Loading...
HomeMy WebLinkAbout04-4831ANDREW C. VAN GORDER, Plaintiff VS. STEPHANIE C. VAN GORDER, Defendant IN THE COURT OF GAMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. p y. q f'31 Civil Term ACTION IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. Where 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, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE; OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 32 South Bedford St. Carlisle, Pa. 17013 (717) 249-3166 ANDREW C. VAN GORDER, Plaintiff VS. STEPHANIE C. VAN GORDER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. O y - `/ P 3 / Civil Term ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Andrew C. Van Gorder, commonly known as Chris Van Gorder, a competent adult individual, who has resided in Waco, Texas, since August 2004. 2. Defendant is Stephanie C. Van Gorder, a competent adult individual, who has resided at 7 High Street, Boiling Springs, Cumberland County, Pennsylvania, since 1996. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on July 2, 1983 in Flint, Michigan. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have four children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. Respectfully submitted, Date: V(2 r// I.D. No. 79465 36 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. •?L?C V? Andrew C. Van Gorder, Plaintiff ""?t "\ v ? r {5'1(71 T 1r' ni-n -pr' rj cn : r 0 U? c DREW C. VAN GORDER, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLANDQpCOUNTY,PENNSYLVANIA No. OA Civil Term VS. STEPHANIE C. VAN GORDER, ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE AND NOW, this October 1, 2004, I, Jane Adams, Esquire, hereby certify that on September 29, 2004, a certified true copy of the NOTICE TO DEFEND AND COMPLAINT was served, via certified mail, return receipt requested, addressed to: Stephanie C. Van Gorder 7 High St. Boiling Springs, Pa. 1700 DEFENDANT rz ; • 3?f?J a Mks 7003 1010 0004 7818 6763 I 'Pt od? ". ,, nN P&WM Respectfully Adams, Esquire [. . No. 79465 6 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF < o a 1 F' O -t T - 4" N it W -C a ALBERT C. VANGORDER, Plaintiff/Respondent VS. STEPHANIE C. VANGORDER, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :NO. 04-4831 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 or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PENNSYLVANIA 17013. IF YOU DO NOT WISH TO 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 249-3166 Lori K. Serratelli, Esquire Pa. Supreme Court ID No. 27426 Serratelli, Schiffinan, Brown and Calhoon, P.C. 2080 Linglestown Road Suite 201 Harrisburg, Pennsylvania 17110 Telephone (717) 540-9170 Fax (717) 540-9170 Attorney for Plaintiff ANDREW C. VANGORDER, Plaintiff/Respondent vs. STEPHANIE C. VANGORDER, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4831 CIVIL ACTION - LAW : IN DIVORCE DEFENDANT'S ANSWER TO PLAINTIFF'S COMPLAINT IN DIVORCE WITH COUNTERCLAIMS AND NOW COMES the above-named Defendant/Petitioner, by and through her attorney, Lori K. Serratelli, Esquire and the law firm of SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C., and files this Answer to Plaintiff's Complaint in Divorce including Counterclaims, averring as follows: 1. Admitted. 2. Admitted in part and denied in part. It is admitted that Defendant is a competent individual who has resided at 7 High Street, Boiling Springs, Cumberland County, Pennsylvania, since 1996. It is denied that Defendant's name is Stephanie C. VanGorder. To the contrary, Defendant's name is Stephanie S. VanGorder. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. Admitted. 9. Admitted. 10. Admitted. DEFENDANT/RESPONDENT'S COUNTERCLAIM COUNTI DIVORCE 11. Paragraphs one through ten are hereby incorporated by reference herein. 12. The Defendant/Petitioner avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Defendant/Petitioner requests the Court to enter a decree in divorce. 2 COUNT II ALIMONY 13. Paragraphs one through ten are hereby incorporated by reference herein. 14. Defendant/Petitioner is unable to adequately support herself through appropriate employment. 15. Defendant/Petitioner lacks sufficient property, including but not limited to, any property distributed pursuant to the Divorce Code of 1980, as amended, to provide for her reasonable needs. WHEREFORE, Defendant/Petitioner prays that your Honorable Court grant an Order upon Plaintiff/Respondent: (a) Compelling the Plaintiff/Respondent to pay alimony to Defendant/Petitioner; COUNT III ALIMONY PENDENTE LITE, COUNSEL FEES AND COSTS 16. Paragraphs one through ten are hereby incorporated by reference herein. 17. That by reason of the institution of the action to the above term and number, Defendant/Petitioner will be and has been put to considerable expense in the preparation of her case, in the employment of counsel and the payment of costs. 3 18. That the Defendant/Petitioner's income is disproportionately lower than Plaintiff/Respondent's income, and Defendant/Petitioner is without adequate funds to pay the costs and expenses of this litigation, and is, likewise, without adequate funds to maintain herself during the pendency of the litigation. 19. The Plaintiff/Respondent is employed at Baylor University and earns approximately $4,400.00 net per month. 20. The Defendant/Petitioner is employed at Tressler Care Wilderness Center (Diakon Lutheran Services) and earns approximately $692.30 net bi-weekly. WHEREFORE, Defendant/Petitioner prays that your Honorable Court grant an Order upon Plaintiff/Respondent to pay Defendant/Petitioner alimony pendente lite and counsel fees and costs of litigation. COUNT IV EQUITABLE DISTRIBUTION 21. Paragraph one through ten are hereby incorporated by reference herein. 22. Defendant/Petitioner states that Plaintiff/Respondent and Defendant/Petitioner possess various items of both real and personal marital property which is subject to equitable distribution by the court. 23. Defendant/Petitioner requests that this Court grant equitable distribution. WHEREFORE, Plaintiff prays that Your Honorable Court: (a) Equitably distribute all property, personal and real owned by the parties; 4 (b) Grant Defendant/Petitioner exclusive possession of the marital residence; (c) Grant such further relief as the Court may deem equitable and just. Respectfully submitted, kLM V)n I I Y'- 1c), Lori K. Serratelli, Es uire Attorney ID No. 27426 S ERRATELLI, S CHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for Defendant/Petitioner 5 VERIFICATION I verify that the statements made in the foregoing Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsification to autho s. Date: J ` Stephanie' . VanGorder 6 CERTIFICATE OF SERVICE I, Cara A. Boyanowski, Esquire, do hereby certify that on this 14th day of December , 2004, I served a copy of the foregoing document by United States Mail, First Class, postage pre- paid, to the following person(s): Jane Adams, Esquire 36 South Pitt Street Carlisle, PA 17013 P1101 0 &0 - fi S Cara A. Boyanowski, squire SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for Defendant r..? ,_, ?? ? ? r ., `Yl .x:^ "" ? C i i? T: "7 _?Si!' - ? ?-? .? ._;-7 ' ??? . l' " i f i ?? ? ? .. ?'•.} ?..,, w. G....: ANDREW C. VAN GORDER, Plaintiff VS. STEPHANIE C. VAN GORDER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 04 - 4831 Civil Term ACTION IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Defendant (Plaintiff)(Defendant) moves this Court to appoint a master with respect to the following claims: Divorce { ) Annulment {}?) Alimony Alimony Pendente Lite and in support of the motion states: Distribution of Property Support Counsel fees Costs and Expenses (1) Discovery is complete as to the claim(s) for which the appointment of a master is requested. (2) The D, fe, d (has has not) appeared in the action (personally his attorne} tc S,e 61 x Esquire). (3) The statutory ground(s) for divorce (is)(are) -i3-0 (4) Delete the inapplicable paragraph(s): (a) Us a4iffi? sted. (b) Aft affeeffient has been reaghpd lyith rospeet to the following claims- (c) contested with respect to the following claims: (5) The action (involves) oes not involve mplex issues of law or fact, (6) The hearing is expected to take day (hours). (7) Additional information, if any, relevant to the Date: a ' ( () 0 s9- Adams, AND NOW, this 20(ir Robert Elicker, Esquire, is appointed Master with respect to the following claims: C(QQ , BY THE J, ANDREW C. VAN GORDER, Plaintiff vs. STEPHANIE C. VAN GORDER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 04 - 4831 Civil Term ACTION IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Defendant (Plaintiff)(Defendant) moves this Court to appoint a master with respect to the following claims: Divorce ( ) Annulment Alimony ??Gj Alimony Pendente Lite and in support of the motion states: Distribution of Property Support Counsel fees Costs and Expenses (1) Discovery is complete as to the claim(s) for which the appointment of a master is requested. (2) The D fendan (has has not) appeared in the action (personally* his attome? S,z , to x Esquire). (3) The statutory ground(s) for divorce (is)(are) -? 3 O 1 (C (4) Delete the inapplicable paragraph(s): contested, (b)Aft agreement has been Feaekedwith Fespect !a the following cWms- (c) The action is contested with respect to the following claims: (5) The action (involves) oes not involve mplex issues of law or fact. (6) The hearing is expected to take 1 day (hours). (7) Additional information, if any, relevant to the Date: I Q ?? Adams, i= AND NOW, this {e K? /,5? , 20CK Robert Elicker, Esquire, is appointed Master with respect to the following claims: _> ?, - - , ., _ .?. . ,, ?.' , ANDREW C. VANGORDER, Plaintiff VS. STEPHANIE C. VANGORDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4831 CIVIL ACTION - LAW : IN DIVORCE STIPULATION TO AMEND CAPTION AND NOW, this _ day of 2005, it is hereby stipulated by Plaintiff's counsel, Jane Adams, Esquire, and Defendant's counsel, Lori K. $erratelli, Esquire, as follows: WHEREAS, Andrew C. VanGorder filed a Complaint in Divorce to the above term and number on September 24, 2004. WHEREAS, Defendant's name is Stephanie S. VanGorder, not Stephanie C. VanGorder. NOW, THEREFORE, the parties intending to be legally bound hereby agree as follows: 1. The caption in the above divorce action shall be amended to read drew C. VanGorder, Plaintiff v. Stephanie S VanGorder Defendan t. IN WITNESS WHEREOF, the parties intending to be legally bound hereby have affixed their hands and seals. ms, Esquire for Plaintiff Deb/SZI Gti '1 i -'* 1 fTi S i"l H?l RECEIVED APR 11100115 V1 ANDREW C. VANGORDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 04-4831 : CIVIL ACTION - LAW STEPHANIE S. VANGORDER, Defendant : IN DIVORCE ORDER AND NOW, this //-day of Ap , WOOS' , upon consideration of the foregoing Stipulation, it is hereby ORDERED and DECREED that the caption in the above titled matter shall be amended to read as follows: Andrew C. VanGorder Plaintiff v Stephanie S VanGorder. Defendant. The correct caption matter. 5 shall be used on all future pleadings filed in this BY THE COURT: ?H; JO ANDREW C. VAN GORDER, Plaintiff vs. STEPHANIE VAN GORDER, S Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 04 - 4831 Civil Tetm ACTION IN DIVORCE AFFIDAVIT OF CONSENT U A complaint in divorce under section 3301(c) of the Divorce Code was filed on Q Z l o 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. 1 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 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unworn falsification to authorities. Date: '/l /0(, (r t??"'? Andrew C. Van Gorder, Plaintiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) AND 43301(d) OF THE DIVORCE CODE 1. I consent to entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of I8 Pa.C.S. §4904 relating to unworn falsification to authorities. Date: 12111/00 Andrew C. Van Gorder, Plaintiff (1 ?...? T ?? ????? -r z.}f, '.'.. ?.? 4} '_'.'?1 ??`-S: Cs3 ANDREW C. VAN GORDER, Plaintiff VS. S STEPHANIE. VAN GORDER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 04 - 4831 Civil Term ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on by 0 4 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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 also understand t4-Alse statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unswom falsif lion to authorities. Date: '?) 5 /o 6 ? - ph i Van Gorder, WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) AND 83301(d) OF THE DIVORCE CODE 1. I consent to 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 1 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. -understand that herein are made subject to the penalties of 18 Pa.C.S. §4904 relatin to = falsification to Date: tech ie,C. Van Gorder. Defenc S ?? ANDREW C. VANGORDER, Plaintiff/Respondent vs. STEPHANIE S. VANGORDER, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4831 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT, made this -,a n,4 day of 1-?ru6L '`? , 2006, by and between, STEPHANIE S. VANGORDER, of Boiling Springs, Cumberland County, Pennsylvania, hereinafter referred to as "WIFE", and ANDREW C. VANGORDER, commonly known as CHRIS VANGORDER, of Waco, Texas, hereinafter referred to as "HUSBAND". WITNESSETH: WHEREAS, Husband and Wife were lawfully married on July 2, 1983, in Flint, Michigan, and; WHEREAS, there were four children born of this marriage; WHEREAS, differences, disputes, and difficulties have arisen between the parties and it is the intention of Husband and Wife to live separate and apart for the rest of their natural lives, and the parties desire to settle their respective financial property rights and obligations as between each other, including the settling of all matters between them relating to ownership and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present, and future support, alimony, and/or maintenance of Husband or Wife; and in general, the settling of any and all possible claims by one against the other or against their respective estates; NOW, THEREFORE, Wife and Husband, each intending to be legally bound, hereby covenant and agree as follows: 1. FULL DISCLOSURE OF ASSETS. Each party warrants that he or she has made a full and fair disclosure of income, assets, and their valuation prior to the execution of this Agreement as well as any other fact relating in any way to the subject matter of this agreement. These disclosures are part of the consideration made by each party for entering into this agreement. 2. ADVICE OF COUNSEL. The Husband has employed and had the benefit or counsel of Jane Adams, Esquire, as his attorney. The Wife has employed and had the benefit or counsel of Lori Seratelli, Esquire, as her attorney. Each party has carefully and completely read this agreement and has been advised and is completely aware not only of its contents but of its legal effect. 3. SEPARATION. The parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intention and purpose of this agreement to set forth their respective rights and duties while they continue to live apart from each other. Neither party shall harass, annoy, injure, threaten, or interfere with the other party in any manner whatsoever. Each party may carry on and engage in any employment, profession, business or other activity as he or she may deem advisable. Neither party shall interfere with the uses, ownership, enjoyment, or disposition of any property now owned and not specified herein or property hereafter acquired by the other. 4. SUBSEQUENT DIVORCE. The parties hereby acknowledge that Husband has filed a Complaint in Cumberland County, Pennsylvania, claiming that the marriage is irretrievably broken under the no-fault mutual consent provision of Section 3301(c) of the Pennsylvania Divorce Code. Wife hereby expresses her agreement that the marriage is irretrievably broken and expresses her intent to execute any and all affidavits or other documents necessary for the parties to obtain an absolute divorce pursuant to Section 3301(c) of the Divorce Code. The parties hereby waive all rights to request Court Ordered counseling under the Divorce Code. The provisions of this Agreement relating to equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever, as contemplated by the Pennsylvania Divorce Code. Should a decree, judgment, or order of separation or divorce be obtained by either of the parties in this or any other state, country or jurisdiction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be affected in any way by any such 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 shall remarry. It is specifically agreed that a copy of this Agreement or the substance of the provisions thereof, may be incorporated by reference into any divorce, judgment, or decree. This incorporation shall not be regarded as a merger, it being the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties. 5. DATE OF EXECUTION. The "date of execution" or "execution date" of this agreement shall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. All provisions of this agreement shall be effectuated by the parties within thirty (30) days of the execution date of this agreement unless otherwise specified within this agreement. 6. MUTUAL RELEASE OF ALL CLAIMS. HUSBAND and WIFE each do hereby mutually remise; release, quit-claim and forever discharge the other and the estate of the other, of and from any and all rights; titles, and interests, 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, or whatever nature and wheresoever situate, which she or he 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 curtesy, or claims in the nature of dower or curtesy of widows 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 the decease spouses estate, whether arising under the laws of Pennsylvania, any state, commonwealth, or territory of the United States, or any other country, or any rights which Wife may have or at any time hereafter have against the other for past, present or future support or maintenance, alimony, alimony pendeme lite, counsel fees, costs, expenses, or equitable distribution of marital property whether arising as a result of any 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. 7. WARRANTY OF DEBTS AND FUTURE OBLIGATIONS. Each party warrants that they have not contracted any debt or liability for the other or which the estate of the other party may be responsible or liable, and except only for the rights arising out of this agreement, neither party will hereafter incur any liability whatsoever for which the other party or the estate of the other parry, will be liable. Each party agrees to indemnify or hold harmless from the other and against all future obligations of every kind incurred by them, including those for necessities. 8. OUTSTANDING JOINT DEBTS. (a) Wife agrees that the following debts are her own personal responsibility and therefore agrees to completely and finally pay on the following debts and obligations: Any and all obligations relating to the marital home including those owed to Citimortgage. (b) Husband agrees that the following debts are his own personal responsibility and therefore agrees to completely and finally pay on the following debts and obligations: The National City Bank Visa, The MBNA Visa, The Susquehanna Valley Credit Union Debt. Husband has completed Assumption of Debt documents regarding these loans which has effectively removed Wife from any obligation regarding these loans. Husband will provide written confirmation of the assumption of debt to wife upon his receipt of such documents. 9. EQUITABLE DIVISION OF MARITAL PROPERTY. The parties have attempted to distribute their marital property in a manner which conforms to the criteria set forth in 23 Pa.C.S.A. s3501 et. seq. and taking into account the following considerations: the length of the marriage, the age, health, station, amount, and sources of income, vocational skills, employability, estate, liabilities, and needs of each of the parties, the contribution of each party to the education, training, or increased earning power of the other parry; the opportunity for each party for future acquisitions 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 the marital property, including the contribution of each spouse as a homemaker; the value of the property set apart to each party; the standard of living the parties established during the marriage; and the economic circumstances of each party at the time the division of property is to become effective. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division is being effected without the introduction of outside funds or other property not constituting marital property. The division of property under this Agreement shall be in full satisfaction of all the marital rights of the parties. As such, the parties acknowledge that Husband or Wife's obligation to make the payments defined in this agreement shall not be subject to termination, discharge, or discontinuance in bankruptcy or for any other reason or by any Court or tribunal. Should Husband or Wife pursue and action in bankruptcy and be successful in extinguishing his obligation to pay any debts for which he has assumed sole obligation as set forth herein, he or she shall immediately be obligated to pay alimony to the other party in an amount equal to the monthly obligation on such debts that he or she otherwise had assumed and for which he had taken sole obligation and responsibility, plus an additional fifteen percent (15%) in consideration of the tax consequences associated with receipt of alimony. At the time of the implementation of this alimony award, which may be made through the appropriate Domestic Relations of support office with the Court of Common Pleas of appropriate jurisdiction as Husband or Wife may select, such party shall then be responsible for any such debts extinguished through the other party's bankruptcy as described herein. 10. OTHER PERSONAL PROPERTY. Husband and Wife do hereby acknowledge that they have previously divided all their tangible personal property. Except as may otherwise be provided in this Agreement, Wife agrees that all of the property of Husband or in his possession shall be the sole and separate property of Husband; and Husband agrees that all of the property of Wife or in her possession shall be the sole and separate property of Wife. The parties do hereby specifically waive, release, renounce, and forever abandon whatever claim, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other. (a) Wife will retain the Muhlenkemp Fund of $300.00 (b) All joint savings accounts shall be closed and the proceeds divided equally. 11. MOTOR VEHICLES. With respect to the motor vehicles, owned by one or both of the parties, they agree as follows: (a) The Honda Passport shall be and remain the sole and exclusive property of Wife. (b) The Toyota Corolla shall be and remain the sole and exclusive property of Husband. The titles to the said motor vehicles shall be executed by the parties, if appropriate for effecting transfer as herein provided, within thirty days of the execution date of this Agreement, and said executed titles shall be delivered to the proper parties on the distribution date. Each party agrees to be solely responsible for the amounts presently due and owing against his or her respective automobiles. 12. REAL ESTATE. (a) HUSBAND and WIFE hold title as Tenants by the Entireties to the premises identified as 7 High Street, Boiling Springs, Cumberland County, Pennsylvania. The parties agree as follows with respect to the marital residence: (1) Wife shall retain all right, title and interest in the marital residence and shall refinance the mortgage obligation in her own name alone within five (5) years of this agreement. Within thirty days (30) of this agreement, and as soon as reasonably possible after the signing of this agreement, Husband shall execute a Deed transferring all right, title and interest in the marital home into Wife's name alone. Wife shall be responsible for all costs and filing fees associated with said refinancing and Deed transfer. If Wife is not able to refinance the mortgage obligation on the marital home, she will list the home for sale and take all actions necessary to sell the marital home. (2) As of the date of separation, and without regard to when bills for such items are incurred, received or due, Wife shall be solely responsible for all past, present, and future costs or liabilities associated with or attributable to maintaining the marital residence (except as provided herein), including but not limited to, the monthly mortgage obligation, all real estate taxes, water and sewer rents, gas, electric, and telephone service, homeowner's insurance, and gardening expenses and repairs, and Wife shall keep Husband and his successors, assigns, heirs, executors, and administrators indemnified and held harmless from any liability, cost or expense, including attorney's fees, which are incurred in connection with such costs and expenses. 13. MUTUAL WAIVER OF EMPLOYMENT BENEFITS. The parties agree to waive any and all rights they have in and to each other's employment benefits, including but not limited to both parties pensions and retirement plans and Incentive Savings Plans. The parties agree never to assume any claim to such benefits of the other at any time in the future. Wife hereby waive any and all interest in Husband's retirement benefit with his previous employers, including his retirements from Messiah and Harrisburg Public Schools. Wife will sign any document required to have her name removed from these benefits. 14. ALIMONY, CHILD SUPPORT, and LEGAL FEES. Other than as provided in this agreement, each party hereby waives any right to spousal support, alimony, or alimony pendente lite, and each party agrees to be responsible for his or her own legal fees and expenses. (a) All alimony to be paid under this agreement shall terminate upon the recipient's death, remarriage or cohabitation with an unrelated person of the opposite sex. (b) Husband shall obtain a Life Insurance Policy in the amount of $250,000.00 and shall maintain such policy as long as alimony or child support payments are being made. Wife shall be listed as the sole irrevocable beneficiary of the policy as long as alimony and/or child support payments are being made by husband. (c) As of the date of the divorce decree, Husband agrees to treat all credits towards child support as zero. Husband shall write a letter to Domestic Relations and/or cooperate in any other documents they may require to effectuate this purpose. (d) Alimony shall be modifiable and the length and amount of alimony shall be subject to review based on a substantial change in the economic circumstances of either party. (e) Immediately, upon entry of a Divorce Decree: (i) Husband shall pay Wife the amount of $300 per month in alimony. The payment will be due on the first of each month. The alimony will continue through May 2018. (ii) Husband and Wife agree that Husband shall pay Wife the amount of $1250 a month in child support. 15. INCOME TAX RETURNS. Husband and wife represent to each other that, other as provided herein, to the best of their knowledge all federal, state, and local taxes required to paid with during the marriage and during the periods covered by such tax returns have been paid. Husband agrees to pay in full all tax deficiencies incurred for the year 2003 by making arrangements directly with the IRS. 16. WAIVER OR MODIFICATION TO BE IN WRITING. No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties, and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 17. 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 further 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. 18. APPLICABLE LAW. The 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. 19. INTEGRATION. This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements or negotiations between them. There are no representations or warranties other than those expressly set forth herein. 20. OTHER DOCUMENTATION. Wife and Husband covenant and agree that they will forthwith execute any and all written instruments, assignments, releases, satisfactions, deeds, notes, or such other writings as may be necessary or desirable for the proper effectuation of this Agreement. 21. NO WAIVER OF DEFAULT. This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any default or breach of any provision hereof by construed as a waiver of any subsequent default or breach of the same or similar nature, not shall it be construed as a waiver or strict performance of any other obligations herein. 22. 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 provisions shall be stricken from this Agreement; and in all other respects, this Agreement shall be valid and continue in full force, effect, and operation. Likewise, the failure of any party to meet his or her obligations under 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. 23. BREACH. If either party breaches any provisions of this agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, or seek other remedies or relief as may be available to him or her, and the parry breaching this contract should be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this agreement. 24. INFORMED AND VOLUNTARY EXECUTION. Each party to this agreement acknowledges that he or she is fully informed as to the facts relating to the subject matter of this agreement, is entering into this agreement voluntarily, free from fraud, undue influence, coercion or duress of any kind, has given careful thought to the making of this agreement, has carefully read each provision of this agreement, and fully and completely understands each provision of this agreement. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written: WITNESS: ANDREW C. VANGORDER Date: I D) -)"Cl `o -- COMMONWEALTH OF PENNSYLVANIA COUN. TY OF CUMBERLAND ):SS On this, the day of V-)2 (Q YY1 , 2005, before me, the undersigned officer, personally appeared ANDREW C. VANGORDER known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he/she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Public commission expires: NWEALTH OF PENNSYLVANIA Notarial Seal Jane Adams, Notary Public 5My lisle Bore, Cumberland County om mission Expires Sept. 6, 2008 TWSS `11. ) ? `"-? Date: COMMONWEALTH OF PENNSYLVANIA COUNTY OFD W ) ss On this, the day of s 2008, before me, the undersigned officer, personally appeared STEPHANIE VANGORDER known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he/she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. h-- Notary Public My commission expires: SEAL NOTARLAL SEAL DEBRA A EVANGEUSTI Notary Public SUBCUENANNA TNP.DAUPNIN COUNTY My CommUm Expyea May 7, 2008 ANDREW C. VANGORDER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 04 - 4831 CIVIL STEPHANIE S. VANGORDER, Defendant IN DIVORCE ORDER OF COURT AND NOW, this iU _U day ofj L(F fi3c 2006, the economic claims raised in the proceedings havi g been resolved in accordance with a marriage settlement agreement dated February 2, 2006, 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, /i Edgar B. Bayley, P.J. cc: Jane Adams Attorney for Plaintiff Lori K. Serratelli o Attorney for Defendant _ .:? 4 ?? 1 _?? V'7 ` _if l.. ? _? ?? ' ? ? ?. ? ? L= ?? C.. c-L. ANDREW C. VANGORDER, Plaintiff/Respondent VS. STEPHANIE S. VANGORDER, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4831 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT, made this ,,.? n? day of Fe-?i'kct 2006, by and between, STEPHANIE S. VANGORDER, of Boiling Springs, Cumberland ounty, Pennsylvania, hereinafter referred to as "WIFE", and ANDREW C. VANGORDER, commonly known as CHRIS VANGORDER, of Waco, Texas, hereinafter referred to as "HUSBAND". WITNESSETH: WHEREAS, Husband and Wife were lawfully married on July 2, 1983, in Flint, Michigan, and; WHEREAS, there were four children born of this marriage; WHEREAS, differences, disputes, and difficulties have arisen between the parties and it is the intention of Husband and Wife to live separate and apart for the rest of their natural lives, and the parties desire to settle their respective financial property rights and obligations as between each other, including the settling of all matters between them relating to ownership and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present, and future support, alimony, and/or maintenance of Husband or Wife; and in general, the settling of any and all possible claims by one against the other or against their respective estates; NOW, THEREFORE, Wife and Husband, each intending to be legally bound, hereby covenant and agree as follows: 1. FULL DISCLOSURE OF ASSETS. Each party warrants that he or she has made a full and fair disclosure of income, assets, and their valuation prior to the execution of this Agreement as well as any other fact relating in any way to the subject matter of this agreement. These disclosures are part of the consideration made by each party for entering into this agreement. 2. ADVICE OF COUNSEL. The Husband has employed and had the benefit or counsel of Jane Adams, Esquire, as his attorney. The Wife has employed and had the benefit or counsel of Lori Seratelli, Esquire, as her attorney. Each party has carefully and completely read this agreement and has been advised and is completely aware not only of its contents but of its legal effect. 3. SEPARATION. The parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intention and purpose of this agreement to set forth their respective rights and duties while they continue to live apart from each other. Neither party shall harass, annoy, injure, threaten, or interfere with the other party in any manner whatsoever. Each party may carry on and engage in any employment, profession, business or other activity as he or she may deem advisable. Neither parry shall interfere with the uses, ownership, enjoyment, or disposition of any property now owned and not specified herein or property hereafter acquired by the other. 4. SUBSEQUENT DIVORCE. The parties hereby acknowledge that Husband has filed a Complaint in Cumberland County, Pennsylvania, claiming that the marriage is irretrievably broken under the no-fault mutual consent provision of Section 3301(c) of the Pennsylvania Divorce Code. Wife hereby expresses her agreement that the marriage is irretrievably broken and expresses her intent to execute any and all affidavits or other documents necessary for the parties to obtain an absolute divorce pursuant to Section 3301(c) of the Divorce Code. The parties hereby waive all rights to request Court Ordered counseling under the Divorce Code. The provisions of this Agreement relating to equitable distribution of property of the parties are accepted by each parry as a final settlement for all purposes whatsoever, as contemplated by the Pennsylvania Divorce Code. Should a decree, judgment, or order of separation or divorce be obtained by either of the parties in this or any other state, country or jurisdiction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be affected in any way by any such 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 shall remarry. It is specifically agreed that a copy of this Agreement or the substance of the provisions thereof, may be incorporated by reference into any divorce, judgment, or decree. This incorporation shall not be regarded as a merger, it being the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties. 5. DATE OF EXECUTION. The "date of execution" or "execution date" of this agreement shall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the parry last executing this Agreement. All provisions of this agreement shall be effectuated by the parties within thirty (30) days of the execution date of this agreement unless otherwise specified within this agreement. 6. MUTUAL RELEASE OF ALL CLAIMS. HUSBAND and WIFE each do hereby mutually remise; release, quit-claim and forever discharge the other and the estate of the other, of and from any and all rights; titles, and interests, 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, or whatever nature and wheresoever situate, which she or he 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 curtesy, or claims in the nature of dower or curtesy of 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 the decease spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth, or territory of the United States, or any other country, or any rights which Wife may have or at any time hereafter have against the other for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs, expenses, or equitable distribution of marital property whether arising as a result of any 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. 7. WARRANTY OF DEBTS AND FUTURE OBLIGATIONS. Each party warrants that they have not contracted any debt or liability for the other or which the estate of the other party may be responsible or liable, and except only for the rights arising out of this agreement, neither party will hereafter incur any liability whatsoever for which the other party or the estate of the other party, will be liable. Each party agrees to indemnify or hold harmless from the other and against all future obligations of every kind incurred by them, including those for necessities. 8. OUTSTANDING JOINT DEBTS. (a) Wife agrees that the following debts are her own personal responsibility and therefore agrees to completely and finally pay on the following debts and obligations: Any and all obligations relating to the marital home including those owed to Citimortgage. (b) Husband agrees that the following debts are his own personal responsibility and therefore agrees to completely and finally pay on the following debts and obligations: The National City Bank Visa, The MBNA Visa, The Susquehanna Valley Credit Union Debt. Husband has completed Assumption of Debt documents regarding these loans which has effectively removed Wife from any obligation regarding these loans. Husband will provide written confirmation of the assumption of debt to wife upon his receipt of such documents. 9. EQUITABLE DIVISION OF MARITAL PROPERTY. The parties have attempted to distribute their marital property in a manner which conforms to the criteria set forth in 23 Pa.C.S.A. s3501 et. seq. and taking into account the following considerations: the length of the marriage, the age, health, station, amount, and sources of income, vocational skills, employability, estate, liabilities, and needs of each of the parties, the contribution of each parry to the education, training, or increased earning power of the other party; the opportunity for each party for future acquisitions 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 the marital property, including the contribution of each spouse as a homemaker; the value of the property set apart to each party; the standard of living the parties established during the marriage; and the economic circumstances of each party at the time the division of property is to become effective. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division is being effected without the introduction of outside funds or other property not constituting marital property. The division of property under this Agreement shall be in full satisfaction of all the marital rights of the parties. As such, the parties acknowledge that Husband or Wife's obligation to make the payments defined in this agreement shall not be subject to termination, discharge, or discontinuance in bankruptcy or for any other reason or by any Court or tribunal. Should Husband or Wife pursue and action in bankruptcy and be successful in extinguishing his obligation to pay any debts for which he has assumed sole obligation as set forth herein, he or she shall immediately be obligated to pay alimony to the other party in an amount equal to the monthly obligation on such debts that he or she otherwise had assumed and for which he had taken sole obligation and responsibility, plus an additional fifteen percent (15%) in consideration of the tax consequences associated with receipt of alimony. At the time of the implementation of this alimony award, which maybe made through the appropriate Domestic Relations of support office with the Court of Common Pleas of appropriate jurisdiction as Husband or Wife may select, such party shall then be responsible for any such debts extinguished through the other party's bankruptcy as described herein. 10. OTHER PERSONAL PROPERTY. Husband and Wife do hereby acknowledge that they have previously divided all their tangible personal property. Except as may otherwise be provided in this Agreement, Wife agrees that all of the property of Husband or in his possession shall be the sole and separate property of Husband; and Husband agrees that all of the property of Wife or in her possession shall be the sole and separate property of Wife. The parties do hereby specifically waive, release, renounce, and forever abandon whatever claim, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other. (a) Wife will retain the Muhlenkemp Fund of $300.00 (b) All joint savings accounts shall be closed and the proceeds divided equally. 