275
V.
Plaintiff
TERM
NO.
CUMBERLAND COUNTY
EDWARD F. WADLINGER
ROSE M. WADLINGER
217 INDIAN CREEK DRIVE
MECHANICSBURG, PA 17055
Def endant(s)
CIVIL ACTION - LAW
MORTGAGE FORECLOSURE
NOTICE
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
You have been sued in Court. If you wish to defend against the
claims set forth in the following pages, you must take action
within twenty (20) days after this Complaint and Notice are
served, by entering a written appearance personally or by
attorney and filing in writing with the court your defenses or
objections to the claims set forth against you. You are warned
that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the court without further
notice for any money claimed in the Complaint or for any other
claim or relief requested by the Plaintiff. You may lose money
or property or other rights important to you.
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
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
WphweblCOT?lly tand CARLISLE, PA 17013
V'dlhintobeat(ue (717) 249-3166
ee, °f f?c 0 POidgE!Al FILE Cop
npi41Q? t? w
??;1I, ,, -
A
1. Plaintiff is
GE CAPITAL MORTGAGE SERVICES, INC.
2000 WEST LOOP SOUTH, SUITE 1300
HOUSTON, TX 77242-0275
2. The name(s) and last known address(es) of the Defendant(s)
are
EDWARD F. WADLINGER
ROSE M. WADLINGER
217 INDIAN CREEK DRIVE
MECHANICSBURG, PA 17055
who is/are the mortgagor(s) and real owner(s) of the
property hereinafter described.
3. On 4/30/93 mortgagor(s) made, executed and delivered a
mortgage upon the premises hereinafter described to BANK
UNITED OF TEXAS, FSB which mortgage is recorded in the
Office of the Recorder of CUMBERLAND County, in Mortgage
Book No. 1131, Page 567. By Assignment of Mortgage dated
9/3/93 the mortgage was assigned to PLAINTIFF which
Assignment is recorded in Assignment of Mortgage Book No.
485, Page 341.
4. The premises subject to said mortgage is described as
attached.
5. The mortgage is in default because monthly payments of
principal and interest upon said mortgage due 7/1/98 and
each month thereafter are due and unpaid, and by the terms
of said mortgage, upon failure of mortgagor to make such
payments after a date specified by written notice sent to
Mortgagor, the entire principal balance and all interest due
thereon are collectible forthwith. A copy of such notice is
attached as Exhibit "A."
A
6. The following amounts are due on the mortgage:
Principal Balance $87,624.83
Interest 3,841.13
6/1/98 through 1/1/99
(Per Diem $17.95)
Attorney's Fees 4,381.24
Cumulative Late charges 224,77
4/30/93 to 1/1/99
Cost of Suit and Title Search 550.00
Subtotal 96,621.97
Escrow
Credit 0.00
Deficit 173.29
Subtotal 173.29
TOTAL $96,795.26
7. The attorney's fees set forth above are in conformity with
the Mortgage documents and Pennsylvania Law, and will be
collected in the event of a third party purchaser at
Sheriff's Sale. If the Mortgage is reinstated prior to the
Sale, reasonable attorney's fees will be charged.
8. This action does not come under Act 6 of 1974 because the
original mortgage amount exceeds $50,000.00.9
9. The Temporary Stay as provided by the Homeowner's
Emergency Mortgage Assistance Program, Act 91 of 1983,
has terminated because either:
(i) Defendant(s) have failed to meet with the Plaintiff or
an authorized credit Counseling Agency in accordance
with Plaintiff's written Notice to Defendants, a true
and correct copy of which is attached hereto as Exhibit
"B" or
(ii) Defendant(s) application for assistance has been
rejected by the Pennsylvania Housing Finance Agency.
10. Pursuant to the Fair Debt Collection Practices Act, 15
U.S.C. § 1692 et seq. (1977), Defendant(s) may dispute
the validity of the debt or any portion thereof. If
Defendant(s) do so in writing within thirty (30) days
of receipt of this pleading, Counsel for Plaintiff will
obtain and provide Defendant(s) with written
verification thereof; otherwise, the debt will be
assumed to be valid. Likewise, if requested within
thirty (30) days of receipt of this pleading, Counsel
for Plaintiff will send Defendant(s) the name and
address of the original creditor if different from
above.
WHEREFORE, PLAINTIFF demands an in rem Judgment against the
Defendant(s) in the sum of $96,795.26, together with interest
from 1/1/99 at the rate of $17.95 per diem to the date of
Judgment, and other costs and charges collectible under the
mortgage and for the foreclosure and sale of the mortgaged
property.
/s/ Frank Federman
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
SCHEDULE OF DISTRIBUTION
SALE NO. 22
Date filed July 7, 2000
Writ No. 1999-284 Civil
GE Capital Mortgage Services Inc.
-vs-
Edward F. Wadlinger and Rose M. Wadlinger
217 Indian Creek Drive
Mechanicsburg, PA 17055
Date of Sale June 7, 2000
Buyer Gary Raymond Morris and Sharon Speck Morris
Bid Price $ 114,001.00
Real Debt $ 99,685.21
Interest 6/10/99-6/7/0016.39 per diem 5,949.57
Writ costs 963.38
$ 106,598.16
DISTRIBUTION
Amount collected $ 119,938.26
Sheriff's Costs 3,136.30
Legal Search 200.00
Transfer Taxes Local 1,728.62
Transfer Taxes state 1,728.62
2000 County Library Township taxes 341.06
Sewer 206.10
Credit Writ No. 1999-284 Civil with 106,598.16
Refund to defendants 5.999.40
$ 000,000.00
Refund to Attorney advance costs
$ 1000.00
.';
So answat` .+?
R. Thomas Kline, Sheriff
By
Real Estate Deputy
??lGnrS?S
% ? I
PENSION APPRAISERS INC.
P.O. Box 4396 • Allentown, PA 18105-4396
1-800-447-0084 • Fax 610-770-9342
March 14, 2001
Melissa Peel Greevy, Esq.
214 Senate Avenue, Suite 105
Camp Hill, Pennsylvania 17011-2336
E-MAIL: penapp@pensionappraisers.com
WNV%V: http://w%v%v.pensionappraisers.com
RE: Present Value of Rose M. Wadlinger's Defined Pension Benefit
File No. 01-26-01-274-0274G
Dear Attorney Greevy:
We have determined the present value of Rose M. Wadlinger's defined pension benefit by the
GATT Method as of March 14, 2001 to be $9,524.26. This valuation was developed and
prepared in conformity with the requirements of the Actuarial Standards of Practice No. 34. These
Standards were developed by the Pension Committee of the Actuarial Standards Board of the
American Academy of Actuaries. The purpose is to set standards for Members and Other
Persons Interested in Actuarial Practice Concerning Retirement Plan Benefits in Domestic
Relations Actions. Pension Appraisers, Inc. relies on the requestor to provide the information
necessary to value pensions. In some cases, information not provided by the requestor may be
obtained from plan summaries on file in Pension Appraisers, Inc.'s offices. All information received
from the requestor is reviewed for practicability and reasonableness. Any information in question is
verified with the requestor, when possible. Any deficiencies in data may materially affect the
results of the appraisal. Pension Appraisers, Inc. utilizes the fractional rule allocation method in
valuing all pensions for equitable distribution purposes unless otherwise stated.
BIRTH DATE: May 6, 1949
SEX: Female
MARRIAGE DATE: August 24, 1974
VALUATION DATE: March 14, 2001
PENSION PLAN: PA State Employees Retirement System
DATE EMPLOYMENT STARTED: February 19, 1993
(Assumed date pension holder began participation in the plan)
DATE BENEFITS STOPPED ACCRUING: April 8, 1997
(Assumed date pension holder ended participation in the plan)
ASSUMED DATE MARRIAGE ENDED: April 8, 1997
AGE WHEN BENEFITS COMMENCE: 60 Years
"Valuators of Defined Pension Benefits for Equitable Distribution"
GATT Actuarial and Mortality Tables Method
March 14, 2001
Rose M. Wadlinger -#01-26-01-274-0274G
Page 2
MORTALITY TABLES: 1983 Group Annuity Mortality Tables
INTEREST RATE ASSUMPTIONS: 5.33 % and 4.33 %
30-Year U.S. Treasury Bond Constant Maturity Rate for the Month of
the Date of Valuation.
U.S. Treasury Bond Rate: 5.33%
Estimated Cost of Living Adjustment: 1,00%
Adjusted Rate: 4.33%
ASSUMED MONTHLY BENEFIT: $165.54
Monthly pension benefit the pension holder would receive at
retirement age with a fully vested pension based upon
compensation and plan provisions as of April 8, 1997.
Formula:
0.02 x Years of Service x Final Average Salary
Annual Maximum Full Retirement
Data:
Years of Service: 4.8030 Years As of 12131/96)
+0.2r Years (12/31/96 - 4/8/97)
5.0713 Years (As of 4/8/97)
Final Average Salary: $19,585.12
Analysis:
0.02 x 5.0713 x $19,585.12 = $1,986.44 (Annual Benefit)
44 = $ 165.54 (Monthly Benefit)
12 Months
REDUCTION FOR NON-VESTING: 0.5071
Represents a reduction for the probability of service to 100 percent
vesting as equal to the portion already completed.
REDUCTION FOR MARITAL COVERTURE FRACTION: 1.0000
Represents that portion of the value of the benefits attributable to
the marriage. The numerator of the fraction represents the total
period of time the pension holder participated in the plan during
the marriage and the denominator is the total period the pension
holder participated in the benefits program.
GATT Actuarial and Mortality Tables Method.
March 14, 2001
Rose M. Wadlinger -#01-26-01-274-0274G
Page 3
PRESENT VALUE BEFORE REDUCTIONS: $ 16,761,62
Reduction for Non-vesting: x 0.5071
Reduction for Marital Coverture: x 1.0000
VALUATION FOR EQUITABLE DISTRIBUTION: $ 9,524.26
PENS% 0 . ION APPRAISERS INC
P.O. Box 4396 • Allentown, PA 18105-4396
1-800-447-0084 • Fax 610-770-9342
March 14, 2001
Melissa Peel Greevy, Esq.
214 Senate Avenue, Suite 105
Camp Hill, Pennsylvania 17011-2336
E-MAIL: penapp@pensionappraisers.com
IVI"V: http://www.pensionappraisers.com
RE: Present Value of Edward F. Wadlinger's Defined Pension Benefit
File No. 01-26-01-273-027313
Dear Attorney Greevy:
We have determined the present value of Edward F. Wadlingers defined pension benefit by the
GATT Method as of March 14, 2001 to be $105,488.07. This valuation was developed and
prepared in conformity with the requirements of the Actuarial Standards of Practice No. 34. These
Standards were developed by the Pension Committee of the Actuarial Standards Board of the
American Academy of Actuaries. The purpose is to set standards for Members and Other
Persons Interested in Actuarial Practice Concerning Retirement Plan Benefits in Domestic
Relations Actions. Pension Appraisers, Inc. relies on the requestor to provide the information
necessary to value pensions. n some cases, information not provided by the requestor may be
obtained from plan summaries on file in Pension Appraisers, Inc.'s offices. All information received
from the requestor is reviewed for practicability and reasonableness. Any information in question is
verified with the requestor, when possible. Any deficiencies in data may materially affect the
results of the appraisal. Pension Appraisers, Inc. utilizes the fractional rule allocation method in
valuing all pensions for equitable distribution purposes unless otherwise stated.
BIRTH DATE: December 11, 1948
SEX: Male
MARRIAGE DATE: August 24, 1974
VALUATION DATE: March 14, 2001
PENSION PLAN: PA State Employees Retirement System
DATE EMPLOYMENT STARTED: November 15, 1975 (Assumed)
(Assumed date pension holder began participation in the plan)
9 S
DATE BENEFITS STOPPED ACCRUING: April 8, 1997
(Assumed date pension holder ended participation in the plan)
ASSUMED DATE MARRIAGE ENDED: April 8, 1997
AGE WHEN BENEFITS COMMENCE: 60 Years
"Valuators of Defined Pension Benefits for Equitable Distribution"
GATT Actuarial and Mortality Tables Method
March 14, 2001
Edward F. Wadlinger -#01-26-01-273-0273G
Page 2
MORTALITY TABLES: 1983 Group Annuity Mortality Tables
INTEREST RATE ASSUMPTIONS: 5.33 % and 4.33 %
30-Year U.S. Treasury Bond Constant Maturity Rate for the Month of
the Date of Valuation.
