HomeMy WebLinkAbout07-312461 '11%,
RICHARD D. FOREMAN, JR.
Plaintiff
VS
LINDA J. FOREMAN,
Defendant
: IN THE COURT OF COMMON
PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYLVANIA
: CIVIL ACTION - LAW
: NUMBER 2007-3 (-)- Y_ CIVIL TERM
: IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims set forth in the following pages, you
must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a
decree of divorce or annulment may be entered against you for any other claim or relief requested in these
papers by the plaintiff. You may lose money or property or other rights important to you including custody
or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request
marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the
Cumberland County Courthouse, One South Hanover Street, Carlisle,
Pennsylvania, 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S
FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY
LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE PA 17013
(717) 249 - 3166
18 N
AL;--
SaTy J. Wi er, sq ire
Attorney for Plaintiff
9974 Molly Pitcher Highway
Shippensburg PA 17257
41,
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RICHARD D. FOREMAN, JR. : IN THE COURT OF COMMON
PLEAS
: OF CUMBERLAND COUNTY,
Plaintiff :PENNSYLVANIA
VS : CIVIL ACTION - LAW
LINDA J. FOREMAN, : NUMBER 2007- 3 /2 CIVIL TERM
Defendant : IN DIVORCE
COMPLAINT
COMES, NOW, the Plaintiff, RICHARD D. FOREMAN, JR., by and through
his counsel, Sally J. Winder, Esquire, and represents as follows:
1. Plaintiff is RICHARD D. FOREMAN, JR., who currently resides at, and
whose mailing address is 386 Springfield Road, Shippensburg, Southampton
Township, Cumberland County, Pennsylvania, since June, 2000.
2. Defendant is LINDA J. FOREMAN, whose currently resides at, and whose
mailing address is 12 Oakville Road, Shippensburg, Cumberland County,
Pennsylvania, since 1996.
3. Both Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for at least six months immediately previous
to the filing of this Complaint.
4. The Plaintiff and Defendant were married on December 1, 1972, at
Mechanicsburg, Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the
parties.
6. The marriage is irretrievably broken. The parties have lived separate and apart
since June 21, 2000.
7. Plaintiff avers that he has been advised of the availability of counseling
sessions for both parties upon request of either party or by order of court, and
that a list of qualified professionals who provide such counseling service is
available at the Domestic Relations Office upon request. By the filing of this
Complaint, the Plaintiff acknowledges having been advised by his attorney of
record of the availability of counseling sessions and a list of qualified
professionals. Plaintiff further avers that he has been advised that the choice
of a qualified professional shall be at the option of the Plaintiff and Defendant
and need not be selected from the list available upon request and further, that
arrangements for and the payment of the services of the qualified professional
shall be the responsibility of the parties and will not be included in the docket
costs of this proceeding.
8. Plaintiff requests the Court to enter a decree of divorce.
WHEREFORE, Plaintiff requests the Court enter an order divorcing the parties
from the bonds of matrimony.
Respectfully submitted,
IN
J. coder, Esquire
ne for Plaintiff
9974 Molly Pitcher Highway
Shippensburg, PA 17257
VERIFICATION
I verify that the statements made in this Complaint 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.
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21 L? 6 -7 1 , . k P' Jazeiy'r-o-?A'
Date:
RI HARD D. FOREMAN, JR.
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RICHARD D. FOREMAN, JR. : IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
Plaintiff :PENNSYLVANIA
VS : CIVIL ACTION - LAW
LINDA J. FOREMAN, :NUMBER 200 31 ?-`I CIVIL TERM
Defendant : IN DIVORCE
NOTICE TO DEFENDANT
If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit with
twenty days after this affidavit has been served on you or the statements will be admitted.
PLAINTIFF'S AFFIDAVIT UNDER
SECTION 3301(d) OF THE DIVORCE CODE
1. The parties to this action separated on June 21, 2000, and have continued to live separate and apart for a
period of at least two years.
2. The marriage is irretrievably broken.
3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if
I do not claim them before a divorce is granted.
I verify that the statements made in this affidavit are true and correct. I understand that false statements
herein are made subject to the penalties of 18 Pa. C. S. section 4904 relating to unworn falsifications to authorities.
RICHARD D. FOREMAN, JR.
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In the Court of Common Pleas of
Cumberland County, Pennsylvania
.X 7-?
No. Civil. 19
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Prothonotary
[orney for Plaintiff
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Filed
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RICHARD D. FOREMAN, JR
Plaintiff
vs.
LINDA J. FOREMAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2007-3124 CIVIL
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims set forth in
the following pages, you must take prompt action. You are warned that if you fail to do so,
the case may proceed without you and a decree of divorce or annulment may be entered
against you by the court. A judgment may also be entered against you for any other claim
or relief requested in these papers by the Plaintiff. You may lose money or property or
other rights important to you, including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is available
in the Office of the Prothonotary at the Cumberland County Court House, Carlisle,
Pennsylvania.
IF YOU DO NOT FILE ACLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL
FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT
IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO
NOT HAVE AN ATTORNEY 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
32 South Bedford Street
Carlisle, PA 17013
Telephone: (717) 249-3166
r
RICHARD D. FOREMAN, JR. : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. : CIVIL ACTION - LAW
LINDA J. FOREMAN, : NO. 2007-3124 CIVIL
Defendant : IN DIVORCE
ANSWER AND COUNTERCLAIM
1. Admitted.
2. Defendant currently resides at 2441 Ritner Highway, Carlisle, PA 17013,
Cumberland County, Pennsylvania.
3. Admitted.
4. The Plaintiff and Defendant were married on December 1, 1973, in Cumberland
County, Pennsylvania.
5. Admitted
6. The Plaintiff has offered such indignities to the Defendant, the innocent and
injured spouse, as to render the Defendant's condition intolerable and her life burdensome.
Additionally, during the course of the parties marriage, the Plaintiff committed adultery
numerous times, the last time resulting in the parties separation.
7. The Defendant has been advised of the availability of counseling and that she
may have the right to request that the Court require the parties to participate in counseling.
8. Plaintiff requests the Court to enter Orders of Alimony and Alimony Pendente
Lite, counsel fees and costs.
COUNTERCLAIM FOR ALIMONY, ALIMONY PENDENTE LITE,
SPOUSAL SUPPORT AND COUNSEL FEES AND EXPENSES
9. Defendant makes claim for and requests that she be paid by the Plaintiff;
alimony, alimony pendente lite, spousal support and reasonable counsel fees and
expenses.
WHEREFORE, Defendant requests the Court Enter an Order or Orders granting her
Alimony, Alimony Pendente Lite, Counsel Fess and Costs.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
L
Robert L. O'Brien, Esquire
Attorney for Plaintiff
I.D. # 28351
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
T
VERIFICATION
I, Linda J. Foreman, verify that the statements made in this Answer and
Counterclaim 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.
x?cJ
Linda . Foreman
Date: Id - D 9 'D 8
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- Do not write or staple in this space.
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, ( Individual income Tax Return
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IRS
Form .
.
For the ear Jan 1 -Dec 31, 2007, or other tax year beginning 2007, ending , OMB No. IM5.0074
20 Your soda) security number
Label Your first name MI Last name
181-42-8761
(See instructions.) LINDA FOREMAN Spouse's social security number
Use the
MI Last name
If a joint return, spouse's first name
191-46-4765
IRS label.
Otherwise,
Home address (number and street). If you have a P.O. box, see instructions. Apartment no. You must enter your
social security
please print
or type.
2441 RITNER HIGHWAY
A number(s) above.
City, town or post office. If you have a foreign address, see instructions. State ZIP code
Checking a box below will not
Presidential
Election CARLISLE PA 17 015 change your tax or refund.
11 You ?Spouse
Campaign.
Check here if you, or your spouse if filing jointly, want $3 to go to this fund. (see instructions) ;
............
.
4 Head of household (with qualifying person).. See i
l
Filing Status 1 Single d
instructions.) If the qualifying person is a chi
'
2 Married filing jointly (even if only one had income) s
but not your dependent, enter this child
3 Married filing separately. Enter spouse's SSN above & full name here . ?
Check only
one box name here 01 RICHARD FOREMAN 5 n Qualifying widow(er) with dependent child (see instructions)
Exemptions Boxes checked
6a Yourself. If someone can claim you as a dependent, do not check box 6a ............ on 6a and 6b .. 1
b Spouse .............................................
(2) Dependent's ........................... :. No. of children
(4) on 6c who:
(3) Dependent's if • lived
qualifying
hi
ti
l
c Dependents: social security p
ons
re
a
child for child with you • • •
number to you tax credit a did not
Last name
First name (see instrs) live with you
due to divorce
or don
(see nstrs) . .
Dependents
on 6e not
If more than entered above
four dependents, n Add numbers
see instructions. on lures
above
d Total number of exemptions claimed ..... .....
• .................. • • • • • • •
m(s) W-2
h F
Att 7 15 195 .
.............
or
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7 Wages, salaries, tips, etc.
.............................
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Income
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b Tax-exempt interest. Do not include on line 8a .............. 8bI
.............................
dule B if required
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.........
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Attach Form(s) 9a Ordinary dividends.
W-2 here. Also b Qualified dividends (see instrs) ..................................I 9bl
f state and local income taxes (see instructions) ......................
attach Fors
ff
t
10
s o
se
10 Taxable refunds, credits, or o
W-213 and 1099-R
11
5,265.
if tax was withheld. 11 Alimony received
................................
Attach Schedule C or C-EZ .
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12 Business income or (
10
did
not
you
.............. Li
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If not re
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13 Capital gain or (loss).
get a
W
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g,
•••••••••.•••••••.••••••••••••••••
Attach Form 4797
l
14
osses).
see instructions. 14 Other gains or (
I 15a .....•...•• b Taxable amount (see instrs) .. 15b
15a IRA distributions ............
iti 16a b Taxable amount (see instrs) .. 16b
es ......
16a Pensions and annu
trusts, etc. Attach Schedule E ..
S corporations
artnerships
lties
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,
,
, p
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17 Rental rea
..................................
Attach Schedule F
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............
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Enclose, but do 18 Farm income or (
...............................
ti
h 19
on ..........................
not attac
, any. 19 Unemployment compensa
payment Also,
120 a I I b Taxable amount (see instrs) ..
fits
b
20b
...........
ene
please use 20 a Social security
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h 21
ncome
er
Form 10404. 21 Ot
22 Add the amounts in the far right column for lines 7 through 21.
23 Educator expenses (see instructions) This i s our total income. 22 20,460.
Adjusted 24 Certain business expenses of reservists, performing artists, and fee-basis
Attach Form 2106 or 2106-EZ ....................
overnment officials
24
.
Gross g
e 25 Health savings account deduction. Attach Form 8889 ........
o
In 25 -
c
m
Attach Form 3903
expenses
26 Movin
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g
27 One-half of self-employment tax. Attach Schedule SE ........ 27
and qualified plans ............
SIMPLE
28 Self-employed SEP 28
,
,
29 Self-employed health insurance deduction (see instructions) ............. 29
30 Penalty on early withdrawal of savings ..................... 30 `
?trr:?:
31 a Alimony paid b Recipient's SSN .... 31 a
32 IRA deduction (see instructions) ........................... 32
33 Student loan interest deduction (see instructions) 33 1 -
7"
34 Tuition and fees deduction. Attach Form 8917 ............... 34
35 Domestic production activities deduction. Attach Form 8903 .............. 35
.................. ...................................... .