11. MOTOR VEHICLES. With respect to the motor vehicles, owned by one or both of the parties, they agree as follows: (a) The Honda Passport shall be and remain the sole and exclusive property of Wife. (b) The Toyota Corolla shall be and remain the sole and exclusive property of Husband. The titles to the said motor vehicles shall be executed by the parties, if appropriate for effecting transfer as herein provided, within thirty days of the execution date of this Agreement, and said executed titles shall be delivered to the proper parties on the distribution date. Each party agrees to be solely responsible for the amounts presently due and owing against his or her respective automobiles. 12. REAL ESTATE. (a) HUSBAND and WIFE hold title as Tenants by the Entireties to the premises identified as 7 High Street, Boiling Springs, Cumberland County, Pennsylvania. The parties agree as follows with respect to the marital residence: (1) Wife shall retain all right, title and interest in the marital residence and shall refinance the mortgage obligation in her own name alone within five (5) years of this agreement. Within thirty days (30) of this agreement, and as soon as reasonably possible after the signing of this agreement, Husband shall execute a Deed transferring all right, title and interest in the marital home into Wife's name alone. Wife shall be responsible for all costs and filing fees associated with said refinancing and Deed transfer. If Wife is not able to refinance the mortgage obligation on the marital home, she will list the home for sale and take all actions necessary to sell the marital home. (2) As of the date of separation, and without regard to when bills for such items are incurred, received or due, Wife shall be solely responsible for all past, present, and future costs or liabilities associated with or attributable to maintaining the marital residence (except as provided herein), including but not limited to, the monthly mortgage obligation, all real estate taxes, water and sewer rents, gas, electric, and telephone service, homeowner's insurance, and gardening expenses and repairs, and Wife shall keep Husband and his successors, assigns, heirs, executors, and administrators indemnified and held harmless from any liability, cost or expense, including attorney's fees, which are incurred in connection with such costs and expenses. 13. MUTUAL WAIVER OF EMPLOYMENT BENEFITS. The parties agree to waive any and all rights they have in and to each other's employment benefits, including but not limited to both parties pensions and retirement plans and Incentive Savings Plans. The parties agree never to assume any claim to such benefits of the other at any time in the future. Wife hereby waive any and all interest in Husband's retirement benefit with his previous employers, including his retirements from Messiah and Harrisburg Public Schools. Wife will sign any document required to have her name removed from these benefits. 14. ALIMONY, CHILD SUPPORT, and LEGAL FEES. Other than as provided in this agreement, each parry hereby waives any right to spousal support, alimony, or alimony pendente lite, and each party agrees to be responsible for his or her own legal fees and expenses. (a) All alimony to be paid under this agreement shall terminate upon the recipient's death, remarriage or cohabitation with an unrelated person of the opposite sex. (b) Husband shall obtain a Life Insurance Policy in the amount of $250,000.00 and shall maintain such policy as long as alimony or child support payments are being made. Wife shall be listed as the sole irrevocable beneficiary of the policy as long as alimony and/or child support payments are being made by husband. (c) As of the date of the divorce decree, Husband agrees to treat all credits towards child support as zero. Husband shall write a letter to Domestic Relations and/or cooperate in any other documents they may require to effectuate this purpose. (d) Alimony shall be modifiable and the length and amount of alimony shall be subject to review based on a substantial change in the economic circumstances of either parry. (e) Immediately, upon entry of a Divorce Decree: (i) Husband shall pay Wife the amount of $300 per month in alimony. The payment will be due on the first of each month. The alimony will continue through May 2018. (ii) Husband and Wife agree that Husband shall pay Wife the amount of $1250 a month in child support. 15. INCOME TAX RETURNS. Husband and wife represent to each other that, other as provided herein, to the best of their knowledge all federal, state, and local taxes required to paid with during the marriage and during the periods covered by such tax returns have been paid. Husband agrees to pay in full all tax deficiencies incurred for the year 2003 by making arrangements directly with the IRS. 16. WAIVER OR MODIFICATION TO BE IN WRITING. No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties, and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 17. 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 further 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. 18. APPLICABLE LAW. The 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. 19. INTEGRATION. This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements or negotiations between them. There are no representations or warranties other than those expressly set forth herein. 20. OTHER DOCUMENTATION. Wife and Husband covenant and agree that they will forthwith execute any and all written instruments, assignments, releases, satisfactions, deeds, notes, or such other writings as may be necessary or desirable for the proper effectuation of this Agreement. 21. NO WAIVER OF DEFAULT. This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any default or breach of any provision hereof by construed as a waiver of any subsequent default or breach of the same or similar nature, not shall it be construed as a waiver or strict performance of any other obligations herein. 22. 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 provisions shall be stricken from this Agreement; and in all other respects, this Agreement shall be valid and continue in full force, effect, and operation. Likewise, the failure of any party to meet his or her obligations under 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. 23. BREACH. If either parry breaches any provisions of this agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, or seek other remedies or relief as may be available to him or her, and the party breaching this contract should be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this agreement. 24. INFORMED AND VOLUNTARY EXECUTION. Each parry to this agreement acknowledges that he or she is fully informed as to the facts relating to the subject matter of this agreement, is entering into this agreement voluntarily, free from fraud, undue influence, coercion or duress of any kind, has given careful thought to the making of this agreement, has carefully read each provision of this agreement, and fully and completely understands each provision of this agreement. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written: WITNESS: O,,d,c,) C- ANDREW C. VANGORDER Date: 17-')-1 05 COMMONWEALTH OF PENNSYLVANIA COUN. TY OF CUMBERLAND ):ss On this, the day of ?P pQ: yY)k '2005, before me, the undersigned officer, personally appeared ANDREW C. VANGORDER known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he/she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Public commission expires: NWEALTH OF PENNSYLVANIA Notarial Seal Jane Adams, Notary Public Carlisle Boro, CnmberIMA" County My Commission Expires Sept. 6, 2008 5 IE S. VANGORD R ?WIT? SS Date: COMMONWEALTH OF PENNSYLVANIA D ?'? L) P N G'W ):ss COUNTY OF CUMAOUAND On this, the ? N day of r 2008' before me, the undersigned officer, personally appeared STEPHANIE VANGORDER known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he/she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public My commission expires: SEAL NOTARIAL SEAL DEBRA A EVANGEUSiI Notary Publk SUSQUEHANNA TWP,DAUPHIN COUNTY My Commpafai Expires May 7, 2008 ANDREW C. VAN GORDER Plaintiff VS. STEPHANIE S. VAN GORDER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 04 - 4831 Civil Term ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following information to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under 0301(c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Via certified mail, restricted- delivery, delivered on: September 29, 2004. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: February 13, 2006. By Defendant: February 1, 2006. 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: February 13, 2006. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: February 13, 2006. Respectfully Submitted Date: N?? J e Adams, Esquire No. 79465 64 S. Pitt Street Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS n , OF CUMBERLAND COUNTY STATE OF PENNA. A dre w C VanGorder Plaintiff VERSUS Stephanie S. VanGorder, Defendant No. No. 2004 - 4831 Civil Term DECREE IN DIVORCE AND NOW, '1'y7,u vh I , X00(- , IT IS ORDERED AND DECREED THAT AND Andrew C. VanGorder Stephanie S. VanGorder ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, 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; the marriage settlement agreement which was executed February 2, 2006, and filed February 13, 2006, shall be incorporated and not merged into this Decree. BY THE COURT: ATTEST- J - PROTHONOTARY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4831 CIVIL TERM STIPULATION AND NOW come the parties, Plaintiff Stephanie VanGorder, by and through her attorney STEPHANIE S. VANGORDER, Plaintiff VS. ANDREW C. VANGORDER, Defendant Lori K. Serratelli, Esquire, and Defendant Andrew C. VanGorder, by and through his attorney, Jane Adams, Esquire, who agree and stipulate as follows: 1. An alimony Order shall be issued effective with the date of the Divorce Decree, payable on the first of each month, in the amount of $300.00 per month, payable through the Domestic Relations Office. 2. Said Order shall terminate with the last payment due May 2018. IN WITNESS WHEREOF, the parties' counsel have set their hands and seals this -f - day of r? , 2006. Lori KgSetratelli, Esquire Attorn6 for Plaintiff ms, Esquire for Defendant ms YM fil -n -.t tS> ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dirt. of CUMBERLAND Date of Order/Notice 03/20/06 Case Number (See Addendum for case summary) FmployerAvithholder's Federal FIN Number BAYLOR UNIVERSITY PO BOX 97042 WACO TX 76798-7042 186-40-2723 Employee/Obligor's Social Security Number 0463101392 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. $ 1, 708. 00 per month in current support $ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes ® no $ o. oo per month in current and past-due medical support $ 0 _ 00 per month for genetic test costs $ per month in other (specify) for a total of $ 1, 708.00 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: $ 394 .15 per weekly pay period. $ 798.31 per biweekly pay period (every two weeks). $ 854 . Elo per semimonthly pay period (twice a month). $ 1. 708. oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). 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. Date of Order: MAR 2 1 2006 DRO: R.J. Shadday Service Type m 648108122 0 Original Order/Notice 04-4831 CIVIL 0 Amended Order/Notice 917106744 O Terminate Order/Notice 841 S 2004 KE:VANGORDER, ANDREW C. Employee/Obligor's Name (Last, first, MI) BY THE COURT: Edward E, o, Judge Form EN-028 0618 No.: U)?D-W 5-0 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If heckeii you are required to provide a copy of this form to your employee. If yo r employee works in a state that is di erent from the state that issued this order, a copy must be provided to your employee even if the box is not checked. 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. 3. *-Reporting the-Paydate/Date of-WithhoicI You must report the paydate/date of withholding-wher -sending a payment.. The paydatef late ofwithhoiding-istire date vmvhieh-amount waswithheMirom-the-employee's wages-. You most comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/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 most 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. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 7411597530 EMPLOYEE'S/OBLIGOR'S NAME: VANGORDER. ANDREW C. EMPLOYEE'S CASE IDENTIFIER: 0463101392 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. Antidiscrimination: You are subject to a fine determined under State law for discharging an employeelobligor 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 more than the lesser of. 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee'slobligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWF). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. 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) 240-6248 or by internet www.chiIdsupport.state.pa.us Service Type M Page 2 of 2 OMB No.: 09700154 Form EN-028 Worker ID $ZATT ADDENDUM Summary of Cases on Attachment DefendanUObligor: VANGORDER, ANDREW C. PACSES Case Number 648108122 Plaintiff Name STEPHANIE S. VANGORDER Docket Attachment Amount 04-4831 CIVIL$ 300.00 Child(ren)'s Name(s): DOB PACKS Case Number 917106744 Plaintiff Name STEPHANIE S. VANGORDER Docket Attachment Amount 00841 S 2004 $ 1,408.00 Child(ren)'s Name(s): DOB PATRICK XAVIER VANGORDER 02/18/87 BRENDAN D. VANGORDER 01/03/92 KEEGAN E. VANGORDER 01/31/94 SEAN M. VANGORDER 12/1'.5/95 El 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(rer0's Name(s): DOB OIf 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. PACKS Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(rer0'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. PACKS Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB OIf checked, you are required to enroll the child(ren) Off checked, you are required to enroll the child(reN identified above in any health insurance coverage available identified above in any health insurance coverage available through the employee's/obligor's employment. through the employee's/obligor's employment. Addendum Form EN-028 Service Type M OMB No: 0970 0154 Worker ID $IATT ro.? ("_'? ca ? c : `ll r `- ??f. 3 n) "T? s4; c-n W i.-1 _ L.) C}7 lZ:r TVFI?I t,1?,k ? " ?Q06 STEPHANIE S. VANGORDER, Plaintiff VS. ANDREW C. VANGORDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4831 CIVIL TERM ORDER AND NOW, this z Y - day of rm a,..a , 2006, upon consideration of the foregoing Stipulation, it is hereby ORDERED and DECREED as follows: An alimony Order shall be issued effective with the date of the Divorce Decree, payable on the first of each month, in the amount of $300.00 per month, payable through the Domestic Relations Office. 2. Said Order shall terminate with the last payment due May 2018. 1 BY THE COURT: / J. v? ?.r 7 11 ORDERINOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of order/Notice 03/29/06 Case Number (See Addendum for case summary) EmployerAvithholdei s Federal EIN Number BAYLOR UNIVERSITY PO BOX 97042 WACO TX 76798-7042 186-40-2723 Employee/Obligor's Social Security Number 0463101392 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. $ _1 550_00 per month in current support $ o . 0 o per month in past-due support Arrears 12 weeks or greater? O yes ® no $ o . 00 per month in current and past-due medical support $ 0 . oo per month for genetic test costs $ per month in other (specify) for a total of $ 1, 550.00 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: $ 357.69 per weekly pay period. $ 715.3 e per biweekly pay period (every two weeks). $ 775. oo per semimonthly pay period (twice a month). $ 1. 550. oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). 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. Date of Order: MAR US 0 2006 DRO: R.J. Shadday Service Type m 648108122 04-4831 CIVIL 917106744 841 S 2004 O Original Order/Notice O Amended Order/Notice O Terminate Order/Notice RE: VANGORDER, ANDREW C. Employee/Obligor's Name (Last, First, MI) BY THE COURT: Edward E o Judge Form EN-028 OMB No., 0970-0154 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? Ifghecked you are required to provide a copy of this form to your employee. If your employee works in a state that is di erent from the state that issued this order, a copy must be providers to your employee even if the box is not checked. 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. 3.*-Reporting-the-Paydate/pate YVithfroMing:-You-mustreportthepaydate/date-ofwit Hingwhen-sending-thepayment. The- paydate/date-otwithhofdin" thedate-arrwhreli-a eemptoyee`s-wages You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/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. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 7411597530 EMPLOYEE'S/OBLIGOR'S NAME: VANGORDER. ANDREW C. EMPLOYEE'S CASE IDENTIFIER: 0463101392 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 employeelobligor 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 more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. §1673 (b)1; 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. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. I (.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 (717) 240-6248 or CARLISLE PA 17013 by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Service Type M oms No.: 0970-0154 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: VANGORDER, ANDREW C. PACSES Case Number 648108122 Plaintiff Name STEPHANIE S. VANGORDER Docket Attachment Amount 04-4831 CIVIL$ 300.00 Chlld(ren)'s Name(s): DOB PACSES Case Number 917106744 Plaintiff Name STEPHANIE S. VANGORDER Docket Attachment Amount 00841 S 2004 $ 1,250.00 Child(ren's Name(s): DOB BRENDAN D. VANGORDER 01/03/92 KEEGAN E. VANGORDER 01/31/94 SEAN M. VANGORDER 12/15/95 ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligors 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 $ 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'sfobligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ o.oo Children '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'slobligor'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) ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available identified above in any health insurance coverage available through the employee's/obligor's employment. through the employee's/obligor's employment. Addendum Form EN-028 Service Type M Worker ID $IATT OMB No, 09)P0154 ?-t ?, _ 'ii -t ?..... .? -t-.,?., .? :., alt ::J ?_s I ?? ??'-' ?.? T •' c J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA `n4rek) C h r? s?G,? ild?1 6A. Plaintiff o ? ? g Vs File No. 4to r1 ?an C' S e ?V,6rz?P,? IN DIVORCE efendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree inivorce dated 3o hereby elects to resume the prior surname of R I IBIS , and gives this written notice vo g his / her intention purs pr sions of 5 S. 704. Date: Signature CJ ` ign a of name be resumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF Cw,%berl" On the 1 akday of o'tre , 200_, before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. G? NOTAtQAI SEAL Prothonotary or Notary Public GKISLE C M? BqL4W ( ? W COMMISSION EXPIREB AVW 4, 2Qf Q n? C ~_V n N fI C.. as ??a 0 STEPHANIE C. VAN GORDER KRIBS, Plaintiff V. ANDREW C. VAN GORDER Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-4831 : CIVIL ACTION - LAW NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIM SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. 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 LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 NOTICA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presenter una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y pueda entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 STEPHANIE C. VAN GORDER KRIBS, Plaintiff V. ANDREW C. VAN GORDER Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4831 CIVIL ACTION - LAW COMPLAINT AND NOW, this a!? y f?MQhtL , 2007, comes Plaintiff, Stephanie C. Van Gorder Kribs, by and through her counsel Mark A. Mateya, Esquire, and in support of her Complaint avers the following: 1. Plaintiff is Stephanie C. Van Gorder Kribs, who currently resides at 7 High Street, Boiling Springs, Cumberland County, Pennsylvania 17007. 2. Defendant is Andrew C. Van Gorder, who currently resides at 2417 Wooded Acres Drive, Waco, Texas 76710. BREACH OF CONTRACT 3. Plaintiff and Defendant were divorced on March 7, 2006, in the County of Cumberland in the Commonwealth of Pennsylvania, docket No. 2004-4831 Civil Term. A copy of the Divorce Decree is attached hereto as Exhibit "A" and is incorporated herein. 4. A Marriage Settlement Agreement was entered into by the Plaintiff and Defendant herein, which Marriage Settlement Agreement was incorporated into and became part of the Divorce Decree. A copy of the Marriage Settlement Agreement is attached hereto as Exhibit "B" and is incorporated herein. 