HomeMy WebLinkAbout03-4409
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 63 - "J"ID9 C;o~L '-r~
LORIE L. TEETER,
Plaintiff
RICHARD S. TEETER,
Defendant
CIVIL ACTION - 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 will proceed without you and a decree in 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, 1 Courthouse Square,
Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL
PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LA WYERA T ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 63 - J/Al07 (!, U'l L '-r~
CIVIL ACTION - IN DIVORCE
LORIE L. TEETER,
Plaintiff
RICHARD S. TEETER,
Defendant
COMPLAINT IN DIVORCE
AND NOW, comes the Plaintiff, Lorie L. Teeter, by and through her attorneys,
Laguna Reyes Maloney, LLP, and represents as follows:
1. Plaintiff is Lorie L. Teeter, an adult individual currently residing at7l1 Alberta
Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17050.
2. Defendant is Richard S. Teeter, an adult individual currently residing at the Grand
Noble Hotel, Gankou Road, Humen Town, Dongguan City, Guangdong, PRC, Post
Code: 523907.
3. Plaintiff is both bona fide resident of the Commonwealth of Pennsylvania and has
been so for at least six months immediately prior to the filing of this Complaint.
4. Plaintiff and Defendant were married on May 15, 1981, in Cumberland County,
Pennsylvania.
5. Plaintiff and Defendant are citizens of the United States of America.
6. The Defendant is not a member of the Armed Forces ofthe United States of America
or its Allies.
7. Plaintiff avers that there are two children of the parties under the age of 18, namely:
Megan B. Teeter, DOB: 7/12/1989, and Alyssa N. Teeter, DOB: 12/20/1991.
COUNT I
IRRETRIEVABLE BREAKDOWN
3301(c) ofthe Divorce Code
8. Paragraphs 1 through 7 are hereby incorporated by reference and made a part
hereof.
9. The marriage is irretrievably broken: Plaintiff and Defendant have lived separate
and apart since September 2002, and continue to live separate and apart as of the
date of filing this Complaint. Plaintiff desires a divorce based upon the belief that
Defendant will, after ninety days from the date of the filing of this Complaint,
consent to this divorce.
10. The Plaintiff has been advised of the availability of counseling and the right to
request that the Court require the parties to participate in counseling. Knowing
this, the Plaintiff does not desire that the Court require the parties to participate in
counseling.
11. Plaintiff requests the Court to enter a decree of divorce.
COUNT II
INDIGNITIES
3301 (a)(6) ofthe Divorce Code
12. Paragraphs 1 through 11 are incorporated herein by reference as if set forth in their
full text.
13. The averments under this complaint are not collusive.
14. Defendant has offered such indignities to Plaintiff, the innocent and injured spouse,
as to render her condition intolerable and life burdensome.
COUNT III
EQUITABLE DISTRIBUTION
3502(a) ofthe Divorce Code
15. Paragraphs 1 through 14 are incorporated herein by reference as if set forth in their
full text.
16. Plaintiff and Defendant are joint owners of various items of realty, personal property,
furniture, and household furnishings acquired during their marriage which are subject
to equitable distribution.
17. Plaintiff and Defendant have incurred debts and obligations during their marriage
which are subject to equitable distribution.
COUNT IV
ALIMONY, ALIMONY PENDENTE LITE AND SUPPORT
18. Paragraphs 1 through 17 are incorporated herein by reference as if set forth in their
full text.
19. Plaintiff is unable to provide for, or afford her counsel fees, expenses and costs during
the pendency of this divorce action, and through its resolution.
20. Plaintiff is without sufficient property and otherwise unable to financially support
herself and her children.
21. Defendant is presently employed and receiving substantial income and benefits and
is able to pay for counsel fees, expenses and costs, as well as alimony, and alimony
pendente lite for Plaintiff.
22. Plaintiff requests your Honorable Court to enter an Order requiring Defendant to pay
child and spousal support, as well as providing for payment of appropriate alimony
and alimony pendente lite for Plaintiff.
COUNT V
CHILD CUSTODY
23. Paragraphs 1 through 22 are incorporated herein by reference as if set forth in their
full text.
24. Defendant hereby seeks custody of the above-mentioned children.
25. The Plaintiff and Defendant are the natural mother and father of the said children.
26. Plaintiff has not participated as a party in other litigation concerning the custody of
the children in this or in another court and Plaintiff has no information of a custody
proceeding concerning the children pending in a court of this Commonwealth.
27. Plaintiff does not know of a person not a party to the proceedings who has physical
custody of the children and claims to have custody or visitation rights with respect to
the children.
28. The best interest and permanent welfare of the children will be served by granting the
relief requested.
29. Each parent whose parental rights to the children have not been tenninated and the
person who has physical custody of the children have been named as parties to this
action.
WHEREFORE, Plaintiff prays that a judgment be entered in favor of the Plaintirf
against the Defendant as follows:
1. As to Counts I and II, that a decree in divorce be entered divorcing Plaintiff
from the bonds of matrimony between the said Plaintiff and Defendant;
2. As to Count III, that your Honorable Court enter a decree equitably dividing
the parties' property and equitably apportioning the debts incurred by the
parties;
3. As to Count IV, that your Honorable Court enter a decree requiring Defendant
to pay child and spousal support, as well as providing for payment or
appropriate alimony and alimony pendente lite for Plaintiff;
4. As to Count V, that your Honorable Court enter a decree granting primary
physical and legal custody of the children to Plaintiff.
5. Such other additional relief as the Court deems necessary and just.
D'" rj 'I/OJ
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esp~ctfully suMritted,
By: '--/'\.~
er R. Lagunl/., \r., Esquire
Supreme Court r:iJ. No.: 75900
Attorney for Plaintiff
LAGUNA REYES MALONEY, LLP
1119 North Front Street
Harrisburg, PA 17102
(717) 233-5292
VERIFICATION
I verify that the statements made in this divorce complaint are true and correct. I
understand that false statements made herein may subject me to penalties ofPa.C.S. ~4904
relating to unsworn falsification to authorities.
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LORIE L. TEETER,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
RICHARD S. TEETER,
Defendant/Respondent
NO. 03-4409 CIVIL TERM
IN DIVORCE
Pacses# 760106025
ORDER OF COURT
AND NOW, this 29th day of December 2003, based upon the Court's determination that Petitioner's
monthly net income/earning capacity is $2,076.46 and Respondent's monthly net income/earning
capacity is $5,779.19, it is hereby Ordered that the Respondent pay to the Pennsylvania State
Collection and Disbursement Unit, $692.67 per month payable bi-weekly as follows; $611.00 for
alimony pendente lite and $21.67 on arrears. First payment due next pay date @ $319.69 bi-weekly.
