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HomeMy WebLinkAbout09-7330Mark T. Silliker, Esquire 5922 Linglestown Road Harrisburg, PA 17112 (717) 671-1500 I.D. No. 33671 Attorney for Plaintiff NASRIN GOLPOUSHAN, Plaintiff V. CHARLES E. PAINTER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. oq - 7330 l.iivi l ?r?-m CIVIL ACTION -LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree in Divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. 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 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 ELEGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mis adelante en las siguientes pfiginas, debe tomar accibn dentro de los pr6ximos veinte (20) dias despu6s de la notificaci6n de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objeccionnes a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accibn como de describe anterionnente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacibn o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIER UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 NASRIN GOLPOUSHAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 7330 CA?"_.? /Q,44-1 CHARLES E. PAINTER, CIVIL ACTION -LAW Defendant : IN DIVORCE COMPLAINT IN DIVORCE 1. The Plaintiff is Nasrin Golpoushan, an adult individual currently residing at 47 South 41" Street, Harrisburg, Dauphin County, Pennsylvania. 17111. 2. The Defendant is Charles E. Painter, an adult individual currently residing at 3702 Swindon Lane, Mechanicsburg, Cumberland County, Pennsylvania. 17050. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania, for a period in excess of six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on March 21, 1997 in State College, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. This action is not collusive. 7. Plaintiff and Defendant separated on or about April 1, 2009. 8. 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. B. Section 3301(d) - The marriage of the parties is irretrievably broken. The parties separated on or about April 1, 2009. 9. Plaintiff has been advised of the availability of marriage counseling and understands that she may request that her spouse and she participate in counseling. 10. Plaintiff does not request that the Court require that her spouse and she participate in counseling prior to a divorce decree being handed down by this Court. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter a final decree in divorce. COUNTI EQUITABLE DISTRIBUTION 11. Paragraphs one through ten are incorporated herein by reference. 12. During their marriage, Plaintiff and Defendant have acquired various items of marital property, both real and personal, which are subject to equitable distribution under Sections 3501 et.sea. of the Divorce Code of 1980. WHEREFORE, Plaintiff respectfully requests this Honorable Court equitably distribute all marital property, both real and personal, owned by the parties. COUNT II ALIMONY 13. Paragraphs one through twelve are incorporated herein by reference. 14. Plaintiff lacks sufficient property to provide for her reasonable needs. 15. Plaintiff is unable to sufficiently support herself through appropriate employment. 16. Defendant has sufficient income and assets to provide continuing and indefinite support for the Plaintiff. WHEREFORE, Plaintiff requests this Honorable Court compel the Defendant to pay alimony to the Plaintiff. COUNT III ALIMONY PENDENTE LITE, COUNSEL FEES. COSTS AND EXPENSES 17. Paragraphs one through sixteen are incorporated herein by reference. 18. By reason of the institution of the action to the above term and number, Plaintiff will be and has been put to considerable expense in the preparation of her case, in the employment of counsel, and the payment of costs. 19. Plaintiff is without sufficient funds to support herself and to meet the costs and expenses of this litigation and is unable to appropriately maintain herself during the pendency of this action. 20. The Plaintiff's income is not sufficient to provide for her reasonable needs and pay her attorney's fees and the costs of this litigation. 21. The Defendant has adequate earnings to provide support for the Plaintiff and to pay her counsel fees, costs and expenses. WHEREFORE, Plaintiff respectfully requests this Honorable Court compel the Defendant to pay alimony pendente lite as well as pay the Plaintiff's counsel fees, costs and expenses. Date: is jog Respectfully submitted, THE LAW OFFICES OF SILLIKER & REINHOLD Mark T. Sill' er, Esquire 5922 Linglestown Road Harrisburg, PA 17112 (717) 671-1500 I.D. No. 33671 Attorney for Plaintiff AFFIDAVIT (9OiQou4 411 ereby certify that the aforegoing is true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. 4909 relating to unsworn falsifications to authorities. Dated: /0 - / 6 C7 I A-0 of nlu?uAOr 2M9 OCT 23 F" 12: 22 * SMS. 50 Pa AT" e a3ais e C, ? ? C' yo Marianne E. Rudebusch, Esquire 4711 Locust Lane Harrisburg, PA 17109 717-657-0632 Id. No. 63522 Attorney for Plaintiff NASRIN GOLPOUSHAN, Plaintiff V. CHARLES E. PAINTER, Defendant 3J 2 F 13 PN 2: r E?!NS `L VAti,IA : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09-7330 : CIVIL ACTION -LAW : IN DIVORCE DEFENDANT'S COMPLAINT FOR ALIMONY PENDENTE LITE UNDER SECTION 3702 OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Nasrin Golpoushan, by and through her attorney, Marianne E. Rudebusch, Esquire, and respectfully files the following Complaint for APL and in support thereof avers as follows: 1. The Plaintiff, Nasrin Golpoushan, is an adult individual who resides at 201 Lakeside Crossing, Mount Joy, Lancaster County, Pennsylvania, 17551. 2. The Defendant, Charles E. Painter, is an adult individual who resides at 3702 Swindon Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. A Complaint in Divorce was filed by Plaintiff on October 23, 2009. 4. Plaintiff does not have sufficient funds to support herself during the pendency of this action. 5. Defendant is well able to pay support to Plaintiff. 6. Plaintiff requests this Court to grant her alimony pendente lite. Respectfully Submitted, Marianne E. Rudebusch, Esquire 4711 Locust Lane Harrisburg, PA 17109 717-657-0632 Id. No. 63522 Dated: ,,1 /13 112- 2 A ATTORNEY VERIFICATION Undersigned counsel, Marianne E. Rudebusch, Esquire, hereby verifies and states that: 1. She is the attorney of record for Nasrin Golpoushan, Plaintiff. 2. She is authorized to make this verification on her behalf. 3. The facts set forth in the foregoing are true and correct to the best of her knowledge, information and belief. 4. This verification is made by counsel pursuant to Pa.R.C.P. Rule 1024(c). 5. She is aware that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Dated: /IS By: h4clly\ ? . ot"aLl -4. Marianne E. Rudebusch, Esquire Attorney for Plaintiff CERTIFICATE OF SERVICE AND NOW, this day of jL\DNLN, , 2012, I, Katherine A. Frey, Secretary to Marianne E. Rudebusch, Esquire, Attorney for the Plaintiff, hereby certify that a copy of the within document has been served, by depositing a copy of the same in the United States mail, first class, postage prepaid, delivery at Harrisburg, Pennsylvania, to the following addressee: Gary L. Kelley, Esquire 3117 Chestnut Street Camp Hill, PA 17011 By: 'k, 14-t A, nth rine A. Frey NASRIN GOLPOUSHAN, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA ~ c-) r 1 V. DOMESTIC RELATIONS SECTION -o:K M U-1 CHARLES E. PAINTER, PACSES NO. 246113057 w r--' Defendant/Respondent DOCKET NO. 09-7330 CIVIL "' C3c? v C-) SUPPORT MASTER'S REPORT AND RECOMMENDATION" Following a hearing held before the undersigned Support Master on February 1 0, 2012, the following report and recommendation are made: FINDINGS OF FACT 1. The Plaintiff is Nasrin Golpoushan, who resides at 201 Lakeside Crossing, Mount Joy, Lancaster County, Pennsylvania. 2. The Defendant is Charles E. Painter, who resides at 3702 Swindon Lane, Mechanicsburg, Pennsylvania. 3. The parties were married on March 21, 1997. 4. The parties separated in 2009 when the Plaintiff moved from the marital residence. 5. On October 23, 2009 the Plaintiff filed a complaint for divorce. 6. Said complaint contained a claim for alimony pendente lite. 7. On February 10, 2012 the Plaintiff requested that her claim for alimony pendente lite be heard by this Master in lieu of a claim for spousal support filed to 905 Support 2011. 8. There are no minor children of the marriage. 9. The Plaintiff is not gainfully employed. 10. The Plaintiff was last employed as a nanny in 1994 when she sustained injuries in a fall while working. 11. The Plaintiff receives Workers' Compensation benefits in the gross amount of $700.16 bi-weekly. 12. The Plaintiff continues to receive physical therapy, pain management, and psychiatric treatment related to her injury. 13. The Plaintiff has multiple convictions for theft by deception. 14. The Plaintiff resides in a home owned by her brother. 15. The Plaintiff is not paying rent at the present time but is paying for utilities on the home. 16. The Defendant is currently employed by Dauphin County. 17. The Defendant has gross bi-weekly pay of $1,693.21. 18. The Defendant has a mandatory retirement deduction of $84.66 bi-weekly. 19. The Defendant pays union dues of $32.55 bi-weekly. 20. The Defendant is retired from the City of Harrisburg where he was employed as a police officer. 21. The Defendant receives a monthly retirement payment of $2,688.76. 22. The parties filed a joint marital tax return for tax year 2010 but have not yet filed their 2011 tax return. 23. The Defendant resides in the marital residence. 24. The home is encumbered by a mortgage with a monthly payment of $2,044.41. 25. The Defendant is paying a bill consolidation home equity loan of $1,157.26 per month. 26. The Defendant provides health insurance coverage on the Plaintiff through his retirement at no cost. 27. The Defendant provides automobile insurance coverage on a vehicle in the possession of the Plaintiff. DISCUSSION Alimony pendente lite is defined as "alimony or maintenance during the pendency of a divorce proceeding so as to enable a dependent spouse to proceed with or defend against the action." Jayne v. Jayne, 663 A.2d 169, 176 (Pa. Super. 1995). The determination of whether to award a spouse alimony pendente lite has traditionally been a matter of sound discretion of the trial court. Litmans v. Litmans, 673 A.2d 382 (Pa. Super. 1996); Clouse v. Clouse, 50 Cumberland L.J. 167 (2001). Factors to consider in determining entitlement to an award of alimony pendente lite include the separate estate and income of the claimant, the ability of the other party to pay, and the character, situation and surroundings of the parties. Litmans v. Litmans, supra. Generally a spouse seeking alimony pendente lite who has sufficient assets to meet the needs of the pending litigation and who is equally situated with the other spouse to maintain or defend the action will not be awarded alimony pendente lite. Powers v. Powers, 615 A.2d 459 (Pa. 2 Super. 1992). Once entitlement to an award of alimony pendente lite is established, the calculation of the amount of the award is made pursuant to the support guidelines. Little v. Little, 47 Cumberland L.J. 131 (1998). The Plaintiff s income is limited to Workers' Compensation benefits. She has not been gainfully employed for the past 18 years. She does not have the present ability to meet her daily living expenses and to proceed with the divorce action without financial assistance. She is clearly not on equal footing with her husband in this regard. The Defendant has income from two sources, his current employment and a pension from prior employment. He has the ability to pay an award of alimony pendente lite. With gross monthly income of $1,517.00 and a tax filing status of married/separate, the Plaintiff has net monthly income for support purposes of $1,400.00.' With gross monthly income of $6,357.00 and a tax filing status of married/separate, and deducting his mandatory retirement contribution and his union dues from his gross income, the Defendant has net monthly income for support purposes of $4,691.00.2 With the net monthly incomes as set forth above and no minor children of the marriage, the Defendant's obligation for alimony pendente lite under the guidelines would be $1,317.00 per month.3 Several factors support a downward deviation in the award. The Defendant is paying a sizable mortgage on the marital residence, is paying towards marital debt, and is providing automobile insurance on a vehicle in the Plaintiffs possession. A recommendation is made that the Defendant's obligation for alimony pendente lite be set at $660.00 per month effective February 10, 2012. RECOMMENDATION A. The Defendant shall pay to the Pennsylvania State Collection and Disbursement Unit as alimony pendente lite the sum of $660.00 per month. B. The Defendant shall provide health insurance coverage for the benefit of his wife as is available to him through employment or other group coverage at a reasonable cost. C. The effective date of this order is February 10, 2012. See Exhibit "A" for tax deductions from gross income. See Exhibit "A" for tax deductions from gross income. See Exhibit "B" for the calculation. 3 Date Cc: Nasrin Golpoushan Charles E. Painter Marianne E. Rudebusch, Esquire For the Plaintiff Gary L. Kelley, Esquire For the Defendant DRO/rj s Michael R. Rundle Support Master 4 In the Court of Common Pleas of Cumberland County, Pennsylvania Tax Detail Report Plaintiff Name: Nasrin Golpoushan Defendant Name: Charles E. Painter Docket Number: 09-7330 Civil PACSES Case Number: 246113057 Other State ID Number: Tax Year: Current: 2012 Defendant Plaintiff 1. Tax Method _ 1040 ES 1040 ES 2. Fling Status Married Filing Separately Married Filing Separately 3. Who Claims the Exemptions Obligee 4. Number of Exemptions 1 1 5. Monthly Taxable Income $6,357.36 $1,517.00 6. Deductions Method Standard Standard 7. Deduction Amount $495.83 $495.83 8. Exemption Amount $316.67 $316.67 9. Income MINUS Deductions and Exem tions $5,544.86 $704.50 10. Tax on Income $1,055.38 $70.45 11. Child Tax Credit _ _ 12. Manual Adjustments to Taxes 13. Federal Income Taxes $1,055.38 $70.45 13 a. Earned Income Credit _ _ 14. State Income Taxes $112.63 $46.57 15. FICA Payments $207.27 _ 16. City Where Taxes Apply Select Select 17. Local Income Taxes $36.69 - _ TOTAL Taxes $1,411.97 $117.02 SupportCalc 2012 EXHIBIT "A" In the Court of Common Pleas of Cumberland County, Pennsylvania Spousal Support Calculation Rule 1910.16 (PACSES FORMAT) Plaintiff Name: Nasrin Golpoushan Defendant Name: Charles E. Painter Docket Number: 09-7330 Civil PACSES Case Number: 246113057 Other State ID Number: 1. Obligor's Monthly Net Income $4,691.49 2. Less All Other Support - 3. Less Obligee's Monthly Net Income $1,399.98 4. Difference $3,291.51 5. Less Child Support Obligation for Current Case Without Part II Substantial or Shared Custody Adjustment - 6. Difference _ $3,291.51 7. Multiply b 30% or 40% 40.00% 8. Income Available for Spousal Support $1,316.60 9. Adjustment for Other Expenses - 10. AMOUNT OF MONTHLY SPOUSAL SUPPORT OR APL $1,316.60 Pre ared b : mrr_ Date: 2/13/2012 SupportCak 2012 EXHIBIT "B" NASRIN GOLPOUSHAN, IN THE COURT OF COMMON PLEAS OF C? Plaintiff/Petitioner ,- CUMBERLAND COUNTY, PENNSYLVANIA mm r-q V. DOMESTIC RELATIONS SECTION :z::0 co Cn CHARLES I?. PAINTER, PACSES NO. 246113057 Defendant/Respondent DOCKET NO. 09-7330 CIVIL *© : INTERIM ORDER OF COURT ' ' AND NOW, this da y of February, 2012, upon consideration of the Support Ma ster s Report and Recommends ion, a copy of which is attached hereto as Exhibit "A", it is ordered and decreed as follows: A. The Defendant shall pay to the Pennsylvania State Collection and Disbursement Unit as alimony pendente lite the sum of $660.00 per month. B. The Defendant shall provide health insurance coverage for the benefit of his wife as is available to him through employment or other group coverage at a reasonable cost. C. The effective date of this order is February 10, 2012. IMPORTANT LEGAL NOTICE PARTIES MUST WITHIN SEVEN DAYS INFORM THE DOMESTIC RELATIONS SECTION AND THE OTHER PARTIES, IN WRITING, OF ANY MATERIAL CHANGE IN CIRCUMSTANCES RELEVANT TO THE LEVEL OF SUPPORT OR THE ADMINISTRATION OF THE SUPPORT ORDER, INCLUDING, BUT NOT LIMITED TO, LOSS OR CHANGE OF INCOME OR EMPLOYMENT AND CHANGE OF PERSONAL ADDRESS OR CHANGE OF ADDRESS OF ANY CHILD RECEIVING SUPPORT. A PARTY WHO WILLFULLY FAILS TO REPORT A MATERIAL CHANGE IN CIRCUMSTANCES MAY BE ADJUDGED IN CONTEMPT OF COURT, AND MAY BE FINED OR IMPRISONED. PENNSYLVANIA LAW PROVIDES THAT ALL SUPPORT ORDERS SHALL BE REVIEWED AT LEAST ONCE EVERY THREE (3) YEARS IF SUCH REVIEW IS REQUESTED BY ONE OF THE PARTIES. IF YOU WISH TO REQUEST A REVIEW AND ADJUSTMENT OF YOUR ORDER, YOU MUST DO THE FOLLOWING: CALL YOUR ATTORNEY. AN UNREPRESENTED PERSON WHO WANTS TO MODIFY (ADJUST) A SUPPORT ORDER SHOULD CONTACT THE DOMESTIC RELATIONS SECTION. ALL CHARGING ORDERS FOR SPOUSAL SUPPORT AND ALIMONY PENDENTE LITE, INCLUDING UNALLOCATED ORDERS FOR CHILD AND SPOUSAL SUPPORT OR CHILD SUPPORT AND ALIMONY PENDENTE LITE, SHALL TERMINATE UPON DEATH OF THE PAYEE. A MANDATORY INCOME ATTACHMENT WILL ISSUE UNLESS THE DEFENDANT IS NOT IN ARREARS IN PAYMENT IN AN AMOUNT EQUAL TO OR GREATER THAN ONE MONTH'S SUPPORT OBLIGATION AND (1) THE COURT FINDS THAT THERE IS GOOD CAUSE NOT TO REQUIRE IMMEDIATE INCOME WITHHOLDING; OR (2) A WRITTEN AGREEMENT IS REACHED BETWEEN THE PARTIES WHICH PROVIDES FOR AN ALTERNATE ARRANGEMENT. UNPAID ARREARAGE BALANCES MAY BE REPORTED TO CREDIT AGENCIES. ON AND AFTER THE DATE IT IS DUE, EACH UNPAID SUPPORT PAYMENT SHALL CONSTITUTE, BY OPERATION OF LAW, A JUDGMENT AGAINST YOU, AS WELL AS A LIEN AGAINST REAL PROPERTY. IT IS FURTHER ORDERED THAT, UPON PAYOR'S FAILURE TO COMPLY WITH THIS ORDER, PAYOR MAY BE ARRESTED AND BROUGHT BEFORE THE COURT FOR A CONTEMPT HEARING; PAYOR'S WAGES, SALARY, COMMISSIONS, AND/OR INCOME MAY BE ATTACHED IN ACCORDANCE WITH LAW. PAYOR IS RESPONSIBLE FOR COURT COSTS AND FEES. The parties are hereby advised that they may file written exceptions to the Support Master's Report and Recommendation within twenty (20) days of this order. Exceptions shall conform with the requirements of Rule 1910.12(f), Pa. R.C.P. If written exceptions are filed by any party, the other party may file exceptions within twenty (20) days of the date of service of the original exceptions. If no exceptions are filed within twenty (20) days of this interim order, this order shall then constitute a final order. Byt , Thom V1- Placey, J. Cc: Nasrin Golpoushan Charles E. Painter Marianne E. Rudebusch, Esquire For the Plaintiff Gary L. Kelley, Esquire For the Defendant DRO/rj s NASRIN GOLPOUSHAN, Plaintiff/Petitioner V. CHARLES E. PAINTER, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION PACSES NO. 246113057 DOCKET NO. 09-7330 CIVIL INDEX OF EXHIBITS Plaintiff's Exhibit No. 1 - Workers' Compensation benefits Defendant's Exhibit No. 1 Defendant's Exhibit No. 2 Defendant's Exhibit No. 3 Defendant's Exhibit No. 4 Income and Expense Statement Photocopy of check withdrawal Earning Statement Retirement benefit ;Z7, - -{ ,a Co -tam "; x> m o 0 O C-; -n 3 6 ..? cA -+? r z ? --?c3 `ha "immw pennsylvania DEPARTMENT OF LABOR & INDUSTRY STATE WORKERS' INSURANCE FUND THIS SECTION OF OUR CHECK IS A REMITTANCE ADVICE FOR YOUR RECORD KEEPING INFORMATION. PAYEE NAME: NASRIN GOLPOUSHAN 201 LAKESIDE CROSSING Mount Joy PA 17552 100 LACKAWANNA AVENUE I P.O. BOX 5100 SCRANTON, PA 18505-5100 570.963.4635 www.dli.state.pa.us DATE: 01/23/2012 CLAIMANT NAME: NASRIN GOLPOUSHAN CLAIM NUMBER: 01462016 INJURY DATE: 05/06/2004 CHECK NUMBER: 08401800 PLAINTIFF'S EXHIBIT 161,1 1 PURSUANT TO THE PROVISIONS OF THE WORKER'S COMPENSATION ACT THE FOLLOWING DISBURSEMENTS HAVE BEEN AUTHORIZED: CLAIMANT AMOUNT: LINE BENEFIT PAYMENT DATE NUMBER OF WEEKLY NUMBER TYPE FROM TO WEEKS COMP RATE 1 TP 01/13/2012 01/26/2012 2 437.60 2 ** TOTAL AMOUNT 700.16 -100.00 CHECK AMOUNT: 600.16 **A CREDIT HAS BEEN APPLIED FOR INDEMNITY PAID. AMOUNT DEDUCTED TO OTHER PAYEES: LINE PAYEE PAYMENT DATE TOTAL NUMBER NAME FROM TO AMOUNT 1 ANGINO & ROVNER PC 01/13/2012 01/26/2012 175.04 CHECK AMOUNT: 175.04 IF YOU HAVE ANY QUESTIONS CONTACT 'Tracy Brown' OF THE 'Harrisburg Office' AT (717) 787-3848. * SEE LAST PAGE FOR PAY CODE DESCRIPTIONS FOLD ON PERFORATION, THEN DETACH CAREFULLY CHECK NUMBER 08401800 CE = Claimant Expense Reimbursement DS = Disfig - Dismem FT = Fatal Benefits IN = Interest SC = Special Payment ST = Settlement TT = Temporary Total Benefit SS = Social Security SV = Severence UE = Unemployment PAGE NUMBER 003230 FB = Federal Black Lung PE = Penalty TP = Temporary Partial PN = Pension ** = Credit Temporary Partial Disability - IRE - SCHEDULED PAYMENT In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION 13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013 Phone: (717) 240-6225 DECEMBER 12, 2011 Fax: (717) 240-6248 NASRIN GOLPOUSHAN ) Docket Number: 00905 S 2011 Plaintiff ) vs. ) PACSES Case Number: 142112212 CHARLES E. PAINTER JR ) Defendant ) Other State ID Number: Please note: All correspondence must include the PACSES Case Number. Income Statement THIS FORM MUST BE FILLED OUT AND YOU MUST PROVIDE DOCUMENTS TO SUPPORT ALL AMOUNTS PROVIDED IN THIS INCOME STATEMENT (if you are self-employed or if you are salaried by a business of which you are owner in whole or in part, you must also fill out the Supplemental Income Statement which appears below.) INCOME STATEMENT OF (Name) (PACSES Number) I verify that the statements made in this Income Statement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: Plaintiff or Defendant INCOME Employer: Address Type of Payroll Number: Pay Period (weekly, biweekly, etc): Gross Pay per Pay Period $ Itemized Payroll Deductions-. Federal Withholding $ _ FICA ' U Local Wage Tax State Income Tax Mandatory Retirement Union Dues Health Insurance .?+. Other (specify) nkA11,Kj . 23. Net Pay per Pay Period: Service Tyoe M 'L? , ( PuC,, I, 3 DEFENDANT'S EXHIBIT Form IN-008 Worker ID 21302 Income Statement (Continued) Other Income: Week Interest $ Dividends Pension Distributions Annuity Social Security Rents Royalties Unemployment Comp. Workers Comp. Employer Fringe Benefits Other TOTAL INCOME PROPERTY OWNED Checking accounts Savings accounts Credit Union Stocks/bonds Real Estate Other INSURANCE Company Policy No. H Hospital Blue Cross Z AK o G ao ti Other CM-6- 0 S ?Y_n!r!10O- ?5 Medical 1 11 Blue Shield Other Health/Accident Disability Income Dental Vv44 G Other t k, V15 low ` So c Z P ' ' Vi 3 t ou I A 1 oS H=Husband; W=Wife; J=Joint; C=Child S PACSES Case Number: 142112212 Month Year (Fill in Appropriate Column) Ownership" Description Value < Hr W ? be" $ l ooy cu G? 10 VY Total $ Coverage' W C Form IN-008 Service ?-ype M Page 2 of 3 Worker ID 21302 / Income Statement (Continued) PACSES Case Number: 142112212 SUPPLEMENTAL INCOME STATEMENT (You only need to complete the below portion if you are self- employed or if you are salaried by a business of which you are owner in whole or in part) (a) This form is to be filled out by a person (check one): O (1) who operates a business or practices a profession, or O (2) who is a member of a partnership or joint venture, or O (3) who is a shareholder in and is salaried by a closed corporation or similar entity. (b) Attach to this statement a copy of the following documents relating to the partnership, joint venture, business, profession, corporation or similar entity: (1) the most recent Federal Income Tax Return, and (2) the most recent Profit and Loss Statement. (c) Name of business: Address and teleph (d) Nature of business (check one) O (1) partnership O (2) joint venture O (3) profession 19l (4) closed corporation O (5) other (e) Name of accountant, controller or other person in tcharge of financial records: W yIN- V&\_.h -1 Q0 i.,awl1, 1 _1..l? 'W\U.VA C P,- (f) Annual income from business: (1) How often is income received? (1 PSG y (?(` (2) Gross income per pay period: -?- (3) Net income per pay period: (4) Specific deductions, if any: Form IN-008 Service Type M Page 3 of 3 Worker ID 21302 (Name) (Pacses Number) I verify that the statements made in this Expense Statement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unswom falsification to authorities. Date: Plaintiff or Defendant Instructions: Guidelines Expense Statement - This form should only be completed when: 1) You are requesting an adjustment to the amount of support pursuant to Rule 1910.16-5 because of unusual needs and unusual fixed obligations, other support obligations, medical expenses not covered by insurance, or any other relevant factors, or 2) You are requesting that the other party share in the following expenses pursuant to Rule 1910.16-6: child care expenses, health insurance premiums, unreimbursed medical expenses, private school tuition, summer camp, or other needs, or mortgage payment. You must provide documents to support all amounts provided in this Expense Statement Weekly on y ear y 11 (Fill in Appropriate Column) Mortgage (including real estate taxes and homeowner's insurance) or Rent $ $ (j 1.. $ Health Insurance Premiums Unreimbursed Medical Expenses: n/ /q Doctor Dentist 'V Orthodontist Hospital ?N Medicine Special Needs (glasses, braces, orthopedic devices, therapy) Service Type M Form IN-008 Worker ID 21302 r Guidelines Expense Statement (Continued) PACSES Case Number: 142112212 Weekl Monthl Yearly d C are Chil Private School Parochial school Loans/Debts Su ort of Other De endents: Other child su ort Alimony payments Other: S eci Om-'r egos Q*e Q-1 4-A? Total $ 3 ?,00 $ V Gri P4 1, 5 kw.o)-v.6\, CPjA L-4?? C-40I 0?ovqs) N#M W ve 4v pP? 1,0\00 X) I -I CC& II 1 I J.? VU ),I. DU So. o., 1Ci 3, 1W ? 1,4 ,oi, ST ol? -11 3,-1.00 Service Type M Page 2 of 2 Form IN-008 Worker ID 21302 Print Images Page 1 of 1 Routing ; Muence # Paid Date Amount Account Serial -cApw a Souse 54059509 8622697349 06162008 $100000.00 05079900000893 1402073076 00900976 WACHOVIA OFFICIAL CHECK CREDIT OVOMM9 prdaw. M ym iwW, da copy in w. 0"m forward 14 2 i)7 3 7 6 wWW &W 0 to WedwAa *Wxid MW d pndWe. 91115(tU WACHOlVIA Pa,.TOThe NA4klN t;01 P0U`.>fA'>R?DiT COPY 7 !J:', L ', ( Q grder 01 v Z 9 •(1Nc li'JNU10-D THGU=ANU DOL'._AR`', AND 00 CFNIS P Dollars `J[+? wdow arik Nrgr,r Meocrron roaSn7r; i,(i .('uu:?rHa j` NONMBLE Ch&iT RpnNtar Sipnawrb M0,020?30?6v' 1:51605-95091:S079900000893"' L?r'OO10000000.,' 0312007304 {A IM1 9VC752 1117T 4ftIU, P0. A61b208E 45PK Endoraemant a GUARANTEED DEFENDANT'S WELLS FARGO BANK, N.A. Camp FB AU 679A0 EXHIBIT BY '7, > 3 7- 3 7 j https:Hoibservice°s. wellsfargo.com/OIB/Printlmage.i,,n ' LULATIUN NAME FED. EX. STATE EX. NAY tNUINU L;HtLK NU. 261 CHARLES E PAINTER JR 6339 M-003 M-000 12/25/11 1400941 EARNINGS DEDUCTIONS THIS IS A STATEMENT OF YOUR EARNINGS, TYPE HOURS AMOUNT TYPE AMOUNT Y.T.D. TYPE AMOUNT Y.T.D. DEDUCTIONS AND LEAVE. DETACH AND RETAIN FOR YOUR RECORDS. REG 58.50 1,099.22 PEN 84.66 2,504.08 EARNINGS 1,693.21 OTl 4.00 112.74 SUP 48.80 1,268.80 DEDUCTIONS 1,693.21 iSl. 11.50 11.50 DEP 0.48 12.48 NET PAY VAC 16.00 300.64 FIC 69.05 2,051.12 PER 9.00 169.11 MED 23 84 708 10 V.T.D. GROSS EARNINGS 50,080.39 F T . 91.58 7 . 3 244.24 V.T.D. TAXABLE EARNINGS 46,330.91 SIT 5 1.98 , 1,537.54 Y.T.D. F.I.C.A. EARNINGS 48, 834.99 L60 27.09 801.30 ACCUMULATIONS PUC 1.35 40.00 PER HRS 0.0010- LST 2.00 52.00 VAC HRS 176.2699 HAR 1,292.38 7,536.14 SIC HRS 293.0407 UDT 390.60 HAR 28,634.23 LE I, 693.21 48,780.631 TOTAL 99,00 1,693.21 COUNTY OF DAUPHIN County of Dauphin Harrisburg, PA 17108-1295 ONE THOUSAND TWO HUNDRED NINETY TWO DOLLARS AND 38 GENTS CHARLES E PAINTER Jig CHECK DATE _ CHECK W. 12/30/11 1400941 AMOUNT $ 1,292.38 P.O. Box 1295 M>i<T BANK 717 717-257-1562 Fax 'M E -780-6230 Phone DIRECT DEPOSIT 3702 SWINDON LANE ° MECHANICSBURG, PA 11050 DIRECT DEPOSIT STATEMENT OF " NOT NEGOTIABLE DEFENDANT'S EXHIBIT allulla ?) C GmW' INSTITUTIONAL SERVICE CENTER 600 63614431 P.O. BOAC 4623 BUFFALO, NY 14240 Addrbss ctv!jt if your address has charpd, complete and sign the form (below), detach this portion and mail to the address at the top of this stub. Please check the Temp Chatge box if this is a temporary PAYEE'S SIGNATURE DATE SIGNED NEW STREET (MAILING) ADDRESS Temp Qsatge y. STATE A ZIP CODfi law a Payee 4966 CHARLES P,?INTFR .TR - REMOVE DOCUMENT ALONG T41 OgffR i v v n_ y do$ DEFENDANT'S EXHIBIT `t q Safi Marianne E. Rudebusch, Esquire 4711 Locust Lane Harrisburg, PA 17109 717-657-0632 Id. No. 63522 Attorney for Plaintiff NASRIN GOLPOUSHAN, : IN THE COURT'OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 09-7330 CHARLES E. PAINTER, : CIVIL ACTION -LAW Defendant : IN DIVORCE DEFENDANT'S COMPLAINT FOR ALIMONY PENDENTE LITE UNDER SECTION 3702 OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Nasrin Golpoushan, by and through her attorney, Marianne E. Rudebusch, Esquire, and respectfully files the following Complaint for APL and in support thereof avers as follows: 1. The Plaintiff, Nasrin Golpoushan, is an adult individual who resides at 201 Lakeside Crossing, Mount Joy, Lancaster County, Pennsylvania, 17551. 2. The Defendant, Charles E. Painter, is an adult individual who resides at 3702 Swindon Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. A Complaint in Divorce was filed by Plaintiff on October 23, 2009. 4. Plaintiff does not have sufficient funds to support herself during the pendency of this action. 5. Defendant is well able to pay support to Plaintiff. 