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HomeMy WebLinkAbout07-6789Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 CHRISTINE M. CZARNECKI, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. RICHARD CZARNECKI, Defendant NO. 07 _ 0789 efVi( r& .rM 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 and visitation of your children. When the grounds for a divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Domestic Relations Office at the County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 CHRISTINE M. CZARNECKI, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. G 7 - G 7"f ?w-- RICHARD CZARNECKI, CIVIL ACTION -LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Christine M. Czarnecki, an adult individual, formerly residing at 121 E. Countryside Drive, Boiling Springs, Cumberland County, Pennsylvania 17007 and whose current address is being held as confidential and undisclosed. For purposes of service, Plaintiffs notice shall be forwarded to her attorney, Barbara Sumple-Sullivan, Esquire at 549 Bridge Street, New Cumberland, Pennsylvania 17070. 2. Defendant is Richard Czarnecki, an adult individual residing at 121 E. Countryside Drive, Boiling Springs, Cumberland County, Pennsylvania 17007. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months prior to filing this complaint. 4. Pennsylvania. The Plaintiff and Defendant were married on May 22, 2000 in Harrisburg, 5. There are no children born of this marriage. 6. The parties separated on November 3, 2007. 7. There have been no prior actions for divorce or annulment between the parties. 8. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 9. Plaintiff has been advised that counseling is available and that Plaintiff has the right to request that the court require the parties to participate in counseling. COUNT I - DIVORCE NO FAULT 10. The averments in paragraphs 1 through 9, inclusive, of Plaintiffs Complaint are incorporated herein by reference thereto. 11. The marriage is irretrievably broken and no possibility of reconciliation exists. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with §3301 of the Pennsylvania Divorce Code. 2 FAULT INDIGNITIES 12. The averments in paragraphs 1 through 11, inclusive of Plaintiffs Complaint are incorporated herein by reference thereto. 13. Plaintiff is the innocent and injured party, and Defendant has offered such indignities to the person of the Plaintiff and has been mentally cruel to her so as to make her life burdensome and her condition intolerable, in violation of the marriage vows and of the laws of the Commonwealth. WHEREFORE, Plaintiff requests this Court to enter a decree in divorce in accordance with the Pennsylvania Divorce Code. COUNT II EQUITABLE DISTRIBUTION 14. The averments in paragraphs 1 through 13 of Plaintiffs Complaint are incorporated herein by reference thereto. 15. The Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties in such proportion as the Court deems just after consideration of all relevant factors. WHEREFORE, Plaintiff requests this Court to equitably divide said property in accordance 3 with Section 401(d) of the Pennsylvania Divorce Code. COUNT III SUPPORT, ALIMONY PENDENTE LITE AND ALIMONY 16. The averments in paragraphs 1 through 15, inclusive, of Plaintiffs Complaint are incorporated herein by reference thereto. 17. Plaintiff requires reasonable support to adequately sustain herself with the standard of living established during the marriage. WHEREFORE, Plaintiff requests an award of Support, Alimony and Alimony Pendente Lite. COUNT IV ATTORNEY'S FEES AND COSTS 18. The averments in paragraphs 1 through 17, inclusive, of Plaintiffs Complaint are incorporated herein by reference thereto. 19. Plaintiff is unable to sustain herself during the course of this litigation and has employed Barbara Sumple-Sullivan, Esquire as counsel, but is unable to pay the necessary and reasonable attorney's fees for said counsel, and the necessary and reasonable costs and expenses. WHEREFORE, Plaintiff requests an award of counsel's fees and expenses. 