Arrears set at $2,013.00 as of December 29,2003. The effective date of the order is December 29,
2003
This order is based upon an agreement of the parties through their counceL
Failure to make each payment on time and in full will cause all arrears to become subject to
immediate collection by all of the means as provided by 23 Pa.C.S.\} 3703. Further, if the Court
finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare
the Respondent in civil contempt of Court and its discretion make an appropriate Order, including,
but not limited to, commitment of the Respondent to prison for a pt:riod not to exceed six months.
Said money to be turned over by the P A SCDU to: Lorie L. Teeter. Payments must be made by
check or money order. All checks and money orders must be made payable to P A SCDU and mailed
to:
P A SCDU
P.O. Box 69110
Harrisburg, PA 17106-9110
Payments must include the defendant's P ACSES Member Number or Social Security Number in
order to be processed. Do not send cash by maiL
Unreimbursed medical expenses that exceed $250.00 annually are to be paid 74% by the respondent
and 26% by petitioner. The petitioner is responsible to pay the first $250.00 annually in
unreimbursed medical expenses. Respondenet to provide medical insurance coverage. Within thirty
(30) days after the entry of this order, the Respondnent shall submit written proof that medical
insurance coverage has been obtained or that application for coverage has been made. Proof of
coverage shall consist, at a minimum, of: I) the name of the health care coverage provider(s); 2) any
applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims
should be made; 5) a description of any restrictions on usage, such as prior approval for hospital
admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage
contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms.
This Order shall become final ten days after the mailing of the notice of the entry of the Order to the
parties unless either party files a written demand with the Prothonotary for a hearing de novo before
the Court.
Consented:
Plaintiff/Petitioner
Plaintiff/Petitioner's Attorney
Defendant/Respondent
Defendant/Respondent's Attorney
DRO: R. .I. Shadday
Mailed copies on
12.31.03 to:
Petitioner
Respondent
Laura Reyes Maloney, Esquire
P. Richard Wagner, Esquire
BY T~~r-;r-,
___~~ v~~~
Edgar B. Bayley J.
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
,
State Commonwealth of Pennsvlvania
CoJl""ity/Dist. of CUMBERLAND
Date of Order/Notice 12/29/03
Tribunal/Case Number (See Addendum for case summary)
o Original Order/Notice
o Amended Order/Notice
o Terminate Order/Notice
FCI USA INC
825 OLD TRAIL RD
ETTERS PA 17319-9392
RE: TEETER, RICHARD S.
Employee/Obligor's Name (last, First, Mil
'llfDl ODCB. ~i 168-54-3024
~ Employee/Obligor's Social Security Number
O?:r 1..\'-\0:::1 ti.vtlL 9474101238
Employee/Obligor's Case Identifier
(See Addendum for plaintiH names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
EmployerMlithholder's Federal EIN Number
'E.'lIIO~O
Cf35soco3
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'sfobligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 1,992.73 per month in current support
$ 43.34 per month in past-due support
$ 0.00 per month in medical support
$ 0 . 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 2,036.07 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:
$ 469.86 per weekly pay period.
$ 939.72 per biweekly pay period (every two weeks).
$ 1.018.04 per semimonthly pay period (twice a month).
$ 2.036.07 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'sf obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #10 on pg. 2).
Arrears 12 weeks or greater?
<Xl yes 0 no
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
Dateoforder:JAN 0 2 200~
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Service Type M
OMB No.: 0970-0154
Form EN-028
Worker ID $IATT
1J
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If rl1ecked you are required. to provi(le a copy of this form to your. employee. If yoUr employee works in.a state that is
dj~rent from the state that Issued thiS order, a copy must be provided to your employee even If the box IS not checked.
1. We ap~reciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned
businesses located on a reselVation that choose to withhold in accordance with this notice.
2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed beiow.
3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employee/obligor.
4. * R~~oltil,g lll~ PAydatefDat! of V/;1I11,oldi"g. YotJ IntBl,~polt ti,e pArdate/d~lt of yy;tl.l,oldil,g nlltl. send;"g ti,e paYlllel,t. TI,~
paydatcfdalc: of yvitl.I,vld:"g;3 tin:; JAll 61. nl,;d, alt.ouIIl nAS vvitl,I,~ld {10m ll,G elllployH..'S nage&. You must comply with the law of the
state of the employee'sJobligor's principal place of employment with respect to the time periods within which you must Implement the
withholding order and forward the support payments.
5.' Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee/obligor and you are unable to honor ali support Order/Notices due to Federal or State withholding limits, you must follow
the law ofthe state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #1 0 below)
6. 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 retum a copy of this Order/Notice to the Agency identified below.
WITHHOLDER'S ID: 0606699290
EMPLOYEE'S/OBlIGOR'S NAME:
EMPLOYEE'S CASE IDENTIFIER:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
TEETER, RICHARD S.
9474101238 DATE OF SEPARATION:
7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
8. liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the 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 govems.
9. 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.
10.' Withholding limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.5.c. 91673 (b)l; or 2) the amounts allowed by the State of the employee'sJobllgor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxeSi Sodal Security taxesi and Medicare taxes.
11. Additional Info:
'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
Submitted By:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
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
Worker ID $IATT
Service Type M
QMBNO.:097Q-0154
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: TEETER, RICHARD S.
PACSES Case Number 760106025
Plaintiff Name
LORIE L. TEETER
Docket Attachment Amount
03=44ii"9CIVIL$ 692.67
Child(ren)'s Name(s):
DaB
o If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's1obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
o If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's1obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attach ment Amou nt
$ 0.00
Child(ren)'s Name(s):
DaB
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,,:-,"-',','-"'-:,.::":-,,:-,:-:'::,'-:::'-',"-,-:-..-..":",..",..,,.".,..,.,.::,.,,'...........,'..,'..-:,;::.:.::-:,:::,::,,,::,,,,,,,:,:.,,,:,,:,,,..:;.:.:.,...
[] If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's1obligor's employment.
Service Type M
OMB No.: 097().()154
PACSES Case Number 871105880
Plaintiff Name
LORIE L. TEETER
Docket Attachment Amount
00935 S 2003 $ 1,343.40
Child(ren)'s Name(s):
M.EGJW..J:.g<I!'m'l'.'l'!l!l'l'!l)j..
ALySSl\i....NICOLl;l...'i'EETER
DaB
. .97IE/8.~
. . 12120/9:t
o If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's1obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
o If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's1obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(renl's Name(s):
DaB
;:'.:::::;-:.:::::>':',"",'::';':-:' ':-:':':::':, >,::', :::::::::::,:>::,:,::::'::,:::':,",:,:.':::,::;::;':':,":'::;':;:":::-:,:.:'::::::;::'-,.:::::,:,.,:,-,:.:,::.,:,:,:".,:':::::'::,<'
..._...._.........:...',"'.'::-,'-::-...:..:.:::.-.::.-..:.:..-.......-....',-:.:.:::'-,' "."""."."."".",.
o If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's1obligor's employment.
