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HomeMy WebLinkAbout06-0264 Cara A. Boyanowski, Esquire Supreme Court l.D. No. 68736 2080 Linglestown Road Suite 201 Harrisburg, PAl 711 0 Telephone: (717) 540-9170 Facsimile: (717) 540-5481 NICOLE A. HURST, Plaintiff N THE COURT OF COMMON PLEAS UMBERLAND COUNTY, PENNSYLVANIA IVIL ACTION - LAW NO. Ole - ;<t,.'I C"UI-L~17\ v. TRAVIS L. HURST, Defendant IN DIVORCE NOTICE TO DEFEN AND CLAIM RJIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt acti n. You are warned that if you fail to do so, the case may proceed without you and a decree of divorfe or annulment may be entered against you by the Court. A judgment may also be entered againstlyou 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 indf.' nities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of arriage counselors is available in the Office of the Prothonotary, High and Hanover Streets, Carli Ie, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM. FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES, OR EXPENSES BEFOREIA DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ~NY OF THEM. YOU SHOULD TAKE THIS PAPER TP YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LA WYER OR CANNOT AFFORD GNE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE ydU CAN GET LEGAL HELP. Cumberland Co nty Bar Association 232 South edford Street Carlisle P A 17013 (717) 49-3166 NOrICIA Le han demandado a usted en la cort1. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tienel viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presenta una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defens s 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiend , la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y po cualquier queja 0 alivio que es pedido en la peticion do demanda. U sted puede perder dinero 0 sus p opiedades 0 otros derechos importanates para usted. LLEVE ESTA DEMANDA A UN A$ODAGO INMEDIATAMENTE. Sl NO TIENE ABOGADO 0 Sl NO TIENE EL DINERO SUF[cIENTE DE P AGAR TAL SERVICIO, V A Y A EN PERSONA 0 LLAME POR TELFONO A LA rmCINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DpNDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. I Cumberland cotnty Bar Association 232 SouthjBedford Street Carlisld, P A 17013 I (717)1249-3166 Cara A. Boyanowski, Esquire Supreme Court J.D. No. 68736 2080 Linglestown Road Suite 201 Harrisburg, PAl 711 0 Telephone: (717) 540-9170 Facsimile: (717) 540-5481 N THE COURT OF COMMON PLEAS UMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NICOLE A. HURST, Plaintiff v. ~ !NO. O~ - :2,/..'1 ; IIN DIVORCE I , C/DJT~ TRAVIS L. HURST, Defendant COMPLAINT I DIVORCE UNDJ[R SECTION 3301(c) R SECTION 3301(d) OF THE DI ORCE CODE AND NOW comes the above Plain iff, Nicole A. Hurst, by her attorney, Cara A. , Boyanowski, Esquire, and seeks to obtain a ddcree in divorce from the above-named Defendant, upon the grounds hereinafter set forth: CQUNTI I I DItORCE I. The Plaintiff, Nicole A. Hurst, is an adult individual who resides at 1262 Hunters Ridge Drive, Mechanicsburg, Cumberland Co nty, Pennsylvania l7050. 2. The Defendant, Travis 1. Hurs , is an adult individual who resides at 5447 Rolling Road, Chambers burg, Franklin County, Penns lvania 1720 I. 3. The Plaintiff has been a bona fi e resident of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to thelfiling of this Complaint. 4. The Plaintiff and Defendant wert married on August] 4,2004, in Enola, Cumberland County, Pennsylvania. 5. The Plaintiff and Defendant are !both citizens of the United States of America. There have been no prior action~ in divorce between the parties. Plaintiff avers that there is one Jhild born of the marriage under the age of eighteen 6. 7. years, namely, Madison N. Hurst, born June 26, 2001. 8. The Plaintiffand the Defendant are not members of the Armed Services of the United States or any of its allies. 9. Plaintiff has been advised ofthejavailability of counseling and that she may have the I ! right to request that the Court require the parties to participate in counseling. She has declined counseling. 10. The causes of action and sedtions of Divorce Code under which Plaintiff is proceeding are: A. Section 3301(c). The rr1arriage of the parties is irretrievably broken. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an Affidavit corsenting to a divorce. Plaintiff believes that Defendant may also file such an Affid4vit. B. Section 3301 (d). The iarriage of the parties is irretrievably broken. The Plaintiff and Defendant separated ~n October 6, 2005. I WHEREFORE. <he PI""";'f pmy~ yot H,oombk Omrt " '"'" " Do,,~ 'e Di '"= from the bonds of matrimony. COUNT II ALIMONY PENDENTE L TE, COUNSEL FEES, COSTS AND XPENSES 11. Paragraphs 1 through 10 of t e Divorce Comp1a.int are incorporated herein by reference as though set forth in full. I , I Defendant earns in excess of $~2,OOO.OO dollars gross per year, and has assets that I have not yet been ascertained. I 13. Plaintiff has employed counsel) but is unable to pay the necessary and reasonable ! 12. attorney's fees for said counsel. 14. Plaintiff is unable to sustain hetself during the course of this litigation. I WHEREFORE, Plaintiff requests YOljr Honorable Court to enter an award of Alimony Pendente Lite, interim counsel fees, costs and ekpenses, until final hearing and thereupon award such additional counsel fees, costs and expenses as Ideemed appropriate. ----. _ _ -I-U I verify that the statements made in thiS Complaint are trU(~ 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. /" By: ~ cAC~uud-~ e A. Hurst, Plaintiff DaJ}Q. . ;<0\ ~OOS- .DyQ*~~~ Attorney No. 68736 2080 Linglestown Road Suite 201 Harrisburg, P A 17110 (717) 540-9170 , , Attorney for Plaintiff l ~ 09J .(Q lIf-9.)::{) ~ 1>0 . . ..... W tI\ C> lI1. ~. ...0 \) (' 0 "-J ..() I I ~ V') ~-J ~ ()J &:pt:: ~t --L.... 1-) ,;::-2, C) (' )-n c_ :-:-1 .~'"; \ ]", i -. -~~ \ " - "Q ~. ;\ ::J::> '('_', i ...f, NICOLE A. HURST, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 06-264 CIVIL TERM P ACSES CASE NO. !.P:;(4- I D 7 '11.> I CIVIL ACTION - LAW IN DIVORCE TRAVIS L. HURST, Defendant NICOLE A. HURST, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA DOMESTIC RELATIONS SECTION v. TRAVIS L. HURST, Defendant NO. 00895 S 2005 PACSES NO. 624107747 CIVIL ACTION - SUPPORT ORDER OF COURT ANDNOW,this--LdayOf .j~ , 2006, upon stipulation of the parties, it is hereby Ordered and Decreed: 1. Defendant, Travis L. Hurst, shall pay the sum of $394.17 per month, to Plaintiff, Nicole A. Hurst, in alimony pendente lite. Any arrearage that accrues on this account may be attached at the rate of $1 0.00 per month. 2. The Defendant, Travis L. Hurst, shall be wage attached for the alimony pendente lite. Defendant's wage attachment shall occur on a weekly basis. 3. The effective date of this Order of Court shall be January 1,2006. Plaintiffs spousal support claim is denied. 4. All remaining provisions surrounding the Order of Court for support, filed at this docket number and entered by this Honorable Court on December 8, 2005 shall remain in full force and effect. 5. This Order of Court shall be enforceable through the Domestic Relations Office ofthe Court of Common Pleas of Cumberland County. COpies ""t/ \!'y l)i1o t-) , C) L Cara A. Boyanowski. Esquire SERRATELLI SCHIFFMAN BROWN & CALHOON 2080 Linglestown Road Suite 201 Harrisburg, PAl 711 0 (717) 540-9170 (telephone) (717) 540-5481 (facsimile) Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA NICOLE A. HURST, Plaintiff v. NO. 06-264 CIVIL TERM PACSES CASE NO. CIVIL ACTION - LAW IN DIVORCE TRAVIS L. HURST, Defendant NICOLE A. HURST, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION v. TRAVIS L. HURST, Defendant NO. 00895 S 2005 PACSES NO. 624107747 CIVIL ACTION - SUPPORT STIPULATION FOR SPOUSAL SUPPORT WHEREAS, Plaintiff filed a complaint for support of herself and the parties' minor child, Madison N. Hurst, born June 26, 2001, on or about October 17, 2005; WHEREAS, on or about December 8, 2005, a support conference was held and an Order of Court was entered on the same date directing Defendant to pay to Plaintiff the sum of$347.00 in child support each month. Defendant raised an entitlement claim for the spousal support request, and therefore, no award for spousal support was entered; WHEREAS, subsequent to the entrance of the above specified Order of Court, Plaintiff filed a Divorce Complaint containing a counterclaim for alimony pendente lite; WHEREAS, Plaintiff and Defendant have reached an agreement, without the need of this Honorable Court's assistance, and wish to enter their agreement as an Order of Court; NOW THEREFORE, intending to be legally bound, the parties agree as follows: A. Defendant, Travis L. Hurst, shall pay the sum of $394.17 per month, to Plaintiff, Nicole A. Hurst, in alimony pendente lite. Any arrearage that accrues on this account may be attached at the rate of $ 10.00 per month. S. The Defendant, Travis L. Hurst, shall be wage attached for the alimony pendente lite. Defendant's wage attachment shall occur on a weekly basis. C. The effective date of this Order of Court shall be January 1, 2006. D All remaining