The URL can be used to link to this page

Home My WebLink About08-0485r_ sy Pamela L. Purdy Attorney ID No. 85783 308 N. Second Street, Suite 200 Harrisburg, PA 17101 (717) 221-8303 (717) 221-8403 facsimile pipurdy@verizon.net Attorney for Plaintiff BARTON MILLER, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. OB- 496 Civil -erm LORRAINE MILLER, Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you 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 divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. ?` YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 fa"p, ?- P,-,q PAMELA L. PURD ATTORNEY FOR PLAINTIFF A. Pamela L. Purdy Attorney ID No. 85783 308 N. Second St., Suite 200 Harrisburg, PA 17101 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.net Attorney for Plaintiff BARTON MILLER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. D? ?l b S C,. ,J 17,,,, LORRAINE MILLER, Defendant IN DIVORCE COMPLAINT IN DIVORCE COUNTI Divorce Under 3301(c) of the Divorce Code 1. Plaintiff is Barton Miller who currently resides at 2715 High Street, P.O. Box 8, Grantham, Cumberland County, Pennsylvania. 2. Defendant is Lorraine Miller who currently resides at 817 West Keller Street, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on November 19, 1994 at Camp Hill, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The grounds on which the action for divorce is based are: Section 3301(c): The marriage of the parties is irretrievably broken. After 90 days have elapsed from the filing of this Complaint, it is believed the parties will file Affidavits of Consent to a divorce. 8. Plaintiff has been advised of the availability of counseling and that he may have the right to request that the Court require the parties to participate in counseling. Plaintiff hereby waives his right to such counseling. WHEREFORE the Plaintiff requests this Court to enter a decree of divorce under Section 3301(c) of the Divorce Code. COUNT II Equitable Distribution 9. Plaintiff incorporates by reference paragraphs I through 8 of this Complaint. 10. Plaintiff and Defendant have acquired various items of marital property which are subject to equitable distribution by this Court under Sections 3501 and 3502 of the Divorce Code. 1 1. Plaintiff and Defendant have not agreed on an equitable distribution of this property. WHEREFORE, Plaintiff requests the Court to enter an order equitably dividing all of the property. Respectfully submitted, P(2 JW j k 10 _. Pamela L. Purdy Dated: Q^,? 'S, 2601 VERIFICATION I verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Cd` ARTON MILLER Dated: NA6-K 15) ?CDC P -6P- rv, c: > -x tv ?1 C'7 I CS9.) J .1 BARTON MILLER, Plaintiff V. LORRAINE MILLER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-485 CIVIL TERM : IN DIVORCE AFFIDAVIT OF ACCEPTANCE OF SERVICE I hereby accept service of the Divorce Complaint on behalf of Defendant Lorraine Miller and hereby certify that I am authorized to do so. Dated: / ZI Qg Kenneth/F. Lewis, Esquire PA ID # k?g3 1 101 North Front Street Harrisburg, PA 17102 (717) 234-3136 CERTIFICATE OF SERVICE The undersigned hereby certifies that on the J 1 S+- day of January, 2008, a true and correct copy of the foregoing document was served by U.S. Mail, First Class, Postage Prepaid, upon the following: Kenneth F. Lewis PA ID # 69383 1 101 North Front Street Harrisburg, PA 17102 P'j By: Pamela L. Purdy rv d to r ril } :13 i t ::' rn Pamela L. Purdy Attorney ID No. 85783 308 N. Second St., Suite 200 Harrisburg, PA 17101 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.net Attorney for Plaintiff BARTON MILLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. LORRAINE MILLER, Defendant NO. 08-485 CIVIL ACTION - LAW IN DIVORCE MOTION FOR APPOINTMENT OF DIVORCE MASTER Barton Miller, Plaintiff, hereby moves this Honorable Court to appoint a Master with respect to the following claims: () Divorce (x) Distribution of Property O Annulment O Support () Alimony () Counsel Fees () Alimony Pendente Lite () Costs and Expenses and in support of the motion states: (1) Discovery is not complete as to the claim(s) for which the appointment of a master is requested. (2) The Plaintiff has appeared in this matter. (3) The statutory grounds for divorce are 3301(d). (4) It is unknown whether the divorce action is contested. No agreement has been reached as to distribution of marital assets. No further claims are pending as of this date. e f (5) The case does not involve complex issues of law. (6) The hearing is expected to take less than one (1) day. (7) No additional information is relevant to this motion. Date: A?L? fPmOe1jaNLL. Purdy Attorney for Plaintiff -2- 19 CERTIFICATE OF SERVICE The undersigned certifies that on the 3 r? day of November, 2009, a true and correct copy of the foregoing document was served by first-class mail, postage prepaid, upon the following: Kenneth F. Lewis, Esq. 1101 North Front Street Harrisburg, PA 17102 I_a? - Pamela L. Purdy Of Counsel for Plaintiff E THE PPC -TAR`Y 2009 NOV -4 P 12: 51 I L. d, w Pamela L. Purdy, Esquire Attorney I.D. No. 85783 308 N. 2nd St., Ste. 200 PO Box 11544 Harrisburg, PA 17108 (717) 221-8303 tel (717) 221-8403 fax pipurdy@verizon.net Attorney for Plaintiff BARTON MILLER, Plaintiff vs. LORRAINE MILLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA *5 NO. 08-845- CIVIL ACTION - LAW IN DIVORCE INCOME AND EXPENSE STATEMENT OF PLAINTIFF, BARTON MILLER INCOME (a) Wages/Salary Employer & Address Job Title/Description Pay Period (week) Gross Pay per Pay P-i Payroll Deductions: Federal Withholding Social Security Local Wage Tax State Income Tax Retirement Health Insurance Other (specify) SCIM Medicare Net Pay per Pay Period t4r. scw 1?rovi 4 onthl 40 1206-. $ 3?