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HomeMy WebLinkAbout08-4955 JAIME D. WASSMER, ESQUIRE Robinson & Geraldo Sup. Ct. I.D. No. 200705 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 - Phone (717) 232-5098 - Fax jwassmer@robinson-geraldo.com KIRSTIN SNOW, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, NO. (7$ - i{Q 55 iv l lerr? TIMOTHY SNOW, Defendant. : CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request counseling. A list of marriage counselors is available in the Office of the Prothonotary, Room 101, Dauphin County Courthouse, Front & Market Streets, Harrisburg, Pennsylvania 17101. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS' FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH THE INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service Cumberland County Court Administrator 4t' Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 KIRSTIN SNOW, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. NO. 0 y 95'Y c rt TIMOTHY SNOW, ; Defendant. : CIVIL ACTION - LAW IN DIVORCE AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notification de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicano en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o caulquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importances para used. SED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME O VAYA A LA SIGUIENTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service Cumberland County Court Administration 4t' Floor Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 JAIME D. WASSMER, ESQUIRE Robinson & Geraldo Sup. Ct. I.D. No. 200705 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 - Phone (717) 232-5098 - Fax jwassmer@robinson-geraldo.com KIRSTIN SNOW, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, : V. NO. TIMOTHY SNOW, Defendant. CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE COUNT I 1. Plaintiff is Kirstin Snow, who currently resides at 341 North 24th Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Timothy Snow, who currently resides at 341 North 24th Street, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 22, 2002 in Elizabethtown, Pennsylvania. 5. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Neither Party is a member of the Armed Forces of the United States or any of its allies. 8. The Plaintiff has been advised of the availability of counseling and that either party may compel the other by Order of Court to attend counseling sessions. WHEREFORE, Plaintiff respectfully requests that your Honorable Court enter a Decree in Divorce under Section 3301 of the Divorce Code. COUNT II--EQUITABLE DISTRIBUTION 9. The Plaintiff incorporates by reference Paragraphs 1 through 8 of the Complaint for Divorce as fully set forth herein. 10. During the marriage, Plaintiff and Defendant have acquired various items of marital property, which are subject to equitable distribution under Section 3502 of the Pennsylvania Divorce Code of 1980, as will be fully set forth in the Plaintiffs Inventory and Appraisement to be filed pursuant to the Pennsylvania Rules of Civil Procedure. 11. Plaintiff and Defendant have been unable to agree as to an equitable division of marital property. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital property. Respectfully submitted, ROBINSON & GERALDO Date: By: 'Q - Jai D. Wassmer, Esquire Attorney for Plaintiff VERIFICATION I verify that the statements made in this Divorce Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. rstin Snow n -r? C)D C:';. G7 l?"J J ¦ JAIME D. WASSMER, ESQUIRE Attorney I.D. No. 200705 Robinson & Geraldo, P.C. 4407 North Front Street P.O. Box 5320 Harrisburg, PA 17110 (717)232-8525 Fax (717)232-5098 jwassmer@robinson-geraldo.com KIRSTIN SNOW, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-4955 TIMOTHY SNOW, Defendant. CIVIL ACTION DIVORCE PROOF OF SERVICE The undersigned makes the following return of service: the Divorce Complaint was served upon Samuel L. Andes, Esquire on September 2, 2008 at PO Box 168, Lemoyne, Cumberland County, Pennsylvania. The signed acceptance of service is attached hereto as Exhibit 1. SIGNATURE AND AFFIDAVIT I, Jaime D. Wassmer, Esquire, certify that I am a competent adult not a party to this action. I verify that the statements made in this affidavit and return of service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsfication to authorities. Respectfully submitted, Dated: September 4, 2008 ROBINSON & GERALDO B Y: Jaime . Wassmer, Esquire Attorney for Plaintiff ? , a Complete items 1, 2, and 3. Also complete item 41f Restricted Delivery Is desired. 0 Print your name and address on the reverse i ' !o that we can return the card to you. ¦ A Etch this card to the hack of the mailpiece, or on the front if space permits. 1. ArWe Addressed to: Sormvi;r L • ????? ??.:. 4t malne, 1% 1743 ? Agent 13 Addre TO Pr/ M Is delivery address different from Item 17 ? Y- J.D N YES, enter delivery address below: ? No 3. lype ?ertifled Mall ? Express Mail Lr'(Raglatered F HUWm Receipt for Merc wKfte ? Insured mail ? C.O.D. 4. Restricted Deliveryt (Exha Fee) ? Yea 7- AfltdeNuOW 7008 1140 0004 4438 0510 ' (ilarsfiltr?seivke iatiefj PS Form 3811, Fdmov iMlrt4 t1MMM1e Marr* tlaaeipt 10259542-WIS40 UNITED STATE. -J ., A -9 L • Sender: Please print your name, address, and ZIP+4 in this box' ROBINSON & GERALDO Attorneys At Law P.O. Box 5320 Hardebarg, PA 17110 srx Lrrfill rr,IrrriL??iH1,r?llrrrrrlhrrlrlllrflfill llli)1111111 -ate --+ -:1 ::. KIRSTIN SNOW, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-4955 TIMOTHY SNOW, Defendant. CIVIL ACTION DIVORCE MARRIAGE SETTLEMENT AGREEMENT -?h THIS AGREEMENT, made this day of Oc?b fog, 2008, by and between Kirstin Snow, of 341 North 24th Street, Camp Hill, Cumberland County, Pennsylvania 17011, hereinafter referred to as "Wife," and Timothy Snow, of 341 North 24th Street, Camp Hill, Cumberland County, Pennsylvania 17011, hereinafter referred to as "Husband." WITNESSETH: WHEREAS, Husband and Wife were lawfully married on June 22, 2002; and WHEREAS, differences have arisen between Husband and Wife in consequence of which they intend to live separate and apart of each other; and WHEREAS, Husband and Wife have made a full