HomeMy WebLinkAbout04-2772
II
SHANNON DIMM,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: No. 01.~77J.- ~--c.-
vs.
JOHN DIMM,
Defendant
: CIVIL ACTION - AT LAW IN DNORCE
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 you,
including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the Office of the
Prothonotary at the Cumberland County Courthouse, Harrisburg, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DNORCE 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 LmERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(800) 990-9108
ORDER/NOTICE TO WITHHOLD INCOME FOIt SUPPORT
State Commonwealth of Pennsvlvania
Co.lCity/Dist. of CUMBERLAND
Date of Order/Notice 07/13/04
Tribunal/Case Number (See Addendum for case summary)
@Original Order/Notice
o Amended Order/Notice
o Terminate Order/Notice
Employer~ithholder's Federal EIN Number
RE: DIMM, JOHN M.
Employee/Obligor's Name (Last, First, MI)
BCA EMPLOYEE MANAGMENT
717 MARKET ST
LEMOYNE PA 17043-1581
GROUP
171-68-6386
Employee/Obligor's Social Security Number
5296101330
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
MI, </~'1 S af,1/)tf
/JI9(!SC$ 1~~/6G, 'I:~ Y
~ Custodial Parent's Name (last, First, M1)
, ;l.(>(;I/. - (}. 7~"'" {,I/
'IJ~zs. 99 ~/l;'~ Wg/
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND 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.
$ 315.00 per month in current support
$ 0.00 per month in past-due support
$ 0.00 per month in medical support
$ 0 . 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 315.00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 72.69 per weekly pay period.
$ 145.38 per biweekly pay period (every two weeks).
$ 157.50 per semimonthly pay period (twice a month).
$ 315.00 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 #10 on pg. 2).
Arrears 12 weeks or greater?
Oyes 0 no
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE D~F~~DA/IIT'S NAME AND THE PACSES MEMBER ID (shown
...~ n'" _,..IO/>H"" c_ -"'0'''''9. "'IT Q OROU m" <'ROC"""
00 NO","O CU" ;~~:L4 111II\' f;~.. "'"' co~ ' ~'" "'.
Date of Order: v ~ \(6.., ~
Ed0~ t.3 (jAYL87
Service Type M
OMB No.: 0970.0154
Form EN-028
Worker 10 $IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If ~hecked you are required to prpvide a copy of this form to your employee. If your employee works in a state that is
different from the state that issued this order, a copy must be provided to your employee even if the box is not checked.
1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned
businesses located on a reservation that choose to withhold in accordance with this notice.
2. 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.
3. Combining Payments: You can combine withheld amounts from more than one employee/obligor'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/obligor.
4.* Rcpo,lihg tl,~ Payddtc/D.ite o(Witl,l,oldit,g. '(otJ IlIust lepolt the pc\ydata{date of nitl',holdil,g nLCI, 5elldi"g tl,~ rH1ylllellt. The
j5AyJatc/,J,Mt of nitl,I,oIJihg;& tile diile 0" vvl.id, 0"10'-"11 neB nitl.l.eld hUll. tl,G elllploYI=e'5 nage3. 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.
S. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee/obligor and you are unable to honor all support Order/Notices due to Federai 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 #10 below)
6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you.
Please provide the information requested and retum a copy of this Order/Notice to the Agency identified below.
WITHHOLDER'S ID: 5423100185
EMPLOYEE'S/OBLlGOR'S NAME:
EMPLOYEE'S CASE IDENTIFIER:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
DIMM, JOHN M.
5296101330
DATE OF SEPARATION:
7. 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.
8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you shouid 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.
9. Antiodiscrimination: 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/obligor 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 governs.
10.' Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 USe. ~1673 (b)l; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxesi Social Security taxes; and Medicare taxes.
11. 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 respect to these items.
Submitted By:
DOMESTIC RELA nONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at 1717) 240-6225 or
by FAX at (717) 240-6248 or
by internet www.childsupport.state.pa.us
Service Type M
Page 2 of 2
Form EN-028
Worker 10 $IATT
OMB No.: 0970-0154
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: DIMM, JoHN M.
PACSES Case Number 156106438
Plaintiff Name
sHAJlNON M. DIMM
Docket Attachment Amount
004'2'98 2004 $ 203.00
Child(ren)'s Name(s):
DOB
you are required to enroll the child(ren)
in any health insurance coverage available
employee'slobligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
you are required to enroll the child(ren)
above in any health insurance coverage available
employee'slobligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
you are required to enroll the child(ren)
In any health insurance coverage available
employee'slobligor's employment.
