HomeMy WebLinkAbout10-1602
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F,~~ti7LES\CGrnts\13517 Kline, E\13517.Ldcom
Revised: 3 /5 / 10 10:1 OAM
FILED-~;~•r~,C1r
,,F ~'Hc p~e~Ti~'~i~~DT~F?Y
Jennifer L. Spears, Esquire 11
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER~1~ ~4R `8 P~~ 3: 23
MARTSON LAW OFFICES CU,~~~~
I.D. 87445 +'~-r~~,v. ~~;' ~ ~,,fJ~'~lil`
10 East High Street L'r f, ~~
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
ERIC KLINE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. NO. 2010- ~ ~ ~ °~., CN • f terrk
CIVIL ACTION -LAW
LAURIE KLINE,
Defendant IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take prompt action. You are warned that if you fail to do so, the case may
proceed without you and a decree of divorce or annulment may be entered against you by the Court.
A judgment may also be entered against you for any other claim or relief requested in these papers
by the Plaintiff. You may lose money or property or other rights important to you, including custody
or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. Upon your request, the Court may require you and your
spouse to attend up to three sessions. A request for counseling must be made in writing and filed
with the Prothonotary within twenty (20) days of receipt of this Notice.
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.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
g~ 3 s~z . od f~ ~7
c,t ~ aa~Y9
R--~ ~- 3 ~sqs
ERIC KLINE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2010- ~~ 0 ~ C r u
CIVIL ACTION -LAW
LAURIE KLINE, :
Defendant IN DIVORCE
DIVORCE COMPLAINT UNDER SECTION 330~C1
1. Plaintiff is Eric Kline, who currently resides at 907 Alexander Spring Road, Carlisle,
PA 17015.
2. Defendant is Laurie Kline, who currently resides at 907 Alexander Spring Road,
Carlisle, PA 17015.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on September 19, 1987.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiffhas been advised that counseling is available and that Plaintiff may have the
right to request that the court require the parties to participate in counseling.
8. Plaintiff requests the Court to enter a decree of divorce.
WHEREFORE, Plaintiff requests the Court to enter a Decree dissolving the marriage
between Plaintiff and Defendant.
MARTSON LAW OFFICES
~ ~~
By
Jennifer LuSpears, Esquire
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
Date: March 5, 2010
T ~
/-
VERIFICATION
The foregoing Divorce Complaint is based upon information which has been gathered by my
counsel in the preparation of the lawsuit. 'The language of the document is that of counsel and not
my own. I have read the document and to the extent that the document is based upon information
which I have given to my counsel, it is true and correct to the best of my knowledge, information and
belief. To the extent that the content of the document is that of counsel, I have relied upon counsel
in making this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities, which provides that if I make knowingly false
averments, I may be subject to criminal penalties.
Eric Klin
F:\FILES\Ctirnts\13517 Kline, E\13517.Leos
Revised: 3/9/10 6:42AM
FILED--~ i-r ;CE
Jennifer L. Spears, Esquire
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FA~$~,~~ ! ~ p~~ ~; ~ ~
MARTSON LAW OFFICES
I.D. 87445 CUI`v" ~ 1 ;~ ~-~;\}1Y
10 East High Street ~, ; ~,~ r~~~~, ,~~, ~;
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
ERIC KLINE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v• NO. 2010-1602
CIVIL ACTION -LAW
LAURIE KLINE,
Defendant IN DIVORCE
ATTORNEY'S ACCEPTANCE OF SERVICE
I, Carol Lindsay, Esquire, attorney for Defendant Laurie Kline in the above-captioned action,
hereby accept service of the Complaint in the above action on March/ l , 2010, on her
behalf and certify that I am authorized to do so.
Date: ~J~~Q Z(JI(,
Carol Lindsay, s ire
F-+9LES\C6ents\13517 Kline, E\I3517.I.dcom
Revised: 3/5/10 10:10AM
Jennifer L. Spears, Esquire
MARTSON DEARDORFF WILLIAMS OTTO GILROY
MARTSON LAW OFFICES
I.D. 87445
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
l
r4 ?
ERIC KLINE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2010- ! (C b °?. Co.:. I 1 e ?n?
