Loading...
HomeMy WebLinkAbout99-06904 Alz ;t? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF k_;? dry PENNA. Lynn K Chambers Plaintiff AND NOW, l Z6 a r 2001 T IS ORDERED AND Michael E. Chambers Defendant N 0. 99-6904 DECREE IN DIVORCE DECREED THAT AND VERSUS Lynn K. Chambers Michael E. Chambers ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE. BY THE COURT: ATT 'T: J PROTHONOTARY y1211-01 cl?e?p? -Z MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT, made this ` "'t daY of 2001, byand between MICHAEL E. CHAMBERS, of Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred to as "Husband," and LYNN K.CHAMBERS, of Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred to as "Wife." WITNESSET11 : WHEREAS, Husband and Wife were lawfully married in June 4, 1994; and WHEREAS, differences have arisen between Husband and Wife in consequence of which they intend to live separate and apart of cacti other; and WHEREAS, Husband and Wife have made a fill disclosure of their assets to each other; and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations with respect to each other, including the disposition and distribution of property rights and interests between them. NOW, THEREFORE, in consideration of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the Parties hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: ADVICE OF COUNSEL. The provisions of this Agreement and their legal effect have been fully explained to the Parties by their respective counsel, Gerald S. Robinson, Esquire, for Husband, and Susan K. Candiello, Esquire for Wife. 'File Parties acknowledge that they have received independent legal advice from counsel of their selection and that they fully understand the facts and have been informed as to their legal rights and obligations and they acknowledge and accept that this Agreement is, in the circumstances, fair and equitable and that it is being entered into freely and voluntarily, after having received such advice and with such knowledge and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. 2. SEPARATION. It shall be lawful for each Party at all times hereafter to continue to live separate and apart from the other Party at such places as he or she may from time to time choose or deem tit. The foregoing provisions shall not be taken as an admission on the part of either Party of the lawfulness or unlawfulness of the causes leading to their living apart. IL i 3. AGREEMENT TO BE INCORPORA"rED IN DIVORCE DECREE. The Parties agree that the terms of this Agreement shall be incorporated into any Divorce Decree, which may be entered with respect to them at the request of either Party. The Parties agree that the Court of Common Pleas of Dauphin County, Pennsylvania, shall retain continuingjurisdiction over the Parties and the Agreement for the purposes of enforcement of any of the provisions thereof. The Parties agree that unless otherwise specifically provided herein, if a Decree is entered divorcing the Parties, although this Agreement shall be incorporated into suit[ Decree, this Agreement shall not merge with, but shall continue in fill force and effect after such time as a Final Decree in Divorce may be entered with respect to the Parties and may be enforced in an action independent of the Divorce Decree. The Parties agree and it is the intent of each of them that even though this Agreement may be enforced either under the provisions of the Pennsylvania Divorce Code or in an action independent of the Divorce Decree in accordance with Section 3502 of the Pennsylvania Divorce Code, the provisions of this Agreement regarding the disposition of existing property rights and interests between the Parties, alimony, alimony pendente lite, counsel fees and expenses shall not be subject to modification by any Court. 4. SUBSEQUENT DIVORCE. The Parties hereby acknowledge and express their agreement that the marriage is irretrievably broken, and the Parties agree to cooperate in any necessary way to obtain a mutual consent, no-fault divorce, pursuant to Section 3301(c) of the Pennsylvania Divorce Code. 5. INTERFERENCE. Each Party shall be free from interference, authority, and contact by the other, as filly 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 or attempt to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 6. WIFE'S DEBTS. Wife represents and warrants to Husband that she will not contract or incur any debt or liability for which Husband or his estate might be responsible and she shall indemnify and save harmless Husband from any and all claims or demands made against him by reason of debts or obligations incurred by her. HUSBAND'S DEBTS. Husband represents and warrants to Wife that he will not contract or incur any debts or liability for which Wife or her estate might be responsible, and he shall indemnify and save harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. S. MUTUAL RELEASE. Subject to the provisions of this Agreement, each Party has released and discharged, and by this Agreement, does for himself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all causes of action, claims, rights, or demands, whatsoever in law or equity, which either of the Parties had or now has against the other, except for any and all causes of action for divorce and except for any and all causes of action for breach of any provisions of this Agreement. 9. DISCLOSURE OF PROPERTY. Husband and Wife acknowledge and agree that they have made a till and complete disclosure to the other of all inforniation pertaining to the Parties' separate and marital property owned, possessed and/or controlled by the other at the time of the separation of the Parties and, further, that the Husband and Wife voluntarily and intelligently agree to waive any rights which they may have to receive an Inventory and Appraisement of all property owned or possessed by them, eitherjointly or individually, at the time of the delivery of this Agreement or of the commencement of any action of divorce. r- 10. EQUITABLE DISTRIBUTION. 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 that have been taken into consideration by the Parties. a. REAL PROPERTY. Husband and Wife agree to list the marital home for sale with a realtor at $120,000.00. The parties agree that the minimal acceptable price is $110,000.00. The proceeds from the sale of the real estate shall be divided equally between the parties, subject to Frank Chamber's claim for $20,000.00, which is being disputed by Wife. The proceeds from the sale are to be held in escrow pending the determination of Frank Chamber's claim. The parties agree to aid a real estate agent in any way possible to list the property for sale as soon as possible. b. PERSONAL PROPERTY. The parties have divided between themselves, to their mutual satisfaction, all remaining items of tangible, personal property previously used by them in the marital home. Neither Party shall make any claim to any such item of tangible personal property; whetlier said items are marital property or said items are separate personal property of either Party. C. CHECKING AND SAVINGS ACCOUNTS. With regard to checking and savings accounts, the Parties agree to close their joint accounts and divide the balance equally between them. d. MARITAL DEBTS. The Parties ack owlcdge that they havcecj dt during the marriage. Flusband agrees to pay Sto Wife whi h co st' es his reimbursement of childcare expenses, healthcare expenses, and pre-marital debt the parties incurred prior to the execution of this agreement, while Wife agrees to pay the remainder of the debts. Husband will pay one third (1/3) of his agreed portion at the signing of the agreement, another one third (113) ninety (90) days after the signing of the agreement, and the remaining one third (1/3) one hundred eighty (180) days after the signing of the agreement. The Domestic Relations arrcarage shall he paid consistent with the Domestic Relations Order with payment in full upon the sale of the marital residence. Husband agrees to assume the liability for half of the debt to Social Security ?Ariinistrati ?5 T?c:???sO r ? -7a? ?u?cv? t-?v?La? ??"C/ C. Both Parties hereby accept the provisions of this Agreement with respect to 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 the equitable distribution of their property by any Court of competent jurisdiction pursuant to Section 3502 of the Divorce Code or any other laws. Husband and Wife voluntarily and intelligently waive and relinquish any rights to seek a Court-Ordered determination and distribution of marital property, but nothing herein shall constitute a waiver by either Party of any rights to seek their relief of any Court for the purpose of enforcing the provisions of this Agreement. IL CHILD CUSTODY/VISITATION. The Parties shall have shared legal custody of the Parties' minor children, Benjamin Chambers, born August 12, 1992, and Andrew Chambers, born December 19, 1994. Wife shall have primary physical custody of the children subject to Husband's right to partial custody as follows: a. Beginning Friday, January 26, 2001, Husband shall have custody of the minor children on alternate weekends from Friday after work (6:00 PM) until Sunday evening at 7:00 PNt; b. Husband shall have custody of the minor children on Wednesdays from 5:30 PM to 7:00 PM; C. During the summer, the parties shall have custody of the minor children on alternate weeks from Sunday evening at 7:00 PM until the following Sunday at 7:00 PM; d. In even numbered years, Wife shall have custody of the minor children on the following holidays from 9:00 AM until 7:00 PM: New Years Day, Memorial Day, Labor Day, and Christmas Eve at noon until Christmas Day at noon. Husband shall have custody of the minor children on the following holidays from 9:00 AM until 7:00 PM: Easter, Independence Day,'rhanksgiving, and Christmas Day at noon until December 26 at noon. In odd numbered years, Husband shall have custody of the minor children on the following holidays tom 9:00 AM until 7:00 PM: New Years Day, Memorial Day, Labor Day, and Christmas Eve at noon until Christmas Day at noon. Wife shall have custody of the minor children on the following holidays from 9:00 AM until 7:00 PM: Easter, Independence Day, Thanksgiving, and Christmas Day at noon until December 26 at noon. C. The children shall spend Father's Day with Husband and Mother's Day with Wife; t. The parties agree that if either parent plans a trip with the minor children which would take the children out of a one hundred (100) mile radius of the parent's residence and would require an overnight stay, the traveling party will notify the non-traveling party. The traveling parent will provide the location of the trip and a telephone number where the children can be reached; g. The parties agree that Wife shall provide Husband with the Employer Identification Number or Social Security Number of all child care providers; h. The parties shall share in the transportation of the minor children for the periods of partial custody; t. In the event there is a conflict between the weekend and holiday schedule, the holiday schedule shall take precedence and be the binding schedule, Husband and Wife, by mutual agreement, may vary from this schedule at any time. Husband and Wife agree that each will notify the other of all medical care the children receive while in that parent's care. Each parent will notify the other immediately of medical emergencies that arise while the children are in that parent's care; k. The parties realize that their children's well being is paramount to any differences they might have between themselves. Theretirre, neither party shall do anything which may estrange the children from the other parent, or injure the opinions of the children as to the other parent, or which may hamper the Iree and natural development of the children's love or respect for the other parent; and opJhimsse for L'hG tcnefiC of 1. The parties agree that Husband will provide life msurancer each oft children in the amount of $25,000.00 per child. Aller a period of two years, Husband shall increase the insurance policies to $50,000.00 per child. Husband shall continue the coverage until the children reach the age of eighteen (18) years and the children shall be the beneficiary on said life insurance policies with Wil'c 1 v/ beingtrustee. Wife may request January 1 of each year following the ?/ Y? scut' of this Agreement, proof of the continuation of. the r/r}r coverage for each of the children. 1 1,s 7N UPTCY. It is hereby understood and agreed by and between the parties that their obligation pursuant to this agreement shall not he afli clcd by any bankruptcy proceeding and shall not be deemed to constitute or be a dischargeable debt ol'a bankruptcy. 10 13. ALIMONY ALIMONY PENDENTE LITE COUNSEL FEES AND EXPENSES. The parties accept the provisions of this Agreement in lieu of and as full and final settlement and satisfaction of all claims and demands that they may now or hereafter have against the other for alimony, alimony pendente lite, counsel fees or expenses, or for any other provision for support and maintenance before, during or after the commencement of any proceedings for the divorce or annulment between the Parties. 14. WAIVER OF CLAIMS AGAINST ESTATE. Except as herein otherwise provided, each Party may dispose of his or her property in any way, and cacti Party hereby waives and relinquishes any and all rights he or she may now or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including, without limitation, dower, courtesy, statutory allowance, widows allowance, right to take property under equitable distribution, right to take in intestacy, right to take against the will of the other's estate, and who 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. I>. BREACH. If either Party breaches any provision of this Agreement, the other Party shall have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as may be advisable to him or her. The Party breaching this Contract should be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement. l? ii 16. 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. 17. MODIFICATION AND WAIVER. 'rile modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same fonnality as this Agreement. The failure ofcither 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. 13. DESCRIPTIVE HEADINGS. 'rile descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the Parties. 19. INDEPENDENT SEPARATE COVENANT. It is specifically understood and agreed by and between the Parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 20. APPLICABLE LAW. This Agrcenunt shall be construed under the laws of the Conmionwealth of Pennsylvania. 21. VOLUNTARY EXECUTION. Husband and Wife acknowledge and represent that the provisions of this Agreement are fully understood by both Parties and each Party acknowledges that this Agreement is in all respects fair and equitable, that it is 12 being entered into voluntarily and knowingly, and that it is not the result of any duress, undue influence, Collusion or improper or illegal agreement or agreements. IN WITNESS WHEREOF, the Parties have hereunto set their hands and seals the day and year first above written. WITNESS: 13 I? LYNN K. CHAMBERS, Plaintiff MICHAEL E. CHAMBERS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6904 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the Court for entry or a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of Complaint: Service upon the Defendant via Certified Mail, Return Receipt Requested, Restricted Delivery, on or about November 16, 1999. (Please see attached Affidavit of Service.) 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code by: Plaintiff: April 2, 2001 Defendant: April 10, 2001 4. (a) Related claims pending: None (b) Claims withdrawn: None (c) Claims settled by agreement of the parties: All claims (d) Please see the Marriage Settlement Agreement, which was executed by the Plaintiff on March 19, 2001 and by the Defendant on March 28, 2001, which is to be incorporated but not merged into the Divorce Decree. 5. 1 certify that the Waiver of Notice of Intention to Request Entry of a Divorce Decree Under Section 3301(c) of Divorce Code as required by Rule 1920.42(c)(1) was executed on April 2, 2001 by the Plaintilrand April 10, 2001 by the Defendant. 6. 1 further certify that all other documents required by Rule 1920.42 have been previously tiled with this Court. Respectfully submitted, LAW FIRM OF SUSAN KAY CANDIELLO, P.C. Dated: April 4, 2001 Susan Kay Can¢ ell , Esquire Counsel for Ph it! PA I.D. # 64998 5021 East Trindle Road Suite 100 Mechanicsburg PA 17050 (717) 796-1930 LYNN K. CHAMBERS, Plaintiff, VS. MICHAEL E. CHAMBERS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6904 Civil Term : CIVIL ACTION- LAW : IN DIVORCE. AFFIDAVIT OF SERVICE 1, GERALD S. ROBINSON, Esquire, certify, for purposes of finalizing the divorce in the above case, that I am an attorney licensed to practice law in the Commonwealth of Pennsylvania, and that my client, Defendant, MICHAEL. E. CHAMBERS, was served with a Divorce Complaint on or about -i wmlk I In , 1999. & GERALDO Dated: April q .2001 Gefald S. Robinson, Esquire Counsel for Defendant PA I.D. if Ylt?n)? 4407 North Front Street Harrisburg PA 17110 (717) 232-8525 LYNN K. CHAMBERS, Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN'T'Y, PENNSYLVANIA CIVIL ACTION - LAW NO. 94- (o9G4/ CIVIL TERM MICHAEL E. CHAMBERS, 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 foregoing pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree in divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House Carlisle, Pennsylvania 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYE'R'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, Pa 17013 Telephone: (717) 249-3166 ii li I LYNN K. CHAMBERS, Plaintiff vs. MICHAEL E. CHAMBERS, Defendant IN THE COURT' OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. ') 6. e, ei0',l CIVIL TERM IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. LYNN K. CHAMBERS, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 • G9o'l CIVIL TERM MICHAEL E. CHAMBERS, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, LYNN K. CHAMBERS, by her r it A ;a Y? attorney, Samuel L. Andes, and makes the following Complaint in Divorce: ' 1. The Plaintiff is LYNN K. CHAMBERS, an adult individual who currently resides at 223 South York Street in Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is MICHAEL E. CHAMBERS, an adult individual who currently resides at 223 South York Street in Mechanicsburg, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona ride residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 4 June 1994 in Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. This marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I - IRRETREIVABLE BREAKDOWN 8. The Plaintiff requests this Cowl to enter a Decree of Divorce. WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to the Divorce Code of Pennsylvania. I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). DATE: A10y /D, i? 9? LYNN K. CHAMBERS =- &L-&') Samuel L. And s Attorney for Plaintiff Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 LYNN K. CHAMBERS, Plaintiff 1 I ) vs. I I MICHAEL E. CHAMBERS, ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-6904 CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVICE AND ENTRY OF APPEARANCE I hereby enter my appearance for the Defendant, Michael E. Chambers, in the above-captioned action. I acknowledge receipt of a true and correct copy of the Complaint in Divorce filed in the above action on behalf of the Defendant on 11 ZO 1999. i Geydld S. Robinson, Esquire f_ C,.. o. CV ) -? t{J ?itl 1. :T u m i ? U LYNN K. CHAMBERS, Plaintiff, VS. MICHAEL E. CHAMBERS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : N0.99-6904 Civil Term : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 16, 1999. 2. The marriage between the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. 1 consent to the entry of a final Decree in Divorce, after the service of notice of intention to request entry of the decree. 4. 1 understand that if a claim for alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or expenses has not been filed with the Court before the entry of a final Decree in Divorce, the right to claim any of them will be lost. 5. 1 have been advised of the availability of marriage counseling, and understand that I may request that the Court require that my spouse and I participate in counseling. 1 further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and 1 participate in counseling prior to a divorce decree being handed down by the Court. statements herein are made subject to the penalties of 18 Pa. C. Section 4904, relating to unsworn falsification to authorities. ?? / 9 1 verify that the Statements in this Affidavit are true and correct. 1 understand that false A "o ' DA? o ,, LYNN K. CHAMBERS, Plaintiff, VS. MICHAEL E. CHAMBERS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6904 Civil Term : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE. OF INTENTION TO REOUFST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF DIVORCE. CODE. 1. 1 consent to the entry of a final decree of divorce without notice. 2. 1 understand that I may lose rights concerning, alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. 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 P.S. Section 4904 relating to unsworn falsification to authorities. / . DA DA E LY N K. rll LYNN A. CHAMBERS, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. N0. 