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HomeMy WebLinkAbout04-0412JANN E. STAPLETON, Plaintiff ANTOINE T. STAPLETON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. : 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 of other rights important to you, including the custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Office of the Prothonotary. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO, OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 JANN E. STAPLETON, Plaintiff ANTOINE T. STAPLETON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. O~- ,4~/D,,. ~; CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the Plaintiff, Jann E. Stapleton, by and through her attorney, Charles Rector, Esquire, and respectfully represents as follows: 1. Plaintiff is Jann E. Stapleton (SS# 316-70-3691), an adult individual, currently residing at 1440 Armitage Way, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. Defendant is Antoine T. Stapleton (SS# 311-68-1069), an adult individual, currently residing at 1440 Armitage Way, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for a period of six months (6) immediately preceding the filing of the Complaint. 4. 5. the parties. 6. America. Plaintiff and Defendant were married on October 26, 1995, in Jamaica. There have been no prior actions for divorce or for annulment between The Plaintiff and Defendant are both citizens of the United States of Count I - Divorce 7. The allegations of Paragraphs 1 through 6 are incorporated herein by reference and made a part thereof. 8. This action is not brought through collusion between the Plaintiff and Defendant, but in sincerity and truth for the reasons set forth within. 9. The marriage is irretrievably broken, and the parties are proceeding under Section 3301 (c) of the Divorce Code. 10. 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. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce decree dissolving the marriage between Plaintiff and Defendant. Count II - EQuitable Distribution 11. Paragraphs 1 through 10 of this Complaint are incorporated herein by reference as if set forth at length. 12. The parties have acquired, during the course of the marriage and prior to separation, property, both real and personal, which they own jointly or which was otherwise purchased so as to constitute marital property within the definition and scope of Section 3502 of the Divorce Code. WHEREFORE, Plaintiff requests your Honorable Court to enter an Order distributing the marital property owned by the parties. Count III - Spousal Support and/or Alimony Pendent Lite and Permanent Alimony 13. The allegations in Paragraph 1 through 12 are incorporated herein by reference and made a part hereof. 14. Plaintiff is unable to sustain herself during the course of this litigation. 15. Plaintiff lacks sufficient property to provide for her reasonable needs and is unable to sustain herself adequately through appropriate employment. t6. Plaintiff requests this Honorable Court to enter an award of spousal support and/or alimony Dendente lite in her favor pursuant to Section 3701 of the Divorce Code. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an award of spousal support and/or alimony I~endente lite until final hearing and thereupon to enter an order of alimony in her favor pursuant to Section 3701 of the Divorce Code. Count IV- Counsel Fees, Expenses and Costs of Suit 17. The allegations of Paragraphs 1 through 16 are incorporated herein by reference and made a part hereof, 18. Plaintiff has retained an attorney to prosecute this action and has agreed to pay him a reasonable fee, 19. Plaintiff has incurred and will incur costs and expenses in prosecuting this action. 20. Plaintiff is not financially able to meet the expenses and costs of prosecuting this action or the fees to which her attorney will be entitled in this case. 21. Plaintiff requests this Honorable Court to enter an award of interim counsel fees, costs and expenses until final headng and thereupon such additional counsel fees, costs and expenses as deemed appropriate. WHEREFORE, Plaintiff respectfully requests that, pursuant to Sections 3702 of the Divorce Code, the Court enter an Order directing Defendant to pay Plaintiff's reasonable counsel fees, costs and expenses. Count V - Custody 22. The allegations of Paragraphs 1 through 21 are incorporated herein by reference and made a part hereof. 23. Plaintiff is seeking primary physical custody of the minor child: Matthew Stapleton, who was bom on October 15, 1996. The child was not born out of wedlock. The child is presently in the custody of both parties. During the past five years, the child has resided with the following persons and at the following addresses: 24. currently resides with the following persons: Antoine T. Stapleton Matthew Stapleton With both parties at 1440 Armitage Way, Mechanicsburg, Pennsylvania. With both parties in Cave Creek, Arizona. With both parties in Draper, Utah. The relationship of the Plaintiff to the child is that of Mother. The Plaintiff Husband Son 25. The relationship of the Defendant to the child is that of Father. The Defendant currently resides with the following persons: Jann E. Stapleton Wife Matthew Stapleton Son 26. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 27. The best interest and permanent welfare of the child will be served by granting the Plaintiff pdmary physical custody. WHEREFORE, Plaintiff requests the Court to grant her primary physical custody of the minor child. Date: RESPECTFULLY SUBMITTED, Cttartes Rectqf, ~squire 1104 Fernwobd A~enue, Ste. 203 Camp Hill, PA 17011 (717) 761-8101 Attorney for Plaintiff I verify that the statements made herein are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Jann E. Stapleton Date: //J~/~ JANN E. STAPLETON, : Plaintiff/Petitioner : VS. : ANTOINE T. STAPLETON, : Defendant/Respondent : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 2004-412 CIVIL TERM IN DIVORCE Pacses# 710106153 ORDER OF COURT AND NOW, this 20th day of February, 2004, upon consideration of the attached Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shadday on March 18, 2004 at 9:00 A.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© (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, George E. Hoffer, President Judge Mail copies on Petitioner 2-20-04 to: < Respondent Charles Rector, Esquire Timothy Colgan, Esquire Date of Order: February 20, 2004 · J. ~thadday, Conference Officer YOU HAVE TIlE RIGHT TO A LAWYER, VCItO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE A LAVgYER 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 JANN E. STAPLETON, Plaintiff/Petitioner VS. ANTO1NE T. STAPLETON, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 2004-412 CIVIL TERM IN DIVORCE Pacses# 710106153 ORDER OF COURT AND NOW, this 19th day of March, 2004, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $3,435.68 and Respondent's monthly net income/earning capacity is $6,015.84, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $262.00 per month payable bi-weekly as follows; $115.38 for alimony pendente lite and $5.54 on arrears. First payment due next pay date at $120.92 bi-weekly. Arrears set at $500.00 as of March 19, 2004. The effective date of the order isJanuary 30, 2004. This order is based upon an agreement of the parties. Respondent is to pay 4.5% of any and all new bonuses directly to Petitioner within five days upon receipt of said bonus with verification of the amount of the bonus and Respondent is to copy the Domestic Relations Section with the same information. 