CIVIL ACTION - LAW
LAURIE KLINE,
Defendant IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take prompt action. You are warned that if you fail to do so, the case may
proceed without you and a decree of divorce or annulment may be entered against you by the Court.
A judgment may also be entered against you for any other claim or relief requested in these papers
by the Plaintiff. You may lose money or property or other rights important to you, including custody
or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. Upon your request, the Court may require you and your
spouse to attend up to three sessions. A request for counseling must be made in writing and filed
with the Prothonotary within twenty (20) days of receipt of this Notice.
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.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street g 3 S? . Db 1°? `7
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166 G? 32?`/?!
FRED 4;;;?; ;CF
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& FALLEP 10 MAR -8 PPS 3: 23
ERIC KLINE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2010- u
CIVIL ACTION - LAW
LAURIE KLINE,
Defendant : IN DIVORCE
DIVORCE COMPLAINT UNDER SECTION 3301(C)
1. Plaintiff is Eric Kline, who currently resides at 907 Alexander Spring Road, Carlisle,
PA 17015.
2. Defendant is Laurie Kline, who currently resides at 907 Alexander Spring Road,
Carlisle, PA 17015.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on September 19, 1987.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised that counseling is available and that Plaintiff may have the
right to request that the court require the parties to participate in counseling.
8. Plaintiff requests the Court to enter a decree of divorce.
WHEREFORE, Plaintiff requests the Court to enter a Decree dissolving the marriage
between Plaintiff and Defendant.
MARTSON LAW OFFICES
By , fa ,f l-Vv
Jennif L Spears, Esquire
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
Date: March 5, 2010
VERIFICATION
The foregoing Divorce Complaint is based upon information which has been gathered by my
counsel in the preparation of the lawsuit. The language of the document is that of counsel and not
my own. I have read the document and to the extent that the document is based upon information
which I have given to my counsel, it is true and correct to the best of my knowledge, information and
belief. To the extent that the content of the document is that of counsel, I have relied upon counsel
in making this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities, which provides that if I make knowingly false
averments, I may be subject to criminal penalties.
?. W,
Eric Klin
F:\FILES\Clients~13517 Kline, E\13517.1.aocwon
Revised: 7/6/10 2a IPM
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Jennifer L. Spears, Esquire
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER ~~ ~ ~ ~~- ~ ~ ;=~~'i ~: ~~
MARTSON LAW OFFICES
I.A. 87445 Cl.ljv ~~.::: ,:!~Ji~.liY
10 East High Street -~~~ ~"..'~;~r'1 `r~i~'"~`''',`'
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
ERIC KLINE, IN THE COURT OF COMMON PLEAS pF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. NO. 2010-1b02
CNIL ACTION -LAW
LAURIE KLINE,
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on
March 8, 2010.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention
to request entry of the decree.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn
falsification to authorities.
Date: ~ 1. ±.) I~} ~ ~~
Laurie Kline, Defendant
Jennifer L. Speazs, Esquire
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
I.U. 87445
10 East High Street
Cazlisle, PA 17013
(717} 243-3341
Attorneys for Plaintiff
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ERIC KLINE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. N0.2010-1602
CIVIL ACTION -LAW
LAURIE KLINE,
Defendant IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
~3301~1 AND & 3301(dl OF THE DIVORCE CODE
I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court
and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary.
I verify that the statements made in this waiver are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn
falsification to authorities.
S C~.~.~
Date: ~ ~ ~
Laurie Kline, Defendant
Jennifer L. Spears, Esquire i1,~ I~~r
- ~1•.ri7
- - -
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES Z~EO ~'~' ~~ ~~~;~ ~`=' ~ '.Y
I.D. 87445 'PM~3~ I`i
10 East High Street UIiP'~r '~~~~~~~~
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
ERIC KLINE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v NO. 2010-1602
CIVIL ACTION -LAW
LAURIE KLINE,
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on
March 8, 2010,
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention
to request entry of the decree.
I verify that the statements made in thi,5 affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn
falsification to authorities.
Date: e2 b ~~
Eric ne, Plaintiff
Jennifer L. Spears, Esquire
MARTSON DEARDORFF WILLIAMS OTTO GILROY
MARTSON LAW OFFICES
I.D. 87445
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
~~'.~' - - `r.
