Loading...
HomeMy WebLinkAbout08-6122ANGELA SAMUELSEN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. pg- 1#1aa CIVIL TERM RONALD SAMUELSEN, Defendant, IN DIVORCE NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 SAIDIS, FLOWER & LINDSAY i A -Y?I I SAIDIS, GSM 26 West High Street Carlisle, PA Ma atas, Esquire Attorney d. 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Fax (717) 243-6486 Counsel for Plaintiff ANGELA SAMUELSEN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 09-4/2Z CIVIL TERM RONALD SAMUELSEN, Defendant, IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Angela Samuelsen, an adult individual currently residing at 2812 Columbia Avenue, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant is Ronald Samuelsen an adult individual currently residing at 2812 Columbia Avenue, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 22, 1996 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. Neither the Plaintiff nor the Defendant is a member of the United States Armed Forces or its Allies. FLOWER & LINDSAY 26 West High Street Carlisle, PA 7. The Plaintiff has been advised that counseling is available and that she has the right to request that the court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with §3301 (c) or (d) of the Pennsylvania Divorce Code. Respectfully submitted, SAIDIS, FLOWER & LINDSAY Ma tas, Es wire Attorney .84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Dated: f C)/ 3 r Counsel for Plaintiff FLOWER ? LINDSAY 26 West High Street Carlisle, PA ANGELA SAMUELSEN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. CIVIL TERM RONALD SAMUELSEN, ; Defendant, IN DIVORCE VERIFICATION I 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 unswom falsifications to authorities. Y1 0 1 n ? I skaAluk.? ANGE SAMUELSEN Date: 0 ? W 00 .p J rRl R 5 tV ANGELA SAMUELSEN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 2008-6122 CIVIL TERM RONALD SAMUELSEN, : Defendant, IN DIVORCE AFFIDAVIT OF SERVICE I, Marylou Matas, Esquire, being duly sworn according to law, hereby deposes and says that on October 14, 2008 she served a true and correct copy of a Complaint in Divorce upon Ronald Samuelsen, my mailing those documents to the his address at P.O. Box 19, Camp Hill, PA 17011 by Certified U.S. Mail, Restricted Delivery, Return Receipt Requested, as evidenced by the attached U.S. Postal Service Form 3811, Domestic Return Receipt, the latter of which is signed by the recipient, Ronald Samuelsen. Respectfully submitted, SAIDIS, FLOWER & LIlVDSAY nrrow?rseruw 26 West High Street Carlisle, PA Dated: / ©/Z l /6E) SAIDIS, FLOWER & LINDSAY Mary o I atas, Esquire ID No. 8 19 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff r ANGELA SAMUELSEN, Plaintiff PENNSYLVANIA V. RONALD SAMUELSEN, Defendant, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, CIVIL ACTION - LAW NO. 2008-6122 CIVIL TERM IN DIVORCE A. re ? Agent X B. Received by ( 'Hied Name) C. 137te /f,71very D. Is delivery address different from item 1? [.9 Yes If YES, enter delivery address below: Ot No ?L (?? L ©I ( 3 Service Type Certified Mail D Express Mail ? Registered ? Retum Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number 7008 0150 0001 6188 4049 (Transfer from service Iabeo PS Form 3811, February 2004 Domestic Retum Receipt 102595-02-M-1540 ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Ariicle Addressed to: Tn.. MDX t9 cl G.3 J IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, COMMONWEALTH OF PENNSYLVANIA ANGELA SAMUELSEN, Civil Action----Divorce PLAINTIFF No. 2008-6122 Movant in Counterclaim VS. RONALD SAMUELSEN. DEFENDANT Respondent in Counterclaim, DEFENDANT'S ANSWER TO PLAINTIFF'S DIVORCE COMPLAINT UNDER 3301 (C) OR 3301 (D) AND COUNTERCLAIM 1. ADMITTED. 2. ADMITTED. 3. ADMITTED. 4. ADMITTED. 5. ADMITTED. 6. ADMITTED. 7. ADMITTED. 8. ADMITTED. 9. ADMITTED. COUNTERCLAIM IN DIVORCE UNDER DIVORCE CODE NOW COMES, the above named Petitioner, Ronald Samuelsen, in response to the aforementioned Divorce Complaint and plaintiff in this Counterclaim by and through his counsel Gregory S. Hazlett, Esquire and alleges and avers the following as hereinafter cited in separately numbered Counts and paragraphs in support of her Counterclaim. COUNT I ALIMONY PENDENTE LITE 1. Defendant, ie ( Movant in this Counterclaim) Ronald Samuelsen, lacks sufficient income and resources to provide for his reasonable needs during the pendancy of this action. 2. Defendant, anticipates consuming a significant portion of his disposable income to defend against and litigate issues relative to her involvement and participation in the above referenced action initiated by the plaintiff Wife due to the existence of Marital Property of which defendant is entitled to a portion. 3. Defendant, alleges and avers that he is and will be in need of financial support during the pendancy of this action to defray the costs and expenses associated with his involvement in this action. 4. Defendant, ie (Plaintiff in this Counterclaim) alleges and avers that in the absence of financial support from plaintiff, in the divorce complaint (defendant to this Counterclaim) he will be prejudiced in the exercise and advancement of his legal rights relative to adjudicating the issues of the distribution of marital property. 5. Plaintiff, has sufficient income derived from her full time employment which substantially exceeds that of defendant's. 6. Defendant, has a physical malady that requires ongoing and extensive medical care, resulting in large continuous medical expenses to treat his chronic condition. 6. Defendant, states that subsequent to the entry of the divorce decree he will encounter financial constraints derived from the costs and expenses associated with maintaining a lifestyle which he had then been accustomed to during his marriage to plaintiff. 7. Defendant, states that subsequent to the entry of the divorce decree he will encounter financial constraints derived from the costs and expenses associated with maintaining a lifestyle which he had then been accustomed to during his marriage to plaintiff as well as ongoing medical expenses to treat his medical condition. WHEREFORE, Defendant, prays this Honorable Court grant her Alimony Pendente Lite, Costs & Expenses during the pendancy of this action and attorney's fees relative to all stages of this action and Alimony subsequent to the entry of the Divorce COUNT II ALIMONY 8. The averments of paragraph 1 through 7 of Count I, are incorporated herein by direct references thereto as if set forth verbatim. 9. The Petitioner is in need of ongoing financial support in the absence of a contribution from plaintiff, to maintain a lifestyle of which he has become accustomed during the marriage. 