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HomeMy WebLinkAbout05-0710MICHELLE E. RAUDABAUGH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE, CUSTODY TOM L. RAUDABAUGH, Defendant : NO. 2004 7/D CIVIL TERM COMPLAINT FOR DIVORCE, CUSTODY, ALIMONY, EQUITABLE DISTRIBUTION AND ALIMONY PENDENTE LITE AND COSTS Plaintiff, Michelle E. Raudabaugh, by her attorneys, the Family Law Clinic, sets forth the following cause of action: COUNTI DIVORCE UNDER 23 Pa.C.S. § 3301(c) or 53301(d) OF THE DIVORCE CODE 1. Plaintiff is Michelle E. Raudabaugh, who currently resides at 119 Oxford Road, Gardners, Cumberland County, Pennsylvania, 17324. 2. Defendant is Tom L. Raudabaugh, who currently resides at 720 Bloserville Road, Newville, Cumberland County, Pennsylvania, 17241. 3. Plaintiff has been a bona fide resident of Cumberland County and the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on July 11, 1998 in Newville, Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since July 15, 2004. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that Plaintiff or Defendant may have the right to request that the court require the parties to participate in counseling. WHEREFORE, Plaintiff requests the court to enter a decree of divorce dissolving the marriage. COUNT II CUSTODY 9. Plaintiff repeats and realleges paragraphs one through eight. 10. Plaintiff seeks custody of the following children: Name Present Residence Melody Renee Hershey-Raudabaugh Cheyenne Grace Hershey-Raudabaugh Geraldine Brianna Hershey-Raudabaugh Harold Levi Hershey-Raudabaugh 119 Oxford Road, Gardners, PA 119 Oxford Road, Gardners, PA 119 Oxford Road, Gardners, PA 119 Oxford Road, Gardners, PA Age 6 5 3 3 All of the children, except Melody Renee Hershey-Raudabaugh, were bom during wedlock. Melody Renee Hershey-Raudabaugh was born prior to wedlock. The children are presently in the custody of Plaintiff, who resides at 119 Oxford Road, Gardners, PA. 11. During the past five years, the children have resided with the following persons and at the following addresses: Persons Addresses Dates Michelle Raudabaugh 427 N. Mountain Road, Newville, PA 1998 until July 1999 Tom Raudabaugh Same 4100 Enola Road, Apt. 1, Newville, PA July 1999 - March 2003 Same 720 Bloserville Rd., Newville, PA March 2003 - July 2004 Michelle Raudabaugh Shirley Rhinehart Henry Rhinehart (Grandparents) 119 Oxford Road, Gamders, PA July 2004 - Present The mother of the children is Plaintiff, Michelle Raudabaugh, currently residing at 119 Oxford Road, Gardners, PA. She is currently married to Defendant, Tom Raudabaugh. The father of the children is the Defendant, who currently resides at 720 Bloserville Road, Newville, PA. Defendant is currently married to Plaintiff, Michelle Raudabaugh 12. The relationship of Plaintiff to the children is that of mother. Plaintiff currently resides with the following persons: Name Relationship Shirley Rhinehart Parent Henry Rhinehart Parent Melody Renee Hershey-Raudabaugh Child Cheyenne Grace Hershey-Raudabaugh Child Geraldine Brianna Hershey-Raudabaugh Child Harold Levi Hershey-Raudabaugh Child 13 The relationship of Defendant to the children is that of father. Defendant currently resides with the following persons: Name Relationship Stacey Moore Girlfriend 14. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 15. The best interest and permanent welfare of the children will be served by granting the relief requested because: a) Plaintiff has been the primary caretaker of the children since birth; b) Plaintiff provides the children with a home with adequate moral, emotional and physical surroundings as required to meet the children's needs; C) Plaintiff is willing to accept custody of the children; d) Plaintiff is willing to allow the father periods of partial custody to allow him to develop a parental relationship with the children. 16. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff requests the Court to grant her primary physical custody of the children, and to grant Defendant periods of partial physical custody as the parties may agree to in the future, and such other relief as the Court deems just. COUNT III ALIMONY 17. Plaintiff repeats and realleges paragraphs one through sixteen. 18. Plaintiff requires support to adequately maintain herself in accordance with a reasonable standard of living. 19. Plaintiff has been and will continue to be the primary caretaker of the minor children. 20. Plaintiff has not been involved in the work force for over five years. 21. Defendant, during the marriage, discouraged Plaintiff from seeking employment outside the home. 22. Plaintiff, now at age twenty seven (27) with no skills or experience, is unable to enter the work force without considerable training. 23. Even with considerable training, Plaintiff will be at a great disadvantage because of her age and lack of experience. 24. Defendant has had over nine (9) years to gain valuable experience and connections in the work environment. 25. Defendant is financially able to provide for his reasonable needs and the reasonable needs of Plaintiff. WHEREFORE, Plaintiff requests the Court to enter an award of reasonable alimony, and such other relief as the Court deems just. COUNT IV EQUITABLE DISTRIBUTION 26. Plaintiff repeats and realleges paragraphs one through twenty five. 27. Plaintiff and Defendant have acquired property during the marriage, including, but not limited to: a) A house located at 720 Bloserville Road, Newville, PA 17241 b) Cars C) Wedding Rings WHEREFORE, Plaintiff requests the Court to enter a decree awarding to Plaintiff the house and property in fee absolute and dividing the other property equitably between the parties and providing such relief as the Court deems just. COUNT V ALIMONY PENDENTE LITE AND COSTS 28. Plaintiff repeats and realleges paragraphs one through twenty seven. 29. Plaintiff has not been employed for the past five (5) years, she is unable to support herself and the children, and she does not possess sufficient property to provide for her reasonable needs or the needs of the children during the pendency of this proceeding. 30. Plaintiff will also be at a disadvantage during this litigation due to the lack of financial resources. Plaintiff will be unable to pay for any expenses that might arise during litigation of this matter. 31. Defendant has been employed during the marriage and will have the financial resources to pay for expenses that might arise during litigation of this matter. 32. Defendant also has the financial ability to provide for the reasonable needs of Plaintiff. WHEREFORE, Plaintiff requests the Court to order Defendant to pay a fair and reasonable sum of money in the form of Alimony Pendente Lite for the purpose of providing for the reasonable expenses that Plaintiff might incur during the pendency of this action and for her costs and attorney's fees incurred in litigating this action. J_?? Je ifer . S itrovich Certified Legal Intern ROBERT E. RAINS LUCY JOHNSTON-W H ANNE MACDONALD-FOX Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 VERIFICATION Understanding that the making of any false statement would subject me to the penalties of 18 Pa. C.S. §4904, the undersigned verifies that the statements made in the foregoing Complaint are true and correct, to the best of my knowledge, information and belief. Dated: I-A-625- ftle (?