HomeMy WebLinkAbout02-0930
HARRY P. CASON I ,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 02 - 9 aO
CIVIL TERM
MARGARET A. CASONI,
DEFENDANT
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against
the claims set forth in the following pages, you must take prompt
action. You are warned that if you fail to do so, the case may
proceed without you and a decree of divorce or annulment may be
entered against you by the Court. A judgment may also be entered
against you for any other claim or relief requested in these papers
by the Plaintiff. You may lose money or property or other rights
important to you, including custody or visitation of your children.
When the ground for is indignities or irretrievable breakdown
of the marriage, you may request marriage counseling. A list of
marriage counselors is available in the Court Administrator's
Office, Fourth floor, Cumberland County Courthouse, Hanover and
High Streets, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
1-800-990-9108
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
MARGARET A. CASONI ) Docket Number 02-930 CIVIL
Plaintiff )
vs. ) PACSES Case Number 545104383
HARRY P. CASONI )
Defendant ) Other State ID Number
ORDER OF COURT
You,
HARRY PETER CASONI
plaintiff/defendant of
PO BOX 1104, MECHANICSBURG, PA. 17055-1104-04
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
AUGUST 6, 2002
at 1:30PM 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, <:") 0
3. verification of child care expenses, and ~ g
4. proof of medical coverage which you may have, or may have available to y~;::;r-""
::zJ
5. information relating to professionailicenses ~ ~ ~
'n
6. other; :;::o~
o
Service Type M
Form CM-509
Worker ID 21302
CASONI
V. CASONI
PACSES Case Number: 545104383
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.
An appropriate order may be entered against either party based upon the evidence
presented without regard to which party initiated the support action.
BY THE COURT:
Date of Order:
'1 IS' 02
7'
~~
JUDGE
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY AITEND THE HEARING AND
REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD
ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU MAY GET LEGAL HELP:
CUMBERLAND CO BAR ASSOCIATION
2 LIBERTY AVE
CARLISLE PA 17013-3308-02
(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.
Service Type M
Page 2 of 2
Form CM-509
Worker ID 21302
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
MARGARET A. CASONI ) Docket Number 02-930 CIVIL
Plaintiff )
vs. ) PACSES Case Number 545104383
HARRY P. CASONI )
Defendant ) Other State ID Number
ORDER OF COURT
You,
MARGARET A. CASON I
plaintiff/defendant of
2713 WOODBINE ROAD, GRANTHAM, PA. 17027
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
AUGUST 6, 2002
at 1:30PM 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, o~
3. verification of child care expenses, and c:: g
4. proof of medical coverage which you may have, or may have available to y~ ~
S. information relating to professional licenses ;,. ~
6. other: z::o~
.."
on
C::)>M
C/l
o
Service Type M
Form CM-S09
Worker ID 21302
CASONI
V. CASONI
PACSES Case Number: 545104383
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.
An appropriate order may be entered against either party based upon the evidence
presented without regard to which party initiated the support action.
BY THE COURT:
Date of Order:
1 15 02..
7'
~".(
JUDGE
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND
REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD
ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU MAY GET LEGAL HELP:
CUMBERLAND CO BAR ASSOCIATION
2 LIBERTY AVE
CARLISLE PA 17013-3308-02
(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 infonnation 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.
Service Type M
Page 2 of 2
Form CM-509
Worker ID 21302
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HARRY P. CASON I ,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 02 - 930
CIVIL TERM
MARGARET A. CASONI,
DEFENDANT
IN DIVORCE
COMPLAINT UNDER SECTION 3301(c) OR
3301 (d) OF THE DIVORCE CODE IN DIVORCE
1. The Plaintiff is Harry P. Casoni who resides at 2713
Woodbine Street, Gratham, Cumberland County, Pennsylvania 17027.
2. The Defendant is Margaret A. Casoni who resides at 2713
Woodbine Street, Gratham, Cumberland County, Pennsylvania 17027.
3. The Plaintiff and Defendant have been a bonafide
residents of the Commonwealth of Pennsylvania for at least six
months immediately prior to the filing of this Complaint.
4. The Plaintiff and Defendant were married on February 7,
1955 in Philadelphia, Pennsylvania.
5. There have been no prior actions of divorce or annulment
between the parties in this or any other jurisdiction.
6. The marriage is irretrievably broken.
7. The Defendant is not a member of the Armed Services of
the United States or any of its Allies.
8. The Plaintiff has been advised of the availability of
counseling and that Plaintiff may have the right to request that
the Court require the parties to participate in counseling.
9. Plaintiff requests the court to enter a decree of divorce.
~:b. ~
Thomas D. Gould
Attorney for Plaintiff
1.0. # 36508
2 East Main Street
Shiremanstown, PA 17011
(717) 731-1461
VERIFICATION
I verify that the statements made in this Complaint are true
and correct.
I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn
falsification to authorities.
Date :7'-- .7f' -tJ/..
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HARRY P. CASONI,
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO, 02-930 CIVIL TERM
MARGARET A. CASONI,
IN DIVORCE
DEFENDANT'S PETITION FOR ECONOMIC RELIEF
AND NOW comes the above-named Defendant, by her attorney, Samuel L. Andes,
and makes the following claim for economic relief in this matter:
1. The Petitioner herein is the Defendant, Margaret A. Casoni, an adult individual
who resides at 2713 Woodbine Road in Grantham, Pennsylvania.
2. The Respondent herein is the Plaintiff, Harry P. Casoni, an adult individual who
resides at P,O. Box 1104 in Mechanicsburg, Cumberland County, Pennsylvania.
3. The Plaintiff commenced this action by filing a Divorce Complaint on 25 February
2002.
4. The parties have been married for more than forty-six years.
COUNT I. EQUITABLE DISTRIBUTION
1. During the course of the marriage, the parties have acquired numerous items of
property, both real and personal, which are held in joint names and in the individual names
of each of the parties hereto.
1
.
.
"
~
WHEREFORE, Defendant prays this Honorable Court, after requiring full disclosure by
the Plaintiff, to equitably divide the property, both real and personal, owned by the parties
hereto as marital property.
COUNT II - ALIMONY
2. Defendant lacks sufficient property to provide for her reasonable needs in
accordance with the standard of living of the parties established during the marriage.
3. Defendant is unable to support herself in accordance with the standard of living
of the parties established during the marriage through appropriate employment,
4. The Plaintiff is employed and enjoys a substantial income from which he is able
to contribute to the support and maintenance of Defendant and to pay her alimony in
accordance with the Divorce Code of Pennsylvania.
WHEREFORE, Defendant prays this Honorable Court to enter an Order awarding
Defendant from Plaintiff permanent alimony in such sums as are reasonable and adequate
to support and maintain Defendant in the station of life to which she has become
accustomed during the marriage.
COUNT III . ALIMONY PENDENTE LITE
5. Defendant is without sufficient income to support and maintain herself during the
pendency of this action.
6. Plaintiff enjoys a substantial income and is well able to contribute to the support
and maintenance of Defendant during the course of this action.
2
-.
--
WHEREFORE, Defendant prays this Honorable Court to order Plaintiff to pay her
reasonable alimony pendente lite during the pendency of this action.
COUNT IV - COUNSEL FEES AND EXPENSES
7. Defendant is without sufficient funds to retain counsel to represent her in this
matter.
8. Without competent counsel, Defendant cannot adequately prosecute her claims
against Plaintiff and cannot adequately litigate her rights in this matter.
9. Plaintiff enjoys a substantial income and is well able to bear the expense of
Defendant's attorney and the expenses of this litigation.
WHEREFORE, Defendant prays this Honorable Court to order Plaintiff to pay the legal
fees and expenses incurred by Defendant in the litigation of this action.
_\::? ~ ~Q ~
~ Andes
Attorney for Defendant
Supreme Court ID 17225
525 North 12th Street
Lemoyne, PA 17043
(717) 761-5361
1 verify that the statements made in this Petition for Economic Relief are true and
correct. I understand that any false statements in this Petition are subject to the penalties
of 18 Pa. C.S. 4904 (unsworn falsification to authorities).
DATE: .3 /61 it;;L
, .
V) (/' ry
?IL~/ pt. L-.~
MARG ET A. CASONI
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HARR'< P. CASON\,
PlaintiH
)
)
)
)
)
)
)
)
)
vs.
MARGAREi A. CASONI,
Defendant
IN 'THE COUR'T OF COMMON
PLEAS Or CUMBERLAND
COUN'T'<, PENNS,<L \I ANIA
C\\IIL ACIION - LAW
NO. 02-930 C\\IIL'TERM
IN D\\IORCE
M01\ON ,OR "","liNG oN AL'MONY ....O"NrE UTE
.,.0 NOW "m" the .bO,,"n.m.d O.f.nd.nt. bV he< atto,n.v. s.mu.1 L" And",
.nd mo'" the "urt to< . "nf".n" beto<. the oom..t;< R.I,"'O", Off'" 0<. to ",.
.",.nt n.""""" . _,'no b.tO" the "urt on O.t.nd.nt" ",qu'" to< .lImonV ,.nd.n"
.... .. "t out ;n he< P.tition to' ""nom'< R.llet. . ",. of "h,<h ;. .tt.<hed h"'to.
S el L. Andes
Attorney for Defendant
supreme Court 10 # n225
525 North' 2'h Street
Lemoyne, pa '7043
(7n) 76,-536'
I.
HARRY P. CASONI,
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 02-930 CIVIL TERM
MARGARET A. CASONI,
IN DIVORCE
DEFENDANT'S PETITION FOR ECONOMIC RELIEF
AND NOW comes the above-named Defendant, by her attorney, Samuel L. Andes,
and makes the following claim for economic relief in this matter:
1. The Petitioner herein is the Defendant, Margaret A. Casoni, an adult individual
who resides at 2713 Woodbine Road in Grantham, Pennsylvania.