6. Plaintiff requests this Court to grant her alimony pendente lite. Respectfully Submitted, Marianne E. Rudebusch, Esquire 4711 Locust Lane Harrisburg, PA 17109 717-657-0632 Id. No. 63522 Dated: /11-5 112- ATTORNEY VERIFICATION Undersigned counsel, Marianne E. Rudebusch, Esquire, hereby verifies and states that: 1. She is the attorney of record for Nasrin Golpoushan, Plaintiff. 2. She is authorized to make this verification on her behalf. 3. The facts set forth in the foregoing are true and correct to the best of her knowledge, information and belief. 4. This verification is made by counsel pursuant to Pa.R.C.P. Rule 1024(c). 5. She is aware that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Dated: ? I Marianne E. Rudebusch, Esquire Attorney for Plaintiff CERTIFICATE OF SERVICE AND NOW, this day of , 2012, I, Katherine A. Frey, Secretary to Marianne E. Rudebusch, Esquire, Attorney for the Plaintiff, hereby certify that a copy of the within document has been served, by depositing a copy of the same in the United States mail, first class, postage prepaid, delivery at Harrisburg, Pennsylvania, to the following addressee: Gary L. Kelley, Esquire 3117 Chestnut Street Camp Hill, PA 17011 By: nth rine A. Frey V INCOME WITHHOLDING FOR SUPPORT Q ORIGINAL INCOME WITHHOLDING ORDER/NOTICE FOR SUPPORT (IWO) 26113057 O AMENDED IWO 09-7330 CIVIL O ONE-TIMEORDER/NOTICE FOR LUMP SUM PAYMENT O TERMINATION OF IWO Date: 02/16/12 ? Child Support Enforcement (CSE) Agency ® Court ? Attorney ? Private Individual/Entity (Check One) NOTE: This IWO must be regular on its face. Under certain circumstances you must reject this IWO and return it to the sender (see IWO instructions http://www acf hhs gov/programs/cse/newhirelemployer/publication/publication htm - forms). If you receive this document from someone other than a State or Tribal CSE agency or a Court, a copy of the underlying order must be attached. water i npet i erniory t;ommonweann or t-ennsyivama remittance ioennner tmcwoe wipayment): waivuuucf t City/County/Dist.fTribe CUMBERLAND Order Identifier: (See Addendum for order/docket Informaiton) Private Individual/Entity CSE Agency Case Identifier: (See Addendum for case summary) DAUPHIN CNTY OFF OF PERSONNEL C/O ATTN: PAYROLL PO BOX 1295 HARRISBURG PA 17108-1295 RE: PAINTER, CHARLES E. JR Employee/Obligor's Name (Last, First, Middle) 210-54-4987 Employee/Obligor's Social Security Number (See Addendum for plaintiff names associated with cases on attachment) Custodial Party/Obligee's Name (Last, First, Middle) Employer/Income Withholder's FEIN 236003043 Child(ren)'s Name(s) (Last, First, Middle) Child(ren)'s Birth Date(s) NOTE: This IWO must be regular on its face. Under certain circumstances you must reject this IWO and return it to the sender (see IWO instructions httn://www.acf.hhs.oov/programs/cse/newhire! employer/Publication/publication.htm - form . If you receive this document from someone other than a State or Tribal CSE agency or a Court, a copy of the underlying order must be attached. 2360030430 See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This document is based on the support or withholding order from CUMBERLAND County, Commonwealth of Pennsylvania (State/Tribe). You are required by law to deduct these amounts from the employee/ obligor's income until further notice. Z?g h ' hI 'Id $ 0.00 per mont In curren t to support o 0 00 A 4= + " $ . rrears 12 weeks or greate per month in past-due child support - : y es O no $ 0.00 per month in current cash medical support lr- nr- N $ 0.00 per month in past-due cash medical support $ 660.00 per month in current spousal support $ 0.00 per month in past-due spousal support $ 0.00 per month in other (must specify) zy'i' `' W for a Total Amount to Withhold of $ 660.00 per month. _ Ln -0 AMOUNTS TO WITHHOLD: You do not have to vary your pay cycle to be in compliance with the Order Information. If your pay cycle does not match the ordered payment cycle, withhold one of the following amount: $ 1- c; J -11 per weekly pay period. $ 330.00 per semimonthly pay period (twice a month) $ 304, 62per biweekly pay period (every two weeks) $ 660.00 per monthly pay period. $ Lump Sum Payment: Do not stop any existing IWO unless you receive a termination order. REMITTANCE INFORMATION: If the employee/obligor's principal place of employment is CUMBERLAND County, Commonwealth of Pennsylvania (State/Tribe), you must begin withholding no later than the first pay period that occurs ten (10) working days after the date of this Order/Notice. Send payment within seven 7 working days of the pay date. If you cannot withhold the full amount of support for any or all orders for this employee/obligor, withhold up to 55% of disposable income for all orders. If the employee/obligor's principal place of employment is not CUMBERLAND County, Commonwealth of Pennsylvania (State/Tribe), obtain withholding limitations, time requirements, and any allowable employer fees at http://www.acf.hhs.gov/programs/cse/newhire/employer/contacts/ contact_map.htm for the employee/obligor's principal place of employment. Document Tracking Identifier OMB No.: 0970-0154 Form EN-028 01/12 Service Type M Worker ID $IATT ? Return to Sender [Completed by Employer/Income Withholder]. Payment must be directed to an SDU in accordance with 42 USC §666(b)(5) and (b)(6) or Tribal Payee (see Payments to SDU below). If payment is not directed to an SDU/Tribal Payee or this IWO is not regular on its face, you must check this box and return the IWO to the sender Signature of Judge/Issuing Official (if required by State or Tribal law): Print Name of Judge/Issuing Official: Placey, Ju e Title of Judge/Issuing Official: Date of Signature: If the employee/obligor works in a State or for a Tribe that is different from the State or Tribe that issued this order, a copy of this I WO must be provided to the employee/obligor. ? If checked, the employer/income withholder must provide a copy of this form to the employee/obligor. ADDITIONAL INFORMATION FOR EMPLOYERS/INCOME WITHHOLDERS Pennsylvania law (23 PA C.S. § 4374(b)) requires remittance by an electronic payment method if an employer is ordered to withhold income from more than one employee and employs 15 or more persons, or if an employer has a history of two or more returned checks due to nonsufficient funds. Please call the Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. PA FIPS CODE 42 000 00 Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER /D (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. State-specific contact and withholding information can be found on the Federal Employer Services website located at: hfto•//www acf hhs oov/programs/cse/newhire/employer/contacts/contacLmao.htm Priority: Withholding for support has priority over any other legal process under State law against the same income (USC 42 §666(bx7)). If a Federal tax levy is in effect, please notify the sender. Combining Payments: When remitting payments to an SDU or Tribal CSE agency, you may combine withheld amounts from more than one employee/obligor's income in a single payment. You must, however, separately identify each employee/ obligor's portion of the payment. Payments To SDU: You must send child support payments payable by income withholding to the appropriate SDU or to a Tribal CSE agency. If this IWO instructs you to send a payment to an entity other than an SDU (e.g., payable to the custodial party, court, or attorney), you must check the box above and return this notice to the sender. Exception: If this IWO was sent by a Court, Attorney, or Private Individual/Entity and the initial order was entered before January 1, 1994 or the order was issued by a Tribal CSE agency, you must follow the "Remit payment to" instructions on this form. Reporting the Pay Date: You must report the pay date when sending the payment. The pay date is the date on which the amount was withheld from the employee/obligor's wages. You must comply with the law of the State (or Tribal law if applicable) of the employee/obligor's principal place of employment regarding time periods within which you must implement the withholding and'forward the support payments. Multiple IWOs: If there is more than one IWO against this employee/obligor and you are unable to fully honor all IWOs due to Federal, State, or Tribal withholding limits, you must honor all IWOs to the greatest extent possible, giving priority to current support before payment of any past-due support. Follow the State or Tribal law/procedure of the employee/obligor's principal place of employment to determine the appropriate allocation method. Lump Sum Payments: You may be required to notify a State or Tribal CSE agency of upcoming lump sum payments to this employee/obligor such as bonuses, commissions, or severance pay. Contact the sender to determine if you are required to report and/or withhold lump sum payments. Liability: If you have any doubts about the validity of this IWO, contact the sender. If you fail to withhold income from the employee/obligor's income as the IWO directs, you are liable for both the accumulated amount you should have withheld and any penalties set by State or Tribal law/procedure. Anti-discrimination: You are subject to a fine determined under State or Tribal law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against an employee/obligor because of this IWO. OMB Expiration Date - 05/31/2014. The OMB Expiration Date has no bearing on the termination date of the IWO; it identifies the version of the form currently in use. Form EN-028 01/12 Employer's Name: DAUPHIN CNTY OFF OF PERSONNEL Employer FEIN: 236003043 Employee/Obligor's Name: PAINTER, CHARLES E. JR 9679000272 CSE Agency Case Identifier: (See Addendum for case summary) Order Identifier: (See Addendum for order/docket information) Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (CCPA) (15 U.S.C. 1673(b)); or 2) the amounts allowed by the State or Tribe of the employee/obligor's principal place of employment (see REMITTANCE INFORMATION). Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; statutory pension contributions; and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is supporting another family and 60% of the disposable income if the obligor is not supporting another family. However, those limits increase 5% - to 55% and 65% - if the arrears are greater than 12 weeks. If permitted by the State or Tribe, you may deduct a fee for administrative costs. The combined support amount and fee may not exceed the limit indicated in this section. For Tribal orders, you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employers/income withholders who receive a State IWO, you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which the employer/income withholder is located or the maximum amount permitted under section 303(d) of the CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State or Tribal law, you may need to also consider the amounts paid for health care premiums in determining disposable income and applying appropriate withholding limits. Arrears greater than 12 weeks? If the Order Information does not indicate that the arrears are greater than 12 weeks, then the Employer should calculate the CCPA limit using the lower percentage. Additional Information: NOTIFICATION OF EMPLOYMENT TERMINATION OR INCOME STATUS: If this employee/obligor never worked for you or you no longer withholding income for this employee/obligor, an employer must promptly notify the CSE agency and/or the sender by returning this form to the address listed in the Contact Information below: 2360030430 Q This person has never worked for this employer nor received periodic income. O This person no longer works for this employer nor receives periodic income. Please provide the following information for the employee/obligor: Termination date: Last known address: Final Payment Date To SDU/Tribal Payee: New Employer's Name: New Employer's Address: Last known phone number: Final Payment Amount: CONTACT INFORMATION: To Employer/Income Withholder: If you have any questions, contact WAGE ATTACHMENT UNIT (Issuer name) by phone at (717) 240-6225, by fax at (717) 240-6248, by email or website at: www.childsupport.state.pa.us. Send termination/income status notice and other correspondence to: DOMESTIC RELATIONS SECTION, 13 N. HANOVER ST. P.O. BOX 320, CARLISLE. PA. 17013 (Issuer address). To Employee/Obligor: If the employee/obligor has questions, contact WAGE ATTACHMENT UNIT (Issuer name) by phone at (717) 240-6225, by fax at (717) 240-6248, by email or website at www.childsupport.state.pa.us. IMPORTANT: The person completing this form is advised that the information may be shared with the employee/obligor. Service Type M OMB No.: 0970-0154 Page 3 of 3 Form EN-028 01/12 Worker ID $IATT C7 ADDENDUM c a Z ---d Summary of Cases on Attachment r-nW -Tr , Defendant/Obligor: PAINTER, CHARLES E. JR CO PACSES Case Number 246113057 Plaintiff Name NASRIN GOLPOUSHAN Docket Attachment Amount 09-7330 CIVIL $ 660.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACKS Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB cz? PACSES Case Number rC Plaintiff Name :z >cz_- Docket Attachm ent Amount $ 0.00 r'0 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment A ount $ 0.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Doc t Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Addendum Form EN-028 01/12 f { NASRIN GOLPOUSHAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA VS. CIVIL ACTION-DIVORCE NO. 09-7338 CIVIL TERM CHARLES E. PAINTER, : IN DIVORCE Defendant PACSES CASE: 246113857 rn Do ORDER OF COURT c� a W C:�J o -� cn AND NOW,this 14th day of March, 2013, a petition has been filed against you, Charles E. Painter, to modify an existing Alimony Pendente Lite Order. You are ordered to appear in person at the Domestic Relations Section, 13 North Hanover Street, Carlisle, Pennsylvania, on Aord 3,2013 at 1:30 P.M. for a conference and to remain until dismissed by the Court. If you fail to appear as provided in this Order, an Order of Court may be entered against you. You are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2°s as filed (2) your pay stubs for the preceding six(6)months (3) the Income and Expense Statement attached to this order, completed as required by the Rule 910.11. (4) verification of child care expenses (5) proof of medical coverage which you may have,or may have available to you 1 CC361 The appropriate court officer may modify or terminate the existing order in any manner based upon the evidence presented. BY THE COUR Date of Order: March 14, 2013 Thomas A. Placey, Judge YOU HAVE THE RIGHT TO A LAWYER,WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 ST. CARLISLE, PENNSYLVANIA 17013 (717)249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of 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 at: 717-240-6225. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference. NASRIN GOLPOUSHAN, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY,PENNSYLVANIA VS. CIVIL ACTION -DIVORCE NO. 09-7330 CIVIL TERM C= CHARLES E. PAINTER, IN DIVORCE Defendant/Respondent PACSES CASE: 246113057 M 3 ORDER OF COURT DO AND NOW,this 4th day of April, 2013, based upon the Court's determination that the Petitioner's monthly net income/earning capacity is $ 1,901.48 and the Respondent's monthly net income/earning capacity is $ 5,518.58, it is hereby ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit Seven Hundred Forty-five and 00/100 Dollars ($ 745.00)'per month payable biweekly as follows: $ 724.00 per month for Alimony Pendente Lite and $ 21.00 per month on arrears. The first payment due in accordance with the Respondent's pay schedule. The effective date of the order is March 6, 2013. Arrears set at $ 842.00 as of April 4, 2013. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C.S.§ 3703. Further, if the Court finds, after hearing,that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and, at its discretion, make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money is to be turned over by the PA SCDU for distribution and disbursement in accordance with Rule 1910.17(d). Payments must be made by check or money order. All checks and money orders must be made payable to PA SCDU and mailed to: PA SCDU P.O. Box 69110 Harrisburg, PA 17106-9110 Payments must include the Respondent's name with their PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. cc360 The monthly support obligation includes cash medical support in the amount of$250 annually for unreimbursed medical expenses incurred for the spouse. Unreimbursed medical expenses of the spouse that exceed $250 annually shall be allocated between the parties. The party seeking allocation of unreimbursed medical expenses must provide documentation of expenses to the other party no later than March 31"of the year following the calendar year in which the final medical bill to be allocated was received. The unreimbursed medical expenses are to be paid as follows: 0 % by Respondent and 100 %by Petitioner. [X] Respondent [] Petitioner [] Neither party to provide medical insurance coverage. Within thirty(30)days after the entry of this order,the [] Petitioner [X] Respondent shall submit written proof that medical insurance coverage has been obtained or that application for coverage has been made. Proof of coverage shall consist, at a minimum, of. 1)the name of the health care coverage provider(s); 2)any applicable identification numbers; 3)any cards evidencing coverage; 4)the address to which claims should be made; 5)a description of any restrictions on usage, such as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage contract; 7)a description of all deductibles and co-payments; and 8) five copies of any claim forms. It is further Ordered that, upon payor's failure to comply with this order,payor may be arrested and brought before the Court for a Contempt hearing; payor's wages, salary, commissions, and/or income may be attached in accordance with law; this Order will be increased without further hearing by 0%a month until all arrearages are paid in full. Payor is responsible for court costs and fees. Other conditions: Pursuant to the Support Masters' order of February 14, 2012 a downward deviation is followed due to the Respondent paying a sizable mortgage on the marital residence and paying towards marital debt. This Order shall become final twenty(20) after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Office of the Prothonotary for a hearing de novo before the Court. Mailed copies on: APR 0 9 2013 Thoma's' A Placey, J. xc:Petitioner Respondent Heather E.Verchick,Esq. Gary L.Kelley,Esq. DRO: R.J. Shadday INCOME WITHHOLDING FOR SUPPORT 0 ORIGINAL INCOME WITHHOLDING ORDERMOTICE FOR SUPPORT(two) C)q -7330 C ©' )NJ) AMENDED two 0 ONE-TIMEORDERMOTICE FOR LUMP SUM PAYMENT 0 TERMINATION OF IWO Date: 04/04113 ❑ Child Support Enforcement(CSE)Agency court ❑ Attorney ❑ Private Individual/Entity(Check One) NOTE:This IWO mUSttoqregular omits-face.Under certain circumstances you must reject this IWO and return it to the sender(see IWO instructions hftp://wwW.acfhh§.go)�#RMgrams/cse/newhiretemployer/publicaUoftublication.htm-forms).If you receive this document from someone other than a State or THbal CSE agency or a Court,a copy of the underlying order must be attached. stateiTriberrerrttory commonwealth of Pennsylvania Remittance Identifier(include w/payment): 9679000272 City/County/Dist./Tribe CUMBERLAND Order Identifier (See Addendum for orderldockot Informalton) Private Individual/Entity CSE Agency Case Identifier: (See Addendum for case summary) DAUPHIN CNTY OFF OF PERSONNEL RE: PAINTER,CHARLES E.JR C/O ATTN: PAYROLL Employee/Obligoes Name(Last,First,Middle) PO BOX 1295 210-54-4987 HARRISBURG PA 17108-1295 Employee/Obligor's Social Security Number (Soo Addendum for plaintiff names associated with cases on attachment) Custodial Party/Obligee's Name(Last,First, Middle) Employer/income Withholder's FEIN 236003043 NOTE:This IWO must be regular on its face. Under certain circumstances you must reject Child(ren)'s Name(s)(Last,First,Middle) Child(ren)'s Birth Date(s) this IWO and return It to the sender(see IWO instructions hitm acfhhs.gQyL=gramstcsstnewhireI ema1V� r ujkaJjgnLWbjicatlion.htrn-fmm$.if you receive this document from someone other than a State or Tribal CSE agency or a Court,a copy of the underlying order must be attached, 2360030430 See Addendum for dependent names and birth dates associated with cases on attachment.(--) ORDER INFORMATION. This document is based on the support or withholding order from L tID Ce inh.t. Commonwealth of Pennsylvania (State/Tribe). You are required by law to deduct these amounts t V— mbPI0ie/ obligor's income until further notice, $ 0.00 Per month in current child support $ 0.00 per month.in past-due child support-Arrears 12 weeks or greater? ic $ 0.00 per month in current cash medical support $ 0.00 per month in past-due cash medical support yA Cz r%.) $ 724.00 per month in current spousal support $ 21.00 per month in past-due spousal support $ uo per month in other(must specify) for a Total Amount to Withhold of$ 745.00 per month. AMOUNTS TO WITHHOLD: You do not have to vary your pay cycle to be in compliance with the Order Information. If your pay cycle does not match the ordered payment cycle,withhold one of the following amount: $ 171.93 per weekly pay period. $ 372.50 per semimonthly pay period(twice a month) $ per biweekly pay period(every two weeks) $ 745.00 per monthly pay period. $ Lump Sum Payment: Do not stop any existing IWO unless you receive a termination order. REMITTANCE INFORMATION. If the employee/obligor's principal place of employment is within the Commonwealth of Pennsylvania (State[Tribe), you must begin withholding no later than the first pay period that occurs ten(10) working days after the date of this Order/Notice. Send payment within seven(7)working days of the pay date. If you cannot withhold the full amount of support for any or all orders for this employee/obligor, withhold up to 55% of disposable income for all orders. If the employee/obligor's principal place of employment is not within the Commonwealth of Pennsylvania (State/Tribe),the employer can obtain withholding limitations, time requirements, and any allowable employer fees at hftp://www.acfhhsoov/12roarams/Cse/no-w-hirelemplQyer/contacts-/contagt-mal2. htm for the employee/obligor's principal place of employment. Document Tracking Identifier OMS No,:0970-0154 Form EN-028 06/12 Service Type M Worker ID$IATT ❑ Return to Winder lCompleted by P.., ' .. ; .v rj. Payr nt must be directed to an SDU in accordance with 42 USC b 5 and b`6 or l real lea ee sae manta# SC3U below). If 6( }{ ) ( �f.) ( y payment is not directed to an SDU/Tribal Payee or this IWO is not regular on its'face, you must check this box and return the IWO to the sender. Signature of Ju4ge/I wing OMeW(if required by State-or Tribal taw). Print Name of Juicigetlesuft Official: Title of Judge/issuing Coal: Date of Signature: If the employeefabiigor works in a State or for a Tribe that is dint from the State or T be that issued this on er, a copy of thin MO must be provided-16 the employod/bb4por. ❑ If checked,the employerlincome withholder must provide>a copy of this form to the am,ployee/obligor.am, ADINTIOWINFORMATION FOR 01111111PLOYERSAKOM W1'1;SLR Pennsylvania law(33 PA C.S.§4374(b))requires remittance by an if an amploayer is ordiored to witlglhold bloomisr 1rom morwftwone ems and employs 15 or more pwoons,or if an employer er h a-history of two or more robvniodthodlits dus to nonst0fidont€cinch, Please,caft the Pennsylvania Colt ons and Disbursement Unit(PA SCOU)Employer Comer Service at 147174764Wi for instructions.PA ffPS:C040 43. QO: Make n0dormo P "W,PEA SCDU Send yak o: Pence# tia"S IDU, P.O. SwOMM.,Hapiebirg, Pa 171,e$4412 IN ADDITION,PAYAWNTS MUST IMCAUDE THE M S AMV Tfff PACSES W{s twm as them br'ar tfldr}©t s SEND a4iiit Ai AWL. State-specific contact and withholding information can be found on the Federal Employer Services welite located at: Priority:Withholding for support has priority over any ether legal process under State law against the same income(USC 42 § (bx7)). If a Federal tax levy*#n affect Cow Pft�rr :When remitting payments tea an SQU or Tel CSF; etY,You may carnbr w'. ,om more therlr one oes Income li s sl pst t.You rttuetx h4�r srx s i Bpi . obligor's paortkn of"'payment. Payments To SOU: You must send child support payments payable by incxtme,w,0ft1ding;to the rq . SDU or to a 11 Tftal CSE a °ry. If IWO ins you to a,�rr�llt�t o art: Ott party,court,or attorney),you must the box fw�' t b a Court,Attome ,or Private Individual/Entity Y Y and the issued by a Tribal CSE agency,you must follow the Reporting the Pay Dam: You must report the pay data when Pat<The psplf d is tkle:r, , :can which the amount was withheld from the ermployee%bllgot's vwt?a ss.You.� "" # v ( if applicable)of the ernployeelobligoes principal ply bf errn s ` i� �* t;irn� _ t the withholding and forward the support payments: Multipio 1W Os: If here is more than one IWO st#ltrs Af and yp ara,u,ab1e,to fuky h_; ab,lyhtt; .fit to Federal,State,orr w�kiq ,y nth 1. support before payment cf,any _ siapport � erg r o1r ms place of errmployment`to determft :e on method. Lump Sum Paymanis: You may be required to qqW a ,or T", CSI,. y of ufacominpiump sprit payments to this employee/obligor such as bonuses'cotrlrnl s;`or se rem I Ce lei de e =qtr lam ed=to report and/or withhold lump sum payments. Liability: If you have any doubts amt t ty f Mi I Q�c ,if you fsil to w, wrr#e from a employee/ s.�e the M�� yam. . ' ._ any penalties set try State or Trll al Iawu/pro t re. Anti-dis+rsrinicaan; You are subject to a lira el i under roc Try for dlspa an k" ; frcattt empioymerit,rettasing to emb#oy,or tilk,6g :' ``` ai r° ;` b' aof . , OMB Expiration Date—05/3112014.The OM8 Expiration Date has no bearing on the tenhinattw date of the IWO,it identifies the version of the form currervoy in use. Form EN-028 06112 Service Type M Page 2 of 3 Worker ID$IATT ^ . Employer's Name: DAUPHIN CNTY OFF OF PERSONNEL Employer FEIN: Name: CSE Agency Case Identifier: Order Identifier:(Sm Addendum for onjonVoket Information Withholding Limits:You may not withhold more than the lesser of. 1)the amounts allowed by the Federal Consumer Credit Protection Act(CCPA)(15 U.S.C. 1673(b));or 2)the amounts allowed by the State or Tribe of the employee/obligors principal place of employment(see REMITTANCE iNFORMATiC>N).Disposable income is the net income left after making mandatory deductions such as:State,Federal,local taxes;Social Security taxes;statutory pension contributions;and Medicare taxes.The Federal limit is5O%of the disposable income if the obligor im supporting another family and 8096uf the disposable income if the obligor|m not supporting another family. However,those limits increase 59&-to55%and R5%-if the arrears are greater than 12 weeks.|f permitted by the State or Tribe,you may deduct a fee for administrative costs.The combined support amount and fee may not exceed the limit indicated in this section. For Tribal orders,you may not withhold more than the amounts allowed under the law of the issuing Tribe.For Tribal employers/income withholders who receive m State|VV[).you may not withhold more than the lesser of the limit set by the law cf the jurisdiction|nwhich the employer/income withholder|o|pnatedorthamoximumamountponnittndwndersed|on3O3(d)oftheCOPA(15U.S.C. 1G73(b)). Depending upon applicable State or Tribal law,you may need to also consider the amounts paid for health care premiums|n determining disposable income and applying appropriate withholding limits. Arrears greater than 12 weeks?If the Order Information does not indicate that the arrears are greater than 12 weeks,then the Employer should calculate the CCPA limit using the lower percentage. Additional Information: NOTIFICATION OF EMPLOYMENT TERMINATION OR INCOME STATUS: If this employeelobligor never worked for you or you are no longer withholding income for this employee/obligor,an employer must promptly notify the CSE agency and/or the sender by retuming this form to the address listed in the Contact Information below: 2360030430 0 This person has never worked for this employer nor received periodic income. 0 This person no longer works for this employer nor receives periodic income. Please provide the following Information for the employee/obligor: Termination date: Last known phone number: Last known address: Final Payment Date To SDUrTribal Payee: Final Payment Amount: New Employer's Name: New Employees Address: CONTACT INFORMATION: To Employer/income Withholder: K you have any questions,contact WAGE ATTACHMENT UNIT(Issuer name) by phone at by fax at by email orvwobs|boat: . Send termination/income status notice and other correspondence to:DOMESTIC RELATIONS SECTION, 13 N.HAN-OVER ST. P.O. BOX 320.CARLISLE, PA. 17013(Issuer address). To EMRIWo/Obligor: |y the employee/obligor has questions,contact WAGE ATTACHMENT UNIT(Issuer name) by phone at . by fax mt .by email orvwebm|boat . IMPORTANT:The person completing this form is advised that the information may be shared with the employeelobligor. OMB wv'09m-0`m Form EN-028 06/12 Service Type yW Page 3of3 Worker|[]$|/A-[ 4Q ! ., '. PAINTER,CHARLES E.JR PACSES Gaes NUMbb r 246113067 PACMS:C ;: MMbfir: P1ab*ff Neer Plain fif N. NABR*t, LPODUSHAN 09-7330 CIVIL $ 146: $ Chiid(ren)'s Name(s): DOB Child(ren)'s Name(s).- DOB PACSES ease Number PA , ( S Numbfi Plaintiff Name PIa3n�#F Name 0'.' 0 $ Child(ren)'s Name(s): DOB Child( nft Name(s): DOB PALS Case Number P N Ply_Name Plaice N 81t I ew Amunt Doe kg Agact±ment Afl:eu $ 0,00 $ q1 Chiid(ren)'s Name(s): DOB Chiid(ren)'s Name(s): DOB Addendum Form EN-028 06112 Service Typo M once No.:oW"I54 Worker ICS$GATT Law Offices of Gary L. Kelley 3117 Chestnut Street Camp Hill, Pennsylvania 17011 c• (717) 238-1484 -03, w =.