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WRIGHT, Plaintiff/Respondent VS. ANN M. WRIGHT, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA : CIVIL ACTION : NO. 04-1375 : IN DIVORCE ORDER AND NOW, this ZZ4?' day of ?.r. l..i 2005, upon consideration of the Motion to Make Rule Absolute, it is hereby ORDERED that the Rule which was issued on Plaintiff Patrick M. Wright, and Defendant's counsel, Barbara Sumple-Sullivan, Esquire, in the above-captioned matter on August 31, 2005, to show cause why the appearance of Dissinger and Dissinger should not be withdrawn is made absolute, and that Dissinger and Dissinger's Petition is granted, and the firm is no longer counsel. ?q BY THE COURT: i J. 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'-4g6taM •N uUV ggtM saptsaa ATquaaano 33TgUTVTd agS aaggs3 3O -4sgq sT uaapTtgo agI 0-3 33TquteTd 3o dtgsuoi'4eTaa agy '6£ 068Z-SL6 (LTL) TTOLT Vd 'TTTH dweO ?aaz?S puZ£ -N 8Z 9£LLZ # GI ;znoO awazdnS 33TIuTPTd zo; fauzo41V zaburssta za44g •FI AaPW uaoxISsia Pup 2immisSIa 'pagltwgns ATTnjgoadsag •uoTgelTSin 90 sggBla aTgeuoseaz paque.zb aq juepua3aQ qeu:l pue 33t:IuzPTd 0:1 APOISno -4uez5 04 gznoO aTgezouoH znoA sAezd ATTnjgDadsaz 33T4uzeTd 'HEOdH?dHHM 33T'4uTeZd biz tz d •uoT4PDTJTsTP3 UaOmsun oq buTgeTGJ b06'v§ 'S'o 'pd 8T 30 SaT'4jeuad aq-4 o-4 :IoaCgns ap2w a32 uTazaq s-4uawagP4s asZs3 gegq puegszapun I -goazzoo pua anzq azs quawnoop buTo6azo3 aqq UT apew squawag2ls aqq gegq AJTzaA 'ggbTzM •W NOTzIed 'I NOIZKJIdIESA ,,.? ?. =„ '"? _ ?. ? ,_, r n? ? p C' ? V C ? ?? ? ~ ' ? vi c; c ?? ? ? s ?. \\ PATRICK M. WRIGHT IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 04-1375 CIVIL ACTION LAW ANN M. WRIGHT IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday April 07, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before -Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street Mechanicsburg, PA 17055 on Tuesday, May 04, 2004 at 1:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ DaWn S. Sunday; Esq mhc Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717)249-3166 ?I III!-? 8-?Er.'?h001 Art` ':! t'Ol ib )`d 3N.i -JO l i,.J.'G-Q3lla PATRICK M. WRIGHT, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY : PENNSYLVANIA VS. : CIVIL ACTION ANN M. WRIGHT, : NO. 04-1375 Defendant : IN DIVORCE AFFIDAVIT OF MAILING COMMONWEALTH OF PENNSYLVANIA . ss .. COUNTY OF CUMBERLAND Mary A. Etter Dissinger, attorney for Plaintiff, being duly sworn according to law, says that she mailed by United States Certified Mail, Restricted Delivery, a true and correct copy of the Plaintiff's Consolidated Complaint: in Divorce in this action to the Defendant at her residence, and that Defendant did receive same as evidenced by the signed receipt dated April 5, 2004, attached hereto as Exhibit "A". `-,po 2n:g G)6LXC ;. Mary A. Etter Dissinger ?? Attorney for Plaintiff Supreme Court ID #27736 28 North Thirty-second Street Camp Hill, PA 17011 (717) 975-2840 Sworn to and subscribed Before me this eighth (8th) lay of April, 2004. tary Public NOTARIAL S MA MEGAN A. LABIt3F108KY, Nobry P1ble Camp HIBwo,Cw6wWd Cou* My Commiedon ExpNea Nov. 8, X08 ecomplete itema t 2 • Print y uRestdcted so that w Hama and i • Attach this can return or on the card to the Ront % t• ArticleAddre apace seed to: l? A complete to therevarse rX You. the mailpiece, B. 110) G33 Lori ht von (?? 01 D. Is de , It YES, enter dery ucre Q Regis's mall Umber Insu ? lt sx ?.. r a 'ce ResMcted Delivegr C, 391, ?003 Au' t 2001 3.110 ?? urn a X92 6798 spj,dy EUSPS laaeis Pald? ge ?` it No GAO UNITED STATES PpSTAL and ZIP+4 in this bO ss M Z 06 e adore ,s, Print your nam c"1 n °i - . gender: Piea (x/? O t-- ? 1a .04 -5 UNITED STATES POSTAL SERVICE :I First-Class Mail I Postage & Fees Paitl I U • I I S Sender. SP Please Pwmh NO. G10 Mint your name, add OJ SSin?? ress, and ZIP+4 in this bo AIADPV ttn oi55jn ;18 N. eYS a? L z 3a"? 5?ree? ? o. CQ P Him pq ac ? cx: lno)? co cz f ? v EXHIBIT 'FA„ C7 N_ C? 1a -i? .. i' j n? ? Barbara Sumple-Sullivan, Esquire Supreme court #32317 549 Bridge Street New Cumberland, PA 17070 17171774-1445 PATRICK M. WRIGHT, Plaintiff V. ANN M. WRIGHT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-1375 CIVIL ACTION - LAW IN DIVORCE PETTTION RAISING MARITAL CLAIMS UNDER THE DIVORCE CODE OF 1980 AND NOW, this ? day of May, 2004, comes Defendant, Ann M. Wright (hereinafter referred to as "PETITIONER"), by and through her attorney, Barbara Sumple-Sullivan, Esquire and files this Petition Raising Marital Claims Under the Divorce Code of 1980 and in support thereof states as follows: A Complaint in Divorce was filed on April 1, 2004. 2. Petitioner is the Defendant in the above action. Petitioner requests the Court to enter an order granting; support, alimony pendente lite and alimony to your Petitioner as the Court deems reasonable pursuant to Sections 3701 and 3702 of the Divorce Code of 1980, together with any amendments thereto. 4. Defendant lacks sufficient assets to provide for her reasonable needs and is unable to support herself fully through appropriate employment. 5. Plaintiff has sufficient assets to provide continuing support for Defendant. 6. Plaintiff has sufficient assets to provide alimony pendente lite for Defendant. WHEREFORE, Petitioner requests your Honorable Covert to enter an award of alimony and enter an award of alimony pendente lite, spousal support, until final hearing, and thereupon enter an award of alimony. Respectfully submitted, DATE: May 1 2004 ? ?- Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney Por Defendant PATRICK M. WRIGHT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-1375 ANN M. WRIGHT, CIVIL ACTION -LAW Defendant IN DIVORCE VERIFICATION I, Ann M. Wright, hereby certify that the facts set fbrth in the foregoing PETITION RAISING MARITAL CLAIMS 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. §4904 relating to unsworn falsification to authorities. DATED: fybtt U - 2004 ` \ Jv ANN M. WRIGHT Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 717)774-1445 PATRICK M. WRIGHT, IN THE COURT OF COMMON PLEAS TY PENNSYLVANIA Plaintiff V. ANN M. WRIGHT, Defendant CUMBERLANI) COUN NO. 04-1375 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 the foregoing PETITION RAISING MARITAL CLAIMS in the above-captioned matter upon the following individual(s) by first class mail, postage prepaid, addressed as follows: Mary A. Etter Dissinger, Esquire Dissinger and Dissinger 28 North Thirty-Second Street Camp Hill, PA 17011 DATED: May ( 2004 Barbara Sumple-Sullivan, Esquire Attorney for Defendant 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme; Court I.D. No. 32317 c r j Ti i }a ? l h? Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717)774-1445 PATRICK M. WRIGHT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 04-1375 ANN M. WRIGHT, CIVIL ACTION - LAW Defendant IN DIVORCE DRS ATTACHMENT FOR APL PROCEEDINGS PETITIONER NAME Ann M. Wri ht ADDRESS 633 Devon Road, Cam Hill, PA 17011 BIRTH DATE Se tember 23, 1965 SOCIAL SECURITY NUMBER 248-49-6262 HOME PHONE 717 737-0950 WORK PHONE N/A EMPLOYER NAME N/A EMPLOYER ADDRESS N/A JOB TITLE/POSITION Homemaker DATE EMPLOYMENT COMMENCED N/A GROSS PAY N/A NET PAY N/A OTHER INCOME N/A ATTORNEY'S NAME Barbara Sum le-Sullivan, Esquire ATTORNEY'S ADDRESS 549 Bride Street, New Cumberland, PA 17070 ATTORNEY'S PHONE NUMBER 717 774-1445 RESPONDENT NAME Patrick M. Wri ht ADDRESS 254 North 29 Street, Cam Hill, PA 17011 B-I TH DATE March 18, 1963 SOCIAL SECURITY NUMBER 170-56-3174 HOME PHONE 717 WORK PHONE 406 581-7058 R NAME Montana State Universit R ADDRESS Unknown /POSITION V Senior Research Assoc. PLOYMENT COMMENCED known Y $90,000.00 OTHER INCOME ATTORNEY'S NAME Mary A. Etter Dissinger, Esquire Dissin er an d Dissin er ATTORNEY'S ADDRESS 28 North 32" Street, Cam Hill, PA 17011 ATTORNEY'S PHONE NUMBER 717 975-2840 MARRIAGE INFORMATION DATE OF MARRIAGE June 7, 1986 PLACE OF MARRIAGE Charleston, SC DATE OF SEPARATION December 6, 2003 ADDRESS OF LAST MARITAL HOME 633 Devon Road Cam Hill, PA 17011 DESCRIPTION OF DOCUMENT RAISING APL CLAIM Petition Raising Marital Claims DATE APL DOCUMENT FILED Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 PATRICK M. WRIGHT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 04-1375 ANN M. WRIGHT, CIVIL ACTION -LAW Defendant IN DIVORCE DRS ATTACHMENT FOR APL PROCEEDINGS PETITIONER NAME Ann M. Wri ht ADDRESS 633 Devon Road, Cam Hill, PA 17011 BIRTH DATE Se tember 23, 1965 SOCIAL SECURITY NUMBER 248-49-6262 HOME PHONE 717 737-0950 WORK PHONE N/A EMPLOYER NAME N/A EMPLOYER ADDRESS N/A JOB TITLE/POSITION Homemaker DATE EMPLOYMENT COMMENCED N/A GROSS PAY N/A NET PAY N/A OTHER INCOME N/A ATTORNEY'S NAME Barbara Sum le-Sullivan, Esquire ATTORNEY'S ADDRESS 549 Bride Street, New Cumberland, PA 17070 ATTORNEY'S PHONE NUMBER 717 774-1445 RESPONDENT NAME Patrick M. Wright ADDRESS 254 North 29 Street, Cam Hill, PA 17011 BIRTH DATE March 18, 1963 SOCIAL SECURITY NUMBER 170-56-3174 HOME PHONE 717 WORK PHONE 406 581-7058 EMPLOYER NAME Montana State University EMPLOYER ADDRESS Unknown JOB TITLE/POSITION Senior Research Assoc. DATE EMPLOYMENT COMMENCED Unknown GROSS PAY $90,000.00 NET PAY OTHER INCOME ATTORNEY'S NAME Mary A. Etter Dissinger, Esquire Dissin er and Dissin er ATTORNEY'S ADDRESS 28 North 32 Street, Cam Hill, PA 17011 ATTORNEY'S PHONE NUMBER 717 975-2840 MARRIAGE INFORMATION DATE OF MARRIAGE June 7, 1986 PLACE OF MARRIAGE Charleston, SC DATE OF SEPARATION December 6, 2003 ADDRESS OF LAST MARITAL HOME 633 Devon Road Cam Hill, PA 17011 DESCRIPTION OF DOCUMENT RAISING APL CLAIM Petition Raising Marital Claims DATE APL DOCUMENT FILED Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 PATRICK M. WRIGHT, Plaintiff V. ANN M. WRIGHT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-1375 CIVIL ACTION - LAW IN DIVORCE DRS ATTACHMENT FOR APL PROCEEDINGS PET ITIONER NAME Ann M. Wright Camp Hill, PA 17011 633 Devon Road ADDRESS , BIRTH DATE Se tember 23, 19 55 SOCIAL SECURITY NUMBER 248-49-6262 HOME PHONE 717 737-0950 WORK PHONE N/A EMPLOYER NAME N/A EMPLOYER ADDRESS N/A JOB TITLE/POSITION Homemaker DATE EMPLOYMENT COMMENCED N/A GROSS PAY N/A NET PAY N/A OTHER INCOME N/A ATTORNEY'S NAME Barbara Sum le-Sullivan, Esquire ATTORNEY'S ADDRESS 549 Bridge Street, New Cumberland, PA 17070 ATTORNEY'S PHONE NUMBER 717 774-1445 SPONDENT R NAME t ADDRESS et, Cam Hill, PA 17011 tre g BIRTH DATE E Z SOCIAL SECURITY HOME PHONE WORK PHONE 57 EMPLOYER NAME Montana State University EMPLOYER ADDRESS Unknown JOB TITLE/POSITION Senior Research Assoc. DATE EMPLOYMENT COMMENCED Unknown GROSS PAY $90,000.00 NET PAY OTHER INCOME ATTORNEY'S NAME Mary A. Etter Dissinger, Esquire Dissin er and Dissin er ATTORNEY'S ADDRESS 28 North 32"d Street, Cam Hill, PA 17011 ATTORNEY'S PHONE NUMBER 717 975-2840 MARRIAGE INFORMATION DATE OF MARRIAGE June 7, 1986 PLACE OF MARRIAGE Charleston, SC DATE OF SEPARATION December 6, 2003 ADDRESS OF LAST MARITAL HOME 633 Devon Road Cam Hill, PA 17011 DESCRIPTION OF DOCUMENT RAISING APL CLAIM Petition Raising Marital Claims DATE APL DOCUMENT FILED Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 PATRICK M. WRIGHT, Plaintiff V. ANN M. WRIGHT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-1375 CIVIL ACTION - LAW IN DIVORCE DRS ATTACHMENT FOR APL PROCEEDINGS PET ITIONER NAME Ann M. Wri ht ADDRESS 633 Devon Road, Cam Hill, PA 17011 BIRTH DATE Se tember 23, 1965 SOCIAL SECURITY NUMBER 248-49-6262 HOMEPHONE 717 737-0950 WORK PHONE N/A EMPLOYER NAME N/A EMPLOYER ADDRESS N/A JOB TITLE/POSTTION Homemaker DATE EMPLOYMENT COMMENCED N/A GROSS PAY N/A NET PAY N/A OTHER INCOME N/A ATTORNEY'S NAME Barbara Sum le-Sullivan, Esquire ATTORNEY'S ADDRESS 549 Brid e Street, New Cumberland, PA 17070 ATTORNEY'S PHONE NUMBER 717 774-1445 RESPONDENT NAME Patrick M. Wri it ADDRESS 254 North 29 Street, Cam Hill, PA 17011 BIRTH DATE March 18, 1963 SOCIAL SECURITY NUMBER 170-56-3174 HOME PHONE 717 WORK PHONE 406 581-7058 EMPLOYER NAME Montana State Uruversit EMPLOYER ADDRESS Unknown JOB TITLE/POSITION Senior Research Assoc. DATE EMPLOYMENT COMMENCED Unknown GROSS PAY $90,000.00 NET PAY OTHER INCOME ATTORNEY'S NAME Mary A. Etter Dissinger, Esquire Dissin er and Dissin er ATTORNEY'S ADDRESS 28 North 32n Street, Cam Hill, PA 17011 ATTORNEY'S PHONE NUMBER 717 975-2840 MARRIAGE INFORMATION DATE OF MARRIAGE June 7, 1986 PLACE OF MARRIAGE Charleston, SC DATE OF SEPARATION December 6, 2003 ADDRESS OF LAST MARITAL HOME 633 Devon Road Cam Hill, PA 17011 DESCRIPTION OF DOCUMENT RAISING APL CLAIM Petition Raising Marital Claims DATE APL DOCUMENT FILED PATRICK M. WRIGHT, Plaintiff/Respondent VS. ANN M. WRIGHT, Defendant/Petitioner : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA : CIVIL ACTION : NO. 04-1375 : IN DIVORCE ANSWER TO DEFENDANT'S PETITION RAISING MARITAL CLAIMS UNDER THE DIVORCE CODE OF 1980 AND NOW comes Plaintiff/Respondent, Patrick M. Wright, by and through his attorneys, Dissinger and Dissinger, and files the following Answer to Defendant's Petition Raising Marital Claims Under the Divorce Code of 1980 and in support thereof avers as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Denied. It is denied that Defendant/Petitioner lacks sufficient assets to provide for her reasonable needs. It is denied that she is unable to support herself through appropriate employment. By way of further answer it is averred that in the recent past, Defendant/Petitioner withdrew $8,000.00 from the parties' joint safety deposit box and has appropriated it to her own purposes. 5. Denied. It is denied that the Plaintiff/Respondent has sufficient assets to provide continuing support for Defendant/Petitioner. By way of further answer it is averred that the parties have four (4) children and they have a shared custodial arrangement, although not yet a 50/50 arrangement. 6. Denied. It is denied that Plaintiff/Respondent has sufficient assets to provide alimony pendente lite to Defendant/Petitioner. By way of further answer, it is averred that Defendant/Petitioner has the ability to work and sufficient assets to provide for her own needs. WHEREFORE, Plaintiff/Respondent :respectfully requests to Court to deny Defendant/Petitioner's request for alimony pendente lite, spousal support and alimony. NEW MATTER 1. Defendant/Petitioner in this action has conducted herself in such a fashion that she is not entitled to alimony. Respectfully submitted: DISSINGER AND DISSINGER Od Mary A. Etter Dissinger Attorney for Plaintiff Supreme Court ID #27736 28 N. 32" Street Camp Hill, PA 17011 (717) 975-2840 VERIFICATION I, Patrick M. Wright, verify that. the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification. i tr ht, Plaintiff PATRICK M. WRIGHT, Plaintiff/Respondent VS. ,ANN M. WRIGHT, Defendant/Petitioner : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA : CIVIL ACTION : NO. 04-1375 : IN DIVORCE CERTIFICATE OF SERVICE I, Mary A. Etter Dissinger, Esquire, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon Barbara Sumple-Sullivan, Esquire, attorney for Defendant, Ann M. Wright, by First Class United States mail addressed as follows: Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 Date: ? Mary A. Etter Dissing r - - ? m c r -?- h rQ `L O \111, PATRICK M. WRIGHT IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 04-1375 CIVIL ACTION LAW ANN M. WRIGHT Defendant IN CUSTODY ORDER OF COURT AND NOW, this /Z.- day of ^07 2004, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Patrick M. Wright, and the Mother, Ann. M. Wright, shall have shared legal custody of Rebecca A. Wright, born July 19, 1988, Jasmine M. Wright, born November 12, 1990, Justin P. Wright, born October 16, 1992 and Hannah A. Wright, barn April 16, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. 2. The parties shall have physical custody of the Children as follows: A. During the school year pending review of the custody arrangements at an additional custody conciliation conference, the parties shall alternate having custody of the Children on weekends from Friday after school through Monday morning before school, beginning with the Mother having custody of the Children for the weekend of Friday, May 7, 2004. The Father shall have custody, during weeks following the Father's weekends, from Wednesday after school through Thursday before school, and during weeks following the Mother's weekends, from Tuesday after school through Wednesday before school. The Mother shall have custody of the Children during weekdays at all times not otherwise specified for the Father. B. During the summer school break, the parties shall alternate having custody of the Children during three periods of custody each week:. The first period shall run from Friday at 5:00 pm through Monday at 5:00 pm, the second period shall run from Monday at 5:00 pm through Wednesday at 5:00 pm, and the third period shall run from Wednesday at 5:00 pm thorough Friday at 5:00 pm. p• r Ano -in C. In addition, during the summer, each party shall be entitled to have custody of the Children for three weeks, with no more than two weeks to be scheduled consecutively. The parties shall provide each other with as much notice as possible when scheduling extended periods under this provision. 3. The parties shall have custody of the Children on holidays as follows: A. THANKSGIVING: The parties shall alternate having custody of the Children over the Thanksgiving holiday from after school on Wednesday through the Sunday following Thanksgiving. The Father shall have custody of the Children for Thanksgiving in even numbered years and the Mother shall have custody in odd numbered years. B. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which shall run from after school on the last day before the holiday break through the end of the first half of the Christmas school break, and Segment B, which shall include the second half of the Christmas school break. In the event that the Children's entire Christmas school break runs for an odd number of days, the extra day shall fall within Segment A. In even numbered years, the Mother shall have custody of the Children during Segment A and the Father shall have custody during Segment: B. In odd numbered years, the Father shall have custody of the Children during Segment A and the Mother shall have custody during Segment B. The parties acknowledge that the Christmas holiday arrangements are designed to provide extended periods of custody to accommodate travel plans. In the event that the parent having custody of the Children during Segment A remains in the local area over the holiday, that party shall cooperate in scheduling a period of custody for the non-custodial parent on the holiday. C. EASTER: The Mother shall have custody of the Children every year over the Easter school break for up to five days, for which the Children shall not be removed from school for more than two days. D. JULY 4TH: The Father shall have custody of the Children for the July 4ch holiday every year for a period of up to five days. E. MOTHER'S DAY / FATHER'S DAY: The Mother shall have custody of the Children every year on Mother's Day and the Father shall have custody of the Children every year on Father's Day. F. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 4. Neither party shall schedule any period of custody (or combination of holiday, vacation or regular custody) to extend more than fourteen consecutive days, unless otherwise agreed between the parties. 5. The parties agree that in the event either party is traveling due to work or otherwise and is unavailable to provide care for the Children, that party shall offer the other party the opportunity to provide care for the Children with as much advance notice as possible. 6. The parties shall promptly share all information concerning the Children's school and activities schedule and shall notify each other in advance of all medical or other appointments scheduled for the Children. 7. The parties agree that they will defer to the Children's choices with regard to attendance at activities, but will notify the other parent in advance if that party intends to permit a Child to miss an activity. 8. The parties agree to cooperate by assisting the custodial parent whenever possible in providing transportation for the Children to activities when necessary to ensure that the Children are able to attend. 9. The parties and counsel shall attend an additional custody conciliation conference in the office of the conciliator, Dawn Sunday, on Tuesday, August 17, 2004 at 8:30 am, for the purpose of reviewing the custody arrangements prior to the beginning of the 2004-2005 school year. 10. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, L ANA cc: 'Mary A. Etter Dissinger, Esquire - Counsel for Father Barbara Sumple-Sullivan, Esquire - Counsel for Mother J? -0? PATRICK M. WRIGHT Plaintiff VS. ANN M. WRIGHT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Defendant 04-1375 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME Rebecca A. Wright Jasmine M. Wright Justin P. Wright Hannah A. Wright DATE OF BIRTH July 19, 1988 November 12, 1990 October 16, 1992 April 16, 1998 CURRENTLY IN CUSTODY OF Mother / Father Mother / Father Mother / Father Mother / Father 2. A Conciliation Conference was held on May 4, 2004, with the following individuals in attendance: The Father, Patrick M. Wright, with his counsel, Mary A. Etter Dissinger, Esquire, and the Mother, Ann M. Wright, with her counsel, Barbara Sumple-Sullivan, Esquire. 3. The parties agreed to entry of an Order in the form as attached. t A l ! a0( )Li &---, Date Dawn S. Sunday, Esquire Custody Conciliator PATRICK M. WRIGHT, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 2004-1375 CIVIL TERM ANN M. WRIGHT, IN DIVORCE Defendant/Petitioner Pacses# 551106380 ORDER OF COURT AND NOW, this 12" day of May, 2004, upon consideration of the attached Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shaddav on June 21, 2004 at 9:00 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11© (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, George E. Hoffer, President Judge Mail copies on Petitioner 5-12-04 to: < Respondent Barbara Sumple-Sullivan, Esquire _ Mary Dissinger, Esquire Date of Order: Mav 12. 2004 J( / / YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 CC361 c? rN. T? Cn Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 PATRICK M. WRIGHT, Plaintiff V. ANN M. WRIGHT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-1375 CIVIL ACTION - LAW IN DIVORCE REPLY TO NEW MATTER 1. Denied. It is denied that Defendant has conducted herself in such a fashion that she is not entitled to alimony. It is specifically averred that Defendant is the innocent and injured party and Plaintiff has acted to offer indignities to her during the marriage. WHEREFORE, Defendant requests support/ APL and alimony be entered in her favor. Respectfully DATED: May , 2004 Barbara Sumple-Sullivan, Esquire Attorney for Defendant 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 Barbara Sumple-Sullivan, Esquire Supreme Court 432317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 PATRICK M. WRIGHT, IN THE COURT OF COMMON PLEAS Plaintiff PERRY COUNTY, PENNSYLVANIA V. CIVIL ACTION - : IN DIVORCE ANN M. WRIGHT Defendant NO. 04-1375 VERIFICATION I verify that the statements made in this Reply to New Matter are true and correct. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unworn falsification to authorities. Date: May G_, 2004 ANN M. WRIGHT Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 PATRICK M. WRIGHT, Plaintiff V. ANN M. WRIGHT Defendant IN TI-R's COURT OF COMMON PLEAS PERRY" COUNTY, PENNSYLVANIA CIVIL ACTION - IN DIVORCE NO. 04-1375 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 DEFENDANT'S RESPONSE TO NEW MATTER, in the above-captioned matter upon the following individual(s) by first class mail, postage prepaid, addressed as follows: DATED: May IL 2004 Mary A. Etter Dissinger Dissinger & Dissinger 28 N. Thirty-Second Str E Camp Hill, PA 170,Yl Barbara Sumple-Sullivan, Esquire Attorney for Defendant 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 ?) N G'7 o 1• •T7 r - ,v o ?z C> _r ?? ?1 C.J ' ?,j -^C F PATRICK M. WRIGHT, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA Vs. CIVIL ACTION - DIVORCE NO. 2004-1375 CIVIL TERM ANN M. WRIGHT, IN DIVORCE Defendant/Petitioner Paeses# 551106380 ORDER OF COURT AND NOW, this 21" day of June, 2004, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $924.30 and Respondent's monthly net income/earning capacity is $5,300.85, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $934.00 per month payable monthly as follows; $934.00 for alimony pendente lite and $0.00 on arrears. First payment due within en days of this date. Arrears set at $1,868.00 as of June 21, 2004. The effective date of the order is May 5, 2004. This Order considers that the wife is livig in the marital home and is responsible for the mortgage that has escrow for taxes and insurance. The additional sum for the mortgage is $138.96 per month. DRO will reconsider the additional sum for mortgage once wife is employed and finished with the current real estate course. Husband is to make a direct payment of $934.00 to wife within ten days of this Order, unless the Wage Withholding Order is effective. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C.S.§ 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the PA SCDU to: Ann M. Wright. Payments must be made by check or money order. All checks and money orders must be made payable to PA SCDU and mailed to: PA SCDU P.O. Box 69110 Harrisburg, PA 17106-9110 Payments must include the defendant's PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. Unreimbursed medical expenses that exceed $250.00 annually are to be paid 0% by the respondent and 100% by petitioner. The petitioner is responsible to pay the first $250.00 annually in unreimbursed medical expenses. Respondent to provide medical insurance coverage. Within thirty (30) days after the entry of this order, the Respondent shall submit written proof that medical insurance coverage has been obtained or that application for coverage has been made. Proof of coverage shall consist, at a minimum, of. 1) the name of the health care coverage provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims should be made; 5) a description of any restrictions on usage, such as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and co-payments; and d) five copies of any claim forms. This Order shall become final ten days after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary for a hearing de novo before the Court. DRO: R. J. Shadday Mailed copies on Petitioner 6-23-04 to: < Respondent Barbara Sumple-Sullivan, Esquire Mary Dissinger, Esquire BY THE COURT, d .54 X4 Kevin A. Hess J. C' ci O C_- c? s -rl ?_ ? _r -r ? ti irn =- w c"?n r ? _. -' -._.. __ -, ?? - %> r_ w .?? W `` C`: ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Q Original order/Notice Co./City/Dist. of CUMBERLAND O Amended Order/Notice Date of Order/Notice 06/21/04 O Terminate Order/Notice Tribunal/Case Number (See Addendum for case summary) RE: WRIGHT, PATRICK M. Employer/Withholder's Federal EIN Number Employee/Obligor's Name (Last, First, MI) 170-56-3174 Employee/Obligor's Social Security Number MONTANA STATE UNIVERSITY 9527101322 PO BOX 172520 bit s-1375eivIe_ Employee/Obligor's Case Identifier BOZEMAN MT 59717-2520 (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, MI) /'Res£ s / 7 3?oto ??? 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. $ 2, 255.00 per month in current support $ o. oo per month in past-due support Arrears 12 weeks or greater? Oyes ® no $ 0.00 per month in medical support $ o . 00 per month for genetic test costs $ per month in other (specify) for a total of $ 2, 255.00 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: $ 520.38 per weekly pay period. $ 1. 040.77 per biweekly pay period (every two weeks). $ 1. 127.50 per semimonthly pay period (twice a month). $ 2.255. oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #10 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. Date of Order: JUN 2 2 e, ' y LUI RT: ?' rr ??..aarHE COU (c -dl Form EN-028 Service Type M OMB No.: 0970-0154 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? I hecke? you are required to provide a copy of this form to your employee. If yo r employee works in a state that is ci erent from the state that issued this order, a copy must be provided to your employee even if the box is not checked. 1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned businesses located on a reservation that choose to withhold in accordance with this notice. 2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 3. Combining Payments: You can combine withheld amounts from more than one employee%bligor'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. 4.* Report ng the Paydate/Date of Withholding. You ee swages You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 5.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to withhold income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #10 below) 6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S ID: 5542100066 EMPLOYEE'S/OBLIGOR'S NAME: WRIGHT, PATRICK M. EMPLOYEE'S CASE IDENTIFIER: 9527101322 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because or a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 10.* Withholding Limits: You may not withhold more than the lesser of. 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 11. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 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 wwvv.childsupport.state.pa.us Page 2 of 2 OMB No.: 097P0154 Form EN-028 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: WRIGHT, PATRICK M. PACSES Case Number 551106380 Plaintiff Name ANN M. WRIGHT Docket Attachment Amount 04-1375 CIVIL$ 934.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. Service Type M PACSES Case Number 793106382 Plaintiff Name_ ANN M. WRIGHT Docket Attachment Amount 00379 S 2004 $ 1,321.00 Child(ren)'s Name(s): DOB REBECCA ANN WRIGHT 07/19/88 JASMINE MARIE WRIGHT 11/13/90 JUSTIN PATRICK WRIGHT 10/16/92 HANNAH AD19LE WRIGHT 04/.16/98 ? If checked, you are required to enroll thechild(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Addendum OMB No.: 097"154 Form EN-028 Worker ID $IATT c7 ? o 1 -7-Yi c.. m ?? -rr rn t < ut U? Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 PATRICK M. WRIGHT, Plaintiff v ANN M. WRIGHT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Civil Action - Law NO. 2004-1375 PACSES Case Number; 551106380 APPEAL OF ORDER AND REQUEST FOR HEARING DE NOVO TO THE PROTHONOTARY: Please accept this as an Appeal of the Order dated June 21, 2004 and request to schedule the matter for De Novo Hearing before the Support Master. Dated: July 1, 2004 Barbara Supple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Supreme Court No. 32317 Attorney for Defendant Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 PATRICK M. WRIGHT, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. ANN M. WRIGHT, Defendant Civil Action - Law NO. 2004-1375 PACSES Case Number: 551106380 CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy of the APPEAL OF ORDER AND REQUEST FOR HEARING DE NOVO, in the above-captioned matter upon the following individual, via United States first-class mail, postage prepaid, addressed as follows: Mary A. Dissinger, Esquire Dissinger and Dissinger 28 North 32nd Street Camp Hill, PE 17011 DATE: July 1, 2004 Barbara Sumple-Sullivan, Esquire 549 Bridge; Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Defendant v i U N c > 1'1 ( T TI ? IIZI cl?l JT J.'1 rD C In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION ANN M. WRIGHT ) Docket Number 04-1375 CIVIL Plaintiff ) VS. ) PACSES Case Number 551106380 PATRICK M. WRIGHT ) Defendant ) Other State ID Number ORDER OF COURT You, PATRICK M. WRIGHT plaintiff/defendant of 254 N 29TH ST, CAMP HILL, PA. 17011-2904-54 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the AUGUST 19, 2004 at 9: ooAM for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as Ifil `r Q 2. your pay stubs for the preceding six (6) months, _ 3. verification of child care expenses, and 4. proof of medical coverage which you may have, or may have available to you 5. information relating to professional licenses w 6. other: cn Form CM-509 Service Type M Worker ID 21302 WRIGHT v. WRIGHT PACSES Case Number: 551106380 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the! support action. BY THE COURT: Date of Order: -) =04 / JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES WHAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Service Type M Worker ID 21302 _., ?? °? ''?i ?_ ?? _? ?-. a. -, , N ,?;> ---? l . _W ' C. .. .T' ., G In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION ANN M. WRIGHT ) Docket Number 04-1375 CIVIL Plaintiff ) vs. ) PACSES Case Number 551106380 PATRICK M. WRIGHT ) Defendant ) Other State ID Number ORDER OF COURT You, ANN M. WRIGHT Plaintiff/defendant of 633 DEVON RD, CAMP HILL, PA. 17011-1621-33 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the AUGUST 19, 2004 at 9: ooAM for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. verification of child care expenses, and 4. proof of medical coverage which you may have, or may have available to you 5. information relating to professional licenses 6. other: o in .n Form CM-509 Type M Worker ID 21302 WRIGHT v. WRIGHT PACSES Case Number: 551106380 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: "7- / -04 /104 JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE 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 CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Service Type M Worker ID 21302 ?, :? ? ;-, ? ?_ - -?, ' ., _ ?, ' ,. _ - ; ,,, ? -r, . ` . N ? . r - i t.o s- - ?;. In the Court of Common Pleas of DOMESTIC CUMBERLAND County RELATIONS SECTION , Pennsylvania ANN M. WRIGHT Plaintiff ) Docket Number 04-1375 CIVIL vs. ) PATRICK M. WRIGHT ) PACSES Case Number ) 551106380 Defendant Other State ID Number RESCHEDULE ORDER OF COURT You, NN M. WRIGHT 633 DEVON RD, A CAMP HILL, PA. 17011-1621-33 Plaintiff/defendant of are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, :PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the OCTOBER 6, 2004 You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W_2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. verification of child care expenses, and 4• proof of medical coverage 5. which you may have, or may have available to you information relating to professional licenses 6• other: Service Type M at 9:0oAM for a hearing. Form CM-509 Worker ID 21700 WRIGHT V• WRIGHT PACSES Case Number: 551106380 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO REPRESENT YOU. IF YOU DO NOT MAY ATTEND THE THE OFFICE SET FORTH BELOW, HAVE A LAWYER, GO TO OR TELEPHONE YOU WITH INFORnIA H B ABOUT HIS OFFICE MAY BE ABLE TO PROVIDE SERVICES TO ELIGIBLE PERSONS AT AGENCIES THAT MAY OFFER REDUCED FEE OR NO FEE. LEGAL CUMBERLAND CO EAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 co The Court of Common Plmply with the Americans with eas of Disabilities Act of 1990. facilities and reasonable accommodations For before the court, please available t disabled made atlea contact our office at: (sine 240-6225 scheduled 11 72 hearing. hours prior to any hearing or business before the Service Type M Page 2 of 2 County is required by law to information about accessible individuals having business All arrangements must be court. You must attend the Form CM-509 Worker ID 21700 r? ?? ?:, __- ?, =? ' ?? - i ? _:.. rj ? CR .. ?'r7 j Q'i In the Court of Common pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION ANN M. WRIGHT Plaintiff Docket Number 04-1375 CIVIL vs. ) PATRICK M. WRIGHT PACSES Case Number 551106380 Defendant ? Other State ID Number RESCHEDULE ORDER OF COURT You, PATRICK M. WRIGHT plaintiff/defendant of 254 N 29TH ST, CAMP HILL, PA. 17011-2904-54 are Ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, :PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the OCTOBER 6, 2004 at 9: 00AM for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. Your pay stubs for the preceding six (6) months, 3. verification of child care expenses, and 4. Proof of medical coverage which you may have, or may have available to you 5. information relating to professional licenses 6. other: Service Type M Form CM-509 Worker ID 21700 WRIGHT V- WRIGHT PACSES Case Number: 551106380 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: q JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND T REPRESENT YpIJ, IF YOU DO NOT THE OFFICE SET* FORTH BELOW. AVEOA LAWYER, GO TO OR TELL G AND THIS YOU WITH INFORMATION ABOUT MAY BE ABLE O PROVIDE SERVICES TO ELIGIBLE PERSONS AT A RAGENCIES EDUCED FEE OR NO FEE. MAY OFFER LEGAL CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 The AMERICANS WITH DISABILITIES ACT OF 1990 Court of Common Pleas of CUMB comply with the Americans with Disabilities Act ofER1990, information For County is required claw to before facilities and reasonable accommodations le to disabled individuals having a bucessible made at siness (availab717) zoo-6z2s . Al] arrangements must be the court, least 72 hours s pr or to any hearing or business before the court. scheduled hearing. You must attend the Service Type M Page 2 of 2 Form CM-509 Worker ID 21700 ?_ C., y _1 ... _, ?, r. "?'? ?. , i -_ Sn C? p-? AW 2 5 2004 PATRICK M. WRIGHT Plaintiff Vs. ANN M. WRIGHT Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-1375 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this z (o • day of /+.., " v , 2004, upon consideration of the attached Custody Conciliation Report, it i's ordered and directed as follows: 1. The parties shall submit themselves, their minor Children, and any other individuals deemed necessary by the evaluator to a custody evaluation to be performed by a professional in the office of Arnold Shienvold, Ph.D. The purpose of the evaluation shall be to obtain independent professional recommendations concerning ongoing custody arrangements which will best meet the needs and interests of the Children. The parties shall sign any authorizations deemed necessary by the evaluator in order to obtain additional information pertaining to the parties or the Children. The parties agree that all costs of the evaluation shall be paid from marital assets. 2. Pending completion of the custody evaluation and further agreement of the parties or Order of Court, the prior Order of this Court dated May 12, 2004 shall Continue in effect with the exception of Paragraphs 2A and 2B which are vacated and replaced with the: provisions of this Order. 3. Pending completion of the custody evaluation and further agreement of the parties or Order of Court, and without prejudice to either party in any subsequent custody proceedings, the parties shall continue to follow the summer custody schedule under which the parties shall alternate having custody of the Children during three periods of custody each week. The first period shall run from Friday after school through Monday after school, the second period shall run from Monday after school through Wednesday after school, and the third period shall run from Wednesday after school through Friday after school. Neither party shall be prejudiced in any subsequent custody proceedings by his or her agreement to extend the summer custody arrangements temporarily pending completion of the custody evaluation and further resolution. VNVAVMd AUJ oo tlt:Rn,? igmo 5 I =1 wi 9Z snv h001 AWIONOH10ad 3N130 4. The parties and their counsel shall attend a follow-up conciliation conference in the office of the conciliator, Dawn S. Sunday, on Wednesday, December 15, 2004, at 8:30 a.m. to review the custody arrangements after receipt of the evaluator's recommendations. BY THE COURT, cc: Karen L. Koenigsberg, Esquire - Counsel for Father Barbara Sumple-Sullivan, Esquire - Counsel for Mother G`` PATRICK M. WRIGHT Plaintiff VS. ANN M. WRIGHT Defendant Prior Judge: Kevin A. Hess CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-1375 CIVIL ACTION LAW IN CUSTODY 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRIENTLY IN CUSTODY OF Rebecca A. Wright Jasmine M. Wright Justin P. Wright Hannah A. Wright July 19, 1988 November 12, 1990 October 16, 1992 April 16, 1998 Mother/Father Mother/Father Mother/Father Mother/Father 2. A conciliation conference was held on August 17, 2004, with the following individuals in attendance: The Father, Patrick M. Wright, with his counsel, Karen L. Koenigsberg, Esquire, and the Mother, Ann M. Wright, with her counsel, Barbara Sumple-Sullivan, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date Dawn S. Sunday, Esquir Custody Conciliator In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION ANN M. WRIGHT ) Docket Number 04-1375 CIVIL Plaintiff ) vs. ) PACSES Case Number 551106380 PATRICK M. WRIGHT ) Defendant ) Other State ID Number PETITION FOR MODIFICATION OF AN EXISTING SUPPORT ORDER 1. The petition of PATRICK M. WRIGHT respectfully represents that on JUNE 21, 2004 , an Order of Court was entered for the support of ANN M. WRIGHT A true and correct copy of the order is attached to this petition. Form OM-501 Service Type M Worker ID 21500 1.n i ro Ti r ? ,;Cm) In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION PACSES Case Number: 793106382 Docket Number: 00379 S 2004 Other State ID Number: Please note: All correspondence must include the PACSES Case Number. JUNE 21, 2004 SUMMARY OF TRIER OF FACT Plaintiff Information Defendant Information ANN M. WRIGHT PATRICK M. WRIGHT Address: 633 DEVON RD CAMP HILL PA 17011-1621 Employer: Attorney: BARBARA SUMPLE-SULLIVAN, ESQ. Address: 254 N 29TH ST CAMP HILL PA 17011-2904 Employer: MONTANA STATE UNIVERSITY PO BOX 172520 BOZEMAN MT 59717-2520 Attorney: MARY A DISSINGER ® Complaint for Support 05 / 05 / 04 ? Petition for Modification Filed ? Other Reason for Conference: WIFE FILED FOR SPOUSAL SUPPORT AND CHILD SUPPORT FOR 4C. HUSBAND DENIES LIABILITY FOR SPOUSAL SUPPORT. WIFE WILL PROCEED W/ APL UNDER PACSES CID#551106380 AND CIVIL DOCKET #04-1375. Dependent(s) REBECCA ANN WRIGHT JASMINE MARIE WRIGHT JUSTIN PATRICK WRIGHT HANNAH ADELE WRIGHT Current Order: $ o . o o 07/19/88 163-70-1766 11/13/90 10/16/92 608-60-0080 04/16/98 169-78-3423 /per month NEW ACTION Form CM-022 Service Type M Worker ID 2100-5 WRIGHT V. WRIGHT Plaintiff Information Current Income: $280.00/W GROSS E.C. $924.30/M NET Tax Return: M-6 Medical Coverage: Child Care/Tuition: Additional Obligations: MORTGAGE PAYMENT OF $1038.00/M (TAXES & INSURANCE IS ESCROWED) Other Information: PACSES Case Number: 793106382 ])efendant Information $7483.92/M GROSS $5300.85/M NET- M-6 HAS COVERAGE THROUGH HIS EMPLOYMENT FOR THE FAMILY @ A COST OF $97.05/M HAS A RENTAL PAYMENT ON A HOUSE OF $1025.00/M. IT IS A 6 MONTH LEASE, IS IN THE SAME SCHOOL DISTRICT, AND HAS 3 BR W/ A 4TH BR IN THE BASEMENT. 6/7/86: PARTIES WERE MARRIED AND THERE ARE FOUR CHILDREN OF THE MARRIAGE AND THE CHILDREN'S AGES RANGE FROM 15 YRS. THROUGH 6 YRS. 12/6/03: PLTF CONSIDERS THE PARTIES SEPARATED 4/1/04: HUSBAND FILED FOR DIVORCE 5/05/04: HUSBAND MOVED FROM THE RESIDENCE OF THE MARITAL HOME 5/05/04: WIFE FILED FOR SPOUSAL SUPPORT AND CHILD SUPPORT AND APL PLTF HAS NOT WORKED OUTSIDE OF THE HOME SINCE 1987. SHE IS A HIGH SCHOOL GRAD WIFE HAS RECENTLY ATTENDED AND COMPLETED A REALTOR'S SCHOOL THAT IS SPONSORED BY THE GREATER HARRISBURG AREA REALTORS. SHE HAS TAKEN THE TEST AND HAS PASSED THE TEST. SHE HAS INTERVIEWS SCHEDULED HOWEVER AS OF THIS DATE WIFE IS IN N.C. FOR AN ILLNESS W/ HER MOTHER. THE PARTIES HAVE SHARED 50/50 CUSTODY DURING THE SUMMER MONTHS AND 38/62 CUSTODY DURING THE SCHOOL YEAR PER THE TEMPORARY CUSTODY ORDER OF 5/12/04. THERE IS A CUSTODY CONFERENCE SCHEDULED FOR AUGUST 17, 2004. HUSBAND STATES Page 2 of 3 Form CM-022 Service Type M Worker ID 21005 WRIGHT V. WRIGHT PACSES Case Number: 793106382 Other Information (continued): THAT HE WANTS TO PURSUE 50/50 SHARED CUSTODY. HUSBAND IS A RESEARCH ENGINEER AND WORKS OUT OF HIS HOME. HE DOES TRAVEL FOR HIS EMPLOYMENT. Facts Agreed Upon: Facts in Dispute and Contentions with Respect to Facts in Dispute: DEF CONTENDS THAT DURING THE MARRIAGE, THE PARTIES SPENT APPROXIMATELY $20,000 IN ORDER TO PREPARE WIFE FOR EMPLOYMENT. WIFE CONTENDS THAT THERE WERE MOVES FOR HUSBAND'S EMPLOYMENT THAT CURBED HER ABILITY TO PURSUE EMPLOYMENT AND THAT SHE HAD TAKEN CARE OF THE FAMILY. Guideline Amount: $ 1, 3 21.4 2 / MONTH DRS Recommended Amount: $1.321.00 /MONTH DRS Recommended Order Effective Date: 05/05/04 Parties to be Covered by Recommended Order Amount: FOUR CHILDREN. Guideline Deviation: YES or NO Reason for Deviation: DRO RECOMMENDS AN ADDITIONAL $139/M ON THE GUIDELINE AMOUNT OF $794.64/M FOR APL, FOR A TOTAL OF $934.00/M DRO WOULD CONSIDER :LOWERING THE APL AMOUNT WHEN PLTF IS EMPLOYED (-139/M) Submitted by: R. J. SHADDAY Date Prepared: JUNE 21, 2004 Page 3 of 3 Form CM-022 Service Type M Worker 1D 21005 C`) C'J r-? 1 C :+ rr,.l GD'e C1 PATRICK M WRIGHT, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 2004-1375 CIVIL TERM ANN M. WRIGHT, IN DIVORCE Defendant/Petitioner/Respondent PACSES # 551106380 ORDER OF COURT AND NOW, this 7`h day of December, 2004, a petition has been filed against you, Ann Wright, to decrease an existing Alimony Pendente Lite Order. You are ordered to appear in person at the Domestic Relations Section, 13 North Hanover Street, Carlisle, Pennsylvania, on January 19, 2005 at 9:00 A.M. for a conference and to remain until dismissed by the Court. If you fail to appear as provided in this Order, an Order of Court may be entered against you. You are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by the Rule 1910.11. (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, George F. Hoffer, President Judge Copies mailed 12-7-04 to:< Petitioner Respondent Barbara Sumple-Sullivan, Esquire A01 Date of Order: December 7, 2004 Ii J. Shadday, Conference Officer s YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 j/2/& 6 y f S ^ d • Y? y PATRICK M. WRIGHT Plaintiff VS. ANN M. WRIGHT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-1375 CIVIL ACTION LAW IN CUSTODY Defendant ORDER OF COURT AND NOW, this 2 / day of 72004, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated August 26, 2004 is vacated and replaced with this Order. The prior Order of this Court dated May 12, 2004 shall continue in effect with the exception of Paragraphs 2A and 2B which are vacated and replaced with the provisions of this Order. 2. The parties and the children, shall engage in a course of therapeutic family counseling with Carol Flory or other professional selected by agreement. It is anticipated that the counselor will alternate meeting with the parties and the children and will make recommendations to the parties as to which family members should attend each session. The parties agree to follow the recommendations of the counselor with respect to the duration of the counseling. 