HomeMy WebLinkAbout08-02651
VALERIE S. STACKNICK,
Plaintiff
VS.
MATTHEW R. STACKNICK,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 0 £- aGS C1?11 -7Z-
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 foregoing 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 in divorce or annulment may be
entered against you by the court. A judgment may also be entered against you for any
other claim or relief requested in these papers by the Plaintiff. You may lose money or
property or other rights important to you, including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is
!! available in the Office of the Prothonotary at:
Office of the Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY , DIVISION OF PROPERTY, 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
Telephone: (717) 249-3166
VALERIE S. STACKNICK,
Plaintiff
I
VS.
MATTHEW R. STACKNICK,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. J e - -?-76 S &?J
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed
in the court of Common Pleas of Cumberland County. This notice is to advise you that in
accordance with Section 3302 (d) of the Divorce Code, you may request that the court
require you and your spouse to attend marriage counseling prior to a divorce being
handed down by the court. A list of professional marriage counselors is available at the
jj Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are
advised that this list is kept as a convenience to you and you are not bound to choose a
counselor from this list. All necessary arrangements and the cost of counseling sessions
are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling
within twenty days of the date on which you receive this notice. Failure to do so will
constitute a waiver of your right to request counseling.
?. A
VALERIE S. STACKNICK,
Plaintiff
VS.
MATTHEW R. STACKNICK,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. -7,., ,,
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, VALERIE S. STACKNICK, by her
attorney, Samuel L. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is VALERIE S. STACKNICK, an adult individual who currently
resides in Cumberland County, Pennsylvania.
2. The Defendant is MATTHEW R. STACKNICK, an adult individual who currently
resides at 646 Old Grove Road in Mechanicsburg, Cumberland County, Pennsylvania.
3. Both the Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for at least six months immediately previous to the filing
of this Complaint.
4. The Plaintiff and Defendant were married on 29 October 1977 in
Mechanicsburg, Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of marriage counseling and the
Plaintiff may have the right to request that the Court require the parties to participate in
counseling.
COUNT I - IRRETRIEVABLE BREAKDOWN
8. The Plaintiff requests this Court to enter a Decree in Divorce.
WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to
the Divorce Code of Pennsylvania.
2, - - - - G?? - 0",
uel L. An s
Attorney for Plaintiff
Supreme Court ID # 17225
525 North 12th Street
Lemoyne, Pa 17043
(717) 761-5361
I verify that the statements made in this Complaint are true and correct. I
understand that any false statements in this Complaint are subject to the penalties of 18
Pa. C.S. 4904 (unsworn falsification to authorities).
Date: OAA'A,,?QQF
?r?,cuul? ?atcC,?
VALERIE S. STACKNICK
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C-n
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-00265 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
STACKNICK VALERIE S
VS
STACKNICK MATTHEW R
MICHAEL BARRICK , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly swo6 according to law,
says, the within COMPLAINT - DIVORCE was ser?ed upon
STACKNICK MATTHEW R the
DEFENDANT at 1334:00 HOURS, on the 29th dayiof January 2008
at 842 W CHURCH STREET
MECHANICSBURG, PA 17055-4088
MATTHEW STACKNICK
by handin? to
a true and attested copy of COMPLAINT - DIVORCE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 9.60
Postage .58
Surcharge 10.00
.00
.210Y167 ; , 38.18
Sworn and Subscibed to
before me this day
So Answers:,
R Thinma a K1 i ne
01/30/2
SAMUEL .
By
of A. D.
F
VALERIE S. STACKNICK,
Plaintiff
V.
MATTHEW R. STACKNICK,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. FC 08-265 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the
claims set forth in the following pages, you must take prompt action. You are
warned that if you fail to do so, the case may proceed without you and a decree
of divorce or annulment may be entered against you by the court. A judgment
may also be entered against you for any other claim or relief requested in these
papers by the plaintiff. You may lose money or property or other rights important
to you, including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of
the marriage, you may request marriage counseling. A list of marriage
counselors is available in the Office of the Prothonotary, Cumberland County
Courthouse, Hanover and High Streets, Carlisle, PA 17013.
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
0
1
VALERIE S. STACKNICK, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vi. : NO. FC 08-265 CIVIL TERM
MATTHEW R. STACKNICK, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
NOTICIA
Le han Demando a usted en la corte. Si usted quiere defenderse de estas
demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de
plazo al partir de la fecha de la demanda y la notificacion. Usted deve presentar
una apariencia excrita o en persona o por abogado y archivar en to corte en
forma escrita sus defensas o sus objeciones a las demandas en contra de su
persona. Sea avisado que si usted no se defiende, la corte tomara medidas y
puede entrar una orden contra usted sin previo aviso o notificacion y por
cualquier queja o alivio que es pedido en la peticion do demanda. Usted puede
perder dinero o sus propiedades o otros derechos importanates para usted
LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL
SERVICIO, VAYA EN PERSONA O LLAME POR TELFONO A LA OFICINA
CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR
DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
2
VALERIE S. STACKNICK, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vii. : NO. FC 08-265 CIVIL TERM
MATTHEW R. STACKNICK, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
ANSWER
AND NOW, comes the Defendant, MATTHEW R. STACKNICK, by his
attorney, Mindy S. Goodman, Esquire, and files the following Answer and asserts
the following allegations:
1. Admitted upon information and belief.
2. Admitted.
3. Admitted.
4. Admitted.
5. Defendant has not previously filed for divorce or annulment and has
no knowledge of a Plaintiff having previously filed for divorce or annulment.
6. Admitted upon information and belief.
7. Defendant cannot admit or deny statements regarding what advice
Plaintiff has received with regard to counseling or any other matter.
8. No response required.
3
COUNTER CLAIMS AND NEW MATTER
COUNT I - DIVORCE SECTION 3301(a)(2)
9. The averments of paragraphs 1 through 8 above are incorporated
herein by reference as if set forth in full.
10. Plaintiff has committed adultery in violation of the marriage vows.
WHEREFORE, Defendant requests this Honorable Court enter a Decree
of Divorce in his favor.
COUNT 11
EQUITABLE DIVISION, DISTRIBUTION AND
ASSIGNMENT OF MARITAL PROPERTY
11. The averments of paragraphs 1 through 10 above are incorporated
herein by reference as if set forth in full.
12. The parties are the owners of various items of property which
qualify as martial property as defined in the Divorce Code.
13. Said marital property is subject to equitable division, distribution
and assignment by the Court.
4
r
WHEREFORE, the Defendant requests this Honorable Court equitably
divide, distribute and assign the parties' marital property.
COUNT III
ALIMONY PENDENTE LITE, SUPPORT,
COUNSEL FEES AND EXPENSES
14. The averments of paragraphs 1 through 13 above are incorporated
herein by reference as if set forth in full.
15. By reason of this action, Defendant will be put to considerable
expense in the preparation of his case, in the employment of counsel and the
payment of costs.
16. Defendant is without sufficient funds to support himself and to meet
the costs and expenses of this litigation and is unable to appropriately maintain
himself during the pendency of this action.
17. Defendant's income is not sufficient to provide for his reasonable
needs and pay attorneys' fees and the costs of this litigation.
18. Plaintiff has adequate earnings to provide support and alimony
pendente lite for Defendant and to pay his counsel fees, costs, and expenses of
this action.
5
WHEREFORE, Defendant requests this Honorable Court compel Plaintiff
to pay Defendant alimony pendente lite, support, counsel fees, costs and
expenses of this action.
Respectfully submitted,
Mindy S. Goodman
Attorney at Law
ID No. 78407
2215 Forest Hills Drive - Suite 35
Harrisburg, PA 17112
(717) 540-8742
Attorney for Defendant
6
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VERIFICATION
I verify that the statements made in this Answer, Counterclaims and New
Matter are true and correct. I understand that false statements herein are
made subject to the penalties of 18 Pa. Cons. Stat. § 4904, relating to
unsworn falsification to authorities.
? P I I 111-e-?' ",.
D lei
DATE: -
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
MATTHEW R. STACKNICK ) Docket Number 08-265 CIVIL
Plaintiff )
vs ) PACSES Case Number 3 5 910 9 8 3 8
VALERIE S. STACKNICK )
Defendant ) Other State ID Number
ORDER OF COURT
You, VALERIE S. STACKNICK
624 HERITAGE CT, MECHANICSBURG, PA. 17050-1856-24
are ordered to appear at DOMESTIC RELATIONS HEARING RM
DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA
before a hearing officer of the Domestic Relations Section, on the
APRIL 22, 2008
at 8: 3 OAM for a hearing.
You are further required to bring to the hearing:
plaintiff/defendant,
Q
17013-3014-1 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 21302
STACKNICK V•STACKNICK
PACSES Case Number: 359109838
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'i j t'? ,
J. ESLEY OLE JR., 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) 2 4 0 - 6 2 2 5 . 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 21302
.1i A
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
MATTHEW R. STACKNICK ) Docket Number 08-265 CIVIL
Plaintiff )
VS. ) PACSES Case Number 359109838
VALERIE S. STACKNICK )
Defendant ) Other State ID Number
ORDER OF COURT
You, MATTHEW R. STACKNICK plaintiff/defendant of
646 OLD GROVE RD, MECHANICSBURG, PA. 17055-4088-46
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are ordered to appear at DOMESTIC RELATIONS HEARING RM s
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DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-i-3•
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before a hearing officer of the Domestic Relations Section, on the -71
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APRIL 22, 2008 at 8:3OAM for a hearing. c%)
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 21302
STACKNICK V• STACKNICK PACSES Case Number: 359109838
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: 2
L ' L77 -o?Ss vC/
J. W SLEY OLE , JR., 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) 2 4 0 - 6 2 2 5 . 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. 1
Service Type M Worker ID 21302
U
VALERIE S. STACKNICK, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. FC 08-265 CIVIL TERM
MATTHEW R. STACKNICK, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
ORDER
AND NOW, this day of
2008, the
Motion to Refer APL Matter to Domestic Relations is GRANTED and the
Prothontary is directed to transfer the appropriate documentation to the Office of
Domestic Relations.
J
i
VALERIE S. STACKNICK,
Plaintiff
V.
MATTHEW R. STACKNICK,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. FC 08-265 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
MOTION TO REFER APL MATTER TO DOMESTIC RELATIONS
AND NOW, comes the Defendant, MATTHEW R. STACKNICK, by his
attorney, Mindy S. Goodman, Esquire, and files the following Motion to Refer
APL Matter to Domestic Relation and in support thereof avers as follows:
1. A Complaint in Divorce was filed by Plaintiff on or about January
15, 2008.
2. On or about January 28, 2008 Defendant filed for spousal support
with the Office of Domestic Relations.
3. Defendant filed an Answer with Counterclaims and New Matter on
or about February 25, 2008.
4. Contained within Defendant's Answer with Counterclaims and New
Matter was a claim for alimony pendente lite.
5. Defendant provided a copy of his Answer with Counterclaims and
New Matter, including the claim for alimony pendente lite, directly to the
conference officer when he appeared at the spousal support conference on
February 25, 2008.
1
6. Counsel for Defendant just received the information necessary to
complete the DRS Attachment for APL Proceedings required by the Office of
Domestic Relations and requests that the APL claim be referred to the Office of
Domestic Relations for entry of an APL Order.
WHEREFORE, Defendant requests that the alimony pendente lite (APL)
matter be referred to the Office of Domestic Relations for entry of an APL Order.
Respectfully submitted,
;;?'
I ,,.iX-
Mindy S. Goodman
Attorney at Law
ID No. 78407
2215 Forest Hills Drive - Suite 35
Harrisburg, PA 17112
(717) 540-8742
Attorney for Defendant
2
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Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
VALERIE S. STACKNICK, : IN THE COURT OF COMMON PLEAS
Plaintiff,
V.
MATTHEW R. STACKNICK,
Defendant
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08 - 265
: CIVIL ACTION -LAW
IN DIVORCE
PRAECIPE TO WITHDRAW APPEARANCE
Please withdraw my appearance on behalf of Defendant, Matthew R. Stacknick, in the above-
captioned matter.
Dated: W ` Z 1 92008
Respectfully submitted,
Mindy S. Goodman, Esquire
Northwood Office Center
(717) 540-8742
Supreme Court I.D. 78407
2215 Forest Hills Drive, Suite 35
Harrisburg PA 17112
PRAECIPE TO ENTER APPEARANCE
Please enter my appearance on behalf of Defendant, Matthew R. Stacknick, in the above-
captioned matter.
Dated:, 2008
Iraarbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
Supreme Court I.D. 32317
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
VALERIE S. STACKNICK, IN THE COURT OF COMMON PLEAS
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
V.
MATTHEW R. STACKNICK,
Defendant
NO. 08 - 265
CIVIL ACTION -LAW
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 a Praecipe to Enter Appearance, in the above-captioned
matter upon the following individual, by United States first-class mail, postage prepaid,
addressed as follows:
DATE: , 2008
Samuel L. Andes, Esquire
P.O. Box 168
Lemoyne, PA 17043
Barbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070-1931
(717) 774-1445
Supreme Court I.D. 32317
Attorney for Defendant
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
MATTHEW R. STACKNICK ) Docket Number 08-265 CIVIL
Plaintiff )
Vs. ) PACSES Case Number 359109838
VALERIE S. STACKNICK )
Defendant ) Other State ID Number
ORDER OF COURT - RESCHEDULE A HEARING
You, VALERIE S. STACKNICK
624 HERITAGE CT, MECHANICSBURG, PA. 17050-1856-24
are ordered to appear at DOMESTIC RELATIONS HEARING RM
of
DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13
on the 15TH DAY OF MAY, 2008
at 8: 3 OAM for a hearing. This date replaces
the prior hearing date of APRIL 22, 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
STACKNICK V. STACKNICK PACSES Case Number: 359109838
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: 1/, ,1 `? . Sao
J WESLEY OL R, JR., JUDGE
YOU HAVE THE RIGHT TO A IjkWYER, 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-514 Rev.
Service Type M Worker ID 21302
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
MATTHEW R. STACKNICK ) Docket Number 08-265 CIVIL
Plaintiff )
vs. ) PACSES Case Number 359109838
VALERIE S. STACKNICK )
Defendant ) Other State ID Number
ORDER OF COURT - RESCHEDULE A HEARING
You, MATTHEW R. STACKNICK
646 OLD GROVE RD, MECHANICSBURG, PA. 17055-4088-46
are ordered to appear at DOMESTIC RELATIONS HEARING RM
of
DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13
on the 15TH DAY OF MAY, 2008
at 8: 3 OAM for a hearing. This date replaces
the prior hearing date of APRIL 22, 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
STACKNICK V. STACKNICK PACSES Case Number: 359109838
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: VuL 1 S o
J. ESLEY OLER, . , 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-514 Rev. 1
Service Type M Worker ID 21302
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MATTHEW R. STACKNICK,
Plaintiff
V.
VALERIE S. STACKNICK,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: DOMESTIC RELATIONS SECTION
PACSES NO. 790109771
DOCKET NO. 77 SUPPORT 2008
VALERIE S. STACKNICK, : IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA
V. : DOMESTIC RELATIONS SECTION
MATTHEW R. STACKNICK, : PACSES NO. 359109838
Defendant/Petitioner : DOCKET NO. 08-265 CIVIL
INTERIM ORDER OF COURT
AND NOW, this Alf?ay of May, 2008, upon consideration of the
Support Master's Report and Recommendation, a copy of which is attached hereto as
Exhibit "A", it is ordered and decreed as follows:
A. The Husband's complaint for spousal support is dismissed.
B. The Wife shall pay to the Pennsylvania State Collection and Disbursement Unit as
alimony pendente lite the sum of $754.00 per month.
C. The Wife shall pay to the Pennsylvania State Collection and Disbursement Unit
the additional sum of $46.00 per month on arrearages.
