HomeMy WebLinkAbout05-6280DANITA DURF, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
LEROY DURF, NO. 0 & CIVIL?fi66
Defendant IN DIVORCE
NOTICE TO DEFEND
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 the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is available in
the Office of the Prothonotary at the Cumberland County Court House, Carlisle,
Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYERS FEES OR EXPENSES BEFORE A DECREE OF DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
SAIDIS, SHUFF, FLOVyER & LINDSAY
SAIDIS
SHUFF, FLOWER
& LINDSAY
26 W. High Street
Carlisle, PA
Carol J. Lindsay, <
Supreme Court ID
26 West High' ree
Carlisle, PA 17013
717-243-6222
44693
DANITA DURF, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY. PENNSYLVANIA
V. CIVIL ACTION - LAW
NO. CIVIL 2005
LEROY DURF,
Defendant IN DIVORCE
COMPLAINT IN DIVORCE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. The Plaintiff is Danita Durf, an adult individual residing at 720 Sand Bank
Road, Mt. Holly Springs, Pennsylvania 17065.
2. The Defendant is Leroy Durf, an adult individual residing at 4075 Carlisle
Road, Gardners, Pennsylvania 17324.
3. The Plaintiff and Defendant both have been bona fide residents in the
Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this
Complaint.
4. The Plaintiff and Defendant were married on July 27, 1985 in Carlisle,
Cumberland County, Pennsylvania.
5. The parties separated on November 8, 2005.
6. There have been no prior actions of divorce or for annulment between the
parties in this or in any other jurisdiction.
7. Neither Plaintiff nor Defendant is in the military or naval service of the United
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATr0RNRYS•AT•LAW
26 W. High Street
Carlisle, PA
States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the
Congress of 1940 and its amendments.
8. The Plaintiff has been advised that counseling is available and that she has
the right to request that the court require the parties to participate in counseling.
9. The marriage is irretrievably broken and no possibility of reconciliation exists.
WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance
with §3301 of the Pennsylvania Divorce Code.
COUNT II - SUPPORT, ALIMONY PENDENTE LITE AND ALIMONY
10. The averments in paragraphs 1 through 9 are incorporated hereto as if fully
set forth herein.
11. Plaintiff requires reasonable support to adequately sustain herself with the
standard of living established during the marriage.
WHEREFORE, Plaintiff requests an award of Support, Alimony and Alimony
Pendente Lite.
COUNT III - ATTORNEY'S FEES AND COSTS
12. The averments in paragraphs 1 through 11 are incorporated hereto as if fully
set forth herein.
18. Plaintiff is unable to sustain herself during the course of this litigation and has
employed Carol J. Lindsay, Esquire, as counsel, but is unable to pay the necessary and
reasonable attorney's fees for said counsel, and the necessary and reasonable costs and
expenses.
WHEREFORE, Plaintiff, Danita Durf, prays this Honorable Court to enter judgment:
a. Awarding Plaintiff a decree in divorce
b. Awarding Plaintiff support, alimony and alimony pendente lite;
C. Awarding Plaintiff counsel fees, costs and expenses; and
d. Awarding such other relief as the Court deems just and reasonable.
SAIDIS
SHUFF, FLOWER
& LINDSAY
26 W. High Street
Carlisle, PA
SAIDIS, SNUFF, FL?YVVER & LINDSAY
Supreme C urt D No. 44693
26 West H(g treet
Carlisle, PA 17013
717-243-6222
VERIFICATION
I verify that the statements made in the foregoing document are true and
correct. I understand that false statements herein are made subject to the penalties
of 18 Pa_ C.S. §4904, relating to unsworn falsifications to authorities.
L 12
Danita Duff
Date;
SAIDIS
SHum FLOWER
& LINDSAY
ATrORNEYS•A7•LAW
26 W. High Street
Carlisle, PA
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DANITA DURF,
Plaintiff
V.
LEROY DURF,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. (,,)A U CIVIL 2005
IN DIVORCE
PETITION FOR ALIMONY PENDENTE LITE
AND NOW, comes Danita Durf, by and through counsel, SAIDIS, SHUFF, FLOWER &
LINDSAY, and petitions this Honorable Court as follows:
1. The parties hereto are husband and wife, having been joined in marriage on .
2. The parties separated on or about .
3. Petitioner is without the ability to earn income sufficient to meet her reasonable
needs and to pay attorney's fees.
WHEREFORE, Petitioner prays this Honorable Court to order alimony pendente lite in an
amount equal to the Pennsylvania State Support Guidelines and reasonable attorney's fees.
SAIDIS, SHUFF, FLOWER & LINDSAY
I
Supreme Cowt ? 0.44693
26 West High .St et
Carlisle, PA 17013
717-243-6222
SAIDIS
SHUFF, FLOWER
& LINDSAY
26 W. High Street
Carlisle, PA
DRS ATTACHMENT FOR APL PROCEEDINGS
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATTORNEYS•AT•EAW
26 W. High Street
Carlisle, PA
PETITIONER:
DOB:
DANITA DURF
ADDRESS:
PHONE:
SSN:
720 SAND BANK ROAD, MT. HOLLY SPRINGS, PA 17065
ATTORNEY: CAROL J. LINDSAY, ESQUIRE
PETITIONER'S EMPLOYMENT: HOME DEPOT
HOW LONG?
NET PAY: $8.50 PER HOUR
JOB TITLE: CASHIER
OTHER INCOME: (INCLUDEAMOUNTAND SOURCE)
RESPONDENT: LEROY DURF
DOB: SSN:
ADDRESS: 4075 CARLISLE ROAD, GARDNERS, PA 17324
PHONE:
ATTORNEY: KATHLEEN A. ENGLE, ESQUIRE
RESPONDENT'S EMPLOYMENT: PENNSY SUPPLY
HOW LONG?
NET PAY: $14.00 PER HOUR
JOB TITLE:
OTHER INCOME: (INCLUDEAMOUNTAND SOURCE)
WHEN MARRIED:
DATE SEPARATED:
17324
WHERE:
WHERE LAST LIVED TOGETHER: 4075 CARLISLE ROAD, GARDERS, PA
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DANITA DURF, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
NO. 05-6280 CIVIL
LEROY DURF,
Defendant IN DIVORCE
ACCEPTANCE OF SERVICE
i accept service of the Divorce Complaint on behalf of Defendant Leroy Durf and certify
that I am authorized to do so.
ABOM & KUTULAKIS
Kathleen A. Engle,`Esquire
36 South Hanover Street
Carlisle, PA 17013
Date:/
7 ?l?I ?U rj
SAIDIS
SHUFF, FLOWER
& LINDSAY
26 W. High Street
Carlisle, PA
DEC 14 M
C7 p
G,
DANITA A. DURF, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - DIVORCE
NO. 05-6280 CIVIL TERM
LEROY A. DURF, IN DIVORCE
Defendant/Respondent
PACSES # 246107936
ORDER OF COURT
AND NOW, this 4th day of January, 2006, 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 January 26, 2006 at 9:00 A.M. for a conference, at 13 N. Hanover St., Carlisle,
PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be
entered.
