HomeMy WebLinkAbout06-3626Constance P. Brunt, Esquire
Supreme Court 10 029933
Beaufort Professional Center
1920 Unglestown Road
Harrisburg, PA 17110
(717) 232-7200
c obrunt ftobruntlaw.com
KAREN D. LUNDY, : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
: CIVIL ACTION -LAW
V. : NO. 01. CHADWICK CLAY-ALLEN LUNDY,
Defendant IN DIVORCE
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 Office of the Prothonotary at Cumberland County Courthouse, One Courthouse
Square, Carlisle, PA 17013-3387.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
Constance P. Brunt, Esquire
Supreme Court ID SM33
Beaufort Protssslonal Center
1820 Unglestown Road
Harrisburg, PA 17110
(717) 232-7200
cobruntitcobruntlaw.com
KAREN D. LUNDY, : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
CIVIL ACTION - LAW
V.
: NO. CL
CHADWICK CLAY-ALLEN LUNDY,
Defendant IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW, comes the above-named Plaintiff, KAREN D. LUNDY, by and
through her attorney, CONSTANCE P. BRUNT, ESQUIRE, and seeks to obtain a
Decree in Divorce from the above-named Defendant, CHADWICK CLAY-ALLEN
LUNDY, upon the grounds hereinafter set forth.
COUNTI
DIVORCE
1. Plaintiff is KAREN D. LUNDY, an adult individual, who currently resides at
a confidential address in Cumberland County, Pennsylvania. Plaintiff declines to
disclose her address, due to the existence of a Protection From Abuse Order entered
by this Court on June 14, 2006.
2. Defendant is CHADWICK CLAY-ALLEN LUNDY, an adult individual, who
currently resides at 815 Appletree Lane, Mechanicsburg, Cumberland County,
Pennsylvania 17050.
3. Plaintiff and Defendant have been bona fide residents in the
Commonwealth of Pennsylvania for at least six (6) months immediately previous to the
filing of this Complaint.
4. The Plaintiff and Defendant were married on July 1, 1989, in
Mechanicsburg, 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 the United States of
America.
7. The Defendant is not a member of the Armed Services of the United
States or any of its allies.
8. The Plaintiff has been advised of the availability of marriage counseling
and understands that she may request that the Court require the parties to participate in
counseling.
9. The Plaintiff avers that the grounds on which the action is based are that
Defendant has offered such indignities to the person of the Plaintiff, the innocent and
injured spouse, as to render her condition intolerable and life burdensome.
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10. Plaintiff requests the Court to enter a Decree in Divorce.
COUNT II
REQUEST FOR EQUITABLE DISTRIBUTION OF MARITAL
PROPERTY UNDER SECTION 35021a1 OF THE DIVORCE CODE
11. Paragraphs 1 through 7 inclusive of Count I are specifically incorporated
by reference as though fully set forth hereinafter.
12. Plaintiff and Defendant have individually or jointly acquired real and
personal property during the marriage, in which they individually or jointly have a legal
or equitable interest, which marital property is subject to equitable distribution.
13. Plaintiff requests the Court to determine and equitably distribute, divide or
assign said marital property, pursuant to Section 3502 of the Divorce Code.
COUNT III
REQUEST FOR ALIMONY PENDENTE LITE, COUNSEL FEES.
COSTS AND EXPENSES UNDER SECTION 3702 OF THE DIVORCE CODE
14. Paragraphs 1 through 7 inclusive of Count I are specifically incorporated
by reference as though fully set forth hereinafter.
15. Plaintiff is without sufficient assets and income to support herself and pay
her attorney's fees and the costs and expenses of this action.
16. Defendant has sufficient earning capacity to support the Plaintiff and to
pay the Plaintiffs attorney's fees and the costs and expenses of this action.
-3-
17. Plaintiff requests the Court to order the Defendant to support the Plaintiff
during the pendency of this action and to pay Plaintiffs counsel fees, expenses and the
costs of this action, pursuant to Section 3702 of the Divorce Code.
COUNT IV
REQUEST FOR ALIMONY UNDER
SECTION 3701 OF THE DIVORCE CODE
18. Paragraphs 1 through 7 inclusive of Count I are specifically incorporated
by reference as though fully set forth hereinafter.
19. Plaintiff lacks sufficient property to provide for her reasonable needs.
20. Plaintiff is unable to sufficiently support herself through appropriate
employment.
21. Defendant has sufficient property, assets, and income to provide
continuing support for the Plaintiff.
22. Plaintiff requests the Court to order the Defendant to pay alimony to
Plaintiff pursuant to Section 3701 of the Divorce Code.
WHEREFORE, Plaintiff prays that your Honorable Court enter a Decree in
Divorce as follows:
(a.) dissolving the marriage between the parties;
(b.) equitably distributing, dividing or assigning the marital property of
the parties;
a-
(c.) ordering Defendant to pay alimony pendente lite, counsel fees,
expenses and costs of this action to Plaintiff;
(d.) ordering Defendant to pay alimony to Plaintiff; and
(e.) granting such other further relief as the Court deems appropriate.
Respectfully submitted,
CONSTANCE P. BRUNT, ESQUIRE
Supreme Court ID# 29933
Beaufort Professional Center
1820 Linglestown Road
Harrisburg, PA 17110-3339
(717) 232-7200
Attorney for Plaintiff
-5-
VERIFICATION
I verify that the statements made in the foregoing Complaint In Divorce are true
and coned. I understand that false statements herein are made subject to the
penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities.
DATED:
KAREN D. LUND , Plainf
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Constance P. Snarl, Esquire
Supreme Court ID /29939
Beaufort Professional Carrier
1920 Unpleataarn Poed
FlwfMx rp, PA 17110
(717) 232-7200
cobrunl@cobruntlaw.com
KAREN D. LUNDY, : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
CIVIL ACTION - LAW
V. • NO. 6(o--34.2C Ccc?cC, [ ?iL
CHADWICK CLAY-ALLEN LUNDY,
Defendant : IN DIVORCE
PETITION FOR ALIMONY PENDENTE UTE
AND NOW, comes the Petitioner, KAREN D. LUNDY, by and through her
attorney, CONSTANCE P. BRUNT, ESQUIRE, and files the following Petition For
Alimony Pendente Lite:
1. Plaintiff/Petitioner, KAREN D. LUNDY, is an adult individual currently
residing at a confidential address in Cumberland County, Pennsylvania, and is the
Plaintiff in the above-captioned divorce action.
2. The Defendant/Respondent, CHADWICK CLAY-ALLEN LUNDY, is an
adult individual residing at 815 Appletree Lane, Mechanicsburg, Cumberland County,
Pennsylvania 17050, and is the Defendant in the above-captioned divorce action.
3. Simultaneously with the filing of this Petition, the Plaintiff/Petitioner
has filed a Complaint in Divorce in the above matter, in which she raised a claim for
alimony pendente lite in Count III.
4. The Plaintiff/Petitioner is employed at Yes Solutions, Mechanicsburg,
Pennsylvania, earning approximately $30,000 per year gross.
5. Defendant/Respondent is employed by PMAC Auto, earning in excess
of $100,000 per year gross.
6. Plaintiff/Petitioner is unable to provide and maintain the standard of
living to which she was accustomed and is need of alimony pendente lite to support
herself and to adequately protect her rights and interests in the pending divorce action.
7. Defendant/Respondent has sufficient assets and income to provide
continuing support to Plaintiff/Petitioner.
WHEREFORE, Plaintiff/Petitioner prays this Honorable Court to enter an Order
directing Defendant/Respondent to pay alimony pendente lite to Plaintiff/Petitioner in
accordance with the guidelines set forth in the Rules of Civil Procedure.
Respectfully submitted,
ZX
CONSTANCE P. BRUNT, ESQUIRE
Attorney I. D. No. 29933
Beaufort Professional Center
1820 Linglestown Road
Harrisburg, PA 17110
(717) 232-7200
Attorney for Plaintiff/Petitioner
VERIFICATION
I verify that the statements made in the foregoing Petition For Alimony Pendente
Lite are true and correct. I understand that false statements herein are made subject to
the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities.
DATED: to/a4OZO Gu e- L Z?
KAREN D. LUND ,
Plaintiff/Petitioner
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KAREN D. LUNDY, THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - DIVORCE
NO. 06-3626 CIVIL TERM
CHADWICK C-A LUNDY, IN DIVORCE
Defendant/Respondent
PACSES CASE NO: 952108394
ORDER OF COURT
AND NOW, this 27th day of June, 2006, upon consideration of the Petition for Alimony Pendente
Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before
R.J. Shaddav on Wednesday. Aueust 2.2006 at 9:00 A.M. for a conference, at 13 N. Hanover St., Carlisle,
PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be
entered.
YOU are further ordered to bring to the conference
(1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed
(2) your pay stubs for the preceding six (6) months
(3) the Income and Expense Statement attached to this order, completed as required by Rule
1910.11 C
(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.
Copies mailed on
June 27, 2006 to: Petitioner
Respondent
Constance P. Brunt, Esq.
Date of Order: June 27, 2006
BY THE COURT,
Edgar B. Bayley, President Judge
J. adday, Conference Officer
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND /?,e/
REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET
LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVE.
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
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Constance P. Brunt, Esquire
Supreme Court ID #29933
Beaufort Professional Center
1820 Linglestown Road
Harrisburg, PA 17110
(717) 232-7200
cpbruntacpbru ntlaw.com
KAREN D. LUNDY,
Plaintiff
V.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO. 06-3626 CIVIL TERM
CHADWICK CLAY-ALLEN LUNDY,
Defendant
IN DIVORCE
ACCEPTANCE OF SERVICE
I, ANDREW C. SHEELY, ESQUIRE, attorney for the Defendant, CHADWICK
CLAY-ALLEN LUNDY, in the above-captioned divorce action, hereby accept service
of the Complaint In Divorce and the Petition For Alimony Pendente Lite, both filed on
June 26, 2006, in the Court of Common Pleas of Cumberland County, Pennsylvania,
and certify that I am authorized to do so.
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Date: 7131 44e4l
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ANDREW C. SHEEL , SQUIRE
127 South Market Street
P.O. Box 95
Mechanicsburg, PA 17055
(717) 697-7050
Attorney for Defendant
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KAREN D. LUNDY, IN THE COURT OF COMMON PLEAS OF
P1aintifflPetitioner CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - DIVORCE
NO. 06-3626 CIVIL TERM
CHADWICK C. LUNDY, IN DIVORCE
Defendant/Respondent
PACSES # 952108394
ORDER OF COURT
AND NOW, this 2nd day of August, 2006, based upon the Court's determination that
Petitioner's monthly net income/earning capacity is $2134.59 and Respondent's monthly net
income/earning capacity is $7167.43, it is hereby Ordered that the Respondent pay to the
Pennsylvania State Collection and Disbursement Unit, $752.00 per month payable as follows:
$687.00 for alimony pendente lite and $65.00 on arrears. First payment due August 5, 2006. Arrears
set at $1374.00 as of August 2, 2006
The effective date of the order is June 22, 2006.
Failure to make each payment on time and in full will cause all arrears to become subject to
immediate collection by all of the means as provided by 23 Pa.C.S.§ 3703. Further, if the Court
finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare
the Respondent in civil contempt of Court and its discretion make an appropriate Order, including,
but not limited to, commitment of the Respondent to prison for a period not to exceed six months.