D. The effective date of this order is March 15, 2008.
IMPORTANT LEGAL NOTICE
PARTIES MUST WITHIN SEVEN DAYS INFORM THE DOMESTIC
RELATIONS SECTION AND THE OTHER PARTIES, IN WRITING, OF ANY
MATERIAL CHANGE IN CIRCUMSTANCES RELEVANT TO THE LEVEL OF
SUPPORT OR THE ADMINISTRATION OF THE SUPPORT ORDER, INCLUDING,
BUT NOT LIMITED TO, LOSS OR CHANGE OF INCOME OR EMPLOYMENT
AND CHANGE OF PERSONAL ADDRESS OR CHANGE OF ADDRESS OF ANY
CHILD RECEIVING SUPPORT. A PARTY WHO WILLFULLY FAILS TO REPORT
A MATERIAL CHANGE IN CIRCUMSTANCES MAY BE ADJUDGED IN
CONTEMPT OF COURT, AND MAY BE FINED OR IMPRISONED.
PENNSYLVANIA LAW PROVIDES THAT ALL SUPPORT ORDERS SHALL
BE REVIEWED AT LEAST ONCE EVERY THREE (3) YEARS IF SUCH REVIEW IS
REQUESTED BY ONE OF THE PARTIES. IF YOU WISH TO REQUEST A
REVIEW AND ADJUSTMENT OF YOUR ORDER, YOU MUST DO THE
FOLLOWING: CALL YOUR ATTORNEY. AN UNREPRESENTED PERSON WHO
WANTS TO MODIFY (ADJUST) A SUPPORT ORDER SHOULD CONTACT THE
DOMESTIC RELATIONS SECTION. ALL CHARGING ORDERS FOR SPOUSAL
SUPPORT AND ALIMONY PENDENTE LITE, INCLUDING UNALLOCATED
ORDERS FOR CHILD AND SPOUSAL SUPPORT OR CHILD SUPPORT AND
ALIMONY PENDENTE LITE, SHALL TERMINATE UPON DEATH OF THE
PAYEE.
A MANDATORY INCOME ATTACHMENT WILL ISSUE UNLESS THE
DEFENDANT IS NOT IN ARREARS IN PAYMENT IN AN AMOUNT EQUAL TO
OR GREATER THAN ONE MONTH'S SUPPORT OBLIGATION AND (1) THE
COURT FINDS THAT THERE IS GOOD CAUSE NOT TO REQUIRE IMMEDIATE
INCOME WITHHOLDING; OR (2) A WRITTEN AGREEMENT IS REACHED
BETWEEN THE PARTIES WHICH PROVIDES FOR AN ALTERNATE
ARRANGEMENT.
UNPAID ARREARAGE BALANCES MAY BE REPORTED TO CREDIT
AGENCIES. ON AND AFTER THE DATE IT IS DUE, EACH UNPAID SUPPORT
PAYMENT SHALL CONSTITUTE, BY OPERATION OF LAW, A JUDGMENT
AGAINST YOU, AS WELL AS A LIEN AGAINST REAL PROPERTY. IT IS
FURTHER ORDERED THAT, UPON PAYOR' S FAILURE TO COMPLY WITH
THIS ORDER, PAYOR MAY BE ARRESTED AND BROUGHT BEFORE THE
COURT FOR A CONTEMPT HEARING; PAYOR'S WAGES, SALARY,
COMMISSIONS, AND/OR INCOME MAY BE ATTACHED IN ACCORDANCE
WITH LAW. PAYOR IS RESPONSIBLE FOR COURT COSTS AND FEES.
The parties are hereby advised that they may file written exceptions to the
Support Master's Report and Recommendation within twenty (20) days of this order.
Exceptions shall conform with the requirements of Rule 1910.12(f), Pa. R.C.P. If written
exceptions are filed by any party, the other party may file exceptions within twenty (20)
days of the date of service of the original exceptions. If no exceptions are filed within
twenty (20) days of this interim order, this order shall then constitute a final order.
By the Court_
Cc: Matthew R. Stacknick
Valerie S. Stacknick
Barbara Sumple-Sullivan, Esquire
For the Plaintiff
Samuel L. Andes, Esquire
For the Defendant
DRO
MATTHEW R. STACKNICK,
Plaintiff
V.
VALERIE S. STACKNICK,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DOMESTIC RELATIONS SECTION
PACSES NO. 790109771
DOCKET NO. 77 SUPPORT 2008
VALERIE S. STACKNICK, : IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA
V. : DOMESTIC RELATIONS SECTION
MATTHEW R. STACKNICK, : PACSES NO. 359109838
Defendant/Petitioner : DOCKET NO. 08-265 CIVIL
SUPPORT MASTER'S REPORT AND RECOMMENDATION
Following a hearing held before the undersigned Support Master on
May 15, 2008, the following report and recommendation are made:
FINDINGS OF FACT
1. The Petitioner is Matthew R. Stacknick, who resides at 646 Old Grove Road,
Mechanicsburg, Pennsylvania; he will hereafter be referred to as "the Husband."
2. The Respondent is Valerie S. Stacknick, who resides at 624 Heritage Court,
Mechanicsburg, Pennsylvania; she will hereafter be referred to as "the Wife."
3. The parties were married on October 29, 1977.
4. The parties separated on November 10, 2007 when the Wife left the marital
residence.
5. The Wife filed a complaint for divorce on January 15, 2008.
6. The Husband filed a complaint for spousal support on January 28, 2008.
7. On February 25, 2008 the Husband filed an Answer to the complaint which contained
therein a claim for alimony pendente lite.'
At the hearing before this Master the Husband orally withdrew his claim for spousal support and elected to
proceed only on his claim for alimony pendente lite. The parties stipulated to an effective date of March 15,
2008 if entitlement to alimony pendente lite was found.
EXHIBIT "A"
8. The Husband is employed by the Borough of Mechanicsburg where he has a gross
bi-weekly salary of $1,688.69.
9. The Husband pays union dues of $27.00 per month.
10. The parties own a rental property located at 425 South High Street, Mechanicsburg,
Pennsylvania.
11. The Husband receives monthly rental payments in the amount of $625.00.
12. The Husband gives the wife $294.00 per month to pay the monthly mortgage
payment on said property.
13. The Husband pays the real estate taxes and insurance on said property.
14. The parties own a residential property located at 938 Allenview Drive,
Mechanicsburg, Pennsylvania where the parties' son resides.
15. The parties receive no rental income on this property.2
16. The Wife pays the mortgage and real estate taxes on this property.
17. The parties own commercial real estate located at 4705 East Trindle Road,
Mechanicsburg, Pennsylvania.
18. The Wife is the sole stockholder of Cornerstone Land Transfer, Inc., a Pennsylvania
subchapter S corporation, hereafter referred to as "Cornerstone."
19. Cornerstone occupies said commercial real estate.
20. In lieu of rent said corporation pays the mortgage, real estate taxes, insurance and
maintenance on said property.
21. The Wife received $52,437.50 in wages from Cornerstone in 2007.
22. The Wife has a minority ownership interest in Select Land Transfer, LLC.
23. The Wife received wages from Select Land Transfer in 2007 of $6,800.00.
24. The Wife received use of a vehicle from Cornerstone in 2007 with the value of said
perquisite being set at $6,230.00.
2 The rental income of $15,600.00 shown on Schedule E of the parties' 2007 federal income tax return is a
fictitious number employed by the parties' tax preparer.
2
25. The Wife has an investment account with Solomon Smith Barney valued at
approximately $400,000.00.
26. The Wife had investment income from said account in 2007 totaling $17,025.00.3
DISCUSSION
In Clouse v. Clouse, 50 Cumberland L.J. 167, 170 (2001) the Honorable J.
Wesley Oler discussed the law of Pennsylvania as it relates to the subject of alimony
pendente lite wherein he stated:
The determination of whether to award alimony pendente lite has
traditionally been a matter within the sound discretion of the trial court.
Litmans v. Litmans, 449 Pa. Superior Ct. 209, 222, 673 A.2d 382, 388 (1996)
(citing Murphy v. Murphy, 410 Pa. Superior Ct. 146, 599 A.2d 647 (1991),
appeal denied, 530 Pa. 633, 606 A.2d 902 (1992), cert. denied, 506 U.S. 868,
113 S.Ct. 196, 121 L.Ed. 2d 139 (1992)). APL is based on the need of one
spouse to have the financial resources to pursue or defend a divorce action.
Litmans, supra at 222, 763 A.2d at 388. The claimant must show that APL is
needed to adequately preserve his or her rights in the litigation. Sutliff v.
Sutliff, 326 Pa. Superior Ct. 496, 500, 474 A.2d 599, 600 (1984), overruled on
other rounds, Rosen v. Rosen, 520 Pa. 19, 549 A.2d 561 (1988). In this
regard, the Pennsylvania Superior Court has stated that "a spouse seeking
alimony pendente lite who has sufficient assets to meet the needs of the
pending litigation and who is equally situated with the other spouse to
maintain or defend the action, will not be awarded alimony pendente lite."
Powers v. Powers, 419 Pa. Superior Ct. 464, 467, 615 A.2d 459, 460 (1992).
In adjudicating a claim for alimony pendente lite, a court should
consider the following factors: "the ability of the other party to pay; the
separate estate and income of the petitioning party; and the character,
situation, and surroundings of the parties." Litmans, supra. at 224, 673 A.2d
at 389.
Once entitlement to an award of alimony pendente lite is established, the calculation of the
amount of the award is made pursuant to the support guidelines. Little v. Little, 47
Cumberland L.J. 131 (1998).
The Husband has gross monthly earnings of $3,659.00 from his employment with the
Borough of Mechanicsburg. He also receives a gross rental check of $625.00 from the tenant
of property at 425 South High Street, Mechanicsburg. From this sum he gives the Wife
$294.00 to pay the monthly mortgage. He pays approximately $30.00 per month on taxes
and insurance on the property.4 This leaves him with a balance of $301.00 per month in net
rental income which he utilizes for his own purposes. Combining this with his wages results
s Said income consisted of $7,382.00 in interest and $9,643.00 in dividends.
4 See Petitioner's Exhibit 2.
in gross monthly income of $3,960.00. With a tax filing status of married/separate, the
Husband has net monthly income for support purposes of $3,019.00.5
The Husband claims monthly expenses exceeding $4,500.00. Although those
expenses are viewed as inflated,6 his monthly income is not adequate to pay his actual
expenses.
The Wife has gross monthly wages totaling $4,947.00 from Cornerstone and Select
Land Transfer. She also has an automobile perquisite from Cornerstone valued at $567.00
per month. Perquisites such as personal automobile expenses constitute income for support
purposes. Calabrese v. Calabrese, 682 A.2d 393 (Pa. Super. 1996). In addition to her
income from employment the Wife has investment income totaling $1,419.00 per month.
Her gross monthly income for support purposes is $6,875.00. The pass through loss and
income from Cornerstone and Select Land Transfer respectively are not treated as income for
support purposes where those funds are not actually available to or received by the Wife.
See, e.g_ Fennell v. Fennell, 753 A.2d 866 (Pa. Super. 2000). There was no evidence
presented that the Wife manipulated her salary, perquisites, corporate expenditures or
corporate distributions in an effort to avoid a support obligation. The corporate distribution
of $31,401.00 withdrawn by the Wife from her partner's capital account with Select Land
Transfer in 2007 is, in the opinion of this Master, addressed more appropriately in equitable
distribution.
With gross monthly income as set forth above and filing her federal income tax return
as married/separate, the Wife has net monthly income for support purposes of $4,905.00.7
The Wife is claiming monthly expenses of $3,975.00.8 Consequently she has the present
ability to pay alimony pendente lite.
With the net monthly incomes as set forth above and no minor children of the
marriage, the Wife's obligation for alimony pendente lite calculated in accordance with the
support guidelines is $754.00 per month.9
RECOMMENDATION
A. The Husband's complaint for spousal support is dismissed.
B. The Wife shall pay to the Pennsylvania State Collection and Disbursement Unit as
alimony pendente lite the sum of $754.00 per month.
C. The Wife shall pay to the Pennsylvania State Collection and Disbursement Unit the
additional sum of $46.00 per month on arrearages.
5 See Exhibit "A" for the tax deductions from gross income.
6 For example, the Defendant is not incurring the pool maintenance expense of $200.00 per month, the
household help expense of $40.00 per month or the entertainment expense of $200.00 per month.
See Exhibit "A" for the tax deductions from gross income. The pass through loss from Cornerstone will not
be utilized to reduce the Wife's income for support purposes.
8 See Respondent's Exhibit 4.
9 See Exhibit "B" for the calculation.
4
D. The effective date of this order is March 15, 2008.
? , 260c3
Date
Michael R. Rundle
Support Master
In the Court of Common Pleas of Cumberland County, Pennsylvania
Tax Detail Report
Plaintiff Name: Matthew R. Stacknick
Defendant Name: Valerie S. Stacknick
Docket Number: 08-265 Civil
PACSES Case Number: 359109838
Other State ID Number:
Tax Year: Current: 2008
1. Tax Method
2. Fling Status
3. Who Claims the Exemptions
_4. Number of Exemptions
5. Monthly Taxable Income
6. Deductions Method
7. Deduction Amount
8. Exemption Amount
9. Income MINUS Deductions and Exem
10. Tax on income
11. Child Tax Credit
12. Manual Adjustments to Taxes
13. Federal Income Taxes
13 a. Earned Income Credit
14. State Income Taxes
15. FICA Payments
16. City Where Taxes Apply
1040 ES 1040 ES
Married Filing Married Filing
Separately Separately
Obli ee
1 1
$61874.50 $3,959.80
Standard Standard
$454.17 $454.17
$291.67 $291.67
S $6,128.66 $3,213.96
$1,247.03 $498.81
61,247.
$217.2 M
$450.3
3 $279.90
--Select 17. Local Income Taxes
SuMortCak 2007
$54.56 $36.59
TOTAL Taxes $1,969.15 $940.43
EXHIBIT "A"
In the Court of Common Pleas of Cumberland County, Pennsylvania
Spousal Support Calculation
Rule 1910.16
(PACSES FORMAT)
Plaintiff Name: Matthew R. Stacknick
Defendant Name: Valerie S. Stacknick
Docket Number: 08-265 Civil
PACSES Case Number: 359109838
Other State ID Number:
1.Obligor's Monthly Net Income
$4,905.35
2. Less All Other Support
3. Less Obli ee's Month! Net Income
$3,019.37
4. Difference
$1,885.98
5. Less Child Su ort Obligation for Current Case
6. Difference
$1,885.98
7. Multiply b 30% or 40%
40.00%
8. Income Available for Spousal Support $754.39
9. Adjustment for Other Expenses
10. AMOUNT OF MONTHLY SPOUSAL SUPPORT OR APL
$754.39
Prepared b : mrr
Date: 5/16/2008
SuMortCak 2008
EXHIBIT "B"
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MATTHEW R. STACKNICK,
Plaintiff
V.
VALERIE S. STACKNICK,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DOMESTIC RELATIONS SECTION
PACSES NO. 790109771
DOCKET NO. 77 SUPPORT 2008
VALERIE S. STACKNICK, : IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA
V. DOMESTIC RELATIONS SECTION
MATTHEW R. STACKNICK, : PACSES NO. 359109838
Defendant/Petitioner : DOCKET NO. 08-265 CIVIL
INDEX OF EXHIBITS
Petitioner's 1 - 2007 W-2 and current earnings statement
Petitioner's 2 - Income and expense statement
Petitioner's 3 - Miscellaneous tax documents
Respondent's 1 - Petitioner's income and expense statement from support conference
Respondent's 2 - Parties' 2007 federal tax return
Respondent's 3 - Cornerstone Land Transfer corporate tax return
Respondent's 4 - Expense statement
Respondent's 5 - Pay statement
Respondent's 6 - Cornerstone income and expense analysis
Respondent' 7 - Cornerstone business structure
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsylvania 359109838 O Original Order/Notice
Co./City/Dist. of CUMBERLAND 08-265 CIVIL O Amended Order/Notice
Date of Order/Notice 05/23/08 O Terminate Order/Notice
Case Number (See Addendum for case summary)
RE: STACKNICK, VALERIE S.
Employer/Withholder's Federal EIN Number Employee/Obligor's Name (Last, First, MI)
CORNERSTONE LAND TRANSFER INC
4705 E TRINDLE RD
MECHANICSBURG PA 17050-3616
194-42-8357
Employee/Obligor's Social Security Number
6405101930
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.