Addendum
Form EN-028
Worker 10 $IATT
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsvlvania
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 08/26/05
Case Number (See Addendum for case summary)
o Original Order/Notice
o Amended Order/Notice
@ Terminate Order/Notice
~l
/1k!.~ s
RE: TEETER, RJ:CHARD S.
Employee/Obligor's Name (Last, First, Mil
168-54-3024
Employee/Obligor's Social Security Number
9474101238
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (last, First, Mil
ErnployertWithholder's Federal EIN Number
FCI USA INC
825 OLD TRAIL RD
ETTERS PA 17319-9392
JjJ. o2OO34'1O~ (Irllll-
f!l:lt~S 7/;D/b(,lJ~~;
93S- g .;ltV3
871/0 5"f M
See Addendum for dependent names and birth dates associaited with cases on attachment.
ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 0.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes <S) no
$ 0.00 per month in current and past-due medical support
$ 0.00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 0.00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 0.00 per weekly pay period.
$ 0.00 per biweekly pay period (every two weeks).
$ 0.00 per semimonthly pay period (twice a month).
$ 0.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on page 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAMf AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SfCURln' NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL. ~".tj1' ,....,~.II E~
jL"2fJof;:;~~~fTHE COU
AU6 3 0 2005
~ "-
Date of Order:
o..~rm E 028
Worker 10 $IATT
Service Type M
OMBNo,;0970-0154
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o I(/ihecked you are required. to provi~e a copy of this form to your. employee. If yow employeefworkbs in.a state hthat ieds
dl erent from the state that Iss.ued thIs order, a copy must be provided to your employee even I the ox 15 not C eck .
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. * RC:fJOrt;1I5 ti,e raydaldDale v{ 'Iv';1I,I,old;1I5' YOu IlIusllt::fJv1l tIn; fJelyJate/Jate of V\ ;lIllloIJ;lIg vvlleh 561J;lIg tlll~ IidYllU::llt. Tile
fJelydaltddate of vv;tl11 IvlJ;1I5 ;~ lIlt:: Jate VII nIl;"...!, dlllUU1Il VV<1:l vv;llllleld {,viII tIle, ~lIltJk,yt::~'5 vvages. 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
wilhholding 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 stale 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.
THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 0606699290
EMPlOYEE'S/OBlIGOR'S NAME: TEETER. RICHARD S.
EMPLOYEE'S CASE IDENTIFIER: 9474101238 DATE OF SE'PARATlON:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the Slate in which he or she is employed governs.
8. Antiodiscrimination: You are subject to a fine delermined 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 anolher State, in which case the law of the State in which he or she is employed governs.
9.' Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.s.c. 91673 ib)l; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxesi Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more
than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more
than the amounts allowed under the law of the state that issued the order.
10. Additional Info:
'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order wilh respect to these items.
l1.Submitted By:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (ZJ11240-624R or
by internet www.childsupport.state.pa.us
Page 2 of 2
Form EN-028
Worker ID $IATT
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OMB No.: 0'O17(}-0154
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In tile Court of Common Pleas of CUl\;mERLANl> County, Pennsylvania
DOIHEI>"TIC RELATIO:>lS SECTION
~OR::E 1... TEETER Docket Number i)j--i,<;09 CIVIl..
P!ai.I1t111' )
YS. ) P ACSES Case r-<umber 760106)2,
RICHAltO S. l'EETE:R .;"R ) I2\S
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Defend"m ) Other SlatO ID ,,",umber
PETITION FOR MODIFICATION
OF AN EXISTING SUPPORT ORDER
I. The petition of
R::;CH.A.RD S. TE....~E:R ...."'R
respectfully
represents !M! on :JE;C!lMllER 29, 2003 . an Order of Court was entered tor tile
support of
LOR:E LEE TEETER
A true and correct copy of the order is aUJched to tIli, petition.
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Z. Petitioner is emitled to C incre3se ~ decrease 0 termination 0 rein$t:llemenr
o ocher of chis Order becau$e of the following m3Ierial and $uosuntial cnange(s) in
circumstance:
h.ta... +0 loss D~ erY1p\O~Vr1eY\t wi Fer ,TnC-.
WHEREFORE. Petitioner requests rhat L'le Court modify the existing order
~c-havj S .1?~ter. JR, P 12i~rJ Wo..jWlAJ
Petitioner I A[rorney for Petitioner
I verify th3.t the $tatem~ms made in this complaint are true and co=ct. r Wlderstand
that false statements herein are made subject to the; penalties of 18 POl. C,S, * 4904 relaTing !O
unsworn falsification 10 authomic:s.
JoQtos
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Service Type M
Po~e 2 of 2
Form OM.501
Worker tD ~l:O'5
LORIE L. TEETER,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
VS.
CIVIL ACTION - DIVORCE
RICHARD S. TEETER, JR.,
DefendanliPetitioner
NO. 03-4409 CIVIL TERM
IN DIVORCE
PACSES #760106025
ORDER OF COURT
AND NOW, this 28th day of October, 2005, a petition has been filed against you, Lorie L. Teeter,
to decrease an existing Alimony Pendente Lite Order. Yau are ordered to appear in person at the Domestic
Relations Section, 13 North Hanover Street, Carlisle, Pennsylvania, on November 1. 2005 at 1:30 P.M. for
a conference and to remain until dismissed by the Court. If you fail to appear as provided in this Order, an
Order of Court may be entered against you.
You are further ordered to bring to the conference:
(1) a true copy of your most recent Federal Income Tax Return, including W -2' s as filed
(2) your pay stubs for the preceding six (6) months
(3) the Income and Expense Statement attached to this order, completed as required by the Rule
1910.11.
(4) verification of child care expenses
(5) proof of medical coverage which you may have, or may have available to you
IF you fail to appear for the conference or bring the required documents, the Court may issue a
warrant for your arrest.
BY THE COURT,
George E. HolIer, President Judge
Copies mailed
10/28/05 to:
Petitioner
Respondent
Thomas Gould, Esquire
P. Richard Wagner, Esquire
Date of Order: October 28, 2005
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTENDf?HE CONFERENCE AND (.
'.
REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL
HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVE.
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
<* Please note: This conference will be held in conjunction with the
the conference for the child support matter. **
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
LORIE L. TEETER ) Docket Number 03-4409 CIVIL
Plaintiff )
vs. ) PACSES Case Number 760106025
RICHARD S. TEETER JR )
Defendant ) Other State ID Number
Order
AND NOW to wit, this
NOVEMBER 1, 2005
it is hereby Ordered
that:
THE DEFENDANT IS TO MAKE A PAYMENT IN THE AMOUNT OF $2,970.45 THAT IS OWED FOR
THE TIME PERIOD OF 7/29/05 THROUGH 12/23/05 AND IS TO BE PAID ON OR BEFORE
NOVEMBER 16, 2005.
