The URL can be used to link to this page

Home My WebLink About02-0649 LINDA A. ROHM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY PENNSYLVANIA v. : NO. 2002- (P Lf q CIVIL TERM IN DIVORCE WILLIAM A. ROHM, Defendant 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND tUT WHERE YOU CAN GET LEGAL HELP. " CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 LINDA A. ROHM, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. : NO. 2002- G l.f1 IN DIVORCE CIVIL TERM WILLIAM A. ROHM, Defendant COMPLAINT UNDER SECTION 3301(C) OR (D) OF THE DIVORCE CODE Plaintiff, Linda A. Rohm, by her attorney, Lindsay D. Baird, Esquire, sets forth the following: Plaintiff, Linda A. Rohm, is an adult individual residing at 227 Webster Street, Carlisle, Cumberland County, Pennsylvania 17013. 2 Defendant, William A. Rohm, is an adult individual residing at 2977 Enola Road, Carlisle, Pennsylvania 17013. 3 The parties were married on February 2, 1973, in Curnberland County, Pennsylvania. 4 Plaintiff and Defendant have lived continuously in the Commonwealth of Pennsylvania for at least six months prior to the commencement of this action. 5 This action is not collusive. 6 There have been no prior actions for divorce or annulment in this or any other jurisdiction within the knowledge of the Plaintiff. 7 In accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is irretrievably broken. 8 Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintitfbe divorced from the Defendant. COUNT II - BQUlT ABLE DISTRIBUTION 9 .1 Paragraphs 1 through 8 of the Complaint are incorporated herein by reference set forth in full. 10 Plaintiff and Defendant have acquired property, both real and personal during their marriage from February 2,1973, until January 12,2002 the date of their separation. . II Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital property. ~ I verify that to the best of my knowledge and belief, the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.H904 relating to unsworn falsification to authorities. y~ ;4,RJdt Linda A. Robm, Plaintiff y~ ~ == - ~e ~ -- ~ ~--~ ~ (J)~,~ tr () 0 (") C N -" < -." -u (Ii m !I. r.; r.p :;Z:::l: zc I oJ }~': 0.... ~6 -:J 2:; (""""; 3: ~'-C) ~C Cd ,~) L N ~ ::;! I"':> -< LINDA ROHM, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff v. NO. 02-649 CIVIL WILLIAM A. ROHM, Defendant IN DIVORCE PRETRIAL STATEMENT PURSUANT TO Pa.R.C.P. 1920.33 I. a. PLAINTIFF'S BACKGROUND Linda A. Rohm 227 Webster Street Carlisle, PA 17013 DOB: Occupation: Income: Educational Clerk PA Department of Education 333 Market Street Harrisburg, PA 17126 $38,083.50 Background: College Graduate b. DEFENDANT'S BACKGROUND William A. Rohm 2977 Enola Road Carlisle, PA 17013 DOB: Occupation: 4/24/49 Unemployed Income: $5448 disability, $11,400 unemployment Background: Higt School Graduate Educational c. Date of Marriage: February 2, 1973 d. Place of marriage: Carlisle, PA e. Grounds for divorce: Date of Separation: 3301 (D) Jaruary 12, 2002 f. Issues for determination: Divorce Equitable distribution APL, alimony Counsel fees, costs, and expenses II. PERTINENT PROCEDURAL HISTORY Complaint in Divorce filed: February 6, 2002 Order for Appointment of Master: December 18, 2004 III. INVENTORY APPRAISAL a. Real Estate: 2977 Enola Road Carlisle, PA 17013 $157,000 It is believed the value can be stipulated to. b. Retirements: WIFE: Pennsylvania State Employee's Retirement System. Husband has waived entitlement to wife's pension. (Exhibit 6) HUSBAND: Quaker Retirement plan c. Personal Property: Division of personal property has not been address by the parties; however, it is anticipated and hoped that there will be no outstanding issues regarding this matter. d. Debts: At the time of separation, the parties had no marital debt. IV. WITNESS a. Lay: 1. Plaintiff 2. Defendant, as on cross Plaintiff reserves the right to identify additional witnesses, if necessary. V. EXHIBITS 1. Listing of value of US Savings bonds; 2. Statement of wife's deferred compensation plan; 3. 2002 Statement of Account for wife's SERS plan, along with letter regarding valuation and information concerning SERS' requirements fc.r Domestic Relations Orders; 4. Appraisal report for marita.l residence. 5. Inventory, Income and Expenses. 6. Pension waiver. Plaintiff reserves the right to identify additional exhibits. VI. INCOMB INFORMATION See attached Income and Expense Statement of Plaintiff attached hereto as Exhibit 5. VII. EXPBNSB INFORMATION See attached Income and Expense Statement of plaintiff attached hereto as Exhibit 5. VII. PENSION VALUE See above. IX. PBRSONALTY See above. X. PROPOSBD ECONOMIC RBSOLUTION Wife proposes that the parties divide the DC (at maturity) with each receiving 50%. She proposes that the parties divide the equity in the home with each receiving 50%. Wife proposes that the parties divide husband's Quaker pension with each to receive 50%. Date: ~ ldu~w. ~( Kara W. Hagger VERIFICATION I, Linda Rohm, verify that the statements made in the foregoing Pre-Trial Statement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Date /J1~ /)-, 1.Do'l a/~C0 ZJm LINDA ROHM ' JI1N-jh~UUj rKI ur;je 1111 Lie UtV ::'U~::'lUlt::'lXlzKHNI::' rHX NU, 1II/tj(~ltr Savings Bond Calculator r, U~ Page 1 ofJ Savinc "~''';',i,.1:'i' -.."- ,;' ," ~ 10112003 l~ifJ 8L:H!li!!f21 .".' ..... ,.,;:./ Serie. DeoolDin-'inn Serial NUI.ber b.ue Date lEE Bonds .:.I sI50 ::J '!)j . /I Bond.. Total Prke Tolal ""erelll Total Value YTD la. 52 51,11%.50 54,522.16 55,634.66 522., latue Interclll Nut FInal Sorial Number ..."" Date Serio. Dellom Prlee latorell VII"" Ilale Ate..... Maturity 1l91384482ee 08/1984 EE S50 $25,00 $49.14 $74.14 3.56% 0212003 08/2014 1l81377886ee 0611984 EE 50 25.00 50.44 75.44 3.04% 0612003 0612014 11 72900479ee 04/1984 EE 50 25.00 52.64 77.64 . 358% 0412003 0412014 1l64780522ee 03/1984 EE 50 25.00 5264 77.64 3.58% 0312003 03/2014 1158088696ee 0111984 EE 50 25.00 54.04 79.04 3.05% 0712003 0112014 1148789624ee 1111983 EE 50 25.00 54.04 79.04 3.05% 0512003 1112013 1145487027ee 09/1983 EE 50 25.00 55.96 80.96 3.95% 0312003 09/2013 1144312774ee 0711983 EE 50 25.00 51.56 82.56 3.04% 0712003 0112013 1l39466716ee 05/1983 EE 50 25.00 57.56 82.56 3.04% 0512003 0512013 1115728135ee 04/1983 EE 50 25.00 60.40 85.40 4.01% 0412003 0412013 11 15723818ee 0211983 EE SO 2500 66.58 91.58 6.00"10 0212003 0212013 1115719491ee 1211982 EE 50 25.00 69.32 94.32 400% 0612003 12/2012 195188130ee 1 011982 EE 50 25.00 73.86 98.86 4.00% 0412003 1012012 01321774e 011]980 E 50 31.50 130.18 167.68 4.00% 0112003 0112010 1219121 1 275e 1111979 E 50 37.50 130.18 167.68 400% OS/2003 1112009 12184760566e 0811979 E 50 37.50 128.60 166.10 4.00"10 0212003 0812009 q6338075435e 07/1979 E 25 18.75 65.96 84.71 4.00% 07/2003 0712009 q6327233021e 05/1979 E 25 18.75 65.77 84.52 4.00% OS/2003 0512009 q6306821725e 0211979 E 25 18.75 6496 83.71 4.000/. 0212003 0212009 q630485II Ole 12/1978 E 25 18.75 66.62 85.37 4.00010 0612003 J 212008 q6293343785e 10/1978 E 25 18.75 65.59 84.34 4.00"/. 04/2003 1012008 q6281087014e 07/1978 E 2S 18.75 6127 86.02 4.00% 0712003 0712008 q6256468793e 05/1978 E 2S 18.75 61.04 85,79 4.00% OS/2003 0512008 q6240332576e 03/1978 E 2S 18.75 71.77 90.52 4.01% 0312003 0312008 q622628583ge 1211977 E 2S 18.75 8662 105.37 4.00% 06/2003 12/2007 q6212712373e 10/1977 E 25 1875 95.83 114.58 4.00"10 0412003 1012007 q6198814494e 08/1977 E 25 18.75 95.83 114.58 4.00"10 0212003 08/2007 q6185418553e 06/1977 E 2S 18.75 98.14 116.89 4.00% 0612003 0612007 http://wwws.public:debt.treas.gov/BC/SBCPrice 1130/03 c....~ (V'\.y Ot:l~m~t-:.: L.II\J,Al fJ~N';' "TY p~ ~ SU"QuU) F'.~U EXHIBIT 1 rnfl I'tV. r II fOrLIII r. Vi: JHN-jU-~UUj IHU U~'UI HI'! L1~ UCV ;)UO;)IUIC;)~UMI11;) (~!)l\"\l"'\."oI:'1h.h . Defierred &11't:llIlivh'~IIl;' , .~.l Compensation ~ Program SECURE YOUR }"UTURE. lODAY. ,dm'"J<""',d, ,.,oll,d cmstreet 3nd ,(rvic~d by A~"'I'~II"II"G~.,e.w.l_ ,....~,,~1i-"'UAtDlEMr>' "'0', !mXL!d;M'iih'r;T~" ' <-::.............,....')'Ei:iii~f'''='...,''.,.:,.. 296-36-173'4 .{...:;.itrirlftllilf'iliiliiii~ii')nH'" _.._- 81111142 .-.,..- .......'.,fi'i.tii(d.~lit:iii;;.'C'i.".i...".'......... <a,;", I. . ,,~;flicm'i,.t!nw;: 1-899-422-132~ PAGE I OF 2 1...111,..111",10.11"11,".1,111..".1,11,,.1,,1.11.,,11,.1,1 Refl 019432 GOlY~ LI NDA A ROItt 227 WEBSTER ST CARL]SLE PA 17013-2027 INCEfTIIJN TO OA TC S/MARY INYfSTMtNI fUND" TDTAL DESIGNATION NUMBER CONTRIBUTION CPA GROUP FUNDS AGGREGATE BOND INDEX 0185 312.00 STOCK INDEX FUND 9187 18,0& PLAN TOTALS jlO,OO **PLEASENOTE VlIURFlIURD1.GIT FUNltNUMBERfOI..UU jilE"KfL~UIl("'fD...MORE"'IlE'1"ILS'/"',ioO.................i.(...'.....::',"..... .... ............,. 'ERIOO S/MARY (ll1/DI/Ol - lZl3l/IJ1 ) INYt5IMtN' lUlU) 'UIAL FtR)UP DESIGNATION BALANCE CONTRIBUTION CPA GROUP FUNDS AGGREGATE BOND INDEX 121.82 ]92.00 STOCK INDEX fUND .00 18,00 ">j>tRtoDtiirAt$I'~ElIi ... ..i'iu. BU' DETAILED TRANSACTIIJNS ( lOI'1I'2 .. 1l/3ll'l ) TRMSft:1 PJ5TIUIlUlIUNS IDTU &AINI 1 LOSS) lZ/31 BALANCE .00 ,00 (,25) .11 ,00 ,00 311.75 18.11 .00 ,~~ (.14) Jt~,Mb .~E~....T~~....f;E~TI!~.~I..~~I~~!~.~.....~.~.f~~H9~. .~HT~~........~~~L IlM:!Iittll DUTluaUIIO"5 PtRIUU 'AlN/ 1 LOSS I Il./31 BALANCE .00 .00 .00 .00 (2,07) ,11 31 \. 75 18,11 . ....,li8 .....' . ..... '.. ".;oil>" ":"{I..~j:' ::jZ9:~8ti:::: IMVE::' ..ltN. DATE 10/04/02 10/18/02 10/29/02 11/01/02 11/15/02 11126/02 II 129/02 12/ 13/02 12/24/02 12124/02 .......lUn/02 ....12/'8/02. . 1 RA"5A~ I J OJI DfSCttPTION CONTRIBOTlON CONTRIBUTION ASSET CHARGE CONTRIBUTION CONTRIBUTION ASSET CHARGE CONTR]BUTION CONTRIBUTION ADMINISTRATIVE CHARGE ASSET CHARGE CONlRIBUHoN CONTRIBUTION' .. tUND .. .... 'NAME,.... ". : AGGREGATE BOND INDEX AGGREGATE BOND INDEX AGGREGATE ROND INDEX AGGREGATE BOND INDEX AGGREGATE OONO INDEX AGGREGATE 80ND INDEX AGGREGATE BOND INDEX' AGGREGATE BOND INDEX AGGREGATE BONO INDEX AGGREGATE BONO INDEX . . ....~~i~~~fiEl\l!!5Na~gEf>< ..... ( PLEASE SEE NEXT PAGE ) DULLAR . . AMOUNt- 30.00 30,00 ,03 30,90 30,00 ,04 39,09 30,00 7,50 .05 .)2~0.0.. IBAKl. UNIT ISHARE " . .. -VAt1lE 167,3391 164.7482 166,5574 166,7458 167,2874 167.3239 166.7979 168.3092 169,4828 169.4828 '. .170.mB.. .... . ...'.1'LII'IIlli:...... ONns/ ---"'''SlIAIE$ , 1792 .1820 ,0001 .1799 .1793 .0002 .1798 , 1782 .0442 .0902 ,a704 ...'t';Siii,q EXHIBIT 2 .rl~-20-2UU3 WED 08:24 AM LIP OEV SUBSIDIES&GRANTS 1':; . F",: j;,r . <~. Personal Data ' ,~, --~i)_' . Social SecuritY Number..... -.-!..O,tl:~!l:' 34 Sex: . ..- FEMALE-- Birth ~l_~: 08-0C'l!-' 9 'CoveraJIC}.ypc:'" _____.... ..f . CODlribution hre; eou.:.'Seiing Con.t..:._ -----,,--- Nmmal Retirement nate, fin.1 A;;emse Salary: NOT DET! . 2002 RetiremOni Covered EaminJl&: -----$34.~ "'-6 TOIlII 581 Non-Covered EaniiiigS': '--"-' 'I !', Joint cOVerage Conversion AmclIuij;---' .. .. ... "'-TUn- -- .. . .-----.. .- ."''7~f-' Debt: '..Ii Service Purchase Debt:---....-.--TT'i[-.... Service Credit U of December 31, 200Z !Ii i::i, - .,u. .',". -'l'-~ ._ Clais Vea.. ofs.r.... Clau v.... of3' ....... i. '~"'~j ..... ' -ii., :-- ____L____ ...i-- .:--'i___ - "T~==-~~"'-- _Jm'l'-' TOT.u. SERVICE 1.77: Priadpal Beneficlary(iet) *" "'-----"-..- -'. ~..:;:,i'" . ';:~. ! .. ,.-. .. ---. -------- - -. I':, --._-_.~.._---_.-.. ".._-~-- I... --,. --------'.':"r;:;.} ':'1 'If you tu'. ./igiblo 10 pw'chflS' credittWk stale aruV", ~Ie service, COlUaCI your R"!'8lfJent CQUlUelor fDr. J1IformauQi. ~ purchasinZ service. Allntuem UI purdt.ue Iim1iu .118; te . f." "'hll')lOII IIn tIIJ IICfiofe. f:l>rotnlnltiltg ...IIer. ,. InfOl'7llationfiled on a NOlfllnalltJn of BItI.frciary(I..) Jii,;,,, befo... J993 or smc, December 3J. 2002. or Inl'Olving s~~"" circumstances (8l/ch ... JJu, deslgtr(llion 01 (In /1$101. Or ~ ;.s. your bmuiflciary may be sllow" Mre; however. you may haW, more benqlcl(lrie.s an your reiir_r rocord. KINp your'! i '. b.lIlljic1aryllllonnalioncurrent. YOII""9'cAI_JIOIIt' ',;. HMJIcWy IIDIIWII,II""1It 11I\I' IiIIN by jili. II n.... N...",,""n of ~cimy('-) fer. wiItI SEJtS. Form,_ -hrbIi~4IIl Yftr /IfftCY P'I'JDII". 0JJice or Yftr rqilllUliSEllS RIf(Ij!.'"1 C.....,i"g Cm"r. I'IHu t:tIlIractlU /fJlOu fWlIof Wllllljwiv benqieitBJl{iG) IbIH "" jIIIruy SIJI'""..Is.] : 'Ii 11.1111111111..111111 ! j' I 'I .'lDOO86i6- FAX NO, 7177P"?117 ?, 02 ACCOUNT [!Z) 1 ACCOlUlt Bal8nee ~---"--Siii---'" . CaatributiolS . CllIlIribuliolli - ber 31 :!OOI~.~e i $1.018.821._._ utiOlls I U.lal.S3 : .n'.'..,..... I ..._..... lUll Pa)m_ I --".'M'_ .. .. I n. ..____ Payllle!~t.~.___.1--__._.._ : _1D!e"'!1t '88.16 I liusuntDts ... I r 31. 2(lOa. Bal.+' $8.231.81 r-- AI. DEDtfCTJONS $3.231.61 Arrean BaIaaee 8$ of Deeember 31. Zotz SSI Taxable Drukdown of Your Account U.. Ie COIltribUlioos $3,138.96 . Non- Tax,oble Contributions ---..~ ~ 86 NOD- Ta.;able Conl:ibutiono i~jj'iii_t.f!flJlllble) -. ..---- .....$92.86 ber 31, 2C102. BalllllCe"---- $8.23i~61- . YTD (Year-l'o-Date) N/iUltmMlS ref/'cl C"17eC1i<>II$,O y, . ai'cov,,'for which you already II,,,,,, r<<eived nOlificatioll. . 3ERs is a ..fined bl!llllfil plan under Inte,."al R..."". s.. . ~ Cotk S.c't1on ilOJ (a). SPEClAL CONDITIONS 1'1 Ilawing Sp..c/al conJltion., apply It> yowr benifu ..,1_ or . JM e.mmtue.s were nor cDlculated: I y, Ilal/tl' insu(ficiene .ervice eNdit. to qualify for G "blUey or. "'/IIII"r 1'fItiremene berae/ie. 11111....111111 OSO'iOIOO-8wC>.\........ou, EXHIBIT 3 llnl\ VI CWo rnl u","~ nil LID Vr.v "UDulVlr."&lrKHI~I" '"n' ,_.- tH^ NU, 11 "NI~III y, U~/lj , .\ .(<~~" , .'~-'-.'i. I ~'Y13-~1~~ .t:rJ~~ ,""~) ,'.... ~.- ~.-.;; . .:->' .' COMMONWllALTH OF PENNSYLVANIA STATE EMPLOYEES' UnUMENT SYSTEM HARRISBUItll RllGIONAL couNSELINO CBNTEIl )0 NOIl1'lI THIRD S'\'II!llT. ROOM 119 HARRlSBURlO FA 17101 71771109065 1400.6)3.$461 FAX, 7I707&1.9S99 www............pI.l1I March 5, 2003 LINDA A. ROHM 227 WEBSTER ST. CARLlSLEPA 17013 SSN 206.36.1734 Dear Ms. Rohm; Per your request I have calculared the value of your retiremcnt account as of today for a divorce matter. As of today' s date, you have 2.0 years of CNldited service lUll! as SIICb are not vested for pension benefits with our System. Therefore, the value of your account is limited to your total accumulated contrlbutiollB and interest, which are $3,708.94. lfyou leave State employmllllt at this time, that amount would be paid in a I~lp sum and the account would be closed. Attached pleuc find infonnalion concerning SBRS' requirements for Domestic Relations Orders. You should give this infonnation to your attorney !i)r rllView. If the attorney bas any questions, belsbe can contact our legal division directly. I trust this infoDnation will adequately address you inquiry. Sincerely, ~F!~ Jane K.uldish, Manager Harrisburg Regional COImseling Center I I I I I I I I I I I I I I I I I I I APPRAISAL REPORT OF A SINGLE-FAMILY DWELLING LOCATED AT 2977 ENOLA ROAD CARLISLE, PENNSYL V ANlA PREPARED FOR LINDA A. ROHM AS OF APRIL 23, 2003 BY LARRY E. FOOTE DIVERSIFIED APPRAISAL SERVICES EAST HIGH STREET, SUITE 101 CARLISLE, PENNSYL V ANL<\. 17013-3052 (717) 249-2758 EXHIBIT 4 , I I I I I I I I I I I I I I I I I I I SUMMARY OF IMPORTANT FACTS ANI) CONCLUSIONS LOCATION: 2977 Enola Road Carlisle, Pennsylvania TAX PARCEL NUMBER: 14-05-0423-020A IMPROVEMENTS: A single-family dwelling. PROPERTY RIGHTS: Fee simple interest. OWNERSHIP HISTORY: The subject property is owned by William A. and Linda A. Rohm. The properly was purchased on March 15, 1974 for a reported consideration of $12,000 and ownership transferred on deed reference 25-N-581. SCOPE OF THE ASSIGNMENT: The scope of the assignment included an analysis of the subject's area, an inspection of the subject property, an estimation of the property's highest and best use, consideration of all thme approaches to value, and the application of those relevant to the valuation of the subject. OBJECTIVE: To estimate the market value of the subject property as unencumbered. EFFECTIVE DATE: April 23, 2003. HIGHEST AND BEST USE: Use as a single-family residence. COST APPROACH: N.A. SALES APPROACH: $157,000 INCOME APPROACH: N.A. FINAL VALUE CONCLUSION: $157,000 2 I I I r: r [ ( I I I I I I ( I I I I I APPRAISAL CERTIFICATION I hereby certify that upon application for valuation by: LINDA A. ROHM the undersigned personally inspected the following described property: All that certain piece or parcel of land, with the improvements thereon erected, situate in Lower Frankford Township, Cumberland County, Pennsylvania, bounded and described as follows: Beginning at a point in the centerline of Enola Road, which point is located 876.62 feet northeasterly of the intersection ofL.R. 21001 and L.R. 21033; thence by centerline of Enol a Road north 41 degrees 14 minutes 46 seconds east 350.00 feet to a point; thence by lands now or formerly of Edward L. Wertz and Warren Gingrich south 44 degrees 07 minutes 55 seconds east 600.00 feet to an iron pin; thence by same north 41 degre'~s 14 minutes 46 seconds east 235.00 feet to an iron pin on line ofJands of James Leidig; th~:nce by aforesaid lands south 44 degrees 07 minutes 55 seconds east 192.85 feet to a stone; thence by same south 04 degrees 52 minutes 11 seconds west 316.35 feet to an iron pin; thence by same south 09 degrees 06 minutes 41 seconds east 338.56 feet to a stump; thence by same south 75 degrees 20 minutes 21 seconds west 131.23 feet to a fence post on line of lands of Edlward L. Wertz and Warren Gingrich; thence by aforesaid lands north 45 degrees 53 minutes 26 seconds west 1,166.49 feet to a point in centerline of Enol a Road being the place of beginning. Containing 10.247 acres. To the best of my knowledge and belief the statements contained in this report are true and correct, and that neither the employment to make this appraisal nor the compensation is contingent upon the value reported, and that in my opinion the Market Value as of April 23, 2003 is: ONE HUNDRED FIFTY-SEVEN THOUSAND DOLLARS $157,000 The property was appraised as a whole, subject to the contingent and limiting conditions outlined herein. x~~~ Larry E. Foote Certified General Appraiser GA-0000!14-L I I I I I I I I I I I I I I I I I I I PURPOSE OF THE APPRAISAL The purpose of this appraisal is to estimate the Market Value of the subject property as of April 23, 2003. Market Value, as defined by the courts, is the most probable price estimated in tenns of money which a property will bring if exposed for sale in the open market, allowing a reasonable time finding a purchaser who buys with knowledge of all the uses to which it is adapted and for which it is capable of being used. Frequently, it is referred to as the price at which a willing seller would sell and a willing buyer would buy, neither being under abnonnal pressure. HIGHEST AND BEST USIL Highest and Best Use is defined by the Appraisal Tenninology and Handbook, published by the Appraisal Institute, as "the most profitable likely use to which a property can be put". The opinion of such use may be based on the highest and most profitable continuous use to which the property is adapted and needed, or likely to be in demand, in the reasonable near future. However, elements affecting value that depend upon events or a combination of occurrences which, while within the realm of possibility, are not fairly shown to be reasonably probable, should be excluded from consideration. Also, if the intended use is dependent on an uncertain act of another person, the intention cannot be considllred. Based on the above definition and after seeing the site, neighborhood, and area, it is my opinion that the present use of the subject is its Highest and Best Use. 4 SITE DATA ADDRESS: 2977 Enola Road BOROUGH: Carlisle COUNTY: Cumberland STATE: Pennsylvania LOT SIZE: 10.247 acres. SEWERS: On-site septic system. WATER: On-site well. ELECTRICITY: Adams Electric. LANDSCAPING: Typical for the area, with a sodded lawn, trees and shrubs. DETRIMENTAL INFLUENC]~S None. Pride of ownership is evident throughout the neighborhood. DESCRIPTION OF IMPROVEMENTS GENERAL DESCRIPTION: One-story detached single-family dwelling contammg approximately 1,500 square feet of gross living area above grade, with an exposed basement that includes a two-car integral garage. CONDITION: Exterior: Average Interior: Average ROOMS: First Floor: Living room, kitchen, dining room, three bedrooms and two full bathrooms. Basement: Full, divided into a finished family room, storage room, and a two-car garage. 5 I I I I I I I I I I I I I I I I I I I EXTERIOR: Foundation: Walls: Sash: Gutters: Roof: Concrete block. Stone Vinyl-clad thermopanes. Aluminum, painted. Asphalt shingles. INTERIOR, PRINCIPAL ROOMS: Flooring: Walls: Ceilings: Trim: Carpet and hardwood. Drywall Drywall Wood, stained and varnished. KITCHEN: BATHROOMS: CONSTRUCTION: HEATING: COOLING: HOT WATER: ELECTRIC: Cabinets: Counters: Walls: Flooring: Sink: Flooring: Walls: Bathtub: Lavatory: Water closet: Joists: Beams: Columns: Plumbing: Heat pump. Wood, stained and varnished. Formica Drywall, papered. Carpet Double-bowl, porcelain. Vinyl Drywall, papered. Built-in, with shower or shower stall. Vanities Two-piece. Wood Wood Steel Plastic Central air conditioning. Electric, 60-gallon. Circuit breaker system, 200-ampere. OTHER: There is a stone fireplace located in the lower level family room. Attached to the front of the dwelling is an enclosed porch and attached to the rear of the dwelling is a large covered porch. Also located on the site is a 600 square foot detached storage building with electrical service. GENERAL CONDITION: All improvements are considered to be in good condition on the interior and on the exterior, with mechanical systems appearing to be adequate and functioning properly. 