3. Pending completion of the family counseling and further agreement of the parties or Order of Court, and without prejudice to either party in any subsequent custody proceedings, the parties shall continue to follow the summer custody schedule under which the parties shall alternate having custody of the children during three periods of custody each week. The first period shall run from Friday after school through Monday after school, the second period shall run from Monday after school through Wednesday after school, and the third period shall run from Wednesday after school through Friday after school. 4. The parties and their counsel shall attend a follow-up conciliation conference in the office of the conciliator, Dawn S. Sunday, on Tuesday, May 24, 2005 at 9:00 a.m. to review the custody arrangements. BY THE COUNT, evin A. Hess J. cc L. Koenigsberg, Esquire - Counsel for Father arbara Sumple-Sullivan, Esquire - Counsel for Mother LJ PATRICK M. WRIGHT Plaintiff vs. ANN M. WRIGHT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-1375 CIVIL ACTION LAW Defendant IN CUSTODY Prior Judge: Kevin A. Hess CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME Rebecca Wright Jasmine Wright Justin Wright Hannah Wright DATE OF BIRTH July 19, 1988 November 12, 1990 October 16, 1992 April 16, 1998 CURRENTLY IN CUSTODY OF Mother/Father Mother/Father Mother/Father Mother/Father 2. A conciliation conference was held on December 15, 2004, with the following individuals in attendance: The Father, Patrick M. Wright, with his counsel, Karen L. Koenigsberg, Esquire, and the Mother, Ann M. Wright, with her counsel, Barbara Sumple-Sullivan, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION PATRICK M. WRIGHT ) Docket Number 04-1375 CIVIL ) Plaintiff /Respondent VS. ) PACSES Case Number 551106380 ANN M. WRIGHT ) Defendant/ Petitioner ) Other State ID Number ORDER AND NOW, to wit on this 19TH DAY OF JANUARY, 2005 IT IS HEREBY ORDERED that the Q Complaint for Support or ® Petition to Modify or Q Other filed On DECEMBER 7, 2004 in the above captioned matter is dismissed without prejudice due to: NO SUBSTANTIAL CHANGE IN CIRCUMSTANCES OR CHANGES IN INCOME. Q The Complaint or Petition may be reinstated upon written application of the plaintiff petitioner. DRO: RJ Shadday xC: plaintiff defendant Barbara Sumple-Su_Llivan, Esquire BY THE COURT: Mary Dissinger, Esquire Kevfi A. Hess JUDGE ? ?0 OS Form OE-506 Service Type M Worker ID 21005 ? _ _: :; -_:, ,, - i ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Penr lvanla Co./City/Dist. of CUMBERLAND Date of Order/Notice 04/12/05 Case Number (See Addendum for case summary) Employer/Withholder's Federal EIN Number O Original Order/Notice O Amended Order/Notice O Terminate Ordet/Notice RE: WRIGHT, PATRICK M. Employee/Obligor's Name (Last, First, MI) MONTANA STATE UNIVERSITY PO BOX 172520jLS S5//GL ??U BOZEMAN MT 59717-2520 ,vkf 379 s ?Y '0*51-4?5 793/66 382 170-56-3174 Employee/Obligor's Social Security Number 9527101322 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, MI) See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 0.00 per month in current support $ o. oo per month in past-due support Arrears 12 weeks or greater? Oyes ® no $ 0. oo per month in current and past-due medical support $ o . oo per month for genetic test costs $ per month in other (specify) for a total of $ o. 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: $ o . oo per weekly pay period. $ o. go per biweekly pay period (every two weeks). $ o. oo per semimonthly pay period (twice a month). $ o. oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the EmployeelObligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. Date of Order. ?'tr n 1 ?Utl3 Service Type M BY THE COURT: kEVrd A. 3 7W4g Form EN-028 OMB No, 097MI54 Worker ID $IATT J ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If hecked you are required to provide a copy of this form to your?mployee. If yorr employee works in a state that is di, erent from the state that issued this order, a copy must be provi ed 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 Paydatefflateof Witliholdling. You must report the paydat&date of mthholding w lie. i sending paYrnent-.-`1-he- . 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. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 5542100066 EMPLOYEE'S/OBLIGOR'S NAME: WRIGHT, PATRICK M. EMPLOYEE'S CASE IDENTIFIER: 9527101322 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employeelobligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Antidiscrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any 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 (15 U.S.C. §1673 01; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 Service Type M If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 OMB No.: 0970-0154 Form EN-028 WorkerlD $IATT FZ-- W ) C" -' P J i r.a Barbara Sumple-Sullivan, Esquire Supreme Court 432317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 PATRICK M. WRIGHT, Plaintiff (Respondent) V. ANN M. WRIGHT, Defendant (Petitioner) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO.04-1375 IN CUSTODY PETITION FOR CONTEMPT Petitioner is Defendant, Ann M. Wright, an individual residing at 633 Devon Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Respondent is Plaintiff, Patrick M. Wright, an individual residing at 254 N. 291" Street, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The parties were married on June 7, 1986 and separated December 6, 2004. 4. Petitioner and Respondent are the natural parents of four (4) minor children. Rebecca A. Wright, born July 19, 1988; Jasmine M. Wright, born November 12, 1990; Justin P. Wright, born October 16, 1992; and Hannah A. Wright, born April 16, 1998. 5. On or about April 1, 2004, Respondent filed a divorce complaint with a claim for primary custody of the parties' minor children and visitation. 6. A Custody Conciliation was held on May 4, 2004 with Custody Conciliator, Dawn S. Sunday, Esquire and in consideration of the Custody Conciliation Report an order was entered on May 12, 2004. A true and correct copy of this order is attached hereto as Exhibit A and is incorporated herein by reference. 7. Upon agreement of the parties, the May 4, 2004 Order awarded the parties shared legal custody. Also, Mother would have primary physical custody during the remainder of the school year and Father would have alternating weekends with one overnight each week during the school year. This order also set forth that during the summer vacations from school, the parties were to share custody equally on an alternating schedule of three segments. Segment one was from Friday at 5:00 p.m. through Monday at 5:00 p.m., the second segment was from Monday at 5:00 p.m. through Wednesday at 5:00 p.m. and the third segment was from Wednesday at 5:00 p.m. through Friday at 5:00 p.m. A specific holiday schedule was also set forth in this order and an additional conciliation was scheduled for August 17, 2004 to review the order. 8. On August 17, 2004, a second Custody Conciliation was held and in consideration of the Custody Conciliation Report, an order was entered on August 26, 2004. A true and correct copy of this order is attached hereto as Exhibit B and is incorporated herein by reference. Upon agreement of the parties, the August 26, 2004 Order amended paragraphs 2A and 2B of the May 4, 2004 Order setting forth a schedule for the school year and summer vacation. This order allowed for the parties to follow the summer custody schedule arrangement of equal shared custody and ordered the parties to attend a custody evaluation performed by Dr. Arnold Shienvold, Ph.D. 10. On December 15, 2004, an order was entered December 21, 2004 which ordered the parties to follow the summer custody plan during the school year. This order also sets forth that the parties were to attend family counseling with Ms. Carol Flory to support each other. The December 15, 2004 order is the current order the parties are to be following and a true and correct copy of said order is attached hereto as Exhibit C and is incorporated herein by reference. 11. The December 15, 2004 order set a date for a follow-up conciliation conference on Tuesday, May 24, 2005 at 9:00 a.m. with Conciliator, Dawn S. Sunday. This conciliation conference is still pending. 12. Respondent has willfully failed to comply with the current Court ordered custody schedule by not returning the parties' children, Justin and Jasmine, to Petitioner during her court ordered custodial periods on numerous occasions. 11 On or about September 19 2004, after Petitioner disciplined the child, Justin, the child left and went to Respondent's home and Respondent failed to return the child despite the fact is was Petitioner's custodial time. 14. This matter was discussed at the December, 2004 conciliation and Respondent pledged his agreement to support Petitioner in her discipline and in returning the children during her custodial periods. 15. On two separate occasions on or about February 25, 2005 and February 27, 2005, during Petitioner's custodial periods, Petitioner and Respondent agreed that Respondent was to take the parties' child, Justin, to a soccer event. However, on these two separate occasions. Respondent again willfully did not return the child to Petitioner at the agreed upon time without the notice to Petitioner on these two separate occasions and kept the child, Justin, overnight. 16. On April 112005, April 14, 2005, April 18, 2005, April 19, 2005, and continuing to the present. Respondent has kept the parties' child, Jasmine, willfully and will not return her to Petitioner for Petitioner's court ordered periods of custody. 17. Respondent is making this current custodial situation very stressful for Petitioner and the children. 18. Petitioner has tried to speak directly with Respondent to advise him to follow the Court ordered arrangement, however, Respondent refuses to deal directly with Petitioner and proceeds to hang up the phone on Petitioner during their conversations. 19. Respondent continues to modify the custody order without the mutual agreement of Petitioner or notice to Petitioner. 20. Petitioner requests a hearing be scheduled: a. For immediate return of the child, Jasmine, to Petitioner's custody; b. To schedule make up time for custodial days lost by Petitioner with her children; c. To enter judgment against Respondent for Petitioner's counsel fees incurred in the preparation , filing, and hearing of this Petition which fees shall be at least Six I lundred Dollars and 00/100 ($600.00); and c. To hold Respondent in contempt and to fine and/or otherwise incarcerate Respondent for said contempt. WHEREFORE, Petitioner requests that Respondent be held in contempt of court and requests an Order be entered granting the relief requested as set forth in the proposed order. DATE: Respectfully submitted, Barbara'Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Petitioner Exhibit A MAY 1 1 2004 ?OpY( PATRICK M. WRIGHT Plaintiff vs. ANN M. WRIGHT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-1375 CIVIL ACTION LAW IN CUSTODY Defendant ORDER OF COURT AND NOW, this 1a+? day of 2004, upon ordered and directed as follows: consideration of the attached Custody Conciliation Report, itA4 U 1. The Father, Patrick M. Wright, and the Mother, Ann. M. Wright, shall have shared legal custody of Rebecca A. Wright, born July 19, 1988, Jasmine M. Wright, born November 12, 1990, Justin P. Wright, born October 16, 1992 and Hannah A. Wright, born April 16, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terns of this paragraph each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. 2. The parties shall have physical custody of the Children as follows: A. During the school year pending review of the custody arrangements at an additional custody conciliation conference, the parties shall alternate having custody of the Children on weekends from Friday after school through Monday morning before school, beginning with the Mother having custody of the Children for the weekend of Friday, May 7, 2004. The Father shall have custody during weeks following the Father's weekends, from Wednesday after school through Thursday before school, and during weeks following the Mother's weekends, from Tuesday after school through Wednesday before school. The Mother shall have custody of the Children during weekdays at all times not otherwise specified for the Father. B. During the summer school break, the parties shall alternate having custody of the Children during three periods of custody each week. The first period shall run from Friday at 5:00 pm through Monday at 5:00 pm, the second period shall run from Monday at 5:00 pm through Wednesday at 5:00 pm, and the third period shall run from Wednesday at 5:00 pm thorough Friday at 5:00 pm. C. In addition, during the summer, each party shall be entitled to have custody of the Children for three weeks, with no more than two weeks to be scheduled consecutively. The parties shall provide each other with as much notice as possible when scheduling extended periods under this provision. 3. The parties shall have custody of the Children on holidays as follows: A. THANKSGNING: The parties shall alternate having custody of the Children over the Thanksgiving holiday from after school on Wednesday through the Sunday following Thanksgiving. The Father shall have custody of the Children for Thanksgiving in even numbered years and the Mother shall have custody in odd numbered years. B. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which shall run from after school on the last day before the holiday break through the end of the first half of the Christmas school break, and Segment B, which shall include the second half of the Christmas school break. In the event that the Children's entire Christmas school break runs for an odd number of days, the extra day shall fall within Segment A. In even numbered years, the Mother shall have custody of the Children during Segment A and the Father shall have custody during Segment B. In odd numbered years, the Father shall have custody of the Children during Segment A and the Mother shall have custody during Segment B. The parties acknowledge that the Christmas holiday arrangements are designed to provide extended periods of custody to accommodate travel plans. In the event that the parent having custody of the Children during Segment A remains in the local area over the holiday, that party shall cooperate in scheduling a period of custody for the non-custodial parent on the holiday. C. EASTER: The Mother shall have custody of the Children every year over the Easter school break for up to five days, for which the Children shall not be removed from school for more than two days. D. JULY 4TH: The Father shall have custody of the Children for the July 4`h holiday every year for a period of up to five days. E. MOTHER'S DAY 1 FATHER'S DAY: The Mother shall have custody of the Children every year on Mother's Day and the Father shall have custody of the Children every year on Father's Day. F. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 4. Neither party shall schedule any period of custody (or combination of holiday, vacation or regular custody) to extend more than fourteen consecutive days, unless otherwise agreed between the parties. 5. The parties agree that in the event either party is traveling due to work or otherwise and is unavailable to provide care for the Children, that party shall offer the other party the opportunity to provide care for the Children with as much advance notice as possible. 6. The parties shall promptly share all information concerning the Children's school and activities schedule and shall notify each other in advance of all medical or other appointments scheduled for the Children. 7. The parties agree that they will defer to the Children's choices with regard to attendance at activities, but will notify the other parent in advance if that party intends to permit a Child to miss an activity. 8. The parties agree to cooperate by assisting the custodial parent whenever possible in providing transportation for the Children to activities when necessary to ensure that the Children are able to attend. 9. The parties and counsel shall attend an additional custody conciliation conference in the office of the conciliator, Dawn Sunday, on Tuesday, August 17, 2004 at 8:30 am, for the purpose of reviewing the custody arrangements prior to the beginning of the 2004-2005 school year. 10. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, AIM J. -? cc: Mary A. Etter Dissinger, Esquire - Counsel for Father Barbara Sumple-Sullivan, Esquire - Counsel for Mother TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal of sal Court at }rli?sle?, Pia. /J ? Thkn......1. .... d; Y ...•.?" `"ft `'i'"'C 1 Prothonotary Exhibit B AUG 2 5 2004 E PATRICK M. WRIGHT IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 04-1375 CIVIL ACTION LAW ANN M. WRIGHT Defendant IN CUSTODY ORDER OF COURT AND NOW, this 2& day of 2004, upon consideration of the attached Custody Conciliation Rep it is ordered and directed as follows: 1. The parties shall submit themselves, their minor Children, and any other individuals deemed necessary by the evaluator to a custody evaluation to be performed by a professional in the office of Arnold Shienvold, Ph.D. The purpose of the evaluation shall be to obtain independent professional recommendations concerning ongoing custody arrangements which will best meet the needs and interests of the Children. The parties shall sign any authorizations deemed necessary by the evaluator in order to obtain additional information pertaining to the parties or the Children. The parties agree that all costs of the evaluation shall be paid from marital assets. 2. Pending completion of the custody evaluation and further agreement of the parties or Order of Court, the prior Order of this Court dated May 12, 2004 shall continue in effect with the exception of Paragraphs 2A and 2B which are vacated and replaced with the provisions of this Order. 3. Pending completion of the custody evaluation and further agreement of the parties or Order of Court, and without prejudice to either party in any subsequent custody proceedings, the parties shall continue to follow the summer custody schedule under which the parties shall alternate having custody of the Children during three periods of custody each week. The first period shall run from Friday after school through Monday after school, the second period shall run from Monday after school through Wednesday after school, and the third period shall run from Wednesday after school through Friday after school. Neither party shall be prejudiced in any subsequent custody proceedings by his or her agreement to extend the summer custody arrangements temporarily pending completion of the custody evaluation and further resolution. 4. The parties and their counsel shall attend a follow-up conciliation conference in the office of the conciliator, Dawn S. Sunday, on Wednesday, December 15, 2004, at 8:30 a.m. to review the custody arrangements after receipt of the evaluator's recommendations. BY THE COURT, 151 &, -- Q. l _ Kevin A. Hess J, re: Karen L. Koenigsberg, Esquire -Counsel for Father Barbara Sumple-Sullivan, Esquire - Counsel for Mother a RILE COr"-Y [-Rok4 .'? w? l?e ssal si U W at Prothar iv Exhibit C PATRICK M. WRIGHT Plaintiff vs. ANN M. WRIGHT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-1375 CIVIL ACTION LAW IN CUSTODY Defendant ORDER OF COURT AND NOW, this 2) r day of 2004, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated August 26, 2004 is vacated and replaced with this Order. The prior Order of this Court dated May 12, 2004 shall continue in effect with the exception of Paragraphs 2A and 2B which are vacated and replaced with the provisions of this Order. 2. The parties and the children, shall engage in a course of therapeutic family counseling with Carol Flory or other professional selected by agreement. It is anticipated that the counselor will alternate meeting with the parties and the children and will make recommendations to the parties as to which family members should attend each session. The parties agree to follow the recommendations of the counselor with respect to the duration of the counseling. 3. Pending completion of the family counseling and further agreement of the parties or Order of Court, and without prejudice to either party in any subsequent custody proceedings, the parties shall continue to follow the summer custody schedule under which the parties shall alternate having custody of the children during three periods of custody each week. The first period shall run from Friday after school through Monday after school, the second period shall run from Monday after school through Wednesday after school, and'the third period shall run from Wednesday after school through Friday after school. 4. The parties and their counsel shall attend a follow-up conciliation conference in the office of the conciliator, Dawn S. Sunday, on Tuesday, May 24, 2005 at 9:00 a.m. to review the custody arrangements. BY THE C URT, >ls-- -d . AL K Hess J. cc: Karen L. Koenigsberg, Esquire - Counsel for Father y Barbara Sumple-Sullivan, Esquire - Counsel for Mother TRUE, F i CNt NRE RED In te.c , a ?rf `N Fr 7 . ! E1 vn3n ° fa r` ??a:2'?e and t„ seal oI sF7U1 _ant, ?I li,ls,. pa. a... PATRICK M. WRIGHT, IN THE COURT OF COMMON PLEAS Plaintiff (Respondent) CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION LAW ANN M. WRIGHT. : NO. 04-1175 Defendant (Petitioner) : IN CUSTODY VERIFICATION 1, Ann M. Wright, hereby certify that the facts set forth in the foregoing Petition for Contempt 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. §4904 relating to unsworn falsification to authorities. Date: Q,1 - Q fV ANN M. WRIGHT PATRICK M. WRIGHT, Plaintiff (Respondent) vs. ANN M. WRIGHT, Defendant (Petitioner) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 04-1375 IN CUSTODY CERTIFICATE OF SERVICE 1, BARBARA SUMPLE-SULLIVAN, ESQUIRE, do hereby certify that on this date, I served a true and correct copy of the Petition for Contempt, in the above-captioned matter upon the following individual(s), by United States first-class mail, postage prepaid, addressed as follows: Karen L. Cummings, Esquire Dissinger and Dissinger 28 North 32nd Street Camp Hill, PA 17011 DATE: . t Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Petitioner JZ J V Y ?J J y n f ? PA RICK M. WRIGHT PLAINTIFF V. AN? M. WRIGHT DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-1375 CIVIL. ACTION LAW IN CUSTODY ORDER OF COURT .4IND NOW, _ Thursday, April 28, 2005 upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, May 24, 2005__!__ at 9;00 AM for a Pre?Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this callnot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 4 children age five or older may also be present at the conference. Failure to appear at the conference may provide rounds for entry of a temporary or permanent order. court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: _!s/ _ Darvn S. Sunday EsT.`V" Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with isabilites Act of 1990. For infomtation about accessibie facilities and reasonable accommodations avail ble to disabled individuals having business before the court, please contact our office. All arrangements must?be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conf rence or hewing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE' AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FOR H BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717)249-3166 5C 17 f?? ono 7 ? -f' 90 0 I,H 9Z 2'd°d SOHZ Ai??1Gr0! iv; J ?.Hi d0 '101140-CIAlU RECEIVED MAY 2620&?r PATRICK M. WRIGHT Plaintiff VS. ANN M. WRIGHT Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-1375 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this Z ?