HomeMy WebLinkAbout09-8902
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
CUMBERLAND COUNTY
Joseph T. Zume, Civil Action - Law
Plaintiff,
V. No.
?9/l02 ?lU? l'f'h1
Blessing Zume,
Defendant In Divorce a.v.m.
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in Court. If you wish to defend against the claims set forth in the
following pages, you must take prompt action. You are warned that if you fail to do so, the case
may proceed without you and a decree of divorce or annulment may be entered against you by
the Court. A judgment may also be entered against you for any other claim or relief requested in
these papers by the plaintiff. You may lose money or property or other rights important to you,
including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the office of
the Prothonotary at the Cumberland County Courthouse, 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 CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Pennsylvania Bar Association - Lawyer Referral Service
Telephone 1-800-692-7375 (PA ONLY)
or 717-238-6715
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the Court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the Court. You must attend the scheduled conference or hearing.
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
CUMBERLAND COUNTY
Joseph T. Zume, Civil Action - Law
Plaintiff,
V.
No.
Blessing Zume,
Defendant In Divorce a.v.m.
COMPLAINT UNDER SECTION 3301(a) OR 3301(c) OR 3301(d)
OF THE DIVORCE CODE
COUNTI
DIVORCE
1. Plaintiff is Joseph T. Zume, a sui juris adult, who currently resides at 3 Holly Court,
Shippensburg, Cumberland County, Pennsylvania.
2. Defendant is Blessing Zume, a sui juris adult, who currently resides at No. 14, 41h
Avenue, off Ter Guma Street, North-Bank, Makurdi, Benue State, Nigeria.
3. Plaintiff has been bona fide resident in the Commonwealth for at least six months
immediately prior to the filing of this Complaint.
5. There have been no prior actions of divorce or annulment of marriage between the
parties except the action represented by this Complaint.
6. Plaintiff and Defendant were married in March 2007 in Norman Oklahoma.
7. The marriage is irretrievably broken.
8. Neither the Plaintiff nor Defendant is a minor or incompetent.
9. Plaintiff has been advised that counseling is available and that Plaintiff may have the
right to request that the court require the parties to participate in counseling.
10. Neither Plaintiff nor Defendant is in the military or naval service of the United States
or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the
Congress of 1940 and its amendments.
WHEREFORE, if both parties file affidavits consenting to a divorce after ninety
(90) days have elapsed from the date of the filing of this Complaint, Plaintiff respectfully
requests that the Court enter a Divorce Decree pursuant to Section 3301(c) of the Divorce
Code. If the parties have lived separate and apart for a period of at least two years at the
time of the entrance of a hearing, Plaintiff respectfully requests that the Court enter a
Decree in Divorce pursuant to Section 3301 (d) of the Divorce Code.
COUNT II
REQUEST FOR A FAULT DIVORCE UNDER SECTION 3301(a)(6) OF THE
DIVORCE CODE
11. The prior paragraphs of this Complaint are incorporated herein by reference as though
set forth in full.
12. Defendant has offered such indignities to Plaintiff, who is the innocent and injured
spouse, so as to render Plaintiffs condition intolerable and life burdensome.
13. This action is not collusive as defined by Section 3309 of the Divorce Code.
WHEREFORE, Plaintiff respectfully requests that the Court enter a Decree of
Divorce pursuant to Section 3301(a)(6) of the Divorce Code.
COUNT III
EQUITABLE DISTRIBUTION SECTION 3502
14. The allegations of paragraphs 1 through 9 hereof are incorporated herein as fully as
though set out at large.
15. The parties have been unable to determine and equitably dispose of their respective
rights and interests in the marital property.
14
16. Plaintiff will, within 60 days after service of this Complaint upon the Defendant, cause
to be filed an inventory and appraisement of all property owned or possessed at the time
this Complaint is filed.
WHEREFORE, Plaintiff requests your Honorable Court to equitably divide,
distribute and assign the marital property pursuant to the provisions of Section 3502 of the
Divorce Code.