THE MODIFICATION MATTER IS CONTINUED UNTIL AFTER DECEMBER 23, 2005, UNLESS
DEFENDANT IS EMPLOYED BEFORE THAT DATE.
BY THE COURT:
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JUDGE
Service Type M
Form OE-520
Worker ID 21005
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03 - 4409
RICHARD S. TEETER,
Defendant
CIVIL ACTION - IN DIVORCE
PRAECIPE TO WITHDRAW APPEARANCE
To the Prothonotary:
Please withdraw the appearance of Laura C. Reyes Maloney, Esquire and Laguna
Reyes Maloney, LLP, as counsel for Lorie L. Teeter, the Plaintiff in the above-captioned
case.
II - ~ - 05
Date
ura C. Reyes Malon ,Esquire
LAGUNA REYES NEY, LL
1119 North Front Street
Hamsburg, PA 17102
PRAECIPE TO ENTER APPEARANCE
To the Prothonotary:
Please enter the appearance of Thomas D. Gould, Esquire as counsel for Lorie L.
Teeter, the Plaintiff in the above-captioned case.
/1- '7- (J S-
Date
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Thomas D. Gould, Esquire
2 E. Main St.
Shiremanstown, PA 17011
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LORIE L. TEETER,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
RICHARD S. TEETER, JR.,
Defendant/Petitioner
NO. 03-4409 CIVIL TERM
IN DIVORCE
P ACSES #
760106025
ORDER OF COURT
AND NOW, this 3rd day of January, 2006, a petition has been filed against you, Lorie L. Teeter,
to modify an existing Alimony Pendente Lite Order. You are ordered to appear in person at the Domestic
Relations Section, 13 North Hanover Street, Carlisle, Pennsylvania, on Januarv 25. 2006 at 10:30 A.M.
for a conference and to remain until dismissed by the Court. If you fail to appear as provided in this Order,
an Order of Court may be entered against you.
You are further ordered to bring to the conference:
(I) a true copy of your most recent Federal Income Tax Return, including W.2's as tiled
(1) your pay stubs for the preceding six (6) months
(3) the Income and Expense Statement attached to this order, completed as required by the Rule
1910.11.
(4) verification of child care expenses
(5) proof of medical coverage which you may have, or may have available to you
IF you tail to appear for the conference or bring the required documents, the Court may issue a
warrant for your arrest.
BY THE COURT,
Edgar B. Bayley, President Judge
Copies mailed
01/03/06 to:
Petitioner
Respondent
Thomas D. Gould, Esq.
P. Richard Wagner, Esq.
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R. J. Y.adday, Conference Officer
Date of Order: Januarv 3,2006
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND
REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL
HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVE.
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
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LORIE L. TEETER,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
RICHARD S. TEETER, JR.,
DefendanllPetitioner
NO. 03-4409 CIVIL TERM
IN DIVORCE
PACSES # 760106025
ORDER OF COURT
AND NOW, this 25th day of January, 2006, based upon the Court's determination that
Plaintiffs monthly net income/earning capacity is $3020.59 and Defendant's monthly net
income/earning capacity is $5402.83 it is hereby Ordered that the Defendant pay to the Pennsylvania
State Collection and Disbursement Unit, $258.00 per month payable monthly as follows: $233.00 for
alimony pendente lite and $25.00 on arrears. First payment due next pay date. Arrears set at
$3442.80 as of January 25,2006.
The effective date of the order is January 1,2006.
Failure to make each payment on time and in full will cause all arrears to become subject to
immediate collection by all of the means as provided by 23 Pa.C.S.~ 3703. Further, if the Court
finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare
the Respondent in civil contempt of Court and its discretion make an appropriate Order, including,
but not limited to, commitment of the Respondent to prison for a period not to exceed six months.
Said money to be turned over by the P A SCDU to: Lorie L. Teeter. Payments must be made
by check or money order. All checks and money orders must be made payable to P A SCDU and
mailed to:
P A SCDU
P.O. Box 69110
Harrisburg, PAl 71 06-911 0
Payments must include the Respondent's P ACSES Member Number or Social Security
Number in order to be processed. Do not send cash by mail.
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Unreimbursed medical expenses that exceed $250.00 annually are to be paid as follows 0% by
Defendant and 100% by Plaintiff The Plaintiff is responsible to pay the first $250.00 annually in
unreimbursed medical expenses. The PlaintifIto provide medical insurance coverage. Within thirty
(30) days after the entry of this Order, the Respondent shall submit to Petitioner written proof that
medical insurance coverage has been obtained or that application for coverage has been made. Proof
of coverage shall consist, at minimum, of: I) the name of the health care coverage provider(s); 2) any
applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims
should be made; 5) a description of any restrictions on usage, such as prior approval for hospital
admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage
contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms.
The Defendant is given credit in the amount of$154.84 for the last week of2005 when he was
not employed.
This Order shall become final ten days after the mailing of the notice of the entry of the Order
to the parties unless either party files a written demand with the Prothonotary for a hearing de novo
before the Court.
Consented:
Petitioner
Petitioner's Attorney
Respondent
Respondent's Attorney
ORO: R. .I. Shad day
Mailed copies on:
January 25, 2006
BY THE COURT,
Petitioner
Respondent
Thomas D. Gould. Esq.
P. Richard Wagner, Esq.
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Edgar B. Bayley, \.
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of pennsylvania
Co./City/Dist of CUMBERLAND
Date of Order/Notice 01/25/06
Case Number (See Addendum for case summary)
760106025 00riginalOrder/Notice
03-4409 CIVIrD Amended Order/Notice
o Terminate Order/Notice
LAIRD TECHNOLOGIES
#2 BUILDING IDUSTRY PARK
TANGZLAYONG SONGGANG TOWN
BOAN SHENZEHN
518105
P.R. CHINA
871105880
935 S 2003
RE: TEETER, RICHARD S. JR
Employee/Obligor's Name (Last, First, Mil
168-54-3024
Employee/Obligor's Social Security Number
9474101238
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, Mil
EmployerlWithho!der's Federal E1N Number
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 1 ,840.00 per month in current support
$ 75.00 per month in past-due support Arrears 12 weeks or greater? (S)yes 0 no
$ 0.00 per month in current and past-due medical support
$ 0.00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 1,915.00 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:
$ 441.92 per weekly pay period.
$ 883.85 per biweekly pay period (every two weeks).
$ 957.50 per semimonthly pay period (twice a month).