2. The Respondent herein is the Plaintiff, Harry P. Casoni, an adult individual who
resides at P.O. Box 1104 in Mechanicsburg, Cumberland County, Pennsylvania,
3. The Plaintiff commenced this action by filing a Divorce Complaint on 25 February
2002.
4. The parties have been married for more than forty-six years,
COUNT I - EQUITABLE DISTRIBUTION
1. During the course of the marriage, the parties have acquired numerous items of
property, both real and personal, which are held in joint names and in the individual names
of each of the parties hereto.
1
WHEREFORE, Defendant prays this Honorable Court, after requiring full disclosure by
the Plaintiff, to equitably divide the property, both real and personal, owned by the parties
hereto as marital property.
COUNT II - ALIMONY
2. Defendant lacks sufficient property to provide for her reasonable needs in
accordance with the standard of living of the parties established during the marriage.
3. Defendant is unable to support herself in accordance with the standard of living
of the parties established during the marriage through appropriate employment.
4. The Plaintiff is employed and enjoys a substantial income from which he is able
to contribute to the support and maintenance of Defendant and to pay her alimony in
accordance with the Divorce Code of Pennsylvania.
WHEREFORE, Defendant prays this Honorable Court to enter an Order awarding
Defendant from Plaintiff permanent alimony in such sums as are reasonable and adequate
to support and maintain Defendant in the station of life to which she has become
accustomed during the marriage.
COUNT III - ALIMONY PENDENTE LITE
5. Defendant is without sufficient income to support and maintain herself during the
pendency of this action.
6. Plaintiff enjoys a substantial income and is well able to contribute to the support
and maintenance of Defendant during the course of this action.
2
WHEREFORE, Defendant prays this Honorable Court to order Plaintiff to pay her
reasonable alimony pendente lite during the pendency of this action.
COUNT IV - COUNSEL FEES AND EXPENSES
7. Defendant is without sufficient funds to retain counsel to represent her in this
matter,
8. Without competent counsel, Defendant cannot adequately prosecute her claims
against Plaintiff and cannot adequately litigate her rights in this matter.
9. Plaintiff enjoys a substantial income and is well able to bear the expense of
Defendant's attorney and the expenses of this litigation.
WHEREFORE, Defendant prays this Honorable Court to order Plaintiff to pay the legal
fees and expenses incurred by Defendant in the litigation of this action.
~~A~Q ~
Attorney for Defendant
Supreme Court 10 17225
525 North 12th Street
Lemoyne, PA 17043
(717) 761-5361
I verify that the statements made in this Petition for Economic Relief are true and
correct. I understand that any false statements in this Petition are subject to the penalties
of 18 Pa, C.S. 4904 (unsworn falsification to authorities).
DATE: 3 /61 llJ.l.
I
"'7 I ~ /Y
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MARG ET A. CASON I
3
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.
HARRY P. CASONI,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO, 02-930 CIVIL TERM
MARGARET A. CASONI,
Defendant
IN DIVORCE
MOTION FOR HEARING ON ALIMONY PENDENTE LITE
AND NOW comes the above-named Defendant, by her attorney, Samuel L. Andes,
and moves the court for a conference before the Domestic Relations Office or, to the
extent necessary, a hearing before the court on Defendant's request for alimony pendente
lite, as set out in her Petition for Economic Relief, a copy of which is attached hereto.
~An'1! ~
Attorney for Defendant
Supreme Court 10 # 17225
525 North 12th Street
Lemoyne, Pa 17043
(717) 761-5361
I.
HARRY P. CASONI, ) IN THE COURT OF COMMON
) PLEAS OF CUMBERLAND
) COUNTY, PENNSYLVANIA
)
vs. ) CIVIL ACTION - LAW
)
) NO. 02-930 CIVIL TERM
)
MARGARET A. CASON I, ) IN DIVORCE
DEFENDANT'S PETITION FOR ECONOMIC RELIEF
AND NOW comes the above-named Defendant, by her attorney, Samuel L. Andes,
and makes the following claim for economic relief in this matter:
1. The Petitioner herein is the Defendant, Margaret A, Casoni, an adult individual
who resides at 2713 Woodbine Road in Grantham, Pennsylvania.
2. The Respondent herein is the Plaintiff, Harry P. Casoni, an adult individual who
resides at P.O. Box 1104 in Mechanicsburg, Cumberland County, Pennsylvania.
3. The Plaintiff commenced this action by filing a Divorce Complaint on 25 February
2002.
4. The parties have been married for more than forty-six years.
COUNT I - EQUITABLE DISTRIBUTION
1. During the course of the marriage, the parties have acquired numerous items of
property, both real and personal, which are held in joint names and in the individual names
of each of the parties hereto.
1
WHEREFORE, Defendant prays this Honorable Court, after requiring full disclosure by
the Plaintiff, to equitably divide the property, both real and personal, owned by the parties
hereto as marital property.
COUNT II - ALIMONY
2. Defendant lacks sufficient property to provide for her reasonable needs in
accordance with the standard of living of the parties established during the marriage.
3. Defendant is unable to support herself in accordance with the standard of living
of the parties established during the marriage through appropriate employment.
4. The Plaintiff is employed and enjoys a substantial income from which he is able
to contribute to the support and maintenance of Defendant and to pay her alimony in
accordance with the Divorce Code of Pennsylvania.
WHEREFORE, Defendant prays this Honorable Court to enter an Order awarding
Defendant from Plaintiff permanent alimony in such sums as are reasonable and adequate
to support and maintain Defendant in the station of life to which she has become
accustomed during the marriage,
COUNT III - ALIMONY PENDENTE LITE
5. Defendant is without sufficient income to support and maintain herself during the
pendency of this action.
6. Plaintiff enjoys a substantial income 'and is well able to contribute to the support
and maintenance of Defendant during the course of this action.
2
WHEREFORE, Defendant prays this Honorable Court to order Plaintiff to pay her
reasonable alimony pendente lite during the pendency of this action.
COUNT IV - COUNSEL FEES AND EXPENSES
7. Defendant is without sufficient funds to retain counsel to represent her in this
matter.
8. Without competent counsel, Defendant cannot adequately prosecute her claims
against Plaintiff and cannot adequately litigate her rights in this matter.
9. Plaintiff enjoys a substantial income and is well able to bear the expense of
Defendant's attorney and the expenses of this litigation.
WHEREFORE, Defendant prays this Honorable Court to order Plaintiff to pay the legal
fees and expenses incurred by Defendant in the litigation of this action.
~,~ \1tDQ ~
uel L. Andes
Attorney for Defendant
Supreme Court 10 17225
525 North 12th Street
Lemoyne, PA 17043
(717) 761-5361
I verify that the statements made in this Petition for Economic Relief are true and
correct. I understand that any false statements in this Petition are subject to the penalties
of 18 Pa. C.S. 4904 (unsworn falsification to authorities).
DATE: .3 /61 /o.:l
, .
VI
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MARG ET A. CASON I
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HARRY P. CASON!,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
MARGARET A. CASON!,
Defendant/Petitioner
NO. 2002 - 930 CIVIL TERM
IN DIVORCE
DR# 31589
PacseS# 545104383
ORDER OF COURT
AND NOW, this 4th day of April, 2002. upon consideration of the attached Petition for Alimony
Pendente Lite and/or counsel fees. it is hereby directed that the parties and their respective counsel appear
before R.J. Shaddav on Mav 2.2002 at 9:00 A.M. for a conference, at 13 N. Hanover St., Carlisle. PA
17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be
entered.
YOU are further ordered to bring to the conference:
(I) a true copy of your most recent Federal Income Tax Return, including W-2's as filed
(2) your pay stubs for the preceding six (6) months
(3) the Income and Expense Statement attached to this order. completed as required by Rule
191O.1l<!:l
(4) verification of child care expenses
(5) proof of medical coverage which you may have. or may have available to you
IF you fail to appear for the conference or bring the required documents, the Court may issue a
warrant for your arrest.
BY THE COURT.
George E. Hoffer, President Judge
Mail copies on Petitioner
4-4-02 to: < Respondent
Samuel Andes. Esquire
Thomas Gould. Esquire
/1~. . /1;(, ,1-{4
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Date of Order; April 4, 2002
R. J. Shadday, Conference Officer
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND
REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET
LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIA nON
2 LIBERTY AVE.
CARLISLE. PENNSYL VANIA 17013
(717) 249-3166
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
'})k.+- {p {I .$;)00 I
State Commonwealth of Pennsvlvania 'PI'\C..S P; 3;) 9 10 '37 :3 lI' 'De.. 30 q 3 ~
Co./City/Dist. of CUMBERLAND
Date of Order/Notice OS/21/02 ::pi\c$ffi 6"'t..f5'/Dl( 38'3
Court/Case Number (See Addendum for case summary) .
o Original Order/Notice
o Amended Order/Notice
o Terminate Order/Notice
) RE: CASONI, HARRY P.
) Employee/Obligor's Name (Last, First, MI)
) 160-26-5245
) Employee/Obligor's Social Security Number
) 6892100834
) Employee/Obligor's Case Identifier
) (See Addendum for plaintiff names associated with cases on attachment)
) Custodial Parent's Name (Last. First, MI)
)
Employer/Withholder's Federal EIN Number
SOCIAL SECURITY ADMINISTRATION
Employer/Withholder's Name
C/O MR. HEWITT
Employer/Withholder's Address
MINVERVA MILLS BLDG
401 E LOUTHER ST
CARLISLE PA 17013-2657
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee'sfobligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 887.00 per month in current support
$ 50 . 00 per month in past-due support Arrears 12 weeks or greater? (g) yes 0 no
$ 0.00 per month in medical support
$ 0 . 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 937.00 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:
$ 216.23 per weekly pay period.
$ 432.46 per biweekly pay period (every two weeks).
$ 468.50 per semimonthly pay period (twice a month).
