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Home My WebLink About03-5588 II MICHELLE CAMERON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. JOHN W. CAMERON, Defendant CIVIL ACTION - DIVORCE] ~- 5'53f C.l~ ' PACSES CASE NO: 477105994 DEMAND FOR HEARING DE NOVO The Plaintiff; Michelle Cameron hereby appeals from the order for alimony pendente lite entered in this case on 21 September 2004 and demands a hearing de novo before the Support Master or the court. 24 September 2004 ~~t~~~(2Q, Attorney for Plaintiff Supreme Court 10 # 17225 525 North 12th Street Lemoyne, Pel 1 7043 (717) 761-5361 II CERTIFICATE OF SERVICE I hereby certify that I served an original of the foregoing document upon the following addresses, by regular mail, postage prepaid as follows: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Squan3 Carlisle, PA 17013 Domestic Relations Office Cumberland County 13 North Hanover StrElet P.O. Box 320 Carlisle, PA 17013 LeRoy Smigel, Esquire 4431 North Front Street Harrisburg, Pa 1711 () Date: 24 September 2004 ~ (') ...., ~ = c: = <.,.... "'"" -." -!)l~~~ en """" n1(71 rTJ ~..,., .7""(1 " 'F C{1 21; N -om (f)..,:' '''::S ':3 --c.: -.J b( ->-- r-:. ... ,.,.,! ,~ :-:::: ..~. :xii ~c: " -+- :r:: ~2(J C Sio [Sm c: ~~) 7: S: t:::::::> :~ c::. :::0 W ~< "J':::> 0 REAGER & ADLER, PC BY: DEBRA DENISON CANTOR, ESQUIRE Attorney LD. No. 66378 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-\383 Attorneys for Plaintiff MICHELLE CAMERON, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03- S S' P ?' Ci..;;.J. J u--. JOHN W. CAMERON, Defendant 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. Ajudgrnent 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. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. 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 1-800-990-9108 REAGER & ADLER, PC BY: DEBRA DENISON CANTOR, ESQUIRE Attorney LD, No. 66378 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Plaintiff MICHELLE CAMERON, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03- 5'V S''i' CwJ J.v- JOHN W. CAMERON, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(C) OR (D) OF THE DIVORCE CODE I. Plaintiff is Michelle Cameron, an adult individual who currently resides at 431 Independence Court, Mechanicsburg, Cumberland County, Pennsylvania 17050 . 2. Defendant is John W. Cameron, an adult individual who currently resides at 3806 Pamay Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 5,1990 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither Plaintiff nor Defendant is in the military or naval services of the United States or its allies within the provisions of the Solders' & Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. Plaintiff avers that there are no children of this marriage. 8. The marriage is irretrievably broken. 9. Plaintiff has been advised that counseling is available and that Defendant may have the right to request that the court require the parties to participate in counseling. Plaintiff declines counseling. 10. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 11. In the alternative, Plaintiff will file a 3301(d) Affidavit and provide the appropriate notices two (2) years from the date of separation. WHEREFORE, Plaintiff respectfully requests this Court to enter a decree of divorce pursuant to Section 3301(c) or (d) of the Divorce Code. COUNT I EQUITABLE DISTRIBUTION 12, Paragraphs one (1) through eleven (II) ofthis Complaint are incorporated herein by reference. 13. Plaintiff and Defendant have acquired property, both real and personal, during their marriage. 14. The parties have acquired marital debt during their marriage. 15. Plaintiff and Defendant may be unable to resolve amicably the property issues in this matter, WHEREFORE, PJaintiffrespectfully requests this Honorable Court to equitably divide all marital property and debt. Respectfully submitted, Dated: \ D f2-1 \ Q ~ By: Attorneys for Plaintiff Michelle Cameron VERIFICATION I, Michelle Cameron, verify that the statements made in this Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: '7VU'~ ()~ MICHELLE CAMERON ~~ '- -c. ~ " U\ "'" '--- v , ~ ~ J\ ... ~ (v ..... --- "" 'K, ~ ~ 0 d '-"-.~ l::> tR-- ~.J; F ~<- \f (-', ." 1 .., ... C \ -' ;11 _OJ . , MICHELLE CAMERON , Plaintiff \1. lNTHECOURT ' CUMBERLAND CO}' COM1\(ON PLE OUN1'}; PENNs'r. NO. 03-551J'(I,,'....,'( : CIVIL A.C'fION _ LA. W : IN DIVORCE JOlIN W. CAMER.ON. , Defendant I, LeRoy Smigel, lsqUire am authorized to . OOc"" .-.",,,,, of ., CO"'Pl,;" ;, D; 'ore, "" ",",If of"", eU,"" JoJ" W. c"""" ~ ."b . ' O\1e captioned matter. 10 2. "I. 03 By: ~~ LERoy S~fIGEL, ESQlJIRE--- v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5~ i,v:( MICHELLE CAMERON, Plaintiff JOHN W. CAMERON, Defendant : CIVIL ACTION - LAW : IN DIVORCE ACCEPTANCE OF SERVICE I, LeRoy Smigel, Esquire am authorized to accept serviice of the Complaint in Divorce on behalf of my client, John W. Cameron, in the above captioned matter. Date: \ 0, 2. " ' 02> By: LEROY SMIGEL, ESQUIRE ~ e Q ~ Co.) "000 ~ :-;:1 0 mrn -.::::: ~:~ ~:u , 05,)2 .s:.- og ;::"'. 6.; KC --I -0 ~L:B ~c ::!c ,') C ~ ,,-~ :i>c:.- i5 :i3 ::;;! CJJ :i::J -.;; -<: MICHELLE CAMERON, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO, 03-5588 Civil Term JOHN W, CAMERON, DEFENDANT CIVIL ACTION - LAW IN DIVORCE ANSWER AND COUNTERCLAIM TO COMPLAINT IN DIVORCE AND NOW, comes Defendant, John W, Cameron, by and through his counsel, Smigel, Anderson & Sacks, and answers Plaintifi's Complaint in Divorce as follows: L Admitted. 2. Admitted, 3, Admitted. 4. Admitted, 5, Admitted. 6, Admitted. 7. Admitted, 8. Admitted. 9, To the extent that a response is required, Defendant is without knowledge as to how Plaintiff has been advised, Defendant will decline to request that the parties participate in counseling, 10, To the extent that a response is required, Defendant is without knowledge about what the Plaintiff intends to do, II, To the extent that a response is required, Defendant is without knowledge about what the Plaintiff intends to do, COUNT I EOUlTABLE DISTRIBUTION 12. No response required. 13. Admitted. 14. Admitted. 15. Admitted. COUNTERCLAIM AND NOW, comes Defendant/Petitioner in Counterclaim, John W. Cameron, through his attorneys, Smigel, Anderson & Sacks and requests as follows: COUNT I EOUlTABLE DISTRIBUTION 16. Defendant repeats and re-alleges the averments of paragraphs 1-15 which are incorporated by reference herein. 17. Plaintiff and Defendant possess various items of both real and personal marital property which is subject to equitable distribution by this Court. WHEREFORE, Defendant requests this Court equitably distribute the marital property after an inventory and appraisement has been filed by the parti,~s. COUNT II ALIMONY UNDER SECTION 3701 OF THE DIVORCE CODE 18. Defendant repeats and re-alleges the averments of paragraphs I through 17 which are incorporated by reference herein. 