$ 1.915.00 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 remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCOU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BYT
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Date of Order: JAN 2 5 ZOGS
DRO: R.J. Shadday
Service Type M
Edgar B. Bayley,
Jtrlge
Form E N-028
Worker ID $IATT
OMB No.: 0970-0134
.,
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If checked you are required to provide a copy of this form to your ~mployee. Ifyol,Jf employe~ works in.3 state that is
ditterent from the state that issued this order, a copy must be provided to your employee even If the box 15 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. *--RC:f-'Vlt;115 tIle r ayJak/Ddle vf W;tl,l,vIJ;,15. Yvu ",u:.l,epo,lll,c: .....ayJdh::lddlc: vf vv;thhotd-ing- vvllell kllJ;llg the-payment;--the
pavd-atefd-ate--ofwith-hotding--is-tllC: Jdte-vll vvl,;d, alllvulll vva:. vv;U,lu::::IJ f,o", tile e".plvyee':. vvages;-- 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.
THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 1717100227
EMPLOYEE'S/OBLlGOR'S NAME: TEETER, RICHARD S. JR
EMPLOYEE'S CASE IDENTIFIER: 9474101238 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9.' Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.s.c. 91673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandato'Y
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more
than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more
than the amounts allowed under the law of the state that issued the order.
10. Additional Info:
'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
11 Submitted By:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717) 240-6248 or
by internet www.childsupport.state.pa.us
Page 2 of 2
Form EN-028
Worker ID $IATT
Service Type M
OMB No.: 097(}-Ol_~4
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ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: TEETER, RICHARD S. JR
PACSES Case Number 760106025
Plaintiff Name
LORIE L. TEETER
Docket Attachment Amount
03-4409 CIVIL$ 258.00
Child/ren)'s Namels):
DOB
PACSES Case Number 871105880
Plaintiff Name
LORIE L. TEETER
Docket Attachment Amount
009355 2003 $ 1,657.00
Child(ren)'s Name/s):
MEGAN BRIANNA TEETER
ALYSSANICOr..ETEETllR
DOB
07/12/89
12/20/91
Olf checked, you are required to enroll the childlren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
o If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren/'s Namels):
DOB
Docket Attachment Amount
$ 0.00
Childlren)'s Name(s):
DOB
o If checked, you are required to enroll the childlren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
o If checked, you are required to enroll the childlren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Childlren)'s Name(s):
DOB
Docket Attachment Amount
$ 0.00
Child/ren)'s Namels):
DOB
o If checked, you are required to enroll the child/ren)
identified above in any health insurance coverage avaiJable
through the employee's/obligor's employment.
o If checked, you are required to enroll the childlren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Service Type M
Addendum
Form E N-028
Worker ID $IATT
OMB No.: 09?O-0154
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LORIE L. TEETER,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 03-4409 CIVIL TERM
RICHARD S. TEETER,
DEFENDANT
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the
Divorce Code was filed on September 8, 2003.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of the
filing and service of the Complaint.
3. I consent to the entry of a Final Decree of Divorce after
service of notice of intention to request entry of the decree. I
acknowledge that pursuant to Rule 1920.42 (e) I have waived the
requirement that I receive notice of intention to request entry of
the decree.
I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein are subject
to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
DATED:
!)/f () I ()ip
LORIE L. TEE TER
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LORIE L. TEETER,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 03-4409 CIVIL TERM
RICHARD S. TEETER,
DEFENDANT
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c} OF THE DIVORCE CODE
1. I consent to the entry of a final decree without notice.
2. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim
them before a divorce is granted.
3. I understand that I will not be divorced until a divorce
decree is entered by the court and that a copy of the decree will
be sent to me immediately after it is filed with the prothonotary.
I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein are subject
to the penalties of 18 Fa. C.S. Section 4904 relating to unsworn
falsification to authorities.
DATED;
J liD JDIo
LO IE L. TEETER
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LORI L. TEETER,
: IN THE COURT OF COMMON PLEAS
. CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff:
v.
: NO. 03-4409
: CIVIL ACTION. LA W
RlCHARD S. TEETER,
IN DIVORCE
Defendant.
AFFlDA vJT OF CONSENT
I. A Complaint in Divorce under Section 3301(c) of the DIvorce Code was filed
on September 8. 2003.
2. The marriage of Plaintiff and Defendant is irTetrievably broken and ninety (90)
days have elapsed from the date 0 f filing and service of the Complaint.
3. I consClIt to the entry of a final decree of divorce after ~rvice of notice of
intention to request entry of the decree.
4. I understand that I may lose rights com:erning alimony, division of property.
lawyer's fees or expenses if r do not dll1m them before a divorce is granted.
I verify that the statemenlS made in this affidavit are true and correct. I understand
that false statements herein are made su~iect to the penalties of 18 Pa.C.s. Section 4904,
relating to unsworn falsification to authorities.
DATE: ()3l'i)arch 010
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Richard S. Teelef
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LORJE L. TEETER,
; IN THE COURT Of COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff.
: CIVIL ACTION - LAW
RICHARD S. TEETER.
: IN D1VORCE
Defendant.
W A.IVER OF NOnCE OF INTENTiON TO
REOCES-r ENTRY OF A DIVOR(;E DECREE (}NDER
SECTION 3301(.:) OF TIlE DIVORCE CODf:
I. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of
property, lawyer's fees or expenses if I do not claim them before a divorce is
granted.
3. I understand that I will not be divorced until a divorce decree is entered
by the Court and that a copy of the decree will be sent to me immediately after it is
filed with the prothonotary'.
I verify that the statements made in this affidavit are true and correct. [
understand that false statements herein are made subject to the penalties of 18
Pa.C.S. g4904 relating to unsworn falsification to authorities.
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Richard S. Teefer
DATE: 03 Kcuct1 010
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State Commonwealth of Pennsvlvania
Co./City/Oist. of CUMBERLAND
Date of Order/Notice 04/05/06
Case Number (See Addendum for case summary)
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
760106025
03-4409 CIVIL
871105880
935 S 2003
o Original Order/Notice
o Amended Order/Notice
@ Terminate Order/Notice
LAIRD TECHNOLOGIES
#2 BUILDING IDUSTRY PARK
TANGZLAYONG SONGGANG TOWN
BOAN SHENZEHN
RE: TEETER, RICHARD S. JR
Employee/Obligor's Name (Last, First, MI)
168-54-3024
Employee/Obligor's Social Security Number
9474101238
Employee/Obligor's Case Identjfier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, first, Mil
EmployerMlithholder's Federal EIN Number
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County. Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 0.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Qyes CSl no
$ 0.00 per month in current and past-due medical support
$ 0 . DOper month for genetic test costs
$ per month in other (specify)
for a total of $ 0.00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 0.00 per weekly pay period.