5. Plaintiff herein has fulfilled all of her requirements according to the Marriage Settlement Agreement. 6. Defendant herein has not complied with Paragraph 8 Outstanding Joint Debt, subparagraph (b) and continues to refuse to comply with all of the obligations thereunder by paying the following debts and obligations: National City Bank Visa, and the MBNA Visa debt. 7. Plaintiff has repeatedly requested that Defendant comply with the above-referenced obligations under the Marriage Settlement Agreement. 8. Defendant has made no attempt to comply with the requirements of Paragraph 8 Outstanding Joint Debt, subparagraph (b) and continues to refuse to comply with all of the obligations thereunder by paying the following debts and obligations: National City Bank Visa, and MBNA Visa. 9. Defendant has not obtained a life insurance policy in accordance to paragraph 14(b) of the Marriage Settlement Agreement, which states in pertinent part:"Husband shall obtain a Life Insurance Policy in the amount of $250,000.00 and shall maintain such policy as long as alimony or child support payments are [due]. Wife shall be listed as the sole irrevocable beneficiary of the policy as long as alimony and/or child support payments are [due] by husband." 10. Plaintiff has expended legal fees to date of approximately $500.00, and anticipates having to expend additional legal fees if a hearing on this issue is required in front of this Honorable Court. THIS SPACE INTENTIONALLY LEFT BLANK IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Andrew C. VanGorder, Plaintiff No. 2004 - 4831 Civil Term NO. VERSUS Stephanie S. VanGorder, Defendant DECREE IN DIVORCE AND NOW, ?'hacyli f r , -200(- , IT IS ORDERED AND Andrew C. VanGorder DECREED THAT AND Stephanie S. VanGorder ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,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; the marriage settlement agreement which was executed February 2, 2006, and filed February 13, 2006, shall be incorporated and not merged into this Decree. BY THE COURT: ATTEST' J. PROTHONOTARY ANDREW C. VANGORDER, Plaintiff/Respondent vs. STEPHANIE S. VANGORDER, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4831 CIVIL TERM CIVIL ACTION - LAW W DIVORCE MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT, made thisDh ? day of 2006, by and between, STEPHANIE S. VANGORDER, of Boiling Springs, Cumberland County, Pennsylvania, hereinafter referred to as "WIFE", and ANDREW C. VANGORDER, commonly known as CHRIS VANGORDER, of Waco, Texas, hereinafter referred to as "HUSBAND". WITNESSETH: WHEREAS, Husband and Wife were lawfully married on July 2, 1983, in Flint, Michigan, and; WHEREAS, there were four children born of this marriage; WHEREAS, differences, disputes, and difficulties have arisen between the parties and it is the intention of Husband and Wife to live separate and apart for the rest of their natural lives, and the parties desire to settle their respective financial property rights and obligations as between each other, including the settling of all matters between them relating to ownership and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present, and future support, alimony, and/or maintenance of Husband or Wife; and in general, the settling of any and all possible claims by one against the other or against their respective estates; NOW, THEREFORE, Wife and Husband, each intending to be legally bound, hereby covenant and agree as follows: 1. FULL DISCLOSURE OF ASSETS. Each party warrants that he or she has made a full and fair disclosure of income, assets, and their valuation prior to the execution of this Agreement as well as any other fact relating in any way to the subject matter of this agreement. These disclosures are part of the consideration made by each party for entering into this agreement. 2. ADVICE OF COUNSEL. The Husband has employed and had the benefit or counsel of Jane Adams, Esquire, as his attorney. The Wife has employed and had the benefit or counsel of Lori Seratelli, Esquire, as her attorney. Each party has carefully and completely read this agreement and has been advised and is completely aware not only of its contents but of its legal effect. 3. SEPARATION. The parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intention and purpose of this agreement to set forth their respective rights and duties while they continue to live apart from each other. Neither party shall harass, annoy, injure, threaten, or interfere with the other party in any manner whatsoever. Each party may carry on and engage in any employment, profession, business or other activity as he or she may deem advisable. Neither party shall interfere with the uses, ownership, enjoyment, or disposition of any property now owned and not specified herein or property hereafter acquired by the other. 4. SUBSEQUENT DIVORCE. The parties hereby acknowledge that Husband has filed a Complaint in Cumberland County, Pennsylvania, claiming that the marriage is irretrievably broken under the no-fault mutual consent provision of Section 3301(c) of the Pennsylvania Divorce Code. Wife hereby expresses her agreement that the marriage is irretrievably broken and expresses her intent to execute any and all affidavits or other documents necessary for the parties to obtain an absolute divorce pursuant to Section 3301(c) of the Divorce Code. The parties hereby waive all rights to request Court Ordered counseling under the Divorce Code. The provisions of this Agreement relating to equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever, as contemplated by the Pennsylvania Divorce Code. Should a decree, judgment, or order of separation or divorce be obtained by either of the parties in this or any other state, country or jurisdiction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be affected in any way by any such 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 shall remarry. It is specifically agreed that a copy of this Agreement or the substance of the provisions thereof, may be incorporated by reference into any divorce, judgment, or decree. This incorporation shall not be regarded as a merger, it being the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties. 5. DATE OF EXECUTION. The "date of execution" or "execution date" of this agreement shall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. All provisions of this agreement shall be effectuated by the parties within thirty (30) days of the execution date of this agreement unless otherwise specified within this agreement. 6. MUTUAL RELEASE OF ALL CLAIMS. HUSBAND and WIFE each do hereby mutually remise; release, quit-claim and forever discharge the other and the estate of the other, of and from any and all rights; titles, and interests, 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, or whatever nature and wheresoever situate, which she or he 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 curtesy, or claims in the nature of dower or curtesy of 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 the decease spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth, or territory of the United States, or any other country, or any rights which Wife may have or at any time hereafter have against the other for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs, expenses, or equitable distribution of marital property whether arising as a result of any 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. 7. WARRANTY OF DEBTS AND FUTURE OBLIGATIONS. Each party warrants that they have not contracted any debt or liability for the other or which the estate of the other party may be responsible or liable, and except only for the rights arising out of this agreement, neither party will hereafter incur any liability whatsoever for which the other party or the estate of the other party, will be liable. Each party agrees to indemnify or hold harmless from the other and against all future obligations of every kind incurred by them, including those for necessities. 8. OUTSTANDING JOINT DEBTS. (a) Wife agrees that the following debts are her own personal responsibility and therefore agrees to completely and finally pay on the following debts and obligations: Any and all obligations relating to the marital home including those owed to Citimortgage. (b) Husband agrees that the following debts are his own personal responsibility and therefore agrees to completely and finally pay on the following debts and obligations: The National City Bank Visa, The MBNA Visa, The Susquehanna Valley Credit Union Debt. Husband has completed Assumption of Debt documents regarding these loans which has effectively removed Wife from any obligation regarding these loans. Husband will provide written confirmation of the assumption of debt to wife upon his receipt of such documents. 9. EQUITABLE DIVISION OF MARITAL PROPERTY. The parties have attempted to distribute their marital property in a manner which conforms to the criteria set forth in 23 Pa.C.S.A. s3501 et. seq. and taking into account the following considerations: the length of the marriage, the age, health, station, amount, and sources of income, vocational skills, employability, estate, liabilities, and needs of each of the parties, the contribution of each party to the education, training, or increased earning power of the other party; the opportunity for each party for future acquisitions 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 the marital property, including the contribution of each spouse as a homemaker; the value of the property set apart to each party; the standard of living the parties established during the marriage; and the economic circumstances of each party at the time the division of property is to become effective. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division is being effected without the introduction of outside funds or other property not constituting marital property. The division of property under this Agreement shall be in full satisfaction of all the marital rights of the parties. As such, the parties acknowledge that Husband or Wife's obligation to make the payments defined in this agreement shall not be subject to termination, discharge, or discontinuance in bankruptcy or for any other reason or by any Court or tribunal. Should Husband or Wife pursue and action in bankruptcy and be successful in extinguishing his obligation to pay any debts for which he has assumed sole obligation as set forth herein, he or she shall immediately be obligated to pay alimony to the other party in an amount equal to the monthly obligation on such debts that he or she otherwise had assumed and for which he had taken sole obligation and responsibility, plus an additional fifteen percent (15%) in consideration of the tax consequences associated with receipt of alimony. At the time of the implementation of this alimony award, which may be made through the appropriate Domestic Relations of support office with the Court of Common Pleas of appropriate jurisdiction as Husband or Wife may select, such party shall then be responsible for any such debts extinguished through the other party's bankruptcy as described herein. 10. OTHER PERSONAL PROPERTY. Husband and Wife do hereby acknowledge that they have previously divided all their tangible personal property. Except as may otherwise be provided in this Agreement, Wife agrees that all of the property of Husband or in his possession shall be the sole and separate property of Husband; and Husband agrees that all of the property of Wife or in her possession shall be the sole and separate property of Wife. The parties do hereby specifically waive, release, renounce, and forever abandon whatever claim, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other. (a) Wife will retain the Muhlenkemp Fund of $300.00 (b) All joint savings accounts shall be closed and the proceeds divided equally. 11. MOTOR VEHICLES. With respect to the motor vehicles, owned by one or both of the parties, they agree as follows: (a) The Honda Passport shall be and remain the sole and exclusive property of Wife. (b) The Toyota Corolla shall be and remain the sole and exclusive property of Husband. The titles to the said motor vehicles shall be executed by the parties, if appropriate for effecting transfer as herein provided, within thirty days of the execution date of this Agreement, and said executed titles shall be delivered to the proper parties on the distribution date. Each party agrees to be solely responsible for the amounts presently due and owing against his or her respective automobiles. 12. REAL ESTATE. (a) HUSBAND and WIFE hold title as Tenants by the Entireties to the premises identified as 7 High Street, Boiling Springs, Cumberland County, Pennsylvania. The parties agree as follows with respect to the marital residence: (1) Wife shall retain all right, title and interest in the marital residence and shall refinance the mortgage obligation in her own name alone within five (5) years of this agreement. Within thirty days (30) of this agreement, and as soon as reasonably possible after the signing of this agreement, Husband shall execute a Deed transferring all right, title and interest in the marital home into Wife's name alone. Wife shall be responsible for all costs and filing fees associated with said refinancing and Deed transfer. If Wife is not able to refinance the mortgage obligation on the marital home, she will list the home for sale and take all actions necessary to sell the marital home. (2) As of the date of separation, and without regard to when bills for such items are incurred, received or due, Wife shall be solely responsible for all past, present, and future costs or liabilities associated with or attributable to maintaining the marital residence (except as provided herein), including but not limited to, the monthly mortgage obligation, all real estate taxes, water and sewer rents, gas, electric, and telephone service, homeowner's insurance, and gardening expenses and repairs, and Wife shall keep Husband and his successors, assigns, heirs, executors, and administrators indemnified and held harmless from any liability, cost or expense, including attorney's fees, which are incurred in connection with such costs and expenses. 13. MUTUAL WAIVER OF EMPLOYMENT BENEFITS. The parties agree to waive any and all rights they have in and to each other's employment benefits, including but not limited to both parties pensions and retirement plans and Incentive Savings Plans. The parties agree never to assume any claim to such benefits of the other at any time in the future. Wife hereby waive any and all interest in Husband's retirement benefit with his previous employers, including his retirements from Messiah and Harrisburg Public Schools. Wife will sign any document required to have her name removed from these benefits. 14. ALIMONY, CHILD SUPPORT, and LEGAL FEES. Other than as provided in this agreement, each party hereby waives any right to spousal support, alimony, or alimony pendente lite, and each party agrees to be responsible for his or her own legal fees and expenses. (a) All alimony to be paid under this agreement shall terminate upon the recipient's death, remarriage or cohabitation with an unrelated person of the opposite sex. (b) Husband shall obtain a Life Insurance Policy in the amount of $250,000.00 and shall maintain such policy as long as alimony or child support payments are being made. Wife shall be listed as the sole irrevocable beneficiary of the policy as long as alimony and/or child support payments are being made by husband. (c) As of the date of the divorce decree, Husband agrees to treat all credits towards child support as zero. Husband shall write a letter to Domestic Relations and/or cooperate in any other documents they may require to effectuate this purpose. (d) Alimony shall be modifiable and the length and amount of alimony shall be subject to review based on a substantial change in the economic circumstances of either party. (e) Immediately, upon entry of a Divorce Decree: (i) Husband shall pay Wife the amount of $300 per month in alimony. The payment will be due on the first of each month. The alimony will continue through May 2018. (ii) Husband and Wife agree that Husband shall pay Wife the amount of $1250 a month in child support. 15. INCOME TAX RETURNS. Husband and wife represent to each other that, other as provided herein, to the best of their knowledge all federal, state, and local taxes required to paid with during the marriage and during the periods covered by such tax returns have been paid. Husband agrees to pay in full all tax deficiencies incurred for the year 2003 by making arrangements directly with the IRS. 16. WAIVER OR MODIFICATION TO BE IN WRITING. No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties, and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 17. 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 further 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. 18. APPLICABLE LAW. The 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. 19. INTEGRATION. This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements or negotiations between them. There are no representations or warranties other than those expressly set forth herein. 20. OTHER DOCUMENTATION. Wife and Husband covenant and agree that they will forthwith execute any and all written instruments, assignments, releases, satisfactions, deeds, notes, or such other writings as may be necessary or desirable for the proper effectuation of this Agreement. 21. NO WAIVER OF DEFAULT. This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any default or breach of any provision hereof by construed as a waiver of any subsequent default or breach of the same or similar nature, not shall it be construed as a waiver or strict performance of any other obligations herein. 22. 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 provisions shall be stricken from this Agreement; and in all other respects, this Agreement shall be valid and continue in full force, effect, and operation. Likewise, the failure of any party to meet his or her obligations under 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. 23. BREACH. If either party breaches any provisions of this agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, or seek other remedies or relief as may be available to him or her, and the party breaching this contract should be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this agreement. 24. INFORMED AND VOLUNTARY EXECUTION. Each party to this agreement acknowledges that he or she is fully informed as to the facts relating to the subject matter of this agreement, is entering into this agreement voluntarily, free from fraud, undue influence, coercion or duress of any kind, has given careful thought to the making of this agreement, has carefully read each provision of this agreement, and fully and completely understands each provision of this agreement. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written: WITNESS: ANDREW C. VANGORDER Date: `'Z - Z--q - COMMONWEALTH OF PENNSYLVANIA ):SS COUN. TY OF CUMBERLAND, ) On this, the day of 2005, before me, the undersigned officer, personally appeared ANDREW C. VANGORDER known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he/she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand an Afficial seal. Public N4 commission expires: S&GONWEALTH OF PENNSYLVANIA Notarial Seal Jane Adams, Notary Public Carlisle Boro, Cumberlan^ County i My Commission Expires Sept. 6, 2008 WI ESS '?,__. Date: COMMONWEALTH OF PENNSYLVANIA COUNTY OFLUMBERtA-ND ) y , 2005; before me, the undersigned officer, On this the day of personally appeared STEPHANIE/e. VANGORDER known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he/she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public My commission expires: SEAL NOTARIAL SEAL DEBRA A EVANGEUSTI Notary Public SUSQUEHANNA TWPDAUPHIN COUNTY My Commission Expires May 7, 2008 T . - 1 I... ?? ? ?• ? /..-ls 1 v .?J I 6 ANDREW C. VANGORDER, Plaintiff V. STEPHANIE S. KRIBS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CASE NO. 04-4831 : CIVIL ACTION - LAW AFFIDAVIT OF SERVICE AND NOW, this 18th day of April, 2007, comes Mark A. Mateya, Esquire, Attorney for Plaintiff, who, being duly sworn according to law, deposes and says that: 1. A Complaint for Breach of Contract was filed to the above term and number on March 29, 2007. 2. On March 31, 2007, a certified copy of the Complaint was sent to the Defendant via certified mail, restricted delivery, return receipt requested pursuant to Pa. R.C.P. 1920.4. 