10. The defendant, movant has and will continue to incur an inordinate level of medical expenses to treat a medical disease that he was diagnosed with and that requires extensive and ongoing medical attention, and treatment which includes but not by way of limitation, medicinal, therapeutic, and potentially surgical intervention. 11. The petitioner, husband is in need of financial support to maintain the lifestyle for which he had become accustomed to during the marriage. WHEREFORE, Defendant, prays this Honorable Court grant him permanent Alimony subsequent to the entry of the Divorce COUNT III REQUEST FOR COUNSEL FEES AND EXPENSES UNDER 3104, 3323, 3502(A) AND 3702 OF THE DIVORCE CODE. 12. The averments of paragraph 1 through 11 of Count I, are incorporated herein by direct references thereto as if set forth verbatim. 13. Ronald Samuelsen has retained counsel Gregory S. Hazlett, Esquire to represent his legal interests relative to Paintiff's Divorce Complaint. 14. It is anticipated that the defendant Ronald Samuelsen, will incur legal costs to both defend against and advance his legal claims during the pendancy of the divorce action. 15. Defendant, petitioner, is unable to afford the ongoing legal expenses associated with the underlying action as they may become due. WHEREFORE, defendant reserves the right to request of the Court as it may become necessary the award of costs, expenses and legal fees and that the Court Order the plaintiff compensate defendant for all costs, expenses and legal fees associated with the litigation of any and all issues that are related directly and/or indirectly to counsel's representation of defendant throughout and to the conclusion of the aforesaid divorce action. COUNT IV PETITION FOR EQUITABLE DIVISION, DISTRIBUTION AND ASSIGNMENT OF MARITAL PROPERTY 16. The averments of paragraph 1 through 15 of Count I, II, and III are incorporated herein by direct references thereto as if set forth verbatim. 17. The parties are the owners of various items of personal property and real property which has been acquired during marriage which qualifies as marital property as defined in Section 401 of the 1980 Divorce Code. 18. Such marital property includes personal property as well as other intangible property thought to exist, including but not by way of limitation bank accounts, pensions and other property which constitutes marital property. 19. Such property is subject to equitable division, distribution and assignment by this Court which is fundamental to the rights and entitlement of the defendant to such property to the extent it qualifies as marital property and was either acquired or accumulated in value during the marriage. WHEREFORE, Defendant, ie (Plaintiff in this Counterclaim) prays that this Honorable Court: (a) equitably divide, distribute and assign all of the parties' marital property: (b) enjoin Defendant from transferring or encumbering any marital property during the pendency of this action. RESPECTFULLY SUBMITTED, GWi?ryS. H, Esquire est Main Street Mechanicsburg, PA. 17055 (717) 790-5500 Atty. I.D. 69528 VERIFICATION I verify that upon personal knowledge or information and belief that the statements made in this Answer and Counterclaim are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa C.S. & 4904, relating to unworn falsification to authorities. Dated: )- /10 1W I Ronald Samuelsen, et' inner c'?'v- Ra --- n• I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA ANGELA SAMUELSEN , PLAINTIFF Movant in Counterclaim VS. RONALD SAMUELSEN. DEFENDANT Respondent in Counterclaim, Civil Action----Divorce No. 2008-6122 MOTION TO SCHEDULE HEARING ON ALIMONY PENDENTE LITE AND NOW, comes the Defendant Movant, Ronald Samuelsen by and through his counsel Gregory S. Hazlett, Esquire and requests of the Court that they schedule a hearing on his Petition for Alimony Pendente Lite and avers the following in support thereof. 1. The defendant, movant relative to this action is Ronald Samuelsen, who resides at 2311 North Front Street, Apt. 1122, Harrisburg, PA. 17110. 2. The plaintiff is Angela Samuelsen, who currently resides at 2812 Columbia Avenue, Camp Hill, PA. 17011. 3. Plaintiff, Angela Samuelsen, filed a divorce action in this matter on October 13`h, 2008. 4. Defendant, movant Ronald Samuelsen, filed an Answer and Counterclaim requesting an award of Alimony Pendente Lite. 5. Defendant, movant requests of the Court that it schedule a hearing regarding the request for Alimony Pendente Lite. WHEREFORE, defendant, movant prays the Honorable Court, schedule a hearing on his request for the award of Alimony Pendente Lite. RESPECTFULLY SUBMITTED, 7,West Main Street uire 'Mechanicsburg, PA. 17055 (717) 790-5500 Atty. I.D. 69528 ^ ? N ;7 T, ?,a T ?i -,. ANGELA J. SAMUELSEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent: CUMBERLAND COUNTY, PENNSYLVANIA V. : DOMESTIC RELATIONS SECTION RONALD M. SAMUELSEN, : PACSES NO. 626110666 Defendant/Petitioner: DOCKET NO. 2008-6122 CIVIL RONALD M. SAMUELSEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : DOMESTIC RELATIONS SECTION ANGELA J. SAMUELSEN, PACSES NO. 368110468 Defendant DOCKET NO. 1013 Support 2008 ANGELA J. SAMUELSEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : DOMESTIC RELATIONS SECTION RONALD M. SAMUELSEN, PACSES NO. 126110560 Defendant DOCKET NO. 1129 Support 2008 ORDER OF COURT AND NOW, this 2nd day of March, 2009, this matter having been scheduled for a hearing de novo before the Support Master on the Husband's claim for alimony pendente lite, the Husband's Complaint for spousal support and the Wife's Complaint for child support, and the parties having reached an agreement on all outstanding issues, upon recommendation of the Master it is ordered and decreed as follows: 1. Effective February 11, 2009 the Wife shall pay to the Pennsylvania State Collection and Disbursement Unit as alimony pendente lite the sum of $450.00 per month. 2. The Husband's Complaint for spousal support is withdrawn and dismissed. 