HomeMy WebLinkAbout07-5732GEORGE E. SHERIFF : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 07- S73-2\ CIVIL TERM
SHIRLEY M. SHERIFF : CIVIL ACTION - LAW
Defendant : IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in Court. If you wish to defend against the claims set forth
in the following pages, you must take prompt action. You are warned that if you fail to
do so, the case will proceed without you and a decree in divorce or annulment may be
entered against you for any other claim or relief requested in these papers by the
Plaintiff. You may lose money or property or other rights important to you, including
custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is
available in the Office of the Prothonotary at the First Floor, Cumberland County
Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL
PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
GEORGE E. SHERIFF : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 07- S"'r.M,_ CIVIL TERM
SHIRLEY M. SHERIFF : CIVIL ACTION - LAW
Defendant : IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is George E. Sheriff, an adult individual, currently residing 95
Spring Garden Estates, Carlisle, Cumberland County, Pennsylvania, 17013.
2. Defendant is Shirley M. Sheriff, an adult individual, currently residing at 75
Spring Garden Estates, Carlisle, Cumberland County, Pennsylvania, 17013.
3. Plaintiff and Defendant are bonafide residents of the Commonwealth of
Pennsylvania and have been so for at least six months immediately previous to the filing
of this complaint.
4. The parties have been married to each other for approximately 7 years
and subsequently they were divorced. Otherwise, there have been no additional action
for divorce or annulment between the parties.
5. Plaintiff and Defendant were married for the second time on January 28,
1994 in Cumberland County, Pennsylvania
6. The Defendant is not a member of the Armed Forces of the United States
of America, or its Allies.
7. The Plaintiff has been advised of the availability of counseling and the
right to request that the Court require the parties to participate in counseling. Knowing
this, the Plaintiff does not desire that the Court require the parties to participate in
counseling.
8. Plaintiff and Defendant are citizens of the United States of America.
9. The parties have lived separate and apart since October 2006 and
continue to live separate and apart as of the date of this Complaint.
10. The parties' marriage is irretrievably broken.
11. Plaintiff desires a divorce based upon the belief that Defendant will, after
ninety days from the date of the filing of this Complaint, consent to the divorce.
WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in
divorce.
COUNT II
EQUITABLE DISTRIBUTION
12. Paragraphs 1 through 11 are incorporated herein by reference as if set
forth in their full text.
13. Plaintiff and Defendant have divided various items of personal property,
furniture and household furnishings acquired during their marriage.
14. Plaintiff and Defendant have incurred debts and obligations during their
marriage, which are subject to equitable distribution.
WHEREFORE, Plaintiff prays this Honorable Court, to enter a decree equitably
dividing the parties property and equitably apportioning the debts incurred by the
parties.
Respectfully Submitted
TURO LAW OFFICES
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Date
Galen R. Wes, E
28 South Fitt S
Carlisle, PA 17013
(717) 245-9688
Attorney for Plaintiff
VERIFICATION
I verify that the statements made in the foregoing Divorce Complaint are true and
correct. I understand that false statements herein made are subject to the penalties of
Pa.C.S. §4904 relating to unsworn falsification to authorities.
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Date
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George E. Sheriff
CERTIFICATE OF SERVICE
I, Galen R. Waltz, Esquire hereby certify that I served a true and correct copy of
the Complaint in Divorce, by first class, certified return receipt requested and depositing
same in the United States Mail, first class, postage pre-paid on the kt day of
3 , 2007, from Carlisle, Pennsylvania, addressed as follows:
_0Q -J t,? e-, Shirley M. Sheriff
75 Spring Garden Estates
Carlisle, PA 17013
TURO LAW OFFICES
G en R. Waltz, Esqui
28 South Pitt Street
Carlisle, PA 17013
(717) 245-9688
Attorney for Plaintiff
70
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Friedman & King, P.C.
Richard S. Friedman, Esq.
ID#07176
3820 Market Street
Camp Hill, PA 17011
(717) 236-8000
(717) 236-8080 FAX
friedmanandkingahotmail.com
GEORGE E. SHERIFF,
Plaintiff
V.
SHIRLEY M. SHERIFF,
Defendant.
Attorney for Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07-5732 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
ENTRY OF APPEARANCE
Kindly enter my appearance on behalf of the Defendant, Shirley M. Sheriff, in the
above-captioned matter.
Dated: November 2007
Respectfully submitted,
FRIEDMAN & G C.
By: -'
/,'Richard S. Friedman, Esq.
3820 Market Street
Camp Hill, PA 17011
(717) 236-8000
(717) 236-8080 FAX
friedmanandking&hotmail.com
TO: TURO LAW OFFICES
Attn: Galen R. Waltz, Esq.
28 S. Pitt Street
Carlisle, PA 17013
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Friedman & King, P.C.
Richard S. Friedman, Esq.
ID#07176
3820 Market Street
Camp Hill, PA 17011
(717) 236-8000
(717) 236-8080 FAX
friedmanandkinp-@,hotmail.com
GEORGE E. SHERIFF,
Plaintiff
V.
SHIRLEY M. SHERIFF,
Defendant.
Attorney for Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07-5732 CIVIL TERM
CIVIL ACTION - LAW
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.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
1-800-990-9108
717-249-3166
Respectfully submitted,
FRIEDMAN,&XING, P.C.
By:
Richatd S. Friedman, Esq.
3820 Market Street
Camp Hill, PA 17011
(717) 236-8000
(717) 236-8080 FAX
friedmanandking@,,hotmail.com
Friedman & King, P.C.
Richard S. Friedman, Esq.
ID#07176
3820 Market Street
Camp Hill, PA 17011
(717) 236-8000
(717) 236-8080 FAX
friedmanandking&hotmail.com
GEORGE E. SHERIFF,
Plaintiff
V.
SHIRLEY M. SHERIFF,
Defendant.
Attorney for Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07-5732 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
ANSWER WITH COUNTERCLAIM
The Defendant, Shirley M. Sheriff, by and through her attorneys, Friedman & King, P.C.,
for her Answer to the Complaint, states as follows:
1. Admitted.
2. Admitted.
3. Admitted.
4. Admitted.
5. Admitted.
6. Admitted.
7. Admitted.
8. Admitted.
9. Admitted.
10. Admitted.
11. Denied.
12. Admitted.
13. Admitted.
14. Admitted.
REQUEST FOR ALIMONY PENDENTE LITE
UNDER SECTION 3702 OF THE DIVORCE CODE
15. Defendant lacks sufficient property or income to provide for her reasonable needs
and legal expenses during the course of this litigation.
16. Defendant requests the Court to enter an award of alimony pendente lite, pursuant
to Section 3702 of the Divorce Code.
WHEREFORE, the Defendant respectfully requests the Court to enter an award of
alimony pendente lite until final hearing, pursuant to Section 3702 of the Divorce Code.
Dated: November, 2007
Respectfully submitted,
FRIEDMAN KING, P.C.
By:
A-cb4E0,9`Friedman, Esq.
3 820 Market Street
Camp Hill, PA 17011
(717) 236-8000
(717) 236-8080 FAX
friedmanandking_ghotmail.com
Attorney for Defendant
TO: TURO LAW OFFICES
Attn: Galen R. Waltz, Esq.
28 S. Pitt Street
Carlisle, PA 17013
Attorney for Plaintiff
VERIFICATION
I, Shirley M. Sheriff, hereby acknowledge that I am the Defendant in the
foregoing action; that I have read the foregoing Answer with Counterclaim and the facts stated
therein are true and correct to the best of my knowledge, information and belief.
I understand that any false statements herein are made subject to penalties of 18
Pa. C.S. Section 4904, relating to unworn falsification to authorities.
Dated: November , 2007
Shirley M. S ff
CERTIFICATE OF SERVICE
I, Richard S. Friedman, Esquire, hereby certify that on the day of
November, 2007, I served a copy of the within answer with counterclaim, by depositing same in
the United States Mail, first class, postage prepaid, addressed as follows:
TURD LAW OFFICES
Attn: Galen R. Waltz, Esq.
28 S. Pitt Street
Carlisle, PA 17013
FRIEDMAN & G, P.C.
r
Richard S. Friedman, Esquire
3820 Market Street
Camp Hill, PA 17011
(717) 236-8000
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GEORGE E. SHERIFF, THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - DIVORCE
NO. 07-5732 CIVIL TERM
SHIRLEY M. SHERIFFF, IN DIVORCE
Defendant/Petitioner :
PACSES CASE NO: 446109615
ORDER OF COURT
AND NOW, this 15th day of November, 2007, upon consideration of the Petition for Alimony Pendente
Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear beforeR. J.
Shadday on December 11, 2007 at 1:30 P.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after
which the conference officer may recommend that an Order for Alimony Pendente Lite be entered.
YOU are further ordered to bring to the conference:
(1) a true copy of your most recent Federal Income Tax Return, including W2'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 Rule 1910.1 IC
(4) verification of child care expenses
(5) proof of medical coverage which you may have, or may have available to you
If you fail to appear for the conference or bring the required documents, the Court may issue a
warrant for your arrest.
BY THE COURT,
Edgar B. Bayley, President Judge
Copies mailed to: Petitioner
Respondent
Richard S. Friedman, Esq.
Galen R. Waltz, Esq.
Date of Order: November 15, 2007
. . Sha y, C fe nce Officer
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND
REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL
HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVE.
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166 cc361
ro
GEORGE E. SHERIFF
Plaintiff
PENNSYLVANIA
V.
SHIRLEY M. SHERIFF
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
NO. 07-5732 CIVIL TERM
: CIVIL ACTION - LAW
: IN DIVORCE
ANSWER TO COUNTER CLAIM
NOW COMES, the Plaintiff, George E. Sheriff, by and through his
Attorney, Galen R. Waltz, answers the counter claim by stating as follows:
15. Denied, proof demanded at a hearing.
16. Request the court deny an award of Alimony Pendente Lite.
WHEREFORE, the Plaintiff respectfully requests the court to dismiss
the request for Alimony Pendente Lite.
Respectfully submitted,
06len R. Watl
Turo Law Offices
28 South Pitt Street
Carlisle, PA 17013
717-245-9688
Attorney for Plaintiff
M
VERIFICATION
I verify that the statements made in the foregoing Answers to Counter
Claim are true and correct. I understand that false statements herein made
are subject to the penalties of Pa.C.S. §4904 relating to unsworn falsification
to authorities.
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Date
George E. Sheriff
CERTIFICATE OF SERVICE
I, Galen R. Waltz, Esquire hereby certify that I served a true and
correct copy of the Complaint in Divorce, by first class, certified return receipt
requested and depositing same in the United States Mail, first class, postage
pre-paid on the F07 day of 2007, from Carlisle,
Pennsylvania, addressed as follows:
Richard S. Friedman, Esquire
3820 Market Street
Camp Hill, PA 17011
TURO LAW OFFICES
G'alen R. Wad Ess
28 South Pitt Strz
Carlisle, PA 17013
(717) 245-9688
Attorney for Plaintiff
CZ)
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsylvania
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 12/11/07
Case N u m be r (See Addendum for case summary)
446109615 0 Original Order/Notice
07-5732 CIVIL O Amended Order/Notice
O Terminate Order/Notice
Employer/Withholder's Federal EIN Number
SOCIAL SECURITY ADMINISTRATION
STE 1
200 S SPRING GARDEN ST
CARLISLE PA 17013-2578
RE: SHERIFF, GEORGE E.
Employee/Obligor's Name (Last, First, MI)
193-36-3892
Employee/Obligor's Social Security Number
6486101875
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 582.00 per month in current support
$ 48 . oo per month in past-due support Arrears 12 weeks or greater? Oyes ® no
$ 0.00 per month in current and past-due medical support
$ 0.00 per month for genetic test costs
$ 0.00 per month in other (specify)
for a total of $ 630.00 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:
$ 144.99 per weekly pay period.
$ 289.97 per biweekly pay period (every two weeks).
$ 315. oo per semimonthly pay period (twice a month).
$ 630. 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.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BY THE COURT:
Date of Order: DEC 12 2007 * 06/,
KEVIIW A. SS, JUDGE
DRO: R.J. SHADDAY Form EN-028 Rev. 1
Service Type M OMB No.: 097"154 Worker ID $OINC
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
? If Necked you are required to provide a opy of this form to your m loyee. If yo r employee works in a state that is
dierent from the state that issued this o er, a copy must be provi?edpto 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.
/-I I '-ensen'in he
3.*
You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee/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 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.
THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 8384100092
EMPLOYEE'S/OBLIGOR'S NAME: SHERIFF GEORGE E.
EMPLOYEE'S CASE IDENTIFIER: 6486101875 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: if you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employeelobligor from employment,
refusing to employ, or taking disciplinary action against any employeelobligor 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
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
Service Type M
OMB No.: 0970-0154
Form EN-028 Rev. 1
Worker ID $OINC
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: SHERIFF, GEORGE E.
PACSES Case Number 446109615 PACSES Case Number
Plaintiff Name Plaintiff Name
SHIRLEY M. SHERIFF
Docket Attachment Amount Docket Attachment Amount
07-5732 CIVIL$ 630.00 $ 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'slobligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren) ? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available identified above in any health insurance coverage available
:hrough the employee's/obligor's employment. through the employee's/obligor's employment.
Addendum Form EN-028 Rev. 1
ervice Type M Worker ID $OINC
OMB No.: 0970-0754
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GEORGE E. SHERIFF, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - DIVORCE
NO. 07-5732 CIVIL TERM
SHIRLEY M. SHERIFF, IN DIVORCE
Defendant/Petitioner
PACSES CASE ID: 446109615
ORDER OF COURT
AND NOW, this 11 th day of December 2007, based upon the Court's determination that
Petitioner's monthly net income/earning capacity is $ 850.00 and Respondent's monthly net
income/earning capacity is $ 2,304.44, it is hereby ordered that the Respondent pay to the
Pennsylvania State Collection and Disbursement Unit Six Hundred Thrity and 00/100 Dollars
($630.00) per month payable as follows: $582.00 per month for Alimony Pendente Lite and $48.00
per month on arrears. First payment dueon or before Januey 5, 2008 and by the 5t" of wach month
therafter. The effective date of the order is November 9, 2007.
