HomeMy WebLinkAbout10-1144MELINDA G. SHAW, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. lO - IIYy ?,vi.?,FJt.
JONATHAN J. SHAW, : CIVIL ACTION - LAW
Defendant :DIVORCE
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NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the ctaimMet
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 or your children.
When the ground for 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:
Office of the Prothonotary
Cumberland County Court House
One Courthouse Square
Carlisle, Pennsylvania 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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
717-249-3166
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MELINDA G. SHAW, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : NO.
JONATHAN J. SHAW, : CIVIL ACTION - LAW
Defendant : DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO JONATHAN J. SHAW, DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed in
the Court of Common Pleas of Cumberland County. This notice is to advise you that in
accordance with Section 3302(d) of the Divorce Code, you may request that the court require you
and your spouse to attend marriage counseling prior to a divorce being handed down by the court.
A list of professional marriage counselors is available at the Domestic Relations Office, 13 North
Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to
you and you are not bound to choose a counselor from this list. All necessary arrangements and
the cost of counseling sessions are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling within
twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a
waiver of your right to request counseling.
MELINDA G. SHAW, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : NO. -?elcJONATHAN J. SHAW, : CIVIL ACTION - LAW
Defendant : DIVORCE
COMPLAINT
COUNT 1 - DIVORCE
AND NOW comes Plaintiff, Melinda G. Shaw, by her attorney, Diane S. Baker, Esquire,
and files this Complaint, based upon the following:
1. Plaintiff, Melinda G. Shaw, is an adult individual who currently resides at 5 Elm
Drive, Enola, Cumberland County, Pennsylvania 17025.
2. Defendant, Jonathan J. Shaw, is an adult individual who currently resides at 5 Elm
Drive, Enola, Cumberland County, Pennsylvania 17025.
3. Plaintiff and Defendant were married on February 20, 2005, in Harrisburg,
Pennsylvania.
4. Plaintiff and Defendant separated on or about November 17, 2009.
5. Plaintiff has been a bona fide resident of this Commonwealth for at least six (6)
months immediately prior to the filing of this Complaint.
6. Defendant is not presently a member of the Armed Forces on active duty. Plaintiff
is not presently a member of the Armed Forces on active duty.
7. There are no pending actions in divorce or annulment in this jurisdiction or in any
other jurisdiction brought by either Plaintiff or Defendant above-named.
8. Plaintiff has been advised of the availability of counseling and that Plaintiff may
have the right to request that the court require the parties to participate in counseling.
9. Plaintiff avers that the marriage is irretrievably broken.
COUNT 2 - CLAIM
FOR EQUITABLE DISTRIBUTION
10. Paragraphs 1 through 9 above are herein incorporated by reference.
11. The Plaintiff and Defendant are owners of various items of personal property,
furniture and household furnishings acquired during the marriage which are subject to equitable
distribution by the Court.
12. The Plaintiff and Defendant are owners of various motor vehicles acquired during
the marriage which are subject to equitable distribution by the Court.
13. The Plaintiff and Defendant singly or jointly have interests in various bank
accounts acquired during the marriage which are subject to equitable distribution by the Court.
14. Plaintiff and Defendant own or have an interest in real estate which is subject to
equitable distribution by the Court.
15. The Plaintiff and the Defendant have acquired during the marriage other marital
property which is subject to equitable distribution by the Court.
WHEREFORE, Plaintiff requests the Court to enter a Decree:
(a) Dissolving the marriage between Plaintiff and Defendant;
(b) Equitably distributing all marital property owned by the parties hereto;
(c) Such further relief as the Court may determine equitable and just.
Respectfully
DATE:
`751-ane S. Baker, Esquire
Supreme Court ID #53200
27 South Arlene Street
Post Office Box 6443
Harrisburg, PA 17112-0443
(717) 671-9600
VERIFICATION
I, MELINDA G. SHAW, verify that the statements made in this Complaint in Divorce 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.
ELINDA G. SHAW
MELINDA G. SHAW,
Plaintiff
VS.
JONATHAN J. SHAW,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:NO. J D ` IN Y
I
: CIVIL ACTION - LAW
: DIVORCE
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PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance on behalf of the Plaintiff, Melinda G. Shaw, in the above-
referenced matter.
Respectfully stibr tted,
DATE:
Baker, Esquire
I.D. No. 53200
27 S. Arlene Street
P.O. Box 6443
Harrisburg, PA 17112-0443
(717) 671-9600
MELINDA G. SHAW, : IN THE COURT OF COMMON PLEAS OF `~- ~ -~~
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA c -~ --~
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vs. : NO. 2010-1144
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JONATHAN J. SHAW, :CIVIL ACTION -LAW .~
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Defendant :DIVORCE
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AFFIDAVIT OF SERVICE
I, Diane S. Baker, Esquire, hereby certify that a true and correct copy of the
Divorce Complaint was served on the Defendant, Jonathan J. Shaw, by certified mail,
restricted delivery, return receipt requested, on February 22, 2010, at the following
address:
Jonathan Shaw
5 Elm Drive
Enola, PA 17025
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The return receipt card is attached hereto as Exhibit "A".
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Lune a. isaxer, esquire
Attorney for Plaintiff
I.D. No. 53200
27 S. Arlene Street
P.O. Box 6443
Harrisburg, PA 1 7 1 1 2-0443
717-671-9600
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EXHIBIT "A"
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^ Complete Rems 1, 2, and 3. Also complete
Item 4 M Restricted Delivery is desired.
^ Print your name and address on the reverse
so that we can return the caret to you.
^ Attach this card to the back of the mailpiece,
or on the front. if space permits.
1. Article Addressed to: -
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A. Signature p
by (Prfrrt~d Marrre) I C. Date of Delivery
D. Is dell -, te~gi~narrt horn Item 1? ^ Yes
Ir Vt~tirhNrv rasa t~etow: ^ No
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Express Mail
^ Registered ^ Return Receipt for Merchandise
^ Insured Mail ^ C.O.D.
4. Restricted Delhrery? (Extra Feel es
~' ~`"a'~"riDir 7D08 2810 DDD1 6229 7779
(nar~slirr tarn a.rda. ~
PS Form 3811, February 2004 Dortreetic Return Receipt ,oxses~.~,s.o
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2010 ~l~1; - I R~111 ~ --0
GUPY ~ ` ~ URT OF COMMON PLEAS
MELINDA G. SHAW, -~-~~-` „ ~ .
PLAINTIFF ~~ '~'l~~C~JMBERLAND COUNTY
PENNSYLVANIA
vs. NO. 2010-1144
JONATHAN J. SHAW, :CIVIL ACTION -LAW
DEFENDANT :DIVORCE
PRAECIPE FOR ENTRY OF APPEARANCE
Please enter my appearance on behalf of the Defendant, Jonathan J. Shaw.
Respectfully submitted,
Dated: February 24, 2010
LAW FIRM OF SU
Susan Kay Candi~
PA I.D. # 64998
4010 Glenfinnan
Mechanicsburg P
(717) 724-2278
KAY CANDIELLO, P.C.
5
MELIND.A G. SHAW, THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
VS CIVIL ACTION - DIVORCE _
. C Z5
NO. 10-1144 CIVIL TERM
JONATHAN J. SHAW, IN DIVORCE _
Defendant/Respondent
PACSES NO: 205111934 :
`
OR DER OF COURT r
AND NOW, this 14th day of September, 2010, upon consideration of the Petition for Alimony Pendente
Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before Timothy J.
Correll on October 5, 2010 at 1:00 P.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which
the conference officer may recommend that an Order for Alimony Pendente Lite be entered.
YOU are further ordered to bring to the conference:
( I ) 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 Rule 1910.1 10(
(4) verification of child care expenses
(5) proof of medical coverage which you may have, or may have available to you.
If you fail to appear for the conference or brim the required documents, the Court may issue a
warrant for your arrest.
Copies mailed to: Petitioner
Respondent
Diane S. Baker, Esq.
Susan K. Candiello, Esq.
Date of Order: September 14, 2010
BY THE COURT,
Edward E. Guido, t Judge
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND
REPRESENT YOU. 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 MAY GET LEGAL
HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVE.
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166 cc361
MELINDA G. SHAW, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : NO. 2010-1144
JONATHAN J. SHAW, : CIVIL ACTION - LAW C-)
Defendant : DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS ~= ` " p
5--c- :3
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the clair` rs 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 or your children.
When the ground for 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:
Office of the Prothonotary
Cumberland County Court House
One Courthouse Square
Carlisle, Pennsylvania 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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
m
ern
717-249-3166
7. CCU
MELINDA G. SHAW,
Plaintiff
VS.
JONATHAN J. SHAW,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2010-1144
: CIVIL ACTION - LAW
: DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO JONATHAN J. SHAW, DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed in
the Court of Common Pleas of Cumberland County. This notice is to advise you that in
accordance with Section 3302(d) of the Divorce Code, you may request that the court require you
and your spouse to attend marriage counseling prior to a divorce being handed down by the court.
