HomeMy WebLinkAbout02-1224
CHRISTOPHER 1. RIZZUTO,
Plaintiff
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION - LA W ~
: NO. O~ - '~2.y (!,'u~l' '~
: IN DIVORCE
KRISTEN N. RIZZUTO,
Defendant
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth
in the following pages, you must take prompt action. You are warned that if you fail to do so, the
case may proceed without you and a decree of divorce or annulment may be entered against you by
the Court. A judgment may also be entered against you for any other claim or relief requested in
these papers by the Plaintiff. You may lose money or property or other 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
Prothonotary's Office, Cumberland County Courthouse, Cumberland, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S
FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY
LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE TillS 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 Referral Services
Cumberland County Bar Association
1 Courthouse Square
Carlisle, P A 17013
(800) 990-9108
CHRISTOPHER 1. RIZZUTO,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION - LAW
~ NO. 0;2 _ I~~
: IN DIVORCE
Gu~l ~~
KRISTEN N. RIZZUTO,
Defendant
COMPLAINT IN DIVORCE
AND NOW, comes the above-named Plaintiff, CHRISTOPHER 1. RIZZUTO, by and
through his attorney, ROBERT B. LIEBERMAN, ESQUIRE, and seeks to obtain a Decree in
Divorce from the above-named Defendant, KRISTEN N. RIZZUTO, upon the grounds
hereinafter set forth:
1. Plaintiff is CHRISTOPHER J. RIZZUTO, an adult individual, residing at 1502
Tussey Court, Mechanicsburg, Cumberland County, Pennsylvania.
2. Defendant is KRISTEN N. RIZZUTO, an adult individual, residing at 66 James Lee
Drive, Chambersburg, Franklin County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of
Pennsylvania for at least six (6) months previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on August 21, 1998 in Chambersburg,
Franklin County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The Plaintiff and Defendant are both citizens of United States of America.
7. The Defendant is not a member of the Armed Services of the United States.
8. The Plaintiff has been advised of the availability of marriage counseling and
understands that he may request that the Court require the parties to participate in counseling.
9. The Plaintiff avers that the marriage is irretrievably broken.
10. Plaintiff requests the Court to enter a Decree in Divorce.
WHEREFORE, Plaintiff, CHRISTOPHER J. RIZZUTO, respectfully requests this
Honorable Court to enter a Decree in Divorce pursuant to the Divorce Code.
Respectfully submitted,
DATED:
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Robert B. Lieberman, Esquire
500 N. Third Street, 12th Floor
P.O. 1004
Harrisburg, P A 17108-1004
(717) 236-1485
Attorney for Plaintiff
VERIFICATION
I verify that the statements made in the foregoing Complaint in Divorce are true and correct
based upon my personal 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.
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VITAL RECOllIlS
COUNTY
Cumberland
DIVORCE
1iI
RECORD OF
OR ANNULMENT
(CHECK ONE) 0
STATE FILE NUMBER
STATE FILE DATE
SS# 210-66-7195
HUSBAND
,. NAME IFIISII IMiddIol
Christopher J. Rizzuto_
3. RESIDENCE SlrNt Dr R.D. CilJ< -. '" 1ioop. CDunly
1502 Tussey Court, Mechanicsburg, Cumberland, PA
5, NUMBER
OF THIS
MAARIAGE
8. RACE
WHITE
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OTHER(~j
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WIFE
(LMIJ 2. DATE lMontlll (Dan \10.,
OF
BIRTH 10 / 19 / 77
SUM .. PlACE (S1II1' '" FfItfIign Coun'ry)
OF l'
BIRTH Pennsy van~a
7. USUAl. OCCUPil\'I1ON
Consultant
SS# 199-54-0204
8. 1oIAI0EN NAME (Fml (M_I (IMtJ I. DATE lMontllJ lOan -
OF /
Kristen N, Stahl IlIRTH 10 29 / 75
10. RESIDENce S,,","'R.D. CilJ<-''''lIop. Counly - 11. PlACe (SlIIle '" FfItfIign CDunlty)
66 James Lee Drive, Charnbersburg, !"ranklin, PA OF
IlIRTH Pennsylvania
'2. NUMBER 8. RACE 1., USUAl. OCCUI\fiT1ON
OF THIS WHITE IllACK OTHER (SoKIfyj
MAARIAGe 1 [] 0 0 Administrative Assistant
15, PlAce OF ~nlyl lSUM '" FfItfIign CounttyJ 18. DATE OF -I (DOYI IY""
THIS Chambersburg, Franklin County, THIS
MARAIAGE Pennsylvania lWlAIAGE 8 / 21 / 98
17A. NUMBER OF 178. NUMBER OF DEPENDENT 18. Pl.<lNTlFF 19. DECIlEE GFWfTa) 10
CHILOREN THIS CHILOREN UNOER 18 HUSIIAND WIFE OTHER (SpK;~ HUSIlAHD WIFE OTHERC_Iy)
MAARIAGe 0 0 !Xl 0 0 iii 0 0
20, NUMBeR OF HUSIlAHD WIFE SPUT CUSlOOY OTHER (SoeaIyt 21. LEGAL GROuNDS FOR
CHILOREN 10 0 0 0 DIYOACE OR ANNULMENT
CUSTOOY OF N/A Irretrievable Breakdown
22. DATE OF DECREE
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DATE REPORT SENT (_till
10 V1TAl ReCORDS
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ROBERT B. LIEBERMAN
ATTORNEY AT l"AW
CHRISTOPHER J. RIZZUTO,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v.
: NO. 02-1224
CIVIL TERM
KRISTEN N. RIZZUTO,
: CIVIL ACTION - LAW
: IN DIVORCE
Defendant
ACCEPTANCE OF SERVICE
I, Douglas G. Miller, Esquire, attorney for the Defendant in the above-captioned matter,
hereby agree on behalf of my client, Kristen N. Rizzuto, to accept service of the Complaint
which was filed on March 12, 2002.
~ II ;1A~1I~
Douglas . Miller, Esquire
Irwin, McKnight & Hughes
60 West Pomfret Street
Carlisle, P A 17013
Attorney for Defendant
Date: ~ r2~ ,2002
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CHRISTOPHER J. RIZZUTO,
PlaintifflRespondent,
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
No. 02 -1224 CIVIL TERM
KRISTEN N. RIZZUTO,
DefendantlPetitioner.
IN DIVORCE
PETITION FOR ALIMONY PENDENTE LITE
AND NOW, comes Petitioner, Kristen N. Rizzuto, by and through her attorneys, Irwin,
McKnight & Hughes, Esquires, and petitions the Court as follows:
1. Petitioner is the above-named Defendant, Kristen N. Rizzuto, an adult individual
currently residing at 66 Jameslee Drive, Chambersburg, Pennsylvania 17201.
2. Respondent is the above-named Plaintiff, Christopher J. Rizzuto, an adult
individual currently residing at 1502 Tussey Court, Mechanicsburg, Pennsylvania 17050.
3. Petitioner's date of birth is October 27, 1975, and her Social Security number is
199-54-0204.
4. Respondent's date of birth is October 19, 1977, and his Social Security number is
210-66-7195.
5. The Petitioner is employed as an administrative assistant at Pinnacle Risk
Management Services. Her net monthly income, as determined at the Domestic Relations
conference on April 24, 2002, is $1,219.54.
1
6. The Respondent is employed as a computer consultant at Informatrix. His net
monthly income, as determined at the Domestic Relations conference on April 24, 2002, is
$4,304.74.
7. The Petitioner is unable to support herself in the lifestyle to which she has been
accustomed during the marriage of the parties.
8. The Petitioner is in need of alimony pendente lite in order to support herself and
defend the divorce action filed at the above docketed number in the Court of Common Pleas of
Cumberland County by Respondent.
9. Respondent has sufficient income and earning capacity, as well as assets, to
support the Petitioner or to assist in supporting Petitioner and to pay alimony pendente lite to
Petitioner.
WHEREFORE, for the above reasons, Petitioner, Kristen N. Rizzuto, respectfully
requests this Honorable Court to enter an Order of Alimony Pendente Lite in this matter pursuant
to the determination of the Hearing Officer at the Domestic Relations conference on April 24,
2002, in the amount of $1,234.08 per month.
Respectfully submitted,
IRWIN, McKNIGHT & HUGHES
By:
Date: April 24, 2002
Miller, Esquire
Supreme ourt 1.D. No. 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Attorney for DefendantlPetitioner,
Kristen N. Rizzuto
2
VERIFICATION
The foregoing document is based upon information which has been gathered by my
counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section
4904, relating to unsworn falsification to authorities.
Date: ~dt/
,oJ
CERTIFICATE OF SERVICE
I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy
of the foregoing document upon the persons indicated below by first class United States mail,
postage paid in Carlisle, Pennsylvania 17013, on the date set forth below:
ROBERT B. LIEBERMAN, ESQUIRE
500 NORTH THIRD STREET
TWELFTH FLOOR
P.O. BOX 1004
HARRISBURG, PA 17108-1004
Date: April 24, 2002
IRWIN, McKNIGHT & HUGHES
Douglas
Supreme ourt 1.D. No. 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Attorney for Plaintiff,
Kristin J. Rizzuto
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CHRISTOPHER J. RIZZUTO,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v,
CIVIL ACTION - LAW
KRISTEN N. RIZZUTO,
Defendant
NO. 02-1224 CIVIL TERM
ORDER OF COURT
AND NOW, this 2nd day of May, 2002, upon consideration of Defendant's
Petition for Alimony Pendente Lite, the petition is referred in the first instance to Rickie
Shadday of the Domestic Relations Office.
BY THE COURT,
Robert B. Lieberman, Esq.
500 North Third Street
Twelfth Floor
P.O. Box 1004
Harrisburg, P A 17108-1004
Attorney for Plaintiff
_ ~ ~ .5/~/o;1..
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Douglas G. Miller, Esq.
60 West Pomfret Street
Carlisle, P A 17013
Attorney for Defendant
Rickie Shadday - )I a.rtI ~:tuV
Domestic Relations Office 5/3/0;) Au
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CHRISTOPHER N. RIZZUTO,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
VS.
CIVIL ACTION - DIVORCE
KRISTEN N. RIZZUTO,
DefendantIPetitioner
NO. 2002-1224 CIVIL TERM
IN DIVORCE
DR# 31687
Pacses# 197104486
ORDER OF COURT
AND NOW, this 6th day of May, 2002, based upon the Court's determination that Petitioner's monthly
net income/earning capacity is $1,219.54 and Respondent's monthly net income/earning capacity is
$4,304.74, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and
Disbursement Unit, $1,234.00 per month payable monthly as follows; $1,234.00 for alimony pendente
lite and $0.00 on arrears. First payment due within five days upon receipt of this order. Arrears set at
$1,234.00 as of May 6,2002. The effective date of the order is April 24, 2002.
The retroactive balance of$I,234.00 is to be paid in full within five days upon receipt of this order.
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.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 P A SCDU to: Kristen N. Rizzuto. Payments must be made by
check or money order. All checks and money orders must be made payable to PA SCDU and mailed
to:
PASCDU
P.O. Box 69110
Harrisburg, P A 171 06-911 0
Payments must include the defendant's P ACSES Member Number or Social Security Number in order
to be processed. Do not send cash by mail.
Unreimbursed medical expenses that exceed $250.00 annually are to be paid 0% by the respondent
and 100% by petitioner. The petitioner is responsible to pay the first $250.00 annually in
unreimbursed medical expenses. Respondent to provide medical insurance coverage. Within thirty
(30) days after the entry of this order, the Respondent shall submit written proof that medical
insurance coverage has been obtained or that application for coverage has been made. Proof of
coverage shall consist, at a minimum, of: 1) the name of the health care coverage provider(s); 2) any
applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims
should be made; 5) a description of any restrictions on usage, such as prior approval for hospital
admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage
contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms.
This Order shall become final ten days after the mailing of the notice of the entry of the Order to the
parties unless either party files a written demand with the Prothonotary for a hearing de novo before
the Court.
DRO: R. J, Shadday
Mailed copies on
5-6-02 to: <
BY THE COURT,
Petitioner
Respondent
Douglas Miller, Esquire
Robert Lieberman, Esquire
Edward E. Guido
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State Commonwealth of Pennsylvania
Co.lCity/Dist. of CUMBERLAND
Date of Order/Notice 05/06/02
Court/Case Number (See Addendum for case summary)
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
);,d, ~O;:). -/)-~V C/t/lL
fJF1C<;fS' /'77itJl/Lff-'
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@ Original Order/Notice
o Amended Order/Notice
o Terminate Order/Notice
) RE: RIZZUTO, CHRISTOPHER J,
) Employee/Obligor's Name (Last. First, Mil
) 210-66-7195
) Employee/Obligor's Social Security Number
) 6107100940
) Employee/Obligor's Case Identifier
) (S"" Addendum for plaintiff names associated with cases on attachment)
) Custodial Parent's Name (Last, First, Mil
)
EmployerlWithholder's Federal EIN Number
INFO-MATRIX CORPORATION
EmployerlWithholder's Name
3 BONNYWICK DR
EmployerlWithholder's Address
HARRISBURG PA 17111
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.
$ 1,234.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes <Xl no
$ 0.00 per month in medical support
$ 0 , 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 1,234.00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 284,77 per weekly pay period.
$ 569,54 per biweekly pay period (every two weeks).
$ 617,00 per semimonthly pay period (twice a month).
$ 1.234,00 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
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 pg. 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 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 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:
MAY
7 2002
BY THE COURT: ~
eM_H GO~:;~
Form E N-028
Worker ID $IATT
Service Type M
IW 1I.11_Ir~MBNO.:0970-0154
~iration Date: 12/31/00
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If checked you are required to provide a copy of this form to your employee.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment
to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to
each employee/obligor.
3.* Reporting tl,e PaydatelDate of Witl,holdil,g. You nlu~t lepol1 the p&ydateldate of "itl,l,oldilog ~hel, ~el,dilog the paymel,t. TI,e
paydateldate of "itl,holdilog i~ tl,e date 01, "hid, amount "a~ "ithheld 110m lI,e e,,,ployee'~ "age~. You must comply with the law of the
state of the employee's1obligor'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's1obligor's principal place of employment. You must honor all Orders/Notices to the greatest
extent possible. (See #9 below)
S. 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.
WITHHOLDER'S 10: 2517885700
EMPLOYEE'S/OBLlGOR'S NAME: RIZZUTO, CHRISTOPHER J.
EMPLOYEE'S CASE IDENTIFIER: 6107100940 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. 91673 (b)l; or 2) the amounts allowed by the State of the employee's1obligor'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.
