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Home My WebLink About09-8925Sandra L. Meilton, Esquire Lindsay Gingrich Maclay, Esquire Daley Zucker Meilton Miner & Gingrich, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 smeiltonndzmmglaw.com lmaclayaa,dzmmg_law.com KIMBERLY D. NEUMYER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 07 - 8U5 CIVIL TERM STEVEN M. NEUMYER, : CIVIL ACTION - LAW Defendant : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim 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 Court House, Carlisle, PA 17013. 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Cumberland County Bar Association 32 S. Bedford Street, Carlisle, PA 17013 Telephone No. (717) 249-3166 or 1-800-990-9108 4sin nGri , Es it , No. 3 1 h Maclay, Esquire, No. 87954 Attorney for laintiff ff DALEY ZUCKER MEH TON MINER & GINGRICH, LLC 1029 Scenery Drive, Harrisburg, PA 17109 (717) 657-4795 Sandra L. Meilton, Esquire Lindsay Gingrich Maclay, Esquire Daley Zucker Meilton Miner & Gingrich, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 smeilton&dzmmglaw.com 1maclay6d)dzmmglaw.com KIMBERLY D. NEUMYER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 09 _ 0 - S- Civil Term STEVEN M. NEUMYER, : CIVIL ACTION - LAW Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(a) OF THE DIVORCE CODE COT NT 1- Plaintiff is Kimberly D. Neumyer, an adult individual who is sui juris and resides at 315 Stuart Place, Harrisburg, Dauphin County, Pennsylvania. 2. Defendant is Steven M. Neumyer, an adult individual who is sui juris and resides at 300 Norman Road, Camp Hill, Cumberland County, Pennsylvania. The present whereabouts of the Defendant, Steven M. Neumyer, to the knowledge of the Plaintiff, is the same. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 22, 2007, in Harrisburg, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The Plaintiff avers that the grounds on which the action is based is that Defendant has offered such indignities to the person of the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome, and that this action is not collusive. COUNT II: CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER THE DIVORCE CODE 9. Defendant is the owner of real estate located at 300 Norman Road, Camp Hill, Pennsylvania, which is subject to equitable distribution by this court. 10. Plaintiff and Defendant are the owners of various items of personal property, furniture and household furnishings acquired during their marriage which are subject to equitable distribution by this court. 11. Plaintiff and Defendant are the owners of various motor vehicles, bank accounts, investments, insurance policies and retirement benefits acquired during their marriage which are subject to equitable distribution by this court. COUNT III: CLAIM FOR ALIMONY UNDER THE DIVORCE CODE 12. The Plaintiff has inadequate means of support for herself except as provided for by Defendant. 13. Plaintiff is employed as a computer trainer at ARC of Dauphin and Lebanon Counties in Harrisburg, Pennsylvania, and earning $16.60 an hour. Defendant is employed as a scheduler for J&D Distribution in Middletown, Pennsylvania (Mecalux USA Inc.), and earning $22.84 an hour. COUNT IV: CLAIM FOR ALIMONY PENDENTE LITE COUNSEL FEES AND EXPENSES UNDER THE DIVORCE CODE 14. Plaintiff does not have sufficient funds to support herself and pay counsel fees and expenses incidental to this action. 15. Defendant is full well and able to pay Plaintiff Alimony Pendente Lite, counsel fees and expenses incidental to this divorce action. WHEREFORE, Plaintiff requests the Court to enter a Decree: A. Dissolving the marriage between Plaintiff and Defendant; B. Equitably distributing all property owned by the parties hereto; C. Directing the Defendant to pay Plaintiff alimony; D. Directing the Defendant to pay Alimony Pendente Lite and Plaintiffs counsel fees and the costs of this proceeding; and E. For such further relief as the Court may determine equitable and just. DALEY ZUCKER MEILTON MINER & GINGRICH, LLC S Llion squireI. o. 32551 ndsay ch Maclay, Esquire, I.D. No. 87954 1029 Scenery Drive, Harrisburg, PA 17109 717-657-4795 Attorneys for Plaintiff I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsification to authorities. Dated: 1 2 m r- 1isG3 DDO 3 i I IN, I e -i $+YU . 