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HomeMy WebLinkAbout01-0390 FX;, e~ d ,. y 1N 'THE COURT OF COMMON PLEAS Melissa Ann Carder N O. 2001-390 Civil Term Plaintiff VERSUS Defendant DECREE [N DIVORCE AND NOW, Q~ r~ 2001 IT IS ORDERED AND DECREED THAT P4~l ism.-A~-Ca°E~Y _, PLAINTIFF, AND Michael Nash Carder ,DEFENDANT, ARE 41VORCEq FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; the Attached Prooertv Settlement Acrreement, dated October 5, 2001 ~~_• P THONOTARY ATTEST: J . ~ ~ ~ i ~b :' ~3 w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW Melissa AnnCarder, Plaintiff v. Michael Nash Carder, Defendant No. 20013°~t! Civil Term IN DIVORCE PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, made this ~ day of October, 2001 by and between MELISSA A CARDER of Cumberland County, Pennsylvania (hereinafter referred to as WIFE), and MICHAEL N. CARDER of Cumberland County, Pennsylvania (hereinafter referred to as HUSBAND), WHEREAS, HUSBAND and WIFE were lawfully married on November 11, 1993 in Monmouth County, New Jersey; and WHEREAS, two (2) children were born of this marriage, namely: Tyler Carder, born January 21, 1995; and Matthew Carder, born April 16, 1996; and WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of HUSBAND and WIFE to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of 1 settling fully and finally their respective financial and property rights and obligations as between each other, including without limitation by specification: the settling of all matters between them relating to the ownership and equitable distribution of real and personal property; the settling of all matters between them relating to past, present and future support and alimony; and in general, the settling of any and all claims by one against the other or against their respective estates. NOW, THEREFORE, in consideration of the premises and 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, HUSBAND and WIFE, each intending to be legally bound, hereby covenant and agree as follows: 1. Separation: It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place as he or she may from time to time choose or deem fit. The foregoing provision 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. 2. 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 2 carry out the provisions of this Agreement. Neither party shall molest the other or attempt to endeavor 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 of the other, while living separate and apart. 3. Subsequent Divorce: The parties acknowledge that WIFE has filed a Complaint in Divorce in Cumberland County, Pennsylvania, on January 19, 2001 to docket number 01-390 Civil Term, claiming that the marriage is irretrievably broken under the no-fault mutual consent provision of Section 3301(c) of the Pennsylvania Divorce Code. HUSBAND hereby expresses his agreement that the marriage is irretrievably broken and expresses his intent to execute, at the time of the execution of this Agreement, any and all affidavits or other documents necessary for the parties to obtain an absolute divorce pursuant to Section 3301(c) of the Divorce Code. The parties hereby waive all rights to request Court- ordered counseling under the Divorce Code. It is specifically understood and agreed by the parties that the provisions of this Agreement as to equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever, as contemplated by the Pennsylvania Divorce Code. Should a decree, judgment or order of separation or divorce be obtained by either of the parties in this or any other state, 3 country or jurisdiction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be affected in any way by any such separation or divorce; and that nothing in any such decree, judgment, order or further modification or revision thereof shall alter, amend or vary any term of this Agreement, whether or not either or both of the parties shall remarry. It is specifically agreed, that a copy of this Agreement or the substance of the provisions thereof, may be incorporated by reference, but not merged, into any divorce, judgment or decree. It is the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties. 4. Date of Execution: The "date of execution" or "execution date" of this Agreement shall be defined as the day upon which it is executed by the parties if they have each executed the agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 5. Distribution Date: The transfer of property, funds and/or documents provided for herein, shall only take place on the "distribution date" which shall be defined as specified herein. 6. Mutual Release: HUSBAND and WIFE each do hereby mutually remise, release, quitclaim and forever discharge the other and the 4 estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and interests, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against the other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or curtesy, or claims in the nature of dower or curtesy or widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania, (b) any State, Commonwealth or territory of the United States, or (c) any country, or any rights which either party may have or at any time hereafter shall have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, property division, costs or expenses, whether arising as a result of the marital relations or otherwise, except, all rights and obligation of whatsoever nature arising or which may arise under this Agreement or for the breach of any provisions thereof. 5 It is the intention of HUSBAND and WIFE to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all right and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is further agreed that this Agreement shall be and constitute a full and final resolution of any and all claims which each of the parties may have against the other for equitable division of property, alimony, counsel fees and expenses, alimony pendente lite or any other claims pursuant to the Pennsylvania Divorce Code or the divorce laws of any other jurisdiction. 7. Advice of Counsel: The provisions of this Agreement and their legal effect have been fully explained to WIFE by JOAN CAREY, ESQUIRE, counsel for WIFE; and to HUSBAND by MICHAEL A. SCHERER, ESQUIRE, counsel for HUSBAND. HUSBAND and WIFE acknowledge and accept that this Agreement is, in the circumstances, fair and equitable and that it is being entered into freely and voluntarily 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 ar agreements. 6 8. Warranty as to Existing Obligations: Each party represents that he or she has not heretofore incurred or contracted for any debt or liability or obligation for which the estate of the other party may be responsible or liable except as may be provided for in this Agreement. Each party agrees to indemnify and hold the other party harmless for and against any and all such debts, liabilities or obligations of every kind which may have heretofore been incurred by them, including those for necessities, except for the obligation arising out of this Agreement. 9. EXISTING DEBTS: HUSBAND and WIFE acknowledge that there is a loan on the 1999 Ford Escort titled in HUSBAND's name. HUSBAND agrees to be solely and exclusively responsible for the balance of this loan, and any and all other debts in his individual name. HUSBAND further agrees to indemnify WIFE and hold her harmless from any and all liability for same. WIFE agrees to be solely and exclusively responsible for any and all debts in her individual name. WIFE further agrees to indemnify HUSBAND and hold him harmless from any and all liability for same. The parties agree that there are no debts in joint names. 10. Warranty as to Future Obligations: HUSBAND and WIFE each covenant, warrant, represent and agree that, with the exception of obligations set forth in this Agreement, neither of them shall 7 hereafter incur any liability whatsoever for which the estate of the other may be liable. Each party shall indemnify and hold harmless the other party for and against any and all debts, charges and liabilities incurred by the other after the execution date of this Agreement, except as may be otherwise specifically provided for by the terms of this Agreement. 