HomeMy WebLinkAbout08-2276Barbara Sumple-Sullivan, Esquire
Supreme Court 432317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
BRENDA L. REDDING, IN THE COURT OF COMMON PLEAS
Plaintiff
V.
ROBERT L. REDDING, JR.,
Defendant
CUMBERLAND COUNTY, PENNSYLVANIA
NO. C%- 99,749 Ctv"l lem
CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT, if you wish to defend against the claims set forth
in the following pages, you must take prompt action. You are warned that if you fail to do so the
case may proceed without you and a decree of divorce or annulment may be entered against you
by the Court. A judgment may also be entered against you for any other claim or relief requested
in these papers by the Plaintiff. You may lose money or property or other rights important to
you, including custody and visitation of your children.
When the grounds for a divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the Domestic
Relations Office at the County Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
Carlisle, Pennsylvania 17013
(717) 249-3166
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
BRENDA L. REDDING, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 4,P'?,Z 74
ROBERT L. REDDING, JR., CIVIL ACTION -LAW
Defendant IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Brenda L. Redding, an adult individual residing at 4060 Caissons Court,
Enola, Cumberland County, Pennsylvania 17025.
2. Defendant is Robert L. Redding, Jr., an adult individual residing at 439 Woodcrest
Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050.
3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six (6) months prior to filing this complaint.
4. The Plaintiff and Defendant were married on February 17, 1973 in Cumberland
County, Pennsylvania.
5. There are no minor children born of this marriage.
6. The parties separated on November 1, 2004.
7. There have been no prior actions for divorce or annulment between the parties.
8. Neither Plaintiff nor Defendant is in the military or naval service of the United States
or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940
and its amendments.
9. Plaintiff has been advised that counseling is available and that Plaintiff has the right to
request that the court require the parties to participate in counseling.
COUNT I - DIVORCE
NO FAULT
10. The averments in paragraphs 1 through 9, inclusive, of Plaintiffs Complaint are
incorporated herein by reference thereto.
11. The marriage is irretrievably broken and no possibility of reconciliation exists.
WIMREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with 3
3301 of the Pennsylvania Divorce Code.
COUNT II
EQUITABLE DISTRIBUTION
12. The averments in paragraphs 1 through 11 of Plaintiffs Complaint are incorporated
herein by reference thereto.
13. The Plaintiff requests the Court to equitably divide, distribute or assign the marital
property between the parties in such proportion as the Court deems just after consideration of all
relevant factors.
WHEREFORE, Plaintiff requests this Court to equitably divide said property in accordance
with Section 401(d) of the Pennsylvania Divorce Code.
COUNT III
SUPPORT, ALIMONY PENDENTE LITE AND ALIMONY
14. The averments in paragraphs 1 through 13, inclusive, of Plaintiffs Complaint are
incorporated herein by reference thereto.
15. Plaintiff requires reasonable support to adequately sustain herself with the standard of
living established during the marriage.
WHEREFORE, Plaintiff requests an award of Support, Alimony and Alimony Pendente Lite.
COUNT IV
ATTORNEY'S FEES AND COSTS
16. The averments in paragraphs 1 through 15, inclusive, of Plaintiffs Complaint are
incorporated herein by reference thereto.
17. Plaintiff is unable to sustain herself during the course of this litigation and has
employed Barbara Sumple-Sullivan, Esquire as counsel, but is unable to pay the necessary and
reasonable attorney's fees for said counsel, and the necessary and reasonable costs and expenses.
WHEREFORE, Plaintiff requests an award of counsel's fees and expenses.
WHEREFORE, Plaintiff, BRENDA L. REDDING, prays this Honorable Court to enter
judgment:
A. Awarding Plaintiff a decree in divorce;
B. Awarding Plaintiff support, alimony and alimony pendente lite;
C. Awarding Plaintiff counsel fees, costs and expenses;
D. Equitably distributing the marital property; and
E. Awarding other relief as the Court deems just and
Dated: ?/z , 2008
Parbara Sumple-Sullivan, Esquire
Attorney for Plaintiff
549 Bridge Street
New Cumberland, PA 17070-1931
(717) 774-1445
Supreme Court I.D. No. 32317
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
BRENDA L. REDDING, IN THE COURT OF COMMON PLEAS
Plaintiff
V.
ROBERT L. REDDING, JR.,
Defendant
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO.
CIVIL ACTION -LAW
IN DIVORCE
AFFIDAVIT REGARDING COUNSELING
I have been advised of the availability of marriage counseling and understand that I
may request that the Court require that my spouse and I participate in counseling.
2. I understand that the Court maintains a list of marriage counselors in the Domestic
Relations Office, which list is available to me upon request.
3. Being so advised, I do not require that the Court require that my spouse and I
participate in counseling prior to a divorce decree being handed down by the Court.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A
Section 4904 relating to unsworn falsification to authorities.
Dated:
BRENDA L. REDDIN
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
BRENDA L. REDDING, IN THE COURT OF COMMON PLEAS
Plaintiff
V.
ROBERT L. REDDING, JR.,
Defendant
: CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION -LAW
IN DIVORCE
VERIFICATION
I, Brenda L. Redding, hereby certify that the facts set forth in the foregoing COMPLAINT IN
DIVORCE are true and correct to the best of my knowledge, information and belief. I understand
that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating
to unsworn falsification to authorities.
Dated: 7 - /" e?
Brenda L. Redding
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Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
BRENDA L. REDDING, IN THE COURT OF COMMON PLEAS
Plaintiff
V.
ROBERT L. REDDING, JR.,
Defendant
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08 - 2276
CIVIL ACTION -LAW
IN DIVORCE
AFFIDAVIT OF SERVICE
I, Barbara Sumple-Sullivan, Esquire, do hereby certify that I served a copy of the
Complaint In Divorce in the above-captioned matter by United States Mail, Restricted Delivery,
Certified No. 7007 3020 0001 1089 2714, Return Receipt Requested, on the above-named
Defendant, Robert L. Redding, Jr., on April 29, 2008 at Defendant's last known address: 439
Woodcrest Drive, Mechanicsburg, Pennsylvania 17055. The original receipt and return
receipt card are attached hereto as Exhibit "A".
I hereby certify that the facts set forth above are true and correct to the best of my
knowledge, information and belief. I understand that any false statements made herein are
subject to penalties of 18 Pa. C.S.A. 34904 relating to unworn falsification to authorities.
Dated: 52008
Barbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070-1931
(717)-774-1445
Supreme Court ID #32317
Attorney for Plaintiff
Postal
CERTIFIED MAIL,,, RECEIPT
(DOMestic Mail Only; No Insurance Coverage Provided)
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EXHIBIT "A"
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Debra R. Mehaffie, Esquire
Scaringi & Scaringi, P.C.
2000 Linglestown Road, Suite 106
Harrisburg, PA 17110
(717) 657-7770
BRENDA L. REDDING,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
-v-
NO.08-2276 - CIVIL TERM
ROBERT L. REDDING, JR., : CIVIL ACTION - LAW
Defendant : IN DIVORCE
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Kindly enter the appearance of Debra R. Mehaffie, Esquire as counsel for Robert L.
Redding, Jr., in the above-captioned matter.
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Respectfully submitted:
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BRENDA L. REDDING,
Plaintiff
Vs.
ROBERT L. REDDING, JR.,
Defendant
MOTION FOR APPOINTMENT OF MASTER
Brenda L. Redding (Plaintiff) (EWAWW? moves the court to appoint a master with
respect to the following claims:
(x) Divorce Distribution of Property
() Annulment) Support
Alimony Counsel Fees
( Alimony Pendente Lite Costs and Expenses
and in support of the motion states:
(1) Discovery is complete as to the claims (s) for which the appointment of a master is
requested.
(2) The defendant (has) appeared in the action (per (by his attorney,
Debra R. Mehaf f ie , Esquire).
(3) The Staturory ground (s) for divorce OW (are)
3301(c) and 3301(d)
(4) Delete the inapplicable paragraph(s):
a. The action is not contested.
b. An agreement has been reached with respect to the following claims:
c. The action is contested with respect to the following claims:
Equitable Distribution, Support, Alimony Pendente Lite, Alimony,
(5) The action (involves) (does not involve) complex issues of law or fact Counsel fees, costs
(6) The hearing is expected to take one s
(7) Additional information, if - r evant to the motion:
Date: March 12, 2009
Print Attorney Name ......... Barbara
ORDER APPOINTING MASTER
AND NOW, , 20 09 ,
is appointed master with respect to the following claims:
Esquire
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Docket No. 08 - 2276
By the Court:
van, Esquire
I.D.: 32317
J.
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Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
BRENDA L. REDDING, : IN THE COURT OF COMMON PLEAS
Plaintiff
v.
ROBERT L. REDDING, JR.,
Defendant
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08 - 2276
CIVIL ACTION -LAW
IN DIVORCE
CERTIFICATE OF SERVICE
I, BARBARA SUMPLE-SULLIVAN, ESQUIRE, do hereby certify that on this date, I
served a true and correct copy of Plaintiff s Motion for Appointment of Master, in the above-
captioned matter upon the following individual(s), by United States first-class mail, postage
prepaid, addressed as follows:
Debra R. Mehaffie, Esquire
Scaringi & Scaringi
2000 Linglestown Road, Suite 106
Harrisburg, PA 17110
DATE: March 12, 2009
L Barbara Sumple-
Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070-1931
(717) 774-1445
Supreme Court I.D. 32317
Attorney for Plaintiff
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BRENDA L. REDDING,
Plaintiff
Vs.
ROBERT L. REDDING, JR.,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Docket No. 08 - 2276
Defendant
MOTION FOR APPOINTMENT OF MASTER
Brenda L. Redding (Plaintiff) (EWAWWZ? moves the court to appoint a master with
respect to the following claims:
( Divorce Distribution of Property
() Annulment) Support
(y) Alimony ¢?) Counsel Fees
(x) Alimony Pendente Lite Costs and Expenses
and in support of the motion states:
(1) Discovery is complete as to the claims (s) for which the appointment of a master is
requested.
(2) The defendant (has) ftemo appeared in the action (per (by his attorney,
Debra R. Mehaf f ie , Esquire).