3. The Wife's Complaint for child support is withdrawn and dismissed. By the Court, Edward E. Guido, J. Cc: Angela J. Samuelsen Ronald M. Samuelsen Gregory S. Hazlett, Esquire For the Plaintiff Marylou Matas, Esquire For the Defendant DRO ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 08-6122 CIVIL State Commonwealth of Penncyl ania (Z)Original Order/Notice Co./City/Dist. of CUMBERLAND OAmended Order/Notice Date of Order/Notice 03/02/09 OTerminate Order/Notice Case Number (See Addendum for case summary) (Done-Time Lump Sum/Notice RE:SAMUELSEN, ANGELA J. E mployer/With holder's Federal EIN Number Employee/Obligor's Name (Last, First, MI) 203-62-9582 SELECT EMPLOYMENT SERVICES INC Employee/Obligor's Social Security Number 4714 GETTYSBURG RD 0418102052 MECHANICSBURG PA 17055-4325 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. $ o. oo per month in current child support $ o. oo per month in past-due child support Arrears 12 weeks or greater? Oyjes ® no $ o. oo per month in current medical support $ 0. oo per month in past-due medical support $ 450.00 per month in current spousal support $ o . oo per month in past-due spousal support $ 0. oo per month for genetic test costs $ o. o o per month in other (specify) $ one-time lump sum payment for a total of $ 450.00 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 dynes not match the ordered support payment cycle, use the following to determine how much to withhold: $ 103.85 per weekly pay period. $ 225.00 per semimonthly pay (period $-----LO 7.69 er biweekl (twice a month) p y pay period (every two weeks) $ 450.00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten 00) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please'call Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-87?-676-9580 for instructions. PA FIPS CODE 42 000 00 Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME CSES MEMBER to (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECU UMBER ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: Edward E. Guido, Judge DRO: R. J. Shadday Form EN-028 Rev. 4 Service Type M OMB No.: 0970-0154 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS If hecke i you are required to provide gopy of this form to your mployee. If your employee orks in a state that is di erent rom the state that issued this o er, a copy must be provi3edpto your employee even if tie box is not checked. 1. Priority: Withholding under this Oder/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.* 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 Oder/Notice to Withhold Income for Support against this employeelobligor and you are unable to honor all support you mu follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices l to the limits, possible. (See #9 below) greatest extent 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no loner working for you. Please provide the information requested and return a copy of this Oder/Notice to the Agency identified below. 251s122450 THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : 0 THE EMPLOYEE/OBLIGOR NO LONGER !WORKS FOR: 0 EMPLOYEE'S/OBLIGOR'S NAME: SAMUELSEN, ANGELA J. EMPLOYEE'S CASE IDENTIFIER. 0418102052 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 Oder/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 (CCPA) (15 U.S.C. 1673 (b)); or 2) the amounts allowed by the State or Tribe of the employee's/obligor's (principal place of employment. Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes, Social Security taxes, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is supporting another family and 60% of the disposable income if the obligor is not supporting another family.However, that 50% limit is increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State, you may deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section.'. Arrears greater than 12 weeks : If the Order Information does not indicate whether the arrears are greater than 12 weeks, then the employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more tho1'n the amounts allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more han the lesser of the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under s ion 303(d) of the CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amount 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 low of the state that issued this order with respect to these items. 11. Send Termination Notice and other correspondence to: If you or your employee/obligor have any qu ions, DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT 73 ? N. HANOVER ST 1 BOX by telephone at (717) 240-6225 or P.O. 320 CARLISLE PA 17013 by FAX at (71 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Rev. 4 Service Type M OMB No.: 0970-0154 Worker I D $ IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: SAMMELSEN, ANGELA J. PACKS Case Number Plaintiff Name Service Type M Addendum OMB No.: 0970-0154 Foom EN-028 Rev. 4 Worker ID $IATT I CID c? 4`x`1 r ,,s ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dirt. of CUMBERLAND Date of Order/Notice 10/22/09 Case Number (See Addendum for case summary) Employer/Withholder's Federal EIN Number HOLY SPIRIT HOSPITAL C/O PAYROLL DEPT 503 N 21ST ST CAMP HILL PA 17011-2204 203-62-9582 Employee/Obligor's Social Security Number 0418102052 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) RE:SAMUELSEN, ANGELA J. Employee/Obligor's Name (Last, First, MI) Custodial Parent's Name (Last, First, MI) See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 450.00 $ 0.00 $ 0.00 $ 0.00 per month in current child support per month in past-due child support per month in current medical support per month in past-due medical support per month in current spousal support per month in past-due spousal support per month for genetic test costs per month in other (specify) Arrears 12 weeks or greater? 0 yes ®no one-time lump sum payment for a total of $ 450.00 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: $ 103.85 per weekly pay period. $ 225.00 per semimonthly pay period (twice a month) $ 207.69 per biweekly pay period (every two weeks) $ 450.00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). Pennsylvania law (23 PA C.S. § 4374(b)) requires remittance by an electronic payment method if an employer is ordered to withhold income from more than one employee and employs 15 or more persons, or if an employer has a history of two or more returned checks due to nonsufficient funds. Please call the Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. PA FIPS CODE 42 000 00 Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NANAA"MPf PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SEC Y NUM IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. . BY THE COURT: DRO: R.J. Shadday Service Type M OMB No.: 0970-0154 08-6122 CIVIL OOriginal Order/Notice OAmended Order/Notice OTerminate Order/Notice OOne-Time Lump Sum/Notice E. Gado, Judge Form EN-028 Rev.5 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS E] If hecked you are required to provide a copy of this form to your ?mployee. If yoyr employee works in a state that is di Brent rrom the state that issued this order, a copy must be provi edd to your employee even if the box is not checked 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld arnounts 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. 