A list of professional marriage counselors is available at the Domestic Relations Office, 13 North
Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to
you and you are not bound to choose a counselor from this list. All necessary arrangements and
the cost of counseling sessions are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling within
twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a
waiver of your right to request counseling.
MELINDA G. SHAW,
Plaintiff
VS.
JONATHAN J. SHAW,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2010-1144
CIVIL ACTION - LAW
DIVORCE
AMENDED COMPLAINT
COUNT 1- DIVORCE
AND NOW comes Plaintiff, Melinda G. Shaw, by her attorney, Diane S. Baker, Esquire,
and files this Amended Complaint, based upon the following:
1. Plaintiff, Melinda G. Shaw, is an adult individual who currently resides at 31
Queen Avenue, Enola, Cumberland County, Pennsylvania 17025.
2. Defendant, Jonathan J. Shaw, is an adult individual who currently resides at 4172
Antelope Court, No. 101, Mechanicsburg, Cumberland County, Pennsylvania 17059.
3. Plaintiff and Defendant were married on June 6, 1987, in Harrisburg,
Pennsylvania.
4. Plaintiff and Defendant separated on or about March, 2010.
5. Plaintiff has been a bona fide resident of this Commonwealth for at least six (6)
months immediately prior to the filing of this Complaint.
6. Defendant is not presently a member of the Armed Forces on active duty. Plaintiff
is not presently a member of the Armed Forces on active duty.
7. There are no pending actions in divorce or annulment in this jurisdiction or in any
other jurisdiction brought by either Plaintiff or Defendant above-named.
8. Plaintiff has been advised of the availability of counseling and that Plaintiff may
have the right to request that the court require the parties to participate in counseling.
9. Plaintiff avers that the marriage is irretrievably broken.
COUNT 2 - CLAIM
FOR EQUITABLE DISTRIBUTION
10. Paragraphs 1 through 9 above are herein incorporated by reference.
11. The Plaintiff and Defendant are owners of various items of personal property,
furniture and household furnishings acquired during the marriage which are subject to equitable
distribution by the Court.
12. The Plaintiff and Defendant are owners of various motor vehicles acquired during
the marriage which are subject to equitable distribution by the Court.
13. The Plaintiff and Defendant singly or jointly have interests in various bank
accounts acquired during the marriage which are subject to equitable distribution by the Court.
14. Plaintiff and Defendant own or have an interest in real estate which is subject to
equitable distribution by the Court.
15. The Plaintiff and the Defendant have acquired during the marriage other marital
property which is subject to equitable distribution by the Court.
COUNT 3 -- ALIMONY PENDENTE LITE,
COUNSEL FEES, COSTS AND EXPENSES
15. Paragraphs 1 through 15 are incorporated by reference herein.
17. By reason of this action, Plaintiff will be put to considerable expense in the
preparation of her case, in the employment of counsel and the payment of costs.
18. The 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.
19. Defendant has adequate earnings to provide for Plaintiff's support and to pay her
counsel fees, costs and expenses.
COUNT 4 - ALIMONY
20. Paragraphs 1 through 19 are incorporated by reference herein.
21. Plaintiff lacks sufficient property to provide for her reasonable needs.
22. Plaintiff is unable to currently sufficiently support herself through appropriate
employment.
23. Defendant has sufficient income and assets to provide continuing support for the
Plaintiff.
WHEREFORE, Plaintiff requests the Court to enter a Decree:
(a) Dissolving the marriage between Plaintiff and Defendant;
(b) Equitably distributing all marital property owned by the parties hereto;
(c) Ordering the payment of Alimony Pendente Lite, costs and expenses;
(d) Ordering the payment of alimony; and
(e) Such further relief as the Court may determine equitable and just.
Respectfully submitted, _
DATE:
?1-
Diane S. Baker, Esquire
q h I ?? Supreme Court ID #53200
r 27 South Arlene Street
Post Office Box 6443
Harrisburg, PA 17112-0443
(717) 671-9600
VERIFICATION
I, MELINDA G. SHAW, verify that the statements made in this Amended Complaint in
Divorce 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.
k r
a
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MELINDA G. SHAW
CERTIFICATE OF SERVICE
I hereby certify that on this day of September, 2010, a true and correct copy of
the aforementioned document was served on the following person by United States Mail,
postage prepaid, addressed as follows:
Susan Kay Candiello, Esquire
4010 Glenfinnan Place
Mechanicsburg, PA 17055
Supreme Court ID 53200
27 South Arlene Street
Post Office Box 6443
Harrisburg, PA 17112-0443
(717) 671-9600
{
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DOMESTIC RELATIONS SECTION
13 N. HANOVER STREET, P.O. BOX 320, CARLISLE, PA 17013
V.
Phone: (717) 240-6225 Fax: (717) 240-6248
MEL:INDA G. SHAW, NO. 2010-1144
Plaintiff
PACSES NO. 948111465
JONATHAN J. SHAW, CIVIL ACTION - LAW
Defendant IN DIVORCE n _
nil
1
DRS ATTACHMENT FOR APL PROCEEDINGS
F? T"h
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PETITIONER'S INFORMATION:
Name: Melinda G. Shaw
Address: 31 Queen Avenue
City: Enola State: Pennsylvania Zip Code: 17025
SSN: 161-54-9157 DOB: November 21, 1960 Telephone: (717) 991-2696
Physical Description: Ht.5'6" Wt. 250 Eyes Blue Hair Brown Race Caucasian
Email Address: melindagardnershaw@comcast.net
Employer: Unemployed
Employer's Address:
Phone:
Job Title/Position: Gross Pay: Net Pay:
Petitioner's Attorney: Diane S. Baker, Esquire
Petitioner's Attorney's Address: P.O. Box 6443, Harrisburg, PA 17112-0443
Phone: (717) 671-9600
Medical Insurance Carrier: Blue Cross Blue Shield
Medical Insurance Carrier Address:
Policy Number: R50184694
Phone:
Group Number: 65006500
-Fi
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RESPONDENT'S INFORMATION:
Name: Jonathan J. Shaw
Address: 4172 Antelope Court, No. 101
City: Mechanicsburg State: Pennsylvania Zip Code: 17059
SSN: 199-48-1018 DOB: July 17, 1958 Telephone:
Physical Description: Ht. 6'0" Wt. 200 Eyes Blue Hair Brown Race Caucasian
Email Address: jonathanjshaw@navy.nil
Employer: Mechanicsburg Navy Depot, Mechanicsburg, PA
Employer's Address: Defense Finance & Accounting, Room 1907, 1240 E. 9'h Street,
Cleveland, Ohio 44199
Phone: (717) 798-1852
Job Title/Position: Mechanical Engineer Gross Pay: $84,235.00
Respondent's Attorney: Susan K. Candiello, Esquire
Respondent's Attorney's Address: 4010 Glenfinnan Place, Mechanicsburg, PA 17055
Phone: (717) 724-2278
Medical Insurance Carrier: Blue Cross Blue Shield
Medical Insurance Carrier Address:
Phone:
Policy Number: R50184694 Group Number: 65006500
MARRIAGE INFORMATION:,
Date Married: June 6, 1987 Date of Separation: March, 2010
Place of Marriage: Mechanicsburg, Pennsylvania
Address of last Marital Domicile: 5 Elm Drive, Enola, PA 17025
Description of Document Raising APL Claim: Amended Complaint in Divorce
Date APL Document Filed": 9/14/10
"Please note: A copy of the filed document MUST be enclosed with this form."
This information is for DRS use in order to build a case in the PACSES System.
MELINDA G. SHAW, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY,
PENNSYLVANIA ?-
C C '--.-
v. NO. 2010-1144 M
F v
JONATHAN J. SHAW, CIVIL ACTION --LAW
Defendant IN DIVORCE =may --
REQUEST FOR ALIMONY PENDENTE LITE HEARING
AND NOW comes the Plaintiff, by and through her attorney, Diane S. Baker,
Esquire, and avers as follows:
Plaintiff, Melinda G. Shaw, is an adult individual who currently resides at
31 Queen Avenue, Enola, Cumberland County, Pennsylvania 17025.
2. Defendant, Jonathan J. Shaw, is an adult individual who currently resides
at 4172 Antelope Court, No. 101, Mechanicsburg, Cumberland County, Pennsylvania
17059.
3. An Amended Complaint in Divorce with a claim for alimony pendente lite
was filed contemporaneously with this Petition, and served upon the Defendant
contemporaneously with this Petition. Plaintiff requests that the alimony pendent lite
claim be forwarded to Office of Domestic Relations and set for hearing on that issue.
f"1
;rn
RespectAtK7?ubmitted,
Diane S. Baker, Esquire
I.D. No. 53200
27 South Arlene Street
P.O. Box 6443
Harrisburg, PA 17112-0443
(717) 671-9600
BakerLawOffice@aot.com
DATE:
CERTIFICATE OF SERVICE
w
I hereby certify that on this day of September, 2010, a true and correct copy of
the Request for Hearing was served on the following person by United States Mail, postage
prepaid, addressed as follows:
Susan Kay Candiello, Esquire
4010 Glenfinnan Place
Mechanicsburg, PA 17055
1 miffed,
r
Diane S. Baker, Esquire
Supreme Court ID 53200
27 South Arlene Street
Post Office Box 6443
Harrisburg, PA 17112-0443
(717) 671-9600
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 10-1144 CIVIL
State Sommonwealth of Pennsylvania
Co./City/Dist. of Ci7NrBERLAND
Date of Order/Notice 10/05/10
Case Number (See Addendum for case summary)
EmployerM/ithholder's Federal EIN Number
OOriginal Order/Notice
948111465 OAmended Order/Notice
~9 S 2010 OTerminate Order/Notice
OOne-Time Lump Sum/Notice
RE: SHAW, JONATHAN J.
