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Home My WebLink About04-5363IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARBARA E. LONG, Plaintiff NO.4n5LI -531.3 ?-1 Ut.1'Yl V. RAHMAN N. LONG, 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 ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Svc. Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6200 CIVIL ACTION - LAW DIVORCE AVISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HAD SIDO DEMANDADO EN LA CORTA. Si desea defenderse de las quejas expuestas en [as paginas siguientes, debe tomar accion con prontitud. Se le avisa que si no se defiende, el caso puede proceder sin usted y decreto de divorcio o anulamiento puede ser emitido en su contra por la Corte. Una Decision puedda tambien ser emitida en su contra por cualquier otra queja o compensacion reclamados por el demandante. Usted puede perder dinero, o propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidadas o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de conjeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Courthouse, Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO 0 ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVER ESTA PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE 0 NO PUEDE PAGAR IN ABOGADO, VAYA 0 LLAME A LA OFFICINO INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Lawyer Referral Svc. Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6200 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARBARA E. LONG, Plaintiff V. RAHMAN N. LONG, Defendant NO. Oq - S'JQ CIVIL ACTION- LAW DIVORCE COMPLAINT Plaintiff, Barbara E. Long by her attorney, Diane G. Radcliff, Esquire, files this Complaint in Divorce of which the following is a statement: COUNTI DIVORCE 1. 2. 3. 4. 5. 6. 7. The Plaintiff is Barbara E. Long, an adult individual who resides at 1221 Brick Street, New Cumberland, Cumberland County, PA 17070. The Defendant is Rahman N. Long, an adult individual residing at 107 Doreen Drive, Hummelstown, Dauphin County, Pennsylvania since 2002. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months previous to the filing of this Complaint. Plaintiff and Defendant were married on July 8, 1995 at Cleveland, Ohio. There have been no prior actions of divorce or annulment between the parties. 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. Defendant is not a member of the Armed Services of the United States or any of its Allies. -2- 8. Plaintiff avers that the grounds on which the action is based are: a. Section 3301(c) Mutual Consent No-Fault: The marriage is irretrievably broken; b. Section 3301(d) Non-Consent No-Fault: The marriage is irretrievably broken and the parties are now living separate and apart. Once the parties have lived separate and apart for a period of two years, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. C. Section 3301(a)(6) Indignities: Defendant has offered such indignities to the person of the Plaintiff, the innocent and injured spouse, as to render [his/her] condition intolerable and life burdensome, and that this action is not collusive. d. Section 3301(a)(2) Adultery: Defendant has committed adultery. 9. Plaintiff requests the Court to enter a decree of divorce. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. COUNT II EQUITABLE DISTRIBUTION 10. Paragraphs 1 through 9 are incorporated by reference hereto as fully as though the same were set forth at length. 11. Plaintiff and Defendant have acquired property, both real and personal, and incurred debts during their marriage during the period from July 8, 1995, the date of their marriage, until the date of their separation, all of which are "marital property" or "marital debts". 11. Plaintiff and/or Defendant have acquired, prior to the marriage or subsequent thereto, "non-marital property" which has increased in value since the date of marriage and/or subsequent to its acquisition during the marriage, which increase in value is "marital property". -3- 13. Plaintiff and Defendant have been unable to agree as to an equitable division of the marital property and marital debts as of the date of the filing of this Complaint. WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital property and debts of the parties. COUNT 111 ALIMONY PENDENTE LITE, ALIMONY 14. Paragraphs 1 through 9 are incorporated by reference hereto as fully as though the same were set forth at length. 15. Plaintiff lacks sufficient property to provide for her reasonable needs and is unable to support herself through appropriate employment. 16. Plaintiff requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. WHEREFORE, Plaintiff requests this Honorable Court to enter an award of alimony pendente lite until final hearing and hereafter enter an award of alimony permanently thereafter. COUNT IV COUNSEL FEES, COSTS AND EXPENSES 17. Paragraphs 1 through 9 are incorporated by reference hereto as fully as though the same were set forth at length. 18. Plaintiff has employed legal counsel in this case, but is unable to pay the necessary and reasonable attorney's fees for said counsel. 19. Plaintiff has or will incur costs in this action including, but not limited to, costs for various experts to appraise the parties' marital assets, and does not have the funds to pay the necessary and reasonable fees , costs and expenses. WHEREFORE, Plaintiff requests this Honorable Court to enter an award of interim counsel fees, costs and expenses and to order such additional sums hereafter as may be -4- deemed necessary and appropriate and at final hearing to further award such additional counsel fees, costs and expenses as are deemed necessary and appropriate. Respectfully submitted, DID . RADCLIFF, S?UIRE 3448 Trin le Road Camp HiU, PA 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 Attorney for Plaintiff -5- VERIFICATION Barbara E. Long verifies that the statements made in this Complaint are true and correct. Barbara E. Long understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Barbara E. Long Date: /0 - 070 -© c/ -6- n ? -?s, „? `T ? ? ? ?,,, o o O ? c ? ?o?? ?? ?? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARBARA E. LONG, Plaintiff NO. 04-5363 V. CIVIL ACTION - LAW RAHMAN N. LONG, DIVORCE Defendant ACCEPTANCE OF SERVICE I, the undersigned attorney for the Defendant in the above captioned action, being duly authorized by said Defendant, hereby accept service of the Complaint filed in the above captioned matter on October 25, 2004. Date: 1111E IX Charles E. Petrie, Esquire Attorney for the Defendant -1- Q ° C? C.^ c .3 S • t t '? C CD IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARBARA E. LONG, Plaintiff NO. 04-5363 V. RAHMAN N. LONG, Defendant CIVIL ACTION - LAW DIVORCE PETITION FOR ORDER FOR ALIMONY PENDENTE LITE TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW, this 24TH day of January , 2005, comes the Petitioner, Barbara E. Long, who files the this Petition for Alimony Pendent Lite and respectfully represents that: 1. Petitioner, Barbara E. Long, is an adult individual residing at 1221-A Bridge Street, New Cumberland, Cumberland County, PA 17070, and is the Plaintiff in the above-captioned divorce action. 2. Respondent, Rahman N. Long, is an adult individual residing at 107 Doreen Drive, Hummelstown, Dauphin County, PA 17036, and is the Defendant in the above- captioned divorce action. 3. Petitioner and Respondent were married on July 8, 1995, at Cleveland, Ohio and separated on October 23, 2004. 4. Respondent has not sufficiently provided support for the Petitioner. 5. Petitioner is not on a financial par with Respondent in prosecuting and/or defending this Divorce Action, and is unable to support herself in accordance with the standard of living established during the marriage. 6. The within action was instituted by the filing of a Divorce Complaint by Plaintiff, Barbara E. Long, on October 25, 2004. 7. In the Divorce Complaint filed on October 25, 2004, Petitioner raised a claim for alimony pendente lite. - 1 - 8. This Petition is filed to secure the entry of an order for alimony pendente lite on the Plaintiff's claim for alimony pendente lite. 9. A background information sheet pertaining to this claim for alimony pendente lite is being filed with Domestic Relations concurrently herewith as required by Local Rules of Court. 10. The amount of alimony pendente lite requested by the Petitioner/Plaintiff is the maximum amount provided for under the guidelines. 11. A companion claim for spousal support is pending in the support action docketed to Cumberland County NO. 01052 S 2004, PACKS NO. 250106938, in which action Respondent denied petitioner's entitlement to spousal support on the basis that she left the marital home without justification. The issue of entitlement will need to be decided by the Support Master, the Petitioner wants an order for spousal support and on if entitlement is denied is she requesting an order for alimony pendente lite. WHEREFORE, Petitioner prays that the Court enter an Order: A. Requiring the Respondent to pay the Petitioner Alimony Pendente Lite in the maximum amount provided for by law under the state support guidelines; B. Requiring the Respondent to provide medical insurance and support for the Petitioner. Rcrnort4. ?I L. c??L.mirr.,a I' - z - Camp Hill, PA 17011 Supreme Court ID # 32112 Phone: (717) 737-0100 Attorney for Petitioner VERIFICATION I verify that the statements made in this Petition for Alimony Pendent Lite are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsification to authorities. 3 BARBARA E. LONG DATE: January S I , 2005 - 3 - N ((?f?? ?.? 47 CJl ,' `• r'? -'' - r-: = v;i :+> ?;nt v -? ? ,l' G" I - ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 01/27/05 Case Number (See Addendum for case summary) Employer/Withholder's Federal EIN Number SINGLE SOURCE TRANSPORTATION PO BOX 855 DES MOINES IA 50304-0855 RE: LONG. RAHMAN N. ,?+?s 683/D7d&'U O Original Order/Notice O Amended Order/Notice O Terminate Order/Notice Employee/Obligor's Name (Last, First, MI) 292-70-8311 Employee/Obligor's Social Security Number 1236100962 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, MI) See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 678.00 per month in current support $ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes ® no $ 0.00 per month in current and past-due medical support $ o . 00 per month for genetic test costs $ per month in other (specify) for a total of $ 678, 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: $ 156.46 per weekly pay period. $ 312.92 per biweekly pay period (every two weeks). $ 339. oo per semimonthly pay period (twice a month). $ 678. oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. , Date of Order: JAN 2 " 2005 BY THE COURT; Service Type M Form EN-028 OMB NO.: 0970-0154 WOrker)D $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If hecke? you are required to provide a Copy of this form to your employee. If your employee works in a state that is different from the state that issued this order, a copy must be provided to your employee even if the box is not checked. 1. 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. paydatefda Dgee`sw .. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 7307219920 EMPLOYEE'S/OBLIGOR'S NAME: LONG. RAHMAN N. EMPLOYEE'S CASE IDENTIFIER: 1236100962 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Antidiscrimination: You are subject to a fine determined under State law for discharging an employeelobligor from employment, refusing to employ, or taking disciplinary action against any employee%obligof because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 1 ].Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your ernployee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us Service Type M Page 2 of 2 OMB No.: 0970-0154 Form EN-028 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: LONG, RAHMAN N. PACSES Case Number 083107080 Plaintiff Name BARBARA E. LONG Docket Attachment Amount 04-5363 CIVIL$ 678.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(en) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll thechild(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACKS Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ?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. ? 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. ? If checked, you are required to enroll the child(ren) ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available identified above in any health insurance coverage available through the employee's/obligor's employment. through the employee's/obligor's employment. Addendum Form EN-028 Service Type M Worker ID $IATT OMB NO, 0910-0154 L T5 -? _ r BARBARA E. LONG, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 04-5363 CIVIL TERM RAHMAN N. LONG, IN DIVORCE Defendant(B espondent PACSES# 083107080 ORDER OF COURT AND NOW, this 27`h day of January, 2005, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $2,049.86 and Respondent's monthly net income/earning capacity is $3,792.02, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $678.00 per month payable bi-weekly as follows; $312.92 for alimony pendente lite and $0.00 on arrears. First payment due next pay date at 312.92 bi-weekly. Arrears set at $678.00 as of January 27, 2005. The effective date of the order is January 24, 2005. Husband is to maintain medical insurance coverage on wife, including dental and vision coverage. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C. S.§ 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the PA SCDU to: Barbara E, Long. Payments must be made by check or money order. All checks and money orders must be made payable to PA SCDU and mailed to: PA SCDU P.O. Box 69110 Harrisburg, PA 17106-9110 Payments must include the defendant's PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. Unreimbursed medical expenses that exceed $250.00 annually are to be paid 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 (30) days after the entry of this Order, the Respondnet shall submit to Petitioner written proof that medical insurance coverage has been obtained or that application for coverage has been made. Proof of coverage shall consist, at minimum, of. 1) the name of the health care coverage provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims should be made; 5) a description of any restrictions on usage, such as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms. This Order shall become final ten days after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary for a hearing de novo before the Court. DRO: R. J. Shadday Mailed copies on 1-28-05: < Petitioner Respondent Diane Radcliff, Esquire Charles Petrie, Esquire BY THE COURT Edward E. Guido J. r? C, ?:u -c; i?"^ i11 -:.: .jt"1t ail ..'1?) Y ?. ?:_ _? .. 1 `! c 1'O -1 ' '? I In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION BARBARA E. LONG ) Docker, Number 04-5363 CIVIL Plaintiff ) VS. ) PACSI'',S Case Number 083107080 RAHMAN N. LANG ) Defendant ) Other State ID Number ORDER OF COURT You, BARBARA EVA LONG plaintiff/defendant of 1221 A BRIDGE ST, NEW CUMBERLAND, PA. 17070-1637-21 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the MARCH 16, 2005 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. information relating to professional licenses 6. other: Form CM-509 Service Type M Worker ID 21302 LONG V. LONG PACSES Case Number: 083107080 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 parry initiated the support action. BY THE COURT: Date of Order: 01-3 I-05 JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND 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 of 2 Form CM-509 Service Type M Worker ID 21302 ?...> r ._i? { i ?? r 1,.? 7 . ' ? .: i'l - ? • i<j ?] N ,.? _ . is _ i i , .. ?.? . ?. j_ CJ t C In the Court of Common Pleas of CUNMERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION BARBARA E. LONG ) Docket Number 04-5363 CIVIL Plaintiff ) VS. ) PACS]'sS Case Number 083107080 RAHMAN N. LONG ) Defendant ) Other :hate ID Number ORDER OF COURT You, RAHMAN N. LONG plaintiff/defendant of 107 DOREEN DR, HUMMELSTOWN, PA. 17036-2725-07 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the MARCH 16, 2005 at 9 : o oAM 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, information relating to professional licenses 6. other: Form CM-509 Service Type M Worker ID 21302 LONG V. LONG PACSES Case Number: 083107080 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 parry based upon the evidence presented without regard to which parry initiated the support action. BY THE COURT: C Date of Order: "~ 1 7- JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED '.FEE OR NO FEE. CUMBERLAND 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 of 2 Form CM-509 Service Type M Worker ID 21302 n> t^ i; ] c r+ tI 1 1 _.. t c 1 M1 ci IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION BARBARA E. LONG, Plaintiff /Petitioner NO.04-5363 CIVIL TERM V. RAHMAN N. LONG, . IN DIVORCE Defendant/Respondent APPEAL OF RECOMMENDED SUPPORT ORDER AND REQUEST FOR HEARING DE NOVO 1. DATE OF ORDER: January 27, 2005 2. AMOUNT OF ORDER: $678.00 per month allocated $678 for spouse. 3. SUPPORT FOR: Spouse. 4. LAST DAY OF APPEAL PERIOD: February 7, 2005. 5. PERSON FILING APPEAL: Plaintiff, Barbara E. Long. 6. REASONS FOR APPEAL: The Plaintiff also filed a spousal support action docketed to Cumberland County No. 04-5363, PACSES No. 88317080, and desires that the Order be entered in that action instead of on her APL claim; provided however, that if such spousal support claim is denied on the entitlement issue Plaintiff then requests the entry of an APL order. DATE: ) /"? CLIFF, QUIRE 34 rm e Road Camp Hill, PA 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 Attorney for Plaintiff r" ?.., c e - ? I 1 " ° -1 ? 1 ^1' _?? [?• ?_! ? ? ??-1 .. -. C t , ", ?;? C,J 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION BARBARA E. LONG, Plaintiff /Petitioner NO.04-5363 CIVIL TERM V. RAHMAN N. LONG, IN DIVORCE Defendant/Respondent ^>, APPEAL OF RECOMMENDED SUPPORT ORDER AND REQUEST FOR HEARING DE NOVO 4.7 ?1. DATE OF ORDER: January 27, 2005 2. AMOUNT OF ORDER: $678.00 per month allocated $678 for spouse. 3. SUPPORT FOR: Spouse. 4. LAST DAY OF APPEAL PERIOD: February 7, 2005. 5. PERSON FILING APPEAL: Plaintiff, Barbara E. Long. 6. REASONS FOR APPEAL: The Plaintiff also filed a spousal support action docketed to Cumberland County No. 04-5363, PACKS No. 88317080, and desires that the Order be entered in that action instead of on her APL claim; provided however, that if such spousal support claim is denied on the entitlement issue Plaintiff then requests the entry of an APL order. t DATE: A CNFF, QUIRE 3 rin e Road Camp Hill, PA 170'11 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARBARA E. LONG, VS. RAHMAN N. LONG, NO. 04-5363 CIVIL TERM Plaintiff CIVIL ACTION - LAW Defendant IN DIVORCE INCOME AND EXPENSE STATEMENT OF BARBARA E. LONG I verify that the facts set forth in the following Income and Expenses Form, including all attachments thereto, are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. DATE: L14 lol-) --? BARBARA E. LONG - 1 - PART I. INCOME A. EMPLOYMENT INFORMATION: Employer: Genco Distribution Systems Address: 100 Papercraft Park, Pittsburgh, PA 15238 Position: 2nd shift supervisor @ 801 Spangler Road, Camp Hill, PA Payroll #: MW$ 101061 351315 Pay Period: Biweekly B. INCOME: DESCRIPTION BIWEEKLY MONTHLY YEARLY Gross Income $1,211.38 $2,624.66 $31,495.88 FICA ($75.11) ($162.74) ($1,952.86) Medicare ($17.57) ($38.07) ($456.82) Federal Tax ($97.70) ($211.68) ($2,540.20) State Tax ($,37.19) ($80.58) ($966.94) Local Tax ($12.11) ($26.24) ($314.86) ($1.09) ($2.36) ($28.34) $0.00 $0.00 SUBTOTAL $970.61 $2,102.99 $25,235.86 401K Loan ($37.99) ($82.31) ($987.74) 401K ($60.57) ($131.24) ($1,574.82) NET INCOME $872.05 $1,889.44 $22,673.30 2- C. CALCULATION OF INCOME BASED ON LAST PAY STUB FOR 2004 (12/23/04): DESCRIPTION YEARLY MONTHLY BIWEEKLY Gross Income 31,495.80 2,624.65 1,211.38 FICA (1,952.74) (162.73) (75.11) Medicare (456.69) (38.06) (17.57) Federal (2,540.25) (211.69) (97.70) State (966.91) (80.58) (37.19) Local (314.94) (26.25) (12.11) PA SU11SDI Tax (28.35) (2.36) (1.09) SUBTOTAL 25,235.92 2,102.99 970.61 401K Loan (151.96) (12.66) (5.84) 401K (1,574.77) (131.23) (60.57) Occupation Tax (10.00) (0.83) (0.38) TOTAL NET INCOME 23,499.19 1,958.27 903.82 Note: 401K loan is not for full year. 3- E. OTHER INCOME: DESCRIPTION WEEKLY MONTHLY YEARLY Interest $0.00 $0.00 $0.00 Dividends $0.00 $0.00 $0.00 Pensions $0.00 $0.00 $0.00 Annuities $0.00 $0.00 $0.00 Social Security $0.00 $0.00 $0.00 Rents $0.00 $0.00 $0.00 Royalties $0.00 $0.00 $0.00 Expense Account $0.00 $0.00 $0.00 Gifts $0.00 $0.00 $0.00 Unemployment Compensation $0.00 $0.00 $0.00 Workman's Compensation $0.00 $0.00 $0.00 Income Tax Refunds $0.00 $0.00 $0.00 Support or Alimony $0.00 $0.00 $0.00 Commissions $0.00 $0.00 $0.00 Tips $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 TOTAL OTHER INCOME $0.00 $0.00 $0.00 4- PART II. EXPENSES DESCRIPTION MONTHLY AMOUNT COMMENTS HOME EXPENSES: Rent $565.00 First Mortgage Second Mortgage/Home Equity Loan Maintenance and Repairs Electric $75.00 Estimate Gas Oil Telephone $53.00 (Based on1 month) Water Sewer Trash EMPLOYMENT Public Transportation Lunches $108.00 Other Employment Expenses TAXES: Real Estate Taxes Personal Property Taxes Income Taxes Not Withheld TBD There are outstanding taxes owed to IRS on joint 2000 tax return. Per Capita/ Occupation Taxes 5- DESCRIPTION MONTHLY AMOUNT COMMENTS INSURANCE: Homeowners Insurance Automobile Insurance $84.62 Life Insurance Accident Insurance Health Insurance $38.33 (currently is military; employer's will be $74, plus a deductible) Otherlnsurance AUTOMOBILE EXPENSES: Payments $206.88 Fuel $130.00 Maintenance and Repair $40.00 License and Registration $4.00 MEDICAL EXPENSES NOT REIMBURSED BY INSURANCE: Doctor $20.00 Optical Dental $20.00 Orthodontic Hospital Medicine $10.00 Special Needs/Therapy Etc. - 6 - DESCRIPTION MONTHLY AMOUNT COMMENTS EDUCATIONAL EXPENSES: Private School Parochial School College/Vocational Religious Training or Education Books/Fees and Supplies Other Educational Expenses PERSONAL EXPENSES: Clothing $100.00 Food $400.00 Barber and Hair Dresser $25.00 Memberships Other Personal Expenses $20.00 CREDIT CARDS AND LOANS: Beneficial Loan $212.82 (Loan to cover joint back taxes, household furniture and child's play ground Chase Visa $75.00 401 K Loan $82.31 