•?9 $ 120-10 $ Z• 3 $ S. $ 3 $ so 7. !r9 $ 21r- Of $ fl 19. 12-- (b) Other Income % Week RtaFewpovo As . CA?/X ...............$ Pension/Annuity ............................... ..$ Social Security ................................. .. $ Rents/Royalties .................................. $ Expense Ac ount ..,4i.. ....$ tom. frtyt...?...$ Unemployment Comp ..................... ... $ Workmen's Compensation ............... ...$ Total, Other Income $ Month Year $ $ $ $ 5bO. ?D $ $ SUb• to Household Child Household Week Week Month EXPENSES Home 00 Mortgage/Rent (bi-weekly) ............... $ $ $ /? ???• $, Maintenance .................................... $ $ $ - $, Utilities (telephone, heating electric, etc.) .................................. $ $ $ ZoO.°' $ Employment (transportation, .00 lunches) ........................................ $ $ $ $. Child Month Taxes .................... Real Estate (annually) !?_°° Personal Property ............................ $ $ $ v. _f $ Income .............................................$ $ $ ! $ Insurance Homeowners .................................... $ $ $ ?• '~ $ Automobile ....................................... $ $ $ $ Life/Accident/Health ......................... $ $ $_? $ Other ................................................ $ $ $ $ Automobile (payments, fuel, repairs)...... $ $ $ s Medical Doctor, Dentist, Orthodontist ............ $ $ $ ZS ?'° $ Hospital ................................... ......... $ $ $ $ Special (glasses, braces, etc.) ......... $ $ $ $ Education Private, Parochial School ........ ......... $ $ $ $ College .................................... ......... $ $ $ $ Personal Clothing ............................................ $. Food ................................................ $ Other (household supplies, barber, etc) .................................... $, Credit payments and loans ............... $ $ $ Z $ $ $ $ $ $ $ Miscellaneous Household help/child care ...................... $ $ $ $ Entertainment (inc. papers, books, vacation, pay TV, etc.) ..... .. $ $ $ $ Gifts/Charitable contributions ......... .. $ $ $ $ Legal Fees (accruing fees now) ..... .. $ $ $ .`.,$ Other child support/alimony payments .................................... .. $ $ $ $ Other (specify) .141150.4 !IA..... ch........ $ Total Expenses ..................................... $ INSURANCE Company $ $ $ Zno. °° Ownership" Coverage Policy No. H W C Hospital .......................... Medical .......................... 9VW S W Health/Accident..... Disability I come............ Other ( er N, etc) .......... (*H - Husband, W - Wife, J - Joint, C - Child) K ?- L x x VERIFICATION I verify that the statements made in this Income and Expense Statement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. laze. Date: ?Y/ 3/ Zmt w • B on Miller CERTIFICATE OF SERVICE The undersigned certifies that on the 3 r?-_ day of November, 2009, a true and correct copy of the foregoing document was served by first-class mail, postage prepaid, upon the following: Kenneth F. Lewis, Esq. 1101 North Front Street Harrisburg, PA 17102 '? 10 - PMJ4- LI-I Lf?? P mela L. Purdy Of Counsel for Plaintiff .,.? ???? ???r;?.x?z? ,? ?? ?E ? .. 2004 ??? ?? ??? 12? ? ? ,, CjV??iS''?1? IZ?VtyjCi `,,a Pamela L. Purdy Attorney ID No. 85783 308 N. Second St., Suite 200 Harrisburg, PA 17101 (717) 221-8303 (717) 221-8403 facsimile pipurdy@verizon.net Attorney for Plaintiff BARTON MILLER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-485 4 LORRAINE MILLER, Defendant CIVIL ACTION - LAW IN DIVORCE INVENTORY OF PLAINTIFF. BARTON MILLER Plaintiff files the following Inventory and Appraisement of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Plaintiff verifies that the statements made in this Inventory and Appraisement are true and correct. Defendant understands that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Ann. § 4904 relating to unsworn falsification to authorities. Date: 1 y on Miller ASSETS OF PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. (X) 1. Real property (X) 2. Motor Vehicles (X) 3. Stocks, bonds, securities and options ( ) 4. Certificates of deposit (X) 5. Checking accounts, cash (X) 6. Savings accounts, money market and savings certificates () 7. Contents of safe deposit boxes () 8. Trusts () 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) (X) 10. Annuities () 11. Gifts () 12. Inheritances () 13. Patents, copyrights, inventions, royalties (X) 14. Personal property outside the