36 Add lines 23 - 31 a and 32 - 35
36
..
37 Subtract line 36 from line 22. This is our adjusted gross income .....................
BAA For Disclosure, Privacy Act, and Paperwork Reduction Act Notice, see Instructions. FDIA0112 12106/ 37
07 -20,460.1
Form 1040 (2007)
V
`_/etu keuvr LILYUA 2U.11 lAN 181-42-8761 Page 2
nd 38 Amount from line 37 (adjusted gross income) ... , .. , .... 38 20,460.
Bits 39a Check r You were born before January 2, 1943, Blind. Total boxes
If: 0 Spouse was born before January 2, 1943, 8 Blind. checked ? 39a
Standard b If your spouse itemizes on a separate return, or you were adual-status alien, see instrs and ck here ? 39 b
_ .,
Deduction 40 Itemized deductions (from Schedule A) or your standard deduction (see left margin) ..................... 40 5 350.
for ,
41 Subtract line 40 from line 38 .................. .
• People who ....................................... 41 _ 15,110.
checked any box 42 If line 38 is $117,300 or less, multiply $3,400 by the total number of exemptions
on line 39a or claimed on line 6d. If line 38 is over $117,300, see the instructions .....................:. 42 3,400.
39b or who can 43 Taxable income. Subtract line 42 from line 41.
be claimed as a If line 42 is more than line 41, enter -0........................................................ 43 11,710.
dependent, see 44 Tax (see instrs). Check if any tax is from: a ? Form(s) 8814 b ? Form 4972
instructions.
c Form(s) 8889 ......................... 44 1,368.
• All others: 45 Alternative minimum tax (see instructions). Attach Form 6251 ........................... 45
Single or Married 46 Add lines 44 and 45 ................................................................ ? 46 1,368.
filing separately, 47 Credit for child and dependent care expenses. Attach.Form 2441 .......... 47 _
$5,350 48 Credit for the elderly or the disabled. Attach Schedule R ..... 48
Married filing 49 Education credits. Attach Form 8863 ....................... 49
jointly or 50 Residential energy credits. Attach Form 5695 50 .
Qualifying
widow(er), 51 Foreign tax credit. Attach Form 1116 if required ............. 51
$10,700 52 Child tax credit (see instructions). Attach Form 8901 if required ........... 52 =Y
Head of 53 Retirement savings contributions credit. Attach Form 8880 53 102.
household, 54 Credits from: a ? Form. 8396 b ? Form 8859 c E] Form 8839 .. 54
$7'850. Form
Form form 55
55 Other credits: a?3800 b 11 8801 G?
56 Add lines 47 through 55. These are your total credits .............. 56. 102.
57 Subtract line 56 from line 46. If line 56 is more than line 46, enter-0. .................. ? 57 1 266 .
58 Self-employment tax. Attach Schedule SE ......... ... , , . , , , ... 58
Other 59 Unreported social security and Medicare tax from: a ? Form 4137 b ? Form 8919 ................. 59
Taxes 60 Additional tax on IRAs, other qualified retirement plans, etc. Attach Form 5329 if required ................... 60
61 Advance earned income credit payments from Form(s) W-2, box 9 ....................... 61
62 Household employment taxes. Attach Schedule H ....................................... 62
63 Add lines 57.62. This is our total tax ...................................................... ? 63 1 266.
Payments 64 Federal income tax withheld from Forms W-2 and 1099 ...... 64 2,076.
If you have a 65 2007 estimated tax payments and amount applied from 2006 return ........ 65
qualifying - 66a Earned income credit (EIC) ................................ 66a
child, attach b Nontaxable combat pay election ..... ?I 66bl 777
Schedule EIC. 67 Excess social security and tier 1 RRTA tax withheld (see instructions) ..... 67
68 Additional child tax. credit. Attach Form 8812 ................ 68
69 Amount paid with request for extension to file (see instructions) .......... 69
70 Payments from: a []Form 2439 b Form 4136 c Form 8885 70 t=?
71 Refundable credit for prior year minimum tax from Form 8801, line 27 ...... 71
72 Add lines 64, 65, 66a, and 67 through 71.
These are your tool moots ....................................... ? . . . . . . . 72 2,076.
.............
Refund 73 If line 72 is more than line 63 act,ip m line 72. This is the amou ov ai 73 810 .
. .............
Direct deposit? 74a Amount of line 73 yo want refunded to orm 8888 is attached, check here .. ? 74a 810.
See instructions ? b Routing number ........ F
XX
XXXXX c T e: Checkin Savin s
and fill in 74b9 g74c, and 7, or d Account number ....... XXXXXXXXXXXXXXX
Form 8888. 75 Amount of line 73 you want applied to your 2008 estimated tax ? 75
Amount 76 Amount you owe. Subtract line 72 from line 63. For details on how to pay, see instructions ............... ? 76
You Owe 77 Estimated tax enal (see instructions . I n I
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Third Party Do you want to allow another person to discuss this return with the IRS (see instructions)? .......... Yes. Complete the following. No
Designee's Phone
Designee name no Personal identification
number (PIN) ?
Under penalties of perjury, I declare that I have examined this
Sign return and accompanying schedules and statements, and to the best of my knowledge and
belief, they are true, correct, and complete. Declaration of preparer (other than taxpayer) is based on all information of which preparer has any knowledge.
Here Your signature
Joint return? Date Your occupation Daytime phone number
See instructions. CASHIER
Keep a copy Spouse's signature. If a joint return, both must sign. Date Spouse's occupation
for your records.
11,
Paid Pgnature , I ?7
signature ?/`
Preparer's Firm's name MARSTON' S
Use Only (or yours if
self•employed)lk 817 FACTO
Pr
nd
ZI
ea
CARLISLE
Date .
02/23/2008 Check if sel
X 'SERVICE
STREET
PA 170131352
FDIA0112 12/06/07
Preparer's SSN or PTIN
EIN 23-2105115
Phoneno. (717) 243-8782
Form 1040 (2007)
Lowe's Home Centers, Inc.
PO Box 111 I
Hwy 268E
N Wilkesboro, NC 28656
Pay Group: LHE Business Unit: 01710
Pay Begin Date: 06/28/2008 Advice #: 000000017340651
Pay End Date: 07/11/2008 AdviosDate: 07/18/2008
Linda J. Foreman Sales ID: 705736 TAX DATA Federal State
2441 Ritner Higbwav Department: 0705 - Cashiers (Lumber) Marital Status Single Not applicable
Carlisle, PA 17015 Location: Carlisle, PA Allowances 0 0
Job title: Cashierll Addl. Pct: 0 0
Pay Rate.. 9.97 Hourly Addl. Amt: 20 0
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--------- Prior Period ----- -------------- - Current -------------- ------- YTD ----------
Description Begin Date End Date Rate Hours Earnings Hours Eamin Description Current YTD
Regular 9.97 80.18 799.40 1,079.43 10,761.94 Fed Withhcidng 97.16 1,533.37
Overtime 5 0.18 0.90 1.56 7.79 FedNIED/EE 11.06 170.13
Fed OASDI/EE 47.28 727.45
PA Unempl BE 0.48 7.38
PA Withholdng 23.41 360.21
PA CARLISLE BORO 12.20 187.73
Withholdng
PA CARLISLE LS Tax 2.00 30.00
Tote 80.36 800.30 1,080.99 12,301.04 Total: 193.59 3,016.27
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Description Current YTD Description Current YTD Description Current YTD
GeisingerHealth Plan 37.87 568.05 Geisinger Health Plan 93.23 1
405.07
401(k) Savings Plan 48.02 738.06 401(k) Savings Plan 34.02 ,
522.86
• Tmable
Total: 85.89
"' 1,306.11 Total: 0.00 0.00 Total: 127.25 1,927.93
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Current 800.30 714.41 193.59 85.89 5.0.82
This pay stub information reflects your payroll data at the time
IN-
the chock or direct deposit was generated. It may not include
adjustments orreversals subsequently applied, and therefore, does Advice #0000017340651 520.82
not represent a guarantee of payroll earnings distributed to you.
Total: 520.82
MESSAGE:
Lowe's Home Centers, Inc.
PO Box 1111
Hwy 268E
N Wilkesboro, NC 28656
Deposit Amount: 520.82
To The
Account(s) Oh
Linda J. Foreman
2441 Rimer Highway
Carlisle, PA 17015
Location:Carlisle, PA
Date
07/18/2008
:•-. - -+ ..,. ? , - ..: •:. maaaas.Mffi
:,m 0
Account Type Account Number Deposit Amount
Checking iey***0301 520.82
Total: 520.82
NON-NEGOTIABLE
Advice No.
17340651
Lowe's Home Centers, Inc.
PO Box I I1 I
Hwy 268E
N Wilkeshoro, NC 28656
Pay Group: LHE Business Unit: 01710
Pay Begin Date: 07/1212008 Advice #: 000000017548086
Pay End Date: 07/25/2008 Advice Date: 08/01/2008
Linda J. Foreman Sales ID: 705736 TAX DATA Federal State
2441 Rimer Highway Department: 0705 . Cashiers (Lumber) Marital Status Single Not applicable
Carlisle, PA 17015 Location: Carlisle, PA ,Allowances D 0
Jobtide: Cashierll Addl. Pet: 0 0
Pay Rate: 9.97 Hourly Addl. Amt: 20 0
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-------Prior Period ------ •--------- Current ------------ -------- WD -------- -
Description Be ' Date End Date Rate Hours Earnings Hours Earnings Description Current YTD
Regular 9.97 79.75 795.10 1,287.67 12,938.08 Fed Withhotdas 96.43 1,835.30
Fed MED/EE 10.98 204.37
Fed OASDI/EE 46.94 873.85
PA Unempl EE 0.48 &87
PA Withholdng 23.25 432.71
PACARLISLEBORO 12.12 225.51
Withholdng
PA CARLISLE LS Tax 2.00 36.00
Total: 79.75 795.10 1,287.67 14,775.98 Total: 192.20 3,616.61
n
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Description Current YlD Description Current YTD Description Current YfD
GeisingerHealth Plan 37.87 681.66 GeisingerHealth Plan 93.23 1,684.76
401(k) Savings Plan 47.71 886.56 401(k)SavingsPlan 33.79 628.04
i Taxable
Total: 85.58 1,568.22 Total: 0.00 0.00 Total: 127.02 2,31280
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Current 795.10 709.52 192.20 85.58 517.32
This pay stub information reflects your payroll data at the tine v : - ,;? ..
the check or direct deposit was generated. It may not include "°
adjustmmrts or revenals subsequently applied, and therefore, does Advice #0000017548086 j 517.32
not represent a guarantee of payroll earnings distributed to you.
Total: 517.32
MESSAGE:
Lowe's Home Centers, Inc.
POBox llll
Hwy 268E
N Wilkesboro, NC 28656
DepositAmounk 517.32
To The
Account(s) Of:
Linda J. Foremast
2441 RitnerHighway
Carlisle, PA 17015
Location:Carlisle, PA
Date
0&01/2008
AccmmtType AccountNumber Deposit Amount
Checking taasase0301 517.32
Total: 517.32
NON-NEGOTIABLE
Advice No.
