Loading...
HomeMy WebLinkAbout02-0207LESLIE A. STONER, Plaintiff V. JEFFREY A. STAMPER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 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 of other rights important to you, including the 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 at the Office of the Prothonotary. 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, PA 17013 717-249-3166 LESLIE A. STONER, Plaintiff V. JEFFREY A. STAMPER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA · NO. O& - ~O'7 ~___.l'~,.x : : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the Plaintiff, Leslie A. Stoner, by and through her attorney, Charles Rector, Esquire, and respectfully represents as follows: 1. Plaintiff is Leslie A. Stoner (SS# 186-58-1417), an adult individual, currently residing at 706 Somerset Ddve, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant is Jeffrey S. Stamper (SS~ 277-80-4647), an adult individual, currently residing in Maine. His last known mailing address is Life Flight of Maine, Central Maine Medical Center, 300 Main Street, Lewiston, Maine, 04240. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for a period of six months (6) immediately preceding the filing of the Complaint. 5. the parties. 6. Plaintiff and Defendant were marded on June 13, 1996, in Tennessee. There have been no pdor actions for divorce or for annulment between The Plaintiff and Defendant are both citizens of the United States of Amedca. Count I - Divorce 7. The allegations of Paragraphs 1 through 6 are incorporated herein by reference and made a part hereof. 8. This action is not brought through collusion between the Plaintiff and Defendant, but in sincerity and truth for the reasons set forth within. 9. The marriage is irretrievably broken, and the parties are proceeding under Section 3301(c) of the Divorce Code. In the alternative, Defendant has offered such indignities to Plaintiff, the innocent and injured spouse, as to render her condition intolerable and her life burdensome. 10. 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. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce decree dissolving the marriage between Plaintiff and Defendant. Count II - Equitable Distribution 11. Paragraphs I through 10 of this Complaint are incorporated herein by reference as if set forth at length. 12. The parties have acquired, during the course of the marriage and prior to separation, property, both real and personal, which they own jointly or which was otherwise purchased so as to constitute madtal property within the definition and scope of Section 3502 of the Divorce Code. WHEREFORE, Plaintiff requests your Honorable Court to enter an Order distributing the marital property owned by the parties. Date: RESPECTFULLY SUBMITTED, Charles Rector, Esquire 1104 Femwood Avenue, Ste. 203 Camp Hill, PA 17011 (717) 761-8101 I verify that the statements made herein 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 unswom falsification to authorities. ~'y Kristin L. Dixon LESLIE A. STONER, Petitioner/Plaintiff JEFFREY A. STAMPER, Respondent/Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-207 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE PETITION FOR JOINDER OF RELATED CLAIMS AND NOW comes the Petitioner/Plaintiff, Leslie A. Stoner, by and through her attorney, Charles Rector, Esquire, and respectfully represents as follows in support of the within Petition: On January 15, 2002, Petitioner filed the above-captioned action in divorce. 2. distribution. 3. Petitioner previously raised the claims of divorce and equitable Petitioner now raises the related claim of spousal support and alimony pendente lite, and permanent alimony because she is unable to sustain herself during the course of this litigation. 4. Petitioner lacks sufficient property to provide for her reasonable needs and is unable to sustain herself adequately through appropriate employment. 5. Petitioner requests this Honorable Court to enter an award of spousal support and/or alimony pendente lite in her favor pursuant to Section 3701 of the Divorce Code. WHEREFORE, Petitioner respectfully requests Your Honorable Court to grant the requested relief retroactive to the date of the filing of this~------- RESPECTFULLY SUBMITI~, Char~r es Re~( tor~ E~qui're'~ 1104 Femwood A~enue, Ste. 203 Camp Hill, PA 17011 (717) 761-8101 /~-~/o Attomey for Plaintiff Date: I vedfy that the statements made herein 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. ,:./,,,/": x?'2. ~,,,;,;:,... _ Le~li~ A. StoBer ~ ~"~' ~' ~ Date: ~ ';~/~~ LESLIE A. STONER, Plaivfiff/Petitioner VS. JEFFREY A. STAMPER, Defendant/Respondent IN TUI~. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - DIVORCE : NO. 2002-207 CIVIL TERM IN DIVORCE DI~ 31896 Pacse~ 739104684 ORDER OF COURT AND NOW, this day of, 2001, upon consideration of the attached Petition for Alimony Pendente Lite and/ur co-n~el fees, it is hereby directed that the parties and their respective counsel appear before ~ on September St 2002 at 900 A.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 thc confcrence: (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 Rule 1910.11© (4) ver/ficalion of ch/Id 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. Mail copies on 8-15-02 to: Petitioner Respondent Charles Rector, Esquire Stanley Laskowski, Esquire BY THE COURT, George E. Hoffer, President Judge Date of Order: August 15, 2002 R. ~m y, erence Officer YOU HAVE THY. 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 THF. OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HF~LP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 LESLIE A. STONER, : Plaintiff/Petitioner : VS. : JEFFREY A. STAMPER, : Dcf~ndnnt/Respondent : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 2002-207 CIVIL TERM IN DIVORCE DR# 31896 Pacses# 739104684 ORDER OF COURT AND NOW, this 3'd day of September, 2002, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $1,641.40 and Respondent's monthly net income/earning capacity is $2,882.00, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $469.00 per month payable monthly as follows; $469.00 for alimony pendente lite and $0.00 on arrears. First payment due on next pay date. Arrears set at $469.00 as of September 3, 2002. The effective date of the order is September 3, 2002. 