home () 15. Businesses (list all owners, including percentage of ownership and officer/director positions held by a party with company) () 16. Employment termination benefits--severance pay, workman's compensation claim/award () 17. Profit sharing plans (X) 18. Pension plans (indicate employee contribution and date plan vests) () 19. Retirement plans, Individual Retirement Accounts () 20. Disability payments () 21. Litigation claims (matured and unmatured) () 22. MilitaryN.A. benefits () 23. Education benefits (X) 24. Debts due, including loans, mortgages held -2- (X) 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute) () 26. Other -3- MARITAL PROPERTY Plaintiff lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced. Item Number Description of Property Names of All Owners 1 Marital Home at 817 W. Keller St. Husband and Wife Mechanicsburg, PA 2 Chevrolet Tahoe Husband and Wife 2 Jeep Husband and Wife 10 Horace Mann Annuity Husband 3 American Funds stocks Husband 3 Janney Montgomery Scott Husband and Wife account 18 Marital portion of Husband's Husband PSERS pension 5 Checking accounts Husband and Wife 6 Savings accounts Husband and Wife 25 Personalty Husband and Wife -4- NON-MARITAL PROPERTY Plaintiff lists all property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property: Item Number Description of Property Reason for Exclusion 18 Nonmarital portion of PSERS Pension Post-separation increase in value -5- PROPERTY TRANSFERRED Plaintiff lists all property in which either or both spouses had a legal or equitable interest individually or with any other person and which has been transferred within the preceding three years: Item Description of Date of Consideration Person to Number Property Transfer Whom Transferred 1 Marital Home 12/30/08 x$84,000 buyer 3 portion of Janney 2008 $1,600 Husband Mont. Scott Acct 3 portion of Janney 2008 $3,400 Wife Mont. Scott acct 5 Cash from HELOC 2008 $9,900 Wife Prior to sale of MH 5 Cash from HELOC 2008 $10,110* Husband Prior to sale of MH 5 Cash from sale of 12/30/08 450,000 Wife Marital home 5 Cash from sale of 12/30/08 $34,000** Husband Marital Home *Was used by Husband to pay off marital debt **Husband received a lesser amount of the net equity from the marital home because approximately $16,000 of the proceeds were used to pay off post-separation debt incurred on the HELOC. -6- LIABILITIES Item Description Number of Property Names of All Creditor Names of All Debtors 24 Line of credit on Marital Home 24 credit card debt Susq. Valley Fed Credit Union First Bankcard Visa Husband and Wife Husband -7 CERTIFICATE OF SERVICE The undersigned certifies that on the day of November, 2009, a true and correct copy of the foregoing document was served by first-class mail, postage prepaid, upon the following: Kenneth F. Lewis, Esq. 1101 North Front Street Harrisburg, PA 17102 L Pamela L. Purdy Of Counsel for Plaintiff FLED- i E '" ""'r.r'wtl s;1 2009 NOY -4 PH 12: 51 NOV 0 5 2009 BARTON MILLER, Plaintiff V. LORRAINE MILLER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 08-485 CIVIL ACTION - LAW IN DIVORCE ORDER 1- AND NOW, this ?L?k Q 2009, _? ??? ?i••.c J / Esquire, is appointed master with respect to the following claims: Equitable Distribution. By th ourt: vo, J Distribution: Pamela L. Purdy, Esquire 308 N. 2nd Street, Suite 200 P.O. Box 11544 Harrisburg, PA 17108 .,Kenneth F. Lewis, Esquire 3301 N. Front Street Harrisburg, PA 17102 Ri.Ct TL 7 2099RO -9 Fit J: 3i BARTON MILLER, Plaintiff V. LORRAINE MILLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-485 Civil Term CIVIL ACTION - LAW DIVORCE NOTICE TO PLEAD TO THE ABOVE-NAMED PLAINTIFF: You are hereby notified to file a written response to the enclosed pleading within twenty (20) days from service hereof or a judgment may be entered against you. DATE: /) 1 0, 1 /, e, M /?, /, 4 KEN ET F. LEWIS, ESQUIRE I.D. # 69383 Attorney for Defendant 1101 N. Front St. Harrisburg, PA 17102 (717) 234-3136 BARTON MILLER, Plaintiff V. LORRAINE MILLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-485 Civil Term CIVIL ACTION - LAW DIVORCE ANSWER & COUNTERCLAIM ANSWER COUNT I Request for a No-fault Divorce Under 63301(c) of the Domestic Relations Code 1. Admitted. 2. Ms. Miller resides at 7 Johns Drive, Enola, PA 17025. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. Admitted. COUNT II Request for Equitable Distribution of Marital Property Under 63502 of the Domestic Relations Code 9. No answer is required. 10. Admitted. 11. Admitted. COUNTERCLAIM COUNT IV - ALIMONY and COUNSEL FEES 12. Defendant hereby incorporates Paragraphs 1 through 11 of her Answer as if fully set forth herein. 13. Defendant lacks sufficient property to provide for her reasonable needs and is unable to fully support himself through appropriate employment upon conclusion of the divorce action. 14. The Plaintiff has more than sufficient property to support himself. 