99-6904 Civil Tenn MICHAEL E. CIIANIBERS, Defendant. CIVIL ACTION- LAW IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under the Divorce code was tiled on November 16, 1999, on the grounds that the marriage of the parties is irretrievably broken. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of tiling the Complaint. 3. 1 consent to the entry of a final decree of divorce. 4. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if 1 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 13 Pa.C.S. 4904 relating to unswom falsification to authorities. Date'.fQtu?w? LYNN A. CHAMBERS, Plaintiff, V. MICHAEL E. CHAMBERS, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6904 Civil Term CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER & 3301 (c) OF TFIE DIVORCE CODE I consent to the entry ofa final decree ofdivorce without notice. 2. 1 understand that 1 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 1 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 tiled with the prothonotary. I verity that the statements made in this affidavit are true and correct. I understand that false statements herein arc made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date?,y0"Jd L tiacl E. Chambers, Defendant t f t e <i r? 1.1 v f: - f ° r? y? Ml t , pK d 1yy ? x 5?- 4+ r/? 1? i; /LG I ?t t t ix? ;a v r •'? /?/rf r t r rt .?,. r1 ?'S: t ? 'f? ? L it S t J y } f ` // l? ' • get ` rt vlV ?? ?i?l?!.W v s n < y ? ? t P 4j I ' < J?o ( t P.02/02 FEB 22 2000 0925 FR PRU SEC Hr1RRI5t3URG ?I,? 975 0426 10 97611435 Unknown From: Gerald S. Robinson [SMTP:grobinson@robinson-geroldo.com] Sent: Thursday, February 03, 2000 6:57 I'M To: 'Mike Chambers' Cc: Crystal Nauman Subject: RE: Deer Mike: I conferred w/ttcr Qtly and he stipulated that the insura s ck marital property and we y en we divide up the marts as a distribution already made to tier. We are preparing the petition for exclusive possession of the mantal residence -Odginal Message From: Mike onday, January 31, 200010:54 PM To: arobinson(8trobinson-nrra do.com Subject: Jerry, Please contact me as soon as possible or have someone from your office contact me, regarding the current situation involving the vehicle, Lynn return home tonight demanding I stop at the insurance company to sign the check, $4600, as she has purchased a car tonight. It is her demand that I relinquish the proceeds to her, in order to purchase, a $6600 car, in her name, which she claims to have arranged financing, and insurance in her name. My response was that I would not do anything until I had the opportunity to speak to you. I pould also like to know how soon we will be proceeding, with the actions we last spoke of. ! can be reached ® work @ 717-597-0500, or my cell phone 714.497.13835 Mike r Property Room lien: Ownership Value Note I I 3 4 Tuesday, April 13, 2000 Misc Kitchen Ulonsl Mikes $0.00 Knives-kitchen, 2. "Gerber" stook Knives from set of 4, enamel coffee pot. "Hershoy's" Cow Creamer, "White House" Vinegar Jug Table & 4 Chairs Joint $0.00 BonTon Chairs Joint $0.00 set of 4 chairs, refurbished, clothing Mikes $0.00 Clothing place in dress given to her by her mother, incl. Sock, jeans, sweats, tee shins, also my grandmother silverware, and school papers and crafts from the boys Jackets Mikes $0.00 Red LL Bean jacket and wind pants, and Teal jacket Christmas present from her mother to me) Air Conditioner Joint 50.00 Lowes purchase, last year TV/Stereo Cabinet Joint 50.00 From Lowes Children's toys Joint $0.00 Games,Puzzels,toys. Printer Mikes $0.00 Christmas present from my lather to me. Computer $0.00 Clone I built, contains network card from work, card for scanner that was left required to use scanner), zip drive. Coffee Table Joint $0.00 Given to us by her mother when it was damaged by movers and was not repaired to her liking Video Tapes Joint 50.00 50+ mostly kids tapes Curtains Joint $0.00 Recently replaced, brackets tom from wall Chair and Hassock Joint $0.00 Purchased from Penney's End Tables(2) Joint $0.00 Purchased from Spiegel Sofa Lynns $0.00 Lynn's sofa, mine was given away to make room for hers Camcorder Joint $0.00 Washer Joint 50.00 Given by her mother when washer motor burnt out Dryer Joint $0.00 Purchased on Lowes charge u-.aZ ?s Page I eft Ronln Iteut ownership Value Note Towels, Bedding $0.00 left 1 towel, and no bedding except 2 comforters use by dog for bedding 5 G 7 3 All medical records $0.00 All financial records $0.00 all photos and alleu $0.00 All furniture 50.00 All her grandmother's except malressaoint), and box springs left behind Clothing and posse $0.00 All, except for trash $0.00 Given by her mother, Lynn painted Dresser for Ben Mattress Joint $0.00 Left bed frame I have built) Air Conditioner Joint $0.00 Purchased with Andrews SSI money Bed and Mattress Joint Jar of Coins Mikes dressers Lynns Curtains Clothing and posse Joint Bed & Mattress Joint Bookcase Lawnmower Outdoor Furniture $0.00 50.00 from Brent's birth year $0.00 $0.00 50.00 $0.00 $0.00 purchase from her psycho friend 50.00 Lowes purchase $0.00 Table, chairs, etc. Teesdrq, April 13, 2000 i,age 2 of 2 Chambers vs. Chambers HOUSEHOLD ITEMS TAKEN BY LYNN Ad/OR LEFT FOR MIKE LIVING ROOM ITEMS LYNN TOOK-- --Sofa-brown suede. Bought by Lynn prior to marriage in 1990. --Entertainment center-bought in 1998, put on Lynn's Lowe's charge. --Cream colored stripe club chair and ottoman---Christmas gift to Lynn and Mike from my mother. --2 end tables-bought by Lynn during marriage Spiegel charge Charged on Lynn's --2 green lamps/white shades- bought prior to marriage at yard sale, 1992 --Curtains, 3 windows - bought during marriage, on Lynn's charge --Cream colored coffee table - given to us during marriage, from my parents, used. --Small taupe suede chair -used, given to Lynn by mother in 1998 --Stereo system - bought before marriage, belongs to Lynn --Computer- desktop, with printer --3/4 of kids toys and games j i Z z LIVING ROOM ITEMS LEFT AT HOUSE --VCR- bought during marriage 1998, at Lowe's, bought on Lynn's charge. (Left with Mike) Oak end table - Mikes, before marriage, (left with Mike) --Small table, wrought iron legs - bought during marriage, at auction (left with Mike) --Computer scanner --Software programs --Mike's books --Wicker magazine rack - Mike's before marriage, left with Mike --Toy, games puzzles- belonging to children. I left enough behind for kid's use during visits. Wooden rocking chair - Mike's before marriage, left with Mike. Black metal IKEA TV cart - Lynn's before marriage, (left behind) Color TV set - given to Lynn by parents (left with Mike) Dining room ITEMS LYNN TOOK --Window air conditioner unit - bought on Lynn's Lowe's charge 3 --White wicker rocker - Given to Lynn during marriage, from grandmother's house --Wooden blanket chest - Lynn's before marriage, given to her from grandmother --4 white painted dining room chairs bought at same time as table, from co-worker. (Lynn took) --Treadmill - given to Lynn during marriage, used, from neighbor --Oak antique dresser - Lynn's before marriage, belonged to Great Aunt ITEMS LEFT IN HOUSE Lace curtains - bought during marriage. Dining room table - bought by Lynn during marriage from co-worker (left with Mike) Utility closet ITEMS TAKEN BY LYNN --Washer - given to Lynn to borrow during marriage. Belongs to her parents --Dryer - Bought last year, during marriage, on Lynn's Lowe's credit ca rd --Hoover upright vacuum - Given to us during marriage, used, from Lynn's parents --Mini canister vacuum- bought last year by Lynn at yard sale. --Sears carpet shampooer - bought during marriage, on Lynn's Sears charge. Iron - bought by Lynn prior to marriage LEFT WITH MIKE a --REGINA Housekeeper Upright vacuum n K itch Items Taken by Lynn --Kitchen table and four chairs - bought during marriage, on Lynn's charge card at Bon Ton --Everyday eating plates, cups, saucers, white, and black rim, Lynn's before marriage, college graduation gift. --Phaltzgraff flatware set - given to Lynn for Xmas present, 1998. --Antique bottle collection, basket collection, wooden wines rack, and various nic-nacs. Bought before marriage, or bought at yard sales for under $1.00 --Black microwave oven - Lynn's before marriage, college graduation present --Kitchen gadgets - took half, left half with Mike --Cake decorator set Lynn's before marriage KITCHEN ITEMS LEFT WITH MIKE Wooden IKEA table, 2 chairs- Lynn's before marriage, given to her by roommate, left with Mike Oak bookcase - Mikes' prior to marriage (left behind) Oriental serving wear" rice pattern", blue and white - Mike's before marriage, (left behind) Smith Bros. China set, strawberry pattern Mike's before marriage, (left behind) Toaster - bought during marriage - left behind Refrigerator - bought during marriage, left behind r- 5 All pots and pans -Belong to both Lynn and Mike, prior and during marriage, left all with Mike Lynn's bedroom ITEMS LYNN TOOK --Maple bedroom suite- bed frame, 2 mirrors, 2 chests, vanity and stool, bedside table -Lynn's before marriage --Mattress- bought on Lynn's charge during marriage from BON TON --Lamps bought on clearance during marriage --Color television set-Lynn's before marriage --Lynn's clothes, shoes, jewelry, personal effects ITEMS LEFT FOR MIKE --Window Air conditioner --Box spring -Mikes before marriage, (left behind) --Mike's clothes and shoes, personal effects Kid's rooms --Beds, mattresses, furniture toys linens, toys etc-all taken for children, except for Ben's frame. --Window Air Conditioner for Ben's room --Andrew's air purifier --All kids' bed linens --All kids personal items r, --All kids bedroom toys and books GARAGE Items taken by Lynn --Bianchi 15 speed mountain bike-belong to Lynn before marriage --MTD lawnmower-bought by Lynn, 1999, damaged for $70.00 --Toro gas blower-bought by Lynn, damaged for $20.00 --Plastic patio furniture-bought on clearance from Lowe's by Lynn on her charge --Kids bikes, sleds, pool toys etc. Items left for Mike- --All tools, power tools, canoe, misc. patio furniture, etc. OF SPECIAL NOTE: I AM BEING ACCUSED OF STEALING SWEATPANTS AND MIKE"S GRANDMOTHER'S SILVER. TO THE BEST OF MY KNOWLEDGE, I DO NOT HAVE EITHER, ENLESS THEY WERE PACKED BY ACCIDENT BY THE MOVERS. I WILL BE GLAD TO RETURN THOSE ITEMS IF FOUND. ,..,•. Chambers vs. Chambers HOUSEHOLD ITEMS TAKEN BY LYNN And OR 2000 FOR MIKE April 12, LIVING ROOM ITEMS LYNN TOOK-- --Sofa-brown suede. Bought by Lynn prior to marriage in 1990. --Entertainment center-bought in 1998, put on Lynn's Lowe's charge. --Cream colored stripe club chair and ottoman---Christmas gift to Lynn and Mike from my mother. --2 end tables-bought by Lynn during marriage. Charged on Lynn's Spiegel charge --2 green lamps/white shades- bought prior to marriage at yard sale, 1992 --Curtains, 3 windows - bought during marriage, on Lynn's charge --Cream colored coffee table - given to us during marriage, from my parents, used. --Small taupe suede chair -used, given to Lynn by mother in 1998 --Stereo system - bought before marriage, belongs to Lynn --Computer- desktop, with printer --3/4 of kids toys and games 1) LIVING ROOM ITEMS LEFT AT HOUSE --VCR- bought during marriage 1998, at Lowe's, bought on Lynn's charge. (Left with Mike) Oak end table - Mikes, before marriage, (left with Mike) --Small table, wrought iron legs - bought during marriage, at auction (left with Mike) --Computer scanner --Software programs --Mike's books --Wicker magazine rack - Mike's before marriage, left with Mike --Toy, games puzzles- belonging to children. I left enough behind for kid's use during visits. Wooden rocking chair - Mike's before marriage, left with Mike. Black metal IKEA TV cart - Lynn's before marriage, (left behind) Color TV set - given to Lynn by parents (left with Mike) Dining room ITEMS LYNN TOOK --Window air conditioner unit - bought on Lynn's Lowe's charge 3 --White wicker rocker - Given to Lynn during marriage, from grandmother's house --Wooden blanket chest - Lynn's before marriage, given to her from grandmother --4 white painted dining room chairs bought at same time as table, from co-worker. (Lynn took) --Treadmill - given to Lynn during marriage, used, from neighbor --Oak antique dresser - Lynn's before marriage, belonged to Great Aunt ITEMS LEFT IN HOUSE Lace curtains - bought during marriage. Dining room table - bought by Lynn during marriage from co-worker (left with Mike) utility closet ITEMS TAKEN BY LYNN --Washer - given to Lynn to borrow during marriage. Belongs to her parents --Dryer - Bought last year, during marriage, on Lynn's Lowe's credit card --Hoover upright vacuum - Given to us during marriage, used, from Lynn's parents --Mini canister vacuum- bought last year by Lynn at yard sale. --Sears carpet shampooer - bought during marriage, on Lynn's Sears charge. Iron - bought by Lynn prior to marriage I FFT WITH MIKE a --REGINA Housekeeper Upright vacuum Kitchen Items Taken by Lynn --Kitchen table and four chairs - bought during marriage, on Lynn's charge card at Bon Ton --Everyday eating plates, cups, saucers, white, and black rim, Lynn's before marriage, college graduation gift. --Phaltzgraff flatware set - given to Lynn for Xmas present, 1998. --Antique bottle collection, basket collection, wooden wines rack, and various nic-nacs. Bought before marriage, or bought at yard sales for under $1.00 --Black microwave oven - Lynn's before marriage, college graduation present --Kitchen gadgets - took half, left half with Mike --Cake decorator set Lynn's before marriage KITCHEN ITEMS LEFT WITH MIKE Wooden IKEA table, 2 chairs- Lynn's before marriage, given to her by roommate, left with Mike Oak bookcase - Mikes' prior to marriage (left behind) Oriental serving wear "rice pattern", blue and white - Mike's before marriage, (left behind) Smith Bros. China set, strawberry pattern Mike's before marriage, (left behind) Toaster - bought during marriage - left behind Refrigerator - bought during marriage, left behind 5 All pots and pans -Belong to both Lynn and Mike, prior and during marriage, left all with Mike Lynn's bedroom ITEMS LYNN TOOK --Maple bedroom suite- bed frame, 2 mirrors, 2 chests, vanity and stool, bedside table -Lynn's before marriage --Mattress- bought on Lynn's charge during marriage from BON TON --Lamps bought on clearance during marriage --color television set-Lynn's before marriage --Lynn's clothes, shoes, jewelry, personal effects ITEMS LEFT FOR MIKE --Window Air conditioner --Box spring -Mikes before marriage, (left behind) --Mike's clothes and shoes, personal effects Kid's rooms --Beds, mattresses, furniture toys linens, toys etc-all taken for children, except for Ben's frame. --Window Air conditioner for Ben's room --Andrew's air purifier --All kids' bed linens --All kids personal items G --All kids bedroom toys and books GARAGE Items taken by Lynn --Bianchi 15 speed mountain bike-belong to Lynn before marriage --MTD lawnmower-bought by Lynn, 1999, damaged for $70.00 --Toro gas blower-bought by Lynn, damaged for $20.00 --Plastic patio furniture-bought on clearance from Lowe's by Lynn on her charge --Kids bikes, sleds, pool toys etc. Items left for Mike- --All tools, power tools, canoe, misc. patio furniture, etc. OF SPECIAL NOTE: I AM BEING ACCUSED OF STEALING SWEATPANTS AND MIKE"S GRANDMOTHER'S SILVER. TO THE BEST OF MY KNOWLEDGE, I DO NOT HAVE EITHER, ENLESS THEY WERE PACKED BY ACCIDENT BY THE MOVERS. I WILL BE GLAD TO RETURN THOSE ITEMS IF FOUND. LYNN K. CHAMBERS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. MICHAEL E. CHAMBERS, Defendant 99-6904 CIVIL TERM IN RE: MATTER TAKEN UNDER ADVISEMENT ORDER OF COURT AND NOW, this 19th day of April, 2000, upon consideration of Defendant's Petition for Special Relief, and following a hearing on the issue of the requested return of marital property to the marital residence, the record is declared closed, and the matter is taken under advisement. The stenographer is requested to transcribe the notes of testimony of this hearing. By the Court, Samuel L. Andes, Esquire Attorney for Plaintiff Gerald S. Robinson, Esquire Attorney for Defendant Sheriff srs R LYNN K. CHAMBERS, Plaintiff V. MICHAEL E. CHAMBERS, Defendant IN THE COURT OF COMMON PLEAS Of CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-6904 CIVIL"I'ERM ORDER OF COUR"I' AND NOW, this It day of March, 2000, upon consideration of Defendant's Petition for special Relief, it is ordered and directed as follows: 1. A hearing is scheduled on the issue of the requested return of marital property to the marital residence for Wednesday, April 19, 2000, at 3:00 p.m., in Courtroom No. 1, Cumberland County, Pennsylvania. 2. Defendant's petition for special relief with respect to the custody is denied, without prejudice to Defendant's right to file such a petition in the custody case pending between the parties at No. 00- 997 Civil Term. BY THE COUR'T', G , J., csley 01c r, Jr., J. Samuel L. Andes, Esq. 525 North 12`x' Street P.O. box 168 Lemoyne, PA 17043 Attorney for Plaintiff Gerald S. Robinson, Esq. 4407 North Front Street P.O. Box 5320 Harrisburg, PA 17110 Attorney lbr Defendant :rc RMO LYNN K. CHAMBERS, Plaintitl7Respondent. MICHAEL E. CHAMBERS, Defendant/Petitioner. IN THE COURT OF CONIMON PLEAS CUNIBERLAND COUNTY, PENNSYLVANIA NO. 99-6904 CIVIL TERM CIVIL ACTION -DIVORCE ORDER OF COUR•r AND NOW, this day of 2000, upon Motion of Gerald S. Robinson, Esquire, attorney for Petitioner, MICHAEL E. CHAMBERS, and upon consideration of the within Petition for Special Relief, a Rule is entered on the Respondent, LYNN K. CHAMBERS, to show cause why the prayer of the within Petition should not be granted. Rule returnable within days from the date of service. Service shall be effective upon counsel of record for Respondent. BY THE COURT: J. LYNN K. CHAMBERS, : IN THE COURT OF COMMON PLEAS Plaintiff/Respondent, : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 99-6904 CIVIL TERM MICHAEL. E. CHAMBERS, Defendant/Petitioner.: CIVIL ACTION -DIVORCE PETITION FOR SPECIAL RELIEF TO THE HONORABLE JUDGES OF SAID COURT: AND NOW comes the petitioner, Michael E. Chambers, by his attorney, Gerald S. Robinson, Esquire, and respectfully states the following: The Petitioner is MICHAEL E. CHAMBERS, an adult individual residing at 223 South York Street, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Respondent is LYNN K. CHAMBERS, an adult individual residing at 908 Loring Lane, Mechanicsburg, Cumberland County, Pennsylvania. On or about November 9, 1999, Plaintiff/Respondent, Lynn K. Chambers, filed a Complaint for child and spousal support even though the parties were residing together with their two minor children. 4. At the Domestic Relations Conicrence held on.lanuary 10, 2000. Defendant/Petitioner. Michael E. Chambers, objected to the claim for support and testified that he was paying most of the parties' marital expenses and argued that his Wile was not entitled to support because the parties continued to reside in the martial residence. 5. By order dated January 28, 2000, a copy of which is enclosed, the complaint for support was denied because Detendant/Petitioner was supporting his liunily. 6. On February 10, 2000, Plaintift7Respondent, Lynn K. Chambers moved out of the marital residence and moved into her parents' residence with the minor children while her husband was at work. Plaintift7Respontlent removal nost of the parties' furnishings from the martial residence and placed them in storage at an undisclosed location making the martial residence inhabitable for Defendant/Petitioner and the minor children. S. Del'cndant/Petitioner is capable of providing a stable and healthy environment for the minor children in the martial residence. WHEREFORE, Petitioner respecttidly requests your Honorable Court to: a) Order Respondent to return the martial property to the marital residence; and b) Order that petitioner shall have primary physical custody of the minor children until further Order of the Court. Respectfully submitted, & GERALDO By: GerSld S. Robinson, csq Attorney I.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, PA 17110 (717)232-3525 Attorney for Petitioner CERTIFICATE: OF SERVICE I, Gerald S. Robinson, Esquire, do hereby certify that on the 23°i day of February, 2000, 1 caused a true and correct copy of the Order to be screed upon the following individual by first class mail by depositing same in the United States, postage prepaid, in I-larrisburg, Pennsylvania. Samuel Andes 525 North 13th Street P.O. Box 163 Lemoyne, PA 17043 Respectfully submitted, ROBINSON & GERALDO By:_ C? Gerald S. Robinson, Esquire Attorney I.D. No. 37423 4407 North Front Street P.O. Box 5320 Harrisburg, PA 17110 (717) 232-5525 LYNN K. CHAMBERS, Plaintill; MICHAEL E. CHAMBERS. Dclcndant. IN TIME COURT OF COiNEMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6904 CIVIL TERjI CIVIL ACTION-DIVORCE ANSWER TO I'LAiN,rIFF'S COMPLAINT IN DIVORCE The Defendant. Michael E. Chambers, by and through his attorney, Gerald S. Robinson, EsdUire, files the hollowing Answer, pursuant to Pa.R.C.P. 1017, to Plaintili's Complaint in Divorce: 1. Denied. The Plaintil7'currently resides at 908 Loring Lane, Mechanicsburg, Cumberland County. Pennsylvania. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. '1'hc Defendant has insufficicnt inibrmation in order to admit or deny this allegation. S. The Defendant has insufficient information in order to admit or deny this allegation. NEW MATTER COUNT 1-CUSTODY 9. The Del'enclant has incorporated by reference Paragraphs I through S of the Answer as filly set forth herein. 10. There was two children born during this marriage, to wit: Benjamin A. Chambers, born August 12, 1992 and Andrew M. Chambers, born December 19, 1994. 