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HomeMy WebLinkAbout08-1310A. MICHELE PARKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. PATRICK PARKER, Defendant NO. 2008 - 131 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 inidignities 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, Carlisle, Pennsylvania 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, 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 SERVIES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 c MICHELE PARKER, Plaintiff V. PATRICK PARKER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008 - 3 16 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE COUNT 1- DIVORCE 1. Plaintiff is Michele Parker, an adult individual who currently resides at 313A Means Hollow Road, Shippensburg, Cumberland County, Pennsylvania 17257. 2. Defendant is Patrick Parker, an adult individual who currently resides at 247 V 2E. Garfield St., Shippensburg, Cumberland County, Pennsylvania 17257. 3. Both Plaintiff and Defendant have been bona fide residents of this Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on August 23, 1991 in Martinsburg, West Virginia. 5. There have been no prior actions of divorce or for annulment between the Parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the Parties to participate in counseling. 8. Neither Plaintiff nor Defendant is a member of the Armed Forces of the United States or any of its allies. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree of divorce in favor of Plaintiff and against Defendant. .,.. COUNT II - EQUITABLE DISTRIBUTION 9. Plaintiff hereby incorporates by reference paragraphs one (1) through eight (8). 10. During the course of the Parties' marriage, Plaintiff and Defendant have acquired many items of property - real, personal, or otherwise - which is marital property. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree that effects an equitable distribution of the Parties' marital property. Respectfully submitted, O'BRIEN, BARIC & SCHERER Robert J. Daile , squire I.D. 203418 19 West South Street Carlisle, Pennsylvania 17013 Phone: (717) 249-6873 Attorney for Plaintiff -.? MICHELE PARKER, Plaintiff V. PATRICK PARKER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008 - 3 jU CIVIL TERM CIVIL ACTION -LAW IN DIVORCE VERIFICATION I, Michele Parker, verify that the statements made in the foregoing Complaint in Divorce 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. § 4904 relating to unsworn falsifications to authorities. Q Michele Parker Plaintiff Date: This Q_ day of February, 2008 ca \ a CIS Q -14 a r-A P n a MICHELE PARKER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2008-1310 PATRICK PARKER : CIVIL ACTION - LAW Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I, Marylou Matas, accepted service of the Complaint in Divorce on behalf of Defendant on March 13, 2008 in the above-captioned matter and state that I am authorized to do so. Date Marylo atas SAIDIS, F -OVVER & LENDS" 26 West High Street Carlisle, PA Zx r _ _ /)rrL ( i It 4 MICHELE PARKER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2008 -1310 CIVIL TERM PATRICK PARKER, CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT OF SERVICE I hereby certify that on March 11, 2008, the United States Postal Service served upon the Date: March 17, 2008 Auvern .r. liaiiey, -squire O'Brien, Baric & S*rer 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 defendant, Patrick Parker, the Divorce Complaint by Certified Mail as indicated by the Certified Mail Domestic Return Receipt attached hereto as "Exhibit A:" Attorney for Plaintiff I* 1 ¦ Complete items 1, 2, and 3. Also complete i item 4 if cted Delivery Is desired. ¦ Pant and address on the reverse ?, that return the card to you. ¦ Attach Card to the back of the mailpiece, or on if space permits. 1. Article Addressed to 04 ya ifs G {, e1 d A. Sgnature i--') r, A-f B. Re(cblved by( Pdo ) I C. ba ry ?t.q I yel?e D. Is delivery address different from item 1? ? Yes If YES, enter delivery address below: ? No 3. Service Type ,XCertmed Mail ? Express Mail ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. _ 4. Restricted Delivery? Pft Fee) Yes 2. Article Number 7006 2760 0002 7405 4138 +( nmier from service label) PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 Exhibit "A" ?.. G w ct n f7l ? J' ..?-i Ln ..... MICHELE PARKER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2008-1310 PATRICK PARKER : CIVIL ACTION - LAW Defendant : IN DIVORCE NOTICE TO: Michele Parker Go Robert J. Dailey, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 YOU ARE HEREBY NOTIFIED to plead to the within Counterclaim within twenty days after service of this Answer and New Matter. Respectfully submitted, SAIDIS, FLOWRR & LINDSAY Marylou-Mla s, EsquI( Attorn , Id. 8 919 26 We Street Carlisle, PA 17013 (717) 243-6222 Counsel for Defendant FLOWER & LUM13SM AIIORN WAX-uw 26 West High Street Carlisle, PA MICHELE PARKER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2008-1310 PATRICK PARKER : CIVIL ACTION - LAW Defendant : IN DIVORCE ANSWER AND COUNTERCLAIM TO PLAINTIFF'S COMPLAINT IN DIVORCE COUNT I - DIVORCE 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Defendant is without specific information or knowledge to form a belief as to the truth of this allegation. 8. Admitted. WHEREFORE, Defendant requests your Honorable Court to enter a Decree in Divorce. COUNT II - EQUITABLE DISTRIBUTION SAMIS, FLOWER & LENDS" 26 West High Street Carlisle, PA 9. Admitted. 10. Admitted. WHEREFORE, Defendant requests your Honorable Court to equitably divide the marital property. COUNTERCLAIM FOR SUPPORT ALIMONY PENDENTE LITE AND ALIMONY 11. The averments in paragraph 1 through 10 are incorporated hereto as if fully set forth herein. 12. Defendant is unable to provide for his reasonable needs and the standard of living established during the marriage. WHEREFORE, Defendant requests an Order of support, alimony and alimony pendente lite. COUNT III - INDIGNITIES 13. The averments in paragraphs 1 through 12 are incorporated hereto as if set forth fully herein. 14. Defendant is the innocent and injured party and Plaintiff has offered such indignities to the person of the Defendant so as to make his life burdensome, his condition intolerable in violation of the marriage vows and of the laws of the Commonwealth. WHEREFORE, Defendant requests this Court to enter a Decree in Divorce in accordance of the Pennsylvania Divorce Code. COUNT IV - ATTORNEY'S FEES AND COSTS 15. The averments in paragraphs 1 through 14 are incorporated hereto as if fully set forth herein. 15. Defendant is unable to sustain himself during the course of this litigation or to pay the necessary and reasonable attorney's fees and reasonable costs and expenses. WHEREFORE, Defendant requests an award of counsel's fees and expenses. SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA SAIDIS_ FLOWER & LINDSAY AttordWd. 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Defendant VERIFICATION CIS & LINDSAY ATFOOMAT-LAW 26 West High Street Carlisle, PA I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. i I §4904, relating to unsworn falsifications to authorities. i .- I Patrick Parker n CERTIFICATE OF SERVICE On this lQ-tX day of J441t , 2008, Marylou Matas, Esquire, of the law firm of SAIDIS, FLOWER & LINDSA , hereby certify that on this date a copy of the attached document was served on the following individual, via first class mail, postage prepaid, addressed as follows: Robert J. Dailey, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 SAIDIS, FLOWER & LINDSAY (rl7q} Marylou tad, Esqui / ' Supre a ourt ID No. 919 26 West High Street Carlisle, PA 17013 717-243-6222 FLOWER & LEVDSAY AMRNENS-AMAW 26 West High Street Carlisle, PA W Q 4 a 4 w G 3 rT7 :"`+ ? r r ` CJ Ly MICHELE PARKER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2008-1310 PATRICK PARKER : CIVIL ACTION - LAW Defendant : IN DIVORCE PETITION TO SCHEDULE ALIMONY PENDENTE LITE CONFERENCE 1. Petitioner is Patrick Parker, Defendant in the above captioned divorce matter. 2. Respondent is Michele Parker, Plaintiff in the above captioned divorce SAMIS, LEVDSAY ATIOWEVW IAw 26 West High Street Carlisle, PA matter. 3. Respondent filed a Complaint in Divorce on February 27, 2008. 4. Petitioner filed an Answer and Counterclaim onhiqtA 19, D , raising claims for support, alimony, alimony pendente lite, counsel fees, costs, expenses and indignities. 5. Petitioner does not have sufficient income or other means by which to support himself or to make payment for his expenses. 6. Respondent has the income and means by which to contribute to Petitioner's expenses. 