50 P D PT'tY 3OLddn L CO 4016 ef-S a47 . rye R LE Sandra L. Meilton, Esquire 2010 JAN 14 AM 10: 48 Daley Zucker Meilton Miner & Gingrich, LLC 1029 Scenery Drive P t: l'v1 Harrisburg, PA 17109 (717) 657-4795 smeilton Adzmmglaw.com KIMBERLY D. NEUMYER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 09-8925 Civil Term STEVEN M. NEUMYER, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF DAUPHIN ) -f in AND NOW, this ` day of January, 2010, personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, Gloria M. Rine, paralegal to Sandra L. Meilton, who being duly sworn according to law, deposes and says that on January 5, 2010, she mailed a certified copy of a Complaint in Divorce to Steven M. Neumyer, 300 Norman Road, Camp Hill, PA 17011, by certified mail no. 7004 2890 0001 3910 5137, return receipt requested, restricted delivery, and the same was received on January 6, 2010 by him, as indicated by the return receipt card which is attached hereto. r 'mc'?A Gloria M. Rine Sworn to and subscribed before me this t 3 1"day M an ary 09. Not ublic (SEAL) CQMMOWMALTH OF PENNSYLVAMA NOTARIAL SGAL PATRICIA A. PATTON, Notary Pubac Lower Pa w'Twp., Dauphin County G Ezpim June 240, 2010 s r%- US Postal S CERTIFIED ervicr MAIL RECE P • No Ins urance Coverage Provided) in Q' m Foss $ GiS C3 0 0 CerUBed Fee etrriark ?O M Return Reoelpt Fee (Endorsement Required) "ore O Restricted Delivery Fee m iT (Endorsement Required) CO ru Total Postage & Fees 1. h C3 ?. tMven M. Neumyer -; ------------------------------------- - d R 99= -- rma.n oa . = -------------- ?11, ---------------- PA ----------- - - 1701 - - --------- ---- ''' ¦ Complete items 1, 2, and 3. Also complete Item 4 If Resbtcted Delivery Is desired. ¦ Print your narrle and address on the reverse so that we can return the cad to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Steven M. Neumyer 300 Norman Road Camp Hill, PA 17011 p HIL< r ?Q10 X B^?eoeived tSy (ftifed Name) of E D. Is delivery address d1ban from Item 1? ? Yes if YES. enter delivery address below: ? No 8. Service IWO l1 osralied Mau ? Exprosr Mau ? Plood red ? PAwnn Receipt far Merchandise ? wwjrod Mau M C.O.D. 4. Restricted Dsuvsyt OD*n Fee) Utibs 2. Article Number v? (Ir'arMwIFom Mw%be flap _ 7004 2890 0001 -- 910 513 7 PS Form 3811, February 2004 DOereraC RetiXfl Receipt 1 02-W1540 (q t ?V-z.o 2010 DAD f 5 P8 ^U SERLA D coub" PENNSYLV . IN THE COURT OF COMMON P OF CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION KIMBERLY NEUMYER, Plaintiff vs. STEVE NEUMYER, Defendant DOCKET NO. &1 .S -,2-10 (0 PACSES CASE NO. 5?3 111 ;' i- OTHER STATE ID NO. PETITION FOR REDUCTION OR TERMINATION OF ALIMONY PENDENTE LITE ORDER AND NOW comes the above-named Plaintiff, by his attorney, Samuel L. Andes, and petitions the court to terminate or significantly reduce the order of alimony pendente lite previously entered in this matter, based upon the following: 1. The Petitioner herein is the Defendant. The Respondent herein is the Plaintiff. 2. This court entered an order on 3 March 2010 obligating Defendant to pay alimony pendente lite to Plaintiff in the amount of $400.00 per month. A copy of that order is attached hereto and marked as EXHIBIT A. 3. Since the entry of that order, Defendant has lost his job and his income has been reduced dramatically. As a result, he can no longer afford to pay alimony pendente lite in accordance with the said order. WHEREFORE, Defendant prays this court to terminate or, in the alternative, to significantly reduce the alimony pendente lite in this case. P ' loner el L. Andes Attorney for Petitioner I verify that the statements made in this document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Z _ to- to - Date Petitio er CERTIFICATE OF SERVICE I hereby certify that I