4 WHEREFORE, Plaintiff, Christine M. Czarnecki, prays this Honorable Court to enter judgment: A. Awarding Plaintiff a decree in divorce; B. Equitably distributing the marital property; C. Awarding Plaintiff support, alimony and alimony pendente lite; D. Awarding Plaintiff counsel fees, costs and expenses; and E. Awarding other relief as the Court deems just and reasonable. Dated: November 6, 2007 Barbara Sumple-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 5 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 CHRISTINE M. CZARNECKI, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 0 7- G -79 9 n,?a -rx, RICHARD CZARNECKI, CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT REGARDING COUNSELING 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not require that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A Section 4904 relating to unworn falsification to authorities. Dated:_ On Q CHRISTINE M. CZARNEC Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 CHRISTINE M. CZARNECKI, : IN THE COURT OF COMMON PLEAS Plaintiff V. RICHARD CZARNECKI, Defendant : CUMBERLAND COUNTY, PENNSYLVANIA : NO. CIVIL ACTION -LAW IN DIVORCE VERIFICATION I, Christine M. Czarnecki, hereby certify that the facts set forth in the foregoing Pleading are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Dated: _V I-A , 2007 ? CHRISTINE M. ECOKI L-3 S g ? O ? D d V- ?7 V? r f7? `?? Q Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 CHRISTINE M. CZARNECKI, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. Docket No. 07-6789 RICHARD CZARNECKI, Defendant IN DIVORCE PETITION REQUESTING HEARING ON ALIMONY PENDENTE LITE 1. Plaintiff is Christine M. Czarnecki, an adult individual, formerly residing at 121 E. Countryside Drive, Boiling Springs, Cumberland County, Pennsylvania 17007 and whose current address is being held as confidential and undisclosed. For purposes of service, Plaintiffs notice shall be forwarded to her attorney, Barbara Sumple-Sullivan, Esquire at 549 Bridge Street, New Cumberland, Pennsylvania 17070. 2. Defendant is Richard Czarnecki, an adult individual residing at 121 E. Countryside Drive, Boiling Springs, Cumberland County, Pennsylvania 17007. 3. On November 7, 2007, Petitioner filed a claim for Alimony Pendente Lite as part of her Complaint in Divorce. 4. An initial support conference is scheduled for December 5, 2007 at 1:30 p.m. on Plaintiff's spousal support claim to PACSES Case No. 200109603. -1- 5. Petitioner will need financial support pending the divorce proceedings and thereafter. 6. Petitioner requests this Petition be considered simultaneously with the prior spousal support claim. 7. A Domestic Relations Section Attachment for APL Proceedings is attached hereto as Exhibit "A." WHEREFORE, Petitioner requests a hearing be scheduled on her alimony pendente lite claim. Dated: November 13, 2007 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Supreme Court No. 32317 Attorney for Plaintiff -2- Exhibit A Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 CHRISTINE M. CZARNECKI, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. Docket No. 07-6789 RICHARD CZARNECKI, Defendant IN DIVORCE DRS ATTACHMENT FOR APL PROCEEDINGS PET ITIONER NAME Christine M. Czarnecki ADDRESS Current address is being held as confidential Prior address was 121 E. Country Side Drive, Boiling S rin s, PA BIRTH DATE November 12, 1959 SOCIAL SECURITY NUMBER 203-52-0769 HOME PHONE 717-386-0525 WORK PHONE 717-724-2167 EMPLOYER NAME Harmon Med Spa EMPLOYER ADDRESS 4076 Market Street, Cam Hill, PA JOB TTTLE/POSTTION Esthetician DATE EMPLOYMENT C0MAHNCED May, 2007 GROSS PAY $1,480.00 average bi-weekly NET PAY $1,157.02 average bi-weekly OTHER INCOME None ATTORNEY'S NAME Barbara Sumple-Sullivan, Esquire ATTORNEY'S ADDRESS 549 Bridge Street, New Cumberland, PA 17070 ATTORNEY'S PHONE NUMBER 717 774-1445 RESPONDENT NAME Richard Czarnecki ADDRESS 121 E. Count Side Drive, Boiling Springs, PA BIRTH DATE Aril 22, 1952 SOCIAL SECURITY NUMBER Unknown HOME PHONE 717-249-3255 WORK PHONE 717-787-2874 EMPLOYER NAME Harrisburg De artment of the Auditor General EMPLOYER ADDRESS Harrisburg, PA JOB =E/POSITION Accountant DATE EMPLOYMENT COMMENCED 1974 GROSS PAY $94,000.00 est. annuall NET PAY _ Unknown OTHER INCOME Football Referee-$2,000.00 est. annually PIRA-$1,000.00 est. annually ATTORNEY'S NAME Unknown ATTORNEY'S ADDRESS Unknown ATTORNEY'S PHONE NUMBER Unknown MORTGAGE INFORMATION DATE OF MARRIAGE Ma 11, 2001 PLACE OF MARRIAGE Cumberland Coun PA DATE OF SEPARATION November 3, 2007 ADDRESS OF LAST MARITAL HOME 121 E. Country Side Drive, Boiling Springs, PA DESCRIPTION OF DOCUMENT RAISING APL CLAIM Divorce Complaint DATE APL DOCUMENT FTLED November 7, 2007 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 CHRISTINE M. CZARNECKI, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 67, (o78y 8'v; c 1perm RICHARD CZARNECKI, : 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 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 and visitation of your children. When the grounds for a divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Domestic Relations Office at the County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 OWE COPY FROM RECORD' in Testimony whored, l we unto set my hano ind the sea) of said Col at Carlisle, Pa. a1. I tso_w a E - 14.1, Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 CHRISTINE M. CZARNECKI, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. RICHARD CZARNECKI, Defendant NO.O?