19. Defendant requires support to adequately maintain himself in accordance with the standard ofliving established during the marriage. WHEREFORE, Defendant requests the Court award him reasonable alimony pursuant to Section 3701 of the Divorce Code. COUNT III ALIMONY PENDENTE LITE. COUNSEL FEES. COSTS AND EXPENSES UNDER SECTION 3702 20. Defendant repeats and re-alleges the averments of paragraphs I through 19 which are incorporated by reference herein. 21. Defendant has no adequate means of support for himself during the course of this litigation. 22. Defendant does not have sufficient funds to pay counsel fees, costs or expenses incidental to this action. WHEREFORE, Defendant requests the Court award him alimony pendente lite, counsel fees, costs and expenses. Respectfully submitted, SMIGEL, ANDERSON & SACKS, LLP ;/ , I 7 'l'J:? By: 't~ Date: LeRoy 8m el, Esquire I.D. #: 09617 443 I North Front Street Harrisburg, PA 17110-1260 (717) 234-2401 Attoffil~ys for Defendant YFRTFlC'A nON I, John W. Cameron, verifY that the statements contained in the foregoing pleading are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsification to authorities. Date: II, 1~ 03 ~ JOHN . CAMERON MICHELLE CAMERON, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA V. NO. 03..5588 Civil Term JOHN W. CAMERON, DEFENDANT CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, LeRoy Smigel, Esquire, attomey for Defendant in the above-captioned matter, do hereby certifY that I served a true and correct copy of the foregoing Answer and Counterclaim to Complaint in Divorce on counsel for Plaintiffby depositing same in the U.S. Mail, first class, postage prepaid, on the ''1~y of tJov ,2003, addressed as follows: Debra Denison Cantor, Esquire Reager & Adler, P.C. 2331 Market Street Camp Hill, PA 117011-4642 Smigel, Anderson & Sacks, LLP By: l&A,r (~'p LeRoy Smigel, Esquire I.D. #09617 4431 North Front Street Harrisburg, P A 17110-1260 (717) 234-240 I Attorneys for Defendant o -o~~ rn; , ;;:,; , ~' ~ 4("-. )c.(,: ;;<, --;:; -, '--'~ () -'il <.",- -.,.... ::'~ '''-.) ""1:1 -ij ~ C') -~ In .J ._, ~,. .:,J =< '" ~ MICHELLE CAMERON, PlaintiffilRespondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYL VANIA VS. CIVIL ACTION - DIVORCE JOHN W. CAMERON, Defendant/Petitioner NO. 2003-5588 CIVIL TERM IN DIVORCE Pacses# 4771 05994 ORDER OF COURT AND NOW, this 15th day of January, 2004, upon consideration of the attached Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before RJ, Shaddav on Februarv 11, 2004 at 10:30 A.M. for a conference, at 13 N, Hanover St, Carlisle, P A 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: (I) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, c.ompleted as required by Rule 1910.11~ (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, George E. Hoffer, President Judge Mail copies on 1-15-04 to: Petitioner < Respondent John Humphries, Esquire Debra Cantor, Esquire Date of Order: January 15. 2004 R 1. Shadday, Conference 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 ASSOCIA nON 2 LIBERTY AVE, CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 CC361 (') ~: -r:~;:' ;D;'? .r,.< ' ::.',n ~;i:~ ;:=-~ ;:.~,;~~ '" -~ -(' ", C::> CC"J -"" 3: =:= C) -n :'E~ I"l1p -nIT! '~j')CJ C) I ;..~fr; ..:'() ~,-)r.n ~"r c.n -'-:~' -'.. .r.- N W .:..(1 ..< II MICHELLE CAMERON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW JOHN W. CAMERON, Defendant NO. 03-5588 CIVIL TERM IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Please enter my appearance in the above matter for the Plaintiff, Michelle Cameron. Dated: 4 ~ ~L4 ~ Sam I L. Andes Attorney for Plaintiff Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 Please withdraw my appearance for the Plaintiff in the above matter. Dated: ~ 0 () = -n <= s~ .r- .-/ ':'..... -ra :t:-n -nt>' f"T1 rn-= ~ " i .. ; = -oFn , :d9 , CO qo ::r::~:{ -u <'::20 -...." -, "'-'if"fl '- - ~=" 2- .. ~ -"1 0 ~ -, N MICHELLE CAMERON, Plaintifti'Resondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE JOHN CAMERON, Defendant/Petitioner NO. 2003-5588 CIVIL TERM IN DIVORCE Pacses# 477105994 ORDER OF COURT NOTICE OF RESCHEDULED CONFERENCE AND NOW, this 19th day of February, 2004, upon consideration of the Petition for Alimony Pendente Ute and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before KJ, Shaddav on March 16. 1004 at 10:30 A.M. for a conference, at 13 N, Hanover St, Carlisle, P A 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: (I) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910,1l@ (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 docmnents, the Court may issue a warrant for your arrest. BY THE COURT, George E. Hoffer, President Judge Mail copies on 3-19-04 to: Petitioner < Respondent Samuel Andes, Esquire Leroy Smigel, Esquire Date of Order: February 19. 2004 , 1. adda, Conference Officer ( YOU HAVE THE RIGHT TO ALA WYER, 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 -r'" '., \;\, '\ . )'\ \ . . " \ , , .' 0 ...., c = 0 -;:,.;: =, :'-r .c- " ...., .... 1""1 I_ vJ nl-!J :".,) r- -r:rm a :DQ C) I -'::: ~Q C. _w. S)~ r'"~ ?..: 'd ~=!.rn ---< -' -< N 5-:., w ,< II MICHELLE CAMERON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW JOHN W. CAMERON, Defendant NO. 03-5588 CIVIL TERM IN DIVORCE PETITION AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, and petitions the court to interpret, clarify, and apply the tl~rms of a Pre-Nuptial Agreement signed by the parties in this matter, based upon the following: 1. The Petitioner herein is the Plaintiff, Michelle Cameron. The Respondent herein is the Defendant, John W. Cameron. 2. The parties were married on 5 February 1990. On 2 February 1990 they entered into and executed a Pre-Nuptial Agreement, a <copy of which is attached hereto and marked as Exhibit A (hereinafter "Agreement"). 3. Paragraph 1 of the Agreement, in part, provides: Except as otherwise provided herein, each party expresses his or her intention not to claim any interest whatsoever in the property accumulated by the other party prior to the marriage as set forth in Exhibit "A". Further, both parties express their intention not to claim any of the income or appreciation derived from their separate property as set forth in Exhibit "A". 4. Paragraph 2 of the Agreement, in part, provides: Attached hereto as Exhibit "A" are statements of the separate property of the parties as of the date hereof. It is understood that as a result of income from or increases in the value of their presently existing separate property, each party may acquire other and different separate property in the future, which each party shall hold free from any claim of the other. II 5. A dispute has arisen between the parties as to the proper interpretation, application, and effect of the Agreement and the extent to which the Agreement i forecloses or limits any claim by either of the parties against the increase in value of each party's pre-marital assets. The parties have not been able to resolve that dispute and require the court to interpret and apply the agreement. 