U.S. Treasury Bond Rate: 5.33%
Estimated Cost of Living Adjustment: 1,00%
Adjusted Rate: 4.33%
ASSUMED MONTHLY BENEFIT: $1,056.48
Monthly pension benefit the pension holder would receive at
retirement age with a fully vested pension based upon
compensation and plan provisions as of April 8, 1997.
Formula:
0.02 x Years of Service x Final Average Salary
Annual Maximum Full Retirement
Data:
Years of Service: 21.4125 Years (As of 12/31/96)
+0.2683 Years (12/31/96 - 4/8/97)
21.6808 Years (As of 4/8/97)
Final Average Salary: $29,237.22
Analysis:
0.02 x 21.6808 x $29,237.22 = $12,677.73 (Annual Benefit)
$12.677.73 = $ 1,056.48 (Monthly Benefit)
12 Months
REDUCTION FOR NON-VESTING: 1.0000
Represents a reduction for the probability of service to 100 percent
vesting as equal to the portion already completed.
REDUCTION FOR MARITAL COVERTURE FRACTION: 1.0000
Represents that portion of the value of the benefits attributable to
the marriage. The numerator of the fraction represents the total
period of time the pension holder participated in the plan during
the marriage and the denominator is the total period the pension
holder participated in the benefits program.
GATT Actuarial and Mortality Tables Method
March 14, 2001
Edward F. Wadlinger -#01-26-01-273-0273G
Page 3
PRESENT VALUE BEFORE REDUCTIONS:
Reduction for Non-vesting:
Reduction for Marital Coverture:
VALUATION FOR EQUITABLE DISTRIBUTION:
$ 105,488.07
x 1.0000
x 1.0000
$ 105,488.07
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C AM L' HILL PA 17;11 'kFri ACCOUNTNO.
`?; e1 05 1 3? 3 1 311
Y `L'7 c.m
kkk 01 C'<I, 'J„ kkk rq 0 14 E_Y Mn•7KrT E'U5. BEGINNING PATS 2.00000
4 CC:7U?!T `i'.7.k%'.rj ":.1 .', 7:71•fll TAX ID N1-wif=. lv'1-+i'-7•'a^
?LV i17 J' iT11t""iC,.'T '•:i.AVC?. ay Dr 02/2C/^1 •..• 5f 11:2
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------------------------------------------------------------
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13
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-'aVL. F OF r?AL ID"'.NUM9ER ";.: 23-?3:4730
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__ ____ •?r _' •y? ___
?kk I I REST F4,RNED THIS`TATEMFNT PE.RII'D kkk
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----------- ----------------
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NOTE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION .- "'
Form DIS•70(OlBcial Form a)
("7)
UNITED STATES BANKRUPTCY COURT
MIDDLE DISTRICT OF PENNSYLVANIA
In Re:
WADLINGER, EDWARD F
217 INDIAN CREEK DR
MECHANICSBURG, PA 17055.2527
Case Number. 99-03703RJW-1
Chapter. 7
Social Security Nola).:
Debtor: 175.40.8934
Debtor )
)
DISCHARGE OF DEBTOR
It appearing that the debtor is entitled to a discharge,
R IS ORDERED:
The debtor is granted a discharge under section 727 of title 11, United States
Code, (the Bankruptcy Code).
BY THE COURT
Dated: December 3, 1999
Robert J. Woodside
Chief Bankruptcy Judge
SEE BACK SIDE OF THIS ORDER FOR IMPORTANT INFORMATION
(o
t??DIS70(oftial Form 1e)
UNITED STATES BANKRUPTCY COURT
U Re. MIDDLE DISTRICT OF PENNSYLVANIA
WADUNOER,ROSE M )
I MDYN W. Caw Number. WWI IRjw.1
Ch Wter 7
?
s00ial84WW NO(e).: Dabw
Debtor, tm-42-m e
I
DISCHARGE OF DEBTOR
It appearing that the debtor Is etnttled to a dkkharge,
IT IS ORDERED.
The debtor Is granted a dia&arp under eeotion 727 of tftie 11, United States
Code, (the Bankruptcy Code).
Dated: February 11, 2000 BY HE COURT,, r
Robert J&side
Chief Untied States Bankruptoy Judge
SEE BACK SIDE OF THIS ORDER FOR IMPORTANT INFORMATION
ArAW
6rb
7
awls
r
SUBJECT: 2000 FEDERAL TAXABLE WAGES
TO: ROSE M WADLINGER
98 A HERMAN AVENUE
LEMOYNE PA 17043
i Social security wages
28,689.49
Medicare wages and tips
28,889.49
I,A410e1140 EIC Payment
The amount of Federal Taxable Wages shown to Block 1 of the attached W2 statement for most employes may
differ from the amount of Gross Earnings you received during the calendar year. Any difference is a
result of one or more of the adjustments explained and calculated below:
If you have any questions, please contact your Personnel Office.
• " e " " • • " " CALCULATION SUMMARY • • • e • •
GROSS EARNINGS
28,669.49
MINUS:
" RETIREMENT PICKUP CONTRIBUTIONS (Non Heart & Lung, or Act 534/632 Earnings) . . . . . . . 1,433.53
EOUALS:
FEDERAL TAXABLE WAGES
27,235.96
• SEE BACK FOR ADDITIONAL INFORMATION
Fscl? 1 ? l?r
Employer's Identification Number
23-2172299
Employer's name, address, and ZIP coda
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF PUBLIC WELFARE
HARRISBURG PA 17120
Employee's Social Securlty Number
191-42-7808
S N MADLINOERmidme, feel
0.............
98 A HERMAN AVENUE
LEMOYNE
1 Nonoualified plans
021-15832
021-2-181-1743-1 10047
191-42-7808 425394 184304
1,777.46
care sex withheld
415.70
rodent core band
Insus. for Box 17 15 Deceased Pension Deferred
Phan Compensation
? ® ?
itY name IO Local wages, tips, etc. 21 Local Income t
--.I .-----•- I ....+...... I awd.ra ILLNUTNE BUBO 1 28,600.49 1 289.-IF-
021-15832
Form W-2 Wage and Tax -- mmeame ma mean •mbmx aeeser .n Is
Staflteant 2000 COPY C - FOR EMPLOYEE'S RECOROS(SEE NOTICE ON BACK OF
COPY B) osexe.tut•eret
n seer ererwulIs to ere na rratum. a negligan n.... 11,".,Mnrnctlon 425394
18 ?b?nlerealler11s1tanp lgrglth,4le ml lgbmll gay?gp{tenka
SUMMARY FOR CALeNDARP YEARL2000 UCTIONS
Your payroll record for the calendar year
e
)
f 2000
m
shows that y ou Theoamounts year-to-
arre a
shown date
your arose pay
torsi for each .
tletluet lore type listetl.
YEAR-TO-DATE
DEDUCTION TE
YEAR ON
DETY
I AMOUNT
TYPE MOUNT
AMOUNT PP
E
SEC
S 1,777,46
FED WTH TX 3,116.19
70
5 H
TA
STATE WTH TX B0Z 73
SOC SEC/MED TX
TX-RES 41
.
236.75
OCC PRIV TX 10 00
057.90
2
LOT WO 433.53
1 SUP ORDER-PA ,
RET P/U CON ,
430.07
UN DUES
Emplloyeef On beck of COPY 51UU t
tax 1. Enter this smoml on the Wages line
of yaw tax return.
tax 2. Enter this amount an the Federal
income lax withhold line of Your tax ratwn.
owned Incom cr dit p Ym? is 11 nedof nee
your Farm 1040 end 1040A.
rare lb ne it you oemployer Paid to You atnt
Incurred on yaw behalf linelUding amounts
from a saction 125 feafelerial plan). Any
amount over $5,000 also is included In box
1. You must COrrlplet Scch ddule Depenunt
1040A) ar Fare 2441.
Care Expenses, to Compute any taxable and
npMSxable a HOU111e.
sex 12. This amount is the taxable fringe
able 10 hauct sexper see that We @la ie
1o fillies benefits; see the Form 1040
instructions.
BOX 12. The following Iis1 explains the
code, Shown in box 10. I ou ma tax
this infarmetion to comp
return.
E - Elective deferrals under a saction (401'bl
salary reduction agreement
C - Electivs end nOnslective deierrels to a
section 457'b) deferred compensation plan
p i Excludable mov to ee (notsincluded sin boxes 1,
paid directly to emP Y
0 or E1
0 - Military employee basic housing, subsistence,
and combat zone Compansel'on'Us• this amount II
you quallfY for EICI
teas 19. If tan "Pensii molten" amount oetnditional
SPSOIS, limits may app Y
IRA contributions You may deduct. if ins "Deferred
compensation" box is checked, me elective
deferrals in ndxforl all Suchgplans to iiwhichl YOU
employers.
500. !bm ve
belong) era gane,efly limited t $10,
deerls lar eectlon 407101 conwsee ue limited to
1110.500r 13,Son in sot a cases, $t000.b Amoluntsha
Sur'Wagesi salariestTlbp ?? c."I" tens)Forma.
1040 Inetrwlrons.
K,s Co C of Form W2 for ef Ieest 2
M t hela arateC will
1 1 1 ke
you beam rase Wlnp Social 1tion tyObeMiNSwaNL
na rd nolor saminoa to a eenlculer veer. Ih?
nil k cord wl\h_
?OUt_
EMPLOYEE W-2 WAGE SUMMARY 2000
0028-7022 00011-0000011
ROBERT S HAMILTON
REMAX REALTY PROFESSIONALS
4775 LINGLESTOWN RD
HARRISBURG PA 17112
FEDERAL WITHHOLDING EXEMPTIONS S 0
PA WITHHOLDING EXEMPTIONS S 0
REGULAR WAGES for 2000 3126.61
For 2000, you have no payroll adiustments which affected lour federal
wages (Box 1) or state wages. Therefore, the wages an your final 2000
check statement should be the same as the wages reported or yo: W.2
statement.
ROSE M WADLINGER
000014-000100 00273 _
PAYROLLS BY MYCHIX'
Form W-2 Wage and Tax Statement 20
00 copy `• for e?Iaree•t reacrb
` M- 22 000014-000100 vtu 1P
?ato?Nh11?N
` "MR`w'S r7 LiIp0 r I fl- a in 'e• • motme
in Isa?apa
REMAX REALTY PROFESSIONALS
""'"'? "? •` "'""'•• 4775 LINGLESTOWN RD
I •tp am.
: ,wee ewe m.IwmMILl
L U
`?
25-1662012 d rwu..v. .....r ..?n .,,,..
191-42-7808 HARRISBURG PA 17112 I3 Soon nom, MG.61 `sow 1Q1M1 or
T
?
°. 8
13 Sw intro. r Boa 13 I" 011W wW ?aIpp
`9899 ?m Ztl NGERr` 's wow°• wow P1 •
2
61 swrr:r m wurw
HERMAN
AVE .
- 45.3
LEMOYNE PA
EM
1
7043 rung wt s 4toso UP,
AIIeu 8818,
Fit twwib
"'Wee"
I rw !m 1 'a 140,7 u r I
I 31rt fegbyr'e sent ID. No.
PA
17927260 U 51,14 wtges, Ilm, oft
3128
1
6 IB Snie I' lu 87
56
lacYC
19PAlryDA weeUP `J IDa •m t
-I- 71 leol alone
m
I . . r
3126.61 31.2
Twnwrm,wn a ewe Axnw'w brw ?nwm fler•••w seat
Form W-2 Wage and Tax Statement 2000 cwY a, to to filed with mPI° '• FEDEM top, return
cZol w
t 0028 022
000014-000100 Vold UP onto
c ROBERTw, seir HNAI LTON
aw d for Trolley
,,..•? ". ,? ,?,,,?„
T REMAX REALTY PROFESSIONALS I reap pet rr ?w
= Ire o, m
wild
er
4775 LINGLESTOWN RD 3126.61 209
.1
t ,.+'•,..• ..•",e'er .,.•« If ,.r. •••'•' ...,,•r ..w. HARRISBURG PA 17112
7 Snow rto<ir,
Sow aiM1 on wiP4w
25-1682012 191-42-7808 6.61
712 193.8
13 5w MM Ir Bet 13 14 now, a Eegltyw's owed, tddrm, r ZIP eod
eap we s
.5 mdo,
a Warr m wra,W
ROSE M WADL INGER 3126.61 45.3
98A HERMAN AVE I son avM1 am E xhx e, um
LEMOYNE PA 17043
1
5 Aewp ed•wr u i..ar we r in
;,luau". ur ? ^'.m ise Y A I
PA 17927260 3126.61 87.56 PA CDAUP 1 3126.61 31.2
n,tnwmtmn eat." wmwa m uw wwwi M.,nw 5tmct
Form W-2 Wage and Tax Statement 2000 Copy 2• to be fI led with Wiry e•a rotor return for PA
t covert meew Vold c Epplpyw9 owed, term, r ZIP rode o, d ft Tree - earn, Mum srnea
0028-7022 000014-000100 ROBERT S HAMILTON as do, IS45-®
15 REMAX REALTY PROFESS IONALS :nap, an
for aw4c,r
:.wee "tee m elVmu
4775 LINGLESTOWN RD 3126.
61 20941
r.w...'•r"".I?...... d u.,v..r•...'•t ..W'v ..w• HARRISBURG PA 17112 _
_
13 Srepa rein, ewp a soy feQirr m "'erne
25-1662012 191-42-7808 3126.61 193.E
13 sw bat M Bm 13 N other • Emplem" now, ,erm, d ZIP coM is Ywoe
ee}t r pm If Wrrve an wewN
ROSE M WADLINGER 3126.61 45.3
98A HERMAN AVE 7 Soon none, row uaw tot
LEMOYNE PA 17043
PA 17927260 1 3126.61 87.56 PA CDAUP 3126.6• 31.2
•
11/ UJ/ LUlu 1Y. 1./
1
IL
D
I1 I1J 1..