$ 0.00 per biweekly pay period (every two weeks).
$ 0.00 per semimonthly pay period (twice a month).
$ 0.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee. cannot exceed 55% of the employee's/ obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on page 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCOU
DRO: R.J. Shadday
Service Type M
Send check to: Pennsylvania SCOU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL. ~
BY THE \~.r-;::JJ
Date of Order: APR 0 6 2006 "_,_ v("'- ~( ~~~\b~
Edgar B. Bayley,Mge
Form EN-028
Worker 10 $IATT
OMB No.: 0970-0154
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If checked you are required to provide a copy of this form to your employee. If your employee works in a state that is
different from the state that issued this order, a copy must be provided to your employee even if the box is not checked.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employee/obligor.
3. *-Reporth Ig tile r'aYlJak/Oate-ot-W;tl,l,vIJ;"g. YOl1-rllu;,llepoll tile payJ<lle/dc'lk vf vv;ll,l,vldir,g ~~I'Ln-send1ng-the-paymem-:--::rhe-
payd-atefdate-ofwith-ho+C:Hng-is-the-d-ate-onVvI';LI, alllOUIIl ~~a::. vvitl,lreld (IVIII tlrL C'llIfJlvyec::':.'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.
THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 1717100227
EMPlOYEE'S/OBLlGOR'S NAME: TEETER, RICHARD S. JR
EMPLOYEE'S CASE IDENTIFIER: 9474101238 DATE OF SEPARATION:
lAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs. you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State In which he or she is employed governs.
8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment,
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9.' Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.s.c. 91673 (b)l; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. FortribaJ orders, you may not withhold more
than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more
than the amounts allowed under the law of the state that issued the order.
10. Additional Info:
'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
11.Submitted By:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (7171 240-6248 or
by internet www.childsuppOrl.state.pa.us
Page 2 of 2
Form EN-028
Worker ID $IATT
Service Type M
OM6 No.: 0970-0154
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: TEETER, RICHARD S. JR
PACSES Case Number 760106025
Plaintiff Name
LORIE L. TEETER
Docket Attachment Amount
03-4409 CIVIL$ 0.00
Child(ren)'s Namels):
DOB
PACSES Case Number 871105880
Plaintiff Name
LORIE L. TEETER
Docket Attachment Amount
00935 S 2003 $ 0.00
Child(ren)'s Namels):
MEGAN BRIANNA TEETER
ALYS SAN!COLE ..TEETER
DOB
07/12/89
12/20/91
D If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
D If checked. you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
D If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
D If checked. you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
D If checked. you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
D If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Addendum
Form E N-028
Worker ID $IATT
Service Type M
OMB No., 0970-01.54
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LORIE L. TEETER,
Plaintiff
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 03 - 4109 CIVIL
RICHARD S. TEETER,
Defendant
IN DIVORCE
ORDER OF COURT
AND NOW, this
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the proceedings having been
2006, the economic claims raised in
resolved in accordance with a marriage settlement agreement
dated August 31, 2006, and supplemental comments made on the
record the same day accompaning the agreement, the appointment
of the Master is vacated and counsel can file a praecipe
transmitting the record to the Court requesting a final decree
in divorce.
B(Q?lJ'I~
Edgar B. Bayley, P.J.
cc:
~mas D. Gould
Attorney for Plaintiff
~ Richard Wagner ~
Attorney for Defendant
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MARRIAGE SETTLEMENT AGREEMENT
,.,.
THIS AGREEMENT made this 3f
and between RICHARD S. TEETER,
"Husband") and LORIE L. TEETER,
"Wife") .
day of ~lL('r ,2006, by
(hereinafter referred to as
(hereinafter referred to as
WITNESSETH:
WHEREAS, the Husband and Wife were lawfully married on May 15,
1981; and
WHEREAS, differences have arisen between Husband and Wife in
consequence of which they intend to live apart from each other; and
WHEREAS, Husband and Wife desire to settle and determine their
rights and obligations; and
WHEREAS, the parties hereto, with the assistance of the
Di vorce .Master, have mutually entered into an agreement for the
division of their jointly-owned assets, the provisions for their
liabili ties and provisions for the resolution of their mutual
differences, after both have had free and ample opportunity to
consult with their respective attorneys, and the parties now wish
to have that agreement reduced to writing; and
NOW, THEREFORE, the parties intending to be legally bound
hereby do covenant and agree as follows;
1 . SEPARATION
It shall be lawful for each party at all times hereafter
to live separate and apart from the other party at such place or
places as he or she may from time to time choose or deem fit. The
foregoing provisions shall not be taken as an admission by either
party as to the lawfulness or unlawfulness of the causes leading to
their living apart.
2 . INTERFERENCE
Each party shall be free from interference, authority,
and contact by the other as fully as if he or she were single and
unmarried except as maybe necessary to carry out the provisions of
the agreement. Neither party shall molest the other nor attempt to
endeavor to molest the other, nor compel the other to cohabit with
the other, or in any way harass or malign the other, nor in any way
interfere with the peaceful existence, separate and apart from the
other.
3 . DIVISION OF PERSONAL PROPERTY
The parties have equitably divided between them to their
mutual satisfaction the personal affects, household furniture and
furnishings and all other articles of personal property which
heretofore have been used by them in common.
4. AUTOMOBILES
Each party is to keep their respective vehicles. Husband
shall have all right and title to any vehicle he owns. He shall
maintain insurance on his vehicle and be responsible for all
maintenance, liens and other payments related thereto. Husband
shall indemnify and hold Wife harmless for all matters related to
his vehicle. Wife shall have all right and title to the 1998 Ford
Explorer. She shall maintain insurance on her vehicle and be
responsible for all maintenance. Wife shall indemnify and hold
Husband harmless for all matters related to her vehicle. Husband
shall sign the vehicle Title transferring all his rights and
interest in the vehicle to Wife.
5 . DIVISION OF REAL PROPERTY
The parties own the real estate at 711 Alberta Avenue,
Mechanicsburg, Pennsylvania. Husband shall transfer by deed all is
right and interest the former marital home to Wife. Wife shall be
responsible for any costs or expenses related to preparing and
filing the necessary deeds or other documents. Wife shall assume
all responsibility for the mortgage and home equity loan placed
against .the former marital home. Wife shall indemnify and hold
Husband harmless for all insurance, taxes, fees or other expenses
and costs related to the former marital home. Wife shall within a
reasonable time, undertake efforts to have Husband's name and
obligation removed from the mortgage, note and home equity loan.
6. FINANCIAL ACCOUNTS, STOCKS, BONDS AND INVESTMENTS
The parties have fully disclosed their marital financial
assets. The parties agree that Husband shall have possession and
ownership of all accounts in his name and Wife shall have
possession and ownership of all accounts in her name regardless of
where the funds in those accounts may have previously been held.
