HomeMy WebLinkAbout07-5375COYNE & COYNE, P.C.
Lisa Marie Coyne, Esquire
Pa. Supreme Ct. No. 53788
3901 Market Street
Camp Hill, PA 17011-4227
(717) 737-0464
ATTORNEYFOR PLAINTIFF
KATHLEEN L. HOLLISTER-PEPPERMAN: IN THE COURT OF COMMON PLEA5 OF
Plaintiff : CUMBE)~tLAND COUNTY, PENNSYLVANIA
.,5375
vs. : NO. ~ry CIVIL TERM
DONALD L. PEPPERMAN
Defendant
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 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAW`YER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT I5 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, TO GET LEGAL HELP SHOULD
CONTACT:
Cumberland County Lawyer Referral Service
32 South Bedford Street, Carlisle, Pennsylvania
1-(800)-990-9108
COYNE & COYNE, P.C.
Lisa Marie Coyne, Esquire
Pa. Supreme Ct. No. 53788
3901 Market Street
Camp Hill, PA 17011-4227
(717) 737-0464
ATTORNEY FOR PLAINTIFF
KATHLEEN L. HOLLISTER-PEPPERMAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : NO. CIVIL TERM
DONALD L. PEPPERMAN,
Defendant : ACTION IN DIVORCE
COMPLAINT IN DIVORCE
NOW COMES the Plaintiff, Kathleen L. Hollister, by her attorney, Lisa Marie Coyne, Esquire
and files this Complaint In Divorce and avers the following in support thereof:
1. The Plaintiff, Kathleen L. Hollister-Pepperman, is an adult individual residing at 16
Ardmore Circle, New Cumberland, Cumberland County, Pennsylvania 17070.
2. The Defendant, Donald L. Pepperman, is an adult individual residing at 6263 Stanford
Court, Mechanicsburg, Cumberland County, Pennsylvania.
3. The Plaintiff and Defendant are sui juris and have been bona fide residents in the
Commonwealth for at least six months previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on October 17, 1988, in Camp Hill,
Pennsylvania and have separated.
5. The Defendant is not a member of the Armed Services of the United States or any of its
Allies.
6. A prior action for divorce was filed at Cumberland County, Civil Term 03-3904;
however, on October 27, 2006 it was dismissed and purged for lack of activity pursuant to local Rule of
Court and furthermore, Plaintiff did not have the resources to pursue her rights under the divorce.
7. Plaintiff has been advised that counseling is available and that Plaintiff may have the
right to request that the Court require the parties to participate in counseling. Further, Plaintiff waives
her right to request that the parties participate in marriage counseling.
COUNT I-REQUEST FOR A NO FAULT DIVORCE
8. Paragraphs 1 through 7 of this Complaint are incorporated by reference.
9. The marriage is irretrievably broken.
10. After ninety (90) days have elapsed from the date of the filing of this Complaint,
Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also
file such an affidavit.
11. At the appropriate time, Plaintiff may submit an affidavit alleging that the parties have
lived separate and apart for at least two (2) years.
WHEREFORE, if both parties file affidavits consents to a divorce after ninety (90) days have
elapsed from the filing of this Complaint, or alternatively if the appropriate time has elapsed since date of
separation, Plaintiff respectfully request the Court enter a Decree in Divorce, pursuant to Section 3301(c}
or Section 3301(d), as may be appropriate.
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COUNT II - EQUITABLE DISTRIBUTION
12. Paragraphs 1 through 11 of this Complaint are incorporated by reference.
13. Plaintiff and Defendant have acquired property, both real and personal, and debt during
their mamage.
14. Plaintiff and Defendant have been unable to agree as to the equitable division of said
property and debt.
WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital property
and debt pursuant to the Divorce Code.
COUNT III -ALIMONY, ALIMONY PENDENTE LITE,
SPOUSAL SUPPORT. COUNSEL FEES. COSTS AND EXPENSES
15. Paragraphs 1 through 14 of this Complaint are incorporated herein by reference.
16. Plaintiff has retained counsel and will incur considerable expense in preparation for her
case in the employment of counsel, accountant, appraiser, actuary, and the payment of costs and is unable
to pay the necessary and reasonable fees and costs.
17. Plaintiff is without adequate funds to support herself and to meet the costs and expenses
of this litigation and is unable to sustain herself during the pendency of this action.
18. Plaintiff lacks sufficient property to provide for her reasonable means and is unable to
support herself through appropriate employment.
19. Plaintiff requires reasonable support to maintain herself adequately in accordance with
the standard of living established during the marriage.
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WHEREFORE, Plaintiff respectfully requests this Honorable Court to order Defendant to pay
Plaintiff alimony, alimony pendente lite, spousal support, counsel fees, costs and expenses associated
with this divorce action and all other relief deemed appropriate by this Court.
Respectfully submitted:
Dated:_ 1~5~ Apr' 7
COYNE & COYNE, P.C.
r
By: -
LIS MARIE COYNE, Es uire
1 Market Street
Camp Hill, PA 17011-4227
(717) 737-0464
Pa. S. Ct. No. 53788
Attorney for Plaintiff
VERIFICATION
The facts set forth in the foregoing are true and correct. to the best of the undersigned's
laiowledge, information and belief and are verified subject to the penalties for unsworn
falsification to authorities under 18 Pa. C.S.A. § 4904.
Dated: 7 S ~ ~ "
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COYNE & COYNE, P.C.
Lisa Marie Coyne, Esquire
Pa. Supreme Ct. No. 53788
3901 Market Street
Camp Hill, PA 17011-4227
(717) 737-0464
Attorney for Plaintiff
KATHLEEN L. HOLLISTER-PEPPERMAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
vs. : NO. d?' ^ S3 xS CIVIL TERM
DONALD L. PEPPERMAN,
Defendant :ACTION IN DIVORCE
TO THE HONORABLE, NDGES OF SAID COURT:
AND NOW comes the Plaintiff/Petitioner, Kathleen L. Hollister-Peppennan, who, by and
through her attorneys, Lisa Marie Coyne, Esquire, files this Petition for Alimony Pendente Lite, Counsel
Fees, Costs and Expenses and Alimony, in which she avers that:
1. Plaintiff/Petitioner, Kathleen L. Hollister-Pepperman, is an adult individual residing at
16 Ardmore Circle, New Cumberland, Cumberland County, Pennsylvania 17070.
2. Defendant/Respondent, Donald L. Pepperman, is an adult individual residing at 6263
Stanford Court, Mechanicsburg, Cumberland County, Pennsylvania.
3. On or about September 10, 2007, Plaintiff/Respondent filed a Divorce Complaint raising,
inter alia, a claim for Alimony Pendente Lite, Counsel Fees, Costs and Expenses, and Alimony.
4. PlaintifflPetitioner and DefendantlRespondent have acquired property, both real and
personal, during the marriage which constitutes marital property subject to equitable distribution under
the Divorce Code.
6. Plaintiff/Petitioner and Defendant/Respondent each owned, prior to the marriage,
personal property which has increased in value during the marriage, and/or which has been exchanged for
other property which has increased in value during the marriage, all of which property is marital
property, subject to equitable distribution under the Divorce Code.
7. Plaintiff/Petitioner and Defendant/Respondent have been unable to agree as to an
equitable division of said property.
8. Plaintiff/Petitioner lacks sufficient property to provide for her reasonable means and is
unable to support herself in the standard of living established during the marriage through appropriate
employment.
10. Plaintiff/Petitioner has employed counsel, but is unable to pay the necessary and
reasonable attorney's fees for said counsel.
11. Plaintiff/Petitioner is unable to sustain herself during the course of this litigation and will
require alimony pendent elite, expenses, and costs in order to do so.
12. Plaintiff/Petitioner requires reasonable alimony to adequately maintain herself in
accordance with the standard of living established during the marriage.
13. Defendant/Respondent has adequate earnings and income and resources to provide for
the Plaintiff's/Petitioner's support and to pay her counsel fees, costs and expenses.
WHEREFORE, Plaintiff/Petitioner, Cheryl E. Merritt, respectfully requests the Court to: (1}
divide all marital property equitably between the parties; (2) enter an award of Alimony Pendente Lite,
I
interim counsel fees, costs and expenses, until final hearing and thereupon award such additional
counsel fees, costs and expenses as deemed appropriate; and (3) enter an award of alimony in her favor.
Respectfully submitted,
COYNE & COYNE, P.C.
Dated: /o S~ u 7 By:
__c1L~'~- -~~
Lis arie Coyne, Esq ' e
a. Supreme Court No 3788
3901 Market Street
Camp Hill, PA 17011-4227
(717) 737-0464
Attorney for Plaintiff/Petitioner
VERIFICATION
The facts set forth in the foregovng are true and correct to the best of the undersigned's
lrnowledge, information .and belief and are verified subject to the penalties for unswom
falsification to authorities under 18 Pa. C.S.A. § 4904.
_ _ .Dated: S,~ ? - °' _.-. - _.. _ - '~--"' . _ _.
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Cmnmonwealth of Pennsvlvania
Co./City/Dist. of CIIrIDERLAND
Date of Order/Notice 09/13/07
Case Number (See Addendum for case summary)
OJ~~~q~}cJ~
0~1-- 535 Civil
XQ Original Order/Notice
Q Arr~nded Order/Notice
Q Terminate Order/Notice
Employer/Withholder's Federal EIN Number
RE. PEPPERMAN, DONALD L.
Employee/Obligor's Name (Last, First, MD
177-42-2391
Employee/Obligor's Social Security Number
DIGITAL INK INC 3521101860
PO BOX 426 Employee/Obligor's Case Identifier
DILLSBURG PA 17019-0426 (SeeAddendamforpiaintiffnames
associated wNh 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 CUt~BERLAAiD 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.
$ 4 s o. o o per month i n current support
$ o . oo per month in past-due support Arrears 12 weeks or greateri Qyes ®no
$ o . oo per month in current and past-due medical support
$ o . 0o Per month for genetic test costs
~ o . oo per month in other (specify)
for a total of $ 480.00 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:
$ 110.1.7 per weekly pay period.
$ 221..5!Iper biweekly pay period (every two weeks).
$ 240.00 per semimonthly pay period (twice a month).
$ 480.00 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.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 1710b-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAMEAND THE PACSES MEM&ER /D (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:
Date of Order: SAP ~ 4 '~~ ~,
Form E - ev. 1
.Service Type M OMBNo.:0970.0154 Worker ID TT
4
~ ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
^ If ~hecke~l you are required to per~~de a~opy of this form to your employee. If yotlr employee works in a state thatkis
di Brent rom the state that lssu is o er, a copy must be provided to your employee even if the box is not chec ed.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee%bligor'sincorne 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%bl igor.
3.* .
. You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4.* Employee/Obligor with Multiple Support Holdings: If there is more than one OrderMotice to Withhold Income for Support against
this employeelobligoranct you are unable to honor all support OrderMotices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employee%bligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2517352020
EMPLOYEE'S/OBLIGOR'S NAME: P$PP$R1KP,N DONALD L
EMPLOYEE'S CASE IDENTIFIER: 3521101860 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%bligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee%bligorfrorn employment,
refusing to employ, or taking disciplinary action against any employee%bligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9.* Withholding limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 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
Service Type M
If you or your employee%bligor 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
.OMB NO.: 0970-0154
Form EN-028 Rev. 1
Worker ID $IATT
~ ~ ADDENDUM
Summary of Cases on Attachment
Defendartt/Obligor: PEPPERMAN, 1~ONALD L.
PACSES Case Number 831109451 PACSES Case Number
Plaintiff Name Plaintiff Name
KATHLEEN L. HOLLISTER-PEPPERMAN
Docket Attachment Amount Docket Attachment Amount
07-5375 CIVIL$ 480.00 $ 0.00
Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB
^ If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
^ If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
^ If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
^ If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
^ If checked, you are required to enroll the child(ren) ^ If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available identified above in any health insurance coverage available
through the employee's/obligor's employment. through the employee's/obligor's employment.
Addendum Form EN-028 Rev. 1
Service Type M Worker ID $IATT
OMB No.: 0970-0154
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KATHLEEN L. HOLLISTER-PEPPERMAN,
Plaintiff/Petitiioner
VS.
DONALD L. PEPPERMAN,
Defendant/Respondent
IN TIIE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -DIVORCE
NO. 07-5375 CIVIL TERM
IN DIVORCE
PACSES Case Number: 831109451
ORDER OF COURT
AND NOW, this 13th day of September, 2007, based upon the Court's determination that
Petitioner's monthly net income%arning capacity is $1,784.42 and Respondent's monthly net
income/earning capacity is $2,801.16, it is hereby ordered that the Respondent pay to the
Pennsylvania State Collection and Disbursement Unit Four Hundred Eighty and 00/100 Dollars
($480.00) per month payable as follows: $480.00 per month for Alimorry Pendente Lite and $0.00 per
month on arrears. First payment due: next pay date at a reate of $221.54 biweekly. The effective date
of the order is September 10, 2007.
Arrears set at $331.40 as of September 13, 2007.
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, at its discretion, make an appropriate Order,
including, but not limited to, commitment of the Respondent to prison for a period not to exceed six
months.
Said money to be turned over by the PA SCDU to: Kathleen L. Hollister-Pepperman.
Payments must be made by check or money order. All checks and money orders must be made
payable to PA SCDU and mailed to:
PA SCDU
P.O. Box 69110
Harrisburg, PA 17106-9110
Payments must include the Respondent's PACSES Member Number or Social Security
Number in order to be processed. Do not send cash by mail.
cc360
;/
The monthly support obligation includes cash medical support in the amount of $250.00
annually for unreimbursed medical expenses incurred for the spouse. Unreimbursed medical expenses
of the obligee that exceeds $250.00 annually shall be allocated between the parties. The party seeking
allocation of unreimbursed medical expenses must provide documentation of expenses to the other
party no later than March 31~` of the year following the calendaz year in which the final medical bill to
be allocated was received. The unreimbursed medical expenses are to be paid as follows: 61 % by
Respondent and 39!/o by Petitioner. ()Respondent (X) Petitioner ()Neither party to provide
medical insurance coverage. Within thirty (30) days after the entry of this Order, the ()Respondent
(X) Petitioner 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 minimum, of: 1) the name
of the health caze 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 $) five copies of any claim forms.
This Order includes an additional sum for annual out of pocket and unreimbursed medical
expenses for the Petitioner in the amount of $400.00 minus $250.00 annually for a total of $150.00 in
annual expenses.
Petitioner is to maintain medical insurance coverage, as provided through her employer, for
the Respondent until the divorce is final.
This order is based upon an agreement of the parties.
This Order shall become final twenty (20) 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
Respondent
Petitioner's Attorney
Respondent's Attorney
BY THE COURT,
`~ ~ ~`
M. L. Ebert, Jr., J.
Mailed copies on: September 14.2007
to: Petitioner
Respondent
Lisa M. Coyne, Esq.
Mark F. Bayley, Esq.
DRO: R.J. Shadday
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COYNE & COYNE, P.C.
Lisa Marie Coyne, Esquire
Pa. Supreme Ct. No. 53788
3901 Market Street
Camp Hill, PA 17011-4227
(717) 737-0464
Attorney for Plaintiff
KATHLEEN L. HOLLISTER-PEPPERMAN,: IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
vs.
N0.07-5375 CIVII. TERM
DONALD L. PEPPERMAN,
Defendant
ACTION IN DIVORCE
CERTIFICATE OF SERVICE
I, LISA MARIE COYNE, ESQUIRE, of Coyne & Coyne, P.C. hereby certify that I have, on the
below date, caused a true and correct copy of the attached Divorce Complaint to be served upon the
person named below by way of certified first class mail, restricted delivery, postage prepaid, return
receipt requested.
Donald L. Pepperman
16 Ardmore Circle
New Cumberland, Pennsylvania 17070
Date
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By:
Lisa Coyne
Pa. S e Ct. No. 53788
3901 Market Street
Carne Hill, PA 17011-4227
(71.7) 737-0464
Attorney for Plaintiff
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COYNE & COYNE, P.C.
Lisa Mazie Coyne, Esquire
Pa. Supreme Ct. No. 53788
3901 Market Street
Camp Hill, PA 17011-4227
(717) 737-0464 Attorney for Plaintiff
KATHLEEN L. HOLLISTER-PEPPERMAN: IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY PENNSYLVANIA
vs.
