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HomeMy WebLinkAbout05-3412A. RONEY, V. Plaintiff AMELA S. RONEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. OS 35//a CIVILTERM CIVIL ACTION - LAW IN DIVORCE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the court. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be home by you and your spouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street LAW OFFICES SNELOAKER & BRENNEMAN, P.C. Carlisle, PA 17013-3302 (717) 249-3166 SNELBAKER & BRENNEMAN, P.C. By: A 4orneys for Plaintiff CURTIS A. RONEY, V. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA PAMELA S. RONEY, Defendant NO. 40'5-- `3 y l2 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT COUNT I - DIVORCE The Plaintiff herein is CURTIS A. RONEY, an adult individual, who resides at 800 West Keller Street (Mechanicsburg, PA 17055) in the Township of Monroe, Cumberland County, Pennsylvania. The Defendant herein is Pamela S. Roney, an adult individual, who resides at the same address as Petitioner: 800 West Keller Street (Mechanicsburg, PA 17055) in the Township of Monroe, Cumberland County, Pennsylvania. 3. The parties were lawfully joined in marriage on December 3, 2003, in the Borough of Newville, Cumberland County, Pennsylvania. 4. Both parties have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction since the date of the marriage as averred in paragraph 3 hereinabove. LAW OFFICES SNELBAKER & 6. Neither 11art is a member of the armed forces of the United States of America. Y Y BRENNEMAN, P.C. 11 7. Plaintiff avers as the alternative grounds upon which this action is based: a. That the marriage between the parties is irretrievably broken; or b. That the Defendant has offered such indignities to Plaintiff, the innocent and injured spouse, as to render his condition intolerable and life burdensome. Plaintiff has been advised that counseling is available and that he may have the right to request the Court to require the parties to participate in counseling. Plaintiff waives such right as evidenced by his affidavit thereto attached hereto marked "Exhibit A". WHEREFORE, Plaintiff requests this Court to enter a decree of divorce, dismissing the Plaintiff from the bonds of matrimony heretofore existing between the parties. COUNT I1- EQUITABLE DISTRIBUTION OF MARITAL PROPERTY 9. Paragraphs 1 through 8 hereinabove are incorporate herein by reference thereto. 10. The Parties have legally and beneficially acquired property during the course of this marriage. 11. The parties have not agreed to any equitable distribution of marital property. WHEREFORE, Plaintiff requests this Court to order equitable distribution of marital property. WHEREFORE, Plaintiff requests this Court to: A. Enter a decree of divorce, divorcing Plaintiff from the bonds of LAW OFFICES SNELBAKER $ BRENNEMAN, P.C. matrimony; B. Order equitable distribution of marital property; and 2 C. Order such other relief as this Court deems just and reasonable. SNELB jd MAN, P.C. By; (/P i . Snelbaker, Esquire 44 West Main Street Mechanicsburg, PA 17055-0318 (717) 697-8528 Attorneys for Plaintiff Curtis A. Roney Date: July S , 2005 lAW OFFICES SNELBAKER & BRENNEMAN,P.C. 3 VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce are true and I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unworn falsification to authorities. 'P,a - R Curtis A. Roney Date: July S , 2005 LAW OFF)CES SNELSAKER & SRENNEMAN,P.C. A. RONEY, Plaintiff v. t S. RONEY, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT Curtis A. Roney, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage coumseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. I Being so advised, I do NOT request that the court require my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Curtis A. Roney lAW OFFICES Date: July -T 2005 SNEL9AKER & 3RENNEMAN. P.C. EXHIBIT A 0 R? ? 0 0 (n ?Q Q5) cs e -„ it { ? n? T i 'YI+T Ot J W `•7 CURTIS A. RONEY, V. PAMELA S. RONEY, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.O` 5 ? 37 0- CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PETITION FOR SPECIAL RELIEF AND NOW, comes Plaintiff-Petitioner, Curtis A. Roney, by his attorneys, Snelbaker & Brenneman, P.C., and respectfully represents as follows: Curtis A. Roney, the Petitioner herein, is an adult individual, who resides at 800 West Keller Street (Mechanicsburg, PA 17055) in the Township of Monroe, Cumberland County, Pennsylvania. 2. Pamela S. Roney, the Respondent herein, is an adult individual, who resides at the same address as Petitioner: 800 West Keller Street (Mechanicsburg, PA 17055) in the Township of Monroe, Cumberland County, Pennsylvania. The parties are husband and wife, having been married at Newville, Pennsylvania on December 3, 2003. 4. No children were born of this marriage. 5. Petitioner is the sole owner of the premises in which the parties reside, having LAW OFFICES SNELBAKER & BRENNEMAN, P.C. acquired the same in 1995, by (a) decree awarding real estate from Estate of Mary Louise Roney, deceased (see Cumberland County Deed Book 119, Page 1087) as to an undivided one-half interest, and (b) deed from Sharon Roney Myers as to an undivided one-half interest (see Cumberland County Deed Book, 120, Page 778). 6. Under the law of Pennsylvania, said real estate is non-marital property. Petitioner has resided in said real estate all of his life, which pre-dates his to Respondent. Commencing in the spring of 2005, Respondent began a persistent course of against Petitioner which has rendered his condition intolerable and life burdensome, including, but not limited to, but highlighted by, falsely accusing Petitioner of using controlled substances, to wit: crack, cocaine, including making false reports to the Pennsylvania State (which she admitted to Petitioner) and to the authorities of the County of Cumberland, by whom Petitioner is employed as a corrections officer at the Cumberland County Prison. 9. As a result of such false reports, Petitioner was subjected to the humiliation of an investigation by his employer, including being subjected to a medical test, which test was negative. 10. Respondent has continued such false accusations against Petitioner in a threatening, taunting and belligerent manner in the parties' place of residence, and has made such false accusations to Petitioner's associates. 11. Petitioner perceives Respondent's persistent and increasing threatening and taunting conduct to be a means of provoking him to aggressive reactions, which is constantly disturbing, frustrating and the source of tension. 12. Petitioner's only practical defense to and relief from such course of conduct has LAW OFFICES SNELBAKER & BRENNEMAN, P.C. been to absent himself from his own home which is, in itself, disconcerting, disturbing, and something which he should not be required to do as the owner of the subject property. 13. Respondent's conduct is causing Petitioner mental anguish and physical reaction by substantial loss of weight. 14. Petitioner has given Respondent no cause for such conduct. 15. Petitioner has requested Respondent to remove herself from his property, which Respondent refused to do without being paid an unspecified amount of money. 16. Respondent has separate assets and income by which to maintain herself. 17. Petitioner has commenced an action in divorce immediately prior to the filing of this Petition. WHEREFORE, Petitioner respectfully requests your Honorable Court to issue an order giving Petitioner exclusive possession of his real estate and ordering Respondent to vacate the premises immediately. SNELBAKER & BRENNEMAN, P.C. By hard C. Snelbaker, Esquire Attorney I.D. No: 06355 44 West Main Street P.O. Box 318 Mechanicsburg, PA 17055-031E (717) 697-8528 Attorneys for Plaintiff-Petitioner Date: July S , 2005 LAW OFFICES SNELRAKER & BRENNEMAN, P.C. VERIFICATION I verify that the statements made in the foregoing Petition for Special Relief are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. Curtis A. Roney Date: July S, 2005 LAW OFFICES SNELBAKER & BRENNEMAN, P.C. c? C) 1-3 c.:, n? r al IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CURTIS A. RONEY, NO. 05-3412 Plaintiff : CIVIL ACTION - LAW V. IN DIVORCE PAMELA S. RONEY, Defendant PRAECIPE FOR ENTRY OF APPEARANCE To the Prothonotary: Enter my appearance on behalf of Pamela S. Roney. Papers may be served upon me at the address set forth below: Diane G. Radcliff, Esquire 3448 Trindle Road Camp Hill, PA 17011 Date: July 19, 2005 bf ne- adcliff, Esquire I.D. No. 32)12 -737-0100 Attorney for Defendant _? z-a a _ _ Q a j IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CURTIS A. RONEY, NO. 05-3412 Plaintiff CIVIL ACTION - LAW V. IN DIVORCE PAMELA S. RONEY, Defendant PETITION FOR ORDER FOR ALIMONY PENDENTE LITE TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW, this 18`h day of July , 2005, comes the Petitioner, Pamela S. Roney, who files the this Petition for Alimony Pendent Lite and respectfully represents that: 1. Petitioner, Pamela S. Roney, is an adult individual residing at P.O. Box 1344, Mechanicsburg, Cumberland County, PA 17055, and is the Defendant in the above- captioned divorce action. 2. Respondent, Curtis A. Roney, is an adult individual residing at 800 W. Keller Street, Mechanicsburg, Cumberland County, PA 17055, and is the Plaintiff in the above-captioned divorce action. 3. Petitioner and Respondent were married on December 3, 2003, at Newville, Cumberland County, Pennsylvania and separated on July 6, 2005. 4. Respondent has not sufficiently provided support for the Petitioner. 5. Petitioner is not on a financial par with Respondent in prosecuting and/or defending this Divorce Action, and is unable to support herself in accordance with the standard of living established during the marriage. 6. The within action was instituted by the filing of a Divorce Complaint by Plaintiff, Curtis A. Roney, on July 6, 2005. 7. This Petition represents Petitioner's claim forAlimony PendentLite and is filed to secure the entry of an order for alimony pendente lite for the Petitioner. - 1 - 8. A background information sheet pertaining to this claim for Alimony Pendente Lite is being filed with Domestic Relations concurrently herewith as required by Local Rules of Court. 9. The amount of Alimony Pendente Lite requested by the Petitioner is the maximum amount provided for under the guidelines. WHEREFORE, Petitioner prays that the Court enter an Order: a. Requiring the Respondent to pay the Petitioner Alimony Pendente Lite in the maximum amount provided for by law under the state support guidelines; b. Requiring the Respondent to provide medical insurance and support for the Petitioner. Respectfully submitted, DIANE G. DCLIFF, ESQUIT 448 Tr' e Road Camp Hill, PA 17011 Supreme Court ID # 32112 Phone: (717)737-0100 Fax: (717)975-0697 Attorney for Petitioner - 2 - VERIFICATION I verify that the statements made in this Petition for Alimony Pendent Lite are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. T? J PAMELA S. RONEY DATE: -?- f 0 - 0 5 - 3 - l? i. Y G? _J' T [i <? `, ?y ) C*, .? , ,c ` ? -.? C ' `> ?;? ;,a, n lA (? Cry G p r _ ? ?. C? ' 'r FJ ?i O IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CURTIS A. RONEY, NO. 05-3412 Plaintiff V. CIVIL ACTION - LAW IN DIVORCE PAMELA S. RONEY, Defendant PACSES NO. DRS ATTACHMENT FOR APL PROCEEDINGS PETITIONER NAME Pamela S. Roney ADDRESS P.O. Box 1344 Mechanicsburg, PA 17055 BIRTH DATE August 5, 1954 SOCIAL SECURITY NUMBER 089-48-9893 HOME PHONE 717-737-7642 WORK PHONE None EMPLOYER NAME N/A EMPLOYER ADDRESS N/A JOB TITLE/POSITION N/A DATE EMPLOYMENT COMMENCED N/A GROSS PAY N/A NET PAY N/A OTHER INCOME $901/month SSD ATTORNEY'S NAME, ADDRESS AND PHONE NUMBER Diane G. Radcliff, Esquire 3448 Trindle Road Camp Hill, PA 17011 (717) 737-0100 - 1 - RESPONDENT NAME Curtis A. Roney ADDRESS 800 W. Keller Street Mechanicsburg, PA 17055 BIRTH DATE July 26, 1946 SOCIAL SECURITY NUMBER 206-36-3745 HOME PHONE 717-766-2772 WORK PHONE 717-245-8787 EMPLOYER NAME Cumberland County Prison EMPLOYER ADDRESS Claremont Road Carlisle, PA 17013 JOB TITLE/POSITION Corrections Officer DATE EMPLOYMENT COMMENCED 1990 GROSS PAY $38,402/year NET PAY Unknown OTHER INCOME None known ATTORNEY'S NAME, ADDRESS & PHONE NUMBER Richard C. Snelbaker, Esquire 44 West Main Street Mechanicsburg, PA 17055 (717) 697-8528 - 2 - MARRIAGE INFORMATION DATE OF MARRIAGE December 3, 2003 PLACE OF MARRIAGE Newville, PA DATE OF SEPARATION July 6, 2005 ADDRESS OF LAST MARITAL HOME 800 W. Keller Street Mechanicsburg, PA 17055 PROCEEDINGS INFORMATION DATE OF FILING OF DIVORCE July 6, 2005 NAME OF PARTY FILING DIVORCE Curtis A. Roney DESCRIPTION OF DOCUMENT RAISING APL/COUNSEL FEES CLAIMS Petition for APL Petition for Economic Claims DATE APL DOCUMENT FILED July 19, 2005 - 3 - N O T c? ?' is _;j C_, ` J-T ? -., m ._,? ? _i t,. i„ =' i `? u v? _ `ri ? =L ??? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CURTIS A. RONEY, Plaintiff : NO. 05-3412 V. : CIVIL ACTION - LAW PAMELA S. RONEY, : IN DIVORCE Defendant NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CURTIS A. RONEY, PAMELA S. RONEY, Plaintiff :NO. 05-3412 V. : CIVIL ACTION - LAW : IN DIVORCE Defendant PETITION FOR ECONOMIC CLAIMS Defendant, Pamela S. Roney, by her attorney, Diane G. Radcliff, Esquire, this Petition for Economic Claims and represents that: 1. Petitioner is Pamela S. Roney, the Defendant in the above-captioned case. 2. Respondent is Curtis A. Roney, the Plaintiff in the above-captioned case. 3. This action was commenced by the filing of a divorce complaint by the respondent on July 6, 2005. 4. The divorce complaint the Defendant raised the following claims: divorce and equitable distribution. 5. The petitioner wishes to raise the following economic claims in this Petition as permitted by the Domestic Relations Law. DEFENDANT'S COUNT I EQUITABLE DISTRIBUTION 6. The Defendant incorporates by reference the averments set forth in Paragraphs 1-5 herein as fully as though the same were set forth at length. 7. Plaintiff and Defendant have acquired property and debts, both real and personal, during their marriage from December 3, 2003 until present, all of which is "marital property". - 2 - 8. Plaintiff and/or Defendant have acquired, prior to the marriage or subsequent thereto, "non-marital property" which has increased in value since the date of marriage and/or subsequent to its acquisition during the marriage, which increase in value is "marital property". 9. Plaintiff and Defendant have been unable to agree as to an equitable division of said property as of the date of the filing of this Complaint. WHEREFORE, Defendant requests this Honorable Court to equitably divide all marital property and debts of the parties. DEFENDANT'S COUNT 111 ALIMONY PENDENTE LITE, ALIMONY 10. The Defendant incorporates by reference the averments set forth in Paragraphs 1-09 herein as fully as though the same were set forth at length. 11. Defendant lacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment. 12. Defendant requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. WHEREFORE, Defendant requests this Honorable Court to enter an award of alimony pendente lite until final hearing and hereafter enter an award of alimony permanently thereafter. DEFENDANT'S COUNT IV COUNSEL FEES AND COSTS 13. The Defendant incorporates by reference the averments set forth in Paragraphs 1-12 herein as fully as though the same were set forth at length. 14. Defendant has employed legal counsel but is unable to pay the necessary and reasonable attorney's fees for said counsel. 15. The Defendant is in need of hiring various experts to appraise the parties' marital assets and does not have the funds to pay the necessary and reasonable fees. - 3 - WHEREFORE, Defendant requests this Honorable Court to enter an award of interim counsel fees, costs and expenses and to order such additional sums hereafter as may be deemed necessary and appropriate and at final hearing to further award such additional counsel fees, costs and expenses as are deemed necessary and appropriate. Respectfully submitted, DIANE G. CLIFF, ESQUIRE nn le Road Camp Hill, PA 17011 Supreme Court ID #32112 Phone: (717) 737-0100 Attorney for Defendant - 4 - VERIFICATION I verify that the statements made in this Answer and Counterclaim to Divorce Complaint are true and correct. Defendant understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. PAMELA S. RONEY Date: -7- If -6 5 CERTIFICATE OF SERVICE AND NOW, this _ day of , 2005, I, DIANE G. RADCLIFF, ESQUIRE, hereby certify that I have this day served a copy of the within PETITION FOR ECONOMIC CLAIMS upon the Plaintiff's attorney, Richard C. Snelbaker, Esquire, by mailing same by first class mail, postage prepaid, addressed as follows: RICHARD S. SNELBAKER, ESQUIRE SNEKBAKER Ix BRENNEMAN, P.C. 44 WEST MAIN STREET MECHANICSBURG, PA 17055 Respectfully submitted, Camp Hill, PA 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 Attorney for Defendant ?l N n+ " ? r L r y Jm? Ji Y?? CURTIS A. RONEY, V. PAMELA S. RONEY, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3412 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO WITHDRAW MOTION TO: PROTHONOTARY OF CUMBERLAND COUNTY We hereby withdraw the Plaintiff s Petition for Special Relief as filed on July 6, 2005. SNELBA R & E4RENNEMAN, P.C. By Riclhard C. Snelbaker, Esquire Attorneys for Plaintiff Dated: July 21, 2005 LAW OFFICES SNELBAKER & BRENNEMAN, P.C. C) hJ {? C:? ?J _ Cry 'i'7 ?? ? ? f ' i 12 r':' ?? 't.., .. C7 ?.I f3 CURTIS A. RONEY, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 2005-3412 CIVIL TERM PAMELA S. RONEY, IN DIVORCE Defendant/Petitioner PACSES # 586107501 ORDER OF COURT AND NOW, this 19"' day of July, 2005, upon consideration of the Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shaddav on August 23, 2005 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 7-19-05 to: < Respondent Diane Radcliff, Esquire Richard Snellbaker, Esquire Date of Order: July 19, 2005 ay, Conference Officer 4J. A- '-4j'7 y 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CURTIS A. RONEY, NO. 05-3412 Plaintiff CIVIL ACTION - LAW V. IN DIVORCE PAMELA S. RONEY, Defendant ACCEPTANCE OF SERVICE I, Diane G. Radcliff, attorney for the Defendant in the above captioned action hereby accept service of the Complaint duly endorsed with a Notice to Plead, which Endorsed Complaint was filed in the above captioned matter on July 6, 2005. 1 certify that I am authorized to accept service on behalf of the Defendant. Date: July 18. 2005 VTANE S-. RA CLIFF, ESQUIRE' Awrney-foKthe Defendant 3448 Trindle Road Camp Hill, PA 17011 (717) 737-0100 Supreme Court I.D. No. 32112 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION CURTIS A. RONEY, Plaintiff / Rrespondent NO. 2005-3412 Civil Term PACKS NO. 586107501 PAMELA S. RONEY, V. Defendant/ Petitioner CIVIL ACTION-LAW IN DIVORCE INCOME AND EXPENSE STATEMENT OF PAMELA S. RONEY CONFERENCE OR HEARING DATE: AUGUST 23, 2005 I verify that the facts set forth in the following Income and Expenses Form, including all attachments thereto, are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. DATE: 8 o Y d 8eo_z.w PAMELA S. RONEY - 1 - PART I. INCOME A. EMPLOYMENT INFORMATION: Employer: N/A DISABLED AND RECEIVING SSD B. INCOME: DESCRIPTION MONTHLY YEARLY Gross Income (Social Security Disability) $901.00 $10,812.00 Medicare Health Insurance Costs None None Net $901.00 $10,812.00 C. OTHER INCOME: DESCRIPTION WEEKLY MONTHLY YEARLY Interest Dividends Pensions Annuities Rents Royalties Expense Account Gifts Unemployment Compensation Workman's Compensation Income Tax Refunds Support or Alimony Commissions Tips 'TOTA113TH;'iIAJk1E $fl'. $tl:ti?• $% 00 2- PART U. EXPENSES IN WAY , Ci1NT5 ?Uo HOME EXPENSES: Rent $900.00 First Mortgage Second Mortgage/Home Equity Loan Maintenance and Repairs Electric $45.00 Gas $119.00 Oil Telephone $25.00 Water $18.00 Sewer Trash EMPLOYMENT Public Transportation Lunches Other Employment Expenses TAXES: Real Estate Taxes Personal Property Taxes Income Taxes Not Withheld Per Capita/ Occupation Taxes - 3 - ?PI INSURANCE: MNf fLY ...#NT fi?E1if f Homeowners Insurance Automobile Insurance $110.00 Life Insurance Accident Insurance Health Insurance Otherlnsurance AUTOMOBILE EXPENSES: Payments Fuel $70.00 Maintenance and Repair $25.00 License and Registration $20.00 MEDICAL EXPENSES NOT REIMBURSED BY INSURANCE: Doctor $130.00 Dr. $30/13W Counseling $30/13W Optical Dental Orthodontic Hospital Medicine $100.00 Special Needs/Therapy, Etc. 4- EE IfI EDUCATIONAL EXPENSES: rYEONTNL. #M . NTS Private School Parochial School College/Vocational Religious Training or Education Books/Fees and Supplies Other Educational Expenses PERSONAL EXPENSES: Clothing $75.00 Food $250.00 Barber and Hair Dresser $40.00 Memberships Other Personal Expenses CREDIT CARDS AND LOANS: ATEtT Universal $224.00 $10,794 balance GE Money Bank $188.26 $9,000 balance Chase Platinum MC $200.00 $9,800 balance MISCELLANEOUS EXPENSES: Household Help Child Care Newspapers/Magazines/Books $20.00 Entertainment TBD TBD based on affordability Pay TV $40.00 - 5 - Vacations TBD TBD based on affordability Gifts $50.00 Legal Fees $250.00 $3000 retainer fee paid Charitable Contributions Other Child Support (not this action) Other Spousal Support or Alimony (not this action) Vet bills for dogs $20.00 TOTAL EXPENSES' $2,919.26 -6- PART III. PROPERTY OWNED PART IV. INSURANCE INSU RANCE INFORMATION 1?A#1f II PII'Q COVERAGE 141 W C' Hospital Medicare 089489893 x Medical H's Highmark PPO ZAR10502430900 1 x x Health Accident Disability Income Dental H's Delta Dental TBD x x Vision Other-Specify *H=Husband; W=Wife; J=Joint; C=Child 7- PART V. SUPPLEMENTAL INCOME STATEMENT [ d ] CHECK HERE IF NOT APPLICABLE (a) This form is to be filled out by a person: (1) Who operates a business or practices a profession, or (2) Who is a member of a partnership or joint venture, or (3) Who is a shareholder in and is salaried by a closed corporation or similar entity. (b) Attach to this statement a copy of the following documents relating to the partnership, joint venture, business, profession, corporation or similar entity (check block to indicate the document is attached): (1) The most recent Federal Income Tax Return. [ ] attached (2) The most recent Profit and Loss Statement. [ ] attached (c) Name of Business: Business Address: Business Telephone: (d) Nature of Business (check one) [ ] 1. Sole Proprietorship [ ] 2. Partnership [ ] 3. Joint Venture [ ] 4. Professional [ ] 5. Corporation [ ] 6. Other (e) Name of accountant, controller or other person in charge of financial records: (f) Bu! 1. 2. 3. 4. 