15. Defendant has retained the undersigned counsel to represent her in this matter and does not earn sufficient monies to pay the legal fees in this case. WHEREFORE, Plaintiff respectfully requests this Court to enter an order of alimony, counsel fees, costs and expenses in her favor. DATE : P t hje4 KEN ET F. LEWIS, ESQUIRE Att rn y I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Defendant 11/03/2009 16:21 7172343650 KREVSKY AND ROSEN PC PAGE 04 I hereby verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated: v(qN?Laldy' INE MILL I certify that I have served a true and correct copy of the within document upon attorney for Plaintiff by mailing same, postage prepaid at Harrisburg, PA, on the filing date, at the following address: Pamela L. Purdy, Esq. 308 N. 2nd Street Suite 200 P.O. Box 11544 Harrisburg, PA 17108 DATED: 16, L- KENNE" F. EWIS, ESQUIRE r? r JY t 0-0 Qom( eC,C uZ ) E; q. f S 33 ?? .133YLj KENNETH F. LEWIS, ESQUIRE Attorney I.D. 169383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff 2 1 AN 2 7 r-? BARTON MILLER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-485 Civil Term LORRAINE MILLER, CIVIL ACTION - LAW Defendant DIVORCE INCOME & EXPENSE STATEMENT OF LORRAINE MILLER I verify that the statements made in the foregoing documents are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated: 112-5110 LO INE MILL 17 INCOME Employer: GPI Marketing address: 1000 N. Front St.: Suite 240• Wormleysburg, PA 17043 pay period: bi-weekly gross income per pay period: (varies) 576.54 net income per pay period: (varies) 456.63 NOTE: L. Miller averages working slightly less than 30 hours per week. She gets $10.00 per hour. There is no overtime. The above numbers are based upon her year-to-date total wages of $14,990 gross and $11,872.33 net (for her last paycheck for 2009, which is attached). OTHER INCOME $897/month child support; $203/month spousal support $6,046.64 gross ($5,188.95 net) earned for year coaching softball for Cumberland Valley School District; pay stub showing deductions attached. MONTHLY EXPENSES: those expenses that vary (i.e. electric bill, etc.) are estimated: RESIDENCE Townhouse $804 Electric/PPL $120 UGI $ 35 Comcast: phone/cable/internet $125 cell phone $ 65 Water $ 52 Sewer $ 38 Homeowner's Insurance $ 31 OTHER $ TAXES: escrowed with the mortgage School Taxes $ Real Estate $ Personal Prop Taxes $ AUTOMOBILE: payment $ Insurance $ 56 Fuel $160 Repairs: (tires, oil changes, inspection, etc.) $65 MISCELLANEOUS: Medical/Dental bills Medical Insurance (self only) Special Needs (glasses...) Memberships Papers, publications Vacation/Entertainment Legal Fees Cable TV Food/household items Clothing Xmas, Birthday, Etc. Barber/Hairdresser Charge accounts/credit cards Life ins. Personal Loans Other $ 60 $300* $varies $400 $542 $varies $varies $35 $25* *$650 owed TOTAL MONTHLY NET INCOME TOTAL MONTHLY EXPENSES $2,318.78** $2,913.00 (excluding clothing, gifts, vacation...) *currently under husband's policy; will not have any health insurance upon the divorce being finalized. All quotes for insurance (personal, not family) exceed $300/month. **$989.37 GPI Marketing; $432.41 coaching; $897.00 child support CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of the within document to counsel for Plaintiff by mailing same by U.S. Mail, postage prepaid at Harrisburg, Pennsylvania addressed to: Pamela L. Purdy 308 N. 2nd St. Ste. 200 P.O. Box 11544 Harrisburg, PA 17108 1 Z? ?d Dated: lzh )611,d KENN TH . LEWIS, ESQUIRE O O O p O M M O O M O ,. ? 11(D O O O 3 tD O U) O Q opO O O O ? 0 0 0 0 Q' ^ O O to lC) to N ? 3 h O 3 Z ? co CO N M r N T O co M N 7 Q M V J U ?? :x U ? - Q M N ??}} pp v! OD O Q O ?? O O O Qj Of N 't N N O (O N M O N Ifj aD ^ C m N ch . -- n 3 z vyi ? 3 4 O NN i U) N ? O co d Of fn ? N ? Or C C 7 O Q LL T Z y M C 2 o E m r a co O? J r. W ? M O ? O N = ? N M N O O (? f? N 2 M M M ? O) ? • o a G m c ? a cn E k 2 x ,L 0(D O W ?, Y Y a E O U U in O LL Z a ( a U U O O O O m O O W m m H Q. R E m 0 0 r N .-1 44y t+ 1 ?y N u ? 0 h 0 O ei O W \ 00 .-f C6 Ed W z a N F. C. 0 0 O O O O O O U E+ RI O r ?!S O ? W W O O N t0 O O '-f N W h W C3 rr 'tl? h th ['? co O O w ra O c tO a% ? co q m cr 1o O C. q? m O o q? w c w ac v e w a o w ? o e a ?o v 0 o v o 0 0 .o co ?o 'o ?o w o ? 9G o aQ an R M 0 C?! LO qw fl 4 O Q1 ?D O ?D O W ?O O ?O O m .? O O N m l0 g a m b O o o q 54 O 41 c a O H a a H O 0 A m Q O O D ri y 0 U ca N O O rl O N \ ri N V4 O Ll 2?f JAH 27 Ali 11: 22 v . BARTON MILLER, IN THE COURT OF COMMONf PLEA OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-485 Civil Term LORRAINE MILLER, CIVIL ACTION - LAW Defendant DIVORCE IFUNTORY & APPRAISEMENT STATERENT OF LORRAINE NILLER Plaintiff files the following Inventory & Appraisement of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. I verify the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated: J/Z5//6 L INE MILLERS CERTIFICATE OF BERVICE I certify I have served a true and correct copy of this document to plaintiffs attorney by mailing same by U.S. Mail, postage prepaid at Harrisburg, PA, addressed to Pamela L. Purdy, 308 N. 2nd St., Ste. 200; P.O. Box 11544, Harrisburg, PA 17108 DATED: ' LSl1O KENN H LEWIS, ESQUIRE 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Defendant I.D. 169383 IMVMORY OF ASSETS OF PARTIES (X) 1. Real