_ &awoa Michelle E. Raudabaugh V MICHELLE E. RAUDABAUGH, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DIVORCE TOM L. RAUDABAUGH, Defendant NO. 2004- CIVIL TERM 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 right important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE LAWYER, GO TO OR TELE PHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford St. Carlisle, PA 17013 (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. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. v 4 i MICHELLE RAUDABAUGH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION-LAW IN DIVORCE TOM RAUDABAUGH, Defendant :NO. 2005- -71l> CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Michelle Raudabaugh to proceed in forma pauperis. The Family Law Clinic, attorneys for the parry proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal services to the parry. Date: Ad S a2?i '1_" fifer SYnitrovich- Certified Legal Intern 7' y f y ROBE INS THOMAS M. PLACE LUCY JOHNSON-WALSH ANNE MACDONALD-FOX Supervising Attorneys THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 r ? i C rr ?r+ '?I 4? Si ' - ? -? ? l_:J :?.,.,.i i_ i ..... r j ?'\ i ...??`fk r.? ",% ?£T MICHELLE RAUDABAUGH IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. TOM RAUDABAUGH DEFENDANT 05-710 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW. Wednesday, February 16, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor Cumberland County Courthouse, Carlisle on Friday, March 04, 2005 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children ale five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s! Hubert X. Gilroy, 1:sg, Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ?9? ?- ? ' so- u.?° .?? ? ?`- MICHELLE E. RAUDABAUGH, Plaintiff V. TOM L. RAUDABAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE, CUSTODY NO. 2005-710 CIVIL TERM CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Divorce Complaint on Tom Raudabaugh, residing at 720 Bloserville Road, Newville, PA 17241, by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Tom Raudabaugh on the nineteenth day of February 2005 as evidenced by his signature on the attached return receipt. Dated: 31a 05 FAMILY LAW CLINIC 45 N. Pitt Street Carlisle, PA 17013 (717) 243-2968 ¦ Complete items 1, 2, and 3. Also complete A. Recelved t P/ease riot C/earty 8. O to of C ;jq item 4 if Restricted Delivery is desired. ( l ?a c ¦ Print your name and address on the reverse so that we can return the card to you. C. $i9patltre ¦ Attach this card to the back of the mailpiece, X/?? ?? '7 ?G?`LfJ or on the front if space permits. D. Is delivery address different trom item 1? Yes 1. Article Addressed to: If YES, enter delivery address below: / No TL5YY1 Gzc<GC'[< ??,'/<?, '?a2O ?IL'a?2SL?idCie ?Crl? -01* ? /?? t 7ay1 2. Article Number (Copy from service label) PS Form 3811, July 1999 Domestic Return Receipt U.S . P ost al Service,, ., ' CE R TIF IED MAIL ,, REC EIPT ` (Do mest ic M ail Only, No ins urance C overa e Provid d g e ) L1 postage a o CedltledFee $2.301 0 17 C3 Return Reciept Fee $1 (Endorsement Required) . C3 Restricted Delivery Fee (Endorsement Required) M Total Postage & Fees $ $8, { 102595-99W-1789 CARLISLE WPO CARLISLE, Pennsylvania ? 170132935 3 "°ti { 4134870013-0098 02/11/2005 (800)275-8777 03:23:42 PM ,r ------ Sales Receipt Product Sale Unit Final Description Qty Price Price M O ent o T jy' a< ?l? b¢- r` ?iiuet. Apt NO .:.................____.._._.__-- __>?..__..._._. Or POaex No. :rr r NEWVILLE PA 17241 $0.60 First-Class Restricted Delivers' $3.50 Return Receipt (Green Card) $1.75 Certified $2.30 Label Serial p: 70033110000457742976 Customer Postage -$8.15 Subtotal: $0.00 Total: $0.00 Paid by: Bil1N: 1000201990729 Clerk: 03 3. Service Type -10 Certified Mail 0 Express Mail 0 Registered 'Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) -16 yes - All sales final on stanips and postage. Refunds for guaranteed services only. Thank you for your business. MICHELLE RAUDABAUGH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW TOM RAUDABAUGH, : NO. 2005 - 710 Defendant : IN CUSTODY COURT ORDER AND NOW, this ! o day of March, 2005, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. The mother, Michelle E. Raudabaugh, and the father, Tom L. Raudabaugh, shall enjoy shared legal custody of Melody Renee Hershey-Raudabaugh, born March 12, 1998, Cheyenne Grace Hershey-Raudabaugh, born August 30, 1999, Geraldine Brianna Hershey-Raudabaugh and Harold Levi Hershey- Raudabaugh, both born January 5, 2002. 2. Mother shall enjoy primary physical custody of the minor children. 3. Father shall enjoy periods of temporary physical custody of the minor children as follows: a. For the week of March 7, on Monday from 3:30 p.m. until 7:00 p.m. and on Tuesday from 9:00 a.m. until 7:00 p.m. b. On the week of March 14, on Monday from 3:30 p.m. until 7:00 p.m. and on Tuesday from 9:00 a.m. until 7:00 p.m. c. On the weeks of March 21 and March 28, father shall enjoy custody on Monday and Tuesday of each week under the time frames set forth above and shall also enjoy custody from 9:00 a.m. until 7:00 p.m. on Wednesday. 4. Legal counsel for the parties shall conduct a telephone conference call with the Conciliator on Friday, April 8, 2005 at 8:30 a.m. At that time, the current situation will be addressed and a determination will be made with respect to any appropriate modifications of the custody order. !. r' . f" 1 ? ? C ? _ ., ..e ?,.1 ?lI 5. Neither parent shall be under the influence of alcohol during any time that they will transport the children in a vehicle, nor shall any parent be abusive of alcohol when they have custody of the minor children. 6. Legal counsel for the parties may contact the Conciliator directly in the event there are any emergency situations that merit attention between the date of this order and the time scheduled for a Conciliation Conference above. 7. Both parents shall ensure that they have appropriate child restraint devices in any automobile that transports the children and that the children be placed in the child restraint devices. 8. Neither parent shall have any feline animals in the home when they have custody of the minor children. BY THE COURT, J M. ?,.8?ean' M. Shultz, Esquire / 'J` rifer M. Smitrovich, Law Student fy/ V C _J 03 1? MICHELLE RAUDABAUGH, Plaintiff v TOM RAUDABAUGH, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO.2005 - 710 : IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Melody Renee Hershey-Raudabaugh, born March 12, 1998, Cheyenne Grace Hershey-Raudabaugh, born August 30, 1999, Geraldine Brianna Hershey- Raudabaugh, born January 5, 2002 and Harold Levi Hershey-Raudabaugh, born January 5, 2002. 2. A Conciliation Conference was held on March 4, 2005, with the following individuals in attendance: The father, Tom Raudabaugh, with his counsel, Sean M. Shultz, and the mother, Michelle Raudabaugh, with her student attorney Jennifer M. Smitrovich of the Dickinson School of Law Family Law Clinic. 