Service Type M
PACSES Case Number 998106548
Plaintiff Name
SHAJlNON M. DIMM
Docket Attachment Amount
04~ CIVIL$ 112.00
Child(ren)'s Name(s):
DaB
you are required to enroll the child(ren)
above in any health insurance coverage available
employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Attachment Amount
$ 0.00
Child(ren)'; Name(s):
Docket
DOB
you are required to enroll the child(ren)
In any health insurance coverage available
employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
Addendum
Form EN-028
Worker 10 $IATT
OMB No.: 0970-0154
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SHANNON DlMM,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: No. O<..[..J. 17), Cu..'0 J;~
vs.
JOHN DlMM,
Defendant
: CIVIL ACTION - AT LAW IN DIVORCE
COMPLAINT FOR DIVORCE AND CUSTODY
AND NOW, comes the above captioned Plaintiff, Shannon Dimm, through her attorneys,
The Law Offices of Patrick F. Lauer, Jr., L.L.C., and makes the following avennents:
I. Plaintiff is Shannon Dimm, an adult individual, who currently resides at 3416
Lisburn Road, Mechanicsburg, Cumberland County, and State of Pennsylvania.
2. Defendant is John Dimm, an adult individual, who currently resides at 420
Candlewyck Road, Camp Hill, Cumberland County, and State of Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of
Pennsylvania for a period of more than six (6) months immediately preceding the filing of this
Complaint.
COUNT 1- REOUEST FOR A NO-FAULT DIVORCE
UNDER &3301 OF THE DIVORCE CODE
The Plaintiff, through her attorney's, seeks to obtain a Decree in Divorce from the above
named Defendant, John Dimm, upon the grounds hereinafter set forth:
4. Paragraphs one (I) through three (3) are incorporated herein through reference.
5. The Plaintiff and Defendant were married on February 22, 2003 in Mechanicsburg,
County of Cumberland, and State of Pennsylvania.
6. The Plaintiff and Defendant are both Citizens of the United States of America.
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7. There has been no prior action for divorce or annulment instituted by either of the
parties in this or any other jurisdiction.
8. The 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.
9. The Plaintiff avers that the marriage is irretrievably broken.
WHEREFORE, the Plaintiff respectfully requests that this Honorable Court enter a Decree
in Divorce.
COUNT ll- COMPLAINT FOR CUSTODY
The Plaintiff, through her attorney's, seeks to obtain custody of her minor child and makiS
the following averments in support thereof: i
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Plaintiff is "Mother," an adult individual, who currently resides at 3416 Lisburn \
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Defendant is "Father," an adult individual, who currently resides at 42~
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10.
Paragraphs one (1) through nine (9) are incorporated herein through reference.
II.
Road, Mechanicsburg, Cumberland County, and State of Pennsylvania.
12.
CandleWyck Road, Camp Hill, Cumberland County, and State of Pennsylvania.
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13.
Plaintiff seeks custody of the following minor child:
Name:
Address:
Age:
Mackenzie A. Dimm
3416 Lisburn Road
Mechanicsburg, PA 17055
9 months
14. The child was not born out of wedlock.
15. The child is presently in the custody of Mother, whose address is 3416 Lisburn
Road, Mechanicsburg, Cumberland County, and State of Pennsylvania.
16. During the past five years, the child has resided with the following persons at the
following address:
"
Persons: Address: Dates
Shannon Dimm 5316 Oxford Circle July 22, 2003-
John Dimm Mechanicsburg, P A 17055 May 10, 2004
Shannon Dimm 3416 Lisbum Road May 10, 2004-
Mechanicsburg, PA 17055 Present
17. The Mother of the child is Shannon Dimm, who currently resides at 3416 Lisbum
Road, Mechanicsburg, Cumberland County, and State of Pennsylvania.
She is Married.
18. The Father of the child is John Dimm, who currently resides at 420 CandleWyck
road, Camp Hill, Cumberland County, and State of Pennsylvania.
He is Married.
19. The relationship of Plaintiff to the child is that of Mother . Plaintiff currently resides
with the following people:
Names:
Relationship:
MackelWe A. Dimm
Carol Smarsh
Thomas Smarsh
Daughter
Mother
Father
20. The relationship of Defendant to the child is that of Father. Defendant currently
resides alone.