- (0'7 8q : CIVIL, ACTION -LAW : IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Christine M. Czarnecki, an adult individual, formerly residing at 121 E. Countryside Drive, Boiling Springs, Cumberland County, Pennsylvania 17007 and whose current address is being held as confidential and undisclosed. For purposes of service, Plaintiff s notice shall be forwarded to her attorney, Barbara Sumple-Sullivan, Esquire at 549 Bridge Street, New Cumberland, Pennsylvania 17070. 2. Defendant is Richard Czarnecki, an adult individual residing at 121 E. Countryside Drive, Boiling Springs, Cumberland County, Pennsylvania 17007. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months prior to filing this complaint. 4. Pennsylvania. The Plaintiff and Defendant were married on May 22, 2000 in Harrisburg, 5. There are no children born of this marriage. 6. The parties separated on November 3, 2007. 7. There have been no prior actions for divorce or annulment between the parties. 8. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 9. Plaintiff has been advised that counseling is available and that Plaintiff has the right to request that the court require the parties to participate in counseling. COUNT I - DIVORCE NO FAULT 10. The averments in paragraphs 1 through 9, inclusive, of Plaintiffs Complaint are incorporated herein by reference thereto. 11. The marriage is irretrievably broken and no possibility of reconciliation exists. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with §3301 of the Pennsylvania Divorce Code. 2 FAULT INDIGNITIES 12. The averments in paragraphs 1 through 11, inclusive of Plaintiffs Complaint are incorporated herein by reference thereto. 13. Plaintiff is the innocent and injured parry, and Defendant has offered such indignities to the person of the Plaintiff and has been mentally cruel to her so as to make her life burdensome and her condition intolerable, in violation of the marriage vows and of the laws of the Commonwealth. WHEREFORE, Plaintiff requests this Court to enter a decree in divorce in accordance with the Pennsylvania Divorce Code. COUNT II EQUITABLE DISTRIBUTION 14. The averments in paragraphs 1 through 13 of Plaintiffs Complaint are incorporated herein by reference thereto. 15. The Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties in such proportion as the Court deems just after consideration of all relevant factors. WHEREFORE, Plaintiff requests this Court to equitably divide said property in accordance 3 with Section 401(d) of the Pennsylvania Divorce Code. COUNT III SUPPORT, ALIMONY PENDENTE ME AND ALIMONY 16. The averments in paragraphs 1 through 15, inclusive, of Plaintiffs Complaint are incorporated herein by reference thereto. 17. Plaintiff requires reasonable support to adequately sustain herself with the standard of living established during the marriage. WHEREFORE, Plaintiff requests an award of Support, Alimony and Alimony Pendente Lite. COUNT IV ATTORNEY'S FEES AND COSTS 18. The averments in paragraphs 1 through 17, inclusive, of Plaintiffs Complaint are incorporated herein by reference thereto. 19. Plaintiff is unable to sustain herself during the course of this litigation and has employed Barbara Sumple-Sullivan, Esquire as counsel, but is unable to pay the necessary and reasonable attorney's fees for said counsel, and the necessary and reasonable costs and expenses. WHEREFORE, Plaintiff requests an award of counsel's fees and expenses. 4 WHEREFORE, Plaintiff, Christine M. Czarnecki, prays this Honorable Court to enter judgment: A. Awarding Plaintiff a decree in divorce; B. Equitably distributing the marital property; C. Awarding Plaintiff support, alimony and alimony pendente lite; D. Awarding Plaintiff counsel fees, costs and expenses; and E. Awarding other relief as the Court deems just and reasonable. Dated: November 6, 2007 Barbara Sumple-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 5 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 CHRISTINE M. CZARNECKI, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. RICHARD CZARNECKI, NO. ?? - ?D'I $R CIVIL ACTION -LAW Defendant : IN DIVORCE AFFIDAVIT REGARDING COUNSELING 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not require that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A Section 4904 relating to unsworn falsification to authorities. Dated: ? ? -A ? 