(3) The Staturory ground (s) for divorce (are)
3301(c) and 3301(4)
(4) Delete the inapplicable paragraph(s):
a. The action is not contested.
b. An agreement has been reached with respect to the following claims:
c. The action is contested with respect to the following claims:
Equitable Distribution, Support, Alimony Pendente Lite, Alimony,
(5) The action (involves) (does not involve) complex issues of law or fact Counsel fees, costs
(6) The hearing is expected to take one ?s
(7) Additional information, if r evant to the motion:
Date: March 12, 2009
Print Attorney Name ......... Barbara Sumple-Sullivan, Esquire I.D.: 32317
AND NOW, y'1'?Gtiu?L i7 , 20 09 -- T/
is appointed master with respect to the following claims:
By Court:
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Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
BRENDA L. REDDING, IN THE COURT OF COMMON PLEAS
Plaintiff
v.
ROBERT L. REDDING, JR.,
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08 - 2276
: CIVIL ACTION - LAW
Defendant : IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
April 10, 2008.
2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days
have elapsed since the filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of
intention to request entry of the decree.
4. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
5. I verify that the statements made in this affidavit are true and correct. I
understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904
relating to unsworn falsification to authorities.
An z4L?
DATE: ACA f
BRENDA L. DD G
OF THE
2009 JUL 10 r= 1 3? 52
f •
BRENDA L. REDDING, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
-v- : NO. 08-2276 - CIVIL TERM
ROBERT L. REDDING, JR., : CIVIL ACTION - LAW
Defendant : IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) or 3301 (d}of the Divorce Code
was filed on April 10, 2008.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final Decree of Divorce after service of Notice of Intention
to Request Entry of the Decree.
I verify that the statements made in this Affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to
unworn falsification to authorities.
Date: 4"'R a20d q
ROBERT L. REDDING, JR., Defen an
2009 AL 10 F 3: 5 2
CU r? ,N.
BRENDA L. REDDING,
Plaintiff
VS.
ROBERT L. REDDING, JR.,
Defendant
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,. PENNSYLVANIA
NO. 08 - 2276 CIVIL
IN DIVORCE
ORDER OF COURT
AND NOW, this 0?0? ' 40 day of _ %?v ,
2009, the economic claims raised in the proceec'ng having been
resolved in accordance with a marital settlement agreement
dated June 22, 2009, 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 THE COURT,
1 a
- Q., Edgar B. Bayley, P. J.
cc: 'kiglrbara Sumple-Sullivan
Attorney for Plaintiff
/EI'E?bra R. Mehaffie
Attorney for Defendant
J
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OF HE--
2009 JUL 22 PH i -, 5 1
ENNSYLVANA
MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT, made this ?. day of June, 2009, by and between,
Robert L. Redding, Jr. (hereinafter referred to as "Husband"), and Brenda L. Redding
(hereinafter referred to as "Wife").
WITNESSETH:
WHEREAS, Husband and Wife, were lawfully married on February 17, 1973;
and
WHEREAS, the parties hereto have two emancipated children born of the
marriage, and
WHEREAS, the parties have lived separate and apart since November 1, 2004
and continue to do so within the meaning of the Pennsylvania Divorce Code; and
WHEREAS, the parties hereto are desirous of settling fully and finally their
respective financial and property rights and obligations as between each other, including,
without limitation, the settling of all matters between them relating to the ownership of
real and personal property, the support and maintenance of one another and, in general,
the settling of any and all claims and possible claims by one against the other or against
their respective estates.
NOW THEREFORE, in consideration of these premises, and of the mutual
promises, covenants and undertakings hereinafter set forth, and. for other good and
valuable consideration, the receipt and sufficiency of which is hereby acknowledged by
• 1
each of the parties hereto, Husband and Wife, each intending to be legally bound hereby,
covenant and agree as follows:
I. PERSONAL RIGHTS. Husband and Wife may, at all times hereafter,
live separate and apart. Each shall be free from all control, restraint, interference and
authority, direct or indirect by the other. Each may reside at such place or places as he or
she may select. Each may, for his or her separate use or benefit, conduct, carry on or
engage in any business, occupation, profession or employment which to him or her may
seem advisable. Husband and Wife shall not molest, harass, disturb or malign each other,
nor compel or attempt to compel the other to cohabit or dwell by any means or in any
manner whatsoever with him or her. Neither party will interfere with the use, ownership,
enjoyment or disposition of any property now owned by or hereafter acquired by the
other.
2. ADVICE OF COUNSEL. Each party acknowledges that he or she has
had the opportunity to receive independent legal advice from counsel of his or her
selection. Husband has been represented in this matter by Debra R. Mehaffie, Esquire,
and Wife has been represented by Barbara Sumple-Sullivan, Esquire. Each party fully
understands the facts and his or her legal rights and obligations, and 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, and that the execution of
this Agreement is not the result of any duress or undue influence, and that it is not the
result of any improper or illegal agreement or agreements. In addition, each party
2
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understands the impact of the Pennsylvania Divorce Code, whereby the court has the
right and duty to determine all marital rights of the parties including divorce, alimony,
alimony pendente lite, equitable distribution of all marital property or property owned or
possessed individually by the other, counsel fees and costs of litigation and, fully
knowing the same, each party hereto still desires to execute this Agreement
acknowledging that the terms and conditions set forth herein are fair, just and equitable to
each of the parties, and waives his and her respective right to have the Court of Common
Pleas of Cumberland County, or any other court of competent jurisdiction, make any
determination or order affecting the respective parties' rights to alimony, alimony
pendente lite, support and maintenance, equitable distribution, counsel fees and costs of
litigation.
3. DISCLOSURE OF ASSETS. Each of the parties hereto acknowledges
that he or she is aware of his or her right to seek discovery including, but not limited to,
written interrogatories, motions for production of documents, the taking . of oral
depositions, the filing of inventories and all other means of discovery permitted under the
Pennsylvania Divorce Code or the Pennsylvania Rules of Civil Procedure. Each of the
parties further acknowledges that he or she has had the opportunity to discuss with
counsel the concept of marital property under Pennsylvania law and each is aware of his
or her right to have the real and/or personal property, estate and assets, earnings and
income of the other assessed or evaluated by the courts of this Commonwealth or any
other court of competent jurisdiction. The parties do hereby acknowledge that there has
3 ll (t- 4A-
been full and fair disclosure to the other of his or her respective income, assets and
liabilities, whether such are held jointly, in the name of one party alone or in the name of
one of the parties and another individual or individuals. Husband and Wife represent and
warrant that each has disclosed to the other in full his or her respective assets, liabilities
and income and that this Agreement was negotiated and entered into on the basis of those
disclosures. The parties hereby acknowledge and agree that the division of assets as set
forth in this Agreement is fair, reasonable and equitable and is satisfactory to them. The
remedies available to either party for breach or violation of this provision shall be those
remedies available pursuant to law and equity. Each party retains the right to assert a
claim against the other for failure to fully and fairly disclose his or her income, assets and
liabilities if it later determined that there has been a failure to disclose, including but not
limited to a claim of constructive trust.
4. MUTUAL CONSENT DIVORCE. It is the intention of the parties, and
the parties agree, that by this Agreement they have resolved all ancillary economic issues
related to the dissolution of their marriage and thus any divorce action with respect to
these parties shall be limited to a claim for divorce only. The parties acknowledge that
Wife filed a Divorce Complaint on April 10, 2008 in the Court of Common Pleas in
Cumberland County, Pennsylvania to Docket No. 08-2276. The parties agree that
concurrent with the execution of this Agreement they will each execute an Affidavit of
Consent and Waiver of Notice of Intention to Request Entry of Divorce Decree so that
either party may finalize the divorce action in a timely fashion. Upon completion of the
4 9_L F- /JO_
divorce action, counsel obtaining a divorce decree shall supply to opposing party a copy
of the Decree.
5. EQUITABLE DISTRIBUTION. The parties have attempted to distribute
their marital property in a manner which conforms to the criteria set forth in Section 3502
of the Pennsylvania Divorce Code. The division of existing marital property is not
intended by the parties to constitute in any way a sale or exchange of assets, and the
division is being affected without the introduction of outside funds or other property not
constituting marital property. The division of property under this Agreement shall be in
full satisfaction of all marital rights of the parties, and shall be as follows:
A. Real Estate- 439 Woodcrest Drive, Mechanicsbur , Pennsvlvania 17055:
The parties acknowledge that the jointly titled real estate situated at 439
Woodcrest Drive, Mechanicsburg, Cumberland County, Pennsylvania, (hereinafter
referred to as the "Marital Home"), was utilized by the parties as the marital
residence. It is also acknowledged that the Marital Home is titled in joint names
and is presently encumbered one (1) mortgage held by :Ever Home Mortgage
Company, with a principal balance of approximately $58,000.00 as of the date of
this Agreement. The parties have agreed that the Marital Home has a fair market
value of $210,000.00 for purposes of equitable distribution. The parties further
acknowledge that Husband has paid the mortgage, real estate taxes and property
insurance since the time that Wife vacated the Marital Home, which was on or
about November 1, 2004. Husband has sole use and possession of same since that
5 PC 1Z '06LA-
time. As part of this Agreement, Wife does hereby waive and release any and all
claims she has against Husband for dissipation of the value of the home while it
has been under his sole care and possession as well as any claim for fair market
rental credit which may be due arising out of his occupancy of the property.
Husband desires and Wife agrees to transfer sole ownership of the Marital
Home to Husband. In exchange for Wife's relinquishment of rights, Wife shall be
due the sum of $83,250.00 from Husband. Wife shall receive the sum of
$83,250.00 in cash upon Husband's refinance of the existing mortgage. Husband
shall secure refinance of the obligation within ninety (90) days of the date of this
Agreement. In the event that Husband is not able to secure refinance, the house
shall be listed for sale with a realtor mutually agreeable to both parties. Both
parties shall be guided by the experience and expertise of the realtor regarding
pricing and maintenance of the home in order to effectuate a prompt sale. Pending
the sale, Husband shall continue to reside in the home and shall timely pay all
expenses related to the home including but not limited to taxes, insurance and
mortgage payments. Husband agrees to indemnify and hold Wife harmless for
any and all expenses related to the real estate, including, but not limited to
mortgage payments, taxes, insurance, assessment or any other costs incurred since
the date of separation. Upon sale, after deduction of all expenses, fees, and taxes
(including closing costs and realtor fees) in connection with the sale and after
6 ? 141-4
satisfaction of the lien of the existing mortgage, the proceeds shall be divided
between the parties in the following manner:
1. Wife shall receive the initial $83,250.00 in net proceeds; and
2. Husband shall receive the remainder of the proceeds.
Simultaneously with the execution of this agreement, Wife shall make,
execute and deliver a quitclaim deed transferring and granting to Husband all of
her right, title, claim and interest in and to the Marital Home. This deed shall be
held in escrow by Wife's counsel pending Husband's refinance and payment to
Wife of the above referenced $83,250.00 or the sale of the property to a third
party. Wife does hereby assign to Husband any and all rights, title and interest that
she may have in any insurance policies covering the real estate, or in proceeds
from such policies, or in any prepaid real estate taxes.