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 heating, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the PA SCDU to: Jann E. Stapleton. 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 defendant's PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. Unreimbursed medical expenses that exceed $250.00 annually are to be paid 0% by the respondent and 100% by petitioner. The petitioner is responsible to pay the first $250.00 annually in unreimbursed medical expenses. Respondent to provide medical insurance coverage. Within thirty (30) days after the entry of this order, the Respondent shall submit written proof that medical insurance coverage has been obtained or that application for coverage has been made. Proof of coverage shall consist, at a minimum, of: 1) the name of the health care coverage provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims should be made; 5) a description of any restrictions on usage, such as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms. This Order shall become final ten days after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary for a heating de novo before the Court. DRO: R. J. Shadday Mailed copies on 3-19-04 to: < Petitioner Respondent Charles Rector, Esquire Timothy Colgan, Esquire BY THECOURT, Kevin A. Hess J. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY JANN E. STAPLETON, Plaintiff VS. ANTOINE T. STAPLETON, Defendant NO. 04-412 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE REOUEST FOR COUNSELING PURSUANT TO 23 Pa. C.S. §3302 and Pa. R. Civ. P. 1920.45 AND NOW COMES Antoine T. Stapleton, by and through his attorney, Timothy J. Colgan, Esquire, and files the following petition requesting counseling, and avers: 1. Petitioner is Antoine T. Stapleton, an individual residing at 1440 Armitage Way, Mechanicsburg, Cumberland County, Pennsylvania. 2. Respondent is Jann E. Stapleton, an individual residing at 62243 Gleim Court, Enola, Cumberland County, Pennsylvania. 3. A Divorce Complaint was filed by Plaintiff-Respondent on or about January 30, 2004, on the grounds of mutual consent, §3301(c). 4. Petitioner desires to attempt reconciliation and requests counseling under the provisions of the Divorce Code, 23 Pa. C.S. §3302. WHEREFORE, Petitioner requests your Honorable Court to require the maximum number of counseling sessions allowed by law. Date: By: Respectfully submitted WILEY, LENOX, COLGAN & MARZZACCO, P.C. Timothy ~~re 130 West Church Street, Suite 100 Dillsburg, PA 17019 (717) 432-9666 Supreme Court ID No. 77944 VERIFICATION I, Antoine T. Stapleton, verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: 3 '-/'9 -° ~( Antoine T. Stapleton IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY JANNE. STAPLETON, Plaintiff VS. ANTOINE T. STAPLETON, Defendant NO. 04-412 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Timothy J. Colgan, Esquire hereby certify that I am this day serving a copy of the foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same postage prepaid in the United States First Class Mail as follows: Charles Rector, Esquire 1104 Fernwood Avenue Suite 203 Camp Hill, PA 17011 Date: '~'/~'~/ By: WILEY, LENOX, COLGAN & MARZZACCO, P.C. Timot~h~e 130 West Church Street, Suite 100 Dillsburg, PA 17019 (717) 432-9666 ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsvlvanla Co./City/Dist of CUMBER~TD Date of Order/Notice 03/19/04 Tribunal/Case Number (See Addendum for case summary) Q~) Original Order/Notice O Amended Order/Notice O Terminate Order/Notice Employer/VVithholder's Federal EIN Number RITE AID CORPORATION* PO BOX 3165 HARRISBURG PA 17105-3165 RE:STAPLETON, ANTOINE T. Employee/Obli§or'sName(Last, Fi~t, Mi) 311-68-1069 £mployee/Obligor'sS~ialSecuri~ Number 429410~285 Date of Order: ~ ~_. Service Type M OMB NO.: 09704)154 Form EN-028 Worker ID $ IATT ,~,,~/ ~Z~ ~ ~,~ Employee/Obligor's Case Identifier ~ ~ ~/~ ~ ($ee Addendum f~ plaintiff names associated with cases on attachment) ~-],/~' ,~:~'Z/. g//~ c';///7'/-- 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 ~ssued by your State. $ 1,050. oo per month in current support $ 50. oo per month in past-due support Arrears 12 weeks or greater? Oyes (~) no $ 0. oo per month in medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ 1,100.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the suppo~t order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 253,85 per weekly pay period. $ 507,69 per biweekly pay period (every two weeks). $ 550. oo per semimonthly pay period (twice a month). $ ~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 tl%e work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #10 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown aDb~ve as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. NOT SEND CASH BY MAIL. ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS [] If checke~d you are required to provide a copy of this form to your~mployee. If yogr employee worlds in a state thaI is different trom the state that issued this order, a copy must be proviaed to your empmyee even if the nox is not checked. 1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indiamowned businesses located on a reservation that choose to withhold in accordance with this notice. 2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of th is order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. uoy .........................~ ..................... an~,~ua, was ...................... u,,~'. ....... ~=~. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 5.* Employee/Obligor with Multiple Support Holdings: If them is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #10 below) 6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S ID: 2319406520 EMPLOYEE'S/OBLIGOR'S NAME: STAPLETON, ANTOINE T. EMPLOYEE'S CASE IDENTIFIER: 429410'128S DATE OF SEI?ARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for' both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law govems unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed govems. 10.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. § 1673 (b)l; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 1 1. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-624(J or by intemet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Service Type M OMSNo.:097~0154 WorkerlD $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: STAPLETON, A~TOINE T. PACSES Case Number 635106250 Plaintiff Name JANN E. STAPLETON Docket Attachment Amount 00245 S 2004 $ 838.00 Child(ren)'s Name(s): MATTHEW M. STAPLETON DOB PACSES Case Number 710106153 Plaintiff Narr~ J~%TN E. S;TAPLETON Docket Attachment Amount 04-412 CIVIL $ 262.00 Child(ren)'s Name(s): DOB ~]if checked you are mqu red to enroll the ch d(ren) dentified above in any health insurance coverage available through the employee's/obligor's employment. l-hr checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ o.oo Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB [] If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.o0 Child(ren)'s Name(s): DOB [] If checked, you are required to enroll the child(ten) identified above in any health insurance coverage available through the employee's/obligor's employment. pACSES Case Number .Plaint ff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB []If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. []If checked you are requ red to enro the child(ren) dentified abov~ in any health insurance coverage available through the employee's/obligor's employment. Addendum Service Type M Form EN-028 OMB No.: 0970-0154 Worker ID $IATT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY JANN E. STAPLETON, ANTOINE T, STAPLETON, Plaintiff