0-1 C'V'ct, t-.2'L 4a CHRISTINE M. CZAR NEC Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 CHRISTINE M. CZARNECKI, : IN THE COURT OF COMMON PLEAS Plaintiff v. RICHARD CZARNECKI, Defendant : CUMBERLAND COUNTY, PENNSYLVANIA NO. 0-1- (0-1 Sq CIVIL ACTION -LAW IN DIVORCE VERIFICATION I, Christine M. Czarnecki, hereby certify that the facts set forth in the foregoing Pleading are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unworn falsification to authorities. Dated: 2007 ??..;. Q?n?? CHRISTINE M. CZARNE CDO cM' ? rn n~ r CHRISTINE M. CZARNECKI, THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 07-6789 CIVIL TERM RICHARD CZARNECKI, IN DIVORCE Defendant/Respondent : PACSES CASE NO: 595109612 ORDER OF COURT AND NOW, this 14th 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 5, 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 1910.110 (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 Barbara Sumple-Sullivan, Esq. Date of Order: November 14, 2007 J. Sher ay, C nference 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 C"} ? d ? o `s7 te'a' .C yJJ J:.. s- g +.. • y t,.. A Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-14'+? CHRISTINE M. CZARNECKI, Plaintiff V. RICHARD CZARNECKI, Defendant IN THE COURT OFO Ty'OpENNSyLVANIA CUMBERLAND NO. 07 - 6789 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OE SERVICE that I served a copy of the I, Barbara Sumple-Sullivan, Esquire, do hereby certify complaint in Divorce in the above-captioned matter by United States Mail, Restricted Delivery, 2890 0002 8468 8790, Return Receipt Requested, on Mr. Richard Czarnecki, Certified No. 7004 er 19 2007 at his last known address: 121 E. Countryside Drive Boiling Springs, on Novemb , Pennsylvania 17007. The original receipts and return receip t cards are attached hereto as Exhibit I hereby certify that the facts set forth above are true and correct to the best of my wled e, information and belief. I understand that any false statements made herein are kno g cat n to authorities. subject to penalties of 18 Pa. C.S.A. §4904 relating to unsw f Dated: November 20, 2007 / Barbara Suinple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ID #32317 Attorney for Plaintiff r, I } A. S X by fik( I C- D. Is delivery address dHfererttfrom item 1? 0 If YES, enter delivery address bell!:. 3. Service TYPO ¦ certmed mail Cl Eltpmw Ma?i ? Registered 0 Return Recelpt for MerdtandMs DELIVERY ?.- insured mail oC.o.D. F . Postal Service RTIFIED MAIL RECEIPT No Irisurance Coverage Provided! estic Mail Only, -0 Bwt I p Vol co Postage $ SOM - 0070, b5 $2 ?< O Certlfled Fee . 9 P O Return Receipt Fee (Endorsement Required) 62.15 v; C3 - a Restricted Delivery Fee (Endorsement Required) ;4.10 1 ?n O -e ru Total Postage & Fees f9.87 1 p S °v tro ?C C ac ` - ------ --- ------------------------ ?eet, ?. xro.: or PO Box No. - - - yr?`,.. ?Qus.c? ?1 -_ --°- ----------------- - . ------------------------ Clly State, ZIP+4 PA I ¦ Complete items 1, 2, and 3. Also complete Nom 4 if Restricted DeOvery is desired. ¦ print your name and address on the reverse Wthat we can return the card to YOU- • Attach this card to the back of the MWIPiece, or on the front if space Permits- 1. Article Addressed to: 'MC'• t?.' c??ar? ?2?'nec.? tat ?D ±R E 411 rd T-E ?W-7 2. Amide Number (ffwx*r*x" w%b* ftw PS Form 3811, Febrimo 2004 7004 2890 0002 8468 8790 102sir-, 401.1ti40 EXHIBIT "A" C? C=3 Z ,-- z r c? M -n F T . cn 71) r= ? ? ? Cr '. ° Dn } O rn C 1 .. i G.J f -1 CHRISTINE M. CZARNECKI, Plaintiff/Petitioner VS. RICHARD CZARNECKI, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 07-6789 CIVIL TERM : IN DIVORCE PACSES CASE ID: 595109612 ORDER OF COURT AND NOW, this 5th day of December 2007, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $ 2,775.86 and Respondent's monthly net income/earning capacity is $ 4,839.63, it is hereby ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit Eight Hundred Nineteen and 00/100 Dollars ($819.00) per month payable as follows: $819.00 per month for Alimony Pendente Lite and $0.00 per month on arrears. First payment due: next pay date at a rate of $378.00 bi-weekly. The effective date of the order is November 14, 2007. Arrears set at $1,276.74 as of December 5, 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: Christine M. Czarnecki. 