B. Division of Household and Personal Property. The parties have
previously divided between themselves to the mutual satisfaction, their household
and personal property upon agreement. It is agreed by the parties that all of the
personal property remaining in the real estate, shall be Husband's sole and
separate property.
Neither party shall make any claim to any such items of marital property
designated to the other party, or of the separate personal property of either party,
which are now in the possession and/or under the control of the other. Should it
become necessary, the parties each agree to sign, upon request, any titles or
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documents necessary to give effect to this paragraph. Property shall be deemed to
be in the possession or under the control of either parry if, in the case of tangible
personal property, it is physically in the possession or control of the party at the
time of the signing of this Agreement or in the case of intangible personal
property, if any physical or written evidence of ownership, such as passbook,
checkbook, policy or certificate of insurance or other similar writing is in the
possession or control of the party.
C. Motor Vehicles. The parties specifically agree that each party shall
retain exclusive use and ownership of the vehicles presently in his or her
possession. Wife shall keep the 1999 Volvo S70 GLT Sedan, which has no
encumbrance. Each party shall be fully and solely responsible for any and all
financial or other obligations associated with the vehicle(s) and he or she agrees to
indemnify and hold harmless the other party from any and all liability for same.
Each party agrees to execute any title or other documentation to effectuate the
terms of this paragraph as provided herein. The parties also agree to obtain the
necessary automobile insurance for the vehicle he or she is retaining with no lapse
in coverage.
D. Pension, Profit-Sharing. Retirement, or other Plans Related to
Employment.
The parties acknowledge that during their marriage Husband and Wife have
acquired various pension and retirement plans. It is the intention of the parties to
8 1 -??-L iz A14-
specifically address distribution of their respective plans in this Agreement.
Except as specifically provided in this Agreement, Wife and Husband hereby
mutually release and waive any and all interest, claim, or right that she or he may
have to any and all retirement benefit (including pension or profit sharing benefits)
or other similar benefits of the parry whether through employment or otherwise.
The distribution of retirement plans shall be as follows:
1. Wife's ROLM Defined Benefit. It is acknowledged that Wife
owns a ROLM Defined Benefit Plan. It is further acknowledged that said
benefit will provide monthly income of $227.50 payable on a single life
basis to Wife commencing the first day of the calendar month following her
65th birthday and continuing thereafter for life. The parties agree that Wife
shall keep this asset. Husband hereby transfers, assigns, and conveys to
Wife as her separate property, all of his right, title, claim and interest in and
to Wife's ROLM Defined Benefit. In addition, Husband agrees not to
make any present or future claim that he has any marital property interest in
and to the above-mentioned value of Wife's Roth IRA and releases and
renounces all rights, powers, and privileges in said Wife's Defined Benefit.
2. Wife's Vanguard Total Stock Index Fund (Roth IRA) Account
No. 0085/09964699325. It is acknowledged that Wife owns a Roth IRA,
with an approximate value of $9,092.23 as of March 31, 2009. The parties
agree that Wife shall keep this asset. Husband hereby transfers, assigns, and
9
conveys to Wife as her separate property, all of his right, title, claim and
interest in and to Wife's Roth IRA. In addition, Husband agrees not to
make any present or future claim that he has any marital property interest in
and to the above-mentioned value of Wife's Roth IRA and releases and
renounces all rights, powers, and privileges in said Roth IRA.
3. Husband's Vanguard Roth IRA Account No. 0085/
09954658900. It is acknowledged that Husband owns a Roth IRA, with an
approximate value of $10,010.00 as of April 17, 2009. The parties agree
that Husband shall keep this asset. Wife hereby transfers, assigns, and
conveys to Husband as his separate property, all of her right, title, claim
and interest in and to Husband's Roth IRA. In addition, Wife agrees not to
make any present or future claim that she has any marital property interest
in and to the above-mentioned value of Husband"s Roth IRA, and she
releases and renounces all rights, powers, and privileges in said Roth IRA.
4. Husband's Smith Barney SEP IRA Account No. 724-67710. It
is acknowledged that Husband owns a SEP IRA through his employment,
with an approximate value of $89,790.80 as of April 20, 2009. The parties
agree that Wife shall receive the sum of $30,347.08 in a rollover from this
account and the balance of the account shall be the sole and separate
property of Husband. Counsel for Wife shall prepare the necessary
documentation to effectuate the rollover. It is the intention of the parties
10 OL /z, AL.
that the rollover be completed without tax consequence to either party.
Wife's share shall be adjusted for interest or loss from April 20, 2009 until
the date of actual distribution.
5. Husband's Central PA Teamsters Retirement Income Plan. It
is acknowledged that Husband owns a Central PA Teamsters Retirement
Income Plan, with a value of $21,500.40 as of April 30, 2009. The parties
agree that Husband shall keep this asset. Wife hereby transfers, assigns,
and conveys to Husband as his separate property, all of her right, title,
claim and interest in and to Husband's Central Pa. Teamsters Retirement
Income Plan. In addition, Wife agrees not to make any present or future
claim that she has any marital property interest in and to the above-
mentioned value of Husband's Central Pa. Teamsters Retirement Income
Plan and she releases and renounces all rights, powers, and privileges in
said Central Pa. Teamsters Retirement Income Plan.
6. Husband's PA Teamsters Defined Benefit Plan. It is
acknowledged that Husband owns a PA Teamsters Defined Benefit Plan. It
is further acknowledged that said benefit will provide monthly income of
$236.91 payable to Husband commencing the first day of the month
coincident with or next following his attainment of normal retirement age,
being age 57. Husband has made application for said benefits and said
application is under review. The parties agree that until Wife reaches age
11 L9- Ack
65 and is able to draw on her ROLM annuity, Husband shall pay to Wife on
a monthly basis one half of the monthly annuity he is due from the PA
Teamsters Defined Benefit Plan. This shall include all retroactive
payments received by Husband from the date of his application. Payment
shall be made to Wife within five (5) days of Husband's receipt of the
monthly payment. Once Wife is able to receive her ROLM benefit,
Husband shall be entitled to receive 100% of his PA Teamsters monthly
benefit. Except as stated herein, Wife hereby transfers, assigns, and
conveys to Husband as his separate property, all of her right, title, claim
and interest in and to Husband's Pa Teamsters Defined Benefit Plan
including the survivor annuity.
E. Distribution of Cash Assets, Stocks and Bonds and Investment Accounts.
The parties agree that they have distributed to each, to their mutual
satisfaction, the sums deposited in the marital bank accounts. Except as
specifically provided in this Agreement, Wife and Husband hereby mutually
release and waive any and all interest, claim, or right that she or he may have to
any and all cash assets, stocks, bond and investment accounts or other similar
accounts of the party whether through employment or otherwise.
It is specifically agreed that the joint Waypoint Checking Account (now
known as Sovereign Bank) shall be Husband's sole and separate property. The
parties further agree that they shall retain as their respective sole and separate
12 2 L J
property any other depository or brokerage accounts, stocks, or bonds held in their
respective individual names. If either parry remains upon an account to be retained
by the other party, the parties agree that they shall take all steps that are necessary
to title the account to a sole name within thirty (30) days of the date of this
Agreement.
With respect to investment accounts acquired during the marriage, the
parties desire to specifically address distribution of these accounts as follows:
1. Vanguard Treasury Money Market Fund: The parties acknowledge
that they jointly own a Vanguard Treasury Money Market Fund, with a
value of $87,648.65 as of September 30, 2004. The parties further
acknowledge that $19,530.20 was used for expenses for their daughter
Abby and it is agreed by the parties that $19,530.20 and by agreement
constitutes non-marital property. Accordingly, the parties agree that the
marital portion that is divisible between the parties is $68,118.45. It is
further acknowledged that during separation, Husband advanced to Wife
$35,400.00 from said account as and for equitable distribution. The parties
hereby agree that the remaining approximate amount of $32,718.45 shall be
Wife's sole and separate property. Husband warrants he has made no
withdrawals from this account and the balance in the account is equal or
greater than $32,718.45. It is agreed that Wife shall be the sole owner of
this account and Husband shall sign all documents necessary to remove his
13 izLp,
e '
name from this account within five (5) days of the execution date of this
Agreement. Husband hereby transfers, assigns, and conveys to Wife as his
separate property, all of his right, title, claim and interest in and to the
Vanguard Treasury Money Market Fund. In addition, Husband agrees not
to make any present or future claim that he has any marital property interest
in the above-mentioned Vanguard Treasury Money Market Fund, and
releases and renounces all rights, powers, and privileges, in said Vanguard
Treasury Money Market Fund.
2. AmeriChoice Monev Market and Saving Accounts: The parties
acknowledge that they jointly own a Money Market Account at
AmeriChoice Federal Credit Union with an approximate value of
$14,171.96 as of September 30, 2003. It is acknowledged that this account
includes $5,000.00 received by WIFE in the form of an inheritance. It is
also acknowledged that the parties have a joint savings account with
AmeriChoice. It is agreed by the parties that Wife shall be the sole owner
of the AmeriChoice Money Market Account and Savings Accounts and
Husband shall sign all documents necessary to remove his name from these
accounts within five (5) days of the execution date of this Agreement.
Husband hereby transfers, assigns, and conveys to Wife as her separate
property, all of her right, title, claim and interest in and to the AmeriChoice
Money Market and Savings Accounts. In addition, Husband agrees not to
,?
14 1? ( Iz-
make any present or future claim that he has any marital property interest in
the above-mentioned AmeriChoice Money Market and Savings Accounts,
and releases and renounces all rights, powers, and privileges in said
AmeriChoice Money Market and Savings Accounts.