Arrears set at $1,002.95 as of December 11, 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: Shirley M. Sheriff. 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
This Order shall become final twenty (20) after the mailing of the notice of the entry of the
Order to the parties unless either parry 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,
:p5-. /f I.
Kev A. Hess, J•
iled copies on: December 12, 2007
Petitioner
Zespondent
Uchard S. Friedman, Esq.
',alen R, Waltz, Esq.
R.J. Shadday
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GEORGE E. SHERIFF )
Plaintiff
VS.
SHIRLEY M. SHERIFF )
Defendant )
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 2007-5732 CIVIL TERM
IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
Plaintiff moves the Court to appoint a Master with respect to the following claims:
(X) Divorce (X) Distribution of Property L? Support (___) Annulment
(_) Alimony CX) Alimony Pendente Lite (_) Counsel Fees (__ Costs and
Expenses
and in support of such motion states:
1. Discovery is complete as to the claims for which the appointment of a Master is requested.
2. The Defendant has appeared in the action by her attorney, Richard S. Friedman, Esquire.
3. The statutory ground for divorce is: 3301 (d)
4. Check the applicable paragraph(s):
The action is not contested
(?) An agreement has been reached with respect to the following claims:
CX ) The action is contested with respect to the above-marked claims.
5. The action does not involve complex issues of law or fact.
6. The hearing is expected to take hours 1 day.
7. Additional information, if, any relevant to this motion:
Date:
en R. Waltz, Esqu'
Attorney for PlainffiT
AND NOW , 2009, E. Robert Elicker, II, Esquire is appointed
Master with respect to the above claims.
BY THE COURT,
J.
CERTIFICATE OF SERVICE
I, Galen R. Waltz, Esquire hereby certify that I served a true and correct copy of
the within Motion for Appointment of Master, by depositing sa a in he United States
Mail, first class, postage pre-paid on the 1 day of '2009,
from Carlisle, Pennsylvania, addressed as follows:
Richard S. Friedman, Esquire
300 North Second Street, Suite 402
Harrisburg, PA 17101
TURO LAW OFFICES
x 44
en R. Waltz, uire
Attorney for Pl intiff
Attorney I.D. No. 39789
28 South Pitt Street
Carlisle, PA 17013
(717) 245-9688
. .
F ?k ir" ; ; i v FILE! CE
OF THE
. , ^r T4pY
?? ?h .?,y ar.R n•
-y
f~ APR 2 7 2009?^ f
v1
GEORGE E. SHERIFF )
Plaintifff )
vs. )
SHIRLEY M. SHERIFF )
Defendant )
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 2007-5732 CIVIL TERM
IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
Plaintiff moves the Court to appoint a Master with respect to the following claims:
( X Divorce (X) Distribution of Property (_) Support Annulment
(_) Alimony LX) Alimony Pendente Lite L? Counsel Fees Costs and
Expenses
and in support of such motion states:
1. Discovery is complete as to the claims for which the appointment of a Master is requested.
2. The Defendant has appeared in the action by her attorney, Richard S. Friedman, Esquire.
3. The statutory ground for divorce is: 3301 (d)
4. Check the applicable paragraph(s):
(?) The action is not contested
(?) An agreement has been reached with respect to the following claims:
( X ) The action is contested with respect to the above-marked claims.
5. The action does not involve complex issues of law or fact.
6. The hearing is expected to take hours 1 day.
7. Additional information, if, any relevant to this motion:
Date:
en R. Waltz, Esq
Attorney for Plai
AND NOW ;27 , 2009, E. Robert Elicker, II, Esquire is appointed
Master with respect to th6 above claims.
BY THE C T,
r
CA
J.
. r-i
RICHARD S. FRIEDMAN, P.C.
Richard S. Friedman, Esquire
ID #07176
300 N. 2nd Street, Suite 402
Harrisburg, PA 17101
Tel.: (717) 234-3441/Fax: (717) 232-9946
e-mail: rsfl32live.com
Attorney for Defendant
GEORGE E. SHERIFF, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 07-5732 CIVIL TERM
SHIRLEY M. SHERIFF, CIVIL ACTION - LAW
Defendant. IN DIVORCE
PETITION FOR ALIMONY
As per Rule 1920.15(b), kindly consider this as a claim for alimony by the Defendant in
the above-captioned matter.
Date: "
Respectfully submitted,
RICHARD S. FRIEDMAN, P.C.
Richar S. Frie an, Esquire
300 .2nd Street, Suite 402
Harrisburg, PA 17101
(717) 234-3441
GEORGE E. SHERIFF,
Plaintiff
V.
SHIRLEY M. SHERIFF,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07-5732 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
CERTIFICATE OF SERVICE
I, Richard S. Friedman, Esquire, hereby certify that on the d?(?'-day of April, 2009, I
served a copy of the within Petition for Alimony, by depositing same in the United States Mail,
first class, postage prepaid, addressed as follows:
Galen R. Waltz, Esquire
Turo Law Offices
28 S. Pitt Street
Carlisle, PA 17013
E. Robert Elicker, II, Divorce Master
9 N. Hanover Street
Carlisle, PA 17013
Rich S. Friedman, Esquire
R1 HARD S. FRIEDMAN, P.C.
300 N. 2nd Street, Suite 402
Harrisburg, PA 17101
(717) 234-3441
F!LE L
OF THE F „-,',1 -,", '-',. API
2009 APR 30 Pih 3 u
401G. 00 Po a47r, (
ex*itt4
aaq 4q9
RICHARD S. FRIEDMAN, P.C.
Richard S. Friedman, Esquire
ID #07176
300 N. 2nd Street, Suite 402
Harrisburg, PA 17101
Tel.: (717) 234-344I/Fax: (717) 232-9946
e-mail: rsfl3&live.com
Attorney for Defendant
GEORGE E. SHERIFF, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 07-5732 CIVIL TERM
SHIRLEY M. SHERIFF, CIVIL ACTION - LAW
Defendant. IN DIVORCE
INCOME AND EXPENSE STATEMENT
OF
SHIRLEY M. SHERIFF
I verify that the statements made in this Income and Expense Statement 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: ??r `0
INCOME
Employer: N/A
Address:
Type of work:
Payroll Number:
Pay Period (weekly, biweekly, etc.):
Gross Pay per Pay Period:
Itemized Payroll Deductions:
Federal Withholding:
Social Security:
Local Wage Tax:
State Income Tax:
Retirement:
Savings Bonds:
Credit Union:
Life Insurance:
Health Insurance:
Other (specify):
Net Pay per Pay Period:
Other Income:
Interest
Dividends
Pension
Annuity
Social Security
Rents
Royalties
Expense Account
Gifts
Unemployment Comp.
Workmen's Comp.
APL (alimony pendente lite)
Total
Week
Month Year
-0-
-0-
-0-
-0-
$ 595.00 $ 7,140.00
-0-
-0-
-0-
-0-
-0-
-0-
630.00 $7,560.00
$1,225.00 $14,700.00
TOTAL INCOME $14,700.00 per year
EXPENSES
Weekly Monthly
Home
Mortgage/rent $648.00
Maintenance
Utilities
Electric $ 70.00
Gas ($289.00 every 2 1/2 months) $125.00
Oil
Telephone $124.00
Water $ 25.67
Sewer $ 24.33
Employment
Public Transportation
Lunch
Taxes
Real Estate
Personal Property
Misc. Taxes $ 4.90
Income
Insurance
Homeowners
Automobile $ 44.80
Life
Accident
Health $ 96.00
Other
Automobile
Payments
Fuel $ 50.00
Repairs $ 8.33
Yearly
$100.00
EXPENSES
Medical
Weeklv Monthlv Yearlv
Doctor
Dentist (plate)
Orthodontist
Hospital
Medicine
Special needs (glasses,
braces, orthopedic
devices)
Education
Private school
Parochial school
College
Religious
Personal
Clothing
Food
Barber/hairdresser
Credit payments
Credit card
Charge account
Memberships
Loans
Credit Union
Miscellaneous
Household Help
Child Care
Papers/books/magazines
Entertainment
Pay TV
Vacation
Gifts (Christmas)
Legal Fees
Charitable Contributions
Other Child Support
Alimony Payments
Other
$ 25.00 $300.00 (approx. total owed)
$ 29.17 $350.00 (total owed)
$ 25.00 $200.00 (approx. total owed)
$ 50.00
$ 20.83 $250.00
$240.00
$ 41.67
$208.33
$ 500.00
$2,500.00
TOTAL EXPENSES: $1,861.03
PROPERTY OWNED:
Checking account
Savings accounts
Credit Union
Stocks/bonds
Real estate
Other
INSURANCE:
Description Value
Members 1 st $100.00
TOTAL $100.00
COM12
Hospital
Blue Cross
Other (Medicare Part A)
Medical
Blue Shield
Other (Medicare Part B)
Health/Accident
Disability Income
Dental
Other
H husband
W wife
J joint
C child
Ownership
HWJ
W
Coverage
Policy No. H W C
193-36-3892B W
193-36-3892B W
SUPPLEMENTAL INCOME STATEMENT
(a) This form is to be filled out by a person (check one):
(1) who operates a business or practices a profession, or
(2) who is a member of a partnership or joint
venture, or
(3) who is a shareholder in and is salaried by a
closed corporation or similar entity.
(b) Attach to this statement a copy of the following documents relating to the partnership, joint
venture, business, profession, corporation or similar entity:
(1) the most recent Federal Income Tax Return, and
(2) the most recent Profit and Loss Statement.
(c) Name of business:
Address and Telephone Number:
(d) Nature of business (check one):
(1) partnership
(2) joint venture
(3) profession
(4) closed corporation
(5) other
(e) Name of accountant, controller or other person in charge of financial records:
(f) Annual income from business:
(1) How often is income received?
(2) Gross income per pay period:
(3) Net income per pay period:
(4) Specified deductions, if any:
E Departrnent of the Treasury - Internal Revenue Service
8 1040 U.S. Individual Income Tax Return 2008 (ss) IRS Use Only-Do not write or
Label L For the year Jan. 1-Dec. 31, 2008, or other tax year beginning 2008, ending 20
(See B Name Spouse's Name (if Joint Return) Home Address City, State, and ZIP Code
Instructions) E SHIRLEY M SHERIFF
Use the
IRS label.
otherwise, JE
pleaseprint R LOT 75 SPRING GARDEN EST
or type. E CARLISLE PA 17 015
Presidential
Election Cai
Filing Status
Check only
one box.
Exemptions
If more
than
four
depen-
dents,
see
instr.
? Check here if you, or your spouse if filing jointly, want $3 to I.
1 Single 4
2 H Married filing jointly (even if only one had income)
3 Married filing separately. Enter spouse's SSN above
and full name here. ? 5
to this fund (see instructions) ?
_
in this space.
OMB No. 1545-0074
Your social security number
192-34-6439
Spouse's social security no.
You muss enter
A your SSN(s above. A
Checking a box below will not
change your tax or refund.
11 You Spouse
Head of household (with qualifying person). (See instructions.)
If the qualifying person is a child but not your dependent, enter
this child's name here. ?
I I Qualifying widow(er) with dependent child (see instructions)
IOnS 6a
b
N Yourself. If someone can claim you as a dependent, do not check box 6a ............... .
Spouse ..................................................................................
-
.
c Dependents:
(1) First name Last name (2) Dependent's
social security no. Dependent's
OT
relationship to
you fy n chi dl
fo c ild tax
credit seeinst
Boxes checked on
6a and 6b .L
No. of children -
on 6c who:
• lived with you 0
• did not live with
you due to divorce
(see inst,.)
or' (?
Dependents on 6c
not entered above
Add numbers
d Tntal number of exemptions claimed on lines above? I ll
7 Wages, salaries, tips, etc. Attach Form(s) W-2
Income 7 300
Attach Schedule B if required ..........................................
8a Taxable interest 8a
.
Attach
Form(s) W-2 here. b Tax-exempt interest. Do not include on line 8a .......... 8b
.::::......
Attach Schedule B if required ........................................
Also attach Forms 9a Ordinar
dividends 9a
-
.
y
W-2G and
b Qualified dividends (see instructions) ....... .. 9b ........
"
1099-R if tax
or offsets of state and local income taxes (see instructions) ........
credits
10 Taxable refunds
s withheld 10 _
,
,
.
wa
received
11 Alimon 11 6,984.
y
Attach Schedule C or C-EZ ....................................
12 Business income or (loss) 12
.
Attach Schedule D if required. If not required, check here ?
If you did not 13 Ca
ain or (loss)
ital 13 _
.
g
p
get a W-2,
ains or (losses). Attach Form 4797 ................................................
14 Other
14
_
g
see instructions.
15a IRA distributions 15a b Taxable amount (see inst.) 15b
..........
16a Pensions and annuities 16a b Taxable amount (see inst.) 16b _
....
partnerships, S corporations, trusts, etc. Attach Schedule E ....
royalties
17 Rental real estate 17 _
,
,
...............................................
Attach Schedule F
18 Farm income or (loss) 18 _
.
.
Enclose, but do 19 Unem
........ • .
loyment compensation 19
........
p
not attach, any
I20a1 7 , 8 9 7 . I b Taxable amount (see inst.)
20a Social security benefits
20b
_
..
payment. Also,
List type and amount (see instr.)
lease use 21 Other income 21 _
.
p
Form 1040-V. 22 Add the amounts in the far right column for lines 7 through 2 1. This is your total income ? 22 7,284.
23 Educator expenses (see instructions) ...................... 23
Adjusted 24 Certain business expenses of reservists, performing artists,
Gross and fee-basis gov. officials. Attach Form 2106 or 2106-EZ
24
Income 25 Health savings account deduction. Attach Form 8889 ...... 25
26 Moving expenses. Attach Form 3903 ...................... 26
27 One-half of self-employment tax. Attach Schedule SE .... 27
28 Self-employed SEP, SIMPLE, and qualified plans ........ 28
29 Self-employed health insurance deduction (see instr.) ...... 29
30 Penalty on early withdrawal of savings ..... 30
30
31a Alimony paid b Recipient'sSSN ? 31a
32 IRA deduction (see instructions) .......................... 32
33 Student loan interest deduction (see instructions) .......... 33
34 Tuition and fees deduction. Attach Form 8917 ............ 34
35 Domestic production activities deduction. Attach Form 8903 35
36 Add lines 23 through 31a and 32 through 35 .................... .......................... 36 _
37 Subtract line 36 from line 22. This is your adjusted gross income .................... 0. 37 7,284.
For Disclosure, Privacy Act, and Paperwork Reduction Act Notice, see instructions. Form 1040 (2008)
BCA Copyright form software only, 2008 Universal Tax Systems, Inc. All rights reserved. US 1040$1 Rev. 1
(orm 1040 (2008) SHIRLEY M SHERIFF 192-34- 6439 Page 2
38 Amount from line 37 (adjusted gross income) ............................................. . 38 7,284.
39a Check r You were born before Jan. 2, 1944,
Blind.