21. Plaintiff has not participated as a party or witness, or in another capacity, in other
litigation concerning the custody of the child.in this or another court.
22. Plaintiff has no information of a custody proceeding concerning the child pending in
a court of this Commonwealth.
23. Plaintiff does not know of a person not a party to the proceedings who has physical
custody of the child or claims to have custody or visitation rights with respect to the child
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24. The best interests and permanent welfare ofthe child will be served by granting the
relief requested because Plaintiff is in a better position to take care of the child as both mother and
Primary Caregiver for the child's entire life.
25. Each parent whose parental rights to the child has not been terminated and the
person who has physical custody of the child have been named as parties to this action.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order
granting her custody of the child.
COUNT m - REOUEST FOR SPOUSAL SUPPORT AND/OR ALIMONY PENDENTE
LITE ANDALIMONY UNDER ~6370l(A) AND 3702 OF THE DIVORCE CODE
26. Paragraphs one (I) through twenty-five (25) are incorporated herein through
reference.
27. Plaintiff is unable to sustain herself during the course oflitigation.
28. Plaintiff lacks sufficient property to provide for her reasonable needs and is unable
to sustain herself through appropriate employment.
29. Plaintiff requests the Court to enter an award of spousal support and/or alimony
pendente lite until final hearing and thereupon to enter an order of alimony in her favor pursuant to
~~3701(a) and 3702 of the Divorce Code.
WHEREFORE, plaintiff respectfully requests the Court to enter an award of
II
spousal support and/or alimony pendente lite until final hearing and thereupon to enter an order oj
alimony in her favor pursuant to ~~3701(a) and 3702 of the Divorce Code.
/
,;
Respe<;tfu1\y sub
J~ . Caraciolo, squire
,h 1 08 Market Street, Aztec Building
{Camp Hill, Pennsylvania 17011-4706
ID# 90919 Tel. (717) 763-1800
Date: oCt f6f7
II
SHANNON DIMM,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No.
JOHN DIMM,
Defendant
: CIVIL ACTION - AT LAW IN DIVORCE
VERlFICATION
I verifY that the statements made in this Complaint for Divorce and Custody 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: (I> \~)\ O.i-.j
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Signature:
II
SHANNON DIMM,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No.
JOHN DIMM,
Defendant
: CIVIL ACTION -ATLAWINDIVORCE
CERTIFICATE OF SERVICE
I hereby certify that I am this day serving a copy of the foregoing Complaint for Divorce
and Custody upon the person and in the manner indicated below, which service satisfies the
requirements of the Pennsylvania Rules of Civil Procedure, by mailing a copy of the same,
certified mail, return receipt requested, to the person named as follows:
John Dimm
420 Candlewyck Road
Camp Hill, PA 17011
o.reoCff 1
se D. Caraciolo, Esquire
108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID#90919 Tel. (717) 763-1800
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vs.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:No. ol.(~ 2/1 ~
SHANNON DI:MM,
Plaintiff
JOHN DI:MM,
Defendant
: CIVIL ACTION - AT LAW IN DIVORCE
PETITION FOR ALIMONY PENDENTE LITE CONFERENCE
AND NOW comes the Plaintiff, Shannon Dimm, by and through her attorney, Joseph D.
Caraciolo, Esq., of the Law Offices of Patrick Lauer, L.L.C., and respectfully files this petition for
relief averring as follows:
1. Plaintiff, filed a divorce complaint with the filing of this petition.
2. Plaintiff's Divorce Complaint included a request for Spousal Support and/or
Alimony Pendente Lite (See Exhibit "A" attached hereto.)
3. Plaintiff asserts that she is entitled to Alimony Pendente Lite and is requesting a
hearing on the matter.
4. A conference regarding spousal support is scheduled for the 13th day of July, 2004
at 8:30 a.m. before a conference officer of the Domestic Relations Section at 13 North Hanover
Street, Carlisle, Pennsylvania, 17013, (See Exhibit "B" attached hereto.)
5. The Defendant will be adequately prepared to discuss both spousal support and
alimony pendente lite at the above-mentioned conference.
6. The Defendant will not be prejudiced in any way by the inclusion of Alimon)
Pendente Lite at the above scheduled time and place.
WHEREFORE Defendant respectfully requests this Honorable Court grant her the
requested relief and schedule a conference on the issue of Alimony Pendente Lite to coincide with
the conference previously scheduled for spousal support.
