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HomeMy WebLinkAbout08-73730 Sarah B. Douglas, Plaintiff VS. Stanley E. Douglas, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA : CIVIL ACTION : NO. G F- 7 3 73&Z--d -7-,u- : IN DIVORCE N O T I C E T O D E F E N D 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: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013-3387 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE PA 17013 1-800-990-9108 717-249-3166 Sarah B. Douglas, Plaintiff VS. Stanley E. Douglas, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA : CIVIL ACTION : NO. Of- 13?j : IN DIVORCE NOTICE OF RIGHT TO COUNSELING You are one of the parties in the above captioned action in divorce. By virtue of Section 202 of the Pennsylvania Divorce Code, it is a duty of the Court to advise both parties of the availability of counseling and upon request of either provide both parties a list of qualified professionals who provide such services. Accordingly, if you desire counseling a list of marriage; counselors is available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013-3387 Sarah B. Douglas, Plaintiff VS. Stanley E. Douglas, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA : CIVIL ACTION . NO. OP- 11373 CtZQ 7?v-- : IN DIVORCE CONSOLIDATED COMPLAINT IN DIVORCE 1. Plaintiff is Sarah B. Douglas, a citizen of Pennsylvania,) residing at 1330 Williams Grove Rd., Mechanicsburg, Cumberland; County, Pennsylvania. 2. Defendant is Stanley E. Douglas, a citizen of Pennsylvania,' residing at 1330 Williams Grove Rd., Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant are suiluris and have been bonafide residents of the Commonwealth of Pennsylvania for at least six months immediately preceding the filing of this Complaint. 4. The parties are husband and wife and were lawfully married on January 10, 2002, in Travis County, Texas. 5. The marriage is irretrievably broken. 6. Neither Plaintiff nor Defendant are in the military or naval service of the United States or its allies within the provisions of the Soldiers' & Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 8. The Plaintiff has been advised of the availability of counseling and of the right to request that the Court require the parties to participate in counseling. COUNT I Request for a Fault Divorce Under 3301(a)(6) of the Divorce Code 9. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 10. Defendant has offered such indignities to the Plaintiff, who is the innocent and injured spouse, as to render Plaintiff's condition intolerable and life burdensome. 11. This action is not collusive. 12. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, Plaintiff 'enter a Decree of Divorce, Code . respectfully requests that the Court pursuant to 3301(a)(6) of the Divorce COUNT II Request for Divorce Due to Irretrievable Breakdown Under 3301(c) of the Divorce Code 13. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 14. The marriage of the parties is irretrievably broken. 15. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 16. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, if both parties file affidavits to a divorce after ninety (90) days have elapsed from the filing of this Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301(c) of the Divorce Code. COUNT III Request for Divorce Due to Irretrievable Breakdown Under 3301(d) of the Divorce Code 17. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 18. The marriage of the parties is irretrievably broken. 19. After a period of two (2) years has elapsed from the date of separation, Plaintiff intends to file her affidavit of having lived separate and apart. 20. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, if two (2) years have elapsed from the date of ,separation and Plaintiff has filed her affidavit, Plaintiff !respectfully requests the Court to enter a Decree of Divorce, ,pursuant to 3301(d) of the Divorce Code. COUNT IV Request for Equitable Distribution of Marital Property Under 3104, 3323, 3501, 3502 and 3503 of the Divorce Code 21. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 22. Plaintiff and Defendant have acquired property, both real and personal during their marriage from the date of said marriage until the date of their separation. 23. Plaintiff and Defendant have been unable to agree as to an equitable distribution of said property. WHEREFORE, Plaintiff respectfully requests the Court to equitably distribute the marital property of the parties, pursuant to 3104 and 3502(a) of the Divorce Code. COUNT V Request for Alimony Pendente Lite and Alimony under 3104, 3323, 3701, 3702 and 3704 of the Divorce Code 24. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 25. Plaintiff is unable to sustain herself during the course of litigation. 26. Plaintiff lacks sufficient property to provide for her reasonable needs and is unable to sustain herself through appropriate employment. 27. Defendant has the means and ability to pay Alimony Pendente Lite and Alimony to Plaintiff. WHEREFORE, Plaintiff requests the Court to enter an award of alimony pendente lite until final hearing and thereupon to enter an Order of alimony in her favor. COUNT VI Request for Counsel Fees, Costs and Expenses Under 3104, 3323, 3502(e) and 3702 of the Divorce Code 28. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 29. Plaintiff has employed Mary A. Etter Dissinger, of the law firm of Dissinger and Dissinger to represent her in this matrimonial cause. 30. Plaintiff is unable to pay the necessary counsel fees, costs, and expenses and Defendant is more than able to pay them. WHEREFORE, reserving the right to apply to the Court for temporary counsel fees, costs and expenses, prior to final hearing, Plaintiff requests that, after final hearing, the Court order Defendant to pay Plaintiff's reasonable counsel fees, costs and expenses. COUNT VII Request for Confirmation of Custody Under 3104 of the Divorce Code 31. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 32. Plaintiff is Sarah B. Douglas, residing at 1330 Williams Grove Rd., Mechanicsburg County, Pennsylvania. 33. Defendant is Stanley E. Douglas, residing 1330 Williams Grove Rd., Mechanicsburg County, Pennsylvania. 34. Plaintiff seeks custody of the following children: Name Present Residence Age Wendy A. Douglas- 1330 Williams Grove Rd. DOB 11/8/94 Tyler A. Douglas- 1330 Williams Grove Rd. DOB 12/2/01 Sean R. Douglas- 1330 Williams Grove Rd. DOB 3/30/07 35. Two children were born out cf wedlock. 36. The children are presently in the custody of Plaintiff and Defendant, residing at 1330 Williams Grove Rd., Mechanicsburg County, Pennsylvania. 37. During the past five years, the children have resided with the following persons at the following addresses: Person Address Date Sarah B. Douglas Stanley E. Douglas Wendy A. Douglas Tyler A. Douglas Sean R. Douglas 1330 Williams Grove Rd. 1330 Williams Grove Rd. 1330 Williams Grove Rd. 1330 Williams Grove Rd. 1330 Williams Grove Rd. 11/25/03 - Present 11/25/03 - Present 11/25/03 - Present 11/25/03 - Present DOB - Present 38. The mother of Sean and Tyler is Sarah B. Douglas who currently resides at 1330 Williams Grove Rd., Cumberland County, Pennsylvania. The mother of Wendy is Bridgett Douglas. 39. She is married to Stanley E. Douglas. 40. The father of all the children is Stanley E. Douglas who currently resides at 1330 Williams Grove Rd., Cumberland County, Pennsylvania. 41. He is married to Sarah B. Douglas. 42. The relationship of Plaintiff to the children is that of natural Mother as to Tyler and Sean, and stepmother as to Wendy. The Plaintiff currently resides with Stanley E. Douglas, Wendy A. Douglas, Tyler A. Douglas, Sean R. Douglas. 43. The relationship of Defendant to the children is that of natural Father. The Defendant currently resides with Sarah B. Douglas, Wendy A. Douglas, Tyler A. Douglas, Sean R. Douglas. 44. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 45. Plaintiff has no information of a custody proceeding concerning any of the children pending in a court of this Commonwealth. 46. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children. Bridgett Douglas is the natural mother of Wendy Douglas but has had no contact with the child for last thirteen (13) years. 47. The best interest and permanent welfare of the children will be served by granting the relief requested because Plaintiff has been the primary caregiver and is more closely bonded with the children than is Defendant, and is better able to provide for their emotional needs. 48. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action, except for Bridgett Douglas whose whereabouts are unknown. All other persons, named below who are known to have or claim a right to custody or visitation of the children will be given notice of the pendency of this action and the right to intervene: None. 49. Defendant shall have the right to reasonable and liberal visitation with the children. WHEREFORE, Plaintiff respectfully prays your Honorable Court to grant custody to Plaintiff and that Defendant be granted reasonable rights of visitation. Respectfully submitted, DISSINGER and DISSINGER Mary A. Etter Dissinger Attorney for Plaintiff Supreme Court ID # 27736 28 North Thirty-Second Street Camp Hill, PA 17011 (717) 975-2840 It VERIFICATION I, Sarah. B Douglas, verify that the statements made in the Divorce Complaint 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. .2wai- Sarah B. Douglas, Plai iff n ? r r U, ILI% y; C Sarah B. Douglas, Plaintiff VS. Stanley E. Douglas, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA : CIVIL ACTION : NO. CAP- 7373P : IN DIVORCE N O T I C E T O D E F E N D 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: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013-3387 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE PA 17013 1-800-990-9108 717-249-3166 Sarah B. Douglas, Plaintiff VS. Stanley E. Douglas, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA : CIVIL ACTION : NO. d4- 137J : IN DIVORCE NOTICE OF RIGHT TO COUNSELING You are one of the parties in the above captioned action in divorce. By virtue of Section 202 of the Pennsylvania Divorce Code, it is a duty of the Court to advise both parties of the availability of counseling and upon request of either provide both parties a list of qualified professionals who provide such services. Accordingly, if you desire counseling a list of marriage counselors is available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013-3387 Sarah B. Douglas, Plaintiff VS. Stanley E. Douglas, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA CIVIL ACTION . N0. 0F-11373 C IN DIVORCE CONSOLIDATED COMPLAINT IN DIVORCE 1. Plaintiff is Sarah B. Douglas, a citizen of Pennsylvania, residing at 1330 Williams Grove Rd., Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Stanley E. Douglas, a citizen of Pennsylvania, residing at 1330 Williams Grove Rd., Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant are suiluris and have been bonafide residents of the Commonwealth of Pennsylvania for at least six months immediately preceding the filing of this Complaint. 4. The parties are husband and wife and were lawfully married on January 10, 2002, in Travis County, Texas. 5. The marriage is irretrievably broken. 6. Neither Plaintiff nor Defendant are in the military or naval service of the United States or its allies within the provisions of the Soldiers' & Sailors' Civil Relief Act of the Congress of 1940 and its amendments. i 7. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 8. The Plaintiff has been advised of the availability of counseling and of the right to request that the Court require the parties to participate in counseling. COUNT I Request for a Fault Divorce Under 3301(a) (6) of the Divorce Code 9. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 10. Defendant has offered such indignities to the Plaintiff, who is the innocent and injured spouse, as to render Plaintiff's condition intolerable and life burdensome. 11. This action is not collusive. 12. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, Plaintiff respectfully requests that the Court enter a Decree of Divorce, pursuant to 3301(a)(6) of the Divorce Code. COUNT II Request for Divorce Due to Irretrievable Breakdown Under 3301(c) of the Divorce Code 13. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 14. The marriage of the parties is irretrievably broken. 15. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 16. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, if both parties file affidavits to a divorce after ninety (90) days have elapsed from the filing of this Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301(c) of the Divorce Code. COUNT III Request for Divorce Due to Irretrievable Breakdown Under 3301(d) of the Divorce Code 17. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 18. The marriage of the parties is irretrievably broken. 19. After a period of two (2) years has elapsed from the date of separation, Plaintiff intends to file her affidavit of having lived separate and apart. 20. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, if two (2) years have elapsed from the date of separation and Plaintiff has filed her affidavit, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301(d) of the Divorce Code. COUNT IV Request for Equitable Distribution of Marital Property Under 3104, 3323, 3501, 3502 and 3503 of the Divorce Code 21. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 22. Plaintiff and Defendant have acquired property, both real and personal during their marriage from the date of said marriage until the date of their separation. 23. Plaintiff and Defendant have been unable to agree as to an equitable distribution of said property. WHEREFORE, Plaintiff respectfully requests the Court to equitably distribute the marital property of the parties, pursuant to 3104 and 3502(a) of the Divorce Code. COUNT V Request for Alimony Pendente Lite and Alimony under 3104, 3323, 3701, 3702 and 3704 of the Divorce Code 24. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 25. Plaintiff is unable to sustain herself during the course of litigation. 26. Plaintiff lacks sufficient property to provide for her reasonable needs and is unable to sustain herself through appropriate employment. 27. Defendant has the means and ability to pay Alimony Pendente Lite and Alimony to Plaintiff. WHEREFORE, Plaintiff requests the Court to enter an award of alimony pendente lite until final hearing and thereupon to enter an Order of alimony in her favor. COUNT VI Request for Counsel Fees, Costs and Expenses Under 3104, 3323, 3502(e) and 3702 of the Divorce Code 28. The prior paragraphs of this Complaint are incorporated herein) by reference thereto. 29. Plaintiff has employed Mary A. Etter Dissinger, of the law firm of Dissinger and Dissinger to represent her in this matrimonial cause. 30. Plaintiff is unable to pay the necessary counsel fees, costs, and expenses and Defendant is more than able to pay them. WHEREFORE, reserving the right to apply to the Court for temporary counsel fees, costs and expenses, prior to final hearing, Plaintiff requests that, after final hearing, the Court order Defendant to pay Plaintiff's reasonable counsel fees, costs and expenses. COUNT VII Request for Confirmation of Custody Under 3104 of the Divorce Code 31. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 32. Plaintiff is Sarah B. Douglas, residing at 1330 Williams Grove Rd., Mechanicsburg County, Pennsylvania. 33. Defendant is Stanley E. Douglas, residing 1330 Williams Grove Rd., Mechanicsburg County, Pennsylvania. 34. Plaintiff seeks custody of the following children: Name Present Residence Age Wendy A. Douglas- 1330 Williams Grove Rd. DOB 11/8/94 Tyler A. Douglas- 1330 Williams Grove Rd. DOB 12/2/01 Sean R. Douglas- 1330 Williams Grove Rd. DOB 3/30/07 35. Two children were born out of wedlock. 36. The children are presently in the custody of Plaintiff and Defendant, residing at 1330 Williams Grove Rd., Mechanicsburg County, Pennsylvania. 37. During the past five years, the children have resided with the following persons at the following addresses: Person Address Date Sarah B. Douglas 1330 Williams Grove Rd. 11/25/03 - Present Stanley E. Douglas 1330 Williams Grove Rd. 11/25/03 - Present Wendy A. Douglas 1330 Williams Grove Rd. 11/25/03 - Present Tyler A. Douglas 1330 Williams Grove Rd. 11/25/03 - Present Sean R. Douglas 1330 Williams Grove Rd. DOB - Present 38. The mother of Sean and Tyler is Sarah B. Douglas who currently resides at 1330 Williams Grove Rd., Cumberland County, Pennsylvania. The mother of Wendy is Bridgett Douglas. 39. She is married to Stanley E. Douglas. 40. The father of all the children is Stanley E. Douglas who currently resides at 1330 Williams Grove Rd., Cumberland County, Pennsylvania. 41. He is married to Sarah B. Douglas. 42. The relationship of Plaintiff to the children is that of natural Mother as to Tyler and Sean, and stepmother as to Wendy. The Plaintiff currently resides with Stanley E. Douglas, Wendy A. Douglas, Tyler A. Douglas, Sean R. Douglas. 43. The relationship of Defendant to the children is that of natural Father. The Defendant currently resides with Sarah B. Douglas, Wendy A. Douglas, Tyler A. Douglas, Sean R. Douglas. 44. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 45. Plaintiff has no information of a custody proceeding concerning any of the children pending in a court of this Commonwealth. 46. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children. Bridgett Douglas is the natural mother of Wendy Douglas but has had no contact with the child for last thirteen (13) years. 47. The best interest and permanent welfare of the children will be served by granting the relief requested because Plaintiff has been the primary caregiver and is more closely bonded with the children than is Defendant, and is better able to provide for their emotional needs. 48. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action, except for Bridgett Douglas whose whereabouts are unknown. All other persons, named below who are known to have or claim a right to custody or visitation of the children will be given notice of the pendency of this action and the right to intervene: None. 49. Defendant shall have the right to reasonable and liberal visitation with the children. WHEREFORE, Plaintiff respectfully prays your Honorable Court to grant custody to Plaintiff and that Defendant be granted reasonable rights of visitation. Respectfully submitted, DISSINGER and DISSINGER r------ Mary A. tter Dissinger Attorney for Plaintiff Supreme Court ID # 27736 28 North Thirty-Second Street Camp Hill, PA 17011 (717) 975-2840 VERIFICATION I, Sarah. B Douglas, verify that the statements made in the Divorce Complaint 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. GCS 1? -6 Sarah B. Douglas, Plaintiff ry Sts ?_ ?J -q ?J ? .? w c t ? N3 t31 j -C I . Sarah B. Douglas, Plaintiff VS. Stanley E. Douglas, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA : CIVIL ACTION : NO. 08-7373 CIVIL TERM : IN DIVORCE MOTION TO SCHEDULE HEARING ON ALIMONY PENDENTE LITE AND NOW comes Sarah B. Douglas by and through her Attorney, Mary A. Etter Dissinger, Esquire, request the court to schedule a hearing on her Petition of Alimony Pendente Lite in support of the Motion avers as follows: 1. The Plaintiff in this action Sarah B. Douglas who resides at 1204 Brandt Rd., Mechanicsburg, PA 17055. 2. The Defendant is Stanley E. Douglas who resides at 1330 Williams Grove Rd., Mechanicsburg, Cumberland County, PA. 3. Plaintiff has filed an action for divorce on December 19, 2008 to the above docket number. 4. In Plaintiff's Complaint in Divorce she asked for alimony and alimony pendente lite. . 4. 5. Plaintiff requests the court to schedule a hearing on her request for alimony pendente lite. Respectfully Submitted, DISSINGER & DISSINGER Mary A. Etter Dissingerl Attorney at Law Supreme Court ID #27736 28 North Thirty-second Street Camp Hill, PA 17011 (717)975-2840 (717)975-3924 - fax l VERIFICATION I, Sarah B. Douglas, 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. P??t,<?- Sarah B. Douglas .. Sarah B. Douglas, Plaintiff VS. Stanley E. Douglas, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA : CIVIL ACTION : NO. 08-7373 CIVIL TERM : 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 Michael A. Scherer, Esq., counsel for Plaintiff by depositing same in the United States Mail, postage prepaid, addressed as follows: Date: Stanley E. Douglas 1330 Williams Grove Rd. Mechanicsburg, PA 17055 Mary. Etter Dissin , Esq. a ? ? ?7 ? f.17?s- t ttt •?' :? <:. ? ? w ''' V Sarah B. Douglas, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY : PENNSYLVANIA VS. : CIVIL ACTION Stanley E. Douglas, : NO. 08-7373 CIVIL TERM 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 Complaint in Divorce in this action to the Defendant at his residence, and that Defendant did receive same as evidenced by the signed receipt dated December 31, 2008, attached hereto as Exhibit "A Mary A. Etter Dissinger Attorney for Plaintiff Supreme Court ID #27736 28 N. 32nd Street Camp Hill, PA 17011 (717) 975-2840 Sworn to and subs ;, ed before 1?uf-vj? his day of 2009. otarv Public NOTARKSM ANNM POMS Notary PL0Uc CAW NU BOROUGH, CUMBERLAND COUNTY My CortanMM Expk a Jul 22, 2009 0 AW t HM?fl?d Nerriy C. D" of DdNMecy Many? 01w. d 0 M DEC 3 I Z(z" G FaOmiwed 0 P4ton PAnd OtbrMMhNx ?es 0kwis PMlWl ®'coo. 4. ROWIWd CarNwey? POW ft* 11Ys 2 ANdeNumb?r 7006 0100 0007 1055 2839 Dprce?C?Ii1Mu?+tlredi?? ?,.._, . _ .._ .A?erNrftl? ?os+o • pMNpIMrNet? ?F.2.mid . Ahw aarrrs "& aqvmr ftn Is desired. ¦ p* t4yw,w addon on the rwam X so thot we can mtum to cod to you. IL FWCSM er Attach ttde card to the backof the MOO*=, or on the dart ff apace PemYts• D. b ddM t. Atdds Ad&wwd m: N VE1% efi? EXHIBIT "A" :. co SARAH B. DOUGLAS, THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 08-7373 CIVIL TERM STANLEY E. DOUGLAS, IN DIVORCE Defendant/Respondent : PACSES NO: 894110596 ORDER OF COURT AND NOW, this 12th day of January 2009, upon consideration of the Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R. J. Shadday on February 4, 2009 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. Copies mailed to: Petitioner Respondent Mary A. Etter Dissinger, Esq. Date of Order: January 12, 2009 BY THE COURT, Edgar B. Bayley, President Judge 4Sdday, PL Coordinator i 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 N_ ? Q "1'f SARAH B. DOUGLAS IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. STANLEY E. DOUGLAS DEFENDANT 2008-7373 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, January 16, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, February 06, 2009 at 10:30 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. 