$ 754.00 per month in current support
$ 46. oo per month in past-due support Arrears 12 weeks or greater? Dyes ® no
$ 0.00 per month in current and past-due medical support
$ o . 00 per month for genetic test costs
$ 0.00 per month in other (specify)
for a total of $ 800.00 per month to be forwarded to payee a ow.
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:
$ 184.62per weekly pay period.
$ 369.23per biweekly pay period (every two weeks).
$ 400.0o per semimonthly pay period (twice a month).
$ 800. 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. S 4374(b)) to remit by electronic payment method, please call
Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580
for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BY THE COURT:
Date of Order: xo ?--r
-? J. ley 018r, Jr f, Judge
DRO: R.J. Shadday Form EN-028 Rev. 1
Service Type M OMB No.: 0970-0154 Worker ID $IATT
804• x
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164.62*
804= x
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
? Me' ecW you are required to U vide a?opy of this form to your mployee. If yo r employee works in a state that is
rent rom the state that tssu this o er, a copy must be provi?ed to your employee even if the box is not checked.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employeelobligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employee/obligor.
3.* Reporting the Paydate/Date of Withholding: You must report the paydate/date of withholding when sending the payment. The
paydate/date of withholding is the date on which amount was withheld from the employee's wages. You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4.* Employee/obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employee obligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2517518210
EMPLOYEE'S/OBLIGOR'S NAME: STACKNICK VALERIE S.
EMPLOYEE'S CASE IDENTIFIER: 6405101930 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employeelobligor from employment,
refusing to employ, or taking disciplinary action against any 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.
I I-Submitted By:
DOMESTIC RELATIONS SECTION
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
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
Service Type M
Page 2 of 2
Form EN-028 Rev. 1
Worker ID $IATT
OMB No.: 0970-0154
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: STACKNICK, VALERIE S.
PACSES Case Number 359109838
Plaintiff Name
MATTHEW R. STACKNICK
Docket Attachment Amount
08-265 CIVIL $ 800.00
Child(ren)'s Name(s): DOB
?Ifchecked, 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
$ o.oo
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 ase 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 Rev. 1
OMB No.: 0970-0154 Worker I D $ IATT
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VALERIE S. STACKNICK,
Plaintiff
VS.
MATTHEW R. STACKNICK,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNA.
DOMESTIC RELATIONS SECTION
PACSES 359109838
DOCKET NO. 08-265 CIVIL
PETITION TO TERMINATE OR MODIFY
ORDER FOR ALIMONY PENDENTE LITE
AND NOW comes the above-named Plaintiff, Valerie S. Stacknick, by her attorney, Samuel L.
Andes, and petitions the Court to terminate or modify the order for alimony pendente lite previously
entered in this matter, based upon the following:
The Petitioner herein is Valerie S. Stacknick, Plaintiff in the above matter (hereinafter
"Wife"). The Respondent is the Defendant, Matthew R. Stacknick (hereinafter "Husband").
2. On 22 May 2008, this Court, on the recommendation of the support master, entered an order
obligating Wife to pay alimony pendente lite to Husband. A copy of that order, and the decision of the
support master, is attached hereto and marked as Exhibit A.
3. The decision and recommendation of the support master was based, in part, upon his finding
that Husband was unable to meet his reasonable living expenses without financial contribution from Wife.
4. Since the entry of that order for alimony pendente lite, Husband's financial circumstances
have changed significantly and he is no longer entitled to alimony pendente lite as a result. The changes
in Husband's circumstances include:
A. He has moved his girlfriend/paramour and her child into the marital residence
which Husband currently occupies.
B. As a result of moving his friend into the residence, his living expenses have
been diminished or offset by contributions from the friend.
C. Husband has demonstrated, by his indirect support of his friend and her child,
that he does not require alimony pendente lite from Wife to meet his reasonable needs.
By virtue of the above, Wife is entitled to the termination of the order for alimony pendente lite or, in the
alternative, to a significant reduction in such order considering Defendant's actual financial need for
support.
5. The continued payment of the alimony pendente lite by Plaintiff, under the circumstances as
they now exist, creates an unreasonable and unnecessary hardship for Plaintiff.
WHEREFORE, Plaintiff prays this Court to terminate the alimony pendente lite immediately or,
in the alternative, to significantly reduce the alimony pendente lite as appropriate.
el L. Andes
Attorney for Valerie S. Stacknick
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 18 Pa. C.S. 4904 (unsworn falsification to
authorities).
DATE:_ ????.?t (A v /V- "J?11
VALERIE S. STACKNICK
CERTIFICATE OF SERVICE
I hereby certify that on 2008, I served a copy of the foregoing document
upon counsel for Defendant by U.S. Mail, postage prepaid, addressed as follows:
Barbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070
4ue4N.Atn?tdjees,
Attorney for Plaintiff
Supreme Court ID 17225
P.O. Box 168
Lemoyne, PA 17043
(717) 761-5361
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VALERIE S. STACKNICK, THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - DIVORCE
NO. 08-265 CIVIL TERM
MATTHEW R. STACKNICK, IN DIVORCE
Defendant/Respondent :
PACSES CASE NO: 359109838
ORDER OF COURT
AND NOW, this 18th day of August, 2008, a petition has been filed against you, Matthew R. Stacknick, to
modify an existing Alimony Pendente Lite Order. You are ordered to appear in person at the Domestic Relations
Section, 13 North Hanover Street, Carlisle, Pennsylvania, on September 15, 2008 at 1:30 P.M. for a conference
and to remain until dismissed by the Court. If you fail to appear as provided in this Order, an Order of Court may be
entered against you.
You are further ordered to bring to the conference:
(1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed
(2) your pay stubs for the preceding six (6) months
(3) the Income and Expense Statement attached to this order, completed as required by the Rule
1910.11.
(4) verification of child care expenses
(5) proof of medical coverage which you may have, or may have available to you
IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for
your arrest.
BY THE COURT,
Edgar B. Bayley, President Judge
Copies mailed to: Petitioner
Respondent
Barbara Sumple-Sullivan, Esq.
Samuel L. Andes, Esq.
P
Date of Order: August 18, 2008 At
R. J. had y, Co erence Officer /
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRES T
YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVE.
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
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VALERIE S. STACKNICK,
Plaintiff/Respondent
VS.
MATTHEW R. STACKNICK,
Defendant/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 08-265 CIVIL TERM
IN DIVORCE
PACSES CASE: 359109838
ORDER OF COURT
AND NOW to wit, this 15th day of September 2008, it is hereby Ordered that the
Respondent's petition to terminate or modify the Order for Alimony Pendente Lite is dismissed,
without prejudice, pursuant to no material or substantial change in circumstance.
This Order shall become final twenty (20) 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 Domestic
Relations Section for a hearing de novo before the Court.
BY THE COURT:
DRO: R.J. Shadday
xc: Petitioner
Respondent
Samuel L. Andes, Esq.
Barbara Sumple-Sullivan, Esq.
Form OE-001
Service Type: M Worker: 21005
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VALERIE S. STACKNICK,
Plaintiff
vs.
MATTHEW R. STACKNICK,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 08-265 CIVIL TERM
}
PACSES CASE # 359109838
NOTICE OF APPEAL AND REQUEST FOR HEARING DE NOVO
The Plaintiff/Respondent Valerie S. Stacknick hereby appeals from this Court's order of
15 September 2008 and requests a hearing de novo before the Support Master.
amuel L. Andes
Attorney for Plaintiff
Supreme Court ID # 17225
525 N. 12th Street
Lemoyne, PA 17043
(717) 761-5361
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
MATTHEW R. STACKNICK ) Docket Number 08-265 CIVIL
Plaintiff )
vs. ) PACKS Case Number 359109838
VALERIE S. STACKNICK )
Defendant ) Other State ID Number
ORDER OF COURT
You, MATTHEW R. STACKNICK
646 OLD GROVE RD, MECHANICSBURG, PA. 17055-4088-46
are ordered to appear at DOMESTIC RELATIONS HEARING RM
plaintiff/defendant of
DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13
before a hearing officer of the Domestic Relations Section, on the
NOVEMBER 4, 2008
at 8. 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 21302
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
MATTHEW R. STACKNICK ) Docket Number 08-265 CIVIL
Plaintiff )
vs. ) PACSES Case Number 359109838
VALERIE S. STACKNICK )
Defendant ) Other State ID Number
ORDER OF COURT
You, VALERIE S. STACKNICK
624 HERITAGE CT, MECHANICSBURG, PA. 17050-1856-24
are ordered to appear at DOMESTIC RELATIONS HEARING RM
plaintiff/defendant of
DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13
before a hearing officer of the Domestic Relations Section, on the
NOVEMBER 4, 2008
at 8: 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. I
Worker ID 21302
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VALERIE S. STACKNICK, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : DOMESTIC RELATIONS SECTION
MATTHEW R. STACKNICK, PACSES NO. 359109838
Defendant DOCKET NO. 08-265 CIVIL
INTERIM ORDER OF COURT
AND NOW, this 1!-day of November, 2008, upon consideration of the Support
Master's Report and Recommendation, a copy of which is attached hereto as Exhibit
"A", it is ordered and decreed as follows:
A. The Wife shall pay to the Pennsylvania State Collection and Disbursement Unit as
alimony pendente lite the sum of $344.00 per month.
B. The Wife shall pay to the Pennsylvania State Collection and Disbursement Unit
the additional sum of $46.00 per month on arrears.
C. The effective date of this order is August 12, 2008.
IMPORTANT LEGAL NOTICE
PARTIES MUST WITHIN SEVEN DAYS INFORM THE DOMESTIC
RELATIONS SECTION AND THE OTHER PARTIES, IN WRITING, OF ANY
MATERIAL CHANGE IN CIRCUMSTANCES RELEVANT TO THE LEVEL OF
SUPPORT OR THE ADMINISTRATION OF THE SUPPORT ORDER,
INCLUDING, BUT NOT LIMITED TO, LOSS OR CHANGE OF INCOME OR
EMPLOYMENT AND CHANGE OF PERSONAL ADDRESS OR CHANGE OF
ADDRESS OF ANY CHILD RECEIVING SUPPORT. A PARTY WHO
WILLFULLY FAILS TO REPORT A MATERIAL CHANGE IN CIRCUMSTANCES
MAY BE ADJUDGED IN CONTEMPT OF COURT, AND MAY BE FINED OR
IMPRISONED.
PENNSYLVANIA LAW PROVIDES THAT ALL SUPPORT ORDERS
SHALL BE REVIEWED AT LEAST ONCE EVERY THREE (3) YEARS IF SUCH
REVIEW IS REQUESTED BY ONE OF THE PARTIES. IF YOU WISH TO
REQUEST A REVIEW AND ADJUSTMENT OF YOUR ORDER, YOU MUST DO
THE FOLLOWING: CALL YOUR ATTORNEY. AN UNREPRESENTED
PERSON WHO WANTS TO MODIFY (ADJUST) A SUPPORT ORDER SHOULD
CONTACT THE DOMESTIC RELATIONS SECTION. ALL CHARGING
ORDERS FOR SPOUSAL SUPPORT AND ALIMONY PENDENTE LITE,
INCLUDING UNALLOCATED ORDERS FOR CHILD AND SPOUSAL SUPPORT
OR CHILD SUPPORT AND ALIMONY PENDENTE LITE, SHALL TERMINATE
UPON DEATH OF THE PAYEE.
A MANDATORY INCOME ATTACHMENT WILL ISSUE UNLESS THE
DEFENDANT IS NOT IN ARREARS IN PAYMENT IN AN AMOUNT EQUAL TO
OR GREATER THAN ONE MONTH'S SUPPORT OBLIGATION AND (1) THE
COURT FINDS THAT THERE IS GOOD CAUSE NOT TO REQUIRE
IMMEDIATE INCOME WITHHOLDING; OR (2) A WRITTEN AGREEMENT IS
REACHED BETWEEN THE PARTIES WHICH PROVIDES FOR AN
ALTERNATE ARRANGEMENT.
UNPAID ARREARAGE BALANCES MAY BE REPORTED TO CREDIT
AGENCIES. ON AND AFTER THE DATE IT IS DUE, EACH UNPAID SUPPORT
PAYMENT SHALL CONSTITUTE, BY OPERATION OF LAW, A JUDGMENT
AGAINST YOU, AS WELL AS A LIEN AGAINST REAL PROPERTY. IT IS
FURTHER ORDERED THAT, UPON PAYOR'S FAILURE TO COMPLY WITH
THIS ORDER, PAYOR MAY BE ARRESTED AND BROUGHT BEFORE THE
COURT FOR A CONTEMPT HEARING; PAYOR'S WAGES, SALARY,
COMMISSIONS, AND/OR INCOME MAY BE ATTACHED IN ACCORDANCE
WITH LAW. PAYOR IS RESPONSIBLE FOR COURT COSTS AND FEES.
The parties are hereby advised that they may file written exceptions to the
Support Master's Report and Recommendation within twenty (20) days of this order.
Exceptions shall conform with the requirements of Rule 1910.12(f), Pa. R.C.P. If written
exceptions are filed by any party, the other party may file exceptions within twenty (20)
days of the date of service of the original exceptions. If no exceptions are filed within
twenty (20) days of this interim order, this order shall then constitute a final order.
By the Court,
J. Wesley Ole vi., J.
Cc: Valerie S. Stacknick
Matthew R. Stacknick
Samuel L. Andes, Esquire
For the Plaintiff
Barbara Sumple-Sullivan, Esquire
For the Defendant
DRO
VALERIE S. STACKNICK,
Plaintiff
V.
MATTHEW R. STACKNICK,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: DOMESTIC RELATIONS SECTION
PACSES NO. 359109838
DOCKET NO. 08-265 CIVIL
SUPPORT MASTER'S REPORT AND RECOMMENDATION
Following a hearing held before the undersigned Support Master on
November 4, 2008, the following report and recommendation are made:
FINDINGS OF FACT
1. The Plaintiff is Valerie S. Stacknick, whose address is 624 Heritage Court,
Mechanicsburg, Pennsylvania, but who is currently residing in Charlotte,
North Carolina; she will hereafter be referred to as "the Wife."
2. The Defendant is Matthew R. Stacknick, who resides at 646 Old Grove Road,
Mechanicsburg, Pennsylvania; he will hereafter be referred to as "the Husband."
3. On January 15, 2008 the Wife filed a Complaint for divorce.
4. By order dated May 22, 2008 the husband was awarded alimony pendente lite in the
amount of $754.00 per month effective March 15, 2008.
5. On August 12, 2008 the Wife filed a petition to modify said order of alimony
pendente lite.
6. In May, 2008 the Wife was found to have had net monthly income for support
purposes based upon her 2007 tax return of $4,905.00.1
7. The Wife's income consisted of wages from Cornerstone Land Transfer, Inc. and
Select Land Transfer LLC, perquisites from the use of an automobile, and investment
income.
8. The Wife runs a company engaged in abstract services and title insurance whose
revenue is dependent upon sales of real estate.
9. In 2008 the gross revenues of the Wife's company are significantly lower than the
2007 revenues because of the downturn in real estate sales.
1 See Support Master's Report and Recommendation dated May 19, 2008.
EXHIBIT "A"
10. The Wife reduced her salary in mid-September from $1,000.00 per week to $900.00
per week as part of an overall company cost reduction plan.
11. The Wife's salary from her company in 2008 is anticipated to be approximately
$50,100.00.
12. The Wife does not anticipate receipt of any wages from Select Land Transfer, LLC in
2008.
13. The Wife anticipates significantly lower income from her investments with Solomon
Smith Barney in 2008 because of the downturn in the stock market which began
during the third quarter.
14. The Wife continues to have the use of a company car, but the value of the use is
reduced because of the lease of a less expensive vehicle.
15. The Wife now receives $350.00 per month in rent from her son who occupies the
jointly-owned residence at 938 Allenview Drive, Mechanicsburg, but pays a
mortgage and taxes in an amount exceeding the rental income.
16. In May, 2008 the Husband was found to have had net monthly income of $3,019.00.2
17. The Husband has had no material or substantial change in his income since May,
2008.
18. Since June, 2008 another woman and her daughter have resided with the Husband in
the marital residence.