disclosure of their assets to each other; and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations with respect to each other, including the disposition and distribution of property rights and interests between them. NOW, THEREFORE, in consideration of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the Parties hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: 1. ADVICE OF COUNSEL. The provisions of this Agreement and their legal effect have been fully explained to the Wife and Husband by their respective counsel, Jaime D. Wassmer, Esquire, and Samuel Andes, Esquire. The parties acknowledge that they have received independent legal advice from counsel of their selection. The parties fully understand the facts and have been informed as to their legal rights and obligations. Husband and Wife acknowledge and accept that this Agreement is, in the circumstance, fair and equitable, and that it is being entered into freely and voluntarily, after having received such advice and with such knowledge. The parties agree that execution of this Agreement is not the result of any duress or undue influence, and that it is not the result of any collusion or improper or illegal agreement or agreements. 2. SEPARATION. It shall be lawful for each party at all times hereafter to continue to live separate and apart from the other party. The foregoing provisions shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of the causes leading to their living apart. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE. The parties agree that the terms of this Agreement shall be incorporated into any Divorce Decree which may be entered with respect to them at the request of either party. The parties agree that the Court of Common Pleas of Cumberland County, Pennsylvania, shall retain continuing jurisdiction over the parties and the Agreement for the purposes of enforcement of any of the provisions thereof. The parties agree that unless otherwise specifically provided herein, if a Decree is entered divorcing the parties, although this Agreement shall be incorporated into said Decree, this Agreement shall not merge with, but shall continue in full force and effect after such time as a Final Decree in Divorce may be entered with respect to the parties and may be enforced in an action independent of the Divorce Decree. The parties agree and it is the intent of each of them that this Agreement may be enforced either under the provisions of the Pennsylvania Divorce Code or in an action independent of the Divorce Decree in accordance with Section 3502 of the Pennsylvania Divorce Code. The provisions of this Agreement, regarding the disposition of existing property rights and interests between the parties, cash settlement/miscellaneous payment, alimony, alimony pendente lite, counsel fees and expenses, shall not be subject to modification by any Court. 4. SUBSEQUENT DIVORCE. The Parties hereby acknowledge and express their agreement that the marriage is irretrievably broken, and the Parties agree to cooperate in any necessary way to obtain a mutual consent, no-fault divorce, pursuant to Section3301 of the Pennsylvania Divorce Code. 5. INTERFERENCE. Each Party shall be free from interference, authority, and contact by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither Party shall molest the other or attempt to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 6. WIFE'S DEBTS. Wife represents and warrants to Husband that she will not contract or incur any debt or liability for which Husband or his estate might be responsible and she shall indemnify and hold harmless Husband from any and all claims or demands made against him by reason of debts or obligations incurred by her. 7. HUSBAND'S DEBTS. Husband represents and warrants to Wife that he will not contract or incur any debts or liability for which Wife or her estate might be responsible, and he shall indemnify and hold harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. 8. MUTUAL RELEASE. Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement, does for himself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all causes of action, claims, rights, or demands, whatsoever in law or equity, which either of the parties had or now has against the other, except for any and all causes of action for divorce and except for any and all causes of action for breach of any provisions of this Agreement. 9. DISCLOSURE OF PROPERTY. Husband and Wife acknowledge and agree that they have made a full and complete disclosure to the other of all information pertaining to the parties' separate and marital property owned, possessed and/or controlled by the other at the time of the separation of the parties and, further, that the Husband and Wife voluntarily and intelligently agree to waive any rights which they may have to receive an Inventory and Appraisement of all property owned or possessed by them, either jointly or individually, at the time of the delivery of this Agreement or of the commencement of any action of divorce. 10. EQUITABLE DISTRIBUTION. Husband and Wife acknowledge and agree that the provisions of this Agreement with respect to the distribution and division of marital and separate property are fair, equitable and satisfactory to them based on the length of their marriage and other relevant factors that have been taken into consideration by the Parties. a. REAL PROPERTY. Husband and Wife hold title as tenants by the entireties the residence identified as 341 North 24th Street, Camp Hill, Cumberland County, Pennsylvania 17011 (the "marital residence"). The residence is encumbered by a first mortgage (National City), whose balance is approximately two hundred thirty-two thousand dollars ($232,000) and a second mortgage (PNC), whose balance is approximately thirty-four thousand dollars ($34,000). The parties agree that Husband will retain possession of the marital residence. Husband agrees to refinance the martial residence to remove Wife's name from the mortgage obligation on the home within three weeks of finalizing this agreement. The parties agree that Wife will sign a deed and other additional documents necessary to accomplish this conveyance transferring her interest in the marital