HomeMy WebLinkAbout09-1168Jay R. Bradennan, Esquire
Attorney 1. D. No. 07047
Todd C. Hough, Esquire
Attorney /.D. No. 91060
Lavery, Faherty, Young & Patterson, P.C.
225 Market Street, Suite 304
P. O. Box 1245
Harrisburg PA 17108-1245
Tel: 717-233-6633
Fax: 717-233-7003
Attomeys forPlaintitf
ANDREW J. UNDERKOFFLER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
vs.
: NOM-111.8 CIVIL TERM
KAREN J. UNDERKOFFLER,
Defendant 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 of 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.
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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
1-800-990-9108
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County complies with the Americans
with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the Court,
please contact our office. All arrangements must be made at least seventy-two (72)
hours prior to any hearing or business before the Court. You must attend the scheduled
conference or hearing.
Jay R. Braderman, Esquire
Attorney I.D. No. 07047
Todd C. Hough, Esquire
Attorney M No. 91060
Lavery, Faherty, Young & Patterson, P.C.
225 Market Sheet, Suite 304
P. O. Box 1245
Harrisburg, PA 17108-1245
Tel: 717-233-6633
Fax: 717-233-7003
Attorneys forPlainMf
ANDREW J. UNDERKOFFLER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
VS.
NO. 09= 7 CIVIL TERM
KAREN J. UNDERKOFFLER, :
Defendant IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW Comes Plaintiff, Andrew J. Underkoffler, by and through his
attorneys, Lavery, Faherty, Young & Patterson, P.C. and Jay R. Braderman, Esquire,
and respectfully represents as follows:
1. Plaintiff, Andrew J. Underkoffler, is of full age and sui juris and resides at
2005 Sheepford Road, Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. Defendant, Karen J. Underkof ler, is of full age and sui juris and resides at
1060 Yocumtown Road, Etters, York County, Pennsylvania 17319.
3. Plaintiff has been a bona fide resident in the Commonwealth of
Pennsylvania for at least 6 months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on October 10, 1987, in Lewisberry,
York County, Pennsylvania.
5. There was one child born of this marriage; Ryan Underkoffler, bom October
17, 1992, who is now 16 years of age.
6. There have been no prior actions for annulment or divorce by either party to
this action.
7. Plaintiff has been advised of the availability of counseling and that the
Plaintiff may have the right to request that the Court require the parties to participate in
counseling.
8. The Defendant is not a member of the Armed Services of the United States
or any of its Allies.
9. The causes of action and sections of the Divorce Code under which Plaintiff
is proceeding are:
A. Section 3301(c). The marriage of the parties is irretrievably broken.
After ninety (90) days have elapsed from the date of filing this Complaint,
Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff
believes that Defendant may also file such an Affidavit.
B. Section 3301 (d). The marriage of the parties is irretrievably broken.
The date of separation was on or about February 1, 2003.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter a
Decree in Divorce from the bonds of matrimony.
COUNTI
REQUEST FOR EQUITABLE DISTRIBUTION
UNDER SECTION 3502 OF THE DIVORCE CODE
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.
12. Plaintiff and Defendant have been unable to agree as to an equitable
division of said property to the date of the filing of this Complaint and Plaintiff requests the
Court to equitably divide, distribute or assign the marital property between the parties and
the marital debts of the parties without regard to marital misconduct in such proportions as
the Court deems just after consideration of all relevant factors.
WHEREFORE, Plaintiff respectfully requests the Court to enter an Order of
equitable distribution of marital property and marital debts.
Date:
171-7-
Respectfully Submitted,
Lavery, Faherty, Young & Patterson, P.C.
ja an, Esquire`
o I . No. 07047
22 arket Street, Suite 304
P O. Box 1245
Harrisburg, PA 17108-1245
Tel: 717-233-6633
Fax: 717-233-7003
Attorneys for Plaintiff
VERIFICATION
Upon my personal knowledge or information and belief, I hereby verify that the facts
averred in the foregoing Complaint are true and correct to the best of my knowledge,
information, and belief. I understand that false statements herein made are subject to the
criminal penalties of 18 Pa.C.S. § 4904, relating to unswom falsification to authorities.
Date:
Andrew J. derkoffler
I verify that I have reviewed this -form with my client and to the best of my
knowledge the allegations herein are true and correct.
Patterson, P.C.
one No. 047
225 M et Str t, Suite 304
P. O ox 1245
Harrisburg, PA 17108-1245
Tel: 717-233-6633
Fax: 717-233-7003
Attorneys for Plaintiff
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Jay R. Braderman, Esquire
Attomey /D. No. 07047
Todd C Hough, Esquire
Attomey I.D. No. 91060
Lavery, Faherty, Young & Patterson, P.C.
225 Market Street, Suite 304
P. O. Box 1245
Harrisburg, PA 17108-1245
Tel: 717-233-6633
Fax: 717-233-7003
Attomeys forPlaintfi
ANDREW J. UNDERKOFFLER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs.
KAREN J. UNDERKOFFLER,
Defendant
CIVIL ACTION -LAW
NO.Dq /A Q' CIVIL TERM
IN DIVORCE
AFFIDAVIT
ANDREW J. UNDERKOFFLER, being duly swom according to law, deposes and
says:
1. I have been advised of the availability of marriage counseling and
understand that I may request that the Court require that my spouse and I participate in
counseling.
2. 1 understand that the Court maintains a list of marriage counselors in the
Prothonotary's Office, which list is available to me upon request.
3. Being so advised, I do not request that the Court require that my spouse
and I participate in counseling prior to a Divorce Decree being handed down by the
Court.
I understand that false statements herein are made subject to the penalties of 18
Pa. C.S. Section 4904 relating to unsw m falsificati n to tho ies.
ANDREW J. UNDER KOFFLER
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IN THE COURT OF COMMON PLEAS - CUMBERLAND COUNTY, PENNSYLVANIA
FAMILY LAW DIVISION
ANDREW J. UNDERKOFFLER,
Plaintiff, No.: 09-1168
v.
CIVIL ACTION - LAW
KAREN J. UNDERKOFFLER, In-Divorce
Defendant.
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance on behalf of the above-captioned Plaintiff, Andrew J.
Underkoffler, in regard to the above-referenced matter.
Farley G Ho t, squire
Attorney for Defendant
34 North Queen Street
York, Pennsylvania 17403
(717) 846-0550
I.D. #59920
OF THE R,14C)NOTARY
2009 APR 14 PH 2: 14
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ANDREW J. UNDERKOFFLER IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
C
vs. -V Z
NO. 09-1168 20M 3-
r
KAREN J. UNDERKOFFLER '--
Defendant <
MOTION FOR APPOINTMENT OF MASTER as
ANDREW J. UNDERKOFFLER. Plaintiff , moves the court to appoint a master wit5pEvec=
the following claims:
OX Divorce --? --
?X Distribution of Property <
? Annulment ? Support
OX Alimony ? Counsel Fees
? Alimony Pendente Lite ? Costs and Expenses
and in support of the motion states:
1. Discovery is complete as to the claims (
s) for which the appointment of a master is requested.
2. The defendant has not appeared in the action (personally) (by his attorney,_
, Esquire).
The staturory ground (s) for divorce is
NO FAULT: 23 Pa.C.S. Section 3301 (c)
Delete the inapplicable paragraph (s): AE] BM CM
a. The action is not contested.
b. An agreement has been reached with resnect to the followine claims:
c. The action is contested with respect to the following claims:
5. The action does not involve complex issues of law or fact.
6. The hearing is expected to take Four _ hours
7. Additional information, if any, relevant t e mo
Date: ? `'
Att a fo laintiff
ay R. Braderman, Esquire
Print Name
ORDER APPOINTING MASTER
AND NOW
20 ,
Esquire,
is appointed master with respect to the following claims:
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By the Court,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DIVORCE HEARING MASTER
ANDREW J. UNDERKOFFLER
Plaintiff
2005 SHEEPFORD ROAD
Street Address
MECHANICSBURG, PA 17055
City - State - Zip Code
VS.
KAREN J. UNDERKOFFLER
Defendant
1060 YOCUMTOWN ROAD
Street Address
ETTERS, PA 17319
City - State - Zip Code
JAY R. BRADERMAN
Attorney for Plaintiff
225 MARKET ST., P.O.BOX 1245
Street Address
HARRISBURG, PA 17108-1245
City - State - Zip Code
717-233-6633
Phone Number
°.
Docket No. 09-1168 CIVIL TERM r-0 (D
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Attorney for Defendant
Street Address
City - State - Zip Code
Phone Number
INVENTORY OF
ANDREW J. UNDERKOFFLER
(Plaintiff)
(Plaintiff) files the following Inventory and Appraisement of all property owned or
possessed by either party at the time this action was commenced and all property transferred within
the preceding three (3) years.
(Plaintiff)) verifies that the statements made in this Inventory and Appraisement are true and
correct. (Plaintiff) (Defendant) understands that false statements herein are made subject to penalties
orities.
of 18 Pa.C.S. Section 4904 relat' to unswo fal 'ficati t 7) ?/
ZOAWO , e,
(Plaintiff)
19
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. If an item has been appraised, copy of the appraisal report is attached.
(X) 1. Real Property
(X) 2. Motor Vehicles
( ) 3. Stocks, Bonds, Securities and Options
( ) 4. Certificates of Deposit
(X) 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 Certification)
( ) 10. Annuities
( ) 11. Gifts
( ) 12. Inheritances
( ) 13. Patents, Copyrights, Inventions, Royalties
(X) 14. Personal Property Outside the Home
( ) 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, Workman's Compensation
(Claim/award)
( ) 17. Profit Sharing Plans
( ) 18. Pension Plans (Indicate Employee Contribution and Date Plan Vests)
(X) 19. Retirement Plans, Individual Retirement Accounts
( ) 20. Disability Payments
( ) 21. Litigation Claims (Matured and Unmatured)
( ) 22. Military N.A. Benefits
( ) 23. Education Benefits
( ) 24. Debts Due, Including Loans, Mortgages Held
( ) 25. Household furnishings and Personality (Include as a Total Category and Attach
Itemized list If Distribution of Such Assets Is in Dispute.
( ) 26. Other
MARITAL PROPERTY
Plaintiff lists all property in which either or both spouses have a legal or equitable
interest individuallv or with anv other person as of the date this action was commenced:
ITEM NUMBER
1.Marital home DESCRIPTION OF PROPERTY
1060 Yocumtown Rd., Etters. PA (Est. $100,000) NAMES OF ALL OWNERS
H&W
2.1999 Ford Truck (Est. $3.000) H
3.Checking Account Sovereign Bank ($500.00) H
43oat (Est. $4,000) H
5.Camper (Est. $5.000) H
6.Pop-ul (Est. $500.00) H
7.Retirement Plan Fidelity Investments ($101,000) H
8.Wife's Bank Accounts (Est. $25.000) W
9.