3. Based upon the strong recommendation of the Conciliator, the parties agree to the entry of an order in the form as attached. DATE Hubert X. Gilroy, Es 91d1re Custody Conciliator A RECEIVED APR 12 2005 MICHELLE RAUDABAUGH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW TOM RAUDABAUGH, : NO. 2005 - 710 Defendant : IN CUSTODY COURT ORDER AND NOW, this i -7 ' day of April, 2005, upon consideration of the attached Custody Conciliation report, it is ordered that this Court's prior Order of March 10, 2005 is vacated and replaced with the following: 1. The mother, Michelle E. Raudabaugh, and the father, Tom L. Raudabaugh, shall enjoy shared legal custody of Melody Renee Hershey-Raudabaugh, born March 12, 1998, Cheyenne Grace Hershey-Raudabaugh, born August 30, 1999, Geraldine Brianna Hershey-Raudabaugh and Harold Levi Hershey- Raudabaugh, both born January 5, 2002. 2. Mother shall enjoy primary physical custody of the minor children. 3. Father shall enjoy periods of temporary physical custody of the minor children as follows: a. Pending completion of parenting classes by father, from Monday at 3:30 p.m. until Tuesday at 7:00 p.m. and from Wednesday at 9:00 a.m. until Wednesday at 7:00 p.m. This shall be each week b. On those days when father is scheduled to pick up the child at 9:00 a.m. and he is more than thirty minutes late, the father shall forfeit the ability to pick the child up at that time and the pick up time shall revert to 3:30 p.m. R IAI nvl LL I L' C, `T 1 C [' 7 l c. Upon completion of parenting classes, from Monday at 3:30 p.m. until Wednesday at 7:00 p.m. d. As such other times as agreed between the parties. 4. Neither parent shall be under the influence of alcohol during any time that they will transport the children in a vehicle, nor shall any parent be abusive of alcohol when they have custody of the minor children. 5. Legal counsel for the parties may contact the Conciliator directly in the event there are any emergency situations that merit attention between the date of this order and the time scheduled for a Conciliation Conference above. 6. Both parents shall ensure that they have appropriate child restraint devices in any automobile that transports the children and that the children be placed in the child restraint devices. 7. Neither parent shall have any feline animals in the home when they have custody of the minor children. 8. Legal counsel for the parties shall conduct a telephone conference call with the Conciliator on Tuesday, July 5, 2005 at 9:00 a.m. At that time, the current situation will be addressed and a determination will be made with respect to any appropriate modifications of the custody order. BY THE COURT, cc: ?5 n M. Shultz, Esquire Judge evin A. Hess /Jennifer M. Smitrovich, Law Student I v ?? CCU MICHELLE RAUDABAUGH, Plaintiff v TOM RAUDABAUGH, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 2005 - 710 : IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The Conciliator spoke with the attorneys for the parties and, based upon that conversation, recommends an Order in the form as attached. DATE Hubert X. Custody C MICHELLE E. RAUDABAUGH, Plaintiff V. TOM L. RAUDABAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 2005-710 CIVIL TERM PRAECIPE TO WITHDRAW EQUITABLE DISTRIBUTION COUNT To the Prothonotary: Please withdraw the Count for Equitable Distribution in the above-captioned Complaint for Divorce filed in the Cumberland County Courthouse on February 9, 2005. Date: g 05 nnif r M. mitrovich Certified Legal Intern .AA IC Lucy o ston-Walsh Anne M cDonald-Fox Thomas Place Robert Rains Supervising Attorneys The Family Law Clinic 45 N. Pitt Street Carlisle, PA 17013 (717) 243-2968 MICHELLE E. RAUDABAUGH, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 2005-710 CIVIL TERM TOM L. RAUDABAUGH, IN DIVORCE Defendant/Respondent PACSES # 459107283 ORDER OF COURT AND NOW, this 4" day of May, 2005, 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 Shadday on May 25,1005 at 10:30 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 (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11© (4) 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 5-4-05 to: < Respondent Anne MacDonald-Fox, Esquire Sean Shultz, Esquire Date of Order: May 4, 2005 I i-3 . 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 ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 CC361 ?? c ?? cn __? _ ??ni- t I f l C..i __ (v ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT O Original Order/Notice State Commonwealth of Pennsylvania Co./City/Dirt. of CUMBERLAND Q Amended Order/Notice Date of Order/Notice 05/25/05 O Terminate Order/Notice Case Number (See Addendum for case summary) RE: RAUDABAUGH, TOM L. Employer/Withholder's Federal EIN Number Employee/Obligor's Name (Last, First, MI) 160-54-5298 by a009-7/0 Ct ? IL Employee/Obligor's Social Security Number LAZER SPOT INC )VnLxS ys-9?OJ ? 93 5533101360 327 DAHLONEGA RD STE 801 Employee/Obligor's Case ldentitier CUMMING GA 30040-2491 ' (See Addendum for plaintiff names W, G3? S ?D associated with cases on attachment) NL16t '?71/o& Sff& Custodial Parent's Name (Last, First, Mp See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 972.00 per month in current support $ 50. oo per month in past-due support Arrears 12 weeks or greater? Dyes ® no $ o. oo per month in current and past-due medical support $ o . 00 per month for genetic test costs $ per month in other (specify) for a total of $ 1, 022.00 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: $ 235.85 per weekly pay period. $ 471.69 per biweekly pay period (every two weeks). $ 511. oo per semimonthly pay period (twice a month). $ 1.022. oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case .Ide r? 0049CIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL BY THE COU Date of Order:. U 2005 A zvw) >?o ?& c Form EN-028 Service Type M OM9No,:0970-0154 WorkerlD $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If hecke? you are required to provide a copy of this form to your. mployee. If your employee works in a state that is di ferent from the state that issued this order, a copy must be provt= to your employee even if the box is not checked. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3.* Report{ngthe paydat&ddle of nithholding is tli- date on which arymmot ww withheld 11011, t1W C.11PIUytfU'? . You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 5822533690 EMPLOYEE'S/OBLIGOR'S NAME: RAUDABAUGH TOM L. EMPLOYEE'S CASE IDENTIFIER: 5533101360 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 employeelobligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11.Submitted By: If you or your employee/obligor have any questions, DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 Service Type m by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 OMB No. 0970-0154 Form EN-028 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: RAUDABAUGH, TOM L. PACSES Case Number 459107283 Plaintiff Name MICHELLE E. RAUDABAUGH Docket Attachment Amount 05-710 CIVIL $ 259.00 Child(ren)'s Name(s): DOB PACSES Case Number 971106588 Plaintiff Name MICHELLE E. RAUDABAUGH Docket Attachment Amount 00636 S 2004 $ 763.00 Child(ren)'s Name(s): DOB MELODY R. RAUDABAUGH 03/12/98 CHEYENNE 0. RAUDABAUGH 08/30./99 GERALDINE B. RAUDABAUGH 01/05/02 HAROLD L.. RAUDABAUGH 01/05/02. ?If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available identified above in any health insurance coverage available through the employee's/obligor's employment. through the employee's/obligor's employment. Addendum Form EN-028 Service Type M OMB No 0910-0154 Worker ID $IATT ,, = ?? . ? : --{ t 4 . ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dirt. of CUMBERLAND Date of Order/Notice 05/25/05 Case Number (See Addendum for case summary) Employer/Withholder's Federal EIN Number RE: RAUDABAUGH AIG ACCIDENT & HEALTH Lrl 4/L C/O CLAIMS DEPARTMENT fS PO BOX 15701 P A9 7 O Ongi nal Order/Notice O Amended Order/Notice O Terminate Order/Notice TOM L. Employee/Obligor's Name (Last, First, MIT- 160-54-5298 Employee/Obligor's Social Security Number 5533101360 Employee/Obligor's Case Identifier (See Addendum for plaintiff names WILMINGTON DE 19850-5701 associated with cases on attachment) &#, (,3& 9 o200y Custodial Parent's Name (Last, First, Mp /'mss 971/0(osff See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 972 . 00 per month in current support $ 50 . oo per month in past-due support Arrears 12 weeks or greater? Oyes ® no $ o . oo per month in current and past-due medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ 1, 022.00 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: $ 235. 85 per weekly pay period. $ 471.69 per biweekly pay period (every two weeks). $ 511. oo per semimonthly pay period (twice a month). $ 1.022.00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: p5- Date of Order .....-.Service Type M ?Ar?f? fzv v 4? F m EN-028 OMB No. 097M 154 WorkerlD $OINC ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If hheckefl you are required to provide a copy of this form to your mployee. If yo r employee works in a state that is di event from the state that issued this order, a copy must be provi?ed to your employee even if the box is not checked. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3. . You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 7043100166 EMPLOYEE'S/OBLIGOR'S NAME: RAUDABAUGH, TOM L. EMPLOYEE'S CASE IDENTIFIER: 5533101360 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Antidiscrimination: You are subject to a fine determined under State law for discharging an 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. §1673 01; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Submitted By: If you or your employee/obligor have any questions, DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 Service Type m by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 OMB NO0970 0I i4 Form EN-028 Worker ID $OINC ADDENDUM Summary of Cases on Attachment Defendant/Obligor: RAUDABAUGH, TOM L. PACSES Case Number 459107283 Plaintiff Name MICHELLE E. RAUDABAUGH Docket Attachment Amount 05-710 CIVIL $ 259.00 Child(ren)'s Name(s): DOB PACSES Case Number 971106588 Plaintiff Name MICHELLE E. RAUDABAUGH Docket Attachment Amount 00636 S 2004 $ 763.00 Child(ren)'s Name(s): DOB MELODY R. RAUDABAUGH 03/12/98 CHEYENNE G. RAUDABAUGH 08/30/9.9 GERALDINE B. RAUDABAUGH 01/05/02 HAROLD L. RAUDABAUGH 01/05/02 ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACKS Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? 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. PAGES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above In any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available identified above in any health insurance coverage available through the employee'slobligor's employment. through the employee's/obligor's employment. Addendum Form EN-028 Service Type M Worker ID $oINC OMB NO. 0970-0154 ?? ° , . _ ? _ MICHELLE E. RAUDABAUGH, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. CIVIL TERM n2?'(? " CIO C TOM L. RAUDABAUGH, IN DIVORCE Defendant(Respondent PACSES#459107283 ORDER OF COURT AND NOW, this 25`h day of May, 2005, 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 $1,551.33, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $249.00 per month plus $10.00 on arrears payable weekly as follows; $57.46 for alimony pendente lite and $2.31 on arrears. First payment due next disability payment. Arrears set at $498.00 as of May 25, 2005. The effective date of the order is April 25, 2005. This order is a temporary order while the respondent is receiving disability insurance due to a work related injury. The matter will be reviewed upon his return to work. Respondent is to provide verification of his disability income and is to provide medical verification on his employment status and is to report to the Domestic Relations Section on his return to work. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C.S.§ 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the PA SCDU to: Michelle E. Raudabaugh. Payments must be made by check or money order. All checks and money orders must be made payable to PA SCDU and mailed to: PA SCDU P.O. Box 69110 Harrisburg, PA 17106-9110 Payments must include the defendant's PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. Unreimbursed medical expenses that exceed $250.00 annually are to be paid as follows: 0% by Respondent and 100% by Petitioner. The Petitioner is responsible to pay the first $250.00 annually in unreimbursed medical expenses. Petitioner to provide medical insurance coverage. Within thirty (30) days after the entry of this Order, the Petitioner 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 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. I Shadday BY THE COURT, Mailed copies on Petitioner 5-26-05: < Respondent Robert Rains, Esquire Sean Shultz, Esquire Edward E. Guido J. ? _', RECEIVED JUL 14 2005 MICHELLE RAUDABAUGH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION -LAW TOM RAUDABAUGH, : NO. 2005 - 710 Defendant : IN CUSTODY COURT ORDER AND NOW, this /V day of July, 2005, upon consideration of the attached Custody Conciliation report, it is ordered that this Court's prior Order of April 13, 2005 is ratified subject to paragraph three being modified as follows: 3. The father, Tom L. Raudabaugh, shall enjoy temporary physical custody of the minor children as follows: a. Pending completion of parenting classes by father, every Monday from 9:00 a.m. until Tuesday at 7:00 p.m. and every Wednesday at 8:00 a.m. until 1:00 p.m. b. Upon written certification that father has completed parenting classes, father's periods of temporary custody shall be every Sunday from 1:00 p.m. until Tuesday at 7:00 p.m. and every Wednesday at 8:00 a.m. until 1:00 p.m. c. At such other times as agreed upon by the parties. In all other respects, the prior Court Order shall remain in effect. BY THE COURT, /_1, A. Hess cc: SEan M. Shultz, Esquire to Gornall , Dickinson School of Law Family Law Clinic b? I z ,,I k!a 9 ! IN SOOZ MICHELLE RAUDABAUGH, Plaintiff v TOM RAUDABAUGH, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2005 - 710 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-5(b), the undersigned Custody Conciliator submits the following report: 1. The Conciliator had a telephone conference with legal counsel for the parties and the parties agreed to the entry of an Order in the form as attached. I/V 7-f 3- DATE Hu ert X. Gilry ,Esquire Custody Conciliator ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 07/27/05 Case Number (See Addendum for case summary) Employer/Withholder's Federal EIN Number AIG ACCIDENT & HEALTH C/O CLAIMS DEPARTMENT PO BOX 15701 WILMINGTON DE 19850-5701 O Original Order/Notice O Amended Order/Notice O Terminate Order/Notice RE: RAUDABAUGH, TOM L. b . ergs- 710 P LI 19YeCES A-9107aF?2 ,ail. ? 