17548086
Lowe's Home Centers, Inc,
PO Box 1111
Hwy 268E
N Wilkesboro NC 28656
Pay Group: LHE Business Unit: 01710
Pay Begin Date: 07/26/2008 Advice 9: 000000017765900
Pay End Date: 08/08/2008 Advice Date: 08/15/2008
Sales ID: 705736 TAX DATA Federal State
Linda J. Foreman
2441 Ritner Highway Department: 0705 • Cashiers (Lumber) Marital Status Single Not applicable
PA 17015 Location: Carlisle, PA
Carlisle Allowances 0 0
,
Job tide: Cash ier ll Addl. Per 0 0
Pay Rate: 9.97 Hourly Addl. Amt: 20 0
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---'----- Prior Period ------ --------- ---- Current -------------- --------- WD ----------
Description Be ' Date End Date Rate Hours Earnings Hours Earnings
Description Current YTD
287.67 12,838.08
72 794.81 1
97 79
9 Fed Withholdng 96.39 1,835.30
,
.
.
Regular FedMED/EE 10.97 204.37
Fed OASDI/EE 46.93 873.85
PA Unempl EE 0.47 8.87
PA Withholdng 23.24 432.71
PA CARLISLE BORO 12.11 225.51
Withholdag
PA CARLISLE LS Tax 2.00 36.00
Total: 79.72 794.81 1,287.67 14,775.98 Total: 192.11 3,616.61
.-R...-..v:. .. ++1 }:{:::;;{??v:iiiy::. v:;v:.}.`w?n-.};.x. v,v.'$-{`-: •h`v'•v`:K
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Description Current YTD Description Current YTD Description Current YPD
Geisin Health Plan 37.87 681.66 GeisingerHealth Plan 93.23 1,684.76
04
78 628
33
401(k)Savings Plan 47.69 886.56 .
.
401(k) Savings Plan
Taxable
Total: 85.56 1,568.22 Total: 0.00 0.00 Total: 127.01 2,312.80
_ :x.:}:i-.'.+?. .v..-+•?v. 4rv:. x• ...., w. ?;,?v}v }
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192.11 85.56 517.14
709.25
794.81
Curtent
{. • •^-- --?•?}'''{>?'?`'??' ry"'
This pay stub information reflects your payroll data at the time
the check or direct deposit was generated. It may not include :.: ' - - ::??:-V A.,VV {::?:Y.f?•.?•.;::~~?:-?
adjustments or reversals subsequently applied, and tberefore, does Advice 90000017765900 517.14
not represent a guarantee of payroll earnings distributed to you.
Total: 517.14
MESSAGE:
Lowe's Home Centers, Inc.
PO Box 1111
Hwy 268E
N Wilkesboro, NC 28656
Deposit Amount: 517.14
To The
Account(s) Of:
Linda J. Foreman
2441 Rimar Highway
Carlisle, PA 17015
Location:Carlisle, PA
Date
08/15/2008
AccountType AccountNumber Deposit Amount
Checking sseaaee0301 517.14
Total: 517.14
Advice No.
17765900
NON-NEGOTIABLE
Lowe's Home Centers, Inc.
PO Box 1111
Hwy 268E
F pLHE Business Umt: 01710
n Date: 08/09/2008 Advice#: 000000018004098
Date: 08/22/2008 Advice Date: 0 8/2 912 0 0 8
V l
ID:
S 705736 TAX DATA Federal State
Linda J. Foreman
2441 Ritner Highway a
a
Department: 0705 - Cashiers (Lumber) Marital status Single Not applicable
PA 17015
Carlisle Location: Carlisle, PA Allowances 0 0
, Job tide: Cashier Il Addl. Pct 0 0
Pay Rate: 9.97 Hourly Addl. Amt: 70 0
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s Hours Earnings
Earnin
H
Description
Current
STD
nDato
Description e End Date Rate ,
g
ours
9
97 77 486.23 1,287.67 12,838.08
48 Fed Withholdng 109.11 1,835.30
Regular .
97
9 .
00 398.80 132.00 1,316.04
40 FedMED/EE 12.29 204.37
Vacation . . Fed OASDI/EE 52.53 873.85
PA Unempl EE 0.54 8.87
PA Withholdng 26.01 432.71
PA CARLISLE BORO 13.55 225.51
Withholdrtg
PA CARLISLE LS Tax 2.00 36.00
Total: 88.77 885.03 1,419.67 14,775.98 Total: 216.03 3,616.61
:y.:}"x:.M1,ty\x, ..: - .. • . ,v4--Av:: ',:.v. :.:{-.xvm::.: •ti x•.. ..
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Description Current Description
YTD Current YTD Description Current YTD
GeisingerHealth Plan 37.87 681.66 GeisingerHealth Plan
401(k) Savings Plan 93.23
37.61 1,684.76
628.04
401(k) Savings Plan 53.10 886.56 • Taxable
Total: 90.97 1,568.22 Total: 0.00 .00 Total 130.84 . 2,312.80
0 x•.+-•':%•? ?x -:
Current 885.03 794.06 216.03 90.97 578.03
This pay stub information inflects your a
yro il data at the time ,!{,:{'''-;{;;-•:s%•°°;-::`:-'+`{<3-': 1111 the check or direct deposit was generated. It may not include
adjustments or reversals subsequently applied, and therefore, does Advice #0000018004098 578.03
not represent a guarantee of payroll earnings distributed to you.
Total: 578.03
MESSAGE:
Lowe's Home Centers, Inc.
PO Box 1111
Hwy 268E
N Will esborc, NC 28656
Deposit Amount: 578.03
To The
Account(s) Of.
Linda J. Foreman
2441 Ritner Highway
Carlisle, PA 17015
Location:Carlisle, PA
Date
0&29/2008
:1 2
AcoouatType Account Number Deposit Amount
Checking eesssss0301 578.03
Total: 578.03
Advice No.
18004098
NON-NEGOTIABLE
Lowe's Home Centers, Inc.
PO Box III 1
Hwy 268E
N Wilkesboro, NC 28656
Pay Group: LHE Business Unit: 01710
Pay Begin Date: 08/23/2008 Advice #: 000000018206482
PavEndDate: 09/05/2008 Advice Date: 09/12/2008
Linda J. Foreman Sala ID: 705736 TAX DATA Federal _ State
2441 Ritner Highway Dgwtrnent: 0705 - Cashiers (Lumber) Marital Status Single Not applicable
Carlisle, PA 17015 Location: Carlisle, PA Allowances 0 0
Job tide: Cashierll Addl. Pct: 0 0
Pay Rate: 9.97 Hourly Addl. Amt: 20 0
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•-------" Prior Period ------ ------------ Current ----------- -------- WD ----------
Description Begin Date End Date Rate Hours Earnings Hours Earma Description Currant YTD
Regular 9.97 79.96 797.20 1,446.17 14,418.32 Fed Withholdng 96.75 2,026.78
Overtimes 5 0.04 0.20 1.60 7.99 Fed MED/EE 11.01 226.19
Fed OASDI/EE 47.09 967.14
PA Unempt EE 0.47 9.81
PA Withholdng 23.32 478.91
PACARLISLEBORO 12.15 249.58
Withholding
PA CARLISLE LS Tax 2.00 40.00
Total: 80.00 797.40 1,447.77 16,356.42 Total: 192.79 3,998.41
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Description Current YCD Description Current YTD Description Current YTD
Geisinger Health Plan 37.87 757.40 Geisinger Health Plan 93.23 1,871.22
401(k) Savings Plan 47.84 981.38 401(k) Savings Plan 33.88 695.20
• Taxable
Total: 85.71 1,738.78 Total: 0.00 0.00 Total: 127.11 2,566.42
Current 797.40 711.69 192.79 85.71 518.90
This pay stub information reflects your payroll data at the time
:; . :-???x•:?'a.:o::.•.'..tt:2't{:;-::;-
the check or direct deposit was generated. It may not include
adjustments or reversals subsequently applied, and therefore, does Advice #0000018206482 518.90
not represent a guarantee of payroll earnings distributed to you.
Total: 518.90
MESSAGE:
Lowe's Home Centers, Inc.
POBox 1111
Hwy 268E
N Wilkesboro, NC 28656
Deposit Amount: 518.90
To The
Account(s) Of.
Linda J. Foreman
2441 Ritner Highway
Carlisle, PA 17015
Location:Carlisle, PA
Date
09/12/2008
cae
W-zg
,Ns
AccountType Account Number DepositAmount
Checking *KYtte*0301 518.90
Total: 518.90
Advice No.
18206482
NON-NEGOTIABLE
Lowe's Home Centers, Inc.
PO Box 1111
Hwy 268E
N Wilkesboro, NC 28656
Pay Group: LHE Business Unit: 01710
Pay Begin Date: 09/06/2008 Advice 000000018419038
Pay End Date: 09/192008 Advice Date: 09/26/2008
Linda J. Foreman Sales ID: 705736 TAX DATA Federal State
2441 Rifler Highwav Department: 0705 - Cashiers (Lumber) Marital Status Single Not applicable
Carlisle, PA 17,015 Location: Carlisle, PA Allowances 0 0
Job tide: Cashier ll Addl. Pct: 0 0
Pay Rate: 9.97 Hourly Addl. Amt: 20 0
w:. -:..-.,};: r:.::::. -.. •:::..v •r::.. vv -.:•••: ••: ..• ••...... vnv v. -v-.vvv.Y.+:. -3m.-m- ,xvvw.x,-wnvvv -
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------ Prior Period ---- ------------- - Current --------------- -------- YTD ----------
Description Begin Date End Date Rate Hours Earnings Hours Earnings Description Current YTD
Regular 9.97 78.54 783.04 1,446.17 14,418.32 Fed Withholdng 94.73 2,026.78
Fed MED/EE 10.81 226.19
Fed OASDI/EE 46.20 967.14
PA Unempl BE 0.47 9.81
PA Withholdng 22.88 478.91
PACARLISLEBORO 11.92 249.58
W ithholdng
PA CARLISLE LS Tax 2.00 40.00
Total: 78.54 783.04 1,446.17 16,356.42 Total: 189.01 3,998.41
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Description Current YTD Description Current YTD Description Current YTD
Geisinger Health Plan 37.87 757.40 Gaisinger Health Plan 93.23 1,871.22
40 1 (k) Savings Plan 46.98 981.38 401(k) Savings Plan 33.28 695.20
'Taxable
Total: 84.85 1 738.78 Total: 0.00 0.00 Total: 126.51 2,566.42
Current 783.04 698.19 189.01 84.85 509.18
This pay stub information reflects your payroll data at the time
, ,-? v. +'Y'C<}. ;;::•:.P' the check or direct deposit was generated. It may not include
adjustments or reversals subsequently applied, and therefore, does Advice #0000018419038 509.18
not represent a guaramee of payroll earnings distributed to you.
Total: 509.18
MESSAGE:
Lowe's Home Centers, Inc.
POBox till
Hwy 268E
N Wilkesboro, NC 28656
Date
09/26/2008
Advice No.
18419038
Deposit Amount: 509.18
To The
Account(s) Of:
Linda J. Foreman
2441 Rimer Highway
Carlisle, PA 17015
Location:Car isle, PA
NON-NEGOTIABLE
Lowe's Home Centers, Inc.