-ri Fax (717) 238-1761 r^rrn - ter= April 17, 2013 z70 a �M Prothonotary �° 0 Office of the Prothonotary D -0 z� Cumberland County Courthouse `� N °r•; 1 Courthouse Square v+ w N Carlisle, PA 17013 DO Re: Golpoushan v. Painter WP �O Docket No. 09-7330 In Divorce Dear Sir/Madam: Mr. Painter wishes to appeal the decision dated April 4, 2013, with a mailing date of April 9, 2013, from the Conference Officer awarding APL to Ms. Golpoushan. Mr. Painter is requesting a hearing de novo. Thank you for your attention to this matter. Very truly ours, Gary . elley cc: Heather E. Verchick, Esq. In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION NASRIN GOLPOUSHAN, ) Docket Numbellip Plaintiff/Petitioner, ) vs. ) PACSES Case Number 246113057 CHARLES E. PAINTER, JR., ) Other State ID Number Defendant/Respondent. ) ORDER OF COURT You, CHARLES E. PAINTER, JR., are ordered to appear at the DOMESTIC RELATIONS hearing room, c/o Hearing Room, DOMESTIC RELATIONS OFFICE, 13 North Hanover Street, Carlisle, PA 17013 on Wednesday, July 17, 2013, at 8:30 a.m., for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income Statement and the appropriate Expense Statement, if required, attached to this order, completed as required by Rule 1910.11(c), 4. verification of child care expenses and, 5. proof of medical coverage which you may have, or may have available to you, 6. information relating to professional licenses, 7. other: rsa w rn cr rn- rn CP <C7 -o [ -}., y GOLPOUSHAN v. PAINTER PACSES Case Number 246113057 If you fail to appear for the hearing or to bring the required documents, the court may issue a warrant for your arrest and/or enter an interim Support order. THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD TO WHICH PARTY INITIATED THE SUPPORT ACTION. • * • Date of Order: JUN 0 5 2013 THOMA . PLACEY, JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. 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 Bedford Street Carlisle, PA 17013-3302-32 (717) 249-3166 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 at(717)240-6225. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. CM-514 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION NASRIN GOLPOUSHAN, ) Docket Number Plaintiff/Petitioner, ) vs. ) PACSES Case Number 2461 13057 CHARLES E. PAINTER, JR., ) Other State ID Number Defendant/Respondent. ) ORDER OF COURT You,NASRIN GOLPOUSHAN, are ordered to appear at the DOMESTIC RELATIONS hearing room, c/o Hearing Room, DOMESTIC RELATIONS OFFICE, 13 North Hanover Street, Carlisle, PA 17013 on Wednesday, July 17, 2013, at 8:30 a.m., for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income Statement and the appropriate Expense Statement, if required, attached to this order, completed as required by Rule 1910.11(c), 4. verification of child care expenses and, 5. proof of medical coverage which you may have, or may have available to you, 6. information relating to professional licenses, 7. other: rri t CD-r* :O c5 ✓` C C C7i_ • - i c, C), GOLPOUSHAN v. PAINTER PACSES Case Number 246113057 If you fail to appear for the hearing or to bring the required documents, the court may issue a warrant for your arrest and/or enter an interim Support order. THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD TO WHICH PARTY INITIATED THE SUPPORT ACTION. - II • : Date of Order: JUN 0 5 2013 THOMA A. PLACEY, JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. 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 Bedford Street Carlisle, PA 17013-3302-32 (717) 249-3166 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 at(717)240-6225. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. CM-514 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION NASRIN GOLPOUSHAN, ) Docket Number 09-7330 CIVIL TERM Plaintiff/Petitioner, ) vs. ) PACSES Case Number 246113057 C" r a - CHARLES E. PAINTER, JR., ) Other State ID Number 3 Defendant/Respondent. ) rn Cc C - = :�t m c r ORDER OF COURT You,NASRIN GOLPOUSHAN, are ordered to appear at the D ESTIC ? --, �--s cRELATIONS hearing room, c/o Hearing Room, DOMESTIC RELATION FI 1 )> �n North Hanover Street, Carlisle, PA 17013 on Monday,August 26, 2013 ':30a.m., r`n for a hearing. o w You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income Statement and the appropriate Expense Statement, if required, attached to this order, completed as required by Rule 1910.11(c), 4. verification of child care expenses and, 5. proof of medical coverage which you may have, or may have available to you, 6. information relating to professional licenses, 7. other: GOLPOUSHAN v. PAINTER PACSES Case Number 246113057 If you fail to appear for the hearing or to bring the required documents, the court may issue a warrant for your arrest and/or enter an interim Support order. THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD TO WHICH PARTY INITIATED THE SUPPORT ACTION. BErGOURT:________ Date of Order: JUL 10 205 THOMAS . PLACEY, JUDGE YOU HAVE THE RIGHT TO A LAWYER,WHO MAY ATTEND THE HEARING AND REPRESENT YOU. 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 Bedford Street Carlisle, PA 17013-3302• (717) 249-3166 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 at (717)240-6225. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. CM-514 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION NASRIN GOLPOUSHAN, ) Docket Number 09-7330 CIVIL TERM Plaintiff/Petitioner, ) . VS. ) PACSES Case Number 246113057 CHARLES E. PAINTER, JR., ) Other State ID Number '' ; Defendant/Respondent. ) -- Ln d �i ORDER OF COURT ' C" 5c= �� pp 3 You, CHARLES E. PAINTER, JR., are ordered to appear at the DOMESTIC< 47 X RELATIONS hearing room, c/o Hearing Room, DOMESTIC RELATI North Hanover Street, Carlisle, PA 17013 on Monday, August 26, 201for a hearing. You are further required to bring to the hearing: v? J 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income Statement and the appropriate Expense Statement, if required, attached to this order, completed as required by Rule 1910.11(c), 4. verification of child care expenses and, 5. proof of medical coverage which you may have, or may have available to you, 6. information relating to professional licenses, 7. other: GOLPOUSHAN v. PAINTER PACSES Case Number 246113057 If you fail to appear for the hearing or to bring the required documents, the court may issue a warrant for your arrest and/or enter an interim Support order. THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD TO WHICH PARTY INITIATED THE SUPPORT ACTION. BY xx Date of Order: JUL 10 2013 THOMAS W. PLACEY, JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. 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 Bedford Street Carlisle, PA 17013-3302• (717) 249-3166 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 at(717)240-6225. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. CM-514 INCOME WITHHOLDING FOR SUPPORT 94[4 1305­7 ORIGINAL INCOME WITHHOLDING ORDER/NOTICE FOR SUPPORT(IWO) 0 v , I • AMENDEDIWO O ONE-TIMEORDERINOTICE FOR LUMP SUM PAYMENT Q TERMINATION OF IWO Date: 07/30113 ❑ Child Support Enforcement(CSE)'Agency ® Court ❑ Attorney ❑ Private Individual/Entity(Check One) NOTE:This IWO mu§t.¢e..r4gulaCkopgtssfaee.°Under certain circumstances you must reject this IWO and return it to the sender(see IWO instructions http:16nm iv,acfY•ihs aov/programs/cse/newhire/employer/publication/publication htm-forms). If you receive this document from someone other than a State or Tribal CSE agency or a Court,a copy of the underlying order must be attached. Statef ribe/Territory Commonwealth of Pennsylvania Remittance Identifier(include w/payment): 9679000272 City/County/Dist./Tribe CUMBERLAND Order Identifier: (See Addendum for order/docket Informalton) Private Individual/Entity CSE Agency Case Identifier: (See Addendum for case summary) DAUPHIN CNTY OFF OF PERSONNEL RE: PAINTER,CHARLES E.JR C/O ATTN: PAYROLL Employee/Obligor's Name(Last, First,Middle) PO BOX 1295 210-54-4987 HARRISBURG PA 17108-1295 Employee/Obligor's Social Security Number (See Addendum for plaintiff names associated with cases on attachment) Custodial Party/Obligee's Name(Last,First, Middle) Employer/Income Withholder's FEIN 236003043 NOTE:This IWO must be regular on its face. Under certain circumstances you must reject Child(ren)'s Name(s)(Last, First,Middle) Child(ren)'s Birth Date(s) this IWO and return it to the sender(see IWO instructions htti):/Iwww.acf hhs.ciov/programs/cse/newhire/ emoloyer/publication/oublication.htm-forms).If you receive this document from someone other than a State or Tribal CSE agency or a Court,a copy of the underlying order must be attached. 2360030430 See Addendum for dependent names and birth dates associated with cases on attachment. r•.a ORDER INFORMATION: This document is based on the support or withholding order from CUMBERLAND County, Commonwealth of Pennsylvania (State/Tribe). You are required by law to deduct these amountts�rt tVemploype/ obligor's income until further notice. ern $ 0.00 per month in current child support cnr I Vic:` $ 0.00 per month in past-due child support- Arrears 12 weeks or greater? Q Q two 7r'. $ 0.00 per month in current cash medical support 'c° --v $ 0.00 per month in past-due cash medical support _ c $ 724,00 per month in current spousal support �`W $ 0.00 per month in past-due spousal support $ 0.00 per month in other(must specify) for a Total Amount to Withhold of$ 724.00 per month. AMOUNTS TO WITHHOLD: You do not have to vary your pay cycle to be in compliance with the Order Information. If your pay cycle does not match the ordered payment cycle, withhold one of the following amount: $ 1&-7.DcS per weekly pay period. $ 362.00 per semimonthly pay period (twice a month) $ :-:�3;4, 1 per biweekly pay period (every two weeks) $ 724.00 per monthly pay period. $ Lump Sum Payment: Do not stop any existing IWO unless you receive a termination order. REMITTANCE INFORMATION: If the employee/obligor's principal place of employment is within the Commonwealth of Pennsylvania (State/Tribe), you must begin withholding no later than the first pay period that occurs ten 10 working days after the date of this Order/Notice. Send payment within seven 7 working days of the pay date. If you cannot withhold the full amount of support for any or all orders for this employee/obligor, withhold up to 55% of disposable income for all orders. If the employee/obligor's principal place of employment is not within the Commonwealth of Pennsylvania (State/Tribe), the employer can obtain withholding limitations, time requirements, and any allowable employer fees at http://www.acf.hhs.gov/programs/cse/newhire/employer/contacts/contact map. htm for the employee/obligor's principal place of employment. Document Tracking Identifier OMB No.:0970-0154 Form EN-028 06/12 Service Type M Worker ID $IATT ' Fl Return tm Sender[Completed 6v Employer/income WithhrNdeM. Payment must be directed toanSOUin , ° accordance with 42 UGC§666(b)(5\and (b)(6)or Tribal Payee(see Payments toSOUbel�. K�yment� n� d�emtedbnanSQU/Trba| Payee or this |VVT�is not regular on its face, you n�uotcheck this ' and return the |VVObo the sender. Signature of Judge/Issuing Official (if required by State or Tribal law): Print Name of Judge/Issuing Official: Title of Judge/Issuing Official: Date of Signature: 1111,312M JUL If the employee/obligor works in a State or for a Tribe that is different from the State or Tribe that issued this order, a copy of this IWO must be provided to the employee/obligor. [] If checked,the employer/income withholder must provide a copy of this form to the employeelobligor. ADDITIONAL INFORMATION FOR EK8PLOYERV|NCOk8EVVITHHOLDERS Pennsylvania law(23PAC.S.§4374(b)) requires remittance byan electronic payment method |fen employer ioordered to withhold income from more than one employee and employs 15 or more persons,or if am employer has o history mf two or more returned checks due tononmufOcierdfunds. P|amme call the Pennsylvania State Collections and Disbursement Unit(PA GCOU) Employer Customer Service et1-x77'G76'0580 for instructions. P/\F|PS CODE 42DOU08 Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDB, P.O. Box 69112, Harrisburg, Pal 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID(shown above as the Employee/Obligor's CaseIdemtifler) OR SOCIAL SECURITY NUMBER 8VORDER TO BE PROCESSED. DO NOT SEND CASH BY MAK, State-specific contact and withholding information can be found on the Federal Employer Services website located at: Priority:Withholding for support has priority over any other legal process under State law against the same income(USC 42 §S86(b)(7)). |fo Federal tax levy ioin effect, please notify the sender, Combining Payments: When remitting payments to an SDU or Tribal CSE agency,you may combine withheld amounts from more than one employee/obligor's income in a single payment.You must, however, separately identify each employee/ obligor's portion of the payment. Payments To SDU: You must send child support payments payable by income withholding to the appropriate SDU or to a Tribal CBE agency. |f this |VVD instructs you busendopayment toan entity other than anSDU(e.g.. payable to the custodial party, court, or attorney), you must check the box above and return this notice to the sender. Exception: If this IWO was sent by a Court,Attorney, or Private Individual/Entity and the initial order was entered before January 1, 1994 or the order was issued by a Tribal CSE agency, you must follow the"Remit payment to"instructions on this form. Reporting the Pay Date: You must report the pay date when sending the payment,The pay date im the date on which the amount was withheld from the emp|oyee/ob|igor's wages.You must comply with the law of the State(or Tribal law if applicable)of the employeelobligor's principal place of employment regarding time periods within which you must implement the withholding and forward the support payments. Multiple IWOm' \f there ia more than one|VVO against this employee/obligor andyouanaunab|e0ufuU honor all /VVDs due 0n Federal, State, or Tribal withholding limits, you must honor all IWOs to the greatest extent possible, giving priority to current support before payment of any past-due support. Follow the State or Tribal law/procedure of the employee/obligor's principal place of employment to determine the appropriate allocation method. Lump Sum Payments: You may be required tnnotify a State or Tribal CSE agency of upcoming lump sum payments tothis employee/obligor such as bonuses, commissions,or severance pay. Contact the sender to determine if you are required to report and/or withhold lump sum payments. Liability: If you have any doubts about the validity of this|VVO. contact the sander. If you fail 0o withhold income from the employee/obligor's income as the IWO directs, you are liable for both the accumulated amount you should have withheld and any penalties set by State or Tribal |am/pnzceduna. And-diecr1nmination: You are subject to a fine determined under State or Tribal law for discharging an amployee/ub|igurhnm employment, refusing to employ, or taking disciplinary action against an employee/obligor because of this IWO. OMB Expiration Date-uom,xmw,The OMB Expiration Date has n"bearing onthe termination date w the/~o;n identifies the version m the form currently/"use. Form EN-D28O6/12 Service Type M Page 2nf3 Worker |D$|/A-T Employer's Name: DAUPHIN CNTY OFF OF PERSONNEL Employer FEIN: 236003043 Employee/Obligor's Name: PAINTER,CHARLES E. JR 9679000272 CSE Agency Case Identifier:(_See Addendum for case summary) Order Identifier:(See Addendum for order/docket information) Withholding Limits:You may not withhold more than the lesser of: 1)the amounts allowed by the Federal Consumer Credit Protection Act(CCPA)(15 U.S.C. 1673(b));or 2)the amounts allowed by the State or Tribe of the employee/obligor's principal place of employment(see REMITTANCE INFORMATION). Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; statutory pension contributions; and Medicare taxes.The Federal.limit is 50%of the disposable income if the obligor is supporting another family and 60%of the disposable income if the obligor is not supporting another family. However,those limits increase 5%-to 55%and 65%-if the arrears are greater than 12 weeks. If permitted by the State or Tribe, you may deduct a fee for administrative costs.The combined support amount and fee may not exceed the limit indicated in this section. For Tribal orders,you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employers/income withholders who receive a State IWO,you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which the employer/income withholder is located or the maximum amount permitted under section 303(d)of the CCPA(15 U.S.C. 1673(b)). Depending upon applicable State or Tribal law,you may need to also consider the amounts paid for health care premiums in determining disposable income and applying appropriate withholding limits. Arrears greater than 12 weeks?If the Order Information does not indicate that the arrears are greater than 12 weeks,then the Employer should calculate the CCPA limit using the lower percentage. Additional Information: NOTIFICATION OF EMPLOYMENT TERMINATION OR INCOME STATUS: If this employee/obligor never worked for you or you are no longer withholding income for this employee/obligor,an employer must promptly notify the CSE agency and/or the sender by returning this form to the address listed in the Contact Information below: 2360030430 Q This person has never worked for this employer nor received periodic income. 0 This person no longer works for this employer nor receives periodic income. Please provide the following information for the employee/obligor: Termination date: Last known phone number: Last known address: Final Payment Date To SDU/Tribal Payee: Final Payment Amount: New Employer's Name: New Employer's Address: CONTACT INFORMATION: To Employer/Income Withholder: If you have any questions, contact WAGE ATTACHMENT UNIT(Issuer name) by phone at(717)240-6225, by fax at(717)240-6248, by email or website at:www.chiIdsupport.state.pa.us. Send termination/income status notice and other correspondence to:DOMESTIC RELATIONS SECTION, 13 N. HANOVER ST. P.O. BOX 320, CARLISLE, PA. 17013(Issuer address). To Employee/Obligor: If the employee/obligor has questions, contact WAGE ATTACHMENT UNIT(Issuer name) by phone at(717)240-6225, by fax at(717)240-6248, by email or website at www.childsupport.state.pa.us. IMPORTANT:The person completing this form is advised that the information may be shared with the employee/obligor. OMB No.:0970-0154 Form EN-028 06/12 Service Type M Page 3 of 3 Worker ID $IATT ADDENDUM SurnrnaU of Cases on Attachment Defendant/Obligor: PAINTER, CHARLES E.JR PACSES Case Number 246113057 PACSES Case Number Plaintiff Name Plaintiff Nam NASRIN GOLPOUSHAN Docket Attachment Amount Docket Attachment Amount 09-7330 CIVIL $ 724.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB PACSES Case Number PACSES Case Number Plaintiff Name Plaintiff Name Docke t Attachment Amount Docket Attachment Amount $ 0.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB PACSES Case Number PACSES Case Number Plaintiff Name Plaintiff Nam Docke t Attachment Amount Docket Attachment Amount $ 0.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB Addendum Form EN-028 06/12 Service Type M OMB No.:0970-0154 Worker ID $IATT In the Court of Common Pleas of CUMBERLAND County,Pennsylvania DOMESTIC RELATIONS SECTION NASRIN GOLPOUSHAN, ) Docket Number 09-7330 CIVIL TERM Plaintiff/Petitioner, VS. ) PACSES Case Number 246113057 c CHARLES E. PAINTER, JR., ) Other State ID Number y ' Defendant/Respondent. ) v C--) C-3 c:)�., ORDER OF COURT You,NASRIN GOLPOUSHAN, are ordered to appear at the DOMESTIC RELATIONS hearing room, c/o Hearing Room, DOMESTIC RELATIONS OFFICE, 13 North Hanover Street, Carlisle, PA 17013 on Thursday, October 24, 2013, at 8:30 a.m., for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income Statement and the appropriate Expense Statement, if required, attached to this order, completed as required by Rule 1910.11(c), 4. verification of child care expenses and, 5. proof of medical coverage which you may have, or may have available to you, 6. information relating to professional licenses, 7. other: GOLPOUSHAN v. PAINTER PACSES Case Number 246113057 If you fail to appear for the hearing or to bring the required documents, the court may issue a warrant for your arrest and/or enter an interim Support order. THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD TO WHICH PARTY INITIATED THE SUPPORT ACTION. B Date of Order: SEP 2015 THOMA§ A PLACEY, JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. 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 Bedford Street Carlisle, PA 17013-3302- (717) 249-3166 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 at(717)240-6225. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. CM-514 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION NASRIN GOLPOUSHAN, ) Docket Number 09-7330 CIVIL TERM Plaintiff/Petitioner, ) �w VS. ) PACSES Case Number 246113057 c ' CHARLES E. PAINTER, JR., ) Other State ID Number ; Defendant/Respondent. ) Z. :�*r:j -m -- D n ° �? ORDER OF COURT sv --� You, CHARLES E. PAINTER, JR., are ordered to appear at the DOMESTIC RELATIONS hearing room, c/o Hearing Room, DOMESTIC RELATIONS OFFICE, 13 North Hanover Street, Carlisle, PA 17013 on Thursday, October 24, 2013, at 8:30 a.m., for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6)months, 3. the Income Statement and the appropriate Expense Statement, if required, attached to this order, completed as required by Rule 1910.11(c), 4. verification of child care expenses and, 5. proof of medical coverage which you may have, or may have available to you, 6. information relating to professional licenses, 7. other: GOLPOUSHAN v. PAINTER PACSES Case Number 246113057 If you fail to appear for the hearing or to bring the required documents, the court may issue a warrant for your arrest and/or enter an interim Support order. THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD TO WHICH PARTY INITIATED THE SUPPORT ACTION. BY THE C Date of Order: S EP 10 2013 THOMAS LACEY, JUDGE YOU HAVE THE RIGHT TO A LAWYER,WHO MAY ATTEND THE HEARING AND REPRESENT YOU. 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 Bedford Street Carlisle, PA 17013-3302• (717) 249-3166 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 at(717)240-6225. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. CM-514 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION NASRIN GOLPOUSHAN, ) Docket Number 1=. Plaintiff/Petitioner, ) ; vs. ) PACSES Case Number -a+ as. CHARLES CHARLES E. PAINTER, JR., ) Other State ID Number s Defendant/Respondent. ) r-z,,.tea -,a c -11 7P cn tp , ., ORDER OF COURT % 7,, You, CHARLES E. PAINTER, JR., are ordered to appear at the DOMESTIC RELATIONS hearing room, c/o Hearing Room, DOMESTIC RELATIONS OFFICE, 13 North Hanover Street, Carlisle, PA 17013 on Thursday, January 9, 2014, at 8:30 a.m., for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income Statement and the appropriate Expense Statement, if required, attached to this order, completed as required by Rule 1910.11(c), 4. verification of child care expenses and, 5. proof of medical coverage which you may have, or may have available to you, 6. information relating to professional licenses, 7. other: GOLPOUSHAN v. PAINTER PACSES Case Number 246113057 If you fail to appear for the hearing or to bring the required documents, the court may issue a warrant for your arrest and/or enter an interim Support order. THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD TO WHICH PARTY INITIATED THE SUPPORT ACTION. BY THE COURT: Date of Order: ( OCT i� ,; THOMAS A. PLA :Y, JUDGE YOU HAVE THE RIGHT TO A LAWYER,WHO MAY ATTEND THE HEARING AND REPRESENT YOU. 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 Bedford Street Carlisle, PA 17013-3302- (717) 249-3166 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 at(717)240-6225. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. CM-514 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION NASRIN GOLPOUSHAN, ) Docket Number 1. Plaintiff/Petitioner, ) vs. ) PACSES Case Number p CHARLES E. PAINTER, JR., ) Other State ID Number s w -r, Defendant/Respondent. ) raM o rn col' ORDER OF COURT <ma' -v c) ; _- You,NASRIN GOLPOUSHAN, are ordered to appear at the DOMESTpt'. _ '` RELATIONS hearing room, c/o Hearing Room, DOMESTIC RELATIONS OFFICE, 13 North Hanover Street, Carlisle, PA 17013 on Thursday, January 9, 2014, at 8:30 a.m., for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income Statement and the appropriate Expense Statement, if required, attached to this order, completed as required by Rule 1910.11(c), 4. verification of child care expenses and, 5. proof of medical coverage which you may have, or may have available to you, 6. information relating to professional licenses, 7. other: GOLPOUSHAN v. PAINTER PACSES Case Number 246113057 If you fail to appear for the hearing or to bring the required documents, the court may issue a warrant for your arrest and/or enter an interim Support order. THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD TO WHICH PARTY INITIATED THE SUPPORT ACTION. BY T. _e . ' . Date of Order: OCT 31 2013 THOMAS A LACEY, JUDGE YOU HAVE THE RIGHT TO A LAWYER,WHO MAY ATTEND THE HEARING AND REPRESENT YOU. 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 Bedford Street Carlisle, PA 17013-3302- (717) 249-3166 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 at(717)240-6225. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. CM-514 i NASRIN GOLPOUSHAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA vs. : DOMESTIC RELATIONS SECTION : DOCKET NO. 09-7330 CIVIL CHARLES E. PAINTER, : PACSES NO. 246113057 rricD Defendant. : `� .„I- cp ORDER OF COURT AND NOW, this 8th day of January, 2014, this matter having been c:., 6-r-, scheduled for a hearing de novo before the Support Master on the Plainffsz- petition for modification of alimony pendente lite, and the Defendant, with theme consent of the Plaintiff, having withdrawn his request for said hearing, upon recommendation of the Master it is ordered and decreed as follows: 1. The interim order entered April 4, 2013 is affirmed as a final order. 2. The hearing scheduled for January 9, 2014 is cancelled. a eCourt, Thomas PI:cey, J. cc: Nasrin Golpoushan Charles E. Painter Heather E. Verchick, Esquire For the Plaintiff Gary L. Kelley, Esquire For the Defendant DRO/rjs NASRIN GOLPOUSHAN, Plaintiff/Petitioner VS. CHARLES E. PAINTER, Defendant/Respondent : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 09 -7330 CIVIL TERM IN DIVORCE -a z -i PACSES CASE: 246113057 z a r';`' -�� C-7.' , r; - C.) 5--; : ru �; _ 4- sc_ --i ORDER OF COURT AND NOW, this 27th day of February, 2014, based upon the Court's determination that the Petitioner's monthly net income /earning capacity is $ n/a and the Respondent's monthly net income /earning capacity is $ n/a, it is hereby ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit One Thousand Five Hundred and 00 /100 Dollars ($ 1,500.00) per month payable bi- weekly as follows: $ 1,447.00 per month for Alimony Pendente Lite and $ 53.00 per month on arrears. The first payment is due in accordance with the Respondent's pay schedule. The effective date of the order is February 14, 2014. Arrears set at $ 313.36 as of February 27, 2014. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C.S.