Respectfully submitted:
i
Date: Z3 By:
M. Teri Mall Stiltner, Esquire
Attorney I.D. No. 86337
The Professional Arts Building
25 Penncraft Avenue, Suite 310
Chambersburg, Pennsylvania 17201
(717) 262-9091
Attorney for Plaintiff
? t
I verify that the statements made in this Complaint are true and correct, and
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: l 9? /c2 9 02
0E_ 0 i0 F Ec: 5R, 113r
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ss
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Joseph T. Zume,
Plaintiff,
V.
Blessing Zume,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
IN DIVORCE a.v.m.
NO.09-8902 CIVIL TERM
ACCEPTANCE OF SERVICE
TO THE PROTHONOTARY:
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I, Allison Weber, Certified Legal Intern representing the Defendant, Blessing Zume in
the above captioned matter, certify that I accept service of a true and correct copy of the
Complaint in Divorce on or about January 25, 2010, and I certify that I am authorized to do so on
behalf of Defendant, Blessing Zume,
Date 2. 2.10
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Allison e er
Certified Legal Intern
(/' ,
Anne ac na d-Fox, Esqu
Supervisin Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
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Joseph Zume, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v. : CIVIL ACTION - LAW
: IN DIVORCE ' `-.,
Blessing Zume, : rriri 7;,:.
Defendant : NO. 09 - 8902 CIVIL TERM ,r`
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MOTION FOR APPOINTMENT OF MASTER
Blessing Zume, Defendant, moves the Court to appoint a Master with respect to the~
following claims:
(X) Divorce (X) Distribution of Property
O Annulment O Support
( ) Alimony ( ) Counsel Fees
( ) Alimony Pendente Lite () Costs and Expenses
Defendant, in support of the motion, states:
1. Discovery is complete as to the claims for which the appointment of a master is
requested.
2. The Plaintiff has appeared in the action by his attorney, Marylou Matas, Esq.
3. The Statutory grounds for divorce are 23 Pa. C.S. § 3301(d).
4. Delete the inapplicable paragraph(s):
a. The action is contested with respect to the following claims:
i. Defendant is entitled to an equitable distribution of Plaintiff's TIAA-
CREF pension account via a Qualified Domestic Relations Order
transferring Defendant $12,500.00 from the pension plan.
5. The action does not involve complex issues of law or fact.
6. The hearing is expected to take two (2) hours.
7. Additional information, if any, relevant to the motion:
a. A portion of Plaintiff's October 1, 2009—December 31, 2009 pension account
statement("Exhibit A") which shows Plaintiff's pension account balance as of
December 31, 2009. The parties were separated in December of 2009.
b. A portion of Plaintiff's July 1, 2009—September 30, 2009 pension account
statement("Exhibit B") which shows Plaintiff's TIAA-CREF account numbers on
"page 2 of 12" of the statement.
c. A letter("Exhibit C") confirming that Plaintiff used the federal first time
homebuyers tax credit to purchase his current residence, and the tax credit was
awarded to Plaintiff in 2009, a year in which the parties filed as married filing
jointly. If Plaintiff had filed as married filing separately, the tax credit would
have only been $4,000, not the $8,000 he received. Because the parties filed
jointly, Defendant is no longer permitted to use this first time homebuyer's credit
for herself, and Plaintiff enjoyed an extra$4,000 in tax credit applied to equity in
a home titled solely in Plaintiff's name. Thus, when Defendant goes to purchase
her own home, it will cost her an additional $4,000 due to the lost tax credit, and
Plaintiff has been unjustly enriched $4,000 by using Defendant's one-time tax
credit without repayment thereof. Please see 26 USC§36—First-Time
Homebuyer Credit.
Date:
Robert E. Je.V
Certified Lega Intern
4 K-(1- 4-41 _
THOM N M. PLACE
ROBERT E. RAINS
MEGAN RIESMEYER
Supervising Attorneys
COMMUNITY LAW CLINIC
371 West South Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 241-3596
T1AH r r
CREF .