PO Box 1111
Hwy 268E
N Wilkesboro, NC 28656
Pay Group: LHE Business Unit: 01710
Pay Begin Date: 09/20/2008 Advice #: 000000018631501
Pay End Date: 10/03/2008 Advice Date: 10110/2008
Linda J. Foreman Sales ID: 705736 TAX DATA Federal State
2441 Rifler Highway Department: 0705 - Cashiers (Lumber) Marital Status Single Not applicable
Carlisle, PA 17015 Location: Carlisle, PA Allowances 0 0
Job title: CashierlI Addl. Pct: 0 0
Pay Rate: 9.97 Houriy Addl. Amt: 20 0
%:...z..:\: is?i{f:}}:ti?i}..+wv?J4,F.. v}:{V---}'.,,vv
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------- Prior Period --•-- --------------- Current -------------- ------- YPD ---------
Description Begin Date End Date Rate Hours Earnings Hours Earnings Description Current YTD
Regular 9.97 80.16 799.19 1,606.16 16,013.42 Fed Withholdng 97.13 2,220.46
Overtime 5 0.17 0.85 1.78 8.89 Fed MED/EE 11.05 248.23
FedOASDI/EE 47.25 1,061.40
PA Unempl EE 0.48 10.77
PA Withholdng 23.40 525.58
PACARLISLEBORO 12.19 273.90
W ithholdng
PA CARLISLE LS Tax 2.00 44.00
Total: 80.33 800.04 1,607.94 17,952.42 Total: 193.50 4,384.34
ih..;,'i{{v}i}g •v\ ,v]},•' }}::},r
i?}i}?•?:'n}}{v., }. .vv?'iv''w i.\,-'??.' ?,',?i. -..2Sk .\iv z
`,v.:n,'+YSt::}: v:Y:ii-. .v
v--tifi?v?v5y
Description Current YCD Description Current YfD Description Current YfD
Geisinger Health Plan 37.87 833.14 GeisingerHealth Plan 93.23 2,057.68
401(k) Savings Plan 48.00 1,077.14 401(k) Savings Plan 34.00 763.03
* Taxable
Total: 85.87 1,910.28 Total: 0.00 0.00 Total: 127.23 2,820.71
?Yvvj'-'.Y-n'i :::}i.
Al ..
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Current 800.04 714.17 193.50 85.87 520.67
This pay stub information reflects your payroll data at the time °??:• • •
175 .- the check or direct deposit was generated. It may not include
adjustments or reversals subsequently applied, and therefore, does Advice #0000018631501 520.67
not represent a guarantee of payroll earnings distributed to you.
Total: 520.67
MESSAGE:
Lowe's Home Centers, Inc.
PO Box 1111
Hwy 268E
N Wilkesboro, NC 28656
Deposit Amount: 520.67
To The
Account(s) Oh
Linda J. Foreman
2441 RitnerHighway
Carlisle, PA 17015
Location:Carlisle, PA
Date
]0/10/]008
Account Type AccountNranber Deposit Amount
Checking "•+"r=0301 520.67
Total: 520.67
Advice No.
18631501
NON-NEGOTIABLE
Lowe's Home Centers, Inc.
PO Box 1111
Hwy 268E
N Wilkesboro, NC ?8656
Pay Group: LHE Business Unit: 01710
Pay Begin bate: 10/042008 Advice #: 000000018823620
Pay End Date: 10/172008 Advice Date: 10/242008
Linda J. Foreman Sales ID: 705736 X DATA Federal State
2441 Ritner Highway Department: 0705 - Cashiers (Lumber) rital Status Single Not applicable
Carlisle, PA 17015 Location: Carlisle, PA 0
rAUowances 0
Job title: CastderlI dl. Pct: 0 0
Pay Rate: 9.97 Hourly dl. Amt: 20 0
..........:-::::::: iny:.t}}:ni-..v.:v. rnx. • •mw-,-
.v {}} ` •`vv'.:}. -.:A...:::.n:•: •-"n` ."?...-h,:." wvi}..: r•:i(i::i:ri` >tC
:.. ..::v::.:•:.x :: xix-:.:vv: -:.
",:'{:.:.....-.??}?}}}}}}}}}}:iii i:i}:v....,vx-m:vv .if \ v::.:-::::::v.....:v- •••••
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...... v v-,-:: }v::.}}:i.}}?i:.:. ":..:•..:: •v::::::
. v: n•:.. v { ........::....:.... .v •: x::.:::.vv:::::.w:.v:•.m•:. :,•
----- ---- Prior Period --°.. ------------- - Cunem ---- --------- ------- YTD
Description Be ' Date End Date Rate Hours Earnings Hours Earnings Description Current YTD
Regular 9.97 79.83 795.91 1,606.16 16,013.42 Fed Withholdng 96.55 2,220.46
Overtime 5 0.01 0.05 1.78 8.89 Fed MED/EE 10.99 248.23
Fed OASDI/EE 47.01 1,061.40
PA Unempl EE 0.48 10.77
PA Withholdng 23.27 525.58
PA CARLISLE BORO 12.13 273.90
W ithholdng
PA CARLISLE LS Tax 2.00 44.00
Total: 79.84 795.96 1,607.94 17,952.42 Total: 192.43 4,384.34
.:n. .. .: •::: .....
}:V;`v-':hl'{v: ..•.: :::'-.in54:::{•}ii}•.: "4:•: {'r'i: t:ii.i-:}-.: v. i:{•:
:}::.:vv: ?: i• l`: i:i}:v vi :: fi:: h:v.}:}{ "} by
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Description Current YTD Description Current YTD Description Current YTD
Geisinger Health Plan 37.87 833.14 Geisinger Health Plan 93.23 2,057.68
401 (k) Savings Plan 47.76 1,077.14 401 (k) Savings Plan 33.83 763.03
e Taxable
Total: 85.63 1,910.28 Taal: 0.00 0.00 Total: 127.06 2,820.71
::.i..,v"$::i•:i.:..v::u-i:: 2ir : .. ., .,.. ., \`•::nY{:x.•'.i:}{:XR,-,:, :`v`..•,i}^h`i $:``k•:
Current 795.96 710.33 192.43 85.63 517.90
This pay stub information reflects your payroll data at the time .: •h3-•-•
the check or direct deposit was generated. It may not include " .`{"..:".ia3ii:: "'r :
adjustments or reversals subsequently applied, and therefore, does Advice #0000018823620 517.90
not represent a guarantee of payroll earnings distributed to you.
Total: 517.90
MESSAGE:
Lowe's Home Centers, Inc.
POBox 1111
Hwy 268E
N Wilkesboro, NC 28656
Deposit Amount: 517.90
To The
Account(s) Of:
Linda J. Foreman
2441 Ritner Highway
Carlisle, PA 17015
Location:Cadisle, PA
Date
10/74/2008
Account Type AccoumtNummber Deposit Amount
Checking saarsse0301 517.90
Total: 517.90
Advice No.
18823620
NON-NEGOTIABLE
Lowe's Hone Centers, Inc.
PO Box 1111
Hwy 268E
N Wilkesboro, NC 28656
Pay Group: LHE Business Unit: 01710
Pay Begin Date: 10/182008 Advice #: 000000019070271
Pay End Date: 10/312008 Advice Date: 11/0712008
Linda J. Foreman Sales ID: 705736 TAX DATA Federal State
2441 Ritner Highway Department: 0705 - Cashiers (Lumber) Marital Status Single Not appl icable
Carlisle, PA 17015 Location: Carlisle, PA Allowances 0 0
Job title: Cwhicrll Addl. Pct: 0 0
Pay Rate: 9.97 Hourly Addl. Amt: 20 0
v.
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------ Prior Period ------ -------------- Current ---- ---------- ---"---- WD ----------
Description Begin Date End Date Rate Hours Earnings Hours Earnings Description Current YTD
Regular 9.97 80.09 798.50 1,765.63 17,603.34 FedWithholdng 96.99 2,418.61
Overtime 5 0.12 0.60 1.90 9.49 Fed MED/EE 11.04 270.70
FedOASDI/EE 47.19 1,157.48
PA Unempl BE 0.48 11.75
PA Withholdng 23.37 573.16
PA CARLISLE BORO 12.18 298.70
Withholdng
PA CARLISLE LS Tax 2.00 48.00
Total: 80.21 799.10 1,767.53 19,577.94 Total: 193.25 4,778.40
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Description Current YTD Description Current YTD Description Current YTD
Geisinger Health Plan 37.87 908.88 GeisingerHealth Plan 93.23 2,244.14
401(k) Savings Plan 47.95 1,172.58 401(k) Savings Plan 33.96 830.62
• Taxable
Total: 85.82 2,081.46 Total: 0.00 0.00 Total: 127.19 3,074.76
.v., - ..vti " \v/ACs v- vv '? ?• jrv??}}i .+,J? vG.:. { `h.\ \• . {..: i:t-^v v,'{v.: i" ?v":.' v"vid
Curent 799.10 713.28 193.25 85.82 520.03
This pay stub information reflects your payroll data at the time ,,. • .i#;•„•:" 2,•
the check or direct deposit was generated. It may not include
adjustments orreversals subsequently applied, and therefore, does Advice #0000019070271 520.03
not represent a guarantee of payroll eamings distributed to you.
Total: 520.03
MESSAGE:
Lowe's Hone Centers, Inc.
POBox 1111
Hwy 268E
N Wilkesboro, NC 28656
Deposit Amount: 520.03
To The
Account(s) Of:
Linda J. Foreman
2441 Ritter Highway
Carlisle, PA 17015
LocatiomCadisle, PA
Date
I V07/2008
Account Type Account Number Deposit Amount
Checking ss"seie0301 520.03
Total: 520.03
Advice No.
19070271
NON-NEGOTIABLE
Lowe's Home Centers, Inc.
PO Box 1111
Hwy 268E
N Wilkesboro, NC 28656
Date
11212008
Linda J. Foreman Sales ID: 705736 TAX DATA Federal State
2441 Rimer Highway Department: 0705 -Cashiers (Lumber) Marital Status Single Not applicable
Carlisle, PA 17015 Location: Carlisle, PA Allowances 0 0
Job tide: Cashier II Addl. Pct: 0 0
Pay Ratc: 9.97 Hourly Addl. Amt: 20 0
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--------- Prior Period ---•-- --------------- Current ------.-- ----•- YTD ----------
Description Begin Date End Date Rate Hours Earrings Hours Earnings Description Current YCD
Regular 9.97 79.38 791.42 1,765.63 17,603.34 Fed Withholdng 101.16 2
418.61
HolGft 35.00 35.00 FedMED/EE 11.43 ,
270.70
Fed OASDI/EE 48.89 1,157.48
PA U=npl EE 0.50 11.75
PA Withholdng 24.21 573.16
PACARLISLEBORO 12.62 298.70
Withholdng
PA CARLISLE LS Tax 2.00 48.00
Total: 79.38 826.42 1,765.63 19,577.94 Total: 200.81 4,778.40
.:v:::: env: .. v::: 4.v
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Description Current YCD Description Current YCD Description Cmrcnt YPD
Geisinger Health Plan 37.87 908.88 Geisinger Health Plan 93.23 2
244
14
401 (k) Savings Plan 47.49 1,17158 401(k) Savings Plan 33.63 ,
.
830.62
• Taxable
Total: 85.36 2,081.46 Total: 0.00 •0 Total:
126.86
3074.76
,
::.vv+}i2::2:h+..j-i'}.:iti??222:i i}:?hi??:i:-,.:j.{~ ivvfiry-. _
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Cm=t 826.42 741.06 200.81 8536 540
25
YTD 19,577.94 17,496.48 4,778.40 2,081.46 .