34 s ae491V l'mf s 97//b61:79/ Employee/Obligor's Name (Last, First, MI) 160-54-5298 Employee/Obligor's Social Security Number 5533101360 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, MI) See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ o . o o per month in current support $ 0.00 per month in past-due support Arrears 12 weeks or greater? Dyes ® no $ o . oo per month in current and past-due medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ 0.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ o. oo per weekly pay period. $ o . o o per biweekly pay period (every two weeks). $ 0.00 per semimonthly pay period (twice a month). $ o. oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. Date of Order: NUL '9 r 2005 Service Type m 17 7 °1 THE COURT:t ii Form EN-028 OMB No.: 0970-0154 Worker ID $OINC ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If hecke? you are required to provide a copy of this form to your z If yo r employee works in a state that is d4erent from the state that issued this order, a copy must be provi ?ed to your employee even if the box is not checked. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. papdate(date-ofwithhelding-mth,?7cfate omwhich-amounTwasNvRhheid4romtheemptoyee`swager. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 7043100166 EMPLOYEE'S/OBLIGOR'S NAME: RAUDA13AUGH, TOM L. EMPLOYEE'S CASE IDENTIFIER: 5533101360 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 emp(oyee/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. §1673 01; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state than issued the order, you are to follow the law of the state that issued this order with respect to these items. 1 ].Submitted By: DOMESTIC RELATIONS SECTION 13 N HANOVER ST P.O. BOX 320 CARLISLE PA 17013 Service Type M If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 10-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 OMB No. 0970-0154 Form EN-028 Worker ID $OINC c-> or - r - , Z7 MICHELLE E. RAUDABAUGH, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 2005-710 CIVIL TERM TOM L. RAUDABAUGH, IN DIVORCE Defendant/Respondent PACSES #459107283 ORDER OF COURT AND NOW, this 3'd day of August, 2005, a petition has been filed against you, Tom Raudabaugh, to review an existing Alimony Pendente Lite Order. You are ordered to appear in person at the Domestic Relations Section, 13 North Hanover Street, Carlisle, Pennsylvania, on September 6. 2005 at 10:30 A.M. for a conference and to remain until dismissed by the Court. If you fail to appear as provided in this Order, an Order of Court may be entered against you. You are further ordered to bring to the conference (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by the Rule 1910.11. (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 Copies mailed 8-3-05 to:< Petitioner Respondent Robert Rains, Esquire Sean Shultz, Esquire Date of Order: August 3, 2005 kIRSIdday, 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 ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 "t G f17? n tn L I n . ..p f .J ? g C- 4 c / MICHELLE E. RAUDABAUGH, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 2005 - 710 CIVIL TERM TOM L. RAUDABAUGH, IN DIVORCE Defendant/Respondent PACSES# 459107283 ORDER OF COURT AND NOW, this 6th day of September, 2005, 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 $2048.55, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $351.00 per month payable monthly as follows; $341.00 for alimony pendente lite and $10.00 on arrears. First payment due next pay date. Arrears set at $1131.07 as of September 6, 2005 . The effective date of the order is July 12, 2005. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C.S.§ 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the PA SCDU to:. Payments must be made by check or money order. All checks and money orders must be made payable to PA SCDU and mailed to: PA SCDU P.O. Box 69110 Harrisburg, PA 17106-9110 Payments must include the defendant's PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. cc360 Unreimbursed medical expenses that exceed $250.00 annually are to be paid as follows: 0% by Respondent and 100% by Petitioner. The Petitioner is responsible to pay the first $250.00 annually in unreimbursed medical expenses. Neither party to provide medical insurance coverage. Within thirty (30) days after the entry of this Order, the Respondent shall submit to Petitioner written proof that medical insurance coverage has been obtained or that application for coverage has been made. Proof of coverage shall consist, at minimum, of. 1) the name of the health care coverage provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims should be made; 5) a description of any restrictions on usage, such as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms. This Order shall become final ten days after the mailing of the notice of the entry of the Order to the parties unless either parry files a written demand with the Prothonotary for a hearing de novo before the Court. This Order is based upon the fact that the Respondnet has returned to full time employment. Consented: Petitioner Respondent Petitioner's Attorney Respondent's Attorney BY THE COURT e=:2 Edward dio, Judge DRO: R. I Shadday Mailed copies on: Petitioner September 6, 2005 Respondent Sean M. Shultz, Esq. Linda LeFever, Esq. ?, r;. ? , .-? ?. -n ?n ?J G? ??L.) }In C .? =1 `_ .? ? '` Ati ,, [j'1 ,. `..Rq r. «. . ,( ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 459ID`lgSS3 State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 09/06/05 Case Number (See Addendum for case summary) Employer/Withholder's Federal EIN Number LAZER SPOT INC STE 1005 327 DAHLONEGA RD CUMMING GA 30040-8210 D5 `11D C1VIL C411 I D1'5B<z low S aOC>II- O Original Order/Notice O Amended Order/Notice O Terminate Order/Notice RE: RAUDABAUGH, TOM L. Employee/Obligor's Name (Last, First, MI) 160-54-5298 Employee/Obligor's Social Security Number 5533101360 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, MI) See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 1, 252, oo per month in current support $ 50.00 per month in past-due support Arrears 12 weeks or greater? (9) Yes Q no $ o , 0o per month in current and past-due medical support $ o , oo per month for genetic test costs $ per month in other (specify) for a total of $ 1, 302.00 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: $ 300.46 per weekly pay period. $ 600.92 per biweekly pay period (every two weeks). $ 651, oo per semimonthly pay period (twice a month). $ 1.302 , oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information i needed (See #9 on page 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. Date of Order: SEP 0 7 2005 Service Type M BY THE COU Edward E, 41 udqq,,e Form EN-028 OMB No.: 0970-0114 WorkerlD $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If hecked you are required to provide a opy of this form to your ,em loyee. If your employee works in a state that is different from the state that issued this or?er, a copy must be prowdeTto your employee even if the box is not checked. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3. employee's ravager. You must comply with the law of the payddte2fddtU of Mthholding is the date an Miich amount ms -ithh-11.1 from 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 49 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 5822533690 EMPLOYEE'S/OBLIGOR'S NAME: RAUDABAUGH, TOM L. EMPLOYEE'S CASE IDENTIFIER: 5533101360 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Antidiscrimination: You are subject to a fine determined under State law for discharging an 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. §1673 fb)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. I I.Submitted By: If you or your employee/obligor have any questions, DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT 13 N. HANOVER ST by telephone at (717) 240-6225 or P.O. BOX 320 by FAX at (717) 240-6248 or CARLISLE PA 17013 by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Service Type M omBNo.:om0-0,54 Worker ID $IATT I ADDENDUM Summary of Cases on Attachment Defendant/Obligor: RAUDABAUGH, TOM L. PACKS Case Number 459107283 Plaintiff Name MICHELLE E. RAUDABAUGH Docket Attachment Amount 05-710 CIVIL $ 351.00 Child(ren)'s Name(s): DOB PACSES Case Number 971106588 Plaintiff Name MICHELLE E. RAUDABAUGH Docket Attachment Amount 00636 S 2004 $ 951.00 Child(ren)'s Name(s): DOB MELODY R. RAUDABAUGH 03/12/98 CHEYENNE G. RAUOAEATJGH 08/30/99 GERALDINE B. RAUDABAUGH 01/05/02 HAROLD L. RAUDABAUGH 01/05/02 ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACKS Case Number Plaintiff Name Docket Attachment Amount $ 0.00 ?If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ?if checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ?If checked, you are required to enroll the child(ren) ?If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available identified above in any health insurance coverage available through the employee's/obligor's employment. through the employee's/obligor's employment. Addendum Form EN-028 Service Type M Worker ID $IATT OMB No.: 09JOUt 54 C, ?, - cn O ?: J_ T cn _ ? ] ~ fly r- 'J ?Y? t,) ?.-jiTi y _ -S MICHELLE E. RAUDABAUGH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE, CUSTODY TOM L. RAUDABAUGH, ?CCXJ 710 Defendant NO.- CIVIL TERM ORDER APPOINTING MASTER i / ? AND NOW, this I?day of T;10 f L- ', 2005, Robert Elicker, Esquire, is appointed master with respect to the following claim: Alimony. By the Court: '11*441v\ - A N! h'tfa d ?!-11 JG MICHELLE E. RAUDABAUGH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW IN DIVORCE TOM L. RAUDABAUGH, Defendant NO. 2005-710 CIVIL TERM PRAECIPE TO WITHDRAW ALIMONY To the Prothonotary: Please withdraw the Count for Alimony in the above-captioned Complaint for Divorce filed in the Cumberland County Courthouse on February 9, 2005. Date: ? z I (, auren Navalkowsky / .... Certified Legal Intern Lucy stun-Walsh Anne MacDonald-Fox Thomas Place Robert Rains Supervising Attorneys The Family Law Clinic 45 M Pitt Street Carlisle, PA 17013 (717) 243-2968 l v ?l -? f T? -1 co IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MICHELLE E. RAUDABAUGH, Plaintiff V. TOM L. RAUDABAUGH, Defendant STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND CIVIL ACTION - LAW NO. 2005-710 IN DIVORCE AFFIDAVIT OF CONSENT SS. 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 9, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subj ect to the penalties of 18 Pa. C. S., Section 4904 relating to unswom falsification to authorities. Date: L 24, 2006 Sworn o and subscri ed befgor me this f C A 2006, Notary ublic 7!f?. , ? Tom L. Raudabaugh F:IUSerN&, IF,? DocsVGcndouVGundo..200S3926-1 ffw... nt wpd r-> ! ?i ?1 f ?S G% C+? . . A' ..,. _... vi+ Ms. Michelle Raudabaugh, Plaintiff Y. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE Mr. Tom Raudabaugh, Defendant : NO. 05- 710 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date Mrs. Ton Raudabaugh , Defe dant :? - t..?. U, ?. Ms. Michelle Raudabaugh, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Mr. Tom Raudabaugh, Defendant ; NO. 05- 710 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on February 9, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. q 2j-?? Date, Ms Michelle Raudabaugh, Plaintiff ,% ? ( r ?? 4% ..? _. ?S? Ms. Michelle Raudabaugh, Plaintiff V. Mr. Tom Raudabaugh , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE Defendant :NO. 05- 710 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date esJ Ms. Michelle Raudabaugh, Plaintiff) ,_:? =:> ?. a MICHELLE E. RAUDABAUGH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 05 - 710 CIVIL TOM L. RAUDABAUGH, Defendant IN DIVORCE ORDER OF COURT AND NOW, this ,366( day of J? 2006, the economic claims raised in the proceedings having been withdrawn by praecipes filed on February 9, 2006, and March 21, 2006, and the parties having filed affidavits of consent and waivers of notice of intention to request entry of divorce decree, there being no matters, therefore, pending before the Master, the appointment of the Master is vacated. BY Edgar B. Bayley, cc: /ne MacDonald-Fox Attorney for Plaintiff \r!? 0om L. Raudabaugh Defendant S_,T_ \ ' .;? 1p I ;;, ; . -h? ,_,,, Michelle Raudabaugh, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW V. : IN DIVORCE AND CUSTODY Tom Raudabaugh, Defendant : No. 05-710 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: February 19, 2005 by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. 3. Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by plaintiff, March 16, 2006; by defendant, March 24, 2006. 4. Related claims pending: none Date plaintiff s Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: March 28, 2006 Date defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: March 28, 2006 auren N valkowsky Certified Legal Intern ANNE ALD-FOX Supervising Attorney FAMILY LAW CLINIC 45 N. Pitt Street Carlisle, PA 17013 717-243-2968 Fax: 717-243-3639 Attorneys for Plaintiff {_'i ,??' ? 