property (X) 2. Motor vehicles (X) 3. Stocks, bonds, securities and options ( ) 4. Certificates of deposit (X) 5. Checking accounts, cash (X) 6. Savings accounts, money market and savings certificates ( ) 7. Contents of safe deposit boxes ( ) 8. Trusts ( ) 9. Life insurance policies (indicate face value cash surrender value and current beneficiaries) (X) 10. Annuities ( ) 11. Gifts ( ) 12. Inheritances ( ) 13. Patents, copyrights, inventions, royalties ( ) 14. Personal property outside the home (X) 15. Business (list all owners, including percentage of ownership, and officer/director positions held by a party with company) ( ) 16. Employment termination benefits--severance pay, worker's compensation claim/award ( ) 17. Profit sharing plans (X) 18. Pension plans (indicate employee contribution and date plan vests) ( ) 19. Retirement plans, Individual Retirement Accounts ( ) 20. Disability payments ( ) 21. Litigation claims (matured and unmatured) ( ) 22. Military/V.A. benefits ( ) 23. Education benefits (X) 24. Debts due, including loans, mortgages held (X) 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute) 26. Other MARITAL PROPERTY Item Number Description of Property Owners 1. Marital home: 817 W. Keller H&W Mechanicsburg, PA (NOTE: SOLD) 2. Chevy Taho (03) H&W 2. Jeep (94) H&W 3. American Funds stocks H 3. Janney Montgomery Scott account H&W 5. checking accounts H&W 6. savings accounts H&W 10. Horace Mann Annuity H 15. Miller Outdoor (landscaping H business) 18. Husband's PSERS pension H 25• Personalty H&W NON-MARITAL PROPERTY Description of Pro erty Owners Basis for Exclusion Wife has a retirement plan through her employer that began after date the parties separated (8/12/07 date of separation). Husband is claiming that any post-separation increase in value in his PSERS plan is non-marital. Wife disputes that assertion. MARITAL LIAHILITIEB Item Number Description Creditors Debtors of Property 24• Line of credit Susq. Valley H&W (re: marital home) Fed. Cred. Union [PAID OFF) PROPERTY TRANBF ED Description Date of to Whom of Property Transfer Consideration Transferred Cash from 12/30/08 $50,000 Wife sale of marital home Cash from 12/30/08 $34,000 Husband* sale of marital home portion of 2008 $1,600 Husband Janney Mont. Scott acct. portion of 2008 $3,400 Wife Janney Mont. Scott acct. cash from HELOC 2008 $9,900 Wife prior to sale of marital home cash from HELOC 2008 $10,110 Husband prior to sale of marital home *As Husband's Inventory reflects, he received $16,000.00 less than wife as approximately $16,000.00 of the proceeds of the sale were used to pay off husband's post-separation debt (he borrowed monies from the home equity line of credit). Pamela L. Purdy Pa. ID No. 85783 308 N. 2nd St., Suite 200 Harrisburg, PA 17101 Tel: 717-221-8303 Fax: 717-221-8403 pipurdy@verizon.net 2010 MAY -3 PN 4: 01 . Iti!TY Attorney for Plaintiff BARTON MILLER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA V. : NO. 08-485 LORRAINE MILLER, Defendant TO THE COURT: IN DIVORCE PRAECIPE TO WITHDRAW ECONOMIC CLAIMS Please withdraw Count II for Equitable Distribution in the Divorce Complaint in the above-captioned matter. Date: Ls 3(0 i 4 Vk iPamela L. Purdy FILED-- ;ri'-E ?r THE F,: fE -11, _ F . R Y 2010 nAY -3 Pf; 4: U 1 Cum, Kenneth F. Lewis, Esq. Attorney I.D. No. 69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Defendant BARTON MILLER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA V. NO. 08-485 LORRAINE MILLER, Defendant TO THE COURT: IN DIVORCE PRAECIPE TO WITHDRAW ECONOMIC CLAIMS Please withdraw Count IV- Alimony and Counsel Fees in the Answer and Counterclaim in the above-captioned matter. /A . C Kenn th V. Lewis, Esquire Date: /" Zlo UJd J. r" FLL(?;? ; i r ., ZOEO E`t' -3 Pc? I' 0 E Pamela L. Purdy Attorney ID No. 85783 308 N. 2nd St., Ste. 200 PO Box 11544 Harrisburg, PA 17108-1166 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.com Attorney for Plaintiff BARTON MILLER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-485 LORRAINE MILLER, CIVIL ACTION - LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 22, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. J. 'it- 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. § 4904 relating to unsworn falsification to authorities. t EtAKTON MILLER Dated: ?7,Z 2,d -2- FILED 20101,iA1 -3 P ?: U 1 Pamela L. Purdy Attorney ID No. 85783 308 N. 2"d St., Ste. 200 PO Box 11544 Harrisburg, PA 17108-1166 (717) 221-8303 (717) 221-8403 facsimile pipurdy@verizon.com Attorney for Plaintiff BARTON MILLER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-485 CIVIL TERM LORRAINE MILLER, CIVIL ACTION - LAW Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER $3301(c) OF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authoritie rton Miller Dated: L 010 -2- FI?EJ-???=i=i;?F "F 71J:7 2010 HAY -3 P11 It: O! BARTON MILLER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-485 LORRAINE MILLER, CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 22, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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. § 4904 relating to unsworn falsification to authorities. Dated: (? N MILLS FILE' -1;;-? r 2910 MAY -3 Pr 1,. 