10.
11.
12.
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 NUMBER DESCRIPTION OF PROPERTY REASON FOR EXCLUSION
PROPERTY TRANSFERRED
Plaintiff lists all property in which either or both spouses has a legal or equitable
interest, individually or with any other person, and which has been transferred within the
preceding three (3) years:
ITEM DESCRIPTION DATE OF CONSIDERATION PERSON TO WHOM
NUMBER OF PROPERTY TRANSFER TRANSFERRED
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
LIABILITIES
ITEM DESCRIPTION OF
NUMBER PROPERTY NAMES OF
ALL CREDITORS NAMES OF ALL
DEBTORS
1.Credit Card Debt To be determined H
2. Loan $27,000.00 Fidelity Investments H
3.
4.
5.
6.
7.
8.
9.
10.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
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R.O. NO. DOCKET NO. GQ - !1 lO ? 20o 9 zrn c =-I]
PACSES Case No. rn
INCOME AND EXPENSE STATEMENT OF <? = °
ANDREW J. UNDERKOFFLER
ADDRESS: 2005 SHEEPFORD ROAD ?• c .. ni
MECHANICSBURG, PA 17055 PHONE: --q -
ATTORNEY:JAY R. BRADERMAN, ESQ.
SECTION I: INCOME AND INSURANCE INFORMATION
INSTRUCTIONS: THIS SECTION MUST BE FULLY COMPLETED. IF YOU ARE NOT
PRESENTLY EMPLOYED, THE EMPLOYER INFORMATION SHOULD REFLECT
EARNINGS INFORMATION FROM YOUR LAST JOB.
INCOME:
CURRENT OR LAST EMPLOYER: EXEL _
PAYROLL ADDRESS: Department 110, 570 Polaris Parkway, Westerville, OH 43082
POSITION HELD: Forklift Operator
HOW PAID: (CIRCLE ONE) WEEKLY / BIWEEKLY / MONTHLY / SEMI-MONTHLY
OTHER
IF LAST JOB: DATE LEFT JOB
GROSS PAY PER PERIOD:
ITEMIZED PAYROLL DEDUCTIONS:
FEDERAL WITHHOLDING
SOCIAL SECURITY (& MEDICARE)
LOCAL WAGE TAX
STATE INCOME TAX
MANDATORY RETIREMENT (Loan)
HEALTH INSURANCE
OTHER (SPECIFY)
Dental
Health Care Spending Acct.
Vision
NET PAY PER PAY PERIOD
REASON FOR LEAVING:
$ 553.74
$ 33.25
$ 31.29
$ 6.54
$ 17.00
$ 149.48 REQUIRED MINIMUM) %:__
$ 55.16
$ 7.93
$ 38.46
$ 3.30
$ 197.62
OTHER INCOME: WEEK MONTH YEAR
(FILL IN APPROPRIATE COLUMN)
INTEREST
DIVIDENDS
PENSION
PROPERTY OWNED: OWNERSHIP
DESCRIPTION VALUE H W J
CHECKING ACCTS $
SAVINGS ACCTS $
CREDIT UNION $
ANNUITY
SOCIAL SECURITY
RENTS
UNEMPLOYMENT COMP.
WORKMENS COMP.
IRA
TIP
ALIMONY (REC'D.)
TOTALS
STOCK/BONDS $
REAL ESTATE $
BUSINESS $
TOTAL
INSURANCE (COVERING DEPENDENTS IN THIS CASE):
COMPANY AND CLAIMS ADDRESS GROUP # POLICY# H W C
HOSPITAL
BLUE CROSS
OTHER
MEDICAL
BLUE SHIELD
OTHER
DISABILITY
DENTAL
OTHER
*H=HUSBAND, W=WIFE, J=JOINT, C=CHILD
I VERIFY THAT THE STATEMENT MADE IN THIS INCOME AND EXPENSE
STATEMNT ARE TRUE AND CORRECT, I UNDERSTAND THAT FALSE STATEMENTS
HEREIN ARE MADE SUBJECT TO PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING
TO UNSWORN FALSIFICATION TO AUTHORITIES.
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SIGNATURE DATE
SECTION H: SUPPLEMENT INCOME STATEMENT
INSTRUCTIONS: IF YOU ARE SELF-EMPLOYED OR IF YOU ARE SALARIED BY A
BUSINESS OF WHICH YOU ARE OWNER WHOLE OR IN PART, YOU MUST ALSO FILL
OUT THIS SECTION.
A. THIS FORM IS TO BE FILLED OUT BY A PERSON (CHECK ONE)
• (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 SI IILAR ENTITY
(i) THE MOST RECENT FEDERAL INCOME TAX RETURN AND
(2) THE MOST RECENT PROFIT AND LOSS STATEMENT.
c. NAME OF BUSINESS
ADDRESS
TELEPHONE NUMBER(S)
D. NATURE OF BUSINESS (CHECK ONE)
• (1) PARTNERSHIP
• (2) JOINT VENTURE
• (3) PROFESSION
(4) CLOSED CORPORATION
• (5) OTHER
E. NAME OF ACCOUNTANT, CONTROLLER OR OTHER PERSON IN CHARGE OF
FINANCIAL RECORDS:
F
ANNUAL INCOME FROM BUSINESS:
(r) HOW OFTEN IS INCOME RECEIVED?
(2) GROSS INCOME PER PAY PERIOD: _
(3) NET INCOME PER PERIOD?
(4) SPECIFIED DEDUCTIONS, IF ANY: _
SECTION III: EXPENSES
INSTRUCTIONS:
I. ONLY SHOW EXTRAORDINARY EXPENSES IN THIS SECTION, UNLESS
NO.2 APPLIES TO YOU.
2. IF YOU ARE REQUESTING SPOUSAL SUPPORT/APL OR IF YOU ASSERT
YOUR CASE CANNOT BE DETERMINED ACCORDING TO THE GUIDELINE
GRIDS OR FORMULA, THIS SECTION MUST BE FULLY COMPLETED.
NUMBER OF PERSONS IN HOUSEHOLD AND AGES OF SAME
MONTHLY EXPENSES
SELF CHILDREN
HOME
MORTGAGE/RENT
MAINTENANCE
UTILITIES
ELECTRIC
GAS
OIL _
TELEPHONE (cell) 143.00
WATER
SEWER
EMPLOYMENT
PUBLIC TRANSPORTATION
LUNCH
TAXES
REAL ESTATE
PERSONAL PROPERTY
INCOME
INSURANCE
HOMEOWNERS
AUTOMOBILE 132.00.
LIFE
ACCIDENT
HEALTH
OTHER
AUTOMOBILE
PAYMENTS
FUEL 325.00
REPAIRS/MAINTENANCE
MEDICAL
DOCTOR
DENTIST
ORTHODONTIST
MONTHLY EXPENSES
SELF CHILDREN
EDUCATION
PRIVATE SCHOOL _
PAROCHIAL SCHOOL _
COLLEGE _
RELIGIOUS _
PERSONAL
CLOTHING 25.00 ,
FOOD 250.00
BARBER/HAIRDRESSIN G 10.00.
CREDIT PAYMENTS _
CREDIT CARDS _
CHARGE ACCOUNT _
MEMBERSHIPS _
LOANS
CREDIT UNION _
Sovereign Bank 100.00
401(k loan 648.00
MISCELLANEOUS
HOUSEHOLD HELP _
CHILD CARE _
PAPERSBOOKS/MAGS _
ENTERTAINMENT _
PAY TV _
VACATION _
GIFTS
LEGAL FEES 100.00
CHARITABLE CONTRIB. _
OTHER CHILD SUPPORT _
ALIMONY PAYMENTS _
OTHER Spousal support 270.00
HOSPITAL
MEDICINE
THERAPY
SPECIAL NEEDS
(GLASSES, BRACES,
ORTHOPEDIC DEVICES, ETC.)
TOTAL EXPENSES $2,003.00
**(CONVERSION FACTOR WEEKLY TO MONTHLY IS 4.345)
Please retain these copies for your records
Federal, State and Local
Tax Returns
for
ANDREW J UNDERKOFFLER
2010
Shoffner Income Tax Service
847 Heck Hill Rd.
Lewisberry, PA 17339-9142
Phone: (717)938-2666
Fax: (717) 932-2055
herbshoff@epix.net
Form Department of the Treasury-Internal Revenue Service
1040A U.S. Individual Income T ax Return (99) 2010 IRS Use Only-Do not write or staple in this space.
Your first name M.I. Last name Suffix OMB No. 1545-0074
Name, R Your social security number
Address N UNDERKOFFLER XXX-XX-XXXX
, ANDREW J
and SSN T if a joint return, spouse's first name M.I. Last name Suffix Spouse's social security number
c
See separate L
E Home address (number and street). If you have a P.O. box, see instructions.
Apt. n
o. . sure the SSN(s) above
Make
correct
r
li
6
instructions. a 2005 SHEEPFORD RD .
c a
e
ne
and on
R
L City, town or post office, state, and ZIP code. If you have a foreign address, see instructions. Checking a box below will not
Presidential Y MECHANICSBURG PA 17055
d
hi
f change your tax or refund.
? ? You ? Spouse
Election Camp . . . .
un
s
aign ? Check here if you, or your spouse if filing jointly, want $3 to go to t . . .
1 ? Single 4 0 Head of household (with qualifying person). (See instructions.) If the
Filing 2 ? Married filing jointly (even if only one had income) qualifying person is a child but not your dependent, enter this child's
status
Check onl 3 ? Married filing separately. Enter spouse's SSN above and name here. ?
y
one box. full name here.? 5 ? Qualifying widow(er) with dependent child (see instructions)
Exemptions 6 a ?X Yourself. If someone can claim you as a dependent, do not check 1 Boxes
J} checked on
b F-1 Spouse box 6a. 6a and 6b 1
If more than six
dependents, see
instructions.
Income
c Dependents:
(1) First name Last name
(2) Dependent's social
security number
(3) Dependent's
relationship to you (4) ff child under
age 17 qualifying for
child tax credit (see
page 16)
RYAN UNDERKOFFLER XXX-XX-XXXX Son
d Total number of exemptions claimed.
Attach 7 Wages salaries, tips, etc.
