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HomeMy WebLinkAbout09-0637i9 KIMBERLY STITT, Plaintiff V. RICKY STITT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 09' 6 G?/?? fcrM . CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'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 1-800-990-9180 or (717) 249-3166 WALKER, CONNOR & JOHNSON LLC 297 Lincoln Way East Chambersburg PA 17201 (717) 262-2185 (717) 262-2187 -Fax IN THE COURT OF COMMON PLEAS OF THE CUMBERLAND COUNTY, PENNSYLVANIA Kimberly Stitt, ) Civil Action -Law Plaintiff, ) vs. ) No. 09-637- Civil Ricky Stitt, ) Def:~c'a..t, lr~ L~ivorc~° a v.m. PRAECIPE FOR WITHDRAWAL AND ENTRY OF APPEARANCE To the Prothonotary: Please withdraw the appearance of Kara W. Haggerty, Esquire, as counsel for the Plaintiff in the above-captioned case and enter the appearance of Martha B. Walker, Esquire as counsel for the Plaintiff. WALKER, CONNOR & JOHNSON, LLC Date: ~ ~ U By: rtha B. Walker, quire ttorney I.D. #15989 247 Lincoln Way East C'!:u:;,bersbu:g, p.? 172!'1 (717) 262-2185 Attorney for Plaintiff Date: f Kara W. Haggerty, Esq r'~ " _ ~ ' -~~ r :~; t ` ?Car `` -~J; ,, _..~~ TA 2OM CSC' &U i ULAKIS Kara W. Haggerty, Esquire Attorney I.D. #: 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 KIMBERLY STITT, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 0 7- ?j 3 7 c,` RICKY STITT, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT 1. Plaintiff is Kimberly Stitt, who currently resides at 62 Quarry Hill Road, Newville Cumberland County, Pennsylvania. >7.1 yi 2. Defendant is Ricky Stitt, who currently resides at 62 Quarry Hill Road, Newville, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 15, 1983 at Walnut Bottom, Cumberland County, Pennsylvania. COUNT I - DIVORCE 5. Paragraphs 1 through 4 of this Complaint are incorporated herein by reference as though set forth in full. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Divorce is sought pursuant to the provisions of the Divorce Code, § 3301(c), in that: a. The marriage is irretrievably broken. b. Plaintiff and Defendant have lived separate and apart since February, 2009 and continue to do so. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in such counseling. 9. The Plaintiff in this action is not a member of the Armed forces. WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce. COUNT II - EQUITABLE DISTRIBUTION 10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference as though set forth in full. 11. Plaintiff and Defendant have acquired property, both real and personal, during their marriage from October 15, 1983, until February of 2009, the date of their separation, which property is "marital property". 12. Plaintiff and Defendant may have owned, prior to marriage, property which has increased in value during the marriage and/or which has been exchanged for other property, which has increased in value during the marriage, all of which property is "marital property". 13. Plaintiff and Defendant have been unable to agree as to an equitable division of said property prior to the filing of this Complaint. WHEREFORE, the Plaintiff requests this Honorable Court to equitably divide all marital property. COUNT III - ALIMONY PENDENTE LITE AND ALIMONY 14. Paragraphs 1 through 13 of this Complaint are incorporated herein by reference as though set forth in full. 15. Plaintiff lacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment. 16. Plaintiff requires reasonable support to maintain herself adequately in accordance with the standard of living established during the marriage. WHEREFORE, Plaintiff requests this Honorable Court to enter an award of alimony pendente lite until final hearing and thereafter to enter an award for alimony. COUNT IV - COUNSEL FEES AND COSTS 17. Paragraphs 1 through 16 of this Complaint are incorporated herein by reference as though set forth in full. 18. Plaintiff has retained the law offices of ABOM & KUTULAKis, L.L.P., but is unable to pay the necessary and reasonable attorney's fees for said counsel. 