01 C!J; ?I IT BARTON MILLER, Plaintiff V. LORRAINE MILLER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-485 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER $3301(c) OF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Dated: si ne Miller (? i i 111 r'. -.?- Tt_{ i 'y 2010 HAY -4 AM 9: 01 Pamela L. Purdy 308 N. 2"d Street, Suite 200 Harrisburg, PA 17101 (717) 221-8303 tel (717) 221-8403 fax plpurdy@verizon.net Attorney for Plaintiff BARTON MILLER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA V. LORRAINE MILLER, Defendant : NO. 08-485 IN DIVORCE MOTION TO WITHDRAW APPOINTMENT OF MASTER AND NOW, this rtk _ day of April, 2010, comes Plaintiff Barton Miller, by and through his attorney, Pamela L. Purdy, and files this Motion to Withdraw Appointment of Master, and in support thereof, avers as follows: 1. Plaintiff Barton Miller is an adult individual who currently resides at 2619 Shingus Circle, Grantham, Cumberland County, Pennsylvania. 2. Defendant Lorraine Miller is an adult individual who currently resides at 7 Johns Drive, Enola, Cumberland County, Pennsylvania. 3. On January 22, 2008, Plaintiff filed a Complaint in Divorce, which included request for equitable distribution. 4. On November 4, 2009, Plaintiff filed a Motion for Appointment of a Master. 5. On November 9, 2009, this Court entered an order appointing E. Robert, Elicker, II, Esquire as Divorce Master in this matter. 6. On November 13, 2009, Defendant filed an Answer and Counterclaim to the Complaint in Divorce, including a request for alimony and counsel fees. 6. On April 20, 2010, the parties entered into a comprehensive Marital Settlement Agreement that resolved all of the outstanding economic issues between the parties. 7. The parties are no longer in need of assistance from this Court in resolving their marital issues. 8. Defendant concurs in this motion. 9. The Honorable Edgar B. Bayley was previously assigned to this matter. WHEREFORE, Plaintiff respectfully requests that this Court withdraw the appointment of E. Robert Elicker, II, Esquire as Divorce Master in this matter. Respectfully submitted, p '- mela L. Purd Y d-N Counsel for Plaintiff Date: -2- CERTIFICATE OF SERVICE The undersigned certifies that on this 30' day of April, a true and correct copy of the foregoing Motion to Withdraw Appointment of Divorce Master was served by first-class mail, postage prepaid, upon the following: E. Robert Elicker, Il, Esquire 13 N. Hanover Street Carlisle, PA 17013 Kenneth F. Lewis, Esquire 1101 North Front Street Harrisburg, PA 17102 Pamela L. Purdy I/ 4 11_??r?_q iivL 77 THE 2010 MIAY -6 All c. 07 BARTON MILLER, Plaintiff V. LORRAINE MILLER, Defendant MAY 0 5 2010 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 08-485 CIVIL ACTION - LAW IN DIVORCE ORDER Y AND NOW, this S"day of Mew, , 2010, upon review of Plaintiffs Motion to Withdraw Appointment of Master, said Motion is GRANTED. The appointment of E. Robert Elicker, II, Esquire as Divorce Master in the above-captioned matter is hereby withdrawn. By the Court: Distribution: ? Kenneth F. Lewis, Esquire 1101 North Front Street Harrisburg, PA 17102 ?mela L. Purdy, Esquire 308 N. 2"d Street, Suite 200 Harrisburg, PA 17101 nn _ ?-.O'? ? E,S rn?, t J . . r T;-„ Pamela L. Purdy, Esquire Attorney I.D. No. 85783 308 N. 2nd St., Ste. 200 PO Box 11544 Harrisburg, PA 17108 (717) 221-8303 tel (717) 221-8403 fax pipurdy@verizon.net Attorney for Plaintiff BARTON MILLER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. : NO. 08-485 LORRAINE MILLER, IN DIVORCE Defendant PRAECIPE TO TRANSMIT RECORD To The Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and manner of service of Complaint: accepted by Defendant's attorney. Acceptance of Service filed of record on February 4, 2008. - 4 3. Date of execution of Affidavit of Consent required by §3301(c) of the Divorce Code: By the Plaintiff: April 12, 2010 By the Defendant: April 20, 2010 4. Related claims pending: Plaintiff and Defendant each filed a Praecipe to Withdraw Economic Claims contemporaneously with this Praecipe. 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: contemporaneously with this Praecipe. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: contemporaneously with this Praecipe. Date: (D By: - Z? Zo Pamela L. Purdy Counsel for Plaintiff -2- IN THE COURT OF COMMON PLEAS OF Barton Miller CUMBERLAND COUNTY, PENNSYLVANIA V. Lorraine Miller NO. 08-485 DIVORCE DECREE AND NOW, oi* ?l -2,o c , it is ordered and decreed that Barton Miller , plaintiff, and Lorraine Miller , 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, COP* 5. f I. to A jatic-CL. rna? ?ec? 40 P? ?... ...s FIM-O ICE JAN 0 7 2011 C1.`i'??:,C.Fti?. A lip Gf '<_ COURT OF COMMON PLEAS OF'AlkD COUNTY, PENNSYLVANIA Barton Miller Plaintiff CIVIL ACTION - LAW VS. Lorraine Miller Defendant NO. 08-485 IN DIVORCE STIPULATION FOR THE ENTRY OF "DOMESTIC RELATIONS ORDER" AND NOW, this f(? day of AIJA,flj the parties, Barton Miller, Plaintiff and Lorraine Miller, Defendant, do hereby Agree and Stipulate as follows: 1. The Plaintiff, Barton Miller (hereinafter referred to as "Member") is a member of the Commonwealth of Pennsylvania, Public School Employees' Retirement System (hereinafter referred to as "PSERS"). 