Form(s) W-2
here. Also 8 a Taxable interest. Attach S
attach b Tax-exempt interest. Do r
Form(s) 9 a ordinary dividends. Attach
1099 R if tax b Qualified dividends (see in
was withheld. 10 Capital gain distrib
If you did not 11a IRA
get a W-2, see distributions.
page 20. 12a Pensions and
Enclose, but do annuities.
not attach, any
payment. Also,
please use Form
13
Unemployment com
1040-v. 14a Social security
benefits.
15 Add lines 7 througl
Adjusted
Attach Form(s) W-2.
dule B if required
include on line 8a
hedule B if requir(
actions).
instructions).
11a
12a
and Alaska
8b
14a
14b (far riqht column). This is
11b Taxable amount
(see instructions
12b Taxable amount
14b Taxable amount
(see instructions
r total i
No. of children
on 6c who:
• lived with
you 1
0 did not live
with you due
to divorce or
separation (see
instructions)
Dependents
on 6c not
entered above
Add numbers
on lines 2
above ?
7 38
_ 8a
9a
10
_ 11b
12b
13
14b
? 15 3F
16 Educator expenses (see instructions.) 16
gross 17 IRA deduction (see instructions). 17
income 18 Student loan interest deduction (see instructions). 18
19 Tuition and fees. Attach Form 8917. 19
20 Add lines 16 through 19 These are your total adjustments.
21 Subtract line 20 from line 15. This is our adjusted gross income.
For Disclosure, Privacy Act, and Paperwork Reduction Act Notice, see separate instructions.
(HTA)
20
21 38,3371
Form 1040A (2010)
Form 1040A (2010) ANDREW J UNDERKOFFLER XXX-XX-XXXX
Tax, credits, 22 Enter the amount from line 21 (adjusted gross income).
and 23a Check f ? You were born before January 2, 1946, ? Blind 1 Total boxes
payments if: 1 ? Spouse was born before January 2, 1946, ? Blind J checked ? 23a
b If you are married filing separately and your spouse itemizes
?_?.._a:......, .. o "In ?nri r hcrr4 hares ?23b f-1
2
24 Enter our standard deduction see instructions . 24 8,400
25 Subtract line 24 from line 22. If line 24 is more than line 22, enter -0-. 25 29,937
26 Exemptions Multiply $3,650 by the number on line 6d. 26 7,300
27 Subtract line 26 from line 25. If line 26 is more than line 25, enter -0-.
This is your taxable income. ? 27 22,637
0o r ., ,. I.,A;- -, ?Ifcrnn#ivo minimum tL1Y ISP.P InStnICtIOnS). 28 2,796
29 Credit for child and dependent care expenses. Attach Form 2441.
30 Credit for the elderly or the disabled. Attach
Schedule R.
31 Education credits from Form 8863, line 23.
32 Retirement savings contributions credit. Attach Form 8880.
33 Child tax credit (see instructions).
34 Add lines 29 through 33 These are your total credits.
35 Subtract line 34 from line 28. If line 34 Is more than Ilr
36 Advance earned income credit payments from Form(:
37 Add lines 35 and 36. This is your total tax.
38 Federal income tax withheld from Forms W-2 and 1099.
If you have 39 2010 estimated tax payments and amount applied
from 2009 return.
a qualifying 40 Making work pay credit. Attach Schedule M.
child, attach
41 a
Earned income credit EIC .
Schedule
Elc b Nontaxable combat pay election. 41 b
42 Additional child tax credit Attach Form 8812.
Refund
Direct
deposit?
See
instructions
and fill in
46b, 46c,
and 46d or
Form 8888.
Amount
29
30
31
32
33
28, enter -0-.
W-2 box 9.
38 2,702
39
40 400
41a
42
34
35
? 37
796
43 American opportunity credit from Form 8863, line 14. 43
44 Add lines 38, 39, 40, 41a 42, and 43. These are your total payments. ? 44
45 If line 44 is more than line 37, subtract line 37 from line 44.
This is the amount you overpaid 45
46 a Amount of line 45 you want refunded to you. If Form 8888 is attached, check here?046a
306
Routing
10, b number XXXXXXXXX ?c Type:
Account
? d number XXXXXXXXXXXXXXXXX
47 Amount of line 45 you want applied to your
2011 estimated tax. 47
48 Amount you owe. Subtract line 44 from line 37. For details on h
--Pp inqtriiintinng
to pay,
? 48
you owe 49 Estimated tax penalty (see instructions). 49 1
Third party Do you want to allow another person to discuss this return with the IRS (see instructions)??X Yes. Complete the following. ? No
Designee's Phone Personal identification
designee name ? Preparer no ? (717) 938-2666 number (PIN) ? XXXXX
Sign Under penalties of perjury, I declare that I have examined this return and accompanying schedules and statements, and to the best of my knowledge
and belief, they are true, correct, and accurately list all amounts and sources of income I received during the tax year. Declaration of preparer (other
here than the taxpayer) is based on all information of which the preparer has any knowledge.
Joint return? Your signature Date Your occupation Daytime phone number
See page 13 FORKLIFT OPER 717 683-6669
Keep a copy
for your Spouse's signature. If a joint return, both must sign. Date Spouse's occupation
Paid Print/type preparer's name Preparer's signature Date Check ? ? if PTIN
Herbert Shoffner Herbert Shoffner 4/1412011 self-employed P01245533
preparer's Firm's name ? Shoffner Income Tax Service Firm's EIN ?
use only Firm's address ? 847 Heck Hill Rd. Lewisberry PA 17339-9142 Phone no. (717)938-2666
1
? Checking ? Savings
Form 1040A (2010)
Form 1040A (2010) ANDREW J UNDERKOFFLER XXX-XX-XXXX Page 2
Tax, credits, 22 Enter the amount from line 21 (adjusted gross income). 22 38,337
and 23a Check f ? You were born before January 2, 1946, ? Blind Total boxes
p ?
aYments if: 1 ? spouse was born before January 2, 1946, ? Blind checked b, 23a
b If you are married filing separately and your spouse itemizes
?-._.:__.. .. ., 1A ?nA nhcnle hcrc ?23b n
24 Enter our standard deduction see instructions). 24 8,400
25 Subtract line 24 from line 22. If line 24 is more than line 22, enter -0-. :?5 29,937
26 Exemptions Multiply $3,650 by the number on line 6d. 26 7,300
27 Subtract line 26 from line 25. If line 26 is more than line 25, enter -0-.
This is our taxable income. ? 27 22,637
nn r___ :_..i...?:..a..,r....?l+erno+ivn minima inn, tav (SP? inStnlCtlOnS). 28 2,796
29 Credit for child and dependent care expenses. Attach Form 2441. 29
30 Credit for the elderly or the disabled. Attach
Schedule R. 30
31 Education credits from Form 8863, line 23. 31
32 Retirement savings contributions credit. Attach Form 8880. 32
33 Child tax credit see instructions). 33
34 Add lines 29 through 33 These are your total credits. 34
35 Subtract line 34 from line 28. If line 34 Is more than line 28, enter -0-. 35 2,796
36 Advance earned income credit payments from Forms W-2 box 9. 36
37 Add lines 35 and 36. This is our total tax. ? 37 2,796,
38 Federal income tax withheld from Forms W-2 and 1099. 38 2,702
39 2010 estimated tax payments and amount applied
If you have from 2009 return. 39
a qualifying 40 Makin work a credit. Attach Schedule M. 40 400
child, attach
41 a Earned income credit EIC . 41a
Schedule
Etc. b Nontaxable combat a election. 41 b
42 Additional child tax credit. Attach Form 8812. 42
43 American opportunity credit from Form 8863, line 14. 43
44 Add lines 38, 39, 40, 41 a, 42, and 43. These are our total payments. ? 44 3,102
Refund 45 If line 44 is more than line 37, subtract line 37 from line 44.
This is the amount you overpaid. 45 306
check here?046a 306
If Form 8888 is attached
ou
nt refunded to
45
f li
Direct 46 ,
.
y
you wa
ne
a Amount o
deposit?
See
?
Routing
?c Type: ? Checking ? Savings
b
instructions number XXXXXXXXX
and fill in Account
46b, 46c, ? d number XXXXXXXXXXXXXXXXX
and 46d or
47
Amount of line 45 you want applied to your
Form 8888. 2011 estimated tax 47 _
48 Amount you owe. Subtract line 44 from line 37. For details on how to pay,
Amount see instructions. ? 48
you owe 49 Estimated tax penalty (see instructions). 49
Third party Do you want to allow another person to discuss this return with the IRS (see instructions)?? Yes. Complete the following. ? No
designee Designee's Phone Personal identification ? XXXXX
name ? Preparer no ? (717) 938-2666 number (PIN)
Sign Under penalties of perjury, I declare that I have examined this return and accompanying schedules and statements, and to the best of my knowledge
arer (other
Declaration of
re
ear
i
th
t
I
i
d d
p
p
.
ax y
ur
ng
e
ve
rece
and belief, they are true, correct, and accurately list all amounts and sources of income
here than the taxpayer) is based on all information of which the preparer has any knowledge.
Date Your occupation Daytime phone number
Joint return? Your signature
See page 13. FORKLIFT OPER _ 717 683-6669
Keep a copy
for your
Spouse's signature. If a joint return, both must sign. Date Spouse's occupation
records.
Paid
Print/type preparer's name Preparer's signature Date Check ? ?X if PTIN
Herbert Shoffner Herbert Shoffner 4/14/2011 self-employed P01245533
preparer's Firm's name ? Shoffner Income Tax Service Firm's EIN ?
use only Firm's address ? 847 Heck Hill Rd. Lewisber PA 17339-9142 Phone no. (717)938-2666
Form 1040A (2010)
SCHEDULE M
(Form 1040A or 1040)
Department of the Treasury
Internal Revenue Service I
Name(s) shown on return
ANDREW J UNDERKO
Making Work Pay Credit
? Attach to Form 1040A or 1040. ? See separate instructions.
OMB No. 1545-0074
00010
Attachment
Sequence No. 166
Your social security number
13 To take the making work pay credit, you must include your social security number (if filing a joint return, the number of either you or your
spouse) on your tax return. A social security number does not include an identification number issued by the IRS. Only the Social Security
Administration issues social security numbers.
13 You cannot take the making work pay credit if you can be claimed as someone else's dependent or if you are a nonresident alien.
Important: Check the "No" box on line 1a and see the instructions if:
(a) You have a net loss from a business,
(b) You received a taxable scholarship or fellowship grant not reported on a Form W-2,
(c) Your wages include pay for work performed while an inmate in a penal institution,
(d) You received a pension or annuity from a nonqualified deferred compensation plan or a
nongovernmental section 457 plan, or
(e) You are filing Form 2555 or 2555-EZ.
1 a Do you (and your spouse if filing jointly) have 2010 wages of more than $6,451 ($12,903 if married filing jointly)?
