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HomeMy WebLinkAbout06-5958 NATALIE S. STARE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. OG -.59.5Q' RONALD L. STARE, Defendant IN DIVORCE NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 SAIDIS, FLOWER & ?tNDSAY SAIDIS, FLOWER & ATTORNEYS-Ar uw 26 West High Street Carlisle, PA Carol J. Lind ay, Esquire Attorney Id. 3 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff NATALIE S. STARE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 06-5958 CIVIL RONALD L. STARE, Defendant IN DIVORCE ORDER AND NOW, this Z 9/` day of April, 2008, upon the agreement of counsel, the hearing on a Petition for Declaratory Judgment scheduled for April 25, 2008, at 1:30 p.m., is continued generally to be listed at the request of either party. BY THE COURT, 1011-7 Kevin Y. Hess, J. arol J. Lindsay, Esquire For the Plaintiff rbara Sumple-Sullivan, Esquire For the Defendant : rlm _ r i•A o ? y i;,J 0 1 :' '11.:1 tE?, ("I'Xi. 01HU n NATALIE S. STARE, Plaintiff V. RONALD L. STARE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06 - S?YX &,.a T?-&-- IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Natalie S. Stare, an adult individual, who has resided at 1405 Goodyear Road, Gardners, Cumberland County, Pennsylvania 17324 since 1970. 2. The Defendant is Ronald L. Stare, an adult individual, who has resided at 1947 Wyoming Avenue, Englewood, Florida 34224 since 2003. 3. The Plaintiff and Defendant were married on October 20, 1995 in Rockville, Maryland. 4. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 5. The Plaintiff has been advised that counseling is available and that she has the right to request that the court require the parties to participate in counseling. 6. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with §3301 of the Pennsylvania Divorce Code. SAIDIS, FLOWER & LINDSAY ATWWiErWX-1Aw 26 West High Street Carlisle, PA Dated: / ©jq rp Respectfully submitted, SAIDIS, FL ER Carol J. Lindsayx E, Attorney Id. 44?/ 26 West High ree? Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff Y VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsifications to authorities. za6.& o At Natalie Stare Date: I V0166 SAIDIS, FLOWER & LINDSAY ATTOM s.Anuw 26 West High Street Carlisle, PA n NATALIE S. STARE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW _ Sxj RONALD L. STARE, NO (31 Defendant IN DIVORCE ACCEPTANCE OF SERVICE certify that I accept service of the Complaint in the above-captioned matter and certify that I am authorized to do so. Daie Attorney for Defendant FLOWER ? LINDSAY 26 West High Street Carlisle, PA Barbara Sumple-Sullivan, Esquire Attorney ID Number: 549 Bridge Street New Cumberland, PA 17070-1931 ?j C ?, r ? ?.. -1 f A7 C?'? ..-? ??? ..._ V AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA NATALIE S. STARE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. RONALD L. STARE, Defendant IN DIVORCE PETITION FOR ALIMONY PENDENTE LITE AND NOW, comes Natalie S. Stare, by and through counsel, SAIDIS, FLOWER & LINDSAY, and petitions this Honorable Court as follows: 1. The parties hereto are husband and wife, having been joined in marriage on October 20, 1995. 2. The parties separated on or about February 2000. 3. Petitioner is without the ability to earn income sufficient to meet her reasonable needs and to pay attorney's fees. WHEREFORE, Petitioner prays this Honorable Court to order alimony pendente lite in an amount equal to the Pennsylvania State Support Guidelines and reasonable attorney's fees. SAIDIS, FLOWER & LINDSAY SAIDIS, FLOWER & LENDS" 26 West High Street Carlisle, PA Carol 'J- Linds`?j ,, gsquire Supreme CoFftZ No. 44693 26 West High Street Carlisle, PA 17013 717-243-6222 DRS ATTACHMENT FOR APL PROCEEDINGS SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA PETITIONER: NATALIE S. STARE DOB: 1/30/47 SSN: 205-36-7506 ADDRESS: 1405 GOODYEAR ROAD, GARDNERS, PA 17324 ATTORNEY: CAROL J. LINDSAY, ESQUIRE PETITIONER'S EMPLOYMENT: PALMYRA BOLOGNA HOW LONG? NET PAY: JOB TITLE: OTHER INCOME: (INCLUDEAMOUNTAND SOURCE) CENTRAL PA TEAMSTERS PENSION FUND INTEREST PAYMENTS FROM FULTON BANK, ADAMS COUNTY NATIONAL BANK AND ENGLEWOOD BANK DIVIDEND PAYMENTS FROM PRUDENTIAL FINANCIAL AND BANK OF NY RESPONDENT: RONALD L. STARE DOB: 7/7/43 SSN: 206-32-0448 ADDRESS: 1947 WYOMING AVENUE, ENGLEWOOD, FL 34224 ATTORNEY: BARBARA SUMPLE SULLIVAN, ESQUIRE RESPONDENT'S EMPLOYMENT: WALMART HOW LONG? NET PAY: JOB TITLE: RETAIL CLERK OTHER INCOME: (INCLUDEAMOUNTAND SOURCE) WHEN MARRIED: OCTOBER 20, 1995 DATE SEPARATED: FEBRUARY 2000 WHERE: ROCKVALE, MARYLAND WHERE LAST LIVED TOGETHER: CUMBERLAND COUNTY, PENNSYLVANIA FOR DRS INFORMATION ONLY VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsifications to authorities. Natalie S. Stare Date: 7 2 p - p SAIDIS, FLOWER & LINDSAY MID 26 West High Street Carlisle, PA n O ^r ^=c?? 01 V Cfs \ ? V L; F .s: NATALIE S. STARE, THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 06-5958 CIVIL TERM RONALD L. STARE, IN DIVORCE Defendant/Respondent PACSES CASE NO: 444109374 ORDER OF COURT AND NOW, this 10th day of August, 2007, 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. Shadday on September 18, 2007 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 V*42'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 Carol J. Lindsay, Esq. Barbara Sumple Sullivan, Esq. Date of Order: August 10, 2007 . Sh ay, C nference Officer r 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> v r ? ? ?t ? - , ?:t?. `?` ? ? ? ° fir, ??? Yl,? ? ..C r -0. NATALIE S. STARE, Plaintiff V. RONALD L. STARE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-5958 PACSES Case No. 444109374 IN DIVORCE PRAECIPE TO THE Please ARY: the Petition for Alimony Pendente Lite of the Plaintiff. SAIDIS, FLOWER & LINDSAY FIA?WFRR & L NIDS?AY 26 W at 110 street Cu[Wc, PA Carol J. Undsa ire , Supreme Co No. 44693 26 West High Street Carlisle, PA 17013 717-243-6222 r . , . CERTIFICATE OF SERVICE On the 14th day of September, 2007, I, Carol J. Lindsay, Esquire, of the law firm of SAIDIS, FLOWER & LI DSAY, hereby certify that on this date a copy of the attached document was served on the f llowing individual, via facsimile and regular mail, postage prepaid, addressed as follows: Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 SAIDIS, FLOWER & LINDSAY (1Aa'4a(0- ?i"l Carol J. Lindsay, Esquire Supreme Court ID No. 44693 26 West High Street Carlisle, PA 17013 717-243-6222 Flit '6L IrIIVll5?lY 26 War High Sum Carlisle, PA CJ R, q ? ?. ? `s ? ?i -?'? In the Court of NATALIE S. STARE VS. RONALD L. STARE Plaintiff Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION Docket Number 06-5958 CIVIL ) PACSES Case Number 444109374 Other State ID Number AND NOW, to wit ORDERED that the Q ( REQUEST FOR APL CONFER] matter is dismissed without THE PETITIONER WITHDRAI Q The Complaint or petitioner. this 18TH DAY OF SEPTEMBER, 2007 IT IS HEREBY [plaint for Support or Q Petition to Modify or ® Other r filed on AUGUST 7, 2007 in the above captioned ;iudice due to: HER REQUEST FOR AN ALIMONY PENDENTE LITE CONFERENCE i may be reinstated upon written application of the plaintiff BY THE COURT: ;J?'- '* X4 KEVI . HESS, JUDGE DRO% R.J. SHADDAY Form OE-506 Service Type M Worker ID 21005 G n 9 -v rn M - R y t .r NATALIE S. STARE, Plaintiff V. RONALD L. STARE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-5958 IN DIVORCE PETITION FOR DECLARATORY JUDGMENT AND NOW comes Natalie S. Stare by and through her counsel, Saidis, Flower & Lindsay, and petitions this Honorable Court as follows: 1. The parties hereto are husband and wife having been joined in marriage on October 20, 1995 and having separated in or about February 2000. 2. In the course of their marriage, Husband was a teamster employed by USF Glen Moore. He retired on or about February 1, 2003. 3. At the time of his retirement, Husband was entitled to benefits through two teamster plans, the 1999 pension plan, a defined benefit plan under which he earned benefits until the plan terminated on or about December 31, 1986, and the replacement plan, a defined contribution plan. 4. Upon information and belief, Respondent was notified by the teamsters that it would be advantageous for him to combine the plans into a single payment. 5. Respondent elected to take the combined plan. However, in order to do so, FLOWER & LIlVDSM 26 West High Street Carlisle, PA he needed the cooperation of Petitioner from whom he had been separated for approximately three years. 