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 a period not to exceed six months. Said money to be turned over by the PA SCDU to: Leslie A. Stoner. Payments must be made by check or money order. All checks and money orders must be made payable to PA SCDU and mailed to: PA SCDU P.O. Box 69110 Harrisburg, PA 17106-9110 Payments must include the defendant's PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. Unreimbursed medical expenses that exceed $250.00 annually are to be paid 0% by the 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 (30) days after the entry of this order, the 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. 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 heating de novo before the Court. DRO: R. J. Shadday Mailed copies on 9-4-02 to: < Petitioner Respondent Charles Rector, Esquire Stanley Laskowski, Esquire BY THE COURT, Edward E. ~ Guido ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania /~, Co./City/Dist. of CUMBERLAND- ~:~/'~' Date of Order/Notice 09/03/02 Court/Case Number (See Addendum for case summary) EmployerANithholder's Federal EIN Number KEYSTONE HELICOPTER CORPORATIO F m ploye rA, Vit h holder's Name C/O ANITA HAMILTON E mployerANithholder's Address 1420 PHOENTXVTT,TJ]~ PTKE WEST (~T4W.~TER PA 19380-1438 (~ Original Order/Notice C) Amended Order/Notice C) Terminate Order/Notice RE: STAbIPER, JEFFREY S. Employee/Obligor's Name (Last, First, MI) 277-80-4647 Employee/Obligor's Social Security Number ~610101016 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 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. $ 469. oo per month in current support $ o. oo per month in past-due support Arrears 12 weeks or greater? C)yes (~) no $ o. 00 per month in medical support $ 0. oo per month for genetic test costs $ per month in other (specify) for a total of $ 469.00 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: $ 108.23 per weekly pay period. $ 216.46 per biweekly pay period (every two weeks). $ 234.50 per semimonthly pay period (twice a month). $ 469.00 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 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 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, 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 MAIL. BY THE COURT: Date of Order: $£P ~~ ~ t~ Form EN-028 Worker ID STATT Service Type M ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS [] If checked you are required to provide a copy of this form to your employee. 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 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. .............. ' .............................................................................. ply ithth I fth 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 mom 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'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/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 ID: 2315965500 EMPLOYEE'S/OBLIGOR'S NAME: STAMP~.R, J~--FFR~-¥ B. EMPLOYEE'S CASE IDENTIFIER: 46:1.02.0:1.0:1.6 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: 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/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. 9.* Withholding Limits: You may not withhold mom than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. § 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 taxes; Social Security taxes; and Medicare taxes. 10. *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. Requesting Agency: DOMESTIC RELATIONS 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 (717) 240-6225 by FAX at (717) 240-6248 or by Internet @ or Service Type M Page 2 of 2 OMB NO.: 0970-0154 Expiralion Date: 12/31/00 Form EN-028 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: STAMPER, JEFFREY S. PACSES Case Number 739104684 /~'/&~'~, Plaintiff Name /-- Plaintiff Name LESLIE A. STONER Docket Attachment Amount 02-207 CIVIL $ 469.00 Child(ren)'s Name(s): DOB [] If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Docket Attachment Amount $ o.oo Child(ren)'s Name(s): DOB [] If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB [] If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ o.oo Chi[d(ren)'s Name(s): DOB [] If checked, you are required to enroll the child(ten) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ o.oo Child(ren)'s Name(s): DOB [] If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaiqtiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB [] If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment, Service Type M Addendum OMB NO,: 0970-0154 Expiration Date: 12/31/00 Form EN-028 Worker ID $IATT LESLIE A. STONER, Plaintiff, VS. JEFFREY A. STAMPER, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-207 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in Divorce under Section 3301(c) o1: the Divorce Code was filed on January 15, 2002. 2. Defendant acknowledges that a copy of the Complaint was served January 28, 2002. 3. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed, both from the date of the filing of the Complaint, and from the service of the Complaint. 4. I consent to the entry of a final Decree of Divorce without notice. 5. 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. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. 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. Dated: /Je~fre¢,~': S~5,pefenda, nt 63072 ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co.~City~Dist. of CUMBERLAATD Date of Order/Notice 10/14/03 Tribunal/Case Number (See Addendum for case summary) C) Origina{ Order/Notice Q~) Amended Order/Notice C) Terminate Order/Notice EmployerANithholder's Federal EIN Number KEYSTONE HELICOPTER CORPORATIO C/O ANITA HAMILTON 1420 PHOENIXVILLE PIKE WEST CHESTER PA 19380-1438 RE: STAMPER, CrEFFREY S. Employee/Obligor's Name (Last, First, 277-80-4647 Employee/Obligor's Social Security Nur~ber 4610101016 Fmployee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) ~,~. c.