$ 937.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee'sf obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on pg. 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer SeNice at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCOU
Send check to: Pennsylvania SCOU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
SeNice Type M
MAILED
"7- c:3;;)-!);)
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crUD&E
Form E N-028
Worker ID $OINC
Date of Order: HAY 2 2 2002
OMB No.: 0970-0154
Expiration Date: 12/31/00
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If checked you are required to provide a copy of this form to your employee.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment
to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to
each employee/obligor.
3.* ~::.r'~~~~~: t~~\e ~~yd~ale ofWitl,holdil,g. You I"ust repolt tl,e paydateJdate of "ithLoldilog "I,el, sel,ding the payl",!!I,t. The
paydale!date of "it~,I,oldil,g is the dale 01, "LICh a,l1ot.nt "as "ltLheld hom tl,e el"ployee's "ages. You must comply With the law of the
state of the employee'slobligor's principal place of employment with respect to the time periods within which you must implement the
withhold ing 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.
WITHHOLDER'S ID: 8384100092
EMPLOYEE'S/OBLlGOR'S NAME: CASONI , HARRY P.
EMPLOYEE'S CASE IDENTIFIER: 6892100834 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-<liscrimination: You are subject to a fine determined under State law for discharging an employee/obligor from
employment, refusing to employ, or taking diSciplinary action against any employee/obligor because of a support withholding.
Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is
employed governs.
9. * Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.S.c. 91673 (b)l; or 2) the amounts allowed by the State of the employee'slobligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes, Social Security taxes; and Medicare taxes.
10.
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
Requesting Agency:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717\ 240-6248 or
by Internet @
Service Type M
Page 2 of 2
Form EN-028
Worker ID $OINC
OMB No.: 0970-0154
Expiration Date: 12/31/00
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: CASONI, HARRY P.
PACSES Case Number 329103738/3CA '5 <(
Plaintiff Name
DONNA M. GOSS
Docket Attachment Amount
oorns 2001 $ 250.00
Child(ren)'s Name(s):
~gJ;:'l''l'.. S1991;1;...............
ClU'r:tiINlhGOsS" .
DOB
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you are required to enroll the child(ren)
in any health insurance coverage available
employee'sJobligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
you are required to enroll the child(ren)
in any health insurance coverage available
employee'sJobligor's employment.
Service Type M
Addendum
OMB No.: 0970-0154
Expiration Date: 12/31/00
PACSES Case Number 545104383/ ~/5i? '7
Plaintiff Name
MARGARET A. CASONI
Docket Attachment Amount
02-930 CIVIL $ 687.00
Child(ren)'s Name(s):
DOB
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
you are required to enroll the child(ren)
in any health insurance coverage available
employee'sJobligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
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o If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Form EN-028
Worker ID $OINC
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HARRY P. CASONI,
PlaintiffIRespondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
VS.
CIVIL ACTION - DIVORCE
MARGARET A. CASONI,
DefendantIPetitioner
NO. 2002-930 CIVIL TERM
IN DIVORCE
DR# 31589
Pacses# 545104383
ORDER OF COURT
AND NOW, this 2111 day of May, 2002, based upon the Court's determination that Petitioner's
monthly net income/earning capacity is $0.00 and Respondent's monthly net income/earning capacity
is $1,717.63, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and
Disbursement Unit, $707.00 per month payable monthly as follows; $687.00 for alimony pendente lite
and $20.00 on arrears. First payment due on or before the 5th day of each month, commencing in
June, 2002 @ $850.00. Arrears set at $548.52 as of May 21,2002. The effective date of the order is
March 19, 2002.
Husband is given credit in the amount of $1,113 .58.
This order considers that husband is responsible for one half ofwife's monthly insurance premium of
$283.00 commencing in June 2002, thus modifYing the Order to $830.00 Alimony Pendente Lite plus
$20.00 on arrears effective June 1, 2002
Failure to make each payment on time and in full will cause all arrears to become subject to immediate
collection by all of the means as provided by 23 Pa.C.S.~ 3703. Further, if the Court finds, after
hearing, that the Respondent has willfully failed to comply with this Order, it may declare the
Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not
limited to, commitment of the Respondent to prison for a period not to exceed six months.
Said money to be turned over by the P A SCDU to: Margaret Casoni. Payments must be made by
check or money order. All checks and money orders must be made payable to P A SCDU and mailed
to:
PASCDU
P.O. Box 69110
Harrisburg, P A 17106-911 0
Payments must include the defendant's P ACSES Member Number or Social Security Number in order
to be processed. Do not send cash by mail.
Unreimbursed medical expenses that exceed $250.00 annually are to be paid 0% by the respondent
and 100% by petitioner. The petitioner is responsible to pay the first $250.00 annually in
unreimbursed medical expenses. Petitioner to provide her own medical insurance coverage. Within
thirty (30) days after the entry of this order, the Plaintiff shall submit written proof that medical
insurance coverage has been obtained or that application for coverage has been made. Proof of
coverage shall consist, at a minimum, of: 1) the name of the health care coverage provider(s); 2) any
applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims
should be made; 5) a description of any restrictions on usage, such as prior approval for hospital
admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage
contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms.
This Order shall become final ten days after the mailing of the notice of the entry of the Order to the
parties unless either party files a written demand with the Prothonotary for a hearing de novo before
the Court.
DRO: R. 1. Shadday
Mailed copies on
5-22-02 to: <
Petitioner
Respondent
Samuel Andes, Esquire
Thomas Gould, Esquire
BY THE COURT,
7' ~ 4.-
Kevin A. Hess
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HARRY P. CASON!,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS
CIVIL ACTION- DIVORCE
MARGARET A CASONI,
Defendant/Petitioner
NO. 2002-930 CIVIL TERM
IN DIVORCE
DR# 31589
Pacses# 545104383
DEMAND FOR HEARING
DA TE OF ORDER: May 21, 2002
AMOUNT: $687 per month plus $20.00 on arrears
FOR: Alimony Pendente Lite
REASON(S)
1.
6.
7.
Hearing Officer failed to recognize net income/earning capacity of the Petitioner.
2.
Hearing Officer failed to consider that Petitioner's primary medical insurance is
Medicare thereby fulfilling the requirement for medical insurance. Furthermore,
Respondent believes that any insurance needs above and beyond Medicare are
unreasonable and present an undo fmancial hardship on Respondent.
3.
Hearing Officer failed to consider Respondent's other medical liability due to
second family - twin children. (59% of all unreimbursed medical costs over $250
for each child)
4.
Hearing Officer failed to recognize that monies eannarked to satisfy other support
obligations (Le. Medical Insurance for Respondent - Support & Medical payments
to Respondent's second family) are not funds that are available for Support &
therefore should not be included in Respondent's net income calculation.
5.
Hearing Officer failed to give Respondent credit for interim payments made to or
on behalf of the Petitioner from hearing date of May 2, 2002 to May 21, 2002 (date
of final order).
Hearing Officer failed to fully investigate/explore all facts pertinent to income,
medical insurance & support to multiple families.
The order is punitive & confiscatory given the Respondent's station in life and does
not make any allowances for Respondent's own medical expenses.
PARTY FILING DEMAND FOR HEARING;
~~
~~5-t2<
D#I
"
HARRY P. CASONI,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVll.. ACTION - DIVORCE
MARGARET A. CASONI,
DefendantJPetitioner
NO. 2002-930 CIVIL TERM
IN DIVORCE
DR# 31589
PacseS# 545104383
NOTICE OF RIGHT TO REOUEST A HEARING
The parties are hereby advised that they have until Jlllv 1.2002 to request a hearing do novo
before the Court. File request in person or mail to:
Office of the Prothonotary
1 Courthouse Square
Carlisle, PA 17013
.... ......
,.-~ .,
HARRY P. CASONI,
Plainti1flRespondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVll.. ACTION - DIVORCE
MARGARET A. CASON!,
Defendant/Petitioner
NO. 2002-930 CIVll.. TERM
IN DIVORCE
DR# 31589
PacseS# 545104383
DEMAND FOR HEARING
DATE OF ORDER: May 21,2002
AMOUNT: $687.00 per month plus $20.00 on arrears
FOR: Alimony Pendente Lite
REASON(S):
PARTY FILING DEMAND FOR HEARING:
Signature
Date
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ORDER/NOTICE TO WITH.!iPJ-D INCOME FOR SUPPORT
/)K:I , ~ 71 s..;;LeJO J
State Commonwealth of Pennsvlvania fll~<;~8, 3:L9IC5373f{ bIZ- 3oq3~
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 06/03/02
Court/Case Number (See Addendum for case summary)
t,Q... 315'6'1
A1CSfS ~b-I{)(./3~3
) RE: CASONI. HARRY P.
) Employee/Obligor's Name (Last, First, MI)
) 160-26-5245
) Employee/Obligor's Social Security Number
) 6892100834
) Employee/Obligor's Case Identifier
) (See Addendum for plaintiff names associated with cases on attachmen
) Custodial Parent's Name (Last, First, MI)
)
o Original Order/Notice
@ Amended Order/Notice
o Terminate Order/Notice
Employer/Withholder's Federal EIN Number
SOCIAL SECURITY ADMINISTRATION
Employer/withholder's Name
C/O MR. HEWITT
Employer/Withholder's Address
MINVERVA MILLS BLDG
401 E LOUTHER ST
CARLISLE PA 17013-2657
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 1 . 030 . 00 per month in cu rrent support
$ 50.00 per month in past-due support Arrears 12 weeks or greater? (Xlyes 0 no
$ 0.00 per month in medical support
$ o. 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 1, 080 . 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:
$ 249.23 per weekly pay period.
$ 498.46 per biweekly pay period (every two weeks).
$ 540.00 per semimonthly pay period (twice a month).
$ 1.080.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on pg. 2).
If remitting by EFT/EDI. please call Pennsylvania State Collections and Disbursement Unit (SCDUl Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
Service Type M
~n
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-
BY THE COURT:
7"
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/9.;</..
