HomeMy WebLinkAbout08-2260Howard B. Krug, Esquire
PA Atty. ID No. 16826
PURCELL, KRUG & HALLER
1719 N. Front Street
Harrisburg, PA 17102
Telephone: (717)234-4178
Email: hkru kh.com
SARA E. THUMA-CROOM, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. : NO. 01- ?.24 0 PAUL L. CROOM, II, : IN DIVORCE
Defendant : CIVIL ACTION - LAW
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth
in the following pages, you must take prompt action. You are warned that if you fail to do so,
the case may proceed without you and a decree of divorce or annulment may be entered
against you by the Court. A judgment may also be entered against you for any other claim or
relief requested in these papers by the Plaintiff. You may lose money or property or other
rights important to you, including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is available in
the Office of the Court Administrator, Cumberland County Courthouse, Hanover Street,
Carlisle, PA.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, 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 AS A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
SARA E. THUMA-CROOM,
Plaintiff
vs.
PAUL L. CROOM, II,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 0 F- ? .2 G 0 CCP Tom--,
IN DIVORCE
CIVIL ACTION - LAW
COMPLAINT UNDER SECTION 3301(C)
OR 3301(D) OF THE DIVORCE CODE
AND NOW, COMES Plaintiff, Sara E. Thuma-Croom, by her attorneys, Purcell,
Krug & Haller, and avers as follows:
1. Plaintiff is Sara E. Thuma-Croom, an adult individual currently residing at
2021 Verona Drive, Harrisburg, Dauphin County, Pennsylvania.
2. Defendant is Paul L. Croom, II, an adult individual currently residing at 106A
Forbes Avenue, Carlisle, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth
of Pennsylvania for at least six (6) months immediately previous to the filing of this
Complaint.
4. The Plaintiff and Defendant were married on August 22, 2002, in Alexandria,
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. Plaintiff requests the court to enter a decree in divorce.
COUNT I
ALIMONY PENDENTE LITE, COUNSEL
FEES, COSTS AND EXPENSES
9. Plaintiff incorporates paragraphs One through Eight by reference hereto as
though the same were set forth herein at length.
10. Plaintiff does not have sufficient funds to support herself and pay counsel
fees, costs and expenses incidental to the action.
11. Defendant is full and well able to pay Plaintiff alimony pendente lite, counsel
fees and expenses incidental to this divorce action
WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree:
(a) Dissolving the marriage between the Plaintiff and Defendant;
(b) Ordering alimony pendente lite, in addition to counsel fees and
expenses necessary for the Plaintiff to adequately prosecute this
case;
(c) Such further relief as the Court may deem equitable and just.
_ PURCELL, KRU HALL
By: _
ward-B" squire
1719 North Front Street
Harrisburg, PA 17102
(717)234-4178
Attorney for Plaintiff
Date: , -'
VERIFICATION
I, Sara E. Thuma-Groom , hereby verify that the
facts contained in the foregoing Complaint in Divorce are true
and correct to the best of my knowledge, information and belief.
I understand that false statements made herein are subject to the penalties of
18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities.
Date: f ??
w - l t
77
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SARA E. THUMA-CROOM, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - DIVORCE
NO. 08-2260 CIVIL TERM
PAUL L. GROOM, II, IN DIVORCE
Defendant/respondent
PACSES Case No: 042109965
ORDER OF COURT
AND NOW to wit, this 17th day of April 2008, it is hereby Ordered that an Order for
Alimony Pendente Lite is entered in the amount of $550.00 per month and a additional sum of
$25.00 per month is to be paid on the retroactive arrears.
This Order is based upon the agreed order of April 1, 2008 under PACSES No.
507109868 and docketed at 00191 S 2008.
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:
Ke A. Hess., J.
DRO: R.J. Shadday
xc: Petitioner
Respondent
Howard B. Krug, Esq.
Carol J. Lindsay, Esq.
Form OE-001
Service Type: M Worker: 21005
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SARA E. THUMA-CROOM, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY
Cog a a (F v
vs. :NO.
PAUL L. CROOM, II, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
ACCEPTANCE OF SERVICE
I, Carol J. Lindsay, Esquire, hereby accept service of the Complaint in Divorce on
behalf of my client, Paul L. Croom, II, Defendant in the above-captioned matter, and
acknowledge that I am authorized to do so.
r
DATE: _Abo ? 6"
Carol J. Lindsay, squire
I.D. No.?f 7_?
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsylvania
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 04/17/08
Case Number (See Addendum for case summary)
E m ployer/With holder's Federal EIN Number
DFAS CLEVELAND CENTER*
C/O DFAS-HGA/CL
GARNISHMENT OPS
PO BOX 998002
CLEVELAND OH 44199-8002
224-47-9444
Employee/Obligor's Social Security Number
1991101958
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee'slobligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 1, 414. 00 per month in current support
$ 50.00 per month in past-due support Arrears 12 weeks or greater? Dyes ® no
$ 0.00 per month in current and past-due medical support
$ 0. 00 per month for genetic test costs
$ 0.00 per month in other (specify)
for a total of $ 1, 464.00 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:
$ 337.85 per weekly pay period.
$ 675.69.per biweekly pay period (every two weeks).
$ 732. oo per semimonthly pay period (twice a month).
$ 1. 464.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on page 2).
If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call
Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580
for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BY THE COURT:
Date of Order: APR 18 2008
DRO: R. J. SHADDAY
Service Type M
507109868
191 S 2008
08-2260 CIVIL
O Original Order/Notice
O Amended Order/Notice
O Terminate Order/Notice
RE: CROOM, PAUL L. II
Employee/Obligor's Name (Last, First, MI)
; 05, 0 ,
KEVIN. HESS, JUDGE
Form EN-028 Rev
OMB No.: 0970-0154
Worker ID $IATT
1?464• x
1.2 • f
52•
337.85*
1j464• x
1 2 '
26-
6
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
? If hecke?l you are required tso provide a Gopy of this form to your em loyee. If yo r employee works in a state that is
di Brent ftrom the state that issued this order, a copy must be providedpto 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'stobligor'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 employee obligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2491016300
EMPLOYEE'S/OBLIGOR'S NAME:_ _ CROOM, PAUL L. II
EMPLOYEE'S CASE IDENTIFIER: 1991101958 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the 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 (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more
than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more
than the amounts allowed under the law of the state that issued the order.
10. Additional Info:
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
11.Submitted By: If you or your employeelobligor have any questions,
DOMESTIC RELATIONS SECTION contact _ WAGE ATTACHMENT UNIT
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
Service Type m
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
OMB No.: 0970-0154
Form EN-028 Rev. 1
Worker I D $ IATT
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: GROOM, PAUL L. II
PACSES Case Number 042109965
Plaintiff Name
SARA E. THUMA-GROOM
Docket Attachment Amount
08-2260 CIVIL$ 575.00
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 required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number 507109868
Plaintiff Name
SARA E. THUMA-GROOM
Docket Attachment Amount
00191 S 2008 $ 889.00
Child(ren)'s Name(s): DOB
SOJOURNER Q, CROOM 12.[06106
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enrol.. 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) ? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available identified above in any health insurance coverage available
through the employee's/obligor's employment. through the employee's/obligor's employment.