residence to Husband once Husband secures the refinancement of the mortgages. Husband shall thereafter own the marital residence and the entire contents thereof free and clear of any and all claims to same by Wife, with exceptions as laid out in this Agreement. Once the transfer of Wife's interest of the marital residence to Husband occurs, Husband agrees to hold Wife harmless for any and all liability or claims that may arise with respect to the residence. The parties agree that Husband will assume responsibility for all expenses associated with the marital residence, including but not limited to the utilities, repairs, taxes, and insurance at the time of the transfer with the exception that Wife will continue to contribute one thousand, seven hundred, seventy-five dollars ($1,775.00) per paycheck to the household expenses for so long as Wife continues to reside in the marital residence. b. PERSONAL PROPERTY. The parties have divided between themselves, to their mutual satisfaction, all items of tangible, personal property previously used by them in the marital home. Neither party shall make any claim to any such item of tangible personal property whether said items are marital property or said items are separate personal property of either party. A list of these items retained by each party has been attached to this agreement as "Exhibit A". c. MOTOR VEHICLES. Effective the date of this agreement, the parties agree that each vehicle in their possession shall be owned independently of any claim or right of the other party, now or hereafter belonging to him or her and now or hereafter in his or her possession, with full power to dispose of the same as fully and effectually as though he or she were unmarried. Further, each waives and relinquishes any right, title and interest which either may have in such property. The parties agree that each will be solely responsible for all payments, insurance premiums, and liabilities associated with their respective leased vehicles. d. MARITAL DEBT. The parties agree that Husband shall assume sole responsibility and liability for all credit cards in his name and Wife shall assume sole responsibility for all credit cards in her name. The parties represent that there are no jointly held credit cards. e. BANK AND FINANCIAL ACCOUNTS. The parties hereby waive, release, and relinquish any and all rights, title, and interest either may have in and to the other's separately titled bank and financial accounts; including, but not limited to, checking, savings, certificates of deposit, money markets, and financial investment accounts of whatever kind and nature, and neither shall make any claim against the other's property now or in the future. The parties agree they will continue to maintain and use the joint checking account to pay the household bills as long as Wife continues to reside in the marital residence. Within ten (10) days of Wife moving out the marital residence, the parties agree to close the joint account. Should any funds remain in the joint account at the time it is to be closed, those funds shall be deposited into the UGMA account for the parties' son, Zane. The parties further agree that Husband will serve as custodian of the UGMA account, which is maintained for their son's benefit. f. RETIREMENT BENEFITSANVESTMENTS. The parties acknowledge that Husband and Wife have acquired several retirement benefits and investments` The parties agree that Wife shall retain as her sole and separate property her pension with the Commonwealth of Pennsylvania, Smith Barney investment account, retirement account with Highmark, her 401(k) retirement plan, and Great Western Deferred Compensation plan. Husband agrees to waive any and all rights or claims to the aforementioned retirement benefits and investments held by Wife. The parties agree that Husband shall retain as his sole and separate property his IRA, Union annuity, Smith Barney investment account, and Union pensions. Wife agrees to waive any and all rights or claims to the aforementioned retirement benefits and investments held by Husband. The parties acknowledge that they have deposited the proceeds from the sale of their Walton Street property into a joint Smith Barney investment account, with an approximate balance of forty-six thousand dollars ($46,000). Within one week of the execution date of this agreement, Husband agrees to pay Wife an amount equal to one-half (1/2) of the then current balance in the investment account after the amount determined by the parties' accountant to be due in capital gains tax is set aside for Husband to pay the tax thereon when due. Husband shall be responsible to pay the tax from the reserved amount. g. REAL ESTATE-RENTAL PROPERTY. The parties agree that Husband shall retain as his sole and separate property the Berry Hill Street residential rental property currently titled in his name. Husband agrees to assume all responsibility and hold Wife harmless for any and all costs, liabilities, and repairs with said property. h. LIFE INSURANCE. The parties each have term life insurance polices with a five hundred thousand dollar ($500,000) death benefit and remaining term of approximately fifteen (15) years. The parties agree to retain these policies in the existing amount for at least the remainder of the terms with their son Zane named as beneficiary (in trust). i. BOAT. During the parties' marriage, they acquired a twenty-four (24) foot pontoon boat. Wife shall retain sole and separate ownership of the boat. The fee to winterize the boat shall be paid from joint checking account; however, once paid, Wife agrees to assume full responsibility and hold Husband harmless for any and all expenses, repairs, and liabilities associated with the boat. j. ALIMONY. The parties agree that Wife will pay alimony to Husband in the amount of seven hundred thirty-three dollars ($733.00) per month for a period of thirty-six (36) months and which will be administered through the Cumberland County Domestic Relations Section. This amount is non-modifiable. Alimony will before the 151' of the month after Wife moves out of the marital residence and the joint checking account is closed and no longer being used for payment of household