MISCELLANEOUS EXPENSES: Household Help Child Care Newspapers/Magazines/Books $15.00 Entertainment $100.00 7- DESCRIPTION MONTHLY AMOUNT COMMENTS EDUCATIONAL EXPENSES: Private School Parochial School College/ Vocational Religious Training or Education Books/Fees and Supplies Other Educational Expenses PERSONAL EXPENSES: Clothing $100.00 Food $400.00 Barber and Hair Dresser $25.00 Memberships Other Personal Expenses $20.00 CREDIT CARDS AND LOANS: Beneficial Loan $212.82 (Loan to cover joint back taxes, household furniture and child's play ground Chase Visa $75.00 Attorneys Fees Loan $82.31 MISCELLANEOUS EXPENSES: Household Help Child Care Newspapers/Magazines/Books $15.00 Entertainment $100.00 -7- DESCRIPTION MONTHLY AMOUNT COMMENTS Pay TV $42.31 Vacations $100.00 Gifts Legal Fees $100.00 Charitable Contributions Other Child Support Other Spousal Support or Alimony TOTAL EXPENSES $2,627.27 - 8 - PART III. PROPERTY OWNED PROPERTY OWNED OWNERSHIP TYPE DESCRIPTION VALUE H W JT Checking M Et T Bank #523326 118.00 X Savings Credit Union 50.00 X Stocks/bonds Real Estate Other 401K (as of 9/30/04) 8,283.74 X TOTAL 8,451.74 PART IV. INSURANCE INSURANCE INFORMATION COVERAGE TYPE COMPANY POLICY NO. H W C Hospital TriCarePrime 292-70-8311 X X X Medical TriCarePrime 292-70-8311 X X X Health Accident TriCarePrime 292-70-8311 X X X Disability Income Dental Vision TriCarePrime 292-70-8311 X X X Other-Specify *H=Husband; W=Wife; J=Joint; C=Child 9- PART V. SUPPLEMENTAL INCOME STATEMENT [ d ] CHECK HERE IF NOT APPLICABLE (a) This form is to be filled out by a person: (1) Who operates a business or practices a profession, or (2) Who is a member of a partnership or joint venture, or (3) Who is a shareholder in and is salaried by a closed corporation or similar entity. (b) Attach to this statement a copy of the following documents relating to the partnership, joint venture, business, profession, corporation or similar entity (check block to indicate the document is attached): (1) The most recent Federal Income Tax Return. [ ] attached (2) The most recent Profit and Loss Statement. [ ] attached (c) Name of Business: Business Address: Business Telephone: (d) Nature of Business (check one) [] 1. Sole Proprietorship [ ] 2. Partnership [ ] 3. Joint Venture [ ] 4. Professional [ ] 5. Corporation [ ] 6. Other (e) Name of accountant, controller or other person in charge of financial records: (f) Business Income: 1. Annual income from business: 2. How often is income received: 3. Gross income per pay period: 4. Net income per pay period: 5. Specify deductions, if any: CERTIFICATE OF SERVICE I, Diane G. Radcliff, Esquire, hereby certify that on served a copy of the within Income and Expense Statement, by mailing same by first class mail, postage prepaid, addressed as follows: Charles E. Petrie, Esquire 3528 Brisban Street Harrisburg, PA 17111 DIANE G. RADCLIFF, ESQUIRE 3448 Trindle Road Camp Hill, PA 17011 Supreme Court ID # 32112 Phone: (717) 737-0100 Fax: (717) 975-0697 Attorney for Plaintiff - 11 - t ,,, '! IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION BARBARA E. LONG, V. RAHMAN N. LONG, Plaintiff /Petitioner NO. 1052 S 2004 PACSES NO. 250106938 IN SUPPORT (Spousal Support) Defendant/Respondent and IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARBARA E. LONG, RAHMAN N. LONG, Plaintiff/ Petitioner V. Defendant/Respondent NO. 04-5363 CIVIL TERM PACKS NO. 083107080 IN DIVORCE (APL) STIPULATED AGREEMENT' We, Diane G. Radcliff, Esquire, attorney for Barbara E. Long, Plaintiff in the above captioned actions, and Charles E. Petrie, Esquire, attorney for Rahman N. Long, Defendant in the above captioned actions, having been duly authorized by Plaintiff and Defendant, hereby stipulate and agree as follows: 1. The appeal and request for a hearing de nova filed by Plaintiff regarding the order for alimony pendente lite entered on January 27, 2005 in the above captioned divorce proceeding docketed to No. 04-5363 Civil Term shall be withdrawn and dismissed. 2. The order for alimony pendente lite entered on January 27, 2005 in the above captioned divorce proceeding docketed to No. 04-5363 Civil Term shall be null and void and shall be replaced with an order for spousal support as hereinafter provided. 3. A support order for spousal support shall be entered in the above captioned support proceeding docketed to number 1052 S 2004, pacses No. 250106938. The terms of the spousal support order shall be identical to the terms of the matter under the same terms FEB-07-2005 16.48 DIANE RADCLIFF 717 975 0697 P.04i04 as the January 27, 2005 alimony pendente lite order. The foregoing notwithstanding, the effective date of the spousal support order shall be the date Plaintiff filed for spousal support. Domestic Relations is hereby authorized to add such amounts to the spousal support order to apply towards the payment of any arrears resulting from said effective date as Domestic Relations deems appropriate. 4. The Court is authorized to enter an order or orders to effectuate the terms of this Stipulated Agreement. DATE: 2- O D LI E UIRE A orney for B rbara ng DATE: A1710 !' cr'L L/r.? CHARLES E. PETRIE, ESQUIRE Attorney for Rahman N. Long TOTAL P.04 '"- ??; BARBARA E. LONG, IN THE COURT OF COMMON PLEAS OF PlaintifflPetitioner CUMBERLAND COUNTY, PENNSYLVANIA V DOMESTIC RELATIONS SECTION RAHMAN N. LONG, PACSES NO. 250106938 Defendant/Respondent : NO. 1052 SUPPORT 2004 BARBARA E. LONG, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. DOMESTIC RELATIONS SECTION RAHMAN N. LONG, : PACSES NO. 083107080 Defendant/Respondent NO. 04-5363 CIVIL TERM ORDER OF COURT Between counsel, a copy of which is attached hereto and made a part hereof, it is ordered and decreed as follows: A. The order entered January 7, 2005 to 04-5363 Civil Term obligating the Defendant to pay alimony pendente lite is vacated. B. In the case docketed to 1052 Support 2004 the Defendant shall pay to the Pennsylvania State Collection and Disbursement Unit for transmission to the Plaintiff as spousal support the sum of $678.00 per month. C. The Defendant shall pay to the Pennsylvania State Collection and Disbursement Unit the additional sum of $100.00 per month on arrearages until paid in full. D. The Defendant shall provide health insurance coverage, to include vision and dental coverage, for the benefit of the Plaintiff as is available to him through his employment or otherwise at a reasonable cost. E. The effective date of this order is November 18, 2004. IMPORTANT LEGAL NOTICE PARTIES MUST WITHIN SEVEN DAYS INFORM THE DOMESTIC RELATIONS SECTION AND THE OTHER PARTIES, IN WRITING, OF ANY MATERIAL CHANGE IN CIRCUMSTANCES RELEVANT TO THE LEVEL OF SUPPORT OR THE ADMINISTRATION OF THE SUPPORT ORDER, INCLUDING, BUT NOT LIMITED TO, LOSS OR CHANGE OF INCOME OR EMPLOYMENT AND CHANGE OF PERSONAL ADDRESS OR CHANGE OF ADDRESS OF ANY CHILD RECEIVING SUPPORT. A PARTY WHO WILLFULLY FAILS TO REPORT A MATERIAL CHANGE IN CIRCUMSTANCES MAY BE ADJUDGED IN CONTEMPT OF COURT AND MAY BE FINED OR IMPRISONED. PENNSYLVANIA LAW PROVIDES THAT ALL SUPPORT ORDERS SHALL BE REVIEWED AT LEAST THREE (3) YEARS IF SUCH A REVIEW IS REQUESTED BY ONE OF THE PARTIES. A MANDATORY INCOME ATTACHMENT WILL ISSUE UNLESS THE DEFENDANT IS NOT IN ARREARS IN PAYMENT IN AN AMOUNT EQUAL TO OR GREATER THAN ONE MONTH'S SUPPORT OBLIGATION AND (1) THE COURT FINDS THAT THERE IS GOOD CAUSE NOT TO REQUIRE IMMEDIATE INCOME WITHHOLDING; OR (2) A WRITTEN AGREEMENT IS REACHED BETWEEN THE PARTIES WHICH PROVIDES FOR AN ALTERNATE ARRANGEMENT. DELINQUENT ARREARAGE BALANCES MAY BE REPORTED TO CREDIT AGENCIES. ON AND AFTER THE DATE IT IS DUE, EACH UNPAID SUPPORT PAYMENT SHALL CONSTITUTE A JUDGMENT AGAINST YOU. IT IS FURTHER ORDERED THAT, UPON PAYOR'S FAILURE TO COMPLY WITH THIS ORDER, PAYOR MAY BE ARRESTED AND BROUGHT BEFORE THE COURT FOR A CONTEMPT HEARING; PAYOR'S WAGES, SALARY, COMMISSION, AND/OR INCOME MAY BE ATTACHED IN ACCORDANCE WITH LAW. By th r Edward lido J. cc: Barbara E. Long Rahman N. Long Diane G. Radcliff, Esquire For the Plaintiff Charles E. Petrie, Esquire For the Defendant DRO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION BARBARA E. LONG, Plaintiff /Petitioner NO. 1052 S 2004 V. PACKS NO. 250106938 RAHMAN N. LONG, IN SUPPORT (Spousal Support) Defendant/Respondent and IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARBARA E. LONG, Plaintiff /Petitioner NO. 04-5363 CIVIL TER C • mr V. PACSES NO. 083107080 ` :moo C=) ' rn ^ tD RAHMAN N. LONG, IN DIVORCE (APL) Defendant/Respondent d STIPULATED AGREEMENT We, Diane G. Radcliff, Esquire, attorney for Barbara E. Long, Plaintiff in the above captioned actions, and Charles E. Petrie, Esquire, attorney for Rahman N. Long, Defendant in the above captioned actions, having been duly authorized by Plaintiff and Defendant, hereby stipulate and agree as follows: 1. The appeal and request for a hearing de novo filed by Plaintiff regarding the order for alimony pendente lite entered on January 27, 2005 in the above captioned divorce proceeding docketed to No. 04-5363 Civil Term shall be withdrawn and dismissed. 2. The order for alimony pendente lite entered on January 27, 2005 in the above captioned divorce proceeding docketed to No. 04-5363 Civil Term shall be null and void and shall be replaced with an order for spousal support as hereinafter provided. 3. A support order for spousal support shall be entered in the above captioned support proceeding docketed to number 1052 S 2004, pacses No. 250106938. The terms of the spousal support order shall be identical to the terms of the matter under the same terms Ftd-N'(-GNUS 1b: 4ti UfFPtt NHLILL)" rir pro UOJ( r. uv. cir as the January 27, 2005 alimony pendente lite order. The foregoing notwithstanding, the effective date of the spousal support order shall be the date Plaintiff filed for spousal support. Domestic Relations is hereby authorized to add such amounts to the spousal support order to apply towards the payment of any arrears resulting from said effective date as Domestic Relations deems appropriate. 4. The Court is authorized to enter an order or orders to effectuate the terms of this Stipulated Agreement. DATE: 2 I I O DATE: 7/O r C?404" LC? CHARLES E. PETRIE, ESQUIRE Attorney for Rahman N. Long TOTAL P.04 r BARBARA E. LONG, Plaintiff V. RAHMAN N. LONG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-5363 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE INVENTORY OF BARBARA E. LONG Plaintiff files the following inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Plaintiff verifies that the statements made in this inventory are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. BARBARA E. LONG, PLAINT Dated: ?S ESQUIRE Trindle Camp Hill, PA 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court I #32112 Dated: 3 16 \\ ASSETS AND LIABILITIES OF PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets and debts on the following pages: (X) I . Real Property and Real Estate Mortgages (X) 2. Motor Vehicles and Vehicle Liens O 3. Stocks, Bonds, Securities and Options O 4. Certificates of Deposit (X) 5. Checking Accounts, Cash O 6. Savings Accounts, Money Market and Savings Certificates O 7. Contents of Safe Deposit Boxes O 8. Trusts O 9. Life Insurance Policies O 10. Annuities O 11. Gifts O 12. Inheritances O 13. Patents, Copyrights, Inventions, Royalties O 14. Personal Property Outside the Home O 15. Business O 16. Employment Termination Benefits-Severance Pay, Worker's Compensation O 17. Profit Sharing Plans (X) 18. Pension Plans (indicate employee contribution and date plan vests) (X) 19. Retirement Plans, Individual Retirement Accounts O 20. Disability Payments O 21. Litigation Claims (matured and unmatured) O 22. MilitaryN.A. Benefits O 23. Education Benefits O 24. Debts Due, including loans, mortgages held O 25. Household Furnishings and Personalty O 26. Other Assets O 27. Loans, Credit Cards and Other Debts Page 2 I INFORMATIONAL NOTES AND CODES " vr" denotes that the entry (value) is verified by a document. 2. "*" denotes value of asset or debt. 3. " *" denotes documents/information to be supplied by a party. 4. "X" denotes an item about which a decision is required. 5. "V" denotes an items for which an appraisal or other valuation may be required. 6. "NM" preceding an entry denotes non-marital property not subject to equitable distribution. 7. "r" or "A" preceding an entry denotes an agreed upon value. 8. "-i" denotes an items of special note. 9. The values used in the various Tables herein may, in some cases, be based on estimated values. Those estimated values are subject to adjustment upon appraisal or otherwise. 10. Any adjustment figures used in the various tables herein are for illustration purposes only and are not to be deemed a representation on the part of the Plaintiff as to whether an adjustment should be made or the amount of the adjustment, if any is appropriate. Page 3 SECTION I. - BACKGROUND INFORMATION TABLE #1-A PARTIES DESCRIPTION HUSBAND WIFE Name Rahman N. Long Barbara E. Long Maiden Name N/A Barbara E. Baumann Address 107 Doreen Drive Hummelstown, PA 17036 1221-A Bridge Street New Cumberland, PA 17070 Home Phone 717-566-8674 717-774-5160 Cell Phone No. 717-421-2392 Work Phone No. Unknown 717-737-1200 E-mail Unknown N/A Date of Birth 10/23/61 05/05/60 Age 43 44 Place of Birth New York Germany Race Black Caucasian Health Status High blood pressure Awaiting results of physical Educational Background Unknown 10°i grade education Names and Relationship of Persons Living with Party None None Date Party Moved to Current Residence January 2002 10/23/04 Date PA Residency Began 1995 1995 Current Military Service Retired N/A Employer's Name and Address Ruan Transport Corp. Box 855 Des Moines, Iowa 50304 Genco Distribution System 801 Spangler Road Camp Hill, PA 17011 Occupation (Job Position) Truck Driver Operator leader Date Employment Commenced Unknown 08/10/99 Est. Annual Income $60,000.00 plus $12,000.00 Military Retirement $32,000.00 Page 4 TABLE #1-B MARRIAGE INFORMATION DESCRIPTION INFORMATION Date of Marriage July 8, 1995 Place of Marriage Cleveland, OH Date of Separation October 23, 2004 Grounds for Divorce No Fault, Indignities and Adultery Prior Divorce Actions Between Parties None Number of this Marriage for Wife 2 Number of this Marriage for Husband 2 TABLE #1-C CHILDREN OF THIS MARRIAGE NAME AGE DATE OF SCHOOL CUSTODIAN OR BIRTH GRADE EMANCIPATION NONE N/A N/A N/A N/A TABLE #1-D SUPPORT FOR THIS MARRIAGE DESCRIPTION INFORMATION Name of Party Paying Support Husband Beneficiaries of Support Wife Amount of Support TBD Allocation Wife only Agreement or Order Order Date of Agreement or Order Docket Number of Support Order Comments: Page 5 TABLE #1-E PRIOR MARRIAGES PARTY NUMBER DATE OF MANNER OF OF TERMINATION TERMINATION MARRIAGE Wife 1 1992 or 1993 Divorce Husband 1 1986 Divorce TABLE #1-F CHILDREN OF OTHER RELATIONSHIPS/MARRIAGES PARTY NAME OF CHILD DATE OF BIRTH AGE CUSTODIAN OR EMANCIPATION Husband Kevin Long Unknown 21 Emancipated Husband Natasha M. Long 3/26/02 2 Mother TABLE #1-G SUPPORT/ALIMONY FOR PRIOR MARRIAGES/RELATIONSHIP DESCRIPTION INFORMATION INFORMATION Name of Party Paying Support N/A N/A Beneficiaries of Support N/A N/A Allocation N/A N/A Agreement or Order N/A N/A Date of Agreement or Order N/A N/A Docket Number of Support Order N/A N/A Comments: N/A N/A Page 6 TABLE #1-H PROCEEDINGS INFORMATION: COMPLAINT Complaint Filing Date October 25, 2004 Date of Service November 19, 2004 Manner of Service Acceptance of Service by Defendant's Attorney Type of Divorce Requested 3301(c); 3301(d); 3301(a)(6); 3301(a)(2) Economic Claims Raised Equitable Distribution; APL; Alimony; Counsel Fees and Costs ANSWER, COUNTERCLAIM AND/OR OTHER ECONOMIC PLEADINGS Type of Pleading Pleading Filing Date Type of Divorce Requested Economic Claims Raised INCOME AND EXPENSE STATEMENTS Plaintiff's I&E Statement Filing Date Defendant's I&E Statement Filing Date INVENTORIES Plaintiff's Inventory Filing Date Defendant's Inventory Filing Date 3301 C DOCUMENTS Plaintiff's 3301(c) Affidavit Date Plaintiff's 3301(c) Affidavit Filing Date Defendant's 3301(c) Affidavit Date Defendant's 3301(c) Affidavit Filing Date Plaintiffs 3301(c) Waiver of Notice Date Plaintiffs 3301(c) Waiver Filing Date Defendant's 3301(c) Waiver of Notice Date Defendant's 3301(c) Waiver Filing Date Page 7 TABLE #1-H PROCEEDINGS INFORMATION: 3301 D DOCUMENTS Date of In House Separation N/A Date of Physical Separation 10/23/04 In House 2 Year Separation Date N/A Physical 2 Year Separation Date 10/23/06 Plaintiff's 3301(d) Affidavit Date Plaintiff's 3301(d) Affidavit Date Filing Date 3301 (D) Affidavit Service Date Manner of Service of 3301(d) Affidavit Date of Plaintiff's Notice of Intent to Request Entry of Divorce Decree and Praecipe to Transmit Record Plaintiff's Notice to Request Entry of Divorce Decree and Praecipe to Transmit Record Service Date Manner of Service of Plaintiff's Notice to Request Entry of Divorce Decree and 3301(d) Counter-Affidavit BIFURCATION Has the case been bifurcated? No Date of decree granting bifurcation N/A If bifurcation granted by consent or after hearing N/A PREVIOUSLY RESOLVED ISSUES Issue #1 Resolution Issue #2 Resolution Page 8 Barbara E. Long vs. Rahman N. Long DOM: July 8, 1995 DOS: October 23, 2004 Prepared: February 4, 2005 SECTION II. MARITAL ASSETS AND DEBTS The following Table #2 sets forth the listing of the marital assets and debts of the parties: TABLE #2 MARITAL ASSETS AND DEBTS 10123104 NO. DESCRIPTION OF DATE/ GROSS VALUE NET VALUE PROPOSED PROPOSED PROPERTY OR DEBT AGREED/ AFTERLIENS DISTRIBUTION DISTRIBUTION DISPUTE TO HUSBAND TO WIFE REAL ESTATEAND REAL ESTATE MORTGAGES RE-1 107 Doreen Drive Est. 183,000.00 //// Value Hummelstown,PA Value? /000 RE-1 Washington 10.19.04 (177,148.55) Mtg. Mutual Update V Mortgage RE-1 Net Equity 5,851.45 5,851.45 5,851.45 Net RE-1 -1 Purchased January 2002 Comments * Mortgage balance to be updated to near date of distribution. Either party to supply mortgage statement near that date. X The parties need to decide if an appraisal is required. Husband has not paid mtg. Effective 1/05. MOTOR VEHICLES AND VEHICLE LIENS VEH-1 Husband's 2004 Est. 37,811.72 37,811.72 37,811.72 Ford Expedition Value? VEH-1 Best Employee's 11.30.04 (37,811.72) (37,811.72) (37,811.72) Loan FCU loan VEH-1 Net Equity -- 0.00 Loan VEH-1 Comments * 11.3 0.04 loan balance @ $37,81 1.72 ? * monthly loan payment @ $629.39 ? -1 Purchased August/September 2004 @ loan amount * Husband to supply purchase documentation. Page 9 Barbara E. Long vs. Rahman N. Long DOM: July 8, 1995 DOS: October 23, 2004 Prepared: February 4, 2005 TABLE #2 MARITAL ASSETS AND DEBTS 10/23/04 NO. DESCRIPTION OF DATE/ GROSS VALUE NET VALUE PROPOSED PROPOSED PROPERTY OR DEBT AGREED/ AFTER LIENS DISTRIBUTION DISTRIBUTION DISPUTE TO HUSBAND TO WIFE VEH-2 Husband's 1990 Est. 1,500.00 1,500.00 1,500.00 Ford Thunderbird Value? VEH-2 * H @ $// Comments 4 This vehicle is paid off. * Husband to supply information necessary to complete NADA valuation VEH-3 Husband's 1995 Est. 2,200.00 2,200.00 2,200.00 Ford Taurus Value? VEH-3 * // @ $// Comments ->• This vehicle was secretly purchased by Husband 8.2.04 for $1,200 f -4 This vehicle is owned jointly with Brenda Wise. I * Husband to supply information necessary to complete NADA valuation VEH-4 Husband's 2003 Est. 10,000.00 10,000.00 10,000.00 Suzuki Value? VEH-5 Best Employee's 11.30.04 (9,232.24) (9,232.24) (9,232.24) Loan FCU loan VEH-4 Comments * 11.3 0.04 loan balance @ $9,232.24 d * monthly loan payment @ $194.83 d Ik Husband to supply information necessary to complete NADA valuation VEH-5 Husband's 1996 Est. 2,200.00 2,200.00 2,200.00 Ford Taurus Value? VEH-5 * // @ $// Comments -4 This vehicle was secretly purchased by Husband on 1.6.03 at auction for $1,600.001 ?h Husband to supply information necessary to complete NADA valuation VEH-6 Wife's 2001 Ford 2.2.05 5,060.00 5,060.00 5,060.00 Taurus SES VEH-6 Best Employee's 9.30.04 (10,282.99) (10,282.99) (10,282.99) Loan FCU loan #5523 VEH-6 * 2.2.05 KBB TIVG @ $5060 d Comments * 9.30.04 loan balance @ $10,282.99 1 * monthly loan payment @ $206.88 1-1 Loan Co-signed by Husband. -1 Purchased March 2004 Page 10 Barbara E. Long vs. Rahman N. Long DOM: July 8, 1995 DOS: October 23, 2004 Prepared: February 4, 2005 TABLE #2 MARITAL ASSETS AND DEBTS 10/23/04 NO. DESCRIPTION OF DATE/ GROSS VALUE NET VALUE PROPOSED PROPOSED PROPERTY OR DEBT AGREED/ AFTER LIENS DISTRIBUTION DISTRIBUTION DISPUTE TO HUSBAND TO WIFE CASH, CHECKING ACCOUNTSAND SA VINGS ACCOUNTS ACCT-1 Husband's M&T 10.26.04 234.41 234.41 234.41 #500 ACCT-1 * 10.26.04 value @ $ 234.41 Comments ACCT-2 Best Employees 11.1.04 128.14 128.14 128.14 FCU #8697 Regular Share ACCT-2 Best Employees 11.1.04 1,243.16 1,243.16 1,243.16 FCU #-8697 Draft Share ACCT-2 Total 11.1.04 1,371.30 ACCT-2 * 11. 1.04 @ $ 1,243.16 d Comments Joint account with Rita Long (???) ACCT-3 Wife's M&T 11.10.04 131.00 131.00 131.00 # 6668 ACCT-3 * 11. 10.04 @ $131.00 Comments ACCT-2 Husband's M&T 6.4.04 N/A N/A N/A #815 ACCT-2 * 6.4.04 @ $110.00 d Comments -1 This account is for Husband's child under UGMA and is non-marital RETIREMENT PLANS RET-1 Husband's Value? TBD TBD TBD Military Pension RET-1 * 12.31.03 @ $11,472.00 per year, approximately 22% of which is marital. Comments Ik Husband to supply benefits statement as of October 23, 2004 and current date and document indicating dates of service. Page 11 Barbara E. Long vs. Rahman N. Long DOM: July 8, 1995 DOS: October 23, 2004 Prepared: February 4, 2005 TABLE #2 MARITAL ASSETS AND DEBTS 10/23/04 NO. DESCRIPTION OF DATE/ GROSS VALUE NET VALUE PROPOSED PROPOSED PROPERTY Oil DEBT AGREED/ AFTER LIENS DISTRIBUTION DISTRIBUTION DISPUTE TO HUSBAND TO WIFE RET-2 Wife's Genco 9.30.04 8,283.74 8,283.74 8,283.74 401K RET-2 * 9.30.04 @ $8,283.74 d Comments Subject to $4,000.00 loan HOUSEHOLD GOODS, FURNISHINGS, TOOLS, PERSONAL EFFECTS ETC. PP-1 Husband's Value? 21,944.00 21,944.00 21,944.00 Personalty PP-1 4 If information available see Tables #3-A & 3-13 for itemization. Comments X The parties need to decide if an appraisal is required or if as is distribution is acceptable; or if an exchange of items is requested. PP-2 Wife's Personalty Value? 4,132.00 4,132.00 4,132.00 PP-2 4 If information available see Tables 43-A & 3-13 for itemization. Comments X The parties need to decide if an appraisal is required or if as is distribution is acceptable; or if an exchange of items is requested. LOANS, CREDIT CARDSAND'OTHER DEBTS DEBT-1 2000 IRS debt Value TBD TBD TBD DEBT-1 * 10. 