YOU are further ordered to bring to the conference:
(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
1910.110
(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,
Edgar B. Bayley, President Judge
Copies mailed on
January 4, 2006 to: Petitioner
Respondent
Carol J. Lindsay, Esquire
Date of Order: January 4. 2006 431v, onference 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
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ORDERINOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsylvania
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 01/26/06
Case Number (See Addendum for case summary)
Employer/Withholder's Federal EIN Number
PENNSY SUPPLY INC
1001 PAXTON ST
HARRISBURG PA 17104-1645
246107936
05-6280 CIVII,
O Original Order/Notice
O Amended Order/Notice
O Terminate Order/Notice
RE: DURF, LEROY A.
Employee/Obligor's Name (Last, First, MI)
_176-52-8231
Employee/Obligor's Social Security Number
3338101603
I mployee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on artachmenn
Custodial Parent's Name (Last, First, MF
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.
$ 548 . 00 per month in current support
$ o . oo per month in past-due support Arrears 12 weeks or greater? O yes ® no
$ o . oo per month in current and past-due medical support
$ o . 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 548. 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:
$ 126.46 per weekly pay period.
$ 252.92 per biweekly pay period (every two weeks).
$ 274, go per semimonthly pay period (twice a month).
$ 548. oo per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information i
needed (See #9 on page 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
Date of Order:JAN 2 ,1 1606
DRO: R.J. Shadday
Service Type M
BY THE COURT: l^?"
Edward E. Guid , Judge
Form EN-028
OMB No.: 0978-0154 Worker ID $IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
? If hecke? you are required to provide a copy of this form to your employee. If your employee works in a state that is
ch 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.*Repo dingthC ding- -Y rreri5enomgLilepayment. ine
is the date on w I. ich amount w as w thdreld from the ee`s-vvages.. You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/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: 2327294960
EMPLOYEE'S/OBLIGOR'S NAME: DURF, LEROY A.
EMPLOYEE'S CASE IDENTIFIER: 3338101603 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 0 5 U.S.C. §1673 01; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more
than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more
than the amounts allowed under the law of the state that issued the order.
10. Additional Info:
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
11. Submitted By: If you or your employee/obligor have any questions,
DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
Service Type M
by telephone at (717) 240-6225 or
by FAX at (717) 240-6248 or
by internet www.childsupport.state.pa.us
Page 2 of 2
OMB No 09700158
Form EN-028
Worker ID $IATT
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: DURF, LEROY A.
PACSES Case Number 246107936
Plaintiff Name
DANITA A. DURF
Docket Attachment Amount
05-6280 CIVIL$ 548.00
Child(ren)'s Name(s): DOB
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.
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.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren) ? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available identified above in any health insurance coverage available
through the employee's/obligor's employment. through the employee's/obligor's employment.
Addendum Form EN-028
Service Type M ID $IATT
OMB No.: 097"154 Worker
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DANITA A. DURF, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - DIVORCE;
NO. 05-6280 CIVIL TERM
LEROY A. DURF, IN DIVORCE
Defendant/Respondent
PACSES # 246107936
ORDER OF COURT
AND NOW, this 26th day of January, 2006, based upon the Court's determination that
Petitioner's monthly net income/eaming capacity is $1215.41 and Respondent's monthly net
income/earning capacity is $2470.57 it is hereby Ordered that the Respondent pay to the Pennsylvania
State Collection and Disbursement Unit, $548.00 per month payable monthly as follows: $548.00 for
alimony pendente lite and $0.00 on arrears. First payment due next pay date at $126.46 per week.
Arrears set at $ t096.00 as of January 26, 2006.
The effective date of the order is December 6, 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: Danita A. Durf. 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 Respondent's PACSES Member Number or Social Security
Number in order to be processed. Do not send cash by mail.
cc360
Unreimbursed medical expenses that exceed $250.00 annually are to be paid as follows 0% by
Respondent and 100% by Petitioner. The Petitioner is responsible to pay the first $250.00 annually in
unreimbursed medical expenses. The Petitioner to provide medical insurance coverage. Within thirty
(30) days after the entry of this Order, the Respondent shall submit to Petitioner written proof that
medical insurance coverage has been obtained or that application for coverage has been made. Proof
of coverage shall consist, at minimum, of: 1) the name of the health care coverage provider(s); 2) any
applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims
should be made; 5) a description of any restrictions on usage, such as prior approval for hospital
admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage
contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms.
The parties agree to hold collection on the retroactive arrears in abeyance.
The Defendant is to make weekly direct payments until the wage withholding order is
effective.
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
Petitioner's Attorney
Respondent Respondent's Attorney
DRO: R. J. Shadday BY THE COURT,
Mailed copies on: Petitioner
January 27, 2006 Respondent
Carol J. Lindsay, Esq.
Kara W. Haggerty, Esq.
Edward rdo, J,
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
DANITA A. DURF ) Docket Number 05-6280 CIVIL
Plaintiff )
vs. ) PACSES Case Number 246107936
LEROY A. DURF )
Defendant ) Other State ID Number
ORDER TO CREDIT ARREARS
AND NOW. on this 3RD DAY of FEBRUARY, 2006 IT IS HEREBY ORDERED
that credit be given on the above captioned case in the amount of $125.00 . There
® is O is not an agreement of the parties to the credit.
This credit is for:
® Direct Payments.
? Purchases made or services performed by the Defendant on behalf of the Plaintiff or
children.
? Time children resided with the Defendant as agreed upon by parties, or addressed in a
partial custody order for the following time periods:
From to
From to
From to
? Other:
PAID BY CHECK #439 AND DATED 1/27/06
Plaintiff
Defendant
FEB 0 G 2006
Date
Date
Date
BY THE COURT:
_;- I
JUDGE
Form FI-002
Service Type M Worker ID 21005
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PWh'-Ub-eea LJ:99 From:M-VLL LhHV HHbIM-M (I 009buul 1o:+1 rl tequbequ F'•e'e
0-08-01 DOM FRUKUberla'd Cuoty Duatitlt h1Q%j QAF 0TIMISUD T•00 P.OOIPoOi F-300
N`. 6S-(v a80 C1%/I1
C J31DERLAND COUNTYDOMESf[C RELATIONS
Da(c of APPikAuoe:,3[31 %P a Requa k for Supparz Reeord 3 sarch
Name:
Address: z v ID I,
Social Security Number r
DomesdeReladoes Case Nam
Puny Requarting kl'oemadom
bajVa- Q' b W - ! ?c JQ %+Xz ?Qhl73LS
Qhs Nomb") (aiavatarp)
A Twenty Dallis (920-00) Yee it Due per SucW Sco°rity Number C?(LT
Make cheek or taaaey order paya63e to: DRS/um Search ZC?-7 (Y
X INmAL REQUEST
_ Hat as Record in Damesdo Relations a oP.