Each party shall be liable for any tax consequences related to
the sale or exchange of their accounts, real estate, stocks or
bonds or other assets under their control. Each party shall
maintai~ their separate accounts and investments as set forth in
this agreement and hereby releases any interest they may have in
the other's accounts or investments and shall sign all documents
required to distribute the assets as set forth in this agreement.
2
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7. MARITAL DEBTS
The parties incurred debt during their marriage. Husband
shall be responsible for all debts solely in his name and the joint
debts with CITI Bank, Member's l't, BELCO and Fleet. Wife shall be
responsible for all debts solely in her name and the joint debts
with Good's Furniture, Sears and Chase Manhattan Bank. In
addition, as set forth in paragraph 5, Wife shall be responsible
for all the debts related to the former marital home.
8 . PENSION AND RETIREMENT ACCOUNTS
The parties have fully disclosed their various pension or
retirement accounts. Husband and Wife shall maintain their
separate pension and/or retirement accounts. Husband relinquishes
any and all rights he may have in Wife's pension or retirement
accounts' and Wife relinquishes any and all rights she may have in
Husband's pension or retirement accounts.
9. SPOUSAL SUPPORT/ALIMONY/ALIMONY PENDENTE LITE
Each party hereby waives, releases, discharges and gives
up any rights either may have against the other to receive
support, a1illjOny pendente li 1;e or alimony. W,,+" Q.'jI'~"J "fI,.J.JJ fJtfna.,u ,+
AfL (}.cc......... k1'<-J (1..J ,f -.JI,;.. e(...z:;. tAl'" ':"1"'~"4,.>\ 'I" I..J./,frw~e J,IJ,,,,,']...J D~"'t'-
1 0 . FILING OF IRS RETURN .A!:J.L
Husband and Wife agree to separate tax returns.
11 . DIVORCE
The parties agree to cooperate with each other in
obtaining a final divorce of the marriage that Wife has filed at,
Cumberland County Court of Common Pleas, docketed at 2003-4409.
The parties have already signed and filed the required Affidavit of
Consents and Waiver of Notice forms. Upon execution of this
agreement it shall be presented to the Master who shall prepare an
order vacating his appointment. Upon vacation of the Master's
appointment, Wife's attorney shall file the Praecipe to Transmit
Record and other documents required to obtain a Decree in Divorce.
12. ATTORNEY FEES
Each party shall be responsible for their respective
attorney fees and costs.
3
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13 . INCORPORATION
This agreement is to be incorporated into any subsequent
Decree in Divorce.
14. CONTINUED COOPERATION
The parties agree that they will within ten days after
the execution of this agreement, or request of the other party,
execute any and all written instruments assignments, releases,
deeds or notes or other writings as may be necessary or desirable
for the proper effectuation of this agreement.
15. BREACH
If either party breaches any provision of this agreement,
the other party shall have the right, at his or her election, to
sue for damages for such breach, and the party breaching this
contract shall be responsible for the payment of legal fees and
costs incurred by the other in enforcing their rights under this
agreement or for seeking such other remedies or relief as may be
available to him or her.
16 . VOLUNTARY AGREEMENT
The provisions of this agreement are fully understood by
both parties and each party acknowledges that there has been a full
and fair disclosure os assets and that the agreement is fair and
equitable, that it is being entered into voluntarily, and that it
is not the result of any duress or undue influence. Each party has
had the opportunity to review this agreement and their legal rights
with an attorney.
17. WAIVER OF CLAIMS AGAINST ESTATES
Except as herein otherwise provided, each party may
dispose of his or her property in any way, and each party hereby
waives and relinquishes any and all rights he or she may now have
or hereafter acquire under the present or future laws of any
jurisdiction to share in the property or the estate of the other as
a result of the marital relationship, including without limitation,
dower, curtesy, statutory allowance, widows allowance, right to
take in intestacy, right to take against the will of the other and
the right to act as administrator/executor of the other's estate.
4
.
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18 . BINDING AFFECT
This agreement shall be binding upon the parties' heirs,
successors and assigns.
19. MODIFICATION AND WAIVER
Any modification or waiver of any of the provisions of
this agreement shall be effective only if made in writing and
executed with the same formalities as this agreement. The failure
of either party to insist upon strict performance of any of the
provisions of this agreement shall not be construed as a waiver of
any subsequent default of the same or similar nature.
20 . PRIOR AGREEMENTS
It is understood and agreed that any prior agreements
which may have been made or executed or verbally discussed prior to
the date and time of this agreement are null and void.
21 . ENTIRE AGREEMENT
This agreement contains the entire understanding of the
parties and there are no representations, warranties, covenants or
undertakings other than those expressly set forth herein.
22. DESCRIPTIVE HEADINGS
The descriptive headings used herein are for convenience
only. They shall not have any binding affect whatsoever in
determining the rights or obligations of the parties.
23. APPLICABLE LAW
This agreement shall be construed under the laws of the
Commonwealth of Pennsylvania.
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Witness
IN WITNESS WHEREOF, the parties
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LORIE L. TEETER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 03 - 4~09 CIVIL
RICHARD S. TEETER,
Defendant
IN DIVORCE
THE MASTER:
Today is Thursday, August 31,
2006. This is the date set for a hearing in the
above-captioned divorce proceedings. Present in the hearing
room are the Plaintiff, Lorie L. Teeter, and her counsel
Thomas D. Gould, and the Defendant, Richard S. Teeter, and
his counsel P. Richard Wagner.
A complaint in divorce was filed on September
8, 2003, raising grounds for divorce of irretrievable
breakdown of the marriage and a claim for indignities. The
parties have each signed affidavits of consent and waivers
of notice of intention to request entry of divorce decree.
Wife's affidavit and waiver were dated February 10, 2006,
and filed February 14, 2006; husband's affidavit and waiver
were dated March 3, 2006, and filed March 21, 2006. The
divorce can, therefore, be concluded under Section 3301(c)
of the Domestic Relations Code.
A claim for equitable distribution has been
filed on behalf of wife. Also wife filed a claim for
alimony which, according to Mr. Gould, is going to be
withdrawn. Apparently that will be done pursuant to the
agreement which the parties have entered into today.
1
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Neither party claimed counsel fees and expenses.
The parties were married on May 15, 1981, and
separated September 2003. They are the parents of two
children, both of whom are in the custody of wife. Both
children are minors.
After considerable discussion today and
previously, the parties have reached an agreement with
respect to the outstanding economic issues. The parties
have signed a marriage settlement agreement dated today,
which is made part of the record and which will be
considered the substantive and comprehensive agreement of
the parties with respect to the outstanding economic issues.
As previously noted, wife has waived her claim for alimony,
alimony pendente lite, and support. Therefore, the
agreement essentially deals with the distribution of the
marital assets and the allocation of the marital debt.
