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Home My WebLink About06-0081 SAIDIS SHUFF, FLOWER & LINDSAY AnuRNEVS.AT.LAW 26 W. High Street Carlisle, PA CHRISTINE G, SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO, O(,,-$') v, MATTHEW G, SNYDER, 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, CarlisleO, 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 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 SAIDIS, SH\F, FL~WER & LINDSAY ~I i I " c'it Carol J, Lindsay, E quire Supreme Court'ID 0, 44693 26 West High Str et Carlisle, PA 17013 717-243-6222 SAIDIS SHUFF, FLOWER & LINDSAY AITORNEYS.AT.LAW 26 W. High Street Carlisle. P A II CHRISTINE G, SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW NO, ot..SI MATTHEW G, SNYDER. Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1, The Plaintiff is Christine G, Snyder, an adult individual residing at 1421 English Drive, Mechanicsburg. Cumberland County, Pennsylvania 17055, 2, The Defendant is Matthew G, Snyder, an adult individual residing at 6326 Pine Street, Harrisburg, Dauphin County, Pennsylvania 17112, 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 May 29, 2004 in Fogelsville, Lehigh County, Pennsylvania, 5, The parties separated on December 15, 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, SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS-AT.LAW 26 W. High Street Carlisle, PA WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with S3301 of the Pennsylvania Divorce Code, Carol ,Linds , squire Supreme Co rt I No, 44693 26 West Hig treet Carlisle, PA 17013 717-243-6222 SAIDIS SHUFF, FLOWER & LINDSAY ATIORNEYS.ATeLAW 26 W. High Street Carlisle, P A II 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, 94904, relating to unsworn falsifications to authorities, ~ ~ I \, '(' " vLA, , ,- , 1 ristine G, Snyder, - Date: 1,-/22/Dt; 1 00 ~ n ~--~ '":.-:' 0 "':'-.:J '''1 ,:'r.... f'J --- <- -, \J 21 ::,:: T ~:'i feD ~ ~ I ,.-;-) "' -' S-) ~ (.., ~ -,) "- -- ~ ~ ~ ~ C,) ,. , ~ I - ~ l:" :> ~ ~ !:' ""' SAIDIS, FLOWER & LINDSAY ATTORNEYS.AT-IAW 26 West High Street Carlisle, PA II .. CHRISTINE G, SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO, ,100(.- 81 IN DIVORCE v, MATTHEW G, SNYDER, Defendant AFFIDAVIT OF SERVICE I, Carol J, Lindsay, Esquire, being duly sworn according to law, hereby deposes and says that on January 10. 2006, she served a true and correct copy of the Divorce Complaint upon Defendant, Matthew G, Snyder. by mailing that document to his address at 6326 Pine Street, Harrisburg. PA 17112, by Certified U,S, Mail, Restricted Delivery, Return Receipt Requested, as evidenced by the attached U,S, Postal Service Form 3811, Domestic Return Receipt, the latter of which is signed by the recipient, Matthew G, Snyder. Respectfully submitted, SAIDIS, FLOWE ~ //', \'-' / ;/ "it ' Carol J, Lind Attorney Id. 93 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff Dated: January:.10, 2006 . , SENDER: COMPLETE THIS SECTION COMPLETE THIS SECT/ON ON DELIVERY . Complete items 1. 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: .J4 8.':-. ., o Agent o Addressee C. Date of Delivery . Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: 0 No f--r)C,'Ltl he. u! G S')l-jCl~. (- c.d;,Cc !?ne <5ffeet HCl..(({<j hLLro--Pr~ r7 (Cd, U' 3. S8IVice Type M Certified Mail b Registered o Insured Mail [J Express Mail o Retum Receipt for MerchandiSe DC,O,D, 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number (Transfer from service label) PS Form 3811, February 2004 7003 1010 0001 1201 6302 Domestic Return Receipt 1 02595-o2-M-1540 ; . Sender: Please print your name, address, p,~, 1f~1 J ~ ' . . ,~-;'~_..j<<{ First.Class Mall Postage & Fees Paid USPS ; "l!\f3fihlJ:l"'1:G.10 UNITED STATES POSTAL SERVICE HARRISBURG Carol.r. Lindsay, Esquire Saidis, Shuff, Flower & Lindsay 26 West High Street Carlisle, P A 17013 'JAM!! 2O(B C004 1111 Hf~ 1,lf' 11"1 ,11.111111,',111,'11','.', fltl~t',Jl'J,.(J,J,l ".' (') \~; a --} , SAIDIS, FlDWER & LINDSAY ATJOIlNEYS.,>J.L\.W 26 West High Street CarlisJe,PA CHRISTINE G, SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO 2006-81 v, MATTHEW G, SNYDER, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1, A Complaint in Divorce under S 3301 (c) of the Divorce Code was filed on January 4, 2006, 2, The marriage of plaintiff and defendant IS Irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3, I consent to the entry of a final Decree 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 LJ 1.1 r; / () 0 I "/ / -}. S;vij/ll --Lf- ristine G, 'Snyder tI ~ PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER& 3301 (cl 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 enterea by tile Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary I verify that the statements made in this Affidavit are true and correct 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, !.dlr:::..l/v Date: ~L!'-:!! , ~' ) I, "/,, ' '/ic~(' , "l hristine G, Snyder ' '.I. t!' -:L: (.,") C',J ,~~ !.'.. : '; APR 1 8 DB ,:,.~."\ ,. ~:J (-.l c-"'; ,~.) SAlOIS, FLOWER & LINDSAY ATRJIINEYSoAT.!.AW 26 West High Street Carlisle, PA CHRISTINE G. SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2006-81 v. MATTHEW G. SNYDER, Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~ 3301(c) of the Divorce Code was filed on January 4, 2006. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree 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 Date: penalties of 8 Pa.C.S. 4904 relating to unsworn falsification to auth DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER!S 3301 (e) 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 ur expenses if I do not claim them before ;3 divorce is gr~mted 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements rein are made subject to the ,pe~alties of7 paiS, 4904 relating to unswom falsification to a th [ i e Date:~ (") c r-.' C:"~) c:::::) cy' ....i~ S;. -.< o -n :::!, -,.~ _-'~ 1 ~ (nr=: fl'1 o 1-::.1 -"1"1 -::J .oF', ,~ ~'ci "::-,.-,; ~ ) -' :::;: r:-? "iJ :-< r'0 CO . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY . . . PENNA. STATE OF . CHRISTINE G. SNYDER . . No. 06-81 . . . . VERSUS MATTHEW G. SNYDER . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . DECREE IN DIVORCE AND NOW, rv12t---l3 CHRISTINE G. SNYDER , 2.606, IT IS ORDERED AND DECREED THAT PLAINTIFF, MATTHEW G. SNYDER AND DEFEN DANT, 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; The terms of the Separation and Property Settlement Agreement dated December 22, 2005 are incorporated, but not merged, into this Decree in Divorce. ATT 'TJ~J / PROTHONOTARY . . . . . . . . J. . . . .k?~~u' '!(}.J/;5 ~ lP 1~' Nup/'P ?rJ' k 0> . " ,., .. <",- '" ......~ \ ,<' ~,~ '1~, .. . . .... SAIDIS, ROWER & LINDSAY ~'IAW 26 West High Street Carlisle. PA --::::1--... -""m t I J3Q , IV CHRISTINE G. SNYDER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2006-81 v. MATTHEW G. SNYDER, Defendant : IN DIVORCE QUALIFIED DOMESTIC RELATIONS ORDER This Order is drawn pursuant to the domestic relations laws of the Commonwealth of Pennsylvania. The Court finds the following: 1. The term "Participant" means Christine G. Snyder, whose last known mailing address is 1421 English Drive, Mechanicsburg, Pennsylvania 17055. 2. A. The term "Alternate Payee" means Matthew G. Snyder, born October 11, 1970, whose last known mailing address is 6326 Pine Street, Harrisburg, Pennsylvania, 17112. B. The Alternate Payee is the former spouse of the Participant. 3. The term "Plan" means the Merck & Co., Inc. Employee Savings and Security Plan. 4. The Alternate Payee is allocated and assigned $4,208.29 of the Participant's account balance under the Plan. The Alternate Payee's benefit shall not include any gains, losses or interest on that amount. 5. The Alternate Payee's benefit shall be distributed to him in a single lump sum as soon as administratively feasible following qualification of this Order by the Plan Administrator. 6. A. At Alternate Payee's distribution, his benefit shall be directly rolled over to his traditional IRA account qualified under Internal Revenue Code ~401 (a) at the following address: &: .<( 1- IUQ O;.-~ -'-.J t; ~., ~j: ~..:--, C[, S;] r"\ ,.,. tr]0-. a:UJ if u.. o c''') c.~ .~ 0: co u w C) ....0 t:....-~ = c--.I ~:5 o SAlOIS, FLOWER & LINDSAY ~A'NAW 26 West High Street Carlisle, PA Name: M& T Bank Address: 4950 Jonestown Road, Harrisburg, PA 17109 Account Number: 35004200985454 B. Whole shares of Merck common stock transferred to the Alternate Payee pursuant to paragraph 5 shall be distributed in-kind, if allowed under the terms of the Alternate Payee's traditional IRA account. If a direct roll over of Merck common stock in-kind is not available, then such whole shares of Merck common stock shall be converted to cash at distribution to permit a direct rollover. Mutual funds and fractional share of Merck common stock, if any, transferred to the Alternate Payee pursuant to paragraph 5 shall be distributed to him in cash. 7. The Alternate Payee's benefit shall consist of pre- and after-tax funds which are in proportion to the pre- and after-tax funds in the Participant's total account at distribution of the Alternate Payee's benefit. 8. In the event the Plan overpays benefits to either the Participant or the Alternate Payee, the Plan shall be entitled to recover such overpayment. 9. The Alternate Payee and the Participant agree to promptly submit this Order to the Plan Administrator for determination of its status as a Qualified Domestic Relations Order. 10. The Alternate Payee and Participant certify that they are not aware of any other order which purports to dispose of the Participant's benefits described herein. 11. The Alternate Payee and Participant agree to hold the Plan, Plan Administrator and Fiduciaries harmless from any liabilities which arise from following this Order, including any reasonable attorney fees which may be incurred in connection with any claims which are asserted because the Plan honors this Order. . . . .. .. SAlOIS, FLOWER & LINDSAY ATIOIINE\'SoAl'.\AW 26 West High Street Carlisle. PA II I 12. The Plan, Plan Administrator, and Fiduciaries shall not be responsible for any attorney fees incurred by the Participant or Alternate Payee in connection with the obtaining or enforcement of this Order. 13. The Alternate Payee and participant have designated the following attorneys as representatives for receipt of copies of notices: Carol J. Lindsay, Esquire Said is, Flower & Lindsay 26 West High Street Carlisle, PA 17013 Participant: Alternate Payee: None. 14. This Order is intended to constitute a Qualified Domestic Relations Order pursuant to IRC ~414(p) and ERISA ~206(d). This Court retains jurisdiction to amend this Order as may be necessary to establish or maintain its status. Witness DeL. 17. 2- DO~ . BY THE COURT tIJ,- \ \ \ J. - I) -11f-a, ~~"-- JMs' I