11. Personal Property: The parties agree that WIFE shall become the sole and exclusive owner of all personal property currently in her possession, and that HUSBAND shall become the sole and exclusive owner of all personal property currently in his possession. HUSBAND and WIFE agree that the above division of property is mutually acceptable to them. Neither party shall make any claim to any such item of marital property or of the separate personal property of either party which will be in the possession and/or under the control of the other at the time of the execution of this Agreement. Should it become necessary, the parties each agree to sign, upon request, any titles or documents necessary to give effect to this paragraph. Property shall be deemed to be in the possession or under the control of either party if, in the case of tangible personal property, the item is physically in the possession or control of the party at the time of the execution of this Agreement; and in 8 the case of intangible personal property, if any physical or written evidence of ownership, such as passbook, checkbook, policy or certificate of insurance or other similar writing is in the possession or control of the party at the time of the execution of this Agreement. 12. Motor Vehicles: The parties agree that HUSBAND shall become the sole and exclusive owner of the 1999 Ford Escort currently titled in HUSBAND's individual name, or any proceeds therfrom. HUSBAND agrees to be solely and exclusively responsible for the balance of the loan on this vehicle, and he further agrees to indemnify WIFE and hold her harmless from any and all liability for same. The parties agree that WIFE shall remain the sole and exclusive owner of the 1993 Dodge Shadow which is non-marital property, purchased by WIFE after the date of separation. 13. Marital Residence: The parties agree that WIFE shall have sole and exclusive possession and ownership o£ the marital residence, a mobile home located at 127 CME, Newville, Cumberland County, Pennsylvania. HUSBAND agrees to waive all of his rights and interest in the marital residence. HUSBAND further agrees to execute any and all documents necessary to transfer title of the marital residence to WIFE's individual name within thirty (30) days of the execution of this Agreement. 9 In consideration for WIFE's sole ownership and possession of the marital residence, WIFE agrees to forgive HUSBAND's child support arrears docketed at 1202 S 96, and APL arrears docketed at 2001-390, as of October 5, 2001, as per paragraph eighteen (18) below. 14. Pension/Retirement/ Military Benefits: The parties agree that HUSBAND shall become the sole and exclusive owner of any and all pension/retirement benefits that he has accrued during the course of the marriage. WIFE agrees to waive all of her rights and interest in these benefits, and she further agrees to execute, upon request, any and all documehts necessary to effectuate the terms of this Agreement. HUSBAND shall enroll the children in any military benefits for which they may qualify. 15. After Acquired Personal Property: Each of the parties shall hereafter own and enjoy, independently of any claims or right of the other, all items of personal property, tangible or intangible, hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried. 16. Applicability of Tax Law to Property Transfers: The parties hereby agree and express their intent that any transfers of 10 property pursuant to this Agreement shall be within the scope and applicability of the Deficit Reduction Act of 1984 (herein the "Act"), specifically, the provisions of said Act pertaining to transfers of property between spouses or former spouses. The parties agree to sign and cause to be filed any elections or other documents required by the Internal Revenue Service to render the Act applicable to the transfers set forth in this Agreement, without recognition of gain on such transfer and subject to the carry-over basis provisions of said Act. 17. Waiver of Alimony: The parties herein acknowledge that, by this Agreement, they have respectively secured and maintained an adequate fund with which to provide for themselves sufficient financial resources for their comfort, maintenance and support. HUSBAND and WIFE do hereby waive, release and give up any rights they may respectively have against the other for alimony, spousal support or maintenance. It shall be, from the execution of this Agreement, the sole responsibility of each of the respective parties to sustain themselves without seeking any support from the other party. 18. Waiver of Spousal Support, Alimony Pendente Lite and Counsel Fees: Each party hereby waives any right to spousal support and alimony pendents lite as of the date of this Agreement. The parties acknowledge that HUSBAND appealed the APL/Spousal 11 Support Order, docketed at 2001-390. HUSBAND agrees withdraw the appeal within ten (10) days of the execution of this agreement. WIFE agrees to contact the Domestic Relations Office of Cumberland County and forgive HUSBAND'S arrears as of October 5, 2001. HUSBAND shall continue to be responsible for his share of the children's outstanding and future medical bills pursuant to the support order of January 24, 2001, through the Cumberland County Domestic Relations office. The parties agree to be responsible for their own attorney's fees. 19. Full Disclosure: HUSBAND and WIFE each represent and warrant to the other that he or she has made a full and complete disclosure to the other of all assets of any nature whatsoever and of every type whatsoever in. which such party has an interest, and of all other facts relating to the subject matter of this Agreement. 20. Disclosure and Waiver of Procedural Rights: Each party understands that he or she has the right to obtain from the other party a complete inventory or list of all of the property that either or both parties own at this time or owned as of the date of separation, and that each party has the right to have all such property valued by means of appraisals or otherwise. Both parties understand that they have the right to have the Court hold hearings 12 and make decisions on the matters covered by this Agreement. Both parties understand that a Court decision concerning the parties' respective rights and obligations might be different from the provisions of this Agreement. Both parties waive the following procedural rights: a. The right to obtain an Inventory and Appraisement of all marital and separate property as defined by the Pennsylvania Divorce Code; b. The right to obtain an Income and Expense Statement of the other party as provided by the Pennsylvania Divorce Code; c. The right to have the Court determine which property is marital and which is non-marital and equitably distribute between the parties that property which the Court determines to be marital; d. The right to have the Court decide any other rights, remedies, privileges, or obligations covered by this Agreement, including but not limited to, possible claims for divorce, spousal support, alimony, alimony pendente lite, counsel fees, costs and expenses. 21. Waiver of Modification to be in Writing: No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any 13 subsequent default of the same or similar nature. 22. Mutual Cooperation: Each party shall, at any time and from time to time hereafter, take any and all steps and execute, acknowledge and deliver to the other party any and all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. 23. Applicable Law: This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date of execution of this Agreement. 24. A~creement Binding on Heirs: This Agreement shall be binding and shall inure to the benefits of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 25. Integration: This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. 