Total boxes
iand B
?
if: L Spouse was born before Jan. 2, 1944, Blind. checked No
39a 1
redits b If your spouse itemizes on a separate return or you were a dual-status alien,
Standard ..........................................
see instructions and check here ? 39b
Deduction
for -
C Check If standard deduction Includes real estate taxes or disaster loss (see inst) ? 39c
8
40 Itemized deductions (from Schedule A) or your standard deduction (see left mar
in) 40 6
800
g
......
• People who ,
.
checked any 41 Subtract line 40 from line 38 .............................................................. 41 484.
box on line 42 If line 38 is over $119,975, or you provided housing to a Midwestern displaced individual,
39a or 39b or
who can be see inst. Otherwise, multiply $3,500 by the total number of exemptions claimed on line 6d 42 3, 500.
claimed as a 43 Taxable income. Subtract line 42 from line 41. If line 42 is more than line 41, enter -0-...... 43 0
dependent, 44 Tax (see instructions). Check if any tax is from: a 0 Form(s) 8814 b 0 Form 4972 . 44
see instr.
• 45 Alternative minimum tax (see instructions). Attach Form 6251 ................... • • , , ..... 45
All others: 46 Add lines 44 and 45
?
46
Single or
Married filing 47 Foreign tax credit. Attach Form 1116 if required ............ 47
separately,
$5
450 48 Credit for child and dependent care exp. Attach Form 2441 48
, 49 Credit for the elderly or the disabled. Attach Schedule R 49
Married filing
jointly or 50 Education credits. Attach Form 8863 .................... 50
Qualifying 51 Retirement savings contributions credit. Attach Form 8880 .. 51
widow(er),
$10
900 52 Child tax credit (see inst.). Attach Form 8901 if required 52
,
Head of 53 Credits from Form: a 8396 b
B 8839 c 5695 53
household, 54 Other credits from Form: a 3800 b aaol c 54
$8,000 55 Add lines 47 through 54. These are your total credits ...... ...... .......................... 55
56 Subtract line 55 from line 46. If line 55 is more than line 46, enter -0- ,, , , , , , , , ,,,,,, , , , ? 56
57 Self-employment tax. Attach Schedule SE ................................................ 57
)ther 58 Unreported social security and Medicare tax from Form: a F] 4137 b0 8919 .... 58
faxes 59 Additional tax on IRAs, other qualified retirement plans, etc. Attach Form 5329 if required .. 59
60 Additional taxes: a 0 AEIC payments b 0 Household employment taxes. Attach Sch. H 60
61 Add lines 56 through 60. This is your total tax ........................................ ? 61
62 Federal income tax withheld from Forms W-2 and 1099 .... 62
payments 63 2008 estimated tax pymts and amt applied from 2007 return 63
64 a Earned income credit (EIC) ....................... • . • , , , , 64a 0
If you have a ?- b Nontaxable combat 64b
Pay election "`
qualifying child,
attach Schedule 65 Excess social security and tier 1 RRTA tax withheld (see Inst) 65
=1C. 66 Additional child tax credit. Attach Form 8812 .............. 66
67 Amount paid with request for extension to file (see inst) .... 67
68 Credits from Form: a02439 b04136 c08801 d0 8885 68
69 First-time homebuyer credit. Attach Form 5405 ............ 69
70 Recovery rebate credit (see worksheet in the instructions) .. 70
71 Add lines 62 through 70. These are your total payments ... ...... ..................... ? 71
lefund 72 If line 71 is more than line 61, subtract line 61 from line 71. This is the amount you overpaid 72
irect deposit?
e
i
t
ti 73 a Amount of line 72 you want refunded to you. If Form 8888 is attached, check here ? 0 73a
e
ns
ruc
ons
id fill in 73b ? b numbe9 11
? c Type: Checking 0 Savings
,
3c, and 73d, No. I num?er
• Form 8888. 74 Amount of line 72 you want applied to your 2009 estimated taw 74
mount 75 Amount you owe. Subtract line 71 from line 61. For details on how to pay, see inst. .... ? 75
Ou Owe 76 Estimated tax penalty (see instructions) ......... .
76
.
.....
hird Party Do you want to allow another person to discuss this return with the IRS (see instructions)? Yes. Complete the following.
No ?Kl
esignee Designee's Phone Personal identification
name ? no. ? number (PIN) iii,
ign Under penalties of perjury, I declare that I have examined this return and accompanying schedules and statements, and to the best of my knowledge and
ere belief, they are true, correct, and complete. Dedaratlon ofr
" rer (other than taxpayer) is based on all information of which preparer has any knowledge.
Your signature Y
t
int return? a
e
our occupation Daytime phone number
re instr. PART MANAGER 717-422-5138
yep a copy Spouse's signature. If a joint return, both must sign. Date Spouse's occupation
your
.ords.
Preparer's' Date Check if Preparer's SSN or PTIN
aid signature self-employed S 2 5 0 5 0 8 0 8
•eparerrs Firm's name (or
EIN
;e Only yours If self -
employed),
address
and
'
,
ZIP code
Phone no.
:A Copyright form software only, 2008 Universal Tax Systems, Inc. All rights reserved. US 1040$2 Rev. 1 Form 1040 (2008)
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Form 8879
Department of the Treasury
Internal Revenue Service
Declaration Control Number (DCN)
IRS a-file Signature Authorization
? Do not send to the IRS. This is not a tax return.
? Keep this form for your records. See instructions.
OMB No. 1545-0074
2008
00235412 9
Taxpayer's name Social security number
SHIRLEY M SHERIFF 192-34-6439
Spouse's name Spouse's social security number
W,Wj? IaX Return Information-TaX Tear Ending December 31, 2008 (Whole Dollars Only)
1 Adjusted gross income (Form 1040, line 38; Form 1040A, line 22; Form 1040EZ, line 4.) ......................... 1 7,284.
2 Total tax (Form 1040, line 61; Form 1040A, line 37; Form 1040EZ, line 11) ...................................... 2
3 Federal income tax withheld (Form 1040, line 62; Form 1040A, line 38; Form 1040EZ, line 7) .................... 3
4 Refund (Form 1040, line 73a; Form 1040A, line 45a; Form 1040EZ, line 12a; Form 1040-SS, Part I, line 12a).... 4
5 Amount you owe (Form 1040, line 75; Form 1040A, line 47; Form 1040EZ, line 13) ...........................
sure you qet and keep a
Under penalties of perjury, I declare that I have examined a copy of my electronic individual income tax return and accompanying schedules and
statements for the tax year ending December 31, 2008, and to the best of my knowledge and belief, it is true, correct, and complete. I further declare
that the amounts in Part I above are the amounts from my electronic income tax return. I consent to allow my intermediate service provider, trans-
mitter, or electronic return originator (ERO) to send my return to the IRS and to receive from the IRS (a) an acknowledgement of receipt or reason for
rejection of the transmission, (b) an indication of any refund offset, (c) the reason for any delay in processing the return or refund, and (d) the date of
any refund. If applicable, I authorize the U.S. Treasury and its designated Financial Agent to initiate an ACH electronic funds withdrawal (direct debit)
entry to the financial institution account indicated in the tax preparation software for payment of my Federal taxes owed on this return and/or a pay-
ment of estimated tax, and the financial institution to debit the entry to this account. I further understand that this authorization may apply to future
Federal tax payments that I direct to be debited through the Electronic Federal Tax Payment System (EFTPS). In order for me to initiate future pay-
ments, I request that the IRS send me a personal identification number (PIN) to access EFTPS. This authorization is to remain in full force and effect
until I notify the U.S. Treasury Financial Agent to terminate the authorization. To revoke a payment, I must contact the U.S. Treasury Financial Agent
at 1-888-353-4537 no later than 2 business days prior to the payment (settlement) date. I also authorize the financial institutions involved in the
processing of the electronic payment of taxes to receive confidential information necessary to answer inquiries and resolve issues related to the pay-
ment. I further acknowledge that the personal identification number (PIN) below is my signature for my electronic income tax return and, if applicable,
my Electronic Funds Withdrawal Consent.
Taxpayer's PIN: check one box only
® l authorize SALVATION ARMY SENIOR ACTION-TCE
ERO firm name
to enter or generate my PIN
98623
Enter five numbers, but
as my signature on my tax year 2008 electronically filed income tax return. do not enter all zeros
I will enter my PIN as my signature on my tax year 2008 electronically filed income tax return. Check this box only if you are
entering your own PIN and your return is filed using the Practitioner PIN method. The ERO must complete Part III below.
Your signature ? Date 1- 04/01/2009
Spouse's PIN: check one box only
® I authorize
ERO firm name
to enter or generate my PIN
1 -1
Enter five numbers, but
as my signature on my tax year 2008 electronically filed income tax return. do not enter all zeros
n I will enter my PIN as my signature on my tax year 2008 electronically filed income tax return. Check this box only if you are
entering your own PIN and your return is filed using the Practitioner PIN method. The ERO must complete Part III below.
Spouse's signature ? Date ?
Practitioner PIN Method Returns Only-continue below
JiGM Certification and Authentication-Practitioner PIN Method Only
ERO's EFIN/PIN. Enter your six-digit EFIN followed by your five-digit self-selected PIN. 23541298765
do not enter all zeros
I certify that the above numeric entry is my PIN, which is my signature for the tax year 2008 electronically filed income tax return
for the taxpayer(s) indicated above. I confirm that I am submitting this return in accordance with the requirements of the Practitioner PIN method and
Publication 1345, Handbook for Authorized IRS a-file Providers of Individual Income Tax Returns.
ERO's signature ? S 2 5 0 5 0 8 0 8 SALVATION ARMY SENIOR Date 0, 04/01/2009
ERO Must Retain This Form - See Instructions
Do Not Submit This Form to the IRS Unless Requested To Do So
For Paperwork Reduction Act Notice, see the instructions. Form 8879 (2008)
BCA Copyright form software only, 2008 Universal Tax Systems, Inc. All rights reserved. US8879$1 Rev. 1
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CAPITAL TAX COLLECTION BUREAU
19 S HANOVER ST, STE 102
CARLISLE, PA 17013-3336 041586 82 04152009 0.00 1201
TELEPHONE (717) 243-3725 DATE RECEIVED 04/15/2009
2008
LOCAL EARNED INCOME TAX RETURN (FORM 531)
W-2 EARNING (FROM ATTACH W-21S) 300.00
EMPLOYEE BUSINESS EXPENSES (FEDERAL FORM 2106)
OTHER TAXABLE EARNED INCOME
NET LOSS FROM BUSINESS, PROFESSION OR FARM
NET PROFIT FROM BUSINESS, PROFESSION OR FARM
TOTAL TAXABLE EARNED INCOME AND NET PROFITS 300.00
TAX LIABILITY: TOTAL TAXABLE EARNED INCOME X 1.1 % 3.30
TOTAL LOCAL INCOME TAXES WITHHELD 3.30
QUARTERLY PAYMENTS
CREDIT FOR TAXES PAID TO PHILA. AND/OR OTHER STATES
TOTAL WITHHOLDING & PAYMENTS 3.30
TAX BALANCE DUE
INTEREST & PENALTY
TOTAL BALANCE DUE
OVERPAYMENT
1201 S MIDDLETON TP
3461732195
SHERIFF SHIRLEY
75 SPRING GARDEN EST
CARLISLE PA 17013
4/15/2009
------------------------------------ -------------------
YOUR SIGNATURE DATE
HAVE YOU MOVED DURING THIS TAX FILING YEAR? YES NO (CIRCLE ONE)
TkXPAYER COPY
GEORGE E. SHERIFF, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
SHIRLEY M. SHERIFF,
Defendant.
NO. 07-5732 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
CERTIFICATE OF SERVICE
I, Richard S. Friedman, Esquire, hereby certify that on the day of May, 2009, I
served a copy, of the within Income and Expense Statement of Shirley M. Sheriff, by depositing
same in the United States Mail, first class, postage prepaid, addressed as follows:
Galen R. Waltz, Esquire
Turo Law Offices
28 S. Pitt Street
Carlisle, PA 17013
E. Robert Elicker, II, Divorce Master
9 N. Hanover Street
Carlisle, PA 17013
Richard S. Friedman, Esquire
RICHARD S. FRIEDMAN, P.C.
300 N. 2nd Street, Suite 402
Harrisburg, PA 17101
(717) 234-3441
t"1( CM
OF THE"
2009 hj"Y 14 Pi i `. 1
TURO LAW OFFICES
Galen R. Waltz, Esquire
ID# 39789
28 South Pitt Street
Carlisle, PA 17013-3211
Tel.: (717) 245-9688/Fax: (717) 245-2165
email: GWaltz ,TuroLaw.com
Attorney for Plaintiff
UhURUE E. SHERIFF,
Plaintiff
V.
SHIRLEY M, SHERIFF
Defendant,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07-5732 CIVIL TERM
CIVIL ACTION- LAW
IN DIVORCE
INCOME AND EXPENSE STATEMENT
OF
GEORGE E. SHERIFF
I verify that the statements made in this Income and Expense Statement 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: (` 119 (0 l
George E. Sheriff, Plaintiff
INCOME
Employer:
Address:
Type of Work:
Payroll Number:
Pay Period (weekly, biweekly, etc,):
Gross Pay per Pay Period: $
Itemized Payroll Deductions:
Federal Withholding: $
Social Security: $
Local Wage Tax: $
State Income Tax: $
Retirement: $
Savings Bonds: $
Credit Union: $
Life Insurance: $
Health Insurance: $
Other (specify):
Net Pay per Pay Period: $
Other Income:
Week Month Year
Interest
Dividends
Pension $999.38 $11,992.56
Annuity
Social Security $1,417.00 $17,004.00
Rents
Royalties
Expense Account
Gifts
Unemployment Comp.