10.
*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.
Requesting Agency:
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 (71 7) 240-6225 or
by FAX at (717\ 240-6248 or
by Internet @
Page 2 of 2
Form EN-028
Worker ID $IATT
Service Type M
OMB No.: 0970-0154
Expiration Date: 12/31/00
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: RIZZUTO, CHRISTOPHER J.
197104480/.3/& ft7 PACSES Case Number
Plaintiff Name
PACSES Case Number
Plaintiff Name
KRISTEN N, RIZZUTO
Docket Attachment Amount
02=1224 CIVIL$ 1,234.00
Child(ren)'s Name(s):
DaB
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PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
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identified above in any health insurance coverage available
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Service Type M
Attachment Amount
$ 0.00
Child(ren)'s Name(s):
Docket
DaB
you are required to enroll the child(ren)
in any health insurance coverage available
employee's1obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0,00
Child(ren)'s Name(s):
DOB
you are required to enroll the child(ren)
above in any health insurance coverage available
employee's1obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
Addendum
Form EN-028
Worker ID $IATT
QMB No.: 0970-0154
Expiration Date: 12/31/00
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CHRISTOPHER N. RIZZUTO,
PlaintifflRespondent
VS.
KRISTEN N. RIZZUTO,
DefendantlPetitioner
d-l CC;S
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 2002-1224 CIVIL TERM
IN DIVORCE
DR# 31687
Pacses# 197104486
DEMAIS:D FOR HEARING
DATE OF ORDER: May 6,2002
AMOUNT: $1,234.00 per month
FOR: Alimony Pendente Lite
REASON(S):
The amount of APL entered is ina ro riate in li ht of the exist' n
quidelines and applicable law,
PARTY Fll..ING DEMAND FOR HEARING:
fAt.::!: k. ~. M-.
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
KRISTEN N, RIZZUTO ) Docket Number 02-1224 CIVIL
Plaintiff )
vs. ) PACSES Case Number 197104486
CHRISTOPHER J. RIZZUTO )
Defendant ) Other State ID Number
ORDER OF COURT
You,
KRISTEN NICOLE RIZZUTO
plaintiff/defendant of
66 JAMES LEE DR, CHAMBERS BURG , PA. 17201-8227-66
are ordered to appear at DOMESTIC RELATIONS HEARING RM
DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13
before a hearing officer of the Domestic Relations Section, on the
JULy 16, 2002
at 1:30PM for a hearing,
You are further required to bring to the hearing:
1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, "
2. your pay stubs for the preceding six (6) months, n~
3. verification of child care expenses, and g
-"
4. proof of medical coverage which you may have, or may have available to r=
5. information relating to professional licenses ~ =
6. other: 5(")
-"
Form CM-509
Worker ID 21302
Service Type M
RIZZUTO
V. RIZZUTO
PACSES Case Number: 197104486
If you fail to appear for the conference/hearing or to bring the required documents, the
court may issue a warrant for your arrest or enter an order in your absence. If paternity is an
issue, the court may enter an order establishing paternity.
An appropriate order may be entered against either party based upon the evidence
presented without regard to which party initiated the support action.
BY THE COURT:
Date of Order:
G 24 02-
JUDGE
YOU HAVE THE R1GIIT TO A LAWYER, WHO MAY ATTEND THE HEARING 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 CO BAR ASSOCIATION
2 LIBERTY AVE
CARLISLE PA 17013-3308-02
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of CUMBERLAND County is required by law to
comply with the Americans with Disabilities Act of 1990. For infonnation about accessible
facilities and reasonable accommodations available to disabled individuals having business
before the court, please contact our office at: (717) 240-6225, All arrangements must be
made at least 72 hours prior to any hearing or business before the court. You must attend the
scheduled hearing,
Page 2 of 2
Form CM-S09
Worker ID 21302
Service Type M
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
KRISTEN N. RIZZUTO ) Docket Number 02-1224 CIVIL
Plaintiff )
vs. ) PACSES Case Number 197104486
CHRISTOPHER J. RIZZUTO )
Defendant ) Other State ID Number
ORDER OF COURT
You,
CHRISTOPHER JAMES RIZZUTO
plaintiff/defendant of
1502 TUSSEY CT, MECHANICSBURG, PA, 17050-7695-02
are ordered to appear at DOMESTIC RELATIONS HEARING RM
DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13
before a hearing officer of the Domestic Relations Section, on the
JULY 16, 2002
at 1: 30PM for a hearing.
You are further required to bring to the hearing:
1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed,
2. your pay stubs for the preceding six (6) months,
3. verification of child care expenses, and
4. proof of medical coverage which you may have, or may have available to
5. information relating to professionailicenses
6. other:
Service Type M
Form CM-509
Worker ID 21302
RIZZUTO
v. RIZZUTO
PACSES Case Number: 197104486
If you fail to appear for the conference/hearing or to bring the required documents, the
court may issue a warrant for your arrest or enter an order in your absence. If paternity is an
issue, the court may enter an order establishing paternity,
An appropriate order may be entered against either party based upon the evidence
presented without regard to which party initiated the support action.
BY THE COURT:
Date of Order: -fJ 24102-
JUDGE
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING 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 CO BAR ASSOCIATION
2 LIBERTY AVE
CARLISLE PA 17013-3308-02
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of CUMBERLAND County is required by law to
comply with the Americans with Disabilities Act of 1990. For information about accessible
facilities and reasonable accommodations available to disabled individuals having, business
before the court, please contact our office at: (717) 240-6225. All arrangements must be
made at least 72 hours prior to any hearing or business before the court. You must attend the
scheduled hearing.
Page 2 of 2
Form CM-509
Worker ID 21302
Seryice Type M
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DOMESTIC RELATIONS SECTION
PACSES NO. 197104486
NO. 02-1224 CIVIL TERM
CHRISTOPHER J. RIZZUTO,
Plaintiff/Respondent
KRISTEN N. RIZZUTO,
DefendanUPetitioner
INTERIM ORDER OF COURT
AND NOW, this 19th day of July, 2002, upon consideration of
the Support Master's Report and Recommendation, a copy of which is attached
hereto as Exhibit "A", it is ordered and decreed as follows:
A. The husband shall pay to the State Collection & Disbursement Unit in
Harrisburg, Pennsylvania, for transmission to the wife the sum of
$1,199.00 per month as alimony pendente lite.
B. Except as modified herein, the order of May 6, 2002, shall remain in
full force and effect.
The parties are hereby advised that they may file written exceptions to the
Support Master's Report and Recommendation within ten (10) days of this order.
Exceptions shall conform with the requirements of Rule 1910.12(f), Pa. RC.P. If
written exceptions are filed by any party, the other party may file exceptions
within ten (10) days of the date of service of the original exceptions. If no
exceptions are filed within ten (10) days of this interim order, this order shall then
constitute a final order.
By the Court,
CC: Christopher J. Rizzuto
Kristen N. Rizzuto
Robert B. Lieberman, Esquire
Douglas B. Miller, Esquire
DRO
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DOMESTIC RELATIONS SECTION
PACSES NO. 197104486
NO. 02-1224 CIVIL TERM
CHRISTOPHER J. RIZZUTO,
Plaintiff/Respondent
KRISTEN N. RIZZUTO,
DefendanUPetitioner
SUPPORT MASTER'S REPORT AND RECOMMENDATION
Following a hearing held before the undersigned Support Master on July
16, 2002, the following report and recommendation are made:
FINDINGS OF FACT
1. The Plaintiff in this divorce action is Christopher J. Rizzuto, who
currently resides at 2613 Cinder Street, Chambersburg, Pennsylvania.
2. The Defendant is Kristen N. Rizzuto, who currently resides at 66
Jameslee Drive, Chambersburg, Pennsylvania.'
3. The parties were married on August 21, 1998.
4. There are no children of the marriage.
5. The parties separated on or about February 11, 2002, when the
husband requested the wife to move from the marital residence.
6. On or about March 12, 2002, the husband commenced this divorce
action.
7. On or about April 24, 2002, the wife filed a petition for alimony
pendente lite (hereafter "APL").
8. The wife is employed as an administrative assistant for Pinnacle Risk
Management Services, Inc. where her gross monthly income is
$1,582.00.
9. The wife currently resides with her parents.
10. Since the separation the wife has been paying approximately $579.00
per month on a loan and credit card bills for items purchased and
charges made during the marriage.
1 The parties will hereafter be referred to as the husband and the wife.
Exhibit "A"
11. Since June, 2002, the wife has been paying approximately $375.00
per month on the mortgage encumbering the martial residence.
12. Immediately following the separation the husband remained in the
marital residence.
13. The husband moved from the marital residence in late May and
currently resides with a female roommate with whom he shares
expenses.
14. The husband paid the mortgage while residing in the marital residence
and has been paying approximately $390.00 per month on the
mortgage since June, 2002.
15. The husband is employed as a consultant for Info-Matrix Corporation
where he earns approximately $1,442.00 per week.
DISCUSSION
Whether to award alimony pendente lite has traditionally been a matter
within the discretion of the trial court. Litmans v. Litmans, 673 A.2d. 382 (Pa.
Super. 1996). If an award of APL is warranted, the amount of that award is
calculated in accordance with the support guidelines. Little v. Little, 47
Cumberland L. J. 131 (1998). Before that calculation is made, however, a
determination must be made as to the entitlement to the award. Clouse v.
Clouse, 50 Cumberland L.J. 167 (2001). To be entitled to an award of APL, a
claimant must show that APL is needed to adequately prosecute or defend the
divorce action. Litmans v. Litmans. SUDra. The purpose of APL is to prevent one
spouse from being financially disadvantaged during the pendency of the action
as compared to the other. Powers v. Powers, 615 A.2d. 459 (Pa. Super. 1992).
Traditionally the fact that one spouse may earn less than the other does not
automatically entitle him or her to an award of APL. Sutliff v. Sutliff, 474 A.2d.
599 (Pa. Super. 1984), overruled on other arounds, Rosen v. Rosen, 549 A.2d.
561 (Pa. Super. 1988). In determining whether an award of APL is appropriate in
a case, the trier of fact may consider the husband's ability to pay, the separate
estate and income of the wife, and the character, situation, and surroundings of
the parties. Orr v. Orr, 461 A.2d. 850 (Pa. Super. 1983).
The husband has conceded that because of the significant disparity in the
incomes of the parties, the wife is entitled to an award of APL. He argues,
however, that the award should not be an amount calculated pursuant to the
support guidelines. However, he overlooks the mandate contained in Pa. R.C.P.
191 0.16-1 (b) which states that "[t]he amount of support (child support, spousal
support or alimony pendente lite) to be awarded pursuant to the procedures
under Rules 1910.11 and 1910.12 shall be determined in accordance with the
support guidelines. . . . " (emphasis added). Although the award may be subject
to deviation if the circumstances of the case warrant, the starting point is the
calculation of a guideline figure.
The wife has a gross monthly income of $1 ,582.00. If the divorce action is
not finalized in 2002, both parties will file federal income tax returns as
married/separate. The tax deductions shown on Exhibit A are calculated on this
filing status. After the permitted deductions, her net monthly income is
$1,275.00.
The husband has gross monthly income of $6,249.00. After the permitted
deductions, his net monthly income is $4,273.00. The husband's monthly APL
obligation to the wife as calculated pursuant to the guidelines is $1,199.00.2 A
support obligation calculated pursuant to the guidelines is presumed to be
correct, but the presumption can be rebutted by evidence that the guideline
award is unjust or inappropriate under the circumstances of the case. Landis v.
Landis, 691 A.2d. 939 (Pa. Super. 1997). There is no such evidence in this case.
The wife is paying $579.00 per month on a bill consolidation loan and credit card
debt for obligations incurred jointly by the parties during the marriage. She is
also paying $375.00 per month on the mortgage encumbering the marital
residence despite the fact that the husband voluntarily chose to move out of the
residence to reside with a female friend. Although her day-to-day living
expenses are greatly reduced because she is presently residing with her parents,
after the payments are made on the various joint debts as stated, the guideline
award effectively provides her with only $245.00 per month to supplement her
income and to litigate the divorce action. There is no reason to deviate
downward from the guideline support figure as suggested by the husband.
RECOMMENDATION
A. The husband shall pay to the State Collection & Disbursement Unit in
Harrisburg, Pennsylvania, for transmission to the wife the sum of
$1,199.00 per month as alimony pendente lite.
B. Except as modified herein, the order of May 6, 2002, shall remain in
full force and effect.
":! v...~ \ tt, 2. 00 2,..
Date
~ (L..-ill ~tLk
Michael R. Rundle
Support Master
2 The calculation is shown on Exhibit B.
In the Court of Common Pleas of Cumberland County, Pennsylvania
Plaintiff Name:
Defendant Name:
Docket Number:
PACSES Case Number:
Other State ID Number:
Tax Year:
1. Fling Status
Kristen N. Rizzuto
Christopher J. Rizzuto
02-1224 Civil
197104486
$327.08
$250,00
$5,671.59
$1,301.91
6. Deduction Amount
7. Exem tion Amount
8. Income MINUS Deductions and Exem tions
9. Tax on Income
10. Child Tax Credit
11. Manual Ad'ustments to Taxes
12. Federal Income Taxes
12 a. Earned Income Credit
13. State Income Taxes
14. FICA Pa ments
15. City Where Taxes Apply
16. Local Income Taxes
SupportCalc 2002
$1,301.91
$174.96
$436.05
$62.49
TOTAL Taxes
$1 975.41
Exhibit "I!."
1
$1,582.00
$327.08
$250.00
$1,004.92
$125.74
$125.74
$44.30
$121.02
--Select--
$15.82
$306.88
In the Court of Common Pleas of Cumberland County, Pennsylvania
Plaintiff Name:
Defendant Name:
Docket Number:
PACSES Case Number:
Other State ID Number:
Kristen N. Rizzuto
Christopher J. Rizzuto
02-1224 Civil
197104486
Net Income
$4,273.26
$1,275.12
$2,998.14
3. Difference
4, Less Child Obli ation for Current
5. Less All Other Su ort
ort $2,998.14
7. Multi I b 30% or 40% 40.00%
8. Amount of Monthl S ousal $1,199.26
Date: 7/17/2002
SupportCa/c 2002
Exhibit "B"
Ilmm
PINNACLE ISIMS
p,o. BOX 19990
PORTLAND, OR 97280-0999
Taxable Marrtal Status: Married
Exemptions/Allowances:
Federal: 0
State: N/A
Earnings
Regular
Holiday
Vacation
Social Securrty Number: 199-54-0204
rate hours this period
9.7339 73.75 717.88
9.7339 7.50 73.00
year to date
9,119.07
212.06
573.61
9,904.74
~9i~!l'~Y$7~iHI)$
Deductions
Statutory
Federal Income Tax
Social Security Tax
Medicare Tax
PA State Income Tax
Other
Checking 1
Medical Exempt
401(K) $
122.50
1,485.69
-38,60
-47.95
-11.21
-21.65
480.30
606.50
141.84
273.89
-535.34
-17.50*
-118.63*
H.f!l'~y?