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 t ''S The monthly obligation includes cash medical obligation in the amount of $250 annually for unreimbursed medical expenses incurred for the spouse. Unreimbursed medical expenses of the oblige that exceed $250 annually shall be allocated between the parties. The parry seeking allocation of unreimbursed medical expenses must provide documentation of expenses to the other party no later than March 31 St of the year following the calendar year in which the final medical bill to be allocated was received. The unreimbursed medical expenses are to be paid as follows: 0% by the Respondent and 100% by the Petitioner. [X] Respondent [] Petitioner [] Neither party to provide medical insurance coverage. Within thirty (30) days after the entry of this order, the [] Petitioner [X] Respondent shall submit to the other parry written proof that medical insurance coverage has been obtained or that application for coverage has been made. Proof of coverage shall consist, at a minimum, of. 1) the name of the health care coverage provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims should be made; 5) a description of any restrictions on usage, such as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy o the benefits booklet or coverage contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms. The Respondentis to make a payment to PA SCDU, P.O. Box 69110, Harrisburg, PA 17109- 9110 of $457.74 within 20 days of this date to liquidate the retroactive arrearage. 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 70T Edgar B. Bayley, J. Mailed copies on: December 6, 2007 to: Petitioner Respondent Barbara Sumple-Sullivan, Esq. Thomas M. Clark, Esq. DRO: R.J. Shadday L J t-... __ J 4 t -.. ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania 595109612 Q Original Order/Notice Co./City/Dirt. of CUMBERLAND 07-6789 CIVIL O Amended Order/Notice Date of Order/Notice 12/05/07 O Terminate Order/Notice Case Number (See Addendum for case summary) RE:CZARNECKI, RICHARD Employer/Withholder's Federal EIN Number DEPT OF AUDITOR GENERAL C/O OFFICE OF THE COMPTROLLER FINANCE BLDG RM 320 HARRISBURG PA 17120-0001 Employee/Obligor's Name (Last, First, MI) 181-42-8850 Employee/Obligor's Social Security Number 6355000288 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. $ 819.00 per month in current support $ o . o o per month in past-due support Arrears 12 weeks or greater? Q yes ® 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 $ 819.00 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: $ 189.00 per weekly pay period. $ 378.00 per biweekly pay period (every two weeks). $ 409.5o per semimonthly pay period (twice a month). $ 819. 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 URT: Date of Order: DEC 0 6 2007 v ? ? EDGAR B. BAYLEY, JUDGE DRO: R. J. SHADDAY Form EN-028 Rev. 1 Service Type M OMB No.: 0970-0154 Worker ID $IATT 819. x 12«+ 26. 78.00* 819•x 12-+ 52. W. 189.00,* ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If hecke? you are required to provide a opy of this form to your m loyee. If yol1 r employee works in a state that is diferent from the state that issued this order, a copy must be provideedpto 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.* paydateidate of withholding-iS tlle- dC-te- U-1-1 which arnount 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. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 7902100082 EMPLOYEE'S/OBLIGOR'S NAME: CZARNECKI. RICHARD EMPLOYEE'S CASE IDENTIFIER: 6355000288 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. Antidiscrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. §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: If you or your employee/obligor have any questions, DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 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 $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: CZARNECKI, RICHARD PACSES Case Number 595109612 PACSES Case Number Plaintiff Name Plaintiff Name CHRISTINE M. CZARNECKI Docket Attachment Amount Docket Attachment Amount 07-6789 CIVIL$ 819.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. 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 through the employee's/obligor's employment. through the employee's/obligor's employment. Addendum Form EN-028 Rev. 1 Service Type M Worker ID $IATT OMB No.: 0970-0154 ??? ti.....? ,, ? ? 4 ., ?? s _ ,. . -? -. -- ?. ? r' ,? _ • • ?? Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 CHRISTINE M. CZARNECKI, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. RICHARD CZARNECKI, Defendant TO THE PROTHONOTARY: NO. 07 - 6789 PACSES CASE ID: 595109612 CIVIL ACTION -LAW IN DIVORCE NOTICE OF APPEAL The Alimony Pendente Lite Order dated December 5, 2007 is hereby appealed for De Novo Hearing by the Court. Dated: December 11, 2007 3arbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ID #32317 Attorney for Plaintiff Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 CHRISTINE M. CZARNECKI, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07 - 6789 PACSES CASE ID: 595109612 RICHARD CZARNECKI, CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy of the Notice of Appeal, in the above-captioned matter upon the following individual, by United States first-class mail, postage prepaid, addressed as follows: Thomas M. Clark, Esquire The Wiley Group 130 W. Church Street, Suite 100 Dillsburg, PA 1701n,,---, DATE: December 11, 2007 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Plaintiff 4 ?x W C t In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION CHRISTINE M. CZARNECKI ) Docket Number 07-6789 CIVIL Plaintiff ) vs. ) PACSES Case Number 595109612 RICHARD CZARNECKI ) Defendant ) Other State ID Number You, CHRISTINE M. CZARNECKI plaintiff/defendant of C/O BARBARA S-SULLIVAN, ESQ., 549 BRIDGE ST, NEW CUMBERLAND, PA. 17070-1999-99 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 ' before a hearing officer of the Domestic Relations Section, on the JANUARY 29, 2008 ORDER OF COURT at 10: 3 OAM for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income Statement and the appropriate Expense Statement, if required, attached to this order, completed as required by Rule 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. information relating to professional licenses 7. other: Service Type M Form CM-509 Rev. 1 Worker ID 21205 CZARNECKI V• CZARNECKI PACSES Case Number: 595109612 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest and/or enter an interim support order. If paternity is an issue, the court shall enter an order establishing paternity. THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD TO WHICH PARTY INITIATED THE SUPPORT ACTION. Date of Order: DEC 12 2007 BY THE COURT: ,. 70, JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE-HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Rev. Service Type M Worker ID 21205 -y c W I S In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION CHRISTINE M. CZARNECKI ) Docket Number 07-6789 CIVIL Plaintiff ) VS. ) PACSES Case Number 595109612 RICHARD CZARNECKI ) Defendant ) Other State ID Number ORDER OF COURT You, RICHARD CZARNECKI plaintiff/defendant of 121 E COUNTRYSIDE DR, BOILING SPRINGS, PA. 17007-9445-21 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the JANUARY 29, 2008 at 10: 3 OAM for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income Statement and the appropriate Expense Statement, if required, attached to this order, completed as required by Rule 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. information relating to professional licenses 7. other: Form CM-509 Rev. 1 Service Type M Worker ID 21205 I CZARNECKI v• CZARNECKI PACSES Case Number: 595109612 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest and/or enter an interim support order. If paternity is an issue, the court shall enter an order establishing paternity. THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD TO WHICH PARTY INITIATED THE SUPPORT ACTION. Date of Order: DEC 12 2007 BY THE COURT: 1 G? JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE-HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Service Type M Page 2 of 2 Form CM-509 Rev. Worker ID 21205 _- = ? -? r ?? In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION CHRISTINE M. CZARNECKI ) Docket Number 07-6789 CIVIL Plaintiff ) VS. ) PACSES Case Number 595109612 RICHARD CZARNECKI ) Defendant ) Other State ID Number ORDER OF COURT - RESCHEDULE A HEARING You, CHRISTINE M. CZARNECKI of CIO BARBARA S-SULLIVAN, ESQ., 549 BRIDGE ST, NEW CUMBERLAND, PA. 17070-1999-99 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 on the 6TH DAY OF MARCH, 2008 at 8: 3 OAM for a hearing. This date replaces the prior hearing date of JANUARY 29, 2008 You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income Statement and the appropriate Expense Statement, if required, attached to this order, completed as required by Rule 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. information relating to professional licenses 7. other: Service Type M Form CM-514 Rev. 1 Worker ID 21302 1 ? CZARNECKI V. CZARNECKI PACSES Case Number: 595109612 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest and/or enter an interim support order. If paternity is an issue, the court shall enter an order establishing paternity. THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD TO WHICH PARTY INITIATED THE SUPPORT ACTION. BY THE COURT: Date of Order: / o. S-Q $ YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE-HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. JUDGE CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Service Type M Page 2 of 2 Form CM-514 Rev, Worker ID 21302 A _? _.l ---i :?.?.