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/ Hubert X. Gilro Es T. . 10 IV' 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 ?J ?o? on ? ??? 4?{?????F ?.J ???=.??'AV ?4?,?, ??` ?' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA SARAH B. DOUGLAS Plaintiff, Civil Action At Law---Custody (Respondent) Case No. 08-7373 VS. STANLEY E. DOUGLAS , (Petitioner) Defendant, COMPLAINT FOR CUSTODY 1. The defendant, Petitioner is Stanley E. Douglas, residing at 1330 Williams Grove Road, Mechanicsburg, PA. 17055 County of Cumberland, Commonwealth of Pennsylvania, 2. The Plaintiff, Respondent is Sarah B. Douglas, whose current residence is 1204 Brandt Street, Mechanicsburg, PA. 17055 in the County of Cumberland, Commonwealth of Pennsylvania. . 3. Defendant, Petitioner, seeks custody of the following children: Name Address _ Ate Sean Douglas same as mother's dob 3/30/2007 1.10 years Tyler Douglas same as mother's dob 12/2/2001 7 years Wendy Douglas same as father's dob 11/8/1994 14 years 4. The children except for Tyler Douglas, were born within wedlock except for Wendy Douglas who was born within wedlock during father's prior marriage. 5. The children except Wendy Douglas, are presently in the custody of Sarah Douglas whose current residence is 1204 Brandt Street, Mechanicsburg, PA. 17055 in the County of Cumberland, Commonwealth of Pennsylvania.. 6. Since January of 2009 the Sean & Tyler Douglas have resided with the Mother at 1204 Brandt Street, Mechanicsburg, PA. 17055 in the County of Cumberland, Commonwealth of Pennsylvania and Wendy Douglas has resided with the father at 1330 Williams Grove Road, Mechanicsburg, PA. 17055 County of Cumberland, Commonwealth of Pennsylvania, 7. The biological mother of Sean & Tyler Douglas is Sarah B. Douglas, whose current address is 1204 Brandt Street, Mechanicsburg, PA. 17055 in the County of Cumberland, Commonwealth of Pennsylvania.. 8. The mother is separated from the father, plaintiff and is currently married to the same. 9. The father of the child is Stanley E. Douglas, who is currently residing at 1330 Williams Grove Road, Mechanicsburg, PA. 17055 County of Cumberland, Commonwealth of Pennsylvania, 10. The father is separated from the mother, and remains married to the same. 11. The relationship of the defendant, Petitioner to the children is that of a biological Father. The Defendant, Petitioner currently resides with the following persons: Name Relationship Wendy Douglas Daughter 12. The defendant has not participated as a party or witness, or in another capacity, in any other litigation concerning the custody of the children in this or another court. 13. The Defendant, petitioner has information of a custody proceeding concerning the children pending in a Court of this Commonwealth as incorporated into a Divorce Complaint filed by Sarah Douglas Case # 08-7373. 5. The children except Wendy Douglas, are presently in the custody of Sarah Douglas whose current residence is 1204 Brandt Street, Mechanicsburg, PA. 17055 in the County of Cumberland, Commonwealth of Pennsylvania. . 6. Since January of 2009 the Sean & Tyler Douglas have resided with the Mother at 1204 Brandt Street, Mechanicsburg, PA. 17055 in the County of Cumberland, Commonwealth of Pennsylvania and Wendy Douglas has resided with the father at 1330 Williams Grove Road, Mechanicsburg, PA. 17055 County of Cumberland, Commonwealth of Pennsylvania, 7. The biological mother of Sean & Tyler Douglas is Sarah B. Douglas, whose current address is 1204 Brandt Street, Mechanicsburg, PA. 17055 in the County of Cumberland, Commonwealth of Pennsylvania.. 8. The mother is separated from the father, plaintiff and is currently married to the same. 9. The father of the child is Stanley E. Douglas, who is currently residing at 1330 Williams Grove Road, Mechanicsburg, PA. 17055 County of Cumberland, Commonwealth of Pennsylvania, 10. The father is separated from the mother, and remains married to the same. 11. The relationship of the defendant, Petitioner to the children is that of a biological Father. The Defendant, Petitioner currently resides with the following persons: Name Relationship Wendy Douglas Daughter 12. The defendant has not participated as a party or witness, or in another capacity, in any other litigation concerning the custody of the children in this or another court. 13. The Defendant, petitioner has information of a custody proceeding concerning the children pending in a Court of this Commonwealth as incorporated into a Divorce Complaint filed by Sarah Douglas Case # 08-7373. 14. Defendant, Petitioner does not know of a person not a party to the proceedings who has Physical Custody of the children or claims to have custody or visitation rights with respect to the children. 15. The best interest and permanent welfare of the children will be served by Granting the relief requested for the reasons as hereinafter recited: (a) The mother in the month of January 2009, unilaterally vacated the marital residence, taking with her Sean & Tyler Douglas, without providing to the father any notice of her intended departure or of her intention to take with her the children. (b) Prior to the mother's departure with the child in January of 2009, the children resided with both parents in the marital home within which they were raised and wherein the children felt a sense of comfort, permanency, and familiarity. (c) The mother due to physical maladies is incapable in the absence of father to adequately parent the children to the extent that mother, suffers from chronic fatigue that requires her to maintain an inordinate level of rest. (d) Prior to mother's departure from the marital residence and while the father was at his place of employment mother had very little interaction with the children in the capacity of a parent and would take the children to her mother's residence whereupon they would be remain for prolonged periods of time. (e) Prior to mother's departure from the marital residence, and while father was at his place of employment mother's step-daughter Wendy Douglas, would provide the parenting role to the minor children Sean & Tyler Douglas while the mother would sleep, to satisfy the demands of her physical ailment. (0 The father prior to the mother's departure and upon his arrival from work each day was the primary custodian and caregiver of the children and provided for all of the children's needs, physically, emotionally, and financially. . 14. Defendant, Petitioner does not know of a person not a party to the proceedings who has Physical Custody of the children or claims to have custody or visitation rights with respect to the children. 15. The best interest and permanent welfare of the children will be served by Granting the relief requested for the reasons as hereinafter recited: (a) The mother in the month of January 2009, unilaterally vacated the marital residence, taking with her Sean & Tyler Douglas, without providing to the father any notice of her intended departure or of her intention to take with her the children. (b) Prior to the mother's departure with the child in January of 2009, the children resided with both parents in the marital home within which they were raised and wherein the children felt a sense of comfort, permanency, and familiarity. (c) The mother due to physical maladies is incapable in the absence of father to adequately parent the children to the extent that mother, suffers from chronic fatigue that requires her to maintain an inordinate level of rest. (d) Prior to mother's departure from the marital residence and while the father was at his place of employment mother had very little interaction with the children in the capacity of a parent and would take the children to her mother's residence whereupon they would be remain for prolonged periods of time. (e) Prior to mother's departure from the marital residence, and while father was at his place of employment mother's step-daughter Wendy Douglas, would provide the parenting role to the minor children Sean & Tyler Douglas while the mother would sleep, to satisfy the demands of her physical ailment. (f) The father prior to the mother's departure and upon his arrival from work each day was the primary custodian and caregiver of the children and provided for all of the children's needs, physically, emotionally, and financially. . (g) Defendant, believes and therefore avers that he can continue to provide a predictable and stable lifestyle for which, the children in a household within which they have become accustomed and one that will be in the best interest of the children during their formative years and throughout their lives. WHEREFORE, Defendant, Petitioner, Stanley Douglas, respectfully requests for the aforementioned reasons, that the court grant and award him primary physical custody of the minor children for the reasons as recited in the aforementioned. Dated: 1/13/2009 Respectfully Submitted, GREGORY S. HAZLETT 7West Main Street Mechanicsburg, PA. 17055 Phone: (717) 790-5500 Attorney for Defendant/Petitioner VERIFICATION I verify that the statements made in this Complaint are true and correct understand that false statements herein are made subject to the penalties of 18 Pa.C.S. & 4904 relating to unsworn falsification to authorities Date: /? 0?" /-I,' Stanley E. Douglas, Plaintiff N O ?o HIM F SARAH B. DOUGLAS PLAINTIFF V. STANLEY E. DOUGLAS DEFENDANT IN THE COURT OF COMM CUMBERLAND COUNTY, 2008-7373 CIVIL ACTION IN CUSTODY QRDER OF COURT AND NOW, Monday, February 09, 2009 , upon consideratic it is hereby directed that parties and their respective counsel appear before Hubert at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, Februs for a Pre-Hearing Custody Conference. At such conference, an effort will be made t if this cannot be accomplished, to define and narrow the issues to be heard by the co order. Failure to appear at the conference may provide grounds for entry of a tempo PLEAS OF NSYLVANIA LAW n of the attached Complaint, X. Gilroy, Esq. , the conciliator, ry 13, 2009 at 9:30 AM resolve the issues in dispute; or irt, and to enter into a temporary 'ary or permanent order. The court hereby directs the parties to furnish any and all existing Prote tion from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to sc ?eduled hearing. FOR THE COURT. By: /s/ Custody Conciliator The Court of Common Pleas of Cumberland County is required by la with Disabilites Act of 1990. For information about accessible facilities and res available to disabled individuals having business before the court, please contac must be made at least 72 hours prior to any hearing or business before the court conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT I HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPH 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 Hubert X. Gilrov. Eso. to comply with the Americans onable accommodations our office. All arrangements You must attend the scheduled CE. IF YOU DO NOT fE THE OFFICE SET L } .C Wd 6- 833 6002 31HI JO FEB " 8 nog G SARAH B. DOUGLAS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW STANLEY E. DOUGLAS, NO. 2008-7373 Defendant IN CUSTODY COURT ORDER -tu AND NOW, this _1rday of February, 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that the following TEMPORARY Custody Order is entered: The mother, Sarah B. Douglas, and the father, Stanley E. Douglas, shall enjoy shared legal custody of Wendy A. Douglas, born November 8,1994, Tyler A. Douglas, born December 2, 2001, and Sean R. Douglas, born March 30, 2007. 2. Physical custody shall be handled as follows: A. Father shall have primary physical custody of Wendy with mother having periods of temporary physical custody of W endy on alternating weekends and on weekdays as set forth below. B. Mother shall have primary physical custody of Tyler and Sean with father having periods of temporary physical custody of Tyler and Sean on weekends and weekdays as set forth below. C. The parties shall alternate custody of all three children on alternating weekends such that the three children are together in one household, with the alternating weekends being from Friday at 5:00 p.m. until Monday morning. D. Father shall also have custody of Tyler and Sean on two evenings per week, with the days to be Tuesdays and Thursdays unless agreed otherwise by the parties. On those weeks when father is off work for the entire day and can give mother reasonable notice in advance, father may exercise custody for the entire day and may request mother to move one of the days from Tuesday and Thursday to another weekday to accommodate the days father is off work. The ending time for the weeknight visitation shall be 7:00 p.m., with the starting time to be when father is off work or early in the morning if he has no work that day. c=, E. Mother shall have custody of Wendy on two evenings a week to be Monday and Wednesday subject to Wendy's gymnastics schedule and also subject to the parties modifying that arrangement to coincide with an effort by the r parties to keep all three children together when possible. Mother's time with Wendy shall be until 8:00 p.m. unless agreed otherwise by the parties. F. Unless agreed otherwise by the parties, exchange of custody shall be handled with the receiving parent picking up the other child at the beginning of the evening or custody period and the other parent who is getting the child or children back at the end of the evening or end of the weekend picking the children up at that point. This provision shall not apply for Monday mornings when the father shall deliver the children to daycare or school as applicable. 3. Father's counsel shall obtain a report from the counselor for the father that may be provided to legal counsel for the mother verifying the father is attending counseling and the number of times he has attended. Mother's counsel shall provide a similar report to the father's attorney concerning the status of mother's counseling. 4. The parties may modify or alter this Order as they agree. Absent an agreement, the order set forth above shall control. 5. Legal counsel for the parties shall have a telephone conference with the Custody Conciliator on Thursday, March 18, 2009, at 8:00 a.m. 6. This Order does not prejudice either party from raising any factual or legal issues at any subsequent hearing in this case or any proceedings in any related matters. BY THE COURT, lv? k Judge cc: ? ary A. Etter Dissinger, Esquire regory S. Hazlett, Esquire W l .es eylaLt LC a f aol og O u l' 0 L 83J 6001 SARAH B. DOUGLAS, Plaintiff VS. STANLEY E. DOUGLAS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2008-7373 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Wendy A. Douglas, born November 8, 1994, Tyler A. Douglas, born December 2, 2001, and Sean R. Douglas, born March 30, 2007. 2. A Conciliation Conference was held on February 13, 2009, with the following individuals in attendance: The mother, Sarah B. Douglas, who appeared with her counsel, Mary A. Etter Dissinger, Esquire, and the father, Stanley E. Douglas, who appeared with his counsel, Gregory S. Hazlett. 3. The parties were willing to agree upon a temporary Order based upon the recommendation of the Custody Conciliator at the Conference. The Conciliator recommends an Order in the form as attached. Date: February, 2009 Hubert X. Gil y, Esquire Custody C ciliator SARAH B. DOUGLAS, THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 08-7373 CIVIL TERM STANLEY E. DOUGLAS, IN DIVORCE Defendant/Respondent : PACSES CASE NO: 894110596 ORDER OF COURT - RESCHEDULE A CONFERENCE AND NOW, this 4th day of March 2009, upon consideration of the 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 April 1. 2009 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. This date replaces the prior conference date of February 4, 2009. 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 (6) 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 Date of Order: March 4. 2009 Copies mailed to: Petitioner Respondent Mary A. Dissinger, Esq. Gregory S. Hazlett, Esq. ?R. J. adds Conference Officer / 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 ( to %, SARAH B. DOUGLAS, Plaintiff/Petitioner VS. STANLEY E. DOUGLAS, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 08-7373 CIVIL TERM IN DIVORCE PACSES Case No: 894110596 ORDER OF COURT AND NOW, this 1 st day of April 2009, based upon the Court's determination that the Petitioner's monthly net income/earning capacity is $ 881.69 and the Respondent's monthly net income/earning capacity is $ 3,670.17, it is hereby ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit Two Hundred Twenty-seven and 00/100 Dollars ($ 227.00) per month payable weekly as follows: $ 200.00 per month for Alimony Pendente Lite and $ 27.00 per month on arrears. First payment due: in accordance with Respondent's pay schedule in the amount of $ 52.38 weekly. The effective date of the order is January 9, 2009. Arrears set at $ 541.23 as of April 1, 2009. 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, at 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: Sarah B. Douglas. 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 name with their PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. cc360 f I 1 The monthly support obligation includes cash medical support in the amount of $250 annually for unreimbursed medical expenses incurred for the obligee. Unreimbursed medical expenses of the obligee that exceed $250 annually shall be allocated between the parties. The party seeking allocation of unreimbursed medical expenses must provide documentation of expenses to the other no later than March 31" of the year following the calendar year in which the final medical bill to be allocated was received. The unreimbursed medical expenses are to be paid as follows: 50 % by the Respondent and 50% by the Petitioner. [X] Respondent [] Petitioner to provide medical insurance coverage. Within thirty (30) days after the entry of this order, the [] Petitioner [X] Respondent shall submit written proof that the medical insurance coverage has been obtained or that application for coverage has been made. Proof of coverage shall consist of, at a minimum of: 1) the name of the health care coverage provide(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. The Respondent is given credit in the amount of $210.00 for a direct payment to the Petitioner. This Order considers that the Respondent is maintaining the mortgage, taxes and insurance on the marital home. In addition, the Respondent is maintaining the vehicle insurance on the vehicle that is in the Petitioner's possession. This Order shall become final twenty (20) 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 Respondent Petitioner's Attorney Respondent's Attorney Mailed copies on: Apri12, 2009 to: Petitioner Respondent Mary A. Dissinger, Esq. Gregory S. Hazlett, Esq. BY THE COURT, lwv?ov Edgar B. ayley, J. DRO: R.J. Shadday ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 08-7373 CIVIL State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 04/01/09 Case Number (See Addendum for case summary) Employer/Withholder's Federal EIN Number SECCO INCORPORATED 1111 PRIMROSE AVE CAMP HILL PA 17011-6922 Employee/Obligor's Name (Last, First, MI) 453-19-6027 Employee/Obligor's Social Security Number 9289102071 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. $ 903.00 $ 100.00 $ 0.00 $ 0.00 $ 200.00 $ 27.00 $ 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? © yes Ono one-time lump sum payment for a total of $ i,230.00 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: $ 283.85 per weekly pay period. $ 615.00 per semimonthly pay period (twice a month) $ 567.69 per biweekly pay period (every two weeks) $ 1, 230.00 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. 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' AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCI SECURIT RDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: ?1111 CA DRO: R.J. Shadday Service Type M ONAB No,: 09 70-0154 OOriginal Order/Notice 517110656 OAmended Order/Notice 102 S 2009 OTerminate Order/Notice OOne-Time Lump Sum/Notice RE: DOUGLAS, STANLEY E. Edgar B. Bayley, Judge Form EN-028 Rev. 4 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS If checked you are required to provide a copy of this form to your em loyee. If your employee works in a state that is different from the state that issued this order, a copy must be provideto 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. 2321546720 THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : O THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 0 EMPLOYEE'S/OBLIGOR'S NAME: DOUGLAS , STANLEY E. EMPLOYEE'S CASE IDENTIFIER: 9289102071 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: LAST KNOWN PHONE NUMBER: NEW EMPLOYER'S NAME/ADDRESS: FINAL PAYMENT AMOUNT. 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: `!ou 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 5T P.O. BOX 320 CARLISLE PA 170"13 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 Service Type M OMB N- 0970-0154 Form EN-028 Rev. 4 Worker ID $ IATT r ADDENDUM Summary of Cases on Attachment Defendant/Obligor: DOUGLAS, STANLEY E. PACSES Case Number 517110656 PACSES Case Number 894110596 Plaintiff Name Plaintiff Name SARAH B. DOUGLAS SARAH B. DOUGLAS Docket Attachment Amount Docket Attachment Amount 00102 S 2009 $ 1,003.00 08-7373 CIVIL$ 227.