Supptut Arrems asofPsd of Mcoth Prior to Date of pPliw' : E 170. 1 _
lYlnrrthly Total Suppon Obligation; E . 00
The Aotamc abown eboro is roRwted in the Domestic Relations Section Office of
Cumberland Cowety, Paoartylvad L w e vv\ b e: 4k 3?, :)? I 0 I L,? 0 3
Domestic FWatious Case Number. P(lC o C $? 2 4 to 10 I q36
%ice seam caadiamod IAW)
BRING-DOWN REQUEST
SupowtATrems: $ As OF
(Des)
Biped: _
(Elea GOpTdlaetor) (Uaz=)
° ¦• Lien Satisfisfection Rocci'pt AvWablc Upon Rcquest***
CC720
M R-M-E C 09:30PM From: +171724062ge IMAPPLE LEW FS(3STRWT Paw4FM3 R--%N
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LIEN SATISFACTION
Name: Lerov Durf
Member Number: 3338101603
Judgment Lien Satisfied as of: 3/14/06
Amount Paid: $ 170.11
Signed: `t,&c fix '--u
?
,(Lien Coordinator)
Pacses# 246107936
No. 05-6280 Civil
DR#
MAR 17 2006
(Date)
CC722
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CUMBERLAND COUNTY DOMESTIC RELATIONS
Date of Application: 3 i/ h Request for support Record Search
Name: Zel-0 y 17
(Last) (First) (MI)
Address:
Social Security Number: f 7(v ' j - ?a / D.O.B.:
Domestic Relations Case Number, if known:
Party Requesting Information: 3 /?c c
-/i7 aYy oU30 S , tt -5
(Telephone Nmnber) Address)
117-
(Fax Number) (r nature)
A Twenty Dollar ($20.00) Fee is Due per Social Security Number
Make check or money order payable to : DRS/Lien Search
INITIAL REQUEST
Has No Record in Domestic Relations as of:
(Date)
Support Arrears As of End of Month Prior to Date of Application: $ Q'20
Monthly Total Support Obligation: $ S`f8. 00 IrrtonfA
The Amount shown above is reflected in the Domestic Relations Section Office of Cumberland
County, Pennsylvania. p M e- ty, 1_ off 3381 Q (i0 o3
Domestic Relations Case Number: I Qrs Q5 ?Ja y(? ? ? ? y 3 (?
?? (eti y?3?010
Signed: _Il"L
(Lien Search Coordinator) (Date)
BRING-DOWN REQUEST
Support Arrears: $ As Of:
(Date)
Signed:
(Lien Coordinator) (Date)
***Lien Satisfaction Receipt Available Upon Request***
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DANITA DURF,
Plaintiff
VS.
LEROY DURF,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA
NO. 05-6280 CIVIL TERM
IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
Leroy Durf, Defendant, moves the Court to appoint a Master with respect to the following
claims:
[ x ] Divorce [ x ] Distribution of Property
[ ] Annulment [ x ] Support
[ x ] Alimony [ ] Counsel Fees
[ ] Alimony Pendente Lite [ ] Costs and Expenses
and in support of the Motion the Defendant states:
1. Discovery is complete as to the claim(s) for which the appointment of a Master is requested.
2. The Plaintiff has appeared in the action by her attorney, Carol Lindsay, Esquire.
3. The statutory ground(s) for the divorce are: 3301(a) (2), 3301(c), and 3301(d).
4. Delete the inapplicable paragraphs:
a. The action is contested with respect to the following claims: Alimony, Alimony
Pendente Lite, and distribution of property
5. The action does not involve complex issues of law or fact.
6. The hearing is expected to take one day.
7. Additional information, if any, relevant to the motions: None
DATE ZL ?/ 0 ?o i,I,71Zf^E?j4
?,rl?ara W. Haggerty
Attorney for Plaintiff
AND NOW, 2006, Esquire, is appointed
Master with respect to the following claims:
BY THE COURT,
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c_ ? om
DANITA DURF,
Plaintiff
VS.
LEROY DURF,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA
NO. 05-6280 CIVIL TERM
IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
claims:
Leroy Durf, Defendant, moves the Court to appoint a Master with respect to the following
[ x ] Divorce
[ ] Annulment
[ x ] Alimony
[ ] Alimony Pendente Lite
[ x ] Distribution of Property
[ x ] Support
[ ] Counsel Fees
[ ] Costs and Expenses
and in support of the Motion the Defendant states:
Discovery is complete as to the claim(s) for which the appointment of a Master is requested.
2. The Plaintiff has appeared in the action by her attorney, Carol Lindsay, Esquire.
3. The statutory ground(s) for the divorce are: 3301(a)(2), 3301(c),and 3301(d).
4. Delete the inapplicable paragraphs:
a. The action is contested with respect to the following claims: Alimony, Alimony
Pendente Lite, and distribution of property
5. The action does not involve complex issues of law or fact.
6. The hearing is expected to take one day.
7. Additional information, if any, relevant to the motions: None
DATE ` ZI 9?0 Co ?"
.J;,1,fa.ra W. Haggerty
Attorney for Plaintiff
AND NOW, Wage -,2A 2006, _ e '7? Esquire, is appointed
Master with respect to the following claims: A'a-,
BY THE
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DANITA DURF, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNA
VS. NO. 05-6280 CIVIL TERM
LEROY DURF,
Defendant IN DIVORCE
MOTION TO DISMISS DIVORCE COMPLAINT
AND NOW, comes the above-captioned Defendant, by and through its counsel, Kara W.
Haggerty, Esquire, of ABOM & KUTUALKIS, L.L.P., and respectfully moves This Honorable
Court to dismiss the above-captioned divorce complaint, and in support thereof avers the
following:
1. On or about December 6, 2005, Plaintiff filed this divorce action for irreconcilable
differences. (See copy attached as Exhibit "A").
2. On or about May 19, 2006, Defendant motioned the Court for appointment of Master.
(See copy attached as Exhibit `B").
3. On or about June 9, 2006, Plaintiff informed Divorce Master that she does not want to
proceed with the divorce. (See copy attached as Exhibit "C").
4. It is believed and therefore averred that Plaintiff is withholding consent on the
Divorce action that she filed so that she may receive alimony pendente lite and
control the proceedings.
5. In Rueckert v. Rueckert, 20 Pa. D. & C.3d 191, the Court held that that a party should
not be allowed to withhold consent while simultaneously seeking alimony pendente
lite.
6. In Hoffman v. Hoffinan, 350 Pa. Super. 280,504 A.2d 356 (1986), the Court held that
the reasoning of the Rueckert court was sound.