PNQ6216Q/0048/0012/01100000 FINANCIAL SERVICES
ill'1'1 1 1 l'11'l i l'11 I I 1111/111 111 I'1 111"I 111 l t'I I I I I l l I I 1 I l'11 FOR THE GREATER GOOD'
JOSEPH T ZUME 730 Thect Avenue New York.NY 10017-3206
3 HOLLY CT
SHIPPENSBURG PA 17257-8749
Quarterly Retirement
Portfolio Statement
October 01, 2009 -December 31, 2009
•
For
JOSEPH T ZUME
Customer Service Portfolio Summary
Website: www.tiaa-cref.org This Period Year-to-Date
Automated 24 hour Information: 800 842-2252 Beginning Balance $18,669.66 $9,506.04
Personal Assistance 800 842-2776
Monday-Friday, 8:00 AM-10:00 PM Eastern Additions 2,390.08 14,306.81
Saturday, 9:00 AM-6:00 PM Eastern Reductions 0.00 -4,724.62
Call 800 842-2776 if you have any questions or would like to Gain/Loss 681.58 2,653.09
discuss any other information on your statement. To view your Ending Balance $21,741.32 $21,741.32
most current account information, go to our website at
www.tiaa-cref.org and log-in with your user ID and password.
Important Note: Please review your statement and let us
know promptly of any inaccuracies. To protect your rights, you
should also notify us in writing. Unless we receive written
notification within 60 days,we will assume our information is
correct.
Retirement Income Projection
As part of your retirement savings planning, have you To raise your savings rate or further personalize the retirement
considered how much you need to retire? Saving a little more income projection,visit us online at www.tiaa-cref.org or call
now can add up by the time you retire. These charts are purely TIAA-CREF at 800-842-2776. Recent changes to your
hypothetical and do not illustrate past or projected _.. contribution amounts may not be reflected on this statement.
performance. Example of Monthly Income at Age 65
What can you expect from Retirement Income?
$2,708
Monthly Sample Lifetime $2,356
Monthly Contribution Retirement Monthly $2,121
Contribution Increased by Income at Age 65
$799 $0 $2,121
$899 $100 $2,356 ■
$1,049 $250 $2,708
Current monthly Increase Increase
contribution contribution by contribution by
$799 $100 $250
Message Board
"Learn about new legislation that opens up Roth IRA conversions to anyone beginning in 2010. In addition, for conversions in
2010 only, individuals can pay the applicable taxes in 2010 or split the payments between 2011 and 2012. Call 800-373-1664
to learn more."
Please refer to the back of this statement for Glossary Terms.
TIM-CREF Individual&Institutional Services,LLC distributes securities Page 1 of 11
products. Data compiled from other entities as noted.
Quarterly Retirement JOSEPH T ZUME
Portfolio Statement
October 01, 2009 - December 31, 2009
Personalized Rate of Return
This Period 3.5% This figure is an estimate of the performance of the assets in
Year-to-Date 16.3% your retirement portfolio, as reflected on this statement, that
are maintained at TIAA-CREF during the period(s) specified.
Past performance is not a guarantee of future results. Please
refer to the Disclosures Section for more information.
Asset Allocation Summary
Current
Percent Asset Class Current Value
sa
® 64% Equities $13,994.46
11% Real Estate 2,378.01
If you are invested in more than NNE 20% Axed Income 4,335.47
one asset class, the Asset
-, Allocation Percentages may not 1 5% Money Market 1,033.38
-.1'.;,, s„.;., be exact due to rounding. 100% Total $21,741.32
Activity Summary by Asset Class
Asset Class/ Beginning Balance Ending Balance
Investment as of 10/01/2009 Additions Reductions Gain/Loss as of 12/31/2009
Equities
CREF Stock $2,974.69 $358.54 $0.00 $156.55 $3,489.78
CREF Growth 2,923.68 358.54 0.00 241.30 3,523.52
CREF Equity Index 1,944.35 238.91 0.00 119.59 2,302.85
CREF Global Equities 1,984.72 239.05 0.00 94.86 2,318.63
T-C Gr& Inc-Rtmt 981.34 119.49 0.00 40.70 1,141.53
T-C Real Est Secs-Rtmt 997.29 119.56 _ 0.00 101.30 1,218.15
Total Equities $11,806.07 $1,434.09 $0.00 $754.30 $13,994.46
Real Estate
11AA Real Estate $2,134.30 $358.47 $0.00 -$114.76 $2,378.01
Axed Income
CREF Bond Market $1,925.55 $238.98 $0.00 $6.91 $2,171.44
CREF Infl Linked Bond 1,889.86 239.05 0.00 35.12 2,164.03
Total Axed Income $3,815.41 $478.03 $0.00 $42.03 $4,335.47
Money Market
CREF Money Market $913.88 $119.49 $0.00 $0.01 $1,033.38
Total Account Value $18,669.66 $2,390.08 $0.00 $681.58 $21,741.32
Please review the "TIAA-CREF Quarterly Performance" card that accompanies this statement. The card shows the current
effective annual interest rates for the TIM Traditional and TIM Stable Return annuities, along with the date on which new
interest rates will be declared. The card also shows how TIAA-CREF investments performed. Not all of the options shown on the
card may be available to you.