Addendum Form EN-028 Rev. 1
Service Type M OMB No.: 0970-0154 Worker ID $IATT
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SARA E. THUMA-CROOM, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
NO. 08-2260 CIVIL TERM
PAUL L. CROOM, II,
Defendant IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
Petitioner, Paul L. Croom, 11, moves the court to appoint a master with respect to the
following claims:
( X ) Divorce
( ) Annulment
( ) Alimony
1 X) Alimony Pendente Lite
( ) Distribution of Property (Equitable
Distribution)
( ) Support
( X 1 Counsel Fees
( X) Costs and Expenses
and in support of the motion states:
(1) Discovery is not complete as to the claim(s) for which the appointment of a
master is requested.
(2) The Defendant, appeared in the action and is represented by counsel, Howard B.
Krug, Esquire
(3) The statutory grounds for divorce are §330(c) and/or (d)
(4) Delete the inapplicable paragraph(s).
(a) The action is contested.
(b) An agreement has been reached with respect to the following
claims: NONE.
(c) The action is contested with respect to the following claims: ALL.
(5) The action does not complex issues of law or fact.
(6) The hearing is expected to take: One day
(7) Additional information, if any, relevant to the motion:
Defendant needs the following information from Plaintiff to proceed:
1. Plaintiff' s 2007 Income Tax Return
2. Plaintiff' s most recent pay stub
F KRIS ?
LINDSAY
26 West High Street
Carlisle, PA
SAIDIS, FLOWER DSAY
r
Dater
Carol J. Lind
O;Esqui re
26West Hig Sreet
Carlisle, PA 17013
717-243-6222
CERTIFICATE OF SERVICE
On the 5 day of , 2008, I, Carol J. Lindsay, Esquire, of the law firm of
SAIDIS, FLOWER & LINDSAY, he eby 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:
Howard B. Krug, Esquire
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
SAIDIS, FLOWER & LINDSAY
Carol J. Linds y, quire
Supreme C rt ID o. 44693
26 West High reet
Carlisle, PA 17013
717-243-6222
SAIDIS,
FLOWER &
LINDSAY
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26 West High Street
Carlisle, PA
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SARA E. THUMA-CROOM, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
NO. 08-2260 CIVIL TERM
PAUL L. CROOM, II,
Defendant IN DIVORCE
ORDER APPOINTING MASTER
AND NOW, this day of , 2008,
?? ??if%T1•, . ) Esquire, is appointed master with respect to the
following claims: Divorce, alimony pendente lite, counsel fees, costs and expenses.
B rHE CO ,
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SAIDIS,
FZAWERR &
LINDSAY
ATFAMEW-Lw
26 West High Street
Carlisle, PA
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Howard B. Krug, Esquire
PA Atty. ID No. 16826
PURCELL, KRUG & HALLER
1719 N. Front Street
Harrisburg, PA 17102
Telephone: (717)234-4178
Email: hkru-gppkh.com
SARA E. THUMA-CROOM, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. : NO. 08-2260
PAUL L. CROOM, II, : IN DIVORCE
Defendant : CIVIL ACTION - LAW
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth
in the following pages, you must take prompt action. You are warned that if you fail to do so,
the case may proceed without you and a decree of divorce or annulment may be entered
against you by the Court. A judgment may also be entered against you for any other claim or
relief requested in these papers by the Plaintiff. You may lose money or property or other
rights important to you, including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is available in
the Office of the Court Administrator, Cumberland County Courthouse, Hanover Street,
Carlisle, PA.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, 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 AS A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
Howard B. Krug , Esquire
I.D. No. 16826
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
hkruq(&-pkh.com
SARA E. THUMA-CROOM,
Plaintiff
V.
PAUL L. CROOM, II,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08-2260
CIVIL ACTION - LAW
IN DIVORCE
PLAINTIFF'S PETITION RAISING CLAIMS
PURSUANT TO Pa.R.C.P. §1920.15 OF THE DIVORCE CODE
COMES NOW Plaintiff, Sara E. Thuma-Croom, by her attorneys, Purcell, Krug &
Haller, and avers as follows:
1. Petitioner is Sara E. Thuma-Croom, Plaintiff in the above-captioned divorce
action.
2. Respondent is Paul L. Croom, II, Defendant in the above-captioned divorce
action.
COUNTI
EQUITABLE DISTRIBUTION
3. Plaintiff incorporates paragraphs 1 through 11 of the Complaint in Divorce by
reference hereto as though the same were set forth herein at length.
4. Plaintiff and Defendant possess various items of both real and personal
property which are subject to equitable distribution by this Court.
WHEREFORE, Plaintiff requests this Honorable Court to equitably distribute the
marital property after an inventory and appraisement has-been filed by the parties.
PURCELL, KRW3 & HAL
By:
How ,01d B. Kr uin
I 16826
1719 North Front Street
Harrisburg, PA 17102
(717)234-4178
Attorney for Plaintiff
Dated: June 13. 2008
2
VERIFICATION
I, Sara Thuma-Croom, hereby verify that the facts contained in the foregoing
Plaintiffs Petition Raising Additional Claims are true and correct to the best of my
knowledge, information and belief.
I understand that false statements made herein are subject to the penalties of
18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities.
Date: 13 Gfll-
CERTIFICATE OF SERVICE
I, Angela S. Shaffer, an employee of the law firm of Purcell, Krug & Haller,
counsel for Plaintiff, hereby certify that service of PLAINTIFF'S PETITION RAISING
ADDITIONAL CLAIMS PURSUANT TO Pa.R.C.P. §1920.15 OF THE DIVORCE CODE
was served upon the following via first class, regular mail on June 13, 2008:
Carol J. Lindsay, Esquire
26 West High Street
Carlisle, PA 17013
Ang I S. Shaffer 01
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Howard B. Krug, Esquire
PA Atty. ID No. 16826
PURCELL, KRUG & HALLER
1719 N. Front Street
Harrisburg, PA 17102
Telephone: (717)234-4178
Email: hkrugagkh.com
SARA E. THUMA-CROOM, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. : NO. 08-2260
PAUL L. CROOM, II, : IN DIVORCE
Defendant : CIVIL ACTION - LAW
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth
in the following pages, you must take prompt action. You are warned that if you fail to do so,
the case may proceed without you and a decree of divorce or annulment may be entered
against you by the Court. A judgment may also be entered against you for any other claim or
relief requested in these papers by the Plaintiff. You may lose money or property or other
rights important to you, including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is available in
the Office of the Court Administrator, Cumberland County Courthouse, Hanover Street,
Carlisle, PA.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, 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 AS A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
Howard B. Krug, Esquire
I.D. No. 16826
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
hkrug@pkh.com
SARA E. THUMA-CROOM,
Plaintiff
V.
PAUL L. CROOM, II,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08-2260
CIVIL ACTION - LAW
IN DIVORCE
PLAINTIFF'S PETITION RAISING CLAIMS
PURSUANT TO Pa.R.C.P. §1920.15 OF THE DIVORCE CODE
COMES NOW Plaintiff, Sara E. Thuma-Croom, by her attorneys, Purcell, Krug &
Haller, and avers as follows:
1. Petitioner is Sara E. Thuma-Croom, Plaintiff in the above-captioned divorce
action.