7. Under the reasoning of Rueckert and Hoffinan, the Plaintiff cannot simply file a
complaint in order to obtain alimony pendente lite and then refuse to proceed with the
action.
8. Based on the letter from the Plaintiff to the Master that is attached as Exhibit "C," the
Plaintiff in this case is using her complaint to obtain alimony pendente lite and has
refused to proceed with the action.
WHEREFORE, Defendant respectfully moves This Honorable Court to dismiss the
above-captioned divorce action, and to terminate the award of Alimony Pendente Lite.
Date: VIP Zq DIP
ABOM & KUTULAKIS, L.L.P.
out_ H-(cq.
Kara W. Haggerty uire
Attorney I.D. No. 86914
36 South Hanover Street
Carlisle, PA 17013
(717) 249-0900
Attorney for Defendant
DANITA DURF, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
NO. CIVIL 2086
LEROY DURF, (v
Defendant IN DIVORCE
NOTICE TO DEFEND
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 the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is available in
the Office of the Prothonotary at the Cumberland County Court House, Carlisle,
Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYERS FEES OR EXPENSES BEFORE A DECREE OF DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
SAIDIS, SHUFF, FLOVIJ,E , & LINDSAY
SAIDIS
SHUFF, FLOWER
& LINDSAY
A/1UA F.10-Al•L.AW
26 W. High Street
Carlisle, PA
Carol 1. Lindsay,
Supreme Court ID
26 West Hig ` reE
Carlisle, PA 17013
717-243-6222
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4uire
o.44693
DANITA DURF,
Plaintiff
V.
LEROY DURF,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. CIVIL 2005
IN DIVORCE
COMPLAINT IN DIVORCE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. The Plaintiff is Danita Durf, an adult individual residing at 720 Sand Bank
Road, Mt. Holly Springs, Pennsylvania 17065.
2. The Defendant is Leroy Durf, an adult individual residing at 4075 Carlisle
Road, Gardners, Pennsylvania 17324.
3. The Plaintiff and Defendant both have been bona fide residents in the
Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this
Complaint.
4. The Plaintiff and Defendant were married on July 27, 1985 in Carlisle,
SAIDIS
SHUFF, FLOWER
26 W. High Street
Carlisle, PA
Cumberland County, Pennsylvania.
5. The parties separated on November 8, 2005.
6. There have been no prior actions of divorce or for annulment between the
parties in this or in any other jurisdiction.
7. Neither Plaintiff nor Defendant is in the military or naval service of the United
States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the
Congress of 1940 and its amendments.
8. The Plaintiff has been advised that counseling is available and that she has
the right to request that the court require the parties to participate in counseling.
9. The marriage is irretrievably broken and no possibility of reconciliation exists.
WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance
with §3301 of the Pennsylvania Divorce Code.
COUNT II - SUPPORT, ALIMONY PENDENTE LITE AND ALIMONY
10. The averments in paragraphs 1 through 9 are incorporated hereto as if fully
set forth herein.
11. Plaintiff requires reasonable support to adequately sustain herself with the
standard of living established during the marriage.
WHEREFORE, Plaintiff requests an award of Support, Alimony and Alimony
Pendente Lite.
COUNT III - ATTORNEY'S FEES AND COSTS
12. The averments in paragraphs 1 through 11 are incorporated hereto as if fully
set forth herein.
18. Plaintiff is unable to sustain herself during the course of this litigation and has
employed Carol J. Lindsay, Esquire, as counsel, but is unable to pay the necessary and
reasonable attorney's fees for said counsel, and the necessary and reasonable costs and
expenses.
WHEREFORE, Plaintiff, Danita Durf, prays this Honorable Court to enter judgment:
a. Awarding Plaintiff a decree in divorce
b. Awarding Plaintiff support, alimony and alimony pendente lite;
C. Awarding Plaintiff counsel fees, costs and expenses; and
d. Awarding such other relief as the Court deems just and reasonable.
SAIDIS
SHUFF, FLOWER
26 W. High Street
Carlisle, PA
SAIDIS, SHUFF, FLJD%ER & LINDSAY
Cd'fof:J. Linea ,'Esquire
D No. 44693
Supreme C u2reet
26 West H(g?j. Carlisle, PA 17013
717-243-6222
VERIFICATION
I verify that the statements made in the foregoing document are true and
correct. I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S. §4904, relating to unsworn falsifications to authorities.
Q? k-,k i - dJ-11'-
Danita Durf
Date:
SAIDIS
SHUFF, FLOWER
Pa T.MMqAV
26 W. High Street
Carlisle, PA
4'711n
DANITA DURF,
Plaintiff
vs.
LEROY DURF,
Defendant
IN THE COURT OF COMMON P
CUMBERLAND COUNTY, PENIAA.
NO. 05-6280 CIVIL TERM IN DIVORCE
MOTION TOR APPOINTMENT OF MASTER
Leroy Durf, Defendant, moves the Court to appoint a Master with respect to the following
claims:
[ x ] Divorce [ x ] Distribution of Property n C=3
[ ] Annulment ` ?
[ x ] Support [ x ] Alimony [ ] Counsel Fees
[ ] Alimony Pendente Lite [ ] Costs and Expenses, j
and in support of the Motion the Defendant states:
71
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1. Discovery is complete as to the claim(s) for which the appointment of a Master is requested-
2. The Plaintiff has appeared in the action by her attorney, Carol Lindsay, Esquire.
3. The statutory ground(s) for the divorce are: 3301(a)(2), 3301(c), and 3301(d).
4. Delete the inapplicable paragraphs:
a. The action is contested with respect to the following claims: Alimony, Alimony
Pendente Lite, and distribution of property
5. The action does not involve complex issues of law or fact.
6. The hearing is expected to take one day.
7. Additional information, if any, relevant to the motions: None
DATE
{s? ra W. Haggerty
ttorney for Plaintiff
AND NOW, 2006, P&A , Esquire, is appointed
Master with respec o the following claims:
A 111
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LAW OFFICES
JOHN E. SLIKE
ROBERT C. SAIDIS
JAMES D. FLOWER, JR
CAROL J. LINDSAY
MICHAEL L. SOLOMON
BRIAN C. CAFFREY
GEORGE F. DOUGLAS, III
THOMAS E. FLOWER
MARYLOU MATAS
SUZANNE C. HIXENBAUGH
SAIDIS, FLOWER & LINDSAY
A PROFESSIONAL CORPORATION
26 WEST HIGH STREET
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486
EMAIL: attorney@sfl-law.com
www.sfl-law.com
June 9, 2006
E. Robert Elicker, II, Esquire
Office of Domestic Relations
9 North Hanover Street
Carlisle, PA 17013
Re: Durf v. Durf
Dear Mr. Elicker:
CAMP HILL OFFICE:
2109 MARKET STREET
CAMP HILL, PA 17011
TELEPHONE: (717)737-3405
FACSIMILE: (717)737-3407
REPLY TO CARLISLE
Kara Haggerty filed a Motion for the Appointment of a Master on May 19, 2006 in the
captioned case. The parties have been separated, however, only since November 8, 2005.