18.04 @ $1,823.34 1 Comments -1 Wife paid $1,082.00 towards this debt on 8.9.04 -1 In 2004 IRS took Wife's 2002 refund @ $580and 2003 refund @ $490 for total of $1,070 and applied towards this debt. Not certain if above balance reflects these payments. DEBT-2 STAR #2963 10.17.04 (4,085.53) (4,085.53) (4,085.53) DEBT-2 * 10. 17.04 @ $4,085.53 d Comments DEBT-3 Value City #7389 25.04 (2,421.33) (2,421.33) (2,421.33) DEBT-3 * 1 1.25.04 @ $2,421.33 Comments DEBT-4 Sears # 0653 12.4.04 (298.80) (298.80) (298.80) DEBT-4 * 12.4.04 @ $298.80 ,f Comments * Either party to supply account statement indicating balance owed as of October 23, 2004. Page 12 Barbara E. Long vs. Rahman N. Long DOM: July 8, 1995 DOS: October 23, 2004 Prepared: February 4, 2005 TABLE #2 MARITAL ASSETS AND DEBTS 10123104 NO. DESCR PI']ON OF DATE/ GROSS VALUE NE9' VALUE PROPOST:U PROPOSED PROPERTY OR DEBT AGREED/ AFTER LIENS DISTRIBUTION DISTRIBUTION DISPUTE TO HUSBAND TO WIFE DEBT-5 Capital One 10.7.04 (1,492.38) (1,492.38) (1,492.38) #6241 DEBT-5 * 10.7.04 @ $1,492.38 J Comments DEBT-6 Citi Financial 10.12.04 (8,811.94) (8,811.94) (8,811.94) #6253 DEBT-6 * 10.04 @ $8,811 .94 Comments DEBT-7 Best Employees 11.1.04 (582.93) (582.93) (582.93) FCU #8697 - signatim loan DEBT-7 * 11. 1.04 @ $582.93 J Comments -1 Husband holds this debt account jointly with his ex-wife, Rita Long. DEBT'-8 Husband's 11. 12.04 (4,285.00) (4,285.00) (4,285.00) Best Visa #5905 DEBT-8 * 1 1.12.04 @ $4,285 d Comments DEBT-9 Beneficial #996-7 10.18.04 (12,343.56) (12,343.56) (12,343.56) DEBT-9 * 10. 18.04 @ $12,343,56 4' Comments debt taken out to pay IRS debt husband failed to pay and for dining room set and play gym for husband's daughter. Interest is @ 26% TOTALS Total of Assets and Liabilities 9,071.20 14,091.01 (5,019.81) PERCENTAGE OF DIVISION Totals from Above 9,071.20 14,091.01 (5,019.81) Percentage of Total 1.55 (0.55) Page 13 Barbara E. Long vs. Rahman N. Long DOM: July 8, 1995 DOS: October 23, 2004 Prepared: February 4, 2005 TABLE #2 MARITAL ASSETS AND DEBTS 10/23/04 NO. DESCRIPTION OF PROPERTY OR DEBT DATE/ AGREED/ DISPUTE CROSS VALUE NET VALUE AFTER LIENS PROPOSED DISTRIBUTION TO HUSBAND PROPOSED DISTRIBUTION TO WIFE ADJUSTMENT FOR 50/50 DIVISION Totals from above 9,071.20 14,091.01 (5,019.81) Amount Due in 50150 Division 4,535.60 4,535.60 Adjustment Figure for 50/50 (9,555.41) 9,555.41 Adjustment if any for 50% of Fair Rental Value 0.00 0.00 Net Adjustment for 50/50 (9,555.41) 9,555.41 ADJUSTMENT FOR 45/55 DIVISION Totals from above 9,071.20 14,091.01 (5,019.81) Amount Due in 45/55 Division 4,082.04 4,989.16 Adjustment Figure for 45/55 (10,008.97) 10,008.97 Adjustment if any for 50% of Fair Rental Value 0.00 0.00 Net Adjustment for 45/55 in Wife's Favor (10,008.97) 10,008.97 ADJUSTMENT FOR 40160 DIVISION Totals from above 9,071.20 14,091.01 (5,019.81) Amount Due in 40/60 Division 3,628.48 5,442.72 Adjustment Figure for 40/60 (10,462.53) 10,462.53 Adjustment if any for 50% of Fair Rental Value 0.00 0.00 Net Adjustment for 40/60 in Wife's Favor (10,462.53) 10,462.53 CALCULATION OF ADJUSTMENT FOR FAIR RENTAL VALUE , IF APPROPRIATE Fair Rental Value @ $///mo x // months (// to Taxes @ $// Mortgage Payments @ $///mo x // months HELOC Mortgage @ ///mo x // months Capital Improvements (// to H Net Estimated Fair Rental Value 0.00 50% of Fair Rental Value -LQD-] Page 14 SECTION III. LISTING OF HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY The following Tables #3-A and # 3-B set forth the household goods and contents and other personal property of the parties: ',' TABLE #3-A HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY IN HUSBAND'S POSSESSION NO. DESCRIPTION OWNER POSSESSOR DATE OF VALUE VALUE BASIS FOR EXCLUSION IF NON- MARITAL 1 Washer/dryer H & W Husband 1,050.00 -- Comments: Purchased in 2002 for $2,000 2 2 Refrigerators H & W Husband 1,012.00 -- Comments: 1 purchased in 2002 for approximately $1,900.00; 1 purchased in 2001 for $125 3 King size bed & headboard H & W Husband 901.00 Comments: Purchased in 2002 for $1802.00. 4 165" TV H & W Husband 1,000.00 -- Comments: Purchased in 1998 for $1,050 from brother. TV was new at the time and had a value of $3000.. 5 Large stereo set including VCR, DVD & premium speakers H & W Husband 700.00 -- Comments: Purchased prior to 2000 for $1,500 6 3 gym sets, barbells, AB Roller etc. H & W Husband 400.00 -- Comments: Purchased in 2004 for approximately $800.00. 'Note: Exclusions from marital property include property acquired before marriage, property acquired after separation, or property acquired during marriage by way of gift or inheritance from third party not a spouse. For gifts and inheritance also specify the source person. 'The value of each item has been estimated by Plaintiff unless otherwsise noted. Page 15 TABLE #3-A HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY IN HUSBAND'S POSSESSION NO. DESCRIPTION OWNER POSSESSOR DATE OF VALUE VALUE BASIS FOR EXCLUSION IF NON- MARITAL 7 Dining room, china set and 2 chairs H & W Husband 1,000.00 -- Comments: 8 Coffee table H & W Husband 25.00 -- Comments: 9 Large spider lamp H & W Husband 25.00 -- Comments: Purchased in 1998 for $100.00 10 Table lamp H & W Husband 5.00 -- Comments: Purchased in 1998 for $20.00 I 1 Outdoor porch furniture H & W Husband 450.00 Gift to Wife from Husband -- Comments: Purchased in 2004 for $900.00. 12 Twin size bed H & W- I Husband 75.00 -- Comments: Estimated original price of $150.00. 13 Dresser with mirror H & W Husband 75.00 -- Comments: Purchased in 1999 for $300.00. 14 CD collection H & W Husband 1,000.00 -- Comments: Claimed 99 CD's @ $2,000.00 in 1999. 15 Liquor collection H & W Husband 150.00 -- Comments: 6 gallons @ estimated $25/gallon. 16 Gun H & W Husband 150.00 -- Comments: Purchased in 1998 for $150; Husband used Wife's money for this purchase. 17 Kitchenware H & W Husband 65.00 -- Comments: Page 16 TABLE #3-A HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY IN HUSBAND'S POSSESSION NO. DESCRIPTION OWNER POSSESSOR DATE OF VALUE VALUE BASIS FOR EXCLUSION IF NON- MARITAL 18 TV stand H & W Husband 10.00 -- Comments: Bought used in 2000 for $25.00. 19 Child's bedroom set H & W Husband 150.00 -- Comments: 20 Inside plants on patio H & W Husband 60.00 -- Comments: 21 3 BBQ's H & W Husband 200.00 Comments: Husband gave 1 of the 3 BBQ to his mistress which is now at her apartment. 22 Child's playground set H & W Husband 450.00 -- Comments: Purchased in 2004 for $900.00. 23 Computer table H & W Husband ?? Comments: Purchased used in 1999 for $20.00. 24 Husband's clothes H & W Husband 1,000.00 -- Comments: 25 Children's clothes H & W Husband 600.00 -- Comments: 26 Child's toys (indoors and outdoors) H & W Husband 470.00 -- Comments: Inside toys estimated at $250.00; outdoor toys estimated at $220.00. All outdoor toys were bought new in 2004 for $440.00. 27 Curtains H & W Husband 400.00 -- Comments: 28 Child's bedding (hand made) H & W Husband 80.00 Comments: Page 17 TABLE 93-A HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY IN HUSBAND'S POSSESSION NO. DESCRIPTION OWNER POSSESSOR DATE OF VALUE VALUE BASIS FOR EXCLUSION IF NON- MARITAL 29 Air Conditioner H & W Husband 170.00 -- Comments: Purchased in 1999 for $340.00; never used 30 Dog cages H & W Husband 250.00 -- Comments: Purchased in 1996 for $645.00 31 Dresser to wife's bedroom set H & W Husband 25.00 -- Comments: 32 Dog hairdryer H & W Husband 75.00 -- Comments: Purchased in 2003 for $150.00. 33 Household tools H & W Husband 300.00 Comments: 34 Car tools H & W Husband 5,000.00 -- Comments: Value is rough guess estimate and items need to be professionally valued 35 Turkey fryer H & W Husband 50.00 -- Comments: Purchased in 2004 for $100.00. 36 Suitcases H & W Husband 150.00 -- Comments: Purchased in 2004 for $300.00. 37 Collection of chess sets H & W Husband 200.00 -- Comments: 38 12 CD disc player H & W Husband 100.00 -- Comments: Purchased in 1997 for $370.00; hardly used 39 Table power saw & 2 power drills H & W Husband 150.00 -- Comments: Purchased in 2003/2004 for $300.00. Page 18 TABLE #3-A HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY IN HUSBAND'S POSSESSION NO. DESCRIPTION OWNER POSSESSOR DATE OF VALUE VALUE BASIS FOR EXCLUSION IF NON- MARITAL 40 Riding lawn mower H & W Husband 500.00 -- Comments: Purchased in 2002 for $1,000.00. 41 Snow blower H & W Husband 301.00 -- Comments: Purchased in 2002 for $602.00. 42 2 power lawn mowers H & W Husband 500.00 -- Comments: Purchased in 2004. Value is rough guess estimate and items need to be professionally valued 43 Leaf blower H & W Husband 100.00 -- Comments: Purchased in 2004. Value is rough guess estimate and items need to be professionally valued 44 Air compressor for auto tires H & W Husband 100.00 -- Comments: Purchased in 2004. Value is rough guess estimate and items need to be professionally valued 45 Power sprayer H & W Husband 200.00 -- Comments: Value is rough guess estimate and items need to be professionally valued 46 2 auto tool cabinets H & W Husband 1,000.00 -- Comments: Value is rough guess estimate and items need to be professionally valued 47 Mountain bike H &W Husband 120.00 -- Comments: Purchased in 2004 for $240.00. 48 4 Thunderbird wheel rims H & W Husband 300.00 -- Comments: Purchased in 1998 for $1,000.00. 49 Exhaust pipe for motorcycle H & W Husband 450.00 Comments: Purchased in 2004 for $900.00. Page 19 TABLE #3-A HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY IN HUSBAND'S POSSESSION NO. DESCRIPTION OWNER POSSESSOR DATE VALUE BASIS FOR OF EXCLUSION IF NON- VALUE MARITAL 50 Couch H & W Husband 300.00 -- Comments: Wife has matching love seat and chair. All three pieces purchased in 2004 for $1,200.00. 51 Coffee table H & W Husband 25.00 -- Comments: Wife has matching end tables. Three pieces purchased used in 2002 for $100.00. 52 New Tire for Wife's car W Husband 75.00 under Porch - Comments: Purchased by wife in 2003 for $150.00. Wife wants it back. TOTAL HUSBAND'S POSSESSION 21,944.00 TABLE #3-B HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY IN WIFE'S POSSESSION NO. DESCRIPTION OWNER POSSESSOR DATE OF VALUE VALUE BASIS FOR EXCLUSION IF NON- MARITAL 1 Lazy Boy chair & loveseat H & W Wife 300.00 -- Comments: Husband has matching couch. Original price for all three pieces in 2004 was approximately $1,200.00. 2 2 end tables H & W Wife 25.00 -- Comments: Husband has matching coffee table. In 2002, three pieces used was $100.00. 3 2 night stands H & W Wife 400.00 -- Comments: Purchased in 2004 for $800.00. 4 3 artificial plants H & W Wife 10.00 -- Comments: Purchased at a flea market for $15.00. 5 2 - 21" tv's H & W Wife 100.00 -- Comments: These are old sets; $100 combined value. Page 20 y ? TABLE #3-B HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY IN WIFE'S POSSESSION NO. DESCRIPTION OWNER POSSESSOR DATE OF VALUE VALUE BASIS FOR EXCLUSION IF NON- MARITAL 6 2 - VCR's H & W Wife 50.00 -- Comments: These are old VCR's; $50 combined value. 7 Small stereo H & W Wife 40.00 -- Comments: 8 3 small table lamps H & W Wife 15.00 -- Comments: Purchased in 2004 for $30.00. 9 2 tall lamps H & W Wife 0.00 -- Comments: 1 is broken; 1 purchased after separation. 10 Doll collection H & W Wife 200.00 -- Comments: 11 Various knick-knacks H & W Wife 100.00 -- Comments: 12 Dining table & chairs H & W Wife 1,000.00 -- Comments: Husband has matching china cabinet and 2 chairs. Entire set purchased in 2004 for $4,000.00. 13 Microwave H & W Wife 25.00 -- Comments: Purchased in 2000 for $50.00. 14 Coffee machine H & W Wife 10.00 -- Comments: 15 Portable electric grill H & W Wife 50.00 -- Comments: Purchased in 2002 for $100.00. 16 Cutting knife set H & W Wife 20.00 -- Comments: 17 Various common cooking utensils H & W Wife 100.00 -- Comments: Page 21 3 Y TABLE #3-B HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY IN WIFE'S POSSESSION NO. DESCRIPTION OWNER POSSESSOR DATE OF VALUE VALUE BASIS FOR EXCLUSION IF NON- MARITAL 18 Everyday dining utensils H & W Wife 20.00 -- Comments: 19 Various toiletries H & W Wife 20.00 -- Comments: 20 Bedroom set H & W Wife 200.00 -- Comments: Purchased in 1999 for $427.00. Husband has dresser. 21 Corner stand H & W Wife 2.00 -- Comments: Purchased at flea market. 22 Telephone set H & W Wife 35.00 -- Comments: Purchased in 2003 for $70.00. 23 Breakfast table H & W Wife 25.00 -- Comments: Husband has the 2 matching chairs. Purchased 3 piece set in 2002 for $99.00. 24 2 sewing machines H & W Wife 75.00 -- Comments: 25 Fabric and sewing accessories H & W Wife 250.00 -- Comments: 26 Computer H & W Wife 400.00 -- Comments: Purchased in 2004 for $800.00. 27 Vacuum cleaner H & W Wife 100.00 -- Comments: Purchased used in 1999 for $400.00. Page 22 TABLE #3-B HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY IN WIFE'S POSSESSION DESCRIPTION OWNER POSSESSOR F VALUE BASIS FOR EXCLUSION IF NON- MARITAL J28 File cabinet H & W Wife 10.00 Comments: Used; estimated value of $10 29 Drapes/curtains H & W Wife 100.00 -- Comments: Most were hand made by Wife. Value is based on price of fabric. 30 Clothing H & W Wife 300.00 -- Comments: 31 Jewelry - bracelet & earrings H & W Wife 150.00 Comments: Bracelet was purchased for $150.00; now valued at $50.00. TOTAL WIFE'S POSSESSION 4,132.00 Page 23 r SECTION IV. NON-MARITAL ASSETS AND DEBTS The following Table 94 sets forth the non-marital assets and debts of the parties:'," TABLE #4 NON-MARITAL PROPERTY AND DEBTS NO. DESCRIPTION OWNER POSSESSOR DATE OF VALUE VALUE BASIS FOR EXCLUSION IF NON- MARITAL 1 Wife's Jewelry Wife Wife 150.00 Wife's pre-marital Comments: 2 Wife's clothing Wife Wife 300.00 Wife's pre-marital Comments: 3 Video camera Husband Husband 150.00 Husband's pre-marital Comments: 4 Wife's mountain bike Wife Husband Unknown Wife's pre-marital Comments: Wife would like to have this item returned to her. 3Note: Exclusions from marital property include property acquired before marriage, property acquired after separation, or property acquired during marriage by way of gift or inheritance from third party not a spouse. For gifts and inheritance also specify the source person. "The value of each item has been estimated by Plaintiff unless otherwise noted. Page 24 J SECTION V. PROPERTY TRANSFERRED The following Table #5 is Plaintiffs listing of all property which was transferred within 3 years of the date of the commencement of this action or was transferred since the date of separation: TABLE #5 PROPERTY TRANSFERRED NO. DESCRIPTION OF PROPERTY TRANSFER DATE CONSIDERATION TRANSFEROR TRANSFEREE 1 BBQ 2001 0.00 Husband Heather Means Comments: Heather Means is husband's mistress. 2. Twin Bed 2001 0.00 Husband Husband's Mistress -- Comments: Heather Means is husband's mistress. 3. Dining Room Set 2001 0.00 Husband Heather Means -- Comments: Heather Means is husband's mistress. -- Comments: Comments: Page 25 w ? r CERTIFICATE OF SERVICE I, Diane G. Radcliff, Esquire, hereby certify that on I served a copy of the within Inventory, by mailing same by first class mail, postage prepaid, ad ressed as follows: Charles E. Petrie, Esquire 3528 Brisban Street Harrisburg, PA 17111 DM-NE G. FF, ESQUIRE e Road Camp Hill, PA 17011 Supreme Court ID # 32112 Phone: (717) 737-0100 Fax: (717) 975-0697 Attorney for Plaintiff Page 26 ?. 7 TZ (l I . BARBARA E. LONG, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW vs. : NUMBER: 04-5363 RAHMAN N. LONG, Defendant IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER 23301(dj OF THE DIVORCE CODE 1. The parties to this action separated in October, 2004, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. DEFENDANT - f d' Date: r u tV -'C r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARBARA E. LONG, Plaintiff NO. 04-5363 V. : CIVIL ACTION - LAW RAHMAN N. LONG, DIVORCE Defendant MOTION FOR APPOINTMENT OF MASTER Barbara E. Long, Plaintiff, moves the Court to appoint a Master with respect to the following claims: [x] Divorce [x] Distribution of Property [ ] Annulment [ ] Support [x] Alimony [x] Counsel Fees [ ] Alimony Pendente Lite [x] Costs and Expenses in support of the Motion the Plaintiff states: 1. Discovery is complete with respect to the claims for which the appointment of the Master is requested. 2. The non-moving party has [appeared in the action by his attorney, Charles E. Petrie, Esquire. 3. The statutory ground for the divorce is/are: Section 3301 (c) and Section 3301(d) No-Fault. 4. Check the applicable paragraphs: [ ] The action is not contested. [ ] An agreement has been reached with respect to the following claims: [X] The action is contested with respect to the following claims: All Economic Claims 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take one-half ('/z ) day. 7. Additional information, if any, relevant to the motion: None Date: 4/11/0-7 DIANE RADCLIFF, ESQtjIftE ey f r Plaintiff ORDER APPOINTING MASTER AND NOW, , 2007, E. Robert Elicker, II, Esquire is appointed Master with respect to the following claims: [x] Divorce [ ] Annulment [x] Alimony [ ] Alimony Pendente Lite [x] Distribution of Property [ ] Support [x] Counsel Fees [x] Costs and Expenses BY THE COURT: JUDGE t MOVING PARTY BARBARA E. LONG Attorney's name and address: Diane G. Radcliff, Esquire 3448 Trindle Road Camp Hill, PA 17011 Phone: 717-737-0100 Fax: 717-975-0697 NON MOVING PARTY RAHMAN N. LONG Attorney's name and address: Charles E. Petrie, Esquire 3528 Brisban Street, Harrisburg, PA 17111 Phone: 561-1939 Fax: 561-4121 c:? ?' -._ z? - __, ; ? .? ?? ? T., ? rv ; ?-? ca - ?::. - ,_._.? ?: ?? r'? --? cs? '? aPIA2 3 200 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAN BARBARA E. LONG, Plaintiff NO. 04-5363 V. : CIVIL ACTION - LAW RAHMAN N. LONG, : DIVORCE Defendant MOTION FOR APPOINTMENT OF MASTER Barbara E. Long, Plaintiff, moves the Court to appoint a Master with respect to the following claims: [x] Divorce [x] Distribution of Property [ ] Annulment [ ] Support [x] Alimony [x] Counsel Fees [ ] Alimony Pendente Lite [x] Costs and Expenses In support of the Motion the Plaintiff states: 1. Discovery is complete with respect to the claims for which the appointment of the Master is requested. 2. The non-moving party has [appeared in the action by his attorney, Charles E. Petrie, Esquire. 3. The statutory ground for the divorce is/are: Section 3301 (c) and Section 3301(d) No-Fault. 4. Check the applicable paragraphs: [ ] The action is not contested. [ ] An agreement has been reached with respect to the following claims: [X] The action is contested with respect to the following claims: All Economic Claims 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take one-half ('/z ) day. 7. Additional information, if any, relevant to the motion: None Date: 1/0-7 DIANE RADCLIFF, ES I ey f Plaintiff ORDER APPOINTING MASTER AND NOW, 3d , 2007, E. Robert Elicker, II, Esquire is appointed Master with respect to the fo owing claims: [x] Divorce [x] Distribution of Property [ ] Annulment [ ] Support [x] Alimony [x] Counsel Fees [ ] Alimony Pendente Lite [x] Costs and Expenses BY T 2v, W?o JUD GE % ALED- 1.,H-1C1_ OF THE PPfM 2007 APP' 30 AH l 6 : S ! Citir}' V'ta?`? EAR , % _..1 MOVING PARTY BARBARA E. LONG Attorney's name and address: Diane G. Radcliff, Esquire _X_k ? 3448 Trindle Road 3? o Camp Hill, PA 17011 Phone: 717-737-0100 Fax: 717-975-0697 NON MOVING PARTY RAHMAN N. LONG Attorney's name and address: -Charles E. Petrie, Esquire 7 3528 Brisban Street, Harrisburg, PA 17111 Phone: 561-1939 Fax: 561-4121 c fl IZI cn cc BARBARA E. LONG : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW vs. NUMBER: 04-5363 CIVIL TERM RAHMAN N. LONG, Defendant IN DIVORCE INVENTORY OF RAHMAN N. LONG Defendant files the following inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Defendant verifies that the statements in this inventory are true and correct. Defendant understands that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: ' G ASSETS OF PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemize the assets on the following pages. (X) 1. Real property (X) 2. Motor vehicles () 3. Stocks, bonds, securities and options () 4. Certificates of deposit (X) 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 O 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) () 19. Retirement plans, Individual Retirement Accounts () 20. Disability payments () 21. Litigation claims (matured and unmatured) ()q 22. Military/VA benefits () 23. Education benefits (X) 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 legal or equitable interest individually or with any other persona as of the date this action was commenced: Item Description Number of Property Names of All Owners 1. 107 Doreen Drive Rahman and Barbara Long Hummelstown, PA 17036 (Real Estate sold by Bankruptcy Trustee - See attached Trustee's Report of Private Sale) 2. 2004 Ford Expedition Rahman Long 2003 Suzuki Hayabusa Rahman Long 1990 Ford Thunderbird Rahman Long 1995 Ford Taurus Rahman Long and Brenda Wise 18. Defense Finance & Acct. Rahman Long Svice - US Military Retirement Genco Distribution Systems Barbara Long (Pension/ Retirement) 22. Military/VA Benefits Rahman Long 25. Household furnishings Rahman and Barbara Lung Please see attached appraisal NON-MARITAL PROPERTY Plaintiff lists all property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property: Item Number Description of Property Reason for Exclusion 2. 5. 