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): SEAN R. DOUGLAS 03/30/07 TYLER A. DOUGLAS 12/02/01 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): 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 DOB DOB Addendum Form EN-028 Rev. 4 Service Type M OMB No. 0970-0154 Worker ID $IATT FLED-Off-CE OF iNc PPMONIOTARY 2009 APR -2 P 3= 10 GUS , x_ JUN Y J APR fl 2?1?tg?i SARAH B. DOUGLAS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW STANLEY E. DOUGLAS, NO. 2008-7373 Defendant IN CUSTODY PRIOR JUDGE: M. L. Ebert, Jr. COURT ORDER AND N OW, this S*Lday of , 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Court Room No. 5 of the Cumberland County Courthouse on the 1 b day of -,wlt{ , 2009 at ) .13Of m. At this hearing, the mother shall 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 the history of custody in this case, the issues currently before the Court, a summary of each parties position on these issues, a list of witnesses who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least fifteen days prior to the mentioned hearing date. 2. Pending further Order of this Court, this court's prior order of February 19, 2009 shall remain in place. BY THE COURT, cc: ?G=go.ry A. Etter Dissinger, Esquire S. Hazlett, Esquire ?a t yes MC-7 t LL I /s- /07 ?:n-yl N-As. ? N Judge M.L. Ebert, Jr. VI MMIA'S-IN N13 d 2s :6 WV s- AVa 60oz ?-?_?C?-Cldll? r SARAH B. DOUGLAS, Plaintiff VS. STANLEY E. DOUGLAS, Defendant PRIOR JUDGE: M. L. Ebert, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-7373 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. A conciliation conference was held with the conciliator and the attorneys via telephone conference and, based upon that conference, the conciliator recommends an order in the form as attached. Date: April ? ?) , 2009 Hubert X. Gil y, Esquire Custody C ciliator ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 05/22/09 Case Number (See Addendum for case summary) EmployerA,Vithholder's Federal EIN Number SECCO INCORPORATED 1111 PRIMROSE AVE CAMP HILL PA 17011-6922 453-19-6027 Employee/Obligor's Social Security Number 9289102071 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. $ $ $ 800.00 100.00 0.00 $ 0.00 $ 200.00 $ 27.00 $ 0.00 $ 0.00 for a total of $ per month in current child support per month in past-due child support per month in current medical support per month in past-due medical support per month in current spousal support per month in past-due spousal support per month for genetic test costs per month in other (specify) one-time lump sum payment 1,127.00 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: $ 260.08-- per weekly pay period. $ 563.50 per semimonthly pay period (twice a month) $ 520.15 per biweekly pay period (every two weeks) $ 1,127.00 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. 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 N E AND TEH?E PAACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL RI NU??1?7 )ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: DRO: R.J. Shadday Service Type M Arrears 12 weeks or greater? ® yes O no 08-7373 CIVIL 517110656 OOriginal Order/Notice 102 S 2009 @Amended Order/Notice OTerminate Order/Notice (:?)One-Time Lump Sum/Notice RE: DOUGLAS, STANLEY E. Employee/Obligor's Name (Last, First, MI) Edgar B. Bayley, Judge OMB No.: 0970-0154 Form EN-028 Rev. 4 Worker I D $ IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS if4heckefi you are required to provide a?opy of this form to yomaloyee. If yoyr employee works in a state that is di Brent Trom the state that issued this o er, a copy must be provi to your emp ogee even if the box is not checked 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employeelobligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each 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 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. 2321546720 THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : 0 THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 0 EMPLOYEE'S/OBLIGOR'S NAME: DOUGLAS, STANLEY E. EMPLOYEE'S CASE IDENTIFIER: 9289102071 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. AntWiscrimination: 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 employeelobligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (CCPA) 0 5 U.S.C. 1673 (b)); or 2) the amounts allowed by the State or Tribe of the employee's/obligor's principal place of employment. Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes, Social Security taxes, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is supporting another family and 60% of the disposable income if the obligor is not supporting another family.However, that 50% limit is increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State, you may deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section. Arrears greater than 12 weeks : If the Order Information does not indicate whether the arrears are greater than 12 weeks, then the employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of the CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amounts paid for health care premiums in determining disposable income and applying appropriate withholding limits. 10. Additional info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Send Termination Notice and other correspondence to: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST 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 Service Type M OMB No.: 0970-0154 Form EN-028 Rev. 4 Worker ID $IATT ! , 4 ADDENDUM Summary of Cases on Attachment Defendant/Obligor: DOUGLAS, STANLEY E. PACSES Case Number 517110656 Plaintiff Name SARAH B. DOUGLAS Docket Attachment Amount 00102 S 2009 $ 900.00 Child(ren)'s Name(s): DOB SEAN R. DOUGLAS 03/30/07 TYL,Ek A. DOUGLAS i2/0?/0I PACKS Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Service Type M Addendum OMB No.: 0970-0154 PACSES Case Number 894110596 Plaintiff Name SARAH B. DOUGLAS Docket Attachment Amount 08-7373 CIVIL$ 227.00 Child(ren)'s Name(s): DOB PACKS Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Form EN-028 Rev. 4 Worker I D $ zATT FLI LIE'U' jE T r., a - SARAH B. DOUGLAS, IN THE COURT OFCOMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. STANLEY E. DOUGLAS, DEFENDANT NO. 08-7373 CIVIL ORDER OF COURT AND NOW, this 22nd day of June, 2009, upon consideration of the information received from counsel that the parties are in agreement to follow the Order of Court dated February 19, 2009, IT IS HEREBY ORDERED AND DIRECTED that the hearing scheduled for July 10, 2009, at 1:30 p.m. is cancelled. By the Court, M. L. Ebert, Jr., ` J. Mary Etter Dissinger, Esquire Attorney for Plaintiff Gregory Hazlett, Esquire .eta Attorney for Defendant bas `-?- OF 23, ±; _, ; Fit jr, ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 08-7373 CIVIL OOriginal Order/Notice State Commonwealth of Pennsylvania 517110656 102 S 2009 @Amended Order/Notice Co./City/Dirt. of CUMBERLAND Date of Order/Notice 09/01/09 OTerminate Order/Notice Case Number (See Addendum for case summary) OOne-Time Lump Sum/Notice RE: DOUGLAS, STANLEY E. Employer/Withholder's Federal EIN Number Employee/Obligor's Name (Last, First, MI) 453-19-6027 Employee/Obligor's Social Security Number SECCO INCORPORATED 9289102071 1111 PRIMROSE AVE Employee/Obligor's Case Identifier CAMP HILL PA 17011-6922 (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. $ 903.00 per month in current child support $ loo. oo per month in past-due child support Arrears 12 weeks or greater? Oyes O no $ 0.00 per month in current medical support $ o. oo per month in past-due medical support $ 200.00 per month in current spousal support $ 27.00 per month in past-due spousal support $ 0.00 per month for genetic test costs $ o . oo per month in other (specify) $ one-time lump sum payment for a total of $ 1,230.00 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: $ 283.85 per weekly pay period. $ 615.00 per semimonthly pay period (twice a month) $ 567.69: per biweekly pay period (every two weeks) $ 1, 230.00 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 DEFENDA AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOC SECURIT A?8 ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: 'r G _ DRO: R.J. Shadday Service Type M OMB No.: 0970-0154 Form EN-028 Rev.5 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS E] If hecke? you are requiredi to provide a opy of this form to your mployee. If yo r employee works in a state tha is d1 erent from the state that ssued this order, a copy must be provi?ed to your emproyee even if the box is not chec?ed. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one 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. 2321546720 THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : O THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 0 EMPLOYEE'S/OBLIGOR'S NAME: DOUGLAS, STANLEY E. EMPLOYEE'S CASE IDENTIFIER: 9289102071 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) 0 5 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.childsuppoMstate.pa.us Page 2 of 2 Form EN-028 Rev.5 Service Type M OMB No.: 0970-0154 Worker I D $ IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: DOUGLAS, STANLEY E. PACKS Case Number 517110656 Plaintiff Name SARAH B. DOUGLAS Docket Attachment Amount 00102 S 2009 $ 1,003.00 Child(ren)'s Name(s): DOB SEAN R. DOUGLAS 03/30/07 TYLX,R A. DOUGLAS 12/02/02 PACKS Case Number 894110596 Plaintiff Name SARAH B. DOUGLAS Docket Attachment Amount 08-7373 CIVIL$ 227.00 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 Rev.5 Service Type M OMBNo.:0970.0154 Worker ID $IATT OF r 2009 SEE -2 PIN 2: it CU ??,s '? t t ? r? Sarah B. Douglas, IN THE COURT OF COMMON PLEAS Plaintiff OF Cumberland County OF PENNSYLVANIA VS. . CIVIL ACTION LAW - CUSTODY Stanley E. Douglas, Defendant NO. 2008-7373 PETITION TO MODIFY CUSTODY 1. Plaintiff is Sarah B. Douglas, mother of the children , residing at 1827 West Lisburn Road, Carlisle, Cumberland County, Pennsylvania 17015. 2. Defendant is Stanley E. Douglas, father of the children, residing at 1330 Williams Grove Road, Mechancisburg, Cumberland County, Pennsylvania 17055. 3. Custody of the minor children, Wendy A. Douglas (11/8/94), Tyler A. Douglas (12/2/01), Sean R. Douglas (3/30/07), was awarded as follows: A. Shared legal custody to both parties. B. Primary physical custody of Tyler and Sean was granted to Plaintiff with periods of temporary custody granted to Defendant, and primary physical custody of Wendy was granted to Defendant with periods of partial physical custody granted to Plaintiff by Order of Court dated February 19,2009. (See copy of Order attached hereto as Exhibit "A".) 4. Plaintiff seeks to modify the current custody arrangement because: A. The Defendant has, since the entry of the order, neglected the physical needs of the children such that Sean's diaper has not be changed appropriately by father or frequently enough and he has ended up with leg burns from the urine leaking out of his diaper. B. The Defendant has emotionally abused all three children since the entry of the last order, and Children and Youth, particularly case worker Shiloh Hagerty, has reported to Plaintiff's mother that this is the worst case of emotional abuse that the agency has seen in a child this young, referring to Sean. C. Children and Youth has recommended that all three children be in therapy or counseling immediately, and while The Defendant has indicated he will cooperate he has not made efforts whatsoever to schedule the children and has refused to provide his medical insurance information to Plaintiff so that she may schedule the counseling sessions for the benefit of the children. D. Tyler needs a physical and a dental examination for school and because Defendant refuses to provide the health insurance card to Plaintiff she is unable to obtain the appropriate physicals. E. Plaintiff has repeatedly requested that Defendant contact his insurer and request a second set of cards for purposes of obtaining medical coverage for the children. He has refused to do so since the time of the Support Conference this past spring, the children have needed medical care and Plaintiff has taken them, and the medical provider has been unable to obtain payment from the insurance company, leading Plaintiff to pay not only the co-pay but the amount that is uncovered by insurance because insurance cards have not been made available to the medical care providers. F. The Defendant has used the children as a pawn in the divorce action to punish Plaintiff for leaving him. WHEREFORE, Plaintiff requests the Court to modify custody of the children as follows: Primary physical custody of all children to Plaintiff with supervised periods of partial physical custody with Defendant. Respectfully Submitted: DISSINGER AND DISSINGER By. Mary A. tter Dissinger Attorney for Plaintiff Supreme Court I.D. #27736 28 North Thirty-Second Street Camp Hill, PA 17011 (717) 957-2840 VERIFICATION I, Sarah B. Douglas, 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 to authorities. i , GZ , Sarah B. Douglas Sarah B. Douglas, IN THE COURT OF COMMON PLEAS Plaintiff OF Cumberland County OF PENNSYLVANIA VS. CIVIL ACTION LAW - CUSTODY Stanley E. Douglas, Defendant NO. 2008-7373 CERTIFICATE OF SERVICE I, Mary A. Etter Dissinger, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon the attorney for Stanley E. Douglas, by First Class United States mail addressed as follows: Gregory S. Hazlett 7 West Main Street Mechanicsburg, PA 17055 Date:__ `17 Mary A. Etter Dissinger FEB " 8 200 61 SARAH B. DOUGLAS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW STANLEY E. DOUGLAS, NO. 2008-7373 Defendant IN CUSTODY COURT ORDER AND NOW, this JTNay of February, 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that the following TEMPORARY Custody Order is entered: The mother, Sarah B. Douglas, and the father, Stanley E. Douglas, shall enjoy shared legal custody of Wendy A. Douglas, born November 8, 1994, Tyler A. Douglas, born December 2, 2001, and Sean R. Douglas, born March 30, 2007. 2. Physical custody shall be handled as follows: A. Father shall have primary physical custody of Wendy with mother having periods oftemporary physical custodyof Wendyon alternating weekends and on weekdays as set forth below. B. Mother shall have primary physical custody of Tyler and Sean with father having periods of temporary physical custody of Tyler and Sean on weekends and weekdays as set forth below. C. The parties shall alternate custody of all three children on alternating weekends such that the three children are together in one household, with the alternating weekends being from Friday at 5:00 p.m. until Monday morning. D. Father shall also have custody of Tyler and Sean on two evenings per week, with the days to be Tuesdays and Thursdays unless agreed otherwise by the parties. On those weeks when father is off work for the entire day and can give mother reasonable notice in advance, father may exercise custody for the entire day and may request mother to move one of the days from Tuesday and Thursday to another weekday to accommodate the days father is off work. The ending time for the weeknight visitation shall be 7:00 p.m., with the starting time to be when father is off work or early in the morning if he has no work that day. E. Mother shall have custody of Wendy on two evenings a week to be Monday and Wednesday subject to Wendy's gymnastics schedule and also subject to the parties modifying that arrangement to coincide with an effort by the EXHIBIT parties to keep all three children together when possible. Mother's time with Wendy shall be until 8:00 p.m, unless agreed otherwise by the parties. F. Unless agreed otherwise by the parties, exchange of custody shall be handled with the receiving parent picking up the other child at the beginning of the evening or custody period and the other parent who is getting the child or children back at the end of the evening or end of the weekend picking the children up at that point. This provision shall not apply for Monday mornings when the father shall deliver the children to daycare or school as applicable. 3. Father's counsel shall obtain a report from the counselor for the father that may be provided to legal counsel for the mother verifying the father is attending counseling and the number of times he has attended. Mother's counsel shall provide a similar report to the father's attorney concerning the status of mother's counseling. 4. The parties may modify or alter this Order as they agree. Absent an agreement, the order set forth above shall control. 5. Legal counsel for the parties shall have a telephone conference with the Custody Conciliator on Thursday, March 18, 2009, at 8:00 a.m. 6. This Order does not prejudice either party from raising any factual or legal issues at any subsequent hearing in this case or any proceedings in any related matters. BY THE COURT, Judge cc: Mary A. Etter Dissinger, Esquire Gregory S. Hazlett, Esquire y rrt 1 ? 7 ?!"tl v it IZF RED...'; OF THEE r r,(?Y 20U, R SLp I 1 pIN I : S r/,Vr a4 AA- /.30&? - 3360jr SARAH B. DOUGLAS IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. STANLEY E. DOUGLAS DEFENDANT 2008-7373 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, October 02, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, October 16, 2009 at 8:30 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. 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/ Hubert X. Gilroy, Esq. 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 OF FILW--O; FjGE t)r THE PROT ';'NOTARY 2009 OCT -2 PM 3: 12 CUMB: FEr'}'?L4'ru^d1A' AP .2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION SARAH B. DOUGLAS ) Docket Number 08-7373 CIVIL Plaintiff ) Vs. ) PACSES Case Number 894110596 STANLEY E. DOUGLAS ) Defendant ) Other State ID Number PETITION FOR MODIFICATION OF AN EXISTING SUPPORT ORDER 1. The petition of SARAH B. DOUGLAS respectfully represents that on APRIL 1, 2009 , an Order of Court was entered for the support of SARAH B. DOUGLAS A true and correct copy of the order is attached to this petition. Service Type M Form OM-501 Worker ID 21203 DOUGLAS V. DOUGLAS PACSES Case Number: 894110596 2. Petitioner is entitled to increase O decrease O termination O reinstatement O other of this Order because of the following material and substantial change(s) in circumstance: c? of r?? (? ?t ; nS v? cxn c? WHEREFORE, Petitioner requests that the Court modify the existing order for support. Q? tisS-In e.r Petitioner Attorney for Petitioner I verify that the statements made in this complaint 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. 10la I0g Date Petitioner Page 2 of 2 Form OM-501 Service Type M Worker ID 21203 r F T? R'E P ;? `' n.RY 2009 O,T 12 Aid 8: u SARAH B. DOUGLAS, THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 08-7373 CIVIL TERM STANLEY E. DOUGLAS, IN DIVORCE Defendant/Respondent : PACSES CASE NO: 894110596 ORDER OF COURT AND NOW, this 12th day of October, 2009, a petition has been filed against you, Stanley E. Douglas, 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 November 10, 2009 at 10:30 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. Copies mailed to: Petitioner Respondent Mary A. Etter Dissinger, Esq. Gregory S. Hazlett353106468, Esq. Date of Order: October 12, 2009 BY THE C RT, v N C 1 Edgar B. Bayley, Judge 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 OF THE P TOTARY 2039 OCT 12 PA 2: L, l ?..,`,;; y ?•{# ?j 1, OCT 19 2009 67 SARAH B. DOUGLAS, Plaintiff VS. STANLEY E. DOUGLAS, Defendant NO. 2008-7373 IN CUSTODY COURT ORDER AND NOW, this 11 day of October, 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW A. The parents shall not allow any of the children to have any additional body piercing or tattoos without the mutual consent of both parents which consent shall be given in writing. B. Both parents shall advise the other parent with respect to any counseling the children are receiving, this advice to include the name, address and phone number of any counselor who may be involved with the children. Additionally, each parent must be notified in advance with respect to the date and time of any counseling sessions that are scheduled. 1. A hearing is scheduled in Courtroom NoA of the Cumberland County Courthouse on the day of , 201 at q'? D ,4 , , in. At this hearing, the Mother shall 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 the history of custody in this case, the issues currently before the Court, a list of witnesses who will be called to testimony on behalf of each party and a summary of the anticipated testimony of each witness. This Memorandum shall be filed at least five days prior to the mentioned hearing date. 2. Pending further Order of this Court, this Court's prior Order of February 19, 2009, shall remain in place subject to the following additions: C. In the event a parent has custody and is for whatever reason not planning on keeping the child overnight pursuant to the schedule, the custodial parent in that situation must contact the other parent to offer the other parent the opportunity to keep the child overnight. This provision relates primarily to weekdays when the children are in school and does not prohibit any of the older children from spending time with their friends on the weekend for a sleep over. BY THE COURT, M. L. Ebert, Jr., Judge cc: ?ary A. Etter Dissinger, Esquire Gregory S. Hazlett, Esquire C/ 2.0 OT SARAH B. DOUGLAS, Plaintiff vs. STANLEY E. DOUGLAS, Defendant Prior Judge: The Honorable M. L. Ebert, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2008-7373 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Wendy A. Douglas, born November 8, 1994 Tyler A. Douglas, born December 2, 2001 Sean R. Douglas, born March 30, 2007 2. A Conciliation Conference was held on October 16, 2009, with the following individuals in attendance: The mother, Sarah B. Douglas, who appeared with her counsel, Mary A. Etter Dissinger, Esquire, and the father, Stanley E. Douglas, with his counsel, Gregory S. Hazlett, Esquire. 3. The parties reached a temporary agreement that was incorporated into a Court Order on February 19, 2009, which, essentially, gives Father primary custody of Wendy and Mother primary custody of Tyler and Sean. The Order also provides for the parents to have periods of temporary custody with all children. 