\:'$QjijQ>
* Excluded from federal taxable wages
Your federal taxable wages this period are $654.75
Earnings Statement
Period Ending:
Pay Date:
07/1 5/2002
07/15/2002
KRISTEN N RIZZUTO
66 JAMESLEE DRIVE
CHAMBERSBURG, PA 17201
Other Benefits and
Information
Float
Vacation
this period
total to date
22.50
32.89
Cl!l91 ADP.lre
De osited to the account of
KRISTEN N RIZZUTO
"nk of Am
transit ABA
2313 7997
NON-NE
PLAINTIFPS
EXHIBIT
l
WH
In the Court of Common Pleas of
County, Pennsylvania
Phone:
Fax:
Plaintiff Name:
Defendant Name:
Docket Number:
PACSES Case Number:
Other State ID Number:
Please note: AU correspondence must include the PACSES Case Number.
Income and Expense Statement
THIS FORM MUST BE FILLED OUT
(If you are self-employed or if you are salaried by a business of which you are owner in whole or part, you must
also fill out the Supplemental Income tatement which appears on page two of this income and expense
statement. )
INCOME STATEMENT OF
Itemized Payroll Deductions:
Section I: Income and Insurance
INCOME:
Employer
Address
Type of Work
Payroll No, Gross Pay per Pay Period $
Federal Withholding $3i'.,.... Social Security H..nq,'i' Local Wage Tax $
State Income Tax $..:)I,/D' Retirement $ /JF;/.1 Savings Bonds $
Credit Union $ Lite Insurance $ Health Insurance $ f VIa
Other Deductions (specify) $ $
$ $
Net Pay per Pay Period $ 55 S': JS'
OTHER (Pill in Appropriate Column)
INCOME WEEK MONTH YEAR
Interest $ $ $
Dividends
Pension
Annuity
Social Security
Rents
Royalties
Expense Account
Gifts
Unemployment
Workmen's
Compensation
Other
Other
TOTAL $ $ $
TOTAL INCOME $
PROPERTY Ownership *
OWNED DESCRIPTION VALUE H W J
Checking Accounts $
Savings Accounts
Credit Union
Stocks/Bonds
Real Estate
Other
TOTAL 1$
* H=Husbaud: W=Wifp' .
PLAINTIFPS
EXHIBIT
Service Type
2 t-FH
J
Income and Expense Statement
PACSES Case Number
Coverage ..
INSURANCE
COMPANY POLICY # H W C
HosDita1
Blue Cross
Other
Medical
Blue Shield
Other
Health! Accident
Disability Income
Dental
Other
* H=Husband; W=Wife; C=Child
Section II: Supolemental Income Statement
a. This form is to be filled out by a person
o (1) who operates a business or practices a profession, or
o (2) who is a member of a partnership or joint venture, or
o (3) who is a shareholder in and is salaried by a closed corporation or similar entity.
b. Attach 10 this statement a copy of the fOllOWing documents relating to the partnership, joint venture, business, profession,
corporation or similar entity:
(I) the most recent Federal Income Tax Return, and
(2) the most recent Profit and Loss Statement
c. Name of business:
Address and telephone number:
d. Nature of business (check ODe)
o (I) partnership
o (2) joint venture
o (3) profession
o (4) closed corporation
o (5) other
e. Name of accountant, controller or other person in charge of financial records:
f. Annual income from business:
(I) How often is income received?
(2) Gross income per pay period:
(3) Net income per pay period:
(4) Specified deductions, if any:
Service Type
Page 20f3
Form IN-D08
Worker ID
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Income and Expense Statement
PACSES Case Number
Section III: Expenses
Instructions: Only show extraordinary expenses in this section unless you filled out Section II on page two. The categories
in BOLD FONT are especially important for calculating child support, If you are requesting Spousal SupporV APL or if
you assert your case cannot be detennined according to the guideline grids or formula, this section must be fully completed.
(Fill in Appropriate Column)
EXPENSES
WEEK MONTH YEAR
Home Y.-v1lJ.'"j ... /\^
I ",llr 11 J( J(
Mortgage/Rent $ ..J.L $31,",.1\ $
Maintenance
Utilities
Electric $ $ $
Gas
Oil
Telephone
Water
Sewer
Emnlovment
Public Transport. $ $ $
Lunch
Taxes
Real estate $ $ $
Personal Property
Insurance
Homeowner's $ $ hll-l-h /OJ ,SJj., i [ l~'" h
Automobile U6.~.;l") I
Life
Accident
Health -,-f;6.()l>
Other
Automobile
Payments $ $2Tk.M $
Puel t06.f>O
Repairs
Medical
Doctor $ $ $
Dentist
Orthodontist
Hospital
Medicine
I Special needs
(glasses. braces,
.vie"'l
~
EXPENSES (Fill in Appropriate Column)
(continued) WEEK MONTH YEAR
Education
Private School $ $ $
ParocbiaJ School
College
Religious
Personal
Clothing $ $ $
Food
Barberi
.Hairl!n:sser
Credit Payments LJ .2 Loo
Credit Card
Charge
Memberships
Loans
Credit Union $ $ $
I( ';, III- ,"/llI I."\:?d.l
Miscellaneous
Household Help $ $ $
Child care
Paperslbooks
Ma~azines
Entertainment
Pay TV
Vacalian
Gifts
Legal rees :JOIH,O
Chantable
Contributions
other Child
,...mnn..;
AJfuiony
Payment.
Other
$ $ $
WEEK
$
Service Type
Page 3 of3
Form IN-008
Worker ID
. .
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Total Payment Due
04/05/02
$7816.77
$153.27 Due Date
Prior Balance
$7 970.04
Current Balance"
*Payments received after the 'as of' dale wi not be reflected on this statement. Please maiJ your payment 5-7 days prior to the due date to ensure that it is received by us on or before the due date.
OESCRIPTION AS OF PAYMENTS APPLIED TO APPLIEO TO SERVICES!
03/1 S/02 & CREOITS BALANCE INTEREST/FEES PROOUCTS
Previous Amount Billed 02/14/02 153.27
Regular Payment Amount 04/05/02 153.27
Payment 03/13/02 -153.27 -153.27
RSGE01 771
'NOTE: Not a PavofI Balance. Oaferred interest, if any, not included. Your c,ontl'$Cl m,a y, p,rovidaJor.arefilnd ~ ,ulll!8med interest or a prepayment p~1lv ij the account is prepaid. In
add~ion. if your aCcount has been extended, is '/nleresf short.' or if a check in payinent oh' Sheen relIIrried ll/lpa!d, there maybe unpaid Iare charges, interest or NSF check
charges no reflected on this statement. If your account is precomputed andyo~ have rllC8IV, .l!n8ior.the ext.8IJsion fee charge is 1101 reflected on 1his statement.
FOR STATEMENT INQUIRIES:
CitiFinancial
3401 HARTZDAlE DRIVE #126
POBOX 13
CAMP Hill, PA 17001-0013
(717) 737-0431
In Pennsylvania; CitiFinancial, Inc.: CiliFinancial Services, Inc.
c~D'oITrONAL FUNDS, CALL
17),737-0431
9lJIi ACCOUNT NUMBER:
0799~0399725
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PLAINTIFFS
EXHIBIT _
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Discover Platinum Card Account Summary
account number
payment dus da.
minimum payment due
- credit limit
_ credit available
_ cash ctedit limit
cash credit available
-
Closing Date: March 11, 21102
page 1 012
6011 002860149137
April 1 0, 2002
$281.00
$7,000
$0
$3,500,00
$0.00 ~
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previous balance
payments andcreclits
purchases
cash advancss
balance transfers
FINANCE CHARGES
new balance
You may ba able to 8NOid Periodic Finance Chatges. see the
reverse side for detals.
$6,924.71
0.00
+ 64.00
+ 0.00
+ 0.00
+ 101.59
= $7,090.30
Transactions
Other/Miscellaneous
trans.
date
Marl1
Marll
post
date
Marll
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Your account is past due. Please pay the past dus amount now, or contact us to make other IlmIIIgements.
We understand how important your credit is to youl Please remember that we must receive payments by thepayment
dua date. For your convenience, you may make payments online at Discove/Cl//'d.com, over tha phone (processing fee
extra), or by mail. Allow 7 to 10 dar- for mail delivery.
Transaction
Average Daly ANNUAL Periodic Fee
Daily Penodic PERCENTAGE FINANCE FINANCE Rats
Balances Ratss RATES CHARGES CHARGES Plan
-
CUrtent bilUng period: 28 dar-
Purchases $6973.57 0.05203" 18.99" $101.59 none fixed
Cash Advances $0 0.057!i1 " 20.99" $0 $0 fixed
Questions? Call1-800-DISCDVER (1-800-347-2683) or log on to Dlscaven:ard.com. For TOO (Telecommunication Device for
the Deal) a.llIt.n.... ... reve... side, Send ~llIlng enor lIoUc:eto: Olscover Platinum: P,O. Box 15192; Wilmington, DE 19850-5192.
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Account Numb... 5121.0717-8278-4478
rvloe,1-80G-66908488
10F1
BIlling Cycle
Clang Date
04J071ll2
Payment
Due Date
05105102
Regular Transactions
Trana Poat
Date Date
03,08 03,08
03,30 04-01
Q4.Q2 04,03
-""-"""'.,."""'.,......."""-"""-_........_.~..".,'~-"~"..,..,. '..""'..;_..,.,~..'._.'4
DATE
STORE
REFERENCE
NUMBER
DEPT, NO.
BON'TON TRANSACTION DESCRIPTION
PURCHASES & PAYMENTS, RETURNS
OTHER CHARGES & OTHER CREDITS
3/19 50
20049201
PAYMENT, THANK YOU
20.00
() ~ ~\o'J-
~ LA\l \b11
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HOP IN FOR KIDS' EASTER SAVINGS STARTING WED. ,MARCH 20.TAKE 25-30% OFF
ALL EASTER DRESSES,ORESSWEAR AND ACCESSORIES FROM RARE EDITIONS,JENNY,
BYER,BABY TOGS,RIVIERA,TRIMFIT AND MORE.SALE ENDS SAT. ,MARCH 30.
PREVIOUS TOTAL PURCHASES TOTAL TOTAL fiNANCE THIS IS YOUR PAYMENT THIS IS YOUR
BALANCE & OTHER CHARGES CREDITS PAYMENTS CHARGE NEW BALANCE OVERDUE MINIMUM PAYMENT
409.50 0.00 0.00 20.00 7.21 396.71 0.00 19.00
AVERAGE PERIODIC ANNUAL BON'TON ACCOUNT ACCOUNT Bill CLOSING DATE
DAilY BALANCE RATE % RATE INfORMATION NUMBER
400.761 1.8% 21. 6% I CREDIT LINE $600 105691299 4/21/02
AVAIL CREDIT $203
-....._~..M....._"-..._~..~_..,,,...,,_,_.
POSTING
DATE
OeSCRIPTlON
REFERENCE NUMBER,,.
03-07 715230020671170004805631
1
1
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1
1
1
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03-07 PAYMENT RECEIVED -- THANK YOU
103.00P~
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. ,,'AVERAGE ',i:""
DAILY BAUlNCE "','
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42.28
.00$
NOTICE: SEe REVERSE SIDE FOR IMPORTANT INFORMATION.
".^'.,. '~-'~'--""--I__"_~.......n._._,~,.,..._,...,..".
KRISTEN N RIZZUTO
At Your Service
HOUSEHOLD BANK MASTERCARD STATEMENT
24-Hour Customer Service: 1-800-477-6000 WWW.hbcard.com
TOO for hearing/speech impaired: 1-800-395-9020
Call collect for Customer Service outside of the U,S,: 1-757-523-3880
Mail written inquiries to: HOUSEHOLD CREDIT SERVICES. PO BOX 81622. SALINAS, CA 93912-1622
Send payments to: HOUSEHOLD CREDIT SERVICES. P,O, BOX 88000 . BALTIMORE. MD 21288-0001
.
This is a grace account Nominal
Grace period Average Daily Days Finance Charges Annual
in1ormation Daily Periodic In Billing AI Periodic Percentage
on back. Balance Rat. Cycle Rei. Rat.
PURCHASES $3,547,30 .06570% 28 $65.26 23,99%
PURCHASES $726,11 .06570% 28 $13,38 23.99%
CASH ADVANCES $0,00 .06570% 28 $0,00 23,99%
ANNUAL PERCENTAGE RATE" 23.990%
'May be higher than nominal Annual Percentage Aate if statement includes misc. finance charges.
001200 24
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STMT36 D
Page 1 011
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Please enclose the bottom portion at your statement with your payment so that our address appears in Ihe window,
-".~...'..--."......_~~..,'
Christopher J. Rizzuto - Expenses
Rent
Phone
TV
Internet
Electric
water
sewer
trash
gas
groceries
visa
mc
student loan
insurance
cell phone
lunch
car
dinner
mortage
390
90
82
52
90
12.00
6
9
300
200
80
52
176
240
150
200
407
50
390
2976 TOTAL
alimoney
1234
4210 GRAND TOTAL
DEFENDANT'S
EXHIBIT
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;".TEL 7'17.260-9850
.. LJ3 BO~ICK DRIVE
HARRISBURG. PA 17111
earnIngs StIll~:?~\rIEt)
Pay Period: 3/0112002 \~""~'1~:':/i :' i
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Pay Date; 4/04/2002 '"
Check'; 10187
Employee Nul1'blr:
Depertll'lllnt Number:
Social Security Number:
Mari1a/ Sl8Ius:
NUl1'blr or AllOwIiInces:
Rate:
0036
210-66-7195
MARRIED
00
36.0500
CHRISTOPHER J RIZZUTo
1502 TUSSEY COURT
MECHANICSBURG, PA 17050
""
-HM;
HOUI8 .nd Eernlnp TlIXlIe and 0lIctucltkm.