2007 Suzuki Boulevard Purchased March, 2007 After date of separation Checking Account All monies deposited after date of separation PROPERTY TRANSFERRED Item Number Description Date of Consid- of Property Transfer eration Person to Whom Transferred LIABILITIES Item Number Description Names of of Property All Creditors Names of All Debtors * Please see attached Schedules D, E, and F of Defendant's Petition for Bankruptcy CLAUDE C. WOLFE & ASSOCIATES AUCTIONEERS & APPRAISERS FAMILY OWNED SINCE 1910 2009 LINCOLN STREET - CAMP HILL, PA 17011 717-737-0734 April 1, 2005 Appraisal for Rahman N. Long 107 Doreen Drive, Hummelstown, PA ITEMS from Section III. Table #3-A Kenmore washer - 2001 225.00 Kenmore dryer - 2001 175.00 Kenmore side-by-side refrigerator - 2001 400.00 White-Westinghouse refrigerator - old 25.00 King size bed & headboard - 2002 350.00 53" TV - 1998 300.00 5-Pieces of Sony stereo system & speakers - 1996 250.00 Gym sets(3) 250.00 Glenwood dining room china closet & (2)chairs - 2004 600.00 Large spider floor lamp - 1998 25.00 Table lamp - 1998 5.00 10-Pieces of outdoor porch furniture - 2004 300.00 Twin size bed 25.00 Dresser with mirror - 1999 75.00 CD collection 250.00 Gun - 1998 150.00 Kitchenware 25.00 TV stand 10.00 Misc. children's bedroom furniture 20.00 Inside plants & artificial plants 25.00 2-BBQ's 135.00 Child's playground set - 2004 300.00 Computer table 5.00 Curtains - 5 burgundy drapes 10.00 Child's bedding 10.00 CLAUDE C. WOLFE & ASSOCIATES AUCTIONEERS & APPRAISERS FAMILY OWNED SINCE 1910 2009 LINCOLN STREET • CAMP HILL, PA 17011 717-737-0734 Long appraisal Page 2 of 3 Dog cages 160.00 Armoire to wife's bedroom suite 25.00 Dog hairdryer 35.00 Household tools - caulking gun, hammer, level, screwdriver, pliers, etc 10.00 Car tools 350.00 Turkey fryer - 2004 30.00 Suitcases - 2004 60.00 Chess set (1) 10.00 12 CD disc player - 1997 75.00 Power saw & 2 power drills 65.00 Snow blower - Murray 5hp - 24" 301.00 (2)Power lawn mowers - Craftsman 22($85) & Murray($1) junk 86.00 Leaf blower - Craftsman - 2004 35.00 Air tank for auto tires - 2004 25.00 Power sprayer - Wagner 20.00 (2)Auto tool cabinets - Clarke 125.00 (4)Thunderbird wheel rims - 16" 1995 Platinum by Ultra 200.00 Exhaust system for motorcycle - 2004 300.00 Couch - light brown - 2004 300.00 Coffee table - poor condition 10.00 New tire for wife's car under porch - Nail through side wall - junk 1.00 2004 Ford Expedition - Eddie Bauer, 15K miles, moon roof, power 27,000.00 1990 Ford Thunderbird SC, 280K, fair condition 1,000.00 1995 Ford Taurus 4-door sedan, 116,340 miles, power accessories 1,300.00 Suzuki 1300 motorcycle - Hayabusa, 7,500 miles 7,500.00 CLAUDE C. WOLFE & ASSOCIATES AUCTIONEERS & APPRAISERS FAMILY OWNED SINCE 1910 2009 LINCOLN STREET • CAMP HILL, PA 17011 717-737-0734 Long Appraisal Page 3 of 3 APPRAISAL TOTAL $ 42,968.00 This Fair Market Value appraisal is true and correct to the best of my ability as an auctioneer and appraiser with 35 years experience. Member: Certified Appraisers Guild of America CLAUDE C. WOLFE & ASSOCIATES W. K. Dusty Chapman, CAGA UNITED STATES DEPARTMENT OF JUSTICE UNITED STATES TRUSTEE MIDDLE DISTRICT OF PENNSYLVANIA REPORT OF PRIVATE SALE (For Chapter 7, 11 or 13 Cases) CASE CAPTION: CASE NO. 1-05-04844 RAHMAN LONG CHAPTER: 7 DATE OF SALE: May 30, 2006 TRUSTEE'S ATTORNEY: Markian R. Slobodian, Esq. 2. ATTORNEY FOR CREDITOR'S COMMITTEE: N/A 3. BRIEF DESCRIPTION OF ASSETS: Real property located at 107 Doreen Drive, Hummelstown PA 17036 4. REASON(S) FOR ACCEPTANCE OF PRIVATE OFFER IN LIEU OF PUBLIC SALE: Highest Offer 5. VALUE OF PROPERTY $232,000.00 HOW OBTAINED: Realtor's Marketing Opinion (Appraisal or Otherwise) 6. PURCHASE PRICE $232,000.00 NAME OF PURCHASER: Amanda E. Calik & Andrew J. Brown 7. HOW WAS PURCHASER OBTAINED: Property listed & marketed by Realtor 8. PURCHASER'S RELATIONSHIP TO DEBTOR: None 9 EXPENSES OF SALE $ 227,403.13 NET AMOUNT REALIZED $ 4,596.87 $ 14,045.00 Realtor's Commission & Fee $207,529.37 Washington Mutual Bank (Mortgagee) $ 2,298.43 Debtor's exemptions (per Court Order) $ 2,298.43 Debtor's spouse (per Court Order) $ 959.66 Current taxes $ 272.24 Miscellaneous costs of sale (Attach itemization or real estate settlement sheet) 10. WERE THERE ANY OBJECTIONS MADE TO THE SALE? No (IF SO, STATE NAME OF OBJECTOR, REASON FOR OBJECTION, OBJECTOR'S RELATION TO DEBTOR AND OUTCOME OF HEARING, IF ANY:) _ Markian R. Slobodian, Esq., Trustee Reporting Party (Type or Print) Date: 6/8/06 /s/ Markian R. Slobodian Signature (File Report with Clerk within five (5) days of sale, even if objection is filed, with copy to U. S. Trustee) UST-PA-MD-6 (Apr, 1988) IN RE: Rahman Long CASE NO 1:05-bk-04844 (if Known) CHAPTER 7 SCHEDULE D (CREDITORS HOLDING SECURED CLAIMS) ? Check this box if debtor has no creditors holding secured claims to report on Schedule D. DATE CLAIM WAS INCURRED, z o AMOUNT OF CLAIM CREDITOR'S NAME AND MAILING ADDRESS o R WE a NATURE OF LIEN, AND DE CRIP IO A w ` p - o WITHOUT UNSECURED INCLUDING ZIP CODE w 3 S T N ND MARKET ? d DEDUCTING PORTION, IF o v c VALUE OF PROPERTY SUBJECT z VALUE OF ANY < rc TO LIEN o Z o COLLATERAL W x ACCT #: DATE INCURRED: 0812004 NATURE OF LIEN: Purchase Money BEST EMPLOYEE'S FCU COLLATERAL: $35 956 00 $8 856 00 21375 ALEXANDER ROAD 2004 Ford Expedition , . , . WALTON HILLS, OH 44146-5583 - REMARKS: COLLATERAL VALUE: $27,000-00 ACCT #: DATE INCURRED: 0312003 NATURE OF LIEN: Purchase Money BEST EMPLOYEE'S FCU COLLATERAL: 2003 Suzuki $8,580.05 $7,080.05 21375 ALEXANDER ROAD WALTON HILLS, OH 44146-5583 ^ REMARKS: COLLATERAL VALUE: $7,600.00 ACCT #: xxxxxx8863 DATE INCURRED: 0112002 NATURE OF LIEN: Mortgage WASHINGTON MUTUAL HOME LOANS COLLATERAL: ;176 553 93 PO BOX 830214 107 Doreen Drive, Hummelstown, PA 1703 , . BALTIMORE, MD 21283-0214 X J REMARKS: COLLATERAL VALUE: $249,900.00 No continuation sheets attached Total for this Page (Subtotal) > $221,089.98 $10,036.05 Running Total > $221,089.98 $10,036.05 UNITED STATES BANKRUPTCY COURT MIDDLE DISTRICT OF PENNSYLVANIA HARRISBURG DIVISION IN RE: Rahman Long CASE NO 1:05-bk-04844 CHAPTER 7 SCHEDULEE (CREDITORS HOLDING UNSECURED PRIORITY CLAIMS) ? Check this box if debtor has no creditors holding unsecured priority claims to report on this Schedule E. TYPES OF PRIORITY CLAIMS (Check the appropriate box(es) below if claims in that category are listed on the attached sheets) ? Extensions of credit in an involuntary case Claims arising in the ordinary course of the debtors business or financial affairs after the commencement of the case but before the earlier of the appointment of a trustee or the order for relief. 11 U.S.C. Sec. 507(a)(2). ? Wages, salaries, and commissions Wages, salaries, and commissions, including vacation, severance, and sick leave pay owing to employees and commissions owing to qualifying independent sales representatives up to $10,000* per person earned within 180 days immediately preceding the filing of the original petition, or the cessation of business, whichever occurred first, to the extent provided by 11 U.S.C. Sec. 507(a)(3), as amended by § 1401 of Pub. L. 109-8. ? Contributions to employee benefit plans Money owed to employee benefit plans for services rendered within 180 days immediately preceding the filing of the original petition, or the cessation of business, whichever occurred first, to the extent provided in 11 U.S.C. Sec. 507(a)(4). ? Certain farmers and fishermen Claims of certain farmers and fishermen, up to $4,925* per farmer or fisherman, against the debtor, as provided in 11 U.S.C. Sec. 507(a)(5). ? Deposits by Individuals Claims of individuals up to $2,225* for deposits for the purchase, lease or rental of property or services for personal, family, or household use, that were not delivered or provided. 11 U.S.C. Sec. 507(a)(6). ? Alimony, Maintenance, or Support Claims of a spouse, former spouse, or child of the debtor for alimony, maintenance, or support, to the extent provided in 11 U.S.C. Sec. 507(a)(7). RI Taxes and Certain Other Debts Owed to Governmental Units Taxes, customs duties, and penalties owing to federal, state, and local government units as set forth in 11 U.S.C. Sec. 507(a)(8). ? Commitments to Maintain the Capital of an Insured Depository Institution Claims based on commitments to the FDIC, RTC, Director of the Office of Thrift Supervision, Comptroller of the Currency, or Board of Governors of the Federal Reserve System, or their predecessors or successors, to maintain the capital of an insured depository institution. 11 U.S.C. Sec. 507(a)(9). ? Administrative allowances under 11 U.S.C. Sec. 330 Claims based on services rendered by the trustee, examiner, professional person, or attorney and by any paraprofessional person employed by such person as approved by the court and/or in accordance with 11 U.S.C. Secs. 326, 328, 329 and 330. *Amounts are subject to adjustment on April 1, 2007, and every three years thereafter with respect to cases commenced on or after the date of adjustment. 1 continuation sheets attached IN-RE: Rahman Long CASE NO 1:0"k-04844 (If Known) CHAPTER 7 SCHEDULE E (CREDITORS HOLDING UNSECURED PRIORITY CLAIMS) Continuation Sheet No, f TYPE OF PRIORITY Taxes F•- ? or ~ 0 W o CREDITOR'S NAME, w a DATE CLAIM WAS INCURRED Z p Q W a AMOUNT AMOUNT MAILING ADDRESS O AND CONSIDERATION FOR OF ENTITLED TO INCLUDING ZIP CODE, zz CLAIM 3 o CLAIM PRIORITY AND ACCOUNT NUMBER v ? U x ACCT #: DATE INCURRED: 2000 IRS CONSIDERATION: 1040 Taxes $1,823.34 $1,823.34 SPECIAL PROCEDURES BRANCH REMARKS: PO BOX 628 BANKRUPTCY DEPT 2000 Tax Record PITTSBURGH, PA 15230 Total for this Page (Subtotal) > $1,823.34 $1,823.34 Running Total > $1,823.34 $1,823.34 IN RE: Rahman Long CASE NO 1:05-bk-04844 (If Known) CHAPTER 7 SCHEDULE F (CREDITORS HOLDING UNSECURED NONPRIORITY CLAIMS) ? Check this box if debtor has no creditors holding unsecured nonpriority claims to report on Schedule F. 0 CREDITOR'S NAME AND MAILING ADDRESS o H- ' DATE CLAIM WAS INCURRED AND o AMOUNT OF CLAIM INCLUDING ZIP CODE w ; CONSIDERATION FOR CLAIM. IF CLAIM z - ° ° 0 O 0 o IS SUBJECT TO SETOFF, SO STATE. z CL m c i m ? 0 rn ? x ACCT #: xxxxxxxx1244.... DATE INCURRED: 0417999 BANK OF AMERICA CONSIDERATION: Credit Card $672.00 1825 E BUCKEYE RD REMARKS: PHOENIX, AZ 85034 Account charged off as of February, 2002 ACCT #: DATE INCURRED: BARBARA E LONG CONSIDERATION: Marital Debt Unknown 1221 A BRIDGE STREET REMARKS: NEW CUMBERLAND, PA 17070-1637 ' ACCT #: XXXX-XXXX-XXXX-5905 DATE INCURRED: 0812004 BEST CONSIDERATION: Credit Card $4,722.25 CUSTOMER SERVICE REMARKS' PO BOX 31112 - TAMPA, FL 33631-3112 ACCT #: XXXX-XXXX-XXXx-6241 DATE INCURRED: 0311996 CAPITAL ONE SERVICES CONSIDERATION: Credit Card $1,636.78 PO BOX 85015 REMARKS: RICHMOND, VA 23285-5015 - Last used 0912004 - high balance was $2,064.00 ACCT #: xxxxxxxx-Xxx3552 DATE INCURRED: 0412003 CITIFINANCIAL CONSIDERATION: Installment account $7,990.66 PO BOX 8020 REMARKS: SOUTH HACKENSACK, NJ 07606-8020 Installment Account - terms 60 months ACCT #: xxxxxxxxxxxx4893 DATE INCURRED: 0411992 MILITARY STAR CONSIDERATION: Credit Card $4,246.91 PO BOX 830031 REMARKS: BALTIMORE, MD 21283-0031 - Last used October, 2004 - High balance was $4600.00 ACCT #: xxxxxxxxxxxx0653 DATE INCURRED: 0111999 SEARS CONSIDERATION: Credit Card $298.80 C/O CITI CARDS REMARKS: PO BOX 182532 Last used December, 2003 - High balance was COLUMBUS, OH 43218-2532 $410.00 1 continuation sheets attached Total for this page (Subtotal) > $19,567.40 Running Total > $19,567.40 - z M n fir„ 9'n. i BARBARA E. LONG, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION LAW vs. : NUMBER: 04-5363 CIVIL TERM RAHMAN N. LONG, Defendant: IN DIVORCE CASE SUMMARY NAME: BARBARA E. LONG ADDRESS: Unknown HOW LONG AT RESIDENCE: Unknown SOCIAL SECURITY NUMBER: Unknown DATE OF BIRTH: May 5, 1960 EMPLOYED BY: Genco Distribution System POSITION: Unknown SALARY: Unknown NAME: RAHMAN N. LONG ADDRESS: 40 Lakepoint Drive, Harrisburg, Pennsylvania 17111 HOW LONG AT RESIDENCE: June, 2006 SOCIAL SECURITY NUMBER: 292-70-8311 DATE OF BIRTH: October 23, 1961 EMPLOYED BY: Single Source Transportation POSITION: Truck Driver SALARY: $5098.00 gross monthly CHILDREN: NAME: Natasha Long SOCIAL SECURITY NUMBER: XXX-XX-1903 DATE OF BIRTH: February 26, 2002 NAME: Kevin Long SOCIAL SECURITY NUMBER: Unknown DATE OF BIRTH: October 10, 1982 DATE OF MARRIAGE: July 8, 1995 PLACE OF MARRIAGE: Cleveland, Ohio DATE OF SEPARATION: 10 / 23 / 2004 DIVORCE COMPLAINT: FILED: October 25, 2004 COUNTY: Cumberland DOCKET NO.: 04-5363 Civil Term CLAIMS: Equitable Distribution, Alimony Pendente Lite, Alimony, and Counsel Fees, costs and expenses SUBSEQUENT PLEADINGS: SUPPORT COMPLAINT: FILED: January, 2005 COUNTY: Cumberland DOCKET NO.: 04-5363 Civil DATE OF ORDER: February 22, 2005 AMOUNT: $678.00 per month EFFECTIVE DATE: November 18, 2004 FOR: ARREARAGES: $100.00 per month until paid in full MEDICAL: SPECIAL PROVISIONS: CUSTODY ORDER: N/A DATED: PRIMARY CUSTODY: PARTIAL CUSTODY: SPECIFICS: ASSETS: REAL ESTATE: 107 Doreen Drive, Hummelstown, PA 17036 (Sold by Bankruptcy Trustee - proceeds divided equally after mortgage payoff) MORTGAGE: Washington Mutual Home Loans MONTHLY PAYMENT: $1667.00 BALANCE: $175,553.93 OWNER: Rahman Long and Barbara Long VEHICLES: MAKE: 2004 Ford Expedition TITLE OWNER: Rahman Long APPROX. VALUE: $25,000.00 MAKE: 2003 Suzuki Hayabusa TITLE OWNER: Rahman Long APPROX. VALUE: $5,000.00 MAKE: 1990 Ford Thunderbird TITLE OWNER: Rahman Long APPROX. VALUE: $1,000.00 MAKE: 1995 Ford Taurus TITLE OWNER: Rahman Long and Brenda Wise (at the time of separation) - Now titled in the name of Brenda Wise APPROX. VALUE: $1,300.00 MAKE: 2007 Suzuki Boulevard TITLE OWNER: Rahman Long PURCHASED: March, 2007 APPROX. VALUE: $12,500.00 PENSIONS: Defense Finance & Accounting Svice US Military Retirement Pay OWNER: Rahman Long VALUE: Unknown PENSIONS: Genco Distribution Systems OWNER: Barbara Long VALUE: Unknown DEBTS: See attached Schedules D, E, F from Defendant's Petition for Bankruptcy MISCELLANEOUS INFORMATION: N/A UNITED STATES DEPARTMENT OF JUSTICE UNITED STATES TRUSTEE MIDDLE DISTRICT OF PENNSYLVANIA REPORT OF PRIVATE SALE (For Chapter 7, 11 or 13 Cases) CASE CAPTION: CASE NO. 1-05-04844 RAHMAN LONG CHAPTER: 7 1. DATE OF SALE: May 30, 2006 TRUSTEE'S ATTORNEY: Markian R. Slobodian, Esq. 2. ATTORNEY FOR CREDITOR'S COMMITTEE: N/A 3. BRIEF DESCRIPTION OF ASSETS: Real property located at 107 Doreen Drive, Hummelstown, PA 17036 4. REASON(S) FOR ACCEPTANCE OF PRIVATE OFFER IN LIEU OF PUBLIC SALE: Highest Offer 5. VALUE OF PROPERTY $232,000.00 HOW OBTAINED: Realtor's Marketing Opinion (Appraisal or Otherwise) 6. PURCHASE PRICE $232,000.00 NAME OF PURCHASER: Amanda E. Calik & Andrew J. Brown 7. HOW WAS PURCHASER OBTAINED: Property listed & marketed by Realtor 8. PURCHASER'S RELATIONSHIP TO DEBTOR: None 9. EXPENSES OF SALE $ 227,403.13 NET AMOUNT REALIZED $ 4,596.87 $ 14,045.00 Realtor's Commission & Fee $207,529.37 Washington Mutual Bank (Mortgagee) $ 2,298.43 Debtor's exemptions (per Court Order) $ 2,298.43 Debtor's spouse (per Court Order) $ 959.66 Current taxes $ 272.24 Miscellaneous costs of sale (Attach itemization or real estate settlement sheet) 10. WERE THERE ANY OBJECTIONS MADE TO THE SALE? No (IF SO, STATE NAME OF OBJECTOR, REASON FOR OBJECTION, OBJECTOR'S RELATION TO DEBTOR AND OUTCOME OF HEARING, IF ANY:) /s/ Markian R. Slobodian Markian R. Slobodian, Esq., Trustee Reporting Party Signature (Type or Print) Date: 6/8/06 (File Report with Clerk within five (5) days of sale, even if objection is filed, with copy to U. S. Trustee) UST-PA-MD-6 (Apr.1988) IN RE: Rahman Long CASE NO 1:05-bk-04844 (IF Known) CHAPTER 7 SCHEDULE D (CREDITORS HOLDING SECURED CLAIMS) ? Check this box if debtor has no creditors holding secured claims to report on Schedule D. REDITOR'S NAME AND MAILING ADDRESS INCLUDING ZIP CODE W v C !R 1 = gle CD s DATE CLAIM WAS INCURRED, NATURE OF LIEN, AND DESCRIPTION AND MARKET VALUE OF PROPERTY SUBJECT TO LIEN z W 5 O ? < o - v d c AMOUNT OF CLAIM WITHOUT DEDUCTING VALUE OF COLLATERAL UNSECURED PORTION, IF ANY ACCT #: DATE INCURRED: 0812004 NATURE OF LIEN: h P M urc ase oney BEST EMPLOYEE'S FCU 21375 ALEXANDER ROAD WALTON HILLS, OH "1"450 _ COLLATERAL: 2004 Ford Expedition REMARKS: $35,966.00 $8,956.00 COLLATERAL VALUE: $27,000.00 ACCT DATE INCURRED: 0312003 NATURE OF LIEN: P h M oney urc ase BEST EMPLOYEE'S FCU 21375 ALEXANDER ROAD WALTON HILLS, OH 44146-5583 _ COLLATERAL: 2003 Suzuki REMARKS: $8,580.05 $1,080.05 COLLATERAL VALUE: $7.500.00 ACCT #: xxxxxx8863 NATURES OF LLIIEN: 0412002 M t or gage WASHINGTON MUTUAL HOME LOANS PO BOX 830214 BALTIMORE, MD 21283-0214 X J COLLATERAL: 107 Doreen Drive, Hummelstown, PA 1703 REMARKS: :176,553.93 COLLATERAL VALUE: $249.900.00 ntinuation sheets attached Total for this Page (Subtotal) > N $221,089.98 $10,036.05 o Co Running Total > $221,089.98 $10,036.05 UNITED STATES BANKRUPTCY COURT MIDDLE DISTRICT OF PENNSYLVANIA HARRISBURG DIVISION IN RE: Rahman Long CASE NO 1:0"k-04844 CHAPTER 7 SCHEDULE E (CREDITORS HOLDING UNSECURED PRIORITY CLAIMS) ? Check this box if debtor has no creditors holding unsecured priority claims to report on this Schedule E. TYPES OF PRIORITY CLAIMS (Check the appropriate box(es) below if claims in that category are listed on the attached sheets) ? Extensions of credit in an Involuntary case Claims arising in the ordinary course of the debtor's business or financial affairs after the commencement of the case but before the earlier of the appointment of a trustee or the order for relief. 11 U.S.C. Sec. 507(x)(2). ? Wages, salaries, and commissions Wages, salaries, and commissions, including vacation, severance, and sick leave pay owing to employees and commissions owing to qualifying independent sales representatives up to 310,000* per person earned within 180 days immediately preceding the filing of the original petition, or the cessation of business, whichever occurred first, to the extent provided by 11 U.S.C. Sec. 507(a)(3), as amended by § 1401 of Pub. L. 109-8. ? Contributions to employee benefit plans Money owed to employee benefit plans for services rendered within 180 days immediately preceding the filing of the original petition, or the cessation of business, whichever occurred first, to the extent provided in 11 U.S.C. Sec. 507(a)(4). ? Certain farmers and fishermen Claims of certain farmers and fishermen, up to $4,925* per farmer or fisherman, against the debtor, as provided in 11 U.S.C. Sec. 507(a)(5). ? Deposits by Individuals Claims of individuals up to $2,225* for deposits for the purchase, lease or rental of property or services for personal, family, or household use, that were not delivered or provided. 11 U.S.C. Sec. 507(a)(6). ? Alimony, Maintenance, or Support Claims of a spouse, former spouse, or child of the debtor for alimony, maintenance, or support, to the extent provided in 11 U.S.C. Sec. 507(a)(7), ® Taxes and Certain Other Debts Owed to Governmental Units Taxes, customs duties, and penalties owing to federal, state, and local government units as set forth in 11 U.S.C. Sec. 507(a)(8). ? Commitments to Maintain the Capital of an Insured Depository Institution Claims based on commitments to the FDIC, RTC, Director of the Office of Thrift Supervision, Comptroller of the Currency, or Board of Governors of the Federal Reserve System, or their predecessors or successors, to maintain the capital of an insured depository institution. 11 U.S.C. Sec. 507(a)(9). ? Administrative allowances under 11 U.S.C. Sec. 330 Claims based on services rendered by the trustee, examiner, professional person, or attorney and by any paraprofessional person employed by such person as approved by the court and/or in accordance with 11 U.S.C. Secs. 326, 328, 329 and 330. * Amounts are subject to adjustment on April 1, 2007, and every three years thereafter with respect to cases commenced on or after the date of adjustment. 1 continuation sheets attached IN RE: Rahmon Long CASE NO 1:0"k-04844 (H Known) CHAPTER 7 SCHEDULE E (CREDITORS HOLDING UNSECURED PRIORITY CLAIMS) Continuation Sheet No. 1 TYPE OF PRIORITY Taxes ' f- z ? Z O CREDITOR'S NAME, I- LL DATE CLAIM WAS INCURRED 0 Z AMOUNT AMOUNT MAILING ADDRESS IN D AND CONSIDERATION FOR d a. OF ENTITLED TO INCLUDING ZIP CODE, O z CLAIM - CLAIM PRIORITY AND ACCOUNT NUMBER U V x ACCT; DATE INCURRED: 2000 IRS 1040TaxesN $1,823.34 $1,823.34 SPECIAL PROCEDURES BRANCH REMARKS: PO BOX 628 BANKRUPTCY DEPT 2000 Tax Record PITTSBURGH, PA 15230 Total for this Page (Subtotal) > $1,823.34 $1,823.34 Running Total > $1,823.34 $1,823.34 IN RE: Rahman Long CASE NO 1:06-bk-04844 (If Known) CHAPTER 7 SCHEDULE F (CREDITORS HOLDING UNSECURED NONPRIORITY CLAIMS) ? Check this box if debtor has no creditors holding unsecured nonpriorily claims to report on Schedule F. DATE CLAIM WAS INCURRED AND u=i CREDITOR'S NAME AND MAILING ADDRESS ?. W CONSIDERATION FOR CLAIM. IF CLAIM AMOUNT OF CLAIM INCLUDING ZIP CODE g IS SUBJECT TO SETOFF, SO STATE. ' v '? oc v x ACCT III: xx)oooooc1244.... DATE INCURRED: 0411999 it DN BANK OF AMERICA t Carrd Credi $672.00 1825 E BUCKEYE RD REMARKS: PHOENIX, AZ 85034 Account charged off as of February, 2002 ACCT #: DATE INCURRED: AT O BARBARA E LONG CONSIDER I N: Marital Debt Unknown 1221 A BRIDGE STREET REMARKS: NEW CUMBERLAND, PA 17070-1637 - ACCT #: xxxx-xxxx-xxxx-5905 DATE INCURRED: 0812004 CONSIDERATION BEST : Credit Card 64,TZZ.ZS CUSTOMER SERVICE REMARKS: PO BOX 31112 TAMPA, FL 33631-3112 ACCT #: x=x-xxxx-)a=-6241 DATE INCURRED: 0311996 TION I E CAPITAL ONE SERVICES RA : D Credit Card CONS $1,636.78 PO BOX 85015 REMARKS: RICHMOND, VA 23285-5015 - Last used 0912004 - high balance was $2,064.00 ACCT #: xxxxxi=-)=3552 DATE INCURRED: 0412003 CITIFINANCIAL CO Installment account 67,880.66 PO BOX 8020 REMARKS: SOUTH HACKENSACK, NJ 07606-8020 Installment Account - berms 60 montin ACCT #: xxxxxxxx =4893 DATE INCURRED: 0411992 CONSIDERATION MILITARY STAR : Credit Card $4,246.91 PO BOX 830031 REMARKS: BALTIMORE, MD 21283-0031 - Last used October, 2004 - High balance was $4600.00 ACCT 63 DATE INCURRED: 0111999 ON I ERATION SEARS S D : d ti Card C 6298.80 C/O CITI CARDS REMARKS: PO BOX 182532 Last used December, 2003 - High balance was COLUMBUS, OH 43218-2532 1$410.00 Total for this Page (Subtotal) > $19,567.40 1 continuation sheets attached Running Total > $19,567.40 r-? t7 ?? A ".1`y ^Y31 G {{''?? . y? ? f .. . fl Ftu` 1 ? L- ? z ? ? :?. ? ?"