provisions surrounding the Order of Court for support, filed at this docket number and entered by this Honorable Court on December 8, 2005 shall remain in full force and effect. Plaintiff agrees to withdraw her request for spousal support. E. Plaintiff is represented by Cara A. Boyanowski, Esquire and Defendant is represented by Debra Denison Cantor, Esquire. Both parties have been informed of the purpose of this Stipulation and its legal effects and consequences. F. Each of the parties have carefully read and fully considered this Stipulation and all of the statements, terms, conditions, and provisions thereofprior to signing below. G. Both parties request this Honorable Court enter this Stipulation for Support as an Order of Court and enforce this action through the Domestic Relations Office of the Court of Common Pleas of Cumberland County. IN WITNESS WHEREOF, the parties have set forth their hands and seals this 11-l1\. . day of (f~i2t ,2006. ~ WITNESS: . . IJ / ",'I.~ /" Ii' .JJaWW i/;;~~/(/1C' . Nicole A. Hurst I / .b~' / ylv.;;;;:;t- /Travis L. Hurst . State Commonwealth of pennsylvania Co.lCity/Dist. of CUMBERLAND Date of Order/Notice 01/24/06 Case Number (See Addendum for case summary) ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 624107747 895 S 2005 626107961 06-264 CIVIL RE: HURST, TRAVIS L. Employee/Obligor's Name (Last, First, MI) o Original Order/Notice o Amended Order/Notice o Terminate Order/Notice Employer/withholder's Federal EIN Number DARDEN CORPORATION C/O PAYROLL/GARNISHMENTS PO BOX 593330 ORLANDO FL 32859-3330 208-62-8654 Employee/Obligor's Social Security Number 9404101572 Employee/Obligor's Case Identifier (Sei' Addf'ndum for plaintiff names associated with cases on atfarnmfmV Custodial Parentis Name (Last, First, Mil See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 741.17 per month in current support $ 53 .00 per month in past-due support Arrears 12 weeks or greater? 0 yes W no $ 0.00 per month in current and past.due medical support $ 0 . 00 per month for genetic test costs $ per month in other (specify) for a total of $ 794.17 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: $ 183.27 per weekly pay period. $ 366.54 per biweekly pay period (every two weeks). $ 397.09 per semimonthly pay period (twice a month). $ 794.17 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 S5% of the employee'sl obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2L 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 SCOU Send check to: Pennsylvania SCOU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEfENDANT'S NAME AND THE PACSES MEMBER 1D (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. DRO: R.J. Shadday Service Type M OMB No.: 0970-0154 "'"~~ ~~v \ (',,~b~~ Edgar B. Bayley, ' Judge Form EN.028 Worker 10 $IATT JAN 2 5 200i Date of Order: . ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If checked you are required to provide a copy of this form to your employee. If yoVr employee works in a state that is different 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 I1sted 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. *~eportingthe.Paydate/fJate ofWithholding:-You""ushepo1Htre paydatefdate of withholdingwhert>endingth"1'ay1 "_, ,I.fhe- payd;rteldat<eofwithholding isthe dat"""whicloamotmt-waswithhekHrom thlOemployee'<wage;; 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: 5933784920 EMPLOYEE'S/OBlIGOR'S NAME: HURST. TRAVIS L. EMPLOYEE'S CASE IDENTIFIER: 9404101572 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. Antiwdiscrimination: 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 115 U.5.c. 91673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240.6248 or by internet www.childsupport.state.pa.us Page 2 of 2 Form EN.028 Worker ID $IATT Service Type M OM8 No.: 0970-(}l54 . '. ADDENDUM Summary of Cases on Attachment Defendant/Obligor: HURST, TRAVIS L. PACSES Case Number 624107747 Plaintiff Name NICOLE A. HURST Docket Attachment Amount 008958 2005 $ 400.00 Childl,en)'s Name(s): MADISON N. HURST DOB 06/26/01 PACSES Case Number 626107961 Plaintiff Name NICOLE A. HURST Docket Attachment Amount 06-264 CIVIL $ 394.17 Childlren)'s Namels): DaB II checked, you are required to enroll the childlren) above in any health insurance coverage available through the employee's/obligor's employment. 