Mrs. Durf, my client, does not with to proceed to divorce at the present time.
Very truly yours,
SAIDIS, FLOWER &
Carol J
CJL/bes
cc: Kara Haggerty, Esquire
Danita Durf
CERTIFICATE OF SERVICE
AND NOW, this Z-q day of June, 2006, I, Kara W. Haggerty, Esquire, of Abom &
Kutulakis, L.L.P., hereby certify that I did serve a true and correct copy of the foregoing Motion to
Dismiss upon Carol Lindsay, Esquire, Attorney for Plaintiff, by mail at the following:
Carol Lindsay, Esquire
Sa& s, Flower & Lindsay
26 West High Street
Carlisle, PA 17103
Date: Db '1 ),p?a
Respectfully submitted,
Abom & Kutulakis, L.L.P.
Kara W. Haggerty q ' e
Attorney I.D. 1, 4
36 South Hanover Street
Carlisle, PA 17013
(717) 249-0900
Attorney for Defendant
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DANITA DURF, IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
LEROY DURF,
DEFENDANT 05-6280 CIVIL TERM
ORDER OF COURT
AND NOW, this ? -day of July, 2006, a Rule is entered against
plaintiff, Danita Durf, to show cause why her complaint in divorce should not be
dismissed. Rule returnable fifteen (15) davs after service.
Carol Lindsay, Esquire
For Plaintiff
Kara W. Haggerty, Esquire
For Defendant
/1u.`d 7' - 04
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tagar b. bayiey, J.
t.
DANITA DURF,
Plaintiff
V.
LEROY DURF,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 05-6280 CIVIL
IN DIVORCE
ANSWER TO MOTION TO DISMISS DIVORCE COMPLAINT
AND NOW, comes Danita Durf by and through her counsel, Saidis, Flower & Lindsay,
and answers the Motion to Dismiss Divorce Complaint as follows:
1. Admitted.
2. Admitted.
3. Admitted.
4. Denied. Plaintiff withheld her consent to the divorce to allow sufficient time to
permit her to obtain an apartment and to deal emotionally with the issues involved in her
separation. She is now ready to proceed through the Divorce Master's process and to obtain a
Decree in Divorce.
5. No answer required.
6. No answer required.
7. No answer required.
SAMIS,
FLOWER St
LEEDS"
26 West High Street
Carlisle, PA
8. Denied that Plaintiff is using her Complaint to obtain alimony pendente lite. As
more particularly set out above, she is prepared to proceed with the divorce. A copy of a letter
to the Divorce Master and her certification that discovery is complete is attached hereto.
WHEREFORE, Respondent prays this Honorable Court to dismiss the Motion to
Dismiss the Divorce Complaint.
SAIDIS, FLOWER & LINDSAY
Supreme Court[D jIb. 44693
26 West High S t
Carlisle, PA 17013
717-243-6222
Dated: -? 2VI67 p
SAIDIS,
FLOWER &
LINDS"
26 West High Street
C lisle, PA
LAW OFFICES
JOHN E. SLID
ROBERT C SAIDIS
JAMES D. FLOWER, JR
CAROL J. LINDSAY
MICHAEL, L. SOLOMON
BRIAN C CAFFREY
GEORGE F. DOUGLAS, III
THOMAS E. FLOWER
MARYLOU MATAS
SUZANNE C. HIXENBAUGH
SAIDIS, FLOWER & LINDSAY
A PROFESSIONAL CORPORATION
26 WEST HIGH STREET
CARLISLE, PENNSYLVANIA 17013
TELEPHONE (717) 243-6222 - FACSIMILE: (717) 243-6486
EMAIL: attorney®sfl-law.com
www.sfl-law.com
July 20, 2006
E. Robert Elicker, II, Esquire
Office of Domestic Relations
9 North Hanover Street
Carlisle, PA 17013
Re: Durf v. Durf
No. 05-6260 Civil
Dear Mr. Elicker:
CAMP HILL OFFICE:
2109 MARKET STREET
CAMP ILL, PA 17011
TELEPHONE: (717)737-3405
FACSIMILE: (717)737-3407
REPLY TO CARLISLE
I represent Danita Durf who was, heretofore, unwilling to proceed with divorce.
However, Danita has obtained an apartment for herself and her situation has stabilized so that
she believes she can go forward. I enclose a Certification of Discovery.
Very truly yours,
CJUbes
Enclosure
cc: Kara Haggerty, Esquire
Danita Durf
SAIDIS, FLOWER & LINDSAY
&f'
Carol J. Lindsay, re
DANITA DURF,
Plaintiff
VS.
LEROY DURF,
Defendant
TO: Carol J. Lindsay
Kara W. Haggerty
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05 - 6260 CIVIL
IN DIVORCE
, Attorney for Plaintiff
, Attorney for Defendant
DATE: Wednesday, June 7, 2006
CERTIFICATION
[ x I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a; Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
DATE
NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
I, Carol J. Lindsay, attorney for Plaintiff, Danita Durf, verify that the statements made
SAIDIS,
FLOWER 6z
LINDSAY
26 West High Street
Carlisle, PA
in the foregoing document are true and correct and certify that I am authorized to do so, and
that the person's having knowledge of matters alleged in this pleadings are outside the
jurisdiction of the Court and her Verification cannot be obtained within the time allowed for
filing the pleading. I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S. § 4901, relating to unswom falsification toaudiQn
Plaintiff
for
CERTIFICATE OF SERVICE
On this ;1,1 day of , 2006, Carol J. Lindsay, Esquire, of the law
firm of SAIDIS, FLOWER & LIND Y, hereby certify that on this date a copy of the attached
document was served on the following individuals, via first class mail, postage prepaid,
addressed as follows:
Kara Haggerty, Esquire
Abom & Kutulakis
36 South Hanover Street
Carlisle, PA 17013
SAIDIS, FLOWER & LINDSAY
Supreme CourtP NQ. 44693
26 West High §We
Carlisle, PA 17013
717-243-6222
SAUDIS '
FWVVIM &
LINDSAY
26 West High Street
Culisle, PA
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DANITA DURF,
Plaintiff
VS.
LEROY DURF,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA
NO. 05-6280 CIVIL TERM
IN DIVORCE
DEFENDANT'S CLAIMS FOR ECONOMIC RELIEF
AND NOW, comes the Defendant, Leroy Durf, by and through his attorney,
Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P., and files these Claims for
Economic Relief as follows:
COUNT I - EQUITABLE DISTRIBUTION
Plaintiff and Defendant have acquired property, both real and personal,
during their marriage from July 27, 1985, until the present, which property is "marital
property".
2. Plaintiff and Defendant may have owned, prior to marriage, property
which has increased in value during the marriage and/or which has been exchanged
for other property, which has increased in value during the marriage, all of which
property is "marital property
3. Plaintiff and Defendant have been unable to agree as to an equitable
division of said property.
