HomeMy WebLinkAbout99-05368
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IN THE COURT OF COMMON PLEAS
CFCUMBERLANDCOUNTY
STP'rE OF PENNA.
DORINE A. BOLLINGER
No. 1999-5368
VERSUS
D. TIMOTHY BOLLINGER
DECREE IN
DIVORCE
AND NOW, Pr/rb7?j r C 20c)4, IT IS ORDERED AND
DECREED THAT DORINE A. BOLLINGER PLAINTIFF,
D. TIMOTHY BOLLINGER
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.
AND IT IS FURTHER ORDERED, that the terms, conditions and
covenants set forth in the written Property Settlement Aareement
made and entered into by the parties on December 19, 2001 are
incorporated into this Decree by reference thereto, but not
merged into this Decree.
BY THE COURT:
ATT Fr ?. J.
I PROTHONOTARY
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TUCKER ARENSBERG & SWARTZ
I I I NORTH FRON'r STRE.Gr
E.O. Iiox 889
IIARRISBURO.I'I'.NNSYINANIA 17111911887
17171 234.4121
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PROPERTY SETTLEMENT AGREEMENT
THIS AGREEMENT, Made this %40< day of 2001,
by and between D. TIMOTHY BOLLINGER, hereinafter referred to as "Husband", and
DORINE A. BOLLINGER, hereinafter referred to as "Wife".
WITNESSETH:
and WHEREAS, Husband and Wife were lawfully married on June 18, 1977;
WHEREAS, three children were born of this marriage, namely,
Stephanie, born February 16, 1979, Julie, born October 2, 1981 and Katie, born
October 27, 1985; and
WHEREAS, certain differences have arisen between the parties as a
result of which they have separated and now live separate and apart from one
another, and are desirous of settling fully and finally their respective financial and
property rights and obligations as between each other, including, without limitation
by specification: the settling of all matters between them relating to the past,
present and future support and/or maintenance of Wife by Husband or of Husband by
Wife; and in general the settling of any and all claims and possible claims by one
against the other or against their respective estates for equitable distribution of all
marital property; and a resolution of all mutual responsibilities and rights growing out
of the marriage relationship; and
WHEREAS, the parties hereto, after being properly advised by their
respective counsel, Husband by his attorney, Emily Long Hoffman, and Wife by her
attorney, Sandra L. Meilton, have come to the following 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:
SEPARATION:
It shall be lawful for each party at all times hereafter to live
separate and apart from the other at such place or places as he or she may from time
to time choose or deem fit.
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2. PERSONAL RIGHTS:
Each party shall be free from interference, 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 harass or malign the other, nor in any way
interfere with the peaceful existence, separate and apart from the other in all respects
as if he or she were single and unmarried.
3. WIFE'S DEBTS:
Wife represents and warrants to Husband that since their
separation on October 17, 1998 she has not, 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 from 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 their
separation on October 17, 1998 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
indemnify and save Wife harmless from any and all claims or demands made against
her by reason of debts or obligations incurred by him.
OUTSTANDING JOINT DEBTS:
Husband and Wife acknowledge and agree that they have no
outstanding debts and obligations of the Husband and Wife incurred prior to the
signing of this Agreement, except as follows:
Description of Debt Responsible Part
GE Capital Consumer Card Co. Husband
Acct. No. 5406-8198-0039-4379,
First USA Bank, Acct. No. Husband
4417 1223 5310 9821,
Bon Ton Charge account Husband
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Limited charge account Wife
Express charge account Wife
City Financial account Wife
At the time of the signing of this Agreement, the parties were not
certain whether there was one or more First USA Bank credit card accounts. It was
agreed that if, in fact, such additional account existed, that Husband would assume
responsibility for any balance owing on same. In addition, Husband shall agrees to
pay the GE Capital Consumer Company card, the First USA Bank account identified
above and the Bon Ton charge. Wife agrees to pay the Limited, Express and City
Financial debts. Each party agrees to pay the outstanding obligations identified as
their responsibility herein and further agrees to indemnify and save harmless the other
from any and all claims and demands made against him or her by reason of the
other's default on such debt or obligation.
Husband and Wife acknowledge and agree that they have no
other outstanding debts and obligations of the Husband and Wife incurred prior to or
after the signing of this Agreement.
In return for Husband's agreement to pay the credit card
accounts set forth above, Wife agrees to pay to Husband $1,500 in satisfaction of
her responsibility for those debts. Wife's $1,500 obligation shall be deducted from
the overall cash payment due from Husband to Wife as set forth on the Exhibit "A"
attached to this Agreement.
6. JOINT CREDIT CARDS AND BANK ACCOUNTS:
Husband and Wife shall immediately close out any remaining
credit card accounts and/or bank accounts existing in joint names. Closure of these
accounts shall be completed within thirty (30) days of the date of this Agreement.
7. 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
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causes of action, claims, rights or demands whatsoever arising out of their marriage,
except any or all cause or causes of action for divorce and except in any or all causes
of action for breach of any provisions of this Agreement. Each party also waives his
or her right to request marital counseling pursuant to 23 Pa.C.S.A. Section 3302.
8. DIVISION OF PERSONAL PROPERTY
(A) PERSONAL PROPERTY:
T marital furniture and the proceeds dividedequally betweenthe Parties Se Husband shall shall be solely
responsible for arranging for the sale of said items and shall clear with Wife all dates
for moving furniture and sale of same.
(B) RETIREMENT BENEFITS:
Employees'
Wife is the owner of a Public Retirement System (PSERS) Pension and Husband is the owner of c a Pace Resources
401(k). The parties have agreed that Harry M. Leister, Jr., F.S.A., of Conrad M.
Siegel, Inc. shall be retained to determine the value of the marital portion of Wife's
PSERS pension and Husband's 401 M. In determining the marital portion of
Husband's 401(k), Harry Leister shall deduct the date of separation value of the
existing loan which on that date was $13,057.63. In the event the date of
separation value of either party's pension/retirement is higher than the current
value, due to market fluctuations, then the lower value shall be used. After
establishing the marital values, the pension and retirement benefits discussed herein
shall be divided fifty-five (55%) percent to Wife and forty-five (45%) percent to
Husband.
For purposes of calculating the 55%-45% division, it is
agreed between the parties that Wife shall retain her PSERS pension in its entirety
and that Husband shall waive any right, title or interest he may have in same. To
compensate Husband for this waiver, Husband's 45% of the marital portion of
Wife's PSERS shall be reduced from the 55% Wife is to receive from Husband's
401 M. Wife waives any right, title or interest she may have in the remainder of
Husband's 401 M. For example. Assume hypothetically that husband's pension Is
worth 5100,000 and wife's pension is worth $50,000. The total marital pensions
equal $150,000. If wife is to receive 55% of that value, her share would be
$82,500. To reach this amount, she would retain her pension valued at $50,000
and $32,500 from husband's pension.
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Harry M. Leister, Jr. shall also be retained by the parties to
prepare the appropriate Qualified Domestic Relations Orders to transfer to Wife her
55% (less the adjustment addressed herein) in Husband's 401 W. The parties shall
equally divide Mr. Leister's fees. To the extent permitted by Husband's 401(k) plan,
Wife shall be entitled to make selections with regard to the accounts, stocks and/or
other assets transferred to her from Husband's 401 W. Wife shall make this decision
with the assistance of a financial planner and shall advise Mr. Leister so that her
selections can be addressed in the Qualified Domestic Relations Order.
(C) RITE AID STOCK:
Husband and Wife acknowledge that they are the owners
of Rite Aid Corporation stock estimated to be 148 shares. Husband and Wife agree
that all of the Rite Aid Corporation stock shall be distributed so that Wife receives
fifty-five (55%) percent and Husband forty-five (45%) percent of the total shares of
stock.
With regard to the above distribution of stock, Husband
and Wife hereby specifically release and waive any and all interest, claim or right that
he or she may have in the stocks of the other. Husband and Wife further agree to
execute the necessary documents to transfer said stocks as provided herein and said
transfer shall be made within thirty (30) days of the signing of this Agreement.
(D) BANK ACCOUNTS:
At the date of separation, the parties jointly held a Pace
Resources Federal Credit Union account, Account No. 1698, with the total value of
$2,609.86. Husband retained said account and the parties agree that he shall pay to
Wife fifty-five (55%) percent of the value of the account as set forth on the attached
Exhibit "A". Payment shall be made within thirty (30) days of the signing of this
Agreement.
(E) PROCEEDS FROM THE SALE OF MARITAL RESIDENCE:
After separation, the marital residence located at 2612
Logan Street, Camp Hill, Pennsylvania was sold and the proceeds distributed
between the parties. The parties agree that Wife was entitled to fifty-five (55%)
percent of those proceeds. Husband shall pay to Wife the sum of $1,432.60 as set
forth on the attached Exhibit "A". Per Paragraph 9 below, payment shall be made
within thirty (30) days of the signing of this Agreement.
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(F) NORTHWESTERN MUTUAL LIFE INSURANCE
ACCOUNTS:
Husband and Wife were, at the date of separation, both
owners of Northwestern Mutual Life Insurance policies. Wife's policy (No.
10651265) has a cash surrender value of $2,665.20 and Husband's policy (No.
9436899) had a cash surrender value of $12,859.09. The parties agree that these
cash values shall be divided fifty-five (55%) percent to Wife and forty-five (45%)
percent to Husband. The distribution of these policies shall be as set forth on the
attached Exhibit "A". Per Paragraph 9 below, payment shall be made within thirty
(30) days of the signing of this Agreement.
. For purposes of calculating the 55%-45% division, it is
agreed between the parties that Wife shall retain her policy noted herein in its
entirety and that Husband shall waive any right, title or interest he may have in
same.
(G) VEHICLE:
Wife shall transfer all of her right, title and interest to
Husband for the 1995 Saturn subject to the lien held by PACE. In return for Wife's
transfer, Husband agrees to pay the PACE loan in full and shall indemnify Wife and
hold her harmless against any and all claims or demands made against her in
connection with said loan.
The parties further acknowledge and agree that the equity
in the said vehicle at the date of separation was $3,506. In further consideration for
Wife's waiver of her interest in said vehicle, Husband shall pay to Wife fifty-five
(55%) percent of said value as set forth on the attached Exhibit "A". Per Paragraph
9 below, payment shall be made within thirty (30) days of the signing of this
Agreement.
(H) BOAT:
Wife shall transfer all of her right, title and interest to
Husband for the 24' Catalina boat subject to the lien held by PACE. In return for
Wife's transfer, Husband agrees to pay the PACE loan in full and shall indemnify Wife
and hold her harmless against any and all claims or demands made against her In
connection with said loan.
The parties further acknowledge and agree that the equity
in the said boat at the date of separation was $6,200. In further consideration for
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Wife's waiver of her interest in said boat, Husband shall pay to Wife fifty-five (55%)
percent of said value as set forth on the attached Exhibit "A". Per Paragraph 9
below, payment shall be made within thirty (30) days of the signing of this
Agreement.
(1) TAX LIABILITY:
The parties believe and agree that the division of property
heretofore made by this Agreement is a non-taxable division of property between
co-owners rather than a taxable sale or exchange of such property. Each party
promises not to take any position with respect to the adjusted basis of the property
assigned to him or her or with respect to any other issue which is inconsistent with
the position set forth in the preceding sentence on his or her Federal or State income
tax returns.
9. CASH PAYMENT:
Husband shall pay to Wife the sum of $12,579.48, as itemized
on the Exhibit "A" which payment shall be made within thirty (30) days of the
signing of this Agreement.
10. CHILD SUPPORT:
Husband shall pay Wife child support for their one minor daughter
in an amount to be calculated under the Pennsylvania Statewide Support Guidelines.
The support payments shall be calculated and an agreement signed in this regard
within thirty (30) days of the signing of this Agreement. The effective date of the
child support shall be October 1, 2001. The parties agree to sign an amicable Order
of Support with the Court of Common Pleas of Cumberland County, Pennsylvania, so
that future payments shall be made in accordance with the Order of Court. The
parties agree that this provision relative to support payments may be enforced by an
action in accordance with the Rules of Civil Procedure governing actions for support.
11. ALIMONY:
Husband agrees to pay Wife the sum of $1,000 per month for
the support and maintenance of Wife for a period of ten (10) years. Said payments
shall be made through the Domestic Relations Section, Court of Common Pleas of
Cumberland County, Pennsylvania. The parties agree that this provision relative to
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support payments may be enforced by an action in accordance with the Rules of Civil
Procedure governing actions for support.
Such obligation for support to Wife shall commence effective
October 1, 2001 and continue until September 30, 2011 or the happening of the
following, whichever shall occur first:
(1) Wife dies;
(2) Wife remarries; or
(3) Wife enters into cohabitation with a person of the
opposite sex, who is not a member of the Wife's immediate family within the
degrees of consanguinity subsequent to the signing of this Agreement,
and in all other respects shall be nonmodifiable. Husband and Wife acknowledge and
agree that the provisions of this Agreement providing for the payment of alimony to
her by her Husband and for no payment of alimony to Husband by Wife are fair,
adequate, and satisfactory to them and are based upon their actual need, their ability
to pay, the duration of the parties' marriage and other relevant factors which have
been taken into consideration by the parties. Although the approval of this
Agreement by a court of competent jurisdiction in connection with an action in
divorce or annulment filed by Wife shall be deemed an order of the court and may be
enforced as provided in 23 Pa.C.S.A. Section 3701, as amended, this Agreement,
insofar as it pertains only to support for Wife or Husband and the payment of alimony
following the entry of a final Decree in Divorce between the parties, may not be
modified, suspended, terminated, or reinstated at the instance or request of the Wife
or Husband, or subject to further order of any court upon changed circumstances of
the Wife or Husband of a substantial or continuing nature, or for any reason claimed
by Wife or Husband whatsoever. Upon that condition, Wife hereby accepts the
provisions of this Agreement in lieu of and in full and final settlement and satisfaction
of all claims and demands that she may now or hereafter have against Husband for
her support and maintenance of herself and for alimony. Husband and Wife further
voluntarily and intelligently waive and relinquish any right to seek a modification,
suspension, termination, reinstitution, or other court order with respect to the terms
of this Agreement pertaining to the payment of support or alimony to Wife by
Husband or the payment of support or alimony to Husband by Wife.
The parties agree that the entire amount being paid to Wife
pursuant to this paragraph is a separate maintenance periodic payment, included and
intended to be included with the income of the Wife within the meaning and intent of
Section 71 of the United States Internal Revenue Code of 1954 and deductible from
the Husband's gross income pursuant to the provisions of Section 215 of the United
States Internal Revenue Code of 1954. Wife agrees that all said payments shall be
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included as income of the Wife in her applicable tax returns and that she shall pay
such taxes as may be required by reason of such inclusion.
12. ALIMONY PENDENTE LITE COUNSEL FEES AND EXPENSES:
Husband and Wife acknowledge and agree that the provisions of
this Agreement providing for the equitable distribution of marital property of the
parties are fair, adequate and satisfactory to them. Both parties agree to accept the
provisions set forth in this Agreement in lieu of and in full and final settlement and
satisfaction of all claims and demands that either may now or hereafter have against
the other for alimony pendente lite, counsel fees or expenses or any other provision
for their support and maintenance before, during and after the commencement of any
proceedings for divorce or annulment between the parties.
13. INCOME TAX PRIOR RETURNS-
The parties have heretofore filed joint federal and state tax
returns. Both parties agree that in the event any deficiency in federal, state or local
income tax is proposed, or any assessment of any such tax is made against either of
them, each will indemnify and hold harmless the other from and against any loss or
liability for any such tax deficiency or assessment and any interest, penalty and
expense incurred in connection therewith. Such tax, interest, penalty or expense
shall be paid solely and entirely by the individual who is finally determined to be the
cause of the misrepresentations or failures to disclose the nature and extent of his or
her separate income on the aforesaid joint returns.
14. WAIVERS OF CLAIMS AGAINST ESTATES:
Except as herein otherwise provided, each party may dispose of
his or her property in any way, and each party hereby waives and relinquishes any
and all rights he or she may now have or hereafter acquire, under the present or
future laws of any jurisdiction, to share in the property or the estate of the other as a
result of the marital relationship, including without limitation, dower, 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. 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.