12,718.08
This pay stub information reflects your payroll data at the time
the check or direct deposit was generated. It may not include 4'•:f=+ix?-...}-.}}---•`•?::.;
adjustments or reversals subsequently applied, and therefore, does Advice #0000019272883 540.25
not represent a guarantee of payroll earnings distributed to you.
Total: 540.25
MESSAGE:
Lowe's Home Centers, Inc.
POBox 1111
Hwy 268E
N Wilkesboso,NC 28656
Deposit Amount: 540.25
To The
Account(s) Of:
Linda J. Foreman
2441 Ritner Highway
Carlisle, PA 17015
Location:CatlislF PA
Pay Group: LHE Business Unit: 01710
Pay Begin Date: 11/01/2008 Advice#: 000000019272883
Pay End Date. 11/142008 Advice Date: 11/21/2008
AccormtType Account Number Deposit Amount
Checking •**"-'0301 540.25
Total: 540.25
Advice No.
19272883
NON-NEGOTIABLE
ill
RICHARD D. FOREMAN, JR
Plaintiff
V.
LINDA J. FOREMAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2007-3124 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
MOTION FOR HEARING ON ALIMONY PENDENTE LITE
ALIMONY AND COUNSEL FEES
1. Movant is Robert L. O'Brien, Esquire, attorney for the Defendant in the
above-captioned divorce action.
2. On December 9, 2008, Defendant filed an Answer and Counterclaim and
raised issues requesting that Plaintiff pay to her, alimony pendente lite, alimony and
counsel fees and costs.
3. Plaintiff, Richard D. Foreman, Jr., has filed an application with the
Domestic Relations office to terminate his spousal support payment.
4. Movant requests that the Defendant's request for alimony pendente lite
and counsel fees be heard at the same time that the support master hears Mr.
Foreman's request for the termination of spousal support.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
Date: Z 11 -7/0 F_
Robert L. O'Brien, Esquire
I.D. # 28351
O'Brien, Baric & Scherer
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
Attorney for Defendant
CERTIFICATE OF SERVICE
I hereby certify that on the 1Q 14141
day of T)2-
O'Brien, Esquire, of O'Brien, Baric & Scherer, did s ' I° Robert L.
2008
on Alimony Pendente Lite, Alimony and serve a copy of the Motion for Hearing
Counsel Fees, by first class U.S. mail, postage
prepaid, to the party listed below, as follows:
Sally J. Winder, Esquire
P.O. Box 341
Newville, Pennsylvania 17241
Robert L. O'Brien, Esquire
-, '?:?
.,
__, ...?
c°? ??
iv ? -?-
-
..,. i
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Y? .? X
Cua
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
LINDA J. FOREMAN ) Docket Number ??-3124 CfVIL
Plaintiff )
vs. ) PACKS Case Number
RICHARD D. FOREMAN JR )
Defendant ) Other State ID Number
ORDER OF COURT
You,
LINDA JANE FOREMAN
plaintiff/defendant of
2441 RITNER HWY, CARLISLE, PA. 17015-7920-41
are ordered to appear at DOMESTIC RELATIONS HEARING RM
DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13
before a hearing officer of the Domestic Relations Section, on the
JANUARY 22, 2009
at s : 3 OAM for a hearing.
You are further required to bring to the hearing:
1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed,
2. your pay stubs for the preceding six (6) months,
3. the Income Statement and the appropriate Expense Statement, if required, attached to this order,
completed as required by Rule 1910.11 (c).
4. verification of child care expenses, and
5. proof of medical coverage which you may have, or may have available to you
6. information relating to professional licenses
7. other:
Service Type M
Form CM-509 Rev. I
Worker ID 21302
? 1%&
FOREMAN
PACSES Case Number: 874110567
If you fail to appear for the conference/hearing or to bring the required documents, the
court may issue a warrant for your arrest and/or enter an interim support order. If paternity is
an issue, the court shall enter an order establishing paternity.
THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST
EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD
TO WHICH PARTY INITIATED THE SUPPORT ACTION.
BY THE COURT:
Date of Order: 12-29-OR
* X4
JUDGE
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE
CONFERENCE-HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
v• FOREMAN
CUMBERLAND CO BAR ASSOCIATION
32 S BEDFORD ST
CARLISLE PA 17013-3302-32
(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 at: (717) 240-6225 . All arrangements must be
made at least 72 hours prior to any hearing or business before the court. You must attend the
scheduled hearing.
Service Type M
Page 2 of 2
Form CM-509 Rev. 1
Worker ID 21302
C-)
'A-
CL- --
,.. C N
C
en
t- ,-%
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
LINDA J. FOREMAN ) Docket Number t7-3124` CIVIL
Plaintiff )
vs. ) PACSES Case Number 61771105,67
RICHARD D. FOREMAN JR )
Defendant ) Other State ID Number
ORDER OF COURT
You, RICHARD DALE FOREMAN JR plaintiff/defendant of
386 SPRINGFIELD RD, SHIPPENSBURG, PA. 17257-9557-86
are ordered to appear at DOMESTIC RELATIONS HEARING RM
DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13
before a hearing officer of the Domestic Relations Section, on the
JANUARY 22, 2009 at 8: 3 0AM for a hearing.
You are further required to bring to the hearing:
1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed,
2. your pay stubs for the preceding six (6) months,
3. the Income Statement and the appropriate Expense Statement, if required, attached to this order,
completed as required by Rule 1910.11 (c).
4. verification of child care expenses, and
5. proof of medical coverage which you may have, or may have available to you
6. information relating to professional licenses
7. other:
Service Type M
Form CM-509 Rev. I
Worker ID 21302
, "+
FOREMAN
PACSES Case Number: 874110567
If you fail to appear for the conference/hearing or to bring the required documents, the
court may issue a warrant for your arrest and/or enter an interim support order. If paternity is
an issue, the court shall enter an order establishing paternity.
THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST
EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD
TO WHICH PARTY INITIATED THE SUPPORT ACTION.
BY THE COURT:
Date of Order: 1-x.5 .. A
JUDGE
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE
CONFERENCE-HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
V• FOREMAN
CUMBERLAND CO BAR ASSOCIATION
32 S BEDFORD ST
CARLISLE PA 17013-3302-32
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of CUMBER
comply with the Americans with Disabilities Act of 1
facilities and reasonable accommodations available to
before the court, please contact our office at: (717)
made at least 72 hours prior to any hearing or business
scheduled hearing.
Service Type M
Page 2 of 2
LAND County is required by law to
990. For information about accessible
disabled individuals having business
240-6225 - All arrangements must be
before the court. You must attend the
Form CM-509 Rev.
Worker ID 21302
c?' C
i_
\ 'Ji
ti-
c" C
CZ,
CV ( j
fil
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
LINDA J. FOREMAN ) Docket Number 07-3124 CIVIL
Plaintiff )
vs. ) PACSES Case Number 874110567
RICHARD D. FOREMAN JR )
Defendant ) Other State ID Number
ORDER OF COURT - RESCHEDULE A HEARING
You,
LINDA JANE FOREMAN
2441 RITNER HWY, CARLISLE, PA. 17015-7920-41
are ordered to appear at DOMESTIC RELATIONS HEARING RM
of
DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13
On the 11TH DAY OF FEBRUARY, 2009
the prior hearing date Of JANUARY 2 2, 2 0 0 9
at 10 : 30AM fora hearing. This date replaces
You are further required to bring to the hearing:
1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed,
2. your pay stubs for the preceding six (6) months,
3. the Income Statement and the appropriate Expense Statement, if required, attached to this order,
completed as required by Rule 1910.11 (c).
4. verification of child care expenses, and
5. proof of medical coverage which you may have, or may have available to you
6. information relating to professional licenses
7. other:
Service Type M
Form CM-514 Rev. 1
Worker ID 21302
w
FOREMAN V. FOREMAN PACSES Case Number: 874110567
If you fail to appear for the conference/hearing or to bring the required documents, the
court may issue a warrant for your arrest and/or enter an interim support order. If paternity is
an issue, the court shall enter an order establishing paternity.
THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST
EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD
TO WHICH PARTY INITIATED THE SUPPORT ACTION.
BY THE COURT:
Date of Order: 1-1lb - cm
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE
CONFERENCE-HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
. X4
doe- JUDGE
CUMBERLAND CO BAR ASSOCIATION
32 S BEDFORD ST
CARLISLE PA 17013-3302-32
(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 at: (73.7) 2 4 0 - 6 2 2 5 . All arrangements must be
made at least 72 hours prior to any hearing or business before the court. You must attend the
scheduled hearing.
Service Type M
Page 2 of 2
Form CM-514 Rev. 1
Worker ID 21302
O
f I'vl
rin
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
LINDA J. FOREMAN ) Docket Number 07-3124 CIVIL
Plaintiff )
VS. ) PACSES Case Number 874110567
RICHARD D. FOREMAN JR )
Defendant ) Other State ID Number
ORDER OF COURT - RESCHEDULE A HEARING
You, RICHARD DALE FOREMAN JR Of
386 SPRINGFIELD RD, SHIPPENSBURG, PA. 17257-9557-86
are ordered to appear at DOMESTIC RELATIONS HEARING RM
DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13
on the 11TH DAY OF FEBRUARY, 2009
the prior hearing date Of JANUARY 2 2, 2 0 0 9
at 10:3 0AM fora hearing. This date replaces
You are further required to bring to the hearing:
1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed,
2. your pay stubs for the preceding six (6) months,
3. the Income Statement and the appropriate Expense Statement, if required, attached to this order,
completed as required by Rule 1910.11 (c).
4. verification of child care expenses, and
5. proof of medical coverage which you may have, or may have available to you
6. information relating to professional licenses
7. other:
Service Type M
Form CM-514 Rev. 1
Worker ID 21302
FOREMAN V. FOREMAN PACSES Case Number: 874110567
If you fail to appear for the conference/hearing or to bring the required documents, the
court may issue a warrant for your arrest and/or enter an interim support order. If paternity is
an issue, the court shall enter an order establishing paternity.
THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST
EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD
TO WHICH PARTY INITIATED THE SUPPORT ACTION.
BY THE COURT:
Date of Order: I . ).p - t!%
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE
CONFERENCE-HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
JUDGE
CUMBERLAND CO BAR ASSOCIATION
32 S BEDFORD ST
CARLISLE PA 17013-3302-32
(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 at: (73.7) 240-6225 . All arrangements must be
made at least 72 hours prior to any hearing or business before the court. You must attend the
scheduled hearing.
Service Type M
Page 2 of 2
Form CM-514 Rev. 1
Worker ID 21302
N
ce) 7
C >
IY' CI
N ,
C.?
LINDA J. FOREMAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : DOMESTIC RELATIONS SECTION
RICHARD D. FOREMAN, JR., PACSES NO. 493102434
Defendant DOCKET NO. 579 SUPPORT 2000
RICHARD D. FOREMAN, JR., IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA
V. DOMESTIC RELATIONS SECTION
LINDA J. FOREMAN, PACSES NO. 874110567
Defendant/Petitioner DOCKET NO. 2007-3124 CIVIL
INTERIM ORDER OF COURT
AND NOW, this 17th day of February, 2009, upon consideration of the Support
Master's Report and Recommendation, a copy of which is attached hereto as Exhibit
"A", it is ordered and decreed as follows:
A. The spousal support order entered to 579 Support 2000 is suspended effective
November 12, 2008.