Said money to be turned over by the PA SCDU to: Karen D. Lundy. Payments must be made
by check or money order. All checks and money orders must be made payable to PA SCDU and
mailed to:
PA SCDU
P.O. Box 69110
Harrisburg, PA 17106-9110
Payments must include the Respondent's PACSES Member Number or Social Security
Number in order to be processed. Do not send cash by mail.
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This Order is a deviation of the Pennsylvania Guideline Calculation, contingent on the marital
home being listed for sale within 60 days and sold within the next six (6) months from this date. At
the end of the six (6) months, either party may request the Alimony Pendente Lite matter be reviewed.
The Parties agree that the effective date of this order is June 22, 2006.
This Order considers that there is a child support obligation for the parties' two children under
PACSES case #159108374.
This Order shall become final ten days after the mailing of the notice of the entry of the Order
to the parties unless either party files a written demand with the Prothonotary for a hearing de novo
before the Court.
Consented:
Petitioner
Petitioner's Attorney
Respondent Respondent's Attorney
DRO: R. J. Shadday BY THE COURT,
Mailed copies on: Petitioner
August 2, 2006 Respondent
Constance P. Brunt, Esq.
Andrew C. Sheely, Esq
M. L. Ebert, Jr., J.
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ORDERINOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsylvania
Co./City/Dirt. of CUMBERLAND
Date of Order/Notice 08/02/06
Case Number (See Addendum for case summary)
EmployerANithholder's Federal EIN Number
S P AUTO PARTS INC
201 EXECUTIVE DR
MOORESTOWN NJ 08057-4221
OI0-,511D2.10 G1V`L
RE: LUNDY, CHADWICK C.
Q Original Order/Notice
O Amended Order/Notice
O Terminate Order/Notice
Employee/Obligor's Name (Last, First, MI)
1591083-A 369-90-9887
CS` C` "J 10011O Employee/Obligor's Social Security Number
0806101684
Employee/Obligor's Case Identifier
(See Addernlme for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee'slobligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 2, 310.00 per month in current support
$ 216.66 per month in past-due support Arrears 12 weeks or greater? 0 yes (S) no
$ o. oo per month in current and past-due medical support
$ 0.0 o per month for genetic test costs
$ per month in other (specify)
for a total of $ 2, 526.66 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:
$ 583. o8 per weekly pay period.
$ 1.166.15 per biweekly pay period (every two weeks).
$ 1.263.33 per semimonthly pay period (twice a month).
$ 2.526.66 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
OrderlNotice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on page 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAMEAND THE PACSES MEMBER /D (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
AUG 0 3 2006
Date of Order:
BY IrT
' Form EN-0
Service Type M OMB No.; 0970-0154 Worker ID
r ` ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
? I heck you are required, to provide a opy of this form to your?U.Ioyee. If yo r employeq %rks in a state thafkis
?ifhferent from the state that issued this onfer, a copy must be provi eedd to your empYoyee even if t e box is not chec ed.
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.* 111o . 111V
You must comply with the law of the
paydateidate of withholding is the date on which a ... mit v... .0thheld from the employee's wages7 state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employeelobligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 5214512040
EMPLOYEE'S/OBLIGOR'S NAME: LUNDY, CHADWICK C.
EMPLOYEE'S CASE IDENTIFIER: 0806101684 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAMEIADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the 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 govems.
8. Antidiscrimination: You are subject to a fine determined under State law for discharging an employeelobligor from employment,
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more
than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more
than the amounts allowed under the law of the state that issued the order.
10. Additional Info:
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
11.Submitted By: If you or your employee/obligor have any questions,
DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT
13 N HANOVER ST by telephone at (717) 240-6225 or
P.O. BOX 320 by FAX at (7171240-6248 or
CARLISLE PA 17013 by internet www.childsupport.state.pa.us
Page 2 of 2 Form EN-028
Service Type M OMB No, 09]00154 Worker ID $IATT
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: LUNDY, CHADWICK C.
PACSES Case Number 159108374
Plaintiff Name
KAREN D. LUNDY
Docket Attachment Amount
00519 S 2006 $ 1,774.66
Child(ren)'s Name(s): DOB
JAMES R. LUNDY 05/08/96
ICAtTLYN M LtINFSf 02/22/95
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number 952108394
Plaintiff Name
KAREN D. LUNDY
Docket Attachment Amount
06-3626 CIVIL$ 752.00
Child(ren)'s Name(s): DOB
?if checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
KAREN D. LUNDY ) Docket Number 06-3626 CIVIL
Plaintiff )
vs. ) PACSES Case Number 952108394
CHADWICK C. LUNDY )
Defendant ) Other State ID Number
PETITION FOR MODIFICATION
OF AN EXISTING SUPPORT ORDER e * k
1. The petition of CHADWICK C. LUNDY respectfully
represents that on AUGUST 2, 2006 , an Order of Court was entered for
KAREN D. LUNDY
A true and correct copy of the order is attached to this petition.
Service Type M
Form OM-501
Worker ID 21205
1
LUNDY v. LUNDY PACSES Case Number: 952108394
2. Petitioner is entitled to O increase ) decrease 0 termination O reinstatement
O other of this Order because of the following material and substantial change(s) in
circumstance:
PLEASE STATE YOUR REASON(s) FOR REQUESTING A MODIFICATION OF YOUR
CURRENT ORDER HERE
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WHEREFORE, Petitioner requests that the Court modify the existing order
Petitioner Attorney for Petitioner
I verify that the statements made in this complaint are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to
unworn falsification to authorities.
Date
Petitioner
Page 2 of 2 Form OM-501
Service Type M Worker ID 21205
.
2 08 0024 F42
S P AUTO PARTS INC
201 EXECUTIVE DRIVE
MOORESTOWN, NJ 08057
ipioyee Number: 0024
parttrent Number. 08
Security Number: XXX-XX-9887
_' :vital Status: MARRIED
,,,dumber Of Allowances: 00
Hnurs and Farninas
Earnings Statement
Pay Period: 12JO712006 to 12/20;2006
Pay Date: 12/22/2006
Check #: 21801975
CHADWICK LUNDY
815 APPLETREE LANE
MECHANICSBURG, PA 17050
Taxes and Deductions
Descri tion Hours This Period Year-To-Date Description This Period rez r
SALARY 50516.07 FED WT 1
(COMMIS 59156.80 FICA 2.90
II1i0NUS1 200.00 200.00 PA UC .18
PA ST I 6.14 -
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$109,872.87 $200.00 $13.42 $1tio.58
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KAREN D. LUNDY,
Plaintiff/Petitioner
VS.
CHADWICK C. LUNDY,
Defendant/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 06-3626 CIVIL TERM
IN DIVORCE
PACSES # 952108394
ORDER OF COURT
AND NOW, this 2nd day of August, 2006, based upon the Court's determination that
Petitioner's monthly net income/earning capacity is $2134.59 and Respondent's monthly net
income/earning capacity is $7167.43, it is hereby Ordered that the Respondent pay to the
Pennsylvania State Collection and Disbursement Unit, $752.00 per month payable as follows:
$687.00 for alimony pendente lite and $65.00 on arrears. First payment due August 5, 2006. Arrears
set at $1374.00 as of August 2, 2006
The effective date of the order is June 22, 2006.
Failure to make each payment on time and in full will cause all arrears to become subject to
immediate collection by all of the means as provided by 23 Pa.C.S.§ 3703. Further, if the Court
finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare
the Respondent in civil contempt of Court and its discretion make an appropriate Order, including,
but not limited to, commitment of the Respondent to prison for a period not to exceed six months.
Said money to be turned over by the PA SCDU to: Karen D. Lundy. Payments must be made
by check or money order. All checks and money orders must be made payable to PA SCDU and
mailed to: ,
PA SCDU
P.O. Box 69110
Harrisburg, PA 17106-9110
Payments must include the Respondent's PACSES Member Number or Social Security
Number in order to be processed. Do not send cash by mail.
cc360
t i
This Order is a deviation of the Pennsylvania Guideline Calculation, contingent on the marital
home being listed for sale within 60 days and sold within the next six (6) months from this date. At
the end of the six (6) months, either party may request the Alimony Pendente Lite matter be reviewed.
The Parties agree that the effective date of this order is June 22, 2006.
This Order considers that there is a child support obligation for the parties' two children under
PACSES case #159108374.
This Order shall become final ten days after the mailing of the notice of the entry of the Order
to the parties unless either party files a written demand with the Prothonotary for a hearing de novo
before the Court.
Consented:
Petitioner
Respondent
DRO: R. J. Shadday
Mailed copies on: Petitioner
August 2, 2006 Respondent
Constance P. Brunt, Esq.
Andrew C. Sheely, Esq
Petitioner's Attorney
Respondent's Attorney
BY THE COURT,
N j. Q" V,.
M. L. Ebert, Jr., J.
C°? r?
ca
d
:rP
KAREN D. LUNDY,
Plaintiff/Petitioner
VS.
CHADWICK C. LUNDY,
Defendant/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 06-3626 CIVIL TERM
IN DIVORCE
PACSES Case Number 952108394
ORDER OF COURT
AND NOW, this 31 st day of January, 2007, based upon the Court's determination that
Petitioner's monthly net income/earning capacity is $2165.40 and Respondent's monthly net
income/earning capacity is $6224.46, it is hereby Ordered that the Respondent pay to the
Pennsylvania State Collection and Disbursement Unit, $389.00 per month payable as follows:
$389.00 per month for alimony pendente lite and $00.00 per month on arrears. First payment due
next wage withholding payment. Credit set at -$224.10 as of January 31, 2007.
The effective date of the order is January 9, 2007.
Failure to make each payment on time and in full will cause all arrears to become subject to
immediate collection by all of the means as provided by 23 Pa.C.S.§ 3703. Further, if the Court
finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare
the Respondent in civil contempt of Court and its discretion make an appropriate Order, including,
but not limited to, commitment of the Respondent to prison for a period not to exceed six months.
Said money to be turned over by the PA SCDU to: Karen D. Lundy. Payments must be made
by check or money order. All checks and money orders must be made payable to PA SCDU and
mailed to:
PA SCDU
P.O. Box 69110
Harrisburg, PA 17106-9110
Payments must include the Respondent's PACSES Member Number or Social Security
Number in order to be processed. Do not send cash by mail.
cc360
I%V
This Order is a deviation of the Pennsylvania Guideline Calculations based upon the fact that
the marital home is under a sales contract and settlement is scheduled for March 30, 2007.
Effective April 1, 2007, the Alimony Pendente Lite is to increased to $768.00 per month.
This Order considers that there is a child support obligation for th parties' two children under
PACSES #159108374 Docket No. 00519 S 2006.
This Order shall become final ten days after the mailing of the notice of the entry of the Order
to the parties unless either party files a written demand with the Prothonotary for a hearing de novo
before the Court.
Consented:
Petitioner
Respondent
Petitioner's Attorney
Respondent's Attorney
BY THE COURT,
N-L M. L. Ebert, Jr., J.
Mailed copies on: February 1, 2007
to: Petitioner
Respondent
Constance P. Brunt, Esq.
Andrew C. Sheely, , Esq.
DRO: R.J. Shadday
N
<
_Y t •`t"'t i it ?,::.
C7,?