26. Other Documentation: HUSBAND and WIFE covenant and agree that they will forthwith execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other 14 6 writings as may be necessary or desirable for the proper effectuation of this Agreement. 27. No Waiver on Default: This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any default or breach of any provisions hereof be construed as a waiver of any subsequent default or breach of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. 28. Severability: If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet his or her obligation under any one or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. 15 .~ 29• Breach: If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as may be available to him or her. The party breaching this contract shall be responsible for payment of reasonable legal fees and costs incurred by the other in enforcing their rights under this agreement. 30. Headings Not Part of Agreement: Any heading preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. IN WITNESS WHEREOF, the parties hereto have set their hands and seals this day and year first above written. Date Witness Date fitness ME IL S AS A. CARDER 16 ~~ *# Y~- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,' PENNSYLVANIA CIVIL ACTION - LAW MELISSA A. CARDER, Plaintiff/Petitioner v. No. 2001-390 Civil Term MYCHAEL N. CARDER, Defendant/Respondent IN DIVORCE PRAECIPE TO TRANSMIT RECORD To The Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and Manner of service of the Complaint: Defendant was ersonally served a true and correct copy of the Complaint for Divorce at the Cumberland County Domestic Relations Office on January 24, 2001, by Maryann Murphy, Esquire. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, October 5.2001; by Defendant, October 5.2001. (b)(1) Date of execution of the Plaintiffls Affidavit required by Section 3301(d) of the Divorce Code: N/A (2) Date of filing -and service of the Plaintiffls Affidavit upon Defendant: NN/A. 4. Related claims pending: All claims have been resolved bathe Property Settlement date October 5, 2001. _. , . 5. Complete either paragraph (a) or (b). (a) Date and manner of service of the notice of intention to file Praecipe to Transmit Record, a copy of which is attached: N/A. (b) Date Plaintiff s Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: October 9, 2001. (c) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: October 9, 2001, 2001. Plaintiff s Social Security Number: 182-66-5213 Defendant's Social Security Number: 453-93-5317 MIDPENN LEGAL 8 Irvine Row Carlisle, PA 17013 (717)243-9400 ... r~ ~ `-~ : -J ~; :,,-~ S' ~ t I~a _ -^~ __ F~~ ,y..~, :- ~- ,.~ :~ ".. i 0{a19sW,gNRS _ ~,sem?Y~, 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW MELISSA A. CARDER, Plaintiff No. ~1 ~39® Civil Term v. MICHAEL N. CARDER, Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOUHAVE BEENSUED dN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Le han demandado a usted a la torte. Si usted quiere defenderse en contra estas demandas expuestas en ]as paginas siguientes, usted tiene veinte {20) dias de plazo al partir de la fecha de la demanda y la notification. Usted debe presentar una apaziencia escrita o en persona o por abogado y azchivaz en la torte en forma escrita sus defensas o sus objeciones a las demandas en contra suya. Se has avisado que si usted no se defienda, la torte tomaza medidas y puede entraz una Orden contra usted sin previo aviso o notification y por cualquier que ja o alivio que es pedido en la petition do demanda. USTED PUEDE PERDER DINERO O PROPTENDADES O OTROS DERECHOS IMPORTANTES PARR USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Baz Association 2 Liberty Avenue Cazlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled Conference or Hearing. Cumberland County Baz Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW MELISSA A. CARDER, Plaintiff No. O ~- 3 ~d Civil Term v. MICHAEL N. CARDER, : IN DIVORCE Defendant COUNTI COMPLAINT UNDER SECTION 3301(cl OF THE DIVORCE CODE AND NOW comes MELISSA A. CARDER, by and through her attorney, Maryann Murphy, Esquire of MidPenn Legal Services, who respectfully avers as follows: 1. Plaintiff is MELISSA A. CARDER whose current address is 127 CME, Newville, Cumberland County, Pennsylvania. 2. Defendant is MICHAEL N. CARDER whose current address is unknown. Defendant's work address is Lear Corporation, 50 Spring Road, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on November 11, 1993 in Monmouth County, New Jersey. 5. There have been no prior actions for divorce or for annulment between the parties. 6. Defendant is not a member of the Armed Forces of the United States of America or any of its Allies. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being handed down by the Court. 9. Plaintiff requests this Court to enter a Decree in Divorce from the bonds of matrimony. COIINT II CLAIM FOR SOIIITASLS DISTRIBIITION OF MARITAL PROPERTY IINDSR SECTION 3502 OF THS DIVORCE CODS 10. Plaintiff hereby incorporates by reference all of the averments contained in Count I of this Complaint. il. Plaintiff and Defendant are the owners of real estate, motor vehicles, retirement benefits and other personal property acquired during the marriage which are subject to equitable distribution by this Court. 12. Plaintiff and Defendant have been unable to agree as to ~,~ an equitable division of said property as of the date of the filing of this Complaint. 13. Plaintiff requests this Court to equitably distribute the parties' marital property. COUNT III CLAIM FOR ALIMONY PSNDSNTS LITS UNDER SECTION 3702 OF T88 DIVORCE CODS 14. Plaintiff hereby incorporates by reference all of the averments contained in Counts I and II of this Complaint. 15. Plaintiff does not have sufficient funds to support herself during the pendency of this action. 16. Defendant does have a sufficient source of income to aid Plaintiff in supporting herself during the pendency of this action. 17. Plaintiff requests this Court to grant her alimony pendente lite during the pendency of this action. COUNT Iy CLAIM FOR ALIMONY UNDER SECTION 3701 OF THS DIVORCE CODS 18. Plaintiff hereby incorporates by reference all of the averments contained in Counts I, II and III of this Complaint. 19. Plaintiff does not have a sufficient source of income or earning capacity at the present time to maintain the standard of living enjoyed by the parties during their marriage. 20. Defendant does have a sufficient source of income and earning capacity to aid Plaintiff in maintaining the standard of living enjoyed by the parties during their marriage. 21. Plaintiff requests this Court to grant her alimony to enable her to maintain the standard of living enjoyed by the parties during their marriage. ~VHSRSFORS, Plaintiff requests this Honorable Court to enter a Decree: a. dissolving the marriage between the Plaintiff and Defendant; and b. equitably distributing all property owned by the parties hereto; and c. directing the Defendant to pay alimony pendente lite during the pendency of this action; and d. granting alimony to Plaintiff; and e. for such further relief as the Court may determine to be equitable and just. Respectfully submitted, Maryann urphy, Esquire MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 Attorney for Plaintiff AFFIDAVIT I, MELISSA A. CARDER, verify that the statements made in the foregoing Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. -~'~~ Date MELISSA A. CARDER ,..r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW MELISSA A. CARDER, Plaintiff No. Civil Term v. MICHAEL N. CARDER, : IN DIVORCE Defendant CHRTIFICATS OF SERVICE I, Maryann Murphy, Esquire, do hereby certify that a true and correct copy of the within Divorce Complaint was mailed to the Defendant, MICHAEL N. CARDER, by first class U.S. mail, postage pre-paid, certified/restricted delivery, addressed as follows: Michael N. Carder c/o Lear Corporation 50 Spring Road Carlisle, PA 17013 Respectfully submitted, vVY ~. Maryann urphy, Esqui e MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 Attorney for Plaintiff o ~ n 'TkC7 [t} ,tye ~ ~i-w - i i ~ ? ~ ~ y _ ~ C" ~~ ~ -"-r ,- ry ~ ~ _ ~ ~: ?r C-3'7 ~ ~ ~~ r~ s,J to -. ~a N'+~ 9e-9~'4 k ~Fi+.