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PMZ3:W
ERIC KLINE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. N0.2010-1602
CIVIL ACTION -LAW
LAURIE KLINE,
Defendant IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
,§3301lc,~ AND § 3301 (dl OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court
and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary.
I verify that the statements made in this waiver are true and correct. I understand that false
statements herein are made subject to the penalties of 18 . C.S. § 4904 relating to unsworn
falsification to authorities.
Date:^~ ~ ~ ~~
Eric Kline laintiff
ERIC KLINE
V.
LAURIE KLINE
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2010-1602
DIVORCE DECREE
AND NOW, _ ~ e~~yy~, ~ ~•~`~ , it is ordered and decreed that
ERIC KLINE
plaintiff, and
LAURIE KLINE ,defendant, are divorced from the
bonds of matrimony.
Any existing spousal support order shall hereafter be deemed an order for
alimony pendente lite if any economic claims remain pending.
The court retains jurisdiction of any claims raised by the parties to this action
for which a final order has not yet been entered. Those claims are as follows: (If no
claims remain indicate "None.")
None.
By the Court,
Attest: ~,
Prothonotary
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ERIC KLINE, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
NO. 2010-1602 CIVIL
LAURIE KLINE,
Defendant IN DIVORCE
QUALIFIED DOMESTIC RELATIONS ORDER
This cause came before the Court for entry of a Qualified Domestic Relations Order
as that term is defined and applied under Section 414(p) of the Internal Revenue Code of
1986 or any successor statute thereto (the "Code"). As the terms of this Order have been
stipulated and agreed to by the parties, and the Court has been fully advised thereof, IT IS
HEREBY ORDERED AS FOLLOWS:
1. Background. This Order pertains to the Members 15t Federal Credit
Union retirement account (hereinafter referred to as the "Plan"); is incorporated into the
judgment order dissolving the marriage of the parties; and may be amended if necessary to
comply with the Code. The Court retains jurisdiction of the subject matter hereof and the
parties hereto to enforce the terms of this Order.
2. Applicable Law. This Order is intended to be a Qualified Domestic
Relations Order (hereinafter referred to as "QDRO") as that term is defined by Section
414(p) of the Internal Revenue Code and Section 206(d)(3) of ERISA, as amended. This
Order relates to the equitable division of martial property as defined under the Pennsylvania
Domestic Relations Code of 1980, as amended.
3. Definitions. As used in this Order, the following terms shall apply:
a. "Participant" shall mean Laurie A. Kline, whose current address is
907 Alexander Spring Road, Carlisle, Pennsylvania 17015-9183, and whose Social Security
Number is (deleted on original) and whose date of birth is November 28,
1967. Attorney: Carol J. Lindsay, Esquire, 26 West High Street, Carlisle, PA 17013.
b. "Alternate Payee" shall mean Eric Kline, whose current address is
142 Virginia Avenue, Carlisle, PA 17013, and whose Social Security Number is
(deleted on original) and whose date of birth is April 16, 1961. Attorney: Jennifer L.
Spears, Esquire, Ten East High Street, Carlisle, PA 17013.
C. "Administrator" shall mean The Plan Administrator for the Members
1' Federal Credit Union retirement plan.
4. Assignment to Alternate Payee. The Alternate Payee (who is the former
spouse of the Participant) is awarded and assigned the following from Participant's plan
account: $35,000.00. Any outstanding loans shall be treated or allocated as follows:
Participant shall continue to make payment on any outstanding loans and such loans shall
not in any way affect the Alternate Payee's monetary benefit as assigned in this paragraph.
5. Commencement of Assigned Benefits to Alternate Payee. The Alternate
Payee shall receive the Alternate Payee's assigned benefit under the Plan as soon as
administratively practicable following the Administrator's determination that this Order is a
Qualified Domestic Relations Order.
6. Form of Payment. Upon Alternate Payee's request for an immediate
distribution, as soon as administratively feasible after the date this Order is determined to
be a QDRO by the Plan Administrator, the Plan shall distribute Alternate Payee's interest in
a single lump sum payment directly to Alternate Payee, or at the direction of Alternate
Payee, to an Individual Retirement Account. The Alternate Payee shall complete such
distribution forms as may be required under the terms of the Plan.