'r1 °:1i i ?. ORDERINOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania 459107283 Original Order/Notice Co./City/Dist. of CUMBERLAND 05-710 CIVIL O Amended Order/Notice Date of Order/Notice 04/05/06 O germinate Order/Notice Case Number (See Addendum for case summary) 971106588 636 S 2004 RE: RAUDABAUGH, TOM L. Employer/Withholder's Federal FIN Number Employee/Obligor's Name (Last, First, MI) PITZER TRUCKING PO BOX 276 BIGLERVILLE PA 17307-0276 160-54-5298 Employee/Obligor's Social Security Number 5533101360 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, MI) See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 1, 252.00 per month in current support $ 50.00 per month in past-due support Arrears 12 weeks or greater? Oyes Q no $ 0 .00 per month in current and past-due medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ 1, 302.00 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: $ 300.46 per weekly pay period. $ 600.92 per biweekly pay period (every two weeks). $ 651. oo per semimonthly pay period (twice a month). $ 1, 302. oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAMEAND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: Date of Order: Fdward E, Cu-i&5, Judge DRO: R.S. Shadday Form EN-028 Service Type M OMBNo.:o9]OO154 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If checked you are required to provide a copy of this form to your. gloyee. If yo r employee works in a state that is different from the state that issued this order, a copy must be provrdeed to your employee even if the box is not checked. 1. Priority: Withholding under this order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3. *i.eportingthe-PaydatelDat?rrg: -YVU-musPreport't . pagdate/dateof withhofdirtg-is the-date-onvhich You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employeelobligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 8401000028 EMPLOYEE'S/OBLIGOR'S NAME: RAUDABAUGH TOM L. EMPLOYEE'S CASE IDENTIFIER: 5533101360 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. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 Service Type M OMB No.: 0970.0154 Form EN-028 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: RAUDABAUGH, TOM L. PACSES Case Number 459107283 Plaintiff Name MICHELLE E. RAUDABAUGH Docket Attachment Amount 05-710 CIVIL $ 351.00 Child(ren)'s Name(s): DOB PACSES Case Number 971106588 Plaintiff Name MICHELLE E. RAUDABAUGH Docket Attachment Amount 00636 S 2004 $ 951.00 Child(ren)'s Name(s): DOB MELODY R. RAUDABAUGH 03/12/98 CHEYENNE G. RAUDABAUGH 08/!30/99 GERALDINE B. RAUDABAUGH 01/05/02 HAROLD L. RAUDAEAi7GH 01/!05/02 ? 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 ?lf checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ?If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available identified above in any health insurance coverage available through the employee's/obligor's employment. through the employee's/obligor's employment. Addendum Form EN-028 Service Type M OMB No.'. 09IP154 Worker ID $IATT ?", `. ?, ? ?. ... _, :-:: _. c- -: t .$3 ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dirt. of CUMBERLAND Date of Order/Notice 04/11/06 Case Number (See Addendum for case summary) EmployerAVithholder's Federal LAZER SPOT INC STE 1005 327 DAHLONEGA RD CUMMING GA 30040-8210 160-54-5298 Employee/Obligor's Social Security Number 5533101360 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, Mb See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 0 . oo per month in current support $ 0. 00 per month in past-due support Arrears 12 weeks or greater? Oyes ® no $ 0.00 per month in current and past-due medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ o. oo 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: $ o . o o per weekly pay period. $ o . oo per biweekly pay period (every two weeks). $ 0. oo per semimonthly pay period (twice a month). $ o . o o per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the EmployeelObligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. Date of Order: A""° 12 ?906 DRO: R.J. Shadday Service Type M 459107283 0Original OrdedNotice 05-710 CIVIL O Amended Order/Notice Terminate Order/Notice 971106588 636 S 2004 RE: RAUDABAUGH, TOM L. Employee/Obligor's Name (Last, First, MI BY THE COURT- Edward E. u o, Judge Form EN-028 OMB No.. 0970-0134 Worker ID $IATT 1 ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If checked you are required to provide a copy of this form to your em loyee. If yoVr employee works in a state that is different from the state that issued this order, a copy must be provideto your employee even if the box is not checked. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employeelobligor. 3. paYnater°am?r1^'mm°torng rstfledate-ort whichzmocmtroveswOhekffrom-th"mpfoyee`swager You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 5822533690 EMPLOYEE'S/OBLIGOR'S NAME: RAUDABAUGH, TOM L. EMPLOYEE'S CASE IDENTIFIER: 5533101360 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 employeelobligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. §1673 (b) 1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. I (.Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us Service Type M Page 2 of 2 OMB No, 0970-0154 Form EN-028 Worker ID $IATT I ADDENDUM Summary of Cases on Attachment Defendant/Obligor: RAUDABAUGH, TOM L. PACSES Case Number 459107283 Plaintiff Name MICHELLE E. RAUDABAUGH Docket Attachment Amount 05-710 CIVIL $ 0.00 Child(reN's Name(s): DOB PACSES Case Number 971106588 Plaintiff Name MICHELLE E. RAUDABAUGH Docket Attachment Amount 00636 5 2004 $ 0.00 Child(ren)'s Name(s): DOB MELODY R. RAUDABAUGH 03/12/98 CHEYENNE. G. RAUDABAUGH 08/34/99 GERALDINE B. RAUDABAUGH 01/05/02 HAROLD L. RAUDABAUGH 01/.05/02 OIf checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(reN's Name(s): DOB Off 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 OIf checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACKS Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(reN's Name(s): DOB Olf checked, you are required to enroll the child(rem 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 Olf checked, you are required to enroll the child(ren) Olf checked, you are required to enroll the child(ren) identified above in any health insurance coverage available identified above in any health insurance coverage available through the employee's/obligor's employment. through the employee's/obligor's employment. Addendum Form EN-028 Service Type M Worker ID $IATT OMB No.: 0470A154 ,, ;, ?, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Michelle Raudabauqh „ NO. 05 21n VERSUS DECREE IN DIVORCE AND NOW, N OCA `I , 2006 , IT IS--ORDERED AND DECREED THAT miir.hplla Ranrlahaugh , PLAINTIFF, AND Tom Raudabaugh - ,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; BY THE COURT: ATTEST: J PROTHONOTARY 'S??h .. ?. In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION MICHELLE E. RAUDABAUGH Docket Number 05-710 CIVIL Plaintiff vs. ) PACSES Case Number 459107283 TOM L. RAUDABAUGH Defendant ) Other State ID Number ORDER AND NOW, to wit, on this 27TH DAY OF APRIL, 2006 IT IS HEREBY ORDERED that the support order in this case be 0 Vacated or OSuspended or ® Terminated without prejudice or 0 Terminated and Vacated, effective APRIL 17, 2006 , due to: THE PARTIES' DECREE IN DIVORCE ON APRIL 17, 2006. THERE IS A REMAINING BALANCE DUE OF $2,672.91 AND IS TO PAID AT THE RATE OF $351.00 PER MONTH. BY TH OURT: ETw-arc E. Gul JUDGE DRO: R.J. Shadday Form OE-504 Service Type M Worker ID 21005 Michelle Raudabaugh, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW IN DIVORCE Tom Raudabaugh, Defendant No. 05-710 CIVIL TERM NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in divorce from the bonds of matrimony on the 17'' day of April, 2006, hereby elects to retake and hereafter use her previous name of Rhinehart, and gives this written notice avowing her intention in accordance with the provisions of 54 Pa.C.S. § 704. Wishes To Be Known As: i Michelle Raudabaugh Michelle Rhinehart ? ? ? ?? ? -n ?? ?? ?;_. -t-; r-rr ? '`? / -_'] ? C"? y `-??;?