served an original of the foregoing document upon counsel for the Plaintiff herein by regular mail, postage prepaid, addressed as follows: Sandra L. Meilton, Esquire Daley Zucker Meilton Miner & Gingrich 1029 Scenery Drive Harrisburg, PA 17109 Date: 14 December 2010 Amy M. arkins cretary for Samuel L. Andes EXHIBIT A In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION KIMBERLY NEUMYER ) Order Number 00081 S 2010 Plaintiff ) VS. ) PACSES Case Number 523111384 STEVE NEUMYER ) Docket Number 00081 S 2010 Defendant ) Other State ID Number ORDER OF COURT 0 Final ® Interim 0 Modified AND NOW, 3RD DAY OF MARCH, 2010 based upon the Court's determination that the Payee's monthly net income is $ 2, 0 8 9.9 8 and the Payor's monthly net income is $ 3, 021.58 , it is hereby ordered that the Payor pay to the Pennsylvania State Collection and Disbursement Unit FOUR HUNDRED AND XX/100 Dollars ($ 400.00 NEXT PAY DATE. ) a month payable BIWEEKLY as follows: first payment due The effective date of the order is 12/11/09 . Arrears set at $ 1425.02 as of MARCH 3, 2010 are due in full IMMEDIATELY. All terms of this Order are subject to collection and/or enforcement by contempt proceedings, credit bureau reporting, tax refund offset certification, driver's license revocation, and the freeze and seize of financial assets. These enforcement/collection mechanisms will not be initiated as long as obligor does not owe overdue support. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all the means listed above. For the Support of: Name Birth Date KIMBERLY NEUMYER 11/09/70 Form OE-518 Rev.7 Service Type M Worker ID 21005 NEUMYER V- NEUMYER The defendant owes a total of $ 4 0 0.0 0 PACSES Case Number: 523111384 per month payable BIWEEKLY $373.00 for current support and $ 2 7.0 0 for arrears. The defendant must also pay fees/costs as indicated below. This order is allocated and monies are to be applied as follows: Frequency Codes: 1 =One Time M =Monthly Payment Amount / Frequency Debt Type Description Beneficiary $373.00 / M SPOUSAL SPT/SO KIMBERLY NEUMYER $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / $ 0.00 / Said money to be turned over by the Pa SCDU to: KIMBERLY NEUMYER . 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 defendant's PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. Page 2 of 4 Form OE-518 Rev.7 Service Type M Worker ID 21005 NEUMYER V- NEUMYER PACSES Case Number: 523111384 The monthly support obligation includes cash medical support in the amount of $250 annually for unreimbursed medical expenses incurred for each child and/or spouse. Unreimbursed medical expenses of the obligee or children 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: 0.00 % by defendant and 10 0.0 0 % by plaintiff. (DInsurance is not ordered and/or no current support obligation exists. 0 Within thirty (30) days after the entry of this order, the OPlaintiff ODefendant shall submit to the other parry and to the Domestic Relations Section 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. Other Conditions: DEFENDANT IS TO PAY THE COURT COSTS OF $48.50 WITHIN TWENTY DAYS FROM THIS DATE AND IS TO BE MADE PAYABLE TO CUMBERLAND COUNTY DRS, P.O. BOX 320, CARLISLE, PA 17013. Defendant shall pay the following fees: Fee Total Fee Description $23.50 for JUDICIAL COMPUTER FEE $ 25.00 for COLLECTION FEE $ 0.00 for $ 0.00 for $ 0.00 for Service Type M Payment Frequency Payable at $ o . 0o per ONE TIME Payable at $ 0. 