~,2~ -~q ~'~/~//'-- Custodial Parent's Name (Last, First, MI) See Addendum for dependent names and birth dates associab?d with cases on attachment. ORDER INFORMATION: 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 the~ 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 $ 108.23 per month in past-due support Arrears 12 weeks or greater? (~)yes O no $ o. oo per month in medical support $ 0. oo per month for genetic test costs $ per month in other (specify) for a total of $ 108.23 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the suppoFt order. If your pay cycle does not matt the ordered support payment cycle, use the following to determine how much to withhold: $ 24.98 per weekly pay period. $ 49.95 per biweekly pay period (every two weeks). $ 54.12 per semimonthly pay period (twice a month). $ 108.23 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 needed (See #10 on pg. 2). If remitting by EFT/EDb 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 THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSE£ DO NOT SEND CASH BY MAIL. Date of Order: ~.,~ "J'- Service Type N BY THE COURT: OMB NO,: 09704)154 ¢'(~~/~,~.. ,~ ;~-g,Z)ff~ t / ~ '~ FormEN-028 Worker D $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS [] If checked you are required to provide a copy of this form to youremoloyee. 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 underthis Order/Noticehas priority over any other legal process underState lawagainstthe same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal lax 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 tg each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to, ~ach employee/obligor. 4 .... h, ...... . ...... ¥ ......................... .. ',,% ......... ~.-., ,h,~ ~,~¥d~=,~/d ~,.ydoL~,~ .... f .,thh.4d...~ ,. Lh~ d ........ h,..h .................hh~Id .......... ~,,,[,,~,y~- state of the employee's/obligor's principal place of employment with respect to the time periods wKhin which you must implement 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 agai~ this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must 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 Please provide the information requested and tatum a copy of this Order/Notice to the Agency identified below. WlTHHOLDER'S ID: 2315965500 EMPLOYEE'S/OBLIGOR'S NAME: STAMPER, JEFFREY S. EMPLOYEE'S CASE IDENTIFIER: ~6].010z0].6 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS:. NEW EMPLOYER'S NAME/ADDRESS: 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 should withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs un 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-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/obligor because of a support withholding. Pennsylvania State I governs un less 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 (b)l; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employme The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandator deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 11. Addilional 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 th law of the state that issued this order with respect to these items. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE A~I-ACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us fthe )W ve It. Service Type Page 2 of 2 OMBNo.:0970~154 Form EN-028 [ Worker ID $IA~T ADDENDUM Summary of Cases on Attachment Defendant/Obligor: ST.~IPER, JEFFREY S. PACSES Case Number 739104684 Plaintiff Name LESLIE A. STONER Docket Attachment Amount 02-207 CIVIL $ 108.23 Child(ren)'s Name(s): DOB [] If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB I-hf checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ o.oo Child(ren)'s Name(s): DOB [] if checked, you am required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.o0 Child(ren)'s Name(s): D~OB I-Jif checked, you are required to enroll the child(ren) identified above in any health insurance coverage availabl through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.o0 Child(ren)'s Name(s): D )B [] If checked, you are required to enroll the child(ren) identified above in any health insurance coverage availabl~ through the employee's/obligor's employment. PACSES Case Number Plaintiff Name. Docket Attachment Amount $ 0.o0 Child(ren)'s Name(s): D( ~B [] If checked, you are required to enroll the child(ren) identified above in any health ~nsurance coverage availab through the employee's/obligor's employment, Service Type M Addendum OMB No; 0970-0154 Form EN-028 Worker ID In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION LESLIE A. STONER Plaintiff vs. JEFFREY S. STAMPER Defendant ) Docket Number ) ) PACSES Case Number ) ) Other State ID Number 02-207 CIVIL 739104684 ORDER AND NOW, to wit, on this 14TH DAY OF OCTOBER, 2003 IT IS HEREBY ORDERED that the support order in this case be C) Vacated or C) Suspended or ~) Terminated without prejudice or C) Terminated and Vacated, effective OCTOBER 3 , 2003 , due to: THE PARTIES' PROPERTY SETTLEMENT AGREEMENT OF OCTOBER 3, 2003. THERE IS A REMAINING BAiG%NCE OF $144.35 THAT IS TO BE PAID OFF' WITH THE CURRENT WAGE ATTACHMENT, DRO: RJ Shadday ~c:: plaintiff dsf~ndant Charl6s R6ctor, Esquir6 Stanley Laskowski, Es~Hr~ BY THE COURT: Edward E. Guido JUDGE Form OE-504 Service Type M Worker ID 21005 JAMES R. CLIPPINGER CHARLES J D£HART. III JAt~ES D. CAMPBELL. JR. JAMES L. GOLDSMITH JEFFREY T. MCGUIRE' STANLEY J. A. LASKOWSKI DOUGLAS K. F4^RSICO BRETT M. WOOl)BURN RAY J. MICHALOWSKI 'AL~O A MEMBER OF NJ BAR CALDWELL ~ KEARNS A PROFESSIONAL CORPORATION ATTORNEYS AT LAW 3631 NORTH FRONT STREET HARRISBURG. PENNSYLVANIA 17110-1533 October 8, 2003 R. J. Shadday, Conference Officer Cumberland County Domestic Relations Section 13 North Hanover Street P. O. Box 320 Carlisle, PA 17013 RE: Leslie A. Stoner v. Jeffrey A. Stamper Cumberland County DR No. 31896 PACSES No. 739104 684 Dear Ms. Shadday: OF COUNSEL RICHARD L. KEARNS CARL G. WASS I Please be advised that the parties in the above-referenced matter are proceeding to conclude the divorce and have executed a Property Settlement Agreement. This Property Settlement Agreement provides that the above-referenced support action shall terminate effective upon execution of the Agreement. Please find enclosed a copy of the relevant portions of the Agreement pertaining to the termination of this action. It is my understanding that payroll deductions may continue to the extent that arrearages, if any, remain to be paid. Also as you will kindly note from the enclosed Agreement, there is an error with the spelling of Mr. Stamper's name. His middle initial should be corrected to read as follows: Jeffrey S. Stamper. If there is any additional information that you will require to terminate the pending Support Order, please feel free to contact me. SJAL:se encs. cc: Charles Rector, Esquire Jeffrey S. Stamper 02229/63368 VeryJ;~ly yours, z3 . Stanley J. A~askowski CALDWELL & KEARNS thefirm~caldwellkearns.