~ Y.. 4. rp'~~-vub.N~~i ~u t ' a 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL ACTION -LAW MELISSA A. CARDER, Plaintiff NO. Ol`3`~® Civil Term v. MICHAEL N. CARDER, Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, MELISSA A. CARDER, Plaintiff, to proceed in forma au eris. I, Maryann Murphy, Esquire, of MidPenn Legal Services, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. t Maryann Murphy, Esquire MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW MELISSA A. CARDER, Plaintiff NO. v ~' 3 4 ~ Civil Term v. IN DIVORCE MICHAEL N. CARDER, Defendant AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS L I am MELISSA A. CARDER, the Plaintiff in the above matter and because of my fmancial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: MELISSA A. CARDER Address: 127 CME. Newville. PA 17241 (b) Social Security Number: 182-66-5213 If you are presently employed, state N/A Employer: N/A Address: Salary or wages per month: N/A Type of work: N/A If you are presently unemployed, state Date of last employment: 1994 Salary or wages per month: $1000.00 gross Type of work: U.S. Army (c) Other income within the past twelve months Business or profession: Other self-employment: Interest: Dividends: Pension and annuities: -0- Social Security benefits: Support payments: -0- Disability payments: Unemployment compensation and supplemental benefits: -0- Workman's compensation: -0- Public Assistance: -0- Other: -0- (d) Other contributions to household support (Wife)(Husband) Name: If your (husband) (wife) is employed, state Employer: ~' 1 Salary or wages per month: N/A Type of work: Contributions from children: (e) Property owned Cash: $3 00 Checking Account: $90.00 Savings Account: $25.00 Certificates of Deposit: Real Estate (including home): Mobile home -approx. $10.000.00 Motor vehicle: Make Dodge Shadow Year 1993 Cost $2.000.00 Amount owed~1,900.00 Stocks; bonds: Other: (f) Debts and obligations Mortgage: Rent: Lot rent $205.00 Loans: $100.00 der month Monthly Expenses: $1586.00 (g) Persons dependent upon you for support (Wife) (Husband) Name: Children, if any: Name: TYLER Name: MATTHEW Age: 6 years Age: 4 year 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. a Date: ) - ) ~ ~ ~) \=~"""'- ` MELIS A A. CARDER t ~~ c? ~a 1 ~ F~: 4 _ ~ . ~_) ° rv ~-~, -~ t ~ '-X~~ c~ ~ ~' .~ ~~ Y W Q ~. ,. .: ^x?rea~x ... .. _ -. ~~nt~ r,xw=< a ,~::u;w.Pr_a•r:aa~!~3er,:'m~,. -..n~sy~.ra~3x'pg~73sp IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW MELISSA A. CARDER, Plaintiff : No. 01-390 Civil Term v. MICHAEL N. CARDER, : IN DIVORCE Defendant AFFIDAVIT OF SERVICE I, Maryann Murphy, Esquire, depose and say: 1. That I am an adult individual residing in Cumberland County, Pennsylvania. 2. That on January 24, 2001 at approximately 9:00 a.m. I personally served upon the Defendant, Michael N. Carder, a true and correct copy of the Complaint in Divorce at the Cumberland County Domestic Relations Office, Carlisle, Pennsylvania. Maryann urphy, Esquire 1 V MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 (717)243-9400 I.D. # 61900 ~ f,~ _ 'D ~ a U~7'~' ~ ^ ` J " : ~ ^Gt ~ ~ ~' ~ ~ f11 ~~ ~ ~ C73 " ~ r_C7 Cl t .~ `.. ._ .. }+z~ ., ~9w~ _. - .. -'* ~~ w=w- s.a~w~e~w~sw ~tx= =.ss;~~rrrw~Ext~iRy IN T$S COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MELISSA A. CARDER, Plaintiff/Petitioner v. MICHAEL N. CARDER, Def¢ndant/Respondent No. ~(.-39~? IN DIVORCE PETITION FOR APL CONFERENCE Civil Term NOW COMES, MELISSA A. CARDER, Plaintiff/Petitioner, by and through her attorney, Maryann Murphy, Esquire, of Mid-Penn Legal Services, and avers as follows: 1. Petitioner is MELISSA A. CARDER who resides at 127 CME, Newville, Pennsylvania 17241. 2. Respondent is MICHAEL N. CARDER whose current residence is unknown. Respondent is employed by Lear Corporation, 50 Spring Road, Carlisle, Pennsylvania 17013. 3. Petitioner and Respondent were married on November 11, 1993 in Monmouth, New Jersey. 4. Petitioner and Respondent are the parents of two (2) minor child, namely: TYLER CARDER, born January 21, 1995; and MATTHEW CARDER, born April 16, 1996. 5. The parties separated on December 26, 2000. 6. On January 19, 2001, Petitioner filed a Complaint in Divorce which includes a Count for Alimony Pendente Lite. -- 4~% d'MEG€_ :ads ~+;-a*s--~; ~,,,,4,:,.",s+?~. a;,.r<t~€,~u•. 7. A DRS Attachment for APL Proceedings has been filed with the Court simultaneously with this Petition. WHEREFORTs, Petitioner, through her counsel, requests a conference be held at the Domestic Relations Section to address her claim for APL. Respectfully submitted: p ~i (0 gy, "'" ~ `~~Jl Maryann Murphy, Esquire (~ Mid-Penn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 Attorney I.D. #61900 Attorney for Plaintiff/Petitioner I, the undersigned, do hereby verify that the statements made in the foregoing instrument are true and correct to the best of my knowledge, information and belief. I understand that statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. MELISS A. CARDER IN THE COURT OF COMMON PLEAS OF ~~((CUMB,JERLAND COUNTY, PENNSYLVANIA ~P.~ l SSQ. l.~d,~ Plaintiff NO. , V• CIVIL ACTION -LAW ' ~ ~ 1 ~(~~~I IN DIVORCE M e~ a.~. 'v 1. • Defendant DRS ATTACHMENT FOR APL PROCcs"DINGS PETITIONER NAME l ~~ s s ~ - e.t' ADDRESS - a~ ~ r 1v ~ i -~. A ~ BIRTH DATE ~ -L~ - ~ q ~ 5 SOCIAL SECURITY NUMBER ~ ~- ~ - ~ ~ - 5 ~ ~ 3 HOME PHONE '~ h ~ ... ~' a 3 D WORK PHONE EMPLOYER NAME ~ ~ R EMPLOYER ADDRESS J~J'a JOB TITLE/POSITION ~ DATE EMPLOYMENT COMMENCED A GROSS PAY ~ NET PAY Q OTHER INCOME ATTORNEY'S NAME P'dA~`~ 0.X1h Ik-h ~ ~ S (~; h , ~g ATTORNEY'S ADDRESS I~(`V `r 11 E nc DLIj `%$~~ PA t 70I ATTORNEY'S PHONE NUMBER ~ ~ ~ L~ 3 ~ ~ ~ ©(~ r RESPONDENT NAME N ~ ~ ~i ~-, ADDRESS ~ l~ ~ BIRTH DATE _r~ _ (l~ 11JN ~ SOCIAL SECURITY NUMBER y ~ 5 3 ` q 3 - JN 3 ~ HOME PHONE woRx PHOrrE ~ 5 g - r~ ~ ~ ~ EMPLOYER NAME ~~~ ~ ~ ~ ~ © (1 EMPLOYER ADDRESS ~'© ~ ~~ I~S~e ~~ b701 JOB TITLE/POSITION ~ r DATE EMPLOYMENT COMMENCED ~q ~ ~ ? GROSS PAY ~ NET PAY ~ OTHER INCOME ATTORNEY'S NAME ~-{, ti (,~ (P. per( ~I Q~ ~f-i ~ ATTORNEY'S ADDRESS M ~ ~ , ~p l~ ' ° ~ ~~ (i ~~ P A 116 ATTORNEY'S PHONE NUMBER a. ~ q - Cq g ~1 '~ MARRIAGE INFORMATION DATE OF MARRIAGE ~ ~ - f j - ~ ~ , G) 3 PLACE OF MARRIAGE M ~ ~ ~, DATE OF SEPARATION l ~ .- ~ J OMRESS OF LAST MARITAL ~ ~ N ~ M L / ~ ~ U i ~ ~ ~ P /'~ ~ 7 a ~ I DESCRIPTION OF DOCUMENT RAISING APL CLAIM l'~Kl ~ ~ ~ ~ ~ h p ~ ~ Q h~N.~ P DATE APL DOCUMENT FILED ~ - l ~ ~ Z O ~ ~ IN THE COURT OF CONMON PLEAS OF CUbIBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LALP MELISSA A. CARDER, 8lsintiff/Petitioner v. MICHAEL N. CARDER, Defendant/Respondent No.pl-39© IN DIVORCE CERTIFICATE OF SERVICE Civil Term I, Maryann Murphy, Esquire, do hereby certify that on the day of 2001 I served a true and correct copy of the foregoing Petition for APL Conference on the Defendant, MICHAEL N. CARDER, at the address set forth below, by placing a copy of same in the United States Mail, first class, postage prepaid. Michael N. Carder c/o Lear Corporation 50 Spring Road Carlisle, PA 17013 Respectfully submitted, Maryann Iurphy, Esqui e 1 Mid-Penn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 540-8600 I.D. # 61900 .~ MELISSA A. CARDER, Plaintiff/Petitioner vs. MICHAEL N. CARDER, Defendant/Respondent DR 30383 PACSES ID 136103000 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION CIVIL ACTION -LAW NO. 01-390 CIVIL TERM ORDER OF COURT AND NOW, this 26a' day of January, 2001, based upon the Court's determination that Petitiorier's monthly net income/earning capacity is $575.57 per month and Respondent's monthly net income%arning capacity is $1,916.18 per month, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $189.37 per month payable monthly as follows; $189.37 per month for alimony pendente lite and $0.00 on arrears. First payment due February 2, 2001. Arreazs set at $189.37 as of January 24, 2001. The effective date of the order is January 19, 2001. Failure to make each payment on time and in full will cause all aneazs to become subject to immediate collection by all of the means as provided by 23 Pa.C.S.