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15. MUTUAL CONSENT DIVORCE-
he arties and broken Tthatthey doanot desire marital counnseling,t and that the yboth
consent to the entry of a decree in divorce pursuant to 23 Pa.C.S.A. Section
3301 (c). Accordingly, both parties agree to forthwith execute such consents,
affidavits, or other documents and to direct their respective attorneys to forthwith file
such consents, affidavits, or other documents as may be necessary to promptly
proceed to obtain a divorce pursuant to said 23 Pa.C.S.A. Section 3301(c). Upon
request, to the extent permitted by law and the applicable Rules of Civil Procedure,
the named defendant in such divorce action shall execute any waivers of notice or
other waivers necessary to expedite such divorce.
It is the intention of the parties that the Agreement shall survive
any action for divorce which may be instituted or prosecuted by either party and no
order, judgment or decree of divorce, temporary, final or permanent, shall affect or
modify the financial terms of this Agreement. This Agreement shall be incorporated
in but shall not merge into any such judgment or decree of final divorce, but shall be
incorporated for the purposes of enforcement only.
16. EFFECT OF RECONCILIATION OR COHABITATION:
This Agreement shall remain in full force and effect and shall not
be abrogated even if the parties effect reconciliation, cohabit as husband and wife or
attempt to effect reconciliation.
17. BREACH AND ENFORCEMENT,
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 this Agreement shall be responsible for payment of legal fees and
costs incurred by the other in enforcing his or her rights under this Agreement.
18. ADDITIONAL INSTRUMENTS,
Each of the parties shall from time to time, at the request of the
other, execute, acknowledge and deliver to the other party any and all further
instruments that may be reasonably required to give full force and effect to the
provisions of this Agreement.
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19. TAX ADVICE:
Both parties hereto hereby acknowledge and agree that they have
had the opportunity to retain their own accountants, certified public accountants, tax
advisor, or tax attorney with reference to the tax implications of this Agreement.
Further, neither party has been given any tax advice whatsoever by their respective
attorneys. Further both parties hereby acknowledge that they have been advised, by
their respective attorneys, to seek their own independent tax advice by retaining an
accountant, certified public accountant, tax attorney, or tax advisor with reference to
the tax implications involved in this Agreement. Further, the parties acknowledge
and agree that their signatures to this Agreement serve as their acknowledgment that
they have read this particular paragraph and have had the opportunity to seek
independent tax advice.
20. VOLUNTARY EXECUTION:
The provisions of this Agreement and their legal effect have been
fully explained to the parties by their respective counsel, and each party
acknowledges that the Agreement is fair and equitable, that it is being entered into
voluntarily, with full knowledge of the assets of both parties, and that it is not the
result of any duress or undue influence. The parties acknowledge that they have
been furnished with all information relating to the financial affairs of the other which
has been requested by each of them or by their respective counsel.
21. 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 on 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 23 Pa.C.S.A. Section 3501 et. sec. or any other
laws. Husband and Wife each voluntarily and intelligently waive and relinquish any
right to seek a court ordered determination and distribution of marital property, but
nothing herein contained shall constitute a waiver by either party of any rights to
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seek the relief of any court for the purpose of enforcing the provisions of this
Agreement.
22. DISCLOSURE:
The parties confirm that they have relied on the completeness
and substantial accuracy of the financial disclosure of the other as an inducement to
the execution of this Agreement. The parties acknowledge that there has been no
formal discovery conducted in their pending divorce action and that neither party has
filed an inventory and appraisement as required by Section 3505fb? of the
Pennsylvania Divorce Code. Notwithstanding the foregoing, the rights of either party
to pursue a claim for equitable distribution, pursuant to the Pennsylvania Divorce
Code, of any interest owned by the other party in an asset of any nature at any time
prior to the date of execution of this Agreement that was not disclosed to the other
party or his or her counsel prior to the date of the within Agreement is expressly
reserved. In the event that either party, at any time hereafter, discovers such an
undisclosed asset, the party shall have the right to petition the Court of Common
Pleas of Cumberland County to make equitable distribution of said asset.
The non-disclosing party shall be responsible for payment of
counsel fees, costs or expenses incurred by the other party in seeking equitable
distribution of said asset.
Notwithstanding the foregoing, the Agreement shall in all other
respects remain in full force and effect.
23. 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.
24. PRIOR AGREEMENT:
It is understood and agreed that any and all property settlement
agreements which may or have been executed prior to the date and time of this
Agreement are null and void and of no effect.
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25. DESCRIPTIVE HEADINGS:
The descriptive
They shall have no effect whatsoe whatsoever inl determining the r ri rights o or obligations of the
parties.
26. APPLICABLE LAW:
This Agreement shall be construed under the laws of the
Commonwealth of Pennsylvania.
27. AGREEMENT BINDING ON HEIRS:
This Agreement the parties hereto and their respective al heirs, executors, administrators, and shall inure to the benefit of
and assigns.
IN WITNESS WHEREOF, the parties hereto have set their Hands and
Seals the day and year first above written.
10-
43704.1
• AL-? ? (SEAL)
Donne A. Bollinger
N`^ 2!°u (SEAL)
D. Timothy B nger
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COMMONWEALTH OF PENNSYLVANIA ?
COUNTY OF ( SS:
again
)
On this, the ?a? day ofN 2001, before
me, a Notary Public, the undersigned officer, personally appearedDonne A. Bollinger,
known to me (or satisfactorily proven) to be the person whose name is subscribed to
the foregoing Property Settlement Agreement and acknowledged that she executed
the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Notariml Seal
Pauline Patti Thomas, Notary Public
%1,
Harrisburg, Dauphin County
s Mar, ?A :'UUJ
My Commission [MPiru
r.h?,,,.: r. f'r. nnLr'.,. ,. _,Ji, .•. Ali Ul HUlauLz
Notary Public
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ?AvolnlrJ
SS:
On this, the .Ly" day of , 2001, before
me, a Notary Public, the undersigned officer, personally appeared D. Timothy
Bollinger, known to me (or satisfactorily proven) to be the person whose name is
subscribed to the foregoing Property Settlement Agreement and acknowledged that
he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Notary Public
NOTARIAL 6EAL
EMILY LONG HOFFMAN, Ndyy PU*
Hanlsburg, Dauphin camly
My Commission Expiree Nov. 12, 2002
EXHIBIT "A"
Descriotion of Marital Asset Total Value
Pace Resource Federal Credit Union $ 2,609.86
Equity in 1995 Saturn $ 3,506.00
24 foot Catalina boat $ 6,200.00
Husband's Cash Surrender Value in Northwestern
Mutual Life Insurance policy $12,859.09
Wife's Cash Surrender Value in Northwestern
Mutual Life Insurance policy $ 2.665.20
$27,840.15
Distribution
Husband's 45% = $12,528.07
Wife's 55% = $15,312.08
Less Husband's credit for credit
card payment - 1,500.00
House proceeds explained below +1,432.60
$15,244.68
Recap
Wife's CSV in NML policy $ 2,665.20
Cash payment to Wife $12.579.48
$15,244.68
Proceeds from sale of the marital residence were $78,652. At settlement, Husband received an
equal share of proceeds less $2,500 or $36,826. Wife received an equal share of proceeds plus
$2,500 or $41,826. Therefore, with the agreed to 55%-45% division of marital assets, Wife
should have received $43,258 and is therefore entitled to an additional $1,432.60.
Retirement benefits: Husband's 401(k) and Wife's PEERS pensions shall be distributed 55% to
Wife and 45% to Husband with Wife's PSERS pension remaining totally in tact. Far example!
Assume hypothetically that husband's pension Is worth $100,000 and wife's pension Is worth
$50,000. The total marital pensions equal $150,000. if wife is to receive 55% of that value, her
share would be $82,500. To reach this amount, she would retain her pension valued at $50,000
and $32,500 from husband's pension. In determining the marital portion of Husband's 401 W,
Harry Leister shall deduct the date of separation value of the existing loan which on that date was
$13,057.63. In the event the date of separation value of either party's pension/retirement is higher
than the current value, due to market fluctuations, then the lower value shall be used. After
establishing the marital values, the pension and retirement benefits discussed herein shall be divided
fifty-five (55%) percent to Wife and forty-five (45%) percent to Husband.
Rite Aid Corporation stock (estimated at 148 shares) to be divided between the parties 55% to Wife
and 45% to Husband.
Qi c%, (-
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7
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L,
L ?? V
IN THE COURT OF COM?ION PLEAS OF
CMIBERLAND COMM, PENNSYLVANIA
NO, 1999-5368CIVIL 19
DORINE A. BOLLINGER
VS.
D. TIMOTHY BOLLINGER
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court
for entry of a divorce decree:
3301(c)
1. Ground for divorce: irretrievable breakdown under Sectionxi"jE W
*EQTMXTZW of the Divorce Code. (Strike out inapplicable section.)
2. Date and manner of service of the complaint:
certified mail, September 14, 1999
3. (Complete either paragraph (a) or (b) .)
(a) Date of execution of the affidavit of consent required by Section
3301(c) December 19, 2001
X?Pk Er? of the Divorce Code: by the plaintiff
by defendant December 20, 2001
(b) (1) Date of execution of the plaintiff's affidavit required by
Section 201(d) of the Divorce Code:
(2) date of service of the plaintiff's affidavit upon the defendant:
4. Related claims pending: None.
Attorney for (Plaintiff)
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DORINE A. BOLLINGER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. S !
D. TIMOTHY BOLLINGER, CIVIL ACTION - LAW
Defendant IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the
claims set forth in the following pages, you must take prompt action.
You are warned that if you fail to do so, the case may proceed without
you and a decree of divorce or annulment may be entered against you by
the court. A judgment may also be entered against you for any other
claim or relief requested in these papers by the plaintiff. You may
lose money or property or other rights important to you, including
custody or visitation of your children.
When the 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
the Cumberland County Court House, 1 Courthouse Square, 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.
The Cumberland County Lawyer Referral Service
Cumberland County ?e-4 se bacr 6-6 ?? ct-a o4 m
Telephone No. (717) ?-3?Fb?6Paro
TUCKER ARENS RG & SWARTZ
Dated: 'I
By: Sandra L. Me Alton
Attorney I.D. #32551
111 North Front Street
P. 0. Box 889
Harrisburg, PA 17108-0889
(717) 234-4121
ATTORNEYS FOR PLAINTIFF
DORINE A. BOLLINGER,
Plaintiff
V.
D. TIMOTHY BOLLINGER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT UNDER SECTION 3301(a ) OF THE DIVORCE CODE
COUNT I:
1. Plaintiff is Dorine A. Bollinger, an adult individual who is
sui juris and resides at 2612 Logan Street, Camp Hill, Cumberland County
Pennsylvania 17011.
2. Defendant is D. Timothy Bollinger, an adult individual who is
sui juris and resides at 848 Long Lane, Gettysburg, Adams County,
Pennsylvania 17325. The present whereabouts of the Defendant, D.
Timothy Bollinger, to the knowledge of the Plaintiff, is the same.
3. Both Plaintiff and Defendant have been bona fide residents in
the Commonwealth of Pennsylvania for at least six (6) months immediately
previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on June 18, 1977, in
Camp Hill, Pennsylvania.
5. There have been no prior actions of divorce or for annulment
between the parties.
6. Plaintiff has been advised of the availability of counseling
and the right to request that the Court require the parties to
participate in counseling.
7. The Defendant is not a member of the Armed Services of the
United States or any of its Allies.
8. The Plaintiff avers that the grounds on which the action is
based is that Defendant has offered such indignities to the person of
the Plaintiff, the innocent and injured spouse, as to render Plaintiff's
condition intolerable and life burdensome, and that this action is not
collusive.
COUNT II:
CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY
UNDER THE DIVORCE CODE
9. Plaintiff and Defendant are the joint owners as tenants by
the entireties of the following real estate which is subject to
equitable distribution by this court:
2612 Logan Street
Camp Hill, PA 17011
10. Plaintiff and Defendant are the owners of various items of
personal property, furniture and household furnishings acquired during
their marriage which are subject to equitable distribution by this
court.
11. Plaintiff and Defendant are the owners of various motor
vehicles, bank accounts, investments, insurance policies and retirement
benefits acquired during their marriage which are subject to equitable
distribution by this court.
COUNT III:
CLAIM FOR ALIMONY UNDER THE DIVORCE CODE
12. The Plaintiff has no adequate means of support for
herself except as provided for by Defendant.
13. Plaintiff is employed as a secretary at Camp Hill School
District in Camp Hill, Pennsylvania, and earned $19,627.70 in 1998.
Defendant is employed as a civil engineer at Buchart Horn, in York,
Pennsylvania, and earned $71,862.93 in 1998.
COUNT IV:
CLAIM FOR ALIMONY PENDENTE LITE, COUNSEL FEES AND
EXPENSES UNDER THE DIVORCE CODE
19. Plaintiff does not have sufficient funds to support herself
and pay counsel fees and expenses incidental to this action.
15. Defendant is full well and able to pay Plaintiff Alimony,
Alimony Pendente Lite, counsel fees and expenses incidental to this
divorce action.
WHEREFORE, Plaintiff requests the Court to enter a Decree:
a. Dissolving the marriage between Plaintiff and
Defendant;
b. Equitably distributing all property owned by the
parties hereto;
C. Directing the Defendant to pay Alimony to the
Plaintiff;
d. Directing the Defendant to pay Alimony Pendente
Lite and Plaintiff's counsel fees and the costs of this proceeding; and
e. For such further relief as the Court may determine
equitable and just.
TUCKER ARENSBERG 6 3WARTZ
Sandra L, eilt , Esquire
111 North Front Street
P.O. Box 889
Harrisburg, PA 17108-0889
(717) 239-9121
ATTORNEYS FOR PLAINTIFF
20596.1
I, the undersigned, Dorine Bollinger, acknowledge that the facts
stated in the foregoing document are true and correct to the best of my
knowledge, information and belief.
I understand that any false statements herein are made
subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to
unsworn falsification to authorities.
Dorine Bollinger
Dated: 8 - Q ? ?1
EMILY LONG HOFFMAN
ATTORNEY AT LAW
?. 105 NOVIt"ON;STREET
HARRISBURG. PENNSYLVANIA 17108-1475
17171 213-1112
D. TIMOTHY BOLLINGER,
Plaintiff
v
DORINE A. BOLLINGER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. No. 99-5368
:CIVIL ACTION-LAW
:DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in Court. If you wish to defend against the claims set forth in
the following pages, you must take prompt action. You are warned that if you fail to do
so, the case may proceed without you and a Decree of Divorce or annulment may be
entered against you by the Court. A judgment may also be entered against you for any
other claim or relief requested in these papers by the Plaintiff. You may lose money or
property or other rights important to you.
When the ground for divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is
available in the office of the Prothonotary at the Cumberland County Courthouse,
Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR
ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM
ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE
YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 240-6200
Le han demandado a usted en Ia corte. Si usted quiere defenderse de estas
demandas expuestas en las paginas siquientes, usted tiene veinte (20) dias de plazo al
partir de lag fecha de la demanda y la notificacion. Usted debe presentar una apariencia
escrita o en persona o por abagado y archival en la corte en forma excrita sus defensas o
sus objecciones a las demandas en contra de su persona. Sea avisado que si ustted no se
defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso
o notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda.
Usted puede perder dinero o sus propiedades o otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABAGADO INMEDIATAIVIENTE. SI NO
TIENE ABAGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL
SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA
CUYA DIRECCION SE ENCURENTRA ESCRITA ABAJO PARA AVERIGUAR
DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 240-6200
D. TIMOTHY BOLLINGER, :IN THE COURT OF COMMON PLEAS
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
V. :No. 99-5368
DORINE A. BOLLINGER, :CIVIL ACTION-LAW
Defendant :DIVORCE
FIRST AMENDED DIVORCE COMPLAINT
I . Plaintiff is D. Timothy Bollinger who has resided at 848 Long Lane,
Gettysburg, Pennsylvania, Adams County, Pennsylvania 17325 since December 1998.
2. Defendant is Dorine A. Bollinger who has resided at 2612 Logan Street,
Camp Hill, Cumberland County, Pennsylvania 17011 for fifteen years.
3. Plaintiff and Defendant have been bona fide residents in the
Commonwealth for at least six (6) months immediately previous to the filing of this
Complaint.
4. The Plaintiff and Defendant were married on June 18, 1977.
5. There have been no prior actions of divorce or annulment between the
parties.
6. Neither of the parties in this action is presently a member of the Armed
Forces.
7. The Plaintiff and Defendant are both citizens of the United States.
8. Plaintiff has been advised of the availability of marriage counseling and
that he may have the right to request the Court to require the parties to participate in such
counseling. Being so advised, Plaintiff does not request that the Court require the parties
to participate in counseling prior to a divorce decree being handed down by the Court.