6. Plaintiff believes there is sufficient confusion about, and ambiguity in, the language of the Agreement that testimony will be required for the court to properly understand and determine the intention of the parties and the effect of the Agreement. WHEREFORE, Plaintiff prays this court to interpret, apply, clarify and, if necessary, enforce the terms and provisions of the Pre-Nuptial Agreement between the parties dated 2 February 1990. ~ Sam I L. Andes Attorney for Plaiintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 II I verify that the statements made in this document are true and correct. I understand that any false statements in this document are subject to the penalties of 1 8 Pa. C.S. 4904 (unsworn falsification to authorities). Date: S7:J.'I/()t.j ~1 0 p i2L (I (]A/YLf A.A.Jv\..../ MICHELL.E CAMERON CERTIFICATE OF SERVICE I hereby certify that I served a copy of the fore~,oing document upon counsel for the Defendant herein by regular mail, postage prepaid, addressed as follows: LeRoy Smigel, Esquire 4431 North Front Str,eet Harrisburg, PA 17110 Date: 24 May 2004 II I:XH I BIT A PRENUPTIAL AGREEMENT This Agreement made and concluded this -;~/;,/.i day of -' .~,_.... (. ,..:...."....,:.,/ r "' 1990, by and between John Cameron of Cumberland County, Pennsylvania, hereinafter referred to as John, and Hichelle Gillespie of Cumberland County, Pennsylvania, hereinafter referred to as Michelle, WITNESSETH WHEREAS, John and Michelle hereto contemplate marriage and desire, ~n advance of the marriage, to agree as to their respective rights and obligations following the marriage; and WHEREAS, the parties desire to define their property rights, NOW, THEREFORE, in consideration of the premises and of several mutual promises and/or covenants and/or agreements hereinafter con- tained, each of the parties hereto, intending to be legally bound hereby, promises, covenants, and agrees as follows: 1. The parties intend to marry and desire to maintain a rela- tionship consisting of mutual love and affection. Except as otherwise provided herein, each party expresses his or her intention not to claim any interest whatsoever in the property accumulated by the other party prior to the marriage as set forth on Exhibit "A". Further, both parties express their intention not to claim any of the income or appreciation derived from their separate property as set forth in Exhibit "A". 2. The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel. John has employed and had the benefit of counsel of Michael Perry, Esquire, as his attorney. Hichelle has employed and had the benefit of Matthew Dempsey, Esquire, as her attorney. Each party acknowledges that he or she has received independent legal advice from counsel of his or her selection, and each fully understands the facts and has been fully informed as to his or her legal rights and obligations, and each party acknowledges and accepts that this Agreement is, in the circumstances, fair and equitable and it is being entered into freely and voluntarily after having received such advice and with such knowledge, and that execution of this Agreement is not the result of any duress or undue influence, and it is not the result of any collusion or improper or illegal agreement or agreements. Both parties to this Agreement have madre to each other a full and complete disclosure of the nature, extent and probable value of all their property and estate. Attached hereto as Exhibit "A" are state- ments of the separate property of the parties as of the date hereof. It is understood that as a result of income from or increases in the value of their presently existing separate property, each party may acquire other and different separate property in the future, which each party shall hold free from any claim of the other. 3. This Agreement does not intend to resolve either party's rights under the Divorce Code with the exception of each party's right to equitable distribution of any of the property set forth in Exhibit '~'r, or property acquired or substituted therefor as set forth in paragraph (2). 4. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania, irrespective of where the parties may hereafter reside. 5. This Agreement shall continue in force until it is modified by a writing executed by both parties. 6. The terms, provisions and conditions of this Agreement shall be binding upon any and all of the heirs, executors, administrators, successors or assigns of either of the respective parties hereto, 7. Each provision of this Agreement j~s separate from the other provisions of this Agreement, and if any provisions shall be deemed to be unenforceable by any court of competent jurisdiction, no other pro- vision of this Agreement shall be affected or invalidated thereby. 8. This Agreement shall not preclude either party from providing for or claiming any bequests which may be made for Such party in any Trust or Will of the other party hereto. IN WITNESS WHEREOF, the parties hereto executed this Agreement on the day and year first above written. .;>;~~ ~ ../ { CH--- ~ ft-;z 7 Matthew Dempsey; Esq( ~~~ Sworn to and subscribed before me this ,-z:i<. day Of?~ ,1990. ~.~~ Notary Publ~c NOTARiAL Sl.AL ( ANNE LA. 7ELl.E, Notary PUhIlc , . 6crar.ton. LaCl{2W~mr.e. ":-~O;~.itl.':r Iv.f~r COlnrniSSi.o:r.: E;.:pirf::.') :::3: :'."::' '::~. ~f!~r: -------....--...-.... ..... . . MICHELLE 40lK IRA Money Market Acct. MICHELLE'S STOCKS Dauphin Deposit General Mills H.J. Heinz (common) International Paper May Co. Merck Co. Pepsico, Inc. EXHIBIT "A" JOHN 6,200 22,000 52,500 40lK IRA Money Market Acct. 27,000 105 50 75 100 50 80 50 JOHN'S STOCKS Baxter International Bell Atlantic Dow Chemical Exxon General Motors Class H General Motors General Motors Class E Penzoil American Home Products Amoco Battle Mountain Gold Class Battle Mountain Gold Class 9,500 2,500 60,000 51,100 0 ~ 27 75 142 4 100 4 135 98 136 A 87 B 135 Equity in John's House at 405 Candlewyck Rd., Camp Hill, PA Remainder of Martha E. Cameron Inheritance , , (') '" C) C::Jo c~ C'::;> 'n ~~ ~ "Tl ::., " hi -< r: (" ~.-,r! (It ( r'-.,J 1,::':1 0) C; ~~J ,,' -'---f -J ': :-'\ . c:- , j ;"t~1 ~". ( to,,) ~-~ ;:;; :-3 '<. "', \LJ MICHELLE CAMERON, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. JOHN W. CAMERON, . DEFENDANT 03-5588 CIVIL TERM ORDER OF COUR': AND NOW, this 5,R. day of June, 2004, the within petition for the entry of a Rule to show cause, IS DENIED.1 By the Court, Cv Edgar El. ~muel L. Andes, Esquire For Plaintiff ~Oy Smigel, Esquire For Defendant ) 7 :sal O~'0:3-0~ I Any issue as to what assets constitute or do not constitute marital property subject to equitable distribution under the Divorce Code l:lr an enforceable pre- nuptial agreement is a matter for resolution by the Divorce Master. ~~" ,-, 1,rt2, '(50 \ L1- tr\o~ ';~~\.-:;:' '- i- \0 C0 -- i:0 "':c. '0..- C0 \ ?:;. .j'..... ~ --""1..::':"; '~:~-\~:l. -~ ::~~ , ;. ).'_" :;:;;, -;;:.;., if, '?> ',C, ':'7:\ ..