Employee/Obligor's Name (Last, First, MI)
DEPT OF DEFENSE CIVILIANS
Sent Electronically
DO NOT MAIL
199-48-1018
Employee/Obligor's Social Security Number
9597102230
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUNBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ ~~o. oo per month in current child support
$ o . oo per month in past-due child support Arrears 12 weeks or greater? yes ®no
$ o . oo per month in current medical support ~-~
$ o . oo per month in past-due medical support c- -- ...~
$ 610 . oo per month in current spousal support
$ 61 . oo per month in past-due spousal support =` =r-.r --i :'~~
$ o . oo per month for genetic test costs ~ ~ ~ ~
$ o. o o per month i n other (specify) --: r a
$ one-time lump sum payment ='r °+~ ~~i
for a total of $ 1, 441. oo per month to be forwarded to payee below. _~ o w ~ ~
=~ ~
You do not have to vary your pay cycle to be in compliance with the support order. if your pay cycle dies wAt mh
the ordered support payment cycle, use the following to determine how much to withhold:
$ 331.63 Per weekly pay period. $ X20. so per semimonthly pay period
(twice a month).
$ 663 .25 per biweekly pay period (every two weeks). $ 1.441 • oo per monthly pay period.
REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10)
working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of
withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work
state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of
the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding,
the following information is needed (See #9 on page 2).
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-b76-9580 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 1 71 06-91 1 2
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 MA/L.
BY THE COURT: KEVIN A HE55
Form EN-428 Rev.1
Service Type M OMBNo.~0970-0154 WorkerlD $IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
~ If ~hecke~l you are required to provide a~opy of this form to your~mployee. If your employee vyorks in a state thatkis
di Brent rom the state that issued this or er, a copy must be provi to your employee even if the box is not chec ell
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employeelobligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employee%bligor.
3.* Reporting the Paydate/Date of Withholding: You must report the paydate/date of withholding when sending the payment. The
paydate/date of withholding is the date on which amount was withheld from the employee's wages. You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4.* Employee/Obligor with Multiple Support Holdings; If there is more than one Order/Notice to Withhold Income for Support against
this employee%bligor and you are unable to honor all support OrderlNotices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employee%bligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. 3115751420
THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : f] THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: C7
EMPLOYEE'S/OBLIGOR'S NAME: SHAW, JONATHAN J.
EMPLOYEE'S CASE IDENTIFIER: 9597102230
LAST KNOWN HOME ADDRESS:
LAST KNOWN PHONE NUMBER:
DATE OF SEPARATION:
FINAL PAYMENT AMOUNT:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment,
refusing to employ, or taking disciplinary action against any employee%bligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed govems.
9.* 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's/obligor's principal place of
employment. 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°1° of the disposable income if the obligor is not supporting another family.However, that 50% limit is
increased to 55% and that 60% limit is increased to 65°!° if the arrears are greater than t 2 weeks. 1f permitted by the State, you may
deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section.
Arrears greater than 12 weeks : If the Order Information does not indicate whether the arrears are greater than 12 weeks, then the
employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts
allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser of
the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of the
CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amounts paid for health
care premiums in determining disposable income and applying appropriate withholding limits.
10. Additional info:
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state
that issued this order with respell to these items.
11. Send Termination Notice and
other correspondence to:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. SOX 320
CARLISLE PA 17013
Service Type M
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at X717) 240-6225 or
by FAX at (717) 240-6248 or
by Internet www.childsupport.state.pa.us
Page 2 of 2
OMB No.: 0970-0154
Form EN-428 Rev.1
Worker I D $ IATT
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: SHAW, JONATHAN J.
PACSES Case Number 205111934
Plaintiff Name
MELINDA G. SHAW
Docket Attachment Amount
10-1144 CIVIL$ 671.00
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ o.oo
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ o.oo
Child(ren)'s Name(s): DOB
Service Type M
Addendum
OMB No.: 0970-0154
PACSES Case Number 948111465
Plaintiff Name
MELINDA G. SHAW
Docket Attachment Amount
00099 S 2010 $ 770.00
Child(ren)'s Name(s): DOB
BETHANY T. SHAW 11/05/93
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ o.oo
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ o.oo
Child(ren)'s Name(s): DOB
Form EN-428 Rev.1
Worker I D $ IATT
MELINDA G. SHAW, IN THE COURT OF COMMON PLEA5 OF
PlaintifflPetitioner CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION -DIVORCE
NO. 10-1144 CIVIL TERM
JONATHAN J. SHAW, IN DIVORCE
DefendantlRespondent PACSES CASE: 205111934
ORDER OF COURT
AND NOW, this 5th day of October, 2010, based upon the Court's determination that the
Petitioner's monthly net income/earning capacity is $ 2,412.48 and the Respondent's monthly net
incomelearning capacity is $ 5,220.00, it is hereby ordered that the Respondent pay to the
Pennsylvania State Collection and Disbursement Unit Six Hundred Seventy-one and 00/100 Dollars
($ 671.00) per month payable bi-weekly as follows: $ 610.00 per month for Alimony Pendente Lite
and $ 61.00 per month on arrears. First payment due: in accordance with Respondent's pay schedule.
The effective date of the order is September 14, 2010.
Arrears set at $ 950.93 as of October 5, 2010.
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 to be turned over by the PA SCDU to: Melinda G. Shaw. 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 each child andlor 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 % by Respondent and 100 % by Petitioner. [] Respondent [X] Petitioner [] Neither
party to provide medical insurance coverage.
Within thirty (30) days after the entry of this order, the [X] Petitioner [] 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.
Other conditions:
The Petitioner is to maintain her own medical insurance coverage.
This order considers that the Respondent has a child support obligation for the parties child
under PACSES Case #948111465 and docketed at 99 S 2010.
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: October 6.2010
Petitioner
Respondent
Diane S. Baker, Esq.
Susan K. Candiello, Esq.
DRO: R.J. Shadday
BY THE COU
~-, ~~.,
Edward E. Guido, -,4~ ~ Q J.~' -
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MELINDA G. SHAW,
Plaintiff/Petitioner
VS.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -DIVORCE
NO. 10-1144 CIVIL TERM
JONATHAN J. SHAW, IN DIVORCE
DefendantlRespondent PACSES CASE: 205111934
AMENDED ORDER OF COURT
AND NOW, this 8th day of October, 2010, based upon the Court's determination that the
Petitioner's monthly net income/earning capacity is $ 2,412.48 and the Respondent's rnvnthly net
income/earning capacity is $ 5,220.00, it is hereby ordered that the Respondent pay to the
Pennsylvania State Collection and Disbursement Unit Six Hundred Seventy-one and 00/100 Dollazs
($ 671.00) per month payable bi-weekly as follows: $ 610.00 per month for Alimony Pendente Lite
and $ 61.00 per month on arrears. First payment due: in accordance with Respondent's pay schedule.
The effective date of the order is September 14, 2010.
Arrears set at $ 950.93 as of October 5, 2010.
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 to be turned over by the PA SCDU to: Melinda G. Shaw. 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 ~~ ~4
PA 17106-9110
Harrisburg `~ ~~' - ~
,
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Payments must include the Respondent's name with their PACSES Member Nu~ orb? ~~`~~
~
Social Security Number in order to be processed. Do not send cash by mail. a --° ~~
_.:
cc360
r,..
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 31 S` 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.
Other conditions:
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.
Consented:
Petitioner
Respondent
Petitioner's Attorney
Respondent's Attorney
Mailed copies on: October 8.2010
Petitioner
Respondent
Diane S. Baker, Esq.
Susan K. Candiello, Esq.
DRO: R.J. Shadday
BY THE COURT
Edward E. C~ii • o, J.
.0 1 .
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
MELINDA G. SHAW ) Docket Number 10-1144 CIVIL
Plaintiff )
vs. ) PACSES Case Number 205111934
JONATHAN J. SHAW )
Defendant ) Other State ID Number CD
t x M
J7 ? I ? t?J
LJ 1 C)
PETITION FOR MODIFICATION
OF AN EXISTING SUPPORT ORDER
p .
1. The petition of JONATHAN J. SHAW respectfully
represents that on OCTOBER 5, 2010 , an Order of Court was entered for the
support of
MELINDA G. SHAW
A true and correct copy of the order is attached to this petition.
Service Type M
Form OM-501
Worker ID 21504
SHAW V. SHAW PACSES Case Number: 205111934
2. Petitioner is entitled to 0 increase 0 decrease ?6 termination 0 reinstatement
0 other of this Order because of the following material. and substantial change(s) in
circumstance:
0
,1G1+^Ua-y rC? a01 b?, /=. VNV."