9. The Plaintiff avers that the marriage is irretrievably broken.
10. The parties have been separated since 1998, thus, they have been separated
for more than two years.
WHEREFORE, Plaintiff requests this Honorable Court enter a decree of
divorce.
Respectfully submitted,
By.
EMILY LON OFFMAN, ESQUIRE
Sup. Ct. I.D. # 66307
105 North Front Street
P.O. Box 11475
Harrisburg, PA 17108-1475
(717) 233-1112
Date: 5/24/2001
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the attached document was served on the
person below on this day by mailing a copy by U.S. First Class mail addressed as follows:
Sandra L. Melton, Esquire
Tucker, Arensberg & Swartz
P.O. Box 889
Harrisburg, PA 17108-0889
Respectfully submitted,
By: 1 -, K--A
Emily LonHoffman, Esquire
Sup. Ct. ID # 66307
105 North Front Street
P.O. Box 11475
Harrisburg, PA 17108
(717)233-1112
Date: 5/29/2001
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• I I I NORTI I FRONT STREET
P.O. BOX 889
HARRISBURG, PENNSYLVANIA 17108,08Y.9 .?o
17171'-344121
DORINE A. BOLLINGER,
Plaintiff
V.
D. TIMOTHY BOLLINGER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. I 1g 1 / - 5 3/t0 (6
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA )
SS:
COUNTY OF DAUPHIN )
AND NOW, this ?q14 day of September , 1999,
personally appeared before me, a Notary Public in and for the
aforesaid Commonwealth and County, Shaun M. Kovach, legal
secretary to Sandra L. Meilton, who being duly sworn according to
law, deposes and says that on September 7, 1999, she mailed a
certified copy of a Complaint in Divorce, by certified mail no.
Z 398 269 550, restricted delivery, return receipt requested, to
D. Timothy Bollinger, 848 Long Lane, Gettysburg, PA 17325, and
the same was received by him on September 14, 1999 as indicated
by the return receipt card which is attached hereto.
?..CSA.fl1?M ? •?`-0u?
Shaun M. Kovach
Sworn to and subscribed
before me this M day
of September , 1999.
Notary Public
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Notarial Seat
i Jacquelyn A. Zettlemoyer, Notary Public
(SEAL) Harrisburg, Dauphin County
My Commission Expires Mar. 24, 2003
Member, Pennsylvania Association of Notaries
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DORINE A. BOLLINGER, : IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99 - 5368 CIVIL
D. TIMOTHY BOLLINGER, CIVIL ACTION - LAW
Defendant : IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
September 1, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of the filing and service of the Complaint.
3. 1 consent to the entry of a final Decree in Divorce.
4. 1 understand that I may lose rights concerning alimony, division of property,
lawyers fees or expenses if I do not claim them before a divorce is granted.
5. 1 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: /?- l f D l Q'bk h ?. ?-
Dorine A.Bollinger, Plaintiff,
S.S. No. 164 - LE - J d l5
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DORINE A. BOLLINGER,
Plaintiff
V.
D. TIMOTHY BOLLINGER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 5368 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c)
OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. 1 understand that I may lose rights concerning alimony, division of
property, lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. 1 understand that I will not be divorced until a divorce decree is
entered by the Court and that a copy of the decree will be sent to me immediately after it
is filed with the prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
Date:
Dorine A. Bollinger, Plaintiff
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DORINE A. BOLLINGER, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99 - 5368 CIVIL
D. TIMOTHY BOLLINGER, CIVIL ACTION - LAW
Defendant IN DIVORCE
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
September 1, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of the filing and service of the Complaint.
3. 1 consent to the entry of a final Decree in Divorce.
4. 1 understand that I may lose rights concerning alimony, division of property,
lawyers fees or expenses if I do not claim them before a divorce is granted.
5. 1 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: itto I•. ;D• 1 Mn t+a?
D. Timothy Bollin r, Defends t
S.S. No. t?&-44- 86611
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DORINE A. BOLLINGER,
Plaintiff
V.
D. TIMOTHY BOLLINGER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 5368 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c)
OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. 1 understand that I may lose rights concerning alimony, division of
property, lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. 1 understand that I will not be divorced until a divorce decree is
entered by the Court.and that a copy of the decree will be sent to me immediately after it
is filed with the prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
Date: 12 IZ?/o t a ?vw et?n n t?'Ju?,Qe qt?t,
43568.1 D. Timothy Bollin r, Defendant
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D. TIMOTHY BOLLINGER
VS.
DORINE A. BOLLINGER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff CIVIL ACTION - LAW
NO.99-5368 CIVIL 19
IN DIVORCE
Defendant
STATUS SHEET
DATE:
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D. TIMOTHY BOLLINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
Vs. NO. 99 - 5368 CIVIL
DORINE A. BOLLINGER,
Defendant IN DIVORCE
TO: Emily Long Hoffman Attorney for Plaintiff
Sandra L. Meilton Attorney for Defendant
DATE: Wednesday, April 11, 2001
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'
(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.
DORINE A. BOLLINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 99 - 5368 CIVIL
D. TIMOTHY BOLLINGER,
Defendant IN DIVORCE
CONFERENCE WITH
COLMSEL AND PARTIES
TO: Sandra L. Meilton Counsel for Plaintiff
Dorine A. Bollinger Plaintiff
Emily Long Hoffman Counsel for Defendant
D. Timothy Bollinger Defendant
A conference has been scheduled at the Office of
the Divorce Master, 9 North Hanover Street, Carlisle,
Pennsylvania, on the 26th day of September, 2001, at 1:30
p.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: 9/7/01 E. Robert Elicker, II
Divorce Master
D. TIMOTHY BOLLINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 99 - 5368 CIVIL
DORINE A. BOLLINGER,
Defendant IN DIVORCE
NOTICE OF PRE-HEARING CONFERENCE
TO: Emily Long Hoffman
Sandra L. Meilton
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 7th of September, 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: 6/25/01 E. Robert Elicker, II
Divorce Master
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OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240-6535
E. Robert Elicker, 11
Divorce Master
West Shore
697.0371 Ext. 6535
Traci Jo Colyer
Oltice Manager/Reporter
May 30, 2001
Emily Long Hoffman
Attorney at Law
105 North Front Street
P.O. Box 11475
Harrisburg, PA 17108-1475
Sandra L. Mcilton
Attorney at Law
TUCKER, ARENSBERG & S WARTZ
I I 1 North Front Street
P.O. Box 889
Harrisburg, PA 17108-0889
RE: D. Timothy Bollinger vs. Dorine A. Bollinger
No. 99 - 5368 Civil
In Divorce
Dear Ms. Long and Ms. Meilton:
Counsel have indicated by filing the certification documents regarding discovery
that discovery is complete. Consequently, I am going to go forward with a directive for
the filing of a pretrial statement.
A divorce complaint was filed on September 1, 1999, raising grounds for divorce
of indignities. I spoke to both counsel regarding the grounds for divorce of irretrievable
breakdown, I am waiting to have a pleading filed raising that ground. Otherwise, if
grounds for divorce of irretrievable breakdown of the marriage are not filed within two
weeks, I intend to schedule a hearing immediately on indignities so that we can resolve
the grounds for divorce issue promptly.
The complaint also raised economic claims of equitable distribution, alimony,
alimony pendente lite, and counsel fees and expenses.
In accordance with P.R.C.P. 1920.33(b) I am directing each counsel to file a
pretrial statement on or before Monday, June 18, 2001. Upon receipt of the pretrial
statements, I will immediately schedule a pre-hearing conference with counsel to discuss
IN
Ms. Long and Ms. Meilton, Attomeys at Law
30 May 2001
P 2
the issues and, if necessary, schedule a hearing.
Very truly yours,
E. Robert Elicker, If
Divorce Master
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,
EMILY LONG HOFFMAN
ATTORNEY A- LAW
105 NORTH FRONT STREET
P O. BOX 11475
HARRISBURG. PA 17108.1475
255 MARKET STREET
MILLERSBURG. PA 17061
(717) 692-424.1
June 15, 2001
Robert Elicker, Esquire
13 North Hanover Street
Carlisle, Pa 17013
Re: Bollinger v. Bollinger
Dear Attorney Elicker:
(717) 233-1112
FAX(717) 234.2234
e m.d: Boffmanepepix.nel
Enclosed please find our Pre-trial Statement for the above-matter. Thank you for your
consideration.
Sincerely yours,
("I
4__Qonj? man
Enclosure
cc: Sandra Wilton, Esquire
Timothy Bollinger
TUCKER ARENSBERG & SWARTZ
I I I NORI'II FRONT S'1'RIA:1-
RO. BOX S89 MAY A l 2001
IL\RRIS81'R0. 1'I'N,N:SYLVANIA 171(MOMv `n'?'? -
(717) 234-4121 DORINE A. BOLLINGER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 99-5368
D. TIMOTHY BOLLINGER, CIVIL ACTION -LAW
Defendant IN DIVORCE
a.. 7 r. 2001, a Rule is issued on
AND NOW, this day of
the Defendant to show cause why the relief sought within the Petition should not be
granted.
This Rule IS RETURNABLE hers"" ??
01 Glol, 4U _60-
BY THE COURT:
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DORINE A. BOLLINGER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-5368
D. TIMOTHY BOLLINGER, CIVIL ACTION -LAW
Defendant : IN DIVORCE
AND NOW comes Plaintiff, Dorine Bollinger, by and through her attorneys,
Sandra L. Meilton, Esq., TUCKER ARENSBERG & SWARTZ, and hereby avers the
following in support of her Petition:
1. Plaintiff, Dorine Bollinger, currently resides at 2612 Logan Street,
Camp Hill, Cumberland County, Pennsylvania.
2. Defendant, Timothy Bollinger, currently resides at 19 S. 24'h Street,
Camp Hill, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant were married on June 18, 1977 and have since
separated.
4. The parties are the natural parents of three children, one of which is a
minor and resides with Plaintiff. The other two children are in college and live with Plaintiff
during the school breaks and summers.
5. A divorce complaint has been filed, the action has been listed with a
Master and the parties have each filed Inventory and Appraisements and Income and
Expense Statements.
6. The parties are the owners of the marital residence in which the
Plaintiff is currently residing and has resided since the parties' separation.
7. Through counsel, the parties have engaged in settlement negotiations
to reach an agreement with regard to the distribution of the marital assets and liabilities.
8. Throughout these negotiations, Defendant has consistently taken the
position that he does not wish to resume responsibility of the marital residence and further
does not wish to retain ownership of the property. Plaintiff has been residing in the marital
residence since the parties' separation, has assumed sole responsibility for the residence
and has always maintained the position that she desired to keep the marital residence.
Defendant has been in agreement with Plaintiff keeping the residence.
9. Plaintiff has found that it is too difficult for her to maintain the
residence and has listed the property for sale. Plaintiff listed the house for sale with the
intention that she would purchase a new residence.
10. Defendant and Plaintiff have signed a sales agreement with Plaintiff to
list the property for sale.
11. A buyer has been secured for the purchase of the marital residence.
12. In reliance on the sale of the residence, Plaintiff entered into a contract
for the purchase of a townhouse and settlement is scheduled to occur on the townhouse on
June 29, 2001.
13. Plaintiff does not have funds available to purchase the townhouse and
secure a mortgage without the proceeds from the sale of the marital residence because
Plaintiff only earns a net annual income of approximately $21,000.
14. Plaintiff is able to lease the townhouse for only one month and then
must complete the purchase of the townhouse.
A
15. Defendant has refused to release all of the sale proceeds to Plaintiff
and to sign an Addendum to the sales agreement setting forth his release of the proceeds.
16. Although the Master's process has been initiated, the process will not
be completed prior to settlement on Plaintiffs townhouse on June 29, 2001.
17. Plaintiff intends to use the sale proceeds for the purchase of the
townhouse.
18. Defendant has a 401(k) with PACE Resources that has a minimum
balance in excess of $160,000, which is of a significant amount to adequately secure his
share of equitable distribution.
WHEREFORE, Plaintiff respectfully requests that the Court direct that
Defendant cooperate in all respects to finalize the sale of the marital residence and further
that the proceeds from the sale of the marital residence be distributed to Plaintiff.
Respectfully submitted,
TUCKER ARENSBERG & SWARTZ
By:
Sandra L. Meilton
I.D. No. 32551
111 North Front Street
P.O. Box 889
Harrisburg, PA 17108
39555.1 ATTORNEYS FOR PLAINTIFF
VERIFICATION
I, the undersigned, Dorine Bollinger, do hereby certify that the statements made in the
foregoing document are true and correct to the best of my knowledge, information and
belief. I understand that any false statements made to this verification are subject to the
penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities.
Date: '5 d 5 ) O ? ?m? . \ ? • ? ?
Dorine Bollinger, Plaintiff
AND NOW, this ag-N, day of _ )2n L)J4 , 2001, I, Shaun M, Kovach,
Secretary to Sandra L. Meilton, Esquire, for the firm ofTucker Arensberg & Swartz, hereby
certify that I have this day served a copy of the within document, by mailing same by first class
mail, postage prepaid, addressed as follows:
Emily Long Hoffman, Esquire
P.O. Box 11475
Harrisburg, PA 17108-1475
Jkc m .
Shaun M. Kovach
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TUCKER ARENSBERG & SWARTZ
I I I NOR'HI FRONT SI'RIT.I-
1lO llox 839
IL\RI213BPRt i. I'6NNS1'I\',\P'I,\ 11111%?utl3n +
1717) ?34-412_1
DORINE A. BOLLINGER,
Plaintiff
V.
D. TIMOTHY BOLLINGER,
Defendant
PROTHONOTARY:
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5368
CIVIL ACTION -LAW
IN DIVORCE
PRAECIPE
Plaintiff hereby withdraws the Petition For Immediate Relief filed in the above matter.
4A 0?1 ?/N ?
Sandra L. Meilton, Esquire
Attorney I.D. #32551
TUCKER ARENSBERG & SWARTZ
111 N. Front Street, P.O. Box 889
Harrisburg, PA 17108
Dated: 1 I3 I' D ATTORNEYS FOR PLAINTIFF
a
I
AND NOW, this ,)_-day of 2000, I, Gloria M. Rine, Legal
Assistant to Sandra L. Meilton, Esquire, for the firm of Tb6ker Arensberg & Swartz, hereby certify
that I have this day served a copy of the within document, by first class mail, addressed as follows:
Emily Long Hoffman, Esquire
P.O. Box 11475
Harrisburg, PA 17108-1475
Honorable J. Wesley Oler
Cumberland County Court House
One Courthouse Square
Carlisle, PA 17013
Gloria M. Rine
28683.1
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TUCKER ARENSBERG & SWARTZ
CLLEBRAI'ING A CLN IUR1 UI SI RVI(I.
Sandra L. Meilton
April 19, 2001
Robert E. Elicker II, Esquire
9 North Hanover Street
Carlisle, PA 17013
RE: Bollinger
Dear Mr. Elicker:
Enclosed please find Dorine A. Bollinger's certification that discovery is complete in the
above referenced matter.
Thank you for your assistance.
Sincerely,
TUCKERpARENSBERG & SWARTZ
Sandra L. Meilton
SLM/smk
Enclosure
cc: Mrs. Dorine Bollinger
I I1 NORTH FRONT STREET PO BOX 889 HARRISBURG. PA 17108.0889 717234-4121 800.2574121 FAX 717.232.6802
P111 11,11Wn • PIMIhWgIi Aupo,1 Area Lavusiown
F.-m,ul 1:1$)CwUCkw1arv com
www.tuckerlaw.com
HOFFMAN LONG LLP
ATTORNEYS AT LAW
105 NORTH FRONT STREET
P. O. BOX 11475
FIARRISSNRG, PENNSYLVANIA 17108-1475
1717) 233-1112
FAX (717) 234-2234
EMILY LONG HOFFMAN
RICHARD W. LONG'
•.EO YEMEER or "..'.A BAR
May 26, 2001
Robert Elicker, Esquire
13 North Hanover Street
Carlisle, Pa 17013
Dear Attorney Elicker:
Enclosed please find our certification.
Sincerely yours,
Emi y on?
253 MARKCT STREET
MILLERSBURG, PA 17061
(717) 692.4244
Enclosure
cc: Sandra Meilton, Esquire
D. TIMOTHY BOLLINGER,
Plaintiff
VS.
