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HomeMy WebLinkAbout06-4331 LISA J. AIKEY, VS. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA KARL S. AIKEY, Defendant NO. o(o - J4221 CIVIL ACTION - LAW IN DIVORCE NOTICE cl U X-? 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 judgement 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 divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counselling. A list of marriage counselors is available at: The Office of the Prothonotary, Dauphin County Courthouse, Front and Market Streets, Harrisburg, Pennsylvania 17101. 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. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 800-990-9108 MEYERS, DESFOR, SALTZGWER 6 BOYLE 410 NORTH SECOND STREET • P.O. BOX 1082 • HARRISBURG, PA 17108 (717)236-9428 • FAX(717)236-2817 LISA J. AIKEY, VS. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA KARL S. AIKEY, Defendant NO. CIVIL ACTION - LAW IN DIVORCE NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomaro medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion do demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 800-990-9108 MEYERS, DESFOR, SALTZGIYER& BOYLE 410 NORTH SECOND STREET • P.O. BOX 1082 • HARRISBURG, PA 17108 (717)236-9428 • FAX (717) 238-2817 LISA J. AIKEY, V3. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA KARL S. AIKEY, Defendant NO. ol,--Q33/ CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE (24 u Z- 7? AND NOW, comes the Plaintiff, Lisa J. Aikey, by and through her attorneys, Meyers, Desfor, Saltzgiver & Boyle and files the following Complaint in Divorce and in support thereof avers as follows: 2. 4. 5. 6. Plaintiff is Lisa J. Aikey, an adult individual who currently resides at 1001 Rupley Road, Apartment 311, Camp Hill, Pennsylvania. Defendant is Karl S. Aikey, an adult individual who currently resides at 213 Edenderry Way, Enola, Pennsylvania. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. The Plaintiff and Defendant were married on August 4, 1984 in Troxelville, Pennsylvania. There have been no prior actions of divorce or annulment between the parties. The marriage is irretrievably broken. The Defendant is not a member of the United States Army or its allies. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request the court require the parties to participate in counseling, being so MEYERS, DESFOR, SALTZOIVER A BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX(717)236-2817 advised, Plaintiff waives that right. 9. Plaintiff requests the Court to enter a Decree of Divorce pursuant to Section 3301(D) of the Divorce Code. WHEREFORE, Plaintiff, Lisa J. Aikey respectfully requests this Honorable Court enter a Decree in Divorce pursuant to Section 3301(D) of the Divorce Code. COUNTS COUNTI EQUITABLE DISTRIBUTION 10. Paragraphs one through ten of the Complaint are incorporated by reference as if fully set forth herein. 11. During the marriage, Plaintiff and Defendant have acquired various items of marital property, both real and personal, which are subject to equitable distribution under the Divorce Code. 12. Plaintiff requests that this Honorable Court equitably distribute all marital property pursuant to the Divorce Code. WHEREFORE, Plaintiff, Lisa J. Aikey respectfully requests this Honorable Court equitably distribute all property, both real and personal, tangible and intangible, acquired by the parties during their marriage. MEYERS, DESFOR, SALTZGiVER & BOYLE 410 NORTH SECOND STREET • P.O.BOX1082 • HARRISBURG.PA17108 (717) 238-8428 • FAX(717)236-2817 COUNT II ALIMONY PENDENTE LITE, SUPPORT. COUNSEL FEES AND EXPENSES 13. Paragraphs one through thirteen of the Complaint are incorporated by reference as if fully set forth herein. 14. By reason of this action, Plaintiff will be put to considerable expense in the preparation of this case, in the employment of counsel, and the payment of costs. 15. Plaintiff is without sufficient funds to support herself and to meet the costs and expenses of this litigation, and unable to appropriately maintain herself during the pendency of this action. 16. Plaintiffs income is not sufficient to provide for her reasonable needs and pay her attorneys' fees and the costs of this litigation. 17. Defendant has adequate earnings to provide support and alimony pendente lite to the Plaintiff and to pay her counsel fees, costs and expenses. WHEREFORE, Plaintiff, Lisa J. Aikey respectfully requests this Honorable Court compel the Defendant to pay Plaintiff alimony pendente lite, support, counsel fees, costs and expenses of this action. COUNT III ALIMONY 18. Paragraphs one through eighteen of the Complaint are incorporated by reference as if fully set forth herein. 19. Plaintiff lacks sufficient property to provide for her reasonable needs. MEYERS, DESFOR, SALTZGIVER 6 BOYLE 410 NORTH SECOND STREET - P.O. BOX 1082 • HARRISBURG, PA 17108 (717) 238-9428 • FAX (717) 2384817 20. Plaintiff is unable to sufficiently support herself through appropriate employment. 21. Defendant has sufficient income and assets to provide continuing support and to pay alimony to the Plaintiff. WHEREFORE, Plaintiff, Lisa J. Aikey respectfully requests this Honorable Court compel Defendant to pay alimony to Plaintiff. Respectfully submitted, Attorney I.D. 61382 \ w Meyers, Desfor, Saltzgiver & Boyle 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717)236-9428 Attorney for Plaintiff MEYERS, DESFOR, SALTZOIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 - HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 VERIFICATION I, Lisa verify that the statements made in this Complaint in Divorce are true and correct to the of my knowledge, information and belief. I understand that f statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: r1-a.'7- Olv ?Ja. , (K ) Plaintiff ( ) Defendant MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 r Ea ? c c 1? ?p d r:. r? ? LISA J. AIKEY, VS. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-4331 KARL S. AIKEY, Defendant CIVIL ACTION - LAW IN DIVORCE PROOF OF SERVICE OF COMPLAINT IN DIVORCE MEYERS, DESFOR, SALTZGWER t BOYLE 410 NORTH SECOND STREET • P.O. BOX 1082 • HARRISBURG, PA 17108 (717) 238.8428 • FAX (777) 2384817 ?r . LISA J. AIKEY, VS. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA KARL S. AIKEY, Defendant NO. 06-4331 CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I hereby certify on this 7" day of August, 2006, that the foregoing copy of the Proof of Service of Complaint in Divorce was mailed, first-class, postage pre-paid to: Karl Aikey 213 Edenderry Way Enola, PA 17025 Attorney for Plaintiff MEYERS, DESFOR, SALTZGIVER i BOYLE 410 NORTH SECOND STREET - P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-8428 • FAX (717) 236-2817 c- 4 4.+ cii I TI t.f+ LISA J. AIKEY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 06-4331 KARL S. AIKEY, CIVIL ACTION -LAW Defendant : ALIMONY PENDENTE LITE PETITION FOR ALIMONY PENDENTE LITE, COUNSEL FEES, COSTS AND EXPENSES AND NOW, comes the Petitioner, Lisa J. Aikey, by and through her attorneys, Meyers, Desfor, Saltzgiver & Boyle, and files the following Petition for Alimony Pendente Lite, Counsel Fees and Expenses and in support thereof avers as follows: 1. Petitioner is Lisa J. Aikey, an adult individual who currently resides at 1001 Rupley Road, Apt. 311, Camp Hill, Pennsylvania. (hereinafter known as "Wife") 2. Respondent is Karl S. Aikey, an adult individual who currently resides at 213 Edenderry Way, Enola, Pennsylvania. (hereinafter known as "Husband") 13. The parties were married on August 4, 1984 in Troxelville, Pennsylvania. 14. A Complaint in Divorce was filed on July 31, 2006. 5. Said Complaint in Divorce contains a count requesting Alimony Pendente Lite, Support, Counsel Fees, Costs and Expenses. 6. Since the date of separation, Wife has received no money from Husband. 7. By reason of this action, Wife will be put to considerable expense in the preparation of her case, in the employment of counsel and the payment of costs and expenses. 8. Wife is without sufficient funds to support herself and to meet the costs and expenses of this litigation and is unable to appropriately maintain herself during the pendency of this MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 action. 9. Wife's income is not sufficient to provide for her reasonable needs and to pay attorney's fees and the costs of this litigation. 10. Husband has adequate earnings to provide support and alimony pendente lite for the Wife and to pay her counsel fees, costs and expenses. WHEREFORE, the Petitioner, Lisa J. Aikey respectfully requests this Honorable Court award her Alimony Pendente Lite. Respectfully submitted, Attorney I.D. 61382 P.O. Box 1062 Harrisburg, PA 17108 (717)236-9428 Attorney for Petitioner MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 Meyers, Desfor, Saltzgiver & Boyle 410 North Second Street y LISA J. AIKEY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 06-4331 KARL S. AIKEY, CIVIL ACTION -LAW Defendant : ALIMONY PENDENTE LITE CERTIFICATE OF SERVICE I hereby certify that on this day of SC'A , 2006, a copy of the attached Petition for Alimony Pendente Lite, Counsel Fees, Costs and Expenses was mailed, postage prepaid, to: Sandra L. Meilton, Esquire TUCKER ARENSBERG 111 N. Front Street Harrisburg, PA 17101 Laurie A.-'Saltzgiver,(E Attorney for Petitioner MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION 13 N. HANOVER ST., P.O. BOX 320, CARLISLE PA 17013 Phone: (717) 240-6225 Fax: (717) 240-6248 Lisa J. Aikey , Plaintiff : NO.0 6 f 4331 V. CIVIL ACTION - LAW IN DIVORCE Karl S. Aikey Defendant DRS ATTACHMENT FOR APL PROCEEDINGS PETITIONER'S INFORMATION: Name: Lisa Jane Aikey Address: 1001 Rupley Road, Apt. 311 City: Cam Hill State: PA SSN: 187-60-7873 DOB: 2/2/65 Physical Description: Ht. Wt. Eyes Email Address: Zip Code: 17 011 Telephone: Hair Race Employer: Crabtree Rohrbaughs & Associates Employer's Address: 401 East Winding Hill Road Mechanicsburg, PA 17055 Phone: 458-0266 Job Title/Position:Admin. Asst. Gross Pay: 3 5 , 0 0 0 / yrNet Pay: Petitioner's Attorney: Laurie A Saltzgiver, Esquire Petitioner's Attorney's Address: P.O. Box 1062, Harrisburg, PA 17108 Phone: (717) 236-9428 RESPONDENT'S INFORMATION: Name: Karl Swartz Aikey Address: 213 Edenderry Way City: Enola State: PA Zip Code: 17025 SSN: 19 5- 4 6- 412 0 DOB: 11 / 1/ 6 2 Telephone: Physical Description: Ht. Wt. Eyes Hair Race Email Address: Employer: Target Systems Employer's Address: Phone: Job Title/Position: Computer Gross Pay: 7 0 ? 0 0 0 Net Pay: Analyst Respondent's Attorney: Sandra L. Milton, Esquire Respondent's Attorney's Address: 111 N. Front Street Harrisburg, PA 17101 Phone: 234-4121 Medical Insurance Carrier: Medical Insurance Carrier Address: Phone: Policy Number: MARRIAGE INFORMATION: Group Number: Date Married: 8 / 4 / 8 4 Date of Separation: Place of Marriage: Troxelville,, PA Address of last Marital Domicile : 213 Edenderry Way Enola, PA 17025 Description of Document Raising APL Claim: Petition for APL, Counsel Fees, Costs F Date APL Document Filed**: Expenses **Please note: A copy of the filed document MUST be enclosed with this form.** o cn ? ? !yam ?\ C LISA J. AIKEY, THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 06-4331 CIVIL TERM KARL S. AIKEY, IN DIVORCE Defendant/Respondent . PACSES CASE NO: 311108642 ORDER OF COURT AND NOW, this 26th day of September, 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 Charles C. Carothers, IV on October 3. 2006 at 10:30 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© (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. "This matter will be heard in conjunction with the Support matter already scheduled." BY THE COURT, Edgar B. Bayley, President Judge Copies mailed to: Petitioner Respondent Laurie A. Saltzgiver, Esq. Sandra L. Meilton, Esq. Date of Order: September 26, 2006 &N. She day, nference Officer YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND ' :• REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 cc361 C CID ? loft t,. ` . 1-?