§ 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and, at its discretion, make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money is to be turned over by the PA SCDU for distribution and disbursement in accordance with Rule 1910.17(d). Payments must be made by check or money order. All checks and money orders must be made payable to PA SCDU and mailed to: PA SCDU P.O. Box 69110 Harrisburg, PA 17106 -9110 Payments must include the Respondent's name with their. PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. cc360 The monthly support obligation includes cash medical support in the amount of $250 annually for unreimbursed medical expenses incurred for the spouse. Unreimbursed medical expenses of the spouse that exceed $250 annually shall be allocated between the parties. The party seeking allocation of unreimbursed medical expenses must provide documentation of expenses to the other party no later than March 31St of the year following the calendar year in which the final medical bill to be allocated was received. The unreimbursed medical expenses are to be paid as follows: 0 % by Respondent and 100 % by Petitioner. [X] Respondent [] Petitioner [] Neither party to provide medical insurance coverage. Within thirty (30) days after the entry of this order, the [] Petitioner [X] Respondent shall submit written proof that medical insurance coverage has been obtained or that application for coverage has been made. Proof of coverage shall consist, at a minimum, of: 1) the name of the health care coverage provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims should be made; 5) a description of any restrictions on usage, such as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and co- payments; and 8) five copies of any claim forms. It is further Ordered that, upon payor's failure to comply with this order, payor may be arrested and brought before the Court for a Contempt hearing; payor's wages, salary, commissions, and/or income may be attached in accordance with law; this Order will be increased without further hearing by 0% a month until all arrearages are paid in full. Payor is responsible for court costs and fees. Other conditions: Effective February 14, 2014, the APL obligation is increased pursuant to the sale and settlement of the marital home on February, 14, 2014. This Order shall become final twenty (20) after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Office of the Prothonotary for a hearing de novo before the Court. FEB 2 8 2014 Mailed copies on: xc: Petitioner Respondent Heather E. Verchick, Esq. Gary L. Kelley, Esq. DRO: R.J. Shadday INCOME WITHHOLDING FOR SUPPORT 071-1-1D l /3 d 57 Q ORIGINAL INCOME WITHHOLDING ORDER/NOTICE FOR SUPPORT(IWO) Q AMENDED IWO 09 _ --733D Li v j J Q ONE-TIMEORDER/NOTICE FOR LUMP SUM PAYMENT Q TERMINATION OF IWO Date: 02/27/14 ❑ Child Support Enforcement(CSE)Agency ® Court ❑ Attorney ❑ Private Individual/Entity(Check One) NOTE:This IWO must be regular on its face. Under certain circumstances you must reject this IWO and return it to the sender(see IWO instructions http://www.acf.hhs.gov/programs/cse/forms/OMB-0970-0154 instructions.pdf). If you receive this document from someone other than a State or Tribal CSE agency or a Court, a copy of the underlying order must be attached. State/Tribe/Territory Commonwealth of Pennsylvania Remittance Identifier(include w/payment): 9679000272 City/County/Dist./Tribe CUMBERLAND Order Identifier: (See Addendum for order/docket information) Private Individual/Entity CSE Agency Case Identifier: (See Addendum for case summary) DAUPHIN CNTY OFF OF PERSONNEL RE: PAINTER,CHARLES E.JR C/O ATTN: PAYROLL Employee/Obligor's Name(Last, First, Middle) PO BOX 1295 210-54-4987 HARRISBURG PA 17108-1295 Employee/Obligor's Social Security Number (See Addendum for plaintiff names associated with cases on attachment) Custodial Party/Obligee's Name(Last, First, Middle) Employer/Income Withholder's FEIN 236003043 NOTE:This IWO must be regular on its face. Under certain circumstances you must reject Child(ren)'s Name(s)(Last, First,Middle) Child(ren)'s Birth Date(s) this IWO and return it to the sender(see IWO instructions htto://www.acf.hhs.gov/programs/cse/forms/ OMB-0970-0154 instructions.odt).If you receive this document from someone other than a State or Tribal CSE agency or a Court,a copy of the underlying order must be attached. 2360030430 See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This document is based on the support or withholding order from CUMBERLAND County, Commonwealth of Pennsylvania (State/Tribe). You are required by law to deduct these amounts from the employee/ obligor's income until further notice. $ 0.00 per month in current child support $ 0.00 per month in past-due child support- Arrears 12 weeks or greater? 0 .j CMo $ 0.00 per month in current cash medical support t $ 0.00 per month in past-due cash medical support rte- c- $ 1,447.00 per month in current spousal support < -v - $ 0.00 per month in past-due spousal support z_c $ 0.00 per month in other(must specify) Ty .• for a Total Amount to Withhold of$ 1,447.00 per month. AMOUNTS TO WITHHOLD: You do not have to vary your pay cycle to be in compliance with the Order Information. If your pay cycle does not match the ordered payment cycle, withhold one of the following amount: $ 333.93 per weekly pay period. $ 723.50 per semimonthly pay period (twice a month) $ 66'7,16 per biweekly pay period (every two weeks) $ 1,447.00 per monthly pay period. $ Lump Sum Payment: Do not stop any existing IWO unless you receive a termination order. REMITTANCE INFORMATION: If the employee/obligor's principal place of employment is within the Commonwealth of Pennsylvania (State/Tribe), you must begin withholding no later than the first pay period that occurs ten (10) working days after the date of this Order/Notice. Send payment within seven (7)working days of the pay date. If you cannot withhold the full amount of support for any or all orders for this employee/obligor, withhold up to 55% of disposable income for all orders. If the employee/obligor's principal place of employment is not within the Commonwealth of Pennsylvania (State/Tribe), the employer can obtain withholding limitations, time requirements, and any allowable employer fees at http://www.acf.hhs.gov/programs/cse/newhire/employer/contacts/contact map. htm for the employee/obligor's principal place of employment. Document Tracking Identifier OMB No.:0970-0154 Form EN-028 11/13 Service Type M Worker ID $IATT ❑ Return to Sender [Completed by Employer/Income Withholder]. Payment must be directed to an SDU in accordance with 42 USC §666(b)(5) and (b)(6) or Tribal Payee (see Payments to SDU below). If payment is not directed to an SDU/Tribal Payee or this IWO is not regular on its face, you must check this box and return the IWO to the sender. Signature of Judge/Issuing Official (if required by State or Tribal law): Print Name of Judge/Issuing Official: Thomas A. Placey Title of Judge/Issuing Official: te,Date of Signature: �-2 8 2014 �u I FEB FE6 � 3 ?flid If the employee/obligor works in a State or for a Tribe that is different from the State or Tribe that issued this order, a copy of this IWO must be provided to the employee/obligor. ❑ If checked,the employer/income withholder must provide a copy of this form to the employee/obligor. ADDITIONAL INFORMATION FOR EMPLOYERS/INCOME WITHHOLDERS Pennsylvania law(23 PA C.S.§4374(b))requires remittance by an electronic payment method if an employer is ordered to withhold income from more than one employee and employs 15 or more persons, or if an employer has a history of two or more returned checks due to nonsufficient funds. Please call the Pennsylvania State Collections and Disbursement Unit(PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. PA FIPS CODE 42 000 00 Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID(shown above as the Employee/Obligor's Case Identifier)OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. State-specific contact and withholding information can be found on the Federal Employer Services website located at: http://www.acf.hhs.gov/programs/cse/newhire/employer/contacts/contact_map.htm Priority: Withholding for support has priority over any other legal process under State law against the same income(USC 42 §666(b)(7)). If a Federal tax levy is in effect, please notify the sender. Combining Payments: When remitting payments to an SDU or Tribal CSE agency, you may combine withheld amounts from more than one employee/obligor's income in a single payment. You must, however, separately identify each employee/ obligor's portion of the payment. Payments To SDU: You must send child support payments payable by income withholding to the appropriate SDU or to a Tribal CSE agency. If this IWO instructs you to send a payment to an entity other than an SDU(e.g., payable to the custodial party, court, or attorney), you must check the box above and return this notice to the sender. Exception: If this IWO was sent by a Court, Attorney, or Private Individual/Entity and the initial order was entered before January 1, 1994 or the order was issued by a Tribal CSE agency, you must follow the"Remit payment to" instructions on this form. Reporting the Pay Date: You must report the pay date when sending the payment. The pay date is the date on which the amount was withheld from the employee/obligor's wages. You must comply with the law of the State(or Tribal law if applicable)of the employee/obligor's principal place of employment regarding time periods within which you must implement the withholding and forward the support payments. Multiple IWOs: If there is more than one IWO against this employee/obligor and you are unable to fully honor all IWOs due to Federal, State, or Tribal withholding limits, you must honor all IWOs to the greatest extent possible, giving priority to current support before payment of any past-due support. Follow the State or Tribal law/procedure of the employee/obligor's principal place of employment to determine the appropriate allocation method. Lump Sum Payments: You may be required to notify a State or Tribal CSE agency of upcoming lump sum payments to this employee/obligor such as bonuses, commissions, or severance pay. Contact the sender to determine if you are required to report and/or withhold lump sum payments. Liability: If you have any doubts about the validity of this IWO, contact the sender. If you fail to withhold income from the employee/obligor's.income as the IWO directs, you are liable for both the accumulated amount you should have withheld and any penalties set by State or Tribal law/procedure. Anti-discrimination: You are subject to a fine determined under State or Tribal law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against an employee/obligor because of this IWO. OMB Expiration Date—05/3112014.The OMB Expiration Date has no bearing on the termination date of the IWO;it identifies the version of the form currently in use. Form EN-028 11/13 Service Type M Page 2 of 3 Worker ID $IATT Employer's Name: DAUPHIN CNTY OFF OF PERSONNEL Employer FEIN: 236003043 Employee/Obligor's Name: PAINTER, CHARLES E. JR 9679000272 CSE Agency Case Identifier:(See Addendum for case summary) Order Identifier:(See Addendum for order/docket information) Withholding Limits:You may not withhold more than the lesser of: 1)the amounts allowed by the Federal Consumer Credit Protection Act(CCPA)(15 U.S.C. 1673(b));or 2)the amounts allowed by the State or Tribe of the employee/obligor's principal place of employment(see REMITTANCE INFORMATION). Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; statutory pension contributions; and Medicare taxes.The Federal limit is 50%of the disposable income if the obligor is supporting another family and 60%of the disposable income if the obligor is not supporting another family. However,those limits increase 5%-to 55%and 65%-if the arrears are greater than 12 weeks. If permitted by the State or Tribe, you may deduct a fee for administrative costs.The combined support amount and fee may not exceed the limit indicated in this section. For Tribal orders,you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employers/income withholders who receive a State IWO,you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which the employer/income withholder is located or the maximum amount permitted under section 303(d)of the CCPA(15 U.S.C. 1673(b)). Depending upon applicable State or Tribal law, you may need to also consider the amounts paid for health care premiums in determining disposable income and applying appropriate withholding limits. Arrears greater than 12 weeks?If the Order Information does not indicate that the arrears are greater than 12 weeks,then the Employer should calculate the CCPA limit using the lower percentage. Additional Information: NOTIFICATION OF EMPLOYMENT TERMINATION OR INCOME STATUS: If this employee/obligor never worked for you or you are no longer withholding income for this employee/obligor, an employer must promptly notify the CSE agency and/or the sender by returning this form to the address listed in the Contact Information below: 2360030430 Q This person has never worked for this employer nor received periodic income. O This person no longer works for this employer nor receives periodic income. Please provide the following information for the employee/obligor: Termination date: Last known phone number: Last known address: Final Payment Date To SDU/Tribal Payee: Final Payment Amount: New Employer's Name: New Employer's Address: CONTACT INFORMATION: To Employer/Income Withholder: If you have any questions, contact WAGE ATTACHMENT UNIT(Issuer name) by phone at(717)240-6225, by fax at(717)240-6248, by email or website at:www.childsupport.state.pa.us. Send termination/income status notice and other correspondence to: DOMESTIC RELATIONS SECTION, 13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013(Issuer address). To Employee/Obligor: If the employee/obligor has questions, contact WAGE ATTACHMENT UNIT(Issuer name) by phone at(717)240-6225, by fax at(717)240-6248, by email or website at www.childsupport.state.pa.us. r a IMPORTANT:The person completing this form is advised that the information may be shared with the employee/obligor. OMB No.:0970-0154 Form EN-028 11/13 Service Type M Page 3 of 3 Worker ID $IATT ADDENDUM • Summary of Cases on Attachment Defendant/Obligor: PAINTER, CHARLES E. JR PACSES Case Number 246113057 PACSES Case Number Plaintiff Name Plaintiff Name NASRIN GOLPOUSHAN Docket Attachment Amount Docket Attachment Amount 09-7330 CIVIL $ 1,447.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB PACSES Case Number PACSES Case Number Plaintiff Name Plaintiff Name Docket Attachment Amount Docket Attachment Amount $ 0.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB PACSES Case Number PACSES Case Number Plaintiff Name Plaintiff Name Docket Attachment Amount Docket Attachment Amount $ 0.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB Addendum Form EN-028 11/13 Service Type M OMB No 0970-0154 Worker ID $IATT INCOME WITHHOLDING FOR SUPPORT O ORIGINAL INCO ME WIT WITHHOLDING ORDERINOTICE FOR R SUPPOR rVw o > C) AMENDED IWO [ ows-TIMsonnsmwoncs FOR LUMP SUM PAYMENT U TERMINATION upIWO nr`-u,| \_ _7 uq _ \ Date: 03/03/14 O Child O Private ndivduaI/Entity (Check One) NOTE: This IWO must be regular on its face. Under certain circumstances you must reject this IWO and return it to (he serder (see IWO instructions http://www.acf.hhs.gov/programs/cse/forms/OMB-0970-0154 instructions_pdf). If you receive this document from someone other than a State or Tribal CSE agency or a Court, a copy of the underlying order must be attached. Staterfribe/Territory Commonwealth of Pennsylvania City/County/Dist./Tribe CUMBERLAND Private Individual/Entity Remittance anc o Identifier (include w/pv'mcnU: 9679000272 ooz/-u Order Identifier: (See Addendum for order/docket information) CSE Agency Cas Identifier: (See Addendum for case summary) DAUPHIN CNTY OFF OF PERSONNEL C/O ATTN: PAYROLL PO BOX 12Q5 HARRISBURG PA 17108-1295 Employer/Income Withholder's FEIN 236003043 ChUU<nmyo Name(s) (Last, First, Middle) Child(ren)'s Birth Date(s) RE: PAINTER, CHARLES E. JR Employee/Obligor's Name (Last, First, Middle) 210'54'4987 emp|uyeux]hngors Social Security Number (See Addendum for plaintiff names associated with cases on attachment) Custodial Party/Obligees Name (Last, First, Middle) NOTE: This WO must be regular on its face. Under certain circumstarices you must reject this IWO and return it to the serider (see WO instructions http:xw~°.acf»ovnownmnramstse/fo,ms/ omB'0970-0154 instrctions.�d. If you receive this document from someone other than a State or TribaI CSE agency or a Court, a copy of the underlying order must be attached 2360030430 See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This document is based on the support or withholding order from CU LAND Ccunh/, Commonwealth of Pennsylvania (State/Tribe). You are required by Iaw to deduct these amounts dhqn obligor's income until further notice. 0.00 per month in current child support OI0 per month in past-due child support ' Arrears 12 weeks prgreater? 0.00 per month in current cash medical support 0.00permonthinpaot'duooashmedioa|oupport 1.447.00 per month in current spousal support per month in past-due spousal support 0.00 per month in other (must specify) for a Total Amount to Withhold of $ 1,500.00 per month. 0 no r AMOUNTS TO WITHHOLD: You do not have to vary your pay cycle to be in compliance with the Order Information. If your pay cycle does not match the ordered payment cycle, withhold one of the following amount: � 34'110perweek/y pay period. 750.00 per semimonthly pay period (twice a month) � 69231 per biweekly pay period (every two weeks) $ 1.5O0.00 per monthly pay period. � Lump Sum Payment: Do not stop any existing IWO unless you receive a termination order. REMITTANCE INFORMATION: If the employee/obligor's principal cJaconfemp|oymerdiswithinVheCommonweo|0h of Pennsylvania (StatelTribe), you must begin withholding no later than the first pay period that occurs ten (10) workinq days after the date of this Order/Notice. Send payment within seven (7) working days of the pay date. If you cannot withhold the full amount of support for any or all orders for this employee/obligor, withhold up to 55% of disposable income for all orders. If the employee/obligor's principal place of employment is not within the Commonwealth of Pennsylvania (Sta(e/Thbe), the employer can obtain withholding |imitaUono. time roquiromentm, and any allowable employer fees at hUD:8vmxwv.an[hhs.gVv/o,ognoms/ose/newhireAemp|oyarkcontentskcontad map. iatin for the employeefobUgor's principal place of employment. Document Tracking Identifier Service Type M Form EN'U2811/13 Worker |O$|ATT ❑ Return to Sender [Completed by Employer /Income Withholder]. Payment must be directed to an SDU in accordance with 42 USC §666(b)(5) and (b)(6) or Tribal Payee (see Payments to SDU below). If payment is not directed to an SDU/Tribal Payee or this IWO is not regular on its face, you must check this box and return the IWO to the sender. Signature of Judge /Issuing Official (if required by State or Tribal law Print Name of Judge /Issuing Official: Title of Judge /Issuing Official: Date of Signature: 42 auras A. P[acey JO 1,,e4=1,.. .tl If the employee /obligor works in a State or for a Tribe that is different from the State or Tribe that issued this order, a copy of this IWO must be provided to the employee /obligor. ❑ If checked, the employer /income withholder must provide a copy of this form to the employee /obligor. ADDITIONAL INFORMATION FOR EMPLOYERS /INCOME WITHHOLDERS Pennsylvania law (23 PA C.S. § 4374(b)) requires remittance by an electronic payment method if an employer is ordered to withhold income from more than one employee and employs 15 or more persons, or if an employer has a history of two or more returned checks due to nonsufficient funds. Please call the Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1- 877 - 676 -9580 for instructions. PA FIPS CODE 42 000 00 Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106 -9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee /Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. State - specific contact and withholding information can be found on the Federal Employer Services website located at: http: / /www.acf.hhs.gov /programs /cse /newhire /employer /contacts /contact map.htm Priority: Withholding for support has priority over any other legal process under State law against the same income (USC 42 §666(b)(7)). If a Federal tax levy is in effect, please notify the sender. Combining Payments: When remitting payments to an SDU or Tribal CSE agency, you may combine withheld amounts from more than one employee /obligor's income in a single payment. You must, however, separately identify each employee/ obligor's portion of the payment. Payments To SDU: You must send child support payments payable by income withholding to the appropriate SDU or to a Tribal CSE agency. If this IWO instructs you to send a payment to an entity other than an SDU (e.g., payable to the custodial party, court, or attorney), you must check the box above and return this notice to the sender. Exception; If this IWO was sent by a Court, Attorney, or Private Individual /Entity and the initial order was entered before January 1, 1994 or the order was issued by a Tribal CSE agency, you must follow the "Remit payment to" instructions on this form. Reporting the Pay Date: You must report the pay date when sending the payment. The pay date is the date on which the amount was withheld from the employee /obligor's wages. You must comply with the law of the State (or Tribal law if applicable) of the employee /obligor's principal place of employment regarding time periods within which you must implement the withholding and forward the support payments. Multiple IWOs: If there is more than one IWO against this employee /obligor and you are unable to fully honor all IWOs due to Federal, State, or Tribal withholding limits, you must honor all IWOs to the greatest extent possible, giving priority to current support before payment of any past -due support. Follow the State or Tribal law /procedure of the employee /obligor's principal place of employment to determine the appropriate allocation method. Lump Sum Payments: You may be required to notify a State or Tribal CSE agency of upcoming lump sum payments to this employee /obligor such as bonuses, commissions, or severance pay. Contact the sender to determine if you are required to report and /or withhold lump sum payments. Liability: If you have any doubts about the validity of this IWO, contact the sender. If you fail to withhold income from the employee /obligor's income as the IWO directs, you are liable for both the accumulated amount you should have withheld and any penalties set by State or Tribal law /procedure. Anti - discrimination: You are subject to a fine determined under State or Tribal law for discharging an employee /obligor from employment, refusing to employ, or taking disciplinary action against an employee /obligor because of this IWO. OMB Expiration Date — 05/31/2014. The OMB Expiration Dale has no bearing on the termination date of the IWO; it identifies the version of the form currently in use. Form EN -028 11/13 Service Type M Page 2 of 3 Worker ID $IATT Employer's Name: DAUPHIN CNTY OFF OF PERSONNEL Employer FEIN: 236003043 Employee /Obligor's Name: PAINTER, CHARLES E. JR 9679000272 CSE Agency Case Identifier: (See Addendum for case summary) Order Identifier: (See Addendum for order /docket information) Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (CCPA) (15 U.S.C. 1673(b)); or 2) the amounts allowed by the State or Tribe of the employee /obligor's principal place of employment (see REMITTANCE INFORMATION). Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; statutory pension contributions; and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is supporting another family and 60% of the disposable income if the obligor is not supporting another family, However, those limits increase 5% - to 55% and 65% - if the arrears are greater than 12 weeks. If permitted by the State or Tribe, you may deduct a fee for administrative costs. The combined support amount and fee may not exceed the limit indicated in this section. For Tribal orders, you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employers /income withholders who receive a State IWO, you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which the employer /income withholder is located or the maximum amount permitted under section 303(d) of the CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State or Tribal law, you may need to also consider the amounts paid for health care premiums in determining disposable income and applying appropriate withholding limits. Arrears greater than 12 weeks? If the Order Information does not indicate that the arrears are greater than 12 weeks, then the Employer should calculate the CCPA limit using the lower percentage. Additional Information: NOTIFICATION OF EMPLOYMENT TERMINATION OR INCOME STATUS: If this employee /obligor never worked for you or you are no longer withholding income for this employee /obligor, an employer must promptly notify the CSE agency and /or the sender by returning this form to the address listed in the Contact Information below: 2360030430 o This person has never worked for this employer nor received periodic income. Q This person no longer works for this employer nor receives periodic income. Please provide the following information for the employee /obligor: Termination date: Last known phone number: Last known address: Final Payment Date To SDU/Tribal Payee: Final Payment Amount: New Employer's Name: New Employer's Address: CONTACT INFORMATION: To Employer /Income Withholder: If you have any questions, contact WAGE ATTACHMENT UNIT (Issuer name) by phone at (717) 240 -6225, by fax at (717) 240 -6248, by email or website at: www.childsupport.state.pa.us. Send termination /income status notice and other correspondence to: DOMESTIC RELATIONS SECTION, 13 N. HANOVER ST. P.O. BOX 320. CARLISLE PA. 17013 (Issuer address). To Employee /Obligor: If the employee /obligor has questions, contact WAGE ATTACHMENT UNIT (Issuer name) by phone at (717) 240 -6225, by fax at (717) 240 -6248, by email or website at www.childsupport.state.pa . us. IMPORTANT: The person completing this form is advised that the information may be shared with the employee /obligor. OMB No.: 0970 -0154 Service Type M Page 3 of 3 Form EN -028 11/13 Worker ID $IATT ADDENDUM Summary of Cases on Attachmerit QefendanUOb|igoc PAINTER, CHARLES E. JR PACSES Case Number 246113057 pACSES Case Number Plaintiff Name Plaintiff Name NASRIN GOLPOUSHAN Docket Attachment Amo nt 09-7330 CIVIL $ 1.500.00 Child(ren)'s,Name(s): DOB Docket Attachment Amo nt � 0.00 Child(ren)'s Name(s): DOB PACSES Case Numbe PACSES Case Number Plaintiff Name Plaintiff Name Docket Attachment Amount u 0.00 Child(ren)'s Name(s): DOB Docket Attachment Amount � 0.00 Child(ren)'s Name(s): DOB PACSES Case Number PACSES Case Numbe Plaintiff Name Plaintiff Name Docket Attachment Amount Docket Attachment Amount $ . 0l0 $ 0.00 ChUdnonyoNomoo): DOB Child(ren)'s Name(s): Service Type M DOB Addendum OMB No.: 0970-0154 Form EN-028 11/13 Worker ID $1ATT NASRIN GOLPOUSHAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 09-7330 CHARLES E. PAINTER, CIVIL ACTION - LAW Defendant IN DIVORCE rn • was WITHDRAWAL OF APPEARANCE cr, Kindly withdraw the appearance of Heather E. Verchick, Esquire, and Andre.,& Associates, P.C. for Plaintiff Nasrin Golpoushan in the above -captioned matter. Respectfully submitted, ANDREOZZI & ASSOCIATES, P.C. Date: 04/10/2014 By: 1fl _..: CD Heather E. Verchick, Esq ire Attorney I.D.#201310 215 Pine Street, Ste 200 Harrisburg, PA 17101 (T) 717.525.9124 (F) 717.525.9143 ENTRY OF APPEARANCE Kindly enter my appearance as counsel for Plaintiff in the above - Date: tet" matter. Bv: Cou tney Kishel P Att• ney I.D. # JSDC L.w-Off1ce. P.O. Box 650 Hershey, PA 17033 (T) 717.533.3280 (F) 717.533.2795 well, Esquire NASRIN GOLPOUSHAN, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA v. : CASE NO. 09-7330 CHARLES E. PAINTER, : CIVIL ACTION — LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Courtney Kishel Powell, Esquire, with JSDC Law Offices, attorneys for the Plaintiff, Nasrin Golpoushan, hereby certify that I have served a copy of the foregoing Withdrawal of Appearance/Entry of Appearance on the following on the date and in the manner indicated below: U.S MAIL, FIRST CLASS, PRE -PAID Gary L. Kelley, Esquire 3117 Chestnut Street Camp Hill, PA 17011 Attorney for Defendant Heather Verchick, Esquire ANDREOZZI & ASSOCIATES, P.C. 215 Pine Street, Suite 200 Harrisburg, PA 17101 , 2014 By: JSDC LAW OFFICES / Courtney Kishel ' We ---1 Attorney Pa. I. D . #:1509 P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Plaintiff, Nasrin Golpoushan NASRIN GOULPOSHAN, . Plaintiff CUMBERLAND COUNTY, PENNSYL 41Na -11 rna c `TI v. NO. 09-7330ix) r1-- •�rn r tv Po CHARLES E. PAINTER, CIVIL ACTION - DIVORCE r�—z ▪ ac) Defendant 3>c-) -v nr o- t ?ca X. )› -I ▪ CD I DEFENDANT'S RESPONSE TO PLAINTIFF'S -�, IN3 D FIRST REQUEST FOR PRODUCTION OF DOCUMENTS .4' IN THE COURT OF COMMON PLEAS AND NOW, comes the Defendant, CHARLES E. PAINTER, by and through his attorney, Gary L. Kelley, and responds to PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS and, in support thereof, respectfully responds as follows: 1 The Plaintiff has repeatedly entered the marital residence since the date of separation during the period in question and removed all documents and furniture from the residence. Moreover, the Plaintiff has been represented by at least three (3) prior attorneys and much of this information was provided to prior counsel or, is in the Plaintiff's sole possession and control as she continuously removed furniture and documents from the home. On December 15, 2008, December 27, 2008, October 14, 2009, October 18, 2009, and October 25, 2009, the Plaintiff sent taunting emails to the Defendant wherein she admitted, inter alia, to removing $100,000 from a joint account, and demanding $7,500 for the dogs she removed from the home or "the dogs are gone." Copies of these emails were provided to prior counsel by a letter dated August 12, 2013. Further, she may obtain this information as many of these returns were filed jointly. Given these facts, the Defendant objects to reconstructing these records as such would be obdurate, vexatious, and unduly burdensome. The parties recently had a four -party conference with prior counsel and these items and information were not in dispute. 2.. The Plaintiff has repeatedly entered the marital residence since the date of separation during the period in question and removed all documents and furniture from the residence. Moreover, the Plaintiff has been represented by at least three (3) prior attorneys and much of this information was provided to prior counsel or, is in the Plaintiffs sole possession and control as she continuously removed furniture and documents from the home. On December 15, 2008, December 27, 2008, October 14, 2009, October 18, 2009, and October 25, 2009, the Plaintiff sent taunting emails to the Defendant wherein she admitted, inter alia, to removing $100,000 from a joint account, and demanding $7,500 for the dogs she removed from the home or "the dogs are gone." Copies of these emails were provided to prior counsel by a letter dated August 12, 2013. Further, she may obtain this information as many of these accounts, if not all, were joint. Given these facts, the Defendant objects to reconstructing these records as such would be obdurate, vexatious, and unduly burdensome. The parties recently had a four -party conference with prior counsel and these items and information were not in dispute. 