011 checked, you are required to enroll the childlren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Childlren)'s Namels): DaB Docket Attachment Amount $ 0.00 Childlren)'s Name!s): DaB 011 checked, you are required to enroll the childlren) identified above in any health insurance coverage available through the employee's/obligor's employment. o II checked, you are required to enroll the childlren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child!ren)', Namels): DaB Docket Attachment Amount $ 0.00 Child(ren)'s Name!,): DaB 011 checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. o II checked, you are required to enroll the childlren) identified above in any health insurance coverage available through the employee's/obligor's employment. Addendum Form E N-028 Worker ID $IATT Service Type M OMB No.: 0970.0154 r'_1 !',:, ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsvlvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 02/01/06 Case Number (See Addendum for case summary) 624107747 895 S 2005 o Original Order/Notice (8) Amended Order/Notice o Terminate Order/Notice DARDEN CORPORATION C/O PAYROLL/GARNISHMENTS PO BOX 593330 ORLANDO FL 32859-3330 626107961 06-264 CIVIL RE, HURST, TRAVIS L. Employee/Obligor's Name (Last, First, MI) 208-62-8654 Employee/Obligor's Social Security Number 9404101572 Employee/Obligor's Case Identifier (5(>e Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (last First, MI) EmployerMtithholder's Federal EIN Number See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above.named employee's/obligor's income until further notice even if the Order/Notice is not issued by you r State. $ 741.17 per month in current support $ 63.00 per month in past-due support Arrears 12 weeks or greater? Oyes @ no $ 0.00 per month in current and past.due medical support $ 0 . 00 per month for genetic test costs $ per month in other (specify) for a total of $ 804.17 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: $ 185.58 per weekly pay period. $ 371.16 per biweekly pay period (every two weeks). $ 402.09 per semimonthly pay period (twice a month). $ 804.17 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydateldate of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the 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 seDU Send check to: Pennsylvania seou, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEfENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. Date of Order: FEB 0 2 20C5 ge Form EN.028 Worker 10 $IATT DRO: R. J. Shadday Service Type M OM6No,:Og7Q..G154 ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOlDERS o If ~hecked you are required to provide a copy of this form to your employee. If yow employee works in a state that is different 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. * Repu,li"5 tJ Ie r aydatc:/DClte of '..t/itl,llok1il15. Yvu ,1IUSt lepOr[ tilt:: IJdyJateldate of vvitl,l,uldi"o vvLell 5ellJil!5lll~ j-1C1yrllellt. -the-- \-"h:l.yJatb'Jo:te of ~v;tlllro'IJ;llg iSl'"t:: ddle 011 vvll;LII dlllOUflt vva.!. vv;tLlleld helll llle elll.....lvyee':> 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 for..vard 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: 5933784920 EMPLOYEE'S/OBLlGOR'S NAME: HURST , TRAVIS L. EMPLOYEE'S CASE IDENTtFIER: 9404101572 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. * Withholding limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.c. ~1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income leh aher 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. l1.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 (7171 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 Form E N-028 Worker ID $IATT Service Type M OMBNo.:0970-0154 , ADDENDUM Summary of Cases on Attachment Defendant/Obligor: HURST, TRAVIS L. PACSES Case Number 624107747 Plaintiff Name NICOLE A. HURST Docket Attachment Amount 0089sS 2005 $ 400.00 Child(ren)'s Name(s): DOB PACSES Case Number 626107961 Plaintiff Name NICOLE A. HURST Docket Attachment Amount 06-264 CIVIL $ 404.17 Child(ren)'s Name(s); DOB o If checked, you are required to enroll the childlrenl identified above in any health insurance coverage available through the employee's/obligor's employment. o if checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(renl's Name(s); DOB Docket Attachment Amount $ 0.00 Child(ren)'s Namels): DOB If you are required to enroll the child(ren) above in any health insurance coverage available the employee's/obligor's employment. If checked, you are required to enroll the child(ren) in any health insurance coverage available employee'siobligor's empioyment. PACSES Case Number Plaintiff Name P ACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Namels): DOB Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. o If checked, you are required to enroli the chiidlren) identified above in any health insurance coverage available through the employee's/obligor's employment. Addendum Form E N-028 Worker 10 $IATT Service Type M OMB No.: 0970-0154 (") C' r-'" ;;-:~.. ,:?J ~.;-. ......, G \ {'.:l ...,...:' :\ -,-', .....