5. iness Income: Annual income from business: How often is income received: Gross income per pay period: Net income per pay period: Specify deductions, if any: Your New Benefit Amount 26:62, BENEFICIARY'S NAME: SOCIAL SECURITY CLAIM NUMBER PAMELA S RONEY (only the last 4 digits are shown to help prevent identity theft): XXX-XX--9893 A Your Social Security benefits will increase by 2.7 percent in 2005, because of a rise in the cost of living. You can use this letter when you need proof of your benefit amount to receive food stamps, rent subsidies, energy assistance, bank loans, or for other business. How Much Will I Get And When • Your new monthly amount (before deductions) is $901.00 • The amount we are deducting for Medicare is $0.00_ (If you did not have Medicare as of Nov. 19, 2004, or if someone else pays your premium, we show $0.00.) • The amount we are deducting for voluntary federal tax withholding is --$0.00-. (If you did not elect voluntary federal tax withholding as of Nov. 19, 2004, we show $0.00.) • After taking any other deductions, we will deposit $901.00 into your bank account on Jan. 12, 2005. If you disagree with any of these amounts, you should write to us within 60 days from the date you receive this letter. What If I Have Questions? We invite you to visit our website at www.socialsecurity.gov on the Internet to find general information about Social Security. You also can call us at 1-800-772-1213 and speak to a representative from 7 a.m. until 7 p.m. on business days. If you have a touch-tone phone, recorded information and services are available 24 hours a day. Our lines are busiest early in the week and early in the month so, if your business can wait, it is best to call at other times. If you are deaf or hard of hearing, you may call our TTY number, 1-800.325-0778. If you are outside the United States, you can contact any U.S. embassy or consulate office, or the Veterans Affairs Regional Office in Manila. Please have your full nine-digit Social Security claim number available when you call or visit and include it on any letter you send to the Social Security Administration. If you are inside the United States, you also can visit your local office. MINERVA MILLS BLDG 401 EAST LOUTHER ST CARLISLE PA BNC#: 04131818D20040 SOCIAL SECURITY ADMINISTRATION OFFICE OF CENTRAL OPERATIONS 1500 WOODLAWN DRIVE BALTIMORE MD 21241-1500 OFFICIAL BUSINESS PENALTY FOR PRIVATE USE, $300 Be sure to check out our website: www.socialsecurity.gov PRESORTED FIRST-CLASS MAIL POSTAGE AND FEES PAID SOCIAL SECURITY ADMINISTRATION PERMIT NO. G-11 263826************** AUTOCiR ** C-007 PAMELA SRONEY 800 W FELLER ST MFC:HANTC,RRTTRP VA 170JrA-7s1u Over > t NI(ME _ RONEY, CURTIS A. 1 NUMBER -SOCIAL SECURITY 4 490 745 'PERIOD 05/01/2005-05/14/2005 CHECK NO , 00252534 CMECH DATE,a " 05/20/2005 E%EMPTIONS( FLING 1Bi °l a i r A NO., w DESCRIPTION ? 'HOURS `RATE; " AMOUNT, "YTO AMOUNT DESCRIPTION "-I AMOUNT' "y'YTD ypM,OUNT 'SS`'.' 1 „ , T REGULAR 77.00 17.07 1,314.39 11 044.29 TAX FICA MEO 19.14 20T53, E, SICK OLD 3.00 17.07 51.21 734.01 TAX FICA SS 81.83 887 36 A VACATION 1,775.28 E` TAX FWT 162.68 , 1,89265 f OTHOL OVERTIME 614.52 409 68 G; TAX LWT ' TAX' UC" 22.44 2 33; N' ' . Um 1.23 - SICKNEW 102.42 TAX SWT 40.52 '439413 SHOE 90.00 TAX OPT "1000, N - r PRETAX BUYUP EE I 46.78 , • 457 90 -" G ' PRETAX RET PRE 6838 ` 13-00 S = G ' ^AFTERTAX RET AFT 68.28 734 DO Np AFTERTAX UNDUEFS '13.38 133.80 , r 'A' a ' " ?h p " E " S µ`t1 t „ i I 1 iE It? i f } F a. d? ? •y 3 F R +? I R 4 it EARNI NGS ' ' AROSE PAY '"'TA%ACLE PAY NET PPY -OE CCCTICN6 ?^, PRPTA 7v. _,`h "rvCCMP ANY?' n•,'sA1'I'E¢X tHls:eEeiDn• - - . __. _ .7?E5 E0 _....12E1 F'i .. ::842.07 397 :RF 7]A 07 YEAR•TOMATE =1 14.//U.2U1 13.576:301 9.U19.931- "- d : I I 1 -? 'I'.' 1 11, °" DESCRIPTION ACCOUNT AMOUNT YTD AMOUNT A DESCRIPTION: BALANCE "DESCRIPTION ? 6ALANCE : OESCRIPTI?4(.SACA NCE 5MZ c COMPTIME .00 E`. PERSONAL 16.00 T VSICK OLD 968.72 V; VACATION 198.20 ° ..•4... E. T.T' P U" A.,.. 5 : E I T 5 71 IMRFRI ANTI C(H INTV - V REMOVE DOCUMENT ALONG THIS PERFORATION V 0 Department of the Treasury - Internal Revenue Service Form 1040 U.S. Individual Income Tax Return Fofthayealdan 1-Dec 31,2004, or Other aax year beginning Libel L, Your final name and initial Last name (see' A CURTI S A RONE7 retractions 13 on page 16.) E If a joint return, spouse's first name and initial Last name Ilse"IRS L PAMELA S RONE7 label. H Home address (number and street). If you have a P.O. box, see page 16, otharalse, plans. print R 800 W. KELLER ST. or type- E City, town or past office, state, and ZIP code- If you have a foreign address, see page 16. Presidential MECHANICSBURG PA Election Campaign Note. Checking "Yes" will not change your tax or reduc (See Dace 16.) )II, Do you, or your spouse if filing a joint return, want $3 tc Filing 1 2 Status Check only 3 one box. nor Exemptions It more than four dependents, see page 18. 7 ............................... d Total number of exemptions claimed Wages, salaries, tips, etc. Attach Form(s) W-2 on 6a aned 6b No. olf children on 6c who: • lived with you (tied rot live with you due to dvace or separbm face page 18) Oependent5 pit 6c Add matters above nber on lines sage ? 2 Income 7 37,592 8a Taxable interest. Attach Schedule B if required .. . . . .... . ... . 8a 6 , 554 Attach Form(s) W-2 here. Also attach Forms b 9a Tax-exempt interest. Do not include on line 8a . .... Bb Ordinary dividends. Attach Schedule B if required . . . . .. .. . ... .. - 9a 1 , 3 6 2 W-2G and 1099-R it tax was withheld. b 10 qualified dividends (see page 20) ... . . . . . . .... 9b 1 , 362 Taxable refunds, credits, or offsets of state and local income taxes (see page 20) . . .... 10 11 Alimony received . . . .. . .... . . . . . . . ..... .. . . . . . . . ... . . 11 If you did not 12 Business income or (loss). Attach Schedule C or C-EZ . . . . . ....... . ... . . 12 get a e, 19 13 Capital gain or (loss). Attach Schedule D if required. If not required, check here ? 13 . see page 14 Other gains or (losses). Attach Form 4797 ... ..... .. 14 Enclose, but do 15a IRA distributions . .. 15a b Taxable amount (see page 22) 15b 2 3 , 6 9 3 not attach, any Also ment a 16a Pensions and annuities 16a b Taxable amount (seepage 22) 161b . , p y please use 17 Rental real estate, royalties, partnerships, S corporations, trusts, etc. Attach Schedule E . 17 Form 1040-V. 18 Farm income or (loss). Attach Schedule F . . . . . ......... . . . . ... . 18 19 Unemployment compensation ... ..... . . . . . . .... . . ... 19 20a Social security benefits 20a I 10,536 I It Taxable amount (seepage 24) 20b 8 , 9 5 6 21 Other income. 21 Adjusted Gross Income 22 Add the amounts in the far right column for lines 7 through 21. This is your total income ? 23 Educator expenses (see page 26) . . ...... .. . 23 24 Coast, business expenses of reservists, performing artists, and fee-b Isis government officials. Attach Form 2106 or 2101 . . . 24 25 IRA deduction (see page 26) . ... . . . . . . . . . . 25 26 Student loan interest deduction (see page 28) . . .. . 26 27 Tuition and fees deduction (see page 29) . . . .. . . . 27 28 Health savings account deduction. Attach Form 8889 .. 28 29 Moving expenses. Attach Form 3903 . . . . . . . . . . 29 30 One-half of self-employment tax. Attach Schedule SE 30 31 Self-employed health insurance deduction (see page 30) 31 32 Self-employed SEP, SIMPLE, and qualified plans .. . . 32 33 Penalty on early withdrawal of savings . . . . . . . . . 33 34a Alimony paid b Recipient's SSN ? 34a 35 Add lines 23 through 34a . . . . ... . . . . . . . ... ..... . . . . ... . 36 Subtract line 35 from line 22. This is your adjusted qross income . . . . . ... . . ... ? For Disclosure, Privacy Act, and Paperwork Reduction Act Notice, see page 75. EEA Single 4 Married filing jointly (even if only one had income) Manned filing separately. Enter spouse's SSN above and full 112004 APL np. ,20 1 01 No. Your social security number security nur ber You must enter your SSN(s) above. 17055-4076 1 your refund. Your? Spouse oto this fund? .. . . . . 0- F1 Yes [XI No nYesn No Head of household (with qualifying person). (See page 17 ) If the qualifying person is a child but not your dependent enter this child's name here. :1e ? 5 Qualifying widow(er) with dependent 6 a EX] Yourself. If someone can claim you as a dependent, do not check box 6a .. . . . ... . 61x1 Snnuee c Dependents: (1) First name Last name (2) Dependent's social security number (3) Dependents relationshipro you (4) Check if qualifying d (edi 14 t Is.. Pat 11 11 11 35 L1 Form 1040 (2004) Form 1040(2004) CURTIS A & PAMELA S RONEY 3745 Paget Tax and 37 Amount from line 36 (adjusted gross income) . . . . . .. ... . . .... . 37 78,157 Credits 38a Check { You were born before January 2, 1940 Blind. Total boxes e e F if: ` Spouse was born before January 2, 1940, Blind. checked ? 38a Standard b If your spouse itemizes on a separate return or you were a dual-status alien, see pg 31 & chock here ? 38b ? Deduction for- 39 Itemized deductions (from Schedule A) or your standard deduction (see left margin) 39 9 , 7 0 0 • People who 40 Subtract line 39 from line 37 .. . . . .......... . . .... . . ... . . . .. 40 6 8 , 4 5 7 checked any 41 If line 37 is $107,025 or less, multiply $3,100 by the total number of exemptions claimed on box on line 3?a or 38b or cl can line 6d. If line 37 is over $107,025, see the worksheet on page 33 . . . . . . . . ..... 41 6 , 2 0 0 claimed as s a 42 Taxable income. Subtract line 41 from line 40. If line 41 is more than line 40, enter -0- 42 62 , 2 5 7 dependent, 43 Tax (see page 33) Check if any tax is from: a ? Form(s) 8814 b ? Form 4972 43 8 898 see page 31. . . . . , • All others: 44 Alternative minimum tax (see page 35). Attach Form 6251 . . .. ... . .. .. ... . 44 Single or 45 Add lines 43 and 44 .. .. . . .. . . . . . . . . .. .. . . . . .. . . . . .... ? 45 8 , 8 9 8 Married filing se aratel 46 Foreign tax credit. Attach Form 1116 if required . . . . . 46 p y, $4,850 47 Credit for child and dependent care expenses. Attach Form 2441 47 Married filin 48 Credit for the elderly or the disabled. Attach Schedule R . . 48 g jointly or 49 Education credits. Attach Form 8863 49 g widower), 50 Retirement savings contributions credit. Attach Form 8880 . 50 $9,700 51 Child tax credit (see page 37) . . . ..... . . . . . . . 51 _..;:...-'. Head of 52 Adoption credit. Attach Form 8839 ....... 52 household, 53 Credits from: a ? Form 8396 b ? Form 8859 . 53 $7,150 54 Other credits. Check applicable box(es): a ? Form 3800 b Form 8801 c ? Specify . . 54 55 Add lines 46 through 54. These are your total credits ... . ... .. . . ....... . 55 56 Subtract line 55 from line 45. If line 55 is more than line 45, enter -0- . ? 56 8,8 9 8 Other 57 Self-employment tax. Attach Schedule SE . . . .. . . . .. . .. . .. .. . . . . . . 57 Taxes 58 Social security and Medicare tax on tip income not reported to employer. Attach Foos 4137 58 59 Additional tax on IRAs, other qualified retirement plans, etc. Attach Form 5329 if required 59 60 Advance earned income credit payments from Form(s) W-2 . . . . . .. . . ..... . 60 61 Household employment taxes. Attach Schedule H . . . . ... . . . ... . . . . . . . 61 62 Add lines 56 through 61. This is your total tax ...... . . ... . . ...... . . ? 62 8, 898 Payments 63 Federal income tax withheld from Forms W-2 and 1099 .. . . 63 5 , 574 ^ 64 2004 estimated tax payments and amount applied from 2003 return . . h 64 ave g ve a 65a Earned income credit (EIC) .. . ..... . . . . . . . 65a ach Ec b Nontaxable combat pay election . ? 65b e EIC. s 66 Excess social securi ty and fiat 1 EFTA tax withheld (see page 54) . . 66 67 Additional child tax credit. Attach Form 8812 . ...... 67 68 Amount paid with request for extension to file (see page 54) . 68 69 Other payments from a? Form 2439 is ? Form 4136 c ? Form 8885 69 70 Add lines 63, 64, 65a, and 66 through 69. These are your total pay ments . . . . .... ? 70 5 , 5 7 4 Refund 71 If line 70 is more than line 62, subtract line 62 from line 70. This is the amount you overpaid 71 72a Amount of line 71 you want refunded to you . .. ? ' Direct deposit? 72a '- See page 54 ? b Routing number ?c Type: Checking Savings and fill in 72b, ? d Account number 72c, and 72d. 73 Amount of line 71 you want applied to your2005 esfirreted tax ? 73 Amount 74 Amount you owe. Subtract line 70 from line 62. For details on how to pay, see page 55 ? 74 3 , 324 You Owe 75 Estimated tax penalty (see page 55) .. . . ...... .. 75 Third Party uu yuu want «, allow anotner person to discuss tnls return with the IRS (see page 56)? U Yes. Complete the following. U No Designee Designee's name Phone no. Personal identification ?ALFRED L WHITCOMB EA ?717-766-9477 b(PIN) ? L10 2 2 4 Sign Under penalties of perjury, I declare that I have examined this return and accompanying schedules and statements, and to the best of my knowledge and Here belief, they are true, correct, and complete. Declaration of preparer (other than taxpayer) Is based on all information of which preparer has any knowledge Joint return? Your signature 43745 Date Your occupation Daytime phone number See page 17. 2005-03-28 SECURITY Keep a copy ' Spouse's signature u , road must sign. Data for your ?498?J? sp°useso°upauon 717-766-2772 records. HOUSEWIFE Paid Preparer's L signature Preparer's Use Onl Only Firm's name (or WHITCC if ll yours sti employed). '43 WES address, antl ZIP code Checkii 8- Q 2- 2 Q Q 5 sel4employetl NCIAL SERVICE EIN taperers ssN or PTIN 176-34-894 3-1943547 MECHANit-bbuxu PA 17055-62621Ph 717-766-9477 EEA Form 1040 (2004) Schedules A&B (Form 1040) 2004 OMB NO.-1 545-0074 Page 2 Name(s) shown on Form 1040. Do not enter name and social security number it shown on page 1. Your social security number CURTFS A & PAMELA S RONEY 3745 Schedule B-Interest and Ordinary Dividends Attachment Sequence No. 08 1 List name of payer. If any interest is from a seller-financed mortgage and the Amount Part I buyer used the property as a personal residence, see page B-1 and list this Interest interest first. Also, show that buyer's social security number and address ? (See page B-1 and the instructions for CITIZENS BANK 15 7 Form 1040, CITIZENS BANK US SAVINGS BONDS 6,397 line 8a.) 1 Note If you . received a Form 1099-INT, Form , 1099 01D r - , o substitute statement from a brokerage firm, list the firm's name as the payer and enter the total interest shown on that 2 Add the amounts on line 1 . .. .... . . .... ... . . . . .. . . . . ... 2 6 , 554 form. 3 Excludable interest on series EE and I U.S. savings bonds issued after 1989. Attach Form 8815 . . .. . .. ... . . . ....... . . . ... . . . . ... . . 3 4 Subtract line 3 from line 2. Enter the result here and on Form 1040, line 8a . ? 4 6 , 5 5 4 Note: If line 4 is over $1,500, you must complete Part III. Amount 5 List name of payer ? Part II Ordinary SHAREBUILDERS SECURITIES 4 Dividends MET LIFE 30 (See page B-2 FISERV SECURITIES 1,318 EDWARD JONES n c 10 i stru tions for Form 1040 , line 9a.) ? r r? Note. If you 5 received a Form 1099-01V or substitute statement from a brokerage firm, list the firm's name as the payer and enter t di nary he or dividends shown on that form. 6 Add the amounts on line 5. Enter the total here and on Form 1040, line 9a . ? 6 1 , 3 62 Part III Foreign Accounts and Trusts (See page B-2.) For Paperwork Note. If line 6 is over $1,500, you must complete Part III. You must complete this part if you (a) had over $1,500 of taxable interest or ordinary dividends; or (b) had a foreign account; or (c) received a distribution from, or were a grantor of, or a transferor to, a foreign trust. 7a At any time during 2004, did you have an interest in or a signature or other authority over a financial account in a foreign country, such as a bank account, securities account, or other financial account? See page B-2 for exceptions and filing requirements for Form TD F 90-22.1 . . . . . . . . . . . . . . b if "Yes," enter the name of the foreign country ? 8 During 2004, did you receive a distribution from, or were you the grantor of, or transferor to, a foreign trust? If "Yes," you may have to file Form 3520. See page B-2 duction Act Notice. see Form 1040 instructions. EeA Schedule 8 (Forr No X X 2004 SCHEDULED (Form 1040) Depa,+ment of the Treasury Internal Revenue Service Capital Gains and Losses ? Attach to Form 1040. ? See Instructions for Schedule D (Form 1040) ? Use Schedule D-1 to list additional transactions for lines 1 and 8. OMB No. 1545-0074 2004 Attachment Sequence No. 12 Name(s) shown on Form 1040 Your social security number CURTIS A & PAMELA S RONEY MONOW3745 Part t +;l Short-Term Capital Gains and Losses -Assets Held One Year or Less (a) Description of property (Example: 100 sh. %YZ CO,) (b) Data acquired (yc, mo. tlay) c Date sold (yr., mo.. day) (d) sales price I sea page D-6 of the nstr Nefions) (e) Cost or other basis (see page D-6 of the instmetlons) (t) Gain or (Ines) Subtract (9) from (tl) 1 FISERV SECR ARI U 0040413 22 22 2 Enter your short-term totals, if any, from Schedule D-1, line2 ................................... 2 '. 3 Total short-term sales price amounts. Add lines 1 and 2 in column (d) .. . ... . .. . . .. . . . .... .. . . .... . ... 3 22 4 Short-term gain from Form 6252 and short-term gain or (loss) from Forms 4684, 6781, and 8824 . . . .... .4 5 Net short-term gain or (loss) from partnerships, S corporations, estates, and trusts from Schedule(s) K-1 ... . .. . . .. . . . .. . . ... . .... . .... . ... . . .. . . . .. . . . . 5 6 Short-term capital loss carryover. Enter the amount, if any, from line 8 of your Capital Loss Carryover Worksheet on page D-6 of the instructions . ..... ... . . . . . . . ..... . .. . . . . 6 ( ) 7 Net short-term capital qain or (loss). Combine lines 1 through 6 in column (f) 7 Part It Long-Term Capital Gains and Losses - Assets Held More Than One Year (a) Description of property (Example: 100 sh. %VZ Co.) (?) Data acquired (Yr., mo., day) (c) Date sold (yc, mo., day) (d) Sales price (see page D-6 of the instructions) (e) Cost or other basis (see page D-6 of the instructions) (f) Ga. or (loss) Subtract (e) from (d) 8 AJ- 9 Enter your long-term totals, if any, from Schedule D-1, line 9 ................................. 9 10 Total long-term safes price amounts. Add lines 8 and 9 in column (d) . . . . . ... . . . . . . .. . .. . .. .. . ... 10 11 Gain from Form 4797, Part I; long-term gain from Forms 2439 and 6252; and long-term gain or (loss) from Forms 4684, 6781, and 8824 . .. . . . . . . ... . .... . . . . ...... . .. . . . . 11 12 Net long-term gain or (loss) from partnerships, S corporations, estates, and trusts from Schedule(s) K-1 . . . . . .. . . . . . .. . .. . ...... . . .... . . . . . . . . . 12 13 Capital gain distributions. See page D-1 of the instructions .. . . .. . . ... . . .. .. . . . . . .... 13 14 Long-term capital loss carryover. Enter the amount, if any, from line 13 of your Capital Loss Carryover Worksheet on page D-6 of the instructions . .. . . . .. . .... . . . . . . . . . . . ... . 14 ( ) 15 Net long-term capital gain or (loss). Combine lines 8 through 14 in column (f). Then go to Part III on page 2 . . . . . .. . .. . . . .. . . . . . . _ 15 For Paperwork Reduction Act Notice, see Form 1040 instructions EEA Schedule 0 (Form 1(140) 2004 Schedule D (Form 1040) 2004 CURT I S A& PAMELA S RONEY 7 4 5 Page 2 Pa_ .,[Il;i Summary 16 Combine lines 7 and 15 and enter the result. If line 16 is a loss, skip lines 17 through 20, and go to line 21. If a gain, enter the gain on Form 1040, line 13, and then go to line 17 below . . .. . . . . . . 16 17 Are lines 15 and 16 both gains? ? Yes. Go to line 18. ? No. Skip lines 18 through 21, and go to line 22. 11 " 18 Enter the amount, if any, from line 7 of the 28% Rate Gain Worksheet on page D-7 of the instructions .. . . . . .. . . . . . .. . . .. . .. . . . ... . . . .. . ... .. . .. . . . . . . ... 18 19 Enter the amount, if any, from line 18 of the Unrecaptured Section 1250 Gain Worksheet on page D-8 of the instructions . .. . ... . .. . . . . .. . .. . . . ... . .. . . . ... . . . . . . 19 20 Are lines 18 and 19 both zero or blank? ? Yes. Complete Form 1040 through line 42, and then complete the Qualified Dividends and Capital Gain Tax Worksheet on page 34 of the Instructions for Form 1040. Do not complete lines 21 and 22 below. ? No. Complete Form 1040 through line 42, and then complete the Schedule D Tax Worksheet on page D-9 of the instructions. Do not complete lines 21 and 22 below. 21 If line 16 is a loss, enter here and on Form 1040, line 13, the smaller of: • The loss on line 16 or • ($3,000), or if married filing separately, ($1,500) Note: When figuring which amount is smaller, treat both amounts as positive numbers. 22 Do you have qualified dividends on Form 1040, line 9b? ® Yes. Complete Form 1040 through line 42, and then complete the Qualified Dividends and Capital Gain Tax Worksheet on page 34 of the Instructions for Form 1040. ? No. Complete the rest of Form 1040. eEA Schedule D (Form 1040) 2004 L N D C? U C'' C- I'}i f G-i £c L S"' C= CX? -? co W 'ORS "F Tl jrn =-C ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dirt. of CUMBERLAND Date of Order/Notice 08/23/05 Case Number (See Addendum for case summary) EmployerNJithholder's Federal FIN Number @ Original Order/Notice O Amended Order/Notice O Terminate Order/Notice RE: RONEY, CURTIS A. Employee/Obligor's Name (Last, First, MI) 206-36-3745 Employee/Obligor's Social Security Number CUMBERLAND COUNTY 3915101526 C/O CONTROLLERS OFFICE Employee/Obligor's Case Identifier 1 COURT HOUSE SQ ?K?, coos-31/?y i?d (See Addendum for plaintiff names CARLISLE PA 17013-3323 P'{.?rt gL associated with cases on attachment) 5810 ?? ! J?l? 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. $ 501.00 per month in current support $ 84.00 per month in past-due support Arrears 12 weeks or greater? Dyes ® no $ 0 , 00 per month in current and past-due medical support $ o . 0o per month for genetic test costs $ per month in other (specify) for a total of $ 585.00 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: $ 135.00 per weekly pay period. $ 270. oo per biweekly pay period (every two weeks). $ 292. so per semimonthly pay period (twice a month). $ 585.00 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 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. BY THE COURT:, Ar Date of Order: AUG 2 4 2W5 Service Type m OMB N...0970-01,4 &I Form EN-028 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If hecked you are required to provide a copy of this form to your mployee. If yo r employee works in a state that is diferent 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.* vs wager, You must comply with the law of the payclat&date of withholding-is tire clate on-which ainoui it was vy !:I 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: 2360031190 EMPLOYEE'S/OBLIGOR'S NAME: RONEY, CURTIS A. EMPLOYEE'S CASE IDENTIf1ER: 3915101526 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. T 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 Service Type M Page 2 of 2 OMB No, 0970-0154 Form EN-028 Worker ID $IATT ADDENDUM Summary of Cases on Attachment DefendanUObligor: RONEY, CURTIS A. PACSES Case Number 586107501 Plaintiff Name PAMELA S. RONEY Docket Attachment Amount 05-3412 CIVIL$ 585.00 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. ?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. PACKS 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. ?lf checked, you are required to enroll the child(ren) ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available identified above in any health insurance coverage available through the employee's/obligor's employment. through the employee's/obligor's employment. Addendum Form EN-028 Service Type M Worker ID $IATT OMB No. 09)0-0154 ? ? O :::? ? -n c... ? ???r ? c? ?, ri N ni?C' ? '-?? V. ^? ?= •7i.> =? `<- t"n W __? O -- .J PAMELA S. RONEY, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 2005 - 3412 CIVIL TERM CURTIS A. RONEY, IN DIVORCE Defendant/Respondent PACSES# 586107501 ORDER OF COURT AND NOW, this 23`d day of August, 2005, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $901.00 and Respondent's monthly net income/earning capacity is $2190.22, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $585.00 per month payable monthly as follows; $501.00 for alimony pendente lite and $84.00 on arrears. First payment due next pay date at $270.00 bi-weekly. Arrears set at $1002.00 as of August 23, 2005 . The effective date of the order is July 19, 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. Unreimbursed medical expenses that exceed $250.00 annually are to be paid as follows: 0% by Respondent and 100% by Petitioner. The Petitioner is responsible to pay the first $250.00 annually in unreimbursed medical expenses. Respondent to provide medical insurance coverage. Within thirty (30) days after the entry of this Order, the Respondent shall submit to Petitioner written proof that medical insurance coverage has been obtained or that application far 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 £) 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. Consented: Petitioner Respondent DRO: R. J. Shadday Maile"5 Petitioner Respondent Diane G. Radcliff, Esq. Richard C. Snelbaker, Esq. Petitioner's Attorney Respondent's Attorney BY THE COURT, cc360 ,?