Date of Order:
JUN 4 2002
OMS No.: 0970-0154
Expiration Date: 12/31/00
Form EN-Ol8
Worker ID $OINC
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If checked you are required to provide a copy of this form to your employee.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income,
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment
to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to
each employee/obligor.
i
I
I
3.' Repolting tl,e Pay date/Date of Withholdirog. You ,,,ust ,epo,tthe paydateldate of "itl,l,oldilog "I ,el, sel,dirog the payro,e:',t. The!
paydate/date of "itl,l,oldi"g is the date 010 "hid, amotllot "as "ithheld fro,,, tl,e emplOyee's "ages. You must comply with the law ofth
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 f r
you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
WITHHOLDER'S ID: 8384100092
EMPLOYEE'S/OBLlGOR'S NAME: CASONI. HARRY P.
EMPLOYEE'S CASE IDENTIFIER: 6892100834 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, 0
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 (15 U.S.c. !j1673 (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.
10.
'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
Requesting Agency:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (7171 240-6248 or
by Internet @
I
I
Form EN-028 I
Worker ID $OIN~
I
!
I
Page 2 of 2
Service Type M
OMB No.: 0970-0154
Expiration Date: 12/31/00
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: CASONI, HARRY P.
32910373y' 309 3i
PACSES Case Number
Plaintiff Name
DONNA M. GOSS
Docket Attachment Amount
00671 S 2001 $ 250.00
Child(ren)'s Name(s):
1'lMll,J;;'J:''I'<::.GqSs
dAj:;;rtitND(GoSS
DOB
'" 1,1,/:!,4/.90
...,.....,iilla4.l~6
you are required to enroll the child(ren)
in any health insurance coverage available
through the employee'sJobligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s}:
DOB
you are required to enroll the child(ren}
in any health insurance coverage available
employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
you are required to enroll the child(ren)
in any health insurance coverage available
employee'sJobligor's employment.
Addendum
Service Type M
OMB No.: 0970-0154
Expiration Date: 12/31/00
PACSES Case Number 545104383/3/5"S '1
Plaintiff Name
MARGARET A. CASON!
Docket Attachment Amount
02-930 CIVIL $ 830.00
Child(ren)'s Name(s}:
DOB
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
you are required to enroll the child(ren}
in any health insurance coverage available
employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
i
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Form EN-028 I
Worker 10 $OIrC
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HARRY P. CASONI,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DOMESTIC RELATIONS SECTION
PACSES NO. 545104383
NO. 02-930 CIVIL TERM
V.
MARGARET A. CASONI,
DefendanUPetitioner
INTERIM ORDER OF COURT
AND NOW, this 13th day of August, 2002, upon consideration of
the Support Master's Report and Recommendation, a copy of which is attached
hereto as Exhibit "A", it is ordered and decreed as follows:
A. For the period of March 19, 2002, through August 31, 2002, the
husband shall pay to the State Collection and Disbursement Unit for
transmission to the wife as alimony pendente lite the sum of $659.00
per month.
B. Effective September 1, 2002, the husband shall pay to SCDU for
transmission to the wife as alimony pendente lite the sum of $541.00
per month.
C. The husband shall receive a credit towards arrearages in the amount
of $1,113.58 for payments made directly to or on behalf of the wife
during the period of March 19, 2002, through May 21, 2002.
D. The administrative provisions of the order of May 21, 2002, shall
remain in full force and effect.
The parties are hereby advised that they may file written exceptions to the
Support Master's Report and Recommendation within ten (10) days of this order.
Exceptions shall conform with the requirements of Rule 1910.12(f), Pa. R. C. P. If
written exceptions are filed by any party, the other party may file exceptions
within ten (10) days of the date of service of the original exceptions. If no
exceptions are filed within ten (10) days of this interim order, this order shall then
constitute a final order.
By the Court,
7' ;f.~
Kevin A. Hess, J.
CC: Harry P. Casoni
Margaret A. Casoni
Samuel L. Andes, Esquire
ORO
HARRY P. CASONI,
Plaintiff/Respondent
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DOMESTIC RELATIONS SECTION
PACSES NO. 545104383
NO. 02-930 CIVIL TERM
MARGARET A. CASONI,
DefendanUPetitioner
SUPPORT MASTER'S REPORT AND RECOMMENDATION
Following a hearing held before the undersigned Support Master on
August 6, 2002, the following report and recommendation are made:
FINDINGS OF FACT
1. The Plaintiff in the divorce action is Harry P. Casoni, who currently
resides at 441 Lamp Post Lane, Camp Hill, Pennsylvania, and whose
mailing address is P.O. Box 1104, Mechanicsburg, Pennsylvania.
2. The Defendant is Margaret A. Casoni, who currently resides at 2363
Hopi Lane, Ventura, California.
3. The parties are husband and wife having married on February 4, 1956.
4. The parties separated in February, 2002.
5. The husband filed an action in divorce on February 25, 2002.
6. On March 19, 2002, the wife filed a petition for alimony pendente lite
and request for hearing.
7. The husband has a child support obligation in the amount of $150.00
per month to Donna M. Goss for twin children to a case docketed to
671 Support 2001.
8. The husband's net monthly income is $2,001.00.1
9. The wife receives $203.00 per month from the Social Security
Administration as a result of the husband's retirement claim.2
10. The husband is 69 years of age, and the wife is 67.
1 For the purposes of this hearing, counsel for the Plaintiff has agreed that the Defendant's income as
detennined in the child support action could be utilized for APL purposes, provided, however, that
consideration should be given to potential income on the part of the husband from promotional sales.
2 The wife had received $459.00 per month prior to the entry of the child support order in the Goss case.
The wife's benefits were reduced when the Goss children began receiving benefits.
Exhibit "A"
11. The wife suffers from fibromyalgia and is unable to work.
12. The former marital residence of the parties has been sold, and the
sum of $155,834.87 representing the net proceeds of the sale is being
held in escrow pending resolution of the economic claims of the parties
in the divorce action.
13. Pending the distribution of said escrowed funds, the wife, by
agreement of the parties, is entitled to receive the interest generated
from said escrow account.
14. The annual percentage yield on said account is 2.27%.
15. Said account will generate approximately $295.00 of interest income
each month beginning in August, 2002.
16. The parties stipulated that the husband is to receive a credit of
$1,113.58 for direct payments made to or on behalf of the wife during
the period of March 19, 2002, through May 21, 2002.
17. The wife is residing in a townhouse owned by her son and is currently
paying no rent.
18. The wife has monthly expenses of approximately $1,200.00 per month
exclusive of her attorney's fees in the divorce.
19. The husband has monthly expenses of approximately $1,800.00 per
month exclusive of his attorney's fees.
20. In 2002, through the month of July, the Defendant earned
approximately $1,400.00 on promotional sales after expenses but
before taxes.
21. The regularity of the husband's income from promotional sales cannot
be predicted.
DISCUSSION
Whether to award alimony pendente lite has traditionally been a matter
within the discretion of the trial court. Litmans v. Litmans, 673 A.2d. 382 (Pa.
Super. 1996). If an award of APL is warranted, the amount of that award is
calculated in accordance with the support guidelines. Little v. Little, 47
Cumberland L. J. 131 (1998). Before that calculation is made, however, a
determination must be made as to the entitlement to the award. Clouse v.
Clouse, 50 Cumberland L.J. 167 (2001). To be entitled to an award of APL, a
claimant must show that APL is needed to adequately prosecute or defend the
divorce action. Litmans v. Litmans. suora. The purpose of APL is to prevent one
spouse from being financially disadvantaged during the pendency of the action
as compared to the other. Powers v. Powers, 615 A.2d. 459 (Pa. Super. 1992).
Traditionally the fact that one spouse may earn less than the other does not
automatically entitle him or her to an award of APL. Sutliff v. Sutliff, 474 A.2d.
599 (Pa. Super. 1984), overruled on other arounds, Rosen v. Rosen, 549 A.2d.
561 (Pa. Super. 1988). In determining whether an award of APL is appropriate in
a case, the trier of fact may consider the husband's ability to pay, the separate
estate and income of the wife, and the character, situation, and surroundings of
the parties. Orr v. Orr, 461 A.2d. 850 (Pa. Super. 1983).
The husband has income from two primary sources, a pension from the
Commonwealth and social security retirement benefits. Together they provide
him with a net monthly income of $2,001.00. The wife's income is minimal. She
receives social security as a result of the husband's claim in the amount of
$203.00 per month. She had been receiving $459.00 per month until the
husband's obligation to support twin children to Donna Goss was established.
Once Ms. Goss began receiving social security benefits on behalf of the children,
the wife's benefits were drastically reduced. The parties' marital residence has
been sold, and the net proceeds, nearly $156,000.00, have been placed in an
interest-bearing escrow account. This account will generate interest of
approximately $295.00 per month commencing in August, 2002. The husband
has agreed that pending the resolution of the economic claims in the divorce, the
wife will receive said interest. This will result in gross monthly income to the wife
of $498.00 beginning September 1, 2002.3 This income is not sufficient to meet
her basic needs.4 Consequently an award of APL is appropriate in this case.
The husband's APL obligation is calculated using lines 20 through 25 of
the formula set forth in Rule 191 0.16-4( a). The calculation is shown on Exhibit A
attached hereto. Under the guidelines the husband is obligated to pay $659.00
per month from March 19, 2002, through August 31,2002, and $541.00 per
month commencing September 1, 2002. With each party paying the premiums
for health insurance coverage for himself or herself only, the support rules do not
mandate an adjustment of the basic support obligation in this case.5
A support order, or in this case an APL order, calculated pursuant to the
guidelines is presumed to be correct, but the presumption may be rebutted by
evidence that the guideline amount of support is unjust or inappropriate under the
circumstances of the case. Landis v. Landis, 691 A.2d. 939 (Pa. Super. 1997).