7. Petitioner requests a conference be scheduled at the Domestic Relations Office to address his claim for alimony pendente lite. WHEREFORE, Petitioner requests your Honorable Court to forward this matter to Domestic Relations for the scheduling of a conference. Respectfully submitted, SAIDIS-ELOWER & LINDSAY Attorne 'Ix919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Defendant FLOWER & LEVDS" 26 West High Street Carlisle, PA VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. L?' ;;? PtrickParker Date: T118p2 SAIDIS, FLOWER & IAVDSAY ATIOMEMM-tAW 26 West High Street Carlisle, PA CERTIFICATE OF SERVICE On this f Qt, day of Au at , 2008, Marylou Matas, Esquire, of the law firm of SAIDIS, FLOWER & LINDSAY, hereby certify that on this date a copy of the attached document was served on the following individual, via first class mail, postage prepaid, addressed as follows: Robert J. Dailey, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 SAIDIS, FLOWER & LINDSAY Marylou Mks, squir Supreme,'Cou ID No. 19 26 West ' Street Carlisle, PA 17013 717-243-6222 FLOWER ? LINDSAY 26 West High Street Carlisle, PA DRS ATTACHMENT FOR APL PROCEEDINGS PETITIONER: PATRICK PARKER DOB: MAY 17, 1965 SSN: 590-07-0240 ADDRESS: 48 EAST KINGS ST., APT. 3, SHIPPENSBURG, PA 17257 PHONE: 717-360-6923 (cell) ATTORNEY: MARYLOU MATAS, ESQUIRE PETITIONER'S EMPLOYMENT: DISABLED GROSS PAY: $850.00 DISABILITY INCOME NET PAY: $798.00 DISABILITY INCOME OTHER INCOME: NONE RESPONDENT: MICHELE PARKER DOB: DECEMBER 13, 1971 SSN: 235-13-9532 ADDRESS: 313-A MEANS HOLLOW ROAD, SHIPPENSBURG, PA 17257 PHONE: 717-530-1198 (home) ATTORNEY: ROBERT DAILEY, ESQUIRE RESPONDENT'S EMPLOYMENT: CONSULATE HEALTH CARE HOW LONG? APPROXIMATELY 2002 SAIDIS, FLOWER & UNDSM ATIONIMS-AT-LAW 26 West High Street Carlisle, PA GROSS PAY: $85,000.00 PER YEAR JOB TITLE: REGIONAL VICE PRESIDENT OF ADMISSIONS OTHER INCOME: NONE WHEN MARRIED: AUGUST 23, 1991 WHERE: MARTINSBURG, BERKLEY COUNTY, WV DATE SEPARATED: DECEMBER 29, 2007 WHERE LAST LIVED TOGETHER: 313-A MEANS HOLLOW ROAD, SHIPPENSBURG, PA 17257 DESCRIPTION OF DOCUMENT RAISING APL CLAIM: ANSWER AND COUNTERCLAIM TO DIVORCE COMPLAINT DATE APL FILE: FOR DRS INFORMATION ONLY SAIDIS, FLOWER & LENDSAY A'CICIWAM-A[ <AW 26 West High Street Carlisle, PA ? `' <,; :> - ?,, rr t? `? -_ -? ,: 7 -r, k r = r - ° 7° -? i ?,? ?._.i C:.: -? {?- MICHELE PARKER, THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 08-1310 CIVIL TERM PATRICK PARKER, IN DIVORCE Defendant/Petitioner : ORDER OF COURT AND NOW, this 20th day of August, 2008, upon consideration of the Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R. J. Shadday on August 27, 2008 at 1:30 P.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11 C (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. Copies mailed to: Petitioner Respondent Marylou Matas, Esq. Robert J. Dailey, Esq. Date of Order: August 20, 2008 BY THE COURT, Edgar B. Bayley, President Judge Jl;. . Sh f ay, C Inference Officer ?s YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 cc361 ?T'7!;> ? G'? t t'? T ? ?? ? - ?' -.,. ; ?: '?7 .. ?.. ? ,t ,,?r ?° ? ? 7 T7 ..""? ?^'?,a . u. ...? MICHELE PARKER, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 08-1310 CIVIL TERM PATRICK PARKER, IN DIVORCE Defendant/Petitioner PACSES Case No: 027110276 ORDER OF COURT AND NOW, this 27th day of August 2008, based upon the Court's determination that the Petitioner's monthly net income/earning capacity is $ n/a and the Respondent's monthly net income/earning capacity is $ n/a, it is hereby ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit Seven Hundred Fifty Eight and 33/100 Dollars ($ 758.33) per month payable bi-weekly as follows: $ 758.33 per month for Alimony Pendente Lite and $ 0.00 per month on arrears. First payment due: in accordance with Respondent's pay schedule in the amount of $350.00 bi-weekly. The effective date of the order is August 13, 2008. Arrears set at $ 473.70 as of August 27, 2008. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C.S.§ 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and, at its discretion, make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the PA SCDU to: Patrick Parker. Payments must be made by check or money order. All checks and money orders must be made payable to PA SCDU and mailed to: PA SCDU P.O. Box 69110 Harrisburg, PA 17106-9110 Payments must include the Respondent's name with their PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. cc360 -s The Respondent is to provide medical insurance coverage. This order is based upon an agreement of the parties and the Respondent having the care and custody of the parties' two children. This Order shall become final twenty (20) after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary for a hearing de novo before the Court. Consented: Petitioner Respondent Petitioner's Attorney Respondent's Attorney Mailed copies on: August 28, 2008 to: Petitioner Respondent Robert J. Dailey, Esq. Marylou Matas, Esq. BY THE COURT, Edward E. Guido, J. DRO: R.J. Shadday I rn co r , ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 08/27/08 Case Number (See Addendum for case summary) Employer/Withholder's Federal EIN Number CONSULATE HEALTH CARE 100 TANDEM VILLAGE RD CANONSBURG PA 15317-2382 235-13-9532 Employee/Obligor's Social Security Number 9585102018 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? Dyes ® no $ 0.00 per month in current medical support $ o . oo per month in past-due medical support $ 758.33 per month in current spousal support $ o. oo per month in past-due spousal support $ 0.00 per month for genetic test costs $ o . oo per month in other (specify) $ one-time lump sum payment for a total of $ 758.33 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: $ 175.00 per weekly pay period. $ 379.17 per semimonthly pay period (twice a month) $ 350.00 per biweekly pay period (every two weeks) $ 758.33 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. 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 NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUM RDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: AUG 2 8 ZUU6 DRO: R. J. Service Type M SHADDAY OMB No.: 0970-0154 08-1310 CIVIL (D original Order/Notice OAmended Order/Notice OTerminate Order/Notice QOne-Time Lump Sum/Notice RE: PARKER, MICHELE Employee/Obligor's Name (Last, First, MI) EDWARD B° JUDGE Form EN-028 Rev. 4 Worker ID $IATT 1 758*33 j. 120 Jf 52- 175.00 75$•33x, 12- + 26• Q 3SC??OQ i ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS If heck you are required to pr vide a opy of this form to your mployee. If yo r employee orks in a state that is dierent from the state that issued this or?er, a copy must be provi?ed to your employee even if tie box is not checked. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3.* Reporting the Paydate/Date of Withholding: You must report the paydate/date of withholding when sending the payment. The paydate/date of withholding is the date on which amount was withheld from the employee's wages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employeelobligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. 2516890880 THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : rl THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 13 EMPLOYEE'S/OBLIGOR'S NAME: PARKER, MICHELE EMPLOYEE'S CASE IDENTIFIER: 9585102018 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 employeelobligor'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 employeelobligor 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'slobligor'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 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT 13 N. HANOVER ST by telephone at (717) 240-6225 or P.O. BOX 320 by FAX at (717) 240-6248 or CARLISLE PA 17013 by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Rev. 4 Service Type M OMB No.: 0970-0154 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: PARKER, MICHELE PACSES Case Number 027110276 Plaintiff Name PATRICK PARKER Docket Attachment Amount 08-1310 CIVIL$ 758.33 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 Addendum Service Type M OMB No.: 0970-0154 PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Form EN-028 Rev. 4 Worker I D $ IATT rv -TI Fl, N F MICHELE PARKER, Plaintiff V. PATRICK PARKER, Defendant Substitution of Counsel / Change in Address Without Leave of Court (Rule 1012(b)(2)(ii)) Praecipe for Entry of Appearance To the Prothonotary: Please enter my appearance on behalf of Michele Parker, Plaintiff. I hereby certify that this change is not intended to, nor will it, delay this proceeding to the best of my knowledge, information and belief. Papers may be served at the address set forth below: Date: 29th of August, 2008 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO.2008 - 1310 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE Robert J. Dailey, Esquire I.D. No. 203418 Gerber & Associates 46 East Main Street Palmyra, PA 17078 Phone (717) 838-5411 Fax (717) 838-3047 rdailey@gerberlawo ffice. com Praecipe for Withdrawal of Appearance To the Prothonotary: Please withdrawal my appearance on behalf of Michele Parker, Plaintiff. Date: 29th of August, 2008 O'Brien, Baric & CERTIFICATE OF SERVICE I hereby certify that on the day of " e- , 2008, I, Andrea M. Barr'ick, of O'Brien, Baric & Scherer, did serve a copy of the Substitution of Counsel/Change Without Leave of Court (Rule 1012(b)(2)(ii)), by first class U.S of Address U.S. mail, postage prepaid, to the party listed below, as follows: Marylou Matas, Esquire Saidis, Flower and Lindsay 26 West High Street Carlisle, Pennsylvania 17013 Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, Pennsylvania 17013 Andrea . Barrick r? c,? ,3_ -, F'i """e.? ??k?" .. ?,! T' ' C,k7 , ; ,, 0. °l?'. ?' ,?,,, ? ? .'S ??? y .-? MICHELE PARKER, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 08-1310 CIVIL TERM PATRICK PARKER, IN DIVORCE Defendant/Petitioner PACSES CASE: 027110276 ORDER OF COURT AND NOW to wit, this 17th day of November 2008, it is hereby Ordered that the Respondent shall pay an additional sum of $54.00 per month on the accumulated arrears. 