11. During the past five (5) years, the children have resided with the following persons at the following addresses: PERSON ADDRESS DATES Plaintiffand Delcndant Plaintiff 223 fork Street Mechanicsburg. PA 17225 Birth to February 2000 February 10, 2000 to Present 12. The Court of Common Pleas of Cumberland County, Pennsylvania, Family Division, has the sole and exclusivejurisdietion in this matter, pursuant to the Uniform Child Custody Jurisdiction Act, and the Commonwealth Child Custody Jurisdiction Act for the following reasons: a. Cumberland County, Pennsylvania, has been the children's home county within the six (6) months before the conuncnccment of the instant proceedings. b. It is in the best interest and welfare ofthe children that the Court of Common Pleas of Cumberland County, Pennsylvania, assume jurisdiction because the children have a significant connection with thisjurisdiction, and there is available in this jurisdiction substantial evidence concerning the children's present or future care, protection, training and personal relationships. o No other state has jurisdiction in this matter under the requirements of tine Unitonn Child Custody Jurisdiction Act and the Commonwealth Child Custody Jurisdiction Act. 13. The Defendant has not participated in any capacity whatsoever in any other litigation concerning the custody of the minor children in this or any other state. 14. The Defendant does not know of any other person other than the Plaintiff herein who claims to have custody or partial custody rights with the minor children. -im A 15. The Defendant submits that it is in the best interest and wellare orlhe minor children that he be granted custody orthe minor children, and that the Defendant can best provide the minor children with a more stable, healthl61, religious and proper environment. WHEREFORE, Defendant prays that this Honorable Court grant custody of the minor children of the parties to Defendant. COUNT 11-EQUITABLE DISTRIBUTION 16. The Plaintiff incorporates by reference Paragraphs I through 15 of the Answer as fully set forth herein. 17. During the marriage, Plaintiff and Defendant have acquired various items or marital property, which are subject to equitable distribution under Section 3502 of the Pennsylvania Divorce Code off 950, as will be fully set forth in the Plaintiffs Inventory and Appraisement to be filed pursuant to the Pennsylvania Rules or Civil Procedure. 18. Plaintiff and Defendant have been unable to agree as to an equitable division of marital property. WHEREFORE. Dclcndant requests your Honorable Court to equitably divide all marital property. Respectfully submitted, R013INSON S CERALDO Date: By: Gerald S. Robinson, Esquire Attorney I.D. #27423 4107 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 332-5525 Attorney for Plaintiff CEWHFICATE OF SERVICE. 1, Gerald S. Robinson, Esquire, do hereby certify that on the 28"' day of February, 2000, 1 caused a true and correct copy of the Answer to be served upon the following individual by first class mail by depositing same in the United States, postage prepaid, in Harrisburg, Pennsylvania. Samuel Andes 525 North 12th Street P.O. Box 16S Lemoyne, PA 170=43 Respec[tidly submitted, ROBINSON & GERALDO By: lGerald S. Robinson, Esquire Attorney I.D. No. 27=423 4407 North Front Street P.O. Box 5320 Harrisburg, PA 17110 (717) 232-5525 ..`.ice VERIFICATION I vcril'v that the statements made in this Answer arc true and correct. I understand that false statements herein are made subject to the penalties of IS Pa. C.S. Section 4904, relating to unsworn falsification to authorities. LYNN K. CI IA\I13ITS, Plaintift', %. MICHAEL E. CI IANIBERS. Defendant. IN Tlil- COURT OI' COMMON PLEAS CUMBERLAND COUNTY. I'I:NNSYLVANIA NO. 99-6904 CIVIL TERM CIVIL ACTION-DIVORCE ANSR'I:R 10 PLAINTIFF'S COMPLAINT IN DIVORC The Defendant, i%lichscl E. Chambers. by and through his attorney, Gerald S. Robinson, Esquire, files the tollowing Answer, pursuant to P.I.R.C.P. 1017, to Plaintiffs Complaint in Divorce: I. Denied. I,he 1,111intil7cm'rently resides at 908 Loring Lane, Cumberland County, Pennsylvania. 2, Admitted. i, Admitted. 4. Admitted. 5, Admitted. °o ,:Urn N ., p l7? ' ^ 6. Admitted. 7. The Dcfcnclant has insullicicnt intinnuuion in order to admit or deny this allegation. S. The Defendant has insufficient inliirmation in order to admit or deny this allegation. rw MATTER COUNT 1-CUSTODY 9. The Del'cndant has incorporated by reference Paragraphs I through S of the Answer as fully set forth herein. 10. There was two children born during this marriage, to wit: Benjamin A. Chambers, born August 12, 1992 and Andrew I9. Chambers, bunt December 19, 1994. 11. During the past live (5) years, the children have resided with the following persons at the following addresses: PERSON ADDRESS DATES Plaintiftand Defendant 223 York Street Nlechanicsbure, PA 17225 Birth to February 2000 Plaintiff February 10, 2000 to Present 12. The Court of C'onunon Plcas of Cumberland County. Pennsvhmnia, family Division, has the sole and exclusive jtn'iscliction in this matter, Ixu'suant to the Unilorol C'hilcl Custody Jurisdiction Act, and the Conunomvc;tlth Child Custody Jurisdiction Act for the followin,- reasons: a. Cumberland County. Pennsylvania, has been the children's home county within the six (G) months betixe the commencement of the instant proceedings. b. It is in the best interest and wellare of the cliiltiren that the Court of Common Pleas of Cumberland County. Pennsylvania, ISSUMCjUrisdiction because the children have a significant connection with thisjurisdiction, and there is available in this jurisdiction substantial evidence concerning the children's present or future care, protection. training and personal relationships. C. No other state hasjurisdiction in this matter under the requirements of the Uniform Child Custody .luriscliction Act and the Commonwealth Child Custody Jurisdiction Act. 13. The Defendant has not participated in any capacity whatsoever in any other litigation concerning the custody of the minor children in this or any other state. 14. The Defendant does not know of any other person other than the Plaintiff herein who claims to have custody or partial custody rights with the minor children. 1 i a I>• The Defcndant submits that it is in the best interest and welfare of the minor children that he be granted custody of the minor children. and that the DClbndaat can best provide the minor Children with a more stable. healthful. religiouS and Proper environment. WHEREFORE, Defendant prays that this I lonorable COUI't grant custody ofthe minor children of the parties to Defendant. COUI,'T II-EQUITABLE DIS' 'RIBUPION 16. The Plaintiff incorporates by reference Paragraphs I throw^h 15 of the Answer as rally set forth herein. 17. During the marriage. Plaintiff and Derendant have acquired various items of marital property, which are subject to equitable distribution under Section 3502 of the Pennsylvania Divorce Code of 1950, as will be fully set forth in the Plaintiffs Inventor' and Appraisement to be tiled pursuant to the Pcnnsyhaniu Rules of Civil Procedure. is. Plaintiff and Defendant have been unable to agree as to an equitable division of marital property. Wl IEREFORE, Dcfend;mt rcyuesu your I lonurable Court ro cyuitahly di?idc all marital property. Respectfully submitted. ROBINSON S GF.RALDO By: Date: Gerald S. Robinson. Esquire Attorney I.D. ti27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsyhani;t 17110-5320 (717) 232-8525 Attorney for Plaintiff Z CERTIFICATE OF SERVICE. I, Gerald S. Robinson, Esquire, do hereby certify that on the 28"' day of February, 2000, 1 caused a true and correct copy of the Answer to be served upon the following individual by first class mail by depositing same in the United States, postage prepaid, in I larrisburg, Pennsylvania. Samuel Andes 525 North 12th Street P.O. Box IGS Lemoyne, PA 17043 Respectrully submitted, R013INSON & CERALDO By: "<9? Gerald S. Robinson, Esquire Attorney I.D. No. 27423 4407 North Front Street P.O. Box 5320 Ilarrisbure, PA 171 10 (717) 232-5525 N'IiRIPICATION I ecrity that the statcmcnts made in this Answer are true and correct. I understand that false statements herein are made subject to the penalties of' I S Pa. C.S. Section 4904, relating to unsworn falsification to authorities. . : dws LYNN K. CHAMBERS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. MICHAEL E. CHAMBERS, Defendant 99-6904 CIVIL TERM TRANSCRIPT OF PROCEEDINGS IN RE: DEFENDANT'S PETITION FOR SPECIAL RELIEF Proceedings held before the HONORABLE J. WESLEY OLER, JR., J. Cumberland County Courthouse, Carlisle, Pennsylvania on Wednesday, April 19, 2000 in Courtroom No. 1 APPEARANCES: SAMUEL L. ANDES, Esquire Attorney for Plaintiff GERALD S. ROBINSON, Esquire Attorney for Defendant 1 INDEX TO WITNESSES FOR THE DEFENDANT DIRECT CROSS REDIRECT RECROSS Michael E. Chambers 3 21 26 FOR THE PLAINTIFF Lynn K. Chambers 30 52 61 -- INDEX TO EXHIBITS I DEFENDANT'S EXHIBIT NO. MARKED ADMITTED 1 - Handwritten note 11 13 2 - List of property prepared 28 30 by Defendant 3 - Letter from Gerald Robinson, Esq., 54 -- ! to Samuel Andes, Esq. PLAINTIFF'S EXHIBIT NO. 1 - E-mail 38 63 2 - List of items taken prepared 50 64 by Plaintiff i 2 1 THE COURT: This is the time and place for a 2 hearing on the request for return of marital property to the 3 marital residence. We will let the record indicate that 4 Plaintiff is present in court with her counsel, Samuel L. 5 Andes, Esquire, and the Defendant, whose request this is, is 6 present in court with his counsel, Gerald S. Robinson, 7 Esquire. Mr. Robinson? 8 MR. ROBINSON: Good afternoon, Your Honor. 9 I have two witnesses to call. Before I do, I'm going to set 10 the record straight that I realize that this is not a hearing 11 on a property distri bution, and I fully understand that 12 that's done in front of a master. I just want to set the 13 record straight with regard to that. With that, I call my 14 first witness, Mr. Chambers. 15 MICHAEL E. CHAMBERS 16 having been duly sworn, testified as follows: 17 DIRECT EXAMINATION 18 BY MR. ROBINSON: 19 Q Mr. Chambers, as I told you yesterday when 20 we we re preparing for this hearing, you're going to have to 21 speak clearly. There are two peopl e here that I'm concerned 22 about that hear everything that you say, and that's Judge 23 Oler and the court reporter. Make sure that Mr. Andes can 24 hear you, as well. Take your time and answer the questions 25 after I pose them to you. 3 Would you state your address, please- 1 2 THE COURT: First, your full name? 3 THE WITNESS: Full name is Michael Edward 4 Chambers. 5 BY MR. ROBINSON: 6 Q 7 A 8 Q 9 A 10 Q 11 A 12 Q 13 marriage? And your age? Forty-three. To whom are you married? To Lynn Chambers. When were you married to Ms. Chambers? In June of 194. Were there any children born of this A Vie have a son, Benjamin, who was born prior 14 ' 15 to the marriage, and a son, Andrew, born after the marriage. 16 THE COURT: Your address is what? THE WITNESS: 223 South York Street in 17 18 Mechanicsburg. 19 BY MR. ROBINSON 20 Q 21 A 22 Q 23 A 24 Q 25 A What are the ages of your children? Ben is seven, and Andrew is five. Are you employed? Yes, I am. Where are you employed? I'm employed by Oak Tree Casework in in I , 4 1 Greencastle, Pennsylvania 2 Q Where is that? 3 A In Greencastle. 4 Q What do you do there? 5 A I'm the chief engineer. 6 Q Is your wife employed? 7 A As far as I know. 8 Q Was she employed as of the date she moved 9 out? 10 A Yes, she was. 11 Q Could you describe her employment as best as 12 you know it, in terms of who her employer was, where her 13 employer was located, and her work hours? 14 A There were two part-time jobs, Prudential 15 Securities, a part-time day job. I believe it was like four 16 hours a day, three days a week. 17 Q What hours? 18 A I don't know that the hours were fixed, 19 because there were some conflicts in the appointments and 20 scheduling. Some adjustments were made. My father helped 21 out watching the kids on occasion. 22 Q Where else did she work? 23 A And Lowe's Home Center in Mechanicsburg. 24 Q what were her work hours there? 25 A Those were evenings, typically Monday, 5 1 Wednesday, Friday; and Saturday afternoon into Saturday 2 evening. 3 Q What were your work hours? 4 A My work hours were between 7 to 7:30, which 5 meant I had to leave home between 6 and 6:30, until 4:30, 6 although I -- from the time I took the job, I had been coming 7 home at 4:00 -- or leaving work to get home by 5:00 on 8 Tuesdays and Thursdays to accommodate her schedule. 9 Q When you say to accommodate her schedule, so 10 she could work? 11 A Between work and time that she spent at the 12 "Y". She went for workouts. She worked also a part-time job 13 at the "Y" one night a week. 14 Q Now, your children, were they in school? 15 A Ben is in first grade, and Andrew is in 16 nursery school three days a week. 17 Q Ben's school time goes from when to when? 18 A He's out of school at 2:30. School starts, 19 I believe, at 8:15. 20 Q Andrew goes -- 21 A Andrew was -- three days a week there was an 22 afternoon, which was like noon to three. 23 Q Who was responsible for getting the kids off 24 to school? 25 A Lynn. 6 1 Q Who was responsible for the kids -- 2 MR. ANDES: If I may, Your Honor, I object 3 to this line of questions. I don't understand what this has 4 to do with personal property. This is not a custody dispute. 5 THE COURT: Mr. Robinson? MR. ROBINSON: I'm giving a little 6 7 background. I'm just about done in this area. It's my g position, Your Honor, without arguing the case, that 9 Ms. Chambers took the items out of the house to prevent Mr. 10 Chambers from having visitation or having time with his kids. 11 I'm going to show you what his role was with regard to the 12 kids, because it's going to be -- I'm anticipating Mr. Andes' 13 position, based on the correspondence, that Ms. Chambers was 14 the primary caretaker of these children. It's our position 15 that the items -- her taking the items out of the house, the 16 design was -- it was motivated by her intent of depriving him 17 custody of the children. 15 THE COURT: where are the children now? 19 MR. ROBINSON: The children are now residing 20 in Ms. Chambers' mother's house. I'm going to get to -- I 21 was just about done with the background, and I was -- 22 THE COURT: You can ask this question. 23 BY MR. ROBINSON: 24 Q So your responsibilities with regard to the 25 children were what? f 7 1 A on returning from work every day, I 2 essentially to ok over the care of the c hildren. Lynn was 3 either leaving for work, leaving to go to the "Y," or going 4 directly from her part-time day job to the "Y". 5 Q How long would she be out after you got 6 home? 7 A The nights she worked at Lowe, s, anywhere 8 from 11:00 until 7:00, 8:00 the next morning. 9 Q Were you the primary caretaker of the 10 children during those hours? 11 A I prepared dinner, gave baths, did homework, 12 got them to bed, took care of my children. 13 Q As further background, but in another 14 direction, did disharmony exist in your household at some 15 point in time? Was there disharmony in your household? 16 A There had been increasing levels of tension 17 for a number of years. 18 Q Did that result in -- well, before that, 19 prior to my involvement in the case, who paid the bills in 20 your household? 21 A Lynn wrote mostly all of the checks, 22 basically all the che cks. I deposited my paycheck into the 23 joint account, and I rarely saw the checkbook. 24 Q Did you make a change in that procedure; and 25 if you did, wh at did you do? 8 1 A Yes. 2 MR. ANDES: Your Honor, if I may, I don't 3 see how any of this has any bearing on the personal property. 4 First of all, we went through the background of a custody 5 dispute, which is before the Court in another matter 6 scheduled for a conciliation in a little less than a week. 7 Now we're going through the history of who paid the bills and 8 who earned the money, which I suppose is going to lead us to 9 a support dispute. 10 What I understand we're here about is the 11 personal property and what belongs to him and/or her and what 12 is marital property and whether that should be returned to 13 the marital residence or we should dispose of that later 14 before the Master. With all due respect, this is all 15 extraneous, and it's going to take a lot of time, because my 16 client now is going to have to get up and tell her side of 17 the story, and it's still extraneous. 18 MR. ROBINSON: Your Honor, I find it a 19 little disingenuous that counsel is taking that position in 20 light of the fact that he found those things very relevant 21 when we were discussing them before we came into the 22 courtroom. 23 THE COURT: I guess what I need is some sort 24 of basic background. Apparently the parties separated, but 25 that's not in the record, and apparently somebody took 9 1 'I 1 furniture in the house, which is not in the record. If you I 2 can get to the basic things, then we can do the refinements. I 3 MR. ROBINSON: Your Honor, I can understand j 4 that you wouldn't know, and I'm trying to develop that, but i I; 5 Mr. Andes has been involved in this all along, and he well 6 knows the relevance. What it is is this, Your Honor. Like I 7 said, I want to present a case. I don't want to argue before 8 I start presenting my case. What happened is this. I 9 THE COURT: Let's bring it out through the i 10 witness. I just need to know the basics of when property was lIi 11 removed, and then you can get into the refinements of why who 12 supported who is important. I! 13 MR. ROBINSON: I'll do that, but you're 14 making me take it out of order. It would be easier if I i 15 could just give a little background and -- 16 THE COURT: I'm lost. When I hear things 17 like who's paying for the groceries and things like that, 18 without knowing the basic things like did somebody leave the 19 premises and did somebody take furniture, it's Iii ! just hard for III 20 me to put it in context. i 21 MR. ROBINSON: That's why I was trying to do 22 it chronologically. Now you're asking me to jump, and then 23 it's really going to be confusing. i j 24 MR. ANDES: If I may, Your Honor, I think 25 you ruled. I mean, we only have a certain amount of time 10 1 today. If Mr. Robinson is going to argue every time you make 2 a ruling, we won't get anything done. 3 THE COURT: I don't think I ruled on this 4 particular objection. I'm just saying I'd like to hear the 5 basic information about who left and when and what was taken. 6 MR. ROBINSON: I would like to have this 7 marked Defendant's Exhibit No. 1. 8 (Defendant's Exhibit No. 1 was marked for 9 identification.) 10 BY MR. ROBINSON: 11 Q Mr. Chambers, I'm showing you what's been 12 marked for identification purposes as Defendant's Exhibit No. 13 1. Could you tell us what it is? 14 A This is a note that I found when I returned 15 home on February 10th from work to a house that was gutted. 16 Almost virtually all furnishings were removed, all beds, 17 bedding, chairs, tables, couches, tables. 18 THE COURT: February 10th of what year? 19 THE WITNESS: Of this year. 20 BY MR. ROBINSON: 21 Q Do you know who took the items out of your 22 house? 23 A According on the note that Lynn left behind, 24 she did. 25 THE COURT: Referring to the Plaintiff? 11 r. I THE WITNESS: Yes. 2 BY MR. ROBINSON: 3 Q Now, how long after you received the order i 4 from this Court denying her petition for support were the 5 items taken out of the house? I li 6 A It was five days from the time I received my 7 notification, which came in the mail on the Saturday before. 8 Q How long had you waited for that decision? 9 A We had waited I believe it was close to a 10 month. 11 Q Within four or five days, then, everything 12 was moved out of the house? 13 A The house was gutted. There was not a bed 14 to sleep on. There was one towel left hanging in the house. 15 There were two blankets left that the dog used for bedding. 16 I had nothing to sleep on or sleep under. 17 THE COURT: This is an order that I issued? 18 MR. ROBINSON: I don't know which judge 19 issued the order. 20 THE COURT: I'm not sure what you are 21 referring to when you say the orders. 22 MR. ROBINSON: That's why I wanted to put it 23 in order. 24 MR. ANDES: To tell you the truth, Your 25 Honor, I don't know which judge signed the order, but I can 12 1 find it. 2 MR. ROBINSON: Basically, it was just an 3 order denying her petition for support. Now I'm going to go 4 back to put it in place. I put a copy of the letter, the 5 exhibit, right there for you. I would move into evidence 6 Exhibit No. 1. 7 MR. ANDES: I have no objection. 8 THE COURT: Okay. Defendant's Exhibit 1 is 9 admitted. 10 (Defendant's Exhibit No. 1 was admitted.) 11 BY MR. ROBINSON: 12 Q Prior to your coming home and finding that 13 everything was taken out of your house, had Mrs. Chambers 14 initiated support proceedings? 15 A Yes, and I don't recall exactly when I first 16 received notice of that, but the support hearing was 17 scheduled the first week of January, which time I was living 18 at home. I had set up a new checking account, and I had 19 taken over paying the bills, trying to get some of the bills 20 caught up. 21 Q Now, going back to where we were before the 22 objection was interposed, at some point in time, the 23 mechanism that your family used the pay bills changed, is 24 that correct? 25 A That's correct. 13 1 Q Could you tell the judge what happened? 2 A I believe it was in mid-November I received 3 a letter from Mr. Andes that he was preparing to file a 4 divorce petition, or something along that effect, and 5 basically threatening to have a sheriff deliver it at work if 6 I wouldn't cooperate, at which time I_ contacted Mr. Robinson. 