WHEREFORE, the Defendant requests This Honorable Court to equitably
divide all marital property.
Date: W
Respectfully submitted,
ABOM & KuTULAKTS, LLP
Kara W. Haggei
Attorney for Defen ant
Attorney I.D. # 86914
36 South Hanover Street
Carlisle, PA 17013
CERTIFICATE OF SERVICE
AND NOW, this 23' day of August 2006, I, Kara W. Haggerty, Esquire, of
Abom & KutulaEs, L.L.P., hereby certify that I did serve a true and correct copy of
the foregoing DEFENDANT'S CLAIMS FOR ECONOMIC RELIEF upon the
following.
Via First-Class Mail
Carol Lindsay, Esquire
Saidis, Shutt, Flower, & Lindsay
26 [hest High Street
Carlisle, PA 17013-2956
Date: ? #k(p
Respectfully submitted,
ABOM&KvTULASIS, LLP
V=L. t
Kara W. Haggerty
Attorney for Defendant
Attorney I.D. # 86914
36 South Hanover Street
Carlisle, PA 17013
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DANITA DURF,
Plaintiff
V.
LEROY DURF,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 05-6280 CIVIL
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
A Complaint in Divorce under § 3301(c) of the Divorce Code was filed December 6,
2005.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. 1 consent to the entry of a final Decree in Divorce after service of notice of intention
to request entry of the Decree.
I verify that the statements made in this Affidavit are true and correct 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: N aY ,a - 'Don to Danita Durf
PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A
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. 1 understand that I will not be divorced until a Divorce Decree is entered by the Court
FLOWER ?
LINDSAY
ATTORNM-AT•uw
26 West High Street
Carlisle, PA
and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary.
I verify that the statements made in this Affidavit are true and correct 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: / yfN. d - DW
Danita Durf 1??c'?
CD <
DANITA DURF,
Plaintiff
V.
LEROY DURF,
Defendant
DEFENDANT'S AFFIDAVIT OF CONSENT
A Complaint in Divorce under § 3301(c) of the Divorce Code was filed December 6,
2005.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. 1 consent to the entry of a final Decree in Divorce after service of notice of intention
to request entry of the Decree.
I verify that the statements made in this Affidavit are true and correct 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: P-, g G
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 05-6280 CIVIL
IN DIVORCE
Leroy Durf
DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER4 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. 1 understand that I will not be divorced until a Divorce Decree is entered by the Court
SAMIS,
FLOWER &
LINDSAY
26 West High Street
Carlisle, PA
and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary.
I verify that the statements made in this Affidavit are true and correct 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: ,Z/ =? et
Leroy Durf
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DANITA DURF,
VS.
LEROY DURF,
Plaintiff
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05 - 6280 CIVIL
IN DIVORCE
ORDER OF COURT
,j-h R
AND NOW, this La day of J ? _
2006, the parties and counsel having entered into an agreement
and stipulation resolving the economic issues on November 2,
2006, the date set for a four-party conference, the agreement
and stipulation having been transcribed, and subsequently
signed by the parties and counsel, the appointment of the
Master is vacated and counsel can conclude the proceedings by
the filing of a praecipe to transmit the record with the
affidavits of consent of the parties so that a final decree in
divorce can be entered.
BY THE COURT,
14?
cc: arol J. Lindsay
Attorney for Plaintiff
/ara W. Haggerty
Attorney for Defendant
4
Edgar B. Bayley, P.J.
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DANITA DURF,
Plaintiff
VS.
LEROY DURF,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05 - 6280 CIVIL
IN DIVORCE
THE MASTER: Today is Thursday, November 2,
2006. This is the date set for a conference with counsel
and the parties. Present in the hearing room are the
Plaintiff, Danita Durf, and her counsel Carol J. Lindsay,
and the Defendant, Leroy Durf, and his counsel Kara W.
Haggerty.
The parties were married on July 27, 1985,
and separated November 8, 2005. The complaint in divorce
was filed on December 6, 2005, raising grounds for divorce
of irretrievable breakdown of the marriage. The Master has
been provided affidavits of consent and waivers of notice of
intention to request entry of divorce decree signed and
dated today by both parties. The Master's office will file
the affidavits and waivers with the Prothonotary so that the
divorce can conclude under Section 3301(c) of the Domestic
Relations Code.
The complaint also raised economic claims of
alimony, alimony pendente lite, and counsel fees and costs.
The Defendant filed a petition for economic relief on August
23, 2006, raising a claim for equitable distribution.
The Master has been advised that after
1
` negotiations today, the parties have reached an agreement
with respect to the outstanding economic claims. That
agreement is going to be placed on the record in the
presence of the parties. The agreement will be considered
the substantive agreement of the parties, not subject to any
changes or modifications except for correction of
typographical errors which may be made during the
transcription. The parties and counsel will return later
this morning to review the draft of the agreement for
typographical errors, make any corrections as necessary, and
then affix their signatures to the agreement affirming the
terms of settlement as stated on the record.
Upon receipt by the Master of a completed
agreement, the Master will prepare an order vacating his
appointment and counsel can then prepare a praecipe
transmitting the record to the Court requesting a final
decree in divorce. Ms. Lindsay.
MS. LINDSAY: The parties have agreed to
divide their property as follows:
1. Husband will retain the 2001 Ranger, the Yamaha ATV
which he has previously sold, the tractor and the trailer.
He would also retain his Commerce Bank account, and any
monies left over from the 401(k) plan which was liquidated
during the parties' marriage. He will also maintain the
Monumental Life insurance policy and its cash value.
Husband will be permitted to change or name whomever he
wishes to have as a beneficiary or beneficiaries on said
policy. Husband also will be entitled to whatever cash
value is in the policy.
2
2. Wife will retain the 1997 Chevrolet Cavalier, her
Commerce Bank account, her US savings bonds, and her 401(k)
plan.
3. Counsel for wife has an escrow account of certain
proceeds from the sale of the marital home. Husband will
receive $1,500.00 of those escrowed funds and wife will
receive the balance of the escrow funds.
For their tax year 2006, the parties agree that each
will report 1/2 of the interest, if anything, earned on that
escrow account as income to each on their separately filed
federal income tax returns.
4. Husband will pay to wife alimony in the amount of
$500.00 a month through the office of Domestic Relations
commencing the first month subsequent to the entry of the
decree in divorce. Until that time, husband will continue
to pay alimony pendente lite as presently ordered.
Such alimony will be modifiable upon a showing of a
change in circumstances of one or both parties so long as
that change is of a substantial and continuing nature.
Alimony shall terminate upon the death of one or both of the
parties, wife's cohabitation with a member of the opposite
sex who is not a member of the family of wife within the
degrees of consanguinity, or wife's remarriage.