3. The Plaintiff has repeatedly entered the marital residence since the date of separation during the period in question and removed all documents and furniture from the residence. Moreover, the Plaintiff has been represented by at least three (3) prior attorneys and much of this information was provided to prior counsel or, is in the Plaintiffs sole possession and control as she continuously removed furniture and documents from the home. On December 15, 2008, December 27, 2008, October 14, 2009, October 18, 2009, and October 25, 2009, the Plaintiff sent taunting emails to the Defendant wherein she admitted, inter aiia, to removing $100,000 from a joint account, and demanding $7,500 for the dogs she removed from the home or "the dogs are gone." Copies of these emails were provided to prior counsel by a letter dated August 12, 2013. Further, she may obtain this information as many of these accounts, if not all, were joint. Given these facts, the Defendant objects to reconstructing these records as such would be obdurate, vexatious, and unduly burdensome. The parties recently had a four-party conference with prior counsel and these items and information were not in dispute. 4. The Plaintiff has repeatedly entered the marital residence since the date of separation during the period in question and removed all documents and furniture from the residence. Moreover, the Plaintiff has been represented by at least three (3) prior attorneys and much of this information was provided to prior counsel or, is in the Plaintiffs sole possession and control as she continuously removed furniture and documents from the home. On December 15, 2008, December 27, 2008, October 14, 2009, October 18, 2009, and October 25, 2009, the Plaintiff sent taunting emails to the Defendant wherein she admitted, inter alia, to removing $100,000 from a joint account, and demanding $7,500 for the dogs she removed from the home or "the dogs are gone." Copies of these emails were provided to prior counsel by a letter dated August 12, 2013. Further, she may obtain this information as many of these accounts, if not all, were joint. Given these facts, the Defendant objects to reconstructing these records as such would be obdurate, vexatious, and unduly burdensome. The parties recently had a four-party conference with prior counsel and these items and information were not in dispute. 5. The Plaintiff has repeatedly entered the marital residence since the date of separation during the period in question and removed all documents and furniture from the residence. Moreover, the Plaintiff has been represented by at least three (3) prior attorneys and much of this information was provided to prior counsel or, is in the Plaintiffs sole possession and control as she continuously removed furniture and documents from the home. On December 15, 2008, December 27, 2008, October 14, 2009, October 18, 2009, and October 25, 2009, the Plaintiff sent taunting emails to the Defendant wherein she admitted, inter alia, to removing $100,000 from a joint account, and demanding $7,500 for the dogs she removed from the home or "the dogs are gone." Copies of these emails were provided to prior counsel by a letter dated August 12, 2011 Copies of the Defendant's pension information was provided to counsel previously by letter and at a hearing for APL. During the course of the hearing, the Support Master specifically informed the Plaintiff that she would be waiving her interest in the Defendant's pension if she insisted that the payments he was receiving at the time from his pension were included as income for calculation purposes. Given these facts, the Defendant objects to reconstructing these records as such would be irrelevant for distribution purposes and obdurate, vexatious, and unduly burdensome. The parties recently had a four -party conference with prior counsel and these items and information were not in dispute. 6. The Plaintiff has repeatedly entered the marital residence since the date of separation during the period in question and removed all documents and furniture from the residence. Moreover, the Plaintiff has been represented by at least three (3) prior attorneys and much of this information was provided to prior counsel or, is in the Plaintiffs sole possession and control as she continuously removed furniture and documents from the home. On December 15, 2008, December 27, 2008, October 14, 2009, October 18, 2009, and October 25, 2009, the Plaintiff sent taunting emails to the Defendant wherein she admitted, inter alia, to removing $100,000 from a joint account, and demanding $7,500 for the dogs she removed from the home or "the dogs are gone." Copies of these emails were provided to prior counsel by a letter dated August 12, 2013. The Defendant owns the same vehicle that he had when the parties separated. It is the Plaintiff that has obtained several different vehicle during the time in question. Given these facts, the Defendant objects to reconstructing these records as such would be obdurate, vexatious, and unduly burdensome. The parties recently had a four -party conference with prior counsel and these items and information were not in dispute. 7. The Defendant has a term life insurance policy through his employer. This has never been an item of contention. 8. None. Respectfully submitted, Ga IY Kelley ID No. 46801 3117 Chestnut S Camp Hill, PA 17011 (717) 612-1484 VERIFICATION I verify that the statements made in this Response are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: NASRIN GOULPOSHAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 09-7330 CHARLES E. PAINTER, CIVIL ACTION - DIVORCE Defendant CERTIFICATE OF SERVICE I, GARY L. KELLEY, Esquire, attorney for Defendant in the above -captioned matter, do hereby certify that I served a true and correct copy of DEFENDANT'S RESPONSE TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS on Plaintiffs counsel on the 25th day of July, 2014, by First Class U.S. Mail, postage prepaid, addressed as follows: Courtney K. Powell, Esq. P.O. Box 650 Hershey, PA 17033 LAW OFFICES OF GARY L. LLEY GARY KELLEY, uire I.D. 3117 Chestnut Street Camp Hill, PA 17011 (717) 612-1484 Attorney for Defendant INCOME WITHHOLDING FOR SUPPORT {} ORIGINAL INCOME WITHHOLDING ORDER/NOTICE FOR SUPPORT (IWN O AMENDED IWO O ONE-TIMEOROER/NOTICE FOR LUMP SUM PAYMENT O TERMINATION orxwo �/U |)�[)�7 ° ` ", . / -^`. -~ ' Cc) - 133D /`1V91 Date: 07/29/14 O Child Support Enforcement (CSE) Agency Eg Court j=1 Attorney Oprivate/ndwdual/Entity(Check One) NOTE: This IWO must be regular on its face. Under certain circumstances you must reject this IWO and return it to the sender (see IWO motmcoonn»op://vmww.ocf.^hs.gov/pmgnsmn/cse/fonnsxJMe'Og7V'n154 instructions.odf. If you receive this document from someone other than a State or Tribal CSE agency or a Court, a copy of the underlying order must be attached. Commonwealth of PennsyIvana CUMBERLAND Privatemuwdual/Emity Remittance Identifier (include °/puvmenV: 9679000272 Order for order/docket information) CSE Agency Case Identifier: (See Addendum for case summary) DAUPHIN CNTY OFF OF PERSONNEL C/0 ATTN: PAYROLL POBOX 12Q5 HARRISBURG PA 17108-1295 Employer/Income Withholders FEIN 236003043 Child(ren)'oName(s)<Lunt. First, Middle) Ch|ld(m )'sBmmDaxe(s) RE: PAINTER, CHARLES E. JR Name (Last, First, MiddIe) 210-54-4987 Employee/Obligor's Social Security Number (See Addendum for plaintiffnames associated with cases on attachment) Custodial Party/Obligee's Name (Last, First, Middle) NOTE: This IVVO must be regular onits face. Under certain circumstances you must reject (his IWO and return it to the sender (see IWO instructions http:xwm*,.acf.xhms/coo/forms/ nMo'0970'0154 instructionspd. 1! you receive this document from someone other than a State or Tribal CSE agency or a Court, a copy of the underlying order must be attached, 2360030430 See Addendum for dependentmames and birth dates associated with cases on attachment. ORDER INFORMATION: This document is based on the support or withho!ding order from CUMBERLAND County, Commonwealth of Pennsylvania (State/Tribe). You are required by Iaw to deduct these amounts from the employee/ obligors income until further notice. 0.00 per month in current child support 0.00 per month in past -due child support - Arrears 12 weeks or greater? 0.00 per month in current cash medical support 0.00 per month in past -due cash medical support 1,447.00 per month in current spousasupport 0.00 per month in past -due spousal support 0.00 per month in other (must specify) for a Total Amount to Withhold of $ 1,447.00 per month. [) yes co Zrn G -J �-� �) A8VO8NT5TON*7�fHOLD: varyYou donot have hooavhoboinvvdh�ha-����k�i yourpay cyclecompliance �your pay ovc�does not n�abchthe ordered payment cycle, withhold one nfthe hd|owingamount: -(+ pw 7 $ 333.93 per weekly pay period. $ 723.50 per semimonthly pay period (twice a Month) $ 667.5per biweekly pay period (every two weeks) $ 1,447.00 per monthly pay period. $ Lump Sum Payment: Do not stop any existing IWO unless you receive a termination order. REMITTANCE INFORMATION: If the employee/obtigor's principal place of employment is within the Commonwealth of Pennsylvania (State/Tribe), you must begin withholding no later than the first pay period that occurs ten (10) workinq days after the date of this Order/Notice. Send payment within seven (7) working days of the pay date. If you cannot withhold the full amount of support for any or all orders for this employee/obligor, withhold up to 55% of disposable income for all orders. If the employee/obligor's principal place of employment is not within the Commonwealth of Pennsylvania (State/Tribe), the employer can obtain withholding |imitmbono. time nequiramanto, and any allowable employer fees at http://wwmv.aof.hhn.gov/orognoms/oae/newhine/anp|Vyor/onnteots/onntnct map. htm for the employee/obligor's principal place of employment. Document Tracking Identifier Service Type MWorker ID $1ATT OMB No.: 0970-0154 Form EN -028 11/13 ❑ Return to Sender [Completed by Employer/Income Withholder]. Payment must be directed to an SDU in accordance with 42 USC §666(b)(5) and (b)(6) or Tribal Payee (see Payments to SDU below). If payment is not directed to an SDU/Tribal Payee or this IWO is not regular on its face, you must check this box and return the IWO to the sender. Signature of Judge/Issuing Official (if required by State or Tribal la Print Name of Judge/Issuing Official: Title of Judge/Issuing Official: Date of Signature: JliL o 0 2014 If the employee/obligor works in a State or for a Tribe that is different from the State or Tribe that issued this order, a copy of this IWO must be provided to the employee/obligor. 0 If checked, the employer/income withholder must provide a copy of this form to the employee/obligor. ADDITIONAL INFORMATION FOR EMPLOYERS/INCOME WITHHOLDERS Pennsylvania law (23 PA C.S. § 4374(b)) requires remittance by an electronic payment method if an employer is ordered to withhold income from more than one employee and employs 15 or more persons, or if an employer has a history of two or more returned checks due to nonsufficient funds. Please call the Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. PA FIPS CODE 42 000 00 Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. State -specific contact and withholding information can be found on the Federal Employer Services website located at: http://www.acf.hhs.gov/programs/cse/newhire/employer/contacts/contact mao.htm Priority: Withholding for support has priority over any other legal process under State law against the same income (USC 42 §666(b)(7)). If a Federal tax levy is in effect, please notify the sender. Combining Payments: When remitting payments to an SDU or Tribal CSE agency, you may combine withheld amounts from more than one employee/obligor's income in a single payment. You must, however, separately identify each employee/ obligor's portion of the payment. Payments To SDU: You must send child support payments payable by income withholding to the appropriate SDU or to a Tribal CSE agency. If this IWO instructs you to send a payment to an entity other than an SDU (e.g., payable to the custodial party, court, or attorney), you must check the box above and return this notice to the sender. Exception: If this IWO was sent by a Court, Attorney,•or Private Individual/Entity and the initial order was entered before January 1, 1994 or the order was issued by a -Tribal CSE agency, you must follow the "Remit payment to" instructions on this form. Reporting the Pay Date: You must report the pay date when sending the payment. The pay date is the date on which the amount was withheld from the employee/obligor's wages. You must comply with the law of the State (or Tribal law if applicable) bf the employee/obligor's principal place of employment regarding time periods within which you must implement the withholding and forward the support payments. Multiple IWOs: If there is more than one IWO against this employee/obligor and you are unable to fully honor all IWOs due to Federal, State, or Tribal withholding limits, you must honor all IWOs to the greatest extent possible, giving priority to current support before payment of any past -due support. Follow the State or Tribal law/procedure of the employee/obligor's principal place of employment to determine the appropriate allocation method. Lump Sum•Payments: You may be required to notify a State or Tribal CSE agency of upcoming lump sum payments to this employee/obligor such as bonuses, commissions, or severance pay. Contact the sender to determine if you are required to report and/or withhold lump sum payments. Liability: If you have any doubts about the validity of this IWO, contact the sender. If you fail to withhold income from the employee/obligor's income as the IWO directs, you are liable for both the accumulated amount you should have withheld and any penalties set by State or Tribal law/procedure. Anti -discrimination: You are subject to a fine determined under State or Tribal law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against an employee/obligor because of this IWO. OMB Expiration Date — 05/31/2014. The OMB Expiration Date has no bearing on the termination date of the IWO; it identifies the version of the form currently in use. Form EN -028 11/13 Service Type M Page 2 of 3 Worker ID $IATT Employer's Name: DAUPHIN CNTY OFF OF PERSONNEL Employer FEIN: 236003043 Employnn/}b(igo/oName: PANTER, CHARLES E. JR 0679000272 C8EAgenoyCono)dentifier:(8peAddmndumybrcaaesu/nnmary) Ovder\donUfioc(SweAmdendumnfor ordeodockor/nfbnnadon) Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (CCPA) (15 U.S.C. 1 673(b)); or 2) the amounts ailowed by the State or Tribe of the employee/obligor's principal place of employment (see REMITTANCE INFORMATION). Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; statutory pension contributions; and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is supporting another family and 60% of the disposable income if the obligor is not supporting another family. However, those limits increase 5% - to 55% and 65% - if the arrears are greater than 12 weeks. If permitted by the State or Tribe, you may deduct a fee for administrative costs. The combined support amount and fee may not exceed the limit indicated in this section. For TribaI orders, you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal withholders who receive a State IWO, you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which the employer/income withholder is located or the maximum amount permitted under section 303(d) of the CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State or Tribal law, you may need to also consider the amounts paid for health care premiums in determining disposabe income and appiying appropriate withholding limits. Arrears greater than 12 weeks? If the Order Information does not indicate thatthatthe arrears are greaterthan 12 weeks, then the Employer should catcuiate the CCPA limit using the lower percentage. Additional Information: NOTIFICATION OF EMPLOYMENT TERMINATION OR INCOME STATUSIf this employee/obligornovorwmrkodhuryouoryouara no longer withholding income for this employee/obligor, an employer must promptly notify the CSE agency and/or the sender by returning this forrn to the address Iisted in the Contact Information below: 2360030430 0 This person has never worked for this employer nor received periodic income. L} This person nolonger works for this employer nor receives periodic income. Please provide the foliowing information for the employee/obligor: Termination date: Last known phone number: Last known address: Final Payment Date To SDU/Tribal PayeeFinat Payment Amount: New Employer's Name: New Employer's Address: CONTACT INFORMATION: To Employer/Income Withholder: If you have any questions, contact WAGE ATTACHMENT UNIT (Issuer name) byphone at(717)240'G225.byfax nt(717)240'8248.byemail orwebsite at: vm^wv.ch|kjnuppmrtstahe.oa.uo. Send termination/income status notice and other correspondence to: DOMESTIC RELATIONS SECTION, 13 N. HANOVER ST. P.O. BOX 320, CARLISLE. PA. 17013 (Issuer address). To Employee/Obligor: If the employee/obligor has questions, contact WAGE ATTACHMENT UNIT (Issuer name) by phone at (717) 240-6225, by fax at (717) 240-6248, by email or website at www.childsupportstate.oa.us. IMPORTANT: The person completing this form is advised that the information may be shared with the employee/ob!igor. OMB 0970-0154 Service Type M Page 3 of 3 Form EN -028 11/13 Worker ID $IATT ADDENDUM Summary of Cases on Attachment DefendantlObligor: PAINTER, CHARLES E. JR PACSES Case Number 246113057 PACSES Case Number Plaintiff Name Plaintiff Name NASRIN GOLPOUSHAN Docket Attachment Amount Docket Attachment Amount 09-7330 CIVIL $ 1,447.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB PACSES Case Number PACSES Case Number Plaintiff Name Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACSES Case Number PACSES Case Number Plaintiff Name Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Service Type M Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Addendum OMB No.: 0970-0154 Form EN -028 11/13 Worker ID $IATT Courtney K. Powell, Esquire Attorney Pa. I.D. #81509 E-mail: ckpAsdc.com JSDC Law Offices P. O. Box 650 Hershey, PA 17033 • Telephone: (717) 533-3280 {2 all- y_ p�E''y**"r,J ARO. :.fir gg�F,E V�,./( ;:/E ARL! CO'W h Y ENNS1 ,r, F'I.i Attorneys for Plaintiff/Petitioner, Nasrin Golpoushan NASRIN GOLPOUSHAN, : IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner, : CUMBERLAND COUNTY, PENNSYLVANIA v. : CASE NO. 09-7330 CHARLES E. PAINTER, : CIVIL ACTION — LAW Defendant/Respondent. : IN DIVORCE PLAINTIFF'S MOTION TO COMPEL RESPONSES TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS, MOTION TO STRIKE DEFENDANT'S RESPONSE TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS, AND PLAINTIFF'S REQUEST FOR SANCTIONS AND NOW, comes the Plaintiff/Petitioner, Nasrin Golpoushan, by and through her counsel, Courtney K. Powell, Esquire, with JSDC Law Offices, and files the within Motion to Compel Responses to Plaintiff's First Request for Production of Documents, Motion to Strike Defendant's Response to Plaintiff's First Request for Production of Documents and Plaintiff's Request for Sanctions, and in support thereof, states the following: 1. The Petitioner is Nasrin Golpoushan, Plaintiff in the above -captioned divorce action, (hereinafter referred to as "Wife"). 2. The Respondent is Charles E. Painter, Defendant in the above -captioned divorce action, (hereinafter referred to as "Husband"). 3. On October 25, 2009, Wife filed a Complaint for Divorce under Sections 3301(c) and 3301(d) and raised counts for Equitable Distribution, Alimony, and Alimony Pendente Lite, Counsel Fees and Expenses. 4. When Wife filed for divorce, she was represented by Mark T. Silliker, Esquire. Thereafter, Wife was represented by Marianne E. Rudebusch, Esquire, and Heather Verchick, Esquire. 5. The undersigned legal counsel entered her appearance on behalf of Wife on May 15, 2014. MOTION TO COMPEL DISCOVERY 6. Averments one (1) through five (5) are incorporated herein by referenced. 7. On Thursday, June 5, 2014, undersigned counsel served Plaintiff's First Request for Production of Documents to Husband via his counsel, Gary L. Kelley, Esquire. A true and correct copy of the Request for Production of Documents is attached hereto and marked as "Exhibit "A." 8. Husband's answers to the Request for Production of Documents were due on or before July 7, 2014; however, Husband failed to produce the same. 9. On Tuesday, July 15, 2014, the undersigned counsel sent a letter to Attorney Kelley, advising that the discovery responses were overdue and requesting responses no later than Monday, July 28, 2014. A copy of said correspondence is attached hereto and marked as Exhibit "B." 10. On Tuesday, July 22, 2014, the undersigned counsel received a voicemail message from Attorney Kelley advising that the discovery materials requested were previously exchanged with prior counsel. 11. On that same day, the undersigned counsel faxed a letter to Attorney Kelley memorializing the voicemail message he left for the undersigned, and advising him that prior counsel's file did not contain the information requested in discovery. The letter requested a copy of the correspondence showing that the discovery materials were previously supplied or to produce the answers to the current discovery requests by July 28, 2014. A copy of said correspondence is attached hereto and marked as Exhibit "C." 12. On Monday, July 28, 2014, the undersigned counsel received Husband's Responses to Plaintiff's First Request for Production of Documents. A copy of said responses are attached hereto and marked as Exhibit "D." 13. Husband did not provide any documents requested, and failed to respond to the discovery requests in accordance with PA.R.Civ.P. 4009.12, in that: a. Pa.R.Civ.P. 4009.12 requires that the objections be made within thirty (30) days. As Husband's responses in the form of objections were not timely, and as such Husband must be compelled to supply the discovery requested. b. Pa.R.Civ.P. 4009.12 requires the responding party produce or make available the information requested, if there is no objection. Husband failed to produce any documentation or make it available for review; c. Pa.R.Civ.P. 4009.12 requires the documentation to identify with reasonable particularity those documents not being produced, along with a reason why they are not being produced. Husband failed to do this. d. Pa.R.Civ.P. 4009.12 requires the answers to be signed and verified by both the party and the party's attorney. The answers were only verified by counsel. 14. Husband's responses in part, asserted that the documents were in Wife's control, which is false. Wife does not have the ability to obtain copies of Husband's individual tax returns, retirement information, brokerage accounts, or Social Security Administration earnings history report. 15. Husband also asserts that Wife is a joint owner for the accounts requested. It is acknowledged that Wife is the joint owner of one bank account; however, it remains unclear from the responses provided whether Husband has any other accounts, and if so, Wife does not have access to any of that information. Moreover, Wife does not have copies of joint tax returns as filed, and needs Husband's assistance in obtaining copies of the same. 16. Husband also maintains that he previously provided the requested material to Wife's prior counsel, although he fails to specifically identify the attorney he submitted them to. 17. Undersigned counsel contacted Mark T. Silliker, Esquire, who first represented Wife. Attorney Silliker advised that the only information he received was in 2010 regarding Husband's pension. No other financial information was supplied to Attorney Silliker. 18. Undersigned counsel also contacted Attorney Rudebusch, who represented Wife from December 2011 through February 2013. The limited financial information she was given, and which she supplied to the undersigned counsel, pertained to Husband's income and wage information in 2011. This information was not requested in Plaintiff's First Request for Production of Documents requests. 19. Additionally, undersigned counsel contacted Heather Verchick Esquire, who represented the Wife from February 2013 through April 2014. She served Husband with Interrogatories and Request for Production of Documents on August 8, 2013. On August 12, 2013, Attorney Kelley wrote to Attorney Verchick requesting that she withdraw her discovery requests, and consider a four -party conference, or he would also serve her with a set of Interrogatories and Request for Admissions. Husband failed to provide any financial information in response to the discovery requests sent by Attorney Verchick. A true and correct copy of these correspondences are attached hereto and marked as Exhibit "E." 20. Husband has failed to provide the documentation requested in Plaintiff's First Request for Production of Documents submitted on June 5, 2014, and on August 8, 2013, and the parties have now been separated for over four (4) years. It is believed and therefore averred that a Court Order is required to compel Husband to produce answers to all of the discovery requested to date, so that the divorce can be finalized. WHEREFORE, for the foregoing reasons, Wife respectfully requests this Court order Husband to produce answers to the discovery requests sent on August 8, 2013 and on June 5, 2014 within ten (10) days. MOTION TO STRIKE DEFENDANT'S RESPONSE TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS 21. Averments one (1) through twenty (20) are incorporated herein by reference. 22. Husband's responses to Wife's First Request for Production of Documents do not adequately respond to the discovery requests. 23. Husband's response to Wife's First Request for Production of Documents serve no legitimate purpose, disparages Wife and alleges conduct that is not relevant to the within action. 24. Husband's counsel filed Defendant's Response to Plaintiff's First Request for Production of Documents, which was improper and unnecessary. WHEREFORE for the foregoing reasons, Wife respectfully requests that this Court strike Husband's responses to her First Request for Production of Documents. MOTION FOR SANCTIONS IN THE FORM OF COUNSEL FEES 25. Averments one (1) through twenty-four (24) are incorporated herein by reference. 26. Wife, through her attorneys, has submitted discovery requests for Husband to complete on at least two occasions, and Husband has failed to answer the same. 27. The discovery is necessary in order to finalize the divorce. 28. Husband has had sufficient time in which to provide his discovery responses. 29. Husband's failure to timely and thoroughly respond to Wife's discovery requests has caused Wife to incur unnecessary counsel fees, which she cannot afford to pay. 30. Wife will continue to incur counsel fees, costs and expenses in attending a conference and/or having a hearing on the within petition. 31. Wife should not have to pay unnecessary attorneys fees to compel Husband to comply with the discovery requests. 32. As a direct result of Husband's failure to comply with the discovery requests, Wife has incurred at least $500.00 in attorney's fees with the undersigned, and will incur attorney's fees until the discovery documents are produced. Wife may have also incurred attorneys' fees with her prior attorneys; however, that amount is not known. 33. Husband's conduct is vexations, obdurate, and dilatory. 34. Pursuant to 42 Pa.C.S. §2503, a party may receive counsel fees as a sanction for conduct which is vexatious, obdurate, or dilatory. 35. Wife requests that this Court impose sanctions on Husband and require him to pay for Wife's counsel fees, costs and expenses incurred as a direct result of Husband's failure to timely respond to Wife's discovery requests. 36. Pursuant to C.C.R.P. No. 208.2(d), it is believed that Husband's counsel does not concur in this Petition. Undersigned counsel attempted to resolve the discovery dispute in a letter dated July 22, 2014; however, the requested documents were not provided. 37. Pursuant to C.C.R.P. No. 208.3 no judge has previously ruled upon any matter relating to this case. WHEREFORE, the Plaintiff/Petitioner, Nasrin Golpoushan, respectfully requests this Court to enter an Order as follows: - a. order Husband to provide the requested documentation within ten (10) days; b. direct the Prothonotary to strike Husband's Responses to Plaintiff's First Request for Production of Documents from the court docket; Dated: c. direct Husband, Charles E. Painter, to pay Wife's counsel fees, costs and expenses that she has incurred as a direct result of Husband's failure to act; and d. grant any other appropriate relief. °(, ` \11\ , 2014 By: Respectfully submitted, JSDC LAW OFFICES Courtney K. Po , Esquire Attorney Pa. I.D. :1509 P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Plaintiff/Petitioner, Nasrin Golpoushan Exhibit "A" I- ., l' .) 