2. Respondent is Paul L. Croom, II, Defendant in the above-captioned divorce
action.
COUNTI
CLAIM FOR ALIMONY
3. Plaintiff incorporates paragraphs 1 through 11 of the Complaint in Divorce by
reference hereto as though the same were set forth herein at length.
4. Plaintiff is presently unemployed.
5. Plaintiff is unable to support herself through appropriate employment.
6. Plaintiff lacks sufficient property and income to provide for her reasonable
needs.
WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree
Ordering alimony.
PUR LL, KRUG & HALL
sy
119rFrisb 2s .?
17or ron reet
Ha rg,PA 17102
(717)234-4178
Attorney for Plaintiff
Dated: June 111, 2008
2
VERIFICAT?
I, Sara Thuma-Croom, hereby verify that the facts contained in the forgoing
PETITION RAISING ADDITIONAL CLAIMS are true and correct to the best of my
knowledge, information and belief.
I understand that false statements made herein are subject to the penalties of
18 Pa. C.S. Section 4904, relating to unswom falsification to authorities.
THUMA-CROOM, Plaintiff
Date: ! 10 `--d-
CERTIFICATE OF SERVICE
I, Angela S. Shaffer, an employee of the law firm of Purcell, Krug & Haller,
counsel for Plaintiff, hereby certify that service of PLAINTIFF'S PETITION RAISING
ADDITIONAL CLAIMS PURSUANT TO Pa.R.C.P. §1920.15 OF THE DIVORCE CODE
was served upon the following via first class, regular mail on June IS , 2008:
Carol J. Lindsay, Esquire
26 West High Street
Carlisle, PA 17013
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Angela . Shaffer
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
507109868
State Commonwealth of Pennsylvania 191 S 2008
CO./City/Dist. Of CUMBERLAND
Date of Order/Notice 06/20/08
Case Number (See Addendum for case summary)
Employer/Withholder's Federal EIN Number
DFAS CLEVELAND CENTER*
C/O DFAS-HGA/CL
GARNISHMENT OPS
224-47-9444
Employee/Obligor's Social Security Number
1991101958
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
PO BOX 9 9 8 0 0 2 associated with cases on attachment)
CLEVELAND OH 44199-8002 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.
$ 864.00 per month in current child support
$ 25.00 per month in past-due child support Arrears 12 weeks or greater? Dyes ® no
$ 0. oo per month in current medical support
$ 0.00 per month in past-due medical support
$ 550.00 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 $ 1,439.00 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:
$ 331.17 per weekly pay period. $ 719.50 per semimonthly pay period
(twice a month)
$ 662 .33 per biweekly pay period (every two weeks) $ 1, 439.00 per monthly pay period.
REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10)
working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of
withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work
state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of
the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding,
the following information is needed (See #9 on page 2).
If required by Pennsylvania law (23 PA C.S. 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 NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BY THE COURT:
08-2260 CIVIL
OOriginal Order/Notice
OAmended Order/Notice
OTerminate order/Notice
QOne-Time Lump Sum/Notice
RE: CROOM, PAUL L. II
Employee/Obligor's Name (Last, First, MI)
KEEN A. HESS, JUDGE
Form EN-028 Rev. 3
Service Type M OMB No.: 0970-0154 Worker ID $IATT
t „`
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
? if hecked you are required to provide a opy of this form to your mployee. If yorr employee orks in a state tha is
di4erent from the state that issued this o er, a copy must be provi?ed to your emp ogee even if t ie box is not the : ed.
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. 2491016300
THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : 1:3 THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: ID
EMPLOYEE'S/OBLIGOR'S NAME:CROOM, PAUL L. II
EMPLOYEE'S CASE IDENTIFIER: 1991101958 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 employee/obligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (CCPA) (15 U.S.C. 1673 (b)); or 2) the amounts allowed by the State or Tribe of the employee's/obligor's principal place of
employment. Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes, Social
Security taxes, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is
supporting another family and 60% of the disposable income if the obligor is not supporting another family.However, that 50% limit is
increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State, you may
deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section.
Arrears greater than 12 weeks : If the Order information does not indicate whether the arrears are greater than 12 weeks, then the
employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts
allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser of
the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of the
CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amounts paid for health
care premiums in determining disposable income and applying appropriate withholding limits.
10. Additional info:
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state
that issued this order with respect to these items.
11. Send Termination Notice and
other correspondence to: 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 intemet www.childsupport.state.pa.us
Page 2 of 2 Form EN-028 Rev. 3
Service Type M OMB No.: 0970-0154 Worker ID $IATT
I' +
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: CROOM, PAUL L. II
PACSES Case Number 042109965
Plaintiff Name
SARA E. THUMA-CROOM
Docket Attachment Amount
08-2260 CIVIL $ 550.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACKS 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.
Service Type M
PACKS Case Number 507109868
Plaintiff Name
SARA E. THUMA-GROOM
Docket Attachment Amount
00191 S 2008 $ 889.00
Child(ren)'s Name(s): DOB
SOJOURNER Q. CROOM 12/06/06
? 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.
PACKS Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
?if checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Addendum
OMB No.: 0970-0154
Form EN-028 Rev. 3
Worker I D $ IATT
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SARA E. THUMA-CROOM, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. :NO. 08-2260 CIVIL
PAUL L. CROOM, 11,
Defendant : CIVIL ACTION - IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed
on April 10, 2008.
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. 1 consent to the entry of a final decree of divorce after service of notice of
intention to request entry of the decree.
I verify that the statements made in this affidavit are true and correct.
understand that false statements herein are made subject to the penalties of 18 Pa.
C.S. §4904 relating to unsworn falsification to authorities.
Date: / / 6
a-Croom, Plaintiff
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SARA E. THUMA-CROOM,
Plaintiff
vs.
PAUL L. CROOK 11,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08-2260 CIVIL
CIVIL ACTION - IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
§3301(c) OF THE DIVORCE CODE
1. 1 consent to the entry of a final decree of divorce without notice.
2. 1 understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. 1 understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the Decree will be sent to me immediately after it is filed with
the Prothonotary.
I verify that the statements made in this Affidavit are true and correct.
understand that false statements herein are made subject to the penalties of 18 Pa.
C.S. §4904 relating to unsworn falsification to a
Date: //// ?- e
Thuma-Croom, Defendant
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SARA E. THUMA-CROOM, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
NO. 08-2260 CIVIL TERM
PAUL L. CROOM, 11,
Defendant IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed April
10, 2008.
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. 1 consent to the entry of a final Decree in 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 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 unswom falsification to authorities.
Date: 21 Ndv 03
Paul L. Croom, 11
DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER4 3301 (c) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
SAMIS,
LMDSAY
ANOWNSWIAW
26 West High Street
Carlisle, PA
2. 1 understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. 1 understand that I will not be divorced until a Divorce Decree is entered by
the Court and that a copy of the Decree will be sent to me immediately after it is filed with
the Prothonotary.
I verify that the statements made in this Affidavit are true and correct 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: 21 Not og
Paul L. Croom, 11
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SARA E. THUMA-CROOM,
Plaintiff
V.