7 Q But answer my question. Was there -- 8 before, who was paying the bills? 9 A Lynn was writing the checks out. 10 Q Who was funding the account? 11 A It was a joint account. My paycheck went 12 into it weekly. Up until several months prior to that, her 13 checks had been going in there, although the last couple of 14 months she had been diverting her funds, also, elsewhere. 15 Q As a result of that, did you take over 16 paying the bills? 17 A Yes, I did. 18 Q What was your wife's reaction to you paying 19 the bills directly? 20 A I was to -- first it was a verbal threat to 21 file for support, and then followed up shortly thereafter 22 with a notice for a support hearing. 23 Q The support hearing was when? 24 A The first week of January. 25 Q During the support hearing, did you provide 14 1 testimony that you were, in fact, supporting your family by 2 paying the bills? 3 A I provided the testimony, along with the 4 documentation -- followed up with the documentation that I 5 was paying the bills and catching up past-due accounts. 6 Q Was the support officer able to give you a 7 decision at the support conference? 8 A No, he was not. 9 Q How long -- 10 THE COURT: I'm sorry, but I'm a little 11 confused. You talked about a hearing and you talked about 12 testimony, but now we're talking about a conference. Was 13 there a hearing? 14 MR. ROBINSON: Well, a Domestic Relations 15 conference. 16 THE COURT: Was there a hearing de novo? 17 MR. ROBINSON: No, it was a Domestic 18 Relations conference. There was no hearing de novo. 19 THE COURT: Was there a recommended order 20 that resulted from the conference? 21 MR. ANDES: There was a conference, Your 22 Honor, before Frank Goshorn of the Domestic Relations office. 23 If you want, I can give you the date of that. Although the 24 parties were not separated, we sought support, in accordance 25 with the decision of Judge Bayley in the Rozman case, with 15 1 which you may or may not be familiar. Mr. Goshorn took it 2 under advisement. I have never seen this. I don't know that 3 he ever filed a recommendation. He must have, because Judge 4 Guido then entered an order, which is dated the 28th day of 5 January, in which he denied the petition because the parties 6 were currently residing in the household. 7 THE COURT: Was that appealed? 8 MR. ANDES: No, that was not appealed. 9 THE COURT: Okay. 10 BY MR. ROBINSON: 11 Q Now, in between the time that you had the 12 Domestic Relations conference and you got the copy of the 13 order denying the petition, were there discussions between 14 you and Ms. Chambers about support and whether or not you 15 were going to have to pay support? 16 A I was told on several occasions that the 17 order was coming very soon and that I would be paying back to 18 the date that she filed. 19 Q The order came, and it indicated that you 20 didn't have to pay support? 21 A That's correct. 22 Q How many days after that did you come home 23 and everything was gone? 24 A Five days. 25 Q Where were your children? 16 1 A According to the note that was left, she 2 took them with her to her mother's. 3 Q Do you know where your property is? 4 A It's my understanding that the majority of 5 the household belongings are in storage. 6 Q Have you had visitation with your children 7 since they were taken out and all of the furniture was taken 8 out? 9 A I have seen my children at her convenience 10 or at her mother and stepfather's convenience. 11 Q Were you able to have your children 12 overnight at your house? 13 A At this point, overnights are out of the 14 question. I have no place for them to sleep. I don't have 15 their bedding. I don't have their clothing. Everything was 16 removed from the house down to the telephones. There was not 17 a working telephone in the house when I came home that night. 18 THE COURT: Your bedroom furniture was gone? 19 THE WITNESS: The bedroom furniture, all 20 bedding, both son's beds, with the exception of my oldest 21 son's bed frame which I had built. It was a bookcase and bed 22 with drawers under it. It was something that I had built. I 23 would imagine it would be very difficult to take apart if you 24 didn't know how it went together. But the mattress itself 25 had been removed and all of the bedding. 17 1 BY MR. ROBINSON: 2 Q Is this property all in storage, to your 3 knowledge? 4 A To my knowledge. 5 Q Is there an existing order for custody? 6 A No, there's not. 7 Q So, legally, if you had the kids, you could 8 keep them as long as you wanted to, is that correct? 9 A That's my understanding. 10 Q But realistically, can you keep the children 11 because of the -- realistically, can you keep the children at 12 your house? 13 A Realistically, as a father who cares very 14 much about his sons, I can't see subjecting them to that or 15 the additional emotional strain at this point, given that 16 they come into their room and see barren walls. Actually, 17 what was left behind was filth. The sofa was moved, and 18 mounds of dog hair and dust balls and everything else were 19 left as they lay. 20 THE COURT: This is a house that's in whose 21 name? 22 THE WITNESS: It is in both names. 23 THE COURT: That's where you're still 24 living? 25 THE WITNESS: Yes, it is. 18 1 THE COURT: I think I have a picture of the 2 furniture left in the house. 3 BY MR. ROBINSON: 4 Q Your son, Ben, he's in kindergarten? 5 A Ben's in first grade. 6 Q How far is the school from your house? 7 A The school is two long blocks, but it's 8 walking distance. 9 Q Did there have to be alternate arrangements 10 for Andrew's schooling, as well? 11 A Andrew, as I understand, was moved from the 12 nursery school, which was two blocks the other direction, to 13 a nursery school in Grantham. 14 Q Did Mrs. Chambers talk to you about any of 15 this? 16 A Just -- it was the week prior I received a 17 call at work. She wanted money because she was putting 18 Andrew in this new nursery school in Grantham, because she 19 said she was going to work more, at which point I suggested 20 that there were other alternates besides additional nursery 21 school. Her response was very immediate, that my father 22 offering to help take care of the kids was not an option and 23 that she didn't want him taking care of them. Again, she 24 pointed out that -- that was probably the last time she 25 pointed out that a support order was coming and that I would 19 1 not only have to pay back support, but I would also have to 2 pay for the day care, as well. 3 Q Now, it's your contention that her taking 4 this furniture is impeding your ability to have custody of 5 your children. In light of the fact that you have working 6 hours, as you've described, have you made arrangements for 7 day care in the event that you had custody of the children? 8 A Yes. 9 MR. ANDES: Your Honor, this is not a 10 custody proceeding. If you want to hear a custody case, we 11 can convene another time and bring in our witnesses. But 12 this is not a custody proceeding, and I think Mr. Robinson is 13 trying to make it one. Frankly, in light of the order that 14 scheduled this hearing, I'm not prepared today to put the 15 merits on of our custody proceedings. 16 MR. ROBINSON: Your Honor, I foresaw these 17 arguments coming from counsel, and that's why I prefaced it 18 by saying we're not here for equitable distribution so we 19 wouldn't have that argument. I should have said we're not 20 here for custody either. However, it's our position that the 21 reason these items were taken out of the house and put in 22 storage, not being used by her, unavailable to him, was to 23 keep him -- well, was to wreck the household, No. 1, and to 24 keep him from seeing his kids. 25 THE COU RT: I think you made that argument. 20 l I I don't need to hear all of the other details. 2 MR. ROBINSON: Your Honor, the relevance of 3 my bringing up the alternate arrangements for child care was 4 to eliminate that as a reason for him not having the children 5 and to isolate the fact that the only reason he can't have 6 his kids is because of the furniture. 7 THE COURT: I'll assume lie can take care of 8 the children, unless that's going to be disputed. We'll see. 9 If that is disputed, then you can bring that out, Lhc 10 arrangements. 11 MR. ROBINSON: Well, Your honor, I think you 12 have a grasp of what our major thrust -- I had a lot of. other 13 testimony to try to build it up in case you didn't, but 1 14 feel that you have, so I will rest- with that. 15 THE COURT: At least you're clone with your 16 direct examination? 17 MR. ROBINSON: Yes, with my direct 18 examination of the witness. 19 THE COURT: Mr. Andes? 20 CROSS-EXAMINATION 21 BY MR. ANDES: 22 Q Do you know where your wif.c works now? 23 A I can only assume that it's still at 24 Prudential Security. 25 Q But you don't know her work schedule; you 4f r? C 21 1 don't know where she works or how often or what her work 2 hours are, is that true? 3 A That's true. 4 Q She took everything from the house except 5 those few items you mentioned, one towel, the dog's two 6 blankets, a box spring and a bed frame, is that your 7 testimony? 8 A There were a number of other items. There 9 were a number of my personal items, clothing. 10 Q Was there, for example, a television? 11 A There was a television and a VCR. 12 Q The items that she took, did they include 13 items that she owned prior to the marriage? 14 A There were items. 15 Q Did they include items that were gifts to 16 her from other people during the marriage, like from her 17 family? 18 A They included items that were gifts to her, 19 as well as gifts from her family to me. 20 Q Are you involved now with another woman 21 named Michelle Ray? 22 A I don't quite understand. 23 Q Are you having sexual relations on a regular 24 basis with a woman named Michelle Ray? 25 A No, I'm not. 22 fi`::. 1 Q Have you ever had sexual relations -- well, 2 in the last year, have you had sexual relations with a woman 3 named Michelle Ray? 4 MR. ROBINSON: Your Honor, I would submit 5 that this is not relevant. 6 THE COURT: Mr. Andes? 7 MR. ANDES: Well, it's relevant because it's 8 the reason for the separation. This man comes in here and 9 ascribes to my client, and, frankly, to me, all of these 10 terrible motives, cleaning out the house, not paying the 11 bills, filing a support action, all of these things he seems 12 to think are terrible. I would like to just establish -- and 13 I can have my client testify as to why she left, and the 14 reason she left is because he was involved with another 15 woman. If he doesn't want to admit that or answer my 16 questions, fine. I'll take that. 17 THE COURT: We'll have you bring that out in 18 your case. 19 MR. ANDES: I'll do that. I would like the 20 record to reflect that he didn't answer that question, 21 though. Thank you. 22 BY MR. ANDES: 23 Q Since February 10th, how many times have you 24 had the boys with you? 25 A They've been with me twice a week. 23 1 Q Every week? 2 A We missed two weeks ago -- or three weeks 3 ago. Ben came down with chickenpox. 4 Q Do they come for the evening, or do they 5 come during the day? 6 A Typically on Tuesday -- although it varies 7 between Tuesday and Wednesday, and I'm not notified until the 8 last minute, and I can't get specific times -- but they're 9 brought to the house by her mother or stepfather around 5:30, 10 and I'm told they're going to be picked up anywhere between 7 11 and 8:00. 12 Q And the other day of the week is what? 13 A The other day of the week is Saturday. 14 Q When do you have them then? 15 A Sometime before noon. 16 Q Until when? 17 A Until -- and that has varied. It was at one 18 point 8:00. Another time I was told they were going to be 19 picked up at 6:00 because they get too wound up when they're 20 with me, and they have to be taken home and given a bath to 21 get ready for Sunday school. Again, her mother or stepfather 22 usually pick them up. 23 Q In fact, have you asked your attorney to 24 contact me to try to set a regular schedule for you to see 25 the children? 24 I A I've discussed with Mr. Robinson custody 2 issues. 3 Q Do you know whether he's ever written me a 4 letter or made a contact with me and said my client would 5 like to see the children on this schedule or that schedule? 6 A our concern right now is the issue of 7 custody. g Q Well, does that mean that your answer is, 9 no, you have not proposed or requested a particular schedule? 10 A No, I have not requested a visitation 11 schedule with my sons, because the issue of their custody is 12 my utmost concern right now. 13 Q Prior to the time that your wife left on the 14 10th of February, is it not true that you had asked your 15 attorney to prepare a petition to remove her from the house 16 and grant you exclusive possession of the house? 17 A Could you repeat that, please? 18 Q Is it not true that prior to the 10th of 19 February you had asked your attorney to prepare a petition 20 and file it on your behalf asking that you be awarded 21 exclusive possession of the house and that she be excluded 22 from the house? 23 A That was one option that was discussed. 24 Q Well, I'm reading from a communication that 25 was forwarded to you from your attorney in which he said, 25 1 quote, we are preparing a petition for exclusive possession 2 of the marital residence. Are you aware that that was being 3 prepared? 4 MR. ROBINSON: Your Honor, I would object to 5 this question, especially if th is is communication between me 6 and my client that was somehow intercepted and should be 7 attorney-client privilege information. 8 MR. ANDES: First of all, Your Honor, it has 9 not been intercepted. It was information that was sent to 10 the home and made available to everyone in the home on the 11 computer. My client can explain that. 12 Secondly, I'm not asking him anything to do 13 with the attorney-client privilege. I'm asking him whether 14 the petition was prepared. He's come in here and accused 15 this woman of sneaking around behind his back to leave the 16 house. The fact is that a week before she left he was 17 communicating with his attorney and leaving these messages 18 around for her to find that he was going to have her thrown 19 out of the house. So I think it goes -- it's very important 20 as to the genuineness of his complaints. 21 THE COURT: The objection is sustained. 22 MR. ANDES: That's all the questions I have. 23 THE COURT: Okay. Mr. Robinson? 24 MR. ROBINSON: Redirect. 25 REDIRECT EXAMINATION 26 I BY MR. ROBINSON: 2 Q Mr. Chambers, Mr. Andes asked you if you had 3 asked your attorney to initiate dialogue regarding custody. 4 If the other side said to you, you can have custody of the 5 children full time, would you -- 6 MR. ANDES: Your Honor, this is a leading 7 question, and I object to the form of it. He's trying to 8 make argument through his question, and I object to it for 9 that reason, as well. 10 THE COURT: Mr. Robinson, do you have a 11 response to that objection? 12 MR. ROBINSON: I'll rephrase the question. 13 THE COURT: Okay. 14 BY MR. ROBINSON: 15 Q Are you able to have the children at the 16 house where they were living for any extended periods of 17 time; and if not, why not? 18 A At the current time, I really don't feel I 19 can, because I have -- I don't have their belongings. I 20 don't have sufficient means for caring for them properly. 21 Q Just so Mr. Andes can understand what you're 22 talking about, what do you need? Do you need beds? 23 A I need bedding, clothing, medicines. What 24 few toys and belongings of theirs that were left behind are 25 mostly trash, mostly broken pieces and things. 27 El' 1 Q You indicated that you prepared meals in the 2 evenings for your children. Is that correct? 3 A That's correct. 4 Q Did you also prepare meals on the weekends? 5 A Yes, I did. 6 Q Do you have pots and pans to use to cook? 7 A Pots and pans and dishes I do have. 8 Q Do you have cleaning fabrics, et cetera, to 9 maintain the dishes, et cetera? 10 A I have been gradually amassing materials as 11 quickly as I can. Two of the items that were removed from 12 the house were the washer and dryer. I have currently been 13 able to put a washer back together, but at this point I don't 14 have a dryer. 15 (Defendant's Exhibit No. 2 was marked for 16 identification.) 17 BY MR. ROBINSON: 18 Q Mr. Chambers, I'm showing you Defendant's 19 Exhibit No. 2. Could you tell us what that is? 20 A It's a list that I had put together of some 21 of the items that were removed from the house, the ownership, 22 whose they were. 23 Q Now, the first item on the list, 24 miscellaneous kitchen utensils, were they premarital property 25 that belonged to Ms. Chambers? 28 A The items I have listed there were items 1 2 that were speci fically mine prior to the marriage or -- in 3 fact, everything listed there were items that were mine 4 prior. Q Is this exhibit -- does this describe the 5 6 items that were taken from the house? A They are brief descriptions, as best I 7 8 could. MR. ROBINSON: Okay. The judge can read 9 10 that. I would move into admission Defendant's Exhibit No. 2. ANDES: Your Honor, I want my client to MR 11 . 12 testify about it before it's admitted. THE COURT: Any further questions, Mr. 13 14 Robinson? ROBINSON: No further questions. MR 15 . THE COURT: Mr. Andes, any further 16 17 questions? ANDES: I have no further questions at MR 18 . 19 this time. THE COURT: You may step down. Thank you. 20 THE COURT: Mr. Robinson, anything further? 21 ROBINSON: I'm going to rest at this MR 22 . 23 point. THE COURT: And you did want to move the 24 25 admission of Defendant's Exhibit No. 2? 29 1 MR. ROBINSON: Yes, I do. 2 THE COURT: I'll admit that. Mr. Andes, you 3 can cross-examine on it. Defendant's Exhibit 2 is admitted. 4 (Defendant's Exhibit No. 2 was admitted.) 5 THE COURT: Mr. Andes? 6 MR. ANDES: I would call Lynn Chambers to 7 the stand. 8 LYNN KATHERINE CHAMBERS 9 having been duly sworn, testified as follows: 10 DIRECT EXAMINATION 11 BY MR. ANDES: 12 Q State your full name and address for the 13 record. 14 A Lynn Katherine Chambers, 908 Loring Lane, 15 Mechanicsburg. 16 Q Since we got into the subject of your 17 children, I'm g oing to ask you some questions about them. 18 How old is Ben? 19 A Seven. 20 Q He is a student at what school? 21 A Broad Street Elementary. 22 Q In what grade? 23 A First. 24 Q Does he have any health or educational 25 problems? 30 /1 1 A He's been diagnosed with ADD, and he's on 2 Ritalin. 3 Q Other than taking medication, does he have 4 any special treatment or education or training that he 5 receives? 6 A Earlier in his life we had to take him for 7 therapy because of aggressiveness and hitting other children 8 and biting, some emotional issues. 9 Q When did that therapy stop or end? 10 A By the time he went to kindergarten, I think 11 it was. 12 Q How does he do in school? 13 A He's been doing very well. 14 Q The other child, Andrew, is how old? 15 A He's five. 16 Q He's not in school yet, that is, in first 17 grade or formal kindergarten, is that correct? 18 A Correct. 19 Q Your husband testified that he attends some 20 day care or some program three days a week? 21 A He attends Little Friends Nursery School two 22 afternoons a week and Messiah Early Learning Center two days 23 a week, and he's baby-sat some afternoons on Fridays by a 24 neighbor. 25 Q Let's talk about the Little Friends Nursery 31 1 School. What hours of the day does he attend that? 2 A He goes Mondays and Tuesdays from 12:30 to 3 3:00. 4 MR. ROBINSON: Your Honor, I would interpose 5 an objection as to the clarity of these questions. Are we 6 talking about now, since they've been removed from the house, 7 or is this before? 8 MR. ANDES: I'll clarify that with a 9 question. 10 BY MR. ANDES: 11 Q Let's talk about presently, today, this 12 week, okay? I assume that what you told us about Benjamin is 13 true, that he's in first grade this week like he was three 14 months ago? 15 A Correct. 16 Q I assume it's the same school? 17 A Correct. 18 Q And it's the same teacher? 19 A Correct. 20 Q And he's doing well? 21 A Correct. 22 Q Now, let's turn to Andrew, the 23 five-year-old. He now, this week, at the present time, 24 attends Little Friends Nursery School? 25 A Yes. 32 .c 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q What days of the week and what hours? A Mondays and Tuesdays, 12:30 to 3:00. Q How long has he been attending that nursery school? A Since he's been, I think, three. Q So that's nothing new? A No. Q You said that he's at Messiah College at the Early Learning Center. What is that? A It's a nursery school/day care center, and he attends part time- Q When does he attend that? A From approximately 7:30 in the morning till about a quarter of 5 on Wednesdays and Thursdays. Q When did he start there? A He started there about the middle of February. Q Prior to that, was he going to a nursery school, another nursery school? A Just Little Friends. Q Who was taking care of him during the week when he was not at the Messiah program? A I was, or sometimes I would have my neighbor if I was working at Prudential. Q In addition to that, presently he sees a I 11 33 I baby-sitter? 2 A Occasionally on Fridays. 3 Q For how long? 4 A From about probably 8:00 till anywhere from 5 2 to 3, and that's not every Friday. 6 Q Now, there's been a change in his schedule, 7 particularly with regard to the Messiah program, since your 8 separation from your husband, is that right? 9 A Correct. 10 Q Why has the change occurred? What caused 11 it? 12 A Because I had to go to work full time. 13 Q where do you work? 14 A Prudential Securities. 15 Q What do you do there? 16 A I work in operations. 17 Q What is your typical work schedule? 18 A It's 8 to 5, Monday through Friday. 