1 1 Id- I S J ( JSDC LAW OffICFS JAMES • SMITH • DIEITERIcK • CONNELLY • SPADE • CHABAL • YAHN • SEEBER • TOMASKO June 5, 2014 Gary L. Kelley, Esquire 3117 Chestnut Street Camp Hill, PA 17011 Re: Nasrin Golpoushan v. Charles E. Painter Cumberland County Docket No. 09-7330 Dear Gary: Courtney Kishel Powell E-mail: ckp@jsdc.com DIRECT FAX 717.298.2025 I have had the opportunity to review Attorney Verchick's file in the above- referenced matter, and need additional information from your client before you and I can proceed in any meaningful discussions. I have enclosed Request for Production of Documents for your client to answer. Please submit your client's responses within the requisite thirty (30) days so that I can finalize my review of the parties' marital estate. I am hopeful that once I review this additional information, you and I can proceed in settlement discussions. If you have any questions concerning this matter, please feel free to contact me at the telephone number listed above. CKP:dej Enclosure cc: Nasrin Golpoushan (w/enc.) Very truly yours, P.O. Box 850 HERSHEY, PA 17033 MAIN OFFICE: 134 SIPE AVENUE HUMMELSTOWN, PA 17036 WEST SHORE LOCATION: 555 GETTYSBURG PIKE SUrrE C400 MECHANICSBURG, PA 17055 TEL 717.533.3280 WWW.JSDC.COM GARY L JAMES MA)( J. SMrrH, JR. JOHN J. CONNELLY, JR. SCOTT A. DIE I I CHICK JAMES F. SPADE MATTHEW-CHABAL, III NEIL W. YARN EDWARD P. SEEBER RONALD T. TOMASKO SUSAN M. KADEL COURTNEY K. POWELL KAREN N. CONNELLY CHRISTINE T. BRANN JESSICA E. LOWE GREGORY A. KOGUT, JR. TERESA M. REIFSW'DER JAMES D. YOUNG CAYLA B. JAKUBOwnTZ ALEXIS M. MILOSZEWSKI KATHRYN L. MASON OF COUNSEL: GREGORY K. RICHARDS KIMBERLY A. BONNER RALPH M. SALVIA ANDREW H. BRIGGS JANA FRIDFINNSDOT IR NASRIN GOLPOUSHAN, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA v. : CASE NO. 09-7330 CHARLES E. PAINTER, : CIVIL ACTION — LAW Defendant : IN DIVORCE PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO: Charles E. Painter, Defendant C/O Gary L. Kelley, Esquire 3117 Chestnut Street Camp Hill, PA 17011 Plaintiff, Nasrin Golpoushan, by her undersigned counsel, hereby propounds the following request for production of documents and tangible, things pursuant to the Pennsylvania Rules of Civil Procedure. The documents and tangible things requested herein must be produced at the JSDC Law Offices within thirty (30) days. INSTRUCTIONS AND DEFINITIONS Each of the following requests is intended as a separate request. Where a request has subparts, please respond to each subpart separately and in full. Do not limit any response to the numbered request as a whole. r If you have any objection to any request, please state your objection fully and set forth the factual basis for your objection in lieu of production of the documents. You must file and serve a written response to these requests within thirty (30) days of service of these requests upon you, regardless of the time set for production of the documents and things requested herein. You are reminded that any objections not raised within the thirty (30) day period provided for by the Rules of Court will be deemed to have been waived by you. These requests are not only for documents and tangible things that are owned by you, but also for documents and tangible things that are in your possession, custody, or control. This means that you must produce all documents and tangible things that are responsive to a particular request and that are in your possession (regardless of whether they are your property), or over which you have control even if they are not in your possession. It also means you must produce documents and tangible things that are in the possession, custody, or control of your agents, employees, and/or attorneys. Before responding to these requests you are required to make a diligent search of your files and records to ascertain whether you have documents that would be responsive to a given request. Your agents, employees, and attorneys must do the same. To avoid any possibility of confusion with respect to these requests, please note that the following terms have the following meanings in these requests, unless a particular request clearly indicates otherwise: "You" or "your" refer to the person to whom these requests have been addressed. "Person" means any natural person, corporation, unincorporated association, trust, partnership, and/or any other legally cognizable entity. It is contemplated that any corporation or other business entity .acts only through its agents, officers, employees, and attorneys, and requests that apply to any such legal entity should be construed accordingly. "Plaintiff means the particular plaintiff or plaintiffs in this section to whom this request is addressed, as set forth above. "Defendant" means the defendant or defendants named in this action. "Document", "record", "file", and "report" all refer to and contemplate all written, recorded, or graphic information, whether preserved in writing, on magnetic tape, by electronic means, in photographic form, on microfilm or microfiche, computer disc, or by any other means of information retrieval or storage. DOCUMENTS TO BE PRODUCED Please produce at the JSDC Law Offices, counsel for Plaintiff, located at 134 Sipe Avenue, Hummelstown, Pennsylvania, 17036, within thirty (30) days of the date of this Request, • . the following documents: . Complete copies of your federal and state income tax returns as filed, and all supporting documentation used to prepare the return, including but not limited to all 1099's, 1098's, W -2's, K -1's, schedules, and worksheets for the tax years of 2008 through 2013. RESPONSE: 2. Copies of the monthly statements for any and all bank accounts in which you have an interest, whether individually or with another, or in which you have deposited funds, including but not limited to checking accounts, savings accounts, money market accounts, certificates of deposits, from. January 1, 2008, through to the date in which you answer these requests. Please include copies of cancelled checks or check registers for each checking account during this time frame. RESPONSE: 5. Copies of all monthly/quarterly/annual statements relating to any individual retirement account, 401(K), pension, profit sharing plan, savings plan, KEOGH, annuity benefits, retirement plan, deferred compensation plan, stock bonus plan, stock option plan, thrift plan or any other retirement benefit in which you have or had an interest or which is/was held for your benefit from January 1, 2008, through the date in which you answer these requests. For each plan that existed at the time of marriage, please provide documentation showing the value of said plan on that date as well. RESPONSE: 6. Copies of the Kelley Blue Book Value for each vehicle you have in an ownership interest in from January 1, 2008, through to the date in which you answer these requests, except that if any vehicle was traded in, sold or otherwise disposed of, provide documentation showing the value of the compensation you received for said vehicle. RESPONSE: 7. Copies of any statements relating to all life insurance policies and/or annuities in which • you are the beneficiary, the owner or the payor, or the insured, including the identity of all beneficiaries for each policy that existed from January 1, 2008, through the date in which you respond to these requests. RESPONSE: 8. Copies of any severance package that you have or have had with your employers fro January 1, 2012, through to the present. RESPONSE: 9. Copies of your most recent statement issued by the Social Security Administration showing your Estimated Benefits and Earnings History. RESPONSE: Dated: , 2014 By: Respectfully submitted, JSDC Law Offices Courtney Kishel we 1, Esquire Attorney LD. #8 P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Plaintiff Nasrin Golpoushan NASRIN GOLPOUSHAN, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA v. : CASE NO. 09-7330 CHARLES E. PAINTER, : CIVIL ACTION — LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Courtney Kishel Powell, Esquire, with JSDC Law Offices, attorneys for the Plaintiff, Nasrin Golpoushan, hereby certify that I have served a copy of Plaintiff's First Request for Production ofDocuments on the following, on the date and in the manner indicated below: Date: U.S. MAIL, FIRST CLASS, PRE -PAID Gary L. Kelley, Esquire 3117 Chestnut Street Camp Hill, PA 17011 Attorneys for Defendant JSDC LAW OFFICES Courtney Kishet owell, Esqui e Attorney PA I. 81509 Post Office Box e 0 Hershey, PA 17033 (717) 533-3280 Attorneys for Plaintiff; Nasrin Golpoushan Exhibi «B» O 1 I C F S J ) JSDC Law OFFICES JAMES • SMITH • DIErrERICK • CONNELLY • SPADE • C HABAL • YAM • SEEBER • TOMASKO July 15, 2014 Gary L. Kelley, Esquire 3117 Chestnut Street Camp Hill, PA 17011 Re: Nasrin Golpoushan v. Charles E. Painter Cumberland County Docket No. 09-7330 Dear Gary: Courtney Kishel Powell E-mail: clp@jsdc.com DIRECT FAX 717.298.2025 As you know, on June 5, 2014, I sent Requests for Production of Documents to you on the above -referenced matter. Your client's responses were due on July 7, 2014. To date, I have not received .any responses from you, and the documents are necessary in order to finalize the divorce. Kindly forward your client's responses to my discovery requests no later than Monday, July 28, 2014, or I will have no other choice but to file a Motion with the Court. I hope that will not be necessary. CKP:dej cc: Nasrin Golpoushan P.O. Box 650 HERSHEY, PA 170: MAIN OFFICE: 134 SPE AVENUE HuMMasrowN, PA 17( WEST SHORE L0C4710 555 GE rryseuRG PKE SUITE C400 MECHANICSBURG, PA 17 TEL 717.533.328( WWW.JSDC.COM GARY L JAMES MAx J. SMITH, JR. JOHN J. CONNELLY, JR. SCorr A. DIErrERICK JAMEs E. SPADE MATTHEW CHABAL, III NEIL W. YARN ammo P. SEEBER RONALD T. TOMASKO SUSAN M. KADa COURTNEY K. POWELL KAREN N. CONNELLY CHRISTINE T. BRANN JESSICA E. LowE GREGORY A. KOGui, JR. TERESA M. REIFSNYOEB JAMES D. YouNG CAYLA B. JAKUBOI^mz ALEXIS M. MILOSZEwsro KATHRYN L. MASON OF COUNSEL: GREGORY K. RICHaRDs KIMBERLY A BONNER RALPH M. SALVIA ANDREW H. BRIGGS JANA FRIDFINNSDOTTIR Exhibit "C" A 1V (1 1- I I( I S JSDC LAW OFFICES JAMES • SMITH • DIEITERIcK • CONNELLY • SPADE • CHABAL • YAHN • SEEBER • TOMASKO July 22, 2014 Via Facsimile No. 717-612-1761 And Rejiular U.S. Mail Gary L. Kelley, Esquire 3117 Chestnut Street Camp Hill, PA 17011 Re: Nasrin Golpoushan v. Charles E. Painter Cumberland County Docket No. 09-7330 Dear Gary: Courtney Kishel Powell E-mail: cicp@jsdc.com DIItECT FAX 717.298.2025 Please allow this letter to memorialize the voicemail message that I left for you this afternoon. I received your voicemail message from this morning concerning my discovery requests. Although you advised that discovery was previously exchanged with prior counsel, I have Attorney Verchick's file and it appears that your client failed to provide responses to her discovery requests. My client does not have the information that I have requested, so I am asking for your client to provide the same to me. If you have previously supplied this information to Attorney Verchick, please forward me a copy of that correspondence with the answers to her discovery requests, and I will be happy to review them and amend my discovery requests accordingly. If your client has not provided discovery previously, please have them completed and submitted to my office by Monday, July 28, 2014. Your attention to this matter is appreciated. CKP:dej cc: Nasrin Golpoushan Very truly yours, Courtney K. Pow P.O. Box 650 HERSHEY, PA 17033 MAN OFFICE: 134 SIRE AVENUE HUMMB.STOWN, PA 17036 WEST SHORE LOCATION' 555 GETTYSBURG PIVE SurTE C400 MECHANiaBURG, PA 1705 TEL 717.533.3280 WWW.JSDC.COM GAN L JAMES MAX J. SMITH, JR. JOHN J. CONNELLY, JR. Sam -A DEI ERICK JAMES F. SPADE MATtHEW CHA3AL, t0 NEL W. YARN EDWAO P. SEEBER RONAn T. TOMASKo SUSAN M. KADEL COURTNEY K. PoWaL KAREN N. CONNEUY CHRISTINE T. BRANN JESSICA E. LOWE GREGORY A. KOGur, JR. TEHESA M. REIFSNYDER JAMES D. YOUNG CAYLA B. JAKueownZ A Das M. MILOsZEwsw KATHRYN L MASON OF Cotmsa: GREGORY K. RICHARDS KIMBERLY A. BONNER RALPH M. SALVIA ANDREW H. BRIGGS JANA FRIDFINNSDOTITR **MAOI*********** —COMM. JOURNAL— *k************ DATE JUL-21-2014 ***** TIME 16:57 ***am*** MODE = MEMORY TRANSMISSION FILE NO.=015 STN NO. COMM. ABER NO. STATION NAME/TEL NO. PAGES DURATION START=JUL-21 16:56 END=JUL-21 16:57 • J..).( 6121761 LJ 001/001 00:00:30 —WWW JSDC COM AW OFF ICES— jJI C LAW OFFICES JAM • Slvani • DIVEERI x • e tLY • SPADE • O -L BAL • YAH1r i • SEEDER • RNA= Courtney Kiehl Powell E mail: ekora7isde.eom DIRECT FAX 7172985025 July 22, 2014 Via Facsimile No, 717-612-176, 4lnd Regular (LS. Mail Gary L. Kelley, Esquire 3117 Chestnut Street Camp Hill, PA 17011 Re: Nasrin Golpoushan v. Charles E. Painter Cumberland County Docket No. 09-7330 Dear Gary: Please allow this letter to memorialize the voicemail message that I left for you this afternoon. I received your voicemail message from this morning concerning my discovery requests. Although you advised that discovery was previously exchanged with prior counsel, I have Attorney Verchick's file and it appears that your client failed to provide responses to her discovery requests. My client does not have the information that I have requested, so 1 am asking for your client to provide the same to me. if you have previously supplied this information to Attorney Verchick, please forward me a copy of that correspondence with the answers to her discovery requests, and I will be happy to review them and amend my discovery requests accordingly, If your client has not provided discovery previously, please have them completed and submitted to my office by Monday, July 28, 2014. Your attention to this matter is appreciated. Very truly yours, CKP:dej cc: Nasrin Golpoushan Courtney K. Pow P.O. BOX 65O•, HERSHEY, PA 17033 MAN O. . 134 SIT AW+1[ Huuntrugorm,8417038 555 GErrnsoG Fla sere CA00 F TEL 717533.9280 www4soo.com (INN L J'M15 Ku J. Brn1, JL JOHN J. COMB n. Jft SOOTY k DErninOit JAWS F. &v,oa YNN £171allo P. SEMI RpuW T.700.1. ssw+M Kota. CaJnT,E4 K PoNal KNEN N. meal, tywone T. afwN JLsscc £. Lone OWCORY A K0317. JA 11:PE3n Mt FE48J1 ER J,w53 0. YwNa C.ru D. JMabourz .ILma M. ransoms; KAnf7IN (• M49RN Exhibit "D" NASRIN GOULPOSHAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA, c, c ez• -r; z Pi z cnr"- rn ---4 c) .§.• C" ":0 -1.1 DEFENDANT'S RESPONSE TO PLAINTIFF'S • • rr; FIRST REQUEST FOR PRODUCTION OF DOCUMENTS v. CHARLES E. PAINTER, Defendant NO. 09-7330 CIVIL ACTION - DIVORCE AND NOW, co.mes the Defendant, CHARLES E. PAINTER, by and through his attorney, Gary L. Kelley, and responds to PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS and, iri support thereof, respectfully responds as follows: 1. The Plaintiff has repeatedly entered the marital residence since the date of separation during the period in question and removed all documents and furniture from the residence. Moreover, the Plaintiff has been represented by at least three (3) prior attorneys and much of this information was provided to prior counsel or, is in the Plaintiffs sole possession and control as she continuously removed furniture and documents from the home. On December 15, 2008, December 27, 2008, October 14, 2009, October 18, 2009, arid October 25, 2009, the Plaintiff sent taunting emails to the Defendant wherein she admitted, inter alia, to removing $100,000 from a joint account, and demanding $7,500 for the dogs she removed from the home or "the dogs are gone." Copies of these emails were provided to prior counsel by a letter dated August 12, 2013. Further, she may obtainthis information as many of these returns were filed jointly. Given these facts, the Defendant objects to reconstructing these records as such would be obdurate, vexatious, and unduly burdensome. The parties recently had a four -party conference with prior counsel and these items and information were not in dispute. 2.. The Plaintiff has repeatedly entered the marital :residence since the date of separation during the period in question and removed all documents and furniture from the residence. Moreover, the Plaintiff has been represented by at least three ) pr 0 attorneys and much of this information was provided to prior counsel or, is in the Plaintiffs sole possession and control as she continuously removed furniture and documents from the home. On December 15, 2008, December 27, 2008, October 14, 2009, October 18, 2009,' and October 2-5; 2-009,—the- Plaintiff sent taunting emails to the Defendant wherein she admitted. inter alia, to removing $100,000 from a joint account, and demanding $7,500 for the dogs she removed from the home or "the dogs are gone." Copies of these emails were provided to prior counsel by a letter dated August 12, 2013. Further, she may obtain this information as many of these accounts, if not all, were joint. Given these facts, the Defendant objects to reconstructing these records as such would be obdurate, vexatious, and unduly burdensome. The parties recently had a four -party conference with prior counsel and these items and information were not in dispute. 3. The Plaintiff has repeatedly entered the marital residence since the date of separation during the period in question and removed all documents and furniture from the residence. Moreover, the Plaintiff has been represented by at least three (3) prior attorneys and much of this information was provided to prior counsel or, is in the Plaintiffs sole possession and control as she continuously removed furniture and documents from the home. On December 15, 2008, December 27, 2008, October 14, 2009, October 18, 2009, and October 25, 2009, the Plaintiff sent taunting emails to the Defendant wherein she admitted, inter alia, to removing $100,000 from a joint account, and demanding $7,500 for the dogs she removed from the home or "the dogs are gone." Copies of these emails were provided to prior counsel by a letter dated August 12, 2013. Further, she may obtain this information as many of these accounts, if not all, were joint. Given these facts, the Defendant objects to reconstructing these records as such would be obdurate, vexatious, and unduly burdensome. The parties recently had a four -party conference with prior counsel and these items and information were not in dispute. 4. The Plaintiff has repeatedly entered the marital residence since the date of separation during the period in question and removed all documents and furniture from the residence. Moreover, the Plaintiff has been represented by at least three (3) prior attorneys and much of this information was provided to prior counsel or, is in the Plaintiffs sole possession and control as she continuously removed furniture and documents from the home. On December 15, 2008, 'December 27, 2008, October 14, 2009, October 18, 2009, and October 25, 2009, the Plaintiff sent taunting emails to the Defendant wherein she admitted, inter alia, to removing $100,000 from a joint account, and demanding $7,500 for the dogs she removed from the home or "the dogs are gone." Copies of these emails were provided to prior counsel by a letter dated August 12, 2013. Further, she may obtain this information as many of these accounts, if not all, were joint. Given these facts, the Defendant objects to reconstructing these records as such would be obdurate, vexatious, and unduly burdensome. The parties recently had a four -party conference with prior counsel and these items and information were not in dispute. 5. The Plaintiff has repeatedly entered the marital residence since the date of separation during the period in question and removed all documents and furniture from the residence. Moreover, the Plaintiff has been represented by at least three (3) prior atiorneys and much of this information was provided to prior counsel or, is in the Plaintiffs sole possession and control as she continuously removed furniture and documents from the home. On December 15, 2008, December 27, 2008, October 14, 2009, October 18, 2009, and October 25, 2009, the Plaintiff sent taunting emails to the Defendant wherein she admitted, inter alia, to removing $100,000 from a joint account, and demanding $7,500 for the dogs she removed from the home or "the dogs are gone." Copies of these emails were provided to prior counsel by a letter dated August 12, 2013. Copies of the Defendant's pension information was provided to counsel previously by letter and at a hearing for APL. During the course of the hearing, the Support Master specifically informed the Plaintiff that she would be waiving her interest in the Defendant's pension if she insisted that the payments he was receiving at the time from his pension were included as income for calculation purposes. Given these facts, the Defendant objects to reconstructing these records as such would be irrelevant for distribution purposes and obdurate, vexatious, -and unduly burdensome. The parties recently had a four-party conference with prior counsel and these items and information were not in dispute. 6. The Plaintiff has repeatedly entered the marital residence since the date of separation during the period in question and removed all documents and furniture from the residence. Moreover, the Plaintiff has been represented by at least three (3) prior attorneys and much of this information was provided to prior counsel or, is in the Plaintiffs sole possession and control as she continuously removed furniture and documents from the home. On December 15, 2008, December 27, 2008, October 14, 2009, October 18, 2009, and October 25, 2009, the Plaintiff sent taunting emails to the Defendant wherein she admitted, inter ajig, to rernoving $100,000 from ajoint account, and demanding $7,500 for the dogs she removed from the home or "the dogs are gone." Copies of these emails were provided to prior counsel by a letter dated August 12, 2013, The Defendant owns the same vehicle that he had when the parties separated.. It is the Plaintiff that has obtained several different vehicle during the time in question. Given these facts, the Defendant objects to reconstructing these records as such would be obdurate, vexatious, and unduly burdensome. The parties recently had a four-party conference with prior counsel and these items and information were not in dispute. 7. The Defendant has a term life insurance policy through his employer. This has never been an item of contention. 8 None. Respectfully submitted, Ga Kelley ID No, 46801 3117 Chestnut S Camp Hill, PA 17011 (717) 612-1484 VERIFICATION verify that the statements made in this Response are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904. relating to unsworn falsification to authorities. Date: NASRIN GOULPOSHAN, Plaintiff v. CHARLES E. PAINTER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-7330 CIVIL ACTION - DIVORCE CERTIFICATE OF SERVICE I, GARY L. KELLEY, Esquire, attorney for Defendant in the above -captioned matter, do hereby certify that I served a true and correct copy of DEFENDANT'S RESPONSE TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS on Plaintiff's counsel on the 25th day of July, 2014, by First Class U.S. Mail, postage prepaid, addressed as follows: Courtney K. Powell, Esq. P.O. Box 650 Hershey, PA 17033 LAW OFFICESOF GARY LLEY GARY KELLEY, I.D. #4 3117 Chestnut Street Camp Hill, PA 17011 (717) 612-1484 Attorney for Defendant Exhibit "E" ANDREOZZI & ASSOCIATES, P.0 ATTORNEYS AT LAW August 8, 2013 Gary L. Kelley, Esquire 3 -H7 -Chestnut Street Camp Hill, Pa 17011 RE: Golpoushan v. Painter, No. 09-7330 Dear Attorney Kelley: BENJAMIN D. ANDREOZZI Member Multi -Million Dollar Advocates Forum HEATHER VERCHICK Enclosed, please find our Interrogatories and Request for Production of Documents directed towards your client, Charles Painter. Please provide responses no later than September 9, 2013. Thank you for your attention to this matter. Sincerely, qlf Heather E. Verchick 215 Pine Street, Suite 200 • Harrisburg, PA 17101 P: 717.525.9124 F: 717.525.9143 www.midstatelaw.com AUG -12--2013.14:21 FROM:GARY L KELLEY 's+ Heather E. Verchick, Esq. 215 Pine Street, Suite 200 Harrisburg, PA 17101 7176121761 T0:5259143 Law Officrs of Gary L. Kelley 1119 North Front Street Harrisburg, Pennsylvania 17102 (717) 238-1484 Fax (717) 238-1761 August 12, 2013 BY FACSIMILE TRANSMISSION ONLY TO (717) 525-9143 lie Golpoushan v Painter Dear Heather Please find enclosed a series of-emails from your client to my client. They are dated December 15, 2008, December 27, 2008,. October 14, 2009, October 18, 2009, and November 25, 2009 In them, you will read, inter -alis, that she admitted to having an affair, that she is a liar and can't be trusted, that she wanted $7,500 for the dogs or "the dogs are gone", and that she admitted to taking $100,000 from an account. 'In light of these emails, I respectfully request that you withdraw your Interrogatories and Request for Production 1 believe than This martcr can be handled in a much friendlier and. productive fashion: Perhaps we should consider a four party conference. Otherwise, 1 will .be serving you with a ser of interrogatories as well and Request For Admissions. 1 would prefer not to proceed in that fashion but If f am forced to file any Emergency .Relief, 1 can assure you that these emails with be a part of the pleading and will be included as exhibits. 1 am still awaiting your client's cooperation in signing the listing agreement. I look forward t� hearing from you in the next two (2) business days regarding her cooperation Otherwise, I will file for Extraordinary Relief and 1 will seek counsel fees in light of your promised cooperation. Thank your for your attention to .this matter. Very truly yo, Gary Enclosures: December 15 and 27, 2008, October 14 and 18, and November 25, 2009.emails cc. Charles Paynter Received Time Aug. 12.. 2013 2:24PM No. 3150 P.1'6 VERIFICATION The undersigned, Courtney Kishel Powell, Esquire, of JSDC Law Offices, Hershey, Pennsylvania, hereby certifies that the foregoing Plaintiff's Motion to Compel Responses to Plaintiff's First Request for Production of Documents, Motion to Strike Defendant's Response to Plaintiff's First Request for Production of Documents and Plaintiff's Request for Sanctions has been prepared by me by knowledge and information acquired during the course of my representation of Plaintiff, Nasrin Golpoushan; and that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: ' , 2014 COURTNEYOWELL, Esquire VERIFICATION I, NASRIN GOLPOUSHAN, verify that the statements made in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: 7-3 --- , 2014 NASRIN GOLUS AN NASRIN GOLPOUSHAN, : IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner, : CUMBERLAND COUNTY, PENNSYLVANIA v. : CASE NO. 09-7330 CHARLES E. PAINTER, : CIVIL ACTION — LAW Defendant/Respondent. : IN DIVORCE CERTIFICATE OF SERVICE I, Courtney K. Powell, Esquire, with JSDC Law Offices, attorneys for the Plaintiff/Petitioner, Nasrin Golpoushan, hereby certify that I have served a copy of the foregoing Plaintiff's Motion to Compel Responses to Plaintiff's First Request for Production of Documents, Motion to Strike Defendant 's Response to Plaintiff's First Request for Production of Documents, and Plaintiff's Request for Sanctions on the following on the date and in the manner indicated below: VIA U.S. MAIL, FIRST CLASS, PRE -PAID Gary L. Kelley, Esquire 3117 Chestnut Street Camp Hill, PA 17011 Attorney for Defendant/Respondent Dated: ' , 2014 By: JSDC LAW OFFICES lik Courtney K. Powr, Esquire Attorney Pa. I.D. 1509 P.O. Box 650' Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Plaintifl7Petitioner, Nasrin Golpoushan 01-7330 VERIFICATION I verify that the statements made in this Response are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relatinu to unsworn falsification to authorities. Date: 9/02.Vv VS PRAECIPE lit aiheli iiiitu4eettoi g fi /4&7i. fikeweedt David D. Buell, Prothonotary In the Court of Common Pleas of Cumberland County, Pennsylvania No, (19- 7339 Civil Term rr -Q C-) N.) C..T1 VERIFICATION I verify that the statements made in this Response are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date. 9/.. V NASRIN GOLPOUSHAN, Plaintiff v. CHARLES E. PAINTER, Defendant i THE inoku 201,11 SEP 25 AN 10•': 03 CUMBERLAND COUNTY PENNSYL ANIA eountp of Cumberianb IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT 2009-7330 CIVIL TERM IN DIVORCE IN RE: PLAINTIFF'S MOTION TO COMPEL RESPONSES TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS, MOTION TO STRIKE DEFENDANT'S RESPONSE TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS, AND PLAINTIFF'S REQUEST FOR SANCTIONS ORDER OF COURT AND NOW, this,) day of September 2014, upon consideration of Plaintiff's Motion to Compel Responses to Plaintiff's First Request for Production of Documents, Motion to Strike Defendant's Response to Plaintiff's First Request for Production of Documents, and Plaintiff's Request for Sanctions, a RULE is issued upon Defendant to show cause the requested relief should not be granted. PLAINTIFF shall effectuate service of this Order of Court upon Defendant and shall file proof of service. RULE RETURNABLE twenty (20) days from the date of service. BY HE COURT, Thomas A. P acey C.P.J. Distribution: • Courtney K. Powell, Esq. .'"*Gary L Kelley, Esq &pe3 14444 eit /4/14 /2416 NASRIN GOLPOUSHAN, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA v. CASE NO. 09-7330 CHARLES E. PAINTER, : CIVIL ACTION — LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Courtney Kishel Powell, Esquire, with JSDC Law Offices, attorneys for the Plaintiff, Nasrin Golpoushan, hereby certify that I have served a copy of the attached Order Re: Rule to Show Cause signed by the Honorable Judge Placey on September 25, 2014, on the following on the date and in the manner indicated below: Via Certified Mail No. 7013 0600 0001 2856 3477 - Return Receipt Requested , And U.S. Mail, First Class, Pre -Paid res 0 CA) 0 Gary L. Kelley, Esquire 3117 Chestnut Street Camp Hill, PA 17011 JSDC LAW OFFICES ,) Dated: September 26� 2014 By: j ! '_ .