B. Effective December 1, 2008 the Husband shall pay to the Pennsylvania State
Collection and Disbursement Unit as alimony pendente lite the sum of $256.00
per month.
C. Any arrearage or credit remaining on PACSES Case 493102434 shall be applied
accordingly to PACSES Case 874110567.
IMPORTANT LEGAL NOTICE
PARTIES MUST WITHIN SEVEN DAYS INFORM THE DOMESTIC
RELATIONS SECTION AND THE OTHER PARTIES, IN WRITING, OF ANY
MATERIAL CHANGE IN CIRCUMSTANCES RELEVANT TO THE LEVEL OF
SUPPORT OR THE ADMINISTRATION OF THE SUPPORT ORDER,
INCLUDING, BUT NOT LIMITED TO, LOSS OR CHANGE OF INCOME OR
EMPLOYMENT AND CHANGE OF PERSONAL ADDRESS OR CHANGE OF
ADDRESS OF ANY CHILD RECEIVING SUPPORT. A PARTY WHO
WILLFULLY FAILS TO REPORT A MATERIAL CHANGE IN CIRCUMSTANCES
MAY BE ADJUDGED IN CONTEMPT OF COURT, AND MAY BE FINED OR
IMPRISONED.
PENNSYLVANIA LAW PROVIDES THAT ALL SUPPORT ORDERS
SHALL BE REVIEWED AT LEAST ONCE EVERY THREE (3) YEARS IF SUCH
REVIEW IS REQUESTED BY ONE OF THE PARTIES. IF YOU WISH TO
REQUEST A REVIEW AND ADJUSTMENT OF YOUR ORDER, YOU MUST DO
THE FOLLOWING: CALL YOUR ATTORNEY. AN UNREPRESENTED
PERSON WHO WANTS TO MODIFY (ADJUST) A SUPPORT ORDER SHOULD
CONTACT THE DOMESTIC RELATIONS SECTION. ALL CHARGING
ORDERS FOR SPOUSAL SUPPORT AND ALIMONY PENDENTE LITE,
INCLUDING UNALLOCATED ORDERS FOR CHILD AND SPOUSAL SUPPORT
OR CHILD SUPPORT AND ALIMONY PENDENTE LITE, SHALL TERMINATE
UPON DEATH OF THE PAYEE.
A MANDATORY INCOME ATTACHMENT WILL ISSUE UNLESS THE
DEFENDANT IS NOT IN ARREARS IN PAYMENT IN AN AMOUNT EQUAL TO
OR GREATER THAN ONE MONTH'S SUPPORT OBLIGATION AND (1) THE
COURT FINDS THAT THERE IS GOOD CAUSE NOT TO REQUIRE
IMMEDIATE INCOME WITHHOLDING; OR (2) A WRITTEN AGREEMENT IS
REACHED BETWEEN THE PARTIES WHICH PROVIDES FOR AN
ALTERNATE ARRANGEMENT. UNPAID ARREARAGE BALANCES MAY BE
REPORTED TO CREDIT AGENCIES. ON AND AFTER THE DATE IT IS DUE,
EACH UNPAID SUPPORT PAYMENT SHALL CONSTITUTE, BY OPERATION
OF LAW, A JUDGMENT AGAINST YOU, AS WELL AS A LIEN AGAINST REAL
PROPERTY. IT IS FURTHER ORDERED THAT, UPON PAYOR'S FAILURE TO
COMPLY WITH THIS ORDER, PAYOR MAY BE ARRESTED AND !BROUGHT
BEFORE THE COURT FOR A CONTEMPT HEARING; PAYOR'S WAGES,
SALARY, COMMISSIONS, AND/OR INCOME MAY BE ATTACHED IN
ACCORDANCE WITH LAW. PAYOR IS RESPONSIBLE FOR COURT COSTS
AND FEES.
The parties are hereby advised that they may file written exceptions to the
Support Master's Report and Recommendation within twenty (20) days of this order.
Exceptions shall conform with the requirements of Rule 1910.12(f), Pa. R.C.P. If written
exceptions are filed by any party, the other party may file exceptions within twenty (20)
days of the date of service of the original exceptions. If no exceptions are filed within
twenty (20) days of this interim order, this order shall then constitute a final order.
1-4--
00
By the Court,
,4)64
Kevin A. Hess, J.
Cc: Linda J. Foreman
Richard D. Foreman, Jr.
Robert L. O'Brien, Esquire
For the Plaintiff
Sally Winder, Esquire
For the Defendant
DRO
LINDA J. FOREMAN,
Plaintiff
V.
RICHARD D. FOREMAN, JR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DOMESTIC RELATIONS SECTION
PACSES NO. 493102434
DOCKET NO. 579 SUPPORT 2000
RICHARD D. FOREMAN, JR., IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA
V. DOMESTIC RELATIONS SECTION
LINDA J. FOREMAN, PACSES NO. 874110567
Defendant/Petitioner DOCKET NO. 2007-3124 CIVIL
SUPPORT MASTER'S REPORT AND RECOMMENDATION
Following a hearing held before the undersigned Support Master on
February 11, 2009, the following report and recommendation are made:
FINDINGS OF FACT
1. The Wife is Linda J. Foreman, who resides at 2441 Ritner Highway, Carlisle,
Pennsylvania.
2. The Husband is Richard D. Foreman, Jr., who resides at 386 Springfield Road,
Shippensburg, Pennsylvania.
3. The parties were married on December 1, 1973.
4. The parties separated in 2000.
5. All of the parties' children are emancipated.
6. By order dated August 3, 2000 the Husband became obligated to pay spousal support
in the amount of $438.74 per month.
7. On November 12, 2008 the Husband filed a petition for modification of the spousal
support order.
8. On November 14, 2008 the Husband filed a praecipe to reinstate a complaint in
divorce previously filed in 2007.
EXHIBIT "A"
9. On December 22, 2008 the Wife filed her request for hearing de novo on her claim
for alimony pendente lite contained in the Answer and Counterclaim filed to the
divorce action.
10. The Wife does not contest the termination of spousal support effective November 12,
2008.
11. The Wife resides in the home of Joseph Thomas.
12. In lieu of rent the Wife provides housekeeping services and care for animals on the
Thomas property.
13. The Wife is employed by Lowe's Home Centers, Inc. where she earned $20,282.25 in
2008.
14. The Wife's tax filing status is married/separate.
15. The Wife provides health insurance coverage on herself through her employment at a
cost of $37.87 bi-weekly.
16. The Husband is primarily employed as a herdsman at a local dairy farm where he
earned $25,680.00 in 2008.
17. The Husband has a part-time job at Carlisle Livestock Market where he earned
$2,820.00 in 2008.
18. The Husband is also self-employed as an auctioneer working primarily at the
Shippensburg Auction Center.
19. In 2007the Husband reported net profit from self-employment of $1,067.00 based
upon gross income of $15,368.00.
20. The Husband estimates his gross income from self-employment in 2008 to be
$16,785.00, of which $15,685.00 was earned at the Shippensburg Auction Center.
21. The Husband estimates that his self-employment expenses in 2008 will be similar to
that which he incurred in 2007.
22. The Husband files his federal income tax return as married/separate.
23. The Wife has filed an economic claim for alimony in the divorce action, but neither
party has filed a claim for equitable distribution.
2
DISCUSSION
Because the Wife has not contested the suspension of the spousal support obligation
effective November 12, 2008, a recommendation is made that the spousal support order
entered to 579 Support 2000 be suspended accordingly.
In Clouse v. Clouse, 50 Cumberland L.J. 167, 170 (2001) the Honorable
J. Wesley Oler discussed the law of Pennsylvania as it relates to the subject of alimony
pendente lite wherein he stated:
The determination of whether to award alimony pendente lite has
traditionally been a matter within the sound discretion of the trial court.
Litman v. Litmans, 449 Pa. Superior Ct. 209, 222, 673 A.2d 382, 388 (1996)
(citing Murphy v. Murphy, 410 Pa. Superior Ct. 146, 599 A.2d 647 (1991),
appeal denied, 530 Pa. 633, 606 A.2d 902 (1992), cert. denied, 506 U.S. 868,
113 S.Ct. 196, 121 L.Ed. 2d 139 (1992)). APL is based on the need of one
spouse to have the financial resources to pursue or defend a divorce action.
Litmans, supra at 222, 763 A.2d at 388. The claimant must show that APL is
needed to adequately preserve his or her rights in the litigation. Sutliff v.
Sutliff, 326 Pa. Superior Ct. 496, 500, 474 A.2d 599, 600 (1984), overruled on
other grounds, Rosen v. Rosen, 520 Pa. 19, 549 A.2d 561 (1988). In this
regard, the Pennsylvania Superior Court has stated that "a spouse seeking
alimony pendente lite who has sufficient assets to meet the needs of the
pending litigation and who is equally situated with the other spouse to
maintain or defend the action, will not be awarded alimony pendente lite."
Powers v. Powers, 419 Pa. Superior Ct. 464, 467, 615 A.2d 459, 460 (1992).
In adjudicating a claim for alimony pendente lite, a court should
consider the following factors: "the ability of the other party to pay; the
separate estate and income of the petitioning party; and the character,
situation, and surroundings of the parties." Litmans, supra. at 224, 673 A.2d
at 389.
Once entitlement to an award of alimony pendente lite is established, the calculation
of the amount of the award is made pursuant to the support guidelines. Little v. Little,
47 Cumberland L.J. 131 (1998).
The Wife, although gainfully employed, has been able to maintain her living expenses
only with the assistance of spousal support received from the Husband since the separation in
2000. The spousal support will now be suspended. She continues to need assistance to
litigate her economic claim in the divorce action.
The Wife has gross monthly income of $1,690.00. Filing her federal income tax
return as married/separate, she has net monthly income for support purposes of $1,382.00.1
' See Exhibit "A" for the tax deductions from gross income.
3
The Husband has gross annual wages from employment on a dairy farm and at the
Carlisle Livestock Market of $28,500.00. He has annual net profit from self-employment of
approximately $2,484.00.2 With total gross annual income of $30,984.00, and a tax filing
status of married/separate, the Husband has net monthly income for support purposes of
$2,022.00.3
With net monthly income for the Husband of $2,022.00 and for the Wife of
$1,382.00, and no minor children, the Husband's oblifation for alimony pendente lite
calculated under the guidelines is $256.00 per month.
The parties have stipulated that if entitlement to an award of alimony pendente lite is
found, the effective date of the order would be December 1, 2008.
RECOMMENDATION
A. The spousal support order entered to 579 Support 2000 is suspended effective
November 12, 2008.
B. Effective December 1, 2008 the Husband shall pay to the Pennsylvania State
Collection and Disbursement Unit as alimony pendente lite the sum of $256.00 per
month.
C. Any arrearage or credit remaining on PACSES Case 493102434 shall be applied
accordingly to PACSES Case 874110567.
Date
Y u a-4-4s.o ot-?
Michael R. Rundle
Support Master
2 The Husband's 2007 business expenses have been deducted from his 2008 gross income to estimate the annual
net profit for 2008.