DIl8criDtion Hours This Period Year-To-Date Descrilltion This Perillld Year- To-Dele
REGLAR 162.50 5858.13 21765,20 FICA 470.21 1950.47
VACTON 1153.60 FED WT 1013.44 4164,53
SICK 8.00 288.40 1423.98 PA ST 172.10 713.89
HDAYOl 1153.60 Middlt 61. 47 254.97
VACBAL 21. 36
I SCKllAL 16.50
, HOLBAL - 32.00
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$6,146.63
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$1,717.22
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DEFENDANT'S
EXHIBIT
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CHRISTOPHER J. RIZZUTO,
Plaintiff /Respondent,
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
No. 02 - 1224 CIVIL TERM
KRISTEN N. RIZZUTO,
Defendant/Petitioner.
IN DIVORCE
PETITION FOR SPECIAL RELIEF
AND NOW, comes Petitioner, Kristen N. Rizzuto, by and through her attorneys, Irwin,
McKnight & Hughes, Esquires, and petitions the Court as follows:
1. Petitioner is the above-named Defendant, Kristen N. Rizzuto, an adult individual
currently residing at 66 Jameslee Drive, Chambersburg, Pennsylvania 17201.
2. Respondent is the above-named Plaintiff, Christopher J. Rizzuto, an adult
individual currently residing at 1502 Tussey Court, Mechanicsburg, Pennsylvania 17050.
3.
On March 12,2002, Respondent filed a Complaint in Divorce.
(0
4,
On April 24, 2002, Petitioner filed a Petition for Alimony Pendente Lite.;:; ','
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5,
On May 6, 2002, an Order of Court was issued awarding Alimony Pel}~h~e Ute
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in the amount of$1,234.00 per month to Petitioner.
,
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Respondent filed an appeal from said Order, and following a hearing oefortf,,fue 2?
6.
Cumberland County Support Master, an Interim Order of Court was issued dated July 19,2002,
awarding Alimony Pendente Lite in the amount of$1,199.00 per month to Petitioner. A true and
correct copy of said Interim Order of Court is attached hereto and incorporated herein as Exhibit
"A."
1
7. No parties have filed exceptions to the Support Master's Report and
Recommendation, and therefore the Order dated July 19,2002 is now a final Order.
8. The Support Master's Findings of Fact attached to Exhibit "A" include that
Respondent remained in the marital residence following the parties' separation and then moved
in late May to reside with a female roommate.
9. Respondent, however, did not pay either the mortgage payment due May 1,2002,
nor the utility bills through the date that he moved from the residence.
10. Notices of nonpayment for these items were received by Petitioner and forwarded
by her legal counsel to Respondent's legal counsel for payment.
11. To date, both the mortgage payment due May 1, 2002 and the utility bills remain
unpaid despite repeated requests for payment.
12. The parties had agreed that for the mortgage payments beginning June 1, 2002,
Respondent would pay approximately $390.00 per month and Petitioner would pay
approximately $375,00 per month to satisfy the mortgage payments until the property was sold.
13. This agreement was stated in testimony before the Support Master and included in
the Master's Report and Recommendation.
14. Following the issuance of the Order attached as Exhibit "A," Respondent has
failed and refused to contribute payments to the mortgage obligation.
15. Furthermore, Respondent left the marital residence In deplorable condition
delaying the listing and sale of the marital residence.
16. Until the condition of the residence is improved, the realtor agreed upon by the
parties refuses to list the home for sale,
2
17. Despite repeated requests to Respondent's legal counsel that the clothes and other
personal property items left by Respondent be removed, the deplorable condition remains and
Petitioner has been forced to hire one or more individuals to permanently remove said items and
clean the residence.
18. In addition, the parties had agreed to file joint federal and state income tax returns
for tax year 2001.
19. The agreement, however, included the provision that Respondent would pay the
tax owed on both returns, as the reason for the deficiency is due primarily to Respondent's
refusal to allow enough withholdings on his monthly paychecks.
20. On behalf of his client, Respondent's legal counsel had indicated that the taxes
owed would be paid by Respondent.
21. Other than the initial required installment, however, Respondent has failed and
refused to satisfy the federal income tax deficiency.
22. Respondent's continued refusal to pay said taxes has resulted in the assessment of
penalties and interest. A true and correct copy of an IRS Notice dated August 12, 2002, is
attached hereto and incorporated herein as Exhibit "B."
23. As a direct result of Respondent's continued refusal to cooperate in the listing of
the marital residence for sale, and to abide by his prior promises and agreements, the Petitioner is
unable to continue to support herself in the lifestyle to which she has been accustomed during the
marriage of the parties.
24. As a direct result of the above, Petitioner has incurred and will incur significant
additional attorney fees in order defend her interests in the divorce action.
3
25. The Petitioner is in need of an increase in the current monthly alimony pendente
lite in order to support herself and defend the divorce action filed by Respondent at the above
docketed number in the Court of Common Pleas of Cumberland County.
26. Respondent has sufficient income and earning capacity, as well as assets, to
support the Petitioner or to assist in supporting Petitioner and to pay additional alimony pendente
lite to Petitioner.
WHEREFORE, for the above reasons, Petitioner, Kristen N. Rizzuto, respectfully
requests this Honorable Court to enter an Order increasing the amount of Alimony Pendente Lite
to be paid to Petitioner in this matter and/or to direct Respondent to satisfy both the outstanding
mortgage payment, the outstanding utility bills incurred while he was residing at the marital
residence and the federal income tax lien, as well as such other and further relief and may be
necessary or just.
Respectfully submitted,
IRWIN, McKNIGHT & HUGHES
By:
Date: August 16,2002
Dougla er, Esquire
Supreme Court I.D. No. 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Attorney for DefendantJPetitioner,
Kristen N. Rizzuto
4
VERIFICATION
The foregoing document is based upon information which has been gathered by my
counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa,C.S.A. Section
4904, relating to unsworn falsification to authorities.
Ujj~~llf
Date: August 16
, 2002
EXHIBIT "A"
CHRISTOPHER J. RIZZUTO,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DOMESTIC RELATIONS SECTION
V.
KRISTEN N. RIZZUTO,
Defendant/Petitioner
PACSES NO. 197104486
NO. 02-1224 CIVIL TERM
~~CG@:UW~~
JUL 20 2002
INTERIM ORDER OF COURT
AND NOW, this 19th day of July, 2002, upon cOl'JltMlat,\\\lNmr.~I & HUGHES
the Support Master's Report and Recommendation, a copy of IM1Yc~ig~l\'a~Stl
hereto as Exhibit "A", it is ordered and decreed as follows:
A. The husband shall pay to the State Collection & Disbursement Unit in
Harrisburg, Pennsylvania, for transmission to the wife the sum of
$1,199.00 per month as alimony pendente lite.
B, Except as modified herein, the order of May 6, 2002, shall remain in
full force and effect.
The parties are hereby advised that they may file written exceptions to the
Support Master's Report and Recommendation within ten (10) days of this order.
Exceptions shall conform with the requirements of Rule 1910.12(f), Pa. R.C.P. If
written exceptions are filed by any party, the other party may file exceptions
within ten (10) days of the date of service of the original exceptions. If no
exceptions are filed within ten (10) days of this interim order, this order shall then
constitute a final order.
CC: Christopher J. Rizzuto
Kristen N. Rizzuto
Robert B. Lieberman, Esquire
Douglas B. Miller, Esquire
DRO
CHRISTOPHER J, RIZZUTO,
Plaintiff/Respondent
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DOMESTIC RELATIONS SECTION
PACSES NO. 197104486
NO. 02-1224 CIVIL TERM
KRISTEN N. RIZZUTO,
Defendant/Petitioner
SUPPORT MASTER'S REPORT AND RECOMMENDATION
Following a hearing held before the undersigned Support Master on July
16, 2002, the following report and recommendation are made:
FINDINGS OF FACT
1. The Plaintiff in this divorce action is Christopher J. Rizzuto, who
currently resides at 2613 Cinder Street, Chambersburg, Pennsylvania.
2. The Defendant is Kristen N. Rizzuto, who currently resides at 66
Jameslee Drive, Chambersburg, Pennsylvania.1
3. The parties were married on August 21, 1998.
4. There are no children of the marriage.
5. The parties separated on or about February 11, 2002, when the
husband requested the wife to move from the marital residence.
6. On or about March 12, 2002, the husband commenced this divorce
action.
7. On or about April 24, 2002, the wife filed a petition for alimony
pendente lite (hereafter "APL").
8. The wife is employed as an administrative assistant for Pinnacle Risk
Management Services, Inc. where her gross monthly income is
$1,582.00.
9. The wife currently resides with her parents.
10. Since the separation the wife has been paying approximately $579.00
per month on a loan and credit card bills for items purchased and
charges made during the marriage.
1 The parties will hereafter be referred to as the husband and the wife.
Exhibit "A"
11. Since June, 2002, the wife has been paying approximately $375.00
per month on the mortgage encumbering the martial residence.
12. Immediately following the separation the husband remained in the
marital residence.
13. The husband moved from the marital residence in late May and
currently resides with a female roommate with whom he shares
expenses.
14. The husband paid the mortgage while residing in the marital residence
and has been paying approximately $390.00 per month on the
mortgage since June, 2002.
15. The husband is employed as a consultant for Info-Matrix Corporation
where he earns approximately $1,442.00 per week.
DISCUSSION
Whether to award alimony pendente lite has traditionally been a matter
within the discretion of the trial court. Litmans v. Litmans, 673 A.2d. 382 (Pa.
Super. 1996). If an award of APL is warranted, the amount of that award is
calculated in accordance with the support guidelines. Little v. Little, 47
Cumberland L. J. 131 (1998). Before that calculation is made, however, a
determination must be made as to the entitlement to the award. Clouse v.
Clouse, 50 Cumberland L.J. 167 (2001). To be entitled to an award of APL, a
claimant must show that APL is needed to adequately prosecute or defend the
divorce action. Litmans v. Litmans. supra. The purpose of APL is to prevent one
spouse from being financially disadvantaged during the pendency of the action
as compared to the other. Powers v. Powers, 615 A.2d. 459 (Pa. Super. 1992).
Traditionally the fact that one spouse may earn less than the other does not
automatically entitle him or her to an award of APL. Sutliff v. Sutliff, 474 A.2d.
599 (Pa, Super. 1984), overruled on other arounds, Rosen v. Rosen, 549 A.2d.
561 (Pa. Super. 1988). In determining whether an award of APL is appropriate in
a case, the trier of fact may consider the husband's ability to pay, the separate
estate and income of the wife, and the character, situation, and surroundings of
the parties. Orr v. Orr, 461 A.2d. 850 (Pa. Super. 1983).
The husband has conceded that because of the significant disparity in the
incomes of the parties, the wife is entitled to an award of APL. He argues,
however, that the award should not be an amount calculated pursuant to the
support guidelines. However, he overlooks the mandate contained in Pa. R.C.P.
1910.16-1(b) which states that "[t]he amount of support (child support, spousal
support or alimony pendente lite) to be awarded pursuant to the procedures
under Rules 1910.11 and 1910.12 shall be determined in accordance with the
support guidelines. . . . " (emphasis added). Although the award may be subject
to deviation if the circumstances of the case warrant, the starting point is the
calculation of a guideline figure.
The wife has a gross monthly income of $1 ,582.00. If the divorce action is
not finalized in 2002, both parties will file federal income tax returns as
married/separate. The tax deductions shown on Exhibit A are calculated on this
filing status. After the permitted deductions, her net monthly income is
$1,275.00.
The husband has gross monthly income of $6,249.00. After the permitted
deductions, his net monthly income is $4,273.00. The husband's monthly APL
obligation to the wife as calculated pursuant to the guidelines is $1,199.00.2 A
support obligation calculated pursuant to the guidelines is presumed to be
correct, but the presumption can be rebutted by evidence that the guideline
award is unjust or inappropriate under the circumstances of the case. Landis v.
Landis, 691 A.2d. 939 (Pa. Super. 1997). There is no such evidence in this case.
The wife is paying $579.00 per month on a bill consolidation loan and credit card
debt for obligations incurred jointly by the parties during the marriage. She is
also paying $375.00 per month on the mortgage encumbering the marital
residence despite the fact that the husband voluntarily chose to move out of the
residence to reside with a female friend. Although her day-to-day living
expenses are greatly reduced because she is presently residing with her parents,
after the payments are made on the various joint debts as stated, the guideline
award effectively provides her with only $245.00 per month to supplement her
income and to litigate the divorce action. There is no reason to deviate
downward from the guideline support figure as suggested by the husband.
RECOMMENDATION
A. The husband shall pay to the State Collection & Disbursement Unit in
Harrisburg, Pennsylvania, for transmission to the wife the sum of
$1 ,199.00 per month as alimony pendente lite.
B. Except as modified herein, the order of May 6, 2002, shall remain in
full force and effect.
J' u..~ ''\, 2 00 2..-
.
Date
~~~~k
Michael R. Rundle
Support Master
2 The calculation is shown on Exhibit B.
In the Court of Common Pleas of Cumberland County, Pennsylvania
Plaintiff Name:
Defendant Name:
Docket Number:
PACSES Case Number:
Other State ID Number:
Tax Year:
1. Fling Status
2. Who Claims the Exem tions
3. Number of Exem tions
4. Monthl Taxable Income
5. Deductions Method
Kristen N. Rizzuto
Christopher J. Rizzuto
02-1224 Civil
197104486
$327.08
$250.00
$5,671,59
$1,301.91
6. Deduction Amount
7. Exem tion Amount
8. Income MINUS Deductions and Exem tions
9. Tax on Income
10. Child Tax Credit
11. Manual Ad'ustments to Taxes
12. Federal Income Taxes
12 a. Earned Income Credit
13. State Income Taxes
14, FICA Pa ments
15. City Where Taxes Apply
16. Local Income Taxes
Support Calc 2002
$1,301.91
$174,96
$436.05
TOTAL Taxes
$62.49
$1 975.41
Exhibit "r."
1
$1,582.00
$327.08
$250.00
$1,004.92
$125.74
$125.74
$44.30
$121.02
--Select--
$15.82
$306.88
In the Court of Common Pleas of Cumberland County, Pennsylvania
Plaintiff Name:
Defendant Name:
Docket Number:
PACSES Case Number:
Other State 10 Number:
Kristen N. Rizzuto
Christopher J. Rizzuto
02-1224 Civil
197104486
3. Difference
$4,273.26
$1,275.12
$2,998.14
2. Less Obli ee's Monthl Net Income
4. Less Child Obli ation for Current
5. Less All Other Su ort
ort $2,998.14
7. Multi I b 30% or 40% 40.00%
8. Amount of Monthl S ousal $1,199.26
Date: 7/17/2002
SupporlCa/c 2002
Exhibit "B"
EXHIBIT "B"
~IRS Dep.rrmeRt ot lh. TrealUl'Y
Jlllel'ul a.v.nu. 1.,\'ICIl
ATLANTA, OA 39901-0030
003723 200112 WI
Notioe Number: CP 503
Notice Date: 08 -12 - 2 0 0 2
SSNJEIN: 210-66-7195
Caller 10: 359702
1,.11111111111.1111111.1,1111111111..111.1.,1111,11111.11,1111.1
CHRISTOPHER & KRISTEN RIZZUTO
1502 TUSSEY CT
MECHANICSBURG PA 17050-7695028
111111111111I111111111111
*210667195101*
IMPORTANT
Immediate action is required.