2315127470 THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : E3 THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: E3 EMPLOYEE'S/OBLIGOR'S NAME: SAMUELSEN, ANGELA J. EMPLOYEE'S CASE IDENTIFIER: 0418102052 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: LAST KNOWN PHONE NUMBER: FINAL PAYMENT AMOUNT- NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (CCPA) (15 U.S.C. 1673 (b)); or 2) the amounts allowed by the State or Tribe of the employee's/obligor's principal place of employment. Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes, Social Security taxes, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is supporting another family and 60% of the disposable income if the obligor is not supporting another family.However, that 50% limit is increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State, you may deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section. Arrears greater than 12 weeks : If the Order Information does not indicate whether the arrears are greater than 12 weeks, then the employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of the CCPA (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 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT 13 N. HANOVER ST by telephone at (717) 240-6225 or P.O. BOX 320 by FAX at (717) 240-6248 or CARLISLE PA 17013 by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Rev.5 Service Type M OMB No.: 0970-0154 Worker ID $IATT ADDENDUM Summarv of Cases on Attachment Defendant/Obligor: SAMUELSEN, ANGELA J. PACSES Case Number 626110666 PACSES Case Number Plaintiff Name Plaintiff Name RONALD M. SAMUELSEN Docket Attachment Amount Docket Attachment Amount 08-6122 CIVIL$ 450.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB PACSES Case Number PACSES Case Number Plaintiff Name Plaintiff Name Docket Attachment Amount Docket Attachment Amount $ 0.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB PACSES Case Number PACSES Case Number Plaintiff Name Plaintiff Name Docket Attachment Amount Docket Attachment Amount $ 0.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB Addendum Form EN-028 Rev.5 Service Type M OMB No.: 0970-0154 Worker ID $IATT OF t?it+ ?c Ma?yw 2N9 OCT 23 M 3+ Of ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania CO./City/Dist. of CUMBERLAND Date of Order/Notice 10/23/09 Case Number (See Addendum for case summary) Employer/Withholder's Federal EIN Number SELECT EMPLOYMENT SERVICES INC 4714 GETTYSBURG RD MECHANICSBURG PA 17055-4325 203-62-9582 Employee/Obligor's Social Security Number 0418102052 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 child support $ . 0.00 per month in past-due child support Arrears 12 weeks or greater? Dyes ®no $ 0. oo per month in current medical support $ o . oo per month in past-due medical support $ 0.00 per month in current spousal support $ o . oo per month in past-due spousal support $ 0.00 per month for genetic test costs $ 0.00 per month in other (specify) $ one-time lump sum payment for a total of $ 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. 00 per weekly pay period. $ 0.00 per semimonthly pay period o . 00 per biweekly pay period (every two weeks) REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). Pennsylvania law (23 PA C.S. § 4374(b)) requires remittance by an electronic payment method if an employer is ordered to withhold income from more than one employee and employs 15 or more persons, or if an employer has a history of two or more returned checks due to nonsufficient funds. Please call the Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. PA FIPS CODE 42 000 00 Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NMWff IN RDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: Edward E. DRO: R.J. Shadday Service Type M OMB No.: 0970-0154 08-6122 CIVIL OOriginal Order/Notice OAmended Order/Notice XOTerminate Order/Notice QOne-Time Lump Sum/Notice RE:SAMUELSEN, ANGELA J. Employee/Obligor's Name (Last, First, MI) (twice a month) o . 00 per monthly pay period. Form EN-028 Rev.5 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS Ei If hecked you are required to provide a copy of this form to your @mployee. If yo r employee works in a state that is diferent 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. 2518122450 THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : 0 THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 0 EMPLOYEE'S/OBLIGOR'S NAME: SAMUELSEN, ANGELA J. EMPLOYEE'S CASE IDENTIFIER: 0418102052 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: LAST KNOWN PHONE NUMBER: NEW EMPLOYER'S NAME/ADDRE FINAL PAYMENT AMOUNT. 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (CCPA) (15 U.S.C. 1673 (b)); or 2) the amounts allowed by the State or Tribe of the employee's/obligor's principal place of employment. Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes, Social Security taxes, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is supporting another family and 60% of the disposable income if the obligor is not supporting another family.However, that 50% limit is increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State, you may deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section. Arrears greater than 12 weeks : If the Order Information does not indicate whether the arrears are greater than 12 weeks, then the employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of the CCPA 0 5 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amounts paid for health care premiums in determining disposable income and applying appropriate withholding limits. 10. Additional info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Send Termination Notice and other correspondence to: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Rev.5 Service Type M OMB No.: 0970-0154 Worker I D $ IATT 4 ADDENDUM Summary of Cases on Attachment Defendant/Obligor: SAMUELSEN, ANGELA J. PACSES Case Number 626110666 PACSES Case Number Plaintiff Name Plaintiff Name RONALD M. SAMUELSEN Docket Attachment Amount Docket Attachment Amount 08-6122 CIVIL$ 0.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB 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): PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB DOB DOB Addendum Form EN-028 Rev.5 Service Type M OMB No.: 0970-0154 Worker ID $ IATT R FFICC OF THE PROWUNOTAR'Y 1009 OCT 26 PM 2: 32 CUMI I LL-1; 41D C"O,? ;INSYLVANA vs Case No. ~/ ~~~~" ~ ~ ' ?~ ~~ .