Workmen's Comp.
APL (alimony pendente lite)
Total $2,416.38 $28,996.56
TOTAL INCOME per year+ $28,996.56
EXPENSES
Home
Mortgage/rent
Maintenance
Utilities
Electric
Gas
Oil
Telephone
Water
Sewer
Monthly Yearly
Weekly
$327.00
$200.00
$120.00
$60.00
$25.67
$24.33
Employment
Public Transportation
Lunch
Taxes
Real Estate
Personal Property
Misc. Taxes
Income
Insurance
Homeowners
Automobile
Life
Accident
Health
Other
Automobile
$125.17
$232.52
Payments $211.00
Fuel $60.00
Repairs
$200.00
$1200.00
$71.15
$30.00
$1,023.00
$200.00
EXPENSES
Medical
Weekly Monthly
Doctor
Dentist (plate)
Orthodontist
Hospital
Medicine
Special needs (glasses,
braces, orthopedic devices)
Education
Private School
Parochial School
College
Religious
Personal
Clothing
Food
Barber/hairdresser
Credit payments
Credit card
Charge Account
Memberships
Loans
Credit Union
Miscellaneous
Household Help
Child Care
Papers/books/magazines
Entertainment
Pay TV
Vacation
Gifts (Christmas)
Legal Fees
Charitable Contributions
Other Child Support
Alimony Payments
Other
$250.00
$185.96
$630.00
Yearly
$2,568.00 (still owe)
$100.00
$50.00
TOTAL EXPENSES: $2,251.65
PROPERTY OWNED:
Ownership
Descri tp ion Value HWJ
Checking account Personal M&T Bank $50.00? H
Savings Accounts Relationship Savings $200.00 H
Credit Union
Stocks/bonds $100.00 Savings Bonds(x4) $400.00 H
Real estate
Other
TOTAL $650.00
INSURANCE:
Coverage
Company Policy No. HWC
Hospital
Blue Cross
Other (Medicare Part A)
Medical
Blue Shield
Other (Medicare Part B)
Health Accident
Disability Income
Dental
Other
H husband
W wife
J joint
C child
193-36-3892-A H
SUPPLEMENTAL INCOME STATEMENT
(a) This form is be filled out by a person (check one):
(1) who operates a business or practices a profession, or
(2) who is a member of a partnership or joint
venture, or
(3) who is a shareholder in and is salaried by a
closed corporation or similar entity.
(b) Attach to this statement a copy of the following documents relating to the partnership,
joint venture, business, profession, corporation or similar entity:
(1) the most recent Federal Income Tax Return, and
(2) the most recent Profit and Loss Statement.
(c) Name of the business:
Address and Telephone Number:
(d) Nature of business (check one):
(1) partnership
(2) joint venture
(3) profession
(4) closed corporation
(5) other
(e) Name of accountant, controller or other person in charge of financial records:
(f) Annual income from business:
(1) How often is income received?
(2) Gross income per pay period:
(3) Net income per pay period:
(4) Specified deductions, if any:
Do Not Submit This Form to the 4RS Unless Requested To Do So
Form 8879 IRS a-file Signature Authorization OMB No. 1545-0074
Department of the Treasury ?Do not send to the IRS. This is not a tax return. 2008
Internal Revenue Service ?Kee this form for our records. See instructions.
Declaration Control Number DCN 00-231272-21095-9
Taxpayer's name Social security number
SHERIFF GEORGE 193-36-3892
Spouse's name Spouse's social security number
Part I Tax Return Information - Tax Year Ending December 31, Whole Dollars Only)
1 Adjusted gross income (Form 1040, line 38; Form 1040A, line 22; Form 1040EZ, line 4) . . . . . . . . . . . . . . . . . 1 29,974
2 Total tax (Form 1040, line 61; Form 1040A, line 37; Form 1040EZ, line 11) . . . . . . . . . . . . . . . . . . . . . . . . 2 2,550
3 Federal income tax withheld (Form 1040, line 62; Form 1040A, line 38; Form 1040EZ, line 7) . . . . . . . . . . . . . . 3 1,527
4 Refund (Form 1040, line 73a; Form 1040A, line 45a; Form 1040EZ, line 12a; Form 1040-SS, Part I, line 12a) . . . . . 4
Part If Taxoaver Declaration and Signature Authorization (Be sure you get and keep a cogy of your return)
Under penalties of perjury, I declare that I have examined a copy of my electronic individual income tax return and accompanying schedules and
statements for the tax year ending December 31, 2008, and to the best of my knowledge and belief, it is true, correct, and complete. I further declare
that the amounts in Part I above are the amounts from my electronic income tax return. I consent to allow my intermediate service provider,
transmitter, or electronic return originator (ERO) to send my return to the IRS and to receive from the IRS(a) an acknowledgement of receipt or
reason for rejection of the transmission, (b) an indication of any refund offset, (c) the reason for any delay in processing the return or refund, and
(d) the date of any refund. If applicable, I authorize the U.S. Treasury and its designated Financial Agent to initiate an ACH electronics funds
withdrawal (direct debit) entry to the financial institution account indicated in the tax preparation software for payment of my Federal taxes owed on
this return and/or a payment of estimated tax, and the financial institution to debit the entry to this account. I futher understand that this authorization
may apply to future Federal tax payments that I direct to be debited through the Electronic Federal Tax Payment System (EFTPS). In order for me
to initiate future payments, I request that the IRS send me a personal identification number (PIN) to access EFTPS. This authorization is to remain in full
force and effect until I notify the U.S. Treasury Financial Agent to terminate the authorization. To revoke a payment, I must contact the U.S. Treasury
Financial Agent at 1-888-353-4537 no later than 2 business days prior to the payment (settlement) date. 1 also authorize the financial institutions
involved in the processing of the electronic payment of taxes to receive confidential information necessary to answer inquiries and resolve issues
related to the payment. I futher acknowledge that the personal identification number (PIN) below is my signature for my electronic income tax return
and, if applicable, my Electronic Funds Withdrawal Consent.
Taxpayer's PIN: check one box only
® I authorize Jackson Hewitt Tax Service to enter or generate my PIN 01628
ERO firm name Enter five numbers, but
as my signature on my tax year 2008 electronically filed income tax return. nt not enter all zeros
? 1 will enter my PIN as my signature on my tax year 2008 electronically filed income tax return. Check this box only
if you are entering your own PIN and your return is filed using the Practitioner PIN method. The ERO must complete Part III below.
Your signature ?
Spouse's PIN: check one box only
Date ?
? I authorize to enter or generate my PIN
ERO firm name Enter five numbers, but
as my signature on my tax year 2008 electronically filed income tax return. do not enter all zeros
? 1 will enter my PIN as my signature on my tax year 2008 electronically filed income tax return. Check this box only
if you are entering your own PIN and your return is filed using the Practitioner PIN method. The ERO must complete Part III below.
Spouse's signature ?
Date ?
W Practitioner PIN Method Returns Only continue below
W Part III Certification and Authentication - Practitioner PIN Method Only
ERO's EFIN/PIN. Enter your six-digit EFIN followed by your five-digit self-selected PIN. 23127248111
99 do not enter all zeros
QI certify that the above numeric entry is my PIN, which is my signature for the tax year 2008 electronically filed income tax return for the taxpayer(s)
wlndicated above. I confirm that I am submitting this return in accordance with the requirements of the Practitioner PIN method and Publication 1345,
r hHandbook for Authorized IRS a-file Providers of Individual Income Tax Returns.
P67 RO's signature ? Christine Moore Data ? 04102/2009
ERO Must Retain This Form - See Instructions
F 11/5/08
Act and Paperwork Reduction Act Notice, see instructions.
Form 8879 (2008)
C
RENtlMREheWfeOP riaTRO6V6NOT FIL
Label For the ear Jan. 1 - Dec. 31 2008 or other tax ear be innin
(See Your first name and initial Last name
instructions.) A GEORGE E SHERIFF
Use the IRS B if a joint return, spouse's first name and initial Last name
label. E
L
Otherwise, H Home address (number and street). If you have a P.O. box, see instructions.
please print R
ortype. E 95 SPRING GARDEN ESTATE
City, town or post office, state, and ZIP code. If you have a foreign address, see instructions.
Presidential CARLISLE. PA 17015
Apt. no.
Your social security number
Spouse's social security number
? You must enter
Checking a box below will
Filing Status 1 ® Single 4 ? Head of household (with qualifying person). (See instr.)
Check only 2 ? Married filing jointly (even if only one had income) If the qualifying person is a child but not your dependent,
one box. 3 ? Married filing separately. Enter spouse's SSN above and enter this child's name here. ?
Exemptions 6 a IN Yourself. If someone can claim you as a dependent, do not check box 6a . . . . . . . . . . . .
b ? SDOUSe.
c Dependents:
(2) Dependent's social I (3) Dependent's I (4) V' if qualifying
security number relationship to child for child tax
If more than four
dept I?i F E
see instructions.
Income 7 Wages, salaries, tips, etc. Attach Form(s) W-2 . . . . . . . . . . . . . . . . . . . . . . . . . .
8 a Taxable interest. Attach Schedule B if required . . .
Attach Form(s) W-2 b Tax-exempt interest. Do not include on line 8a . . . . . . . . I 8b
here. Also attach 9 a Ordinary dividends. Attach Schedule B if required . . .
Forms W-2G and
b . . . . . . . . . .
Qualified dividends (see instructions) . . . . . . . . . . . . 19b I
1099-R if tax 10 Taxable refunds, credits, or offsets of state and local income taxes (see instructions) . . . . . .
was withheld. 11 Alimony received . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
12 Business income or (loss). Attach Schedule C or C-EZ . . . . . . . . . . . . . . . . . . . . . .
13 Capital gain or (loss). Attach Schedule D if req f ^^ ?°
^,r
e
.
6
O
If you did not
14
t
C
-
ft
0p
1
Other gains or (losses). Attach Form 4797. r 1 1? +
Y
get a W-2, see 15a IRA distributions . . . . . . . . . 15a b Taxable amount (see instr).
instructions. 16a Pensions and annuities . . . . . 16a 114.059 b Taxable amount (see instr).
17 Rental real estate, royalties, partnerships, S corporations, trusts, etc. Attach Schedule E . . . .
Enclose, but do 18 Farm income or (loss). Attach Schedule F . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
not attach, any 19 Unemployment compensation .
payment. Also, 20 a Social security benefits . . . . . . 1 20a I 16r 080 I b Taxable amount (see in'str).
please use 21 Other income. List type and amount (see instructions)
?
23 Educator expenses (see instructions) . . . . . . . . . . . . . . . 23
Adjusted 24 Certain business expenses of reservists, performing artists, and
FERFNi=s= ffil C,
nc
P
T
A
?
?
2
M c
ont l
o ,
: 8? 5
26 Moving expenses. Attach Form 3903 . . . . . . . . . 26
27 One-half of self-employment tax. Attach Schedule SE . . . . . 27
28 Self-employed SEP, SIMPLE, and qualified plans . . . . . . . . 28
29 Self-employed health insurance deduction (see instructions) 29
30 Penalty on early withdrawal of savings . . . . . . . . . . . . . . 30
31 a Alimony paid b Recipient's SSN ? 31a
32 IRA deduction (see instructions) . . . . . . . . . . . . . . . . . 32
33 Student loan interest deduction (see instructions) . . . . . . . . 33
34 Tuition and fees deduction. Attach Form 8917 . . . . . . . . . . 34
35 Domestic production activities deduction. Attach Form 8903 . . 35
36 Add lines 23 through 31a and 32 through 35 . . . . . . . . . . . . . . . . . . . . . . . . . . .
i-or visciosure, Privacy Act, and Paperwork Reduction Act Notice, see instructions.
NONE
MXA F 11/10/08 Form 1040 (2008)
Boxes checked 1
on 6a and 6b
No. of children
on 6c who:
0 lived with you
• did not live with
you due to divorce
or separation
(see instructions)
Dependents on 6c
not entered above
Add numbers
C
Form W' R COPY - DO NOT FlL6D021095.ETR 901 2008.07 193-36-3892 D-'3 C
Tax and 38 Amount from line 37 (adjusted gross income) . . . . . . . . . . . . . . . . . . . . . 38
re it 39 a Check ® You were born before January 2, 1944, ? Blind.1 Total boxes
Standard if: ? Spouse was born before January 2, 1944. ? Blind.] checked ?39a 1
Deduction b If your spouse itemizes on a separate return or you were a dual-status alien, see instr and check here ?39b
for - c check if standard deduction includes real estates taxes or disaster loss (see instr) . ?39c ?
• People who 40 Itemized deductions (from Schedule A) or your standard deduction (see left margin) . . . . . 40 6,800
checked any
b
li 41 Subtract line 40 from line 38 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41 23,174
ox on
ne
42 If line 38 is $119,975 or less, or you provided housing to a Midwestern displaced individual
see
39a, 39b or 39c ,
or who can be instructions. Otherwise, multiply $3,500 by the total number of exemptions claimed on line 6d . . 42 3,500
claimed as a 43 Taxable income. Subtract line 42 from line 41. If line 42 is more than line 41, enter -0- . . . . . 43 19,674
dependent,
see instructions. 44 Tax (see instr). Check if any tax is from: a E1 F 2
?J?ct rO
• All others: PY. -
45 Alternative minimum tax (see instructions). Atta 6 1,?? V
Single or 46 Add lines 44 and 45 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ? 46 2,550
Married filing 47 Foreign tax credit. Attach Form 1116 if required. . . . . . . . . . . 47
separately, 48 Credit for child and dependent care expenses. Attach Form 2441 . 48
$5,450
Married filing 49 Credit for the elderly or the disabled. Attach Schedule R . 49
jointly or 50 Education credits. Attach Form 8863 . . . . . . . . . . . . . . . . 50
Qualifying 51 Retirement savings contributions credit. Attach Form 8880 . . . . . 51
widow(er), 52 Child tax credit (see instructions). Attach Form 8901 if required . . 52
$10,900 53 Credits from Form: a ? 8396 b ? 8839 c ? 5695
53
Head of
household, . . .