.F
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT ('I U1
State Commonwealth of Pennsylvania 15'f / () S 374- O Original Order/Notice
Co./City/Dist. of CUMBERLAND 0 Amended Order/Notice
Date of Order/Notice 01/31/07 5?R lJV O Terminate Order/Notice
Case Number (See Addendum for case summary)
RE: LUNDY, CHADWICK C.
Employer/Withholder's Federal EIN Number Employee/Obligor's Name (Last, First, MI)
S P AUTO PARTS INC
201 EXECUTIVE DR
MOORESTOWN NJ 08057-4221
369-90-9887
Employee/Obligor's Social Security Number
0806101684
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
See Addendum for dependent names and birth dates associated with cases on attachment
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 1, 889 .00 per month in current support
$ 78.00 per month in past-due support Arrears 12 weeks or greater? Dyes ® no
$ 0.00 per month in current and past-due medical support
$ 0.00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 1, 967.00 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:
$ 453.92 per weekly pay period.
$ 907. 85 per biweekly pay period (every two weeks).
$ 983.50 per semimonthly pay period (twice a month).
$ 1, 967. o0 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on page 2).
If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call
Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580
for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BY THE COURT:
Date of Order: IER 4 i 2-o
Service Type M
For N-028 Rev.'
A I-.I.... 1r,%
OMB No.: 0970-0154
$IATT
F.
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
? Me' hecke?i you are required to provide a copy of this form to yourvloyee. If yo?1r employee works in a state that is
rent rrom the state that issued this order, a copy must be provi eeccii to your employee even if the box is not checked.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employeelobligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employee/obligor.
3.* Reporting the Paydatefflate of Withholding. You must report the paydate/date of withholding when sending the payment. The
paydate/date of withholding is the date on which amount was vvithhe'd from the employee's wages. You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 5214512040
EMPLOYEE'S/OBLIGOR'S NAME: LUNDY, CHADWICK C.
EMPLOYEE'S CASE IDENTIFIER: 0806101684 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employeelobligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Antidiscrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment,
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.S.C. §1673 01; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more
than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more
than the amounts allowed under the law of the state that issued the order.
10. Additional Info:
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
11. Submitted By: If you or your employee/obligor have any questions,
DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT
13 N. HANOVER ST by telephone at (717) 240-6225 or
P.O. BOX 320 by FAX at (717) 240-6248 or
CARLISLE PA 17013 by internet www.childsupport.state.pa.us
Service Type M
Page 2 of 2
Form EN-028 Rev. 1
Worker I D $ IATT
OMB No.: 0970-0154
J ?
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: LUNDY, CHADWICK C.
PACSES Case Number 159108374
Plaintiff Name
KAREN D. LUNDY
Docket Attachment Amount
00519 S 2006 $ 1,578.00
Child(ren)'s Name(s): DOB
JAMES,.. R. ..LUNDY... 05/,08/96,
nITLYN M.LUNDY ?f95
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Service Type M
PACSES Case Number 952108394
Plaintiff Name
KAREN D. LUNDY
Docket Attachment Amount
06-3626 CIVIL$ 389.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Addendum
OMB No.: 0970-0154
Form EN-028 Rev. 1
Worker ID $IATT
C? G
-- ; _ `-VI
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsylvania
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 03/27/07
Case Number (See Addendum for case summary)
EmployerM/ithholder's Federal EIN Number
S P AUTO PARTS INC
201 EXECUTIVE DR
MOORESTOWN NJ 08057-4221
159108374 O Original Order/Notice
519 S 2006
O Amended Order/Notice
952108394 O Terminate Order/Notice
06-3626 CIVIL
RE: LUNDY, CHADWICK C.
Employee/Obligor's Name (Last, First, MI)
369-90-9887
Employee/Obligor's Social Security Number
0806101684
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 1, 889. oo per month in current support
$ o . oo per month in past-due support Arrears 12 weeks or greater? Dyes ® no
$ 0.00 per month in current and past-due medical support
$ 0.00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 1, 889.00 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:
$ 435.92 per weekly pay period.
$ 871.85 per biweekly pay period (every two weeks).
$ 944.50 per semimonthly pay period (twice a month).
$ 1.889. oo per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on page 2).
If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call
Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580
for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BY THE COURT:
Date of Order:
DRO: R.J. Shadday
Service Type M
N -f L
M. L. Ebert, Jr., qe
For Efv028 V.
OMB No.: 0970-0154 Worker I D $ IATT
9-
h
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
? Ifgheckeff you are required to provide a copy of this form to your3mployee. If yorr employee works in a state that is
di Brent rrom the state that issued this order, a copy must be provi edd to your employee even if the box is not checked.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employee/obligor.
3.* Reporting
the Payddte/E)ate of Withholding. You must report the paydateldate of withholding when sendivir the Pdymelit.
paydate/date of withholding 65 t i je date on which amount was withheld froin the employee's wages. You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 5214512040
EMPLOYEE'S/OBLIGOR'S NAME: LUNDY, CHADWICK C.
EMPLOYEE'S CASE IDENTIFIER: 0806101684 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Antidiscrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment,
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9.* Withholding Limits: You may not withhold more than the lesser of. 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more
than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more
than the amounts allowed under the law of the state that issued the order.
10. Additional Info:
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
11 -Submitted By: If you or your employee/obligor have any questions,
DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
Service Type M
by telephone at (717) 240-6225 or
by FAX at (717) 240-6248 or
by internet www.childsupport.state.pa.us
Page 2 of 2
OMB No.: 0970-0154
Form EN-028 Rev. 1
Worker ID $ IATT
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: LUNDY, CHADWICK C.
PACSES Case Number 159108374
Plaintiff Name
KAREN D. LUNDY
Docket Attachment Amount
00519 S 2006 $ 1,500.00
Child(ren)'s Name(s): DOB
JAMES R. LUNDY 05,,08/96
KAIT,YN M.' LUNDY 02/2 J.S
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACKS Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Service Type M
PACSES Case Number 952108394
Plaintiff Name
KAREN D. LUNDY
Docket Attachment Amount
06-3626 CIVIL$ 389.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Addendum
OMB No.: 0970-0154
Form EN-028 Rev. 1
Worker I D $ IATT
0
rZ~;sc.
r .,;
co -V M
_x)
. tom:
t, .? :7...T?
C-n
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: LUNDY, CHADWICK C.
PACSES Case Number 159108374 PACSES Case Number 952108394 +
Plaintiff Name Plaintiff Name
KAREN D. LUNDY KAREN D. LUNDY
Docket Attachment Amount Docket Attachment Amount
00519 S 2006 $ 1,500.00 06-3626 CIVIL$ 768.00
Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB
JAMES R.. ..LIMY 0,5,08/96.
M. TLYN M. LUNDY (12 / f 9:5
? If checked, you are required to enroll the child(ren) ? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available identified above in any health insurance coverage available
through the employee's/obligor's employment. through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Service Type M
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Addendum
OMB No.: 0970-0154
Form EN-028 Rev. 1
Worker ID 21205
159108374
?I ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 519 S 2006
State Commonwealth of Pennsylvania
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 06/15/07
Case Number (See Addendum for case summary)
Employer/Withholder's Federal EIN Number
S P AUTO PARTS INC
201 EXECUTIVE DR
MOORESTOWN NJ 08057-4221
952108394
06-3626 CIVIL
O Original Order/Notice
O Amended Order/Notice
O Terminate Order/Notice
RE: LUNDY, CHADWICK C.
Employee/Obligor's Name (Last, First, MI)
369-90-9887
Employee/Obligor's Social Security Number
0806101684
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 2, 268. 00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Qyes ® no
$ 0. oo per month in current and past-due medical support
$ 0.00 per month for genetic test costs
$ 0.00 per month in other (specify)
for a total of $ 2, 268.00 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:
$ _ 523.38 per weekly pay period.
$ _ 1046.77 per biweekly pay period (every two weeks).
$ 1,134. oo per semimonthly pay period (twice a month).
$ 2, 268. go per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on page 2).
If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call
Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580
for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
Date of Order: JUN 15 2007
DRU: R. J. Shadday
Service Type M
BY THE COURT:
N -L
M. L. Ebert, Jr., Judge
Form EN-028 Rev.
OMB No,0970-01S4 Worker ID 21205
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
? If hecke? you are required to provide a opy of this form to your m loyee. If yo r employee works in a state that is
diferent from the state that issued this order, a copy must be provi?edpto your employee even if the box is not checked.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employee/obligor.
3.* Reporting the Paydate/Date of Withholding. You inust report the paydateldate of withholding when sending the payment. The
paydate/date of withholding is the date vi i which amount was withheld from the employee's wag You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 5214512040
EMPLOYEE'S/OBLIGOR'S NAME: LUNDY, CHADWICK C.
EMPLOYEE'S CASE IDENTIFIER: 0806101684 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment,
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.S.C. §1673 01; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more
than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more
than the amounts allowed under the law of the state that issued the order.
10. Additional Info:
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
11.Submitted By: If you or your employee/obligor have any questions,
DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT
13 N. HANOVER ST by telephone at (717) 240-6225 or
P.O. BOX 320 by FAX at (717) 240-6248 or
CARLISLE PA 17013 by internet www.childsupport.state.pa.us
Service Type M
Page 2 of 2
Form EN-028 Rev. 1
Worker ID 21205
OMB No.: 0970-0154
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: LUNDY, CHADWICK C.
PACSES Case Number 159108374
Plaintiff Name
KAREN D. LUNDY
Docket Attachment Amount
00519 S 2006 $ 1,500.00
Child(ren)'s Name(s): DOB
JAMES R. LUNDY 05.08196
KA.XTLYN M. tVNDY 02 tt 1119.5.
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
PACSES Case Number 952108394
Plaintiff Name
KAREN D. LUNDY
Docket Attachment Amount
06-3626 CIVIL$ 768.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren) ? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available identified above in any health insurance coverage available
through the employee's/obligor's employment. through the employee's/obligor's employment.
Addendum Form EN-028 Rev. 1
Service Type M Worker ID 21205
OMB No.: 0970-0154
r»
.
CA ,
? ^v
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
KAREN D. LUNDY ) Docket Number 06-3626 CIVIL
Plaintiff )
VS. ) PACSES Case Number 952108394
CHADWICK C. LUNDY )
Defendant ) Other State ID Number
PETITION FOR MODIFICATION
OF AN EXISTING SUPPORT ORDER
1. The petition of CHADWICK C. LUNDY respectfully
represents that on JANUARY 31, 2007 , an Order of Court was entered for
KAREN D. LUNDY
A true and correct copy of the order is attached to this petition.
c
Form OM-501
Service Type M Worker ID 21205
.p. t ,
LUNDY V. LUNDY PACSES Case Number: 952108394
2. Petitioner is entitled to 0 increase decrease 0 termination 0 reinstatement
0 other of this Order because of the following material and substantial change(s) in
circumstance:
PLEASE STATE YOUR REASON(S) FOR REQUESTING A MODIFICATION OF YOUR
C RENT ORDER HERE:
a des `? a w e D
WHEREFORE, Petitioner requests that the Court modify the existing order
Q?2W
Petitioner Attorney for Petitioner
I verify that the statements made in this complaint are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to
unworn falsification to authorities.