6 THE APPRAISAL PROCESS Three approaches to value are generally included in an appraisal report. These techniques include the cost approach, sales comparison approach, and income approach to value. The cost approach to value is based on the assumption that the reproduction cost of a building plus land value, tends to set the upper limit to value. A key assumption is that a newly constructed building would have advantages over the existing building, therefore an evaluation focuses upon disadvantages or deficiencies (depreciation) of the existing building compared to a new facility. Due to the age of the subject improvements, the cost approach is considered to be inappropriate and has, therefore, not been included in the' development of this appraisal report. The sales comparison approach to value assumes that under normal conditions, a given number of parties acting intelligently and voluntarily, tend to set a pattern from which value can be estimated. Application of this approach relies on a comparison of the subject with a sufficient number of recent transactions of comparable properties in the market, based on a common unit, such as price per square foot of building area. The income approach concerns itself with present worth of the future potential benefits of a property. The initial estimate involves the net income, which a fully informed person is justified in assuming the property will produce during its remaining useful life. This estimated net income is then capitalized into a value estimate, based upon the level of risk as compared with that of a similar type and class. Since homes similar Ito the subject are not typically utilized as income-producing investment properties, the income approach to value is considered to be inappropriate and has, therefore, not been included in the development of this appraisal report. 7 SALES COMPARISON APPROACH In arriving at this conclusion of the value of the subject property, the appraiser made a survey of properties that have sold in the area of the subject property. Consideration was given and adjustments were made on each comparable sale as to time of sale, size, location, as well as all other factors that might affect value. A resume of some of the sales considered by the appraiser is as follows: SALE NO.1: Location: Date of Sale: Sale Price: Size: Unit Price: SALE NO.2: Location: Date of Sale: Sale Price: Size: Unit Price: SALE NO.3: Location: Date of Sale: Sale Price: Size: Unit Price: 460 Pleasant Hall Road, Carlisle. October 31, 2002. $142,500 1,747 square feet. $81.57 per square foot. 34 Fish Hatchery Road, Newville. September 14,2002. $179,900 1,860 square feet. $96.72 per square foot. 698 Brandy Run Road, Newville. September 13, 2002. $162,900 1,673 square feet. $97.37 per square foot. The appraiser, in addition to the sales listed, also considered several additional sales in arriving at his final opinion of value. On the Sales Comparison Analysis form that follows this page are dollar adjustments reflecting market reaction to thos,e items of significant variation between the subject and comparable properties. If a signHicant item in the comparable property is superior to, or more favorable than, the subject property, a minus (-) adjustment is made, thus reducing the indicated value of the subject; if a significant item in the comparable is inferior to, or less favorable than, the subject property, a plus (+) adjustment is made, thus increasing the indicated value of the subject. After making all of the necessary adjustments, it is the appraiser's considered opinion that the indicated value of the subject property by the Sales Comparison Approach is $157,000. 8 SALES COMPARISON ANAI_ YSIS ITEM SUBJECT COMPARABLE #1 COMPARABLE #2 COMPARABLE #3 2977 Enola Road 460 Pleasant Hall Road 34 Fish Hatchery Hoad 698 Brandy R\UJ Road Address Carlisle Carlisle Newville Newville Proximity to Subject :t"~~~." ~~ c" $162,900 Sale Price Price I Sq. Ft. GLA NA $8157' '.,.;'. "" ,$%,72 iiI, '''. $9137 Data Source Inspection Central Penn tv!LS Central Penn MLS Central Penn MLS ADJUSTMENTS DESCRIPTION DESCRlI'TION $ Adjust. DESCRII'I10N $ Adjust. DESCRlP'nON $ Adjust. Sales or Financing Concessions None None None Date of Sale I Time As of 4-23'()3 1O.31.()2 9-14.()2 9-1.l'()2 Location Average Superior -14,300 Similar Similar Site/View 10.247 acres 1.25 acres +18,000 6.49 acres +7,500 3.32 acres +13,900 Design .nd Appeal One--story detached Similar Similar Similar Construction Stone Brick +3,000 Brick +3,000 Brick +3.000 Age 27 years 43 years +14,300 26 years 29 years Condition Average Similar Superior -5,000 Superior -5,000 Above Grade Tot. Bed. Bath Tot. Bed. Bath Tot. Bed, Bath Tot. Bed. Bath Room Count 6 3 2 6 3 2 6 3 2 7 3 2 -2,000 Gross Living Area 1,500 square feet 1,747 square leet -9,900 1,860 square feet +14,400 1,673 square feet -<>,900 Basement &Finished FulJ basement.. with Rooms Below Grade family room. Similar Full basement +2,000 Full basement +2,000 Functional Utility Average Similar Similar Similar Heating: I CoolimI Heat oumo Oil hot wtr. w/c.air Baseboard electric +2,000 Baseboard electric +2 000 Oanule I Carport 2 -car intearal g,afa2e 2-car attached ll8rtUle -2,000 2_ attached """Ole -2,000 2..car attached aanuze -2,000 Porches, Patios Porch, encl. poroh, Enclosed poroh, 30' x 60' storage Pools, etc. storaQ.e buildinQ.. hreezaw.v. +5,000 building:. areenhouse -5,000 Porch, end. rKm:h. +5,000 Special Energy Typical for the Efficient Items reszion. Similar Similar Similar Firool.ce{s Firoolace Similar FnIc. & woodstoVt: -1,000 Similar Other (e.g. kitchen equip., remodeling) Built~ins. . Similar Similar Similar Net Adi, (total) " +14,100 -12,900 )iI'.'" + 10,000 Indicated Value of Subject ;::.;;<, . , " " - SI56,600 $167,000 -"n ... " $172,900 FINAL INDICATED VALUE OF SUBJECT PROPERTY: $157,000 9 .. UNDERLYING ASSUMPTIONS AND UMITING CONDITIONS SUBJECT TO THIS AJ'PRAISAL I. I assume no responsibility for matters legal in nature, nor do I render any opinion as to the title, which is assumed to be marketable. The propelty is appraised as though under responsible ownership. 2. The legal description used herein is correct. 3. I have made no survey of the property, and the boundaries are taken from records believed to be reliable. 4. I assume that there are no hidden or unapparent conditions of the property, subsoil or structures which would render it more or less valuable. I assume no responsibility for such conditions or for engineering which might be requir1ed to discover such factors. 5. The information, estimates, and opinions furnished to me and contained in this report were obtained from sources considered reliable and believed to be true and correct. However, no responsibility for accuracy can be assumed by me. 6. This report is to be used in its entirety and only for the purpose for which it was rendered. 7. Neither all nor any part of the contents of this report (especially any conclusions as to value, the identity of the appraiser or the firm with which he is connected) shall be reproduced, published, or disseminated to the public through advertising media, public relations media, news media, sales media, or any other public means of communication, without the prior written consent and approval of the appraiser. 8. This appraisal was prepared for the exclusive use of the client identified in this appraisal report. The information and opinions contained in this appraisal set forth the appraiser's best judgment in light of the information available at the time of the preparation of this report. Any use of this appraisal by any other person or entity, or any reliance or decisions based on this appraisal are the sole responsibility and at the sole risk of the third party. The appraiser accepts no responsibility for damages suffered by any third party as a result of reliance on or d(:cisions made or actions taken based on this report.1 10 CERTIFICATE OF APPRAISAL Your appraiser hereby certifies that: 1. The statements of fact contained in this report are true and correct. 2. The reported analyses, opinions, and conclusions are limited only by the reported assumptions and limiting conditions, and are my personal, impartial, and unbiased professional analyses, opinions, and conclusions. 3. I have no present of prospective interest in the property that is the subject ofthis report, and no personal interest with respect to the parties involved. 4. I have no bias with respect to the property that is the SUbjllct of this report or to the parties involved with this assignment. 5. My engagement in this assignment was not contingent upon developing or reporting predetermined results. 6. My compensation for completing this assignment is 110t contingent upon the development or reporting of a predetermined value or direct1ion in value that favors the cause of the client, the amount of the value opinion, the attainment of a stipulated result, or the occurrence of a subsequent event directly related to the intended use of this appraisal. 7. To the best of my knowledge and'belief, the statements of fact contained in this appraisal report, upon which the analyses, opinions, and conclusions expressed herein are based, are true and correct. 8. This appraisal report sets forth all of the limiting conditions (imposed by the terms of my assignment or by the undersigned) affecting the analyses, opinions, and conclusions contained in this report. 9. This appraisal repo,rt has been made in conformity with the Uniform Standards of Professional Appraisal Practice adopted by the Appraisal Standards Board of the Appraisal Foundation, and is subject to the requirements of the Code of Professional Ethics and Standards of Professional Conduct of the National Association of Realtors Appraisal Section. II 10. No one other than the undersigned prepared the analyses, conclusions, and opinions concerning real estate that are set forth in this appra!isal report. /~~ Larry E. Foote Certified General Appraiser GA-OOOOI4-L 12 LARRY E. FOOTE REAL ESTATE APPRAISER EXPERIENCE: 1979-Present: Chief Appraiser, Diversified Appraisal Services, Carlisle, Pa. Principal Broker, LaRue Development Compal1LY, Carlisle, Pa. 1976- 1 979: Associate Broker, Colonial Realty, Carlisle, Pa. 1972-1976: Realtor Associate, Jack Gaughen Realtor, Carlisle, Pa. Appraisal experience included undeveloped land, fanns, building lots, single-family dwellings, mobile home parks, medical centers, nursing homes, motels, apartment buildings and complexes, office buildings, service stations, veterinmy clinics, rehabilitation centers, retaill buildings, daycare centers. warehouses, and manufacturing facilities. EDUCATION: Bachelor of Business Administration, Pennsylvania State University, 1976. Associate Bachelor of Business Administration, Harrisburg Area Community College, 1974. Diploma, Carlisle Senior High School, 1965. Certificate, Pennsylvania Realtors Institute, GRI I, GRI II. GRI III. Certificate, Realtors National Marketing Institute, CI 101. CI 102, CI 103, C1 104, CI 105. Standards of Professional Practice, American Institute of Real Estate Appraisers. Real Estate Appraisal Principles. American Institute of Real Emile Appraisers. Residential Valuation, American Institute of Real Estate Appraisers. Appraisal Procedures, Appraisal Institute. Principles of Income Property Appraising, Appraisal Institute. Case Studies in Real Estate Valuation, Appraisal Institute. Report Writing and Valuation Analysis, Appraisal Institute. PROFESSIONAL LICENSES: General Appraiser #GA-000014-L, Commonwealth ofPennsylv:mia. Real Estate Broker #RB-029729-A, Commonwealth of Pennsylvania. PROFESSIONAL DESIGNATIONS: GR1: Graduate of the Pennsylvania Realtors Institute, awarded by the Pennsyl- vania Association of Realtors. CRS: Certified Residential Specialist, awarded by the Realtors National Market- ing Institute of the National Association of Realtors. CCIM; Certified Commercial Investment Member, awarded by the Realtors National Marketing Institute of the National Association of Realtors. PROFESSIONAL ORGANIZATION AFFILIATIONS: National Association of Realtors Appraisal Section. Carlisle Association of Realtors. Pennsylvania Association of Realtors. National Association of Realtors. Realtors National Marketing Institute. 13 PAST CLIENTS: Borough of Carlisle Keystone Financial Mortgage Cornerstone Federal Credit Union Pennsylvania State Bank Commerce Bank Cumberland-Perry Association for Retarded Citizens Carlisle Suburban Authority Members I" Federal Credit Union Pennsylvania National Bank Evans Financial Corporation Greenawalt & Company, CPA Smith's Transfer Corporation Carlisle Department of Parks and Recreation Executive Relocation Services Carlisle Area School District Messiah Homes, Incorporated ERA Eastern Regional Services Pennsylvania Turnpike Commission Chase Home Mortgage Corporation Defense Activities Federal Credit Union Pennsylvania State Employees Credit Union PNC Mortgage Corporation F&M Trust Company National City Mortgage Corporation Washington Mutual Home Loans, Inc. Prudential Relocation Services Lender's Choice Market Intelligence, Incorporated United Telephone Employees Federal Credit Union Cumberland County Commissioners Allstate Enterprises Mortgage Corporation Dickinson College PPG Industries, Incorporated Gettysburg CoJlege Redevelopment Authority of Cumberland County Record Data Appraisal Services, Incorporated First United Federal Savings Association Fulton Bank United States Marshall Service GMAC Mortgage Corporation Orrstown Bank Letterkenny Federal Credit Union BancPlus Mortgage Corporation Coldwell Banker Relocation Services, Incorporated Central Pennsylvania Savings Bank Mellon Bank Provident Home Mortgage Corporation Drovers Bank 14 American Home Bank Trans Union M&T Mortgage Corporation Cody Finlmcial Mortgage Services Waypoint Bank Northwest Savings Bank Blue Ball National Bank Adams County National Bank Countrywide Home Loans Aarrow Mortgage Various law fIrms and individuals PHOTOGRAPHS OF THE SUBJECT IMPROVEMENTS 15 PHOTOGRAPHS OF THE SUBJECT IMPROVEMENTS 16 EXHIBIT 5 LINDA A. ROHM, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, P A v. NO. 02-649 CIVIL WILLIAM A. ROHM, Defendant IN DIVORCE INVENTORY OF WILLIAM A. AND LINDA A. ROHM Plaintiff f1les the following inventory of all properly owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. I, LINDA A. ROHM, verify that the statements made in this inventory are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa CS ~ 4904, relating to unsworn falsification to authorities. /J1~ .5; Zc:{Y! Date ~t/Cl-- ;p.-cl/?( LINDA ROHM ASSETS OF THE PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. (X ) 1. Real Property () 2. Motor vehicles () 3. Stocks, bonds, securities and options () 4. Certificates of deposit () 5. Checking accounts, cash () 6. Savings accounts, money market and savings certificates () 7. Contents of safe deposit boxes () 8. Trusts () 9. Life insurance policies (indicate face value, cash surrender value, and current beneficiaries) () 10. Annuities () 11. Gifts () 12. Inheritances () 13. Patents, copyrights, inventions, royalties () 14. Personal property outside the home () 15. Business (list all owners, including percentage of ownership, and officer/director positions held by a party with company) () 16. Employment termination benefits-..severance pay, worker's compensation claim/ award () 17. Profit sharing plans (X) 18. Pension plans (indicate employee contribution and date plan vests) (X) 19. Retirement plans, Individual Retirement Accounts () 20. Disability payments () 21. Litigation claims (matured and unmatured) () 22. Military /VA benefits () 23. Education benefits () 24. Debts due, including loans, mortgages held (X)25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute) () 26. Other MARITAL PROPERTY Plaintiff lists all marital property in which either or both spouses have a leg,li or equitable interest individually or with any other person as of the date this action was commenced: ITEM DESCRIPTION OF PROPERTY NUMBER NAMES OF AI.J... OWNERS light (table) Linda Curio Cabinet Linda Wash stand-gift from Dixie Linda Entertainment unit & contents Linda Small stand (3-legged) Linda Grandmother's Clock-gift H to W Linda Table & chairs Linda Dry sink-gift H to W Linda Stand (made by W uncle) Linda Ladies rocker Linda Cherry end table Linda Foot stool Linda Oak dresser Linda Quilt rack & quilts Linda Desk light Linda Night stands Linda Night stand lights Linda light shades Linda Recliner (green) Linda Wicker light-gift from sons Linda Chest-made by W father Linda Bookcase & books Linda Stool (by IV) Linda Sofa table-made by Daniel Linda Dolls Linda Maple bed frame Linda Artificial plants Linda Pictures-cross stitch, old tyme (2), Linda family (Keller-4), boy's senior pictures, dining room (3), boys' collages (hall) Gramp Rohm cutting board or circle Linda ITEM DESCRIPTION OF PROPERTY NUMBER plaque Holiday decorations Full size bed sheets & blankets Tractors (2 antique Fannall) A TV & trailer-new 2001 Table Chairs Cabinet TV Sofa End Table Light Rocker Bed Desk & chair TV Chest of drawers Dresser Gun cabinet & contents Recliner Wheel table Hanging light Bar stools End table Sofa NAMES OF ALL OWNERS Linda Linda William William William William William William William William William William William William William William William William William William William Willimn Willimn Wilfum NON-MARITAL PROPERTY (plaintift)(Defendant) lists all property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property; ITEM DESCRIPTION OF PROPERTY NUMBER REASON FOR EXCLUSION Piano Kitchen clock Mande clock Wing chair End table & light library table Blanket chest Sewing Machine Round table Owned by W prior to marriage Owned by W prior to marriage Owned by W prior to marriage Owned by W prior to marriage Owned by W prior to marriage Owned by W prior to marriage Owned by W prior to marriage Owned by W prior to marriage Owned by W prior to marriage PROPERTY TRANSFERRED ITEM DESCRIPTION OF NUMBER PROPERTY DATE OF CONSIDERATION PERSON TO WHOM TRANSFER TRANSFERRED LINDA ROHM, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, P A v. NO. 02-649 CIVIL WILLIAM A. ROHM, Defendant IN DIVORCE PLAINTIFF'S INCOME AND EXPENSE STATEMENT I, LINDA ROHM, verify that the statements made in this Income and Expense Statement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Date $c:5 S, 2=<( ,./. ~,.t? ff0?/dC;, /fc#hr1. LINDA ROHM INCOME: Employer: Address: PA Department of Education 333 Market Street Harrisburg, PA 17126 Clerical 516847 Type of Work: Payroll Number: Pay Period: Biweekly Gross Pay per Pay Period: Itemized Payroll Deductions: Federal Withholding Social Security Local Wage Tax State Income Tax Retirement Savings Bonds Credit Union Life Insurance Health Insurance Other (specify) Net Pay per Pay Period: 1,464.75 164.74 90.81 23.44 44.97 91.55 4.00 21.23 Medicarle 1.32 Unempl()yment 13.98 Union Fair Share 125.00 Deferred Comp $883.71 OTHER INCOME: Weekly Monthly Yearly Interest Dividends Pension Annuitly Social Security Rents Royalties Expense Account Gifts Unemployment Compensation Worker's Compensation Other: $127.00 Total $0.00 0.00 $127.00 EXPENSES: Weekly Monthly Yearly Home: MortgagelRent Maintenance 3,910.00 Bathroom remodel Utilities: 90.00 Electric Gas Oil Telephone 145.00 Water Sewer Employment: Public Transportation Lunch 25.00 Taxes: Real Estate Personal Property 26.00 Income 3,942.00 Insurance: Homeowners Automobile 65,2.00 Life Accident Health 1,090.00 Dan Other Automobile: Payments 300.00 Fuel 30.00 Repairs 180.00 Medical: Doctor: 81.00 Dentisti 92.00 Orthodontist Hospital Medicine 208.00 Special Needs: Eye glasses Braces Orthopedic Devices Education: Private School Parochial School College Religious Personal: Clothing Food Barber/Hairdresser Credit Payments Credit Card Charge Account Memberships Loans: Credit Union Other: 1,500.00 Brian 400.00 110.00 135.00 600.00 400.00 Miscellaneous: Household Help Child Care Subscriptions Entertainment Pay TV Vacation Gifts Legal Fees Charitable Contributions Child Support Payments Alimony Payments Other: PetsNet 28.00 25.00 45.00 Cable 2,000.00 1,800.00 1,250.00 260.00 280.00 TOTAL EXPENSES: $165.00 860.00 $18,579.00 x52 x 12 $8,580.00 10,320.00 $37,479.00 TOTAL PROPERTY OWNED: Description Value H W J C Checking Accounts Savings Accounts Credit Union Stocks/Bonds RealEstate Other TOTAL 0.00 INSURANCE: Hospital Blue Cross Other Medical Blue Shield Other Health/Accident Disability Income Dental Other Company No. . H = Husband; W = Wife; J = Joint; C = Child H W C I, Willir,m A. Rohm, of 2977 Enola Road, Carlisle, P A 17013, do hereby waive and revoke any past, present or future claim to the Pelllisylvania State Employees Retirement System account and any supplemental retirc;11cnt account created during state employment of Linda A. Rohm. I h2ve hereunto set my h3nd and seal this 1'1 day of May, 2003. / ,-;;j',~ .' t ~ , ..4~""/" /-.f < .'r~ ';>2_ t-..r /' ?~~,__--... _ ~~",.~_~___,....L....j.__ , Wiliiam A. Ilolm1 (SEAL) COMMONWEALTH OF PENNSYLVANIA ) 55 COUNTY OF CUMBERLAND ) On this & day of May, 2003, before me, the undersigned officer, personally appeared the above named William A. Rohm, known to me, or satisfactorily proven to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same as his free act and deed. IN WITNESS \VI-lEREOF, I have hereunto set my hand and seal the day and year urst above written. l'\ '\ ~_. . \ tary Public \ i~O I AF'.IAL SEAL APRIL D. SdEAr=FER, NClary Pub]" Carlisle Cumberland County Mv COiTlm:'::~!c>n Exp:res ,A,pril 23, 2.:' I. ~_"'~ EXHIBIT 6 CBRTIFICATB OF SBRVJ:CB AND NOW, this ,5~day of MAY, 2004, I, Kara W. Haggerty, Esquire, of ABOM & KUTULAKIS, LLP, hereby certify that I did serve a true and correct copy of the foregoing Defendant's Pre-Trial Statement by depositing, or causing to be deposit1ed, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Bradley L. Griffie, Esquire Griffie & Associates 200 North Hanover Street Carlisle, PA 17013 Divorce Master 9 North Hanover Carlisle, PA 17013 Respectfully submitted, ABOM & KUT'OLlUCIS, LLP DATE ~u-w. fl Kara W. Ha~3'ge ire 36 S. Han~~er treet Carlisle, PA 17013 (717) 249-0900 ID No. 86914 Attorney for Plaintiff (") ...., (") = C ceo> -n ;.