~ --~ Statement of Intention to Proceed ~m c~j ~-t-'~' ~ ~ -t ~--~ ~"' z To the Court: ~ ~ ~ ~ .., ~ _~``EY_~_~ ~•_lY~~~ SC1 Y~ intends to proceed with the above captioned~er. t~j ~~1 ', Print Name~Q ~ ~~ (i ~ 1' ; ~ ;, / ~-~~~ - "~~, ~; ~(" L Sign Name ii ~ ~ w - - '^ Date: _ ~ Attorney for / rn ~~1Q (~ rn ,(Q j ~ (~. ~~ - -- Explanatory Comment The Supreme Court of Pennsylvania has promulgated new Rule of Civil Procedure 230,2 governing the termination of inactive casea and amended Rule of Judicial Administration 1901. Two aspects of the recommendation merit comment- L Rule of crvtl Proredur~e New Rule of Civil Procedure 230.2 has been promulgated to govern the termination of inactive cases within the scope of the Pennsylvania Rules of Civil Procedure. The termination of these cases for inactivit}~ was previously governed by -Rule of Judicial Administration 1901 and local rules promulgated pursuant to it. New Rule :230.2 is tailored to the needs of civil actions. ]t provides a complete procedure and a uniform statewide practice. preempting local rules. This rule ~+~as promulgated in response to the decision of the Supreme Court in Shop v. Eagle, 551 Pa. 3'0.7]0 A.2d 1104 (1998) in which the court held that "prejudice to the defendant as a result of delay in prosecution is required before a case may be dismissed pursuant to local rules implementing Rule of Judicial Administration 1901."~ Ruie of Judicial Administration 1901(b) has been amended to accommodate the new rule of civil procedwe. "the genera] policed of the prompt disposition of matters set forth in subdivision (a) of that rule continues to be applicable. I1 Inactive Cases The purposr: of Rule 230.2 is to eliminate inactive cases from the judicial system. The process is initiated by the court. After ;diving notice of intent to terminate an action for inactivity, The course of the procedure is with the parties. IC thr parties cio not wish to pursue the case, tliey will take no action and "the Prothonotary shall enter an order as of course terminating the matter with prejudice for failure to prosecute." If a party wishes to pursue the matter, he or she will file a notu:e of intention to proceed and the action shall continue. a. Wiaere [he action has bee~~ terminated If the action. is terminated when a party believes that. it should not have been terminated, that party may proceed under Ru1e230(d) for relief from the order of termination. An example of such an occurrence might be the termination of a viable action when the aggrieved party did not receive the notice of intent to terminate and thus did not timely file the notice of intention to proceed. "Chc timing of the filing of the petition to reinstate the action is important. If the petition is filed within thirty ~:1ays of the entry of the order of termination on the docket, subdivision (d)(2) provides that the court must grant the petition and reinstate the action. If the petition is filed later than the thirty-day period, subdivision (d)(3) requires that the plaintiff must make a showing to the court that the petition was promptly filed and that there is a reasonable explanation or legitimate excuse both for the failure to file the notice of intention to proceed prior to the entry of the order of termination on the docket and for the failure to file the petition within the thirty-day period under subdivision (d)(2}. E3. Yl~hei-e the action has not been terminated An action which has not been terminated but which continues upon the filing of a notice of intention to proceed may have been the. subject of inordinate delay. In such an instance, the aggrieved party may pursue the remed~~ of a common law non pros which exits independently of termination under Rule 230.2. ANGELA SAMUELSEN, Plaintiff V. RONALD SAMUELSEN, Defendant IN THE COURT OF COMMON PLEAS COUNTY OF CUMBERLAND, PENNSYLVANIA NO. 2008- 6122 CIVIL ACTION - LAW IN DIVORCE CI'L TAM r rrl m 1. -< co >, ? . COUNTER-AFFIDAVIT UNDER §3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree (b) I oppose the entry of a divorce decree because (check (i), (ii) or both) (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) 7X- I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-affidavit are true and correct. I Law Offices of Saidis Sullivan & Rogers 26 West High Street Carlisle, PA 17013 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Dated: _,/tv I Ronald Samuel on NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you should not file this counter-affidavit. r ANGELA SAMUELSEN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA V. CIVIL ACTION—LAW NO. 2008-6122 CIVIL TERM RONALD SAMUELSEN, Defendant, IN DIVORCE INVENTORY AND APPRAISEMENT OF DEFENDANT, Angela Samuelsen, Plaintiff, files this inventory of all property owned or possessed by either parry at the time this action was commenced and all property transferred within the preceding three years. Angela Samuelsen, Plaintiff, verifies that the statements made in this inventory are true and correct. Defendant further understands that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. �� (� l�l..i U(Lh J 11 Angela amuelsen,Plaintiff ASSETS OF PARTIES Angela Samuelsen, Plaintiff, marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. (g ) 1. Real property (X ) 2. Vehicles ( ) 3. Stocks, bonds, securities and options ( ) 4. Certificates of deposit (x ) 5. Checking accounts, cash (x ) 6. Savings accounts,money markets and savings certificates ( ) 7. Contents of safe deposit boxes ( ) 8. Trusts (g ) 9. Life insurance policies(indicate face value, cash surrender value and Law Offices of current beneficiaries) S11C11S ( ) 10. Annuities ( ) 11. Gifts Sullivan ( ) 12. Inheritances C e ( ) 13. Patents, copyrights, invention,royalties -W2 ZZ & Rogers ( ) 14. Personal property outside the home XM a 9i: _< 26 West High Street i (list including of ownership, andc�� C 15. Business a owners, ng p Carlisle,PA 17013 ( - °rte C ( ) �b �. � -.-' officer/director positions held by a party with company) ( ) 16. Employment termination benefits-severance pay, worker's 'si compensation claim/award z g ( ) 17. Profit sharing plan ( ) 18. Pension plan(indicate employee contribution and date plan vests) `1 �" ' 19. Retirement plans,Individual Retirement Accounts 20. Disability payments 21. Litigation claims(matured and unmatured) 22. MilitaryN.A. benefits 23. Education benefits (X) 24. Debts due, including loans,mortgages held 25. Household furnishings and personalty(include as a total category,and attach itemized list of distribution of such assets is in dispute) 26. Other LIABILITIES OF PARTIES Defendant,marks on the list below those items applicable to the case at bar and itemizes the liabilities on the following pages. SECURED (X) 1. Mortgages 2. Judgments 3. Liens 4. Other secured liabilities UNSECURED (X) 5. Credit Card balances 6. Purchases 7. Loan purchases 8. Notes payable 9. Other unsecured liabilities CONTINGENT OR DEFERRED 10. Contract or Agreements 11. Promissory Notes 12. Lawsuits 13. Options 14. Taxes 15. Other contingent or deferred liabilities Law Offices of Saidis Sullivan & Rogers 26 West High Street Carlisle,PA 17013 ANGELA SAMUELSEN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 200846 4� CIVIL TERM RONALD SAMUELSEN, Defendant IN DIVORCE - MOTION TO WITHDRAW APPOINTMENT OF MASTER AND NOW, comes Angela Samuelsen by and through her counsel, Marylou Matas, Esquire of Saidis, Sullivan & Rogers, and moves this Honorable Court as follows: 1. The parties hereto are husband and wife having been joined in marriage on June 22, 1996, a Complaint in Divorce having been filed with the Court on October 13, 2008. 