Portfolio Breakdown
Beginning Balance Ending Balance
as of 10/01/2009 as of 12/31/2009
Plans
PA STATE SYSTEM OF HIGHER ED ALT RETIREMENT PLAN $18,669.66 $21,741.32
Page 2 of 11
*MOM10.04806:0:j006Z*
•
TIAA
CREF
PNQ6219Q/0055/0012/01100000
IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII'IIIIIIII'IIIIIIIIIII'I'IIIII"I FINANCIAL SERVICES
FOR THE GREATER GOOD"
DR JOSEPH T ZUME 730 Third Avenue New York.NY 10017-3206
3 HOLLY CT
SHIPPENSBURG PA 17257-8749
Quarterly Retirement
Portfolio Statement
July 01, 2009- September 30, 2009
For
DR JOSEPH T ZUME
Customer Service Portfolio Summary
Website: www.tiaa-cref.org This Period Year-to-Date
Automated 24 hour Information: 800 842-2252 Beginning Balance $14,008.17 $9,506.04
Personal Assistance 800 842-2776
Monday- Friday, 8:00 AM -10:00 PM Eastern Additions 7,712.40 11,916.73
Saturday, 9:00 AM-6:00 PM Eastern Reductions -4,724.62 4,724.62
Call 800 842-2776 if you have any questions or would like to Gain/Loss 1,673.71 1,971.51
discuss any other information on your statement. To view your
most current account information, go to our website at Ending Balance $18,669.66 $18,669.66
www.tiaa-cref.org and log-in with your user ID and password.
Important Note: Please review your statement and let us
know promptly of any inaccuracies.To protect your rights, you
should also notify us in writing. Unless we receive written
notification within 60 days, we will assume our information is
correct.
Retirement Income Projection
As part of your retirement savings planning, have you To raise your savings rate or further personalize the retirement
considered how much you need to retire? Saving a little more income projection, visit us online at www.tiaa-cref.org or call
now can add up by the time you retire.These charts are purely TIAA-CREF at 800-842-2776. Recent changes to your
hypothetical and do not illustrate past or projected contribution amounts may not be reflected on this statement.
performance.
Example of Monthly Income at Age 65
What can you expect from Retirement Income?
Monthly Sample Lifetime $2,674
$2.321
Monthly Contribution Retirement Monthly $2,086
Contribution Increased by Income at Age 65
$799 $0 $2,086
$899 $100 $2,321
$1,049 $250 $2,674
Please refer to the disclosures and assumptions at the back of Current monthly Increase Increase
this statement for more information. contribution contribution by contribution by
$799 $100 $250
Message Board
Are Your Investments Living Up to Their Potential? Make a Change for the Good with a TIAA-CREF Advice Session. To schedule,
simply call us at 866 843-0338 or go to www.tiaa-cref.org/planning. C45786
•
Please refer to the back of this statement for Glossary Terms.
TIAA-CREF Individual& Institutional Services, LLC distributes securities Page 1 of 12
products. Data compiled from other entities as noted.
Quarterly Retirement ( DR JOSEPH T ZUME
Portfolio Statement
July 01, 2009 -September 30, 2009
Personalized Rate of Return
This Period 10.6% This figure is an estimate of the performance of the assets in
Year-to-Date 12.4% your retirement portfolio, as reflected on this statement, that
are maintained at TIAA-CREF during the period(s) specified.