We previou.ly wrote to you about YO\lr unpaid account, but you haven't contacted u. about it. Penaltie. and
intere.t on the unpaid balance are continuing to incre..e. Pie... p,y the amount you owe within ten day. from
the date ofthil notice. If you c.n't p'ay now, call u. at the number .hOWD below. You may be q,ualified for an
in.tallment agreement or payroll d.auction agreement. We want to help you resolve thi. bill. However, if We
don't hear from you, we will have no ohoice but to proceed with .teps required to colleot the amount you owe.
Uyo" already plid YOllr blllanee in rull or arranged tor In inltlllment IlVaement, please disregard this notice.
Account Summary
IPorm: 1040 I I Tax Period: 12-31-2001
Current Balance: .89 D . 13
mc;ludea :
Penalty: '
Interest:
Lut Payment
For Information on
your penalty & Interest
comfutat'ons. you may
call -800-829-8815.
ta.S6
tlO.09
to.OO
~ Questions? call us ~t 1.800.820-8815
Please malllhis part with your payment, payable to United States Treasury.
Notice Number: CP 603
Notice Date: 08-12-2002
wr//tl "")/Our check:
11040 112-31-2001 1210-66-7195 I
t Amount Due:
U90.13
,
Internal Revenue Service
ATLANTA. GA 399DI-0030
CHRISTOPHER & KRISTEN RIZZUTO
1502 TUSSEY CT
MECHANICSBURG PA 17050-7695028
Inll.1.I111 ,1..1 11111I1111111I1111,"11.11 nil
CERTIFICATE OF SERVICE
I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy
of the foregoing document upon the persons indicated below by fIrst class United States mail,
postage paid in Carlisle, Pennsylvania 17013, on the date set forth below:
ROBERT B. LIEBERMAN, ESQUIRE
500 NORTH THIRD STREET
TWELFTH FLOOR
P.O. BOX 1004
HARRISBURG, P A 17108-1004
Date: August 16,2002
IRWIN, McKNIGHT & HUGHES
Douglas G.
Supreme Co J.D. No. 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Attomey for Petitioner,
Kristin J. Rizzuto
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMErnc RELATIONS SECTION
KRISTEN N, RIZZUTO ) Docket Number 02-1224 CIVIL
Plaintiff ) 1971044 sy'U&g" 7
VS. ) PACSES Case Number
CHRISTOPHER J. RIZZUTO )
Defendant ) Other State lD Number
PETITION FOR MODIFICATION
OF AN EXISTING SUPPORT ORDER
1. The petition of
KRISTEN NICOLE RIZZUTO
respectfully
represents that on MAY 6, 2002
ALIMONY PENDENTE LI'IE for
KRISTEN NICOLE RIZZUTO
, an Order of Court was entered for
A true and correct copy of the order is attached to this petition.
Service Type M
Form OM-50l
Worker lD 21502
RIZZUTO
V. RIZZUTO
PACSES Case Number: 197104486
2. Petitioner is entitled to . increase 0 decrease 0 termination 0 reinstatement
o other of this Order because of the following material and substantial change(s) in
circumstance:
WHEREFORE, Petitioner requests that the Court modify the existing order for support.
I verify that the statements made in this complaint are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to
unsworn falsification to authorities.
Page 2 of 2
Form OM-50 1
Worker ID 21502
Service Type M
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
})e/. ~~A ~/~;/~ {!./P/L
State Commonwealth of Pennsylvania ,KJ~>ES /97/"V~C.
Co.lCity/Dist. of CUMBERLAND !5.
Date of Order/Notice 08/15/02 VC c:I/{pf7
Court/Case Number (See Addendum for case summary)
o Original Order/Notice
o Amended Order/Notice
o Terminate Order/Notice
) RE: RIZZUTO, CHRISTOPHER J.
) Employee/Obligor's Name (last, First, Mil
) 210-66-7195
) Employee/Obligor's Social Security Number
) 6107100940
) 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
INFO-MATRIX CORPORATION
Employer/Withholder's Name
3 BONNYWICK DR
Employer/Withholder's Address
HARRISBURG PA 17111
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.
$ 1,199.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes (g) no
$ 0,00 per month in medical support
$ 0,00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 1,199.00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 276.69 per weekly pay period.
$ 553,38 per biweekly pay period (every two weeks).
$ 599,50 per semimonthly pay period (twice a month).
$ 1.199,00 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
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 followinginformatlorr is
needed (See #9 on pg. 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to:PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BY THE COURT:
Date of Order:
AUG 1 6 2002
Service Type M
~ e.>w-",> If' t;~,.DO
970-0154
- '- xp;,.tion Dat., 12/31/00
.:Tl.J.o4 ~
Form EN-028
WorkerlD $IATT
Ot!lc.
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If checked you are required to provide a copy of this form to your employee.
1. Priority: Withholding under this OrderINotice 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.' :~~:~ :': :~~ ~f ~'ithh~!din1J' You '"U5t lepOlt II,e paydateldat-e of ~i~~';ldil,g "hen se"dihg tl,e payl "el,t. TI,e
payd;!teldat~ of ..ill ,holding i5 II,'!' .:late OJ, "I ,id, a,nOlll ,t "a5 "Ill ,held ti'Ol" tl,e employee', 5. You must comply with the law of the
state of the employee'slobligor'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.' EmployeelObligor 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'slobligor'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 retum a copy of this Order/Notice to the Agency identified below.
WITHHOLDER'S ID: 2517885700
EMPlOYEE'S/OBl/COR'S NAME: RIZZUTO, CHRISTOPHER J.
EMPLOYEE'S CASE IDENTIFIER: 6107100940 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 whichcase the law of the State in which he or she is employed govems.
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. 91673 (b)l; or 2) the amounts allowed by the State of the employee'slobligor'S principal place of employment.
The Federal limit applies to the aggregate disposable weekly eamings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes.
10.
· 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.
Requesting Agency:
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 @
Service Type M
Page 2 of 2
Form EN-028
Worker JD $IATT
OMB No,: 0970-0154
Expiration Date: 12/31/00
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor:
PACSES Case Number 197104486 ~teY7
Plaintiff Name '1 '"
KRISTEN N. RIZZUTO
Docket Attachment Amount
02::i2'2'4 CIVIL $ 1,199,00
Child(ren)'s Name(s):
RIZZUTO, CHRISTOPHER J.
DOS
bif~h~k~,y~~~re rE!Q~ir~t~e~roll the child(ren)
identified above in any health insurance coverage available
through the employee'slobligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0,00
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'slobligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0,00
Child(ren)'s Name(s):
DOS
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identified above in any health insurance coverage available
through the employee'slobligor's employment.
Service Type M
Addendum
OMB No.: 0970-0154
Expiration Date: 12/31100
-------- -.
PACSES Case Number
Plaintiff Name
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'slobligor'semploymenl.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOS
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o If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee'slobligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOS
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identified above in any health insurance coverage available
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Form EN-028
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CHRISTOPHER J. RIZZUTO,
PlaintifflRespondent,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CML ACTION - LAW
No. 02 - 1224 CML TERM
KRISTEN N. RIZZUTO,
DefendanVPetitioner.
IN DIVORCE
ORDER OF COURT
AND NOW, this 7o"""day of y , 2002, upon consideration of the within
Petition for Special Relief, a hearing is scheduled for ~JII1. ~~ , 2002, at /:0 l)
o 'clock~. m., in Courtroom # 5 , Cumberland County Courthouse, Carlisle, Pennsylvania 170 13. ~
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IN TIIE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - DIVORCE
CHRISTOPHER N. RIZZUTO,
PlaintifflRespondentlRespondent
KRISTEN N. RIZZUTO,
DefendantIPetitioner/Petitioner
NO. 2002-1224 CIVIL TERM
IN DIVORCE
DR# 31687
Pacses# 197104486
ORDER OF COURT
AND NOW, this 6th day of September, 2002, a petition has been filed against you, Christopher
Rizzuto, to modify an existing Alimony Pendente Lite Order. You are ordered to appear in person at the
Domestic Relations Section, 13 North Hanover Street, Carlisle, PA, on October 9.2002 at 9:00 A,M. for a
conference and to remain until dismissed by the Court. If you fail to appear as provided in this Order, an
Order of Court may be entered against you.
You are further ordered to bring to the conference:
(1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed
(2) your pay stubs for the preceding six (6) months
(3) the Income and Expense Statement attached to this order, completed as required by the Rule
1910.11.
(4) verification of child care expenses
(5) proof of medical coverage which you may have, or may have available to you
IF you fail to appear for the conference or bring the required documents, the Court may issue a
warrant for your arrest.
BY TIIE COURT,
George E. Hoffer, President Judge
Copies mailed
9-6-02 to:<
Date of Order: September 6, 2002
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YOU HA VB TIIE RIGHT TO A LAWYER, WHO MAY ATIEND TIIE CONFERENCE AND
REPRESENT YOU. IF YOU 00 NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE TIIE OFFICE SET FORm BELOW TO FIND OUT WHERE YOU MAY GET LEGAL
HELP.
Petitioner
Respondent
Robert Lieberman, Esquire
Douglas Miller, Esquire
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY A VB.
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
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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: CHRISTOPHER J. RIZZUTO
~ernberIDNutnber: 6107100940
Please note: All correspondence must include the Member ID Number,
Financial Break Down of Multiole Cases on Attachment
Plaintiff Name
KRISTEN N. RIZZUTO
3/lIt ..,
PACSES
Case Number
197104486
Docket
Number
02-1224 CIVIL
$
I
$
$
I
$
Attachment Amount/Frequency
1,199.00 I MONTH
~
/
~
~
/
/
TOTAL AITACHMENT AMOUNT: $
1,199,.00
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 $ 276.69
per week, or 50 %, of the Unemployment Compensation benefits otherwise payable to the Defendant,
CHRISTOPHER J, RIZZUTO Social Security Number 210-66-7195, Member
ID Number 6107100940 . 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 SEPTEMBER 8, 2002 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: Sf.P 1 1 2002
~ii
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JUDGE
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Form EN-530
Worker ID $IATT
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CHRISTOPHER J. RIZZUTO,
PlaintifflRespondent
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION - LAW
: NO. 02-1224 CIVIL TERM
KRISTEN N. RIZZUTO,
Defendant/Petitioner
: IN DIVORCE
ORDER OF COURT
AND NOW, this ;l~ ~ day oiliflfunhEIL. 2002, upon due consideration
of the request submitted by Robert B. Lieberman, Esquire, for Christopher 1. Rizzuto,
Plaintiff/Respondent, the hearing on the Petition for Special Relief previously scheduled for
September 25,2002, in Courtroom 5 is rescheduled for ~,~,. t ~7 ,2002,
atl:t:k) 0' clock L.m. in Courtroom ~ , Cumberland County Courthouse, Carlisle,
Pennsylvania.
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ROBERT B. LIEBERMAN
ATTORNEY AT LAW
Five Hundred North Third Street
Twelfth Floor
P. O. Box 1004
Harrisburg, Pennsv1vania 171 08-1 004
(717) 236.1485
FAX (717) 236-7777
File No.
1917-1
September 18, 2002
Honorable Edward E. Guido
Cumberland Court of Common Pleas
One Courthouse Square
Carlisle, PA 17013-3387
In re: Rizzuto v. Rizzuto
Dear Judge Guido:
In follow up to a recent phone conversation with your secretary, enclosed is a proposed
Order of Court regarding my request to continue the hearing in the above case scheduled for
September 25, 2002.
The continuance is being requested due to a conflict in my client's work schedule.
I have spoken with the Petitioner's attorney, Douglas G. Miller, Esquire regarding the
request. Mr. Miller is not objecting to the case being rescheduled to a later date.
Thank you very much for your consideration.
\'l Very truly yo
~~.
Robert B. Lieberman
RBL/cso
Enclosure
cc: Douglas G. Miller, Esquire
Christopher J. Rizzuto
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
MI ~O;J, - /~Jf/ (J/tJI L
State Commonwealth of Pennsylvania /'}&trooQ /tJ7/bt./'1i{p
Co.lCity/Dist. of CUMBERLAND rhC->c ?
Date of Order/Notice 10/09/02 ()IL ~(p '1'1
Tribunal/Case Number (See Addendum for case summary)
@ Original Order/Notice
o Amended Order/Notice
o Terminate Order/Notice
INFO-MATRIX CORPORATION
3 BONNYWICK DR
HARRISBURG PA 17111
RE: RIZZUTO, CHRISTOPHER J,
Employee/Obligor's Name (Last, First, MI)
210-66-7195
Employee/Obligor's Social Security Number
6107100940
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 TION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's!obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 1,199.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes <Xl no
$ 0,00 per month in medical support
$ 0 , 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 1, 199 . 00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 276,69 per weekly pay period.
$ 553,38 per biweekly pay period (every two weeks).
$ 599,50 per semimonthly pay period (twice a month).
$ 1.199.00 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 thelimitation on withholding, the following information is
needed (See #10 on pg. 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, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER 10 (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL,
BY THE COURT:
-7VM~
Form EN-028
Worker ID $IATT
Date of Order:
OCT 1 0 2002
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Service Type M
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If ~hecked you are required to provide a (:opy of this form to your employee. If YO\Jr employee works in a state that is
ditterent from the state that issued this order, a copy must be provided to your employee even if the box is not checked.
1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned
businesses located on a reservation that choose to withhold in accordance with this notice.
2. 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.
3. 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.
4.' ~~~i;:! ~': ~d~~~~~'~V~,',oldil,g. '(au must report tl,e paydateldate of "itl,holding "helo s!!ndil,g d,e payl"el,t. TI,e
paydate/date vi "ithholding is tl,!! date 01, "hkh al"OUI ,t "as "itl,held flOI" the el"ployee's "ages. You must comply with the law of the
state of the employee'slobligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
5.' 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 #10 below)
6. 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 retum a copy of this Order/Notice to the Agency identified below.