§ 3703. Further, if the Court finds, after heazing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the PA SCDU to: Melissa A. Carder. Payments must be made by check or money order. All checks and money orders must be made payable to PA SCDU and mailed to: PA SCDU P.O. Box 69110 Hamsburg, PA 17106-9110 Payments must include the defendant's PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. Respondent to provide medical insurance coverage for wife.. This Order shall become final ten days after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary for a hearing de novo before the Court. DRO: R J. Shadday BY THE COURT, Mailed copies on Petitioner ~-~~-d/ [o: < Respondent Michael Scherer, Esquire Maryann Murphy, Esquire Edward E. Guido J. c~ ~~ c~- _.. 'tz ` v -" " - ^~ ~ - - zY ' _.~ -_ z r ; ~. ~: E~~~ +`~ ~"] ~ .- ~~ r-, _ ~~~ - .. ~ii ~~ ~ ~~ ~~ r , -'~-{ iV -G "' -. 'fry*~? g__,F,~ ..iy, as;,mFr>(~4!rSV.*g1F8~f:kfi'A~1Y.~'.Mf!R;9RB4`fn;.n.~1411¢'iNU~p' ~i '~ ORDER/NOTiCE TO WITHHOLD'dINCOME FOR SUPPORT 2 Z.OODd(J ~7 f 36~O.30aD _ OOriginal Order/Notice State Commonwealth of Pennsvlvania t 3-oZ S 4G DI=-390 G%u. L Amended Order/Notice Co./City/Dist. of CUms&Ri~ND ~Q , Date of Order/Notice 01/24/01 1~2 zS9S~ Aa-3d?~3 QTerminateOrder/Notice Court/Case Number (See Addendum for case summary) EmployerM/ithholders Federal EIN Number LEAR EAST LP Employer/Wi[hholder's Name 50 SPRING RD Empoyer/1Nithholder's Address CARLISLE PA 17013-0040 )RE: CARDER. MICHAEL N. Employee/Obligor's Name (Last, First, Mq > 453-93-5317 Employee/Obligors Social Secudiy Number 3778000032 Employee/Obligor's Case Identifier (See Addendmn for plaintiff names associated with cases on attachmenU Custodial Parent's Name (Last, First, Mp 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 evmssRLAND County, Commonwealth of Pennsylvania. Bylaw, 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. $ 823 , 33 per month in current support $ 0, oo per month in past-due support Arrears 12 weeks or greater Qyes ®no $ o, 0o per month in medical support $ o , o o per month for genetic test costs $ per month in other (specify) for a total of $ 823.33 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: $ 190, oo per weekly pay period, $ 380. oo per biweekly pay period (every two weeks). $ 411.67 per semimonthly pay period (twice a month). $ 823.33 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 BYMAIL. _ ~ BY THE COURT: DRO: RT Shadday :` ";° xc: defendant J-~l -0/ Date of Order: Jant:ary 29, 2001 Edward E. Guido JUDGE Form EN-028 Service Type M oraeNo.:ae~a-olsa WOrkerlD $IATT Fxpimtion Date: 11/31/00 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 kom more than one employee%bligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3.* . You must comply with the law of the state of the employee's/obligor's principal place of employment with respell 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%bligoranll you are unable [o honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when [he 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. W ITHHOLDER'S ID: 2516 5 24 5 5 0 EMPLOYEE'S/OBLIGOR'S NAME: CARDER, MICHAEL N. EMPLOYEE'S CASE IDENTIFIER: 3778000032 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRE55: 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%bligor'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%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 State in which he or she is employed governs. 9.* Withholding Limits: You may notwithhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. §1673 (b)1; or Z) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 10. *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Requesting Agency: DOMESTIC RELATIONS SECTION P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by Internet @ Service Type M Page 2 of 2 OMB No.: a9)a-0154 Expiration Daze: 11/31/00 Form EN-028 Worker ID $IATT ADDENDUM Summarv of Cases on Attachment Defendant/Obligor: CARDER, MICHAEL N. PACSES Case Number 136103000 Plaintiff Name MELISSA A. CARDER Docket AttachmentAmount 01-390 CIVIL $ 169.37 Child(ren)'s Name(s): DOB ^Ifchecked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ^ If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ^ If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket AttachmentAmount $ o.oo 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. T C> {~ n " ti ~: 7~ j-~r - ~i 'Q ;' rti `' ~ ~ _7 '~ • t:., v'rP '[ ,V , ~~ «~- Y ~`. MELISSA A. CARDER, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION -DIVORCE NO.Ol-390 CIVIL TERM MICHAEL N. CARDER, IN DIVORCE DefendanURespondent DR# 30383 Pacses# 136103000 NOTICE OF RIGHT TO REQUEST A HEARING The parties aze hereby advised that they have until Fe6ruary 10.2001 to request a heazing do novo before the Court. File request in person or mail to: Office of the Prothonotary 1 Courthouse Square Carlisle, PA 17013 MELISSA A. CARDER, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION -DIVORCE MICHAEL N. CARDER, DefendantBespondent NO.Ol-390 CIVIL TERM IN DIVORCE DR# 30383 Paeses# 136103000 DEMAND FOR HEARING DATE OF ORDER: January 26, 2001 AMOUNT: $189.37 per month FOR Alimony Pendente Lite nc n enwtim. PARTY FILING DEMAND FOR HEARING: Signa A~'-'~"Y ~'~- /l/-IGHAc't. N. (ARJr'A.. Z_?. o! Date ~- ~__ . 4y:c ti.. ~ ~_-~ ~ r~u(r T . ~A t1 _~` v. `/ v? ~•. ~..~ ~ . rv" _ '.. <--rj ~ ~ ~. -;! ~T 11(1 ++~_ l , ~ _ ~ • ~~'~ !ter J a_S f ~ S, , 'l ~ ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT ;~ Di-~Qd L~/v/L State Commonwealth of Pennsylvania ~~s~ /3Lo/03o00 OX Original Order/Notice ' CO./City/DiSt. Of CUMBERLAND ~ l.'7U,/~f ~j 77~~~~~~gg a~ / O Amended Order/Notice Date of Order/Notice 06/08/01 `~'cx" /~~ s /7 c/S~ Terminate Order/Notice Court/Case Number (See Addendum for case summary) /~/4~SFS °Z~G,'DG/G fr~ Employer/Withholder's Federal EIN Number MANPOAIER TEMPORARY SERVICES Employer/Withholder's Name 761 SCRANTON CARBONDALE H Employer/Withholder's Address SCRANTON PA 18508-1121 ~- as9 RE: CARDER, MICHAEL N. Employee/Obligor's Name (Last, First, Mp ) 453-93-5317 Employee/Obligor's Social Security Number 3778000032 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, 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. $ 823.33 per month in current support $ 0.00 per month in past-due support Arrears 12 weeks or greater? ®yes ~ no $ o. oo per month in medical support $ o . oo per month for genetic test costs $ per month in other_(specify) for a total of $, 623.33 Aer month to be forwarded to payee below. You do not have to vary your pay cycle to be incompliance 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: $ 19o.ooperweeklypayperiod. $ 380.00 per biweekly pay period (every two weeks). $ 411.67 per semimonthly pay period (twice a month). $ 823.33 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-mount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposabT'e 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 ADDI7/ON, 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 Shadday xc: defendant / _/(_ ~_~ Date of Order: ,Tune lf, 2-~L1fLL Edward E. Guido JODGE Form EN-028 Service Type M Done NO.: o9~o-olsa Worker ID $IATT Expiration Dale 12/31/00 -r,. ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ^ If checked you are required to provide a copy of this form to your employee. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee%bligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee%bligor. 3.