00 per ONE TIME Payable at $ o . o o per Payable at $ 0 . o o per Payable at $ o. o o per Page 3 of 4 Form OE-518 Rev.7 Worker ID 21005 NEUMYER V. NEWYER PACSES Case Number: 523111384 IWORTANT 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 MAYBE 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; this Order will be increased without further hearing by o % a month until all arrearages are paid in full. Payor is responsible for court costs and fees. Copies delivered to parties . MAR 0 5 20.10 Consented: Date Plaintiff Defendant 3RD DAY OF MARCH, 2010 DRO: R. J. Shadday Date Service Type M Plaintiff's Attorney Defendant's Attorney BY THE COURT: J sley Oler, Jr., Judge Page 4 of 4 Form OE-518 Rev.7 Worker ID 21005 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION PACSES Case Number: 523111384 Docket Number: 00081 S 2010 Other State ID Number: Please note: All correspondence must include the PACSES Case Number. MARCH 3, 2010 SUMMARY OF TRIER OF FACT Plaintiff Information KIMBERLY NEUMYER Address: 315 STUART PL HARRISBURG PA 17109-5727 Employer: ARC OF DAUPHIN COUNTY 2569 WALNUT ST HARRISBURG PA 17103-1760 Attorney: QUINTINA M. LAUDERMILCH, ESQ. ® Complaint for Support 12/11/09 ? Petition for Modification Filed ? Other Defendant Information STEVE NEUMYER Address: 300 NORMAN RD CAMP HILL PA 17011-6128 Employer: MECALUX USA INC 1600 N 25TH AVE MELROSE PARK IL 60160-186 Attorney: SAMUEL L. ANDES, ESQ. Reason for Conference: PLTF FILED FOR SPOUSAL SUPPORT THROUGH DAUPHIN COUNTY DRS. DEF DOES NOT CONTEST ENTITLEMENT. Dependent(s) Current Order: $ 0.0 0 / per month NEW ACTION Service Type M Form CM-022 Rev.3 Worker ID 21005 NEUMYER V- NEUMYER Plaintiff Information Current Income: $30,228.62/A GROSS 2009 W2 $2089.98/M NET Tax Return: H-2 Medical Coverage: HAS HER OWN COVERAGE AT NO COST Child Care/Tuition: Additional Obligations: HAS A 12 YR OLD CHILD FROM A PREVIOUS MARRIAGE. HER FATHER IS DECEASED AND SHE IS CURRENTLY RESIDING W/ HER GRANDPARENTS Other Information: PACSES Case Number: 523.111384 Defendant Information $1826.93/B GROSS SALARY $3021.58/M NET P-1. 9/22/07: PARTIES WERE MARRIED THERE ARE NO CHILDREN OF THE MARRIAGE 9/09: PARTIES SEPARATED 12/09: PLTF FILED FOR A DIVORCE IN DAUPHIN COUNTY DEFENDANT DOES NOT CONTEST ENTITLEMENT FOR SPOUSAL SUPPORT. Page 2 of 3 Service Type M Form CM-022 Rev.3 Worker ID 21005 NEUMYER V- NEUMYER Other Information (continued): Facts Agreed Upon: PACSES Case Number: 523111384 Facts in Dispute and Contentions with Respect to Facts in Dispute: Guideline Amount: $ 372.64 / MONTH DRS Recommended Amount: $ 373.00 / MONTH DRS Recommended Order Effective Date: 12/11/09 Parties to be Covered by Recommended Order Amount: WIFE Guideline Deviation: O YES or ONO Reason for Deviation: Submitted by: R. J. SHADDAY Date Prepared: MARCH 3, 2010 Page 3 of 3 Form CM-022 Rev.3 Service Type M Worker ID 21005 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION KIMBERLY NEUMYER ) Docket Number 00081 S 2010 Plaintiff ) VS. ) PACSES Case Number 523111384 STEVE NEUMYER ) Defendant ) Other State ID Number NOTICE OF RIGHT TO REQUEST A HEARING The parties are hereby advised that they have until MARCH 25, 2010 to request a hearing de novo before the Court. File requests in person at: DOMESTIC RELATIONS SECTION 13 NORTH HANOVER STREET CARLISLE PA 17013 or mail to: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 Service Type M Form OE-572 Worker ID 21205 -OFFICt- OF ICE 0 O; IHE PROTHONO, Tt4, says Sandra L. Meilton, Esquire ` Quintina M. Laudermilch, Esquire FEB z PM 3M '1 EB A I DALEY ZUCKER MEILTON 2611 24 MINER & GINGRICH, LLC CUMBERLAND COUNTY 1029 Scenery Drive PENNSYL.VANIADA F'Id , TY Harrisburg, PA 17109; A (717) 657-4795 smeilton@dzmmglaw.com tlaudermilch@dzmmglaw.com KIMBERLY D. NEUMYER, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 09-8925 Civil Term STEVEN M. NEUMYER, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on December 31, 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. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: mberly D. umyer, aintiff T1 W r iLED-OFFICE. ICE 0 OF THE PROTHONOTARY PP Sandra L. Meilton, Esquire Quintina M. Laudermilch, Esquire 2011 FEB 22 PM 3: 23 2011 AM 11 )FE : 24 DALEY ZUCKER WILTON MINER & GINGRICH, LLC CUMBERLAND COUNTY 1029 Scenery Drive PENNSYLVANIA D I TY Harrisburg, PA 17109 N (717) 657-4795 smeilton@dzmmglaw.com taudermilch@dzmmglaw.com KIMBERLY D. NEUMYER, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 09-8925 Civil Term STEVEN M. NEUMYER, : CIVIL ACTION - LAW Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER & 3301(0 OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: //0//// imberly "eumye?pTaintijl' KIMBERLY D. NEUMYER, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA -- V. : NO. 09-8925 Civil Term -a= rn m STEVEN M. NEUMYER, : CIVIL ACTION - LAW Defendant . IN DIVORCE n >C-) =O N AFFIDAVIT OF CONSENT -< can 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on December 31, 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. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: Lit St6vj M. Neumyer, Defendant i C) c C) -? E.5 C-) --i M KIMBERLY D. NEUMYER, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 09-8925 Civil Term STEVEN M. NEUMYER, : CIVIL ACTION - LAW Defendant : IN DIVORCE 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. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: y"L?? t _? ........._...... even M eumye , Defendant C) Q Z C f Sandra L. Meilton Esquire HoNOTA , Quintina M. Laudermilch, Esquire Z' 3 Daley Zucker Meilton t 't0it ter R Miner & Gingrich, LLC 1029 S D i ERLAtD COUNT'( cenery r ve ;??B ttaSYL?ANIA Harrisburg, PA 17109 PE (717) 657-4795 smeilton@dzmmglaw.com tlauderinilch@dzmmglaw.com KIMBERLY D. NEUMYER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 09-8925 Civil Term STEVEN M. NEUMYER. : CIVIL ACTION - LAW Defendant : IN DIVORCE PRAECIPE TO WITHDRAW ECONOMIC CLAIMS To the Prothonotary: Plaintiff hereby withdraws Count II, Count III, and Count IV of the Divorce Complaint, which was filed on December 31, 2009 in the above-captioned matter. Respectfully submitted, DALEY ZUCKER MEILTON MINER & GINGRICH, LLC I Date: err/ ''i By: ? c,•? Sandra L. Meilton, Esquire Supreme Court I.D. #32551 Quintina M. Laudermilch, Esquire Supreme Court I.D. # 94664 1029 Scenery Drive Harrisburg, Pennsylvania 17109 (717) 657-4795 Attorneys for Plaintiff f 1^ Sandra L. Meilton, Esquire r 'r i'101,1C$d0 TA1", Quintina M. Laudermilch, Esquire Daley Zucker Meilton ?SJ ; P Z' 36 Miner & Gingrich, LLC MSERLANO COUNTY t - 1029 Scenery Drive , ,U PENNSYLVANIA Harrisburg, PA 17109 (717) 657-4795 smeilton@dzmmglaw.com taudermilch@dzmmglaw.com KIMBERLY D. NEUMYER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 09-8925 Civil Term STEVEN M. NEUMYER, : CIVIL ACTION - LAW Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the Record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Ground for Divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: A true and correct certified copy of the Divorce Complaint was served on Defendant via Certified Mail, Restricted Delivery, having been received by him on January 6, 2010. The Affidavit of Service was filed on January 14, 2010. 3. As required by Section 3301(c) of the Divorce Code, Plaintiff executed her Affidavit of Consent on February 10, 2011 and Defendant executed his Affidavit of Consent on March 1, 2011. Plaintiffs Affidavit of Consent was filed on February 22, 2011 and Defendant's Affidavit of Consent is being filed contemporaneously herewith. 4. Related claims pending: None. •W Docket No. 09-8925 5. As required by Section 3301(c) of the Divorce Code, Plaintiff executed her Waiver of Notice of Intention to Request Entry of Divorce Decree on February 10, 2011 and Defendant executed his Waiver of Notice of Intention to Request Entry of Divorce Decree on March 1, 2011. Plaintiff's Waiver of Notice was filed on February 22, 2011 and Defendant's Waiver of Notice is being filed contemporaneously herewith. DALEY ZUCKER MEILTON MINER & GINGRICH, LLC Date: ?iC?I r By: andra L. Meilton, Esquire Supreme Court I.D. #32551 Quintina M. Laudermilch, Esquire Supreme Court I.D. #94664 1029 Scenery Drive Harrisburg, Pennsylvania 17109 (717) 657-4795 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KIMBERLY D. NEUMYER V. STEVEN M. NEUMYER DIVORCE DECREE AND NOW, l eWl;? 1?2(2, it is ordered and decreed that KIMBERLY D. NEUMYER , plaintiff, and STEVEN M. NEUMYER , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None. By the Court, NO. 09-8925 Attest: , .. J. Cer4. Cap rr?t -l6d + - awl La,tid?ertn4A, No*e + ?; maAAxd 4* c { Andes