19. Plaintiff may need to hire experts to appraise the marital property but she lacks funds to pay the necessary and reasonable fees. WHEREFORE, Plaintiff requests this Honorable Court to enter an award of interim counsel fees, costs and expenses and to order such additional sums hereafter as may be deemed necessary and appropriate, and at final hearing to award such additional counsel fees, costs and expenses as are deemed necessary and appropriate. DATE DZ otp o Respectfully submitted, ABOM & KUT ULAKIs, L.L.P. Attorney for Plaini 36 South Hanover Carlisle, PA 17013 (717) 249-0900 VERIFICATION I, Kimberly Stitt, verify that the statements made in this Divorce Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. ?i Date J4! Kimberly Stitt 17r S 1 d W lJJ v Q W Q G c 'T_7f;7 N O ? W -Tl 'rt f't'7 r? -? t OM & LITLILAKIS Kara W. Haggerty, Esquire Attorney I.D. #: 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 KIMBERLY STITT, Plaintiff V. RICKY STITT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. ?? -(y3? G r,/I CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this 7Aday of R66tr"'I , 2009, I, 6nlamAf "arti' 11 hereby certify that I did serve a copy of the Divorce Complaint in the above-captioned matter upon RICKY STITT by personally handing him a copy of said Complaint on the 7A day of 2009 at r )41')) k0j 'Pe AA 17-1V) (location). i `w or, - KIMBERLY STITT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09-637 CIVIL TERM RICKY STITT, Defendant CIVIL ACTION -LAW IN DIVORCE PRAECIPE TO ENTER APPEARANCE I TO THE PROTHONOTARY: Please enter the appearance of Keith O. Brenneman, Esquire and Snelbaker & Brenneman, P. C. as attorneys for Defendant Ricky Stitt in the above-captioned action. SNELBAKER & BRENNEMAN, P. C. BY: Keith O. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 Date: February 25, 2009 (717) 697-8528 Attorneys for Defendant Ricky Stitt LAW OFFICES SNELBAKER BRENNEMAN, P.C. r -,. CERTIFICATE OF SERVICE I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date, a true and correct copy of the foregoing Praecipe to be served upon the person and in the indicated below: FIRST CLASS MAIL POSTAGE PREPAID ADDRESSED AS FOLLOWS: Kara W. Haggerty, Esquire 36 South Hanover Street Carlisle, PA 17013 Keith O. Brenneman, Esquire SNELBAKER & BRENNEMAN, P. C. 44 W. Main Street P. O. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Defendant Ricky Stitt Date: February 25, 2009 LAW OFFICES SNELBAKER & BRENNEMAN, P.C. f? c?? CI -TI . 4 r. _ --a C'tJc do WALKER, CONNOR & JOHNSON LLC 247 Lincoln Way East Chambersburg PA 17201 (717) 262-2185 (717) 262-2187-Fax IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Kimberly Stitt, Civil Action-Law Plaintiff, ) vs. ) No: 09-637 -Civil Ricky Stitt, ) Defendant, ) In Divorce a v.m. PETITION TO SCHEDULE ALIMONY PENDENTE LITE CONFERENCE NOW comes the Petitioner, Kimberly Stitt., by and through her attorney, Martha B. Walker, Esquire, of Walker, Connor & Johnson, LLC, and sets forth the following information in a request for the scheduling of an Alimony Pendente Lite Conference: 1. Plaintiff is a residence of Cumberland County. However, as there is a PFA action against the above-captioned Defendant, Plaintiff's mailing address should be listed as c/o Martha B. Walker, Esquire, 247 Lincoln Way East, Chambersburg, Pennsylvania. Plaintiff's date of birth is November 29, 1958. 2. Defendant resides at 62 Quarry Hill Road, Newville, Cumberland County, Pennsylvania. Defendant's date of birth is September 16, 1957. 3. (a) Plaintiff and Defendant were married on October 15, 1983 in Walnut Bottom, Pennsylvania. (b) Plaintiff and Defendant were separated on June 10, 2009. (c) Plaintiff filed a Complaint in Divorce on February 6, 2009. Said Complaint raised the issue of alimony pendente lite. The fee for said count of alimony pendente lite was paid on the aforementioned date. 4. Plaintiff and Defendant are the parents of the following children born of the marriage: adult children. 5. Plaintiff seeks support for the following persons: Plaintiff, Kimberly K. Stitt. 6. (a) Plaintiff is not receiving public assistance. (b) Plaintiff is receiving no additional income. 7. No previous Order has been entered against the Defendant in an action for the support of Plaintiff. 8. Plaintiff last received support from Defendant in the amount of $0.00. WHEREFORE, Plaintiff requests that an alimony pendente lite conference be scheduled and an Order be entered against the Defendant and in favor of Plaintiff for reasonable support and medical coverage. 