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Home My WebLink About09-5852 AMY J. SNYDER, V. : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA JEFFREY W. SNYDER, Defendant : CIVIL ACTION - LAW NO. 09 - 585*1 CIVIL TERM : IN DIVORCE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORAMTION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. 10 AMY J. SNYDER, V. Plaintiff JEFFREY W. SNYDER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09 - S 8 5 z CIVIL TERM : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Amy Jo Snyder, an adult individual, who resides at 813 Lee Court, Enola, Cumberland County, Pennsylvania 17025. 2. Defendant is Jeffrey Ward Snyder, an adult individual, who resides at 813 Lee Court, Enola, Cumberland County, Pennsylvania 17025. 3. Plaintiff and Defendant have both been.bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on November 8, 1996, in Hummelstown, Dauphin County, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 7. The marriage is irretrievably broken. 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 counseling. 9. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, Rominger & Associates Date: August 25, 2009 KwM. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court I.D. # 81924 Attorney for Plaintiff AMY J. SNYDER, V. Plaintiff JEFFREY W. SNYDER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 09 - CIVIL TERM IN DIVORCE VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unworn falsification to authorities. Date: r?5 - ` 0,? Amy . Sn , Plain i Of I-bE, ,,. 'TARY 2069 AUG 25 Pik 3.38 4-4-%.,95o pa ATI-f C V C2183 P3* oU9790 AMY J. SNYDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. . : CIVIL ACTION - LAW JEFFREY W. SNYDER, : NO. 09 - 5852 CIVIL TERM Defendant : IN DIVORCE MOTION TO FREEZE RETIRMENT BENEFITS AND NOW, comes Amy J. Snyder, by and through her counsel, Karl E. Rominger, Esquire and in support of her Motion avers as follows: 1. A divorce is pending at the above caption docket. 2. Defendant has threatened to cash out his retirement. 3. Undersigned counsel sent a letter requesting that a hold be placed on the retirement until the divorce is settled. Attached as Exhibit "A". 4. A response was received stating that an Order of Court is needed to place the retirement monies on hold. Attached as Exhibit B". WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order freezing the retirement account, so as to preserve the status quo. Date: !` aS Respectfully Submitted, Rominger & Associates Karl E ominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID #81924 Attorney for Plaintiff ROMINGER & ASSOCIATES Attorneys at Law Karl E. Rominger Michael O. Palermo, Jr. Lee E. Oesterling Vincent M. Monfredo November 23, 2009 VIA Facsimile Only (717) 783-9599 Pennsylvania State Employees Retirement System 30 North Third Street Harrisburg, Pennsylvania 17101 RE: Jeffrey W. Snyder SS #: 204-52-3762 To Whom It May Concern: This letter is to inform you that I represent Amy J. Snyder in regards to a divorce between herself and her husband Jeffrey W. Snyder and the same is docketed at 09-5852 in the Cumberland County Courthouse. It is my understanding that Mr. Snyder has a retirement account through the State. That said no monies should be released until the divorce is final. Thank you in advance for your time and attention to this matter. Should you have any questions, please do not hesitate to contact the office. E. Rominger, Esquire KER/tlp Enclosure cc: Amy J. Snyder Jeffrey W. Snyder, pro se 155 South Hanover Street, Carlisle, Pennsylvania 17013 • TeL• (717) 241-6070 • Fax: (717) 241-6878 wwwxomingerlaw.com ADVOCACY • ADVICE • ANSWERS f:??blt'Afr MEMORY TRANSMISSION REPORT TIME :11-23-'09 13:08 FAX NO.1 :7172416878 NAME :ROMINGER & ASSOC FILE NO. DATE TO DOCUMENT PAGES START TIME END TIME PAGES SENT STATUS 213 11.23 13:06 8 7839599 1 11.23 13:08 11.23 13:08 1 OK *** SUCCESSFUL TX NOTICE *** ROMINGER 8-c ASSOCIATES Attorneys at Law Karl E. Rtotnitager L.ee E_ Oesterlittg November 23, 2009 NIA F=asimila C31 (7171 783-9599 Pennsylvania State Employees Retirement System 30 North Third street Harrisburg, Pennsylvania 17101 lsE: Jefltey W- Snyder SS #: 204-52-3762 To Whom It May Concern: Michael 0. Palermo, jr. Vincent M. Monfredo This letter is to inform you that I represent Amy J. Snyder in regards to a divorce between herselrand her husband Jev*Wwy W. Snyder and the same is docketed at 09-5852 in the Cumberland County Courthouse. It in my understanding that Mr. Snyder has a retirement account through the State. That said no monies should be released until the divorce is final. Thank you in advance flaw your time and attention to this matter- Should you havo any questions, please do not hesitate to contact the ofSlluc?e. j ' E. Ii:ominger. Esquire Kim/tip Enclosure cc: Amy J. Snyder Jefttey W. Snyder. Pro sa 155 South Hanover Street, Carlisle. P?xmsylva?ata 17023 -Tel: (717-) 241-6070 • Pax: (717) 242-667$ www.roMit? p?erl aw.cpa? ADVOCACY ADVICE ANSWERS COMMONWEALTH OF PENNSYLVANIA STATE EMPLOYEES' RETIREMENT SYSTEM 30 North Third Street, Suite 150 Harrisburg, Pennsylvania 17101-1716 FACSIMILE COVER SHEET LEGAL DIVISION DATE: November 23, 2009 TOTAL NUMBER OF PAGES, INCLUDING COVER: 3 TO: Karl Rominger, Esquire COMPANY: Rominger & Associates FACSIMILE: 717-241-6878 TELEPHONE: 