4. Mother has now petitioned to modify the Order making various allegations with respect to Father's handling of the children. The parties were unable to reach an agreement at the Conciliation Conference and a hearing is needed. The Conciliator recommends an Order in the form as attached. Date: October, 2009 6 Hubert X. Gi oy, Esquire Custody Conciliator O FILE D- 0--f O F THE 2009OCT 20 A-M 8- 5 i Sarah B. Douglas, Plaintiff VS. Stanley E. Douglas, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA : CIVIL ACTION : NO. 08-7373 CIVIL TERM : IN DIVORCE Petition for Special Relief Requesting a Court Order Directing the Sale of the Marital Residence And now comes Sarah B. Douglas by and through her attorneys, Dissinger & Dissinger, and requests the court to direct the sale of the marital residence and in support of the petition avers as follows: 1. Petitioner is Sarah B. Douglas, who resides at 1827 W. Lisburn Rd., Carlisle, Cumberland County, Pennsylvania, 17015 2. Respondent is Stanley E. Douglas, who resides 1330 Williams Grove Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff filed the divorce action to the above docket December 19, 2008. 4. The parties have been separated since November 23, 2008. 5. The Respondent, Stanley E. Douglas, resides in the marital residence at 1330 Williams Grove Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 6. On April 1, 2009 a support order was entered with an effective date of February 9, 2009, directing Stanley Douglas to pay child support and granting him a deviation on the child support based up on "husband maintaining the mortgage, taxes and insurance on the marital home and insurance on wife's vehicle." (See copy of order and conference summary attached as exhibit A.) I7. Since that date, Respondent has not paid the mortgage. 8. The property is encumbered from One West Bank (See exhibit B.). 9. The principle balance due on the loan is $267,761.83. (See exhibit B.) 10. The monthly interest and principle payment on the mortgage is $1,801.01. (See exhibit B.) 11. Past due payments through September 18, 2009 were $8,980.83. (See exhibit B.) I12. There are unpaid late fees of $447.82 due and owing on the delinquent mortgage. (See exhibit B.) 13. The mortgage lender, OneWest Bank, advanced some funds in the amount of $33.00 for a purpose unknown to Petitioner herein. (See exhibit B.) 14. As of October 15, 2009 because of non-payment there is a balance due and owing of almost $10,000.00 over and above the principle balance, which was due at the time of the support order. (See exhibit B.) 15. Petitioner has asked husband, through counsel, to agree to list this property for sale. 16. Respondent has refused to enter into an agreement to list the real estate for sale. 17. Respondent has attempted to refinance this property and has been denied the privilege of refinancing; he has been denied the right to reduce payments; he has been unable to make any payments on account of the mortgage. 18. Petitioner believes that the Respondent wants to utilize his 401K to bring the mortgage current, which Petitioner opposes. 19. Even if the Respondent brings the mortgage current by liquidating other marital assets, which Petitioner herein is entitled to, the Respondent will not, thereafter, be able to make the payments on his mortgage from his ordinary income since his income has only gone down since April 1, 2009. 20. Petitioner believes that in the interest of preserving the marital estate, to the extent that it can be preserved, this property should be sold. 21. Petitioner is fearful that the property will go into foreclosure and thereby impact her ability to obtain financing to acquire another home after the divorce is final. I22. Petitioner would like to list the real estate with Tracy Georgeff of Keller Williams Realty. (WHEREFORE, Petitioner requests the court to enter an order directing the sale of the marital residence Respectfully Submitted: DISSINGER AND DISSINGER BY: Mary A. tter Dissinger Attorney for Plaintiff Supreme Court I.D. #27736 28 North Thirty-Second Street Camp Hill, PA 17011 (717) 957-2840 VERIFICATION I, Sarah B. Douglas, 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 to authorities. vfJf ? )00 / ...??i Sara B. Douglas/?? In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION SARAH B. DOUGLAS ) Order Number 00102 5 2009 Plaintiff ) vs. ) PACSES Case Number 517110656 STANLEY E. DOUGLAS ) Docket Number 00102 S 2009 Defendant ) Other State ID Number ORDER OF COURT Q Final ® Interim O Modified AND NOW, 1ST DAY OF APRIL, 2009 based upon the Court's determination that the Payee's monthly net income is $ 881.69 and the Payor's monthly net income is $ 3, 670.17 , it is hereby ordered that the Payor pay to the Pennsylvania State Collection and Disbursement Unit ONE THOUSAND THREE AND XX/100 Dollars ($1, 003.00 ) a month payable WEEKLY as follows: first payment due NEXT PAY DATE. The effective date of the order is 02/09/09 . Arrears set at $ 2 6 9 5 . 16 as of APRIL 1, 2009 are due in full IMMEDIATELY. All terms of this Order are subject to collection and/or enforcement by contempt proceedings, credit bureau reporting, tax refund offset certification, driver's license revocation, and the freeze and seize of financial assets. These enforcement/collection mechanisms will not be initiated as long as obligor does not owe overdue support. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all the means listed above. For the Support of: Name SEAN R. DOUGLAS TYLER A. DOUGLAS EXHIBIT A Birth Date 03/30/07 12/02/01 Form OE-518 Rev.6 Service Type M Worker ID 21005 DOUGLAS V. DOUGLAS The defendant owes a total of $1, 003.00 PACSES Case Number: 517110656 per month payable WEEKLY ; $ 903.00 for current support and $ 1 o o . o o for arrears. The defendant must also pay fees/costs as indicated below. This order is allocated and monies are to be applied as follows: Frequency Codes: I =One Time M =Monthly Payment Amount / Frequency Debt Type Description $451.50 / M CS ALLOC/MED $451.50 / M CS ALLOC/MED $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / Beneficiary SEAN R. DOUGLAS TYLER A. DOUGLAS Said money to be turned over by the Pa SCDU to: SARAH B. DOUGLAS . 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. Page 2 of 4 Form OE-518 Rev.6 Service Type M Worker ID 21005 DOUGLAS V. DOUGLAS PACSES Case Number: 517110656 The monthly support obligation includes cash medical support in the amount of $250 annually for unreimbursed medical expenses incurred for each child and/or spouse. Unreimbursed medical expenses of the obligee or children that exceed $250 annually shall be allocated between the parties. The party seeking allocation of unreimbursed medical expenses must provide documentation of expenses to the other party no later than March 31st of the year following the calendar year in which the final medical bill to be allocated was received. The unreimbursed medical expenses are to be paid as follows: a 1. o o % by defendant and 19. 00 % by plaintiff.0 Defendanto Plaintiffo Neither party to provide medical insurance coverage. Within thirty (30) days after the entry of this order, the O Plaintiff ® Defendant shall submit to the person having custody of the child(ren) 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 8) five copies of any claim forms. Other Conditions: -THIS ORDER CONSIDERS THAT DEFENDANT HAS THE CARE AND CUSTODY OF ONE CHILD FROM A PREVIOUS RELATIONSHIP. -DEFENDANT IS TO MAKE DIRECT PAYMENT OF 25% OF ANY AND ALL NET BONUS(ES) TO PLAINTIFF, WITHIN SEVEN DAYS UPON RECEIPT OF SAID BONUS, WITH VERIFICATION OF SAID BONUS. DEFENDANT OWES PLAINTIFF $260.40 FOR THE BONUS THAT WAS PAID ON FEBRUARY 13, 2009 AND THAT AMOUNT WILL BE ADDED TO THE CHILD SUPPORT ARREARS. --COMMENCING IN THE TAX YEAR 2009, DEFENDANT CAN CLAIM ONE CHILD, TYLER, AS A DEPENDENCY TAX EXEMPTION AND PLAINTIFF WILL EXECUTE THE WAIVER REQUIRED BY THE IRS CODE, 26 U.S.C.A. ss 152(e) IN A TIMELY MANNER. DEFENDANT IS TO PAY THE COURT COSTS OF $35.00 WITHIN TEN DAYS FROM THIS DATE AND IS TO BE MADE PAYABLE TO CUMBERLAND COUNTY DRS, P.O. BOX 320, CARLISLE, PA 17013. Defendant shall pay the following fees: Fee Total Fee Description $ 10.00 for JUDICIAL COMPUTER FEE $ 25.00 for COLLECTION FEE $ 0.00 for $ 0.00 for $ 0.00 for Payment Frequency Payable at $ 0 . 00 per ONE TIME Payable at $ 0 . 00 per ONE TIME Payable at $ o . o0 per Payable at $ 0. oo per Payable at $ 0 . oo per Service Type M Page 3 of 4 Form OE-518 Rev.6 Worker ID 21005 DOUGLAS V. DOUGLAS PACSES Case Number: 517110656 IMPORTANT LEGAL NOTICE PARTIES MUST WITHIN SEVEN DAYS INFORM THE DOMESTIC RELATIONS SECTION AND THE OTHER PARTIES, IN WRITING, OF ANY MATERIAL CHANGE IN CIRCUMSTANCES RELEVANT TO THE LEVEL OF SUPPORT OR THE ADMINISTRATION OF THE SUPPORT ORDER, INCLUDING, BUT NOT LIMITED TO, LOSS OR CHANGE OF INCOME OR EMPLOYMENT AND CHANGE OF PERSONAL ADDRESS OR CHANGE OF ADDRESS OF ANY CHILD RECEIVING SUPPORT. A PARTY WHO WILLFULLY FAILS TO REPORT A MATERIAL CHANGE IN CIRCUMSTANCES MAY BE ADJUDGED IN CONTEMPT OF COURT, AND MAY BE FINED OR IMPRISONED. PENNSYLVANIA LAW PROVIDES THAT ALL SUPPORT ORDERS SHALL BE REVIEWED AT LEAST ONCE EVERY THREE (3) YEARS IF SUCH REVIEW IS REQUESTED BY ONE OF THE PARTIES. IF YOU WISH TO REQUEST A REVIEW AND ADJUSTMENT OF YOUR ORDER, YOU MUST DO THE FOLLOWING: CALL YOUR ATTORNEY. AN UNREPRESENTED PERSON WHO WANTS TO MODIFY (ADJUST) A SUPPORT ORDER SHOULD CONTACT THE DOMESTIC RELATIONS SECTION. ALL CHARGING ORDERS FOR SPOUSAL SUPPORT AND ALIMONY PENDENTE LITE, INCLUDING UNALLOCATED ORDERS FOR CHILD AND SPOUSAL SUPPORT OR CHILD SUPPORT AND ALIMONY PENDENTE LITE, SHALL TERMINATE UPON DEATH OF THE PAYEE. A MANDATORY INCOME ATTACHMENT WILL ISSUE UNLESS THE DEFENDANT IS NOT IN ARREARS IN PAYMENT IN AN AMOUNT EQUAL TO OR GREATER THAN ONE MONTH'S SUPPORT OBLIGATION AND (1) THE COURT FINDS THAT THERE IS GOOD CAUSE NOT TO REQUIRE IMMEDIATE INCOME WITHHOLDING; OR (2) A WRITTEN AGREEMENT IS REACHED BETWEEN THE PARTIES WHICH PROVIDES FOR AN ALTERNATE ARRANGEMENT. UNPAID ARREARAGE BALANCES MAY BE REPORTED TO CREDIT AGENCIES. ON AND AFTER THE DATE IT IS DUE, EACH UNPAID SUPPORT PAYMENT SHALL CONSTITUTE, BY OPERATION OF LAW, A JUDGMENT AGAINST YOU, AS WELL AS A LIEN AGAINST REAL PROPERTY. IT IS FURTHER ORDERED that, upon payor's failure to comply with this order, payor may be arrested and brought before the Court for a Contempt hearing; payor's wages, salary, commissions, and/or income may be attached in accordance with law; this Order will be increased without further hearing by o % a month until all arrearages are paid in full. Payor is responsible for court costs and fees. Copies delivered to parties . APR 0 2 2009 Date Consented: Plaintiff Defendant 1ST DAY OF APRIL, 2009 DRO: R.J. Shadday Service Type M Plaintiff's Attorney Defendant's Attorney BY T O T• Date 9dgar B. Bayley, Judge Page 4 of 4 Form OE-518 Rev.6 Worker ID 21005 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION PACSES Case Number: 517110656 Docket Number: 00102 S 2009 Other State ID Number: Please note: Ail correspondence must include the PACSES Case Number. APRIL 1, 2009 SUMMARY OF TRIER OF FACT Plaintiff Information SARAH B. DOUGLAS Address: 1204 BRANDT RD MECHANICSBURG PA 17055-9772 Employer: MARY LOREMAN' S GROUP DAYCARE HOME 1330 WILLIAMS GROVE ROAD MECHANICSBURG, PA 17055 Attorney: MARY A. ETTER DISSINGER, ESQ. Defendant Information STANLEY E. DOUGLAS Address: 1330 WILLIAMS GROVE RD MECHANICSBURG PA 17055-5785 Employer: SECCO INCORPORATED 1111 PRIMROSE AVE CAMP HILL PA 17011-6922 Attorney: GREGORY S. HAZLETT, ESQ. ® Complaint for Support 02/09/09 O Petition for Modification Filed El Other Reason for Conference: 1/9/09: WIFE FILED FOR APL UNDER C#894110597. WIFE FILED FOR SPOUSAL SUPPORT AND CHILD SUPPORT FOR TWO CHILDREN ON 2/9/09. HUSBAND DENIES ENTITLEMENT FOR SPOUSAL SUPPORT AND DRO PROCEEDS ON APL. Dependent(s) SEAN R. DOUGLAS 03/30/07 - -3138 TYLER A. DOUGLAS 12/02/01 - -5195 Current Order: $ 0.0 0 / per month NEW ACTION Form CM-022 Rev.3 Service Type M Worker ID 21005 DOUGLAS V. DOUGLAS Plaintiff Information PACSES Case Number: 517110656 Defendant Information Current Income: $230.00/W GROSS FOR AVG 23 HRS WK $881.69/M NET $1062.09/W GROSS YTD - 2/09 BONUS $3670.17/M NET Tax Return: H-2 H-3 WIFE CAN CLAIM 1C, SEAN HUSBAND CAN CLAIM 1C, TYLER AND HE CLAIMS ].C, WENDY, FROM A PREVIOUS RELATIONSHIP Medical Coverage: HUSBAND HAS COVERAGE THROUGH HIS $133.10/WK FOR FIVE PEOPLE EMPLOYMENT Child Care/Tuition: STATES THAT SHE PAYS HER MOTHER $150/W IN LIEU OF RENT FOR HERSELF & 2C Additional Obligations: CARE & CUSTODY OF 1C, WENDY, 14 YRS MORTGAGE=$1779/M TAXES= $171/M HOMEOWNER'S INS= $65/M PLTF VEH INS= $76/M Other Information: 1/10/02: PARTIES WERE MARRIED THERE ARE TWO CHILDREN OF THE MARRIAGE TYLER IS 7 YRS & SEAN IS 2 YRS. 12/19/08: WIFE FILES FOR A DIVORCE 118/09: PARTIES SEPARATED 1/9/09: WIFE FILES FOR APL **** 2/9/09: WIFE FILES FOR SPOUSAL SUPPORT AND CHILD SUPPORT FOR THE 2C HUSBAND DENIES ENTITLEMENT DUE TO WIFE ABANDONING THE MARITAL HOME WIFE RESIDES W/ HER MOTHER ANp HER MOTHER OWNS AND OPERATES A CHILD CARE CENTER. WIFE IS EMPLOYED BY HER MOTHER AND IS PAID $10/HR AND IS AVERAGING 23 HRS PER WEEK. THF, CHILD CARE CENTER IS LICENSED TO CARE FOR 12 CHILDREN THERE IS ONE OTHER EMPLOYEE EMPLOYED BY HER MOTHER H R HRS VARY DUE TO THE NUMBER OF CHILDREN THAT ARE PRESENT HUSBAND RESIDES IN THE MARITAL HOME W/ ONE 14 YR OLD CHILD THE MARITAL HOME IS OWNED BY WIFE'S PARENTS AND THE PARTIES THE DEED IN IN THE FOUR NAMES THE MORTGAGE IS THE PARTIES' NAME ONLY THE MORTGAGE WAS REFINANCED IN 2007 FOR Page 2 of 3 Service Type M Form CM-022 Rev.3 Worker ID 21005 DOUGLAS V- DOUGLAS PACSES Case Number: 517110656 Other Information (continued): $35,000.00 IN BACK CHILD SUPPORT OWED BY THE DEFENDANT FOR ANOTHER CHILD THAT IS EMANCIPATED AND $5-7,000 IN CREDIT CARD DEBT BY WIFE. HUSBAND RECVD A BONUS OF $1270.02 ON 2/13/09. DRO RECOMMENDS THAT HE PAY 25% OF ANY NET BONUS. HE WOULD OWE WIFE $260.40 AND THAT AMT IS ADDED TO THE CHILD SUPPORT ARREARS Facts Agreed Upon: PARTIES HAD AN AGREEMENT FOR APL OF $200/M & TRIED TO AGREE ON A CHILD SUPPORT AMT THAT DID NOT COME TO FURCATION HUSBAND MADE A DIRECT PAYMENT OF $210.00 TO WIFE. DRO CREDIT'S IT TO THE APL CASE. Facts in Dispute and Contentions with Respect to Facts in Dispute: WIFE'S EARNING CAPACITY. HUSBAND REQUESTS TO CLAIM BOTH CHILDREN OF THIS ORDER FOR TAX PURPOSES DRO GRANTS ONE CHILD, TYLER. Guideline Amount: $ 902.94 / MONTH DRS Recommended Amount: $ 9 0 3.0 0 / MONTH DRS Recommended Order Effective Date: 02/09/09 Parties to be Covered by Recommended Order Amount: TWO CHILDREN ****APL CALL = $322.96/M.... DRO RECOMMENDS $200/M Guideline Deviation: ® YES or ONO Reason for Deviation: DEVIATION ON APL DUE TO HUSBAND MAINTAINING THE MORTGAGE, TAXES, & INSURANCE ON THE MARITAL HOME 7 INSURANCE ON WIFE'S VEHICLE. Submitted by: R. J. SHADDAY Date Prepared: APRIL 1, 2009 Page 3 of 3 Form CM-022 Rev.3 Service Type M Worker ID 21005 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION SARAH B. DOUGLAS ) Docket Number 00102 5 2009 Plaintiff ) vs. ) PACSES Case Number 517110656 STANLEY E. DOUGLAS ) Defendant ) Other State ID Number NOTICE OF RIGHT TO REQUEST A HEARING The parties are hereby advised that they have until APRIL 22, 2009 to request a hearing de novo before the Court. File requests in person at: DOMESTIC RELATIONS SECTION 13 NORTH HANOVER STREET CARLISLE PA 17013 or mail to: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 Form OE-572 Service Type M Worker ID 21205 OneWest Bank 10/15/2009 11:43:55 AM PAGE 2/002 Fax Server M MI M 0 ¦ ym PrimaryRIdMNUlber: (717) 236-1142 Account Inforrre00n a%of 09/14/09 >M00110ery RaneN4hber: ldtnNuMer 2009023112 Property Address: 1330 WIWAMSGFKMFO, Inleres Hate Rtncipal Balance 7.110041 $267,761.63 MECHANICSBU. FA 17066 Escrow eslan® $ .00 Unepplied Funds $ .00 061617 FE FundsAWanOedby IMS (1.2) $33.00 OBNNDXCT FYindpel Paid YTD 926.44 #66021139990010954 interest paid yro $0$3 77.47 AoporlyTaxes ft aYTD $ .ass Hazard tneurance Paid YD $ .00 STANLEY ODUaLAe SARAN DDUDUS 1aS0 NMLI ANS OROVE ROAD NaehanleabW" PA 17056 Fp statement IpNtWOM, III"" call Customer Service at 1.000.701.73*9 t ttlollM Pietlre.a16 Oetleee RincipalanatorInterest Escrow $1.401.01 Your Account is Optional Prod uds(2) $ . oo Past Doe. $ ,00 .00 v PaMentAe4suet 91.401.01 Pas Due PeYmenl(s) ?y1714 , WP91aMWAPer 11eea.r sw.ng y4M. psy Total l7,aYhlahtSDue $1.9110.113 bed-Pdsabag Urcaid EaICCWOSO 1447.83 to"two reepA Returned Payment Fees $ .00 4 A4uQr 4er 4'41911e54uPa Other UnpaidChergae(2) 4 .00 r."& FundsAdvanceobylMS(1.2) $33.00 3 nreatesssuAvAL " TAM Anaamot Dug $9,461.66 Law to. After 10/16/09 plossa pay: (3) 9!.551.71 1ete1 P art deslt9it/Deferred interest 031/76/09 nee Assessment l0.05- ONLINE ACCESS TO YOUR LOAN 1 NFORNIATWN IS JUST A LUCK AWAYI To find out more, see the back of this statement. DemGh iM9 portion b,d i4rurn wnh YOOr 0.. mode aDYDEk tU IndymoC e.,nk. Neas4 write Your IDOL -Der an your tMck. - 'vm P,Y'n:'!t wdi M:•r/Dyad in the qdN ,tpec:hr :n yaw nrq.lyer detDlM)Mt :r .x .. . , a•rr.9niq,J?Yl.nnrl li:nJr. Plevsa"i'cste uvlw?'ww h.:X'nry t?Ibv. . Addhlonal Principal g ` AdAYional Escrow: $ STANtEYDOUGIAS teen NullbwI006993112 . late ChsrgeArFees7 $ SAR?N DOUGLAS ---- OSM109FbImeatlnlomsllon 5 (Niter: S Total Amount Enclosed. S aarsN' a'so•ee no - asess" T01?ymua:1 54.980.11) AtWIDfl? 1 $9,070.86 1 INOVRAC NORT4AOE SERVICES Tot=0?e: 1 st,A6t.66 r0 00X 70921 A?1011? 1 59, sst.fl PHDENIX Alll `85082-682241 1 l III IIII'III)(I lll??ll ll llf 111 ?5111?It1151tu i11151I1?I11I115u EXHIBIT 1009993112 00946166 00955171 0 13 E OneWest Bank 10/15/2009 11:45:09 AM PAGE IndyMac Mortgage Services Payoff Statement Stanley Douglas Sarah Douglas 1330 Williams Grove Roa Mechanicsburg PA 17055 Stanley Douglas Sarah Douglas 1330 Williams Grove Roa Mechanicsburg PA 17055 2/00b rax odzvCl October 15, 2009 Loan No: 1009993112 Investor: 756 Pr.opert. Address: 330 W:i 1 i urns !;rove Rd Mechanicsburg PA 1'105`• THIS STATEMENT REFLECTS IMPORTANT INFORMATION OF THE Payoff PROCESS FOR YOUR LOAN. PLEASE READ THOROUGHLY. ** %NDYMt1C vJILL PAY A1:. TAX AND INSURANCE PAYMENTS UNTIL RECEIPT OF PayoLL FUNDS. *** ********f******** STATEMENT OF ACCOUNT '***•"**'"*****x****x FOP. INFORMATION PURPOSES ONLY. WE.. RESERVE Till; iti dFiT TO CORRECT ANY ERROR OR OMISSION IN THIS Payoff QL10TE. 1'H [S P'ayoff' QUOTE IS VOII; AFTER 10-16-09. YOU MUST CONFIRM THE Payoff. AMOUNT' PRIOR 'I'0 REMITTING FUNDS. Payoff as of date: 10-16-09 Next payment due: 06-01-09 267 761.93 The current total unpaid Princippal Balance is: $ -7,318.16 Interest at 7.50000, through 10-16-09 (Per day interest is $ 55.99 00 Recoverable Corporate Advance Balance 44 ** 497 00 Unpaid Late charges 27.00 Recording Fee ,00 Fax/Quote .00 Demand Fees .00 Heloc Incentive Fee 10.00 Wire Fee * 'A 1 g 277,608.82 * * * * * * * * * TOTAL DUE By 10 6 0a . If Remitting by Check Deduct $10.00 ** Itemized'Detail Available upon Request Payoff funds received after 4:00 p.m. (ET) MUST include additional interest to the next, business day. Issuance of this quote does nc-._ suspend t_he or.tract req ,irer,:ent tc make 90.05 will your monthly mortgage payments when due. A late c'^arge of _, be assessed 15 da s after a next L)ayment is due (shown above) and will be added to t?ie Payoff total if received after that time. if you are set up for automatic draft each month, your payment will draft, as usual, if it is due before the Payoff funds are received. Please notify us at least 5 days prior to your draft date if you will be sending in the Payoff funds within that period. These figures are subject to final verification by the Note holder. Figures maybe adjusted if any check or money order previously received is rejected by the institution upon which it was drawn. To the extent applicable, additional legal fees or costs associated with servicing your loan may accrue daily. If Payoff funds received are inadequate, IndyMac Mortgage Services will contact the sender of the funds to c:>:i lErct ; lic. shortage. it we cannot contact or the remaining funds have not beet. cc?ilected within five (5) business days, the orig1nal funds will be returned to the sender. Any OneWest Bank 10/15/2009 11:45:09 AM PAGE 3i0u5 rax OcivCOL overage of funds (including escrow) will iFe returned to the mortgagor fifteen (15) business days after the Payoff date. To the extent permitted by state law, the Note Holder reserves the right to withhold the issuance of the satisfaction of mortgage until it receives all funds owed under the terms of your Note. We reserve the right to use available escrow funds to offset the amount of the returned item. * As this is an Adjustable Rate Mortgage Loan, it is imperative that you call to verify final Payoff amount prior to remitting funds. Please WIRE Payoff funds to: JP Morgan Chase (Dallas, Texas) ABA Routing No. 111000619 MRC Account. No. 063926297: Beneficiary: IndyMac Payoff Clearing **Please reference the Customer Name, Loan Number and Property Address to avoid any delays in processing. ** Any funds not wired must be sent as certified funds (non--certified funds will be returned) and a copy of the Payoff statement to the following address: Ind Mac Mortgage Services 6'?,^,0 Beat-r-4 e (fir ve. Ka:amazoo, M; 4:?00:?-% 0"'0 Ar.t.n: Mortgage raY;-:ffs Funds not Wired must i rlc. ,.de Uer d i,m 1 1 er 5' o a i i::w or ra i l or delivery time. (Funds submitted to an; u,ddress could delay Payoff, causing additional interest_ to accrue.) If you have any questions about wiring or remitting the Payoff funds, please contact us at 1.800.781.7399. SEE ATTACHED INSTRUCTION SHEET NOTE: If this property is being sold, please provide us with a valid mailing address for tKe seller (our cust_omer). XPOCI 133 30Q OneWest Bank 10/15/2009 11:45:09 AM PAGE 4/ UUb rax adivci important Tnstruc.' icx?s>! a:>e Read! payoff Funds: Personal check will NOT be accepted for payoff balance. We reserve the right to correct any error or omission in payoff quotes. To ensure your ppayoff figures have not changed since your payoff statement was issued YOU NT obtain a verbal verification 29 hours prior to submitting funds. Payoff funds must be sufficient for payoff on the business date received at IndyMac Mortage Services Payoff Department. (By 5 PM Eastern Time, Monday - Friday). if payoff funds are not sufficient for payment in full, the amount needed will be taken from escrow if available. If funds are not available, the payoff will not be processed until we receive the full payoff balance. Wire Funds to: JP Morgan Chase (Dallas, 'T'exas) ABA Routin #1110006:4 Account #06'3926'2971 When wiring funds for payoff, please reference our loan number address. borrowers name(s) and provide a contact name, phone This will enable us to contac.t you promptly in the event the payoff funds are not sufficient to pay the loan to tu,.. that are not remitted ;^ a.