� : : Ask � Courtney Kishel 'o ell Attorney Pa. I.D. 81509 P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Plaintiff, Nasrin Golpoushan ( Ri SEP 25 NASRIN GOLPOUSH411113ERLif"“i L'1)-1-1-1 Plaintiff 'PENNSYLVANIA V. CHARLES E. PAINTER, Defendant toot? of tunierthub IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT 2009-7330 CIVIL TERM IN DIVORCE IN RE: PLAINTIFF'S MOTION TO COMPEL RESPONSES TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS, MOTION TO STRIKE DEFENDANT'S RESPONSE TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS, AND PLAINTIFF'S REQUEST FOR SANCTIONS ORDER OF COURT AND NOW, this, day of September 2014, upon consideration of Plaintiff's Motion to Compel Responses to Plaintiffs First Request for Production of Documents, Motion to Strike Defendant's Response to Plaintiffs First Request for Production of Documents, and Plaintiff's Request for Sanctions, a RULE is issued upon Defendant to show cause the requested relief should not be granted. PLAINTIFF shall effectuate service of this Order of Court upon Defendant and shall file proof of service. RULE RETURNABLE twenty (20) days from the date of service. Distribution: Courtney K. Powell, Esq. Gary L Kelley, Esq Thomas A. Placey C.P. NASRIN GOULPOSHAN, Plaintiff v. . IN THE COURT OF COMMON PLEAS • : CUMBERLAND COUNTY, PENNSYLytANIA ri . -cr.) F:•=1- --.7 (--.t .--r— NO. 09-7330 ----, -,..-- CHARLES E. PAINTER, CIVIL ACTION - DIVORCE Defendant ci -- C DEFENDANT'S RESPONSE TO PLAINTIFF'S MOTION TO COMPEL RESPONSES TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS, MOTION TO STRIKE DEFENDANTS RESPONSE TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS AND PLAINTIFF'S REQUEST FOR SANCTIONS AND NOW, comes the Defendant, CHARLES E. PAINTER, by and through his attorney, Gary L. Kelley, and responds to PLAINTIFF'S MOTION, and in support thereof, respectfully responds as follows: 1. Admitted. 2.. Admitted. 3. Admitted. By way of further answer, the Plaintiff initially initiated a complaint for spousal support in Dauphin County which was apparently dismissed and, attempted to file a second time in Dauphin County. She never appeared for any conferences and apparently attempted to have the action transferred to another county at some point. The second complaint laid dormant and was ultimately dismissed. During this time, the Plaintiff was apparently pro se and was evasive and uncooperative. The Plaintiff attempted to initiate these actions while the Defendant was paying all bills and had access to joint bank accounts which she regularly accessed. 4. Denied as stated. While the listed attorneys may have represented the Plaintiff since the October 25, 2009 filing, it is believed, and therefore averred that the Plaintiff may have had at least one attorney prior to Mr. Silliker's entry of appearance. Moreover, each change of counsel has caused further delay while new counsel becomes familiar with the file. 5, Admitted. DEFENDANT'S RESPONSE TO MOTION TO COMPEL DISCOVERY 6. Defendant's responses to Averments 1 through 5 are incorporated herein as if set forth more fully. 7. Admitted. By way of further answer, as has been previously pleaded, the Plaintiff has repeatedly entered the marital residence since the date of separation during the period in question and removed all documents and furniture from the residence. Moreover, the Plaintiff has been represented by at least three (3) prior attorneys and much of this information was provided to prior counsel or, is in the Plaintiffs sole possession and control as she continuously removed furniture and documents from the home. The parties had limited assets during the course of their marriage. The significant assets included Mr. Painter's pension which is no longer an asset available for distribution since it has been included in APL calculations, complete information of which was provided to previous counsel including a pension worksheet; a Wachovia account from which the Plaintiff withdrew $100,000 and virtually closed the account and account statements were provided to prior counsel; and the marital residence. The Plaintiff received a significant Worker's Compensation settlement which has never been completely disclosed. There is a Belco joint account which has been dormant. Aside from the partiespersonalty, this is the bulk of the marital estate. Further, the proceeds from the sale of the marital residence are being held in escrow by Plaintiffs counsel. On December 15, 2008, December 27, 2008, October 14, 2009, October 18, 2009, and October 25, 2009, the Plaintiff sent taunting emails to the Defendant wherein she admitted, inter alia, to removing $100,000 from a joint account, and demanding $7,500 for the dogs she removed from the home or "the dogs are gone." Copies of these emails were provided to prior counsel by a letter dated August 12, 2013. The Defendant has offered to sign any releases necessary in order for the Plaintiff to obtain these records. Further, she may obtain this information as many of these returns were filed jointly. Given these facts, the Defendant objects to reconstructing these records as such would be obdurate, vexatious,' and unduly burdensome. The parties recently had a four -party conference with prior counsel and these items and information were not in dispute. The conference was prematurely terminated as a result of Plaintiffs conduct which included a profane tirade. 8. Denied as stated as the Defendant could have filed objections as well. By way of further answer, see answer to Averment 7. 9. Denied as stated. By way of further answer, see answers to Averments 7 and 8. 10. Denied as stated. By way of further answer, see answer to Averment 7. 11. Denied as stated. By way of further answer, said letter speaks for itself. Counsel believed that by this letter he had received an extension to respond appropriately to the request for production by said date. After conferring with his client, the undersigned submitted a response. 12. Admitted. 13. a. Said Rule speaks for itself. Hence this averment is denied. By way of further answer, Counsel received a letter from opposing counsel dated July 15, 2014 which was attached to Plaintiffs Motion sub iudice as Exhibit "A." In this letter, counsel noted that responses should be forwarded by July 28, 2014. If the responses were not received by that date, counsel stated that she would file a Motion with the Court. Counsel believed that by this letter he had received an extension to respond appropriately to the request for production by said date. In reliance thereupon, counsel filed his response on or about July 25, 2014, three days prior to the date listed in counsel's letter. b. Said Rule speaks for itself. Hence this averment is denied. By way of further answer, Counsel received a letter from opposing counsel dated July 15, 2014 which was attached to Plaintiffs Motion sub iudice as Exhibit "A." In this letter, counsel noted that responses should be forwarded by July 28, 2014. If the responses were not received by that date, counsel stated that she would file a Motion with the Court. Counsel believed that by this letter he had received an extension to respond appropriately to the request for production by said date. In reliance thereupon, counsel filed his response on or about July 25, 2014, three days prior to the date listed in counsel's letter. c. Said Rule speaks for itself. Hence this averment is denied. By way of - further answer, counsel's Response speaks for itself. d. Said Rule speaks for itself. Hence this averment is denied. By way of further answer, counsel has since filed an appropriate verification signed by the Defendant and has informed counsel of same. 14. Denied in its in entirety. The Plaintiff repeatedly entered the marital residence after she had abandoned it and removed the majority of the partiesfurnishings and all of the parties' financial records, As the financial records were at the residence prior to the Plaintiffs repeated entries and missing thereafter, the Defendant believes and therefore avers that the Plaintiff removed these documents and has them in her possession and control. Moreover, the Defendant has offered to sign any necessary releases for the Plaintiff to obtain this information as it would be patently unfair to require the Defendant to reconstruct records which the Plaintiff removed. Aside from the sale of the residence, there have been no significant changes in the parties' assets. 15. Said Response speaks for itself. Hence this averment is denied. By way of further answer, given that Plaintiff removed all financial information from the parties' marital residence, which included post separation information, it is respectfully submitted that the Plaintiff has this information in her possession or control. Defendant has offered to sign any necessary releases for the Plaintiff to obtain this information. 16. Said Response speaks for itself. Hence this averment is denied. Mr. Silliker received the pension information as set forth herein and Ms. Rudebusch received a copy of the Wachovia account from which the Plaintiff took $100,000 and subsequently taunted the Defendant about in a series of emails which were also provided to prior counsel as set forth in Plaintiffs Motion sub judice. 17. Denied as stated. See response to Averment 16. 18. Denied as stated. See response to Averment 16. 19. Denied as stated. See response to Averment 16. 20. Denied as stated, See Response to Averment 13. b. WHEREFORE, based upon all of the foregoing, the Defendant respectfully requests that this Honorable Court deny Plaintiffs Motion. DEFENDANT'S RESPONSE TO MOTION TO STRIKE DEFENDANT'S RESPONSE TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS 21. Defendant's responses to Averments 1 through 20 are incorporated herein as if set forth more fully. 22. Legal conclusion to which no response is necessary. To the degree that a response is deemed necessary, the Defendant denies this averment. 23. Denied as stated. By way of further answer, said response provides information which provides a picture of the entire course of conduct which is relevant in response to such requests. 24. Counsel is confused by this averment. Hence it is denied. WHEREFORE, based upon all of the foregoing, the Defendant respectfully requests that this Honorable Court deny Plaintiffs Motion, DEFENDANT'S RESPONSE TO MOTION FOR SANCTIONS IN THE FORM OF COUNSEL FEES 25. Defendant's responses to Averments 1 through 24 are incorporated herein as if set forth more fully. 26. Denied as stated. By way of further answer, the Defendant filed a response to the Request sub judice and requested that prior counsel withdraw her earlier requests based upon Plaintiffs conduct. 27. Denied as stated. 28. Denied as stated. By way of further answer, the Defendant filed a response to which counsel apparently takes exception even though she granted an extension of time in which to respond. 29. Denied as stated. The Plaintiff has had sufficient funds for which to hire at least five (5) different attorneys in this matter. This matter could have been completed at a prior four party conference had Plaintiffs conduct not been so egregious and profane. The subsequent filings appear to be retaliatory in nature given that these items were not in dispute previously and after a conference was ended prematurely for the reasons set forth herein. 30. Denied as stated. By way of further answer, see response to averment 29. 31. Denied as stated. 32. Denied as stated. 33. Denied. 34. Said Rule speaks for itself. Hence this averment is denied. 35. Counsel is confused by this averment. Hence it is denied. 36. Denied as stated. 37. Admitted. WHEREFORE, based upon all of the foregoing, the Defendant respectfully requests that this Honorable Court deny Plaintiffs Motion. Respectfully submitted, Gary LWelley ID No. 46801 3117 Chestnut Street Camp Hill, PA 17011 (717) 612-1484 VERIFICATION 1 verify that the statements made in this Response are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. VERIFICATION I verify that the statements made in this Response are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: /0///if NASRIN GOULPOSHAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 09-7330 CHARLES E. PAINTER, CIVIL ACTION - DIVORCE Defendant CERTIFICATE OF SERVICE I, GARY L. KELLEY, Esquire, attorney for Defendant in the above -captioned matter, do hereby certify that I served a true and correct copy of DEFENDANT'S RESPONSE TO PLAINTIFF'S MOTION TO COMPEL RESPONSES TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS, MOTION TO STRIKE DEFENDANT'S RESPONSE TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS, AND PLAINTIFF'S REQUEST FOR SANCTIONS on Plaintiffs counsel on the 1st day of October, 2014, by First Class U.S. Mail, postage prepaid, addressed as follows: Courtney K. Powell, Esq. P.O. Box 650 Hershey, PA 17033 LAW OFFI f4 S OF GARY L. KELLEY GA' Y ' . KELLEY •:quire 80 311 hes nut S Camp Hill, PA 17011 (717) 612-1484 Attorney for Defendant NASRIN GOULPOSHAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 09-7330 CHARLES E. PAINTER, . CIVIL ACTION - DIVORCE Defendant CERTIFICATE OF SERVICE I, GARY L. KELLEY, Esquire, attorney for Defendant in the above -captioned matter, do hereby certify that I served a true and correct copy of DEFENDANT'S RESPONSE TO PLAINTIFF'S MOTION TO COMPEL RESPONSES TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS, MOTION TO STRIKE DEFENDANT'S RESPONSE TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS, AND PLAINTIFF'S REQUEST FOR SANCTIONS on Plaintiffs counsel on the 1st day of October, 2014, by First Class U.S. Mail, postage prepaid, addressed as follows: Courtney K. Powell, Esq. P.O. Box 650 Hershey, PA 17033 LAW OFFICES OF ; .i' Y L. KELLEY GARY la ELLEY, E I.D. #4 3117 Chestnut Street Camp Hill, PA 170] 1 (717) 612-1484 Attorney for Defendant C) CD z -C c-- -F, NASRIN GOLPOUSHAN, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA v. : CASE NO. 09-7330 CHARLES E. PAINTER, : CIVIL ACTION — LAW Defendant : IN DIVORCE AMENDED CERTIFICATE OF SERVICE I, Courtney Kishel Powell, Esquire, with JSDC Law Offices, attorneys for the Plaintiff, Nasrin Golpoushan, hereby certify that I have served a copy of the attached Order Re: Rule to Show Cause signed by the Honorable Judge Placey on September 25, 2014, on the following on the date and in the manner indicated below: U.S. Mail, First Class, Pre -Paid Gary L. Kelley, Esquire 3117 Chestnut Street Camp Hill, PA 17011 Dated: October 7, 2014 By: JSDC LAW OFFICES Courtney 1 Attorney Pa. 09 P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Plaintiff, Nasrin Golpoushan C) m C) C) cD -< CO N) CD Co SE) NASRIN GOLPOUSHAi4,3'- L'.iL d Plaintiff PLJt15YL�li'ilA v. CHARLES E. PAINTER, Defendant IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT 2009-7330 CIVIL TERM IN DIVORCE IN RE: PLAINTIFF'S MOTION TO COMPEL RESPONSES TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS, MOTION TO STRIKE DEFENDANT'S RESPONSE TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS, AND PLAINTIFF'S REQUEST FOR SANCTIONS ORDER OF COURT AND NOW, this day of September 2014, upon consideration of Plaintiffs Motion to Compel Responses to Plaintiffs First Request for Production of Documents, Motion to Strike Defendant's Response to Plaintiffs First Request for Production of Documents, and Plaintiff's Request for Sanctions, a RULE is issued upon Defendant to show cause the requested relief should not be granted. PLAINTIFF shall effectuate service of this Order of Court upon Defendant and shall file proof of service. RULE RETURNABLE twenty (20) days from the date of service. Distribution: Courtney K. Powell, Esq. Gary L Kelley, Esq BY H COURT, Thomas A. Placey C.P.J. FILA Cr-C err r�7 r s 1 — �1 + ti j + 11 r`ifUI?AYi { OCT 16 �g�. 11: 55 Courtney K.Powell,Esquire H, Attorney Pa.I.D.#81509 . C E-mail: cknna,isdc.com t t JSDC Law Offices t �J t LYrPdl,' P.O.Box 650 Hershey,PA 17033 Telephone: (717)533-3280 Attorneys for Plaintiff/Petitioner, Nasrin Golpoushan NASRIN GOLPOUSHAN, IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner, CUMBERLAND COUNTY, PENNSYLVANIA V. CASE NO. 09-7330 CHARLES E. PAINTER, CIVIL ACTION—LAW Defendant/Respondent. IN DIVORCE PRAECIPE FOR DISPOSITION TO THE PROTHONOTARY: Please transmit the accompanying Plaintiff/Petitioner's Motion to Compel Responses to Plaintiff's First Request for Production of Documents, Motion to Strike Defendant's Response to Plaintiffs First Request for Production of Documents, and Plaintiff's Request for Sanctions which was filed with the Court on September 18, 2014, to The Honorable Thomas A. Placey for disposition. The names and addresses of all opposing counsel/pro se litigants are as follows: Gary L. Kelley, Esquire 3117 Chestnut Street Camp Hill, PA 17011 Respectfully submitted, JSDC LAW OFFICES Dated: ,2014 By: f Courtney Kish 4 kw'ell Attorney I.D. #N09 P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Plaintiff, Nasrin Golpoushan NASRIN GOLPOUSHAN, IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner, CUMBERLAND COUNTY, PENNSYLVANIA V. CASE NO. 09-7330 CHARLES E. PAINTER, CIVIL ACTION—LAW Defendant/Respondent. IN DIVORCE ORDER AND NOW, this day of 2014, upon consideration of Plaintiff's Motion to Compel Responses to Plaintiff's First Request for Production of Documents, Motion to Strike Defendant's Response to Plaintiff's First Request for Production of Documents, and Plaintiff's Request for Sanctions, it is hereby ORDERED and DECREED that Plaintiff's Motion is granted. a. Husband shall provide Wife with full and complete responses to the discovery requests sent on August 8, 2013, as well as the discovery requests sent June 5, 2014, within ten (10) days of this Order; b. The Cumberland County Prothonotary is hereby directed to strike Husband's Responses to Plaintiff's First Request for Production of Documents from the court docket; and C. This Court finds that Husband's behavior in filing Defendant's Response to Plaintiff's First Request for Production of Documents, as well as his failure to provide discovery responses to Wife and her attorney is vexatious, obdurate and dilatory conduct. As such Husband shall pay Wife's counsel fees, costs and expenses in the total sum of $ within thirty(30) days of this Order. BY THE COURT: J. Distribution: Courtney K. Powell, Esquire, P.O. Box 650, Hershey, PA 17033 // Attorneys for Plaintiff/Petitioner Gary L. Kelley, Esquire, 3117 Chestnut Street, Camp Hill, PA 17011 Attorney for Defendant/Respondent Fi_ � At Courtney K.Powell,Esquire PH 12: 07 Attorney Pa.I.D.#81509 C'If MBERLAN0 C0UN—Y E-mail: cjq&jsdc.com P L NJ 6 Y LVA;N I A JSDC Law Offices P.O.Box 650 Hershey,PA 17033 Telephone: (717)533-3280 Attorneys for PlaintiffTetitioner, Nasrin Golpoushan NASRIN GOLPOUSHAN, IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner, CUMBERLAND COUNTY, PENNSYLVANIA V. CASE NO. 09-7330 CHARLES E. PAINTER, CIVIL ACTION—LAW Defendant/Respondent. IN DIVORCE PLAINTIFF'S MOTION TO COMPEL RESPONSES TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS, MOTION TO STRIKE DEFENDANT'S RESPONSE TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS, AND PLAINTIFF'S REQUEST FOR SANCTIONS AND NOW, comes the Plaintiff/Petitioner, Nasrin Golpoushan, by and through her counsel, Courtney K. Powell, Esquire, with JSDC Law Offices, and files the within Motion to Compel Responses to Plaintiff s First Request for Production of Documents,Motion to Strike Defendant's Response to Plaintiff's First Request for Production of Documents and Plaintiff's Request for Sanctions, and in support thereof, states the following: 1. The Petitioner is Nasrin Golpoushan, Plaintiff in the above-captioned divorce action, (hereinafter referred to as "Wife"). 2. The Respondent is Charles E. Painter, Defendant in the above-captioned divorce action, (hereinafter referred to as "Husband"). 3. On October 25, 2009, Wife filed a Complaint for Divorce under Sections 3301(c) and 3301(d) and raised counts for Equitable Distribution, Alimony, and Alimony Pendente Lite, Counsel Fees and Expenses. 4. When Wife filed for divorce, she was represented by Mark T. Silliker, Esquire. Thereafter, Wife was represented by Marianne E. Rudebusch, Esquire, and Heather Verchick, Esquire. 5. The undersigned legal counsel entered her appearance on behalf of Wife on May 15, 2014. MOTION TO COMPEL DISCOVERY 6. Averments one (1) through five (5) are incorporated herein by referenced. 7. On Thursday, June 5, 2014, undersigned counsel served Plaintiff's First Request for Production of Documents to Husband via his counsel, Gary L. Kelley, Esquire. A true and correct copy of the Request for Production of Documents is attached hereto and marked as "Exhibit "A." 8. Husband's answers to the Request for Production of Documents were due on or before July 7, 2014; however, Husband failed to produce the same. 9. On Tuesday, July 15, 2014, the undersigned counsel sent a letter to Attorney Kelley, advising that the discovery responses were overdue and requesting responses no later than Monday, July 28, 2014. A copy of said correspondence is attached hereto and marked as Exhibit`B." 10. On Tuesday, July 22, 2014, the undersigned counsel received a voicemail message from Attorney Kelley advising that the discovery materials requested were previously exchanged with prior counsel. 11. On that same day, the undersigned counsel faxed a letter to Attorney Kelley memorializing the voicemail message he left for the undersigned, and advising him that prior counsel's file did not contain the information requested in discovery. The letter requested a copy of the correspondence showing that the discovery materials were previously supplied or to produce the answers to the current discovery requests by July 28, 2014. A copy of said correspondence is attached hereto and marked as Exhibit"C." 12. On Monday, July 28, 2014, the undersigned counsel received Husband's Responses to Plaintiff s First Request for Production of Documents. A copy of said responses are attached hereto and marked as Exhibit "D." 13. Husband did not provide any documents requested, and failed to respond to the discovery requests in accordance with PA.R.Civ.P. 4009.12, in that: a. Pa.R.Civ.P. 4009.12 requires that the objections be made within thirty(30) days. As Husband's responses in the form of objections were not timely, and as such Husband must be compelled to supply the discovery requested. b. Pa.R.Civ.P. 4009.12 requires the responding party produce or make available the information requested, if there is no objection. Husband failed to produce any documentation or make it available for review; c. Pa.R.Civ.P. 4009.12 requires the documentation to identify with reasonable particularity those documents not being produced, along with a reason why they are not being produced. Husband failed to do this. d. Pa.R.Civ.P. 4009.12 requires the answers to be signed and verified by both the party and the party's attorney. The answers were only verified by counsel. 14. Husband's responses in part, asserted that the documents were in Wife's control, which is false. Wife does not have the ability to obtain copies of Husband's individual tax returns, retirement information, brokerage accounts, or Social Security Administration earnings history report. 15. Husband also asserts that Wife is a joint owner for the accounts requested. It is acknowledged that Wife is the joint owner of one bank account; however, it remains unclear from the responses provided whether Husband has any other accounts, and if so, Wife does not have access to any of that information. Moreover, Wife does not have copies of joint tax returns as filed, and needs Husband's assistance in obtaining copies of the same. 16. Husband also maintains that he previously provided the requested material to Wife's prior counsel, although he fails to specifically identify the attorney he submitted them to. 17. Undersigned counsel contacted Mark T. Silliker, Esquire, who first represented Wife. Attorney Silliker advised that the only information he received was in 2010 regarding Husband's pension. No other financial information was supplied to Attorney Silliker. 18. Undersigned counsel also contacted Attorney Rudebusch, who represented Wife from December 2011 through February 2013. The limited financial information she was given, and which she supplied to the undersigned counsel,pertained to Husband's income and wage information in 2011. This information was not requested in Plaintiff's First Request for Production of Documents requests. 19. Additionally, undersigned counsel contacted Heather Verchick Esquire, who represented the Wife from February 2013 through April 2014. She served Husband with Interrogatories and Request for Production of Documents on August 8, 2013. On August 12, 2013, Attorney Kelley wrote to Attorney Verchick requesting that she withdraw her discovery requests, and consider a four-party conference, or he would also serve her with a set of Interrogatories and Request for Admissions. Husband failed to provide any financial information in response to the discovery requests sent by Attorney Verchick. A true and correct copy of these correspondences are attached hereto and marked as Exhibit "E." 20. Husband has failed to provide the documentation requested in Plaintiff's First Request for Production of Documents submitted on June 5, 2014, and on August 8, 2013, and the parties have now been separated for over four(4) years. It is believed and therefore averred that a Court Order is required to compel Husband to produce answers to all of the discovery requested to date, so that the divorce can be finalized. WHEREFORE, for the foregoing reasons, Wife respectfully requests this Court order Husband to produce answers to the discovery requests sent on August 8, 2013 and on June 5, 2014 within ten (10) days. MOTION TO STRIKE DEFENDANT'S RESPONSE TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS 21. Averments one (1) through twenty (20) are incorporated herein by reference. 22. Husband's responses to Wife's First Request for Production of Documents do not adequately respond to the discovery requests. 23. Husband's response to Wife's First Request for Production of Documents serve no legitimate purpose, disparages Wife and alleges conduct that is not relevant to the within action. 24. Husband's counsel filed Defendant's Response to Plaintiff's First Request for Production of Documents, which was improper and unnecessary. WHEREFORE for the foregoing reasons, Wife respectfully requests that this Court strike Husband's responses to her First Request for Production of Documents. MOTION FOR SANCTIONS IN THE FORM OF COUNSEL FEES 25. Averments one (1)through twenty-four(24) are incorporated herein by reference. 26. Wife, through her attorneys, has submitted discovery requests for Husband to complete on at least two occasions, and Husband has failed to answer the same. 27. The discovery is necessary in order to finalize the divorce. 28. Husband has had sufficient time in which to provide his discovery responses. 29. Husband's failure to timely and thoroughly respond to Wife's discovery requests has caused Wife to incur unnecessary counsel fees, which she cannot afford to pay. 30. Wife will continue to incur counsel fees, costs and expenses in attending a conference and/or having a hearing on the within petition. 31. Wife should not have to pay unnecessary attorneys fees to compel Husband to comply with the discovery requests. 32. As a direct result of Husband's failure to comply with the discovery requests, Wife has incurred at least $500.00 in attorney's fees with the undersigned, and will incur attorney's fees until the discovery documents are produced. Wife may have also incurred attorneys' fees with her prior attorneys; however, that amount is not known. 33. Husband's conduct is vexations, obdurate, and dilatory. 34. Pursuant to 42 Pa.C.S. §2503, a party may receive counsel fees as a sanction for conduct which is vexatious, obdurate, or dilatory. 35. Wife requests that this Court impose sanctions on Husband and require him to pay for Wife's counsel fees, costs and expenses incurred as a direct result of Husband's failure to timely respond to Wife's discovery requests. 36. Pursuant to C.C.R.P. No. 208.2(_d), it is believed that Husband's counsel does not concur in this Petition. Undersigned counsel attempted to resolve the discovery dispute in a letter dated July 22, 2014; however, the requested documents were not provided. 