* You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee%bligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state ofemployee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee%bligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'$ ID: 3918365860 EMPLOYEE'S/OBLIGOR'S NAME: CARDER, MICHAEL N. EMPLOYEE'S CASE IDENTIFIER: 3778000032 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold hom 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%bligor'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%bligorfvom employment, refusing [o employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. $1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 10. *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Requesting Agency: OMESTIC RELA IONS 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 (7171 240-6248 or by Internet ~ Service Type M Page 2 of 2 OMB No.:09)0-0154 Expiration Date: tY31/00 Form EN-028 Worker ID $2ATT ADDENDUM Summary of Cases on Attachment PACSES Case Number Plaintiff Name Docket AttachmentAmount $ o.oo 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 AttachmentAmount $ o.oo Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket AttachmentAmount $ o.oo 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 AttachmentAmount $ o.oo Child(ren)'s Name(s): DOB ORDERINOTICE TO WITHHOLD INCOME FOR SUPPORT d/- &4U Irv/L, State Commonwealth of Pennsylvania P'gfr-S~'S /3/-r/300 p X~Original Order/Notice CO./City/Dist. Of CilMBERLAND ~~ 30,3 g3 O Amended Order/Notice Date of Order/Notice 06/08/01 Court/Case Number (See Addendum for case summary) Employer/Withhotder's Federal EIN Number ) ONSITfi COMPANIES INC ) Employer/Withholder's Name ) ~. /c2Go2 S ~~ g ~/ Terminate Order/Notice ~i3eSFS a~o~0~lJOO f~~ ~R-- ab 9s~8' RE: CARDER, MICHAEL N. Employee/Obligor's Name (Last, Firsi, Mp 453-93-5317 Employee/Obligor's Social Security Number 921 ELKRIDGE LANDING RD ) 3778000032 Employer/Withholder's Address ) Employee/Obligor's Case Identifier LINTHICUM MD 21090-2918 ) (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, 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. $ 823.33 per month in current support $ 0.00 per month in past-due support Arrears 12 weeks or greater? ®yes ~ no $ o.ooPermonth in medical support $ o. oo per month for genetic test costs $ per month in other (specify) for a total of $ 823.33 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: $ 190.00 per weekly pay period. $ 380. oo per biweekly pay period (every two weeks). $ 411.67 per semimonthly pay period (twice a month). $ 823.33 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (70) 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 /N 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 BYM ,,~ "i BY THE COURT: I3R0: RJ Shadday ~- xc: deEerxlant Date of Order: June 11, 20p1 Edward E. Guido Jt]D(,E Form EN-028 Service Type M OMBNO.:09]0-0154 Worker ID $IATT Expiration Date: 14/3 V00 ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ^ If checked you are required to provide a copy of this form to your employee, 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment [o each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3.* . 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%bligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee 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. W17HHOLDER'S ID: s2iea2eoso EMPLOYEE'S/OBLIGOR'S NAME: CARDHR. MICHAEL N. EMPLOYEE'S CASE IDENTIFIER: 3778000032 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You maybe requimd ro 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: ff you fail to withhold income as the Order/Notice directs, you are liable for both fhe accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee%bligorfyom 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 State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 10. *NOTE: if you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Requesting Agency: If you or your employee%bligor have any questions, DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT P.O. BOX 320 by telephone at (717) 240-6225 or CARLISLE PA 17013 by FAX at (717) 240-6248 or by Internet Crd Service Type M Page 2 of 2 Form EN-028 Worker ID $IATT OM8 No.: 09)D-Ot 54 Expiation Date: II/31/00 ~ d ADDENDUM Summary of Cases on Attachment Defendant/Obligor: CARDER, MICHAEL N. PACSES Case Number 1351030oo/<-J~3~3 Plaintiff Name MELISSA A. CARDER Docket AttachmentAmount 01-390 CIVIL $ 189.37 Child(ren)'s Name(s): DOB ^ If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ^ If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ^ 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 AttachmentAmount $ o.oo 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. l~~ ~f ~.- ~ ~ ~l7 f ~y In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION MELISSA A. CARDER ) Docket Number 1202 S 96 argt P1ainGff ) 2~l 39m ClViL„ vs. ) PACSES Case Number 220000084 ~ MICHAEL N. CARDSR ) 136'1G3~ - Defendant )Other State ID Number Order AND NOW to wit, this JUNE zl, zool it is hereby Ordered that: LEAK LINK, P.O. BOX 420, LITTLE FALLS, NEW JERSEY, 07424-0420 IS PROHIBITED AND ENJOINED FROM RELEASING ANY FINAL DISTRIBUTION/RETIREMENT FUNDS FOR AND TO MICHAEL N. CARDER, SOCIAL SECURITY NUMBER 453-93-5317, UNTIL FURTHHR ORDHR OF COURT. DRO: RJ Shadday xc: plaintiff defetxlant Michas Sclr_rer, Esquire Maryann Murphy, Esquire `~ ; Service Type M ~ .a -G1 ~, BY THE COURT: Edward E. Guido JUDGE Form 0E-001 Worker ID 21005 ' ° ORDER/NOT CE TO WITHHOLD INCOME FOR SUPPORT 0/-390 ~iaiC 1 State Commonwealth of Pennsylvania ~~ /3~/0301~ QOriginal Order/Notice / /Z O Amended Order/Notice Co./City/Dist. of CUMBERLAND 3U3 ~3 ~Kt ~aoa ~ /99Cv Date Of Order/NotlCe 07/10/01 (~ Terminate Order/Notice Court/CaseNumber (See Addendum /or case summary) !~~'SFS aadOU~O~! Employer/4Vithholder's Federal EIN Number UNITED PARCEL SERVICE* Employer/Withholder's Name 8325 ARDWICK ARDMORE RD Employer/Withholder's Address LANDOVER MD 20785-1622 ~~ as9sSl RE: CARDER, MICHAEL N. Employee/Obligor's Name (last, First, Mp ) 453-93-5317 Employee/Obligor's Social Security Number 3778000032 Employee/Obligor's Case Identifier (See Addendum for plaintiff names assodated with cases on attarhmenU Custodial Parent's Name (Last, First, MO See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INEORMATION: 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. $ 823.33 per month in current support $ 0. oo per month in past-due support Arrears 12 weeks or greaten ®yes ~ no $ 0.00 Per month in medical support $ o. 0o per month for genetic test costs $ per month in other (specify) for a total of $ 823.33 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: $ 190.00 per weekly pay period. $ 380.00 per biweekly pay period (every two weeks). $ 411.67 per semimonthly pay period (twice a month). $ 823.33 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. DRO: RJ Shadd,3y BY THE COURT: xc: defecxlant Date of Order: July 11, 2®pl Edward E. U~xido ,7UD~ Form EN-028 Service Type M OMBNO.:09]0-0154 Worker ID $IATT Expiration Datc 12/31/00 ` ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ^ If checked you are required to provide a copy of [his 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.* . You must comply with the law of the state of the employee's/obligor's principal place of employment with respell to [he 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%bligorartd you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment, You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee%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'SID: iaia26sooo EMPLOYEE'S/OBLIGOR'S NAME: CARDER. MICHAEL N. EMPLOYEE'S CASE IDENTIFIER: 3778000032 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: _ NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required [o 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 OrderMotice directs, you are liable for both the accumulated amount you should have withheld from the employee%bligor'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%bligorfmm employment, refusing to employ, or taking disciplinary action against any employee%bligorhecause of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser oF. 