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 parry files a written demand with the Domestic Relations Section for a hearing de novo before the Court. BY THE COURT: 6W Edward E. Guido, J. DRO: R.J. Shadday xc: Petitioner Respondent Marylou Matas, Esq. Robert J. Dailey, Esq. Form OE-001 Service Type: M Worker: 21005 e 7 r ..xC ....a S"4"p 1 y .. ? ?1 4 ? ORDERMOTICE TO WITHHOLD INCOME FOR SUPPORT 08-1310 CIVIL State Commonwealth of Pennsylvania OOriginal Order/Notice Co./City/Dist. Of CUMBERLAND @Amended Order/Notice Date of Order/Notice 11/17/08 QTerminate Order/Notice Case Number (See Addendum for case summary) (Done-Time Lump Sum/Notice Employer/Withholder's Federal EIN Number CONSULATE HEALTH CARE 100 TANDEM VILLAGE RD CANONSBURG PA 15317-2382 235-13-9532 Employee/Obligor's Social Security Number 9585102018 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 $ 758.33 $ 54.00 $ 0.00 $ 0.00 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? byes ® no one-time lump sum payment for a total of $ 812.33 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: $ 187.46 per weekly pay period. $ 406.17 per semimonthly pay period (twice a month) $ 374.92 per biweekly pay period (every two weeks) $ 812.33 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten 00) 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 eamings. 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. 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 NAME AND Tt . P-ACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY R / RDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: RE: PARKER, MICHELE Employee/Obligor's Name (Last, First, MI) Edward E.' GuiA, Judge DRO: R. J. Shadday Form EN-028 Rev. 4 Service Type M OMB No.: 0970-0154 Worker ID $IATT + 1$'x•46 $12,33x 12, + 26, 3??•g2* ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS 94 hecke l you are required, to perde a opy of this form to youraloyee. If yoyr employee works in a state that is erent rom the state that issu t is o er, a copy must be provi 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 employeelobligor. 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'slobligor'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 employeelobligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employeelobligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. 2516890880 THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : 0 THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 0 EMPLOYEE'S/OBLIGOR'S NAME: PARKER, MICHELE EMPLOYEE'S CASE IDENTIFIER: 9585102016 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. Antidiscrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employeelobligor 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'slobligor'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 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT 13 N. HANOVER ST by telephone at (717) 240-6225 or P.O. BOX 320 by FAX at (717) 240-6248 or CARLISLE PA 17013 by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Rev. 4 Service Type M OMB No.: 0970.0154 Worker I D $ IATT t ADDENDUM Summary of Cases on Attachment Defendant/Obligor: PARKER, MICHELE PACSES Case Number 027110276 PACSES Case Number Plaintiff Name Plaintiff Name PATRICK PARKER Docket Attachment Amount Docket Attachment Amount 08-1310 CIVIL$ 812.33 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff Name Docket Attachment Amount Docket Attachment Amount $ 0.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff Name Docket Attachment Amount Docket Attachment Amount $ 0.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB Addendum Service Type M OMB No.: 097401 S4 Form EN-028 Rev. 4 Worker ID $IATT Jm ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 08? 1310 CIVIL State Commonwealth of Pennsylvania 0Original Order/Notice Co./City/Dist. of CUMBERLAND OAmended Order/Notice Date of Order/Notice 06/30/09 0Terminate Order/Notice Case Number (See Addendum for case summary) QOne-Time Lump Sum/Notice RE: PARKER, MICHELE Employer/Withholder's Federal EIN Number Employee/Obligor's Name (Last, First, MI) 235-13-9532 Employee/Obligor's Social Security Number CONSULATE HEALTH CARE 9585102018 100 TANDEM VILLAGE RD Employee/Obligor's Case Identifier CANONSBURG PA 15317-2382 (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 $ o.00 per month in past-due child support Arrears 12 weeks or greater? Dyes ® no $ 0.00 per month in current medical support $ 0.00 per month in past-due medical support $ 758.33 per month in current spousal support $ o . oo per month in past-due spousal support $ 0.00 per month for genetic test costs $ 0.00 per month in other (specify) $ one-time lump sum payment for a total of $ 758.33 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: $ 175.00 per weekly pay period. $ 379.17 per semimonthly pay period (twice a month) $ 350.00 per biweekly pay period (every two weeks) $ 758.33 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, Harrisbur 106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NA AND TH CSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SEC ITY N?ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. p:r BY THE COURT: DRO: R.J. Shadday Edward E. Guido, Judge Form EN-028 Rev.5 Service Type M OMB No.: 0970-0154 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS If hecked you are required to provide a copy of this form to your m loyee. If your employee works in a state that is dierent from the state that issued this order, a copy must be provicedpto your employee even if the box is not checked. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3.* Reporting the Paydate/Date of Withholding: You must report the paydate/date of withholding when sending the payment. The paydate/date of withholding is the date on which amount was withheld from the employee's wages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the 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. 2516890880 THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : 0 THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: O EMPLOYEE'S/OBLIGOR'S NAME: PARKER, MICHELE EMPLOYEE'S CASE IDENTIFIER: 9585102018 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 Service Type M OMB No.: 0970-0154 Form EN-028 Rev.S Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: PARKER, MICHELE PACSES Case Number 027110276 PACSES Case Number Plaintiff Name Plaintiff Name PATRICK PARKER Docket Attachment Amount Docket Attachment Amount 08-1310 CIVIL$ 758.33 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB PACSES Case Number PACSES Case Number Plaintiff Name Plaintiff Name Docket Attachment Amount Docket Attachment Amount $ 0.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB PACSES Case Number PACSES Case Number Plaintiff Name Plaintiff Name Docket Attachment Amount Docket Attachment Amount $ 0.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB Addendum Form EN-028 Rev.5 Service Type M oMBNo.:0970-0154 Worker ID $IATT n r)_, ; :F Cyr ,Y 2009 JUL -1 PH 3: } 0 LJ In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION PATRICK PARKER ) Docket Number 08-1310 CIVIL Plaintiff ) vs. ) PACSES Case Number 027110276 MICHELE PARKER ) Defendant ) Other State ID Number PETITION FOR MODIFICATION OF AN EXISTING SUPPORT ORDER 1. The petition of MICHELE PARKER respectfully represents that on AUGUST 27, 2008 , an Order of Court was entered for the support of PATRICK PARKER A true and correct copy of the order is attached to this petition. Form OM-501 Service Type M Worker ID 21504 PARKER V. PARKER PACSES Case Number: 027110276 2. Petitioner is entitled to 0 increase 0 decrease ® termination 0 reinstatement 0 other of this Order because of the following material and substantial change(s) in circumstance: WHEREFORE, Petitioner requests that the Court modify the existing order for support. ( R?Z? Petitioner Attorney for Petitioner I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unworn falsification to authorities. --Iko o Date Service Type m Petitioner Page 2 of 2 Form OM-501 Worker ID 21504 i ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 08=1310 CIVIL State Commonwealth of Pennsylvania OOriginal Order/Notice Co./City/Dist. of CUMBERLAND OAmended Order/Notice Date of Order/Notice 06/30/09 0Terminate Order/Notice Case Number (See Addendum for case summary) QOne-Time Lump Sum/Notice RE: PARKER, MICHELE Employer/Withholder's Federal EIN Number Employee/Obligor's Name (Last, First, MI) 235-13-9532 Employee/Obligor's Social Security Number CONSULATE HEALTH CARE 9585102018 100 TANDEM VILLAGE RD Employee/Obligor's Case Identifier CANONSBURG PA 15317-2382 (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 $ o . oo per month in past-due child support Arrears 12 weeks or greater? 0 yes ® no $ 0.00 per month in current medical support $ 0.00 per month in past-due medical support TRUE COPY FROM RECORD $ 758.33 per month in current spousal support In Testimony whereof, I he-re unto set my hand $ o . oo per month in past-due spousal support and the seal Af said Court at Carlisle, Pa. $ o.00 per month for genetic test costs (:? a9 $ o. oo per month in other (specify) This ................ dtayy of...... ...... ...., ..... $ one-time lump sum payment = ..:?: - -P O for a total of $ 758.33 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: $ 175.00 per weekly pay period. $ 379.17 per semimonthly pay period 350.00 - (twice a month) $ per biweekly pay period (every two weeks) $ 758.33 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, Harrisbur 106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NA AND TH CSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SEC ITY N?ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. .o" BY THE COURT: Edward E. Guido, Judge DRO: R. J. Shadday Form EN-028 Rev.5 Service Type M OMB No.: 0970-0154 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS Ifheckei you are required to provide a copy of this form to your m loyee. If your employee works in a state that is di erent rom the state that issued this order, a copy must be provideedpto your employee even if the box is not checked. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3.* 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. '.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employeelobligor 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. 2516890880 THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : 0 THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 0 EMPLOYEE'S/OBLIGOR'S NAME: PARKER, MICHELE EMPLOYEE'S CASE IDENTIFIER: 9585102018 LAST KNOWN HOME ADDRESS: DATE OF SEPARATION: 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 0 5 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: If you or your employee/obligor have any questions, DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT 13 N. HANOVER ST by telephone at (717) 240-6225 or P.O. BOX 320 by FAX at (717) 240-6248 or CARLISLE PA 17013 by Internet www.childsupport.state.pa.us Service Type M Page 2 of 2 OMB No.: 0970-0154 Form EN-028 Rev.5 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: PARKER, MICHELE PACSES Case Number 027110276 PACSES Case Number Plaintiff Name Plaintiff Name PATRICK PARKER Docket Attachment Amount Docket Attachment Amount 08-1310 CIVIL$ 758.33 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): 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 PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB DOB DOB Addendum Form EN-028 Rev.5 Service Type M Worker I D $ IATT OMB No.: 0970-0754 FILE OF TNF F ray 2009 JUL - 6 All 6: 3 6 F '- T I In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION f PATRICK PARKER ) Docket Number 08-1310 CIVIL Plaintiff ) VS. ) PACSES Case Number 027110276 MICHELE PARKER ) Defendant ) Other State ID Number PETITION FOR MODIFICATION OF AN EXISTING SUPPORT ORDER 1. The petition of MICHELE PARKER respectfully represents that on AUGUST 27, 2008 , an Order of Court was entered for the support of PATRICK PARKER A true and correct copy of the order is attached to this petition. Service Type M Form OM-501 Worker ID 21504 PARKER V. PARKER PACKS Case Number: 027110276 2. Petitioner is entitled to O increase Q decrease ® termination O reinstatement O other of this Order because of the following material and substantial change(s) in circumstance: WHEREFORE, Petitioner requests that the Court modify the existing order for support. ?r'&Lt n? Petitioner Attorney for Petitioner I verify that the statements made in this complaint 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. .--A on n Date Petitioner Page 2 of 2 Form OM-501 Service Type M Worker ID 21504 FILE OF THE L'-? P,: - „ 't' Y 2009 JU? --;f F01 1" It 3 ?? I? 7s I_u ri .i', COpLt Ito OQ.o MICHELE PARKER, THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 08-1310 CIVIL TERM PATRICK PARKER, IN DIVORCE Defendant PACSES CASE NO: 027110276 ORDER OF COURT AND NOW, this 10th day of July, 2009, a petition has been filed against you, Patrick Parker, 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 Au¢ust 4.2009 at 10:30 A.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 Marylou Matas, Esq. Robert J. Dailey, Esq. , Date of Order: July 10, 2009 y R. J. Slodday, Conference Officer YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 cc361 Ti?q OF THE 2009 !UL 10 El 3: '1 9 MICHELE PARKER, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 08-1310 CIVIL TERM PATRICK PARKER, IN DIVORCE Defendant/Petitioner PACSES CASE: 027110276 ORDER OF COURT AND NOW to wit, this 4th day of August, 2009, it is hereby Ordered that the Respondent's petition to terminate the Alimony Pendente Lite is dismissed, without prejudice. 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: Edward E. Guido, J. DRO: R.J. Shadday xc: Petitioner Respondent Marylou Matas, Esq. Robert J. Dailey, Esq. Form OE-001 Service Type: M Worker: 21005 FILED v?+ ! iy,rw (f THE `, EO } r 2909 AUG -4 Fl h 2: 15 UNTY MICHELE PARKER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - DIVORCE CASE NO.2008-1310 CIVIL TERM PACSES NO. 027110276 PATRICK PARKER, Defendant IN DIVORCE NOTICE OF APPEAL AND REQUEST FOR HEARING DE NOVO AND NOW, comes Plaintiff, Michele Parker, by and through her attorneys, GERBER & ASSOCIATES, and appeals from the order entered in this matter on August, 2009 dismissing her petition to modify the previous alimony pendente lite Order of Court, and requests a hearing de novo before the Support Master of Cumberland County, PA. Respectfully requested, GERBER & Robert J? Dailey, sqi I.D. No. 203418 46 East Main Street Palmyra, PA 17078 (717) 838-5411 Attorney for Plaintiff MICHELE PARKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -DIVORCE CASE NO.2008-1310 CIVIL TERM PACSES NO. 027110276 PATRICK PARKER, : Defendant IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that I, Robert J. Dailey, Esquire of GERBER & ASSOCIATES, have served a copy of Plaintiff's Notice of Appeal and Request for Hearing De Novo by U.S. mail, postage prepaid, to counsel for the interested party as follows: Date: q"" of August 2009 Marylou Matas, Esquire SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA 17013 F=ILE:`-` ?JF -Mr L 2009 AUG I I At o 5 i CUM" Cmpy 40 t In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION PATRICK PARKER ) Docket Number 08-1310 CIVIL Petitioner ) vs. ) PACSES Case Number 027110276 MICHELE PARKER ) Other State ID Number Respondent ) ORDER OF COURT You, MICHELE PARKER, of 313A Means Hollow Road, Shippensburg, PA 17257 are ordered to appear at the DOMESTIC RELATIONS hearing room, c/o Hearing Room, DOMESTIC RELATIONS OFFICE, 13 North Hanover Street, Carlisle, PA 17013 on the I st day of October, 2009, at 10:30 a.m. 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: PARKER v. PARKER PACSES Case Number: 027110276 If you fail to appear for the hearing or to bring the required documents, the court may issue a warrant for your arrest and/or enter an interim support: order. 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 CO Date of Order:' (? Uf JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE 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 County Bar Association 32 Bedford Street 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. OF THIS ?TO'r? 0TAPY 2009 AUU 17 PIN 2: 3 5 Ci Pt Nin/ t"?.r."1`it4 t`,l F l..Yiyi 'did In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION PATRICK PARKER Petitioner Docket Number PACSES Case Number Other State ID Number 08-1310 CIVIL vs. MICHELE PARKER ORDER OF COURT 027110276 You, PATRICK PARKER of 7614 Woodbine Road, Woodbine, MD 21797 are ordered to appear at the DOMESTIC. RELATIONS hearing room, c/o Hearing Room, DOMESTIC RELATIONS OFFICE, 13 North Hanover Street, Carlisle, PA 17013 on the Is' day of October, 2009, at 10:30 a.m. 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: Respondent PARKER v. PARKER PACSES Case Number: 027110276 If you fail to appear for the hearing or to bring the required documents, the court may issue a warrant for your arrest and/or enter an interim support: order. 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 COU Date of Order: y JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE 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 County Bar Association 32 Bedford Street 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. 4N SLED-OFFICE OF THE PROT 'nNOTARY 2009 AUG 17 PM Z* ? ?? MICHELE PARKER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : DOMESTIC RELATIONS SECTION PATRICK PARKER, PACSES NO. 027110276 Defendant DOCKET NO. 08-1310 CIVIL ORDER OF COURT AND NOW, this 2nd day of October, 2009, this matter having been scheduled for a hearing de novo before the Support Master on the Wife's petition for modification of alimony pendente lite, and the parties having reached an agreement on all outstanding issues, upon recommendation of the Master it is ordered and decreed as follows: A. The Wife's request for hearing having been withdrawn, the prior order entered August 27, 2008 shall remain in full force and effect. B. Said order of August 27, 2008 shall be suspended effective March 31, 2010. By the Court, 1?? 11 Edwjr ; . Cc: Patrick Parker Michele Parker Marylou Matas, Esquire For the Plaintiff Robert J. Dailey, Esquire For the Defendant DRO/rjs FILED t-aJIFFICE OF 7'HE PFPT- ONOTARY 2009 OCT -5 AM i 1.0 4 CUM ,: ?t?t; y MICHELE PARKER, Plaintiff/Respondent V. PATRICK PARKER, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Case No. 2008-1310 CIVIL TERM PACSES Case No. 027110276 : In Divorce/ APL ALIMONYPENDENTELITE STIPULATION AND AGREEMENT THIS AGREEMENT AND STIPULATION is made this v, 1 day of September 2009, BY AND BETWEEN Michele Parker ("Plaintiff') and Patrick Parker ("Defendant"). WITNESSETH: WHEREAS, Plaintiff and Defendant are currently engaged in divorce proceedings and the most recent alimony pendente lite ("APL") Order was entered August 27, 2008; WHEREAS, the parties now wish to enter into a new agreement as part of a comprehensive agreement to conclude the divorce and support proceedings; NOW THEREFORE, in consideration of the parties' mutual covenants and promises set forth below, Plaintiff and Defendant, agreeing to be legally bound, agree as follows: 1. Plaintiff shall continue to pay to Defendant the amount of seven hundred and fifty-eight dollars and thirty-three cents ($758.33) per month for APL through March 31, 2010. 2. After March 31, 2010, Plaintiffs obligation of APL and all other support to Defendant shall terminate. All terms of the prior Order not altered herein are incorporated herein and shall continue to be in effect hereafter. 