PAUL L. CROOM, fl,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 08-2260 CIVIL TERM
IN DIVORCE
PROPERTY SETTLEMENT AND SEPARATION AGREEMENT
THIS AGREEMENT made this day of 6ye?--?•`, 2008,
between PAUL L. CROOM, II, of 4590 Sequoia 'Drive, Apartment B, Harrisburg, Dauphin
County, Pennsylvania, hereinafter referred to as Husband, and SARA E. THUMA-CROOM, of
2021 Verona Drive, Harrisburg, Dauphin County, Pennsylvania, hereinafter referred to as Wife.
RECITALS:
R.1: The parties hereto are husband and wife, having been joined in marriage on
August 22, 2002 in Alexandria, Virginia; and
R.2: A Complaint for Divorce has been filed in the Court of Common Pleas of
Cumberland County, Commonwealth of Pennsylvania, to Number 08-2260 Civil Term; and
R.3: The parties hereto desire to settle fully and finally their respective financial and
property rights and obligations including, but not limited to, all matters between them relating to
the ownership of real and personal property, claims for spousal support, alimony, alimony
pendente lite.
R4: The parties also desire to settle their issues of alimony pendente lite, counsel fees
and costs, and the settling of any and all claims and possible claims against the other or against
their respective estates.
NOW THEREFORE, in consideration of the covenants and promises hereinafter to be
mutually kept and performed by each party, as well as for other good and valuable consideration
and intending to be legally bound, it is agreed as follows:
1
A
(1) SEPARATION: It shall be lawful for each party at all times hereafter to live
separate and apart from the other party at such place or places as he or she from time to time
may choose or deem fit, free from any control, restraint or interference from the other. Neither
party will molest the other or endeavor to compel the other to cohabit or dwell with him or her by
any legal or other proceeding. Each party shall be free of the interference, authority or contact by
the other as if he or she was single and unmarried except as maybe necessary to carry out the
terms of this agreement.
(2) DIVORCE: The parties acknowledge that the marriage is irretrievably broken and
that they will secure a mutual consent no-fault divorce decree in the above-captioned divorce
action. Within five days of the date of this agreement, the parties shall file Affidavits of Consent
and Waivers of Notice necessary to finalize said divorce. Husband will forward to the Master two
copies of the Marital Settlement Agreement and ask the Master to vacate his appointment. Within
five days of the Order vacating the Master's appointment, Wife will transmit the record so that the
Decree in Divorce may be entered.
If either party fails or refuses to complete his or her obligation under this paragraph to sign
and file Affidavits of Consent and to promptly transmit the record, then, and in that event, the
other party, at his or her sole discretion, may terminate the Agreement.
(3) DEBT:
A. Marital Debt: Husband and Wife acknowledge and agree that there are no other
outstanding debts and obligations which are marital or for which the other might be liable incurred
prior to the signing of this Agreement, except as follows:
i. Husband's USAA Master Card.
ii. Wife's NFCU Visa.
iii. Wife's student loans.
iv. Husband's Navy Federal Credit Union vehicle loan.
2
1: Husband shall pay the obligations to USAA Master Card and to Navy Federal
Credit Union for the vehicle loan by making timely monthly payments in at least the minimum
amount required by the creditors until paid in full.
2: Wife shall pay the obligations to NFCU Visa and on her student loans by making
timely monthly payments in at least the minimum amount required by the creditors until paid in full.
Each party shall pay the outstanding debts as set forth herein and further agrees to
indemnify and save harmless the other from any and all claims and demands made against either
of them by reason of such debts or obligations.
B: Post Separation Debt: In the event that either party contracted or incurred any
debt since the date of separation on February 22, 2008, the party who incurred said debt shall be
responsible for the payment thereof regardless of the name in which the debt may have been
incurred.
C: Future Debt: From the date of this agreement neither party shall contract or incur
any debt or liability for which the other party or his or her property or estate might be responsible
and shall indemnify and save the other party harmless from any and all claims or demands made
against him or her by reason of debts or obligations incurred by the other party.
(4) MOTOR VEHICLES: Each party relinquishes any right, title and interest he or she
may have to any and all motor vehicles currently in possession of the other party. Each party
shall assume full responsibility for any encumbrance on the motor vehicle received by said party,
and shall hold harmless and indemnify the other party from any loss thereon. Specifically,
Husband will retain the 2006 Forester and Wife will retain the 1997 Subaru Legacy.
(5) TANGIBLE PERSONAL PROPERTY: The parties hereto mutually agree that they
have effected a satisfactory division of the furniture, household furnishings, appliances, tools and
other household personal property between them, and they mutually agree that each party shall
from and after the date hereof be the sole and separate owner of all such property presently in his
3
or her possession whether said property was heretofore owned jointly or individually by the parties
hereto. This agreement shall have the effect of an assignment or bill of sale from each party to
the other for such property as may be in the individual possession of each of the parties hereto.
(6) INTANGIBLE PERSONAL PROPERTY: Each party hereby relinquishes any right,
title or interest he or she may have in or to any intangible personal property currently titled in the
name of or in the possession of the other party, including, but not limited to, stocks, bonds,
insurance, bank accounts, individual retirement accounts, employment benefits including
retirement accounts, savings plans, pension plans, stock plans, 401K plans except as stated
herein. Nevertheless, Husband shall transfer to Wife by Administrative Domestic Relations Order
prepared by Husband $12,000.00 from his Thrift Savings Plan. The transfer shall be made
directly into an IRA for Wife and the transfer will not be a taxable event to either party.
The parties have equally divided the contents of their Navy Federal Credit Union account
(--4003). The parties will each retain the following bank accounts:
a. Husband will retain his Navy Federal Credit Union account (--701), his
Members 1s' Federal Credit Union accounts and his Navy Federal Credit Union savings
account (--1008).
b. Wife will retain the joint Navy Federal Credit Union account (--4706), her
own Navy Federal Credit Union accounts (--1107 and -1719), her Navy Federal Credit
Union savings account (--1008) and her ING High Yield savings account. Wife will close
any joint account which she is retaining within five days of the date of this Agreement.
The parties will equally divide their IRS refund in the amount of $3,452 and any State
refund check for 2007. They will also equally divide the IRS stimulus payment, except that Wife
will retain the stimulus payment attributable to the parties' child, Sojourner Croom.
(7) ALIMONY: Husband shall pay to Wife monthly alimony of $300.00 per month
commencing the first day of the month following the date of entry of the Decree in Divorce and
4
I
continuing for 23 additional months, each payment made on or about the first day of the month
until the occurrence of one of the following:
a. The death of Wife.
b. The death of Husband.
C. The remarriage or cohabitation of Wife with a member of the opposite
sex not within the degrees of consanguinity
d. The passing of three months of Wife's continuous employment which
has health insurance as an employee benefit. It shall be Wife's obligation to
immediately notify Husband upon her employment with an employer which offers health
insurance benefits. Should the employment terminate for any reason within the three
month period, alimony shall continue for the duration of the 24 month term as provided
herein.
The parties acknowledge that they know one another's Social Security Number.
Alimony payments shall be deductible from Husband's gross income for the purpose of filing
federal income tax returns and includible in Wife's gross income for the same purpose.