~ .r:- -...;~ ::rJ To , :;.-:-,... fl'j f"';; -::: -0 ~,C! I ....:..~ --r' C" ~=~ ~) ~:: ".-,.- --H "'j"" ~~ ",. .._- :.;:'; ,- .~ ' ) ., (jlll ),,' \.,n -,.:~ ~ CJ '"I) .t.-- '< LINDA A. ROHM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW WILLIAM A. ROHM, Defendant : NO. 2002-649 CIVIL TERM : IN DIVORCE NOTICE TO PLEAD You are hereby notified to file a written response to the within Counterclaim within twenty days (20) days from service hereof or a judgment may be entered against you. LINDA A. ROHM, Plaintiff ; IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW WILLIAM A. ROHM, Defendant : NO. 2002-649 CIVIL TERM : IN DIVORCE ANSWER TO COMPLAINT IN DIVORCE AND COUNTERCLAIM AND NOW comes Defendant, William A. Rohm, by and through his counsel of record, Marylou Matas, Esquire, and answers Plaintiff's Complaint as follows: I. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. Admitted. WHEREFORE, Defendant requests your Honorable Court to grant Plaintiff's request for the entry of a Decree in Divorce. COUNT II - EQUITABLE DISTRIBUTION 9. Defendant's Answers to Plaintiffs paragraphs I through 8 are incorporated herein as if set forth in their full text. 10. Admitted in part and denied in part. It is admitted that Plaintiff and Defendant have acquired personal property during their marriage, from February 2, 1973 to the date of their separation. It is denied that January 12, 2002, is the date of separation. Defendant avers that January 10,2002, is the date of separation. 11. Admitted. WHEREFORE, Defendant requests your Honorable Court to equitably divide all marital property owned by Plaintiff and Defendant. COUNTERCLAIM COUNT III ALIMONY. ALIMONY PENDENTE LITE. COUNSEL FEES. COSTS AND EXPENSES 12. Defendant's Answers Plaintiff's Paragraphs I through 11 are incorporated herein by reference as if set forth in their full text. 13. Defendant is unable to provide for, or afford his I~ounsel fees, expenses and costs during the pendency of this divorce action, and through its resolution. 14. Defendant is without sufficient property and otherwise unable to financially support himself through appropriate employment. 15. Plaintiff is presently employed and receiving a substantial income and benefits and is able to pay for counsel fees, expenses, and costs, as well as alimony, and alimony pendente lite for the Defendant. WHEREFORE, Defendant requests your Honorable Court to enter an Order requiring Plaintiff to pay for Defendant's counsel fees, expenses, and costs as well as providing for payment of an appropriate alimony and alimony pendente lite to Defendant. Respectfully submitted, OA IY\ cctC4J t s, Esquire Attorney fa efendant GRIFFIE & ASSOCIATES 200 North Hanover Stree1 Carlisle, P A 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: ~ -;2. - 0 'I '/;f- a~ WILLIAM A. ROHM . . r p '- -~ \' v, ~ -- l" " '" -> ':-? r-o 0 C:) L_ c',:) -n J:' ~ __'0 ~ .--1 l-~ :r -I""j . lnF~ ] -.jrn I -:':JC;:J GO S~> -:_~-- -+i -'.1 \_) (') :J:.' "" ~ ,) r.. * f:? ---, <:> 0 -', .j;" ~,...- 2 N t ? . ~ DR#: LINDA A. ROHM, IN THE COURT OF COMMON PLEAS OF Plaintiffi'Respondent CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW WILLIAM A. ROHM, : NO. 2002-649 CIVIL TERM DefendantJPetitioner : IN DIVORCE PETITION FOR ALIMONY PENDENTE LITE. INTERIM COUNSEL FEES AND EXPENSES AND NOW comes Petitioner, William A. Rohm, by and through his counsel of records, Marylou Matas, Esquire, and petitions the Court as follows: I. Your Petitioner is the above named Defendant, William A. Rohm, an adult individual currently residing at 2977 Enola Road, Carlisle, Cumberland County, Pennsylvania. 2. Your Respondent is the above named Plaintiff, Linda A. Rohm, an adult individual currently residing at 227 Webster Street, Carlisle, Cumberland County, Pennsylvania. 3. Petitioner's date of birth is April 24, 1949, and his Social Security number is 184-38- 1079. 4. Respondent's date of birth is October 3, 1949, and her Social Security number is 206- 36-1734. 5. The divorce action filed to the above docketed number in the Court of Common Pleas of Cumberland County requests a divorce based upon Section 3301(c) of the Divorce Code of 1980 as amended. 6. Petitioner has employed counsel and will incur certain costs and expenses in pursuit of the aforementioned divorce action, but is without sufficient assets or income to support himself, pay for attorney's fees, or pay for the costs and expenses associated with this action. 7. Respondent has sufficient income and earning capacity, as well as assets, to support the Petitioner or to assist in supporting Petitioner, Imd to pay alimony pendente lite to Petitioner, as well as assist in paying his counsel fees, costs and expenses. WHEREFORE, Petitioner requests you Honorable Court to enter an Order of Alimony Pendente Lite, Interim Counsel Fees, Costs and Expenses in this matter. Respectfully submitted, ,. ~'-m~ ~ Marylou Attorney for eftndantlPetitioner GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: '-;2.- 6</ #_ a ,4/ VI LLlAM A. ROHM Plaintiff : IN THE COURT OF COMMON PLEAS OF ; CUMBERLAND COUNTY, PENNSYLVANIA LINDA A. ROHM, v. : CIVIL ACTION - LAW WILLIAM A. ROHM, Defendant : NO. 2002-649 CIVIL TERM : IN DIVORCE DRS ATTACHMENT FOR APL PROCEEDINGS PETITIONER NAME William Rohm ADDRESS 2977 Enola Road, Carlisle, P A 17013 BIRTH DATE 04/24/49 SOCIAL SECURITY NUMBER 184-38-1079 HOME PHONE 249-7215 WORK PHONE n/a EMPLOYER NAME n/a EMPLOYER ADDRESS n/a JOB TITLE/POSITlON n/a DATE EMPLOYMENT COMMENCED n/a GROSS PAY n/a NET PAY n/a OTHER INCOME $454/mo. (V A Disability) ATTORNEY'S NAME Marylou Matas, Esquire ATTORNEY'S ADDRESS 200 North Hanover St., Carlisle, P A ATTORNEY'S PHONE NUMBER (717) 243-5551 RESPONDENT NAME Linda Rohm ADDRESS 227 Webster Street, Carlisle, PA 17013 BIRTH DATE 10/03/49 SOCIAL SECURITY NUMBER 206-36.-1734 HOME PHONE WORK PHONE EMPLOYER NAME P A Department of Education EMPLOYER ADDRESS 333 Market Street, Harrisburg, P A JOB TITLE/POSlTlON Clerk DATE EMPLOYMENT COMMENCED June 2000 GROSS PAY $38,083.00/year NET PAY OTHER INCOME ATTORNEY'S NAME Kara Haggerty, Esquire ATTORNEY'S ADDRESS 36 South Hanover Street, Carlisle, P A 17013 ATTORNEY'S PHONE NUMBER (717) 249-0900 MARRIAGE INFORMATION DATE OF MARRIAGE 02/02/73 PLACE OF MARRIAGE Carlisle, P A DATE OF SEPARATION January 10, 2002 ADDRESS OF LAST MARITAL 2977 Enola Road HOME Carlisle, P A 17013 DESCRIPTION OF DOCUMENT Counter-claim RAISING APL CLAIM DATE APL DOCUMENT FILED 0 r"'.~ 0 r..,;;, S',.; c:;:, -n ...L;- '-- -=I ~=; :1--" rllF I -of.q :JJy <..:> C)..-., v ~!; ~J ~..:!.... " '":'? '.-.: C) :~"J -.l .,,- . LINDA ROHM, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. NO. 02-649 CIVIL WILLIAM A. ROHM, Defendant IN DIVORCE TO THE PROTHONOTARY OF SAID COURT; PRAECIPE TO ENTER APPEARANCE AND NOW, this + ~day of ..M.nrr L. 2004, please enter the appearance of the undersigned counsel on behalf of the Plaintiff, Linda Rohm, in the above captioned matter. Respectfully submitted, ABOM & KUTULAKIS, L.L.P DATE~ ~e,~M 36 South Hanover Street Carlisle, Pennsylvania 11013 (717) 249-0900 A ttomey for Plain tiff ID #86914 , PRAECIPE TO WITHDRAW APPEARANCE AND NOW, this~ day of -;r;tMe..i. ,2004, please withdraw the appearance of the undersigned counsel on behalf of the Plaintiff, Linda Rohm, in the above captioned matter. DATE .3' ::,-.()'; t~t~ . dsay Baird;'flsquil: 7 S. Hanover Street Carlisle, PA 17013 ,~, C) '" s = 0 = ...... 'T] i-',.:. "-- ---1 c: H1:D ::1:: .. I -QrTl -.J :""? , , . - :;J ~? .- ~;?iZ.1 ( -,.. , 'f? i_:~,i fT) ~:,:'- "_--4 -., 0 ::.:u -< 1:) -.J ,"" LINDA A. ROH M, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE WILLIAM A. ROHM, Defendant/Petitioner NO. 2002-649 CIVIL TERM IN DIVORCE Pacses# 632106483 ORDER OF COURT AND NOW, this 29'h day of June, 2004, upon consideration of the attached Petition for Alimony Pendente Lite andlor counsel fees, it is hereby directed that the parties and their respective counsel appear before R.I. Shaddav onA""".t 19. 2004 at 9:00A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (I) a true copy of your most recent Federal Income Tax Retwn, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11<1':> (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, Georg" E. Hoffer, President Judg" Mail copies on 6-29-04 to; Petitioner < Respondent Marylou Matas, Esquire Kara Haggerty, Esquire Date of Order; June 29. 2004 YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA ] 7013 (717) 249-3166 CC361 ".::t f1-!"1e -:';1. "" co::, = -"'" o -., .-1 -r fil:D ,- :T2j ~:~1t) :'-J ~;:.! :,. (l ,-f] . ,- ~::: c, c;. -I"f r:~) en C.J1 LINDA A. ROHM, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA VS. CIVIL ACTION - DIVORCE WILLIAM A. ROHM, Defendant/Petitioner NO. 2002-649 CIVIL TERM IN DIVORCE Pacses# 632106483 ORDER OF COURT AND NOW, this 19th day of August, 2004, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $1,271.00 and Respondent's monthly net income/eaming capacity is $2,419.87, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $460.00 per month plus $40.00 on arrearages payable bi-weekly as follows; $212.31 for alimony pendente lite and $18.46 on arrears. First payment due next pay date at $230.77. Arrears set at $1,380.00 as of August 19, 2004. The effective date of the order is June 3, 2004. Wife is to obtain and maintain medical insurance coverage on Husband. This Order is based upon the condition that Wife cooperate and sign all necessary documents to assist with the expedition of Husband's retirement income. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C.S.~ 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the P A SCDU to: William A. Rohm. Payments must be made by check or money order. All checks and money orders must be made payable to P A SCDU and mailed to: P A SCDU P.O. Box 69110 Harrisburg, PAl 71 06-911 0 Payments must include the defendant's P ACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. Unreimbursed medical expenses that exceed $250.00 annually are to be paid as follows: 0% by Respondent and 100% by Petitioner. The Petitioner is responsible to pay the first $250.00 annually in unreimbursed medical expenses. Respondent to provide medical insurance coverage. Within thirty days after the entry of this order, the Respondent shall submit to the Petitioner written proof that medical insurance coverage has been obtained or that application for coverage has been made. Proof of coverage shall consist, at a minimum, of: I) the name of the health care coverage provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage; 4)the addr4ess to which claims should be made; 5) a description of any restrictions on usage, such as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms. This Order shall become final ten days after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary for a hearing de novo before the Court. ORO: R. J. Shadday Mailed copies on 8-20-04: < Petitioner Respondent Marylou Matas, Esquire Kara Haggerty, Esquire BY THE COLRT, (~ Edward E. Guido " J. C) c:- '-' r".:'} co " -. ,"', " ..',\ .'--\ , (~? C'". --, ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsvlvania Co.lCity/Dist. of CUMBERLAND Date of Order/Notice 08/19/04 Tribunal/Case Number (See Addendum for case summary) o Original Order/Notice o Amended Order/Notice o Terminate Order/Notice EmployerlWithholder's Federal EIN Number RE: ROHM, LINDA A. Employee/Obligor's Name (Last, First, MI) 206-36-1734 Employee/Obligor's Social Security Number 3925101346 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, Mil COMMONWEALTH OF PA C/O PAYROLL OPERATIONS ATTACHMENTS RESEARCH UNIT PO BOX 8006 HARRISBURG PA 17105-8006 'Dd ~a-~l/9 (1[/ P/!e~f<:;' {,3UOb~~ See Addendum for dependent names and birth dates associatl!d with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct 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. $ 460.00 per month in current support $ 40.00 per month in past-due support Arrears 12 weeks or greater? @yes 0 no $ 0 . 00 per month in medical support $ 0 . 00 per month for genetic test costs $ per month in other (specify) for a total of $ 500.00 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: $ 115.38 per weekly pay period. $ 230.77 per biweekly pay period (every two weeks). $ 250.00 per semimonthly pay period (twice a month). $ 500.00 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 paydateJdate of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #10 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND 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: AUS 2 0 200ft on", cou.., ~~ H)tuX/-,CLJ E {pvtOO :JVt>~ Form EN-028 OMBNo.:0970-0154 Worker ID $IATT Service Type M ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If ~hecked you are required to prpvide a copy of this form to your empioyee. If your employee works in a state that is ditterent from the state that issued this order, a copy must be provided to your employee even if the box is not checked. 1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned businesses located on a reservation that choose to withhold in accordance with this notke. 2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 4. * R(!POlt;"g the raydat~/D~~ of'lv'itl,holdil.g. YOu must I~po,t ll,~ paydateldate of n;I.I,I,0Idillg vvl,{J, 3~lld;'15 ti,e payll.c'I't. The payda~/ddto;:: of nitLI,oldi"g;;; th~ date 01. nl,id, A,"0ul1t mH yy;tLL~ld (115111 ti,e elllploy(,~'.!, nages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 5. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhoid Income for Support against this employee/obligor and you are unable to honor ail 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 #1 0 below) 6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S ID: 2321722990 EMPLOYEE'S/OBLlGOR'S NAME: EMPLOYEE'S CASE IDENTIFIER: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: ROHM, LINDA A. 3925101346 DATE OF SEI'ARATION: 7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the empioyee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. Anti-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. 10.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.s.c. 91673 (b)l; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxeSi Social Security taxes; and Medicare taxes. 11. Additional Info: *NOTE; If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER 5T P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obiigor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at !.ZJ...ZL240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Worker ID $IATT Service Type M OMB No.: 0970-0154 ADDENDUM Summary of Cases on Attachment Defendant/Obligor: ROHM, LINDA A. PACSES Case Number 632106483 Plaintiff Name WILLIAM A. ROHM Docket Attachment Amount 02 =6'49CIVIL $ 500.00 Child(ren)'s Name(s): PACSES Case Number Plaintiff Nam~ DOB Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB you are required to enroll the child(ren) above in any health insurance coverage available through the employee's/obiigor's employment. you are required to enroll the child(ren) in any health insurance coverage available employee's/obiigor's employment. PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff Nam~ Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB you are required to enroll the child(ren) in any health insurance coverage available employee's/obiigor's employment. you are required to enroll the child(ren) in any health insurance coverage available employee's/obiigor's employment. PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff Nam~ Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB you are required to enroll the child(ren) in any health insurance coverage available employee's/obiigor's employment. If checked, you are required to enroll the child(ren) in any health insurance coverage available employee's/obligor's employment. Addendum Form E N-028 Worker ID $IATT Service Type M OMB No.: 0970-0154 3nn'e.ci f-,.71 t~ t~::} (-) :'j'1 " r".' CJ {.~~ en -.J LINDA A.. ROHM, Plaintiff/Respondent , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNNSYLV ANIA ClVlL ACION-DlVORCE vs. NO. 2002-649 CIVIL TERM. IN DIVORCE WILLIAM. A.. ROHM, Defendant/Petitioner pacses# 632106483 DE~D FOR HEMUNG. DATE OF ORDER; August 19, 2004 AMOUNT: $460.00 per month plus $40.00 on arrears For; Alimony Pendente Lite REASON (S): Wife requests a hearing de novO on the award and amount of APL to husband. The grounds are as followS; Husband should be assessed an earning capacity consistent with his training; husband should be requited to seek and obtain employment~ wife should be given consideration for the support of the parties' adult son that she continues to support while he completes his college education. ~~~~~- Abom & Kutulakis, LLP 36 South Hanover Street Carlisle, P A 17013 717 _249-0900 Atty. No.;86914 Attomry for P laintiff/ Respondent, Linda A. Rnhm Date CERTIFICATE OF SERVICE~ AND NOW, this 30th day of August 2004, I, Kara W. Haggerty, Esquire, by and through ABOM & KUTULAKlS, hereby certify that I did serve a true and correct copy of the foregoing Demand for Hearing, upon the below listed counsel of record, and/ or parties, by US Mail, addressed to the following; Marylou Matas, Esquire GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, P A 17013 ABOM & KUTULAKlS, L.L.P. Date: August 30, 2004 ~~w. Kara W. Haggerty, Attorney for Plainti Abom & Kutulakis, LLP 36 South Hanover Street Carlisle, P A 17013 LINDA A. ROHM, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, l'ENNSYL VANIA CIVIL ACTION - DIVORCE VS. NO. 2002-649 CIVIL TERM IN DIVORCE WILLIAM A. ROHM, Defendantll'etitioner l'acses# 632106483 NOTICE OF RIGHT TO REOUEST A Hl~ARING The parties are hereby advised that they have until Au~ust 30. 201 before the Court. File request in person or mail to; I Office of the Prothonotary 1 Courthouse Square Carlisle, PA 17013 p 0 ...., 0 C:i = c "''' ." ...( ?;: .r- > -< -r}C;:' ffl:!J n-lfl = t ::~ ::L~ G'" 2"'C- (...) -O~ ((I.' 0 B -<: ~ 'i:!u r::: c~' - To 'i>C :;;:;"" ~;- ." ""..,.. ..' ::>: 9t"5 e ~;?~' <;;> 15m --, :z >- --I .r:- :D -< N -< In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION WILLIAM A. ROHM ) Docket Nwnber 02-649 CIVIL Plaintiff ) vs. ) PACSES Case Number 632106483 LINDA A. ROHM ) Defendant ) Other State ID Number ORDER OF COURT You, WILLIAM A. ROHM plaintiff/defendant of 2977 ENOLA RD, CARLISLE, PA. 17013-9542-77 are ordered to appear at DOMESTIC RELATIONS HEARING Rl!1 DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE:, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the OCTOBER 21, 2004 at 9 : OOAM for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. verification of child care expenses. and 4. proof of medical coverage which you may have, or may have available to you 5. infonnation relating to professional licenses 6. other; Form CM-509 Worker ID 21302 Service Type M ROHM V. ROHM PACSES Case Number; 632106483 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated th.e support action. Date of Order: ?-5\~'\ BY THE COURT: (--"" ~ r -f..i JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATIEND THE HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. TIDS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCElI> FEE OR NO FEE. CUMBERLAND co BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of2 Form CM-509 Worker ID 21302 Service Type M ~ .~ , 0 ...., ~ = c c.~ -cfr .J:" "'"' ~ ! -,", ; -~ c:: rll~ ..-F ---, G"l '''f' w ~~ tll,! :0 '<.. 9 '-::c~; < -0 ~..;..j. ~c; .~o :J: "..-~ ~c:. <.f! 0 z: ,.~ ;:e: _':l &"" ~ -< c"J , !'-~ '::~' c:l In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION WILLIAM A. ROIIM ) Docket Number 02-649 CIVIL Plaintiff ) vs. ) PACSES Case Number 632106483 LINDA A. ROIIM ) Defendant ) Other State ID Number ORDER OF COUR1!: You, LINDA A. ROIIM plaintiff/defendant of 227 WEBSTER ST, CARLISLE, PA. 17013-2027-27 are ordered to appear at DOMESTIC RELATIONS HEARING R11 DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISL1~, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section,. on the OCTOBER 21, 2004 at 9: OOAM for a ht:aring. You are further required to bring to the hearing: I. a true copy of your most recent Federal Income Tax Retum, including W -2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. verification of child care expenseS, and 4. proof of medical coverage which you may have, or may have available to you 5. information relating to professional licenses 6. other; Form CM-509 Worker ID 21302 Service Type M ROIIM V. ROIIM PACSES Case Number; 632106483 If you fail to appear for the conferencelhearing or to bring the required documents, the , court may issue a warrant for your arrest or enter an order ill your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: x01-0'-\ r---." ,:-~.-t: ; 1 JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATIEND THE HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. TinS OFFIC'E MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELlGmLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLlum County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 2'~0-6225. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Worker ID 21302 Service Type M o C .:c:''''' 3i ...... ~~~: U)eL':- -' ,. C::Ci ,'. ,jO' Zl.