-,.,. _1..'. o ~'f\ _A -:'~ --D (\\f: ~.'~\\"S' c:? \ ~;~1, ',- j ',';\~, ,,/,-_l. _: f\' ,,;\ ")7 ".~ -- .p -"~--- MAY. 24. 2006 3:58PM S.S.B.&C. Hbg,Pa,17110 IAAY-z4-uB J~:Z( PKuM"CumblrlillQ ~gUOlJ ~gm""' ""OllU"O +11172406146 T-3~P' ~mJ/OOl .3m No. DIo- ;{Io~ Civi I zt i ND. rrq5 ~ dO~- ~y 2 4 _ ! ~RLAND COlJNTY MESTICRELAll0NS Date ofApplication:5-~ - ReqaMUor Sap 011 Record Search Name: ~Llr'5+ (Last) ~~~~ =lIl-540-54&/ (FIx N'1IIIIber) PA 11/10 amy Number Search X INITIAL REQUEST. (,D8Ie) '3 '3 9J' 9 Support ArreIt8 as of Bud ofMomh Prior to Date of Applicatio : S "2 (., '3 ? ( Monthly Total Support Obligation: S I C ~ Tho __ _ b """"" In ~n:.....,_ s..dm Offiooor "~~,--> CumberlaDd County, Pewytvimia.' 'm b if -.Jl.- q D 41 0 I S7 ~ . Uv\ ,. . Domestic Relations Case Number: eM G,;2 (. IOj 9" + b~ 101 7 SigDed: .])j)~e~ Hal DO Record in Domesnc R.elaticms as of. ~. . $"~z..V,-Q<" (D*) llRING-DOWN REQUEST Suppon Amlars: S As Of (DBIe) Signed: . (LieD CoordIaaror) (Dale) .. '" Lien Satisfisfaction Receipt Available Up n Request*** CC720 ~ \? ::S :r.?~ ;...<. (.,) -- ~ ~~ -dl)~' '\lIf\ '-7' " ~/~ t, ~:>., ~~ ~~~', "pC ~_./ :2 ~ .-\ ::t:'" f'''\f:: -Cr:~ ...jCi ':-~3,(,?, -0 '$ t.;? ~ -- :;2{~) ..;.-rn ~3 "'~;;.., .~ LIEN SATISFACTION N me: Travis Hurst M mber Number: 9404101572 J dgment Lien Satisfied as of: May 29, 2006 A ount Paid: $_$339.89 Si ned: Pacses# 626107961 No. 06-264 CV DR# CC722 r-.> c;::;~ g:~ L_ I~-\ ~""1 .-4 :r::....., \"" ~::, :g~? -),(~,\ ., '" '~c\ .,1;:":": ~..,>, .{ ('Srn ::::.\ "r".. -13 :-0:.:::, (~--; ,-v 0" -,.:~. ~) r<l State Commonwealth of Pennsylvania Co.lCity/Dist. of CUMBERLAND Date of Order/Notice 12/29/06 Case Number (See Addendum for case summary) ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT (p~ t./ 1077'-1-7 ~q5 5 2005 /,:l /" I D TCJ /, / Of, - el./p/f CJ VI L " .~ o Original Order/Notice o Amended Order/Notice o Terminate Order/Notice GMR RESTAURANTS INC C/O ATTN: PAYMENTS/GARNISHME PO BOX 593330 ORLANDO FL 32859-3330 RE:HURST, TRAVIS L. Employee/Obligor's Name (Last, First, MI) 208-62-8654 Employee/Obligor's Social Security Number 9404101572 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, MI) Employer/Withholder's Federal EIN Number See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMA nON: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 741.17 per month in current support $ 0 . 00 per month in past-due support Arrears 12 weeks or greater? 0 yes @ no $ 0.00 per month in current and past-due medical support $ 0 . 00 per month for genetic test costs $ per month in other (specify) for a total of $ 741 . 17 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: $ 171.04 per weekly pay period. $ 342.08 per biweekly pay period (every two weeks). $ 370.59 per semimonthly pay period (twice a month). $ 741.17 per monthly pay period. REMITTANCE INFORMA nON: 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: P A SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. ~. . . ,', \, BY TH OURT: ~ Date of Order: .;,'.ii 0 2 200t l. _..f^v V \(b,. '1 ~ \ Form EN-028 Rev. 1 Worker ID $IATT Service Type M OMB No,: 0970-0154 , - ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If checked you are required to provide a copy of this form to your employee. If your employee works in a state that is different 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. * Repoltillg ti,e rayJdte/Date of W;tlll,oIJ;lIg. YOu Illust lepolt ti,e paydate/date of vvitl,l,oldil,g vvl,ell sel,dil,g ti,e paynlellt. Ti,e paydate/date of vvitl.l,old;l,g is ti,e date 01. vvl.id, dll.OUllt VVCl:> vv;t1,lleld flollltlle t:1I11.lIoyee'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 em p loyee's/ob I igor'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: 5912191680 EMPLOYEE'S/OBLlGOR'S NAME: HURST, TRAVIS L. EMPLOYEE'S CASE IDENTIFIER: 9404101572 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. * Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.c. ~1673 (b)l; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 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 (71 7) 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Rev. 1 Worker ID $IATT Service Type M OMB No.: 0970-0154 . ' ... ADDENDUM Summary of Cases on Attachment Defendant/Obligor: HURST, TRAVIS L. PACSES Case Number 624107747 Plaintiff Name NICOLE A. HURST Docket Attachment