VS. Defendant NO. 04-412 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE ORDER AND NOW, this ~ · ~ day of t'na~-gaL ,2004, it is ordered that the parties undergo ~ counseling sessions with a qualified professional to be selected by them. If the parties are unable to agree, is appoimed. The counselor shall provide the Court with a report at the end of the time set for counseling stating whether or not the parties attended. Counseling must be completed no later than ~ 0 ,:ffa./.c , unless the parties agree to a longer period. While counseling is being pursued the action in divorce shall be stayed. BY THE COURT: 03 .,.q.5 - O ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dist of CUMBERLAND Date of Order/Notice 08/23/04 Tribunal/Case Number (See Addendum for case summary) O Original Order/Notice {~ Amended Order/Notice O Terminate Order/Notice Employer/Withholder's Federal EIN Number RITE AID CORPORATION* PO BOX 3165 HARRISBURG PA 17105-3165 RE:STAPLETON, AI~TOINE T, Employee/Obligor's Name (Last, First, MI) 311-68-1069 Employee/Obligor's Social Security Number 4294101285 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodiar Parent's Name (Last, First, MI) See Addendum for dependent names and birth dates associated with cases on attachmenL ORDER INFORMATION: This is an Order/Notice to Withhold Income for :Support based upon an order for support from CUMBERnAND County, Commonwealth of Pennsylvania. By law, you am 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. $ 1,050.00 per month in current support $ 12 . 00 per month in past-due support Arrears12 weeks or greater? Oyes (~) no $ 0.00 per month in medical support $ o. oo per month for genetic test costs $ per month in other (specify) for a total of $ 1,062. O0 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: $ ~per weekly pay period. $ 490.15 per biweekly pay period (every two weeks). $ 531. oo per semimonthly pay period (twice a month). $ 1. 062. oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten {10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/obJigor's aggregate disposable weekly earnings. For the purpose of the limitation on 'withholding, the following information is needed (See #10 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. Date of Order:~~l Service Type M OMB NO.: 097C~0154 Form EN-028 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS [] If checked you are required to prgv de a copy of this form to yourem~ oyee. If your employee works in a state that is different trom the state that issuedthis order, a copy must be prov dec[ to your employee even fthe box is not checked. 1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned businesses located on a resewation that choose to withhold in accordance with this notice. 2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. ~,oy,~,,,~,,,,,~ ~,, ,,,,,,,,,~,,~,,,~ ,~ ,,,~ ,,o~ ,,,, ,,,,,,~,, ,,,,,,,,~,,, ,,o~ ,,,,,,,~,,~ ,,,~,,, ~,,~ ~,,,~,,,~y~ ~ ,,,,~. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. .5.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Fecleral or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #10 below) 6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S ID: 2319406520 EMPLOYEE'S/OBLIGOR'S NAME: STAPLETON, ANTOINE T. EMPLOYEE'S CASE IDENTIFIER: 429410198S DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs urdess the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 10.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. § 1673 (b)l; or 2) the amounts allowed by the State of the ernployee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 11. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone al: (71 7) 240-6225 or by FAX at (717~ or by internet www.childsupportstate.pa.us Page 2 of 2 Form EN-028 Service Type M OM~ No.:09704)154 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: STAPLETON, ANTOINE T. PACSES Case Number 635106250 Plaintiff Name JASTN E. STAPLETON Docket Attachment Amount 00245 S 2004 $ 800,00 Child(ren)'s Name(s): MATTHEW M. STAPLETON DOB PACSES Case Number 710106153 Plaintiff Name JASrN E. STAPLETON Docket Attachment Amount 04-412 CIVIL $ 262.00 Child(ren)'s Name(s): DOB I~lf checked, you are required to enroll the child ren) identified above in any health nsurance coverage available through the employee's/obligor's employment. l-Jif checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the ernployee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.o0 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB [] If checked, you are requital to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. [] If checked, you are required to enroll the ch d ren) identified above in any health nsurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Chi[d(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ o.oo Child(ren)'s Name(s): DOB [] If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. [] If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. Addendum Form EN-028 Service Type PI OMBNo.:0970-0154 Worker ID $IATT JANN E. STAPLETON, Plaintiff ANTOINE T. STAPLETON, Defendant · IN THE COURT OF: COMMON PLEAS OF · CUMBERLAND cOUNTY, PENNSYLVANIA : : NO. 04-412 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENI.~ 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on January 30, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3, I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree, WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE. 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if i do not claim ti3em 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, ~ verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Antoine T. Stapleton Date:_ JANN E. STAPLETON, Plaintiff ANTOINE T. STAPLETON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 04-412 CIVIl_ TERM : : CIVIL ACTION - I_AW : iN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 30, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 33011[c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do flo[ 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 rne immediately after it is filed with the Prothonotary. I verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Jann E. Stapleton JANN E. STAPLETON, Plaintiff ANTOINE T. STAPLETON, Defendant IN THE COURT .OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-412 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERI/ICE I, Timothy J. Colgan, Esquire, counsel for the Defendant, Antoine T. Stapieton, accept service of the Complaint in Divorce, received on /~¥v,~.//ol ~z~y and certify that I am authorized to do so. Date: Timothy J. C~.~,_~sflu~re MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT made this [~ ~ day of ~ i,~,~ ~,.~3~' between JANN E. STAPLETON(WIFE) and ANTOINE T. STAPLETON (HUSBAND) ,2004, by and WlTNESSETH: WHEREAS, the parties hereto are HUSBAND and WIFE, having been married on October 26, 1995, in Jamaica. There was one (1) child bom of this marriage: Matthew M. Stapleton (DOB 10/15/96). WHEREAS, diverse and unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of HUSBAND and WIFE to live separate and apart for the rest of their natural lives, and 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 by specification: the settling of all matters between them relating to the ownership and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present and future support, alimony and/or maintenance of WIFE by HUSBAND or of HUSBAND by WIFE; and in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. NOW, THEREFORE, in consideration of the premises and mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, WIFE and HUSBAND, each intending to be legally bound hereby, covenant and agree as follows: 1. .INCORPORATION OF PREAMBI F The recitals set forth in the Preamble of this Agreement are incorporated herein and made a part hereof as if fully set forth in the body of the Agreement. 2. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS. This Agreement shall not be considered to affect or bar the rights of HUSBAND and WIFE to an absolute divorce on lawful grounds if such grounds now exist or shall hereafter exist or to such defense as may be available to either party. This Agreement is not intended to condone and shall not be deemed to be condonation on the part of either party hereto of any act or acts on the part of the other party which have occasioned the disputes or unhappy differences which have occurred or may occur subsequent to the date hereof. The parties acknowledge that their mardage is irretrievably broken and that they shall secure a mutual consent no-fault divorce pursuant to the terms of Section 3301(c) of the Divorce Code in WIFE's Cumberland County divorce action docketed to number 04-412. Upon the signing of this Agreement, the parties shall execute and file all documents and papers, including affidavits of consent, necessary to finalize said divorce. 3. .EFFECT OF DIVORCE DECREE. The parties agree that unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final Decree in Divorce may be entered with respect to the parties. 4. AGREEMENT TO BE INCORPORATED IN DIVORCE DECRF; The parties agree that the terms of this Agreement shall be incorporated into any Divorce Decree which may be entered with respect to them. 5. NON-MERGER. It is the parties' intent that this Agreement does not merge with the Divorce Decree, but rather shall continue to have independent contractual significance. Each party maintains his or her contractual remedies as well as court ordered remedies as the result of the aforesaid incorporation or as otherwise provided by law or statute. Those remedies shall include, but not be limited to, damages resulting from breach of this Agreement, specific enforcement of this Agreement and remedies pertaining to failure to comply with an order of court or agreement pertaining to equitable distribution, alimony, alimony pendente lite, counsel fees and costs as set forth in the Pennsylvania Divome Code or other similar statutes now in effect and as amended or hereafter enacted. 6. DATE OF EXECUTION The 'date of execution" or "execution date' of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 7. DISTRIBUTION DATE. The transfer of property, funds and/or documents provided for herein shall only take place on the "distribution date' which shall be defined as the date of execution of this Agreement unless otherwise specified herein. 8. ADVICE OF COUNSEL. The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, Charles Rector, Esquire for WIFE, and Timothy J. Colgan, Esquire, for HUSBAND. The parties acknowledge that they have received independent legal advice from counsel of their selection and that they fully understand the facts and have been fully informed as to their legal rights and obligations and they acknowledge and accept that this Agreement is, in the circumstances, fair and equitable and that it is being entered into freely and voluntarily, after having received such advice and with such knowledge and that execution of this Agreement is not the result of any duress or undue influence and that it Js not the result of any collusion or improper or illegal agreement or agreements. 9. FINANCIAL DISCLOSURF The parties confirm that each party has made a full and fair disclosure to the other of all of their assets, debts and incomes and that each has relied on the substantial accuracy of the financial disclosure of the other, as an inducement to the execution of this Agreement. 10. DISCLOSURE AND WAIVER OF PROCEDURAL RIGHTS. Each party understands that he or she has the right to obtain from the other party a complete inventory or list of all of the property that either or both parties own at this time or owned as of the date of separation, and that each party has the right to have all such property valued by means of appraisals or othen~vise. Both parties understand that they have the right to have a court held hearings and make decisions on the matters covered by this Agreement. Both parties understand that a court decision concerning the parties' respective rights and obligations might be different from the provisions of this Agreement. Each party hereby acknowledges that this Agreement is fair and equitable, that it adequately provides for his or her needs and is in his or her best interests, and that the Agreement is not the result of any fraud, duress, or undue influence exercised by either party upon the other or by any other person or persons upon either party. Both parties hereby waive the following procedural rights: a. The right to obtain an inventory and appraisement of all marital and non- marital property as defined by the Pennsylvania Divorce Code. 4 b. The right to obtain an income and expense statement of the other party as provided by the Pennsylvania Divorce Code. Procedure. The right to have property identified and appraised. The right to discovery as provided by the Pennsylvania Rules of Civil e. The right to have the court determine which property is marital and which is non-marital, and equitably distribute between the parties that property which the court determines to be marital, and to set aside to a party that property which the court determines to be that parties' non-marital property. f. The right to have the court decide any other rights, remedies, privileges, or obligations covered by this Agreement and/or arising out of the marital relationship, including but not limited to possible claims for divorce, child or spousal support, alimony, alimony Pendente Lite (temporary alimony), equitable distribution, custody, visitation, and counsel fees, costs and expenses. 11. PERSONAL PROPERTY. The parties agree that in addition to the items already in WIFE' s possession, WIFE shall receive as her sole and separate property the items contained on Exhibit 'A" attached hereto. WIFE shall arrange for pick up said items, which items shall be made available by HUSBAND, at his home, within thirty (30) days of the date of execution of this Agreement. Except for the items identified on Exhibit "A," the parties acknowledge that they have previously agreed to a division of all of their tangible personal property including, but not limited to, jewels, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, tools, pictures, books, works of art and other tangible personal property. With respect to said division the parties agree that HUSBAND shall receive as his sole and separate property all items currently in his possession and WIFE shall receive as her sole and separate property all items of tangible personal property in her possession. Each of the parties hereto does waive, release, and forever abandon any dght and all title, interest and claim, in and to the tangible personal property to become the property of the other party pursuant to the terms of this paragraph. 12. AFTER-ACQUIRED PROPERTY Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all property, tangible or intangible, real, personal or mixed, acquired by him or her, with or without non-marital assets, after the date of this Agreement, with full power Jn him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried and each party hereby waives, releases, renounces and forever abandons any dght, title, interest and claim in and to said after acquired property of the other party pursuant to the terms of this paragraph. 