2. On December 6, 2012 Plaintiff filed a Motion for the Appointment of the Master and on December 10, 2012, E. Robert Elicker, II, Esquire was appointed Master with regard to the claims of divorce and equitable distribution. 3. The parties have entered into a Marital Settlement Agreement resolving all outstanding economic claims and have signed Consents for the entry of a Decree in Divorce. 4. As all matters presented to the Master for determination have been resolved, the Master's appointment may be withdrawn. 5. Respondent is represented by Gregory S. Hazlett, Esquire who concurs in the relief requested. WHEREFORE, Movant prays this Honorable Court to withdraw the appointment of E. Robert Elicker, II, Esquire in the captioned case. Law Offices of Sa.idis SAIDIS, SULLIVAN & ROGERS Sullivan Date: 19/�Z& :7)Vb4iAt.W4,o & Rogers Maryl { s, Esquire t s T 26 West High Street Attorney ld. 919 Carlisle,PA 17013 26 West High Street rZ L Carlisle, PA 17013 73 F- —1;j:w (717) 243-6222 j- -- W� t' Counsel for Plaintiff ` ` --f :� .�.. >.-F. - ANGELA SAMUELSEN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2008-6112 CIVIL TERM RONALD SAMUELSEN, : Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Marylou Matas, Esquire hereby certify that on this � / "_day of c1 2013, a true and correct copy of the within document was served upon the party listed below, via First Class Mail, postage prepaid, addressed as follows: Gregory S. Hazlett, Esquire 7 West Main Street Mechanicsburg, PA 17065-6331 Counsel for Defendant SAIDIS, SULLIVAN & ROGERS Mar ou% s, Esqui Supreme rt ID No. 84919 26 West High Street Carlisle, PA 17013 717-243-6222 Law Offices of Saidis Sullivan & Rogers 26 West High Street Carlisle,PA 17013 ANGELA J. SAMUELSEN, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 08-6122 CIVIL TERM RONALD M. SAMUELSEN, IN DIVORCE Defendant/Petitioner PACSES Case No: 626110666 -� -�> ORDER OF COURT , cY ::Zr. c.a AND NOW to wit, on this 18th day of July, 2013, it is hereby Ordered that the pursuant to the parties' Property Settlement and Separation Agreement of July 17, 2013, the Alimony Pendente Lite is terminated effective July 1, 2013 with no balance due the Petitioner. Petitioner remits all arrears owed to him. This Order shall become final twenty (20) days after the mailing of the notices of the entry of the Order to the parties unless either party files a written demand with the Office of the Prothonotary for a hearing de novo before the Court. BY THE C,,?( o s Edward E. Guido, J. DRO: R.J. Shadday xc: Petitioner Respondent Marylou Matas, Esq. Gregory S. Hazlett, Esq. Form OE-001 Service Type:M Worker:21005 M INCOME WITHHOLDING FOR SUPPORT O ORIGINAL INCOME WITHHOLDING ORDER/NOTICE FOR SUPPORT(IWO) � _�) yti CAM U O AMENDEDIWO p( (/ O ONE-TIMEORDER/NOTICE FOR LUMP SUM PAYMENT (j) TERMINATION OF IWO Date: 07/18/13 ❑ Child Support Enforcement(CSE)Agency ® Court ❑ Attorney ❑ Private Individual/Entity(Check One) NOTE:This IWO must be regular on its face. Under certain circumstances you must reject this iWO and return it to the sender(see iWO instructions httg://www acf hhs gov/programs/ese/newhire/emg lover/publication/publication htm-forms). If you receive this document from someone other than a State or Tribal CSE agency or a Court,a copy of the underlying order must be attached. State/Triberrerritory Commonwealth of Pennsylvania Remittance identifier(include w/payment): 0418102052 City/County/Dist.rrribe CUMBERLAND Order identifier: (See Addendum for order/docket informaiton) Private individual/Entity CSE Agency Case Identifier: (See Addendum for case summary) HOLY SPIRIT HOSPITAL RE: SAMUELSEN ANGELA J. C/O PAYROLL DEPT Employee/Obligor's Name(Last,First,Middle) 503 N 21 ST ST 203-629582 CAMP HILL PA 1 701 1-2204 Employee/Obligor's Social Security Number (See Addendum for plaintiff names associated with cases on attachment) Custodial Party/Obligee's Name(Last,First, Middle) Employer/income Withholder's FEiN 231512747 NOTE:This IWO must be regular on its face. Under certain circumstances you must reject Child(ren)'s Name(s)(Last,First,Middle) Child(ren)'s Birth Date(s) this IWO and return it to the sender(see IWO instructions http://www.acf.hhs.gov/pro-grams/cse/newhire gmot over/publication/publication.htm-forms).If you receive this document from someone other than a State or Tribal CSE agency or a Court,a copy of the underlying order must be attached. 2315127470 See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This document is based on the support or withholding order from CUMBERLAND County, Commonwealth of Pennsylvania (State/Tribe). You are required by law to deduct these amounts from the employee/ obligor's income until further notice. �; $ 0.00 per month in current child support --vim w $ 0.00 per month in past-due child support- Arrears 12 weeks or greater? 