_5 •oU? 5 d ? S ,J,ro ?av ?
WHEREFORE, Petitioner requests that the Court modify the existing order for support.
Petitioner Attorney for Petitioner
I verify that the statements made in this complaint are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to
unworn falsification to authorities.
Jr- ! --
Date
etitioner
Page 2 of 2 Form OM-501
Service Type M Worker ID 21504
MELINDA G. SHAW, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - DIVORCE , .,,
NO. 10-1144 CIVIL TERM f '
JONATHAN J. SHAW, IN DIVORCE =
Defendant PACSES CASE: 205111934
ORDER OF COURT
AND NOW, this 6th day of January 2011, a petition has been filed against you, Melinda G. Shaw, 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 January 26, 2011, 2011 at 9:00 A.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
1910.11.
(4) verification of child care expenses
(5) proof of medical coverage which you may have, or may have available to you
IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for
your arrest.
Copies mailed to: Petitioner
Respondent
Diane S. Baker, Esq.
Susan K. Candiello, Esq.
Date of Order: January 6, 2011
BY THE COURT
Edward E. Guido, Judge
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT
YOU. 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 MAY GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVE.
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
cc361
MELINDA G. SHAW, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - DIVORCE
NO. 10-1144 CIVIL TERM
L I
JONATHAN J. SHAW, IN DIVORCE c r'3 iO?`Y
;
Defendant/Respondent PACSES CASE: 205111934 m co
ORDER OF COURT 'CD
=o -v ?
C c
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AND NOW to wit, this 11th day of March, 2011, it is hereby Ordered that pursuan t t an _.yr
agreement of the parties, through their counsel, the Alimony Pendente Lite order is terminated,
effective January 11, 2011.
The Alimony Pendente Lite account is closed with a credit of -$713.00.
This Order shall become final twenty (20) days after the mailing of the notices 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.
BY THE COURT:
1.00
Edward P. Guidb, J.
DRO: R.J. Shadday
xc: Petitioner
Respondent
Diane S. Baker, Esq.
Susan K. Candiello, Esq.
Form OE-001
Service Type: M Worker: 21005
MELINDA G. SHAW, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANI A.
VS. : NO. 2010-1144
JONATHAN J. SHAW, : CIVIL ACTION - LAW < - -
-
Defendant : DIVORCE =o ? c
,
oc
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on
February 17, 2010.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of
intention to request entry of the decree.
4. I have been advised of the availability of marriage counseling and understand that
I may request that the Court require that my spouse and I participate in counseling. I further
understand that the Court maintains a list of marriage counselors in the Prothonotary's Office,
which list is available to me upon request. Being so advised, I do not request that the Court
require that my spouse and I participate in counseling prior to a decree being handed down by the
Court.
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.
DATED: SC l I zo r (
A 9G. SHAW
PLAINTIFF
MELINDA G. SHAW,
Plaintiff
VS.
JONATHAN J. SHAW,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2010-1144
: CIVIL ACTION - LAW
: DIVORCE
-0 _.
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vc
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WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
§3301 (c) OF THE DIVORCE CODE
I consent to the entry of a final decree of divorce without notice.
r? F
4
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn
falsification to authorities.
DATED:fzb t MELINDA G. SHAW
PLAINTIFF
MELINDA G. SHAW, : IN THE COURT OF COMMON PLEAS
PLAINTIFF : OF CUMBERLAND COUNTY
: PENNSYLVANIA
P? SE
VS. NO. 2010-1144
JONATHAN J. SHAW, CIVIL ACTION - LAW Cl) r-
DEFENDANT DIVORCE
C 77
(
AFFIDAVIT OF CONSENT 4
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
September 14, 2010.
2. The marriage between the Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of filing the Complaint.
3. I consent to the entry of a final Decree in Divorce, after the service of notice of
intention to request entry of the decree.
4. I understand that if a claim for alimony, alimony pendente lite, equitable distribution
of marital property, counsel fees or expenses has not been filed with the Court before the entry of
a final Decree in Divorce, the right to claim any of them will be lost.
5. I have been advised of the availability of marriage counseling, and understand that I
may request that the Court require that my spouse and I participate in counseling. I further
understand that the Court maintains a list of marriage counselors in the Prothonotary's Office,
which list is available to me upon request. Being so advised, I do not request that the Court
require that my spouse and I participate in counseling prior to a divorce decree being handed
down by the Court.
I verify that the Statements in this Affidavit 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.
i
-ZA
DATE JONATHAN J HAW
MELINDA G. SHAW, : IN THE COURT OF COMMON PLEAS
PLAINTIFF : OF CUMBERLAND COUNTY
: PENNSYLVANIA
VS. NO. 2010-1144
m 77'- .
rn
=M C= rii
JONATHAN J. SHAW, : CIVIL ACTION -LAW
DEFENDANT : DIVORCE
O C) ?
X.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OA2 T
r
DIVORCE DECREE UNDER SECTION 3301(c) OF DIVORCE CODE-<
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court
and that a copy of the decree will be sent to me immediately after it is filed with the
prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
DATE ONATHAN J. SHA
, r
16 -, ) I qy cv: I
MARITAL PROPERTY SETTLEMENT AGREEMENT
THIS AGREEMENT is entered into this day ofkus 1 , 2011, by and between
MELINDA GARDNER SHAW and JONATHAN JAYS W.
RECITALS
Date of Marriage: June 6, 1987
Place of Marriage: Harrisburg, Pennsylvania
VJ-4-k )A-
Last Marital Residence: 5 Elm Drive, Enola, Cumberland County, PA 17025 5 E04
Date of Separation: February 19, 2010
Child: BETHANY T. SHAW, born on November 5, 1993
Pending Court Proceedings: None
Court of Common Pleas No. 2010- 1144
of Cumberland County, Pennsylvania
WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between
the parties and it is the intention of Wife and Husband to live separate and apart for the rest of
their natural lives, and the parties hereto are desirous of settling fully and finally their respective
financial and property rights and obligations as between each other including, without limitation:
the ownership and equitable distribution of marital property; the past, present and future support,
and/or maintenance of Wife by Husband; and, in general, any and all claims and possible claims
by one against the other or against their respective estates.
NOW, THEREFORE, in consideration of the premises and of the mutual promises,
covenants and undertakings hereinafter set forth and for other good and valuable consideration,
receipt of which is hereby acknowledged by each of the parties hereto, Wife and Husband, each
intending to be legally bound hereby, covenant and agree as follows:
PERSONAL RIGHTS
Wife and Husband may and shall, at all times hereafter, live separate and apart. They
shall be free from any contact, restraint, interference or authority, direct or indirect, by the other
in all respects as fully as if they were unmarried. Each may, for his or her separate use or
benefit, conduct, carry on and engage in any business, occupation, profession or employment
which to him or her may seem advisable. Wife and Husband shall not molest, harass, disturb or
malign each other or the respective families of each other at all times and at all locations,
including but not limited to each party's place of work, nor compel or attempt to compel the
other to cohabit or dwell by any means whatsoever with him or her.
A
WAIVER OF RIGHTS AND MUTUAL RELEASES
Except as otherwise expressly provided by this Agreement:
(a) Each party hereby absolutely and unconditionally releases and forever discharges the
other and the estate of the other for all purposes from any and all rights and obligations which
either may have or at any time hereafter have for past, present or future support or maintenance,
alimony pendente lite, alimony, equitable distribution, counsel fees, costs, expenses and any
other right or obligation, economic or otherwise, whether arising out of the marital relationship
or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, its
supplements and amendments, as well as under any other law of any other jurisdiction, except
and only except all rights, agreements and obligations of whatsoever nature arising or which may
arise under this Agreement or for the breach of any provision thereof. Neither party shall have
any obligation to the other not expressly set forth herein.
(b) Each party hereby absolutely and unconditionally releases and forever discharges the
other and his or her heirs, executors, administrators, assigns, property and estate from any and all
rights, claims, demands or obligations arising out of or by virtue of the marital relationship of the
parties or otherwise, whether now existing or hereafter arising. The above release shall be
effective regardless of whether such claims arise out of any former or future acts, contracts,
engagements or liabilities of the other or by way of dower, curtesy, widow's rights, family
exemption or similar allowance, or under the intestate laws, or the right to take against the
spouse's will, or the right to treat a lifetime conveyance by the other as testamentary, or all other
rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the
laws of Pennsylvania, any state, commonwealth or territory of the United States, or any other
country. It is expressly understood, however, that neither the provisions of this release nor the
subsequent entry of a divorce decree are intended to defeat the right of either party to receive any
insurance proceeds at the death of the other of which she or he is the named beneficiary (whether
the beneficiary designation was made prior or subsequent to execution hereof), nor to defeat the
right of either party to receive any legacy, bequest or residuary portion of the other's estate under
his or her will, or to act as personal representative or executor if so named by the will of the
other, whether such will was executed prior or subsequent to this Agreement.