2. PSERS, as a creature of statue, is controlled by the Public School Employees' Retirement Code, 24 Pa. C.S. §§8101-et. Seq. ("Retirement Code"). 3. Member's date of birth and Social Security number are contained in the attached Addendum. 4. The Defendant, Lorraine Miller (hereinafter referred to as "Alternate Payee") is the former spouse of Member. Alternate Payee's date of birth and Social Security number are contained in the attached Addendum. 5. Member's last known mailing address is: P.O. Box 8 2619 Shingus Circle Grantham, PA 17027 DRO Page 2 6. Alternate Payee's current mailing address is: 7 Johns Drive Enola, PA 17025 It is the responsibility of Alternate Payee to keep a current mailing address on file with PSERS at all times. 7. The Member and the Alternate Payee agree that the Alternate Payee's equitable distribution portion of the Member's retirement benefits is $22,267.00 increased with interest at the statutory rate (currently 4% per annum) compounded annually from August 11, 2007, until the first to occur of (a) the date of commencement of a disability retirement benefit to the Member or (b) the date of death of the Member or (c) the date of commencement of a retirement benefit (other than a disability retirement benefit) to the Member. 8. Member's retirement benefit is defined as all monies paid to or on behalf of Member by PSERS, including any lump sum withdrawals or scheduled or ad hoc increase, but not including the disability portion of any disability annuities paid to Member by PSERS as a result of a disability which occurs before the Member's marriage to Alternate Payee or after the date of the Member and Alternate Payee's final separation. The equitable distribution portion of the Member's retirement benefit, as set forth in Paragraph 7, shall be payable to Alternate Payee and shall commence as soon as administratively feasible on or about the date the Member actually enters pay status and PSERS approves a Domestic Relations Order incorporating this Stipulation and Agreement, whichever is later. 9. Member hereby nominates Alternate Payee as an irrevocable beneficiary to the extent of Alternate Payee's equitable distribution portion of Member's retirement benefit for any death benefits payable by PSERS. This nomination shall become effective upon approval by the Secretary of the Retirement Board, or his authorized representative, of any Domestic Relations Order incorporating this Stipulation and Agreement. The balance of any death benefit remaining after the allocation of Alternate Payee's equitable distribution portion ("Balance") shall be paid to the beneficiaries named by Member on the last Nomination of Beneficiaries Form filed with the Retirement Board prior to Member's death. DRO Page 3 (a) If the last Nomination of Beneficiaries Form filed by Member prior to Member's death (a) predates any approved Domestic Relations Order incorporating this Stipulation and Agreement, and (b) names Alternate Payee as a beneficiary, then: (1) the terms of the Domestic Relations Order shall alone govern Alternate Payee's share of any death benefit, and (2) for purposes of paying the Balance via the last Nomination of Beneficiaries Form filed with the Retirement Board prior to Member's death, Alternate Payee shall be treated as if Alternate Payee predeceased Member. No portion of the Balance shall be payable to Alternate Payee's estate. (b) In addition, Member shall execute and deliver to Alternate Payee an authorization, in a form acceptable to PSERS, which will authorize PSERS to release to Alternate Payee all relevant information concerning Member's retirement account. Alternate Payee shall deliver the authorization to PSERS which will allow the Alternate Payee to check that she has been and continues to be properly nominated under this paragraph. 10. The term and amounts of Member's retirement benefits payable to Alternate Payee after PSERS approves a Domestic Relations Order incorporating this Stipulation and Agreement depends upon which options Member selects upon retirement. Member and Alternate Payee expressly agree that at the time Member files an Application for Retirement with PSERS: (a) Member shall elect to take a lump sum withdrawal of his accumulated deductions of at least the amount of the Alternate Payee's equitable distribution share, as set forth in Paragraph 7. Alternate Payee's equitable distribution portion, as set forth in Paragraph 7, shall be payable from that withdrawal. (b) In addition, Member may select any PSERS, retirement option for his monthly annuity. 