19 Q When did you start that job on that 20 schedule? 21 A I started that job February 7th. 22 Q Your husband testified that you worked in 23 the evenings at Lowe's. Is that now true? 24 A No. I quit. 25 Q when did you last -- when did you quit? 34 I A It was, I believe, the beginning of March. 2 Q He testified that you worked somewhere else 3 on Saturdays or Fridays or some evening a week, I think, at 4 the "Y"? 5 A I volunteer two hours a week at the YMCA in 6 exchange for a f amily membership. 7 Q So that you and the boys can participate? 8 A Right, and go to the pool. 9 Q Okay. Now, let's talk about Andrew. Does 10 Andrew have any medical or educational condition that 11 requires special treatment? 12 A Yes. 13 Q Tell us about that? 14 A He has chronic lung disease and mild 15 cerebral palsy. There's major issues. And he has a lot of 16 delays. 17 Q A lot of what? 18 A Delays. 19 Q When you talk about major issues, you're 20 going to have to describe that in such away that we can 21 understand what you mean. What are his problems? How do 22 they show up? 23 A He needs breathing treatments twice a day. 24 He's susceptible to getting ill a lot. He's small and frail. 25 He's not as coordinated as other kids his age. He needs 35 1 therapy, occupational and physical therapy. 2 Q How often does he receive physical therapy? 3 A It's now every other week. 4 Q Where does fie receive that? 5 A Pinnacle Physical Therapy. 6 Q How does he get there? 7 A Since I'm working now, my mother takes him. 8 Prior to my job, I took him. 9 Q Where does he get the occupational therapy? 10 A I was taking him here to Carlisle, to the 11 Capital Area Intermediate Unit, every Wednesday. But now 12 that I'm working, we arranged for his therapist to go out to 13 Messiah and do therapy on site. 14 Q So he's receiving the therapy now while he's 15 at Messiah? 16 A Yes. It's not on the same frequency, but 17 he's still receiving the therapy. 18 Q What is your mother's name? 19 A Mary Laveer Thaller (phonetic). 20 Q How old is she? 21 A I believe she is fifty-seven. 22 Q Is she in good health? 23 A Yes. 24 Q Does she work? 25 A Part time in the home. 36 1 Q In her home? 2 A Right. 3 Q You are living with her now, is that 4 correct? 5 A Correct. 6 Q Is that a permanent or temporary 7 arrangement? 8 A Temporary. 9 Q Until what? 10 A Until I get some child support and am able 11 to get financially back on my feet. 12 Q You separated on February 10th. Have you 13 asked your husband to pay you support for the children? 14 A I basically did. I asked him if he could 15 buy the kids some clothes, because all of their clothes have 16 holes in the knees. He did buy each boy a pair of jeans. I 17 asked him about two weeks ago if he could please help me by 18 buying them some shoes, which he did do. Otherwise, I have 19 received not a penny. 20 Q You filed a support action, is that correct? 21 A Correct. 22 Q That's scheduled for a conference next week? 23 A Correct. 24 Q Who lives in the home other than you and 25 your mother and the boys? 37 1 A My stepfather. 2 Q How do the boys get along with your mother 3 and stepfather? 4 A They love each other. 5 Q Your husband testified that he sees the boys 6 one evening a week plus every Saturday. Is that essentially 7 correct? 8 A Correct. 9 Q Has he asked to see them any more than that? 10 A No. And he's never asked for overnights 11 either. 12 Q If he had asked for more time or overnights, 13 would you have been willing to let him have more time? 14 A Yes. 15 Q Would you be willing to let him have the 16 children overnight? 17 A Yes. 18 (Plaintiff's Exhibit No. 1 was marked for 19 identification.) 20 BY MR. ANDES: 21 Q Prior to the time you left the marital home, 22 was there a computer there? 23 A Yes. 24 Q Did you and your husband and the boys use it 25 for E-mail? Pf ,a s 38 1 A I did, and the boys. He had a laptop he 2 used mostly, but he did stuff with the desktop, too, somehow 3 connecting them. 4 Q In February, shortly before you left the 5 home, did you come across an E-mail that he had exchanged 6 with his attorney? 7 A Yes. I was trying to erase files and clear 8 stuff up, because he had asked me to give him his work stuff. 9 I was trying to figure out how to get his work programs to 10 him, and I accidentally came across an E-mail. 11 Q Is that document a copy of it? 12 A Yes. 13 Q That's been marked as Plaintiff's Exhibit 1, 14 is that correct? 15 A Yes. 16 Q When you saw that, did you learn something 17 about his intentions regarding you and the house? 18 A Yes. 19 Q What did you learn? 20 A That he was trying to take over the house 21 even though we're both joint owners. 22 Q Did that play a part in your decision to 23 move out of the house? 24 A Partially, yes. 25 Q What were the other reasons why you moved 39 z I out of the house? 2 A It was just a very bad situation. The 3 children were suffering, and there was a lot of hate. I felt 4 threatened, and I felt like I was being mentally abused, and 5 sometimes he would push me. 6 Q Let's talk, first of all, about the 7 background. To your knowledge, was he involved with another 8 woman? 9 A Yes. 10 Q How did that take place? Was it secret? 11 Was he open about it? 12 A It's his best friend's wife. I came 13 across -- she would come to visit him while I was at work at 14 Lowe's. They would do things. They'd go boating. I just 15 assumed that -- 16 MR. ROBINSON: Your Honor, I would object to 17 this line of questioning. 18 THE COURT: What I'm really interested in is 19 these items that were taken from the house, where they are 20 now, and why each side feels that they should be in their 21 possession. 22 MR. ANDES: Your Honor, if I may just 23 respond to his objection. 24 THE COURT: Sure. 25 MR. ANDES: We spent a lot of time throwing 40 1 arrows and rocks at my client, and I think it's only fair she 2 be able to take two minutes or five minutes and tell you why 3 she left, tell you what special needs these children have and 4 why it's important to keep them out of this fraction. That's 5 the reason I asked the question. That's my offer of proof. 6 If you choose not to hear it, that's -- you're the judge. 7 THE COURT: I'll be glad to hear one minute 8 of testimony as to why she left the house, but I'm really 9 interested basically in why the items are in storage, why 10 they couldn't be in the house, if that's the case. I don't 11 even know if that's the case at this point. 12 MR. ANDES: First, I'm going to have her 13 identify these items and testify about which are hers and 14 which are not marital property, because I don't believe 15 nonmarital property should be before us in this petition. 16 Then I'll have her explain where these items are and the 17 reason. 18 MR. ROBINSON: Your Honor, I want to reply 19 to a couple of things. No. 1, I did not throw any rocks or 20 spears or anything at this witness. Our testimony wasn't to 21 that. No. 2, as I told you before, this is not a 22 determination of marital property. We are requesting a 23 return of all of the items back to the marital residence 24 until this can get resolved by a Master. I thought that I 25 had laid enough of a foundation through this witness that the 41 17l 1" 1 1 reason we need this is to continue the household with his 2 kids. So, therefore, whether it's marital, nonmarital or 3 whatever is irrelevant. What's relevant is the fact that 4 they're not there, and it's preventing him from being able to 5 accommodate his kids at their own house. 6 THE COURT: Mr. Andes? 7 MR. ANDES: I'd like to respond to that. 8 THE COURT: Well, why don't you just go 9 ahead and ask the one-minute question and then the specific 10 question. 11 BY MR. ANDES: 12 Q Why did you leave the house? 13 A Because the marriage was over. It was very 14 cruel. I had no other choice. He would not leave even after 15 I filed for divorce. He just threatened me. 16 Q What did he threaten to do? 17 A Just that, quote, your ass is going to be 18 out on the doorstep. If you think you're keeping this house, 19 you're nuts. Things like that. I asked him several times to 20 leave so the kids could stay in their home, and he refused, 21 so I had no other recourse. 22 Q You mentioned this woman coming to the 23 house. Was that when the children were there? 24 A Correct. 25 Q Did you learn about that through the 42 ---A 1 ., 1 children? 2 A Sometimes, but I had no idea what was going 3 on at the time. And then I found correspondence between the 4 two of them, and that confirmed that there was an affair 5 going on. 6 Q I would like to get before you Defendant's 7 Exhibit 2. Defendant's Exhibit 2 is your husband's list of 8 property that he claims to have removed -- or he claims you 9 removed from the house. Let's go through that, if I may. 10 Did you remove all of his kitchen utensils from the house? 11 A I didn't think I did. I had helped in 12 packing, and I instructed whoever was helping me what to take 13 and what not. In the confusion, some of his things might 14 have been taken by accident. 15 Q How about down below. He has, under dining 16 room, a lot of his clothing. 17 A His clothing was put into garbage bags. As 18 far as I know, when we left, there was still the garbage bags 19 sitting there. If things were taken, again, it was by 20 accident. As soon as I can find them, I'll be glad to return 21 them. 22 Q Okay. The table and chairs in the kitchen, 23 why did you take those? 24 A They were put on my Bon-Ton charge. Being 25 that he -- in October, when he opened up his own account, he 43 I stopped paying any bills that had my name on it. Since I'm 2 the only one paying on the account and have been, and the 3 account is in my name, I took them. I needed them for the 4 kids. 5 Q So you're still paying for the table and 6 chairs? 7 A I'm paying for a lot. 8 Q He claims all working telephones were 9 removed from the house. Is that right? 10 A I thought I had left him one. I took the 11 ones that I had bought on my Lowe's charge. Again, he has 12 not paid for or given me any money towards those charge 13 cards. 14 Q So you took those items that you're paying 15 for? 16 A Correct. 17 Q The dining room, the chairs and the air 18 conditioner, are the chairs something acquired during the 19 marriage? 20 A Yes. 21 Q Why did you take those? 22 A Actually, I didn't want to. The movers took 23 them by accident. I refinished them. I didn't take the 24 table. I just ended up with the chairs, which really doesn't 25 do me any good. a... 44 _.1 1 Q You're willing to let him have those back? 2 A Yes. 3 Q What about the air conditioner? 4 A We had a couple of units. one was bought 5 for our son with the breathing problems with his SSI money 6 when he did receive SSI. Being that he still has lung 7 problems, I anticipate using it again for his benefit. S Q In the living room, videotapes, mostly the 9 children's tapes, why did you take those? 10 A Because I did not think he had a reason for 11 them, to have videotapes. Plus he's bought several other 12 ones since I've moved out that they watch. 13 Q The same would be true of the children's 14 toys? 15 A I took probably three quarters of them and 16 left plenty in the one toy cabinet. 17 Q Let's talk about the children's things; for 18 instance, the furnishings and the bedding from their rooms. 19 Is it your intention that those items be with whoever has 20 primary custody? 21 A Correct, because they are going to need 22 their beds. Q So, then, if you have custody, you'd like to 23 24 have the beds so the boys have something to sleep on; but if 25 your husband were to get custody, the beds could go with the 45 1 children? 2 A 'Being that I'm paying for them, again, on my 3 Bon-Ton charge, the mattresses -- I'm sure we could work 4 something out, but... 5 Q How about things like their dressers and 6 bookcases and the other things that belong to the children? 7 A The one dresser, my mother gave me, which 8 was hers, for our son Ben. The other dressers were mine that 9 my college roommate gave me when I lived in Philadelphia 10 years before I met Mike. 11 Q So they're not marital property? 12 A I would not consider them, no. 13 MR. ROBINSON: Your Honor, I would object to 14 distinguishing the different types of property in terms of 15 marital, premarital, mine and yours, only because, No. 1, 16 it's obvious that this witness does not understand the 17 concept of marital property. If it was obtained during the 18 marriage, it's marital property, and the Court can divide it 19 and distribute it how it sees fit, not just having to go to 20 her or him if he bought it. No. 2, as I told you, as I 21 opined in the beginning, I wasn't here to deal in terms of 22 marital property and distribution. I was here to deal in 23 terms of getting it back in the house for the kids' sake. 24 THE COURT: Well, I think your list listed 25 the ownership of them, so I think Mr. Andes has a right to 46 I examine the witness on those points. 2 BY MR. ANDES: 3 Q I think we were back in the living room. 4 The coffee table, why did you take that? 5 A My mother had given that to me. It was 6 hers. 7 Q The computer and the printer, why did you 8 take those? 9 A Because the kids mainly use it to play 10 games, and Mike has a laptop, and he has since bought another 11 desktop. So he has two computers, plus a new fax machine, 12 since I moved out. 13 Q So the children use it, and he really 14 doesn't need it, is what you're saying, is that right? 15 A No, because he mainly did all of his work on 16 his laptop. 17 Q The camcorder? 18 A I did take that. 19 Q You left a television? 20 A Yes. The one that my mother had given me I 21 left for him. 22 Q And a VCR? 23 A Yes, which I had purchased on a charge card. 24 Q Are you still paying for that? 25 A I'm heavily in debt with credit cards, yes. 47 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q The TV and stereo cabinet and the chair and hassock and the end tables, why did you take those? A The stereo cabinet and the TV cabinet was again purchased on my Lowe's charge. The chair and the hassock was a gift for both of us from my parents. Q The end tables? A I had bought them on a charge card. Q so those are things you're still paying for? A Right. Q The sofa, was that yours prior to the marriage? A That was mine probably ten years before I even kn ew him. Q The laundry room, the washer and dryer? A The washing machine my mother gave us, because our ot her one burned out. Q Did she give it to the two of you or to you? A Basi cally to me, because I was the only one who did laundr y. Q How about the dryer? A That was, again, something purchased on the Lowe's credit card. Q He c laims you left one towel and no bedding, except for the dog's two comforters. Is that true? A No. I left more than one towel, and I did LI 48 i 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 leave bedding for him. In fact, I left the comforter off my bed, which he's using now. Q He claims you took all financial records, all photos, all medical records. Is that true? A I suppose. They've just been in storage, and he had no -- did nothing with them, so... Q You mean they were just stored at the house? A They were just sitting in a closet. Q Has he asked for any of those? A No. Q Then he said you took all of the furniture from the master bedroom. A It was all given to me from my grandmother before I was married to him. Q In the garage you took the lawn mower and the outdoor furniture he claims. Is that true? A I took a lawn mower, but I left him the other lawn mower. Q Why did you take the lawn mower you took? A Because I bought it, again, on my charge card for like 20 bucks -- excuse me, it was $70.00. I got it damaged at Lowe's because I worked there. Q How about the outdoor furniture? A The same thing. I bought stuff on clearance. My manager gave me a good deal. I got stuff for 49 I like 5 bucks each. 2 MR. ANDES: I'm going to show you a document 3 that we'll mark Plaintiff's Exhibit 2. 4 (Plaintiff's Exhibit No. 2 was marked for 5 identification.) 6 BY MR. ANDES: 7 Q I'm going to show you a document we have 8 marked as Plaintiff's Exhibit No. 2. What is that? 9 A It's a list of the things that I took and 10 the things that I left, to the best of my knowledge. 11 Q Does that also have your notes as to the 12 origin and the ownership of some of those items? 13 A Correct. 14 Q I think you may have answered this, but does 15 that, in fact, include the items you left behind for your 16 husband? 17 A To the best of my knowledge, yes. 18 Q Now, your husband claims that all of these 19 things are in storage. Is it true that all of them are in 20 storage? 21 A Well, the big things like the furniture and 22 stuff, because I had nowhere to put them, and I needed a 23 place to put that temporarily until we could find our own 24 home. 25 Q Have you looked for a home? 50 1 A I'm starting to this week. 2 Q I think you said earlier the problem is you 3 have to get on your feet financially, correct? 4 A Correct. I receive no support from him. 5 Q What's your plan regarding -- are you going 6 to rent a house, an apartment, buy a house, what? 7 A I'm looking to rent a town house in the 8 district so the boys can still attend their same school and 9 be around their same friends. 10 Q What's your intention to do with the 11 furniture when you do that? 12 A Move it into that town house for them. 13 Q If the Court grants you custody of the 14 children, do you intend to keep the children's furniture and 15 toys and clothing primarily with you and share them with him 16 as he needs them when the boys go to visit with him; for 17 instance, the clothing? 18 A Right. 19 Q If he were awarded custody, would you be 20 willing to let him have the clothing and the toys and the 21 boys' basic furniture that they need, except for the items 22 that were gifts to you or owned by you prior to the marriage? 23 A Yes. 24 Q When is the custody conference, do you know? 25 A Next week. 51 1 MR. ANDES: Cross-examine. 2 CROSS-EXAMINATION 3 BY MR. ROBINSON: 4 Q Ms. Chambers, is your E-mail address 5 lynnkatc©yahoo.com? 6 A Correct. 7 Q Do you know who SAdsa3k©yahoo.com is? 8 A Yes. 9 Q Who's that? 10 A His name was Stanley Gerberich. 11 Q I'm reading from -- I'll show you what I'm 12 reading from. Does that E-mail message look familiar to you? 13 A Yes. 14 Q Is that something that you generated? 15 A Yes. 16 Q I'm just going to read one paragraph from 17 it. 18 MR. ANDES: Could we have the date of that, 19 Mr. Robinson, please? 20 BY MR. ROBINSON: 21 Q Could you give us the date? 22 A August 8th, 1999. 23 Q Were you having an affair with him? 24 A A short one prior to that. 25 Q And you were discussing with him in this 52 ti 1 E-mail the fact that you couldn't stand his wife lurking in 2 the background with regard to his relationship with you? 3 A I don't remember what it said. I didn't 4 have a chance to read the whole thing. But that was probably 5 true. 6 Q Okay. Now you are working full time, is 7 that correct? 8 A Correct. 9 Q Were you working full time at the time that 10 you were seeking support from your husband while you were 11 living together? 12 A No. I was working two part-time jobs. 13 Q At that time, you were seeking for him to 14 get out of the house, is that correct? 15 A I thought it would be best for the kids' 16 sake. 17 Q Did you think that the two of you -- that 18 the money that you had had enough to support another 19 household? 20 A It wasn't my concern if he could support 21 himself or not. I only made $7,500.00 last year. He made 22 close to 50. 23 Q So your answer is you didn't care whether or 24 not he could support himself? 25 A Well, it was obvious he could, considering 53 1 what he made. And the whole time I was seeking full-time 2 employment so I could take care of the kids and the house. 3 Q Did you ask your attorney to ask him to 4 leave the house? 5 A It was discussed. 6 MR. ROBINSON: I would like to have this 7 marked as Defendant's Exhibit No. 3. S (Defendant's Exhibit No. 3 was marked for 9 identification.) 10 BY MR. ROBINSON: 11 Q I'm going to show you what's been marked for 12 identification purposes as Defendant's Exhibit No. 3. Could 13 you briefly look at that and tell me if you've seen that 14 before? Well, can you tell me -- could you tell the judge 15 who the letter is from? 16 A Sam Andes -- no, you, Gerald Robinson. 17 Q To whom is it addressed? 18 A To Sam Andes. 19 MR. ANDES: Your Honor, I'm going to object 20 to any reference to the letter. It's hearsay. If Mr. 21 Robinson wants to testify, he'll have to take the stand and 22 testify. He can't testify indirectly by offering the letter 23 from him. That's hearsay. 24 MR. ROBINSON: I'm not offering it to prove 25 that. I'm offering it to prove that there were, in fact, 54 1 discussions about their inability to support two households. 2 This letter is only evidence to show that. I'm not offering 3 it to prove the facts of the matter asserted in that letter. 4 MR. ANDES: That's hearsay. 5 THE COURT: The objection is sustained. 6 MR. ROBINSON: Could I ask her if she ever 7 saw the letter? 8 THE COURT: All I'm really interested in is 9 whether there's a reasonable reason that these items are in 10 storage instead of back at the marital residence. I'm 11 curious as to how much the storage is costing, whether it's 12 cost effective, things like that. 13 BY MR. ROBINSON: 14 Q You took the bedding from the children's 15 room? 16 A Correct. 17 Q And where are they? 18 A In storage. 19 Q So you're not using them? 20 A Not at present, but I intend to. 21 Q Why did you take the children's bedding out 22 of the house and put them in storage? 23 A Because they need them because of living. 