5. Wife withdraws her claim for counsel fees and costs.
6. Except as herein otherwise provided, each party may
dispose of his or her property in any way and each party
hereby waives and relinquishes any and all rights he or she
may now have or hereafter acquire under the present or
future laws of any jurisdiction to share in the property or
the estate of the other as a result of the marital
relationship including without limitation, statutory
allowance, widow's allowance, right of intestacy, right to
take against the will of the other, and right to act as
administrator or executor in the other's estate. Each will
at the request of the other execute, acknowledge, and
deliver any and all instruments which may be necessary or
advisable to carry into effect this mutual waiver and
relinquishment of all such interest, rights, and claims.
MS. LINDSAY: Ms. Durf, did you hear the
agreement which I dictated here today?
3
MS.
MS.
MS.
MS.
MS.
MS.
agreement that was
MR.
MS.
terms of that agre
MR.
MS.
to enter into that
MR.
DURF: Yes.
LINDSAY: Did you understand it?
DURF: Yes.
LINDSAY: It is acceptable to you?
DURF: Yes, it is acceptable to me.
HAGGERTY: Mr. Durf, did you hear the
read on the record by attorney Lindsay?
DURF: Yes.
HAGGERTY: Do you understand all of the
ement?
DURF: Yes.
HAGGERTY: And at this time, do you want
agreement?
DURF: Yes.
I acknowledge that I have read the above
stipulation and agreement, that I understand the terms of
settlement as set forth herein, and that by signing below I
ratify and affirm the agreement previously made and intend
to bind myself to the settlement as a contract obligating
myself to the terms of settlement and subjecting myself to
the methods and procedures of enforcement which may be
4
imposed by law and in particular Section 3105 of the
Domestic Relations Code.
WITNESS:
DATE:
Carol J. ?i dsay
Attorney/(fo Plaint ff
Danita Durf
Kara W. Hagger Leroy D rf
Attorney for en a t
5
DANITA DURF,
Plaintiff
V.
LEROY DURF,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 05-6280 CIVIL
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Kindly transmit the record, together with the following information, to the Court for
entry of a Decree in Divorce:
1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the
Divorce Code.
2. Date and manner of service of the Complaint: Defendant's counsel accepted
service of the Complaint on December 14, 2006. Proof of service was filed with the Court on
December 20, 2006.
3. Date Affidavit of Consent required under Section 3301(c) of the Divorce Code
was signed:
By Plaintiff: November 2, 2006 and filed with the Prothonotary on
November 3, 2006.
By Defendant: November 2, 2006 and filed with the Prothonotary on
November 3, 2006.
4. Related claims pending: None.
5. Date Waiver of Notice under Section 3301(c) of the Divorce Code was signed:
By Plaintiff: November 2, 2006 and filed with the Prothonotary on
November 3, 2006.
By Defendant: November 2, 2006 and filed with the Prothonotary on
November 3, 2006.
SAIDIS, FLOWER & LIN
SAIDIS,
FLOWER &
L NDSAY
ATrORNEIS.Khuw
26 West High Street
Carlisle, PA
Carol J. Lindsay, E?sgi
Supreme Court I No
26 West High Str
Carlisle, PA 17013
717-243-6222
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IN THE COURT OF COMMON PLEAS
DANITA DURF
OF CUMBERLAND COUNTY
STATE OF PENNA.
No. 05-6280
VERSUS
LEROY DURF
DECREE IN
DIVORCE
AND NOW, k)cg?"- 24 1-ft v IT IS ORDERED AND
DECREED THAT
DANITA DURF
, PLAINTIFF,
AND L.EROY IN IRE DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
None. %
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
?.JC?Y1 i 1'G? lJ U• E'? ,
Plaintiff
Vs File No. O S - (? g d
IN DIVORCE
Defendant
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff / defendant in the above matter,
[select one by marking "x"]
prior to the entry of a Final Decree in Divorce,
. or X after the entry of aFinal Decree in Divorce dated NO'iember , ac (a
hereby elects to resume-the prior surname of K l ? , and gives this
written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704.
Date: 1 ?)- 1 1- o Cs,
Signa
"V?
Signature of name being resumed
COMMONWE TH OF P NNSYLVANIA )
COUNTY OF
On the I I day of t)ep- e e R , 200L, before me, the Prothonotary or the
notary public, personally appeared the above affiant known to me to be the person whose
name is subscribed to the within document and acknowledged that he / she executed the
foregoing for the purpose therein contained.
In Witness Whereof, I have hereunto set my hand hereunto set my hand and official
seal. nn /! ) r_'\ I
NOTARIAL SEAL
PROTHONOTARY, NOTARY PUBLIC
CARLISLE CUMBERLAND COUNTY COURTHOUSE
MY COMMISSION EXPIRES JANUARY 4, 2010
I
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Defendant Name: LEROY A. DURF
Member ID Number: 3338101603
Please note: All correspondence must include the Member ID Number.
ORDER OF ATTACHMENT OF UNEMPLOYMENT COMPENSATION BENEFITS
Financial Break Down of Multiple Cases on Attachment
Plaintiff Name
DANITA A. KUHN
PACSES Docket
Case Number Number
246107936 05-6280 CIVIL
TOTAL ATTACHMENT AMOUNT: $ 548.00
Attachment Amount/Frequency
$ 548.00 MONTH
Now, by Order of this Court, the Department of Labor and Industry, Bureau of Unemployment
Compensation Benefits and Allowances (BUCBA), is hereby directed to attach the lesser of $126.12
per week, or 50 of the Unemployment Compensation benefits otherwise payable to the Defendant,
LEROY A. DURF Social Security Number 17 6 - 5 2 - 8 2 31 , Member
ID Number 3338101603 . BUCBA is ordered to remit the amount attached to the Department of Public
Welfare (DPW). DPW shall forward the amount received from BUCBA to the Domestic Relations Section of this
Court for support and/or support arrearages.
If the Defendant's Unemployment Compensation benefits are attached by another Court or Courts for
support and/or support arrearages, DPW may reduce the amount attached under this Order so that the total
amount attached does not exceed the maximum amount subject to garnishment pursuant to 15 U.S.C. § 1673
(b)(2) and 23 Pa. C.S.A. § 4348 (g).
This Order shall be effective upon receipt of the notice of the Order by the BUCBA and shall remain in
effect until the Defendant's entitlement to Unemployment Compensation benefits, under the Application for
Benefits dated DECEMBER 2, 2 0 0 7 is exhausted, expired or deferred.
BUCBA shall comply with this Order, unless it is amended or vacated by subsequent Order of this Court.
All questions, challenges or obligations to this Order shall be directed to the Domestic Relations Section of this
Court.
BY THE COURT
Date of Order: DEC 18 2007
DRO: R.J. SHADDAY
Service Type M
EDWARD E. JUDGE
Form EN-530
Worker ID $ IATT
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Defendant Name: LEROY A. DURF
Member ID Number: 3338101603
Please note: All correspondence must include the Member ID Number.