3 The receipt of $295.00 per month in interest income will not result in a federal tax liability to the wife.
Because the wife is now a resident of California, and because no evidence was presented as to her potential
state and local tax liability, the wife's gross monthly income will be treated as if it were her net monthly
income to calculate the husband's APL obligation.
4 See Explanatory Comment to Rule 1910.16-2-1998 which states that an individual with a net monthly
income of $550.00 is "barely able to meet basic personal needs."
5 See Rule 1910.16-6(b).
Deviation from the guidelines is permitted only where special needs and/or
circumstances are present such as to render an award in the guideline amount
inappropriate. Elias v. Soencer, 673 A.2d. 982 (Pa. Super. 1996). It is
abundantly clear in this case that neither party will be able to meet his or her
current expenses as presented with the disposable income each will have after
the guideline order is paid. The uncertainty of the husband's generating
additional income from promotional sales precludes a recommendation of an
upward deviation in the award. No evidence presented by either party justifies a
deviation.
RECOMMENDATION
A. For the period of March 19, 2002, through August 31,2002, the
husband shall pay to the State Collection and Disbursement Unit
for transmission to the wife as alimony pendente lite the sum of
$659.00 per month.
B. Effective September 1, 2002, the husband shall pay to SCDU for
transmission to the wife as alimony pendente lite the sum of
$541.00 per month.
C. The husband shall receive a credit towards arrearages in the
amount of $1,113.58 for payments made directly to or on behalf of
the wife during the period of March 19, 2002, through May 21,
2002.
D. The administrative provisions of the order of May 21, 2002, shall
remain in full force and effect.
~\).~C01-
Date
I\.uu~ .LQ R~~
Michael R. Rundle
Support Master
HUSBAND'S APL OBLIGATION
(March 19, 2002 through August 31, 2002)
20. Obligor's Monthly Net Income
$2001
21. Less Obligor's support, alimony
pendente lite or alimony obligations,
if any, to children or former spouses
who are not part of this action
(150)
22. Less Obligee's Monthly Net Income (203)
23. Difference 1648
24. Multiply by 40% x .4
25. Amount of Monthly Spousal Support $659
or APL
(September 1, 2002 forward)
20. Obligor's Monthly Net Income
$2001
21. Less Obligor's support, alimony
pendente lite or alimony obligations,
if any, to children or former spouses
who are not part of this action
(150)
22. Less Obligee's Monthly Net Income
(498)
23. Difference
1353
24. Multiply by 40%
x .4
25. Amount of Monthly Spousal Support
or APL
$541
....
Exhibit "A"
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In the Court of Common Pleas of
Phone:
County, Pennsylvania
Fax:
Plaintiff Name:
Defendant Name:
Docket Number:
PACSES Case Number:
Other State ID Number:
Please note: All correspondeuce must include the PACSES Case Number.
Income and Exoense Statement
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 part, you must
also fill out the Supplemental Income Statement which appears on page two of this income and expense
statement. )
INCOME STATEMENT OF
Section I: Income and Insurance
~#~
.
INCOME:
Employer
Address
Type of Work
Payroll No. Gross Pay per Pay Period $
Itemized Payroll Deductions:
Pay Period (wlc1y., bi-wlc1y.. etc.)
Federal Withholding $ Social Security $ Local Wage Tax $
State Income Tax $ Retirement $ Savinas Bonds $
Credit Union $ Life Insurance $ Health Insurance $
Other Deductions (specity) $ $
$ $
Net Pay per Pay Period $
OTHER (Fill in Appropriate Column)
INCOME WEEK MONTH YEAR
Interest $ S $
Dividends
Pension
Annuitv
Social Securitv
Rents
Royalties
I ExDense Account
Gifts
Unemoloyment
Workmen's
ComoeDS8tion
Other
Other
TOTAL S S S
TOTAL INCOME $
Service Type
PROPERTY
OWNED
Ownership *
DESCRIPTION
VALUE H W J
Checking Accounts
Savings Accounts
Credit Union
Stocks/Bonds
Real Estate
Other
TOTAL S
* H=Husband; W=Wife; J-Joint
DIEFENDANT'S
EXHIBIT
) j-fH
Income and Expense Statement
PACSES Case Number
"eOTerage ..
INSURANCE \H W C
COMPANY POLICY #
HOlnilal ~-,.-~. ~. /t~ ~4_ ~ .I. _"'_ ~_A 1./ /<
Blue Cross
Other '/
Medical \
Blue Shield
Other
Hca11b1 Accident
Disability Income
Dental
Other
.. H=Husband; W=Wife; C=Child
Section IT: Supplemental Income Statement
a.
~ ~ is to be filled out by a pcrson
~ (I) who operates a business or practices a profession. or
D (2) who is a member of a partnership or joint venture, or
D (3) who is a shareholder in and is salaried by a closed cOlporation or similar entity.
Allach to this statement a copy of the following documents relating to the partnership, joint venture. business. profession.
cOlporation or similar entity:
(1) the most recent Federal Income Tax Return, and
(2) the most recent Profll and Loss Statement
~:::'f:n:s~~;~otlCnu~,.h~M~~~ h /7~ ~~
Nature of busUlCSS (checlt one)
b.
c.
d.
e.
D (I) partnership
D (2) joint venture
D (3) profession
D ..,..-<4) closed cOlporation
[jI' (5) other
Name of accountant. controller or other pcrson in charge of ftnancial records:
ffF~
f.
Annual income from business:
L~ }:1';:1"
(I) How oftAOn is income received?
(2) Gross income pcr pay pcriod:
(3) Net income pcr pay pcriod:
(4) Spcc:ilied deductions, iflny:
Page 20f3
Form IN-OOS
Worker ID
Service Type
Income and Expense Statement
Section ill: Exoenses
P ACSES Case Number
Instructions: Only show extraordinary expenses in this section unless you filled out Section n on page two. The categories
in BOLD FONT are especially important for calculating child support. If you are requesting Spousal Support! APL or if
you assert your case cannot be determined according to the guideline grids or formula. this section must be fully completed.
(Fill in Appropriate Column)
EXPENSES
WEEK MONTH YEAR
Home
MortgagelRt:nt $ $ 5"'M $
Maintenance
Utilities
Electric $ $ $
Gas
Oil
Telephone 4""'4"'
Water
Sewer
EmnlnVTnent
Public Tl'lIIlSIlort. $ $ $
Lunch
Taxes
Real eSlate $ $ $
Personal Property
Insuran....,
Homeowner's $ $ $
Automobile ~
Life
Accident
Health 1-7~
Other
Automobile
PaYlllCnts $ $ $
Fuel 6/1
Repairs _?~
Medical
Doctor $ $ $ AM
Dendst &t>t
Orthodontist 4M=
HospItaJ ~
MedIdne
~races. ?1/76
EXPENSES (Fill in Appropriall: Column)
(continued) WEEK MONTH YEAR
Education
Private School $ $ $
ParocbIal School
College
Rel~ious
Personal
Clothing $ $ _41 $
Food :1f"7r
Ba~r/ //J
Credit PaYlllCnts .!Ii
Credit Card
Charge
Memberships
Loans
Credit Union $ $ $
Miscellaneous
Household Help $ $ $
CbiJd care
Paperslbooks
Entertainment -"/I
Pay TV
Vacation
Gifts /0
Legal fees
-';~bl~
<i....::;bOd '?r".
AlImony
P ".-
Other
?, $ $ #;' $
--,
I ~:~nses: I $ WEEK $ ~f;/ $ ;:I{~ I I
I verify that the statements made in this Income and Expense Statement are true and correct. I understand that false
statements herein are subject to the criminal penalties of 18 Pa. C.S. ~ 4904. re g to unsworn fa . cation to authorities.
~6-1J,e
Date
Service Type
Page 3 of3
Form IN-008
Worker ID
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
~d. (,7/ S' .:x;O/
State Commonwealth of Pennsvlvania .l'1'Je~ 361- 9/o~ 7~?
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 08/14/02 bit:.... 3t:)9~8
Court/Case Number (See Addendum for case summary) j)~l.S SV5"IO~J g~
) RE: CASONI, HARRY P.
) Employee/Obligor's Name (last, First, Mil
) 160-26-5245
) Employee/Obligor's Social Security Number
) 6892100834
) Employee/Obligor's Case Identifier
) (See A.ddendum for plaintiff names associated with cases on attachment)
) Custodial Parent's Name (last, First, Mil
)
o Original Order/Notice
@ Amended Order/Notice
der/Notice
~J! 3/sG-,
Employer/\Nithholder's Federal EIN Number
SOCIAL SECURITY ADMINISTRATION
Employer/\Nithholder's Name
C/O MR. HEWITT
Employer/\Nithholder's Address
MINVERVA MILLS BLDG
401 E LOUTHER ST
CARLISLE PA 17013-2657
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'sfobligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 809.00 per month in current support
$ 50.00 per month in past-due support Arrears 12 weeks or greater? @yes 0 no
$ 0.00 per month in medical support
$ 0 . 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 859.00 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:
$ 198.23 per weekly pay period.
$ 396.46 per biweekly pay period (every two weeks).
$ 429.50 per semimonthly pay period (twice a month).
$ 859.00 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 paydateldate of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee'sf obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on pg. 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
Date of Order:
AUa 15 _
BY THE COURT:
5--
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Service Type M
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OMB No.: 0970-0154
Expiration.Date: 12/31/00
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Form EN-028
Worker ID$OINC
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
D If checked you are required to provide a copy of this form to your employee.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment
to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to
each employee/obligor.
3. * Repoltilog tl,e P3.ydatelDate of Withholdilog. V\'ltl must lepoltthe p3.ydateldate of ..ithl ,olding ..hen sendil ,g tl,e "ayn,e"t. TI,e
paydate!date of ..ithholdh,g is tl,e date 010 ..hid, al"otll ,t ..as ..ill ,held flon. lhe el"ployee's ..ages. 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 Oroer/Notices due to Federal or State withholding limits, you must
follow the law ofthe 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. Tennination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for
you. Please provide the infonnation requested and retum a copy of this Order/Notice to the Agency identified below.