RUDGR I R I CRMPIh1C
rm= VD
Patient: Rose M. Wallinga
Ii1RIWe": OO106/1fM9
Pie~ Robert R. Taremw D.D.S.
Pheee:1717j2334944
Ollloe: 1900 Unglestown Road Sts. 306
Harrisburg, PA 17110
Chat
Date: 11/092000
Chad tR00D24 BBk 191-42-7606
1 2 3 4 5 8 7 8 9 10 11 12 13 14 15 18
A0 A i
ovovoa
E9
Todh Description Amount Pat, Deal 9 ha.
1- Retainer am-pore fused-hi nob .1101111101) .244.00 301.00
2 ExUactioneingle tooth 60.00 1740 43.00
2 Extractloo-singta tooth 60.00 17.00 43.00
2 Pontlo-cast high noble metal 40Itl? 241.00 301.00
3 F*sWonsingle tooth 80.00 17.00 43.00
3 Pontlooast high noble metal 516.00 241.00 301.00
4 Pontloeut high noble metal 616.00 241.00 301.00
6 Pbntlocest high noble metal 546.00 244.00 301.00
8 ResifWwwturbot, anterior 70.00 19.00 51.00
6 Retainer em-porn NeW-M nob 646.00 244.00 301.00
7 Realm one surboe, anterior 70.00 19.00 51.00
11 Resin-two turbots, anterior 82.00 20.00 62.00
12 Rbsinwns surface, anterior 70.00 19.00 61.00
Continued on Nwa Page
NF
32 31 30 29 28 27 28 25 24 23 22 21 20 19 18 17
Tlwlwll/In CrI111M1? i I`., . !
Treatment Plan tsttbnats
HMLit tALO- 04
IL.9.740bb KUCtKI
?1/tl7/'Ltltltl 14: L0
K ItK
Chan
bete: 11109IL000
• Pad Rose M.Wadlxlger Chart?:R00024 x:191.42.7808
ekthdi e:05ro6?1946
provider. Robert R. Tenmee D.O.S.
(717 33 4
pl4orta.
own ate. 308
Road
ptllea:1t100 angled
ttarrlebUrg. PA 17110
Treatment Plan P.eDmaw Continued
A nUPAO PAL Dental Ins.
Pl / Todh DeaerlPdarn
r 646.00 244.00 301.00
12 Retainer em-Perc fee"" nob 60.00 17.00 43.00
13Eidnotlon+Ingletooth 645.00 244.00 301.00
13 Pontlo-aet high noble metal 545,00 244.00 301.00
14 pontlo-aet high noble metal 645.00 244.00 301.00
15 Poet high noble metal 545.00 244.00 301.00
10 Retainer crn pore tweed hl nob 80.00 17.00 43.00
17 Dcbaotlen Nn9le tooth
u
' It". -19.8 0,00
00
301
.
peYIO o F
17 lmplard GL? 645.00 244.00 .
17 RdWner orh.porc fused-hl nob 545.00 244.00 301.00
1S Ponvo alt high noble metal 645-00 244.00 301.00
r 19 Pontio-oeet high noble metal 646.00 244.00 301.00
20 Portio-wet high noble metal
80
00 17.00 43.00
21 F,tdnotl0n'$Mgletodh .
546.00 244.00 301.00
21 Pontio wet high noble metal 645.00 244.00 301.00
22 Retainer Or4orc Need-hl nob 545.00 244.00 301.00
27 Ratdner ore-pole Nead-hl nob 80.00 17,00 43.00
28 EAM0110n Ingle tooth 546.00 244.00 301.00
20 PCMUO• Mat high noble metal 645
00 444,00 301.00
29 pontlaast high noble metal .
645.00 244.00 301.00
30 Pontio?eeat high noble metal 00
545 244.00 301.00
31 Ponoo oeet high noble metal .
X45.00 244.00 301.00
22 Rettlnar O"Orc ty""' nob
13362.00 5923.00 7430.00
Treatment Plan TOWS
• Treatment Plane Are SaOmata Only W i I
-f he +ee,?h haute sh'??"L
be. Clv,(8(i 0:5 3. u" + no +
r
dl/k1W 201JU 14: 2J
4
i
Chart
Patient: Rose M. Wedlinger Date: 11109/2000
OW8rdola:061O811949 Chano.,R00024 Sgt 19132-7608
Prowlaes: Retort R. Temmas D.D.S.
Photo: (717)2334044
0111106: 1800 Unplatown Rood Ste. 308
Harrisburg, PA 17110
NO
a
IL
/1 /'1JJ95bb
ROBERT R TERAMAE
PAGE 85
1 2 3 4 5 8 7 8 9v10 11 12 13 14 15 18
g.
AAA n A
a ?oa???oo®o
G3 ® on??ooo ?
e
32 31 30 29 28 27 28 25 24 23 22 21 20 19 18 17
Tmatmant Plan Evarnate
Tooth Daactlpgon - _^ --Anna Pat. DW"Ing.
2Eitractic single tooth 80.00 17.00 43.00
2 Extraction-single tooth 80.00 17.00 43.00
3 0hae0on4 ftle tooth 60.00 17.00 43.00
5lmplarrt 115.00 115.00 0.00
5 Crowm-porn fuse high noble mtl 545.00 240.00 305.00
6 Crown intact 0.00 0.00 0.00
8 Rain-one surface, anterior 70.00 19.00 61.00
6 Crown-pore fuse high noble mtl 546.00 240.00 305.00
8 Crown Insert 0.00 0.00 0.00
7 Reel"ne sufecs, anterior 70.00 10.00 61.00
11 Rosin-two surfaces, anWor 82.00 20.00 82.00
11 Crown-porn Nee high noble mH 545.00 240.00 306.00
11 Crown inert 0.00 0.00 0.00
Continued on Next Pepe
31/09/2000 14:13 7172334566
..
ROBERT R TERAMAE
PAGE 06
Chart
Patient: Ross M. Wadanger
11/09/2000
DIMwdo: 06100/1949 Dale:
Chen t.R00024 > s;19 M0000
P OWWor Robert R. TWernas D.D.S.
Phan: (717)233.49"
Me: 1000 Unglrtown Road Ste. 308
Harrisburg, PA 17110
Treatment Plan tetlmale Continued
nn TOE?°^
11?
a -- - Amount PaR Dental Ina.
12 Raln.one turha, anterior 70.00 19,00 51
00
13 Extraction-singla tooth 00.00 17.00 .
43
00
13 Implant 115.00 115.00 .
0
00
13 Crewn.pore Mae high noble mill 646,00 240.00 ,
305.00
13 Crown Intel 0.00 0.00 0
00
17 Fidraelbn-singlo tooth 00.00 17.00 .
43
00
21 E1dradlon-tingletooth 00.00 17.00 .
43
00
21 Implant 115.00 116.00 .
0.00
21 Cmwn.poro fuse high noble mil 646.00 240.00 306,00
21 Crown Inset 0.00 0.00 0
00
28 EWadlo"Ingle tooth 00.00 17.00 .
43
00
28 Implant 115.00 116.00 .
0
00
28 Crown-porn fuse high noble mtl 646.00 240.00 ,
305.00
20 Crown Inset 0.00 0.00 0.00
•
Treatment Plan Totals 4442.00 2090.00 2340.00
• Treatment Plant Are Estimates Only
-__-
IL
a u wi cuuv a.. w
C
` )
!11,11.000
MUOMMI m IMMW c
rA= to
Chart
PaINM: Roar M, Wedlinger Dar: 11109x2000
Blrthdeb:06MI949 Charta:R00024 08x:19142-7605
Provider: Robert R. TeamM D.D.S.
Photo: (717)2334944
Office: `18W Unglestovm Road Ste. 306
Harrisburg, PA 17110
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
• ®?
00
d O 17 W U ? O® O
t
r
..I
I
Q ? oonnoo
32 31 30 29 28 27 26 25 24 23 22 21 20 19 18 17
lrrxrx Nw ??.? I tawwb a
Traatmard Plan ladmar
Tooth Desorlp"On Amount Pat. Dental Me.
2 Extnotic"Ingle tooth 80.00 17.00 43.00
2 Emotion-single tooth 60.00 17.00 43.00
2.15 MWI Partlel-mNN Bea* WWI 632.00 171.60 360'60
3E)ftellon-single tooth 00.00 17.00 43.00
0 Resin-one surface, anterior 70.00 16.00 51.00
0 CmwnIMM Nee high noble and 645.00 240.00 305.00
0 Crown hue" 0.09 0.00 0.00
7 Resin-one surface, anterior 70.00 16.00 61.00
11 Resimtwo surfaces, antorlor 82.00 20.00 82.00
11 Crown•poro fuss high noble m0 646.00 240.00 305.00
11 Crown Insert 0100 0.00 0.00
12 Rain-one surface, anterior 70.00 16.00 51.00
13 GxtraWon-rinale tooth 60.00 17.00 43.00
Condnued on Nsott Papa
11/UJ/LOVU 1Y. LJ f1fLJJYJ00
M
1?
16
16
MubrMl K 1LKIAMAr
I'Hlat OU
Chet
Penn., Row M. Wsdlln8w DeM:1t108/2000
ebthdess:OG10611WG ChM8:RO0024 3191.42-78011P owMa Robwt R. Tsremse OAS,
PMm:(717)233.4844
Olllw: 1600 Unglestown Road Sts. 306
t4erdebur8, PA 17110
TroMlnad Plan Esgnrsle Congnued
Tooth Deaalpow Amount Pat. Darlalln@.
17 Mac11on-41MI s toOM 60.00 17.00 43.00
18-31 Mend pordal.mstel be" w/sdle 632.00 171.60 360.60
21 Exhwtloneings tooth 60.00 17.00 43.00
28Eftedon-slnBNtooth 80.00 17.00 43,00
Toombnont Plan Tolle 2888.00 1018.00 1847.00
• Trselmsnt Plans Are Estimates Only
m.
Melissa Pee(Gree
Attorney and Counselor at Law
214 Senate Avenue Suite 602
Camp Hill, Pennsylvania 17011-2336
Telephone: (717)763.8995
November 30, 1999
P. Richard Wagner, Esquire
Mancke, Wagner, Hershey & Tully
2233 N. Front Street
Harrisburg, PA 17110
Re: Rose Mary Wadlinger vs. Edward F. Wadlinger
No. 99-4198 Civil Term
Dear Mr. Wagner:
My client has asked whether you and your client may be willing to sit down for a four-way
conference in effort to resolve the economic issues and work towards settlement in their divorce.
Please let me know your client's thoughts on this issue.
I understand that both parties have filed for bankruptcy. Therefore, much of the debt, with
the exception of student loans and tax liens, should be relieved as a result of bankruptcies.
I would also like to have an update on the status of the marital home. I understood that it
was in foreclosure and that the foreclosure had been held off pending the outcome of the
bankruptcy proceedings.
I look forward to hearing from you in early December,
Very truly yo
Melissa Peel Greevy
lp3
cc: Rose Mary Wadlinger
MPG/csj
d ff
1 'A
7 k,,,n-hg ?M
Me(issa Peelaree
Attorney and Counselor at Law
214 Senate Avenue Suite 602
Camp Hill, Pennsylvania 17011.2336
Telephone: (717) 763-8995
May 19, 2000
P. Richard Wagner
Mancke, Wagner, Hershey & Tulley
2233 N. Front Street
Harrisburg, PA 17110
Re: Wadlinger
Dear Rich:
I understand that the couple's marital home is again scheduled for Sheriffs Sale on June 9,
2000. My client informed me that there may be an offer on the house which would require a pre-
settlement lease on the part of your client. However, he has informed her that he does not intend
to have to pay to live there. As you know, he has been living there rent and mortgage-free for
quite some time now. Additionally, the couple's daughter will be graduating from high school in
early June.