„I T-- 3 3 C LISA J. AIKEY, THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 06-4331 CIVIL TERM KARL S. AIKEY, IN DIVORCE Defendant/Respondent . PACSES CASE NO: 311108642 ORDER OF COURT - RESCHEDULE A CONFERENCE AND NOW, this 29th day of September, 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 October 31, 2006 at 10:30 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© (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 Laurie A. Saltzgiver, Esq. Sandra L. Meilton, Esq. Date of Order: September 29, 2006 1adtd--ay7,Conference Officer J. // Officer YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND " ` REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 cc361 `y LISA J. AIKEY, Plaintiff/Petitioner VS. KARL S. AIKEY, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 064331 CIVIL TERM IN DIVORCE PACSES # 311108642 ORDER OF COURT AND NOW, this 13th day of December, 2006, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $0 and Respondent's monthly net income/earning capacity is $0, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $160.00 per month payable as follows: $160.00 per month for alimony pendente lite and $0.00 per month on arrears. First payment due next pay date. Arrears set at $320.00 as of December 13, 2006. The effective date of the order is November 1, 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: Lisa J. Aikey. Payments must be made by check or money order. All checks and money orders must be made payable to PA SCDU and mailed to: PA SCDU P.O. Box 69110 Harrisburg, PA 17106-9110 Payments must include the Respondent's PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. cc360 Unreimbursed medical expenses that exceed $250.00 annually are to be paid as follows 0% by Respondent and 100% by Petitioner. The Petitioner is responsible to pay the first $250.00 annually in unreimbursed medical expenses. The Petitioner is to provide medical insurance coverage. This Order is based upon a Stipulation of the parties. The Respondent is to report to the Domestic Relaitons Officer a payment schedule for liquidation of the retroactive arrears or to report any direct payments that have been made to the Petitioner and should be credited to the Alimony Pendente Lite account. The Petitioner is to maintain her own medical insurance coverage. 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 Mailed copies on: December 13, 2006 to: Petitioner Respondent Laurie A. Saltzgiver, Esq. Sandra L. Meilton, Esq. BY THE COURT, Ke n A. Hess, J. DRO: R.J. Shadday r ? ?' r. ? c ? c? ? ? ? ? c.7 `-,-? Y`• ?:?. L :'1 ? ? ' 1..1 / l l L 7 to Lf-Q ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT Na - '4-33 / C/ V )L, State Commonwealth of Pennsylvania 7416 sq7 3 Q Original Order/Notice Co./City/Dist. of CUMBERLAND /"? O Amended Order/Notice Date of Order/Notice 12/13/06 7g S oCV?? O Terminate Order/Notice Case Number (See Addendum for case summary) RE: AIKEY, KARL S. Employer/Withholder's Federal EIN Number Employee/Obligor's Name (Last, First, MI) TARGET SYSTEMS INC 700 BENT CREEK BLVD MECHANICSBURG PA 17050-1875 195-46-4120 Employee/Obligor's Social Security Number 9035101722 Employee/Obligor's Case Identifier (See Ad&ndum 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. $ 880.00 per month in current support $ 0. oo per month in past-due support Arrears 12 weeks or greater? Oyes ® no $ 0.00 per month in current and past-due medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ 880.00 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: $ 203.08 per weekly pay period. $ 406.15 per biweekly pay period (every two weeks). $ 440, oo per semimonthly pay period (twice a month). $ 880.00 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 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: DEC 1 4 2006 Service Type M BY THE COURT: OMB No.: 0970-0154 Form EN-028 Rev. ' Worker ID $IATT y ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? Ifhecketi you are required to provide aopy of this form to yourgem?loyee. If your employee ?yorks in a state that is di Brent TTrom the state that issued this o er, a copy must be provi a to your employee even if tF1e 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.* . 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: 2516383770 EMPLOYEE'S/OBLIGOR'S NAME: AIKEY, KARL S. EMPLOYEE'S CASE IDENTIFIER: 9035101722 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 0 5 U.S.C. §1673 01; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Submitted By: DOMESTIC RELATIONS SECTION 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 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT Service Type M Page 2 of 2 Form EN-028 Rev. 1 Worker ID $IATT OMB No.: 0970-0154 ADDENDUM Summary of Cases on Attachment Defendant/Obligor: AIKEY, KARL S. PACSES Case Number 311108642 Plaintiff Name LISA J. AIKEY Docket Attachment Amount 06-4331 CIVIL$ 160.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACKS Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ................ ............. ....................... . ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ?If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. Service Type M PACKS Case Number 748108593 Plaintiff Name LISA J. AIKEY Docket Attachment Amount 00783 S 2006 $ 720.00 Child(ren)'s Name(s): DOB REBECCA.,E AIKEY 03/11/91 MMTk"HBkf`' T .YfE?I 08 /iL)i/93 ? 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. 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. Addendum OMB No.: 0970-0154 Form EN-028 Rev. 1 Worker ID $IATT C -Ti I cnI --+ T F CD ED002 12/26/2006 18:21 FAX 763 1907 REAGER&ADI.ER - AuG-27-02 14:38 FROG-Cumberland County Domestic Relations 7172407TTS T-163 P.002/002 F-638 DEC 2 7 2006 No. o(o- 4 83) Civ,'I CUMERLAND COUNTY DOMSTfC RELATIONS Date of Application: 1.Q 1.D 6) 06 Request for Support Record Starch Name: Iq r 1e_! h G i• S (L4"V_ 0110? Address: 3 Z-d d Lo a. no 1 c? A 170 6-1.5 Social Security Number: 1 R s. U 6 L) a D.O.B.: DOMestic Relations Case Number if Known, PartyRequeating Information: CMMkxn 1 j?yLAct.-?r'c.??s Mi ante of Fins Name) 717 9 0 - 6 q X19 _ _03,31 S6 , cI'i ?Aao?e?s) 2J7 -763-Jg07 (Fax Nurnbtr) (??) . :.Tw-vz Dgllar.(S20.00) Fee is Due per Social Security Number ?.....:. ,..?,... .. 1Vlxlce cherk'or money order able to: DRSILnt Search - IMTZAL )REQUEST Has no Record in Domestic Relations as of. (D*) Support Arrears as of End of Month Prior to Date of Application: $ 30? o.' o o IKonthiy Total Support Obligation: $_L10 o . oo/rni n The Amount shown above is reflected in the Domestic Relations Section Office of Cumberland County, Pennsylvania. m ?mb c r • g p 3 s o r 7a a Domestic Reladons Case Number. QaGS e S # 3 11) 64 & 9 A Signed: _C'?x ,J seam cooadinaw) ) ;i; .. t' BRING-DOWN REQUEST Support Arrears: $ As OE (ate) Signed: (Lien Coonansnor) (Date) * * * Lien, Satisfisfaction Receipt Available Upon Request*** C,e -7d o C"') r.,? t.,. ?. i t+? ?"; 4_"? ?,; ?? T =] ?? G s -yf .x, -!? ..,,? LISA J. AIKEY, vs. Plaintiff (KARL S. AIKEY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-4331 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 1, 2006. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days ve elapsed from the date of filing and service of the Complaint. I consent to the entry of a final decree of divorce after service of notice of intention to guest entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to orn falsification to authorities. Karl S. Aikey MEYERS, SFO 410 NORTH SECOND STREETPOS BO G62R & HBOYLE II ARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 N cl s ?7 J. AIKEY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 06-4331 S. AIKEY, CIVIL ACTION -LAW Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(C) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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 se statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to sworn falsification to authorities. 06 s Karl S. Aikey MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 17 -7 = G ; j w ? -7U, oG- 433/ MARITAL PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT made this day of 2007 by and between Lisa J. Aikey (hereinafter referred to as "Wife") of Cumberland County, Pennsylvania and Karl S. Aikey (hereinafter referred to as "Husband") of Cumberland County, Pennsylvania. WITNESSETH: WHEREAS, Husband and Wife were lawfully married on August 4, 1984 in Snyder County, Pennsylvania; and WHEREAS, two children have been conceived of this marriage; namely, Rebecca Elizabeth Aikey, born on March 11, 1991 and Matthew Isaac Aikey born on August 6, 1993; and WHEREAS, diverse differences and difficulties have arisen between the parties respecting their interests, rights and title in and to certain property, real and/or personal, owned by or in possession of the said parties to either of them; and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations and to amicably adjust, compromise and forever settle all property rights and all rights in, to or against each other's property or estate of any kind or nature whatsoever, including property heretofore or subsequently acquired by either party and to settle all disputes existing between them, including any and all claims for Wife's and/or Husband's rights to equitable distribution, maintenance and/or support, alimony, alimony pendente lite, counsel fees and costs; and WHEREAS, the parties acknowledge and agree that in entering into this Agreement, including foregoing waivers, they are each relying on truth and completeness in all material respects as to all information provided by the other party hereto regarding the assets of such person. NOW THEREFORE, in consideration of the mutual promises, covenants and agreements hereinafter contained, each of the parties hereto intending to be legally bound hereby promises, covenants and agrees as follows: DIVORCE: The parties agree that their marriage is irretrievably broken and that they mutually consent to a divorce. The parties agree to execute all necessary Affidavits of Consent and Waivers of Notice forms required by the court for the entry of a mutual consent divorce no earlier than January 1, 2007 and no later than January 16, 2007. Both Husband and Wife will direct their respective counsel to file with the Court said Affidavits and Waivers and file the appropriate documents to request a Decree in Divorce from the bonds of matrimony under Section 3301(c) of the Divorce Code on or about January 16, 2007. The parties acknowledge and agree that they do not intend to move 2 2 4 5 forward to obtain the Divorce Decree until January 2007. However, in no event shall they file their Affidavits of Consent and Waiver of Notice forms any later than January 16, 2007. FULL FORCE AND EFFECT: This Agreement shall continue in full force and effect until such time of final Decree in Divorce is entered. AGREEMENT TO CONTINUE IN EVENT OF DIVORCE: In the event that the marriage of the parties hereto is terminated by divorce, this Agreement shall nevertheless remain in full force and effect, and shall survive such decree and shall not in any way be affected thereby, except as provided for herein. INTERFERENCE: Each-party shall be free froinn interference, authority, and contact by the other, as fully as if he or she were single and unmarried except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. WIFE'S DEBTS: Wife represents and warrants to Husband that since the parties' separation, to wit, February 28, 2006, 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 responsible and shall indemnify and save harmless Husband from any and all claims or demands made against him by reason of debts or obligations incurred by her. 6. HUSBAND'S DEBTS: Husband represents and warrants to Wife that since the parties' separation, to wit, February 28, 2006, 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 shall indemnify and save harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. 7. DISCOVERY/FINANCIAL DISCLOSURE: The parties acknowledge and agree that they have each had the opportunity to conduct discovery and investigation of the assets of both parties. The parties acknowledge and agree that they have made full and fair disclosure of all of their assets and income to the other party. The parties acknowledge that they have both been given the opportunity to conduct investigation into all assets, whether separate or marital, prior to entry into this agreement. Both Husband and Wife acknowledge they have had full and fair disclosure of all assets prior to execution of this agreement. Furthermore, the parties acknowledge that they have both had full disclosure as to both parties income and financial condition. MUTUAL RELEASES: Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge 4 the other of and from all causes of action, claims, rights, or demands, whatsoever in law or equity, which either of the parties ever had or now has against the other, except any or all causes of action for termination of the marriage by divorce or annulment and except any or all causes of action for breach of any provisions of this Agreement. Husband and Wife specifically release and waive any and all rights lie or she might have to raise claims under the Pennsylvania Divorce Code and all subsequent amendments, but not limited to claims for equitable distribution of marital property, support, alimony, alimony pendente lite, counsel fees or expenses. The fact that a party brings an action to enforce the property agreement as incorporated in the divorce decree, under the Pennsylvania Divorce Code and all subsequent amendments, does not give either party the right to raise other claims under the Divorce Code, specifically waived and released by this paragraph and all rights and obligations of the parties arising out of the marriage shall be determined by this Agreement. 