^_cr_:r.dar:ce wit'^ t h e fnreIoi:. . instructions ?c ;;der nsructions shall not be considered proper of consiCderdtlon. IndyMac Bank reserves the right to refuse processing of any payment noll made in accordance with these instructions. Cooperative Loans: For payoff of a Cooperative loan, other means of information are required. If this is a Cooperative loan you need to inform us by contacting 1-800-781-7399 ext. 2470. A stock certificate and ropr. tary lease are involved and it is a lengthy process to get that information. Please provide two (2) to three (3) weeks notification. Thank you for your cooperation. Escrow Accounts: The escrow balance is subject to audit and may change due to payments or weekaafter payoffir?g in escrow wilbubeerefundediapproxpimately thrfueell All We will continue to disburse escrow/impound funds for the payment of taxes, insurance or PMT as bills become due, 11p to the date payoff funds are received. It is critical that you verify fi:iai p ynff figures to obtain a correct escrow balance. Taxes, Insurance, Year End Statements, Mortgage Release: You should contact your taxing authority and irs.iranc:e com any to ensure tha*_ yyou receive future bills and verify payment status. ruture payments will be your responsibility. We will not.fy the taxing authority and insurance company that we no longer have an interest. in this property. (This does not apply if you are refinancing with IndyMac Mortgage Services.) Please provide us with a forwarding address. To ensure proper delivery of your year-end statement, appropriate release documents, and escrow refund check (if applicable). OneWest Bank 10/15/2009 11:45:09 AM PAGE 5/005 Fax Server Mortgage Payments: Issuance of a payoff statement does NOT suspend the contract requirement to make mortgadge payment when due. You are obiigated to provide payments when due to avoi late fees. Payoff quotes and demands do not reflect late charges until they have- been assessed. Yo!_: m:.-W: irclude assessed late fees with payoff funds. In the event a :,ym;er.: is ^e.de alter the payoff statement is issued, do not stox; paymo -n iecri. Any WOr:,aymen,, will be refunded to you approximately three (s} wor-_ti a'ter payc,ff with any escrow overage. AUTOMATIC DRAFT - We must be notified 6 days prior to payment draft date to stopdraft_ing, if you intend to pay the loan off before your scheduled draft date. For further assistance you may contact IndyMac Mortgage Services at 1-800-761-7399. Representatives are available to assist you from 8:00 AM to 9:OOPM Eastern Time, Monday through Friday. Sarah B. Douglas, Plaintiff vs. Stanley E. Douglas, Defendant : IN THE COURT OF COMMON : OF CUMBERLAND COUNTY : PENNSYLVANIA CIVIL ACTION NO. 08-7373 CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I, Mary A. Etter Dissinger, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon the attorney for Stanley E. Douglas, by First Class United States mail addressed as follows: Gregory S. Hazlett 7 West Main Street Mechanicsburg, PA 17055 Date:_ A /U ? ? ary A. Etter Dissin r FII_E-&-- _ ; C'F THrE F -T i 'PAW 2009 NOV -5 F N 2: 2O SARAH B. DOUGLAS, THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 08-7373 CIVIL TERM STANLEY E. DOUGLAS, IN DIVORCE Defendant/Respondent : PACSES CASE NO: 894110596 ORDER OF COURT - RESCHEDULE A CONFERENCE AND NOW, this 9th day of November, 2009, upon consideration of the 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 November 20, 2009 at 10:30 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. This date replaces the prior conference date of November 10, 2009. 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 1910.1 IC (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you (6) IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. Date of Order: November 9. 2009 Copies mailed to: Petitioner Respondent Mary A. Etter Dissinger, Esq. Gregory S. Hazlett, Esq. BY THE COURT, Edgar B. Bayley, Judge 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 F.LED- r 2 09 N" w"! - 6 2 SARAH B. DOUGLAS, PLAINTIFF V. STANELY E. DOUGLAS, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-7373 CIVIL IN RE: PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 10th day of November, 2009, upon consideration of the Plaintiff's Petition for Special Relief Requesting a Court Order Directing Sale of Marital Residence, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Defendant to show cause why the relief requested should not be granted; 2. The Defendant will file an answer on or before December 8, 2009; 3. The Prothonotary is directed to forward said Answer to this Court. 4. A hearing on the matter will be held on Tuesday, December 22, 2009 at 9:00 a.m. in Courtroom No. 5 of the Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, Mary A. Dissinger, Esquire Attorney for Plaintiff Gregory Hazlett, Esquire Attorney for Defendant bas l , ?w I ??a M. L. Ebert, Jr., J. lr?I Vii,'. ?i'v ?f SARAH B. DOUGLAS, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 08-7373 CIVIL TERM STANLEY E. DOUGLAS, IN DIVORCE Defendant/Respondent : PACSES Case No: 894110596 ORDER OF COURT AND NOW, this 24th day of November 2009, based upon the Court's determination that the Petitioner's monthly net income/earning capacity is $ 881.69 and the Respondent's monthly net income/earning capacity is $ 4,503.86, it is hereby ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit Five Hundred Twenty-five and 00/100 Dollars ($525.00) per month payable biweekly as follows: $ 500.00 per month for Alimony Pendente Lite and $ 25.00 per month on arrears. First payment due: in accordance with Respondent's pay schedule. The effective date of the order is October 16, 2009. Arrears set at $ 2,106.39 as of November 24, 2009. 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, at 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: Sarah B. Douglas. 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 name with their PACKS Member Number or Social Security Number in order to be processed. Do not send cash by mail. cc360 V The monthly support obligation includes cash medical support in the amount of $250 annually for unreimbursed medical expenses incurred for each child and/or spouse. Unreimbursed medical expenses of the obligee or children that exceed $250 annually shall be allocated between the parties. The party seeking allocation of unreimbursed medical expenses must provide documentation of expenses to the other party no later than March 31" of the year following the calendar year in which the final medical bill to be allocated was received. The unreimbursed medical expenses are to be paid as follows: 50% by Respondent and 50% by Petitioner. [X] Respondent [] Petitioner [] Neither party to provide medical insurance coverage. Within thirty (30) days after the entry of this order, the [] Petitioner [X] 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 8) five copies of any claim forms. Other conditions: This Order is based upon the fact that the Respondent has not made a payment on the marital home mortgage since April, 2009 and the property is now in foreclosure and that the Respondent has not maintained insurance on the Petitioner's vehicle. Effective May 1, 2009, the Alimony Pendente Lite is modified to $323.00 per month. Effective October 16, 2009, the Alimony Pendente Lite is modified to $500.00 per month. This Order shall become final twenty (20) 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. Mailed copies on: November. 24, 2009 to: Petitioner Respondent Mary A. Etter Dissinger, Esq. Gregory S. Hazlett, Esq. DRO: R.J. Shadday BY THE COURT, 1 %.%*A Edgar B. Bayley, J. FILEI}°C'r'T- E r, ,,, Iii 2009 NOV 24 PH 2: 40 ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 11/24/09 Case Number (See Addendum for case summary) ?q y 110 5q Lo 08-1313 Ctv? Original Order/Notice O OAmended Order/Notice 0Terminate Order/Notice OOne-Time Lump Sum/Notice RE:DOUGLAS, STANLEY E. Employer/Withholder's Federal EIN Number Employee/Obligor's Name (Last, First, MI) 5k_1 I MILDSIIJ 453-19-6027 Employee/Obligor's Social Security Number SECCO INCORPORATED ,02- S ZO 9289102071 1111 PRIMROSE AVE Employee/Obligor's Case Identifier CAMP HILL PA 17011-6922 (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. $ 1,005.00 per month in current child support $ 50. 00 per month in past-due child support Arrears 12 weeks or greater? (g) yes 0 no $ 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 $ 25.00 per month in past-due spousal support $ o. oo per month for genetic test costs $ o. o o per month in other (specify) $ one-time lump sum payment for a total of $ 1, 580 . oo per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 364.62 per weekly pay period. $ 790.00 per semimonthly pay period (twice a month) $72()_2_'1-- per biweekly pay period (every two weeks) $ 1, 580.00 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, PAYM MUS I E DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employ / bligor's ase t.fie OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CAS M v NOV Z 5 2009 BY THE COURT: Edgar B. Bayley, Judge Service Type M OMB No.: 0970-0154 Form EN-028 Rev.5 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS If hecke? you are required to provide a opy of this form to your mployee. If yo r employee orks in a state that is diherent from the state that issued this order, a copy must be provi?ed to your employee even if tie box is not checked. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. if there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one 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 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. 2321546720 THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : 0 THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: E:3 EMPLOYEE'S/OBLIGOR'S NAME: DOUGLAS EMPLOYEE'S CASE IDENTIFIER: 9289102071 LAST KNOWN HOME ADDRESS: LAST KNOWN PHONE NUMBER: DATE OF SEPARATION: FINAL PAYMENT AMOUNT: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (CCPA) (15 U.S.C. 1673 (b)); or 2) the amounts allowed by the State or Tribe of the employee's/obligor's principal place of employment. Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes, Social Security taxes, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is supporting another family and 60% of the disposable income if the obligor is not supporting another family.However, that 50% limit is increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State, you may deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section. Arrears greater than 12 weeks : If the Order Information does not indicate whether the arrears are greater than 12 weeks, then the employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of the CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amounts paid for health care premiums in determining disposable income and applying appropriate withholding limits. 10. Additional info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Send Termination Notice and other correspondence to: If you or your employee/obligor have any questions, DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT 13 N HANOVER ST by telephone at (717) 240-6225 or P.O. BOX 320 by FAX at (717) 240-6248 or CARLISLE PA 17013 by Internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Rev.5 STANLEY E. Service Type M OM8 No.: 0970-0154 Worker I D $ IATT • r ADDENDUM Summary of Cases on Attachment Defendant/Obligor: DOUGLAS, STANLEY E. PACKS Case Number 517110656 PACSES Case Number 894110596 Plaintiff Name Plaintiff Name SARAH B. DOUGLAS SARAH B. DOUGLAS Docket Attachment Amount Docket Attachment Amount 00102 S 2009 $ 1,055.00 08-7373 CIVIL$ 525.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB SEAN R. DOUGLAS 03/30/07 TYLER A DOUGLAS 12/02/0 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 Rev.5 Service Type M OMB No.; 0970-0154 Worker ID $IATT FILUD- 01!+ 1 CE OF THE F'"' 1 NI.1TARY 2009 NO 2? l ill C-1 3 CU .. oe -'7313 MULL T F_ The monthly support obligation includes cash medical support in the amount of $250 annually, for unreimbursed medical expenses incurred for each child and'or spouse. Unreimbursed medical expenses of the obligee or children that exceed $250 annually shall be allocated between the parties. The party seeking allocation of unreimbursed medical expenses must provide documentation of expenses to the other party no later than March 31" of the year following the calendar year in which the final medical bill to be allocated was received. The unreimbursed medical expenses are to be paid as follows: 50% by Respondent and 50% by Petitioner. [X] Respondent [] Petitioner 0 Neither patty to provide medical insurance coverage. Within thirty (30) days after the entry of this order, the [] Petitioner [X] 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 S) five copies of any claim forms. Other conditions: This Order is based upon the fact that the Respondent has not made a payment on the marital home mortgage since April. 2009 and the property is now in foreclosure and that the Respondent has not maintained insurance on the Petitioner's vehicle. Effective May 1.2009. the Alimony Pendente Lite is modified to $323.00 per month. Effective October 16, 2009. the Alimony Pendente Lite is modified to $500.00 per month. This Order shall become final twenty (20) 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. Mailed copies on: November 24. to: Petitioner Respondent Mary A. Etter Dissinger, Esq. Gregory S. Hazlett, Esq. BY THE COURT, .r 1 Ci* Edgar B. Bayley. J. pRO: R.J. Shaddky /2- -l SARAH B. DOUGLAS, IN THE COURT OF COMMON PLEAS OF PlaintitftPetitioner CUMBERLAND COUNTY, PENNSYLVANIA v5, CIVIL ACTION -DIVORCE NO. 08-7373 CIVIL TERIM STANLEY E. DOUGLAS, IN DIVORCE Defendant/Respondent PACSES Case No: 89411059+6 ORDER_UF COIF RT AND NOW, this 24th day of November 2009, based upon the Court's determination that the Petitioner's monthly net income/earning capacity is $ 881.69 and the Respondent's monthly net income'earning capacity is $ 4,503 .86, it is herebv ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit Five Hundred Tiventy-five and 00.'100 Dollars (5525.00) per month payable biweekly as follows: S 500.00 per month for.41imo7t- Pendente Lite and $ 25.00 per month on arrears. First payment due: in accordance with Respondent's pay schedule. The effective date of the order is October 16, 2009. Arrears set at S'2,106.39 as of :November 24, 2009. Failure to snake each payment on time and in fiill 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- «-ith this Order, it may declare the Respondent in civil contempt of Court and, at 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: Sarah B. Douglas. Payments must be trade 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 llarrisburg, PA 17106-9110 Payments must include the Respondent's name with their PACSES Member Number or Rncial Security Number in order to be processed. Do not send cash by mail. SARAH B. DOUGLAS, . Plaintiff'Petitioner VS. STANLEY E. DOUGLAS, . Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 08-7373 CIVIL TERM IN DIVORCE PACSES Case No: 894110596 NOTICE OF RIGHT TO REQUEST A HEARING The parties are hereby advised that they have until December 14,2009 to request a hearing do novo before the Court. File request in person at: Office of the Prothonotary 1 Courthouse Square Carlisle, PA 17013 Or mail to: Office of the Prothonotary 1 Courthouse Square Carlisle, PA 17013 CC363 ?Y OF TH: 2009 DEC I Pil 3: 5 3 f".. v ?i'LV,- Sarah B. Douglas, Plaintiff VS. Stanley E. Douglas, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA : CIVIL ACTION : NO. 08-7373 CIVIL TERM : IN DIVORCE MOTION TO ENTER STIPULATION AGREEING TO THE SALE OF THE MARITAL RESIDENCE AND NOW comes Mary A. Etter Dissinger, Esquire, who requests the Court to enter the attached Stipulation as an Order of Court and in support of the Motion avers as follows: 1. Movant is counsel for Plaintiff, Sarah B. Douglas. 2. Plaintiff, Sarah B. Douglas, filed a Petition with the Court to compel the listing of the marital real estate for sale. 3. The Court entered an Order directing a Rule Returnable by December 8, 2009. 4. In lieu of responding to the Rule, the parties have entered into a Stipulation to list the real estate for sale and request that the Court enter the Stipulation as an Order of Court. 5. The Stipulation of the parties is attached hereto as Exhibit "A". 6. Attached is a proposed Order of Court for the Court to enter the Stipulation. (See Exhibit "B" attached) 7. Attorney Hazlett, counsel for Stanley E. Douglas concurs in the filing of this Motion. WHEREFORE, it is respectfully requested that the attached Exhibit "B" be made an Order of Court. Respectfully Submitted, DISSINGER & DISSINGER _;?J- s-_? (4 OArz, Mary A. Etter Dissinger, Attorney at Law Supreme Court ID #27736 28 North Thirty-second Street Camp Hill, PA 17011 (717)975-2840 (717)975-3924 - fax Sarah B. Douglas, Pl e..i xi ±-_i .f. f vs. Stanley E. Dt iigl as, Defendant : 'IN TBE CCURT OF COIF` ON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA : CIVII ACTION NO. 08-7373 CIVIL TERM : IN DIVORCE St lml.atai.on A*r*ei tq to t_ Balms of the j" mtal Roaxjenca And now- comes Sarah. B. Douglas and Stanley E. nouglas and request -he court tv direct ;:he sale of the marital resldr r c..,e aaCz Liivy ag-zve els fa1.1Ows: 1. Pet:itdone:r, Sarah S. VOUglas, may list for sale the rra.ri.t.al res..idence located a- 1330 Williams Grove Road, Mechanicsburg, C'and erland County, Pennsylvania 17055 at a Pr-ice to b*-- reca endied by the real t nr of her choice. 2- The Court shall enter an order directing her to do so and that nrrler shall prezride that the signature of Defendant on the :fisting ccntract shall not be required to he a valid Contract fox the _]i-t:a_ng 0-117 the r?,.al -ez;tate for sale. 3. The cot.,7rt: -ct•,.a_l l ez:ater apt. c:r crier rega-i i_ing Defendant to cot-}berate in the sale of the residence, 9_ T :^ *earirg on Plalr)id:ff's Petition to Special Relief Req esting the C:>ia:r_ to Ordez the Sale of the Nariral. Resin=ep-- wi-,_ar_.-h awns filed Ncv%:: ri?eX- £, 200.9 and scheduled for heasi ag on Decea-ber 22, 25?? Thal., he cancelled. EXMBIT J__A a-J tti1GC !; .G 1.1!. i'`l.} .f xt?!3 I S?s 3 tj '{? _x a.?te a *_+.5- x IT L1 ti?'7' n T' L•nrt .7 L. rv -, .ti ., 4. This Stipulation sha? 1 be made an Order, of Cou.Tt in the form attached as Exhibit A. Sarah 3_ Douglas, Plaiitiff . St3s+1,? E. ."..P..7glas, Respectfully Submitted: D' SaMN40 R JOW Drg.933 M Mary A: Etter Pjssinger Attorney for Plaintiff SuP`e'me C'Durt T _ D. #27736 28 Nomth Thirty-Second Street Camp Hill, PA 17011 ( 717) 9-V,-2840 , p,ey for Defendant t Main Street niesburg, PA 17055 E -4 #i J -'r'+d 2" I '6 S T t7 '9 ..,a?aa.:?u r ss Y n Sarah B. Douglas, Plaintiff VS. Stanley E. Douglas, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA : CIVIL ACTION : NO. 08-7373 CIVIL TERM : IN DIVORCE ORDER And now this day of December, 2009, it is hereby ordered and decreed as follows: 1. The hearing on Plaintiff's Petition to Special Relief Requesting the Court to Order the Sale of the Marital Residence which was filed November 6, 2009 and scheduled for hearing on December 22, 2009 is cancelled. 2. Plaintiff, Sarah B. Douglas, shall list for sale the marital residence located at 1330 Williams Grove Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 at a price to be recommended by the realtor of her choice. 2. The Court directs that the signature of Defendant on the listing contract shall not be required to be a valid contract for the listing of the real estate for sale. 3. Defendant shall cooperate in the sale of the residence. By the Court: J. -!l&- Sarah B. Douglas, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY : PENNSYLVANIA VS. : CIVIL ACTION Stanley E. Douglas, : NO. 08-7373 CIVIL TERM 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 Gregory S. Hazlett, Esquire, counsel for Defendant by depositing same in the United States Mail, postage prepaid, addressed as follows: Gregory S. Hazlett 7 West Main Street Mechanicsburg, PA 17055 Date: Mary A. Etter Dissingg Esq. FlLE1----l?;-:r. THE ,) '# ,TARY 1209 d-E C 23 AN' 3: 16 n Sarah $. Douglas, PIAI ti.:ff vs. a-d Stanley E. Douglas, Defendant : IN TBE COURT OF COMMON PLEAS : OF CIAH1ERLA.ND COUNTY : PENNSYLVANIA : CIVIL ACTION : NO. 08-7373 CIVIL TERM : IN DIVORCE 8ti Raroe i ng to the Salmi of the 3faaita l Rosidance And now comes Sarah B. Douglas and Stanley E. Douglas and re4uest the court to direct the sale of the marital residence and they agree as follows 1. Petitioner, Sarah B. Douglas, may list for sale the marital residence located at 1330 Williams Grove Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 at a price to be r+eocxmmended by the zealtor of her choice. 2. The Court shall enter an order directing her to do so and that order shall provide that the signature of Defendant on the listing contract shall not be required to be a valid contract for the listing of the seal estate for sale. 3. The court shall enter an order rega i.ring Defendant to cooperate in the sale of the resadence. 4- The hearing on Plaintiff's Petition to Special Relief Requesting the Court to Order the Sale of the Marital Rea- den wb-ich was filed. November f, 2009 and scheduled for hearing cm December 22, 2009 sohaj,. be cancelled. *ZGC -9LG-L1L H3 ja2uxNsxU I Aa2uissin wwzT :DT sons *a oaa f 4, Th1% tipuat4hall ma-de an Cider of court in the farm attaaied as Exhibit A. Respectfully Submitted: Sa ah B. Douglas, Plaintiff L? St. nUej' E. D uglaB. FE-01 .