717-241-6070 FILE/MATTER: Snyder v. Snyder, Cumberland Co. No. 09-5852 FROM: Salvatore A. Darigo, Jr. FACSIMILE: (717) 787-5751 TELEPHONE: (717) 237-0231 COMMENTS: CONFIDENTIALITY NOTICE The information contained in the accompanying facsimile message is intended only for the personal and confidential use of the designated recipient named above. This message may be an Attorney-Client communication, and as such is privileged and confidential. If the reader of the accompanying message is not the intended recipient, you are hereby notified that you have received this document in error, and that any review, dissemination, distribution or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately by telephone so that we can arrange for the return of the original documents to us by mail or other means at no cost to you. Thank you. If you have any questions or have difficulty receiving this transmission, please contact SALLY TOTTON at (717) 237-0351. HARD COPY X WILL FOLLOW WILL NOT FOLLOW ???? It Fj ! r L . , L &Ak low y'es t .' y. LUMMUNWtALIM Uh NtNNSYLVANIA STATE EMPLOYEES' RETIREMENT SYSTEM LEGAL OFFICE 30 NORTH THIRD STREET, SUITE 160 HARRISBURG, PA 17101-1716 TELEPHONE: 717.763.7317 FAX: 717.787-6761 ww-meerextue.0a.U& November 23, 2009 'V'ia Facsimile to 717-241-6878 and First Class Mail Karl E. Rominger, Esquire 155 S. Hanover Street Carlisle, PA 17013 RE: Jeffrey W. Snyder . Your Client: Amy J. Snyder Dear Mr. Rominger: L SSE Kindly be advised that your fax of November 23 regarding the above-referenced member has been referred to me. Please direct any further communication regarding this matter to me at the address above. The Commonwealth of Pennsylvania State Employees' Retirement System is a governmentally-funded retirement plan for government employees r As such, SERS is not subject to the provisions of the Employee Retirement Income Security Act ("ERISA") or the Retirement Equity Act of 1984 regarding qualified domestic relations orders and spousal consent to benefit elections. Unlike ERISA plans, this means that in the absence of an appropriate court order, a member may take any action with regard to the member's retirement benefits without any notice or consent required from anyone, including the member's spouse. In the absence of a court order prohibiting the member from applying for retirement benefits, receiving payment from SERS, or changing beneficiaries, SERS cannot place a "hold" on an individual account for equitable distribution purposes. Furthermore, SERS cannot retain funds for future payment in furtherance of equitable distribution or assist with the recovery of benefits previously paid to a member. If it is believed that the member may take action prejudicial to your client's interest in a SERS benefit, you must petition the appropriate Court of Common Pleas for an order freezing the account. Any such order should explicitly state what actions the member is prohibited from taking with regard to his or her retirement benefits. Pursuant to the State Employees' Retirement Code, 71 Pa. C.S. §§5101-5956, a member's retirement elections are final, binding, and irrevocable once the member's effective date of retirement has passed. Therefore, should Mr. Snyder become a SERS annuitant before an order freezing his retirement benefits is entered, any Domestic Relations Order attaching his benefits cannot alter the terms and conditions of the benefit V L 6y?__ ??. 'l Karl Rominger, Esquire November 23, 2009 Page 2 options he previously elected. Should you wish to obtain information regarding Mr, Snyder's benefits, please note that SERS cannot release information regarding individual members and their benefits without an appropriate subpoena or an explicit authorization signed by the member. 1 will be pleased to provide you with information about SERS' requirements for approvable Domestic Relations Orders and a copy of SERS' Sample DRO form upon request. Of course, if you have any questions or wish to discuss this matter in further detail, please do not hesitate to contact me. Sincerely, Salvatore A. Darigo, Jr. Counsel State Employees' Retirement System cc; Addressee via First Class Mail Jane Kuklish, Harrisburg Regional Counseling Ctr. Jeffrey W. Snyder (pro se)(via mail only) AMY J. SNYDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW JEFFREY W. SNYDER, : NO. 09 - 5852 CIVIL TERM Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, certify that I this day served a copy of the within Motion to Freeze Retirement Benefits upon the following by depositing the same in the United States Mail, postage prepaid, by first class mail, addressed as follows: Jeffrey W. Snyder, pro se 813 Lee Court Enola, Pennsylvania 17025 Date: l lor'- Respectfully Submitted, Rominger & Associates K E. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID #81924 Attorney for Plaintiff "7 THE PP ';-VOTARY 20UH NOV 2a AM 9. 4 cu w . '? CY : IN THE COURT OF COMMON PLEAS OF Amy J. Snyder, PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. Jeffrey W. Snyder, DEFENDANT NO. 09-5852 DIVORCE DECREE AND NOW, 12--, it is ordered and decreed that Amy J. Snyder plaintiff, and Jeffrey W. Snyder defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None ourt, Thomas A. Placey mmon Pleas J J. D V? D D. vE?Li rothonota 6 6 /? ($t4- copy oa,lPd k?,dcot? ? mo,l?d P1; :e4? D, ss le r