WITHHOLDER'S 10: 2517885700
EMPLOYEE'S/OBLlGOR'S NAME:
EMPLOYEE'S CASE IDENTIFIER:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
RIZZUTO, CHRISTOPHER J.
6107100940 DATE OF SEPARATION:
7. 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.
8. 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 govems 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. 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.
10.' 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. 91673 (b)1; or 2) the amounts allowed by the State of the employee'slobligor'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.
11. 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.
Submitted By:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717l240-6248 or
byi nternet www.childsupport.state.pa.us
Service Type M
Page 2 of 2
Form EN-028
Worker ID $IATT
OMB No.: 0970-0154
ADDENDUM
of Cases on Attachment
UTO, CHRISTOPHER J,
Defendant/Obligor: RIZ
PACSES Case Number 197104486 ~/(Pf7
Plaintiff Name /' ~
KRISTEN N. RIZZUTO
Docket Attachment Amount
02=1224 CIVIL $ 1,199.00
Child(ren)'s Name(s):
DOB
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o If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage avail ble
through the employee's1obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0,00
Child(ren)'s Name(s):
DaB
o If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage availa Ie
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
OB
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Service Type M
Addendum
OMS No.: 0970-0154
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
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
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
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o If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
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PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
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Form EN-028
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CHRISTOPHER N. RIZZUTO,
PlaintiffJRespondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
KRISTEN N. RIZZUTO,
DefendanifPetitioner
NO. 2002-1224 CIVIL TERM
IN DIVORCE
DR# 31687
Pacses# 197104486
ORDER OF COURT
AND NOW, this 9th day of October, 2002, based upon the Court's determination that Petitioner's
monthly net income/earning capacity is $N/A and Respondent's monthly net income/earning capacity
is $N/ A, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and
Disbursement Unit, $1,199.00 per month payable monthly as follows; $1,199.00 for alimony pendente
lite and $0.00 on arrears. First payment due next pay date. Arrears set at $2,266.05. The effective
date of the order is April 24, 2002.
This order is based upon an agreement of the parties. The parties agree that a total of$I,207.05 is to
be added to the arrears. This sum represents three months of Defendant's one half obligation (377.35
per month) of the parties mortgage payment and a $75.00 late fee.
The order is to be increased by $377,35 for a total of$I,536.35, effective November 1, 2002. The
original APL ordered amount of $1, 199.00 per month will resume after the sale of the parties' house.
Collection on the arrears will be held in abeyance until after the first of the year 2003.
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 P A SCDU to: Kristen Rizzuto. Payments must be made by
check or money order. All checks and money orders must be made payable to P A SCDU and mailed
to:
PASCDU
P.O. Box 69110
Harrisburg, P A 17106-911 0
Payments must include the defendant's P ACSES Member Number or Social Security Number in order
to be processed. Do not send cash by mail.
O~/(,
Unreimbursed medical expenses that exceed $250.00 annually are to be paid ()01o by the respondent
and 100% by petitioner. The petitioner is responsible to pay the first $250.00 annually in
unreimbursed medical expenses. Respondent to provide medical insurance coverage. Within thirty
(30) days after the entry of this order, the Respondent shall submit written proof that medical
insurance coverage has been obtained or that application for coverage has been made. Proof of
coverage shall consist, at a 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 foons.
This Order shall become final ten days after the mailing of the notice of the entry of the Order to the
parties unless either party files a written demand with the Prothonotary for a hearing de novo before
the Court.
DRO: R. J, Shadday
Mailed copies on
10-10-02 to: <
Petitioner
Respondent
Douglas Miller, Esquire
Robert Lieberman, Esquire
BY THE COURT,
Edward E. Guido
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CHRISTOPHER J. RIZZUTO,
Plaintiff/Respondent,
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
KRISTEN N. RIZZUTO,
DefendantJPetitioner.
: CIVIL ACTION - LAW
: No. 02 - 1224 CIVIL TERM
: IN DIVORCE
ORDER OF COURT
1~ O~
AND NOW, this / day of
, 2002, upon consideration of the request
submitted by Douglas G. Miller, Esquire for Kristen N. Rizzuto, Defendant/Petitioner, the hearing on the
Petition for Special Relief previously rescheduled for Thursday, October 17, 2002, at 1 :00 p.m. in
Courtroom #5, Cumberland County Courthouse, Carlisle, Pennsylvania, is hereby continued generally
subject to the right of either party to request that a new hearing date be scheduled to resolve any issue
raised in the Petition not satisfied by the Domestic Relations hearing held on Wednesday, October 9,
2002, or subsequent agreement of the parties.
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LAW OFFICES
IRWIN McKNIGHT & HUGHES
ROGER B, IRWIN
MARCUS A, McKNIGHT. III
JAMES D, HUGHES
REBECCA R, HUGHES
DOUGLAS G, MILLER
WEST POMFRET PROFESSIONAL BUILDING
60 WEST POMFRET STREET
CARLISLE, PENNSYL VANIA 17013-3222
(717) 249-2353
FAX (717) 249-6354
E.MAIL: IMHLAW@SUPERNET.COM
HAROLDS, IRWIN (1925-1977)
HAROLDS, IRWIN, JR, (1954-1986)
IRWIN, IRWIN & IRWIN (1956-1986)
IRWIN, IRWIN & McKNIGHT (/986-1994)
IRWIN. McKNIGHT & HUGHES (/994- )
October 11, 2002
THE HONORABLE EDWARD GUIDO
CUMBERLAND COUNTY COURTHOUSE
ONE COURTHOUSE SQUARE
CARLISLE, P A 17013
RE: RIZZUTO v. RIZZUTO
No. 2002 - 1224, In Divorce, Cumberland County
Dear Judge Guido:
On Wednesday, October 9,2002, the parties appeared for a Domestic Relations hearing
before Ms. Shadday, and at that time reached an agreement regarding the issue of the mortgage
payments on the marital residence and modification of the current APL Order. Accordingly, it
appears that the hearing on the Petition for Special Relief rescheduled for Thursday, October 17,
2002, will not be necessary at this time. I have enclosed a proposed Order for your review and to
reflect the above information. Also enclosed are stamped envelopes to myself and Attorney
Lieberman.
Please do not hesitate to contact me in the event you have any questions or concerns and
thank you for your assistance in this matter.
Very truly yours,
IRWIN, McKNIGHT & HUGHES
~:!~
DGM:tds
Enclosure
cc: Kristen Rizzuto
Robert Lieberman, Esquire
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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
Phone: (717) 240-6225
Fax: (717) 240-6248
Defendant Name: CHRISTOPHER J. RIZZUTO
Member ID Number: 6107100940
Please note: All correspondence must include the Member ID Number.
MODIFIED ORDER OF ATTACHMENT OF UNEMPLOYMENT BENEFITS
Plaintiff Name
KRISTEN N. RIZZUTO
Financial Break Down of Multiple Cases on Attachment
PACSES Docket
Case Number ~
197104486 02-1224 CIVIL
3/&>37
$
I
$
$
I
$
Attachment AmountlFreauencv
1,536.35 I MONTH
~
/
/
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/
/
TOTAL ATTACHMENT AMOlNT: $
1,536.35
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 $ 354 , 54
per week, or 50, 0 %, of the Unemployment Compensation benefits otherwise payable to the Defendant,
CHRISTOPHER J, RIZZUTO Social Security Number 210-66-7195, Member
ID Number 6107100940 . 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 arrearage, 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. ~ l673(b)(2) and 23
Pa. C.S. ~ 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 SEPTEMBER 8, 2002 is exhausted, expired or deferred.
BUCBA shall comply with this Order, unless it is amended or val~ated 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:
NOV U 4ZUU:L
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
l# ~t?). /;J;)1eif/lL
State Commonwealth of Pennsylvania .I,1clF1,Sf> /97/0'/l/fC:,
Co./City/Dist. of CUMBERLAND (TI-
, Date of Order/Notice 11/01/02 }A- ~/(Yf'7
Tribunal/Case Number (See Addendum for case summary)
RE:RIZZUTO, CHRISTOPHER J.
Employee/Obligor's Name (Last, First, MI)
210-66-7195
Employee/Obligor's Social Security Number
6107100940
Employee/Obligor's Case Identifier
(S<!e Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
o Original Order/Notice
o Amended Order/Notice
o Terminate Oider/Notice
EmployerMlithholder's Federal EIN Number
INFO-MATRIX CORPORATION
2101 N FRONT ST
HARRISBURG PA 17110-1086
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.
$ 1,536.35 per month in current support
$ 0 . 00 per month in past-due support Arrears 12 weeks or greater? 0 yes <X) no
$ --~ per month in medical support
$ 0,00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 1, 536 . 35 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:
$ 354.54 per weekly pay period.
$ 709,08 per biweekly pay period (every two weeks).
$ 768.18 per semimonthly pay period (twice a month).
$ 1.536.35 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 paydateJdate 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 amouht, and your tee, cannot exceed 55% of the employee's/ obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, thefollowing information is
needed (See #10 on pg. 2).
If remitting by EFl'/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 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.
Service Type M
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If I;hecked 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 pro\ 'oed to your employee even if the box is not checked.
1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned
businesses located on a reservation that choose to withhold in accordance with this notice.
2. 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 t.ax levies in effect please contact the requesting
agency listed below.
3. 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.
4.' Repaltingtl,ePaydate!Date ofV/itl,holding. Yat! must leportthe paydate!date of ,;ithhaldil,g "I,el, sel,ding the payl"ellt. The
paydate!date of "itl,haldilog is tI ,edate on "hich alo,aul,t"as "itl,l,eld from tl,e en,plo) ee's "ages. You must comply with the law of the
state of the employee's1obligor's principal place of employment with respect to the time periods within which you must implement the
withhold ing order and forward the support payments.
5.' 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'slobligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #1 0 below)
6. 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.
WITHHOLDER'S ID: 2517885700
EMPLOYEE'S/OBUGOR'S NAME:
EMPLOYEE'S CASE IDENTIFIER:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
RIZZUTO, CHRISTOPHER J.
6107100940 DATE OF SEPARATION:
7. 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.
8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable fOl' 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.
9. 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.
10.' 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. 91673 (b)l; or 2) the amounts allowed by the State of the employee's1obligor'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.
11. Additional Info:
'NOTE: If you or your agentare served witha 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.
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 20f 2
Form EN-028
Worker ID $IATT
Service Type M
OMB No.: 0970-0'54
ADDENDUM
Summary of Cases on Attachment
RIZZUTO, CHRIs'rOPHER J.
Defendant/Obligor:
197104486./3/hf 7
PACSES Case Number
Plaintiff Name
KRISTEN N. RIZZUTO
Docket Attachment Amount
02=1224 CIVIL $ 1,536.35
Child(ren)'s Name(s):
DOB
o Ifchecked, 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
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
Docket Attachment Amount
$ 0.00
Child(ren)'s Name{s):
DOB
:;:-:';..': <:;:;:::::::::::;::;"::::;'::::-::::;:;;':"::;.-:::::'.,:':;.-,-:;.,::::;:,;:::.: '::/":-::::::";::::::;:::\:;:<:::,-::::::<:::;.::-:::::::;::.. ::.;:/:>::<::::.:.;':':'.-;-.....
',',',""','"',,',',',',,',',',',",,,',',',",',',,,"','"',',,',',,,' ","',"'","',',.-.""",.-..,",""'",,,,',,,,'",',",',",',',','...,",',.,...,'"..'.."'...,,',,",',',",',","',',',',",',.....
'[J If ~h~ck~, ~o~ are r~qui;~t~ e~;ollth~~hild(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Service Type M
Addendum
OMS No.~ 0970.01 54
PACSES Case Number
Plaintiff Name
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.
PACSES Case Number
Plaintiff Nam~
Docket Attachment Amount
$ 0.00
Child{ren)'s l\Jame{s):
DOB
....,. .., . -... ,..-.-.,., .,._, -, - , "'-"""""" ,.
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"". '" ',' ",," ,'",' ," ,', "',' ",', ","',',' ',',','
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., ,....".."_..,,,, ....". -" ..., -..--,., '''''..."".
",..,"""",',',"',",'"","""".,-.",.,..",,,,',,',', ,', ,",', ",',','"',',.."",,
',,' '" " ',' ,,' ",' ,', '," '" ',,' ,', ", " ", '
'" -. .... '. --, ,. ., -,. " ..", ".-..
o If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee'slobligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
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.
Form EN-028
Worker ID $IATT
ORDER/NOTICE TO,W~T}lHOLD INCOME FOR: SUPPORT
!Xt-r ~;J. -I ~cr Y
State Commonwealth of Pennsylvania 1'l g[-<;; q 7/ t5 tiC; fG.
Co.lCity/Dist. of CUMBERLAND ,JIK" , I
Date of Order/Notice 12/02/02 )K S/&f7
Tribunal/Case Number (See Addendum for case summary)
o Original Order/Notice
@ Amended Order/Notice
o Terminate Order/Notice
INFO-MATRIX CORPORATION
2101 N FRONT ST
HARRISBURG PA 17110-1086
RE:RIZZUTO, CHRISTOPHER J.
Employee/Obligor's Name (last, First, MI)
210-66-7195
Employee/Obligor's Social Security Number
6107100940
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associafed with cases on attachment)
Custodial Parent's Name (last, First, MI)
EmployerMtithholder's Federal EIN Number
See Addendum for dependent names and birth dates associatE~ 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.
$ 1,199.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes @ no
$ 0,00 per month in medical support
$ 0,00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 1,199.00 per month to be forwarded to payee below,
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 276,69 per weekly pay period.
$ 553.38 per biweekly pay period (every two weeks).
$ 599,50 per semimonthly pay period (twice a month).
$ 1.199.00 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 #10 on pg. 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, HarrisbUlrg, 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 THE COURT: C ~==;,
~""",,~,~"",'"
~~~o~
"::/
~6?u/'l.cO ,{;' &'u/Jt:-"'^-;'I :Jl;;LJ(,c
i Form EN-028
Worker 10 $IATT
Date of Order:
DEe
3 2002
Service Type M
~';'~~.l~:i~al~..zi~"~~: ;j)
OMS No.: 097().{)154
_J~ -t/O)-
Off'-
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If l:hecked you are required to prpvide a 1=0Py of this fonn to your employee. If YO\lr 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. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned
businesses located on a reservation that choose to withhold in accordance with th is notice.
2. 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.
3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to
each agency requesting withhold ing. You must, however, separately identify the portion of the single payment that is attributable to each
employee/obligor.