In the event Alternate Payee does not request an immediate distribution, as soon as
administratively feasible after this Order is determined to be a QDRO by the Plan
Administrator, the Alternate Payee's interest shall be separated from the Participant's
interest in the account and will be held by the Plan in a separate account for the Alternate
Payee until Alternate Payee's request for distribution. Such separate account will be
credited with its allocable share of the income and losses of the Plan but shall not be
credited with any future contributions or forfeitures. Alternate Payee shall have the same
ability to designate the investment of the amounts in the separate account as the
Participant would otherwise have had with respect to those amounts. In accordance with
the Plan, as soon as administratively feasible after Participant's Normal Retirement, death
or termination of employment, or at such earlier time as Alternate Payee may request in
writing, the Plan shall distribute the amount in Alternate Payee's separate account to
Alternate Payee in a single lump sum payment directly or, at the direction of the Alternate
Payee, to an Individual Retirement Account. The Alternate Payee shall complete such
distribution forms as may be required under the terms of the Plan.
7. Death of Participant. The death of the Participant, either before or after the
Alternate Payee has received payment of the Alternate Payee's assigned benefit, shall
neither affect the Alternate Payee's right to payment of the assigned benefit nor entitle the
Alternate Payee to any additional benefits.
8. Death of Alternate Payee.
a. Before Commencement to Alternate Payee. If the Alternate Payee
dies prior to receiving payment of the benefits assigned under this Order, the benefits
payable under this Order shall be paid to Alternate Payee's beneficiary, or if no beneficiary
has been designated, then to his estate.
b. After Commencement to Alternate Payee. If the Alternate Payee
dies after receiving payment of the benefits assigned under this Order, no additional
benefits shall be payable under this Order.
9. Taxes. For purposes of Sections 402(a)(2) and 72 of the Internal Revenue
Code, any Alternate Payee who is the former spouse of the Participant shall be treated as
the distributee of any distribution or payments made to the Alternate Payee under the terms
of this Order, and as such, will be required to pay the appropriate federal income taxes on
such distribution. The Alternate Payee shall have the right to roll over the benefits
distributed to him pursuant to the terms and provisions of this Order to an eligible retirement
plan such as an Individual Retirement Account. Subject to the conditions imposed by
ERISA and the Internal Revenue Code, such transfer shall be considered a tax-free rollover
of the benefits distributed.
10. Continuing Interests. From the date of this Order and thereafter, except as
provided herein, the Alternate Payee shall have no further right or interest in any portion of
Participant's Plan benefits. From the date of this Order and thereafter, except as provided
herein, the Participant shall have no further right or interest in any portion of the Plan
benefits which are assigned to the Alternate Payee pursuant to this Order.
11. Costs for Implementation. Any reasonable costs incurred by the Plan
Administrator to effectuate the terms and provisions of the Qualified Domestic Relations
Order shall be assessed against the parties such that the Alternate Payee pays 50% of the
costs and the Participant pays 50% of the costs. Any surrender charges incurred on the
portion transferred to Alternate Payee shall be paid by the Alternate Payee.
12. Plan Provisions to Govern. This Order shall not be construed to require
the Plan, the Administrator, or any trustee or other fiduciary with respect to the Plan to take
any action which is inconsistent with any provision of the Plan, as now or hereafter in effect.
The Participant and the Alternate Payee shall be subject to all of the provisions of the Plan
and any administrative rules as from time to time in effect under the Plan.
13. Limitations. This order shall not be construed to require the Plan, the
Administrator, or any trustee or other fiduciary with respect to the Plan to:
a. Make any payment or take any action which is inconsistent with any
federal law, rule, regulation, or applicable judicial decision;
b. Provide any type or form of benefit, or any option, which is not
otherwise provided under the provisions of the Plan;
C. Pay benefits to the Alternate Payee that are required to be paid to
another alternate payee under another order previously determined to be a Qualified
Domestic Relations Order in accordance with the provisions of Code Section 414(p) and
Section 206(d) of the Employee Retirement Income Security Act.