54 Other credits from Form: a ? 3800 b ? 8801 c ? 54
$8,000 55 Add lines 47 through 54. These are your total credits . . . . . . . . . . 55
lREFERFENCE10MV-64,113. 5 o h 4 nter -0- . . ? 56 2,550
Other 57 Self-employment tax. Attach Schedule SE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57
Taxes 58 Unreported social security and Medicare tax from Form: a ? 4137 b ? 8919 . . . . . . . . 58
59 Additional tax on IRAs, other qualified retirement plans, etc. Attach Form 5329 if required . . . . . 59
60 Additional taxes: a ? AEIC payments b ? Household employment taxes. Attach Schedule H 60
61 Add lines 56 through 60. This is our total tax . 00-
....................... . 61 2 550
Payments 62 Federal income tax withheld from Forms W-2 and 1099 1019 62 1,527
63 2008 estimated tax payments and amount applied from 2007 rel!urn 3
If you have a 64 a Earned income credit (EIC) . . . . . . . . . . . . . . 64a
qualifying b Nontaxable combat pay election . 64b
child, attach 65 Excess social security and tier 1 RRTA tax withheld (see instructions) 65
Schedule EIC. 66 Additional child tax credit. Attach Form 8812 . . . . . . . . . . . . 66
67 Amount paid with request for extension to file (s
e'
? 67-
C
?
68 Credits from Form: a El 2439 b El 4136 c - D NOT FILE
69 First-time homebuyer credit. Attach Form 5405 . . . . . . . . . 69
70 Recovery rebate credit (see worksheet in the instructions) . . . . . 70
71 Add lines 62 throw h 70. These are our total a m nts
.....
...
.........
? 71 1 527
Refund 72 If line 71 is more than line 61, subtract line 61 from line 71. This is the amount you overpaid . . . 72
Direct deposit? 73 a Amount of line 72 you want refunded to you. If Form 8888 is attached, check here . ? ? 73a
See instructions ? b Routing number ?c Type: ? Checking ? Savings
and fill in 73b,
73c, and 73d. ? d Account number
or Form 8888. 74 Amount of line 72 you want a lied to our 2009 estimated tax ? 74
Amount 75 Amount you owe. Subtract line 71 from line 61. For details on how to pay, see instructions . ? 7 1,023
Y W 76 Estimated tax Penalty see instructions . 7 NONE
I III a? aC(5pyerso? F,5cf }y Tur, Vth tb&IRS (see instructions)? W Yes. Complete the following. L] No
De RIME I'MN u V ry V r- I Lt. Personal identification
name ?Linda L Bear no ?(717) 554-1170 number (PIN) ?06000
Sign Under penalties of perjury, I declare that I have examined this return and accompanying schedules and statements, and to the best of my knowledge and
belief, they are true, correct, and complete. Declaration of preparer (other than taxpayer) is based on all information of which preparer has any knowledge.
Here Your signature Date Your occupation Daytime phone number
Joint return? RET I RED
See Instructions. Spouse's signature. If a joint return, both must sign. Date Spouse's occupation
Keep a copy
Paid Preparers'
Preparer's s?nature
Use Only Firm's name (or yours Jackson Hewi t
if self-employed), ' 60 NOBLE BLVD
address. and ZIP code Carlisle
Date I Check if
Preparer's SSN or PTIN
1401
17) 243-1004
Form 1040 (2008)
F 1/7/09
.ax Service
PA
Phone no.
GEORGE E. SHERIFF, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 07-5732 CIVIL TERM
SHIRLEY M, SHERIFF CIVIL ACTION- LAW
Defendant, IN DIVORCE
CERTIFICATE OF SERVICE
I, Galen R. Waltz, Esquire, hereby certify that on the 5th day of June, 2009, I served a
copy of the within Income Expense Statement of George E. Sheriff, by depositing same in the
United States Mail, first class, postage prepaid, addressed as follows:
Richard S. Friedman, Esquire
300 N. 2nd Street, Suite 402
Harrisburg, PA 17101
E. Robert Elicker, II, Divorce Master
9 N. Hanover Street
Carlisle, PA 17013
CYglel-W-altz, Esquire
Turo Law Offices
28 S. Pitt Street
Carlisle, PA 17013
(717) 245-9688
OF THE PPOT Wl'.ARY
2009 JINN -5 PM t : 16
CCUNTY
PENNSYLVANA
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 07-5732 CIVIL
State Commonwealth of Pennsylvania QOriginal Order/Notice
CO./City/Dist. Of CUMBERLAND @Amended Order/Notice
Date of Order/Notice 09/03/09 OTerminate Order/Notice
Case Number (See Addendum for case summary) OOne-Time Lump Sum/Notice
RE: SHERIFF, GEORGE E.
Employer/Withholder's Federal EIN Number Employee/Obligor's Name (Last, First, MI)
193-36-3892
Employee/Obligor's Social Security Number
SOCIAL SECURITY ADMINISTRATION 6486101875
STE 1 Employee/Obligor's Case Identifier
200 S SPRING GARDEN ST (See Addendum for plaintiff names
CARLISLE PA 17013-2578 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
$ o. oo per month in past-due child support Arrears 12 weeks or greater? Dyes ® no
$ 0.00 per month in current medical support
$ 0.00 per month in past-due medical support
$ 582.00 per month in current spousal support
$ o . oo per month in past-due spousal support
$ o . oo per month for genetic test costs
$ 0.00 per month in other (specify)
$ one-time lump sum payment
for a total of $ 582.00 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:
$ 133.94 per weekly pay period. $ 291.00 per semimonthly pay period
(twice a month)
$ 267.88 per biweekly pay period (every two weeks) $ 582 . 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 Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BY THE COURT: y'
DRO: R.J. Shadday
Service Type M
OMB No.: 0970-0154
A. Hess, Judge
Form EN-028 Rev.5
Worker ID $oINC
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
If hecked you are required to provide a copy of this form to your mployee, if yo41 r employee works in a state that is
diferent from the state that issued this order, a copy must be provi3ed 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. 8384100092
THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : E3 THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: O
EMPLOYEE'S/OBLIGOR'S NAME: SHERIFF, GEORGE E.
EMPLOYEE'S CASE IDENTIFIER: 6486101875 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
LAST KNOWN PHONE NUMBER:
FINAL PAYMENT AMOUNT-
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment,
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (CCPA) (15 U.S.C. 1673 (b)); or 2) the amounts allowed by the State or Tribe of the employee's/obligor's principal place of
employment. Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes, Social
Security taxes, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is
supporting another family and 60% of the disposable income if the obligor is not supporting another family.However, that 50% limit is
increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State, you may
deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section.
Arrears greater than 12 weeks : If the order information does not indicate whether the arrears are greater than 12 weeks, then the
employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts
allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser of
the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of the
CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amounts paid for health
care premiums in determining disposable income and applying appropriate withholding limits.
10. Additional info:
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state
that issued this order with respect to these items.
11. Send Termination Notice and
other correspondence to:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717) 240-6248 or
by internet www.childsupport.state.pa.us
Page 2 of 2
Service Type M OMB No.: 0970-0154
Form EN-028 Rev.5
Worker ID $OINC
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: SHERIFF, GEORGE E.
PACSES Case Number 446109615 PACKS Case Number
Plaintiff Name Plaintiff Name
SHIRLEY M. SHERIFF
Docket Attachment Amount Docket Attachment Amount
07-5732 CIVIL$ 582.00 $ 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
PACKS Case Number PACSES Case Number
Plaintiff Name Plaintiff Name
Docket Attachment Amount Docket Attachment Amount
$ 0.00 $ 0.00
Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB
Addendum Form EN-028 Rev.5
Service Type M OMB No.: 0970-0154 Worker I D $OINC
RLED-C*FICE
OF THE MOT HONOTARY
2009 SEP -4 PM 2: 30
CUMBL-?.?,'ij COUNTY
PENNSYLVANIA
RICHARD S. FRIEDMAN, P.C.
Richard S. Friedman, Esquire
ID #07176
300 N. 2nd Street, Suite 402
Harrisburg, PA 17101
Tel.: (717) 234-3441/Fax: (717) 232-9946
e-mail: rsf13(&Jive.com
GEORGE E. SHERIFF,
Plaintiff
V.
SHIRLEY M. SHERIFF,
Defendant.
Attorney for Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07-5732 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
PETITION FOR LEA VE TO WITHDRA WAS DEFENDANT'S COUNSEL
AND NOW comes the Petitioner, Richard S. Friedman, P.C., by Richard S. Friedman,
Esquire, seeking leave of this Honorable Court to withdraw as counsel for Defendant, Shirley M.
Sheriff, pursuant to the Rules of Professional Conduct Rule 1. 16, and avers as follows:
Petitioner is counsel of record for Defendant herein by virtue of having filed an
Entry of Appearance on November 13, 2007 and an Answer with Counterclaim.
2. Defendant has terminated Petitioner's services, as per a letter mailed September
29, 2009. A copy of the letter and envelope is attached hereto and marked as
Exhibit "A".
3. A Judge has not ruled upon any other issue in this or any related matter.
4. Opposing counsel, Galen R. Waltz, Esquire, concurs with this Petition For Leave
to Withdraw as Defendant's Counsel.
WHEREFORE, Petitioner seeks leave of this Honorable Court to terminate Petitioner's
representation of the Defendant and to withdraw his appearance as counsel in the above-
captioned matter.
Date_
Respectfully submitted,
RICHARD S. FRIEDMAN, P.C.
Rich S. Friedman, Esquire
300 .2nd Street, Suite 402
Harrisburg, PA 17101
(717) 234-3441
I ?
Shidey Sheriff. "ARPUTM 0 f!A 17
Lot 75 Spdnggarden Est.
z ? ;Carlisle PA 17015
R jG?wry
.3Oo
FI?IQDAlp/y
'V • a 'Yd st s u- l)-,e Z/o -L
#,4 P" sbu-,JZ3.d.&. 171ej
ltttfill tiilIIfill Iitittlft10111,11,'Ittttilitlitittt1tlttl1l1
GEORGE E. SHERIFF, : IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 07-5732 CIVIL TERM
SHIRLEY M. SHERIFF, : CIVIL ACTION - LAW
Defendant. IN DIVORCE
CERTIFICATE OF SERVICE
I, Richard S. Friedman, Esquire, hereby certify that on the 30th day of September, 2009, I
served a copy of the within Petition For Leave To Withdraw As Defendant's Counsel, by
depositing same in the United States Mail, first class, postage prepaid, addressed as follows:
Ms. Shirley M. Sheriff
Spring Garden Estates, Lot 75
Carlisle, PA 17015
Galen R. Waltz, Esquire
Turo Law Offices
28 S. Pitt Street
Carlisle, PA 17013
E. Robert Elicker, II, Divorce Master
9 N. Hanover Street
Carlisle, PA 17013
Rich S. Friedman, Esquire
RI ARD S. FRIEDMAN, P.C.
300 N. 2nd Street, Suite 402
Harrisburg, PA 17101
(717) 234-3441
OF7lfWMM
2009 OCT -1 11 . b 8
"I'll;. Eau c.;€?+?iY
OCT 0 2 2009 6
GEORGE E. SHERIFF, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 07-5732 CIVIL TERM
SHIRLEY M. SHERIFF, CIVIL ACTION - LAW
Defendant. IN DIVORCE
RULE TO SHOW CAUSE
AND NOW, this 2;+-day of 009, upon consideration of the
foregoing Petition for Leave to Withdraw as Defendant's Counsel, the Court grants a Rule to
Show Cause why the appearance of Richard S. Friedman, Esquire, and Richard S. Friedman,
P.C., on behalf of Defendant should not be allowed to be withdrawn.
RULE RETURNABLE WITHIN 1, o DAYS FROM THE DATE OF
SERVICE OF THIS RULE.
BY THE CO
J.
HLED-OrF CE
OF THE PRA" ICNOTARY
2009OCT -6 AM 9: 59
•-yl t `tL.V - iifi..
/o/4,/6Y jEZ , en
?.?.. 194 4-,t ?. t.t)17, 62,
RICHARD S. FRIEDMAN, P.C.
Richard S. Friedman, Esquire
ID #07176
300 N. 2nd Street, Suite 402
Harrisburg, PA 17101
Tel.: (717) 234-3441/Fax: (717) 232-9946
e-mail: rsfl3klive.com
Attorney for Defendant
GEORGE E. SHERIFF, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 07-5732 CIVIL TERM
SHIRLEY M. SHERIFF, CIVIL ACTION - LAW
Defendant. IN DIVORCE
PRAECIPE
Kindly make the attached certified mail cards part of the record, indicating service upon
the Defendant and Plaintiff's counsel of the Rule to Show Cause and Petition For Leave To
Withdraw As Defendant's Counsel.
Respectfully submitted,
RICHARD S. FRIEDMAN, P.C.
Date: ' `3, &?o
T-- Richard /S. Friedman, Esquire
300 N:' 2nd Street, Suite 402
Harrisburg, PA 17101
(717) 234-3441
¦ Complete items 1, 2, and 3. Also complete
Item 4 if Restricted Delivery is desired.
¦ Print your name and address on the reverse
soffit we can return the card to you.
¦ A#tsI this card to the back of the mailpiece,
or 00 the front if space, permits.
1. Addressed to:
WAA94-1 &147j"
A.
X ?.. - rv r Agent
'V_ t Addre
B. Received by (Pointed Name) C. Date of Deli
1/0- o? c
D. Is delivery address different from Item 1? ? Yes
if YES, enter delivery address below: ? No
3. Service Type
?ls ?ertifled Mail ? Express Mail
? Registered etum Receipt for Merchandise
? Insured Mail C.O.D.
4. Restricted Delivery? (Extra Fee) ? Yes
2. Article Number 7008 1140 0003 9595 9 711
(Transfer from service label)
PS Form 3811, February 2004 Domestic Return Receipt
¦ Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
¦ Print your name and address on the reverse
so that we can return the card to you.
¦ Attach this card to the back of the mailpiece,
or on the front if space permits.
1. ArticlwAddressed to:
V-1 t ??3
A. I
X
102595-02-M-1540
' "ent
B. R$t:eived by (printed Name)(C. Data f C
D. Is delivery address diffe t from item 1? Yes
If YES, enter delivery address below: ? No
3. epylce Type
Permed Mail ? Mail
? Registered etum Receipt for Merchandise
? Insured Mail ? C.O.D.