-2 /
Date
-d?=
Petitioner
Page 2 of 2 Form OM-501
Service Type M Worker ID 21205
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
KAREN D. LUNDY ) Order Number 00519 S 2006
Plaintiff )
VS. ) PACSES Case Number 159108374
CHADWICK C. LUNDY ) Docket Number 00519 S 2006
Defendant ) Other State ID Number
ORDER OF COURT
Q Final ® Interim O Modified
AND NOW, 31ST DAY OF JANUARY, 2007 based upon the Court's
determination that the Payee's monthly net income is $ 2, 16 5.4 0 and the Payor's
monthly net income is $ 6, 224.46 , it is hereby ordered that the Payor pay to the
Pennsylvania State Collection and Disbursement Unit
ONE THOUSAND FIVE HUNDRED SEVENTY EIGHT AND XX/100
Dollars ($1, 578.00 ) a month payable BIWEEKLY as follows: first payment due
NEXT MODIFIED WAGE ATTACHED PAYMENT.
The effective date of the order is 01/09/07 .
Arrears set at $ 154.42 as of JANUARY 31, 2007 are due in full
IMMEDIATELY. All terms of this Order are subject to collection and/or enforcement by
contempt proceedings, credit bureau reporting, tax refund offset certification, driver's license
revocation, and the freeze and seize of financial assets. These enforcement/collection
mechanisms will not be initiated as long as obligor does not owe overdue support. Failure to
make each payment on time and in full will cause all arrears to become subject to immediate
collection by all the means listed above.
For the Support of:
Name Birth Date
JAMES R. LUNDY 05/08/96
KAITLYN M. LUNDY 02/22/95
ti
Form OE-518
Service Type M Worker ID 21005
LUNDY V. LUNDY PACSES Case Number: 159108374
The defendant owes a total of $ 1, 578. 00 per month payable BIWEEKLY ;
$ 1,500.00 for current support and $ 7 8.0 0 for arrears. The defendant must
also pay fees/costs as indicated below. This order is allocated and monies are to be applied as
follows :
Frequency Codes: 1 =One Time B =BiWeAly 2 =Bi-Monthly M =Monthly
5 =Semi-Annually S =Semi-Monthly A =Annually W =Weekly
Payment Amount/
Frequency
T)ebt Type Description $Pneficiar;
$ 750.00 /M CHILD SPT ALLOC JAMES R. LUNDY
$750.00 /M CHILD SPT ALLOC KAITLYN M. LUNDY
$ 0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
Said money to be turned over by the Pa SCDU to:
Q = Quarterly
KAREN D. LUNDY . Payments must be made by check or
money order. All checks and money orders must be made payable to Pa SCDU and mailed to:
Pa SCDU
P.O. Box 69110
Harrisburg, Pa 17106-9110
Payments must include the defendant's PACSES Member dumber or Social Security Number
in order to be processed. Do not send cash by mail.
Page 2 of 4 Form OE-518
Service Type M Worker ID 21005
LUNDY v. LUNDY PACSES Case Number: 159108374
Unreimbursed medical expenses that exceed $250.00 annually per child and/or spouse
are to be paid as follows: 74 % by defendant and 26 % by plaintiff. The plaintiff is
responsible to pay the first $250.00 annually (per child and/or spouse) in unreimbursed
medical expenses. O Defendant (D Plaintiff O Neither party to provide medical insurance
coverage. Within thirty (30) days after the entry of this order, the (j)Plaintiff
O Defendant shall submit to the person having custody of the child(ren) 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.
Other Conditions:
Defendant shall pay the following fees:
Fee Total Fee Description
$ 0.00 for JUDICIAL COMPUTER FEE
$ 0.00 for COURT COSTS
$ 0.00 for
$ 0.00 for
$ 0.00 for
Eayment Fre =U
Payable at $ 0 . o o
Payable at $ 0.0 0
Payable at $ 0 . o 0
Payable at $ 0. 0 o
Payable at $ 0 . 0 0
per ONE TIME
per ONE TIME
per
per
per
Page 3 of 4 Form OE-518
Service Type M Worker ID 21005
LUNDY V. LUNDY PACSES Case Number: 159108374
IMPORTANT LEGAL NOTICE
PARTIES MUST WITHIN SEVEN DAYS INFORM THE DOMESTIC RELATIONS SECTION AND
THE OTHER PARTIES, IN WRITING, OF ANY MATERIAL CHANGE IN CIRCUMSTANCES RELEVANT
TO THE LEVEL OF SUPPORT OR THE ADMINISTRATION OF THE SUPPORT ORDER, INCLUDING,
BUT NOT LIMITED TO, LOSS OR CHANGE OF INCOME OR EMPLOYMENT AND CHANGE OF
PERSONAL ADDRESS OR CHANGE OF ADDRESS OF ANY CHILD RECEIVING SUPPORT. A PARTY
WHO WILLFULLY FAILS TO REPORT A MATERIAL CHANGE IN CIRCUMSTANCES MAY BE ADJUDGED IN
CONTEMPT OF COURT, AND MAYBE FINED OR IMPRISONED.
PENNSYLVANIA LAW PROVIDES THAT ALL SUPPORT ORDERS SHALL BE REVIEWED AT LEAST
ONCE EVERY THREE (3) YEARS IF SUCH REVIEW IS REQUESTED BY ONE OF THE PARTIES. IF
YOU WISH TO REQUEST A REVIEW AND ADJUSTMENT OF YOUR ORDER, YOU MUST DO THE
FOLLOWING: CALL YOUR ATTORNEY. AN UNREPRESENTED PERSON WHO WANTS TO MODIFY
(ADJUST) A SUPPORT ORDER SHOULD CONTACT THE DOMESTIC RELATIONS SECTION.
ALL CHARGING ORDERS FOR SPOUSAL SUPPORT AND ALIMONY PENDENTE LITE, INCLUDING
UNALLOCATED ORDERS FOR CHILD AND SPOUSAL SUPPORT OR CHILD SUPPORT AND ALIMONY
PENDENTE LITE, SHALL TERMINATE UPON DEATH OF THE PAYEE.
A MANDATORY INCOME ATTACHMENT WILL ISSUE UNLESS THE DEFENDANT IS NOT IN
ARREARS IN PAYMENT IN AN AMOUNT EQUAL TO OR GREATER THAN ONE MONTH'S SUPPORT
OBLIGATION AND (1) THE COURT FINDS THAT THERE IS GOOD /CAUSE NOT TO REQUIRE
IMMEDIATE INCOME WITHHOLDING; OR (2) A WRITTEN AGREEMENT IS REACHED BETWEEN
THE PARTIES WHICH PROVIDES FOR AN ALTERNATE ARRANGEMENT.
UNPAID ARREARAGE BALANCES MAY BE REPORTED TO CREDIT AGENCIES. ON AND
AFTER THE DATE IT IS DUE, EACH UNPAID SUPPORT PAYMENT SHALL CONSTITUTE, BY
OPERATION OF LAW, A JUDGMENT AGAINST YOU, AS WELL AS A LIEN AGAINST REAL
PROPERTY.
IT IS FURTHER ORDERED that, upon payor's failure to comply with this order, payor may be
arrested and brought before the Court for a Contempt hearing; payor's wages, salary,
commissions, and/or income may be attached in accordance with law; this Order will be
increased without further hearing by o % a month until all arrearages are paid in full. Payor
is responsible for court costs and fees.
Copies delivered to parties . FEB Q 1 ZOO?
Date
Consented:
Plaintiff Plaintiff's Attorney
Defendant Defendant's Attorney
BY THE COURT:
NN -L
M. L. Ebert, Jr., Judge
DRO: R.J. Shadday Page 4 of 4 Form OE-518
Service Type M Worker ID 21005
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KAREN D. LUNDY, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - DIVORCE
NO. 06-3626 CIVIL TERM
CHADWICK C. LUNDY, IN DIVORCE
Defendant/Petitioner
PACSES Case Number: 952108394
ORDER OF COURT
AND NOW, this 10th day of July 2007, a petition has been filed against you, Karen D. Lundy, to
modify an existing Alimony Pendente Lite Order. You are ordered to appear in person at the Domestic
Relations Section, 13 North Hanover Street, Carlisle, Pennsylvania, on August 8. 2007 at 10:30 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 W2's as filed
(2) your pay stubs for the preceding six (6) months
(3) the Income and Expense Statement attached to this order, completed as required by the Rule
1910.11.
(4) verification of child care expenses
(5) proof of medical coverage which you may have, or may have available to you
IF you fail to appear for the conference or bring the required documents, the Court may issie a
warrant for your arrest.
BY THE COURT,
Edgar B. Bayley, President Judge
Copies mailed to: Petitioner
Respondent
Constance P. Brunt, Esq.
Andrew C. Sheely, Esq.
Date of Order: July 10, 2007
J. S dday Conference Officer l
IV-
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND
REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL
HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVE.
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
cc361
G?
KAREN D. LUNDY, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - DIVORCE
NO. 06-3626 CIVIL TERM
CHADWICK C. LUNDY, IN DIVORCE
Defendant/Petitioner
PACSES Case Number : 952108394
ORDER OF COURT
AND NOW, this 8th day of August, 2007, based upon the Court's determination that
Petitioner's monthly net income/earning capacity is $2,141.08 and Respondent's monthly net
income/earning capacity is $5,599.77, it is hereby ordered that the Respondent pay to the
Pennsylvania State Collection and Disbursement Unit Six Hundred Eighteen and 00/100 Dollars
($618.00) per month payable as follows: $618.00 per month for Alimony Pendente Lite and $0.00 per
month on arrears. First payment due: next modified wage attached payment. The effective date of
the order is July 10, 2007.
Arrears set at $230.79 as of August 8, 2007.
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, at its discretion, make an appropriate Order,
including, but not limited to, commitment of the Respondent to prison for a period not to exceed six
months.
Said money to be turned over by the PA SCDU to: Karen D. Lundy. Payments must be made
by check or money order. All checks and money orders must be made payable to PA SCDU and
mailed to:
PA SCDU
P.O. Box 69110
Harrisburg, PA 17106-9110
Payments must include the Respondent's PACSES Member Number or Social Security
Number in order to be processed. Do not send cash by mail.
cc360
This Order considers that the Plaintiff is maintaining the medical insurance on the Defendant
and that the Defendant has a child support obligation of $1400.00 per month under PACSES Case #
159108374 and docketed at 00519 S 2006.
This Order shall become final twenty (20) after the mailing of the notice of the entry of the
Order to the parties unless either party files a written demand with the Prothonotary for a hearing de
novo before the Court.
Consented:
Petitioner
Respondent
Petitioner's Attorney
Respondent's Attorney
BY THE COURT,
M. L. Ebert, Jr., J.
Mailed copies on: August 9, 2007
to: Petitioner
Respondent
Constance P. Brunt, Esq.
Andrew C. Sheely, Esq.
DRO: R.J. Shadday
_N
Ca 0
?
C° "T1
C-n
t -,
952108394
06-3626 CIVIL
1% ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State commonwealth of Pennsylvania 159108374
Co./City/Dist. of CUMBERLAND 519 S 2006
Date of Order/Notice 08/08/07
Case Number (See Addendum for case summary)
Employer/Withholder's Federal EIN Number
S P AUTO PARTS INC
201 EXECUTIVE DR
MOORESTOWN NJ 08057-4221
369-90-9887
Employee/Obligor's Social Security Number
0806101684
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 2, 018.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Dyes ® no
$ 0.00 per month in current and past-due medical support
$ 0. 00 per month for genetic test costs
$ 0.00 per month in other (specify)
for a total of $ 2, 018.00 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:
$ 465.69 per weekly pay period.