3. Metropolitan Life Insurance Stock: The parties acknowledge that
Husband owns approximately 53 shares of Metropolitan Life Insurance
Stock for a present total approximate value of $1,206.81. The parties agree
that Husband shall keep this asset and that Wife waives any and all interests
she may have in this asset. Wife hereby transfers, assigns, and conveys to
Husband as his separate property, all of her right, title, claim and interest in
and to the Metropolitan Life Insurance Stocks. In addition, Wife agrees not
to make any present or future claim that she has any marital property
interest in the above-mentioned Metropolitan Life Insurance Stocks, and
releases and renounces all rights, powers, and privileges in said
Metropolitan Life Insurance Stocks.
4. Irwin Stock: The parties acknowledge that Husband owns Stock in
Irwin Associates, Inc., through his employment, with an unknown value.
The parties agree that Husband shall keep this asset and that Wife waives
any and all interests she may have in this asset. Wife hereby transfers,
assigns, and conveys to Husband as his separate property, all of her right,
title, claim and interest in and to the Irwin Stocks. In addition, Wife agrees
15 1
1
not to make any present or future claim that she has any marital interest in
the above-mentioned Irwin Stocks, and releases and renounces all rights,
powers, and privileges in said Irwin Stocks.
F. Life Insurance. Life insurance policies shall be retained by the titled owner
and the other party shall waive any and all rights to same. There shall be no
restrictions on either parry regarding designations of beneficiaries nor shall there
be any other limitations regarding the financing, continuation, or termination of
any life insurance policies held by either of the parties. 'With respect to specific
insurance policies, the parties desire to address distribution of these assets as
follows:
1. New England Life Insurance - Husband owns a whole life insurance
policy through New England Life Insurance with an approximate cash
value of $50,953.17 as of April, 2009. Husband shall retain this asset and
he shall be the sole owner of this policy. Wife hereby transfers, assigns, and
conveys to Husband as his separate property, all of her right, title, claim
and interest in and to the New England Life Insurance policy. In addition,
Wife agrees not to make any present or future claim that she has any
marital property interest in the above-mentioned New England Life
Insurance policy, and releases and renounces all rights, powers, and
privileges in said New England Life Insurance policy.
16 _L2 w?
Notwithstanding the above, Husband agrees to name Wife as
irrevocable beneficiary on the policy for an amount equal to his outstanding
alimony obligation as set forth in paragraph 9 of this Agreement. This
coverage sum shall be $125,000.00 at the time of execution of this
Agreement. Husband can reduce on Wife's benefit annually on the
anniversary of this Agreement to reflect the reduced actual outstanding
balance which may be due to Wife. Notwithstanding the ability to reduce
the coverage as his alimony obligation is reduced, Husband shall retain
insurance coverage on his life for his Wife's benefit at a minimum of
$25,000.00 death benefit for the benefit of Wife at least until the receipt of
her initial ROLM Pension payment.
2. Penn Mutual Life Insurance - During the marriage Husband owned a
life insurance policy through Penn Mutual Life Insurance, Husband
warrants that this policy has now expired and has no cash value.
6. DEBTS. Husband represents and warrants to Wife that since the separation
he has not, and in the future he will not contract or incur any debt or liability for which
Wife or her estate might be responsible, and he shall indemnify and save Wife harmless
from any and all claims or demands made against her by reason of such debt or obligation
incurred by him since the date of said separation, except as otherwise set forth herein.
Wife represents and warrants to Husband that since the separation she has not, and
in the future she will not, contract or incur any debt or liability for which Husband or his
17 AIL
estate might be responsible, and she shall indemnify and save Husband harmless from
any and all claims or demands made against him by reason of such debts or obligations
incurred by her since the date of said separation, except as otherwise set forth herein.
The parties also agree to the following:
a. Marital Debt. During the course of the marriage, Husband and Wife have
incurred certain bills and obligations that are marital debt. It is their specific
desire to address a distribution of those debts herein. The parties agree that
each party shall retain as his or her sole and separate obligation the marital
debt as described in this section.
b. General Provision. Any debt herein described shall be deemed to include
the current balance owed on the debt as of the date of execution of this
Agreement.
C. Wife's debts. Wife shall be solely responsible for the following bills and
debts: Any and all other debts, liabilities, obligations, loans, credit card
accounts, and the like incurred in Wife's sole name, and not otherwise
provided for herein. It is estimated that Wife's marital debt is $3,500.00 for
debts associated with her VISA and Mastercards.
d. Husband's Debts. Husband shall be solely responsible for the following
bills and debts: Any and all other debts, liabilities, obligations, loans, credit
card accounts, and the like incurred in Husband's sole name, and not
otherwise provided for herein.
e. Indemnification. Each party agrees to hold the other harmless from any
and all liability which may arise from the aforesaid bills which pursuant to
the terms herein are not the responsibility of the other party. This includes
but is not limited to any attorney's fees and costs incurred by the other
party as the result of defending against the obligation and/or enforcing the
provisions of this indemnification.
f. No Further Charges on Joint Debts. Neither party shall make any further
charges on any joint debt for which the other party may be responsible, and
if said charges are made in violation of this Agreement, then the party
incurring said charge shall immediately repay same. From the date of this
Agreement, each party shall only use those credit accounts or incur such
further obligations for which that party is individually and solely liable and
18 LG7-,
the parties shall cooperate in closing any remaining accounts which provide
for joint liability.
g. Non-Disclosed Liabilitv. Any liability not disclosed in this Agreement
shall be the sole responsibility of the party who has incurred or may
hereafter incur it, and the party incurring or having incurred said debt shall
pay it as it becomes due and payable.
7. INCOME TAX. The parties have heretofore filed joint federal and state tax
returns. Both parties agree that, in the event any deficiency in federal, state or local
income tax is proposed or any assessment of any such tax is made against either of them,
each will indemnify and hold harmless the other from and against any loss or liability for
any such tax deficiency or assessment and any interest, penalty and expense incurred in
connection therewith. Such tax, interest, penalty or expense shall be paid solely and
entirely by the individual who is finally determined to be the cause of the
misrepresentations or failures to disclose the nature and extent of his or her separate
income on the aforesaid joint returns.
8. BANKRUPTCY OR REORGANIZATION PROCEEDINGS: In the
event that either party becomes a debtor in any bankruptcy or financial reorganization
proceeding of any kind while any obligations remain to be performed by that party for the
benefit of the other party pursuant to the provisions of this Agreement, the debtor spouse
hereby waives, releases and relinquishes any right to claim any exemption (whether
granted under State or Federal law) to any property remaining in the debtor as a defense
to any claim made pursuant hereto by the creditor-spouse as set forth herein, including all
attorney fees and costs incurred in the enforcement of this paragraph or any other
19 17 L
y j \ 4
provision of this Agreement. No obligation created by this Agreement shall be discharged
or discharged or dischargeable, regardless of Federal or State law to the contrary, and
each party waives any and all right to assert that obligation hereunder is discharged or
dischargeable.
The parties mutually agree that in the event of bankruptcy or financial
reorganization proceedings by either party in the future, any monies to be paid to the
other party, or to a third party, pursuant to the terms of this Agreement, shall constitute
support and maintenance and shall not be discharged in bankruptcy.
9. ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT:
Husband agrees that he shall pay alimony to Wife in the amount of $1,400.00 per
month until December 31, 2015. Said alimony shall immediately terminate on December
31, 2015. This payment shall be non-modifiable in duration or amount except that the
alimony shall terminate earlier only in the event of Wife's co-habitation with a member
of the opposite sex, remarriage or death. The parties hereto acknowledge that said
alimony payments shall be deductible by Husband on his income tax returns and shall be
included as income to Wife on her income tax returns. This payment shall be made
through Domestic Relations by payroll deduction for Husband.
10. PAYMENT OF COUNSEL FEES. The parties acknowledge that they are
each Responsible for payment of their own counsel fees and costs associated with their
divorce and support, alimony pendente lite, and alimony disputes. Neither party shall
Iq L E A?_
20
seek contribution from the other for counsel fees or costs incurred through the date of
execution of this Agreement.
11. WAIVER OF INHERITANCE RIGHTS. Unless otherwise specifically
provided in this Agreement, as of the execution date of this Agreement, Husband and
Wife each waives all rights of inheritance in the estate of the other, any right to elect to
take against the will or any trust of the other or in which the other has an interest, and
each of the parties waives any additional rights which said party has or may have by
reason of their marriage, except the rights saved or created by the terms of this
Agreement. This waiver shall be construed generally and shall include, but not be limited
to, a waiver of all rights provided under the laws of Pennsylvania. or any other
jurisdiction.
12. WAIVER OF BENEFICIARY DESIGNATION. Unless otherwise
specifically set forth in this Agreement, each party hereto specifically waives any and all
beneficiary rights and any and all rights as a surviving spouse in and to any asset, benefit
or like program carrying a beneficiary designation which belongs to the other party under
the terms of this Agreement, including, but not limited to, pensions and retirement plans
of any sort or nature, deferred compensation plans, life insurance policies, annuities,
stock accounts, bank accounts, final pay checks or any other post-death distribution
schemes, and each party expressly states that it is his and her intention to revoke by the
terms of this Agreement any beneficiary designations naming the other which are in
effect as of the date of execution of this Agreement. If and in the event the other party
21
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continues to be named as beneficiary and no alternate beneficiary is otherwise
designated, the beneficiary shall be deemed to be the estate of the deceased party.
13. WAIVER OF CLAIMS. Except for the obligations of the parties contained
in this Agreement and such rights as are expressly reserved herein, each party gives to the
other by the execution of this Agreement an absolute and unconditional release and
discharge from all causes of action, claims, rights or demands whatsoever in law or in
equity, which either party ever had or now has against the other.
14. PRESERVATION OF RECORDS. Each party will keep and preserve for a
period of four (4) years from the date of their divorce decree all financial records relating
to the marital estate and each party will allow the other party access to those records in
the event of tax audits.
15. MODIFICATION. No modification, rescission, or amendment to this
Agreement shall be effective unless in writing signed by each of the parties hereto.
16. SEVERABILITY. If any provision of this Agreement is held by a court of
competent jurisdiction to be void, invalid or unenforceable, the remaining provisions
hereof shall nevertheless survive and continue in full force and effect without being
impaired or invalidated in any way.
17. BREACH. If either party hereto breaches any provision hereof, the other
party shall have the right, at his or her election, to sue for damages for such breach, or
seek such other remedies or relief as may be available to him or her. The non-breaching
22
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party shall be entitled to recover from the breaching party all costs, expenses and legal
fees actually incurred in the enforcement of the rights of the non--breaching party.