6. The parties entered into an oral contract according to the terms of which Respondent would go with Petitioner to sign any documents required so that he could combine the two pension plans and in consideration of her cooperation, he would pay to her $900.00 per month. 7. Petitioner cooperated in permitting Respondent to combine the plans and gain the advantage he wished. 8. Respondent performed on his promise and paid to Petitioner $900.00 per month until on or about February 2006 when he stopped the payments. 9. Wife filed for divorce on October 11, 2006. 10. Wife seeks to obtain the appointment of the Divorce Master but, upon information and belief, the Divorce Master will refer the issue of the oral contract between the parties to the Court for resolution. 11. Respondent is represented by Barbara Sumple-Sullivan, Esquire who does not concur with the relief requested. 12. No Judge has been appointed in this case. WHEREFORE, Petitioner prays this Honorable Court to determine that the parties entered into an enforceable oral contract according to the terms of which Respondent is obligated to pay Petitioner $900.00 per month. SAIDIS, FLOWER & LINDSAY r SAIDIS, FLOWER & LINDSAY ?notw?s?uw 26 West High Street Carlisle, PA Carol J. Lindsa , E5 Attorney 1 : 4469 26 West 49.h 5free, Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsifications to authorities. tia JA?- Natalie S. Stare Date: / A 9 -C4' SAIDIS, FLOWER & L04DS" 26 West High Street Carlisle, PA 1 CERTIFICATE OF SERVICE On the J- V day of January, 2008, I, Carol J. Lindsay, Esquire, of the law firm of SAIDIS, FLOWER & LINDSAY, hereby certify that on this date a copy of the attached document was served on the following individual, via regular mail, postage prepaid, addressed as follows: Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 SAIDIS, FLOWER & LINDSAY Carol"J. Lindsay quire Supreme Cou ID o. 44693 26 West Hig eet Carlisle, PA 17013 717-243-6222 SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA . IAN IQ ???R a I NATALIE S. STARE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW : NO. 06-5958 RONALD L. STARE, Defendant IN DIVORCE ORDER OF COURT SAM, FLOWERI & LINDSAY 26 West High Street Carlisle, PA AND NOW, this 7-4 day of , 2008, upon consideration of ell the within Petition, a Rule is issued on the Respondent to show cause why the declaratory judgment should not be issued as requested in the Petition. Rule returnable at a hearing set for the day of , 200,,Lat /; 30 /0.M o'clock in Court Room Number of the Courthouse in Carlisle, Pennsylvania. BY THE COURT, cc: ?Carol J. Lindsay, Esquire Counsel for Petitioner A Barbara Sumple-Sullivan, Esquire Counsel for Respondent C:op/iZs mac l.l_ a/0,3108 ?t FLED OF THc )INKY 2008 FEB -8 Ail It : 19 AD, ..'. Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 NATALIE S. STARE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. RONALD L. STARE, Defendant : NO. 06-5958 CIVIL ACTION -LAW IN DIVORCE NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a Counter- affidavit within TWENTY (20) DAYS after this affidavit has been served on you or the statements will be admitted. DEFENDANT'S AFFIDAVIT UNDER SECTION 3301 (D) OF THE DIVORCE CODE 1. The parties to this action separated in February, 2000, and have continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably broken. I understand that I may lose rights concerning spousal support, alimony, division of marital property, attorneys' fees or expenses if I do not claim them before a divorce is granted. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION, AND BELIEF. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA. C.S.A. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATED: Ronald L. Stare, Defendant :7 a Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 NATALIE S. STARE, IN THE COURT OF COMMON PLEAS Plaintiff V. RONALD L. STARE, Defendant : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06-5958 : CIVIL ACTION -LAW IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): _ (a) I do not oppose the entry of a divorce decree. _ (b) I oppose the entry of a divorce decree because (Check (i) (ii) or both): _ (i) The parties to this action have not lived separate and apart for a period of at least two years. _ (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): _ (a) I do not wish to make any claims for economic relief. 