3 See Exhibit "A" for the tax deductions from gross income.
4 See Exhibit "B" for the calculation.
4
. In the Court of Common Pleas of Cumberland County, Pennsylvania
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Plaintiff Name: Linda J. Foreman
Defendant Name: Richard D. Foreman Jr.
Docket Number: 2007-3124 Civil
PACSES Case Number: 874110567
Other State ID Number:
Tax Year: Current: 2008
1. Tax Method 1040 ES 1040 ES
2. Fling Status Married Filing
Separately Married Filing
Separately
3. Who Claims the Exemptions Obli ee
4. Number of Exemptions 1 1
5. Monthly Taxable Income $2,582.00 $1,690.20
6. Deductions Method Standard Standard
7. Deduction Amount $454.17 $454.17
8. Exemption Amount $291.67 $291.67
9. Income MINUS Deductions and Exemptions $1,836.16 $944.36
10. Tax on Income $241.99 $108.22
11. Child Tax Credit - -
12. Manual Adjustments to Taxes - -
13. Federal Income Taxes $241.99 $108.22
13 a. Earned Income Credit - -
14. State Income Taxes $81.59 $53.41
15. FICA Payments $210.67 $129.30
16. City Where Taxes Apply --Select-- --Select--
17. Local Income Taxes $25.82 $16.90
TOTAL Taxes $560.07 $307.83
SupportCalc 2007
EXHIBIT "A"
In the Court of Common Pleas of Cumberland County, Pennsylvania
Plaintiff Name: Linda J. Foreman
Defendant Name: Richard D. Foreman Jr.
Docket Number: 2007-3124 Civil
PACSES Case Number: 874110567
Other State ID Number:
1.Obligor's Month/ Net Income $2,021.93
2. Less All Other Support
3. Less Obli ee's Month/ Net Income $1,382.37
4. Difference $639.56
5. Less Child Support Obligation for Current Case
6. Difference $639.56
7. Multiply b 30% or 40% 40.00%
8. Income Available for Spousal Support $255.82
9. Adjustment for Other Expenses
10. AMOUNT OF MONTHLY SPOUSAL SUPPORT OR APL $255.82
Prepared b : mrr Date: 2/12/2009
supportca?c 2008
EXHIBIT "B"
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RICHARD D. FOREMAN, JR.,
Plaintiff/Respondent
VS.
LINDA J. FOREMAN,
Defendant/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 07-3124 CIVIL TERM
IN DIVORCE
PACSES CASE: 874110567
ORDER OF COURT
AND NOW to wit, this 17th day of February 2009, it is hereby Ordered that the sum of
$280.08 is credited to the Alimony Pendente Lite account from the spousal support account under
Case #493102434.
There is a remaining balance of $487.92 owed to the Petitioner. The Respondent is to
report to the Domestic Relations Section within twenty (20) days for a payment plan of the
remaining balance.
BY THE COURT:
Kev' Hess, J.
DRO: R.J. Shadday
xc: Petitioner
Respondent
Robert L. O'Brien, Esq.
Sally J. Winder, Esq.
Form OE-001
Service Type: M Worker: 21005
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LINDA J. FOREMAN,
Plaintiff
V.
RICHARD D. FOREMAN, JR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DOMESTIC RELATIONS SECTION
PACSES NO. 493102434
DOCKET NO. 579 SUPPORT 2000
RICHARD D. FOREMAN, JR., IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA
V. DOMESTIC RELATIONS SECTION
LINDA J. FOREMAN, PACSES NO. 874110567
Defendant/Petitioner DOCKET NO. 2007-3124 CIVIL
INDEX OF EXHIBITS
Petitioner's 1 - 2008 W-2
Petitioner's 2 - Checking account statements
Petitioner's 3 - Checking account statements
Petitioner's 4 - IRS standards
Petitioner's 5 - Earnings statement
Respondent's 1 - Deed
Respondent's 2 - Income and expense statement
Respondent's 3 - 2007 federal tax return
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsylvania
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 02/17/09
Case Number (See Addendum for case summary)
Employer/Withholder's Federal EIN Number
HARPER HERSHEY'S DAIRY
3 OAKVILLE RD
SHIPPENSBURG PA 17257-9773
191-46-4765
Employee/Obligor's Social Security Number
9364100570
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$
$
$ 0.00
0.00
0.00
$ 0.00
$ 256.00
$ 0.00
$ 0.00
$ 0.00
for a total of $
per month in current child support
per month in past-due child support
per month in current medical support
per month in past-due medical support
per month in current spousal support
per month in past-due spousal support
per month for genetic test costs
per month in other (specify)
one-time lump sum payment
256.00 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:
$ 59 _ ()R per weekly pay period. $ 128.00 per semimonthly pay period
(twice a month)
$ 11 R _ 1 S per biweekly pay period (every two weeks) $ 256.00 per monthly pay period.
REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10)
working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of
withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work
state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of
the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding,
the following information is needed (See #9 on page 2).
If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call
Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580
for instructions. PA FIPS CODE 42 000 00
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S 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:
DRO: R.J. Shadday
Service Type m
493102434
579 S 2000
07-3124 CIVIL
OOriginal Order/Notice
OAmended Order/Notice
0Terminate Order/Notice
QOne-Time Lump Sum/Notice
RE: FOREMAN, RICHARD D. JR
Employee/Obligor's Name (Last, First, MI)
Arrears 12 weeks or greater? O yes ® no
OMB No, 0970-0154
A. Hess, Judge
Form EN-028 Rev. 4
Worker ID $IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
Ej If heckefl you are required to provide asopy of this form to your gmployee. If yo r employee works in a state that is
di Brent rom the state that issued this or er, a copy must be provided to your employee even if the box is not checked.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. if there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employee/obligor.
3.* Reporting the Paydate/Date of Withholding: You must report the paydate/date of withholding when sending the payment. The
paydate/date of withholding is the date on which amount was withheld from the employee's wages. You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. 8394100136
THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : 0 THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 13
EMPLOYEE'S/OBLIGOR'S NAME: FOREMAN, RICHARD D. JR
EMPLOYEE'S CASE IDENTIFIER: 9364100570 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:.
LAST KNOWN PHONE NUMBER:
FINAL PAYMENT AMOUNT-
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment,
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9.* Withholding Limits: You may not withhold more than the lesser of. 1) the amounts allowed by the Federal Consumer Credit
Protection Act (CCPA) (15 U.S.C. 1673 (b)); or 2) the amounts allowed by the State or Tribe of the employee's/obligor's principal place of
employment. Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes, Social
Security taxes, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is
supporting another family and 60% of the disposable income if the obligor is not supporting another family.However, that 50% limit is
increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State, you may
deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section.
Arrears greater than 12 weeks : If the Order Information does not indicate whether the arrears are greater than 12 weeks, then the
employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts
allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser of
the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of the
CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amounts paid for health
care premiums in determining disposable income and applying appropriate withholding limits.
10. Additional info:
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state
that issued this order with respect to these items.
11. Send Termination Notice and
other correspondence to:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717) 240-6248 or
by internet www.childsupport.state.pa.us
Page 2 of 2 Form EN-028 Rev. 4
Service Type M OMB No.: 0970-0154 Worker ID $IATT
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: FOREMAN, RICHARD D. JR
PACSES Case Number 874110567
Plaintiff Name
LINDA J. FOREMAN
Docket Attachment Amount
07-3124 CIVIL$ 256.00
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
PACKS Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
Addendum Form EN-028 Rev. 4
Service Type M $IATT
OMB No.: 0970-0154 Worker ID
M-7
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DOMESTIC RELATIONS SECTION
FOREMAN, LINDA J.
Plaintiff
V.
FOREMAN, RICHARD D. JR.
Defendant
TO: Commonwealth of Pennsylvania
Treasury Department
Bureau of Unclaimed Property
PO Box 1837
Harrisburg, PA 17105
Docket Number 07-3124 CIVIL
PACSES Number 874110567
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Lump Sum Order of Attachment of Income -< x o
N 00
Pursuant to the laws of the Commonwealth of Pennsylvania, the income of Richard D. Foreman Jr., Defendant, Social
Security Number 191-46-4765, Claim number,7239154 , is hereby attached as follows: You are directed to pay to the Cumberland
County Domestic Relations Section a lump sum payment in the amount not to exceed $231.00 due from Defendant's unclaimed
property. The attachment payment must be sent to the Cumberland County Domestic Relations Section within seven (7) working days
of the pay date/date of withholding. The check should be made payable to and mailed to the Cumberland County Domestic Relations
Section, PO Box 320, Carlisle, PA 17013.
THE MEMBER NUMBER, 9364100570, SOCIAL SECURITY NUMBER 191-46-4765 AND NAME OF
DEFENDANT MUST APPEAR ON THE FACE OF THE CHECK TO APPLY CREDIT TO THE PROPER ACCOUNT.
This order of attachment for support is binding upon you until further notice and shall have priority over any attachment,
execution, garnishment or wage attachment under state or local law except one relating to a prior support order.
You are notified further that pursuant to law:
I . The Defendant has been notified that an order of attachment for support would be issued.
2. Willful failure to comply with this order may result in i) you being adjudged in contempt of court and committed
to jail or fined by the court„ ii) you being held liable for any amount not withheld or withheld but not forwarded
to the Domestic Relations Section, and iii) attachment of your funds or property.
3. The attachment of income or the possibility thereof as a basis, in whole or in part, for the discharge of an
employee or any disciplinary action against or demotion of an employee is prohibited. Violation may result in i)
you being adjudged in contempt and committed to jail or fined by the court and ii) an action against you by
the employee for damages.
4. The maximum amount of the attachment shall not exceed the limit of withholding covered under section 303(b) of
the Consumer Credit Protection Act, 15 U.S.C. §I673(b)I.
5. You must notify the Domestic Relations Section when the defendant terminates employment and provide the
Domestic Relations Section with the employee's last known address and the name and address of the new
employer, if known.
6. The term "income" as defined by law includes compensation for services. including, but not limited to, wages:
salaries: fees; compensation in kind; commissions and similar items; income derived from business, gains derived
from dealings in property; interest; rents; royalties, dividends: annuities: income from life insurance and
endowment contracts: all forms of retirement; pensions; income from discharge of indebtedness; distributive share
of partnership gross income; income in respect of a decedent; income from and interest in an estate or trust:
military retirement benefits; railroad employment retirement benefits: social security benefits: temporary and
permanent disability benefits; Worker's compensation and unemployment compensation; or other entitlements
to money or lump sum awards, without regard to source, including lottery winnings; income tax refunds;
insurance compensation or settlements, awards or verdicts; and any form of payment due to and collectible by an
individual regardless of source.
n1jf?J.NNBY TH URT:
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Date of Order April 20, 2010
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- INCOME WITHHOLDING FOR SUPPORT �-�4- I 1 DSL-,
0 ORIGINAL INCOME WITHHOLDING ORDER/NOTICE FOR SUPPORT(IWO) C1 U l I
O AMENDED IWO 2 1 aL]
O ONE-TIMEORDERINOTICE FOR LUMP SUM PAYMENT J 1
O TERMINATION OF IWO Date: 09/09/13
❑ Child Support Enforcement(CSE)Agency ® Court ❑ Attorney ❑ Private Individual/Entity(Check One)
NOTE:This IWO must be regular on its face. Under certain circumstances you must reject this IWO and return it to the sender(see IWO
instructions http://www acf hhs gov/programs/cse/newhire/employer/publication/publication htm-forms). If you receive this document from
someone other than a State or Tribal CSE agency or a Court, a copy of the underlying order must be attached.