11. Alternate Payee may not exercise any right, privilege or option offered by PSERS. PSERS shall issue individual tax forms to Member and Alternate Payee for amounts paid to each. 12. The Member and Alternate Payee agree that if the Member becomes disabled, the Member shall file an application for disability retirement and he shall elect the maximum DRO Page 4 disability option. The Alternate Payee's share of the Member's disability retirement benefits shall be paid to the Alternate Payee, by deducting $X from only the early retirement portion of the Member's monthly disability retirement benefit and paying this amount to the Alternate Payee until and only until the Alternate Payee's share, as set forth in Paragraph 7, has been fully paid. X is defined as the early retirement portion of the Member's monthly disability retirement benefit, multiplied by 50%, and further multiplied by a fraction, the numerator of which is 9.33 and the denominator of which is the total years of credited service earned by Member on the date of his disability retirement. If the Member dies while receiving a disability retirement benefit from PSERS, any death benefit payable by PSERS shall be paid to the Alternate Payee to the extent, if any, that her equitable distribution portion of the Member's retirement benefit, as set forth in Paragraph 7, exceeds the total of the monthly payments she previously received. 13. In the event of the death of Alternate Payee prior to receipt of all of her payments payable to her from PSERS under this Order, any death benefit or retirement benefit payable to Alternate Payee by PSERS shall be paid to the Alternate Payee's estate to the extent of the Alternate Payee's equitable distribution portion of Member's retirement benefit. 14. In no event shall Alternate Payee have greater benefits or rights other than those which are available to Member. Alternate Payee is not entitled to any benefit not otherwise provided by PSERS. The Alternate Payee is only entitled to the specific benefits offered by PSERS as provided in this Order. All other rights, privileges and options offered by PSERS not granted to Alternate Payee by this Order are preserved for Member. Member and Alternate Payee acknowledge that benefits paid pursuant to this Stipulation and Agreement are and shall remain subject to the Public Employee Pension Forfeiture Act, 43 P.S. §1311, et seq. 15. It is specifically intended and agreed by the parties hereto that this Order: (a) Does not require PSERS to provide any type or form of benefit, or any option not otherwise provided under the Retirement Code; (b) Does not require PSERS to provide increased benefits (determined on the basis of actuarial value) unless increased benefits are paid to Member based upon cost of living or increases based on other than actuarial values. I)RO Page 5 16. The parties intend and agree that the terms of this Stipulation and Agreement shall be approved, adopted and entered as a Domestic Relations Order. 17. The Court of Common Pleas of Cumberland County, Pennsylvania, shall retain jurisdiction to amend any Domestic Relations Order incorporating this Stipulation and Agreement, but only for the purpose of establishing it or maintaining it as a Domestic Relations Order; provided, however, that no such amendment shall require PSERS to provide any type or form of benefit, or any option not otherwise provided by PSERS, and further provided that no such amendment or right of the Court to so amend will invalidate this existing Order. 18. Upon entry as a Domestic Relations Order, a certified copy of the Domestic Relations Order and this Stipulation and Agreement and any attendant documents shall be served upon PSERS immediately. The Domestic Relations Order shall take effect immediately upon PSERS approval and PSERS approval of any attendant documents and then shall remain in effect until further Order of the Court. WHEREFORE, the parties, intending to be legally bound by the terms of this Stipulation and Agreement, do hereunto place their hands and seals. Lj -'41' , Plaintiff/Member V Attorney for Plaintiff/Memberx ?4 6 ' [b e antlAlternat ayee V /'M OLI Witn ss f Defendant/Alternate Payee ADDENDUM TO DOMESTIC RELATIONS ORDER For Submission to Public School Employees' Retirement System Onlv Due to the Federal Privacy Act, many state courts prohibit the inclusion of personal data in public records to prevent identity theft. Therefore, please forward the following information sheet to Public School Employees' Retirement System when submitting the court certified copy of the Domestic Relations Order. Do NOT file the Addendum with the court. Participant Information Alternate Payee Information Name: Barton Miller Name: Lorraine Miller Address: P.O. Box 8, 2619 Shingus Circle Address: 7 Johns Drive Grantham, PA 17027 Enola, PA 17025 SSN: 162-52-1541 SSN: 164-56-4273 Date of Birth: April 22, 1967 Date of Birth: May 10, 1968 Participant Attorney's Information Alternate Payee Attorney's Information Name: Pamela L. Purdy, Esq. Name: Kenneth F. Lewis, Esq. Address: 308 N. Second St., Suite 200 Address: 1101 N. Front Street P.O. Box 11544 Harrisburg, PA 17102-3318 Harrisburg, PA 17108 Phone Number: (717) 221-8303 Phone Number: (717) 234-3136 The court certified copy of the Domestic Relations Order and this Addendum should be sent to: Public School Employees' Retirement System P.O. Box 125 Harrisburg, PA 17108-0125