24 Q They're not using them now, though, are 25 they? 55 rti 1 1 A No. But where we ' re living now is only 2 temporary. 3 Q How long have you been there? 4 A Since February 10th. 5 Q Is that why you got the full-time job, so 6 you can find a place? 7 A It all kind of coincided together. I had 8 been looking fo r a full-time job. Yes. I needed a full-time 9 job to support myself and the children. 10 Q You didn't have a full-time job at the time 11 of the support conference, did you? 12 A No. 13 Q Now, you indicated about Mr. Chambers not 14 buying clothes and providing support, et cetera, since you I 15 moved out. Did you envision that he would have to make 16 extraordinary e xpenditures after you took all of those items 17 out of the hous e? 18 A I don't think giving me $20.00 for groceries 19 is extraordinar y. 20 Q Could you please answer the question. 21 A Can you repeat it, please. 22 Q After you took all of the items out of the 23 house, did you envision -- 24 MR. ANDES: I'm going to object to the form 25 of the question . That's not the testimony even of his 56 1 client. At first he said she took everything out of the 2 house. Then when we cross-examined him and he produced a 3 list, he finally acknowledged that there was more left than 4 just one towel and two dog blankets, so I object to the form 5 of the question. 6 THE COURT: Mr. Robinson? 7 BY MR. ROBINSON: 8 Q When you took the items out of the house, 9 did you envision that Mr. Chambers would have to replace any 10 of those items? 11 A Most of them belonged to me before I was 12 married to him, the major things; the bedroom set, the sofa. 13 Q Was the family using those items, 14 nonetheless, while you were together, meaning Mr. Chambers 15 and your children and you? Were you all using those items? I 16 A Correct. 17 Q After you took them out, wouldn't they have 18 to be replaced? 19 A Well, he's done nothing to replace them. I !'. 20 He's spending his money on new computers. 21 Q You said you placed his clothing in a 22 garbage bag. Why did you place his clothing into garbage I? n 23 bags? 24 A Because I moved him out of the master ! 25 bedroom, and there was no room for his clothes. I! i ! 57 1 Q Why didn't you leave them where they were? 2 A Because I saw no reason for him to come into 3 the room where I was sleeping. Our marriage was that bad. 4 We did not speak to each other. 5 THE COURT: I gather this is something that 6 was done before February 10th, the placement of the clothing 7 in garbage bags? 8 THE WITNESS: Correct. 9 BY MR. ROBINSON: 10 Q Now, the tables and chairs, where are they? 11 A The dining room table is at the residence, 12 along with another kitchen table and two chairs that I owned 13 prior to the marriage that I left for him. 14 Q What about the other table and the other 15 chairs? 16 A It's in my storage unit. 17 Q Are they being used at all? 18 A Not presently. 19 Q Were they used before that by Mr. Chambers, 20 yourself and the children? 21 A Correct. 22 Q You said you took the videotapes, the 23 children's videotapes. Why did you take the children's 24 videotapes? 25 A I did not think he would need to be watching F r' 58 -: M 1 Barney tapes. So, then, you didn't envision him having the 2 Q 3 children at the house? A Yes, but I wasn't really going into complete 4 5 detail as to what he would need or would not. I thought I 6 left him adequate things. I left everything he owned prior 7 to our marriage and then some. I left toys. I sent clothes 8 along on visitation. Q You testified that you bought a lot of these 9 10 things on this Lowe's account? 11 A Yes. Q Was that Lowe's account paid for from the 12 13 joint account that the two of you had? 14 A Yes. 15 Q Is that the same account that his check had 16 been deposited into? 17 A And mine, but there's about a $3,000.00 18 balance on the Lowe's card. 19 Q And a lot of these items that you indicated 20 you took because they were on the Lowe's account, they were 21 purchased five years ago, isn't that correct? 22 A There's always been a running balance on the 23 Lowe's card, because we've never been able to pay everything 24 off. He refused to pay any bills since October of last year 25 except anything in his -- he would only pay anything that was i I M 59 ?1 1 in his name only; no charge cards that were, you know, in 2 mine, even though it was for marital property. 3 Q But you admit, though, that in November, at 4 the -- no, in January, at the Domestic Relations conference, 5 he produced receipts of things that he paid for that were not 6 in his name only; in fact, he produced receipts that he paid 7 for your car, is that correct? 8 MR. ANDES: I object to that. That's just 9 simply not true. If he wants to ask her if she did, that's 10 fine. 11 MR. ROBINSON: I'm asking her that. 12 MR. ANDES: No, you asked her if she 13 admitted that he had done that. 14 BY MR. ROBINSON: 15 Q At the hearing, didn't he prove that he paid 16 for things related to the house that even were in your name 17 only? 18 A Like what? 19 Q Like your car note. 20 A The car was in both of our names. Both of 21 our vehicles at the time were in both names. 22 Q And the car that you were driving, was he 23 paying on that? 24 A We were both paying. Contrary to what he 25 says, my measly paychecks were going into the account, as 60 r\ iwr I well. 2 Q Is it your testimony that he did not produce 3 documentation at the January Domestic Relations conference 4 indicating that he was providing support for the whole 5 family? 6 A From the time he decided to open up his own 7 account and, q uote, take over the bills, he did not pay on 8 anything that was in my name only, and he barely paid 9 anything that was in the joint, like utilities. They were 10 still behind. If you remember correctly, I had called all 11 the utilities, and it was given how much in arrears we were, 12 which did not correspond with what he had said. 13 MR. ROBINSON: I have no further questions. 14 I'll bring tha t up with Mr. -- 15 THE COURT: We're out of time, basically. 16 Mr. Andes, do you have any further questions of this witness? 17 MR. ANDES: I do, Your Honor. 18 REDIRECT EXAMINATION 19 BY MR. ANDES: 20 Q Your husband claimed at the Domestic 21 Relations office that these bills were being paid, but did he 22 provide any documents to verify that they'd been paid? 23 A Ones that were inaccurate. 24 Q After that conference, did you, in fact, 25 verify whether the utility bills and the mortgage and the 61 rl?% 1 other payments had been made for the family residence? 2 A Correct, because I had called all of them 3 and gotten the balances. 4 MR. ROBINSON: I would object. It's hearsay 5 testimony. 6 THE COURT: I'm sorry. I'm going to end the 7 hearing, becau se I just am out of time. It's the end of the 8 day. Let's se e, there are Plaintiff's Exhibits 1, 2 and 3. 9 Any objection to the admission of those? 10 MR. ROBINSON: No, Your Honor. 11 THE COURT: All right. Plaintiff's Exhibits 12 1, 2 and 3 are admitted. we'll enter this order -- no, I'm 13 sorry. Exhibi t 3 was a letter that I think there's an 14 obection to. 15 MR. ANDES: Yes. Defendant's Exhibit 3 was 16 not admitted. 17 THE COURT: It was Plaintiff's Exhibits 1 18 and 2. 19 MR. ROBINSON: Your Honor, was one of the 20 exhibits that the Plaintiff produced the document that was a 21 communication between me and my client? 22 THE COURT: I have Plaintiff's Exhibit 1 was 23 an E-mail. 24 MR. ROBINSON: I would object to that. 25 THE COURT: The E-mail? 62 1 MR. ROBINSON: Yes. If you want, I can put 2 my witness on the witness stand to give -- 3 THE COURT: I have down a letter from you. 4 MR. ANDES: No, that's Defendant's 1 there, 5 Your Honor. Plaintiff's 1 was an E-mail that my client 6 testified about -- and without objection, I would point out -- 7 that had to do with the notification from Mr. Robinson that 8 he had prepared or was preparing a petition for exclusive 9 possession. The attorney-client privilege does not prevent 10 the testimony about or the admission of communications from 11 an attorney to a client. It only protects communications 12 from the client to the attorney. This is a communication 13 from Mr. Robinson in which he states that he is preparing a 14 petition for exclusive possession. 15 THE COURT: Plaintiff's Exhibit 1 is 16 admitted. 17 (Plaintiff's Exhibit No. 1 was admitted.) 18 THE COURT: Plaintiff's Exhibit 2 is a list 19 of items -- 20 MR. ANDES: That my client had prepared, 21 that the Plaintiff herself had prepared. 22 THE COURT: Is there any objection to the 23 admission of that item? 24 MR. ROBINSON: No, Your Honor. 25 THE COURT: Plaintiff's Exhibit 2 is 63 I admitted. 2 (Plaintiff's Exhibit No. 2 was admitted.) 3 THE COURT: One thing I was interested in is 4 how much the storage was costing. As far as I know, that's 5 never come out in evidence. 6 MR. ANDES: It's $90.00. 7 THE COURT: Ninety dollars a month? 8 MR. ANDES: Yes, and it's something that we 9 anticipate ending this month. 10 THE COURT: Mr. Robinson, are you in 11 agreement with that figure? 12 MR. ROBINSON: We have no understanding as 13 to that figure, because we had nothing to do with this. 14 THE COURT: So there's no stipulation as to 15 how much it's costing. We'll enter this order: 16 (The following order was entered by the 17 Court:) 18 "AND NOW, this 19th day of April, 2000, upon 19 consideration of Defendant's Petition for Special Relief, and 20 following a hearing on the issue of the requested return of 21 marital property to the marital residence, the record is 22 declared closed, and the matter is taken under advisement. 23 "The stenographer is requested to transcribe 24 the notes of testimony of this hearing." 25 THE COURT: I'll try to enter an order 64 -1 1 fairly promptly once the notes of testimony are transcribed. 2 (Court was adjourned.) 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 65 CERTIFICATION I hereby certify that the proceedings are contained fully and accurately in the notes taken by me on the above cause and that this is a correct transcript of same. (1, ? K/ Susan Rice Stoner Official Stenographer The foregoing record of the proceedings on the hearing of the within matter is hereby approved and directed to be filed. I? 7 1 (0, 266 Date 66 LYNN K. CHAMBERS. Plaintiff VS. MICHAEL E. CHAMBERS, Defendant IN TRIG COURT OF COMMON PLEAS 01' CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6904 CIVIL TERM IN RE: DEFENDANT'S PETITION FOR SPECIAL RELIEF BEFORE OLGR. J. ORDER OF COURT AND NOW, this 1- t4 day of May, 2000, upon consideration of Defendant's Petition for Special Relief, and following a hearing held on April 19, 2000, it is ordered and directed as follows: 1. Within 14 days of the date of this order. Plainti Tshall return to the marital residence at 223 South York Street, Mechanicsburg, Cumberland County, Pennsylvania, the following items which she removed from the premises on or about February 10, 2000: (1) any clothing of Defendant; (2) furniture, including mattresses and air- conditioner(s), from the children's bedrooms; (3) kitchen utensils; (4) cream-colored coffee table from the living room; (5) cream-colored striped club chair and ottoman from the living room; (6) four white dining room chairs; (7) Ml'D lawn mower; and (8) desktop computer and printer. 2. Nothing herein is intended to represent a distribution of marital property or a determination orally issue respecting marital or nonmarital property. i w2k) 5-15-a Q R Q) BY'rl-IE COURT, Samuel L. Andes, Esquire 525 North 12`x' Street Lemoyne, PA 17043 Attorney for Plaintiff Gerald S. Robinson, Esquire Robinson &. Geraldo, P.C. 4407 North Front Street P. 0. Box 5320 Harrisburg. PA 17110 Attorney for Defendant i i Arn LYNN K. CHAMBERS, ) Plaintiff 1 1 VS. 1 MICHAEL E. CHAMBERS, 1 Defendant 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-6904 CIVIL TERM IN DIVORCE PLAINTIFF'S PETITION FOR ECONOMIQ RELIEF AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, and petitions the Court for economic relief as follows: 1. The Petitioner herein is the Plaintiff, Lynn K. Chambers. The Respondent herein is the Defendant, Michael E. Chambers. COUNT I - ALIMONY 2. Plaintiff lacks sufficient property to provide for her reasonable needs in accordance with the standard of living of the parties established during the marriage. 3. Plaintiff is unable to support herself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 4. The Defendant is employed and enjoys a substantial income from which he is i able to contribute to the support and maintenance of Plaintiff and to pay her alimony in accordance with the Divorce Code of Pennsylvania. I WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding Plain- tiff from Defendant permanent alimony in such sums as are reasonable and adequate to support and maintain Plaintiff in the station of life to which she has become accustomed during the marriage. COUNT II - ALIMONY PENDENTE LITE 5. Plaintiff is without sufficient income to support and maintain herself during the pendency of this action. 6. Defendant enjoys a substantial income and is well able to contribute to the support and maintenance of Plaintiff during the course of this action. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her reasonable alimony pendente lite during the pendency of this action. COUNT III - COUNSEL FEES AND EXPENSES 7. Plaintiff is without sufficient funds to retain counsel to represent her in this matter. 8. Without competent counsel, Plaintiff cannot adequately prosecute her claims against Defendant and cannot adequately litigate her rights in this matter. 9. Defendant enjoys a substantial income and is well able to bear the expense of Plaintiff's attorney and the expenses of this litigation. 1) it WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay the legal fees and expenses incurred by Plaintiff in the litigation of this action. I verify that the statements made in this Petition for Economic Relief are true and correct. I understand that any false statements in this Petition are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). DATE: LYN K. CHAMBERS Samuel L. Andes Attorney for Plaintiff Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 3 LYNN K. CHAMBERS, IN THE COURT OF COMMON PLEAS OF Plaintiff/Pctitioncr CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO.99-67111 CIVILT'ERI11 MICHAEL E. CHAMBERS, IN DIVORCE Defendant/Respondent DR# 29,810 Pacses# 225102120 ORDER OF COURT AND NOW, this 30" day of June. 2000, upon consideration of the attached Petition for Alimony Pcndcntc Lite and/or counsel fees. it is hereby directed that the parties and their respective counsel appear before R.J. Shaddav on Aueusr J, 2000 nr 9:/J0 A.M. fora confcrcncc. at 13 N. Hanover SL. Carlisle. PA 17013. aRcr abich the confcrcncc officer may recommend drat an Order for Alimony Pcndcntc Litc be entered. YOU are further ordered to bring to the confcrcncc: (1) a Ins copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pa}' stubs for the preceding siN (6) months (3) the Inconne and Expense Statement attached to this order, completed as required by Rule 1910.11 U (1) verification of child care expenses (5) proof of medical coverage which you may have. or may have available to you IF you fail to appear for the conference or bring the required documents. the Court may issue a warrant for ourarrest. BY THE COURT. George E. Hoffer. President Judge Mail copies on Pctitioncr 6-30-00 to: < Respondent - / Samuel Andes. Esquire ' /.;tea Gerald Robinson. Esquire Date of Order: Junc 30. 2000 R. J. Shadday. Conference Officer YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE. PENNSYLVANIA 17013 (717) 217-3166 -:., ..,.;,, r LYNN K. CHAMBERS, Plaintiff ) 1 1 VS. ) 1 MICHAEL E. CHAMBERS, ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-6904 CIVIL TERM IN DIVORCE RIIATwiY i y^ f1EAR11V t] ON PETITION FOR ALIMONY PENDENTE LITE AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, and moves the Court to assign this matter to the Domestic Relations Office to conduct a conference and make a recommendation for an award of alimony pendente lite in this matter. Dated: .j-? l? Samue L. An s Attorney for Plaintiff Supreme Court ID 17225 525 North 12`h Street Lemoyne, PA 17043 (717) 761-5361 'ISM i i LYNN K. CHAMBERS, 1 Plaintiff 1 1 1 VS. 1 1 MICHAEL E. CHAMBERS, 1 Defendant 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-6904 CIVIL TERM IN DIVORCE PLAINTIFF'S PETITION FOR ECONOMIC RELIEF AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, and petitions the Court for economic relief as follows: 1. The Petitioner herein is the Plaintiff, Lynn K. Chambers. The Respondent herein is the Defendant, Michael E. Chambers. COUNT I - ALIMONY 2. Plaintiff lacks sufficient property to provide for her reasonable needs in accordance with the standard of living of the parties established during the marriage. 3. Plaintiff is unable to support herself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 4. The Defendant is employed and enjoys a substantial income from which he is able to contribute to the support and maintenance of Plaintiff and to pay her alimony in accordance with the Divorce Code of Pennsylvania. i , I I i 1 WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding Plain- tiff from Defendant permanent alimony in such sums as are reasonable and adequate to support and maintain Plaintiff in the station of life to which she has become accustomed during the marriage. COUNT II - ALIMONY PENDENTE LITE 5. Plaintiff is without sufficient income to support and maintain herself during the pendency of this action. 6. Defendant enjoys a substantial income and is well able to contribute to the support and maintenance of Plaintiff during the course of this action. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her reasonable alimony pendente lite during the pendency of this action. COUNT III - COUNSEL FEES AND EXPENSES 7. Plaintiff is without sufficient funds to retain counsel to represent her in this matter. 8. Without competent counsel, Plaintiff cannot adequately prosecute her claims against Defendant and cannot adequately litigate her rights in this matter. 9. Defendant enjoys a substantial income and is well able to bear the expense of Plaintiff's attorney and the expenses of this litigation. I WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay the legal fees and expenses incurred by Plaintiff in the litigation of this action. I verify that the statements made in this Petition for Economic Relief are true and correct. I understand that any false statements in this Petition are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). DATE: LYN K. CHAMBERS ,ter s v??? Samuel L. Andes Attorney for Plaintiff Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 101 MUMMA ROAD, SUITE 100, LEMOVNE, PENNSYLVANIA A0IJ . LYNN K. CHAMBERS, Plaintiff V. MICHAEL E. CHAMBERS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE : NO. 99-6904 CIVIL TERM PRAECIPE FOR WITHDRAWAL OF APPEARANCE Please withdraw my appearance on behalf of the Plaintiff, Lynn K. Chambers. Respectfully submitted, Dated: September 21 , 2000 Sa ue L. An , Esquire Counsel for Plaintiff PA I.D. # 0 525 North 12'h Street P.O. Box 168 Lemoyne PA 17043 (717) 761-5361 PRAECIPE FOR ENTRY OF APPEARANCE Please enter my appearance on behalf of the Plaintiff, Lynn K. Chambers. Respectfully submitted, GATES & ASSOCIATES, P.C. Dated: September oCJ?12000 , k Susan Kay Can squire Cow. for PI 'nti PA I.D. # 64998 1013 Mumma Road, Suite 100 Lemoyne, PA 17043 (717) 731-9600 ?'` :- _: °s>« _? ` ??J ?? _ (? I-j V: _!i ' 1. ;? Cl . . J ORDER(NOTICE TO WITHHOLD INCOME FOR SUPPORT ?,e? M 7_'-Cr9Dy 4'-/ML OOriginal Order/Nulicr Stale eommomv alf? h of Pennsylvania ,6 0 Arm- drd Order/Notice Co./City/DiSL Of CUMBERLAND C n??. ri74 .??` Dale of Order/Notice 01/31/01 V/` 9 of v 7 ?T Tormin.na Order/Nulicc Court/Case Number (See Addendum for case summary) EmployerAVithholder's Federal EIN Numlxer OAKTREE CASEWORK INC EmplnycdlVithholder'S Name 335 NOVA DR EmplayrrAVithholder's Address GREENCASTLE PA 17225-1545 I RE: CIiWsIBERS, MICHAEL E. Employee/Obligor's Namv (Last, Firti, N10 I 168-48-3337 I Engdnyer/O6lignrs Social Sveurity Nuolvr 1 3068100412 En loyve/Ohligor', Case Wonti0er (See Addendum for plaintiff names associated with Ca5e5 on attachment) Custodial Parente Nam,- (Last. First, Alll 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, 252.813 per month in current support $ 1so.00 per month in past-due support Arrears 12 weeks or greater? Dyes ® no $ o. oo per month in medical support $ 0, 00 per month for genetic test costs S per month in other (specify) for a total of $ 1, 402.88 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: $ 323.74 per weekly pay period. $ 647.48 per biweekly pay period (every two weeks). $ 701.44 per semimonthly pay period (twice a month). $ 1 . 402.88 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See ;#9 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106.9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: DRO: RJ Shillay 1: ?' 't <•., xc: defen9ant Y Date of Order: Pehn,ry 7 7m1 Eirorl E. Guiio JUDGE Form EN-028 Service Type M oun.,:0?10 .0154 WorkerlD $IATT I Tiinion Oar: I to ?)" 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 lase 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 helow. 2. Combining Payments: You can combine withheld amounts from more than on(! 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 ennployee/obligor. 