Amount 00895 S 2005 $ 347.00 Child(ren)'s Name(s): DOB you are required to enroll the child(ren) 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) 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) above in any health insurance coverage available through the employee's/obligor's employment. Addendum Service Type M OMB No.: 0970-0154 PACSES Case Number 626107961 Plaintiff Name NICOLE A. HURST Docket Attachment Amount 06-264 CIVIL $ 394.17 Child(ren)'s Name(s): DOB D If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB D If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): 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. Form EN-028 Rev. 1 Worker 10 $IATT .... .,. McNEES WALLACE & NURICK LLC By: DEBRA D. CANTOR Attorney 10 No. 66378 100 Pine Street Harrisburg, PA 17108-1166 (717) 237-5297 (717) 237-5300 facsimile dcantor@mwn.com Attorneys for Defendant Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NICOLE A. HURST, v. NO. 06-264 CIVIL TERM TRAVIS L. HURST. IN DIVORCE Defendant MOTION FOR APPOINTMENT OF MASTER ~ Defendant moves the court to appoint a master with respect to the following claims: ~ Divorce D Annulment D Alimony ~ Alimony Pendente Lite ~ Distribution of Property D Support ~ Counsel Fees ~ Costs and Expenses and in support of the Motion states: 1 . Discovery [8J is complete as to the c1aim( s) for which the appointment of master is requested. 2. The non-moving party ~ has D has not appeared in the action D personally [gJ by counsel, Cara A. Boyanowski, Esquire. 3. The statutory ground(s) for divorce 0 are r8J 3301(c) and (d). 4. The action is contested with respect to the following claims: divorce, distribution of property, alimony pendente lite, and counsel fees. 5. The action D involves ~ does not involve complex issues of law or fact. 6. The hearing is expected to take 1 day. 7. Additional information, if any, relevant to the motion: none. Date: ~)(\ rU/~( '1 '~'1, d-Q) I AND NOW. TMLL N~" . Cantor Attorney for Defendant ,2007, , Esquire, is appointed master with respect to the following claims: MOVING PARTY NAME: Travis L. Hurst ATTORNEY'S NAME: Debra D. Cantor ATTORNEY'S ADDRESS: 100 Pine Street Harrisburg, PA 17101 ATTORNEY'S TELEPHONE NO.: 717-237-5297 ATTORNEY'S EMAIL: dcantor@mwn.com PARTY'S ADDRESS & TELEPHONE NUMBER IF NOT REPRESENTED BY COUNSEL: BY THE COURT: J. NON-MOVING PARTY NAME: Nicole A. Hurst ATTORNEY'S NAME: Cara A. Boyanowski ATTORNEY'S ADDRESS: 2080 Linglestown Rd Suite 201 Harrisburg, PA 17110 ATTORNEY'S TELEPHONE NO.: 717-540-9170 x125 ATTORNEY'S EMAIL: cbovanowski@ssbc-Iaw.com PARTY'S ADDRESS & TELEPHONE NUMBER IF NOT REPRESENTED BY COUNSEL: - 2 - .. CERTIFICATE OF SERVICE The undersigned hereby certifies that on the ~y of'\- true and correct copy of the foregoing document was served by first-class prepaid, upon the following: Cara A. Boyanowski, Esquire Serratelli, Schiffman, Brown & Calhoon, P.C. 2080 Linglestown Road, Suite 201 Harrisburg, PA 17110-9670 ~/~.A De~~& \_/ ~ Counsel for Defendant -- '-. t JAN 25 2007, McNEES WALLACE & NURICK LLC By: DEBRA D. CANTOR Attorney 10 No. 66378 100 Pine Street Harrisburg, PA 17108-1166 (717) 237-5297 (717) 237-5300 facsimile dcantor~mwn.com Attorneys for Defendant Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-264 CIVIL TERM NICOLE A. HURST, v. TRAVIS L. HURST, IN DIVORCE Defendant MOTION FOR APPOINTMENT OF MASTER ~ Defendant moves the court to appoint a master with respect to the following claims: ~ Divorce D Annulment D Alimony ~ Alimony Pendente Lite ~ Distribution of Property D Support ~ Counsel Fees ~ Costs and Expenses and in support of the Motion states: 1. Discovery [8J is complete as to the c1aim( s) for which the appointment of master is requested. 2. The non-moving party [8J has 0 has not appeared in the action o personally [8J by counsel, Cara A. Boyanowski, Esquire. ..-.I .. 3. The statutory ground(s) for divorce 0 are ~ 3301(c) and (d). 4. The action is contested with respect to the following claims: divorce, distribution of property, alimony pendente lite, and counsel fees. 5. The action 0 involves [gJ does not involve complex issues of law or fact. 6. The hearing is expected to take 1 day. 7. Additional information, if any, relevant to the motion: none. Date: .J~ l'\.lNl j '1 a ~ , (t.a> 1 AND NOW. ~/L - N :' . Cantor Attorney for Defendant ,2007, c3..