Staterrriberrerritory Commonwealth of Pennsylvania Remittance Identifier(include w/payment): 9364100570
City/County/Dist./Tribe CUMBERLAND Order Identifier: (See Addendum for order/docket informaiton)
Private Individual/Entity CSE Agency Case Identifier: (See Addendum for case summary)
SOCIAL SECURITY ADMINISTRATION RE: FOREMAN, RICHARD D.JR
STE 1 Employee/Obligor's Name(Last, First,Middle)
200 S SPRING GARDEN ST 191-46-4765
CARLISLE PA 17013-2578 Employee/Obligor's Social Security Number
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Party/Obligee's Name(Last, First,
Middle)
Employer/Income Withholder's FEIN NOTE:This IWO must be regular on its face.
Under certain circumstances you must reject
Child(ren)'s Name(s)(Last, First,Middle) Child(ren)'s Birth Date(s) this IWO and return it to the sender(see IWO
instructions
htti)://www.acf.hhs.gov/programs/cse/newhire/
eml2loyer/r)ublication/publication.htm-forms).If
you receive this document from someone other
than a State or Tribal CSE agency or a Court,a
copy of the underlying order must be attached.
8384100092
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This document is based on the support or withholding order from CUMBERLAND County,
Commonwealth of Pennsylvania (State/Tribe). You are required by law to deduct these amounts from the employee/
obligor's income until further notice. c -1
$ 0.00 per month in current child support rn=
$ 0.00 per month in past-due child support- Arrears 12 weeks or greater? O yea9 ��
$ 0.00 per month in current cash medical support =r- ::u
$ 0.00 per month in past-due cash medical support -< ° -�-IC-"7
$ 256.00 per month in current spousal support �C:? =
$ 0.00 per month in past-due spousal support C�k C:)
$ 0.00 per month in other(must specify)
for a Total Amount to Withhold of$ 256.00 per month. Cn
AMOUNTS TO WITHHOLD: You do not have to vary your pay cycle to be in compliance with the Order Information.
If your pay cycle does not match the ordered payment cycle, withhold one of the following amount:
$ 58.92 per weekly pay period. $ 128.00 per semimonthly pay period (twice a month)
$ 117.83 per biweekly pay period (every two weeks) $ 256.00 per monthly pay period.
$ Lump Sum Payment: Do not stop any existing IWO unless you receive a termination order.
REMITTANCE INFORMATION: If the employee/obligor's principal place of employment is within the Commonwealth
of Pennsylvania (State/Tribe), you must begin withholding no later than the first pay period that occurs ten 10
working days after the date of this Order/Notice. Send payment within seven 7 working days of the pay date. If
you cannot withhold the full amount of support for any or all orders for this employee/obligor, withhold up to 55 110 of
disposable income for all orders. If the employee/obligor's principal place of employment is not within the
Commonwealth of Pennsylvania (State/Tribe), the employer can obtain withholding limitations, time requirements,
and any allowable employer fees at http://www.aef.hhs.ciov/programs/cse/newhire/employer/contacts/contact map.
htm for the employee/obligor's principal place of employment.
Document Tracking Identifier
OMB No.:0970-0154 Form EN-028 06/12
Service Type M Worker ID $OINC
E] Return to Sender[Completed by Employer/income Withho|dmH^ Payment must Le directed bzanSDUin �
accordance with 42U0C§6O0(b)(5)and (b)(0)or Tribal Payee(see Payments bo8OUbeloxv . If payment ianot
directed to an SDU/TdbalPevea or this |WOis not regular on its face, check
the sender.
Signature of Judge/Issuing Official (if required by State or Tribal law):
Print Name of Judge/Issuing Official: Ed;�� Ld"gicpao
Title of Judge/Issuing Official:
Date of Signature:
If the employee/obligor works in a State or for a Tribe that is different from the State or Tribe that issued this order,a copy of this|VVU
must be provided to the employom/ob|ignr
171 If checked,the employer/income withholder must provide a copy of this form to the employee/obligor.
ADDITIONAL INFORMATION FOR E&8PLOYERS/INCOK0EVVITHHOLDERS
Pennsylvania law(23 PA C.S.§4374(b))requires remittance bysn electronic payment method |fmn employer|aordered
to withhold income from more than one employee and employs 15 ov more persons,orifmn employer has a history of
two o,more returned checks due tmnonoufMc|entfunds. Please call the Pennsylvania State Collections and
Disbursement Unit(PA SCDU)Employer Customer Service m&1~8?7-676-9580 for instructions. PA FlPS CODE 42A00 0$
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDL1, U».O. Box 69112, Harrisburg, Pa 17106~9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAMEAND THE PACSES MEMBER/D(shown above aa
the Employeel0bligor's Case Identifler)OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT
SEND CASH BY MA/1.
State-specific contact and withholding information can be found on the Federal Employer Services website located at:
Priority: Withholding for support has priority over any other legal process under State law against the same income(USC 42
Q6G5(b)(7)). |fo Federal tax levy isin effect, please notify the sender.
Combining Payments: When remitting payments to an SDU or Tribal CSE agency,you may combine withheld amounts from
more than one em ployee/obl 1gor's income in a single payment. You must, however, separately identify each employee/
obligor's portion of the payment.
Payments To SDU: You must send child support payments payable by income withholding to the appropriate SDU or to a
Tribal CSE agency. |f this |VVO instructs you ko send o payment 0oon entity other than an SOU(m.0.. payable Vu the custodial
party, court, or attorney), you must check the box above and return this notice to the sender. Exception: If this IWO was sent
bya Court, Attorney, o Private Individual/Entity and the initial order was entered before January 1, 1994 or the order was
issued by a Tribal CSE agency,you must follow the"Remit payment to"instructions on this form.
Reporting the Pay Date: You must report the pay date when sending the payment. The pay date is the date on which the
amount was withheld from the emp|oyaakob|igor's wages.You must comply with the law of the State(or Tribal law iY
applicable)of the employee/obligor's principal place of employment regarding time periods within which you must implement
the withholding and forward the support payments.
Y0whip|e IVVOo: |f there io more than one|VV(]against this employee/obligor nndyouoreunmbletofu||yhunoraU |VVOoduoto
Federal, State, or Tribal withholding limits, you must honor all IWOs to the greatest extent possible,giving priority tocunent
support before payment of any past-due support. Follow the State or Tribal law/procedure of the employee/obligor's principal
place of employment bo determine the appropriate allocation method.
Lump Sum Payments: You may be required ho notify o State or Tribal CSE agency of upcoming lump sum payments 0nthis
employee/obligor such as bonuses, commissions, or severance pay. Contact the sender to determine if you are required to
report and/or withhold lump sum payments.
Liability: If you have any doubts about the validity of this IWO, contact the sender. If you fail to withhold income from the
employee/obligor's income as the IWO directs,you are liable for both the accumulated amount you should have withheld and
any penalties set by State or Tribal |awYproceduna.
And'discrinn|nat|on: You are subject to a fine determined under State or Tribal law for discharging an employee/obligor from
employment, refusing to employ, or taking disciplinary action against an employee/obligor because of this IWO.
OMB Expiration Date-05/3`/201^.The OMB Expiration Date has no bearing on the termination date mthe IWO:^identifies the version mthe form currently muse.
Form EN-O38O8/12
Service Type M Page 2of3 Worker ID $O|NC
Employer's Name: SOCIAL SECURITY ADMINISTRATION Employer FEIN:
Employee/Obligor's Name: FOREMAN, RICHARD D.JR 9364100570
CS Agency Case Identifier:(See Addendum for case summa rvl Order Identifier:(See Addendum for order/docket information)
Withholding Limits:You may not withhold more than the lesser of: 1)the amounts allowed by the Federal Consumer Credit Protection
Act(CCPA)(15 U.S.C. 1673(b));or 2)the amounts allowed by the State or Tribe of the employee/obligor's principal place of
employment(see REMITTANCE INFORMATION). Disposable income is the net income left after making mandatory deductions such
as: State, Federal, local taxes;Social Security taxes; statutory pension contributions;and Medicare taxes.The Federal limit is 50%of
the disposable income if the obligor is supporting another family and 60%of the disposable income if the obligor is not supporting
another family. However,those limits increase 5%-to 55%and 65%-if the arrears are greater than 12 weeks. If permitted by the State
or Tribe,you may deduct a fee for administrative costs.The combined support amount and fee may not exceed the limit indicated in
this section.
For Tribal orders,you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employers/income
withholders who receive a State IWO,you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which
the employer/income withholder is located or the maximum amount permitted under section 303(d)of the CCPA(15 U.S.C. 1673(b)).
Depending upon applicable State or Tribal law,you may need to also consider the amounts paid for health care premiums in
determining disposable income and applying appropriate withholding limits.
Arrears greater than 12 weeks?If the Order Information does not indicate that the arrears are greater than 12 weeks,then the
Employer should calculate the CCPA limit using the lower percentage.
Additional Information:
NOTIFICATION OF EMPLOYMENT TERMINATION OR INCOME STATUS: If this employee/obligor never worked for you or you are
no longer withholding income for this employee/obligor, an employer must promptly notify the CSE agency and/or the sender by
returning this form to the address listed in the Contact Information below: 8384100092
• This person has never worked for this employer nor received periodic income.
• This person no longer works for this employer nor receives periodic income.
Please provide the following information for the employee/obligor:
Termination date: Last known phone number:
Last known address:
Final Payment Date To SDU/Tribal Payee: Final Payment Amount:
New Employer's Name:
New Employer's Address:
CONTACT INFORMATION:
To Employer/Income Withholder: If you have any questions, contact WAGE ATTACHMENT UNIT(Issuer name)
by phone at(717)240-6225, by fax at(717)240-6248, by email or website at:www.childsupport.state.pa.us.
Send termination/income status notice and other correspondence to: DOMESTIC RELATIONS SECTION, 13 N. HANOVER ST.
P.O. BOX 320, CARLISLE, PA. 17013(Issuer address).
To Employee/Obligor: If the employee/obligor has questions, contact WAGE ATTACHMENT UNIT(Issuer name)
by phone at(71 7)240-6225, by fax at(717)240-6248, by email or website at www.childsupport.state.pa.us.
IMPORTANT:The person completing this form is advised that the information may be shared with the employee/obligor.
OMB No.:0970-0154 Form EN-028 06/12
Service Type M Page 3 of 3 Worker ID $OINC
4
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: FOREMAN, RICHARD D. JR
PACSES Case Number 874110567 PACSES Case Number
Plaintiff.Name Plaintiff Name
LINDA J. FOREMAN
Docket Attachment Amount Docket Attachment Amount
07-3124 CIVIL $ 256.00 $ 0.00
Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB
PACSES Case Number PACSES Case Number
Plaintiff Name Plaintiff Name
Docket Attachment Amouni Do ke Attachment Amount
$ 0.00 $ 0.00
Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB
PACSES Case Number PACSES Case Number
Plaintiff Name Plaintiff Name
Docket Attachment Amount Docket Attachment Amount
$ 0.00 $ 0.00
Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB
Addendum Form EN-028 06112
Service Type M OMB No.:0970-0154 Worker ID $OINC