19. That woman is now the husband's fiancee.
20. That woman contributes to grocery expenses but pays no other household expenses.
DISCUSSION
A party seeking to modify a support order has the burden of demonstrating that a
material and substantial change of circumstances has occurred since the entry of the order to
justify a modification. Samii v. Samii, 847 A.2d 691 (Pa. Super. 2004). The Wife has
demonstrated that she has had a material and substantial reduction in her income in 2008. A
recalculation of her obligation to pay alimony pendente lite is warranted.
The Wife's anticipated earnings in 2008 are estimated to be $50,100.00 from
Cornerstone Land Transfer.3 No wages from Select Land Transfer are anticipated. The
Wife's investment income decreased in the third quarter of 2008 because of the downturn in
z See Support Master's Report and Recommendation dated May 19, 2008.
s This is based upon a salary of $1,000.00 per week for mid-September and $900.00 per week thereafter.
2
the stock market. It is anticipated that her annual investment income will be $9,366.00.4 The
Wife's automobile perquisite is reduced to $300.00 per month for 2008. The gross monthly
income for support purposes is $5,255.50. Filing her federal income tax return as
married/separate will result in net monthly income for support purposes of $3,880.00.5 This
is significantly less than the $4,905.00 attributed to her in May based upon the 2007 tax
return.
The Husband has had no material and substantial change of income since the entry of
the prior order. His net monthly income of $3,019.00 will continue to be utilized for
calculation of the APL obligation.
With net incomes as set forth above the Wife has an APL obligation of $344.00 per
month.b
RECOMMENDATION
A. The Wife shall pay to the Pennsylvania State Collection and Disbursement Unit as
alimony pendente lite the sum of $344.00 per month.
B. The Wife shall pay to the Pennsylvania State Collection and Disbursement Unit the
additional sum of $46.00 per month on arrears.
C. The effective date of this order is August 12, 2008.
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Date
Michael R. Rundle
Support Master
4 The Wife failed to submit documentation of her investment income for the first two quarters of 2008. She will
be imputed with one-half of the 2007 investment income for that period of time. Added to this will be $433.00
per quarter for the third and fourth quarters.
5 See Exhibit "A" for the tax deductions from gross income. The Wife is listed as the "Defendant" on the
exhibit because she is the obligor.
6 See Exhibit "B" for the calculation.
In the Court of Common Pleas of Cumberland County, Pennsylvania
Tax Detail Report
Plaintiff Name: Matthew R. Stacknick
Defendant Name: Valerie S. Stacknick
Docket Number: 08-265 Civil
PACSES Case Number: 359109838
Other State ID Number:
Tax Year: Current: 2008
Defendant Plaintiff
1. Tax Method 1040 ES Manual
2. Fling Status Married Filing
Separately Married Filing
Separately
3. Who Claims the Exemptions Obligee
4. Number of Exemptions 1 1
5. Monthly Taxable Income $5,255.50 $3,019.00
6. Deductions Method
7. Deduction Amount $454.17 $454.17
8. Exemption Amount $291.67 $291.67
9. Income MINUS Deductions and Exemptions $4,509.66 $2,273.16
10. Tax on Income $822.73 $307.54
11. Child Tax Credit - -
12. Manual Adjustments to Taxes - -
13. Federal Income Taxes $822.73 -
13 a. Earned Income Credit - -
14. State Income Taxes $166.07 -
15. FICA Payments $342.34 -
16. City Where Taxes Apply
17. Local Income Taxes $44.75 -
TOTAL Taxes $1,3 5.89
-
SupportCak 2007
EXHIBIT "A"
In the Court of Common Pleas of Cumberland County, Pennsylvania
Spousal Support Calculation
Rule 1910.16
(PACSES FORMAT)
Plaintiff Name: Matthew R. Stacknick
Defendant Name: Valerie S. Stacknick
Docket Number: 08-265 Civil
PACSES Case Number: 359109838
Other State ID Number:
1. Obligor's Monthly Net Income $3,879.61
2. Less All Other Support
-
3. Less Obligee's Monthly Net Income $3,019.00
4. Difference $860.61
5. Less Child Support Obligation for Current Case -
6. Difference $860.61
7. Multiply b 30% or 40% 40.00%
8. Income Available for Spousal Support $344.24
9. Adjustment for Other Expenses -
10. AMOUNT OF MONTHLY SPOUSAL SUPPORT OR APL $344.24
Prepared b : mrr Date: 11/ 4/2008
SupportCalc 2008
EXHIBIT "B"
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VALERIE S. STACKNICK, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : DOMESTIC RELATIONS SECTION
MATTHEW R. STACKNICK, PACSES NO. 359109838
Defendant DOCKET NO. 08-265 CIVIL
INDEX OF EXHIBITS
Plaintiff's Exhibit No. 1 - Earnings statement
Plaintiff's Exhibit No. 2 - 2008 deposits into Cornerstone Land Transfer operating
account
Plaintiff's Exhibit No. 3 - 2007 tax return for Cornerstone Land Transfer
Plaintiff's Exhibit No. 4 - 2008 deposits into other operating accounts
Plaintiff's Exhibit No. 5 - Interest income from Smith Barney third quarter 2008
Plaintiff's Exhibit No. 6 - Income and expense statement
Defendant's Exhibit No. I - Income and expense statement
Defendant's Exhibit No. 2 - Counsel fees
THEFACE OF THIS DOCUMENT CONTAUVS MICROPRINTMG THE.BACKGHOVND COLOR GRANGES GRADUALLY AND EVENLY FROM DARKEN TO LIGHTER WITH THE DARKEN AHtA AI 1 HE I LW
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CdRNEf ? l Np T tAN FE i, ; NC622 L 1Q8/
GENERAL AG4? T
10/24/2008F3985500658(
60 -,
4705, BEAST. INDLf 'Rd 433
MECHGSBURC PA, 155' DATE. -- _ cKNO
70
PAY TO THE VALERIE STACKNICK VOID AFTER 180 days
ORDER OF 624 HERITAGE COURT **V01 D** 7
MECHANICSBURG PA 17050
AMOUNT k t
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i
**VOID****THIS IS NOT A CHECK****VOID****THIS IS NOT A CHECK** `
PNC-$ANK DEPOSIT;A000UNT_ DEPOSIT AMOUNT * Non Negotiable
1010181011994 ******493,23
JEANNETTE,RA
AUTHORIZED SIGNATURE(S)
TO VERIFY AUTHENTICITY OF THIS .DOCUMENT _THE BACK CONTAINS HEAT MNSMVEINK71-AT CHANGES EHOMBLUE TO CLEAR AND ALSO CONTAINS AN ARTIFlCIAL WATERMASK WHICH CAN BE VIEWED WHEN HELDAT AN-ANGLE
FOLD AND REMOVE FOLD AND REMOVE
YOUR BANKING HOURS RATE
EA?f#I?
YTE3 AM0 Q?T
AMO0NT
- - -
-
ITEM AMOUNT DEPOSIT TO ACCT
- -- -
REGUQ4L-
-
-
906.OD
_
NET 493.23 1010181011994 -
TOTAL EARNINGS -
900.00 42812.50
-
I=iLING' STA7U5_
-
TAX, r
A 8CY'T _. YTD
STOIfE SFER, INC
GENERAL COUNT MEDICARE
620.79
-
4705 EAST TRINDLE RD M 01 FEDERAL 4
82.83 160.05
MECHANICSBURG,PA 17055 M 00
PA.
1314.34
27.5
4
-
1.7% MECHA 15.30 727,81 _
PAY PERIOD 10/18/08 TO 10/24/08 M 00 LST10 0.00 10.00
CHECK DATE 10/24108 CHECK f 3985500658
- - TOTAL WITHHOLDINGS - 195.15 9513.05
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VALERIE STACKNICK EE S IRA 7
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HERITAGE" COURT
624 GARNISHMNT 184.62 - 3877 02
MECHANIC59URG PA 17050 OTHERCOMP _ ER, S IRA _ 27.00_ 1294.38 .
SSf XXX-XX-8357 EMPL# 000001 DEPT# 000100 -
TOTAL ADJUSTMENTS- 211.62- -
PLAINTIFF'S
- EXHIBIT
Payrolls by Paychex Inc.
0028 61223 0004 000100
NET PAY
493.23 28138.05
2008 Deposits into the Cornerstone Land Transfer, Inc. Operating Account
January 8,262.39
February 2,803.98
March 8,098.55
April 5,425.80
May 8,571.73
June 10,734.50
July 5,018.00
August 8,157.15
September 8,623.59
October 6,778.67
72,474.36 Gross deposits
Less 15% paid to underwriters 10,871.15
Less salaries,aentt_l.supplies and general operating expenses
I am currently operating in the negative
PLAINflFF'S
FJ(HIBR
Form1 "12 a S U.S. Income Tax Return for an S Corporation OMB No. 1545-0130
? Do not file this form unless the corporation has filed or Is
Department or the Treasury attaching Form 2553 to elect to be an S corporation. ?00
Internal Revenue Service (rr) ? See separate Instructions.
For calendar vear 2007 or tax vear beginnina anri onriinn
A S election effective date Use Name
D Employer Identification number
11/14/1994 IRS
l.bel CORNERSTONE LAND TRANSFER, INC. 25-1751821
B nBusiness umber (see i Instructions) moons) .
Omer-
Number, street, and room or suite no. If a P.O. box, see instructions. =
E Date incorporated
524210 4705 EAST TRINDLE ROAD 11/14/1994
?
C Check if Sch. M-3
attached
?'p'• City or town, state, and ZIP code J
•.
?,
,
V Total assets (see instructions)
'
MECHANICSBURG, PA 17050-3616 111,790
u is the corporation electing to De an 5 corporation beginning with this tax ear? L_j Yes U No If "Yes," attacTi Form 2553 if not already filed
H Check if: (1) Final return (2) El Name change (3) Address change
(4) 8 Amended return (5) 1:1 S election termination or revocation
I Enter the number of shareholders in the corporation at the end of the tax year ? 1
Caution. Include 0* trade or business income and expenses on lines fa through 29. See the instructions for more infomatinn
ross receipts 10 5, 4 3 3 I b Less returns and allowances) 0 e Bal ?
1 a G
or sales
1 c
105,433
2 Cost of goods sold (Schedule A
line 8) 2
,
, , , , , , , , , , , , , , , , , , , , , , , , , , , ,
E i 3 Gross profit. Subtract line 2 from line 1c 3 105, 4 33
L) 4 Net gain (loss) from Form 4797, Part Il, line 17 (attach Form 4797) q
5 Other income (loss) (see instructions - attach statement) , SCHEDULE. ATTACHED . . . . 5 116, 38 4
6 Total income (loss). Add lines 3 through 5 ? 6 221,817
7 Compensation of officers , , , , , , , , , , , , , , , , , , , , , , , , , , , , , 7 52,437
8 Salaries and wages (less employment credits) 8 74,743
9 Repairs and maintenance PROPERTY AND EQUIPMENT
.................... .................. 9 1, 817
10 Bad debts 10
_ ........................................
0 11 Rents
.............................................. 11 30,000
r-
o 12 Taxes and licenses SCHEDULE ATTACHED
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 16,026
2 13 Interest .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 2,958
14 Depreciation not claimed on Schedule A or elsewhere on return (attach Form 4562) 14 12,438
d 15 Depletion (Do not deduct oil and gas depletion.) 15
, , , , , , , , , , , ,
16 Advertising . . 16 20,052
p 17 Pension, profit-sharing, etc., plans . , . 17 3,243
U 18 Employee benefit programs HEALTH/HOSPITALIZATION INSURANCE 18 4
166
...................................... ,
19 Other deductions (attach statement) , , , , , , , , , , , , , , , , , , , , , , , , , , 19 _ 82, 80 6
20 Total deductions. Add lines 7 through 19 , , , _ . , , . . ? 20 300, 68 6
21 Ordinary business Income (loss). Subtract line 20 from line 6 . 21 (78,869)
22a Excess net passive income or LIFO recapture tax (see instructions) . . , 22a
b Tax from Schedule D (Form 1120S) 226
y c Add lines 22a and 22b (see instructions for additional taxes) . , , , , , , , , , , , 2c 0
E? , .
23a 2007 estimated tax payments and 2006 overpayment credited to 2007 23a
a _
b Tax deposited with Form 7004 , , . . . . . . , , 23b
_
c Credit for federal tax paid on fuels (attach Form 4136) , , , , , , , , , 23c
x d Add lines 23a through 23c • • • • • • • . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 0
t? 24 Estimated tax penalty (see instructions). Check if Form 2220 is attached ?El 0
25 Amount owed. If line 23d is smaller than the total of lines 22c and 24, enter amount owed . , . , , , 25 0
26 Overpayment If line 23d is larger than the total of lines 22c and 24, enter amount overpaid , , , , , _ . . 2g 0
, 27 Enter amount from line 26 Credited to 2008 estimated tax ? Refunded ? 27 0
Under penalties of perjury, I declare that I have examined this return, including accompanying schedules and statements, and to the best of my knowledge and belief, It Is true
correct
and
complete. Declaration of preparer (other than taxpayer) is based on all information of which preparer has any knowledge. ,
,
Sign his return with
Here
PRESIDENT n below (see
=insVucUons)?
? N
'
Signature of officer es
.
Date Titl e
Preparers
i
, ^
C, a J
??Q k 0AW Date
em
Preparers SSN or PTIN
nature
W CPA
Paid S
r
-
o_
I V#, ".. -I--- -
2/18/08
ployed
-
P00642780
-' -"' Firm's name (oryours - 11- 1 1- ra.? w? inl?o, r. t,.
Use only if self-employed), ' 19 SOUTH 19TH STREET
address, and ZIP code CAMP HILL, PA 17011-5402
For Privacy Act and Paperwork Reduction Act Notice, see separate instructions.
4
1410 3.000
23-2031522
717)761-8072
Form 1120S (2007)
Form 1120S
2
1 Inventory at beginning of year, • • • • • • • , • • • , , , , , , , , , , , , , , , , , , , , , , , , , , 1
2 Purchases 2
3 Cost of labor . . . . . . . ... . . . . .. . . . . . . . .... . .. . . .... .. . . . . . . . 3
4 Additional section 263A costs (attach statement) , , , , , , , , , , , , , , , , , , , , , 4
5 Other costs (attach statement)
6 Total. Add lines 1 through 5 , , , g `
?•
7 Inventory at end of year , , , , , , , , , , , , , , , , , , , , , , , • . • .. .. . . . . . .... ; F
8 Cost of goods sold. Subtract line 7 from line 6. Enter here and on page 1, line 2 • , , , , , , , , 8 N/A
9a Check all methods used for valuing closing inventory: OF Cost as described in Regulations section 1.471-3
(ii) 11 Lower of cost or market as described in Regulations section 1.471-4
(iii) Other (Specify method used and attach explanation.) ? ---------------------------------------- ---
b Check if there was a writedown of subnormal goods as described in Regulations section 1.471-2(c), , , , , , , , , , , , ??
c Check if the LIFO inventory method was adopted this tax year for any goods (if checked, attach Form 970) , • , .. , , , ?
d If the LIFO inventory method was used for this tax year, enter percentage (or amounts) of closing
inventory computed under LIFO , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , 9d
e If property is produced or acquired for resale, do the rules of section 263A apply to the corporation? • . • . ... Yes No
f Was there any change in determining quantities, cost, or valuations between opening and closing inventory?. . . Yes No
If "Yes," attach explanation.
- . - - Other Information see instructions
1 Check accounting method: a ? Cash b Yes No
g 0 Accrual c `
El Other (specify) ?--------------------
2 See the instructions and enter the:
a Business activity ?_ _ TITLE _ INSURANCE _ AGENCY____ b Product or service ? TITLE INS./SETTLEMENT SVC - #.0
3 At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a domestic
corporation? (For rules of attribution, see section 267(c).) If "Yes," attach a statement showing: (a) name and employer
identification number (EIN), (b) percentage owned, and (c) if 100% owned, was a QSub election made? X
4 Has this corporation filed, or is it required to file, a return under section 6111 to provide information on any reportable
transaction'L ....................................................... X
5 Check this box if the corporation issued publicly offered debt instruments with original issue discount . . ... ? ?
If checked, the corporation may have to file Form 8281 , Information Return for Publicly Offered Original Issue Discount
Instruments.