~t/;eJ ~, Esquire, is appointed master with respect 0 the following claims: .b.,(J ~ I BY THE MOVING PARTY NAME: Travis L. Hurst ATTORNEY'S NAME: Debra D. Cantor ATTORNEY'S ADDRESS: 100 Pine Street Harrisburg, PA 17101 ATTORNEY'S TELEPHONE NO.: 717 -237 -5297 ATTORNEY'S EMAIL: dcantor@mwn.com PARTY'S ADDRESS & TELEPHONE NUMBER IF NOT REPRESENTED BY COUNSEL: J. NON-MOVING PARTY NAME: Nicole A. Hurst / ATTORNEY'S NAME:vCara A. Boyanowski ATTORNEY'S ADDRESS: 2080 Linglestown Rd Suite 201 Harrisburg, PA 17110 ATTORNEY'S TELEPHONE NO.: 717-540-9170 x125 ATTORNEY'S EMAIL: cbovanowski@ssbc-Iaw.com PARTY'S ADDRESS & TELEPHONE NUMBER IF NOT REPRESENTED BY COUNSEL: - 2 - 2!FI~ J~" ')~ UJ I I\;i ",b D>l I? l: 9 i" c:... ..; rlj 1::: I..A)'.' ~:.. I_;UNTY .~... McNEES WALLACE & NURICK LLC By: DEBRA D. CANTOR Attorney ID No. 66378 100 Pine Street Harrisburg, PA 17108-1166 (717) 237-5297 (717) 237-5300 facsimile dcantor@mwn.com Attorneys for Defendant Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 06-264 CIVIL TERM NICOLE A. HURST, v. TRAVIS L. HURST, IN DIVORCE Defendant DEFENDANT'S PETITION FOR EQUITABLE DISTRIBUTION PURSUANT TO PA R.C.P. 1920.15 AND NOW, comes Defendant Travis L. Hurst, by and through his counsel, McNees Wallace & Nurick LLC, and raises the following counterclaim: 1. A divorce was filed in the above captioned matter on January 11, 2006. 2. Defendant/Petitioner is Travis L. Hurst, an adult individual, currently residing at 5447 Rolling Road, Chambersburg, Franklin County, Pennsylvania, 17201. 3. Plaintiff/Respondent is Nicole A. Hurst, an adult individual, currently residing at 1455 English Drive, Mechanicsburg, Cumberland County, Pennsylvania. 4. Plaintiff and Defendant have legally and beneficially acquired property, both real and personal during their marriage. 5. 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 Petition. WHEREFORE, Defendant/Petitioner, Travis L. Hurst, respectfully requests this Honorable Court to equitably divide all marital property. Respectfully submitted, McNEES WALLACE & NURICK LLC ~- . . tor 1.0. 8 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorneys for Defendant Dated: January 17, 2007 -2- "_h.4. .. CERTIFICATE OF SERVICE The undersigned hereby certifies that on the F of~, 2007, a true and correct copy of the foregoing document was served by first-class 'ail, postage prepaid, upon the following: Cara A. Boyanowski, Esquire Serratelli, Schiffman, Brown & Calhoon, P.C. 2080 Linglestown Road, Suite 201 Harrisburg, PA 17110-9670 Counsel for Defendant R ~ ,...., -p co:> ~ c:::> _-J t- \t. ~ C- .-4 :;->". -:T--n :L: rl1p 0 1'..) .-;4 f"1-~ -r)y \) ~ 1-.~3 C~J -- - -0 ' " ~ 'f1 \ - ::--~J.,~~l -"'" ";1'\ ') i;-? :~~5 fn ,~ ~ ~ ~ 0.) ,:>" :!::::> :';0 u:> ~ t) ~ f: r-- r ~ NICOLE A. HURST, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. 06-264 CIVIL TERM TRAVIS L. HURST, IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on January 11, 2006. 2. The marriage of the plaintiff and defendant is irretrievably broken. Ninety days have elapsed since the date of service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: March /J , 2007 )> (") ~ 4,~.,. ~ C;:;;> ......J - ~ ...--:, sa ~ - s:- .~..,., 4~ f1c,; :2'0 " \ ;"~?~ (~?~ ':,' "\:; (~ ~~)\ ~\ ~; ::.< -0 ::g: - - C1J NICOLE A. HURST, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. 06-264 CIVIL TERM TRAVIS L. HURST, IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SAction 3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ~~// 7avis L. Hurst Date: March IS , 2007 n (,; 9 e::::> :-,.l ~ ~ - ;;:" ~ ..-::?~ -~~-"\~ \. \-r, -c; ..-, ~\~ '1; :;1~$} '{C?: n 'c; ::::.::". - .- ~eo ::.c. j':" cP NICOLE A. HURST, Plaintiff v. TRAVIS L. HURST, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-264 CIVIL TERM IN DIVORCE 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on January 11, 2006. 2. The marriage of the pi intiff and defendant is irretrievably broken. Ninety days have elapsed since the date of s rvice of the Complaint. 3. I consent to the ent of a final decree of divorce after service of notice of intention to request entry of the ecree. I verify that the statement made in this affidavit are true and correct. understand that false statements herein ar made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsific tion to authorities. D~e: March 20, 2007 ., ,L.~,jj C) ,--fjAd/i}- N(Cole A. Hurst .1:"""";:...... :,,:'\- .,--~ ._"'~ ,. () c <- -q en ~L' -.;..:"" ;...::.,-~~ ......_ I, (J.) .}~ '-<: ::.~ r-'~, :x~' :", :;-~1.. ; .:;; C) c: ~ ~ <:::) = ....... :x :I.> :;;0 N o ." :r:o m, -om :09 8Q o::D z~ ~ ~ " :t:: .c- .. -....J NICOLE A. HURST, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. 