13. .DIVISION OF VEHI~;=$, With respect to the vehicles owned by one or both of the parties, or the net proceeds or value derived from any prior sale or trade in thereof, they agree as follows: WIFE waives all right, title and interest she may have in and to the Harley Davidson Motorcycle and Toyota Tundra to HUSBAND. In consideration therefore, HUSBAND agrees to assume sole responsibility for all costs associated with both vehicles including, but not limited to, the motorcycle loan due and owing to Community Bank and he shall indemnify and save WIFE harmless from any such debts or obligations arising from the vehicles. HUSBAND waives all right, title and interest he may have in and to the Toyota Highlander to WIFE and WIFE shall assume full responsibility for all debts and costs associated with this vehicle including, but not limited to, the loan obligation due and owing to Chase Manhattan Bank and she shall indemnify and save harmless HUSBAND from the payment of any such cost or expense. The titles or assignment of any lease agreements to said vehicles shall be executed by the parties, if appropriate, for effectuating transfer as herein provided on the date of execution of this Agreement and said executed titles/assignments shall be delivered to the proper party on the distribution date. For purposes of this Paragraph the term "title" shall be deemed to include 'power of attomey" if the title or lease agreement to the vehicle is unavailable due to financing arrangements or otherwise. In the event any vehicle is subject to a lien, encumbrance, lease or other indebtedness in the party receiving said vehicle as his or her property shall take it subject to said lien, encumbrance, lease or other indebtedness and shall be solely responsible therefor and said party further agrees to indemnify, protect and save the other party harmless from said lien, encumbrance, lease or other indebtedness. Each of the parties hereto does specifically waive, release, renounce and forever abandon whatever right, title and interest he or she may have in the vehicle(s) that shall become the sole and separate property of the other pursuant to the terms of this Paragraph. 14. plVlSION OF REAL ESTATE. WIFE agrees to transfer all right, title and interest which she may have in the marital property located at 1440 Armitage Way, Mechanicsburg, Cumberland County, Pennsylvania, 17050, and any improvements thereon, to HUSBAND and releases all claims which she may have regarding said real estate in accordance with this Paragraph, and in consideration for the monetary payment due and owing to her pursuant to Paragraph 15. HUSBAND agrees to assume sole responsibility for payments on all mortgages on said property, as well as all real estate taxes, insurance, and any maintenance and repair costs, and he shall indemnify and save WIFE harmless from any such obligations. In furtherance of the transfer of all right, title and interest in said real estate, WIFE hereby agrees to execute a deed conveying her interest in the property to HUSBAND. HUSBAND agrees to refinance the existing mortgage obligations on the property and thereby remove WIFE's name from said obligations. Legal counsel for WIFE shall prepare the necessary Deed and hold the signed document in escrow until such time as necessary for HUSBAND's refinance, and payment to WIFE pursuant to Paragraph 15, at which time the Deed shall be filed on record with the Cumberland County Recorder of Deeds. In the event that HUSBAND fails and/or refuses to refinance the existing mortgage obligations within thirty (30) days from the date of this Agreement, the real estate shall be immediately listed for sale and shall remain listed with a certified real estate broker until sold. If the parties ara unable to agree upon a list price, each shall obtain a market appraisal on the home and in the event that neither market appraisal is acceptable to both parties, the initial list price shall be the average of both appraisals. Neither party shall unreasonably withhold authority to sell the home if a bona fide good faith offer is made at or near the list price. Following sale, WIFE shall receive the first $27,000.00 of net proceeds at settlement and the remaining proceeds, if any, shall be divided equally between the parties. In the event that sale of the home yields net proceeds which total less than $27,000.00, HUSBAND shall be responsible for payment to WIFE of the difference between the net proceeds received and $27,000.00, which balance will be due and owing within fourteen (14) days of the real estate settlement. In addition to said $27,000.00, payment to WIFE, HUSBAND shall assume sole responsibility for any net loss resulting from the sale of the real estate and he shall indemnify and save WIFE harmless from any such loss. 15. MONETARY PAYMENT. In consideration of the distribution of the marital assets set forth in this Agreement, and in further consideretion of WIFE's waiver of her interest in the marital home, HUSBAND agrees to pay WIFE the lump sum of $27,000.00 in one non-taxable equitable distribution payment upon refinancing of the mortgage obligations as required by Paregraph 14 of this Agreement. The lending institution providing refinancing to HUSBAND to facilitate the terms of this Agreement may require the tendering of the Deed by WIFE's attorney before the actual payment. WIFE agrees to cooperate with whatever requirements HUSBAND's lender has in this regard. 16. .EACH PARTY RETAINS PENSION PLANS. Each of the parties does specifically waive, release, renounce and forever abandon all of his or her right, title, interest or claim, whatever it may be, in any Pension Plan, Retirement Plan, Profit Sharing Plan, 401-K Plan, Keogh Plan, Stock Plan, Tax Deferred Savings Plan and/or any employee benefit plan of the other party, whether acquired through said party's employment or otherwise, and hereafter said Pension Plan, Retirement Plan, Savings Plan, Tax Deferred Savings Plan and/or any employee benefit plan shall become the sole and separate property of the party in whose name or through whose employment said plan is carried. 17. plVlSlON OF BANK ACCOUNTS/STOCK/LIFE INSURANCF The parties acknowledge and agree that they have previously divided to their mutual satisfaction ail of their bank accounts, brokerage accounts, certificates of deposit, IRA accounts, bonds, shares of stock, investment plans and life insurance cash value and hereafter WIFE agrees that all said bank accounts, certificates of deposit, iRA ac. counts, bonds, shares of stock, investment plans and life insurance cash value in the possession of HUSBAND shall become the sole and separate property of HUSBAND and HUSBAND agrees that all said bank accounts, certificates of deposit. IRA accounts, bonds, shares of stock, investment plans and life insurance cash value in the possession of WIFE shall become the sole and exclusive property of WIFE. Each of the parties does specifically waive, release, renounce and forever abandon whatever right, title, interest or claim, he or she may have in any bank account, brokerage account. certificates of deposit, IRA account, bonds, shares of stock, investment plans and life insurance cash value that is to become the sole and separate property of the other pursuant to the terms hereof. 