-7- Mary A.' `Etter Dissinger`'--_. Attorney for Plaintiff Supra Court I.D. #27736 28 Worth Thirty-Second Street Camp Hill, PA 17011 ( 717) 9,1*1-2840 i , ,e _ Attor Y for De endant 7 W t Main Street M haniesburg, PA 17055 *ZfiE-SLG-L I L HO .J02" I ss i n 1 .ae2uI SS IV WUZ T : D I SOOZ 40 00a t?. 7Q09OC 231' ?w+ DEC 2 8 20D9 67 Sarah B. Douglas, Plaintiff VS. Stanley E. Douglas, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA : CIVIL ACTION : NO. 08-7373 CIVIL TERM : IN DIVORCE ORDER And now this 1%A day of December, 2009, it is hereby ordered and decreed as follows: 1. The hearing on Plaintiff's Petition to Special Relief Requesting the Court to Order the Sale of the Marital Residence which was filed November 6, 2009 and scheduled for hearing on December 22, 2009 is cancelled. 2. Plaintiff, Sarah B. Douglas, shall list for sale the marital residence located at 1330 Williams Grove Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 at a price to be recommended by the realtor of her choice. 2. The Court directs that the signature of Defendant on the listing contract shall not be required to be a valid contract for the listing of the real estate for sale. ?3. Defendant shall cooperate in the sale of the residence. By the Court: ?AA FILED--; Fr -. t ,,_ t ;,fr)TARY 2010 JAN -4 111: 113 GU , Cori-g" M?tg*LECL A",( b1ccl-Lica- W Sarah B. Douglas, Plaintiff VS. Stanley E. Douglas, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA : CIVIL ACTION : NO. 08-7373 CIVIL TERM : IN DIVORCE AGREEMENT p 54- - AGREEMENT made this AUCA day of wry, 2010, by and between Stanley E. Douglas ("Husband"), of Cumberland County, Pennsylvania and Sarah B. Douglas ("Wife") of Cumberland County, Pennsylvania. WITNESSETH: WHEREAS, the parties hereto are Husband and Wife, having been married on the tenth day of January, 2002 in Austin, Texas. There were born two children of this marriage, said children being: Tyler A. Douglas and Sean R. Douglas, both minors. Husband has another child, Wendy A. Douglas, a minor, to a prior relationship. Wife has no other issue, living or deceased, and neither party has any adopted children. WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties and as a result they have lived separate and apart since November 23, 2008. A proceeding for the divorce of the parties has been filed by the Wife in the Court of Common Pleas of Cumberland County, Pennsylvania, on December 19, 2008, to Docket No.08-7373 Civil Term. It is the intention of Wife and Husband to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each Fdk, 1.9 =7 Di.:ssi.nger & J i_ssinger Cif 717-975-3924 p.14 other including without limitation by specification: the settling c?f all matters between them relating to the ownership and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present and future: spousal support, alimony pendente lite, alimony and/or maintenance of Wife by Husband and of Husband by Wife; child support: for Wendy, and possible claims by one against the other and against their respective estates. NOW THEREFORE, in consideration of the above recitals and the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt and sufficiency of which is hereby acknowledged by each of the parties ,hereto, Wife and Husband, each intending to be legally bound :hereby, covenant and agree as follows: 1, 11'1` NOT A BAR TO DIVORCE PROMMINGS Wife filed a mutual consent, no-fault divorce pursuant to the terms of Section 3301(c) of the Divorce Code cf the Commonwealth of Pennsylvania, and this Agreement is contingent upon the Wife proceeding with said divorce, and Wife and Husband contemporaneously with the execution of this Agreement signing an Affidavit of Consent and Waiver of Notice of Intention to Request Entry of a Divorce Decree. Said Affidavits and Waivers shall be promptly transmitted to counsel for Wife who will file a Praecipe to Transmit Record and Vital Statistics form to precipitate the prompt entry of a decree of divorce. Neither Husband nor Wife shall either directly or indirectly permit the withdrawal of their respective Affidavits of Consent or any and all other documents executed by Husband and Wife subsequent to the execution of the documents. -2- FR b 1P 2011. 1 1. :5F_3P'q r ss'.-Cp- ?t n, S* .'."iv(a. 717-?75-3P124 P. 15 2. EFFECT OF DI VORCH 1,?SCRM The parties agree that unjTess otherwise specifically provided herein, this Agreement shall continue in full force and effect after such once as a :Final decree in divorce may be entered with respect to the parties. 3. INCoRpoRRxioN o8' AG ENSI T rN DIVORCE DECREE The purposes, of this Agreement are to effect a complete and final settlement, with reference to each party of: a. A.11 of the :respective property and property rights of the parties, b. The obligation of each party for the support of each other, and for Wendy and the parties agree that the terms of this Agreement shall be incorporated but not merged into any final divorce decree which may be entered with. respect to them. 4. A 1'P NOT TO BE NNR® This Agreement shall be incorporated into the final decree of divorce of the parties hereto for purposes of enforcement only, but otherwise shall not be merged into said decree. The terms shall be incorporated into the final divorce decree for the purpose of enforcement only and any modification of the terms. hereof shall be valid only if made in writing and signed by both of the parties. Any Court having jurisdiction shall enforce the provisions of this Agreement as if it were a Court Order. This Agreement shall survive in its entirety, resolving the spousal support, alimony pendente lite, alimony, equitable distribution and other interest. and rights of the parties under and pursuant to the Divorce Code of the Commonwealth of Pennsylvania, and no court asked to enforce or interpret this Agreement shall in any way -3- Mary A. Etter Dissinger, Esquire, attorney for Wife, and Greg Hazlett, Esquire, attorney for Husband. The parties acknowledge that they have received independent legal advice from counsel of their selection and that they fully understand the facts and have been fully informed as to their legal rights and obligations and they acknowledge and accept their legal rights and obligations and they acknowledge and accept that this Agreement is, in the circumstances, fair and equitable and that it is being entered into freely and voluntarily, after having received such advice and with such knowledge, and the parties acknowledge that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. In addition, each party hereto acknowledges that he or she has been fully advised by his or her respective attorney of the impact of the Pennsylvania Divorce Code of 1980, 23 P.S. Section 101 et. seq., whereby the Court has the right and duty to determine all marital rights of the parties including divorce, alimony, alimony pendente lite, equitable distribution of all marital property or property owned or possessed individually by the other, counsel fees and costs of litigation and, fully knowing the same and being fully advised of his or her rights thereunder, each party still desires to execute this Agreement, acknowledging that the terms and conditions set forth herein are fair, just and equitable to each of the parties, and waives his or her respective right to have the Court of Common Pleas of Cumberland County, or any other Court of competent jurisdiction, make any determination or order affecting the respective parties' rights to a divorce, alimony, alimony pendente lite, equitable distribution of all marital property, counsel fees and costs of litigation, or any other rights arising from the parties' marriage. -5- ? ?, ±a ;,-,7 7nss nger C?4 717-975-3924 p.18 01 9. HIM RS'1'AWE i?,The marital residence situate at 1330 Williams Grove Road,. Mechanicsburg, Pennsylvania, (herein referred to as "Residence"), is listed for sale pursuant to an agreed order of Court :sated December 31, 2009. Husband agrees to cooperate with Wife's efforts to obtain a short sale to eliminate any future obliga.tion by either party on the mortgage currently owed on 1330 Williams Grove Road. Husband's failure to cooperate in any way will be deemed a violation of this Agreement. Any request by Wife or the realtor or a financial institution for Husband's signature to accomplish the sale of the residence shall be complied with by Husband within 98 hours of demand for his signature. 10. PMSCQIhL FMPIMY Husband and Wife do hereby acknowledge that they have previously divided their tangible personal property including, but without limitation, jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, pictures, books, works of art and other personal property and hereafter Wife agrees that all of property in the possession of Husband shall be the sole and separate property of Husband, and Husband agrees that all of the property in the possession of Wife shall be the sole and separate property of Wife, except to the extent specifically set forth otherwise in this Agreement. The parties do hereby specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may have with respect to the above items which shall become the sole and separate property of each other, except to the extent specifically set forth otherwise in this Agreement, a. Each waives any claim they may have to the pension, retirement and/or profit sharing plan or other retirement benefits of the other. S,(,LCA as 4011 5' Pic. 4117PO GSH -6- & Pissing+er ?' r ?_7-475-QQ?E P.19 11. HOTOR NrXHICLES With respect to the motor vehicles owned by one or both of the PELrties, they have already been divided and transferred. 12. ASSUMPTION OF S Unless otherwise provided herein, each party hereby assumes the debts, encumbrances, taxes and liens on all the property each will hold subsequent to the date of this Agreement, and each party agrees to indemnify and hold harmless the other party and his or her pr,aperty from any claim or liability that the other party will suffer or may be required to pay because of such debts, encumbrances or liens. Each party in possession of property to be awarded to the other warrants that all dues, fees, assessments, mortgages, taxes, insurance payments and the like attendant to such property are current, or if not current, notice of any arrearages or deficiency has been given to the receiving party prior to the execution of this Agreement. 13. CREDIT CARDS The parties warrant that they have returned each to the other any charge cards, if any, in the name of the other party and each party agrees not to charge any expenses in the name of the other warty. Each party represents and warrants that all jointly held accounts have been closed. From the date of execution of this Agreement, each party shall use only those cards and accounts for which that party is individually "Liable. Each party agrees to save and hold harmless and indemnify the other from any liability on any credit card debt assumed by him or her. 14. LIABILITY NOT LISTSD Each party represents and warrants to the other that he or she has not incurred any debt, obligation, or other liability, other than those described in this Agreement, for which the party -7- F-b 19 2C?'7 ?_issi.niger & .Iissireer C'4 717-975-3324 p.20 is or may be liable. A liability not disclosed in this Agreement will lie the :pole responsibility of the party who has incurred or may hereafter incur it, and each party agrees to pay it as the same shall becone due, .and to indemnify and hold the other party and his or her property harmless from any and all such debts, obligations and liabilities. is. 11MMMIFICATIOff of WIFE If any claim, action or proceeding is hereafter initiated seeking to hold Wife liable for the debts or obligations assumed by Husband under this Agreement, Husband will, at his sole expense, defend Wife against any such claim, action or proceeding, whether or not well-founded, and indemnify her and her property against: any damages or loss resulting therefrom, including, but not limited to, costs of court and attorney's fees incurred by Wife in connection therewith. 16. INDEMNIFICATION OF RUSHAM If any claim, action or proceeding is hereafter initiated seeking to hold Husband liable for the debts or obligations assumed by Wife under this Agreement, Wife will, at her sole expense, defend Husband against any such claim, action or proceeding, whether or not well-founded, and indemnify him and his property against any damages or loss resulting therefrom, including, but not limited to, costs of court and attorney's fees incurred by Husband in connection therewith. 17. WAIVER OF ALIMNY The parties acknowledge that inflation may increase or decrease, their respective incomes may change, that either may be employed or unemployed at various times in the future, that their respective assets may substantially increase or decrease in value, and that notwithstanding these or other economic circumstances, -e- the parties acknowledge that they each have sufficient property and resources to provide for her or his reasonable needs and that each is able to support himself or herself without contribution' from the other. Therefore, the parties hereby expressly waive, discharge and release any and all rights and claims which they may have now or hereafter have, by reason of the parties' marriage, to alimony, alimony pendente Site, support or maintenance and they acknowledge that this Agreement constitutes a final determination for all time of either party's obligation to contribute to the support and maintenance of the other. It shall be, from the execution date of this Agreement, the sole responsibility of each of the respective parties to sustain himself or herself without seeking any additional spousal support from the other party. 18. TAX JWrU NS AlAD 3WDITS Husband and Wife represent that all federal, state and local tax returns required to be filed by Husband and Wife have been filed, and all federal, state and local taxes required to be paid with respect to the periods covered by such returns are paid. Husband and Wife further represent there are no tax deficiencies proposed or assessed against Husband and/or Wife for such periods, and neither Husband nor Wife executed any waiver of the Statute of Limitations on the assessment or collection of any tax for such periods. 19. TAMS FOR YEAR OF DIVORCE Each party shall file separately. Wife shall claim only Sean as her dependent for 2009. Husband in 2009 shall be entitled to claim both Tyler and Wendy as his dependents. For tax year 2010 and every year thereafter, Wife shall claim Wendy and Sean, and Husband shall only be entitled to claim Tyler as his dependent. -9- ;?P •d base-9L8-GIG H3 ua9utssla 1 J83utssIG waIT:2 nrn7 sal oa_j i.ss?.ner r. K=.rgk*r 717-975-3924 p.22 For tax year 2010 and every year thereafter, Wife shall claim Wendy and Sean, and Husband shall only be entitled to claim Tyler as his dependent. Each party shall execute and deliver to the other any and all forms or documents necessary for each to claim the child or children as dependant under Federal, State or Local Law as set forth in the foregoing two paragraphs. 20. PRE8BRVA'TION OP RECORDS Each party will keep and preserve for a period of four (4) years from the date of divorce all financial records relating to the marital estate, and each party will give the other party immediate access to these records in the event of tax audits. 21. 7 TTZR-ACQUIRSD PSRSO?ML PROPERTY Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of personal property, tangible or intangible, hereafter acquired by. him or her, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried. 22. LZQhL TZ8S Each party will be responsible for their respective counsel fees and costs involved in securing a 90-day no-fault divorce. In the event, for whatever reason, either party fails or refuses to execute an affidavit evidencing their consent to the divorce, pursuant to 53301(c) of the Divorce Code, that party shall indemnify, defend and hold the other harmless from any and all additional expenses, including actual counsel fees resulting from any action brought to compel the refusing party to consent. Each party hereby agrees that a legal or equitable action may be -10- j ' W-b IF PC?.C 2:C1CP'" Pi.ssi.n er & Uissi.nger 717-975-3924 P.23 brought to compel slim or her to execute a consent form and that, absent any breach of this Agreement by the proceeding party, there shall be no defense to such action asserted. *.1811\0 23. RO CHILD SUPPORT FM V=Y 4h Wi a agrees not to s ek child upport f r Wendy. W ugfi tlUsbci r S1?ct 1 vc?r?t ( t vm ?it? ! f?i )tjj1aag1j (1// t 24 . 41D (9 0) SPOUSAL SUPP414T,ALI140NY PEND8NT2 LITR ALMOMY Husband and Wife agree and hereby do release and renounce any claim they may have against the other party for spousal support, alimony pendente lite, alimony and maintenance from this date forward. Nothing in this Agreement shall affect or impact Husband's duties and responsibilities to pay support and/or alimony pendent lite to wife from date of separation to date of execution of this Agreement. Wr-Clp 5)n1l (I116'E'h4riQ?,? rt1 dN an j4PL jspuubQl sub oN? arrFogics LA fp -? ?,F ?u ©,p q t"RP 25. SG RRAZ?ITY AS TO XXI ?kcc? ON -,4149 sTZx? OHLIGATIO? % ll Q `o G J H 9 Each party represents that he or she has not heretofore incurred or contracted any debt or liability or obligation for which the estate of the other party may be responsible or liable except as may be provided in this Agreement. Each party agrees to indemnify or hold the other party harmless from and against any and all such debts, liabilities or obligations of every kind which may have heretofore been incurred by them including those for necessities except for the obligations arising out of this Agreement. 26. TtAR MUM AS TO PUTURZ OBLIGATIOUS Except as set forth in this Agreement, Husband and Wife each represents and warrants to the other that he or she has not in the past or will not at any time in the future incur or contract any debt, charge or liability for which the other's legal representatives, property or estate may be responsible. Each -11- Gk+h 1.?3 ?^l ^ ?. f1R°"' I?i.ssingnr ?J _ssi.nger r.74 71.7-975-3924 p.24 hereby agrees tc indemnify, save and hold the other and his or her propeerty harmless from any liability, loss, cost or expense whatsoaver incurred in the event of breach hereof. 27. PROPERTY itF•T E"R =.1. is the intention of Husband and Wife to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision of this Agreement. All property hereunder is transferred subject to all existing encumbrances and liens thereon. The transferee of such property agrees to indemnify and save harmless the other party from any claim or liability that such other party may suffer or may be required to pay on account of such encumbrances or liens. Such party will, at his or her sole expense, defend the other against any such claim, whether or not well founded, and he or she will indemnify and hold harmless the other party in respect to all damages resulting therefrom. The insurance on the property being transferred hereunder is assigned to the party receiving such property, and the premiums on such insurance shall be paid by the party to whom the insurance is assigned. By this Agreement the parties have intended to effect an equitable distribution of their assets. The parties have determined that the division of said property conforms to the criteria set forth in 53501 et. seq. of the Pennsylvania Divorce Code taking into consideration the length of marriage; the fact that it is the first marriage for Husband and Wife; the age, health, station, amount and sources of income, vocational skills, employability, estate, liabilities and needs of each of the parties; the contribution of each party to the education, training or increased earning power of the party; the -12- ¦ Fir 1. f1 2CI7 ?- 2CU" nissin;er & Di_ssirger CP 717-975-3924 p.25 opportunity of each party for future acquisitions of capital assets and income; the sources of income of both parties, including but not limited to medical., retirement, insurance or other benefits; the contributions or dissipation of each party in the acquisition, preservation, depreciation or appreciation of the marital property, including the contribution of each spouse as homemaker; the value of the property set apart to each party; the standard of living of the parties established during the marriage; and the economic circumstances of each party at the time the division of property is to become effective. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division is being effected without the introduction of outside funds or other property not constituting a part of the matrimonial estate. The division of property under this Agreement shall be in full satisfaction of all marital rights of the parties. 28. OVAL RELEASES Husband and Wife each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of the other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and interest or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by law of dower or courtesy, or claims in the nature of dower or courtesy or widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the riq to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a Oeceased,,=apouse's estate, -13- F?*k? 19 207C ni.ssinger & BJ.ssireer CH 717-975-3924 p.26 whether ari,-ing under the laws of Pennsylvania, any other state, Comm:,xr*ealt1-:: or territory of the United States, or any other country, or any rights which either party may have or at any time hereaf--ter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, equitable distribution, costs or expenses, whether arising as a result of the marital relation or otherwise, except, and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision of this Agreement. 