ORDER OF ATTACHMENT OF UNEMPLOYMENT COMPENSATION BENEFITS
Financial Break Down of Multiple Cases on Attachment
Plaintiff Name
DANITA A. KUHN
PACSES Docket
Case Number Number
246107936 05-6280 CIVIL
Attachment Amount/Frequenc
$ 548.00 MONTH
/
/
/
TOTAL ATTACHMENT AMOUNT: $ 548.00
Now, by Order of this Court, the Department of Labor and Industry, Office of Unemployment
Compensation Benefits (OUCB), is hereby directed to attach the lesser of $ 126.12
per week, or 50 of the Unemployment Compensation benefits otherwise payable to the Defendant,
LEROY A. DURF Social Security Number XXX-XX- 8231 ,
Member ID Number 3 3 3 81016 0 3 . OUCB is ordered to remit the amount attached to the Department of
Public Welfare (DPW). DPW shall forward the amount received from OUCB to the Domestic Relations Section
of this Court for support and/or support arrearages.
If the Defendant's Unemployment Compensation benefits are attached by another Court or Courts for
support and/or support arrearages, DPW may reduce the amount attached under this Order so that the total
amount attached does not exceed the maximum amount subject to garnishment pursuant to 15 U.S.C. § 1673
(b)(2) and 23 Pa. C.S.A. § 4348 (g).
This Order shall be effective upon receipt of the notice of the Order by the OUCB and shall remain in
effect until the Defendant's entitlement to Unemployment Compensation benefits, under the Application for
Benefits dated DECEMBER 7, 2008 is exhausted, expired or deferred.
OUCB shall comply with this Order, unless it is amended or vacated by subsequent Order of this Court.
All questions, challenges or obligations to this Order shall be directed to the Domestic Relations Section of this
Court.
Date of Order: DEC 16 2008
DRO: R.J. SHADDAY
BY THE COURT
EDWA} D E. GUIDO,
JUDGE
Form EN-530 Rev.2
Service Type M Worker ID $ IATT
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DANITA A. KUHN, ,
Plaintiff/Petitioner
VS. ,
LEROY A. DURF, ,
Defendant/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 05-6280 CIVIL TERM
IN DIVORCE
PACSES CASE: 246107936
ORDER OF COURT
AND NOW to wit, this 29th day of December 2008, it is hereby Ordered that the
the Order for Alimony Pendente Lite is terminated, effective January 1, 2009, pursuant to the
Petitioner's request.
The Alimony Pendente Lite is closed with a credit of $969.52.
BY THE COURT:
Edward E. Guido, J.
DRO: R.J. Shadday
xc: Petitioner
Respondent
Form OE-001
Service Type: M Worker: 21005
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 05-6280 CIVIL
State Commonwealth of Pennsylvania OOriginal Order/Notice
Co./City/Dist. of CUMBERLAND OAmended Order/Notice
Date of Order/Notice 01/01/09 OX Terminate Order/Notice
Case Number (See Addendum for case summary) (Done-Time Lump Sum/Notice
Employer/Withholder's Federal EIN Number
PENNSY SUPPLY INC
1001 PAXTON ST
HARRISBURG PA 17104-1645
RE: DURF, LEROY A.
Employee/Obligor's Name (Last, First, MI)
176-52-8231
Employee/Obligor's Social Security Number
3338101603
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.
$ 0.00 per month in current child support
$ o. oo per month in past-due child support Arrears 12 weeks or greater? Oyes ® no
$ 0.00 per month in current medical support
$ o . oo per month in past-due medical support
$ o. oo per month in current spousal support
$ o . oo per month in past-due spousal support
$ 0. oo per month for genetic test costs
$ o . oo per month in other (specify)
$ one-time lump sum payment
for a total of $ 0 . 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. $ o. oo per semimonthly pay period
(twice a month)
$ 0.00 per biweekly pay period (every two weeks) $ o . 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. 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 LWJLKSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY ,01110-ER IN DER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL. 140' -11?00
BY THE COURT:
DRO: R. J. Shadday
Service Type M
OMB No.: 0970-0154
Edward E. Guido,
Juclqe
rm EN-028 Rev. 4
Worker ID $IATT
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
A I heck you are required to pr vide a opy of this form to your m loyee. If yo r employee orks in a state that is
iferent from the state that issuedthis or?er, a copy must be provic?edpto your empyoyee even if t?le 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 employeetobligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. 2327294960
THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : 0 THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 0
EMPLOYEE'S/OBLIGOR'S NAME:DURF, LEROY A.
EMPLOYEE'S CASE IDENTIFIER: 3338101603
LAST KNOWN HOME ADDRESS:
DATE OF SEPARATION:
LAST KNOWN PHONE NUMBER: FINAL PAYMENT AMOUNT
NEW EMPLOYER'S NAMEIADDRESS:
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 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 (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
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
13 N. HANOVER ST by telephone at (717) 240-6225 or
P.O. BOX 320 by FAX at (717) 240-6248 or
CARLISLE PA 17013
by internet www.childsupport.state.pa.us
Page 2 of 2 Form EN-028 Rev. 4
Service Type M OMB No.: 0970-0154 Worker ID $IATT
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ADDENDUM
Summary of Cases on Attachment
DefendanVObligor: DURF, LEROY A.
PACSES Case Number 246107936
Plaintiff Name
DANITA A. KUHN
Docket Attachment Amount
05-6280 CIVIL$ 0.00
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
Service Type M
Addendum
OMB No.: 0970-0154
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
Form EN-028 Rev. 4
Worker ID $IATT
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 Fax: (717) 240-6248
Defendant Name: LEROY A. DURF
Member ID Number: 3338101603
Please note: All correspondence must include the Member ID Number.
ORDER TO VACATE ATTACHMENT OF UNEMPLOYMENT BENEFITS
Financial Break Down of Multiple Cases on Attachment
Plaintiff Name
DANITA A. KUHN
PACSES Docket
Case Number Number
246107936 05-6280 CIVIL
TOTAL ATTACHMENT AMOUNT:
Attachment Amount/Freauencv
$ 548.00 MONTH
/
/
$ 548.00
The prior Order of this Court directing the Department of Labor and Industry, Office of
Unemployment Compensation Benefits (OUCB), to attach $ 126.11
or 5 o % per week of the Unemployment Compensation benefits of
LEROY A. DURF
,Social Security Number XXX-XX_8231 ,
Member ID Number 3 3 3 81016 03 is hereby vacated.
This Order to Vacate shall be effective upon receipt of the notice of the Order by the
Department and shall remain in effect until a further Order of the Court is filed.
BY THE COURT
Date of Order: JAN 1 2009
DRO: R.J. SHADDAY
EDWARD E. DO, JUDGE
Form EN-035 Rev.2
Service Type M Worker ID $ IATT
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