Date:O r. /10'1
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Respectfully s bmitteQ(
6-Ji
J s D. Caraciolo, Esquire
108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 90919 Tel. (717) 763-1800
SHANNON DIMM,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No.
JOHN DIMM,
Defendant
: CIVIL ACTION - AT LAW IN DIVORCE
ATTORNEY VERIFICATION
The undersigned, Joseph D. Caraciolo, Esquire, hereby verifies and states that:
1. He is the attorney for the Plaintiff Shannon Dimm;
2. He is authorized to make this verification on her behalf;
3. The facts set forth in the foregoing Petition are known to him and not necessarily to his
client;
4. The facts set forth in the foregoing Petition are true and correct to the best of his
knowledge, information and belief; and
5. He is aware that false statements herein are made subject to the penalties of 18 Pa. C,S.
4904, relating to unsworn falsification to authorities.
DateO {, (f P ;(
7'{,iJ '
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. sepiIJ . Caraciolo, Esquire
108 Market Street, Aztec Building
. Camp Hill, Pennsylvania 17011-4706
ID#90919 Tel. (717)763-1800
SHANNON DIMM,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No.
JOHN DIMM,
Defendant
: CIVIL ACTION - AT LAW IN DIVORCE
CERTIFICATE OF SERVICE
I hereby certify that I am this day serving a copy of the foregoing Petition upon the person
and in the manner indicated below, which service satisfies the requirements of the Pennsylvania
Rules of Civil Procedure, by depositing a copy of the same in the United States Mail, Camp Hill,
Pennsylvania, through first class U.S. Mail, prepaid, and addressed as follows::
John Dimm
420 Candlewyck Road
Camp Hill, PA 17011
Date: 0 4(( klt/ '1
lly su mitted, / -I
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Isep D. Caraciolo, Esquire
~~ Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 90919 Tel. (717) 763-1800
Exhibit A
24. The best interests and permanent welfare of the child will be served by granting the
I relief requested because Plaintiff is in a better position to take care of the child as both mother and
Primary Caregiver for the child's entire life.
25. Each parent whose parental rights to the child has not been terminated and the
person who has physical custody of the child have been named as parties to this action.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order
granting her custody of the child.
COUNT m - REOUEST FOR SPOUSAL SUPPORT AND/OR ALIMONY PENDENTE
LITE ANDALIMONY UNDER lili3701(A) AND 3702 OF THE DIVORCE CODE
26. Paragraphs one (1) through twenty-five (25) are incorporated herein through
reference.
27. Plaintiff is unable to sustain herself during the course of litigation.
28. Plaintiff lacks sufficient property to provide for her reasonable needs and is unable
to sustain herself through appropriate employment.
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29.
Plaintiff requests the Court to enter an award of spousal support and/or alimony
pendente lite until final hearing and thereupon to enter an order of alimony in her favor pursuant to
~~3701(a) and 3702 of the Divorce Code.
WHEREFORE, plaintiff respectfully requests the Court to enter an award of
Exhibit B
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
SHANNON M. DIMM ) Docket Number 00429 S 2004
Plaintiff )
vs. ) PACSES Case Number 156106438
JOHN M. DIMM )
Defendant ) Other State 10 Number
ORDER OF COURT
You,
SHANNON M. DIMM
plaintiff/defendant of
3416 LISBURN RD, MECHANICSBURG, FA. 17055-6714-16
are ordered to appear at CUMBERLAND CO DRS
13 NORTH HANOVER STREET. CARLISLE, PA. 17013
before a conference officer of the Domestic Relations Section, on
JULY 13, 2004
at 8: 30AM for a conference, after which the
conference officer may recommend that an order for support be entered.
You are further required to bring to the conference:
I. a true copy of your most recent Federal Income Tax Return, including W -2s, as filed,
2. your pay stubs for the preceding six (6) months,
3. the Income and Expense Statement attached to this order as required by Rule 1910 .11 (c).
4. verification of child care expenses, and
5. proof of medical coverage which you may have, or may have available to you
6. information relating to professional licenses
7. other:
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SHANNON DIMM
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
04-2772 CIVIL ACTION LAW
JOHN DIMM
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Tuesday, June 22, 2004
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before . Dawn S. Sunday, Esq.
at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, July 15, 2004
, the conciliator,
at 10:00 AM
for a Pre-Hearing Custody Conference. At such conference, an enor[ will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existin!: Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: Isl
Dawn S, Sunday, Esq.