DORINE A. BOLLINGER
Defendant
TO: Emily Long Hoffman
Sandra L. Meilton
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 5368 CIVIL
IN DIVORCE
Attorney for Plaintiff
Attorney for Defendant
DATE: Wednesday, April 11, 2001
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.
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
r1l
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.
1
D. TIMOTHY BOLLINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99 - 5368 CIVIL
DORINE A. BOLLINGER,
Defendant IN DIVORCE
TO: Emily Long Hoffman Attorney for Plaintiff
Sandra L. Meilton Attorney for Defendant
DATE: Wednesday, April 11, 2001
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.
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
7 DATE COUNSEL FOR PLAINTIFF
( )
COUNSEL FOR DEFENDANT (?S
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.
71
EMILY LONG HOFFMAN
ATTORNEY AT LAW
• 106 NORTH FRONT STREET
? - HARRISBURG. PENNSYLS.,ANIA 17108-147,1
17171 751-1112
D, TIMOTHY BOLLINGER,
Plaintiff
V.
DORINE A. BOLLINGER,
Defendant
AN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
:No. 99.5368
:CIVIL ACTION-LAW
:DIVORCE
AND NOW, this S_ ` Day of , 2001,
Esquire, is appointed master with respect to the following claims: Equitable Distribution, Alimony,
Alimony Pendente Lite, Counsel Fees and Costs and Expenses.
BY THE COURT:
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D. TIMOTHY BOLLINGER, IN THE COURT OF COMMON PLEAS
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
V. :No. 99-5560
DORINE A. BOLLINGER, :CIVIL ACTION-LAW
Defendant :DIVORCE
MOTION FOR APPOINTMENT OF MASTER
D. TIMOTHY BOLLINGER (X)Plaintiff () Defendant, moves the court to appoint a
master with respect to the following claims:
(X) Divorce (X) Distribution of Property
() Annulment () Support
(X) Alimony (X) Counsel Fees
(X) Alimony Pendente Lite (X) Costs and Expenses
and in support of the motion states:
1. Discovery is complete as to the claim(s) for which the appointment of a master is requested.
2. The defendant (X ) has () has not appeared in the action () personally (X ) by attorney,
SANDRA MEILTON , Esquire.
3. The statutory grounds(s) for divorce (is) 3301(d)
4. Check the applicable paragraph(s) by check mark:
() The action is not contested.
() An agreement has been reached with respect to the following
claims:
(X) The action is contested with respect to the following claims: Equitable
Distribution,
Alimony, Alimony Pendent Lite, Counsel Fees, Costs and Expenses
5. The action () involves (X) does not involve complex issues of law or fact.
6. The hearing is expected to take 6 (hours) (days).
7. Additional information, if any, relevant to the motion: (2, W- ?1 X'f ('4jn'
Date: j asl ko t r -
E ily Lon ffman, Attorney for Plaintiff
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the attached document was served on the
person below by U.S. Mail on this day:
Sandra L. Meilton, Esquire
Tucker, Arensberg & Swartz
P.O. Box 889
Harrisburg, PA 17108-0889
Respectfully submitted,
By: `l'oll ?? ??
Emily Long Hoffman, Esquire
Sup. Ct. ID # 66307
105 North Front Street
P.O. Box 11475
Harrisburg, PA 17108
(717)233-1112
Date: 3/29/01
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EMILY LONG HOFFMAN
ATTORNEY AT LAW _
103 NORM FRONT STREET
HARRISBURG. PENNSYLVANIA 1710 6-4 75
17171113-1112 .c
DORINE A. BOLLINGER,
Plaintiff'
V.
D. TIMOTHY BOLLINGER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 99-538
CIVIL ACTION - LAW
IN DIVORCE
ORDER
AND NOW, this day of , 2001, it is hereby
ORDERED and DECREED that Plaintifrs Petition for Special Relief is denied.
J.
DORINE A. BOLLINGER,
Plaintiff
V.
D. TIMOTHY BOLLINGER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-538
CIVIL ACTION - LAW
IN DIVORCE
DEFENDANT'S RESPONSE TO PLAINTIFF'S
PETITION FOR SPECIAL RELIEF
AND NOW comes Defendant, D. Timothy Bollinger, by and through his attorney, Emily
Long Hoffman, Esquire, and hereby avers the following in support of his Response to Plaintiff's
Petition for Special Relief
1. Admitted.
2. Admitted.
3. Admitted.
4. Denied. It is denied that the other two children are in college. By way of further
explanation, Stephanie, the oldest child, has graduated from college and moved to Florida. Julie
is home from college for the summer and, at this time, it is undecided where she will go to school
in the fall.
5. Admitted.
6. Admitted.
7. Admitted.
8. Admitted in part, denied in part. It is specifically denied that throughout these
negotiations, Defendant has consistently taken the position that he does not wish to resume
responsibility of the marital residence. By way of further explanation, Defendant has maintained
responsibility for the marital home since separation and he has consistently paid for the first and
second mortgages and other additional expenses for the home in an amount equal to $41,922.09
since separating (these figures are in addition to the monies he has expended for his Wife's life
insurance, her taxes, his daughters' housing expenses while at school, child support and other
items paid). It is further denied that Plaintiff has assumed sole responsibility for the residence
and has always maintained the position that she desired to keep the marital residence. It is further
denied that Defendant has been in agreement with Plaintiff keeping the residence. Defendant
requires a residence as well.
9. This is an averment to which no response is required as Defendant has no knowledge
of Plaintiff's state of mind or intention and, as such, this response is deemed denied.
10. Admitted.
11. Admitted.
12. This is an averment to which no response is required as Defendant has no knowledge
of Plaintiffs state of mind or intention and as such, this response is deemed denied.
13. This is an averment to which no response is required as Defendant has no knowledge
of Plaintiffs available funds and, as such, this response is deemed denied. Nonetheless, even if i
Plaintiff were released all the funds, it is believed that Plaintiff would not have funds available to
purchase the townhouse because the cost of the townhouse is $160,000 with an $85 per month
maintenance fee. Furthermore, if this Court were to release one half of the proceeds to Wife and
one half to the Husband (as previously suggested by Husband) the difference in the mortgage
payment is only approximately $269.00 per month. If plaintiffs income is not sufficient to
support the townhouse then she should not have entered into the contract.
14. This is an averment to which no response is required as Defendant has no knowledge
of the terms of Plaintifrs agreement and, as such, this response is deemed denied. We have not
been informed of the terms of Plaintiffs Agreement but we suspect that the contract provides
that she may terminate the contract in the event she is unable to obtain financing.
15. Admitted. By way of further explanation, Defendant desires to utilize the proceeds to
purchase his own home.
16. Admitted.
17. This is an averment to which no response is required as Defendant has no knowledge
of Plaintiffs state of mind or intention and, as such, this response is deemed denied.
18. Denied. It is specifically denied that Defendant has a 401(k) with PACE Resources
that has a minimum balance in excess of $160,000. By way of further explanation, Defendant
has a 401 (k) which has a current value of $132,000. If Defendant would withdraw the funds in
his 401 (k) he would incur capital gains taxes and a penalty for early withdrawal.
WHEREFORE, Defendant respectfully requests that this Honorable Court deny
Plaintiff's Petition for Special Relief.
Respectfully submitted,
LONG HOFFMAN, LIIL,,P
By
Emily Long Hoffman
I.D. No. 66307
105 N. Front Street
P. 0. Box 11475
Harrisburg PA 17108
ATTORNEYS FOR DEFENDANT
Date: 6/22/2001
CERTIFICATE OF SERVICE
1 hereby certify that a true and correct copy of the attached document was served on the
person below on this day by hand delivery to the person listed below:
Sandra L. Meilton, Esquire
Tucker, Arensberg & Swartz
P.O. Box 889
Harrisburg, PA 17108-0889
Respectfully submitted,
By: _ FA-L 'L ,
Emily Long o an, Esquire
Sup. Ct. ID # 66307
105 North Front Street
P.O. Box 11475
Harrisburg, PA 17108
(717)233-1112
Date: 6/25/2001
Ol
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M1LY LONG HOFFMAN
ATTORNEY AT LAW
- 105 NORTII FRONT STREET
HARRISBURG, PENNSYLVANIA 17108-1475
(717) 235.1112
DORINE A. BOLLINGER,
Plaintiff
V.
D. TIMOTHY BOLLINGER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-538
CIVIL ACTION - LAW
IN DIVORCE
ORDER
AND NOW, this day of 2001, it is hereby
ORDERED and DECREED that Plaintiffs Petition for Special Relief is denied.
J.
DORJNE A. BOLLINGER,
Plaintiff
V.
D. TIMOTHY BOLLINGER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-538
CIVIL ACTION - LAW
IN DIVORCE
DEFENDANT'S RESPONSE TO PLAINTIFF'S r'
PETITION FOR SPECIAL RELIEF ?i
f 1
AND NOW comes Defendant, D. Timothy Bollinger, by and through his aitorney, _) mily
Long Hoffman, Esquire, and hereby avers the following in support of his Response to Plaihtin,2
Petition for Special Relief:
1. Admitted.
2. Admitted.
3. Admitted.
4. Denied. It is denied that the other two children are in college. By way of further
explanation, Stephanie, the oldest child, has graduated from college and moved to Florida. Julie
is home from college for the summer and, at this time, it is undecided where she will go to school
in the fall.
5. Admitted.
6. Admitted.
7. Admitted.
8. Admitted in part, denied in part. It is specifically denied that throughout these
negotiations, Defendant has consistently taken the position that he does not wish to resume
responsibility of the marital residence. By way of further explanation, Defendant has maintained
responsibility for the marital home since separation and he has consistently paid for the first and
second mortgages and other additional expenses for the home in an amount equal to $41,922.09
since separating (these figures are in addition to the monies he has expended for his Wife's life
insurance, her taxes, his daughters' housing expenses while at school, child support and other
items paid). It is further denied that Plaintiff has assumed sole responsibility for the residence
and has always maintained the position that she desired to keep the marital residence. It is further
denied that Defendant has been in agreement with Plaintiff keeping the residence. Defendant
requires a residence as well.
9. This is an averment to which no response is required as Defendant has no knowledge
of Plaintiff s state of mind or intention and, as such, this response is deemed denied.
10. Admitted.
11. Admitted.
12. This is an averment to which no response is required as Defendant has no knowledge
of Plaintiffs state of mind or intention and as such, this response is deemed denied.
13. This is an averment to which no response is required as Defendant has no knowledge
of Plaintiffs available funds and, as such, this response is deemed denied. Nonetheless, even if
Plaintiff were released all the fimds, it is believed that Plaintiff would not have funds available to
purchase the townhouse because the cost of the townhouse is $160,000 with an $85 per month
maintenance fee. Furthermore, if this Court were to release one half of the proceeds to Wife and
one half to the Husband (as previously suggested by Husband) the difference in the mortgage
payment is only approximately $269.00 per month. If plaintiffs income is not sufficient to
support the townhouse then site should not have entered into the contract.
14. This is an averment to which no response is required as Defendant has no knowledge
of the terms of Plaintiffs agreement and, as such, this response is deemed denied. We have not
been informed of the terms of Plaintiff's Agreement but we suspect that the contract provides
that she may terminate the contract in the event she is unable to obtain financing.
15. Admitted. By way of further explanation, Defendant desires to utilize the proceeds to
purchase his own home.
16. Admitted.
17. This is an averment to which no response is required as Defendant has no knowledge
of Plaintiff's state of mind or intention and, as such, this response is deemed denied.
18. Denied. It is specifically denied that Defendant has a 401(k) with PACE Resources
that has a minimum balance in excess of $160,000. By way of further explanation, Defendant
has a 401 (k) which has a current value of $132,000. If Defendant would withdraw the funds in
his 401 (k) he would incur capital gains taxes and a penalty for early withdrawal.
WHEREFORE, Defendant respectfully requests that this Honorable Court deny
Plaintiffs Petition for Special Relief.
Respectfully submitted,
LONG HOFFMAN, LLP
By
Emily Long Hoffman
I.D. No. 66307
105 N. Front Street
P. 0. Box 11475
Harrisburg PA 17108
ATTORNEYS FOR DEFENDANT
Date: 6/22/2001
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the attached document was served on the
person below on this day by hand delivery to the person listed below:
Sandra L. Meilton, Esquire
Tucker, Arensberg & Swartz
P.O. Box 889
Harrisburg, PA 17108-0889
Res ectfully submitted,
By:
Emily Long Ho man, Esquire
Sup. Ct. ID # 66307
105 North Front Street
P.O. Box 11475
Harrisburg, PA 17108
(717)233-1112
Date: 6/25/2001
EMILY LONG HOFFMAN
s<'S,
ATTORNEY AT LAW
lap NORM FRONT 9rRFFl' ,. r
IIARRISOURG, PENNSYLVANIA 1710»-1475
17171 241-1112
SR...
DORINE A. BOLLINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-538
D. TIMOTHY BOLLINGER, CIVIL ACTION - LAW
Defendant IN DIVORCE
DEFENDANT'S MEMO IN SUPPORT OF RESPONSE TO PLAINTIFF'S
PETITION FOR SPECIAL RELIEF
1. FACTS
The parties, Dorine Bollinger (hereinafter "Wife") and D. Timothy Bollinger (hereinafter
"Husband"), were separated in October 1998. Wife lives in the marital home located in Camp
Hill with the parties' minor children Katie, age 15. The parties oldest daughter, Stephanie,
recently graduated from Bucknell University and moved to Florida. Julie, age 19, is a college
student and lives with Wife during her summer break. D. Timothy Bollinger (hereinafter
"Husband"), initially after separation resided with his mother. He now resides in a two bedroom
apartment in Camp Hill (for which he pays approximately $300 per month) with an apartment
mate with whom he shares expenses. Husband would like to buy a place of his own.
Since the date of separation, Husband has paid the first and second mortgages, the
utilities, support, Wife's life insurance. From October 1998 to the present, Husband has paid to
Wife or on behalf of Wife $57,344.97. In addition, Husband paid $360 per month for
Stephanie's apartment while she was in school at Bucknell and sent Stephanie and Julie each $40
per pay period while they were attending college and also put loans against his life insurance
policy and 401 k in order to assist with the tuition. In return, Wife took Husband off her health
and dental insurance without informing him before hand. As a result, Husband incurred
considerable additional unnecessary expense when he had substantial dental work performed and
then learned that she had dropped him beforehand from coverage.
Wife, by letter dated March 29, 2001, informed Husband that she found a buyer for the
marital home and that she wanted to use the total net proceeds from the sale (estimated to be
$75,000 to $80,000) to purchase another home. Husband, by letter dated April 2, 2001,
responded that he needed funds at the time of settlement to purchase a home and set forth his
willingness to work with Wife to effectuate a partial distribution of the proceeds from which both
parties would receive funds. Wife entered into an alleged sales contract to purchase a home for
$160,000 without Husband's agreement to release all the funds to her nor with his knowledge.
The only other marital asset of any value is Husband's 401(k). If Defendant would withdraw the
funds in his 40 1(k), he would incur capital gains taxes and a penalty for early withdrawal.
Husband filed a Motion to Appoint Master on March 29 and thus the Master will most likely
resolve the equitable distribution matter in the near future.
II. ARGUMENT
In the interest of fairness and equity, Husband is entitled to a share of the proceeds from
the home, the only liquid asset of the marital estate. Wife had the power all along to seek
appointment of the divorce master prior to selling the home. Furthermore, there is no sense of
urgency for Wife to go out and purchase a home of her own at this time. All along, Husband has
been willingly and voluntarily paying above and beyond his fair share of his obligated support
and has maintained the mortgages and expenses associated with the home.
If this Honorable Court should release the proceeds to Wife, Husband will be unable to
purchase a home of his own. Currently, his daughters do not stay overnight at his apartment
because there is no room for them. Husband would tike to purchase a home so that they have a
place to sleep.
Husband, unless provided liquid funds, will not be able to afford a home on his own.
Husband, after separation, has greatly reduced his lifestyle expenses. Conversely, Wife is
maintaining the same lifestyle by purchasing a $160,000 home. Husband, through his search for
his own home, has found suitable three bedroom homes in the Camp Hill area for under
$125,000. Wife maintains that she needs all the proceeds from the home to purchase her
$160,000 home. Husband has a good job, however, his expenses exceed his income.