WITHHOLDER'S ID: 8384100092
EMPLOYEE'S/OBlIGOR'S NAME: CASONI, HARRY P. \
EMPLOYEE'S CASE IDENTIFIER: 6892100834 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-{jiscrimination: You are subject to a fine detennined 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 govems unless the obligor is employed in another State, in which case the law of the State in which he or she is
employed governs.
9. * Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.S.c. 91673 (b)l; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes.
10.
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
Requesting Agency:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (7171 240-6248 or
by Internet @
Page 2 of 2
Form EN-028
Worker ID $OINC
Service Type M
OMS No.: 0970-0154
Expiration Date: 12/31/00
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: CASONI, HARRY P.
PACSES Case Number 329103738 /~D'3 9"
Plaintiff Name '/ .
DONNA M. GOSS
Docket Attachment Amount
oorns 2001 $ 200.00
Child(ren)'s Name(s):
.~i~~jg;i>i'"
DOB
"',',,1}./:!4;/,~,O
:ttI2:41~d
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
>~:;,:::,:: :\:::;:;::::::;:,:,'</:::::::'::::::,:".:::;:::::::.'>>:::'::/::':,},::::\:::<</ ::,::::::; ::'::::.{ :;<:;:::: ::.'>>>>:\:':::';<:":::::\ :;'::;: :::: ::,:{:::'<::"'; :.:
.... .. ... ....... ........ .... ......... .........................
o If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee'slobligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
...".................,.....,..
',;:/ .::;:,::,::;..::::;:;\,:<:;':::.";.:;}:<;::\.::;..
tJ If~hecl<l'!d, y~u are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee'slobligor's employment.
Service Type M
Addendum
OMB No.: 0970-0154
Expiration Date: 12/31/00
PACSES Case Number 545104383/~I'5'r'
Plaintiff Name
MARGARET A. CASONI
Docket Attachment Amount
02~CIVIL $ 659.00
Child(ren)'s Name(s):
DOB
"/.' ":<:;:::":::::;,'::'::/:; '.:::;.:";..:: . '::<:: :'::;.';::0::':.;:' :::;'::;::::..".
Dlf~;'eck~, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee'slobligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
:..';.;...,...:-;.;.....,..;..;.:,'.;'.;.;.;.; ;'", ";";':"';',;
. "," .... ..... ... . ...,..
' ,"',",. ,..,.... ..,.,.....
. ...",",. .." . ..... ...
.. ," ... ," .... .... . ...
.... .... ..... ... .
o If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee'slobligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s}:
DOB
tiii~~~~~~~~~~~~ required to enroll the Chil~i;~~;i/..
identified above in any health insurance coverage available
through the employee'slobligor's employment.
Form EN-028
WorkerlD $OINe
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
lJi/. t; u S ~oI
,4t}(!Sf$ 32 '7/037~ 'I
~ jo't3fJ
~~fS 'WS10C/'5~$ p/l. 9/sf9
) RE: CASONI, HARRY P.
) Employee/Obligor's Name (Last, First, Mil
) 160-26-5245
) Employee/Obligor's Social Security Number
) 6892100834
) Employee/Obligor's Case Identifier
) (See Addendum for plaintiff names associated with cases on attachment)
) Custodial Parent's Name (Last, First, Mil
)
o Original Order/Notice
@ Amended Order/Notice
Terminate Order/Notice
State Commonwealth of Pennsylvania
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 08/28/02
Court/Case Number (See Addendum for case summary)
EmployerMiithholder's Federal EIN Number
SOCIAL SECURITY ADMINISTRATION
EmployerMiithholder's Name
C/O MR. HEWITT
EmployerMiithholder's Address
MINVERVA MILLS BLDG
401 E LOUTHER ST
CARLISLE PA 17013-2657
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMA nON: 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's1obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 809 . 00 per month in current support
$ 0 . 00 per month in past-due support Arrears 12 weeks or greater? <X) yes 0 no
$ 0.00 per month in medical support
$ 0 . 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 809 . 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:
$ 186.69 per weekly pay period.
$ 373.38 per biweekly pay period (every two weeks).
$ 404.50 per semimonthly pay period (twice a month).
$ 809.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's! obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on pg. 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
/9. 4...
Date of Order: Alln 2 9 ZOOZ
Service Type M
.:n..;M €
Form EN-028
Worker ID $OINC
O,e/~
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
D If checked you are required to provide a copy of this form to your employee.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment
to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to
each employee/obligor.
3.' Repo!ti"g tl,e F'aydatefDate of 'Nithholding. You must repo!t the paydateJdate of "itl,l,oldi"g ...I,eio sending the payl"e! ,t. TI,e
paydate/date of "itl ,I ,oldi! ,g is tI ,e date on "hieh amoUl ,t "as "itl ,held from the emplOyee's "ages. 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'slobligor's principal place of employment. You must honor all Orders/Notices to the greatest
extent possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for
you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
WITHHOLDER'S ID: 8384100092
EMPLOYEE'S/OBLlGOR'S NAME: CASONI , HARRY P.
EMPLOYEE'S CASE IDENTIFIER: 6892100834 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
un less the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
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 F€deral Consumer Credit
Protection Act (15 U.S.c. 91673 (b)l; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes: Social Security taxes: and Medicare taxes.
10.
'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
Requesting Agency:
DOMESTIC RElA nONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (7171 240-6248 or
by Internet @
Page 2 of 2
Form EN-028
Worker ID $OINC
Service Type M
OMS No.: 0970-0154
Expiration Date: 12/31/00
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: CASONI, HARRY P.
PACSES Case Number 329103738 I ~'~'i
Plaintiff Name I .
DONNA M. GOSS
Docket Attachment Amount
0067lS 2001 $ 150.00
Child(ren)'s Name(s):
I3Jl,llBW'J:''J:'C::, ,c;()SS
CAITLINP;Gdsll
DOB
!}I:1~/~q
11/24/90
you are required to enroll the child(ren)
in any health insurance coverage available
the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
o If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
Service Type M
Addendum
OMB No.: 0970-0154
Expiration Date: 12/31/00
PACSES Case Number 545104383 / ~S'"ft,
Plaintiff Name / ·
MARGARET A. CASONI
Docket Attachment Amount
02=93()CIVIL $ 659.00
Child(ren)'s Name(s):
DOB
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor'S employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
you are required to enroll the child(ren)
in any health insurance coverage available
employee'slobligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
you are required to enroll the chiJd(ren)
in any health insurance coverage available
employee'slobligor'S employment.
Form EN-028
Worker ID $OINC
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State Commonwealth of Pennsylvania
Co.lCity/Dist. of CUMBERLAND
Date of Order/Notice 09/02/02
Court/Case Number (See Addendum for case summary)
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
oJ/, (P71 S .;..tJa/
PI'J(!SeJ' 3d.9/~7~1
M '()9~~
o Original Order/Notice
mended Order/Notice
Terminate Order/Notice
?liS" loI/~ 8'3
bit.. .A/S'f" ,
) RE: CASONI, HARRY P.
) Employee/Obligor's Name (Last, First, MI)
) 160-26-5245
) Employee/Obligor's Social Security Number
) 6892100834
) Employee/Obligor's Case Identifier
) (See Addendum for plaintiff names associated with cases on attachment)
) Custodial Parent's Name (Last, First, MI)
)
Employer/Withholder's Federal EIN Number
SOCIAL SECURITY ADMINISTRATION
Employer/Withholder's Name
C/O MR. HEWITT
Employer/Withholder's Address
MINVERVA MILLS BLDG
401 E LOUTHER ST
CARLISLE PA 17013-2657
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee'sfobligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 691.00 per month in current support
$ 0 . 00 per month in past-due support Arrears 12 weeks or greater? G9 yes 0 no
$ 0.00 per month in medical support
$ 0 . 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 691 . 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:
$ 159.46 per weekly pay period.
$ 318.92 per biweekly pay period (every two weeks).
$ 345.50 per semimonthly pay period (twice a month).
$ 691.00 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 paydateldate of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee'sf obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on pg. 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
SEP 3 2002
BY THE COURT:
7.~
I(GwA/' 1'1-. N-E;.~
~
Date of Order:
Service Type M
."..~~~D
.' ',' '. ".' '\~ . '1 t~1_ ~,c -'
_c........';f'.;1.; ;,.~ et-lU'J. '
OMB No.: 0970-0154
Expiration Date: 12/31/00
~4.6
Form EN-028
Worker I D $OINC
{J,<!,I(p
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If checked you are required to provide a copy of this form to your employee.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment
to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to
each employee/obligor.
3.' Repo,til,g tl.e F'ayddtefDate ofWitl,noldi"g. You I,~dst lepolt tl,e paydaleklate of "itl,holdil,g "hel, sel,dil,g II,e payl"ellt. The
paydatefdate of "itl,I,olding is tl,e date 01. "I.id, al"Odl,t "as "ill,l,eld flon111,e el"flloyee's "ages. 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.
WITHHOLDER'S ID: 8384100092
EMPLOYEE'S/OBLlGOR'S NAME: CASONI , HARRY P.
EMPLOYEE'S CASE IDENTIFIER: 6892100834 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 (15 U.S.c. 91673 (b)l; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes.
10.
'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
Requesting Agency:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717) 240-6248 or
by Internet @
Page 2 of 2
Form EN-028
Worker ID $OINe
Service Type M
OMB No.: 0970-0154
Expiration Dale: 12131/00
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: CASONI, HARRY P.