Yes. Skip lines 1 a through 3. Enter $400 ($800 if married filing jointly) on line 4 and go to line 5.
No. Enter your earned income (see instructions) . . . . . . . . . 1a
b Nontaxable combat pay included on
line 1 a (see instructions) . . . . . . . lb
2 Multiply line 1 a by 6.2% (.062) . . . . . . . . . . . . . . . . . . ? 2
3 Enter $400 ($800 if married filing jointly). . . . . . . . . . . . . . 1 3
4 Enter the smaller of line 2 or line 3 (unless you checked "Yes" online 1a) . . . . . . . . . .
5 Enter the amount from Form 1040, line 38", or Form 1040A, line 22 . . . 5 38
6 Enter $75,000 ($150,000 if married filing jointly) . . . . . . . . . . . 6 L 75
7 Is the amount on line 5 more than the amount on line 6?
FX No. Skip line 8. Enter the amount from line 4 on line 9 below.
Yes. Subtract line 6 from line 5 . . . . . . . . . 7
8 Multiply line 7 by 2% (.02) . . . . . . . .
9 Subtract line 8 from line 4. If zero or less, enter -0- . . . . . . . . . . . . . . . . . . . .
10 Did you (or your spouse, if filing jointly) receive an economic recovery payment in 2010? You may
have received this payment in 2010 if you did not receive an economic recovery payment in 2009
but you received social security benefits, supplemental security income, railroad retirement
benefits, or veterans disability compensation or pension benefits in November 2008, December
2008, or January 2009 (see instructions).
?X No. Enter -0- on line 10 and go to line 11.
[-] Yes. Enter the total of the payments you (and your spouse, if filing jointly) received in 2010.
Do not enter more than $250 ($500 if married filing jointly) . . . . . . . . . .
4
8
9 400
11 Making work pay credit. Subtract line 10 from line 9. If zero or less, enter -0-. Enter the result
here and on Form 1040, line 63; or Form 1040A, line 40 . . . . . . . . . . . . . . . . . . 11 400
`If you are filing Form 2555, 2555-EZ, or 4563 or you are excluding income from Puerto Rico, see instructions.
For Paperwork Reduction Act Notice, see your tax return instructions. Schedule M (Form 1040A or 1040) 2010
(HTA)
I
XXXXXXXXX
UNDERKOFFLER
ANDREW
2005 SHEEPFORD RD
MECHANICSBURG
717-683-6669
1000118016 1
PA-40 - 2010
Pennsylvania Income Tax Return
ENTER ONE LETTER OR NUMBER IN EACH BOX.
Do Not Use Your Preprinted Label
J Occupation FORKLIFT 0
Occupation
PA 17055
21900
la Gross Compensation. Do not include exempt income, such as combat zone pay and
qualifying retirement benefits. See the instructions.
lb Unreimbursed Employee Business Expenses.
1c Net Compensation. Subtract Line 1b from Line 1a.
N Extension.
N Amended Return.
R Residency Status.
PA Resident/Nonresident/Part-Year Resident
from to
S Single/Married, Filing Jointly/Married,
Filing Separately/Final Retum/Deceased
Date of death
N Farmers.
School District Name W E S T S H 0 R E
2 Interest Income. Complete PA Schedule A if required.
3 Dividend and Capital Gains Distributions Income. Complete PA Schedule B if required.
4 Net Income or Loss from the Operation of a Business, Profession or Farm.
5 Net Gain or Loss from the Sale, Exchange or Disposition of Property.
6 Net Income or Loss from Rents, Royalties, Patents or Copyrights.
7 Estate or Trust Income. Complete and submit PA Schedule J.
8 Gambling and Lottery Winnings. Complete and submit PA Schedule T.
9 Total PA Taxable Income. Add only the positive income amounts from Lines 1 c,
2, 3, 4, 5, 6. 7 and 8. DO NOT ADD any losses reported on Lines 4, 5 or 6.
10 Other Deductions. Enter the appropriate code for the type of deduction. N
See the instructions for additional information.
11 Adjusted PA Taxable Income. Subtract Line 10 from Line 9.
1a 38337
1b 0
1C
F 38337
2 0
3 0
4 0
5 0
6 0
7 0
8 0
9 38337
10 0
11 38337
EC Page 1 of 2 FC
1000118016 ?? ????? ?? 1000118016
J PA-40 - 2010 1000218022
Social Security Number
XXXXXXXXX Name(s) UNDERKOFFLER ANDREW J
12 PA Tax Liability. Multiply Line 11 by 3.07 percent (0.0307).
13 Total PA Tax Withheld. See the instructions.
14 Credit from your 2009 PA Income Tax return.
15 2010 Estimated Installment Payments.
16 2010 Extension Payment.
17 Nonresident Tax Withheld from your PA Schedule(s) NRK-1. (Nonresidents only)
18 Total Estimated Payments and Credits. Add Lines 14, 15, 16 and 17.
Tax Forgiveness Credit. Submit PA Schedule SP.
19a Filing Status: 01 Unmarried or Separated 02 Married 03 Deceased
19b Dependents, Part B, Line 2, PA Schedule SP
20 Total Eligibility Income from Part C, Line 11, PA Schedule SP.
21 Tax Forgiveness Credit from Part D, Line 16, PA Schedule SP.
22 Resident Credit. Submit your PA-Schedule(s) G-R with your
PA Schedule(s) G-S, G-L and/or RK-1.
23 Total Other Credits. Submit your PA Schedule OC.
24 TOTAL PAYMENTS and CREDITS. Add Lines 13, 18, 21, 22 and 23.
25 TAX DUE. If Line 12 is more than Line 24, enter the difference here.
26 Penalties and Interest. See the instructions. Enter Code:
If including form REV-1630/REV-1630A, mark the box.
T
27 TOTAL PAYMENT DUE. See the instructions.
28 OVERPAYMENT. If Line 24 is more than the total of Line 12 and Line 26, enter
the difference here.
The total of Lines 29 through 35 must equal Line 28.
29 Refund - Amount of Line 28 you want as a check mailed to you. Refund
30 Credit - Amount of Line 28 you want as a credit to your 2011 estimated account.
31 Amount of Line 28 you want to donate to the Wild Resource Conservation Fund.
32 Amount of Line 28 you want to donate to the Military Family Relief Assistance Program.
33 Amount of Line 28 you want to donate to the Governor Robert P. Casey Memorial
Organ and Tissue Donation Awareness Trust Fund.
34 Amount of Line 28 you want to donate to the Juvenile (Type 1) Diabetes Cure
Research Fund.
35 Amount of Line 28 you want to donate to the PA Breast Cancer Coalition's Breast
and Cervical Cancer Research Fund.
Signature(s). Under penalties of penury, I (we) declare that I (we) have examined this return, including all
accompanying schedules and statements, and to the best of my (our) belief, they are true, correct, and complete.
Your Signature I Spouse's Signature, if filing jointly
Preparer's Name and Telephone Number
Shoffner Income Tax Service
Date
L.
12 1177
13 1177
14 0
15 0
16 0
17 0
18 0
19a 00
19b 00
20 0
21 0
22 0
23 0
24 1177
25 0
26 0
27 0
28 0
29 0
30 0
31 0
32 0
33 0
34 0
35 0
E-File Opt Out
0414111 Firm FEIN
(717)938-2666 I Preparer's SSN/PTIN XXXXXXXXX
Page 2 of 2
10002180.22 1000218022 1
1001910023
PA SCHEDULE W-2S
Wage Statement Summary
PA-40 Schedule W-2S 201 0
09-10 I OFFICIAL USE ONLY
Summary of PA Taxable Employee, Non-employee and Miscellaneous Compensation
Name shown first on the PA-40 (if filing jointly) Social Security Number (shown first)
ANDREW J UNDERKOFFLER X)()(-X(-XXXX
Use this schedule to list and calculate your total PA taxable compensation and PA tax withheld from all sources.
Part A Instructions: List each Federal Form W-2 for you and your spouse, if married, received from your employer(s). In the first column enter T for the taxpayers
Social Security Number that appears first on the PA tax return and enter S for the second or spouse SSN. From the Forms W-2, enter each employer's federal identification
number. Enter the amounts from the Forms W-2 in each column. IMPORTANT: You do not have to submit a copy of your Form W-2 if you earned all your income in
Pennsylvania and your employer reported your PA wages correctly and withheld the correct amount of PA income tax. You must submit a copy of your Form W-2 in
certain circumstances. See the PA Schedule W-2S instructions for a list of when a copy of a W-2 is required.
Part B Instructions: List each source of income received during the taxable year on a form or statement other than a Federal Form W-2. Enter each payers name. List
the payment type that most closely describes the source of your non-employee compensation. Enter the amount of other compensation that you earned. If the form or
statement does not have separately stated amounts, enter the amount shown in both Federal and PA columns.
IMPORTANT: You must submit a copy of each form and statement that you list in Part B, whether or not the payer withheld any PA income tax and regardless of
whether or not the income was taxable in PA. CAUTION: The federal and Pennsylvania (state) wages may be different in Part A and Part B.
If ed more s ace ou may photocopy this schedule or make your own schedules in this format.
you ne p , y
Part A - Federal Forms W-2
TIS
Employer's identification number from Box b Federal wages
from Box 1 Medicare wages
from Box 5 PA compensation
from Box 16 PA income tax
withheld from Box 17
T XX-XXXXXXX 38,337 38,337 38,337
7
1,17
Total Part A- Add the Pennsylvania columns 38 337
7
1,17
Part B - Miscellaneous and Non-employee Compensation from Federal Forms 1099-11, 1099-MISC and other statements
YOU MUST SUBMIT COPIES OF EACH FORM OR STATEMENT LISTED IN THIS PART
A.
T/S B.
Type C.
Payer name D.
1099R code E.
Total federal amount F.
Adjusted plan basis G.
PA compensatior H.
PA tax withheld
Total Part B - Add the Pennsylvania columns
TOTAL - Add the totals from Parts A and B 38,3371 1,177
Enter the TOTALS on your PA tax return on: Line 1a _ Line 13
Payment type: A. Executor fee B. Jury duty pay C. Director's fee D. Expert witness fee
E. Honorarium F. Covenant not to compete G. Damages or settlement for lost wages. other than personal injury
H. Other nonemployee compensation. Describe:
1. Distribution from employer sponsored retirement, pension or qualified deferred compensation plan
J. Distribution from IRA (Traditional or Roth) K. Distribution from Life Insurance, Annuity or Endowment Contracts
L. Distribution from Charitable Gift Annuities
1 1001910023 1001910023 1
FORM 531 - FINAL EARNED INCOME TAX RETURN
WEST SHORE TAX BUREAU
PHONE: 717-761-4900
WEB SITE: WWW.WESTAB.ORG TAX YEAR 2010
ATTACH APPROPRIATE
COPIES OF STATE
SCHEDULES AND/OR ALL
W-2'S & 1099'S
_... -.-. - no Ccrnoc Boon Irth FvFni it tun TAX IS DUE OR IF ALL TAX HAS BEEN WITHHELD
FULL YEAR RESIDENT YES ?X NO L] MUNICIPALITY
FLER A huisband`and>wife may both 1,4 on this form, however
tax CaiGUli kmo must be roporto in separate cottin'".