File No. 07-5375 CIVII. TERM
DONALD L. PEPPERMAN ,
Defendant : ACTION IN DIVORCE
CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.21
TO: Donald L. Pepperman
Mark F. Bayley, Esquire
17 West South Street
Carlisle, PA 17013
As a prerequisite to service of a subpoena for documents and things pursuant to Rule
40009.22, Plaintiff hereby certifies that:
1. A Notice of Intent to Serve A Subpoena, with copies of the subpoenas attached
thereto, was mailed, via First Class Mail, or delivered to each party at least twenty days prior to
the date on which the subpoenas were sought to be served;
2. A copy of the Notice of Intent including the proposed subpoenas, is attached to this
certificate;
3. There were no objections to the subpoenas;
4. The subpoenas to be served are identical to the subpoenas attached to the Notice of
Intent.
Dated: ~S' 2a d~
Respectfully submitted,
COYNE & COYNE, P.C.
By: ~ ~-
sa Marie Coyn ,Esquire
a. Supreme Ct. o. 53788
3901 Market Street
Camp Hill, PA 17011-4227
(717) 737-0464
~-na+~1JLNl~ L• .1~~u~a~~,n-rr,rr~tuvlAly: ~,lv tt~; U;VUK'1' Vr' C:UMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY PENNSYLVANIA
vs. :File No. 07-5375 CIVIL TERM
DONALD L. PEPPERMAN •
Defendant : ACTION IN DNORCE ~~
NOTICE OF INTENT TO SERVE SUBPOENA
TO PRODUCE
DOCUMENTS AND THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.21
Kathleen L. Hollister-Pepperman intends to serve a subpoena identical to the one that is
attached to this notice. You have twenty (20) days from the date listed below in which to file of
record and serve upon the undersigned an objection to the subpoena. If no objection is made the
subpoena maybe served.
DATE: ~ ~ I ~
isa arie Coyne, Esq.
rney for Plaintiff
,.
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
KATHLEEN L. HOLLISTER-PEPPERMAN
Plaintiff
vs.
File No. 07-5375 CNIL TERM
DONALD L. PEPPERMAN
Defendant : ACTION IN DNORCE
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Xerox Corporation
651 East Park Drive
Harrisburg, PA 17111
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce
the following documents or things:
Any and all documents listed below for Mr. Donald L. Pepperman concerning the period of time from
January 1, 2000 to present. Any and all documents and statements concerning any and all 401K Plan,
retirement plan, pension plan, deferred compensation plan, or any other like kind of retirement
vehicle/plan in which Donald L. Pepperman is or was a participant or a recipient of such employment
benefit at Covne and Coyne, P.C.. 3901 Market Street Camn Hill PA 17011-4227
You may deliver or mail legible copies of the documents or produce things requested by this
subpoena, together with the certificate of compliance, to the party making this request at the address listed
above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the
things sought.
If you fail to produce the documents or things required by this subpoena within twenty(20) days
after its service, the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: Lisa Marie Coyne
ADDRESS: 3901 Market Street
Camp Hill, PA 17011-4227
TELEPHONE: (717) 737-0464
SUPREME COURT ID #: 53788
ATTORNEY FOR: Kathleen L. Hollister-Pepperman
Date:
Seal of the Court
BY THE COURT:
Prothonotary, Civil Division
Deputy
KATHLEEN L. HOLLISTER-PEPPERMAN,: IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
vs. : N0.07-5375 CIVIL TERM
DONALD L. PEPPERMAN,
Defendant : ACTION IN DIVORCE
CERTIFICATE OF SERVICE
I, Lisa Marie Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the Notice
of Intent to Serve a Subpoena to Produce Documents and Things for Discovery Pursuant to Rule
F
4009.21was served this date upon the below-referenced individuals at the below listed address by way of
first class mail, postage pre-paid:
Mark F. Bayley, Esquire
17 West South Street
Carlisle, PA 17013
Dated: ~" ~ ~?
r
~---
Li,~a 'e Coyne, Esquire
39 arket Street
Camp Hill, PA 17011-4227
(717) 737-0464
Pa. S. Ct. No. 53788
Attorney for Plaint
KATHLEEN L. HOLLISTER-PEPPERMAN: IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY PENNSYLVANIA
vs. :File No. 07-5375 CIVIL TERM
DONALD L. PEPPERMAN ,
Defendant : ACTION IN DIVORCE
NOTICE OF INTENT TO SERVE A SUBPOENA
TO PRODUCE
DOCUMENTS AND THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.21
Plaintiff, Kathleen L. Hollister-Pepperman intends to serve a subpoena identical to the
one that is attached to this notice. You have twenty (20) days from the date listed below in
which to file of record and serve upon the undersigned an obj ection to the subpoena. If no
objection is made the subpoena maybe served.
DATE: ~~ ~'~
.~----
Lisa arie Coyne, Es .
rney for Plaintiff
..........
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
KATHLEEN L. HOLLISTER-PEPPERMAN
Plaintiff
vs.
File No. 07-5375 CIVIL TERM
DONALD L. PEPPERMAN
Defendant :ACTION IN DIVORCE
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Digital Ink, Inc.
P.O. Box 426
Dillsburg, PA 17019
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce
the following documents or things:
Any and all documents listed below for Mr. Donald L. Pepperman concerning the period of time from
January 1, 2000 to present.
1. All income and earnings statements to include Monthly Earnings Statements, pay stubs, etc.
2. W-2 forms
3. Any and all documents and statements concerning any and a11401K Plan, retirement plan,
pension plan, deferred compensation plan, or any other like kind of retirement vehicle/plan in which
Donald L. Pepperman is or was a participant or a recipient of such employment benefit at Coyne and
Coyne, P.C., 3901 Market Street, Camp Hill, PA 17011-4227.
You may deliver or mail legible copies of the documents or produce things requested by this
subpoena, together with the certificate of compliance, to the party making this request at the address listed
above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the
things sought.
If you fail to produce the documents or things required by this subpoena within twenty(20) days
after its service, the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: Lisa Marie Coyne
ADDRESS: 3901 Market Street
Camp Hill, PA 17011-4227
TELEPHONE: (717) 737-0464
SUPREME COURT ID #: 53788
ATTORNEY FOR: Kathleen L. Hollister-Pepperman
BY THE COURT:
Prothonotary, Civil Division
Date:
Seal of the Court
Deputy
KATHLEEN. L. HOLLISTER-PEPPERMAN,: IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
vs. : N0.07-5375 CIVIL TERM
DONALD L. PEPPERMAN, .
Defendant : ACTION IN DNORCE
CERTIFICATE OF SERVICE
I, Lisa Marie Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the Notice
of Intent to Serve a Subpoena to Produce Documents and Things for Discovery Pursuant to Rule
4009.21was served this date upon the below-referenced individuals at the below listed address by way of
first class mail, postage pre-paid:
Mark F. Bayley, Esquire
17 West South Street
Carlisle, PA 17013
Dated: ~ ~ ~
r
~~ }
Li 'e Coyne, Esquire
39 arket Street
Camp Hill, PA 17011-4227
(717 737-0464 `
Pa. S. Ct. No. 53788
Attorney for Plaintiff
xa~rtit.~;~N L. HOLLISTER-PEPPERMAN: IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY PENNSYLVANIA
vs. :File No. 07-5375 CIVIL TERM
DONALD L. PEPPERMAN
Defendant : ACTION IN DNORCE
NOTICE OF INTENT TO SERVE SUBPOENA
TO PRODUCE
DOCUMENTS AND THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.21
Kathleen L. Hollister-Pepperman intends to serve a subpoena identical to the one that is
attached to this notice. You have twenty (20) days from the date listed below in which to file of
record and serve upon the undersigned an objection to the subpoena. If no objection is made the
subpoena maybe served.
DATE: (' ~ '
'~~~- r-^
sa arie Coyne, Es .
A ey for Plaintiff
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
KATHLEEN L. HOLLISTER-PEPPERMAN
Plaintiff ,
vs.
File No. 07-5375 CNIL TERM
DONALD L. PEPPERMAN
Defendant :ACTION IN DNORCE
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Hewitt Associates, LLC
One Oxford Centre
Pittsburg, PA 15219
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce
the following documents or things:
Any and all documents .listed below for Mr. Donald L. Pepperman concerning the period of time from
January 1, 2000 to present. Any and all documents and statements concerning any and all 401K Plan,
retirement plan, pension plan, deferred compensation plan, or any other like kind of retirement
vehicle/plan in which Donald L. Pepperman is or was a participant or a recipient of such employment
benefit at Coyne and Come, P.C., 3901 Market Street, Camp Hill PA 17011-4227
You may deliver or mail legible copies of the documents or produce things requested by this
subpoena, together with the certificate of compliance, to the party making this request at the address listed
above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the
things sought.
If you fail to produce the documents or things required by this subpoena within twenty(20) days
after its service, the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: Lisa Marie Coyne
ADDRESS: 3901 Market Street
Camp Hill, PA 17011-4227
TELEPHONE: (717) 737-0464
SUPREME COURT ID #: 53788
ATTORNEY FOR: Kathleen L. Hollister-Pepperman
Date:
-Seal of the Court
BY THE COURT:
Prothonotary, Civil Division
Deputy
KATHLEEN L. HOLLISTER-PEPPERMAN,: IN THE COURT OF COMMON PLEAS OF
Plaintiff : CITMBERLAND COUNTY, PENNSYLVANIA
vs. : N0.07-5375 CNII., TERM .
DONALD L. PEPPERMAN,
Defendant
ACTION IN DIVORCE
CERTIFICATE OF SERVICE
I, Lisa Mane Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the Notice
of Intent to Serve a Subpoena to Produce Documents and Things for Discovery Pursuant to Rule
4009.21was served this date upon the below-referenced individuals at the below listed address by way of
first class mail, postage pre paid:
Mark F. Bayley, Esquire
17 West South Street
Carlisle, PA 17013
Dated: ~l ~ ~?
r
~-
L' ~e Coyne, Esquire
39 arket Street
Camp Hill, PA 17011-4227
(717) 737-0464
Pa. S. Ct. No. 53788
Attorney for Plaintiff'
CERTIFICATE OF SERVICE
I, Lisa Marie Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that a true copy of
the Certificate Prerequisite To Service Of A Subpoena Pursuant To Rule 4009.21 was served this
date upon the below-referenced individuals at the below listed address by way of first class mail,
postage pre-paid:
Mark F. Bayley, Esquire
17 West South Street
Carlisle, PA 17013
Dated: 2 j o
i~~ ~._
isa Marie Coyr) ,Esquire
3901 Market Street
Camp Hill, PA 17011-4227
(717) 737-0464
Pa. S. Ct. No. 53788
Attorney for Plaintiff'
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COYNE & COYNE, P.C.
Lisa Marie Coyne, Esquire
Pa. Supreme Ct. No. 53788
3901 Market Street
Camp Hill, PA 1 70 1 1-4227
(717) 737-0464
Attorney for Plaintiff
KATHLEEN L. HOLLISTER-PEPPERMAN,
Plaintiff
vs.
DONALD L. PEPPERMAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
N0.07-5375 CIVIL TERM
ACTION IN DIVORCE
MOTION TO COMPEL DISCOVERY
TO THE HONORABLE JUDGES OF SAID COURT:
AND NOW COMES the Plaintiff, Kathleen Hollister-Pepperman, by and through her
attorney, Lisa Marie Coyne, Esquire, and moves this Honorable Court to grant his Motion to
Compel Discovery and, in support thereof, respectfully represents the following:
1. On September 4, 2008, the Plaintiffs Counsel served Plaintiff's Second Set of
Request for Production of Documents on Defendant's Counsel.
2. No objections or protective orders where sought by Defendant concerning the
discovery propounded upon Defendant.
3. On October 19, 2008, Plaintiff s Counsel sent a letter to Defendant's Counsel that
the response to the Discovery request was overdue and requested opposing counsel to immediately
provide the requested discovery. (Exhibit A).
4. On October 17 and 27, 2008, Plaintiff s Counsel called and left a message for
Defendant's Counsel requesting that he comply with the Discovery Request. Plaintiff's Counsel
has attempted to resolve the issue with no response received from Defendant's Counsel.
5. As of the date of this Motion, Defendant has not answered the discovery propounded
upon him and Plaintiff has not received any of the requested discovery materials as requested in
Plaintiff's discovery requests.
6. Without the required discovery materials, Plaintiff cannot adequately prepare for
trial.
7. Plaintiff is financially disadvantaged in comparison to Defendant whose salary is
approximately $1050 net per month more than Plaintiff s.
8. Plaintiff through counsel has attempted to resolve the discovery dispute short of
filing this motion and the associated expenses caused to Plaintiff due to the Defendant's failure to
comply with the discovery requests and the various extensions provided to Defendant.
9. The undersigned counsel has attempted to confer with opposing counsel via
telephone and written correspondence; however, opposing counsel has been unresponsive and
therefore, in accordance with the local rules of this court, it is believed that that opposing counsel
opposes the relief sought in this motion.
10. No judge has previously been assigned to this case.
WHEREFORE, for all of the foregoing reasons, the Defendant respectfully requests that this
Honorable Court order the Defendant and Defendant's Counsel to (1) immediately provide the
discovery materials requested in Plaintiff's discovery request and (2) to award Plaintiff reasonable
attorney fees incurred by Plaintiff in pursuing this Motion to Compel and which would not have
been incurred if Defendant had complied with the reasonable discovery requests, and (3) all other
relief deemed appropriate by this Honorable Court.
Respectfully submitted:
Dated:_ ~p 4CT a g
COYNE & COYNE, P.C.
By. ~ ~
sa arie Coyne, Esq ire
. Ct. No. 53788
3901 Market Street
Camp Hill, PA 17011-4227
(717) 737-0464
Attorney for Plaintiff
CERTIFICATE OF SERVICE
I, Lisa Marie Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the foregoing
Motion to Compel was served this date upon the below-referenced individuals at the below listed address by
way of first class mail, postage pre-paid:
Mark F. Bayley, Esquire
Bayley & Mangan
17 West South Street
Carlisle, PA 17013
Dated: ~ O G7 g'
L' a arie Coyne, Esq ' e
39 Market Street
Camp Hill, PA 1 70 1 1-4227
(717) 737-0464
Pa. S. Ct. No. 53788
Attorney for Plaint
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COYNE & COYNE, P.C.
Lisa Marie Coyne, Esquire
Pa. Supreme Ct. No. 53788
3901 Market Street
Camp Hill, PA 1 70 1 1-4227
(717) 737-0464
Attorney for Plaintiff
KATHLEEN L. HOLLISTER-PEPPERMAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner :CUMBERLAND COUNTY, PENNSYLVANIA
vs.
DONALD L. PEPPERMAN,
Defendant/Respondent
N0.07-5375 CIVIL TERM
ACTION IN DIVORCE
PACSES Case Number: 831109451
PETITION FOR MODIFICATION
OF AN EXISTING ALIMONYPENDENTE LITE ORDER
TO THE HONORABLE, Judges of Said Court:
AND NOW COMES the Plaintiff, Kathleen L. Hollister-Pepperman, by and through her
attorneys, COVNE & COYNE, P.C. and avers the following in support of her Petition to Modify
an Existing Alimony Pendente Lite Order:
1. Petitioner, Kathleen Hollister-Pepperman respectfully represents that on
September 13, 2007, an Order of Court for Alimony Pendente Lite was entered for, Plaintiff,
Kathleen L. Hollister-Pepperman. A true and correct copy of the order is attached to this petition
as Exhibit "A".
2. Petitioner is entitled to an increase in Alimony Pendente Lite of this Order because
of the following material and substantial change(s) in circumstance:
a. Respondent Donald L. Pepperman's income has increased substantially from the
annual gross income amount used to determine the initial APL amount.
b. Petitioner has employed counsel, but is unable to pay the necessary and
reasonable attorney's fees for said counsel.
c. Petitioner is unable to sustain herself during the course of this litigation and will
require alimony pendent elite, expenses, and costs in order to do so.
d. Petitioner requires reasonable alimony to adequately maintain herself in
accordance with the standard of living established during the marriage.
e. Respondent has adequate earnings and income and resources to provide for the
Plaintiff's/Petitioner's support and to pay her counsel fees, costs and expenses.