$ 931.38 per biweekly pay period (every two weeks).
$ 1, oo9. o0 per semimonthly pay period (twice a month).
$ 2. 018. oo per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on page 2).
If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call
Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580
for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
Date of Order: AUG 9, 2007
DRO: R.J. Shadday
Service Type m
O Original Order/Notice
O Amended Order/Notice
O Terminate Order/Notice
RE: LUNDY, CHADWICK C .
Employee/Obligor's Name (Last, First, MI)
BY THE COURT:
N
M. L. Ebert, Jr., J e
Form EN-028 Rev. 1
\A/nrl-ar in IATT
OMB No.: 0970-0154
t ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
? Ifghecked you are required, to provide gopy of this form to your mployee. If your employee works in a state that is
di Brent from the state that issued this o er, a copy must be provi ed to your employee even if the box is not checked.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employee/obligor.
paydatefdate ol withholldirigis-the date on which amount was with re d froin the employees . You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 5214512040
EMPLOYEE'S/OBLIGOR'S NAME: LUNDY, CHADWICK C.
EMPLOYEE'S CASE IDENTIFIER: 0806101684 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 employeelobligor from employment,
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act 0 5 U.S.C. § 1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more
than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more
than the amounts allowed under the law of the state that issued the order.
10. Additional Info:
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
I I-Submitted By: If you or your employee/obligor have any questions,
DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT
13 N. HANOVER ST by telephone at (717) 240-6225 or
P.O. BOX 320 by FAX at (717) 240-6248 or
CARLISLE PA 17013 by internet www.childsupport.state.pa.us
Service Type M
Page 2 of 2
Form EN-028 Rev. 1
Worker ID $IATT
OMB No.: 0970-0154
` ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: LUNDY, CHADWICK C.
PACKS Case Number 159108374
Plaintiff Name
KAREN D. LUNDY
Docket Attachment Amount
00519 S 2006 $ 1,400.00
Child(ren)'s Name(s): DOB
JAMES R. LUNDY _0.5/08/96
RAITiYN M. <LUNDY x!/22/9.5
? 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 952108394
Plaintiff Name
KAREN D. LUNDY
Docket Attachment Amount
06-3626 CIVIL$ 618.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACKS Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren) ? if checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available identified h above any insurance overage available
through the employee's/obligor's employment. through employee's/obligor's ptoy
Addendum Form EN-028 Rev. 1
Service Type M OMB No.: 0970-0154 Worker ID $IATT
Cam.. ? '"cl
rill i7l
Constance P. Brunt, Esquire
Supreme Court ID #29933
Beaufort Professional Center
1820 Linglestown Road
Harrisburg, PA 17110
(717) 232-7200
FAX (717) 232-0255
cpbrunt(&CPBru ntLaw.com
Attorney for Plaintiff
KAREN D. LUNDY, IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
: CIVIL ACTION -LAW
V.
CHADWICK CLAY-ALLEN LUNDY,
: NO. 06-3626 CIVIL TERM
Defendant : IN DIVORCE
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 Office of the Prothonotary at Cumberland County Courthouse, One Courthouse
Square, Carlisle, PA 17013-3387.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
Constance P. Brunt, Esquire
Supreme Court ID #29933
Beaufort Professional Center
1820 Linglestown Road
Harrisburg, PA 17110
(717) 232-7200
FAX (717) 232-0255
cpbru ntPCPBru ntLaw.com
Attorney for Plaintiff
KAREN D. LUNDY,
Plaintiff
V.
CHADWICK CLAY-ALLEN LUNDY,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 06-3626 CIVIL TERM
IN DIVORCE
AMENDED COMPLAINT IN DIVORCE
AND NOW, comes the above-named Plaintiff, KAREN D. LUNDY, by and
through her attorney, CONSTANCE P. BRUNT, ESQUIRE, and seeks to obtain a
Decree in Divorce from the above-named Defendant, CHADWICK CLAY-ALLEN
LUNDY, upon the grounds hereinafter set forth.
COUNTI
DIVORCE
1. Plaintiff is KAREN D. LUNDY, an adult individual, who currently resides at
5 Shady Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050.
2. Defendant is CHADWICK CLAY-ALLEN LUNDY, an adult individual, who
currently resides at 176 State Road, Mechanicsburg, Cumberland County,
Pennsylvania 17050.
3. Plaintiff and Defendant have been bona fide residents in the
Commonwealth of Pennsylvania for at least six (6) months immediately previous to the
filing of this Complaint.
4. The Plaintiff and Defendant were married on July 1, 1989, in
Mechanicsburg, 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 the United States of
America.
7. The Defendant is not a member of the Armed Services of the United
States or any of its allies.
8. The Plaintiff has been advised of the availability of marriage counseling
and understands that she may request that the Court require the parties to participate in
counseling.
9. The Plaintiff avers that the grounds on which the action is based are that
-2-
the marriage is irretrievably broken.
10. Plaintiff requests the Court to enter a Decree in Divorce.
COUNT II
REQUEST FOR EQUITABLE DISTRIBUTION OF MARITAL
PROPERTY UNDER SECTION 3502(a) OF THE DIVORCE CODE
11. Paragraphs 1 through 7 inclusive of Count I are specifically incorporated
by reference as though fully set forth hereinafter.
12. Plaintiff and Defendant have individually or jointly acquired real and
personal property during the marriage, in which they individually or jointly have a legal
or equitable interest, which marital property is subject to equitable distribution.
13. Plaintiff requests the Court to determine and equitably distribute, divide or
assign said marital property, pursuant to Section 3502 of the Divorce Code.
COUNT III
REQUEST FOR ALIMONY PENDENTE LITE, COUNSEL FEES.
COSTS AND EXPENSES UNDER SECTION 3702 OF THE DIVORCE CODE
14. Paragraphs 1 through 7 inclusive of Count I are specifically incorporated
by reference as though fully set forth hereinafter.
15. Plaintiff is without sufficient assets and income to support herself and pay
-3-
her attorney's fees and the costs and expenses of this action.
16. Defendant has sufficient earning capacity to support the Plaintiff and to
pay the Plaintiffs attorney's fees and the costs and expenses of this action.
17. Plaintiff requests the Court to order the Defendant to support the Plaintiff
during the pendency of this action and to pay Plaintiffs counsel fees, expenses and the
costs of this action, pursuant to Section 3702 of the Divorce Code.
COUNT IV
REQUEST FOR ALIMONY UNDER
SECTION 3701 OF THE DIVORCE CODE
18. Paragraphs 1 through 7 inclusive of Count I are specifically incorporated
by reference as though fully set forth hereinafter.
19. Plaintiff lacks sufficient property to provide for her reasonable needs.
20. Plaintiff is unable to sufficiently support herself through appropriate
employment.
21. Defendant has sufficient property, assets, and income to provide
continuing support for the Plaintiff.
22. Plaintiff requests the Court to order the Defendant to pay alimony to
Plaintiff pursuant to Section 3701 of the Divorce Code.
-4-
WHEREFORE, Plaintiff prays that your Honorable Court enter a Decree in
Divorce as follows:
(a.) dissolving the marriage between the parties;
(b.) equitably distributing, dividing or assigning the marital property of
the parties;
(c.) ordering Defendant to pay alimony pendente lite, counsel fees,
expenses and costs of this action to Plaintiff;
(d.) ordering Defendant to pay alimony to Plaintiff; and
(e.) granting such other further relief as the Court deems appropriate.
Respectfully submitted,
CONSTANCE P. BRUNT, ESQUIRE
Supreme Court I.D. No. 29933
Beaufort Professional Center
1820 Linglestown Road
Harrisburg, PA 17110-3339
(717) 232-7200
FAX (717) 232-0255
cpbrunt _CPBruntLaw.com
Attorney for Plaintiff
-5-
VERIFICATION
I verify that the statements made in the foregoing Amended Complaint In Divorce
are true and correct. I understand that false statements herein are made subject to the
penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities.
DATED: (2117X-,r
KAREN D. LUNDY, aintiff
CERTIFICATE OF SERVICE
7f?
1, CONSTANCE P. BRUNT, ESQUIRE, do hereby certify that on the
day of , 2007, 1 served a true and correct copy of the foregoing
Amended Complaint In Divorce by depositing same in the United States Mail, first-class
postage prepaid, at Harrisburg, Pennsylvania, addressed as follows:
Andrew C. Sheely, Esquire
127 South Market Street
P. O. Box 95
Mechanicsburg, PA 17055
Attorney for Defendant
J=M?'
CONSTANCE P. BRUNT, ESQUIRE
Supreme Court ID # 29933
Beaufort Professional Center
1820 Linglestown Road
Harrisburg, PA 17110-3339
(717) 232-7200
FAX (717) 232-0255
cp b ru nt(&-C P B ru ntLaw. co m
Attorney for Plaintiff
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
KAREN D. LUNDY ) Docket Number 06-3626 CIVIL
Plaintiff )
VS. ) PACSES Case Number 9 5 210 8 3 9 4
CHADWICK C. LUNDY )
Defendant ) Other State ID Number
PETITION FOR MODIFICATION
OF AN EXISTING SUPPORT ORDER
1. The petition of CHADWICK C. LUNDY respectfully
represents that on AUGUST 8, 2007 , an Order of Court was entered for
KAREN D. LUNDY
A true and correct copy of the order is attached to this petition.
Form OM-501
Service Type M Worker ID 21503
0 P-3
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LUNDY v- LUNDY PACSES Case Number: 952108394
2. Petitioner is entitled to 0 increase decrease 0 termination 0 reinstatement
0 other of this Order because of the following material and substantial change(s) in
circumstance:
Lo? H-c T ), ) C -T-,?) Pd6Y?--
WHEREFORE, Petitioner requests that the Court the existing order
Petitioner Attorney for Petitioner
I verify that the statements made in this complaint are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to
unworn falsification to authorities.
RAX-C-f A 7 2?s
Date
-Cl/c
Petitioner
Page 2 of 2 Form OM-501
Service Type M Worker ID 21503
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KAREN D. LUNDY, THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - DIVORCE
NO. 06-3626 CIVIL TERM
CHADWICK C. LUNDY, IN DIVORCE
Defendant/Petitioner :
PACSES CASE NO: 952108394
ORDER OF COURT
AND NOW, this 10th day of March, 2008, a petition has been filed against you, Karen D. Lundy, to modify
an existing Alimony Pendente Lite Order. You are ordered to appear in person at the Domestic Relations Section,
13 North Hanover Street, Carlisle, Pennsylvania, on March 31, 2008 at 10:30 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 THE COURT,
Edgar B. Bayley, President Judge
Copies mailed to: Petitioner
Respondent
Constance P. Brunt, Esq.
Andrew C. Sheely, Esq.
Date of Order: March 10, 2008
J. Sh ay, Conference Officer
%14
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT
YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVE.
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
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KAREN D. LUNDY, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - DIVORCE
NO. 06-3626 CIVIL TERM
CHADWICK C. LUNDY, IN DIVORCE
Defendant/Petitioner
PACSES Case No: 952108394
ORDER OF COURT
AND NOW to wit, this 31 st day of March 2008, it is hereby Ordered that the
Defendant's Petition for Modification of the Alimony Pendente Lite is dismissed and the Order of
August 8, 2007 remains in its entirety until the final Decree of Divorce.