4. Restricted Delivery? (Extra Fee) ? Yes
2. Article Number
(Transfer from service label) 7008 1140 0003 9595 9704
PS Form 3811, February 2004 Domestic Return Receipt
102595-02-M-1540
4
GEORGE E. SHERIFF,
Plaintiff
V.
SHIRLEY M. SHERIFF,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07-5732 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
CERTIFICATE OF SERVICE
I, Richard S. Friedman, Esquire, hereby certify that on the 13th day of October, 2009, I
served a copy of the within Praecipe, by depositing same in the United States Mail, first class,
postage prepaid, addressed as follows:
Ms. Shirley M. Sheriff
Spring Garden Estates, Lot 75
Carlisle, PA 17015
Galen R. Waltz, Esquire
Turo Law Offices
28 S. Pitt Street
Carlisle, PA 17013
E. Robert Elicker, II, Divorce Master
9 N. Hanover Street
Carlisle, PA 17013
Richard . Friedman, Esquire
RICHA S. FRIEDMAN, P.C.
300 N. 2nd Street, Suite 402
Harrisburg, PA 17101
(717) 234-3441
vuM0' t L ; ;u COUNRY
PET"S,,UVA NA
RICHARD S. FRIEDMAN, P.C.
Richard S. Friedman, Esquire
ID #07176
300 N. 2nd Street, Suite 402
Harrisburg, PA 17101
Tel.: (717) 234-3441/Fax: (717) 232-9946
e-mail: rsfl3glive.com
Attorney for Defendant
GEORGE E. SHERIFF,
Plaintiff
V.
SHIRLEY M. SHERIFF,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07-5732 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
MOTION TO MAKE RULE TO SHOW CAUSE ABSOLUTE
Richard S. Friedman, Esquire, respectfully requests this Court to make absolute the Rule
to Show Cause which was issued in the above-captioned matter on October 5, 2009, and in
support states the following:
1. A Petition for Leave to Withdraw as Defendant's Counsel was filed by the
Petitioner on October 1, 2009.
2. The Rule to Show Cause was issued on October 5, 2009, and was served on Galen
R. Waltz, Esquire, attorney for Plaintiff, and Shirley Sheriff, Defendant. See copies of the
Domestic Return Receipts attached hereto as Exhibit "A".
3. To date, no response has been forthcoming from the Defendant or Attorney Waltz
to this Honorable Court's Rule to Show Cause.
WHEREFORE, Petitioner respectfully requests that this Court make the Rule to Show
Cause Absolute.
Date: 0?1?, I On)
Respectfully submitted,
RICHARD S. FRIEDMAN, P.C.
Richard S. Friedman, Esquire
300 N. 21ld Street, Suite 402
Harrisburg, PA 17101
(717) 234-3441
¦ CoQmpldft items 1, 2, arid & Also-corrlplete
item 41 Restricted Delivery 4 des(red.
¦ print name and address on the reverse
sa= can.'. return the card to you.
this, card'to the tack of the mallpiece,
or11
efront ff spaoe.pemdts
1. ArIMAddressed to:
6t? "-- je4-1-bK
2. ArtldeMxnbw 7008 1140 0003 9595 9711
(liarrslfar Avm service i?
PS Form 3811, Fewtiary 2004 DOmsetlc Return Receipt 102596,02 WI5 0
¦ Complete Iberfts 1.2. and & Also complete
Item 4 if Restricted Delivery is desired.
¦ Print your name and address on the reverse
so tha;•:we can return the card to you.
¦ Attach tMs card to the back of the mallpiece,
or on the front N space permits.
1. ArboWAddressed to.
Gay , P?4 i??3
A.
X- - .?-. - Agent
Addressee
'Th B. Received by (PAW Name) C. Date Of Delivery
LAO- 0Q 09,
D. Is delivery eddrese dilfererk twn Rem-1? 0 lies
If YES, enter delivery add?ee 1 below: ? No
3. Service Type
ertliled Mall ? A; Ron Mail
fiegfalered
WAWm Receipt for Mere
?:lnsured Mal
13 C.O.D.
4. Restricted DeWay? Sidra Feel 01fes
A.
X
B. Rilbenred by (f4irled Name)U 1 C.
D. Is dellmy address dilfere/k tram Item 1? M Yei
If YES, enter delivery address below: ? No
3. )=I We
Mail ? EmaseMd
0 Registered atrmr Receipt for Merchandise
? Irmired Mail ? C.O.D.
4. Restricted Deilvery'1 extra Fee) 0 Yes
2. Article n
(Trz r from m service label) 7008 1140 0003 9595 9704
PS Form 3$11, February 2004 Domestic Return Receipt 10-Wis4o r
GEORGE E. SHERIFF,
Plaintiff
V.
SHIRLEY M. SHERIFF,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07-5732 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
CERTIFICATE OF SERVICE
I, Richard S. Friedman, Esquire, hereby certify that on the 20th day of October, 2009, I
served a copy of the within Motion to Make Rule to Show Cause Absolute, by depositing same
in the United States Mail, first class, postage prepaid, addressed as follows:
Ms. Shirley M. Sheriff
Spring Garden Estates, Lot 75
Carlisle, PA 17015
Galen R. Waltz, Esquire
Turo Law Offices
28 S. Pitt Street
Carlisle, PA 17013
E. Robert Elicker, II, Divorce Master
9 N. Hanover Street
Carlisle, PA 17013
RICTAli yS. FRIEDMAN, P.C.
300 N. 2nd Street, Suite 402
Harrisburg, PA 17101
(717) 234-3441
ni..
-ARY
2009 C!C 2 # f"1112-: 4 9
r f:
M. 4
OCT 2 2 200,Q
GEORGE E. SHERIFF, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 07-5732 CIVIL TERM
SHIRLEY M. SHERIFF, CIVIL ACTION - LAW
Defendant. IN DIVORCE
ORDER
AND NOW, this _2:.4_ day of October, 2009, upon consideration of the Petition for
Leave to Withdraw as Defendant's counsel, and Rule to Show Cause, and there being no
opposition thereto, it is hereby
ORDERED and DECREED that said Petition is granted and that Petitioner, Richard S.
Friedman, Esquire, and the firm of Richard S. Friedman, P.C., be permitted to withdraw their
appearance of record for the Defendant in the above matter and the Prothonotary shall so mark
the docket.
DISTRIBUTION:
hard S. Friedman, Esq., 300 N. 2°a Street, Ste. 402, Harrisburg, PA 17101, (717) 234-3441
?en R. Waltz, Esq., 28 S. Pitt St., Carlisle, PA 17013, (717) 245-9688
-`-Shirley Sheriff, Spring Garden Estates, Lot 75, Carlisle, PA 17015
t" rnat l?k
?v z? 1 vr'
0? MV
2MlOGt 26 MME'S {
GEORGE E. SHERIFF,
Plaintiff,
V.
SHIRLEY M. SHERIFF,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07 - 5732 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
STIPULATION TO ENTRY OF QUALIFIED DOMESTIC RELATIONS ORDER
George E. Sheriff and Shirley M. Sheriff, parties hereto, stipulate to the entry of
the foregoing being entered as a Qualified Domestic Relations Order.
r
George E. Sheriff
AI
Shirley M. Sh ff
636- n ok
Witness
/01// -7&!?
Date
t . IAP,
2Gv GEC 2" 9
1': ;: i ,r
GEORGE E. SHERIFF, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 07 - 5732 CIVIL TERM
SHIRLEY M. SHERIFF, : CIVIL ACTION - LAW
Defendant. : IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on
October 1, 2007.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of the filing of the Complaint.
3. 1 consent to the entry of the final Decree in Divorce after service of Notice
of Intention to request entry of the decree.
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.
/.112 d
Date
Shirley M. S
3 t L"
alt 7 DEC 2 a
t a?`1
a
t
0 ) 5-7 3,-2-
4
MARRIAGE SETTLEMENT AGREEMENT
AGREEMENT MADE this '71'- day of DerL?-M13EX , 2009, by and
between GEORGE E. SHERIFF ("Husband") of 95 Spring Garden Estates, Carlisle,
Cumberland County, Pennsylvania - A N D - SHIRLEY M. SHERIFF ("Wife"), of Spring
Garden Estates, Lot 75 Carlisle, Cumberland County, Pennsylvania.
WHEREAS, the parties hereto are husband and wife having been married on
January 28, 1994.
WHEREAS, diverse unhappy differences, disputes and difficulties have arisen
between the parties and it is the intention of Wife and Husband to live separate and
apart for the rest of their natural lives, and the parties desire to settle fully and finally
their respective financial and property rights and obligations as between each other
including, without limitation by specification: settling of all matters between them relating
to the ownership and equitable distribution of real and personal property; settling of all
matters between them relating to the past, present and future support, alimony and/or
maintenance of Wife by Husband or of Husband by Wife; and in general, the settling of
any and all claims and possible claims by one against the other or against their
respective estates.
NOW, THEREFORE, in consideration of the foregoing 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, Husband
and Wife, each intending to be legally bound hereby, covenant and agree as follows:
1. Divorce and Separation. The parties agree to the entry of a decree in
divorce pursuant to Section 3301(c) of the Divorce Code of 1980. Husband and Wife
shall at all time hereafter have the right to live separate and apart from each other and
to reside from time to time at such place or places as they shall respectively deem fit,
free from any control, restraint, or interference whatsoever by the other. Neither party
shall molest the other or endeavor to compel the other to cohabit or dwell with him or
her by and legal or other proceedings. The foregoing provision shall not be taken to be
an admission on the part of either Husband or Wife of the lawfulness or unlawfulness of
the causes leading to their living apart.
..a
The parties acknowledge that a divorce action has been filed in the Court of
Common Pleas of Cumberland County, Pennsylvania at docket number 07-5732. The
parties agree that they will execute and file Affidavits of Consent and Waivers of Notice
of Intention to Request Entry of a Divorce Decree simultaneously with the signing of this
document. Thereafter, counsel for Husband shall file a Praecipe to Transmit Record
and obtain a divorce decree.
2. Division of Property. Husband and Wife agree that the following
constitutes an equitable distribution of the marital property.
A. Husband's Property. The following property shall become the
sole and exclusive property of Husband:
1. All right, title and interest in the mobile home situate at 95
Spring Garden Estates, Carlisle, Cumberland County, Pennsylvania.
2. Wife agrees to sign a transfer of title to Husband for the
mobile home upon request of Husband.
B. Wife's Property. The following property shall become the sole and
exclusive property of Wife:
1. All right, title and interest in the life insurance policies titled in
Wife's name.
C. Payment from Pension. Husband agrees to pay to Wife the lump
cash sum of $286.00 from his pension account. Husband shall, through the use
of a Qualified Domestic Relations Order, transfer to Wife the sum of $286.00.
Husband shall keep as his separate property the remaining interest in his
pension plan. Husband acknowledges Wife's status as survivor beneficiary of
Husband's pension.
D. Tangible Personal Property. Each party will retain the tangible
personal property already in his or her possession and waive any claim against
the other for tangible personal property.
E. Satisfactory Division of Marital and Non-Marital Property.
Husband and Wife hereby acknowledge that they have divided, to their mutual
satisfaction, all of their marital and non-marital assets, including but without
limitation, business interests, partnerships, inheritances, jewelry, clothing,
pensions, brokerage accounts, stocks, bonds, life insurance policies or other
2
3
securities, individual retirements accounts, 401(k), employment benefits,
checking and savings accounts, mutual funds and other assets, whether real,
personal or mixed, tangible or intangible.
3. Marital Residence. The parties acknowledge that they are the owners of
the mobile home situate at 95 Spring Garden Estates, Carlisle, Cumberland County,
Pennsylvania 17013 (hereinafter "Marital Home"). Husband shall become the sole and
exclusive owner of the Marital Home and shall be permitted to take any action with
respect thereto that he deems appropriate. Wife hereby waives, relinquishes and
releases any and all past, present or future right, title, claim and/or interest she may
have in and to the Marital Home. Wife shall, at Husband's request, execute a deed or
any other necessary document transferring all of her right, title and interest in the Marital
Home to Husband. Wife agrees that as of the date of execution of this Agreement, any
and all title policies and any other policies of insurance with respect to the Marital Home
shall be endorsed to reflect Husband as the sole owner thereof and further agrees that
husband shall be entitled to receive any payments now or hereafter due under such
insurance policies.
Commencing on the execution date of this Agreement, Husband shall be solely
and exclusively responsible for all costs, expenses and liabilities associated with or
attributable to the Marital Home, including, but not limited to, any mortgages, any and all
home equity loans or lines of credit, taxes, insurances premiums, utilities, maintenance
and repairs. Husband shall keep Wife and her successors, assigns, heirs, executors
and administrators indemnified and held harmless from any liability, costs or expense,
including actual attorneys fees, which may be incurred in connection with such liabilities
and expenses or resulting from Husband's ownership interest in the Marital Home. If
husband refuses to indemnify Wife for any such expenses, Wife is entitled to recover
from Husband all costs, expenses and legal fees incurred in enforcing Husband's duty
to pay the expenses.
4. Taxes. Both parties agree that in the event any deficiency in federal, state
or local income tax is proposed, or any assessment of any such tax is made against
either of them, each will indemnify and hold harmless the other from and against any
loss or liability for any such tax deficiency or assessment and any interest, penalty and
expense incurred in connection therewith. Such tax, interest, penalty or expense shall
3
46
Y
be paid solely and entirely by the individual who is finally determined to be the cause of
the misrepresentations or failures to disclose the nature and extent of his or her
separate income on the aforesaid joint returns.
5. Additional documentation. The parties agree to execute any deeds,
assignments, titles or other instruments necessary and appropriate to accomplish the
aforesaid division of property.
6. Representations and Warranties. The parties represent and warrant to
each other that the property described in this Agreement represents all of the property
in which they have any right, title and interest, and that such property is subject to no
mortgage, pledge, lien, security interest, encumbrance or charge except those which
are disclosed herein.
7. Equitable Division. By this Agreement the parties have intended to
effect an equitable division of their jointly owned property. The parties have determined
that an equitable division of such property conforms to a just and right standard, with
due regard to the rights of each party. The division of existing marital property is not
intended by the parties to constitute in any way a sale or exchange of assets, and the
division is being effected without the introduction of outside funds or other property not
constituting a part of marital estate. It is the intention of the parties to treat all transfers
herein as non-taxable.