4." Repoltilog tl,~ raydate!Date of 'Nitl,I.olding. Vot! n,t!st leport tl,e pay date/date of "itlnholding "I,en selodilog tke paymelot. The
paydate/date of "ithholdilog is the date 010 "I,ich an,oUl,t "as ~itl,held "01.. tl,~ en,ploy,~e's "ages. You must comply with the law of the
state of the employee'slobligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
S." 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 Jaw of the state of employee'slobligor's principal place of employment. You must honor all Orders/Notices to the greatest extent '
possible. (See #10 below)
6. Termination NotifICation: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you.
Please provide the infonnation requested and retum a copy of this Order/Notice to the Agency identified below.
WITHHOLDER'S ID: 2517885700
EMPLOYEE'S/OBLlGOR'S NAME:
EMPLOYEE'S CASE IDENTIFIER:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
RIZZUTO, CHRISTOPHER J.
6107100940 DATE OF SEPARATION:
7. 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.
8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should ha':e
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law govems unless
the obligor is employed in another State, in which case the law of the State in which he orshe is employed govems.
9. Anti-discrimination: You are subject to a fine detennined 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
govems unless the obligor is employed in another State, in which case the law of the State in which he or she is employed govems.
10." Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (IS U.S.c. 91673 (b)l; or 2) the amounts allowed by the State of the employee'slobligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly eamings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes.
11. 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.
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 !.Z1.Zl.j'40-6248 or
by internet www.childsupport.state.pa.us
Service Type M
Page 2 of 2
Form EN-028
Worker II) $IATT
OMB No.: 0970-0154
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor:
PACSES Case Number 197104486/?J/(pf7
Plaintiff Name ! '
KRISTEN N, RIZZUTO
Docket Attachment Amount
02=1224 CIVIL $ 1,199.00
Child(ren)'s Name(s):
RIZZUTO, CHRISTOPHER J.
DOS
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOS
o If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee'sJobligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOS
Service Type M
Addendum
OMS No.: 097()..()154
PACSES Case Number
Plaintiff Nam'~
Docket Attachment Amount
$ 0,00
Child(ren)'s Name(s):
DOS
.;...;.':..:.;...;....:.::..,:.;....:.:;:.;.;...;..:.;.,;.:.:,".:.;.:;'.;.:.;.;..:.;".;..;:.:.:.:-:;':; .
::,;.:::.;::.:.:;:;:;:.:;.;....:;:;:;:;:;..;;:::.::;.,:..;:;:;:.:;:;.;:.::;:::.:::;::-..:;:;:;:;:;.:;..:;:;.:..;....
d If~I1~I<~I,y~~ a~e~qui~d to enroll the child(ren)
identified above in any health insurance coverage available
through the el11ployee'sJobligor's employment.
PACSES Case Number
Plaintiff NamE!
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'sJobligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOS
EJii~heCked, you are required to enroll the Child(re~i ,\, ..'
identified above in any health insurance coverage available
through the elTlployee'sJobligor's employment.
Form EN-028
Worker ID $IATT
.'
(") Cl 0
'~ N -'I
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-ocn n, -.:- ........
cP !!J n 'il'lj=''::j.
"-~-" I r"'J1't
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.<"_(-\ orrJ
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,=J " ,
In the Court of Common Pleas of
CUMBERLAND
County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER sr, P.O. BOX 320, CARLISLE, PA. 17013
Phone: (717) 240-6225
Fax: (717) 240-6248
Defendant Name: CHRISTOPHER J, RIZZUTO
Member ID Number: 6107100940
Please note: All correspondence must Include the Member ID Number.
MODIFIED ORDER OF ATTACHMENT OF UNEMPLOYMENT BENEFITS
Plaintiff Name
KRISTEN N. RIZZUTO
Financial Break Down of MultiDle Cases on Attachment
PACSES Docket
Case Number ~
~97104486 02-~224 CIVIL
/)/ ~ 'i7
Attachment Amount/FreQuency
$ I, ~99. 00 jMONTH
I ~
$ /
$ ~
I ~
$ /
TOTAL ATIACHMENT AMOUNT: $
~,~99.00
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 $ 276.69
per week, or 50. 0 %, of the Unemployment Compensation benefits otherwise payable to the Defendant,
CHRISTOPHER J, RIZZUTO Social Security Number 210-66-7195 , Member
ID Number 6107100940 . BUCBA is ordered to remit the amount atullChed 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 arrearage, DPW may reduce the amount attached ulllder 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. ~ 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 SEPTEMBER 8, 2002 is exhausted, expired or deferro~.
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 3 2002
(- )
'~~~
!;bt<Jl-J-.et> ;(;,CJ1D "
JUDGE
Service Type M
Form EN-034
Worker ID $IATT
L-'f/~
(') 0 0
C N 'TJ
s: 0 ---J
"U [1; !'Y1
rpL)) n I .- 1" _~_J
'r--"
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en *1;t. .j;'" "'1(-:)
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-0 ,- ..
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)>2 w tsrn
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U1 ~D
""<. -<
anned
State Commonwealth of Pennsylvania
Co.lCity/Dist. of CUMBERLAND
Date of Order/Notice 03/11/03
Tribunal/Case Number (See Addendum for case summary)
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
Dd. :U19. -/ ~J- t/ {l/ 1// L
~4e5f'5 /cI7/oY'yf'&
o Original Order/Notice,
o Amended Order/Notice
o Terminate Order/Notice
EmployerNvithholder's Federal EIN Number
INFO-MATRIX CORPORATION
2101 N FRONT ST
HARRISBURG PA 17110-1086
RE: RIZZUTO I CHRISTOPHER J,
, Employee/Obligor's Name (last, First, MI)
210-66-7195
Employee/Obligor's Social Security Number
6107100940
Employee/Obligor's Case Identifjer
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's 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.
$ 0.00 per month in current support
$ 0,00 per month in past-due support Arrears 12 weeks or greater? 0 yes (g) no
$ 0.00 per month in medical support
$ 0.00 per month for genetic test costs
$ per month in other (specify)
fo"r a total of $ 0 . 00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the SUPPOlt order. If your pay cycle does not matCh
the ordered support payment cycle, use the following to determine how much to withhold:
$ 0.00 per weekly pay period.
$ 0.00 per biweekly pay period (every two weeks).
$ 0,00 per semimonthly pay period (twice a month),
$ 0.00 per monthly pay period.
REMITTANCE INFORMA TlON:
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 #10 on pg. 2).
If remitting by EFTfEDI, 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
Date of Order:
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 171 06~9112
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 THE COURt: ' ,J.,
:,/""r:..f
@cu4eD E, '~JOI/)
MAR 1 2 2003
Service Type M
:,,",< ~~_~? ;2} V:~~.1 r~7r f;}
~, ~..~~.'j..'!t~~~~.1~~Jtj-:.~7
OMB No.: 097().(J154
JtjMG
Form E N-028
Worker I D $ IATT
..3-/J.-o3
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
O'f ~hecked you are required to provide a (:opy of this form to your employee. If yo~r employee works in a state that is
ditterent from the state that issued this order, a copy must be provided to your employee even if the box is not checked.
1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned
businesses located on a reservation that choose to withhold in accordance with this notice.
2. 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.
3. 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.
4. * Reporting t:-~e .Pa)~;t!~~ of Withholdin~. rOt! mt!st repo~ !',e paydateJdate Of;w;itnholding ..hen sendil,g the pay ":lent. The
paydateldate-of WIthhOlding IS the date on vvhlch amount vvaS-Wftl,held from--theemp 10 ree's v.ages. 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.
5. * Employee/Obligor with Multiple Support Holdings: If there is more than one OrderlNotice 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 greatestextent
possible, (See #10 below)
6. 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.
WITHHOLDER'S 10: 2517885700 ,
EMPLOYEE'S/OBlIGOR'S NAME: RIZZUTO, CHRISTOPHER J,
EMPLOYEE'S CASE IDENTIFIER: 6107100940 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW fMPLOYER'S NAME/ADDRESS:
7. Lump Sum Payments: You may be required to report and withhold from lump sum palyments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments; contact the person or authority below.
8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for hoththe accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs uni,...ss
the obligor is employed in another State, in which case the law of the State in which he Of' she IS employed governs.
9. AntkJiscrimination: 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 oil 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,
10. * 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. 91673 (b) 1 ; or 2) the amounts allowed by the State of the emplo)'ee'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.
11. 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.
Submitted By:
DOMESTIC RELA nONS SECTION
13 N. HANOVER ST
r.o, BOX 320
CARUSLEPA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at Q17) 240-6225 or
by FAX at (717) 240-6248 or
by internet www.childsupport.state.pa.us
Service Type M
Page 2 of 2
Form EN-028
Worker ID $IATT
OM8 No.: 0970-0154
o
-o~
!Till:
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cr~
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. ~lj
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I "J
(J')
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-<..
State Commonwealth of Pennsvlvania
Co.lCity/Dist. of CUMBERLAND
Date of Order/Notice 03/17/03
Tribunal/Case Number (See Addendum for case summary)
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
ok!' C2tJ0;) - / ;;-;;-q eJ t/j L
/Y}(!.SE9 /9 7/0 Lj'l'r~
@ Original Order/Notice
o Amended Order/Notice
o Terminate Order/Notice
GLOBAL DATA CONSULTANT INC
219 FALLING SPRING RD
CHAMBERS BURG PA 17201-8482
RE: RIZZUTO, CHRISTOPHER J,
Employee/Obligor's Name (Last, First, MI)
210-66-7195
Employee/Obligor's Social Security Number
6107100940
Employt'e/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.
$ 1, 19 9,00 per month in current support
$ 0,00 per month in past-due support Arrears 12 weeks or greater? 0 yes <X) no
$'-'-O"~bO-per month in medical support
$ 0,00 per month for genetic test costs
$ .---- per month in other (specify)
for a total of $ 1,199.00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 276.69 per weekly pay period,
$ 553.38 per biweekly pay period (every two weeks),
$ 599.50 per semimonthly pay period (twice a month).
$ 1,199.00 per monthly pay period.
RfMITTANCE INFORMA TION:
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 J 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 em pi oyee's/ obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #10 on pg. 2),
If remitting by EFI/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions,
Make Remittance Payable to: PASCO U
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 ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL,
BY THE COURT:
Date of Order:
MAR 1 ~ lUU~
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If checked you are required to provide a copy ot 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 h", provided to YOUI' employee even if the box is not checked.
1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned
businesses located on a reservation that choose to withhold in accordance with this notice.
2. 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.
3. 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.
4. * RepOltillg ti,e ra~date/Date of Withl,oldil,g. You 1I1ustlepOlt ti,e paydate/date of vvitl,holdil,g ",I,el, !lellding ti,e payl1 lei I!. Tl.e
pa~dare/date of vvitl,l,oldil,g is the date 01, vvl,id, alllount vvas vvitl,l,eld f10lll ti,e elllploye,~'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.
5. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/i'Jotice 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 taw of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #10 below)
6. 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.
WITHHOLDER'S ID: 9178100176
EMPLOYEE'S/OBLlGOR'S NAME:
EMPLOYEE'S CASE IDENTIFIER:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
RIZZUTO, CHRISTOPHER J,
6107100940 DATE OF SEPARATION:
7. Lump Sum Payments: Y(lU may be required to report and withhold from lump sum payments such as bonuses, commissions, or
sevemnce pay If you have any questions about lump sum payments, contact the person or authority below.
8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should h ,'If'
withheld fmlll the emplvyee/0bligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs un:",;>
the obligor is employed ill another St~te, 111 wlll,h case the law of the State in wh ich he or she is employed governs,
9. Anti-discrimination: Vou 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 obligoris employed 111 another State, in which case the law of the State in which he or she is employed governs.
10. * 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.e. 91673 (b)1; or 2) the amounts allowed by the State of theemployee'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.
11. 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.
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 ATIACHMENT UNIT
by telephone at )717) 240-6225 or
by FAX at f.Z1Zl...240-6248 or
by internet www.childsupport.state.pa.us
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ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: RIZZUTO, CHRISTOPHER J.
PACSES Case Number 197] 04486
Plaintiff Name
KRISTEN N. RIZZUTO
Docket Attachment Amount
02-1224 CIVIL$ 1,199.00
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'sfobligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
o If .:hecked, you dre required to enroll the child(ren)
idpnl.jfjed dhovp in dny health insuran( e coverage available
through the l:'llIployee'sfohligor's l:'mpluyment.
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
the employee'sfobligor's employment.
Service Type M
OMB r,ju.' ~lq70.[)1 ';4
PACSES Case l\lumber
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s I\lame(s):
DOB
If you are required to enroll the child(ren)
above in any health insurance coverage available
through the employee'sfobligor's employment.
PACSES Case Number
Plaintiff Name.
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 availabi.~
through the employee'sfobligor's employment.
PACSES Case Number
Plaintiff Namt~
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'sfobligor's employment.
Addendum
Form EN-028
Worker 10 $IATT
CHRISTOPHER J. RIZZUTO,
PlaintiffnResponden~
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
No. 02 - 1224 CIVIL TERM
KRISTEN N. RIZZUTO,
Defendant/Petitioner.
IN DIVORCE
PETITION FOR SPECIAL RELIEF
AND NOW, comes Petitioner, Kristen N. Rizzuto, by and through her attorneys, Irwin,
McKnight & Hughes, Esquires, and petitions the Court as follows:
1. Petitioner is the above-named Defendant, Kristen N. Rizzuto, an adult individual
currently residing at 66 James1ee Drive, Chambersburg, Pennsylvania 17201.
2. Respondent is the above-named Plaintiff, Christopher J. Rizzuto, an adult
individual who upon information and belief currently resides in Chambersburg, Pennsylvania.
3. The parties separated on or about February 11, 2002, when the Respondent
requested and the Petitioner agreed to move herself from the marital residence.
4. On March 12, 2002, Respondent filed a Complaint in Divorce.
5. On April 24, 2002, Petitioner filed a Petition for Alimony Pendente Lite and is
currently receiving $1,199.00 per month from Respondent pursuant to an Order of Court dated
July 19, 2002, issued following a hearing before the Cumberland. County Support Master.
6. Since the separation of the parties, Respondent has retained the sole use of a 2000
Mercury Cougar automobile.
1
7. The automobile is titled in joint names, but has been exclusively in the possession
of Respondent since the separation of the parties.
8. Petitioner has recently been contacted by a representative from Ford Motor Credit
who informed her that the loan payments for the vehicle are not current and that if payments are
not received the vehicle will be repossessed.
9. Upon information and belief, Respondent was also contacted about the failure to
make the monthly loan payments and he consented to the repossession of the vehicle by Ford
Motor Credit.