WHEREFORE, Petitioner requests that the Court modify the existing order for
Alimony Pendente Lite.
Respectfully submitted:
COYNE & COYNE, P.C.
Dated: ~ D Rio d
r
Lis Marie Coyne, Esq ire
P . S. Ct. No. 53788
901 Market Street
Camp Hill, PA 17011-4227
(717)737-0464
Attorney for Plaintiff
_~
Iu'rxi.~Ex i.. a0iiis~R-rErP$~N, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petltiloner CUMBERi.AND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION -DIVORCE
DONALD L. PEPPERMAN,
Defendant/R~aposdent
NO. 07-5375 CIVIL TERM
IN DIVORCE
PACSES Case Number. 831109451
ORDER OF COURT
AND NOW, this 13th day of September, 2007, based upon the Courts determination that
Petitioner's monthly net incomeJearning capacity is 51,784.42 and Respondent's monthly net
income%arning capacity is 52,801.16, it is hereby ot~dered that the Respondent pay to the
Pennsylvania State Collection and Disbursement Unit Four Hundrod Eighty and 00/100 Dollars
(5480.00) per month payable as follows: 5480.00 per month for Alimorry Peruler-te Lite and $0.00 per
month on arrears. First payment due: next pay date at a taste of 5221.54 biweekly. The effective date
of the order is September 10, 2007.
Arrears set at 5331.40 as of September 13, 2007.
Failure to make each payment on tune and in full will cause all arrears to become subject to
immediate collection by all of the means as provided by 23 PaC.S.§ 3703. Further, if the Court
finds, alter hearing, that the Respondent has willfully failed to comply with this Order, it may declare
the Respondent in civil contempt of Court and, at its discretion, make as 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 aver by the PA SCDU to: Kathleen L. Hollister-Pcpperman.
Payments must be made by check or money order. All checks and money orders must be made
payable to PA SCDU and mailed to:
PA SCDU
P.O. Box 69110
Harrisburg, PA 17106-9110
Payments must include the Respondent's PACSES Member Number or Social Security
Number in order to be processed. Do not send cash by mail.
cc360
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The monthly support obligation includes cash medical support in the mount of X250.00
annually for unreimbiu~ed medical expenses inctarod for the spouse. Unreimbursed medical expenses
of the obligee that exceeds 5250.00 annually shall be allocated between the parties. The party seeking
allocation of wn+eimbucsed medical expenses must provide documentation of expenses to the other
party no later than March 31'~ of the year following the calendar year in which the final medical bill to
be allocated was received. The unreimbursed medical expenses are to be paid as follows: 62% by
Respondent and 39'/. by Petitioner. ()Respondent (X) Petitioner () Neither party to provide
medical insinatx~e coverage. Within thirty (30} days after the ely0ry of this Order, the ()Respondent
(X) Petitioner shall subunit 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: 1) the name
of the health care coverage provider(s); 2) atry 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; ~ a description of all deductibles and
co-payments; and 8) five copies of any claim forms.
This Order includes an additional sum for annual out of pocket and unreimbursed medical
expenses for the Petitioner in the amount of $400.00 minus $250.00 annually for a total of ~ 150.00 in
annual expenses.
Petitioner is to maintain medical insurance coverage, as provided through her employer, for
the Respondent until the divorce is final.
This order is based upon an agreement of the parties.
This Order shall become final twenty (20) 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
rove before the Court.
Consented:
Petitioner
Petitioner's Attorney
Respondtnt
Mailed copies on: Septeeiber 14.2007
to: Petitioner -
Rospondent
Liss M. Coynq Esq.
Mark F. Bayley, Esq
DRO: RJ. Shaddsy
Respondent's Attorney
BY THE COURT,
~ ~
M. L. Ebert, Jr., J.
,r
~_ ORDER/NOTICE TO WITHHOLD INCOME fFOR SUPPORT
State $3t t Oq 4 ~1 Q Original OrderMarice
Co./City/Dist. of Ct>Irl88RLAND Q Amended OrderMarice
Date of Order/Notice 09/13/07 ~1- 531 CJ C1Vtt O Terminate OrdedNarice
Case Number (Ste Addendum for case summary)
REc PSPPBRMAN, DONALD L.
Employer~thholder's Federal EIN Number Employee/Obligor's Name (Last, First, Mq
DIt3ITAL INR INC
PO HOX 425
DILLSHIIRC3 PA 17019-0426
177-4s-13s1
Employee/Obligot's Social Security Number
35Z11018i0
EmplayeePObligor's Case Identifier
(See Addendum t6r plairrilf names
ssaoBafaal w110 m~er an atYa~nKnf)
Custodial Parentis Name (Last, First, MI)
See Aaldendvm for dependent names and birth datm assodated widr calm on attadurienL
ORDER INFORMATION: This is an OrderMotice to Withhold income for Support based upon an order for support
from C[A488RLAND 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 OrderlNotice is not
issued by your State.
$ 4ao . 0o per month in current support
$ o . oo per month in past-due support Arrears 12 weeks or greaten' Qyes ®no
$ o . oo per month in current and past-due medical support
$ o , pQ per month for genetic test costs
$ _ o . oo per month in other (specify)
for a total of S X80.00 Per month to be forwarded to payee below.
You do not have to vary your pay cycle to be incompliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ ilo .~.~ per weekly pay period.
$ 221 . b~4per biweekly pay period (every two weeks).
$ - 240 . oo per semimonthly pay period (twice a month).
$ 4 s o. o o 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 5586 of the employee's! obligor's
aggregate disposable weekly earrings. 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. 3 4374(b)) to snit by electronic payment method, please call
Pennsylvania State Cdlections and Disbursement Unit (PA SCDU) Employer Customer Service at i-877-676.9580
for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT' NAMEAND THE PACSES MEMtER /D (shown
above as the Employee/ObllRor's Cane Identifier) OR SOCGIt SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND GSH BY MAIL.
Date of Order: SEP 1 ~ ?D01
Service Type M
BY THE COURT:
.L.
Form .1
oA+e-a.:o9mo,s, WOrkerlD ~
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. § 4904 relating to
unsworn falsification to authorities.
Date
~~(aw..
Kathleen L. Hollister-Pepperman
CERTIFICATE OF SERVICE
I, Lisa Marie Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the foregoing
Petition to Modify APL was served this date upon the below-referenced individuals at the below listed
address by way of first class mail, postage pre-paid:
Mark F. Bayley, Esquire
Bayley & Mangan
17 West South Street
Carlisle, PA 17013
Dated: ~ 4 v 0 f(
isa ~e Coyne, Esquire
901 arket Street
am Hill, PA 17011-4227
( ) 737-0464
Pa. S. Ct. No. 53788
Attorney for Plaint
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KATHLEEN L. HOLLISTER-PEPPERMAN, THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION -DIVORCE
. NO. 07-5375 CIVIL TERM
DONALD L. PEPPERMAN, IN DIVORCE
Defendant/Respondent
. PACSES CASE NO: 831109451
ORDER OF COURT
AND NOW, this 3rd day of November, 2008, a petition has been filed against you, Donald L. Pepperman ,
to modify an existing Alimony Pendente Lite Order. You aze ordered to appeaz in person at the Domestic Relations
Section, 13 North Hanover Street, Carlisle, Pennsylvania, on December 1.2008 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 ~ ~ ~! ~~ s { 1
4v
entered against you.
You aze 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 caze 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,
Edgar B. Bayley, President Judge
Copies mailed to: Petitioner
Respondent
Lisa M. Coyne, Esq.
Mazk F. Bayley, Esq. ~ ~ FIA
Date of Order: November 3, 2008
. J. Sh day, Conference Officer
~i~
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
cc361
I<~4THLEEN L. HOLLISTER-PEPPERMAN,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
DONALD L. PEPPERMAN,
DEFENDANT
NO. 07-5375 CIVIL
ORDER OF COURT
AND NOW, this 20th day of November, 2008, upon consideration of the Motion to
Compel Discovery filed by the Plaintiff,
IT IS HEREBY ORDERED AND DIRECTED that:
1, A Rule is issued upon the Defendant to show cause why the relief requested should
not be granted;
2. The Defendant will file an answer on or before December 10, 2008;
3. If no answer to the Rule to Show cause is filed by the required date, the relief
requested by Plaintiff shall be granted upon the Court's receipt of a Motion requesting Rule be
made Absolute. If the Defendant files an answer to this Rule to Show Cause, the Court will
determine if further order or hearing is necessary.
4. The Prothonotary is directed to forward said Answer to this Court.
By the Court,
/ Lisa Marie Coyne, Esquire
Attorney for Plaintiff
/ Mark Bayley, Esquire
Defendant
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M. L. Ebert, Jr., J.
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 831109451
07-5375 CIVIL
State Commonwealth of P nn y nia OOriginal Order/Notice
CO./City/Dist. Of CUMBERLAND OAmended Order/Notice
Date of Order/Notice 12/01/08 OTerminate Order/Notice
Case Number (See Addendum for case summary) QOne-Time Lump Sum/Notice
Employer/Withholder's Federal EIN Number
DIGITAL INK INC
PO BOX 426
DILLSBURG PA 17019-0426
177-42-2391
Employee/Obligor's Social Security Number
3521101860
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, Mq
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$
$ o.oo
o.oo
$ o.oo
$ o.oo
$ 587.00
$ o.oo
$ o.oo
$ o.oo
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
for a total of $ 587.00 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:
$ 135.46 Per weekly pay period. $ 293 . so per semimonthly pay period
(twice a month)
$ 270.92 per biweekly pay period (every two weeks) $ 587 . oo per monthly pay period.
REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10)
working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of
withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work
state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of
the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding,
the following information is needed (See #9 on page 2).
If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call
Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580
for instructions. PA FIPS CODE 42 000 00
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER 1D (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER /N ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MA/L.
BY THE COURT:
D}ZO: R.J. Shadday
Service Type M
RE: pEPPERMAN, DONALD L.
Employee/Obligor's Name (Last, First, Mq
Arrears 12 weeks or greater? 0 yes ®no
M.~
OMB No.: 0970-0154
Form EN-028 Rev. 4
Worker ID $IATT
567• x
12•~
52•-
135.46*
~~~
56?• x
~2•-
26• -
27~>•92
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
~ If~hecked you are required. to provide a~opy of this form to your em loyee. If yo r employee works in a state that is
di Brent from the state that issued this or er, a copy must be providedpto your emp~oyee 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%bligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employee/obligor.
3.* 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%bligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employee%bligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. 2517352020
THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : ~ THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: D
EMPLOYEE'S/OBLIGOR'S NAME: PEPPERMAN, DONALD L.
EMPLOYEE'S CASE IDENTIFIER: 3521101860 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%bligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee%bligorfrnm employment,
refusing to employ, or taking disciplinary action against any employee%bligorbBcause 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 $IATT
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: PEPPERMAN, DONALD L.
PACSES Case Number 831109451 PACSES Case Number
Plaintiff Name Plaintiff Name
KATHLEEN L. HOLLISTER-PEPPERMAN
Docket Attachment Amount Docket Attachment Amount
07-5375 CIVIL$ 587.00 $ 0.00
Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ o.oo
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ o.oo
Child(ren)'s Name(s):
Service Type M
DOB
Addendum
OMB No.: 0970-0154
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ o.oo
Child(ren)'s Name(s):
DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ o.oo
Child(ren)'s Names}: DOB
Form EN-028 Rev. 4
Worker ID $IATT
na
KATHKEEN L. HOLLISTER-PEPPERMAN,: IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION -DIVORCE
NO. 07-5375 CIVIL TERM
DONALD L. PEPPERMAN, IN DIVORCE
Defendant/Respondent
PACSES Case No: 831109451
ORDER OF COURT
AND NOW, this 1st day of December 2008, based upon the Court's determination that the
Petitioner's monthly net income/earning capacity is $ 1,871.44 and the Respondent's monthly net
income/earning capacity is $ 3,284.84, it is hereby ordered that the Respondent pay to the
Pennsylvania State Collection and Disbursement Unit Five Hundred Eighty Seven and 00/100 Dollars
($ 587.00) per month payable bi-weekly as follows: $ 587.00 per month for Alimony Pendente Lite
and $ 0.00 per month on arrears. First payment due: in accordance with Respondent's pay schedule
in the amount of $ 270.92 bi-weekly. The effective date of the order is October 31, 2008.
Arrears set at $ 558.98 as of December 1, 2008.
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, at its discretion, make an appropriate Order,
including, but not limited to, commitment of the Respondent to prison for a period not to exceed six
months.
Said money to be turned over by the PA SCDU to: Kathleen L. Hollister-Pepperman.
Payments must be made by check or money order. All checks and money orders must be made
payable to PA SCDU and mailed to:
PA SCDU
P.O. Box 69110
Harrisburg, PA 17106-9110
Payments must include the Respondent's name with their PACSES Member Number or
Social Security Number in order to be processed. Do not send cash by mail.
cc360
The monthly support obligation includes cash medical support in the amount of $250 annually
for unreimbursed medical expenses incurred for the obligee. Unreimbursed medical expenses of the
obligee that exceed $250 annually shall be allocated between the parties. The party seeking allocation
of unreimbursed medical expenses must provide documentation of expenses to the other no later than
March 31 S` of the year following the calendar year in which the final medical bill to be allocated was
received. The unreimbursed medical expenses are to be paid as follows: 64 % by the Respondent
and 36 % by the Petitioner. [] Respondent [X] Petitioner to provide medical insurance coverage.
Within thirty (30) days after the entry of this order, the [X] Petitioner [] Respondent shall submit
written proof that the medical insurance coverage has been obtained or that application for coverage
has been made. Proof of coverage shall consist of, at a minimum of: 1) the name of the health care
coverage provide(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 includes an additional sum for annual out of pocket and unreimbursed medical
expenses for the Petitioner in the amount of $600.00 minus $250.00 annually for a total of $350.00 in
annual expenses.
The Petitioner is to maintain medical insurance coverage, as provided through her employer,
for the Respondent until the divorce is final.
This Order shall become final twenty (20) 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
Respondent
Petitioner's Attorney
Respondent's Attorney
Mailed copies on: December 2. 2008
to: Petitioner
Respondent
Lisa M. Coyne, Esq.
Mark F. Bayley, Esq.
BY THE COURT,
M. L. Ebert, Jr., J.
DRO: R.J. Shadday
,_
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S
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KATHLEEN L. HOLLISTER-PEPPERMAN,
Plaintiff
vs.
DONALD L. PEPPERMAN
IN THE COURT OF COMMON
PLEAS, CUMBERLAND
COUNTY, PENNSYLVANIA
N0.07-5375 CIVIL
DEFENDANT'S RESPONSE TO PLAINTIFF'S MOTION TO COMPEL
DISCOVERY AND RULE TO SHOW CAUSE ISSUED NOVEMBER 20.2008
AND NOW, comes Donald Pepperman, by and through his attorney, Mazk F.
Bayley, and in response to Plaintiffs Motion to Compel Discovery avers as follows:
1. Defendant forwazded his first set of discovery requests to Plaintiff s
counsel on August 12, 2008.
2. Plaintiff forwarded her second set of discovery requests (the first set had
long since been answered by Defendant) on September 4, 2008.
3. On October 2, 2008 Undersigned Counsel faxed a letter to Plaintiffs
Counsel inquiring into whether her client would be responding to Defendant's first set of
requests (prior to Defendant commencing work on Plaintiff s second set); the same day
Plaintiff forwazded responses.
4. It appeazs to Undersigned Counsel that the only outstanding debate
regazding Plaintiff s second set of requests relates to Defendant's childhood baseball cazd
collection; Plaintiffs Counsel has demanded that she be provided the baseball card
collection at her office.
5. Defendant acquired the baseball card collection well before the parties
were married and it is not mazital property; Defendant estimates there aze over 1000 cazds
in the collection which is currently stored in a medium sized box.
6. Defendant is no expert in the value of baseball cards; he believes the
collection is worth between $2,000. and $3,000; the collection likely has more
sentimental value to Defendant than cash value.
7. Defendant has no desire to leave his card collection in the hands of his
wife's attorney.
Despite the collection's apparent lack of relevance, Undersigned Counsel
offered, by letter dated November 11, 2008, to arrange a date to have Defendant make the
collection available for inspection by Plaintiffs Counsel at Undersigned Counsel's office.