18. MARITAL DEBTS. The parties acknowledge that they have previously divided the obligations and payments required thereof of any debts and obligations arising dudng the mardage and in accordance therewith any obligation being paid by a party shall continue to be so paid and said party shall indemnify, protect and save the other party harmless therefrom. A liability not disclosed in this Agreement will be the sole responsibility of the party who has incurred or may hereafter incur it, and each agrees to pay it as the same shall became due. Each party agrees to indemnify and hold the other party and his or her property harmless from any and all such debts, obligations and liabilities assumed by a party pursuant to this Paragraph. From the date of execution of this Agreement, each party shall use only those credit cards and accounts for which the party is individually liable and the parties agree to cooperate in closing any remaining accounts which provide for joint liability. 19. WAIVER OF INHERITANCF Each of the parties hereto does specifically waive, release, renounce and forever abandon any right, title, interest or claim, if any, either party may have in and to any 10 inheritance of any kind or nature whatsoever previously or in the future received by the other party. 20. WIFE'S DEBTS. WIFE represents and warrants to HUSBAND that since the parties' madtal separation she has not contracted or incurred any debt or liability for which HUSBAND or his estate might be responsible and WIFE further represents and warrants to HUSBAND that she will not contract or incur any debt or liability after the execution of this Agreement, for which HUSBAND or his estate might be responsible. WIFE shall indemnify and save HUSBAND harmless from any and all claims or demands made against him by reason of obligations incurred by her. 21. HUSBAND'S DEBTS. HUSBAND represents and warrants to WIFE that since the parties' madtal separation he has not contracted or incurred any debt or liability for which WIFE or her estate might be responsible and HUSBAND further represents and warrants to WIFE that he will not contract or incur any debt or liability after the execution of this Agreement, for which WIFE or her estate might be responsible. HUSBAND shall indemnify and save WIFE harmless from any and all claims or demands made against her by reason of debts or obligations incurred by him. 22. BANKRUPTCY The parties hereby agree that the provisions of this Agreement shall not be dischargeable in bankruptcy consistent with 11 USC 52(a)5 and expressly agree to reaffirm any and all obligations contained herein. In the event a party files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party shall have the right to terminate this Agreement in which event the division of the parties' marital assets and all other rights determined by this ]! Agreement shall be subjected to court determination the same as if this Agreement had never been entered into. 23. SOCIAL SECURITY BENEFITS. The parties agree that subject to the rules and regulations of the Social Security Administration, each of the parties shall continue to be eligible for Social Security benefits to which he or she would ordinarily be qualified as a parbj to a divorce after a marriage of ten (10) years or more in duration, if the parties' marriage is determined to be of ten (10) or more years in duration. 24. INCOME TAX PRIOR RETURNS. The parties have heretofore filed joint federal and state 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 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 extent of his or her separate income on the aforesaid joint retums. 25. FINAL ECIUITABLE DiSTR_!_RUTiON OF PROPERTY. The parties agree that the division of all property set forth in this Agreement is equitable and in the event an action in divorce is commenced [and/or finalized], both parties relinquish the right to divide said property in any manner not consistent with the terms set forth herein. It is further the intent, understanding and agreement of the parties that this Agreement is a full, complete and equitable property division. 26. WAIVER OF ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL .SUPPORT~ COUNSEL F_FI=S, MAINTENANCE AND COSTS. The parties hereto.agree and do hereby waive any right and/or claim they may have, both now and in the future, against the other for alimony, alimony ~. spousal support, maintenance, counsel fees and costs. The parties further agree that the current Order of Alimony Pendente Lite paid by HUSBAND to WIFE through the Domestic Relations Office of Cumberland County and docketed at 2004-412 (PACSES # 710106153) shall terminate effective upon the date of issuance of the Divorce Decree. Any and all arrears due and owing on this account shall be paid directly by HUSBAND to WIFE within fourteen (14) days of the date of issuance of the Divorce Decree. HUSBAND shall, through his counsel, notify the Domestic Relations Office of the date of issuance of the parties' Decree in Divorce to effectuate the terms of this Paragraph. 27. CHILD SUPPORT. The parties agree to sign a stipulation for child support to be entered as an Order of Court docketed at 245 S 2004 (PACSES 635106250), ordering HUSBAND to pay WIFE, as and for child support, $838.00 per month payable bi-weekly with $800.00 per month payable for current support and $38.00 per month payable on arrears. The parties acknowledge and agree that said Order of Child Support paid by HUSBAND to WIFE shall, from time to time, be adjusted upward or downward in accordance with substantial changes in the respective incomes of the parties and/or the needs of their child. 28. COLLEGE FUND. In further consideration of the distribution of marital assets as set forth in this Agreement, HUSBAND agrees to establish a college education fund for the benefit of the parties' minor child, Matthew M. Stapleton (DOB 10/15/96), within thirty (30) days of the date of execution of this Agreement, which college fund shall be funded as follows: 13 a. HUSBAND shall make an initial contribution of $25,000.00; and b. Each of the parties shall contribute no less than $75.00 per month to said educational account, which monthly contributions shall continue until a sufficient balance has accumulated to fund the cost of the minor child's undergraduate college education, to include payment of, but not be limited to the following: tuition, mom and board, books, supplies, fees, transportation and clothing. In no event shall either parties' contributions extend beyond the minor child's twenty-fifth (25th) birthday. HUSBAND agrees to assume sole responsibility for the maintenance of said account and shall provide monthly statements to WIFE to include, but not be limited to, investment summaries and/or account balance statements. The parties further acknowledge and agree that none of the principal or interest derived from said account shall be substituted for or credited to HUSBAND's existing child support obligation. In the event that the minor child chooses to not attend college and/or voluntarily withdraws prior to the completion of his undergraduate education, or the account balance exceeds the college costs, the balance remaining in the college account shall be divided equally between the parties. In the event that the accumulated balance in the college fund account is insufficient to cover the above-described college costa of the minor child, the parties agree to each contribute one-half (1/2) of any additional amounts due and owing to finance the costs of said undergraduate education. 29. CUSTODY. The parties agree that WIFE shall be primary physical custodian of the parties minor child Matthew M. Stapleton (DOB 10/15/96). Legal custody shall be shared by the parties, with HUSBAND having periods of temporary physical custody in alternating weeks from Tuesday after school through the following Sunday at 7:00 p.m. The party Hu~A~ ~ Wlf=~. 