~~o- ....1 o In the Court of Common Pleas of CUMBERLAND County, Pennsylvania OOMESTlC RELATIONS SECTION JOHN W. CAMERON ) Docket Number 03-5588 CIVIL Plaintiff ) vs. ) PACSES Case Number 477105994 MICHELLE CAMERON ) Defendant ) Other Sltate ID Number ORDER AND NOW, to wit on this 7TH DAY OF JULY, 2004 IT IS HEREBY ORDERED that the 0 Complaint for Support or 0 Petition to Modify or (i) Other ALIMONY PENDENTE LITE filed on DECEMBER 3, 2003 in the above captioned matter is dismissed without prejudice due to: THE PLAINTIFF NOT PURSUING THE COMPLAINT FOR ALIMONY PENDENTE LITE THROUGH THE DOMESTIC RELATIONS SECTION SINCE THE REQUEST E'OR AN ALIMONY PENDENTE LITE CONFERENCE. (i) . !he Complaint or Petition may be reinstated upon writ1ten application of the plaintiff petltlOner. DRO: RJ Shadday xc: plaintiff defendant Samuel Andes, Leroy Smigel, ~BYTHE~I~_' i' /72 ,~- / \ (). Esquire __i.~p..v' "'\ ~ Esquire Edgar B. Bayley JUDGE Service Type M Form OE-506 Worker ID 21005 -'''or~ 1~~,~1' ....-.:".,.. li) ~:- r~t-. ~f-~~ "}/C:: ~ -< o c: ~". r-> =' :'? <- c: .-- 1 .....l o ." ~::D :g~ OC' ~~ 9ro ,"'-fr1 S }-:; ::< -0 :x <.J .- .r;:- -J MICHELLE CAMERON, PlaintiflmRespondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - nIVORCE JOHN W. CAMERON, Defendant/Petitioner NO. 2003-5588 CIVIL TERM IN DIVORCE Pacses# 477105994 ORDER OF COURT AND NOW, this 30th day of July, 2004, upon consideration of the Petition for Alimony Pendente Ute and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before RJ, Shaddav onSelJtember 21.2004 at 9:00A.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, Note: There will be no requests for continuances granted. YOU are further ordered to bring to the conference: (I) a true copy of your most recent F ederallncome Tax Retum, including W - 2' s as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, eompleted as required by Rule 1910,11~ (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest BY THE COURT, George E. Hoffer, President Judge Mail copies on 7-30-04 to: Petitioner < Respondent Leroy Smigel, Esquire Samuel Andes, Esquire j}' ;:JL~~ dday, Conference Officer . Date of Order: Julv 30. 2004 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 JUL 1 5 200t. SMIGEL, ANDERSON & SACKS LLP LEROY SMIGEL, ESQUIRE PHONE: (717) 234-2401 TOLL FREE: 1_800_822_9757 ATTORNEYS AT LAW FACSIMILE (717) 234-3611 EMAIL: lsmigel@sasllp.com www.sasllp.com FileNo. 3946-2-4 July 9, 2004 FAX 240-6248 R.}, Shadday, Conferell~e Office Cumberland County Domestic Relations Section 13 North Hanover Street P.O. Box 320 Carlisle, PA 17013 Re: John W. Cameron v, Michelle Cameron DocketNo.1086S 2003 PACSES No. 586105990 (Spousal Support) John W, Cameron v. Michelle Cameron Docket No. 03-5588 Civil PACSES No. 477105994 (APL) Dear Ms. Shadday: Thank you for advising me about the above matters. 1 would appreciate it if you would please reinstate the actions retroactive to the original dates of filing. Please call me with any problems or questions. Sincerely, ~ \t(~ LeRoy Smigel LRS:vlf cc: Samuel L. Andes, Esquire Mr. John Cameron 4431 North Front Street. Harrisbure:. Pennsylvania 17110 A PENNSYLVANIA LIMITED LIABILITY 'PARTNERSHIP t;))/K'r "'" COO c..-:;, .r- J> c:: G') I N ~ =l ft;:a r- -om :uy 00 :f1....- C)::i:l .,:'",,(-' OfT} :-1 :4J -< -0 :x c." (.0 <n MICHELLE CAMERON, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE JOHN W. CAMERON, Defendant/Petitioner NO. CIVIL TERM IN DIVORCE O'?J- 5'5"n ~:\:,( Pacses# 477105994 ORDER OF COURT AND NOW, this 21 st day of September, 2004, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $6,182.51 and Respondent's monthly net income/earning capacity is $8,484.42, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $900.00 per month payable monthly as follows; $900,00 for alimony pendente lite and $0.00 on arrears. First payment due next pay date at $415,38 bi-weekley. Arrears set at $2,700.00 as of September 21,2004. The effective date of the order is July 9,2004, Respondent is to pay 40% of any and all net bonuses to Petitioner within five days upon receipt of said bonus (es) and provide verification of the amount of the bonus to Respondent Collection on the retroactive arrears is held in abeyance until disposition from the Support Master. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all ofthe means as provided by 23 Pa,C.S.~ 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months, Said money to be turned over by the P A SCDU to: John W. Cameron. Payments must be made by check or money order. All checks and money orders must be made payable to P A SCDU and mailed to: P A SCDU P.O, Box 69110 Harrisburg, PAl 71 06-911 0 Payments must include the defendant's P ACSES Member Number or Social Security Number in order to be processed, Do not send cash by mail. Unreimbursed medical expenses that exceed $250.00 annually are to be paid as follows: 0% by Respondent and 100% by Petitioner. The Petitioner is responsible to pay the first $250,00 annually in unreimbursed medical expenses. Respondent to provide medical insurance coverage. Within thirty days after the entry of this order, the Respondent shall submit to the Petitioner written proof that medical insurance coverage has been obtained or that application for coverage has been made. Proof of coverage shall consist, at a minimum, of: I) the name of the health care coverage provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage; 4)the addr4ess to which claims should be made; 5) a description of any restrictions on usage, such as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms. This Order shall become final ten days after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary for a hearing de novo before the Court. DRO: R j, Shadday Mailed copies on 9-21-04: < Petitioner Respondent Leroy Smigel, Esquire Samuel Andes, Esquire BY THE COURT, ~'1~ Edgar B. Bayley j, C) ::c' h) (~J -l;,-. ;:i~f('\ tot ~~_ ,,-, c:::-..:- ;:;-;-;., ...;:,:- .-) ~"h r/) ;--.'-: -u ", "-' ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsvlvania Co.lCity/Dist. of CUMBERLAND Date of Order/Notice 09/21/04 Tribunal/Case Number (See Addendum for case summary) @Original Order/Notice o Amended Order/Notice o Terminate Order/Notice EmployerM'ithholder's Federal EIN Number RE: CAMERON, MICHELLE Employee/Obligor's Name (last, First, MO 17105-8375 M. f'~Eb ;lea.- 65W' ~"I , I./nloS",99 186-50-2363 Employee/Obligor's Social Security Number 1126101252 Employee/Obligor's Case Identifier (S.. Addendum for p/~iH n$l!i/!s 0 associated with cases b,J;attadiinent) -n Custodial Parent's f'fat:n~ (Lastl~,iljstl MJ1~ -~r:, "':". --:J "'r-=:, ~.....) i--) LJ (~.) PA MED SOCIETY 777 E PARK DR PO BOX 8375 HARRISBURG PA LIABILITY INS r See Addendum for dependent names and birth dates associated with cases on attachment. -c, _:' i "'-' ,-,;,-'-) ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an oid\Jdor ~pport5,' n from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required Wpedu.<=! thellr; amounts from the above-named employee'sfobligor's income until further notice even if the Order/NottEe is !lOt .< issued by your State. $ 900.00 per month in current support $ 0 . 