9. By letter dated November 25, 2008, Plaintiffs Counsel alternatively
demanded that Defendant make a "list of all of the baseball cards, with the name on the
card, the year of the card, date acquired and present value."
10. Such a list would likely take Defendant days to create which would be a
waste of time seeing that the majority of the cards have nominal book values.
11. Undersigned Counsel believes that an experienced baseball card dealer
and/or collector could likely skim through the collection and give a ballpark estimate
within a half hour; Undersigned Counsel suggested this approach to Plaintiffs Counsel
by letter dated November 28, 2008 and has not received a response to date.
12. Undersigned Counsel's invitation for Plaintiffs Counsel, and/or her agent,
to inspect the collection at Undersigned Counsel's office and in the presence of Defendant
remains open.
Respe lly subm' ,
F. Bayley, squire
17 West South Street
Carlisle, PA 17013
(717) 241-2446
Supreme Court I.D.#87663
.,,, `
KATHLEEN L.HOLLISTER-PEPPERMAN,: IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY,PENNSYLVANIA
V• No. 07 - 5375 CIVIL TERM
DONALD L. PEPPERMAN, :CIVIL ACTION -LAW
Defendant IN DIVORCE
VERIFICATION
Mark F. Bayley, Esquire, states that he is the attorney for Deffendant in this action; that
he makes this affidavit as attorney because he has sufficient knowledge or information and
belief, based upon his investigation of the matters averred or denied in the foregoing document;
and that this statement is made subject to the penalties of 18 Pa. C.S. Pa. C.S. §4904, relating to
unsworn falsification to authorities.
Date 7 J ) / ~
l., I v
Mark F. Bayley, squire
Attorney for Defendant
KATHLEEN L.HOLLISTER-PEPPERMAN,: IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY,PENNSYLVANIA
V' No. 07 - 5375 CIVIL TERM
DONALD L. PEPPERMAN, :CIVIL ACTION -LAW
Defendant IN DIVORCE
CERTIFICATE OF SERVICE
I, Mazk F. Bayley, Esquire, attorney for Defendant do hereby certify that I this day served
a copy of the foregoing document upon the following by depositing same in the United States
mail, postage prepaid, at Cazlisle, Pennsylvania, addressed as follows:
Lisa Marie Coyne, Esquire
3901 Market St.
Camp Hill, PA 17011-4227
Dated: ~ J ~C~
Mazk F. Bayley, Esquire
Attorney for Defendant
~~
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COYNE & COYNE, P.C.
Lisa Marie Coyne, Esquire
Pa. Supreme Ct. No. 53788
3901 Market Street
Camp Hill, PA 17011-4227
(717) 737-0464
Attorney for Plaintiff
KATHLEEN L. HOLLISTER-PEPPERMAN,: IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
vs.
DONALD L. PEPPERMAN,
Defendant
N0.07-5375 CIVIL TERM
ACTION IN DIVORCE
MOTION TO MAKE RULE ABSOLUTE
To the Honorable, Judge Ebert:
And now comes the Plaintiff, Kathleen Hollister-Pepperman by and through her counsel,
Lisa Marie Coyne, Esquire, and avers the following in support of this Motion to Make Rule
Absolute:
1. On October 30, 2008, Plaintiff filed a Motion to Compel Discovery concerning
Defendant's failure to provide requested Discovery to Plaintiff which was due October 5, 2008.
A Copy of the Motion is Attached as Exhibit "A".
2. On November 20, 2008, this Honorable Court issued a Rule upon the Plaintiff to
show cause why the relief requested should not be granted and made the rule returnable by
December 10, 2008. (A copy of an Order of Court is attached as Exhibit "B.")
3. Defendant filed a Response to Plaintiff's Motion to Compel Discovery and Rule
1
to Show Cause on December 10, 2008; however, Defendant did not provide any of the requested
discovery material to Plaintiff. (A copy of the Response is attached as Exhibit "C")
4. Notably, pursuant to the Pennsylvania Rules of Civil Procedure No. 4009.12
Defendant did not file any objections to the requested Discovery within thirty days of service of
Plaintiff's Request for Production of Documents and by way of further response, Plaintiff
provides the following information in Response, seriatim, to Defendant's Response to Rule to
Show Cause of December 10, 2008:
a. 1. Admitted.
b. 2. Admitted.
c. 3. Admitted in part and Denied in Part. Admitted that on October 2, 2008
Defendant's Counsel faxed a letter to Plaintiff's Counsel concerning status of Answers to
Discovery. It is denied that Plaintiff had not already provided responses to Defendant which
were mailed to Defendant prior to Defendant's fax. Furthermore, unlike Defendant, Plaintiff has
complied with all discovery requests propounded by Defendant.
d. 4. Denied. It is specifically denied that the only "outstanding debate" regarding
Plaintiff s second set of Requests for Production of Documents relates to Defendant's "childhood
baseball card collection". It is specifically denied that Plaintiff s Counsel demanded that she be
provided the baseball card collection at her office. By way of further answer, the Defendant has
not provided the requested any information concerning his coin collection or the baseball card
collection. Additionally, Plaintiff did not "demand" that the baseball card collection be provided
at her office. Plaintiff s counsel requested in the Second Request for Production of Documents
2
that Pursuant to Pa. R.C.P. 4009, that the Defendant was requested to produce, within thirty (30)
days of the date of the request, the below-listed documents and/or items for purposes of
discovery. This material will be examined and/or photocopied. Said documents or tangible
things are to be produced at the office of Coyne & Coyne, P.C., 3901 Market Street, Camp Hill,
Pennsylvania 17011-4227. The material in question inter alia was the baseball card and coin
collections. This request was propounded upon Defendant's counsel on September 4, 2008.
Defendant's counsel never filed any objection to the Request for Production of Documents
within the 30 day time frame under Pa.R.C.P. 4009.12. Furthermore, Plaintiff has repeatedly
requested that as a reasonable compromise that Defendant produce an inventory of the
collections which Defendant refuses.
e. 5. Denied. After reasonable investigation, Plaintiff is without knowledge or
information sufficient to form a belief as to the truth of when Defendant acquired the baseball
card or coin collection contents, the number of items in the collection, or the manner of storage
of the collections. It is denied that the baseball card collection and the coin collections are not
marital property.
f. 6. Denied. After reasonable investigation and since Defendant has not provided
the baseball cards or the coins to Plaintiff for inspection or even provided an inventory of the
collections, Plaintiff is without knowledge or information sufficient to form a belief as to the
truth of the value of the collections or what the Defendant believes their value to be and the same
is therefore strictly denied.
3
g. 7. Denied. Plaintiff is without knowledge or information sufficient to form a
belief on what Defendant's desires are and the same is therefore specifically denied. By way of
further answer, Plaintiff has repeatedly offered to Defendant the option to provide Plaintiff which
a written inventory of the collections; however, even with that compromise, Defendant refuses to
provide any specific information concerning the individual contents of the collections.
h. 8. Admitted in part and Denied in part. Admitted that Defendant's Counsel sent
a letter to Plaintiff s counsel on November 11, 2008 offering to arrange a date to have Defendant
make the collection available for inspection at Defendant's Counsel Office. It is specifically
denied that the collection "lacks relevance" merely by Defendant's counsel proclamation and
without having previously filed any objection to the discovery requests as required by the Rules
of Civil Procedure. By way of further answer, Defendant's Counsel's letter was sent
approximately six weeks after the Discovery was already overdue and after Plaintiff had to
undertake the steps of filing a Motion to Compel. Furthermore, the divorce code provides at 23
Pa.C.S.A. § 3501 states that, "`marital property' means all property acquired by either party
during the marriage, including the increase in value, prior to the date of final separation of any
non-marital property acquired pursuant." Furthermore, while generally only property acquired
after marriage and prior to separation is considered marital property, those separate estates and
net worth of a party is a relevant consideration in any claim for equitable distribution. Thus, the
Pennsylvania Rules of Discovery allow for the discovery of any material not privileged, which is
relevant to the subject matter involved in the pending action. It is not for the Defendant to
determine if the requested Discovery is marital property, that matter remains this Honorable
4
skim the collection and give a "ballpark estimate within a half hour" and further the require the
Plaintiff to immediately retain the services of appraisers to do an in-person travel and inspection
of the baseball card and coin collections when, if necessary, the collections can be inspected and
analyzed if Defendant would merely provide in inventory of the cards and coins and/or
photocopies of the collections. By way of further answer, Defendant's Counsel's letter was sent
approximately eight weeks after the Discovery was due and Defendant had not filed any
objections to the Request for Production of Documents within the 30 day time limit as allowed
under Pa.R.C.P. 4009.12.
1. No response necessary as this is not an averment of fact.
WHEREFORE, Plaintiff Kathleen Hollister-Pepperman, requests this Honorable Court
grant Plaintiff s Motion to Make Rule Absolute and award Plaintiff reasonable attorney fees
incurred by Plaintiff in pursuing the Motion to Compel and the Motion to Make Rule Absolute,
and all other relief deemed appropriate by this Honorable Court since Defendant has failed to
comply with the Rule to Show Cause propounded upon him on November 20, 2008 and has,
instead, maintained an intransigent, obstinate position in this matter.
Furthermore, in civil discovery cases, counsel fees incurred as a direct result of a
discovery violation may be imposed as a sanction. See, Sun Pipe Line Co. v. Tri-State
Telecommunications, Inc., 440 Pa.Super. 47, 655 A.2d 112 (1994). "A failure to produce
documents may be a basis to award attorney's fees where a party's failure to produce is the result
of intransigent obstinacy. Helm v. Community Financial, Inc., No. 07-2122 Civil, Cumberland
Co. Court of Common Pleas, quoting Markey v. Marino, 361 Pa.Super. 92, 521 A.2d 942 (1987).
6
COYNE & COYNE, P.C.
Lisa Marie Coyne, Esquire
Pa. Supreme Ct. No. 53788
3901 Market Street
Camp Hill, PA 17011-4227
{717) 737-0464
Attorney for Plaintiff'
KATHLEEN L. HOLLISTER-PEPPERMAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
vs. : N0.07-5375 CIVII, TERM
DONALD L. PEPPERMAN,
Defendant :ACTION IN DIVORCE
MOTION TO COMPEL DISCOVERY
TO THE HONORABLE JUDGES OF SAID COURT:
AND NOW COMES the Plaintiff, Kathleen Hollister-Peppennan, by and through her
attorney, Lisa Marie Coyne, Esquire, and moves this Honorable Court to grant his Motion to
Compel Discovery and, in support thereof, respectfully represents the following:
1. On September 4, 2008, the Plaintiff's Counsel served Plaintiff's Second Set of
Request for Production of Documents on Defendant's Counsel.
2. No objections or protective orders where sought by Defendant concerning the
discovery propounded upon Defendant.
3. On October 19, 2008, Plaintiffs Counsel sent a letter to Defendant's Counsel that
the response to the Discovery request was overdue and requested opposing counsel to immediately
provide the requested discovery. (Exhibit A).
4. On October l7 and 27, 2008, Plaintiff's Counsel called and left a message for
Defendant's Counsel requesting that he comply with the Discovery Request. Plaintiffs Counsel
has attempted to resolve the issue with no response received from Defendant's Counsel.
5. As of the date of this Motion, Defendant has not answered the discovery propounded
upon him and Plaintiff has not received any of the requested discovery materials as requested in
Plaintiff's discovery requests.
6. Without the required discovery materials, Plaintiff cannot adequately prepaze for
trial.
7. Plaintiff is financially disadvantaged in comparison to Defendant whose salary is
approximately $1050 net per month more than Plaintiff s.
8. Plaintiff through counsel has attempted to resolve the discovery dispute short of
filing this motion and the associated expenses caused to Plaintiff due to the Defendant's failure to
comply with the discovery requests and the various extensions provided to Defendant.
9. The undersigned counsel has attempted to confer with opposing counsel via
telephone and written correspondence; however, opposing counsel has been unresponsive and
therefore, in accordance with the local rules of this court, it is believed that that opposing counsel
opposes the relief sought in this motion.
10. No judge has previously been assigned to this case.
WHEREFORE, for all of the foregoing reasons, the Defendant respectfully requests that this
Honorable Court order the Defendant and Defendant's Counsel to (1) immediately provide the
discovery materials requested in Plainti:ff's discovery request and (2) to award Plaintiff reasonable
attorney fees incurred by Plaintiff in pursuing this Motion to Compel and which would not have
been incurred if Defendant had complied with the reasonable discovery requests, and (3) all other
relief deemed appropriate by this Honorable Court.
Respectfully submitted:
Dated: ~D OAT DS
COYNE & COYNE, P.C.
i
By:
sa arie Dyne, Esq ire
. Ct. No. 53788
3901 Market Street
Camp Hill, PA 17011-4227
(717) 737-0464
Attorney for Plaintiff
164THLEEN L. HOLLISTER-PEPPERMAN,
PLAINTIFF
V.
DONALD L. PEPPERMAN,
DEFENDANT
{N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
N0.07-5375 CIV{L
ORDER OF COURT
AND NOW, this 20"' day of November, 2008, upon consideration of the Motion to
Compel Discovery filed by the Plaintiff,
1T IS HEREBY ORDERED AND DIRECTED that:
1. A Rule is issued upon the Defendant to show cause why the relief requested should
not be granted;
2. The Defendant will file an answer on or before December 10, 2008;
3. If no answer to the Rule to Show cause is filed by the required date, the relief
requested by Plaintiff shall be granted upon the Court's receipt of a Motion requesting Rute be
made Absolute. If the Defendant files an answer to this Rule to Show Cause, the Court will
determine if further order or hearing is necessary.
4. The Prothonotary is directed to forward said Answer to this Court.
By the Court,
/Lisa Marie Coyne, Esquire
Attorney for Plaintiff
/Mark Bayley, Esquire
Defendant
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M. L. Ebert, Jr., J.
Mark F. Bayley, Esquire
John J. Mangan, III, Esquire
Julie M. Good, Paralegal
Bayley 8v Mangan
ATTORNEYS AT LAW
17 West South Street
Carlisle, Pa 17013
December 10, 2008
Lisa Marie Coyne, Esquire
Coyne & Coyne
3901 Market Street
Camp Hill, PA 17011-4227
Re: Donald Pepperman & Kathleen Pepperman
07 - 5375
Dear Lisa:
Telephone: (717) 241-2446
Fax: (717)241-2456
Enclosed please find Defendant's Response To Plaint ffs Motion To Compel Discovery
And Rule To Show Cause Issued November 20, 2008 filed on December 10, 2008.
Sincerely,
Mark F. Bayley, Esquire
MFB/jmg/
Enclosure
KATHLEEN L. HOLLISTER-PEPPERMAN, : IN THE COURT OF COMMON
Plaintiff :PLEAS, CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
NO. 07-5375 CIVIL
DONALD L. PEPPERMAN
DEFENDANT'S RESPONSE TO PLAINTIFF'S MOTION TO COMPEL
DISCOVERY AND RULE TO SHOW CAUSE ISSUED NOVEMBER 20, 2008
AND NOW, comes Donald Pepperman, by and through his attorney, Mark ~ o
u ~r;
Bayley, and in response to Plaintiffs Motion to Compel Discovery avers as folld~vs' ~ ~~
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1. Defendant forwarded his first set of discovery requests to Plainti~~'
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counsel on August 12, 2008. ~ ':~ ~ "'
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2. Plaintiff forwarded her second set of discovery requests (the first set had -c
long since been answered by Defendant) on September 4, 2008.
3. On October 2, 2008 Undersigned Counsel faxed a letter to Plaintiffs
Counsel inquiring into whether her client would be responding to Defendant's first set of
requests (prior to Defendant commencing work on Plaintiffs second set); the same day
Plaintiff forwarded responses.
4. It appears to Undersigned Counsel that the only outstanding debate
regarding Plaintiffs second set of requests relates to Defendant's childhood baseball card
collection; Plaintiffs Counsel has demanded that she be provided the baseball card
collection at her office.
5. Defendant acquired the baseball card collection well before the parties
were married and it is not marital property; Defendant estimates there are over 1000 cards
in the collection which is currently stored in a medium sized box.