The alimony payment set out herein shall be payable to the Office of Domestic Relations
of Cumberland County. Enforcement shall be by attachment of Husband's wages. In the event
that an overpayment in the amount of alimony is made, Wife will refund said overpayment to
Husband within thirty days of receipt and notice of its payment in error.
Alimony pendente lite currently in effect shall remain in full force and effect until the
commencement of alimony. Any arrears in APL shall be paid by Husband within 30 days of its
termination. Any credit due Husband shall be paid by Wife within 30 days of the termination of
APL.
5
(8) ADVICE OF COUNSEL: The parties hereto acknowledge that each has been
notified of his or her right to consult with counsel of his or her choice., and have been provided a
copy of this agreement with which to consult with counsel. Wife is represented by Howard B.
Krug, Esquire and Husband is represented by Carol J. Lindsay, Esquire. Each party
acknowledges and accepts that this Agreement is, under the circumstances, fair and equitable,
and that it is being entered into freely and voluntarily after having received such advice and with
such knowledge as each has sought from counsel, and 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. Each party shall pay his or her own attorney for all legal services
rendered or to be rendered on his or her behalf.
(9) ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the
request of the other, execute, acknowledge and deliver to the other party any and all further
instruments that may be reasonably required to give full force and effect to the provisions of this
Agreement.
(10) INCOME TAX:
A. 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
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 tax problem.
B. Husband will take the dependency exemption for the parties' child, Sojourner
Croom, on his Federal tax return for 2008.
6
I
(11) COMPLETE DISCLOSURE: The parties do hereby warrant, represent,
acknowledge and agree that each is fully and completely informed of, and is familiar with, the
wealth, real and personal property, estate and assets, earnings and income of the other and has
made any inquiry he or she desires into the income or estate of the other and received any such
information requested. Each has made a full and complete disclosure to the other of his and her
entire assets, liabilities, income and expenses and any further enumeration or statement thereof in
this Agreement is specifically waived.
(12) RIGHTS AND RESPONSIBILITIES: Husband and Wife acknowledge that each of
them has read and understand his and her rights and responsibilities under this Agreement and
that they have executed this Agreement under no compulsion to do so but as a voluntary act.
(13) FULL SETTLEMENT: Except as herein otherwise provided, each party hereby
releases the other from any and all claims, or demands up to the date of execution hereof. It is
further specifically understood and agreed by and between the parties hereto that each party
accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all
of said party's rights against the other for past, present and future claims on account of support,
maintenance, alimony, alimony pendente life, counsel fees, costs and expenses, equitable
distribution of marital property and any other claims of the party, including all claims which have
been raised or may be raised in an action for divorce.
(14) RELEASE OF ALL CLAIMS: Except as to obligations and rights set forth herein
or as otherwise specifically provided in this Agreement, Husband and Wife, for themselves, their
heirs, representatives and assigns, each hereby forever releases, remises, discharges and
quitclaims the other, and such other's heirs, representatives, assigns and estate, from and with
respect to the following:
a. All liability, claims, causes of action, damages, costs, contributions and expenses
or demands whatsoever in law or in equity;
7
1 .
b. All rights, title, interest or claims in or to any property of the other, whether real,
personal or mixed and whether now owned or hereafter acquired;
C. All rights of courtesy and dower and all claims or rights in the nature of courtesy
and dower;
d. All widow or widower's rights;
e. All right, title, interest or claim in or to the other's estate, whether now owned or
hereafter acquired, including but not limited to all rights or claims:
(1) to take against the other's will;
(2) under the laws of intestacy;
(3) to a family exemption or similar allowance;
and
(4) all other rights or authority to participate or intervene in a deceased
spouse's estate in any way, whether arising under the laws of Pennsylvania or any other
country, territory, state or political subdivision.
f. All rights or claims to any accounting;
g. All rights, claims, demands, liabilities and obligations arising out of or in connection
with the marital relationship or the joint ownership of property, whether real, personal or mixed;
h. All rights, claims, demands, liabilities and obligations arising under the provisions
of the Pennsylvania Divorce Code, as the same may be amended from time to time, and under
the provisions of any similar statute enacted by any other country, state, territory or political
subdivision;
i. All rights, claims, demands, liabilities and obligations each party now has, or may
hereafter have, against or with respect to the other.
8
(15) GOVERNING LAW: This Agreement shall be construed under the law of the
Commonwealth of Pennsylvania. If any provision of this Agreement is determined to be invalid or
unenforceable, all other provisions shall continue in full force and effect.
(16) INCORPORATION INTO DECREE: In the event that either of the parties shall
recover a final judgment or decree of absolute divorce against the other in a court of competent
jurisdiction, the provisions of this Agreement may be incorporated by reference or in substance
but shall not be merged into such judgment or decree and this Agreement shall survive any such
final judgment or decree of absolute divorce and shall be entirely independent thereof.
(17) BREACH: In the event that either party breaches any provision of this Agreement,
he or she shall be responsible for any and all costs incurred to enforce the Agreement, including,
but not limited to, court cost and counsel fees of the other party, In the event of breach, the other
party shall have the right, at his or her election; to sue for damages for such breach or to seek
such other and additional remedies as may be available to him or her.
(18) ENTIRE UNDERSTANDING: This Agreement constitutes the entire understanding
between the parties and there are no covenants, conditions, representations, or agreements, oral
or written, of any nature whatsoever, other than those herein contained.
(19) AGREEMENT BINDING ON PARTIES AND HEIRS: This Agreement shall bind
the parties hereto, their respective heirs, executors and assigns.
IN WITNESS WHEREOF, the parties hereto intending to be legally bound have hereunto
set their hands and seals the day and year first wri
9
?ajz 6 &*>?a" al
Paul L. Croom, 11
1 i
SARA E. THUMA-CROOM, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 08 - 2260 CIVIL
PAUL L. CROOM, II,
Defendant IN DIVORCE
ORDER OF COURT
AND NOW, this Aq U-. day of '? hVWM'n-' ,
2008, the economic claims raised in the proceedings having been
resolved in accordance with a property settlement and
separation agreement dated November 21, 2008, the appointment
of the Master is vacated and counsel can file a praecipe
transmitting the record to the Court requesting a final decree
in divorce.
BY TH RT,
W'C"
1^ cc: Howard B. Krug
Attorney for Plaintiff
Carol J. Lindsay
Attorney for Defendant
I "..C«•l //- a y-D g
A*10-e - L?'
( j ??
SARA E. THUMA-CROOM,
Plaintiff
vs.
PAUL L. CROOM, II,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08-2260 CIVIL
CIVIL ACTION - IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the Court for entry of a
Divorce Decree:
1. Ground for divorce: Irretrievable breakdown under 3301 c of the Divorce Code.
2. Date and manner of service of the Complaint: Complaint in Divorce was served
on Counsel for Defendant by Acceptance of Service by Counsel on April 18, 2008 & said
counsel was authorized to accept Complaint on behalf of Defendant.
3. (Complete either paragraphs (a) or (b).
(a) Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce
Code: By Plaintiff: 11/1 8/2008and By Defendant: I I 1 - 0 $
(b) (1) Date of execution of the Affidavit required by §3301(d) of the Divorce Code:
N/A;
(2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: N/A.