9. RELEASE OF TESTAMENTARY CLAIMS: Except as provided for in this Agreement, each of the parties hereto shall have the right to dispose of his or her property by Last Will and Testament or otherwise and each of them agree that the estate of the other, whether real, personal or mixed, shall be and belong to the person or persons who would become entitled thereto as if the decedent had been the last to die. This provision is intended to constitute a mutual waiver by the parties of any rights to take against each other's Last Wills under the present or future laws of any jurisdiction whatsoever and is intended to confer third-party beneficiary rights upon the other heirs and beneficiaries of each. 10. AGREEMENT BINDING ON HEIRS: The parties acknowledge that except as provided for in this Agreement, each of the parties shall have the right to dispose of their respective property by Last Will and Testament, and that each party waives the right to take under the Will of the other. This Agreement shall be binding on the respective heirs, executors, administrators and assigns of the parties thereto. 11. ENTIRE AGREEMENT: This Agreement represents the entire agreement between the parties. There are no representations, promises, agreements, conditions, or warranties between the parties other than those set forth herein. 12. LEGAL ADVICENOLUNTARY EXECUTION: 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 has had the benefit of counsel of Laurie A. Saltzgiver, Esquire, as her attorney. The Husband has employed and has had the benefit of counsel of Sandra L. Meilton, Esquire, as his attorney. Each party acknowledges that they have received independent legal advice from counsel and that each party fully understands the facts and have been fully informed of their legal rights and obligations, and 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 6 result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. Also, each party hereto acknowledges that he or she has been fully advised by his or her respective attorney of the current Pennsylvania Divorce Law, and 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 their respective right to have the Court make any determination or order affecting the respective parties' right to a divorce, alimony, alimony pendente lite, equitable distribution of all marital property, counsel fees and costs and expenses. 13. DIVISION OF PERSONAL PROPERTY: The parties have divided between them, to their mutual satisfaction, the personal effects, household furniture and furnishings, and all other articles of personal property which have heretofore been used by them in common. Should it become necessary, the parties each agree to sign any titles or documents necessary to give effect to this paragraph. 14. EQUITABLE DISTRIBUTION: a. Marital Residence - The parties acknowledge and agree that the marital residence located at 213 Edenderry Way, Enola, Pennsylvania 17025 is currently under a contract for sale and is scheduled for settlement on December 29, 2006. The parties agree that following the settlement and payment of all debts and costs of sale and closing, that any prorated real estate taxes which are reimbursed to the 7 parties shall be repaid to Husband. Thereafter, the parties agree that Wife shall receive sixty (60%) percent of the net proceeds and Husband shall receive forty (40%) percent of the net proceeds. b. Retirement Accounts, 401 M's, IRAs, Deferred Compensation Accounts: Husband shall rollover to Wife $30,000.00 from his Lutheran Brotherhood Thrivent IRA account. Said rollover shall be from Husband's IRA to Wife's IRA and shall not be a taxable event to either party. Husband shall retain the balance of said account as his sole and exclusive possession, free and clear of any and all claim by Wife. Additionally, Husband shall keep as his sole and exclusive possession any and all retirement accounts, 401(k)'s, IRAs and deferred compensation accounts presently in his name alone. Said retirement accounts, 401(k)'s, IRAs and deferred compensation accounts shall be Husband's sole and exclusive possession, free and clear of any and all claim and demand by Wife. Wife shall keep any and all retirement accounts, 401(k)'s, IRAs and deferred compensation accounts presently in her name alone. Said retirement accounts, 401(k)'s, IRAs and deferred compensation accounts shall be Wife's sole and exclusive possession, free and clear of any and all claim or demand by Husband. Automobiles: Wife shall keep the 2002 Honda Accord automobile as her sole and exclusive possession, free and clear of anv claim or demand by Husband. Wife shall be responsible for payment of any and all loans against said automobile. Husband shall keep the Honda CRV automobile as his sole and exclusive 8 possession, free and clear of any and all claim or demand by Wife. Husband shall remove Wife's name from the title to said vehicle, as well as any loan against said vehicle within twenty (20) days from the execution of the within agreement. The parties agree to execute any and all documentation necessary to give effect to the above paragraphs. d. Checkin /Savings Accounts: Wife shall keep as her sole and exclusive possession any and all checking and savings accounts in her name alone. Husband waives any and all right or claim to said checking and savings accounts. Husband shall keep as his sole and exclusive possession any and all checking and savings accounts in his name alone. Wife waives any and all right or claim to said checking and savings accounts. The parties agree that if there are any funds remaining in their joint checking account at Members I s' Federal Credit Union that they shall split these remaining funds 50/50. 