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 unsworn falsification to authorities. Date MartB. Walker, Esqui e Atto ey for Kimberly K. Stitt Guidelines for child and spousal support and for alimony pendente lite have been prepared by the Court of Common Pleas and are available for inspection in the Office of the Domestic Relations Section, Chambersburg, Pennsylvania. 2 KIMBERLY STITT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA n ? V. NO. 'Q ?- fp 3 0-J" ° o rA-r rx' RICKY STITT, CIVIL ACTION -LAW Defendant IN DIVORCE rn 1 NOTICE TO DEFEND AND CLAIM RIGHTS Vic; c? r r"-N i YOU HAVE BEEN SUED IN COURT. If you wish to defend against the laund)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 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'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 1-800-990-9180 or (717) 249-3166 4-4P I'M TRUE COPY a ONA In Testimony whereof, I here unto s t my hand and the seqi of said Court at Carlisle, Pa. This ?..... day of......... -? ......u; y ... F ..................a........ , :: ... Prot rotary 'MOM & Nu ULAKIS Kara W. Haggerty, Esquire Attorney I.D. #: 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 KIMBERLY STITT, Plaintiff V. RICKY STITT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. Q (j 3 ov"rl CIVIL ACTION - LAW IN DIVORCE COMPLAINT 1. Plaintiff is Kimberly Stitt, who currently resides at 62 Quarry Hill Road, Newville Cumberland County, Pennsylvania. 2. Defendant is Ricky Stitt, who currently resides at 62 Quarry Hill Road, Newville, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint 4. The Plaintiff and Defendant were married on October 15, 1983 at Walnut Bottom, Cumberland County, Pennsylvania. COUNT I - DIVORCE 5. Paragraphs 1 through 4 of this Complaint are incorporated herein by reference as though set forth in full. 6. There have been no prior actions of divorce or for annulment between the parties 7. Divorce is sought pursuant to the provisions of the Divorce Code, § 3301(c), in that: a. The marriage is irretrievably broken. b. Plaintiff and Defendant have lived separate and apart since February, 2009 and continue to do so. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in such counseling. 9. The Plaintiff in this action is not a member of the Armed forces. WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce. COUNT II - EQUITABLE DISTRIBUTION 10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference as though set forth in full. 11. Plaintiff and Defendant have acquired property, both real and personal, during their marriage from October 15, 1983, until February of 2009, the date of their separation, which property is "marital property". 12. Plaintiff and Defendant may have owned, prior to marriage, property which has increased in value during the marriage and/or which has been exchanged for other property, which has increased in value during the marriage, all of which property is "marital property". 13. Plaintiff and Defendant have been unable to agree as to an equitable division of said property prior to the filing of this Complaint. WHEREFORE, the Plaintiff requests this Honorable Court to equitably divide all marital property. COUNT III - ALIMONY PENDENTE LITE AND ALIMONY 14. Paragraphs 1 through 13 of this Complaint are incorporated herein by reference as though set forth in full. 15. Plaintiff lacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment. 16. Plaintiff requires reasonable support to maintain herself adequately in accordance with the standard of living established during the marriage. WHEREFORE, Plaintiff requests this Honorable Court to enter an award of alimony pendente lite until final hearing and thereafter to enter an award for alimony. COUNT N - COUNSEL FEES AND COSTS 17. Paragraphs 1 through 16 of this Complaint are incorporated herein by reference as though set forth in full. 18. Plaintiff has retained the law offices of ABOM & KUTULAKIs, L.L.P., but is unable to pay the necessary and reasonable attorney's fees for said counsel. 