~ .,..C Pc.: :7 =2 :::,;. c.','" '::::<.":3 '" '." "" = = .r" ;r.... C; Co'" t..) ~ :2 rn:D :g~'- o ~.,,~ 0-"" ~?r..) 01"11 -..of >' ;JJ -< -u ::x: ~ .J:"' W LINDA A. ROHM, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent: CUMBERLAND COUNTY, PENNSYLVANIA V. : DOMESTIC RELATIONS SECTION WilLIAM A. ROHM, : PACSES NO. 632106483 Defendant/Petitioner: DOCKET NO. 02..649 CIVil INTERIM ORDER OF COURT AND NOW, this 2ih day of October, 2004, upon consideration of the Support Master's Report and Recommendation, a copy of which is attached hereto as Exhibit "A", it is ordered and decreed as follows: A. The Respondent shall pay to the Pennsylvania State Collection and Disbursement Unit for transmission to the Petitioner as alimony pendente lite the sum of $324.50 per month. B. The effective date of this order is June 3, 2004. C. The obligation to pay alimony pendente lite is suspended December 1, 2004, with the respondent continuing to pay the sum of $324.50 per month on arrearages effective that date until all arrearages are paid in full. The parties are hereby advised that they may fiile written exceptions to the Support Master's Report and Recommendation within ten (10) days of this order. Exceptions shall conform with the requirements of Rule 191 0.12(f), Pa. R.C.P. If written exceptions are filed by any party, the other party may file exceptions within ten (10) days of the date of service of the original exceptions. If no exceptions are filed within ten (10) days of this interim order, this order shall then constitute a final order. By~ui'l; '-~~~ Edwar E. M J. Cc: William A. Rohm Linda A. Rohm Marylou A. Matas, Esquire For the Plaintiff/Respondent Kara W. Haggerty, Esquire For the Defendant/Petitioner DRO LINDA A. ROHM, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent: CUMBERLAND COUNTY, PENNSYLVANIA V. : DOMESTIC RELATIONS SECTION WilLIAM A. ROHM, : PACSES NO. 632'106483 Defendant/Petitioner: DOCKET NO. 02-649 CIVil SUPPORT MASTER'S REPORT AND RECOMMENDATION Following a hearing held before the undersigned Support Master on October 21,2004 the following report and recommendation are made: FINDINGS OF FACT 1. The Petitioner is William A. Rohm, who resides at 2977 Enola Road, Carlisle, Pennsylvania. 2. The Respondent is Linda A. Rohm, who resides at 227 Webster Street, Carlisle, Pennsylvania. 3. The Respondent is the Plaintiff in the divorce action filed to the above term and number on February 6, 2002. 4. On June 3, 2004 the Petitioner filed a claim for alimony pendente lite. 5. The parties were married on February 2,1973 and separated on or about January 10, 2002. 6. At the time of the separation the Petitioner was employed by Griffin Services as an HVAC mechanic. 7. In April, 2002 the petitioner began working four days per week at his request. 8. The Petitioner is a veteran of the United States Marine Corps who sustained injuries to his legs while serving in Vietnam as a result of the detonation of a landmine. 9. The Petitioner has been classified as 40% disabled by the Veteran's Administration and receives monthly disability payments of $454.00. 10. The Petitioner was laid off by Griffin Services in February, 2003. 11. The Petitioner's hourly rate of pay with Griffin Services was $17.69. EXHIBIT "A" 12. The Petitioner received unemployment compensation benefits until obtaining employment with West Perry School District in September, 2003. 13. Although hired as an HVAC mechanic by West Perry, the Petitioner was required to perform general labor to include such tasks as carrying heavy loads and plowing snow. 14. The Petitioner voluntarily left his employment with West Perry School District in December, 2003 because the pain in his legs was getting progressively worse performing the duties required of the position. 15. The Petitioner has not been gainfully employed since December, 2003. 16.Since terminating his employment with West Perry School District the Petitioner has applied for approximately five job vacancies but has been offered no employment. 17. Prior to his employment with Griffin Services thiS Petitioner had been employed by Quaker Oats Company. 18. The Petitioner lost his position with Quaker Oats when the company was sold and the plant closed. 19. The Petitioner was vested in the Quaker Oats retirement plan and was eligible for retirement upon obtaining his 55th birthday in April, 2004. 20. Because of the divorce litigation the Petitioner was unable to receive monthly retirement payments. 21. The Petitioner will begin receiving retirement benefits in the amount of $825.00 per month on or about December 1, 21004.1 22. The parties have two children, both of whom have reached the age of majority. 23. The parties' older son resides with the Petition'sr. 24. The Petitioner's son is gainfully employed. 25.lt is anticipated that the Petitioner will file his federal tax return for tax year 2004 as married/separate. 26. The Respondent is employed by the Commonwealth of Pennsylvania. 1 Following the hearing the Respondent executed documentation required by Quaker Oats to have the Petitioner's retirement go into pay status. 2 27. The Respondent has gross bi-weekly income of $1 ,495.50. 28. The Respondent has a mandatory retirement dEiduction of $93.47 bi-weekly. 29. The Respondent has a deduction for union dues of $15.01 bi-weekly. 30. The Respondent provides health insurance coverage for the benefit of the Petitioner at no monetary cost. 31. The parties' younger son, a college student, resides with the Respondent. 32. The Respondent files her federal tax return as head of household and claims her younger son as a dependency exemption. 33. The Respondent is assisting her son with colle~le expenses. DISCUSSION The purpose of alimony pendente lite is to enable a dependent spouse to prosecute or defend a divorce action. Litmans v. Litmans 673 A.2d. 382 (Pa. Super. 1996). Factors to consider in determining whether a claimant is entitled to an award of APL include the separate estate and income of the claimant, the ability of the other spouse to pay, and the character, situation and surroundings of the parties. Litmans supra. If entitlement is found, the amount of the award is calculated pursuant to the support guidelines. Little v. Little, 47 Cumberland L.J. 131 (1998). Before a calculation is made, however, a determination must be made as to the claimant's entitlement to the award. Clouse v. Clouse, 50 Cumberland L.J. 167 (2001 ). In early 2002 when the parties separated and when the divorce complaint was filed the Petitioner was gainfully employed as an HV AC mechanic with Griffin Services. In April, 2002 he voluntarily reduced his hours of employment to four days per week because of pain in his legs. He continued to work four days per week until he was laid-off in February, 2003. Following the lay-off the Defendant collected unemployment compensation benefits until September, 2003 when he obtained employment with West Perry School District as an HVAC mechanic. The Petitioner was required to perform labor beyond what would normally be required of an HVAC mechanic at West Perry. Specifically he was required to carry heavy objects and to plow snow. After a labor intensive day plowing snow in December, 2003 the Petitioner decided he could no longer handle the physical aspects of the position and voluntarily terminated his employment. The Petitioner has submitted approximately five applications for employment since leaving West Perry School District. He has received no offers of employment. The Petitioner became eligible to receive a pension from prior employment with Quaker Oats in late April, 2004 when he turned !i5 years of age. Because of 3 the divorce litigation, the pension could not go into pay status at that time. The parties have since stipulated that the Petitioner will commence receiving pension payments on or about December 1, 2004 in the amount of $825.00 per month. The Petitioner filed his petition for alimony pendente lite on June 3, 2004 at which time his sole income was veteran's disability payments in the amount of $454.00 per month. With total income of only $454.00 per month thE~ Petitioner is clearly entitled to an award of APL. The respondent argues, however, that an earning capacity should be imputed to the petitioner based upon his extensive work history. Pa. R.C.P. 191 0.16-2(d)(4) provides as follows: (4) Income Potential Ordinarily, a party who wilfully fails to obliain appropriate employment will be considered to have an income equal to the party's earning capacity. Age, education, training, health, work experience, earnings history and child care responsibilities are factors which shall be considered in determining earning capacity. The Petitioner's efforts to obtain employment have been meager at best. He has applied for five positions since leaving the employ of the West Perry School District in December, 2003. In his own words, he has "given up" trying to find a job. The Petitioner has acquired marketable skills in his 25, plus year career as an HVAC mechanic. While he may not be able to perform the rigorous duties of carrying furnaces into home basements or climbing high ladders because of the pain he experiences in his legs, he has the skills to work as an electrician or plumber's assistant on a part-time basis earning a minimum of $300.00 per week. An earning capacity in that amount will be imputed to him. With earnings of $300.00 per week or $1 ,300.00 per month, and monthly VA disability benefits of $454.00, the Petitioner would have total monthly income of $1,754.00. Filing his federal tax return as married/separate, his net monthly income would be $1,535.00.2 The respondent has gross bi-weekly earnings of $1 ,495.50, or $3,240.00 per month. Deducting her union dues and mandatory retirement from her gross income, and filing her federal tax return as head of household with her college-aged son claimed as a dependency exemption, the respondent would have net monthly income of $2,346.00.3 With these relative incomes, the respondent's obligation for APL under the guidelines is $324.50 per month.4 ThE~ effective date of the obligation is June 3, 2004. 2 See Exhibit "A" for the tax deductions from gross income. 3 See Exhibit "A" for the tax deductions from gross income. 4 See Exhibit "B" for the calculation. 4 With the Petitioner's receipt of his pension in the amount of $825.00 per month on December 1, 2004, the obligation of the Respondent to pay APL would be suspended because the Petitioner's total monthly income would approximate that of the Respondent. RECOMMENDATION A. The Respondent shall pay to the Pennsylvania State Collection and Disbursement Unit for transmission to the Petitioner as alimony pendente lite the sum of $324.50 per month. B. The effective date of this order is June 3, 2004. C. The obligation to pay alimony pendente lite is suspended December 1, 2004, with the respondent continuing to pay the sum of $324.50 per month on arrearages effective that date until all arrearages are paid in full. oc..+olu.. 2 <; . 2..00 </- Date ~~)Q\Lk Michael R. Rundle Support Master 5 In the Court of Common Pleas of Cumberland County, Pennsylvania Plaintiff Name: Defendant Name: Docket Number: PACSES Case Number: Other State 10 Number: Tax Year: William A. Rohm Linda A. Rohm 02-649 Civil 632106483 ". .OW'eI1$tnt ' "Plaintiff, ' 1. Fling Status Married Filing 2. Who Claims the Exem tions 3. Number of Exemptions 4. Monthl Taxable Income 5. Deductions Method 1 6. Deduction Amount 7. Exem tion Amount 8. Income MINUS Deductions and Exem tions 9. Tax on Income 10. Child Tax Credit 11. Manual Ad'ustments to Taxes 12. Federal Income Taxes 12 a. Earned Income Credit 13. State Income Taxes 14. FICA Pa ments 15. City Where Taxes Apply $595.83 $404.17 $516.66 $258.33 $2,127.76 $637.50 $276.66 $65.83 $276.66 $65.83 $102.39 $41.08 $247.88 $99.45 TOTAL Taxes $32.40 $659.33 $13.00 16. Local Income Taxes $219.36 Support Calc 2004 EXHIBIT "All In the Court of Common Pleas of Cumberland County, Pennsylvania Plaintiff Name: Defendant Name: Docket Number: PACSES Case Number: Other State 10 Number: William A. Rohm Linda A. Rohm 02-649 Civil 632106483 $2,345.88 2. Less All Other Su ort 4. Difference $1,534.64 $811.24 3. Less Obli ee's Monthl Net Income 5. Less Child Su 6. Difference $811.24 7. Multi I b 30% or 40% 40.00% ort $324.50 9. Ad'ustment for Other Ex enses 10. AMOUNT OF MONTHLY SPOUSAL SUPPORT OR APL $324.50 Date: 10/22/2004 Support Calc 2004 EXHIBIT liB" Commonwealth of Pennsylvania EMPLOYEE PAY STATEMENT ILinda A Rohm 1227 Webster Street Icarlisle PA 17013 I I !S/U:C4 I I Pay Date I 10/15/2004 I Group: 07 Level :03 IPersonnel Number. 00516847 I Education !Fay Period. 09/18/2004 - 10/01/2004 IFed Tax Status: Married, withhold at Higher IFed Tax Allowances: 00 period: 21/2004 I I 0.00 Taxes 357.54 Deds. 468.25 669.71 Gross 1,495.50 Reim. Payment Amount Rate Hrs/Vnt Amount Year To Date IGross Current Pay 19.94 75.00 1,495.50 27,553.02 1,210.85 78.12 375.95 638.08 352.78 735.45 INormal working hours IAnnual Leave Pay IPaid-Office Closing ISick Leave Pay ISick Bereavement Leave IPersonal Leave Pay IHoliday/camp lieu Holiday I ITotal Gross I 1,495.50 30,944.25 Amount Year To Date ITaxes I I Federal Federal ITX Withholding Tax ITX EE Social Security Tax ITX EE Medicare Tax !State pennsylvania ITX Withholding Tax ITX EE Unemployment Tax ]Local Carlisle Borough !TX Withholding Tax I Local Harrisburg ITX EE occupation Tax I ITotal Taxes I 171.95 92.72 21.68 3,502.72 1,918.54 448.69 45.91 1.35 950.01 27.85 23.93 495.18 10.00 357.54 7,352.99 Amount Year To Date I Deductions 125.00 4.00 15.01 230.77 93.47 2,625.00 84.00 310.06 692.31 1,934.07 IDeferred compensation 1St Emp Comb Appeal (SECA) IFOSCEP - Fair Share IGarnish: Alimony/Support IFull Cov Class AA/Cat 0 I ITotal Deductions 468.25 5,645.44 INon Cash compensation nt Year To Date PLAINTlFPS EXHIBIT u Commonwealth of Pennsylvania EMPLOYEE PAY STATEMENT I Reimbursements Amount !Direct Deposit Bank / Check I INet Payment I Amount 669.71 Istate Paid Benefits I ITX ER Social Security Tax !TX ER Medicare Tax IER Basic Life IAnnuitant Med Hospital IER Workers Camp Benefit jPR HealthAmer.Central HMO IER-SERS I Amount 92.72 21.68 4.55 20' ,60 26 .83 270 .00 21 .39 IFederal Taxable Wages I ICurrent Period Results Amount 1,277.03 IGarnishment Type Beg Balance Total To Date Remain Balance IGarnish: Alimony/Support 0.00 692.31 0.00 IPayroll Area Z3 Commonwealth of Pennsylvania EMPLOYEE PAY STATEMENT 004259 Personnel No. 00516847 Linda A Rohm 227 Webster Street Carlisle, PA 17013 Education Period Ending 0911712004 Organizational Unit Name: ED Oi" lib Imp COC Code: BIU: C4 Group: 07 Level: 03 FWT Marital Status: M No Exemptions I Allowances' 00 Pay Date 1010112004 0008888 GROSS EARNINGS YEAR TO DATE 29.448,75 EARNINGS HOURS RATE AMOUNT NET PAY THIS PAY Normal working hours 67.50 19.94 1,345.95 MEMBERS 1ST FeU 669.71 Holiday/Camp lieu Holiday 7.50 19.94 149.55 TOTAL NET 669,71 OEDUCTIONS THIS PAY YTD Federal Withholding Tax 171.95 3,330.77 TX EE Social Security Tax 92.72 1,825.82 TX EE Medicare Tax 21.69 427.01 State Withholding-Pennsylvania 45.91 904.10 Local Wage Tax-Carlisle Borough 23.93 471.25 TX EE Unemployment Tax 1.34 26.50 Garnish: Alimony/Support 230.77 461.54 5t Emp Comb Appeal (SECA) 4.00 80.00 FOSCEP - Fair Share 15,01 295.05 State Emp Ret 93.47 1,840.60 Deferred Compensation 125.00 2,500,00 TOTAL DEDUCTIONS 825.79 12,162,64 REIMBURSEMENTS THIS PAY YTD TOTAL EARNIIIGS 1.495,50 TOTAL REIMBURSEMENTS SERVICE CREDIT 03 YR 12 PP EMPLOYER PAID BENEFITS THIS PAY TX ER Social Security Tax SENIORITY INFORMATION 92.72 Bargaining Unit Days: FOSCEP AGREEMENT 578,00 TX ER Medicare Tax 21.69 ER Basic life 4.55 State Emp Ret 21.39 Annuitant MI'>f1 Hos?ital 20.4.60 ABSENCE ACTIVITY ANNUAL SICK PERSONAL ER Workers Comp Benefit Quota Last Stmnt 25.75 20803 4.50 26,83 PR HealthAmer.Central HMO Accrual This PP 8.66 7.50 0,00 270.00 Absence Reported This PP 0,00 0.00 0.00 . Adjustment 4.33- 3.75- 0,00 = ""= Quota This Stmnt 30,08 211.78 4.50 0 TOTAL BENEFITS 641.78 ACCRUAL RATE: ANNUAL 5.77 % SICK 5.00% ~ ~ FWT Taxable Gross 1.277.03 . Contact your local Human Resources Office if you have any questions regarding the content and distribution of your Employee Pay Statement ~ ~. ~~ ,~~ --....J ~" Grifl1n Services fr:f: SEN:~~!:3i_C /i.PFFWA~JI :;::;.;Cft..:T!::: 1);)5 U.S. Ann/ DPW Cor,]" ,ctor uru>,: 19 September 2002 Subject: 'vVilliam Rohm To \vhom it may concern: William Rohm has been employed with Griffin Services Inc. as a HV AC Mechanic since November 2001. After four months of working eight hour days, five days a week, 1vfr. Rohm requested Griffm Services to a11ov/ him to work only four eight hour days because his legs were becoming progressively worse after working five straight days, Sincere vi 12 ' t-~VV1 f/ /j1cit Tommy D, Border . 1 Facilities Supelyisor DEFENDANT'S EXHIBIT Grit:i;, SS}",f:::es, inc:, 33(,' E.oyinue!' F.u;;Jd, Cari/.:::;'i,,, B,j,vrdc,c;,. P,':" I,' ,," '),J ~)I-O'j 1 ~) 770-2.4S.:J3tYF.1X 717-2"';5-4296 '.]:.Fi!? S:'nt'lc.}~, 1:::;, 5755 [)~t:F2e Dti'",,:, N.ll/... $1.Jit.} 220.. ,:':l;;n::1 C:;}!X":J'; ~.~..;' >,lJ5:2 77(;'-S:'i;;.i ~;?r;,,::;;)X 770-:15::-0.) i {1 September 17, 2002 Dear Sir: I, William A. Rohm, Social Security No. 1884-38-1079, Service No. 2264205, VA lD No. MM042449 595, Priority No. C23993103 3 020 7V, would like to be considered for a step increase in the VA monthly benefit check. Reason being: I have developed more pain in my right knee where I have two pieces of shrapnel and also my left foot gets a tingling feeling due to the shrapnel in my left calf. It is more of a constant pain now. For many years I would only experience pain in those areas when there would be a change in the weather. Due to this more constant pain, I am working less than 40 hours per week _ 4, 8 hour days. This reduced work time gives me more time to rest my knee and legs. As a result of these injuries and the reduced work time needed for rest, I have lost considerable income, which I would like to be compensated for. Thank you for your consideration. Sincerely, William A. Rohm O~Nl'S OEf:~H\6\1 }.- V) Ie -J1-ft1 CARLISLE AREA SCHOOL DISTRICT 623 West Penn Street Carlisle, Pennsylvania 17013-2298 Gerald L. Fowler, Ph.D.. 5uperinlendeni C{'lltmlAdmillislralioll 717-2-j.O-(:lHOO Fax 717.24(J-(;H~)H April 20, 2004 Mr. William A. Rohm 2971 Enola Rd. Carlisle, PA 17013 Dear Mr. Rohm: Thank you for your interest in the HV AC position offered by the Carlisle Area School District. We have completed all ofthe scheduled interviews for this position. I regret to infonn you that the district has chosen a candidate to fill this position. Thank you again and wish you much success with your career. L a. LwI- HOWARD A. SWART Director of Buildings and Grounds c: file hvacItr DEFENDANT' EXHIBIT 5 /d:J/_.y 3 Id ~ SARAH A. TODD MEMORIAL HOME 1000 West South Street, Carlisle, PA 17013 (717) 245-2187 . (717) 245-9733 FAX www.ucc-homes.org April 21, 2004 William A. Rohm 2977 Eno1a Road Carlisle, Pa. 17013 Dear Mr. Rohm, Thank you for taking the time to interview for the position of Maintenance Helper. We had several well-qualified candidates and the position is now filled. Your resume will remain on file in the event another position would become available. .~ I wish you success in the attainment of your career objectives.. cf:re~ Jim Snyder Directo r Maintenance Department DEFENDANT'S EXHIBIT A program of service for the older person sponsored by United Church of Christ Homes 10:11-0'14 16 Income and Expense Statement ROHM V. ROHM PACSES Case Number >~~ 632106483 Section III: Expenses Instructions: Only show extraordinary expenses in this section unless you filled out Section II on page two. The categories in BOLD FONT are especially important for calculating child support. If you are requesting Spousal Support/APL or if you assert your case cannot be determined according to the guideline grids or formula, this section must be fully completed. (Fill in Appropriate Column) EXPENSE WEEK MONTH YEAR Home Mortgage/Rent Maintenance 100.00 Utilities Electric 200.00 Gas Coal 50.00 Telephone 40.00 Water Sewer Emnlovrnent Public Transportation Lunch Taxes Real Estate 125.00 Personal Property 42.00 Insurance Homeowner's Automobile Life Accident Health Other Automobile Payments Fuel 80.00 Repairs 125.00 Medical Doctor Dentist Orthodontist Hospital Medicine Special needs (glasses. braces orthopedic devices) EXPENSES (Fill in Appropriate Column) (continued) WEEK MONTH YEAR Education Private School Parochial School College Religious Personal Clothing 30.00 Food 250.00 Barber/ 10.00 Hairdresser Credit Payments Credit Card Charge Memberships Loans Credit Union Miscellaneous Household Help Child care Papers/books 5.00 Magazines Entertainment 25.00 Pay TV 35.00 Vacation 10.00 Gifts 5.00 Legal fees 100.00 Charitable 10.00 Contributions Other Child Support Alimony Payment Other - DEFENDANT'S EXHIBIT h,l!-()'jS iL\ Total WEEK MONTH YE.~ Expenses $ $ 1.237.50 $ ===..J 1 verify that the statements made in the foregoing document are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE; Service Type Page3 of3 WILLIAl1 ROHM Form IN-OOS Worker ID For the year Jan 1 ' Dec 31, 2003, or other tax year beginning ,2003, ending ,20 OMS No, 1545,0074 label Your first name MI Laslname Your social security number (See instructions.) William Rohm 184-38-1079 Ii a jomt return, spow;e'sfirst name MI Last name Spouse's social security number Use the IRS label. Otherwise, Home address (nLllober and street) H you have a P,O, box see instructions Apartment no ! Important! ! please print or type. 2977 Enola Rd You must enter your social City, town or post office If you have a foreign address. seeinstl1..lctions State ZIP code secul'ity number(s) above. Presidential Carlisle I'A 17013 d Total number of exemptions claimed 7 Wages, salal'ies, tipS, etc. Attach Form(s) W,2 8a Taxable Interest. Attach Schedule B if requll'ed . b Tax-exempt interest. Do not include on line 8a 1 8bl 9a Ordinal'y dividends. Attach Schedule B if required b Qualified dividends (see instl'uctions) ,I 9131 10 Taxable refunds, credits, or offsets of state and locallllcome taxes (see Instructions) . 