4. This Agreement and Stipulation may be executed in multiple counterparts and a photocopy shall have the same effect as the original. 5. Plaintiff hereby withdrawals her request for a de novo hearing scheduled for Thursday, November 1, 2009 and Defendant consents to Plaintiff's withdrawal of said hearing. IN WI ESS W OF, the parties hereto, intending to be legally bound, set their hands and s?'al on the a set orth above. R bert J. bailey, 7eParker ire Mary u tas, Esq Counsel for MU Counsel atrick Parker FILED-0!--* ;ter OF THE P`^,TH(IN!r.)TA?Y 2009 OC -G PH 2: c 9 PEt'i°a4'?f ??aki+ b8-13to MARITAL SETTLEMENT AGREEMENT BY AND BETWEEN MICHELE PARKER PATRICK PARKER Robert J. Dailey, Esquire GERBER & ASSOCIATES 46 East Main Street Palmyra, PA 17078 (717) 838-5411 Attorney for Michele Parker Marylou Matas, Esquire SAIDIS, FLOWER & LINDSAY 27 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Patrick Parker MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this 0 day of "6-w 2009 by and between Michele Parker ("Wife") and Patrick Parker ("Husband"); WITNESSETH: WHEREAS, Wife and Husband ("the parties") were lawfully married on August 23, 1991 in Martinsburg, West Virginia; WHEREAS, differences have arisen between the parties and they have resolved that the marriage is irretrievably broken and that it is not possible to continue the martial relationship for reasons known to them; WHEREAS, Wife filed for divorce on February 27, 2008 in the Cumberland County Court of Common Pleas, Pennsylvania and Husband accepted service by certified mail on March 11, 2008 and counsel for Husband accepted service on March 13, 2008; WHEREAS, the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation, the settling of all matters between them relating to the ownership of real and personal property, the support and maintenance of one another and, in general, the settling of any and all claims and possible claims by one against the other or against their respective estates; and WHEREAS, the parties declare that each has had a full and fair opportunity to obtain independent legal advice of counsel and Wife has been independently represented by Robert J. Dailey, Esquire of GERBER & ASSOCIATES and Husband has been independently represented by Marylou Matas, Esquire of SAIDIS, FLOWER & LINDSAY. NOW THEREFORE, in consideration of these promises, and of the mutual promises, covenants and undertakings hereinafter set forth, and for other good and valuable consideration, the 1 receipt and sufficiency of which is hereby acknowledged by each of the parties hereto, Husband and Wife, each intending to be legally bound hereby, covenant and agree as follows: 1. PERSONAL RIGHTS. Husband and Wife may, at all times hereafter, live separate and apart. Each shall be free from all control, restraint, interference and authority, direct or indirect by the other. Each may reside at such place or places as he or she may select. Each may, for his or her separate use or benefit, conduct, carry on or engage in any business, occupation, profession or employment which to him or her may seem advisable. Husband and Wife shall not molest, harass, disturb or malign each other, nor compel or attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with him or her. Neither party will interfere with the use, ownership, enjoyment or disposition of any property now owned by or hereafter acquired by the other. 2. ADVICE OF COUNSEL. Each party acknowledges that he or she has had the opportunity to receive independent legal advice from counsel of his or her selection. Wife has secured legal advice from Robert J. Dailey, Esquire, of GERBER & ASSOCIATES, her counsel, and Husband has secured legal advice from Marylou Matas, Esquire, of SAIDIS, FLOWER & LINDSAY, his counsel. Each party fully understands the facts and his or her legal rights and obligations, and each party acknowledges and accepts that this Agreement is, in the circumstances, fair and equitable, and that it is being entered into freely and voluntarily, and that the execution of this Agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal agreement or agreements. 3. DISCLOSURE OF ASSETS. Each of the parties hereto acknowledges that he or she is aware of his or her right to seek discovery including, but not limited to, written interrogatories, motions for production of documents, the taking of oral depositions, the filing of 2 inventories and all other means of discovery permitted under the Pennsylvania Divorce Code or the Pennsylvania Rules of Civil Procedure. Each of the parties further acknowledges that he or she has had the opportunity to discuss with independent legal counsel the concept of marital property under Pennsylvania law and each is aware of his or her right to have the real and/or personal property, estate and assets, earnings and income of the other assessed or evaluated by the courts of this Commonwealth or any other court of competent jurisdiction. The parties do hereby acknowledge that there has been full and fair disclosure to the other of his or her respective income, assets and liabilities, whether such are held jointly, in the name of one party alone or in the name of one of the parties and another individual or individuals. Each party agrees that any right to further disclosure, valuation, appraisal or enumeration or statement thereof in this Agreement is hereby specifically waived, and the parties do not wish to make or append hereto any further enumeration or statement. Specifically, each party waives the need for copies of bank statements, insurance policies, retirement plan statements or any other documentation. Each party warrants that he or she is not aware of any marital asset which is not identified in this Agreement. The parties hereby acknowledge and agree that the division of assets as set forth in this Agreement is fair, reasonable and equitable, and is satisfactory to them. Each of the parties hereto further covenants and agrees for himself and herself and his or her heirs, executors, administrators or assigns, that he or she will never at any time hereafter sue the other party or his or her heirs, executors, administrators or assigns in any action of contention, direct or indirect, and allege therein that there was a denial of any rights to full disclosure, or that there was any fraud, duress, undue influence or that there was a failure to have available full, proper and independent representation by legal counsel. 4. MUTUAL CONSENT DIVORCE. It is the intention of the parties, and the parties agree, that by this Agreement they have resolved all ancillary economic issues related to the 3 dissolution of their marriage and thus any divorce action with respect to these parties shall be limited to a claim for divorce only. The parties agree that on April 1, 2010 or the payment of $2,000.00 from Wife to Husband, whichever occurs later in time, each party shall execute his and her (c) affidavit of consent and waiver of notice of intention to request entry of divorce decree and shall forward the same to counsel for Wife. Time is of the essence to ensure that counsel for Wife can forward the necessary documents to the Court for finalization of the parties' divorce and entry of a final decree in divorce. 5. EQUITABLE DISTRIBUTION. A. Real Estate. The Parties own no real estate. B. Furnishinus and Personalty. The parties agree that they have, by agreement, divided all furnishings and personalty located in the marital property, including all furniture, furnishings, antiques, jewelry, rugs, carpets, household appliances and equipment with the exception of the List attached hereto and incorporated herein. The items on the List are exclusive and items to that List shall not be added to nor deleted from except upon written agreement of the parties. The List items shall be made available to Husband by Wife on a mutually agreeable weekend date for pick-up. Wife shall place these items outside the home for Husband's convenience and in no event shall Husband enter Wife's residence. The pick-up date shall be scheduled after the signing and execution of this Agreement. Thereafter, Husband shall retain sole and exclusive ownership of all furnishings and personalty currently in his possession, free and clear of any right, title, claim and/or interest of Wife and Wife shall retain sole and exclusive ownership of all furnishings and personalty currently in her possession, free and clear of any right, title, claim and/or interest of Husband. 