29. PER842t!!]:. RIGHTS Wife and Husband may and shall at all times hereafter live separate and apart. Each shall be free from any control, restraint, interference or authority, whether direct or indirect, by the other in all respects as fully as if he or she were unmarried. Each may also reside at such place or places as he or she may select. Each may, for his or her separate use or benefit, conduct, carry on and engage in any business, occupation, profession or employment which to him or her may seem advisable. Wife and Husband shall not molest, harass, or malign each other or the respective families of each other, nor compel or attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with him or her. Each party hereto releases the other from all claims, liabilities, debts, obligations, actions and causes of action of every kind that have been or will be incurred relating to or arising from the marriage between the parties, except that neither party is relieved or discharged from any obligation under this Agreement- Neither party will interfere with the use, ownership, enjoyment or disposition of any property now owned by or hereafter acquired by the other. -14- P-b 19 2clc 2:C70?, ?Jissinggr & Dissinger CP 71.7-975-3924 (0.27 30. 4"TZNERAL PROVISIONS This Agreement shall be effective from and after the time of its execution, however, the transfer of the property provided for herein shall only take place upon the entry of a final decree in divorce. The support provisions of this Agreement shall take effect immediately upon execution. 31. WUVSR = MDIFICATION TO W IN MITI= No modification, rescission, amendment or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. Any oral representations or modifications concerning this instrument shall be of no force or effect excepting a subsequent modification in writing, signed by the party to be charged. 32. MUTUAL coopmaTion Each party shall on demand execute and deliver to the other party any deeds, bills of sale, assignments, consents to change of beneficiaries of insurance policies, tax returns, and other documents, and shall do or cause to be done every other act or thing that may be necessary or desirable to effectuate the provisions and purposes of this Agreement. If either party unreasonably fails on demand to comply with these provisions, that party shall pay to the other party all attorney's fees, costs, and other expenses reasonably incurred as a result of such failure. 33. LRN OF PMMSYLVAMA APPLICABLE This Agreement and all acts contemplated by it shall be construed and enforced in accordance with the laws of the Commonwealth of Pennsylvania. -15- ?`?a>h 18 2010 2:n?.PM Pissinmer ?!t !? .??:.^?+?r ?,'J 71.7-975-3924 P.28 34. IWMGRATX(Mq This Agreement constitutes the entire understanding of the parties and :supersedes any and all prior agreements and negotiations between them. There are no representations other than those expressly set forth herein. 35. R"IRE AGR NT Each party acknowledges that he or she has carefully read this Agreement, including all Schedules and other documents to which it refers; that he or she has discussed its provisions with an attorney of his or her own choice, or has waived the opportunity to do so, and has executed it voluntarily and in reliance upon his or her own attorney; and that this instrument expresses the entire agreement between the parties concerning the subjects it purports to cover. 36. 3MCOP"RATION or 31111111=12S All Schedules and other instruments referred to in this Agreement are incorporated into this Agreement as completely as if they were copied verbatim in the body of it. 37. OTHRR DOCUMENTATION Wife and Husband covenant and agree that they will forthwith, and within ten (10) days after demand therefore, execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this Agreement. 38. NO WAIVER OF DEFAULT This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same,- -16- 18 2LI10 2_:02_PM Dissinger ?J? ssi.r er ?=' 7'.7-?75-? 3?? p.29 'eta 4. nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall it he ccnstructed as a waiver of strict performance of any obligation: herein. 39. SEVERASILITY The parties agree that each separate obligation contained in this Agreement shall be deemed to be a separate and independent covenant and agreement. If any term, condition, clause or provision of this Agreement shell be determined or declared to be void, unenforceable or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet her or his obligations under any one or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way void or alter the remaining obligations of the parties. 40. IN"INGS NOT PART OF AL 1?T Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for the convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. 41. COUNTERPARTS This Agreement may be executed in any number of counterparts and any party hereto may execute any such counterpart, each of which when executed and delivered shall be deemed to be an original and all of which counterparts taken together shall constitute but one and the same instrument. The execution of this Agreement by any -17- {.e to 10 2010 2: 02P" 717-975-392 p. 30 party hereto will not become effecy_ive until counterparts hereof have been executed by all the parties hereto. EXECUTED in triplicate on the day and year first above written. ary Etter IIssinger Sarah H. Dough in iff Attorn y for F? reg zl t Stanley E. Dou as ]A t Att r ey for efendant a?1cj.?Ol? ?? to 201lA -Z 3t 1 2 QAsw=zOQLW 25 yt t Sarah B. Douglas, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY : PENNSYLVANIA VS. : CIVIL ACTION Stanley E. Douglas, : NO. 08-7373 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under § 3301(c) of the Divorce Code was filed on December 19, 2008 and served on December 31, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of the notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Date: ) l / Ill Sarah B. Dougl s, Plaintiff 0 . bti t. A A? ?? 3 FQh 'Q ?^?.? '.:?^' n;.ssinge^ D;.ssinger 717-975-394 p,12 Sarah B. Douglas, : IN THE COURT OF COMMON FLEAS Plaintiff : OF CUMBERLAND COUNTY : PENNSYLVANIA VS. : CIVIL ACTION ,Stanley E. Douglas, : NO. 08-7373 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF CONSFM 1. A Complaint in divorce under 5 3301(c) of the Divorce Code was filed on December 19, 2008 and served on December 31, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of the notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. G.S. §4944 relating to unsworn falsification to authorities. Date: t?'?q?o20lO S anley E. D glas, Defendant s i w S:R?4a r. Gw ' r Tow CIts Sarah B. Douglas, Plaintiff VS. Stanley E. Douglas, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA : CIVIL ACTION : NO. 08-7373 CIVIL TERM : 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 in Divorce without notice. 2. I understand that I may lose rights concerning alimony, alimony pendente lite, 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 statements herein are made subject to the penalties of 18 Pa. C . S . §4904 relating to unsworn falsification to authorities. Date 3I I i 0 Sarah B. Dougl s, Plaintiff N ca 3 i A r W Feb 18 2010 1 :55P'11 7' i. s ?. r??er z ss i. nger C!-4 717-975-3924 Sarah B. Douglas, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY : PENNSYLVANIA VS. : CIVIL ACTION Stanley E. Douglas, : NO. 08-7373 CIVIL TERM Defendant : IN DIVORCE MAIV39R OF MTICS OF INT HTION TO R$QUZST EXTRY OF A DIVOT= DZCMXZ UNDZR 53301(c) OF THE DiVORCR CWZ 1. I consent to the entry of a final Decree in Divorce without notice. 2. I understand that I may lose rights concerning alimony, alimony pendente lite, 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 statements herein are made subject to the penalties of 18 Pa.C.S. 54904 relating to unsworn falsification to authorities. Date: St n e E. Dou as, Defendant p.11 b ca s ?v cr: ? i w ea FES I's 20 Sarah B. Douglas, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY : PENNSYLVANIA VS. : CIVIL ACTION Stanley E. Douglas, : NO. 08-7373 CIVIL TERM Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Grounds for divorce: Irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: December 31, 2008, by United States Certified Mail, Restricted Delivery. 3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: By Plaintiff March 1, 2010; by Defendant February 19, 2010. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in § 3301(c) Divorce filed with the Prothonotary: March 2, 2010; Date Defendant's Waiver of Notice in § 3301(c) Divorce filed with the Prothonotary: March 2, 2010. Respectfully submitted, Date: March 2, 2010 DISSINGER AND DISSINGER ti Mary A. Etter Dissinger-,-;77' Attorney at Law Supreme Court ID #27736 28 North Thirty-second Street Camp Hill, PA 17011 ra (717) 975-2840 °-cb (717)975-3924 - fax cc: Gregory S. Hazlett, Esquire Sarah B. Douglas tv r- a Sarah B. Douglas, Plaintiff VS. Stanley E. Douglas, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA : CIVIL ACTION : NO. 08-7373 CIVIL TERM : IN DIVORCE MOTION TO ENTER CUSTODY AGREEMENT AND NOW comes Mary A. Etter Dissinger, Esquire, who requests the Court to enter the attached Stipulation as an Order of Court and in support of the Motion avers as follows: 1. Movant is counsel for Plaintiff, Sarah B. Douglas. 2. The Stipulation of the parties is attached hereto as Exhibit "A". 3. Attached is a proposed Order of Court for the Court to enter the Stipulation. (See Exhibit "B" attached) 4. Attorney Hazlett, counsel for Stanley E. Douglas concurs in the filing of this Motion. m T° ? WHEREFORE, it is respectfully requested that the attached Exhibit "B" be made an Order of Court. Respectfully Submitted, DISSINGER & DISSINGER Mary A. Etter Dissinger, Attorney at Law Supreme Court ID #27736 28 North Thirty-second Street Camp Hill, PA 17011 (717)975-2840 (717) 975-3924 - fax ?., U r_uIU I; 0-tri7 uissinger & llissinger CH 717-975-3924 p.5 Sarah B. Douglas, Plaintiff VS. Stanley E. Douglas, Defendant : IN THE CCURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA : CIVIL ACTION : NO. 08-7373 CIVIL TERM : IN DIVORCE stipulation for Entry of a Custody Order And now comes Sarah B. Dcuglas and Stanley E. Douglas and request the court to enter tee following Agreement as an order of Court: 1. This Agreement shall supercede all price agreements and the order of custody shall supercede all prior custody orders. 2. T'r_e parties shall have shared legal custody and control of Wendy A. Douglas, bcrn November 18, 1994, Tyler A. Douglas, born December 2, 2001 and Sean R. Douglas, born March 30, 2007. 3. Mother shall have primary physical custody of all children. 4. Father shall have such rights of partial custody as follows: av 1. Alternate weekends from Friday at 4:00 P.M. until Sunday at 7:00 p.m. co enc ng February 19 2010. ?. ?v -Fufh Pr s' J 60V - l?pP Div p - fP% f r S"j I ba JJ ?14P 'q 00 y) I I d y-efV (P Ad Fr I ?aY a-1 $4k / -/; sk 5. Each party shall be en-itled to 8 days of vacation to 1 be taken four days at a ti Ir_e . 6. The Christmas holiday shall be alternated so that in EXHIBIT I -j?- even numbered years Mother will have from December 24, ' at 7:00 p.m. until December 25, at 7:00 p.m., and Father will have the from December 25 at 7:00 p.m. until December 26 at 7:00 p.m. In odd numbered years Mothers holiday will be from December 25 at 7:00 p.m. until December 26 at 7:00 p.m. and Father's holiday will be from December 24 at 7:00 p.m. until December 25 at 7:00 p.m. 7. Father shall be entitled to custody at such other times as the parties may agree upon. $. The party commencing their period of custody with the children shall be responsible for "picking up" the children. The parent relinquishing custody shall insure that the exchange goes smoothly, such as bags and packed and ready at the door, the walk and drive a cleared of snow and other obstructions, and the children will be dressed and ready at the exchange time. 9. If the children are to be taken out of state by anyone, the party in whose custody they would be shall notify the other parent no less than ten (10) days in advance of where the children will be, providing a street address, name of town and state or province and land line telephone number and a cell telephone number if there is one. In the event the custodial parent is not driving, he or she shall provide the other parent with the name of the transporter and the means of transportation including departure point and arrival point and scheduled times of departure and arrival. reo Ib euiu i_nnrm _ uissinger?& Dissinger LH '/1'/-y'/5-;1824 10. Father shall provide to _,4oaher the birth certificate and social security card and social security number for Wendy within three (3) days of signing this Agreement. 11. Father shall within three (3) days of signing this Agreement provide Mother with copies of all Wendy's medical cards, medical insurance Forms and papers. Respectfully Submitted: DISSINGER AND DiSSINGER Sarah B. Douglas, ?I l r? J plaintiff Stanley E. uglas 2.-/4-.9010 C? A Mary A. Etter Di finger Attorney for Plaintiff' Supreme Court I.U. #27736 28 North Thirty-Second Street Camp H-411 PA 17011 (717) 840 // Gregg S . Hai gott Ar-to ey for Defendant 7 st Main Street Mechanicsburg, PA 17055 (717) 790-5500 aNRl/o s1 t-eb 18 eulu 1:bbvm Uissinger & Vissinger CH /1'/-`3'/`s-38 4 Sarah B. Douglas, Plaintiff vs. Stanley E. Douglas, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CVIL ACTION NO. 08-7373 CIVIL TERM IN DIVORCE ORDER AND NOW, this day of __, 201C, upon consideration of the Agreement of the Parties and upon motion of Mary A. Etter Dissinger, Esquire, it is ORDERED and DECREED as fol_cws: 12. This Crder supercedes all prior custody orders. p.8 13. The parties shall have shared legal custody and control 2r of Wendy A. Douglas, born November. 48, 1994, Tyler_ A. `43 i?o Douglas, born Decerrber 2, 2001 and Sean R. Douglas, h? born Mareh 30, 2007. 14. Mother shall have primary physical custody of all children. 15. Father shall have such rights of partial custody as follows: 1. Alternate wee.<ends from Friday at 4:00 p.m. until Sunday at 7:00 p.m. commence'g F'ebrYarx 19, 2010 ro + 4-h r.5 -- N oov- erkelvd h s hart now va SIP 1 - pool t 0 7 ?°i"1, Gsy? cht1drtonrow Fr- iday -f'O M y:ov 15. Each party shall be entitled to 8 days of vacation to be taken `our days at a tirr.e. [EXHIBIT IQ CU IU l:DZ)rIII liissinger at Dissznger L:H '/1'/-5'/'J-39r?4 p ?? 17. The Christmas holiday shall be alternated so that in even numbered years Mot:~er will have from December 24 at 7:00 p.m. until December at 7:00 p.m., and Father will have the from December 25 at 7:00 p.m. until December 26 at 7:00 p.m. In odd numbered years Mothers holiday will be from December 25 at 7:00 p.m. until December 26 at 7:00 p.m. and Father's holiday will be from December 24 at 7:00 p.m. until December 2,_ at 7:00 p.m. 18. Father shall be entitled to custody at such other tunes as the parties may agree upon. 19. The party commencing their period of custody with the children shall be responsible for "picking up" the children. The parent relinquishing custody shall insure that the exchange goes smoothly, such as bags and packed and ready at the door, the walk and drive a cleared of snow and other obs,?ructions, and the children will be dressed and ready at the exchange time. 20. If the children are to be taken out of state by anyone, the party in whose custody they would be shall notify the other parent no less than ten (10) days in advance of where the children will be, providing a street address, name of town and state or province and land lire telephone number and a cell telephone number if there is one. In the event the custodial parent is not driving, he or she shall provide the other parent with the name of the transporter and the means of transportation including departure point and arrival rcu A0 culu I:Z)Z)rn uissinger & Lissinger l;H f1f-?J/5-Ji3e4 point and scheduled times of departure and arrival. 21. Father shall provide to Mother the birth certificate and social security card and social security number for Wendy within three (3) days. 22. Father shall within three (3) days provide Mother with copies of all Wendy's medical cards, medical insurance forms and papers. BY THE LOUR'_: P. 10 J. Sarah B. Douglas, Plaintiff VS. Stanley E. Douglas, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA CIVIL ACTION NO. 08-7373 CIVIL TERM 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 Gregory S. Hazlett, Esquire, counsel for Defendant by depositing same in the United States Mail, postage prepaid, addressed as follows: Gregory S. Hazlett 7 West Main Street Mechanicsburg, PA 17055 Date: Mary . Etter Dissinger, Esq. Feb 18 2010 1:54PM Dissinger & Dissinger rt= 77.7-x'75-?S24 ^.5 Sarah B. Douglas, IN THE COURT OF C:OtWON PLEAS Plaintiff OF CUMBERLAND COUNTY PENNSYLVANIlk VS. CIVIL AC''TIO14 0 Stanley E. Douglas, : NO. 08--7373 CIVIL TE m Defendant : IN DIVORCE s ti Stipulation for Zntry of a custody Qrdex ' .? 3 And now comes Sarah B. Douglas and Stanley E. gl* er`, and request the court to enter the following Agreeme ais a t Order of Court: 1. 2. 3. 4. 5. This Agreement shall supercede all prior agreements and the order of custody shall supercede all prior custody orders. The parties shall have shared legal custody and control of Wendy A. Douglas, barn November 18, 1994, Tyler A. Douglas, born December 2, 2001 and Sean R. Douglas, born March 30, 2007. Mother shall have primary physical custody of all children. Father shall have such rights of partial custody as follows: O 1. Alternate weekends from Friday at 4:00 P.M. until ,,)INN Sunday at 7:00 p.m. co enc ng February 19 2010 ?. ,v -FuFh?r s` JoKt- urP+°e??we? -F?Fh?. sG?al? ha,va? ??p 41 (P A) Fr, play «-?-? c? 1dreN Each party shall be entitled to 8 days of vacation to be taken four days at a time. 6. The Christmas holiday shall be alternated so that in even numbered years Mother will have from December 24, ' at 7:00 p.m. until December 25, at 7:00 p.m., and Father will have the from December 25 at 7:00 p.m. until December 26 at 7:00 p.m. In odd numbered years Mothers holiday will be from December 25 at 7:00 p.m. until December 26 at 7:00 p.m. and Father's holiday will be from December 24 at 7:00 p.m. until December 25 at 7:00 p.m. 7. Father shall be entitled to custody at such other times as the parties may agree upon. 8. The party commencing their period of custody with the children shall be responsible for "picking up" the children. The parent relinquishing custody shall insure that the exchange goes smoothly, such as bags and packed and ready at the door, the walk and drive a cleared of snow and other obstructions, and the children will be dressed and ready at the exchange time. 9. If the children are to be taken out of state by anyone, the party in whose custody they would be shall notify the other parent no less than ten (10) days in advance of where the children will be, providing a street address, name of town and state or province and land line telephone number and a cell telephone number if there is one. In the event the custodial parent is not driving, he or she shall provide the other parent with the name of the transporter and the means of transportation including departure point and arrival point and scheduled times of departure and arrival. Feb JIB 2010 1:55PM ??v 7,^-X75-3D?4 Dissinger & Dissinger de to Mother the bi rt}Z certificate e shall prOvl card and social security 10. Father fox social security Of sign irg this Agreement- and Wendy within three (3) days o clays of Signing this 's Father shall Within three w (3) ith copies of all Wendy 11, rovide Mather and papers. pgreemcnt P insurance forms medical cards' medical Respectfully Submitted: DISSINGER A1W DISSI Doug las, Ito Sarah $- Plaintiff Puglaso Stanley Zo !O < 2rl 4 P er D finger Mary A. for Plaintiff ,ttorneyCourt I.D. #21736 Supreme Second Street 28 North Thirty-Second 17Q1I camp Kill 2 A (717) /// Gr7SItcleymsa ?ndant tfor A 7 in street 1'1055 Mechanicsburg ('71'1) 7 a/17 110 SARAH B. DOUGLAS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. DOMESTIC RELATIONS SECTION STANLEY E. DOUGLAS, PACSES NO. 517110656 Defendant DOCKET NO. 102 SUPPORT 2009 n DOUGLAS SARAH B IN THE COURT OF COMMON PLEA , . Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSVANW =?7 `? Uj, - -- DOMESTIC RELATIONS SECTION 7 l ? V. . STANLEY E. DOUGLAS, PACSES NO. 894110596 co " Defendant/Respondent DOCKET NO. 08-7373 CIVIL' ORDER OF COURT AND NOW, this 23rd day of February, 2010, this matter having been scheduled for a hearing de novo before the Support Master on the Wife's petition for modification of child support and petition for modification of alimony pendente lite, and the Husband having withdrawn his request for said hearing, upon recommendation of the Master it is ordered and decreed as follows: 1. The order entered to 102 Support 2009 on November 24, 2009 is affirmed as a final order. 2. The order entered to 08-7373 Civil Term on November 24, 2009 is affirmed as a final order. By th Court, Albert H. Masland, J. Cc: Sarah B. Douglas Stanley E. Douglas Mary A. Etter Dissinger, Esquire For the Plaintiff/Petitioner Gregory S. Hazlett, Esquire For the Defend ant/Respondent DRO/rjs IN THE COURT OF COMMON PLEAS OF Sarah B. Douglas CUMBERLAND COUNTY, PENNSYLVANIA V. Stanley E. Douglas NO. 08-7373 DIVORCE DECREE AND NOW, h dC can 10 '1818 , it is ordered and decreed that Sarah B. Douglas plaintiff, and Stanley E. Douglas , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") NONE. The Property Settlement Agreement of the parties dated March 1, 2010, is hereby incorporated but not merged in this decree of divorce. By the Court, J Attest: J. Prothonotary It ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 03/03/10 Case Number (See Addendum for case summary) Employer/Withholder's Federal FIN Number SECCO INCORPORATED 1111 PRIMROSE AVE CAMP HILL PA 17011-6922 517110656 102 S 2009 08-7373 CIVIL OOriginal Order/Notice OAmended Order/Notice OTerminate Order/Notice QOne-Time Lump Sum/Notice RE: DOUGLAS, STANLEY E. Employee/Obligor's Name (Last, First, MI) 453-19-6027 Employee/Obligor's Social Security Number 9289102071 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. n o $ _ 005.00 per month in current child support o 1 $ , 50.00 per month in past-due child support Arrears 12 weeks or greater? ?o $ oo per month in current medical support o $ . o . oo per month in past-due medical support $ o . oo per month in current spousal support c r^ ?