15. AFTER-ACQUIRED PROPERTY: The parties acknowledge that Wife is in the process of purchasing a townhouse property located at 740 Sterling Court, Enola, Pennsylvania 17025. The parties acknowledge that this property is Wife's own separate, non-marital property. Husband has no right or claim against said property. Husband agrees to execute any and all waivers or documentation necessary to indicate his waiver of any interest in this property. 9 16. CHILDREN'S ACCOUNTS: The parties acknowledge that their two children, Rebecca and Matthew, presently have UGMA accounts, savings accounts, and TAP accounts. The parties agree that these accounts shall continue to be held for the children's college education and both of the parties shall be named as custodians on these accounts. 17. COUNSEL FEES: Husband shall pay $1,000.00 to Wife's attorney, Laurie A. Saltzgiver, Esquire as counsel fees within ten (10) days of the execution of the within agreement. 18. ALIMONY: Husband shall pay alimony to Wife in the amount of $160.00 per month for six (6) years from January 1, 2007 until December 31, 2012. These alimony payments shall be deductible to Husband for income tax purposes and taxable to Wife for income tax purposes. These alimony payments shall terminate only upon Wife's remarriage or the death of either party. The parties acknowledge that there is presently a child support order in the Cumberland County Domestic Relations Office docketed at #00783 S 2006 and an APL order in the Court of Common Pleas of Cumberland County docketed at #06-4331. The parties agree that effective January 1, 2007, the APL portion of the order shall become alimony and shall continue to be paid through the Cumberland County Domestic Relations Office. 10 19. 2006 INCOME TAX RETURN: The parties agree that they shall file a joint income tax return for the year 2006. The parties agree that any tax deficit shall be paid by the parties equally and any tax refund, likewise, shall be equally split by the parties. For 2007 and forward, Husband shall claim the parties' daughter, Rebecca, as a dependant on his income tax returns. Wife shall claim the parties' son, Matthew, as a dependent on her income tax return for 2007 and forward. 20. WAIVER OF RIGHT TO ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT, COUNSEL FEES, COSTS AND EXPENSES: The parties hereby acknowledge that they each waive their right to request alimony, alimony pendente lite, spousal support, counsel fees, costs and expenses from the other unless otherwise provided for in this Agreement. 21. BREACH: If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as may be available to him or her, and the party breaching this contract shall be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement. 22. ADDITIONAL INSTRUMENTS: a. 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 that t may be reasonably required to give full force and effect to the provisions of this Agreement. b. This Agreement shall be incorporated into a Divorce Decree but not merged therein. 23. MODIFICATION AND WAIVER: A modification or waiver of any of the 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 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. 24. 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. 25. 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. 26. EXECUTION DATE: The execution date shall be defined as the date both parties have signed this Agreement. In the event that the parties do not sign this Agreement at 12 the same time, the execution date shall be the date the last party has signed. 27. APPLICABLE LAW: This Agreement shall be construed pursuant to the laws of the Commonwealth of Pennsylvania. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above-written. CA, 6e, Lisa J. Ail y QY_ ?c Karl S. Aikey i Laurie A. Saltzgiver, quire _A% Sandra L. Meilton, Esq ire 13 - - rJ - F 1 r ` ? ` LISA J. AIKEY, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 06-4331 KARL S. AIKEY, CIVIL ACTION -LAW Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD THEPROTHONOTARY: Transmit the record, together with the following information, to the court for entry of a vorce decree: 1. Ground for Divorce: irretrievable breakdown under Section 3301(c) of the 2. Date and manner of service of the Complaint: Certified mail, restricted delivery )efendant. received on August 3. 2006. Proof of Service filed with the Prothonotarv on 3. (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of Divorce Code: by the plaintiff January 16, 2007; by the defendant December 18, 2006. 4. Related claims pending: No other claims are pending. 5. Date and manner of service of the notice of intention to file praecipe to transmit )rd, a copy of which is attached, if the decree is to be entered under section 3301(d)(1)(1) of Divorce Code. (b) Date plaintiffs Waiver of Notice in § 3301(c) Divorce was filed with the otary: January 16, 2007 . Date defendant's Waiver of Notice in § 3301(c) Divorce was filed with the : January 12, 2007. 'A Laurie A.-Saltzgi'ver, Attorney for Plaintiff MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 r7 ?, i ? ,, , ? ? ?_ ` ?' ' r ? ?? '? r--- ?? ; ,ti ,? `G '-? -. j -' -; ~?, _? f' ?? ?, ?? , ?, : ? . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Lisa J. Aikey Plaintiff No. 06-4331 VERSUS Karl S. Aikey Defendant DECREE IN DIVORCE AND NOW, A.- ft, / 7 7-007 , IT IS ORDERED AND DECREED THAT Lisa J. Aikey , PLAINTIFF, AND Karl S. Aikey , 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; The Marital Property Settlement Agreement dated January 16, 2007 is hereby incorporated but not merged herein. BY THE CkOURT: ATT E 712 PROTHONOTARY t,v R "" In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION LISA J. AIKEY ) Docket Number 06-4331 CIVIL Plaintiff ) VS. ) PACSES Case Number 311108642 KARL S. AIKEY ) Defendant ) Other State ID Number ORDER AND NOW, to wit, on this 17TH DAY OF JANUARY, 2007 IT IS HEREBY ORDERED that the support order in this case be Q Vacated or Q Suspended or ® Terminated without prejudice or Q Terminated and Vacated, effective DECEMBER 31, 2006 , due to : THE PARTIES' MARITAL SETTLEMENT AGREEMENT OF JANUARY 16, 2007. THERE IS A CREDIT OF $73.85 REMAINING ON THE ALIMONY PENDENTE LITE ACCOUNT AND THAT CREDIT WILL BE DIRECTED TO THE ALIMONY ACCOUNT. BY THE COURT: A?