11 Alimony received 12 Business income or (loss). Attach Schedule C or C.EZ . 13a Capital gall1 or (loss), AU Scll D if reqd, If not reqd, ck here b Ifboxon 13a is checked, enter post, May 5 capital gain distribullons 14 Other gains m (losses). Attach Form 4797 15a IRA distributions .. .1 15al I bb Taxable amount (see instrs) 16a Pensions and annuities ~ Taxable amount (see instrs) 17 Rental real estate, royalties, partnerships, S corporations, tl'ustS, etc, Attach Schedule E . 18 Farm Income or (loss). Attach Schedule F 19 Unemployment compensation 20 a Social security benefits I 20 a I 21 other income ~~------------------------------------ 22 Add the amounts in the far right column for lines 7 throu our total income ~ 23 Educator expenses (see instructions) 23 24 IRA deduction (see Instructions) . , 24 25 Student loan interest deduction (see instructions) 25 26 Tuition and fees deduction (see Instructions) 26 27 Moving expenses. Attach Form 3903 27 28 One,half of self-employment tax, Attach Schedule SE 28 29 Self-employed health insurance deduction (see instrs) . 29 30 Self, employed SEP, SIMPLE, and qualified plans 30 31 Penalty on early Withdrawal of savings 31 32a Alimony paid b Recipient's SSN ~ 33 Add lines 23 througl132a 34 Subtract line 33 from line 22. This is your adjusted gross income For Disclosure, Privacy Act, and Paperwork Reduction Act Notice, see instructions. Form 1 040 Election Campaign (See Instl1..lclions.) Filing Status Check only one box. Exemptions If more than five dependents, see instructions. Income Attach Forms W.2 and W.2G here. Also attach Form(s) 1099.R if tax was withheld. If you did not get a W-2, see instructions. Enclose, but do not attach, any payment. Also, please use Form 1040-V. Adjusted Gross Income BAA Department of the Treasury - Internal Revenlle Service I (99) IRS Use Only - Do not write or staple In this space 2003 u.s. Individual Income Tax Return ~ Note: Checking Yes' Will not change your tax or reduce youl refund You Spouse Do ou, 01 your spouse If filing a JOint I eturn, want $3 to go to thiS fund? ~ Yes No Yes 1 Single 4 X Head of household (with qualifying person). (See 2 Married filing JOintly (even if only one had Illcome) instructions.) If the qualifYing person is a child but not your dependent, enter this child's 3 Married fllil1Q separately, Enter spouse's SSN above & full name here ~ Dan i e 1 Rohm name here. ~ 5 QualifYing wldow(er) with dependent child. (See II1structions.) 6a X Yourself. If your parent (or someone else) can claim you as a (jependent on hiS or ~ No. of boxes her tax I'eturn, do not check box 6a ~~~~kde~bon b 0 Spouse - No. of children on6cwho: No 1 c Dependents: (2) Dependent's SOCial security number (3) Dependent's relationship to you . lived with you . did not live with you due to divorce or separation (seeinstrs) . Dependents on6c not entered above (1) First name Last name n Add numbers on Jines above ~ 1 12,692. 121. 1l3b1 ~D 10 11 12 13a 14 1Sb 1Gb 12,617. 17 18 19 11 , 400 . 20b 21 22 36,830. I b Taxable amount (see Instrs) d ~ 36,830. Form 1040 (2003) FDIA0112 11/25/03 W1l1, am Rohm 35 Amount fmm Ime 34 (adjusted gross Income) 36a Check J 0 You were born before January 2, 1939, D Blind. Total boxes I If: L 0 Spouse was born before January 2, 1939, [J Blind, checked --- 36a _ b If you are married filing separately and yourspouse Itemizes deductions, or you were a dual-status allen, see Instructions and check here. .. .. '5l Itemized deductions (from Schedule A) or your standard deduction (see left margin) 38 Subtract line 37 fl"Om line 35 39 If line 35 IS $104,625 or less, multiply $3,050 by the total number of exemptions claimed on line 6d. If line 35 IS ovel" $104,625, see the worksheet In the Instructions . . 40 Taxable income. Subtract 11118 39 from 1111838, Iflllle39islllorethanlll1e32,8nter.Q. 41 Tax (see II1slrs), Check 11 any tax IS from a 0 Form(s) 2814 b 0 Form 4972 42 Alternative minimum tax (see instructions), Attach Form 6251 43 Add lines 41 and 42 44 FOI'elgn tax nedlt Attach Fmm 1116 if required 45 Credit lor child and dependent care expenses. Attach Form 2441 46 Credit for the elderly or the disabled. Attach Schedule R . 47 Education credits. Attach Form 8863. 48 Retll'ement savings contributions credit. Attach Form 8880 49 Child tax credit (see instructions) . 50 Adoption credit Attach Form 8839 ,... . . . . , 51 Credits from: a 0 Form 8396 b 0 Form 8859 .. . . . 52 Other credits. Check applicable box(es): a 0 Form 3800 b 0 ~gb~ c DSpeclfy 53 Add lines 44 through 52, These al'e your total credits. . . 54 Subtract line 53 from line 43. If line 53 is more than line 43, enter -()- 55 Self-employment tax, Attach Schedule SE . . 56 Social security and Medicare lax on tip income not reported to employer. Attach Form 4137 57 Tax on qualifled plans, includillQ IRAs, and other tax-favored accounts. Attach Form :329 if required, . 58 Advance earned income credit payments from Form(s) W-2 59 Household employment taxes. Attach Schedule H 60 Add lilles 54,59, ThiS IS your total tax 61 Federal income tax withheld from Forms W-2 and 1099 L 62 2003 estimated tax payments alld amount applied from 2002 return . 63 Earned income credit (EIC) 64 Excess social security and tier 1 RRTA lax withheld (see Instructions) 65 Additional child tax credit Attach Form 8812 66 Amount paid With request for extension to file (see instructions) 67 Other pmts from: a 0 Form 2439 b 0 Form 4136 c D Form 8885 68 Add lines 61 through 67, These are your total payments 69 If Ime 68 lS more than Illle 60, subtract line 60 from line 68. This IS the amount you overpaid. 70 a Amount of line 69 you want refunded to you . b Routing number XXXXXXXXX . c Type: 0 Cllecklng . d Account number XXXXXXXXXXXXXXXXX 71 Amount of lille 69 you wallt applied to your 2004 estimated tax . . . "I 71 I 72 Amount you owe. Subtract line 68 from Illle 60. For details on how to pay, see instr Jctions 73 Estimated tax penalty (see instructions) ,I 73 I Do you want to allow another pel'son to dlSCUSS this return With the IRS (see Instructions)? 0 Yes. Complete the follOWing. Designee's Phone Personal identification name ~ no, .. number (PIN) ~ Under penalties of perJl.lry. I declare that I have examined this return and accompanying schedules and statements. and to_the best of my knowledge and belief. they are true, correct, and complete, Declaration of preparer (other than taxpayer) IS b,lsed on all Informahon of which preparer has any knowledge. Form 1040 (2003) Tax and Credits Standard Deduction for- . People who checked any box on line 36a or 36b or wh 0 can be claimed as a dependent, see Instructions, . All others: Single or Married filing separately, $4,750 Married filing jointly or QualifYing wldow(er), $9,500 Head of household, $7,000 Other Taxes Payments jf you have a qualifying Child, attach I Schedule EIC, I Refund Dlrect deposit? See instructions and fill In 70b, 70c, and 70d, Amount You Owe Third Party Designee Sign Here Joint return? See instructions. Keep a copy for your records. Paid Preparer's Use Only 44 45 46 47 48 49 50 51 52 61 62 No 63 64 65 66 67 Your signature Dale YOl.lr occupation ~ HI/AC Mech. Spouse's occupation Spouse's signatl.lre. If a joint return, both must sign ~ Date I D," Preparer's IIrr.. Slgnati.lre ,.. Lu Ann Siegfried Firm'sname Wagner's Tax Service (oryowslf ... self'employed).'" 1 0 1 E a s t Hi gh S t address. and ZIP code Carlisle Check if self-employed PA 1;'013 FDIA0112 11/25/03 184-38-1079 35 Pa e 2 36,830. 7,000. 29,830. 39 3,050. 40 26,780. 41 3,516. 42 ~ 43 3,516. ~ 53 54 3,516. 55 56 57 1,262. 58 59 60 4,778. N.o ~ 5,345. ~ 68 69 .. 70a 5,345. 567. 567. D Savings ~72 IZJ No Preparer'r. SSN or PTIN 175-48-4559 EIN 23-2262892 (717) 243-8314 Form 1040 (2003) Phone no RE-rUHI~ bY Ar'KIL 10, "UU4 IU: CAPITAL TAX COLLECTIOI~ BUREAU See Page 3 at Instruction Sheets in this packet tor mailing address labels or see back at Taxpayers Copy of return for acldresses, phone numbers, and office hours. o CONSTITUTE PROOF OF FILING, THE TAXPAYER'S COPY MUST IE VALlOATED BY THE BUREAU. TO HAVE YOUR COPY VALIDATED IV MAIL, RETURN BOTH THE TAX BUREAU'S ANDTAXPAYER'S COPIES ,LONG WITH A SELF ADDRESSED STAMPED ENVELOPE. ~(Q)U3 LOCAL EARNED INCOME TAX RETURN (FORM 531) www.captax.com I W-2 EARNINGS (From attached W.2's) , EMPLOYEE BUSINESS EXPENSES (Attached Federal Form 2106 & State Schedule UE) 3 TAXABLE VV-2 EARNINGS LESS EBEs (Subtract Line 2 from Line 1) I OTHER TAXABLE EARNED INCOME (NO INTEREST OR DIVIDENDS) LIST TYPE: i TOTAL TAXABLE EARNED INCOME (Add Lines 3 and 4) ENTER ONLY 10% OF NET LOSS(ES) FROM BUSINESS,_ PROFESSION, OR FARM (See instructions for more information) Report r"mainder of Net Lassies) on LlIle 9 below. Re on Net Profit s on LlIle 8 below. Attach Federal and State Schedules C F and/or K-1 1065 , SUBTOTAL (Subtract Line 6 from Line 5) IF LESS THAN ZERO, ENTER ZERO l NET PROFIT(S) FROM BUSINESS, PROFESSION, OR FARM i~:~;~:e,de;~55ndS"teSchedulesc.F 3 ENTER ONLY gO'};' OF NET LOSS(ES) from Business, Profession or Farm ~~~~~:_e1dr~~6~n~ Stale Schedules C, F ) Subtract Line 9 from Line 8 (IF LESS THAN ZERO, ENTER ZERO) 1 REQUIRED FOR INFORMATION PURPOSES ONLY: Enter Net, Subchapter S Corporation pass-thru Net Profit(s)/Loss(es) as reported on our PA.40 return 2 TOTAL TAXABLE EARNED INCOME AND NET PROFITS (Add Line 7 and 10) 3 ENTER TAX RATE FROM THE "TAX RATE TABLE" FOUND ON THE LAST PAGE OF THIS FORM PACKET ~ TAX LIABILITY: Multiply Line 12 by Line 13 :5 TOTAL LOCAL INCOME TAXES WITHHELD EXCEPT PHILADELPHIA INCOME TAX (From attached W_~~'s, Box 19) 3 QUARTERLY PAYMENTS AND/OR LAST YEAR'S OVERPAYMENT CREDITED TO THIS YEAR 7 CREDITS FOR TAXES PAID TO PHILADELPHIA AND/OR STATES OTHER THAN PA (ATTACH SOH. G) AND/OR CREDITS FOR CERTIFIED RESIDENTS OF THE HARRISBURG KEYSTONE OPPORTUNITY ZONE KOZ 3 TOTAL WITHHOLDINGS & PAYMENTS (Add Line 15, 16 and 17) 1 TAX BALANCE DUE (Subtract Line 18 from Line 14) PAYMENT NOT NECESSARY IF LESS THAN $1.00 ) INTEREST & PENALTY (See Instructions) 1[ TOTAL BALANCE DUE (Add Lines 19 and 20) Make check payable to "CTCB" 2 OVERPAYMENT (Subtract Line 14 tram Line 18) IF LESS THAN ZERO, ENTER ZERO ~ OVERPAYMENT TO BE REFUNDED Er>JTER nTA}?AYER CHECK ONE lRECT ,-'SPOUSE" OR"BOTH CHECKING SAVINGS ROUTING NO EPOSIT I JFORMATION I~- ACCOUNT NO, 4 OVERPAYiVlENT TO BE CREDITED TO NEXT YEAR'S TAX o OVERPAYMENT TO BE CREDITED TO SPOUSE'S BALANCE DUE FOR THIS FILING YlcAR YOUR RESIDENT MUNICIPALITY (TOWNSHIP, BOROUGH, OR CITY) t ;~., LC'~\i:,':<;_ i:k.,~~i\t:,F:::j:-L T:-\i-'- YOUR CTCB ACCOUNT NUMBER (IF KNOWN) o o .3';';:Jl:r,~ce'S7:1 YOUR NAME (LAST,FIRST,MI) SPOUSE'S NAME (LAST.FIRST,Mll ~,::o~t< Lltl;CA_ f. @ g / 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 ,- I ,- I ----I--- I ~ G/:-- -'---r- i +- I --+--- I I _..L. I .._.1. I I , -1'-- --r- I --I- I -+-- I '-, I I _L_ r.... r' "1-' , '~i 21'S- ':, '5 ~-1 {.1 ~.; ;~ ( t~: r ~~- r t l. t.:;, ~.< ;., SPOUSE'S CTCB ACCOUNT NUMBER (IF KNOWN) HAVE YOU MOVED FROM THE BEGiNNING OF THE TAX FILING YEAR TO PRESENT? DYES DNC HOME ADDRESS .(::~)17 :;i:",Ct;l 1'.1.. u"Ll ",Ll: .. jt~ 1 :,i L _~ IF YES. COMPLETE SCHEDULE P ON BACK OF "BUREAU'S" COPY OF RETURN . .. . . YOUR SIGNATURE X SPOUSE'S SIGN,';TUR~ IDI'ILY iF ALSO FILlHG ON THIS FORM) X DATE YOUR OCCUPATION SPOUSE'S OCCUPATION (ONLY IF ALSO FILING ON THIS FORl\rI) FIRM'S NAME (OR ENTER "SE IF SELF EMPLOYED) PAID PRE PARER'S l'iAME iPLEASE PRINT) PAID PREPARE A'S PHONE NUMBER STATEMENT fOR RECIPIENTS Of PA I I his torm snows me tOtal unemployment compensa Ion palO ro you oy UNEMPLOYMENT COMPENSATION PAYMENTS the Department of Labor and Industry in the tax year indicated, and the amount of Federal income tax withheld (if you requested tax withhold- Payer ing). This is important tax information ",od is being furnished to the COMMONWEALTH OF PENNSYLVANIA Internal Revenue Service (IRS). If you are required to file a return, a DEPARTMENT OF LABOR AND INDUSTRY negligence penalty or other sanction may be imposed on you if this BUREAU OF UC BENEfiTS AND ALLOWANCES income is taxable and the IRS determines that it has not been reported. HARRISBURG, PA 17121-0001 For income tax purposes, unemployment compensation benefits (717)783.3140 are reported in the calendar year in which they are paid, regard- OMBNO. 1545.0120 FEDERAL ID NO 23-6003107 ~.e.~s. ~I ~he~ ~~e. claim tor b:ne~ItS_~~S !jhJ~~Wlif:' 'i il,Cid eMf;",""m ,!,,'d." ',; {jii!.ifi~ soc T TAL PAYMENT TAX WITHHELD TAX YR, Dear Recipient: you may be eligible for the earned income credit, which is a Federal benefit for both 184-38 1079 $11,400.00 $1,140,00 2003 married and single parents who worked either lull or part time during all alar part of the year RECIPIENT'S name, address, zip code and earned less than the Federal qualifying amount. It you are eligible, you will either owe less taxes or Qualify for a larger tax return. To file WILLlAIvI A ROHIvI for the Earned Income Credit, fill oul and attach .Schedule EIC'. to ~our Federal income tax re- 2977 ENOLA RD turn. For more info:mation, call the IRS toll free CARLISLE PA 17013-9542 at 1-800-829.1040, NOTE: If you were ol/erpaid benefits, and repaid the I amount, it is still included in the 'TOTAL PAYMENT', Iflhe repayment was madein ':hesameyearastheove~ayment, makethenecessaryadjlJslmentandnotationonyourTax Form 1 0400r 104QA. Receiptsyou havelromthe Oept. of Labor & Industry maylle used as your proof lor adjust. mentsclaimed Auxlllaryaldsand selVlces are available upon request to individuals With disabilities. Equal OpportumtyEfTU)loyer/Prol)ram UC-1099G REV 1-04 S'b>cr u: 0 0. 0 " . 0..., " 0,< 3 ~ m m m m 0, ~ N:E 3 3 3 3 0 . ~ ~ ~ ~ 1l ....... 15 15 15 15 "- . 0 ~ ~ ~ ~ . '" . m 0 0 ~ ~ 0 0 0 c "'ON 3 ". " " 0. 0 ~.., ~ 0 " 0 . 0 $. . 0 . ~ ~ c:: 3 n 3 " " ~ ~. 'i. ~ ? 0. III :JE .. n " . " . ~ ~S Q) , ~ 0 ~ a ru ~ n " 0 ~..<Cl " ro <; . 0 "", '" ,~ '" ~ c 3'3.. is .' 3 0 . " 0 . c ...,,,, " c 0 3 0 ~ oa Q. 3 ~ 0 ~ 0 N ~ N "Ii -I ~ 'is 'is ~ .. n n ~. >< 0 0 ~ ~ VI . . or .' ~ Q .. '" ':" ru Q " ~ r ~ 0 . 0 " !!. '6 " . n 0 " :: '" ru z '" 0 0 ru ~ ru ~ 5' ~ 0 n b 0 0 3 0 . .. W ru x ~ ~ ~ ~ w ~ .. ~ ~ w " 3~ z ,. '" " '" ;\' ~2" 0 ~ 0 . 0 a; ~ ,g 0 < n ~ 0 ~ ~ ~ . ![ ~ .m r C 0 n 0 "- 0 " . " :;, 3i . . ro . ~ m n n 0"" . " . " . ~~ ~ n . 0 . '0 -=z" oo -=z" " ~ ~ '0 . " . " . . 0 ~ '6' " 3 . . n ~" " 0 '" 0 . ~ . 3 ~ " ~ 0 . 0<' ~ . . n .. '0 ~ '0 "e " ~ -. ~ 5 3' 0 . " ~ "- '" r ~Q.Q"", ~Q.O"... .."0"... " 0 0; n N N N .. .. ~ N . "- n " . ~ 5' 0 le " '" ~ ro n . 15 . 0 . . 0 '0 n ~ " 3 . n ~ 'i. . " . 0 . n .. ~ ,; . ~ ~ . m " I ~ . 5' ~ n 5' '6 ru " n n 0 " . " x -2 3 3 ro . . "- 0 S. ru ru N . ~ X X '" 0 0 . . . ~ 0: . < r s: . ~ ~ s: 0 ~ c . ~ . -2 0: . i6' 0 0: 2 ~ Ii . a: . ~ O>~ 0>9 0>:1 ....~ :i~ a:~ 00 u.. E It:a iii 8.s ~:e e i i Gl_ CIIEQ..ii:!;:J gt:OOl!g -;:l<E...c-b ::I ~ C "0:. Ii C .Q ~ Q) CII -< 0 :;.~ ~ ~!!: t.l . . ~ is ~:; 0.0: [;] '" o o '" o UJ f- o UJ a: a: 8'i 01 o :8 ~ .c l~ I-~ v '" v '" ... '" '" o c , ~ O~ , . a 0 ~.~ .2 ~~ x_ . a 1-0 .0 N c... Q- ~'" ogN ~- :;:;tfj. m j Q ~ ~ . N ~ g~~~~~ <ll - J;: 0Il:::- E ~ \/I E III ~ gg~g~~ ~l~~~€ c ~~=<P:E. g-.2 0..... .....<:1) E. &~ i~~ ~ ~.2 c ~ " ;e IX! >- D- B n ! , ~ .1 ~ & '" g V M ~~ ~ ~~ '" . j:R. ~-~ ffi~ ~~ -" ~.= ~ 15 . n n , g o c '~~ ~~ ~~ L'S.= M ~ E ~:1 ,g'~ ,,~ ~ ~ f~ E'S w5 ~~ ~w - w~O'6 ~~ "''' ~ ~- . _en 1: <:: ~82 ,g ~E. ::l .....t:: ~ ,- ~.g ;e~ Co ~ ... " 1 c 0 m ~ ... 0 ~ - , " .. ~ '" " >- , n iii v 0 0 0: .. <;0 8 - NU n ~ c~ 0 - ".U ... "z "' ] '" ".. '" - " .'" , ~ m 1 "'" '" N .. -'5tn m n , :i~ '"' c '" c 0 " 0 ~ 1-10 cc ~ :gLlJUJ g . "'..... ~ ",u..UJoCt n :I:C- g 1j~:="'" ." co: t ( 0: .. ~o t; VlUl ..~ "m .~ ~ ..~ "'" "'<l:;::I:Z ~ c~ ~~ ~c..~- ~ ~ ",z~ <=__0 .. >- "~Vl ~ - Ul(,J:J::E '" ffi - - "'0 ",z c 0 0: ~...~ w , LlJ...........Ul , V ~...'" >", ~C::""UJ 0 .. " _m" <tv .ii w c..o..r--c '" ~ "''''u " v > '" . ... ~ . " . ~ ~ , ~ '" ~ ~ ~ ~ t) ~ ~ Iii ~:E i: , . " . ~ . 5 "0 .0 ~ " 1 ~ -. " ~ " ~ In c . '" E ~ i o . '" 0 '" .. - .. - ~ ~ -;;-e.~ ~ On .~~ 502 ~. . ~ :! --'--~-~-------- d lir"pluyl'l:~. ~,()U"I "t:;:l.LlI it'! i'llinl~jer --------"---------- e EIIIIJluYc!I;'-' IkHl,l:, dliLili-'~,~ ClIKI ZIP code I ,L FlllploYl!1 -, SWk If) l1U1nt)(~1 'I 5 ::>1 Jl L~ '''''lltileli<:',\JI!,,,,I, ell_ .1\ ~\lWW.II:;.\JOV. Safe, i:JCCl1r,lle, FAST! Use ,e,1' -";" .'rPflt'1'n '~ '.. ~ 2 F,!{JerJI ilKorm; I,)): 'Nlthndc Wag~s lip:; othel' compt:IlSiJtion 3 Sociol C,UCU(lly \,ViJ(Jl'C, 1"~""":~~c~'_~~=_=[-------__-_-LNl8 N0 ,,'" 0008 It Erll!.Jlo'l"": idelHl!;L.H1ljll nund)d \~i;;,;;;;;~;,c~,;;,;,;,-,;;,;:;;,,_-;':iL'-';;:;;";:----'-------------- \ 116 S\dli:~ wdges, lipS de + I Ivledicdl<! ',~dge::, 0111(1 tipS SUCidl -,(!(UrilY [iP',----~ 9 Advanct' EIC I-ldyment 11 l\lonqudlilled pl<:lno, 13SI"llilllfl' L''',plu,/"c Pl'III"","HI 1,1,111 _Il TII",_I-p~lll ''''1'"1 o '14 Olher n State income telX 10 Lon,1 v'lJql)~ ;;"'"'H r 9 I I 1 4 5,,,.,,,, -.I.C UI"Y ,,,, ""tI,,,, ,,' 1'6~1\;dl:~t~-;;[~;t,8:i---- I I Alloull~",_1 til's 10 Oel-lend;,r,l can-; tJ"lldih .---------------..-------. '12<.1 ":,C,t: irlsuuuiQ!I-, kJI [j,jX "I::: ~----- I 1____- 2003 [)ep<lI'tment of the -Tr'e:~sury-- II'1t~;lrl,-11 Re'IE~IILI" :--"_i This Information is being rurnished tu Hle Imel'fldl RlJVI;;:I1U,-, Fo,m W..2 Wage and Tax Statement Copy B To Be Filed with Employee's fEDERAL Tax Return. Trlis information is being furnished to the Internal F~eV8! lue Service. Wages, tips, other camp. 5278.70 3 Social SlOcurity wages 6598. ~-; 5 MedicarlO wages and tips 6598.37 a Control Number Dept. 092408 70/EBB 520064 2 Federal income tax withheld 632.01 Social security tiilxwithheld 409.10 6 Medicare tax withheld 95.68 CDrp. mplayer use Dnly T 1403 c Employer's name, address. and ZIP code GRIFFIN SERVICES INC 5755 DUPREE DRIVE, NW ATLANTA GA 30327 b Employer's FED lD number S8.1470581 7 Social security tips B Advance EIC payment 11 NonquOIlified plans 14 other 1.32 PA 5UI Batch #01354 d Employee's SSA nl.lmber 184-38.1079 Atlocatedtips 10 Dependent care benefit'15 12a See instructions 10r box 12 D 1319.67 12b~ 12c -~ 12' 13 5tatemp.Retplan 3rd party sick pay elf Employee's name, address and ZIP code 1II/l.UI1M 11. RDHM 2977 ENOLA ROAD CARLISLE PA 17013 15 State Employer'~ state 10 no. PA 1882 8848 17 State income tax I , , I 16StateWage~,tips,e~ 6598.37 . 2003 W-2 and EARNINGS SUMMARY This blue Earnings Summary section is included with your W-2 to help describe portions in morE: dE:' The reverse side includes general information that you may also find helpful. 1. The following information reflects your iinal 2003pay stub plus any adjustments submitted by you, ernt=>Joy Gross Pay 6598.37 Soci211 Security 409.10 PA. State Income Tax Tax Withheld Box 17 of W-2 Box 4 of W-2 Local Income Tax 95.68 Box 19 of W-2 SUIISDI Box 14 of W-2 Fed. Income Tax Withheld Box 2 of W.2 632.01 Medicare Tax Withheld Box6ofW-2 'lcA.-, 1-15 2. Your Gross Pay Was Adjusted as follows to produce your W-2 Statement. Wages, Tips, other Social Security Medicare Compensation Wages Wages Box 1 of W-2 Box 3 of W-2 Box 5 of W-2 Gross Pay Less 401 (k) (D.Box 12) Reported W-2 Wages 6,598.37 1,319.67 5,278.70 6,598.37 NIA 6,598.37 PA. State Wages, CARLlSL Tips, Etc. Loc.;;1 Wa, Box 1 6 of W-2 Tips, Etc Box is of 6,598.37 N/A 6,598.37 6,598.37 NIA 6,598.37 6,59 6,59 3. Employee W-4 Profile. To change your Employee W-4 Profile Information, file 4 new >>'...,"*'#~~~~ 18 Local wages, tip$, etc. 184.76 6598.37 I 2ll Localityllame I ll~,~ C~f\L\~LE I, .. '='''~'I'' ~ Q1~l~fr" I <~~._,_._~_._~ .l9~.,!.... 5' roc.,ulI "lI'tu.. 'll l f;":'-i':;:;!;l'i,^":.::'-'- '- -- ~,;-r~~--. '--"~"'>~~-~~~-~ -->~ -:>>' ~ - ~ -- ~ .-'?_- - -" .- ~- >' -'-- _ --. --: _ ': ~~-_ _,,"::" -- ~ :: -'7~~ "--~""~~- 19 Localincometa)( WILLIAM A. ROHM 2977 ENOLA ROAD CARLISLE PA 17013 LINDA A. ROHM, : IN THE COURT OF COMMON PLEAS OF PlaintiffJRespondent ; CUMBERLAND COUNTY, PENNSYLVANIA v. ; CIVIL ACTION - LAW WILLIAM A. ROHM, ; NO. 2002-649 CIVIL TERM Defendant/Petitioner ; IN DIVORCE STIPULATION AND AGREEMENT THIS STIPULATION AND AGREEMENT, entered into the day and year hereinafter set forth by and between LINDA A. ROHM, (hereinafter referred to as "Wife") and WILLIAM A. ROHM, (hereinafter referred to as "Husband"), WHEREAS, the parties are legally married; and WHEREAS, the parties are parties to the above captioned divorce action; and WHEREAS, Husband is eligible to receive retirement benefits through Pepsico, Inc. from his employment with Quaker Oats; and WHEREAS, the parties wish to enter into a Stipulation and Agreement relative to Husband's receipt of retirement benefits. NOW, THEREFORE, in consideration of mutual covenants, promises and agreements as hereinafter set forth, the parties stipulate and agree as follows; 1. Husband became eligible to receive retirement b<~nefits beginning May 2004. 2. Husband's retirement benefits may be considered marital property subject to equitable distribution. 3. Through the above captioned divorce action, Wife may be eligible to receive a portion of the marital portion of Husband's retirement benefits. 4. A divorce action is pending, but the Court of Common Pleas of Cumberland County has not yet distributed the parties' marital property. DEfENDANT'S EX.HIBIT 1 0 ~~I~~ '--' 5. Pending equitable distribution of the parties' marital property, which may include a distribution of the marital portion of Husband's retirement benefits, the parties agree that Husband should begin to receive: monthly retirement benefits immediately. 