19. Plaintiff may need to hire experts to appraise the marital property but she lacks funds to pay the necessary and reasonable fees. WHEREFORE, Plaintiff requests this Honorable Court to enter an award of interim counsel fees, costs and expenses and to order such additional sums hereafter as may be deemed necessary and appropriate, and at final hearing to award such additional counsel fees, costs and expenses as are deemed necessary and appropriate. Respectfully submitted, ABOM&KUTULAKi4 L.L.P. DATE 0-2-DV' iog Kara W. Haggerty, Esq ' A.D. No. 8 914 Attorney for Plaintif 36 South Hanover Stye Carlisle, PA 17013 (717) 249-0900 VERIFICATION I, Kimberly Stitt, verify that the statements made in this Divorce Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date Kimberly Stitt PYS510D Cumberland County Prothonotary's Ottice Case Costs and Fees 2009-00637 STITT KIMBERLY (vs) STITT RICKY Filed Date: 210612009 Time: 2:49 Case Type: COMPLAINT - DIVORCE Sel Costs & Fees Beg Bal Adjusts Payments End Bal _ DIVORCE 000 55.00 55.00 _ TAX ON CMPLT 000 .50 .50 _ SETTLEMENT 000 8.00 8.00 _ MASTER'S FEE 000 250.00 250.00 _ DIV PA SURCHG 000 10.00 10.00 _ AUTOMATION FEE 000 5.00 5.00 _ JCP FEE 000 10.00 10.00 _ ADD'L COUNTS 000 16.00 16.00 _ JCP FEE 000 10.00 10.00 _ ADD'L COUNTS 000 16.00 16.00 _ JCP FEE 000 10.00 10.00 _ ADD'L COUNTS 000 16.00 16.00 _ JCP FEE 000 - 10.00 --------- --------- 10.00 - 416.50 ---------- ---------- 416.50 Select With "X" To Display Cost/Fee Detail Information F2=Done F7=Receipts F10=Prin t F12=Cancel FILI OF THE 07 2009.i' L -b FM 1: 26 LAITY C" -4o v P-V KIMBERLY STITT, THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION -DIVORCE NO. 09-637 CIVIL TERM RICKY STITT, IN DIVORCE Defendant/Respondent PACSES NO: 752110980 ORDER OF COURT counsel appeAlimony andtheir consieration of ar beforeeR. J tShadday on AND NOW, this 7th day of Julyha0 he upon and/or counsel fees, it is hereby directed t parties August 20 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. BY THE COURT, Edgar B. Bayley, President Judge Copies mailed to: Petitioner Respondent Martha B. Walker, Esq. Keith O. Brenneman, Esq. Date of Order: July 7.2009 Sh? ay, L Coordinator YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE YOU DO NOT HAVE ALAWYER OR ANNOTA FFORD ONE, GO TO OR REPRESENT YOU. . IF IF 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 cc361 (717) 249-3166 Fil OF THE pp, ? ` '-' DINV ?Y 2004 JUL -7 PH 3: { 3 c?, FY WALKER, CONNOR & JOHNSON, LLC 247 Lincoln Way East Chambersburg PA 17201 (717) 262-2185 (717) 262-2187- Fax KIMBERLY STITT, ) IN THE COURT OF COMMON PLEAS Plaintiff, ) CUMBERLAND COUNTY, PENNSYLVANIA v. ) No. 09-637-Civil RICKY STITT, ) Defendant, ) In Divorce a v.m. INCOME AND EXPENSE STATEMENTOF PLAINTIFF (Kimberly Stitt) WALKER, CONNOR & JOHNSON LLC 247 Lincoln Way East Chambersburg PA 17201 (717) 262-2185 (717) 262-2187- Fax In the Court of Common Pleas of Cumberland County, Pennsylvania Plaintiff Name: Kimberly Stitt Defendant Name: Ricky Stitt Docket Number: 09-637 Income and Expense Statement THIS FORM MUST BE FILLED OUT (If you are self-employed or if you are salaried by a business of which you are owner in whole or in part, you must also fill out the supplemental income statement which appears on the last page of this income and expense statement) INCOME STATEMENT OF: KIMBERLY STITT I verify that the statements made in this Income and Expense Statement are true and correct. I understand that false statements herein are subject to the criminal penalties of 18 PA C.S. §4004, relating to unsworn falsification to authorities. y/a i/~ 9 Date ' Name: Kimber Stitt INCOME: Employer: ~livrirJel-~cin ~ ~uvY~Ty Address: dh e Cove-7~1. ari.Se Sly u~ --.o ~~t- (,'s ~ ~, /`ci / ~o/ 3 Type of Work: G`let-/(~ Payroll No. ~O(,~ 7 Gross Pay Per Period$ o l oZ-S~ Pay Period(wkly./by-wkly./etc. b,~~~¢¢,~~ Federal Withholding $ 39 ~ ~ Social Security $ ~ ~ ~ S Local Wage Tax $ ~d.o y State Income T $ 3 ? ~ ~ Retirement $ 6 ~~~ Savings Bonds $ ~ ax Credit Union $ ~ Life Ins. $ ~2 Health Ins. $ 25Z Other Deductions (specify) Net Pay Per Pay Period $ jd 3 ~ 7 Service Type M Form IN-008 Income and Expense Statement Worker ID 28204 Income and Expense Statement OTHER INCOME (FILL IN Appropriate Column) WEEK MONTH YEAR Interest $ $ $ Dividends Pension Annuity Social Security Rents Royalties Ex ense Account Gifts Unemployment Compensation Workmen's Compensation IRS Refund Other Other TOTALS $ $ $ TOTAL INCOME $ (FILL IN Appropriate Column) EXPENSES: WEEK MONTH YEAR Home $ $ $ Mort ag ent o0, Maintenance _ ~ . Utilities SO'~ ~ o Electric 1S ~ v0 ~ O0 Gas _ D _, Oil _ Tele hone , v U f o, c o Clothing Service Type M Form IN-008 Income and Expense Statement Worker ID 28204 Income and Expense Statement EX (fill in Appropriate Column) PENSES WEEK MONTH YEAR Water ,. _ b Sewer Em to ment Public Transportation .