18. WAIVER OF BREACH. The waiver by one party of any breach of this
Agreement by the other party will not be deemed a waiver of any other breach or any
provision of this Agreement.
19. APPLICABLE LAW. All acts contemplated by this Agreement shall be
construed and enforced under the substantive laws of the Commonwealth of
Pennsylvania (without regard to the conflict of law rules applicable in Pennsylvania) in
effect as of the date of execution of this Agreement.
20. DATE OF EXECUTION. The "date of execution" or "execution date" of
this Agreement shall be defined as the date upon which the parties signed the Agreement
if they do so on the same date, or if not on the same date, then the date on which the
Agreement was signed by the last party to execute this Agreement.
21. EFFECTIVE DATE. This Agreement shall become effective and binding
upon both parties on the execution date.
22. EFFECT OF RECONCILIATION COHABITATION OR DIVORCE. This
Agreement shall remain in full force and effect and shall not be abrogated even if the
parties effect a reconciliation, cohabit as husband and wife or attempt to effect a
reconciliation. This Agreement also shall continue in full force and effect in the event of
the parties' divorce. There shall be no modification or waiver of any of the terms hereof
23 gLI?_ 44
. • i )
unless the parties in writing execute a statement declaring this Agreement or any term of
this Agreement to be null and void.
23. HEADINGS NOT PART OF AGREEMENT. Any headings preceding the
text of the several paragraphs and subparagraphs hereof are inserted solely for
convenience of reference and shall not constitute a part of this Agreement nor shall they
affect its meaning, construction or effect.
24. AGREEMENT BINDING ON PARTIES AND HEIRS. This Agreement
shall bind the parties hereto and their respective heirs, executors, administrators, legal
representatives, assigns, and successors in any interest of the parties.
25. ENTIRE AGREEMENT. Each party acknowledges that he or she has
carefully read this Agreement; that he or she has sought sufficient legal advice from legal
counsel of his or her own choice, if any, and has executed it voluntarily and in reliance
upon his or her own attorney, if any; and that this instrument expresses the entire
agreement between the parties concerning the subjects it purports to cover and supersedes
any and all prior agreements between the parties. This Agreement should be interpreted
fairly and simply, and not strictly for or against either of the parties.
26. MUTUAL COOPERATION. Each party shall, on demand, execute and
deliver to the other any deeds, bills of sale, assignments, consents to change of
beneficiary designations, tax returns, and other documents, and shall do or cause to be
done every other act or thing that may be necessary or desirable to effectuate the
provisions and purposes of this Agreement. If either party unreasonably fails on demand
24 J/c'`?
y c • M
to comply with these provisions, that party shall pay to the other party all attorney's fees,
costs, and other expenses actually incurred as a result of such failure.
27. AGREEMENT NOT TO BE MERGED. This Agreement may be
incorporated into a decree of divorce for purposes of enforcement only, but otherwise
shall not be merged into said decree. The parties shall have the right to enforce this
Agreement under the Divorce Code of 1980, as amended, and in addition, shall retain any
remedies in law or in equity under this Agreement as an independent contract. Such
remedies in law or equity are specifically not waived or released.
28. BINDING EFFECT. BY SIGNING THIS AGREEMENT, EACH PARTY
ACKNOWLEDGES HAVING READ AND UNDERSTOOD THE ENTIRE
AGREEMENT, CONSISTING OF TWENTY-SIX (26) PAGES AND EACH PARTY
ACKNOWLEDGES THAT THE PROVISIONS OF THIS AGREEMENT SHALL BE AS
BINDING UPON THE PARTIES AS IF THEY WERE ORDERED BY THE COURT
AFTER A FULL HEARING.
IN WITNESS WHEREOF, and intending to be legally bound hereby, the parties
hereto have hereunto set their hands and seals the day and year first: above written.
ROBERT L. REDDING.-JR//
BRENDA L. REDDING (;?
25
4 , ti
COMMONWEALTH OF PENNSYLVANIA
: ss.
COUNTY OF DAUPHIN
On this L44 day of 11
2009 before me, 'the undersigned officer,
personally appeared Robert L. Redding, Jr., known to me (or satisfactorily proven) to
be the person whose name is subscribed to the within Agreement, and acknowledged that
he executed the same for the purposes therein contained.
NOTARIAL SEAL
AMANDA L EMERSON
Notary Pumit Notary Public
SUSQUEHANNA TWP, DAUPHIN COUNTY
My Commission Expiras Jun 2, 2012
COMMONWEALTH OF PENNSYLVANIA
: ss.
COUNTY OF CUMBERLAND
On this day of June, 2009, before me, the undersigned officer, personally
appeared Brenda L. Redding, known to me (or satisfactorily proven) to be the person
whose name is subscribed to the within Agreement, and acknowledged that she executed
the same for the purposes therein contained.
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal Public
Barbara Sumple-Sullivan, Notary Nevi Cumberland Boro. Cumberland County
My Commission E)ires Nov.15, 2011
Member, Pennsylvania Association of Noteries
26
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.?.UG Jam.. a ? 7.
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
BRENDA L. REDDING, IN THE COURT OF COMMON PLEAS
Plaintiff
V.
ROBERT L. REDDING, JR.,
Defendant
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08 - 2276
CIVIL ACTION -LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
43301(c) OF THE DIVORCE CODE
I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed with the
prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statement herein are made subject to the penalties of 18 Pa.C.S. 34904 relating to unsworn
falsification to authorities.
??.
DATE: o 9
BRENDA L. REDDING
O PE: F-7,77
2009 JUL 31 PM 3: PS
BRENDA L. REDDING,
Plaintiff
-v-
ROBERT L. REDDING, JR.,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08-2276 - CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER SECTION 3301(c)(d) OF THE DIVORCE CODE
I consent to the entry of a final Decree of Divorce without Notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a Divorce Decree is entered by the
Court and that a copy of the Decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this Waiver are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn
falsification to authorities.
Date: aZ 'woq 4y? / -
ROBERT L. REDDING, JR., endant
R LE
2099 JUL 31 Ph 'j* 0 3
P-I
r.
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
BRENDA L. REDDING, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
: NO. 08 - 2276
ROBERT L. REDDING, JR., CIVIL ACTION -LAW
Defendant 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: Certified Mail-Restricted Delivery on April
29, 2008.
3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code:
by Plaintiff. June 22, 2009; by Defendant: June 24, 2009.
4. Related claims pending: All matters have been resolved between the parties
pursuant to the Marital Settlement Agreement dated June 22, 2009 and incorporated, but
not merged, into the Decree. See paragraph 27, page 25.
5. Date Plaintiffs Waiver of Notice in §3301(c) Divo e as file ith Prothonotary: July
27, 2009. Date Defendant's Waiver of Notice in §3301(c) orc was ed ith Prothonotary: July
27, 2009.
Dated: July 24, 2009
Barbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070-1931
(717)-774-1445
Supreme Court ID #32317
Attorney for Plaintiff
J
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
BRENDA L. REDDING, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 08 - 2276
ROBERT L. REDDING, JR., CIVIL ACTION -LAW
Defendant IN DIVORCE
CERTIFICATE OF SERVICE
I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and
correct copy of the foregoing Plaintiffs Praecipe to Transmit Record, in the above-captioned
matter upon the following individual by first class mail, postage prepaid, addressed as follows:
Debra R. Mehaffie, Esquire
DATED: July 24, 2009
Scaringi & Scaringi
2000 Linglestown Road, Suite
Harrisburg, PA 17 W -Z
Barbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
Supreme Court I.D. No. 32317
Attorney for Plaintiff
OF THE
2009 JUL 3 ( 0'3
Ty
BRENDA L. REDDING
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
ROBERT L. REDDING, JR.
NO. 08 - 2276
DIVORCE DECREE
AND NOW, it is ordered and decreed that
BRENDA L. REDDING plaintiff, and
ROBERT L. REDDING, JR. , defendant, are divorced from the
bonds of matrimony.
Any existing spousal support order shall hereafter be deemed an order for
alimony pendente lite if any economic claims remain pending.
The court retains jurisdiction of any claims raised by the parties to this action
for which a final order has not yet been entered. Those claims are as follows: (If no
claims remain indicate "None.")
None. All matters have been resolved between the parties pursuant to the Marital
Settlement Agreement dated June 22, 2009 and incorporated, but not merged, into the
Decree.
Attest: J.
N? AA
Prot onotary
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 08-2276 CIVIL
State Commonwealth of Pennsylvania
CO./City/Dist. of CUMBERLAND
Date of Order/Notice 08/06/09
Case Number (See Addendum for case summary)
Employe r/Withholder's Federal EIN Number
IRWIN ASSOCIATES INC
PO BOX 5187
HARRISBURG PA 17110-0187
Employee/Obligor's Name (Last, First, MI)
181-42-9866
Employee/Obligor's Social Security Number
5453102023
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 1,400.00
$ 0.00
$ 0.00
$ 0.00
per month in current child support
per month in past-due child support
per month in current medical support
per month in past-due medical support
per month in current spousal support
per month in past-due spousal support
per month for genetic test costs
per month in other (specify)
one-time lump sum payment
for a total of $ 1,400.00 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:
$ 323.08 per weekly pay period. $ 700.00 per semimonthly pay period
(twice a month)
$ 646.15 per biweekly pay period (every two weeks) $ 1, 400.00 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 MA/L. X4
BY THE COURT:
Arrears 12 weeks or greater? 0 yes ® no
O original Order/Notice
772110277 OAmended Order/Notice
754 S 2008 OTerminate Order/Notice
QOne-Time Lump Sum/Notice
RE: REDDING, ROBERT L. JR
Kevin A. Hess, Judge
DRO: R.J. Shadday Form EN-028 Rev.5
Service Type M OMB No.: 0970-0154 Worker ID $IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If 4hecke?l you are required to provide a opy of this form to yourg l your lemo r employee vYorks in g state that is
Brent di the state that issued this or?er, a copy must be prove ployee 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
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'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. 2321541940
THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : I] THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 0
EMPLOYEE'S/OBLIGOR'S NAME: REDDING, ROBERT L. JR
EMPLOYEE'S CASE IDENTIFIER: 5453102023 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 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 Form EN-028 Rev.5
Service Type M OMB No.: 0970-0154 Worker ID $IATT
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: REDDING, ROBERT L. JR
PACKS Case Number 312111065
Plaintiff Name
BRENDA L. REDDING
Docket Attachment Amount
08-2276 CIVIL$ 1,400.00
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
Service Type M
PACKS Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
Addendum
OMB No.: 0970-0154
Form EN-028 Rev.5
Worker ID $IATT
2 G C ; AUG 10 l "E 11; 0 J
t
L,, r `
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Defendant Name: ROBERT L. REDDING JR
Member ID Number: 5453102023
Please note: All correspondence must include the Member ID Number.