~ om PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, dated the 5''''1' day of ~c.4.-~ ,2003, by and between JEFFREY~)ffSTAMPER, c/o Life Flight, 300 Main Street, Lewiston, Maine 04240, Social Security No. 277-80-4647, hereinafter called the "HUSBAND", and LESLIE A. STONER, 706 Somerset Drive, Mechanicsburg, Pennsylvania 17055, Social Security No. 186-58-1417, hereinafter called the "WIFE", who agree as follows: WITNESSETH: WHEREAS, the parties are Husband and Wife, having been married on June 13, 1996; WHEREAS, diverse, unhappy and irreconcilable differences, disputes and difficulties have arisen between the parties, and it is the intention of Wife and Husband to live separate and the parties desire to enter into an Agreement settling fully and finally their ;respective financial and property rights and obligations as between each other including, without limitation: ownership and equitable distribution of real and personal property; past, present and future support, alimony and/or maintenance of Wife by Husband or o f Husband by Wi re; and any and all claims and possible claims by one against the other or against their respective estates; and NOW THEREFORE, in consideration of the promises 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, mutually agree as follows: a distribution in the sum of $5,500.00 and Husband acknowledge,,; that he has received a distribution from said sale of $500.00. 18. REVOCATION OF POWER OF ATTORNEY XXXXnXXXXXXXXX~XXXXXXX_ Husband executed a Power of Attorney appointing Wife as Husband's attorney-in-fact. Effective immediately upon execution of this Agreement individually by Husband, without any need of joinder, consent or execution in this Agreement by Wife whatsoever, Husband hereby revokes and makes void said Power of Attorney igdii~ti~XXXXXXXXX7s xxxxx× and further revokes and makes void for any and all purposes all powers and authorities therein and thereby given to Wife. Wife upon and by her execution of this Agreement expressly acknowledges the full and complete revocation of Husband's Power of Attorney and also warrants and represents that since the separation she has not and in the future will not act upon or exercise any powers or authority provided therein for any and all purposes. 19. WAIVER OF SPOUSAL SUPPORT, ALIMONY PENDENTE LITE, AND ALIMONY Wife and Husband do hereby waive, release and give up any rights they may respectively have against the other for alimony, alimony pendente lite, support or other maintenance. It shall be from the date of this agreement the sole responsibility of each of the respective parties to sustain themselves without seeking any support from the other party. Wife has initiated against Husband legal or other action for or pertaining to support or maintenance, such as spousal support, alimony or alimony pendente lite, at Cumberland County No. 2002-207, D.R. No. 31896, PACSES No. 739104684, and said action, including but not limited to any Order of Court for alimony pendente lite, shall be deemed withdrawn and be terminated for all purposes effective immediately upon execution of this Agreement. 11 29. HEADING 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 IN WITNESS WHEREOF, the parties hereto have set their hands and seals they day and year first written above. WITNESS: Leslie A. Stoner Jeffrey,~. Stamper 5', 42787 14 COMMONWEALTH OF COUNTY OF On this, the ~ 3 day of ~)c -/',/~ ~, 2003, before me, a Notary Public, the undersigned officer, personally appeared Jeffrey ,A( Stamper, known to me to be the person whose name is subscribed to the within Property Settlement Agreement, and acknowledged that he executed the same for the purposes therein contained. SHANE J. SOIETr Notary Public, Maine My Commlssbn Expires Ju~y 11,201 COMMONWEALTH OF PENNSYLVANIA : COUNTY OF CLty~c a~ : On this, the \ ~.~k. day of c"~}-.%~-F~, 2003, before me, a Notary Public, the undersigned officer, personally appeared Leslie A. Stoner, known to me to be the person whose name is subscribed to the within Property Settlement Agreement, and acknowledged that she executed the same for the purposes therein contained. 42787 Not~t~yVPublic~// . v, NOTARIAL SEAL TAMMY S. FAUST, Notary Public Lower Allen Twp., Cumberland County My Commission Expires July 5, 2006 PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, dated the ~t. day of ~c~o ~'cf ,2003, by and between JEFFREY,. STAMPER, c/o Life Flight, 300 Main Street, Lewiston, Maine 04240, Social Security No. 277-80-4647, hereinafter called the "HUSBAND", and LEoLIE A. STONER, 706 Somerset Drive, Mechanicsburg, Pennsylvania 17055, Social Security No. 186-58-1417, hereinafter called the "WIFE", who agree as follows: WITNESSETH: WHEREAS, the parties are Husband and Wife, having been married on June 13, 1996; WHEREAS, diverse, unhappy and irreconcilable differertces, disputes and difficulties have arisen between the parties, and it is the intention of Wife and Husband to live separate and the parties desire to enter into an Agreement settling fully and finally their respective financial and property rights and obligations as between each other including, without limitation: ownership and equitable distribution of real and personal property; past, present and future support, alimony and/or maintenance of Wife by Husband or of Husband by Wife; and any and all claims and possible claims by one against the other or against their respective estates; and NOW THEREFORE, in consideration of the promises 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, mutually agree as follows: 1. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS This Agreement shall not be considered to affect or bar the right of Wife or Husband to a limited or absolute divorce on lawful grounds if such grounds nc,w exist or shall hereafter exist or to such defense as maybe available to either party. This Agreement is not intended to condone and shall not be deemed to condone any act(s) of the other party which have occasioned the disputes or unhappy differences whether occurring prior or subsequent to the ,date of this Agreement. An action in divorce has been initiated between the parties at Cumberland County Court of Common Pleas No. 02-207 Civil Term. The parties intend and agree to secure a mutual consent, no-fanlt divorce pursuant to the terms of Section 3301 (c) of the Divorce Code. 2. EFFECT OF DECREE, NO MERGER The provisions of this Agreement relating to the equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever. Should either of the parties obtain a decree, judgment, or order of separation or divorce in any state, country, or jurisdiction, each of thc parties to this Agreement hereby consents and agrees that this Agreement and all of its covenants shall not be affected in any way by any snch separation or divorce; and that nothing in any such decree, judgment, order or further modification or revision thereof shall alter, amend or vary any term of this Agreement, whether or not either or both of the parties should remarry, it being understood by and between the parties that this Agreement shall survive and shall not be merged into any decree, judgment, or order of divorce or separation. The parties agree that the terms of this Agreement may be incorporated into any divome decree which may be entered with respect to them for purposes of enforcement only of any provisions therein, but shall survive such decree. 2 3. DISTRIBUTION DATE The transfer of property, funds and/or documents provided for herein shall take place simultaneously with the execution of this Agreement. 4. ADVICE OF COUNSEL The parties acknowledge that they have had the opportunity to receive and have received independent legal advice from counsel of their selection at their sole discretion and that they fully understand the facts and have been fully informed as to their legal rights and obligations, and they acknowledge and accept that this Agreement is, in the circumstm~ces, fair and equitable and that it is being entered into freely and voluntarily, after having received such advice and with such knowledge and that the execution of this Agreement is not t?te result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreements. 5. FINANCIAL DISCLOSURE Husband and Wife represent and agree that they have made a full and complete disclosure to the other of all information of financial nature requested by the other, and that no information of such nature has been subject to distortion or in any manner misrepresented. Each party acknowledges that they have been informed they may have the right, as provided by statute and Pennsylvania Rules of Civil Procedure, to obtain information regarding the parties' finances. Such information would include, without limitation, their present and past income; and the identity and value of assets both presently owned and transferred previously. 6. FILING INVENTORIES AND APPRAISEMENT The parties further acknowledge their understanding that they each have the right to file Inventories and Appraisement with the Court and to require the other party to do so. Such Inventories and Appraisement require a party to indicate, under oath, information regarding all marital property in which either party has an interest as of the ,:late the action was commenced. Husband and Wife vohmtafily and intelligently agree to waive m~y rights which they may have to receive an inventory and appraisement of all property owned by them jointly or individually, at the time of delivery of this Agreement or of the commencement of any action in divorce. 7. TAX LIABILITY The parties believe and agree, and have been so advised, each at their sole discretion by their attorneys that the division of property made by this Agreement is a non-taxable division of property between co-owners rather than a taxable sale or exchange of property. Each party promises not to take any position with respect to the property assigned to him or her or which is inconsistent with this position on his or her federal, state or local income tax returns. 8. PERSONAL RIGHTS Wife and Husband may and shall, at all times hereafter, hve separate and apart. They shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if they were unmarried. They may reside at such place or places as they may select. 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. Husband and Wife shall not molest or interfere with each other, nor shall either of them attempt to compel the other to cohabit or dwell with her or him, by any means whatsoe, ver, nor in any way interfere with the peaceful existence, separate and apart from the other. Neither party shall harass or be verbally or physically abusive to the other. 4 9. MUTUAL RELEASES Husband and Wife each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and interest, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or courtesy, or claims in the nature of dower or courtesy or widow's or widower'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 (a) Pennsylvania, (b) any State, Commonwealth or territory of the United States, or (c) any other country, or any rights which either party may have or at any time hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, equitable distribution, costs or expenses, whether arising as a result of the marital relation or otherwise, except, and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof. It is the intention of Husband and wife to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof. 5 10. EQUITABLE DISTRIBUTION OF PROPERTY It is specifically understood and agreed that this Agreement constitutes an equitable distribution of property, both real and personal, which was legally and beneficially acquired by Husband and Wife or either of them during the marriage, as contemplated by The Act of April 2, 1980 (P.L. 63, No. 26) known as "The Divorce Code," 23 P.S. 3101 et. seq. of the Commonwealth of Pennsylvania. And further, that the parties have attempted to divide tl~teir marital property in a manner which conforms to the criteria set forth in 3502 of the Pennsylvania Divorce Code, and taking into account the following considerations: the length of the marriage, the prior marriages, if any, of the parties; the age, the health, station, amount and sources of income, vocational skills, employability, estate, liabilities and needs of each of the parties; the contribution of one party to the education, training, or increased earning power of the other party; the opportunity of each party for future acquisition of capital assets and income; the sources of income of both parties, including but not limited to medical, retirement, insurance or other benefits; the contribution or dissipation of each party in the acquisition, preservation, depreciation, or appreciation of marital property, including the contribution of a party as a homemaker; the value of the property set apart to each party; the standard of living of the parties established during the maniage; and the economic circumstances of each party at the time the division of property is to become effective. 