Past performance is not a guarantee of future results. Please
refer to the Disclosures Section for more information.
Asset Allocation Summary
Current
Percent Asset Class Current Value
ME 64% Equities $11,806.07
- 11% Real Estate 2,134.30 _
If you are invested in more than ® 20% Fixed Income 3,815.41
one asset class,the Asset
7
I- Allocation Percentages may not I 5% Money Market 913.88
be exact due to rounding. 100% Total $18,669.66
Activity Summary by Asset Class
Asset Class/ Beginning Balance Ending Balance
Investment as of 07/01/2009 Additions Reductions Gain/Loss as of 09/30/2009
Equities
CREF Stock $1,730.85 $1,175.03 -$363.43 $432.24 $2,974.69
CREF Growth 1,760.55 1,175.04 -363.43 351.52 2,923.68
CREF Equity Index 1,139.22 783.36 -242.29 264.06 1,944.35
CREF Global Equities 1,145.57 783.34 -242.29 298.10 1,984.72
T-C Gr&Inc-Rtmt 580.01 391.68 -121.15 130.80 981.34
T-C Real Est Secs-Rtmt 490.18 391.72 -121.15 236.54 997.29
Total Equities $6,846.38 $4,700.17 -$1,453.74 $1,713.26 $11,806.07
Real Estate
TIAA Real Estate $1,482.67 $1,174.99 -$363.42 -$159.94 $2,134.30
Fixed Income
CREF Bond Market $1,316.56 $783.38 -$242.29 $67.90 $1,925.55
CREF Infl Linked Bond 1,296.37 783.33 -242.28 52.44 1,889.86
Total Fixed Income $2,612.93 $1,566.71 -$484.57 $120.34 $3,815.41
Money Market
CREF Money Market $3,066.19 $270.53 -$2,422.89 $0.05 $913.88
Total Account Value $14,008.17 $7,712.40 -$4,724.62 $1,673.71 $18,669.66
Portfolio Breakdown
Beginning Balance Ending Balance _
as of 07/01/2009 as of 09/30/2009
Plans
PA STATE SYSTEM OF HIGHER ED ALT RETIREMENT PLAN $14,008.17 $18,669.66
Annuities In Your Plans
...1:111A3521_2.6 A-2 CREF 459162A-0 i ) c $10,515.12 $16,691.03
�A 365385A-0,CREF 465385A-8 fie 4-1- , 2,422.86 0.00
Total Annuities In Your Plans $12,937.98 $16,691.03
Page 2 of 12
*M000100550601006Z*
All 855(06/091
Law Offices of
SAIDIS, SULLIVAN & ROGERS
A PROFESSIONAL CORPORATION
26 WEST HIGH STREET
ROBERT C.SAIDIS CARLISLE,PENNSYLVANIA 17013 LEMOYNE OFFICE:
DANIEL L.SULLIVAN TELEPHONE:(717)243-6222-FACSIMILE:(717)243-6486 635 NORTH 12T"STREET,sTE.400
ELYSE E.ROGERS EMAIL:attorney @ssr-attorneys.com LEMOYNE,PA 17043
JOHN A.FEICHTEL www.ssr-attorneys.com TELEPHONE:(717)612-5800
DEAN E.REYNOSA FACSIMILE: (717)612-5805
TODD F.TRUNTZ
MARYLOU MATAS Of Counsel
SEAN M.SHULTZ JOHN E.SLIKE
ROBERT B.HAMILTON STEPHEN L.GROSE
HANNAH WHITE-GIBSON
REPLY TO CARLISLE
December 26, 2012
Robert E. Jeppson, Certified Legal Intern
Community Law Clinic
371 West South Street
Carlisle, PA 17013
RE: Zume v. Zume
Docket No.: 09-8909
Dear Mr. Jeppson:
I am sorry we did not get to speak on December 21, 2012, regarding the Property
Settlement Agreement. I did however speak with Mr. Zume regarding the distribution of funds
from his TIAA-CREF and your client's assertion that the funds should instead be paid in cash.