ORDER OF ATTACHMENT OF UNEMPLOYMENT COMPENSATION BENEFITS
Financial Break Down of Multiple Cases on Attachment
Plaintiff Name
BRENDA L. REDDING
PACSES Docket
Case Number Number
312111065 08-2276 CIVIL
TOTAL ATTACHMENT AMOUNT:
Attachment Amount/kR enc.
z
$ 1,400.00 /MOTTH
$ T
1
i
CF
....
$ rZ:
1,400.00
-fi
.0
Now, by Order of this Court, the Department of Labor and Industry, , Office of Unemployment
Compensation Benefits (OUCB), is hereby directed to attach the lesser of $ :322.19
per week, or 50 %, of the Unemployment Compensation benefits otherwise payable to the Defendant,
ROBERT L. REDDING JR Social Security Number XXX-XX- 9866 ,
Member ID Number 5453102023 . OUCB is ordered to remit the amount attached to the Department of
Public Welfare (DPW). DPW shall forward the amount received from OUCB to the Domestic Relations Section
of this Court for support and/or support arrearages.
If the Defendant's Unemployment Compensation benefits are attached by another Court or Courts for
support and/or support arrearages, DPW may reduce the amount attached under this Order so that the total
amount attached does not exceed the maximum amount subject to garnishment pursuant to 15 U.S.C. § 1673
(b)(2) and 23 Pa. C.S.A. § 4348 (g).
This Order shall be effective upon receipt of the notice of the Order by the OUCB and shall remain in
effect until the Defendant's entitlement to Unemployment Compensation benefits, under the Application for
Benefits dated JANUARY 2, 2 011 is exhausted, expired or deferred.
OUCB shall comply with this Order, unless it is amended or vacated by subsequent Order of this Court.
All questions, challenges or obligations to this Order shall be directed to the Domestic Relations Section of this
Court.
BY THE COURT
Date of Order: JAN 11 2011
V. MnalcLnCL , JUDGE
Form EN-530 Rev.2
Service Type M Worker ID $ IATT
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT ac? - ?a,? tv C )11 1
State Commonwealth of Pennsylvania OOriginal Order/Notice
Co./City/Dist. of CUMBERLAND (Amended Order/Notice
Date of Order/Notice 01/13/11 XOTerminate Order/Notice
Case Number (See Addendum for case summary) OOne-Time Lump Sum/Notice
RE: REDDING, ROBERT L. JR
Employer/Withholder's Federal EIN Number Employee/Obligor's Name (Last, First, MI)
181-42-9866
Employee/Obligor's Social Security Number
IRWIN ASSOCIATES INC 5453102023
PO BOX 5187 Employee/Obligor's Case Identifier
HARRISBURG PA 17110-0187 (See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 0.00 per month in current child support
$ o. oo per month in past-due child support Arrears 12 weeks or greater? Dyes ® np.,
$ 0.00 per month in current medical support
- - "?
$ o. oo per month in past-due medical support
per month in current spousal support ? ;M'
$ 0.00
$ o . oo per month in past-due spousal support . :V
$ o.oo p Z)
per month for genetic test costs `f r
?-
$ 0.00 per month in other (specify) =$'
$ one-time lump sum payment
C t -
for a total of $ o. o o per month to be forwarded to payee below. 7'-
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 0. oo per weekly pay period. $ 0. oo per semimonthly pay period
(twice a month)
$ o . 00 per biweekly pay period (every two weeks) $ 0.00 per monthly pay period.
REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10)
working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of
withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work
state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of
the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding,
the following information is needed (See #9 on page 2).
Pennsylvania law (23 PA C.S. § 4374(b)) requires remittance by an electronic payment method if an employer is
ordered to withhold income from more than one employee and employs 15 or more persons, or if an employer has
a history of two or more returned checks due to nonsufficient funds. Please call the Pennsylvania State Collections
and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. PA FIPS CODE
42 000 00
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER /D (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:
Vber+ H. U
Form EN-028 Rev.5
Worker ID $IATT
Service Type M OMB No.: 0970-0154
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
If hheckefl you are required to provide a?opy of this form to pour?mpto your emoUr employee v?orks in a state that is
di e v box is not chec ed.
ent rrom the state that issued this or er, a copy must be rovi ed ployee even if the
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. 2321541940
THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : 0 THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 13
EMPLOYEE'S/OBLIGOR'S NAME:REDDING, ROBERT L. JR
EMPLOYEE'S CASE IDENTIFIER: 5453102023 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 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 Form EN-028 Rev.5
Service Type M OMB No.: 0970-0154 Worker ID $IATT
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: REDDING, ROBERT L. JR
PACSES Case Number 312111065 PACSES Case Number
Plaintiff Name Plaintiff Name
BRENDA L. REDDING
Docket Attachment Amount Docket Attachment Amount
08-2276 CIVIL$ 0.00 $ 0.00
Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): 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
PACKS Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
Form EN-028 Rev.5
Worker ID $ IATT
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
C 3 : wz '
Defendant Name: ROBERT L. REDDING JR -
Member ID Number: 54
53102023 tr r" tv "
,
Please note: All correspondence must include the Member ID Number.
ORDER OF ATTACHMENT OF UNEMPLOYMENT COMPENSATION I E FTS ? ,?.
Financial Break Down of Multiple Cases on Attachment
PACSES Docket Attachment Amount/Fregunc
Plaintiff Name Case e Num Number Number Y
BRENDA L. REDDING 312111065 08-2276 CIVIL 1,400.00 / MONTH
1
/
$ S
TOTAL ATTACHMENT AMOUNT: $ 1,40""
Now, by Order of this Court, the Department of Labor and Industry, Office of Ur Aym&d
Compensation Benefits (OUCB), is hereby directed to attach the lesser of $ 322.19 per at?k, or 5 , of
the Unemployment Compensation benefits otherwise payable to the Defendant,
ROBERT L. REDDING JR Social Security Number XXX-XX-9866, Member ID Number 5453102023.
OUCB is ordered to remit the amount attached to the Department of Public Welfare (DPW). DPW shall
forward the amount received from OUCB to the Domestic Relations Section of this Court for support
and/or support arrearages.
If the Defendant's Unemployment Compensation benefits are attached by another Court or
Courts for support and/or support arrearages, DPW may reduce the amount attached under this Order so
that the total amount attached does not exceed the maximum amount subject to garnishment pursuant to
15 U.S.C. § 1673 (b)(2) and 23 Pa. C.S.A. § 4348 (g).
This Order shall be effective upon receipt of the notice of the Order by the OUCB and shall
remain in effect until the Defendant's entitlement to Unemployment Compensation benefits, under the
Application for Benefits dated JANUARY 1, 2012 is exhausted, expired or deferred.
OUCB shall comply with this Order, unless it is amended or vacated by subsequent Order of this
Court. All questions, challenges or obligations to this Order shall be directed to the Domestic Relations
Section of this Court.
BY THE COURT
Date of Order: JAN 2 ? 2012
Service Type M
Albert H. Masland JUDGE
Form EN-530
Worker ID $IATT
t,
INCOME WITHHOLDING FOR SUPPORT -3 1 ? I I I L)L S
0 ORIGINAL INCOME WITHHOLDING ORDERMOTICE FOR SUPPORT (IWO) Cl - ? /t ) L I
0 AMENDEDIWO l?
O ONE-TIMEORDER/NOTICE FOR LUMP SUM PAYMENT
0 TERMINATION OF IWO Date: 02/08/12
? Child Support Enforcement (CSE) Agency S Court ? Attorney ? Private Individual/Entity (Check One)
NOTE: This IWO must.be regular on its face. Under certain circumstances you must reject this IWO and return it to the sender (see IWO
instructions http•//www acf hhs oov/programs/csetnewhire/employer/publication/publication htm - forms). If you receive this document from
someone other than a State or Tribal CSE agency or a Court, a copy of the underlying order must be attached.
State/Tribe/Territory Commonwealth of Pennsylvania Remittance Identifier (include w/payment): 5453102023
City/County/Dist./Tribe CUMBERLAND Order Identifier: (See Addendum for order/docket lnformalton)
Private Individual/Entity CSE Agency Case Identifier: (See Addendum for case summary)
R&R PLASTER & DRYWALL CO, INC.
325 EASTERN DR
HARRISBURG PA 17111-3394
Employee/Obligor's Social Security Number
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Party/Obligee's Name (Last, First,
Middle)
Employer/Income Withholder's FEIN 023223485
Child(ren)'s Name(s) (Last, First, Middle) Child(ren)'s Birth Date(s)
RE: REDDING, ROBERT L. JR
Employee/Obligor's Name (Last, First, Middle)
181-42-9866
NOTE: This IWO must be regular on its face.
Under certain circumstances you must reject
this IWO and return it to the sender (see IWO
instructions
http://www acf hhs gov/2roarams/cse/newhire/
emi2loyer/publication/[)ublication.htm - form. If
you receive this document from someone other
than a State or Tribal CSE agency or a Court, a
copy of the underlying order must be attached.
0232234850
See Addendum for dependent names and birth dates associated with cases on
G'7
ORDER INFORMATION: This document is based on the support or withholding order from CUWI
C' -Iv,
Commonwe a - .
alth of Pennsylvania (State/Tribe), You are required by law to deduct these amounts §;WthAmp /
-
obligor's income until further notice. i
,r
$ 0.00 per month in current child support f
$ 0.00 per month in past-due child support -Arrears 12 weeks or greater? Q ye$i n0X
".
$ 0.00 perm nth in current cash medical support N
$ 0
00 ''
.
per month in past-due cash medical support cr
$ 1,400.00 per month in current spousal support ?c Cn
$ 0.00 per month in past-due spousal support
$ 0.00 per month in other (must specify)
for a Total Amount to Withhold of $ 1,400.00 per month.
AMOUNTS TO WITHHOLD: You do not have to vary your pay cycle to be in compliance with the Order Information.