-yy W ? 4 MICHELLE RHINEHART, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY TOM RAUDABAUGH, Defendant. : NO. 2005-710 CIVIL TERM CUSTODY AGREEMENT THIS AGREEMENT, made this ° 3 day of , 2007, between Michelle Rhinehart, hereinafter Mother, and Tom Raudabaugh, hereinafter Father, concerns the custody of their four children: Melody Renee Hershey-Raudabaugh, Born March 12, 1998, Cheyenne Grace Hershey-Raudabaugh, born August 30, 1999, Geraldine Brianna Hershey-Raudabaugh and Harold Levi Hershey-Raudabaugh, both born January 5, 2002. Mother and Father desire to enter into an agreement regarding the custody of their children. Mother and Father agree to the following. 1. Mother and Father shall have shared legal custody of the children. 2. Mother shall have primary physical custody of the children. 3. Father shall have periods of partial physical custody of the children alternate weeks, from Friday at 5:00 p.m. until Sunday at 6:00 p.m. The children shall be picked up and dropped off at Mother's residence. As well as such other times mutually agreed to by the parties. Father shall have periods of partial physical custody of the children at such other times as mutually agreed by the parties. 4. Neither parent shall be under the influence of alcohol during any time that he or she is transporting the children in a vehicle, nor shall any parent be abusive of alcohol when they have custody of the minor children. 5. Both parents shall ensure that they have appropriate child restraint devices in any automobile that transports the children and that the children are placed in the child restraint devices. 6. Neither parent shall have any feline animals in the home when they have custody of the minor children. 7. Mother and Father agree that the custodial parent shall provide the non- custodial parent with reasonable telephone contact with the children. 8. Neither parent will display any negative behavior to the other parent in the presence of the children or during the exchange of the children. 9. Neither parent will do anything which may estrange the children from the other party, or injure the opinion of the children as to the other parent or which may hamper the free and natural development of the children's love and respect for the other parent. 10. The parties may modify this agreement by mutual agreement. 11. The parties intend to be bound by the terms of this agreement and intend for this agreement to be made an Order of Court. Date: Mkcllje Rhinehart?Plaintiff Tom Raudabaugh, Defendan Kdrista Ann F Certified Lee ROBE E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Counsel for Plaintiff FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717)243-2968 Fax (717)243-3639 C) ? v n 'te'e 371r -S ` co may i ( "e JUN 2 7 2007 Michelle Rhinehart IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 2005-710 CIVIL TERM Tom Raudabaugh, Defendant : IN CUSTODY ORDER OF COURT And now, this C' I day of , 2007, as per the attached and signed Custody Agreement, the following terms are approved and entered as an Order of Court: 1. Mother and Father shall have shared legal custody of the children. 2. Mother shall have primary physical custody of the children. 3. Father shall have periods of partial physical custody of the children alternate weeks, from Friday at 5:00 p.m. until Sunday at 6:00 p.m. The children shall be picked up and dropped off at Mother's residence. Father shall have periods of partial physical custody of the children at such other times as mutually agreed by the parties. 4. Neither parent shall be under the influence of alcohol during any time that he or she is transporting the children in a vehicle, nor shall any parent be abusive of alcohol when they have custody of the minor children. 5. Both parents shall ensure that they have appropriate child restraint devices in any automobile that transports the children and that the children are placed in the child restraint devices. 6. Neither parent shall have any feline animals in the home when they have custody of the minor children. 7. Mother and Father agree that the custodial parent shall provide the non-custodial parent with reasonable telephone contact with the children. 8. Neither parent will display any negative behavior to the other parent in the presence of the children or during the exchange of the children. 9. Neither parent will do anything which may estrange the children from the other party, or injure the opinion of the children as to the other parent or which may hamper the free and natural development of the children's love and respect for the other parent. 10. The parties may modify this agreement by mutual agreement. 11. The parties intend to be bound by the terms of this agreement and intend for this agreement to be made an Order of Court. The Honorable Edward E. Guido Fj I Fed R X LOOZ Michelle Rhinehart, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW CUSTODY Tom Raudabaugh, Defendant NO. 05 - 710 CIVIL TERM CERTIFICATE OF SERVICE I, Holly O. Vaughn, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the June 29, 2007 Order of Court regarding custody on Tom Raudabaugh, by depositing on July 11, 2007 a copy of the same in the United States mail, postage prepaid, addressed as follows: Tom Raudabaugh P. O. Box 271 Aspers, PA 17304 4?6?b 1'?Vik Holly O. aughn Certified Legal Intern &Wul &o_m ZA Mega Riesmeyer Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 <'> c? r ? ..: ! """ fT'f J^" ---- ; J iT k ?i ?r. . 7 } ?` !? ? f?e .. { •? ' .? MICHELLE E. RAUDABAUGH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE, CUSTODY TOM L. RAUDABAUGH, Defendant NO.2004 - 710 CIVIL TERM MOTION FOR APPOINTMENT OF MASTER Michelle E. Raudabaugh, Plaintiff, through her counsel, the Family Law Clinic, moves the court to appoint a Master with respect to the following claims: O Divorce O Distribution of Property O Annulment O Support (X) Alimony O Counsel Fees O Alimony Pendente Lite O Costs and Expenses Plaintiff, in support of the motion, states: 1. Discovery is complete as to the claim for which the appointment of a master is requested. 2. Plaintiff filed for divorce on February 9, 2005 under §§ 3301(c) and (d) of the Divorce Complaint. The Divorce Complaint included counts for Custody, Alimony, Equitable Distribution, and Alimony Pendente Lite. 3. Defendant was served with the Divorce Complaint on February 19, 2005. 4. Plaintiff filed a Praecipe to Withdraw Equitable Distribution Count on April 18, 2005. 5. Plaintiff receives Alimony Pendente Lite pursuant to an Order of Court dated September 6, 2005. 6. The claim for Alimony is contested. 7. The claim for Alimony does not involve complex issues of law and/or fact. 8. A hearing is expected to take two hours. WHEREFORE, Plaintiff requests that a master be appointed to hear the Alimony claim. DIL4 Dat X - O LACE ROBERT E. RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 170131 717-240-2968 ?, ?, t - r? r ?., -i O „?,vy T rn _r, ri? ,4, "l 1(.5 ,_;rn _'?