This Order shall become final twenty (20) days after the mailing of the notice of
the entry of the order to the parties unless either party files a written demand with the Domestic
Relations Section for a hearing de novo before the Court.
BY THE COURT:
- N I
M. L. Ebert, Jr., J.
DRO: R.J. Shadday
xc: Petitioner
Respondent
Constance P. Brunt, Esq.
Andrew C. Sheely, Esq.
Form OE-001
Service Type: M Worker: 21005
x fir
,
ca -
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsylvania 159108374
Co./City/Dist. of CUMBERLAND 519 S 2006
Date of Order/Notice 03/31/08
Case Number (See Addendum for case summary)
Employer/Withholder's Federal EIN Number
S P AUTO PARTS INC
201 EXECUTIVE DR
MOORESTOWN NJ 08057-4221
369-90-9887
Employee/Obligor's Social Security Number
0806101684
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 1, 965.00 per month in current support
$ o. oo per month in past-due support Arrears 12 weeks or greater? Dyes ® no
$ 0.00 per month in current and past-due medical support
$ o . 00 per month for genetic test costs
$ 0.00 per month in other (specify)
for a total of $ 1, 965.00 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:
$ 453.46per weekly pay period.
$ 906.92 per biweekly pay period (every two weeks).
$ 982.50 per semimonthly pay period (twice a month).
$ 1. 965. oo per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on page 2).
If required by Pennsylvania law (23 PA C.S. S 4374(b)) to remit by electronic payment method, please call
Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580
for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
Date of order: APR 0 1 2008
DRO: R.J. SHADDAY
Service Type M
06-3626 CIVIL
O Original Order/Notice
O Amended Order/Notice
O Terminate Order/Notice
RE: LUNDY, CHADWICK C.
Employee/Obligor's Name (Last, First, MI)
BY THE COURT:
N -L
M.L. EBERT, JR., JUDGE
Form EN-028 Rev. 1
OMB No.: 0970-0154
Worker I D $ IATT
1,965 00 x
12.1
4 5 3 46*
1,9 6 5 • x
12-+
26•
906.92*
s
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
? Age' ecke? you are required, to provide a opy of this form to your m loyee. If your employee yorks in a state that is
erent from the state that issued this order, a copy must be provic?edpto your employee even if the box is not checked.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employeelobligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employee/obligor.
3.* Reporting the Paydate/Date of Withholding: You must report the paydate/date of withholding when sending the payment. The
paydate/date of withholding is the date on which amount was withheld from the employee's wages. You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employeelobligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 5214512040
EMPLOYEE'S/OBLIGOR'S NAME: LUNDY, CHADWICK C.
EMPLOYEE'S CASE IDENTIFIER: 0806101684 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employeelobligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Antidiscrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment,
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9.* Withholding Limits: You may not withhold more than the lesser of. 1) the amounts allowed by the Federal Consumer Credit
Protection Act 0 5 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more
than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more
than the amounts allowed under the law of the state that issued the order.
10. Additional Info:
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
11 -Submitted By:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employeelobligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717) 240-6248 or
by internet www.childsupport.state.pa.us
Page 2 of 2
Service Type M
OMB No.: 0970-0154
Form EN-028 Rev. 1
Worker ID $IATT
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: LUNDY, CHADWICK C.
PACSES Case Number 159108374
Plaintiff Name
KAREN D. LUNDY
Docket Attachment Amount
00519 S 2006 $ 1,347.00
Child(ren)'s Name(s): DOB
JAMES R..,LUNDY. „05./08/96,
K&? Y-**N M.` LUNDY 0 7:22 9$
PACSES Case Number 952108394
Plaintiff Name
KAREN D. LUNDY
Docket Attachment Amount
06-3626 CIVIL$ 618.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
? If checked, you are required to enroll the child(ren) ? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available identified above in any health insurance coverage available
through the employee's/obligor's employment. through the employee's/obligor's employment.
Addendum Form EN-028 Rev. 1
Service Type M Worker ID $IATT
OMB No.: 0970-0154
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Constance P. Brunt, Esquire
Supreme Court ID #29933
Beaufort Professional Center
1820 Linglestown Road
Harrisburg, PA 17110
(717) 232-7200
FAX (717) 232-0255
cabru nt(&-CPBruntLaw.com
Attorney for Plaintiff
KAREN D. LUNDY, : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
CIVIL ACTION -LAW
V.
NO. 06-3626 CIVIL TERM
CHADWICK CLAY-ALLEN LUNDY,
Defendant IN DIVORCE
MARITAL SETTLEMENT AGREEMENT
Lundy Marital Settlement Final Draft
MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT, made this day of 2007, by and
between KAREN D. LUNDY, now of Mechanicsburg, Cumberland County, Pennsylvania,
hereinafter referred to as "Wife",
-AND-
CHADWICK CLAY-ALLEN LUNDY, now of Mechanicsburg, Cumberland County,
Pennsylvania, hereinafter referred to as "Husband",
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on July 1, 1989, in
Mechanicsburg, Pennsylvania, and there were two children born of the marriage: KAITLYN
LUNDY (DOB 2/22/95) and JAMES LUNDY (DOB 5/8/96); and
WHEREAS, diverse unhappy marital difficulties have arisen between the parties,
causing them to believe that their marriage is irretrievably broken, as a result of which the
parties intend to live separate and apart from one another hereafter, the parties being
estranged due to such marital difficulties with no reasonable expectation of reconciliation;
and the parties hereto are desirous of settling fully and finally their respective financial and
property rights and obligations as between each other, including, without limitation by
specification: the settling of all matters between them relating to the ownership of real and
personal property; the setting of all matters between them relating to the past, present, or
future support and/or maintenance of Wife by Husband or of Husband by Wife; and in
general, the settling of any and all claims and possible claims by one against the other or
against their respective estate, particularly those responsibilities and rights growing out of the
Lundy Marital Settlement Final Draft
marriage relationship; and
WHEREAS, both Husband and Wife have been fully, separately and independently
advised of their legal rights and obligations, and each covenants that he and she has each
made a full and complete disclosure to the other of his or her respective property, holdings
and income; and
The provisions of this Agreement and their legal effect have been fully
explained to the parties by their respective counsel. The Wife has employed and had the
benefit of counsel of CONSTANCE P. BRUNT, ESQUIRE, as her attorney. The Husband
has employed and had the benefit of counsel of ANDREW C. SHEELY, ESQUIRE, as his
attorney. Each party acknowledges that he or she has received independent legal advice
from counsel of his or her selection and that each fully understands the facts and has been
fully informed as to his or her legal rights and obligations. Each party acknowledges and
accepts that this Agreement is, under the circumstances, fair and equitable, and that it is
being entered into freely and voluntarily after having received such advice and with such
knowledge, and that execution of this Agreement is not the result of any duress or undue
influence and that it is not the result of any collusion or improper or illegal agreement or
agreements. In addition, each party hereto acknowledges that he or she has been fully
advised by his or her respective attorney of the impact of the Pennsylvania Divorce Code,
whereby the Court has the right and duty to determine all marital rights of the parties,
including divorce, alimony, alimony pendente lite, equitable distribution of all marital property
owned or possessed jointly or individually by either party, counsel fees and costs of litigation,
and, fully knowing the same and being fully advised of his or her rights thereunder, each
party hereto still desires to execute this Agreement, acknowledging that the terms and
conditions set forth herein are fair, just and equitable to each of the parties, and waives his
and her respective right to have the Court of Common Pleas of Cumberland County or any
other court of competent jurisdiction make any determination or order affecting the respective
parties' rights to a divorce, alimony, alimony pendente lite, equitable distribution of all marital
Lundy Marital Settlement Final Draft -2-
property, counsel fees and costs of litigation.
NOW, THEREFORE, in consideration of the premises and of the promises, covenants
and undertakings hereinafter set forth, and for other good and valuable consideration, the
receipt of which is hereby acknowledged by each of the parties hereto, Husband and Wife,
each intending to be legally bound hereby, covenant and agree as follows:
1. SEPARATION. It shall be lawful for Husband and Wife at all times hereafter
to live separate and apart from each other and to reside, from time to time, at such place or
places as they shall respectively deem fit, free from any control, restraint or interference,
direct or indirect, by each other. Neither party shall molest the other or compel or endeavor
to compel the other to cohabit or dwell with him/her by any legal or other proceedings.
2. SUBSEQUENT DIVORCE. The parties hereby agree that Wife has filed a
Complaint in Divorce in The Court Of Common Pleas of Cumberland County, Pennsylvania,
docketed to No. 06-3626 Civil Term claiming that the marriage is irretrievably broken under
the no-fault, mutual consent provision of Section 3301(c) of the Pennsylvania Divorce Code.
The parties hereby express their agreement that the marriage is irretrievably broken and
express their intent to execute any and all affidavits or other documents necessary for the
parties to obtain an absolute divorce pursuant to Section 3301(c) of the Divorce Code as
soon as practicable and permissible under the Divorce Code and the PA Rules of Civil
Procedure, which shall be delivered to Wife's counsel for filing. The parties hereby waive all
rights to request Court-ordered counseling under the Divorce Code. Neither party to such
action shall seek alimony, alimony pendente lite, or support or maintenance of any nature
contrary to the provisions of this Agreement. It is further specifically understood and agreed
by the parties that the provisions of this Agreement relating to equitable distribution of
property of the parties are accepted by each party as a final settlement for all purposes
whatsoever, as contemplated by the Pennsylvania Divorce Code.
Lundy Marital Settlement Final Draft -3-
Should a decree, judgment or order of separation or divorce be obtained by
either of the parties in this or any other state, country or jurisdiction, each of the parties
hereby consents and agrees that this Agreement and all of its covenants shall not be
affected in any way by any such separation or divorce; and that nothing in any such decree,
judgment, order or further modification or revision thereof shall alter, amend or vary any term
of this Agreement, whether or not either or both of the parties shall remarry, it being
understood by and between the parties hereto that this Agreement shall survive and shall not
be merged into any decree, judgment, or order of divorce or separation. Notwithstanding the
provisions of the Pennsylvania Divorce Code or of any law to the contrary, none of the terms
and provisions of this Agreement shall be subject to modification by the Court or in any
fashion other than as set forth hereinafter. It is specifically agreed, however, that this
Agreement shall be subject to enforcement under the provisions of the Pennsylvania Divorce
Code or, at the option at the aggrieved party, by a suit against the alleged breaching party
either in law or in equity.
3. EFFECTIVE DATE. The effective date of this Agreement shall be the "date
of execution" or "execution date", defined as the date upon which it is executed by the parties
if they have each executed the Agreement on the same date. Otherwise, the "date of
execution" or "execution date" of this Agreement shall be defined as the date of execution by
the party last executing this Agreement.
4. DEBTS AND OBLIGATIONS. Husband represents and warrants to Wife that
he has not, and in the future he will not, contract or incur any debt or liability for which Wife or
her estate might be responsible, and he shall indemnify and save Wife harmless from any
and all claims or demands made against her by reason of such debts or obligations incurred
by him since the date of said separation.
Wife represents and warrants to Husband that she has not, and in the future
she will not, contract or incur any debt or liability for which Husband or his estate might be
Lundy Marital Settlement Final Draft -4-
responsible, and she shall indemnify and save Husband harmless from any and all claims or
demands made against him by reason of such debts or obligations incurred by her since the
date of said separation.