> _? ? ;?J ;J ., 7 (S1 ?? ?. ??? f_.) .. _I " 'f:r JtY° % ?. G.i CURTIS A. RONEY, V. PAMELA S. RONEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3412 CIVIL TERM CIVIL ACTION - LAW Defendant : IN DIVORCE : PACSES NO: 586107501 PRAECIPE APPEALING INTERIM ORDER FOR ALIMONY PENDENTE LITE AND REQUESTING A DE NOVO HEARING BEFORE THE COURT TO: Prothonotary of Cumberland County CURTIS A. RONEY, Plaintiff in the above captioned matter (Respondent in Order being appealed) hereby appeals from the interim Order dated August 23, 2005, and requests a hearing de novo before the Court BRENNEMAN, P.C. By ,&iMVM C. Snelbaker, Esquire Attorney I.D. No: 06355 44 West Main Street P.O. Box 318 Mechanicsburg, PA 17055-0318 (717) 697-8528 Attorneys for Plaintiff (Respondent) Dated: September 1, 2005. LAW OFFICES SNELBAKER & BRENNEMAN, P.C. CERTIFICATE OF SERVICE I hereby certify that I am this date serving a true and correct copy of the within Praecipe Appealing Interim Order For Alimony Pendente Lite Arid Requesting A De Novo Hearing Before The Court upon the following persons by sending the same by first-class mail, postage paid, addressed as follows: Diane G. Radcliff, Esquire 3448 Trindle Road Camp Hill, PA 17011 (Attorney for Defendant/Petitioner) Rickie J. Shadday, Conference Officer Cumberland County Domestic; Relations Office P.O. Box 320 Carlisle, PA 17013 SNELBA & BRENNEMAN, P.C. By Ric and C. Snelbaker, Esquire 44 West Main Street P.O. Box 318 Mechanicsburg, PA 17055-0318 (717) 697-8528 (Attorneys for Plaintiff/Respondent) Dated: September 1, 2005 LAW OFFICES SNELSAKER & RENNEMAN, P.C. ? ? . } i) G 4" O In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION PAMELA S. RONEY ) Docket Number 05-3412 CIVIL Plaintiff ) vs. ) PACSES Case Number 586107501 CURTIS A. RONEY ) Defendant ) Other State ID Number ORDER OF COURT You, PAMELA S. RONEY plaintiff/defendant of PO BOX 1344, MECHANICSBURG, PA. 17055-1344-44 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3¢>.,3 ? ?mr before a hearing officer of the Domestic Relations Section, on the ?o SEPTEMBER 27, 2005 at 9: ooAM for a hearing. ?? m co o W You are further required to bring to the hearing: <N 15 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. verification of child care expenses, and 4. proof of medical coverage which you may have, or may have available to you 5. information relating to professional licenses 6. other: Form CM-509 Service Type M Worker ID 21302 RONEY V. RONEY PACSES Case Number: 586107501 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Service Type M Worker ID 21302 ?\ 11 V ? G p? .J b ?? 'O ?`J?(w l U ?N\ In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION PAMELA S. RONEY ) Docket Number 05-3412 CIVIL Plaintiff ) VS. ) PACSES Case Number 586107501 CURTIS A. RONEY ) Defendant ) Other State ID Number ORDER OF COURT You, CURTIS A. RONEY 800 W KELLER ST, MECHANICSBURG, PA. 17055-7518 are ordered to appear at DOMESTIC RELATIONS HEARING RM plaintiff/defendant of DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the SEPTEMBER 27, 2005 at 9 : ooAM for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, 2. your pay stubs for the preceding six (6) months, 3. verification of child care expenses, and 4. proof of medical coverage which you may have, or may have available to you 5. information relating to professional licenses 6. other: -5 CD ? cn `; r p O t ? ? n r Form CM-509 Service Type M Worker ID 21302 RONEY V. RONEY PACSES Case Number: 586107501 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: - YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Service Type M Worker ID 21302 r- ? -n cn -± A c!1 L, CURTIS A. RONEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent: CUMBERLAND COUNTY, PENNSYLVANIA V. : DOMESTIC RELATIONS SECTION PAMELA S. RONEY, : PACSES NO. 586107501 Defendant/Petitioner: DOCKET NO. 05-3412 CIVIL INTERIM ORDER OF COURT AND NOW, this day of 2005, upon consideration of the Support Master's Report and Recommendation, a copy of which is attached hereto as Exhibit "A". it is ordered and decreed as follows: A. The Husband shall pay to the Pennsylvania State Collection and Disbursement Unit as alimony pendente lite the sum of $501.00 per month. B. The Husband shall pay to the Pennsylvania State Collection and Disbursement Unit on arrearages the additional sum of $84.00 per month. C. The Husband shall provide health insurance coverage for the benefit of the Wife as is provided through his employer at a reasonable cost. D. The effective date of this order is July 19, 2005. The parties are hereby advised that they may file written exceptions to the Support Master's Report and Recommendation within ten (10) days of this order. Exceptions shall conform with the requirements of Rule 1910.12(f), Pa. R.C.P. If written exceptions are filed by any party, the other party may file exceptions within ten (10) days of the date of service of the original exceptions. If no exceptions are filed within ten (10) days of this interim order, this order shall then constitute a final order. By the Court, SCANNED Cc: Curtis A. Roney Pamela S. Roney Richard C. Snelbaker, Esquire Keith O. Brenneman, Esquire For the Plaintiff/Respondent Diane G. Radcliff, Esquire For the Defendant/Petitioner DRO CURTIS A. RONEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent: CUMBERLAND COUNTY, PENNSYLVANIA V. : DOMESTIC RELATIONS SECTION PAMELA S. RONEY, : PACSES NO. 586107501 Defendant/Petitioner: DOCKET NO. 05-3412 CIVIL SUPPORT MASTER'S REPORT AND RECOMMENDATION Following a hearing held before the undersigned Support Master on September 27, 2005 the following report and recommendation are made: FINDINGS OF FACT 1. The Plaintiff/Respondent is Curtis A. Roney, who resides at 800 West Keller Street, Mechanicsburg, Pennsylvania. Hereafter he will be referred to as "the Husband." 2. The Defendant/Petitioner is Pamela S. Roney, whose mailing address is P.O. Box 1344, Mechanicsburg, Pennsylvania. She will hereafter be referred to as "the Wife." 3. The parties were married on December 3, 2003 and separated on or about July 6, 2005. 4. On July 6, 2005 the Husband filed a complaint for divorce. 5. On July 19, 2005 the Wife filed a petition for alimony pendente lite. 6. The Wife is 51 years of age. 7. The Wife receives social security disability benefits of $901.00 per month. 8. The Wife suffers from fibromyalgia for which she takes prescribed pain medication on a daily basis. 9. The Wife suffers from migrane headaches one to two times per week. 10. The Wife suffers from a hiatal hernia and gastroesophageal reflux disease (GERD). 11. The Wife suffers from epicondylitis, a condition more commonly referred to as "tennis elbow." EXHIBIT "A" 12. The Wife has had bilateral carpel tunnel surgery and surgery for repair of a rotator cuff tear. 13. The Wife suffers from asthma. 14. The Wife suffers from depression and anxiety attacks. 15. The Wife was employed as a customer service representative for Blue Shield until 1996 when she filed a workers compensation claim. 16. The Wife received a $30,000.00 commutation settlement in 1997. 17. The Wife worked as a shelf-stocker for Home Depot for a minimal period of time in 1997. 18. The Wife has not been gainfully employed outside the home since 1997. 19. The Wife has received social security disability benefits since 1999. 20. The Wife has three previous marriages all ending in divorce. 21. Despite her various physical ailments the Wife owns and operates a jet ski most recently during the summer of 2005. 22. The Plaintiff's living expenses, exclusive of credit card payments, total approximately $1,600.00 per month.' 23. The Wife has no savings. 24. The Wife owns a car, a truck, a camper, and a jet ski. 25.The Husband is 59 years of age. 26. The Husband is employed as a corrections officer at the Cumberland County Prison. 27. The Husband has gross bi-weekly income of $1,484.00. 28. The Husband makes mandatory bi-weekly retirement contributions of $148.00. 29. The Husband pays bi-weekly union dues of $13.38. 30. The Husband pays $45.80 bi-weekly for health insurance coverage on both parties through his employer. ' The Plaintiff has credit card expenses of $612.00 per month on an outstanding balance exceeding $30,000.00. 2 31. The Husband will file his 2005 federal income tax return as married/separate. 32. The Husband has annual income from interest and dividends totaling approximately $1,645.00. 33. The Husband has $117,500.00 in his personal checking account. 34. The Husband has savings bonds valued at $16,261.00. 35. The Husband has a brokerage account valued at $23,292.00. DISCUSSION In Clouse v. Clouse, 50 Cumberland L.J. 167, 170 (2001) the Honorable J. Wesley Oler discussed the law of Pennsylvania as it relates to the subject of alimony pendente lite wherein he stated: The determination of whether to award alimony pendente lite has traditionally been a matter within the sound discretion of the trial court. Litmans v. Litmans, 449 Pa. Superior Ct. 209, 222, 673 A.2d 382, 388 (1996) (citing Murphy v. Murphy, 410 Pa. Superior Ct. 146, 599 A.2d 647 (1991), appeal denied, 530 Pa. 633, 606 A.2d 902 (1992), cert. denied, 506 U.S. 868, 113 S.Ct. 196, 121 L.Ed. 2d 139 (1992)). APL is based on the need of one spouse to have the financial resources to pursue or defend a divorce action. Litmans, supra at 222, 763 A.2d at 388. The claimant must show that APL is needed to adequately preserve his or her rights in the litigation. Sutliff v. Sutliff, 326 Pa. Superior Ct. 496, 500, 474 A.2d 599, 600 (1984), overruled on other grounds, Rosen v. Rosen, 520 Pa. 19, 549 A.2d 561 (1988). In this regard, the Pennsylvania Superior Court has stated that "a spouse seeking alimony pendente lite who has sufficient assets to meet the needs of the pending litigation and who is equally situated with the other spouse to maintain or defend the action, will not be awarded alimony pendente lite." Powers v. Powers, 419 Pa. Superior Ct. 464, 467, 615 A.2d 459, 460 (1992). In adjudicating a claim for alimony pendente lite, a court should consider the following factors: "the ability of the other party to pay; the separate estate and income of the petitioning party; and the character, situation, and surroundings of the parties." Litmans, supra at 224, 673 A.2d at 389. Once entitlement to an award of alimony pendente lite is established, the calculation of the amount of the award is made pursuant to the support guidelines. Little v. Little, 47 Cumberland L.J. 131 (1998). The evidence as presented in this case clearly establishes both a need of the Wife for alimony pendente lite and the ability of the Husband to pay it. Her income from social security disability is considerably less than her reasonable living expenses and she has no liquid assets to pursue her economic claims in the divorce action. She suffers from a variety of debilitating ailments and has not been gainfully employed since 1997. Her condition predated the marriage. The Husband has both income and income-generating assets. He is gainfully employed as a corrections officer with gross bi-weekly income of $1,484.00, or $3,215.00 per month. He has annual interest and dividend income totaling $1,645.00, or an average of $137.00 per month.2 His total gross monthly income for support purposes is $3,352.00. After deductions for taxes, mandatory retirement, and union dues are taken from his gross monthly income, the Husband has net monthly income for support purposes of $2,229.00.3 With the Wife having net monthly income of $901.00 and the Husband having net monthly income of $2,229.00, the Husband's obligation for alimony pendente lite calculated pursuant to the guidelines is $531.00 per month.4 The length of time in which the parties resided together from the date of the marriage to the date of final separation is a factor to be considered in determining whether to deviate from the guideline award in a claim for alimony pendente lite. The parties married on December 3, 2003 and separated on or about July 6, 2005. They resided together for approximately 19 months following the marriage, a relatively short duration. Another relevant and appropriate factor to consider in this case is the Husband's payment of $45.80 bi-weekly, or $99.00 per month, to provide health insurance coverage for himself and his wife. Taking all factors into consideration, a downward deviation in the APL obligation to $501.00 per month is recommended.6 RECOMMENDATION A. The Husband shall pay to the Pennsylvania State Collection and Disbursement Unit as alimony pendente lite the sum of $501.00 per month. B. The Husband shall pay to the Pennsylvania State Collection and Disbursement Unit on arrearages the additional sum of $84.00 per month. See Plaintiffs Exhibit I. a See Exhibit "A" for the tax deductions from gross income. a See Exhibit °B" for the calculation. s See Pa. R.C.P. 1910.16-5(6)(8). " Although Pa. R.C.P. 1910-16-5(c) permits consideration of the period of time the parties resided together from the date of the marriage to the final separation in determining the duration of an award of alimony pendente lite, no recommendation relative to duration of award is made at this time. 4 C. The Husband shall provide health insurance coverage for the benefit of the Wife as is provided through his employer at a reasonable cost. D. The effective date of this order is July 19, 2005. 2 2CY?? ??1K k? Da a Michael R. Rundle Support Master In the Court of Common Pleas of Cumberland County, Pennsylvania Tax Detail Report Plaintiff Name: Pamela S. Roney Defendant Name: Curtis A. Roney Docket Number: 05-3412 Civil PACSES Case Number: 586107501 Other State ID Number: Tax Year: Current: 2005 Defendant Plaintiff 1. Tax Method 1040 ES 1040 ES 2. Fling Status Married Filing Separately Single 3. Who Claims the Exemptions Obligee 4. Number of Exemptions 1 1 5. Monthly Taxable Income $3,352.41 - 6. Deductions Method 7. Deduction Amount $416.67 $416.67 8. Exem tion Amount $266.67 $266.67 9. Income MINUS Deductions and Exemp tions $2,669.07 -$683.34 10. Tax on Income $389.35 11. Child Tax Credit - 12. Manual Adjustments to Taxes - 13. Federal Income Taxes $389.35 13 a. Earned Income Credit - 14. State Income Taxes $105.94 15. FICA Payments $245.97 16. City Where Taxes Apply --Select-- 17. Local Income Taxes $32.15 TOTAL Taxes $773.41 SupportCak 2005 EXHIBIT "A" In the Court of Common Pleas of Cumberland County, Pennsylvania Spousal Support Calculation Rule 19"1#3.16 IPACSES FORMAT) Plaintiff Name: Pamela S. Roney Defendant Name: Curtis A. Roney Docket Number: 05-3412 Civil PACSES Case Number: 586107501 Other State ID Number: 1. Obligor's Monthly Net Income $2,229.34 2. Less All Other Support - 3. Less Obligee's Monthly Net Income $901.00 4. Difference $1,328.34 5. Less Child Support Obligation for Current Case - 6. Difference $1,328.34 7. Multiply b 30%or40% 40.00% 8. Income Available for Spousal Support $531.34 9. Adjustment for Other Expenses - 10 . AMOUNT OF MONTHLY SPOUSAL SUPPORT OR APL $531.34 Prepared b : Date: 9/27/2005 SupportCalc 2005 EXHIBIT "B" o ?r - o _ ?„? films IC_J c,a n co < CURTIS A. RONEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent: CUMBERLAND COUNTY, PENNSYLVANIA V. : DOMESTIC RELATIONS SECTION PAMELA S. RONEY, : PACSES NO. 586107501 Defendant/Petitioner: DOCKET NO. 05-3412 CIVIL INDEX OF EXHIBITS Plaintiff's Exhibit No. 1 - Income and expense statement Plaintiff's Exhibit No. 2 - Marital assets Plaintiff's Exhibit No. 3 - Savings bonds calculations Plaintiff's Exhibit No. 4 - Settlement statement Defendant's Exhibit No. 1 - Income and expense statement In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION 13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013 Phone: (717) 240-6225 JULY 19, 2005 Fax: (717) 240-6248 •Plaintiff Name: PAMELA S. RONEY Defendant Name: CURTIS A. RONEY Docket Number: 00544 S 2005 PACSES Case Number: 459107475 Other State ID Number: Please note: All correspondence must include the PACSES Case Number. Income and Expense Statement THIS FORM MUST BE FILLED OUT (If you are self-employed or if you are salaried by a business of which you are owner in whole or part, you must also fill out the Supplemental Income Statement which appears on page two of this income and expense statement.) y? INCOME STATEMENT OF C U R7'% 5 A.• 'KO iU" Section I: Income and Insurance INCOME: Employer 1V VMUt UJWA i4JIY' 1 Address ?I d? C:lBILPf1/IC Typeof Work CDRAFLY/sw/ Payroll No. Gfq' y Gross Pay per Pay Period S Es" l'^V I? Itemized Payroll Deductions: Pay Period (wkly., bi-wkly., etc.) g? Federal Withholding $1G A. Gl Social Security 4- $rDD Cf7 Local Wage Tax $ 3 ??! State Income Tax $ Vo, 5 Retirement $ At,, S6 Savings Bonds $ Credit Union $ Life Insurance $ Health Insurance $ 4S.7 Uncwi ., ' r^, $ X23 $ Other Deductions (specify) ^ (Jn?o-r DJs $ /?•38' $ Net Pay per Pay Period $ 64 R , o $ OTHER (Fill in Appropriate C olumn) Own ershi p INCOME WEEK MONTH YEAR PROPERTY Interest $ $ $ P.2? 10 OWNED DESCRIPTION VALUE H W J Dividends t7. Dp C`r f Pension Checking Accounts " 7 ^ , •"" f $ 8 Annuity Savings E Bowo5 /( ;t ? Social Securi " Rents Credit Union Royalties Stocks/Bonds kw A,+ ?9:.. a 3 ? Expense Account Tm ' . Z Gifts Real Estate 1400s.r c1 (0- Unemployment Other (?ecia 6 676 6 ? Workmen's Compensation . Other TOTAL $ Other TOTAL Is $ ?'" •? TOTAL INCOME IS J ,ea Wife; J=Joint PI Burr. Service Type M EXHISIT J 1 Form IN-008 Worker ID 21205 Income and Expense Statement PACSES Case Number 459107475 Coverage INSURANCE COMPANY POLICY H H W C HOSDital Bl C rFr6v+ 10,4 arc ross ue Other 6 ? V7, Medical Shi ld 5A_ M C e Blue Other Health/Accident Disability Income Dental Other * H=Husband; W=Wife; C=Child Section H: Supplemental Income Statement a. This form is to be filled out by a person (1) who operates a business or practices a profession, or (2) who is a member of a partnership or joint venture, or (3) who is a shareholder in and is salaried by a closed corporation or similar entity. b. Attach to this statement a copy of the following documents relating to the partnership, joint venture, business, profession, corporation or similar entity: (1) the most recent Federal Income Tax Return, and (2) the most recent Profit and Loss Statement c• Name of business: Address and telephone number: d. Nature of business (check one) (1) partnership E (2) joint venture (3) profession (4) closed corporation (5) other e. Name of accountant, controller or other person in charge of financial records: f. Annual income from business: (1) How often is income received? (2) Gross income per pay period: (3) (4) Net income per pay period: Specified deductions, if any: Page 2 of 3 Form IN-008 Service Type M Worker ID 27.205 Income and Expense Statement PACSES Case Number 459107475 Section III: Expenses Instructions: Only show extraordinary expenses in this section unless you filled out Section II on page two. The categories in BOLD FONT are especially important for calculating child support. If you are requesting Spousal Support/APL or if you assert your case cannot be determined according to the guideline grids or formula, this section must be fully completed. (Fill in Appropriate Column) EXPENSES WEEK MONTH YEAR Home Mortgage/Rent $ $ $ Maintenance Utilities Electric $ $ $ Gas Oil c a tr? Telephone Water Sewer '77 4-mo Employment Public Transport. $ $ $ Lunch Taxes Real estate $ $ $ 'lap O Personal Property Insurance Homeowner's $ $ $ T?0.00 Automobile Life Accident Health Other Automobile Payments $ $ $ Fuel a h&Z as Repairs O".00 Medical Doctor $ $ $ a Dentist Orthodontist Hospital Medicine peci needs (glasses, bradevices, ortho dic ces EXPENSES (Fill in Appropriate Column) (continued) WEEK MONTH YEAR Education Private School $ $ $ Parochial School College Religious Personal Clothing $ $ $ Food 7o, Farber/ Hairdresser /5. c-o OU Credit Payments Credit Card Charge Memberships Loans Credit Union $ $ $ Miscellaneous Household Help $ $ $ Child care Papers/books Ma azines Entertainment Pay TV Vacation Gifts Legal fees Charitable -Contributions Other Child . unnort Alimony Pa ents Other I s $ $ 05. D L- I Total WEEK MONTH YEAR Ex es• $ $ $/k, "V-.- I verify that the statements made in this Income and Expense Statement are true and correct. I understand that false statements herein are subject to the criminal penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Dat Plaintiff or Defendant t Service Type M Page 3 of 3 Form IN-008 Worker ID 21205 JOINTLY OWNED ASSETS Marital Assets: Furniture, household goods unilaterally taken by Pamela S. Roney at separation (2. 2004 Dodge Ram 2500 Truck originally title jointly; Curtis transferred his interest to Pamela upon her request) PLAINTIFF'S EXHIBIT CURTIS A. RONEY INDIVIDUALLY OWNED ASSETS Marital Assets: 1. Increase of value of U.S. Savings Bonds $135.43 2. Increase (nominal, if any) in value of Curtis' residence real estate (800 West Keller Street, Mechanicsburg) 3. Increase (nominal, if any) in value of Curtis' unimproved real estate sold on May 25, 2005 4. Interest @1% earned on net proceeds of sale ($103,767.79) of Curtis' unimproved real estate from May 25, 2005 to July 6, 2005 $116.56 5. Approximate increase in value of Curtis' Retirement Fund in Cumberland County Employee's Retirement Fund As of 7/6/05: $64,941.83 As of 12/3/03: 53.877.30 $11,064.53 6. Increase (nominal, if any) of value of Brokerage Account with Citizens Bank $ 1999 Harley-Davidson motorcycle (approximate value based on difference paid on trade-in of 1998 Harley- Davidson motorcycle) $921.00 Increase in value of 65 shares of MetLife, Inc. Common Stock Value as of 12/3/03: $2,148.25 Value as of 7/6/05: $3.034.20 $885.95 CURTIS A. RONEY Non-Marital (Pre-Marital) Assets: Curtis' residence at 800 West Keller Street, Mechanicsburg, PA, acquired in 1995 $ 2. Curtis' unimproved real estate acquired in 1995, but sold on May 25, 2005 - r $103,769.79 3. Curtis' retirement fund from Cumberland County Employee's Retirement Fund $53,877.30 4. Furniture, household goods $ 5. Brokerage Account at Citizens Bank $24,568.82 6. U.S. Series "E" Savings Bonds $16,261.41 7. 1995 F-150 Ford Truck $ PAMELA S. RONEY INDIVIDUALLY OWNED ASSETS Marital Assets: 1. 2004 Dodge Ram 2500 Truck (purchased: 6111104) Sale/Purchase Price: Trade-in allowance of 2003 Ford Explorer: $20,500 Cash paid by Curtis A. Roney: 4,500 2. Sunline Camper Sea-Doo Jet Ski and Trailer $32,275.00 Curtis A. Roney paid $4,000 PAMELA S. RONEY Non-Marital (Pre-Marital) Assets: 2003 Ford Explorer Truck (purchased 8/7/03) $30,012.40 2. 1995 Pontiac Firebird Automobile SAVINGS BONDS CALCULATIONS Serial Number Q1680877305E Q1680877328E Q1680877321E Q1699646381E Q1843407943E Q1871785518E Q1957692914E Q2095136756E Q2138244175E Q2143544407E Q2149574774E Q2150300137E Q2154903160E Q2159711258E Q2164656564E Q2164750133E Q2169393497E Q2173039356E Q2182386109E Q2183659174E Q2194110398E L676075225E L676075223E L676075226E Value Issue Date Series Denom. 