(c) Except for any cause of action for divorce which either party may have or claim to
have, and except for the obligations of the parties contained in this Agreement and such rights as
are expressly reserved herein, each party gives to the other by the execution of this Agreement an
absolute and unconditional release and discharge from all causes of action, claims, rights or
demands whatsoever, in law or in equity, which either party ever had or now has against the
other.
FINANCIAL DISCLOSURE
The parties have disclosed to each other and they are each aware of the extent of each
other's income, assets, liabilities, holdings and estate.
AGREEMENT TO BE INCORPORATED
BUT NOT MERGED INTO DIVORCE DECREE
In the event that either of the parties shall recover a final judgment or decree of absolute
divorce against the other in a court of competent jurisdiction, the provisions of this Agreement
may be incorporated by reference or in substance but shall not be deemed merged into such
judgment or decree. This agreement shall survive any such final judgment or decree of absolute
divorce, shall be entirely independent thereof, and the parties intend that all obligations
contained herein shall retain their contractual nature in any enforcement proceedings, whether
enforcement is sought in an action on the contract itself or in any enforcement action filed to the
divorce caption.
EFFECT OF DIVORCE DECREE ON AGREEMENT
Either party may enforce this Agreement as provided in Section 3105(a) of the Divorce
Code, as amended. As provided in Section 3105(c), provisions of this Agreement regarding
equitable distribution, alimony, alimony pendente lite, counsel fees or expenses shall not be
subject to modification by the court.
The parties agree to sign Affidavits of Consent and Waivers of Notice of Intention to
Request Entry of Final Divorce Decree as appropriate with the current ninety (90) day waiting
period in effect in the Commonwealth of Pennsylvania. Wife shall be responsible for filing these
documents and finalizing the divorce.
DATE OF EXECUTION
The "date of execution" or "execution date" of this Agreement shall be defined as the date
upon which it is executed by the parties if they have each executed the Agreement on the same
date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined
as the date of execution by the party last executing this Agreement.
ADVICE OF COUNSEL
The provisions of this Agreement and their legal effect have been fully explained to the
parties by their respective counsel, Susan Kay Candiello, Esquire, for Husband and Diane S.
Baker, Esquire, for Wife. The parties acknowledge that each has received independent legal
advice from counsel of their selection and that they have been fully informed as to their legal
rights and obligations, including all rights available to them under the Pennsylvania Divorce
Code of 1980, as amended, and other applicable laws. Each party confirms that he or she fully
understands the terms, conditions and provisions of this Agreement and believes them to be fair,
just, adequate and reasonable under the existing circumstances.
VOLUNTARY EXECUTION
Each party understands the terms and conditions of this Agreement and acknowledges
that the Agreement is fair and equitable. The parties have reached this Agreement freely and
voluntarily, without any duress, undue influence, collusion or improper or illegal agreements.
WAIVER OR MODIFICATION TO BE IN WRITING
No modification or waiver of any of the terms hereof shall be valid unless in writing and
signed by both parties and no waiver or any breach hereof or default hereunder shall be deemed a
waiver of any subsequent default of the same or similar nature. Notwithstanding this provision,
under applicable Pennsylvania law, the parties understand that any provision of this Agreement
relating to child support or to custody shall be subject to modification by the Court upon a
showing of changed circumstances.
LAW OF PENNSYLVANIA APPLICABLE
This Agreement shall be construed in accordance with the laws of the Commonwealth of
Pennsylvania.
AGREEMENT BINDING ON HEIRS
Except as may otherwise be provided, this Agreement shall be binding and shall inure to
the benefit of the parties hereto and their respective heirs, executors, administrators, successors
and assigns.
INTEGRATION
This Agreement constitutes the entire understanding of the parties and supersedes any
and all prior agreements and negotiations between them. There are no representations or
warranties other than those expressly set forth herein.
ADDITIONAL INSTRUMENTS
Wife and Husband covenant and agree that they will forthwith within a reasonable time,
but not longer than thirty (30) days after demand is made by the other party, execute any and all
written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as
may be necessary or desirable for the proper effectuation of this Agreement.
NO WAIVER OF DEFAULT
This Agreement shall remain in full force and effect unless and until terminated under
and pursuant to the terms of this Agreement. The failure of either party to insist upon strict
performance of any of the provisions of this Agreement shall in no way affect the right of such
party hereafter to enforce the same, nor shall the waiver of any breach of any provision hereof be
construed as a waiver of any subsequent default of the same or similar nature, nor shall the
waiver of any breach of any provision hereof be construed as a waiver of strict performance of
any other obligations herein.
4
SEVERABILITY AND INDEPENDENT AND SEPARATE COVENANTS
The parties agree that each separate obligation contained in this Agreement shall be
deemed to be a separate and independent covenant and agreement. If any term, condition, clause
or provision of this Agreement shall be determined or declared to be void or invalid in law or
otherwise, then only that term, condition, clause or provision shall be stricken from this
Agreement and in all other respects this Agreement shall be valid and continue in full force,
effect and operation. Likewise, the failure of any party to meet her or his obligations under any
one or more of the paragraphs herein, with the exception of the satisfaction of any conditions
precedent, shall in no way avoid or alter the remaining obligations of the parties.
MANNER OF GIVING NOTICE
Any notice required by this Agreement to be sent to Husband shall be sent by certified
mail, return receipt requested, to Susan Kay Candiello, Esquire, at the Law Firm of Susan Kay
Candiello, P.C., 4010 Glenfinnan Place, Mechanicsburg, Pennsylvania 17055, or such other
address as Husband from time to time may designate in writing.
Any notice required by this Agreement to be sent to Wife shall be sent by certified mail,
return receipt requested, to Diane S. Baker, Esquire, 27 South Arlene Street, P.O. Box 6443,
Harrisburg, Pennsylvania, 17112-0443, or such other address as Wife from time to time may
designate in writing.
HEADINGS NOT PART OF AGREEMENT
Any headings preceding the text of the several paragraphs and subparagraphs hereof are
inserted solely for convenience of reference and shall not constitute a part of this Agreement nor
shall they affect its meaning, construction or effect.
BANKRUPTCY OR REORGANIZATION PROCEEDINGS
In the event that either party becomes a debtor in any bankruptcy or financial
reorganization proceedings of any kind while any obligations remain to be performed by that
party for the benefit of the other party pursuant to the provisions of this Agreement, the debtor
spouse hereby waives, releases and relinquishes any right to claim any exemption (whether
granted under state or federal law) to any property remaining in the debtor as a defense to any
claim made pursuant hereto by the creditor-spouse, and the debtor-spouse hereby assigns,
transfers and conveys to the creditor-spouse an interest in all of the debtor's exempt property
sufficient to meet all obligations to the creditor-spouse as set forth herein, including all attorneys'
fees and costs incurred in the enforcement of this Paragraph or any other provision of this
Agreement. No obligation created by this Agreement shall be discharged or dischargeable,
regardless of federal or state law to the contrary, and each party waives any and all right to assert
that any obligation hereunder is discharged or dischargeable.
EFFECT OF RECONCILIATION OR RECONCILIATION ATTEMPT
This Agreement shall remain in full force and effect even if the parties reconcile, cohabit
as husband and wife, or attempt reconciliation. This Agreement shall continue in full force and
effect and there shall be no modification or waiver of any of the terms hereof unless the parties,
in writing, signed by both parties, execute a statement declaring this Agreement or any term of
this Agreement to be null and void.
EXISTING AND FUTURE PERSONAL OBLIGATIONS
Further, Wife and Husband each covenant, warrant, represent and agree that neither has
heretofore contracted for any debt, liability or obligation for which the other or the estate of the
other may be responsible or liable except as specifically disclosed and provided for by the terms
of this Agreement. The parties further covenant, warrant, represent and agree that each will now
and at all times hereafter save harmless and indemnify the other and the estate of the other from
all debts, charges and liabilities incurred after the execution date hereof, except as may be
otherwise specifically provided herein, as well as from all debts, liabilities or obligations of
every kind which have been incurred heretofore by either party, including those for necessities,
except for obligations arising out of this Agreement.
ENFORCEMENT
The parties intend that this Agreement shall be subject to enforcement under the
Pennsylvania Divorce Code of 1980, as amended, and that, notwithstanding any language herein
that may be construed to the contrary, this Agreement is not subject to modification except under
such terms as the parties have specifically provided for in this Agreement.
REMEDIES AND SANCTIONS
In addition to such other remedies and sanctions available under applicable law, the
parties may utilize any remedy or sanction set forth in the Pennsylvania Divorce Code, as
amended, to enforce any term of this Agreement as though it had been an order of the Court.
ATTORNEY'S FEES FOR ENFORCEMENT
In the event that either party breaches any provision of this Agreement and the other
party retains counsel to assist in enforcing the terms thereof, the parties hereby agree that the
breaching party will pay all attorney's fees incurred by the other party in enforcing the
Agreement, provided that the enforcing party is successful in establishing that a breach has
occurred.