6 If the corporation: (a) was a C corporation before it elected to be an S corporation or the corporation acquired an
asset with a basis determined by reference to its basis (or the basis of any other property) in the hands of a <4
C corporation and (b) has net unrealized built-in gain (defined in section 1374(d)(1)) in excess of the net recognized
built-in gain from prior years, enter the net unrealized built-in gain reduced by net recognized built-in g?ain from prior:
years . . . . . . . .. . .. ... N/A
7 Enter the accumulated earnings and profits of the corporation at the end of the tax year. $ N/A
8 Are the corporation's total receipts (see instructions) for the tax year and its total assets at the end of the tax year
less than $250,000? If "Yes," the corporation is not required to complete Schedules L and M-1 X
-. - Shareholders' Pro Rata Share Items Total amount
1 Ordinary business income (loss) (page 1, line 21 (78, 869)
2 Net rental real estate income (loss) (attach Form 8825) . , • • . , • • • , , , , , , , , , , , , 2
3 a Other gross rental income (loss), , • , , , , , , , , , .. 3a
b Expenses from other rental activities (attach statement) 3b
to c Other net rental income (loss). Subtract line 3b from line 3a. ... . . , • , , , , , , , , , , , 3c
4 Interest income 4 1,979
E 5 Dividends: a Ordinary dividends • • • . . „ 5a
o b Qualified dividends 5b
............
6 Royalties , , , , , , , , , , , , , , , ,
7 Net short-term capital gain (loss) (attach Schedule D (Form 1120S)). , , , , , . , , . . 7
8 a Net long-term capital gain (loss) (attach Schedule D (Form 1120S)) . . , , , • , , , , , , , , , , • 8a
b Collectibles (28%) gain (loss) • • , , , , , , , , , , , , 8b
c Unrecaptured section 1250 gain (attach statement) 8c
9 Net section 1231 gain (loss) (attach Form 4797), , , , , , , , , 9
10 Other income (loss) (see instructions) , . Type ? 10
Form 1120S (2007)
4
14202.000
Form 1120S (2007)
Paae 3
Shareholders' Pro Rata Share Items (continued) Total amount
y
c 11 Section 179 deduction (attach Form 4562) 17
12a Contributions , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , 12a
s b Investment interest expense 12b
o
c Section 59(e)(2) expenditures (1) Type ?_______________________ (2) Amount ?
12c(2)
d Other deductions (see instructions) . ,Type ? 12d
13a Low-income housing credit (section 420)(5)) . . . . . . . . . . . . . . . . . . . 7',: F
q
b Low-income housing credit (other) . . . . . . . . . . . . . . . . . . . . . . . I ?
1 '77
- g
c Qualified rehabilitation expenditures (rental real estate) (attach Form 3468) . . . . . ' . 0,! 1 3c
2 d Other rental real estate credits (see instructions) Type ? _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 13d _
L) e Other rental credits (see instructions) . . . . . . . Type ? ______________________ 139
f Credit for alcohol used as fuel (attach Form 6478) . . . . . . . . . . . . . . . . . . . . . 13f
g Other credits see instructions . Type li? 13
14a Name of country or U.S. possession ?_____________________________
b Gross income from all sources
.................................. 14b
c Gross income sourced at shareholder level 14c
Foreign gross income sourced at corporate level
d Passive category
......................... 14d
c
o e General category 14e
;; If Other (attach statement) , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , 14f
A
Deductions allocated and apportioned at shareholder level
r 9 Interest expense 14
h Other. 14h
`
0
Deductions allocated and apportioned at corporate level to foreign source income
i Passive category . . . . . . . . .. . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . 141
j General category . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
k Other (attach statement) , , , , , , , , , , , , , , , , , , , , , , , , , , , , 14k
Other information
I Total foreign taxes (check one): ? ? Paid FlAccrued . . . . . . . . . . . . . . . . . . 141
m Reduction in taxes available for credit (attach statement) _ . . . . . . , , . , , , 14m
n Other foreign tax information (attach statement)
15a Post-1986 depreciation adjustment , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , 15a 4,701.
F E b Adjusted gain or loss , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , 15b
E E ^ c Depletion (other than oil and gas) , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , 16c
:t d Oil, gas, and geothermal properties - gross income , 15d
a M g e Oil, gas, and geothermal properties - deductions , , , , , , , , , , , , , , , , , , , , , , , , , 150
f Other AMT items (attach statement) ,
.............................. 15f
o?
c 16a Tax-exempt interest income . . . . . . . . . . . . . . . . . . . 16a
v b Other tax-exempt income . 16b
a 212 c Nondeductible expenses , , I . . SECTION. 274 .(.. ,EXCLUSION, .. . .. . , . . 16c 2,474
E2 d Property distributions,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, 16d
- e Repayment of loans from shareholders . 16e
17a Investment income . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17a 1, 97 9
r € b Investment expenses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17b
0,2 c Dividend distributions paid from accumulated earnings and profits . . . . . .. . . . . . . . . . 17c
d Other items and amounts attach statement
c
60
'51 0 18 Income/loss reconciliation. Combine the amounts on lines 1 through 10 in the far right
z column. From the result, subtract the sum of the amounts on lines 11 through 12d and 141 18 (76,890)
Form 1120S (2007)
,1430 2.000
Pane 4
• e a ce ee Beginning of tax year End of tax year
Assets (a) (b) (c) (d)
I Cash 23,320 21,593
2a Trade notes and accounts receivable -
,
b Less allowance for bad debts ( )
, • •
3 Inventories "
, , , , ,
government obligations
S
4 U ! " Y
.
.
5 Tax-exempt securities (see instructions)
,
6 Other current assets (attach statement)
21,033
{
( _ 11, 076
,
7 Loans to shareholders . . . . . .
8 Mortgage and real estate loans . .
9 Other investments (attach statement) 7 4, 0 4 4 56, 455
10a Buildings and other depreciable assets , 179,785 179,785
b Less accumulated depreciation ( 144, 681) 35, 104 ( 157,119)
2 , 6 b 6
1 1 a Depletable assets
, , , , , , , ,
b Less accumulated depletion
( )
, , ,
12 Land (net of any amortization)
13a Intangible assets (amortizable only) 192
b Less accumulated amortization ( 192) 0 1'±2 0
,
14 Other assets (attach statement)
.
15 Total assets
...
153,501
111,790
. .. ....
Liabilities and Shareholders' Equity
16 Accounts payable , _ , , , , ,
17 Mortgages, notes, bonds payable in
less than 1
ear 19,168
51, 875
y
,
18 Other current liabilities (attach
3, 715
3, 705
statement)
19 Loans from shareholders .
25,471
30,647
20 Mortgages, notes, bonds payable in
. . . . .
1 year or more
. . . .
? 1 Other liabilities (attach statement)
,
22 Capital stock
47,000
47,000
. .. _ .. , ,
?3 Additional paid-in capital , , , ,
)-4 Retained earnings 58,147 (21, 437)
• •
,5 Adjustments to shareholders'
(attach statement)
e
uit
. . . .
q
y
!6 Less cost of treasury stock . , , ,
!7 Total liabilities and shareholders' equity. 153,501 ill, 7 90
RMIT.-TIMMIN3111111 Reconcilia tion of Income (Loss) Der Books With Incom e (Loss) Der Return
Note: Schedule M-3 required instead of Schedule M-1 if total assets are $10 million or more - see instructions
1 Net income (loss) per books (79,584) t, income recorded on books this year not included
2 income included on Schedule K lines 1, 2, 3c, 4, on Schedule K lines 1 through 10 (itemize):
5a, 6, 7, 8a, 9, and 10, not recorded on books this
year (itemize): a Tax-exempt interest $
----------------
AUTO LEASE INCLUSION 220
---------------------- ----------------------------
3 Expenses recorded on books this year not 6 Deductions included on Schedule K, lines
included on Schedule K, lines 1 through 12 1 through 12 and 141, not charged against
and 141 (itemize): book income this year (itemize):
a Depreciation $ _ _ _ _ _ _ _ _ _ _ _ _ _ _ a Depreciation $
--------------------
b Travel and entertainment $_ 2,474
----------------------------
_2,474 7 Add lines 5and6. , , • • , , , , _ . . . . 0
4 Add lines 1 through 3 (76, 890) 8 Income (loss) (Schedule K, line 18). Line 4 less line 7 (76,890)
_ Analysis of Accumulated Adjustments Account, Other Adjustments Account, and Shareholders'
Undistributed Taxable Income Previous) Taxed see instructions
(a) Accumulated (b) Other adjustments (c) Shareholders' undistributed
adjustments account account taxable income previously tweed
I Balance at beginning of tax year 58,147
t Ordinary income from page 1, line 21
I Other additions . . . . . . . . . . . . . . . . .... 1, 97 9
1 Loss from page 1, line 21 , • , • , . . . . . . • . . , , 78,869
Other reductions . . . . . . . . . . . . . . . . . . 2,694
Combine lines 1 through 5 , , , , , , , , , , , , , , , , (21,437)
Distributions other than dividend distributions , , , , , ,
Balance at end of tax year. Subtract line 7 from line 6 . . . . (21,437) N/A
A
1440 2.000
N/A
Form 1120S (2007)
Cornerstone Land Transfer, Inc.
4705 East Trindle Road
Mechanicsburg, PA 17050-3616
EIN 25-1751821
Form 1120S °
Year End 12131/2007 ED ;
Form 1120S, Page 1. Line 5 - Other Income
Ordinary trade/busn=iness income derived from limited liability companies
(See schedules K-1, attached) -
Charter Settlement Services, LLC $40,703
EIN 25-1848631
Heritage Settlement Services, LLC (577)
EIN 25-1844857
Management services 51,928
Rents 5,400
Title search fees 18,710
Auto lease inclusion ?2Q
TOTAL 116:384
Form 1120S, Page 1, Line 12 - Taxes & Licenses
Miscellaneous business priviledge taxes $112
Payroll taxes 11,316
Real estate taxes 3,574
State capital stock tax 1.024
TOTAL
Form 11208, Page 1, Line 19 - Other Deductions
Automobile and travel expenses $36
Automobile lease 6,027
Computer services and support 1,323
Copying services 1,679
Dues, subscriptions and publications 125
Entertainment and promotion 2,474
[net of $2,474 IRC section 274(n) exclusion]
Insurance 8,342
Janitorial services and supplies 1,283
Office supplies and expenses 15,012
Payroll preparation services 2,745
Postage, courier and express 3,781
Professional development and education 140
Professional servies, legal/accounting 10,445
Professional servies, title search costs 16,356
Service contracts, office equip[ment 1,033
Telephone and communications 7,121
Utilities 4,884
TOTAL MAW
1120.WK4
Cornerstone Land Transfer, Inc.
4705 East Trindle Road
Mechanicsburg, PA 17050-3616
EIN 25-1751821
Form 11203 ?.
Year End 12131/2007`
Form 11203. Page 4, Schedule L, Line 6 - Other Current Assets
Beginning Ending
Prepaid state capital stock tax $6,500 $2,850
Management fees receivable 14,533 8.226
TOTAL 21
Form 1120S. Page 4, Schedule L, Line 9 - Other Investments
Investment in Heritage Settlement Services, LLC $66,718 $50,018
Investment in Charter Settlement Services, LLC 7.326 6.437
TOTALS
Form 1120S, Page 4, Schedule L, Line 18 - Other Current Liabilities
State capital stock tax payable $3,715
Retirement withholding payable 0
TOTALS
Form 1120S, Page 4, Schedule M-2, Line 3 - Other Additions
Portfolio/interest income
Form 1120S, Page 4, Schedule M-2, Line 5 - Other Reductions
Auto lease inclusion
IRC section 274(n) exclusion
TOTAL
$1,024
2.681
$220
474
1120.WK4
671107
n Final K-1 I I Amended K-1 OMB No. 1545-0130
Schedule K-1 ?0?7
(Form 1120S) arln.
? 1xlE?ri%,
Department of the Treasury For calendar year 2007, or tax
Internal Revenue Service
year beginning 1 Ordinary business income (loss)
(78,869) 13 Credits
and ending 2 Net rental real estate income 008111
Shareholder's Share of Income, Deductions,
Credits, etc. I? See back of form and separate Instructions. 3 Other net rental income (loss ' `
Information About the Corporation 4 Interest income
1,979
A Corporation's employer identification number
25-1751821 Sa Ordinary dividends
B Corporation's name, address, city, state, and ZIP code 5b Qualified dividends 14 Foreign transactions
CORNERSTONE LAND TRANSFER, INC.
4705 EAST TRINDLE ROAD 6 Royalties
MECHANICSBURG, PA 17050-3616 7 Net short-term capital gain (loss)
C IRS Center where corporation filed return
CINCINNATI, OH 8a Net long-term capital gain (loss)
Information About the Shareholder 8b Collectibles (28%) gain (loss)
D Shareholder's identifying number
194-42-8357 8c Unrecaptured section 1250 gain
E Shareholder's name, address, city, state, and ZIP code
VALERIE S. STACKNICK 9 Net section 1231 gain (loss)
4705 EAST TRINDLE ROAD
MECHANICSBURG, PA 17050-3616 10 Other income goes) 15
A Alternative minimum tax (AMT) Rams
4,701
F Shareholder's percentage of stock
ownership for tax year. . , . . . . . . 100.00 %
11 Section 179 deduction 16
C Items affecting shareholder basis
**2,474
12 Other deductions
c
O
N
m 17
A Other information
1,979
0
* See attached statement for a dditional information.
For Paperwork Reduction Act Notice, see Instructions for Form 1120S. Schedule K-1 (Form 11205) 2007
JSA ** IRC SECTION 274(n) EXCLUSION (MEALS & ENTERTAINMENT)
7C1600 2.000
Form 4 V 6 2
Department of the Treasury
Depreciation and Amortization
(Including Information on Listed Property)
2007
Attachment
Internal Revenue Service
? See separate instructions. ? Attach to your tax return. Sequence No. 6 7
Name(s) shown on return Business or activity to which this form relates identifying number
CORNERSTONE LAND TRANSFER, INC. TITLE INS AGENCY/ SETTLEMENT AGT 25-1751821
Election To Expense Certain Property Under Section 179
?_a_. Ar .,.... L......, .? .. 1;c+nri nrnnorhl rmmnlofa Part V hP.fnrP vnu complete Part 1, a
See the instructions for a higher limit for certain businesses
mount
i
1 M 1 $12 00
.
mum a
ax
, , , , , ,
roperty placed in service (see instructions)
t of section 179
t
l
2 T
, , , , , , , , , , , , , , , , , ,
p
cos
o
a
ost of section 179 property before reduction in limitation
h
ld
Th 3 $500,000
o
c
res
3
, , , , , ,
Subtract line 3 from line 2. If zero or less, enter -0-
in limitation
d
ti
4 R 4
. • , , , , , , , , , , , , ,
.
on
e
uc
5 Dollar limitation far tax year. Subtract line 4 from line 1. If zero or less, enter -0-. If manta filing 5
se aratel see instructions . . . . . . . . . . . . • . • . • • • • • • • . . • . •
(a) Description of property (b) Cost (business use only) (c) Elected cos
6 12 5 , <)
t
e
-
7
Enter the amount from line 29
ro
ert
7 Listed k
, , , , , , , , , , , , , , , , , , , , ,
p
y.
p
8 Total elected cost of section 179 property. Add amounts in column (c), lines 6 and 7
8
Enter the smaller of line 5 or line 8
9 Tentative deduction 9
.
over of disallowed deduction from line 13 of your 2006 Form 4562
10 Carr 10
y
Enter the smaller of business income (not less than zero) or line 5 (see instructions)
11 Business income limitation 11
.
17 Sartinn 179 exnense deduction. Add lines 9 and 10, but do not enter more than line 11 .. . . . . . . . . . . . . 12 _
13 Carryover of disallowed deduction to 2008. Add lines 9 and 10, less line 12 . ? 13
Note: Do not use Part 11 or Pad 111 below for listed property. Instead, use Part V.
, Special Depreciation Allowance and Other Depreciation (Do not include listed property.) (See instructions.)