Joint filing (combining of Income or expsnsee) Is not
i?{rid l
ANDREW J UNDERKO
2005 SHEEPFORD RD
MECHANICSBURG PA 17055
Lower Allen Township 058 - West Shore School District
IF YOU MOVED DURING THE TAX YEAR COMPLETE THE FOLLOWING M
VING INFORMATION:
Moved in Address Moved in Address
Moved Out Moved Out
Moved in Moved in
Moved Out Moved Out
YOU MUST Taxpayer A SS #° -XX-XXXX TIP A - NAME y TIP B - NAMEy
COMPLETE Taxpayer B SS # ANDREW J UNDERK
Gross Earnings from Employment: Enclose w-2s
1 1 38,337
.
Allowable Non-Reimbursed Employee Business Expenses Enclose PA Sch UE
2 2
.
Other Earned income Enclose 1099-MISC / 1099-R Excluding CODES 3,4 & 711099-C
DIVIDENDS or CAPITAL GAINS
3
DO NOT INCLUDE INTEREST 3
.
,
4. Taxable Earnings Line 1 minus Line 2 plus Line 3. CAN NOT BE < $0 4 38,337
Net Profit Attach PA Sch C, F, RK-1 and/or NRK-1
5
reverse side onl
f
t
C
P
* 5
.
y
on
ro
i
orp
REPORT S
6. Net Loss Attach PA Sch C, F, RK-1 and/or NRK-1
on reverse side only
L
RT S C
*
6
oss
orp
REPO
7. Subtotal Subtract Line 6 from Line 5 IF LESS THAN ZERO, ENTER ZERO 7
8. Total Earned Income Line 4 plus Line 7 DO NOT ROUND PAST THIS POINT 8 38,337
9. Tax Liability Line 8 multiplied by tax rate 1.45% (See instructions) 9 556
10. Earned Income Tax Withheld 10 383
11. Quarterly Estimated Payments/Credit From Previous Tax Year 11
12. Misc Credit See worksheet on back of form for calculating Philadelphia/Out of State Credit 12
13. Total of 10, 11, & 12 13 383
14. REFUND/CREDIT Subtract Line 9 from Line 13 NOTE: NO Refunds under $1.00 14
15. CREDIT TO NEXT YEAR/CREDIT TO SPOUSE Next Year ? Spouse ? 1 5
16. TAX DUE If Line 9 is greater than Line 13-Subtract Line 13 from Line 9
00 need not be paid.
NOTE: Amounts Less than $1 1 6 173
.
17. Penalty after April 15th SEE INSTRUCTIONS 1 7
18. Interest after April 15th SEE INSTRUCTIONS 1 8
19. TOTAL AMOUNT DUE Line 16 plus Line 17 plus Line 18 1 9 173
MAKE CHECKS PAYABLE TO WEST SHORE TAX BUREAU. A FEE OF $20.00 WILL BE CHARGED FOR RETURNED CHECKS.
I declare under penalties of perjury that I have examined this return and to the best of my knowledge and belief, it is a true, accurate and complete return.
re-Taxoaver A Date Occupation E-Mail Daytime Telephc
FORKLIFT OPER
TaxoaverB
Preparer's Name/Address (Please Print) Preparer's Telephone
Herbert Shoffner 847 Heck Hill Rd Lewisberry PA 17339-9142 (717)938-2666 71
National Account 5erviaes Year To Date Earnings
a mac- acv a.d i Hourly Pay,* . ; X77:•26'
Overtime -.1.5x yo39'11j
DD6bj6ima' 2 ..Ox ` 7
Vacation
019.017384 EXEL1 " Hol idyy P { T 00;,
Floating/njetiona{y Holtddyr k?, OC
*? Zncf ease y" pD:20
Lump R"
.? y. ?f tin.
Non-DisaaK onary'Bohus lgZ?23
472.60 .
3bU?li?.
X14': Ofi 7
37AA
T72 -96
2010 Em to ee's Copy C - For EMPLOYEE'S RECORDS. (See Notice to Employee back)
Form W-2 Wage and Tax Statement p y Department of the Treasury-Internal Revenues Service. This information is being furnished
Copy the internal Revenue Service. If you are required to file a tax return, a negligence penalty
other sanction may be imposed on you if this income is taxable and you fail to report it.
OMB No. 1545-0008
V
ANDREW J. UNDERKOFFLER : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENN SYLVANIA
Plaintiff
vs.
NO. 09-1168 204x? x,. =-_•.
C=am
KAREN J. UNDERKOFFLER
Defendant C a =ri'
MOTION FOR APPOINTMENT OF MASTER
Z C,
ANDREW J. UNDERKOFFLER, _Plaintiff , moves the court to appoint a master C)
wit4;jpecCM
the following claims:
?
?X Divorce ?X Distribution of Property
-
.t-
? Annulment ? Support
?X Alimony ? Counsel Fees
? Alimony Pendente Lite ? Costs and Expenses
and in support of the motion states:
1. Discovery is complete as to the claims (s) for which the appointment of a master is requested.
2. The defendant has not appeared in the action (personally) (by his attorney,_
Esquire).
3. The staturory ground (s) for divorce is
NO FAULT: 23 Pa.C.S. Section 3301 (c)
4. Delete the inapplicable paragraph (s): A ? B ® C ?
a. The action is not contested.
b. An agreement has been reached with respect to the following claims:
C. The action is contested with respect to the following claims:
5. The action does not involve complex issues of law or fact.
-MOD
C= r mn
The hearing is expected to take Four hours G-)
1
7. Additional information, if any, relevan
x>- C) 3C
?;
• -n;7'
(i ,
* ?,:
.C-
Date:
Alfteifo/r/Plaintiff
squ
ire
Print Name
ORDER APPOINTING MASTER
AND NOW 20
17 Esquire,
1
is appointed master with re
spect to the following claims: zk Q4-e
-)L i .
By the Court,
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4I aren J. onderkoffler 81,8111
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Jay R. Braderman, Esquire
Attorney I.D. No. 07047
Lavery Faherty Patterson
225 Market Street, Suite 304
P. O. Box 1245
Harrisburg, PA 17108-1245
Tel: 717-233-6633
Fax: 717-233-7003
Attorneys for Plaintiff
0f7 " ? n) !4040 TAf- t
1111 FER 16 AM 10: 5Q
IMIERLAND COUNTY
PENNSYLVANIA
ANDREW J. UNDERKOFFLER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
vs.
KAREN J. UNDERKOFFLER,
Defendant
(Domestic Mail Only; No Insurance Coverage Provided)
For delivery information visit our website at www.uspsxom W
NO. 09-1168 CIVIL TERM
IN DIVORCE
PROOF OF SERVICE
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Jay R. Braderman, Esquire
Attorney I.D. No. 07047
Lavery Faherty Patterson
225 Market Street Suite 304
P. O. Box 1245
Harrisburg, PA 17108-1245
Tel: 717-233-6633
Fax: 717-233-7003
Attorneys forPlaintifl
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('L't,BERLAND COUNT`'
PEMNs YLVAt41
ANDREW J. UNDERKOFFLER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
vs.
NO. 09-1168 CIVIL TERM
KAREN J. UNDERKOFFLER,
Defendant IN DIVORCE
NOTICE OF INTENTION TO REQUEST ENTRY OF § 3301 (d) DIVORCE DECREE
TO: KAREN J. UNDERKOFFLER:
You have been sued in an action for divorce. You have failed to answer the
complaint or file a counter-affidavit to the § 3301(d) affidavit. Therefore, on or after
March 27, 2012, the other party can request the Court to enter a final decree in divorce.
If you do not file with the Prothonotary of the Court an answer with your signature
notarized or verified or a counter-affidavit by the above date, the Court can enter a final
decree in divorce. A counter-affidavit which you may file with the Prothonotary of the
Court is attached to this notice.
Unless you have already filed with the Court a written claim for economic relief,
you must do so by the above date or the Court may grant the divorce and you will lose
forever the right to ask for economic relief. The filing of the form counter-affidavit alone
does not protect your economic claims.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF
YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATIOHN ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
TELEPHONE: 717-249-3166
Jay R. Braderman, Esquire
Attorney I.D. No. 07047
Lavery Faheriy Patterson
225 Market Street, Suite 304
P. O. Box 1245
Harrisburg, PA 17108-1245
Tel: 717-233-6633
Fax: 717-233-7003
Attorneys for Plaintiff
ANDREW J. UNDERKOFFLER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
vs.
NO. 09-1168 CIVIL TERM
KAREN J. UNDE RKOFFLER,
Defendant IN DIVORCE
COUNTER-AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE
1. Check either (a) or (b):
(a) I do not oppose the entry of a divorce decree.
(b) I oppose the entry of a divorce decree because
(Check (i), (ii) or both):
(i) The parties to this action have not lived separate and apart for
a period of at least two years.
(ii) The marriage is not irretrievably broken.
2. Check either (a) or (b):
(a) I do not wish to make any claims for economic relief. I understand that I may
lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not
claim them before a divorce is granted.
(b) I wish to claim economic relief which may include alimony, division of property,
lawyer's fees or expenses or other important rights.
I understand that in addition to checking (b) above, I must also file all of my
economic claims with the Prothonotary in writing and serve them on the other party. If I
fail to do so before the date set forth on the Notice of Intention to Request Divorce
Decree, the divorce decree may be entered without further notice to me, and I shall be
unable thereafter to file any economic claims.
I verify that the statements made in this counter-affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
§4904 relating to unsworn falsification to authorities.
Date:
Karen J. Underkoffler
NOTICE: If you do not wish to oppose the entry of a divorce decree and you
do not wish to make any claim for economic relief, you should not file this
counter-affidavit.