? BARBARA E. LONG, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW VS. NUMBER: 04-5363 RAHMAN N. LONG, Defendant IN DIVORCE THIS FORM MUST BE FILLED OUT (If you are self-employed or if you are salaried by a business of which you are owner in whole or in part, you must also fill out the Supplemental Income Statement which appears on the last page of this Income and Expense Statement.) INCOME AND EXPENSE STATEMENT OF RAHMAN N. LONG I 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: INCOME Employer: Single Source Transportation Address: PO Box 855, Des Moines, IA 50304-0855 Type of Work: Truck Driver Payroll Number: Pay Period (weekly, biweekly, etc.): Bi-weekly Monthly Gross Pay: $5098.00 Itemized Payroll Deductions Federal Withholding $986.15 Social Security $317.66 Medicare Tax $74.29 Local Wage Tax $101.97 State Income Tax $157.29 Retirement Savings Bonds Credit Union Life Insurance $20.19 Health Insurance $28.09 Other (specify) Support Std $22.17 Spousal Support $359.08 PA Unemployment Pretax benefit Monthly Net Pay: $3,031.11 Other Income: Week Month Year (Fill in Appropriate Column) Interest Dividends Pension $1300.00 Annuity Social Security Rents Royalties Expense Account Gifts Unemployment Comp. Worker's Comp. Total TOTAL INCOME: Bi-weekly Monthly $4331.11 EXPENSES Week Month Year (Fill in Appropriate Column) Home Mortgage/ rent $705.00 Maintenance Utilities Electric $100.00 Gas Oil Telephone $50.00 Water Sewer Employment Public Transportation Lunch $250.00 Taxes Real Estate Personal Property Income Insurance Homeowners Automobile $214.00 Life Accident Health Other (Renters) Automobile Payments: Ford Expedition $624.00 Motorcycle (1) $197.00 Motorcycle (2) $206.00 Fuel $250.00 Repairs Medical Doctor Dentist Orthodontist Hospital Medicine Special Needs (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 Cell Phone $100.00 $50.00 $300.00 $60.00 $150.00 Miscellaneous Household help Child care $150.00 Papers/books/ Magazines Entertainment $25.00 Pay TV $144.00 Vacation Gifts Legal fees $100.00 Charitable Contributions Other Child support $640.00 Alimony payments Total Expenses $4315.00 PROPERTY OWNED Ownership* Description Value H W J Checking accounts Savings accounts - - - Credit Union Stocks/bonds - - Real estate 107 Doreen Drive $249,900 - X Hummelstown, PA 17036 (Sold by B'kcy Trustee 06/2006) Other - - - TOTAL INSURANCE Coverage* Company Policy No. H W C Hospital Blue Cross Other - - Medical Blue Shield - Other _ Health/Accident Disability Income Dental - - Other * H=Husband; W=Wife; J=Joint; C=Child SUPPLEMENTAL INCOME STATEMENT (a) This form is to be filled out by a person (check one); +-+ (1) who operates a business or practices a profession, or +-+ (2) who is a member of a partnership or joint venture, or +-+ (3) who is a shareholder in and is salaried by a closed corporation or similar entity. (b) Attach to this statement a copy of the following documents, relating to the partnership, joint venture, business, profession, corporation or similar entity: (1) the most recent Federal Income Tax Return, and (2) the most recent Profit and Loss Statement. (c) Name of business: Address and Telephone Number: (d) Nature of business (check one) +-+(1) partnership +-+(2) joint venture +-+(3) profession +-+(4) closed corporation +-+(5) other (e) Name of accountant, controller or other person in charge of financial records: (fl Annual income from business: (1) How often is income received? (2) Gross income per pay period: (3) Net income per pay period: (4) Specified deductions, if any: 5-2 I l BARBARA E. LONG, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW VS. NUMBER: 04-5363 CIVIL TERM RAHMAN N. LONG, Defendant: IN DIVORCE PLAINTIFF'S PRETRIAL STATEMENT 1. a) Marital assets: See Inventory. b) Non-marital assets: See Inventory. 2. Expert witnesses: None. 3. Witnesses: Rahman N. Long 4. Exhibits: 5. Income: Appraisal of Personal Property left in Marital Residence Report of Private Sale (Real Estate) Schedules D, E, & F of Defendant's Petition for Bankruptcy (See Defendant's Inventory for above exhibits) See Income and Expense Statement. 6. Expense statement: See Income and Expense Statement. 7. Pension/ Retirement benefits: See attached 2006 Military Retirement 1099-R 8. Counsel fees: $3,500.00 to Attorney for Defendant 9. Disputed personal property: None 10. Marital debt: See attached Inventory and Defendants' Schedules D, E, & F from Chapter Seven Bankruptcy Petition 11. Proposed resolution of economic issues: Defendant retains all property currently in his possession. Spousal Support to be terminated and no alimony awarded. Plaintiff shall be the sole owner of all personal property in her possession. Plaintiff waives any and all interest she may have in Defendant's Military Retirement and Defendant waives any and all interest he may have in Plaintiffs Pension/ Retirement through her current employer. Respectfully submitted, zs-i° CHARLES E. PETRIE 3528 BRISBAN STREET HARRISBURG PA 17111 (717) 561-1939 ATTORNEY FOR DEFENDANT CERTIFICATE OF SERVICE I, Charles E. Petrie, hereby certify that a true and correct copy of the within Pretrial Statement has been served upon the following individual by first class, United States mail, postage prepaid, by depositing same at the post office in Harrisburg, Pennsylvania, on the first day of June, 2007, addressed as follows: E. ROBERT ELICKER II, ESQUIRE OFFICE OF THE DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEAS 9 NORTH HANOVER STREET CARLISLE, PA 17013 DIANE G. RADCLIFF, ESQUIRE 3448 TRINDLE ROAD CAMP HILL, PA 17011 Respectfully submitted, e! 7- /? E? CHARLES E. PETRIE ATTORNEY-AT-LAW 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Control Number RETO111491 ? CORRECTED (if checked) 12111/06 PAYER'S name, street address, city, state, and ZIP code 1 Gross distribution OMB No. 1545-0119 Distributions From r DEFENSE FINANCE AND ACCOUNTING SERVICE Pensions, Annuities, US MILITARY RETIREMENT PAY $ 12516.00 Retirement, or 2a Taxable amount Profit-Sharing PO BOX 7130 006 Plans, IRAs, LONDON KY 40742-7130 --- insurance $ 12516.00 Contracts, etc. ?-? PAYER'S Federal identification number RECIPIENT'S identification number 21b Total 1099-R 34-0727612 292-70-8311 distribution Form RECIPIENT'S name, street address, city, state, and ZIP code 4 Federal income tax withheld 7 Distribution code IIIt111111111111111'11111111111111111111111111111111111111111) RAHMAN N LONG 605379 $ 451.20 7 107 DOREEN DR 9 Your percentage of total distribution HOMMELSTOWN PA 17036-2725 10 State tax withheld Form 1099-R 11 State/Payer's state no, Copy 2 File this copy with your state, city, or local income tax return, when required. RED - - - -- nint nnfi-f? -i9nn--- Department of the Treasury - Internal Revenue Service Control Number RETO111491 CORRECTED if checked ( ) 12/11!06 PAYER'S name, street address, city, state, and ZIP code 1 Gross distribution OMB No. 1545-0119 Distributions From DEFENSE FINANCE AND ACCOUNTING SERVICE $ 1251 b 00 Pensions, Annuities, US MILITARY RETIREMENT P Y . Retirement, or A 2a Taxable amount 2006 P p PO BOX 7130 lanss , IRA LONDON KY 40742-7130 $ 12516 00 Insurance . Contracts etc PAYER'S Federal identification number RECIPIENTS identification number 2b Total , . 34-0727612 292-70-8311 distribution Form 1 Q99-R RECIPIENT'S name, street address, city, state, and ZIP code 4 Federal income tax withheld 7 Distribution code Copy B Report this income $ 451.20 7 on your Federal tax return. If this form 9 Your percentage of total distribution shows Federal RAHMAN N LONG o? ° income tax withheld In box 4 att h thi 107 DOREEN DR 10 State tax withheld 11 State/Payer's state no, , ac s copy to your return. HOMMELSTO WN PA 17036-2725 This information isb? a f i ue 1?E`I`I1 75---- --------- -0TGf2QU6 I23I2QU6-- urn s to veenu eSSe?t Re I Form I Uyy-K Department of the Treasury - Internal Revenue Service Control Number RETO111491 ? CORRECTED (if checked) 12/11/06 PAYER'S name, street address, city, state, and ZIP code 1 Gross distribution OMB No. 1545-0119 Distributions From DEFENSE FINANCE AND ACCOUNTING SERVICE Pensions, Annuities, US MILITARY RETIREMENT PAY $ 12516.00 Retirement, or PO BOX 7130 2a Taxable amount ®O6 Profit-Sharing LONDON KY 40742-7130 Plans, IRAs, $ 12516 00 Insurance . Contracts etc PAYER'S Federal identification number RECIPIENT'S identification number 2b Total . , 34-0727612 292-70-8311 distribution Form 1099-R RECIPIENT'S name, street address, city, state, and ZIP code 4 Federal income tax withheld 7 Distribution code Copy C $ 451 20 For Recipient's R d . 7 ecor s. RAHMAN N LONG 9 Your percentage of total distribution This information 107 DOREEN DR % is being furnished to the HOMMELSTOWN PA 17036-2725 10 State tax withheld 11 State/Payer's state no. Internal Revenue $ Service. Keep this copy RETIRED -- ---- 1710 2006-12312006 for your records. r 1(1114-H Department of the Treasury - Intemal Revenue Service 8311 r? ? - 'c . ?? '? , ' c34 ?t,?, , ..c .?..- ? _ W ??- -v ? ? ? ` N ?t 3?' Prepared By: Diane G. Radcliff, Esquire 3448 Trindle Road Camp Hill, PA 17011 Supreme Court ID # 32112 Phone: 717-737-0100 Fax: 717-975-0697 Email: dianeradcliff @comcast.net Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARBARA E. LONG, Plaintiff NO. 04-5363 CIVIL TERM V. CIVIL ACTION - LAW RAHMAN N. LONG IN DIVORCE Defendant INCOME AND EXPENSE STATEMENT OF BARBARA E. LONG - 1 - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARBARA E. LONG, NO. 04-5363 CIVIL TERM Plaintiff VS. CIVIL ACTION - LAW RAHMAN N. LONG, Defendant IN DIVORCE INCOME AND EXPENSE STATEMENT OF BARBARA E. LONG I verify that the facts set forth in the following Income and Expenses Form, including all attachments thereto, are true and correct to the best of my knowledge, information and belief. 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: ?O BARBARA E. LONG"'- - 1 - PART I. INCOME EMPLOYMENT INFORM'A'TION: Employer: Genco Distribution Systems Address: 100 Papercraft Park, Pittsburgh, PA 15238 Position 2"d shift supervisor Pay Period: Biweekly CALCULATION OF 2006 INCOME BASE-WON 12/17/06-?PAY, STUB DESCRIPTION BIWEEKLY MONTHLY YEARLY Total Gross Income 1,164.60 2,523.29 30,279.47 Social Security Tax (43.80) (94.90) (1,138.84) Medicare Tax (10.24) (22.20) (266.34) Federal Tax (62.40) (135.20) (1,622.35) State Tax (21.69) (46.99) (563.92) Local Tax (10.24) (22.20) (266.34) PaSUI (UC) (0.64) (1.39) (16.63) Acc Insurance (4.04) (8.75) (105.04) 401 K Retirement (35.53) (76.97) (923.68) 401 K Loan (30.68) (66.48) (797.79) EMS Tax (2.00) (4.33) (52.00) NET INCOME 943.33 21?043.88 24,526.54 - 3 - E. OTHER INCOME: DESCRIPTION MONTHLY YEARLY Interest $0.00 $0.00 Dividends $0.00 $0.00 Pensions $0.00 $0.00 Annuities $0.00 $0.00 Social Security $0.00 $0.00 Rents $0.00 $0.00 Royalties $0.00 $0.00 Expense Account $0.00 $0.00 Gifts $0.00 $0.00 Unemployment Compensation $103.75 $17245.00 Workman's Compensation $0.00 $0.00 Income Tax Refunds $0.00 $0.00 Support or Alimony $0.00 $0.00 Commissions $0.00 $0.00 Tips $0.00 $0.00 $0.00 $0.00 TOTAL OTHER INCOME $103.75 $1,245.00 -4- PART II. EXPENSES DESCRIPTION MONTHLY AMOUNT COMMENTS HOME EXPENSES: Rent $460.00 Maintenance and Repairs Electric $125.00 Varies Gas/Oil Telephone $58.00 Water X50.00 Varies Sewer/Trash EMPLOYMENT Public Transportation Lunches $125.00 TAXES: Real Estate Taxes Personal Property Taxes Per Capita /Occupation Taxes INSURANCE: Homeowners Insurance Automobile Insurance 75.28 Life Insurance Accident Insurance Se-?, pay stub Health Insurance - 5 - DESCRIPTION MONTHLY AMOI "NT COMMENTS AUTOMOBILE EXPENSES: Payments $220.00 Fuel $175.00 Maintenance and Repair $50.00 License and Registration $4.00 MEDICAL EXPENSES NOT REIMBURSED BY INSURANCE: Doctor $20.00 Optical Dental $20.00 Hospital Medicine 510.00 Special Needs/Therapy Etc. PERSONAL EXPENSES: Clothing $150.00 Food $400.00 Barber and Hair Dresser $140.00 Other Personal Expenses $30.00 CREDIT CARDS AND LOANS: Beneficial Loan $212.82 (Loan to cover joint back taxes, household furniture and child's play ground Chase Visa $100.00 Attorneys Fees Loan `',82.31 401 K Plan loan -6- DESCRIPTION MONTHLY AMOUNT COMMENTS MISCELLANEOUS EXPENSES: Household Help/Child Care Newspapers/Magazines/ Books $20.00 Entertainment $150.00 Pay TV ;49.56 Vacations $100.00 Gifts $25.00 Legal Fees $150.00 Charitable Contributions Internet $45.00 TOTAL EXPENSES $3,046.97 -7- PART III. INSURANCE INSURANCE INFORMATION COVERAGE TYPE COMPANY POLICY NO. H W Hospital TriCarePrime 292-70-8311 X X Medical TriCarePrime 292-70-8311 X X Health Accident TriCarePrime 292-70-8311 X X Disability Income Dental Vision TriCarePrime 292-70-8311 X X Other-Specify *H=Husband; W=Wife; J=Joint; C=Child Insurance is through Husband (military). Wife is obtaining figures to establish cost to her upon divorce once she is on her work policy. C X X X X -8- PART V. SUPPLEMENTAL INCOME STATEMENT [ d ] CHECK HERE IF NOT APPLICABLE (a) This form is to be filled out by a person: (1) Who operates a business or practices a profession, or (2) Who is a member of a partnership or joint venture, or (3) Who is a shareholder in and is salaried by a closed corporation or similar entity. (b) Attach to this statement a copy of the following documents relating to the partnership, joint venture, business, profession, corporation or similar entity (check block to indicsite the document is attached): (1) The most recent Federal Income Tax Return. [ ] attached (2) The most recent Profit and Loss Statement. [ ] attached (c) Name of Business: Business Address: Business Telephone: (d) Nature of I [] 1. [] 2. [] 3. [] 4. [] 5. [J 6. 3usiness (check one) Sole Proprietorship Partnership Joint Venture Professional Corporation Other (e) Name of accountant, controller or other person in charge of financial records: (f) Bu 1. 2. 3. 4. 5. siness Income: Annual income from business: How often is income received: Gross income per pay period: Net income per pay period: Specify deductions, if any: CERTIFICATE OF SERVICE I, Diane G. Radcliff, Esquire, hereby certify that on G I served a copy of the within Income and Expense Statement, by mailing same by first class mail, postage prepaid, addressed as follows: Charles E. Petrie, Esquire 3528 Brisban Street Harrisburg, PA 17111 DIANE G DCLIFF, ESQUIRE rindle Road Camp Hill, PA 17011 Supreme Court ID # 32112 Phone: (717) 737-0100 Fax: (717) 975-0697 Attorney for Plaintiff -10- C- o Cz 711 Cr1 rv -{ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARBARA E. LONG, Plaintiff V. RAHMAN N. LONG, Defendant J%TO. 04-5363 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE PLAINTIFF'S PRE-TRIAL STATEMENT DATED: (3 ?? ly Submitted, M-13?.-RAVCLIFF, ESQUIRE Trindle R ad C,an-p-*+41;? 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 Attorney for Plaintiff Plaintiff, Barbara E. Long, by her attorney, Diane G. Radcliff, Esquire files this Pre-Trial Statement. TABLE OF CONTENTS INFORMATIONAL NOTES AND CODES, RULES & SANCTIONS NOTES AND CODES 1. denotes that the entry (value) is verified by a document. 2. denotes the value of an asset or debt; 3. " *" denotes documents/information to be supplied by the designated party. 4. ">" denotes information of special interest. 5. "X" denotes an item about which a decision is required. 6. "NM" denotes non-marital property not subject to equitable distribution. 7. The values used in the various Tables herein may, in some cases, be based on estimated values. Those estimated values are subject to adjustment upon appraisal or otherwise. Any adjustment figures used in the various tables herein are for illustration purposes only and are not to be deemed a representation on the part of the Plaintiff «a to whether an adjustment should be made or the amount of the adjustment, if any is appropriate. -2- SECTION I. - BACKGROUND INFORMATION DESCRIPTION Name Maiden Name Address Date of Birth Age Place of Birth Health Status Educational Background Names and Relationship of Persons Living with Party Date Party Moved to Current Residence Date PA Residency Began Current Military Service Employer's Name and Address Occupation (Job Position) Date Employment Commenced Est. Monthly Income TABLE #1-A PARTIES HUSBAND Rahman N. Long N/A 40 Lakepoint Drive Harrisburg, I'A 17111 10/23/61 45 New York High blood pressure Unknown None Known 6/2006 1995 Retired Single Source Transportation P.O. Box 855 Des Moines, IA 50304-0855 Truck Driver Unknown $5,098/month truck driver $1,300/mo Military Retirement Total: $6,398/mo WIFE Barbara E. Long Barbara E. Baumann 1101 Bridge Street, 2"d Floor New Cumberland, PA 17070 05/05/60 47 Germany Shoulder Injury Completed 10'h grade None 10/2005 1995 N/A Genco Distribution System 10th Street Lemoyne, PA Operator leader 08/10/99 $2 523.29 Regular Employment income + $103.75 Unemployment Compensation Page 3 TABLE #1-B MARRIAGE INFORMATION DESCRIPTION INFORMATION Date of Marriage July 8, 1995 Place of Marriage Cleveland, OH Date of Separation October 23, 2004 Grounds for Divorce No Fault, Indignities and Adultery Prior Divorce Actions Between Parties None Number of this Marriage for Wife 2 Number of this Marriage for Husband 2 TABLE #1-C CHILDREN OF THIS MARRIAGE NAME AGE DATE OF SCHOOL CUSTODIAN OR BIRTH GRADE EMANCIPATION NONE N/A N/A N/A. N/A TABLE #1-D SUPPORT FOR THIS MARRIAGE DESCRIPTION INFORMATION Name of Party Paying Support/APL Husband Beneficiaries of Support/APL Wife Amount of Support/APL $678/month Allocation Wife only Agreement or Order Order Date of Agreement or Order 1/27/05 Effective Date of Order 1/24/05 Docket Number of Support Order 04-5363 Civil Term Comments: This is an order for APL : Under current incomes this amount should be $983 per month. See support calculations attached in Exhibit Section. Page 4 TABLE #1-E PRIOR MARRIAGES PARTY NUMBER DATE OF MANNER OF OF TERMINATION TERMINATION MARRIAGE Wife 1 1992 or 1993 Divorce Husband 1 1986 Divorce TABLE #1-F CHILDREN OF OTHER RELATIONSHIPS/MARRIAGES PARTY NAME OF CHILD DATE OF BIRTH AGE CUSTODIAN OR EMANCIPATION Husband Kevin Long Unknown 25 Emancipated Husband Natasha M. Long 3/26/02 5 Mother TABLE #1-G SUPPORT/ALIMONY FOR PRIOR MARRIAGES/RELATIONSHIP DESCRIPTION INFORMATION INFORMATION Name of Party Paying Support N/A N/A Beneficiaries of Support N/A N/A Allocation N/A N/A Agreement or Order N/A N/A Date of Agreement or Order N/A N/A Docket Number of Support Order N/A N/A Comments: N/A N/A Page; 5 IABLE 41-H PROCEEDINGS INFORMATION: COMPLAINT Complaint Filing Date October 25, 2004 Date of Service November 19, 2004 Manner of Service Type of Divorce Requested Acceptance of Service by Defendant's Attorney 3301(c); 3301(d); 3301(a)(6); 3301(a)(2) Economic Claims Raised Equitable Distribution; APL; Alimony; Counsel Fees and Costs ANSWER, COUNTERCLAIM AND/OR OTHER ECONOMIC PLEADINGS Type of Pleading Pl di ea ng Filing Date Type of Divorce Requested Economic Claims Raised INCOME AND EXPENSE STATEMENTS Plaintiffs I&E Statement Filing Date 5/22/05 & Concurrent with this filing Defendant's I&E Statement Filing Date 5/30/07 INVENTORIES Plaintiffs Inventory Filing Date 3/11/05 Defendant's Inventory Filing Date 5/30/07 3301 C DOCUMENTS Plaintiffs 3301(c) Affidavit Date Plaintiffs 3301(c) Affidavit Filing Date Defendant's 3301(c) Affidavit Date Defendant's 3301(c) Affidavit Filing Date Plaintiffs 3301(c) Waiver of Notice Date Plaintiffs 3301(c) Waiver Filing Date Defendant's 3301(c) Waiver of Notice Date Defendant's 3301(c) Waiver Filing Date Page, 6 TABLE #1-H PROCEEDINGS INFORMATION: 3301 D DOCUMENTS Date of In House Separation N/A Date of Physical Separation 10/23/04 In House 2 Year Separation Date N/A Physical 2 Year Separation Date 10/23/06 Defendant's 3301(d) Affidavit Date 4/12/07 Defendant's 3301(d) Affidavit Date Filing Date 4/13/07 Defendant's 3301 (D) Affidavit Service Date 4/17/07 Manner of Service of Defendant's 3301(d) Affidavit Regular mail Date of Plaintiffs Notice of Intent to Request Entry of Divorce Decree and Praecipe to Transmit Record Plaintiffs Notice to Request Entry of Divorce De :ree and Praecipe to Transmit Record Service Date Manner of Service of Plaintiffs Notice to Request Entry of Divorce Decree and 3301(d) Counter-Affidavit BIFURCATION Has the case been bifurcated? No Date of decree granting bifurcation N/A If bifurcation granted by consent or after hearing N/A PREVIOUSLY RESOLVED ISSUES Issue #1 Resolution APL -Pursuant to Order dated 1/27/05 Husband pays Wife APL un the amount of $678 per month effective 1/24/05. Issue #2 Resolution Husband previously filed bankruptcy and discharged debts in his sole name. Page 7 Barbara E. Long vs. Rahman N. Long DOM: July 8, 1995 DOS: October 2: , 2004 INCOME: Husband @ $72,000; Wife @ $30,000 Date Prepared: June 5, 2007 MARITAL ASSETS AND DEBTS The following Table #2 sets forth the listing of the marital assets and debts of the parties: L- +rA • mad ILai Hssets ana ueDiS A B C D E F G H I Ln No B. Ref Ow Description Date Net Value Net Distribution Proposed Proposed ner Calculation Value Distribution To Distribution To a - Husband Wife :S d De . 5 RE 1 0 - F 7 Doreen Drive FHummwn, elstoPA Sold N/A N/A N/A N/A 6 Comments: *This property was sold through the bankruptcy and each party received $2,298.43 represe 1/4 of the net nting proceeds. The remaining /2 the proceeds was paid to Husband' dit s cre ors . The remaining debt was discharged. Wife's creditors set forth below were not paid. IyOrl OR VEHICLES AN^,r 8 V-1 H Husband's 2004 Ford Est 37,811.72 Expedition 9 V 1 - H Best Employees FCU 11.30.044 35 956.00 loan 10 V-1 -- Net Value -- 1,855.72 1,855.72 1,855.72 11 Comments: >Purchased August/September 2004 @ loan amount. *Loan balance taken from Bankruptcy schedule D *Husband appraisal indicates that the value of this vehicle on 4.5.05 was only $27,000.00, $ 10,000 less than its purchase price, I/2 year before 12 V-2 H H b ' us and s 1990 Ford Thunderbird 4.1.054 1,000.00 1,000.00 1,000.00 13 Comments: 14 V-3 H H b ' us and s 1995 Ford Taurus 4.1.054 11,300.00 11,300.00 11,300.00 15 Comments: )P-This vehicle was secretly purchased by Husband on 8.2.04 for $1,200 and is owned jointly with Brenda Wise l 16 V-4 H Husband's 2003 Suzuki 4.1.054 7,500.00 17 V-4 H B E est mployees FCU 11.30.044 (8.f 30.05 loan 18 V-4 H N V l et a ue -- (1,080.05) (1,080.05) (1,080.05) 19 Comments: *Loan balance taken from Bankruptcy Schedule D 20 V-5 H H b d' us an s 1996 Ford Taurus Est 1,600.00 1,600.00 1,600.00 21 Comments: ?k This vehicle was secretly purchased by Husband on 1/6/03 at auction for $1 600 4 , alc Husband to supply information necessary to complete NADA valuation. Page 8 Barbara E. Long vs. Rahman N. Long DOM: July 8, 1995 DOS: October 23, 2004 INCOME: Husband @ $72,000; Wife @ $30,000 Date Prepared: June 5, 2007 TABLE #2 - Marital Assets and Debts A B C D E F G H I Ln 7BRel Ow Description Date No. Value Net Distribution Proposed Proposed No ner Calculation Value Distribution To Distribution To 22 V-6 W Wife's 2001 Ford Taurus 2.2.051 SES sold 23 V-6 R Best Employees FCU 9.30.041 loan #5523 paid 24 V-6 -- Net Value 25 Comments: * 2.2.05 KBB TIV-G @$5060 ?k Purchased March 2004; Loan co-signed by Husband. 26 CA$714 CHECKING ACCO`Ul` 27 A-1 H Husband's M&T #500 10.26.041 28 Comments: 29 A-2 H Best Employees FCU 11.1.041 #8697 regular share 30 A-2 H Best Employees FCU 11. 1.041 #8697 draft share 31 A-2 -- Net Value 32 Comments: 33 A-3 W Wife's M&T #6668 34 Comments: 35 36 Ret-1 -- Wife's Genco 401K 37 Comments: 38 39 M4 H Husband's Military Pension 11.10.041 RETIR 9.30.041 5,060.00 / , (10,282.99) (5,222.99) (5,222.99) 1TS A S? G NTs 234.41 234.41 234.41 128.14 1,243.16 / 1,371.30 131.00 (5,222.99) 1,371.30 1 1,371.30 131.00 -NT PLANS 8,283.74 8,283.74 131.00 8,283.74 MILITARV'/VA BFI TS`' TBD TBD TBD TBD 40 Comments: ,Or 12.31.03 @ $11,472.00/yr, approximately 22% or $2,523 84/yr of which is marital.d' ?k Husband to supply benefits statement as of October 2:3, 2004 & current date, and dates of service. 