It is anticipated that Husband's adverse financial condition will not be alleviated for years
to come. Husband will have child support payments for three more years plus college expenses
for two children. Most likely, Husband will be obligated to pay some form of alimony. It is
anticipated that his child support and alimony will be at least $1,300 per month. In addition,
Husband will have to continue paying the current loan against his 401 k in the amount of $154 per
month which loan was used for his oldest daughter's college education, and other loans in the
amount of $349 per month which includes the loan against his life insurance policy for his
daughter's college education. There is also credit card debt from the marriage that Husband
pays.
To release all of the proceeds of the sale of the home to Wife would be inequitable and
patently unfair to Husband. Husband has, to his credit, provided for his Wife and children
voluntarily over and above his legal obligation since the date of separation. To allow Wife to
maintain her standard of living to the levels achieved during the marriage while Husband lives a
sub-standard existence would be inequitable. Husband will suffer irreparable harm if the only
liquid assets of the marriage are awarded in totality to Wife. Husband too has a right to own a
home.
WHEREFORE, Defendant respectfully requests that this Honorable Court deny
Plaintiffs Petition for Special Relief.
Respectfully submitted,
LONG HOFFMAN, LLP
By LG?-
Emily Long Hoffman
I.D. No. 66307
105 N. Front Street
P. O. Box 11475
Harrisburg PA 17108
ATTORNEYS FOR DEFENDANT
Date: 6/25/2001
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the attached document was served on the
person below on this day by hand delivery to the person listed below:
Sandra L. Meilton, Esquire
Tucker, Arensberg & Swartz
P.O. Box 889
Harrisburg, PA 17108.0889
Res ectfully submitted,
By:
Emily Long go man, Esquire
Sup. Ct. ID # 66307
105 North Front Street
P.O. Box 11475
Harrisburg, PA 17108
(717)233-1112
Date: 6/25/2001
D, TIMOTHY BOLLINGER,
Plaintiff
v
DORINE A. BOLLINGER,
Defendant
JN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-5560
:CIVIL ACTION-LAW
:DIVORCE
INVENTORY AND APPRAISEMENT
OF
D, TIMOTHY BOLLINGER
D. Timothy Bollinger files the following Inventory and Appraisement of all property
owned or possessed by either party at the date of separation and all property transferred within
the preceding three years,
Ile verifies that the statements made in this Inventory and Appraisement are true and
correct. Ile understands that false statements herein are made subject to the penalties of 18
Pa.C.S, §4904 relating to unsworn falsification to authorities.
p ?
D. Timothy Bollin r
ASSETS OF PARTIES
( X) I . Real property
( 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
( ) 8. •rmsts
( X) 9. Life insurance policies (indicate face value, cash surrender value and current
beneficiaries)
( ) 10. Annuities
( ) ll. Gifts
( ) 12. 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 benefits - severance pay, workman's compensation
clahn/award
( ) 17. Profit sharing plans
( X ) 18. Pension plans (indicate employee contribution and date plan vests)
( X ) 19. Retirement plans, Individual Retirement Accounts
( ) 20. Disability payments
( ) 21. Litigation claims (matured and unmatured)
( ) 22. MilitaryN.A. benefits
( ) 23. Education benefits
( X) 24. Debts due, including loans, mortgages held
( X) 25. Household furnishings and personalty
( X) 26. Other
MARITAL PROPERTY
List nll marital property in which either or both spouses have a legal or equitable interest
individually or with any other person as of the dale this action was commenced:
Item Description Nantes of
Number of Pr perty All Owners
1 2612 Logan Street 11 & W
Camp Hill, Pennsylvania
2 1995 Saturn 11 & %V
2 1998 Jeep (lease) W
l 168 shares Rite-Aid stock II & W
S Pennsylvania State Bank 11 & W
6 Pace Resources FCU 11
9 Northwestern Mutual W
9 Notthwestern Mutual If
(Loan against)
19 PSERS W
19 Pace Resources, Itic. 401K 11
24 Citi Mortgage II & W
24 Pa. State Bank 1Ionte Equity Loan I I & W
24 Loan against Northwestern policy 11
24 Visa 11 & W
24 Master Card II & W
24 PACE. Iesources FCU car loan II (husband paid ofl)
24 80111'011 Charge 11 k %V
24 Loan against 401K for if
daughter's college education
25 Nome Furnishings I I & W
25 Pace Resources FCU (boat loan) It
26 25 Foot Catalina Sail Boat If
LIABILITIES
Item
Number Creditor Debtor D value Pavor
24 Mortgage H & W
24 1lome Equity Loan 11 & W
24 Loan against Northwestern policy I I
24 Visa
24 Master Card
24 PACE Resources FCU car loan I I (husband paid off)
24 DonTon Charge 11 & W
24 Loan against 401 for daughters 11
college education
24 Mathias and I Joke I I
dental bill for I lusband. Wife
dropped I lusband from coverage in summer
of 2000 without his knowledge even though
it was available at not cost through her
employer
24 Health insurance @ $60.00 per month H
Wife dropped Husband from coverage
in summer of 2000 without his knowledge
even though it was available at not cost through her
employer
D. TIMOTHY BOLLINGER,
Plaintiff
V.
DORINE A. BOLLINGER,
Defendant
IN TIIE COURT Of COMMON PLEAS
CUN11lERLAND COUNTY, PENNSYLVANIA
No.
CIVII. ACTION-LAW
DIVORCE
INCOME AND F,3(PEN9E
OF
PLAIN'LMI? , D. TIMOTHY I1O1,1,INGER
Plaintiff Files the following Income and Expense Statement.
Plaintiff verifies that the statements made in this Income and Expense Statement we 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.
?D. fl! e ..?1.?
D. TIMOTHY BOLL INGER
3/1/01
INCOME AND EXPENSE STATEMENT OF
D. TIMOTIIY BOLLINGER
INCOME
Employer: Buchan-Ilotn
Address 445 W. Philadelphia St.. York. PA 17404
Type of Work: Electrical Engineering Payroll Number: 1698
Pay Period (weekly, biweekly, etc.): Biweekly
Gross Pay per Pay Period: $_ 2.800
Itemized Payroll Deductions
Federal Withholding $ 569
FICA $_ 174
Local Wage Tax $ 0
State Income Tax $ 78
Medicare $ 41
Retirement 401(k) $ 28
Savings Bonds $ 0
Credit Union $ 349 (Includes two loans)
Life Insurance $ 0
Health Insurance $ 34
Other - LTD $ 4 Long term disability
401(k)loan repay $ 155
Net Pay per Pay Period: $ 1.368
Week Month
(Fill in Appropriate Column)
Other Income: N/A
Interest -
Individual $ $ 5 $
Joint
Dividends
Pension
Annuity
Social Security
Rents
Royalties
Expense Account
Gifts
Unemployment Comp _
Workmen's Comp.
Total $ $ 5 $
TOTAL NIONTIII,Y NET INCOME $ 2.969
Year:
EXPENSES
Week Month Year
Home
Mortgage (I sl) $ $1006 $
Mortgage (2nd) 250
Maintenance
Apartment 225
Utilities
Electric & Gas 50
Sewer/Garbage 10
Telephone 25
Water _
Employment
Public
Transportation
Lunch 60
Taxes
Real Estate
Personal Tax 90
Income
Insurance
Homeowners
Automobile 100
Life 160
Accident
Health
Other (boat) 15
Automobile
Car (pmt./maint)
Boat (pmt./maint) _ 130
Fuel 80
Repairs 30
Medical
Doctor/Dentist 20
Hospital
Special needs
(glasses, braces,
orthopedic
devices) 20
Education
Private school
Enrichment courses
College 520
Religious
- 3 -
INCOME AND EXPENSE STATEMENT OF
D- TIMOTHY BOLLINGER
INCOME
Employer: Buchart-Horn
Address 445 W. Philadelphia St York PA 17404
Type of Work:_Electrical Enstinecrint; Payroll Number: 1698
Pay Period (weekly, biweekly, etc ): Biweekly _
Gross Pay per Pay Period: $_ 2.800
Itemized Payroll Deductions
Federal Withholding $ 569
FICA $ 174
Local Wage Tax $ 0
State Income Tax $ 78
Medicare $ 41
Retirement 401(k) $ 28
Savings Bonds $ 0
Credit Union $ 349 (Includes two loans)
Life Insurance $ 0
Health Insurance $ 34
Other - LTD $ 4 Long term disability
401(k) loan repay $ 155
Net Pay per Pay Period: $=1:j_68
Week Month Year:
(Fill in Appropriate Column)
Other Income: N/A
Interest -
Individual $ $ 5 $
Joint
Dividends
Pension
Annuity
Social Security
Rents
Royalties
Expense Account
Gifts
Unemployment Comp.
Workmen's Comp.
Total $ $ 5 S
TOTAL MON'T'HLY NET INCOME S2,969
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the attached document was served on the
person below by U.S. Mail on this day:
Sandra L. Meillon, Esquire
Tucker, Arensberg & Swartz
P.O. Box 889
Ilarrisburg, PA 17108-0889
Respectfully submitted,
By: CL LQ-
Emily Long Iloffman, Esquire
Sup. Ct. ID b 66307
105 North Front Street
P.O. Box 11475
Ilarrisburg, PA 17108
(717)233-1112
Dale: 3/29/01
'ITI(XIT ARNNSBIiRG & SWAR'IZ
I I I NIIR I I I IRON I'S I'RIIA
1'.U. BOX 990
I IA RRISIt I' RU. IiINNS) ' I V\N I:\ 17109(IN9o
'117i a'II 11,11
NE A. BOLLINGER,
Plaintiff
v.
D. TIMOTHY BOLLINGER,
Defendant
IN THE COURT OF COMMON PLEA
CUMBERLANn COUNTY, PENNSYLVANIA
NO. 99-5368
CIVIL ACTION -LAW
IN DIVORCE
INVENTORY AND APPRAISEMENT
OF
DORINE A. BOLLINGER
I, DORINE BOLLINGER file the following inventory and
appraisement of all property owned or possessed by either party
at the time this action was commenced and all property
transferred within the preceding three years.
I verify that the statements made in this inventory and
appraisement 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.
NO'l?:e. ?d'lYosnol..iJ
DORINE BOLLINGER Plaintiff
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. If an item has been appraised, a copy of the
appraisal report is attached.
(X) 1. Real property
(X) 2. Motor vehicles
(x) 3. Stocks, bonds, securities and options
( ) 4. Certificates of deposit
( ) 5. Checking accounts, cash
(X) 6. Savings accounts, money market and savings
certificates
( ) 7. Contents of safe deposit boxes
( ) 8. Trusts
(X) 9. Life Insurance policies (indicate face value, cash
surrender value and current beneficiaries)
( ) 10. Annuities
( ) 11. Gifts
( ) 12. Inheritances
( ) 13. Patents, copyrights, inventions, royalties
( ) 14. Personal property outside the home
( ) 15. Businesses (list all owners, including percentage
of ownership, and officer/director positions held
by a party with company)
( ) 16. Employment termination benefits - severance pay,
workman's compensation claim/award
( ) 17. Profit sharing plans
(X) 18. Pension plans (indicate employee contribution and
date plan vests)
(x) 19. Retirement plans, Individual Retirement Accounts
( ) 20. Disability payments
( ) 21. Litigation claims (matured and unmatured)
( ) 22. Military/V.A. 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)
(x) 26. Other
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Plaintiff marks on the list below those items
applicable to the case at bar and itemizes the liabilities on the
following pages.
Secured
(x) 1. Mortgages
( ) 2. Judgments
( ) 3. Liens
(x) 4. Other secured liabilities
Unsecured
(x) 5. Credit card balances
( ) 6. Purchases
(x) 7. Loan payments
( ) 8. Notes payable
( ) 9. Other unsecured liabilities
Continqent or Deferred
10.
11.
12.
13.
14.
15.
Contracts or. Agreements
Promissory notes
Lawsuits
Options
Taxes
Other contingent or deferred liabilities
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114 SATURN 1994.91
Trade-in BODY Model
TYPE No.
M.S.R.P. Weight
Loan
Relall
1994 SATURN4 Cyi: AT-PS-AC•FWD-Continued
6300 Sedan 4D SL2 ........................ ZK5 $11795 2334 5675 7875
5900 Coupe 2D SCI .........................ZF1 11695 2314 5325 7450
0 6850 Coupe 2D SC2 ........................ ZHI 12895 2404 617153' 8475
M 5950
6800 Station Wagon 4D SW1 ............. ZH8
i 11695 2397 5375 7500
Stat
on Wagon 4D SW2 ............. ZK8 12595 2476 6125 8400
E 250 Add Power Sunroof ................................ 250 250
S 50 Add Compact Disc Player ...................... .. 50 50
. 50 Add Power Windows .......................... :.. .. 50 50
T 50 Add Cruise Control ............................... .. 50 50
100 Add Leather Seats .......................
........
..
100
100
50 Add Alumtnum/Alloy Wheels ................... .. 50 50
C 100 Add Anti-TheftlRecovery System .............. .. 100 100
300 Deduct Wlout Automatic Trans ................ .. 300 300
400 Deduct W/out Air Conditioning ................ .. 400' 400
C '1993 SATURN-4 Cyl.-AT-PS-AC-FWD
A Veh. Ident.:1G8(Model)OOOP0000001 Up.
R 3450.
4425 Sedan 4D SL (5 Spd.) ...............ZF5
S
d $9195 2283 3125 '4725
e
an 4D SL1 ........................ ZH5 9995 2283 4000 5825
S 5250 Sedan 4D SL2 ........................ ZK5 11495 2386 4725. 6750
4900 Coupe 2D SCI .........................ZF1 10995 2256 4425 6325
5750 Coupe 2D SC2 ........................ ZHI 12795 2438 5175 7275
4950 Station Wagon 4D SW1 ............. ZH8 10895 2329 4475 6400
5700 Station Wagon 4D SW2 ............. ZK8 12195 2430 5150 7225
200 Add Powet Sunroof ................................ 200 200
250 Deduct W/out Automatic Trans ................. . 250 250
350 :Deduct W/out Air Conditioning ................. . 350 350.
1992 SATURN4 Cyl.-AT-PS-AC-FWD
Veh. Ident.:1G8(Model)OOONZ000001 Up.
2600 Sedan 4D SL (5 Spd.) ...............ZF5 $8195 2343 2350 3775
3550 Sedan 4D SL1 ........................ ZH5 8995 2343 3200 4825
4300 Sedan 4D Touring SL2 .............. ZK5 10395 2438 3875 5675
4775 Coupe 2D SC ......................... ZHI 11875 2403 4300 6200
150 Add Power Sunroof ............................... . 150 150
200 Deduct W/out Automatic Trans ................. . 200 200
300 Deduct W/out Air Conditioning ................. . 300 300
1991 SATURN-4 Cyl.-FWD
Veh. Ident.:1G8(Model)4O()MZ000001 Up.
1975 Sedan 4D SL (5 Spd) ....... * $7995 2312 1800 3075
2950 Sedan 4D SL1 ........ ,,_.......... ZH5 8595 2312 2675 4175
3625 Sedan 4D Touring SL2 .............. ZK5 10295 2408 3275 4900
4050 Coupe 2D SC ......................... ZHI 11775 2375 3650 5400
5;250
- 250 (ded. for w/o auto trans.)
$5,000
DEDUCT FOR RECONDITIONING
1998 OCTOBER 1998 A
MODEL,
A4/A6/A8
Accent
Accord
Altima
Avalon
Beetle
Boxster
C36
C70
C22030/28f
Cabrio
Cabriolet
Camry
Cellda
Charade
Civic
CL
CL500/600 '
CLK
Corolla
Corrado
Cressida
CRX
Del Sol
Memento
E300/320
E420/430/50C
Eclipse
Elantra
ES250/300
Esteem
Excel
Expo
Forester
&1
PONTIAC 1982 87
BODY Model
IrBde•In NOW No. M.S.R.P. Weight Loan Relall
..... oeaan 4u ............................... N69
276 Station w 4D'
D .................... N35
826 Sedan 4D &
h $6527
6694 3203
3380 226
260 1400
1450 D
oug
am ................. R69
GRAND PRIX
8985
3237
800
1626 O
250 Coupe 2D ................................J37
260 Coupe 2D W
$8333
3226
226
1876 M
............................K37
276 Coupe 2D Brougham
P37 8788
9209 3248 226 1426 E
..................