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 10. *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Requesting Agency: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 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 OMB No.: 09]0-0154 Expiation Dale: tY31/00 Form EN-028 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: CARDER, MICHAEL N. PACSES Case Number 136103000 / 3p3~3 Plaintiff Name / MELISSA A. CARDER Docket AttachmentAmount 01-390 CIVIL $ 189.37 Child(ren)'s Name(s): DOB ^ If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ^ If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ^ 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 AttachmentAmount $ o.oo 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 AttachmentAmount $ o.oo Child(ren)'s Name(s): DOB SUPPORT State Commonwealth of Pennskvania P.T/P`~> /3(v, Co./City/Dist. of CUMBERLAND J~/'L 3~~~ Date of Order/Notice 07/31/01 Court/Case Number (See Addendum for case summary) Employer/Withholder's Federal EIN Number PAPA JOHN'S PIZZA EmployerM/ithholder's Name 500 S HANOVER ST Employer/Withholder's Address CARLISLE PA 17013-3918 r0 jQ~~ OOriginal Order/Notice 73 j~a~ ~ /~(a.~ Q Amended Order/Notice ~~ 5~~~~( Nq~'(~O Terminate OrderlNotice RE CARDER, MICHAEL N. Employee/Obligor's Name (Las[, First, MU ) 453-93-5317 Employee/Obligors Social Security Number 3778000032 Employee/Obligor's Case Identifier (See Addendum for plaintiff names assodated with cases on attachment) Custodial 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 [o 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. $ 823.33 per month in current support $ 0.00 per month in past-due support Arrears 12 weeks or greater? ®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 $ 823 , 33 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: $ 190.00 per weekly pay period. $ 380. oo per biweekly pay period (every two weeks). $ 411.67 per semimonthly pay period (twice a month). $ 823.33 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 PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO RE PROCESSED. DO NOT SEND CASH BY MAIL. Date of Order: ~ ~ ~ Service Type M Q_~~` BY THE COURT: Eorm EN-028 OMB NO.: 09]0-0154 WOrkef ID $IATT Exoirdtion Dale: 12/31/00 ' ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ^ If checked you are required to provide a copy of this form to your employee. r 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 [ax levies in effect please contact the requesting agency listed below 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding, You must, however, separately identify the portion of the single payment that is attributable to each employee%bligor. 3.* . You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligorwith Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee%bligorend you are unable to honorall support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify [he Requesting Agency when the employee%bligar 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: 4666100092 EMPLOYEE'S/OBLIGOR'S NAME: CARDER. MICHAEL N. EMPLOYEE'S CASE IDENTIFIER; 3778000032 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee%bligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 1 b. *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 respell to these items. Requesting Agency: If you or your employee/obligor have any questions, DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT 13 N. HANOVER ST by telephone at (717) 240-6225 or P.O. BOX 320 by FAX at (717) 240-6248 or CARLISLE PA 17013 by Internet Page 2 of 2 Form EN-028 Service Type jv1 OMBNO.:09]0-0154 WorkerlD $IATT Expiration Date: 12/31/00 ADDENDUM Summary of Cases on Attachment Defendant/Obligor: CARDER, MICHAEL N. PACSES Case Number 13alo3oo%3033 Plaintiff Name MELISSA A. CARDER Docket AttachmentAmount 01-390 CIVIL $ 169.37 Child(ren)'s Name(s): DOB ^ If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ^ If checked, you are required to enroll the child{ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ^ If checked, you are required toenroll 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. ORDER/NOTIC~EfT~O WITHHOLD INCOME FOR SUPPORT ""'- ~/ 390 ~~~/~ OOriginal Order/Notice State Commonwealth of Penns~vania P,ac~s `z,,(~,/D3pD ~ CO./City/DiSt.Of CUMBERLAND ,( 3G~~3 ~~t~,~ QAmendedOrder/Notice Date of Order/Notice 08/06/01 ~'~ /Owa `~ Terminate Order/Notice Court/Case Number (See Addendum for case summary) ~~CSG~S' aappGD6 ~'~ Q Employer/Withholder's Federal EIN Number DON SAYLOR'S MARKETS INC Employer/Withholder's Name AOUTE 641 & GINTEAS MILL Employer/Withholder's Address NE-V{TILLE PA 17241 v2 a5~i5'~ RE: CARDER, MICHAEL N. Employee/Obligor's Name (Last, First, MI) ) 453-93-5317 Employee/Obligor's Social Security Number > 3778000032 Employee/Obligor's Case Identifier (See Addendum for plaintiff names assoriated with cases on attachmen0 Custodial Parent's Name (Last, First, MI) See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 823.33 per month in current support $ 0.00 per month in past-due support Arrears 12 weeks or greater? ®yes Q no $ 0.00 Per month in medical support $ o. oo Per month for genetic test costs $ per month in other (specify) for a total of $ 823.33 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: $ 190.00 per weekly pay period. $ 380. oo per biweekly pay period (every two weeks). $ 411.67 per semimonthly pay period (twice a month). $ 823.33 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 PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASK/ BY MAIL. BY THE COURT: Date of Order: AUG 1 72001 Service Type M ..., dm.r ~~~~~ b zD TV~GC- Form EN-028 B No.: 09]0-0154 ~`~ Emimtion Dale 12/31/00 ` j~~tT L Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ^ If checked you are required to provide a copy of this form to your employee. . 1, Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee%bligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3.* . 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%bligoranll you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state ofemployee's/obligor's principal place of employment. You must honor all Orders/Notices to fhe 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: 2320839830 EMPLOYEE'S/OBLIGOR'S NAME: CARDER, MICHAEL N. EMPLOYEE'S CASE IDENTIFIER: 3778000032 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: _ NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee%bligorfvom employment, refusing to employ, or taking disciplinary action against any employee%bligorhecause of a support withholding. Pennsylvania State iaw governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 10. *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to fol low the law of the state that issued this order with respell to these items. Requesting Agency: AOMESTIC RELATIONS SECTION 13 N. HANOVER ST P,O, BOX 320 CARLISLE PA 17013 Service Type M If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at 1717) 240-6248 or by Internet ~ Page 2 of 2 oM8 No.: 0910-01 sa Expiation Date: 12/31/00 Form EN-028 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: CARDER, MICHAEL N. PACSES Case Number 136103000 /~O~i~3 Plaintiff Name / MELISSA A. CARDER Docket AttachmentAmount 01-390 CIVIL $ 189.37 Child(ren)'s Name(s): DOB ^ If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ^ If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ^ 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 AttachmentAmount $ o.oo 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. C~ c~ i C ^' ii ~, ~y7 ~__ ~~__ _" _ G.~ ~ _, -y ~4.% ` _.t.r ice .ry_ '/ ~' ~ C L,7 ~,Ji`r : ~ .. { ~ ~ -< CSJ < ~i~ ~. .. .. .. ~ _ ;a~~ma~.«ic~s ~:vs ~xwa;' w~u*~ww~n ~xarrmw.~ ..rpm~n,~rw~ay_ _ ._.,. ORDER/NOTICE TO WIT~HpHOLD INCOME FOR SUPPORT ~~' ~/-i/~ ~vlC QOriginal Order/Notice State Commonwealth of Penns~vania ~S>=S j 3 ~ i63~~ CO./City/DiSt. Of CUMBERLAND ,)~ ?