4. Related claims pending:
in this final Decree in Divorce pursuant to Paragraph 16 of said Agreement.
5. (Complete either (a)_or (b).)
(a) Date and manner of service of the notice of intention to file a Praecipe to
Transmit Record, a copy of which is attached: N/A
(b) Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the
Prothonotary: i -
Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the
Prothonotary: - 1-0
B
Dated:
Harrisburg, PA 17102
(717) 234-4178
ID No. 16826
C-I
SARA E. THUMA-CROOM
V.
PAUL L. CROOM, II
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2008-2260
DIVORCE DECREE
AND NOW, .«...?? q` Lo a8 , it is ordered and decreed that
Sara E. Thuma-Groom plaintiff, and
Paul L. Croom, II
bonds of matrimony.
defendant, are divorced from the
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.")
The terms of the Marital Settlement Agreement, dated November 21
2008, are incorporated but not merged into this Decree in Divorce.
By the CoUrt,
V, Y- el
.?a, of - of
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 08-2260 CIVIL
O Origi nal Order/Notice
State Commonwealth of Pennsylvania 507109868 amended Order/Notice
COJCity/Dist. of CUMBERLAND 191 S 2008
Date of Order/Notice 01/13/09 0 Terminate Order/Notice
Case Number (See Addendum for case summary) QOne-Time Lump Sum/Notice
Employer/Withholder's Federal EIN Number
DFAS MARINE CORPS
RE: CROOM, PAUL L. II
Employee/Obligor's Name (Last, First, MI)
Sent Electronically
DO NOT MAIL
224-47-9444
Employee/Obligor's Social Security Number
1991101958
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.
$ 864.00 per month in current child support
$ 25. oo 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
$ 300.00 per month in current spousal support
$ o. oo per month in past-due spousal support
$ o . oo per month for genetic test costs
$ o. o o per month in other (specify)
$ one-time lump sum payment
for a total of $ 1,189 . oo 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:
$ 273.63 per weekly pay period. $ 594.50 per semimonthly pay period
(twice a month).
$ 547.27 per biweekly pay period (every two weeks). $ 1,189.00 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 earnings. For the purpose of the limitation on withholding,
the following information is needed (See #9 on page 2).
If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call
Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580
for instructions. PA FIPS CODE 42 000 00
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAMEAND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BY THE COURT: EDGAR B BAYLEY
Form EN-428
Service Type M OMB No.: 0970-0154 Worker ID $IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
Me hereck you are s required to pr vide a opy of this form to your m loyee. If yo r employeg orks in a state that is
nt from the tate that issuefthis order, a copy must be provic?ec?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 employeetobligor'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 paydateldate of withholding when sending the payment. The
paydateldate 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 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'stobligor'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. 5399900000
THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : 13 THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: O
EMPLOYEE'S/OBLIGOR'S NAME:CROOM, PAUL L. II
EMPLOYEE'S CASE IDENTIFIER: 1991101958 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) (15 U.S.C. 1673 (b)); or 2) the amounts allowed by the State or Tribe of the employee's/obligor's principal place of
employment. Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes, Social
Security taxes, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is
supporting another family and 60% of the disposable income if the obligor is not supporting another family.However, that 50% limit is
increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State, you may
deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section.
Arrears greater than 12 weeks : If the Order Information does not indicate whether the arrears are greater than 12 weeks, then the
employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts
allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser of
the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of the
CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amounts paid for health
care premiums in determining disposable income and applying appropriate withholding limits.
10. Additional info:
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state
that issued this order with respect to these items.
11. Send Termination Notice and
other correspondence to: 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
Page 2 of 2
Service Type M OMB No.: 0970-0154
Form EN-428
Worker ID $IATT
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: GROOM, PAUL L. II
PACSES Case Number 042109965
Plaintiff Name
SARA E. THUMA-CROOM
Docket Attachment Amount
08-2260 CIVIL$ 300.00
Child(ren)'s Name(s): DOB
PACKS Case Number
Plaintiff Name
SOJOURNER.::CROOM .:..:.::.:....................................12/.06/06
,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.: 0970-0154
Form EN-428
Worker I D $ IATT
N
'Al Ti
SARA E. THUMA-CROOM,
Plaintiff/Petitioner
VS.
PAUL L. CROOM, II,
Defendant/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 08-2260 CIVIL TERM
IN DIVORCE
PACSES CASE: 042109965
ORDER OF COURT
AND NOW to wit, this 15th day of January 2009, it is hereby Ordered that the
Alimony Pendente Lite is terminated, effective January 1, 2009, pursuant to the parties' Property
Settlement and Separation Agreement of November 21, 2008 and the Divorce Decree of
December 9, 2008.
The Alimony Pendente Lite account is closed with a credit of $550.00 and will be directed
to the Alimony account as an offset to the January, 2009 Alimony balance of $300.00.
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:
'Ov.
W n A. Hess, J.
DRO: R.J. Shadday
xc: Petitioner
Respondent
Carol J. Lindsay, Esq.
Howard B. Krug, Esq.
Form OE-001 Type: M Worker: 21005
rv
f-
cn
Howard B. Krug, Esquire
PA Supreme Court ID# 16826
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Phone: (717) 234-4178
Fax: (717) 234-0409
hkrugQpkh.com
SARA E. THUMA-CROOM, : IN THE COURT OF COMMON PLEAS
Plaintiff/Movant : CUMBERLAND COUNTY, PENNSYLVANIA
vs. : NO. 2008-2260
PAUL L. CROOM, II,
Defendant/Respondent : CIVIL ACTION - LAW
MOTION FOR ENTRY OF A
DOMESTIC RELATIONS ORDER
AND NOW, comes Movant, Sara E. Thuma-Croom, by and through her counsel,
Purcell, Krug & Haller, and avers the following:
1. Movant is Sara E. Thuma-Croom, Plaintiff in the above captioned divorce
action.
2. Respondent is Paul L. Croom, II, Defendant in the above captioned divorce
action.
3. Pursuant to a Property Settlement and Separation Agreement signed by the
parties, Sara E. Thuma-Croom is to receive a portion of Respondent's Thrift Savings
Plan.
4. The parties have agreed to the terms of a Domestic Relations Order
distributing this asset, as evidenced by their signatures on the proposed stipulated
order attached to this Motion.
5. Counsel for Respondent concurs with this Motion.
WHEREFORE, Movant, Sara E. Thuma-Croom, respectfully requests this
Honorable Court to enter the attached stipulation as an Order of Court.
By
PURCELL, KRUG & HALLER
How
D. #Morth 6
171 Front Street
Harrisburg, PA 17102
717 234-4178
Attorney for Sara E. Thuma-Croom
Date: ' 31- &,
CERTIFICATE OF SERVICE
I, Angela S. Shaffer, employee for the law firm of Purcell, Krug & Haller, counsel
for Plaintiff/Movant, Sara E. Thuma-Croom, hereby certify that service of the foregoing
Motion for Entry of Domestic Relations Order was made on the following via regular
/A puzl
mail on Mereh . 2009:
Carol J. Lindsay, Esquire
SAIDIS, FLOWER & LINDSAY
26 West High Street
Carlisle, PA 17013
Attorney for Defend ant/Respondent
r
Angela S. Shaffe
i
l
? I Iv.
