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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 c-rj Q V,S < ? 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 r 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: - M hew R. St c 7 G' "b C' C'+ cr?? N W c Kk O ? O c P , .? r GT1 ' r'Y 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 rv 0 are ordered to appear at DOMESTIC RELATIONS HEARING RM s -*z M r, t i 1 ; C:?7 ? DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-i-3• `t before a hearing officer of the Domestic Relations Section, on the -71 .. CO JCr1 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 - ... .? . 7V ?! i t 1 C\S :.e7 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 ?? ? t ? ?'_ ??? ?-? ° r,? ;3 r ? f :. -1,i `jT Cr,> ;T? • i '. .v? c?? ? r V 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 ? ?? ?x . ,c ?:; _ 2 ? ? ? ?.;? ? t? ? --? r t 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 °m r . { n 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" r? ? i::. ?, r, g ='J '-- ...?, .? ri-r `--?' ? T?,. C.,:i -?t'w . t . ` - _ ..:, .:. , ... ..a.,} ?:,, _ . .? ? °? 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 ?y rT, ?c; 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 12•- 52•s 164.62* 804= x 12. + 6 • ov, 2 369.23* 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 ry ^? s ?7 -,? ? ? ---1 ; ?_. . F ..s ? 514 ? ,,. .._, ??4i _. ('? ?; ., __., ,..... _ ?; °? ?w ._..,? :1? "+.u _.,C 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 fryer. ? ?q ?J Y 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 cc361 C _ co ? ? C? ' '•T - r lo 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 0 G co i _. - Ml itL W `-4 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 t? C. ?.. cry ? `? `,? _l t'3 '3 V..?... j'-'f' ,Cg ?"'- 1 1V ?:/ • -V4 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 f' P-4 --n ? m CL _ 4. '14, 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 ? ?' ? ?? ? ?„ ?° --? `? ?.° ? cfs ?' ! ;' gy n . . p ?v }-;? ? '° _ --? -..t 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. il\? 0ti O w ?.; Y S 2cc-?P> 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 $344.24 Prepared b : mrr Date: 11/ 4/2008 SupportCalc 2008 EXHIBIT "B" ?- 7 .. °';"_ E? "i VALERIE S. STACKNICK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : DOMESTIC RELATIONS SECTION MATTHEW R. STACKNICK, PACSES NO. 359109838 Defendant DOCKET NO. 08-265 CIVIL INDEX OF EXHIBITS Plaintiff's Exhibit No. 1 - Earnings statement Plaintiff's Exhibit No. 2 - 2008 deposits into Cornerstone Land Transfer operating account Plaintiff's Exhibit No. 3 - 2007 tax return for Cornerstone Land Transfer Plaintiff's Exhibit No. 4 - 2008 deposits into other operating accounts Plaintiff's Exhibit No. 5 - Interest income from Smith Barney third quarter 2008 Plaintiff's Exhibit No. 6 - Income and expense statement Defendant's Exhibit No. I - Income and expense statement Defendant's Exhibit No. 2 - Counsel fees THEFACE OF THIS DOCUMENT CONTAUVS MICROPRINTMG THE.BACKGHOVND COLOR GRANGES GRADUALLY AND EVENLY FROM DARKEN TO LIGHTER WITH THE DARKEN AHtA AI 1 HE I LW r rkNn:vn >AOn'E4oG >nNf,'fdr,w CdRNEf ? l Np T tAN FE i, ; NC622 L 1Q8/ GENERAL AG4? T 10/24/2008F3985500658( 60 -, 4705, BEAST. INDLf 'Rd 433 MECHGSBURC PA, 155' DATE. -- _ cKNO 70 PAY TO THE VALERIE STACKNICK VOID AFTER 180 days ORDER OF 624 HERITAGE COURT **V01 D** 7 MECHANICSBURG PA 17050 AMOUNT k t .c i **VOID****THIS IS NOT A CHECK****VOID****THIS IS NOT A CHECK** ` PNC-$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 Ft ? *P 1 6 VALERIE STACKNICK EE S IRA 7 0 0- 84 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 -v 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: ? rn 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 ? , 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