- day of , 2005, upon consideration of the attached Custody Conciliation Report, it is o dered and directed as follows: 1. The parties shall participate in family counseling with Sally Rooney or other professional selected by agreement between the parties. The purpose of the counseling shall be to explore each party's perspective on parenting issues and conflicts and develop a plan for supportive, consistent parenting to address the specific needs of each Child. In addition, through counseling, the parties seek to obtain specific guidance on parenting techniques which are designed to address specific areas of conflict. The parties shall follow the recommendations of the counselor as to the Children's participation in the counseling. 2. Pending further agreement of the parties or Order of Court, the prior Order of this Court dated December 21, 2004 shall continue in effect as modified by this Order. 3. Following the completion of counseling, counsel for either party may contact the conciliator within six months of the date of this Order to schedule an additional custody conciliation conference, if necessary. BY THE COURT, cc: en L. Koenigsberg, Esquire - Counsel for Father 7bara Sumple-Sullivan, Esquire - Counsel for Mother '15 (t.3 f:'t i PATRICK M. WRIGHT Plaintiff VS. ANN M. WRIGHT Defendant Prior Judge: Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-1375 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: follows: NAME The pertinent information concerning the Children who are the subjects of this litigation is as DATE OF BIRTH CURRENTLY IN CUSTODY OF Rebecca Wright July 19, 1988 Mother/Father Jasmine Wright November 12, 1990 Mother/Father Justin Wright October 16, 1992 Mother/Father Hannah Wright April 16, 1998 Mother/Father 2. A conciliation conference was held on May 24, 2005, with the following individuals in attendance: The Father, Patrick M. Wright, with his counsel, Karen L. Koenigsberg, Esquire, and the Mother, Ann M. Wright, with her counsel, Barbara Sumple-Sullivan, Esquire. 3. The parties agreed to entry of an Order in the form as attached. It should be noted that the Mother's Petition for Contempt was also addressed at the conference, which had been originally scheduled as a follow-up conference in proceedings initiated by the Father's filing of a divorce complaint with a custody count. The Mother agreed not to pursue the Petition for Contempt further pending completion of the counseling required by this Order. /!Lao a S 'Pops Date Dawn S. Sunday, Esquire 0 Custody Conciliator Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 PATRICK M. WRIGHT, IN THE COURT OF COMMON PLEAS Plaintiff (Respondent) : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION LAW ANN M. WRIGHT, NO. 04 - 1375 Defendant (Petitioner) IN CUSTODY PETITION TO SET HEARING ON CONTEMPT PETITION Petitioner is Defendant, Ann M. Wright, an individual residing at 633 Devon Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Respondent is Plaintiff, Patrick M. Wright, an individual residing at 254 N. 29 h Street, Camp Hill, Cumberland County, Pennsylvania 17011. Petitioner and Respondent are the natural parents of four (4) minor children. Rebecca A. Wright, bom July 19, 1988; Jasmine M. Wright, born November 12, 1990; Justin P. Wright, born October 16, 1992; and Hannah A. Wright, born April 16, 1998. 4. The parties have equally shared legal and physical custody of their children since their separation on December 6, 2004. 5. The custodial arrangement has been set forth in the Order of Court dated May 27, 2005. 6. Since separation, and despite the existing Order, Respondent has acted in a continuous and sustained manner in contravention of the best interest of the children by alienating the children from their Mother, the Petitioner. As a result of Respondent's continued negative actions and to in an effort to secure contact with and continue Petitioner's relationship with her children, Petitioner filed a Petition for Contempt against Respondent. A copy of same is attached hereto as Exhibit A. The matter was referred to the Conciliator and a Conciliation was held on May 24, 2005. 9. At the Conciliation, the parties agreed to attempt additional counseling with a new counselor and to hold the Petition for Contempt open pending these efforts. A copy of the Order and the Conference Summary Report is attached hereto as Exhibit "B." 10. The parties did attend counseling with the newly suggested Counselor, Sally Rooney, their third counselor, and she indicated that counseling would be futile in light of the past history of counseling between the parties and the increased alienation of Petitioner from her children, which alienation had developed initially with one child and now with a second during the term of the parties' active counseling with the prior counselor, Carol Flory. Respondent has refused to counsel with Flory and another suggested counselor. 11. The middle children, Jasmine and Justin, do not follow the Court Ordered custody and Respondent takes no action to force their compliance. 12. But for one overnight, Petitioner does not and has not had custody of Justin and Jasmine, for months. The children leave Petitioner's house without notice to Petitioner and with knowledge of Respondent when they visit her and Respondent refuses to return the children or coordinate their actions between the houses. Respondent takes no action to meet the obligations of the Order. 13. It is believed and averred that, in order to assert herself back into her children's lives as a parent, Petitioner needs to force Respondent and the children to comply with the terms of the current Custody Order and Respondent's conduct must be sanctioned. 14. The Petition for Contempt needs to be heard before the Court so enforcement can occur. 15. Sending this matter again to Conciliation will be futile and the Conciliator, Dawn Sunday, Esquire has indicated that conciliation will not be productive or a result in restoration of Mother's contact. WHEREFORE, Petitioner requests that the pending Contempt Petition be scheduled for immediate hearing. DATE: July 14, 2005 Respectfully Barbar4-Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 7744445 Supreme Court I.D. 32317 Attorney fbr Petitioner 4 PATRICK M. WRIGHT, Plaintiff (Respondent) VS. ANN M. WRIGHT, Defendant (Petitioner) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 04-1375 IN CUSTODY NOTICE AND ORDER TO APPEAR Legal Proceedings have been brought against you alleging that you have willfully disobeyed an order of court of custody. If you wish to defend against the claim set forth in the following pages, you may but are not required to file in writing with the court your defenses and objections. Whether or not you file in writing with the court. you defenses or objections, you must appear in person in court on the day of 2005, at _. M., in Courtroom of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Cumberland County, Pennsylvania. IF YOU DO NOT APPEAR IN PERSON, THE COURT MAY ISSUE A WARRANT FOR YOU ARREST. If the court finds that you have willfully failed to comply with its order for custody, you may be found in contempt of court and committed to jail, fined or both. 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 FOR THE COURT, By: PATRICK M. WRIGHT, Plaintiff (Respondent) V. ANN M. WRIGHT, Defendant (Petitioner) AND NOW, this day of IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 04-1375 IN CUSTODY ORDER 2005, upon consideration of Defendant's Petition for Contempt, it is further ORDERED and DECREED that Respondent is hereby adjudicated to be in contempt of court for noncompliance of the Order of this Court dated December 21, 2004. Judgment is hereby entered in favor of'Petitioner as follows: a. The child, Jasmine, shall be immediately returned to Petitioner's custody; b. Make up time shall be scheduled for custodial days lost by Petitioner with her children; c. Judgment is entered against Respondent for Petitioner's counsel fees incurred in the preparation , filing, and hearing of this Petition which fees shall be at least Six Hundred Dollars and 00/100 ($600.00); and d. Respondent is held in contempt and to fined and/or otherwise incarcerated for said contempt. BY THE COURT: Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 PATRICK M. WRIGHT, Plaintiff (Respondent) V. ANN M. WRIGHT, Defendant (Petitioner) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO.04-1375 IN CUSTODY c> a cn - n? " N Q -n ?C7 PETITION FOR CONTEMPT 1. Petitioner is Defendant, Ann M. Wright, an individual residing at 633 Devon Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Respondent is Plaintiff, Patrick M. Wright, an individual residing at 254 N. 29'h Street, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The parties were married on June 7, 1986 and separated December 6, 2004. 4. Petitioner and Respondent are the natural parents of four (4) minor children. Rebecca A. Wright, born July 19, 1988; Jasmine M. Wright, born November 12, 1990; Justin P. Wright, born October 16, 1992; and Hannah A. Wright, born April 16, 1998. 5. On or about April 1, 2004, Respondent filed a divorce complaint with a claim for primary custody of the parties' minor children and visitation. 6. A Custody Conciliation was held on May 4, 2004 with Custody Conciliator, Dawn S. Sunday, Esquire and in consideration of the Custody Conciliation Report an order was entered on May 12, 2004. A true and correct copy of this order is attached hereto as Exhibit A and is incorporated herein by reference. Upon agreement of the parties, the May 4, 2004 Order awarded the parties shared legal custody. Also, Mother would have primary physical custody during the remainder of the school year and Father would have alternating weekends with one overnight each week during the school year. This order also set forth that during the summer vacations from school, the parties were to share custody equally on an alternating schedule of three segments. Segment one was from Friday at 5:00 p.m, through Monday at 5:00 p.m., the second segment was from Monday at 5:00 p.m. through Wednesday at 5:00 p.m. and the third segment was from Wednesday at 5:00 p.m. through Friday at 5:00 p.m. A specific holiday schedule was also set forth in this order and an additional conciliation was scheduled for August 17, 2004 to review the order. 8. On August 17, 2004, a second Custody Conciliation was held and in consideration of the Custody Conciliation Report, an order was entered on August 26, 2004. A true and correct copy of this order is attached hereto as Exhibit B and is incorporated herein by reference. Upon agreement of the parties, the August 26, 2004 Order amended paragraphs 2A and 2B of the May 4, 2004 Order setting forth a schedule for the school year and summer vacation. This order allowed for the parties to follow the summer custody schedule arrangement of equal shared custody and ordered the parties to attend a custody evaluation performed by Dr. Arnold Shienvold, Ph.D. 10. On December 15, 2004, an order was entered December 21, 2004 which ordered the parties to follow the summer custody plan during the school year. This order also sets forth that the parties were to attend family counseling with Ms. Carol Flory to support each other. The December 15, 2004 order is the current order the parties are to be following and a true and correct copy of said order is attached hereto as Exhibit C and is incorporated herein by reference.. 11. The December 15, 2004 order set a date for a :follow-up conciliation conference on Tuesday, May 24, 2005 at 9:00 a.m. with Conciliator, Dawn S. Sunday. This conciliation conference is still pending. 12. Respondent has willfully failed to comply with the current Court ordered custody schedule by not returning the parties' children, Justin and Jasmine, to Petitioner during her court ordered custodial periods on numerous occasions. 13. On or about September 19 2004, after Petitioner disciplined the child, Justin, the child left and went to Respondent's home and Respondent failed to return the child despite the fact is was Petitioner's custodial time. 14. This matter was discussed at the December, 2004 conciliation and Respondent pledged his agreement to support Petitioner in her discipline and in returning the children during her custodial periods. 15. On two separate occasions on or about February 25, 2005 and February 27, 2005, during Petitioner's custodial periods, Petitioner and Respondent agreed that Respondent was to take the parties' child, Justin, to a soccer event. However, on these two separate occasions, Respondent again willfully did not return the child to Petitioner at the agreed upon time without the notice to Petitioner on these two separate occasions and kept the child, Justin, overnight. 16. On April 13, 2005, April 14, 2005, April 18, 2005, April 19, 2005, and continuing to the present, Respondent has kept the parties' child, Jasmine, willfully and will not return her to Petitioner for Petitioner's court ordered periods of custody. 17. Respondent is malting this current custodial situation very stressful for Petitioner and the children. 18. Petitioner has tried to speak directly with Respondent to advise him to follow the Court ordered arrangement, however, Respondent refuses to deal directly with Petitioner and proceeds to hang up the phone on Petitioner during their conversations. 4 19. Respondent continues to modify the custody order without the mutual agreement of Petitioner or notice to Petitioner. 20. Petitioner requests a hearing be scheduled: a. For immediate return of the child, Jasmine, to Petitioner's custody; b. To schedule make up time for custodial days lost by Petitioner with her children; c. To enter judgment against Respondent for Petitioner's counsel fees incurred in the preparation , filing, and hearing of this Petition which fees shall be at least Six Hundred Dollars and 00/100 ($600.00); and c. To hold Respondent in contempt and to fine and/or otherwise incarcerate Respondent for said contempt. WHEREFORE, Petitioner requests that Respondent be held in contempt of court and requests an Order be entered granting the relief requested as set forth in the proposed order. DATE: KZ- z l ?/ Respectfully f Barbara Siumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Petitioner 5 MAY 1 1 2004 V PATRICK M. WRIGHT IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 04-1375 CIVIL ACTION LAW ANN M. WRIGHT Defendant IN CUSTODY ORDER OF COURT AND NOW, this ?2 )I day of , 2004, upon consideration of the attached Custody Conciliation Report, i ordered and directed as follows: 1. The Father, Patrick M. Wright, and the Mother, Ann. M. Wright, shall have shared legal custody of Rebecca A. Wright, horn July 19, 1988, Jasmine M. 'Wright, born November 12, 1990, Justin P. Wright, bom October 16, 1992 and Hannah A. Wright, born April 16, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. 2. The parties shall have physical custody of the Children as follows: A. During the school year pending review of the custody arrangements at an additional custody conciliation conference, the parties shall alternate having custody of the Children on weekends from Friday after school through Monday morning before school, beginning with the Mother having custody of the Children for the weekend of Friday, May 7, 2004. The Father shall have custody during weeks following the Father's weekends, from Wednesday after school through Thursday before school, and during weeks following the Mother's weekends, from Tuesday after school through Wednesday before school. The Mother shall have custody of the Children during weekdays at all times not otherwise specified for the Father. B. During the summer school break, the parties shall alternate having custody of the Children during three periods of custody each week. The first period shall run from Friday at 5:00 pm through Monday at 5:00 pm; the second period shall run from Monday at 5:00 pm through Wednesday at 5:00 pm, and the third period shall run from Wednesday at 5:00 pm thorough Friday at 5:00 pm. C. In addition, during the summer, each party shall be entitled to have custody of the Children for three weeks, with no more than two weeks to be scheduled consecutively. The parties shall provide each other with as much notice as possible when scheduling extended periods under this provision. 3. The parties shall have custody of the Children on holidays as follows: A. THANKSGNII3G: The parties shall alternate having custody of the Children over the Thanksgiving holiday from after school on Wednesday through the Sunday following Thanksgiving. The Father shall have custody of the Children for Thanksgiving in even numbered years and the Mother shall have custody in odd numbered years. B. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which shall run from after school on the last day before the holiday break through the end of the first half of the Christmas school break, and Segment B, which shall include the second half of the Christmas school break. In the event that the Children's entire Christmas school break runs for an odd number of days, the extra day shall fall within Segment A. In even numbered years, the Mother shall have custody of the Children during Segment A and the Father shall have custody during Segment B. In odd numbered years, the Father shall have custody of the Children during Segment A and the Mother shall have custody during Segment B. The parties acknowledge that the Christmas holiday arrangements are designed to provide extended periods of custody to accommodate travel plans. In the event that the parent having custody of the Children during Segment A remains in the local area over the holiday, that party shall cooperate in scheduling a period of custody for the non-custodial parent on the holiday. C. EASTER: The Mother shall have custody of the Children every year over the Easter school break for up to five days, for which the Children shall not be removed from school for more than two days. D. JULY 4T1': The Father shall have custody of the Children for the July 4`n holiday every year for a period of up to five days. E. MOTHER'S DAY f FATHER'S DAY: The Mother shall have custody of the Children every year on Mother's Day and the Father shall have custody of the Children every year on Father's Day. F. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 4. Neither parry shall schedule any period of custody (or combination of holiday, vacation or regular custody) to extend more than fourteen consecutive days, tmless otherwise agreed between the parties. 5. The parties agree that in the event either party is traveling due to work or otherwise and is unavailable to provide care for the Children, that party shall offer the other party the opportunity to provide care for the Children with as much advance notice as possible. 6. The parties shall promptly share all information concerning the Children's school and activities schedule and shall notify each other in advance of all medical or other appointments scheduled for the Children. 7. The parties agree that they will defer to the Children's choices with regard to attendance at activities, but will notify the other parent in advance if that party intends to permit a Child to miss an activity. 8. The parties agree to cooperate by assisting the custodial parent whenever possible in providing transportation for the Children to activities when necessary to ensure that the Children are able to attend. 9. The parties and counsel shall attend an additional custody conciliation conference in the office of the conciliator, Dawn Sunday, on Tuesday, August 17, 2004 at 8:30 am, for the purpose of reviewing the custody arrangements prior to the beginning of the 20042005 school year. 10. This Order is entered pursuant to- an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, IS] M M-. ? - - J. cc: Mary A. Etter Dissinger, Esquire - Counsel for Father Barbara Sumple-Sullivan, Esquire - Counsel for Mother TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal of sat Court d . at rlisle, Pa. rni ......1..... ........ Prot onotary AUG 2 5 2004 PATRICK M. WRIGHT IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 04-1375 CIVIL ACTION LAW ANN M. WRIGHT Defendant IN CUSTODY ORDER OF COURT AND NOW, this 2& ?' day of , 2004, upon consideration of the attached Custody Conciliation Rep rt, it is ordered and directed as follows: 1. The parties shall submit themselves, their minor Children, and any other individuals deemed necessary by the evaluator to a custody evaluation to be performed by a professional in the office of Arnold Shienvold, Ph.D. The purpose of the evaluation shall be to obtain independent professional recommendations concerning ongoing custody arrangements which will best meet the needs and interests of the Children. The parties shall sign any authorizations deemed necessary by the evaluator in order to obtain additional information pertaining to the parties or the Children. The parties agree that all costs of the evaluation shall be paid from marital assets. 2. Pending completion of the custody evaluation and further agreement of the parties or Order of Court, the prior Order of this Court dated May 12, 2004 shall continue in effect with the exception of Paragraphs 2A and 213 which are vacated and replaced with the provisions of this Order. 3. Pending completion of the custody evaluation and further agreement of the parties or Order of Court, and without prejudice to either party in any subsequent custody proceedings, the parties shall continue to follow the summer custody schedule under which the parties shall alternate having custody of the Children during three periods of custody each week. The first period shall run from Friday after school through Monday after school, the second period shall run from Monday after school through Wednesday after school, and the third period shall run from Wednesday after school through Friday after school. Neither party shall be prejudiced in any subsequent custody proceedings by his or her agreement to extend the summer custody arrangements temporarily pending completion of the custody evaluation and further resolution. 4. The parties and their counsel shall attend a follow-up conciliation conference in the office of the conciliator, Dawn S. Sunday, on Wednesday, December 15, :2004, at 8:30 a.m. to review the custody arrangements after receipt of the evaluator's recommendations. BY THE COURT, Is Q. IaZc4a- Kevin A. Hess J. cc: Karen L. Koenigsberg, Esquire - Counsel for Father Barbara Sumple-Sullivan, Esquire - Counsel for Mother f ¢! T d?tlt pfid?yt i 1?F 1 iE fld (5 5 ° ?aW tad tw Be' of ,ski att ^Wmow Oa. Fni Prothon amrv PATRICK M. WRIGHT IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 04-1375 CIVIL ACTION LAW ANN M. WRIGHT Defendant IN CUSTODY ORDER OF COURT AND NOW, this ?'Sr day of , 2004, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated August 26, 2004 is vacated and replaced with this Order. The prior Order of this Court dated May 12, 2004 shall continue in effect with the exception of Paragraphs 2A and 2B which are vacated and replaced with the provisions of this Order. 