expenses. In any event alimony shall not begin until at least forty-five (45) days after Wife makes her final payment on the mortgage on the marital residence. Alimony will terminate prior to the full term of thirty-six (36) months in the event of death of either party or should Husband remarry. k. MISCELLANEOUS. i. Child Support. The parties agree that Wife shall pay four hundred fifty-four dollars ($454.00) per month for support for their son Zane through the Cumberland County Domestic Relations Office. The parties agree that this amount includes the first two hundred fifty dollars ($250.00) per year for medical costs and that thereafter, Zane's medical expenses, which are not covered by insurance, will be shared equally. For-the purposes of support, the parties agree that medical expenses shall include psychiatric, psychological, and mental health counseling. The parties further agree that Husband will be responsible to maintain medical insurance for Zane, although Wife will add Zane to her coverage in the event Husband should lose his medical coverage. The parties agree Wife shall pay the cost of Zane's childcare during the day, specifically the expenses that are incurred for a childcare provider to watch Zane while both parties are unavailable to watch the child. Further, the aforementioned provision concerning Wife's financial obligation to pay for childcare expenses remain modifiable as the child's needs should change. The parties agree Husband will file the necessary paperwork with the Domestic Relations Office to begin the process and will forward the parties' agreement as specified herein to the DRO for entry of an Order reflecting this agreement. The parties agree Wife's obligation to pay support will not commence until Wife moves out of the marital residence and the joint checking account is closed and no longer being used for payment of household expenses. The parties agree to alternate claiming Zane as a dependant for tax purposes, with Wife being entitled to the exemption in the first year which the parties file taxes separately. ii. Taxes. Husband and Wife agree that they will obtain guidance from their tax preparer as to the options for filing their 2008 income tax returns in such a way as to maximize the tax benefit to both of them. iii. Pets. At such time when Wife no longer resides in the marital residence, the parties agree that Husband shall maintain possession of and responsibility for the care of Harry, the dog, and all of the fish and Wife shall maintain possession of and responsibility for the care of Sydney, the dog, and the two (2) cats. 11. WAIVER OF CLAIMS AGAINST ESTATE. Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including, without limitation, dower, courtesy, statutory allowance, widows allowance, right to take property under equitable distribution, right to take in intestacy, right to take against the will of the other's estate, and who will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. 12. BREACH. The parties will cooperate with each other and their counsel and others as may be necessary to fully and properly implement the provisions of this paragraph. If either party breaches any provision of this Agreement, 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 advisable to him or her, and the party breaching this Contract shall be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement. 13. ENTIRE AGREEMENT. This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. The parties agree to execute any documents necessary to effectuate the conveyance of title to the party receiving such property under this Agreement and agree to deliver necessary documents in a timely manner. 14. MODIFICATION AND WAIVER. The modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 15. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 16. INDEPENDENT SEPARATE COVENANT. It is specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 17. APPLICABLE LAW. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 18. VOLUNTARY EXECUTION. Husband and Wife acknowledge and represent that the provisions of this Agreement are fully understood by both parties and each party acknowledges that this Agreement is in all respects fair and equitable, that it is being entered into voluntarily and knowingly, and that it is. not the result of any duress, undue influence, collusion or improper or illegal agreement or agreements. AN, IN WITNESS WHEREOF, the Parties have hereunto set their hands and seals the day and year first above written. Wi ss 4rstin Snow, Plaintiff Witn ss Timothy Snow, Defendant STATE OF PENNSYLVANIA COUNTY OF DAUPHIN : ss: On this, the ? day of Cdyo &I'"- , 2008, before me, a Notary Public, the undersigned officer, personally appeared KIRSTIN SNOW, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and seal. 12 (SEAL) 4 otary Public My Commission Expires: Y /07 -do /a O-W-AONWEALTH OF PENNSYLVANIA STATE OF PENNSYLVANIA Notarial Seal Gloria J. Lebo, Notary Public ss: Susquehanna'rWP•, Dauphin County COUNTY OF DAUPHIN CPenn!?a '%j1$oclatWof o'tariea On this, the /®`A day of 2008, before me, a Notary Public, the undersigned officer, personally appeared TIMOTHY SNOW, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and seal. 'R" 4 (SEAL) otary Public My Commission Expires: ?'"aka CEALTH OF ''?snVANw Notarial 8 Gbrya J. Lebo, ?w oft rwP, p a?ubiic a6to-12.2012 n obariea Marital and Personal Assets going to Kirstin Snow upon leaving the marital residence: Dining Room: all furniture in dining room is property of KS as she acquired it before marriage date; and other furniture in dining room was a gift from her parents. This includes all lamps, rugs, pictures, mirrors, tables, candelabra, wine racks and chairs. Living Room: KS requests the living room set. The mirror was purchased by her before the marriage and will become her property upon moving; all lamps and decor were purchased by KS or were given as gifts; this includes all pictures, candle holders and tables. KS will also take her CDs and her books. Stereo is property of TS. Reading Room: leopard chaise is property of KS as are all decor items in said room including plants, lamps and wall decor including circular wall candelabra. Kitchen: KS