6. Wife waives and releases her interest in these monthly benefits only to the extent that she shall not receive a portion of the marital portion of the retirement benefits unless and until the Court makes a determination that she is entitled to receive such benefits, which the Court has not yet done. 7. The parties agree that Pepsico, Inc. should immediately take whatever action necessary to begin disbursement of Husband's retirement benefits to him as he chooses. 8. Wife shall take no action whatsoever to limit or interfere with Pepsico's disbursement of retirement benefits to Husband. 9. In the event the Court determines that Wife is entitled to receive a portion of the marital portion of Husband's retirement benefits, the parties shall prepare a Qualified Domestic Relations Order to effectuate such a distribution. 10. This Stipulation and Agreement is not intendl~d to be a Qualified Domestic Relations Order. 11. This Agreement affects only the immediate distribution of Husband's retirement benefits to Husband and does not in any way imply a waiver of either party's interest they may have in marital property, induding, but not limited to, real property, personal property, vehicles, intangible personal property and marital debts. IN WITNESS WHEREOF, the parties intending to be legally bound by the terms hereof, set their hands and seals the day and year hereinafter mentioned. WITNESSETH: kaW{).ffjf{!j-- ~Jtt~ JVL~7d) c; / %10'1 Date "r -18.6,/ Date c/ . -' 'Ji:..-/l ,,-/.-:.:.nr/n ./I, :cJ /1'7 LINDA A. ROHM ~ ~~~.~ c{ d ~ ,WILLIAM A. ROHM . 'mill i ',,-, --I I ROBERT ? ZIEGLE ~ Qx:ueo HECORDE \ 0,: D:C[lS ..:h\i.lEi~LANO COU'Cy- i", Tax Parcel No. 02-20-1800-119 1'j rlAR 29 AI~ 9 3THIS D:EED, MADE THE 10th day of March in the year of our Lord Two Thousand and Four (2004), BElWEEN CHLOE E. KELLER, widow, of Carlisle, Cumberland County, Pennsylvania Grantor and UNDA A. ROHM, of Carlisle, Cumberland County, Pennsylvania, Grantee WITNESSETH, that in consideration of One and 00/100 Dollars, - $1.00 in hand paid, the receipt whereof is hereby acknowledged, the said grantor does hereby grant and convey to the said grantee, her Heirs and Assigns, ALL those two certain lots of ground situate in the Borough of Carlisle, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEING Lots Nos. 18 and 19 as shown on a plot oflots l:aid out and known as "Henderson Addition", and recorded in the office of the Recorder of Deeds in and for the said Cumberland County in Plan Book 2, Page 27, and being known and numberc:d as 227 Webster Street, Carlisle, Pennsylvania. BEING the same lots of ground which Ray S. Cornman, Executor of the Last Will and Testament of Mrs. Gertrude M. Cornman, conveyed by deed to Clyde E. Keller and Chloe E. Keller, his wife, dated January 3, 1939, and recorded in Cumberland County Deed Book "X", Vol. 11, Page 504. Clyde E. Keller died on the 2S1h day of November, 1985, thus vesting sole title to the property in Chloe E. Keller, his widow. TOGETHER with all and singular ways, waters, water-courses, rights, liberties, privileges, hereditaments and appurtenances whatsoever thereunto beIongiIJ~ or in anywise appertaining, and the reversions, and remainders, rents, issues, and profits thereof; and all the estate, right title, interest, trust, property, possession, claim and demand whatsoever, of it in law, equity, or othetwise howsoever, of, in and to the same and every part thereof. AND the said grantor hereby covenants and agrees that she will warrant specially the property hereby conveyed. THIS conveyance is a transfer from mother to daughter and is, therefore, exempt from Pennsylvania realty transfer tax. BOOK ;262 PAGf1_188 NOAN1'S OEfix.\-\\6\1 (O-,).{ -v'1 r o ~ , IN WITNESS WHEREOF, said grantor has hereunto set her hand and seal the day and year first above written. . Signed, Sealed and Delivered in the Presence of (/-ALk1&..<. \ ~ f!j.J:{-t. . {~ CWoe E. Keller Commonwealth of Pennsylvania County of Cumberland : ss. On this, the 10th day of March, 2004 , before me, Lindsay D. Baird, the undersigned officer, personally appeared Chloe E. Keller, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ....,~~~Lf::.~: ~ .' ~_~vt> ~ 4'1t~..... .. ,.:. ft"s...,,' ":.:... :<tt;....'\~ ,~. ~. . .. .f.... _._ .: 1': . ..; N Publi .. ... - . ,. \. l C:~.. \. .... " .. Notvial Seal 1~: ~j"', . ,'.\~ ~':'-"~' ,cC~~Y S D. Sol"" Nowy PlIbJlc . '1L .ij' ..........tg:;;~\~: My C'-_l..~ ~1.lJd c~ ... ~...... .\..~ I"~ kilt . ........Q~B Expln'< n-.. 21 -..,." '" .. '-"'il. . ~Ifottlll""\'" AIembet, f'ennayfvljiIaAs~orNofanoO I Hereby CertifY. that the precise residence and complete post office address of the WithIn named Grantee is : ;.ld'? WdXSKr Stull" (b..dtSU P"'l t"'?tJr3 ~a.d- A~mqfur ( a , . be recorded \ Certi fy tIns to ty PA I d Coun \ cumber an . ,. n r' Jut! · . '. LJ.J....:r" 'I'" ':"J,.~r--- f(.r-;. .,'~ ~ '$', . eeds ~ . Recorder of D 600K 26;2 PAGE1189 ...., ,"::') :,:2 C) C '} ._..._~ ~ '~'. r'_,,) ,-,,~ o -n :?:!] inp- n, I;' .-) :'-n I.("",?- ,\ll , , ~',{ "r'> "n .-< (;"? (,,) w ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co.lCity/Dist. of CUMBERLAND Date of Order/Notice 10/28/04 Tribunal/Case Number (See Addendum for case summary) o Original Order/Notice @ Amended Order/Notice o Terminate Order/Notice RE: ROHM, LINDA A. Employee/Obligor's Name (Last, First, MI) 206-36-1734 Employee/Obligor's Social Security Number 3925101346 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, Mil Employerl\Nithholder's Federal EIN Number COMMONWEALTH OF PA C/O PAYROLL OPERATIONS ATTACHMENTS RESEARCH UNIT PO BOX 8006 HARRISBURG PA 17105-8006 Jt1 02fJJlJ,).. -tycJ /1-1/ .P~fS 63;L;t:/P'IK3 See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 324.50 per month in current support $ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes (X) no $ 0.00 per month in medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ 324. SO 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: $ 74.88 per weekly pay period. $ 149.77 per biweekly pay period (every two weeks). $ 162.25 per semimonthly pay period (twice a month). $ 324.50 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten ('10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's! obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #10 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NI.IMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL..-"'-" ~Ji',","",\ . 1<1PVJHE COURT: -0 Date of Order:,DCl ~ lj tilll+ eo~ t;: .~v/,tJ{) 7V s Form EN-028 Worker ID $IATT Service Type M OMB No.: 0970-01 S4 ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If ~hecked you are required to provide a {:opy of this form to your employee. If YOl,Jr employee works in a state that is different from the state that issued this order, a copy must be provided to your employee even if the box is not checked. 1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned businesses located on a reservation that choose to withhold in accordance with this notice. 2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 4. * Repol1ing the Pay date/Date of'vVithholding. You must report the paydate!date of vvithholding vvhen sending the payment. The paydate/date of vvithholding is the date on vvhich amount vvas vvitl,l,eld from the employee's vvages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 5. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #1 0 below) 6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S 10: 2321722990 EMPLOYEE'S/OBLlGOR'S NAME: ROHM. LINDA A. EMPLOYEE'S CASE IDENTIFIER: 3925101346 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. 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. 10. * Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.s.c. 91673 (b)l; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 11. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: DOMESTIC 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 (71 7) 240-6225 or by FAX at LZ1ZL240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Worker ID $IATT Service Type M OMB No.: 0970-0154 ADDENDUM Summary of Cases on Attachment Defendant/Obligor: ROHM, LINDA A. PACSES Case Number 632106483 Plaintiff Name WILLIAM A. ROHM Docket Attachment Amount 02-649 CIVIL $ 324.50 Child(ren)'s Name(s): PACSES Case Number Plaintiff Name DOB Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB o 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. o 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 PACSES 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 o 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. o 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 PACSES Case Number Plaintiff Naml~ Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB o 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. . . . . .. ',' " . . .,.... , " o 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. Addendum Form EN-028 Worker ID $IATT Service Type M OMB No.: 0970-01 S4 0 ,....", () C:ll c- c.:;:;:) -n .r- ....~-"ri Z :::l -'-' fr' :L., r-; I ... C:.> rl1-- ~ il "111.::: :9 r:;; (,f) i'l I _'J~ -,. N 0 I~~t~:; "I "Cl "'1'.~ I ~~~; --") ..,., :J;: ~,~O c,...:> arM =;;; ---I -;> =-:1 en ':I -< 0::> ::< ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 01/07/05 Case Number (See Addendum for case summary) o Original Order/Notice o Amended Order/Notice @ Terminate Order/Notice RE: ROHM, LINDA A. Employee/Obligor's Name (Last, First, Mil 206-36-1734 Employee/Obligor's Social Security Number 3925101346 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, Mil Employerl\Nithholder's Federal EIN Number COMMONWEALTH OF PA C/O PAYROLL OPERATIONS ATTACHMENTS RESEARCH UNIT PO BOX 8006 HARRISBURG PA 17105-8006 Jd df)1);). -tVCJ t7t1 ;?~~fS G;;)/oiP '/f3 See Addendum for dependent naines and birth dates associat4~ with cases on attachment. ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's!obligor's income until further notice even if the Order/Notice is not issued by your State. $ 0.00 per month in current support $ 0 . 00 per month in past-due support Arrears 12 weeks or greater? 0 yes (X) no $ 0.00 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 $ 0.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 0.00 per weekly pay period. $ 0.00 per biweekly pay period (every two weeks). $ 0.00 per semimonthly pay period (twice a month). $ 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). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER 10 (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. -- ~.-" l""C:-'~ ~'.':; . . ,. I.!:, . .~, '1. ...:.lcL.,c:'~.';:""' '8'Y HE COURT: j-IO-{)5 bbwHf'2.fJ F JU fcG- Form EN-028 Worker ID $IATT Date of Order: JAM 1 0 2005 Service Type M OMB No.: 0970-0154 ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If ~hecked you are required, to provige a {:opy of this form to your. employee. If your employe~ works in.a state that is different from the state that Issued thiS order, a copy must be provided to your employee even If the box IS not checked. 1. 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. * Repoltil,g tl,e Paydate/Date of Witl,I,oldi..g. You I ,lUst lepolt ti,e paydateldate of ""itl,holdil,g vvl,el, sel,dil,g tI,e paylllellt. The pay date/date of vvitl,l,oldil,g is tI,e date Oil ""I,id, allloUllt vvas vvitl,l,eld f,OIIl ti,e elllployt:e's vvages. 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/t-lotice 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 retum a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2321722990 EMPLOYEE'S/OBLlGOR'S NAME: ROHM. LINDA A. EMPLOYEE'S CASE IDENTIFIER: 3925101346 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 01' 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 (15 U.S.c. 91673 (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. 1 1. 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 U1Zl..240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Worker ID $IATT Service Type M OMB No.: 0970-0154 n I"-.) 0 <.= ~c~ c..-:::> .1 ""', C- :~ Ii . , ~ rn--. .. ~ h1 :9,9 -0 ~~: I, {?~5 '<'( ,~- . "'.-' :3rn ..... r (.-j ~--l ",;=.-.. .~ ---j 0 ~i~ -( (..I. -.:.,...,1 c: .~ !"'r r-r e. C1 LINDA A. ROHM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW WILLIAM A. ROHM, : NO. 2002-649 CIVIL TERM Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I, William A. Rohm, acknowledge that I received a eopy of Plaintiffs Complaint in Divorce in the above captioned action by it being mailed to me by first class, U.S. mail on or about February 20, 2002. Date: Hi :T 7" OZ ot' 5--- -/' C; /Cd;' ~lOHM <.-_._1 Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA LINDA A. ROHM, v. : CIVIL ACTION - LAW WILLIAM A. ROHM, : NO. 2002-649 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A. Complaint in Divorce under ~3301 (c) of the Divorce Code was filed on February 6, 2002, and served on or about February 20, 2002. 2. The marriage of Plaintiff and Defendant is in-etrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. ~4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE:;:;:/; <],1... ;;ZooS- ~L ad W LIAM A. ROHM:Defendant Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA LINDA A. ROHM, v. : CIVIL ACTION - LAW WILLIAM A. ROHM, : NO. 2002-649 CIVIL TERM Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concl:ming alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorce 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. ~4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE:k.i 9~ ;lddS- ~/ L 4 d '.1\iitUAM A. ROHM, Defendant ~..,-. 11 . . LINDA A. ROHM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW WILLIAM A. ROHM, Defendant : NO. 2002-649 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A. Complaint in Divorce under 93301 (c) of the Divorce Code was filed on February 6, 2002, and served on or about February 20, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry ofthe decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 94904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: mcz-,ch 30, 200:3 ~'-' ,~ ~. /I. fr:rl'fd7 LINDA A. ROHM, Plaintiff n r-,' c;.;.J <:::~:) "" '?::'; -;;J CJ C> .\1 ::;l r,~.~~ -,.-,' , :~~\~;; ,....,..., "'-'-":l ) ~. :)h\ ..-~\ ~. ...;. ~".'" r:? - (...:~ . . LINDA A. ROHM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW WILLIAM A. ROHM, Defendant : NO. 2002-649 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorce 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. S4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: //hAr4,O leV:> Jt,~ ~:~(~7 LINDA A. ROHM, Plaintiff r--.J '.:;::' ~;j? ::!:1''' ~r' -;.;::J o -\'1 :cJ d'1f~ ~lri'\ =-:lCJ "::~~!:.' .~';-~ r-r\ ~'- ~i .:1 .< CP 1') <'--,) - LINDA A. ROHM, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 02 - 649 CIVIL WILLIAM A. ROHM, Defendant IN DIVORCE ORDER OF COURT AND NOW, this ;//0 day of ----- 2005, the economic claims raised in the proceedin having been resolved in accordance with a separation and property settlement agreement dated March 30, 2005, the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. BY THE COURT, cc: ~ra W. Haggerty Attorney for Plaintiff Alarylou Matas Attorney for Defendant ~ ~-O 6-0 o > "{1'1 . I'".' fCC: '''I) 1':1 (.'..- t. ~D"7 '.~' ".' ,\.. ,l.. '. _ v SEPARATION AND PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT made this~fI'4ay of fl{u/U'J- , 2005, by and between LINDA A. ROHM, of227 Webster Street, Carlisle, Cumberland County, Pennsylvania, 17013, party ofthe first part, hereinafter referred to as "Wife," AND WILLIAM A. ROHM, of 2977 Enola Drive, Carlisle, Cumberland County, Pennsylvania, 17013, party of the second part, hereinafter referred to as "Husband," WITNESSETH: WHEREAS, Husband and Wife were married on February 2, 1973, in Cumberland County, Pennsylvania; and WHEREAS, Husband and Wife are residents of the Commonwealth of Pennsylvania and have been so for at least the past six months; WHEREAS, certain differences have arisen between the parties hereto which have made them desirous of living separate and apart from one another; and WHEREAS, Husband and Wife desire to settle and determine certain of their marital rights and obligations, and make an equitable distribution of their marital property, determine their rights to alimony and support and any other matters which may be considered under the Divorce Code; and WHEREAS, it is the intention and purpose of this Agreement to set forth the respective ri$hts and duties of the parties while they continue to live apart from each other and to settle all fiJjlancial and property rights between them; and WHEREAS, the parties hereto have mutually entered into an agreement for the division of their jointly owned assets, the provisions for the liabilities they owe, and provisions for the --Page 1 of15-- resolution of their mutual differences, after both have had full and ample opportunity to consult with attorneys of their respective choice, the parties now wish to have that agreement reduced to writing. NOW, THEREFORE, the parties hereto in consideration of the mutually made and to be ~ept promises set forth hereinafter and for other good and valuable consideration, and intending to be legally bound and to legally bind their heirs, successors, assigns, and personal lepresentatives, do hereby covenant, promise and agree as follows: ARTICLE I SEPARATION 1.1 It shall be lawful for Husband and Wife at all times hereafter to live separate and apart ftom each other and to reside from time to time at such place or places as they shall respectively deem fit free from any control, restraint, or interference, direct or indirect, by each other. Neither party shall molest the other or compel or endeavor to compel the other to cohabit or df,vell with him or her by any legal or other proceedings. The foregoing provisions shall not be t<(ken to be an admission on the part of either Husband or Wife of the lawfulness of the causes leading to them living separate and apart. ARTICLE II DIVORCE 2.1 This Agreement is not predicated on divorce. It is specifically understood and agreed by I aqd between the parties hereto that each of the said parties does hereby warrant and represent to , th~ other that the execution and delivery of this Agreement is not predicated upon nor made sJbject to any agreement for institution, prosecution, defense, or for the non-prosecution or non- defense of any action for divorce; provided, however, that nothing contained in this Agreement --Page 2 of] 5-- shall prevent or preclude either of the parties hereto from commencing, instituting or prosecuting any action or actions for divorce, either absolute or otherwise, upon just, legal and proper grounds; not to prevent either party from defending any such action which has been, may, or shall be instituted by the other party, or from making any just or proper defense thereto. It is warranted, covenanted, and represented by Husband and Wife, each to the other, that this Agreement is lawful and enforceable and this warranty, covenant, and representation is made for the specific purpose of inducing Husband and Wife to execute the Agreement Husband and Wife each knowingly and understandingly hereby waive any and all possible claims that this 1i\greement is, for any reason, illegal, or for any reason whatsoever of public policy, Unenforceable in whole or in part. Husband and Wife do each hereby warrant, covenant and '1gree that, in any possible event, he and she are and shall forever be estopped from asserting any illegality or unenforceability as to all or any part of this Agreement 2.2 It is further specifically understood and agreed that the provision of this Agreement nblating to the equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever. Should either of the parties obtain a decree, judgment or order of separation or divorce in any other state, country, or jurisdiction, each of the pltrties to this Agreement hereby consents and agrees that this Agreement and all its covenants s~all not be affected in any way by any such separation and divorce. 2.3 This Agreement shall survive any decree in divorce and shall be forever binding and c~nclusive on the parties. It is understood by and between the parties that this Agreement shall bq incorporated into any decree, divorce or separation, but it shall not be deemed merged in such decree. --Page 3 of 15-- ARTICLE III EOUlTABLE DISTRIBUTION OF MARITAL PROPERTY 3.1 The parties have attempted to divide their marital property in a manner which conforms ,to the criteria set forth in the Pennsylvania Divorce Code, and taking into account the following considerations: the length of the marriage; the prior marriages of the parties; the age, health, station, amount and sources of income, vocational skills, employability; estate, liabilities, and needs for each of the parties; the contribution of one party to the education, training or increased ~aming power to the other party; the opportunity of each party for future acquisition of capital ~ssets 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 part in the ~cquisition, preservation, depreciation, or appreciation of marital property, including the <tontribution of a party as a homemaker; the value of the property set apart to each party; the ~tandard of living of the parties established during their marriage; the economic circumstances of ~ach party, including federal, state and local tax ramifications, at the time of the division of the property is to become effective; and whether the parties will be serving as the custodian of any dependent minor children. 