00 per month in past-due support $ 0.00 per month in medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ 900.00 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: $ 207.69 per weekly pay period. $ 415.38 per biweekly pay period (every two weeks), $ 450.00 per semimonthly pay period (twice a month), $ 900.00 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'sf obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #10 on pg. 2), Arrears 12 weeks or greater? @yes 0 no If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AMD 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. ~ ,. . , -. :'"'1,~~';:J ~2 ' _ ' .f.:;G:;;;"1JY'THE C~: ~ ~ ' _' ." \ 0-\1\ Date of Order: SEP 2 2 2OD~ . \ ~(';~ 4, .t$,4YlCY Service Type M OMB No.: 0970-0154 Form EN-028 Worker 10 $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If ~hecked you are required to prpvide a Copy of this form to your employee. If your employee works in a state that is different from the state that issued this order, a copy must be provided to your employee even if the box is not checked. 1, We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally'{)wned businesses, and Indian-owned businesses located on a reservation that choose to withhold in accordance with this notice. 2, Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income, Federal tax levies in effect before receipt of this order have priority, If there are Federal tal( levies in effect please contact the requesting agency listed below. 3, Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding, You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor, 4. * Repoll;llg t1,~ PAydatJD,&,oc of'Nitl.',old;l.g. YOu Illu;;llepol1 tl,~ pAydi:!.tc'dAle of nitl,ll,oldil,g nl,tl, sCI,d;"g tLe pa.YII,CI,t. TI,~ payda.tddi:.\loc; of nal,I,oldil,g;.!J ll,G dA Oil nl,;d. At..Oul,t n(lS n;ll,I,~ld (1\5111 diG ~llIploye~:/~ na~s. 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, 5,' Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor 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 #1 0 below) 6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you, Please provide the information requested and retum a copy of this Order/Notice to the Agency identified below, WITHHOLDER'S ID: 2320056560 EMPLOYEE'S/OBLlGOR'S NAME: EMPLOYEE'S CASE IDENTIFIER: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: CAMERON. MICHELLE 1126101252 DATE OF SEPARATION: 7, Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person 0Ir authority below. 8, Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs, 9, Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, ortaking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs, 10, * Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C 91673 (b)l; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment The Federal limit applies to the aggregate disposable weekly earnings (ADWE), ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxesi Social Security taxeSi and Medicare taxes. 11, Additional Info: 'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P,O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at ill 7) 240-6225 or by FAX at (7171 240-6248 or by internet www.childsupport.state.pa.us Service Type M Page 2 of 2 Form EN-028 Worker ID $IATT OMS No.; 0970.0154 ADDENDUM Summary of Cases on Attachment Defendant/Obligor: CAMERON, MICHELLE PACSES Case Number 477105994 Plaintiff Name JOHN W. CAMERON Docket Attachment Amount 03=ssaa CIVIL$ 900.00 Chlld(ren)'s Name(s): PACSES Case Number Plaintiff Name DOB Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Chlld(ren)'s Name(s): DOB Docket Attachment Amount $ 0.00 Chlld(ren)'s ~Iame(s): DOB o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the em ployee's/obligor's employment PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB '",",-,'" "_'.'_..,_,.'.'.'_'_.,_,."_"..,.._.,...,_..,.,...._-"-'-",",-",_,"0".-_'.-.'..-.."".,.-..-,.".- ..-................. ................................ ....... -,...... -.'" .,'....,..,.."",....,.,.",-,,_......,.,-,,-,.-,_....."-"'-"""',,-,',-""",',',"""'-, "". - """""""""'"""-,-"",-",-,-',-,-".'",-,,-",-,:,,:,-:-,,-,"-".":-,""'-'-.":-:":""-":,-:,:,.:-,:":::,::::-:,, o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment Service Type M Addendum Form EN-028 Worker ID $IATT OMB No.: 097().{)154 .:::: -'t:' C{ () r-' c;;"l ~, ;;? 1:::_ tj") ;-\ -"0 C) -n :::-~ r':> (...J 0) c-J MICHELLE CAMERON, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - DIVORCE JOHN W, CAMERON, DEFENDANT NO, CIVIL TERM IN DIVORCE PACSES # 477105994 O~:-5'5'&8' DRMAND FOR HF.ARTNG DR NOVO Defendant, John W. Cameron, hereby appeals from the order for alimony pendente lite entered in this case on September 21, 2004 and demands a hearing de novo before the Support Master or the Court. SMIGEL, ANDERSON & SACKS Date: /0/1(04 By:~_D Q L oy Smigel, Esquire I.D. #09617 ames R Demmel, Esquire LD. #90918 4431 North Front Street Harrisburg, PA 17110-1709 (717) 234-2401 Attorneys for Defendant MICHELLE CAMERON, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - DIVORCE JOHN W. CAMERON, DEFENDANT NO. CIVIL TERM IN DIVORCE PACSES # 477105994 C'F,RTIFIc.ATF OF SFRVICE I do hereby certifY that I served a true and correct copy of the foregoing Demand for Hearing De Novo upon the following individuals by depositing same in the U.S. Mail, first class, postage prepaid, on the 1st day of October, 2004, addressed as follows: Cumberland County Domestic Relations Office 13 North Hanover Street P,O. Box 320 Carlisle, PA 17013 Samuel L. Andes, Esquire 525 North Twelfth Streeil Lemoyne, P A 17043 SMIGEL, ANDERSON & SACKS By: C)u X ~)y Smigel, Esquire I.D. #09617 ~~s R. Demmel, Esquire I.D. #90918 4431 North Front Street Harrisburg,PA 17110-1709 (717) 234-2401 Attomeys for Defendant ':) ~ ~ c/I " '" ~ -->-- '" D 7'::J o ( r~:' )~., ,-' :;;:c.:' 5~: q.:'4 -< n f.:: ..... :t.:FP -., ~. - ~.;) CfJ C;, t:; <-Cd -"'" c::, C) -, I P .1 --I ih.":r; _ r-'';;; .t'JfT"' "p;r;-' i"J ::1J"~) .~~.~ (oJ C,)rn ~~.;" ~.<;,. In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION JOHN w. CAMERON ) Docket Number 03-5588 CIVIL Plaintiff ) vs. ) PACSES Case Number 477105994 MICHELLE CAMERON ) Defendant ) Other State ID Number ORDER OF COURT You, JOHN W. CAMERON plaintiff/defendant of 3806 PAMAY DR, MECHANICSBURG, PA. 17050-7676-06 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3~4-13 <:".11 ~ (":':0 ~ :Io CJ~"'" 0 ,T1rrlr n -~tf')f"I"1 . -it:) '~~~ c!:4("T'1 :z _ -:: -<0 1. a true copy of your most recent Federal Income Tax Return, including W -2s, a'smled, ~ 2. your pay stubs for the preceding six (6) months, 3, verification of child care expenses, and 4, proof of medical coverage which you may have, or may have available to you 5, information relating to professional licenses 6. other: before a hearing officer of the Domestic Relations Section, on the NOVEMBER 23, 2004 at 9: OOAM for a hearing. You are further required to bring to the hearing: Form CM-509 Worker ID 21302 Service Type M PACSES Case Number: 477105994 CAMERON v. CAMERON If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: .