12/3/03 7/6/05 05/1959 E $25.00 $191.53 $191.53 06/1959 E 187.88 187.88 06/1959 E 187.88 187.88 07/1959 E 187.88 187.88 11/1960 E 196.79 196.79 02/1961 E 199.07 199.07 11/1962 E 214.33 214.33 06/1965 E 176.59 185.97 08/1965 E 173.19 180.42 09/1965 E 174.08 181.35 10/1965 E 171.92 181.35 11/1965 E 171.92 178.40 11/1965 E 171.92 178.40 12/1965 E 128.12 128.12 01/1966 E 128.13 128.13 01/1966 E 128.13 128.13 02/1966 E 128.13 128.13 03/1966 E 121.94 121.84 04/1966 E 121.94 121.94 05/1966 E 122.02 122.02 06/1966 E 123.28 123.28 06/1966 E 50.00 246.56 246.56 06/1966 E 50.00 246.56 246.56 06/1966 E 50.00 246.56 246.56 Increase -0- -0- -0- -0- -0- -0- -0- $ 9.38 $ 7.23 $ 7.27 $ 9.43 $ 6.48 $ 6.48 -0- -0- -0- -0- -0- -0- -0- -0- -0- -0- -0- Value Serial Number Issue Date Series Denom. 12/3/03 7/6/05 Increase L676075222E 06/1966 E $50.00 246.56 246.56 -0- L676075227E 06/1966 E 50.00 246.56 246.56 -0- L676075228E 06/1966 E 50.00 246.56 246.56 -0- L676075229E 06/1966 E 50.00 246.56 246.56 -0- L676075230E 06/1966 E 50.00 246.56 246.56 -0- Q2195665068E 07/1966 E 25.00 123.27 123.27 -0- Q2201149948E 08/1966 E 25.00 123.27 123.27 -0- Q2210074760E 09/1966 E 25.00 123.27 123.27 -0- Q2218759866E 10/1966 E 25.00 123.27 123.27 -0- Q2223429875E 11/1966 E 25.00 124.46 124.46 -0- Q2219154848E 12/1966 E 125.85 125.85 -0- Q2231375130E 12/1966 E 125.85 125.85 -0- Q2215742934E 12/1966 E 125.85 125.85 -0- Q2231625225E 01/1967 E 125.86 125.86 -0- Q2242930741E 02/1967 E 125.86 125.86 -0- Q2249356257E 03/1967 E 125.86 125.86 -0- Q2254634676E 04/1967 E 125.86 125.86 -0- Q2260370347E 05/1967 E 127.06 127.06 -0- Q2261494795E 06/1967 E 128.46 128.46 -0- Q2268644001E 07/1967 E 128.45 128.45 -0- Q2279570662E 08/1967 E 128.45 128.45 -0- Q2283857231E 09/1967 E 128.45 128.45 -0- Q2290565893E 10/1967 E 128.45 128.45 -0- Q2297556788E 11/1967 E 129.70 129.70 -0- Q2306350822E 12/1967 E 13138 131.38 -0- Value Serial Number Issue Date Series Denom. 12/3/03 7/6/05 Increase Q2306366930E 12/1967 E $25.00 131.38 131.38 -0- Q2298749859E 12/1967 E 131.38 131.38 -0- Q2311795544E 01/1968 E 131.28 131.28 -0- Q2322245836E 02/1968 E 131.28 131.28 -0- Q2326860199E 03/1968 E 131.28 131.28 -0- Q2332629255E 04/1968 E 131.28 131.28 -0- Q2334485111E 05/1968 E 132.57 132.57 -0- Q2341546518E 06/1968 E 134.16 134.16 -0- Q2347842651E 07/1968 E 134.14 134.14 -0- Q2359995935E 08/1968 E 134.14 134.14 -0- Q2367477032E 09/1968 E 134.14 134.14 -0- Q2368880856E 10/1968 E 134.14 134.14 -0- Q11400690 10/1968 E 134.14 134.14 -0- Q12190288 11/1968 E 135.44 135.44 -0- Q13876875 11/1968 E 135.44 135.44 -0- Q2375501914E 11/1968 E 135.44 135.44 -0- Q2382234897E 11/1968 E 135.44 135.44 -0- Q13885470 12/1968 E 137.28 137.28 -0- Q2382253695E 12/1968 E 137.28 137.28 -0- Q13887048 01/1969 E 137.27 137.27 -0- Q2393863320E 01/1969 E 137.27 137.27 -0- Q2400791342E 02/1969 E 137.27 137.27 -0- Q14349594 02/1969 E 137.27 137.27 -0- Q16129107 03/1969 E 137.27 137.27 -0- Q2407662732E 03/1969 E 137.27 137.27 -0- Value Serial Number Issue Date Series Denom. 12/3/03 7/6/05 Increase Q16741681 04/1969 E $25.00 137.27 137.27 -0- Q2414878356E 04/1969 E 137.27 137.27 -0- Q2416511966E 05/1969 E 138.60 138.60 -0- Q17310244 05/1969 E 138.60 138.60 -0- Q17381767 06/1969 E 133.42 133.42 -0- Q2421889554E 06/1969 E 133.42 133.42 -0- Q17389306 07/1969 E 134.71 134.71 -0- Q2432303132E 07/1969 E 134.71 134.71 -0- Q17390881 08/1969 E 135.01 135.01 -0- Q2432313616E 08/1969 E 135.01 135.01 -0- Q18767458 09/1969 E 135.02 135.02 -0- Q2433683013E 09/1969 E 135.02 135.02 -0- Q20710117 10/1969 E 135.02 135.02 -0- Q2445578006E 10/1969 E 135.02 135.02 -0- Q20711716 11/1969 E 135.02 135.02 -0- Q21548273 11/1969 E 135.02 135.02 -0- Q2458309775E 11/1969 E 135.02 135.02 -0- Q2458322005E 11/1969 E 135.02 135.02 -0- Q2455397065E 12/1969 E 135.72 135.72 -0- Q21558820 12/1969 E 135.72 135.72 -0- Q2457222724E 12/1969 E 135.72 135.72 -0- Q22245349 01/1970 E 137.00 137.00 -0- Q22381830 02/1970 E 137.34 137.34 -0- Q23895203 03/1970 E 137.36 137.36 -0- Q2488524097E 04/1970 E 25.00 137.36 137.36 -0- Value Serial Number Issue Date Series Denom. 12/3/03 7/6/05 Increase Q24132381 04/1970 E $25.00 137.36 137.36 -0- C2042114626E 05/1977 E 100.00 485.44 515.16 $29.72 C2042114625E 05/1977 E 100.00 485.44 515.16 $29.72 C2044569278E 05/1977 E 100.00 485.44 515.16 $29.72 TOTAL INCREASE: 35.4$ OMB NO. 2502-0265 IF A. B. TYPE OF LOAN: DEPARTMENT OF HOUSING & URBAN DEVELOPMENT U S 1.?FHA 2.[]FmHA 3.?CONV. UNINS. 4.EJVA 5. []CONV. INS. . . SETTLEMENT STATEMENT 6. FILE NUMBER: CAR154-05 7. LOAN NUMBER: 8. MORTGAGE INS CASE NUMBER: C. NOTE: This form is furnished to give you a statement of actual settlement costs. Amounts paid to and by the settlement agent are shown. Items marked "(POC)" were paid outside the closing; they are shown here for informational purposes and are not included in the totals. 1.0 3/98 (CAR154-05.PFDICAR1 5 4-0 512) D. NAME AND ADDRESS OF BUYER: OLIVIA S. CARPENTER and TIMOTHY E. CARPENTER 545 E. SIODONSBURG ROAD MECHANICSBURG, PA 17055 E. NAME AND ADDRESS OF SELLER: CURTIS A. RONEY 800 WEST KELLER STREET MECHANICSBURG, PA 17055 F. NAME AND ADDRESS OF LENDER: CASH G. PROPERTY LOCATION: LOTS 59, 60 & 80 POINT COMFORT MECHANICSBURG, PA 17055 CUMBERLAND County, Pennsylvania H. SETTLEMENT AGENT: 25-1619811 TRI-COUNTY ABSTRACT SERVICE PLACE OF SETTLEMENT 3414 CHESTNUT STREET CAMP HILL, PA 17011 1. SETTLEMENT DATE: May 25, 2005 J. SUMMARY OF BUYER'S TRANSACTION K. SUMMARY OF SELLER'S TRANSACTION 100. GROSS AMOUNT DUE FROM BUYER: 400. GROSS AMOUNT DUE TO SELLER:. 101. Contract Sales Price 112,000.00 401. Contract Sales Price 112,000.00 102. Personal Pro ert 402. Personal Property Settlement Charges to Buyer Line 1400 1,935.50 403. 104. 404. 105. 405. Adjustments For Items Paid B Seller in advance Adjustments For Items Paid B Seller in advance 106. City/Town Taxes 05/25/05 to 01/01/06 108.35 406. City/Town Taxes 05/25/05 to 01/01/06 108.35 107. Count Taxes to 407. Count Taxes to 108. SCHOOL TAX 05/25/05 to 07/01/05 43.44 408. SCHOOL TAX 05125/05 to 07101/05 43.44 109. 409. 110. 410. 111. 411. 112. 412. 120. GROSS AMOUNT DUE FROM BUYER 114,087.29 420. GROSS AMOUNT DUE TO SELLER 112,151.79 200. AMOUNTS PAID BY OR IN BEHALF OF BUYER: 500. REDUCTIONS IN AMOUNT DUE TO SELLER: 201. Deposit or earnest money 5,000.00 501. Excess Deposit See Instructions 202. Principal Amount of New Loan(s) 502. Settlement Charges to Seller Line 1400 8,384.00 203. Existing loans taken subject to 503. Existing loans taken subject to 204. 504. Payoff of first Mortgage 205. 505. Payoff of second Mortgage 206. 506. 207. 507. (Deposit disb. as proceeds) 208. 508. 209. 509. Adjustments For Items Unpaid B Seller Adjustments For Items Unpaid B Seller 210. Cit rrown Taxes to 510. City/Town Taxes to 211. Count Taxes to 511. Count Taxes to 212. SCHOOL TAX to 512. SCHOOL TAX to 213. 513. 214. 514. 215. 515. 216. 516. 217. 517. 218. 518. 219. 519. 220. TOTAL PAID BY/FOR BUYER 5,000.00 520. TOTAL REDUCTION AMOUNT DUE SELLER 8,384.00 300. CASH AT SETTLEMENT FROM/TO BUYER: 600. CASH AT SETTLEMENT TO/FROM SELLER: 301. Gross Amount Due From Buyer Line 120 114,087.29 601. Gross Amount Due To Seller Line 420 112,151.79 302. Less Amount Paid By/For Buyer (Line 220) ( 5,000.00) 602. Less Reductions Due Seller (Line 520) ( 8,384.00 303. CASH ( X FROM) ( TO) BUYER 109,087.29 603. CASH ( X TO) ( FROM) SELLER 103,767.79 The undersigned hereby acknowledge receipt of a completed copy of pages 1&2 of this statement & any attachments referred to herein. I HAVE CAREFULLY REVIEWED THE HUD-1 SETTLEMENT STATEMENT AND TO THE BEST OF MY KNOWLEDGE AND BELIEF, IT IS A TRUE AND ACCURATE STATEMENT OF ALL RECEIPTS AND DISBURSEMENTS MADE ON MY ACCOUNT OR BY ME IN THIS TRANSACTION. I FURTHER CERTIFY THAT I HAVE RECEIVEDA COPY OF THE HUD-1 SETTLEMENT STATEMENT. Buyer (2'a _A?4:J w? o.n XJ.? Seller C A? ?LQ.LL OLIIVIIA S. CARPENTER ?y ?r??yy ?^ CURTIS A. RONE TIMOTHY E. C ENTE7J- TO THE BEST OF MY K LEDGE, THE HUD-1 SETTLEM NT ST TEMENT WHICH I HAVE PREPARED IS A TRUE AND ACCURATE ACCOUNT OF THE FUNDS WHICH WERE VED AND AVE B ..D BY THE UNDERSIGNED AS PART OF THE SETTLEMENT OF THIS TRANSACTION. ETTLEMENT OFFICER Settlement Agent WARNING: IT IS A CRIME TO KNOWINGLY MAKE FALSE ST EMENTS TO THE UNITED STATES ON THIS OR ANY SIMILAR FORM. PENALTIES UPON CONVICTION CAN INCLUDE A FINE AND IMPRISONMENT. FOR DETAILS SEE: TITLE 18 U.S. CODE SECTION 1001 & SECTION 1010. aa Page 2 L. SETTLEMENT CHARGES 700. TOTAL COMMISSION Based on Price $ % 7,700.00 PAID FROM PAID FROM Division of Commission line 700 as Follows: BUYER'S SELLER'S 701. $•7,000.00 to ERA-NRT, INC. FUNDS AT FUNDS AT 702. $ 700.00 to ERA NRT, INC. SETTLEMENT SETTLEMENT 703. Commission Paid at Settlement 700.00 7,000.00 704. TRANSACTION FEE to ERA-NRT, INC. 125.00 $00. ITEMS PAYABLE IN CONNECTION WITH LOAN 801. Loan Origination Fee % to 802. Loan Discount % to 803. Appraisal Fee to 804. Credit Report to 805. Lender's Inspection Fee to 806. Mortgage Ins. App. Fee to 807. Assumption Fee to 808. 809. 810. all. 900. ITEMS REQUIRED BY LENDER TO BE PAID IN ADVANCE 901. Interest From to @ $ /day ( days %) 902. MIP Totlns. for LifeOfLoan for months to 903. Hazard Insurance Premium for 1.0 ears to 904. 905. 1000. RESERVES DEPOSITED WITH LENDER 1001. Hazard Insurance months $ per month 1002. Mortgage Insurance months $ per month 1003. Cit frown Taxes months $ per month 1004. Count Taxes months $ per month 1005. SCHOOL TAX months @ $ per month 1006. months $ per month 1007. months @ $ per month 1008. AGGREGATE ESCROW ADJUSTMEI months $ per month 1100. TITLE CHARGES 1101. Settlement or Closing Fee to 1102. CLOSING PROTECTION LETTER to FIRST AMERICAN TITLE INSURANCE COMPANY 1103. Title Examination to 1104. Title Insurance Binder to 1105. Document Preparation to TRI-COUNTY ABSTRACT SERVICE DEEDS 115.00 1106. Notary Fees to CASH 6.00 1107. Attorney's Fees to includes above item numbers: 1108. Title Insurance to TRI-COUNTY ABSTRACT SERVICE AGENT includes above item numbers: 1109. Lender's Coverage $ 1110. Owner's Coverage $ 112,000.00 1111. ENDORSEMENTS 1112. 1113. 1200. GOVERNMENT RECORDING AND TRANSFER CHARGES 1201. Recording Fees: Deed $ 115.50; Mortgage $ Releases $ 3 @ $38.50 115.50 1202. City/County Tax/Stamps: Deed 1,120.00; Mortgage 1,120.00 1203. State Tax/Stamps: Revenue Stamps 1,120.00; Mortgage 1,120.00 1204. 1205. OVERNIGHT/COURIER FEES 1300. ADDITIONAL SETTLEMENT CHARGES 1301. Survey to 1302. Pest Inspection to 1303. TAX CERTIFICATION FEE to MARY A. MURRAY, TAX COLLECTOR 18.00 1304. 1305. 1400. TOTAL SETTLEMENT CHARGES Enter on Lines 103, Section J and 502, Section K 1,935.50 8,384.00 ey signing papa i of mn vatemem, me signefones erxnomegge reoepf of a oompiefec copy of page 2 of this t" ge sla enl. SETTLEMENT OFFICER Settlement Agent Certified to be a true copy. (CAR15445I CAR154-0512) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION CURTIS A. RONEY, NO. 2005-3412 Civil Term Plaintiff /Respondent PACKS NO. 586107501 V. CIVIL ACTION-LAW PAMELA S. RONEY, Defendant/ Petitioner IN DIVORCE INCOME AND EXPENSE STATEMENT OF PAMELA S. RONEY HEARING DATE: 9/27/2005 I verify that the facts set forth in the following Income and Expenses Form, including all attachments thereto, are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. DATED /' 2?2 -0S "" ,, PAMELA S. RONEY 1. 1- vc? W( PART I. INCOME A. EMPLOYMENT INFORMATION: Employer: N/A DISABLED AND RECEIVING SSD B. INCOME: DESCRIPTION MONTHLY YEARLY Gross Income (Social Security Disability) $901.00 $10,812.00 Medicare Health Insurance Costs None None Net $901.00 $10,812.00 C. OTHER INCOME: DESCRIPTION WEEKLY MONTHLY YEARLY Interest Dividends Pensions Annuities Rents Royalties Expense Account Gifts Unemployment Compensation Workman's Compensation Income Tax Refunds Support or Alimony Commissions Tips TOTAL OTHER INCOME $0.00 $0.00 $0.00 -2- PART II. EXPENSES DESCRIPTION MONTHLY AMOUNT COMMENTS HOME EXPENSES: Rent $525.00 Was $900 through 9/30/05 First Mortgage Maintenance and Repairs Electric $45.00 Gas oil $100.00 Was $119 for gas Telephone $25.00 Water $18.00 Sewer Trash EMPLOYMENT Public Transportation Lunches Other Employment Expenses TAXES: Real Estate Taxes Personal Property Taxes Income Taxes Not Withheld Per Capita/ Occupation Taxes .3- DESCRIPTION MONTHLY AMOUNT COMMENTS INSURANCE: Homeowners Insurance Automobile Insurance $110.00 Life Insurance Accident Insurance Health Insurance Otherlnsurance AUTOMOBILE EXPENSES: Payments Fuel $70.00 Maintenance and Repair $25.00 License and Registration $20.00 MEDICAL EXPENSES NOT REIMBURSED BY INSURANCE: Doctor $95.00 Dr. $30/Mo Counseling $30/BW Optical Dental Orthodontic Hospital Medicine $100.00 Special Needs/Therapy, Etc. 4- DESCRIPTION MONTHLY AMOUNT COMMENTS EDUCATIONAL EXPENSES: Private School Parochial School College/Vocational Religious Training or Education Books/Fees and Supplies Other Educational Expenses PERSONAL EXPENSES: Clothing $75.00 Food $300.00 Barber and Hair Dresser $40.00 Memberships Other Personal Expenses CREDIT CARDS AND LOANS: ATB:T Universal $224.00 $10,794 balance GE Money Bank $188.26 $9,000 balance Chase Platinum MC $200.00 $11,000 balance MISCELLANEOUS EXPENSES: Household Help Child Care Newspapers/Magazines/Books $20.00 Entertainment TBD TBD based on affordability Pay TV $36.00 - 5 - DESCRIPTION MONTHLY AMOUNT COMMENTS Vacations TBD TBD based on affordability Gifts TBD TBD based on affordability Legal Fees $250.00 $3000 retainer fee paid Charitable Contributions Other Child Support (not this action) Other Spousal Support or Alimony (not this action) TOTAL EXPENSES $2,466.26 -6- PART III. PROPERTY OWNED PROPERTY OWNED OWNERSHIP TYPE DESCRIPTION VALUE H W JT Checking Member's 1" Minimal - varies x Savings Member's 1" 25.00 x Credit Union Stocks/bonds Real Estate Other vehicles 20,000.00 x TOTAL 20,025.00 PART IV. INSURANCE INSURANCE INFORMATION COVERAGE TYPE COMPANY POLICY NO. Hospital Medicare 089489893 x Medical H's Highmark PPO ZAR10502430900 1 x x Health Accident Disability Income Dental H's Delta Dental TBD x x Vision Other-Specify *H=Husband; W=Wife; J=Joint; C=Child -7- PART V. SUPPLEMENTAL INCOME STATEMENT [ f ] CHECK HERE IF NOT APPLICABLE (a) This form is to be filled out by a person: (1) Who operates a business or practices a profession, or (2) Who is a member of a partnership or joint venture, or (3) Who is a shareholder in and is salaried by a closed corporation or similar entity. (b) Attach to this statement a copy of the following documents relating to the partnership, joint venture, business, profession, corporation or Similar entity (check block to indicate the document is attached): (1) The most recent Federal Income Tax Return. [ ] attached (2) The most recent Profit and Loss Statement. [ ] attached (c) (d) (e) Name of Business: Business Address: Business Telephone: Nature of Business (check one) [ ] 1. Sole Proprietorship [] 2. Partnership [ ] 3. Joint Venture [ ] 4. Professional [ ] 5. Corporation [] 6. Other Name of accountant, controller or other person in charge of financial records: (f) Business Income: 1. Annual income from business: 2. How often is income received: 3. Gross income per pay period: 4. Net income per pay period: 5. Specify deductions, if any: i C- < T r -' Tii I .n c.? ?-y r.J iJ co { SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-03412 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RONEY CURTIS A VS RONEY PAMELA S R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT RONEY PAMELA S but was unable to locate Her in his bailiwick He therefore returns the COMPLAINT - DIVORCE , the within named DEFENDANT RONEY PAMELA S NOT FOUND , as to 800 WEST KELLER STREET MECHANICSBURG, PA 17055 DEFENDANT IS BELIEVED TO BE LIVING AT 243 MINE BANK ROAD WELLSVILLE. Sheriff's Costs: So answerer--- Docketing 18.00 Service 8.00 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 41.00 SNELBAKER BRENNEMAN 08/24/2005 Sworn and subscribed to before me this day of U G ' A.D. Pr ,MhonotaV SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2005-03412 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND RONEY CURTIS A VS RONEY PAMELA S R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT RONEY PAMELA S but was unable to locate Her deputized the sheriff of YORK serve the within COMPLAINT - DIVORCE to wit: He therefore County, Pennsylvania, to On August 24th , 2005 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing Out of County Surcharge Dep York County Postage in his bailiwick so ansrw-eF , 6.00 f 9.00 10.00 R. Thomas Kline 46.78 Sheriff of Cumberland County .74 72.52 08/24/2005 SNELBAKER BRENNEMAN Sworn and subscribed to before me this - day of aw "tKt OvV V A . D . ??°°r , P on ary COUNTY OF YORK OFFICE OF THE SHERIFF 45 N. GEORGE ST., YORK, PA 17401 J4?AD _A00 '?U? qr. SHERIFF SERVICE NSTIN)CTIONS PROCESS RECEIPT and AFFIDAVIT OF RETURN K"S IR TYPE OWY LW 1 THRU 12 00 NOT V TACH ANY WOWS 1 PLAINTIFF/S/ 2. COURT NUMBER Curtis A. Roney 05- 4. TYPE OF WRIT OR COMPLAINT 3. DEFENDANT/S/ Pamela S. Roney Notice and Complaint p Divorce Pati Linn fnr SnPnial Rol l icf SERVE N~t, Ul INUIVIUUAL, UUMYANT, WAI`U"l I U T1, UN Ut JumlYI WN V? 1* PMPIA R_ Rnngr L(Y/ 77f" SL 6. ADDRESS [STREET OR RFO WITH B NUMBER, APT NO CITY, BORO TWP, At AT ^"? Mine R k R-?-- 'T^ •,T ?cz y 7. INDICATE SERVICE. ID PERSONAL U PERSON IN CHARGE DEPUTIZE U CET?A?WXwr" r NOW July 15, 20 1, SHERIFF OF AW-661dN York COUNTY to execute thi§,.M to law. This deputization being made at the request and risk of the plaintiff ;'` 6. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WALL ASSIST IN EXPEDITING SERVICE. 4 CLASS MAIL U POSTED U OTHER PA, do hereby deputize the sheriff of ndmake return yW_oo-accordmg Ctliftberlaad C?00t7fU AoVq(lce `F'ee i'eaee whit retumia at sWifi ice to i0 mberland Oa3nty Sheriff. Ttlalk you. NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN -Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without Babllity on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriffs sale thereof. 9. TYPE NAME and ADDRESS of ATTORNEY / ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER 11 DATE FILED ,Richard C 15ne)bc4)er- 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must completed it notice is to be mailedt, _ I, _ f" . . A n IUI i a C^FIVED 115 E?vp 4oN rin 13. I acknowledge receipt of the writ 114. D?E Ri?(2J' or complaint nt as as indicated above. 16. HOW SERVED: PERSONAL ( ) RESIDENCE( ) POSTED( ) POE ( ) SHERIFF'S OFFICE ( ) OTHER ( ) SEE REMARKS BELOW 17. I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, etc named above. (See remarks below.) 1£ NAME AND TITLE OF INDIVIDUAL SERVED / LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 1 19. Date of Service 1 20 Time of Service 21. ATTEMPTSI Date I Time I Miles I Int. I Dare I Time I Miles I Int.. I Dale I Time I Miles I Int. 1 Date I Time, I Miles I Int. I Date I Time I Miles I Int. 1 Date I Time I Miles I Inl 22. REMARKS' 23. Advance Costs 124- Service Costs 1 25 26. Syb Total 129. Pound 1 30 Notary 131 . Surchg. 132. Tot. Costsf 33 n SERVICE CALL. (717) 771-9601 Cart 1 36 M9eage/Postage/Not 41. AFFIRMED and subscribed to before me this / N I 4 q day of A" I1CdNiRP`I Crr MELISSA I t4 ovary IBBAT& MELISSA 1 rit Ci!r2 i`tY c _.. pr1 -0, 2006 [O ?J'Ord? I / Costs 40. Costs Due or Refund 44. Signature of 45. DATE Dep. Sheriff 46. Signature of York 47 DATE County Sheriff / ? 17TLL1AN ii EOSE,SHEP,I 48 Signature of Foreign 49 DATE Count' Sheriff CURTIS A. RONEY, Plaintiff V. PAMELA S. RONEY, Defendant c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 053y/a CIVIL TERM CIVIL ACTION - LAW IN DIVORCE NOTICE 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 theZourt. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the court. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013-3302 (717) 249-3166 LAW OFFICES SNELBAKER & BRENNEMAN, P.C. SNELBAKER & BRENNEMAN, P.C. By' wa A orneys for Plaintiff t ? era r? s;r?'???8? CURTIS A. RONEY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. CIVIL TERM CIVIL ACTION -LAW PAMELA S. RONEY, Defendant IN DIVORCE COMPLAINT COUNT I - DIVORCE 1. The Plaintiff herein is CURTIS A. RONEY, an adult individual, who resides at 800 West Keller Street (Mechanicsburg, PA 17055) in the Township of Monroe, Cumberland County, Pennsylvania. 2. The Defendant herein is Pamela S. Roney, an adult individual, who resides at the same address as Petitioner: 800 West Keller Street (Mechanicsburg, PA 17055) in the Township of Monroe, Cumberland County, Pennsylvania. 3. The parties were lawfully joined in marriage on December 3, 2003, in the Borough of Newville, Cumberland County, Pennsylvania. 4. Both parties have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction since the date of the marriage as averred in paragraph 3 hereinabove. LAW OFFICES SNELBAKER & 6. Neither party is a member of the armed forces of the United States of America. BRENNEMAN. P.C. Y J Plaintiff avers as the alternative grounds upon which this action is based: a. That the marriage between the parties is irretrievably broken; or That the Defendant has offered such indignities to Plaintiff, the innocent and injured spouse, as to render his condition intolerable and life burdensome. 8. Plaintiff has been advised that counseling is available and that he may have the right to request the Court to require the parties to participate in counseling. Plaintiff waives such right as evidenced by his affidavit thereto attached hereto marked "Exhibit A". WHEREFORE, Plaintiff requests this Court to enter a decree of divorce, dismissing the Plaintiff from the bonds of matrimony heretofore existing between the parties. COUNT II - EQUITABLE DISTRIBUTION OF MARITAL PROPERTY 9. Paragraphs 1 through 8 hereinabove are incorporate herein by reference thereto. 10. The Parties have legally and beneficially acquired property during the course of this marriage. 11. The parties have not agreed to any equitable distribution of marital property. WHEREFORE, Plaintiff requests this Court to order equitable distribution of marital property. WHEREFORE, Plaintiff requests this Court to: A. Enter a decree of divorce, divorcing Plaintiff from the bonds of LAW OFFICES SNELBAKER & BRENNEMAN, P.C. matrimony; B. Order equitable distribution of marital property; and 2 C. order such other relief as this Court deems just and reasonable. SNELr ppMAN, P.C. By, WSnelb , Esquire i 44 West Main Street Mechanicsburg, PA 17055-0318 (717) 697-8528 Attorneys for Plaintiff Curtis A. Roney Date: July S , 2005 LAW OFFICES SNELBAKER & BRENNEMAN, F.C. 3 VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce 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. C,??, R- Curtis A. Roney Date: July 5 , 2005 LAW OFFICES SNELBAKER & SRENNEMAN. P.C. CURTIS A. RONEY, COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. CIVIL TERM CIVIL ACTION -LAW PAMELA S. RONEY, Defendant IN DIVORCE AFFIDAVIT Curtis A. Roney, being duly sworn according to law, deposes and says: 1. 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. 2. I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do NOT request that the court require my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unswom falsification to authorities. Curtis A. Roney LAW OFFICES SNELBAKER & 3RENNEMAN. P.C. Date: July ,5- , 2005 EXHIBIT A CURTIS A. RONEY, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA PAMELA S. RONEY, Defendant NO. 05- 3q/2- CIVIL TERM CIVIL ACTION - LAW IN DIVORCE ORDER OF COURT AND NOW, this day of 2005, upon consideration of Plaintiff's Petition for Special Relief, a Rule is issued upon Pamela S. Roney to show cause, if any she has, why Curtis A. Roney should not be granted exclusive possession of the home known as 800 West Keller Street„ Mechanicsburg, Pennsylvania. Said Rule is returnable at a hearing scheduled for the day of 2005, at o'clock . M. in Courtroom No. , Fourth Floor, Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, J LAW OFFICES SNELEAKER & BRENNEMAN. P.C. CURTIS A. RONEY, V. PAMELA S. RONEY, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PETITION FOR SPECIAL RELIEF AND NOW, comes Plaintiff-Petitioner, Curtis A. Roney, by his attorneys, Snelbaker & Brenneman, P.C., and respectfully represents as follows: Curtis A. Roney, the Petitioner herein, is an adult individual, who resides at 800 West Keller Street (Mechanicsburg, PA 17055) in the Township of Monroe, Cumberland County, Pennsylvania. 