purchased the chair and tables; all kitchen items (appliances and cookware, utensils, dishware and glasses) that were hers before the marriage, or were gifts or her private purchases, will be retained by KS. Wall hangings are also property of KS. KS will also take possession of her cooking spices and certain pantry items. The cuisinarts and mixer are hers; KS requests the toaster as it is a shared marital gift. TS can retain possession of the range, refrigerator, microwave, blender, dishwasher and coffeemaker. KS requests the mixed set of shared knives that was a gift to her. Office off Kitchen: Wall items are property of KS. All office furniture is property of TS. White chest of drawers and dinnerware are property of KS, as is the bakers' rack. Plants are KS'. All lamps belong to KS. KS will also take her personal cookbooks. Upstairs Front Guest Room: Chest and rocker are property of KS. Queen mattress, boxspring and frame are property of KS. Bedroom set will go to KS as will all decor in that room, as it was purchased by KS with her personal funds. Upstairs Yellow Guest Room: all items in this room are property of KS. Specifically, they include maple dresser, futon, futon bench, bedding, red sleeping bag, decorations, lamps, books, clothing and bedding items. Zane's Bedroom: all furniture except bed is property of KS. KS will, however, leave one of the two bookshelves. The dresser belongs to KS and will be placed in Zane's new room at her other residence. KS will retain half of Zane's clothes, books and toys as well as his keepsake box which she purchased. She will also take the horse poster, Harley lamp and the stereo in this room, as they are her property. TS shall retain possession of the blue rocker. Walk in Closet: all items in closet are property of KS. Hallway: all items in upstairs hallway were purchased by KS before marriage and she will retain these items. They include two tables, pictures, and a lamp and small glass decoration. Towels will be divided between TS and KS. Master Bedroom: Chair, jewelry chest and metal side tables are property of KS. Bedroom set and bed were purchased jointly. KS willing to leave jointly purchased bedroom set and king bed set and king bedding to Tim in exchange for the armoire and television which were also joint purchases. All lamps except for lamp on highboy are KS. TV/Sunroom: All wall hanging are KS. Wooden cart is KS. Large armoire and its contents are KS. TV is TS'. KS willing to release joint ownership of all other items in sunroom in exchange for the desk in this room. Items KS is willing to give to Tim in this room are the sleeper sofa and glass top table and chairs. Red lamp is KS. Side and coffee tables are TS. Bathroom and Linen Closet: KS will take half of towels; stainless steel toiletry stand and her toiletries as well as hair dryer and all of her personal grooming items. She will also take all of her personal items from the linen closet. Miscellaneous/Outside/Garage items: KS will take the dog crate and plastic gate. She will also take half of Zane's toys. In addition, she'll take any personal items in garage. KS will take the black iron outdoor furniture set; and the umbrella and chiminea and stand. She'll also take the grill. KS will leave Zane's playset, the canopy and frame and outdoor couch, two chairs and tables. All decorations in basement are KS. KS will remove the electric bed and mattress. KS shall retain decorations she purchased with personal funds. ** KS will not move items from home unless TS is present. rstin Snow c? Date Timothy Sno o iQ a 8' Date EXHIBIT cry _ S •• i..-t . .? w. -115 4 VVI 1 Luuu OCT 7 5 2000 KIRSTIN SNOW, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-4955 TIMOTHY SNOW, Defendant. CIVIL ACTION DIVORCE ORDER OF COURT AND NOW, this _ dayof_ 014 '2008, it is hereby ORDERED and DECREED that the attached Marriage Settlement Agreement is entered as an Order of this Court. Distribution: ime D. Wassmer, Esquire, 4407 North Front Street, Harrisburg, PA 17110 Samuel L. Andes, Esquire, P.O. Box 168, Lemoyne, PA 17043 BY THE COURT: :10 KIRSTIN SNOW, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. TIMOTHY SNOW, Defendant CIVIL ACTION - LAW NO. 08-4955 IN DIVORCE DEFENDANT'S PETITION FOR ECONOMIC RELIEF AND NOW comes the above-named Defendant, by his attorney, Samuel L. Andes, and files the following Petition for Economic Relief: COUNT II - ALIMONY 1. Defendant lacks sufficient property to provide for her reasonable needs in accordance with the standard of living of the parties established during the marriage. 2. Defendant is unable to support himself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 3. The Plaintiff is employed and enjoys a substantial income from which she is able to contribute to the support and maintenance of Defendant and to pay him alimony in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Defendant prays this Honorable Court to enter an Order awarding Defendant from Plaintiff permanent alimony in such sums as are reasonable and adequate to support and maintain Defendant in the station of life to which he has become accustomed during the marriage. COUNT III - ALIMONY PENDENTE LITE 4. Defendant is without sufficient income to support and maintain himself during the pendency of this action. 5. Plaintiff enjoys a substantial income and is well able to contribute to the support and maintenance of Defendant during the course of this action. WHEREFORE, Defendant prays this Honorable Court to order Plaintiff to pay him reasonable alimony pendente lite during the pendency of this action. Sara` L. And Attorney for Defendant Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 I verify that the statements made in this Petition for Economic Relief are true and correct. I understand that any false statements in this Petition are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). DATE: ?0 6 0 TIMOTHY SN W hip . w KIRSTIN SNOW, vs. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TIMOTHY SNOW, Defendant NO. 08-4955 IN DIVORCE JOINT MOTION FOR ENTRY OF ALIMONY ORDER AND NOW come the above-named parties, by their undersigned attorneys who represent to the court that they are authorized to make this motion on behalf of their clients, and jointly move the court to enter the attached Order for Alimony to implement a provision of rties' Martial Settlement Agreement. Jai e . Wassmer A or ey for Plaintiff S eme Court ID # 200705 4407 North Front Street P.O. Box 5320 Harrisburg, PA 17110 (717) 232-8525 e"IL. Ai; h es 4rAuneyfio1rDefendant Supreme Court ID # 17225 525 North 12th Street P.O. Box 168 Lemoyne, PA 17043 (717) 761-5361 r.a coo KIRSTIN SNOW, Plaintiff vs. TIMOTHY SNOW, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-4955 IN DIVORCE ACCEPTANr-l= ®F SERVICE I hereby accept service of the Divorce Complaint in the above matter and acknowledge receipt of a copy of the Complaint on August 20, 2008. Timothy Snow L ti?3 KIRSTIN SNOW, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, : V. NO. 08-4955 TIMOTHY SNOW, : Defendant. CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 3301(c) of the Divorce code was filed on August 18, 2008, on the grounds that the marriage of the parties is irretrievably broken. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 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 herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. 4 cv Da te: rstin Snow r--a ?? - ? ?z ? ?? ? :.. .?- =', r,.: _. -_ - ..++^` ww 6 };? KIRSTIN SNOW, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. NO. 08-4955 TIMOTHY SNOW, Defendant. CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER & 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim 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. 4. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: l ` Kirstin Snow, Plaintiff r ? ,,` w -? ,'q-`;,, , ?? ?` ?? -- c?z ?- --,?, ., jt.t. - . ? . .?; ._ ., ,,, KIRSTIN SNOW, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, : V. NO. 08-4955 TIMOTHY SNOW, Defendant. : CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 3301(c) of the Divorce code was filed on August 18, 2008, on the grounds that the marriage of the parties is irretrievably broken. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 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 herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date. ?, Timothy Ono r, ?a ; r; KIRSTIN SNOW, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. NO. 08-4955 TIMOTHY SNOW, Defendant. : CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER & 3301 (c) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 2. 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. 4. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date:, Timothy Sno ,Defendant mj I NUV Z 4 Z0016 KIRSTIN SNOW, Plaintiff vs. TIMOTHY SNOW, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-4955 IN DIVORCE ORDER FOR ALIMONY AND NOW, this Z6 I ?day of (V e V , 2008, upon the joint motion of counsel for Plaintiff and Defendant, and to implement a provision of the parties Settlement Agreement, we hereby award alimony to the Defendant and order as follows: 1. The Plaintiff Kirstin Snow (hereinafter "Wife") shall pay alimony or alimony pendente lite to the Defendant Timothy Snow (hereinafter "Husband") as follows: A. The amount of alimony pendente lite or alimony shall be $733.00 per month.. Until such time as the parties are divorced, the payments shall be alimony pendente lite and after the entry of a final decree in divorce, the payments shall be alimony. B. The term of the alimony or alimony pendente lite shall be for thirty-six (36) months and shall commence on November 15, 2008 and shall continue thereafter on the 15th day of each consecutive month, thereafter, for thirty-six (36) consecutive months. Alimony shall terminate prior to thirty-six (36) months in the event of the death of either party or Husband's remarriage. C. Neither the amount nor the term of alimony shall be subject to modification by this court or any other tribunal. 2. The payments of alimony pursuant to this order shall be administered by the Domestic Relations Office of Cumberland County, which is hereby directed to open and administer an account for the collection and disbursement of the same. The parties are directed to cooperate with the Domestic Relations Office and all other court personnel to implement the terms of this order promptly. 3. Both parties shall treat the payments made pursuant to this order as alimony for income tax purposes. BY THE COURT, J. Distribution: Domestic Relations Office - Cumberland County P.O. Box 320, Carlisle, PA 17013 P-1 Jaime D. Wassmer, Esquire (Attorney for Plaintiff) 4407 North Front Street, P.O. Box 5320, Harrisburg, PA 17110-5320 Samuel L. Andes, Esquire (Attorney for Defendant) 525 North 12th Street, P.O. Box 168, Lemoyne, PA 17043 -..nrnry 4 f JAIME D. WASSMER, ESQUIRE Robinson & Geraldo Sup. Ct. I.D. No. 200705 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 - Phone (717) 232-5098 - Fax jwassmer@robinson-geraldo.com KIRSTIN SNOW, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. NO. 08-4955 TIMOTHY SNOW, Defendant. : CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for the entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under section 3301(c) of the Divorce code. 2. Date and Manner of service of the Complaint: An Acceptance of Service was signed by the Defendant and filed with the Court on November 21, 2008. 3. Date of execution of the affidavit required by section 3301(c) of the Divorce Code: by Plaintiff on November 20, 2008 and by Defendant on November 20, 2008. 4. Related claims pending. The economic claims have been settled by agreement. 5. Date the Plaintiffs Waiver of Notice in section 3301(c) of the Divorce was filed with the Prothonotary: is November 21, 2008. 6. Date the Defendant's Waiver of Notice in section 3301(c) of the Divorce was filed with the Prothonotary: November 21, 2008 Respectfully submitted, RgleeD.y ON & GERALDO B Wassmer, Esq. for Plaintiff CERTIFICATE OF SERVICE I, Jaime Wassmer, Esquire, do hereby certify that on the 1 day of 2W2yri??,- , 20081 caused a true and correct copy of the Praecipe to Transmit the Record to be served upon the following individual(s) by first class mail by depositing same in the United States, postage prepaid, in Harrisburg, Pennsylvania. Samuel L. Andes P.O. Box 168 Lemoyne, PA 17043 Respectfully submitted, ROBINSON & GERALDO By: a Jai Wassmer, Esq. C? "? - ?s ? , -t ± ? ---t v 4 ? ` + I ? ' xa. _,"" r ? ,, , ? ? ? a y C"? w ? ? : ?? :w ?