-1 D~'\ -0'-\ W-l~~ JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. TillS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELlGmLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 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. AMERICANS WITH DISABILITIES ACT OF 1990 Page 2 of2 Form CM-509 Worker ID 21302 Service Type M ",. tl. :-!>i.";r;::j' o ~,;'; ..., c;,:, (':,::-.) ~ o ." =:J fR:n ."n/=;; -uc,.' c,~c ~ - ,I ) r.:.'~' (:',-' fj .':;: (~) c5n~! "):';.' :1"] -....,: a C'-J ...... I CJ1 -0 :::J:: ~ c:., In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION JOHN w. CAMERON ) Docket Number 03-5588 CIVIL Plaintiff ) vs. ) PACSES Case Number 477105994 MICHELLE CAMERON ) Defendant ) Other State ID Number ORDER OF COURT You, MICHELLE CAMERON plaintiff/defendant of 131 N 26TH ST, CAMP HILL, PA. 17011-3617-31 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 ..., C ~1 NOVEMBER 23, 2004 at 9: OOAM for a hearing. Co 3:0 OJ 3:-" You are further required to bring to the hearing: ;~8 z(""') I, a true copy of your most recent Federal Income Tax Retum, including W -2s, as~ "-' 2. your pay stubs for the preceding six (6) months, c-~~ -'-I 3, verification of child care expenses, and ~ 0 4. proof of medical coverage which you may have, or may have available to you -< ~ 5, information relating to professional licenses 6. other: N .J:J Form CM-509 Worker ID 21302 Service Type M PACSES Case Nmnber: 477105994 CAMERON v. CAMERON If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may 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: .-J 0 - \\ -\) '-\ ~'1'o. \ JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELlGmLE 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 of2 Form CM-509 Worker ID 21302 Service Type M >:: t": i:"',t ,,-~; ..-,! '" c:::> C;:.Jl ~ ,-, '..,j -'n ~._j c: 'npg iT) S') C) C) C.') I en ''''\:J :::.1: (:,,' (->J ..-::- In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Phone: (717) 240-6225 DOMESTIC RELATIONS SECTION 13 N. HANOVER ST, P.O. BOX 320, CARUSIE, PA. 17013 Fax: (717) 240-6248 OCTOBER 27, 2004 Plaintiff Name: JOHN W. CAMERON Defendant Name: MICHELLE CAMERON Docket Number: 03-5588 CIVIL PACSES Case Number: 477105994 Other State ID Number: Please note: All correspondence must include the FIACSES Case Number. Notice of a Cancelled Event MICHELLE CAMERON 131 N 26TH ST CAMP HILL PA 17011-3617 Dear MICHELLE CAMERON The 0 Appointment or 0 Conference or G\) Hearing or 0 Exception Argument or o Genetic test or 0 Relisted Event originally scheduled for NOVEMBER 23, 2004 , has been cancelled. Sincerely, R. J. SHADDAY Service Type M Form CM-015 WorkerlD 21302 ~ o :::2~ ,-..",) '__1 ~ ~ \~"'tf9 :3'Q .(:J~() ,,~~~~\ ;0 .,-.:.)r\1 '~::~ "T>' ~a. ~:':'; ~,f! c~) <.,:J In the Court of Common Pleas of CUMBERLAN!) County, Pennsylvania Phone: (717) 240-6225 DOMESTIC RELATIONS SECTION 13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013 Fax: (717) 240-6248 OCTOBER 27, 2004 Plaintiff Name: JOlIN W. CAMERON Defendant Name: MICHELLE CAMERON Docket Number: 03-5588 CIVIL PACSES Case Number: 47710599,1 Other State ID Number: Please Dote: All correspondence must include the JPACSES Case Nwnber. Notice of a Cancelled Event JOlIN W. CAMERON 3806 PAMAY DR MECHANICS BURG PA 17050-7676 Dear JOlIN W. CAMERON The 0 Appointment or 0 Conference or Gtl Hearing or 0 Exception Argument or o Genetic test or 0 Relisted Event originally scheduled for NOVEMBER 23, 2004 , has been cancelled. Sincerely, R. J. SHADDAY Service Type M Fonn CM-OI5 Worker ID 21302 (-, (') '''' ~ (::::) .r' o (') -., ~ :-l .T:_~ n-l~ -;:,n, :))~ (J --.Ie.. "r'-,- '5::i1 ',0 '5rf1 }~ -< 1"'.) '.'..3 :"? (;"? C,) W MICHELLE CAMERON, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - DIVORCE JOHN W. CAMERON, DEFENDANT NO. CIVIL TERM IN DIVORCE PACSES # 477105994 (j(J/J- 03 - 55't8' e I ; , / PRAECIPE - TO THE PROTHONOTARY: Please withdraw without prejudice the Defendant's demand for hearing on alimony pendente lite filed in the above-captioned matter. SMIGEL, ANDERSON & SACKS, LLP Date: 10 )L'1 Jel.{ , I By: L oy migel, Esquire I.D. #09617 Ja R. Demmel, Esquire I.D. #90918 4431 North Front Street Harrisburg, PA 17110-1709 (717) 234-2401 Attorneys for Defendant MICHELLE CAMERON, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - DIVORCE JOHN W. CAMERON, DEFENDANT NO. CIVIL TERM IN DIVORCE PACSES # 477105994 CRRTIFICA TR OF SRRVICR I, James R. Demmel, Esquire, do hereby certify that I served a true and correct copy of the foregoing Praecipe upon the following individuals by depositing same in the U.S. Mail, first class, postage prepaid, on the 29th day of October, 2004, addressed as follows: Cumberland County Domestic Relations Office 13 North Hanover Street P.O. Box 320 Carlisle, PAl 70 13 Samuel L. Andes, Esquire 525 North Twelfth Street Lemoyne, P A 17043 SMIGEL, ANDERSON & SACKS, LLP By: L Smigel, Esquire J.D. #09617 James R. Demmel, Esquire J.D. #90918 4431 North Front Street Harrisburg, P A 17110-1709 (717) 234-2401 Attorneys for Defendant ~ n <,.,;:; D l' ~ f c:f r- ::::--... <::" f' ~ () ~ ...... ".''',' -"'l"' f;! r 1':; ~"'r~- ;;::(' g:1~' /-,>r:, J= ~. :;iC: :s. C) f;: ..7 ~ -0 :::!l: <..> .. CJ'J 'J:) ~ c:;, ..t::"- O n -f N t.O ~ "-of ::C .... izF! o :::rJ a::d ;.;;>>c> C5n'i --I ~" ..l.'1 -< ~ ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State CommonweaLth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 11/12/04 Tribunal/Case Number (See Addendum for case summary) o Original Order/Notice o Amended Order/Notice o Terminate Order/Notice PA MED SOCIETY LIABILITY INS 777 E PARK DR PO BOX 8375 HARRISBURG PA 17105-8375 '1>/(1 ;LlJtJ3 - ~ (>y P/f~5ES 177 /oSCI1'V RE: CAMERON, MICHELLE Employee/Obligor's Name (Last, First, Mil 186-50-2363 Employee/Obligor's Social Security Number 1126101252 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, Mil EmployerMithholder's Federal EIN Number See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 0.00 per month in current support $ 0 . 00 per month in past-due support Arrears 12 weeks or greater? 0 yes ~ no $ 0.00 per month in medical support $ 0 . 00 per month for genetic test costs $ per month in other (specify) for a total of $ 0.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 0.00 per weekly pay period. $ 0.00 per biweekly pay period (every two weeks). $ 0.00 per semimonthly pay period (twice a month). $ 0.00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's! obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #10 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU , P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. :~~::::'D CASH:~~/: lu~-//)~i:;:~~~~ J~~~ Form EN-028 Service Type M OMBNo.:0970-0154 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If ~hecked you are required to provide a ~opy of this form to your employee. If YOl,lr employee works in a state that is ditterent from the state that issued this order, a copy must be provided to your employee even if the box is not checked. 1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned businesses located on a reservation that choose to withhold in accordance with this notice. 