4 C. Motor Vehicles. The parties agree that they have, by agreement, divided all motor vehicles. Accordingly, Husband shall retain sole and exclusive ownership of the 1990 Chevrolet conversion van currently in his possession, free and clear of any right, title, claim and/or interest of Wife and Wife shall retain sole and exclusive ownership of the 2004 Ford Explorer currently in her possession, free and clear of any right, title, claim and/or interest of Husband. The parties agree that they will cooperate in effectuating the necessary transfer of any titles, registration or insurance on these vehicles within thirty (30) days of execution of this Agreement and that all costs thereof shall be equally shared between them. D. Life Insurance. To the extent that either party has life insurance policies, simultaneous with the execution of this Agreement those policies shall become the sole and separate property of the individual owning the policy. The parties adopt 20 Pa.C.S.A. § 6111.2 to govern their policies held in favor of each other, regardless of where each individual party resides at the time of his or her death. Nothing in this Agreement shall prevent or preclude either party from designating beneficiaries under or encumbering their respective life insurance policies. E. Pension and Retirement Benefits. Husband shall keep and retain any and all pension and retirement benefits currently titled in his name and Wife shall keep and retain any and all pension and retirement benefits in her name. Each party hereby releases and relinquishes any and all rights, title and interest in or to any benefits of the other party. F. Bank Accounts. Wife shall pay to Husband $2,000.00 on or before March 31, 2010. In the event Wife does not pay Husband $2,000.00 on or before March 31, 2010, Husband may refuse to execute the documents necessary to conclude this divorce and shall have the right to enforce this Agreement. Husband shall keep and retain any and all accounts 5 titled in his name and Wife shall keep and retain any and all accounts titled in her name. Each party hereby releases and relinquishes any and all rights, title and interest in or to any accounts of the other party. G. Miscellaneous Property. As of the execution date of this Agreement, any and all property not specifically addressed herein shall be owned by the party to whom the property is titled; and if untitled, the party in possession. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property from each to the other. H. Property to Wife. The parties agree that Wife shall own, possess, and enjoy, free from any claim of Husband, the property awarded to her by the terms of this Agreement. Husband hereby quitclaims, assigns and conveys to Wife all such property, and waives and relinquishes any and all rights thereto, together with any insurance policies covering that property, and any escrow accounts relating to that property. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property from Husband to Wife. I. Property to Husband. The parties agree that Husband shall own, possess, and enjoy, free from any claim of Wife, the property awarded to him by the terms of this Agreement. Wife hereby quitclaims, assigns and conveys to Husband all such property, and waives and relinquishes any and all rights thereto, together with any insurance policies covering that property, and any escrow accounts relating to that property. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property from Wife to Husband. 6 J. Marital Debt. Husband shall pay all debt titled in his name and Wife shall pay all debt titled in her name. There is no marital debt on which the parties are jointly obligated. In the event that either party contracted or incurred any debts since the date of separation other than the debts listed above, the party who incurred the debt and benefited therefrom shall be responsible for the payment thereof, regardless of the name in which the debt may have been incurred. Each party agrees to indemnify and hold each other harmless from any and all debts, obligations and liabilities in each parties name alone. K. Liability not Listed. Each party represents and warrants to the other that there is not any joint debt and that he or she has not incurred any debt, obligation or other liability, other than those described in this Agreement, on which the other party is or---may be liable. A liability not disclosed in this Agreement will be the sole responsibility of the party who has incurred or may hereafter incur it and/or benefit from it, and such party agrees to pay it as the same shall become due, and to indemnify and hold the other party and his or her property harmless from any and all debts, obligations and liabilities. L. Indemnification of Wife. If any claim, action or proceeding is hereafter initiated seeking to hold Wife liable for the debts or obligations assumed by Husband under this Agreement, Husband will, at his sole expense, defend Wife against any such claim, action or proceeding, whether or not well-founded, and indemnify her and her property against any damages or loss resulting therefrom, including, but not limited to, costs of court and actual attorney's fees incurred by Wife in connection therewith. M. Indemnification of Husband. If any claim, action or proceeding is hereafter initiated seeking to hold Husband liable for the debts or obligations assumed by Wife 7 under this Agreement, Wife will, at her sole expense, defend Husband against any such claim, action or proceeding, whether or not well-founded, and indemnify him and his property against any damages or loss resulting therefrom, including, but not limited to costs of court and actual attorney's fees incurred by Husband in connection therewith. N. Warranty as to Future Obligations. Husband and Wife each represents and warrants to the other that he or she will not at any time in the future incur or contract any debt, charge or liability for which the other, the other's legal representatives, property or estate may be responsible. From the date of execution of this Agreement, each party shall use only those credit cards and accounts for which that party is individually liable and the parties agree to cooperate in closing any remaining accounts which provide for joint liability. Each party hereby agrees to indemnify, save and hold the other and his or her property harmless from any liability, loss, cost or expense whatsoever, including actual attorneys fees, incurred in the event of breach. 6. JURISDICTION. The Court of Common Pleas of Cumberland County, Pennsylvania will retain jurisdiction in order to implement the terms and conditions of this equitable distribution paragraph should there be any dispute between the parties regarding the final distribution. 7. INCOME TAX. The parties have heretofore filed joint federal and state tax returns. Both parties agree that, in the event any deficiency in federal, state or local income tax is proposed or any assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and 8 extent of his or her separate income on the aforesaid joint returns. 8. SUPPORT: Alimony, Alimonypendente lite, Support. Wife shall continue to pay Husband alimony pendente lite through the Domestic Relations Office of Cumberland County through March 31, 2010 in accordance with the terms of the August 27, 2008 Order of Court. Thereafter, on April 1, 2010, the support obligation shall terminate and Husband and Wife hereby expressly waive, discharge and release any and all rights and claims which he or she may have now or hereafter by reason of the parties' marriage to alimony, alimony pendente lite, spousal support and/or maintenance or other like benefits resulting from the parties' status as husband and wife. 9. WAIVER OF INHERITANCE RIGHTS. Unless otherwise specifically provided in this Agreement, as of the execution date of this Agreement, Husband and Wife each waives all rights of inheritance in the estate of the other, any right to elect to take against the will or any trust of the other or in which the other has an interest, and each of the parties waives any additional rights which said party has or may have by reason of their marriage, except the rights saved or created by the terms of this Agreement. This waiver shall be construed generally and shall include, but not be limited to, a waiver of all rights provided under the laws of Pennsylvania, or any other jurisdiction. 10. WAIVER OF BENEFICIARY DESIGNATION. Unless otherwise specifically set forth in this Agreement, each party hereto specifically waives any and all beneficiary rights and any and all rights as a surviving spouse in and to any asset, benefit or like program carrying a beneficiary designation which belongs to the other party under the terms of this Agreement, including, but not limited to, pensions and retirement plans of any sort or nature, deferred compensation plans, life insurance policies, annuities, stock accounts, bank accounts, final pay 9 checks or any other post-death distribution scheme, and each party expressly states that it is his and her intention to revoke by the terms of this Agreement any beneficiary designations naming the other which are in effect as of the date of execution of this Agreement. If and in the event the other party continues to be named as beneficiary and no alternate beneficiary is otherwise designated, the beneficiary shall be deemed to be the estate of the deceased party. 