EQUITABLE DISTRIBUTION
1. PERSONAL PROPERTY
Husband and Wife do hereby acknowledge that they have previously divided their
tangible personal property including, but without limitation, jewelry, clothes, furniture,
6
furnishings, rugs, carpets, household equipment and appliances, pictures, books, works of art and
other personal property; and hereafter Wife agrees that all of the property in the possession of
Husband shall be the sole and separate property of Husband; and Husband agrees that all of the
property in the possession of Wife shall be the sole and separate property of Wife. The parties
do hereby specifically waive, release, renounce and forever abandon any claims, which either
may have with respect to the above items, which shall hereafter be the sole and exclusive
property of the other.
2. MOTOR VEHICLES
With respect to the motor vehicles owned by one or both of the parties, they agree as
follows:
A. Husband and Wife jointly owned a Ford F150. This vehicle has been sold and the
proceeds from the sale of the vehicle have been equally divided between the parties.
B. The 2004 Buick Rendezvous titled in Husband and Wife's names jointly has been
transferred into Wife's name alone, the parties have agreed this vehicle shall hereafter be the sole
and exclusive property of Wife. There is no loan on this vehicle. Wife agrees to be solely
responsible for all taxes and insurance on this vehicle. Wife shall be sole owner of this vehicle
C. The 2008 Ford Mustang titled in Husband's name, has been sold. Husband purchased
a 2008 Chevrolet HHR and a 1998 Buick Skylark which was given to the parties' Daughter,
Bethany. The 2008 Chevrolet HHR and the 1998 Buick Skylark shall both hereafter be the sole
and exclusive property of Husband. There are no loans for these vehicles. Husband agrees to be
solely responsible for all taxes and insurance on these vehicles. Husband shall be the sole owner
of these vehicles. The 1998 Buick Skylar is for the use of the parties' daughter, but, shall remain
in Husband's name, until the Daughter, is able to put the vehicle into her name alone.
D. Husband and Wife owned two (2) Harley Davidson motorcycles. The parties have
sold both motorcycles and equally divided the proceeds from the sale.
E. Husband and Wife also owned an aluminium boat with trailer, a sunfish sail boat and
a pop-up camper. The parties have sold each of these items and have equally divided all the
proceeds from the sales.
F. The parties agree to execute any documents necessary to effectuate the provisions of
this Paragraph on the execution date hereof, including Vehicle Sales and Use Tax Returns as
necessary to make any conveyances on a tax-free basis if possible. The said documents shall be
delivered to the party entitled to receive same pursuant hereto on execution date.
G. In the event that any documents of title to the said vehicles shall be in the hands of a
bank or other holder of a lien or encumbrance upon either of the said vehicles, and it is intended
that such vehicle be conveyed subject to the said lien or encumbrance, the parties agree that they
will advise the bank and/or lienholder as to the transfer of title and they further agree to execute
whatever documents may be required to transfer title where the parties' documents of title are in
the hands of such bank and/or lienholder.
3. BANK ACCOUNTS
The parties had joint checking accounts with Metro Bank and with Member's First
Federal Credit Union. These accounts have been closed and the parties have agreed upon a
division of any monies remaining in these accounts.. Husband has opened his own individual
checking and savings accounts with Member's First Federal Credit Union, Metro Bank and
Pennsylvania State Employees Credit Union. Wife has opened her own individual checking and
savings accounts with Member's First Federal Credit Union. The parties do hereby specifically
waive, release, renounce and forever abandon any claims which either may have with respect to
each of their individual bank accounts. The funds from these accounts shall hereafter be the sole
and exclusive property of the party in possession of them.
The parties agree that they will execute any documents necessary to effectuate the
provisions of this Paragraph on execution date.
4. RETIREMENT INTEREST
Wife
401(k) Plan with Ash Brokerage Wife had a 401(k) with her former employer, Ash Brokerage.
Wife has received a taxable distribution of her 401(k) balance after the parties were separated.
Wife received a distribution of 49,350.23. Husband and Wife had stipulated to use this value as
Wife's 401(k) retirement assets as of the time of separation.
Husband
Federal Thrift Savings Plan Husband owns an interest in the Federal Thrift Savings Plan
("TSP"). Husband's account balance as of May 31, 1987, (the presumed accumulation as of the
date of the marriage of June 6, 1987) was $816.95. Husband's account balance as of February
19, 2010, was $306,319.98, which was net of an outstanding participant loan balance which
Husband is responsible for paying off. The increase in the TSP account balance, net of loans,
amounts to $305,503.03.
The difference between Husband's TSP and Wife's 401(k) as of February 19, 2010 is
$258,413.09. Husband and Wife have agreed Wife shall receive 50% of this amount, or
$129,206.55, as of February 19, 2010. The investment return on Wife's share of Husband's TSP
from February 19, 2010 to March 31, 2011 is now $157,292.25, to be accumulated with earnings
and losses from March 31, 2011, until the date of distribution of Wife's share. Wife's counsel
shall be responsible for the processing of the Qualified Domestic Relations Order directing this
sum from be transferred from Husband's TSP to Wife.
Husband and Wife agree to share in any costs or expenses for the above QDRO.
Husband agrees should Jonathan Cramer, actuary- require any additional information to prepare
the above QDRO, he will provide this requested information to Jonathan Cramer within ten (10)
days of the request.
Federal Employees Retirement System (Hereinafter known as "FERS") Husband owns an
interest in the Federal Employees' Retirement System ("FERS"), a defined benefit plan. Wife is
awarded 50% of the marital portion of Husband's FERS pension payable at the time of
Husband's retirement from Federal service. Under the terms of FERS, Wife may not collect her
share of the pension until Husband enters pay status. The marital portion shall be determined
using the gross pension as of Husband's retirement date and a coverture fraction whose
numerator is the years of creditable military and civilian service earned under FERS from June 6,
1987 until February 19, 2010. The denominator of the coverture fraction shall equal the total
years of creditable military and civilian service as of the date of Husband's retirement.
Husband's FERS pension excludes any supplemental annuity paid until the age of 62 should
Husband retire before 62 and be eligible for said supplemental annuity. Wife shall be entitled to
a pro rata share of any cost-of-living adjustments paid by FERS.
If Husband dies before retirement, FERS pays a pre-retirement basic lump sum death benefit.
Wife shall receive any pro-rata share of the basic lump sum death benefits based upon the
coverture fraction defined above. If Husband dies before retirement with at least 10 years of
federal service, FERS also pays a pre-retirement survivor annuity to eligible spouse's equal to
50% of the accrued pension at the time of death. Wife is entitled to any pro-rata share of the pre-
retirement survivor annuity, based upon the coverture fraction as defined above.
Upon Husband's retirement, Wife shall be provided a post-retirement former spouse survivor
annuity using a pro-rata share of the maximum survivor annuity (50%) with the coverture
fraction defined above. The cost of such post-retirement former spouse survivor annuity shall be
deducted from Wife's share of the FERS pension as otherwise calculated under the terms of this
Section.
If Wife predeceases Husband, her share of Husband's pension shall revert to Husband
If Husband leaves Federal service prior to retirement, Husband shall not apply for a lump sum
refund of his own contributions since that would cancel his right to receive a deferred annuity
under FERS. Wife's counsel shall be responsible for the processing of the Qualified Domestic
Relations Order directing the above.
Husband and Wife agree to share in any costs or expenses for the above QDRO.
Husband agrees should Jonathan Cramer, actuary require any additional information to prepare
the above QDRO, he will provide this requested information to Jonathan Cramer within ten (10)
days of the request.
5. MARITAL RESIDENCE
Marital ResidenceNalue Husband and Wife jointly own the marital residence,
located at 5 Elm Drive, Enola, Pennsylvania, 17025. Husband and Wife have sold the marital
residence. All expenses associated with the marital residence have been paid in full. All
remaining monies from the sale of the marital residence were equally divided between the
Husband and Wife.
6. JOINT DEBTS AND LIABILITIES
The joint debts incurred during the marriage and unsatisfied at the time of the execution
of this Agreement are as follows:
1) Mortgage on the marital residence was paid in full at the time of the sale of the
marital residence;
2) All vehicle loans have been paid in full;
3) The parties have paid in full and closed their Visa, in both Husband and Wife's
names.
Each parry warrants to the other that he/she does not have any credit cards in joint names.
Any obligations incurred by either party in his or her individual name, whether incurred before
or after the parties' separation, and including credit cards, are the sole responsibility of the party
in whose name the debt or obligation was incurred.
7. SEPARATE ASSETS
A. Release: The parties hereby agree that as to each of their separate assets, as that term
is defined herein, the party not having title to or possession of any particular separate asset
hereby waives, releases, relinquishes and forever abandons any and all claim therein, and
acknowledges that hereafter the party having title to or possession of a separate asset is the sole
and exclusive owner thereof.
B. Limitation to Assets Disclose& The above release is subject to the proviso that it shall
be effective only as to those assets disclosed to the other party, although such assets need not be
specifically named or disposed of in this Agreement. Neither party intends by the execution
hereof to release any claim, which he or she may have in assets, which have not been disclosed.
C. Definition: The term "separate asset" is defined for purposes of this Agreement as
designating any asset of any kind (whether real, personal or mixed, tangible or intangible) which
is presently titled either in the sole name of a party hereto or jointly with one of the parties hereto
and a third party or parties. The term also includes any untitled asset which is presently in the
sole possession of one of the parties hereto. The term shall further include any business interests
owned by either party, whether individually or together with a third party or parties.