3. On March 31, 2007, a certified copy of the Complaint was set to the Defendant via first class mail, postage prepaid. A copy of the Certificate of Mailing is attached hereto as Exhibit `A' and is incorporated herein by reference. 4. On or about April 17, 2007, undersigned counsel for Plaintiff received the return receipt card signed by the Defendant on or about April 5, 2007. Said receipt is attached hereto as Exhibit "B" and is incorporated herein by reference. Respectfully submitted, '4 k -LI: -7 Mark A. Mateya, Esq ' e Attorney I.D. No. 78931 P.O. Box 127 Boiling Springs, PA 17007 (717) 241-6500 (717) 241-3099 Fax Attorney for Plaintiff S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: -4A r-K A ?1 RT?ya PO -BOX- 1A11 BolL j.vG SPRI,)95 A 1700'/ One piece of ordinary mail addressed to: kv-DkEy) C Yak L?EI? A411 'NOVb E-b l ck,,:-S -DR I vu WA P_ '7 (n 7/0 PS Form 3817, Mar. 1989 rT N ? M ?C D J 0 pC :13M 2 V c w'.1 1> C V) t j A a: K;c CD L7 G cn cn r+ M 1 Postal .? L n CERTIFIED MAILT. RECEIPT Q' (Domestic Only No Insurance Co vera e Provided M , g ) m stage O Cerfi ied Fee $ ?' 1Ic p7 t? O Return Rede t F ic p ee (Endorsement Required) + t : ' • '.j Hers-/, ° Ln (Endorsee Delivent Requir dj cc ° Total Postage & Fees ?'. ?2 nl-il,i C M ° sent ' 10 L ?Ek . I!7 .. C -- ---------- - f: state, z, Joo -.-AL L FS -D ... . _....-- • Complete kerns 1. 2, and & Also Complete A. Meet 4 If Restricted Delivery is desired. ant x ¦ P* t your name and address on the reverse ? Addt.s... so that we can return the card to you. ¦ Mach this card to the back of the mailpieC^ B. ReoeNed by (Pdnted Name) C. Date of D*4wy or on the front ff space permits. 1. Artlde Addressed to. D. Is delivery address dUfwwd from Item 1? ? Yes A a-bk E:U) e. VA A) N YES, enter delivery No ,J s a??7 'VaoD?? Ac eus ?. APR - z lP -9?, o O Registered for Mercltartdlq ? Insured fvlap O . 4. Restricted DWWery? (Extra Fee) Yes 2. Arftle Number (1fen Wfromswviwkkw 7003 0500 0004 2330 3956 PS Form 3811, February 2004 Domestic Retum Recelpt 1025954)2-WI640 Laserfiche WebLink Page 1 of 1 rn r-a ??II CCCC ? X ? 1'3 : K ANDREW C. VAN GORDER, Plaintiff VS. STEPHANIE C. VAN GORDER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 04 - 4831 Civil Term : ACTION IN DIVORCE ANSWER TO PLAINTIFF'S COMPLAINT 1. Admitted, Plaintiff is Stephanie C. Van Gorder Kribs, who currently resides at 7 High Street, Boiling Springs, Cumberland County, Pennsylvania. 2. Admitted, Defendant is Andrew C. Van Gorder, who currently resides at 2417 Wooded Acres Drive, Waco, Texas, 76710. 3. Admitted. Plaintiff and Defendant were divorced on March 7, 2006 under the above- captioned docket number. 4. Admitted. 5. Denied. Plaintiff has not complied under section 17, of the agreement, which provides that the parties shall mutually cooperate and take all steps that the other parry may require to effectuate the agreement. 6. Denied. Defendant has complied with the requirements of Paragraph 8 of the marriage settlement agreement to the best of his ability and has taken all reasonable steps to satisfy these debts to the best of his ability. Husband has been prevented from paying off all debts in full because the debts are in Wife's name and Wife refuses to give consent for Husband to contact the Creditor directly to obtain information about the debt or negotiate a reduced one time payment. 7. Admitted. 8. Denied. Defendant has made many attempts to comply with the requirements of Paragraph 8 of the marriage settlement agreement to the best of his ability and has taken all reasonable steps to satisfy these debts to the best of his ability. Husband was prevented from paying off all debts in full because debts are in Wife's name and Wife refuses to give consent for Husband to contact the Creditor directly to obtain information about the debt or negotiate a reduced one time payment. 9. Denied. Defendant has taken all actions necessary and which could be reasonably expected to obtain multiple life insurance policies and currently has ample life insurance in the amount required by the marriage settlement agreement. 10. Defendant has no personal knowledge as to Plaintiff s fees. Strict proof is demanded. Defendant does not believe he should be liable for Plaintiffs fees due to his compliance with the agreement. Respectfully submitted, Date: e Adams, Esquire No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF %I ATTORNEY VERIFICATION Undersigned counsel, Jane Adams, Esquire, hereby verifies and states that: 1. She is the Attorney of record for Andrew C. Van Gorder. 2. Andrew C. Van Gorder currently resides in Waco, Texas. 3. Andrew C. Van Gorder has reviewed the Answer via electronic communications. 4. She is authorized to make this verification on his behalf. 5. The facts set forth in the foregoing response are true and correct to her to the best of her knowledge, information, and belief 6. She is aware that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Respectfully submitted, Date: a? Adams, Esquire C(f Pitt St. Carlisle, Pa. 17013 Attorney for Andrew C. Van Gorder + ` %& CERTIFICATE OF SERVICE AND NOW, this April 23, 2007, I, Jane Adams, Attorney for Andrew. C. Van Gorder, hereby certify that a copy of Defendant's ANSWER has been duly served upon the Plaintiff Counsel by placing such in the custody of the United States Postal Service, via certified mail, postage pre-paid addressed to: Mark A. Mateya, Esquire P.O. Box 127 Boiling Springs, Pa. 17007 ATTORNEY FOR PLAINTIFF J Adams, Esquire . No. 79465 South Pitt St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR DEFENDANT C ? <. c ?? < G.} r n Q Q C STEPHANIE C. VAN GORDER KRIBS, Plaintiff V. ANDREW C. VAN GORDER Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-4831 : CIVIL ACTION - LAW NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIM SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. 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 LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 NOTICA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y pueda entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 STEPHANIE C. VAN CORDER KRIBS, Plaintiff V. ANDREW C. VAN GORDER Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4831 CIVIL ACTION - LAW FIRST AMENDED COMPLAINT Qi _ AND NOW, this o .? day of , 2007, comes Plaintiff, Stephanie C. Van Gorder Kribs, by and through her counsel Mark A. Mateya, Esquire, and in support of her Complaint avers the following: 1. Petitioner reaffirms paragraphs one through nine of the Complaint in Breach of Contract. 10. Defendant has made no attempt to comply with the requirements of Paragraph 15 Income Tax Returns and continues to refuse to comply with all of the obligations thereunder by paying in full all tax deficiencies incurred for the year 2003. 11. Plaintiff had her personal tax refund intercepted by the IRS as a result of the 2003 tax bill still being due and owning and not having been satisfied by Defendant, per paragraph 15 of the Marriage Settlement Agreement. Please see the notice from the Department of Treasury attached hereto as Exhibit "A" which is incorporated herein by reference. 12. Defendant has made no attempt to comply with the requirements of Paragraph 14(b) regarding Life Insurance. Defendant has not obtained a Life Insurance Policy as agreed upon in Paragraph 14(b). 13. Plaintiff has expended additional legal fees to date of approximately an additional $500.00 for a total of $1,000.00, and anticipates having to expend additional legal fees if a hearing on this issue is required in front of this Honorable Court. J WHEREFORE Plaintiff respectfully requests that this Honorable Court issue an Order holding the Defendant in Breach of Contract and ordering Defendant to pay and keep his obligations according to the Marriage Settlement Agreement as set forth more fully in the Complaint and the First Amended Complaint and to reimburse Plaintiff for her reasonable legal expenses in filing this legal action. Date: 17? /'C? Respectfully submitted, V`'LA L'qk: Mark A. Mateya, Esquir Post Office Box 127 Boiling Springs, PA 17007 (717) 241-6500 (717) 241-3099 FAX VERIFICATION . MARK A. MATEYA, ESQUIRE, verifies that he is the attorney and agent for the Plaintiff herein, that the Plaintiffs verification cannot be obtained within the time allowed for the filing of this pleading, that as attorney for the Plaintiff, he has sufficient knowledge and information concerning the contents of the within document and that the facts set forth in the foregoing are true and correct to the best of his knowledge, information and belief. He understands that false statements made therein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. r MARK A. MATEY SQUIRE Dated: Z?l f Depanirento'.::...reasurv Internal Revenue Seri-ice f Andov% M.A 1:55111-h035 133462.317118.0415.010 1 AT 0.308 694 Ii.dIIIIfill I'MIIIH16111111is IIIII `F STEPHANIE S VAN GORDER 1 7 _HIGH_ST BOILING SPRGS PA 17007--9201076 62 IVI dJJl Jl it lll;C. GJ11: 1-800-829-0922 Your Caller Il): 288925 Notice Number: C1142 Date: March 26, 2007 Taxpayer Identification Number: 444-76-0562 Tax Form: 1040 Tax Fear: December 31, 2006 Overpaid Tax Applied to Other Federal Taxes Owed on Secondary Social Security Number Our records showyouu owed other federal taxes under Social Security Number 186-40-2723. therefore S 1,662.85 of the overpaid tax on your tax return for the above year has been applied to the unpaid amount.- '1-he nsures below show the amount of any refund due to you. If so, a check will be sent to you for the rota. amount due if it is more than S 1 and you owe no other obligations. However, if the amount due to you is less than S 1, it will be sent to you only if you ask for it. Tax Statement Your Overpaid Tax on Return 55,531.00 Amount of Overpaid Tax Applied S1,662.85 Amount to be Applied to Other Obligations, Refiuided, or Applied to Your Estimated Tax 53,868.15 If you are due a refund from the Internal Revenue Service, your check will be mailed in C to 8 weeks. Any interest clue you will be added. How Your Overpaid Taxes were Applied Social Security Number Form(s) Tax Period(s) Amount Applied 1Q4?? Decernber 1, 2-003 S1,66? -YAW This is not a bill. You may receive another notice in the next few weeks. The foilowins2 information may pertain to you if you are currently married or were previously married. Did we use your refund to pay for income taxes that you and a former (or current) spouse owe? If you file a claim, you ma}. be eligible to receive relief from having to pay your former (or current) spouse's income tax debt. A successful claim for relief could change the tax you have to pay. You may not owe anything at all. You could receive your refund or other payments back. Pa¢e I . . CERTIFICATE OF SERVICE I, hereby certify that I have served a copy of the foregoing First Amended Complaint on the following person(s) by depositing a true and correct copy of the same in the United States Mail, first class, postage prepaid, at Boiling Springs, Cumberland County, Pennsylvania addressed to: Jane Adams, Esquire 36 South Pitt Street Carlisle Pa 17013 Dated: - 2 _LJ,k 4t Mark A. Mateya, Esqu' P.O. Box 127 Boiling Springs, PA 17007 (717) 241-6500 (717) 241-3099 Fax ?v m p 33 8 I IL ANDREW C. VAN GORDER, Plaintiff vs. STEPHANIE C. VAN GORDER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 04 - 4831 Civil Term ACTION IN DIVORCE ANSWER TO PLAINTIFF'S FIRST AMENDED COMPLAINT 1. Defendant reaffirms paragraphs one through 9. of the Answer to Plaintiff s Complaint in Breach of Contract. 10. Denied. Defendant has been attempting to comply with all relevant provisions in Section 15 of the marriage settlement agreement, and is currently working with the IRS to rectify all outstanding taxes for the years covered by the marriage settlement agreement. 11. It is admitted that Plaintiff had her personal tax refund intercepted by the IRS; however, Defendant has no specific or detailed knowledge as to the cause or reason for the interception, other than as was recently provided in Plaintiff s Exhibit A, which is a letter from the IRS. 12. Denied. Defendant has obtained Life Insurance as required by the marriage settlement agreement. 13. Defendant has no knowledge as to Plaintiff s legal fees and denies liability for such fees. Strict proof is demanded. Defendant does not believe he should be liable for Plaintiffs fees due to his compliance with the agreement. Respectfully submitted, Date: Jhne Adams, Esquire D. No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF 1 ATTORNEY VERIFICATION Undersigned counsel, Jane Adams, Esquire, hereby verifies and states that: 1. She is the Attorney of record for Andrew C. Van Gorder. 2. Andrew C. Van Gorder currently resides in Waco, Texas. 3. She is authorized to make this verification on his behalf. 4. The facts set forth in the foregoing response are true and correct to her to the best of her knowledge, information, and belief. 5. She is aware that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Respectfully submitted, Date: j.e?A d ams, Esquire Pitt St. Carlisle, Pa. 17013 Attorney for Andrew C. Van Gorder ? ? -- -,- -? r _ ? ,,? ti? ? -= , :? r?? ? ?? '_, r.? :< :? ?.- STEPHANIE C. VAN GORDER KRIBS, Plaintiff V. ANDREW C. VAN GORDER Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4831 CIVIL ACTION - LAW PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Mark A. Mateya, Esquire, counsel for the Plaintiff in the above action, respectfully represents that: 1. The above-captioned action is at issue. 2. The claim of Plaintiff in the action is $ I, ost o 9/The counterclaim of the defendant in the action is $ The following attorneys are interested in the case as counsel or are otherwise disqualified to sit as arbitrators: 17A?r A-b A ms WHEREFORE, your Petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. AND NOW, as prayed for. Respectfully submitte , ORDER OF COURT !viv, ?C, k 2007, in consideration of the foregoing petition, Esq., and , Esq., and Esq., are appointed arbitrators in the above captioned action BY THE COURT, J. ;' ? r.v "u'^+ h"'? °"r~ } ?r t . ? ? ?? _ STEPHANIE C. VAN GORDER KRIBS, Plaintiff V. ANDREW C. VAN GORDER Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-4831 : CIVIL ACTION - LAW PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Mark A. Mateya, Esquire, counsel for the Plaintiff in the above action, respectfully represents that: 1. The above-captioned action is at issue. 2. The claim of Plaintiff in the action is $ r/ 0s/. YJ7 The counterclaim of the defendant in the action is $ The following attorneys are interested in the case as counsel or are otherwise disqualified to sit as arbitrators: 17A?ur AbAM6 WHEREFORE, your Petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitte , ORDER OF COURT ! AND NOW, oZ , 2007, in consideration of the foregoing petition, all Alk of . Esq., and J sq., and Esq., are appointed arbitrators in the above captioned action as prayed for. BY CCouZ2 lvl? V ? d CE 77, `E C\f f? R Z) - Q DO STEPHANIE C. VAN GORDER KRIBS, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ANDREW C. VAN GORDER, DEFENDANT 04-4831 CIVIL TERM ORDER OF COURT AND NOW, this day of August, 2007, the appointment of a Board of Arbitrators in the above-captioned case, IS VACATED. Edward L. Schorpp, Esquire, Chairman, shall be paid the sum of $50.00. Y Edward L. Schor Esquire pp, Court Administrator sal mooltd 0D101 1 C -D az - I - `% 10 STEPHANIE C. VAN GORDER IN THE COURT OF COMMON PLEAS KRIBS, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. No. 04 - 4831 Civil Term ANDREW C. VAN GORDER, CIVIL ACTION - LAW. Defendant STIPULATION 1164 THIS AGREEMENT, made this day of U , 2007, by and between, STEPHANIE C. KRIBS, of Boiling Springs, Cumberland County, Pennsylvania, hereinafter referred to as "WIFE", and ANDREW C. VANGORDER, commonly known as ANDREW C. VAN GORDER, of Waco, Texas, hereinafter referred to as "HUSBAND". WITNESSETH: WHEREAS, Husband and Wife were lawfully married on July 2, 1983, in Flint, Michigan, and were divorced on March 7, 2006; and WHEREAS, a marriage settlement agreement was executed by the parties on February 2, 2006; and WHEREAS,Wife filed a Complaint on March 28, 2007 under the above-captioned docket number; NOW THEREFORE, Wife and Husband, each intending to be legally bound, hereby covenant and agree as follows: 1. Husband has obtained life insurance as provided in the marriage settlement agreement. Husband has provided written proof of the beneficiary designation on his insurance policies to Wife's attorney. 2. Husband has satisfied all debts as provided under the marriage settlement agreement. 3. Husband has fully compensated Wife for all tax deficiencies incurred. r r 4. Each party shall remain responsible for their own attorney's fees. 5. No further payment is due from Husband to Wife. 6. Husband and Wife do hereby release all claims asserted under this matter. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written: - S: d'a e Adams, Esquire 6 S. Pitt St. arlisle, Pa. 17013 (717) 245-8508 Attorney for Husband. Andrew C. Van der sband. Date: I d l ?? l0 Mark A. Mateya, squire P.O. Box 127 Boiling Springs, Pa. 17007 (717) 241-6500 Attorney for Wife. Date: 10 1 -')1 r /0 -) C -n C p ---t ---r m try' % w 7 C G cn cr,j ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 04-4831 CIVIL State Commonwealth of Pennsylvania OOriginal Order/Notice Co./City/Dist. of CUMBERLAND 917106744 OAmended Order/Notice Date of Order/Notice 04/23/10 841 S 2004 0Terminate Order/Notice Case Number (See Addendum for case summary) OOne-Time Lump Sum/Notice RE:VANGORDER, ANDREW C. Employer/Withholder's Federal EIN Number Employee/Obligor's Name (Last, First, MI) 186-40-2723 Employee/Obligor's Social Security Number BAYLOR UNIVERSITY 0463101392 PO BOX 97042 Employee/Obligor's Case Identifier WACO TX 76798-7042 (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. $ 1,250.00 per month in current child support c7 0 -11 $ 100.00 per month in past-due child support Arrears 12 weeks or greater? O (9;no $ 0.00 per month in current medical support r ? x-n $ 0.00 per month in past-due medical support mr.. $ 300.00 per month in current spousal support J ., ? 73 { $ o . oo per month in past-due spousal support $ 0.00 per month for genetic test costs f W}?` $ o . oo per month in other (specify) ='t = $ one-time lump sum payment _ Cao ? for a total of $ 1,650.00 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: $ 380.7T per weekly pay period. $ 825. oo per semimonthly pay period (twice a month) $ 761.54 per biweekly pay period (every two weeks) $ 1, 650. oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). Pennsylvania law (23 PA C.S. § 4374(b)) requires remittance by an electronic payment method if an employer is ordered to withhold income from more than one employee and employs 15 or more persons, or if an employer has a history of two or more returned checks due to nonsufficient funds. Please call the Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. PA FIPS CODE 42 000 00 Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AN CSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURIT MBER M ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. 1001- -1-4ar BY THE COURT: DRO: R.J. Shadday Edward E Service Type M OMB No.: 0970-0154 Form EN-028 Rev.5 Worker ID $ IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS If4heckefl you are required to rQvide a jopy of this form to your?mloyee. If yoyr employee works in a state tha?is di event rrom the state that issued this o er, a copy must be provi to your employee even if the box is not checked. 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. 3. * Reporting the Paydate/Date of Withholding: You must report the paydate/date of withholding when sending the payment. The paydate/date of withholding is the date on which amount was withheld from the employee's wages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/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. 7411597530 THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : O THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: EZI EMPLOYEE'S/OBLIGOR'S NAME:VANGORDER, ANDREW C. EMPLOYEE'S CASE IDENTIFIER: 0463101392 DATE OF SEPARATION LAST KNOWN HOME ADDRESS: LAST KNOWN PHONE NUMBER: FINAL PAYMENT AMOUNT- NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/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 more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (CCPA) 0 5 U.S.C. 1673 (b)); or 2) the amounts allowed by the State or Tribe of the employee's/obligor's principal place of employment. Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes, Social Security taxes, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is supporting another family and 60% of the disposable income if the obligor is not supporting another family.However, that 50% limit is increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State, you may deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section. Arrears greater than 12 weeks : If the Order Information does not indicate whether the arrears are greater than 12 weeks, then the employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of the CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amounts paid for health care premiums in determining disposable income and applying appropriate withholding limits. 10. Additional info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Send Termination Notice and other correspondence to: 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) 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Rev.5 Service Type M OMB No.: 0970-0154 Worker I D $ IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: VANGORDER, ANDREW C. PACSES Case Number 648108122 Plaintiff Name STEPHANIE S. KRIBS Docket Attachment Amount 04-4831 CIVIL$ 300.00 Child(ren)'s Name(s): DOB PACKS Case Number 917106744 Plaintiff Name STEPHANIE S. KRIBS Docket Attachment Amount 00841 S 2004 $ 1,350.00 Child(ren)'s Name(s): DOB D VANGORDER BRENDAN 01/03/92 ... aGAN E VMG 0RDER' 01/x`1/9'4 SEAN M. VANGORDER 12/15/95 PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Addendum Form EN-028 Rev.5 Service Type M OMB No, 0970-0154 Worker ID $IATT ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 04-4831 CIVIL O Origi nal Order/Notice State Commonwealth of Penn ylvania Co./City/Dist. of CUMBERLAND 917106744 OAmended Order/Notice Date of Order/Notice 08/09/10 841 S 2004 OTerminate Order/Notice Case Number (See Addendum for case summary) QOne-Time Lump Sum/Notice RE: VANGORDER, ANDREW C . EmployedWithholder's Federal EIN Number Employee/Obligor's Name (Last, First, Mp 186-40-2723 Employee/Obligor's Social Security Number BAYLOR UNIVERSITY PO BOX 97042 0463101392 Employee/Obligor's Case Identifier WACO TX 7 6 7 9 8 - 7 04 2 (See Adderxlum 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. $ 834.00 per month in current child support $ ioo. oo per month in past-due child support Arrears 12 weeks or greateri' Qy~s~~no $ o. oo per month in current medical support r_- e ~ '-; $ o . oo per month in past-due medical support -~ ~ y c-~- -_~' T, $ 300. oo per month in current spousal support _ ` $ o . oo per month in past-due spousal support ~ ~ ~ . -' -~ ~ ~x~ $ o . oo per month for genetic test costs -- $ o . oo per month in other (specify) - -° ~""'_ $ one-time lump sum payment '~ ~1 for a total of $ 1, 234.00 per month to be forwarded to payee below. _'.~ ~ op ~- ~:. q~, You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not 7tiatch the ordered support payment cycle, use the following to determine how much to withhold: $ 283 99 per weekly pay period. $ 617, oo per semimonthly pay period (twice a month) $ 567.98 per biweekly pay period (every two weeks) $ 1, 234 . oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. ~ Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). Pennsylvania law (23 PA C.S. S 4374(b)) requires remittance by an electronic payment method if an employer is ordered to withhold income from more than one employee and employs 15 or more persons, or if an employer has a history of two or more returned checks due to nonsufficient funds. Please call the Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. PA FIPS CODE 42 000 00 Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 !N ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME A PACSES MEMBER /D (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECUR UMBE N ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: DRO: R.J. Shadday Service Type M Edward E. OMB No.: 0970-0154 Form EN-028 Rev.5 Worker ID 21205 ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS If ~heckefl you are required to provide a~opy of this form to your~mployee. If yorr employee vyorks in a state that is di Brent Trom the state that issued this or er, a copy must be provi edd to your emp ogee even if the box is not checked 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%bligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee%bligor. 3.* Reporting the Paydate/Date of Withholding: You must report the paydate/date of withholding when sending the payment. The paydate/date of withholding is the date on which amount was withheld from the employee's wages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respell to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/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%bligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. ~a11s9~s3o THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : ~ THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: ~ EMPLOYEE'S/OBLIGOR'S NAME:VANGORDER, ANDREW C. EMPLOYEE'S CASE IDENTIFIER: 0463101392 LAST KNOWN HOME ADDRESS: LAST KNOWN PHONE NUMBER: DATE OF SEPARATION: FINAL PAYMENT AMOUNT• NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee%bligor'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. Antidiscrimination: You are subject to a fine determined under State law for discharging an employee%bligorfrnm employment, refusing to employ, or taking disciplinary action against any employee%bligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (CCPA) (15 U.S.C. 1673 (b)); or 2) the amounts allowed by the State or Tribe of the employee's/obligor's principal place of employment. Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes, Social Security taxes, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is supporting another family and 60% of the disposable income if the obligor is not supporting another family.However, that 50% limit is increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State, you may deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section. Arrears greater than 12 weeks : If the Order Information does not indicate whether the arrears are greater than 12 weeks, then the employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of the CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amounts paid for health care premiums in determining disposable income and applying appropriate withholding limits. 10. Additional info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this orcler with respect to these items. 11. Send Termination Notice and other correspondence to: DOMESTIC RELATIONS SECTION 1~ 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) 240-6248 or by Internet www.childsupport.state.pa.us Page 2 of 2 Service Type M OMB No.: 0970.0154 Form EN-028 Rev.5 Worker ID 21205 ADDENDUM Summary of Cases on Attachment Defendant/Obligor: VANGORDER, ANDREW C . PACSES Case Number 648108122 Plaintiff Name STEPHANIE S. KRIBS Docket Attachment Amount 04-4831 CIVIL$ 300.00 Child(ren}'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ o.oo Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ o.oo Child(ren)'s Name(s): DOB Service Type M Addendum OMB No.: 0970-0154 PACSES Case Number 917106744 Plaintiff Name STEPHANIE S. KRIBS Docket Attachment Amount 00841 S 2004 $ 934.00 Child(ren)'s Name(s): DOB KEEGAN E . VP,NGORDER 0 1.31 / 94, . PACSES Case Number Plaintiff Name Docket Attachment Amount $ o.oo Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ o.oo Child(ren)'s Name(s): DOB Form EN-028 Rev.5 Worker ID 21205 ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania 917106744 Co./City/Dist. of CUMBERLAND _ 841 S 2004 Date of Order/Notice 08/27/10 Case Number (See Addendum for case summary) Employer/Withholder's Federal EIN Number BAYLOR UNIVERSITY PO BOX 97042 WACO TX 76798-7042 04-4831 CIVIL 0Original Order/Notice OAmended Order/Notice XQTerminate Order/Notice OOne-Time Lump Sum/Notice RE: VANGORDER, ANDREW C. Employee/Obligor's Name (Last, First, MI) 186-40-2723 Employee/Obligor's Social Security Number 0463101392 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. $ o . oo per month in current child support $ o. oo per month in past-due child support Arrears 12 weeks or greater? Dyes ® no $ o.0o per month in current medical support $ o.0o per month in past-due medical support s $ o . oo per month in current spousal support $ o. oo per month in past-due spousal support CDL. . ?. r- $ 0.00 per month for genetic test costs rn $ o . oo per month in other (specify) C.0 c) i $ one-time lump sum payment for a total of $ o . o o per month to be forwarded to payee below. ?' G? C) You do not have to vary your pay cycle to be in compliance with the support order. If your pay cyck4Des taet m h the ordered support payment cycle, use the following to determine how much to withhold: $ o. oo per weekly pay period. $ o. 0o per semimonthly pay period (twice a month) $ o. 00 per biweekly pay period (every two weeks) $ 0.00 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 #9 on page 2). Pennsylvania law (23 PA C.S. § 4374(b)) requires remittance by an electronic payment method if an employer is ordered to withhold income from more than one employee and employs 15 or more persons, or if an employer has a history of two or more returned checks due to nonsufficient funds. Please call the Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. PA FIPS CODE 42 000 00 Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAM ACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SEC WY NUMB ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: - x Edward E. Guido, Judge DRO: R. J. Shadday Form EN-028 Rev.5 Service Type M oM9 No, 0970-0154 Worker ID $ IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS loyee. If yo r employee works in a state that is If checked you are required to provide a opy of this form to your ern different from the state that issued this or?er, a copy must be provideto your employee even it the box is not checked. 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. 3.* Reporting the Paydate/Date of Withholding: You must report the paydate/date of withholding when sending the payment. The paydate/date of withholding is the date on which amount was withheld from the employee's wages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/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. 7411597530 THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : M THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 0 EMPLOYEE'S/OBLIGOR'S NAME: VANGORDER, ANDREW C. EMPLOYEE'S CASE IDENTIFIER: 0463101392 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: LAST KNOWN PHONE NUMBER: FINAL PAYMENT AMOUNT- NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/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 more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (CCPA) (15 U.S.C. 1673 (b)); or 2) the amounts allowed by the State or Tribe of the employee's/obligor's principal place of employment. Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes, Social Security taxes, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is supporting another family and 60% of the disposable income if the obligor is not supporting another family.However, that 50% limit is increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. if permitted by the State, you may deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section. Arrears greater than 12 weeks : If the Order Information does not indicate whether the arrears are greater than 12 weeks, then the employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of the CCPA 0 5 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amounts paid for health care premiums in determining disposable income and applying appropriate withholding limits. 10. Additional info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11, Send Termination Notice and other correspondence to: 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 (717) 240-6248 or CARLISLE PA 17013 by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Rev.5 Service Type M OMB No.: 0970-0154 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: VANGORDER, ANDREW C. PACSES Case Number 648108122 PACSES Case Number 917106744 Plaintiff Name Plaintiff Name STEPHANIE S. KRIBS STEPHANIE S. KRIBS Docket Attachment Amount Docket Attachment Amount 04-4831 CIVIL$ 0.00 00841 S 2004 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB KEEGAN E. VANGORDER 01/31/94 SEAN M 'VANGORDER 12/15/95 PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Addendum Form EN-028 Rev.5 Service Type M OMB No.: 0970-0154 Worker ID $IATT ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 04-4831 CIVIL State Commonwealth of Pennsylvania 917106744 (S)Original Order/Notice Co./City/Dist. of CUMBERLAND 841 S 2004 OAmended Order/Notice Date of Order/Notice 09/29/10 OTerminate Order/Notice Case Number (See Addendum for case summary) (Done-Time Lump Sum/Notice RE: VANGORDER, ANDREW C. Employer/4Vithholder's Federal EIN Number Employee/Obligor's Name (Last, First, MI) 186-40-2723 Employee/Obligor's Social Security Number UNIVERSITY OF SOUTH FLORIDA 0463101392 4202 E FOWLER AVE Employee/Obligor's Case Identifier SVC 2172 (See Addendum for plaintiff names TAMPA FL 33620-9951 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'slobligor's income until further notice even if the Order/Notice is not issued by your State. $ 834.00 per month in current child support $ loo. oo per month in past-due child support Arrears 12 weeks or greater? O Qs } nOn $ 0.00 per month in current medical support ?_X C= --? $ 0.00 per month in past-due medical support rr) tart - $ 300.00 per month in current spousal support $ o . oo per month in past-due spousal support w ?D $ 0.00 per month for genetic test costs (- ?C=) $ o . oo per month in other (specify) ;rte C-) ?-? C.-I F3 $ one-time lump sum payment a? for a total of $ 1,234.00 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: $ 284.77 per weekly pay period. $ 62.7. 00 per semimonthly pay period 569.54 (twice a month) $ per biweekly pay period (every two weeks) $ 1, 234.00 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 #9 on page 2). Pennsylvania law (23 PA C.S. S 4374(b)) requires remittance by an electronic payment method if an employer is ordered to withhold income from more than one employee and employs 15 or more persons, or if an employer has a history of two or more returned checks due to nonsufficient funds. Please call the Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. PA FIPS CODE 42 000 00 Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 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) 'S'ly AL CURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: Edward E. -dM, g Form EN-028 Rev.S Service Type M OMB No.: 0970.0154 Worker I D $ IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS If Necked you are required to provide a copy of this form to your mployee. If yo r employee works in g state that rs d4erent from the state that issued this order, a copy must be provided to your employee even if the box is not checked. 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, 3.* Reporting the Paydate/Date of Withholding: You must report the paydate/date of withholding when sending the payment. The paydate/date of withholding is the date on which amount was withheld from the employee's wages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employeelobligor 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. 5931021120 THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : 0 THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 0 EMPLOYEE'S/OBLIGOR'S NAME: VANGORDER, ANDREW C. EMPLOYEE'S CASE IDENTIFIER: 0463101392 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: LAST KNOWN PHONE NUMBER: FINAL PAYMENT AMOUNT. NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: if you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employeelobligor'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. Antidiscrimination: 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 more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (CCPA) 0 5 U.S.C. 1673 (b)); or 2) the amounts allowed by the State or Tribe of the employee's/obligor's principal place of employment. Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes, Social Security taxes, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is supporting another family and 60% of the disposable income if the obligor is not supporting another family.However, that 50% limit is increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State, you may deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section. Arrears greater than 12 weeks : if the Order Information does not indicate whether the arrears are greater than 12 weeks, then the employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of the CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amounts paid for health care premiums in determining disposable income and applying appropriate withholding limits. 10. Additional info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Send Termination Notice and other correspondence to: DOMESTIC RELATIONS SECTION If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT 13 N. HANOVER ST by telephone at (7717) 240-6225 or P.O. BOX 320 by FAX at (717) 240-6248 or CARLISLE PA 17013 by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Rev.5 Service Type M OMB No, 0970-0154 Worker I D $ IATT Defendant/Obligor: VANGORDER, ANDREW C. PACSES Case Number 648108122 Plaintiff Name STEPHANIE S. KRIBS Docket Attachment Amount 04-4831 CIVIL$ 300.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount Docket Attachment Amount $ 0.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name ADDENDUM Summary of Cases on Attachment PACKS Case Number 917106744 Plaintiff Name STEPHANIE S. KRIBS Docket Attachment Amount 00841 S 2004 $ 934.00 Child(ren)'s Name(s): DOB KEEGAN E. VANGORDER 01 /31/94 tot . Vi G 3RDER , 1.2 /.1:.5 f 9:5 PACKS Case Number Plaintiff Name PACKS Case Number Plaintiff Name Docket Attachment Amount Docket Attachment Amount $ 0.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB Service Type M Addendum OMB No.: 0970-0154 Form EN-028 Rev.5 Worker ID $IATT In the Court of Common Pleas of ~~E~„~ County, Pennsylvania DOMESTIC RELATIONS SECTION STEPHANIE( S. KRIBS ) Docket Number 04-4831 CIVIL Plaintiff ) vs. ) PACSES Case Number 648108122 ANDREW C. VANGORDER ) Defendant ) Other State ID Number ORDER TO CREDIT ARREARS AND NOW, On th1S 20TH DAY OF OCTOBER, 2010 IT IS HEREBY ORDERED that credit 1De given on the above captioned case in the amount of $ 4 s 6 . o o There ® is ~ ~s not an agreement of the parties to the credit. This credit is for: ® Direct Payments. ^ Purchases made or services performed by the Defendant on behalf of the Plaintiff or children. ^ Time children resided with the Defendant as agreed upon by parties, or addressed in a partial custody order for the following time periods: From to ~ ~ t~ '~ From to ~?~ o ;~ ~- From to ~ ~ ~ r ~ ~ ~~ ~ ~~ ^ Other: = ~-~ .~- MONEY ORDER #28721671 '."-~ W -' _~ . • t ~ .."~ ,.. i Plaintiff Date Defendant Date i 20TH DAY' OF OCTOBER, 2010 Date DRO: R. J. Shadday Service Type M BY THE COURT: A ~. `.~,~ EDWARD E. GUIDO, JUDGE Form FI-002 Rev. l Worker ID 210 0 5 ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 04-4831 CIVIL OOriginal Order/Notice State Commonwealth of Pennsylvania 917106744 X Amended Order/Notice Co./City/Dist. of CUMBERLAND 841 S 2004 Date of Order/Notice 12/20/10 (Terminate Order/Notice Case Number (See Addendum for case summary) QOne-Time Lump Sum/Notice RE:VANGORDER, ANDREW C. Employer/Withholder's Federal EIN Number Employee/Obligor's Name (Last, First, MI) 186-40-2723 Employee/Obligor's Social Security Number UNIVERSITY OF SOUTH FLORIDA 0463101392 4202 E FOWLER AVE Employee/Obligor's Case Identifier SVC 2172 (See Addendum for plaintiff names TAMPA FL 33620-9951 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 orde2or 4pomc:' from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required'edtit th? amounts from the above-named employee's/obligor's income until further notice even if the Order/f ree is$?t rn,= issued by your State. N -0 r_ t $ 834.00 per month in current child support $ 0.00 per month in past-due child support Arrears 12 weeks or greater? .