3.' -Reporting-the-Paydate/Date-of-Withholdimg-You must report the payd;ve/date of withholding when sendingilne paynnent-The- paydate/date of withholding-is-the date-on which-amount was withheld from the employees wages: You nest 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 innplennent the withholding order and forward the support payments. -1.' Ennployee/Obligor with Multiple Support Holdings: If there is nnore than one Order/Notice to Withhold Income for Support against this employeeJobligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you nest follow the law of the state of employee's/obligor's principal place of employnnent. You must honor all Orders/Notices to the greatest extent possible. (See 89 below) i. Termination Notification: You must promptly notify the Requesting Agency when the ennployee/obligor is no longer working for you. Please provide the information requested and return a copy of Ibis Order/Notice to the Agency identified below. WITHHOLDER'S ID: 2515823980 EMPLOYEE'S/OBLIGOR'S NAME: CHAMBERS. MICHAEL E. EMPLOYEE'S CASE IDENTIFIER: 3068100412 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lmnp 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 Slate 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 employee/ohligor 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 0 S U.S.C. §1673 (b)1; or 2) the amounts allowed by the Slate 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 staking mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 10. 'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Requesting Agency: DOMESTIC RELATIONS SECTION P.O. BOX 320 CARLISLE PA 17013 Service Type M If you or your ernployee/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 oar ao.: or, o 013+ 1 4aflon Dac: 1.1131 00 Form EN-028 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: CHAMBERS, MICHAEL E. i PACSES Case Numher 225102420 ?;,1 f;516 Plaintiff Name LYNN K. CHAMBERS Docket Attachment Amount 99-6904 CIVIL$ 187.13 Child(ren)'s Nante(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. PAGES Case Number Plaintiff Name Dorket Attachment Amount $ 0.00 Child(ren)'s Naple(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. PAGES Case Number Plaintiff Name Docket Attachment Amount S 0.00 Child(ren)'s Name(s): DOB PACSES Case Numher 94 3 10 16 9 0/Z(/ Plaintiff Name LYNN K. CHAMBERS Docket Attachment Amount 00976 S 1999 S 1,215.75 Clidd(ren)'s Name(s): DOB BENJAMIN ALDEN CHAMBERS 08/12/92 ANDREW MORGAN CHAMBERS 12/19/94 ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee /obligor's enlploynlent. PAGES Case Number Plaintiff Nanip Dorket Attachment Amount S 0.00 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. PACSES Case Number Plaintiff Name Docket Attachment Amount S 0.00 Child(ren)'s Naple(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 employees/obligor's employment. through the employee's/obligor's enlploynlent. Addendum Form EN-028 Service Type M Worker ID $IATT 0%13 %a:On; nAlir I,niraYon n.tlr: C.JVUn tA_- C. _il ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State commonwealth of Pennsylvania Mr. 99-6904 CIVIL Co./City/Dist. of CUMBERLAND PPLSES 225102420 Date of Order/Notice 02/15/01 DR 29810 Court/Case Number (See Addendum for case summary) EmployerAVilhhnlder's Fedoral EIN Numlxrr OAKTREE CASEWORK INC 6nplnycdwilltholder's Nam, 335 NOVA DR EmployerAVithholder's Address GREENCASTLE PA 17225-1545 O Original Order/Notice O Amended Order/Notice Mr. 976 S 1999 Q Terminal,. Order/Noon, PACSES 943101690 DR 29163 IRE: CHAMBERS, MICHAEL E. Employee/Obligor'. Name (Lash Firsl, X111 168-48-3337 Emplnyee!Obligor's Social Security Numlwr 3068100412 1 Employee/Obligor's Caw Identifier (See Addendum for plaintiff names associated with easeson altachmeno Cu,todial Parent's Name (Las, 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, 252. 88 per month in current support $ 150. oD per month in past-due support Arrears 12 weeks or greater? (Dyes O no $ o. oo per month in medical support $ 0.00 per month for genetic test costs S per month in other (specify) for a total of S 1, 402.88 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: $ 323.74 per weekly pay period. $ 647.48 per biweekly pay period (every two weeks). $ 701.44 per semimonthly pay period (twice a month). $ 1.402. s8 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 i needed (See #9 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676.9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PA CSES MEMBER 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. c'+ BY THE COURT: DRO: RJ Sha99ay --: xc: defenlant 2 . 3./ / Date of Order: Febnory 16, 2001 EM,rl E. Gui•9o JUDGE Form EN-028 Service Type M D to au0n70-013? Worker lD $IATT I Wiulion Doc 193Im0 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.my 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 ansounts front 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 payciate/date of withholding when sending-thepayment.-The- paydateJdate of-withholding-is the. date onwhich-amount was withheld front the, employee's wages: You mLISI 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.' Enhployee/Obligor with Multiple Support Holdings: If there is more than one Order/Noice to Withhold Income for Support against this enhployee./obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the late of the state of employee's/obligor's principal place of employment. You most hortorall Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee%bligor 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: 2515823980 EMPLOYEE'S/OBLIGOR'S NAME: CHAMBERS. MICHAEL E. EMPLOYEE'S CASE IDENTIFIER: 3068100412 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sunh Payments: You may be required to report and withhold front lump suns payments such as bonuses, commissions, or severance pay. If you have any questions about lump stmt paynents, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notire directs, you are liable for both the accumulated anhount 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 employee/obligor front employment, refusing to employ, or taking disciplinary action against any employeelobllgor because of a support withholding. Pennsylvania State late 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 Nledicare 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: DONIESTIC RELATIONS SECTION P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact kVAGE ATTACHMENT UNIT by telephone at (717) 240.6225 or by FAX at (717) 240.6248 or by Internet p Service Type M Page 2 of 2 osm No.: ao-,ta 134 1"'iocan D " ua 1 ua Form EN-028 Worker ID $IATT If ADDENDUM Summarv of Cases on Attachment Defendant/Obligor: CHAMBERS, MICHAEL E. PACSES Case Number 225102420 PACSES Case Nunther 943101690 Plaintiff Name Plaintiff Name LYNN K. CHAMBERS LYNN K. CHAMBERS Docket Atta chment Amount Docket Attachment Amount 99-6904 CIVILS 237.13 00976 S 1999 $ 1,165.75 Child(ren)'s Name(s): DOB Child(re0's Nanhe•(s): DOB BENJAMIN ALDEN CHAMBERS 08/12/92 ANDREW MORGAN CHAMBERS 12/19/94 ? 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 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 employees/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 employees/obligor's employment. PACSES Cane Number Plaintiff Name Docket Attachment Amount S 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 Docker Attachment Amount S 0.00 Child(ren)'; 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 enhployee's/abligor's employment. through the enpluye.eWobligor's employment. Addendum Form EN-028 Service Type M WorkerlD $IATT ohm >.,.: nn; n.m s+ ly,iminn Uer: rlU V,ID In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION LYNN K. CHAMBERS ) Docket Number 99-6904 CIVIL Plaintiff ) VS. ) PACSES Case Number 225102420 /D29810 MICHAEL E. CHAMBERS ) Defendant ) Other State ID Number CONSENT ORDER AND NOW, to wit, on this 15TH DAY OF MARCH, 2001 IT IS HEREBY ORDERED that the support order in this case be Q Vacated or QSuspended or ®Terminated without prejudice or Q Terminated and Vacated, effective JANUARY 1, 2001 , due to: PARTIES' AGREEMENT AND CHANGE IN CUSTODY OF THE PARTIES' TWO CHILDREN. THERE IS A BALANCE DUE OF $338.95 AND IS TO BE PAID OF AT $50.00 PER MONTH. DRO: RJ Shvlday xc: plaintiff Defendant Siuan Cantello, Esquire Gerald S. Robinson, Esquire F, Service Type M BY THE CO Edwnrd E. Guido JUDGE `larch 16, 2001 Date Form OE-503 Worker ID 21005 - tJ C. Cl. L :! ? ORDER/NOTICE TO WITH,VOLD INCOME FOR SUPPORT ?fLJ -G rvy C irr? Slate Commonwealth of Pennsylvania 191kiASpFS c Z?/GoZ?{??% 0 Original Order/Notice CO./City/DISC. Of CUMBERLAND J•? ol_9 /(J O Amomded Order/Notice Date of Order/Notice 03/15/01 ?? /?7C x ( t Terminate Ortler/Notice Pr?LrS?S /?? ; Court/Case Number (See Addendum for case summary) O c Employer/wilhholdcr's Federal EIN Number OAKTREE CASEWORK INC EmployerMrithholder's Name 335 NOVA DR EmployerMrilhholder's Address GREENCASTLE PA 17225-1545 )RE:CHAMBERS, MICHAEL E I Employee/Obligor's Name (Lail, Firm„ \tl) 168-48-3337 Employee/Obligor's Social Security Numbn,r 1 3068100412 Employee/Obligor's Case Identifier (See Addendum for plaintiNnames associated with cases on attachment) Custodial Parent's Name (Last, Firsl, MO 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, 065.75 per month in current support $ 15o. oo per month in past-due support Arrears 12 weeks or greater? Q yes Q no $ 0.00 per month in medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ 1, 215.75 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: $ 280.56 per weekly pay period. $ 561, 12 per biweekly pay period (every two weeks). $ 607.88 per semimonthly pay period (twice a month). $ 1.215 .75 per monthly pay period. REINUTTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the the allowable amount. The total withheld amount, and your fee, cannot exceed 55% Of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676.9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PA CSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. DRO: RJ Shadiay =,?L BY THE COURT: xc: defeniint - ^- Date of Order: ?ltrch 16, 2001 &M, rd E. Guido JUDGE Form EN-028 Service Type M ostn rv,,.: as;aols? Worker ID $IATT [.nirnian m,a iLi VOa 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 wider 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/obligors 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.' -Reponing-thr Paydate/Date-of-Withholding-Yntt-must report the-paydate/date of withholdingAvhen sending tile. payment-The- paydate/date of withholding isihedate m%%•hichamount%vts-withheld-from-the-entployee's-wager. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the lime periods within which you must implement the withholding order and forward the support payments. 4.' Entployee/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 Ifntfts, 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 die information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S ID: 2515823980 EMPLOYEE'S/OBLIGOR'S NAME: CHAMBERS. MICHAEL E. EMPLOYEE'S CASE IDENTIFIER: 3068100412 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/abligor's income and other penalties set by Pennsylvania State law. Pennsylvania Stale 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 entployee%bligor from employment, refusing to employ, or taking disciplinary action against any employee%bligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the Slate fn 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: AOMESTIC RELATIONS SECTION 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 0 Page 2 of 2 oztn no.: aerom s+ RnGntan nor. WJt/ao Form EN-028 WorkerlD $IATT N li !1 Y ADDENDUM Summary of Cases on Attachment Defendant/Obligor: CHAMBERS, MICHAEL E. PACSES Case Number 225102420 ;1 ?J /b PACSES Case Number 943101690/Jf?/(( Plaintiff Nance Plaintiff Name LYNN K. CHAMBERS LYNN K. CHAMBERS Dorket Anirllment Amount Docket Attarltment Amount 99-6904 CIVIL$ 50.00 00976 S 1999 $ 1,165.75 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB BENJAMIN ALDEN CHAMBERS 08/12/92 ANDREW MORGAN CHAMBERS 12/19/94 ? 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/ohligor's employment. PACSES Case Number Plaintiff Name Dorket Attachment Amount $ 0.00 Childhen)'s Name(s): DOB ?If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the entployee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(reo)'s Name(s): DOB ?If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employees/obligor's employment. PACSES Case Number Plaintiff Name Docket Attarlinient Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) ? If cltecked, 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 Worker ID $IATT Service Type m 0%111 so.: uwo.ms+ t.pir+rnn 0+14 14131,100 =?51?JLIJO gt13l1)1VIG ?? ?Cl f t( ( ?? 01 ORDER/NOTICETO WITHHOLD INCOME FORSUPPORTO //I C, 0 Original Onler/Notit)e II State Commonwealth ylvania QAmendud Onler/Notice Co./City/DiSt. of CUMBERLAND Date of Order/Notice 04/30/01 O Terminate Order/Notice Court/Case Number (See Addendum for case summary) EmployLAVithlwlder's Federal EIN Numlxr OAKTREE CASEWORK INC EmplayerAVilhholder's Name 335 NOVA DR EmploycdWithlmlder's Address GREENCASTLE PA 17225-1545 1 RE: CFLV4BERS, MICEIAEL E. 1 Employer/Obligor's Name (Lail, First, N10 1 168-48-3337 1 Employee/OLligari tincial Security Numlw 1 3068100412 Emplnyer/Obligor's Case Idenlifer (See Addendum far plaintiff names associated with cases on atrachmen0 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, 092.00 per month in current support $ 150. oo per month in past-due support Arrears 12 weeks or greater? ®Yes O no $ o. oo per month in medical support $ 0, 00 per month for genetic test costs $ per month in other (specify) for a total of $ 1, 242.00 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: $ 286.62 per weekly pay period. $ 573.23 per biweekly pay period (every two weeks). $ 621, oo per semimonthly pay period (twice a month). $ 1. 242, oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. DRD: RJ SK0,- ay r k' 1i xc: deferdenr Dale of Order: ?Lac 8, 2001 Service Type M BY THE COURT: E-N sd E. Gtlldo JUDGE Form EN-028 0118 r.o.: 09:0.013+ WorkerlD $ZATT r.pbn:n? D+ic tvn,ron r 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 front 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/Doteof-Withholding-You must report the paydate/datrofseithholdingwhen-lending thrpayment-The- paydate/date-ofwithholding-is the-date--oft-which-amount waswithheld I'mm the-employeeswages: You must comply with the law of the state of the employee's/obligors principal place of employment with respect to the time periods within which you must implement tine 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 entployee%obligar and your ere unable to hanar all support Order/Notices due to Federal or State withholding Ifm its, you must follow the law of the state of employee's/obligor's principal place of entp!oyment. You must honor all Orders/Notices to the greatest extent possible. (See K9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide tine information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S ID: 2515823980 EMPLOYEE'S/OBLIGOR'S NANIE: CHAMBERS, MICHAEL E. EMPLOYEE'S CASE IDENTIFIER: 3068100412 DATE OF SEPARATION: LAST KNOWN HONE 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 front 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 tine determined under State law for discharging an employeeJobligor front employment, refusing to employ, or taking disciplinary action against any employee/abligor 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. 41673 (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: AOMESTIC RELATIONS SECTION P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by Internet Service Type M Page 2 of 2 our \n.: 0q,0.015+ Lptrnign onr. 'V31,00 Form EN-028 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: CHAMBERS, MICHAEL E. PACSES Case Number 225102420 PAGES Case Number 943101690 Plaintiff Name Plaintiff Name LYNN K. CHAMBERS LYNN K. CHAMBERS Docket Atta chment Amount Docket Attachment Amount 99-6904 CIVIL$ 50.00 00976 S 1999 S 1,192.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB BENJAMIN ALDEN CHAMBERS 00/12/92 ANDREW MORGAN CHAMBERS 12/19/94 ? 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 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Nance Docket Attachment Amount S 0.00 Child(ren)'s Name(s): DOB ?if checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) ? 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 0516 No.: 09704134 Worker ID $IATT t,piwl.. De, 12131/00 LYNN K. CHAMBERS, Plaintiff V. BY THE COURT, MICHAEL E. CHAMBERS, Defendant IN THE' COURT OP COMMON PLEAS OF CUM13ERLAND COUNTY, PENNSYLVANIA CIVIL AC'I'ION - LAW NO. 99-6904 CIVIL TERM ORDER OF COURT AND NOW, this 20°i day of August, 2001, upon consideration of Plaintiff's Petition for Contempt, a hearing is scheduled for Monday, October 15, 2001, at 1030 a.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. Lynn K. Chambers 124 W. Portland Street Apt. 28 Mechanicsburg, PA 17055 Plaintiff, Pro Se Gerald S. Robinson, Esq. 4407 North Front Street Harrisburg, PA 17110 Attorney for Defendant Michael E. Chambers 223 S. York Street Mechanicsburg, PA 17055 J. csley Olcr, r_ J. y a 62 00 :rc e 0 UU: pri IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY OF LYNN K. CHAMBERS Plaintiff. Vs. PENNSYLVANIA NO. 99-6904 MICHAEL E. CHAMBERS CIVIL LAW-ACTION IN LAW Defendant. CONTEMPT ORDER OF THE COURT AND NOW, this day of upon consideration of the attached Petition for Contempt, it is hereby directed that the Defendant comply with the property agreement signed by both the plaintiff and defendant. Defendant is ordered to provide plaintiff payment of $245.62 ---$234.62 (the second payment due) plus $11.00 for postage fees incurred with the delivery of petitions. Defendant has five (5) days fi•orn the receipt of this order to comply. In regards to the last 1!3 payment of $234.62 due on September 14, 2001-- Defendant is ordered to pay Plaintiff by the stated date. If payment is not received on or before September 14, 2001, interest will be attached to the owed amount at a daihv rate of 20%, compounded daily. Defendant will also be responsible for all fitture legal and miscellaneous costs incurred by the Plaintiff, for collection of these debts. Defendant will also be held further in contempt, with further legal action being taken against him and his property. FOR THE COURT, BY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY OF PENNSYLVANIA LYNN K. CHAMBERS Plaintiff, Vs. MICHAEL E. CHAMBERS Defendant. NO. 99-6904 CIVIL LAW-ACTION IN LAW CONTEMPT You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Petition and notice are served by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgement may be entered against you by the court without further notice for any money claimed in the petition or for any Plaintiff. You may lose money or property or rights e important to relief you requested by the 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 Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 1.800-990-9108 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY OF PENNSYLVANIA LYNN K. CHAMBERS re: 99-6904 DIVORCE Plaintiff, Vs. MICHAEL E. CHAMBERS CIVIL LAW-ACTION IN LAW Defendant. CONTEMPT PETITION FOR CONTEMPT 1. Plaintiff, Lynn K. Chambers, is an adult individual residing at 124 W. Portland Street, Apt. 28, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant, Michael E. Chambers, is an adult individual residing at 223 S. York Street, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant were married June 1994, and were subsequently divorced April 26, 2001. NO. 99-6904. Cumberland Counnv (EXHIBIT A). 4. As part of the divorce, a Property Settlement Agreement was drafted, and signed by both plaintiff and defendant, on March 28`h 2001. (EXHIBIT B). 5. The Marital Property Settlement Agreement was filed on April 19`h 2001, in the Cumberland County Office of the Prothonotary. The terms of the Agreement were to be incorporated as part of the divorce decree. 6. Section 10 (d) of the Marital Property Agreement states that Husband (defendant) shall pay Wife (plaintiff) the sum of 5703.88, for his reimbursement of marital debt. Husband (defendant) agreed to pay the $703.88 in three installments, equaling $234.62 each. The first 1/3 of his agreed portion at the signing of the agreement, (March 28, 2001), the second 1/3, due ninety (90) days from the signing of the Agreement (June 26"i, 2001), and the remaining 1/3 due one-hundred eighty (180) days from the signing of the Agreement, (September 14"i, 2001). 8. Husband paid first installment over one month late. Despite numerous demands, Husband (defendant) refuses to pay the second installment of the 1/3 due. The sum equaling $234.62 was owed to Plaintiff on June 26, 2001. As of today's date, it is now over 30 days past due. 10. Defendant earns approximately $48,000 - $50,000 yearly, plus bonuses. Defendant has the financial ability to meet these small payments. 