8. Relinquishment of Rights. Except as expressly provided herein,
Husband forever relinquishes any right, title or interest he may now or hereafter have in
any tangible or intangible assets now belonging to Wife, and Wife forever relinquishes
any right, title or interest he may now or hereafter have in any tangible or intangible
assets now belonging to Husband.
9. After-Acquired Property. Each of the parties shall hereafter own and
enjoy independently of any claim of right of the other, all items or property, be they real,
personal or mixed, tangible or intangible, which are hereafter acquired by him or her,
with full power in him or her to dispose of the same as fully and effectively, in all
respects and for all purposes as though he or she were unmarried.
10. Debts. Husband and Wife shall each be solely responsible for all debts in
their respective names, including but not limited to personal loans, charge accounts or
credit cards. Both parties represent and warrant to the other that as of the date of this
4
0
4
Agreement they have not incurred, and in the future will not contract or incur, any debt
or liability for which the other or the estate of the other might be responsible.
Husband agrees to waive claims against wife for (a) a credit card debt in the
amount of $1,200.00 and (b) reimbursement of a handwriting expert fee in the amount
of $650.00.
11. Liabilities. All debts, contracts, obligations or liabilities incurred at any
time in the past or future by either party will be paid promptly by said party, unless and
except as otherwise specifically set forth in this Agreement; and each of the parties
hereto further promises, covenants and agrees that each will now and at all time
hereafter save harmless and keep the other or his or her estate indemnified and save
harmless from all debts or liabilities incurred by him or her, as the case may be, and
form all actions, claims and demands whatsoever with respect thereto, and from all
costs, legal or otherwise, and counsel fees whatsoever pertaining to such actions,
claims and demands. Neither party shall, as of the date of this Agreement, contract or
incur any debt or liability for which the other or his or her property may be responsible,
and shall indemnify and save harmless the other from any and all claims or demands
made against him or her by reason of debts or obligations incurred by him or her and
from all expenses, legal costs, and counsel fees unless provided to the contrary herein.
12. Counsel Fees, Costs and Expenses. Each party shall be responsible
for his or her own legal fees, costs and expenses incurred in connection with their
separation and/or the dissolution of their marriage.
13. Alimony. Husband agrees to pay and Wife agrees to accept $500.00 per
month in cash.
14. Full Disclosure. The respective parties to hereby warrant, represent and
declare and do acknowledge and agree that each is and has been fully and completely
informed of and is familiar with and cognizant of the wealth, real and/or personal
property, estate and assets, earnings and income of the other and that each has made
a full and complete disclosure to the other of his or her entire assets and liabilities and
any further enumeration or statement thereof in this Agreement is specifically waived.
15. Releases. Each party does hereby remise, release, quitclaim and forever
discharge the other and the estate of the other from any and every claim that each other
may now have, or hereafter have or can have at any time, against the other, or in and to
5
or against the other's estate, or any part thereof, whether arising out of any former
contracts, engagements or liabilities of the other, or by way of dower or claim in the
nature of dower, widow's rights, or under the intestate laws, or the right to take against
the other's will, or for support or maintenance, or of any other nature whatsoever,
except any rights accruing under this Agreement.
16. Indemnification. Each party represents and warrants to the other that he
or she has not incurred any debt, obligation, or other liability, other than described in
this Agreement, on which the other party is or may be liable. Each party covenants and
agrees that if any claim, action or proceeding is hereinafter initiated seeking to hold the
other party liable for any other debts, obligations, liability, act or omission of such party,
such party will at his or her sole expense, defend the other against any such claim or
demand, whether or not well-founded, and that he or she will indemnify and hold
harmless the other party in respect to all damages as resulting therefrom. Damages as
used herein shall include any claim, action, demand, loss, cost, expense, penalty, and
other damage, including without limitation. counsel fees and other costs and expenses
reasonable incurred in investigating or attempting to avoid same or in opposing the
imposition thereof or enforcing this indemnity, resulting to Husband or Wife from any
inaccurate representation made by or on behalf of either Husband or Wife to the other in
this Agreement, any breach of any of the warranties made by Husband or Wife in this
Agreement, or breach or default in performance by Husband or Wife of any obligations
to be performed by such party hereunder. The Husband or Wife to give the other
prompt written notice of any litigation, threatened or instituted against either party which
might constitute the basis for a claim or indemnity pursuant to the terms of this
Agreement.
17. General Provisions. This Agreement constitutes the entire
understanding of the parties and supercedes any and all prior agreements and
negotiations between them. There are no representations or warranties other than
those expressly set forth herein.
18. Breach. It is expressly stipulated that if either party fails in the due
performance of any of his or her material obligations under this Agreement, the other
party shall have the right, at his or her election, to sue for damages for breach thereof,
to sue for specific performance, or to seek any other legal remedies as may be
6
available, and the defaulting party shall pay the reasonable legal fees for any services
rendered by the non-defaulting party's attorney in any action or proceeding to compel
performance hereunder.
19. Execution of Documents. Each party shall on demand execute any
other documents that may be necessary or advisable to carry out the provisions of this .
Agreement.
20. Modification. No modification, rescission or amendment to this
Agreement shall be effective unless in writing signed by each of the parties hereto.
21. Severability. If any provision of this Agreement is held by a court of
competent jurisdiction to a void, invalid or unenforceable, the remaining provisions
hereof shall nevertheless survive and continue in full force and effect without being
impaired or invalidated in any way.
22. Applicable Law. This Agreement shall be construed under the laws of
the Commonwealth of Pennsylvania.
23. Agreement Not to be Merged. This Agreement may be filed with the
Court for incorporation into the Decree of Divorce for purposes of enforcement only, but
otherwise shall not be merged into said Decree. The parties shall have the right to
enforce this Agreement under the Divorce Code of 1980, as amended, and in addition,
shall retain any remedies in law or in equity under this Agreement as an independent
contract. Such remedies in law or in equity are specifically not waives or released.
IN WITNESS WHEREOF, the parties have set their hands and seals the day and
year first above written.
George E. Sheriff
n
Shirley M. Sheri
7
Witness:
4
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF COrAbeZ1A^0
Personally appeared before me, a Notary Public in and for the aforesaid
Commonwealth and County, GEORGE E. SHERIFF, who being duly sworn according to
law deposes and says that he is a party of the foregoing Agreement and he executed
the same for the purposes therein contained.
Witness my and seal this 9 Rday of ec ems, 2009.
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
James M. Robinson, Notary Public
Carlisle Boro, Cumberland County
My Commission Expires June 6, 2013
Member, Pennsylvania Assucittion of Notaries
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF
Public
mission Expires:
ss.
Personally appeared before me, a Notary Public in and for the aforesaid
Commonwealth and County, SHIRLEY M. SHERIFF, who being duly sworn according
to law deposes and says that she is a party of the foregoing Agreement and she
executed the same for the purposes therein contained.
Witness my and seal this 174h
day of , 2009.
COMMONWEALTH R PINNSYLVANIA
Notarial Seal
Lisa M. Warner, Notary Public to Public
Carlisle Boro, Cumberiand County
My Commission Expires Feb. 5, 2013
Member, Pennsylvania Association of Notari
My Commission Expires: Frbkua j 5 )bI3
8
A
1
•
DEC 3 0 2009
GEORGE E. SHERIFF, : IN THE COURT OF COMMON LEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 07 - 5732 CIVIL TERM
SHIRLEY M. SHERIFF, : CIVIL ACTION - LAW
Defendant. : IN DIVORCE
AND NOW, this t" _ day of a4 -/v p 2 y , 201 q , upon consideration of
the within Stipulation for Entry of a Qualified Domestic Relations
hereby entered as a Qualified Domestic Relations Order:
PENSION PLAN FOR THE FROG, SWITCH & MANUFACTU
§ 1. Definitions. For the purposes of this section 1 and the folio
3 of this domestic relations order, the following terms, when used
letters, shall have the following meanings.
§1.1. Account - The Participant's entire interest in the Plan
vested.
§ 1.2. Alternate Payee - The following person:
Name:
Last known mailing address:
Social Security No.:
Date of Birth:
, the following is
COMPANY
sections 2 through
initial capital
or not
Shirley M. Sh riff
Spring Garde Estates, Lot 75
Carlisle, PA 1 013
192-34-6439
06/15/1942
§ 1.3. Distribution Date - Distribution will be made as soon s administratively
feasible after the Plan Administrator formally and finally determines hat this domestic
relations order constitutes a qualified domestic relations order and all appropriate time
for appeals under the claims procedure of the Plan applicable to do estic relations
orders has expired.
§ 1.4. Participant - The following person:
Name:
Last known mailing address:
Social Security No.:
Date of Birth:
George E. Sh riff
95 Spring Gar en Estates
Carlisle, PA 1 013
193-36-3892
01/16/1943
r
§ 1.5. The Plan - The defined benefit plan from The Pensi n Plan for Production
and Maintenance Employees of The Frog, Switch & Manufacturing ?Company.
§ 1.6. Plan Administrator - The following:
Wachovia Bank, N.A.
Wachovia Retirement Services
VA9412
9020 Stony Point Parkway
Suite 200
Richmond, VA 23235
§ 2. Award to Alternate Payee.
§ 2.1. Time and Amount of Payment. As soon as admini
the Distribution Date, the Plan Administrator shall cause the truste
distribute to the Alternate Payee Two Hundred and Eighty-Six ($2
Account irrespective of the Participant's Vested Account as of the
amount awarded to the Alternate Payee shall be adjusted for inve
losses from the date of this Order to the Distribution Date.
§ 2.2. Form of Payment. Distribution from the Account to
shall be made in a single lump sum payment in cash. The Alterni
permitted to elect any other form or time of distribution even if it W
available under the Plan. Upon the completion of this distribution
the Plan shall have no further obligation to make any further distril
Account to the Alternate Payee.
§ 3. Miscellaneous Procedural Provisions. Upon entry relations order, the Alternate Payee shall deliver to the Plan Admini
copy of this domestic relations order and shall simultaneously furnis
evidence of such delivery. The Alternate Payee shall notify in writin
administrator and/or trustee of the Plan of any changes in her mailir
Alternate Payee shall be responsible for a payment of all state and 1
on amounts awarded to and paid to the Alternate Payee under this
order. The Alternate Payee shall file all elections, applications or otl
the Plan Administrator in connection with the distribution contemplal
relations order. The Participant shall cooperate fully with the Plan a
Payee in executing such documents and taking all other actions whi
necessary or required by the Plan Administrator for the purpose of c
distribution to the Alternate Payee which is contemplated by this dor
order. The Participant and the Alternate Payee may notify the Plan
writing that copies of notices to the Participant or the Alternate Paye
be, should be sent to a designated representative. Upon receipt of
Administrator shall give copies of the notices sent by the Plan Admir
Participant or Alternate Payee, as the case may be, to that represen
'ativelyfffeasible after
of the Plan to
.00) Dollars of the
istribution Date. The
nent gains and/or
e Alternate Payee
Payee shall not be
Id be otherwise
the Alternate Payee,
Jons from the
this domestic
rator a certified
the Participant with
the plan
address. The
deral income taxes
)mestic relations
;r forms required by
d by this domestic
J the Alternate
i may be
using the
estic relations
dministrator in
as the case may
ich notice, the Plan
strator'to the
rtive. To the extent
Y .`
L.
that the Plan Administrator makes a reasonable and good faith of
terms of this domestic relations order in making the distribution to
contemplated by this domestic relations order, the Plan, the Plan
every fiduciary of the Plan shall be deemed to have fully satisfied
Participant and the Alternate Payee (and their successors and as
discharged from any further liability to the Participant and the Alte
successors and assigns) with respect to such distribution.
BY THE COURT,
-x
C.C. ? rin Andrew
Snyder, Esq.
Shirley M. Sheriff, Pro se
(20 p 1'es &111't L?CL
/iq 11v
t=wv
t to observe the
e Alternate Payee
Iministrator and
sir obligations to the
ns) and shall be fully
ate Payee (and their
J.
2010 JAN -4 P
OF THE LED-CF
P 0TARY
2010 JAN -6 PM 1: IS
GEORGE E. ?H ,R
Plainti PENNSYLVANjl `?`'?t3Y
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
SHIRLEY M. SHERIFF
Defendant
NO. 07- 5732 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
AFFID"IT OF CONSENT
1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on
October 1, 2007.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of the filing of the Complaint.
3. 1 consent to the entry of the final Decree in Divorce after service of Notice
of Intention to request entry of the decree.
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.
) Z-3z)o - 5:ff '411
Date George E. Sheriff
(? THE PRO-CIFFACE
ROTHONOTARY
2010 JAN -6 Pm 1: 15
GEORGE LCfD C,'OUNTY
Plaintiff N$YLVANIA
V.
SHIRLEY M. SHERIFF
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07-5732 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
§ 3301(c) OF THE DIVORCE CODE
1. 1 consent to the entry of a final Decree of Divorce without notice.
2. 1 understand that I may lose rights concerning alimony, division of
property, lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. 1 understand that I will not be divorced until a Divorce Decree is entered by
the Court and that a copy of the decree will be sent to me immediately after it is filed
with the Prothonotary.
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.
ll ?
Date George E. Sheriff
iz-
GEORGE E. SHERIFF, : IN THE COURT OF COMMON
AS
Plaintiff, : CUMBERLAND COUNTY
PENN* t"ifA n,?
:--
,
co ?ijc;
v. : NO. 07 - 5732 CIVIL TERM
SHIRLEY M. SHERIFF, : CIVIL ACTION - LAW= `•
Defendant. : IN DIVORCE
PETITION TO VACATE APPOINTMENT OF DIVORCE MASTER
AND NOW, comes George E. Sheriff, Plaintiff, by and through his attorneys, Turo
Robinson and files this Petition to Vacate the Master, averring the following:
1. Petitioner/Plaintiff is George E. Sheriff, an adult individual currently
residing at 95 Spring Garden Estates, Carlisle, Pennsylvania 17013.
2. On April 24, 2009, Petitioner filed for the appointment of a Master in the
above captioned divorce.
3. On April 27, 2009, E. Robert Elicker, II, Esquire, was appointed as Master.
4. On December 17, 2009, the parties entered into a Property Settlement
Agreement which resolved all of the issues in the above captioned divorce.
5. As a result of the above, the appointment of the Master is no longer
required.