~ .- Lunch - v- ai-k:,,~ ~r ~( v `~ 3 a o Taxes Real Estate _ ~ Personal Property I . ~~ Income Insurance Homeowners ~Qey,-{~ O~ ~~ Automobile .~ • o~ Life ~' 3o8~ao Accident ..~ Health - a- Other - o- Automobile Payments ~" 3S7 ~ `~ ,Z 9a. Fuel ~ S o0 Repairs !3; G ~ ~ '80~ v Medical Doctor /UO~ o 0 Dentist Cr~wr~ 37 u Gam. _ ~'3a v Orthodontist Service Type M Form IN-008 Income and Expense Statement Worker ID 28204 Income and Expense Statement EXPENSES (fill in Appropriate Column) WEEK MONTH YEAR Medicine ~~o Special needs (glasses, braces, orthopedic devices) - ~} - Education Private School .~ Parochial School _ ,~ College Religious ~ ~, ~ /y ao D _ ~ Personal Clothing Food S, o o ,S o0 oD Barber/Hairdresser as ~ ~ ~ 00 Credit Payments: Credit Card Charge Acct. 3y/pnc~.us of9l>9 '~/338,So Memberships ~ ~ Loans Credit Union Miscellaneous Household help Child Care ,,,~_ ~_ Papers/Books/Ma azines Entertainment Pay TV Vacation Service Type M Form IN-008 Income and Expense Statement Worker ID 28204 Income and Expense Statement EXPENSES (FILL IN APPROPRIATE Column) WEEK MONTH YEAR Gifts Legal Fees s3 SSvU Charitable Contributions _ Other child Support ~=- Alimony Payments Child Support Other TOTALS TOTAL EXPENSES $ ~ ~ aD ~5~ PROPERTY DESCRIPTION VALUE OWNERSHIP OWNED H W J Checking Accounts Savings Accounts _ p . Credit Union _ p -- Stocks/Bonds _ ~ ,, Real Estate _ b Other TOTAL INSURANCE COMPANY POLICY# Coverage* H W C Hospital ~ y/ Murk PP~Q~ Blue Cross Other ZA~i2/6a,3SI`'tSSaa / Medical Blue Cross Other $u u..,.L.._a .., "',~Y . - ~ ~uwauu w - w lIe L - l:Ombined J -Joint Service Type M Income and Expense Statement Form IN-008 Worker ID 28204 5 Income and Expense Statement INSURANCE COMPANY POLICY# Coverage* H W C F~ Heal/accident Disability Income Dental Other $Cl IL...L„~J w ~, S; aN - ~l r{ SS 93nZ 6639 .. - ~ ~u~uauu w - w uC L - l,OmbineQ J - JOlnt SuUAlemental Income Statement a. This form is to be filled out by a person: (1) Who operates a business or practices a profession, or (2) Who is a member of a partnership or joint venture, or (3) Who is a shareholder in and is salaried by a closed corporation or similar entity. b. Attach to this statement a copy of the following documents relating to the partnership, joint venture, business, profession, corporation or similar entity: (1) The most recent Federal Income Tax Return, and (2) The most recent Profit and Loss Statement Name of business: Address and telephone number: d. Nature of business (check one): (1) Partnership (2) Joint Venture (3) Profession (4) Closed corporation (5) Other NIA e. Name of accountant, controller or other person in charge of financial records: f. Annual Income from business: (1) How often is income received? (2) Gross Income per pay period:~ (3) Net Income per pay period:- (4) Specified deductions, if any:_ Service Type M Income and Expense Statement Form IN-008 Worker ID 28204 <~ 6 w.~ 1~=~1C~' 209 4CT -2 P~ 1 ~ 1 a i='r:Pv~J~ siVAi'.r.~ ~4 WALKER, CONNOR & JOHNSON, LLC 247 Lincoln Way East Chambersburg PA 17201 (717) 262-2185 (717) 262-2187 -Fax KIMBERLY STITT, ) Plaintiff, ) v. ) RICKY STITT, ) Defendant, ) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 09-637-Civil In Divorce a v.m. INVENTORY OF PLAINTIFF Plaintiff files the following inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Plaintiff verifies that the statements made in this inventory are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. X4904 relating to unworn falsification to authorities. imberly K. S , Plaintif Date of Marriage: October 15, 1983 Date of Separation: June 10, 2009 ASSETS OF THE PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. (X) 1. Real Property (X) 2. Motor vehicles ( ) 3. Stocks, bonds, securities and options ( ) 4. Certificate of deposit ( ) 5. Checking accounts, cash ( ) 6. Savings accounts, money market and savings certificates ( ) 7. Contents of safe deposit boxes ( ) 8. Trusts ( ) 9. Life Insurance policies (indicate face value, cash surrender value and current beneficiaries) ( ) 10. Annuities ( ) 11. Gifts ( ) 12. Inheritances ( ) 13. Patents, copyrights, inventions, royalties (X) 14. Personal Property ( ) 15. Business (List all owners, including percentage of ownership, and officer/director positions held by a party with the company.) ( ) 16. Employment termination benefits -severance pay, workers' compensation claim/award ( ) 17. Profit sharing plans (X) 18. Pension plan (indicate employee contribution and date plan vests) (X) 19. Retirement plan, Individual Retirement Accounts. 