11. DISTRIBUTION OF PERSONAL PROPERTY The parties hereto have divided between themselves, to their mutual satisfaction, all items of tangible and intangible marital property, including but not limited to bank accounts, household goods, furniture and furnishings. Neither party shall make an5' claim to any such other items of 6 marital property, or of the separate personal property of either pray, which are now in the possession and/or under the control of the other. Should it become necessary, the parties each agree to sign, upon request, any titles or documents necessary to give effect to this paragraph. Property shall be deemed to be in the possession or under the control of either party if, in the case of tangible personal property, the item is physically in the possession or control of the party at the time of the signing of this Agreement and, in the case of intangible personal property, if any physical or written certificate of insurance or other similar writing is in the possession or control of the party. Each of the parties, subject to the terms hereof, hereby specifically waives, releases, renounces and forever abandons any claim which he or she may ?rave with respect to those items of personal property hereby assigned to the other, which such items shall hereafter be the sole and exclusive property of the other. From and after the date of the signing of this Agreement both parties shall have complete freedom of disposition as to their separate property and any property which is in their possession or control pursuant to this Agreement, and may mortgage, sell, grant, convey, or otherwise encumber or dispose of such property, whether real or personal, whether such property was acquired before, during or after marriage, and neither Husband nor Wife need join in, consent to, or acknowledge any deed, mortgage, or other instrument of the other pertaining to such disposition of property. Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of personal property, tangible and intangible, subsequently acquired by a party. VEHICLES Distribution of personal property hereunder is deemed to include the motor vehicles previously owned or leased by the parties, and any substitutions and replacements thereof. It is agreed that the 2000 Yamaha TTR 125 motorcycle and 1997 Honda Passport, together with all right, 7 title and interest therein, shall become and remain the sole and exclusive property of Wife. Furthermore, it is agreed that the 1997 Nissan track, subject to the Members 1 st Federal Credit Union lien, together with all right, title and interest therein, shall become and remain the sole and exclusive property of Husband. Each of the parties agrees to assume, indemnify and hold respectively the other harmless from any and all liability for any and all liens,, encumbrances, lease and other obligations with respect to such vehicles retained by each party, as well as be responsible for any and all maintenance, taxes and insurance with respect to their vehicles. JOINT BANK ACCOUNTS Distribution of personal property hereunder is deemed to include the parties' joint checking and savings accounts to No. 100168509 at Waypoint Bank which shall become and remain the sole and exclusive property of wife. The joint savings and checking account to No. 137682 at Members 1st Federal Credit Union shall become and remain the sole and exclusive property of Husband. 12. WIFE'S DEBTS Wife represents and warrants to Husband that since the separation she has not and in the future she will not contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save harmless Husband from any and all claims or demands made against him by reason of debts and obligations incurred by the Wife prior to the date of the delivery of this Agreement, and all further debts incurred by the Wife from and after the date of delivery hereof, shall be the Wife's individual responsibility. 13. HUSBAND'S DEBTS Husband represents and warrants to Wife that since the separation he has not and in the future he will not contract or incur any debt or liability for which Wife or her estate might be responsible 8 may have respectively a vested or contingent right or interest at the time of the signing of this Agreement. 16. LIFE AND HEALTH INSURANCE Husband and Wife shall each be deemed to be and remain in sole and exclusive possession, control and ownership of his or her own life insurance policies and benefits, if any, and any life insurance policies and benefits as a result of their respective employments, if any, and neither will make any claim against the other for any interest therein. Husband agrees to maintain health insurance coverage for Wife through Husband's employer to December 1, 2003, at which time the parties shall promptly proceed to secure a mutual consent, no-fault divorce pursuant to the terms of Section 3301(c) of the Divorce Code. Except as provided otherwise in this Agreement, Husband and Wife each shall be deemed to be and remain in sole and exclusive possession, control and ownership of his or her own medical, dental and all health insurance policies and benefits, and neither will make any claim against the other for any interest therein. Each of the parties agrees to assume, indemnify and hold respectively the other harmless from any and all liability for any and all costs, expenses, claims, demands and obligations whatsoever with respect to their life insurance, medical, dental and all health insurance policies and benefits. 17. REAL ESTATE Husband and Wife were the joint owners of a marital residence located in Kentucky (hereinafter "Property"). The net proceeds of the sale of said Property have been divided to the mutual satisfaction of each party. Wife acknowledges that she has received as the result of said sale 10 a distribution in the sum of $5,500.00 and Husband acknowledges that he has received a distribution from said sale of $500.00. 