10. Upon information and belief, Respondent has informed Ford Motor Credit that he
is unable to pay the current monthly loan amount, and to date Respondent has made no attempt at
even partial payments.
11. Upon information and belief, Respondent has made no attempt to sell the vehicle
in an attempt to satisfy the vehicle loan to Ford Motor Credit.
12. Upon information and belief, Respondent has made no attempt to trade in the
vehicle for a less expensive model, thereby satisfying the current vehicle loan,
13, Petitioner, through the parties' respective legal counsel, has informed Respondent
that she would sign any and all paperwork necessary to sell or transfer the vehicle so that it is not
repossessed and the current loan is satisfied.
14. Repossession of the vehicle would result not only in increased liabilities to the
parties, but would adversely affect the credit of both parties.
1 S. Despite repeated requests to avoid repossession to Respondent's legal counsel has
indicated only that Respondent will try to make payments to avoid repossession.
2
16. As a direct result of the above, Petitioner has incurred and will incur significant
additional attorney fees in order defend her interests in the divorce action.
17. Petitioner respectfully requests an increase :in the current monthly alimony
pendente lite in order to support herself and defend the divorce action filed by Respondent, an
order directing Respondent to pay the monthly vehicle loan payments, an order directing
Respondent to sell the subject vehicle, and/or an order directing Respondent to otherwise trade in
the vehicle and satisfy the current loan.
WHEREFORE, for the above reasons, Petitioner, Kristen N, Rizzuto, respectfully
requests this Honorable Court to enter an Order as requested above, as well as such other and
further relief and may be necessary or just.
Respectfully submitted,
IRWIN, McKNIGHT & HUGHES
By:
Date: April 30, 2003
Douglas
Supreme ~ urt J.D. No. 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Attorney for DefendantJPetitioner,
Kristen N. Rizzuto
3
VERIFICATION
The foregoing document is based upon information which has been gathered by my
counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief, I
understand that false statements herein made are subject to the penalties of 18 Pa,C.S.A. Section
4904, relating to unsworn falsification to authorities.
Jiil~~7d
KRIST N. RIZZ t$
Date:
April 29
, 2003
CERTIFICATE OF SERVICE
I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy
of the foregoing document upon the persons indicated below by first class United States mail,
postage paid in Carlisle, Pennsylvania 17013, on the date set forth below:
MARTHA WALKER, ESQUIRE
247 LINCOLN WAY EAST
CHAMBERSBURG, PA 17201-2295
Date: May 1, 2003
IRWIN, McKNIGHT & HUGHES
Mill r, Es uire
Supreme ourt J.D. No. 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Attorney for Petitioner,
Kristin J. Rizzuto
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PJaintiff/Respondent,
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
No. 02 - 1224 CIVIL TERM
KRISTEN N. RIZZUTO,
Defendant/Petitioner.
IN DIVORCE
ORDER OF COURT
AND NOW, this 1~ day of ~
, 2003, upon consideration of the
within Petition for Special Reliel; a hearing is scheduled for _. M 'q I' ,2003, at
1 D:OO o'clock A . m., in Courtroom # S, Cumberland County COurthonse, Carlisle,
PennsylVania 17013,
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LAW OFFICES
JUN 1 O~
IRWIN McKNIGHT & HUGHES
ROGER B. IRWIN
MAf!.CUS A. McKNIGHT, III
JAMES D. HUGHES
REBECCA R. HUGHES
DOUGLAS G. MILLER
WEST POMFRET PROFESSIONAL BUILDING
60 WEST POMFRET STREET
CARLISLE. PENNSYLVANIA 17013-3222
17171 249-2363
FAX (717) 249-6364
~MAft:IMHLAW@SUPERNE~COM
HAROLDS./RWIN (1925-1977)
HAROLD S. IRWIN. JR. (1954-1986)
IRWIN, IRWIN & IRWIN (1956-1986)
IRW1N, IRWIN & McKNIGHT (1986-/994)
IRWIN, McKNIGHT & HUGHES (1994- )
June 9, 2003
THE HONORABLE EDWARD E. GUIDO
CUMBERLAND COUNTY COURTHOUSE
ONE COURTHOUSE SQUARE
CARLISLE, P A 17013
RE: RIZZUTO v. RIZZUTO
DOCKET NO.: 2002 - 1224
Dear Judge Guido: f'LdJ:;-a' fD W, /h~~ P-dihfYl ~(0'p~;"1
This letter shall confirm my telephone conversation with your secretary during which I {(-el j &--
indicated that my client was withdrawing her Petition for Special Relief regarding repossession
of a vehicle.
Thank you for your attempts to schedule a hearing in this matter. Please contact me in
the event there are any additional questions or concerns.
Very truly yours,
IRWIN, McKNIGHT & HUGHES
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DGM:tds
cc: Martha Walker, Esquire
Kristen Rizzuto
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Christopher 1. Rizzuto, )
Plaintiff, )
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Kristen N. Rizzuto, )
Defendant, )
Civil Action - Law
No.02-1224 - Civil Term
In Divorce a v.m.
AFFIDAVIT OF CONSENT
I. A Complaint in Divorce was filed on March 12. 2002
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
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.
Date: .January 16, 2004
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Christopher J. Rizzuto, )
Plaintiff, )
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Kristen N. Rizzuto, )
Defendant, )
Civil Action - Law
No. 02-1224 - Civil Term
In Divorce a v.m.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE
I. 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 in 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 Waiver 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.
Date: Januarv 16. 2004
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Christopher 1. Rizzuto, )
Plaintiff, )
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Kristen N. Rizzuto, )
Defendant, )
Civil Action - Law
No.02-1224 - Civil Term
In Divorce a v.m.
AFFIDAVIT OF CONSENT
I. A Complaint in Divorce was filed on March 12. 2002
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service ofthe Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
I verify that the statements made in this Affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
Date:
1- 13-0t/
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Christopher J. Rizzuto,
Civil Action - Law
Plaintiff,
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No.02-1224 - Civil Term
vs.
Kristen N. Rizzuto,
Defendant,
In Divorce a v.m.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE
I. 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! 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 Waiver 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.
Date: /-/3 -0'/
Christopher J. Rizzuto, Plaintiff
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CUMBERLAND COUNTY, PENNSYLVANIA
Christopher J. Rizzuto, )
Plaintiff, )
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Kristen N, Rizzuto, )
Defendant, )
Civil Action - Law
No. 02-1224 - Civil Term
In Divorce a v.m.
PRAECIPE FOR WITHDRAWAL AND ENTRY OF APPEARANCE
To the Prothonotary:
Please withdraw Robert B. Liberman, Esquire as attorney for the Plaintiff in the
above-captioned case and enter the appearance of Martha B. Walker, Esquire as attorney
for the Plaintiff.
BARLEY, SNYDER, SENFT & COHEN, LLC
BV '-:'1,1i1!.,: ir!U,-
r:t~~y for Plaintiff
fZ~"V .
Robert B. Liberman, Esquire
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CUMBERLAND COUNTY, PENNSYLVANIA
Christopher 1. Rizzuto, )
Plaintiff, )
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vs. )
)
Kristen N. Rizzuto, )
Defendant, )
Civil Action - Law
No. 02-1224 - Civil Term
In Divorce a v,m.
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 Section 3301(c) of the Divorce Code,
2. Date and manner of service of the Complaint: March 22, 2002 - Acceptance of Service signed
by Defendant's counsel.
3. Date of execution ofthe Affidavit of Consent required by Section 3301 (c) of the Divorce Code:
by Plaintiff, January 13,2004; by Defendant, January 16,2004.
4, Related claims pending: Resolved through private Agreement;
5. (a) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: February 10, 2004;
(b) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: January 28, 2004.
BARLEY SNYDER
By:
t€5. ~k-,
artha B, Walker, Esquire
ttorney for Plaintiff
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AND NOW, ' , . . , ' , , . ('fl,~ . iJ:'. . ' , . " iR. 20D4., it is ordered and
decreed that,. ,CIjIUSrQl?Ij~ILJ. ,RIZZUTO...",....,....,.""..,. plaintiff,
and. ,!<?-~13;r!lN, N", ?-~~~!1;rp. , . ' . . . . . . . , . , . . . . . , . , . , . . , . , , . . , . , , " defendant,
are divorced from the bonds of matrimony.
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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
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CHRISTOPHER J, RIZZUTO,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: NO. 02-1224 CIVIL TERM
KRISTEN N. RIZZUTO,
Defendant
: IN DIVORCE
NOTICE OF INTENTION TO
RETAKE AND USE PRIOR NAME
I, KRISTEN N. RIZZUTO, hereby give notice, avowing my intention to resume and
hereafter use my prior surname, to wit: KRISTEN N. STAHL, in accordance with the
provisions of the Act of December 16, 1982, P.L. 1309, No. 295, Section 704(a) (54 Pa.C.S.A.
704(a). My divorce is docketed to 02-1224 Civil Term.
I verify that the statements made in this document are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904 relating to
unsworn falsification to authorities.
IN WITNESS WHEREOF, I have hereunto set my hand and seal this 8th day of March,
2004.
WITNESSED:
vdA9.A--I?<--YfJ!l....Jbd-4k -'
AL)
(SEAL)
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, this 8th day of March, 2004, a Notary
Public, in and for the Commonwealth of Pennsylvania and County of Cumberland, KRISTEN
N, RIZZUTO, known to me (or satisfactorily proven) to be the person whose name is subscribed
to the within Notice of Intention to Retake and Use Prior Name, and acknowledges that she
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
COMMONWEALTH OF PENNSYLVANIA
NcIaftaI SeeI
MaI1ha L Noel. NoIary Pld:
Carliole Boro. Cu.oboIIaIodCallly
My cO','iffiissIon ElqlIres SlIpl. 18. '1!1J7
I\'k__' "~"~;,;::';,vlvania Association Of Notaries
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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
Phone: (717) 240-6225
Fax: (717) 240-6248
Defendant Name: CHRISTOPHER J. RIZZUTO
Member ID Number: 6107100940
Please note: All correspondence must include the Member ill Number.
ORDER TO VACATE ATIACHMENT OF UNEMPLOYMENT BENEFITS
Financial Break Down of Multiole Cases on Attachment
Plaintiff Name
KRISTEN N. RIZZUTO
PACSES
Case Number
197104486
Docket
Number
02-1224 CIVIL
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Attachment Amount/FreQuencv
1,199.00/MONTH
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TOTAL ATTACHMENT AMOUNT: $ 0,00
The prior Order of this Court directing the Department of Labor and Industry, Bureau of
Unemployment Compensation Benefits and Allowances (BUCBA), to attach $ 0.00
or 50 % per week of the Unemployment Compensation benefits of
CHRISTOPHER J. RIZZUTO
, Social Security Number 210-66-7195 ,
Member 10 Number 6107100940 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: --.::tJ Ii I d~
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JUDGE
Service Type M
Form EN-035
Worker ID $IATT
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EmployerMlithholder'S Federal EIN Number
State Commonwpalfh of Ppnnsvlvania
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 04/13/04
Tribunal/Case Number (See Addendum for case summary)
RE: RIZZUTO, CHRISTOPHER J.
Employee/Obligor's Name (last, First, MI)
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
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o Original Order/Notice -,
o Amended Order/Notice
(8) Terminate OrderlNotice
GLOBAL DATA CONSULTANTS, INC.
STE 11
166 S MAIN ST
CHAMBERSBURG PA 17201-2500
210-66-7195
Employee/Obligor's Social Security Number
6107100940
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 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.
$ 0.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? 0 yes <X) no
$ 0.00 per month in medical support
$ 0 . 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ o. 00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the fOllowing to determine how much to withhold:
$ 0.00 per weekly pay period.
$ 0.00 per biweekly pay period (every two weeks).
$ 0.00 per semimonthly pay period (twice a month).
$ 0.00 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 5';% of the employee's! obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #10 on pg. 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 SeDU, 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 NUM'~ER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
Date of Order:
y Ili/~y
BY THE COURC
-
Service Type M
OMB No.: 0970-0154
Form EN-028
Worker 10 $IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If (hecked you are required to provide a ,opy of this form to your employee, If your employee works in a state that is
ditterent from the state that issued this order, a copy must be provided to your employee eVen if the box is not checked,
1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned
businesses located on a reservation that choose to withhold in accordance with this notice,
2, 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,
3, 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,
4, *,:"~~;;~o ~'~ '~~I~~~~~~ ~:~~~'~~I~;t :~~,,:~:~~ ~~:'~ ll~~ ~.~~:.~~;~:~ ~~ :~:~I,.uld;',~ ..I,~" 'c"di"o tl,c pa,,,,,,,,,!. TI,~
pa,ddl"'d'kof..,iI,h"IJ"'o"tl.cda ., I, . ,I" I " "~ce"..gt;, 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,
S. * 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 #10 below)
6, 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,
WITHHOLDER'S ID: 5933412100
EMPLOYEE'S/OBLlGOR'S NAME:
EMPLOYEE'S CASE IDENTIFIER:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
RIZZUTO. CHRISTOPHER J.
6107100940 DATE OF SEI'ARATlON:
7, 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,
8, 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,
9, Antkjiscrimination: 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,
10, * Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (1 S U ,S,C, ~ 1673 (b) 1 ; or 2) the amounts allOWed by the State of the employee's/obligor'S principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE), ADWE is the net Income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes.
11, 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,
Submitted By:
DOMESTIC RElA nONS SECTION
13 N. HANOVER ST
p,O. 80X 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at 07) 240-622S or
by FAX at (7171 240-6248 or
by internet www.childsuPPorl.state.pa.us
Service Type M
Page 2 of 2
OMB No.: 0970-0154
Form EN-028
Worker ID $IATT
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
KRISTEN N. RIZZUTO ) Docket Number 02-1224 CIVIL
Plaintiff )
vs. ) PACSES Case Number 197104486
CHRISTOPHER J. RIZZUTO )
Defendant ) Other State ID Number
ORDER
AND NOW, to wit, on this
3RD DAY OF MAY, 2004
IT IS HEREBY
ORDERED that the support order in this case be 0 Vacated or o Suspended or
~Terminated without prejudice or 0 Terminated and Vacated,
effective JANUARY 16, 2004 , due to:
THE PARTIES' MARITAL SETTLEMENT AGREEMENT. THERE IS A REMAINING CREDIT OF
$1131.52.
DRO: RJ Shadday
xc: plaintiff
defendant
o:>uglas Miller, Esquire
Martha Miller, Esquire
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BYTHECO~
Edward E. Guido
JUDGE
Service Type M
Form OE-S04
Worker ID 21005
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