329103730D'I31
PACSES Case Number
Plaintiff Name
DONNA M. GOSS
Docket Attachment Amount
006'71S 2001 $ 150.00
Child(ren)'s Name(s):
BARRETT C. GOSS
dMTLINtl.GbSS
DaB
:L11~~/ 99
11/24/9.0
you are required to enroll the child(ren)
in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
D If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
.',".',',',',',',' :-"0' ''''.-.,._.-.',_','.',''',',,',.,',.
:<::;:::'::::::,:,:::,:::;,:,-.;..,::,,-::::-:-:::-:-::::<::
D If checked,~ouare req~i;~dt~ ~~r~ll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Service Type M
PACSES Case Number 545104383/,3/511'
Plaintiff Name
MARGARET A. CASONI
Docket Attachment Amount
02~CIVIL $ 541.00
Child(ren)'s Name(s):
DaB
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
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o If ~l1ecked, y~uare r~~~i~~t~~~rollth~ ~11i1d(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Addendum
Form EN-028
Worker ID $OINC
OMS No,: 0970-0154
Expiration Date: 12/31/00
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HARRY P. CASONI
PLAINTIFF
V.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
NO. 02 - 930 CIVIL TERM
MARGARET A. CASONI
DEFENDANT
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in Divorce under Section 3301 ( c ) of the Divorce Code was
filed on February 25, 2002.
2. The marriage of Plaintiff and Defendant is irretrievably broken and (90) days
have elapsed from the date of the filing and service of the Complaint.
3. I consent to the entry of a Final Decree of Divorce after service of notice of
intention to request entry of the decree. I acknowledge that pursuant to Rule 1920.42 (a)
I have waived the requirement that I receive 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating
to unsworn falsification to authorities.
Dated: //- ~7-tt7...<
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HARRY P. CASONI
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 02 - 930 CIVIL TERM
MARGARET A. CASONI
DEFENDANT
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301 (c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses ifI do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the court
and that a copy of the decree will be sent to me immediately after it is filed with the
prothonotary.
I verifY that the statements made in this Affidavit are true and correct. I understand that
false statements herein are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsification to authorities.
Dated://- vf )1,- c/~
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HARRY P. C NI
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HARRY P. CASONI
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 02 - 930 CML TERM
MARGARET A. CASONI
DEFENDANT
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in Divorce under Section 3301 (c) of the Divorce Code was
filed on February 25,2002.
2. The marriage of Plaintiff and Defendant is irretrievably broken and (90) days
have elapsed' from the date of the filing and service of the Complaint.
3. I consent to the entry of a Final Decree of Divorce after service of notice of
intention to request entry of the decree. I acknowledge that pursuant to Rule 1920.42 (a)
I have waived the requirement that I receive 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating
to unsworn falsification to authorities.
Dated:
JJ I D it Ic;)..
~A~.
MARG T A. CASONI
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HARRY P. CASONI
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 02 - 930 CIVIL TERM
MARGARET A. CASONI
DEFENDANT
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301 (c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if! do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the court
and that a copy of the decree will be sent to me immediately after it is filed with the
prothonotary
I verify that the statements made in this Affidavit are true and correct. I understand that
false statements herein are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsification to authorities.
Dated:
JI / }'('/6.2.
[ ? (!~
MAR~~~SONI '
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Guy H. Brooks, Esquire
GOLDBERG, KATZMAN & SHIPMAN, P.C.
P.G. Box 1268
Harrisburg, PA 17108-1268
Attorney I.D. No: 49672
Attornev for Defendant. Penn Mutual
GREAT-WEST LIFE & ANNUITY,
INSURANCE COMPANY,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
No. 02-980 Civil Term
PENN MUTUAL LIFE INSURANCE
COMPANY and TODD PERRY,
Defendants
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
CERTIFICATE PREREQUISITE TO SERVICE
OF A SUBPOENA PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22,
Plaintiff hereby certifies that:
1) A Notice of Intent to serve the subpoena, with a copy of the subpoena attached
thereto, was mailed or delivered to each party at least twenty days prior to the date on
which the subpoena was sought to be served;
2) A copy of the Notice of Intent, including the proposed subpoena, is attached to this
certificate;
3) Plaintiff has not received any objections to the subpoena being served upon Fulton Bank;
and
4) The subpoena to be served is identical to the subpoenas attached to the Notice of
Intent.
GO~~~~
By:
DATE: 11125/02-.
Guy H. Brooks, Esquire
Attorney 1.0. #49672
320 Market Street
P.O. Box 1268
Harrisburg, PA 17108-1268
Telephone: (717) 234-4161
Attorneys for Defendant, Penn Mutual life Insurance Company
Guy H. Brooks, Esquire
GOLDBERG, KATZMAN & SHIPMAN, P.C.
P,O, Box 1268
Harrisburg. P A 17108-1268
Attorney LD. No: 49672
Attornev for Defendant. Penn Mutual Life Insurance Comnanv
GREAT-WEST LIFE & ANNUITY,
INSURANCE COMPANY,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
No. 02-980 Civil Term
PENN MUTUAL LIFE INSURANCE
COMPANY and TODD PERRY,
Defendants
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NOTICE OF INTENT TO SERVE SUBPOENA TO
PRODUCE DOCUMENTS AND THINGS FOR
DISCOVERY PURSUANT TO RULE 4009.21
TO: John MeN. Cramer, Esquire
Reed Smith LLP
213 Market Street, 9th Floor
Harrisburg, PA 17101
WiIliam P. Thornton, Jr., Esquire
Stevens & Lee, PC
P.O. Box 679
111 North Sixth Street
Reading, PA 19603-0679
PLEASE TAKE NOTICE that Plaintiff intends to serve subpoenas identical to those
attached to this notice. You have twenty (20) days from the date listed below in which to file of
record and serve upon the undersigned an objection to the subpoenas. If no objection is made,
the subpoenas may be served.
GOLD~~ &SHIP~. P.c.
B" ~ .~
Guy H. Brooks, Esquire
Attorney 1.0. #49672
320 Market Street
P.O. Box 1268
Harrisburg, P A 17108-1268
Telephone: (717) 234-4161
Attorneys for Defendant,
Penn Mutual Life Insurance Company
DATE: /0/31/02-
COMMONWEALTH OF PENNSYLVANIA
COUNTI OF CUMBERLAND
GREAT-WEST LIFE & ANNUITY,
INSURANCE COMPANY,
Plaintiff
IN TIIE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYL VANIA
No. 02-980 Civil Term ..
PENN MUTUAL LIFE INSURANCE
COMPANY and TODD PERRY,
Defendants
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 400Q.2:i!
TO: Custodian of Records for FULTON BANK
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the
following documents or things: Anv and all documents l'e1!ardin2 Commercial Loan Number 71.';2::1.';6-Q001
issued to Todd A. Perry. includin2 but not limited to the orilrinalloan aoolication. installment oavrnents.
letters. assi2nments, UCC documents and notices of loan satisfactio~ at Goldberg, Katzman & Shipman, P.C.,
320 Market Street, P.O. Box 1268, Harrisburg, PA 17108-1268.
You may deliver or mail legible copies of the documents or produce things requested by this subpoena,
together with the certificate of compliance, to the party making this request at the address listed above. You
have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its
service, the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OFTHE FOLLOWING PERSON:
NAME:
ADDRESS:
Guv H. Brooks . F.sauire
::120 Market Street, Strawberry Sauare
Harrisbul'l!:. FA 17108-1 268
(717) 2::14-4161
4Q672
TELEPHONE:
SUPREME COURT ID #
-----
DATE: ~ .lc:>, ..206 do......
Seal of the Court
(Eff.7/97)
'.
CERTIFICATE OF SERVICE
I, Mary K. Ridings, Paralegal w/Goldberg, Katzman & Shipman, P.c. do hereby certify that on
this ,,~i'" r day of (J::31)bVL- ,2002, a true and correct copy of the foregoing NOTICE OF
INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS OR THINGS was selYed upon the
following by depositing same into the United States Mail, first-class mail, postage pre-paid, to:
John MeN. Cramer, Esquire
Reed Smith LLP
213 Market Street, 9th Floor
Harri sburg, PAl 710 1
William P. Thornton, Jr., Esquire
Stevens & Lee, PC
P.O. Box 679
III North Sixth Street
Reading, PA 19603-0679
GOLDBERG, KATZMAN & SHIPMAN, P.c.
BY:
CERTIFICATE OF SERVICE
2511 I, Mary Xl Ridinbs, Paralegal w/Goldberg, Katzman & Shipman, P. C. do hereby certify that on this -
day of /) VtrYI Lr, 2002, a true and correct copy of the foregoing CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA TO PRODUCE DOCUMENTS OR THINGS was
selYed upon the following by depositing same into the United States Mail, first-class mail, postage pre-
paid, to:
John MeN. Cramer, Esquire
Reed Smith LLP
213 Market Street, 9th Floor
Harrisburg, PAl 710 I
William P. Thornton, Jr., Esquire
Stevens & Lee, PC
P.O. Box 679
11 I North Sixth Street
Reading, PA 19603-0679
GOLDBERG, KATZMAN & SHIPMAN, P. C.
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DEj{o 2002
HARRY P. CASONI,
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 02-930 CIVIL TERM
MARGARET A. CASONI,
IN DIVORCE
ORDER FOR ALIMONY
AND NOW, this L' 0#- day of ~ ,2002, on the basis of
the Property Settlement Agreement between the parties, and the stipulation of their
counsel attached hereto, we hereby order as follows:
1. The Plaintiff Harry P. Casoni (hereinafter "Husband") shall pay to
the Defendant Margaret A. Casoni (hereinafter "Wife") alimony in the amount
of $600.00 per month, commencing with the month following the entry of a
final decree in this divorce action. Husband's payment shall be made on the
fifth day of that month and on each consecutive month thereafter.
2. Husband shall authorize his lending institution to permit a direct withdraw from
his account within that institution and a direct deposit into Wife's lending institution to
make the monthly payments electronically on the fifth day of each month or the next
business day thereafter.