My client would like to bring this matter to a conclusion. However, we have not
discussed settlement with your office. If you think that your client might be willing to sit down
and have reasonable negotiations in the context of a four-way conference, please contact my
office within the next 10 days to schedule a future appointment for that purpose. If I do not hear
from you within that period of time, I will assume that your client is not agreeable to settlement
negotiations and I will proceed to prepare my client for a master's hearing before Mr. Elicker to
resolve these economic issues and bring this matter to its conclusion. .
Kindly have your client prepare an Income and Expense Report so that we are able to
consider what may be realistic in terms of an alimony obligation on his part. I look forward to
receiving this from your office at your earliest convenience.
Very truly yours,
2?: 7Oj
Greevy
cc: Rose Wadlinger
MPG/cj 716-tri-{t A
cac l1 1, ?`?'
1&??,
McCirssa 2'ee(i
Attorney and Counselor at taw
214 Senate Avenue, Suite 105
Camp Hill, Pennsylvania 17011.2336
Telephone: (717) 763.8995
August 2, 2000
Richard Wagner, Esquire
M ancke, Wagner, Hershey & Tully
2233 North Front Street cO p
Harrisburg, PA 17110
Re: Rose.NIary Wadlingerv. Edward F.Wadlinger
No. 994198 Civil Term
In Divorce
Dear 5 9 ard:// _ ?`1--1
I have been informed that the parties' home was sold at Sheriffs Sale on or about June 7.
2000. 1 understand that our client has relocated to 216 West Simpson Street in Mechanicsburg.
Pennsylvania.
Our clients have received the enclosed letter indicating that there are proceeds in the
amount of $5999.40. I understand that our clients plan to pick up the check on Monda%. August
7. 2000. They have not reached an agreement regarding the disposition of these funds, nor the
overall distribution of the marital estate. Therefore, I would propose the following:
I . The IRS debt from 1996 in the amount of approximately $1334.76 should be paid
immediately to avoid further interest and penalty.
2. The parties should sign a Stipulation agreeing that the funds remaining from the
sale of the home should be held by you or I, in escrow, pending an agreement. I believe the entire
remaining amount should go to my client in partial compensation for the losses caused by ) our
client as described in greater detail in paragraph 4 below.
3. The Parties' PSERS pensions should be valued and amounts transferred via the
appropriate DRO to make the pension values equal.
4. It is our position that Mrs. Wadlinger should be compensated for the reduction in
the proceeds from the sale of the marital home due to your client's acts and omissions . We will
review the documentation of payments made after the sale of the home to teach an agreement on
the amount for which my client should be compensated for your client's failure to pay the
mortgage since July 1, 1998 while continuing to reside therein. The expenses at sale, including
but not limited to the following, should be attributable solely to your client:
41
P. Richard Wagner, Esquire
Page Two
August 2, 2000
• Interest, (This figure was $3841.13 for the period from June 1, 1998 through
January 1, 1999.)
• Attorney's Fees,
• Cumulative Late Charges,
• Cost of Suit, and
• Title Search,
• Real estate taxes (the 1999 taxes were approximately $1600) and,
• Unpaid water and sewer bills.
Your client should make monthly payments to my client to reimburse her for these losses.
Said payments would be in the form of equitable distribution and therefore non-taxable income
to my client. I would require that the language of the settlement agreement would indicate that
the payments would be non-dischargable in bankruptcy.
I realize that you have taken the position that my client was as obligated on the mortgage
as was your client. However, it cannot be over looked that your client lived with no mortgage or
rent payment for the period of two years, to the detriment of my client's interest. In fact, his
recent statement to her on this point was "That's how the game is played".
5. Alimony: Your client will pay my client alimony in the amount of $200.00
per month, terminating upon the death of either party, or my client's remarriage or cohabitation.
I have instructed my client not to sign the check until, at minimum, we have a Stipulation
with regard to the immediate payment of the 1996 IRS debt and the balance remaining in escrow
pending the finalization of the economic issues and completion of the divorce agreement.
If your client is unwilling to proceed on these terms, please advise. At that time, I will
advise her we should proceed with a Motion to Appoint a Master and prepare to litigate all of
her claims, seeking an alimony awards for an indefinite period as is traditionally awarded in
Cumberland County. In the mean time, I expect that we will be filing an APL petition within the
next week.
I look forward to hearing from you within ten days of the date of this letter.
Very truly ?r?n
LA
Enc. Melissa Peel Greevy
cc: Rose Mary Wadlinger
MPG/jav
d
A THOMAS kLINF
SnFda 1v4:4, R :I?Gcn iU\'
EO'NAA.t I.. S ;HgnPP e! ":,?•?
&qw;w PA, ur:R. j.
OPPICE OF THE SHER;7F
OnE ca;rtlv,j3P Sy:;nrP
Cacisla, PPnrl;ytra-,n 17013
July 26, 2009
Ro. a Wadlhv,:r
98•A Hctmall Avenue
Lemoyne, VA 1704
Dear MS Wiilinger:
Reference to Silcriff s Sale held on June 7, 2000 at which time your properly located al
117 Indian Cretk Road. Paecil.•ul:csburg was sold
1 nm writing W advisr yin' that aver the 1rongage and MI other cuss were paid there is
a balance rem:mug ofS ? 9y9.40 which you are entitled to. 711e check will be erittei in
both names so 1 and asking thet -..u and Edward Wadlinue, conic to the Sherifr's Office
!o pick up the check.
I and also \! riling to Edwara asking him tt• make arrangements to come to this offiee to
pick up check.
VC7 Mlly yoprs.
c rc«.., ,.,Patricia silatto
heal Estate Deputy
ROSE MARY WADLINGER,
V.
Plaintiff,
EDWARD F. WADLINGER,
Defendant.
I N THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO: 99-4198 Civil Term
CIVIL ACTION - LAW
IN DIVORCE
DEFENDANT'S ANSWERS TO PLAINTIFF'S
INTERROGATORIES
AND NOW, comes the Defendant, Edward F. Wadlinger, by and through his
attorneys, Mancke, Wagner, Hershey & Tully, and files the following Answers to
Interrogatories:
1. List the name of each employer, the beginning and ending date of all
employment held by you with each, whether fill time or part time, permanent or
temporary, for the years 1996 through 2000.
Answer: A. Department of Agriculture
September of 1987 to the present
B. The Mechanicsburg Club
May of 1989 to November of 1998
C. Lowe's
April of 1996 to October 1996
D. Phar-Mor
March 1997 to August of 1998
r
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aa?
?Cwlt'?%V/S
EVA L4 -
E. Eltra Tech
March of 1997 to October 2000
F. Patriot News
August 2000
G. Martz Marketing
February 1998 to present
2. State the beginning and ending date of the first period of your employment
with Commonwealth of Pennsylvania. State the beginning date of the current period
of employment with the Conunonwealth of Pennsylvania.
Answer: November of 1975 to December of 1985. Thereafter, Defendant
returned to work September of 1987 and continues to work as of the
present.
I State the basis of the frozen present value debt in the amount of
$45,172.64 as listed on the attached 1999 Statement of Account for your State
Employees' Retirement System account.
Answer: The Defendant contacted the legal department of SERS and was
advised that this is not a debt but a frozen amount of pension to which
the Defendant is entitled should he choose to buy it back. Defendant
reasonably believes that when he retired in December of 1985, he
removed money from his pension fund. When he returned to
employment in September of 1987, in order for him to be otherwise
current as of today, as though he had not left the state, he would have r
to re-contribute $45,172.64.
?af
3. For the period during which you resided in the former marital home at 217
Indian Creek Drive and did not pay the mortgage, complete the attached income and
expense statement.
Answer: See Exhibits A and B attached hereto.
Respectfully submitted,
Mancke, Wagner, Hershey & Tully
By.
I P. Richar agn5VEsq
I.D. #2 03
2233 No t Front Street
Harrisburg, PA 17110
(717) 234-7051
Attorneys for Defendant
Date: 1111 d/
VERIFICATION
1, Edward F. Wadlinger, the within named Defendant, do verify that the facts contained in
the foregoing Answers to Plaintiffs Interrogatories are true and correct to the best of my
knowledge, information, and belief. I understand that false statements in these Answers are made
subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities.
Date: //q/D/
Edward F. Wadlinger ?
Income 7-31-98 to 531-00
Gross Deductions Net
Agriculture $ 69,879.34 $17,129.48 $ 52,749.86
Mechanicsburg Club $ 680.00 $ 77.90 $ 602.10
Ultra-Tech $ 6,864.00 $ 1,127.92 $ 5,736.08
Phar-Mor $ 114.75 $ 13.15 $ 101.60
Martz Marketing $ 837.00 $ 123.14 $ 713.86
Total $ 78,375.09 $18,471.59 $ 59,903.50
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ROSE MARY WADLINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99 - 9198 CIVIL
EDWARD F. WADLINGER,
Defendant IN DIVORCE
TO: Melissa Peel Greevy , Attorney for Plaintiff
P. Richard Wagner Attorney for Defendant
DATE: Monday, December 9, 2000
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
Counsel have agreed to obtain Pension present valuations.
Reque9t for Production of Documents and Interrogatories were
served upon Defendant's counsel via U. S. Mail on December 15,
2000 to complete discovery and update information previously
provided in informal discovery. There are no outstanding disco-
very motions.
i
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
It is expected that Defendant will complete discovery responses
on or before January 15, 2001. Year end retirement account state-
ments may be need to be provided as a supplemental response in
the event that there is a delay in receipt from the employer.
DATE COUNSEL FOR PLAINTIFF
COUNSEL FOR DEFENDANT ( )
NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
ROSE MARY WADLINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 99 - 4198 CIVIL
EDWARD F. WADLINGER,
Defendant IN DIVORCE
CONFERENCE WITH
(O 1N E AND PARTIES
TO: Melissa Peel Greevy Counsel for Plaintiff
Rose Mary Wadlinger Plaintiff
P. Richard Wagner Counsel for Defendant
Edward F. Wadlinger Defendant
A conference has been scheduled at the Office of
the Divorce Master, 9 North Hanover Street, Carlisle,
Pennsylvania, on the 20th day of August, 2001, at 9:00 a.m.,
with counsel and the parties to discuss the outstanding
economic issues to determine if there is a basis of
settlement of claims. If issues remain after the
conference, a hearing will be scheduled at another date.
Very truly yours,
Date of Notice: 6/22/01 E. Robert Elicker, II
Divorce Master
ROSE MARY WADLINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 99 - 4198 CIVIL
EDWARD F. WADLINGER,
Defendant IN DIVORCE
NOTICE OF PRE-HEARING CONFERENCE
TO: Melissa Peel Greevy
P. Richard Wagner
Attorney for Plaintiff
Attorney for Defendant
A pre-hearing conference has been scheduled
at the Office of the Divorce Master, 9 North Hanover Street,
Carlisle, Pennsylvania, on the 22nd of June, 2001, at 9:30
a.m., at which time we will review the pre-trial statements
previously filed by counsel, define issues, identify
witnesses, explore the possibility of settlement and, if
necessary, schedule a hearing.
Very truly yours,
Date of Notice: 4/26/01 E. Robert Elicker, II
Divorce Master
ROSE MARY WADLINGER
IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
99 - 4198
Vs. NO. CIVIL 19
EDWARD F. WADLINGER
IN DIVORCE
Defendant
STATUS SHEET
DATE: I., ACTIVITIES:
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...1VIA
ROSE MARY WADLINGER,
Plaintiff
VS.
EDWARD F. WADLINGER,
Defendant
TO: Melissa Peel Greevy
P. Richard Wagner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 4198 CIVIL
IN DIVORCE
Attorney for Plaintiff
Attorney for Defendant
DATE: Monday, December 4, 2000
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
?r
,t.
r
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
DATE COUNSEL FOR PLAINTIFF ( )
COUNSEL FOR DEFENDANT ( )
NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
;:y
McCissa Pee[ ree
Attorney and Counselor at Law
214 Senate Avenue, Suite 105
Camp Hill, Pennsylvania 17011-2336
Telephone: (717) 763.8995 November 6, 2001
E. Robert Elicker, H., Esquire
9 North Hanover Street
Carlisle, PA 17013
Re: Rose Mary Wadlinger v. Edward F. Wadlinger
No. 99-4198 Civil Term
Dear Mr. Elicker:
I am writing to inform you that the parties to the above action executed an agreement
effective October 26, 2001 resolving all claims for which you were appointed. Therefore, with
concurrence of P. Richard Wagner, Esquire, who represents the Defendant, I respectfully request
your appointment be vacated. Two copies of the executed Separation and Property Settlement
Agreement are enclosed.