0 ye C•} $ 0.00 per month in current cash medical support r- $ 0.00 per month in past-due cash medical support $ 0.00 per month in current spousal support CD �`T $ 0.00 per month in past-due spousal support C7i ; $ 0.00 per month in other(must specify) .m Z, for a Total Amount to Withhold of$ 0.00 per month. AMOUNTS TO WITHHOLD: You do not have to vary your pay cycle to be in compliance with the Order Information. If your pay cycle does not match the Ordered payment cycle, withhold one of the following amount: $ 0.00 per weekly pay period. $ 0.00 per semimonthly pay period(twice a month) $ 0.00 per biweekly pay period(every two weeks) $ 0.00 per monthly pay period. $ Lump Sum Payment: Do not stop any existing IWO unless you receive a termination order. REMITTANCE INFORMATION: If the employee/obligor's principal place of employment is within the Commonwealth of Pennsylvania (State/Tribe), you must begin withholding no later than the first pay period that occurs ten 10 working days after the date of this Order/Notice. Send payment within seven 7 working days of the pay date. If you cannot withhold the full amount of support for any or all orders for this employee/obligor, withhold up to 5510 of disposable income for all orders. If the employee/obligor's principal place of employment is not within the Commonwealth of Pennsylvania (State/Tribe), the employer can obtain withholding limitations, time requirements, and any allowable employer fees at http://www acf hhs gov/programs/cse/newhire/employer/contacts/contact map htm for the employee/obligor's principal place of employment. Document Tracking Identifier OMB No.:0970-0154 Form EN-028 06/12 Service Type M Worker ID$IATT s ❑ Return to Sender[Completed by Employer/Income Withholder]. Payment must be directed to an SDU in accordance with 42 USC§666(b)(5)and (b)(6)or Tribal Payee(see Payments to SDU below). If payment is not directed to an SDU/Tribal Payee or this IWO is not regular on its face, you must check this box and return the IWO to the sender. Signature of Judge/Issuing Official(if required by State or Tribal law): " Print Name of Judge/Issuing Official: Ed w ;Tido Title of Judge/Issuing Official: Date of Signature: JUL f 9 7n13 If the employee/obligor works in a State or for a Tribe that is different from the State or Tribe that issued this order, a copy of this IWO must be provided to the employee/obligor. ❑ If checked,the employer/income withholder must provide a copy of this form to the employee/obligor. ADDITIONAL INFORMATION FOR EMPLOYERS/INCOME WITHHOLDERS Pennsylvania law(23 PA C.S.§4374(b))requires remittance by an electronic payment method if an employer is ordered to withhold income from more than one employee and employs 15 or more persons,or if an employer has a history of two or more returned checks due to nonsufficient funds. Please call the Pennsylvania State Collections and Disbursement Unit(PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. PA FIPS CODE 42 000 00 Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION,PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID(shown above as the EmployeelObligor's Case identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. State-specific contact and withholding information can be found on the Federal Employer Services website located at: http://www.acf.hhs.gov/programs/cse/newhire/`employer/contacts/contact map.htm Priority: Withholding for support has priority over any other legal process under State law against the same income(USC 42 §666(b)(7)). If a Federal tax levy is in effect, please notify the sender. Combining Payments: When remitting payments to an SDU or Tribal CSE agency,you may combine withheld amounts from more than one employee/obligor's income in a single payment. You must, however, separately identify each employee/ obligor's portion of the payment. Payments To SDU: You must send child support payments payable by income withholding to the appropriate SDU or to a Tribal CSE agency. if this IWO instructs you to send a payment to an entity other than an SDU(e.g., payable to the custodial party, court, or attorney), you must check the box above and return this notice to the sender. Exception: If this IWO was sent by a Court,Attorney, or Private Individual/Entity and the initial order was entered before January 1, 1994 or the order was issued by a Tribal CSE agency, you must follow the"Remit payment to" instructions on this form. Reporting the Pay Date: You must report the pay date when sending the payment.The pay date is the date on which the amount was withheld from the employee/obligor's wages.You must comply with the law of the State(or Tribal law if applicable)of the employee/obligor's principal place of employment regarding time periods within which you must implement the withholding and forward the support payments. Multiple IWOs: If there is more than one IWO against this employee/obligor and you are unable to fully honor all IWOs due to Federal, State, or Tribal withholding limits, you must honor all IWOs to the greatest extent possible, giving priority to current support before payment of any past-due support. Follow the State or Tribal law/procedure of the employee/obligor's principal place of employment to determine the appropriate allocation method. Lump Sum Payments: You may be required to notify a State or Tribal CSE agency of upcoming lump sum payments to this employee/obligor such as bonuses,commissions,or severance pay. Contact the sender to determine if you are required to report and/or withhold lump sum payments. Liability: If you have any doubts about the validity of this IWO, contact the sender. If you fail to withhold income from the employee/obligor's income as the IWO directs,you are liable for both the accumulated amount you should have withheld and any penalties set by State or Tribal law/procedure. Anti-discrimination: You are subject to a fine determined under State or Tribal law for discharging an employee/obligor from employment, refusing to employ,or taking disciplinary action against an employee/obligor because of this IWO. OMB Expiration Date—05/31/2014.The OMB Expiration Date has no bearing on the termination date of the IWO;it identifies the version of the farm currently in use. Form EN-028 06/12 Service Type M Page 2 of 3 Worker ID$IATT � . Employees Name: Employer FEIN: Name: SAMUELSEN,ANGELA J. 0418102052 CSE Agency Case Identifier: Order Identifier:age Addendum for orderldocket information Withholding Limits:You may not withhold more than the lesser of: 1)the amounts allowed by the Federal Consumer Credit Protection Act(CCPA)(15 U.S.C. 1673(b));or 2)the amounts allowed by the State or Tribe of the employee/obligor's principal place of employment(see REMITTANCE INFORMATION). Disposable income is the net income left after making mandatory deductions such as: State, Federal,local taxes; Social Security taxes; statutory pension contributions; and Medicare taxes.The Federal limit is 50%of the disposable income if the obligor is supporting another family and 60%of the disposable income if the obligor is not supporting another family. However.those limits increase 596-to 55%and 65%-if the oneune are greater than 12 weeks. If permitted by the State or Tribe,you may deduct a fee for administrative costs.The combined support amount and fee may not exceed the limit indicated in this section. For Tribal orders,you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employers/income withholders who receive a State IWO,you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which the employer/income withholder is located or the maximum amount permitted under section 303(d)of the CCPA(15 U.S.C. 1673(b)) Depending upon applicable State or Tribal law,you may need to also consider the amounts paid for health care premiums in determining disposable income and applying appropriate withholding limits. Arrears greater than 12 weeks?If the Order Information does not indicate that the arrears are greater than 12 weeks,then the Employer should calculate the COPA limit using the lower percentage. Additional Information: NOTIFICATION OF EMPLOYMENT TERMINATION OR INCOME STATUS: If this employee/obligor never worked for you or you are no longer withholding income for this employee/obiigor,an employer must promptly notify the CSE agency and/or the sender by returning this form to the address listed in the Contact Information below: 2315127470 0 This person has never worked for this employer nor received periodic income. 