3. The order previously entered in this action obligating Husband to pay alimony
pendente lite or spousal support to Wife shall terminate at the end of the month in which
the final decree in divorce between the parties is entered.
BY THE COURT,
Distribution:
J.
Thomas D. Gould, Esquire (Attorney for Plaintiff)
2 East Main Street, Shiremanstown, PA 17011
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3d e> 1- Samuel L. Andes, Esquire (Attorney for Defendant)
525 North 12th Street, Lemoyne, PA 17043
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AND NOW this ~ 7"'" day of ,.1'1/""""'- , 2002, the above-named
parties, by their undersigned attorneys, hereby stipulate and agree that the court shall
enter the attached Order for Alimony to implement one of the provisions of the Property
Settlement Agreement reached between the parties.
11
HARRY P. CASONI,
vs.
MARGARET A. CASONI,
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 02-930 CIVIL TERM
IN DIVORCE
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Thomas D. Gould
Attorney for Plaintiff
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Attorney for Defendant
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Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
MARGARET A. CASONI,
Defendant
NO. 02-930 CIVIL TERM
IN DIVORCE
ACCEPTANCE OF SERVICE
I acknowledge receipt of service of a copy of the Divorce Complaint filed in this
matter on or about February 27, 2002 and accept servicE! of the Complaint as of that date
on behalf of the Defendant, Margaret A. Casoni.
4 December 2002
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HARRY P. CASONI,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 02-930 CIVIL TERM
MARGARET A. CASONI,
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
o THE PROTHONOTARY:
Transmit the record, together with the following information, to the Court for entry of a divorce
ecree:
1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c).
2. Date and manner of service of the Complaint: Acceot.ance of Service filed bv Defendant's
ounsel indicatin service on or about 27 Februar 2002.
3. Complete either Paragraph (a) or (b):
(a) Date of execution of the Affidavit of Consent required by Section 3301 (c)
of the Divorce Code: By Plaintiff: 29 November 2002 By Defendant: 18 November
2002
(b) (1) Date of execution of the Affidavit required by Section 3301 (d) of the
Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit
upon the Respondent:
4. Related claims pending:
None.
5. Complete either (a) or (b):
(a) Date and manner of service of the Notice of Intention to File Praecipe to
Transmit Record, a copy of which is attached:
(b) Date Plaintiff's Waiver of Notice in Section 3301 (c) Divorce was filed with
the Prothonotary: Dated 29 November 2002, and filed on :2 December 2002. Date
Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the
Prothonotary: Dated 18 November 2002, and filed on 2 December 2002.
Date: 4 December 2002
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Attorney for Defendant
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
HARRY P. CASONI,
PENNA.
STATE OF
PLAINTIFF
No.
02-930 CIVIL TERM
VERSUS
MARGAREr A. CASONI,
DEFENDANT
DECREE IN
DIVORCE
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AND NOW,
, ~o 2---, IT IS ORDERED AND
DECREED THAT
HARRY P. CASONI
, PLAINTIFF,
MARGAREr A. CASCNI
AND
, 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;
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HARRY P. CASONI :
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 02-930 CIVIL TERM
MARGARET A CASONI
Defendant
IN DIVORCE
STIPULATION FOR THE ENTRY OF "DOMESTIC RELATIONS ORDER"
AND NOW, this gj{ day of J11~ ,2006, the parties, Harry P. Casom, Plaintiff,
and Margaret A. Casoni, Defendant do ~e and Stipulate as follows:
1. The Plaintiff, Harry P. Casom, (hereinafter referred to as "Member") is a member
of the Commonwealth of Pennsylvania State Employees' retirement System
(hereinafter referred to as "SERS").
2. SERS, as a creature of statute, is controlled by the State Employees' Retirement
Code, 71 Pa. C.S. ~~5101-5956 ("Retirement Code").
3. Member's date of birth is May 4, 1933 and his Social Security number is 160-26-
5245.
4. The Defendant, Margaret A. Casoni, (hereinafter referred to as "Alternate Payee")
is the former spouse of Member. Alternative Payee's date of birth is April 4,
1935 and her Social Security number is 209-26-7405.
5. Member's last known mailing address is:
PO Box 1104, Mechanicsburg, PA 17055
6. Alternative Payee's last known mailing address is:
6804 Shadow Mountain Road, San Jose, California 95120
It is the responsibility of Alternate Payee to keep a current mailing address on file
with SERS at all times.
7. Member and Alternate Payee acknowledge that the Member's retirement benefit
is currently in pay status pursuant to the terms of Option 1. The Alternate Payee's
2
,
share of the Member's retirement benefit is $600 of the monthly annuity
payments made to or on behalf of the Member, together with 100% of any death
benefit payable by SERS upon the death of the Member.
8. Member's retirement benefit is defined as all monies paid to or on behalf of
Member by SERS excluding or ad hoc increases, and the disability portion of any
disability annuities paid to Member by SERS as a result of a disability which
occurs before member's marriage to Alternate Payee or after the date of
Member's and Alternate Payee's final separation. Member's retirement benefit
does not include any deferred compensation benefits paid to Member by SERS or
any enhancements to the Member's retirement benefit arising from post
separation monetary contributions made by Member. The equitable distribution
portion of the marital property component of Member's retirement benefit as set
forth in Paragraph Seven (7), shall be payable to Alternate Payee and shall
commence as soon as administratively feasible and SERS approves a Domestic
Relations Order incorporating this Stipulation and Agreement.
9. Member hereby nominates Alternate Payee as an irrevocable beneficiary to the
extent of Alternate Payee's equitable distribution portion of Member' s retirement
benefit for any death benefits payable by SERS. This nomination shall become
effective upon approval by the Secretary, of any Domestic Relations Order
incorporating this Stipulation and Agreement. The balance of any death benefit
remaining after the allocation of the equitable distribution portion payable to
Alternate Payee and any other alternate payees named under other SERS-
approved Domestic Relations Orders ("Balance") shall be paid to the beneficiaries
named by Member on the last Nomination of Beneficiaries Form filed with the
Retirement Board prior to Member's death.
If the last Nomination of Beneficiaries Form filed by Member prior to Member's
death (a) predates any approved Domestic Relations Order incorporating this
Stipulation and Agreement, and (b) names Alternate Payee as a beneficiary, then:
(1) the terms of the Domestic Relations Order shall govern Alternate Payee's
share of any death benefit, and (2) for purposes of paying the Balance via the last
Nomination of Beneficiaries Form filed with the Retirement Board prior to
Member's death, Alternate Payee shall be treated as if Alternate Payee
predeceased Member. No portion of the Balance shall be payable to Alternate
Payee's estate.
In addition, Member shall execute and deliver to Alternate Payee an
authorization, in a form acceptable to SERS, which will authorize SERS to release
to Alternate Payee all relevant information concerning Member's retirement
account.
3
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10. The Member and Alternate Payee acknowledge that the Member is retired and
elected to receive an annuity pursuant to the terms of Option 1. The parties
understand that the Member's retirement option elections are final, binding and
irrevoca11le.
11. Alternate Payee may not exercise any right or option offered by SERS. SERS
shall issue individual tax forms to Member and Alternate Payee for amount paid
to each.
12. In the event of the death of Alternative Payee prior to receipt of all of payments
payable from SERS under a Domestic Relations Order incorporating this
Stipulation and Agreement, any death benefit or retirement benefit payable to
Alternate Payee by SERS shall revert to Member.
13. In no event shall Alternative Payee have greater benefits or rights other than those
that are available to Member. Alternative Payee is not entitled to any benefit not
otherwise provided by SERS. Alternate Payee is only entitled to the specified
benefits offered by SERS as provided in this Stipulation and Agreement. All
other rights, privileges and options offered by SERS not granted to Alternative
Payee by this Stipulation and Agreement are preserved for by Member. Member
and Alternative Payee acknowledge that benefits paid pursuant to this Stipulation
and Agreement are and shall remain subject to the Public Employee Pension
Forfeiture Act, 43 P.S. ~1311, et seq.
14. It is specifically intended and agreed by the parties hereto that any Domestic
Relations Order incorporating this Stipulation and Agreement:
a. Does not require SERB to provide any type of benefit, or option, not
otherwise provided under the Retirement Code.
b. Does not require SERS to provide increased benefits.
15. The Parties intend and agree that the terms of this Stipulation and Agreement
shall be approved, adopted and entered as a Domestic Relations Order.
16. The Court of Common Pleas of Cumberland Count, Pennsylvania, shall retain
jurisdiction to amend any Domestic Relations Order incorporating this Stipulation
and Agreement, but only for the purposes of establishing it or maintaining it as a
Domestic Relations Order; provided, however that such amendment shall nottrequire SERS to provide any type or form of benefit, or any such option not
otherwise provided by SERS, and further provided that such amendment or right
of the Court to so amend will not invalidate the parties existing Domestic
Relations Order.
4
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17. Upon entry as a Domestic Relations Order incorporating this Stipulation and
Agreement, a certified copy of the Domestic Relations Order and this Stipulation
and Agreement and any attendant documents shall be served upon SERS
immediately. Such Domestic Relations Order shall take effect immediately upon
SERS approval and SERS approval of any attendant documents and then shall
remain in effect until such time as a further Order of Court amends or vacates the
Domestic Relations Order.
IN WITNESS WHEREOF, the parties, intending to be legally bound by the
Stipulation and Agreement do hereunto place their hands,
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: MAY 1 0 2006
IN TIlE COURT OF COMMONC .~t~
CUMBERLAND COUNTY, PENNSYLVANIA
o~
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vs.
No. 02-930 CIVIL TERM
MARGARET A CASONI
Defendant
IN DIVORCE
ORDER
AND NOW, this I" day of ",~ . 2006, the attached Stipulation and Agreement
.4ated _ of the parties in this case is incorporated, but not merged into this Order of
Court.
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