Except as otherwise specifically set forth herein, each party shall be solely
responsible for any debts or liabilities incurred in his/her individual name at any time, and
shall indemnify and save the other party harmless from any and all claims or demands made
against him/her by reason of such debts or obligations.
5. MUTUAL RELEASES. Husband and Wife do hereby mutually remise,
release, quit-claim or forever discharge the other and the estate of such other, for all time to
come, and for all purposes whatsoever, from any and all rights, title and interest, or claims in
or against the estate of such other, of whatever nature and wherever situate, which he/she
now has or at any time hereafter may have against such other, the estate of such other or
any part thereof, whether arising out of any former acts, contracts, engagements or liabilities
of such other or by way of dower or curtesy; or claims in the nature of dower or curtesy, or
widow's or widower's rights, family exemption or similar allowance or under the intestate
laws; or the right to take against the spouse's will; or the right to treat a lifetime conveyance
by the other as testamentary; or all other rights of a surviving spouse to participate in a
deceased spouse's estate, whether arising under the laws of Pennsylvania, any state,
commonwealth or territory of the United States, or any other country; or any rights which
either party may now have or at any time hereafter have for past, present or future support or
maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether
arising as a result of the marital relation or otherwise, except, and only except, all rights and
agreements and obligations of whatsoever nature arising or which may arise under this
Agreement or for the breach of any provision hereof. It is the intention of Husband and Wife
to give to each other by the execution of this Agreement a full, complete and general release
with respect to any and all property of any kind or nature, real, personal or mixed, which the
other now owns or may hereafter acquire, except, and only except, all rights and agreements
and obligations of whatsoever nature arising or which may arise under this Agreement or for
Lundy Marital Settlement Final Draft -5-
the breach of any provision hereof.
6. DIVISION OF HOUSEHOLD AND PERSONAL PROPERTY. The parties
hereto mutually agree that they have effected a satisfactory division of the furniture,
household furnishings, appliances and other household personal property between them.
Each party shall retain as his/her sole and separate property all such items now in his/her
respective possession, free from any claim by the other party. Should it become necessary,
the parties each agree to sign upon request any titles or documents necessary to give effect
to this paragraph. Wife relinquishes any ownership interest or claim she may have for
equitable distribution of the guns currently being held by the Sheriff of Cumberland County
pursuant to a Protection From Abuse Order entered on June 14, 2006, docketed to No. 06-
3230.
7. MARITAL RESIDENCE. The parties were formerly the joint owners of a
marital residence at 815 Appletree Lane, Mechanicsburg, Cumberland County,
Pennsylvania, which was sold on March 29, 2007. The parties acknowledge that Husband
resided alone in the said residence following the separation on June 7, 2006, and that he
paid the expenses incident to the use and ownership of the said marital home from the date
of separation to the date of its sale. Husband hereby waives any claim against Wife related
to any such expenses and agrees to indemnify and hold Wife harmless from any such
liabilities, obligations or expenses or any claims or demands as a result thereof. The parties
further acknowledge that they each received an advance distribution of $5,000.00 from the
net sale proceeds at settlement. The balance of the proceeds have been held in an escrow
account with Wachovia Bank by their counsel, which account had a balance of $25,580.23
as of October 31, 2007. The parties agree that Husband shall receive the sum of $12,000.00
from the Wachovia escrow account as his separate property, with the balance of the said
account being distributed to Wife as her separate property.
Lundy Marital Settlement Final Draft -6-
8. DISTRIBUTION OF CASH ASSETS Wife shall retain all funds as were on
deposit in the Postmark Credit Union checking and savings accounts and Members 1' Credit
Union checking and savings accounts in her name as of the date of separation.
Husband shall retain all funds as were on deposit in Postmark Credit Union
checking and savings accounts and the Americhoice Federal Credit Union account in his
name as of the date of separation.
Each party shall also retain as his/her sole and separate property, free and
clear of any claim on the part of the other, any bank or depository account or cash assets of
any nature, now his/her respective individual name.
9. VEHICLES. Wife shall retain possession and ownership of the 2006 Subaru
Forester as her sole and separate property, free and clear of any claim, right, title or interest
by Husband. Wife shall be solely responsible for the payment any outstanding balance due
on the car loan encumbering the said vehicle.
Husband shall retain possession of the leased 2006 Ford 150 truck, free and
clear of any claim, right, title or interest by Wife. The lease for this vehicle is in Husband's
name alone, and he shall be solely responsible for making all payments due and for
complying with all other lease terms.
The parties shall promptly cooperate in the execution and delivery of any titles
or other documents necessary to effectuate any required transfer of title or registration
consistent with this provision. The parties shall be solely responsible for maintaining
appropriate insurance on the vehicles assigned to them herein.
10. LIFE INSURANCE. Subject to the restrictions set forth below, the parties
shall each retain as his/her separate property any policies of life insurance of which he/she is
now the owner. Each party shall maintain a minimum of $100,000.00 in life insurance on
his/her life in full force and effect, paying all premiums due thereon, such insurance to remain
in effect until such time as the younger child of the parties graduates from college or reaches
Lundy Marital Settlement Final Draft -7-
the age of 23, whichever first occurs. Each party shall be prohibited from borrowing against,
signing, pledging or otherwise encumbering the insurance, or surrendering it to obtain its
cash value.
Within 30 days following the execution of this Agreement, each party shall duly
execute a valid Will creating a Testamentary Trust providing for two separate trusts for the
benefit of the minor children of the parties. The parties shall continuously maintain a valid
will including the said Trust provision until such time as the younger child of the parties
graduates from college or reaches the age of 23, whichever first occurs. The Trust shall
provide for the Trustee's discretionary distribution of principal and income for the health,
support, maintenance and education of the children, including college and post-graduate
education, with the balance of each child's separate trust being distributed in full to him/her at
such time as he/she graduates from college or reaches the age of 23, whichever first occurs.
Wife shall designate her sister, TRACY STUM, as Trustee, and her friend, LORRIE PERRY,
as the Alternate Trustee. Husband shall designate his sister, DAWN HESSELL as Trustee,
with his brother, JASON MURAR, being named as the Alternate Trustee. Each party shall
promptly designate the aforesaid Testamentary Trust as the sole primary beneficiary of the
$100,000.00 in life insurance described above and shall continuously maintain such
beneficiary designation for as long as he/she is required to maintain the said insurance.
Each party shall, within 30 days of the execution of this Agreement and thereafter upon
request made no more frequently than semi-annually, provide the other party with
satisfactory proof of the continued maintenance of the appropriate insurance and the
required beneficiary designation and with a copy of his/her current Will evidencing the
aforesaid Testamentary Trust.
11. DISTRIBUTION OF RETIREMENT ASSETS AND ACCOUNTS. The parties
shall each retain as his/her sole and separate property any pensions, 401(k) accounts,
Individual Retirement Accounts, employee stock ownership accounts, deferred compensation
accounts or other qualified or non-qualified plans or retirement accounts of any nature in
Lundy Marital Settlement Final Draft -8-
his/her respective name. Each party waives any interest in any such plans or accounts now
held or hereafter acquired by the other. Specifically, without limitation by reference, Husband
shall retain his Merrill Lynch Individual Retirement Account, and Wife shall retain her Fidelity
401(k), both accumulated during the course of the marriage. Contemporaneously with the
execution of this Agreement or promptly upon subsequent request, the parties shall execute
any additional waivers or other documents that may be required by the other party's plan
administrators to effectuate the provisions of this paragraph and to waive any claims he/she
may now or hereafter have in the other party's said retirement assets.
12. CHILDREN'S COLLEGE ACCOUNTS The parties acknowledge that during
the course of their marriage, they accumulated two college savings plan accounts with Merrill
Lynch, one in the name of KAITLYN and one in the name of JAMES. Husband is currently
designated as the Custodian for both of these accounts. The parties agree that they shall
take all necessary steps to transfer control of these accounts to Wife as Custodian. These
accounts shall be maintained for the payment of college or other post-high school
educational expenses for the named child, with any funds remaining in the account to be
distributed to the child at such time as he/she reaches the age of 21.
13. PET OWNERSHIP. Wife shall retain ownership and possession of the three
family dogs, provided that she agrees to return to Husband any dog which she decides at
any time that she is unable to keep. Husband shall promptly execute any necessary
documents to transfer ownership and registration of the dogs to Wife.
14. ALIMONY PENDENTE LITE. The parties acknowledge that Wife is
receiving alimony pendente lite from Husband in the amount of $618 per month pursuant to
an Order Of Court entered by the Court of Common Pleas of Cumberland County on August
8, 2007, docketed to No. 06-3626 CIVIL TERM. Husband's obligation for payment of
alimony pendente lite will terminate effective as of the date of the entry of a final decree in
Lundy Marital Settlement Final Draft -9-
divorce, but any outstanding arrears as of that date shall be payable at the rate of $618 per
month until paid in full.
15. TAXES. By this Agreement, the parties have intended to effectuate and by
this Agreement have equally divided their marital property. The parties have determined that
such division conforms to a right and just standard with regard to the rights of each party.
The division of existing marital property is not, except as may be otherwise expressly
provided herein, intended by the parties to constitute in any way a sale or exchange of
assets, and the division is being effected without the introduction of outside funds or other
property not constituting a part of the marital estate. As a part of the equal division of the
marital property and the marital settlement herein contained, the parties agree to save and
hold each other harmless from all income taxes assessed against the other resulting from the
division of the property as herein provided.
The parties acknowledge that they have filed various joint income tax returns
during the course of their marriage. In filing each such return, each party has relied
exclusively upon the other party to provide truthful and accurate information relating to the
other party's employment income, business income or deductions, or income from any other
source. In the event that any additional taxes, penalties or interest are assessed as a result
of any such joint return, the party responsible for under-reporting income or claiming any
improper deduction shall be solely responsible for payment of and shall indemnify and save
the other party harmless from such tax liability, penalties, interest, attorney's fees or
accountant's fees.
16. ADDITIONAL INSTRUMENTS. Each of the parties shall, from time to time at
the request of the other, execute, acknowledge and deliver to the other party any and all
further instruments or documents as may be reasonably required to give full force and effect
to the provisions of this Agreement.
17. MODIFICATION AND WAIVER A modification or waiver of any of the
Lundy Marital Settlement Final Draft -10-
provisions of this Agreement shall be effective only if made in writing and executed with the
same formality as this Agreement. The failure of either party to insist upon the strict
performance of any of the provisions of this Agreement shall not be construed as a waiver of
any subsequent default of the same or similar nature.
18. ENTIRE AGREEMENT. This Agreement contains the entire, complete and
exclusive understanding of the parties, and there are no representations, warranties,
covenants or undertakings other than those expressly set forth herein.
19. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for
convenience only. They shall have no effect whatsoever in determining the rights or
obligations of the parties.
20. INDEPENDENT SEPARATE COVENANTS. It is specifically understood and
agreed by and between the parties hereto that each paragraph hereof shall be deemed to be
a separate and independent agreement.