0 This person no longer works for this employer nor receives periodic income. Please provide the following information for the employee/obligor: Termination date: Last known phone number: Last known address: Final Payment Date To SDLI/Tribal Payee: Final Payment Amount: New Employer's Name: New Employer's Address: CONTACT INFORMATION: To Employer/Income Withholder: |f you have any questions, contact WAGE ATTACHMENT UNIT(Issuer name) by phone at . by fax at . by email orwebo|ha a1: . Send termination/income status notice and other correspondence to:DOMESTIC RELATIONS SECTION, 13-N..HANOVER ST, P.O. BOX 320. CARLISLE, PA. 17013(Issuer address). To Employee/Obligor: |f the employee/obligor has questions,contact WAGE ATTACHMENT UNIT(Issuer name) by phone at . by fax at . by email orvvebsite at . IMPORTANT:The person completing this form isadvised that the information may Ue shared with the ompinyne/ob|iQnr. | OMB m».'«»m-01s4 Form EN-028 08/12 Service Type K8 Page 3 of Worker/O$iATT r ADDENDUM SummaU of Gases on Attachment Defendant/Obligor: SAMUELSEN, ANGELA J. PACSES Case Number 626110666 PACSES Case Number Plaintiff Name Plaintiff Name RONALD M.SAMUELSEN Do ket Attachment Amount Docket Attachment Amount 08-6122 CIVIL $ 0.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB PACSES Case Number PACSES Case Number Plaintiff Nam Plaintiff Name Docket Attachment Amount Docket Aeachment Amount $ 0.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB PACSES Case Number PACSES Case Number Plaintiff Name Plaintiff Name Do ke Attachment Amount Docko Attachment Amount $ 0.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB Addendum Form EN-028 06/12 Service Type M OMB No.:0970-0154 Worker ID$IATT ANGELA SAMUELSEN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2008-64-1--2- CIVIL TERM RONALD SAMUELSEN, Defendant IN DIVORCE ORDER OF COURT AND NOW, this 2'Z� day of 2013 , the economic claims raised in the proceedings having been resolved in accordance with a Martial Settlement Agreement dated July 17, 2013, the appointment of Master is vacated and counsel can file a Praecipe transmitting the record to the Court requesting a final decree in divorce. BY THE COURT, J. cc: Marylou Matas, Esquire Counsel for Plaintiff ✓Gregory S. Hazlett, Esquire Counsel for Defendant - d� Law Offices of Saidis Sullivan f �rrn r-- 7; -T] & Rogers 26 West High Street Carlisle,PA 17013 `� ANGELA SAMUELSEN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION — LAW _ NO. 2008-6122 CIVIL TERM -a M Cc = " RONALD SAMUELSEN, C= t✓ Defendant, IN DIVORCEW , PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under§ 3301(c) of the Divorce Code was filed bfr. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Date: 7 r? Zi 3 6W 0 J , 20"1116,09 tNi Angela amuelsen PLAINTIFF'S 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. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. Law Offices of 3. 1 understand that I will not be divorced until a Divorce Decree is entered by the Sa.idis Sullivan Court and that a copy of the Decree will be sent to me immediately after it is filed with the & Rogers Prothonotary. 26 West High Street Carlisle,PA 17013 1 verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Date: 7ZI"7 13 amil J. Angel Samuelsen ANGELA SAMUELSEN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION — LAW " •7T; NO. 2008-6122 CIVIL AAM RONALD SAMUELSEN, ' 0 Defendant, IN DIVORCE ' ? 1 DEFENDANT'S AFFIDAVIT OF CONSENTS 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was died rtober 13, 2008. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Date: INIJ01 �'- ONALD SA U LSEN DEFENDANT'S 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. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. Law offices of 3. 1 understand that I will not be divorced until a Divorce Decree is entered by the Court Saidis Sullivan and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. & Rogers I verify that the statements made in this Affidavit are true and correct to the best of my 26 West High Street Carlisle,PA 17013 knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsificati to authorities. Date: 7 A 2 / AONALD S SEN ANGELA SAMUELSEN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION —LAW NO. 2008-6122 CIVIL TERM RONALD SAMUELSEN, Defendant, IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint on October 20, 2008, via certified restricted mail. Proof of service was filed with the Court on October 21, 2008. 3. Date Affidavit of Consent required under Section 3301(c) or(d) of the Divorce Code was signed: By Plaintiff: July 17, 2013 and filed with the Prothonotary on August 7, 2013. By Defendant: July 28, 2013 and filed with the Prothonotary on August 7, 2013. 4. Related claims pending: Resolved by the Marital Settlement Agreement dated July 17, 2013. 5. Date Waiver of Notice under Section 3301(c) of the Divorce Code was signed: By Plaintiff: July 17, 2013 and filed with the Prothonotary on August 7, 2013. By Defendant: July 28, 2013 and filed with the Prothonotary on August 7, 2013. Law Offices of Saidis Sullivan SAIDIS, SULLIVAN & ROGERS & Rogers 26 West High Street /w'✓ v u / ""0 _ Carlisle,PA 17013 Marylo6 Matas, Esquire Supreme Court ID No. 84919 26 West High Street Carlisle, PA 17013 717-243-6222 ` Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ANGELA SAMUELSEN V. RONALD SAMUELSEN No, 2008-6122 DIVORCE DECREE AND NOW. 2zkk%,Lb' - , 20%�3 it is ordered and decreed that ANGELA SAMUELSEN plaintiff, and RONALD SAMUELSEN defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows- (If no claims remain indicate "None.") Marriage Settlement Agreement dated July 17, 2013 is incorporated but not merged. ............................ 400Y Attest: Common;zudqe Jg4gIM4.,1021" 104 1 Z). Bvi5al 4:>rothonota o /fWL goo`y MalZed 4 ldthll