14. Mailing to Last Known Address. All appropriate payments, notices and
other communications shall be mailed to the Participant and the Alternate Payee at the
respective addresses set forth in Paragraph 3 above, until such time as the Participant or
Alternate Payee advises the Administrator in writing of the occurrence of a change of
address. Any benefit payment or communication to the Alternate Payee at the Alternate
Payee's last known address shall operate on a complete discharge of the obligations, with
respect to such payment or communication, of the Plan.
15. Parties to Cooperate. If the Administrator of the Plan does not agree that
this is a "Qualified" Domestic Relations Order under Code Section 414(p), each party shall
cooperate and do all things reasonably necessary to devise a form of Order acceptable to
the Administrator as a Qualified Domestic Relations Order.
9 10
-
Date
Witness
Witness
BY THE COURT:
Judge
Laurie Klin , Participant
Dated:
co
Eric KR e, Iternate Payee
Dated:
Co Es m tLa
A?
4 1?
CEP 9 9 ZU10
ERIC KLINE, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
NO. 2010-1602 CIVIL
LAURIE KLINE,
Defendant IN DIVORCE
QUALIFIED DOMESTIC RELATIONS ORDER
SOCIAL SECURITY COVER SHEET
For the preservation of privacy, it is the practice of this office not to disclose Social
Security Numbers in public court documents whenever possible, particularly where court
documents are more commonly becoming available to access on-line. Federal law has
been enacted to address some of these concerns, but State law has not yet brought
historical practice into accordance with recent financial and health information privacy laws.
Typically, Qualified Domestic Relations Orders require the inclusion of Social
Security Numbers in order to properly identify the Participants and Alternate Payees in a
particular Plan. This Qualified Domestic Relations Order will be circulated only among the
parties and the Plan Administrator, unless requested by the Court or otherwise directed by
the parties or the Plan Administrator.
Therefore, I request that the Qualified Domestic Relations Order attached hereto be
signed as an Order but not docketed for public viewing by the Prothonotary.
Respectfully submitted:
Carol J. Linds , , Esquire
Saidis, Flower & Lindsay
26 West High Street
Carlisle, PA 17013
(717) 243-6222
-bao
Ilk/ as
z
DEC 2 0 2010
Eric Mine
Plaintiff
VS
Laurie Mine
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2010-1602 CIVIL
IN DIVORCE
QUALIFIED DOMESTIC RELATIONS ORDER
I. Recitals
1. The parties to this action have entered into a Property Settlement Agreement
dated ?l 01(x. The Court incorporated the Property Settlement Agreement into its
Decree of Dissolution of Marriage dated JU,Ay ?010
2. This Order creates and recognizes the existence of an Alternate Payee's right to
receive a portion of the Participant's benefits payable under an employer sponsored defined
benefit plan which is intended to be qualified under Section §401(a) of the Internal Revenue
Code of 1986, as amended ("Code"). The Court intends this Order to be a Qualified Domestic
Relations Order ("QDRO") within the meaning of Code §414(p). The Court enters this QDRO
pursuant to its authority under the 23 P.C.S.A. §3502.
II. Statements of Fact Pursuant to Code §414(p)
3. This QDRO applies to the Members 1St Federal Credit Union Pension Plan
("Plan"), as sponsored by Members 1St Federal Credit Union. Further, this Order shall apply to
any successor plan to the Plan or any other plan(s) to which liability for provision of the
Participant's benefits described below is incurred. Any benefits accrued by the Participant
under a predecessor plan of the employer or any other defined benefit plan sponsored by the
Participant's employer, whereby liability for benefits accrued under such predecessor plan or
other defined benefit plan has been transferred to the Plan, shall also be subject to the terms of
this Order. Any changes in Plan Administrator, Plan sponsor, or name of the Plan shall not
affect Alternate's Payee's rights as stipulated under this Order.
4. Laurie Mine ("Participant") is a participant in the Plan. Eric Mine ("Alternate
Payee") is the alternate payee for purposes of this QDRO.
5. The Participant's name, mailing address, social security number, daU of_7:f
birth are: rrs
F-9
Name: Laurie Mine :Z:?o r--10
o
Address: 907 Alexander Spring Road - c S
Carlisle, PA 17013
SS#: See Addendum Z ?- D?