18. REVOCATION OF POWER OF ATTORNEY XxX~gxxxxxxxx)fxxxxxxx Husband executed a Power of Attorney appointing Wife as Husband's attorney-in-fact. Effective immediately upon execution of this Agreement individually by Husband, without any need of joinder, consent or execution in this Agreement by Wife whatsoever, Husband hereby revokes and makes void said Power of Attorney 8a~tfd~XXXXXXXXXX, XXXXXX and further revokes and makes void for any and all purposes all powers and authorities therein and thereby given to Wife. Wife upon and by her execution of this Agreement expressly acknowledges the full and complete revocation of Husband's Power of Attorney and also warrants and represents that since the separation she has not and in the future will not act upon or exemise any powers or authority provided therein for any and all purposes. 19. WAIVER OF SPOUSAL SUPPORT, ALIMONY PENDENTE LITE, AND ALIMONY Wife and Husband do hereby waive, release and give up any rights they may respectively have against the other for alimony, alimony pendente lite, support or other maintenance. It shall be from the date of this agreement the sole responsibility of each of the respective parties to sustain themselves without seeking any support from the other party. Wife has initiated against Husband legal or other action for or pertaining to support or maintenance, such as spousal support, alimony or alimony pendente lite, at Cumberland County No. 2002-20'1, D.R. No. 31896, PACSES No. 739104684, and said action, including but not limited to any Order of Court for alimony pendente lite, shall be deemed withdrawn and be terminated for all purposes effective immediately upon execution of this Agreement. 11 20. ATTORNEY FEES, COSTS & EXPENSES The parties agree to waive receipt of and to be responsible for their own attorney fees, costs and expenses in connection with the negotiation and preparation of this agreement and the granting of a divorce decree. 21. BREACH OF AGREEMENT If either party fails in the due performance of obligations under this agreement at their election, the non-breaching party shall have the right to sue for damages for breach of this agreement or to rescind same and seek such legal remedies as may be available to them. The breaching party will be responsible for actual legal fees and costs incurred by the non-breaching party necessary to the enforcement of this agreement. 22. LAW OF PENNSYLVANIA APPLICABLE This agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date of execution of this agreement. 23. AGREEMENT BINDING ON HEIRS This agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 24. SEVERABILITY 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 full force, effect and operation. Likewise, the failure of any party to meet her or his obligations under 12 any one or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. 25. 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. 26. 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 of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 27. MUTUAL COOPERATION Each party shall, at any time and from time to time hereafter, take any and all steps and execute, acknowledge and deliver to the other party any and all furl:her instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this agreement. 28. WAIVER 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 it be construed as a waiver of strict performance of any other obligations herein. 13 29. HEADING 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 constitu'Ie a part of this agreement nor shall they affect its meaning, construction or effect IN WITNESS WHEREOF, the parties hereto have set 'their hands and seals they day and year first written above. WITNE S S: Leslie A. Stoner ~ Je ffre-y/2~amper 42787 14 COMMONWEALTH OF COUNTY OF : SS: On this, the ~ ~ day of (7)chcq~ ~-, 2003, before me, a Notary Public, the undersigned S, officer, personally appeared Jeffrey ,~. Stamper, known to me to be the person whose name is subscribed to the within Property Settlement Agreement, and acknowledged that he executed the same for the purposes therein contained. ~IANE J. 8OIEI'T ~ Pub~ M~;ne My ~n F.~res Ju~y 11,2010 COMMONWEALTH OF PENNSYLVANIA : Ct.,-& ta,4 :ss: COUNTY OF : On this, the \ \-~-x day of ~, 2003, before me, a Notary Public, the undersigned officer, personally appeared Leslie A. Stoner, known to me to be the person whose name is subscribed to the within Property Settlement Agreement, and acknowledged that she executed the same for the purposes therein contained. 42787 Not'a~y~Publi~v// I 'NOTARIAL SEAL TAMMY S. FAUST, Notary Public Lower ALlen Twp. Cumberland County My Commission Expires July 5, 2006 LESLIE A. STONER, : Plaintiff : JEFFREY S. STAMPER, : Defendant : THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 207 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this day of , 2003, the economic claims raised in the proceedings having been resolved in accordance with a property settlement agreement dated October 3, 2003, the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. BY THE COURT, cc: fharles Rector Attorney for Plaintiff ~tanley J.A. Laskowski Attorney for Defendant LESLIE A. STONER, Plaintiff, VS. JEFFREY A. STAMPER, Defendant. TO THEPROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-207 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PRAECIPE The parties by and through their undersigned counsel hereby stipulate and agree that the caption in the above-referenced matter be amended to reflect the correct spelling of Defendant's name and that such caption should now read as follows: LESLIE A. STONER, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 02-207 CIVIL TERM JEFFREY S. STAMPER, Defendant. CIVIL ACTION - LAW IN DIVORCE Please mark the docket and amend the caption accordingly pursuant to the foregoing. Date: Date: /o 63365 By: By: Respe_~t.f, glly su b,mitte,~, Stanley J. A~Laskowski, Esquire Attorney I. D. # 37422 Caldwell & Keams, P.C. 3631 North Front Street Harrisburg, PA 17110-1533 (717) 232-7661 Attorney for Defendant, Jeffrey S. Stampe~ C~larles ReC't~, Esquire Attorney I.D.# ~ ?