14 receiving custody shall be responsible for transportation. The parties agree to alternate Thanksgiving and Christmas and may agree to further holidays as the need arises. The parties agree that in the event of a relocation which would substantially impair or alter the current custody arrangement, the party relocating agrees to attempt to obtain the consent of the non-relocating party or shall obtain an order of court regarding relocation prior to such relocation consistent with the laws in the Commonwealth of Pennsylvania then in effect regarding relocation. 30. PERSONAL RIGHTS. HUSBAND and WIFE may and shall, at all times hereafter, live separate and apart. They shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if they were unmarried. They may reside at such place or places as they may select. Each may, for his or her separate use or benefit, conduct, carry on and 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 or the respective families of 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. Except that the parties acknowledge that relocation by the custodial parent shall only be accomplished with the consent of the parties or by order of court. 31. MUTUAL RELEASES. HUSBAND and WIFE each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, from any and all rights, title and interest, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or courtesy, or claims Jn the nature of dower or courtesy or 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 surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) the Commonwealth of Pennsylvania, (b) State, Commonwealth of territory of the United States, or (c) any other country, or any rights which either party may have or at any time hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, equitable distribution, costs or expenses, whether arising as a result of the marital relation or otherwise, except, and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is the intention of HUSBAND and WIFE to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may adse under this Agreement or for the breach of any previsions thereof. 32. WAIVER OR MODIFICATION TO BE IN WRITING. No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 16 33. MUTUAL COOPERATION. Each party shall, at any time and from time to time hereafter, take any and all steps and execute, acknowledge and deliver to the other party, any and all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this ^greement. 34. AGREEMENT BINDING ON HEIRS. This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 35. INTEGRATION. This Agreement constitutes the entire understanding of the parties and supersedes any and all pdor agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. 36. OTHER DOCUMENTATION. WIFE and HUSBAND covenant and agree that they will forthwith (and within at least twenty (20) days after demand therefor), execute any and all written instruments, assigns, releases, satisfactions, deeds, notes, stock certificates, or such other writings as may be necessary or desirable for the proper effectuation of this Agreement, and as their respective counsel shall mutually agree should be so executed in order to carry out fully and effectively the terms of this Agreement. 37. NO WAIVER OF DEFAULT. This Agreement shall remain in full fome and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon stdct performance of any of the provisions of this Agreement shall in no way affect the right to such party hereafter to enforce the same, nor shall the waiver of any 17 subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. 38. BREACH. If for any reason either HUSBAND or WIFE fails to perform his or her obligations hereunder owed to or for the benefit of the other party and/or othe~vise breaches the terms of this Agreement, then the other party shall have the following rights and remedies, all of which shall be deemed to be cumulative and not in the alternative, unless said cumulative effect would have an inconsistent result or would result in a windfall to the other parbj. (a) the right to specific performance of the terms of this Agreement, in which event the non-breaching party shall be reimbursed for all reasonable attorney's fees and costs incurred as the result of said breach and in bringing the action for specific performance. (b) the right to damages arising out of the breach of the terms of this Agreement, which damages shall include reimbursement of all attorney's fees and costs incurred as the result of the breach and in bringing the damage action. (c) the right to all remedies set forth in Section 3502(e) of the Pennsylvania Divorce Code, 23 Pa.C.S.A. 3502(e), and any additional rights and remedies that may hereafter be enacted by virtue of the amendment of said Section or replacement thereof by any other similar laws, which remedies shall include, but not be limited to: (1) the entry of judgement; (2) the authorization of the taking and seizure of goods and chattels and collection of rents and profits of real and personal and tangible and intangible property; (3) the transfer and sale of any property required to obtain compliance with the obligations undertaken by this Agreement; (4) the posting of security to insure future payments to assure compliance with the obligations undertaken by this Agreement; (5) the issuance of attachment proceedings and the holding of the Defendant to be in contempt and the making of appropriate order thereof including, but not limited to, commitment of the breaching party to county jail for a period not to exceed six (6) months; (6) the award of counsel fees and costs; (7) the attachment of the breaching party's wages. (d) Any other remedies provided for in law or in equity. 39. SEVERABIMTY If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet his or her obligations under any one or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. 40. LAW OF PENNSYLVANIA APPLICABLE. This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 41. HEADINGS NOT PART OF AGREEMENT. Any heading 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. BY SIGNING THIS AGREEMENT, EACH PARTY ACKNOWLEDGES HAVING READ AND UNDERSTOOD THE ENTIRE AGREEMENT, AND EACH PARTY ACKNOWLEDGES THAT THE PROVISIONS OF THIS AGREEMENT SHALL BE AS BINDING UPON THE PARTIES AS IF THEY WERE ORDERED BY THE COURT AFTER A FULL HEARING. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. WITNESS: , · ' ...... Antoine T. Stapleton 2o STATE OF PENNSYLVANIA ( ( COUNTY OF CUMBERLAND ( SS. On this, the \~'~'~day of , 2004, before me the undersigned officer, personally appeared Jann E. Stapl'~on known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposed therein contained. IN WITNESS WHEREOF, I have hereunto set me hand and seal. STATE OF PENNSYLVANIA ( ,, ( COUNTY OF this, the /~?~ayof ,~..~/.<~ ~ ,2004 before me the undersigned officer, On personally appeared Antoine T. Stapleton known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposed therein contained. IN WITNESS WHEREOF, I have hereunto set me hand and seal. Notarial Seal S. Dawn Gladfeller, Notary Public Dillsbur,g Bom. York County My Commiss,on Expires May 17, 2005 Meml~r, Pennsylvanm Assocmbo~ ot Notarms 21 ~..:.:..:...: ~ ....... Jeming room ,, ' - ' 1.'.-~:'_::--~- ----= --; ....... '"_~"' ?."' ~,.'~ lertlfro house .............. j*~. .............. a,, u,~;uranons Ii,yen oF my mom or family or pucha,~c~ ~' '! .................... ~- ................. ,i .-b:~:,,b~ & 2,~'~u.....:. <:....? ...... ....:: .... . .... ... :. ...... I .:'"':- ....... ~elt'8 bike .......... · ' ' ...... "::' : ~'. ....?l~.~Opm ..,::....'