.•
6. Defendant is no expert in the value of baseball cards; he believes the
collection is worth between $2,000. and $3,000; the collection likely has more
sentimental value to Defendant than cash value.
7. Defendant has no desire to leave his card collection in the hands of his
wife's attorney.
8. Despite the collection's apparent lack of relevance, Undersigned Counsel
offered, by letter dated November 11, 2008, to arrange a date to have Defendant make the
collection available for inspection by Plaintiffs Counsel at Undersigned Counsel's office.
9. By letter dated November 25, 2008, Plaintiffs Counsel alternatively
demanded that Defendant make a "list of all of the baseball cards, with the name on the
card, the year of the card, date acquired and present value."
10. Such a list would likely take Defendant days to create which would be a
waste of time seeing that the majority of the cards have nominal book values.
11. Undersigned Counsel believes that an experienced baseball card dealer
and/or collector could likely skim through the collection and give a ballpark estimate
within a half hour; Undersigned Counsel suggested this approach to Plaintiff s Counsel
by letter dated November 28, 2008 and has not received a response to date.
12. Undersigned Counsel's invitation for Plaintiffs Counsel, and/or her agent,
to inspect the collection at Undersigned Counsel's office and in the presence of Defendant
remains open.
Resp ly sub ,
F. Bayley, squire
17 West South Street
Carlisle, PA 17013
(717) 241-2446
Supreme Court I.D.#87663
KATHLEEN L.HOLLISTER-PEPPERMAN,: IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY,PENNSYLVANIA
V. : No. 07 - 5375 CIVIL TERM
DONALD L. PEPPERMAN,
Defendant
CIVIL ACTIOI~T - LAVJ
IN DIVORCE
VERIFICATION
Mark F. Bayley, Esquire, states that he is the attorney .for Deffendant in this action; that
he makes this affidavit as attorney because he has sufficient knowledge or information and
belief, based upon his investigation of the matters averred or denied in the foregoing document;
and that this statement is made subject to the penalties of 18 Pa. C.S. Pa. C.S. §4904, relating to
unsworn falsification to authorities.
Date
v ~v
Mark F. Bayley, squire
Attorney for Defendant
KATHLEEN L.HOLLISTER-PEPPERMAN,: IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY,PENNSYLVANIA
V. No. 07 - 5375 CIVIL TERM
DONALD L. PEPPERMAN, :CIVIL ACTION -LAW
Defendant : IN DIVORCE
CERTII+'ICATE OF SERVICE
I, Mark F. Bayley, Esquire, attorney for Defendant do hereby certify that I this day served
a copy of the foregoing document upon the following by depositing same in the United States
mail, po§tage prepaid, at Carlisle, Pennsylvania, addressed as follows:
Lisa Marie Coyne, Esquire
3901 Market St.
Camp Hill, PA 1701 ~-4227
J /~ )~~
Dated: ~. -- "// UU
Mark F. Bayley, Esquire
Attorney for Defendant
Henxy F. Coyne
Lisa Marie Covne
John u%. Carter
~a~T~ c~; ~~~f~'F
A PROFESSIONAL CGtZ~ORATION
ATTO12NEYS AT I,AW
3901 T~Iarket Street
Camp Hi11, Pennsylvania
17011-4227
November 25, 2008
Mark r. Bayley, Esquire
Bayley & Mangan
Mark F. Bayley, Esquire
17 West South Street
Carlisle, PA 17013
• Re:
Dear Mark:
717-737-0464
Fax: 717-737-~ 161
www. coyneandcoyne. com
Kollister-Pepperman v. Pepperr~zan
In an effort to resolve the Discovery issues, I am willing to compromise and meet you half way
concerning the baseball cards, coi.~i collection and stock certificate.
If you will provide the following to my office within one (1) week from the date of this letter, we
can resolve this matter:
a. List of all of the baseball cards, with the name on the card, the year of the card, date acquired
and present value.
b. List of all of the coins, the date on the coin, date acquired, and present value.
c. Copy of the Stock Certificate with the date it was acquired by Mr. Pepperman,
I am assuming that since Mr. Pepperman is a collector of coins and baseball cards, he lalows the
present value of each of the items in those collections.
Thank you for your assistance.
Very truly yours,
LMGjwc
Cc: Kathleen L. Pepperman
COYNE & CO~'NE, P.C.
}
Lisa l~Iane Coyne
i~
u
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. § 4904 relating to
unsworn falsification to authorities.
lZ/~ out
Date
~ ~
Kathleen L. Hollister-Pepperman
CERTIFICATE OF SERVICE
I, Lisa Marie Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of
the foregoing Motion to Make Rule Absolute was served this date upon the below-referenced
individuals at the below listed address by way of first class mail, postage pre-paid:
Donald L. Pepperman
c/o Mark F. Bayley, Esquire
17 West South Street
Carlisle, PA 17013
Dated: /G DEC O8~ .~
s Marie Coyne
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KATHLEEN L. HOLLISTER-PEPPERMAN,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
DONALD L. PEPPERMAN,
DEFENDANT
NO. 07-5375 CIVIL
ORDER OF COURT
AND NOW, this 17th day of December, 2008, upon consideration of the Motion to
Compel Discovery filed by the Plaintiff and the Response filed by the Defendant,
IT IS HEREBY ORDERED AND DIRECTED that a status conference shall be held on
Tuesday, January 13, 2009, at 8:30 a.m. in chambers on Courtroom No. 5 of the Cumberland
County Courthouse, Carlisle, Pennsylvania.
~ Lisa Marie Coyne, Esquire
Attorney for Plaintiff
~' Mark Bayley, Esquire
Defendant
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By the Court,
M. L. Ebert, Jr., J.
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KATHLEEN L.HOLLISTER-PEPPERMAN,: IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. No. 07 - 5375 CIVIL TERM
DONALD L. PEPPERMAN, :CIVIL ACTION -LAW
Defendant IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
Defendant moves this Court to appoint a master with respect to the following claims:
(X) Divorce
( )Annulment
(X) Alimony
(X) Alimony Pendente Lite
(X) Distribution of Property
(X) Support
(X) Counsel fees
(X) Costs and Expenses
and in support of the within motion states:
(1) Discovery is substantially complete as to the claim(s) for which the appointment of a
master is requested.
(2) The Plaintiff is represented by Lisa Coyne, Esquire
(3) The Statutory ground(s) for divorce is 3301(a).
(4) The action is contested with respect to the following claims: Plaintiff has never
responded to Defendant's previous offer of settlement (forwarded to Plaintiffs counsel on March
9, 2007) or made an offer of settlement (despite numerous requests by the undersigned to do so);
therefore, it is unknown to Defendant what claims will be contested by Plaintiff.
(5) The action does not involve complex issues of law or fact.
(6) The hearing is expected to take one day.
(7) Additional information, if any, relevant to the motion: Defendant wishes that Plaintiff
would make an attempt to negotiate a settlement so as to avoid additional unnecessary attorney
fees.
WHEREFORE, the Defendant respectfully requests the Divorce Master to be appointed
to resolve the above claims.
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Respectfully~bmitted,
Mark F. Bayley, Esqu' e
17 West South Str
Carlisle, PA 17013
(717)-241-2446
Supreme Court I.D.#87663
KATHLEEN L.HOLLISTER-PEPPERMAN,: IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY,PENNSYLVANIA
v No. 07 - 5375 CIVIL TERM
DONALD L. PEPPERMAN, :CIVIL ACTION -LAW
Defendant IN DIVORCE
VERIFICATION
Mark F. Bayley, Esquire, states that he is the attorney in relation to the within matter; that
he makes this affidavit as attorney because he has sufficient knowledge or information and
belief, based upon his investigation of the matters averred or denied in the foregoing document;
and that this statement is made subject to the penalties of 18 Pa. C.S. Pa.C.S. §4904, relating to
unsworn falsification to authorities.
Date: r1 ~ ~ .. ~~
V
F. Bayley, Esquir
. ~ .
KATHLEEN L.HOLLISTER-PEPPERMAN,: IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY,PENNSYLVANIA
~• No. 07 - 5375 CIVIL TERM
DONALD L. PEPPERMAN, :CIVIL ACTION -LAW
Defendant IN DIVORCE
CERTIFICATE OF SERVICE
I, Mark F. Bayley, Esquire, attorney for Defendant, do hereby certify that I this day
served a copy of the foregoing document upon the following by First Class U.S. Mail:
Lisa Marie Coyne, Esquire
3901 Market St.
Camp Hill, PA 17011-4227
Mark F. Bayley, Esquire
„~
2004 OCT r9 ~'tl 2~ 02
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KATHLEEN L.HOLLISTER-PEPPERMAN,: IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. No. 07 - 5375 CIVIL TERM
DONALD L. PEPPERMAN, :CIVIL ACTION -LAW
Defendant IN DIVORCE
PETITION FOR MODIFICATION OF AN EXISTING
ALIMONY PENDENTE LITE ORDER
AND NOW, comes the Defendant, Donald Pepperman, by and through his counsel, Mark
F. Bayley, and in support of the within petition avers as follows:
1. An award of alimony pendente lite was awarded in favor of Plaintiff by order
dated December 1, 2008.
2. Defendant's income has since substantially decreased.
3. A reduction to the current alimony pendente lite award is now appropriate.
WHEREFORE, Defendant respectfully requests that the court modify the existing order
for alimony pendente lite.
Respectfully submitted,
BAYLEY & D~NGAN
oa,~:10~ Z1~-09
Mark F. Bayley, Es~re
17 West South Street
Carlisle, PA 17013
(717) 241-2446
Supreme Court ID # 87663
KATHLEEN L.HOLLISTER-PEPPERMAN,: IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY,PENNSYLVANIA
v. No. 07 - 5375 CIVIL TERM
DONALD L. PEPPERMAN, :CIVIL ACTION -LAW
Defendant IN DIVORCE
VERIFICATION
Mark F. Bayley, Esquire, states that he is the attorney in relation to the within matter; that
he makes this affidavit as attorney because he has sufficient knowledge or information and
belief, based upon his investigation of the matters averred or denied in the foregoing document;
and that this statement is made subject to the penalties of 18 Pa. C.S. Pa.C.S. §4904, relating to
unsworn falsification to authorities.
Date: ~ /'~ ~ ~ ~ ~ ^ (~
F. Bayley, squire
KATHLEEN L.HOLLISTER-PEPPERMAN,: IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY,PENNSYLVANIA
v, No. 07 - 5375 CIVIL TERM
DONALD L. PEPPERMAN, :CIVIL ACTION -LAW
Defendant IN DIVORCE
CERTIFICATE OF SERVICE
I, Mark F. Bayley, Esquire, attorney for Defendant, do hereby certify that I this day
served a copy of the foregoing document upon the following by First Class U.S. Mail:
Lisa Marie Coyne, Esquire
3901 Market St.
Camp Hill, PA 17011-4227
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Mar F. Bayley, Esquire
~ Th3~ AR~~71~Q~41'~RY'
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OCi' 3 0 2009 ~
KATHLEEN L.HOLLISTER-PEPPERMAN,: IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
~. No. 07 - 5375 CIVIL TERM
DONALD L. PEPPERMAN, :CIVIL ACTION -LAW
Defendant IN DIVORCE
ORDER APPOINTING MASTER
AND NOW, this ~~`~` day 2009, Robert Flicker, Esquire,
is appointed as Master with respect to the following claims:
(X) Divorce
( )Annulment
(X) Alimony
(X) Alimony Pendente Lite
(X) Distribution of Property
(X) Support
(X) Counsel fees
(X) Costs and Expenses
BY E COU
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J.
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/k F. Bayley, Esquire
isa M. Coyne, Esquire
f.
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F11~G-t)i~r~CE
4F ~c P~?~*Nn!~~QTARY
2009 NDY -2 ~M 8~ ! ~
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KATHLEEN L. HOLLISTER-PEPPERMAN,: THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION -DIVORCE
NO. 07-5375 CIVIL TERM
DONALD L. PEPPERMAN, IN DIVORCE
Defendant
PACSES CASE NO: 831109451
ORDER OF COURT
AND NOW, this 2nd day of November, 2009, a petition has been filed against you, Kathleen L. Hollister-
Pepperman, to modify an existing Alimony Pendente Lrte Order. You are ordered to appear in person at the
Domestic Relations Section, 13 North Hanover Street, Carlisle, Pennsylvania, on December 2.2009 at 9:00 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:
(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
1910.1 1.
(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.
Copies mailed to: Petitioner
Respondent
Lisa M. Coyne, Esq.
Mark F. Bayley, Esq.
Date of Order: November 2, 2009
BY THE COURT,
M. L. Ebert, Jr., Judge
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
cc361
2009 NOY -2 PM 2~ t~ 9
CUP~~4:~ ~~ ~~~;~.~{~
~~r~~vs~~v~~~~
KATHLEEN L. HOLLISTER-PEPPERMAN,:
Plaintiff
VS.
DONALD L. PEPPERMAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -DIVORCE
NO. 07-5375 CIVIL TERM
IN DIVORCE
. PACSES Case No: 831109451
ORDER OF COURT
AND NOW, this 2nd day of December 2009, based upon the Court's determination that the
Petitioner's monthly net income/earning capacity is $ 1,967.64 and the Respondent's monthly net
income/earning capacity is $ 3,180.54, it is hereby ordered that the Respondent pay to the
Pennsylvania State Collection and Disbursement Unit Five Hundred Seventy-four and 00/100 Dollars
($574.00) per month payable biweekly as follows: $ 574.00 per month for Alimony Pendente Lite and
$ 0.00 per month on arrears. First payment due: in accordance with Respondent's pay schedule. The
effective date of the order is October 29, 2009.
Arrears set at $ 582.44 as of December 2, 2009.
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, at its discretion, make an appropriate Order,
including, but not limited to, commitment of the Respondent to prison for a period not to exceed six
months.
Said money to be turned over by the PA SCDU to: Kathleen L. Hollister-Pepperman.
Payments must be made by check or money order. All checks and money orders must be made
payable to PA SCDU and mailed to:
PA SCDU
P.O. Box 69110
Harrisburg, PA 17106-9110
Payments must include the Respondent's name with their PACSES Member Number or
Social. Security Number in order to be processed. Do not send cash by mail.
cc360
The monthly support obligation includes cash medical support in the amount of $250 annually
for unreimbursed medical expenses incurred for each child and/or spouse. Unreimbursed medical
expenses of the obligee or children that exceed $250 annually shall be allocated between the parties.
The party seeking allocation of unreimbursed medical expenses must provide documentation of
expenses to the other party no later than March 31 S` of the year following the calendar year in which
the final medical bill to be allocated was received. The unreimbursed medical expenses are to be paid
as follows: 62% by Respondent and 38% by Petitioner. [] Respondent [X] Petitioner [] Neither party
to provide medical insurance coverage.
Within thirty (30) days after the entry of this order, the [X] Petitioner [] Respondent 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: 1) 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.
Other conditions:
This Order includes an additional sum for annual out of pocket and unreimbursed medical
expenses for the Petitioner in the amount of $1908.00 minus $250.00 for a total of $1658.00 in
annual expenses.
The Petitioner is to maintain medical insurance coverage, as provided by her employment, for
the Respondent until the divorce is final.
This Order shall become final twenty (20) 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.
Mailed copies on: December 3, 2009
to: Petitioner
Respondent
Lisa M. Coyne, Esq.
Mark F. Bayley, Esq.
BY THE COURT,
M. L. Ebert, Jr., J.
DRO: R.J. Shadday
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 07-5375 CIVIL
State Commonwealth of Pennsylvania OOriginal Order/Notice
CO./City/Dlst. Of CUMBERLAND OAmended Order/Notice
Date of Order/Notice 12/02/09 OTerminate Order/Notice
Case Number (See Addendum for case summary) QOne-Time Lump Sum/Notice
RE: pEPPERMAN, DONALD L.
Employer/Withholder's Federal EIN Number Employee/Obligor's Name (Last, First, Mp
177-42-2391
Employee/Obligor's Social Security Number
DIGITAL INK INC 3521101860
PO BOX 426 Employee/Obligor's Case Identifier
DILLSBURG PA 17 019 - 04 2 6 (See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, Mp
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ o. oo per month in current child support
$ o. oo per month in past-due child support Arrears 12 weeks or greaten yes ®no
$ o.oo per month in current medical support
$ o.oo per month in past-due medical support
$ 574.00 per month in current spousal support
$ o . oo per month in past-due spousal support
$ o . oo per month for genetic test costs
$ o . oo per month in other (specify)
$ one-time lump sum payment
for a total of $ 574.00 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:
$ 132.46 Per weekly pay period. $ 2a7. oo per semimonthly pay period
(twice a month)
$ 264.92 per biweekly pay period (every two weeks) $ s74 . oo per monthly pay period.
REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10)
working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of
withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work
state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of
the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding,
the following information is needed (See #9 on page 2).
Pennsylvania law (23 PA C.S. § 4374(b)) requires remittance by an electronic payment method if an employer is
ordered to withhold income from more than one employee and employs 15 or more persons, or if an employer has
a history of two or more returned checks due to nonsufficient funds. Please call the Pennsylvania State Collections
and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. PA FIPS CODE
42 000 00
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER /D (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY UMB R 1N O DE TO BE PROCESSED.
DO NOT SEND CASH BY MALI.
BY THE COURT:
D}ZO: R.J. Shadday Form EN-028 Rev.5
Service Type M OMB No.: 0970-0154 Worker I D $ IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
~ If heck you are required to pr vide a opy of this form to your mployee. If yo r employee orks in a state that is
di~erent from the state that issued this or~er, a copy must be provideed to your emproyee even if tie 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%bligor.
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%bligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employeelobligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. 2517352020
THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : D THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: ~
EMPLOYEE'S/OBLIGOR'S NAME:PEPPERMAN, DONALD L.
EMPLOYEE'S CASE IDENTIFIER: 3521101860 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%bligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Antidiscrimination: You are subject to a fine determined under State law for discharging an employee%bligorfrnm employment,
refusing to employ, or taking disciplinary action against any employee%bligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (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: If you or your employee/obligor have any questions,
DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT
13 N HANOVER ST by telephone at X717) 240-6225 or
P.O. BOX 320 by FAX at (717) 240-6248 or
CARLISLE PA 17013
by Internet www.childsupport.state.pa.us
Page 2 of 2 Form EN-028 Rev.S
Service Type M OMBNo.:0970-0154 Worker ID $IATT
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: PEPPERMAN, DONALD L .
PACSES Case Number 831109451
Plaintiff Name
KATHLEEN L. HOLLISTER-PEPPERMAN
Docket Attachment Amount
07-5375 CIVIL$ 574.00
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ o.oo
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ o.oo
Child(ren)'s Name(s): DOB
Service Type M
Addendum
OMB No.: 0970-0154
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ o.oo
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ o.oo
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ o.oo
Child(ren)'s Name(s): DOB
Form EN-028 Rev.5
Worker I D $ IATT
~4~~ ~;',,.rju~
2G04 OTC -3 ~~~ 2~ ~; 8
ti t~ ~IS
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Defendant Name: DONALD L. PEPPERMAN iYt -- t-
Member ID Number: 3521101860
en
t
?,...
76.
Please note: All correspondence must include the Member ID Number.
ORDER OF ATTACHMENT OF UNEMPLOYMENT C0MPEN5A1I0 hi%aN L*IT 7--'-''
cZl.
Financial Break Down of Multiple Cases on Attachment
PACSES Docket
Plaintiff Name Case Number Number
KATHLEEN L. HOLLISTER-PEPPERMAN 831109451 07-5375 CIVIL
TOTAL ATTACHMENT AMOUNT:
Attachment Amount/Freauencv
574.00 MONTH
574.00
Now, by Order of this Court, the Department of Labor and Industry, Office of Unemployment
Compensation Benefits (OUCB), is hereby directed to attach the lesser of $ 132.10 per week, or 50%, of
the Unemployment Compensation benefits otherwise payable to the Defendant,
DONALD L. PEPPERMAN Social Security Number XXX-XX-2391, Member ID Number 3521101860.
OUCB is ordered to remit the amount attached to the Department of Public Welfare (DPW). DPW shall
forward the amount received from OUCB to the Domestic Relations Section of this Court for support
and/or support arrearages.
If the Defendant's Unemployment Compensation benefits are attached by another Court or
Courts for support and/or support arrearages, DPW may reduce the amount attached under this Order so
that the total amount attached does not exceed the maximum amount subject to garnishment pursuant to
15 U.S.C. § 1673 (b)(2) and 23 Pa. C.S.A. § 4348 (g).
This Order shall be effective upon receipt of the notice of the Order by the OUCB and shall
remain in effect until the Defendant's entitlement to Unemployment Compensation benefits, under the
Application for Benefits dated FEBRUARY 27, 2011 is exhausted, expired or deferred.
OUCB shall comply with this Order, unless it is amended or vacated by subsequent Order of this
Court. All questions, challenges or obligations to this Order shall be directed to the Domestic Relations
Section of this Court.
BY THE COURT
Date of Order: MAR 0 8 2011 T* -t `,U4
M. L. EBERT, JR., JUDGE
DRO: R.J. Shadday
Form EN-530
Service Type M Worker ID $IATT
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State: Commonwealth of Pennsylvania
Co./City/Dist. of: CUMBERLAND
Date of Order/Notice: 04/05/11
Case Number (See A en um for case summary)
Employer/Withholder's Federal EIN Number
DIGITAL INK INC
PO BOX 426
DILLSBURG PA 17019-0426
RE: PEPPERMAN, DONALD L.
D7- 53-7 5 0- 1v1
O Original Order/Notice
Q Amended Order/Notice
0 Terminate Order/Notice
0 One-Time Lump Sum/Notice
Employee/Obligor's Name (Last, First, MI)
177-42-2391
mp oyee igor s ocia ecunty um er
3521101860
mp oyee igor s ase enti ier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts
from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your
State.
$ 0.00 per month in current child support c rl
$ 0.00 per month in past-due child support Arrears 12 weeks or greater? ® s ?.}
$ 0.00 per month in current medical support x? ro ?-
$ 0.00 per month in past-due medical support
-?
$ 0.00 per month in current spousal support < rn o °
$ 0.00 per month in past-due spousal support
<o a
$ 0.00 per month for genetic test costs C) -;
$ 0.00 per month in other (specify) C-D t-,
$ one-time lump sum payment ?''. rv ?-d'
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 semimonthly pay period
$ 0.00 per biweekly (twice a month)
y pay period (every two weeks) $ 0.00 per monthly pay period.
REMITTANCE INFORMATION. You must begin withholding no later than the first pay period occurring ten (10)
working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of
withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work
state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of
the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding,
the following information is needed (See #9 on page 2).
Pennsylvania law (23 PA C.S. § 4374(b)) requires remittance by an electronic payment method if an
employer is ordered to withhold income from more than one employee and employs 15 or more persons, or
if an employer has a history of two or more returned checks due to nonsufficient funds. Please call the
Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at
1-877-676-9580 for instructions. PA FIPS CODE 42 000 00
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID
(shown above as the Employeel0bligor's Case Identirrer) OR SOCIAL SECURITY NUMBER IN ORDER TO BE
PROCESSED. DO NOT SEND CASH BY.MAIL.. .. a I
BY THE COURT:
c-rti, I
OMB No.: 0970-0154 Form EN-028
Service Type M Worker ID $IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
[] if checked you are required to provide a copy of this form to your employee. if your employee works in a state that is
different from the state that issued this order, a copy must be provided to your employee even if the box is not checked.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the
requesting agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment
to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to
each employee/obligor.
3.* Reporting the Paydate/Date of Withholding: You must report the paydate/date of withholding when sending the payment. The
paydate/date of withholding is the date on which amount was withheld from the employee's wages. You must comply with the law of
the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement
the withholding order and forward the support payments.
4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support
against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you
must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the
greatest extent possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for
you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. 2517352020
THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER: Q THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: Q
EMPLOYEE'S/OBLIGOR'S NAME: PEPPERMAN DONALD L.
EMPLOYEE'S CASE IDENTIFIER: 3521101860 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
LAST KNOWN PHONE NUMBER:
NEW EMPLOYER'S NAME/ADDRESS:
FINAL PAYMENT AMOUNT:
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
Service Type M
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717) 240-6248 or
by internet www.childsupp-ort.state.pa.us
OMB No.: 0970-0154
Page 2 of 2
Form EN-028
Worker ID $IATT
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: PEPPERMAN, DONALD L.
PACSES Case Number 831109451
Plaintiff Name
KATHLEEN L. HOLLISTER-PEPPERMAN
Docket Attachment Amount
07-5375 CIVIL $ 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
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
Service Type M OMB No.: 0970-0154 Worker ID $IATT
ORDERMOTICE TO WITHHOLD INCOME FOR SUPPORT d-7- .53-75 C I v 1 L
State: Comm onwealth of Pennsylvania Q. Original Order/Notice
Co./City/ ist. c f: CUMBERLAND Q Amended Order/Notice
Date of Order/ Notice: 04/21 /11 O Terminate Order/Notice
Case Number (See A en um r case summary) Q One-Time Lump Sum/Notice
RE: PEP PERMAN, DONALD L.
EmployerNVithhol er's Federal EIN Number Employee/Obligor's Name (Last, First, MI)
177-42-2391
NIPS01 4 AMERICA, INC. mpoyee igo s Social SecurI171Tu-m_Fe_r
1375 E IRVING PARK RD 3521101860
ITASC IL 60143-2300 Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
See A ddendum for dependent names and birth dates associated with cases on attachment.
ORDER INFO RMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBER LAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts
from the above -named employee's/obligor's income until further notice even if the Order/Notice is not issued by your
State.
$ 0.00 per month in current child support '? ^u
$ 0.00 per month in past-due child support Arrears 12 weeks or greater? (%M ZIT no-i
$ 0.00 per month in current medical support ^n
=No n_
r-
? -
$ 0.00 per month in past-due medical support ,,
$ 5 74.00 per month in current spousal support
$ 0.00 per month in past-due spousal support
$ 0.00 per month for genetic test costs r)
$ 0.00 per month in other (specify) cl cz CD
$ one-time lump sum payment
_
for a total of $ 574.00 per month to be forwarded to payee below.
You do not hav e to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered su pport payment cycle, use the following to determine how much to withhold:
$ 3 per weekly pay period. $ 287.00 per semimonthly pay period
(twice a month)
$ 4 - 93 per biweekly pay period (every two weeks) $ 574.00 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. Y Du are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work
state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of
the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding,
the following information is needed (See #9 on page 2).
Pennsylvania law (23 PA C.S. § 4374(b)) requires remittance by an electronic Mment method if an
employer is ordered to withhold income from more than one employee and employs 15 or more persons, or
if an employe has a history of two or more returned checks due to nonsufficient funds. Please call the
Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at
1-877-676-9510 for instructions. PA FIPS CODE 42 000 00
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER /D
(shown above as the Employee/Obligor's Case Identiber) OR SOCIAL SECURITY NUMBER IN ORDER TO BE
PROCESSED. DO NOT SEND CASH BY rL. -t UV I TA BY THE COURT: i
AA. L. E b er + .J_t 1
OMB No.: 0970-0154 Form EN-028
Service Type M Worker ID $IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
If chocked 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 emDlovee/ob iaor.
3.* Reporting the aydate/Date of Withholding: You must report the paydate/date of withholding when sending the payment. The
paydate/date of wi hholding is the date on which amount was withheld from the employee's wages. You must comply with the law of
the state of the a ployee's/obligor's principal place of employment with respect to the time periods within which you must implement
the withholding or er and forward the support payments.
4.* Employee/Obi gor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support
against this emplo ee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you
must follow the la of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the
greatest extent po sible. (See #9 below)
5. Termination N tification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for
you. Please provid the information requested and return a copy of this Order/Notice to the Agency identified below. 5509100297
THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER: O THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: O
NAME: PEPPERMAN, DONALD L.
LAST KNOA
LAST KNOV%
NEW EMPLC
CASE IDENTIFIER: 3521101860 DATE OF SEPARATION:
HOME ADDRESS:
PHONE NUMBER:
NAME/ADDRESS:
FINAL PAYMENT AMOUNT:
6. Lump Sum Pa ments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If ou have any questions about lump sum payments, contact the person or authority below.
7. Liability: If yo fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should
have withheld fro the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law
governs unless thobligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8.
employment, refus
Pennsylvania Stag
is employed gover
9.* Withholding L
Protection Act (CC
of employment. DI
Social Security tax
obligor is supportir
50% limit is increa
you may deduct a
Arrears greater 0
employer should c
allowed under the
of the limit set by tl
the CCPA (15 U.S.
health care premiu
10. Additional info
tion: You are subject to a fine determined under State law for discharging an employee/obligor from
ig to employ, or taking disciplinary action against any employee/obligor because of a support withholding.
law governs unless the obligor is employed in another State, in which case the law of the State in which he or she
nits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
A) (15 U.S.C. 1673 (b)); or 2) the amounts allowed by the State or Tribe of the employee's/obligor's principal place
posable income is the net income left after making mandatory deductions such as: State, Federal, local taxes,
s, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the
another family and 60% of the disposable income if the obligor is not supporting another family. However, that
ad to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State,
e for administrative costs. The support amount and the fee may not exceed the limit indicated in this section.
n 12 weeks: If the Order Information does not indicate whether the arrears are greater than 12 weeks, then the
culate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts
w of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser
law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of
:. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amounts paid for
is in determining disposable income and applying appropriate withholding limits.
*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
Service -type M
If you or your employee/obligor have any questions,
contact _ WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717) 240-6248 or
by internet www.childsupport.state.pa.us
OMB No.: 0970-0154
Page 2 of 2
Form EN-028
Worker ID $IATT
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: PEPPERMAN, DONALD L.
PACSES Case Number 831109451
Plaintiff Name
KATHLEEN L. H LLISTER-PEPPERMAN
Docket Attachment Amount
07-5375 CIVIL 574.00
Child(ren)'s Nam (s): DOB
Plaintiff Name
Docket
Child(ren)'s Nam (s): DOB
Plaintiff Name
Docket
Child(ren)'s Nam (s): 0.00
DOB
PACSES Case Number
Plaintiff Name
PACSES Case Number
Plaintiff Name
PACSES Case Number
Plaintiff Name
Addendum Form EN-028
Service type M OMB No.: 0970-0154 Worker ID $IATT
2
KATHLEEN L. HOLLISTER-PEPPERMAN,
Plaintiff
VS.
DONALD L. PEPPERMAN,
Defendant
IN THE COURT OF COMMON
: PLEAS OF CUMBERLAND COUNTY,
:PENNSYLVANIA
: NO. 07-5375 CIVIL TERM
: ACTION IN DIVORCE
QUALIFIED DOMESTIC RELATIONS ORDER
(DEFINED CONTRIBUTION PLAN)
This order creates and recognizes the existence of an alternate payee's right to receive a portion
of the participant's benefits payable under an employer-sponsored defined contribution plan,
which is qualified under Section 401 of the Internal Revenue Code (the "Code"). This order is
intended to constitute a Qualified Domestic Relations Order ("QDRO") under Section 414(p) of
the Code and Section 206(d) of the Employee Retirement Income Security Act of 1974
("BRISA") and shall be interpreted and administered in conformity with such laws.
This order is entered pursuant to the authority granted under the applicable domestic relations
laws of the state of Pennsylvania.
1. PLAN
This order applies to the Xerox Corporation Savings Plan (401K Savings Plan for
Salaried Employees) and the Xerox Corporation Employee Stock Ownership Plan.
Any successor to this plan shall also be subject to the terms of the order.
2. PARTICIPANT
Name: Donald L. Pepperman
Address: 16 Ardmore Circle
New Cumberland, PA 17070
Social Security No. See Addendum
Date of Birth: See Addendum
3. ALTERNATE PAYEE
The person named as alternate payee meets the requirements of the definition of alternate payee
as set forth in Section 4 of this order. The alternate payee's name, address, Social Security
number, date of birth, and relationship to the participant are as follows:
Name:
Address:
Social Security No:
Date of Birth:
Relationship to Participant:
Kathleen L. Hollister-Pepperman
6263 Standford Court
Mechanicsburg, PA 17050
See Addendum
See Addendum
Spouse
The alternate payee shall be responsible for notifying the Plan Administrator in writing of any
changes in his or her mailing address subsequent to the submission of this order.