D. Indemnification as to Expenses: Each of the parties hereby guarantees to indemnify
and hold the other harmless from any liability, cost or expense, including attorneys' fees and
10
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interest, which either may be in the future or has been previously incurred with respect to the
parties' separate assets as defined herein.
8. AFTER-ACQUIRED PROPERTY
Each of the parties shall hereafter own and enjoy, independently of any claim or right of
the other, all items of property, be they real, personal or mixed, tangible or intangible, which are
acquired by him or her after execution of this Agreement, with full power in him or her to
dispose of the same as fully and effectively, in all respects and for all purposes, as though he or
she were unmarried.
9. WAIVER OF SPOUSAL SUPPORT, ALIMONY, ALIMONY PENDENTE LITE,
AND ACKNOWLEDGMENT OF ADEQUACY
The parties herein acknowledge that by this Agreement they have each respectively
secured sufficient financial resources to provide for his or her own comfort, maintenance and
support. The parties do hereby acknowledge that inflation may increase or decrease, that their
respective incomes and assets may substantially increase in value, that either may be employed
at various times in the future, and that notwithstanding these or other economic circumstances,
which may be changes in circumstances of a substantial and continuing nature, the terms of this
Agreement are just and reasonable. Therefore, except for the provisions of this Agreement, the
parties hereby expressly waive, discharge and release any and all rights and claims which they
may now or hereafter have, by reason of the parties' marriage, to alimony, alimony pendente lite,
support or maintenance, and they further release any rights they may have to seek modification
of the terms of this Agreement in a court of law or equity, it being understood that the foregoing
constitutes a final determination for all time of either party's obligation to contribute to the
support and maintenance of the other. It shall be, from the execution date of this Agreement, the
sole responsibility of each of the respective parties to sustain themselves without seeking any
support from the other party.
10. INCOME TAX RETURNS
Husband and Wife have filed joint income tax returns while married. If the parties are
entitled to a refund and/or incur any liability as a result of joint income tax returns filed during
the parties' marriage, the refund and/or the liability shall be equally divided between them. The
cost of preparing and handling any prior income tax return from the parties' married years shall
be shared equally between them. Husband and Wife agree to promptly make available to each
other all records and information necessary or helpful for the preparation of any tax returns, any
claim for refunds, and defense of any tax audit.
11. COUNSEL FEES AND EXPENSES
Husband and Wife agree to be responsible for the individual counsel fees in obtaining
this divorce.
II
Each of the parties has carefully read and fully considered this Agreement and all of
the statements, terms, conditions and provisions thereof prior to signing below.
IN WITNESS WHEREOF, intending to be legally bound hereby, the parties hereto
have set their hands and seals the day and year first written above.
TNESS
I ', ?e k. W /, 6 , e
-M4 Jr
e S
MELINDA GARDNER SHAW, WIFE
NATHAN JAY , HUSBAND
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF
SS:
On this, the /S? day of &- a-S , 2011, before me, a Notary Public
for the Commonwealth of Pennsylvania, a undersigned officer, personally appeared
JONATHAN J. SHAW known to me (or satisfactorily proven) to be the person whose name is
subscribed to the within Marital Settlement Agreement and acknowledged that he executed the
same for the purpose therein contained.
IN WITNESS WHEREOF, I have set my hand and notarial seal.
Notary Public
My Commission Expires: A,y d-01,5-
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Matthew Alexander Kiral, Notary Public
Silver Spring Twp., Cumberland County
My Commission Expires May 4, 2015
MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES
12
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF
On this, the
,am ay , 2011, before me, a Notary Public
for the Commonwealth of Pennsylvani the dersigned officer, personally appeared
MELINDA G. SHAW, known to me r s t' factorily proven) to be the person whose name is
subscribed to the within Marital Settlement greement and acknowledged that she executed the
same for the purpose therein contained.
IN WITNESS WHEREOF, I have set my hand and notarial seal.
No Public
My Commission Expires: 10\ COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Marianne C. Bechtel, Notary Public
Horsham Twp., Montgomery County
My Commission Expires Dec. 26, 2013
Member, Pennsylvania Association of Notaries
13
Melinda G. Shaw
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
DIVORCE
Jonathan J. Shaw NO. 10-1144 Civil Term
Defendant
DOMESTIC RELATIONS ORDER
1. This Domestic Relations Order ("DRO") creates and recognizes the existence of the
Alternate Payee's right to receive a portion of the benefits payable with respect to the Employee. It
is intended to constitute a Court Order Acceptable for Processing ("COAP") under final regulations
issued by the United States Office of Personnel Management ("OPM"). This DRO applies to the
Federal Employees Retirement System ("FERS") and any successor thereto. The court has
considered the requirements and standard terminology in Part 838 of Title 5, Code of Federal
Regulations. The terminology used in the provisions of this Order that concern benefits under the
Federal Employees Retirement System are governed by the standard conventions established in
that part.
2. This DRO is entered pursuant to authority granted under the applicable domestic
relations laws of the State of Pennsylvania and in accordance with Part 838 of Title 5, Code of
Federal Regulations.
3. This DRO relates to the provision of marital property rights to the Alternate Payee.
4. Jonathan J. Shaw ("Employee") is a Member of FERS. Melinda G. Shaw ("Alternate
Payee"), the former spouse, is the Alternate Payee for the purposes of this DRO.
5. The Employee's name, mailing address, Social Security number and date of birth are:
Jonathan J. Shaw
439 North Enola Drive -?
Enola, PA 17025 -? _ .,?
Social Security No.: See Addendum
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Date of Birth: See Addendum r
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6. The Alternate Payee's name, mailing address, Social Security number and date of birth
are:
Melinda G. Shaw
100 Ardwick Terrace
Lansdale, PA 19446
Social Security No.: See Addendum
Date of Birth: See Addendum
It is the responsibility of the Alternate Payee to keep a current mailing address on file
with the OPM at all times.
The Employee is or will be eligible for retirement benefits under the FERS based on his
employment with the United State Government. The Alternate Payee is entitled to a portion of the
Employee's monthly annuity under the FERS as set forth below.
8. This DRO assigns to Alternate Payee 50.00% of the marital portion of the Employee's
self-only basic monthly annuity payable by the FERS, calculated as of the date of Employee's benefit
commencement date. If the employee waives military retired pay to credit military service under
the FERS, the increased FERS annuity shall be used for purposes of this Section 8. The Alternate
Payee's basic monthly benefit shall then be reduced by the cost of the former spouse survivor
annuity awarded to the Alternate Payee pursuant to Section 12. The marital portion of the
Employee's monthly annuity shall be determined by multiplying the Employee's monthly annuity by
a "marital coverture fraction" (less than or equal to 1.0), the numerator of which is the total number
of months of creditable civilian and military service earned by the Employee from June 6, 1987, the
date of marriage, to February 19, 2010, the date of separation, and the denominator of which is the
total number of months of creditable civilian and military service earned by the Employee as of the
date of cessation of benefit accruals. The Alternate Payee is not entitled to receive any portion of the
Employee's supplemental annuity, which may be payable to him if he retires prior to age 62. When
Cost-of-Living Adjustments ("COLA") are applied to Employee's retirement benefits, the same COLA
shall apply to the Alternate Payee's share. The OPM is hereby directed to pay Alternate Payee's
share directly to Alternate Payee.
the commence to the
9. payments to Alternate Payee shall commence on the date paymefor OpM nts
commence
Employee. Employee agrees to arrange or to execute all forms necessary
payments to the Alternate Payee in accordance with the terms of the DRO.
ments shall continue to Alternate Payee for the remainder of the Employee's lifetime.
10. Pay Payee's share of the Employee's
If the Alternate Payee dies before the Employee, the Alternate Pay
annuity shall revert to the Employee.
nder Section 8445 of Title 5, United States Code, the Alternate Payee is awarded a
11. Under to dies before his benefits commence,
former spouse pre-retirement survivor annuity. If the Emp Yee
the amount of the survivor annuity payable to the Alternate Payee shall be the marital portion of
maximum possible former spouse survivor annuity under FERS where marital portion is
the
determined using the marital coverture fraction defined in Section 8.
Under Section 8445 of Title 5, United States Code, the Alternate Payee is awarded nce, the former U mount of
post-retirement survivor annuity. If the Employee dies after his benefits commence,
the e survivor annuity payable to the Alternate Payee shall be the marital portion of the maximum
with using the
possible former spouse survivor annuity under FERS where marital portion is determined
marital coverture fraction defined in Section 8. Such survivor annuity sha be The costs associated with
COLAs fi°om the Employee's date of retirement or death as applicable.
this former spouse survivor annuity coverage shall be deducted from the Alternate Payee's
providing 7 , ste s to elect Alternate
portion of the monthly annuity. Employee agrees to take all necessary p
Pa ee as designated beneficiary for the purposes of establishing and sustaining such former spouse
y
survivor annuity for Alternate Payee.
the Alternate Payee is awarded a
12. If the Employee dies before his benefits commence, pro rata
share of the basic lump sum death benefit. The Alternate Payee shall receive u 00,0% of a pro l
share of the basic lump sum death benefit where pro rata share is calculated g the marita
coverture fraction defined in Section 8. The parties were married June 6, 1987 and separated on
February 19, 2010.