1,-„ „ -. r
r i . ; _, ?
?.'.. i
APR 0 2 20UA? 1
i
Al-I% V ` &-%OW 7
Sara E. Thuma-Croom
Plaintiff
VS.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Paul L. Croom, II NO. 2008-2260
Defendant
DOMESTIC RELATIONS ORDER
1. This Domestic Relations Order ("DRO") creates and recognizes the existence of the
Alternate Payee's right to receive a portion of the benefits payable with respect to the Participant.
It is intended to constitute a Qualifying Retirement Benefits Court Order by the Federal
Retirement Thrift Investment Board ("Board")
2. This DRO is entered pursuant to authority granted under the applicable domestic
relations laws of the State of Pennsylvania.
3. This DRO relates to the provision of marital property rights to the Alternate Payee.
4. This DRO applies to the Thrift Savings Plan ("Plan") and any successor thereto. Paul
L. Croom, II ("Participant") is a Participant in the Plan. Sara E. Thuma-Croom ("Alternate
Payee"), the former spouse, is the Alternate Payee for the purposes of this DRO.
5. The Participant's name, mailing address, Social Security number and date of birth are:
Paul L. Croom, II
MIOC09-1, NMITC, Dam Neck
2088 Regulus Avenue
Virginia Beach, VA 23461
Social Security No.: 224-47-9444
Date of Birth: August 26, 1977
6. The Alternate Payee's name, mailing address, Social Security number and date of birth
are
Sq q WA c- My 60oz
AL?I
DRO
Page 2
Sara E. Thuma-Croom
2021 Verona Drive
Harrisburg, PA 17110
Social Security No.: 202-58-1304
Date of Birth: July 16, 1978
It is the responsibility of the Alternate Payee to keep a current mailing address on file
with the Plan at all times.
7. This Order assigns to Alternate Payee an amount equal to $12,000.00.
8. The Alternate Payee shall be paid benefits as soon as administratively feasible
following the date this Order is approved as a Qualifying Retirement Benefits Court Order by the
Board.
9. Benefits are to be payable to the Alternate Payee in the form of a lump sum cash
payment.
10. All payments made pursuant to this order shall be conditioned on the certification by
the Alternate Payee and the Participant to the Board of such information as the Board may
reasonably require from such parties.
11. This DRO does not require the Plan to provide any type or form of benefit the Plan does
not otherwise provide.
12. This DRO does not require the Plan to provide increased benefits.
13. This DRO does not require the Plan to pay any benefits which another order previously
determined to be a qualified domestic relations order requires the Plan to pay to another alternate
payee.
14. In the event that the Plan inadvertently pays to the Participant any benefits that are
assigned to the Alternate Payee pursuant to the terms of this order, the Participant shall
DRO
Page 3
immediately reimburse the Alternate Payee to the extent that he has received such benefit
payments and shall forthwith pay such amount so received directly to the Alternate Payee within
ten (10) days of receipt. In the event that the Plan inadvertently pays to the Alternate Payee any
benefits that are assigned to the Participant pursuant to the terms of this order, the Alternate
Payee shall immediately reimburse the Participant to the extent that she has received such
benefit payments and shall forthwith pay such amount so received directly to the Participant
within ten (10) days of receipt.
15. After payment of the amount required by this DRO, the Alternate Payee shall have no
further claim against the Participant's interest in the Plan.
16. The Alternate Payee assumes sole responsibility for the tax consequences of any
payments made to her under this DRO.
17. In the event the Participant predeceases the Alternate Payee before she receives her
distribution, his death shall have no effect on her assigned portion of the benefits, as stipulated
herein. If applicable, the Alternate Payee shall be treated as the beneficiary of the Participant to
the extent of her assigned interest hereunder.
18. If Participant takes any action that prevents, decreases or limits the collection by
Alternate Payee of the sums to be paid hereunder, he shall make payments to Alternate Payee
directly in an amount sufficient to neutralize, as to Alternate Payee, the effects of the actions
taken by Participant.
DRO
Page 4
19. The Court of Common Pleas of Cumberland County, Pennsylvania shall retain
jurisdiction to amend this Order, but only for the purpose of establishing it or maintaining it as a
Domestic Relations Order, provided, however, that no such amendment shall require the Plan to
provide any form of benefit or any option not otherwise provided by the Plan, and further provide
that no such amendment or right of the Court to so amend will invalidate this Order.
EXECUTED this 3' day of BY ?
BY THE COURT
A/
Judge
CONSENT T;0 ORDER:
Plaintiff/Alternate Payee ate
- ? g
Attorney Date
Alternate Payee
Defendant/Participant
Date
it
Attorney for Defe dant/ 12l
Date
Participant "
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsylvania
CO./City/Dist. of CUMBERLAND
Date of Order/Notice 05/04/09
Case Number (See Addendum for case summary)
Employer/Withholder's Federal EIN Number
DFAS MARINE CORPS
507109868
191 S 2008
08-2260 CIVIL
OOriginal Order/Notice
@Amended Order/Notice
OTerminate Order/Notice
OOne-Time Lump Sum/Notice
RE: GROOM, PAUL L. II
Employee/Obligor's Name (Last, First, MI)
Sent Electronically
DO NOT MAIL
MMMENWOMEW
224-47-9444
Employee/Obligor's Social Security Number
1991101958
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.
$ 864.00 per month in current child support
$ o. oo 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
$ 300.00 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 $ 1,164.00 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:
$ 267.88 per weekly pay period. $ 582. oo per semimonthly pay period
535.76 per biweekly pay period (every two weeks). $
REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10)
working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of
withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work
state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of
the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding,
the following information is needed (See #9 on page 2).
If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call
Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580
for instructions. PA FIPS CODE 42 000 00
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BY THE COURT: EDGAR B BAYLEY
(twice a month).
1,164.00 per monthly pay period.
Form EN-428
Service Type M OMB No.: 0970-0154 Worker I D $ IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
F1 If hhecked you are required to provide a copy of this form to yourgmployee. If yo?r employee works in a state that is
di Brent from the state that issued this order, a copy must be provi edd to your employee even if the box is not checked.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employee/obligor.
3. * Reporting the Paydate/Date of Withholding: You must report the paydate/date of withholding when sending the payment. The
paydate/date of withholding is the date on which amount was withheld from the employee's wages. You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. 5399900000
THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : C] THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: O
EMPLOYEE'S/OBLIGOR'S NAME:CROOM, PAUL L. II
EMPLOYEE'S CASE IDENTIFIER: 1991101958
DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
LAST KNOWN PHONE NUMBER:
FINAL PAYMENT AMOUNT:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment,
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (CCPA) (15 U.S.C. 1673 (b)); or 2) the amounts allowed by the State or Tribe of the employee's/obligor's principal place of
employment. Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes, Social
Security taxes, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is
supporting another family and 60% of the disposable income if the obligor is not supporting another family.However, that 50% limit is
increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State, you may
deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section.