• ? i :1 ?? ht] --? IN THE COURT OF COMMON PLEAS OF KIRSTIN SNOW CUMBERLAND COUNTY, PENNSYLVANIA V. TIMOTHY SNOW NO. 08-4955 DIVORCE DECREE AND NOW, T Zoo , it is ordered and decreed that KIRSTIN SNOW , plaintiff, and TIMOTHY SNOW , 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.") The terms of the Marriage Settlement Agreement are hereby incorporated but shall not merge in the final Divorce Decree. rothonotary By the Court, 4' *,o"kyp *p 4 ?- / -,w, (-/ - e7 -1 ORDER/NOTICE TO WITHHOLD INCOME State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 12/15/08 Case Number (See Addendum for case summary) E m ployer/With holder's Federal EIN Number BUREAU OF COMMONWEALTH* C/O WAGE ATTACHMENT SECTION PO BOX 8006 HARRISBURG PA 17105-8006 SUPPORT 08-4955 CIVIL OOriginal Order/Notice 1401103 4 900 S 2008 @Amended Order/Notice OTerminate Order/Notice OOne-Time Lump Sum/Notice RE: SNOW, KI4STIN D. See Addendum for dependent names and birth dates associ ORDER INFORMATION: This is an Order/Notice to Withhold Income fc from CUMBERLAND County, Commonwealth of Pennsylvani amounts from the above-named employee's/obligor's income until furthe issued by your State. $ 454 . 00 per month in current child support Employee/Obligor's Name (Last, First, MI) 163-48-0109 Employee/Obligor's Social Security Number 0572102047 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, MI) with cases on attachment. Support based upon an order for support By law, you are required to deduct these notice even if the Order/Notice is not O yes ® no $ o. oo per month in past-due child support Arrears 1 ? weeks or greater? $ 0.00 per month in current medical support $ 0.00 per month in past-due medical support $ 733.00 per month in current spousal support $ o . oo per month in past-due spousal support $ O. .Lo per month for genetic test costs $ o. oo per month in other (specify) $ one-time lump sum payment for a total of $ 1,187.00 per month to be forwarded to payee bel You do not have to vary your pay cycle to be in compliance with the supr the ordered support payment cycle, use the following to determine how n $ 273.92 per weekly pay period. $ $ 547,85 per biweekly pay period (every two weeks) $ ort order. If your pay cycle does not match uch to withhold: i93.50 per semimonthly pay period (twice a month) 1, 87.00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later thi working days after the date of this Order/Notice. Send payment within sl withholding. You are entitled to deduct a fee to defray the cost of withh( state of your employee for the allowable amount. The total withheld am the employee's/ obligor's aggregate disposable weekly earnings. For the the following information is needed (See #9 on page 2). If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by elect Pennsylvania State Collections and Disbursement Unit (PA SCDU) Empl for instructions. PA FIPS CODE 42 000 00 Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harri IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAN above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURII DO NOT SEND CASH BY MAIL. BY THE COURT: DRO: R. J. Shadday Service Type M OMB No.: 0970-0154 the first pay period occurring ten (10) en (7) working days of the paydate/date of ling. Refer to the laws governing the work nt, and your fee, cannot exceed 55% of irpose of the limitation on withholding, payment method, please call Customer Service at 1-877-676-9580 rg, Pa 17106-9112 THE PACSES MEMBER ID (shown BER IN ORDER TO BE PROCESSED. ,* X4 . I Hess, Judge Form EN-028 Rev. 4 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AN OTHER WITHHOLDERS I heck you are required to pr vide aopy of this form to your m I yee. If your employee works in a state tha is i fer cent ' from the state that issuefthis o er, a copy must be provideedpt your employee even if the box is not chec?ed. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one mployee%obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the po ion of the single payment that is attributable to each employee/obligor. 3.* Reporting the Paydate/Date of Withholding: You must report the paydate/date f withholding when sending the payment. The paydate/date of withholding is the date on which amount was withheld from the em loyee'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 ti a 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 Or er/Notice to Withhold Income for Support against this employeelobligor and you are unable to honor all support Order/Notices due to ederal 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 whe the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to th Agency identified below. 2321722990 THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : O THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: E3 EMPLOYEE'S/OBLIGOR'S NAME: SNOW, KIRSTIN D. EMPLOYEE'S CASE IDENTIFIER: 0572102047 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 per on 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 disc arging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employeelobligor becaus of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the tate in which he or she is employed governs. 9. * Withholding Limits: You may not withhold more than the lesser of. 1) the amour Protection Act (CCPA) (15 U.S.C. 1673 (b)); or 2) the amounts allowed by the State or employment. Disposable income is the net income left after making mandatory dedu Security taxes, statutory pension contributions and Medicare taxes. The Federal limit supporting another family and 60% of the disposable income if the obligor is not supl increased to 55% and that 60% limit is increased to 65% if the arrears are greater thar deduct a fee for administrative costs. The support amount and the fee may not exceed Arrears greater than 12 weeks : If the Order Information does not indicate whether I employer should calculate the CCPA limit using the lower percentage. For Tribal orde allowed under the law of the issuing Tribe. For Tribal employers who receive a State ( the limit set by the law of the jurisdiction in which the employer is located or the max CCPA 0 5 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to t care premiums in determining disposable income and applying appropriate withholdi 10. Additional info: *NOTE: If you or your agent are served with a copy of this order in the state that i that issued this order with respect to these items. 