21. BREACH. If either party breaches any provision of this Agreement, the other
party shall have the right, at his/her election, to sue for damages for such breach or to seek
such other remedies or relief as may be available to him/her, and the party breaching this
contract shall be responsible for payment of reasonable legal fees and costs incurred by the
other in enforcing his/her rights under this Agreement, or in seeking such other remedies or
relief as may be available to him/her, regardless of whether the issues relating to the breach
are resolved by settlement or by determination of the court. In the event of an alleged
breach of any term of this Agreement, the aggrieved party shall provide written notice to the
breaching party and his/her counsel of his/her intent to take action to enforce his/her rights
under the Agreement and to remedy such breach. The breaching party shall have a period
of 15 days from the mailing of such notice to cure the alleged breach prior to the institution of
Lundy Marital Settlement Final Draft -11-
any proceedings of any nature for enforcement of this Agreement.
22. APPLICABLE LAW. This Agreement shall be construed under the laws of
the Commonwealth of Pennsylvania.
23. VOID CLAUSES. If any term, condition, clause or provision of this
Agreement shall be determined or declared to be void or invalid in law or otherwise, then only
that term, condition, clause or provision shall be stricken from this Agreement, and in all
other respects this Agreement shall be valid and continue in full force, effect and operation.
24. AGREEMENT BINDING ON HEIRS. This Agreement shall be binding on and
shall inure to the benefit of the parties hereto and their respective heirs, executors,
administrators, successors and assigns.
IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day
and year first above written.
WITNESS:
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KAREN D. LUNDY "J F
(SEAL)
CHADWICK CLAY-ALLEN LUN Y
Lundy Marital Settlement Final Draft -12-
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
. SS.
On this day of , 2007, before me, the undersigned
officer, personally appeared KAREN D. LUNDY, known to me (or satisfactorily proven) to be
the person whose name is subscribed to the within Agreement, and acknowledged that she
executed the same for the purposes therein contained.
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Constar- P. Brunt, Notary Public
Susquehanna Twp., Dauphin County
My Commission Expires Oct. 20, 2009
Notary Public
COMMONWEALTH OF PENNSYLVANIA
. SS.
COUNTY OF Cvn????G?4N?
On this
day of ?DeCe(n'1be.t?__ , 2007, before me, the undersigned
officer, personally appeared CHADWICK CLAY-ALLEN LUNDY, known to me (or
satisfactorily proven) to be the person whose name is subscribed to the within Agreement,
and acknowledged that he executed the same for the purposes therein contained.
R&'ej_? M, buLll'
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An,:rew C. Sheely, Esquire
127 S. Market Street
P.O. Box 95
Mechanicsburg, PA 17055
PA ID NO. 62469
717-697-7050 (Phone)
717-697-7065 (Fax)
KAREN D. LUNDY,
Plaintiff
VS.
CHADWICK CLAY-ALLEN LUNDY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
06 - 3626 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the
Divorce Code was filed on June 26, 2006.
2. The marriage of Plaintiff and Defendant is
irretrievably broken and ninety (90) days have elapsed from the
date of filing 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 pena].-4-- , r f 10 "z..^.u.A. Section 4':04
relating to unsworn falsification to the authorities.
DATE :
CHADWICK CLAY-ALLEN LUNDY, Defendan
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Andrew C. Sheely, Esquire
1.27 S. Market Street
P.O. Box 95
Mechanicsburg, PA 17055
PA ID NO. 62469
717-697-7050 (Phone)
717-697-7065 (Fax)
KAREN D. LUNDY,
Plaintiff
VS.
CHADWICK CLAY-ALLEN LUNDY,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
06 - 3626 CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
§3301 (C) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of
divorce without notice.
2. I understand that I may lose rights. concerning
alimony, division of property, lawyer's fees or expenses if I do
not claim them before a divorce decree is granted.
3. I understand that I will not be divorced until a
divorce decree is entered by the Court and that a copy of the
decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this affidavit
are true and correct. I understand that false statements herein
are made subject to the penalties of 18 Pa.C.S.A. Section 4904
relating to unsworn falsification to the authorities.
DATE: CJ
CHADWICK CLAY-ALLEN LUNDY, Defendan
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Constance P. Brunt, Esquire
Supreme Court ID #29933
Beaufort Professional Center
1820 Linglestown Road
Harrisburg, PA 17110
(717) 232-7200
FAX (717) 232-0255
cpbrunt(&-CP B runtLaw.com
Attorney for Plaintiff
KAREN D. LUNDY,
Plaintiff
V.
CHADWICK CLAY-ALLEN LUNDY,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 06-3626 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
1. An Amended Complaint in Divorce under Section 3301(c) of the Divorce Code
was filed on December 28, 2007.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing and service of the Complaint.
3. 1 consent to the entry of a final Decree In Divorce after service of notice of
intention to request entry of the decree.
I verify that the statements made in this affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating
to unsworn falsification to authorities.
DATE: 1/w ? *O ¢_pf, D kttowc/
KAREN D. LUNDY, Plaintiff
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Constance P. Brunt, Esquire
Supreme Court ID #29933
Beaufort Professional Center
1820 Linglestown Road
Harrisburg, PA 17110
(717) 232-7200
FAX (717) 232-0255
cpbru nto_CPBru ntLaw.com
Attorney for Plaintiff
KAREN D. LUNDY, : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
: CIVIL ACTION -LAW
V.
CHADWICK CLAY-ALLEN LUNDY,
: NO. 06-3626 CIVIL TERM
Defendant : IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
§3301(C) AND §3301(D) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree In Divorce without notice.
2. 1 understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. 1 understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
verify that the statements made in this Affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating
to unsworn falsification to authorities.
DATE:
KAREN D. LUNDY, Plaintiff
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Constance P. Brunt, Esquire
Supreme Court ID #29933
Beaufort Professional Center
1820 Linglestown Road
Harrisburg, PA 17110
(717) 232-7200
FAX (717) 232-0255
cpbrunt(&-CPBruntLaw.com
Attorney for Plaintiff
KAREN D. LUNDY, : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
: CIVIL ACTION -LAW
V.
NO. 06-3626 CIVIL TERM
CHADWICK CLAY-ALLEN LUNDY,
Defendant IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the Court for entry of
a divorce decree:
1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the
Divorce Code.
2. Date and manner of service of the Complaint: By an Acceptance of Service by
Defendant's counsel, dated July 3, 2007 and filed on July 3, 2007. Amended Complaint
served by first class mail to Defendant's counsel of record on December 27, 2008.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the Affidavit of Consent required by Section 3301(c)
of the Divorce Code: By Plaintiff on March 28, 2008; by Defendant on March 26, 2008.
(b)(1) Date of execution of the Plaintiffs Affidavit required by Section 3301(d)
of the Divorce Code: Not applicable;
(2) Date of filing and service of the Plaintiffs Affidavit upon the Defendant:
Not applicable.
4. Related claims pending: None.
5. Complete either (a) or (b).
(a) Date and manner of service of the Notice Of Intention To File Praecipe To
Transmit Record, a copy of which is attached: Not applicable.
(b) Date Plaintiffs Waiver Of Notice was filed with the Prothonotary: April 2,
2008.
Date Defendant's Waiver Of Notice was filed with the Prothonotary: April
2, 2008.
Respectfully submitted,
DATE: q/t /ce
CONSTANCE P. BRUNT, ESQUIRE
Supreme Court ID # 29933
Beaufort Professional Center
1820 Linglestown Road
Harrisburg, PA 17110-3339
(717) 232-7200
FAX (717) 232-0255
cpbruntO-CPBruntLaw.com
Attorney for Plaintiff
tea
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
PLAINTIFF
N O. o6-3626 .TVT . TERM
VERSUS
CHADWICK CLAY-ALLEN LUNDY,
DEFENDANT
DECREE IN
DIVORCE
AND NOW, A ??•?` 2008 IT IS ORDERED AND
DECREED THAT KAREN D LUNDY , PLAINTIFF,
AN D CHADWICK CLAY-ALLEN LUNDY DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
NONE
BY THE COURT: UA
ATTEST: J
PROTHONOTARY
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KAREN D. LUNDY,
Plaintiff/Petitioner
vs.
CHADWICK C. LUNDY,
Defendant/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 06-3626 CIVIL TERM
IN DIVORCE
PACSES Case No: 952108394
ORDER OF COURT
AND NOW to wit, this 14th day of April 2008, it is hereby Ordered that the Alimony
Pendente Lite award is terminated, effective April 8, 2008, pursuant to Decree in Divorce
entered.
There is a credit in the amount of $244.99 on the APL account that will be directed to the
child support account under PACSES C#159108374.
BY THE COURT:
-N I U" ie
M. L. Ebert, Jr., \ 6 J.
DRO: R.J. Shadday
xc: Petitioner
Respondent
Constance P. Brunt, Esq.
Andrew C. Sheely, Esq.
Form OE-001
Service Type: M Worker: 21005
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06-3626 CIVIL
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsylvania 159108374
Co./City/Dist. of CUMBERLAND 519 S 2006
Date of Order/Notice 04/14/08
Case N u m ber (See Addendum for case summary)
Employer/Withholder's Federal EIN Number
S P AUTO PARTS INC
201 EXECUTIVE DR
MOORESTOWN NJ 08057-4221
369-90-9887
Employee/Obligor's Social Security Number
0806101684
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 1, 347.00 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 current and past-due medical support
$ 0.00 per month for genetic test costs
$ 0.00 per month in other (specify)
for a total of $ 1, 347.00 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:
$ 310.85 per weekly pay period.
$ 621.69.per biweekly pay period (every two weeks).
$ 673.50 per semimonthly pay period (twice a month).
$ 1, 347.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on page 2).
If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call
Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580
for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAMEAND 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: APR 15 42008
DRO: R.J. SHADDAY
N t LJ?? ?
M. L. EBERT, JR.,, JUDGE
Form EN-028 Rev. 1
O Original Order/Notice
O Amended Order/Notice
O Terminate Order/Notice
RE: LUNDY, CHADWICK C.
Employee/Obligor's Name (Last, First, MI)
Service Type M OMB No.: 0970-0154 Worker ID $IATT
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of - 3Com
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
? If hecke? you are required to provide a copy of this form to your, mployee. If yo r employee works in a state that is
diherent from the state that issued this order, a copy must be provi?ed to your employee even if the box is not cheCKed.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employee/obligor.
3.* Reporting the Paydate/Date of Withholding: You must report the paydate/date of withholding when sending the payment. The
paydate/date of withholding is the date on which amount was withheld from the employee's wages. You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employeelobligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 5214512040
EMPLOYEE'S/OBLIGOR'S NAME: LUNDY, CHADWICK C.
EMPLOYEE'S CASE IDENTIFIER: 0806101684 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Antidiscrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment,
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.S.C. §1673 01; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more
than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more
than the amounts allowed under the law of the state that issued the order.
10. Additional Info:
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
11. Submitted By: if you or your employee/obligor have any questions,
DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
by telephone at (717) 240-6225 or
by FAX at (717) 240-6248 or
by internet www.childsupport.state.pa.us
Page 2 of 2
Service Type M OMB No.: 0970-0154
Form EN-028 Rev. 1
Worker ID $IATT
. .
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: LUNDY, CHADWICK C.
PACSES Case Number 159108374
Plaintiff Name
KAREN D. LUNDY
Docket Attachment Amount
00519 S 2006 $ 1,347.00
Child(ren)'s Name(s): DOB
JAMES R. LUNDY 05/08/96
KAITLYN M. LUNDY 02/22/95
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PAGES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Addendum Form EN-028 Rev. 1
Service Type M OMB No.: 0970-0154 Worker ID $IATT
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