DOB: See Addendum ,
= F --
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6. The Alternate Payee's name, mailing address, social security number, and date of
birth are:
Name: Eric Mine
Address: 142 Virginia Avenue
Carlisle, PA 17013
SS#: See Addendum
DOB: See Addendum
The Alternate Payee shall have the duty to notify the Plan Administrator in writing of any
changes in this mailing address subsequent to the entry of this Order. The name and address the
Plan Administrator is as follows:
Name: Members 1St Federal Credit Union
Address: 5000 Louise Drive
Mechanicsburg, PA 17055
7. This Order assigns to Alternate Payee an amount equal to the actuarial equivalent of
12.9% of the marital portion of Participant's accrued benefit under the Plan (including any
temporary or supplemental benefits that may become payable) as of the Participant's benefit
commencement date, or the Alternate Payee's benefit commencement date, if earlier. For
purposes of calculating Alternate Payee's benefit hereunder, the Plan Administrator is instructed
to use, as applicable, the Participant's average compensation in effect as of the Alternate Payee's
benefit commencement date. The Alternate Payee and Participant were married on
September 19, 1987. The marital portion of Participant's accrued benefit shall be determined by
multiplying the Participant's accrued benefit by a fraction, the numerator of which is the
Participant's Benefit Service under the Plan earned while married to the Alternate Payee, and the
denominator of which is the Participant's Benefit Service under the Plan as of the earlier of the
date the Participant permanently ceases to accrued benefits thereunder or the date the Alternate
Payee commences to receive benefits hereunder. For this purpose, the marriage shall be treated
as having terminated as of September 30, 2009.
In addition to the above, the Alternate Payee shall receive a pro rata share of any
postretirement cost-of-living adjustments or other economic improvements made to the
Participant's benefits on or after the date of his retirement. Such pro rata share shall be
calculated in the same manner as the Alternate Payee's share of the Participant's retirement
benefits is calculated pursuant to this Section 7.
If there should be a legal cause by which the Participant's benefits under the Plan
may be offset by the amount of a judgment or settlement that the Participant is required to pay as
a result of a crime involving the Plan, nevertheless, the award in this Order to the Alternate
Payee shall be based on the Participant's benefits before any such offset.
Notwithstanding the language set forth in this Section 7, in the event that the
Alternate Payee becomes entitled to a qualified preretirement survivor annuity under Section 9 of
this Order, then the Alternate Payee's right to a share of the Participant's benefits as called for
under this Section 7 shall be terminated as of the date of the Participant's death, and such
preretirement death benefit shall be payable to the Alternate Payee in lieu of any other benefits to
which he may be entitled under the terms of this Order.
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III. Time and Manner of Payment
S. The Alternate Payee may elect to commence his benefits under the Plan at any time
on or after the date the Participant attains the earliest retirement age as defined by Code
§414(p)(4)(B). Further, in the event the Participant becomes eligible to commence benefits at an
earlier date as the result of a disability retirement, the Alternate Payee shall also be entitled to
commence his share of the benefits at such earlier date. Notwithstanding the above, the
Alternate Payee shall commence his share of the benefits no later than the Participant's actual
date of benefit commencement. The Plan Administrator is instructed to provide any required
notice and election forms in a timely manner to the Alternate Payee before such date of benefit
commencement.
The Alternate Payee shall be entitled to receive his benefits in any form available
under the terms and provisions of the Plan, other than a qualified joint and survivor annuity with
his current spouse as the survivor annuitant. The Alternate Payee shall execute any forms
required by the Plan Administrator.
The form of benefits paid to the Alternate Payee shall be based on the life
expectancy of the Alternate Payee. Any actuarial reduction that might be necessary to convert
Alternate Payee's benefits to one based on the Alternate Payee's lifetime shall be borne by the
Alternate Payee. Further, should any early commencement reduction be necessary in the event
that the Alternate Payee commences his benefits prior to Participant's normal retirement date,
then such reduction shall be applied to Alternate Payee's benefits.