2. Pamela S. Roney, the Respondent herein, is an adult individual, who resides at the same address as Petitioner: 800 West Keller Street (Mechanicsburg, PA 17055) in the Township of Monroe, Cumberland County, Pennsylvania. 3. The parties are husband and wife, having been married at Newville, Pennsylvania on December 3, 2003. 4. No children were born of this marriage. 5. Petitioner is the sole owner of the premises in which the parties reside, having LAW OFFICES SNELBAKER & BRENNEMAN, P.C. acquired the same in 1995, by (a) decree awarding real estate from Estate of Mary Louise Roney, deceased (see Cumberland County Deed Book 119, Page 1087) as to an undivided one-half interest, and (b) deed from Sharon Roney Myers as to an undivided one-half interest (see Cumberland County Deed Book, 120, Page 778). 6. Under the law of Pennsylvania, said real estate is non-marital property. Petitioner has resided in said real estate all of his life, which pre-dates his ge to Respondent. 8. Commencing in the spring of 2005, Respondent began a persistent course of against Petitioner which has rendered his condition intolerable and life burdensome, ing, but not limited to, but highlighted by, falsely accusing Petitioner of using controlled substances, to wit: crack, cocaine, including making false reports to the Pennsylvania State Police (which she admitted to Petitioner) and to the authorities of the County of Cumberland, by Petitioner is employed as a corrections officer at the Cumberland County Prison. 9. As a result of such false reports, Petitioner was subjected to the humiliation of an investigation by his employer, including being subjected to a medical test, which test was negative. 10. Respondent has continued such false accusations against Petitioner in a threatening, taunting and belligerent manner in the parties' place of residence, and has made such false accusations to Petitioner's associates. 11. Petitioner perceives Respondent's persistent and increasing threatening and taunting conduct to be a means of provoking him to aggressive reactions, which is constantly disturbing, frustrating and the source of tension. 12. Petitioner's only practical defense to and relief from such course of conduct has LAW OFFICES SNELSAKER & BRENNEMAN, P.C. been to absent himself from his own home which is, in itself, disconcerting, disturbing, and something which he should not be required to do as the owner of the subject property. 13. Respondent's conduct is causing Petitioner mental anguish and physical reaction by substantial loss of weight. 14. Petitioner has given Respondent no cause for such conduct. 2 15. Petitioner has requested Respondent to remove herself from his property, which <Zespondent refused to do without being paid an unspecified amount of money. 16. Respondent has separate assets and income by which to maintain herself. 17. Petitioner has commenced an action in divorce immediately prior to the filing of this Petition. WHEREFORE, Petitioner respectfully requests your Honorable Court to issue an order giving Petitioner exclusive possession of his real estate and ordering Respondent to vacate the premises immediately. SNELBAKER & BRENNEMAN, P.C. By Date: July S , 2005 hard C, Snelbaker, Esquire Attorney I.D. No: 06355 44 West Main Street P.O. Box 318 Mechanicsburg, PA 17055-0318 (717) 697-8528 Attorneys for Plaintiff-Petitioner y 3 v ' ,i SF:, a LAW OFFICES SNELBAKER & BRENNEMAN, P.C. 3 VERIFICATION I verify that the statements made in the foregoing Petition for Special Relief 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. c? A. &ng-!4 Curtis A. Roney Date: July 6, 2005 s' 46ft,.. LAW OFFICES SNELBAKER & BRENNEMAN. P.C. rti',J ?-w !M Wi l 6 9- C(lr U51 ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania 586107501 Co./City/Dist. of CUMBERLAND 05-3412 CIVIL Date of Order/Notice 02/06/06 Case Number (See Addendum for case summary) RE: RONEY, CURTIS A. EmpfoyerANithholder's Federal FIN Number CUMBERLAND COUNTY C/O CONTROLLERS OFFICE 1 COURT HOUSE SQ CARLISLE PA 17013-3323 O Original Order/Notice O Amended Order/Notice O Terminate Order/Notice Employee/Obligor's Name (Last, First, MI) 206-36-3745 Employee/Obligor's Social Security Number 3915101526 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. $ 501.00 per month in current support $ o 00 per month in past-due support Arrears 12 weeks or greater? Oyes ® no $ 0.00 per month in current and past-due medical support $ o . oo per month for genetic test costs $ per month in other (specify) for a total of $ 501.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 115.62 per weekly pay period. $ 231.23 per biweekly pay period (every two weeks). $ 250. So per semimonthly pay period (twice a month). $ 501.00 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 OURT: I Date of Order: J. s ey Oler, Jr.,- Judge DRO: R.J. Shadday Form EN-028 Service Type M OMB No. 0 9)aot sa Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? Ifghecked you are required to provide a Copy of this form to your employee. If yoVr employee works in a state that is di erent from the state that issued this order, a copy must be provided to your employee even if the box is not checked. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3. Pagaateraateorwlmnotet,'.6 .? trIU date orr wages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2360031190 EMPLOYEE'S/OBLIGOR'S NAME: RONEY, CURTIS A. EMPLOYEE'S CASE IDENTIFIER: 3915101526 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 (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 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) 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 OMB No.'. 0970-0154 Form EN-028 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: RONEY, CURTIS A. PACSES Case Number 586107501 Plaintiff Name PAMELA S. RONEY Docket Attachment Amount 05-3412 CIVIL$ 501.00 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. 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. 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. Service Type M Addendum Form EN-028 OMB NO.: 0970-0154 Worker ID $IATT r ,.,.> O '?? ?? ? r. ?:?i Pig--. G? '1 ?_ ;,T `'r ii - . T TIS A. RONEY, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA 'AMELA S. RONEY, Defendant NO: 05-3412 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE NOTICE IF YOU WISH TO DENY ANY STATEMENTS SET FORTH IN THE ATTACHED AFFIDAVIT, YOU MUST FILE A COUNTER-AFFIDAVIT WITHIN TWENTY (20) DAYS AFTER THE ATTACHED AFFIDAVIT HAS BEEN SERVED UPON YOU OR THE STATEMENTS WILL BE ADMITTED. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on July 6, 2005 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA C.S. § 4904 relating to unsworn falsification to authorities. Date: July 2 6 , 2007 ,f Ah , a. a7U?.t.r Curtis A. Roney (Plaintiff) LAW OFFICES SNELSAKER & BRENNEMAN, P.C. CERTIFICATE OF SERVICE I hereby certify that I am this date serving a true and correct copy of the within Affidavit § 3301(d) of the Divorce Code upon the Attorney for Defendant by sending the same by -class mail, postage paid, addressed as follows: Diane G. Radcliff, Esquire 3448 Trindle Road Camp Hill, PA 17011 SNELBAKER & BRENNEMAN, P.C. By Keith O. Brenneman, Esquire 44 West Main Street P.O. Box 318 Mechanicsburg, PA 17055-0318 (717) 697-8528 (Attorneys for Plaintiff) July 30 , 2007 LAW OFFICES SNELBAKER & BRENNEMAN, P.C. M r? k r-- W x,- 25 t" T-li ? ? N 0 , In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION CURTIS A. RONEY, Plaintiff/Respondent VS. PAMELA S. RONEY, Defendant/Petitioner Docket Number: PACSES Case Number: Other State ID Number: PETITION FOR TERMINATION OF AN EXISTING ALIMONY PENDENTE LITE ORDER 05-3412-Civil 586107501 The Petition of CURTIS A. RONEY respectfully represents that on October 4, 2005, an Order of Court was entered for the benefit of PAMELA S. RONEY in the nature of alimony pendente lite. A true and correct copy of the order is attached to this petition. Roney v. Roney DRAFT PACSES Case Number: 586107501 2. Petitioner is entitled to termination of this Order because of the following reasons: a. The parties were married on December 3, 2003. b. The parties separated on July 6, 2005 by the Defendant/Petitioner leaving the marital home. C. Therefore, the actual duration of their marriage was nineteen (19) months. d. The subject Order for Alimony Pendente Lite was effective as of July 19, 2005. e. Plaintiff/Respondent has paid and otherwise faithfully observed the Order for Alimony Pendente Lite for more than two years, which exceeds the actual length of the parties' marriage. f. The Order should be terminated as allowed by Pa. R.C.P. 1910-16-5 (c). WHEREFORE, Petitioner requests that the Court terminate the existing order for Alimony Pendente Lite. Petitioner I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Petitioner Date: 2007 1 CURTIS A. RONEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent: CUMBERLAND COUNTY, PENNSYLVANIA V. : DOMESTIC RELATIONS SECTION PAMELA S. RONEY, : PACSES NO. 586107501 Defendant/Petitioner: DOCKET NO. 05-3412 CIVIL INTERIM ORDER OF COURT AND NOW, this day of - , 2005, upon -q &L consideration of the Support Master's Report and Recommendation, a copy of which is attached hereto as Exhibit "A", it is ordered and decreed as follows: A. The Husband shall pay to the Pennsylvania State Collection and Disbursement Unit as alimony pendente lite the sum of $501.00 per month. B. The Husband shall pay to the Pennsylvania State Collection and Disbursement Unit on arrearages the additional sum of $84.00 per month. C. The Husband shall provide health insurance coverage for the benefit of the Wife as is provided through his employer at a reasonable cost. D. The effective date of this order is July 19, 2005. The parties are hereby advised that they may file written exceptions to the Support Master's Report and Recommendation within ten (10) days of this order. Exceptions shall conform with the requirements of Rule 1910.12(f), Pa. R.C.P. If written exceptions are filed by any party, the other party may file exceptions within ten (10) days of the date of service of the original exceptions. If no exceptions are filed within ten (10) days of this interim order, this order shall then constitute a final order. By the Court, esley Oler, .,/ . Cc: Curtis A. Roney Pamela S. Roney Richard C. Snelbaker, Esquire Keith O. Brenneman, Esquire For the Plaintiff/Respondent Diane G. Radcliff, Esquire For the Defendant/Petitioner DRO CURTIS A. RONEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent: CUMBERLAND COUNTY, PENNSYLVANIA V. : DOMESTIC RELATIONS SECTION PAMELA S. RONEY, : PACSES NO. 586107501 Defendant/Petitioner: DOCKET NO. 05-3412 CIVIL SUPPORT MASTER'S REPORT AND RECOMMENDATION Following a hearing held before the undersigned Support Master on September 27, 2005 the following report and recommendation are made: FINDINGS OF FACT 1. The Plaintiff/Respondent is Curtis A. Roney, who resides at 800 West Keller Street, Mechanicsburg, Pennsylvania. Hereafter he will be referred to as "the Husband." 2. The Defendant/Petitioner is Pamela S. Roney, whose mailing address is P.O. Box 1344, Mechanicsburg, Pennsylvania. She will hereafter be referred to as "the Wife." 3. The parties were married on December 3, 2003 and separated on or about July 6, 2005. 4. On July 6, 2005 the Husband filed a complaint for divorce. 5. On July 19, 2005 the Wife filed a petition for alimony pendente lite. 6. The Wife is 51 years of age. 7. The Wife receives social security disability benefits of $901.00 per month. 8. The Wife suffers from fibromyalgia for which she takes prescribed pain medication on a daily basis. 9. The Wife suffers from migrane headaches one to two times per week. 10. The Wife suffers from a hiatal hernia and gastroesophageal reflux disease (GERD). 11. The Wife suffers from epicondylitis, a condition more commonly referred to as "tennis elbow." EXHIBIT "A" 12. The Wife has had bilateral carpel tunnel surgery and surgery for repair of a rotator cuff tear. 13. The Wife suffers from asthma. 14. The Wife suffers from depression and anxiety attacks. 15. The Wife was employed as a customer service representative for Blue Shield until 1996 when she filed a workers compensation claim. 16. The Wife received a $30,000.00 commutation settlement in 1997. 17. The Wife worked as a shelf-stocker for Home Depot for a minimal period of time in 1997. 18. The Wife has not been gainfully employed outside the home since 1997. 19. The Wife has received social security disability benefits since 1999. 20. The Wife has three previous marriages all ending in divorce. 21. Despite her various physical ailments the Wife owns and operates a jet ski most recently during the summer of 2005. 22. The Plaintiff's living expenses, exclusive of credit card payments, total approximately $1,600.00 per month.' 23. The Wife has no savings. 24. The Wife owns a car, a truck, a camper, and a jet ski. 25. The Husband is 59 years of age. 26. The Husband is employed as a corrections officer at the Cumberland County Prison. 27. The Husband has gross bi-weekly income of $1,484.00. 28. The Husband makes mandatory bi-weekly retirement contributions of $148.00. 29. The Husband pays bi-weekly union dues of $13.38. 30. The Husband pays $45.80 bi-weekly for health insurance coverage on both parties through his employer. i The Plaintiff has credit card expenses of $612.00 per month on an outstanding balance exceeding $30,000.00. 2 31. The Husband will file his 2005 federal income tax return as married/separate. 32. The Husband has annual income from interest and dividends totaling approximately $1,645.00. 33. The Husband has $117,500.00 in his personal checking account. 34. The Husband has savings bonds valued at $16,261.00. 35. The Husband has a brokerage account valued at $23,292.00. DISCUSSION In Clouse v. Clouse, 50 Cumberland L.J. 167, 170 (2001) the Honorable J. Wesley Oler discussed the law of Pennsylvania as it relates to the subject of alimony pendente lite wherein he stated: The determination of whether to award alimony pendente lite has traditionally been a matter within the sound discretion of the trial court. Litmans v. Litmans, 449 Pa. Superior Ct. 209, 222, 673 A.2d 382, 388 (1996) (citing Murphy y. Murphy, 410 Pa. Superior Ct. 146, 599 A.2d 647 (1991), appeal denied, 530 Pa. 633, 606 A.2d 902 (1992), cert. denied, 506 U.S. 868, 113 S.Ct. 196, 121 L.Ed. 2d 139 (1992)). APL is based on the need of one spouse to have the financial resources to pursue or defend a divorce action. Litmans, supra at 222, 763 A.2d at 388. The claimant must show that APL is needed to adequately preserve his or her rights in the litigation. Sutliff v. Sutliff, 326 Pa. Superior Ct. 496, 500, 474 A.2d 599, 600 (1984), overruled on other grounds, Rosen v. Rosen, 520 Pa. 19, 549 A.2d 561 (1988). In this regard, the Pennsylvania Superior Court has stated that "a spouse seeking alimony pendente lite who has sufficient assets to meet the needs of the pending litigation and who is equally situated with the other spouse to maintain or defend the action, will not be awarded alimony pendente lite." Powers v. Powers, 419 Pa. Superior Ct. 464, 467, 615 A.2d 459, 460 (1992). In adjudicating a claim for alimony pendente lite, a court should consider the following factors: "the ability of the other party to pay; the separate estate and income of the petitioning party; and the character, situation, and surroundings of the parties." Litmans, supra at 224, 673 A.2d at 389. Once entitlement to an award of alimony pendente lite is established, the calculation of the amount of the award is made pursuant to the support guidelines. Little v. Little, 47 Cumberland L.J. 131 (1998). The evidence as presented in this case clearly establishes both a need of the Wife for alimony pendente lite and the ability of the Husband to pay it. Her income from social security disability is considerably less than her reasonable living expenses and she has no liquid assets to pursue her economic claims in the divorce action. She suffers from a variety of debilitating ailments and has not been gainfully employed since 1997. Her condition predated the marriage. The Husband has both income and income-generating assets. He is gainfully employed as a corrections officer with gross bi-weekly income of $1,484.00, or $3,215.00 per month. He has annual interest and dividend income totaling $1,645.00, or an average of $137.00 per month.2 His total gross monthly income for support purposes is $3,352.00. After deductions for taxes, mandatory retirement, and union dues are taken from his gross monthly income, the Husband has net monthly income for support purposes of $2,229.00.3 With the Wife having net monthly income of $901.00 and the Husband having net monthly income of $2,229.00, the Husband's obligation for alimony pendente lite calculated pursuant to the guidelines is $531.00 per month.4 The length of time in which the parties resided together from the date of the marriage to the date of final separation is a factor to be considered in determining whether to deviate from the guideline award in a claim for alimony pendente lite. The parties married on December 3, 2003 and separated on or about July 6, 2005. They resided together for approximately 19 months following the marriage, a relatively short duration. Another relevant and appropriate factor to consider in this case is the Husband's payment of $45.80 bi-weekly, or $99.00 per month, to provide health insurance coverage for himself and his wife. Taking all factors into consideration, a downward deviation in the APL obligation to $501.00 per month is recommended.s RECOMMENDATION A. The Husband shall pay to the Pennsylvania State Collection and Disbursement Unit as alimony pendente lite the sum of $501.00 per month. B. The Husband shall pay to the Pennsylvania State Collection and Disbursement Unit on arrearages the additional sum of $84.00 per month. See Plaintiffs Exhibit 1. See Exhibit "A" for the tax deductions from gross income. ' See Exhibit "B" for the calculation. $ See Pa. R.C.P. 1910.16-5(b)(8). Although Pa. R.C.P. 1910-16-5(c) permits consideration of the period of time the parties resided together from the date of the marriage to the final separation in determining the duration of an award of alimony pendente lite, no recommendation relative to duration of award is made at this time. 4 C. The Husband shall provide health insurance coverage for the benefit of the Wife as is provided through his employer at a reasonable cost. D. The effective date of this order is July 19, 2005. Date Michael R. Rundle Support Master In the Court of Common Pleas of Cumberland County, Pennsylvania Tax Detail Report Plaintiff Name: Pamela S. Roney Defendant Name: Curtis A. Roney Docket Number: 05-3412 Civil PACSES Case Number: 586107501 Other State ID Number: Tax Year: Current: 2005 Defendant Plaintiff 1. Tax Method 1040 ES 1040 ES 2. Fling Status Married Filing Separately Single 3. Who Claims the Exemptions Oblige 4. Number of Exemptions 1 1 5. Month) Taxable Income $3,352.41 - 6. Deductions Method 7. Deduction Amount $416.67 $416.67 8. Exemption Amount $266.67 $266.67 9. Income MINUS Deductions and Exemptions $2,669.07 -$683.34 10. Tax on Income $389.35 - 11. Child Tax Credit - _ 12. Manual Adjustments to Taxes - - 13. Federal Income Taxes $389.35 - 13 a. Earned Income Credit - - 14. State Income Taxes $105.94 - 15. FICA Payments $245.97 - 16. City Where Taxes Apply --Select-- 17. Local Income Taxes $32.15 - TOTAL Taxes $773.41 - SupportCalc 2005 EXHIBIT "A" In the Court of Common Pleas of Cumberland County, Pennsylvania Spousal Support Calculation Rule 1910.16 (PACSES FORMAT) Plaintiff Name: Pamela S. Roney Defendant Name: Curtis A. Roney Docket Number: 05-3412 Civil PACSES Case Number: 586107501 Other State ID Number: 1. Obligor's Month/ Net Income $2,229.34 2. Less All Other Support - 3. Less Obligee's Month/ Net Income $901.00 4. Difference $1,328.34 5. Less Child Support Obligation for Current Case - 6. Difference $1,328.34 7. Multiply b 30% or 40% 40.00% 8. Income Available for Spousal Support $531.34 9. Adjustment for Other Expenses - 10. AMOUNT OF MONTHLY SPOUSAL SUPPORT OR APL $531.34 Prepared b : Date: 9/27/2005 SupportCalc 2005 EXHIBIT "B" r-l O -rt c !E C- fil w C-5 t LOD CURTIS A. RONEY, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE PAMELA S. RONEY, NO. 05-3412 CIVIL TERM DIVORCE Defendant/Respondent PACSES Case Number: 586107501 ORDER OF COURT AND NOW, this 6th day of August, 2007, a petition has been filed against you, Pamela S. Roney to modify 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 August 27, 2007 at 1.30 P.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 W2'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 issie a warrant for your arrest. BY THE COURT, Edgar B. Bayley, President Judge Copies mailed to: Petitioner Respondent Diane G. Radcliff Esq. Keith O. Brenneman, Esq Date of Order: August 6, 2007 00 R. J., adday, 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 Q ? Q .2>C_ t17 li7 d t 9 CURTIS A. RONEY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. PAMELA S. RONEY, NO. 05-3412 CIVIL TERM Defendant CIVIL ACTION - LAW IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Curtis A. Roney, Plaintiff moves this Court to appoint a master with respect to the following claims: (x) Divorce (x) Distribution of Property ( ) Annulment ( ) Support (x) Alimony (x) Counsel Fees ( ) Alimony Pendente Lite (x) Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claims(s) for which the appointment of a master is requested. (2) The Defendant has appeared in the action by his attorney, (3) The statutory grounds for divorce is Section 3301(d). (4) Delete the inapplicable paragraph(s): (a) The ae6eft is net . (b) An agreement has been reached with respect to the following claims: None. (c) The action is contested with respect to the following claims: equitable distribution, alimony, counsel fees, costs and expenses. (5) The action (invelves)(does not involve) complex issues of law or fact. (6) The hearing is expected to take 4 (days)(hours). (7) Additional information, if any, relevant to the motion: N/A. Date: August 2007 dot--? Keith O. Brenneman, Esquire Attorney for Plaintiff ORDER APPOINTING MASTER AND NOW, this day of , 2007, E. Robert Elicker, II, Esquire is appointed Master with respect to the following claims: BY THE COURT: J. '? ??- C? .y f'-° . ?d f 4? ? ?',, ; ?.r a 3 ?? f„} ,.? ??? 4 ? ?_ i ? # 4J d ? ry t ? V ? CURTIS A. RONEY, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-3412 CIVIL TERM PAMELA S. RONEY, Defendant CIVIL ACTION - LAW IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Curtis A. Roney, Plaintiff moves this Court to appoint a master with respect to the following claims: (x) Divorce ( ) Annulment (x) Alimony ( ) Alimony Pendente Lite and in support of the motion states: (x) Distribution of Property ( ) Support (x) Counsel Fees (x) Costs and Expenses (1) Discovery is complete as to the claims(s) for which the appointment of a master is requested. (2) The Defendant has appeared in the action by his attorney, (3) The statutory grounds for divorce is Section 3301(d). (4) Delete the inapplicable paragraph(s): (a) The ae6ea is not . (b) An agreement has been reached with respect to the following claims: None. (c) The action is contested with respect to the following claims: equitable distribution, alimony, counsel fees, costs and expenses. (5) The action (invelves)(does not involve) complex issues of law or fact. (6) The hearing is expected to take 4 (days)(hours). (7) Additional information, if any, relevant to the motion: N/A. Date: August / d , 2007 Keith O. Brenneman, Esquire Attorney for Plaintiff ORDER APPOINTING MASTER AND NOW, this l34j' day of _ Master with respect to the following claims: rhh? ?V V 2007, E. Robert Elicker, II, Esquire is appointed J. ?C' , ` `4 C i-9 LL- 40 1 CV :5 D rT `r"7 te ? 