3.2 The division of existing marital property is not intended by the parties to constitute in any *ay a sale or exchange of assets and the division is being effected without the introduction of ~tside funds or other property not constituting marital property. The division of property under t~is Agreement shall be in full satisfaction of all rights of equitable distribution of the parties. --Page 4 of 15-- 3.3 Personal Prooertv. The parties acknowledge that they have divided their personal property, tangible and intangible, to their mutual satisfaction. The parties acknowledge that they have the cash, accounts, furniture, appliances, guns, and other personal property, tangible and intangible, in their possession that they wish to have and retain from this time forward. Neither party shall make any claim whatsoever against the personal property in the other party's possession or assets in that other party's possession from the time of execution of this Agreement forward. 3.4 Life Insurance. Each party agrees that the other party shall have sole ownership and possession of any life insurance policies owned by the other. Each party shall have the right to borrow against, cash in policies, change beneficiaries, an exercise any other incidents of ownership of the respective policies free of any right or claim by the other party. Each party agrees to sign any documents necessary to waive, relinquish or transfer any rights in such ~olicies to the respective party who presently owns such policies. 3.5 Subsequentlv Acquired Prooertv. Husband and Wife agree to waive and relinquish any apd all right that he or she may now have or hereafter acquire in any real or tangible personal property subsequently acquired by the other party. Husband and Wife specifically agree to ~aive and relinquish any right in such properly that may arise as a result of the marriage rJlationship. 3.6 Real Estate. The parties are joint owners of real estate located at 2977 Enola Drive, Carlisle, Cumberland County, Pennsylvania, which property is currently held in the joint names --Page 5 of 15-- as tenants by the entirety. Wife agrees that contemporaneously with the execution of this Agreement, she will execute a Deed conveying all of her right, title and interest in the aforesaid real estate to Husband by fee simple general warranty deed. Wife shall then make no claim of any nature whatsoever relative to any legal or equitable interest in the aforesaid real estate. From the date of execution and delivery of the Deed forward, Husband shall be solely and exclusively responsible for the payment of the taxes, insurance and maintenance associated with the aforesaid property and shall make each such payment due hereunder when and as payments are due, including any and all interest, late charges, and the like. Husband shall indemnify Wife and hold her harmless from and against any and demands for payment or collection activity of any nature whatsoever on account of the aforesaid payments from the date of signing and delivery of the aforesaid Deed forward. The receipt of benefits provided for herein by Wife take into consideration Wife's transfer of her legal and equitable interest in the aforesaid real estate. From the date of execution qf this Agreement forward, Wife shall make no claim of any nature whatsoever, legal or e~uitable, in the interest in the aforesaid real estate. 3.7 Pension. Retirement, Protit-Sharinl!. Wife agrees to waive, relinquish or transfer any apd all of her right, title and interest she has or may have in Husband's pension or retirement atcount with Pepsico, Inc. through his employment with Quaker Oats. Wife hereby waives, r~linquishes and transfers any and all right, title and interest she has in this retirement account, as ~elJ as any other accounts that Husband may have in his individual name or may have secured tl\rough his present or prior employment. The parties previously signed a Stipulation and Aigreement dated September 18, 2004, regarding Wife's release of interest in Husband's pension account, which is attached hereto and incorporated herein by reference as Exhibit "A." --Page 6 of 15-- Husband agrees to waive, relinquish or transfer any and all of his right, title and interest he has or may have in Wife's pension, retirement, deferred compensation account with Pennsylvania State Employees Retirement System and the like through her employment with Pennsylvania State Library. Husband hereby waives, relinquishes and transfers any and all right, title and interest he has in any present retirement account, as well as other accounts that Wife may have in her individual name or may have secured through her present or prior employment. 3.8 Vehicles. The parties acknowledge that at the time of separation Wife retained sole and exclusive ownership and possession of a certain 1998 Chevrolet Blazer Sport Utility vehicle which was originally titled in the parties' names jointly. Husband executed the title of the 'liehicle to Wife's name individually. Husband shall make no claim whatsoever relative to access tb or use of the aforesaid vehicle and shall make no ownership claims of any nature whatsoever tll the aforesaid vehicle from the date of execution of this Agreement forward. The parties acknowledge that at the time of separation Husband retained sole and e~clusive ownership and possession of the parties' 1998 Chevrolet 1500 Longbed Pickup truck, ~hich was originally titled in the parties name jointly. Wife executed the title to the vehicle to Husband's name individually. Wife shall make no claim whatsoever relative to access to or use or the aforesaid vehicle and shall make no ownership claims of any nature whatsoever to the aforesaid vehicle from the date of execution of this Agreement forward. 3.9 Intanflible Personal Property. At the time of separation, Wife retained possession of the i1fnds held in the Members First Credit Union account listed in her name individually, with an a*proximate date of separation balance of THREE THOUSAND SEVENTY-SEVEN AND 23/100 ($3,077.23) DOLLARS. Husband waives all interest he may have had to these funds. --Page 7 of 15-- At the time of separation, Husband retained possession of the funds held in the Members First Credit Union account listed in his name individually, with an approximate date of separation balance of SLY THOUSAND NINE HUNDRED THIRTY-FIVE AND 44/100 ($6,935.44) DOLLARS. Wife waives all interest she may have had to these funds. Husband owns or has an interest in an IRA CD held at First Union bank with an approximate maturity value of ONE HUNDRED THIRTY-FIVE THOUSAND THREE JjUNDRED F/FTY-FOUR AND 44/100 ($135,354.44) DOLLARS. Husband shall transfer his interest in this CD to Wife's name individually within fifteen (15) days of being requested to do so by Wife or Wife's legal counsel. Husband shall waive any interest he may have in this CD and shall make no claim whatsoever to the funds from the date of execution of this Agreement forward. The parties are the joint owners of savings bonds with an approximate date of separation value of FIVE THOUSAND SIX HUNDRED THIRTY-FOUR AND 66/100 ($5,634.66) JjJOLLARS. Husband shall sign whatever documents necessary to transfer his interest in these bonds to Wife's name individually within fifteen days of being requested to do so by Wife or Wife's legal counsel. Husband shall waive all interest he may have in these bonds and shall make no claim whatsoever to these bonds from the date of execution of this Agreement forward. In the event other joint accounts still exist between the parties, each party agrees to sign alny documents necessary to close any joint accounts within fifteen (15) days of signing this J\.greement. Neither party shall make any claim of any nature whatsoever against the other party rflative to the financial accounts or other investments or intangible personal property that have , , a/ready been retained by that party as described herein. --Page 8 of 15-- ARTICLE IV DEBTS OF THE PARTIES 4.1 Each party represents to the other that except as is otherwise set forth in this Agreement, there are no major outstanding obligations of the parties; that since the separation neither party ,has contracted for any debts for which the other will be responsible and each party indemnifies and holds harmless the other for all obligations separately incurred or assumed under this Agreement. ARTICLE VI ALIMONY. ALIMONY PENDENTE LITE. COUNSEL FEES. COSTS & EXPENSES 5.1 The parties have each secured and maintained a substantial and adequate fund from ~hich to provide themselves sufficient resources to provide for their own comfort, maintenance i\!ld support in the station of life to which they were accustomed. Husband and Wife do hereby waive, release and give up any rights they may have, respectively against the other, for alimony, ~upport or maintenance. 5.2 Husband and Wife specifically waive, release and give up any rights for alimony, ~Iimony pendente lite and spousal support pursuant to Chapter 37 of the Domestic Relations Code. ARTICLE V MISCELLANEOUS PROVISIONS 6.1 Advice of Counsel. The parties acknowledge that they have either received independent legal advice from counsel of their own selection, that they fully understand the facts and have --Page 9 of 15-- been fully informed as to their legal rights an obligation or otherwise understand those legal rights and obligations. They acknowledge and accept that this Agreement is, in the circumstances, fair and equitable, that it is being entered into freely and voluntarily, after having received such advice and with such knowledge that execution of this Agreement is not the result of any duress or undue influence, and further that it is not the result of any collusion or improper or illegal agreement or agreements. 6.2 Mutua/ Release. Husband and Wife each do hereby mutually remise, release, quitclaim, i\md forever discharge the other and the estate of such other, for all times to come and for all purposes whatsoever, of and from any and all right, title and interest, or claims in or against the Jilroperty (including income and gain from property hereafter accruing) of the other or against the <;\state of such other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against such other, the estate of such other, or any part thereof, ~hether arising out of any former acts, contracts, engagements, or liabilities of such other as by ~ay of dower or curtesy, or claims in the nature of dower or curtesy or widow's or widower's rIghts, family exemption, or similar allowance, or under the intestate laws, or the right to take against the spouse's Will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether aj-ising under the laws of (a) Pennsylvania, (b) any state, commonwealth or territory of the lfnited States, or (c) any other country, or any rights which either party may have or at any time hbreafter have for past, present, or future support or maintenance, alimony, alimony pendente li~e, counsel fees, costs or expenses, whether arising as a result of the marital relation or , otherwise, except and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof. It is the --Page 10 of 15-- intention of Husband and Wife to give to each other by execution of this Agreement a full, complete, and general release with respect to any and all property of any kind or nature, real or personal, not mixed, which the other now owns or may hereafter acquire, except and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof. 6.3 Bankruvtcv. The parties agree that any and all financial obligations assumed herein shall not be subject to discharge through bankruptcy proceedings. This includes, but is not limited to, all financial obligations assumed under this Agreement In the event either party attempts to avoid financial obligations described herein through bankruptcy proceedings the other party shall have an independent claim against the party claiming bankruptcy for any and all sums that the <1lther party assumes or is required to pay due to the actions of the party claiming bankruptcy. Further, all rights available to the other party provided for in Paragraph 6.13 hereinafter shall be qvailable to the party not filing bankruptcy. 6.4 Warranties. Each party represents that they have not heretofore incurred or contracted for any debt or liability or obligation for which the estate of the other party may be responsible or liable, except as may be provided for in this Agreement Each party agrees to indemnify or hold the other party harmless from and against any and all such debts, liabilities or obligations of dvery kind, including those for necessities, except for the obligations arising out of this 4.greement Husband and Wife each warrant, covenant, represent and agree that each will, now ~d at all times hereafter, save harmless and keep the other indemnified from all debts, charges, ard liabilities incurred by the other after the execution date of this Agreement, except as is --Page 11 of 15-- otherwise specifically provided for by the terms of this Agreement and that neither of them hereafter incur any liability whatsoever for which the estate of the other may be liable. 6.5 No waiver or modification of any of the terms of this Agreement 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. 6.6 Husband and Wife 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 implementation of this Agreement, and as their respective counsel shall mutually agree should be so executed in order to carry fully and effectively the terms of this Agreement. 6.7 This Agreement shall be construed in accordance with the laws of the Commonwealth of pennsylvania which are in effect as ofthe date of the execution of this Agreement. 6.8 This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 6.9 This Agreement constitutes the entire understanding of the parties and supersedes any <ilnd all prior agreements and negotiations between them. There are no representations or ~arranties other than those expressly set forth herein. --Page 12 of 15-- 6.10 Severabilitv. If any term, condition, clause, section, or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement, and in all other respects, this Agreement shall be valid and continue in full force, effect, and operation. Likewise, the failure of any party to meet his or her obligation under anyone or more of the articles and sections herein shall in no way void or aIter the remaining obligations of the parties. 6.11 It is specifically understood and agreed that this Agreement constitutes the equitable ~istribution of property, both real and personal, which was legally and beneficially acquired by ~usband and Wife, or either of them, during the marriage as contemplated by the Divorce Code ?fthe Commonwealth of Pennsylvania. 6.12 Disclosure. The parties each warrant and represent to the other that he or she has made a ~ll and complete disclosure to the other of all assets of any nature whatsoever in which party has l/fl interest, of the sources, and amount of the income of such party of every type whatsoever, and all other facts relating to the subject matter of this Agreement. 6.13 Enforceabilitv and Consideration. This Agreement shall survive any action for divorce l/fld decree of divorce and shall forever be binding and conclusive on the parties; and any independent action may be brought, either at law or in equity, to enforce the terms of the tgreement by either Husband or Wife until it shall have been fully satisfied and performed. The qonsideration for this contract and agreement is the mutual benefits to be obtained by both of the parties hereto and the covenants and agreements of each of the parties to the other. The --Page 13 of 15-- adequacy of the consideration for all agreements herein contained is stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound hereby. In the event either party breaches the aforesaid Agreement and it is determined through appropriate legal action that the alleged party has so breached the Agreement, the breaching party shall be responsible for any :and all attorney's fees as well as costs and expenses associated with litigation incurred by the non-breaching party to enforce this Agreement against the breaching party. In the event of breach, the non-breaching party shall have the right, at his or her election, to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her including equitable enforcement of this Agreement. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and : year first above written. WI1NESSED BY: / \ . 1/ . n '1.1 .1 '. /IItl/. :3 /30 I oS;- Date ,/ ~\/ ~ /' (/ t.~_--:;t--/h ,/I, LINDA A. ROHM .-.) .t:.r /1<-/>,7" :7 } 1.../ KF-U ['I",' Y::'- _~I,--.J.h 11--/L- ] J z.} ..- hb /- .A:>o-' Date --Page 14 of15-- COMMONWEALTH OF PENNSYLVANIA COUNTY OF~c9-- On thici:>+1,- day of '1l~ , 2005, before me, the undersigned officer, personally appeared LINDA A. ROHM, known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seaL (:{~~:6~:~ [A NCil:\na\ Seal \ Rhonda D. Rudy, Notary Public Carlisle BOrG, Cumberland County . . My Commission E...,~!re~; ,/\ug. 12_ 2006 ! ~ ----.--...---- - Membe~':-i.'i':':.~,- (1/ :'Jr:18nes !COMMONWEALTH OF PENNSYLVANIA /j . COUNTY OF Cu rv'..l.:u \..lJ' v"C On this 9iJ, day of (f b.tc, CG~ ' 2005, before me, the undersigned officer, personally appeared WILLIAM A. ROHM, known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seaL fi ARIAl SEAL ROBIN]. GOSHORNM~~~m~~~~~w :~61~~I~~,~~'E~~IRES APRil 17 20U7 -Page 15 of15-- . . SEPARATION AND PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT made this~fl'day of f11.JuuJ- , 2005, by and between LINDA A. ROHM, of227 Webster Street, Carlisle, Cumberland County, Pennsylvania, 17013, party of the first part, hereinafter referred to as "Wife," AND WILLIAM A. ROHM, of2977 Enola Drive, Carlisle, Cumberland County, Pennsylvania, 17013, party of the second part, hereinafter referred to as "Husband," WI1NESSETH: WHEREAS, Husband and Wife were married on February 2, 1973, in Cumberland County, Pennsylvania; and WHEREAS, Husband and Wife are residents of the Commonwealth of Pennsylvania and have been so for at least the past six months; WHEREAS, certain differences have arisen between the parties hereto which have made them desirous of living separate and apart from one another; and WHEREAS, Husband and Wife desire to settle and determine certain of their marital rights and obligations, and make an equitable distribution of their marital property, determine their rights to alimony and support and any other matters which may be considered under the Divorce Code; and WHEREAS, it is the intention and purpose of this Agreement to set forth the respective rights and duties of the parties while they continue to live apart from each other and to settle all financial and property rights between them; and WHEREAS, the parties hereto have mutually entered into an agreement for the division of their jointly owned assets, the provisions for the liabilities they owe, and provisions for the --Page 1 of 15-- . . resolution of their mutual differences, after both have had full and ample opportunity to consult with attorneys of their respective choice, the parties now wish to have that agreement reduced to writing. NOW, THEREFORE, the parties hereto in consideration of the mutually made and to be kept promises set forth hereinafter and for other good and valuable consideration, and intending to be legally bound and to legally bind their heirs, successors, assigns, and personal representatives, do hereby covenant, promise and agree as follows: ARTICLE I SEPARATION 1.1 It shall be lawful for Husband and Wife at all times hereafter to live separate and apart from each other and to reside from time to time at such place or places as they shall respectively deem fit free from any control, restraint, or interference, direct or indirect, by each other. Neither party shall molest the other or compel or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceedings. The foregoing provisions shall not be taken to be an admission on the part of either Husband or Wife of the lawfulness of the causes leading to them living separate and apart. ARTICLE II DIVORCE 2.1 This Agreement is not predicated on divorce. It is specifically understood and agreed by and between the parties hereto that each of the said parties does hereby warrant and represent to the other that the execution and delivery of this Agreement is not predicated upon nor made subject to any agreement for institution, prosecution, defense, or for the non-prosecution or non- defense of any action for divorce; provided, however, that nothing contained in this Agreement --Page 2 of 15-- . . shall prevent or preclude either of the parties hereto from commencing, instituting or prosecuting any action or actions for divorce, either absolute or otherwise, upon just, legal and proper grounds; not to prevent either party from defending any such action which has been, may, or shall be instituted by the other party, or from making any just or proper defense thereto. It is warranted, covenanted, and represented by Husband and Wife, each to the other, that this Agreement is lawful and enforceable and this warranty, covenant, and representation is made for the specific purpose of inducing Husband and Wife to execute the Agreement. Husband and Wife each knowingly and understandingly hereby waive any and all possible claims that this Agreement is, for any reason, illegal, or for any reason whatsoever of public policy, unenforceable in whole or in part. Husband and Wife do each hereby warrant, covenant and agree that, in any possible event, he and she are and shall forever be estopped from asserting any illegality or unenforceability as to all or any part of this Agreement. 