The Alternate Payee shall be entitled to a pro rata share of any early retirement
subsidy (including any temporary or supplemental benefits) provided under the Plan to the
Participant on the date of her retirement, and in the event the Alternate Payee has already
commenced his share of the benefits on the date of the Participant's retirement, then the amounts
payable to the Alternate Payee shall be recalculated in accordance with the Plan Administrator's
practices and the Plan's actuarial principles in order to provide the Alternate Payee with the pro
rata share of such early retirement subsidy. Such pro rata share shall be calculated in the same
manner as the Alternate Payee's share of the Participant's retirement benefits is calculated
pursuant to Section 7 of this Order.
9. In the event the Participant predeceases the Alternate Payee and neither the
Participant nor the Alternate Payee has commenced their benefits under the Plan, the Alternate
Payee shall be designated as the surviving spouse of the Participant for the purposes of
establishing the Alternate Payee's entitlement to receipt of all or a portion of the preretirement
survivor annuity.
This designation applies to the portion of the Participant's accrued benefit assigned
to the Alternate Payee as set forth in Section 7 of this Order. The Alternate Payee shall be
treated as the surviving spouse for the purposes of the preretirement survivor annuity benefits
that are attributable to the portion of the Participant's accrued benefit assigned to the Alternate
Payee and any subsequent spouse of the Participant shall not be treated as a surviving spouse for
such purposes. In the event that the costs associated with providing this preretirement survivor
annuity benefit are not fully subsidized by the Participant's employer, the Participant must make
an affirmative election for such preretirement survivor annuity benefit coverage in a timely
manner and in accordance with the Plan's election procedures.
Further, if the Plan provides for any death benefit in excess of a qualified
preretirement survivor annuity, the Alternate Payee shall be designated as the beneficiary with
3
respect to the Alternate Payee's share of the Participant's accrued benefit of the excess death
benefits payable.
10. If the Alternate Payee predeceases the Participant prior to the commencement of
his benefits, the Alternate Payee's portion of the Participant's benefits as set forth in Section 7 of
this Order shall be payable in equal portions to the surviving children of the Participant and the
Alternate Payee as if they were the original Alternate Payee created hereunder. The Alternate
Payee or Participant shall have no authority to alter this beneficiary designation. Payments to
the surviving children would begin as soon as administratively possible after the Alternate
Payee's death, or the earliest date permitted by the Plan, if later. Payments will be actuarially
adjusted to be paid over each child's lifetime. As of the execution date of this Order, the children
of the Alternate Payee and the Participant are as follows:
Baylie Mine
Carley Mine
11. If the Alternate Payee predeceases the Participant after his benefit commencement
date, any remaining benefits shall be paid in accordance with the form of benefit elected by the
Alternate Payee.
12. In the event that the Participant's accrued benefit is limited or reduced as the result
of a benefit limitation imposed under Code §415, the Alternate Payee's share of the benefits shall
also be limited or reduced in the same proportion and to the same extent as the Participant's
benefits.
13. On and after the date that this Order is deemed to be a QDRO, but before the
Alternate Payee receives his distribution under the Plan, the Alternate Payee shall be entitled to
all of the rights and election privileges that are afforded to active participants, except as otherwise
noted in this Order.
14. All payments made pursuant to this Order shall be conditioned on the certification
by the Alternate Payee and the Participant to the Plan Administrator of such information as the
Plan Administrator may reasonably require from such parties, including the information the Plan
Administrator requires to make the necessary calculation of the benefit amounts contained
herein.
15. It is the intention of the parties that this Order continue to qualify as a QDRO
under Code §414(p), as it may be amended from time to time, and that the Plan Administrator
shall reserve the right to reconfirm the qualified status of the Order at the time benefits become
payable hereunder.
16. 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 Plan to the extent that she has received such benefit payments and
shall forthwith pay such amount so received directly to the Plan within ten (10) days of receipt.
In the event that 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 Plan to the extent that he has received such benefit payments and
shall forthwith pay such amount so received directly to the Plan within ten (10) days of receipt.
17. The Participant shall not take any actions, affirmative or otherwise, that can
circumvent the terms and provisions of this QDRO, or that could diminish or extinguish the rights
4
and entitlements of the Alternate Payee as set forth herein. Should the Participant take any
action or inaction to the detriment of the Alternate Payee, she shall be required to make sufficient
payments directly to the Alternate Payee to the extent necessary to neutralize the effects of her
actions or inactions and to the extent of the Alternate Payee's full entitlements hereunder.