Custody Conciliator
mhc
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilites Act of 1990. For information about accessiblle facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our office.
An arrangements must be made at least 72 hours prior to any hearing or business before the court. You must
attend the scheduled conference or hcaring.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY 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
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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SHANNON M. DlMM,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - mVORCE
JOHN M. DlMM,
Defendant/Respondent
NO. 2004-2772 CIVIL TERM
IN DIVORCE
Pacses# 998106548
ORDER OF COURT
AND NOW, this 13th day of July, 2004, based upon the Court's determination that Petitioner's
monthly net income/earning capacity is $948.50 and Respondent"s monthly net income/earning
capacity is $1,524.66, it is hereby Ordered that the Respondent pay to the Pennsylvania State
Collection and Disbursement Unit, $1 12.00 per month payable bi.-weekly as follows; $51.69 for
alimony pendente lite and $0.00 on arrears. First payment due fi(~xt pay date. Arrears set at $112.00
as of July 13, 2004. The effective date of the order is June 17,2004.
This Order is based upon an agreement of the parties.
Husband is to maintain medical insurance on Wife.
Collection on the retroactive arrears is held in abeyance until September I, 2004 and will then be
payable at $10.00 per month.
This Order considers that Husband is under an obligation of child support for the parites' child under
PACSES C1D#156106438.
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 its discretion make an appropriate Order, including,
but not limited to, commitment of the Respondent to prison for 2l period not to exceed six months.
Said money to be turned over by the P A SCDU to: Shannon M. Dimm. Payments must be made by
check or money order. All checks and money orders must be made payable to P A SCDU and mailed
to:
P A SCDU
P.O. Box 69110
Harrisburg, P A 17106-9 I 10
Payments must include the defendant's P ACSES Member Number or Social Security Number in
order to be processed. Do not send cash by mail.
Unreimbursed medical expenses that exceed $250.00 annually are to be paid as follows: 0% by
Respondent and 100% by Petitioner. The Petitioner is responsible to pay the first $250.00 annually in
unreimbursed medical expenses. Respondent to provide medical insurance coverage. Within thirty
days after the entry of this order, the Respondent6 shall submit to the Petitioner 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: I) the name ofthe h(:alth care coverage provider(s); 2)
any applicable identification numbers; 3) any cards evidencing coverage; 4)the addr4ess 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.
This Order shall become final ten days after the mailing of the notice of the entry of the Order to the
parties unless either party files a written demand with the Prothonotary for a hearing de novo before
the Court.
DRO: R. J. Shadday
Mailed copies on
7-13-04: <
BY THE COURT,
Petitioner
Respondent
Joseph Caraciolo, Esquire
Michael Travis, Esquire
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No.
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Date of Application:
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CUl\;mERLAND COUNTY DOMESTIC RELATIONS
''J-,~fl-(}'-{ Request for SUpport Record Search
Name: -01 YY\ YY'I :::r () h (\ .
(Last) AFirst) ~I)
Address: 4(},o (anr.\LRw'{d::. K-014o l""",-, \-1.'\\ \ A 17011
Social Security Number: /7/ _ €I 8 -- c., 3 t D.O.B.:
Domestic Relations Case Number if Known: ISu /614l./3Si- f'tC\r! 9q~ /Olp,s,-Vi:-
Party Requesting Information: Her;\-o,O' s c>.\.\-t. ""'. ,,,+. Sen/', ("0" LL C.
(Print Name of Firm Name) .
117- ')30 -9/" c,<(
(Telephone Number)
'1/7 -- 7.~ -- C(1"fA,\
(Fax Number)
470S- e --rr,'N11o ~)oc1 J T1koho.f\iCSb\l'O?f+
(Address)
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(Signature)
17 O.sv
A Twenty Dollar ($20.00) Fee is Due per Social Sf,curity Number
Make check or money order payable to: DRS/Lien Search
X INITIAL REQUEST
Has no Record in Domestic Relations as of:
(Date)
Support Arrears as of End of Month Prior to Date of Application: $ 1/:;;'.00
Monthly Total Support Obligation: $ lid... 00 J mn(\~
,
The Amount shown above is reflected in the Domestic Relations Section Office of
Cumberland County, Pennsylvania.