The Master understands that counsel wish to
go on the record with some supplemental remarks after which
the record will be closed. The Master will then prepare an
order vacating his appointment and counsel can then file a
praecipe transmitting the record to the Court requesting a
final decree in divorce. Mr. Gould.
MR. GOULD: I have nothing further at this
time.
MR. WAGNER: Mr. Teeter, I want to make sure
2
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/
we have certain items on the record. Prior to the execution
of the marriage settlement agreement dated the 31st of
August 2006, you had the opportunity to review this
agreement with me, did you not?
MR. TEETER: Yes.
MR. WAGNER: And the signature dated the 31st
of August 2006 that purports to be Richard S. Teeter in this
agreement is, in fact, your agreement?
MR. TEETER: Yes.
MR. WAGNER: You understand that by signing
this agreement you have effectively compromised and resolved
any economic claims under the Divorce Code?
MR. TEETER: Yes.
MR. WAGNER: And do you understand that by
signing this agreement the issues that we discussed that
could have been part of this process are hereby resolved by
this agreement?
MR. TEETER: Right.
MR. WAGNER: In other words, we talked about
issues such as tax consequences of your 401(k)? We talked
about issues such as reasonable rental value? We talked
about issues of getting credit for certain payments that you
have made since the date of separation? You recall that we
talked about those issues?
MR. TEETER: Yes.
3
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MR. WAGNER: Do you understand that by
signing this agreement those issues are resolved within the
context of this agreement?
MR. TEETER: Yes.
MR. WAGNER: And knowing all of that, is it
your desire that this marriage settlement agreement be
entered into the record with the knowledge that this will
compromise all of the issues and that within probably less
than thirty (30) days you will be divorced?
MR. TEETER: Yes.
MR. WAGNER: Is it your desire to have it
accomplished in that fashion?
MR. TEETER: Yes.
THE MASTER: The statement of Mr. Wagner will
be transcribed and added as an addendum to the record with
the marriage settlement agreement when we send it over to
the Court for vacation of my appointment and for the
permanent file which will be in the Prothonotary's office.
The Master also will retain a file with the agreement and
the remarks made by Mr. Wagner and his client.
cc: Thomas D. Gould, Attorney for Plaintiff
P. Richard Wagner, Attorney for Defendant
4
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LORIE L. TEETER,
Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 03 - 4409
RICHARD S. TEETER,
Defendant
CIVIL ACTION - IN DIVORCE
CERTIFICATE OF SERVICE
I hereby certify that I served a copy of the Complaint in Divorce filed in the above-
captioned matter upon Richard S. Teeter, by first-class U.S. mail and registered U.S. mail on
September 12,2003, addressed as follows:
Richard S. Teeter
Grand Noble Hotel
Gankou Road, Humen Town
Dongguan City, Guangdong, PRC
Post Code: 523907
and did thereafter receive the attached U.
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U.S. POSTAL SERVICE CERTIFICATE FAILING
MAY BE USED FOR OOMESTIC AND INTERNATIONAL MAIL, ODES NOT
PROVIDE FOR INSURANCE-POSTMASTER
ReceiveL A ,
1119N.FR~TREET
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LORIE L.' TEETER,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 03-4409 CIVIL TERM
RICHARD S. TEETER,
DEFENDANT
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information,
to the Court for the entry of a divorce decree:
1. Ground for divorce: irretrievable breakdown under Section
3301(c) of the Divorce Code.
2. Date and manner of service of the complaint: On September
12, 2003 by U.S. Mail, Restricted delivery.
3. Date of execution of the affidavit of consent required by
Section 3301(c) of the Divorce Code: By Plaintiff, February 10,
2006; By Defendant, March 3, 2006.
4.
Related claims pending:
None
5. Date Plaintiff's Waiver of Notice in 5 3301(c) divorce
was filed with the Prothonotary on February 14, 2006.
Date Defendant's Waiver of Notice in 5 3301(c) divorce
was filed with the Prothonotary on March 21, 2006.
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Thomas D. Gould, Esquire
Attorney For Plaintiff
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESfIC RELATIONS SECTION
LORIE L. TEETER ) Docket Number 03-4409 CIVIL
Plaintiff )
VS. ) PACSES Case Number 760106025
RICHARD s. TEETER JR )
Defendant ) Other State ID Number
PETmON FOR MODIFICATION
OF AN EXISTING SUPPORT ORDER
1. The petition of
RICHARD S. TEETER JR
respectfully
represents that on JANUARY 25, 2006
, an Order of Court was entered for
LORIE LEE TEETER
A true and correct copy of the order is attached to this petition.
Service Type M
Form OM-SOl
Worker ID 21205
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TEETER
V. TEETER
PACSES Case Number: 760106025
2. Petitioner is entitled to 0 increase 0 'decrease ~ tennination 0 reinstatement
o other of this Order because of the following material and substantial change(s) 'in
circumstance:
FOR REQUESTING A MODIFICATION OF THE
WHEREFORE, Petitioner requests that the Court modify the existing order .~
~\~\-~\t:.ekr ~~ ~\ ~~,
Petitioner Attorney for Petitioner
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. ~ 4904 relating to
unsworn falsification to authorities.
<4\~\G\o
Date
Service Type M
Page 2 of 2
Form OM-50 I
Worker ID 21205
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IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
STATE OF
PENNA.
LORIE L. TEETER,
No. 2003-4409
CIVIL
PLAINTIFF
VERSUS
RICHARD S. TEETER,
DEFENDANT
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DECREE IN
DIVORCE
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~, IT IS ORDERED AND
AND NOW,
DECREED THAT
LORIE L. TEETER
, PLAI NTI FF,
RICHARD S.
TEETER
AND
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED; NONE
THE MARRIAGE SETTLEMENT AGREEMENT DATED AUGUST -31,
2006 IS
HEREBY INCORPORATED INTO THIS DECREE IN
J.
PROTHONOTARY
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LORIE L. TEETER,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
VS.
CIVIL ACTION - DIVORCE
RICHARD S. TEETER, JR.,
Defendant/Petitioner
NO. 03-4409 CIVIL TERM
IN DIVORCE
P ACSES # 760106025
ORDER OF COURT
AND NOW to wit, this 11 th day of September, 2006, it is hereby Ordered that the
Alimony Pendente Lite order is terminated, effective August 31, 2006, with no balance due the
Petitioner, pursuant to the parties' marital settlement agreement of August 31, 2006.
BY THE COURT:
ML~'~ ~ ~J
DRO: R.J. Shadday
xc: Petitioner
Respondent
Thomas D. Gould, Esq.
P. Richard Wagner, Esq.
Service Type: M
Form OE-OO I
Worker: 21 OOS
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