-rt $ o . oo per month in past-due spousal support ' (? = frn' $ 0.00 per month for genetic test costs C O $ o . oo per month in other (specify) u1 $ one-time lump sum payment C" -c for a total of $ 1,055.00 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: $ 243.46 per weekly pay period. $ 527.50 per semimonthly pay period (twice a month) $ 486.92 per biweekly pay period (every two weeks) $ 1, 055.00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). Pennsylvania law (23 PA C.S. § 4374(b)) requires remittance by an electronic payment method if an employer is ordered to withhold income from more than one employee and employs 15 or more persons, or if an employer has a history of two or more returned checks due to nonsufficient funds. Please call the Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. PA FIPS CODE 42 000 00 Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBE N O TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: rt H. Masland, Judge DRO: R. J. Shadday Form EN-028 Rev.5 Service Type M OMB No.: 0970-0154 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS If hecked you are required to provide a opy of this form to your m loyee. If yo r employeevyorks in.a state that is diferent from the state that issued this or?er, a copy must be provicedpto 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. 2321546720 THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : I] THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 0 EMPLOYEE'S/OBLIGOR'S NAME: DOUGLAS, STANLEY E. EMPLOYEE'S CASE IDENTIFIER: 9289102071 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: If you or your employee/obligor have any questions, DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT 13 N. HANOVER ST by telephone at (717) 240-6225 or P.O. BOX 320 by FAX at (717) 240-6248 or CARLISLE PA 17013 by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Rev.5 Service Type M OMB No.: 0970-0154 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: DOUGLAS, STANLEY E. PACSES Case Number 517110656 Plaintiff Name SARAH B. DOUGLAS Docket Attachment Amount 00102 S 2009 $ 1,055.00 Child(ren)'s Name(s): DOB SEAN R. DOUGLAS 03/30/07 T ,Y,LER A. D00GLAS 3.2/02/01 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 PACKS Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Addendum Form EN-028 Rev.5 Service Type M OMB No.: 0976-0154 Worker I D $ IATT SARAH B. DOUGLAS, Plaintiff/Petitioner VS. STANLEY E. DOUGLAS, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 08-7373 CIVIL TERM IN DIVORCE PACSES CASE: 894110596 C K . Z f_ i~ ? c Z N Q i ro w cn ao ORDER OF COURT AND NOW to wit, this 3rd day of March, 2010, it is hereby Ordered that the Order for Alimony Pendente Lite is terminated, effective March 1, 2010, pursuant to the Petitioner's request to terminate and remit all arrears.. This Order shall become final twenty (20) 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's Office for a hearing de novo before the Court. BY THE COURT: 0 -n By 9 rn arlig, lbei f. Masland, J. DRO: R.J. Shadday xc: Petitioner Respondent Mary A. Etter-Dissinger, Esq. Gregory S. Hazlett, Esq. Form OE-001 Service Type: M Worker: 21005 NAR 0 0 go Sus ?enc ?1 o?y ?s o 3/ ?// o 2A?t 0-4- ? 3/3/ 1b Otcc-?Ll i'ldcl,)c-, Sarah B. Douglas, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY . PENNSYLVANIA C7 C= VS. C , -n CIVIL ACTION r;-),., ni "I Stanley E. Douglas, : NO. 08-7373 CIVIL TERM -nFn Defendant : IN DIVORCE ' cn 0 t. "} ` =K C) C:_ dm o ? ORDER AND NOW, this 5 day of 2010, upon consideration of the Agreement of the Parties and upon motion of Mary A. Etter Dissinger, Esquire, it is ORDERED and DECREED as follows: 1. 2. 3. 4. This Order supercedes all prior custody orders. The parties shall have shared legal custody and control of Wendy A. Douglas, born November 8, 1994, Tyler A. Douglas, born December 2, 2001 and Sean R. Douglas, born March 30, 2007. Mother shall have primary physical custody of all children. Father shall have such rights of partial custody as follows: a. Alternate weekends from Friday at 4:00 p.m. until Sunday at 7:00 p.m. commencing February 19, 2010. b. On Father's non-weekend he shall have the children on Friday from 4:00 p.m. to 7:00 p.m. 5. Each party shall be entitled to 8 days of vacation to be taken four days at a time. 6. The Christmas holiday shall be alternated so that in even numbered years Mother will have from December 24, at 7:00 p.m. until December 25, at 7:00 p.m., and Father will have the from December 25 at 7:00 p.m. until December 26 at 7:00 p.m. In odd numbered years Mothers holiday will be from December 25 at 7:00 p.m. until December 26 at 7:00 p.m. and Father's holiday will be from December 24 at 7:00 p.m. until December 25 at 7:00 p.m. 7. Father shall be entitled to custody at such other times as the parties may agree upon. 8. The party commencing their period of custody with the children shall be responsible for "picking up" the children. The parent relinquishing custody shall insure that the exchange goes smoothly, such as bags and packed and ready at the door, the walk and drive a cleared of snow and other obstructions, and the children will be dressed and ready at the exchange time. 9. If the children are to be taken out of state by anyone, the party in whose custody they would be shall notify the other parent no less than ten (10) days in advance of where the children will be, providing a street address, name of town and state or province and land line telephone number and a cell telephone number if there is one. In the event the custodial parent is not driving, he or she shall provide the other parent with the name of the transporter and the means of transportation including departure point and arrival point and scheduled times of departure and arrival. 10. Father shall provide to Mother the birth certificate and social security card and social security number for Wendy within three (3) days. 11. Father shall within three (3) days provide Mother with copies of all Wendy's medical cards, medical insurance forms and papers. BY THE COURT: N -- \ ?-, C?? £S ,nla (L LL( l SARAH B. SNYDER, IN THE COURT OF COMMON PLEAS OF (formerly Sarah B. Douglas), CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. CIVIL ACTION - LAW 4.? STANLEY E. DOUGLAS, NO. 2008-7373 Mm ??- Defendant IN CUSTODY vm Prior Judge: The Honorable M. L. E bert, Jr. C -?' t C.- COURT ORDER '' { AND NOW, this day of June, 2011, upon consideration of the attached Custody Conciliation Report, it is ordered that this Court's prior Order of March 5, 2010, is reaffirmed subject to the following modifications: 1. The father, Stanley E. Douglas, shall enjoy primary physical custody of Wendy A. Douglas, born November 8, 1994. The mother, Sarah B. Snyder, shall enjoy periods of temporary physical custody with Wendy at such times as agreed upon by the parties. 2. Paragraph 4(B) of the March 5, 2010, Order shall be modified such that father's custody on his non-weekend shall be from Friday at 4:00 p.m. until Saturday at noon. 3. Paragraph 9 of the March 5, 2010, Order is modified such that either parent may take the children out of state subject, however, to the requirement that the parent must notify the non-custodial parent as to where they will be, who they will be with and provide a telephone number for contact. 4. Father shall attend and complete an anger management counseling program at his own expense. 5. Both parties shall give at least ten days notice with respect to exercising vacation time pursuant to the March 5, 2010, Order. BY THE COURT, -? ?4 V - Vrl M. L. Ebert, Jr., Judge cc: Gregory S. Hazlett, Esquire Mated ? Ms. Sarah B. Snyder oopio4 tf 61 ?0 I SARAH B. SNYDER, (formerly Sarah B. Douglas), Plaintiff vs. STANLEY E. DOUGLAS, Defendant Prior Judge: The Honorable M. L. Ebert, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-7373 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Wendy A. Douglas, born November 8, 1994, Tyler A. Douglas, born December 2, 2001, and Sean R. Douglas, born March 30, 2007. 2. A Conciliation Conference was held on June 7, 2011, with the following individuals in attendance: The mother, Sarah B. Snyder, who appeared without counsel, and the father, Stanley E. Douglas, with his counsel, Gregory S. Hazlett, Esquire. 3. The parties agree to the entry of an Order in the form as attached. Date: June l '2011 Hubert X. Gilroy, Custody Conciliar SARAH B. SNYDER, IN THE COURT OF COMMON PLEAS (formerly Sarah B. Douglas), CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 2008-7373 v.a CIVIL ACTION-LAW 's- STANLEY E. DOUGLAS, IN CUSTODY Defendant c PETITION FOR MODIFICATION AND CONTEMPT AND NOW, comes the Petitioner, Sarah B. Snyder, by and through her attorney,; Timothy L. Czekaj of Czekaj Law Office, and for her Petition for Modification and Contempt against the Respondent respectfully avers as follows: Petitioner is Sarah B. Snyder, formerly known as Sarah B. Douglas, who resides at 1827 West Lisburn Road, Carlisle, Pennsylvania 17015. 2. Respondent is Stanley E. Douglas, who resides at 1330 Williams Grove Road, Mechanicsburg, Pennsylvania 17055. 3. On March 5, 2010, and reaffirmed subject to modifications on June 9, 2011, the Honorable M. L. Ebert, Jr. entered Orders of Court pertaining to the custody of minor children Tyler, Sean, and Wendy Douglas. True and correct copies of the respective Orders are attached hereto, marked as Exhibit "A" and Exhibit "B" and incorporated by reference hereto. COUNTI MODIFICATION OF 3/5/10 and 6/9/11 CUSTODY ORDERS 4. Petitioner incorporates by reference the averments set forth in paragraphs 1-4 of the Petition as though fully set forth herein. 5. Petitioner seeks modification of both Custody Orders, and in support thereof, Petitioner avers that said Custody Orders should be modified because: 6?:)s C?a1-, s $3?1 a. Tyler Douglas's school schedule is such that Respondent's current visitation time is impracticable. b. The parties are currently practicing custodial habits, routines and patterns that are contrary to the provisions of the current Custody Orders. C. Ambiguous provisions of said Orders regarding "picking up" the children and vacation time have created substantial controversy and resulted in the children losing opportunities to participate in various school-related and extracurricular activities. d. Tyler and Sean Douglases' behavior and development is suffering as a result of extended time with Respondent. 6. Petitioner requests that said Custody Orders be modified as follows: a. Father shall have rights of partial custody on alternate weekends from Friday at 5:00 p.m. until Sunday at 6:00 p.m. b. Father shall not have the children on the Friday of his non-weekend. Each party shall be entitled to 8 days of vacation to be taken NO MORE THAN four days at a time. d. The odd and even years of the holiday schedule shall be reversed, as the inverse of the Order is currently being practiced. The person "picking up" the children while commencing a period of custody shall be a parent/stepparent, grandparent, or a non-related adult over the age of 21 to be previously agreed upon by the parties. f. Mother shall no longer enjoy periods of custody of child Wendy Douglas. g. Both parties shall provide 10 days WRITTEN notice before exercising vacation days. Vacation days may not be denied if no previously scheduled events exist on the requested days. Vacation days may not be taken on birthdays or holidays. h. Children shall be permitted to attend and participate in any appropriate after school/extracurricular activity of their choosing so long as said activity does not conflict with an already scheduled vacation or holiday time. Participation will be permitted regardless of which party has custody at that time. Notice of said activity must be provided to the noncustodial parent at least 7 days prior to the activity. If the custodial parent is not willing or unable to transport and/or facilitate the child to the activity, the noncustodial parent and/or an approved "pick up" person may do so. WHEREFORE, Petitioner respectfully requests that this Honorable Court modify the 3/5/10 and 6/9/11 Orders in accordance with the requests of Petitioner as set forth in this Petition. COUNT II CONTEMPT FOR DISOBEDIENCE OF 6/9/11 ORDER 7. Petitioner incorporates by reference the averments set forth in paragraphs 1-7 of the Petition as though fully set forth herein. Paragraph number 4 of the 6/9/11 Order states that Father shall attend and complete an anger management counseling program at his own expense. A true and correct copy of said Order is attached as Exhibit "B" and incorporated by reference hereto. 9. Respondent has willfully and in bad faith disobeyed this Court's Order, and has failed to attend any anger management counseling programs as of the date of this Petition. 10. Petitioner has no reason to believe that Respondent will seek anger management counseling in the future. 11. The best interest of the children will be served by Respondent participating in said anger management counseling. WHEREFORE, Petitioner respectfully requests that this Honorable Court: a) Enter an Order of Contempt against Respondent, b) direct Respondent to pay Petitioner's reasonable attorney's fees in the amount of $500.00 pursuant to 23 Pa.C.S.A. § 5339, c) direct Respondent to pay Petitioner's costs, and d) grant such other relief this Court deems just and appropriate. Dated: May 22, 2012 Respectfully submitted. Timothy L. Czekaj, Esquire PA ID No. 210165 Attorney for Petitioner CZEKAJ LAW OFFICE 315 N. Front Street Harrisburg, PA 17101 (717) 236-9377 VERIFICATION I verify that the statements made in this petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unworn falsification to authorities. 4 Dated: Sarah B. Snyder Sarah B. Douglas, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY PENNSYLVANIA C o vs. n CIVIL ACTION € v r? Stanley E. Douglas, : NO. 08-7373 CIVIL TERM '- _T1Fq Defendant : IN DIVORCE c.n O? +U i1c - .? m J o rv ? ORDER AND NOW, this day of Marc, , 2010, upon consideration of the Agreement of the Parties and upon motion of Mary A. Etter Dissinger, Esquire, it is ORDERED and DECREED as follows: 1. This Order supercedes all prior custody orders. 2. The parties shall have shared legal custody and control of Wendy A. Douglas, born November 8, 1994, Tyler A. Douglas, born December 2, 2001 and Sean R. Douglas, born March 30, 2007. 3. Mother shall have primary physical custody of all children. 4. Father shall have such rights of partial custody as follows: a. Alternate weekends from Friday at 4:00 p.m. until Sunday at 7:00 p.m. commencing February 19, 2010. b. On Father's non-weekend he shall have the children on Friday from 4:00 p.m. to 7:00 p.m. EXHIBIT 1 .9 A 5. Each party shall be entitled to 8 days of vacation to be taken four days at a time. 6. The Christmas holiday shall be alternated so that in even numbered years Mother will have from December 24, at 7:00 p.m. until December 25, at 7:00 p.m., and Father wi11 have the from December 25 at 7:00 p.m. until December 26 at 7:00 p.m. In odd numbered years Mothers holiday will be from December 25 at 7:00 p.m. until December 26 at 7:00 p.m. and Father's holiday will be from December 24 at 7:00 p.m. until December 25 at 7:00 p.m. 7. Father shall be entitled to custody at such other times as the parties may agree upon. 8. The party commencing their period of custody with the children_ shall be responsible for "picking up" the children. The parent relinquishing custody shall insure that the exchange goes smoothly, such as bags and packed and ready at the door, the walk and drive a cleared of snow and other obstructions, and the children will be dressed and ready at the exchange time. 9. If the children are to be taken out of state by anyone, the party in whose custody they would be shall notify the other parent no less than ten (10) days in advance of where the children will be, providing a street address, name of town and state or province and land line telephone number and a cell telephone number if there is one. In the event the custodial parent is not driving, he or she shall provide the other parent with the name of the transporter and the means of transportation including departure point and arrival point and scheduled times of departure and arrival. 10. Father shall provide to Mother the birth certificate and social security card and social security number for Wendy within three (3) days. 11. Father shall within three (3) days provide Mother with copies of all Wendy's medical cards, medical insurance forms and papers. BY THE COURT: i SARAH B. SNYDER, IN THE COURT OF COMMON PLEAS OF (formerly Sarah B. Douglas), CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW 47) N vs. c 3 ? STANLEY E. DOUGLAS, NO. 2008-7373 Mm <= r?r Defendant IN CUSTODY z j Prior Judge: The Honorable M. L. E bert, Jr. COURT ORDER - ?' n AND NOW, this , day of June, 2011, upon consideration of the attached Custody Conciliation Report, it is ordered that this Court's prior Order of March 5, 2010, is reaffirmed subject to the following modifications: I . The father, Stanley E. Douglas, shall enjoy primary physical custody of Wendy A. Douglas, born November 8, 1994. The mother, Sarah B. Snyder, shall enjoy periods of temporary physical custody with Wendy at such times as agreed upon by the parties. 2. Paragraph 4(B) of the March 5, 2010, Order shall be modified such that father's custody on his non-weekend shall be from Friday at 4:00 p.m. until Saturday at noon. 3. Paragraph 9 of the March 5, 2010, Order is modified such that either parent may take the children out of state subject, however, to the requirement that the parent must notify the non-custodial parent as to where they will be, who they will be with and provide a telephone number for contact. 4. Father shall attend and complete an anger management counseling program at his own expense. EXHIBIT 5. Both parties shall give at least ten days notice with respect to exercising vacation time pursuant to the March 5, 2010, Order. BY THE COURT, -? U'A - Vri M. L. Ebert, Jr., Judge MaIed cc: '/ Gregory S. Hazlett, Esquire ? Ms. Sarah B. Snyder COP (o glif 1 W SARAH B. DOUGLAS IN THE COURT OF COMMON PLEAS OF PLAINTIFF PENNSYLVA 141 CUMBERLAND COUNTY Cn z , , C- .. ,; tm V t3? ' c 2008-7373 CIVIL ACTION LAW TES; r; ° - STANLEY E. DOUGLAS j C7 N) IN CUSTODY _ DEFENDANT °? cl cz s ORDER OF COURT AND NOW, Tuesday, June 05, 2012 , upon consideration of the attached Complaint, it is herehy directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, June 21, 2012 at 8:30 AM _ ......... ................... .....--- ---- tor 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. 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/ Hubert X. Gilro Es . 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 conterence 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 ?Cer1. ,Ary tla?? Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 Wit ad * 91C ?`ecl Kv Alri le - 6v-/1 ?/a? P ? ? 0011111? SARAH B. SNYDER, : IN THE COURT OF COMMON PLEAS (formerly Sarah B. Douglas), : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : NO. 2008-7373 V. {7 : CIVIL. ACTION-LAW STANLEY E. DOUGLAS, : IN CUSTODY ?:. Defendant r0 AFFIDAVIT Of SFJLV- WE C-) 3 I, Timothy L. Czekaj, Esquire, counsel for Petitioner, hereby verify that Peti Petition for Modification and Contempt was served on June 13, 2012 pursuant to and in accordance with C.CJLP.1915.3-5. Dated: July 27, 2012 Respectfully submitted, 0 Timothy L. Czekaj, Esquire PA ID No. 210165 Attorney for Petitioner CZEKAJ LAW OFFICE 315 N. Front Street Harrisburg, PA 17101 (717) 236-9377 SARAH B. DOUGLAS, Plaintiff vs. STANLEY E. DOUGLAS, Defendant Prior Judge: The Honorable M. L. Ebert, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAT : CIVIL ACTION -LAW NO. 2008-7373 IN CUSTODY COURT ORDER AND NOW, this Sr ? day of 2012, upon consideration o the attached Custody Conciliation Report, it is ordered and directed that the prior Orders entered i this case are vacated and replaced with the following Order: 1. The mother, Sarah B. Douglas, and the father, Stanley E. Douglas, shall enjoy sh ed legal custody of Wendy A. Douglas, born November 8, 1994, Tyler A. Douglas, born December 2, 2001, and Sean R. Douglas, born March 30, 2007. 2. The father shall enjoy primary physical custody of the minor child Wendy, and mother shall enjoy primary physical custody of the minor children Tyler and S an. 3. The mother shall enjoy periods of partial physical custody with Wendy as ag eed upon by the parties. 4. The father shall enjoy periods of partial custody with Tyler and Sean as A. The parties shall go on a 2-1 schedule with father having two weeker row and mother having the third weekend with them following t schedule thereafter. The weekends shall commence at 5:00 p.m on and end at 6:00 p.m. on Sunday when the children have school on but end at 8:00 p.m. on Sunday when the children do not have school, in a 2-1 B. At such other times as agreed upon by the parties. 12. This Order is entered pursuant to an agreement reached by the parties at a Conciliation Conference. In the event either party desires to modify this Order, party may petition the Court to have the case again scheduled with the Conciliator for a conference. No party shall be permitted to relocate the residence of the child where said relocation significantly impair the ability to exercise custody unless every individual who has custo rights to the child consents to the proposed relocation or the court approves the prop( relocation. Any party proposing to relocate MUST comply with 23 Pa. C.S. § 5337. BY THE COURT, M. L. Ebert, Jr., Judge cc: r/ Timothy L. Czekaj, Esquire ?Gregory S. Hazlett, Esquire 4p res / -r v c-j C -y=/rr...rn .R6r Ln r_ a C- C) e- w W S O C: C a ?d ca ?a , 71> SARAH B. DOUGLAS, Plaintiff vs. STANLEY E. DOUGLAS, Defendant Prior Judge: The Honorable M. L. Ebert, Jr. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAN CIVIL ACTION - LAW NO. 2008-7373 IN CUSTODY 1. The pertinent information pertaining to the children who are the subject of litigation is as follows: Wendy A. Douglas, born November 8, 1994, Tyler A. Douglas, December 2, 2001, and Sean R. Douglas, born March 30, 2007. 2. A Conciliation Conference was held on July 27, 2012, with the following indivi in attendance: The mother, Sarah B. Douglas, who appeared with her counsel, Timothy L. Esquire, and the father, Stanley E. Douglas, with his counsel, Gregory S. Esquire. 3. The Conciliator recommends an Order in the form as attached. Date: July 2012 Hubert X. Custody 0 ?y, Esquire iator f