()Jemb.u- ~ 5.:2'lfc/O/33 0
PQCst,S ~ (jq'i?IOlPS;l.j~
Domestic Relations Case Number:
Signed:
ctl1 7h J5~
(Lien Search Coordmator)
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(Date)
BRING-DOWN REQUEST
Support Arrears: $
As Of:
(Date)
Signed:
(Lien Coordinator)
(Date)
*** Lien Satisfisfaction Receipt Available Upon Request***
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
SHANNON M. DIMM ) Docket Nwnber 04-2772 CIVIL
Plaintiff )
VS. ) PACSES Case Nwnber 998106548
JOHN M. DIMM )
Defendant ) Other State 10 Number
ORDER
AND NOW, to wit, on this
1ST DAY OF SEPTEMBEFc, 2004
IT IS HEREBY
ORDERED that the support order in this case be 0 Vacated or <Xl Suspended or
o Terminated without prejudice or 0 Terminated and Vacated,
effective AUGUST 16, 2004 , due to:
THE PLAINTIFF'S REQUEST TO SUSPEND THE ALIMONY PENlJENTE LITE PURSUANT TO THE
PARTIES RECONCILING. THERE IS NO BALANCE DUE THE PLAINTIFF.
DRO: RJ Shadday
xc: plaintiff
defendant
Joseph earaciolo, Esquire
Michael Travis, Esquire
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Worker 10 21005
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
E mployerlWithhofder's Federal EIN Number
State Commonwealth of Penll!ivlvani'l
Co.ICity/Dist. of CUMBERLAND
Date of Order/Notice 09/01/04
Tribunal/Case Number (See Addendum for case summary)
RE: DIMM, JOHN M.
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/it!$[$ 978/~S97'
o Original Order/Notice
o Amended Order/Notice
(8) Terminate Order/Notice
Employee/Obligor's Name (Last, First, Mil
171-68-6386
Employee/Obligor's Social Security Number
5296101330
Employee/Obligor's Case Identifier
(See Addendum for plaintiff ""1IIe_
associated with cases on attachment)
Custodial Parent's Name (last, First MI)
BCA EMPLOYEE MANAGMENT
71 7 MARKET ST
LEMOYNE PA 17043-1581
GROUP
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See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND 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.
$ 0 . 00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes <Xl no
$ 0.00 per month in medical support
$ 0.00 per month for genetic test costs
$ per month in other (specify)
tor a total of $ 0.00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 0.00 per weekly pay period.
$ 0.00 per biweekly pay period (every two weeks),
$ 0.00 per semimonthly pay period (twice a month).
$ o. oQ 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 goveming 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 #10 on pg. 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INClUDE THE DEFENDANT'S NAME AND TH.f PACSES MEMBER 10 (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBE~~ IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
Date of Order:
SEP - 2 200t
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Form E N- 28
Worker 10 $IATT
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Service Type M
OMB No.: 0970-0154
ADDITIONAL INFORMATION TO EMPLOYERS AND .oTHER WITHHOLDERS
o If ,hecked you are required to provide a copy of this form to your employee. If yo~r employee vvorks in a state that is
different from the state that issued this order, a copy must be provided to your employee even if the box is not checked.
1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribatlly-owned businesses, and Indian-owned
businesses located on a reservation that choose to withhold in accordance with this notice.
2. Priority: Withhold ing under this Order/Notice has priority over any other legal process under Stale 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.
J. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is affributable to each
employee/obligor.
4. *-Reporting-the-raydl.t~IDate of 'Nithltfild;ug. VOl., f1IU!t report tin... payd8te'datf uf y"ithholdil.& ""Len sel,d;',g ti,l. (.laYlllo.-'it. Ti,e
p(l.ydateJdate-ofu;ll,I,old;lIgi'S"the datf vI. nllkl. An10uht vva& n;t1,I,~ld hulllll,e enlployee's ""Age:;" 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.
5,' Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law of the state of employee's1obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #1 0 belowl
6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you,
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
WITHHOLDER'S 10: 5423100185
EMPLOYEE'S/OBLlGOR'S NAME: DIMM , JOHN M.
EMPLOYEE'S CASE IDENTIFIER: 5296101330 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
7. l.ump 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.
8. liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld lrom 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.
9. Anti-<liscrimination: You are subject to a line determined under State law for discharging an employee/obligor from employment,
relusing to employ, or taking disciplinary action against any employee/obligor because Oil 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 governs.