2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 4. * Reporting the Paydate/Date of Withholding. You must report the paydate/date of withholding when sending the payii.ent. The paydate/date of withholding is the date on which amount was withheld from the eiTiployee'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. 5. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor 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 #10 below) 6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S ID: 2320056560 EMPLOYEE'S/OBLlGOR'S NAME: EMPLOYEE'S CASE IDENTIFIER: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: CAMERON, MICHELLE 1126101252 DATE OF SEPARATION: 7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 8, Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 10.* Withholding limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U,S.c. ~1673 (b)l; or 2) the amounts allowed by the State of the employee'slobligor'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. 11. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Worker ID $IATT Service Type M OMB No.: 0970-0154 ~.' ~::! ~! ('~ E'. ':j o (-- I' i, 'I \~--; 3 " .. "" c-:;;:) (;: '~.:J .-:;;- 25 o -1) ;:1 hj:rJ T)r:;::; ,~tJ~ -0 ::jl n ~ ;~~ -.:., 0> :0 ..;J.;: ':';) l"...' In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION JOHN W. CAMERON ) Docket Number 03-5588 CIVIL Plaintiff ) VS. ) PACSES Case Number 477105994 MICHELLE CAMERON ) Defendant ) Other State ID Number ORDER AND NOW, to wit, on this 12TH DAY OF NOVEMBER, 2004 IT IS HEREBY ORDERED that the support order in this case be 0 Vacated or o Suspended or ~ Terminated without prejudice or 0 Terminated and Vacated, effective JULY 9, 2004 , due to: THE PLAINTIFF WITHDRAWING HIS CLAIM FOR ALIMONY PENDENTE LITE, WITHOUT PREJUDICE, AND WITHDRAWING HIS DEMAND FOR HEARING DE NOVO BEFORE THE SUPPORT MASTER. THE PARTIES' AGREE THAT THERE IS NO BALANCE DUE ON THIS ACCOUNT AND MONIES RECEIVED ARE TO BE REFUNDED TO THE DEFENDANT. DRa: RJ Shadday xc: plaintiff defendant Leroy Smigel, Esquire Samuel Andes, Esquire , 1r:,,5'."=~'- ___)/ ~/5~CiI- . - BY THE~: ~~ Edgar B. ay y ~ XmGE Service Type M Form OE-504 Worker ID 21005 "~' '." t, '";. ~., ,::... , ~,.;. C) c:; ", C:::::~J c:::..-::> _t:- o -n -'"",,,.. c~'j ::;:1 i'ilf~: -cr r T1 -'iO /1J ~iL; ~~~1 :i; -..;..:;,: CTI :::? <:? 1"'<> ..' ~ .. " 'jl vs. ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MICHELLE CAMERON, Plaintiff CIVIL ACTION - LAW NO. 03-5588 CIVIL TERM JOHN W, CAMERON, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 23 October 2003 and served upon the Defendant on or about 19 November 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant 3, I consent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention 11 to Request Entry of the Decree. 'I i 4, I have been advised of the availability of marriage counseling and understand that I the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct and I understand that false statements herein are made subject to the penalties of 18 Pa. C,S, Section 4904 relating to unsworn falsification to authorities, Lf- 1- oS Date ~chli1.t_ ~ MICHELLE CAMERON t<) 1.''-:,;) C~:) C-J"l (j ,j .>;.. .-:., ~----"' CJ ~.; 1-::; 0''1 II , 'I vs. ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MICHELLE CAMERON, Plaintiff CIVIL ACTION - LAW NO, 03-5588 CIVIL TERM JOHN W. CAMERON, Defendant I I, 1\ 1 1\ AFFIDAVIT OF CONSENT I 1, A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on I 23 October 2003 and served upon the Defendant on or about 19 November 2003, I 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days \ have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant IN DIVORCE 3, I consent to the entry of a final decree in divorce either after service of a Notice of [ Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention ,I to Request Entry of the Decree, II 4, I have been advised of the availability of marriage counseling and understand that I the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct and I understand that false statements herein are made subject to the penalties of 18 Pa. C,S, Section 4904 relating to unsworn falsification to authorities, ~-I- 0';; ~~ Date r-~ {-~ c.r. ?:': C) .1 --l '~~,~ ::--~,1~~ C';~~ .--, , --.,- co ~'1 Ci "< (j"i II ! vs, ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MICHELLE CAMERON, Plaintiff CIVIL ACTION - LAW NO. 03-5588 CIVIL TERM JOHN W, CAMERON, Defendant IN DIVORCE II WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice, 2, I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted, 3, I understand that I will not be divorced until a divorce decree is entered by the court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary, I verify that the statements made in this Waiver are true and correct I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Jf-I-OS Date J.J;u. ct'll n, r .f] AMP A ..tfV\.-1 MICHELLE CAMERON .-, '_.,,-."'} > --, U - c:J --' .' c' (j', - ,- II vs, ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MICHELLE CAMERON, Plaintiff CIVIL ACTION - LAW NO, 03-5588 CIVIL TERM JOHN W, CAMERON, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 IC) OF THE DIVORCE CODE 1, I consent to the entry of a final decree in divorce without notice, 2, I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted, 3, I understand that I will not be divorced until a divorce decree is entered by the court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Waiver are true and correct I understand that false statements herein are subject to the penalties of 18 Pa, C,S, Section 4904 relating to unsworn falsification to authorities, 4'\~6>S" J~. - Date ----- '" C:,) ;.".;..) c.n < ) -/1 ~-T; ;-11 (__~', ~'" f '~: ~'-:J C ' :) I~ ~,:, (_,I :r:'" -';:"1 .,,'-' co 4~ t--', C.n - MICHELLE CAMERON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 03-5588 CIVIL TERM JOHN W. CAMERON, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD r I TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a !divorce decree: 1. Ground for Divorce: Irretrievable breakdown under Section 3301 (c). I, 2. Date and manner of service of the Complaint: Filed 23 October 2003 and served on or I ~bout 19 November 2003. 3. Complete either Paragraph (al or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301 (c) of the ~ivorce Code: by Plaintiff: 1 Aoril 2005 by Defendant: 1 Aoril 2005 . (b) (1) Date of execution of the Affidavit required by Section 3301(d) of the Divorce I ~ode: (2) Date of filing and service of the Plaintiff's Affidavit upon the I' ~espondent: I 4, Related claims pending: None I 5. Complete either (a) or (b): (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Rrcord, a copy of which is attached: i (b) Date Plaintiff's Waiver of Notice in Section 3301 Ic) Divorce was filed with the P~othonotary: Dated 1 Aoril 2005, filed 18 Aoril 2005. Date Defendant's Waiver of Notice in S+ction 3301 (c) Divorce was filed with the Prothonotary: dated 1 A ril 5 filed 18 A ril 2005. D~te: L.( /2-5/ oS- By Samuel L. Andes Attorney for Plaintiff ~. . ~ ~~ , -0\3 -:J \ ,~ :J ~(~{-. -:-.< ..."! \~:~?\ ~, -::::, "-)_1, 0- ..p, ~ Q 0:::"_- ~\__.