10
Jay R. Braderman, Esquire
Attorney I.D. No. 07047
Lavery Faherty Patterson
225 Market Street, Suite 304
P. O. Box 1245
Harrisburg, PA 17108-1245
Tel: 717-233-6633
Fax: 717-233-7003
Attorneys for Plaintiff
?FiO TA t
f Z AP -2 P,m ?:
7'.'13SERLA0 COUNT,
,
PI- NNS YL't?ANIA
ANDREW J. UNDERKOFFLER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 09-1168 CIVIL TERM
r
KAREN J. UNDERKOFFLER,
Defendant
IN DIVORCE
PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE
If you wish to deny any of the allegations set forth in this Affidavit, you must file a
Counter-affidavit within twenty (20) days after this Affidavit has been served on you or the
allegations will be admitted.
1. A complaint in Divorce under Section 3301 (d) of the Divorce Code was
filed on February 26, 2009.
2. The parties to this action separated on or about February 1, 2003 and have
continued to live separate and apart for a period of at least two years.
3. The marriage is irretrievably broken.
4. 1 understand that if a claim for alimony, alimony pendente lite, equitable
distribution of marital property, counsel fees, costs or expenses has not been filed with
the Court before the entry of a final decree in divorce, the right to claim any of them will
be lost.
I verify that the statements in this Affidavit are true and correct. I understand that
all statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to
unsworn falsification to authorities. /
?r
Date:
Andrew J. Underkoffler
Jay R. Braderman, Esquire
Attorney I.D. No. 07047
Lavery Faherty Patterson
225 Market Street, Suite 304
P. O. Box 1245
Harrisburg, PA 17108-1245
Tel: 717-233-6633
Fax: 717-233-7003
Attorneys for Plaintiff
ANDREW J. UNDERKOFFLER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
vs.
NO. 09-1168 CIVIL TERM
KAREN J. UNDERKOFFLER,
Defendant IN DIVORCE
COUNTER-AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE
1. Check either (a) or (b):
(a) I do not oppose the entry of a divorce decree.
(b) I oppose the entry of a divorce decree because
(Check (i), (ii) or both):
(i) The parties to this action have not lived separate and apart for
a period of at least two years.
(ii) The marriage is not irretrievably broken.
2. Check either (a) or (b):
(a) I do not wish to make any claims for economic relief. I understand that I may
lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not
claim them before a divorce is granted.
(b) I wish to claim economic relief which may include alimony, division of property,
lawyer's fees or expenses or other important rights.
I understand that in addition to checking (b) above, I must also file all of my
economic claims with the Prothonotary in writing and serve them on the other party. If I
fail to do so before the date set forth on the Notice of Intention to Request Divorce
Decree, the divorce decree may be entered without further notice to me, and I shall be
unable thereafter to file any economic claims.
I verify that the statements made in this counter-affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
§4904 relating to unsworn falsification to authorities.
Date:
Karen J. Underkoffler
NOTICE: If you do not wish to oppose the entry of a divorce decree and you
do not wish to make any claim for economic relief, you should not file this
counter-affidavit.
Kart R. Hildabrand, Esquire
Attorney LD. No. 30102
Lavery Faherty Patterson
225 Market Street, Suite 304
P. O. Box 1245
Harrisburg, PA 17108-1245
Te1.• 717-233-6633
Fax: 717-233-7003
Attorneys for Plaint>tf
~~- -~ fair Pr~(77HONOTAi~'~
ZQl1 AUG ! 7 AN 11~ 18
CUMBERLAND COUNTY
~ENNSYLVAN~a
ANDREW J. UNDERKOFFLER, IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
vs.
KAREN J. UNDERKOFFLER,
Defendant
CIVIL ACTION -LAW
NO. 09-1168 CIVIL TERM
IN DIVORCE
PLAINTIFF'S PETITION PURSUANT TO Pa.R.C.P. 2056(b)
FOR THE APPOINTMENT OF A GUADIAN AD LITEM FOR
DEFENDANT KAREN J. UNDERKOFFLER WITH RESPECT TO THE
ABOVE CAPTIONED DIVORCE ACTION
1. Plaintiff Andrew J. Underkoffler commenced the above-captioned D
Action by the filing of a Complaint on February 26, 2009.
2. Plaintiff and Defendant were married on October 10, 1987 and separated
on or about February 1, 2003.
3. There was one child born of the marriage, Ryan Underkoffler, born
17, 1992, who is now 19 years of age.
4. Plaintiffs Complaint sought Divorce under Section 3301(c) or Section
3301(d) of the Divorce Code and sought an order of equitable distribution pursuant to
Section 3502 of the Divorce Code.
r
5. Defendant Karen J. Underkoffler is not represented in the current action.
6. The Divorce Complaint was served upon the Defendant, by certified mail
return receipt requested, on March 7, 2009.
7. On August 11, 2011 Plaintiff filed a Motion for Appointment of Master
together with his Inventory and Income and Expense Statement.
8. On August 17, 2011 This Honorable Court signed an Order appointing E.
Robert Elicker, 11, Esquire as Master in this matter.
9. On or about October 12, 2011 Plaintiff filed his Pre-Trial Statement
pursuant to Pa.R.C.P. 1920.33(b).
10. On October 24, 2011 aPre-Hearing Conference was held with the D
Master and the Defendant failed to appear.
11. At the Pre-Hearing Conference in October the Master suggested that the
marital home be appraised and that the rental value be determined, especially since
Defendant continues to reside there. In addition, the Master recommended that the
Plaintiff send Interrogatories to Defendant to discover assets.
12. On November 9, 2011 counsel for Plaintiff sent Plaintiff's Interrogatories
addressed to Defendant by certified mail, return receipt requested to the Defendant.
13. Plaintiff s counsel also attempted to arrange an appraisal of the marital
residence but the Defendant failed to respond to correspondence from Plaintiffs cou
and Plaintiffs appraiser, Mark Heckman.
14. On January 26, 2012 Plaintiffs counsel sent, by certified mail, a copy of
Master's Order and notice scheduling a hearing date for February 14, 2012 at 9:00 a.
It was also noted that the Defendant had ignored and not responded to the
Interrogatories and had failed to cooperate with the appraiser in scheduling access to tl~e
home. This mail was sent certified mail and was returned to Plaintiff's counsel marked)
"return to sender unclaimed."
15. Prior to the February, 2012 hearing Plaintiff s counsel subpoenaed the
Defendant, and her parents, Paul Rehm, Sr. and Dorcas Rehm.
16. On February 14, 2012 Plaintiff s counsel notified the Defendant, by
mail, return receipt requested, that the Master's Hearing had been re-scheduled for
March 14, 2012 at 9:00 a.m. and indicated "the earlier hearing date was continued so
you would have more time to reply and/or attend." A copy of the Plaintiffs Affidavit ar
Counter-Affidavit for use by the Defendant was also forwarded to the Defendant.
17. On February 29, 2012 Plaintiff s counsel's paralegal, Susan Gelber,
received a phone call from Dorcas Rehm, the Defendant's mother. She was in tears
was very worried that she would be arrested if she could not get Karen to the hearing.
She further advised that Mr. Rehm, due to his health, would be unable to attend. Mrs.
Rehm further advised that the house was not in good condition and indicated that she
had used most or all of her social security check to pay the Defendant's expenses.
18. Again, on March 7, 2012 Plaintiffs counsel sent to the Defendant the
of Intention to Request Entry of 3301(d) Divorce Decree and attached a Counter
under Section 3301(d) of the Divorce Code for use by the Defendant. The letter
concluded: "You should fill out and return the Counter-Affidavit in the self-addressed
stamped envelope. It is very important that you respond and attend the hearing on
March 14 as it is possible that you may lose certain marital property rights."
19. On March 14, 2012 Plaintiff and Plaintiff's counsel and Mrs. Dorcas
attended the hearing/conference with the Divorce Master, Attorney Elicker. The
Defendant, Karen Underkoffler, refused to appear and ignored the subpoena.
20. The Defendant failed to respond to Plaintiff s Affidavit, Counter-Affidavit
Notice of Intention to Request Entry of 3301(d) Divorce Decree.
21. At the Master's Hearing discussion was held regarding the possible
appointment of a guardian for Defendant Karen Underkoffler. The Master asked that
Mrs. Rehm prepare a list for counsel of all of the avenues that she had pursued in
attempting to obtain help for the Defendant. To date, Mrs. Rehm has not provided that
list.
22. Plaintiff, and the party's adult son, believe that the Defendant is not
competent to handle her own affairs and unwilling and unable to properly represent
herself in the pending Divorce.
23. Plaintiff believes that a Guardian Ad Litem should be appointed to
the Defendant in the pending Divorce action so that her rights are properly represented
and that the matter can proceed to conclusion.
24. Plaintiff respectfully requests that This Court issue a Rule upon Defe
Karen J. Underkoffler to Show Cause, if any she has, why a Guardian Ad Litem should
not be appointed to represent her interests in the pending action pursuant to Pa.R.C.P.
nt
2056(b}.
25. Pursuant to Rule 2056 Plaintiff has provided notice of this Petition to the
Defendant, Karen J. Underkoffler, her parents, Paul Rehm, Sr. and Dorcas Rehm, and
her adult son, Ryan Underkoffler.
Date: r f S l?.i
Respectfully submitted,
Lavery Faherty Patterson
~.a ~
arl R. Hildabrand, Esquire
Attomey I.D. No.: 30102
225 Market Street, Suite 304
P.O. Box 1245
Harrisburg, PA 17108-1245
Tel: 717-233-6633
Fax: 717-233-7003
khildabrandCa~laverylaw.com
Attomey for Plaintiff
VERIFICATION
I, Andrew J. Underkoffler, verify that the statements made in the foregoing
for Appointment of Guardian Ad Litem are true and correct to the best of my knowledge,
information and belief. I understand that false statements herein are made subject to tfhe
penalties of 18 Pa. C.S. §4904 relating to unsworn falsecation to authorities.
Da#e:
Andrew J. n erkoffler
Kart R. Hildabrand, Esquire
Attorney I.D. No. 30102
Lavery Faherty Patterson
225 Market Street, Suife 304
P. O. Box 1245
Harristwrg, PA 1710&1245
Tel: 717-233-6633
Fax: 717-233-7003
Attorneys for Plaintiff
~~
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ANDREW J. UNDERKOFFLER, IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
vs.
NO. 09-1168 CIVIL TERM
KAREN J. UNDERKOFFLER,
Defendant IN DIVORCE
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance on behalf of Plaintiff, Andrew J. Underkoffler, in the
above matter.