11. Plaintiff has physical custody of the two minor children derived from the marriage, the money owed was ear-marked for summer daycare, thus the failure to pay has created financial stress for the plaintiff. WHEREFORE, due to Plaintiffs financial burden, Plaintiff demands a CONTEMPT judgement against the Defendant in the sum of $234.00 plus all costs incurred to remedy the above petition. Plaintiff is also respectfully asking the court to ensure the defendant pays the final 1/3 payment by the scheduled date of September 14'h, 2001, by court order. Respectfully'ubmitted o Au ustl4, 2001, By: -A?111?ot LYNN K. CHAMBERS 124 W. Portland Street Apt. 28 Mechanicsburg, PA 17055 7/x•69/ -S6"?,7 VERIFICATION I VERIFY THAT THE STATEMENT MADE IN THIS PETITION ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE PENALTIES SUBJECT TgWORN FALSIFOICATIOti SecTtion 4904, TIES. EATING TO L K. CHAMBERS, PLAINTIFF EXHIBIT A Chambers vs. Chambers IN THE COURT OF COMMON PLEAS OFCUMBERLAND COUNTY STATE OF PEN NA. Lynn K_ rtnmhwrs, Plaintiff VERSUS Michael E. Chambers, Defendant No. 99-6904 DECREE IN DIVORCE AND NOW. April 26, , 2001 IT IS ORDERED AND DECREED THAT Lynn K. Chambers PLAINTIFF, - AND Michael E. Chambers , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF T*- F- FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED: NOW BY THE COURT: /s/ J. Wesley Oler, Jr. ATTEST: J. (I PROTHONOTARY CERTIFIED COPY ISSUED APRIL 26, 2001 EXHIBIT B Chambers es. Chambers MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT, made this day of 2001, by and between MICHAEL E. CHAMBERS. of Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred to as "Husband." and LYNN K.CHAIIBERS, of Mechanicsburg, Cumberland County, Pennsylvania. hereinafter referred to as "Wife." WITNESSETH: WHEREAS. Husband and Wife were lawfully marred in June 4.1994: and WHEREAS, differences have arisen between Husband and Wife in consequence of which they intend to live separate and apart of each other: and WHEREAS, Husband and Wife have made a full disclosure of their t sets to each other, and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations with respect to each other, including the disposition and distribution of property rights and c-; J interests between them. NOW. THEREFORE, in consideration of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the Parties hereto. Wife and I lusband, each intending to be legally bound hereby, covenant and agree as follows: 1. ADVICE OF COUNSEL. The provisions of this Agreement and their legal effect have been fully explained to the Parties by their respective counsel, Gerald S. Robinson, Esquire, for Husband. and Susan K. Candiello. Esquire for Wife. The Parties acknowledge that they have received independent legal advice from counsel of their selection and that they fully understand the facts and have been informed as to their legal rights and obligations and they acknowledge and accept that this Agreement is, in the circumstances, fair and equitable and that it is being entered into freely and voluntarily, after having received such advice and with such knowledge and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. 2. SEPARATION. It shall be lawful for each Party at all times hereafter to continue to live separate and apart from the other Party at such places as he or she may from time to time choose or deem fit. The foregoing provisions shall not be taken as an admission on the part of either Party of the lawfulness or unlawfulness of the causes leading to their living apart. 3. AGREEMENT TO BE NCORPORATED N DIVORCE DECREE. The Parties agree that the terms of this Agreement shall be incorporated into any Divorce Decree, which may be entered with respect to them at the request of either Party. The Parties agree that the Court of Common Pleas of Dauphin County, Pennsylvania, shall retain continuing jurisdiction over the Parties and the Agreement for the purposes of enforcement of any of the provisions thereof. The Parties agree that unless otherwise specifically provided herein, if a Decree is entered divorcing the Parties, although this Agreement shall be incorporated into said Decree, this Agreement shall not meme with. but shall continue in full force and effect after such time as a Final Decree in Divorce may be entered with respect to the Parties and may be enforced in an action independent of the Divorce Decree. The Parties agree and it is the intent of each of them that even though this Agreement may be enforced either under the provisions of the Pennsylvania Divorce Code or in an action independent of the Divorce Decree in accordance with Section 3502 of the Pennsylvania Divorce Code, the provisions of this Agreement regarding the disposition of existing property rights and interests between the Parties, alimony, alimony pendente lite, counsel fees and expenses shall not be subject to modification by any Court. 4. SUBSEQUENT DIVORCE. The Parties hereby acknowledge and express their agreement that the marriage is irretrievably broken, and the Parties agree to cooperate in any necessary way to obtain a mutual consent, no-fault divorce, pursuant to Section 3301(c) of the Pennsylvania Divorce Code. 5. INTERFERENCE. 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 or attempt to molest the other. nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 6. WIFE'S DEBTS. Wife represents and warrants to Husband that she will not contract or incur any debt or liability for which Husband or his estate might be responsible and she shall indemnify and save harmless Husband from any and all claims or demands made against him by reason of debts or obligations incurred by her. HUSBAND'S DEBTS. Husband represents and wan-ants to Wife that he will not contract or incur any debts or liability for which Wife or her estate might be responsible, and he shall indemnify and save harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. S. MUTUAL RELEASE. Subject to the provisions of this Agreement, each Party has released and dischareed, and by this Agreement, does for himself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all causes of action, claims, rights, or demands, whatsoever in law or equity, which either of the Parties had or now has against the other, except for any and all causes of action for divorce and except for any and all causes of action for breach of any provisions of this Agreement. 9. DISCLOSURE OF PROPERTY. Husband and Wife acknowledge and agree that they have made a full and complete disclosure to the other of all information pertaining to the Parties' separate and marital property owned, possessed and/or controlled by the other at the time of the separation of the Parties and, further, that the Husband and Wife voluntarily and intelligently agree to waive any rights which they may have to receive an Inventory and Appraisement of all property owned or possessed by them, either jointly or individually, at the time of the delivery of this Agreement or of the commencement of any action of divorce. 10. EQUITABLE DISTRIBUTION. 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 that have been taken into consideration by the Parties. a. REAL PROPERTY. Husband and Wife agree to list the marital home for sale with a realtor at S 120,000.00. The parties agree that the minimal acceptable price is $I 10,000.00. The proceeds from the sale of the real estate shall be divided equally between the patties, subject to Frank Chamber's claim for 520,000.00. which is being disputed by Wife. The proceeds from the sale are to be held in escrow pending the determination of Frank Chamber's claim. The parties agree to aid a real estate agent in any way possible to list the property for sale as soon as possible. b. PERSONAL PROPERTY. The parties have divided between themselves, to their mutual satisfaction, all remaining items of tangible, personal property previously used by them in the marital home. Neither Party shall make any claim to any such item of tangible personal property; whether said items are marital property or said items are separate personal property of either Party. C. CHECKING AND SAVINGS ACCOUNTS. With regard to checking and savings accounts, the Parties agree to close theirjoint accounts and divide the balance equally between them. 6 d. MARITAL DEBTS. The Parties acknowledge that they, vet debt during the marriage. Husband agrees to pav S 1. to Wife which Ttes his reimbursement of childcare expenses. healthcare expenses, and pre-marital debt the parties incurred prior to the execution of this agreement, while Wife agrees to pay the remainder of the debts. Husband will pay one third (1/3) of his agreed portion at the signing of the agreement, another one third (1/3) ninety(90) days after the signing of the agreement, and the remaining one third (1/3) one hundred eighty (180) days after the signing of the agreement. The Domestic Relations arrearage shall be paid consistent with the Domestic Relations Order with payment in full upon the sale of the marital residence. Husband agrees to assume the liability for half of the debt to Social Security Administration, A-5 IA) at- / dl -)Wz- A60 de- 6 t lc . T 061 C. Both Parties hereby accept the provisions of this Agreement with respect to 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 the equitable distribution of their property by any Court of competent jurisdiction pursuant to Section 3502 of the Divorce Code or any other laws. Husband and Wife voluntarily and intelligently waive and relinquish any rights to seek a Court-Ordered determination and distribution of marital property, but nothing herein shall constitute a waiver by either Party of any rights to seek their relief of any Court for the purpose of enforcing the provisions of this Agreement. 11. CHILD CUSTODYIViSITATION. The Parties shall have shared legal custody of the Parties' minor children, Benjamin Chambers, bom August 12, 1992, and Andrew Chambers, bom December 19, 1994. Wife shall have primary physical custody of the children subject to Husband's right to partial custody as follows: a. Beginning Friday, January 26, 2001, Husband shall have custody of the minor children on alternate weekends from Friday after work (6:00 PM) until Sunday evening at 7:00 PM: b. Husband shall have custody of the minor children on Wednesdays from 5:30 PM to 7:00 PM; C. During the summer, the parties shall have custody of the minor children on alternate weeks from Sunday evening at 7:00 PM until the following Sunday at 7:00 PM: d. In even numbered years, Wife shall have custody of the minor children on the following holidays from 9:00 AM until 7:00 PM: New Years Day, Memorial Day, Labor Day, and Christmas Eve at noon until Christmas Day at noon. Husband shall have custody of the minor children on the following holidays from 9:00 AM until 7:00 PM: Easter, Independence Day, Thanksgiving, and Christmas Day at noon until December 26 at noon. In odd numbered years. Husband shall have custody of the minor children on the following holidays from 9:00 AM until 7:00 PM: New Years Day, Memorial Day, Labor Day, and Christmas Eve at noon until Christmas Day at noon. Wife shall have custody of the minor children on the following holidays from 9:00 AM until 7:00 PM: Easter, Independence Day, Thanksgiving, and Cl istmas Day at noon until December 26 at noon. C. The children shall spend Father's Day with Husband and Mother's Day with Wife; f. The patties agree that if either parent plans a trip with the minor children which would take the children out of a one hundred (100) mile radius of the parent's residence and would require an overnight stay, the traveling party will notify the non-traveling party. The traveling parent will provide the location of the trip and a telephone number where the children can be reached; g. The parties agree that Wife shall provide Husband with the Employer Identification Number or Social Security Number of all child care providers; It. The parties shall share in the transportation of the minor children for the periods of partial custody; In the event there is a conflict between the weekend and holiday schedule, the holiday schedule shall take precedence and be the binding schedule; j• Husband and Wife, by mutual agreement, may vary from this schedule at any time. Husband and Wife ag-ce that each will notify the other of all medical care the children receive while in that parent's care. Each parent will notify the other immediately of medical emergencies that arise while the children are in that parent's care; k. The parties realize that their children's well being is paramount to any differences they might have between themselves. Therefore, neither party shall do anything which may estrange the children from the other parent. or injure the opinions of the children as to the other parent, or which may hamper the free and natural development of the children's love or respect for the other parent; and on himsf for the benefit 1. The parties agree that Husband will provide life insurance M each of the of children in the amount of $25,000.00 per child. After a period of two years, Husband shall increase the insurance policies to $50,000.00 per child. Husband shall continue the coverage until the children reach the age of eighteen 0 9) years and the children shall be the beneficiary on said life insurance policies with Wife that th proceeding and shall not be deemed to constitute or be a dischargeable debt of a bankruptcy. o. Wife may request January 1 of each year following the ag execution of this Agreemstt, proof of the continuation of the ; ^"„'?^ce coverage for each of the children. 12. BANKItiJpTCY It is hereby understood and agreed by and between the parties eir obligation pursuant to this agreement shall not be affected by any bankruptcy 10 -11 13. ALIMONY ALIMONY PENDENTE LITE COUNSEL FEES AND EXPENSES. The parties accept the provisions of this Agreement in lieu of and as full and final settlement and satisfaction of all claims and demands that they may now or hereafter have against the other for alimony, alimony pendcnte lite, counsel fees or expenses, or for any other provision for support and maintenance before, during or after the commencement of any proceedings for the divorce or annulment between the Parties. 14. WAIVER OF CLAIMS AGAINST ESTATE. 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 or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including, without limitation, dower, courtesy, statutory allowance, widows allowance, right to take property under equitable distribution, right to take in intestacy, right to take against the will of the other's estate, and who will, at the request of the other, execute, acknowledge and deliver any and all instnunents which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights . . . 11 and claims. 15. BREACH. If either Party breaches any provision of this Agreement, the other Party shall have the right, at his or her election, to sue for damages for such breach or seek such, other remedies or relief as may be advisable to him or her. The Party breaching this Contract should be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement. 16. 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. 17. MODIFICATION AND WAIVER. The 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. 18. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the Patties. 19. INDEPENDENT SEPARATE COVENANT. It is specifically understood and agreed by and between the Parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 20. APPLICABLE LAW. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 21. VOLUNTARY EXECUTION. Husband and Wife acknowledge and represent that the provisions of this Agreement are fully understood by both Parties and each Party acknowledges that this Agreement is in all respects fair and equitable, that it is 12 being entered into voluntarily and knowingly, and that it is not the result of any duress, undue influence, collusion or improper or illegal agreement or agreements. IN WITNESS WHEREOF. the Parties have hereunto set their hands and seals the day and year first above written. 13 WITNESS: CERTIFICATE OF SERVICE I, Lynn K. Chambers Plaintiff, Pro Se, do hereby certify that on the _th day of August 2001, I caused a true and correct copy of the Petition to be served upon the following individuals by certified mail, return receipt requested, restricted delivery by depositing the same in the United States mail, postage prepaid, in Harrisburg, Pennsylvania. Gerald S. Robinson, Esquire ROBINSON & GERALDO 4407 North Front Street Harrisburg, PA 17110 Michael E. Chambers 223 S. York Street Mechanicsburg, PA 17055 Respe lly Sub ' ed, L K. Chambers, Plaintiff, Pro Se 124 W. Portland Street Apt. 24 Mechanicsburg, PA 17055 AFFIDAVIT OF SERVICE I, Gerald S. Robinson, ESQUIRE, certify, that I am an attorney licensed to practice law in the Commonwealth of Pennsylvania, and that my client, MICHAEL E. CHAMBERS, was served with a CONTEMPT PETITION on or about August 2001. ROBINSON & GERALDO Gerald S. Robinson, Esquire Counsel for the Defendant PA I.D. 4407 North Front Street Harrisburg, PA 17110 717-232-8525 ,_ : J .. ; ; ,.. ` ; , _ -- :; r- LYNN K. CHAMBERS, Plaintiff N'. MICHAEL E. CHAMBERS, Defendant IN "rl-IE COURT OF COMMON PLEAS OP CUMBE=RLAND COUNTY. PENNSYLVANIA CIVIL AC'T'ION - LAW NO. 99-6904 CIVIL TERM ORDER OF COURT AND NOW, this I I"' day of October, 2001, upon consideration of' the attached letter from Plaintiff dated October 10, 2001, indicating that she wishes to withdraw the petition for contempt filed in this case, Plaintiff's Petition for Contempt is deemed withdrawn and the hearing scheduled for October 15, 2001, is cancelled. BY THE COURT. Lynn K. Chambers 124 W. Portland Street Apt. 28 Mcchanicsburg, PA 17055 Plaintiff, Pro Se Gerald S. Robinson, Esq. 4407 North Front Street Harrisburg, PA 17110 Attorney for Defendant Michael E. Chambers 223 S. York Street Mechanicsburg. PA 17055 :rc 1. esley Oler, ., Lynn K. Chambers 124 W. Portland Street Apt 28 Mechanicsburg. PA 17055 717-691-5507 October 10 2001 ria ftix 240-6462 RE: CIVIL -DOCKET 99-6904-IZEOUEST FOR WITHDRAW Honorable Judge Wesley Oler Cumberland County Courthouse Carlisle. PA 17013 Dear Judge Oler: I wish to withdraw my petition for Contempt against defendant Michael E. Chambers. and cancel the hearing set for October 16. The defendant has paid me the money owed, as dictated in the marital property agreement. This particular debt is now satisfied. As the defendant has resolved the conflict by paving the money, there is no reason to have a hearing now. Your office scheduled a hearing for Mondav. October 161h at 10:30 a.m. I called your office this morning and informed them of this. They suggested I write this letter to officially inform you of this change. Thank you for your time in this matter. b i;? Plaintiff Pro Se CC: ATTORNEY GERALD ROBINSON Michael Chambers i IV ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT D,? y State -Commonwealth of Pennsylvania J,J `> I -) 0 ?I Co./City/Dist. of CUMBERLAND q?( - /6LJ VU I Date of Order/Notice 01/28/02 Court/Case Number (See Addendum for case summary) EmployediVilhholder's Federal EIN Number E C SNYDER INC EmployedWithholder's Name 250 S 18TH ST EmplayediVithholder's Address HARRISBURG PA 17104-1211 ?(LI31of+??l?' i)7 I `+ `f r1 )ef1?.3 O Original Onlar/Notice Ox Amended Order/Notice O Terminals onler/Nolice I RE: CHAMBERS, MICHAEL E. 1 Employer/Ohligor's Name Mast, First, Nil) 1 168-48-3337 1 EmployedObligor's Social Security Nurnixor 1 3068100412 1 Employee/Obligor's Caseldenlihur 1 (See Addendum for plaintiff names associated with cases on attachment) 1 Cuslodi.d Parent's Name (Las(, 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, 030. oo per month in current support $ o . 00 per month in past-due support Arrears 12 weeks or greater? Oyes ® 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 $ 1, 030.00 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: $ 237. 69 per weekly pay period. $ 47s. 38 per biweekly pay period (every two weeks). $ 51s . oo per semimonthly pay period (twice a month). $ _ 1.030.00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten 0 0) 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 1D (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: / /aq / 0,) Service Type M BY THE COURT: 'N% i' MIR %..:09700154 I PN60n are 1v3J,n0 Form EN-028 Worker ID $IATT V ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If checked you are required to provide a copy of this form to your employee. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee%bligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee%bligor. 3.' -Reporting-the-Paydate/Date of Withholding-You must report the paydateJdateofwithholding-when sending the-payment.-The- paydate/date-oftvithholding-is-the date-on-which-amount wws-withheld from the employee`sAvages: 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 A9 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. WITHHOLDER'S ID: 2312858390 EMPLOYEE'S/OBLIGOR'S NAME: CHAMBERS. MICHAEL E. EMPLOYEE'S CASE IDENTIFIER: 3068100412 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. 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 It S U.S.C. §1673 MI; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 10. 'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Requesting Agency: If you or your employee/obligor have any questions, AOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT 13 N. HANOVER ST by telephone at (717) 240.6225 or P.O. BOX 320 by FAX at (717) 240.6248 or CARLISLE PA 17013 by Internet p Service Type M Page 2 of 2 Form EN-028 oNte ?o.: acroou+ Worker ID $IATT no?.mm? one ivnm0 1 R ADDENDUM Summary of Cases on Attachment Defendant/Obligor: CHAMBERS, MICHAEL E. PACSES Case Number 943101690 Plaintiff Name LYNN K. CHAMBERS Docket Attachment Amount 00976 S 1999 E 1,030.00 Child(ren)'s Name(s): DOB BENJAMIN ALDEN CHAMBERS 08/12/92 ANDREW. MORGAN. CHAMBERS 12/19/94 PACSES Case Numher Plaintiff Name 22EL12 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 ?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. ? 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 PACSES Case Number Plaintiff Name Plaintiff Name Docket Attachment Amount Docket Attachment Amount $ 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) ? 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. Service Type M Addendum Form EN-028 Worker ID $IATT 0f16 No.: 09700154 t,piolion Oac: 1I/31100 r _ ?, <.. ?-: .=; C\' 1?. -? CSI 7 :_? U