41 HOUSEHOLD GOODS, FUkNTSHINGS, TO(f S P1 i8,614fl,°)ti E CTS ETC. 42 HG -1 H Household Goods -- 10,000.00 10,000.00 10,000.00 43 Comments:: >-If information available see Tables #3-A & 3-B for itemization. >Husband had his property valued at substantially less than Wife's value, but did not include all of the items. >-Wife has reduced the value of Husband's items from that set forth on Table #3-A since it is obvious that she over valued all items as shown by Husband's appraisal. She reduced the value of his items by roughly the same amount as the reduction in value for her items. Page 9 Barbara E. Long vs. Rahman N. Long DOM: July 8, 1995 DOS: October 23, 2004 INCOME: Husband @ $72,000; Wife @ $30,000 Date Prepared: June 5, 2007 TABLE #2 - Marital Assets and Debts A B C D E F G H I Ln B. Ref Ow Description Date Net Value Net Distribution Proposed Proposed No ner Calculation Value Distribution To Distribution To 44 HG-2 W Household Goods -- 2,000.00 2,000.00 2,000.00 45 Comments: )0-If information available see Tables #3-A & 3-B for itemization. >Wife has reduced the value of her items from that set fort; on Table #3-B since it is obvious that she over valued all items as shown by Husband's appraisal. She reduced the value of her items by roughly the same amount as the reduction in value for husbands's items. 47 48 Total of Assets ASSET TOTALS 31,473.13 I 26,281.38 5,191.75 50 LOANS, CAEDIT'CARDSG` ,. 51 52 D-1 JT 2000 IRS debt 10.18.04 (1,823.34) (1,823.34) (1,823.34) Comments: *10.18.04 @ 1,823.34; Wife paid $1,082 towards this debt on 8.9.04. In 2004, IRS took Wife's 2002 refund @ $580 and 2003 refund @ $490 for a total of $1,070 and applied towards this debt. 53 D 2 B - W eneficial #996.7 10.18.04 (12,343.56) (12,343.56) (12 343.56) 54 , Comments: * Debt taken out to pay IRA debt which husband failed to pay and for dining room set and play gym for husband's daughter. Interest is @ 26%. )P-Balance as of 5.29.07 reduced to $5,746.14 x 2vw 56 DEBT TOTALS 57 Tot l f D bt a o e s (14,166.90) 0 00 (14 166 90 . , . ) 59 NET TOTALS 60 Ass t T t l f e o a s rom above 31,473.13 26,281.38 5,191.75 61 Less Debt Totals from Above 1 E.166.90 0.00 14 166.90 62 Net Total • Assets Minus Liabilities 17,306.23 26,281.38 (8,975.15) 64 AD JUSTMENT FOR OVERALL 50150 DIVISI ON 65 Net T l • A t o a ssets Minus Liabilities From Above 17,306.23 66 Amo t D P i i un ue art es n 50150 Division 8,653.12 8 653.12 67 Less T t l A i d , 68 o a ss gne to Parties From Above 50150 Di i i Ad 26 281.38 8.975.15 v s on justment Amount (17,628.27) 17,628.27 69 Fair Rental Value Adjustment Noted Below (12,750.00) 12,750.00 70 Final 50150 Adjustment Amount (30,378.27) 30,378.27 Page 10 Barbara E. Long vs. Rahman N. Long DOM: July 8, 1995 DOS: October 23, 2004 INCOME: Husband @ $72,000; Wife @ $30,000 Date Prepared: June 5, 2007 I AtsLt w - mantaI Assets and Debts A B C D E F G H I Ln No B. Ref Ow ner Description Date Net Value Net Distribution Calculation Value Proposed Proposed Distribution To Distribution To Husband Wife 71 ADJUSTMENT FOR OVERALL 45/55 DIYVIS ION 72 Net Total • Assets Minus Liabilities From Above 17,306.23 73 Amount Due Parties in 45/55 Division 7,787.80 9,518.43 74 Less Total Assigned to Parties From Above 26 281.38 8,975.15 75 76 45/55 Division Adjustment Amount F i R t l V (18,493.58) 18,493.58 a r en a alue Adjustment Noted Below (12,750.00) 12,750.00 77 Final 55/45 Adjustment Amount (31,243.58) 31,243.58 78 ADJUSTMENT FOR OVERALL 40/60 DIVIS ION 79 N t T l • A t e o a ssets Minus Liabilities From Above 17,306.23 80 Amount Due Parties in 40/60 Division 6,922.49 10,383.74 81 82 Less Total Assigned to Parties From Above 40/60 Di i i 26 281.38 8.975.15 83 v s on Adjustment Amount F i R t l V l (19,358.89) 19,358.89 a r en a a ue Adjustment Noted Below (12,750.00) 12,750.00 84 Final 50150 Adjustment Amount (32,108.89) 32,108.89 85 SUMMARY OF OVER-ALL ADJUSTMENTS 86 50/50 Di i i v s on Adjustment Amount (30,378.27) 30,378.27 87 88 40/55 Division Adjustment Amount 40/60 Di i i (31,243.58) 31,243.58 v s on Adjustment Amount (32,108.89) 32,108.89 NOTE: HOUSEHOLD GOODS Wife's values used for household goods has been reduced from the estimated value set forth on Tables #3- A and #3-B. NOTE: MILITARY RETIREMENT Wife should be awarded a portion of Husband's miliary retirement based upon the marital =coverture fraction. Since only a small portion of Husband's retirement is marital the rest should be used to fashion an alimony ward in favor of wife. NOTE - FAIR RENTAL VALUE CLAIM The above me u es i e s c aim or air rental value of *lie prior marital home which Husband occupied from 10/23/2004 to 6/1/06, a period of 19 months. From /112005 through 5/31/06, a period of 17 months he paid nothing for the mortgage, taxes or insurance. Wife estimates the fair rental value at $1500 per month for 17 months for a total of $25,500, half of which or $12,750 is owed to her. 50% of the total fair rental value has been included as part of the adjustment amounts set forth above. Page 11 SECTION III. LISTING OF HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY The following Tables #3-A and # 3-B set forth the household goods and contents and other personal property of the parties: , TABLE #3-A HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY IN HUSBAND'S POSSESSION NO DESCRIPTION OWNER POSSESSOR DATE OF VALUE VALUE BASIS FOR EXCLUSION IF NON- MARITAL 1 Washer/dryer H & W Husband 1,050.00 -- Comments: Purchased in 2002 for $2,000 2 2 Refrigerators H & W Husband 1,012.00 -- Comments: 1 purchased in 2002 for approximately $1,900.00; 1 purchased in 2001 for $125 3 King size bed & headboard H & W Husband 901.00 -- Comments: Purchased in 2002 for $1802.00. - 4 165" TV F H & W Husband 1,000.00 -- _ Comments: Purchased in 1998 for $1,050 from brother. TV was new at the time and had a value of $3000.. 5 Large stereo set including VCR, DVD & premium speakers H & W Husband 700.00 -- Comments: Purchased prior to 2000 for $1,500 6 3 gym sets, barbells, AB Roller etc. H & W Husband 400.00 -- Comments: Purchased in 2004 for approximately $800.00. 7 Dining room, china set and 2 chairs H & W Husband 1,000.00 -- Comments: 8 Coffee table H & W Husband 25.00 -- Comments: 'Note: Exclusions from marital property include pr, perty acquired before marriage, property acquired after separation, or property acquired during marriage by way of gift or inheritance from third party not a spouse. For gifts and inheritance also specify the source person. 2The value of each item has been estimated by Plaintiff unless otherwsise noted. Page 12 HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY IN HUSBAND'S POSSESSION NO DESCRIPTION OWNER POSSESSOR DATE VALUE BASIS FOR OF EXCLUSION IF NON- VALUE MARITAL 9 Large spider lamp H & W Husband 25.00 -- Comments: Purchased in 1998 for $100.00 10 Table lamp H & W Husband 5.00 -- Comments: Purchased in 1998 for $20.00 11 Outdoor porch furniture H & W Husby id 450.00 Gift to Wife from u., u -, -- Comments: Purchased in 2004 for $900.00. µIµ 12 Twin size bed H & W T-Husband 75.00 -- Comments: Estimated original price of $150.00. 13 Dresser with mirror H & W Husband 75.00 -- Comments: Purchased in 1999 for $300.00. 14 CD collection H & W Husband I 1 1,000.00 -- Comments: Claimed 99 CD's @ $2,000.00 in 1999. 15 Liquor collection H & W Husband 150.00 -- Comments: 6 gallons @ estimated $25/gallon. 16 Gun H & W Husband 150.00 T -- Comments: Purchased in 1998 for $150; Husband used Wife's money for this purchase. 17 Kitchenware H & W Husband 65.00 -- Comments: 18 TV stand H & W Husband 10.00 -- Comments: Bought used in 2000 for $25.00. 19 Child's bedroom set H & W Husband F 150.00 -- Comments: 20 Inside plants on patio H & W Husband 60.00 -- Comments: 21 3 BBQ's H & W Husband 200.00 -- Comments: Husband gave 1 of the 3 BBQ to nis mistress which is now at her apartment. 22 Child's playground set H & W Husband F 450.00 -- Comments: Purchased in 2004 for $900.00. Page 13 TABLE #3-A HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY IN HUSBAND'S POSSESSION NO DESCRIPTION OWNER POSSESSOR DATE OF VALUE VALUE BASIS FOR EXCLUSION IF NON- MARITAL 23 Computer table H & W Husband ?? -- Comments: Purchased used in 1999 for $20.00. 24 Husband's clothes H & W Husband 1,000.00 -- Comments: 25 Children's clothes H & W Husband 600.00 -- Comments: 26 Child's toys (indoors and outdoors) H & W Husband 470.00 -- %-villillumb. inswe toys esumatea at outdoor toys estimated at $220.00. All outdoor toys were bought new in 2004 for $440.00. 27 Curtains H & W Husband 400.00 -- Comments: 28 Child's bedding (hand H & W Husband 80 00 made) . T -- Comments: 29 Air Conditioner H & W Husband 170.00 -- Comments: Purchased in 1999 for $340.00; never used 30 Dog cages H & W Husband 250.00 -- Comments: Purchased in 1996 for $645.00 31 Dresser to wife's H & W Husband 25 00 bedroom set . -- Comments: 32 Dog hairdryer H & W Husband 75.00 -- Comments: Purchased in 2003 for $150.00. 33 Household tools H & W Husband 300.00 -- Comments: 34 Car tools H & W Husband 5,000.00 -- Comments: Value is rough guess estimate and items need to be professio?oally valued 35 Turkey fryer H & W Husband 50.00 -- Comments: Purchased in 2004 for $100.00. Page 14 HOUSEHOLD GOODS AND CONTETABLE #3-A NTS AND OTHER PERSONAL PROPERTY IN HUSBAND'S POSSESSION NO DESCRIPTION OWNER POSSESSOR DATE OF VALUE VALUE BASIS FOR EXCLUSION IF NON- MARITAL 36 Suitcases H & W Husband 150.00 -- Comments: Purchased in 2004 for $300.00. 37 Collection of chess sets H & W Husband 200.00 -- Comments: 38 12 CD disc player 11 & W Husband 100.00 -- Comments: Purchased in 1997 for $370.00; hardly used 39 Table power saw & 2 power drills H & W Husband 150.00 -- Comments: Purchased in 2003/2004 for $300.00. 40 Riding lawn mower H & W Husband 500.00 -- Comments: Purchased in 2002 for $1,000.00. 41 Snow blower H & W lusband- F -1 301.00 -- Comments: Purchased in 2002 for $602.00. 42 2 power lawn mowers H & W Husband 500.00 -- Comments: Purchased in 2004. Value is rough guess estimate and items need to be professionally valued 43 Leaf blower H & W Husband 100.00 -- Comments: Purchased in 2004. Value is rougn guess estimate and items need to be professionally valued 44 Air compressor for auto tires H & W Husband 100.00 -- Comments: Purchased in 2004. Value is rough guess estimate and items need to be professionally valued 45 Power sprayer H & W Husband 200.00 -- Comments: Value is rough guess estimate and items need to be professionally valued 46 2 auto tool cabinets H & W Husband 1,000.00 -- Comments: Value is rough guess estimate and items need to be professionally valued 47 Mountain bike H & W Husband 120.00 -- Comments: Purchased in 2004 for $240.00. 48 4 Thunderbird wheel rims H & W Husband 300.00 - Purchased in 1998 for $1,000.00. Page 15 HOUSEHOLD GOODS AND CONTENTS #AND OTHER PERSONAL IN HUSBAND'S POSSESSION PROPERTY NO DESCRIPTION OWNER POSSESSOR DATE VALUE BASIS FOR OF EXCLUSION IF NON- VALUE MARITAL 49 Exhaust pipe for H & W Husband 450.00 motorcycle -- Comments: Purchased in 2004 for $900. 50 Couch H & W Husband 300.00 -- Comments: Wife has matching love seat and chair. All three pieces purchased in 2004 for $1,200.00. 51 Coffee table H & W Husband 25.00 -- Comments: Wife has matching end tables. Three pieces purchased used in 2002 for $100.00. 52 New Tire for Wife's car W Husband 75.00 under Porch [-7 -- Comments: Purchased by wife in 2003 for $150.00. Wife wants it back. TOTAL HUSBAND'S POSSESSION 21,944.00 Note: Total reduced to $10,000 on Table 2 Page 16 TABLE #3-B HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY IN WIFE'S POSSESSION NO DESCRIPTION OWNER POSSESSOR DATE VALUE BASIS FOR OF EXCLUSION IF NON- VALUE MARITAL 1 Lazy Boy chair & H & W Wife 300.00 loveseat -- Comments: Husband has matching couch. Original price for all three pi-ces in 2004 was approximately $1,200.00. -f F- -T- 2 2 end tables H & W Wife 25.00 -- Comments: Husband has matching coffee table. In 2002 three „ipnpc„cP.l .-- e 1 nn nn 3 2 night stands H & W Wife 400.00 -- Comments: Purchased in 2004 for $800.00. 4 3 artificial plants H & W Wife 10.00 -- Comments: Purchased at a flea market for $15.00. 5 2 - 21" tv's H & W Wife 100.00 -- Comments: These are old sets; $100 combined value. 6 2 - VCR's H & W Wife 50.00 -- Comments: These are old VCR's; $50 combined value. 7 Small stereo H & W Wife 40.00 -- Comments: 8 3 small table lamps H & W Wife 15.00 -- Comments: Purchased in 2004 for $30.00. 9 2 tall lamps H & W Wife 0.00 -- Comments: 1 is broken; 1 purchased after separation. 10 Doll collection H & W Wife 200.00 -- Comments: 11 Various knick-knacks H & W Wife 100.00 -- Comments: 12 Dining table & chairs H & W Wife 1,000.00 -- Comments: Husband has matching china cabinet and 2 chairs. Entire set purchased in 2004 for $4,000.00. 13 Microwave H & W Wife 25.00 -- Comments: Purchased in 2000 for $50.00. 14 Coffee machine H & W Wife 10.00 -- Comments: Page 17 TABLE #3-B HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY IN WIFE'S POSSESSION NO DESCRIPTION OWNER POSSESSOR DATE OF VALUE VALUE BASIS FOR EXCLUSION IF NON- MARITAL 15 Portable electric grill H & W Wife 50.00 -- Comments: Purchased in 2002 for $100.00. 16 Cutting knife set H & W Wife 20.00 -- Comments: 17 Various common cooking utensils H & W Wife 100.00 -- Comments: 18 Everyday dining utensils H & W Wife 20.00 -- Comments: 19 Various toiletries H & W Wife 20.00 -- 1.. V111111G1115. 20 Bedroom set H & W Wife 200.00 -- Comments: Purchased in 1999 for $427.00. Husband has dresser. 21 Corner stand H & W Wife 2.00 -- Comments: Purchased at flea market. 22 Telephone set H & W Wife 35.00 -- Comments: Purchased in 2003 for $70 23 Breakfast table H & W Wife 25.00 -- Comments: Husband has the 2 matching chairs. Purchased 3 piece set in 2002 for $99.00. 24 2 sewing machines H & W Wife : T7 F 75.00 -- Comments: 25 Fabric and sewing H & W Wife 250.00 accessories -- Comments: 26 Computer H & W Wife 400.00 -- Comments: Purchased in 2004 for $800.00. 27 Vacuum cleaner H & W Wife 100.00 -- Comments: Purchased used in 1999 for $400.00. 28 File cabinet H & W Wife 10.00 -- Comments: Used; estimated value of $10 Page 18 TABLE #3-B HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY IN WIFE'S POSSESSION NO DESCRIPTION OWNER POSSESSJR DATE OF VALUE VALUE BASIS FOR EXCLUSION IF NON- MARITAL 29 Drapes/curtains li & W Wife I 100.00 I -- - Comments: Most were hand made by Wife. Value is based on price of fabric. 30 Clothing H & W Wife 300.00 -- Comments: 31 Jewelry - bracelet & earrings H & W Wife 150.00 -- Comments: Bracelet was purchased for $150.00; now valued at $50.00. TOTAL WIFE'S POSSESSION 4,132.00 Note: Total reduced to $2,000 on Table 2. Page 19 SECTION IV. NON-MARITAL ASSETS Ar+iD DEBTS 3Note: Exclusions from marital property include property acquired before marriage, property acquired after separation, or property acquired during marriage by way of gift or inheritance from third party not a spouse. For gifts and inheritance also specify the source person. a The value of each item has been estimated by Plaintiff unless otherwise noted. Page 20 The following Table #4 sets forth the non-marital assets and debts of the parties: 3,4 SECTION V. PENSIONS AND RETIREMENT BENEFITS Page 21 The following Table #5 sets forth the listing of the pensions and retirement plans of the parties: SECTION VI. INCOME AND EXPENSES The following Table #6-A sets forth the incomes of the parties: TABLE #6-A INCOME OF THE PARTIES MONTHLY INCOME DESCRIPTION HUSBAND WIFE Regular Employment $5,098.00 2,523.29 Retirement in pay status $1,300.00 -- Unemployment Compensation -- 103.75 Total $6,398.00 2,627.04 Notes: Pursuant to Order dated 1/27/05 Husband pays wife APL up., the amount of $678 per month effective 1 /24/05 . Husband's income is not verified and is based solely on his representations in his Income and Expense Statement. The following Table #6-B sets forth the monthly expe; ses of the parties taken from their respective Income and Expense Statements: TABLE #6-B MONTHLY EXPENSES OF THE PARTIES DESCRIPTION HUSBAND WIFE Total Monthly Expenses Reported on Income & Expense Statement $4,315.00 $3,046.97 Page 22 SECTION VII. COUNSEL FEES The following Table #7 sets forth the listing of the counsel fees and expenses incurred by Plaintiff if a claim has been made for counsel fees and costs: TABLE #7 COUNSEL FEES AND COSTS DESCRIPTION DATES, BILLS AND CHARGES Dates Services Were Rendered 10/19/2004 to 5/29/07 Hourly Rate $200.00 Costs At Cost Total Amount of Fees and Costs Claimed to Date of this Pre-Trial Statement $5,018.10 Anticipated Fees and Costs $2,000 to $3,000 Itemization of Services Rendered See itemized billing statement attached in Exhibit Section Page 23 SECTION VIII. EXPERT WITNESSES The following Table #8 sets forth the listing of the experts who the party intends to call to testify in this case: TABLE #8 EXPERT WITNESSES NAME SUBJECT OF REPORT ATTACHED REPORT TO BE TESTIMONY SUPPLIED Experts who prepared any report To be determined Report is attached if and If not currently referenced in the Proposed Exhibits to extent such report is available Report to be in Section XI and XII. ** referenced in Exhibit , supplied as soon as Section. available "Additional experts who may be called to testify are not known at this time. Plaintiff reserves the right to call additional expert witnesses upon nroper notification to the other party once those expert witnesses are identified and retained. Page 24 SECTION IX. OTHER WITNESSES The following Table #9 sets forth the listing of the anticipated witnesses other than experts who will be called to testify in this case: TABLE #9 LAY WITNESSES NAME SUBJECT OF TESTIMONY Barbara Long History of the marriage; Identification and valuation of marital assets and debts; Other relevant testimony relating to the factc;'s set forth in the divorce code Rahman N. Long History of the marriage; Identification and valuation of marital assets and debts; Other relevant testimony relating to the factors set forth in the divorce code "Additional witnesses who may be called to testify are not known at this time. Plaintiff reserves the right to call additional witnesses upon proper notification to the other party once those witnesses are identified and agree to testify. Page 25 SECTION XI. PROPOSED RESOLUTION The following is Plaintiffs proposed resolution of the issues presented in this case: A. DIVORCE: A No-fault Divorce Decree should be entered under either section 3301c or 3301d. B. ALIMONY PENDENTE LITE: N/A. Wife has already been awarded APL, and no additional award is necessary. C. ALIMONY: Wife's claim for alimony should be granted. Wife should be awarded alimony in the amount of $983.00 per month for an indefinite period of time, modifiable based on a change in circumstances. D. COUNSEL FEES AND COSTS: Wife's claim for counsel fees and costs should be granted. Wife should be awarded counsel fees and costs in the amount of $6,000.00. E. EQUITABLE DISTRIBUTION: The parties' marital assets and debts should be divided and distributed 60% to Wife and 40% to Husband and in accordance with the schedule set forth as follows: Page 26 Barbara E. Long vs. Rahman N. Long A B C D G H I No B. Ref Owner Description Net Distribution Distribution To Distribution To 4 5 V-1 H Husband's 2004 Ford Expedition Net Value 6 V-2 H Husband's 1990 Ford Thunderbird 7 V-3 H Husband's 1995 Ford Taurus 8 V-4 H Husband's 2003 Suzuki Net Value 9 V-5 H Husband's 1996 Ford Taurus 10 V-6 -- Wife's 2001 Ford Taurus Net Value 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 337 A-1 H Husband's M&T #500 A-2 -- Best Employees FCU #8697 Net Value - A-3 W Wife's M&T #6668 Ret-1 -- Wife's Genco 401K M-1 H Husband's Military Pension HG-1 H Household Goods HG-2 W Household Goods Total of Assets LOANS, CREDIT' , M2D- JT 2000 IRS debt w Beneficial #996-7 Total of Debts NET TOTALS Asset Totals from above Less Debt Totals from Above Net Total • Assets Minus Liabilities ADJUSTMENT F( Net Total • Assets Minus Liabilities From Above Amount Due Parties in 40/60 Division Less Total Assigned to Parties From Above 40/60 Division Adjustment Amount Fair Rental Value Adjustment Noted Below Final 60/40 Adjustment Amount 0.00 24,425.66 0.00 24,425.66 6,180.20 24 425.66 (18,245.46) (12,750.00) (5,222.99) 131.00 8,283.74 TBD 2,000.00 5,191.75 (1,823.34) (12,343.56) (14,166.90) 5,191.75 14 166.90 (8,975.15) 9,270.31 8,975.15 18,245.46 12,750.00 30,995.46 NOTE: MILITARY RETIREMENT Wife should be awarded 60% of the marital portion of Husband's miliary retirement using the marital coverture fraction. Since only a small portion of HusbanO's retirement is marital, that retirement has also been considered in fashioning Wife's alimony award.. NOTE - FAIR RENTAL VALUE CLAIM The above includes Wife's claim for fair rental value of the prior marital home which Husband occupied 1,855.72 1,851.72 1,00(1.00 1,000.00 - 11,300.00 11,300.00 (1,080.05) (1,080.05) 1,600.00 1,600.00 (5,222.99) 234.41 234.41 1,371.30 1,371.30 131.00 8,283.74 TBD TBD 10,000.00 10,000.00 2,000.00 29,617.41 24,425.66 W WO 0-1-0- _ wo I (1,823.34) (12,343.56) (14,166.90) 29,617.41 14 166.90 15,450.51 15,450.51 Page 27 from 10/23/2004 to 6/1/06, a period of 19 months. From 1 /1/2005 through 5/31/06, a period of 17 months he paid nothing for the mortgage, taxes or insurance. Wife estimates the fair rental value at $1,500 per month for 17 months for a total of $25,500, half of which or $12,750 is owed to her. 50% of this fair rental value has been included as part of the adjustment amount set forth above Page 28 SECTION XII. PROPOSED EXHIBITS The following Table #11 sets forth Plaintiff s listing the proposed exhibits to be submitted at the hearing in this case. Exhibits are being supplied to Defendant only as the Divorce Master has requested that they not be filed with this statement. s TABLE #11 LISTING OF EXHIBITS NO. DESCRIPTION SUPPLIED TO BE SUPPLIED 1 Wife's Income and Expense Statement X 2 Wife's Pay Stub X X 3 Wife's 2006 Federal and State Income Tax Returns X X 4 Wife's Health Insurance Cost document X 5 Support Order @2/2005 & APL Order @ 11/25/04 X 6 Support Calculations X 7 Wife's Attorneys Fees Statement X X 8 Husband's Bankruptcy Petition @ 7/22/2005 X 9 Bankruptcy Real Estate Private Sale Proceeds Statement X 10 Mortgage Foreclosure Documents X 11 Best Employees FCU Vehicle Loan Statement @ 11/1/2004 X 12 Purchase Documents for Husband's 1995 Ford Taurus @ 8/2/2004 X 13 Purchase Documents for Husband's 1996 Ford Taurus @ 1/6/2003 X 14 KBB Valuation for Wife's 2001 Ford Taurus @ 2/2/2005 X 15 Best Employees FCU Statement for the loan Wife's 2001 Ford Taurus @ 9/30/2004 X 16 Statement for Husband's M&T Account #500 @ 10/2004 X 17 Statement for Husband's Best Employees FCU Account #8697 @ 1 l /2004 X 18 Statement for Wife's M&T Account # 6668 @ 11/2004 X 19 Wife's 401 K Statement @ 9/30/2004 X 5Plaintiff'reserves the right to submit additional exhibits upon proper notification to the other party. Page 29 TABLE #11 LISTING OF EXHIBITS NO. DESCRIPTION SUPPLIED TO BE SUPPLIED 20 Wife's 401K Loan Statement @ 10/29/2004 X 21 Husband's Military Retirement documents X 22 Husband's Bankruptcy Personal Property Appraisal @ 4/1/2005 X 23 Wife's 2000 Federal Income Tax Debt Documents X 24 Wife's Beneficial Loan Statement Account #996-7 @10/18/2004 X Page 30 CERTIFICATE OF SERVICE I, Diane G. Radcliff, Esquire, hereby certify that on , I served a copy of the within Pre-Trial Statement upon Defendant's Attorney by mailin Wcoy esame by first class mail, postage prepaid, addressed as follows: Charles E. Petrie, Esquire 3528 Brisban Street Harrisburg, PA 17111 I, Diane G. Radcliff, Esquire, also certify that on _?J( j 167 , I served a copy of the within Pre- Trial Statement, upon the Divorce Master by deliverin a copy of the same to his office addressed as follows: E. Robert Elicker, II, Esquire Cumberland County Divorce Master's Office 9 North Hanover Street Carlisle, PA 17013 Page 31 Camp Hill, PA 17011 Srpreme Court ID # 32112 Phone: (717) 737-0100 Fax: (717) 975-0697 Attorney for Plaintiff (:'l cl c -A r CJ 1 :.? BARBARA E. LONG, Plaintiff VS. RAHMAN N. LONG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04 - 5363 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this 74 day of j 2008, counsel and the parties having entered into an agreement and stipulation resolving the economic issues on February 7, 2008, the date set for a Master's hearing, the agreement and stipulation having been transcribed, the appointment of the Master is vacated and counsel can conclude the proceedings by the filing of a praecipe to transmit the record with the affidavits of consent of the parties so that a final decree in divorce can be entered. BY THE COURT, cc: /iiane G. Radcliff orney for Plaintiff arles E. Petrie //Attorney for Defendant >- E C?) >- I- 1 UJ C) 03 LLILI- ...J LIJ vL+, ._.