./.. '!...,.....~':..: .:.:.: .~(: .~..........: ... ':" ............. ' I~'~~e ..... Ix" "' orie~lnl.ru~.~. ~. ;...... :.:. 2."...: .... :':" ' *:'~' "'<~ ~.'X .... ' JANN E. STAPLETON, Plaintiff V. ANTOINE T. STAPLETON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 00-412 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORn To the Prothonotary: Transmit the record together with the following information, to the Court for entry of a divorce decree: 1. Ground for a divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: Acceptance of Service by Timothy J. Co clan. Es~3uire, on February 10, 2004. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the Plaintiff 08/10/00, by the Defendant 08/19/00. (b) (1) Date of execution of the plaintiff's affidavit required by Section 3301(d) of the Divorce Code: (2) Date of service of the plaintiff's affidavit upon the Defendant: 4. Related claim pending: None. 5. Complete either (a) or (b) (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached, if the decree is to be entered under section 3301 (d) of the Divorce Code: (b) Date Plaintiff's Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary 08/31/00. Date Defendant's Waiver of Notice in § 3301(c) was filed with the Prothonotary 08/31/04. Date: 09/01/04 a es Rector, Esquire Attorney for the Plaintiff IN THE COURT OF COMMON PLEAS OFCUMBERLAND COUNTY STATE OF JANN E. STAPLETON VERSUS ANTOINE T. STAPLETON NO. PENNA. B~-412 ~T~TT. mERM DECREE iN DIVORCE AND NOW, DECREED THAT AND ! · 3~nn E_ St~p!eton Antoine T. Sbapleton ~O~/ , IT IS ORDERED AND ·PLAINTIFF, .DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORDIN THIS ACTION FOR WHICh A FINAL ORDER HAS NOT Yet BEEN ENTERED; N/A The parties Marriage Settlement Agreement dated August 19, 2004, is attached hereto and incorporated ~nto ~h~ n~r~ for enforcement purposes only pursuant to Section 31~5 of the Pennsylvania Divorce Code. BY THE COURT: ATT~ J. PROTHONOTARY ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dist. of CUMBE~iaUND Date of Order/Notice 10/05/04 Tribunal/Case Number fSee Addendum for case summary) O Original Order/Notice (~) Amended Order/Notice O Terminate OrdedNotice EmployerANithholder's Federal EIN Number RITE AID CORPORATION* PO BOX 3165 HARRISBURG PA 17105-3165 RE: STAPLETON, ANTOINE T. Employee/Obligor's Name (Last, First, MI) 311-68-1069 Employee/Obligor's Social Security Number 4294101285 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attac~ment~ Custodial Parent's Name (Last, First, MI) See Addendum for dependent names and birth dates associated with cases on attachmenL ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from C~ERI~N~ 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. $ 8oo. 00 per month in current support $ o. oo per month in past-due support Arrears 12 weeks or greater? Oyes (~) no $ 0. oo per month in medical support $ o. oo per month for genetic test costs $ per month in other (specify) for a total of $ 800.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 184.62 per weekly pay period. $ 369.23 per biweekly pay period (every two weeks). $ 400,00 per semimonthly pay period (twice a month). $ 800. oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #10 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at t-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SC DU, 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 Ide~tifier~ OR S~OCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED DONOTSENDCASHBYMAIL. ~ :~, ! 'i ' ~ ~ / Date of Order: L0~ ' ~ 2~ / Form EN-028 Service Type M OMB No.; 097~0154 WorkerlD $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS [] I~;hecked you are required to prpvide a ~:opy of this form to your m oyee. If yo r employee orks in a state tha is dinerent trom the state that issued this oroer, a copy must be prov c~en~:)~o your emp~oryee even if tV~e box is not che~tked. 1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned businesses located on a reservation that choose to withhold in accordance with this notice. 2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. ' ' ' ' ~ You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments· 5.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #10 below) 6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S ID: 2319406520 EMPLOYEE'S/OBLIGOR'S NAME: BTAPLETON, ANTOINE T. EMPLOYEE'S CASE IDENTIFIER: 42943.03.285 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. §. Liability: If you fail to withhold income as the Order/Notice directs, you are liable tbr both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. Ant -discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing t° employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 10.* Withholding Limits: You may not withhold more than the lesser of' I) the amoums allowed by the Federa Protecton ACt(15 U S C §1673 (b)l.or2 ,r. ......... ' ' . Consumer Credit · · , , ,,,~ dmuunLs auowee Dy the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 11. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER :~T P.O. BOX 320 CARLISLE PA 1 7013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at 71~0-6225 or by FAX at (717) 240-624,~ or by internet www.childsupport.state.pa.us Page 2 of 2 Service Type M Form EN-028 OMB No,:0970~n54 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: STAPLETON, ANTOINE T. PACSES Case Number 6353.06250 Plaintiff Name JANN E. STAPLETON Docket Attachment Amount 00245 S 2004 $ 800.00 Child(me)'s Name(s): MATTHEW M. STAPLETON DOB PACSES Case Number '7/O,/ O~,/,.~"' ~ Plaintiff Name Docket ~ttachment Amount 22o~ ¥/,~ ~Y $ 0.DO Child(ren)'s Name(s): DOB []if checked, you are required to enm the child ren) identified above in any health nsurance coverage available through the employee's/obligor's employment. [] If checked, you am required to enroll the child(mn) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ o.oo Child(mn)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ o.oo Child(ren)'s Name(s): DOB [] If checked, you am required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. [] If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through th(; employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket. Attachment Amount $ o.oo Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Nam~e Docket Attachment Amount $ o.oo Child(ren)'s Name(s): DOB J--Jif checked, you am required to enroll the child(mn) identified above in any health insurance coverage available through the employee's/obligor's employment. .,E~ If.,c. hecked, you am required to enroll the child(ren) Ioenbried above in any health insurance coverage available through the employee's/obligor's employment. Addendum Form EN-028 Service Type M OMB No.: 0970-0154 Worker ID $IATT In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION JANN E. STAPLETON Pl~miff VS. ANTOINE T. STAPLETON Defendant ) Docket Ntunber ) ) PACSES Case Number ) ) Other State ID Number 04-412 CIVIL 710106153 ORDER AND NOW, to wit, on this 5TH DAY OF OCTOBER, :!004 IT IS HEREBY ORDERED that the support order in this case be C) Vacated or C) Suspended or (~) Terminated without prejudice or C) Terminated and Vacated, effective SEPTEMBER 13, 2004 , due to: TEE DECREE IN DIVORCE ON SEPTEMBER 13, 2004 AND THE PARTIES' SETTLEMENT AGREEMENT. THE BALkNCE DUE THE PLAINTIFF IS TO BE PAID PURSUkNT TO THE TERMS OF THE PARTIES' MARITAL SETTLEMENT AGREEMENT. THE DOMESTIC RELATIONS SECTION DISMISSES THEIR INTEREST IN TEE ALIMONY PENDENTE LITE MATTER. XC: RJ Shadday plaintiff defendant Charles Rector, Esquire Timothy Colg~n, Esqu~ Service Type M Kevin A. Hess JUDGE Form OE-504 Worker ID 21005