Deduct 50% of Trade4n Value tar DleBei Engine. 3264 260 1476
s
SATURN
MILEAGE CATEGORY : Satum.1
1008 CATUDU_ewn C
sacs oeean 41.1 SL ........................... ZF5
2750 Sedan 4D SL1 ...... ............. ZG51Zt15 $9195
9995 2283
2283
8076 Sedan 4D SL2 ................ ....7.15 5 11495 2386
2900 Coupe 2D SCI ...............
8425 Couppea 2D SC2 ...............
2800
2 ....ZEIMF1
...ZG11MI 10995
12795 2256
2438
".
Wagon 4D SW1....
8325 Station Wa
on 4D SW2 ... ZG8rLH8 10895 2329
g
.... .... LWK8 12195 2430
1992 SATURN-FWD
Veh. Ident.:1G8Model)()()()NZ000001 Up.
2000 Sedan 49 SL
.................
2400 Sedan 4D SL1 ................ ..........ZF5
......... ZH5 $8195
8995 2343
2343
2676 Sedan 4D Touting SL2 ..... ......... ZK5 10395 2438
2976 Coupe 2D SC ................. ......... 7H1 11875 2403
1991 SATURN-FWD
Veh. Ident.:1G8(Model)4ppMZ000001 Up.
1700 Sedan 4 SL
..................
2025 Sedan 4D SL1 ................. ..... ....ZF5
........ 71-15 $7995
8595 2312
2312
2260 Sedan 4D Touting SL2 ...... ........ ZK5 10295 2408
2625 Coupe 2D SC .................. ........ ZH1 11775 2375
-i
i
i
DEDUCT FOR RECONDITIONING
JANUARY TNRU APRIL 2001
2100 3600 C
2475 4076
2776 4425 A
2625 4225 R
3100 4825
2526 4126 S
3000 4700
1800 8260
2176 8676
2425 8975
2700 4325
1550 2800
1825 8275
2025 8526
2275 3825
i
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• _
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l l •
i
TUCKER ARENSBERG & SWARTZ
I I I NORTH FRONT STREET
P.O. BOX 889
IIARRISBURG.PENNSYLVANIA 1718.0889
1 i 17r?:441L
DORINE A. BOLLINGER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-5368 Civil Term
D. TIMOTHY BOLLINGER, CIVIL ACTION -LAW
Defendant IN DIVORCE
PRE-TRIAL. STATEMENT
AND NOW, comes the Plaintiff, Dorine A. Bollinger, by and
through her attorneys, Tucker Arensberg & Swartz, and files the
following Pre-trial Statement.
1. The marital and non-marital assets relative to this
matter have been set forth in the Inventory and Appraisement which was
filed with the court on May 16, 2001. The marital assets of the
parties are valued in excess of $250,000.00. The non-marital property
of the Plaintiff consists solely of contributions to her PSERS pension
after the date of separation. The non-marital property of the
Defendant is unknown to Plaintiff with the exception of the increase
in value of his contributions to his 401(k).
2. Plaintiff expects to call the following persons to
testify as expert witnesses:
Harry Leister Jr., F.S.A. of Conrad M. Siegel, Inc., P.O. Box 5900,
Harrisburg, PA 17110-0900. Mr. Leister will be called to testify in
the event that the parties can not stipulate to the marital portion
and present values of Defendant's 401(k) and Plaintiff's PSERS'
pension.
3. Plaintiff will testify on her behalf and there will be
no other fact witnesses which Plaintiff intends to call to testify on
-1-
her behalf at the Master's Hearing. Plaintiff will testify as to the
assets and liabilities of the marriage, her income and expenses, the
issue of fault as it pertains to her request for alimony and other
relevant issues with regard to equitable distribution and alimony.
4. The following is a list of exhibits which Plaintiff
intends to introduce at the Master's Hearing:
Plaintiff's Income
& Expense Statement
Plaintiff's
Inventory & Appraisement
Tax Returns
Legal Bills
Plaintiff's Exhibit 1
Plaintiff's Exhibit 2
Plaintiff's Exhibit 3
Plaintiff's Exhibit 4
5. Plaintiff has a net monthly income of approximately
$1370.00, which is itemized in the Income and Expense Statement which
was filed with the Court on May 16, 2001. A copy of Plaintiff's most
recent state and federal income tax returns is attached hereto and
incorporated herein.
6. Plaintiff's monthly expenses are approximately
$5,300.00. An itemization of these expenses has been set forth in the
Income & Expense Statement which was filed with the Court on May 16,
2001.
7. Plaintiff contends that the Pension of Defendant has a
value in excess of $160,000.00 as set forth on the Pension Statement
dated March 31, 2000.
S. Plaintiff has incurred Counsel fees in excess of
$3,500.00 in accordance with the fee letter which was signed on
2-
February 12, 1999. A detailed itemization of these services will be
introduced at the hearing.
9. The parties are in dispute over several issues
including but not limited to the date of separation, equitable
distribution of property, alimony, counsel fees and costs, and alimony
pendente lite.
10. The parties have accumulated marital debts in the
amount of approximately $125,000.00, which have been itemized on the
Inventory and Appraisement filed with the Court on May 16, 2001.
11. Given the difference in the parties, income and their
ability to accumulate future income, it is believed that a 60/40
distribution would be appropriate with Plaintiff receiving 60t of the
assets and that Plaintiff should also be awarded alimony and counsel
fees. A more specific proposal will be submitted at the conclusion of
testimony or sooner if the Master so requires.
TUCKER ARENSBERG & SWARTZ
BY:
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Sandra` L. ?,FF
I.D. #3255'1
DATED: ?I?SIa
40514.1
111 North Front Street
P.O. Box 889
Harrisburg, PA 17108-0889
(717) 234-4121
ATTORNEYS FOR PLAINTIFF
-3-
AND NOW, this day of 2001, I, Shaun
M. Kovach, Secretary to Sandra L. Meilton, Esquire, for the firm of
Tucker Arensberg & Swartz, hereby certify that I have this day served
the original and two copies of the within Interrogatories, by mailing
same by first class mail, postage prepaid, addressed as follows:
Emily Long Hoffman, Esquire
P.O. Box 11475
Harrisburg, PA 17108-1475
Shaun M. Kovach
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D. TIMOTHY BOLLINGE
Plaintiff
V.
DORINE A. BOLLINGER,
Defendant
DOM: June 18, 1977
DOS: October 1998
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-5560
CIVIL ACTION-LAW
DIVORCE
PRE-TRIAL STATEMENT
List of Assets: assets and liabilities are set forth in the Inventory and Appraisement.
2. Expert witnesses: Harry Leister - Pension appraiser
Furniture appraiser
Plaintiff reserves the right to call additional experts
3. Witnesses:
Tim Bollinger
Plaintiff reserves the right to call additional witnesses
4. Exhibits
a. Statements reflecting mortgage balances
b. Statement reflecting Plaintiffs payment of marital debts since date of separation and
supporting documentation
c. Statements reflecting the values of assets
Plaintiff reserves the right to provide additional exhibits
5. Plaintiff s Gross Income: Please see income and Expense Statement.
6. Plaintiffs expenses: Please see Income and Expense Statement.
7. Value of Plaintiff s Retirement Benefits: $80,498.00
Value of Defendant's Retirement Benefits is unknown
8. Plaintiff makes no claim for counsel fees.
9. Valuation of property will be provided with date of separation and current value
statements prior to the pre-trial conference.
10. Marital Debts are set forth in the Inventory and Appraisement and documentation will be
provided at the pre-trial conference.
11. Proposed resolution: fifty/fifty division of proceeds of the marital home and fifty/fifty
division of the retirement accounts. Fifty/fifty division of the debts. Plaintiff shall be
credited for payments made on credit accounts and home.
Respectfully submitted,
Date:
ISi t?l
Emily Long Hoffman, Esquire
Sup. Ct. ID # 66307
105 North Front Street
Harrisburg, PA 17108
(717)233-1112
Attorney for Defendant
TUCKER ARENS13ERG & SWARTZ
I I I NOM H FRl1N'I S MITI'
IW.110A %NY.
11ARRISRI1R(LP1NNSN1AANIA I7108118sa
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DORINE A. BOLLINGER,
Plaintiff
V.
D. TIMOTHY BOLLINGER,
Defendant
MAY 18 2200'-0`1110\'
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5368
CIVIL ACTION - LAW
IN DIVORCE
INCOME AND EXPENSE STATEMENT
Attached hereto is the Income and Expense Statement of Plaintiff submitted
pursuant to Pa. R.C.P. No. 1920.31.
"Sandra L. Meilton
Attorney for Plaintiff
INCOME AND EXPENSE STATEMENT OF
DORINE A. BOLLINGER
INCOME
Employer: Camp Hill School District
Address:_ Camp Hill PA
Type of Work:_ Secretary
Payroll Number:
Pay Period (weekly, biweekly, etc.):_ biweekly
Gross Pay per Pay Period:
Itemized Payroll Deductions:
Federal Withholding $-4.6.55
Social Security 51.17
Local Wage Tax 8.25
State Income Tax 23.11
Retirement 51.58
Savings Bonds
Credit Union
Life Insurance
Health Insurance
Other (specify)
Medicare 11.97
Net Pay per Pay Period:
$ 825.30
$ 632.67
.2-
Other Income:
Week Month Year
(Fill in Appropriate Column)
Interest $ $ $
Dividends
Pension
Annuity
Social Security
Rents
Royalties
Expense Account
Gifts
Unemployment Comp.
Workmen's Comp.
Total
TOTAL INCOME
$ 1,370.78
-3-
EXPENSES
Home
Mortgage/rent
Maintenance
Utilities
Electric
Gas
Oil
Telephone
Cell Phone
Water
Trash
Employment
Public Transportation
Lunch
Taxes
Real Estate
Personal
Income
Insurance
Homeowners
Automobile
Life
Accident
Health
Other
Automobile
Payments
Fuel
Repairs
Medical
Doctor
Katie and Donne
Estimate - Dorine Only
Week Month
(Fill in Appropriate Column)
$ $ 991.00 $
100.00/
150.00
54.00
30.00
177.00
115.00
30.00
25.00
10.00
$ $ g
90 .00,
Year
$ $ $
38.00 $450.00
$ $ 25.00 $ 300.00
50.00 800.00
58.00
$
$
$ 325.00 $
150.00
$ 48.003 $ 580.00
-4-
Week Month Year
(Fill in Appropriate Column)
Dentist 85.0 1,000.00
Orthodontist
Hospital
Medicine - ----- ------ ---j-
29.00
Special needs (glasses,
braces, orthopedic 20.00 240.00
devices) (Glasses)
Education
Private School $ $ $
Parochial School
College -27
Religious
Personal
Clothing 565.00'
Food 650.00
Barber/Hairdresser 25.00
Credit Payments 200.00
Credit Card (Kohl's) 30.00
Charge Account
Memberships
Loans
Credit Union $ $ $
City Financial 98.00
Miscellaneous
Household Help $ $ $
Child Care
Papers/books/magazines 3.00 36.00
Entertainment 250.00 3,000.00
Pay N 29.00
Vacation 100.00 1,200.00
Gifts 200.00 2,355
Legal Fees 200.00
Charitable Contributions 87.00
Other Child Support
Alimony Payments
Other
' Dorine and girls
' Julie and Stephanie
-5-
Trips to Clarion and
Bucknell - Pick Up and
Drop off girls (Clarion
requires overnight) $
Week Month
(Fill in Appropriate Column)
$ 50.00 $
TOTAL EXPENSES $ $ 5,309.00 $
Year
600.00
6-
INSURANCE
Company Policy No. Coverage'
H W J
Hospital
Blue Cross
Other
Medical
Blue Shield
Other
Health/Accident
Disability Income
Dental
Other
H = Husband; W = Wife; C = Child
7-
VERIFICATION
I, the undersigned, Dorine Bollinger, do hereby certify that the statements made in
the foregoing document are true and correct to the best of my knowledge, information and
belief. I understand that any false statements made to this verification are subject to the
penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities.
S-?y-?)
Date:
Dorine Bollinger, Plai
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DORINE A. BOLLINGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99 - 5368 CIVIL
D. TIMOTHY BOLLINGER,
Defendant IN DIVORCE
ORDER OF COURT
AND NOW, this day of dim hG?
2001, the economic claims raised in the proceedings having
been resolved in accordance with a property settlement
agreement dated December 19, 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,
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CC: Sandra L. Meilton
Attorney for Plaintiff ?2CC ?uvWLC(?
Emily Long Hoffman n c
Attorney for Defendant l°yo2c/Q/
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DORINE A. BOLLINGER,
Plaintiff
V.
D. TIMOTHY BOLLINGER,
Defendant
IN THE COURT OF COMMON PLEAS _
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-5368
CIVIL ACTION-LAW
DIVORCE
DEFENDANT'S RESPONSE TO PETITION TO ENFORCE
PROPERTY SETTLEMENT AGREEMENT
AND NOW, comes Defendant, D. Timothy Bollinger, by and through his attorneys,
Hoffman Long LLP, and hereby responds to Plaintiffs Petition as follows:
1. Admitted. n -.
2. Admitted. & Q
i
3. Admitted.
4. The Agreement speaks fo
5. Admitted.
6. Denied. The payment has been paid.
DORINE A. BOLLINGER,
Plaintiff
V.
D. TIMOTHY BOLLINGER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-5368
CIVIL ACTION-LAW
DIVORCE
DEFENDANT'S RESPONSE TO PETITION TO ENFORCE
PROPERTY SETTLEMENT AGREEMENT
AND NOW, comes Defendant, D. Timothy Bollinger, by and through his attorneys,
Hoffman Long LLP, and hereby responds to Plaintiffs Petition as follows:
1. Admitted.
2. Admitted.
3. Admitted.
4. The Agreement speaks for itself.
5. Admitted.
6. Denied. The payment has been paid.
1
7. Denied. It is denied that Plaintiffs counsel provided Defendant's counsel with
her support calculations on January 16, 2002.
8. Admitted.
9. The Agreement speaks for itself.
WHEREFORE, Defendant has paid the amount due under the agreement and Plaintiff has
scheduled a support conference in addition Defendant demands proof in the fees to prepare this
matter as the fees are excessive.
Respectfully submitted,
"11t-yl
Emily Long Hoffman
Sup. Ct. I.D. # 66307
P.O. Box 11475
105 N. Front Street
Harrisburg, PA 17108-1475
717-233-1112
Date: 4/2/2002
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the attached document was served on the
person below on this day by First Class U.S. Mail addressed as follows:
Sandra L. Meillon, Esquire
Tucker, Arenberg & Swartz
P.O. Box 889
Harrisburg, PA 17108-0889
Respectfully submitted,
C
By: (?;41A tE?--
Emil y Loi g Hoffman, Esquire
Sup. Ct. ID # 66307
105 North Front Street
P.O. Box 11475
Harrisburg, PA 17108
(717)233-1112
Date: 4/2/2002
'FUCKER ARENSBERG & SWARTZ
I I I INOR'I II INON'r SI'RH 1'
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DORINE A. BOLLINGER, : IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99 - 5368 CIVIL
D. TIMOTHY BOLLINGER, : CIVIL ACTION -LAW
Defendant : IN DIVORCE
RULE
AND NOW, this ? day of ao,? er , 2002, In consideration of
the Petition to Enforce Property Settlement Agreement filed by Plaintiff, a Rule is issued on
Defendant as to why Plaintiffs Petition should not be granted.
RULE returnable Lv days after service on Defendant and/or his counsel.
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BY THE COURT:
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DORINEA. BOLLINGER,
Plaintiff
V.
D. TIMOTHY BOLLINGER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99.5368 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
PETITION TO ENFORCE
PROPERTY SETTLEMENT AGREEMENT
AND NOW, comes Plaintiff, Dorine A. Bollinger, by and through her attorneys,
TUCKER ARENSBERG & SWARTZ and hereby avers the following in support of her petition:
1. Plaintiff and Defendant were married on June 18, 1977 and divorced by Decree
entered on December 28, 2002.
2. Plaintiff and Defendant entered into a Property Settlement Agreement on
December 19, 2001 and said agreement was incorporated, but not merged into the Divorce
Decree.
3. Paragraph 9 of the Agreement states that:
9. CASH PAYMENT:
Husband shall pay to Wife the sum of $12,579.48,
as itemized on the Exhibit "A" which payment shall be made
within thirty (30) days of the signing of this Agreement.
4. The Exhibit "A" to the Property Settlement Agreement is attached hereto and
incorporated herein as Exhibit "A".