If your pay cycle does not match the ordered payment cycle, withhold one of the following amount:
$ 08per weekly pay period. $ 700.00 per semimonthly pay period (twice a month)
$ ra46 ,.fio per biweekly pay period (every two weeks) $ 1,400.00 per monthly pay period.
$ Lump Sum Payment: Do not stop any existing IWO unless you receive a termination order.
REMITTANCE INFORMATION: If the employee/obligor's principal place of employment is CUMBERLAND County,
Commonwealth of Pennsylvania (State/Tribe), you must begin withholding no later than the first pay period that
occurs ten (10) working days after the date of this Order/Notice. Send payment within seven 7 working days of the
pay date. If you cannot withhold the full amount of support for any or all orders for this employee/obligor, withhold up
to 55% of disposable income for all orders. If the employee/obligor's principal place of employment is not
CUMBERLAND County, Commonwealth of Pennsylvania (State/Tribe), obtain withholding limitations, time
requirements, and any allowable employer fees at htto://www acf hhs qov//programs/cse/newhire/employer/contacts/
contact map.htm for the employee/obligor's principal place of employment.
Document Tracking Identifier
Service Type M
OMB No.: 0970-0154
Form EN-028 01112
Worker ID $IATT
? Return to Sender [Completed by Employer/Income Withholder]. Payment must be directed to an SDU in
accordance with 42 USC §666(b)(5) and (b)(6) or Tribal Payee (see Payments to SDU below). If payment is not
directed to an SDU/Tribal Payee or this IWO is not regular on its face, you must check this box and return the IWO to
the sender.
Signature of Judge/Issuing Official (if required by State or Tribal law):
Print Name of Judge/Issuing Official: t "-
Title of Judge/Issuing Official
Date of Signature: EFB 0 9 2012
If the employee/obligor works in a State or for a Tribe that is different from the State or Tribe that issued this order, a copy of this IWO
must be provided to the employee/obligor.
? If checked, the employer/income withholder must provide a copy of this form to the employee/obligor.
ADDITIONAL INFORMATION FOR EMPLOYERSIINCOME WITHHOLDERS
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.
State-specific contact and withholding information can be found on the Federal Employer Services website located at:
m
http://www acf hhs ggv/proaramstcse/newhire/employer/contacts/contact map-ht
Priority: Withholding for support has priority over any other legal process under State law against the same income (USC 42
§666(b)(7)). If a Federal tax levy is in effect, please notify the sender.
Combining Payments: When remitting payments to an SDU or Tribal CSE agency, you may combine withheld amounts from
more than one employee/obligor's income in a single payment. You must, however, separately identify each employee/
obligor's portion of the payment.
Payments To SDU: You must send child support payments payable by income withholding to the appropriate SDU or to a
Tribal CSE agency. If this IWO instructs you to send a payment to an entity other than an SDU (e.g., payable to the custodial
party, court, or attorney), you must check the box above and return this notice to the sender. Exception: If this IWO was sent
by a Court, Attorney, or Private Individual/Entity and the initial order was entered before January 1, 1994 or the order was
issued by a Tribal CSE agency, you must follow the "Remit payment to" instructions on this form.
Reporting the Pay Date: You must report the pay date when sending the payment, The pay date is the date on which the
amount was withheld from the employee/obligor's wages. You must comply with the law of the State (or Tribal law if
applicable) of the employee/obligor's principal place of employment regarding time periods within which you must implement
the withholding and forward the support payments.
Multiple IWOs: If there is more than one IWO against this employee/obligor and you are unable to fully honor all IWOs due to
Federal, State, or Tribal withholding limits, you must honor all IWOs to the greatest extent possible, giving priority to current
support before payment of any past-due support. Follow the State or Tribal law/procedure of the employee/obligor's principal
place of employment to determine the appropriate allocation method.
Lump Sum Payments: You may be required to notify a State or Tribal CSE agency of upcoming lump sum payments to this
employee/obligor such as bonuses, commissions, or severance pay. Contact the sender to determine if you are required to
report and/or withhold lump sum payments.
Liability: If you have any doubts about the validity of this IWO, contact the sender. If you fail to withhold income from the
employee/obligor's income as the IWO directs, you are liable for both the accumulated amount you should have withheld and
any penalties set by State or Tribal law/procedure.
Anti-discrimination: You are subject to a fine determined under State or Tribal law for discharging an employee/obligor from
employment, refusing to employ, or taking disciplinary action against an employee/obligor because of this IWO.
OMB Expiration Date - 05/3112014. The OMB Expiration Date has no bearing on the termination date of the IWO; it identifies the version of the form currently in use.
Form EN-028 01/12
Service Type M Page 2 of 3 Worker ID $IATT
• J
Employer's Name: R&R PLASTER & DRYWALL CO, INC. Employer FEIN: 023223485
Employee/Obligor's Name: REDDING, ROBERT L. JR 5453102023
CSE Agency Case Identifier: (See Addendum for case summarvl Order Identifier: (See Addendum for ordertdocket information)
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/obligor's principal place of
employment (see REMITTANCE INFORMATION). 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, those limits increase 5% - to 55% and 65% - if the arrears are greater than 12 weeks. If permitted by the State
or Tribe, you may deduct a fee for administrative costs. The combined support amount and fee may not exceed the limit indicated in
this section.
For Tribal orders, you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employers/income
withholders who receive a State IWO, you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which
the employer/income withholder is located or the maximum amount permitted under section 303(d) of the CCPA (15 U.S.C. 1673 (b)).
Depending upon applicable State or Tribal law, you may need to also consider the amounts paid for health care premiums in
determining disposable income and applying appropriate withholding limits.
Arrears greater than 12 weeks? If the Order Information does not indicate that the arrears are greater than 12 weeks, then the
Employer should calculate the CCPA limit using the lower percentage.
Additional Information:
NOTIFICATION OF EMPLOYMENT TERMINATION OR INCOME STATUS: If this employee/obligor never worked for you or you
no longer withholding income for this employee/obligor, an employer must promptly notify the CSE agency and/or the sender by
returning this form to the address listed in the Contact Information below: 0232234850
Q This person has never worked for this employer nor received periodic income.
0 This person no longer works for this employer nor receives periodic income.
Please provide the following information for the employee/obligor:
Termination date:
Last known address:
Final Payment Date To SDU/Tribal Payee:
New Employer's Name:
New Employer's Address:
CONTACT INFORMATION:
To Employer/Income Withholder: If you have any questions, contact WAGE ATTACHMENT UNIT (Issuer name)
by phone at (717)1240-6225, by fax at (717) 240-6248, by email or website at: www.childsuQport.state.ga.us.
Send termination/income status notice and other correspondence to: DOMESTIC RELATIONS SECTION, 13 N. HANOVER ST.
P.O. BOX 320, CARLISLE PA 17013 (Issuer address).
To Employee/Obligor: If the employee/obligor has questions, contact WAGE ATTACHMENT UNIT (Issuer name)
by phone at (717) 240-6225, by fax at (717) 240-6248, by email or website at www.childsupport.state.pa.us.
Last known phone number:
Final Payment Amount:
IMPORTANT: The person completing this form is advised that the information may be shared with the employee/obligor.
Service Type M
OMB No.: 0970-0154
Page 3 of 3
Form EN-028 01/12
Worker ID $IATT
ADDENDUM
Summary of Cages on Attachment
Defendant/Obligor: REDDING, ROBERT L. JR
PACSES Case Number 312111065 PACSES Case Number
Plaintiff Name Plaintiff Name
BRENDA L. REDDING
Docket Attachment Amount Docket Attachment Amount
08-2276 CIVIL $ 1,400.00 $ 0.00
Child(ren)'s Name(s): DOB Child(ren)'s Name(s):
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
PACKS Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
DOB
PACKS 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
Addendum Form EN-028 01/12
Sarvice TVne M OMB No.: 097M 154 Worker ID $IATT
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
BRENDA L. REDDING
Plaintiff
vs.
ROBERT L. REDDING JR
Defendant
Order
) Docket Number: 08 -2276 CIVIL
) PACSES Case Number: 312111065
)
) Other State ID Number:
AND NOW to wit, this MARCH 25, 2014 it is hereby Ordered that:
The Cumberland County Domestic Relations Section dismisses its interest in the
above captioned alimony matter, pursuant to the Petitioner requesting that the
alimony case be closed and she remits any remaining balance.
BY THE COURT:
Service Type M
C
-t
Albert H. land JUDGE
Form 0E -520 02/11
Worker ID 21205
i 71((ecezL
d/ air¢
2 5 20I4
S CANNEIJ
MAR
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U
&(41.e_ .-,6/4,t
CUt- oi.c -t
at o 5-
el ,a/oxez
.ixice
.-1/,‘e_,
-
,
-NrY4 ,
Irl /
7a- *77-,50//
INCOME WITHHOLDING FOR SUPPORT
O ORIGINAL INCOME WITHNOLDING ORDER/NOTICE FOR SUPPORT (IWO)
D AMENDED IWO
O ONE-TMEORDR!NOTICE FOR LUMP SUM PAYMENT
C) TERMINATION OF IWO
.
��~
~ �� m�".:= �� ~ss El Court O Attorney 0 Private Indivi ual/Emity (Check One)
NOT�:-nno-tmumunt*O��n nmmumo�nnaeyoumumnqommm/,vuono�mmnmtnonemonr\voe/wu
inoh�cUnnoh�o�V"m^wv B�}�7O�154 inn�uoUono.od���vouece�e#hiodooumon from someone
� hs.gov/Program � �. '
other than a State or Tribal CSE agency or a Court, a copy of the underlying order must be attached.
3/Z ob5
��
_ ^�'7-7/. L��1
(�o c*un /�
Date: 03/25/14
State/Tribe/Territory Commonwealth of Pennsylvania
City/County/Dist./Tribe CUMBERLAND
pnvate|nuwuuaxenuty
Remittance Identifier (include 5453102023
Order Identifier: (See Addendum for order/docket information)
CSE Agency Case Identifier: (See Addendum for case summary)
R&R PLASTER & DRYWALL CO INC.
325 EASTERN DR
HARRISBURG PA 17111-3394
Employer/Income WithhoNer's FEIN 02322348
Child(ren)s Name(s) (Last, First, Middle)
ChiM(mm)'oEUnth Date(s)
RE: REDDING, ROBERT L. JR
Employee/Obligors Name (Last, First, Middle)
181'42'9866
Empioyoe/Ob|igorsSocia| Security Number
(See Addendum for plaintiff names
associated with cases on atfachment)
Custodial Party/Obligees Name (Last, First,
Middle)
NOTE: This IWO must be regular on its face.