2 ( ) 20. Disability payments ( ) 21. Litigation Claims (matured or unmatured) ( ) 22. Military / V.A. benefits ( ) 23. Education benefits ( ) 24. Debts due, including loans, mortgage held (X) 25. Household furnishings and personality (include as total category and attach itemized list if distribution of such assets in dispute) (X) 26. Other 3 MARITAL PROPERTY Plaintiff lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date of this action was commenced: ITEM NO. DESCRIPTION OF PROPERTY 1. 62 Quarry Hill Road Newville PA 2. (a) 2003 Chevrolet Trailblazer (b) 2008 Chevrolet Pick-up Truck (c) House trailer 3. Two cemetery lots, 2 vaults and one opening 4. Cumberland County retirement 5. Carlisle Syntec retirement Cash balance account Carlisle Corporation Lucrative Savings 6. Nationwide 457(b) 7. Wachovia 401(k) 8. Personal property at marital residence NAME OF ALL OWNERS Husband & Wife Wife Husband Wife Husband & Wife Wife Husband Wife Husband Husband & Wife 4 NON- MARITAL PROPERTY Plaintiff lists all property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property. ITEM NO. DESCRIPTION OF PROPERTY NAME OF ALL OWNERS 1. Post-separation contributions to retirements Husband & Wife PROPERTY TRANSFERRED ITEM DESCRIPTION NO. OF PROPERTY PERSON TO DATE OF WHOM TRANSFER CONSIDERATION TRANSFERRED NONE LIABILITIES DESCRIPTION NAMES OF ITEM NO. OF PROPERTY CREDITORS l . Mortgage Citi 2. Home Equity Members First 3. Car loan GMAC 4. Credit card Visa NAMES OF ALL DEBTORS Husband & Wife Husband & Wife Wife Wife 7 ~~~ 4F SHE f'~T1-'t~~4t~1RY 1009 OCT -2 Pty I ~ l 5 CU~d~t.~W= ~. ' ~~~; C~~~vN7Y PENaJ~1'LVVr~;'~1A KIMBERL K. STITT, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA c? `°' - ~. VS. CIVIL ACTION -DIVORCE - a ~`~ ~ _- ~ _-~ NO. 09-637 CIVIL TERM ~ ._, RICKY L. STITT, IN DIVORCE _ - DefendandRespondent PACSES CASE: 752110980 = - - ,.,~ = .. ~~~ ORDER OF COURT ,~~ .~ - AND NOW to wit, this 26th day of January, 2009, it is hereby Ordered that the Order for Alimony Pendente Lite is suspended, effective December 11, 2009, pursuant to the Respondent receiving sick and accident benefits and restrictions for work. The Respondent is to report to the Domestic Relations Section after his February 23, 2010 doctor appointment with medical verification and verification from his employer concerning his work status. The Alimony Pendente Lite account is suspended with a credit of -$308.11 as of this date. 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: Gi ~ J. esley Oler, Jrl DRO: R.J. Shadday xc: Petitioner Respondent Martha B. Walker, Esq. Keith O. Brenneman, Esq. Service Type: M = J. Form 0E-001 Worker: 21005 Walker, Connor & Spang, LLC 247 Lincoln Way East Chambersburg PA 17201 (717) 262-2185 (717) 262-2187 -Fax IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Kimberly Stitt, ) Civil Action -Law Plaintiff, ) vs. ) No. 09-637 -Civil ~ ~ ,.~ .. ~ ,.~, Ricky Stitt, ) _' ~"' Defendant, ) In Divorce a v.m. ~: ~ -~+ AFFIDAVIT OF CONSENT _ , ~ -- N 3 ~..~ 1. A Complaint in Divorce was filed on February 6, 2009. ~ c~ ~- ,ti 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of both the filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION ~ 3301 (cl OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. Date: ~ to ~ .~ Kimberly .Stitt, Plaintiff Walker, Connor & Spang, LLC 247 Lincoln Way East Chambersburg PA 17201 (717) 262-2185 (717) 262-2187 -Fax IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Kimberly Stitt, ) Civil Action -Law Plaintiff, ) ) ) No. 09-637 -Civil vs ~ ~- ~=, . ) ,. -.~ Ricky Stitt, ) r '.... ~-~ I ~~ J ... Defendant, ) In Divorce a v.m. , ; , `" ' ' ~~ r _ _~ -..o ~_: ~` : C i c_ _ iV ~- C AFFIDAVIT OF CONSENT `= ~-' 1. A Complaint in Divorce was filed on February 6, 2009. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of both the filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION & 3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made above are true and correct. I understand that false statements herein aze made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. Date: a 'a Y '~~ Ricky .Stitt, efendant KIMBERLY STITT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. N0. 09 - 637 CIVIL RICKY STITT, Defendant IN DIVORCE ORDER OF COURT AND NOW, this d ~ day of , 2010, counsel and the parties having entered into an agreement and sti ulation resole p -the economic issues on February 24, 2010, the date set for a conference, the agreement and stipulation having been transcribed and signed by the parties, the appointment of the Master is vacated and counsel can conclude the proceedings by the filing of a praecipe to transmit the record with the affidavits of consent and waivers of the parties so that a final decree in divorce can be entered. BY THE COURT, cc: Martha B. Walker At orney for Plaintiff Keith O. Brenneman Attorney for Defendant 1 3/zs /~v ~~ ~r~- Kevin Hess, P.J. rn ~' C ~... d Z ~ ~~!! N C11 -p ~_~ N ~' . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KIMBERLY STITT V. RICKY STITT NO. 09-637-CI VI L DIVORCE DECREE AND NOW, G ~ L ~~ P ~ , it is ordered and decreed that KIMBERLY STITT plaintiff, and RICKY STITT 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 By the Court, LI•lC~•!D Ce~-k. ccn~ mcu1~ -~o Il~o-F;ce reed -tb A~fi,~ 0 t,~aA,k_e,d-~' ~t'ex~nenrl,~.n ., . V , . WALKER, CONNOR & SPANG, LLC 247 Lincoln Way East Chambersburg PA 17201 (717) 262-2185 (telephone) (717) 262-2187 (facsimile) Kimberly Stitt Plaintiff VS. Ricky Stitt Defendant OCT 12 20104 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-637-CIVIL QUALIFIED DOMESTIC RELATIONS ORDER This court, having granted a Divorce Decree on April 15, 2010, by the Hon. J. Wesley Oler, Jr., Judge of the Court of Common Pleas of Cumberland County, and upon the parties' Settlement Agreement placed on the Court record February 24, 2010 (the "Agreement"), and it appearing to the satisfaction of the Court that the Agreement and the Divorce Decree provide for an equitable distribution of marital assets, including certain retirement benefits of the Defendant in the Retirement Plan for Employees of Carlisle Corporation (hereinafter the "Plan") and it appearing to the satisfaction of the Court that a Qualified Domestic Relations Order will be necessary for the purpose of assigning a portion of the Defendant's vested benefit in the Plan to the Plaintiff, the court makes the findings herein and orders as follows: I. FINDINGS The Court finds as follows: The parties hereto were married on October 15, 1983, and separated on June 10, 2009. 2. Ricky Stitt, Defendant, herein and hereinafter referred to as the "Participant," is an employee of Carlisle Companies. 3. Participant is enrolled in the Retirement Plan for Employees of Carlisle Corporation with a vested benefit in the Plan. 4. Kimberly Stitt, Plaintiff, herein and hereinafter "Alternate Payee," is the alternate payee under this Qualified Domestic Relations Order for the purposes of receiving distributions from the Plan. 5. Pursuant to this Order under Pennsylvania Domestic Relations Law and the Divorce Decree, Alternate Payee is entitled to a share of the vested benefit of Participant in the Plan. 6. The current last known mailing address of the Participant is 62 Quarry Hill Road, Newville, PA 17241. His Social Security number and date of birth are contained in the attached Addendum. QDRO Page 2 7. The current last known mailing address of the Alternate Payee is 400 Mohawk Road, Apt. 1, Newville, PA 17241. Her Social Security number and date of birth are contained in the attached Addendum. II. ORDER To accommodate the equitable distribution of marital property between the parties, and in accordance with the findings above, the Court orders as follows: 1. The Alternate Payee is hereby assigned $23,583.32 as of January 1, 2009, of the Participant's vested cash balance account under the Plan. 2. The amount payable to the Alternate Payee hereunder shall be adjusted to reflect any interest credits applied to cash balance accounts by the Plan from January 1, 2009, until the Alternate Payee's benefit commencement date. 3. After a determination is made by the Plan Administrator that this Order is