37. Pursuant to C.C.R.P. No. 208.3 no judge has previously ruled upon any matter relating to this case. WHEREFORE, the Plaintiff/Petitioner, Nasrin Golpoushan, respectfully requests this Court to enter an Order as follows: a. order Husband to provide the requested documentation within ten (10) days; b. direct the Prothonotary to strike Husband's Responses to Plaintiff's First Request for Production of Documents from the court docket; C. direct Husband, Charles E. Painter, to pay Wife's counsel fees, costs and expenses that she has incurred as a direct result of Husband's failure to act; and d. grant any other appropriate relief. Respectfully submitted, JSDC LAW OFFICES Dated: I J A , 2014 By: 1 I a I i Iri,10 P 111,�-I-)ru Courtney K Po e , squire Attorney Pa. I.D. # 1509 P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Plaintiff/Petitioner, Nasrin Golpoushan Exhibit "A" JSDC LAW OFtCE5 JAMES•SMHH•DIETT cK•CONNELLY•SPADE•CHABAL•YAHN•SIKER•TOMASKO Courtney Kishel Powell E-mail: ftoisdc.com DIRECT FAX 717.2982025 June 5,2014 P.O.BOX 650 HERSHEY,PA 170a MAIN OFFICE: 134 SIPE AVENUE Gary L. Kelley, Esquire HUMMEL=m,PA 1703 3117 Chestnut Street WE—ST SHORE LOCATION' Camp Hill, PA 17011 555 GETnseuRG PIKE SURE C40o Re: Nasrin Golpoushan v. Charles E. Painter MECWYNIMMG,PA 170E Cumberland County Docket No. 09-7330 TEL.717.533.3280 Dear Gary: WWW.JSDC.COM GARY L.JAMES MAX J.I have had the opportunity to review Attorney Verchick's file in the above- JOHN CONNELLY,JR. referenced matter, and need additional information from your client before you and I can SCOTT A.DIEITERICK proceed in any meaningful discussions. I have enclosed Request for Production of JAMES rnAEW SPADE CAL III Documents for your client to answer. NEIL W.YAHN EDWARD P.SEEBER Please submit your client's responses within the requisite thirty(30) days so that I SUSAN can finalize my review of the parties' marital estate. I am hopeful that once I review this COURTNEY K.PowELL additional information, you and I can proceed in settlement discussions. KAREN N.CONNELLY CHRISTINE T.BRANN JESSICA E.LoNE If you have any questions concerning this matter, please feel free to contact me at GREGORY A.KOGuT,JR. the telephone number listed above. TERES^M.RBFsNYDER JAMES D.YOUNG CAYLA B.JAKUBOWITZ Very truly yours, ALEXIS M.MILOSZEWSKI KATHRYN L.MASON r1 OF COUNSEL: GREGORY K.RICHARDS KIMBERLY A.BONNER Courtney K. Pow 1 RALPH M.SALVIA ANDREW H.BRIGGS CKP:dej JANA FRIDRNNSD MR Enclosure cc: Nasrin Golpoushan (w/enc.) NASRIN GOLPOUSHAN, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY,PENNSYLVANIA V. CASE NO. 09-7330 CHARLES E. PAINTER, CIVIL ACTION—LAW Defendant IN DIVORCE PLAINTIFF'S FIRST REQUESTFO_R PRODUCTION OF DOCUMENTS TO: Charles E. Painter, Defendant CIO Gary L. Kelley, Esquire 3117 Chestnut Street Camp Hill, PA 17011 Plaintiff, Nasrin Golpoushan, by her undersigned counsel, hereby propounds the following request for production of documents and tangible things pursuant to the Pennsylvania Rules of Civil Procedure. The documents and tangible things requested herein must be produced at the JSDC Law Offices within thirty(30) days. INSTRUCTIONS AND DEFINITIONS Each of the following requests is intended as a separate request. Where a request has subparts, please respond to each subpart separately and in full. Do not limit any response to the numbered request as a whole. r _ If you have any objection to any request, please state your objection fully and set forth the factual basis for your objection in lieu of production of the documents. You must file and serve a written response to these requests within thirty (30) days of service of these requests upon you, regardless of the time set for production of the documents and things requested herein. You are reminded that any objections not raised within the thirty(3 0)day period provided for by the Rules of Court will be deemed to have been waived by you. These requests are not only for documents and tangible things that are owned by you, but also for documents and tangible things that are in your possession, custody, or control. This means that you must produce all documents and tangible things that are responsive to a particular request and that are in your possession (regardless of whether they are your property), or over which you have control even if they are not in your possession. It also means you must produce documents and tangible things that are in the possession, custody, or control of your agents, employees, and/or attorneys. Before responding to these requests you are required to make a diligent search of your files and records to ascertain whether you have documents that would be responsive to a given request. Your agents, employees, and attorneys must do the same. To avoid any possibility of confusion with respect to these requests, please note that the following terms have the following meanings in these requests, unless a particular request clearly indicates otherwise: "You"or"your"refer to the person to whom these requests have been addressed. "Person" means any natural person, corporation, unincorporated association, trust, partnership, and/or any other legally cognizable entity. It is contemplated that any corporation or other business entity acts only through its agents, officers, employees, and attorneys, and requests that apply to any such legal entity should be construed accordingly. "Plaintiff'means the particular plaintiff or plaintiffs in this section to whom this request is addressed, as set forth above. "Defendant"means the defendant or defendants named in this action. "Document", "record", "file", and "report" all refer to and contemplate all written, recorded, or graphic information, whether preserved in writing, on magnetic tape, by electronic means, in photographic form, on microfilm or microfiche, computer disc, or by any other means of information retrieval or storage. DOCUMENTS TO BE PRODUCED Please produce at the JSDC Law Offices, counsel for Plaintiff, located at 134 Sipe Avenue, Hummelstown, Pennsylvania, 17036, within thirty(30) days of the date of this Request, the following documents: 1. Complete copies of your federal and state income tax returns as filed, and all supporting documentation used to prepare the return, including but not limited to all 1099's, 1098's, W-2's, K-1's, schedules, and worksheets for the tax years of 2008 through 2013. RESPONSE: 2. Copies of the monthly statements for any and all bank accounts in which you have an interest, whether individually or with another, or in which you have deposited funds, including but not limited to checking accounts, savings accounts, money market accounts, certificates of deposits, from January 1, 2008, through to the date in which you answer these requests. Please include copies of cancelled checks or check registers for each checking account during this time frame. RESPONSE: 3. Copies of monthly statements for any and all brokerage, investment accounts, and/or mutual funds in which you have an interest (whether individual or jointly with another), in which you have deposited funds, or which is held for your benefit, from January 1, 2008, through to the present. RESPONSE: 4. Copies of monthly statements for any and all securities, including tax free bonds, and funds, in which you have an interest (whether individual or jointly with another), or which is held for your benefit, from January 1, 2008, through to the present. RESPONSE: 5. Copies of all monthly/quarterly/annual statements relating to any individual retirement account, 401(K), pension, profit sharing plan, savings plan, KEOGH, annuity benefits, retirement plan, deferred compensation plan, stock bonus plan, stock option plan, thrift plan or any other retirement benefit in which you have or had an interest or which is/was held for your benefit from January 1, 2008, through the date in which you answer these requests. For each plan that existed at the time of marriage, please provide documentation showing the value of said plan on that date as well. RESPONSE: 6. Copies of the Kelley Blue Book Value for each vehicle you have in an ownership interest in from January 1, 2008, through to the date in which you answer these requests, except that if any vehicle was traded in, sold or otherwise disposed of, provide documentation showing the value of the compensation you received for said vehicle. RESPONSE: 7. Copies of any statements relating to all life insurance policies and/or annuities in which you are the beneficiary, the owner or the payor, or the insured, including the identity of all beneficiaries for each policy that existed from January 1, 2008, through the date in which you respond to these requests. RESPONSE: 8. Copies of any severance package that you have or have had with your employers from January 1, 2012, through to the present. RESPONSE: 9. Copies of your most recent statement issued by the Social Security Administration showing your Estimated Benefits and Earnings History. RESPONSE: Respectfully submitted, JSDC Law Offices Dated: ,2014 By: J Courtney Kishel well,Esquire Attorney I.D. #8 5 P.O.Box 650 Hershey,PA 17033-0650 (717) 533-3280 Attorneys for Plaintiff, Nasrin Golpoushan e , NASRIN GOLPOUSHAN, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. CASE NO. 09-7330 CHARLES E. PAINTER, : CIVIL ACTION—LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Courtney Kishel Powell, Esquire, with JSDC Law Offices, attorneys for the Plaintiff, Nasrin Golpoushan, hereby certify that I have served a copy of Plaintiff"s First Request for Production of Documents on the following, on the date and in the manner indicated below: U.S. MAIL, FIRST CLASS,PRE-PAID Gary L. Kelley,Esquire 3117 Chestnut Street Camp Hill, PA 17011 Attorneys for Defendant JSDC LAW OFFICES Date: Q; , 2014 By: CotheEsqui eAPo Hershey, PA 17033 (717) 533-3280 Attorneys for Plaintiff, Nasrin Golpoushan Exhibit "B " JSDC LAW OFFICES JAMES'SMrrH•DIET=CK•CONNELLY•SPADE•CHABAL•YAHN•SEEBER•TOMASKO Courtney Kishel Powell E-mail: �jsdc.com DIRECT FAX 717.298.2025 July 15, 2014 P.O.Box 650 HERSHEY,PA 1 MAIN 134SFE AVENUE HIwasTowN,PA NEST,%0R I nrei Gary L. Kelley, Esquire 555 GETTYSBURG PI 3117 Chestnut Street SU7EC400 Camp Hill, PA 17011 MEcaWCSBURG,PA TEL 717.533.32 Re: Nasrin Golpoushan v. Charles E. Painter Cumberland County Docket No. 09-7330 wwwJSDC.CO GARY L JAMES Dear Gary: MAX J.SMmi,JR. JOHN J.CONNELLY,JR SCM A DE TERICK As you know, on June 5, 2014, I sent Requests for Production of Documents to JAMES F.SPADE MAmtw CHABAL,III you on the above-referenced matter. Your client's responses were due on July 7, 2014. NEIL w YAHN To date, I have not received any responses from you, and the documents are necessary in E[Y"ARD P SEEKER order to finalize the divorce. RONALD T ToMAsKo SUSAN M.KADEL CouRTNEY K.PowELL Kindly forward your client's responses to my discovery requests no later than KAREN N.CONNELLY CHRIE T Monday, July 28, 2014, or I will have no other choice but to file a Motion with the Court. Ass ANE.LOwE BRANN I hope that will not be necessary. GREGoRvA.KOGUT,JR. TERESA M.REIFsNYDER JAMES D.YOUNG - Very truly yours, CAYLA B.JAKUBOWITZ ALEXIS M.MILOSZEWSKI KATHRYN L.MASON OF COUNSEL: Courtney K. Pow 11 GREGORY K.RIGHARDs KIMBERLY A.BONNER RALPH M.SALVA CKP:dej ANDREW H.BRIGGS cc: Nasrin Golpoushan JANA FRDFINNSDOTRR Exhibit "C " JSDC LAW 0FRC,>5 JAMES•S=•DmTrMCK•CONNELLY•SPADE•C[IABAL•YATiN•SE BER•TOMASKO Courtney Kishel Powell E-mail: pkg@Lsdc.com DnZECT FAX 717.298.2025 July 22, 2014 PO.Box 650 HERSHEY,PA 1703 Via Facsimile No. 717-612-1MAIN OFFlCE: 761 MA SIPS AVENUE And Regular U.S. Mail HUMMELSTONN,PA 170: WEST SHORE LOCATION 555 GETTYSBURG PIKE SURE C400 Gary L. Kelley, Esquire MEOW CMURG,PA 170, 3117 Chestnut Street TEL.717.533.3280 Camp Hill, PA 17011 WWW.JSDC.COM Re: Nasrin Golpoushan v. Charles E. Painter GARY L.JAMES Cumberland County Docket No. 09-7330 MAX J.SMRH,JR. JOHN J.C CRLY,JR. SCOTT A.DIEnFACK Dear Gary: JAMES F SPADE MATTHEW CHABAL,III NoL W.YARN Please allow this letter to memorialize the voicemail message that I left forou EDWARD P SEEBER y RONALD T.TOMAsKo this afternoon. I received your voicemail message from this morning concerning my SUSAN M.KADEL .discovery requests. Although you advised that discovery was previously exchanged with COURTNEY K.POWELL prior counsel, I have Attorney Verchick's file and it appears that your client failed to KAREN N.CONNELLY provide responses to her discovery CHRIST NE T.BRANN p p ery requests. My client does not have the information that JESSICA E.LOWS I have requested, so I am asking for your client to provide the same to me. GREGORY a Kocur,JR. TERESA M.RBFSwDER JAMES D.YOUNG If you have previously supplied this information to Attorney Verchick, please CAn^B.JAKUBOWITz forward me a copy of that correspondence with the answers to her discovery requests, ALENS M.MlLoszmsKI and I will be happy to review them and amend my discovery requests accordingly. If KATHRYN L MASON your client has not provided discovery previously, please have them completed and GOF RECOUNSEL :GORY to my office by Monday, July 28, 2014. GREGORY K. RDs KIMBERLY A.E3oNN0NNFA RALaH M.SALVIA Your attention to this matter is appreciated. ANDRE H.BRGGs JANA FRIDRNNSDOTTIR Very truly yours, - Courtney K. Pow CKP:dej cc: Nasrin Golpoushan ******** ***** —COMM. JOURNAL— DATE JUL-21-2014 ***** TIME 16:57 ******** MODE = MEMORY TRANSMISSION START=JUL-21 16:5G END=JUL-21 16:57 FILE NO.=015 STN NO. COMM. ABBR NO. STATION NAME/TEL NO. PAGES DURATION 001 OK a 6121761 001/001 00:00:30 —WWW JSDC COM _ ************************************ —JSDC LAW OFFICES— JSDC taw OFFICES ;kia JAM SMIni E)IMT UCK•CONN13LLY SPADE (NADAL YAHNSEEBEK•TOIvIA.9K0 �yt Courtney vishel Powell E-mail:ekeMsde.com DIRECT FAX 717298.2025 July 22,2014 P.O.sox 650 HPA$HEY,PA 17= MAN QPBM Vta Facsimile No. 717-612-1761 134 SPEAWwE And Releular U.S.Mail HjMwr`m,as IM36 d 555 cerrrmm PW Sure 0400 MEaWdC6g.RG,PA 17055 Gary L.Kelley,Esquire 3117 Chestnut Street TEL 717,533.9280 Camp Hill,PA 17011 Wvw_jsDG_C0MGW . Re: Nasrin Golpoushan v, Charles F.Painter MAX `�IR Cumberland County Docket No.09-7330 juNd.COAKUY,JR scorn A XrMICK JA6*S F.SRaOe Dear Gary: MArn4Mv Qu&4 111 Na W.YA6N EDWAFU P.Sa Wl Please allow this letter to memorialize the voicemail message that I left for you AWADT.7oMOO this afternoon, I received your voicemail message from this morning concerning my sr%K K4oe, discovery requests. Although you advised that discovery was previously exchanged with cagMk.K FUveu WeN OMNalY Prior counsel, I have Attorney Verchick's file and it appears that your client failed to c'0ZI Y.Bf" provide responses to her discovery requests. My client does not have the information that J«r,F.nom I have requested,so I am asking for your client to provide the same to me. Tarm `K°"'r Ja Ci�.'A M.FE7fsry0ER JAS 0.YOUM If you have previously supplied this information to Attorney Verchick, please c""-^a J"q'D01TrZ forward me a copy of that correspondence with the answers to her discovery requests, and I will be happy to review them and amend my discovery requests accordingly, If `r` your client has not provided discovery previously, please have them completed and GraoMK FeaAFM submitted to my office by Monday,July 28,2014, KMBFFLYA.Buoffl FatPrl M.SNYA Mm w H.BFKGs Your attention to this matter is appreciated. Very truly yours, Courtney K.Pow CKP:dej cc: Nasrin Golpoushan Exhibit "D " NASRIN GOULPOSHAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA � VNO. 09-7330 c CHARLES E. PAINTER, CIVIL ACTION - DIVORCE .c Defendant w � DEFENDANT'S RESPONSE TO PLAINTIFF'S �n FIRST RE UEST FOR PRODUCTION OF DOCUMENTS -< C w AND NOW, comes the Defendant, CHARLES E. PAINTER, by and through his attorney, Gary L. Kelley, and responds to PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS and, in support thereof, respectfully responds as follows: I• The Plaintiff has repeatedly entered the marital residence since the date of separation during the period in question and removed all documents and furniture from the residence. Moreover, the Plaintiff has been represented by at least three (3) prior attorneys and much of this information was provided to prior counsel or, is in the Plaintiffs sole possession and I control as she continuously removed furniture and documents from the home. On December 15 j 2008, December 27, 2008, October 14, 2009, October 18, 2009, and October 25, 2009, the I Plaintiff sent taunting etna'is to the Defendant wherein she admitted, inter alia, to removing I $100,000 from a joint account, and demanding $7,500 for the dogs she removed from the home or "the dogs are gone." Copies of these emails were provided to prior counsel by a letter dated August 12, 2013. Further, she may obtain this information as many of these returns were filed jointly. Given these facts, the Defendant objects to reconstructing these records as such would be obdurate, vexatious, and unduly burdensome. The parties recently had a four-party conference with prior counsel and these items and information were not in dispute. 2.. The Plaintiff has repeatedly entered the marital residence since the date of i separation during the period in question and removed all documents and furniture from the I residence. Moreover, the Plaintiff has been represented by at least three (3) prior attorneys and much of this information was provided to prior counsel or, is in the Plaintiffs sole possession and control as she continuously removed furniture and documents from the home. On December 15. 2008, December 27, 2008, October 14, 2009, October 18, 2009, and October 25, 2009, the i Plaintiff sent taunting emails to the Defendant wherein she admitted, inter alia, to removing $100,000 from a joint account, and demanding $7,500 for the dogs she removed from the home or "the dogs are gone." Copies of these emails were provided to prior counsel by a letter dated August 12, 2013. Further, she may obtain this information as many of these accounts, if not all, were joint. Given these facts, the Defendant objects to reconstructing these records as such would be obdurate, vexatious, and unduly burdensome. The parties recently had a four-party conference with prior counsel and these items and information were not in dispute. 3. The Plaintiff has repeatedly entered the marital residence since the date of separation during the period in question and removed all documents and furniture from the residence. Moreover, the Plaintiff has been represented by at least three (3) prior attorneys and much of this information was provided to prior counsel or, is in the Plaintiffs sole possession and control as she continuously removed furniture and documents from the home. On December 15, 2008, December 27, 2008, October 14, 2009, October 18, 2009, and October 25, 2009, the Plaintiff sent taunting emails to the Defendant wherein she admitted, inter alia, to removing $100,000 from a joint account, and demanding $7,500 for the dogs she removed from the home or "the dogs are gone." Copies of these emails were provided to prior counsel by a letter dated August 12, 2013. Further, she may obtain this information as many of these accounts, if not all, were joint. Given these facts, the Defendant objects to reconstructing these records as such would be obdurate, vexatious, and unduly burdensome. The parties recently had a four-party conference with prior counsel and these items and information were not in dispute. 4. The Plaintiff has repeatedly entered the marital residence since the date of separation during the period in question and removed all documents and furniture from the residence. Moreover, the Plaintiff has been represented by at least three (3) prior attorneys and much of this information was provided to prior counsel or, is in the Plaintiffs sole possession and control as she continuously removed furniture and documents from the home. On December 15, 2008, December 27, 2008, October 14, 2009, October 18, 2009, and October 25, 2009, the Plaintiff sent taunting emails to the Defendant wherein she admitted, inter alia, to removing $100,000 from a joint account, and demanding $7,500 for the dogs she removed from the home or "the dogs are gone." Copies of these emails were provided to prior counsel by a letter dated August 12, 2013. Further, she may obtain this information as many of these accounts, if not all, were joint. Given these facts, the Defendant objects to reconstructing these records as such would be obdurate, vexatious, and unduly burdensome. The parties recently had a four-party conference with prior counsel and these items and information were not in dispute. 5. The Plaintiff has repeatedly entered the marital residence since the date of separation during the period in question and removed all documents and furniture from the residence. Moreover, the Plaintiff has been represented by at least three (3) prior attorneys and much of this information was provided to prior counsel or, is in the Plaintiffs sole possession and control as she continuously removed furniture and documents from the home. On December 15, 2008, December 27, 2008, October 14, 2009, October 18, 2009, and October 25, 2009, the Plaintiff sent taunting emails to the Defendant wherein she admitted, inter glia, to removing $100,000 from a joint account, and demanding $7,500 for the dogs she removed from the home 1• ' , or "the dogs are gone." Copies of these emails were provided to prior counsel by a letter dated August 12, 2013. Copies of the Defendant's pension information was provided to counsel previously by letter and at a hearing for APL. During the course of the hearing, the Support Master specifically informed the Plaintiff that she would be waiving her interest in the Defendant's pension if she insisted that the payments he was receiving at the time from his ion purposes. Given these facts, the Defendant pension were included as income for calculat objects to reconstructing these records as such would be irrelevant for distribution purposes and obdurate, vexatious, and unduly burdensome. The parties recently had a four-party conference with prior counsel and these items and information were not in dispute. G. The Plaintiff has repeatedly entered the marital residence since the date of separation during the period in question and removed all documents and furniture from the residence. Moreover, the Plaintiff has been represented by at least three (3) prior attorneys and much of this information was provided to prior counsel or, is in the Plaintiffs sole possession and control as she continuously removed furniture and documents from the home. On December 15, 2008, December 27, 2008, October 14, 2009, October 18, 2009, and October 25, 2009, the Plaintiff sent taunting emails to the Defendant wherein she admitted, inter alia, to removing $100,000 from a joint account, and demanding $7,500 for the dogs she removed from the home or "the dogs are gone." Copies of these emails were provided to prior counsel by a letter dated August 12, 2013. The Defendant owns the same vehicle that he had when the parties separated. It is the Plaintiff that has obtained several different vehicle during the time in question. Given these facts, the Defendant objects to reconstructing these records as such would be obdurate, vexatious, and unduly burdensome. The parties recently had a four-party conference with prior counsel and these items and information were not in dispute. 7. The Defendant has a term life insurance policy through his employer. This has never been an item of contention. 8. None. Respectfully submitted; 1 ' � b tGaKelley ID No. 46801 3117 Chestnut Str Camp Hill, PA 17011 (717) 612-1484 VERIFICATION I verify that the statements made in this Response are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: f NASRIN GOULPOSHAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-7330 CHARLES E. PAINTER, CIVIL ACTION - DIVORCE Defendant . CERTIFICATE OF SERVICE I, GARY L. KELLEY, Esquire, attorney for Defendant in the above-captioned matter, do hereby certify that I served a true and correct copy of DEFENDANT'S RESPONSE TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS on Plaintiffs counsel on the 25th day of July, 2014, by First Class U.S. Mail, postage prepaid, addressed as follows: Courtney K. Powell, Esq. P.O. Box 650 Hershey, PA 17033 LAW OFFICES OF GARY L. LLEY _&4 L � GARY KELLEY, s uire LD. #4 A8k 1 3117 Chestnut Street Camp Hill, PA 17011 (717) 612-1484 Attorney for Defendant Exhibit "E " ANDREOZZI BENJAMIN D.ANDREOZZI Member Multi-Million Dollar Advocates Forum & ASSOCIATES , P. C . HEATHER VERCHICK ATTORNEYS AT LAW August 8, 2013 Gary L. Kelley, Esquire 3117 Chestnut Street Camp Hill, Pa 17011 RE: Golpoushan v. Painter,No. 09-7330 Dear Attorney Kelley: Enclosed,please find our Interrogatories and Request for Production of Documents directed towards your client, Charles Painter. Please provide responses no later than September 9, 2013. Thank you for your attention to this matter. Sincerely, Heather E. Verchick 215 Pine Street, Suite 200• Harrisburg, PA 17101 P: 717.525.9124 F: 717.525.9143 www.midstatelaw.rnm HU(9—iL�—c�01-5 14:U1 FKUM:(aHKY L KELLEY 7176121761 70:5259143 P.1/6 'r Law Ofliucs of Gary L. Kelley 1119 North Front Streer I-Wrisburg, Pennsylvania 17102 (717) 238-1494 Fax (717) 238-1761 August 12, 2013 Heather E. Verchick, Esq. 215 Pine Street, Suite 200 Elarrnsburg, PA 17'101 BY FACSIMILE TRANSMISSION ONLY TO (717) 525-9143 Re Golpoushan v Painter Dear Heather' Plea_fe find enclosed a series of emails from your client to my client. They are dated December 15, 2008, December 27, 2008, October 14, 2009, October 18, 2009, and November 25, 2009 !n them, you wilt read, inter glia, that She admitted to having; an affair, that she is a liar and can't be trusted, that she wanted $7,500 for the dogs or "the dogs are gone", and that she admitted to taking; $100,000 from an account. In light of these emails, I respectfully request that you withdraw your Interrogatories and Request for Production 1 believe that this matter can be handled in a much friendlier and, productive fashion. Perhaps we should consider a four party conference. Otherwise, 1 will be serving; you with i ser of friterrogatories as well and Request For Admissions. I would prefer not to proceed in that fashion but If I am forced to file any Emergency .Relief, I can assure you that these emails with be a part of the pleading and will be included as exhibits. 1 am still awaiting your client's cooperation in signing the listing agreement. I look forward to hearing; from you in the next two (2} business days regarding her cooperation Otherwise. I will file for Extraordinary Relief and I wall seek counsel fees in light of your promised C00peration. Thank your for your attention to this matter. Very truly yo r , Gary elley Enclosures: Decemb4r 15 and 27, 2008, Oeto er 14 and 18, and November 25, 2009 emails cc. Charles Painter Received Time Auo. 12. 2013 2: 24PM No. 3150 VERIFICATION The undersigned, Courtney Kishel Powell, Esquire, of JSDC Law Offices, Hershey, Pennsylvania, hereby certifies that the foregoing Plaintiff's Motion to Compel Responses to Plaintiff's First Request for Production of Documents, Motion to Strike Defendant's Response to Plaintiff's First Request for Production of Documents and Plaintiff's Request for Sanctions has been prepared by me by knowledge and information acquired during the course of my representation of Plaintiff, Nasrin Golpoushan; and that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. l Date: , 2014 COURTNEY &nq WELL, Esquire VERIFICATION I,NASRIN GOLPOUSHAN,verify that the statements made in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date: — -- , 2014 R NASRIN GOL US A NASRIN GOLPOUSHAN, : IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner, : CUMBERLAND COUNTY, PENNSYLVANIA V. CASE NO. 09-7330 CHARLES E. PAINTER, CIVIL ACTION—LAW Defendant/Respondent. IN DIVORCE CERTIFICATE OF SERVICE I, Courtney K. Powell, Esquire, with JSDC Law Offices, attorneys for the Plaintiff/Petitioner, Nasrin Golpoushan, hereby certify that I have served a copy of the foregoing Plaint's Motion to Compel Responses to Plaintiff's First Request for Production of Documents, Motion to Strike Defendant's Response to Plaintiff's First Request for Production of Documents, and Plaintiffs Request for Sanctions on the following on the date and in the manner indicated below: VIA U.S.MAIL FIRST CLASS PRE-PAID Gary L. Kelley, Esquire 3117 Chestnut Street Camp Hill, PA 17011 Attorney for Defendant/Respondent JSDC LAW OFFICES Dated: + 01 ' 2014 By: Courtney K. Pow$,Esquire Attorney Pa. I.D. 141509 P.O. Box 650 Hershey,PA 17033-0650 (717) 533-3280 Attorneys for Plaintiff/Petitioner, Nasrin Golpoushan NASRIN GOLPOUSHAN, IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner, CUMBERLAND COUNTY, PENNSYLVANIA V. CASE NO. 09-7330 CHARLES E. PAINTER, CIVIL ACTION— LAW Defendant/Respondent. IN DIVORCE CERTIFICATE OF SERVICE I, Courtney Kishel Powell, Esquire, with JSDC Law Offices, attorney for the Plaintiff, Nasrin Golpoushan, hereby certify that I have served a copy of the Praecipe for Disposition on the following on the date and in the manner indicated below: U.S.MAIL,FIRST CLASS,PRE-PAID Gary L. Kelley, Esquire 3117 Chestnut Street Camp Hill, PA 17011 JSDC LAW OFFICES Dated: `\ ,2014 By: urtney Kis el P ell Attorney I.D. P.O. BOX 650 Hershey,PA 17033-0650 (717) 533-3280 Attorneys for Plaintiff, Nasrin Golpoushan NASRIN GOLPOUSHAN, Plaintiff v. CHARLES E. PAINTER, Defendant !LED-O: FICE ' H PPOTHO; OT 2OI4 QCT 28 PH I: 04 CUMBERLAND COUNTY PENNSYLVANIA County of i umberlgnb IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT 2009-7330 CIVIL TERM IN DIVORCE IN RE: PLAINTIFF'S MOTION TO COMPEL RESPONSES TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS, MOTION TO STRIKE DEFENDANT'S RESPONSE TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS, AND PLAINTIFF'S REQUEST FOR SANCTIONS ORDER OF COURT AND NOW, this 27th day of October 2014, upon consideration of Plaintiff's Motion to Compel Responses to Plaintiff's First Request for Production of Documents, Motion to Strike Defendant's Response to Plaintiff's First Request for Production of Documents, and Plaintiff's Request for Sanctions, the Motion is GRANTED in part. Defendant is DIRECTED to respond to Plaintiff's request for the Production of Documents as made in its First Request. Full and complete responses to the discovery requests of 8 August 2013 shall be provided to Plaintiff within twenty (20) days of this Order. Plaintiff's request to strike Husband's Responses to the First Discovery Request and Plaintiff's request for Attorney's fees are DENIED. D' tribution: 9urtney K. Powell, Esq. ./Gary L Kelley, Esq eU teE.s flt t LL P ,�.at(f BY TH Thoma Alacey. C.P.J.