- ., • ..er,. - +;_ i !"' ---1 .,:? ?? ?X & ••4 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION CHRISTINE M. CZARNECKI ) Docket Number 07-6789 CIVIL Plaintiff ) vs. ) PACSES Case Number 595109612 RICHARD CZARNECKI ) Defendant ) Other State ID Number ORDER OF COURT - RESCHEDULE A HEARING You, RICHARD CZARNECKI of 121 E COUNTRYSIDE DR, BOILING SPRINGS, PA. 17007-9445-21 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 on the 6TH DAY OF MARCH, 2008 at 8: 3 OAM for a hearing. This date replaces the prior hearing date of JANUARY 29, 2008 You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income Statement and the appropriate Expense Statement, if required, attached to this order, completed as required by Rule 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. information relating to professional licenses 7. other: Service Type M Form CM-514 Rev. 1 Worker ID 21302 CZARNECKI V. CZARNECKI PACSES Case Number: 595109612 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest and/or enter an interim support order. If paternity is an issue, the court shall enter an order establishing paternity. THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD TO WHICH PARTY INITIATED THE SUPPORT ACTION. BY THE COURT: Date of Order: a 'R YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE-HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Q1111V 1 G JUDGE CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Service Type M Page 2 of 2 Form CM-514 Rev. 1 Worker ID 21302 r.. ? ^.,? ;. rr? ?7 ? __ .. ?? .. ry, , ? -? „° 7 ?-. ?„ ?. <<4 _, .. i:. . ? ,-. ?i ? i .. t _8 1: :. ?r i ,aft CHRISTINE M. CZARNECKI, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. : DOMESTIC RELATIONS SECTION RICHARD CZARNECKI, PACSES NO. 595109612 Defendant/Respondent DOCKET NO. 07-6789 CIVIL ORDER OF COURT AND NOW, this 6th day of March, 2008, this matter having been scheduled for a hearing de novo before the Support Master on the Plaintiff's petition for alimony pendente lite, and the parties having reached an agreement on all outstanding issues, upon recommendation of the Master it is ordered and decreed as follows: A. The Defendant/Respondent shall pay to the Pennsylvania State Collection and Disbursement Unit as alimony pendente lite the sum of $858.57 a month. B. The Defendant/Respondent shall provide health insurance coverage for the benefit of the Plaintiff/Petitioner as is available through his employment or other group coverage at a reasonable cost. C. The monthly obligation includes cash medical support in the amount of $250.00 annually for unreimbursed medical expenses incurred for the spouse. Unreimbursed medical expenses of the obligee that exceed $250.00 annually shall be allocated between the parties. The party seeking allocation of unreimbursed medical expenses must provide documentation of expenses to the other party no later than March 31 st of the year following the calendar year for which the final medical bill to be allocated was received. The unreimbursed medical expenses are to be paid as follows: 50% by the Defendant/Respondent and 50% by the Plaintiff/Petitioner. D. The effective date of this order is November 14, 2007. Cc: Christine M. Czarnecki Richard Czarnecki Barbara Sumple-Sullivan, Esquire For the Plaintiff/Petitioner Thomas M. Clark, Esquire For the Defendant/Respondent DRO c°a L y co 07-6789 CIVIL ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 03/11/08 Case Number (See Addendum for case summary) Employer/Withholder's Federal EIN Number DEPT OF AUDITOR GENERAL C/O OFFICE OF THE COMPTROLLER FINANCE BLDG RM 320 HARRISBURG PA 17120-0001 Employee/Obligor's Name (Last, First, M0 181-42-8850 Employee/Obligor's Social Security Number 6355000288 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. $ 858.57 per month in current support $ 0 . 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 $ 858.57 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: $ 198.13-per weekly pay period. $ 396.26 -per biweekly pay period (every two weeks). $ 429.29 per semimonthly pay period (twice a month). $ 858.57 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 TH OURT: Date of order: MAR 12 2008 N 0? EDGAR B. BAYLEY, -it DRO: R.J. SHADDAY Form EN-028 Rev. 1 Service Type M OMB No.: 0970-0154 Worker ID $IATT O Original Order/Notice O Amended Order/Notice O Terminate Order/Notice RE: CZARNECKI , RICHARD I i 858.57x i2. 