® ncrc -r, $ 0.00 per month in current medical support C- -? r?"I $ o.00 per month in past-due medical support >? rv ?i $ 300.00 per month in current spousal support $ o . oo per month in past-due spousal support $ o . oo per month for genetic test costs $ 0.00 per month in other (specify) _ $ one-time lump sum payment for a total of $ 1,134.00 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: $ 961 69 per weekly pay period. $ 567.00 per semimonthly pay period (twice a month) $ 52-3 --3R per biweekly pay period (every two weeks) $ 1,134.00 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 #9 on page 2). Pennsylvania law (23 PA C.S. § 4374(b)) requires remittance by an electronic Payment method if an employer is ordered to withhold income from more than one employee and employs 15 or more persons, or if an employer has a history of two or more returned checks due to nonsufficient funds. Please call the Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. PA FIPS CODE 42 000 00 Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE 7 NT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case /d ier) OR S L SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: Edward E. Guido, DRO: R. J. Shadday Service Type M OMB No.: 0970-0154 Form EN-028 Rev.5 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS t If Necked you are required to provide a copy, of this form to your mployee. if yo r employee v?or s i is state ohecked. d4erent from the state that issued this order, a copy must be provideed to your empyloyee even if t e box against the te law der al process same 1. Priority: Withholding under this recordlthis order priority over any other priority. If there are gFederal tax levies inaeffect please contact he' requesting Federal tax levies in effect before receipt of agency listed below. income in ngle 2. Combining Payments: You can combine hho ever, separately identify the portonlof the single payment that islattr bput ble to each each agency requesting withholding. You must, employee/obligor. with the lawe pa of the he employee's wages. You must complypayment. Reporting the P /Date of Weonowh which amount was withheld paydate/date of date state of of withholding is 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. ort against there than one thiEmployee/Obligor oblgwith you ware ltiplu able to onodr'allll support O der/Not ices due ttorFede al'orSta a wit holding limits, ySupp ou must follow this employee/state or y the law law of 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 stdeANot ce e hthe hee emp o e e/obl below.o to g1 works o for you. Please provide the information requested and return a copy this THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : O THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: EMPLOYEE'S/OBLIGOR'S NAME: VANGORDER, ANDREW C. DATE OF SEPARATION: EMPLOYEE'S CASE IDENTIFIER: 0463101392 LAST KNOWN HOME ADDRESS: FINAL PAYMENT AMOUNT LAST KNOWN PHONE NUMBER: 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. yment 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an mplo a ?d IligorPfrom a ploa State law refusing to employ, or taking disciplinary action against any employee/obligor because of a support 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 more than the lesser of: 1) the amounts ahowed by the Federal Consumer Credit Protection Act (CCPA) (15 U.S.C. 1673 (b)); or 2) the amounts allowed deductions such asmStlateeFedeballglocalpaxespSopial a of employment. Disposable income is the net income left after making mandatory Security taxes, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is supporting another family and 60% of the disposable income if the obligor is not supporting another family.However, that 500% limit is increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State, y may deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section. Arrears greater than 12 weeks : If the Order information does not indicate whether the arrears are greater than 12 weeks, then the employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts re than the lesser allowed under the law of the issuing Tribe. For Tribal employers ehocated or State order, you may not mum amount permitted ul derosection 303(d) of the the limit set by the law of the jurisdiction in which the s CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amounts paid for health care premiums in determining disposable income and applying appropriate withholding limits. 10. Additional info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Send Termination Notice and other correspondence to: If you or your ernployee/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 (717) 240-6248 or CARLISLE PA 17013 by internet www childsupport.state.pa.us Page 2 of 2 OMB No.: 0970-0154 Form EN-028 Rev.5 Worker ID $IATT Service Type M ADDENDUM Summary of Cases on Attachment Defendant/Obligor: VANGORDER, ANDREW C. PACKS Case Number 648108122 Plaintiff Name STEPHANIE S. KRIBS Docket Attachment Amount 04-4831 CIVIL$ 300.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Addendum Service Type M OMB No.: 0970-0154 PACSES Case Number 917106744 Plaintiff Name STEPHANIE S. KRIBS Docket Attachment Amount 00841 S 2004 $ 834.00 Child(ren)'s Name(s): DOB KEEGAN E. VANGORDER 01/31/94 ?E'AI? M . < St:'?.N`Gf?TtF#)?.'R ' 12 / 15 / 9 5 PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACKS Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Form EN-028 Rev.5 Worker I D $ zATT INCOME WITHHOLDING FOR SUPPORT p O ORIGINAL INCOME WITHHOLDING ORDERINOTICE FOR SUPPORT (IWO)'?? D O AMENDED IWO q I? I b ?? ll' ONE-TIMEORDER/NOTICE FOR LUMP SUM PAYMENT I r t Ut} [ } $ I CIVIL- 0 O TERMINATION OF IWO S41 S Date: 06/07/12 ? Child Support Enforcement (CSE) Agency ® Court E] Attorney ? Private Individual/Entity (Check One) NOTE: This I O must be reg?ul-a-,rr???'oo'gg its face. Under certain circumstances you must reject this IWO and return it to the sender (see IWO instructions I? )Mhvw acf hFiB bi?dTl3rooramE/cse/nevvhire/employer/publication/DUbhcatlon htm forms). If you receive this document from someone other than a State or Tribal CSE agency or a Court a cop of the and 1 State/Tribe/Territory Commonwealth of Pennsylvania City/County/Dist./Tri be CUMBERLAND Private Individual/Entity Remittance Identifier (include w/payment): 0463101392 Order Identifier: (See Addendum for order/docket Informalton) CSF AnPnr.v rnm Lae..r re.. ie__ BAYLOR UNIVERSITY PO BOX 97042 WACO TX 76798-7042 Employer/Income Withholder's FEIN 741159753 Child(ren)'s Name(s) (Last, First, Middle) Child(ren)'s Birth Date(s) ?----._ ................ -.1"Inmaryl RE: VANGORDER, ANDREW C. Employee/Obligor's Name (Last, First, Middle) 186-40-2723 Employee/Obligor's Social Security Number (See Addendum for plaintiff names associated with cases on attachment) Custodial Party/Obligee's Name (Last, First, Middle) NOTE: This IWO must be regular on its face. Under certain circumstances you must reject this IWO and return it to the sender (see IWO instructions httn://www.acf hhs gorograMs1 sgJn vhire/ emoloveOublication/pub-lialion.htm forma, If you receive this document from someone other than a State or Tribal CSE agency or a Court, a copy of the underlying order must be attached. 7411597530 See Addendum for dependent names and birth dates associated with cases on attachment. Anr k-r% Sao- wow.-.. --•----._ tova vr? w-1-rr. nis aocument is based on the support or withholding order from CUMBERLAND County, Commonwealth of Pennsylvania (State/Tribe). You are required by law to deduct these amounts from the employee/ obligor's income until further notice. $ 839.00 per month in current child support $ $ 0.00 per month in past-due child support - Arrears 12 weeks or greater? Q yes 4 nib $ 0.00 per month in current cash medical support `-n M 0.00 per month in past-due cash medical support M C_ -' $ $ 300.00 permonth in current spousal support ` 0.00 per month in past-due spousal support Co $ 0.00 per month in other (must specify) for a Total Amount to Withhold of $ 1,139.00 per month. - - - - AMOUNTS TO WITHHOLD: You do not have to vary your pay cycle to be in compliance with the Oizfer n ralo on. If your pay cycle does not match the ordered payment cycle, withhold one of the following amount: $ 262.$5 per weekly pay period. $ 569.50 per semimonthly a $ 525,11D per biweekly pa P Y period (twice a month) y period (every two weeks) $ 1,139.00 per monthly pay period. $ Lump Sum Payment: Do not stop any existing IW uunless you receive a termination order. REMITTANCE INFORMATION: If the employee/obligor's principal place of employment is within the Commonwealth of Pennsylvania (State/Tribe), you must begin withholding no later than the first pay period that occurs en 1 working days after the date of this Order/Notice. Send payment within even 7 working days of the pay date. If you cannot withhold the full amount of support for any or all orders for this employee/obligor, withhold up to 5°0 of disposable income for all orders. If the employee/obligor's principal place of employment is not within the Commonwealth of Pennsylvania (State/Tribe), the employer can obtain withholding limitations, time requirements, and any allowable employer fees at http://www.acf hhs.gov/programs/cse/newhire/employer/contacts/contact map htm for the employee/obligor's principal place of employment. Document Tracking Identifier Service Type M Y er ying order must be attached. OMB No.: 0970-0154 Form EN-028 06/12 Worker ID $IATT ? Return to Sender [Completed by Employer/Income Withholder]. Payment must be directed to an SDU in accordance with 42 USC §666(b)(5) and (b)(6) or Tribal Payee (see Payments to SDU below). If payment is not directed to an SDU/Tribal Payee or this IWO is not regular on its face, you must check this box and return e IWO to the sender. Signature of Judge/Issuing Official (if required by State or Tribal law): Print Name of Judge/Issuing Official:„ Title of Judge/Issuing Official: JUN Date of Signature: If the employee/obligor works in a State or for a Tribe that is different from the State or Tribe that issued this order, a copy of this IWO must be provided to the employee/obligor. ? If checked, the employer/income withholder must provide a copy of this form to the employee/obligor. ADDITIONAL INFORMATION FOR EMPLOYERS/INCOME WITHHOLDERS Pennsylvania law (23 PA C.S. § 4374(b)) requires remittance by an electronic naurnent method if an employer is ordered to withhold income from more than one employee and employs 15 or more persons, or if an employer has a history of two or more returned checks due to nonsufficient funds. Please call the Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676.9580 for instructions. PA FIPS CODE 42 000 00 Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Sox 99112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the EngAW9@10bllgor's Case IdentWor) OR SOCIAL SECURITY NUM&ER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. State-specific contact and withholding information can be found on the Federal Employer Services website located at: //wtiativ acf hhs ^^?s:, ,anle{ne hit +Iert,Ansstcont rrta htm Priority: Withholding for support has priority over any other legal process under State law against -the same incoo?e (USC 42 §666(bx7)). If a Federal tax levy is in effect, please notify the sender. Combining Payments: When remitting payments to an SDU or Tribal CSI= agency, you may combine withheld amounts from more than one employee/obligor's income in a single payment. You must, however, separately identify each employee/ obligor's portion of the payment. Payments To SDU: You must send child support payments payable by income withholding to the appropriate SDU or to a Tribal CSE agency. If this IWO instructs you to send a payment to an entity other than an SDU (e.g., payable to the custodial party, court, or attorney), you must check the box above and return this notice to the sender. Exception: If this IWO was sent by a Court, Attorney, or Private Individual/Entity and the initial order was entered before January 1, 1994 or the order was issued by a Tribal CSE agency, you must follow the "Remit payment to" instructions on this form. Reporting the Pay Date: You must report the pay date when sending the payment. The pay date is the date on which the amount was withheld from the employee/obligor's wages. You must comply with the law of the State (or Tribal law if applicable) of the employee/obligor's principal place of employment regarding time periods within which you must implement the withholding and forward the support payments. Multiple IWOs: If there is more than one IWO against this employee/obligor and you are unable to fully honor all IWOs due to Federal, State, or Tribal withholding limits, you must honor all IWOs to the greatest extent possible, giving priority to current support before payment of any past-due support. Follow the State or Tribal law/procedure of the empioyeelobligor's principal place of employment to determine the appropriate allocation method. Lump Sum Payments: You may be required to notify a State or Tribal CSE agency of upcoming lump sum payments to this employee/obligor such as bonuses, commissions, or severance pay. Contact the sender to determine if you are required to report and/or withhold lump sum payments. Liability: If you have any doubts about the validity of this IWO, contact the sender. if you fail to withhold income from the employee/obligor's income as the IWO directs, you are liable for both the accumulated amount you should have withheld and any penalties set by State or Tribal law/procedure. Anti-discrimination: You are subject to a fine determined under State or Tribal law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against an employee/obligor because of this IWO. OMB Expiration Date - 05/31/2014. The OMB Expiration Date has no bearing on the termination date of the IWO; it identifies the version of the form currently in use. Form EN-028 06/12 Service Type M Page 2 of 3 Worker ID $IATT Employer's Name: BAYLOR UNIVERSITY Employee/Obligor's Name: VANGORDER ANDREW C. Employer FEIN: 741159753 CSE Agency Case Identifier: (See Addendum for case summar r? Order Identifier: (See Addendum for order /docket0information ) Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (CCPA) (15 U.S.C. 1673(b)); or 2) the amounts allowed by the State or Tribe of the employee/obligor's principal place of employment (see REMITTANCE INFORMATION). Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; statutory pension contributions; and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is supporting another family and 60% of the disposable income if the obligor is not supporting another family. However, those limits increase 5% - to 55% and 65% - if the arrears are greater than 12 weeks. If permitted by the State or Tribe, you may deduct a fee for administrative costs. The combined support amount and fee may not exceed the limit indicated in this section. For Tribal orders, you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employers/income withholders who receive a State IWO, you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which the employer/income withholder is located or the maximum amount permitted under section 303(d) of the CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State or Tribal law, you may need to also consider the amounts paid for health care premiums in determining disposable income and applying appropriate withholding limits. Arrears greater than 12 weeks? If the Order Information does not indicate that the arrears are greater than 12 weeks, then the Employer should calculate the CCPA limit using the lower percentage. Additional Information: NOTIFICATION OF EMPLOYMENT TERMINATION OR INCOME STATUS: If this employee/obligor never worked for you or you no longer withholding income for this employee/obligor, an employer must promptly notify the CSE agency and/or the sender by returning this form to the address listed in the Contact Information below: 7411597530 Q This person has never worked for this employer nor received periodic income. O This person no longer works for this employer nor receives periodic income Please provide the following information for the employee/obligor: Termination date: Last known address: Final Payment Date To SDU/Tribal Payee: New Employer's Name: New Employer's Address: CONTACT INFORMATION: Last known phone number: Final Payment Amount: To Emcloyer/Income Withholder: If you have any questions, contact WAGE ATTACHMENT UNIT (Issuer name) by phone at (717) 240-6225, by fax at (717) 240-6248, by email or website at: www.childsupport state oa us. Send termination/income status notice and other correspondence to: DOMESTIC RELATIONS SECTION, 13 N. HANOVER ST P.O. BOX 320, CARLISLE PA 17013 (Issuer address). To Employee/obligor: If the employee/obligor has questions, contact WAGE ATTACHMENT UNIT (Issuer name) by phone at (717) 240-6225, by fax at (717) 240-6248, by email or website at www.childRllooort state a us. IMPORTANT: The person completing this form is advised that the information may be shared with the employee/obligor. Service Type M OMB No.: 0970-0154 Page 3 of 3 Form EN-028 06/12 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: VANGORDER, ANDREW C. PACSES a_se Number 648108122 PACSES Case Numt1-,1 917106744 Na aintiffme Plaintiff Name Pl STEPHANfE S. KRIBS STEPHANIE S. KRIBS A achment Amount Docket Attachment Amount 00841?S 2004 $ 839.00 04-4831 CIVIL $ 300.00 DOB Child(ren)'s Name(s): DOB Child(ren)'s Name(s): SEAN M. VANGORDER 12/15195 PACSES Case Number P1 affl Name Docket AMwhment unt $ 0.00 Child(ren)'s Name(s): pocket Attachment Amount $ 0.00 Child(ren)'s Name(s): PACSES Case Number Plaintiff Name Docket gkt?nJ?tppM Amount $ 0.00 DOB Child(ren)'s Name(s): DOB PAC *,S Gass UMIDD r Plaintiff Name Docket Attachment Amount $ 0.00 DOB Child(ren)'s Name(s): DOB Service Type M Addendum OMB No.: 0970-0154 Form EN-028 06112 Worker ID $IATT INCOME WITHHOLDING FOR SUPPORT Cpl N' O ORIGINAL INCOME WITHHOLDING ORDER/NOTICE FOR SUPPORT (IWO) (? O AMENDED IWO `1 1'] I GU-744 o4-0011 Clv i l O ONE-TIMEORDER/NOTICE FOR LUMP SUM PAYMENT J' Q TERMINATION OF IWO iL' I J ?GC Date: 06/15/12 ? Child Support Enforcement (CSE) Agency ® Court ? Attorney ? Private Individual/Entity (Check One) NOTE: This tAMJ"st7b66@d" its face. Under certain circumstances you must reject this IWO and return it to the sender (see IWO instructions http://www.acf.hhs.gov/programs/cse/newhire/employer/publication/publication htm - forms). If you receive this document from someone other than a State or Tribal CSE agency or a Court, a copy of the underlying order must be attached. mate"noel errn[ory uommonweann or rennsyrvama Remittance Identifier (include w/payment): 0463101392 City/County/Dist.fTribe CUMBERLAND Order Identifier: (See Addendum for orderldocket lnformalton) Private Individual/Entity CSE Agency Case Identifier: (See Addendum for case summary) BAYLOR UNIVERSITY PO BOX 97042 WACO TX 76798-7042 Employer/Income Withholder's FEIN 741159753 Child(ren)'s Name(s) (Last, First, Middle) Child(ren)'s Birth Date(s) RE: VANGORDER. ANDREW C Employee/Obligor's Name (Last, First, Middle) 186-40-2723 Employee/Obligor's Social Security Number (See Addendum for plaintiff names associated with cases on attachment) Custodial Party/Obligee's Name (Last, First, Middle) NOTE: This IWO must be regular on its face. Under certain circumstances you must reject this IWO and return it to the sender (see IWO instructions htto://www.acf.hhs,oov/proarams/cse/newhire / em Foyer/publication/publication htm - form . If you receive this document from someone other than a State or Tribal CSE agency or a Court, a copy of the underlying order must be attached. 