11. RELEASE OF CLAIMS. A. Wife and Husband acknowledge and agree that the property dispositions provided for herein constitute an equitable distribution of their assets and liabilities pursuant to §3502 of the Divorce Code, and Wife and Husband hereby waive any right to division of their property except as provided for in this Agreement. Furthermore, except as otherwise provided for in this Agreement, each of the parties hereby specifically waives, releases, renounces and forever abandons any claim, right, title or interest whatsoever he or she may have in property transferred to the other party pursuant to this Agreement or identified in this Agreement as belonging to the other party, and each party agrees never to assert any claim to said property or proceeds in the future. The parties have divided between them to their mutual satisfaction, personal effects, household goods and furnishings and all other articles of personal property which have heretofore been used in common by them, and neither party will make any claim to any such items which are now in the possession or under the control of the other. Should it become necessary, each party agrees to sign any title or documents necessary to give effect to this paragraph, upon request. However, neither party is released or discharged from any obligation under this Agreement or any instrument or document executed pursuant to this Agreement. Husband and Wife shall hereafter own and enjoy independently of any claim or right of the other, all items of personal property, tangible or intangible, acquired by him or her from the 10 execution date of this Agreement with full power in him or her to dispose of the same fully and effectively for all purposes. B. Each party hereby absolutely and unconditionally releases and forever discharges the other and the estate of the other for all purposes from any and all rights and obligations which either party may have or at any time hereafter has for past, present or future support or maintenance, alimony pendente lite, alimony, equitable distribution, counsel fees, costs, expenses, and any other right or obligation, economic or otherwise, whether arising out of the marital relationship or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, its supplements and amendments, as well as under any other law of any other jurisdiction, except and only except all rights and obligations arising under this Agreement or for the breach of any of its provisions. Neither party shall have any obligation to the other not expressly set forth herein. C. Except as set forth in this Agreement, each party hereby absolutely and unconditionally releases and forever discharges the other and his or her heirs, executors, administrators, assigns, property and estate from any and all rights, claims, demands or obligations arising out of or by virtue of the marital relationship of the parties whether now existing or hereafter arising. The above release shall be effective regardless of whether such claims arise out of any former or future acts, contracts, engagements or liabilities of the other or by way of dower, curtsey, widow's or widower's rights, family exemption or similar allowance, or under the intestate laws or the right to take against the spouse's will, or the right to treat a lifetime conveyance by the other as testamentary or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory of the United States, or any other country. 11 D. Except for the obligations of the parties contained in this Agreement and such rights as are expressly reserved herein, each party gives to the other by the execution of this Agreement an absolute and unconditional release and discharge from all causes of action, claims, rights or demands whatsoever in law or in equity, which either party ever had or now has against the other. 12. ATTORNEY'S FEES. Each party shall be responsible for his or her counsel fees, costs and expenses, if any. Each of the parties hereby waives the right to receive counsel fees from the other. 13. BANKRUPTCY. Each party agrees that the provisions of this Agreement shall not be dischargeable in bankruptcy and expressly agreement to reaffirm any and all obligations contained herein as to the other party and indemnify and hold the other party harmless on all obligations of that party. 14. PRESERVATION OF RECORDS. Each party will keep and preserve for a period of four (4) years from the date of their divorce decree all financial records relating to the marital estate, and each party will allow the other party access to those records in the event of tax audits. 15. MODIFICATION. No modification, rescission, or amendment to this Agreement shall be effective unless in writing signed by each of the parties hereto. 16. SEVERABILITY. If any provision of this Agreement is held by a court of competent jurisdiction to be void, invalid or unenforceable, the remaining provisions hereof shall nevertheless survive and continue in full force and effect without being impaired or invalidated in any way. 12 17. BREACH. If either party hereto breaches any provision hereof, the other party shall have the right, at his or her election, to sue for damages for such breach, or seek such other remedies or relief as may be available to him or her. The non-breaching party shall be entitled to recover from the breaching party all costs, expenses and legal fees actually incurred in the enforcement of the rights of the non-breaching party as well as interest at a rate of six percent (6%) annually. 18. WAIVER OF BREACH. The waiver by one party of any breach of this Agreement by the other party will not be deemed a waiver of any other breach or any provision of this Agreement. 19. NOTICE. Any notice to be given under this Agreement by either party to the other shall be in writing and may be effected by registered or certified mail, return receipt requested. 20. APPLICABLE LAW. All acts contemplated by this Agreement shall be construed and enforced under the substantive laws of the Commonwealth of Pennsylvania (without regard to the conflict of law rules applicable in Pennsylvania) in effect as of the date of execution of this Agreement. 21. DATE OF EXECUTION. The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which the parties signed the Agreement if they do so on the same date, or if not on the same date, then the date on which the Agreement was signed by the last party to execute this Agreement. 22. EFFECTIVE DATE. This Agreement shall become effective and binding upon both parties on the execution date. 13 23. EFFECT OF RECONCILIATION. COHABITATION OR DIVORCE. This Agreement shall remain in full force and effect and shall not be abrogated even if the parties effect a reconciliation, cohabit as husband and wife or attempt to effect a reconciliation. This Agreement also shall continue in full force and effect in the event of the parties' divorce. There shall be no modification or waiver of any of the terms hereof unless the parties in writing execute a statement declaring this Agreement or any term of this Agreement to be null and void. 24. HEADINGS NOT PART OF AGREEMENT. Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. 25. AGREEMENT BINDING ON PARTIES AND HEIRS. This Agreement shall bind the parties hereto and their respective heirs, executors, administrators, legal representatives, assigns, and successors in any interest of the parties. 26. ENTIRE AGREEMENT. Each party acknowledges that he or she has carefully read this Agreement; that he or she has discussed its provisions with an attorney of his or her own choice, and has executed it voluntarily and in reliance upon his or her own attorney; and that this instrument expresses the entire agreement between the parties concerning the subjects it purports to cover and supersedes any and all prior agreements between the parties. This Agreement should be interpreted fairly and simply, and not strictly for or against either of the parties. 27. MUTUAL COOPERATION. Each party shall, on demand, execute and deliver to the other any deeds, bills of sale, assignments, consents to change of beneficiary designations, tax returns, and other documents, and shall do or cause to be done every other act or thing that 14 may be necessary or desirable to effectuate the provisions and purposes of this Agreement. If either party unreasonably fails on demand to comply with these provisions, that party shall pay to the other party all attorney's fees, costs, and other expenses actually incurred as a result of such failure. 28. AGREEMENT NOT TO BE MERGED. This Agreement may be incorporated into a decree of divorce for purposes of enforcement only, but otherwise shall not be merged into said decree. The parties shall have the right to enforce this Agreement under the Divorce Code of 1980, as amended, and in addition, shall retain any remedies in law or in equity under this Agreement as an independent contract. Such remedies in law or equity are specifically not waived or released. IN WITNESS WHEREOF, the parties hereto set their hands and seals on the dates of their acknowledgments. Michele Parker Patrick Parker 15 COMMONWEALTH OF PENNSYLVANIA S.S. COUNTY OF 00,R)6AGnAl : On this, the 2S day of r p , 2009, before me, a Notary Public, the undersigned offer, personally appeared Michele Parker, known to me or satisfactorily proven to be the person whose name is subscribed to the within Marriage Settlement Agreement, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. OOMMONWEN314 OF PENNMANIA NolerW SW Peeler & LbptM Notary PuNao C4fte Borough, CunbwkW Co" * C•w nWon Exphes Dso.12, 2011 16 r COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND S.S. On this, the ?r day of ()(?tA u ,l , 2009, before me, a Notary Public, the undersigned offer, personally appeared Patrick Parker, known to me or satisfactorily proven to be the person whose name is subscribed to the within Marriage Settlement Agreement, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. NOTARY PUBLIC N0 lm:-inion A E. STEEL, Mnwy hb& rg, 0A*ftJ od may, P, Exphis Ime 7,261 ( 17 , f ` ? , ? ? )? ?{ v ? ? S. ._ _ : ?tr +..? ? ? ? ? L ? ? id i1 L1 R ? r [ *? l ?I `?'. I? .. ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 08-1310 CIVIL State Commonwealth of Pennsylvania Co./City/Dist. Of CUMBERLAND Date of Order/Notice 04/01/10 Case Number (See Addendum for case summary) Employer/Withholder's Federal EIN Number CONSULATE HEALTH CARE 100 TANDEM VILLAGE RD CANONSBURG PA 15317-2382 RE See Addendum for dependent names and birth OOriginal Order/Notice OAmended Order/Notice XOTerminate Order/Notice OOne-Time Lump Sum/Notice MICHELE Employee/Obligor's Name (Last, First, MI) 235-13-9532 Employee/Obligor's Social Security Number 9585102018 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, MI) 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 unt I further notice even if the Order/Notice is not issued by your State. $ 0.00 $ $ 0.00 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 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 for a total of $ 0.00 per month to be forwarded to You do not have to vary your pay cycle to be in compliance witl the ordered support payment cycle, use the following to determi $ 0.00 per weekly pay period. $ 0-00 per biweekly pay period (every two weeks) ,rrears 12 weeks or greater? O yes ® no c? © 1 0 -0 t i% iayee below. the support order. If your pay cy l does--not mat to how much to withhold: C, tv > o . oo per semimonthly IV periad (twice a month) 0.00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding n 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 with held 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 b an electronic payment method if an employer is ordered to withhold income from more than one employee an employs 15 or more persons, or if an employer has a history of two or more returned checks due to nonsufficient unds. Please call the Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Servic 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 DEFENDAN 'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL S ECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. _07 LA , Z.O.,.4-0 BY THE COURT: DRO: R.J. Shadday Service Type M OMB No.: 0970-0154 H. Masland, Judge Form EN-028 Rev.5 Worker I D $ IATT ADDITIONAL INFORMATION TO EMPLOY RS AND OTHER WITHHOLDERS E] If 4hecke?i you are required to provide a copy of this form toy ur mployee. If yo4? r employee works in a state thatis event di the state that issued this order, a copy must be pr vied to your employee even if the box is not checked. 1. Priority: Withholding under this Order/Notice has priority over any oth r legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there re Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more t an one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identi the portion of the single payment that is attributable to each employee/obligor. 3.* Reporting the Paydate/Date of Withholding: You must report the payd te/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 respe 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. ou 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. 256890880 THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : HE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: I--] EMPLOYEE'S/OBLIGOR'S NAME: PARKER MICHELE EMPLOYEE'S CASE IDENTIFIER: 9585102018 LAST KNOWN HOME ADDRESS: LAST KNOWN PHONE NUMBER: NEW EMPLOYER'S TE OF SEPARATION: FINAL PAYMENT AMOUN 6. Lump Sum Payments: You may be required to report and withhold frog lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, cont ct 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 Pe nsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State n which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State la for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obli or because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the w of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) Protection Act (CCPA) 0 5 U.S.C. 1673 (b)); or 2) the amounts allowed by tl employment. Disposable income is the net income left after making mand Security taxes, statutory pension contributions and Medicare taxes. The Fe, supporting another family and 60% of the disposable income if the obligor increased to 55% and that 60% limit is increased to 65% if the arrears are g deduct a fee for administrative costs. The support amount and the fee may Arrears greater than 12 weeks : If the Order information does not indicat, employer should calculate the CCPA limit using the lower percentage. For allowed under the law of the issuing Tribe. For Tribal employers who recei the limit set by the law of the jurisdiction in which the employer is located CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State law, you ma care premiums in determining disposable income and applying appropriat( 10. Additional info: he amounts allowed by the Federal Consumer Credit e State or Tribe of the employee's/obligor's principal place of tory deductions such as: State, Federal, local taxes, Social eral limit is 50% of the disposable income if the obligor is s not supporting another family.However, that 50% limit is 'eater than 12 weeks. ?f permitted by the State, you may of exceed the limit indicated in this section. whether the arrears are greater than 12 weeks, then the ribal orders, you may not withhold more than the amounts e a State order, you may not withhold more than the lesser of it the maximum amount permitted under section 303(d) of the need to take into consideration the amounts paid for health withholding limits. *NOTE: If you or your agent are served with a copy of this order in the sta 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 by P.O. BOX 320 by CARLISLE PA 17013 y by Page 2 of 2 Service Type M OMB No.: 0970-0154 If y?u or your employee/obligor have any questions, on ct WAGE ATTACHMENT UNIT lone at (717) 240-6225 or at (717) 240-6248 or tet www.childsupport.state.pa.us Form EN-028 Rev.5 Worker ID $IATT Defendant/Obligor: PARKER, MICHELE PACSES Case Number 027110276 Plaintiff Name PATRICK PARKER Docket Attachment Amount 08-1310 CIVIL$ 0.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB DOB PA Docket Attachment Amount $ 0.00 hild(ren)'s Name(s): DOB Docket Attachment Amount $ 0.00 :hild(ren)'s Name(s): DOB Docket Attachment Amount $ 0.00 hild(ren)'s Name(s): DOB Addendum Form EN-028 Rev.5 Service Type M OMBNo.:0970-0154 Worker ID $IATT KER IN TH E COURT OF COMMON PLE@3 o i? MICHELE PAR , : Plaintiff : CUM BERLAND COUNTY, PEN A' 1 V. :NO. 08-1310 PATRICK PARKER 'CIVIL CTlON -LAW ._? , Defendant : IN DI ORCE c`,` to '" VTl N nFFFNnAWT's OF IDOVIT OF CC)NSFNT SAIDIS, LENDSM nnoxt?YS.nruw 26 West High Street Carlisle, PA 1. A Complaint in Divorce under § 301(c) of the Divorce Code was filed February 27, 2008. 2. The marriage of plaintiff and de endant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a final ecree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in knowledge, information and belief. I understa Affidavit are true and correct to the best of my that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to u Date: ( ;-,o 10 1. I consent to the entry of a final 2. 1 understand that I may lose i falsification to authorities. ATRICK of Divorce without notice. concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before divorce is granted. 3. 1 understand that I will not be Ivorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent tom immediately after it is filed with the Prothonotary. I verify that the statements made in his Affidavit are true and correct to the best of my knowledge, information and belief. i understa that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unswo n falsification to authorities. Date: A/1 / 1- 10 PA RICK PARKE MICHELE PARKER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2008 -1310 CIVIL TERM PATRICK PARKER, CIVIL ACTION - LAW -ca 1. February 27, 2008 in the Cumberland County Prothonotary's office. N CJ o-? cJa 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days (90) have elapsed from the date of filing and service of the Complaint. 3. I 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 i? 4 c_a r; _1 a false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. ?r Defendant IN DIVORCE` r AFFIDAVIT UNDER & 3301(c) OF THE DIVORCE CODE A complaint in divorce under § 3301(c) of the Divorce Code was filed sn Dater fLQx Michele Parker MICHELE PARKER, Plaintiff V. PATRICK PARKER, Defendant I. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008 -1310 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE :L's+ 0_l C.+:J 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 affidavit are true and correct. I understand that t'7 r?3 fil .:w.l false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: L ? CV,__4 Q p .c Michele Parker .?, r .. I consent to the entry of a final decree of divorce without notice. +`i MICHELE PARKER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2008 -1310 CIVIL TERM PATRICK PARKER, CIVIL ACTION -LAW Defendant IN DIVORCE PRAECIPE TO TRANSMIT THE RECORD ? v+ To the Prothonotary: Transmit the record, together with the following information, to the Cou r V Y il. 4ft Divorce Decree. 1. Ground for divorce: mutual consent and irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: acceptance of service signed by Defendant on March 13, 2008. 3(a). Date of execution of the affidavit required by § 3301(c) of the Divorce Code: By Plaintiff. April 1, 2010; By Defendant: April 1, 2010. 4. Related claims pending: None. 5(b). Date Waiver of Notice of Intention to Request Entry of Divorce Decree was filed the Prothonotary: By Plaintiff. April 6, 2010; By Defendant: April 5, 2010. Robert J. Dailey, E 'uire I.D. No. 203418 46 East Main Street Palmyra, PA 17078 Phone: (717) 838-5411 Fax: (717) 838-3047 Email: rdailev(a)?_)erberlawoffice.com Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF MICHELE PARKER CUMBERLAND COUNTY, PENNSYLVANIA V. PATRICK PARKER : NO 2008-1310 DIVORCE DECREE , it is ordered and decreed that AND NOW, 6 MICHELE PARKER plaintiff, and PATRICK PARKER , 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. The parties' marriage settlement agreement entered into on December 23, 2009 is hereby incorporated but not merged into this Final Decree in Divorce. tk? A-0 keA -vo h?*as