5. Paragraph 10 of the Agreement states as follows:
10. CHILD SUPPORT:
Husband shall pay Wife child support for their one
minor daughter in an amount to be calculated under the
Pennsylvania Statewide Support Guidelines. The support
payments shall be calculated and an agreement signed in
this regard within thirty (30) days of the signing of this
Agreement. The effective date of the child support shall be
October 1, 2001. The parties agree to sign an amicable
Order of Support with the Court of Common Pleas of
Cumberland County, Pennsylvania, so that future payments
shall be made in accordance with the Order of Court. The
parties agree that this provision relative to support payments
may be enforced by an action in accordance with the Rules
of Civil Procedure governing actions for support.
6. Despite correspondence and telephone calls to Defendant's counsel from
Plaintiffs counsel requesting the status of the said cash payment, the thirty (30) day time limit
has expired and no payment has been made to Plaintiff from Defendant.
7. On January 16, 2002, Plaintiffs counsel provided Defendant's counsel with her
support calculations to resolve the outstanding issue of support.
8. To date, no response has been received from Defendant's counsel to the
January 16, 2002 letter and Plaintiff will take the steps necessary to have the support matter
scheduled for a support conference with the Cumberland County Domestic Relations Office.
9. Paragraph 17 of the Property Settlement Agreement sets forth Plaintiffs
remedies for Defendant's breach including the payment of legal fees and costs to enforce the
Agreement.
WHEREFORE, Plaintiff requests that this Honorable Court direct Defendant:
(a) To immediately pay to Plaintiff the full cash payment plus interest at the
rate of ten (10%) percent per annum for the period from January 19, 2002 (the expiration of the
thirty days) to the date of payment.
(b) To make payment of $750 to Plaintiffs counsel as legal fees in
connection with his breach of the Agreement.
(c) To cooperate fully with regard to finalizing an appropriate support amount
as agreed to in Paragraph 10 of the Property Settlement Agreement.
Respectfully submitted,
TUCKER ARENSBERG 6 SWARTZ
BY: 1,?Z4ue?,t rte' ?iL
Sandra L. Meilton
I. D. #32551
111 North Front Street
P.O. Box 889
Harrisburg, PA 17108-0889
Date: ATTORNEYS FOR PLAINTIFF
VERIFICATION
I, Dorine A. Bollinger, acknowledge that the facts stated in the within
document are true and correct to the best of my knowledge, information and belief.
I understand that any false statements herein are made subject to the penalties
of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities.
Donne A. Bollinger
DATED: 3 - "1 - oz)
EXHIBIT "A"
Description of Marital Asset Total Value
Pace Resource Federal Credit Union $ 2,609.86
Equity in 1995 Saturn $ 3,506.00
24 foot Catalina boat $ 6,200.00
Husband's Cash Surrender Value in Northwestern
Mutual Life Insurance policy $12,859.09
Wife's Cash Surrender Value in Northwestern
Mutual Life Insurance policy $ 2,665.20
$27,840.15
Distribution
Husband's 45% = $12,528.07
Wife's 55% = $15,312.08
Less Husband's credit for credit
card payment 1,500.00
House proceeds explained below +11,432.60
$15,244.68
Recap
Wife's CSV in NML policy $ 2,665.20
Cash payment to Wife $12,579.48
$15,244.68
Proceeds from sale of the marital residence were $78,652. At settlement, Husband received an
equal share of proceeds less $2,500 or $36,826. Wife received an equal share of proceeds plus
$2,500 or $41,826. Therefore, with the agreed to 55%-45% division of marital assets, Wife
should have received $43,258 and is therefore entitled to an additional $1,432.60.
Retirement benefits, Husband's 401(k) and Wife's PSERS pensions shall be distributed 55% to
Wife and 45% to Husband with Wife's PSERS pension remaining totally in tact. for example:
Assume hypothetically that husband's pension is worth $100,000 and wife's pension Is worth
$50,000. The total marital pensions equal $150,000. If wife is to receive 55% of that value, her
share would be $82,500. To reach this amount, she would retain her pension valued at $50,000
and $32,500 from husband's pension. In determining the marital portion of Husband's 401(k),
Harry Leister shall deduct the date of separation value of the existing loan which on that date was
$13,057.63. In the event the date of separation value of either party's pension/retirement is higher
than the current value, due to market fluctuations, then the lower value shall be used. After
establishing the marital values, the pension and retirement benefits discussed herein shall be divided
fifty-five (55%) percent to Wife and forty-five (45%) percent to Husband.
Rite Aid Corporation stock (estimated at 148 shares) to be divided between the parties 55% to Wife
and 45% to Husband.
Exhibit "A"
CERTIFICATE OF SERVICE
AND NOW, this ' ?hday of 0 ??1 -L. 2002, I, Gloria M. Rine, Legal
Assistant to Sandra L. Meilton, Esquire, for the firm of Tucker Arensberg & Swartz, hereby certify
that I have this day served a copy of the within document, by mailing same by first class mail,
postage prepaid, addressed as follows:
Emily Long Hoffman, Esquire
P.O. Box 11475
Harrisburg, PA 17108-1475
Gloria M. Rine
48009.1
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of P nnryl -nia t'IL @Original Order/Notice
Co./CitY/Dist, of CUMBERLAND 6,,7911-(137S-
Date of Order/Notice 05/01/02 O Amended Order/Notice
6 O Terminate Order/Notice
Court/Case Number (See Addendum for case summary)
EmployerAvithholder's Federal EIN Number
PACE RESOURCES INC
Employer/Withholder's Name
445 W PHILADELPHIA ST
Employer/Withholder's Address
YORK PA 17404-3340
IRE: BOLLINGER, D. TIMOTHY
1 Employee/Obligor's Name (Last, First, MI)
1 194-44-8811
I Employee/Obligor's Social Securily Number
1 2611100804
I Employee/Obligor's Case Identifier
(See Addendum Ior plaintiff names associated with cases on affachmen0
Custodial 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.
$ 1, 635.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Dyes ® no
$ 0.00 per month in medical support
$ o. 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 1, 635.00 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:
$ 377.31 per weekly pay period.
$ 7s4.62 per biweekly pay period (every two weeks).
$ 817. so per semimonthly pay period (twice a month).
$ 1. 635. go 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 10 BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BY THE COURT:
Date of Order: MAY 2 2002 )?- ?/
r7i 3Y
$m ?•ia 4? Form EN-028
Service Type M 5 y? OVEINnnennHll WorkerlD $IATT
1. W r.piOn D.01 1211 I.M1NI
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 Stale 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.
V -Reporting the-Paydate/Date of Withholding: You must report the paydate/date of withholding when sending the-paymentrThr
paydatddateiOwftoldfrq; is-thedateon which amountwas withheld from the-employee's wages. You must comply with the law of the
state of the employee'slobligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4.• Employee/Obligor with Multiple Support Hollings: If there is more than one Order/Notice to Withhold Income for Support
against this empfeyee%obfigor 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: 2312848130
EMPLOYEE'S/OBLIGOR'S NAME: BOLLINGER, D. TIMOTHY
EMPLOYEE'S CASE IDENTIFIER: 2611100804 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. Ifyou 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. Antidiscrimination: You are subject to a fine determined under Stale 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
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
Service Type M
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717) 240.6248 or
by Internet
Page 2 of 2
Dula No 0410 111 S4
fyuuLnn DAr• II/HIM,
Form EN-028
Worker ID $IATT
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: BOLLINGER, D. TIMOTHY
PA S a N mb f 029104375/y/1;ee PACSES Case Number 472103587
Plaintiff Name Plaintiff Name
DORINE A. BOLLINGER DORINE A. BOLLINGER
Docket Attachment Amount Docket Attachment Amount
99-5368 CIVIL$ 1,000.00 00512 8 2001 $ 635.00
Child(ren)'s Name(s): DOB Childften)'s Name(s):
KATIE L. BOLLINGER
?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.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
DOB
10/27/85
?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.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(rer)'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.
Addendum Form EN-028
Service Type M M8 n 0'070-111 s Worker lD $ IATT
t m.cnion D.m.. vn i,rAl
?,
.-?
?.s
V
DEC 2 6 2002 -1&
Dorine A. Bollinger
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
D. Timothy Bollinger NO. 99-5368
Defendant
QUALIFIED DOMESTIC RELATIONS ORDER
1. The parties to this action have entered into a Property Settlement Agreement dated
December 19, 2001. The Court incorporated the Marriage Settlement Agreement into its Decree
of Dissolution of Marriage dated December 28, 2001.
2. This Order creates and recognizes the existence of an Alternate Payee's right to receive
a portion of the Participant's benefits payable under an employer sponsored defined contribution
plan which is intended to be qualified under Internal Revenue Code of 1986 ("Code") §401(a). The
Court intends this order to be a Qualified Domestic Relations Order ("QDRO") within the meaning
of Code §414(p) and §206(d) of the Employee Retirement Income Security Act of 1974 as amended
("ERISA'). The Court enters this QDRO pursuant to its authority under the 23 P.C.S.A. §3502.
3. This QDRO applies to the Pace Resources, Inc. Retirement Savings Plan ("Plan').
Further, this Order shall apply to any successor plan to the Plan or any other plan(s) to which
liability for provision of the Participant's benefits described below is incurred. Any benefits
accrued by the Participant under a predecessor plan of the employer or any other defined
contribution plan sponsored by the Participant's employer, whereby liability for benefits accrued
under such predecessor plan or other defined contribution plan has been transferred to the Plan,
shall also be subject to the terms of this Order. Any changes in Plan Administrator, Plan sponsor,
or name of the Plan shall not affect Alternate Payee's rights as stipulated under this Order.
4 D. Timothy Bollinger ("Participant') is a participant in the Plan. Dorine A. Bollinger,
("Alternate Payee'), the former spouse of the Participant, is the alternate payee for purposes of
this QDRO.
5. The Participant's name, mailing address, Social Security number and date of birth are:
D. Timothy Bollinger
1n South 241h Street- a31(9 Ken Street;
Camp Hill, PA 17011
Social Security #: 194-44-8811
S Date of Birth: November 23, 1955
6. The Alternate Payee's name, mailing address, Social Security number and date of birth
are:
QDRO
Page 2
Dorine A. Bollinger
8117 Scarborough Court
Indianapolis, IN 46256
Social Security #: 184-48.9275
Date of Birth: October 16, 1955
The Alternate Payee shall have the duty to notify the Plan Administrator in writing of
any changes in this mailing address subsequent to the entry of this Order.
7. The portion of the Participant's plan benefits payable to the Alternate Payee under this
QDRO is $46,779 of the Participant's total account balance accumulated under the Plan.
The Alternate Payee's portion of the benefits described above shall be segregated and
separately maintained in account(s) established on her behalf and shall be credited with any
investment income or losses attributable thereto from the date of segregation, until the date of
total distribution to the Alternate Payee.
8. This QDRO does not require the Plan to provide any type or form of benefit the Plan
does not otherwise provide.
9. This QDRO does not require the Plan to provide increased benefits.
10. This QDRO does not require the Plan to pay any benefits which another order
previously determined to be a qualified domestic relations order requires the Plan to pay to
another alternate payee.
11. The Plan shall distribute to the Alternate Payee her benefits (as designated in
Paragraph 7 of this Order), as soon as administratively feasible following the Plan
Administrator's approval of this Order.
12. The distribution shall be a direct rollover to an Individual Retirement Account for the
benefit of Dorine A. Bollinger. The check should be made payable to New England Securities.
13. On and after the date that this order is deemed to be a QDRO, but before the Alternate
Payee receives her distribution under the Plan, the Alternate Payee shall be entitled to all of the
rights and election privileges that are afforded to Plan beneficiaries, including, but not limited to,
the right to name a beneficiary and the right to direct her Plan investments to the extent
permitted under the Plan.
14. All payments made pursuant to this order shall be conditioned on the certification by
the Alternate Payee and the Participant to the Plan Administrator of such information as the
Plan Administrator may reasonably require from such parties.
15. It is the intention of the parties that this QDRO continue to qualify as a QDRO under
Code §414(p), as it may be amended from time to time, and that the Plan Administrator shall
reserve the right to reconfirm the qualified status of the order at the time benefits become payable
hereunder.
Q6RO
Page 3
16. In the event that the Plan inadvertently pays to the Participant any benefits that are
assigned to the Alternate Payee pursuant to the terms of this order, the Participant shall
immediately reimburse the Alternate Payee to the extent that he has received such benefit
payments and shall forthwith pay such amount so received directly to the Alternate Payee within
ten (10) days of receipt.
In the event that the Plan inadvertently pays to the Alternate Payee any benefits that
are assigned to the Participant pursuant to the terms of this order, the Alternate Payee shall
immediately reimburse the Participant to the extent that she has received such benefit payments
and shall forthwith pay such amount so received directly to the Participant within ten (10) day of
receipt.
17. After payment of the amount required by this QDRO, the Alternate Payee shall have no
further claim against the Participant's interest in the Plan.
18. The Alternate Payee assumes sole responsibility for the tax consequences of the
distribution under this QDRO.
19. The Alternate Payee's right to the amount assigned to her under this QDRO shall not
be affected by the Participant's death (whether before or alter benefit payments to the Alternate
Payee have commenced). In the event of the Alternate Payee's death prior to the commencement
of benefit payments to the Alternate Payee pursuant to this QDRO, the Plan shall pay the
remaining benefits under this QDRO as soon as practicable to any beneficiary designated by the
Alternate Payee and recorded with the Plan Administrator under the terms of the Plan. If no
designated beneficiary survives the Alternate Payee, benefits shall be paid to the Alternate
Payee's estate.
20. The Plan shall treat this QDRO in accordance with Code §414(p)(7). While the Plan is
determining whether this order is a qualified domestic relations order, the Plan Administrator
shall separately account for the amounts which would have been payable to the Alternate Payee
while the Plan is determining the qualified status of this QDRO.
21. The Plan Administrator promptly shall notify the Participant and the Alternate Payee
of the receipt of this QDRO and shall notify the Participant and the Alternate Payee of the Plan's
procedures for determining the qualified status of this QDRO. The Plan Administrator shall
determine the qualified status of the QDRO and shall notify the Participant and the Alternate
Payee of the determination within a reasonable period of time after receipt of this QDRO.
22. The Court shall retain jurisdiction with respect to this Order to the extent required to
maintain its qualified status and the original intent of the parties as stipulated herein.
I ..
@nRO
Page 4
CONSENT TO ORDER:
PLAINTIFF/ALTERNATE PAYEE
DEFENDANT/PARTICIPANT
Signature \?J Y
/o- do -Oa
Date
ATTORNEY FOR PLAINTIFF/
ALTERNATE PAYEE
Signature
Date '
r5iignature
/2.?020? Dot.
Date
ATTORNEY FOR DEFENDANT/
PARTICIPANT
Signature
12-
Date
Accepted and ordered this "21, day of e ?cJ 2vo 2-
BY THE COURT
/? ?l(o U? l,?t ttial? 5-ervk,(, m
?. - I "F:y
02CrC26 Ai19:In
Gut; : %IN
i'EiViV• ;'i.'i, ,M4
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsylvania Q Original Order/Notice
Co./City/Dist. of CUMBERLAND Q Amended Order/Notice
Date of Order/Notice 09/17/04 Q Terminate Order/Notice
Tribunal/Case Number (See Addendum for case summary)
RE: BOLLINGER, D. TIMOTHY
Employer/Withholder's Federal EIN Number Employee/Obligor's Name (Last, First, M1)
194-44-8811
Fmployee/Obligor's Social Security Number
RDMM KLEPPER & KARL 2611100804
81 MOS HER ST Employee/Obligor's Case Identifier
BALTIMORE MD 21217-4243 3? X999 S ?f(IrLassociate with cases rm 2!!:chmeno
Custodial 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.
$ 1, 000.00 per month in current support $ o. oo per month in past-due support Arrears 12 weeks or greater? Qyes (R)no
$ 0.00 per month in medical support
$ o. 00 per month for genetic test costs
$ per month in other (specify)
fora total of $ 1, 000.00 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:
$ 230.77 per weekly pay period.
$ 461.54 per biweekly pay period (every two weeks).
$ 5oo. oo per semimonthly pay period (twice a month).
$ 1. ooo. oo per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten 00) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #10 on pg. 2).
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.
BY THE COU T:
Date of Order: SEP 2 0 1004
Service Type M
?oCCe
Form EN-028
Worker ID $IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
Igi hecke? you are required, to pr iOe a opy of this form to your employee. If yo r employe@ orks in a state that is
I event rcm the state that Issued tlrls order, a copy must be provided to your employee even If II a box is not checked.