a qualified domestic relations order, and the Alternate Payee furnishes to the Plan Administrator any forms or documents which the Plan Administrator may require to effect payment, the Plan Administrator shall pay to the Alternate Payee the amount awarded assigned hereunder in any form of payment permitted under the Plan and Internal Revenue Code Section 414(p). In no event may the Alternate Payee commence her benefit earlier than the earliest date permitted under the terms of the Plan. 4. If the Alternate Payee dies before she receives the portion of the Participant's vested cash balance account in the Plan assigned to her hereunder, the amount assigned to her hereunder shall be paid to her named beneficiary, using the Plan's forms for purposes of naming a beneficiary. If no beneficiary has been named or is alive at the time of Alternate Payee's death, Alternate Payee's benefit shall be paid to her estate. 5. The Participant and any person to whom he may becomes legally married shall have no further rights under the Plan with respect to the portion of his vested cash balance account assigned to the Alternate Payee hereunder. 6. The Alternate Payee shall be treated as the Participant's beneficiary for the entirety of his vested accrued benefit under the Plan. The Participant shall complete whatever forms are required by the Plan Administrator to effect the terms of this Paragraph 6. 7. The Plan and the Plan Administrator thereof shall have no obligation or responsibility as a consequence of this action apart from the specific direction set forth in this Order. 8. In the event of a change of address of the Alternate Payee, she will immediately notify the Plan Administrator. 9. The Participant, the Alternate Payee and the Court intend this Order to be a Qualified Domestic Relations Order as defined in Section 414(p) of the Internal Revenue Code of 1986, as amended (IRC §414(p)). QDRO Page 3 10. This Order: a. Shall not require the Plan to provide any type or form of benefit, or any option, not otherwise provided under the Plan, b. Shall not require the Plan to provide increased benefits, and c. Shall not require the payment of benefits to the Alternate Payee which are required to be paid to another alternate payee under another order previously determined to be a qualified domestic relations order. 11. This Court retains jurisdiction to amend this Order for purposes of establishing or maintaining its qualifications as a Qualified Domestic Relations Order under IRC §414(p). 12. IRC §414(p) provides that no amendment of this Order shall require the Plan to provide any type or form of benefit or any option not otherwise provided, and further provides that no such amendment or the right of the Court to so amend shall invalidate this Order as "qualified" under IRC §414(p). 13. The provisions of this Order supersede the provisions of previous orders, judgments or prior agreement between the Participant and the Alternate Payee, in the instant action insofar as those provisions relate to the interest of the Alternate Payee in Participant's vested cash balance account under the Plan. 14. A certified copy of this Order shall be served upon the Plan by Martha B. Walker, counsel for the Alternate Payee, to the Plan Administrator who shall: a. promptly notify the Participant, the Alternate Payee and their counsel, whose addresses are listed in the attached Addendum, of the receipt of a copy of this Order by the Plan Administrator; and b. within a reasonable period of time after receipt of a copy of this Order, determine whether this Order is a Qualified Domestic Relations Order and so notify the attorneys for the Participant and the Alternate Payee. Counsel may serve this order on the Plan by first class mail. 15. The parties shall use their best efforts in taking such steps as shall be reasonable and appropriate to cause the Plan Administrator to comply with those provisions of this Order addressed to it. QDRO Page 4 III. NOTICE OF ENTRY This Order having been filed and entered by the Court, this ? day of C ? (o BY THE COURT CONSENT TO ORDER: Z"J'" o Plaintiff/ ernate Payee Date • /1/0 A orney for Plaintiff/ Date ternate Payee w??ES m-. c 1.? lO?t3 ?!d 4?udge k, / L ?' 4 xd t /0// O Defendan anticipant IYate to////. Attorney for Defendant/ Alternate Payee Date ' 0 rTP