4. DEFINITIONS
a. Alternate Payee: The alternate payee is any spouse, former spouse, child, or
other dependent of a participant who is recognized by a domestic relations order
as having a right to receive all or a portion of the benefits payable under the Plan
with respect to the participant.
b. Liquidation Date: The liquidation date is the date the amount assigned to the
alternate payee is transferred from the participant's Vested Account Balance to a
separate account established for the alternate payee in accordance with the terms
of the QDRO. An assignment as of the liquidation date assigns a portion of the
participant's current Vested Account Balance.
Plan Administrator: Xerox Corporation ("Xerox") is the Plan Administrator for
Xerox's employee benefit plans. Xerox has contracted with Hewitt Associates
LLC to process domestic relations orders in accordance with Xerox QDRO
requirements. Hewitt's Qualified Order Team will conduct the qualification
process.
2
d. Valuation Date: The Valuation Date is the date on which the participant's
Vested Account Balance will be valued in order to determine the alternate payee's
designated portion in accordance with the terms of this order. Accounts are valued
on a daily basis.
e. Vested Account Balance: The participant's Vested Account Balance is the
dollar amount the participant has a nonforfeitable right to receive from the Plan.
5. BENEFIT PAYABLE TO THE ALTERNATE PAYEE
Option A. Straight Percentage
The order assigns to the alternate payee an amount equal to 50 % of the participant's
Vested Account Balance under the Plan (identified in Section 1) as of the date of
liquidation.
From the Valuation Date to the liquidation date, the amount assigned to the alternate
payee (select one):
X Will include earnings and losses.
Will not include earnings and losses.
The participant's Vested Account Balance (select one):
Will be reduced by the value of outstanding loans before the alternate
payee's portion of the benefit is determined.
X Will not be reduced by the value of outstanding loans before the alternate
payee's portion of the benefit is determined.
6. FORM OF PAYMENT
The alternate payee shall receive the portion of the plan benefits assigned to the alternate payee
in a single lump-sum payment. Such amount shall be adjusted for earnings and losses from the
liquidation date to the date of distribution to the alternate payee.
7. COMMENCEMENT
The alternate payee shall be eligible to receive payment as soon as administratively reasonable
following the determination that this order is a Qualified Domestic Relations Order. In no event
can the alternate payee begin his or her benefit later than April I following the year in which the
participant attains age 70-12.
8. DEATH PROCEDURES
If the participant predeceases the alternate payee prior to payment of the alternate payee's
assigned benefits under the QDRO, the alternate payee's benefits will not be affected. In the
event of the participant's death, the account balance, which remains the property of the
participant, will be payable to the participant's designated beneficiary or in accordance with Plan
provisions. This order does not require the participant to name the alternate payee as the
beneficiary for the benefits not assigned to the alternate payee.
In case of the death of the alternate payee prior to distribution of the alternate payee's benefits
under the QDRO, the assigned benefits will be paid to the alternate payee's designated
beneficiary or, if none, in accordance with Plan provisions.
9. RETENTION OF JURISDICTION
This matter arises from an action for divorce or legal separation in this court under the case
number set forth at the beginning of this order. Accordingly, this court has jurisdiction to issue
this order.
In the event the Plan Administrator determines that this order is not a Qualified Domestic
Relations Order, both parties shall cooperate with the Plan Administrator in making any changes
needed for it to become qualified. This includes signing all necessary documents. For this
purpose, this court expressly reserves jurisdiction over the dissolution proceeding involving the
participant, the alternate payee, and the participant's interest in the Plan.
4
10. LIMITATIONS
Pursuant to Section 414(p)(3) of the Code and except as provided by Section 414(p)(4), this
order:
(i) Does not require the Plan to provide any type or form of benefit, or any option,
not otherwise provided under the Plan;
(ii) Does not require the Plan to provide increased benefits; and
(iii) Does not require the payment of benefits to an alternate payee that is required to
be paid to another alternate payee under another order previously determined to
be a Qualified Domestic Relations Order.
11. TAXATION
For purposes of Sections 402 and 72 of the Code, any alternate payee who is the spouse or
former spouse of the participant shall be treated as the distributee of any distributions or
payments made to the alternate payee under the terms of the order and, as such, will be required
to pay the appropriate federal, state, and local income taxes on such distributions.
12. CONSTRUCTIVE RECEIPT
If the Plan inadvertently pays to the participant any benefit that is assigned to the alternate payee
pursuant to the terms of this order, the participant will immediately reimburse the Plan to the
extent the participant has received such benefit payments and shall forthwith pay such amounts
so received to the Plan within ten (10) days of receipt.
If the Plan inadvertently pays to the alternate payee any benefit that is actually payable to the
participant, the alternate payee must make immediate reimbursement. The alternate payee must
reimburse the Plan to the extent he or she has received such benefit payments and shall forthwith
pay such amount so received to the Plan within ten (10) days of receipt.
13. EFFECT OF PLAN TERMINATION
If the Plan is terminated, the alternate payee shall be entitled to receive his or her portion of the
participant's benefits as stipulated herein in accordance with the Plan's termination provisions
for participants and beneficiaries.
14. CERTIFICATION OF NECESSARY INFORMATION
All payments made pursuant to this order shall be conditioned on the certification by the
alternate payee and the participant to the Plan Administrator of such information as the Plan
Administrator may reasonably require from such parties to make the necessary calculation of the
benefit amounts contained herein.
BY THE COURT:
CONSENTED TO:
J. C130 It
Kathleen L. ollister-Pepperman, Plaintiff Donald L. Pepperman, Defendant
4 isa arie Coyne, Esquir
ark F. Bayley, Es ire
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KATHLEEN L. HOLLISTER-PEPPERMAN : IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
VS.
DONALD L. PEPPERMAN, :
Defendant/Respondent:
CIVIL ACTION - DIVORCE
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NO. 07-5375 CIVIL TERM
IN DIVORCE
PACSES Case No: 831109451
ORDER OF COURT
AND NOW to wit, this 6th day of July, 2011, it is hereby Ordered that
the Order for Alimony Pendente Lite is terminated, effective April 1, 2011, pursuant
to the parties' Marital Settlement Agreement of June 27, 2011.
The Alimony Pendente Lite account is closed with a credit of -$604.71.
This Order shall become final twenty (20) days after the mailing of the notices of
the entry of the Order to the parties unless either party files a written demand with the
Office of the Prothonotary for a hearing de novo before the Court.
BY THE COURT:
1k I U-4A, ? --
M. L. Ebert, Jr., J.
DRO: R.J. Shadday
xc: Petitioner
Respondent
Lisa M. Coyne, Esq.
Mark F. Bayley, Esq.
Form OE-001
Service Type: M Worker: 21005
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Phone: (717) 240-6225 Fax: (717) 240-6248
Defendant Name: DONALD L. PEPPERMAN
Member ID Number: 3521101860 c
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Please note: All correspondence must include the Member ID Number. cav
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) VACATE ATTACHMENT OF UNEMPLOYMENT BE T
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aC
Financial Break Down of Multiple Cases on Attachment
PACSES Docket
Plaintiff Name Case Number Number
KATHLEEN L. HOLLISTER-PEPPERMAN 831109451 07-5375 CIVIL
TOTAL ATTACHMENT AMOUNT
Attachment Amount/Frequency
574.00 MONTH
I
/
$ I
$ 574.00
The prior Order of this Court directing the Department of Labor and Industry, Office of
Unemployment Compensation Benefits (OUCB), to attach $132.09 or 50% per week of
the Unemployment Compensation benefits of DONALD L. PEPPERMAN, Social Security
Number XXX-XX-2391, Member ID Number 3521101860 is hereby vacated.
This Order to Vacate shall be effective upon receipt of the notice of the Order by the
Department and shall remain in effect until a further Order of the Court is filed.
BY THE COURT
Date of Order: JUL 0 7 2011
JUDGE
Form EN-035
Service Type M Worker ID $IATT
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT Y7- 5 3 5 C I v I I
State: Commonwealth of Pennsylvania
Co./City Dist. o : CUMBERLAND
Date of Order/Notice: 07/06/11
Case Number (See A e?for case summary)
O Original Order/Notice
Q Amended Order/Notice
(?) Terminate Order/Notice
O One-Time Lump Sum/Notice
RE: PEPPERMAN, DONALD L.
Employee/Obligor's Name (Last, First, MI)
177-42-2391
mp oyee Igor s Social ecun um er
3521101860
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
Employer/Withholder's Federal EIN Number
NIPSON AMERICA, INC.
1375 E IRVING PARK RD
ITASCA IL 60143-2300
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts
from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your
State.
$ 0.00 per month in current child support
$ 0.00 per month in past-due child support Arrears 12 weeks or greater? p yes p no
$ 0.00 per month in current medical support
$ 0.00 per month in past-due medical support
$ 0.00 per month in current spousal support n c
$ 0.00 per month in past-due spousal support
$ 0.00 per month for genetic test costs r nCD `i
$ 0.00 per month in other (specify) C= F-- ?r--
$ one-time lump sum payment t
r- v a ,
for a total of $ 0.00 per month to be forwarded to payee below. b _ -p --n
You do not have to vary your pay cycle to be in compliance with the support order. If your pay,3 to does nO tch
the ordered support payment cycle, use the following to determine how much to withhold: -4 ca % i
$ 0.00 per weekly pay period. $ 0.00 per semimonthly $ay-'`brioa'
(twice a month) `
$ 0.00 per biweekly pay period (every two weeks) $ 0.00 per monthly pay period.
REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10)
working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of
withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work
state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of
the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding,
the following information is needed (See #9 on page 2).
Pennsylvania law (23 PA C.S. § 4374(b)) requires remittance by an electronic payment method if an
employer is ordered to withhold income from more than one employee and employs 15 or more persons, or
if an employer has a history of two or more returned checks due to nonsufficient funds. Please call the
Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at
1-877-676-9580 for instructions. PA FIPS CODE 42 000 00
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER /D
(shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE
PROCESSED. DO NOT SEND CASH BY MAIL.
BY THE COURT:
OMB No.: 0970-0154 Form EN-028
Service Type M Worker ID $IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
If checked you are required to provide a copy of this form to your employee. If your employee works in a state that is
different from the state that issued this order, a copy must be provided to your employee even if the box is not checked.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the
requesting agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment
to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to
each employee/obligor.
3.* Reporting the Paydate/Date of Withholding: You must report the paydate/date of withholding when sending the payment. The
paydate/date of withholding is the date on which amount was withheld from the employee's wages. You must comply with the law of
the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement
the withholding order and forward the support payments.
4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support
against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you
must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the
greatest extent possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for
you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. 5509100297
THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER: O THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 0
EMPLOYEE'S/OBLIGOR'S NAME: PEPPERMAN DONALD L.
EMPLOYEE'S CASE IDENTIFIER: 3521101860 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 b.mployee/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
Service Type M
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717) 240-6248 or
by internet www.childsuonort.state.pa.us
OMB No.: 0970-0154
Page 2 of 2
Form EN-028
Worker ID $IATT
ADDENDUM
Summary of Cases on Attachment
Defendant/O bl Igor: PEPPERMAN, DONALD L.
PACSES Case Number 831109451 PACSES Case Number
Plaintiff Name Plaintiff Name
KATHLEEN L. HOLLISTER-PEPPERMAN
Docket Attachment Amount Docket Attachment Amount
07-5375 CIVIL $ 0.00 $ 0.00
Child(ren)'s Name(s): DOB 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
Addendum Form EN-028
Service Type M OMB No.: 0970-0154 Worker ID $IATT
KATHLEEN L. HOLLISTER-PEPPERMAN,: THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 07 - 5375 CIVIL
DONALD L. PEPPERMAN,
Defendant IN DIVORCE
ORDER OF COURT
AND NOW, this day of ,
2011, the economic claims raised in the proceedings having been
resolved in accordance with a marital separation agreement
dated June 22, 2011, the appointment of the Master is vacated
and counsel can file a praecipe transmitting the record to the
Court requesting a final decree in divorce.
BY THE COURT,
Kev' A. Hess, P.J.
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cc: Lisa M. Coyne -033
Attorney for Plaintiff Ma((eJ MM
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Attorney for Defendant / OV6 ?= x•
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FILED-OFFICV WR`l
2011 JUL 26 PM 12: 5 ?+
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CUMBERLAND COUNT",
PENNSYLVANIA
KATHLEEN L. HOLLISTER-PEPPERMAN,
Plaintiff
VS.
DONALD L. PEPPERMAN,
Defendant
: IN THE COURT OF COMMON
: PLEAS OF CUMBERLAND COUNTY,
: PENNSYLVANIA
: NO. 07-5375 CIVIL TERM
: ACTION IN DIVORCE
MARITAL SEPARATION AGREEMENT
THIS AGREEMENT, entered into on the specified date below, by and between Donald
L. Pepperman, (hereinafter referred to as "HUSBAND") and Kathleen L. Hollister-
Pepperman, (hereinafter referred to as "WIFE").
WITNESSETH: WHEREAS, HUSBAND and WIFE were lawfully married on October
17,1988; and
WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between
the parties and it is the intention of HUSBAND and WIFE to live separate and apart for the rest
of their natural lives, and the parties hereto are desirous of settling fully and finally their
respective financial and property rights and obligations as between each other, including, without
limitation by specification; the settling of all matters between them relating to the ownership and
equitable distribution of real and personal property; the settling of all claims and possible claims
by one against the other or against their respective estates and equitable distribution of property
and alimony for each party.
NOW, THEREFORE, in consideration of the promises and the mutual promises,
covenants and undertakings hereinafter set forth and for other good and valuable consideration,
receipt of which is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE,
each intending to be legally bound, hereby covenant and agree as follows:
1. The parties intend to maintain separate and permanent domiciles and to live apart
from each other. It is the intention and purpose of this agreement to set forth the respective
rights and duties of the parties while they continue to live apart from each other.
ft
2. The parties have attempted to divide their matrimonial property in a manner that
conforms to a just and right standard, with due regard to the rights of each party. It is the
intention of the parties that such division shall be final and shall forever determine their
respective rights. The division of existing marital property is not intended by the parties to
constitute in any way a sale or exchange of assets.
3. Further, the parties agree to continue living separately and apart from each other
at any place or places that he or she may select. Neither party shall molest, harass, annoy, injure,
threaten or interfere with the other party in any manner whatsoever. Each party may carry on
and engage in any employment, profession, business or other activity, as he or she may deem
advisable for his or her sole use and benefit. Neither party shall interfere with the uses,
ownership, enjoyment or disposition of any property now owned and not specified herein or
property hereafter acquired by the other.
4. The consideration for this contract and agreement is the mutual benefits to be
obtained by both of the parties hereto and the covenants and agreements of each of the parties to
the other. The adequacy of the consideration for all agreements herein contained is stipulated,
confessed, and admitted by the parties, and the parties intend to be legally bound hereby.
5. WIFE is represented by Lisa Marie Coyne, Esquire; HUSBAND is represented by
Mark F. Bayley, Esquire. Each party to this agreement acknowledges and declares that he or she,
respectively:
A. Enters into this agreement voluntarily after receiving the advice of
counsel; or has voluntarily decided not to receive advice from counsel
acknowledging that adequate time and opportunity has been provided to
do so;
B. Is fully and completely informed of the facts relating to the subject matter
of this agreement and of the rights and obligations of the parties;
C. Has given careful and serious thought to the making of this agreement;
D. Has carefully read each provision of this agreement;
E. Fully and completely understands each provision of this agreement, both
as to the subject matter and legal effect; and
F. Agrees this Agreement is, under the circumstances, fair, reasonable and
equitable, that it is being entered into freely, voluntarily, and in good faith
and that the execution of this Agreement is not the result of any duress,
undue influence, coercion, collusion and/or improper or illegal agreement.
2
6. Each party represents and warrants that he or she has made a full and fair
disclosure to the other of all of his or her property interests, including any mortgage, pledge, lien,
charge, security interest, encumbrance, or restriction to which any property is subject. Each
party further represents that he or she has made a full and fair disclosure of all debts and
obligations of any nature for which he or she is currently liable or may become liable. Each
further represents and warrants that he or she has not made any gifts or transfers of Marital
Property for inadequate consideration without the prior consent of the other. Each party
acknowledges that, to the extent desired, he or she has had access to all of the above information
from the other party. Each party acknowledges that, to the extent desired, he or she has had
access to all joint and separate state and federal tax returns filed by or on behalf of both parties
during the marriage.