2.2 It is further specifically understood and agreed that the provision of this Agreement relating to the equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever. Should either of the parties obtain a decree, judgment or order of separation or divorce in any other state, country, or jurisdiction, each of the parties to this Agreement hereby consents and agrees that this Agreement and all its covenants shall not be affected in any way by any such separation and divorce. 2.3 This Agreement shall survive any decree in divorce and shall be forever binding and conclusive on the parties. It is understood by and between the parties that this Agreement shall be incorporated into any decree, divorce or separation, but it shall not be deemed merged in such decree. --Page 3 of 15-- . . ARTICLE III EQUITABLE DISTRIBUTION OF MARITAL PROPERTY 3.1 The parties have attempted to divide their marital property in a manner which confonns to the criteria set forth in the Pennsylvania Divorce Code, and taking into account the following considerations: the length of the marriage; the prior marriages of the parties; the age, health, station, amount and sources of income, vocational skills, employability; estate, liabilities, and needs for each of the parties; the contribution of one party to the education, training or increased eaming power to the other party; the opportunity of each party for future acquisition of capital assets and income; the sources of income of both parties, including but not limited to medical, retirement, insurance or other benefits; the contribution or dissipation of each part in the acquisition, preservation, depreciation, or appreciation of marital property, including the contribution of a party as a homemaker; the value of the property set apart to each party; the standard of living of the parties established during their marriage; the economic circumstances of each party, including federal, state and local tax ramifications, at the time of the division of the property is to become effective; and whether the parties will be serving as the custodian of any dependent minor children. 3.2 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 rights of equitable distribution of the parties. --Page 4 of 15-- '. . . 3.3 Personal ProDertv. The parties acknowledge that they have divided their personal property, tangible and intangible. to their mutual satisfaction. The parties acknowledge that they have the cash, accounts, furniture, appliances, guns, and other personal property, tangible and intangible, in their possession that they wish to have and retain from this time forward. Neither party shall make any claim whatsoever against the personal property in the other party's possession or assets in that other party's possession from the time of execution of this Agreement forward. 3.4 Life Insurance. Each party agrees that the other party shall have sole ownership and possession of any life insurance policies owned by the other. Each party shall have the right to borrow against, cash in policies, change beneficiaries, an exercise any other incidents of ownership of the respective policies free of any right or claim by the other party. Each party agrees to sign any documents necessary to waive, relinquish or transfer any rights in such policies to the respective party who presently owns such policies. 3.5 Subsequentlv Acquired ProDertv. Husband and Wife agree to waive and relinquish any and all right that he or she may now have or hereafter acquire in any real or tangible personal property subsequently acquired by the other party. Husband and Wife specifically agree to waive and relinquish any right in such property that may arise as a result of the marriage relationship. 3.6 Real Estate. The parties are joint owners of real estate located at 2977 Enola Drive, Carlisle, Cumberland County, Pennsylvania, which property is currently held in the joint names --Page 5 of 15-- . . as tenants by the entirety. Wife agrees that contemporaneously with the execution of this Agreement, she will execute a Deed conveying all of her right, title and interest in the aforesaid real estate to Husband by fee simple general warranty deed. Wife shall then make no claim of any nature whatsoever relative to any legal or equitable interest in the aforesaid real estate. From the date of execution and delivery of the Deed forward, Husband shall be solely and exclusively responsible for the payment of the taxes, insurance and maintenance associated with the aforesaid property and shall make each such payment due hereunder when and as payments are due, including any and all interest, late charges, and the like. Husband shaH indemnify Wife and hold her hannless from and against any and demands for payment or collection activity of any nature whatsoever on account of the aforesaid payments from the date of signing and delivery of the aforesaid Deed forward. The receipt of benefits provided for herein by Wife take into consideration Wife's transfer of her legal and equitable interest in the aforesaid real estate. From the date of execution of this Agreement forward, Wife shaH make no claim of any nature whatsoever, legal or equitable, in the interest in the aforesaid real estate. 3.7 Pension. Retirement. Profit-Sharinf!. Wife agrees to waive, relinquish or transfer any and all of her right, title and interest she has or may have in Husband's pension or retirement account with Pepsico, Inc. through his employment with Quaker Oats. Wife hereby waives, relinquishes and transfers any and all right, title and interest she has in this retirement account, as well as any other accounts that Husband may have in his individual name or may have secured through his present or prior employment. The parties previously signed a Stipulation and Agreement dated September 18, 2004, regarding Wife's release of interest in Husband's pension account, which is attached hereto and incorporated herein by reference as Exhibit "A." --Page 6 of 15-- . . Husband agrees to waive, relinquish or transfer any and all of his right, title and interest he has or may have in Wife's pension, retirement, deferred compensation account with Pennsylvania State Employees Retirement System and the like through her employment with Pennsylvania State Library. Husband hereby waives, relinquishes and transfers any and all right, title and interest he has in any present retirement account, as well as other accounts that Wife may have in her individual name or may have secured through her present or prior employment. 3.8 Vehicles. The parties acknowledge that at the time of separation Wife retained sole and exclusive ownership and possession of a certain 1998 Chevrolet Blazer Sport Utility vehicle which was originally titled in the parties' names jointly. Husband executed the title of the vehicle to Wife's name individually. Husband shall make no claim whatsoever relative to access to or use of the aforesaid vehicle and shall make no ownership claims of any nature whatsoever to the aforesaid vehicle from the date of execution of this Agreement forward. The parties acknowledge that at the time of separation Husband retained sole and exclusive ownership and possession of the parties' 1998 Chevrolet 1500 Longbed Pickup truck, which was originally titled in the parties name jointly. Wife executed the title to the vehicle to Husband's name individually. Wife shall make no claim whatsoever relative to access to or use of the aforesaid vehicle and shall make no ownership claims of any nature whatsoever to the aforesaid vehicle from the date of execution of this Agreement forward. 3.9 Intamlible Personal ProDertv. At the time of separation, Wife retained possession of the funds held in the Members First Credit Union account listed in her name individually, with an approximate date of separation balance of THREE THOUSAND SEVENTY-SEVEN AND 23/100 ($3,077.23) DOLLARS. Husband waives all interest he may have had to these funds. --Page 7 of 15-- . . At the time of separation, Husband retained possession of the funds held in the Members First Credit Union account listed in his name individually, with an approximate date of separation balance of SIX THOUSAND NINE HUNDRED THIRTY-FIVE AND 44/100 ($6,935.44) DOLLARS. Wife waives all interest she may have had to these funds. Husband owns or has an interest in an IRA CD held at First Union bank with an approximate maturity value of ONE HUNDRED THIRTY-FIVE THOUSAND THREE HUNDRED FIFTY-FOUR AND 44/100 ($135,354.44) DOLLARS. Husband shall transfer his interest in this CD to Wife's name individually within fifteen (15) days of being requested to do so by Wife or Wife's legal counsel. Husband shall waive any interest he may have in this CD and shall make no claim whatsoever to the funds from the date of execution of this Agreement forward. The parties are the joint owners of savings bonds with an approximate date of separation value of FIVE THOUSAND SIX HUNDRED THIRTY-FOUR AND 66/100 ($5,634.66) DOLLARS. Husband shall sign whatever documents necessary to transfer his interest in these bonds to Wife's name individually within fifteen days of being requested to do so by Wife or Wife's legal counsel. Husband shall waive all interest he may have in these bonds and shall make no claim whatsoever to these bonds from the date of execution of this Agreement forward. In the event other joint accounts still exist between the parties, each party agrees to sign any documents necessary to close any joint accounts within fifteen (15) days of signing this Agreement. Neither party shall make any claim of any nature whatsoever against the other party relative to the financial accounts or other investments or intangible personal property that have already been retained by that party as described herein. --Page 8 of 15-- . . ARTICLE IV DEBTS OF THE PARTIES 4.1 Each party represents to the other that except as is otherwise set forth in this Agreement, there are no major outstanding obligations of the parties; that since the separation neither party has contracted for any debts for which the other will be responsible and each party indemnifies and holds hannless the other for all obligations separately incurred or assumed under this Agreement. ARTICLE VI ALIMONY. ALIMONY PENDENTE LITE. COUNSEL FEES. COSTS & EXPENSES 5.1 The parties have each secured and maintained a substantial and adequate fund from which to provide themselves sufficient resources to provide for their own comfort, maintenance and support in the station of life to which they were accustomed. Husband and Wife do hereby waive, release and give up any rights they may have, respectively against the other, for alimony, support or maintenance. 5.2 Husband and Wife specifically waive, release and give up any rights for alimony, alimony pendente lite and spousal support pursuant to Chapter 37 of the Domestic Relations Code. ARTICLE V MISCELLANEOUS PROVISIONS 6.1 Advice of Counsel. The parties acknowledge that they have either received independent legal advice from counsel of their own selection, that they fully understand the facts and have --Page 9 of 15-- . . been fully informed as to their legal rights an obligation or otherwise understand those legal rights and obligations. They acknowledge and accept that this Agreement is, in the circumstances, fair and equitable, that it is being entered into freely and voluntarily, after having received such advice and with such knowledge that execution of this Agreement is not the result of any duress or undue influence, and further that it is not the result of any collusion or improper or illegal agreement or agreements. 6.2 Mutual Release. Husband and Wife each do hereby mutually remise, release, quitclaim, and forever discharge the other and the estate of such other, for all times to come and for all purposes whatsoever, of and from any and all right, title and interest, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against such other, the estate of such other, or any part thereof, whether arising out of any former acts, contracts, engagements, or liabilities of such other as by way of dower or curtesy, or claims in the nature of dower or curtesy or widow's or widower's rights, family exemption, or similar allowance, or under the intestate laws, or the right to take against the spouse's Will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania, (b) any state, commonwealth or territory of the United States, or (c) any other country, or any rights which either party may have or at any time hereafter have for past, present, or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof. It is the --Page 10 of 15-- . . intention of Husband and Wife to give to each other by execution of this Agreement a full, complete, and general release with respect to any and all property of any kind or nature, real or personal, not mixed, which the other now owns or may hereafter acquire, except and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof. 6.3 BankruDtcv. The parties agree that any and all financial obligations assumed herein shall not be subject to discharge through bankruptcy proceedings. This includes, but is not limited to, all financial obligations assumed under this Agreement. In the event either party attempts to avoid financial obligations described herein through bankruptcy proceedings the other party shall have an independent claim against the party claiming bankruptcy for any and all sums that the other party assumes or is required to pay due to the actions of the party claiming bankruptcy. ( Further, all rights available to the other party provided for in Paragraph 6.13 hereinafter shall be available to the party not filing bankruptcy. 6.4 Warranties. Each party represents that they have not heretofore incurred or contracted for any debt or liability or obligation for which the estate of the other party may be responsible or liable, except as may be provided for in this Agreement. Each party agrees to indemnifY or hold the other party harmless from and against any and all such debts, liabilities or obligations of every kind, including those for necessities, except for the obligations arising out of this Agreement. Husband and Wife each warrant, covenant, represent and agree that each will, now and at all times hereafter, save harmless and keep the other indemnified from all debts, charges, and liabilities incurred by the other after the execution date of this Agreement, except as is ..page II of 15-- . . otherwise specifically provided for by the terms of this Agreement and that neither of them hereafter incur any liability whatsoever for which the estate of the other may be liable. 6.5 No waiver or modification of any of the terms of this Agreement shaIl 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. 6.6 Husband and Wife 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 implementation of this Agreement, and as their respective counsel shall mutually agree should be so executed in order to carry fuIly and effectively the terms of this Agreement. 6.7 This Agreement shaIl be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date of the execution of this Agreement. 6.8 This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 6.9 This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. --Page 12 ofl5-- '. . . 6.10 Severabilitv. If any term, condition, clause, section, or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement, and in all other respects, this Agreement shall be valid and continue in full force, effect, and operation. Likewise, the failure of any party to meet his or her obligation under anyone or more of the articles and sections herein shall in no way void or alter the remaining obligations of the parties. 6.11 It is specifically understood and agreed that this Agreement constitutes the equitable distribution of property, both real and personal, which was legally and beneficially acquired by Husband and Wife, or either of them, during the marriage as contemplated by the Divorce Code of the Commonwealth of Pennsylvania. 6.12 Disclosure. The parties each warrant and represent to the other that he or she has made a full and complete disclosure to the other of all assets of any nature whatsoever in which party has an interest, of the sources, and amount of the income of such party of every type whatsoever, and all other facts relating to the subject matter of this Agreement. 6.13 Enforceabilitv and Consideration. This Agreement shall survive any action for divorce and decree of divorce and shall forever be binding and conclusive on the parties; and any independent action may be brought, either at law or in equity, to enforce the terms of the Agreement by either Husband or Wife until it shall have been fully satisfied and performed. The consideration for this contract and agreement is the mutual benefits to be obtained by both of the parties hereto and the covenants and agreements of each of the parties to the other. The --Page 13 of 15-- . . adequacy of the consideration for all agreements herein contained is stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound hereby. In the event either party breaches the aforesaid Agreement and it is determined through appropriate legal action that the alleged party has so breached the Agreement, the breaching party shall be responsible for any and all attorney's fees as well as costs and expenses associated with litigation incurred by the non-breaching party to enforce this Agreement against the breaching party. In the event of breach, the non-breaching party shall have the right, at his or her election, to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her including equitable enforcement of this Agreement. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. WITNESSED BY: ~o ff~Jr~~ 3/3{)lo~ Date ;J' ()/~ /1- LINDA A. ROHM /dd77 , '7 Jll klr6 ~V<. ( .,LJ;4" H..^-- CJ hi 9"~- ~Lod Date Wi lAM A. ROHM --Page 14 of 15-- .,' . . . COMMONWEALTH OF PENNSYLVANIA COUNTYOF~!J-- Onthi~dayof ~~ , 2005, before me, the undersigned officer, personally appeared LINDA A. ROHM, known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. (~~~ . COMMOt~\\ LAL';', ,j; ~~;~'~~.:.;::. 1 i,\.'i\J-.Jli\ NOlanal Seai Rhonda D. Rudy, Notary Public Carlisle Boro, Cumberland County My Commission E:,.\"~i(es Aug, \2,2006 Member De!\ns,..j',S"1;'- \-"",,:,:-~r;t'n of Nol~ries COMMONWEALTH OF PENNSYLVANIA COUNTY OF ~ll",b.J.C\~ On this 9 .1Jt. day of H MiA Cl~ ' 2005, before me, the undersigned officer, personally appeared WILLIAM A. ROHM, known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~RII\l SEAL Rotlll J. GOSHORN, ~~~~~~~~1Y Mcrc~~~I:Oro~'&~~ES APRIL 17 2007 --Page 15 of 15-- ("-1,,\ _. .,c,<1). ,'i." ',t "'i tJ;..> , I\." \..J " .~-:\ j,_.. .,) --- ~.-..'" ...-..- -......... \.j {. --".. ;" ,<:'\ ,II: n (- ,> ~-:, .....:) <;:5' :.'~ C' --(\ ,-- < ;--.\ --- r-' r.....) -).; ." c" '- LINDA A. ROHM, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW WILLIAM A. ROHM, Defendant' : NO. 2002-649 CIVIL TERM : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the court for entry of a divorce decree: I. Ground for divorce: Irretrievable breakdown under S330 I (c) 3301(d)(I) of tile Divoree Cese. (Strike out inapplicable section). 2. Date and manner of service of the Complaint: certified mail/restricted delivery on February 20, 2002. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by 93301 (c) of the Divorce Code: by Plaintiff: March 30, 2005 by Defendant: February 9, 2005 (b) (I) Date of execution of the affidavit required by S3301 (d) of the Divorce Code: (2) Date offiling and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: none 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file Praecipe to Transmit record, a copy of which is attached: (b) Date of plaintiff's Waiver of Notice in S3301 (c) Divorce was filed with the Prothonotary: April 18, 2005 Date defendant's Waiver of Notice III S3301 (c) Divorce was filed with the Prothonotary: February II, 2005 AOJ...<t (Q~ 1Vl,,--l7Y1 MaryiOuMatas, Esquire GRIFFIE & ASSOCIATES Attorney for Defendant r'0 cr"; ()", ,........:1 c:~:> <~:.) i_~"'l () -;-) -no,':; (',) T .~ LINDA A. ROHM, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 02 - 649 CIVIL WILLIAM A. ROHM, Defendant IN DIVORCE ORDER OF COURT AND NOW, this 7),/0 day of 2005, the economic claims raised in the proceedin been resolved in accordance with a separation and property settlement agreement dated March 30, 2005, the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. BY THE COURT, cc: ~ra W. Haggerty Attorney for Plaintiff vtGlarylou Matas Attorney for Defendant ~,o':J 6-0 o ;"li,,:rr!r 't'[{) ,..f'" t" .:.1 :(\\ \}\j ~ 11" t ,\',' o-QL )"' I q,' ~\\' " ".,....IJ _....., -,'-,,} ~~~~~~~~~~~~~~~~~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . + + . . . . . . . . . + . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ++ + ~ + ~ + ~ + ~~~~~~~~~+~++~~~~~~~~~~~++~+~~~+~+~~++~+~~~~~~++~+~~+~++++~~ . . . . . . . . . . . . . . + . . . . . . . + . + + + . . + . + . + + + + . . . + . + . + . . + + . . + . + . . . . . . + . + . . + . + + + . . . . + . + + . + + + + . . + + + + + . + + . + + + + + + . + + +~+~~+~~~+~~++~++++++++++~++~+++++++++~++++++++++++++~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY LINDA A. ROHM, PENNA. STATE OF Plaintiff No. 2002-649 CIVIL TERM VERSUS WILLIAM A ROHM, Defendant DECREE IN DIVORCE ,. J -i. /61./11 )- o()S , IT IS ORDERED AND AND NOW. m~f? Linda A. Rohm , PLAINTIFF, DECREED THAT William A. Rohm , DEFENDANT, AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; The parties' Separation and Property Settlement Agreement dated March 30, 2005, is AT"5" ~~~~ ~ . PROTHONOTARY J. nr"1I WV 7J rw ryM yO J7/ . Y ~ r #/1'tfT'"' i,;,;;;%I .S<l?" h ~ .. ,,' 11. ~... ,"