1 ..r ` `r y? ? ? s 8 9 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CURTIS A. RONEY, Plaintiff/ Respondent V. PAMELA S. RONEY, Defendant/ Petitioner NO. 2005-3412 Civil Term PACSES NO. 586107501 CIVIL ACTION-LAW IN DIVORCE INCOME AND EXPENSE STATEMENT OF PAMELA S. RONEY CONFERENCE DATE: 8/27/2005 I verify that the facts set forth in the following Income and Expenses Form, including all attachments thereto, are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. DATE: g ?a X2 00-7 PAMELA S. RONEY - 1 - PART I. INCOME A. EMPLOYMENT INFORMATION: Employer: I N/A DISABLED AND RECEIVING SSD R_ INCOME- DESCRIPTION MONTHLY YEARLY Gross Income (Social Security Disability) $969.00 $11,628.00 Medicare Health Insurance Costs None None Net $969.00 $11,628.00 C_ OTHER INrnAAF- DESCRIPTION WEEKLY MONTHLY YEARLY Interest Dividends Pensions Annuities Rents Royalties Expense Account Gifts Unemployment Compensation Workman's Compensation Income Tax Refunds Support or Alimony - Not this Case Commissions Tips TOTAL OTHER INCOME $0.00 so-00 1 so-00 -2- PART II. EXPENSES DESCRIPTION * Cows HOME EXPENSES: Rent $403.00 Low income housing Utilities Included in rent Cell Phone $40.00 Telephone/Cable TV/Internet $112.00 EMPLOYMENT Public Transportation Lunches TAXES: Real Estate Taxes Personal Property Taxes Income Taxes Not Withheld Per Capita/ Occupation Taxes $1.00 INSURANCE: Renter's Insurance Automobile Insurance $50.00 Life Insurance Accident Insurance Health Insurance .3- DESCRIPTION AUTOMOBILE EXPENSES: Payments Fuel $200.00 Maintenance and Repair $200.00 License and Registration $4.00 MEDICAL EXPENSES NOT REIMBURSED BY INSURANCE: Doctor $30.00 Optical Dental $11.00 Hospital Medicine $120.00 Special Needs/Therapy, Etc. EDUCATIONAL EXPENSES: Private/ Parochial School College/ Vocational Books/Fees and Supplies PERSONAL EXPENSES: Clothing $75.00 Food $400.00 Barber and Hair Dresser $40.00 Memberships $2.00 Other Personal Expenses -4- DESCRIPTION MORMLY'ANOOT " C+ Ibis CREDIT CARDS AND LOANS: Just filed Bankruptcy so currently no credit cards MISCELLANEOUS EXPENSES: Newspapers /Magazines/ Books $10.00 Entertainment TBD TBD based on affordability Vacations TBD TBD based on affordability Gifts TBD TBD based on affordability Legal Fees $150.00 Charitable Contributions TOTAL EXPENSES $1,848.00 - 5 - PART III. PROPERTY OWNED PROPERTY OWNED OWNERSHIP TYPE DESCRC t VULVE H w JT Checking Member's 1St Minimal - varies x Savings Member's 1St Minimal - varies x Credit Union Stocks/bonds Real Estate Other TOTAL 0.00 PART IV. INSURANCE INSURANCE INFORMATION COVERAGE TYPE COOP ANY PAY-. H W C Hospital Medicare part A 089489893 x Medical H's Highmark PPO ZAR105024309001 x x Health Accident Disability Income Dental H's Delta Dental TBD x x Vision Other-Specify *H=Husband; W=Wife; J=Joint; C=Child -6- PART V. SUPPLEMENTAL INCOME STATEMENT [ d ] CHECK HERE IF NOT APPLICABLE (a) This form is to be filled out by a person: (1) Who operates a business or practices a profession, or (2) Who is a member of a partnership or joint venture, or (3) Who is a shareholder in and is salaried by a closed corporation or similar entity. (b) Attach to this statement a copy of the following documents relating to the partnership, joint venture, business, profession, corporation or similar entity (check block to indicate the document is attached): (1) The most recent Federal Income Tax Return. [ ] attached (2) The most recent Profit and Loss Statement. [ ] attached (c) Name of Business: Business Address: Business Telephone: (d) Nature of Business (check one) [ ] 1. Sole Proprietorship [ ] 2. Partnership [ ] 3. Joint Venture [ ] 4. Professional [ ] 5. Corporation [ ] b. Other (e) Name of accountant, controller or other person in charge of financial records: (f ) Bus 1. 2. 3. 4. 5. ;iness Income: Annual income from business: How often is income received: Gross income per pay period: Net income per pay period: Specify deductions, if any: CERTIFICATE OF SERVICE I hereby certify that I am this day serving the foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure: Service by Hand Delivery to the Person and at the Address as Follows: Keith 0. Brenneman, Esquire (Counsel for Plaintiff ) C? Domestic Relations Office 13 North Hanover Street Carlisle, PA 17013 Dated: (Att ney Reg' tration No 32112) 3448 n e Road Camp Hill, PA 17011 Email: dianeradcliffCcomcast.net Phone: (717) 737-0100 Fax: (717) 975-0697 Counsel for Defendant -8- p ,C'7 ; M? ` In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION CURTIS A. RONEY ) Docket Number 05-3412 CIVIL Plaintiff /Petitioner ) VS. ) PACSES Case Number 586107501 PAMELA S. RONEY ) Defendant/Respondent ) Other State ID Number ORDER AND NOW, to wit, on this 27TH DAY OF AUGUST, 2007 IT IS HEREBY ORDERED that the APL order in this case be Q Vacated or 0Suspended or (j) Terminated without prejudice or Q Terminated and Vacated, effective AUGUST 3, 2007 , due to: THE PARTIES BEING MAItR= .FOR NINETEEN MONMS...BEFORE cRFARATION .IN THE :YZAR OF 2005 AND THE DEFENDANT MAKING PAYMENTS FROM AN ALIMONY PENDENTE LITE ORDER OF OCTOBER 4, 2005. THE ALIMONY PENDENTE LITE ACCOUNT IS CLOSED WITH A CREDIT OF $312.15. ALL PAYMENTS THAT ARE BEING HELD ARE TO BE REFUNDED TO THE DEFENDANT AND TO CONTINUE TO BE REFUNDED UNTIL THE WAGE ATTACHMENT ORDER CAN BE TERMINATED. BY THE COURT: .I L-.7 . U JUDGE DRO: R.J. SHADDAY j/ Form 0E-504 Service Type M Worker ID 21005 C7 0 ?... ... -3? -Ti ORDERINOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth,of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 08/27/07 Case Number (See Addendum for case summary) 586107501 0Original Order/Notice 05-3412 CIVIL O Amended Order/Notice O Terminate Order/Notice Employer/Withholder's Federal EIN Number CUMBERLAND COUNTY C/O CONTROLLERS OFFICE 1 COURT HOUSE SQ CARLISLE PA 17013-3323 RE: RONEY, CURTIS A. Employee/Obligor's Name (Last, First, MI) 206-36-3745 Employee/Obligor's Social Security Number 3915101526 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. op per month in current support $ o. oo per month in past-due support Arrears 12 weeks or greater? Oyes ® no $ 0.00 per month in current and past-due medical support $ o . 00 per month for genetic test costs o $ 0, oo per month in other (specify) C_- °_ for a total of $ o . 00 per month to be forwarded to payee below. rn3 ,, You do not have to vary your pay cycle to be in compliance with the support order. If youvAf*ycl s not match the ordered support payment cycle, use the following to determine how much to -- -0 $ o. oo per weekly pay period. o? $ o. oo per biweekly pay period (every two weeks). $ 0. M per semimonthly pay period (twice a month). ZP. rn to $ o . oo per monthly pay period. ?_ .? REMITTANCE INFORMATION: cn M? You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S 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 COURTS //) A Date of Order:?? a J. OLER, JUDGE Form EN-028 Rev. 1 Service Type M or,,ero.:o97oo,S. Worker ID $IATT r "% ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If heck you are required to pr idea opy of this form to youreec?m loyee. If yor employee works in a state that is di Brent from the state that issuedoNs order, a copy must be provito your empl oyee even if ie box is not checked. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee%bligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employeelobligor. 3.* Reporting the Paydate/Date of Withholding. You must report die paydate/date of withholding when sending tile Payment. Tire paydateldate of withholding is the date on which amount was Withheld koin die employee's wages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employeelobligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2360031190 EMPLOYEE'S/OBLIGOR'S NAME: RONBY, CURTIS A. EMPLOYEE'S CASE IDENTIFIER: 3915101526 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 employeelobligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employeetobligor from employment, refusing to employ, or taking disciplinary action against any employeelobligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of. 1) the amounts allowed by the Federal Consumer Credit Protection Act 0 5 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Submitted By: DOMESTIC RELATIONS SECTION 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 if you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT Page 2 of 2 OMB No.: 0970-0154 Form EN-028 Rev. 1 Worker I D $ IATT ADDENDUM Summary of Cases on Attachment Defendant/obligor: RONEY, CURTIS A. PACKS Case Number 586107501 Plaintiff Name PAMELA S. RONEY Docket Attachment Amount 05-3412 CIVIL $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? if checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee'slobligor's employment. PACSES 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. C71 p C.- ca -?! t [fi `` 44 j ? W ""'^^1??rr y ` IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PEN#%L CURTIS A. RONEY, NO. 05-3412 Plaintiff CIVIL ACTION - LAW V. IN DIVORCE PAMELA S. RONEY, Defendant APPEAL OF APL ORDER AND REQUEST FOR HEARING DE NOVO DATE OF ORDER: August 27, 2007 AMOUNT OF ORDER: $0.00 - Termination of APL Order PARTY FILING APPEAL/DE NOVO HEARING REQUEST: Pamela S. Roney REASONS FOR APPEAL/ DE NOVO HEARING REQUEST: The prior APL order should not have been terminated since wife is disabled and the divorce proceedings are still pending and wife needs to APL to be on a financial par with her husband in defending/ prosecuting this divorce. WHEREFORE, Pamela S. Roney requests this Honorable Court to hold a Hearing De Novo in the above captioned case and to enter an appropriate support order based on the facts of this case. SIGNATURE OF ATTORNEY/APPELLANT: Camp Hill, PA 17011 Phone: (717) 37-010 Date: 01 CERTIFICATE OF SERVICE I hereby certify that I am this day serving the foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure: Service by First Class Mail Addressed as Follows: Keith 0. Brenneman, Esquire Snelbaker Et Brenneman, P.C. 44 West Main Street Mechanicsburg, PA 17055 (Counsel for Plaintiff, Curtis A. Roney ) Dated: b? DIANE-Er1bkDCL?FF, ESQUIRE (Attorney Registration No 32112) 3448 Trindle Road Camp Hill, PA 17011 Email: dianeradcliff2comcast.net Phone: (717) 737-0100 Fax: (717) 975-0697 Counsel for Pamela Roney C) ? Cam, C==, -ri ? cn rn r? r -am Cil c w cj d 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CURTIS A. RONEY, NO. 05-3412 Plaintiff CIVIL ACTION - LAW V. IN DIVORCE PAMELA S. RONEY befendant INVENTORY OF PAMELA S. RONEY Defendant files the following inventory of all property owned or possessed by either parry at the time this action was commenced and all property transferred within the preceding three years. Defendant verifies that the statements made in this inventory are true and correct. Defendant understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. PAMELA S. RONEY, DEFE ANT Dated: $ ` D- 1 ` O -7 4 ZMANE . CLIFF, ESQUIRE 48 Trindle R ad Ca 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court IJ3 #321,12 Dated: g 2-? ASSETS AND LIABILITIES OF PARTIES Defendant marks on the list below those items applicable to the case at bar and itemizes the assets and debts on the following pages: (X) 1. Real Property and Real Estate Mortgages (X) 2. Motor Vehicles and Vehicle Liens (X) 3. Stocks, Bonds, Securities and Options O 4. Certificates of Deposit (X) 5. Checking Accounts, Cash (X) 6. Savings Accounts, Money Market and Savings Certificates () 7. Contents of Safe Deposit Boxes () 8. Trusts () 9. Life Insurance Policies () 10. Annuities (} 11. Gifts () 12. Inheritances {) 13. Patents, Copyrights, Inventions, Royalties () 14. Personal Property Outside the Home O 15. Business () 16. Employment Termination Benefits-Severance Pay, Worker's Compensation () 17. Profit Sharing Plans (X) 18. Pension Plans (indicate employee contribution and date plan vests) () 19. Retirement Plans, Individual Retirement Accounts () 20. Disability Payments () 21. Litigation Claims (matured and unmatured) () 22. MilitaryN.A. Benefits () 23. Education Benefits () 24. Debts Due, including loans, mortgages held (X) 25. Household Furnishings and Personalty () 26. Other Assets (X) 27. Loans, Credit Cards and Other Debts -2- INFORMATIONAL NOTES AND CODES "d" denotes that the entry (value) is verified by a document. 2. W denotes documents/information to be supplied by the designated party. 3. "W' denotes an item about which a decision is required. 4. "W" denotes non-marital property not subject to equitable distribution. 5. The values used in the various Tables herein may, in some cases, be based on estimated values. Those estimated values are subject to adjustment upon appraisal or otherwise. 6. Any adjustment figures used in the various tables herein are for illustration purposes only and are not to be deemed a representation on the part of the Defendant as to whether an adjustment should be made or the amount of the adjustment, if any is appropriate. -3- SECTION I. BACKGROUND INFORMATION The following Table #1 sets forth the background information relevant to this case: T #S DEWFUMON Name Curtis A. Roney Pamela S. Roney Maiden Name N/A Pamela S. Bronson Address 800 West Keller St. Mechanicsburg, PA 17055 PO Box 1344 Mechanicsburg, PA 17055 Names and Relationship of Persons Living with Party None Known None Date Party Moved to Current Residence 1949 3/07 Date PA Residency Began Birth Birth E-mail N/A N/A Date of Birth 7/26/46 8/5/54 Age 59 51 Place of Birth Mechanicsburg, PA Wellsboro, PA Race Caucasian Caucasian Health Status Good Disabled: Fibromialgia; GERD; IBS; Arthritis; Ashma; Depression; Migraines Educational Background High School Graduate High School Graduate Current Military Service NIA N/A Employer's Name and Address Cumberland County Cumberland Count Prison Claremont A Carlisle, PA N/A - disabled, on SSD Occupation (Job Position) Corrections Officer N/A Date Employment Commenced 1990 N/A Est. Annual Income 1,477 BW ( 8 402/yr (Figures from )d5; current income un(nown) 969/mo SSD (11,6281yr) -4- TABLE #1-B MARRIAGE INFORMATION DESCRIPTION Date of Marriage 12/03/03 Place of Marriage Newville, Cumberland County, PA Date of Separation 7/6/05 Statement of Marital Problems Husband told wife to get out of the marital home. He called her names and treated her like dirt. He abused drugs. Grounds for Divorce 3301(d) 2 year separation no fault Prior Divorce Actions Between Parties None Number of this Marriage for Wife 4 Number of this Marriage for Husband 2 TABLE #1-C CHILDREN OF THIS MARRIAGE NA AGE DAVE-Op r 4 None N/A N/A N/A N/A TABLE #1-D SUPPORT FOR THIS MARRIAGE DESCRIPTION Name of Party Paying Support Husband Beneficiaries of Support Wife Amount of Support $501 per month terminated effective 8/3/07 Allocation All APL Agreement or Order Order Date of Agreement or Order 10.4.05 Effective Date of Order 6.19.05 Docket Number of Support Order NO. 05-3412; Pacses # 586107501 Comments: Appeal of Termination Pending -5- TABLEV-E PRIOR MARRIAGES PARTY I p -11,111, MIN- Wife 1 Divorce Wife 2 Divorce Wife 3 Divorce Husband 1 Divorce TABLE #1-F CHILDREN OF OTHER RELATIONSHIPSIMARRIAGES PARTY NAME OF CHILD Wife James Eslinger 35 Emancipated Wife Patricia Reuter 34 Emancipated Wife Angela Cuoczo 31 Emancipated Husband Barbara ? 35 Emancipated TABLE #1•G SUPPORT/ALIMONY FOR PRIOR MARRIAGES/RELATIONSHIP Q;RTRNI IN' Name of Party Paying Support N/A NIA Beneficiaries of Support N/A N/A Allocation N/A N/A Agreement or Order N/A N/A Date of Agreement or Order NIA N/A Docket Number of Support Order N/A NIA Comments: N/A N/A -6- ' TABLE #1,H PROCEEDINGS INFORMATION: CO1?` Complaint Filing Date 7/6/05 Date of Service 7/18/05 Manner of Service Acceptance of Service by Defendant's Attorney Type of Divorce Requested No Fault & Indignities Economic Claims Raised Equitable Distribution AWINER, COUNTERCLANF' 'O Type of Pleading Petition Raising Economic Claims Pleading Filing Date 7/19/05 Type of Divorce Requested N/A Economic Claims Raised Equitable Distribution; APL, Alimony; CFC INGE g Plaintiff's I&E Statement Filing Date Note Filed Defendant's 1&E Statement Filing Date 9/4/07 E Plaintiffs Inventory Filing Date None filed Defendant's Inventory Filing Date 9/4/07 Am Cim- Plaintiffs 3301(c) Affidavit Date Plaintiff's 3301(c) Affidavit Filing Date Defendant's 3301(c) Affidavit Date Defendant's 3301(c) Affidavit Filing Date Plaintiffs 3301(c) Waiver of Notice Date Plaintiffs 3301(c) Waiver Filing Date Defendant's 3301(c) Waiver of Notice Date Defendant's 3301(c) Waiver Filing Date -7- TABLE #1-H PROCEEDINGS INFORMATION: 3I #° Date of Physical Separation 7.6.2005 Physical 2 Year Separation Date 7.6.07 Plaintiffs 3301(d) Affidavit Date 7.26.07 Plaintiffs 3301(d) Affidavit Date Filing Date 7.30.07 3301(D) Affidavit Service Date 7.30.07 Manner of Service of 3301(d) Affidavit Regular mail to Defendant's Attorney Date of Plaintiffs Notice of intent to Request Entry of Divorce Decree and Praecipe to Transmit Record Plaintiffs Notice to Request Entry of Divorce Decree and Praecipe to Transmit Record Service Date Manner of Service of Plain fffs Notice to Request Entry of Divorce Decree and 3301(d) Counter-Affidavit BIA)f Has the case been bifurcated? No Date of decree granting bifurcation - N/A b,7fu7rc7afion granted by consent or after hearing rlf N/A -8- Curtis A. Roney vs. Pamela S. Roney DOM:12103/2003 DOS (Filing Date): 7/6/2005 DATE PREPARED: August 21, 2007 SECTION II. MARITAL ASSETS AND DEBTS The following Table #2 sets forth the listing of the marital assets and debts of the parties: TABLE #2' MARIT SSM D DEBTS_ A B C D E F G H I Ln B. Ref Owner Description Date Net Value Net Proposed Proposed No Calculation Distribution Distribution Distribution V ue To Husband To We ??dd 5 RE-1 H 800 W. Keller St, Mbg TBb / DOS Value 0 / 1A 6 RE-1 H Less DOM Value 7 RE-1 -- Net Marital Increase/Value -- TBD TBD TBD 8 Comments: > Husband inherited from his mother in 1994 * Property to be appraised as of date of marriage and'date of separation. 9 RE-2 H Sale Proceeds 3 lots Keller TBD Street DOS Value 10 RE-2 H Less DOM Value T 11 RE-2 -- Net Marital Increase/Value -- Tea TBD TBD 12 Comments: > Husband inherited from his mother in 1994 * Property to be appraised as of date of marriage * Husband to provide sale documents 11!` z- ,a 14 V-1 W 2004 Bombardier Jet Ski DOS 8,000 15 V-1 W Less Jet Ski Loan GE Bank (B.OOOI 16 V-1 -- Net Equity 0 0 0 0 17 Continents: > Purchased for $10,500+; totally financed. * Sold by wife 612006 for loan balance 18 V-2 W 2004 Dodge Ram Tk DOS -- WNM 19 V-2 W Less DOA Value -- WNM 20 V-2 -- Net Equity -- No MI' No MI No MI 21 Comments: > Wife's non-marital - acquired by wife from retirement funds received from prior marriage divorce settlement - no known marital increase in value > Wife gifted in March 2006 to Wife's son; condition of qualifying for low income housing -9- Curtis A. Roney vs. Pamela S. Roney DOM:12/03/2003 DOS (Filing Date): 7/612005 DATE PREPARED: August 21, 2007 TABLE 42 " TAL ASSETS IIiJ?A WTS A B C D E F G H I Ln B. Ref Owner Description Date Net Value Net Proposed Proposed No Calculadon Distribution Distribution Distribution V To Husband To Wife 22 V-3 W 2004 Sunline Camper DOS -- to 23 V-3 W Less DOA Value -- T 24 V-3 -- Net Marital Increase - NQ MI No MI No MI 25 Comments: > Wife's non-marital - acquired by wife from retirement funds received from prior marry divorce settlement - no known marital increase in value > Wife gifted in March 2006 to Wife's son; condition of qualifying for low income housing 26 V4 W 1995 Pontiac Firebird DOS -- V*M 27 V4 W Less DOM Value -- WNM IF oo0f' 28 V4 -- Net marital Increase -- No Ml No MI No MI 29 Comments: > Wife's non-marital - acquired by wife prior to marriage 30 V-5 H 1995 Ford F-150 TK DOS -- HNM 31 V-5 H Less DOM Value -- HMI 32 V-5 -- Net Marital Increase -- No MI No MI No MI 33 Comments: > Husband's non-marital - acquired by Husband prior to marriage 34 V-6 H 1999 Harley Davidson DWG -- HIM DOS Value 35 V-6 H Less DOA Value -- 36 V-6 -- Net Marital Increase -- ''No W No MI No MI 37 Possible Non-marital Husband. Acquired in part fro m trade in or sale of 1998 Dresser Harley Davidson 39 INVA H Citizen's Brokerage Account 24,981 DOS Value 40 INV-1 H Less Citizen's Brokerage TOD Account NM Gift or Investment 41 INV-1 -- Net Marital Increase 24,981 24,981 24,981 42 Comments: > Wife believes DOS value was $24,981. $15,000 was transferred into checking just prior to separation so prior balance was $39,981. Of this husband's father gave husband $17,000. Some of the stock was sold for $15,000 and put into Citizen's checking account. * Husband to provide copies of all statements from 121112003 to 8131105. ff he claims this asset is partially non- marital, he needs to provide proof of the non-marital value. -10- Curtis A. Roney vs. Pamela S. Roney DOM:12103/2003 DOS (Filing Date): 7/6/2005 DATE PREPARED: August 21, 2007 TABLE #2 1111ANTAL. EANUDEBT A B C D E F G H I Ln B. Ref Owner Description Date Net Value Net Proposed Proposed No Calculation Distribution Distribution Distribution Value To Husband To Wife 43 INV-2 H US Savings Bonds DOS 44 INV-2 H Less DOM or DOA Value 45 INV-2 -- Net Marital Increase T8Q TBD TBD 46 Comments: )'-Husband's acquired by gift from his grandmother. # Husband to provide copies of bonds and proof of value of bonds as -of date of acquisition and 711105 48 A-1 H Citizen's Bank Checking #826-4 -- 125;46 125,496 125,496 49 Commeids: * Husband to provide of all statements from U/1=3 to 8/31105. !f he claima this asset Is pard* non- marital, he needs to provvWproof of the non-marital value )P-Includes proceeds from sale of 3 lots on Keller Street which will to be backed out and Irtsel?tsd In `Rdal Estate #2 above once ll tat rmi nt a det th id d t t a s eme s re prov o e e ne e amount deposi . _ 50 A-2 W Wife's Member's I' Account F6 0-5 82 82 82 51 Comments: 53 INS-1 H Met Life DOS TaD 001, 54 INS-1 H Less DOM Value 55 INS-1 -- Net Marital Increase -- a 0 0 0 56 Comments: * Husband to provide copies of all statements from 12/1/2003 to 8131105. If he claims this asset' is partially non-marital, he d t id f f th i l l nee s o prov e proo e non-mar o ta va ue 58 RET-1 H Cumberland County Pension TBD DOS Value 59 RET-1 H Less DOM Value TBD 60 RET-1 -- Net Marital Increase -- 0 0 0 61 Comments: * Husband to provide copy of most recent benefit statement and summary plan description. * Pension to be appraised or marital value distributed on a deferriObasls. 63 HG1 H Household Goods 0 0 64 Comments: * Wife believes prior distribution is satisfactory and parties will waive further distribution. However, if requested by Husband, value to be determined by appraisal. -It- Curtis A. Roney vs. Pamela S. Roney DOM:12/03/2003 DOS (Filing Date): 7/6/2005 DATE PREPARED: August 21, 2007 TABLE #2 MA A-L AS TS, DINS A B C D E F G H I Ln No B. Ref Owner I Description Date Net Value Calculadon Not Distributlon Value Proposed Distribution Td Husband Proposed Distribution To We 65 HG-2 W Household Goods 0 0 66 Costs: W& beeves prior dl bfbution is satisfactory and partles Y411 waive further dkb*uUw. Hwovw, If reclutoW by Husband, value to be dertnined by appraisal. 