Respectfully submitted,
Lavery Faherty Patterson
DATE: ?~
By:
arl R. Hildabrand, Esquire
Atty No. PA30102
225 Market Street, Suite 304
P.O. Box 1245
Harrisburg, PA 17108-1245
(717) 233-6633 (telephone)
(717) 233-7003 (facsimile)
khildabrand@laverylaw.com
Attorney for Plaintiff
CERTIFICATE OF SERVICE
I, Karl R. Hildabrand, Esquire of the law arm Lavery Faherty Patterson,
certify that I served a true and exact copy of the foregoing document referenced to
foregoing Entry of Appearance by First Class Mail, postage prepaid, this ~ day of
August, 2012, on the following:
Karen J. Underkoffler
1060 Yocumtown Road
Etters, PA 17319
. Hildabrand
Karl R. H' brand, Esquire
Attorney L . No. 30102
Lavery Faberty Patterson
225 Market Street, Suite 304
P. 0. Box 1245
Harrisburd. PA 17108-1245
Tel: 717- 33-6633
Fax: 717- 33-7003
Attorneys or Plaintiff
ANDREW J. UNDERKOFFLER,
Plaintiff
J .?
M c
77
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
vs.
NO. 09-1168 CIVIL TERM
KAREN u. UNDERKOFFLER,
Defendant IN DIVORCE
CERTIFICATE OF SERVICE
I, (Karl R. Hildabrand, Esquire, of the law firm of Lavery Faherty Patterson, counsel
for Andrew J. Underkoffler, hereby certify that I served a true and exact copy of Plaintiff's
Petition Pursuant to Pa. R.C.P. 2056(b) for the Appointment of a Guardian Ad Litem for
Defendant Karen J. Underkoffler with Respect to the Above Captioned Divorce Action, by
First Class Mail, postage prepaid, this 15th day of August, 2012, on the following:
Karen J. Underkoffler
1060 Yocumtown Road
Etters, PA 17319
R. Hildabrand
ANDREW J. UNDERKOFFLER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
V.
KAREN J. UNDERKOFFLER,
Defendant
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
NO. 09-1168
IN DIVORCE
C
n
-
n?
CD
C,)
Kindly enter my appearance on behalf of the Defendant, Karen J. Underkoffler, in the
above-captioned divorce proceeding.
Respectfully submitted,
?ohn err aw. PC
5020 RMter RoHd
SuNe 104
Medw9c9bkII9, PA 17055
PHow 717.766.4008
FAx: 717.788.4066
Dated: October 15, 2012
Q. /1I.1'?'??
J C09 MKerr
Attorney I.D. # 26414
John Kerr Law, P.C.
5020 Ritter Road
Suite 104
Mechanicsburg, PA 17055
(717) 766-4008
CERTIFICATE OF SERVICE
The undersigned hereby certifies that he has served a copy of the foregoing, "Entry of
Appearance," on the below-named individual in the manner indicated:
First Class Mail, Postage Prepaid
Karl R. Hildabrand, Esquire
Lavery Faherty Patterson
225 Market Street
Suite 304
P.O. Box 1245
Harrisburg, PA 17108-1245
J4 144W
1oh 9Kerr, Esquire
502 Ritter Road
Suite 104
Mechanicsburg, PA 17055
(717) 766-4008
Dated: October 15, 2012
Qohn Kerr aw, PC
v 5020 FUM Road
SIffie 104
MedwWS 9, PA 17055
FHoNE: 717.788.4008
FAx: 717.788.4088
ANDREW J. UNDERKOFFLER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY PENNYSLVANIA
c
c= cm -�
No. 09-1168 -Q 3 w ��
V. rn C In
CIVL ACTION—LAW r; 7
in r— CD
KAREN J. UNDERKOFFLER, -<—' —�
Defendent IN DIVORCE
c ca r
DEFENDANT'S ANSWER WITH RELATED CLAIMS TO COMPLAINT IN DIVORCE
AND NOW,comes Karen J. Underkoffler, by her attorney,John M. Kerr, Esquire, and
John Kerr Law, P.C., and files the within Answer with Related Claims to Complaint in Divorce,the
nature of which is as follows:
Count I - Divorce
1. ADMITTED.
2. DENIED. Defendant's current address is 1068 Yocumtown Road, Etters,York County,
Pennsylvania, 17319.
3. ADMITTED.
4. ADMITTED.
5. ADMITTED
6. ADMITTED
7. ADMITTED.
\yohn Ke,,,4—a ..PC 8, ADMITTED
a 5020 Ritter Road
State 104
McChardCSbUrg,PA 17055
PHONE: 717.766.4008
FAx: 717.766.4066
NEW MATTER—RELATED CLAIMS UNDER THE DOMESTIC RELATIONS CODE
COUNT I—REQUEST FOR ALIMONY PEDENTE LITE, COUNSEL FEES AND EXPENSES
;x-02��wo
9. Defendant Karen Underkoffler incorporates by reference, as if fully set forth in their
entirety, her answers to paragraphs 1-8 above.
10. Defendant, Karen Underkoffler is on a fixed income, receiving only social security
disability benefits.
11. As a consequence, Defendant lacks the economic resources to support herself and to
pay counsel fees and expenses in order to properly litigate this action.
12. Plaintiff is financially able to provide for the reasonable needs of Defendant during the
remainder of this action.
WHEREFORE, Defendant requests that she be awarded a reasonable sum for alimony pendent
lite, counsel fees and expenses.
COUNT II- REQUEST FOR AN AWARD OF ALIMONY
13. As set forth at paragraph 10-11 above, Defendant lacks the earning capacity to fully
support herself through appropriate employment.
14. Defendant's sole and separate property, including the marital property subject to
distribution, is insufficient to provide for her reasonable needs.
15. Plaintiff is financially able to provide for the reasonable needs of the Defendant.
01111 J<err
v 5020 RIM,Road
SX 104
MCCharftSbUrg,PA 17055
PHONE: 717.766.4008
FAx: 717.766.4066
WHEREFORE, Defendant requests that she be awarded a reasonable sum for alimony
following the entry of a divorce decree.
Respectfully submitted,
Q4 )0,)4v"
Jo 0 M. Kerr, Esquire
Attorney I.D. 26414
John Kerr Law, P.C.
5020 Ritter Road
Suite 104
Mechanicsburg, PA 17055
(717)766-4008
Dated: July 9, 2013
\/john�err�aw.PC
a 5020 Ritter Road
Suite 104
MechaniCSburg,PA 17055
PHONE: 717.766.4008
FAx: 71 7.766.4066
`
CERTIFICATE OF SERVICE
The undersigned hereby certifies that he has served a copy of the foregoing,
"Defendant's Answer To Amended Complaint in Divorce," on the below-named individuals in
the manner indicated:
VIA FASCIMILE: (717)233-7003 HAND-DELIVERED
Karl R. Hi|dabrond Robert E. E|iciker, ||
Lavery FahertyPatterson Divorce Master
225 Market Street 9 Hanover Street
Suite 304 Carlisle, PA17O13
P.O. Box 1345
Harrisburg, PAl71O8-1245
Joh M. Kerr, Esquire
50/0 Ritter Road
Suite 104
Mechanicsburg, PA17OS5
(717)766-4008
Dated:July 9,2013
5020 Ritter Road
suite 104
Mechanicsburg,m`m55
r"v=. 717.766.4008
pA3c 717.766'4066
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F'lLL wif F r
Karl R.Hildabrand,Esquire 2013 JUL t
Lavery Faherty Patterson (�t
225 Market Street,Suite 304
P.O.Box 1245 'IMBERLAND CClU14T V
�
Harrisburg,PA 17108-1245 PENNSYLVANIA
(717)233-6633 (telephone)
(717)233-7003 (facsimile)
Atty No.PA30102
khildabrand@laverylaw.com
Attorney for Plaintiff
ANDREW J.UNDERKOFFLER, : IN THE COURT OF COMMON PLEAS
Plaintiff, : CUMBERLAND COUNTY,PENNSYLVANIA
V. NO. 09-1168-DV
KAREN J. UNDERKOFFLER, CIVIL ACTION- LAW
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days
have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of Notice of
Intention to Request Entry of the Decree.
I verify that the statements made in this affidavit are true and correct. 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:
Andrew J. U erkoffler, Defend
1L Eli-0 F F'k',
Karl R.Hildabrand,Esquire +
Lavery Faherty Patterson
225 Market Street, Suite 304
P.O.Box 1245 CUMBERLAND COUNTY
Harrisburg,PA 17108-1245 PENNSYLVANIA
(717)233-6633 (telephone)
(717)233-7003 (facsimile)
Atty No.PA30102
khildabrand@laverylaw.com
Attorney for Plaintiff
ANDREW J. UNDERKOFFLER, : IN THE COURT OF COMMON PLEAS
Plaintiff, : CUMBERLAND COUNTY,PENNSYLVANIA
V. NO. 09-1168-DV
KAREN J. UNDERKOFFLER, CIVIL ACTION -LAW
Defendant IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE
DECREE UNDER 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn
falsification to authorities.
Date:
v�
Andrew J. Und offler, Defendant
ANDREW K. UNDERKOFFLER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBLERAND COUNTY, PENNSYLVANIA
V,
NO. 09-1168 n+,
• ^el
KAREN J. UNDERKOFFLER, : IN DIVORCEti,
Defendant : CIVIL ACTION zM ; ,�:
DEFENDANTOS AFFIDAVIT OF CONSENT
UNDER SECTION §3301(c) & (d) OF THE DIVORCE CQDEI''
1. A Complaint in Divorce under Section §3301(c) and (d) of the Divorce Code
was filed on February 26, 2009.
2. The marriage of the Plaintiff and the 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 notice of
intention to request entry of the decree.
4. I verify that the statements made in this affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.
C.S. §4904 relating to unsworn falsification to authorities.
December 6, 2013
Kare J. Under Omer
ANDREW K. UNDERKOFFLER, IN THE COURT OF COMMON P ,S °
Plaintiff CUMBLERAND COUNTY, PENNg.VTIk i m'=
NO. 09-1168 r 4'
KAREN J. UNDERKOFFLER, : IN DIVORCE µx
Defendant : CIVIL ACTION r
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER §3301(c) and (d) OF THE DIVORCE CODE
1. I consent to entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by
the Court and that a copy of the decree will be sent to me immediately after it is
filed with the Prothonotary.
I verify that the statements made in this affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.
C.S. §4904, relating to unsworn falsification to authorities.
o
December 6, 2013
K ren . U rkoffler
ANDREW J. UNDERKOFFLER, • IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. • NO. 09 - 1168 CIVIL '
KAREN J. UNDERKOFFLER, Sri rn
Defendant IN DIVORCE " c-),
- CD-,
ORDER OF COURT c z'-_ -=
AND NOW, this 16 day of ,
2013, counsel and the parties having entered into an agreement
and stipulation resolving the economic issues on December 2,
2013, the date set for a Master' s hearing, 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,
•
Kevin . Hess, P.J.
cc: �' Karl R. Hildabrand
Attorney for Plaintiff
/Lc/ohn M. Kerr
Attorney for Defendant
COr 1.£S / ' ,41 lcL
ANDREW J. UNDERKOFFLER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. E4
- ,3 � >
KAREN J. UNDERKOFFLER, CIVIL ACTION - LAW 2 3 t--7 -
Defendant NO. 09-1168 CIVIL TERM c'E --
r
< '
THE MASTER: Today is Monday, December 2,
2013 . This is the date set for a hearing in the
above-captioned proceedings . Present in the hearing room
are the Plaintiff, Andrew J. Underkoffler, and his counsel,
Karl R. Hildebrand, and the Defendant, Karen J.