2. The parties and the children, shall engage in a course of therapeutic family counseling with Carol Flory or other professional selected by agreement. It is anticipated that the counselor will alternate meeting with the parties and the children and will make :recommendations to the parties as to which family members should attend each session. The parties agree to follow the recommendations of the counselor with respect to the duration of the counseling. 3. Pending completion of the family counseling and further agreement of the parties or Order of Court, and without prejudice to either party in any subsequent custody proceedings, the parties shall continue to follow the summer custody schedule under which the parties shall alternate having custody of the children during three periods of custody each week. The first period shall run from Friday after school through Monday after school, the second period shall run from Monday after school through Wednesday after school, and the third period shall run from Wednesday after school through Friday after school. 4. The parties and their counsel shall attend a follow-up conciliation conference in the office of the conciliator, Dawn S. Sunday, on Tuesday, May 24, 2005 at 9:00 a.m. to review the custody arrangements. BY THE C L1RT, s K in A. Hess 3. cc: Karen L. Koenigsberg, Esquire - Counsel for Father Barbara Sumple-Sullivan, Esquire - Counsel for Mother TRUE COF HOW H RD In Testiraony whereo , i hare unto sst my hand and Ale seal of said ow lisle, Pa. J Thi ...c?.s... d o D-1% 1 7 71004 PATRICK M. WRIGHT Plaintiff VS. ANN M. WRIGHT Defendant Prior Judge: Kevin A. Hess IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: CUSTODY CONCILIATION SUMMARY REPORT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-1375 CIVIL ACTION LAW IN CUSTODY 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Rebecca Wright Jasmine Wright Justin Wright Hannah Wright July 19, 1988 November 12, 1990 October 16, 1992 April 16, 1998 Mother/Father Mother/Father Mother/Father Mother/Father 2. A conciliation conference was held on December 15, 2004, with the following individuals in attendance: The Father, Patrick M. Wright, with his counsel, Karen L. Koenigsberg, Esquire, and the Mother, Ann M. Wright, with her counsel, Barbara Sumple-Sullivan, Esquire. 3. The parties agreed to entry of an Order in the form as attached. il& I?? LC,? Date Dawn S. Sunday, Esquire Custody Conciliator RECEIVED MAY 26-% PATRICK M. WRIGHT IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 04-1375 CIVIL ACTION LAW ANN M. WRIGHT Defendant IN CUSTODY ORDER OF COURT I., AND NOW, this 17 day of , 2005, upon consideration of the attached Custody Conciliation Report, rith dered and directed as follows: 1. The parties shall participate in family counseling all y Rooney or other professional selected by agreement between the parties. The purpose of the counseling shall be to explore each party's perspective on parenting issues and conflicts and develop a plan for supportive, consistent parenting to address the specific needs of each Child. In addition, through counseling, the parties seek to obtain specific guidance on parenting techniques which are designed to address specific areas of conflict. The parties shall follow the recommendations of the counselor as to the Children's participation in the counseling. 2. Pending further agreement of the parties or Order of Court, the prior Order of this Court dated December 21, 2004 shall continue in effect as modified by this Order. 3. Following the completion of counseling, counsel for either party may contact the conciliator within six months of the date of this Order to schedule an additional custody conciliation conference, if necessary. BY THE CQURT, A. Hess ' J. cc: Karen L. Koenigsberg, Esquire - Counsel for Father Barbara Sumple-Sullivan, Esquire - Counsel for Mother TRUE COPY 'ROM ?ECOR? In 1'estimony ?yhereofI I here unfio set hand and Ylte sea! of said,Courhat fmrlisle. PATRICK M. WRIGHT Plaintiff VS. ANN M. WRIGHT Defendant Prior Judge: Kevin A. Hess IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: CUSTODY CONCILIATION SUMMARY REPORT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-1375 CIVIL ACTION LAW IN CUSTODY 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Rebecca Wright Jasmine Wright Justin Wright Hannah Wright July 19, 1988 November 12, 1990 October 16, 1992 April 16, 1998 Mother/Father Mother/Father Mother/Father Mother/Father 2. A conciliation conference was held on May 24, 2005, with the following individuals in attendance: The Father, Patrick M. Wright, with his counsel, Karen L. Koenigsberg, Esquire, and the Mother, Ann M. Wright, with her counsel, Barbara Sumple-Sullivan, Esquire. 3. The parties agreed to entry of an Order in the form as attached. It should be noted that the Mother's Petition for Contempt was also addressed at the conference, which had been originally scheduled as a follow-up conference in proceedings initiated by the Father's filing of a divorce complaint with a custody count. The Mother agreed not to pursue the Petition for Contempt further pending completion of the counseling required by this Order. lha.-, a T '2005 Date C) Dawn S. Sunday, Esquire Custody Conciliator PATRICK M. WRIGHT, IN THE COURT OF COMMON PLEAS Plaintiff (Respondent) CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION LAW ANN M. WRIGHT, : NO. 04-1375 Defendant (Petitioner) : IN CUSTODY VERIFICATION I, Ann M. Wright, hereby certify that the facts set forth in the foregoing Petition to Set Hearing on Contempt Petition 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. §4904 relating to unsworn falsification to authorities. Dater ?s ANN M. WRIGHT Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 PATRICK M. WRIGHT, Plaintiff (Respondent) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. ANN M. WRIGHT, Defendant (Petitioner) CIVIL ACTION LAW NO. 04 - 1375 IN CUSTODY CERTIFICATE OF SERVICE I, BARBARA SUMPLE-SULLIVAN, ESQUIRE, do ]hereby certify that on this date, I served a true and correct copy of the Petition to Set Hearing on Contempt Petition, in the above- captioned matter upon the following individual(s), by facsimile and United States first-class mail, postage prepaid, addressed as follows: Mary A. Etter Dissinger, Esquire Dissinger and Dissinger 400 South State Road Marysville, PA 17053 DATE: July 14, 2005 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Petitioner h? ? ?? b \ h r?r ? c? -?, ?t? i c,? " : „ nor s- __,,± U r s?? ! -ii w r ' ?1 .-- - .< CT1 PATRICK M. WRIGHT IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ANN M. WRIGHT DEFENDANT 04-1375 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, July 22, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, August 16, 2005 at 9:00 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S. Sunday, Esq. IF Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 00 :Z !-!Cl S7 So PATRICK M. WRIGHT, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY : PENNSYLVANIA VS. CIVIL ACTION ANN M. WRIGHT, NO. 04-1375 Defendant IN DIVORCE PETITION TO WITHDRAW APPEARANCE AND NOW COMES, Mary A. Etter Dissinger, counsel for Patrick M. Wright, and requests permission to withdraw as counsel and in support thereof avers as follows: 1. Petitioner is Mary A. Etter Dissinger, an attorney associated with Dissinger and Dissinger. 2. Respondent is Patrick M. Wright, Plaintiff in the within action. 3. Petitioner entered her appearance on behalf of Patrick M. Wright on April 1, 2004, by filing a Consolidated Complaint in Divorce. 4. On July 19, 2005, Petitioner requested, by letter, that Respondent pay his overdue balance in full and deposit an additional retainer with her office in ten (10) days. 5. On July 28, 2005, Petitioner again reminded Respondent by letter that his overdue balance and additional retainer needed to be paid by July 29, 2005. 6. On August 11, 2005, Petitioner again sent a letter to Respondent requesting the overdue balance and additional retainer be deposited with her office by August 15, 2005. 7. Petitioner's office attempted to contact Respondent by telephone several times but was unsuccessful. 8. As of August 15, 2005, Respondent has not paid his overdue balance and additional retainer, nor called Dissinger and Dissinger. 9. The engagement letter signed by the client with Dissinger and Dissinger permits Dissinger and Dissinger to withdraw as counsel for nonpayment. WHEREFORE, Petitioner requests that a Rule be issued upon Plaintiff and Defendant herein to show cause why the relief requested should not be granted. Respectfully Submitted, DISSINGER & DISSINGER Mary A.' Etter Dissinger,° Esquire Petitioner Supreme Court ID# 27736 28 North Thirty-second Street Camp Hill, PA 17011 717-975-2840 VERIFICATION I, Mary A. Etter Dissinger, verify that the foregoing facts 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. Mary A. Etter Dissinger PATRICK M. WRIGHT, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY : PENNSYLVANIA VS. : CIVIL ACTION ANN M. WRIGHT, : NO. 04-1375 Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Mary A. Etter Dissinger, Esquire, do hereby certify that a copy of the foregoing document has been duly served upon Patrick M. Wright, Plaintiff, and Barbara Sumple-Sullivan, Esquire, attorney for Defendant, by depositing same in the United States Mail, postage prepaid, addressed as follows: Patrick M. Wright 254 N. 29th Street Camp Hill, PA 17011 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 IDate:-?zG?o? ?f.. ti- T Mary. Etter lssinger hJ CJ CJ cJ 'T7 T v 'CJ T -`?Er C7? t\? ^? , J CTl N q O { RECEIVED AUG 18 20050 PATRICK M. WRIGHT IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 04-1375 CIVIL ACTION LAW ANN M. WRIGHT Defendant IN CUSTODY ORDER OF COURT AND NOW, this aa??t day of 19 , 2005, upon consideration of the attached Custody Conciliation Repo &, it is ordered and directed as follows: 1. A Hearpg is scheduled in Court Room No. 4 of the Cumberland County Courthouse on the day of t poirrt.?Pi}? 2005, at/, 5/s o'clock . in., at which time testimony will be taken. For purposes of the hearing, the Mother, Ann M. Wii t, shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a memorandum setting forth each party's position on custody, a list of witnesses who are expected to testify at the hearing, and a summary of the anticipated testimony of each witness. These memoranda shall be filed at least ten days prior to the hearing date. 2. The parties shall provide all authorizations deemed necessary by Dr. Batista in order to enable counsel for both parties to obtain information from Dr. Batista as to the family counseling. cc: bara Sumple-Sullivan, Esquire -Counsel for Mother ary A. Etter Di`singer, Esquire - Counsel for Father a 0%, BY THE COURT, 62 .11 wv N SM SOOZ AtlG'ivOrlu'ao 3HL 90 331-4:0-013119 PATRICK M. WRIGHT Plaintiff VS. ANN M. WRIGHT Defendant Prior Judge: Kevin A. Hess CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-1375 CIVIL ACTION LAW IN CUSTODY 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Rebecca A. Wright Jasmine M. Wright Justin P. Wright Hannah A. Wright July 19, 1988 November 12, 1990 October 16, 1992 April 16, 1998 Mother/Father Mother/Father Mother/Father Mother/Father 2. A custody conciliation conference was held on August 16, 2005, with the following individuals in attendance: The Father, Patrick M. Wright, with his counsel, Mary A. Etter Dissinger, Esquire, and the Mother, Ann M. Wright, with her counsel, Barbara Sumple-Sullivan, Esquire. 3. The Mother previously filed a Petition for Contempt on April 22, 2005 which was addressed, along with the Father's Complaint for Custody at the prior conciliation conference held on May 24, 2005. The parties agreed at that conference to attempt to resolve the issues through counseling. The Mother's Petition for Contempt was therefore put on hold. As the counseling had not been successfully initiated, the Mother filed a Petition to Schedule a Hearing on Contempt Petition which was again referred to conciliation. As the Mother seeks a hearing on the contempt issue and enforcement of the current Order dated December 21, 2004, no agreement was reached at the conference and it will be necessary to schedule the hearing. 4. The Mother's position on custody is as follows: The Mother believes that the Father is alienating the Children from her and causing serious damage to her parental relationship with them. The Mother alleges that the Father is violating the existing custody Order, under which the parties have shared physical custody, by not requiring the Children to spend their periods of custody with the Mother. The Mother indicates that past repeated efforts to resolve the issues through counseling have not been effective and that the only way to ensure that the Father complies with the custody schedule is through the contempt and enforcement process. 5. The Father's position on custody is as follows: The Father indicated that he has been making an effort to address the issues raised by the Mother through family counseling and that it is also his desire for the Mother and Children, particularly Jasmine, to repair their relationship. The Father indicated that he was willing to ensure that Jasmine would attend all counseling sessions recommended by Dr. Batista who is the parties' current counselor and that he would require Jasmine to go to the Mother's residence for periods of custody if recommended by Dr. Batista. 6. The conciliator recommends an Order in the form as attached scheduling a hearing on the Mother's Petition for Contempt and requiring the parties to authorize Dr. Batista to provide information to counsel as agreed during the conference. 14W-gL /G .Zoos * ,=ee, Date -?' Dawn S. Sunday, Esquire Custody Conciliator I, RECEIVED AUG 29 209 'j PATRICK M. WRIGHT, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY PENNSYLVANIA VS. : CIVIL ACTION ANN M. WRIGHT, NO. 04-1375 Defendant : IN DIVORCE RULE TO SHOW CAUSE AND NOW, this 31' day of j!gmp"? , 2005, a rule is issued upon Patrick M. Wright, Plaintiff, and Barbara Sumple-Sullivan, Esquire, attorney for Defendant, to show cause why Dissinger and Dissinger should not be allowed to withdraw their appearance on behalf of Patrick M. Wright. Rule returnable ten (10) days after Iservice. BY THE COURT: ivy ip _ CO ti? d CJ N PATRICK M. WRIGHT, Plaintiff/Respondent VS. ANN M. WRIGHT, Defendant/Petitioner : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA : CIVIL ACTION : NO. 04-1375 : IN DIVORCE MOTION TO MAKE RULE TO SHOW CAUSE ABSOLUTE AND NOW, comes Mary A. Etter Dissinger, of Dissinger and Dissinger, and respectfully moves this Court to make absolute the Rule to Show Cause which was issued in the above-captioned matter on August 31, 2005, and in support states the following: 1. A Petition to withdraw Appearance was filed with this court on August 26, 2005. 2. On August 31, 2005, this Court issued a Rule on Plaintiff, Patrick M. Wright, and Defendant's counsel, Barbara Sumple- Sullivan, Esquire, to show cause why the withdrawal of appearance of Dissinger and Dissinger should not be allowed. 3. A letter of transmittal to Attorney Sumple-Sullivan, counsel for Defendant, and a letter of transmittal to Patrick M. Wright, Plaintiff, dated September 2, 2005, were sent on September 2, 2005. (Copies of said letter attached hereto as exhibit A). 4. No response has been filed. WHEREFORE, Mary A. Etter Dissinger and Dissinger and Dissinger requests that this Court make the Rule To Show Cause absolute and grant the Petition To withdraw Appearance. Respectfully Submitted, DISSINGER ANA DISSINGER i Dated: ( a 6 -' ' Mary A. Etter Dissinger, squire Petitioner and Attorney For Plaintiff Supreme Court ID # 27736 28 North Thirty-second Street Camp Hill, PA 17011 (717) 975-2840 VERIFICATION I, Mary A. Etter Dissinger, verify that the foregoing facts 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. Mary A. Etter Dissinger _ _L" ?J11V V?I? _ DISSIN E_ Camp Hill Offices: 717.975.2840/voice • 717.975.3924/fax Marysville Offices: 717.957.3474/voice • 717.9.1i7.2316/fax September 2, 2005 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 RE: Wright v. Wright Dear Ms. Sumple-Sullivan: Enclosed find a copy of the Rule To Show Cause regarding the withdrawal of appearance as counsel. Very truly yours, Lam" Mary A. Etter Dissinger Attorney at Law MAED:amp encl: 1 cc: Patrick Wright File 4-04-512 Attorneys at Lain 23 Nonh Thimr-Second Street • Camo Hi[L PA 17011 EXHIBIT "All I v?Jilvvlil% _ ' DISSINGER Camp Hill Offices: 717.975.2840/voice • 717.975.3924/fax Marysville Offices: 717957.3474/voice • 717957.2316/fax. September 2, 2005 Patrick M. Wright 254 N. 29`n Street Camp Hill, PA 17011 Dear Mr. Wright, Enclosed find a copy of the Rule To Show Cause regarding the withdrawal of appearance as counsel. You have ten (10) days to respond. Very truly yours, Mary A. Etter Dissinger Attorney at Law MAED:amp encl: 1 File 4-04-512 Attorneys at Lau, 28 Sotth Thitw-Second Street • Camp Hill, Pd 17011 400 South State Road • Marysville, PA 17033 PATRICK M. WRIGHT, Plaintiff/Respondent VS. ANN M. WRIGHT, Defendant/Petitioner : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA : CIVIL ACTION : NO. 04-1375 : IN DIVORCE OF SERVICE I, Mary A. Etter Dissinger, Esquire, do hereby certify that a copy of the foregoing document has been duly served upon Patrick M. Wright, and Defendant's counsel, Barbara Sumple- Sullivan, Esquire, by depositing the same in the United States mail, postage prepaid, addressed as follows: Patrick M. Wright 254 N. 2911 Street Camp Hill, PA 17011 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 Date: Mary A 7 Etter Dissinger riy S? '?-„? Y??} ? `? 't) S `??yt. „n : y ?? r ry„ .,;?? y ? ?fl .? ? PATRICK M. WRIGHT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 04 - 1375 CIVIL ANN M. WRIGHT, . Defendant IN DIVORCE THE MASTER: Today is Wednesday, August 30, 2006. This is the date set for a conference in the above-captioned divorce proceedings. Present in the hearing room are the Plaintiff, Patrick M. Wright, and his counsel Shana M. Pugh, and the Defendant, Ann M. Wright, and her counsel Barbara Sumple-Sullivan. This action was commenced by the filing of a complaint in divorce on April 1, 2004, raising grounds for divorce of irretrievable breakdown of the marriage. With respect to the grounds for divorce, the parties have signed and dated today affidavits of consent and waivers of notice of intention to request entry of divorce decree. The affidavits and waivers will be filed by the Master's office with the Prothonotary and the divorce can, therefore, conclude under Section 3301(c) of the Domestic Relations Code. The complaint in divorce also raised a claim for equitable distribution and counsel fees, costs and expenses. No claim for alimony was raised in the complaint. On May 5, 2004, the Defendant filed a claim raising alimony and alimony pendente lite. 1 The parties were married on June 7, 1986, and separated December 6, 2003. The parties are the natural parents of four children, one of whom is emancipated. The other minor children are residing with both parties on a shared custody arrangement. After considerable negotiations this morning, the parties and counsel have reached an agreement with respect to the outstanding economic issues. The agreement is going to be placed on the record in the presence of the parties. The agreement as placed on the record will be considered the substantive agreement of the parties, not subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. Later this afternoon the parties and counsel are going to return to review the transcribed agreement and make any correction of typographical errors as necessary and then affix their signatures affirming the terms of settlement as stated on the record. It is understood that the parties are bound by the agreement when they leave the hearing room today even though it is not subsequently signed. The signing of the agreement by the parties is an affirmation of the agreement as stated on the record. Upon receipt by the Master of a completed agreement the Master will prepare an order vacating his 2 appointment and counsel can then file a praecipe transmitting the record to the Court requesting a final decree in divorce. Ms. Sumple-Sullivan. MS. SUMPLE-SULLIVAN: 1. The parties own real estate located at 633 Devon Road, Camp Hill, Pennsylvania 17011. The property is currently encumbered with a mortgage due and owing to Washington Mutual Mortgage Company. The parties agree that wife shall. have sole ownership of that home. Husband agrees to execute a deed transferring ownership to wife within twenty (20) days of the date of this agreement. Wife will be solely responsible for the remaining balance on the Washington Mutual mortgage and agrees to indemnify and hold husband harmless for that obligation as well as any tax or insurance obligation in regards to the property. Wife will have three years from the date of this agreement to refinance that Washington Mutual mortgage into a loan obligation in her individual name. 2. At the time of separation the parties had a 2001 Suzuki XL 7 which will become the sole property of wife. Said vehicle is encumbered with a debt currently owing to Chase Bank. Wife will be solely responsible for that obligation and agrees to indemnify and hold husband harmless for said liability. At the time of separation the parties additionally had a 1988 Mazda 626 which had been in a vehicle accident and had $2,500.00 worth of accident proceeds paid on its behalf. The parties have agreed to share equally those accident proceeds and have gifted that to a minor child. Additionally, husband has a Scion vehicle which he has secured post-separation. Wife acknowledges that that is non-marital property and that it shall be his sole and separate property. 3. In regards to investments existing at the time of separation, the parties had money with MML Investor Services, Integrity Bank, Citizen's Bank (checking and savings), and GF Employee's Credit Union. All sums that were part of those bank accounts have been retained by husband and shall be husband's sole and separate property. Wife waives and releases any claims to any of these sums included in those financial accounts. 3 4. Additionally, at the time of separation, the parties had $8,000.00 in cash in a safety deposit box. Wife has receipt of that $8,000.00 in cash and husband releases and waives any claim to that money obtained by wife at the time of settlement. 5. Additionally, the parties have an American Funds joint cash account, Account No. 6678120. The parties have confirmed today that the balance on that account is $28,234.75. The parties agree that that amount shall be shared equally between them and distributed with one-half being paid to each party. From husband's one-half of his joint account, he agrees to tender to wife the additional sum of $4,976.00 which shall be paid to satisfy the current arrearage on an existing alimony pendente lite award in full. 6. Additionally, at the time of separation, there was a SEP IRA with Scudder Investments which shall become the sole and separate property of husband. Husband has also obtained the proceeds of a pension and retirement account with American Funds, Account No. 67112765 which is referred to as the "roll over account". Husband has withdrawn significant monies from that account from date of separation but any balance remaining in that account shall be husband's sole and separate property and except as hereinafter stated wife waives and releases any and all rights and claims to that money. 