I have reviewed the file on this matter as well as reviewing with Mr. Zume the purchase
of the home in 2010. For your information the home was purchased and he did receive the first
time home buyers credit. He could have claimed the credit either in 2009 or in the 2010 tax
year. However, because he took a loan from his 401(k) to pay for settlement costs he opted to
claim that credit in the 2009 tax year in order to receive the credit more immediately. The
parties had already filed their 2009 income tax return and this required an amended 2009
return. You indicated your client cooperated with that return and that maybe true, however she
had no income to report and so it is slightly disingenuous to argue that my client received any
additional funds because of her cooperation. Mr. Zume would have received this same credit
had he opted to claim this credit in the 2 009 tax year Cr the 2010 tax year. In fact he previeasly
shared the 2009 income tax refund with her equally, despite the fact that she had no reportable
------------------income-and-had-separated-from-him-earlier_in-the year. The-children_had-been_residing_with Mr. _____________
Zume for at least six (6) months of the 2009 year and he had been providing for their primary
support.
When Mr. Zume received the funds from this tax credit he used the funds to pay the
401(k) loan used for settlement costs. The original amount of the loan was almost $6,000.00.
In addition because your client did not sign the check when it was first received Mr. Zume paid
the loan over a period of more than six (6) months incurring fees, costs and interest. Therefore,
the $8,000.00 tax credit was not received by him as cash or any benefit it was used entirely to
pay this loan. Your client's argument that Mr. Zume has received some additional benefit or
asset simply has no merit.
Robert E. Jeppson, Certjr Legal Intern
December 26, 2012 -=.-- f
Page 2
With that said Mr. Zume is willing only to transfer the $12,500.00 as a roll-over from his
TIAA-CREF account. He does not have cash and is not willing to withdraw the funds inquiring
an early withdraw penalty and tax penalty to do so. He will roll-over the funds by way of a
Qualified Domestic Relations Order. If your client needs to withdraw the funds once she
receives them she will need to do so at her cost. As we discussed I would encourage your
client to explore hardship exception options. Furthermore she very likely has a lower tax rate
then Mr. Zume and would likely suffer fewer penalties by withdrawing these funds herself.
I will be happy to prepare an agreement and even the final Qualified Domestic Relations
Order so this matter can be completed as quickly as possible once you have confirmed with me
that this is satisfactory. I will look forward to hearing from you.
Very Truly Yours,
SAIDIS, S LLIVAN & ROGERS
Wk\-L [WAIQvy—__
Marylou 'tas, Esquire
MM/tlp
cc: Joseph T. Zume
i
/ J
Joseph Zume, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
IN DIVORCE
Blessing Zume,
Defendant NO. 09 - 8902 CIVIL TERM
ORDER APPOINTING MASTER
AND NOW, this R day of �{�, , 2013,
Robert Elicker, Esquire is appointed master with respect to the following claims: Equitable
distribution of Plaintiff's TIAA-CREF pension account via a Qualified Domestic Relations
Order.
By the Court:
C-:a
J.
CI
t3 CIJI
17.",
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JOSEPH T. ZUME IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 09-890 CIVIL TERM ..j
r1
BLESSING ZUME CIVIL ACTION — LAW ' ' _
Defendant IN DIVORCE �3>
ES ;.
PLAINTIFF'S AFFIDAVIT OF CONSENT ' ='
c-n
1. A Complaint in Divorce under§ 3301(c) of the Divorce Code was filed December 30,
2009.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. 1 consent to the entry of a final Decree in Divorce after service of notice of intention
to request entry of the Decree.
I verify that the statements made in this Affidavit are true and correct to the best of my
knowledge, information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities.
Date: q//5/1-,2 —
Joseph T. Zume
PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER§3301 (c)OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
Law Offices of
Saidis 3. 1 understand that I will not be divorced until a Divorce Decree is entered by the Court
Sullivan and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary.
& Rogers I verify that the statements made in this Affidavit are true and correct to the best of my
26 West High Street
Carlisle,PA 17013
knowledge, information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities.
Date:
Joseph T. ume
JOSEPH T. ZUME IN THE COURT OF COMMON PLE# F � 4 '`=
Plaintiff CUMBERLAND COUNTY, PENNSY V
c1 ,
V. NO. 09-8901 CIVIL TERM
c3
BLESSING ZUME CIVIL ACTION — LAW -
Defendant IN DIVORCE � -.