7. DEBTS AND LIABILITIES: It is further mutually agreed by and between the
parties that:
a. HUSBAND will be responsible for all debts, liabilities, contracts and
payments currently contracted, deeded or titled under his name or relating to items owned
pursuant to the terms ofthe within agreement, not otherwise mentioned by the within agreement
and shall indemnify, defend and save WIFE harmless from any and all claims or demands made
against him by reason of debts or obligations incurred by him.
b. WIFE will be responsible for all debts, liabilities, contracts and payments
currently contracted, deeded or titled under her name or relating to items owned pursuant to the
terms of the within agreement, not otherwise mentioned by the within agreement and shall
indemnify, defend and save HUSBAND harmless from any and all claims or demands made
against her by reason of debts or obligations incurred by her.
8. CASH ASSETS: The parties have previously distributed cash assets not
otherwise mentioned herein to their mutual satisfaction.
9. PERSONAL PROPERTY, VEHICLES, ETC.:
a. HUSBAND is entitled to full ownership of the Dodge Durango. WIFE
agrees upon entry of a final Divorce Decree to sign any and all necessary documents to complete
a title transfer into HUSBAND's name upon HUSBAND's request.
b. Personal property not otherwise mentioned by the within agreement will
belong to the respective party possessing the personal property at the time of execution of the
within agreement.
10. SUPPORT AND ALIMONY: Both parties hereby waive and forego all
financial and material spousal support from each other and agree not to request or seek to obtain
alimony or spousal support before or after any divorce which may be granted. WIFE agrees to
terminate the current alimony pendente lite order retroactively to April 1, 2011.
11. RETIREMENT ACCOUNTS/ PENSIONS:
a. HUSBAND and WIFE shall each assume ownership of half of the value of
HUSBAND's Xerox Corporation Savings Plan and Xerox Corporation Employee Stock
Ownership Plan valued at the date of distribution. Said asset shall be equally divided so that
Husband shall receive Fifty percent (50%) and Wife shall receive Fifty percent (50%) of the total
shares and cash balances, including earnings and losses, held in the accounts per a Qualified
Domestic Relations Order ("QDRO") which shall be prepared by WIFE's counsel. Further,
HUSBAND hereby stipulates that he has not made any transfers or direct withdrawals from the
Xerox Corporation Savings Plan and Xerox Corporation Employee Stock Ownership Plan nor
has he sold any stock from such plans or withdrawn any cash balances since the parties
separated. Husband further stipulates that any increase or decrease in the values of these
accounts since the date of separation, were due solely to the fluctuations of the market value of
the deposited shares and any accrued dividends issued to those accounts based upon the stock
share holdings in the accounts.
b. WIFE will maintain full ownership of her Pennsylvania State Employee
Retirement System ("SERS") benefits/plan and HUSBAND waives all claims to the same.
C. HUSBAND shall assume full ownership of the 24 shares of Xerox stock
that are not a part of the Xerox Corporation Savings Plan or Xerox Corporation Employee Stock
Ownership Plan, and shall assume full ownership of any other assets currently titled under his
name and not otherwise mentioned herein.
12. REAL ESTATE:
a. HUSBAND shall maintain full ownership of the residence in which he
currently resides.
b. WIFE shall maintain full ownership of the residence in which she
currently resides.
4
13. WAIVER OF CLAIMS AGAINST THE ESTATES: Except as otherwise
provided herein, each party may dispose of his or her property in any way, and each party hereby
waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the
present or future laws of any jurisdiction, to share in the property or the estate of the other as a
result of the marital relationship, including without limitation, dower, curtesy, statutory
allowance, widow's allowance, right to take in intestacy, right to take against the Will of the
other, and right to act as administrator or executor of the other's estate, and each will., at the
request of the other, execute, acknowledge and deliver any and all instruments which may be
necessary or advisable to carry into effect this mutual waiver and relinquishment of all such
interests, rights and claims. Additionally, each party waives and relinquishes any and all rights
to share in any estate inheritances or bequests the other may receive and/or be entitled to.
14. INCOME TAX RETURNS: All future income tax returns will be filed
separately and the parties will each retain any refund due to them unless otherwise agreed upon
in writing.
15. DIVORCE: HUSBAND and WIFE agree to voluntarily execute all necessary
documents to finalize a divorce. In the event, for whatever reason, either party fails or refuses to
execute such affidavit upon the other parry's timely request, that party shall indemnify, defend
and hold the other harmless from any and all additional expenses, including actual counsel fees,
resulting from any action brought to compel the refusing party to consent. Each party hereby
agrees that a legal or equitable action may be brought to compel him or her to execute a consent
form and that, absent some breach of this Agreement by the proceeding party, there shall be no
defense to such action asserted.
16. HEALTH INSURANCE: Effective upon the signing of this Agreement, the
parties shall provide their own health insurance. Neither party shall be responsible for any health
insurance, health costs or medical expenses incurred by the other and shall indemnify and hold
harmless the other from any past, present or future claim put forth in that regard.
17. BREACH: In the event of the breach of this agreement by either party, the
nonbreaching party shall have the right to seek monetary damages for such breach, where such
damages are ascertainable, and/or to seek specific performance of the terms of this agreement,
where such damages are not ascertainable. All costs, expenses and reasonable attorney fees
incurred by the successful party in any litigation to obtain monetary damages and/or specific
performance of this agreement shall be recoverable as part of the judgment entered by the court.
18. ADDITIONAL INSTSRUMENTS: Each of the parties shall from time to time,
at the request of the other, execute, acknowledge and deliver to the other party any and all further
instruments that may be reasonably required to give full force and effect to the provisions of this
agreement.
19. VOLUNTARY EXECUTION: The provisions of this agreement and their legal
effect are fully understood by both parties. HUSBAND's legal counsel is Mark F. Bayley,
Esquire. WIFE's legal counsel is Lisa Marie Coyne, Esquire.
20. 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.
21. APPLICABLE LAW: This agreement shall be construed under the laws of the
Commonwealth of Pennsylvania.
22. PRIOR AGREEMENTS: It is understood and agreed that any and all property
settlement agreements which may or have been executed or verbally discussed prior to the date
and time of this agreement are null and void and of no effect.
23. DATE OF EXECUTION: The "date of execution" or "execution date" of this
Agreement shall be defined as the date upon which it is executed by the parties if they have each
executed the Agreement on the same date. Otherwise, the "date of execution" or "execution
date" of this Agreement shall be defined as the date of execution by the party last executing this
Agreement.
24. MARITAL DEBT: Each party hereby confirms they have not incurred any
additional debt since their separation that has in any way obligated the other party. Neither
party will take any action to incur additional debt of any nature whatsoever in the other party's
name from the date of execution of this Agreement forward.
25. EQUITABLE DISTRIBUTION: It is specifically understood and agreed that
this Agreement constitutes an equitable distribution of property, both real and personal, which
was legally and beneficially acquired by Husband and Wife or either of them during the marriage
as contemplated by The Act of April 2, 1980 (P.L. No. 63, No. 26), known as "The Divorce
Code," 23 P.S. 101 et seq. of the Commonwealth of Pennsylvania, and as amended.
26. SUMMARY OF EFFECT OF AGREEMENT: It is specifically understood
and agreed by and between the parties hereto, and each party accepts the provisions herein made
in lieu of and in full settlement and satisfaction of any and all of the said parties' rights against
the other for any past, present and future claims on account of support, maintenance, alimony,
alimony pendente lite, counsel fees, costs and expenses, equitable distribution of marital property
and any other claims of each party, including all claims raised by them in the divorce action
pending between the parties.
27. RECONCILIATION: The parties shall only effectuate a legal reconciliation
which supersedes this Agreement by their signed agreement containing a specific statement that
they have reconciled and that this Agreement shall be null and void; otherwise, this Agreement
shall remain in full force and effect. Further, the parties may attempt a reconciliation, which
action, if not consummated by the aforesaid agreement, shall not affect in any way the legal
affect of this Agreement or cause any new marital rights or obligations to accrue.
28. SEVERABILITY: If any term, condition, clause or provision of this Agreement
shall be determined or declared to be void or invalid in law or otherwise, then only that term,
condition, clause or provision shall be stricken from this Agreement and in all other respects this
Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of
any party to meet her or his obligations under any one or more of the paragraphs herein, with
exception of the satisfaction of the conditions precedent, shall in no way void or alter the
remaining obligations of the parties.
29. NO WAIVER OF DEFAULT: This agreement shall remain in full force and
effect unless and until terminated under and pursuant to the terms of this Agreement. The failure
of either party to insist upon strict performance of any of the provisions of this Agreement shall
in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any
breach of any provision hereof be construed as a waiver of any subsequent default of the same or
similar nature, nor shall it be construed as a waiver of strict performance of any other obligations
herein.
30. EFFECT OF DIVORCE DECREE: The parties agree that unless otherwise
specifically provided herein, this Agreement shall continue in full force and effect after such
time as a final Decree in Divorce may be entered with respect to the parties.
31. INCORPORATION: It is the intention that the Agreement shall survive any
action for divorce which may be instituted or prosecuted by either party and no order, judgment
or decree of divorce, temporary, final or permanent, shall affect or modify the financial terms of
this Agreement. This Agreement shall be incorporated in, but shall not merge into, any such
judgment or decree of final divorce, but shall be incorporated for the purposes of enforcement
only.
7
32. WAIVER OR MODIFICATION TO BE IN WRITING: No modification or
waiver of any of the terms hereof shall be valid unless in writing and signed by both :parties and
no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent
default of the same or similar nature.
33. AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and
shall insure to the benefit of the parties hereto and their respective heirs, executor,
administrators, successors and assigns.
IN WITNESS WHEREOF, the parties have hereunto set their hands and seals on the
date indicated below.
Donald L. Pepperman
Date
' eD
athleen L. ollister-Pepperman Date
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
: SS
PERSONAL APPEARED BEFORE ME, a notary public for Cumberland County
Pennsylvania, this day of _, 20_jl , Donald L. Pepperman, known
to me (or satisfactorily proven) to be th person whose name is subscribed to the within
agreement, and acknowledge that he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and o f4icial seal.
tary Public
NOTARIAL SEAL
JANE ADAMS
Notary Public
CARLISLE BORO., CUMPERI AN^ ^OUNTV
F? 2
COMMONWEALTH OF PENNSYLVANIA My Commission Expires S ti 12
SS
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, a notary public for Cumberland County
Pennsylvania, this 2y day of , 20 it , Kathleen L. Hollister-
Pepperman, known to me (or satisfac rily proven) to be the person whose name is subscribed
to the within agreement, and acknowledge that she executed the same for the purposes therein
contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
of ry Publ c
COMMONWEALTH OF PENNSYLVANIA
NOTAR4AL SEAL
Lisa Marie Coyne, Notary Public
Hampden Township, Cumberland County
M.y Commission Expires June 10, 2012
COYNE & COYNE, P.C. =' THE PRO,! nr
tl oTAIR111
Lisa Marie Coyne, Esquire ZO I i JUL 26 PM 12: 51i
Pa. Supreme Ct. No. 53788
3901 Market Street CUMBERLAND COUN T ?,
Camp Hill, PA 17011-4227 PENNSYLVANIA
(717) 737-0464 Attorney For Plaintiff
KATHLEEN L. HOLLISTER-PEPPERMAN, : IN THE COURT OF COMMON
Plaintiff : PLEAS OF CUMBERLAND COUNTY,
:PENNSYLVANIA
VS.
DONALD L. PEPPERMAN,
Defendant
: NO. 07-5375 CIVIL TERM
ACTION IN DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE
DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on
September 10, 2007.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce without formal notice of
intention to request entry of the decree.
4. 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. § 4904 relating to unsworn
falsification to authorities.
Date:
KATHLEEN
L. HOLLISTER-PEPPERMAN,
Plaintiff
JUL o 20"l
KATHLEEN L. HOLLISTER-PEPPERMAN,
Plaintiff
V.
DONALD L. PEPPERMAN,
Defendant
ILLU-t FFIGir-.
NE RR0T?l
'M A 11 :W THE COURT F` OMMON
.'?nAND COUNTY,
PE lm
:NO. 07-5375 CIVIL TERM
: ACTION IN DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE
DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE
A complaint in Divorce under §3301(c) of the Divorce Code was filed on September 10,
2007
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 the final Decree in Divorce without formal Notice of Intention to
request entry of the decree.
4. 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 THE FOREGOING AFFIDAVIT
ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN
ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO
UNSWORN FALSIFICATION TO AUTHORITIES.
C Donald L. Pepperman
Defendant
BAYLEY & MANGAN
Mark F. Bayley, Esquire
Attorney I.D. #: 87663
17 West South Street
Carlisle, PA 17013
(717) 241-2446
KATHLEEN L. HOLLISTER-PEPPERMAN,
Plaintiff
V.
DONALD L. PEPPERMAN,
Defendant
_ FILED-OF iCC
0 Ti?
HE PROTHON
2011 JUL 26 Ply 12: 56
CUMBERLAND COUNTY
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL ACTION - LAW
NO. 07-5375
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the Court for entry of a divorce
decree:
1. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code.
2. Date and manner of service of the Complaint: Certified First Class Mail, restricted
delivery; receipt card was signed by Defendant on September 15, 2007 and made part of
the record on September 19, 2007.
3. Date of execution of the affidavit of consent required by § 3301(c) of The Divorce
Code: by the Plaintiff, June 22, 2011 (attached); by the Defendant July 2, 2011
(attached).
4. Related claims pending: None
5. Date Plaintiff s Waiver of Notice of Intention to Request Entry of Divorce under
§3301(c) of the Divorce Code (attached) was filed with the Prothonotary:
contemporaneously with this filing.
Date Defendant's Waiver of Notice of Intention of Request Entry of Divorce under
§3301(c) of the Divorce Code (attached) was filed with the Prothonotary:
contemporaneously with this filing.
Date: .,
Mark F. Bayley, Esqui
BAYLEY & MANGAN
17 W. South St.
Carlisle, PA 17013
717) 241-2446
Supreme Court I.D. # 87663
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
KATHLEEN L. HOLLISTER-PEPPERMAN
V.
DONALD L. PEPPERMAN NO. 07-5375 CIVIL TERM
DIVORCE DECREE
AND NOW, A 4 S? 2 Ibll , it is ordered and decreed that
KATHLEEN L. HOLLISTER-PEPPERMAN plaintiff, and
DONALD L. PEPPERMAN
defendant, are divorced from the
bonds of matrimony.
Any existing spousal support order shall hereafter be deemed an order for
alimony pendente lite if any economic claims remain pending.
The court retains jurisdiction of any claims raised by the parties to this action
for which a final order has not yet been entered. Those claims are as follows: (If no
claims remain indicate "None.")
NONE. The Marriage Settlement Agreement recorded of record with is Court in
this matter is incorporated, but not merged into this Decree in Divorce.
By the Court,
Attest: J.
SOL
41b D • vb?.??Pr honotary
g •? ll- C??- ??? Mai%ed A"JI 6d ?e
et,j
F co/l 'wo"Ye of ggy/J
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Gt I-e? vt ?._ 1Sir-42e0,ermc w
Plaintiff
vs.
0-7-53-75
FILE NO. 20_
IN DIVORCE
Defendant
?r
..-a c
NOTICE TO RESUME PRIOR SURNAME :)
rr
Notice is hereby given that the Plaintiff/Defendant in the above matter, h9m N
a
been granted a Final Decree in Divorce on the day of A ugo A a o i I co
hereby elects to resume the prior surname of ?c? {-?l ee rn ?- u l S }`er" ,
and gives this written notice pursuant to the provisions of 54 P.S. 704.
DATE: d q O ( ke'4j?-? ^ °1
Signature
f
Signature of name being resumed
COMMONWEALTH OF PENNSYLVANIA
SS.
COUNTY OF CUMBERLAND
On the 6 q day of &4&m? , 20-L-I--, before me, a
Notary Public, personally appeared the above affiant known to me to be the person whose name
is subscribed to the within document and acknowledged that he/she executed the foregoing for the
purpose therein contained.
In Witness Whereof, I have hereunto set my hand and official s
NotaryPublic
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201
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