14 Special allowance for qualified New York Liberty or Gulf Opportunity Zone property (other than listed property) and
cellulosic biomass ethanol plant property placed in service during the tax year (see instructions) , , , , , . . . . . . 14
15 Property subject to section 168(f)(1) election . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
16 Other depreciation (including ACRS) 16
OMNI! MACRS Depreciation (Do not include listed property.) (See instructions.)
Section A
17 MACRS deductions for assets placed in service in tax years beginning before 2007 , , , , , , . . . . . 17 12,438
18 If you are electing to group any assets placed in service during the tax year into one or more
general asset accounts, check here . . . . . . . . . . . . . . . . . . . . . . . . . . . No- Section B - Assets Placed in Service During 2007 Tax Year Using the General Depreciation System
(b) Month and (c) Basis for depreciation (d) Recovery
(a) Classification of property year placed in (businessfinvestment use per'w (e) Convention (f) Method (g) Depreciation deduction
service only - see instructions)
19a 3-year property
b 5-year property
c 7-year property
d 10-year property
e 15-year property
f 20-year property
g 25-year property 25 yrs. S/L
h Residential rental 27.5 yrs. M M S/L
property 27.5 yrs. M M S/L
i Nonresidential real 39 yrs. M M S/L
property M M S/L
Section C - Assets Pl aced in Service During 2007 Tax Year Using the Alternative De preciation System
20a Class life S/L
b 12-year 12 yrs. S/L
c 40-year 40 yrs. M M S/L
Summary (see instructions)
21- Listed property. Enter amount from line 28 , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , 21
22 Total. Add amounts from line 12, lines 14 through 17, lines 19 and 20 in column (g), and line 21.
Enter here and on the appropriate lines of your return. Partnerships and S corporations - see instr.. - 22 12,438
23 For assets shown above and placed in service during the current year,
enter the portion of the basis attributable to section 263A costs . . . . . 2For Paperwork Reduction Act Notice, see separate Instructions. Form 4562 (2007)
JSA
7W8656 1.000
Form 4562 (2007) Page 2
Listed Property (include automobiles, certain other vehicles, cellular telephones, certain computers, and
property used for entertainment, recreation, or amusement.)
Note: For any vehicle for which you are using the standard mileage rate or deducting lease expense, complete only
24a 24b, columns (a) through (c) of Section A all of Section B, and Section C if applicable.
Section A - Depreciation and Other Information (Caution: See the instructions for limits for passenger automobiles.)
n_ ...... ti.. - e,dA-- to -.nnnrt the hneineccfinwetmPnt usa r1nimed? X Yes No 24b if "Yes." is the evidence written? IX I Yes I I No
- --'- (a)
Type of property (list (b)
Date placed in Business/
investment (d)
Cost or other (e)
Basis for depreciation
(businessrnystment M
Recovery (9)
Method/ (h)
Depreciation Elected
section 1179
vehicles first) service use basis use onl
) period Convention deduction
percentage y
25 Special allowance for qualified Gulf Opportunity Zone property placed in service during t
tax year and used more than 50% in a qua lified business use (see instructions) ,?
_- 1 t_I i `
ec o?.,ne.t„ ncort mnre than 5no/ in a nualfiPtt business use: =._.y
LEASED AUTO 9/14/04 1000
LEASED AUTO 9/19/07 100°/
014
27 Property used 50% or less in a qualified business use:
S/L -
S/L -
S/L -
28 Add amounts in column (h), lines 25 through 27. Enter here and on line 21, page 1 , , , , , , , , , , , , , , , 28
29 Add amounts in column (I) line 26. Enter here and online 7, page 1 29
Section B - Information on Use of Vehicles
Complete this section for vehicles used by a sole proprietor, partner, or other "more than 5% owner," or related person.
If vni nrnvided vehicles to vour emDlovees, first answer the questions in Section C to see if you meet an exception to completing this section for those vehicles.
30 Total business/investment miles driven
ti (a)
Vehicle 1 (b)
Vehicle 2 (c)
Vehicle 3 (d)
Vehicle 4 (e)
Vehicle 5 (f)
Vehicle 6
ng
during the year (do not include commu
miles) 14455 4819
31 ,,,,,,,,,,,,,,,,,,,,,,
Total commuting miles driven during the year 0 0
32 Total other personal (noncommuting)
miles driven 0 0
33 Total miles driven during the year. Add
lines 30 through 32 14 , 4 55 4, 819
34 , , , , , , , , , , , , , , ,
Was the vehicle available for personal Yes No Yes No Yes No Yes No Yes No Yes No
use during off-duty hours? X X
, , , , , , , , , , , , ,
35 Was the vehicle used primarily by a
more than 5% owner or related person? X X
, , , , , , ,
36 is another vehicle available for personal
use? X X
Section C - Questions for Employers Who Provide Vehicles for Use by Their Employees
Answer these questions to determine if you meet an exception to completing Section B for vehicles used by employees who are
not more than 5% owners or related persons (see instructions).
37 Do you maintain a written policy statement that prohibits all personal use of vehicles, including commuting, Yes No
by your employees? . . . . . . . . . . , , ------ , , . . , , , , , , , , , , , . , .
38 Do you maintain a written policy statement that prohibits personal use of vehicles, except commuting, by your employees?
See the instructions for vehicles used by corporate officers, directors, or 1%or more owners , , , , , , , , , , , , , , , , , , , , ,
39 Do you treat all use of vehicles by employees as personal use?
40 Do you provide more than five vehicles to your employees, obtain information from your employees about
the use of the vehicles, and retain the information received?
41 Do you meet the requirements concerning qualified automobile demonstration use? (See instructions.)
Note: If your answer to 37, 38, 39, 40, or 41 is "Yes," do not complete Section B for the covered vehicles. t'
Amnrii??tinn
F-PlIllMill
•,v• -•
-.v.. (b) (c) (d) rtez M
(a) Date amortization Amortizable Code ation
Amo Amortization for
Description of costs begins amount section period or this year
percentage
42 Amortization of costs that begins during your 2007 tax year (see instructions):
43 Amortization of costs that began before your 2007 tax year 43
44 Total. Add amounts in column (f). See the instructions for where to report , , , , , , , , , , , , , , , , , , , , , , 44
J 6A
7X2310 7.000 Form 4562 (2007)
7X2
2008 Deposits into the Select Land Transfer, US. Operating Account
January 1, 2008 to October 31, 2008 $139,336.60
Less 15% to underwriters 20,900.49
Amount paid to Cornerstone from revenues (25Z) 29,588.52
*******?r***?*?Ie******ic?kileileib?e****?reie****?re*********ikdc**ak?Ae****************ik?t*?1F
2008.,?Deposits into the Heritage Land Transfer, 1}1x6. Operating Account
January 1, 2008 to October 31, 2008 $10,221,20
less 15% to underwriterers11553.18
Amount paid to Cornerstone from Revenues (512) 4,420.69
2008 Deposits into the Charter Settlement Services-,,LLC Operating Account
January 1, 2008 to October 31, 2008 20,786.66
less 15Z to underwriters 3,117.99
Amount paid to Cornerstone from Revenues (70Z) 12,386.06
PLAINTIFF'S
EXHIBIT
- oY
Interest income earned from Smith Barney Account
July, August, September 432.74
PLAINTIFF'S
EXHIBIT
I1- -0 ?e.
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Phone: (717) 240-6225 SEPTEMBER 23, 2008 Fax: (717) 240-6248
MATTHEW R. STACKNICK )
Plaintiff )
VS. )
VALERIE S. STACKNICK )
Defendant )
Docket Number 08-265 CIVIL
PACSES Case Number 3 5 910 9 8 3 8
Other State ID Number
Please note: All correspondence must include the PACSES Case Number.
Income Statement
THIS FORM MUST BE FILLED OUT AND YOU MUST PROVIDE DOCUMENTS TO SUPPORT ALL
AMOUNTS PROVIDED IN THIS INCOME STATEMENT
(If you are self-employed or if you are salaried by a business of which you are owner in whole or in part, you
must also fill out the Supplemental Income Statement which appears below.)
INCOME STATEMENT OF
)/ abm (Name) (PACSES Number)
I verify that the statements made in this Income Statement are true and correct. I understand that false statements
herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unworn falsification to authorities.
Date: I C7(?5??? .
Plaintiff or Defendant
INCOME
Employer:
Address:
l?anS?v?'
Type of Work: rQOJ AxA 0-, i ka? (51
.J.riO?IJJ? Q Q (] 1yC i 1,
Payroll Number:
Pay Period (weekly, biweekly, etc): y?l
Gross Pay per Pay Period $ 011)(),(30
Itemized Payroll Deduction:
Federal Withholding $ a .? 3
FICA
Local Wage Tax j , 3
State Income Tax
Mandatory Retirement -
Union Dues -
Health Insurance
Other (specify) _-MA Q1.v 6
?1? rnor ? ?u, t? ?.
U. 1 ? S
Net Pay per Pay Period:
PLAINTIFF'S
EXHIBIT
1-y-0 v? 6
$ J? 93, ?)3
Form IN-008 Rev. 2
Service Type M Worker ID 21302
A
Income Statement (Continued)
Other Income:
Week
Interest $ _
Dividends
Pension Distributions
Annuity
Social Security
Rents fQ ` ULYl VI WJ
Royalties
Unemployment Comp.
Workers Comp.
Employer Fringe Benefits
Other
PACSES Case Number 359109838
Month Year
(Fill in Appropriate Column)
1,520 -
Ownership*
Value H W J
TOTAL INCOME
PROPERTY OWNED
Checking accounts
Savings accounts
Credit Union
Stocks/bonds
Real Estate
Other
Description
Total
INSURANCE
Hospital
Blue Cross
Other
Medical
Blue Shield
Other
Health/Accident
Disability Income
Dental
Other
Coverage*
Company Policy No. H W C
*H=Husband; W=Wife; J=Joint; C=Child
Service Type M
Page 2 of 3 Form IN-008 Rev. 2
Worker ID 21302
w
Income Statement (Continued)
PACSES Case Number 359109838
SUPPLEMENTAL INCOME STATEMENT (You only need to complete the below portion if you are
self-employed or if you are salaried by a business of which you are owner in whole or in part)
(a) This form is to be filled out by a person (check one):
? (1) who operates a business or practices a profession, or
? (2) who is a member of a partnership or joint venture, or
? (3) who is a shareholder in and is salaried by a closed corporation or similar entity.
(b) Attach to this statement a copy of the following documents relating to the partnership, joint venture,
business, profession, corporation or similar entity:
(1) the most recent Federal Income Tax Return, and
(2) the most recent Profit and Loss Statement.
(c) Name of business:
Address and telephone number:
(d) Nature of business
(check one)
? (1) partnership
? (2) joint venture
? (3) profession
? (4) closed corporation
? (5) other
(f) Annual income from business:
(1) How often is income received?
(2) Gross income per pay period:
(3) Net income per pay period:
(4) Specific deductions, if any: _
Page 3 of 3 Form IN-008 Rev. 2
Service Type M Worker ID 21302
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Phone: (717) 240-6225 SEPTEMBER 23, 2008 Fax: (717) 240-6248
MATTHEW R. STACKNICK ) Docket Number 08-265 CIVIL
Plaintiff )
VS. ) PACSES Case Number 3 5 910 9 8 3 8
VALERIE S. STACKNICK )
Defendant ) Other State ID Number
Please note: All correspondence must include the PACSES Case Number.
Guidelines Expense Statement
EXPENSE STATEMENT OF
(Name)
(Pacses Number)
I verify that the statements made in this Expense Statement are true and correct. I understand that false statements
herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unworn falsification to authorities.
Date:
Plaintiff or Defendant
Instructions: Guidelines Expense Statement - This form should only be completed when:
1) You are requesting an adjustment to the amount of support pursuant to Rule 1910.16-5 because of
unusual needs and unusual fixed obligations, other support obligation, medical expenses not covered by
insurance, or any other relevant factors, or
2) You are requesting that the other party share in the following expenses pursuant to Rule 1910.16-6:
child care expenses, health insurance premiums, unreimbursed medical expenses, private school tuition,
summer camp, or other needs, or mortgage payment.
You must provide documents to support all amounts provided in this Expense Statement
Weekly Monthly Yearly
( Fill in Appropriate Column)
Mortgage (including real estate
taxes and hom er's
insurance) Rent
$ (X ??
'r1 p f, L'# M
$ Q,opO C
11 y
$AGt?op e
Health Insurance Premiums -- p -
Unreimbursed Medical
-Expenses:
-
Doctor
Dentist 46, 0 d a;t rte,
Orthodontist _ 0-
Hospital ital -0-
Medicine -0-
Special Needs (glasses,
braces, orthopedic
devices, therapy)
_ D_
?-1 k.nv1ew?
Form IN-008 Rev. 2
Service Type M Worker ID 21302
Guidelines Expense Statement (Continued)
Weekly Monthly Yearly
Child Care
Private School - d ,
Parochial school . ?-
Loans/Debts 0
Support of Other Dependents: -- D -
Other child support -0-
Alimony payments
Other: (Specify) Q?
0.
9AZ ,a
Total
JL) $ $ IS .D6
$
PACSES Case Number 359109838
}btA
sac p
Service Type M
Page 2 of 2
Form IN-008 Rev. 2
Worker ID 21302
f
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
MATTHEW R. STACXMCY, IN THE COURT OF COMMON PLEAS
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
V. : PACSES NO. 790109771
VALERIE S. STACXMCY, CIVIL ACTION -LAW
Defendant IN DIVORCE
INCOME AND EXPENSE STATEMENT
OF MATTHEW R STACKNICK
I, Matthew R. Stacknick, verify that the statements made in this income and expense
statement are true and correct. I understand that false statements herein are made subject to the
penalties if 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities.
Dated: 2008
/VW
DEFENDANT'S
EXHIB
ML-
THEW R CIMCK
INCOME:
Employer:
Address:
Type of work:
Payroll Number:
Pay period (weekly, biweekly, etc.):
Gross pay per pay period:
Federal Filing Status:
Itemized Payroll Deductions:
Borough of Mechanicsburiz
36 West Allen Street
Mechanicsbure. PA 17055
Operations Manager
Bi-weekly
$1,688.69
Federal Withholding: 261.56
Social Security: $ 104.70
Local Wage Tax: 28.71
State Income Tax: 51.84
Other State: 1.01
Medicare: 24.49
Union Dues $ 27.00
LST EMS Tax: 2.10
Health Insurance: .00
Net pay per pay period: $1,187.28
Monthly net: $2,572.44
OTHER INCOME: MONTHLY
Interest .00
Dividends .00
Pension $ .00
Annuity .00
Social Security .00
Rents $ .00
Royalties $ 00
Expense Acct. .00
Gifts $ .00
Unemployment Comp. $ .00
Alimony .00
Total Income: 00 Net/Month
2
EXPENSES MONTHLY
Home: Mortgage/Rent
Maintenance/Pool 100.00 1/2 of household expense
Utilities:
Electric 129.45 1/2 of household expense
Gas 24.00
Telephone/Cell 105.00 Average
Sewer 46.36 High St and Cabin
Trash 7.25 1/2 of household expense
Kerosene 17.50 1/2 of household expense
Lawn Care 25.00 1/2 of household expense
Septic Tank Pump 11.66 1/2 of household expense
Every three years, due this year
Employment: Public Transportation
Lunch
Taxes: Real Estate 299.70 House and Cabin
Real Estate 24.33 High Street
Insurance: Homeowners 47.41 House and Cabin
Homeowners 5.58 High Street
Automobile 151.50 Cars and Motorcycle
Life
Accident
Long term health insurance
Health Insurance
Other-Umbrella
Automobile: Payments 1260.00
Tractor Payment 322.00
Fuel 180.00
Repairs 100.00
AAA $5.40
Medical Doctor $20.00 co-pays
Dentist $20.00 co-pays
Orthodontist
Hospital
Medicine
Special Needs: $25.00
(Glasses, braces, orthopedic)
EXPENSES
Education: Private School
Parochial School
College
Religious
Personal: Clothing 50.00
Food 300.00
Barber/Hairdresser/Nails
Credit Payments Credit Card 100.00
Charge
Other
Loans: Credit Union
Miscellaneous Household Help
Child Care
Papers/books/magazines 20.00
Entertainment 200.00
Pay Television 65.00
Vacation 125.00
Gifts 100.00
Legal Fees $1,000.00 Approx. based on last 4 months
Charitable Contributions 25.00
Gym Membership $35.00
Pets 12.50
Other: Internet 20.71
Total Expenses $4,960.35
Yp'yd -
42or'al6U4
Stacknick - Counse l Fees
4/8/08-4/15/08 $260.00
4/16/08-5/16/08 $3,297.52
5/16/08-6/16/08 $493.96
6/17/08-7/17/08 $683.99
7/17/08-8/17/08 $766.16
Conrad Sie el Actuaries $450.00
8/18/08-9/17/08 $615.01
9/18/08-1 0/18/08 $231.34
$6,797.98
F
not",
,, _?