6. The Honorable Kevin A. Hess signed the most recent Order of Court in
this matter.
7. Shirley M. Sheriff, pro se Defendant in this matter was contacted and
concurs with this Petition.
WHEREFORE, Petitioner respectfully requests this Honorable Court to
vacate the appointment of the Master in the above captioned case.
Respectfully Submitted,
01/01/10
Date
TURO ROB[
Lorin A rew Snyder/,'Esq.
28 S. [tt Stre -
Carlisle, PA 17013
717-245-9688
CERTIFICATE OF SERVICE
I hereby certify that I served a true and correct copy of the Petition to Vacate
Master by first class, postage pre-paid and depositing same in the United States Mail,
first class, postage pre-paid on the Eighth day of January, 2010, from Carlisle,
Pennsylvania, addressed as follows:
Shirley M. Sheriff
Spring Garden Estates, Lot 75
Carlisle, PA 17013
Pro se
TURO ROBINSON
Lorin Ap(drew Sn der, Esq.
28 South Pitt Str et
Car isle, PA 170 3
71 -245-9688
Atto laintiff/Petitioner
i W
"AIV r r ?
GEORGE E. SHERIFF, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 07 - 5732 CIVIL TERM
SHIRLEY M. SHERIFF, : CIVIL ACTION - LAW
Defendant. : IN DIVORCE
ORDER OF COURT
AND NOW, this /z ` day of 2010, after review of the
Petition to Vacate Appointment of Master, the appointment of the Master is vacated and
the parties can conclude the proceedings by the filing of a Praecipe to Transmit the
Record so that a final decree in divorce can be entered.
By the Court,
C.C. Lo
rin A. Snyder, Esq.
Shirley M. Sheriff, pro se
?rr
, f16
n 4
mot? f.' (.,,, --1
<
l
-
ib
i r
C Q ?i
GEORGE E. SHERIFF,
Plaintiff
VS.
SHIRLEY M. SHERIFF,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07 - 5732 CIVIL
IN DIVORCE
ORDER OF COURT
AND NOW, this Mt4 day of ,
2010, the economic claims raised in the proceedings having been
resolved in accordance with a marriage settlement agreement
dated December 17, 2009, 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,
'A. Hess, P.J.
' 7
cc:
Galen R. Waltz
Attorney for Plaintiff C-)
? Shirley M. Sheriff
=
Defendant (Pro Se) Mii
J; . n
?£s M.-a [L4.GL
Ca
r
` ho w
GEORGE E. SHERIFF,
Plaintiff,
V.
SHIRLEY M. SHERIFF,
Defendant.
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
r-4
NO. 07 - 5732 CIVIL TERM c o
rat ? .?•
CIVIL ACTION - LAW :-1_,
IN DIVORCE `r'"
PROOF OF SERVICE
PM
¦ Complete items 1, 2, and 3. Also COMOWA ° e
Nsrn 4 if Restricted Delivery Is desired: `µ -• _ _
¦ Print your name and address on the reverse
so that we can return the card to you.
¦ Attach this card to the back of the mailpiece,
or on the front If space permits.
1. Article Addressed to: Q
A. SignadaW_j
x $ * -41
B. Received by (
T
Delivery
D. Is delivery address ditw t from item 1? ? Yes
If YES, enter delivery address below: ? No
3. Service Type
13 Certifled Mail ? Express Mail
? Registsied ? Return Receipt for Mercl*ndlee
? insured mail ? c.o.D.
4. Restricted Delivery? (Extra Fes) ? Yes
2. Article Number 7006 2760 0002 7413 8234
(riangw from servte label) _
PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540
-r
Ci7 -=7
=? tJ
fJ rri
-c
GEORGE E. SHERIFF, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 07 - 5732 CIVIL TERM
SHIRLEY M. SHERIFF, : CIVIL ACTION - LAW
Defendant. : IN DIVORCE
PRAECIPE TO TRANSMIT RECORD c3
2-
1
TO THE PROTHONOTARY:
Transmit the record, together with the following information to e OdUrt ~r entry
of a Divorce Decree: Q^
1. Ground for divorce: Irretrievable breakdown under § 3301(c) of the
Divorce Code.
2. Date and manner of service of Complaint: First Class, Certified, Returned
Receipt mail delivered to Defendant on or about October 2, 2007.
3. Date of execution of Affidavit of Consent:
By Plaintiff: January 6, 2010
By Defendant: December 17, 2009
4. Related claims pending: None.
5. Date the Waiver of Notice was filed with the Prothonotary:
By Plaintiff:
By Defendant:
January 6, 2010
December 29, 2009
Respectfully Submitted,
TURO LAW OFFICES
01 14 ?2 o10
Date
1-6 Andrew Sn)
2 S. Pitt Street
rlisle, PA 1701
7 7-245-9688
GEORGE E. SHERIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
SHIRLEY M. SHERIFF
: NO. 2007-5732 CIVIL TERM
DIVORCE DECREE
AND NOW, oMr V 40 it is ordered and decreed that
GEORGE E. SHERIFF plaintiff, and
SHIRLEY M. SHERIFF , 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.")
The economic issues in this case have been resolved by an agreement of the parties dated
December 17, 2009, which is incorporated into, but shall not merge with, this decree.
By the Court,
Attest:
Prothonotary
6
a4
GEORGE E. SHERIFF,
Plaintiff,
V.
SHIRLEY M. SHERIFF,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07 - 5732 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
STIPULATION TO ENTRY OF QUALIFIED DOMESTIC RELATIONS ORDER
George E. Sheriff and Shirley M. Sheriff, parties hereto, stipulate to the entry of
the foregoing being entered as a Qualified Domestic Relations Order.
r
George E. Sheriff
Shirley M. S
Witness ,
IJdLU
?z ? q ?/ /d
Date
? o
o -n
"?? tT 3
.
... C..,
cn
ca'.
MAR 0 52010
GEORGE E. SHERIFF, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
C--
-;,
V. : NO. 07 - 5732 CIVIL TERM
SHIRLEY M. SHERIFF, : CIVIL ACTION - LAW
;?. _ P
Defendant. : IN DIVORCE
QUALIFIED DOMESTIC RELATIONS ORDEKi c- c R
AND NOW, this day of ?,.al , 2010, upon corfsideration of
the within Stipulation for Entry of a Qualified Domestic Relations Order, the following is
hereby entered as a Qualified Domestic Relations Order:
All previous Domestic Relations Orders in this matter relative to the Pension Plan
for the Frog, Switch & Manufacturing Company are hereby vacated.
PENSION PLAN FOR THE FROG, SWITCH & MANUFACTURING COMPANY
§ 1. Definitions. For the purposes of this section 1 and the following sections 2 through
3 of this domestic relations order, the following terms, when used with initial capital
letters, shall have the following meanings.
§1.1. Account - The Participant's entire interest in the Plan whether or not
vested.
§ 1.2. Alternate Payee - The following person:
Name:
Last known mailing address:
Social Security No.:
Date of Birth:
Shirley M. Sheriff
Spring Garden Estates, Lot 75
Carlisle, PA 17013
192-34-6439
06/15/1942
§ 1.3. Distribution Date - Distribution will be made as soon as administratively
feasible after the Plan Administrator formally and finally determines that this domestic
relations order constitutes a qualified domestic relations order and all appropriate time
for appeals under the claims procedure of the Plan applicable to domestic relations
orders has expired.
§ 1.4. Participant - The following person:
Name:
Last known mailing address:
George E. Sheriff
95 Spring Garden Estates
Carlisle, PA 17013
.W
Social Security No.: 193-36-3892
Date of Birth: 01/16/1943
§ 1.5. The Plan - The defined benefit plan from The Pension Plan for Production
and Maintenance Employees of The Frog, Switch & Manufacturing Company.
§ 1.6. Plan Administrator - The following:
Plan Administrative Committee
The Frog, Switch & Manufacturing Company
600 East High Street, P.O. Box 70
Carlisle, PA 17013-0070
§ 2. Award to Alternate Payee.
§ 2.1. Time and Amount of Payment. As soon as administratively feasible after
the Distribution Date, the Plan Administrator shall cause the trustee of the Plan to
distribute to the Alternate Payee Two Hundred and Eighty-Six ($286.00) Dollars of the
Account irrespective of the Participant's Vested Account as of the Distribution Date.
§ 2.2. Form of Payment. Distribution from the Account to the Alternate Payee
shall be made in a single lump sum payment in cash. Alternate Payee's single payment
shall be deducted from one monthly pension payment of Participant (i.e., $286.00 to
Alternate Payee and $713,38 to Participant). The Alternate Payee shall not be permitted
to elect any other form or time of distribution even if it would be otherwise available
under the Plan. Upon the completion of this distribution to the Alternate Payee, the Plan
shall have no further obligation to make any further distributions from the Account to the
Alternate Payee during Participant's lifetime. Alternate Payee will remain beneficiary of
the Plan.
§ 3. Miscellaneous Procedural Provisions. Upon entry of this domestic
relations order, the Alternate Payee shall deliver to the Plan Administrator a certified
copy of this domestic relations order and shall simultaneously furnish the Participant with
evidence of such delivery. The Alternate Payee shall notify in writing the plan
administrator and/or trustee of the Plan of any changes in her mailing address. The
Alternate Payee shall be responsible for a payment of all state and federal income taxes
on amounts awarded to and paid to the Alternate Payee under this domestic relations
order. The Alternate Payee shall file all elections, applications or other forms required by
the Plan Administrator in connection with the distribution contemplated by this domestic
relations order. The Participant shall cooperate fully with the Plan and the Alternate
Payee in executing such documents and taking all other actions which may be
necessary or required by the Plan Administrator for the purpose of causing the
distribution to the Alternate Payee which is contemplated by this domestic relations
order. The Participant and the Alternate Payee may notify the Plan Administrator in
writing that copies of notices to the Participant or the Alternate Payee, as the case may
be, should be sent to a designated representative. Upon receipt of such notice, the Plan
Administrator shall give copies of the notices sent by the Plan Administrator to the
Participant or Alternate Payee, as the case may be, to that representative. To the extent
that the Plan Administrator makes a reasonable and good faith effort to observe the
terms of this domestic relations order in making the distribution to the Alternate Payee
contemplated by this domestic relations order, the Plan, the Plan Administrator and
every fiduciary of the Plan shall be deemed to have fully satisfied their obligations to the
Participant and the Alternate Payee (and their successors and assigns) and shall be fully
discharged from any further liability to the Participant and the Alternate Payee (and their
successors and assigns) with respect to such distribution.
?1-
c.c. ?
n Andrew Snyder, Esq.
Shirley M. Sheriff, Pro se
/(o
BY THE COURT,
%? ?, J.
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 07-5732 CIVIL
OOriginal Order/Notice
State Commonwealth of Pennsylvania
Co./City/Dist. of CUMBERLAND (Amended Order/Notice
Date of Order/Notice 03/09/10 OTerminate Order/Notice
Case Number (See Addendum for case summary) 00ne-Time Lump Sum/Notice
RE: SHERIFF, GEORGE E.
Employer/Withholder's Federal EIN Number Employee/Obligor's Name (Last, First, MI)
193-36-3892
Employee/Obligor's Social Security Number
SOCIAL SECURITY ADMINISTRATION 6486101875
200 S SPRING GARDEN ST Employee/Obligor's Case Identifier
CARLISLE PA 17013 (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 o
$ 0.00 per month in past-due child support Arrears 12 weeks or greater? Qv:-es no -i
. 7
$ 0.00 per month in current medical support
$ o . oo per month in past-due medical support
- o
$ o . oo per month in current spousal support
$ o. oo per month in past-due spousal support
$ 0.00 per month for genetic test costs
$ o . oo per month in other (specify)
$ one-time lump sum payment -? r:- cJ
for a total of $ o . o o 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. oo per semimonthly pay period
(twice a month)
$ 0-00 per biweekly pay period (every two weeks) $ o . 00 per monthly pay period.
REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10)
working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of
withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work
state of your employee for the 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 Employee/Obligor's Case Identifier) OR SO IAL SECURITNUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BY THE COURT:
Albert H. Mas ge
DRO: R. J. Shadday Form EN-028 Rev.5
Service Type M OMS No.: 0970-0154 Worker ID $OINC
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
E] If hecked you are required to provide a opy of this form to your gm loyee. If your employee works in a state thakis
di4erent from the state that issued this orr er, a copy must be provi?edpto 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 employeelobligor'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. 2197100277
THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : ID THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: O
EMPLOYEE'S/OBLIGOR'S NAME: SHERIFF, GEORGE E.
EMPLOYEE'S CASE IDENTIFIER: 6486101875 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 employeelobligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment,
refusing to employ, or taking disciplinary action against any employeelobligor 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 0 5 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 (717) 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.5
Service Type M OMB No.: 0970-0154 Worker ID $OINC
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: SHERIFF, GEORGE E.
PACSES Case Number 446109615 PACSES Case Number
Plaintiff Name Plaintiff Name
SHIRLEY M. SHERIFF
Docket Attachment Amount Docket Attachment Amount
07-5732 CIVIL$ 0.00 $ 0.00
Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB
PACKS 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
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
Addendum Form EN-028 Rev.5
Service Type M OMS No.: 0970-0154 Worker ID $oINC
GEORGE E. SHERIFF,
Plaintiff/Respondent
VS.
SHIRLEY M. SHERIFF,
Defendant/Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 07-5732 CIVIL TERM
IN DIVORCE
PACSES CASE: 446109615
ORDER OF COURT
AND NOW to wit, this 10Th day of March, 2010, it is hereby Ordered that the Order for
Alimony Pendente Lite is terminated, effective January 20, 2010, pursuant to the parties'
Divorce Decree.
The Alimony Pendente Lite is closed with a credit of -$1,387.50 -
- a _? r,
This O
come final twent
(20) after the mailin
of the notice ofbw
de
shall b
r
r
y
g
e
C r, Om
entry of the Order to the parties unless either party files a written demand with the r-
ati
Prothonotary's Office for a hearing de novo before the Court.
BY THE COURT:
0000-01
Albert H. Masland, J.
DRO: R.J. Shadday
xc: Petitioner
Respondent
Galen R. Waltz, Esq.
Richard S. Friedman, Esq.
Form OE-001
Service Type: M Worker: 21005