3
13. If Employee leaves Federal service before retirement and applies for a refund of employee
contributions under the FERS, the OPM is directed not to pay the Employee a refund of such
employee contributions.
14. In. no event shall the Alternate Payee have greater benefits or rights other than those
which are available to the Employee. The Alternate Payee is not entitled to any benefit not
otherwise provided by the FERS. The Alternate Payee is only entitled to the specific benefits offered
by the FERS as provided in this Order. All other rights, privileges and options offered by the FERS
not granted to Alternate Payee are preserved for the Employee.
15. The OPM shall issue individual tax forms to the Employee and Alternate Payee for
amounts paid to each such person.
16. In the event that OPM inadvertently pays to the Employee any benefits that are assigned
to the Alternate Payee pursuant to the terms of this DRO, the Employee shall immediately
reimburse the Alternate Payee to the extent that he has received such benefit payments, and shall
forthwith pay such amounts so received directly to the Alternate Payee within ten (10) days of
receipt. In the event OPM inadvertently pays to the Alternate Payee any benefits that are not
assigned to her pursuant to the terms of this DRO, the Alternate Payee shall immediately reimburse
the Employee to the extent she has received such benefit payments and shall forthwith pay such
amounts so received directly to the Employee within ten (10) days of receipt.
17. If Employee takes any action that prevents, decreases, or limits the collection by
Alternate Payee of the sums to be paid hereunder, he shall make payments to Alternate Payee
directly in an amount sufficient to neutralize, as to Alternate Payee, the effects of the actions taken
by Employee.
18. The OPM shall notify the Alternate Payee and her legal representative when the
Employee makes an application for any benefit payments or withdrawals from the FERS.
19. The Court of Common Pleas of Cumberland County, Pennsylvania shall retain
jurisdiction to amend this Order, but only for the purpose of establishing it or maintaining it as a
Domestic Relations Order, provided, however, that no such amendment shall require the FERS to
provide any form of benefit or any option not otherwise provided by the FERS, and further provide
that no such amendment or right of the Court to so amend will invalidate this Order.
Accepted and Ordered this fS day of apD I/
BY T
Judge
CONSENT TO ORDER:
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/ Alternate Payee Date
Atfo-mey for Plaintiff / Date
Alternate Payee
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Melinda G. Shaw IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
DIVORCE
Jonathan J. Shaw NO. 10-1144 Civil Term
Defendant
DOMESTIC RELATIONS ORDER
This Domestic Relations Order ("DRO") creates and recognizes the existence of the
Alternate Payee's right to receive a portion of the benefits payable with respect to the Participant.
It is intended to constitute a Qualifying Retirement Benefits Court Order by the Federal
Retirement Thrift Investment Board ("Board").
2. This DRO is entered pursuant to authority granted under the applicable domestic
relations laws of the State of Pennsylvania.
This DRO relates to the provision of marital property rights to the Alternate Payee.
4. This DRO applies to the Thrift Savings Plan ("Plan") and any successor thereto.
Jonathan J. Shaw ("Participant") is a Participant in the Plan. Melinda G. Shaw ("Alternate
Payee"), the former spouse, is the Alternate Payee for the purposes of this DRO.
a re:
The Participant's name, mailing address, Social Security number and date of birth are:
Jonathan J. Shaw
439 North Enola Drive
Enola, PA 17025
Social Security No.: See Addendum
TSP Account No.: See Addendum
Date of Birth: See Addendum
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The Alternate Payees name, mailing address, Social Securit - 7;7 - v ?--
y number and of-Wrth7ocD
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Melinda G. Shaw <U
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100 Ardwick Terrace -
Lansdale, PA 19446
Social Security No.: See Addendum
Date of Birth: See Addendum
It is the responsibility of the Alternate Payee to keep a current mailing address on file
with the Plan at all times.
This Order assigns to Alternate Payee an amount equal to $157,292.25 of the
Participant's total account balance accumulated under the Plan as of March 31, 2011. The
Alternate Payee's award shall be adjusted for earnings, gains or losses from March 31, 2011, to the
(late of distribution using the actual rate of earnings experienced by the Participant's Thrift
Savings Plan account from March 31, 2011, until the date of distribution. In no event shall the
Alternate Payee receive more than the Participant's vested account balance on the date of
distribution.
8. The Alternate Payee shall be paid benefits as soon as administratively feasible following
the date this Order is approved as a Qualifying Retirement Benefits Court Order by the Board.
9. Benefits are to be payable to the Alternate Payee in the form of a lump sum cash
payment (in the form of a tax-deferred rollover to an IRA or eligible retirement plan, if so elected
by the Alternate Payee on forms supplied by the Thrift Savings Plan Administrator).
10. All payments made pursuant to this Order shall be conditioned on the certification by
the Alternate Payee and the Participant to the Board of such information as the Board may
reasonably require from such parties.
11. This DRO does not require the Plan to provide any type or form of benefit the Plan does
not otherwise provide.
12. This DRO does not require the Plan to provide increased benefits.
13. This DRO does not require the Plan to pay any benefits which another order previously
determined to be a Qualifying Retirement Benefits Court Order requires the Plan to pay to
another alternate payee.
14. In the event that the Plan inadvertently pays to the Participant any benefits that are
assigned to the Alternate Payee pursuant to the terms of this Order, the Participant shall
immediately reimburse the Alternate Payee to the extent that he has received such benefit
payments and shall forthwith pay such amounts so received directly to the Alternate Payee within
ten (10) days of receipt. In the event the Plan inadvertently pays to the Alternate Payee any
benefits that are assigned to the Participant pursuant to the terms of this Order, the Alternate
Payee shall immediately reimburse the Participant to the extent that she has received such benefit
payments and shall forthwith pay such amount so received directly to the Participant within ten
(10) days of receipt.
15. After payment of the amount required by this DRO, the Alternate Payee shall have no
further claim against the Participant's interest in the Plan.
16. The Alternate Payee assumes sole responsibility for the tax consequences of any
payments made to her under this DRO.
17. In the event the Participant predeceases the Alternate Payee before she receives her
distribution, his death shall have no effect on her assigned portion of the benefits, as stipulated
herein. If applicable, the Alternate Payee shall be treated as the beneficiary of the Participant to
the extent of her assigned interest hereunder.
18. If the Participant takes any action that prevents, decreases or limits the collection by
Alternate Payee of the sums to be paid hereunder, he shall make payments to Alternate Payee
directly in an amount sufficient to neutralize, as to Alternate Payee, the effects of the actions
taken by Participant.
19. The Court of Common Pleas of Cumberland County, Pennsylvania shall retain
jurisdiction to amend this Order, but only for the purpose of establishing it or maintaining it as a
Domestic Relations Order, provided, however, that no such amendment shall require the Plan to
provide any form of benefit or any option not otherwise provided by the Plan, and further provide
that no such amendment or right of the Court to so amend will invalidate this Order.
EXECUTED this I t4 (\
day of
BY T
Judge
CONSENT TO ORDER:
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Plaintiff/ Alternate Payee Date
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Attorney for Plaintiff/ Date
Alternate Payee
/ef'eg%n-dant / a ipant Date
Participant
Date
MELINDA G. SHAW,
Plaintiff
VS.
JONATHAN J. SHAW,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2010-1144
: CIVIL ACTION - LAW
: DIVORCE
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PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the Court for
entry of a divorce decree:
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1. Ground for divorce: irretrievable breakdown under 3301(c) of the Divorce
Code.
2. Date and manner of service of the complaint: Certified restricted mail
pursuant to an Affidavit of Service signed by the Defendant dated February 22, 2010, and
filed with the Court February 24, 2010.
3. (a) Date of execution of the affidavit of consent required by Section
3301(c) of the Divorce Code: by the Plaintiff on August 6, 2011, and filed with the Court
August 9, 2011; by the Defendant on August 1, 2011, and filed with the Court August 9,
2011.
4. Related claims pending: None. The Marital Property Settlement
Agreement dated August 1, 2011, resolved all outstanding claims between the parties.
5. (b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed
with the Prothonotary on August 9, 2011.
Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed
with the Prothonotary on August 9, 2011.
DATE:
Diane S. Baker, Esquire
Supreme Court ID #53200
27 South Arlene Street
Post Office Box 6443
Harrisburg, PA 17112-0443
(717) 671-9600
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNtY, PENNSYLVANIA
MELINDA G. SHAW
V.
JONATHAN J. SHAW
No. 2010-1144
DIVORCE DECREE
AND NOW, it is ordered and decreed that
MELINDA G. SHAW , plaintiff, and
JONATHAN J. SHAW 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 pa?rties 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. The Marital Property Settlement Agreement dated August 1, 2011,
resolved all outstanding claims between the parties and is incorporated but not
merged into this Decree.
By the C
Attest: J.
Prothonotary
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