; ? ?
,-t
y
-; Y.t
_
?r
r
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State _Commonwealth of Pennsylvania
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 11/06/08
Case Number (See Addendum for case summary)
Employer/Withholder's Federal EIN Number
CORNERSTONE LAND TRANSFER INC
4705 E TRINDLE RD
MECHANICSBURG PA 17050-3616
194-42-8357
Employee/Obligor's Social Security Number
6405101930
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.
$ 0.00
$
$ 0.00
0.00
$ 0.00
$ 344.00
$ 46.00
$ 0.00
$ 0.00
for a total of $
per month in current child support
per month in past-due child support
per month in current medical support
per month in past-due medical support
per month in current spousal support
per month in past-due spousal support
per month for genetic test costs
per month in other (specify)
one-time lump sum payment
Arrears 12 weeks or greater? ® yes Q no
390.00 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:
$ 90.00 per weekly pay period. $ 195.00 per semimonthly pay period
(twice a month)
$ 180.0 0 per biweekly pay period (every two weeks) $ 390.00 per monthly pay period.
REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10)
working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of
withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work
state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of
the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding,
the following information is needed (See #9 on page 2).
If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call
Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580
for instructions. PA FIPS CODE 42 000 00
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAMEAND 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. / , 7 // 17
BY THE COURT: / l/// C__7 iY ? V. 7, , 2 0 -?
DRO: R. J. Shadday
Service Type M
OMB No.: 0970-0154
OOriginal Order/Notice
3591098
08-265 CIVIL OAmended Order/Notice
(Terminate Order/Notice
QOne-Time Lump Sum/Notice
RE:STACKNICK, VALERIE S.
Employee/Obligor's Name (Last, First, MI)
. Wesley Oler, Jr.,
Judge
Form EN-028 Rev. 4
Worker ID $IATT
390-
5 2 2• .
90.00
390-
?
126
180?'?C*
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
F1 If heck you are required to provide a copy of this form to your m loyee. If yoyr employee works in a state that. is
dierent from the state that issued this order, a copy must be provigec?to your employee even if the box is not checked
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employee/obligor.
3.* Reporting the Paydate/Date of Withholding: You must report the paydate/date of withholding when sending the payment. The
paydate/date of withholding is the date on which amount was withheld from the employee's wages. You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. 2517518210
THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : 0 THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 0
EMPLOYEE'S/OBLIGOR'S NAME: STACKNICK, VALERIE S.
EMPLOYEE'S CASE IDENTIFIER: 6405101930 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
LAST KNOWN PHONE NUMBER:
FINAL PAYMENT AMOUNT-
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employeelobligor from employment,
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (CCPA) 0 5 U.S.C. 1673 (b)); or 2) the amounts allowed by the State or Tribe of the employee's/obligor's principal place of
employment. Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes, Social
Security taxes, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is
supporting another family and 60% of the disposable income if the obligor is not supporting another family.However, that 50% limit is
increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State, you may
deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section.
Arrears greater than 12 weeks : If the Order Information does not indicate whether the arrears are greater than 12 weeks, then the
employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts
allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser of
the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of the
CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amounts paid for health
care premiums in determining disposable income and applying appropriate withholding limits.
10. Additional info:
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state
that issued this order with respect to these items.
1 1. Send Termination Notice and
other correspondence to:
DOMESTIC RELATIONS SECTION
If you or your employee/obligor have any questions,
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.childsuppor .state.pa.us
Page 2 of 2 Form EN-028 Rev. 4
Service T e M OMB No.: 0970-0154
YP Worker ID $IATT
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: STACKNICK, VALERIE S.
PACSES Case Number 359109838
Plaintiff Name
MATTHEW R. STACKNICK
Docket Attachment Amount
08-265 CIVIL $ 39010
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintime
Docket Attachment Amount
$ o.oo
Child(ren)'s Name(s): DOB
PACSES Case Number
Plainti- ff Name
Docket Attachment Amount
$ o.oo
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ o.oo
Child(ren)'s Name(s): DOB
PACKS Case Number
Plaintiff Name
Docket Attachment Amount
$ o.oo
Child(ren)'s Name(s): DOB
Service Type M Addendum Form EN-028 Rev. 4
OMB No.: 0970-0154 Worker ID
$IATT
N
c t
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsylvania
CO./City/Dist. of CUMBERLAND
Date of Order/Notice 10/30/09
Case Number (See Addendum for case summary)
Employer/Withholder's Federal EIN Number
CORNERSTONE LAND TRANSFER INC
4705 E TRINDLE RD
MECHANICSBURG PA 17050-3616
08-265 CIVIL
0original Order/Notice
OAmended Order/Notice
OTerminate Order/Notice
OOne-Time Lump Sum/Notice
Employee/Obligor's Name (Last, First, MI)
194-42-8357
Employee/Obligor's Social Security Number
6405101930
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'slobligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 344.00
$ 0.00
$ 0.00
$ 0.00
for a total of $
per month in current child support
per month in past-due child support
per month in current medical support
per month in past-due medical support
per month in current spousal support
per month in past-due spousal support
per month for genetic test costs
per month in other (specify)
Arrears 12 weeks or greater? 0 yes ® no
one-time lump sum payment
344.00 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:
$ 79.38 per weekly pay period. $ 172.00 per semimonthly pay period
(twice a month)
$ 158.77 per biweekly pay period (every two weeks) $ 344.00 per monthly pay period.
REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10)
working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of
withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work
state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of
the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding,
the following information is needed (See #9 on page 2).
Pennsylvania law (23 PA C.S. § 4374(b)) requires remittance by an electronic payment method if an employer is
ordered to withhold income from more than one employee and employs 15 or more persons, or if an employer has
a history of two or more returned checks due to nonsufficient funds. Please call the Pennsylvania State Collections
and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. PA FIPS CODE
42 000 00
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDA T'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identi ier) OR SOC SECUR Y NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL. /y ?A ,
BY THE COURT: (? IV'o V • a 9
J. Wesley Oler, Jr., Judge
RE:STACKNICK, VALERIE S.
DRO: R. J. Shadday r Form EN-028 Rev.5
Service Type M OMB No.: 0970-0154 Worker ID $IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
? If hheckefl you are required to provide a copy of this form to youum loyee. If you
r employee works in a state that is
di event rrom the state that issued this order, a copy must be provi edpto your employee even if the box is not checked.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employee/obligor.
3. * Reporting the Paydate/Date of Withholding: You must report the paydate/date of withholding when sending the payment. The
paydate/date of withholding is the date on which amount was withheld from the employee's wages. You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. 2517518210
THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : 0 THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 0
EMPLOYEE'S/OBLIGOR'S NAME: STACKNICK, VALERIE S.
EMPLOYEE'S CASE IDENTIFIER: 6405101930 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
LAST KNOWN PHONE NUMBER:
FINAL PAYMENT AMOUNT
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment,
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9. * Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (CCPA) 0 5 U.S.C. 1673 (b)); or 2) the amounts allowed by the State or Tribe of the employee's/obligor's principal place of
employment. Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes, Social
Security taxes, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is
supporting another family and 60% of the disposable income if the obligor is not supporting another family.However, that 50% limit is
increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State, you may
deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section.
Arrears greater than 12 weeks : If the Order Information does not indicate whether the arrears are greater than 12 weeks, then the
employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts
allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser of
the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of the
CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amounts paid for health
care premiums in determining disposable income and applying appropriate withholding limits.
10. Additional info:
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state
that issued this order with respect to these items.
11. Send Termination Notice and
other correspondence to:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717) 240-6248 or
by internet www.childsupport.state.pa.us
Page 2 of 2 Form EN-028 Rev.5
Service Type M OMB No.:097aois4 Worker ID $IATT
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: STACKNICK, VALERIE S.
PACSES Case Number 359109838 PACSES Case Number
Plaintiff Name Plaintiff Name
MATTHEW R. STACKNICK
Docket Attachment Amount Docket Attachment Amount
08-265 CIVIL $ 344.00 $ 0.00
Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
PACKS Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
Addendum Form EN-028 Rev.5
Service Type M Worker ID
OMB No.: 0970.0154 $IATT
HLED-?FICE
OF THE P"'THO'! 'OTARY
R.
2609 NOV -4 PH 2: 33
VALERIE S. STAC MILK : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff n o
Vs. a T'
Docket No. 2008-265
MAZRW R. STACRnTIC?C? T
z f'
Defendant
MOTION FOR APPOINTMENT OF "TER > C 0M
Matthew R. Stacknick Q3Ltica (Defendant), moves the court to appoinga njster th
respect to the following claims: o
() Divorce Distnbution. of Property
() Affiulment E) Support
( Alimony ( Counsel Fees
Alimony Pendeate Lite (K) Costs and Expenses
and in support of the motion states:
(1)' Discovery is complete as to the claims (s) for which fli appointment of a master is
requested Discovery is being served simultaneously herewith.
(2) The defendant (has) appeared in the action ( (by his attorney,
Barbara Simple-Sullivan , Esquire).
(3) The Staturory ground (s) for divorce (10 Cx (are)
3301(a)(2), 3301(c)', 3301(d)
(4) Delete the inapplicable paragraph(s):
a. The action is not contested
b. An agreement has been reached with respect. to the following claims:
None.,
action. - is : contested, with .° :respect to ;lhe fohowmg _ .Maims:
Divorce, Egvtable Distribution, Alimony,.Counsel Fees, Costs and
(5) The action (jffi(does not involve) complex issues, of law or fact Expenses.
{6) .The.. g s`expected to take one, ) ( )
(7) Addltianal information; if/ re to the .. motion:
None.. /
Date: March A 2010 fib
Attorney for ((.-(Defendant)
Print Agamey Name Barbara sumple-sul.1tvapi! Esquire
ORDER APPOINTING MASTER
AND NOW, , 20 Esquire
is appointed master with respect to the following claims:
By the Court:
J.
MAR U 8 ZU10
VALERIE S. STAC=CK : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff c7
Vs. C - `n
MATIMW R. STAMUCK Docket No. 2008-265
f r, cn C
Defendant = f -0 c?
MOTION FOR APPOINTMENT OF MASTER r_ (Z 0M
Matthew R. Stacknick (Defendant), moves the court to appoh$ a aster th
respect to the following claims: e
( Divorce Distribution. of Property.
() Annulment () Support
(x.) Alimony (} Counsel Fees
(.} Alimony Pendente Lite Oc) Costs and Expenses
and in support of the motion states:
(1)' Discovery is complete as to the claims (s) for which thgappointment of a master is
requested Discovery is being served simultaneously herewith.
(2),-Tlie defendant (has) #==o#X appeared in the action: e( verse (by his attorney,
Barbara Sumple-Sullivan , Esquire). ..
(3) The Staturory ground (s) for divorce (1-0m (are)
.3301(a)(2), 3301(c), 3301(d) -
(4) Delete the inapplicable paragraph(s):
a. The action is not contested
b. An agreement has been reached with respect to the following claims:
None.
C. The action .: 2s : contested with .:respect to ;. the fallo.:'
g claims:
Divorce,. Equitable Distribution,. Alimony,:C'ounsel Fees, Costs and
(3) The action (?y*kwck(does not involve) co le^x issues-of law or fact Expenses.
eating: s?expected o take one Ems) ( )?
(7) : Additional information; / -re and ta. the_:. - motion:
None:.
Date: March ..4, 2'010 ??--
Attorne for efendant
Y ?;CD )
Pnnt.Attomey Name .......... Barbara Sua ple=Sull van Eseluire
ORDER APPOIN [ING TER
AND NOW, 20dA&A,' R' , 200 Esquire
is appointed master with respect to the following claims: ?i ?a.? d,?suP
£C :11 HV 6- EV14 01OZ
Ab ONG"H .Odd 3Hi :
3,,,_=-0--Q3113
By the Court' ? J.
' Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
VALERIE S. STACKNICK, IN THE COURT OF COMMON PLEAS ? -
Plaintiff, CUMBERLAND COUNTY
PENNSfUV I A
,
M 13,71 L
r, r1i
v. NO. 08 - 265 r ? m
' Cr, 2
MATTHEW R. STACKNICK, CIVIL ACTION -LAW
Defendant IN DIVORCE C_
? ca
,
NOTICE TO PLAINTIFF
If you wish to deny any of the statements set forth in this Affidavit, you must file a Counter-
affidavit within TWENTY (20) DAYS after this affidavit has been served on you or the statements
will be admitted.
DEFENDANT'S AFFIDAVIT UNDER SECTION 3301 (D)
OF THE DIVORCE CODE
1. The parties to this action separated on November 10, 2007, and have continued to live
separate and apart for a period of at least two (2) years.
2. The marriage is irretrievably broken.
3. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
I VERIFY THAT THE STATEMENTS MADE IN THIS AFFIDAVIT ARE TRUE
AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE
SUBJECT TO THE PENALTIES OF 18 PA. C.S.A. SECTION 4904 RELATING TO
UNSWORN FALSIFICATION TO AUTHORITIES.
DATED: 4, a 20,1o
TTHEW . STACKNICK
P
VALERIE S. STACKNICK,
Plaintiff,
V.
MATTHEW R. STACKNICK,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08 - 265
: CIVIL ACTION -LAW
IN DIVORCE
COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE
1. Check either (a) or (b):
(a) I do not oppose the entry of a divorce decree.
_ (b) I oppose the entry of a divorce decree because
(Check (I) (ii) or both):
_ (I) The parties to this action have not lived separate and apart for a period of at least two years.
_ (ii) The marriage is not irretrievably broken.
2. Check either (a) or (b):
_ (a) I do not wish to make any claims for economic relief. 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.
_ (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees
or expenses or other important rights.
I understand that in addition to checking (b) above, I must also file all of my economic claims
with the prothonotary in writing and serve them on the other party. If I fail to do so before the date
set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered
without further notice to me, and I shall be unable thereafter to file any economic claims.
I verify that the statements made in this counter-affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to
unworn falsification to authorities.
Dated:
VALERIE S. STACKNICK
NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to
make any claim for economic relief, you should not file this counter-affidavit.
r -
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
VALERIE S. STACKNICK,
Plaintiff,
V.
MATTHEW R. STACKNICK,
Defendant
FILED-c FF11CE
OF Th'E PP0TH0N10TAPY
201QHAA -5 Ph f:39
CUPS _ ,, ;?
IN THE COURT OF COMM ,"OURS. i
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08 - 265
CIVIL ACTION -LAW
IN DIVORCE
PETITION RAISING MARITAL
CLAIMS UNDER THE DIVORCE CODE OF 1980
AND NOW, this 4t' day of March, 2010, comes Defendant, Matthew R. Stacknick
(hereinafter referred to as "PETITIONER"), by and through his attorney, Barbara Sumple-Sullivan,
Esquire and files this Petition Raising Marital Claims Under the Divorce Code of 1980 and in
support thereof states as follows:
1. A Complaint in Divorce was filed on January 15, 2008.
2. Petitioner is the Defendant in the above action.
3. Respondent is the Plaintiff in the above action.
4. Petitioner lacks sufficient assets to provide for his reasonable needs and is unable to
support himself fully through appropriate employment.
e? ?ogY
i?a?O y
5. Respondent has sufficient assets to provide alimony for Petitioner.
6. Petitioner requests the Court to enter an order granting alimony to your Petitioner as the
Court deems reasonable pursuant to Sections 3701 of the Divorce Code of 1980, together
with any amendments thereto.
WHEREFORE, Petitioner requests this Honorable Court enter an order for an award of
alimony.