F °
DEFENDANT'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under§ 3301(c) of the Divorce Code was filed December 30,
2009.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. 1 consent to the entry of a final Decree in Divorce after service of notice of intention
to request entry of the Decree.
I verify that the statements made in this Affidavit are true and correct to the best of my
knowledge, information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities.
Date: h
Blessing Zume
DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER) 3301 (c) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
Law Offices of 3. 1 understand that I will not be divorced until a Divorce Decree is entered by the Court
Saiclis and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary.
Sullivan
S Rogers I verify that the statements made in this Affidavit are true and correct to the best of my
26 West High Street knowledge, information and belief. I understand that false statements herein are made subject to the
Carlisle,PA 17013
penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities.
Date:
Blessing Zume
JOSEPH T. ZUME IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 09-890?CIVIL TERM
BLESSING ZUME CIVIL ACTION — LAW_
Defendant IN DIVORCE
ORDER OF COURT
AND NOW, this 28° day of Ayew` 20__e_, the economic
claims raised in the proceedings having been resolved in accordance with a Martial
Settlement Agreement dated August 15, 2013, the appointment of Master is vacated and
counsel can file a Praecipe transmitting the record to the Court requesting a final decree in
divorce.
BY THE COURT,
J.
cc: � Marylou Matas, Esquire
Counsel for Plaintiff
,, fohnathan Vega, Certified Legal Intern
Counsel for Defendant
&I
Law Offices of C.
Saidis ,,,vr, =
Sullivan r
& Rogers ,_ ._.,
26 West High Street •�;C:7 3"�..
Carlisle,PA 17013 C7:.
C'3 "
---
JOSEPH T. ZUME IN THE COURT OF COMMON PLEAS =T°`
M. �
Plaintiff CUMBERLAND COUNTY, PENNSYLVAlf� G5 -zit
in r` CA3 = ti
-aC CD t'
V. NO. 09-890,ZCIVIL TERM
BLESSING ZUME CIVIL ACTION- LAW
Defendant . IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Kindly transmit the record, together with the following information, to the Court for
entry of a Decree in Divorce:
1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the
Divorce Code.
2. Date and manner of service of the Complaint: December 30, 2009, accepted
service of the Complaint on January 25, 2010, via Acceptance of Service. Proof of service
was filed with the Court on February 9, 2010.
3. Date Affidavit of Consent required under Section 3301(c) or(d) of the Divorce
Code was signed:
By Plaintiff: August 15, 2013 and filed with the Prothonotary on August 16, 2011
By Defendant: July 29, 2013 and filed with the Prothonotary on August 16, 2013.
4. Related claims pending: Resolved by the Marital Settlement Agreement dated
August 15, 2013.
5. Date Waiver of Notice under Section 3301(c) of the Divorce Code was signed:
By Plaintiff: August 15, 2013 and filed with the Prothonotary on August 16, 2013.
By Defendant: July 29, 2013 and filed with the Prothonotary on August 16, 2013.
Law Offices of
Saidis SAIDIS, SULLIVAN & ROGERS
Sullivan � ,�u
& Rogers Date: 2f)
26 West High Street Marylou M@ y, Esquire
Carlisle,PA 17013 Supreme Court ID No. 84919
26 West High Street
Carlisle, PA 17013
717-243-6222
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Joseph T. Zume
V.,
Blessing Zume NO. 09-89OZ
DIVORCE DECREE
AND NOW, 13 0 _26 /2 it is ordered and decreed that
Joseph T. Zume plaintiff, and
Blessing Zume defendant, are divorced from the
bonds of matrimony.
Any existing spousal support order shall hereafter be deemed an order for
alimony pendente lite if any economic claims remain pending.
The court retains jurisdiction of any claims raised by the parties to this action
for which a final order has not yet been entered. Those claims are as follows: (if no
claims remain indicate "None.")
A Marital Settlement Agreement dated August 15, 2013, is incorporated but not
merged.
By the Court,
Attest- J.
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