Very tru yours,
Melissa Peel Greevy
MPG/jv
cc: Rose Mary Wadlinger (w/o enc.)
P. Richard Wagner, Esquire (w/o enc.)
uW OFFICE/
MANCKE, WAGNER. HERSHEY & TULLY
3213 NORTH FRONT STREET
JOHN D. MANCKE: HARRISMURO. PA 17110
P. RICHARD WAGNER
DAVID E. HERSHEY
WILLIAM T. TULLY
April 18, 2001
E. Robert Elicker, Esquire
9 North Hanover Street
Carlisle, PA 17013
Re: Wadlinger v. Wadlinger
No: 99-4198
Dear Mr. Elicker:
PHONE 17171 214.7091
PAX 17171 214.7090
Enclosed herein please find a Pre-Trial Statement on behalf of the Defendant,
Edward F. Wadlinger.
Your attention is appreciated.
P. Richard-
PRW/dks
Enclosure
cc: Melissa P. Greevy, Esq. (w/encl.)
McCtssa Pee!(
Attorney and Counselor at Law
214 Senate Avenue, Suite 105
Camp Hill, Pennsylvania 17011.2336
Telephone: (717)763.8995
December 15, 2000
Office of the Divorce Master
E. Robert Elicker, Esquire
9 North Hanover Street
Carlisle, PA 17013
Re: Wadlingerv. Wadlinger
No. 99-4198 Civil Term.
Dear Mr. Elicker:
Enclosed is the Certification regarding the above-captioned matter.
Very tr ly yours,
Melissa Peel Greevy
Enc.
cc: P. Richard Wagner, Esq.
MPg/jav
`J
i
,t?
McCsssa Peefareevy
Attorney and Counselor at Law
214 Senate Avenue, Suite 105
Camp Hill, Pennsylvania 17011.2336
Telephone: (717)763.8995
May 24, 2001
E. Robert Elicker,ll., Esquire
Office of the Divorce Master
9 North Hanover Street
Carlisle, PA 17013
Re: Wadlinger v. Wadlinger
Dear Mr. Elicker:
Enclosed as an update is the May 20, 2001 statement for the Commerce Bank Account
which is holding the proceeds from the sheriffs sale of the marital home. By copy of this letter
and enclosure, Mr. Wagner is also provided with this update.
Very y yours,
4?
Melissa Peel Greevy
MPG/jv
cc: Rose Mary Wadlinger
P. Richard Wagner, Esquire
LAW O311CLL
MANCKE, WAGNER, HERSHEY & TULLY
2233 NORTH WONT LTRLLT
JOHN 0. MANCKL
P. RICHARD WAGNLR HARRISBURG. •A ,)110
DAVID K. HLRSIRY
WILLIAM T. TULLY
April 24, 2001
E. Robert Elicker, Esquire
9 North Hanover Street
Carlisle, PA 17013
Re: Wadlinger v. Wadlinger
Dear Mr. Elicker:
PHONL 17171 234.7001
PAX 17171 204.7000
Recently I submitted a Pre-Trial Memo on behalf of Mr. Wadlinger and
inadvertently indicated that Mrs. Wadlinger had not paid child support for the child.
Apparently, before my involvement, Mr. Wadlinger, on his own, had filed a
child support action and in fact, Mrs. Wadlinger was paying child support to him on
behalf of the daughter.
I regret any inconvenience for this omission, but it was certainly
unintentional.
Your attention is apprecial
P. Richard Wagner
PR W/dks
cc: Melissa P. Greevy, Esq.
LAW OFFICES
MANCKE, WAGNER, HERSHEY & TULLY
3333 NORTH FRONT STREET
JOHN B. MANCKE
P. RICHARD WAGNER HARRISBURG. PA 11110
DAVID E. HERSHEY
WILLIAM T. TULLY
December 5, 2000
AREA CODE ]iT
3]4•]071
E. Robert Elicker, Esquire
9 North Hanover Street
Carlisle, PA 17013
Re: Wadlinger v. Wadlinger
No: 4198 Civil 1999
Dear Mr. Elicker:
Enclosed herein please find the Certification regarding the above-captioned
matter.
Your attention is appreciated.
Sincerely;-
l
P: Ric ' rd Wagner
PRW/dks
Enclosure
cc: Melissa Peel Greevy, Esq. (w/encl.)
H
I
ROSE MARY WADLINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99 - 4198 CIVIL
EDWARD F. WADLINGER,
Defendant IN DIVORCE
TO: Melissa Peel Greevy Attorney for Plaintiff
P. Richard Wagner , Attorney for Defendant
DATE: Monday, December 4, 2000
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
i
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
MOO-
DATE UNS^ PLAINTIFF ( )
UNSEL FOR DEFENDANT (?-}-
NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
Melissa Ped
Attorney and Counselor at La- w
214 Senate Avenue, Suite 1 o5
Camp Hill, Pennsylvania 17011-2336
Telephone: (717) 763-8995
E. Robert Elicker, Esquire
9 North Hanover Street
Carlisle, PA 17013
March 22, 2001
Re: Wadlinger v. Wadlinger
No. 4198- Civil Term 1999
Dear Mr. Elicker:
You were appointed to serve as Master to all claims in the above referenced matter on
November 27, 2000. The defendant's discovery responses have been received, the pensions have
been valued and a copy of said valuations have been provided to opposing counsel. My client's
income and expense statement and inventory were filed on November 27, 2000. Kindly consider
now our request for a pre-hearing conference with counsel.
Very tru ours,
Meliss Peel Greevy
cc: Rose M. Wadlinger
P. Richard Wagner
MPG/jv
OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle. PA 17013
(717) 240-6535
E. Robert Elicker, 11
Divorce Master
West Shore
697-0371 Ext. 6535
Traci Jo Colyer
Office Manager/Reporter
Melissa Peel Greevy
Attorney at Law
214 Senate Avenue, Suite 105
Camp Hill, PA 17011-2336
March 23, 2001
P. Richard Wagner, Esquire
MANCKE, WAGNER, HERSHEY & TULLY
2233 North Front Street
Harrisburg, PA 17110
RE: Rose Mary Wadlinger vs. Edward F. Wadlinger
No. 99 - 4198 Civil
In Divorce
Dear Ms. Greevy and Mr. Wagner:
I am writing in response to Ms. Greevy's letter of March 22, 2001, indicating that
discovery issues have been resolved, particularly with regard to the pension valuation.
Consequently, I will go forward with the directive for pretrial statements.
This action was commenced by the filing of a divorce complaint on July 9, 1999,
raising grounds for divorce of irretrievable breakdown of the marriage and the economic
claims of equitable distribution and alimony.
In accordance with P.R.C.P. 1920.33(b) I am directing each counsel to file a
pretrial statement on or before Friday, April 20, 2001. Upon receipt of the pretrial
statements, I will immediately schedule a pre-hearing conference with counsel to discuss
the issues and, if necessary, schedule a hearing.
Very truly yours,
E. Robert Elicker, II
Divorce Master
Ms. Greevy and Ms. Wagner, Attorneys at Law
23 March 2001
Pave ?
NOTE: Sanctions for failure to file the pretrial statements are set
forth in subdivision (c) and (d) of Rule 1920.33.
THE ORIGINAL PRETRIAL STATEMENT SHOULD BE FILED
IN THE MASTER'S OFFICE AND A COPY SENT DIRECTLY
TO OPPOSING COUNSEL.
FAILURE TO FILE PRETRIAL STATEMENTS AS DIRECTED
BY THE MASTER MAY RESULT IN THE MASTER'S
APPOINTMENT BEING VACATED.
JOHN S. MANCKE
P. RICHARD WAGNER
DAVID E. HERSHEY
WILLIAM T. TULLY
LAW OFFICES
MANCKE, WAGNER, HERSHEY & TULLY
2233 NORTH FRONT STREET
HARRISSIIRO. PA 17110
August 8, 2001
E. Robert Elicker, Esquire
9 North Hanover Street
Carlisle, PA 17013
Re: Wadlinger v. Wadlinger
Dear Mr. Elicker:
PHONE 17171 234.70:1
FAN 17171 234.7080
It would appear that the above-captioned matter has been settled, and
accordingly, I would ask that the hearing be canceled. I enclose a copy of Ms.
Greevy's letter verifying the same.
Your attention is appreciated.
PRW/dks
elv_
P. ichard
Enclosure
Melissa Pee((
Attorney and Counselor at Law
214 Senate Avenue, Suite 105
Camp Hill, Pennsylvania 17011-2336
Telephone: (717) 763-8995
P. Richard Wagner, Esquire
Mancke, Wagner, Hershey & Tully
2233 North Front Street
Harrisburg, PA 17110
August 3, 2001
Re: Wadlinger v. Wadlinger
Dear Rich:
I have spoken with my client regarding the terms discussed at the pre-trial conference.
She, too, has indicated a willingness to settle the matter along the lines of the terms discussed.
Kindly prepare a Property Settlement Agreement consistent with the terms in your letter of July
31, 2001. I will be out of the office the week of August 13, 2001. However, I will look for your
draft upon my return.
Thank you for taking care of notifying Mr. Elicker that we will not need the August 20,
2001 date. You may use copy of this letter to indicate my concurrence in canceling that date.
Very truly rs,
Melissa Peel Greew
cc: Rose M. Wadlinger
MPG/jv
(? `R is
l il
Melissa Peel
Attorney and Counselor at Law
214 Senate Avenue, Suite 105
Camp Hill, Pennsylvania 17011.2336
Telephone: (717)763.8995
August 10, 2001
E. Robert Elicker, II.
Office of the Divorce Master
9 North Hanover Street
Carlisle, PA 17013
Re: Wadlinger v. Wadlinger
No. 99-4198 Clvil Term - In Divorce
Dear Mr. Elicker:
It appears that the parties have reached an agreement on the settlement of their economic
claims. However, the draft document has not yet arrived from Mr. Wagner's office for review
that and execution by the parties. Therefore, I request, and it appears that my co-counsel wou.
aldUponagree
there should be a continuance of the conference date for August 20, 2001 at 9:01
.m
the happening ofa fully executed settlement agreement, your office will be timely notified.
Thank you for your assistance in this matter.
r Very?t Yo
Melissa Peel Greevy
MPGjv
cc: Rose M. Wadlinger
P. Richard Wagner, Esquire
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennwly' nia p1 " 0 ?Y-4r/qpo d"/v/G xO Original Order/Notice
Co./City/Dist. Of CUMBERLAND AP;FS 7,13/6/V94;
O Amended Order/Notice
Date of Order/Notice 10/19/00 90910% O Terminate Osier/Notice
Court/Case Number (See Addendum for case summary)
Employer/WilhWdWs Federal EIN i umlxr
COMMONWEALTH OF PA
Employer/Wlthholder's Name
C0 PAYROLL OPERATIONS
Employer/WlthholdvFs Address
PO BOX 8006
HARRISBURG PA 17105-8006
RE: DLINGER, EDWARD F.
Mployee/Obiigor's Name (Last, First, MI)
1 175-40-6934
Employee/Obligor's Soci 71
Securly Number
I 9500100003
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names assodated with cases on affachmeno
1 Cuslwlial Parent's Name (Last, First, MI)
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
8 99. 00 per month in current support
$ 51. 00 per month in past-due support Arrears 12 weeks or greater? Oyes O no
$ _ o - 00 per month in medical support
$ o. 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 150.00 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:
$ 34 - 6,2 per weekly pay period.
$ 69.23 per biweekly pay period (every two weeks).
$ 7s. oo per semimonthly pay period (twice a month).
$ 1 so. oo per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on pg. 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877.676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106.9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
DRO: RJ Shiadday BY THE COURT:
xc: defendant .
Date of Order: October 23, 2000
Form Service Type M VMB N., OM0154/ Wo kerND28
F.,44bn oaa 11bV00 $ IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
? If checked you are required to provide a copy of this form to your employee.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment
to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to
each employee/obligor.