Respectfully submitted,
DATE: March 4, 2010
(717) 774-1445
Supreme Court I.D. 32317
Attorney for Defendant
2
Barbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070-1931
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
VALERIE S. STACKNICK, IN THE COURT OF COMMON PLEAS
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 08 - 265
MATTHEW R. STACKNICK, CIVIL ACTION -LAW
Defendant IN DIVORCE
VERIFICATION
I, Matthew R. Stacknick, hereby certify that the facts set forth in the foregoing PETITION
RAISING MARITAL CLAIMS 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.
§4904 relating to unsworn falsification to authorities.
DATED: l?G? d/O wx'?" ke-"r_L?
M THEW . STACKNIC
4
J
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
VALERIE S. STACKNICK, IN THE COURT OF COMMON PLEAS
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 08 - 265
MATTHEW R. STACKNICK, 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 foregoing PETITION RAISING MARITAL CLAIMS in the above-captioned
matter upon the following individual(s) by first class mail, postage prepaid, addressed as follows:
Samuel L. Andes, Esquire
P.O. Box 168
Lemoyne, PA 17043
DATED: March 4, 2010
L3arbara Sumple-Sullivan, Esquire
Attorney for Defendant
549 Bridge Street
New Cumberland, PA 17070-1931
(717) 774-1445
Supreme Court I.D. No. 32317
Commonwealth of Pennsylvania
County of Cumberland, ss: FILM ? ;E
r Ry
VALERIE S. STACKNICK, ) W /* l? SD
Plaintiff ) NO. 08-265 Civil Term- j
vs. ) CIVIL ACTI(WMfik !? ?C ,gTy
PEN,
vSY('Wt??1?
MATTHEW R. STACKNICK, ) DIVORCE
Defendant )
Motion for Appointment of Master
VALERIE S. STACKNICK, Plaintiff moves the court to appoint a Master with respect to the following
claims:
(xxx) Divorce (xxx) Distribution of Property
( ) Annulment ( ) Support
(xxx) Alimony (xxx) Counsel Fees
(xxx) Alimony Pendente Lite (xxx) Costs and Expenses
and in support of the motion states:
1. Discovery is complete as to the claim(s) for which the appointment of a Master is requested.
2. The Defendant has appeared in the action by his attorney, Barbara Sumple Sullivan.
3. The statutory ground(s) for divorce is: 3301 (c) of the Divorce Code.
4. Check the applicable paragraph(s).
(xxx) The action is not contested.
( ) An agreement has been reached with respect to the following claims:
( ) The action is contested with respect to the following claims:
5. The action does not involve complex issues of law or fact.
6. The hearing is expected to take 1 day.
7. Additional information, if any, relevant to the motion:
Date muel L. A N es
Attorney for Plaintiff
AND NOW, _ 2010, , Esquire, is appointed Master
with respect to the following claims: divorce, alimony, alimony pendente lite, distribution of property, counsel
fees, and costs and expenses.
BY THE COURT,
J.
Distribution:
Samuel L. Andes, Esquire (Attorney for Plaintiff)
525 North 12''' Street, P.O. Box 168, Lemoyne, PA 17043
Barbara Sumple Sullivan, Esquire (Attorney for Defendant)
549 Bridge Street, New Cumberland, Pa 17070
VALERIE S. STACKNICK, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 08 - 265 Civil
MATTHEW R. STACKNICK,
?rn '-'
-0 -r
rnF
Defendant IN DIVORCE =? ::v -0p
=
ORDER OF COURT C
C D
tV
M
AND NOW, this 1 day of
2011, an agreement having been reached between the parties
resolving all claims raised in the proceedings, the agreement,
at the request of counsel (see counsel's letter of March 30,
2011, attached hereto), not to be made part of the record, the
appointment of the Master is vacated and counsel can file a
praecipe transmitting the record to the Court, along with the
affidavits of consent and waivers of notice of intention to
request entry of divorce decree signed by the parties,
requesting a final decree in divorce.
BY THE COURT,
V__ ' /'1 / K,
Kevin X. Hess, P. J.
cc: ? Samuel L. Andes /
Attorney for Plaintiff l ?f
Barbara Sumple-Sullivan
Attorney for Defendant y/IJH
MAR-30-2011(WED) 10:03
KA=LnM AZDRW'4r:
P. 0. RON Ieo
L=OTXLr PA 17"N-101py
30 March 2011
SENTRY FAX sic R -GUTAR MAIL (240-78901
Mr. E. Robert Elicker, 11
Office of the Divorce Master
9 North Hanover Street
Carlisle, PA 17013
RE: Stacknick vs. Stacknick
No. 08-26S Ctvti Term
Dear Mr. Elicker:
P. 001/001
Tr,LKPUD!R
7171 76J-6 N11
P46X
1717) 7tl1-mapt
I represent Valerie Stacknick in the above matter, in which you have scheduled a
pre-hearing settlement conference for Wednesday. I am happy to report that the parties
have reached an agreement which resolves all of the economic issues in the case and do
not need any further proceedings in your office.
The parties do not want the terms of their settlement placed into the court record or
made public in any other way. Accordingly, I write to request that you vacate your
appointment without receiving a copy of the agreement. When I file the consents and
waivers to conclude the divorce, I will have the parties sign Praecipes withdrawing their
economic claims.
If this is satisfactory, please file the paperwork to vacate your appointment as soon
as possible so we can conclude the divorce.
Sincerely,
wnh
Samuel Andes. Esq.
(FRX)717 761 1435
SAMUEL L. ANDES
ATTORNZY AT T. %W
=5 WORM rwrTrM STkaa'r
P O• Box lea
1.1:MOYXF. PB1WSYI.YAXX.% 17043
Samucl L. Andes
cc: Ms. Valerie S. Stacknick
Barbara Sumple Sullivan, Esquire
FILED-OFFICE
OF THE PROTHONOTARY
VALERIE S. STACKNICK,
Plaintiff
vs.
MATTHEW R. STACKNICK,
Defendant
TO THE PROTHONOTARY:
2011 APR -5 PM 12: 32
CUMBERLAND COUNTY
PENNSYLVANIA
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 08-265 CIVIL TERM
IN DIVORCE
PRAECIPE
Please withdraw all economic claims previously filed by me or on my behalf in the above
matter, including, without lnnitation, claims for equitable distribution, alimony, alimony
pendente lite, and counsel fees and expenses.
Date: S-'29- 1I
/&? IAZ /
Ma hew R. Stac ck.
646 Old Grove Road
Mechanicsburg, PA 17055
FILED-OFFICE
OF THE PROTHONOTARY
VALERIE S. STACKNICK,
Plaintiff
vs.
MATTHEW R. STACKNICK,
Defendant
TO THE PROTHONOTARY:
2011 APR -S PM 12: 33
CUMBERLAND COUNTY
PENNSYLVANIA
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 08-265 CIVIL TERM
IN DIVORCE
PRAECIPE
Please withdraw all economic claims previously filed by me or on my behalf in the above
matter, including, without limitation, claims for equitable distribution, alimony, alimony
pendente lite, and counsel fees and expenses.
Date: 1 r?? a ?l a o II
Valerie S. Stacknick
4705 E. Trindle Road
Mechanicsburg, PA 17050
FILED-OFFICE
OF THE PROTHONOTARY
2011 APR -5 PM 12: 33
CUMBERLAND COUNTY
PENNSYLVANIA
VALERIE S. STACKNICK,
Plaintiff
vs.
MATTHEW R. STACKNICK,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 08-265 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
15 January 2008 and served upon the Defendant thirty days thereafter.
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
to Request Entry of the Decree.
4. I have been advised of the availability of marriage counseling and understand that 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.
Date
Va tvu.W /Jt u e?;tiuU/
VALERIE S. STACKNICK
FILED-OFFICE h Y,,
OF THE PROTHONO TAR e
2011 APR -5 PM 12: 33
CUMBERLAND N iw
AA
VALERIE S. STACKNICK,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
MATTHEW R. STACKNICK,
Defendant
CIVIL ACTION - LAW
NO. 08-265 CIVIL TERM
IN DIVORCE
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.
0 vWkv ag, a oll
Date
Y(t /v v /J lit a
VALERIE S. STACKNICK
FILED-OFFICE
OF THE PROTHONOTARY,
2011 APR -5 PM 12: 32
CUMBERLAND COUNT"
PENNSYLVANIA,
VALERIE S. STACKNICK,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
MATTHEW R. STACKNICK,
Defendant
CIVIL ACTION - LAW
NO. 08-265 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
15 January 2008 and served upon the Defendant thirty days thereafter.
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
to Request Entry of the Decree.
4. I have been advised of the availability of marriage counseling and understand that 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.
_?' -'' 9 -//
Date
OTTHEW AK
FILED-OFFICE
OF THE PROTHONOTARY
2011 APR -5 PM 12= 32
CUMBERLAND COUNTY
PENNSYLVANIA
VALERIE S. STACKNICK,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
MATTHEW R. STACKNICK,
Defendant
CIVIL ACTION - LAW
NO. 08-265 CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER SECTION 3301 LQ 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.
,3J-?I /?
Date
HEW R. ACKNICK
VALERIE S. STACKNICK,
vs.
MATTHEW R. STACKNICK,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NO. 08-265 CIVIL TERM
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court for entry of a divorv
decree:
rnco
1. Ground for divorce: =
Irretrievable breakdown under § (3301(c)) and CAI-
§ (3301(d)(1)) of the Divorce Code. r-
v
(Strike out inapplicable section.) 'ex,
2. Date and manner of service of the complaint: '
Sheriffs service on Defendant on 29 January 2008.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by § 3301(c) of the
Divorce code:
by plaintiff 29 March 2011 ; by defendant 29 March 2011
(b) (1) Date of execution of the affidavit required by § 3301(d) of the Divorce Code:
0
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CT1
Ts
0
.a-
(2) Date of filing and service of the plaintiff's § 3301(d) affidavit upon the
respondent opposing party:
4. Related claims pending:
None
5. Complete either (a) or (b)
(a) Date and manner of service of the notice of intention to file praecipe to transmit
record, a copy of which is attached:
(b) Date plaintiff's Waiver of Notice was filed with the Prothonotary:
29 March 2011 and filed on or about 4 April 2011
Date defendant's Waiver of Notice was filed with the Prothonotary:
29 March 2011 and filed on or about 4 April 2011
Attorney or Plaintiff/Defendant
C:
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x -n
VALERIE S. STACKNICK,
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND. COUNTY, PENNSYLVANIA
MATTHEW R. STACKNICK, NO. 08-265 CIVIL
DIVORCE DECREE
AND NOW, Z y t t J it is ordered and decreed that
VALERIE S. STACKNICK, , plaintiff, and
MATTHEW R. STACKNICK, , defendant, are divorced from the
bonds of matrimony.
Any existing spousal support order shall hereafter be deemed an order for
alimony pendente lite if any economic claims remain pending.
The court retains jurisdiction of any claims raised by the parties to this action
for which a final order has not yet been entered. Those claims are as follows: (If no
claims remain indicate "None.")
None
By the Court,
d s +. Copy mw lad ^o a ,t Amda
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No*e -ttCopy ma.<<ed 4 alti4
ORDERMOTICE TO WITHHOLD INCOME FOR SUPPORT
State: Commonwealth of Pennsylvania
Co./City/Dist. of: CUMBERLAND
Date of Order/Notice: 08/04/11
Case Number (See Addendum for case summary)
Employer/Withholder's Federal EIN Number
CORNERSTONE LAND TRANSFER INC
4705 E TRINDLE RD
MECHANICSBURG PA 17050-3616
194-42-8357
ployee/Obl e Igor s Social Secur-i-ty-ITu-m-FeTr
6405101930
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.
$ 0.00 per month in current child support
$_ 0.00 per month in past-due child support Arrears 12 weeks or greater? Q yes O pct
$ 0.00 per month in current medical support
$ 0.00 per month in past-due medical support
$_ 0.00 per month in current spousal support G rn -
$ 0.00 per month in past-due spousal support -;10_ G-) rP
$ 0.00 per month for genetic test costs
w `tea.
$_ 0.00 per month in other (specify) r - -
$ _ one-time lump sum payment
for a total of $ 0.00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 0.00 per weekly pay period. $ 0.00 per semimonthly pay period
(twice a month)
$ _ 0.00 per biweekly pay period (every two weeks) $ 0.00 per monthly pay period.
REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10)
working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of
withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work
state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of
the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding,
the following information is needed (See #9 on page 2).
Pennsylvania law (23 PA C.S. § 4374(b)) requires remittance by an electronic payment method if an
employer is ordered to withhold income from more than one employee and employs 15 or more persons, or
if an employer has a history of two or more returned checks due to nonsufficient funds. Please call the
Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at
1-877-676-9580 for instructions. PA FIPS CODE 42 000 00
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE ENDANT'S NAME AND THE PACSES MEMBER ID IPF (shown above as the Employee/Obli )r's Cas Id ntifer) /?OC/AL SECURITY NUMBER IN ORDER TO BE
PROCESSED. DO NOT SEND CAS BY MAI . /
BY THE COURT:
J. WeMky Oler, A,
08-265 CIV
O Original Order/Notice
O Amended Order/Notice
(Q Terminate Order/Notice
O One-Time Lump Sum/Notice
RE: STACKNICK, VALERIE S.
Employee/Obligor's Name (Last, First, MI)
OMB No, 0970-0154 Form EN-028
Service Type M Worker ID $IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
If checked you are required to provide a copy of this form to your employee. If your employee works in a state that is
different from the state that issued this order, a copy must be provided to your employee even if the box is not checked.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the
requesting agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment
to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to
each employee/obligor.
3.* Reporting the Paydate/Date of Withholding: You must report the paydate/date of withholding when sending the payment. The
paydate/date of withholding is the date on which amount was withheld from the employee's wages. You must comply with the law of
the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement
the withholding order and forward the support payments.
4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support
against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you
must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the
greatest extent possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for
you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. 2517518210
THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER: Q THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: Q
EMPLOYEE'S/OBLIGOR'S NAME: STACKNICK, VALERIE S.
EMPLOYEE'S CASE IDENTIFIER: 6405101930 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
LAST KNOWN PHONE NUMBER: FINAL PAYMENT AMOUNT:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should
have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from
employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding.
Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she
is employed governs.
9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (CCPA) (15 U.S.C. 1673 (b)); or 2) the amounts allowed by the State or Tribe of the employee's/obligor's principal place
of employment. Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes,
Social Security taxes, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the
obligor is supporting another family and 60% of the disposable income if the obligor is not supporting another family. However, that
50% limit is increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State,
you may deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section.
Arrears greater than 12 weeks: If the Order Information does not indicate whether the arrears are greater than 12 weeks, then the
employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts
allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser
of the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of
the CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amounts paid for
health care premiums in determining disposable income and applying appropriate withholding limits.
10. Additional info:
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the
state that issued this order with respect to these items.
11. Send Termination Notice and
other correspondence to:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
Service Tvne M
If you or your employee/obligor have any questions
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717) 240-6248 or
by internet www.childsupport state pa us
OMB No.. 0970-0154
Form EN-028
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: STACKNICK, VALERIE S.
PACSES Case Number 359109838
Plaintiff Name
MATTHEW R. STACKNICK
Docket Attachment Amount
08-265 CIVIL $ 0.00
Child(ren)'s Name(s):
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
DOB
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
PACKS Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
Addendum Form EN-028
Service Type M OMB No 0970-0154 Worker ID $IATT
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
MATTHEW R. STACKNICK Docket Number: 08-265 CIVIL
vs. Plaintiff PACKS Case Number: 359109838
VALERIE S. STACKNICK
Defendant Other State ID Number:
ORDER
AND NOW, to wit, on this 4TH DAY OF AUGUST, 2011 IT IS HEREBY
ORDERED that the support order in this case be O Vacated or O Suspended or
O Terminated without prejudice or O Terminated and Vacated, effective
APRIL 21, 2011, due to:
THE DIVORCE DECREE OF APRIL 21, 2011.
THE ALIMONY PENDENTE LITE ACCOUNT IS CLOSED WITH A CREDIT BALANCE OF $805.81.
BY THE COURT:
te
r- ? ..
r
J. Welley W, Jr., Judg? '
Service Type M
Form OE-504
Worker ID 21005