Arrears greater than 12 weeks : If the Order Information does not indicate whether the arrears are greater than 12 weeks, then the
employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts
allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser of
the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of the
CCPA 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:
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-428
Service Type M OMB No.: 0970-0154 Worker ID $ IATT
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: CROOM, PAUL L. II
PACSES Case Number 042109965 PACSES Case Number 507109868
Plaintiff Name Plaintiff Name
SARA E. THUMA-GROOM SARA E. THUMA-CROOM
Docket Attachment Amount Docket Attachment Amount
08-2260 CIVIL$ 300.00 00191 S 2008 $ 864.00
Child(ren)'s Name(s): DOB Child(ren)'s Name(s):
SOJOURNER Q. GROOM
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):
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
DOB Child(ren)'s Name(s):
PACKS Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
DOB Child(ren)'s Name(s):
DOB
12/06/06
DOB
DOB
Service Type M Addendum Form EN-428
OMB No.: 0970-0154 Worker I D $ IATT
RLED-01'FICF
OF 114,E
2009 MAY -S PH 3: 10
V?tiY C" .' ,) a )JNlry
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT [A- aAlDb 0,1 VIL.
State Commonwealth of Pennsylvania 5D-1 I D 9'9 (o 2 OOriginal Order/Notice
Co./City/Dist. of CUMBERLAND 1 I S -;;, I) N Amended Order/Notice
Date of Order/Notice 01/05/11 OTerminate Order/Notice
Case Number (See Addendum for case summary) (Done-Time Lump Sum/Notice
RE: CROOM, PAUL L. II
Employer/Withholder's Federal EIN Number Employee/Obligor's Name (Last, First, MI)
DFAS MARINE CORPS
Sent Electronically
DO NOT MAIL
224-47-9444
Employee/Obligor's Social Security Number
1991101958
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.
$ 864.00 per month in current child support
$ 0.00 per month in past-due child support Arrears 12 weeks or greater? 0X,1164 n or
$ 0.00 per month in current medical support .. ?
i = ?.I
'
$ 0.00 per month in past-due medical support m
r -
y
?
$ 0.00 per month in current spousal support rT n
" r
$ o . oo per month in past-due spousal support can C)
$ o . o o per month for genetic test costs Yeti
$ o . o o per month in other (specify) r-; c)
$ one-time lump sum payment ' C1 "jc
for a total of $ 864.00 per month to be forwarded to payee below. r
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:
$ 198. 84 per weekly pay period. $ 432.00 per semimon thly pay pe riod
$ 397.68 per biweekly pay period (every two weeks)
(twice a month).
864.00 per monthly pay period.
REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10)
working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of
withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work
state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of
the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding,
the following information is needed (See #9 on page 2).
Pennsylvania law (23 PA C.S. § 4374(b)) requires remittance by an electronic payment method if an employer is
ordered to withhold income from more than one employee and employs 15 or more persons, or if an employer has
a history of two or more returned checks due to nonsufficient funds. Please call the Pennsylvania State Collections
and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. PA FIPS CODE
42 000 00
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BY THE COURT: KEVIN A HESS
Form EN-428 Rev.1
Service Type M OMB No.: 0970-0154 Worker ID $IATT
av
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
EJ if4rheckei you are required to ffvide a?opy of this form to your mployee. If yo r employee works in a state that is
di Brent rom the state that issu this order, a copy must be provised to your employee even if the box is not checed
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. 5399900000
THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : ? THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: ?
EMPLOYEE'S/OBLIGOR'S NAME:CROOM, PAUL L. II
EMPLOYEE'S CASE IDENTIFIER: 1991101958
LAST KNOWN HOME ADDRESS:
LAST KNOWN PHONE NUMBER:
DATE OF SEPARATION:
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"1. of the disposable income if the obligor is
supporting another family and 60% of the disposable income if the obligor is not supporting another family.However, that 50% limit is
increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State, you may
deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section.
Arrears greater than 12 weeks : if the Order Information does not indicate whether the arrears are greater than 12 weeks, then the
employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts
allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser of
the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of the
CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amounts paid for health
care premiums in determining disposable income and applying appropriate withholding limits.
10. Additional info:
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state
that issued this order with respect to these items.
11. Send Termination Notice and
other correspondence to:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
Service Type M
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717) 240-6248 or
by internet www.childsupport.state.pa.us
Page 2 of 2
OMB No.: 0970-0154
Form EN-428 Rev.1
Worker 1 D $ IATT
.f
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: CROOM, PAUL L. II
PACKS Case Number 507109868
Plaintiff Name
SARA E. THUMA
Docket Attachment Amount
00191 S 2008 $ 864.00
Child(ren)'s Name(s): DOB
SOJOURNER Q. CROOM 12/06/06
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
Service Type M
Addendum
OMB No.: 0970-0154
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
PACKS Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
Form EN-428 Rev.1
Worker ID $IATT
SARA E. THUMA,
Plaintiff/Petitioner
VS.
PAUL L. CROOM, II,
Defendant/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 08-2260 CIVIL TERM
IN DIVORCE
PACSES CASE: 042109965
C)
Q X
CO
ORDER OF COURT
AND NOW to wit, this 5th day of January, 2011, it is hereby Ordered that the
h.J
C-
-ca
h?
i// )
....k L ? r
Cumberland County Domestic Relations Section dismisses their interest in the above captioned
Alimony matter as the account is paid in full and closed pursuant: to the parties' Marital
Settlement Agreement.
This Order shall become final twenty (20) days after the mailing of the notices of the
entry of the Order to the parties unless either party files a written. demand with the Office of the
Prothonotary for a hearing de novo before the Court.
BY THE COURT:
DRO: R.J. Shadday
xc: Petitioner
Respondent
Carol J. Lindsay, Esq.
Howard B. Krug, Esq..
Form OE-001
Service Type: M Worker: 21005
c .L
r
~''' T~~ Pf~O TF~~~ TAB ~.
20IZSEp -5 ~H~l: ~~
v ~~~i R~, AND ~
PF~1MS YLyANigNT }~
Nichole M. Staley O'Gorman, Esquire
ID #78966
1820 Linglestown Road
Harrisburg, PA 17110
(717) 236-9777
nogorman@staleyogormanlaw.com
Attorney for Plaintiff
SARA E. THUMA-GROOM,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
PAUL L. GROOM, II,
Defendant
NO. 08-2260 CIVIL
CIVIL ACTION - IN DIVORCE
NOTICE OF INTENTION TO RETAKE PRIOR NAME
Notice is hereby given that Plaintiff in the above matter, a Complaint in Divorce
having been filed to the above-caption on April 10, 2008, hereby elects to retake and
hereafter use her previous name of Sara E. Thuma.
.s' / ~
ara E. Thuma-Groom
g~~.~Pa aN~
a~`} i a3~v
1 ~~'
~~~~b2~~
'~-:
TO BE KNOWN AcS:
r,
.%
~.:
1, ~
ara E`ThGma
Sworn to and subscribed before me this'~day of , 2012.
Notary Public
C niiMONWEA TH O PEN YLVAN
NOTARIAL SEAL
ELIZABETH A. GOWNLEY, Notary Public
Susquehanna Twp., Dltuphin County
My Comm~sion Expires May 12, 2015
2