3.• -Reps rningthe-Paydat&Date-of-Withhotding---/ouynustrepertthr. paydate/dmofwithholdingwhen sendingthe-payment.- h
paydat&WvtL withholding-irthe-date-enwhich-amnuntwas-withhekHmmrthcemPloyee`rwages: You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4.` Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support
against this employeeobligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must
follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest
extent possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employeelobligor 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: 2321722990
EMPLOYEE'S/OBLIGOR'S NAME: WADLINGER EDWARD F.
EMPLOYEE'S CASE IDENTIFIER: 9500100003 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should
have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs
unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
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 employeelobligor because of a support withholding.
Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is
employed governs.
9,. Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.S.C. 31673 (b) 1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes.
10.
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
Requesting Agency: If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
DOMESTIC RELATIONS SECTION by telephone at (717) 240.6225 or
o n BOX 1'1D -
CARLISLE PA 17013 by FAX at (717) 94n-6248 or
by Internet
Page 2 of 2 Form EN-028
Worker ID $IATT
Service Type M OMBNndpVi1
[.nlmmn Datcam ILnroo
ADDENDUM
Summarv of Cases on Attachment
Defendant/Obligor: WADLINGER, EDWARD F.
PA d1 N (mbar 710301496/.Zg"A PACSES Case Number
Plaintiff Name Plaintiff Name
ROSE M. WADLINGER
Docket AttachmentAmount Docket Attachment Amount
99-4199 CIVIL$ 150.00 $ 0.00
Cltild(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB
?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.o0
Child(ren)'s Name(s): DOB
?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
$ 0.00
Child(ren)'s Name(s): DOB
?Ifchecked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Service Type M
Addendum
OMB No.; 0910.0154
Eap1m6on Dale V/31100
?lf 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
?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.
Child(ren)'s Name(s): DOB
? 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 mount
$ 0.00
Form EN-028
WorkerlD $IATT
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ROSE M. WADLINGER,
Plaintiff/Petitioner
VS.
EDWARD F. WADLINGER,
Defendant/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 99.4198 CIVILTERM
IN DIVORCE
DR# 28,992
Pacses# 713101496
DEMAND FOR HEARING
DATE OF ORDER: October 19, 2000
AMOUNT: $ 150.00 per month
FOR: Alimony Pendente Lite
REASON(S):
Wife has not actively pursued the divorce action in this
matter and wife has no need for $99.00 per month.
/?/30l o-?
Dates
Mailw copies
AI7
- 00 to: plaintiff
Arty Greevy
Arty Wagner
v
PARTY FILING DEMAND FOR HEARING:
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Penn l m f' _9- y_y2 C'?u?C
CO./City/DISC. Of CUMBERLAND //?\ 0Original Order/Notice
Date of Order/Notice 05/04/005/04/01 Amended Order/Notice
C0 /Case Number (See Addendum for case summary) Q Terminate Order/Notice
Employer/Wilhholder's Federal EIN Numlvr
C tM10NNEALTH OF PA
Employelhholder s Nam,
CPAYROLL OPERATIONS
Empioyer/4i 01,ldersPERA
PO BOX_8006
HARRISBURG PA 17105-8006
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ X99. 00 per month in current support
$ o. 00 per month in past-due support 0 00 per month in medical su Arrears 12 weeks or greater? Qyes (R) no
$ PPort
0 0o Per month for genetic test costs
$ per month in other (specify)
fora total of $ 99. 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:
$_ .Uperweeklypayperiod.
$ 45, 69 per biweekly pay period (every two weeks).
$?49, so per semimonthly pay period (twice a month).
$ 99, oo per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information Is
needed (See #9 on pg. 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1.877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER /D (shown
above as the Employee/Obligor's Case identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
)RE:WADLINGER EDWARD F.
Employee/Obligor's Name (last, First, MII
1 175-40-6934
Employee/Obligor, Social Se[udly Number
1 9500100003
Employee/Obligor's Cas, Irlenti0er
1 (See Addendmn for Plaintiff names associated with cases on attachmen0
> Custodial Pamnl's Name (Lasl, First, MU
1
DRO: RJ Shadday BY THE COURT:
xc: defenlant
Date of Order: May 29, 2001 ?y
-
Kevin C?C,e ?'X ) ? t)1 less ?JUDGE
Service Type N Form EN-028
osm nn,: nvrva s? Worker I D
I/ rte.
Q. tmloVon o+m: irmroe $IATT
J
i
ti
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
? If checked you are required to provide a copy of this form to your employee.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee%bligor's income in a single payment
to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to
each employee/obligor.
3.• -Reportingihe-PeydaWDare-ttFWithhold'
paydaMdateofwithhold'mgis mg-You-mtwithheom a rJdaoyn 's-thholdingwsernl?
thedatcnnwhichmmountwaswhhheld{4d*mm-th ?thcemphtyee'swager; You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4.• Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support
against this employee%obligorand you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must
follow the law ofthe state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest
extent possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employeelobligor 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: 2321722990
EMPLOYEE'S/OBLIGOR'S NAMF: WADLINGER EDWARD F.
EMPLOYEE'S CASE IDENTIFIER: 9500100003 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should
have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs
unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from
employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding.
Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is
employed governs.
9.` Withholding Limits: You may not withhold more than the lesser of 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes.
10.
"NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
Requesting Agency:
DOMESTIC RELATIONS SECTION
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 (71 7) 240-6248 or
by Internet
Service Type M
Page 2 of 2
OMB No.: 097M 154
hplnrion e,tc 1]b 1N0
Form EN-028
Worker ID $IATT
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: WADLINGER, EDWARD F.
PACSES Case Number 713 10 14 9 6/,?Dq1,;? PACSES Case Number
Plaintiff Name Plaintiff Name
ROBE M. WADLINGER
Docket Attachment Amount Docket Attachment Amount
99-4198 CIVIL$ 99.00 $ 0.00
Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB
?If checked, you are required to enroll the child(ren) ? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available identified above in any health insurance coverage available
through the employee's/obligor's employment. through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? 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
?If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Service Type M
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? 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
? 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.
Addendum
OMH No.: 09700154
1 •ylration Date. 1341/00
Form EN-028
Worker ID $IATT
a ?
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= _Call.
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?
Commerce BanklHarrisburg N.A.
Commerce too Senate Avenue
P.O. BOX 9599
??ank Camp Hill, PA 17011
ROSE MARY WADLINGER
MELISSA PEEL G,?FEVY ESCROW AGENT
214 SENATE AVENUE SUITE 105
CAMP HILL PA 17011
RECRYED
1 DATR
\1u Kr 610
STATEMENT DATE
05/20/J1
ACCOUNTNO.
0517271811 .
*** CHECKING *** MONEY MARKET BUS. BEGINNING RATE 1.40000
ACCOUNT NUMBER 0513231811 TAX 10 NUMBER 191-42-7808
PREVIOUS STATEMENT BALANCE AS OF 04/20/01 .... 59102.71
PLUS 1 DEPOSITS AND OTHER CREDITS 4.38
LESS O CHECKS AND OTHER DEBITS.*. .00
CURRENT STATEMENT 13ALANCF. AS OF 05/20/01 ..... 5.107.09
NUMBER OF DAYS IN THIS STATEMENT PERIOD 30
------------------------------------------------------------
*** CHECKING ACCOUNT TRANSACTIONS ***
DATE DESCRIPTION DEBITS CREDITS
04/24 RATE CHANGE TO 1.00500 .00
05/20 INTEREST PAYMENT 4.38
------------------------------------------------------------
*** BALANCE BY DATE ***
04/20 5,102.71 05/20 5.107.09
PAYER FEDERAL ID NUMBER 23-2324730
INTEREST PAID YEAR TO DATE 37.40
----------------------------------------------------
*** INTEREST'`:EARNED-THISST'ATEMENT'PERIOD ***
DAYS IN PERIOD 30
INTEREST EARNED ;pt?; •r••••••.••••ea•••.•••.. 4.38
ANNUAL PF_RCENT'A6•L''YIELD"EARNED {APY).... 1.05%
------------- -----------
lialpff -16- ;
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rgL?
NOTE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION
rcu vi V4 "LW UI'L4 11, ."4.
Z 895 783 767
EDWARD F A ROSE M NADLINGER
217 INDIAN CREEK DR
NHCIIANICS)IURL PA 17055-2527178
Dale;
NOV. 10, 2000
Taxpayer Idenrayrng Number.
175-40-6934 A 04
MI
Comael Telephem Numhar,
TOLL FREE; 1-800-1129-7650
BEST TIME TO CALL,
8100 AM To 4,30 PN
TUESDAY, WEDNESDAY AND THURSDAY
Oeparhantofthe Treasury
Internal Reverie Service
P.O. BOX 57
BENsA.EM,PA.Ism
Final Notice - Notice at Intent to Levy and Notice of Your Right toe Hearing
Please ResPond Immediately
You Invo not paid your fed: ral tax. We Previously asked you to pay but we still haven't
received 11111 payoienL Tlds lvitor is your notice of our intentto levy under Internal Revenue
Code Section (IRC) 6331 and yournonce ors right to receive Appels cousldention under IRC
0330. P1.11ASRCALL.I1 i IMMrirXU'ELY scene of the telephone numbors shown above if
you recently made a payment or can't pay tho amount you owo,
We may file a Notice of Cederal Tax Licn at anytime to protect the government's interest A
lion is public noticu to your creditors that the government has a right to your interests in your
curr8nl assets and asms you acquire after we file alien.
if you don't pay this enwunt, make nlternative arrangements to pay, orrequest Appeals
cousidornllon within 30 days 1}our the dale of this letter, we may take your property orrigbia to
property such se real estate, automobiles, business assets, bank accounts, wages, commissions,
and other inconto to collect the snrmmt you owe. Ree the enclosed Publication 594,
Understanding the Collection Process, for additional Information about this sad see publication
1660 which explains your right to it hearing. '1'ho enclosed Form. 12153 is used to requost a
hcarln;.
'i'o prevent enforced collection actions, please send us full payment today for the amount you
utve shown on the beck of this letter. Make your check or money orders able to the, united
NlatusTreasuty. Wdteyour social security number oremployerientifcstionnumber andthe
tax year ou yourpayment, Send yourpnyment In the enclosed envelope with a copy of this
idler.
upyurletier
Poem 11153 L. a. Dip
Chief, Automated C olleclion Branch
Putak;ation $94
PnbllcsYnu 1660
rinvdulr
r'1754G69Jaiol+
Letter 1058 (Rev. 01.1999x1.7 11)
Department of the Treasury •• tntemal Revenue 5trvice
4xa- ??-! >6`?3
To THE
ORDER
DATC O2 '/3-0/
00-1541
317
DOLLARS M19
comme/Ce
"Ba??nppp CAMk ?/NNUNbap, NA
S NjU! AMl0I I
FOR 10/5 '6)•'Gb L '7 6 -HD- b ?i 3 o ?
,4:0 3 i 30 1846': SL
3 2 3 181 iii'
11I VJI LYVV J1. LJ
' ILILJJIJVV
Pedant: Ross M. Wedlinger
®Irtlrds4/: O8I08/194p
Prw~. Robert R. Teramse D.D.S.
Photo: (717)233.4944
CHOW ta00linglestown Road Ste. 309
Harrisburg, Pa 17110
1\VULI\1 1\ Ill\h11'MK.
Chart
Chat W.R00024
Dale: 11109/2000
sar: 101-42-7908
1 2 3 4 5 8 7 8 -_•
9 10 11 12 13 14 13 18
Q4 CD c0o -
"vvwu u V I M,?
®'I®e Qua l?n
32 31 30 29 28 27 28 25 24 23
22 e7 20 19 18 17
T,MIYANM , Gneyed
ce".e'
Tnsabnom Plan FAumata
Tooth Oasorlptlon - -??
?_- ..._.._...._. Amoum Pat. DentNina.
1' Rowner "n pore 1Weod•hl nob
2 ExMaetlon-alnplo tooth qPMM41V 244.00 301.00
2 Exbloo"Inple tooth 60.00 17.00 43.00
2 Pon& cast Mph noble metal 00'00 17.00 43.00
3 ExtneNonatngle tooth "Ift 244.00 301.00
3 PoMlopst high noble mdal 80.00 17.00 43.00
4 Pontlopst high noble mdal 646.00 244.00 301.00
6 Ponto."st high noble mold 646.0 244.00 301.00
a Raln-one euhtws onterlor 546.00 244.00 301.00
8 ne alner arHx o Nsed.hl nob 70.00 19.00 51.00
7 Rown.oru surf*, anterior 646.00 244.00 301.00
O1 Raalndwn Whim, anterior 70.00 19.00 51.0
12 Resin-one surhoe, entsrtor 01200 20.00
70.00 82.00
ConOnued on fWyt Pape 19.00 61.00
?\1 VJ
}1/ U]/ LUUU LY. CJ 1 4 / LJJY:Joo
rtUL+GR I R I CRNI•ING 1'NgG UY
Chat
•' Pad ; Rose M. Wedlinger
Bitbdats:OM M"ll Chat6:RO0024 Data: 11A W OOD
6641:16142-7e0e
PtoNder: RoMrr R. Teremaa D.O,S.