-- 4.441 Kevin Hess, JUDGE DRO: R.J. Shadday Form OE-504 Service Type M Worker ID 21005 ?? ?:::j psi =;? ? ;?y ...., •=, i ?- ; ? ? ,, `t ?..? }.i .w C,?`ti LIEN SATISFACTION Name: Karl Aikey Member Number: 9035101722 Pacses# 311108642 No. 06-4331 CV DR# Judgment Lien Satisfied as of: December 28, 2006 Amount Paid: $ 320.00 Signed: f :22. (z (Lien Coordinator) FES 0 1 2007 (Date) CC722 ,. ,° ;1 --' -€ -? ?-. -; s? nrt ?=_ c? ? ??; ? _1Y " ._- >: - -' , , ..?:: , ' `? n r ?Y i1 f { _ ' ..? C1^? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Pl tiff . Vs File No. 00 to IN DIVORCE J Defe dart NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, or ;Z after the entry of aFinal Decree in Divorce dated /,/7-0-7 , hereby elects to resume the prior surname of G SS , and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704. Date: Gov I e gnature U LOCI" ? - 6e_a- Signature of name being resumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF C;c ,-J.4 ) On the -JL_ day of 'IL 2042, before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. Prothonotary or c NOTARIAL SEAL PROTHONOTARY NOTARY PUBLIC MULE CUMBERLAMQ COUNTY COURTHOUSE MY COMMISSION EXPIRES JANUARY 4, ZOiO Q .? I ?,?Mti?raaP ,. ?rx l? In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION 13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013 Defendant Name: KARL S. AIKEY Member ID Number: 9035101722 Please note: All correspondence must include the Member ID Number. ORDER OF ATTACHMENT OF UNEMPLOYMENT COMPENSATION BENEFITS Financial Break Down of Multiple Cases on Attachment Plaintiff Name LISA J. AIKEY LISA J. AIKEY PACSES Docket Case Number Number 311108642 06-4331 CIVIL 748108593 00783 S 2006 Attachment Amount/Freouenc $ 161.00 /MONTH $$$ 720.00 MONTH / / / TOTAL ATTACHMENT AMOUNT: $ 881.00 Now, by Order of this Court, the Department of Labor and Industry, Bureau of Unemployment Compensation Benefits and Allowances (BUCBA), is hereby directed to attach the lesser of $ 2 0 2.7 5 per week, or 50 of the Unemployment Compensation benefits otherwise payable to the Defendant, KARL S. AIKEY Social Security Number XXX-XX- 4120 Member ID Number 9035101722 . BUCBA is ordered to remit the amount attached to the Department of Public Welfare (DPW). DPW shall forward the amount received from BUCBA to the Domestic Relations Section of this Court for support and/or support arrearages. If the Defendant's Unemployment Compensation benefits are attached by another Court or Courts for support and/or support arrearages, DPW may reduce the amount attached under this Order so that the total amount attached does not exceed the maximum amount subject to garnishment pursuant to 15 U.S.C. § 1673 (b)(2) and 23 Pa. C.S.A. § 4348 (g). This Order shall be effective upon receipt of the notice of the Order by the BUCBA and shall remain in effect until the Defendant's entitlement to Unemployment Compensation benefits, under the Application for Benefits dated MARCH 2, 2 0 0 8 is exhausted, expired or deferred. BUCBA shall comply with this Order, unless it is amended or vacated by subsequent Order of this Court. All questions, challenges or obligations to this Order shall be directed to the Domestic Relations Section of this Court. BY THE COURT Date of Order: MAR I 12008 DRO: R.J. SHADDAY Service Type M KEVIN A. HESS, JUDGE Form EN-530 Rev.1 Worker ID $ IATT nib Y ... i :-M CFI -G In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION 13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013 Defendant Name: KARL S. AIKEY Member ID Number: 9035101722 Please note: Ali correspondence must include the Member ID Number. ORDER OF ATTACHMENT OF UNEMPLOYMENT COMPENSATION BENEFITS Financial Break Down of Multiple Cases on Attachment Plaintiff Name LISA J. GOSS LISA J. GOSS PACSES Docket Case Number Number 311108642 06-4331 CIVIL 748108593 00783 S 2006 Attachment Amount/Frequency $ 160.00 /MONTH $$$ 720.00 MONTH / / TOTAL ATTACHMENT AMOUNT: $ 880.00 Now, by Order of this Court, the Department of Labor and Industry, Office of Unemployment Compensation Benefits (OUCB), is hereby directed to attach the lesser of $ 202.52 per week, or 50 of the Unemployment Compensation benefits otherwise payable to the Defendant, KARL S. AIKEY Social Security Number XXX-XX- 4120 , Member ID Number 9035101722 . OUCB is ordered to remit the amount attached to the Department of Public Welfare (DPW). DPW shall forward the amount received from OUCB to the Domestic Relations Section of this Court for support and/or support arrearages. If the Defendant's Unemployment Compensation benefits are attached by another Court or Courts for support and/or support arrearages, DPW may reduce the amount attached under this Order so that the total amount attached does not exceed the maximum amount subject to garnishment pursuant to 15 U.S.C. § 1673 (b)(2) and 23 Pa. C.S.A. § 4348 (g). This Order shall be effective upon receipt of the notice of the Order by the OUCB and shall remain in effect until the Defendant's entitlement to Unemployment Compensation benefits, under the Application for Benefits dated MARCH 2, 2 0 0 8 is exhausted, expired or deferred. OUCB shall comply with this Order, unless it is amended or vacated by subsequent Order of this Court. All questions, challenges or obligations to this Order shall be directed to the Domestic Relations Section of this Court. BY THE COURT Date of Order: SEP 14 2009 DRO: R.J. SHADDAY 7?,'- ' X,4 KEVIN HESS, JUDGE Form EN-530 Rev.2 Service Type M Worker ID $ IATT FILED- )r"FACE OF THE PROTI-I ;nT'A 2009 SEP 14 PH 2.27 ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania '742 1 U Z 5 9 3 Co./City/Dist. of CUMBERLAND 7TS-:S S qD0(, Date of Order/Notice o6/06/11 Case Number (See Addendum for case summary) Employer/Withholder's Federal EIN Number Sent Electronically DO NOT MAIL 195-46-4120 Employee/Obligor's Social ecunty um er 9035101722 Employee/Obligor's Case Identifier (See Addendum for plaintiff' names associated with cases on attachmeno Custodial Parent's Name (Last, First, MI) See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 0.00 per month in current child support $ 0.00 per month in past-due child support Arrears 12 weeks or greater? O yes & no $ 0.00 per month in current medical support $ 0.00 per month in past-due medical support $ 0.00 per month in current spousal support -std z-? m -?