7. Husband additionally had a Roth IRA with American Funds, Account No. 6678906 which husband has liquidated. Said Roth IRA will be the sole and separate property of husband and wife hereby releases and waives any claims to that Roth IRA. 8. Wife has an American Funds Roth IRA, Account No. 66778905. Said account shall be transferred to wife and shall be the sole and separate property of wife and husband does hereby waive any claims to said American Funds Roth IRA account. 9. Husband additionally has an account with TIAA-CREF. Said account is confirmed by husband as having a balance today of $43,036.36. Said entire TIAA-CREF shall be the sole and separate property of wife and shall be transferred to wife by an appropriate QDRO or other necessary forms. In the event at the time of transfer, the TIAA-CREF account is less than $43,036.36, the necessary difference to bring that account to the stated value shall be transferred from husband's roll over account with American Funds which 4 account is Account No. 67112765, to the extent that it will be necessary to make that account as the stated value. In regards to the transfer of retirement accounts from husband to wife, it is anticipated that there will be no tax liability incurred in these transfers inasmuch as the account will transfer into a qualified roll over account for wife. In the event that wife chooses to take the funds without putting them into a tax-free account, she will be responsible for any penalty and tax liability as a result of transfer of the funds. 10. In regards to personal property, the parties have divided household property. All property in the present possession of each party shall be that party's sole property. Each party waives and releases any claims to 'the items of personal property which are already in the possession of the other party as of the date of this agreement. 11. In regards to alimony, husband agrees to pay to wife the sum of $500.00 per month upon the entry of the divorce decree. Said payment shall continue for a period of sixty (60) months. Said alimony amount shall be non-modifiable either in term or in amount. Alimony shall terminate in the event that wife will cohabit, remarry or die. The alimony payment indicated herein shall not be includable in the gross income of wife for calculation of child support or deducted from the income of husband for the purposes of calculation of child support. This $500.00 per month shall be treated as income to wife for federal tax purposes and also as a deduction for husband for federal tax purposes. This payment shall be made through the Domestic Relations Office. 12. The parties had individual accounts for their four children and the parties agree that both parents shall be designated as owners and co-trustees of those accounts and as trustees of those funds for the benefit of the children. Husband agrees to provide the necessary paperwork from those investments to document the amount that is currently in those children's accounts as well to add wife as an owner and co-trustee of the account. 13. Wife waives her claim to counsel fees in light of the division of equitable distribution that has been reached. Husband waives any claim he may have to counsel fees as part of that distribution. 5 14. In regards to the marital liabilities, the parties agree that the outstanding marital debt included on a Visa card obligation of husband to Account No. 4417128419160237 has been in fact satisfied and he agrees to indemnify and hold wife harmless from any obligation relative to that Visa and wife's name has been removed from that card. Additionally, wife had a debt on a Chase Bank One card, 4417121000909328. Wife shall be responsible for that obligation on the Chase Bank One card. Husband's name is not part of the Chase Bank One account and wife agrees to indemnify and hold husband harmless for said liability. 15. 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 have 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, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate. Each 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 interest, rights, and claims. MS. SUMPLE-SULLIVAN: Ann, you've been in the hearing room today as I dictated the terms of the settlement agreement that we reached here this morning? MS. WRIGHT: Yes. MS. SUMPLE-SULLIVAN: Have you heard those terms? MS. WRIGHT: Yes. MS. SUMPLE-SULLIVAN: Do you understand those terms? MS. WRIGHT: Yes. 6 MS. SUMPLE-SULLIVAN: Are you entering into this agreement freely and voluntarily? MS. WRIGHT: Yes. MS. SUMPLE-SULLIVAN: Do these terms accurately represent the terms of the agreement which have been reached between you and Pat? MS. WRIGHT: Yes. MS. PUGH: Patrick Wright, you've been in the hearing room while Barbara Sumple-Sullivan has enunciated the terms of your agreement? MR. WRIGHT: Yes. MS. PUGH: You understand the agreement? MR. WRIGHT: Yes. MS. PUGH: You agree to the terms of the agreement? MR. WRIGHT: I do. MS. PUGH: You are acting on your own volition? MR. WRIGHT: Yes. THE MASTER: And to both parties, you understand that when you leave this hearing room, even 7 though you do not subsequently sign the agreement, you are bound by the terms of the agreement? MR. WRIGHT: Yes. MS. WRIGHT: Yes. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations Code. WITNESS: A aha Att ney laAntiff DATE: Ann M. Wright Barbara Sumple-Sullivan Attorney for Defendant Pr- , i) OV US 15 S-3i o1? 8 = a tr1 C l PATRICK M. WRIGHT, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 04 - 1375 ANN M. WRIGHT, : CIVIL ACTION - AT LAW Defendant, : IN DIVORCE PRAECIPE TO WITHDRAW COUNTS TO THE PROTHONOTARY: Kindly withdraw Count IV - Equitable Distribution, Count V - Counsel Fees, Costs, and Expenses, and Count VI - Custody in the above-referenced divorce as the issues have been settled. Respectfully submitted, Date:/ ?= Shana M. Pugh, Esquire/ Law Offices of Patrick F. Lauer, Jr., LLC 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 200952 Tel. (717) 763-1800 ti CO :- j 4 PATRICK M. WRIGHT, Plaintiff, VS. ANN M. WRIGHT, Defendant, To the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 04 - 1375 CIVIL ACTION - AT LAW IN DIVORCE 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. (Strike out inapplicable section) 2. Date and Manner of service of the Complaint: Service by restricted delivery, certified mail # 7003-3110-0002-7192-6798, return receipt, delivered on April 5, 2004. Affidavit of Mailing was filed with the Court on April 21, 2004. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by the Plaintiff AuMist 30, 2006 ; by the Defendant Anwist 30, 9006 (b) Date of execution of the affidavit required by § 3301(d) of the Divorce Code: ; Date of filing of the Plaintiff s affidavit upon the respondent: ; Date of service of the Plaintiffs affidavit upon the respondent: 4. Related claims pending: None- All d aims raised have been settled by Agreement at Buster's Hearing on Aim l-;t lO, 2006_ Please incorporate, without mer¢ the attnched A=r m nt of th n rti g into the Divorce Decree _ 5. (Complete either paragraph (a) or (b).) (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached, ; (b) Date Plaintiffs Waiver of Notice in § 3301(c) Divorce was filed with the prothonotary: Auw ist 31, 2006 ; Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed with the prothonotary: August 31, 2006 Respectfully submitted, , Date: _(. Shana M. Pugh, Esgtlife Law Offices of Patrick F. Lauer, Jr., LLC 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 200952 Tel. (717) 763-1800 -TI - - T ? ?. i " t3 rri - - Co nom. ? N THE COURT OF COMSON PLEAS OF CLZMERLAND COUNTY, PENNSYLVANIA PATRICK M WRIGHT Plaintiff VS. ANN M. WRIGHT No. 04-1375 MOTION FOR APPOL*TT24E?7T OF MASTER Ann M. Wright (z.;6;B66;&?X (Defend a master with respect to the following claims- (X ) Divorce ( X ) ( ) Annulment ( X ) (X) Alimony ( X) (X) Alimony Pendente Lite ( X) ant), moves the court to appoint Distribution of Property Support Counsel Fees 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 igomwamoddbe) (by his attorney, Barbara Sumo e-&Il van ,Esquire). (3) The staturory ground(s) for divorce 66ec) (are)3301(a)(6) 3301(c) 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 clams: (c) The action is contested with respect to the following claims:Ecriitable Distribution Alimony APL, Suanort, Counsel Fees.-.Costs and Exoenses (5) The action (tzmnbmPwi (does not involve les issues of law or fact, __..-____ __-_ (6) The hearing is expected to take 1 &nWqhj (days). (7) Additional information, if any. A1ev - t e motion: Date: Attorney for C (Defendant) ORDER APPOINTLVG mAsTER Barbara Sumple-Sullivan, Esquire AND NOW ,19_, Esquire, is appointed master with respect to the following claims: By the Court: S N C) l ^? ,, ,y ? `? N w U ?,a. ?; G j;. ?,. :rte 6_ (?' W '> sr C . r,-? 1? , t"? :2 ay ?'+ ?s PATRICK M. WRIGHT Plaintiff vs. ANN M. IN THE COURT OF COW-ON PLEAS OF CTJI?ffiERLAND COUNTY, ?FNNSY-Z ANLA NO. 04-1375 - 19 MOTION FOR APPOINMIENT OF MASTER Ann M. Wright (Z? (Defendant), moves the court to appoint a master with respect to the following claims: (X) Divorce ( X) Distribution of Property ( ) Annulment (X) Support (X) Alimony (X) Counsel Fees (X) Alimony Pendente Lite (X) 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 reo_uested. (2) The defendant (has) 3 aoacm? appeared in the action (by his attorney, Barbara Sumple-Sullivan ,Esquire). (3) The statutory ground(s) for divorce 660? (are)3301(a)(6) 3301(c) 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. Alinr)nv_ APT._ Rnnnnrh- rnnnsol Faaa _ rncl-c anri (5) The action ( (does not involve lex issues of law or r?rr (6) The hearing expected to take (days) /(7) Additional information, if any. lev t.e motion: Date c- 2-1c Attorney for 65jac p? (Defendant) ORDER APPOINTING BLASTER Barbara Sumple-Sullivan, Esquire AND VOW ,19 d; 'e? c4e'6? Esquire, is appointed ma ter with respect to the following claims: ?A ?Z By the C> n p G Gn T ? -o m ca v S I :Z Ud 9Z ddS S',30? YJ?KKnnJJ r? AU`1Ci??ili kd ?F?130 ?`aC? C1:71(d ORDERINOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 11/21/05 Case Number (See Addendum for case summary) Employer/Withholder's Federal EIN Number PENNONI ASSOCIATES INC C/O 1 DREXEL PLZ STE 200 170-56-3174 Employee/Obligor's Social Security Number 9527101322 Employee/Obligor's Case Identifier (See Addendum for plaintiff names 3001 MILT ST associated with cases on attachment) PHILADELPHIA PA 19104-2800 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. $ 2, 255. 00 per month in current support $ 0. oo per month in past-due support Arrears 12 weeks or greater? Oyes Q no $ 0.00 per month in current and past-due medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ 2, 255.00 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: $ 520.38 per weekly pay period. $ 1, 040.77 per biweekly pay period (every two weeks). $ 1, 127. So per semimonthly pay period (twice a month). $ 2.255. oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: Date of Order: NOV 2 ? 2rj65 DRO: R.J. Shadday Service Type m 551106380 O Original Order/Notice 04-1375 CIVIL O Amended Order/Notice 793106382 Q Terminate order/Notice 379 S 2004 RE: WRIGHT, PATRICK M. Employee/Obligor's Name (Last, First, MI) ?' * 154 Kevin. Hess, Judge Form EN-028 OMB No, 0970-0154 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? UP ecntffredom you are required. to provide asopy of this form to your employee. If yo r employee works in a state that is re the sta te that issued this or er, a copy must be provided to your e mployee 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/obhgor. 3.* You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employeelobligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2316834290 EMPLOYEE'S/OBLIGOR'S NAME: WRIGHT, PATRICK M. EMPLOYEE'S CASE IDENTIFIER: 9527101322 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability; If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the 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 0 5 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe, For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Submitted By: DOMESTIC RELATIONS SECTION 131 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us Service Type M Page 2 of 2 OMB No.: 09700154 Form EN-028 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: WRIGHT, PATRICK M. PACSES Case Number 551106380 Plaintiff Name ANN M. WRIGHT Docket Attachment Amount 04-1375 CIVIL$ 934.00 Child(ren)'s Name(s): DOB PACSES Case Number 793106382 Plaintiff Name ANN M. WRIGHT Docket Attachment Amount 00379 S 2004 $ 1,321.00 Child(ren)'s Name(s): DOB REBECCA ANN WRIGHT 07/19/88 JASMINE MARIE WRIGHT 11/19/90 JUSTIN PATRICK WRIGHT 10/16/92 HANNAH ADELE WRIGHT 04/1.6/98 ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available identified above in any health insurance coverage available through the employee's/obligor's employment. through the employee's/obligor's employment. Service Type M Addendum Form EN-028 OMB NO.: 0970-0154 Worker ID $IATT r? ('} 'li -7 . .y, r__) 6'? ... i ,;.n G, "'? t t: =' ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT p.\ 1??cJ `? ?L State _Commonwealth of Pennsylvania 0Original Order/Notice Co./City/Dist. of CUMBERLAND ZC'C 1_1 O Amended Order/Notice Date of Order/Notice 12/23/05 \ O Terminate Order/Notice Case Number (See Addendum for case summary) RE: WRIGHT, PATRICK M. Employer/Withholder's Federal EIN Number Employee/Obligor's Name (Last, First, Mb PENNONI ASSOCIATES INC C/O 1 DREXEL PLZ STE 200 3001 MKT ST PHILADELPHIA PA 19104-2800 170-56-3174 Employee/Obligor's Social Security Number 9527101322 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, MI) See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 0. 00 per month in current support $ o. oo per month in past-due support Arrears 12 weeks or greater? Oyes ® no $ 0. 00 per month in current and past-due medical support $ o . oo per month for genetic test costs $ per month in other (specify) for a total of $ 0.00 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: $ o. oo per weekly pay period. $ o. go per biweekly pay period (every two weeks). $ o. oo per semimonthly pay period (twice a month). $ o . oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg;, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORTO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE 4 Date of Order: DEC .1 1 7 7 2005 Service Type M Form EN-0 OMB No.: 0970.0154 Worker lD ATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If khecked you are required to provide a copy of this form to yourgmployee. If your employee works in a state that is di erent from the state that issued this order, a copy must be provi e- d 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.*-Reportiog-the-Paydate/9ate-of-Withholding. the-payc[ate/date-of withhaldingvuh vrrwhich-amovrttwas-wit',held-from-the-empioyee`swarm 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. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2316834290 EMPLOYEE'S/OBLIGOR'S NAME: WRIGHT, PATRICK M. EMPLOYEE'S CASE IDENTIFIER: 9527101322 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the 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 (15 U.S.C. § 1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Submitted By: If you or your employee/obligor have any questions, DOMESTIC RELATIONS SECTION contact 'ArAGE ATTACHMENT UNIT 13 N. HANOVER ST by telephone at L.717) 240-6225 or P.O. BOX 320 by FAX at 7( 17) 240-6248 or CARLISLE PA 17013 by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Service Type M Worker ID $IATT ome No.. owao1 54 r-> ? C'> ? ? ? ? ri . f', '9 '? G -(ii".? ?? T inr? ? ?i ? . -ii _. '?( CI i _ ?? ORDERINOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania 1?13tC'r ' >? 2 (D O Original Order/Notice Co./City/Dist. of CUMBERLAND ! f. _C •r ( 0 Amended Order/Notice Date of Order/Notice 12/29/05 O Terminate Order/Notice Case Number (See Addendum for case summary) RE:WRIGHT, PATRICK M. Employer/Withholder's Federal EIN Number Employee/Obligor's Name (Last, First. MI) PENNONI ASSOCIATES INC C/O 1 DREXEL PLZ STE 200 170-56-3174 Employee/Obligor's Social Security Number 9527101322 Employee/Obligor's Case Identifier (See Addendum for plaintiff names 3001 MKT ST associated with cases on attachment) PHILADELPHIA PA 19104-2800 Custodial Parent's Name (Last, First, Mb 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. $ 2, 255.0o per month in current support $ o . oo per month in past-due support Arrears 12 weeks or greater? ® yes 0 no $ 0.00 per month in current and past-due medical support $ o . co per month for genetic test costs $ per month in other (specify) for a total of $ 2, 255.00 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: $ 520.38 per weekly pay period. $ 1.040.77 per biweekly pay period (every two weeks). $ 1. 127.50 per semimonthly pay period (twice a month). $ 2, 255. oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to- PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED, DO NOT SEND CASH BY MAIL. BY THE COURT: [AG "I 1) 7005 Date of Order: Form EN-028 Service Type M OM9No.:09loa154 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If thecke5 you are required to provide a copy of this form to your employee. If your employee works in a state that is diffferent rrom 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.*-Repoftmr -the-Pagdate/DateofiNithh i . ate-of-withhahting pagdatefdatemfwichholding-is-the-date ithheldfromthernrpfogee`swages- 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. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2316834290 EMPLOYEE'S/OBLIGOR'S NAME: WRIGHT, PATRICK M. EMPLOYEE'S CASE IDENTIFIER: 9527101322 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Antidiscrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any 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 (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. I I.Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 Service Type M If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 OMB No 0970.0154 Form EN-028 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendantl0bllgor: WRIGHT, PATRICK M. PACSES Case Number 551106380 Plaintiff Name ANN M. WRIGHT Docket Attachment Amount 04-1375 CIVIL$ 934.00 Child(ren)'s Name(s): DOB PACSES Case Number 793106382 Plaintiff Name ANN M. WRIGHT Docket Attachment Amount 00379 S 2004 $ 1,321.00 Child(ren)'s Name(s): DOB REBECCA ANN WRIGHT 07/19/88 JASMINE ".MARIE :WRIGHT 11/13/90 JUSTIN PATRICK WRIGHT 10/16/92 HANNAHIADELE WRIGHT 04/16/98 ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ?lf checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACKS Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available identified above in any health insurance coverage available through the employee's/obligor's employment. through the employee's/obligor's employment. Addendum Form EN-028 Service Type M Worker ID $IATT OMB No.: 09>0-Olii r? c- __ -??? _ ?-, t± i?i i`n 'q fl^. cJ '.' t . C3 S' .... ( ) ?(:, f?i ' . , 1 0 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 ANN M. WRIGHT, V. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 04-1375 PATRICK M. WRIGHT, Defendant PACSES CASE NUMBER 551106380 PETITION FOR MODIFICATION OF AN EXISTING SUPPORT ORDER Petitioner is Ann M. Wright (hereinafter referred to as "Plaintiff'), who currently resides 633 Devon Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Respondent is Patrick M. Wright (hereinafter referred to as "Defendant"), who currently resides 254 North 29"' Street, Camp Hill, Cumberland County, Pennsylvaina 17011. There is an existing Alimony Pendente Lite Order which requires Respondent to pay Nine Hundred Thirty-Four Dollars ($934.00) per month for Alimony Pendente Lite and One Hundred Thirty-Eight Dollars and 96/100 ($138.96) for mortgage contribution to Petitioner. A true and correct copy of the Order dated June 21, 2004 is attached to this petition as Exhibit "A" 4. Petitioner seeks an increase in support because: a. The parties' child, Rebecca, became emancipated in June, 2006 when she graduated from high school and she will no longer be included in the child support Order which Respondent is responsible for. WHEREFORE, Petitioner requests that the Court modify the existing Order for support. DATE: June 19, 2006 ` ad5aar'd`BGmple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Plaintiff Exhibit A • • PATRICK M. WRIGHT, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 2004-1375 CIVIL TERM ANN M. WRIGHT, IN DIVORCE Defendant/Petitioner Pacses# 551106380, ORDER OF COURT AND NOW, this 21" day of June, 2004, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $924.30 and Respondent's monthly net income/earning capacity is $5,300.85, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $934.00 per month payable monthly as follows; $934.00 for alimony pendente lite and $0.00 on arrears. First payment due within en days of this date. Arrears set at $1,868.00 as of June 21, 2004. The effective date of the order is May 5, 2004. This Order considers that the wife is livig in the marital home and is responsible for the mortgage that has escrow for taxes and insurance. The additional sum for the mortgage is $138.96 per month. DRO will reconsider the additional sum for mortgage once wife is employed and finished with the current real estate course. Husband is to make a direct payment of $934.00 to wife within ten days of this Order, unless the Wage Withholding Order is effective. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C.S.§ 3703. Farther, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the PA SCDU to: Ann M. Wright. Payments must be made by check or money order. All checks and money orders must be made payable to PA SCDU and mailed to: PA SCDU P.O. Box 69110 Harrisburg, PA 17106-9110 Payments must include the defendant's PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 PATRICK M. WRIGHT IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. ANN M. WRIGHT DOCKET NO. 04-1375 Defendant : PACSES CASE NUMBER 551106380 VERIFICATION I, Ann M. Wright, hereby certify that the facts set forth in the foregoing FOR MODIFICATION OF AN EXISTING SUPPORT ORDER 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. ANN M. WRIGHT h? 07, r `4 C r.: PATRICK M. WRIGHT, Plaintiff/Respondent vs. ANN M. WRIGHT, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 04-1375 CIVIL TERM IN DIVORCE PACSES # 551106380 ORDER OF COURT - RESCHEDULE A CONFERENCE AND NOW, this 21 st day of June, 2006, a petition has been filed against you, Patrick in. Wright, to modify an existing Alimony Pendente Lite Order. You are ordered to appear in person at the Domestic Relations Section, 13 North Hanover Street, Carlisle, Pennsylvania, on July 20, 2006 at 9:00 A.M. for a conference and to remain until dismissed by the Court. If you fail to appear as provided in this Order, an Order of Court may be entered against you. You are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by the Rule 1910.11. (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, Edgar B. Bayley, President Judge Copies mailed June 20, 2006 to: Petitioner Respondent Barbara Sumple-Sullivan, Esq. i Date of Order: June 21, 2006 J. SJ kdy,fficer YO U HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND /7 REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 cc361 f -1 f' < 7 tYf °s PATRICK M. WRIGHT, IN THE COURT OF COMMON PLEAS OF PlaintifflRespondent CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 04-1375 CIVIL TERM ANN M. WRIGHT, IN DIVORCE Defendant/Petitioner PACSES # 551106380 ORDER OF COURT AND NOW, this 21 st day of July, 2006, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $1811.46 and Respondent's monthly net income/earning capacity is $4624.73, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $699.00 per month payable as follows: $699.00 for alimony pendente lite and $0.00 on arrears. First payment due next pay date. Arrears set at $4976.68 as of July 21, 2006. The effective date of the order is July 19, 2006. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C.S.§ 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the PA SCDU to: Ann M. Wright. Payments must be made by check or money order. All checks and money orders must be made payable to PA SCDU and mailed to: PA SCDU P.O. Box 69110 Harrisburg, PA 17106-9110 Payments must include the Respondent's PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. cc360 Unreimbursed medical expenses that exceed $250.00 annually are to be paid as follows 0% by Respondent and 100% by Petitioner. The Petitioner is responsible to pay the first $250.00 annually in unreimbursed medical expenses. The Respondent is to provide medical insurance coverage. Within thirty (30) days after the entry of this Order, the Respondent shall submit to Petitioner written proof that medical insurance coverage has been obtained or that application for coverage has been made. Proof of coverage shall consist, at minimum, of. 1) the name of the health care coverage provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims should be made; 5) a description of any restrictions on usage, such as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms. This Order is based upon a modification of the child support order under PACSES #793106382. The Respondent is to obtain and maintain medical insurance for the Petitioner/Wife immediately, including prescription, dental, and vision coverage. Effective August 1, 2006, the Alimony Pendente Lite will be increased to $727.00 per month. The additional sum of $207.00 has been included for the mortgage. This Order shall become final ten days after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary for a hearing de novo before the Court. Consented: Petitioner Petitioner's Attorney Respondent Respondent's Attorney DRO: R. J. Shadday BY THE COURT, Mailed copies on: Petitioner July 21, 2006 Respondent Barbara Sumple-Sullivan, Esq. ;P?- '40 064 Kevin ess, J. ^? ?. - ;; ° ?, -„ - ? :?-± _ , __ ?.? ?, ?; n? ,;, r-,, ".'t - cn i- -? cr ORDERINOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 07/21/06 Case Number (See Addendum for case summary) Employer/Withholder's Federal EIN Number PENNONI ASSOCIATES INC C/O 1 DREXEL PLZ STE 200 3001 MKT ST PHILADELPHIA PA 19104-2800 170-56-3174 Employee/Obligor's Social Security Number 9527101322 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. $ 1, 549.00 per month in current support $ 0. oo per month in past-due support Arrears 12 weeks or greater? ®yes Q no $ 0 00 per month in current and past-due medical support $ 0 , . oo Per month for genetic test costs $ per month in other (specify) for a total of $ 1, 549.00 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: $ 357.46 per weekly pay period. $ 114.92 per biweekly pay period (every two weeks). $ 774.5o per semimonthly pay period (twice a month). $ 1.549. oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. Date of Order: JUL 2 4 2006 DRO: R.J. Shadday Service Type M BY THE COURT: Kevin Hess, Judge Form EN-028 OMB No.: 09700154 Worker ID $IATT 551106380 04-1375 CIVIL 793106382 379 S 2004 O Original Order/Notice O Amended Order/Notice O Terminate Order/Notice RE WRIGHT, PATRICK M. Employee/Obligor's Name (Last, First, MI) ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? I f heck you are required. to pr vide a opy of this form to your m loyee. If yo r employee orks in a state that is di Brent from the state that issue this or?er, a copy must be provi ?ec?to your employee even if t e box is not checked. 1. Priority: Withholding under this order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employeelobligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3.* . 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.* Employeelobligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employeelobligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2316834290 EMPLOYEE'S/OBLIGOR'S NAME: WRIGHT, PATRICK M. EMPLOYEE'S CASE IDENTIFIER: 9527101322 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Antidiscrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employeelobligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee'slobligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: * NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Submitted By: If you or your employeelobligor have any questions, DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT 13 N HANOVER ST by telephone at (717) 240-6225 or P.O. BOX 320 by FAX at (7171 240-6248 or CARLISLE PA 17013 by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Service Type M OMB No, 0970-0154 WorkerID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: WRIGHT, PATRICK M. PACSES Case Number 551106380 Plaintiff Name ANN M. WRIGHT Docket Attachment Amount 04-1375 CIVIL$ 699.00 Child(ren)'s Name(s): DOB PACSES Case Number 793106382 Plaintiff Name ANN M. WRIGHT Docket AttachmentAmount 00379 S 2004 $ 850.00 Child(ren)'s Name(s): DOB JASMINE MARIE WRIGHT 11/13/90 JUSTSIff PATRICK WATT M 1f7/$ 6/9 HANNAH ADELE WRIGHT 0446/98 ?lf checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ?if checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee'stobligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. -; ?., ? ' - ; ; ? __ In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION ANN M. WRIGHT ) Docket Number 04-1375 CIVIL Plaintiff ) Vs. ) PACSES Case Number 551106380 PATRICK M. WRIGHT ) Defendant ) Other State ID Number ORDER OF COURT You, ANN M. WRIGHT plaintiff/defendant of 633 DEVON RD, CAMP HILL, PA. 17011-1621-33 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the SEPTEMBER 19, 2006 at 9: oo,M for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 1 your pay stubs for the preceding six (6) months, 3. verification of child care expenses, and 4. proof of medical coverage which you may have, or may have available to you 5. information relating to professional licenses 6. other: Service Type M Form CM-509 Worker ID 21302 ?,.} ? ! - ? . .__ f .. - . , ' , L ?J t In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION ANN M. WRIGHT ) Docket Number 04-1375 CIVIL Plaintiff ) VS. ) PACSES Case Number 551106380 PATRICK M. WRIGHT ) Defendant ) Other State ID Number ORDER OF COURT You, PATRICK M. WRIGHT plaintiff/defendant of 254 N 29TH ST, CAMP HILL, PA. 17011-2904-54 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the SEPTEMBER 19, 2006 at 9: 00AM for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, inctuding W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. verification of child care expenses, and 4. proof of medical coverage which you may have, or may have available to you 5. information relating to professional licenses 6. other: Service Type M Form CM-509 Worker ID 21302 WRIGHT PACSES Case Number: 551106380 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either parry based upon the evidence presented without regard to which parry initiated the support action. BY THE COURT: Date of Order: r(--Ob JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE 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. V. WRIGHT CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-622s . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Service Type M Page 2 of 2 Form CM-509 Worker ID 21302 1 ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dirt. of CUMBERLAND Date of Order/Notice 08/01/06 Case Number (See Addendum for case summary) Employer/Withholder's Federal EIN Number PENNONI ASSOCIATES INC C/O 1 DREXEL PLZ STE 200 170-56-3174 Employee/Obligor's Social Security Number 9527101322 Employee/Obligor's Case Identifier (See Addendum for plaintiff names 3001 MKT ST associated with cases on attachment) PHILADELPHIA PA 19104-2800 Custodial Parent's Name (Last, First, M0 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. $ 1, 486.00 per month in current support $ o. oo per month in past-clue support Arrears 12 weeks or greater? (9) Yes Q no $ o. oo per month in current and past-due medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ 1, 486.00 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: $ 342.92 per weekly pay period. $ 685.85 per biweekly pay period (every two weeks). $ 743. oo per semimonthly pay period (twice a month). $ 1.486.00 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 OrderJNotice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: Date of Order: AUG 0 2 2006 DRO: R.J. Shadday Service Type M 551106380 04-1375 CIVIL 793106382 379 S 2004 O Original Order/Notice O Amended Order/Notice O Terminate Order/Notice PE:WRIGHT, PATRICK M. Employee/Obligor's Name (Last, First, MI) * X,4 Kevp Hess, Judge F EN 028 OMB No.: 0970.0154 orm - Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If khecke?f you are required to provide a Copy of this form to your Cmployee. If your employee orks in a state that is di erent rom the state that issued this order, a copy must be provided to your emp oyee even if t e box is not checked. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employeelobligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3.* 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.* EmployeelObligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee%obligorand you are unable to honor all support Omer/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2316834290 EMPLOYEE'S/OBLIGOR'S NAME: WRIGHT, PATRICK M. EMPLOYEES CASE IDENTIFIER: 9527101322 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Antidiscrimination: You are subject to a fine determined under State law for discharging an employeelobligor 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 (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional *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. I 1.Submitted By: 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 (7171 240-6248 or CARLISLE PA 17013 by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Service Type K OMB No.: 097"154 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: WRIGHT, PATRICK M. PACSES Case Number 551106380 Plaintiff Name ANN M. WRIGHT Docket Attachment Amount 04-1375 CIVIL$ 727.00 Child(ren)'s Name(s): DOB PACSES Case Number 793106382 Plaintiff Name ANN M. WRIGHT Docket Attachment Amount 00379 S 2004 $ 759.00 Child(ren)'s Name(s): DOB JASMINE MARIE WRIGHT 11/13/90 atISTM PATRICK WRIGHT VVIG/92 HANNAH ADELE WRIGHT 04./16/98 ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. r-? " ? 3 T {' -i Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 PATRICK M. WRIGHT, Plaintiff V. ANN M. WRIGHT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-1375 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 1, 2004. 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 unworn falsification to authorities. /?G l/ DATE: &4 o c r1o b T ?? ca g Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 PATRICK M. WRIGHT, Plaintiff V. ANN M. WRIGHT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-1375 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. 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. §4904 relating to unworn falsification to authorities. DATE: ??v 4 T ?s r Cl) 1 2=CJ co ''rn c.; Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 PATRICK M. WRIGHT, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. ANN M. WRIGHT, Defendant NO. 04-1375 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 1, 2004. 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. DATE: ' c> l Q 1 J,g ANN M. . W RIGHT /vl r? ? fp ? .. y'' ? -i t: f rn N ?? ?? za+ !? t'? C_ ? " r ? G: Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 PATRICK M. WRIGHT, Plaintiff V. ANN M. WRIGHT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-1375 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(cWF: THE DIVORCE CODE I . 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. §4904 relating to unworn falsification to authorities. DATE: O `ma'r " ANN M. WRIGHT ^ N f? C? O 7 CT -ry T . C7J _, ;,ti o 7p.7 PARTICK M. WRIGHT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 04 - 1375 CIVIL ANN M. WRIGHT, Defendant IN DIVORCE ORDER OF COURT AND NOW, this day of 2006, the parties and counsel having entered into an agreement and stipulation resolving the economic issues on August 30, 2006, the date set for a conference, the agreement and stipulation having been transcribed, and subsequently signed by the parties and counsel, the appointment of the Master is vacated and counsel can conclude the proceedings by the filing of a praecipe to transmit the record with the affidavits of consent of the parties so that a final decree in divorce can be entered. BY T COURT, G Edgar B. Bayley, P.J. cc: Shana M. Pugh Attorney for Plaintiff Barbara Sumple-Sullivan Attorney for Defendant Vno 611 :6 R I - AS 90OZ Rio . <; .,d 3Hi ?O PATRICK M. WRIGHT, Plaintiff Vs. ANN M. WRIGHT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04 - 1375 CIVIL IN DIVORCE THE MASTER: Today is Wednesday, August 30, 2006. This is the date set for a conference in the above-captioned divorce proceedings. Present in the hearing room are the Plaintiff, Patrick M. Wright, and his counsel Shana M. Pugh, and the Defendant, Ann M. Wright, and her counsel Barbara Sumple-Sullivan. This action was commenced by the filing of a complaint in divorce on April 1, 2004, raising grounds for divorce of irretrievable breakdown of the marriage. With respect to the grounds for divorce, the parties have signed and dated today affidavits of consent and waivers of notice of intention to request entry of divorce decree. The affidavits and waivers will be filed by the Master's office with the Prothonotary and the divorce can, therefore, conclude under Section 3301(c) of the Domestic Relations Code. The complaint in divorce also raised a claim for equitable distribution and counsel fees, costs and expenses. No claim for alimony was raised in the complaint. On May 5, 2004, the Defendant filed a claim raising alimony and alimony pendente lite. 1 M The parties were married on June 7, 1986, and separated December 6, 2003. The parties are the natural parents of four children, one of whom is emancipated. The other minor children are residing with both parties on a shared custody arrangement. After considerable negotiations this morning, the parties and counsel have reached an agreement with respect to the outstanding economic issues. The agreement is going to be placed on the record in the presence of the parties. The agreement as placed on the record will be considered the substantive agreement of the parties, not subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. Later this afternoon the parties and counsel are going to return to review the transcribed agreement and make any correction of typographical errors as necessary and then affix their signatures affirming the terms of settlement as stated on the record. It is understood that the parties are bound by the agreement when they leave the hearing room today even though it is not subsequently signed. The signing of the agreement by the parties is an affirmation of the agreement as stated on the record. Upon receipt by the Master of a completed agreement the Master will prepare an order vacating his 2 r appointment and counsel can then file a praecipe transmitting the record to the Court requesting a final decree in divorce. Ms. Sumple-Sullivan. MS. SUMPLE-SULLIVAN: 1. The parties own real estate located at 633 Devon Road, Camp Hill, Pennsylvania 17011. The property is currently encumbered with a mortgage due and owing to Washington Mutual Mortgage Company. The parties agree that wife shall have sole ownership of that home. Husband agrees to execute a deed transferring ownership to wife within twenty (20) days of the date of this agreement. Wife will be solely responsible for the remaining balance on the Washington Mutual mortgage and agrees to indemnify and hold husband harmless for that obligation as well as any tax or insurance obligation in regards to the property. Wife will have three years from the date of this agreement to refinance that Washington Mutual mortgage into a loan obligation in her individual name. 2. At the time of separation the parties had a 2001 Suzuki XL 7 which will become the sole property of wife. Said vehicle is encumbered with a debt currently owing to Chase Bank. Wife will be solely responsible for that obligation and agrees to indemnify and hold husband harmless for said liability. At the time of separation the parties additionally had a 1988 Mazda 626 which had been in a vehicle accident and had $2,500.00 worth of accident proceeds paid on its behalf. The parties have agreed to share equally those accident proceeds and have gifted that to a minor child. Additionally, husband has a Scion vehicle which he has secured post-separation. Wife acknowledges that that is non-marital property and that it shall be his sole and separate property. 3. In regards to investments existing at the time of separation, the parties had money with MML Investor Services, Integrity Bank, Citizen's Bank (checking and savings), and GF Employee's Credit Union. All sums that were part of those bank accounts have been retained by husband and shall be husband's sole and separate property. Wife waives and releases any claims to any of these sums included in those financial accounts. 3 4. Additionally, at the time of separation, the parties had $8,000.00 in cash in a safety deposit box. Wife has receipt of that $8,000.00 in cash and husband releases and waives any claim to that money obtained by wife at the time of settlement. 5. Additionally, the parties have an American Funds joint cash account, Account No. 6678120. The parties have confirmed today that the balance on that account is $28,234.75. The parties agree that that amount shall be shared equally between them and distributed with one-half being paid to each party. From husband's one-half of his joint account, he agrees to tender to wife the additional sum of $4,976.00 which shall be paid to satisfy the current arrearage on an existing alimony pendente lite award in full. 6. Additionally, at the time of separation, there was a SEP IRA with Scudder Investments which shall become the sole and separate property of husband. Husband has also obtained the proceeds of a pension and retirement account with American Funds, Account No. 67112765 which is referred to as the "roll over account". Husband has withdrawn significant monies from that account from date of separation but any balance remaining in that account shall be husband's sole and separate property and except as hereinafter stated wife waives and releases any and all rights and claims to that money. 7. Husband additionally had a Roth IRA with American Funds, Account No. 6678906 which husband has liquidated. Said Roth IRA will be the sole and separate property of husband and wife hereby releases and waives any claims to that Roth IRA. 8. Wife has an American Funds Roth IRA, Account No. 66778905. Said account shall be transferred to wife and shall be the sole and separate property of wife and husband does hereby waive any claims to said American Funds Roth IRA account. 9. Husband additionally has an account with TIAA-CREF. Said account is confirmed by husband as having a balance today of $43,036.36. Said entire TIAA-CREF shall be the sole and separate property of wife and shall be transferred to wife by an appropriate QDRO or other necessary forms. In the event at the time of transfer, the TIAA-CREF account is less than $43,036.36, the necessary difference to bring that account to the stated value shall be transferred from husband's roll over account with American Funds which 4 account is Account No. 67112765, to the extent that it will be necessary to make that account as the stated value. In regards to the transfer of retirement accounts from husband to wife, it is anticipated that there will be no tax liability incurred in these transfers inasmuch as the account will transfer into a qualified roll over account for wife. In the event that wife chooses to take the funds without putting them into a tax-free account, she will be responsible for any penalty and tax liability as a result of transfer of the funds. 10. In regards to personal property, the parties have divided household property. All property in the present possession of each party shall be that party's sole property. Each party waives and releases any claims to the items of personal property which are already in the possession of the other party as of the date of this agreement. 11. In regards to alimony, husband agrees to pay to wife the sum of $500.00 per month upon the entry of the divorce decree. Said payment shall continue for a period of sixty (60) months. Said alimony amount shall be non-modifiable either in term or in amount. Alimony shall terminate in the event that wife will cohabit, remarry or die. The alimony payment indicated herein shall not be includable in the gross income of wife for calculation of child support or deducted from the income of husband for the purposes of calculation of child support. This $500.00 per month shall be treated as income to wife for federal tax purposes and also as a deduction for husband for federal tax purposes. This payment shall be made through the Domestic Relations Office. 12. The parties had individual accounts for their four children and the parties agree that both parents shall be designated as owners and co-trustees of those accounts and as trustees of those funds for the benefit of the children. Husband agrees to provide the necessary paperwork from those investments to document the amount that is currently in those children's accounts as well to add wife as an owner and co-trustee of the account. 13. Wife waives her claim to counsel fees in light of the division of equitable distribution that has been reached. Husband waives any claim he may have to counsel fees as part of that distribution. 5 14. In regards to the marital liabilities, the parties agree that the outstanding marital debt included on a Visa card obligation of husband to Account No. 4417128419160237 has been in fact satisfied and he agrees to indemnify and hold wife harmless from any obligation relative to that Visa and wife's name has been removed from that card. Additionally, wife had a debt on a Chase Bank One card, 4417121000909328. Wife shall be responsible for that obligation on the Chase Bank One card. Husband's name is not part of the Chase Bank One account and wife agrees to indemnify and hold husband harmless for said liability. administrator or executor in the other's estate. Each 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 interest, rights, and claims. 15. 