18. In the event that the Participant's benefits, or any portion thereof, become payable
to the Participant as a result of termination or partial termination, then the Alternate Payee shall
be entitled to commence his benefits immediately in accordance with the terms of this QDRO and
in accordance with the termination procedures of the Plan and the Pension Benefit Guaranty
Corporation. Further, should the Participant's benefits be reduced as a result of such termination
or partial termination, then the amounts otherwise payable to the Alternate Payee under this
QDRO shall be reduced to the same extent and in the same ratio as the Participant's benefits are
reduced.
19. After payment of the amount required by this QDRO, the Alternate Payee shall
have no further claim against the Participant's interest in the Plan.
20. The Alternate Payee assumes sole responsibility for the tax consequences of the
distribution under this QDRO.
IV. Recitals Pursuant to Code §414(p)(3)
21. This QDRO does not require the Plan to provide any type or form of benefit the Plan
does not otherwise provide.
22. This QDRO does not require the Plan to provide increased benefits determined on
the basis of actuarial value.
23. This QDRO does not require the Plan to pay any benefits which another order
previously determined to be a Qualified Domestic Relations Order requires the Plan to pay to
another alternate payee.
V. Procedure for Processing this QDRO
24. The Plan Administrator promptly shall notify the Participant and the Alternate
Payee of the receipt of this QDRO and shall notify the Participant and the Alternate Payee of the
Plan's procedures for determining the qualified status of this QDRO. The Plan Administrator
shall determine the qualified status of the QDRO and shall notify the Participant and the
Alternate Payee of the determination within a reasonable period of time after receipt of this
QDRO.
25. The Court shall retain jurisdiction with respect to this Order to the extent required
to maintain its qualified status and the original intent of the parties as stipulated herein.
5
In the event that the Plan Administrator determines that an overpayment has been
made to the Participant and/or the Alternate Payee for any reason, including but not limited to,
the Participant's retroactive eligibility for Social Security disability payments, and the parties
cannot come to an agreement regarding their respective liability toward the Plan's recoupment of
such overpayments, the Court shall retain jurisdiction regarding the allocation of such
repayments to the Plan between the Participant and the Alternate Payee.
ST
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EXECUTED this ? day of
CONSENT TO ORDER:
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Plaintiff/ t rnate Payee ate
Atto eye or Plaintiff/ Date
Alternate Payee
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BY THE COURT
ADDENDUM TO DOMESTIC RELATIONS ORDER
For Submission to the Plan Administrator Only
Due to the Federal Privacy Act, many state courts prohibit the inclusion of personal data in
public records to prevent identity theft. Therefore, please forward the following information
sheet to the Plan Administrator when submitting the court certified copy of the Domestic
Relations Order. Do NOT file the Addendum with the court.
Participant Information
Name: Laurie Kline
Address: 907 Alexander Spring Road
Carlisle, PA 17013
SSN: 202-62-5911
Date of Birth: November 28, 1967
Alternate Payee Information
Name: Eric Kline
Address: 142 Virginia Avenue
Carlisle, PA 17013
SSN: 191-56-4162
Date of Birth: April 16, 1961
Participant Attorney's Information
Name: Carol J. Lindsay, Esq.
Address: Saidis, Flower & Lindsay
26 West High Street
Carlisle, PA 17013
Phone Number: (717) 243-6222
Alternate Payee Attorney's Information
Name: Jennifer L. Spears, Esq.
Address: Martson Law Offices
10 East High Street
Carlisle, PA 17013
Phone Number: (717) 243-3341
The identifying information for the Participant's and Alternate Payee's children as of the time
this QDRO was executed is as follows:
Child #1
Child #2
Name: Baylie Kline
Address: 907 Alexander Spring Road
Carlisle, PA 17013
SS#: 171-78-1517
DOB: May 26, 1998
Carley Kline
907 Alexander Spring Road
Carlisle, PA 17013
170-82-4202
March 31, 2004
The court certified copy of the Domestic Relations Order and this Addendum should be sent to:
Members 1St Federal Credit Union
Attn: Ms. Lisa McCardell, Mgr. of Human Resources
5000 Louise Drive
Mechanicsburg, PA 17055