~~~~. ~r // Q Amended Order/Notice Date of Order/Notice 08/22/01 ;/lam ~~~ S 1~9V XQ Terminate Order/Notice Court/Case Number (See Addendum for case summary) ~? o~dbt?r~ ~~ Employer/Withholder's Federal EIN Number DON SAYLOR'S MARKETS INC Employer/Withholder's Name ROUTE 641 & LINTERS MILL Employer/Withholder's Address NEWVILLE PA 17241 ~~ stt5{Is'~ RE: CARDER, MICHAEL N Employee/Obligor's Name (Last, First, Mp ) 453-93-5317 Employee/Obligor's Social Security Number 3778000032 Employee/Obligor's Case Identifier (See Addendmn for plaintiff names associated with cases on attachment) Custodial Parent's Name (Las[, First, Mq See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 0.00 per month in current support $ 0.00 per month in past-due support Arrears 12 weeks or greater? Qyes ®no $ 0.00 Per month in medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ 0.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 0.0o per weekly pay period. $ o . 00 per biweekly pay period (every two weeks). $ o. oo per semimonthly pay period (twice a month). $ o. 00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the 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 NAMEAND 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: phi 2 3 1QQ1 °°°° Date of Order: `h '° Form EN-028 Service Type jv] t' . OMa NO.: 09]0-0154 Worker ID $IATT pim[ion Date: 12/31/00 ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ^ If checked you are required to provide a copy of this form to your employee. 7. 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.* . 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/Obligorwhh Multiple Suppon Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee%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: 2320839830 EMPLOYEE'S/OBLIGOR'S NAME: CARDER. MICHAEL N. EMPLOYEE'S CASE IDENTIFIER: 3778000032 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 l ump 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%bligor'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 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. 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 [he 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, DOMESTIC RELATIONS SECTION contact 13 N. HANOVER ST by telephone at (717) 240-6225 or P.O. BOX 320 by FAX at 17171 240-6248 or CARLISLE PA 17013 by Internet Service Type M Page 2 of 2 Form EN-028 Worker ID $IATT OMB No.: 09]0-0154 Expiation Date: 1P/31/00 ~y@n ~ C.} n 7> -3 ~ ~~_ - -' C7 _~ '`D r'~ C. .: _=i -~ ~a =. ~Y - _ _ _ _ B~kT _ ~ _ .. '2Ji~Y ~f!~ ~ w N'p~i T+a4':~.)FiNA xe?(+~ ef~tl3F11M1F59 .~` DR 30,383 PACSES 136103000 MELISSA A. CARDER, PLAINTIFF VS MICHAEL N. CARDER, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION CIV[L ACTION -SUPPORT NO. 390 CIVIL TERM 2001 NOTICE Legal proceedings have been brought against you alleging that you have willfully disobeyed an order of court for support. 1. If you wish to defend against the claim set forth in the following pages, you may, but are not required to file in writing with the Court your defenses or objections. 2. You must appear in person in Court on Friday, October 5, 2001 at 9:00 a.m. in Court Room No. 1, Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT APPEAR IN PERSON, THE COURT MAY ISSUE A WARRANT FOR YOUR ARREST AND YOU MAY BE COMMITTED TO JAIL. 3. If the Court finds that you have willfully failed to comply with its order for support, you may be found in contempt of court and committed to jail, fined or both, 4. You must bring the following to the Court hearing: a. a true copy of your most recent Federal Income Tax Return, as filed and W-2 forms; b. a completed Income and Expense Statement in the form attached to this notice; and c. a statement from your employer of your earnings and deductions on the enclosed Earnings Report. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU NEED AN ATTORNEY TO REPRESENT YOU BUT CANNOT AFFORD TO HIRE ONE, YOU SHOULD REPORT TO THE PUBLIC DEFENDER'S OFFICE, THIRD FLOOR, CUMBERLAND COUNTY COURT HOUSE, CARLISLE,.PENNSYLVANIA, AT ON THE DAY OF YOUR HEARING. BY THE COURT, George E. Hoffer President Judge Date: 8/27/0 l BY . J. adda Conf ence Officer RJS/jIg Enclosures -defendant only cc: PLAINTIFF -Your attendance at the hearing is encouraged but not required. If you wish to speak with the Domestic Relations Office attorney prior to the hearing, he will be available at the Domestic Relations Office, ] 3 North Hanover Street, Carlisle, Pennsylvania one hour before the hearing. DR 30,383 PACSES 136103000 MELISSA A. CARDER, PLAINTIFF VS MICHAEL N. CARDER, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION CIVIL ACTION -SUPPORT NO. 390 CIVIL TERM 2001 PETITION FOR CONTEMPT -DEFENDANT TO THE HONORABLE, THE JUDGES OF SAID COURT: l . Petitioner is Cumberland County Domestic' Relations Section. 2. Defendant is Michael N. Carder, who resides at 863 Carlwynne Manor, Apartment B107, Carlisle, Pennsylvania. 3. On January 26, 2001 an order of support was entered by the Honorable Court directing Defendant to pay the sum of $189.37 to the Plaintiff. 4. Defendant has failed to comply with the order as enterd by the Court by failing to: a. Pay as ordered; b. Failure to maintain employment; and c. Failure to abide by January 26, 2001 court order. Wherefore, Petitioner prays that the Court issue an order directing the attendance of Defendant at a hearing of said Petition and hereafter to make an adjudication of contempt. verify that the statements made in this Petition are true and correct to the best of my knowledge. 1 understand that false statements herein are made to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authoritites. .~ Date: ~~a~~r7~ ~. R.. had y, C rference Officer F: IN TILE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW Melissa Ann Carder, Plaintiff No. 2001-390 Civil Term v. Michael Nash Carder, : IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 19, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date Melissa Am Carder 18 ` i . . j R r: - i A ~~ ' w l Y ~ ~~ tip l ,f _. . _ . ~1IRAaWitffiiHA~i ii!9~4~* '. 'f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW MELISSA A. CARDER, Plaintiff ~': MICHAEL N. CARDER, Defendant No. 01-390 Civil Term IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. i( Date Melissa Ann Carder 19 ~31§iH[. EAR a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW Melissa Ann Carder, . Plaintiff No. 2001-390 Civil Term v. Michael Nash Carder, : IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 19, 2001. 2. The marriage of Plaintiff and Defendant is nretrievably broken, and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.5. Section 4904 relating to unsworn falsification to authorities. ~0. 5 . 01 Date 18 .. , ~-: - ~, r,~,- --_ ~~; ~: ~. _~ - .; =;: - ~~ :~ <;-, __ . _ _ fli~G:Nf~9~~W~,"xgis~ ~ A`v `-~"'~wti1c9{gg!rs£AJF~ _. s r f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW MELISSA A. CARDER, Plaintiff : No. 01-390 Civil Term ~. MICHAEL N. CARDER, : IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(cI OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. 10.S.oI Date 19 f Fl f 1? t ~W~._ MELISSA A. CARDER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DOMESTIC RELATIONS SECTION MICHAEL N. CARDER, Defendant No. 1202 SUPPORT 1996 ----------------------------------- MELISSA A. CARDER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. MICHAEL N. CARDER, Defendant CIVIL ACTION - LAW :/ NO. 01-390 CIVIL TERM ORDER OF COURT AND NOW, this 5th day of October, 2001, upon consideration of the petitions for contempt filed in the above-captioned matters, and upon relation of counsel for the Domestic Relations Office, Michael R. Rundle, Esquire, that the parties have agreed upon a resolution in this case in the form of a dismissal of the petitions for contempt, the petitions for contempt are dismissed. Michael R. Rundle, Esquire Special Counsel for DRO -~~~~aJ~~/ U-efYL~ ~~~3o~e1 (wC~. Maryann Murphy, Esquire For the Plaintiff Michael A. Scherer, Esquire For the Defendant wcy By the Court, ~k dire d~m~ai~ra d,r~~ 6U ~E! ~a+i C~~ 1~C3 4~ ~; .;~ ~~ -~_.,...-. ~a