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 have 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, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as MS. SUMPLE-SULLIVAN: Ann, you've been in the hearing room today as I dictated the terms of the settlement agreement that we reached here this morning? MS. WRIGHT: Yes. MS. SUMPLE-SULLIVAN: terms? MS. WRIGHT: Yes. MS. SUMPLE-SULLIVAN: terms? MS. WRIGHT: Yes. Have you heard those Do you understand those 6 MS. SUMPLE-SULLIVAN: Are you entering into this agreement freely and voluntarily? MS. WRIGHT: Yes. MS. SUMPLE-SULLIVAN: Do these terms accurately represent the terms of the agreement which have been reached between you and Pat? MS. WRIGHT: Yes. MS. PUGH: Patrick Wright, you've been in the hearing room while Barbara Sumple-Sullivan has enunciated the terms of your agreement? MR. WRIGHT: Yes. MS. PUGH: You understand the agreement? MR. WRIGHT: Yes. MS. PUGH: You agree to the terms of the agreement? MR. WRIGHT: I do. MS. PUGH: You are acting on your own volition? MR. WRIGHT: Yes. THE MASTER: And to both parties, you understand that when you leave this hearing room, even 7 r though you do not subsequently sign the agreement, you are bound by the terms of the agreement? MR. WRIGHT: Yes. MS. WRIGHT: Yes. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations Code. WITNESS: DATE: P-30 -0.6 - CJ- n Ann M. Wright Attorney for Defendant 8 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. PATRICK M. WRIGHT,r` Plaintifif VERSUS ANN M WRIGHT, Defendant NO. 2004-1375 DECREE IN DIVORCE AND NOW, DECREED THAT AND Patrick M. Wright Ann M. Wright , 70&(.0 , IT IS ORDERED AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; PROTHONOTARY The attached Agreement dated August 30, 2006, is incorporated, without mercer. herein- ev,?V, 1? . }It - 01 Y. y PATRICK M. WRIGHT, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 04-1375 CIVIL TERM ANN M. WRIGHT, IN DIVORCE Defendant/Petitioner PACSES # 551106380 ORDER OF COURT AND NOW to wit, this 5th day of January 2007, it is hereby Ordered that should the Respondent fall in arrears, payments are to be increased by $1.50 per moth for payment on said arrears. BY THE COURT: K n A. Hess, J. DRO: R.J. Shadday Form OE-001 Type: M Worker: 21005 '??; X002 11s..Zu;'2007 15:01 FAX 0 APR 0 2 ZW7 AR-19-OT 13:20 FROM-Cumberland County Dwastic Relations +IT172408248 W T-988 P-004/005 F-949 Date of Application.: -7 a1a Q' I Request for Support Record Search Name: tO 1 [ ?. it yPvip (First) - ' 1'70?1 Address: sScSy-- ?4 ' S7, r, .0 uti1 ?a- Social Security Number: / 7 0- J-c - 310 51 _ _ A.O.S.: Domestic Relations Case Nurn her if Known: x 3 8 4 Party Requesting Information: rt (Print Name o Name) 8QQ- 333-coXoZII'? iC rxer? /3 r1 A-?.. '- . (Tclephwc Number) drm) C,66%Vom K, O W6 aBg y3a?o??rg (Pax Number) (Sigrature) ? I A Twenty Doilar (520,00) Fee is Due per Social Security Number Mako check or money order payable to: WiSILien Search CUMBERLAND COUNTY DOMES?'IO RELATIONS >tNl!'X'XAL REQUEST Has no Record in Domestic Relations as of I (Date) Support Arrears as of End of Month Prior-to Date of pplication: S Monthly Total Support Obligation: $ '7 7, 0 O The Amount shown above is reflected in the Domestic Relations Section Office of Cumberland County. Pennsylvania. Member -* 95a 71013aa Domestic Relations Case Number: -Lu•W e5 -* "/?' E5,3 $ O Signed: ,cam- 0 7 (Lien Scarch Coordinator) (Dart) BIUNC-DOWN REQUEST Support Arrears: S As Of: ' (Date) Signed: (Lien Coordinator) (Date) *** Lien Satisfrsfaction Receipt Available Upon Request*** CC720 No. 04- 137.5 C?v? I v e st w _ic7_} ,'. a n • Djz! PATRICK M. WRIGHT, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 04-1375 CIVIL TERM ANN M. WRIGHT, IN DIVORCE Defendant/Petitioner PACSES Case No.: 551106380 ORDER OF COURT AND NOW to wit, this 13th day of April 2007, it is hereby Ordered that, the Alimony Pendente Lite order in this case be terminated without prejudice effective October 1, 2006, due to the parties' Marital Settlement Agreement of August 30, 2006 and Alimony being awarded to Ann M. Wright. There is a credit balance of $197.54 on the Alimony Pendente Lite account.. Payments that were paid on the Alimony Pendente Lite account from October 1, 2006 to date, a total of $4,362.05, are directed to the Alimony account. The Alimony account will be given credit in the amount of $4,362.05. BY THE COURT: , * X, A-, - I ?, - evin A. Hess, J. DRO: R.J. Shadday xc: Petitioner Respondent Shana M. Pugh, Esq. Barbar Sumple-Sullivan, Esq. Form OE-001 Service Type: M Worker: 21005 ??a ?-- r_'.' _„? ' ? 4 ..?? ' ,? ? Z = _ -.? "{ ?? ' w. ? ?, 1 ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 04/13/07 Case Number (See Addendum for case summary) E mployer/With holder's Federal EIN Number PENNONI ASSOCIATES INC C/O 1 DREXEL PLZ STE 200 3001 MKT ST PHILADELPHIA PA 19104-2800 551106380 04-1375 CIVIL 793106382 379 S 2004 RE: WRIGHT, PATRICK M. O Original Order/Notice O Amended Order/Notice O Terminate Order/Notice Employee/Obligor's Name (Last, First, MI) 170-56-3174 Employee/Obligor's Social Security Number 9527101322 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. $ 1, 259 . 00 per month in current support $ o . oo per month in past-due support Arrears 12 weeks or greater? Oyes ® no $ 0.00 per month in current and past-due medical support $ 0 . 00 per month for genetic test costs $ 0.00 per month in other (specify) for a total of $ 1, 259.00 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: $ 289.74 per weekly pay period. $ 579.48 per biweekly pay period (every two weeks). $ 629.50 per semimonthly pay period (twice a month). $ 1. 259. 00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: Date of Order: APR 16 2037 DRO: R.J. Shadday Service Type M Kevin A. ss, Judge Form EN-028 Rev. " OMB No.: 0970-0154 Worker ID $IATT 1+ ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If hecked you are required to provide a copy of this form to your employee. If your employee works in a state that is die rent 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 thePaydate/Date-of Withholding: You-mustTeportthgpayd pagmerrt. The paydate/date of withholdingis thedateon which-amountwas withheleffromthe 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. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2316834290 EMPLOYEE'S/OBLIGOR'S NAME: WRIGHT, PATRICK M. EMPLOYEE'S CASE IDENTIFIER: 9527101322 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the 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 (15 U.S.C. §1673 01; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Submitted By: If you or your employee/obligor have any questions, DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 Service Type M by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 OMB No, 0970-0154 Form EN-028 Rev. 1 Worker ID $ IATT 41 ADDENDUM Summary of Cases on Attachment Defendant/Obligor: WRIGHT, PATRICK M. PACSES Case Number 551106380 Plaintiff Name ANN M. WRIGHT Docket Attachment Amount 04-1375 CIVIL$ 500.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): PACSES Case Number 793106382 Plaintiff Name ANN M. WRIGHT Docket Attachment Amount 00379 S 2004 $ 759.00 Child(ren)'s Name(s): DOB JASMINE MARIE WRIGHT 11/13/90 JUSTIN PATRICK WRIGHT 10/16/92 HANNAH ADELE WRIGHT 04/16/98 ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 DOB Child(ren)'s Name(s): ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available identified above in any health insurance coverage available through the employee's/obligor's employment. through the employee's/obligor's employment. Addendum Form EN-028 Rev. 1 Service Type M Worker ID $IATT OMB No.: 0970-0154 C"? `..' ?? C? c:-a _ -? ? 3 ? _. J -^? ? _?? i'i' 4, . Qi a-y _7' .,. ? r.., - ?r, ?.?_l -1 .. ';? ._ ? .?. Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 PATRICK M. WRIGHT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 04-1375 ANN M. WRIGHT, CIVIL ACTION -LAW Defendant IN DIVORCE QUALIFIED DOMESTIC RELATIONS ORDER AND NOW, this .20 - day of 42 2007, it appears to the Court as follows: 1. The parties hereto were husband and wife, and they seek this Order in conjunction with a final decree of dissolution of marriage dated October 11, 2006 in that action pending in this Court at the above number. 2. Patrick M. Wright, 170-56-3174, hereinafter referred to as "Participant" was employed by Montana State University, is a participant in the Teachers Insurance and Annuity Association-College Retirement Equities Fund, hereinafter "TIAA-CREF" and has the following annuities: TIAA Retirement Annuity (RA) Contract No. TIAA-D256278-5 CREF Retirement Annuity (RA) Certificate No. CREF-V256278-2 Patrick M. Wright's current and last known mailing address is 254 N. 29h Street, Camp Hill, Pennsylvania 17011 and daytime phone number is (717) 730-9155. 3. The Alternate Payee is Ann M. Wright whose current and last known mailing address is 633 Devon Road, Camp Hill, Pennsylvania 17011. The Alternate Payee's Social Security Number is 248-49-6262 and daytime phone number is (717) 649-0751. 4. To accommodate the marital property distribution between the parties, IT IS ORDERED, ADJUDICATED AND DECREED AS FOLLOWS: A. That TIAA-CREF annuities previously referenced are marital property; B. Upon finalization of this Order and pursuant to the terms of said annuities, the entire value as of the distribution date of the Participant's TIAA-CREF annuity accumulations shall be awarded as the Alternate Payee's sole and exclusive property to be applied to TIAA-CREF annuities. The values actually transferred will reflect interim investment experience until the transfer is recorded by TIAA-CREF. The 2 TIAA Traditional accumulations will increase over time, whereas the TIAA Real Estate and CREF accumulations may increase or decrease, reflecting the performance of the underlying investments. C. Conditions of division of annuity contracts: i. All ownership and interest in the balance of the accumulations not transferred in all annuities issued to the Participant by TIAA-CREF will belong to the Participant. ii. All ownership rights in the newly issued annuities will belong to the Alternate Payee. iii. The beneficiary designation of the Alternate Payee's annuities will be her estate, unless a beneficiary designation is submitted pursuant to the provisions of the contracts, and accepted by TIAA-CREF. The Alternate Payee must review the contracts as issuance for accuracy and inform TIAA-CREF of any change of address. iv. The Alternate Payee's Annuities will be issued with the same investment allocation as the Participant's applied pro rata. The Alternate Payee may change the investment allocation once his or her annuities are issued in accordance with the contributing employer's plan. D. Termination of Alternate Payee's status as beneficiary of record for all annuity contracts or individual life insurance funded through TIAA-CREF on the life of the Participant. CHOOSE 1 or 2 1. Termination- As of the date of TIAA-CREF' S receipt of the QDRO, all TIAA-CREF benefits otherwise payable to Alternate Payee as beneficiary are payable to the estate of the Participant. This paragraph does not apply in light of the fact the entire TIAA-CREF benefit of Participant is hereby transferred to the Alternate Payee. 2. Reaffirmation- This paragraph does not apply in light of the fact the entire TIAA-CREF benefit of Participant is hereby transferred to the Alternate Payee. a. Alternate Payee is to remain beneficiary as per existing designations. b. The Alternate Payee is to be primary beneficiary for the following percentage of the retirement contract death benefits and for life insurance proceeds as described: TIAA Contracts CREF Certificates 4 Individual Life Insurance % The participant retains the right to change these designations. E. TIAA Traditional Retirement Annuities (RAs) do not allow single-sum withdrawals or transfers to alternate carriers. For other TIAA-CREF annuities, the Alternate Payee's rights to receive single-sum withdrawals and/or transfer all or a part of the accumulation to an alternate carrier may be limited in accordance with the contributing employer's plan. F. The parties are directed to submit to TIAA-CREF all documents and releases (if required by TIAA-CREF) to finalize this Order within 30 days of the request for same. 5. This Order: A. does not require any plan to provide any type of form of benefit, or any options not otherwise provided under the plan; B. does not require TIAA-CREF to provide increased benefits; C. does not require the payment of benefits to Alternate Payee which are required to be paid to another Alternate Payee under 5 another Order previously determined to be a Qualified Domestic Relations Order; and D. If any portion of this Order is rendered invalid, the balance of the Order will remain fully enforceable. 6. This Court reserves jurisdiction to issue further orders as needed to execute this Order. BY THE COURT PARTICIPANT ALTERNATE PAYEEh Date y- r e - o7 Date 7(C/0? Date I- I , 6 b 6 lirl 'INVAIASNN3d 81 :6 WV 03 M LOOZ 32HI JO 301,-'? r-GDJ r- 793106382 379 S 2004 ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT ti51106380 State w Ith of Pennsylvania 04-1375 CIVIL Co./City/Dist. of UMBERLAND Date of Order/Not ce 06/25/07 Case Number (Se Addendum for case summary) EIN Number PENNONI SOCIATES INC C/O 1 DRE EL PLZ STE 200 3001 MKT IT PHILADELP I. See A ORDER INFORMAT from CUMBER amounts from the a issued by your State. PA 19104-2800 170-56-3174 Employee/Obligor's Social Security Number 9527101322 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, MI) for dependent names and birth dates associated with cases on attachment. This is an Order/Notice to Withhold Income for Support based upon an order for support County, Commonwealth of Pennsylvania. By law, you are required to deduct these amed employee's/obligor's income until further notice even if the Order/Notice is not $ 773.00 pe month in current support $ 0. 00 pe month in past-due support Arrears 12 weeks or greater? Oyes ® no $ 0.00 pe month in current and past-due medical support $ 0.00 pe month for genetic test costs $ 0.00 pe month in other (specify) fora total of $ 773.00 per month to be forwarded to payee below. You do not have to v the ordered support p $ 178.38 per $ 356.77 per $ 386 .50 per $ 773 .00 per REMITTANCE INFOR You must begin withh Order/Notice. Send p deduct a fee to defray allowable amount. TI aggregate disposable 1 needed (See #9 on pa if required by Pennsy Pennsylvania State C4 for instructions. Make Remittance Send check to: y your pay cycle to be in compliance with the support order. If your pay cycle does not match yment cycle, use the following to determine how much to withhold: weekly pay period. biweekly pay period (every two weeks). semimonthly pay period (twice a month). monthly pay period. tTION: ling no later than the first pay period occurring ten 00) working days after the date of this ment within seven (7) working days of the paydate/date of withholding. You are entitled to e cost of withholding. Refer to the laws governing the work state of your employee for the total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's ekly earnings. For the purpose of the limitation on withholding, the following information is 2). knia law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call -ctions and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 to: PA SCDU SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYME TS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/ bligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH Y MAIL. BY THE COURT: Date of Order: JUN' 2 f1 6 i 2007 Kevin A. ss, Judge DRO: R.J. Shad 4y Form EN-028 Rev. 1 Service Type M OMB NO.: 097MI 54 Worker I D $ IATT O Original Order/Notice O Amended Order/Notice O Terminate Order/Notice RE: WRIGHT, PATRICK M. Employee/Obligor's Name (Last, First, MI) 0 ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If hecke?? you are required to provide a copy of this form to your m loyee. if your employee works in a state that is di erent trorh the state that issued this order, a copy must be provideedpto your employee even if the box is not checked. 1. Priority: Withholding, under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effe before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employeelobligor's income in a single payment to each agency requesting ithholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. You must comply with the law of the state of the employee's/ob igor's principal place of employment with respect to the time periods within which you must implement the withholding order and fo and the support payments. 4.* Employee/Obligor wit this employee/obligor and the law of the state of emp possible. (See #9 below) 5. Termination Notificati Please provide the inform THE EMPLOYEE EMPLOYEE'S/OI EMPLOYEE'S C/ LAST KNOWN I NEW EMPLOYE 6. Lump Sum Payments: Y severance pay. If you have Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against ou are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow oyee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. n requested and return a copy of this Order/Notice to the Agency identified below. LIGOR NO LONGER WORKS FOR: 2316834290 ;OR'S NAME: WRIGHT PATRICK M. IDENTIFIER: 9527101322 DATE OF SEPARATION: NE ADDRESS: NAME/ADDRESS: may be required to report and withhold from lump sum payments such as bonuses, commissions, or questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to wi hhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employe bligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in a other State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You re subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking isciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is mployed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You ay not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act 0 5 U.S.C. §16 3 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to th aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Fed ral, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed un er the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed and r the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your aget 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 t is order with respect to these items. 11.Submitted By: If you or your employeelobligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 Service Type M OMB No.: 0970.0154 Form EN-028 Rev. 1 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: WRIGHT, PATRICK M. PACSES Case Number 5 1106380 Plaintiff Name ANN M. WRIGHT Docket Attac ment Amount 04-1375 CIVIL$ 500.00 Child(ren)'s Name(s): DOB ? If checked, you are req ired to enroll the child(ren) identified above in any health insurance coverage available through the employee's/ob igor's employment. PACSES Case Number Plaintiff Name Docket Attachm nt Amou S o.oo Child(ren)'s Name(s): DOB i i i P ? If checked, you are requir d to enroll the child(ren) identified above in any heap insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachmen Amou $ 0.00 Child(ren)'s Name(s): I DOB I If checked, you are required to enroll the child(ren) identified above in any health i surance coverage available through the employee's/obligor' employment. Service Type M PACSES Case Number 793106382 Plaintiff Name ANN M. WRIGHT Docket Attachment Amount 00379 S 2004 $ 273.00 Child(ren)'s Name(s): DOB HANNAH ADELE WRIGHT 04/16/98 ?if checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACKS Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. Addendum OMB No.: 0970-0154 Form EN-028 Rev. 1 Worker I D $ IATT ? ? ? ' C.= -- -n ,_f ; r 3 '.? W ORDERMOTICE TO WITHHOLD INCOME FOR SUPPORT State: Commonwealth of Pennsylvania i C to Co./City/Dist. of. CUMBERLAND 370 SD Date of Order/Notice: 02/04/11 Case Number (See A e?for case summary) Employer/Withholder's Federal EIN Number PENNONI ASSOCIATES INC C/O 1 DREXEL PLZ STE 200 3001 MKT ST PHILADELPHIA PA 19104-2800 RE: WRIGHT, PATRICK M. L,4- /375 cl&tll O Original Order/Notice (j Amended Order/Notice O Terminate Order/Notice O One-Time Lump Sum/Notice Employee/Obligor's Name (Last, First, MI) 170-56-3174 Employee/Obligors Social ecun um er 9527101322 Employee/Obligor's ase enti er (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, MI) See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 0.00 per month in current child support $ 0.00 per month in past-due child support $ 0.00 per month in current medical support $ 0.00 per month in past-due medical support $ 500.00 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) $ one-time lump sum payment for a total of $ 500.00 per month to be forwarded to payee below. O yps 2g) nVi r_- .-..j Mco r-n rT' Z? c3 rn c: , -4 C:) {tom -p C:) -11 Acn =-- C"") Z C tU O T' ? I vn - 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: $ 115.37 per weekly pay period. $ 250.00 per semimonthly pay period (twice a month) $ 230.77 per biweekly pay period (every two weeks) $ 500.00 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 DEFE AME AND THE PACSES MEMBER /D (shown above as the Employee/Obligor's Case I Mier) OR CIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: Service Type M ?dw?ird E, C ?, OMB No.: 0970-0154 Arrears 12 weeks or greater? Form EN-028 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS F-1 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. 2316834290 THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER: Q THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: Q EMPLOYEE'S/OBLIGOR'S NAME: WRIGHT, PATRICK M. EMPLOYEE'S CASE IDENTIFIER: 9527101322 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: LAST KNOWN PHONE NUMBER: FINAL PAYMENT AMOUNT: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (CCPA) (15 U.S.C. 1673 (b)); or 2) the amounts allowed by the State or Tribe of the employee's/obligor's principal place of employment. Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes, Social Security taxes, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is supporting another family and 60% of the disposable income if the obligor is riot supporting another family. However, that 50% limit is increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State, you may deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section. Arrears greater than 12 weeks: If the Order Information does not indicate whether the arrears are greater than 12 weeks, then the employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of the CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amounts paid for health care premiums in determining disposable income and applying appropriate withholding limits. 10. Additional info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Send Termination Notice and other correspondence to: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 Service Type M If you or your employee/obligor have any questions contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us OMB No.: 0970-0154 Page 2 of 2 Form EN-028 Worker ID $IATT 1 46 ADDENDUM Summary of Cases on Attachment Defendant/Obligor: WRIGHT, PATRICK M. PACSES Case Number 551106380 Plaintiff Name ANN M. WRIGHT Docket Attachment Amount 04-1375 CIVIL $ 500.00 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 PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Addendum Form EN-028 Service Type M OMB No.: 0970-0154 Worker ID $IATT LIEN SATISFACTION Name: Patrick Wright Member Number: M#9527101322 Judgment Lien Satisfied as of: 10/4/11 Amount Paid: $ Closed Signed: 2h,, / (Lien Coordinator) Pacses# 551106380 No. 04-1375 Civil DR# N MM 3W - -<> o ° r <? -p a CD--n m c) c-, 5;= W ° M JAN092012 (Date) CC722