/.2/ 1104 Fernwood Avenue, Suite 203 Camp Hill, PA 17011 (717) 761-8101 Attorney for Plaintiff, Leslie A. Stoner ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERZA.,'TD Date of Order/Notice 10/23./03 Tribunal/Case Number (See Addendum for case summary) C) Original Order/Notice C) Amended Order/Notice {~) Terminate Order/Notice Employer/Withholder's Federal £1N Number KEYSTONE HELICOPTER CORPORATIO C/O ANITA HAMILTON 1420 PHOENIXVILLE PIKE WEST CHESTER PA 19380-1438 RE: STAMPER, JEFFREY S. Employee/Obligor's Name (Last, First, 27"/-80-4647 Employee/Obli§or's Social Security Nur 4610101016 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 CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct the~ 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. o0. per month in current support $ o. 00 per month in past-due support Arrears 12 weeks or greater? Oyes (~) no $ o. oo per month in medical support $ 0. o0 per month for genetic test costs $ per month in other (specify) for a total of $ 0. O0 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 ma the ordered support payment cycle, use the following to determine how much to withhold: $ 0. oo per weekly pay period. $ o. oo per biweekly pay period (every two weeks). $ 0. oo per semimonthly pay period (twice a month). $ 0. 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 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 Date of Order: Service Type N Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 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 PROCESSEI~ DONOTSENDCASHBYMAIL.'~'?~,,~~.. ~~/0' 2. ~--~, BY THE CO 5~ OMB NO.: 0970-0154 Form EN-028 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS [] If checked you are required to provide acopy of this form to your emo oyee. If your eml)lovee works in a state h ' different from the state that issued this order, a copy must be provided to your employee'ev~n if the box is not c~tk~d. 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 ~ax levies in effect please contact the requesti agency listed below. 3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to employee/obligor. -~',- ,,,~ ~,,,l~,~,y ~ ~ -,~.~ You must comply with the law, state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement tt withholding order and forward the suppor[ payments. 5.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support agail th is employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must foil the law of the state of employee's/obligor's principal place of employment. You must hoqor 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 Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S ID: 2315965500 EMPLOYEE'S/OBLIGOR'S NAME: STAMPER, JEFFREY S. EMPLOYEE'S CASE IDENTIFIER: 461010:].0:].6 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 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. g. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should h withheld from the employee/ob[igor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unl~ the obligor is employed in another State, in which case the [aw of the State in which he or she is employed governs. 9. 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/obligor because of a support withholding. Pennsylvania State 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. t 0.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection ACt (1.5 U.S.C. §1673 (b)l; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employme 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 taxes; 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 th~ law of the state that issued this order with respect to these items. Submitted By: DOMESTIC RELATIONS 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 .(717) 240~6225 or by FAX at (717) 240-624(I or by internet www.childsupport.state.pa.us lg ~ach ,f the Ye Page 2 of 2 Form EN~028 Service Type M OMB No: 09704~154 Worker ID STA?' LESLIE A. STONER, Plaintiff JEFFREY S. STAMPER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-207 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE PROOF OF SERVICE OF' DIVORCE COMPLAINT · Complete items 1, 2, and 3. Aisc complete item 4 if Restricted Delivery is desired. · Pri~ yeur name ar~t-eddrese~ thereverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. A. Received by (P/ease Print Cleady) B. Date o( Delivery 2. A~ticle Number (Copy from service label~ r-i Express Mai Registered r"l Return Rec~ [] insured Mail [] C.O.D. 4. Restricted Derivery? (Extra F6e) PS Fo~n 3811, July 1999 Domestic Return Receipt Date: By: Charles Rector, Esquire 1104 Fernwood Avenue, Ste. 203 Camp Hill, PA 17011-6912 (717) 761-8101 Attorney for Plaintiff LESLIE A. STONER, Plaintiff V. JEFFREY $. STAMPER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-207 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 15, 2002. 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 in divorce after service of notice of intention to request entry of the decree. ~_O_F INTENTION TO REQUEST ENTRY '..','~ =.~u-~ C UP 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 herein are true and Correct. I understand that false statements herein are made subject to the penalties of 118 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: Leslie A. Stoner LESLIE A. STONER, Plaintiff V. JEFFREY S. STAMPER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO, 02-207 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORn To the Prothonotary: Transmit the record together with the following information, to the Coud for entry of a divorce decree: 1. Ground for a divorce: irretrievable breakdown urnder Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified Mail - 01/28/02. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the Plaintiff 11/24/03, by the Defendant 1--0/03/03. (b) (1) Date of execution of the plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of service of the plaintiff's affidavit upon the Defendant: 4. Related claim pending: _None. 5. Complete either (a) or (b) (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached, if the decree is to be entered under section 3301 (d) of the Divorce Code: (b) Date Plaintiff's Waiver of Notice in § 3301 (c) Divorce was filed with the Prothonotary 12/01/03. Date Defendant's Waiver of Notice in § 3301(c) was filed with the Prothonotary 1~0/14/03. Date: 12/02/03 Charles Rector, Esquire Attorney for the Plaintiff IN THE COURT OF COIVIMON PLEAS OF CUMBERLAND COIJNTY STATE OF PENNA. LESLIE A. STONER NO. 02-207 Civil Term VERSUS JEFFREY S. STAMPER DECREE IN AND NOW,.. DIVORCE , IT IS ORDERED AND DECREED THAT Leslie A. Stoner AND Jeffrey S. Stamper _,PLAINTIFF, _,DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. 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; N/A The written Property Settlement Agreement -ex=uub=d b~ Lh= ~ti=~ i~ aLtacl~=d ...... -~ -' into this Decree for enfor, )oses only pursuant to Section 3105 of the Pennsylva Code. ATTEST: dated October 3, 2003,