Phone: (717)2334844
OfMw- 1600 Unglestown Road Sta. 306
Harrisburg, PA 17110
Treatment Plan estimate Continued
.
/ V Toots Daeerlptlon -_
Amount
Pat.
Dental ins.
12 Retainer am-pore fusad-hl nob 545.00 244.00 301
00
13 Extrection4ingle tooth 60.00 17
00 .
13P
6-otat high noble metal
646
00 .
244
00 43.00
1
14 PontloYalal high noble metal .
646.00 .
244
00 301.00
15 Pondo-pat high noble metal
616
00 .
244
00 301.00
16 Retainer an-pore fused-hl nob .
545
00 .
244
00 301.00
17 Exhedlon-single tooth .
60.00 .
17
00 301.00
17 Implant a}'7- erto o?4e.
?+eeo .
1" 43.00
17 Retalner em-pore fused-hl nob
646
00
244
00 0,00
16 Pontio.pat high noble most .
$45.00 .
244.00 301.00
301
00
19 Pon0o4mal high noble metal
616.00
244.00 .
301
00
20 Pontlo•cest high noble metal 646.00 244.00 .
301
00
21 Mdraetlon-single loath 60.00 17.00 .
43
00
21 Ponllo.aal high noble metal 646.00 244,00 .
301
00
22 Retainer cm-porc Nsed-hl nob 545.00 244.00 .
301
00
27 Ralalno cn -porc Nasd•hl nob 645,00 244.00 .
301
00
28ExtAaNon-stnglstooth 60.00 17.00 .
43
00
26 Pontio•cest high noble metal 545.00 244.00 .
301
00
26 Pontio•ast high noble metal 545.00 244.00 .
301
00
30 Pon6o•ewst high noble metal 645.00 244.00 .
301
00
31 Pontlo-cast high noble metal 615.00 244.00 .
301
00
32 Retainer ern-pore fused-hl nob 545.00 244.00 .
301.00
Treatment Plan Totals 13302.00 5023.00 7430.00
• Treatment Plans Are EsOmalas Only
-'JF The 4ee4,h haue. Shy ?Ied -,I-he bri* will
bP, dvrjed QS 3 -Unr+ n0+ S.
11I UJ1 LUOU LY. LJ
w
111LJJYJOO
RUMM I R 16RRPD m
rmm On
PatleMr Rote M. Wedlinger
slrthdsta: 06M1949
Pm~: Robert R. Teramae D.D.S.
Phone: (717)233.4941
Office: 1!100 Unolestewn Road Ste. 309
Harrisburg, PA 17110
Chen
Chart M: R00024
Deb: 1110=000
SSO 101-42-7808
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
1{'111/11?U\_?n-'/(U'I/,1,11I\/, {((/I1'/?M11I1I1\I1/
a 00®?)?00® o 0
a ® OC)00n0
32 31 30 29 28 27 26 25 24 23 22 21 20 19 18 17
neCIIa1 Mel I ?, I
•
w
tooth Osar ptlon
2 Exhsdion-single tooth
2 extraction-single tooth
3 Extraction-single tooth
5 Implant
5 Crown-pore fuse high noble mti
6 Crown insert
6 rtseinone sur}aoe, snterior
6 Crown-porc fuse high noble mti
8 Crown Insert
7 Ruin-one suHaae, anterior
11 Resin-two surfaces, anterior
11 Crown-pore fuse high noble mti
11 Crown Insert
Continued on Next Page
VseI I &WWIlePwr
Treatment Plan Estimate
Amount
Pet. Dental Inc.
80.00
80.00
60.00
115.00
545.00
0.00
70.00
545.W
0.00
70.00
62.00
545.00
0.00
17.00
17,00
17.00
116.00
240.00
0.00
19.00
240.00
0.00
10.00
20.00
240.00
0.00
43.00
43.00
43.00
0.00
305.00
0.00
51.00
305.00
0.00
61.00
82.00
305.00
0.00
?It VWIzvvu ly." 11110p4wll
RVDCRI R IGRWy??
r•r+ue DD
Fallon!: 4090 M. Wedlinger Chant
Bilthdals:06MIS49
chuttR00024 Dose: ltrOgg000
Provider Robert R. Torames D
D
S eti76. 191042-7606
.
.
.
Phone:(717933-4914
OMoe:18M UnpNStown Rood ft. 306
Harrisburg, PA 17110
Troahnent Plan Retimabe continued
"Ih
„
?00M PaR Dental Ing.
Resift-one surtace, ontsrlor
traction-single tooth 70.00 19.00 61
00
plant 60.00 17.00 .
43.00
own.porc Mae Mph noble mtl 116.00 116.00 0.00
own insert 646.00 240.00 306.00
r
racUunylrtIls tooth 0.00 0.00 0.00
raelbn.singN tooth 60.00 17.00 43.00
lant 80.00 17.00 43
00
Crownport Pose high noble mll 116.00 116.00 .
000
wn Insert 646.00 240.00 306.00
raefbli aingle tooth 0.00 0.00 0.00
lant 60.00 17.00 43.00
wm porn loss high noble mu 116.00 116.00
0.00
26 Crown insert 646.00 240.00 3
06.00
0.00 0.00 0.00
Tnahnerrt Plan Totals
4412.00
2096.00
2346.00
• Troll mant Plans An Estimates Only
r
IL
Chan
•
r%
to
t_
Patlsnt: Rose M. Wadlinger
Sirtholds: 06/00/1949 Chart/:800024
Provider: Robert R. Tammes D.D.S.
Phone: (7`17)2334044
DOW: 1800 Unglestown Road ate. 908
Harrisburg, PA 17110
Date: 11/09!2000
90•: 19142-7808
1 2 3 4 5 8 7 8 9 10 11 12 13 14 15 18
Aci3 0 0 •
- ®MeD
32 31 30 29 28 27 28 i5 24 23 22 21 20 19 18 17
Traalmerd Plan Estimate
Team Daecdption
-
- -
---Amount
Pat.
Dental Inc.
_......_......_
2Extredbn•single tooth _.........
80.00
17.00
43.00
2 Extractlon-single tooth 80.00 17.00 43.00
2.15 Mandl par0sl-metal Des* W/adis 532.00 171.60 360.60
3 E#nction-single tooth 00.00 17.00 43.00
0 Resin-one surface, anterior 70.00 16.00 51.00
0 Crown-porc Nu high noble m0 545.00 240.00 305.00
a Crown Insert 0.00 0.00 0.00
7 Resin-one surface, anterior 70.00 16.00 51.00
11 Resln wo surfaces, anterior 82.00 20.00 62.00
11 Crown•porc Mss high noble mtl 545.00 240.00 305.00
11 Crown Insart 0.00 0.00 0.00
12 Ramona surface, anterior 70.00 19.00 51.00
13 Gxtreetlorraingla tooth 00.00 17.00 43.00
Continued on Nest Pegs
LLI V.II LYVV a?•LJ Ia1LJJ1JVV
1\VYLI\1 1\ ILI\,11•Ie1L
Chart
PadaM: Rose M, Wayln0ar
01r8MaM. O&IM1848 Chwt P RO0024
P16VMW. RoW R. Tsnmss D.D.S.
PION :(717)233-4044
• ORlos: 1800 Unpwtown Rosy gt•. 308
Hanlebur8, PA 17110
Tmonstd Plan EWMGM CoMlnusd
TOOM Dasstlptlon
Haunt
xtlrKtloMlnyls (y001 -
Msnd Pal-msMI baw Whdls 80.00
ftetloneln8lstooth
t 632.00
26
xhsalw&Wn0y tooth 80.00
00.00
Trsatmant Plan ToMla 2808.00
' TrsMmaM Plans Are Etflmatw only -- -----
IL
Do": 11MV2WO
$90-101-42-7808
I MV YV
Pat. Ow" Inc
17.00 43.00
171.60 360,80
17.00 43.00
17.00 43.00
1018.00 1847,00
iii
i
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
ROSE M. WADLINGER ) Docket Number 99-4198 CIVIL
Plaintiff )
VS. ) PACSES Case Number
713101496/D28992
EDWARD F. WADLINGER )
Defendant ) Other State ID Number
ORDER
AND NOW, to wit, on this 14TH DAY OF JANUARY, 2002 IT IS HEREBY
ORDERED that the APL order in this case be Q Vacated or OSuspended or
®Terminated without prejudice or Q Terminated and Vacated,
effective NOVEMBER 21, 2001 , due to:
THE PARTIES' DECREE IN DIVORCE ON NOVEMBER 21, 2001. THE CASE IS CLOSED WITH
A CREDIT OF $284.93 WITH LAST PAYMENT RECEIVED ON JANUARY 11, 2001. ALL
FUTURE PAYMENTS WILL BE REFUNDED TO DEFENDANT UNTIL THE TERMINATION OF THE
WAGE WITHHOLDING ORDER IS EFFECTIVE.
DRO: RJ Shadday
xC: plaintiff
defendant
Melissa Greevy, Esquire
P. Richard Wagner, Esquire
r?
BY THE COURT:
Kev' A. Hess JUDGE
Form OE-504
Service Type M Worker ID 21005
1.J
:J
?
.1
G i,
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pen ?`"` • f /// 7` "' 1/14 0Original Order/Notice
nsylvania ?f l%S
CO./City/Dise.Of CUMBERLAND 71310141f& ?y OAmended Order/No1ia•
Date of Order/Notice 01/14/02 L? a$449 ?- XQ FerminaleOrder/Notice
Court/Case Number (See Addendum for case summary)
Employer/Withholder's Federal I:IN Number
COMMONWEALTH OF PA
Employer/Wilhholder's Name
C/O PAYROLL OPERATIONS
Employer/Wilhholder's Address
ATTACHMENTS RESEARCH UNIT
PO BOX 8006
HARRISBURG PA 17105-8006
)RL:WADLINGER, EDWARD F.
1 Fmployec/Obligor's Name (I a,l, First, MI)
1 175-40-6934
I mployee/Obligor: Social Security Number
1 9500100003
Employee/Obligors Case Identifier
4" Addendum for plaintiNnames assoriated with cases w anachmenU
) Custodial Parent's Name Qasl, First, MII
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ o . oo per month in current support
$ o . oo per month in past-due support Arrears 12 weeks or greater? Oyes ® no
$ o . oo per month in medical support
$ o . oo 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:
$ o . oo per weekly pay period.
$ o . oo per biweekly pay period (every two weeks).
$ o . oo per semimonthly pay period (twice a month).
$ o . oo per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on pg. 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PA CSES MEMBER /D (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BY THE COURT:
Date of Order: JAN 1 4 2002
Kc-v .4. mss ?
r^ Form EN-028
Service Type M O4\1B No: W104154 Worker ID 21005 n ct
f ya --
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDER
? If checked you are rcyuired to provide a copy of this form to your employee.
Priority: Withholding under this Order/Notice has priority over any other legal process under Sate law again>t the same income.
receipt of this order have pri priority If (here are Federal tax levies in effect please contact the requesting
Federal tax levies in effect Withholding
agency listed blow. PaYment
In
2. Combining Payments: You can combine withheld amounts from more than one n of the e singlig income in a single
to each agency requesting withholding. You must, however, separately identify the portion of th single payment nt that is atlribuable"o
each employee/obligor.
3.' -You-must -report
--Re(mrting-1CPaydate/Dntrnf-Withholding:
-thepaydatddate-o(tivllhhnldingwhen-sending-tficpayment. -T C,hi Tate helemployee s/ob gis. thprio loo I 1 I :c? f em Inymen hhh ref pect to the time I ^ri` ??`hwith nlwhich mustYou rout tvimplemenWthethe
stat
withholding order and forward the support payments.
q - Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice 141 Withhold Income ((IT Support I,e to Federal
follow against greateUtmtlst
State tthislJw{of the alte of employeeas/obligor ctpr nclpal place' ofremployment. You must honor allrOrder./Notice>lu the
extent possible. ISee #9 below)
S. Termination Notification: when the employee/obligor is no longer working for
You must promptly notify the Requesting Agency
you. Please provide the information raluested and return a copy of this order/Notice to the Agency identified below,
WITHHOLDER'SID: 2321722990 WADLINGER EDWARD F.