11. Send Termination Notice and other correspondence to: If you or yoi DOMESTIC RELATIONS SECTION contact 13 N. HANOVER ST by telephone P.O. BOX 320 CARLISLE PA 17013 by FAX at by internet ?s allowed by the Federal Consumer Credit -ribe of the employee's/obligor's principal place of tions such as: State, Federal, local taxes, Social 50% of the disposable income if the obligor is 3rting another family.However, that 50% limit is 12 weeks. If permitted by the State, you may he limit indicated in this section. 1e arrears are greater than 12 weeks, then the s, you may not withhold more than the amounts der, you may not withhold more than the lesser of num amount permitted under section 303(d) of the ke into consideration the amounts paid for health g limits. the order, you are to follow the law of the state have any questions, (717) 240-6225 or ) 240-6248 or us Page 2 of 2 Form EN-028 Rev. 4 Service Type M OMB No.: 0970-0154 Worker ID $IATT ADDENDUM Defendant/Obligor: SNOW, KIRSTIN D. ZANE T. SNOW 0,8.17/03 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 732110440 Docket Attachment Amount $ 0.00 Child(ren 's Name(s): DOB Addendum Form EN-028 Rev. 4 Service Type M OMB No.: 0970-0154 Worker ID $IATT Fri i-T _ -7 N?li W ORDERMOTICE TO WITHHOLD INCOME FOR SUPPORT State: Commonwealth of Pennsylvania 14o )) Gas 4- Co./City/Dist. Of.- CUMBERLAND G)DD S C'CR? Date of Order/Notice: 02/04/11 Case Number (See A e?for case summary) Employer/Withholder's Federal EIN Number EDWARD G RENDELL LLC 200 S BROAD ST FL 4 PHILADELPHIA PA 19102-3814 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. $ 454.00 per month in current child support $ 0.00 per month in past-due child support Arrears 12 weeks or greater? O yes O no $ 0.00 per month in current medical support $ 0.00 per month in past-due medical support $ 733.00 per month in current spousal support $ 0.00 per month in past-due spousal support $ 0.00 per month for genetic test costs 0.00 per month in other (specify) V) c $ one-time lump sum payment rnm _n M for a total of $ 1,187.00 per month to be forwarded to payee below. =? w - rl., Cn r- t ::23 C j CD I You do not have to vary your pay cycle to be in compliance with the support order. If your pay cyoi;es`Rbt n the ordered sup ort payment cycle, use the following to determine how much to withhold: Ca -a o- -n $ 273.2 per weekly pay period. $ 593.50 per semimonthly Aaeri% cs (twice a month67>c tv? $ -547 Q?per biweekly pay period (every two weeks) $ 1,187.00 per monthly pay perA. m 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 Ba. MAIL_ _ RE: SNOW, KIRSTIN D Employee/Obligor's Name (Last, First, MI) 163-48-0109 Employee/Obligors S-oci-aF-Security Number 0572102047 Employee/Obligor's Case dente ier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, MI) 61- 4055 0,11 ; ) 0 Original Order/Notice Q Amended Order/Notice 0 Terminate Order/Notice 0 One-Time Lump Sum/Notice BY THE COURT: Service Type M I?L?ICLY.?c1+? OMB No.: 0970-0154 Form EN-028 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS If checked you are required to provide a copy of this form to your employee. if your employee works in a state that is different from the state that issued this order, a copy must be provided to your employee even if the box is not checked. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3.* Reporting the Paydate/Date of Withholding: You must report the paydate/date of withholding when sending the payment. The paydate/date of withholding is the date on which amount was withheld from the employee's wages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. 2745062420 THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER: Q THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: Q EMPLOYEE'S/OBLIGOR'S NAME: SNOW, KIRSTIN D. EMPLOYEE'S CASE IDENTIFIER: 0572102047 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: LAST KNOWN PHONE NUMBER: NEW EMPLOYER'S NAME/ADDRESS: FINAL PAYMENT AMOUNT: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (CCPA) (15 U.S.C. 1673 (b)); or 2) the amounts allowed by the State or Tribe of the employee's/obligor's principal place of employment. Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes, Social Security taxes, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is supporting another family and 60% of the disposable income if the obligor is not supporting another family. However, that 50% limit is increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State, you may deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section. Arrears greater than 12 weeks: If the Order Information does not indicate whether the arrears are greater than 12 weeks, then the employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of the CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amounts paid for health care premiums in determining disposable income and applying appropriate withholding limits. 10. Additional info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Send Termination Notice and other correspondence to: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST FO. BOX 320 CARLISLE PA 17013 Service Type M If you or your employee/obligor have any questions contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us OMB No.* 0970-0154 Page 2 of 2 Form EN-028 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: SNOW, KIRSTIN D. PACSES Case Number 140110384 Plaintiff Name TIMOTHY A. SNOW Docket Attachment Amount 00900 S 2008 $ 454.00 Child(ren)'s Name(s): DOB ZANE T. SNOW 08/17103 PACSES Case Number 732110440 Plaintiff Name TIMOTHY A. SNOW o k Attachment Amount 08-4955 CIVIL $ 733.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name D cket Att achment Amount $ 0.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docks 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 Form EN-028 Service Type M OMB No.: 0970-0154 Worker ID $IATT