-o M -- $ 0.00 per month in past-due spousal support ! ?; r n r- $ 0.00 per month for genetic test costs $ 0.00 per month in other (specify)' $ one-time lump sum payment CD _n for a total of $ 0.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle doffs not>match the ordered support payment cycle, use the following to determine how much to withhold: $ 0.00 per weekly pay period. $ 0.00 per semimonthly pay period (twice a month). $ 0.00 per biweekly pay period (every two weeks). $ 0.00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 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). Pennsylvania law (23 PA C.S. § 4374(b)) requires remittance by an electronic payment method if an employer is ordered to withhold income from more than one employee and employs 15 or more persons, or if an employer has a history of two or more returned checks due to nonsufficient funds. Please call the Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. PA FIPS CODE 42 000 00 Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND 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. BY THE COURT: KEVIN A HESS v(o 4331 0-N I I Q Original Order/Notice O Amended Order/Notice & Terminate Order/Notice 0 One-Time Lump Sum/Notice RE: AIKEY, KARL S. Employee/Obligor's Name (Last, First, MI) OMB No.: 0970-0154 Form EN-428 Service Type M Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS di eeent rdm the state that issued this oder, acopyfmusttbe proemployee. iurfemployeeleven if the box istnot 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 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. 3115751420 THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER: O THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: Q EMPLOYEE'S/OBLIGOR'S NAME: AIKEY, KARL S. EMPLOYEE'S CASE IDENTIFIER: 9035101722 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: LAST KNOWN PHONE NUMBER: NEW EMPLOYER'S NAME/ADDRESS: FINAL PAYMENT AMOUNT: 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 (CCPA) (15 U.S.C. 1673 (b)); or 2) the amounts allowed by the State or Tribe of the employee's/obligor's principal place of employment. Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes, Social Security taxes, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is supporting another family and 60% of the disposable income if the obligor is not supporting another family. However, that 50% limit is increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State, you may deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section. Arrears greater than 12 weeks : If the Order Information does not indicate whether the arrears are greater than 12 weeks, then the employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of the CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amounts paid for health care premiums in determining disposable income and applying appropriate withholding limits. 10. Additional info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Send Termination Notice and other correspondence to: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www childsupoort state a us OMB No.: 0970-0154 Form EN-428 Service Type M Page 2 of 2 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: AIKEY, KARL S. PACKS Case Number 311108642 PACSES Case Number 748108593 Plaintiff Name Plaintiff Name LISA J. GOSS LISA J. GOSS Docket Attachment Amount Docket Attachment Amount 06-4331 CIVIL $ 0.00 00783 S 2006 $ 0.00 Child(ren)'s Name(s): nnR r,11:1 PAQSES a Number Plaintiff Name Docket Att achment Amount $ 0.00 Child(ren)'s Name(s): DOB PACSE• Ca Number Plaintiff Nam Docks Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Service Type M id(ren) s Name(s): DOB MATTHEW 1. AIKEY 08/06/93 PACKS Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACSES as Numb r Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Addendum OMB No.: 0970-0154 Form EN-428 Worker ID $IATT In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION 13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013 Phone: (717) 240-6225 Fax: (717) 240-6248 C-) r-.a C: q ',--", -% Defendant Name: KARL S. AIKEY nr' art, Member ID Number: 9035101722 -? 17-1 Please note: All correspondence must include the Member ID Number. - ,?• ?,, ?' --,, ? ;,? -.;-? : -- C + C) 4 ORDER TO VACATE ATTACHMENT OF UNEMPLOYMENT BENEFXtS Financial Break Down of Multiple Cases on Attachment Plaintiff Name LISA J. GOSS LISA J. GOSS PACSES Docket Case Number Number 311108642 06-4331 CIVIL 748108593 00783 S 2006 TOTAL ATTACHMENT AMOUNT: $ 880.00 Attachment Amount/Frequency 160.00 / MONTH 720.00 MONTH The prior Order of this Court directing the Department of Labor and Industry, Office of Unemployment Compensation Benefits (OUCB), to attach $202.52 or 50% per week of the Unemployment Compensation benefits of KARL S. AIKEY, Social Security Number XXX-XX-4120, Member ID Number 9035101722 is hereby vacated. This Order to Vacate shall be effective upon receipt of the notice of the Order by the Department and shall remain in effect until a further Order of the Court is filed. BY THE COURT ,.ldN 0 7 0;i Date of Order: Fd?var Er ?LUdv JUDGE Form EN-035 Service Type M Worker ID $IATT LISA J. GOSS, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 06-4331 CIVIL TERM KARL S. AIKEY, IN DIVORCE ' Defendant/Respondent: PACSES Case No: 311108642 j1-n c =M , . ORDER OF COURT r-- = C: w -. AND NOW to wit, this 16th day of June, 2011, it is hereby Ordered that the Cumberland County Domestic Relations Section dismiss their interest in the above captioned matter, pursuant to the demise of the Petitioner on June 5, 2011 The account is closed with no balance due to the Plaintiff. This Order shall become final twenty (20) days after the mailing of the notices of the entry of the Order to the parties unless either party files a written demand with the Office of the Prothonotary for a hearing de novo before the Court. BY THE COURT: t Edward E. Guido, J. DRO: R.J. Shadday xc: Petitioner Respondent Sandra L. Wilton, Esq. Laurie A. Saltzgiver, Esq. Form OE-001 Service Type: M Worker: 21005