10.' Withholding limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.s.c. ~1673 (bll; or 21 the amounts allowed by the State of the employee's1obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxesj Social Security taxesj and Medicare taxes.
11. Additionallofo:
'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 respect to these items.
Submitted By: If you or your employee/obligor have any questions,
DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT
13 N. HANOVER ST by telephone at (717) 240-6225 or
P.O. BOX 320 by FAX at lZ1ZL240-6248 or
CARLISLE PA 17013 by internet www.childsupport.state.pa.us
Service Type M
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LIEN SATISFACTION
Name: John Dimm
Social Security Number: 171-68-6386
Judgment Lien Satisfied as of: 08/31/04
Amount Paid: $ 112.00
Signed: ~J~ VI ~
(Lien Coordinator)
]~acses# 998106548
No. 04-2772 CV
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JAN 0 6 2005
(Date)
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
SHANNON DIMM, )
Plaintiff, )
vs. ) No. 04-2772
)
JOHN DIMM, ) CIVIL TERM
Defendant. ) IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on June 17,
2004.
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.
DATED: 7 - /:5 -C1't
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Hampden I\-..p., O"fiberla:ld CO;J<liy
My ~m~~~ E;.':~.:> At:x._:~~~_(:1{.~_"..
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
SHANNON DIMM, )
Plaintiff, )
vs. ) No. 04-2772
)
JOHN DIMM, ) CIVIL TERM
Defendant. ) IN DIVORCE
AFFIDAVIT OF CONSENT
I. A complaint in divorce under !}3301(c) of the Divorce Code was filed on June 17,
2004.
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.
DATED: ;< ~ If -0(,
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
SHANNON DIMM, )
Plaintiff, )
vs. ) No. 04-2772
)
JOHN DIMM, ) CIVIL TERM
Defendant. ) IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF
A DIVORCE DECREE UNDER & 3301(c) OF THE DIVORCE CODE
I. 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! 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.
Date: 2. - L') :Xr
1/1 .-1 rJ
hannon Dimm, Plaintiff
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
Defendant.
)
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No. 04-2772
CIVIL TERM
IN DIVORCE
SHANNON DlMM,
Plaintiff,
vs.
JOHN DIMM,
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER & 330Hc) OF THE DIVORCE CODE
I. 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! 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.
Date:d:' -/J~-OC
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
)
)
) No. 04-2772 Civil Term
)
)
) CIVIL ACTION - AT LAW IN DIVORCE
SHANNON DIMM,
vs.
JOHN DIMM,
Defendant
ACCEPTANCE OF SERVICE
I accept service ofthe complaint in the divorce. A copy of the complaint was received
on June 18,2004.
n Dimm, Defendant
420 Candlewyck Road
Camp Hill, PA 1701 I
Date: February 15,2006
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Michael S. Travis
IV No. 77399
3904 Trindle Road
Camp Hill, PA 17011
(717)731-9502
SHANNON DlMM,
Plaintiff,
In tbe Court of Common Pleas of Cumberland County,
Pennsylvania
)
)
)
)
)
)
No. 04-2772
vs.
Defendant.
CIVIL TERM
IN DIVORCE
JOHN DIMM,
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court for entry of a
divorce decree:
I. Ground for divorce: irretrievable breakdown under !}3301(c)(I) of the Divorce
Code.
2. Date and manner of service of the complaint: Complaint was accepted by
Defendant on June 18, 2004, Acceptance of Service, filed on February 15, 2006.
3. Date of execution of the affidavit of consent required by !} 3301(c) of the Divorce
Code: by Plaintiff on February 13,2006; by Defendant on February 15,2006.
4.
Related claims pending: No claims were raised.
5.
prothonotary:
Waiver of Notice in !}3301(c) Divorce was filed with the
,2006.
prothonotary:
Date /ifendant's Waiver of Notice in !}3301(C).-..
J: -5 , 2006. .:? .
ce was filed with the
Mic ael S. Travis
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
SHANNON DIMM,
PENNA.
STATE OF
No.
2004-2772
Plaintiff,
VERSUS
JOHN flIMM,
Defendant.
DECREE IN
DIVORCE
NOW,~1MJ~
2-Z-
~, IT IS ORDERED AND
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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AND
DECREED THAT
Shannon Dimm
, PLAINTIFF,
AND
John Dimm
, DEFENDANT,
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
None.
~/
/ ~//?
BnCq:~/
ATTEST;
J.
.
ROTHONOTARY
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