\ kL_ 'YC_~I ' v", ~ o c: ;~~~ ""'!"1t",;;:\ mf';-' z.:}' -,~ r ~...- ". (.r~ r', r:( - '"'- ~h ""- --! -< ...., = = o:.n ",. -0 :;:<;) N O'l J>> :Jo:: o 11 :2" 1} np- -C,m -')Y r~) '::',Q ,~~~ ..:'.0 :-< '!? N c.n - 'f'+=:t:;+. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . + . + . + + + + + + 'y" ~Jt> + . + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + . + + + + + + + :+:+:t' + :t:~ :t:'+= ~~+++++:t:++:++++:+:+:++:+:++:+++++++ :+:+:++:+++:+++++:+:+:++~:+:+:++:+:+:+:+~:+ :t:+:+++:++:t:+~ + + . + + + + + + + + + . + + . + + + + + + + . + + + . + + + + + + . + . . . . + . + . + + + + . + . + + + . + . . . . + . + + + + . . . . . . . . . . . . . . . . + . . . . . . . . . . . + . + . + + . + . :++:+:++:+:+:+:+:+:+:+++:+:+:++:++:+:+:+:++:+:++:+:+~:t:+:++:+++:++ ++ ++++++++:+++++:++:++:++:+:+++++:+++:+? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA, MICHELLE CAMERON, Plaintiff No. 2003-5588 VERSUS JOHN W. CAMERON, Defendant DECREE IN DIVORCE AND NOW, ~1 MICHELLE CAMERON ~-, IT IS ORDERED AND 2005 DECREED THAT , PLAINTIFF, JOHN W. CAMERON AND , DEFE:NDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH {>, FINAL ORDER HAS NOT YET BEEN ENTERED; NONE / /~-}/~ Bnt:~ ATTEST: --- PROTHONOTARY J, /~' ~~~;' ,'}> j-'7r-"nf il7JJ"y P /' ljJ' /'" (/ - r'!/ .., ;:",,?>t:ll ~P.1Z ~-U' 44r;;-v I v (L-.' F'Z/ y)' 5':1 _9.7 5 ~,-:- ~ vs. ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OIF CUMBERLAND COUNTY, PENNSYLVANIA MICHELLE CAMERON, PLaintiff CIVIL ACTION - LAW NO. 03-5588 CIVIL TERM JOHN W. CAMERON, Defendant 11\1 DIVORCE MOTION FOR ENTRY OF QUALIFIED DOMESTIIC RELATIONS ORDER AND NOW comes the above-named PLaintiff, by her attorney, SamueL L. Andes, and moves this court to enter the attached QuaLified Domestic ReLations Order, based upon the stipuLation of the parties, and their counseL as set forth in the proposed order. ~~ ~ Sam L. Andes Attorney for PLaintiff Supreme Court ID ;1/ 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 .-> [::::; ~ o -1'1 :T!.,., rne 13t~ "'j I '~~~~ ~..,. ...) "(-\-'1 ~,~ "> '_C':J :< o- r:: r.... N 9 U1 o - RECEIVED JUL 131005::1 ~ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Michelle Cameron Plaintiff CML ACTION - LAW VS. NO. 03-5588 John W. Cameron Defendant IN DIVORCE STIP TION FOR THE E AND NOW, this l day of Cameron, Plaintiff and John W. Cameron, Defendant, STI RELATIONS ORDER" ~) ~ parties, Michelle o hereby Agree and Stipulate as follows: 1. The Defendant, John W. Cameron (hereinafter referred to as "Member") is a member of the Commonwealth of Pennsylvania, State Employees' Retirement System (hereinafter referred to as "SERS"). 2, SERS, as a creature of statue, is controlled by the State Employees' Retirement Code, 71 Pa. C.S, ~~5101-5956 ("Retirement Code"). 3. Member's date of birth is January 14, 1948, and his Social Security number is 198-36- 0793. 4. The Plaintiff, Michelle Cameron (hereinafter referred to as "Alternate Payee") is the former spouse of Member. Alternate Payee's date of birth is May 5, 1957, and her Social Security number is IB6-50-2363. 5. Member's last known mailing address is: 3B06 Pamay Drive Mechanicsburg,PA 17050 6. Alternate Payee's current mailing address is: 131 North 26th Street Camp Hill, PA 17011 DRO Page 2 It is the responsibility of the Alternate Payee to keep a current mailing address on file with SERS at all times. 7. The Alternate Payee is entitled to a portion of the Member's benefits under the Plan as set forth below. The Plan is hereby directed to pay Alternate Payee's share directly to Alternate Payee. 8. The Member is currently receiving a monthly annuity for his lifetime pursuant to the terms of Option 2. The parties acknowledge that the Member's retirement option elections are fmal and irrevocable. 9, If the Member dies before the Alternate Payee, the Alternate Payee shall be provided a survivor benefit in accordance with Option 2 elected by the Member upon his retirement, Member reaffirms his selection of Alternate Payee as his survivor annuitant and waives his right to select a new survivor annuitant by reason of his divorce from Alternate Payee. 10. The Alternate Payee is not awarded any portion of the monthly annuity payable to the Member. 11. Member shall execute and deliver to Alternate Payee an authorization, in a form acceptable to SERS, which will authorize SERS to release to Alternate Payee all relevant information concerning Member's retirement account. Alternate Payee shall deliver the authorization to SERS which will allow the Alternate Payee to (:heck that she has been and continues to be named as the survivor annuitant under Option :~. 12, Alternate Payee may not exercise any right, privilege or option offered by SERS, 13. In no event shall Alternate Payee have greater benefits or rights other than those which are available to Member. Alternate Payee is not entitled to any benefits not otherwise provided by SERS. The Alternate Payee is only entitled to the 8pecific benefits offered by SERS as provided in this Order. All other rights, privileges and options offered by SERS not granted to Alternate Payee by this Order are preserved for Member, DRO Page 3 14. It is specifically intended and agreed by the parties heireto that this Order: (a) Does not require SERB to provide any type or form of benefit, or any option not otherwise provided under the Retirement Code; (b) Does not require SERS to provide increased benefits (determined on the basis of actuarial value) unless increased benefits are paid to Member based upon cost of living or increases based on other than actuarial values. 15. The parties intend and agree that the terms of this Stipulation and Agreement shall be approved, adopted and entered as a Domestic Relations Order. 16. The Court of Common Pleas of Cumberland County, Pennsylvania, shall retain jurisdiction to amend any Domestic Relations Order incorporating this Stipulation and Agreement, but only for the purpose of establishing it or maintaining it as a Domestic Relations Order; provided, however, that no such amendment shall requirEl SERB to provide any type or form of benefit, or any option not otherwise provided by SERS, and further provided that no such amendment or right of the Court to so amend will invalidate this existing Order. 17. Upon entry as a Domestic Relations Order, a certified copy ofthe Domestic Relations Order and this Stipulation and Agreement and any attendant documents shall be served upon SERS immediately. The Domestic Relations Order shall take effect immediately upon BERB approval and SERB approval of any attendant documents and th.en shall remain in effect until further Order of the Court. DRO Page 4 WHEREFORE, the parties, intending to be legally bound by the term and Agreement, do hereunto place their hands and seals. BYtOURT ~ D~ A~~=bm VVL.:. chit 1 Q (c::umvurv-- Plaintiff/Alternate Payee , Stipulation >: ~ (:) \..L\~'< o~, S~~: ~6~ w"- ~\JJ u-fS ..:r o c;.. :1C :.a: U- o 11 t\ - ~ "p~ . f:1 ~ l v\. S> i.J P ~ .:S r c.-:: /- ."~,,:j' (.~~1t ~~ ~~ '-;~? L: __I :::. -, or.> = = ..... ;j(:] :.::,;} 0- -:.~--:. ,..) (J