67 68 71 Total of Assets 4i D-1 W Chase Platinum MC #6389 4.21.05 (.9i 150,558 (9,852) 150,477 82 (9,852) 72 Comments: 73 D-2 W AT&T Universal #3758 7.19.05 (10,795) (10,795) (10,795) 74 COtl1/1143fitS: 75 D-3 W GE Money Bank #1711 7.25.05 (8,354) (8,354) (8,354) 76 `iOWW?Wft >000000 78 79 Total of Debts (29,001) 0 (29,001) 81 111. 82 Asset Totals from above 150,558 150,477 82 83 Less Debt Totals from Above Q-00 0 29 001 84 Net Total • Assets Minus Liabilities 121,557 150,477 (28,919) -12- SECTION III. LISTING OF HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY The following Tables #3-A and # 3-8 set forth the household goods and contents and other personal property of the parties: ' Wife does not believe there is a dispute over household goods and contents. Therefore Tables #3-A and #3-B have not been completed. TABLE #3-A HOUSEHOLD GOODS AN kCSB NSAND TN RSONAL PROPERTY NO. DESCRIPTION OWNER POSSESSOR VALUE DATE VALUE BASIS FOR EXCLUSION IF NOW MARITAL H & W Husband -- Comments: TOTAL HUSBAND'S POSSESSION NIA HOUSEHOLD GOODS AND CON ENBTS AND OTHER PERSONAL PROPERTY IN WIFE'S POSSESSION NO. DESCRIPTION OWNER POSSESSOR VALUE DATE VALUE BASIS FOR EXCLUSION IF NON- MARITAL H & W Wife -- Comnwts: TOTAL WIFE'S POSSESSION NIA Note: Exclusions from marital property include property acquired before marriage, property acquired after separation, or property acquired during marriage by way of gift or inheritance from third party not a spouse. For gifts and inheritance also specify the source person. -13- SECTION IV. NON-MARITAL ASSETS AND DEBTS The following Table #4 sets forth the non-marital assets and debts of the parties: 2,3 TABLE #4 NON-MARITAL. PROPERTY AND NETS A B C D E F G H I J Ln B. Owner Description Value Gross Non-Marital Marital Basis for Method of No Ref Date Value Value Value Exclusion If Valuation & Claimed to Be supporting NM M uments 1 RE-1 H 800 W. Keller St, Mbg TBD TBD TBD TBD Inheritance TBD Premarital 2 RE-2 H Proceeds from Sale of TBD TBD TBD TBD Inheritance TBD Lots W. Keller Street Premarital 3 V-2 W 2005 Dodge Ram Truck TBD TBD TBD TBD Purchased with TBD Premarital Funds 4 V-3 W 2004 Sunline Camper TBD TBD TBD TBD Purchased with TBD Premarital Funds 5 V-4 W 1995 Pontiac Firebird TBD TBD TBD TBD Premarital TBD 6 v-5 H 1995 Ford F-150 TK TBD TBD TBD TBD Premarital TBD 7 v-s H 1999 Harley Davidson TBD TBD TBD TBD Purchased with TBD DWG Premarital Funds 8 Inv-1 H Citizen's Bank TBD TBD TBD TBD Premarital TBD Brokerage Account Gift? 9 Inv-2 H US Savings Bonds TBD TBD TBD TBD Inheritance TBD Premarital 10 Ins-1 H H's Met Life Policy TBD TBD TBD TBD Premarital TBD 11 Ret-1 H H's Cumberland County TBD TBD TBD TBD Premarital TBD Pension Plan 2Note: Exclusions from marital property include property acquired before marriage, property acquired after separation, or property acquired during marriage by way of gift or inheritance from third party not a spouse. For gifts and inheritance also specify the source person. 3The value of each item has been estimated by Defendant unless otherwise noted. -14- SECTION V. PROPERTY TRANSFERRED The following Table #5 is Defendant's listing of all property which was transferred within 3 years of the date of the commencement of this action or was transferred since the date of separation: TABLE #5 PROPERTY TRANSFERRED NO. DESCRIPTION OF PROPERTY TRANSFER DATE CONSIDERATION TRANSFEROR TRANSFEREE 1 H's 3 lots on Keller Street, Mechanicsburg Near Separation Unknown Husband Unknown 2. W's 2004 Bombardier Jet Ski 6.06 Loan Balance Wife n Unknown 3. E W's 2005 Dodge Ram Truck 3.06 None - Gift Wife Wife's son 4. W's 2004 Sunline Camper 3.06 None - Gift Wife Wife's Son -15- CERTIFICATE OF SERVICE I hereby certify that I am this day serving the foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure: Service by First Class Mail Addressed as Follows: Keith 0. Brenneman, Esquire Snelbaker Et Brenneman, P.C. 44 West Main Street Mechanicsburg, PA 17055 (Counsel for Plaintiff, Curtis A. Roney ) Dated: '"t I ±? / G DI E G. RAD IFF, ESQUIRE (Att stration No 32112) Camp Hill, PA 17011 Email: dianeradcliff@comcast.net Phone: (717) 737-0100 Fax: (717) 975-0697 Counsel for Pamela Roney -16- ^a ...a ? c:: ? -n i. + fir:; `.. C/? ?7 ? ? i? C17 ? -r, , ? -,-? k i ." CAS : .j t..) . _... -.r I 1 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION PAMELA S. RONEY ) Docket Number 05-3412 CIVIL Plaintiff ) VS. ) PACSES Case Number 586107501 CURTIS A. RONEY ) Defendant ) Other State ID Number ORDER OF COURT You, PAMELA S. RONEY plaintiff/defendant of PO BOX 1344, MECHANICSBURG, PA. 17055-1344-44 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the OCTOBER 15, 2007 at 10:3 0AM fora hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income Statement and the appropriate Expense Statement, if required, attached to this order, completed as required by Rule 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. information relating to professional licenses 7. other: Service Type M Form CM-509 Rev. 1 Worker ID 21302 f Z RONEY If you fail to appear for the conference/hearing or to bring the required documents, the , court may issue a warrant for your arrest and/or enter an interim support order. If paternity is an issue, the court shall enter an order establishing paternity. THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD TO WHICH PARTY INITIATED THE SUPPORT ACTION. BY THE COURT: Date of Order: o7 J. WESLEY 04R, JR. , JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE-HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. V. RONEY CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 PACSES Case Number: 586107501 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240 - 6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Service Type M Page 2 of 2 Form CM-509 Rev. 1 Worker ID 21302 12WO Y3S23W L C) ra C= M co 0 144 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION PAMELA S. RONEY ) Docket Number 05-3412 CIVIL Plaintiff ) VS. ) PACSES Case Number 586107501 CURTIS A. RONEY ) Defendant ) Other State ID Number ORDER OF COURT You, CURTIS A. RONEY plaintiff/defendant of 800 W KELLER ST, MECHANICLSBURG, PA. 17055-7518 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the OCTOBER 15, 2007 at 10 : 3 OAM for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the income Statement and the appropriate Expense Statement, if required, attached to this order, completed as required by Rule 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. information relating to (professional licenses 7. other: Service Type M Form CM-509 Rev. 1 Worker ID 21302 ld%l RONEY V. RON EY PACSES Case Number: 586107501 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for, your arrest and/or enter an interim support order. If paternity is an issue, the court shall enter',an order establishing paternity. THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD TO WHICH PARTY INITIATED THE SUPPORT ACTION. BY THE COURT: Date of Order: JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE-HEARING,! AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND CO BAR ASSOCIATION 32:S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable ac ommodations available to disabled individuals having business before the court, please contact our office at: (717) 2 4 0 - 6 2 2 5 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Rev. Service Type M Worker ID 21302 90 ;C- CURTIS A. RONEY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : DOMESTIC RELATIONS SECTION PAMELA S. RONEY, PACSES NO. 586107501 Defendant DOCKET NO. 05-3412 CIVIL INTERIM ORDER OF COURT AND NOW, this JYk -day of October, 2007, upon consideration of the Support Master's Report and Recommendation, a copy of which is attached hereto as Exhibit "A", it is ordered and decreed as follows: A. The order entered August 27, 2007 terminating the Husband's obligation to pay alimony pendente lite is vacated. B. The Husband's petition to terminate alimony pendente lite is dismissed without prejudice to refile should the Wife fail to proceed to resolve the economic isWes in the divorce with due diligence. o IMPORTANT LEGAL NOTICE =' - 00 -r, PARTIES MUST WITHIN SEVEN DAYS INFORM THE DOM??IC T% RELATIONS SECTION AND THE OTHER PARTIES, IN WRITING; `ANYgo MATERIAL CHANGE IN CIRCUMSTANCES RELEVANT TO THE U?X/EL Qfj SUPPORT OR THE ADMINISTRATION OF THE SUPPORT ORDER`; INCLUDING, BUT NOT LIMITED TO, LOSS OR CHANGE OF INCOME OR EMPLOYMENT AND CHANGE OF PERSONAL ADDRESS OR CHANGE OF ADDRESS OF ANY CHILD RECEIVING SUPPORT. A PARTY WHO WILLFULLY FAILS TO REPORT A MATERIAL CHANGE IN CIRCUMSTANCES MAY BE ADJUDGED IN CONTEMPT OF COURT, AND MAY BE FINED OR IMPRISONED. PENNSYLVANIA LAW PROVIDES THAT ALL SUPPORT ORDERS SHALL BE REVIEWED AT LEAST ONCE EVERY THREE (3) YEARS IF SUCH REVIEW IS REQUESTED BY ONE OF THE PARTIES. IF YOU WISH TO REQUEST A REVIEW AND ADJUSTMENT OF YOUR ORDER, YOU MUST DO THE FOLLOWING: CALL YOUR ATTORNEY. AN UNREPRESENTED PERSON WHO WANTS TO MODIFY (ADJUST) A SUPPORT ORDER SHOULD CONTACT THE DOMESTIC RELATIONS SECTION. ALL CHARGING ORDERS FOR SPOUSAL SUPPORT AND ALIMONY PENDENTE LITE, INCLUDING UNALLOCATED ORDERS FOR CHILD AND SPOUSAL SUPPORT OR CHILD SUPPORT AND ALIMONY PENDENTE LITE, SHALL TERMINATE UPON DEATH OF THE PAYEE. ..X _r .. y CD CURTIS A. RONEY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : DOMESTIC RELATIONS SECTION PAMELA S. RONEY, PACSES NO. 586107501 Defendant DOCKET NO.05-3412 CIVIL INDEX OF EXHIBITS Plaintiff's Exhibit No. 1 - 2006 federal tax return Plaintiffs Exhibit No. 2 - 2006 W-2 Plaintiff's Exhibit No. 3 - Earnings statement Plaintiffs Exhibit No. 4 - Income and expense statement Defendant's Exhibit No. I - Correspondence between counsel Defendant's Exhibit No. 2 - Income and expense statement Department of the Treasury - Imemal Revenue Service m 1440 U.S. Individual Income Tax Return For the year Jan. 1-Dec. 31, 2006, or other tax year beginning abet L Your firs, name and initial Last name as B CURTIS A RONEY A itructions page 16) E If a joint return, spouse's first name and initial Last name L ra the IRS )(31. H Home address (number and street). If you have a P.O. box, see page 16. herwise, E ease print R 800 W. KELLER ST. type. E City, town or post office, state, and ZIP code. If you have a foreign address, see page 16. residential MECHANICSBURG PA Iection Cam ai n loo. Check here if you, or your spouse if filing jointly, want $3 to 1 Single 4 I staatu tus 2 Married filing jointly (even if only one had income) 3 X Married filing separately. Enter spouse's SSN above and full 10. heck only 6a ie box. name here. ? PAMELA S RONEY 5T f Qualifying widow(er) with dependent Nemptions more than tour ependents,see age 19. Yourself. If someone can claim you as a dependent, do not check box 6a . . . . . . . . . ..................... . . . . . . . . . . ......... b n Spouse 2006 (99) IRS Use Only-Do not write or staple in this space. 2006, ending 20 ; OMB. No. 1545-0074 Your social security number 206-36-3745 Spouse's social security nuo nber 089-48-9893 Apt. no. You must enter • your SSN(s) above, Checking a box below will not 17055-4076 change your tax or refund. o to this fund (see page 16) ? F I You [-I Spouse Head of household (with qualifying person). (See page 17.) If the qualifying person is a child but not your dependent, enter this child's name here, child (see page 17) Boxes checked on 6a and 6b No. of children on 6c who: c Dependents: 1) First name Last name (2) Dependent's social security number (3) Dspend gFit relationshipijY? + you (4) Check if qualifyying child for phild tax credo see 1 rb Tnfel numhe of cvomntinne rlnimcrf . . . . . . . ...... Income Attach Form(s) W-2 here. Also attach Forms W-2G and 1099-R if tax was withheld. If you did not get a W-2, see page 23. Enclose, but do not attach, any payment. Also, please use Form 1040-V. 7 Wages, salaries, tips, etc. Attach Form(s) W-2 8a Taxable interest. Attach Schedule B if required . . . . b Tax-exempt interest. Do not include on line 8a.,;,.,:• . 9 O d' d' 'd d Atf h S h d le B if r !:::F 7 41,032 3,693 a r(nary fvlens, ac ceu eq„.: .::A.•...••.... b Qualified dividends (see page 23) . it'. ?:;;• ` :..I, "9b I 1 , 056 10 Taxable refunds, credits, or offsets of Sta# !, local incoi > axes (see page 24) 11 Alimony received . . . . . . . . ..;.:,... >t''` . .. .. . 12 Business income or (loss). Attach Schedule``?r r' . . 13 Capital gain or (loss). Attach Schedule D it required In required, check here ? . . 14 Other gains or (losses). Attach Form 4797 . . . . . . . . . . . . . . . . . . . . . . . . . 15a IRA distributions . . . . . b Taxable amount (sea page 25) 16a Pensions and annuities b Taxable amount (see page 26) 17 Rental real estate, royalt1e5,,.partner§tj7?COrporations, trusts, etc. Attach Schedule E . . . 18 Farm income or (loss). ;EF>hedule F 19 Unemployment comolilation :. . . . . . . . . • . . . . . . . . . . . . • . . 20a Social security benef;;i, 20b Taxable amount (see page 27) 21 Other income..:::: 9a 10 11 12 13 14 15b 16b 17 18 19 20b 1 • lived with you • did not live with ) you due to divorce or separation (see page 20) Dependents on 6c not entered above Add numbers on lines above ? 9 1 1,056 - ------- L21 Adjusted Gross Income 22 Add;the am4ttsii tf1e#a;,', right column for lines 7 through 21. This is t 23 4 ro)i2r;fa)5 A fde14?4tjQ[?f 'ftach Form 8853 . . . . . . . 23 24 ,::; :,`:;;Main fhfSp356;expef55`f)1'reseroists, performing artists, and fieg;iy:goi7gtp;gfticials. At Form 2106 or 2106-EZ . . . . . 24 HeafEt ihwngi`9count deduction. Attach Form 8889 . . . . 25 Moving`r5??tses. Attach Form 3903 . . . . . . . . . . . . 26 27 OnoN- If of `self-employment tax. Attach Schedule SE . . . 27 >:.. 28 SelfY3ployed SEP, SIMPLE, and qualified plans . . . . . . 28 `:'>•.??:; , ...S.el#rtployed health insurance det?uction (see page 29) 29 `Q # ftalty on early withdrawal of savings 30 31a Alimony paid b Recipient's SSN ? 089-48-9893 31a 32 IRA deduction (see page 31) . . 32 33 Student loan interest deduction (see page 33) • . . . . . . 33 34 Jury duty pay you gave to your employer • . . . . . . . . . 34 N Domestic production activities deduction Attach Form 8903 . 35 Add lines 23 through 31 a and 32 through 35 . . • . . . . . . • . . hbbbb, Subtract line 36 from line 22. This is your adjusted gross income and Paperwork Reduction Act Notice, see page 80. total income . . ? ? 22 6.012 ............. 36 . . . . . ... . .? 37 EEA 45,781 6, 012 39,769 Form 1040 (2006) ti .'m 1040 (2006) CURTI S A RONEY 206-36-3745 Paoe2 38 Amount from line 37 (adjusted gross income) . . . . . . . . . . . . . . . . . . . d 38 3 9 , 7 6 9 Tax an 39a Check f You were born before January 2, 1942, Blind. )checked boxes Credits if: l 8 Spouse was born before January 2, 1942, 8 Blind. ) checked ? 39a Standard b if your spouse itemizes on a separate return or you were a dual-status alien, see pg 34 & check here ? 39b Deduction 40 Itemized deductions (from Schedule A) or your standard deduction (see left margin) r- f 0.: , 15 0 o le who Peo r41 Subtract line 40 from line 38 . . . • . • . • • • . • . • • • • • • • . • • • • . • • • • . 41 3 4 , 619 p checked any box on line 3 a or 39b or 42 If line 38 is over $112,875, or you provided housing to a person displaced by Hurricane Katrina, see page 36. Otherwise, multiply $3,300 by the total number of exemptions claimed on line 6d ._... 42 3 , 3 0 0 who can claimed as s a 43 Taxable income. Subtract line 42 from line 41. If line 42 is more than line 41, enter -0- 43 31,319 dependent, 34 44 Tax (see page 36). Check if any tax is from: a ? Form(s) 8814 b ? Form 4972 . . . 44 4 , 2 8 3 . see page r th 45 Alternative minimum tax (see page 39). Attach Form 6251 . . • . . . . . . . . . . . . . 45 e s: • All o le or Sin 46 Add lines 44 and 45 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ? 46 4 , 2 8 3 g Married filing 47 Foreign tax credit. Attach Form 1116 if required . . . . . . . 47 separately, 150 $5 48 Credit for child and dependent care expenses. Attach Form 2441 • . . . 48 , 49 Credit for the elderly or the disabled. Attach Schedule R . . . 49 Married filing jointly or 50 Education credits. Attach Form 8863 . . .. . . . . . . . . . 50 Qualifyln idow(er? 51 Retirement savings contributions credit. Attach Form 8880 . . . 51 w $10,300 52 Residential energy credits. Attach Form 5695 . . . . . . . . . 52 Head of 53 Child tax credit (see page 42). Attach Form 8901 if required 53 household, 54 Credits from: a Form 8396 b Form B839 C Form 8859. 54 $7,550 55 i C'tt18r creel ts. a Form 3800 b Form 8601 c Form 8 55 56 Add lines 47 through 55. These are your total credits . . . . . . .. ;. 56 57 Subtract line 56 from line 46. If line 56 is more than line 46, enter •0 '<ti'". .'r:,; . "`? 57 4 , 2 8 3 58 Self-employment tax. Attach Schedule SE . . . . . . . . . . . . . . . Oth 58 er 59 Social security and Medicare tax on tip income not reported to emplojtrar'orm 4137 T 59 axes 60 Additional tax on IRAs, other qualified retirement plans, etc.,:ktf&tC13R[m`53c? 11jequired 60 61 Advance earned income credit payments from Form(s) W.,* box 61 62 Household employment taxes. Attach Schedule,H.,,#=:,:;. r' • • • • • • • • • 62 63 Add lines 57 through 62. This is your total tblti>s<z:'•`•,+ ;';'x'' ? 63 4 , 2 8 3 Payments 64 Federal income tax withheld from Forms W-0 W and 1099 ;:;. . . 64 61 269 X65 2006 estimated tax payments and amount applied frdi?ifl05 return Ei;•ir,4 • 65 If you have a qualifying 66a Earned income credit (EIC) . 66a child, attach b Nontaxable combat pay election . . ? 66b Schedule EIC.F67 Excess social security and tier 1 RRTA tax withheld (see page 6i))"'"'"' ' 67 68 Additional child tax credit. Attach Fprm 8812 . . • . • . . . . 68 69 Amount paid with request for &Xtf tt5ion to file (see page 60) 69 70 Payments from: a ? Form 24 %i!Iji Form, 4136 c Form 8885 70 71 Credit for federal telephone excise;W,paid. A12C4i?0p3 if required 71 30 72 Add lines 64, 65, 66a, 40 QUgh 71'' These are your total pay ment s ? 72 6 , 2 9 9 Refund 73 If line 72 is more than line 6S;;S lbtract li 16...: ,JJ W line 72. This is the amount you overpaid . . . . . 73 2 , 0 16 Direct deposit? 74a Amount of line 73 y6ixiau+ t.,, refund to you. If Form 8888 is attached, check here ? 74a 2 , 016 See page 61 ? b Routing number:;::::::::., ``>'.;;:;• 0 7 6 1 5 0 0-c Type: X Checking Savings and till in ? d Account nulrik 0 6 2 8 2 6 4 7bc, and 744dd, , or Form 6888. 75 Amc3ltAt of ;ire ou:Wfetiti ylled to your 20,07 estimated tax ? 75 .,, Amount 76 A'fi#frurkt you<ti # ..t ct line 72 from line 63. For details on how to pay, see page 62 ? 71 You Owe 77 V, see page 62) 77 Third party uo yot??? t to 8110 Fia Qther person to discuss this return with the IRS (see page 63)? U Yes. Complete the following. U No Designee ''tee's n2A3i•`:;:;. Phone no. Personal Identification _ 'i'lwATFREl?ITCOMB ?717-766-9477number(PIN) ? 1 0 2 `51gn Under penal W.-Of perjury, I declare that I have exam ,d this return and accompanying schedules and statements, and to the best of my knowledge and Here belief, they afgle, correct, and complete. Declaration of preparer (other than taxpayer) is based on all information of which preparer has any knowledge. Joint return? `' 'iiQur signaturgi r Date Your occupation Daytime phone number seepage)?. 03-IS-2007 SECURITY o Keep a COPY Spouse's signature. If a joint return, both must sign. Date Spouse's occupation your ,., 717-766--2772 ecords. HOUSEWIFE Paid Prepare Is Deta eck it Preparer's SSN or PTIN F-C-h Pr r s signature ALFRED WHIT COMB 3- 2 0- 2 0 0 7 f-employed sparer X 176-34-8948 Use Only Firm's name (or Whitcomb Tax and Financial Services EIN 23-1943547 add r you If selfemployecl), reesss,, and and ZIP ZIP code ca k43 West Main Street add EEA Mechanicsburg PA 17055-6262 Phoneno. 717-766-9477 _ f-1 /?nnOC/-'TCn /: ..M nnl.oi-11 Schedules A&B (Form 1040) 2006 OMB No. 1545-0074 Page 2 Name(s) shown on Form 1040. Do not enter name and social security number if shown on page 1. CURTIS A RONEY 1 Your social security number 206-36-3745 Schedule B-Interest and Ordinary Dividends Attachment Sequence No. 08 1 List name of payer. If any interest is from a seller-financed mortgage and the Amount Part I buyer used the property as a personal residence, see page B-1 and list this Interest interest first. Also, show that buyer's social security number and address ? (See page B-1 and the instructions for CITIZENS BANK 3 , 6 9 3 Form 1040, line 8a.) 1 If ou Note y . received a Form 1099-INT, Form OID , or 1099- substitute statement from a brokerage firm, list the firm's name as the payer and enter the total interest - shown on that 2 Add the amounts on line 1 . . . . . . . . . . . . . . . . . .. 2 3 , 6 9 3 form. .MW 3 Excludable interest on series EE and I U.S. savings bonds issua4r 1989:1,;sr Attach Form 8815 . . . . . . . . . . . . . . . . . ......>.•,•.•'•.`•>:?::<:x:::#' 3 4 Subtract line 3 from line 2. Enter the result here and on For} <E i;)ine'8 <;# ;, . ? 4 3 , 6 9 3 Note: If line 4 is over $1,500, you must complete Part III. Amount 5 List name of payer 11, Part I I Ordinary MELLON INVESTOR SER ':`: `CES 34 Dividends MELLON INVESTOR SER'•.`•.CES 38 (See page B-1 CITIZENS INVESTMENT<,'`RVICE 984 and the instructions for Form 1040 , line 9a.) Note. If you 5 received a Form 1099-DIV or substitute statement from a brokerage firm, list the fi m's r name as the payer and enter th e ordinary dividends shown ; on that form. Add i;Mi?j ounts on line 5. Enter the total here and on Form 1040, line 9a ? 6 ( 1 , 0 5 6 Note..;},e 6 is over $1,500, you' ust complete Part III. Part III You mU plete this part if you (a toad over $1,500 of taxable interest or ordinary dividends; or (b) had Yes No Forei <'`•'?<forei t1ount; or (c) received a distribution from, or were a grantor of, or a transferor to, a foreign trust. t.,. A# any time during 2006, did you have an interest in or a signature or other authority over a financial Accounts and Trusts account in a foreign country, such as a bank account, securities account, or other financial account? See page B-2 for exceptions and filing requirements for Form TD F 90-22.1 . . . . . . . . . • . • . . . • • X ? b If "Yes," enter the name of the foreign country (See page B-2.) 8 During 2006, did you receive a distribution from, or were you the grantor of, or transferor to, a ? V foreign trust? If "Yes," you may have to file Form 3520. See page B-2 For paperwork Reduction Act Notice, see Form 1040 instructions. EEA Schedule B (Form 1040) 2006 This infonnabon is being fumished to the Internal Revenue Seim. If you are required to file a tax return, a negllgenee penalty or other wnobon may be imposed on you d this Income Is taxable and you 1W to report tt Form W-2 Wage and Tax Statement 2110 6 7 Social security tips 1 Wages, lips, other compensation 410 i l.88 2 Federal income tax withheld 6268.93 c Employer's name, address, and ZIP code 8 Allocated tips 3 Social Security Wages 4 Social security tax withheld 43244.56 2681.16 CUMBERLAND COUNTY 9 Advanced EIC payment 6 Medicare wages and tips 6 Medicare tax withheld 1 COURTHOUSE SQUARE 43244.56 627.05 CARLISLE PA 17013 10 Dependent care benefit 11 Nonqualified plans 2Siuction s for box 12 ' e Employee's name, address, and ZIP code 13 L 14 Other X UC 39.91 CURT I S A. RONEY b Employer identification number OPT 5 2. 