5 2,• 1"98.13* 858.57x 1 2. t 26•= Ive 396.26* z ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If hecked you are required to provide a opy of this form to your m loyee. If yor employee works in a state that is diferent from the state that issued this order, a copy must be provicedpto 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 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: 7902100082 EMPLOYEE'S/OBLIGOR'S NAME: CZARNECKI, RICHARD EMPLOYEE'S CASE IDENTIFIER: 6355000288 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. Antidiscrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. §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 $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: CZARNECKI, RICHARD PACSES Case Number 595109612 Plaintiff Name CHRISTINE M. CZARNECKI Docket Attachment Amount 07-6789 CIVIL$ 858.57 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. Service Type M 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. Addendum OMB No.: 0970-0154 Form EN-028 Rev. 1 Worker ID $IATT N o {Y ? "77 i C i ? J L _ C y y> rn - co ? ?U CHRISTINE M. CZARNECKI : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. RICHARD CZARNECKI Plaintiff : NO. 6789 20 07 Defendant MOTION FOR APPOINTMENT OF MASTER CHRISTINE M. CZARNECKI Plaintiff , moves the court to appoint a master with respect to the following claims: ❑X Divorce (] Distribution of Property ❑ Annulment ❑X Support 0 Alimony ❑X Counsel Fees ❑X Alimony Pendente Lite ❑X Costs and Expenses and in support of the motion states: 1. Discovery is complete as to the claims (s) for which the appointment of a master is requested. 2. The defendant has appeared in the action (personally) (by his attorney,_ Thomas M. Clark , Esquire). 3. The staturory ground (s) for divorce is No fault divorce under 23 Pa.C.S. §3301 4. Delete the inapplicable paragraph (s): A 0 B ❑ C ❑ a. The action is not contested. n b. An agreement has been reached with resnect to the following claims: C M � cn All above. < CD D 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take one days C. The action is contested with respect to the following claims: 7. Additional information, if anv, relevant to the mdt on: { Date: . rhei)//6(i Atto Barbara Sumple-Sullivan, Esquire Print Name ORDER APPOINTING MASTER Wr9 61 d3S h 1 Ol h3 AND NOW , 20 , Esquire, is appointed master with respect to the following claims: By the Court, J. C r i ski r� m . Cioi"neck '' vs Case No. 01— (01%9 EiChard Czarn ecru STATEMENT OF INTENTION TO PROCEED To the Court: C h ri sal t. ne l , C-zo-neCId intends to proceed with above captioned matter. Print Name `aJQ%b.aSc,ImptQ-s3 Sf SigName box' q,2�1�- P�CAi�-rff- Date:' Attorney for ,, rn CZ) J -fit) C/) r- , — r-- In IMPORTANT NOTE -0 > --r c.:: , t, In the event that this is a second or subsequent filing of a Statement of Intension"tb Proceed, this matter will be referred to the President Judge for the purpose of conducting a status conference involving all counsel. The goal of the status conference will be to set the matter for trial or other final disposition within a time certain. Prior to the status conference, Counsel will be expected to submit to the court, in writing, a proposed schedule for the completion of discovery, the filing of dispositive motions and a report as to whether alternative dispute resolution has been used or discussed. CHRISTINE M. CZARNECKI : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. RICHARD CZARNECKI Plaintiff : NO.6789 Defendant MOTION FOR APPOINTMENT OF MASTER CHRISTINE M. CZARNECKI Plaintiff , moves the court to appoint a master the following claims: ❑X Divorce ❑X Distribution of Property ❑ Annulment ❑X Support X❑ Alimony ❑X Counsel Fees ❑X Alimony Pendente Lite ❑X Costs and Expenses and in support of the motion states: 1. Discovery is complete as to the claims (s) for which the appointment of a master is •Es9/2_2/1 2. The defendant has Thomas M. Clark appeared in the action (personally) (by his attorney,_ 3. The staturory ground (s) for divorce 's No fault divorce under 23 Pa.C.S. §3301 4. Delete the inapplicable paragraph (s): A ❑ B ❑ C ❑ a. The action is not contested. b. An agreement has been reached with resnect to the following claims: C. The action is contested with respect to the following claims: All above. 5. The action does not involve 6. The hearing is expected to take one 7. Additional information, if any, relevant to the motion: complex issues of law or fact. days Date: rhs)/so/V Atto Barbara Sumple-Sullivan, Esquire Print Name ORDER APPOINTING MASTER AND NOW XyrtAir Z Q , 20 I `1 , is appointed master with respect to the following claims: 20 07 with respect to requested. , Esquire). -- b�►-r €11 h4 - f� rsz; -tea ri rn rs� ri r ro 'squire, cbe+t J. -r f r+ 1-- L; rri 7-0 cl -n c CD t