06-264 CIVIL TERM TRAVIS L. HURST, IN DIVORCE Defendant 1. I consent to the en ry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do ot claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statement made in this affidavit are true and correct. I understand that false statements herein are ade subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification t authorities. /~j,-t- Date: March 2.0, 2007 g ~ -0(1) rr',~; >~:s'~ ~t> y'C. z() ~c z -~ -- ~ <.5 ::JC. ~ rY q. ~:Q :B~' b - .~\ -'I" -c;.:p Q~ /-,.. 9 ?J5. - ~ -J ~ :;:&:. .s:: NICOLE A. HURST, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA VS. CIVIL ACTION - DIVORCE TRAVIS L. HURST, Defendant NO. 06-264 CIVIL TERM IN DIVORCE PACSES Case No.: 626107961 ORDER OF COURT AND NOW to wit, this 28th day of March 2007, it is hereby Ordered that, the Alimony Pendente Lite is terminated effective March 20, 2007 and Cumberland County Domestic Relations Section dismiss their interest in the above captioned matter pursuant to the parties' property settlement agreement. There is no balance due the Plaintiff. ~1~ Edgar B. Bayley, , J> DRO: R.J. Shadday xc: Petitioner Respondent Debra D. Cantor, Esq. Cara Boyanowski, Esq. Service Type: M Form OE-OOI Worker: 21005 (') ~~c t-' r;:;:;> = -J ~ N ...0 -0 -- .-.I"';" ~ -\ -r-n fn r:: -(1~ ~r~ ll~ j::~::\ (.:~ "."\':~ -+~ );") :":frl 2, 'V ~ .< c:? U1 o NICOLE A. HURST, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 06-264 CIVIL TERM CIVIL ACTION - LAW TRAVIS L. HURST, Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Debra Denison Cantor, Esquire, attorney for the in the above-captioned matter, hereby certify that service of the Complaint in Divorce filed in the above matter on January 11, 2006. Defendant I accept captioned rJllRllq lid ra Den: MCNEES, WA LACE 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 237-5297 Sworn and Subscribed to before me this f1~ day of cro..~ ,2006. ~A'~ NOTARY PUBLIC My Commission Expires: NOTARIAl SEAL MICHELE S. BEERY, Notary Pt.bIic City of HarrisbUrg, PA Dauphin County My Commission Expires July 6. 2006 ~ ~ = -..J ~ :::0 I &"" ~ -,",'" - - ~ s!-n rnhi ::g c;:: ;=~~~, : ~ iff; 8 .--1 "p. ~ C;) "., '"" Cara A. Boyanowski, Esquire SERRA TELL! SCHIFFMAN BROWN & CALHOON 2080 Linglestown Road Suite 20 I Harrisburg, P A 17110 (717) 540-9170 telephone (717) 540-5481 facsimile c boyan owski (tV,ss bc-la w. com Attorney for Plaintiff, Nicole A. Hurst NICOLE A. HURST, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW v. NO. 06-264 CIVIL TERM TRAVIS L. HURST, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under S3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: The divorce complaint, filed on January II, 2006, was served upon Defendant, through his counsel of record, Debra Denison Cantor, Esquire by first class mail, postage prepaid, on January 17,2006. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by S3301(c) of the Divorce Code: by Plaintiff: March 20,2007; by Defendant: March 13, 2007. (b)(1) Date of execution ofthe affidavit required by S3301(d) ofthe Divorce .- .... Code: NI A; (2) Date of filing and service of the Plaintiffs Affidavit upon the respondent: NI A. 4. Related claims pending: None. 5. (Complete either (a) or (b).) ( a) Date and manner of service of the notice of intention to file praecipe to transmit record; a copy of which is attached: NI A. (b) Date Plaintiffs Waiver of Notice in 93301(c) Divorce was filed with the Prothonotary: on March 21, 2007. (c) Date Defendant's Waiver of Notice in 93301(c) Divorce was filed with the Prothonotary: on or about March 14,2007. Respectfully submitted, SERRA TELL! SCHIFFMAN BROWN & CALHOON Cara A. Boyanowsk , Esquire Supreme Court J.D. No. 68736 2080 Linglestown Road, Suite 201 Harrisburg, PAl 711 0 (717) 540-9170 Attorney for Plaintiff ......, c:::> CC:::> --l ~ ::;0 I ,I:'" l...__,. (-,~ ~, -<., ~ ~"'1"'l fr\r: --nf11 ';1Y ~1 S;\ ,-",",-,.-. \;;-~O bfn ..-\ "i:>- ~ ?; ~~- - - - c:P <Ii <Ii <Ii <Ii <Ii <Ii <Ii <Ii <Ii <Ii <Ii <Ii <Ii <Ii <Ii<li<li <Ii <Ii <Ii <Ii <Ii<li <Ii<li <Ii <Ii <Ii <Ii <Ii <Ii<li<li<li<li<li<li~~ <Ii<li~~~<Ii <Ii~ <Ii IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF NICOLE A. HURST, VERSUS TRAVIS L. HURST, AND NOW, Plaintiff Defendant PENNA. No. 06-264 CIVIL TERM DECREE IN AND TRAVIS L. HURST ~\ DIVORCE \0 ~, IT IS ORDERED AND DECREED THAT NICOLE A. HURST , PLAINTIFF, , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. ~ ~ ~ ~ ;t; ;t; ;t; ;t; ;t; 0+; ;t; J. 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. ATTEST'f~/ PROTHONOTARY ~~~~ ~ ~ :t::+: 0+; 0+; ~~~ ~ ~~ ~~~:+;~:+;~~~~~~ ~~ :+;~:+;:+;:+;~~ ~~~~~ 0+; ~;t; ~ '" ;t; '" '" '" ~;t;;t; "'~ ;t; ;t; ~~f~ryu., .~47 ~ fJ ~ 4-rb;) .f'7J 'j. " ." . ,~... ~ LO' II. h , LO- II-If