-. fr © CCG".1 _? C ? ?Mr r BARBARA E. LONG, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 04 - 5363 CIVIL RAHMAN N. LONG, Defendant IN DIVORCE THE MASTER: Today is Thursday, February 7, 2008. This is the date set for a hearing on the factor of marital misconduct as that factor may have affected wife's alimony claim. Present in the hearing room are the Plaintiff, Barbara E. Long, and her counsel Diane G. Radcliff, and the Defendant, Rahman N. Long, and his counsel Charles E. Petrie. This action was commenced by the filing of a complaint in divorce on October 25, 2004. The complaint raised grounds for divorce of irretrievable breakdown of the marriage, indignities and adultery. However, counsel and the parties have agreed that the divorce will conclude under the no-fault provisions of the Domestic Relations Code and will provide the Master today, before they leave, affidavits of consent and waivers of notice of intention to request entry of divorce decree. Said affidavits and waivers will be filed by the Master's office with the Prothonotary's office. The divorce can, therefore, conclude under Section 3301(c) of the Domestic Relations Code. The complaint also raised economic claims of equitable distribution, alimony, alimony pendente lite and 1 counsel fees and costs and expenses. The Master has been advised that the parties have negotiated a comprehensive settlement this morning so we do not need to have a hearing on the marital misconduct issues. The settlement that counsel and the parties have reached will resolve all claims raised in the action. An agreement is going to be placed on the record in the presence of the parties. The agreement as placed on the record will be considered the substantive agreement of the parties, not subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. The parties and counsel are going to return later this morning to review the draft of the agreement, make any correction of typographical errors as required, and then affix their signatures affirming the terms of settlement as stated on the record. It is noted, however, that when the parties leave the hearing room today, even though there is no subsequent signing of the agreement affirming the settlement, the parties are bound by the terms of the agreement as stated on the record. The parties were married July 8, 1995, and separated October 23, 2004. There are no children of this marriage. Upon receipt by the Master of a the completed agreement, the Master will prepare an order vacating his 2 appointment and counsel can then file a praecipe transmitting the record to the Court requesting a final decree in divorce. Ms. Radcliff. MS. RADCLIFF: (Whereupon, Joint Exhibit No. 1 was marked for identification and admitted into the record.) 1. The parties marital assets with the exception of husband's military retirement shall be divided in accordance with Joint Exhibit No. 1, with wife receiving the assets and paying the debts that are set forth in Column "G", entitled "distribution to wife" of that exhibit, and husband receiving the assets and paying any debts that are set forth in Column "F", entitled "distribution to husband". 2. With respect to husband's military pension, commencing with the date of this agreement, wife shall receive an amount equal to the percentage that is arrived at by dividing $250.00 by the gross monthly benefit together with any cost of living adjustment or other military adjustments accruing hereafter. To effectuate that distribution to wife, a Domestic Relations Order shall be prepaid by wife's counsel and submitted to husband's counsel for approval and then submitted to the Court for approval. Pending the approval of the Domestic Relations Order by the military and commencement of the benefits directly by the military to the wife, the percentage payment to wife shall be paid to her in the form of alimony pendente lite/alimony payable through the Domestic Relations Office as a temporary additional part of the alimony order hereafter provided in the present amount of $250.00 per month. When wife receives her first payment of the $250.00 from the military, that portion of the alimony shall terminate and she shall be paid her share of the pension through the Domestic Relations Order. Counsel for the parties shall communicate directly with the Domestic Relations Office to advise them when that payment commences. 3. Commencing with the date February 7, 2008, the spousal support order being paid in the Cumberland County Domestic Relations action, docketed to No. 04 - 5363, PACES No. 083107080 shall terminate. Commencing with February 7, 2008, husband shall pay wife the amount of $900.00 per 3 month in alimony pendente lite which shall convert automatically into an order for alimony once the divorce decree is entered. The alimony shall continue for an indefinite period of time and shall be modifiable or terminable in accordance with the Divorce Code, Section 3301(e). The alimony will also terminate in the event of wife's cohabitation with a person of the opposite sex or in the event of wife's remarriage or the death of either party. The payment of alimony shall be made pursuant to an order to be entered in the Domestic Relations Office and shall be paid through that office and husband's wages shall be attached therefore. 4. The parties waive any and all other claims that they may have against each other including but not limited to any claims for the payment of counsel fees. 5. There are no outstanding issues with regard to household tangible personal property, all items of personal property having been resolved between the parties, each party keeping the property in his or her possession. 6. There no is debt other than as shown on Joint Exhibit No. 1 that the parties know about that existed that either party may be liable for in the future. 7. Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship including without limitation, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate. Each will at the request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interest, rights, and claims. MS. RADCLIFF: Barbara, you've heard me recite my understanding of the terms that the two of you have agreed to. Did you understand everything that I said? MS. LONG: No. 4 THE MASTER: Let's go off the record. We are going to go off the record so Ms. Radcliff can discuss the last paragraph, which she recited on the record, with her client. (A discussion was held off the record.) MS. RADCLIFF: Back on the record. Now, with the explanation that we gave you off the record of what estate rights were, do you now understand everything that I said on the record pertaining to the agreement? MS. LONG: Yes. MS. RADCLIFF: And is that your agreement that you are willing to sign? MS. LONG: Yes. MS. RADCLIFF: And you are agreeing to it even without signing it; is that correct? MS. LONG: Yes. MS. RADCLIFF: Do you have any questions about anything that was said? MS. LONG: Not at this moment. MS. RADCLIFF: You are not under the influence of any drugs or alcohol? MS. LONG: No. MS. RADCLIFF: And you are competent to enter into this agreement? MS. LONG: Yes. 5 THE MASTER: Mr. Petrie. MR. PETRIE: Mr. Long you've been present in the hearing room in the Cumberland County Divorce Master's Office for the last 15 - 20 minutes or so? MR. LONG: Yes. MR. PETRIE: And you have heard the three of us discuss and prepare and present to the court reporter the outline of the terms of an agreement that resolves all of the marital issues between you and your wife; is that right? MR. LONG: Yes. MR. PETRIE: And you heard each and every one of those terms; is that correct? MR. LONG: Yes. MR. PETRIE: And you understand all of those terms? MR. LONG: Yes. MR. PETRIE: Do you have any questions at this point for me or the Divorce Master? MR. LONG: None. MR. PETRIE: Are you in agreement with those terms? MR. LONG: Yes, I am. MR. PETRIE: And are prepared to sign a written statement setting forth all of those terms? MR. LONG: Yes. 6 MR. PETRIE: And are you at this time under the influence of any intoxicating beverages or controlled substances that would affect your ability to understand any of this? MR. LONG: No. MR. PETRIE: And you are fully competent? MR. LONG: Yes. MR. PETRIE: And understanding all of that, are you in agreement with all of the terms of this? MR. LONG: Yes. THE MASTER: Thank you very much. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations Code. DATE: iff Charles E. Petrie Attorney for Defendant -71 /0,1? Aar ara E. ng 4Wm L7 7 WITNESS: Barbara E. Long vs. Rahman N. Long DOM: July 8, 1995 DOS: October 23, 2004 INCOME: Husband @ $72,000; Wife @ $30,000 Date Prepared: June 13, 2007 Barbara E. Long vs. Rahman N. Long PROPOSED DISTRIBUTION SCHEDULE - WITH DEBTS CONSIDERED A B D E F G Ln No B. Ref Ow Description Net Distribution Distribution To Distribution To Wife nor Valu Husband 4 ASSETS 5 RE-1 JT Proceeds from sale of marital home 4,596.86 2,298.43 2,298.43 6 V-1 H Husband's 2004 Ford Expedition Net Value 0.00 0.00 7 V-2 H Husband's 1990 Ford Thunderbird 1,000.00 1,000.00 8 V-3 H Husband's 1995 Ford Taurus 9 V-4 H Husband's 2003 Suzuki Net Value 0.00 0.00 10 V-5 H Husband's 1996 Ford Taurus 1 1 V-6 -- Wife's 2001 Ford Taurus Net Value 0.00 0.00 12 A-1 H Husband's M&T #500 234.41 234.41 13 A-2 -- Best Employees FCU #8697 Net Value 1,371.30 1,371.30 14 A-3 W Wife's M&T #6668 131.00 131.00 15 Ret-1 -- Wife's Genco 401 K 8,283.74 8,283.74 16 M-1 H Husband's Military Pension TBD TBD TBD 17 HG-1 H Household Goods 7,533.00 7,533.00 18 HG-2 W Household Goods 2,000.00 2,000.00 19 Total of Assets 20,553.45 10,138.71 10,414.74 20 LOANS, CREDIT CARDS AND OTHER DEBTS 21 D-1 JT 2000 IRS debt (1,823.34) (1,823.34) 22 D-2 W Beneficial #996-7 (12,343.56) (12,343.56) 23 Total of Debts (14,166.90) 0.00 (14,166.90) 24 NET TOTALS 25 Asset Totals from above 20,553.45 10,138.71 10,414.74 26 Less Debt Totals from Above (14,166.90) 0.00 04,166.901 27 Net Total • Assets Minus Liabilities 6,386.55 10,138.71 (3,752.16) EXHIBIT i 04-5363 CIVIL ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania 0Original Order/Notice Amended Order/Notice Co./City/Dirt. of CUMBERLAND 0 Date of Order/Notice 02/08/08 150106938 1052 S 2004 O Terminate Order/Notice Case Number (See Addendum for case summary) Employer/VVithholder's Federal EIN Number RE: LONG, RAHMAN N. Employee/Obligor's Name (Last, First, MI) 292-70-8311 Employee/Obligor's Social Security Number 1236100962 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) SINGLE SOURCE TRANSPORTATION PO BOX 855 DES MOINES IA 50304-0855 Custodial Parent's Name (Last, First, MI) See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 1, 150.00 per month in current support $ o. oo per month in past-due support Arrears 12 weeks or greater? Oyes ® no $ 0.00 per month in current and past-due medical support $ 0.00 per month for genetic test costs $ o . o0 per month in other (specify) for a total of $ 1,150.00 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: $ 265,38 per weekly pay period. $ 530.77 oer biweekly pay period (every two weeks). $ 575. oo per semimonthly pay period (twice a month). $ 1, 150. 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 required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAMEAND 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: FEB 11 Z008 DRO: R. J. SHADDAY Service Type M BY THE COURT: EDWARD E. GUIDO, JUDGE Form EN-028 Rev. 1 OMB No.: 0970-0154 Worker ID $IATT 1xf500x 12.+ 52•: 265-• 38 * 1,1 5Q. x 12•+ 26•= 53Q•77* ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If hecked you are required to provide a copy of this form to your mployee. If your employee works in a state that is dierent from the state that issued this order, a copy must be provi?ed to your employee even if the box is not checked. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3.* Reporting the Paydate/Date of Withholding. You inust report the paydateldate of withholding when sendilig, tile payment. TI le paydate/date of withholding is the date on which aniount was withheld from the employee's wages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 7307219920 EMPLOYEE'S/OBLIGOR'S NAME: LONG, RAHMAN N. EMPLOYEE'S CASE IDENTIFIER: 1236100962 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act 0 5 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Submitted By: If you or your employee/obligor have any questions, DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 Service Type m by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 OMB No.: 0970-0154 Form EN-028 Rev. 1 Worker ID $IATT C? c-a F-q ? `- _ .. C.JW ? o Tl C-0 Co < 0 FEB-06-2008 22:30 DIANE RADCLIFF ?1? 9?5 069? P.01i04 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARBARA E. LONG, V. RAHMAN N. LONG, Plaintiff . Defendant NO. 04.5363 CIVIL ACTION - LAW DIVORCE AFFIDAVIT F CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 25, 2004. 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. 1 consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: ()-?2 _ 073 BARBARA E. ONG Co FEB-06-2008 22:30 DIANE RADCLIFF 717 975 0697 P.02i04 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARBARA E. LONG, V. RAHMAN N. LONG, Plaintiff Defendant NO. 04-5363 CIVIL ACTION - LAW DIVORCE 1. 1 consent to the entry of a final decree in divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Dated: - -D c? BARBARA E. LONG -= r lwo W CJ'i --? FEB-06-2008 22:31 DIANE RADCLIFF 717 975 0697 P.03i04 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARBARA E. LONG, V. RAHMAN N. LONG, Plaintiff Defendant NO. 04-5363 CIVIL ACTION - LAW DIVORCE AFFIDAVIT OF C NSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 25, 2004. 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 in Divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: KAMMAWK-LONG T ? om t yl co " yD r lye I L -C ; FEB-06-2008 22:31 DIANE RADCLIFF 717 975 0697 P.04i04 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARBARA E. LONG, V. RAHMAN N. LONG, Plaintiff Defendant NO. 04.5363 CIVIL ACTION - LAW DIVORCE 1. I consent to the entry of a final decree in divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. 1-7 Dated: C;7 TOTAL P.04 C fir rt j 'r7 1 tJ y HAROLD S. IRWIN,111, ESQUIRE SUPREME COURT ID NO. 29920 " SOUTH PITT STREET CARLISLE, PA 17013 717-24346090 ATTORNEY FOR DEFENDANT GARY P. CORDON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW MARIA L. GORDON, : NO. 2004 - 5365 CIVIL TERM Defendant : IN DIVORCE PRAECIPE FOR WITHDRAWAL OF PETITION FOR PERMISSION TO WITHDRAW AS COUNSEL TO THE PROTHONOTARY: Please withdraw my petition for permission to withdraw from this case as counsel for the defendant. Please inform Judge Ebert that the hearing scheduled for Tuesday, February 12, 2008, may be cancelled. February 11, 2008 _ -1>' l/ k_,P"" HAROLD S. IRWIN, II ESQUI Supreme Court ID No. 64 South Pitt Street Carlisle, PA 17013 717-243-6090 rv V L+•3 ? T F _Y .zJ *.t.` BARBARA E. LONG IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. RAHMAN H. LONG Defendant NO. 04-5363 CIVIL IN DIVORCE PRAECIPE OF TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. GROUND FOR DIVORCE: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. DATE OF FILING AND MANNER OF SERVICE OF THE COMPLAINT: a. Date of Filing of Complaint: October 25, 2004 b. Manner of Service of Complaint: Acceptance of Service by Attorney for Defendant C. Date of Service of Complaint: November 19, 2004 3. DATE OF EXECUTION OF THE AFFIDAVIT OF CONSENT REQUIRED BY SECTION 3301 (C) OF THE DIVORCE CODE: a. Plaintiff: February 7, 2008 b. Defendant: February 7, 2008 4. RELATED CLAIMS PENDING: No issues are pending. All issues have been resolved pursuant to the parties' Stipulation and Agreement dated February 7, 2008, which Agreement is to be incorporated into but not merged with the Divorce Decree. 5. DATE WAIVER OF NOTICE IN SECTION 3301(C) DIVORCE WAS FILED WITH THE PROTHONOTARY: a. Plaintiff's Waiver: February 11 ?. 2008 b. Defendants Waiver: February 1266R? RAD IFF, ESQUIRE 3448 Trindle Ro d Camp ,, 17011 Supreme Court ID # 32112 Phone: (717) 737-0100 t 3 +v YY " C'? ""? '3"7 7 ?` ? a` i ? ,. 7'; 3 ? I A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. N O. 04 - 5363 CIVIL TE13M VERSUS RAHMAN N. LONG, Defendant DECREE IN DIVORCE 1 •o .fi4 •M ' AND NOW, >2nd, IT IS ORDERED AND DECREED THAT BARBARA E. LONG , PLAINTIFF, AND RAHMAN N. LONG DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; No issues are outstanding. All issues have been resolved and settled by the Parties' Stipulation and Agreem ted February 7, 2008, filed of record and incorporated into, t not merge with, this Decree. ATTEST: J. 0 -? W. - PROTHONOTARY 1? -? ? ? ?- ?? ? ?©. ?? - ?.. z INCOME WITHHOLDING FOR SUPPORT pg3 wp7 p go ORIGINAL INCOME WITHHOLDING ORDERMOTICE FOR SUPPORT (IWO) AMENDED IWO ONE-TIMEORDERINOTICE FOR LUMP SUM PAYMENT O?- ?_:StoJ Cw \L TERMINATION OF IWO Date: 12127111 F- ] Child Support Enforcement (CSE) Agency ® Court ? Attorney ? Private Individual/Entity (Check One) "E: This IWO must be regular on its face. Under certain circumstances you must reject this IWO and return it to the sender (see IWO uctions http://www.aaf.hhs.gov/programs/cse/newhire/em looyer/publication/publication.htm - forms). If you receive this document from eone other than a State or Tribal CSE agency or a Court, a copy of the underlying order must be attached. Statc:/Tribe/Territory Commonwealth of Pennsylvania Remittance Identifier (include w/payment): 1236100962 City/--ounty/Dist.rrribe CUMBERLAND Order Identifier: (See Addendum for order/docket lnformaiton) Private Individual/Entity CSE Agency Case Identifier: (See Addendum for case summary) SINGLE SOURCE TRANSPORTATION PO BOX 855 DES MOINES IA 50304-0855 Eriployer/Income Withholder's FEIN Child(ren)'s Name(s) (Last, First, Middle) Child(ren)'s Birth Date(s) RE: LONG, RAHMAN N. Employee/Obligor's Name (Last, First, Middle) 292-70-8311 Employee/Obligor's Social Security Number (See Addendum for plaintiff names associated with cases on attachment) Custodial Party/Obligee's Name (Last, First, Middle) NOTE: This IWO must be regular on its face. Under certain circumstances you must reject this IWO and return it to the sender (see IWO receive this document from someone other a State or Tribal CSE agency or a Court, a / of the underlying order must be attached. See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This document is based on the support or withholding order from CUMBERLAND County, Commonwealth of Pennsylvania (State/Tribe). You are required by law to deduct these amounts from th"mdZyee/ obligor's income until further notice. -03 = -4 $ 0.00 per month in current child support rn4w rn 0 00 =-n - $_ . per month in past-due child support - Arrears 12 weeks or greater? O O qM tn r- Or $_ 0.00 per month in current cash medical support - < o Qr? $_ 0.00 per month in past-due cash medical support <? o $_ 0.00 per month in current spousal support $_ 0.00 per month in past-due spousal support D? $_ 0.00 per month in other (must specify) for a Total Amount to Withhold of $ 0.00 per month. 