0 0 L 800 W KELLER ST 23-6003119 RETIR 2212.68 d Employee's social security number 11 22dd MECHANICSBURG PA 17055 206-36-3745 VWIN41140"Wm -woo Is State Employer's Slate ID number 16 State wages, lips, etc. 17 State income tax 18 Local wages, tips, etc. 19 Local income tax 20 Locality name PA 23-6003119 43244.56 1327.62 43244.56 735.19 COM Copy C For EMPLOYEE'S RECORDS (See Notice to Employee on back of Copy B.) ofy19 No. 15454006 Dept. of the Treasury • IRS 4 PLAINTIFF'S EXHIBIT 10- - 7 VS a NAME NUMBER PERIOD - CHECK NO CHECK DATE EXEMPTIONS/ FILING STATUS RONEY, CURTIS A. 4490 09/16/2007-09/29/2007 1 00267744 10/05/2007 1 Staieal 8 i ? Sinp e DESCRIPTION HOURS RATE AMOUNT YTD AMOUNT TYPE DESCRIPTION AMOUNT YTD AMOUNT REGULAR 64.00 20.47 1,310.08 29,086.68 TAX FICA IVIED 24.69 506.55 E SICK OLD 16.00 20.47 327.52 1,050.04 D TAX FICA SS 105.55 2 165.94 A OT60 3.50 31.60 110.62 515.80 E TAX FWT 245.18 , 5,115.71 R OTHOL 2,172.36 D TAX LWT 28.94 593.89 N VACATION 1,300.48 u TAX UC 1.57 32.22 FUNERAL 802.80 TAX SWT 52.26 1,072.50 OVERTIME 782.73 TAX EMST 52 00 N SHOE 90.00 T PRETAX BUYUP EE 45.79 . 870.01 G SHIFT60 3.60 o PRETAX RET PRE 87.41 1,785.72 AFTERTAX UNDUE S 86 8 1 N F 1 .3 324.77 S AFTERTAX SUPPORT 3,930.91 A N D T A X E S ? TOTALS EARNINGS ? GROSS PAY TAXABLE PAY NET PAY DEDUCTIONS TAX PRETAX COMPANY AFTER TAX I THIS PERIOD U74822 1?615;Q2 _ 1 053.04 .19 _._133 2_ 103 79 YEAR-TO-DATE 35804.49 33148.76 17 568.60 _ V J D DESCRIPTION ACCOUNT AMOUNT YTD AMOUNT DESCRIPTION BALANCE DESCRIPTION BALANCE DESCRIPTION BALANCE c COMPTIME .00 e PERSONAL 16.00 u SICK OLD 1134.16 T E VACATION 299.00 D E P T D I S M E S - 1..V1V1ULIlL/'11VV VVVINI I PLAINTIFF'S EXHIBIT r- In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION 13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013 Phone: (717) 240-6225 AUGUST 6, 2007 Fax: (717) 240-6248 PAMELA S. RONEY Plaintiff ) vs. ) CURTIS A. RONEY ) Defendant ) Docket Number 05-3412 CIVIL PACSES Case Number 5 8 610 7.5 01 Other State ID Number Please note: All correspondence must include the PACSES Case Number. Income Statement THIS FORM MUST BE FILLED OUT AND YOU MUST PROVIDE DOCUMENTS TO SUPPORT ALL AMOUNTS PROVIDED IN THIS INCOME STATEMENT (If you are self-employed or if you are salaried by a business of which you are owner in whole or in part, you must also fill out the Supplemental Income Statement which appears below.) INCOME STATEMENT OF (Name) (PACSES Number) I verify that the statements made in this Income Statement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: Lit, Plaintiff or Defendant INCOME Employer: 6.? fi Address: aType of Work: Payroll Number: Pay Period (weekly, biweekly, etc): Gross Pay per Pay Period $ „ Itemized Payroll Deductions: Federal Withholding $ 7, FICA NTIFF'S Local Wage Tax EV3 State Income Tax HIBIT Mandatory Retirement Union Dues Health Insurance Other (specify) Net Pay per Pay Period: $ Form IN-008 Rev. 2 Service Type M Worker lD 21205 Income Statement (Continued) Other Income: Annuity Social Security Rents Royalties Unemployment Comp. Workers Comp. Employer Fringe Benefits Other Week Month Year (Fill in Appropriate Column) ytrt 174,-T"-r- .` P Interest -c rt IZ &N s $ $ $ 7 j' Dividends ?•4K`! 2 Z 9 g 2 Pension Distributions TOTAL INCOME $ PROPERTY OWNED Ownership* Description Value H W J Checking accounts z r,a. $' Savings accounts (? -t ? rr?s 8 n / ?f.6 , _ _ Medical Blue Shield Other Health/Accident Disability Income Dental Other Other w> Total $ INSURANCE Coverage* Company Policy No. H W C Hospital Blue Cross Stocks/bonds` Real Estate Other Credit Union PACSES Case Number 5 8 610 7 5 01 *H=Husband; W=Wife; J=Joint; C=Child Service Type M Page 2 of 3 Form IN-008 Rev. 2 Worker ID 21205 r, Income Statement (Continued) PACSES Case Number 586107501 SUPPLEMENTAL INCOME STATEMENT (You only need to complete the below portion if you are self-employed or if you are salaried by a business of which you are owner in whole or in part) (a) This form is to be filled out by a person (check one): ? (1) who operates a business or practices a profession, or ? (2) who is a member of a partnership or joint venture, or ? (3) who is a shareholder in and is salaried by a closed corporation or similar entity. (b) Attach to this statement a copy of the following documents relating to the partnership, joint venture, business, profession, corporation or similar entity: (1) the most recent Federal Income Tax Return, and (2) the most recent Profit and Loss Statement. (c) Name of business: Address and telephone number: (d) Nature of business (check one) ? (1) partnership ? (2) joint venture ? (3) profession ? (4) closed corporation ? (5) other (f) Annual income from business: (1) How often is income received? (2) Gross income per pay period: (3) Net income per pay period: _ (4) Specific deductions, if any: Service Type M Page 3 of 3 Form IN-008 Rev. 2 Worker ID 21205 r In the Court of Common Pleas of CuMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION 13 N. RANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013 Phone: (717) 240-6225 AUGUST 6, 2007 Fax: (717) 240-6248 PAMELA S. RONEY ) Docket Number 05-3412 CIVIL Plaintiff ) vs. ) PACSES Case Number 586107501 CURTIS A. RONEY ) Defendant ) Other State ID Number Please note: All correspondence must include the PACSES Case Number. Guidelines Expense Statement EXPENSE STATEMENT OF (Name) (Passes Number) I verify that the statements made in this Expense Statement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unworn falsification to authorities. Date: 0- Plaintiff or Defendants Instructions: Guidelines Expense Statement - This form should only be completed when: 1) You are requesting an adjustment to the amount of support pursuant to Rule 1910.16-5 because of unusual needs and unusual fixed obligations, other support obligations, medical expenses not covered by insurance, or any other relevant factors, or 2) You are requesting that the other party share in the following expenses pursuant to Rule 1910.16-6: child care expenses, health insurance premiums, unreimbursed medical expenses, private school tuition, summer camp, or other needs, or mortgage payment. You must provide documents to support all amounts provided in this Expense Statement Weekly Monthly Yearly ( Fill in Appropriate Column ) Mortgage (including real estate taxes and homeowner's insurance) or Rent $ $ $ Health Insurance Premiums Unreimbursed Medical Expenses: Doctor Dentist Orthodontist Hospital Medicine Special Needs (glasses, braces, orthopedic devices, therapy) Service Type M Form IN-008 Rev. 2 Worker ID 21205 Guidelines Expense Statement (Continued) PACSES Case Number 586107501 Weekly Monthly Yearly Child Care Private School Parochial school Loans/Debts Support of Other Dependents: Other child support Alimony payments Other: (Specify) Total $ $ $ Page 2 of 2 Form IN-008 Rev. Service Type M Worker ID 21205 r, E7_j7 FILE DIANE G. RADCLIFF, ESQUIRE 3448 Trindle Road, Camp Hill, PA 17011 Phone: 717-737-0100 Fax: 717-975-0697 E-mail: dianeradcliffCcomcast.net August 10, 2005 Richard C. Snelbaker, Esquire SNELBAKER Ft BRENNEMAN) P.C. 44 West Main Street Mechanicsburg, PA 17055 Re: Curtis A. Roney vs. Pamela S. Roney Cumberland County Divorce No. 05-3412 Dear Attorney Snelbaker: In order to work towards a negotiated settlement, we need to exchange certain documents. To assist in this regard, I prepared the enclosed preliminary Marital Estate Analysis (Table 2 of my Inventory). With regard to this Analysis, I offer you the following comments or make the following requests: 1. Documents: In the row marked "Comments" following each item entry I inserted entries which indicate documents I require to complete this form. Those items are preceded by a "W'. Please provide all documents preceded by a "* Husband to supply ..." 2. Appraisals or Other Valuation. In Table #2 you may find various references to decisions that need to be made regarding the appraisal or valuation of assets. With respect to each such asset, please advise me if you want an appraisal or other valuation of that asset. If an appraisal is requested, please provide me with the name of your suggested appraisers and your position regarding an joint appraisal and the sharing of costs. 3. Pensions: For each pension listed, please advise me if you want to distribute the pension(s) on an offset or deferred basis. If an offset basis is desired, please advise me if we can agree to use Mr. Leister to value the pension and share the cost of his services. /0-is-a1 vJ J r,N Page 2 Richard C. Snelbaker, Esquire Re: Curtis A. Roney vs. Pamela S. Roney August 10, 2005 4. Undisclosed Assets and Debts: If you are aware of any asset or debt that has not been listed, please supply me with all relevant information and documentation. 5. Erroneously Included Assets and Debts: If I have included any asset or debt that should not have been included, please advise me. I provided this Analysis to my client and requested that she provide me with her documentation. I will provide you with copies of that documentation upon my receipt. I trust that you will provide me with the documents/ responses requested herein on a voluntary basis within thirty (30) days of the date of this letter, being on or before September 9, 2005. Very truly yours, DIANE G. RADCLIFF, ESQUIRE DGR/dr Enclosure(s): Preliminary Marital Analysis cc: Pamela Roney File Transmitted by mail 11 .11 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CURTIS A. RONEY, NO. 2005-3412 Civil Term Plaintiff /Respondent PAGES NO. 586107501 V. CIVIL ACTION-LAW PAMELA S. RONEY, Defendant/ Petitioner IN DIVORCE INCOME AND EXPENSE STATEMENT OF PAMELA S. RONEY A. EMPLOYMENT INFORMATION: Employer: N/A DISABLED AND RECEIVING SSD -? B. INCOME: DESCRIPTION MONTHLY YEARLY Gross Income (Social Security Disability) $969.00 $11,628.00 Medicare Health Insurance Costs None None Net $969.00 $11,628.00 C. OTHER INCOME: DESCRIPTION WEEKLY MONTHLY YEARLY None $0.00 $0.00 $0.00 D. Monthly Expenses Summary DESCRIPTION MONTHLY Total Monthly Expenses $1,693.00 DEFEND. EXHIBIT - 1 - 10v5-67 ?f ?? E. MONTHLY EXPENSES -ITEMIZED DESCRIPTION MONTHLY AMOUNT COMMENTS HOME EXPENSES: Rent $248.00 Low income subsidized housirg; Amount based on income. With APL terminated the rent was reduced to $248.00 starting October 1, 2007. If APL reinstated the rent will increase to $403.00. Utilities Included in rent Cell Phone $40.00 Telephone/Cable TV/ Internet $112.00 TAXES: Per Capita/ Occupation Taxes $1.00 INSURANCE: Renter's Insurance Automobile Insurance $50.00 Life Insurance Health Insurance AUTOMOBILE EXPENSES: Payments Fuel $200.00 Maintenance and Repair $200.00 License and Registration $4.00 - 2 - DESCRIPTION MONTHLY AMOUNT COMMENTS MEDICAL EXPENSES NOT REIMBURSED BY INSURANCE: Doctor $30.00 Optical Dental $11.00 Hospital Medicine $120.00 Special Needs/Therapy, Etc. PERSONAL EXPENSES: Clothing $75.00 Food $400.00 Barber and Hair Dresser $40.00 Memberships $2.00 Other Personal Expenses CREDIT CARDS AND LOANS: Filed Bankruptcy - no credit cards balances MISCELLANEOUS EXPENSES: Newspapers/Magazines/Books $10.00 Entertainment TBD TBD based on affordability Vacations TBD TBD based on affordability Gifts TBD TBD based on affordability Legal Fees $150.00 Charitable Contributions TOTAL EXPENSES $1,693.00 - 3 - PART III. PROPERTY OWNED PROPERTY OWNED OWNERSHIP TYPE DESCRIPTION VALUE H W JT Checking Member's 1" Minimal - varies x Savings Member's 1St Minimal - varies x Credit Union Stocks/bonds Real Estate Other TOTAL 0.00 PART IV. INSURANCE INSURANCE INFORMATION COVERAGE TYPE COMPANY POLICY NO. H W C Hospital Medicare Part A 089489893 x Medical H's Highmark PPO ZAR105024309001 x Health Accident Disability Income Dental H's Delta Dental TBD x Vision Other-Specify *H=Husband; W=Wife; J=Joint; C=Child -4- PART V. SUPPLEMENTAL INCOME STATEMENT [ ] CHECK HERE IF NOT APPLICABLE (a) This form is to be filled out by a person: 0 ) Who operates a business or practices a profession, or (2) Who is a member of a partnership or joint venture, or (3) Who is a shareholder in and is salaried by a closed corporation or similar entity. (b) Attach to this statement a copy of the following documents relating to the partnership, joint venture, business, profession, corporation or similar entity (check block to indicate the document is attached): (1) The most recent Federal Income Tax Return. [ ] attached (2) The most recent Profit and Loss Statement. [ J attached (c) Name of Business: Business Address: Business Telephone: (d) Nature of Business (check one) [ ] 1. Sole Proprietorship [ ] 2. Partnership [ J 3. Joint Venture [ ] 4. Professional [ J 5. Corporation [ ] 6. Other (e) Name of accountant, controller or other person in charge of financial records: (f} Business Income: 1. Annual income from business: 2. How often is income received: 3. Gross income per pay period: 4. Net income per pay period: 5. Specify deductions, if any: N L.3 CJ # Co ,. .. ,:._5 ._ 'P'te' 'a J) r 1 ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania 586107501 0Original Order/Notice Co./City/Dist. of CUMBERLAND 05-3412 CIVIL O Amended Order/Notice Date of Order/Notice 10/18/07 O Terminate Order/Notice Case N u m ber (See Addendum for case summary) RE: RONEY, CURTIS A. Employer/Withholder's Federal EIN Number CUMBERLAND COUNTY C/O CONTROLLERS OFFICE 1 COURT HOUSE SQ CARLISLE PA 17013-3323 Employee/Obligor's Name (Last, First, MI) 206-36-3745 Employee/Obligor's Social Security Number 3915101526 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. $ 501.00 per month in current support $ 84 . oo per month in past-due support Arrears 12 weeks or greater? Dyes ® no $ 0. 00 per month in current and past-due medical support $ o . 0o per month for genetic test costs $ 0.00 per month in other (specify) for a total of $ 585.00 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: $ 135.00per weekly pay period. $ 270.00per biweekly pay period (every two weeks). $ 292.50 per semimonthly pay period (twice a month). $ 585. 00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S 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: Date of Order: o o ? J. ISLEY OLER, JR., 6UDGE DRO: R. J. SHADDAY Form EN-028 Rev. 1 Service Type M OMB No.: 0970-0154 Worker I D $ IATT 2• 135.00 585•x 12-+ ?? 2 ?0. 00 ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? if?hecke?i you are required to provide aopy of this form to your3mployee. If yoyr employee works in a state that is di erent fTrom the state that issued this order, a copy must be provi edd to your emp ogee even if the box is not checked. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3.* Reporting the Paydat&Date of Withholding. You must report the paydate/date of withholding when sending the payment. The paydate/date of withholding is the date on which amount was withheld fi-orn the employee's wases. 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: 2360031190 EMPLOYEE'S/OBLIGOR'S NAME: RONEY, CURTIS A. EMPLOYEE'S CASE IDENTIFIER: 3915101526 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employeelobligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of. 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 1 1. Submitted By: If you or your employee/obligor have any questions, DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 Service Type M by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 OMB No.: 0970-0154 Form EN-028 Rev. 1 Worker I D $ IATT f w ADDENDUM Summary of Cases on Attachment Defendant/Obligor: RONEY, CURTIS A. PACKS Case Number 586107501 Plaintiff Name PAMELA S. RONEY Docket Attachment Amount 05-3412 CIVIL$ 585.00 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 ?ifchecked, 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 Rev. 1 Service Type M Worker ID $IATT. OMB No.: 0970-0154 `m R ?;?? om' t ? ..r,f CURTIS A. RONEY, Plaintiff/Petitioner VS. PAMELA S. RONEY, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 05-3412 CIVIL TERM IN DIVORCE PACSES Case No: 586107501 ORDER OF COURT AND NOW to wit, this 10th day of July 2008, it is hereby Ordered that the Order for Alimony Pendente Life is terminated, effective July 9, 2008, with no balance due pursuant to the parties' Marital Settlement Agreement. This Order shall become final twenty (20) 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 Domestic Relations Section for a hearing de novo before the Court. BY THE COURT: lalc? J. esley Oler, DRO: R.J. Shadday xc: Petitioner Respondent Keith Brenneman, Esq. Diane G. Radcliff, Esq. Service Type: M J. Form OE-001 Worker: 21005 t.'? ra :: c. c_ t_.. S ?..! ? Y+i t i? ?--?°? ?? _. 4.•.r .?'.. }.?? l`•J ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 07/10/08 Case Number (See Addendum for case summary) Employer/Withholder's Federal EIN Number CUMBERLAND COUNTY C/O CONTROLLERS OFFICE 05-3412 CIVIL 0Original Order/Notice OAmended Order/Notice XOTerminate order/Notice OOne-Time Lump Sum/Notice Employee/Obligor's Name (Last, First, MI) 206-36-3745 Employee/Obligor's Social Security Number 3915101526 Employee/Obligor's Case Identifier 1 COURT HOUSE SQ (See Addendum for plaintiff names CARLISLE PA 17013-3323 associated with cases on attachment) Custodial Parent's Name (Last, First, MI) See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ o. oo per month in current child support $ 0.00 per month in past-due child support Arrears 12 weeks or greater? Dyes ® no $ 0.00 per month in current medical support $ 0.00 per month in past-due medical support $ 0.00 per month in current spousal support $ o. oo per month in past-due spousal support $ o. oo per month for genetic test costs $ 0.00 per month in other (specify) $ one-time lump sum payment for a total of $ 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: $ 0.00 per weekly pay period. $ 0. oo per semimonthly pay period $ 0.00 per biweekly pay period (every two weeks) REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. PA FIPS CODE 42 000 00 Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier)R SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. / i / z BY THE COURT: RE: RONEY, CURTIS A. (twice a month) o . 00 per monthly pay period. 0? t v" J. WESLEY OLER, JR., t JUbGE Form EN-028 Rev. 3 Service Type M OMB No.: 0970-0154 Worker ID $ IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If heck you are required to provide a opy of this form to your mployee. If yo r employee orks in a state that is diferent from the state that issued this or?er, a copy must be provi?ed to your employee even if tie 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.* Reporting the Paydate/Date of Withholding: You must report the paydate/date of withholding when sending the payment. The paydate/date of withholding is the date on which amount was withheld from the employee's wages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employeelobligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. 2360031190 THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : 0 THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR:[--] EMPLOYEE'S/OBLIGOR'S NAME:RONEY, CURTIS A. EMPLOYEE'S CASE IDENTIFIER: 3915101526 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: LAST KNOWN PHONE NUMBER: FINAL PAYMENT AMOUNT: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Antidiscrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (CCPA) 0 5 U.S.C. 1673 (b)); or 2) the amounts allowed by the State or Tribe of the employee's/obligor's principal place of employment. Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes, Social Security taxes, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is supporting another family and 60% of the disposable income if the obligor is not supporting another family.However, that 50% limit is increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State, you may deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section. Arrears greater than 12 weeks : If the Order Information does not indicate whether the arrears are greater than 12 weeks, then the employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of the CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amounts paid for health care premiums in determining disposable income and applying appropriate withholding limits. 10. Additional info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Send Termination Notice and other correspondence to: DOMESTIC RELATIONS SECTION 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 Rev. 3 Worker I D $ IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: RONEY, CURTIS A. PACKS Case Number 586107501 PACKS Case Number Plaintiff Name Plaintiff Name PAMELA S. RONEY Docket Attachment Amount Docket Attachment Amount 05-3412 CIVIL$ 0.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): ? 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) identified above in any health insurance coverage available through the employee's/obligor's employment. DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACKS Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? 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. Addendum Form EN-028 Rev. 3 Service Type M OMB No.: 0970-0154 Worker ID $IATT CURTIS A. RONEY, Plaintiff V. PAMELA S. RONEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3412 CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on July 6, 2005. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. 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: J?" `? 24d8 Curtis A. Roney LAW OFFICES SNELBAKER & BRENNEMAN, P.C. ?-=? :? X ? °'i"i ??.. ti.. ;' f.•" „?:. :-i 4'? CURTIS A. RONEY, Plaintiff V. PAMELA S. RONEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3412 CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree 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. 4. 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. Zoo Date: Curtis A. Roney LAW OFFICES SNELBAKER & BRENNEMAN, P.C. ?": °?., -. ;: -:r ra•,„ r °? r° ^ ?'=.. ?`` ; t - '?,? ? ?' ? `? , i i.:? - ('' CURTIS A. RONEY, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA PAMELA S. RONEY, Defendant NO. 05-3412 CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted. 3. 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. 4. 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: `7/-71p8 Pamela S. Roney LAW OFFICES SNELBAKER & BRENNEMAN, P.C. c:n CURTIS A. RONEY, V. Plaintiff PAMELA S. RONEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3412 CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on July 6, 2005. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. 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: 7 / 7 /a 9 Pamela S. Roney LAW OFFICES SNELBAKER & BRENNEMAN, P.C. ?.-,4 ?? , ???: : ``, -?-, rc- ?? -- - gym,; ..? ?r,, ., *? ?= ?_ r-_ ?' ? r.. Ci_ RTIS A. RONEY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COLINTY, PENNSYLVANIA V. NO. 05-3412 CIVIL TERM PAMELA S. RONEY, ; Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO: Prothonotary of Cumberland County: Please transmit the record, together with the following information, to the Court foz entry ofa divorce decree: L Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce I CoU, e. 2. Date and manner of service of Complaint: July 18, 2005 on Defendant by certified mail. restricted delivery (see Acceptance of Service filed August 2, 2005 herein). 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by the Plaintiff. July), 2008; by the Defendant. July 7, 2008. 4. Date of execution of Waiver of Notice in Section 3301(c) Divorce: by the Plaintiff. July 9. 2008, by the Defendant: July 7, 2008. 5. Related pending claims. None. SNELBAKF,R & BRENNEMAN, P. C. Date: July 14. 2008 Bv: Attorneys for Plaintiff LAW OFFICES SNELBAKER 8C BRENNEMAN, P.C. ??, ??:3 > ?'?'] 'i? ?? G.ti { ? Y ???{ f?' __ ?'v ?? ???. ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. CURTIS A. RONEY, Plaintiff VERSUS PAMELA S. RONEY, Defendant N O. 2005-3412 CIVIL DECREE IN DIVORCE AND NOW, :U 4 3l , ZOO IT IS ORDERED AND DECREED THAT CURTIS A. RONEY PLAINTIFF, AND PAMELA S. RONEY ARE DIVORCED FROM THE BONDS OF MATRIMONY. ,DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None. The parties Post-Nuptial Agreement dated July 9, 2008 is incorporated BY THE COURT: PROTHONOTARY but not merged into this Decree. ' i ? ? • s