EMPLOYEE'S/OBLIGOR'S NAME: 9500100003 DATE OF SEPARATION:
EMPLOYEE'S CASE IDENTIFIER:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
S: You may be required in report and withhold (Tom lump sum payments such as bonuses, commissions, or
pay. If you have any questions about lump sum payments, contact the p erson or autho
severance oily be ow.
6. Lump Sum Payments: Liability: If you (ail in withhold income income as the other Ord penalties ce directs, you are liable for both the accumulated amount you should
7 governs.
unle withheld To the emplo in another State, in which case the law of the State no which he or she isPemplo yed State law governs
have
withholding.
Anti-discrimination: You are subject to a fine determined under State law for discharging se Of a support i loin
he is
B• or taking disciplinary action against any employee/obligor because. of a support withholding.
employment, refusing to employ,
Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or s
employed governs.
than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
or 21 the amounts allowed by the State of the employee's/obligor's principal place of employment.
9 - Protection Act Withholding U.S.C. .S.C. 41 Limits: Y673ou (b)1; may not withhold more
; Social Sec ur iy laxe?+FJnd MWdicaADWcs the net income left after making mandatory
.10 wel
c limit Iedurl'lon lsu has toFederal the, Iggre ocal tax
10.
* that issued the order, you are to follow the
state
NOTE: If you or your agent are served with a copy of this order in the
law of the state that issued this order with respect to these items- you or your employee/obligor have any questions, 4
Requesting Agency: contact WAGE ATTACHMENT UNIT
OMESTIC RELATIONS SECTION by telephone at (717) 24_ u-6 or
N N VE T by FAX at 1'171 o-6 44
p .BOX 320 by Internet ;
CARLISLE PA 17013
Service Type M
Page 2 of 2
oxm na.: 0700154
ExeirAiun 041: 12/31INn
Form
i
Lr.
'r _
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ROSE MARY WADLINGER,
Plaintiff
VS. No. 99-4198
EDWARD F. WADLINGER,
Defendant Civil Action - In Divorce
AFFIDAVIT OF INTENTION TO RESUME PRIOR SURNAME
I, Rose Mary Wadlinger, being duly sworn according to law, deposes and says that she is
the Plaintiff in the above-captioned divorce action in which a final decree from the bonds of
matrimony was entered on November 21, 2001, and she hereby elects to resume her prior
surname of GAJDEK and therefore, gives this written notice avowing said intention in
accordance with # 704 of the Act of November 15, 1972, P.L. 1063, 54 Pa. C. S. A. § 704.
aj?1._?od9._
Notarial Sat
Linda K Shaull, Nwa y Public
tower Paxton 7Wp., Dauphin County
My Commisdon Bapim Sept. 19, zoos To be known as:
Member,P9nMyNatYegaEOClabmdNOlerle6
Sworn and subscribed to before me this
(? Sk day ofd, 2002.
CL. CV I ? w
.l. ._.. =?_I O
l_ ? In
JAN 0 9 2004 G
ROSE MARY WADLINGER,
Plaintiff
V.
EDWARD F. WADLINGER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4198
CIVIL ACTION - LAW
IN DIVORCE
DOMESTIC RELATIONS ORDER
AND NOW, this /y ' day of ±:!7 2004, this Stipulation and Agreement
of the parties is hereby made a Domestic Relations Order.
J.
Dist: /P. Richard Wagner, Esquire, 2233 North Front Street, Harrisburg, PA 17110
/Melissa Peel Greevy, Esquire, PO Box 109, Lemoyne, PA 17043.0109
Jur S..l
Mmrr "A°
(?1 J' JJ
Z.J!! J.,?i I''?
G? n• .'?,li i
Johnson, Duffle, Stewart & Weidner
By: Melissa Peel Greevy
I.D. No. 77950
301 Market Street
P. 0. Box 109
Lemoyne, Pennsyh,ania 1 7043-0 1 09
(717) 761-4540
ROSE MARY WADLINGER,
Plaintiff
V.
EDWARD F. WADLINGER,
Defendant
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4198
CIVIL ACTION - LAW
IN DIVORCE
AND NOW, comes Rose Mary Wadlinger, now known as Rose Mary Gajdek, by and through her
attorneys, Johnson, Duffle, Stewart & Weidner, and moves your Honorable Court to enter an Order upon
Stipulation for the entry of a Domestic Relations Order entered between Plaintiff and Defendant, a copy of
which is attached hereto and marked as Exhibit "A".
Respectfully submitted,
Date:_ yLlb 4/
JOHNSON, DUF STEWART & WEIDNER
By:
Melissa Pee Greevy
Attorney I.D. No. 77950
301 Market Street
Post Office Box 109
Lemoyne, PA 17043-0109
(717) 761-4540
Attorney for Plaintiff
222711
C ER MICA r E OF S ER VICE
AND NOW, this 6" day of January, 2004, the undersigned does hereby certify that she did this date
serve a copy of the foregoing Motion for Entry of Order upon Stipulation upon the other parties of record by
causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne,
Pennsylvania, addressed as follows:
P. Richard Wagner, Esquire
Mancke, Wagner & Spreha
2233 North Front Street
Harrisburg, PA 17110
DUFFIE) STEWART & WEIDNER
Peel Greevy
I
Johnson, Duffle, Stewart & Weidner
By: Melissa Peel Greevy
I.D. No. 77950
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
Attorneys for Plaintiff
ROSE MARY WADLINGER, IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. 99-4198
V.
CIVIL ACTION - LAW
EDWARD F. WADLINGER,
IN DIVORCE
Defendant
STIPULATION AND AGREEMENT
AND NOW, the parties Rose Mary (Wadlinger) Gajdek, Plaintiff, and Edward F. Wadlinger,
Defendant, do hereby Stipulate and Agree as follows:
1. The parties hereto were husband and wife, and a divorce action is in this Court at the above
number, and this Court has personal jurisdiction over the parties. The parties were married on August 24,
1974 and divorced on November 21, 2001.
2. Edward F. Wadlinger, hereinafter referred to as "Member," is a member of the
Commonwealth of Pennsylvania, State Employes' Retirement System, hereinafter referred to as "SERS."
3. SERS, as a creature of statute, is controlled by the State Employes' Retirement Code, 71 Pa.
C.S. Section 5101-5956 ("Retirement Code").
4. Rose Mary (Wadlinger) Gajdek, hereinafter referred to as "Alternate Payee," is the former
spouse of Member.
ii
5. The name, last known address, social security number, and date of birth of the plan "Member"
are:
Name: Edward F. Wadlinger ("Member")
Address: 216 West Simpson Street, Mechanicsburg, Pennsylvania 17055-6320
Social Security Number: 175-40-6934
Birth Date: December 11, 1948
6. The name, last known address, social security number, and date of birth of the "Alternate
Payee" are:
Name: Rose Mary (Wadlinger) Gajdek ("Alternate Payee")
Address: 67 Fairfax Village, Harrisburg, Pennsylvania 17112
Social Security Number: 191-42-7808
Birth Date: May 6, 1949
It is the responsibility of Alternate Payee to keep a current mailing address on file with SERS at all
times.
7. (a) The marital property component of Member's retirement benefit equals (1) the
Coverture Fraction multiplied by (2) the Member's retirement benefit as of Member's effective date of
retirement.
(b) The Coverture Fraction is a fraction with a value less than or equal to one. The
numerator shall equal the amount of Member's credited service for the period from November 15, 1975, to
April 8, 1997. The denominator shall equal the amount of Member's service, for the period from the date
Member became a Participant in the SERS, to the date the Member ended Participation in the SERS.
(c) Fifty Percent (50%) of the marital property component of Member's retirement benefit
is to be allocated to Alternate Payee for the purpose of equitable distribution of this marital asset.
8. Member's retirement benefit is defined as all monies paid to or on behalf of Member of SERS,
including any lump sum withdrawals or scheduled or ad hoc increases, but excluding the disability portion of
any disability annuities paid to Member by SERS or any deferred compensation benefits paid to Member by
SERS. Equitable distribution of the marital property component of Member's retirement benefit, asset forth
n Paragraph Seven (7) shall commence as soon as administratively feasible after Member's effective date
of retirement or the entry of this Stipulation and Agreement as a Domestic Relations Order acceptable to
SERS, whichever is later.
9. Member hereby nominates Alternate Payee as an irrevocable beneficiary to the extent of the
Alternate Payee's equitable distribution portion of the Member's retirement benefit for any death benefits
payable by SERS. This nomination shall become effective upon approval by the Secretary of the Retirement
Board, or his authorized representative of any Domestic Relations Order incorporating this Stipulation and
Agreement. The balance of any death benefit remaining after the allocation of the Alternate Payee's
equitable distribution portion ("Balance") shall be paid to the beneficiaries named by the Member on the last
Nomination of Beneficiaries Form filed with the Retirement Board prior to Member's death.
(a) If the last Nomination of Beneficiaries Form filed by the Member prior to Member's
death (a) predates any approved Domestic Relations Order incorporating this Stipulation and Agreement,
and (b) names Alternate Payee as a beneficiary, then (1) the terms of the Domestic Relations Order shall
alone govern Alternate Payee's share of any death benefit, and (2) for purposes of paying the Balance via
the last Nomination of Beneficiaries Form filed with the Retirement Board prior to Member's death, Alternate
Payee shall be treated as if the Alternate Payee predeceased Member. No portion of the Balance shall be
payable to the Alternate Payee's estate.
(b) In addition, Member shall execute and deliver to the Alternate Payee an authorization,
in a form acceptable to SERS, which will authorize SERS to release to the Alternate Payee all relevant
information concerning Member's retirement account. Alternate Payee shall deliver the authorization to
SERS which will allow the Alternate Payee to check that she has been and continues to be properly
nominated under this paragraph.
10. The type and amount of Member's retirement benefit payable under the terms of this
Stipulation and Agreement after its entry as a Domestic Relations Order acceptable to SERS is dependent
upon which option(s) is (are) selected by Member upon retirement. Member and Alternate Payee expressly
are that:
For the duration of the Member's life, the Alternate Payee's portion of the Member's retirement
benefit should be deducted from the Member's monthly annuity and paid to the Alternate Payee.
11. Alternate Payee may not exercise any right, privilege or option offered by SERS. SERS shall
issue individual tax forms to Member and Alternate Payee for amounts paid to each.
12. In the event of the death of Alternate Payee either prior to or after receipt of any payments
payable to Alternate Payee from SERS under the terms of this Stipulation and Agreement, any death benefit
or retirement benefit payable to Alternate Payee by SERS shall:
Be paid to Alternate Payee's Estate to the extent of Alternate Payee's equitable distribution
interest in Member's retirement benefit as set forth in Paragraphs Seven through Nine.
13. In no event shall Alternate Payee have greater benefits or rights other than those which are
available to Member. Alternate Payee is not entitled to any benefit not otherwise provided by SERS. The
Alternate Payee is only entitled to the specific benefits offered by SERS as provided in this Stipulation and
Agreement. All other rights, privileges and options offered by SERS not granted to Alternate Payee are
preserved for Member.
14. It is specifically intended and agreed by the parties hereto that this Stipulation and
Agreement:
(a) Does not require SERS to provide any type or form of benefit, or any option not
otherwise provided under the Retirement Code;
(b) Does not require SERS to provide increased benefits (determined on the basis of
actuarial value) unless increased benefits are paid to Member based upon cost of living or increases bases
on other than actuarial values.
15. The parties intend and agree that the terms of this Stipulation and Agreement shall be
approved, adopted and entered as a Domestic Relations Order.
16. The Court of Common Pleas of Cumberland County, Pennsylvania, shall retain jurisdiction to
amend any Domestic Relations Order based on this Stipulation and Agreement, but only for the purpose of
;stablishing it or maintaining it as a Domestic Relations Order; provided, however, that no such amendment
,hall require SERS to provide any type or form of benefit, or any option not otherwise provided by SERS,
and further provided that no such amendment or right of the Court to so amend will invalidate any existing
Order.
17. Upon its entry as a Domestic Relations Order, a certified copy of this Stipulation and
Agreement and any attendant documents shall be served upon SERS immediately. The Domestic Relations
Order shall take effect immediately upon its approval and the approval of any attendant documents by SERS
and shall remain in effect until further Order of Court.
WHEREFORE, the parties, intending to be legally bound by the terms of this Stipulation, do hereunto
place there hands and seals.
Dated: % 1T o 3
Dated:__ \ 2L \ t k ') 3
Dated: -?? "03
:165593
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