00 A16YOUNTS TO WITHHOLD: You do not have to vary your pay cycle to be in compliance with the Order Information. If your pay cycle does not match the ordered payment cycle, withhold one of the following amount: $ 0.00 per weekly pay period. $ 0.00 per semimonthly pay period (twice a month) $ 0.00 per biweekly pay period (every two weeks) $ 0.00 per monthly pay period. $ Lump Sum Payment: Do not stop any existing IWO unless you receive a termination order. RE'M/TTANCE INFORMATION: If the employee/obligor's principal place of employment is CUMBERLAND County, Commonwealth of Pennsylvania (State/Tribe), you must begin withholding no later than the first pay period that occurs ten (10) working days after the date of this Order/Notice. Send payment within seven 7 working days of the pad/ date. If you cannot withhold the full amount of support for any or all orders for this employee/obligor, withhold up to 55% of disposable income for all orders. If the employee/obligor's principal place of employment is not CUMBERLAND County, Commonwealth of Pennsylvania (State/Tribe), obtain withholding limitations, time requirements, and any allowable employer fees at http://www.acf.hhs.aov/?roarams/cse/newhire/employer/contacts/ contact_map.htm for the employee/obligor's principal place of employment. Document Tracking Identifier onns No.: 0970 -0154 Form EN-028 11/11 Service Type M Worker ID $IATT ? Return to Sender [Completed by Employer/Income Withholder]. Payment must be directed to an SDU in accordance with 42 USC §666(b)(5) and (b)(6) or Tribal Payee (see Payments to SDU below). If payment is not directed to an SDU/Tribal Payee or this IWO is not regular on its face, you must check this bo rn the IWO to the sender. Signature of Judge/Issuing Official (if required by State or Tribal law): Print Name of Judge/Issuing Official: E6k11_10X& L _C=lap Title of Judge/Issuing Official: Date of Signature: 12-Z-q- kt If the employee/obligor works in a State or for a Tribe that is different from the State or Tribe that issued this order, a copy of this IWO must be provided to the employee/obligor. ? If checked, the employer/income withholder must provide a copy of this form to the employee/obligor. ADDITIONAL INFORMATION FOR EMPLOYERS/INCOME WITHHOLDERS Pennsylvania law (23 PA C.S. § 4374(b)) requires remittance by an electronic payment method if an employer is ordered to withhold income from more than one employee and employs 15 or more persons, or if an employer has a history of two or more returned checks due to nonsufficient funds. Please call the Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1.877.676-9580 for instructions. PA FIPS CODE 42 000 00 Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER /D (shown above as the Emp/oyee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. State-specific contact and withholding information can be found on the Federal Employer Services website located at: http://www.acf. h hs.gov/proaramstcse/newhire/employer/contacts/contact_ gip. htm Priority: Withholding for support has priority over any other legal process under State law against the same income (USC 42 §666(b)(7)). If a Federal tax levy is in effect, please notify the sender. Combining Payments: When remitting payments to an SDU or Tribal CSE agency, you may combine withheld amounts from more than one employee/obligor's income in a single payment. You must, however, separately identify each employee/ obligor's portion of the payment. Payments To DU: You must send child support payments payable by income withholding to the appropriate SDU or to a Tribal CSE agency. If this IWO instructs you to send a payment to an entity other than an SDU (e.g., payable to the custodial party, court, or;attorney), you must check the box above and return this notice to the sender. Exception: If this IWO was sent by a Court, Attdmey, or Private Individual/Entity and the initial order was entered before January 1, 1994 or the order was issued by a Tribal CSE agency, you must follow the "Remit payment to" instructions on this form. Reporting the Pay Date: You must report the pay date when sending the payment. The pay date is the date on which the amount was withheld from the employee/obligor's wages. You must comply with the law of the State (or Tribal law if applicable) of the employee/obligor's principal place of employment regarding time periods within which you must implement the withholding and forward the support payments. Multiple IWOs: If there is more than one IWO against this employee/obligor and you are unable to fully honor all IWOs due to Federal, State, or Tribal withholding limits, you must honor all IWOs to the greatest extent possible, giving priority to current support before payment of any past-due support. Follow the State or Tribal law/procedure of the employee/obligor's principal place of employment to determine the appropriate allocation method. Lump Sum Payments: You may be required to notify a State or Tribal CSE agency of upcoming lump sum payments to this employee/obligor such as bonuses, commissions, or severance pay. Contact the sender to determine if you are required to report and/or withhold lump sum payments. Liability: If you have any doubts about the validity of this IWO, contact the sender. If you fail to withhold income from the employee/obligor's income as the IWO directs, you are liable for both the accumulated amount you should have withheld and any penalties set by State or Tribal law/procedure. Anti-discrimination: You are subject to a fine determined under State or Tribal law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against an employee/obligor because of this IWO. OMB Expiration Dale - 05/31/2014. The OMB Expiration Date has no bearing on the termination date of the IWO; it identifies the version of the form currently in use. Form EN-028 11 /11 Service Type M Page 2 of 3 Worker ID $IATT 4W Employer's Name: SINGLE SOURCE TRANSPORTATION Employer FEIN: Employee/Obligor's Name: LONG, RAHMAN N. CSE Agency Case Identifier: (See Addendum for case summary Order Identifier: (See Addendum for order /docket information Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (CCPA) (15 U.S.C. 1673(b)); or 2) the amounts allowed by the State or Tribe of the employee/obligor's principal place of employment (see REMITTANCE INFORMATION). Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; statutory pension contributions; and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is supporting another family and 60% of the disposable income if the obligor is not supporting another family. However, those limits increase 5% - to 55% and 65% - if the arrears are greater than 12 weeks. If permitted by the State or Tribe, you may deduct a fee for administrative costs. The combined support amount and fee may not exceed the limit indicated in this section. For Tribal orders, you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employers/income withholders who receive a State IWO, you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which the employer/income withholder is located or the maximum amount permitted under section 303(d) of the CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State or Tribal law, you may need to also consider the amounts paid for health care premiums in determining disposable income and applying appropriate withholding limits. Arrears greater than 12 weeks? If the Order Information does not indicate that the arrears are greater than 12 weeks, then the Employer should calculate the CCPA limit using the lower percentage. Additional Information: NOTIFICATION OF EMPLOYMENT TERMINATION OR INCOME STATUS: If this employee/obligor never worked for you or you no longer withholding income for this employee/obligor, an employer must promptly notify the CSE agency and/or the sender by returning this form to the address listed in the Contact Information below: 0 This person has never worked for this employer nor received periodic income. 0 This person no longer works for this employer nor receives periodic income. Please provide the following information for the employee/obligor: Termination date: Last known address: Final Payment Date To SDU/Tribal Payee: New Employer's Name: Last known phone number: Final Payment Amount: New Employer's Address: CONTACT INFORMATION: To Employer/Income Withholder: If you have any questions, contact WAGE ATTACHMENT UNIT (Issuer name) by phone at 717 240-6225, by fax at (717) 240-6248, by email or website at: www.childsupport.state.12a.us. Send termination/income status notice and other correspondence to: DOMESTIC RELATIONS SECTION, 13 N. HA OVER ST. P.O. BOX 320, CARLISLE PA 17013 (Issuer address). To Employee/Obligor: If the employee/obligor has questions, contact WAGE ATTACHMENT UNIT (Issuer name) by phone at (717) 240-6225, by fax at 717) 240-6248, by email or website at www.childsupportstate pa .us. IMPORTANT: The person completing this form is advised that the information may be shared with the employee/obligor. Service Type M OMB No.: 0970-0154 Page 3 of 3 Form EN-028 11/11 Worker ID $IATT ADD DUM Summary of Cases on Attachment Defendant/Obligor: LONG, RAHMAN N. PACSES Case Number 083107080 PACSES Case Number Plaintiff Name Plaintiff Name BARBARA E. LONG Docket Attachment Amount Docket Attachment Amount 04-5363 CIVIL $ 0.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACKS Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACKS Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Addendum Form EN-028 11/11 Service Type M OMB No.: 0970-0154 Worker ID $IATT INCOME WITHHOLDING FOR SUPPORT m3 I C)--�0,30 0 ORIGINAL INCOME WITHHOLDING ORDERINOTICE FOR SUPPORT(tWO) 0 AMENDED IWO OL�- 53(o3 CNI ) 0 ONE-TIMEORDER/NOTICE FOR LUMP SUM PAYMENT 0 TERMINATION OF IWO Date: 11/13/13 ❑ Child Support Enforcement(CSE)Agency Z Court ❑ Attorney ❑ Private Individual/Entity(Check One) NOTE:This IWO must be regular on its face. Under certain circumstances you must reject this IWO and return it to the sender(see IWO instructions bft://www.acf.hhs.gov/procirams/cse/f`orms/QMB-0970-0154 instructions.pd . If you receive this document from someone other than a State or Tribal CSE agency or a Court,a copy of the underlying order must be attached. State/Tribe/Territory Commonwealth of Pennsylvania Remittance Identifier(include w/payment): 1236100962 City/County/Dist./Tribe CUMBERLAND Order Identifier: (See Addendum for order/docket information) Private Individual/Entity CSE Agency Case Identifier: (See Addendum for case summary) RE: LONG, RAHMAN N. DFAS RETIRED MILITARY Employee/Obligor's Name(Last,First,Middle) 292-70-8311 Sent Electronically Employee/Obligor's Social Security Number DO NOT MAIL (See Addendum for plaintiff names associated with cases on attachment) Custodial Party/Obligee's Name(Last, First, Middle) Employer/income Withholder's FEIN 340727612 NOTE:This IWO must be regular on its face. Under certain circumstances you must reject Child(ren)'s Name(s)(Last,First,Middle) Child(ren)'s Birth Date(s) this IWO and return it to the sender(see IWO instructions hLtr)://www.acf.hhs.aov/i)rograms/r-se/form OMB-0970-0154 Jngrpgj2ns pdt).If you receive this document from someone other than a State or Tribal CSE agency or a Court,a L copy of the underlying order must be attached. 3407276120 See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION. This document is based on the support or withholding order from CUMBERLAND County, Commonwealth of Pennsylvania (State/Tribe). You are required by law to deduct these amounts from the employee/ obligor's income until further notice. $ 0.00 per month in current child support $ 0.00 per month in past-due child support- Arrears 12 weeks or greater? O ye*w� $ 0.00 per month in current cash medical support =M r-rl => M7— $ 0.00 per month in past-due cash medical support $ 1.150,00 per month in current spousal support $ 0.00 per month in past-due spousal support $ 0.00 per m_ onth in other(must specify) )>C:)C--.� for a Total Amount to Withhold of$ 1,150.00 per month. =' � AMOUNTS TO WITHHOLD: You do not have to vary your pay cycle to be in compliance with the or'der rnvorr6mon. If your pay cycle does not match the ordered payment cycle,withhold one of the following amount: $ 264.66 per weekly pay period. $ 575.00 per semimonthly pay period (twice a month) $ 529.32 per biweekly pay period(every two weeks) $ 1,150,00 per monthly pay period. $ Lump Sum Payment: Do not stop any existing IWO unless you receive a termination order. REMITTANCE INFORMATION. If the employee/obligor's principal place of employment is within the Commonwealth of Pennsylvania (State/Tribe), you must begin withholding no later than the first pay period that occurs ten (10) woLkft days after the date of this Order/Notice. Send payment within seven (7)working days of the pay date. If you cannot withhold the full amount of support for any or all orders for this employee/obligor, withhold up to 55% of disposable income for all orders. If the employee/obligor's principal place of employment is not within the Commonwealth of Pennsylvania (State/Tribe), the employer can obtain withholding limitations, time requirements, and any allowable employer fees at http://www.acf.hhs-gov/pro-cLrams/cse/newhire/employer/contacts/contact—map. htm for the employee/obligor's principal place of employment, Document Tracking Identifier OMB No.:0970-0154 Form EN-428 11/13 Service Type M Worker ID$IATT ❑ Return to Sender[Completed by Employer/income Withholder]. Payment must be directed to an SDU in accordance with 42 USC§666(b)(5)and (b)(6)or Tribal Payee(see Payments to SDU below). If payment is not directed to an SDU/Tribal Payee or this IWO is not regular on its face, you must check this box and return the IWO to the sender. Signature of Judge/issuing Official (if required by State or Tribal law): KEVIN A HESS Print Name of Judge/Issuing Official: Title of Judge/Issuing Official: Date of Signature: NOVEMBER 13 2013 If the employee/obligor works in a State or for a Tribe that is different from the State or Tribe that issued this order,a copy of this IWO must be provided to the employee/obligor. ❑ If checked,the employer/income withholder must provide a copy of this form to the employee/obligor. ADDITIONAL INFORMATION FOR EMPLOYERS/INCOME WITHHOLDERS Pennsylvania law(23 PA C.S.§4374(b))requires remittance by an electronic payment method if an employer is ordered to withhold income from more than one employee and employs 15 or more persons,or if an employer has a history,of two or more returned checks due to nonsufficient funds. Please call the Pennsylvania State Collections and Disbursement Unit(PA SCDU)Employer Customer Service at 1-877-676-9580 for instructions.PA FIPS CODE 42 000 00 Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID(shown above as the EmployeelObligor's Case Identifier)OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. State-specific contact and withholding information can be found on the Federal Employer Services website located at: http://www.acf.hhs.00v/proarems/cse/newhire/employer/contacts-/contagl-map,htm Priority:Withholding for support has priority over any other legal process under State law against the same income(USC 42 §666(b)(7)). If a Federal tax levy is in effect, please notify the sender. I Combining Payments: When remitting payments to an SDU or Tribal CSE agency,you may combine withheld amounts from more than one employee/obligor's income in a single payment.You must, however, separately identify each employee/ obligor's portion of the payment. Payments To SDU: You must send child support payments payable by income withholding to the appropriate SDU or to a Tribal CSE agency. If this IWO instructs you to send a payment to an entity other than an SDU(e.g., payable to the custodial party, court, or attorney),you must check the box above and return this notice to the sender. Exception: If this IWO was sent by a Court,Attorney, or Private Individual/Entity and the initial order was entered before January 1, 1994 or the order was issued by a Tribal CSE agency,you must follow the"Remit payment to"instructions on this form. Reporting the Pay Date: You must report the pay date when sending the payment. The pay date is the date on which the amount was withheld from the employee/obligor's wages.You must comply with the law of the State(or Tribal law if applicable)of the employee/obligor's principal place of employment regarding time periods within which you must implement the withholding and forward the support payments. Multiple IWOs: If there is more than one IWO against this employee/obligor and you are unable to fully honor all IWOs due to Federal, State, or Tribal withholding limits, you must honor all IWOs to the greatest extent possible, giving priority to current support before payment of any past-due support. Follow the State or Tribal law/procedure of the employee/obligors principal place of employment to determine the appropriate allocation method. Lump Sum Payments: You may be required to notify a State or Tribal CSE agency of upcoming lump sum payments to this employee/obligor such as bonuses, commissions, or severance pay. Contact the sender to determine if you are required to report and/or withhold lump sum payments. Liability: If you have any doubts about the validity of this IWO, contact the sender. If you fail to withhold income from the employee/obligor's income as the IWO directs,you are liable for both the accumulated amount you should have withheld and any penalties set by State or Tribal law/procedure. Anti-discrimination: You are subject to a fine determined under State or Tribal law for discharging an employee/obligor from employment, refusing to employ,or taking disciplinary action against an employee/obligor because of this IWO. OMB Expiration Date—05M/2014.The OMB Expiration Date has no bearing on the termination date of the IWO;it identifies the version of the form currently in use. Form EN-428 11/13 Service Type M Page 2 of 3 Worker ID$IATT Employees Name: DFAS RETIRED MILITARY Employer FEIN: 340727612 Employee/Obligoes Name: LONG, RAHMAN N. 1236100962 CSE Agency Case Identifier:Lee Addendum for case summa Order Identifier:(See Addendum for ordenVocket informa Withholding Limits:You may not withhold more than the lesser of: 1)the amounts allowed by the Federal Consumer Credit Protection Act(CCPA)(15 U.S.C. 1673(b));or 2)the amounts allowed by the State or Tribe of the employee/obligor's principal place of employment(see REMITTANCE INFORMATION). Disposable income is the net income left after making mandatory deductions such as:State, Federal, local taxes;Social Security taxes; statutory pension contributions; and Medicare taxes.The Federal limit is 50%of the disposable income if the obligor is supporting another family and 60%of the disposable income if the obligor is not supporting another family. However,those limits increase 5%-to 55%and 65%-if the arrears are greater than 12 weeks. If permitted by the State or Tribe,you may deduct a fee for administrative costs.The combined support amount and fee may not exceed the limit indicated in this section, For Tribal orders,you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employers/income withholders who receive a State IWO,you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which the employer/income withholder is located or the maximum amount permitted under section 303(d)of the CCPA(15 U.S.C. 1673(b)). Depending upon applicable State or Tribal law,you may need to also consider the amounts paid for health care premiums in determining disposable income and applying appropriate withholding limits. Arrears greater than 12 weeks?If the Order Information does not indicate that the arrears are greater than 12 weeks,then the Employer should calculate the CCPA limit using the lower percentage. Additional Information: NOTIFICATION OF EMPLOYMENT TERMINATION OR INCOME STATUS: If this employee/obligor never worked for you or you are no longer withholding income for this employee/obligor,an employer must promptly notify the CSE agency and/or the sender by returning this fon*n to the address listed in the Contact Information below: 3407276120 0 This person has never worked for this employer nor received periodic income, 0 This person no longer works for this employer nor receives periodic income. Please provide the following information for the employee/obligor: Termination date: Last known phone number: Last known address: Final Payment Date To SDU/Tribal Payee: Final Payment Amount: New Employer's Name: New Employees Address: CONTACT INFORMATION: To Employer/Income Withholder: If you have any questions, contact WAGE ATTACHMENT UNIT(Issuer name) by phone at(717)240-6225, by fax at(717)240-6248, by email or website at:www.childsupport.state.pa.us. Send termination/income status notice and other correspondence to: DOMESTIC RELATIONS SECTION, 13 N. HANOVER ST. P.O. BOX 320, CARLISLE, PA. 17013(Issuer address). To Employee/Obligor: If the employee/obligor has questions, contact WAGE ATTACHMENT UNIT(Issuer name) by phone at(717)240-6225, by fax at(717)240-6248, by email or website at www.childsupport.state.pa.us. IMPORTANT:The person completing this form is advised that the information may be shared with the employee/obligor. OMB No.:0970-0154 Form EN-428 11/13 Service Type M Page 3 of 3 Worker ID$IATT *7 V ti ADDENDUM ` Summary of Cases on Attachment Defendant/Obllgor: LONG, RAHMAN N. PACSES Case Number 083107080 PACSES Case Number Plaintiff Name Plaintiff Name BARBARA E. LONG Docket Attachment Amount Docket Attachment Amount 04-5363 CIVIL $ 1,150.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB'I I I PACSES Case Number PACSES Case Number i Plaintiff Name Plaintiff Name Docket Attachment Amount Docke t Attachment Amount $ 0.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB I I PACKS Case Number PACSES Case Number Plaintiff Name Plaintiff Name Docket Attachment Amount Docket Attachment Amount $ 0.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB Addendum Form EN-428 11/13 Service Type M OMB No.:0970-0154 Worker ID$IATT In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION Phone: (717) 240-6225 13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013 azz -o Z Fax: (7172M-6 ri-L2 z Z;f t\> -(3> ca <cD • • -.1 2r" Defendant Name: RAHMAN N. LONG Member ID Number: 1236100962 Please note: All correspondence must include the Member ID Number. ORDER TO VACATE ATTACHMENT OF UNEMPLOYMENT BENEFITS Plaintiff Name BARBARA E. LONG Financial Break Down of Multiple Cases on Attachment PACSES Docket Case Number Number 083107080 04-5363 CIVIL TOTAL ATTACHMENT AMOUNT: Attachment Amount/Frequency 1,150.00 / MONTH 1,150.00 The prior Order of this Court directing the Department of Labor and Industry, Office of Unemployment Compensation Benefits (OUCB), to attach $264.65 or 50% per week of the Unemployment Compensation benefits of RAHMAN N. LONG, Social Security Number XXX-XX-8311, Member ID Number 1236100962 is hereby vacated. This Order to Vacate shall be effective upon receipt of the notice of the Order by the Department and shall remain in effect until a further Order of the Court is filed. Date of Order: APR 2_ 2 '314 Service Type M BY THE COURT Form EN-035 Worker ID $IATT