Underkoffler, and her counsel, John M. Kerr. Also present
in the hearing room are two family members of the Defendant,
Dorcas L. Rehm, the Defendant ' s mother, and Lucy M. Hart,
the Defendant ' s aunt . Also present as well is my law clerk,
Matthew Kudrick. Mr. Kerr and Mr. Hildebrand have advised
that an agreement has been reached. I will go on the record
after the agreement is stated on the record with some final
remarks, and I will let Mr. Kerr proceed now with statement
of the agreement that the parties and counsel have reached.
MR. KERR: Husband, Andrew J. Underkoffler,
initially filed the divorce action. This is the time for a
divorce master ' s hearing that has been scheduled. The
agreement would be as follows :
Karen Underkoffler, the Defendant in this
proceeding, retains the marital home located at 1060
Yocumtown Road, Etters, Pennsylvania, 17319 . Husband agrees
to relinquish all interest he has in this property as a
result of the marriage. Husband also agrees to withdraw his
claim for the fair rental value during the period of time
since separation when wife has been living at the residence
since he left . Currently the property is free and clear of
any liens including the original mortgage that was on the
property. Wife and husband agree that a deed reflecting
this transfer to Karen Underkoffler shall be prepared and
executed by husband within 30 days of this date, which is
December 2nd, 2013 . Counsel for the Defendant, Karen J.
Underkoffler, shall prepare the deed and present it to
counsel for husband in order for him to execute said deed.
THE MASTER: And the deed will be delivered
to Mr. Kerr upon execution.
MR. KERR: Husband shall retain his interest
in his Fidelity 401k from his former employment. Wife
agrees to relinquish any marital interest that she has in
said 401k.
Husband agrees to pay alimony to wife in the
amount of $364 . 80 from the date of any divorce decree for
two years (24 months) . Said alimony shall not be
modifiable . Husband agrees that wife ' s counsel shall
prepare an order for Domestic Relations so that said amount
2
of alimony may be deducted from his social security
disability payments on a monthly basis directly by Domestic
Relations .
Each party shall retain any tangible personal
property that they have in their possession as of this date.
MR. HILDABRAND: The additional paragraph
would indicate that there was an ambulance bill incurred by
Mrs . Underkoffler. The insurance check was apparently
mailed to Mr. Underkoffler. He cashed the check. Mr.
Underkoffler agrees to see that the ambulance bill is paid
or that Ms . Underkoffler is reimbursed, whichever is more
appropriate.
THE MASTER: And the approximate amount of
that is?
MR. HILD BRAND: Twelve hundred dollars .
MR. KERR: Except as herein otherwise
provided, each party may dispose of his or her property in
any way and each party hereby waives and relinquishes any
and all rights he or she may now have or hereafter acquire
under the present or future laws of any jurisdiction to
share in the property or the estate of the other as a result
of the marital relationship including, without limitation,
statutory allowance, widow' s allowance, right of intestacy,
right to take against the will of the other, and right to
act as administrator or executor in the other' s estate.
3
Each will at the request of the other execute, acknowledge,
and deliver any and all instruments which may be necessary
or advisable to carry into effect this mutual waiver and
relinquishment of all such interests, rights, and claims .
THE MASTER: I 'm going to go on the record
now with a few remarks . The complaint in divorce was filed
on February 26th, 2009, raising grounds for divorce of
irretrievable breakdown of the marriage . Although there was
an affidavit under Section 3301 (d) previously filed averring
a separation in excess of two years, nevertheless, counsel
and the parties have agreed to proceed under Section 3301 (c)
of the Domestic Relations Code . Mr. Underkoffler has filed
an affidavit of consent and a waiver of notice of intention
to request entry of divorce decree on July 11, 2013 . Mr.
Kerr indicated that he will have his client execute and will
file an affidavit under Section 3301 (c) with a waiver within
the next 7 days . Therefore the divorce can conclude under
Section 3301 (c) of the Domestic Relations Code .
The complaint in divorce raised a claim for
equitable distribution. The Defendant wife filed a
counterclaim for alimony on July 9, 2013 . Both of the
economic claims have been addressed in the foregoing
agreement .
The agreement that Mr. Kerr and Mr. Hildebrand
have placed on the record by stipulation is the final
4
agreement of the parties resolving all claims in this
action. The agreement is going to be transcribed and the
parties and counsel return later this morning to review for
typographical errors, and those corrections can be made if
necessary. However, no substantive changes can be made .
The agreement as stated on the record is considered the
agreement of the parties, even though there is no subsequent
signing. However, the Master is going to ask the parties to
return later this morning to review the agreement and then
sign affirming the terms of settlement as stated on the
record. The parties are bound by this agreement when they
leave the hearing room today.
The parties were married on October 10, 1987, and
separated on or about February 1, 2003 . They are the
natural parents of one emancipated child.
Now, Mr. Underkoffler, you've been present during
the statement of the agreement on the record, correct?
MR. UNDERKOFFLER: Yes .
THE MASTER: Do you understand the agreement?
MR. UNDERKOFFLER: Yes .
THE MASTER: And are you willing to resolve
the economic claims in this action based on the agreement
that ' s stated on the record?
MR. UNDERKOFFLER: Yes .
THE MASTER: And you understand that when you
5
leave this hearing room today, you' re bound by the
agreement?
MR. UNDERKOFFLER: Yes .
THE MASTER: You also understand you' re going
to come back a little later this morning and review the
agreement that ' s been drafted and sign it affirming the
settlement?
MR. UNDERKOFFLER: Yes .
THE MASTER: Mrs . Underkoffler, have you been
present during the statement of the agreement on the record?
MRS . UNDERKOFFLER: Yes .
THE MASTER: Do you understand the agreement?
MRS . UNDERKOFFLER: Yes .
THE MASTER: And are you willing to accept
the agreement as a final settlement of all issues raised in
this divorce?
MRS . UNDERKOFFLER: Absolutely.
THE MASTER: And you understand that you' re
bound by this agreement when you leave the hearing room
today?
MRS . UNDERKOFFLER: Yes .
THE MASTER: And you' re going to come back a
little later this morning and sign the agreement affirming
the settlement and complete the proceedings?
MRS . UNDERKOFFLER: Yes .
6
THE COURT: All right. Thank you very much.
We ' ll see you back here at 11 : 15 .
i
1
/// /
Andrew
4 Li or ' hi*" r 0/ "
J. U 4erkoffler `�/ Karen S nderkof /Or
____C.)
/-
K. R. Hildakbr.nd Jo t M. Ketr
Counsel for Plaintiff Counsel for Defendant
7
:r : i, i- ‘ 04.- „
'3OEC /8 pm 3.
Karl R.Hildabrand,Esquire 09
Lavery Faherty Patterson („�
2 5 Box 12St eet,Suite 304 P�"NSYW ANIA rY
Harrisburg,PA 17108-1245
(717)233-6633(telephone)
(717)233-7003(facsimile)
Atty No.PA30102
khildabrand @laverylaw.com
Attorney for Plaintiff
ANDREW J. UNDERKOFFLER, : IN THE COURT OF COMMON PLEAS
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
v. : NO. 09-1168-DV
KAREN J. UNDERKOFFLER, : CIVIL ACTION-LAW
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. Ground for divorce: Irretrievable breakdown under §3301(c) of the Divorce
Code.
2. Date and manner of service of the complaint: The Defendant, Karen J.
Underkoffler, was served by Certified Mail, Return Receipt Requested, on March
7, 2009. Acceptance of Service was filed on February 16, 2012.
3. Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce
Code: By Plaintiff: July 11, 2013 and Filed: July 11, 2013; By Defendant:
December 6, 2013 and Filed December 6, 2013.
4. Related Claims pending: None. All claims resolved by Marital Settlement
Agreement placed on the record with the Divorce Master, E. Robert Elicker,
Esquire, on December 2, 2013 and signed by the parties on December 2, 2013,
which will be incorporated but not merged into the Final Divorce Decree.
5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the
Prothonotary: July 11, 2013.
Date Defendant's Waiver of Notice in &3301(c) Divorce was filed with the
Prothonotary: December 6, 2013.
Respectfully submitted,
LAVERY FAHERTY PATTERSON
�
Date: /2-/ (3 ' (-> By � -
K . Hildabrand, Esquire
Attorney I.D. No. 30102
225 Market Street, Suite 304
P.O. Box 1245
Harrisburg, PA 17108-1245
(717) 233-6633 Telephone
(717) 233-7003 Facsimile
khildabrand@laverylaw.com
Attorney for Plaintiff
CERTIFICATE OF SERVICE
I, Karl R. Hildabrand, Esquire, of the law firm Lavery Faherty Patterson, hereby certify
that I served a true and exact copy of the foregoing Praecipe to Transmit Record by First Class
Mail, postage prepaid, this day of December, 2013, on the following:
John M. Kerr, Esquire
John Kerr Law, PC
5020 Ritter Road, Suite 104
Mechanicsburg, PA 17055
1 n
- _ �1✓ -
Karl . Hildabrand
• IN THE COURT OF COMMON PLEAS OF
• CUMBERLAND COUNTY, PENNSYLVANIA
ANDREW J. UNDERKOFFLER •
•
V. •
•
KAREN J. UNDERKOFFLER • NO. 09-1168
DIVORCE DECREE
AND NOW, _)e.44 Ac' s b , zo '3 , it is ordered and decreed that
ANDREW J. UNDERKOFFLER , plaintiff, and
KAREN J. UNDERKOFFLER , defendant, are divorced from the
bonds of matrimony.
Any existing spousal support order shall hereafter be deemed an order for
alimony pendente lite if any economic claims remain pending.
The court retains jurisdiction of any claims raised by the parties to this action
for which a final order has not yet been entered. Those claims are as follows: (If no
claims remain indicate "None.")
The Marital Settlement Agreement of the parties dated December 2, 2013 is
incorporated but not merged herein.
By the Court,
•
_
Atte- ' J.
Prothonotary
C eoptf rnai led 4o Ida brand
.o eew CON pro le -fo(MI k'Nrr
•
IAd`/eS