7411597530 See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This document is based on the support or withholding order from CUMBERLAND County, Commonwealth of Pennsylvania (State/Tribe), You are required by law to deduct these amounts from tte employee/ obligor's income until further notice. - -:. $ 839.00 per month in current child support - $ 153.00 per month in past-due child support - Arrears 12 weeks or greater? Q t ito r $ 0.00 per month in current cash medical support $ 0.00 per month in past-due cash medical support $ 300.00 per month in current spousal support $ 0.00 per month in past-due spousal support $ 0.00 per month in other (must specify) for a Total Amount to Withhold of $ 1,292.00 per month. AMOUNTS TO WITHHOLD: You do not have to vary your pay cycle to be in compliance with the Order Information. If your pay cycle does not match the ordered payment cycle, withhold one of the following amount: $ Aga, I t? per weekly pay period. $ 646.00 per semimonthly pay period (twice a month) $ 59(o. ,:g I per biweekly pay period (every two weeks) $ 1,292.00 per monthly pay period. $ Lump Sum Payment: Do not stop any existing IWO unless you receive a termination order. REMITTANCE INFORMATION: If the employee/obligor's principal place of employment is within the Commonwealth of Pennsylvania (State/Tribe), you must begin withholding no later than the first pay period that occurs ten 10 working days after the date of this Order/Notice. Send payment within even 7 working days of the pay date. If you cannot withhold the full amount of support for any or all orders for this employee/obligor, withhold up to 55% of disposable income for all orders. If the employee/obligor's principal place of employment is not within the Commonwealth of Pennsylvania (State/Tribe), the employer can obtain withholding limitations, time requirements, and any allowable employer fees at http'//www acf hhs gov/programs/cse/newhire/employer/contacts/contact_map htm for the employee/obligor's principal place of employment. Document Tracking Identifier OMB No.: 0970-0154 Form EN-028 06/12 Service Type M Worker ID $IATT ? Return to Sender [Completed by Employer/Income Withholder]. Payment must be directed to an SDU in accordance with 42 USC §666(b)(5) and (b)(6) or Tribal Payee (see Payments to SDU below). If payment is not directed to an SDU/Tribal Payee or this IWO is not regular on its face, you must check this box and return the IWO to the sender. Signature of Judge/Issuing Official (if required by State or Tribal law): Print Name of Judge/Issuing Official: Title of Judge/Issuing Official: Date of Signature: JUN 18 -2 012 If the employee/obligor works in a State or for a Tribe that is different from the State or Tribe that issued this order, a copy of this IWO must be provided to the employee/obligor. ? If checked, the employer/income withholder must provide a copy of this form to the employee/obligor. ADDITIONAL INFORMATION FOR EMPLOYERS/INCOME WITHHOLDERS Pennsylvania law (23 PA C.S. § 4374(b)) requires remittance by an electronic payment method if an employer is ordered to withhold income from more than one employee and employs 15 or more persons, or if an employer has a history of two or more returned checks due to nonsufficient funds. Please call the Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. PA FIPS CODE 42 000 00 Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER /D (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. State-specific contact and withholding information can be found on the Federal Employer Services website located at: hfp://www acf hhs gov/pl4orams/cs,e/`newhere/-employer/contacts/contact map htm Priority: Withholding for support has priority over any other legal process under State law against the same income (USC 42 §666(b)(7)). If a Federal tax levy is in effect, please notify the sender. Combining Payments: When remitting payments to an SDU or Tribal CSE agency, you may combine withheld amounts from more than one employee/obligor's income in a single payment. You must, however, separately identify each employee/ obligor's portion of the payment. Payments To SDU: You must send child support payments payable by income withholding to the appropriate SDU or to a Tribal CSE agency. If this IWO instructs you to send a payment to an entity other than an SDU (e.g., payable to the custodial party, court, or attorney), you must check the box above and return this notice to the sender. Exception: If this IWO was sent by a Court, Attorney, or Private Individual/Entity and the initial order was entered before January 1, 1994 or the order was issued by a Tribal CSE agency, you must follow the "Remit payment to" instructions on this form. Reporting the Pay Date: You must report the pay date when sending the payment. The pay date is the date on which the amount was withheld from the employee/obligor's wages. You must comply with the law of the State (or Tribal taw if applicable) of the employee/obligor's principal place of employment regarding time periods within which you must implement the withholding and forward the support payments. Multiple IWOs: If there is more than one IWO against this employee/obligor and you are unable to fully honor all IWOs due to Federal, State, or Tribal withholding limits, you must honor all IWOs to the greatest extent possible, giving priority to current support before payment of any past-due support. Follow the State or Tribal law/procedure of the employee/obligor's principal place of employment to determine the appropriate allocation method. Lump Sum Payments: You may be required to notify a State or Tribal CSE agency of upcoming lump sum payments to this employee/obligor such as bonuses, commissions, or severance pay. Contact the sender to determine if you are required to report and/or withhold lump sum payments. Liability: If you have any doubts about the validity of this IWO, contact the sender. If you fail to withhold income from the employee/obligor's income as the IWO directs, you are liable for both the accumulated amount you should have withheld and any penalties set by State or Tribal law/procedure. Anti-discrimination: You are subject to a fine determined under State or Tribal law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against an employee/obligor because of this IWO. OMB Expiration Date - 05/31/2014. The OMB Expiration Date has no bearing on the termination date of the IWO; it identifies the version of the form currently in use. Form EN-028 06/12 Service Type M Page 2 of 3 Worker ID $IATT Employer's Name: BAYLOR UNIVERSITY Employer FEIN: 741159753 Employee/Obligor's Name: VANGORDER, ANDREW C. 0463101392 CSE Agency Case Identifier: (See Addendum for case summary) Order Identifier: (See Addendum for order/docket information) Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (CCPA) (15 U.S.C. 1673(b)); or 2) the amounts allowed by the State or Tribe of the employee/obligor's principal place of employment (see REMITTANCE INFORMATION). Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; statutory pension contributions; and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is supporting another family and 60% of the disposable income if the obligor is not supporting another family. However, those limits increase 5% - to 55% and 65% - if the arrears are greater than 12 weeks. If permitted by the State or Tribe, you may deduct a fee for administrative costs. The combined support amount and fee may not exceed the limit indicated in this section. For Tribal orders, you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employers/income withholders who receive a State IWO, you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which the employer/income withholder is located or the maximum amount permitted under section 303(d) of the CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State or Tribal law, you may need to also consider the amounts paid for health care premiums in determining disposable income and applying appropriate withholding limits. Arrears greater than 12 weeks? If the Order Information does not indicate that the arrears are greater than 12 weeks, then the Employer should calculate the CCPA limit using the lower percentage. Additional Information: NOTIFICATION OF EMPLOYMENT TERMINATION OR INCOME STATUS: If this employee/obligor never worked for you or you no longer withholding income for this employee/obligor, an employer must promptly notify the CSE agency and/or the sender by returning this form to the address listed in the Contact Information below: 741 1597530 Q This person has never worked for this employer nor received periodic income. O This person no longer works for this employer nor receives periodic income. Please provide the following information for the employee/obligor: Termination date: Last known address: Last known phone number: Final Payment Date To SDU/Tribal Payee: New Employer's Name: New Employer's Address: Final Payment Amount: CONTACT INFORMATION: To Employer/Income Withholder: If you have any questions, contact WAGE ATTACHMENT UNIT (Issuer name) by phone at (717) 240-6225, by fax at (717) 240-6248, by email or website at: www.childsupportstate. pa us. Send termination/income status notice and other correspondence to: DOMESTIC RELATIONS SECTION, 13 N. HANOVER ST P.O. BOX 320, CARLISLE. PA 17013 (Issuer address). To Employee/Obligor If the employee/obligor has questions, contact WAGE ATTACHMENT UNIT (Issuer name) by phone at (717) 240-6225, by fax at (717) 240-6248, by email or website at www.childsupportstate a us. IMPORTANT: The person completing this form is advised that the information may be shared with the employee/obligor. Service Type M OMB No.: 0970-0154 Page 3 of 3 Form EN-028 06/12 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: VANGORDER, ANDREW C. PACSES Case Number 648108122 STEPHANIE S. KRIBS Docket Attachment Amount 04-4831 CIVIL $ 300.00 Child(ren)'s Name(s): DOB PACKS Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACSES Case Number 917106744 Plaintiff Name STEPHANIE S. KRIBS Docket Attachment Amount 00841 S2004 $ 992.00 Child(ren)'s Name(s): DOB SEAN M. VANGORDER 12/15/95 PACKS Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Addendum Form EN-028 06/12 Service Type M OMB No.: 0970-0154 Worker ID $IATT INCOME WITHHOLDING FOR SUPPORT Lt-I-S\Intag, 4T5} Cm' O ORIGINAL INCOME WITHHOLDING ORDER/NOTICE FOR SUPPORT (IWO) @) AMEwosoxwo O ONE-TIMEORDER/NOTICE FOR LUMP SUM PAYMENT O TERMINATION OF IWO S4H S 7�a� Date: 06m0/1* O Child Support Enforcement (CSE) Agency [8] Court OAttorney 0 Private Individual/Entity (Check One) NOTE: This IWO must circumstances you must reject this IWO and return it to the sender (see IWO inotruntionoh8pJ/w^ww.aotfiNgt.dhv/prhdfAK7mAefornnoX]M8'087O'O154 instructions.pctf). If you receive this documont from someone other than a State or Tribal CSE agency or a Court, a copy of the underlying order must be attached. State/Tribe/Territory Commonwealth of Pennsylvania CUMBERLAND Private Individual/Entity Remittance Identifier (includew/paymrm): 0463101392 Order Identifier: (See Addendum for order/docket informatio CSE Agency Case Identifuer: (See Addendum for case summary) BAYLOR UNIVERSITY PO BOX 9704 WACO TX 76798-7042 EmployamnoomavVithxnlder's FEIN 741159753 Child(ren)'s Name(s) (Last, First, Middle) ChxU(mn)'s Birth Date(s) RE: VANGORDER, ANDREW C. EName (Last, First, Middle) 186-40-2723 Social Security Number (See Addendum for plaintiff names associated with cases on attachment) Custodial Party/Obtigees Name (Last, First, Middle) NOTE: This IWO must be regular on its face. Under certain circumstances you must reject this IWO and retum it to the sender (see IWO instructions onn:x°mww.ocf.oha.yownmoramnmoenxnns/ OMB -0 70'015* instructions oufi.xyou receive this document from someone other than a State or TribaI CSE agency or a Court, a copy of the underlying order must be attached. 7411597530 See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This document is based on the support or withholding order from CUMBERLAND County, Commonwealth of Pennsylvania (State/Tribe). You are required by law to deduct these amounts from the employee/ obIigors income until further notice. $ 0.00 per month in current chfld support $ 0.00 per month in past -due child support - Arrears 12 weeks or greater? 0 y $ 0.00 per month in current cash medical support $ 0.00 per month in past -due cash medical support z 70 c.,-)1— $ 300.00 per month in current spousal support > $ O.OVper month inpast-due spousal ouppo� � CD $ 0.00 per month in other (musspecify) )>for ��c� a Total Amount to Withhold of $ 300.00 per month. + au �^ AMOUNTS TO WITHHOLD: You do not have to vary your pay cycle to be in compliance with the OirlerfnfonmaN:n. If your pay cycle does not match the ordered payment cycle, withhold one of the following amount: $ GQD4per weekly pay period. $ 150.00 per semimonth)y pay period (twice a month) $ 13808 per biweekly pay period (every two weeks) $ 8O0.UOper monthly pay period. $ Lump Sum Payment: Do not stop any existing IWO unless you receive a termination order. .Y- REMITTANCE INFORMATION: If the employee/obligor's principalcdaoeofmmcdoyment|awdhintha Commonwealth of Pennsylvania (State/Tribe), you must begin withholding no later than the first pay period that occurs ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the pay date, If you cannot withhold the full amount of support for any or all orders for this employee/obligor, withhold up to 55% of disposable income for all orders. If the employee/obligor's principal place of employment is not within the Commonwealth of Pennsylvania (8tobe/Thbe), the employer can obtain withholding hm)toUons. time naquinemento, and any allowable employer fees at h8p://wwxw.ac[hho.gov/onngoama/oua/nevvhirm/emp|oyer/cnnbacto/conbaot map. U1OIfor the employee/obligor's principal place of employment. Document Tracking Identifier Service Type MWorker ID $1ATT OMB No.: 0970-0154 Form EN -028 11/13 D Return to Sender [Completed by Employer/Income Withholder]. Payment must be directed to an SDU in accordance with 42 USC §666(b)(5) and (b)(6) or Tribal Payee (see Payments to SDU below). If payment is not directed to an SDU/Tribal Payee or this IWO is not regular on its face, you must check this box and return the IWO to the sender. Signature of Judge/Issuing Official (if required by State or Tribal law): Print Name of Judge/Issuing Official: Title of Judge/Issuing Official: Date of Signature: If the employee/obligor works in a State or for a Tribe that is different from the State or Tribe that issued this order, a copy of this IWO must be provided to the employee/obligor. [j If checked, the employer/income withholder must provide a copy of this form to the employee/obligor. ADDITIONAL INFORMATION FOR EMPLOYERS/INCOME WITHHOLDERS Pennsylvania law (23 PA C.S. § 4374(b)) requires remittance by an electronic payment method if an employer is ordered to withhold income from more than one employee and employs 15 or more persons, or if an employer has a history of two or more returned checks due to nonsufficient funds. Please call the Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. PA FIPS CODE 42 000 00 Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 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. State -specific contact and withholding information can be found on the Federal Employer Services website located at: http://www.acf.hhs.gov/programs/cse/newhire/employer/contacts/contact map.htm Priority: Withholding for support has priority over any other legal process under State law against the same income (USC 42 §666(b)(7)). If a Federal tax levy is in effect, please notify the sender. Combining Payments: When remitting payments to an SDU or Tribal CSE agency, you may combine withheld amounts from more than one employee/obligor's income in a single payment. You must, however, separately identify each employee/ obligor's portion of the payment. Payments To SDU: You must send child support payments payable by income withholding to the appropriate SDU or to a Tribal CSE agency. If this IWO instructs you to send a payment to an entity other than an SDU (e.g., payable to the custodial party, court, or attorney), you must check the box above and return this notice to the sender. Exception: If this IWO was sent by a Court, Attorney, or Private Individual/Entity and the initial order was entered before January 1, 1994 or the order was issued by a Tribal CSE agency, you must follow the "Remit payment to" instructions on this form. Reporting the Pay Date: You must report the pay date when sending the payment. The pay date is the date on which the amount was withheld from the employee/obligor's wages. You must comply with the law of the State (or Tribal law if applicable) of the employee/obligor's principal place of employment regarding time periods within which you must implement the withholding and forward the support payments. Multiple IWOs: If there is more than one IWO against this employee/obligor and you are unable to fully honor all IWOs due to Federal, State, or Tribal withholding limits, you must honor all IWOs to the greatest extent possible, giving priority to current support before payment of any past -due support. Follow the State or Tribal law/procedure of the employee/obligor's principal place of employment to determine the appropriate allocation method. Lump Sum Payments: You may be required to notify a State or Tribal CSE agency of upcoming lump sum payments to this employee/obligor such as bonuses, commissions, or severance pay. Contact the sender to determine if you are required to report and/or withhold lump sum payments. Liability: If you have any doubts about the validity of this IWO, contact the sender. If you fail to withhold income from the employee/obligor's income as the IWO directs, you are liable for both the accumulated amount you should have withheld and any penalties set by State or Tribal law/procedure. Anti -discrimination: You are subject to a fine determined under State or Tribal law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against an employee/obligor because of this IWO. OMB Expiration Date — 05131/2014. The OMB Expiration Date has no bearing on the termination date of the IWO; it identifies the version of the form currently in use. Form EN -028 11/13 Service Type M Page 2 of 3 Worker ID $IATT Employers NameBAYLOR UNIVERSITY Employer FEIN: 741159753 Employee/Obligors Name: VANGORDER, ANDREW C. 0463101392 CSE Agency CasIdentifier: (See Addendum for case summary) Ondur|dontifioc/See Addendum for orderldocket Information) Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (CCPA) (15 U.S.C. 1673(b)); or the State orTribe ofthe omp|oyeo/ b|igo/sphncipa|p|annof employment (see REMITTANCE -INFORMATION). Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; statutory pension contributions; and Medicare taxes. The Federal limit is 50% of the ciisposable income if the obligor is supporting another family and 60% of the disposable income if the obligor is not supporting another family. However, those limits increase 5% - to 55% and 65% - if the arrears are greater than 12 weeks. If permitted by the State or Tribe, you may deduct a fee for administrative costs. The combined support amount and fee may not exceed the limit indicated in this section. For Tribal orders, you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal withholders who receive a StatIWO, you may nowithhold more than the Iesser of the limit set by the Iaw of the jurisdiction in which the employer/income withholder is located or the maximum amount permitted under section 303(d) of the CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State or Tribal law, you may need to also consider the amounts paid for health care premiums in determining disposable income and applying appropriate withholding limits. Arrears greater than 12 weeks? If the Order Information does not indicate thatthatthe arrears are greaterthan 12 weeks, then the Employer should calculate the CCPA timit using the lower percentage, Additional Information: NOTIFICATION OF EMPLOYMENT TERMINATION OR INCOME STATUSf thiloyme/o or never workefor you or you are no longer withholding income for this employee/obligor, an employer must promptly notify the CSE agency and/or the sender by retuming this form to (he address Iisted in the Contact Information below: 7411597530 0 This person has never worked for this employer nor received periodic income. [] This person no Ionger works for this employer nor receives periodic income. Please provide the foliowing infomiation for the employee/obligor: Termination date: Last known phone number: Last known address: Final Payment Date To SDUfTribaI Payee: Final PaymenAmount: New Employer's Name: New Employer's Address: CONTACT INFORMATION: To Employer/Income Withholder: If you have any questions, contact WAGE ATTACHMENT UNIT (Issuer name) by phone at (717) 240-6225, by fax at (717) 240-6248, by email or website at: www.childsupport.state.Da.us. Send termination/income status notice and other correspondence to: DOMESTIC RELATIONS SECTION, 13 N. HANOVER ST. P.O. BOX 320 CARLISLE, PA. 17013 (Issuer address). To Employee/Obligor: If the employee/obligor has questions, contact WAGE ATTACHMENT UNIT (Issuer name) by phone at (717) 240-6225, by fax at (717) 240-6248, by email or website at www.childsupport.state.pa.us. IMPORTANT: The person completing this form is advised that the information may be shared with the employeefobligor. OMB No.: 0970-0154 Service Type M Page 3 of 3 Form EN -028 11/13 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: VANGORDER, ANDREW C. PACSES Case Number 648108122 Plaintiff Name STEPHANIE S. KRIBS Docket Attachment Amount 04-4831 CIVIL $ 300.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): PACSES Case Number PACSES Case Number Plaintiff Name Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Service Type M Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): Addendum OMB No.: 0970-0154 Form EN -028 11/13 Worker ID $IATT