Under certain circumstances you must reject
this IWO and retum 1 to the sender (see IWO
instructions
http://www.acthhs.gov/programs/cse/forms/
owe'0970-015* instructions.d. If you
receive this document from someone other
than a State or Tribal CSE agency or a Court, a
copy of (he underlying order must be attached.
0232234850
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This document is based on the support or withholding order from CUMBERLAND County,
Commonwealth of Pennsylvania (State/Tribe). You are required by Iaw to deduct these amounts hnmthoemployee/
=^
obligors income until further notice. -- -+
S 010 per month in current child support rnro a.,...
� ~
$ 0.00 per month in past-due child support Arrears 12 weeks or greater? 0 ^~~-� no--0
0.00 per month in current cash medical support u«r-
-< r\.) $ O.UO per month inpae�duo cash medical suppod �� -
-<o
$ U.00 per month in current spousal suppnrt �>r) -o
—
$ 0.00 per month in past-due spousal support =(--,
$ 0.00 per month in other (must specify) 3> c pw
-~ /a
-‹ ■u
for a Total Amount to Withhold of $ 0.00 per month.
AMOUNTS TO WITHHOLD: You do not have to vary your pay cycle to be in compliance with the Order Information.
If your pay cycle does not match the ordered payment cycle, withhold one of the following amount:
�
0.00 per weekly pay period. 0.00 per semimonthly pay period (twice a month)
�
0.00 per biweekly pay period (every twa weeks) $ 0,00 per monthly pay period.
�
Lump Sum Payment: Do not stop any existing IWO unless you receive a termination order.
REMITTANCE INFORMATION: If the employee/obligors principal place of employment is within the Commonwealth
of Pennsylvania (StatefTribe), you must begin withholding no later than the first pay period that occurs ten (10)
working days after the date of this Order/Notice. Send payment within seven (7) working days of the pay date. If
you cannot withhold the full amount of support for any or all orders for this employee/obligor, withhold up to 55% of
disposable income for all orders. If the employee/obligor's principal place of employment is not within the
Commonwealth of Pennsylvania /State/Tribe>, the employer can obtain withholding |im|taUono. time requiramento,
and any allowable employer fees at h#p:/kxwvw.acf.hhagov/programo/oom/newhire/annp|oyer/cnntacts/unntact map.
h1Dlfor the employee/obligor's principal place of employment.
Document Tracking Identifier
OMB No.: 0970-0154
Service Type M
Form EN-028 11/13
Worker ID 21205
❑ Return to Sender [Completed by Employer /Income Withholder]. Payment must be directed to an SDU in
accordance with 42 USC §666(b)(5) and (b)(6) or Tribal Payee (see Payments to SDU below). If payment is not
directed to an SDU/Tribal Payee or this IWO is not regular on its face, you must check this box and return the IWO to
the sender.
Signature of Judge /Issuing Official (if required by State or Tribal law):
Print Name of Judge /Issuing Official:
Title of Judge /Issuing Official:
Date of Signature:
MAR 252014
If the employee /obligor works in a State or for a Tribe that is different from the State or Tribe that issued this order, a copy of this IWO
must be provided to the employee /obligor.
❑ If checked, the employer /income withholder must provide a copy of this form to the employee /obligor.
ADDITIONAL INFORMATION FOR EMPLOYERS /INCOME WITHHOLDERS
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.
State - specific contact and withholding information can be found on the Federal Employer Services website located at:
http: / /www.acf. hhs.gov/programs/cse/newhire/employer/contacts/contact_map.htm
Priority: Withholding for support has priority over any other legal process under State law against the same income (USC 42
§666(b)(7)). If a Federal tax levy is in effect, please notify the sender.
Combining Payments: When remitting payments to an SDU or Tribal CSE agency, you may combine withheld amounts from
more than one employee /obligor's income in a single payment. You must, however, separately identify each employee/
obligor's portion of the payment.
Payments To SDU: You must send child support payments payable by income withholding to the appropriate SDU or to a
Tribal CSE agency. If this IWO instructs you to send a payment to an entity other than an SDU (e.g., payable to the custodial
party, court, or attorney), you must check the box above and return this notice to the sender. Exception: If this IWO was sent
by a Court, Attorney, or Private Individual /Entity and the initial order was entered before January 1, 1994 or the order was
issued by a Tribal CSE agency, you must follow the "Remit payment to" instructions on this form.
Reporting the Pay Date: You must report the pay date when sending the payment. The pay date is the date on which the
amount was withheld from the employee /obligor's wages. You must comply with the law of the State (or Tribal law if
applicable) of the employee /obligor's principal place of employment regarding time periods within which you must implement
the withholding and forward the support payments.
Multiple IWOs: If there is more than one IWO against this employee /obligor and you are unable to fully honor all IWOs due to
Federal, State, or Tribal withholding limits, you must honor all IWOs to the greatest extent possible, giving priority to current
support before payment of any past -due support. Follow the State or Tribal law /procedure of the employee /obligor's principal
place of employment to determine the appropriate allocation method.
Lump Sum Payments: You may be required to notify a State or Tribal CSE agency of upcoming lump sum payments to this
employee /obligor such as bonuses, commissions, or severance pay. Contact the sender to determine if you are required to
report and /or withhold lump sum payments.
Liability: If you have any doubts about the validity of this IWO, contact the sender. If you fail to withhold income from the
employee /obligor's income as the IWO directs, you are liable for both the accumulated amount you should have withheld and
any penalties set by State or Tribal law /procedure.
Anti - discrimination: You are subject to a fine determined under State or Tribal law for discharging an employee /obligor from
employment, refusing to employ, or taking disciplinary action against an employee /obligor because of this IWO.
OMB Expiration Date — 05/31/2014. The OMB Expiration Date has no bearing on the termination date of the IWO; it identifies the version of the form currently in use.
Form EN -028 11/13
Worker ID 21205
Service Type M Page 2 of 3
Employer's Name: R &R PLASTER & DRYWALL CO, INC. Employer FEIN: 023223485
Employee /Obligor's Name: REDDING, ROBERT L. JR 5453102023
CSE Agency Case Identifier: (See Addendum for case summary) Order Identifier: (See Addendum for order /docket information)
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 /obligor's principal place of
employment (see REMITTANCE INFORMATION). 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, those limits increase 5% - to 55% and 65% - if the arrears are greater than 12 weeks. If permitted by the State
or Tribe, you may deduct a fee for administrative costs. The combined support amount and fee may not exceed the limit indicated in
this section.
For Tribal orders, you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employers /income
withholders who receive a State IWO, you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which
the employer /income withholder is located or the maximum amount permitted under section 303(d) of the CCPA (15 U.S.C. 1673 (b)).
Depending upon applicable State or Tribal law, you may need to also consider the amounts paid for health care premiums in
determining disposable income and applying appropriate withholding limits.
Arrears greater than 12 weeks? If the Order Information does not indicate that the arrears are greater than 12 weeks, then the
Employer should calculate the CCPA limit using the lower percentage.
Additional Information:
NOTIFICATION OF EMPLOYMENT TERMINATION OR INCOME STATUS: If this employee /obligor never worked for you or you are
no longer withholding income for this employee /obligor, an employer must promptly notify the CSE agency and /or the sender by
returning this form to the address listed in the Contact Information below: 0232234850
Q This person has never worked for this employer nor received periodic income.
Q This person no longer works for this employer nor receives periodic income.
Please provide the following information for the employee /obligor:
Termination date: Last known phone number:
Last known address:
Final Payment Date To SDU/Tribal Payee: Final Payment Amount:
New Employer's Name:
New Employer's Address:
CONTACT INFORMATION:
To Employer /Income Withholder: If you have any questions, contact WAGE ATTACHMENT UNIT (Issuer name)
by phone at (717) 240 -6225, by fax at (717) 240 -6248, by email or website at: www.childsupport.state.pa.us.
Send termination /income status notice and other correspondence to: DOMESTIC RELATIONS SECTION, 13 N. HANOVER ST,
P.O. BOX 320, CARLISLE, PA, 17013 (Issuer address).
To Employee /Obligor: If the employee /obligor has questions, contact WAGE ATTACHMENT UNIT (Issuer name)
by phone at (717) 240 -6225, by fax at (717) 240 -6248, by email or website at www.childsupport.state.pa,us.
IMPORTANT: The person completing this form is advised that the information may be shared with the employee /obligor.
OMB No.: 0970 -0154
Service Type M Page 3 of 3
Form EN -028 11/13
Worker ID 21205
ADDENDUM
Summary of Cases on Attachment
Defendant /Obligor: REDDING, ROBERT L. JR
PACSES Case Number 312111065
Plaintiff Name
BRENDA L. REDDING
Docket Attachment Amount
08 -2276 CIVIL $ 0.00
Child(ren)'s Name(s):
DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
PACSES Case Number PACSES Case Number
Plaintiff Name Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
PACSES Case Number PACSES Case Number
Plaintiff Name Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
Service Type M
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
Addendum
OMB No.: 0970 -0154
Form EN -028 11/13
Worker ID 21205
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Phone: (717) 240 -6225 Fax: (717) 240 -6248
Defendant Name: ROBERT L. REDDING JR
Member ID Number: 5453102023
Please note: All correspondence must include the Member ID Number.
ORDER TO VACATE ATTACHMENT OF UNEMPLOYMENT BENEFITS
Plaintiff Name
BRENDA L. REDDING
Financial Break Down of Multiple Cases on Attachment
PACSES Docket Attachment Amount/Frequency
Case Number Number 4 Y
312111065 08 -2276 CIVIL
TOTAL ATTACHMENT AMOUNT: $
1,400.00 / MONTH
1,400.W. cm
C
Ce
The prior Order of this Court directing the Department of Labor and Industry, Office of
Unemployment Compensation Benefits (OUCB), to attach $322.19 or 50% per week of
the Unemployment Compensation benefits of ROBERT L. REDDING JR, Social Security
Number XXX -XX -9866, Member ID Number 5453102023 is hereby vacated.
This Order to Vacate shall be effective upon receipt of the notice of the Order by the
Department and shall remain in effect until a further Order of the Court is filed.
BY THE COURT
Albert Mlasland
Date of Order: MAR 2 6 2014-
Service Type M
J.UDOE
Form EN -035
Worker ID $IATT