1, We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned
businesses located on a reservation that choose to withhold in accordance with this notice.
2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
3, Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employee/obligor.
4.'-Reporting- Ine ftdatetoatcpfWithholding, -you-must report thepaydatevdate of withholding when-sending the payment-The-
PaYdate/date ofwkhholdingis-thedate,orrrtwhich amount was-withheld from the employee's wages: 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.
S." Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #10 below)
6. Termination Notification: You must promptly notify the Requesting Agency when the 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: 5205991120
EMPLOYEE'S/OBLIGOR'S NAME: BOLLINGER, D. TIMOTHY
EMPLOYEE'S CASE IDENTIFIER: 2611100804 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employeelobligor's income and other penalties set by Pennsylvania Stale law. Pennsylvania Slate 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. Antidiscrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment,
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
10." Withholding Limits: You may not withhold more than the lesser of. 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.S.C. §1673 Ml; 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.
11. Additional
'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
Submitted By:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact _ WAGE ATTACHMENT UNIT
by telephone at J717) 240-6225 or
by FAX at (717) 240.6248 or
by internet www.childsupportstate.pa.us
Service Type M
Page 2 of 2
nNla N. 09704154
Form EN-028
Worker ID $IATT
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: BOLLINGER, D. TIMOTHY
PACE a N umb r 029104375 PACSES Case Number
Plaintiff Name Plaintiff Name
DORINB A. BOLLINGER
packet Attachment Amount Docket Attachment Amount
99-5368 CIVIL$ 1,000.00 1 0.00
Child(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.
PACKS Case Number
Plaintiff Name
Docket Attachment Amount
$ 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.
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.
?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.
PACKS Case Number
Plaintiff Name
Docke Attachment Amount
! o.06
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
S o.oo
Child(ren)'s Name(s): DOB
?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.
Addendum Form EN-028
Service Type M ID $IATT
on;e No.. a9nwi;a Worker
{ v'
U.?_
r' 1J
N
IZ
LLJ
LL
LAJ
1- Cq 112
s
H C..)
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
Stale Commonwealth of Pennsylvania 0Original Order/Notice
Co./City/Dist. Of CUMBERLAND O Amended Order/Notice
Date of Order/Notice 09/17/04 O Terminate Order/Notice
Tribunal/Case Number (See Addendum for case summary)
RE: BOLLINGER, D. TIMOTHY
Employer/Wnhholder's Federal EIN Number Employee/Obligor's Name (Last, First, MI)
BUCHART-HORN INC
445 W PHILADELPHIA ST
YORK PA 17404-3340
194-44-8811
Employee/Obligor's Social Security Number
2611100804
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, 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. 00 per month in current support
$ o. oo per month in past-due support Arrears 12 weeks or greater? Dyes ® no
$ o, oo per month in medical support
$ o. 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 0.00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ o. o o 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
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #10 on pg. 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676.9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania 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. - - - --
Date of Order: !ZFP 5) 0 20A
BY THE COURT:
Form EN-028
Service Type M oars wo: 097" Worker lD $IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
? ijelrPcked you are required, to protvri(leomerPa of this form to your employee. If your employeg Works in a state tha( is
i Brent rom the state that issu copy must be provieeo to your employee even if the box is not checked.
1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned
businesses located on a reservation that choose to withhold in accordance with this notice.
2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employeelobligor.
F,ayu am %vftnnommg-rs-ime-*ate-omwhich-amourrtwas-whhheld-from-the employees wages: You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
5. • Employee/Obligor with Multiple Support holdings: if there is more than one Order/Notice to Withhold Income for Support against
this employeelobligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #10 below)
6. Termination Nolification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
WITHHOLDER'S ID: 2314983260
EMPLOYEE'S/OBLIGOR'S NAME: BOLLINGER, D. TIMOTHY
EMPLOYEE'S CASE IDENTIFIER: 2611100804 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employeelobligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9. Antidiscrimination: 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.
10." Withholding Limits: You may not withhold more than the lesser of. 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.S.C. §1673 (b)1; 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.
11. Additional Info:
"NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
Submitted By:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
Service Type M
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717) 240-6248 or
by internet www.childsupport.state.pa.us
Page 2 of 2
OMBrao. 0•17M10154
Form EN-028
Worker ID $IATT
Y Lo
U7 }
UJ? Z
1
r N n
LLI
i
?lU U ri:I L'
?'
c
v U
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of P nnayivania
Co./City/Dist.of CUMBERLAND )l1C\C C (?LiC'/375
Date of Order/Notice 08/07/02
Court/Case Number (See Addendum for case summary)
Employer/Withholders Federal [IN Number
PACE RESOURCES INC
EmployerAvithholder's Name
445 W PHILADELPHIA ST
Employer/Withholder's Address
YORK PA 17404-3340
O Original Order/Notice
O Amended Order/Notice
O Terminate Order/Notice
)RE: BOLLINGER, D. TIMOTHY
Employee/obligor's Name (Last, First, MI)
) 194-44-8811
Employee/Obbgar's Social Security Number
2611100804
Employee/Obligor's Case Identifier
(see Addendum for plaintiff names associated with cater on atlarhmen0
Custodial Parent's Name (Last, First, Ml)
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.
$ 1 , coo. Ito per month in current support
$ 0. o0 per month in past-due support Arrears 12 weeks or greater? Qyes ® no
$ 0. oo per month in medical support
$ 0. 00 .per month for genetic test costs
$ per month in other (specify)
for a total of $ 1, 000.00 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:
$ 230.77 per weekly pay period.
$ 461.54 per biweekly pay period (every two weeks).
$ Soo. oo per semimonthly pay period (twice a month).
$ 1.0oo.ooper 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.
BY THE COURT:
AUC C 2002
Date of Order:
,Y(I: %. ,01
Service Type M
?T.
12/31/00
FY(-(
Form EN-028
Worker ID 21205
1
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 employeelobligor.
3.* Ing the Paycla!c6irle of Withholding. oumvstrcportthePM'date/dateofwithhold'
pa 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/Obligorwith Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support
against this employee%b)igorand you a2 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: 2312848130
EMPLOYEE'S/OBLIGOR'S NAME: BOLLINGER, D. TIMOTHY
EMPLOYEE'S CASE IDENTIFIER: 2611100804 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. Antidiscrimination: You are subject to a fine determined under State law for discharging an employeelobligorfrom
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 0 5 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee'slobligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE 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 employeelobligor have any questions,
]DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT
13 N. HANOVER ST by telephone at (717) 246.6225 or
P.O. BOX 320 by FAX at (717) 2466248 or
CARLISLE PA 17013 by Internet
Page 2 of 2 Form EN-028
Service Type M OMB No, 097"154 Worker ID 21205
E.pimim D41r. 12/31100
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FEB-12-02 10:24 FROl1-Cueberland County Domestic Relations 7172407775 T-204 P.002/003 F-821
0p- 31535 No, qq- 536$ SEP 17 202
CUMBERLAND COUNTY DOMESTIC RELATIONS
Date of Application:,0 Request for Support Record Search
Name: F30LL/ j r F A-- h- _ V
Address: ":Hrloe?t Camp W4
Social Security Number. -+ D.O.B.:
Domestic Relations Case Number if Known:
Parry Requesting Information:
(FrintNeme f Finn Name)
('717 93 - 3 " '33d9 Mark ??i Pig m-o Hill /70
C (relephone Number) (Address) _T-?-
17 1 I-a
(Fax Number) ?gnature)
A Twenty Dollar (520.00) Fee is Due per Social Security Number
Make check or money order payable to: DRS/Lien Search
INITIAL REQUEST
Has no Record in Domestic Relations as of
(Date)
Support Arrears as of End of Month Prior to Date of Application: S 5137. 9-7
Monthly Total Support Obligation: S 1000. Dy/mnnA
The Amount shown above is reflected in the Domestic Relations Section Office of
Cumberland County, Pennsylvania. //?? Mcmbee -W-,? to I I 1 00 So
Domestic Relations Case Number: P&Q,,S 0ag1043 75
Signed: QaL w?.
(Lien ordinator) (Data)
BRING-DOWN REQUEST
Support Arrears: $ As Of
(Date)
Signed:
(Lien Coordinator)
(Date)
*** Lien Satisfisfaction Receipt Available Upon Request***
_?
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsylvania
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 03/21/08
Case Number (See Addendum for case summary)
Employer/Withholder's Federal EIN Number
PACE RESOURCES INC
40 S RICHLAND AVE
YORK PA 17404-3425
194-44-8811
Employee/Obligor's Social Security Number
2611100804
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER 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? Dyes ® no
$ 0. 00 per month in current and past-due medical support
$ 0. oo per month for genetic test costs
$ 0. 00 per month in other (specify)
for a total of $ 0.00 per month to be forwarded to payee a ow.
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 . 00 per weekly pay period.
$ o . 0o per biweekly pay period (every two weeks).
$ o. go 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
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 page 2).
If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call
Pennsylvania State Collections and Disbursement Unit (PA 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.
BY THE COURT: /? /,7
Date of Order: OA -) L? 21,5 J. SLEY OLER
DRO: R.J. SHADDAY
Service Type M
OMB No.: 0970-0154
99-5368 CIVIL
O Original Order/Notice
O Amended Order/Notice
O Terminate Order/Notice
RE:BOLLINGER, D. TIMOTHY
Employee/Obligor's Name (Last, First, MI)
JUDGE
Form EN-028 Rev. 1
Worker ID $IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
? Ifghecke?l you are required. to provide a Copy of this form to your m loyee. If your employee works in a state that is
rent trom the state that
di B issued this order, a copy must be provi?edpto your employee even if the box is not checked.
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
employeelobligor.
3.* Reporting the Paydate/Date of Withholding: You must report the paydate/date of withholding when sending the payment. The
paydate/date of withholding is the date on which amount was withheld from the employee's wages. You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the 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.
THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2312848130
EMPLOYEE'S/OBLIGOR'S NAME: BOLLINGER, D. TIMOTHY
EMPLOYEE'S CASE IDENTIFIER: 2611100804 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 employeelobligor'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. Antidiscrimination: You are subject to a fine determined under State law for discharging an employeelobligor 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. For tribal orders, you may not withhold more
than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more
than the amounts allowed under the law of the state that issued the order.
10. Additional Info:
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
11 - Submitted By:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717) 240-6248 or
by internet www.childsupport.state.pa.us
Page 2 of 2
Service Type M
OMB No.: 0970-0154
Form EN-028 Rev. 1
Worker ID $IATT
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: BOLLINGER, D. TIMOTHY
PACSES Case Number 029104375 PACSES Case Number
Plaintiff Name Plaintiff Name
DORINE A. BOLLINGER
Docket Attachment Amount Docket Attachment Amount
99-5368 CIVIL$ 0.00 $ 0.00
Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACKS 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.
XXXX
? 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) ? 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.
Addendum Form EN-028 Rev. 1
Service Type M
OMB No.: 0970-0154 Worker I D $ IATT
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DORINE A. BOLLINGER, IN THE COURT OF COMMON PLEAS OF
Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - DIVORCE
NO. 99-5368 CIVIL TERM
DAVID T. BOLLINGER, IN DIVORCE
Respondent PACSES Case No: 029104375 -ate
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ORDER OF COURT
AND NOW to wit, this 4th day of October 2011, it is hereby Ordered that
the Cumberland County Domestic Relations Section dismiss their interest in the
above captioned Alimony matter pursuant to the terms of the parties' Marital
Settlement Agreement and the account being paid in full.
There is no balance due the Petitioner.
This Order shall become final twenty (20) days after the mailing of the notices of
the entry of the Order to the parties unless either party files a written demand with the
Office of the Prothonotary for a hearing de novo before the Court.
DRO: R.J. Shadday
xc: Petitioner
Respondent
Sandra L. Meilton, Esq.,
Emily Long Hoffman, Esq.
RY TNF r0l IRT-
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT (-101 _ 5?loR Uv1 I
State: Commonwealth of Pennsylvania O Original Order/Notice
Co./City/Dist. o : CUMBERLAND Q Amended Order/Notice
Date of Order/Notice: 10/03/11 O Terminate Order/Notice
Case Number (See Addendum for case summary) O One-Time Lump Sum/Notice
Employer/Withholder's Federal EIN Number
RUMMEL KLEPPER & KAHL
81 MOSHER ST
BALTIMORE MD 21217-4243
RE: BOLLINGER, DAVID T.
Employee/Obligor's Name (Last, First, MI)
194-44-8811
Employee/Obligors Social SecuFf717u-m-Fe-r
2611100804
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER 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.
$ 0.00 per month in current child support
$ 0.00 per month in past-due child support
$ 0.00 per month in current medical support
$ 0.00 per month in past-due medical support
$ 0.00 per month in current spousal support
$ 0.00 per month in past-due spousal support
$ 0.00 per month for genetic test costs
$ 0.00 per month in other (specify)
$ one-time lump sum payment
for a total of $ 0.00 per month to be forwarded to payee below.
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You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 0.00 per weekly pay period. $ 0.00 per semimonthly pay period
(twice a month)
$ 0.00 per biweekly pay period (every two weeks) $ 0.00 per monthly pay period.
REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10)
working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of
withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work
state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of
the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding,
the following information is needed (See #9 on page 2).
Pennsylvania law (23 PA C.S. § 4374(b)) requires remittance by an electronic payment method if an
employer is ordered to withhold income from more than one employee and employs 15 or more persons, or
if an employer has a history of two or more returned checks due to nonsufficient funds. Please call the
Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at
1-877-676-9580 for instructions. PA FIPS CODE 42 000 00
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 /dentifi "R S AL SECURITY NUMBER IN ORDER TO BE
PROCESSED. DO NOT SEND CASH BY WAIL?
BY THE COURT: , L_111_,X? 0(--f S_ Arrears 12 weeks or greater?
J. Wesley Oler,`Jr., Judge ?
/ OMB No.: 0970-0154 Form EN-028
Service Type M ??// Worker ID $IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
f-I If checked you are required to provide a copy of this form to your employee. If your employee works in a state that is
different from the state that issued this order, a copy must be provided to your employee even if the box is not checked.
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.* Reporting the Paydate/Date of Withholding: You must report the paydate/date of withholding when sending the payment. The
paydate/date of withholding is the date on which amount was withheld from the employee's wages. You must comply with the law of
the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement
the withholding order and forward the support payments.
4,* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support
against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you
must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the
greatest extent possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for
you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. 5205991120
THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER: 0 THE EMPLOYEEIOBLIGOR"NO LONGER WORKS FOR: 0
EMPLOYEE'S/OBLIGOR'S NAME: BOLLINGER DAVID T.
EMPLOYEE'S CASE IDENTIFIER: 2611100804 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
LAST KNOWN PHONE NUMBER:
FINAL PAYMENT AMOUNT:
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 (CCPA) (15 U.S.C. 1673 (b)); or 2) the amounts allowed by the State or Tribe of the employee's/obligor's principal place
of employment. Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes,
Social Security taxes, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the
obligor is supporting another family and 60% of the disposable income if the obligor is not supporting another family. However, that
50% limit is increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State,
you may deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section.
Arrears greater than 12 weeks: If the Order Information does not indicate whether the arrears are greater than 12 weeks, then the
employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts
allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser
of the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of
the CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amounts paid for
health care premiums in determining disposable income and applying appropriate withholding limits.
10. Additional info:
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the
state that issued this order with respect to these items.
11. Send Termination Notice and
other correspondence to:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717) 240-6248 or
by internet www.childsupport.state. pa. us
OMB No.: 0970-0154 Form EN-028
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: BOLLINGER, DAVID T.
PACSES Case Number 029104375 PACKS Case Number
Plaintiff Name Plaintiff Name
DORINE A. BOLLINGER
Docket Attachment Amount Docket Attachment Amount
99-5368 CIVIL $ 0.00 $ 0.00
Child(ren)'s Name(s): DOB Child(ren)'s Name(s):
PACKS Case Number
Plaintiff Name
Do kS a Attachment Amount
$ 0.00
Child(ren)'s Name(s):
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
DOB
DOB
Addendum Form EN-028
Service Type M OMB No.: 0970-0154 Worker ID $IATT
LIEN SATISFACTION
Name: D. Timothy Bollinger
Member Number: M#2611100804
Judgment Lien Satisfied as of: 10/4/11
Amount Paid: $ Closed
Signed: ))). ?
?571 (Lien Coordinator)
Pacses# 029104375
No. 99-5368 Civil
DR# 31585
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