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. _ (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: Natalie S. Stare, Plaintiff NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you should not file this counter-affidavit. ?w? 17 7 a t`? #? 3 rn NATALIE S. STARE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 06-5958 RONALD L. STARE, Defendant IN DIVORCE NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 SAIDIS, LINDSAY 26 West High Street Carlisle, PA SAIDIS, FLOWER & LINQSAY Carol J. Lindsay, E uire Attorney Id.?446 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff NATALIE S. STARE, Plaintiff V. RONALD L. STARE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-5958 IN DIVORCE AMENDED COMPLAINT IN DIVORCE 1. The Plaintiff is Natalie S. Stare, an adult individual, who has resided at 1405 Goodyear Road, Gardners, Cumberland County, Pennsylvania 17324 since 1970. 2. The Defendant is Ronald L. Stare, an adult individual, who has resided at 1947 Wyoming Avenue, Englewood, Florida 34224 since 2003. COUNT I - DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 3. The Plaintiff and Defendant were married on October 20, 1995 in Rockville, Maryland. 4. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 5. The Plaintiff has been advised that counseling is available and that she has the right to request that the court require the parties to participate in counseling. 6. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance SAIDIS, FLOWER & LINDSAY AMMMAZDAW 26 West High Street Carlisle, PA with §3301 of the Pennsylvania Divorce Code. COUNT II - EQUITABLE DISTRIBUTION 7. The averments in paragraphs 1 through 6 are incorporated hereto as if fully set forth herein. 8. During their marriage, the parties have acquired certain property, both personal and real. WHEREFORE, Plaintiff requests this Court to equitably divide the marital property. SAIDIS, FLOWER & LIND Y Carol I Lindsay,s Attorney Id. 44k3_, 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA 04/Z8/?6?t8 11: 58 8:385315 .+113o1r,?., ?S, 7172436510 X1002 :_IlAll PACE ?5/as i VERIFICATION verify that the statements made in thW foregQinq document are .'true and correc#. I f{ understand that fare statements herein -3re prude subject to the penalties of 18 Pa. C.S. I §4904, relating to unsworn falsifications to autf, Atie:, I Natalie Stara i Date: s WERI5, & IINDW Rummk5i 26 Went Nigh 5r, c.t CUBSIc, PA g 00 r co ?r NATALIE S. STARE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 06-5958 RONALD L. STARE, Defendant IN DIVORCE ORDER OF COURT AND NOW, this 28' day of April, 2008, upon the agreement of counsel, the hearing on a Petition for Declaratory Judgment scheduled for 1:30 PM on April 25, 2008 is hereby continued generally to be listed at the request of either party. BY THE COURT, The norable Kevin A. Hess FLOWER & LINDSAY 26 West High Street Carlisle, PA u 0 ?p f /I8bl()r"ir(?{l j0 NATALIE S. STARE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 06-5958 RONALD L. STARE, ; Defendant IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff, in the above matter, Natalie S. Stare, FLOWER ? LINDSAY 26 West High Street Carlisle, PA X prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of NATALIE S. MEGONNELL and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. 704. Date: G.?30z N talie S. Stare N TALIE S. MEGON LL COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND On the -d??:day of June, 2008, 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 she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Official Seal. *Pu&b?lic????WTARUL , ¦A2 9A U E. STEEL, No" Bom, Cnmbednd Co M Commission Expins J00 7 ,2081 -P 1 b v.-... `, 411 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 NATALIE S. STARE, IN THE COURT OF COMMON PLEAS Plaintiff V. RONALD L. STARE, Defendant CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5958 CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 11, 2006. 2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days have elapsed since the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. 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. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. DATE: <J I a? u?s RONALD L. STARE 0 1 rn G ? .. -i Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 NATALIE S. STARE, IN THE COURT OF COMMON PLEAS Plaintiff V. RONALD L. STARE, Defendant : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06-5958 : CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 33301(c) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is 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 statement herein are made subject to the penalties of 18 Pa.C.S. 34904 relating to unsworn falsification to authorities. DATE: ? a-, lO? ? ? 1 "'o d RONALD L. STARE Cf? cn yy ? ti? NATALIE S. STARE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 06-5958 RONALD L. STARE, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed October 11, 2006. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Date: 0& lm? .Natalie S. Stare PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER6 3301 (c) OF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce without notice. SAMIS, FLOWER & LINDSAY AT 5Fff9•AT1Aw 26 West High Street Carlisle, PA 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. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Date: •? Dry /?? ?? - ZT?c Natalie S. Stare tea. `_. C-1 ? X .J NATALIE S. STARE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 06-5958 RONALD L. STARE, Defendant IN DIVORCE PROPERTY SETTLEMENT AND SEPARATION AGREEMENT THIS AGREEMENT made this 7 day of , 2008, by and between NATALIE S. STARE, of 1405 Goodyear Road, Gardners, Cumberland County, Pennsylvania 17324, hereinafter referred to as Wife and RONALD L. STARE, of 1947 Wyoming Avenue, Englewood, Florida 34224, hereinafter referred to as Husband. RECITALS: R.1: The parties hereto are husband and wife, having been joined in marriage on October 20, 1995 in Rockville, Maryland; and R.2: A Complaint for Divorce has been filed in the Court of Common Pleas of Cumberland County, Commonwealth of Pennsylvania, to Number 06-5958, Civil Term; and R.3: The parties entered into a Pre-Nuptial Agreement on October 13, 1995; and R.4: The parties hereto desire to settle fully and finally their respective financial and property rights and obligations including, but not limited, of all matters between them relating to the ownership of real and personal property, claims for spousal support, alimony, alimony pendente lite, counsel fees and costs, and the settling of any and all claims and possible claims against the other or against their respective estates. NOW THEREFORE, in consideration of the covenants and promises hereinafter to be mutually kept and performed by each party, as well as for other good and valuable consideration and intending to be legally bound, it is agreed as follows: 1 (1) SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place or places as he or she from time to time may choose or deem fit, free from any control, restraint or interference from the other. Neither party will molest the other or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceeding. Each party shall be free of the interference, authority or contact by the other as if he or she was single and unmarried except as maybe necessary to carry out the terms of this agreement. (2) DIVORCE: The parties acknowledge that the marriage is irretrievably broken and that they will secure a mutual consent no-fault divorce decree in the above-captioned divorce action. Simultaneously with the execution of this agreement, the parties shall execute and file Affidavits of Consent and Waivers of Notice and Wife will transmit the record so that the Decree in Divorce may be promptly entered. (3) REAL PROPERTY: Wife owns pre-marital real estate at 1405 Goodyear Road, Gardners, Cumberland County, Pennsylvania 17324. Husband waives any interest he may have in Wife's pre-marital real estate. Husband purchased two tracts of real estate in Florida subsequent to the parties' separation. Wife waives any interest she may have in any real property titled in Husband's name. With regard to all realty owned by the parties, the owner hereby indemnifies and holds the other harmless against any loss related to the property he or she is retaining. (4) DEBT: A. Marital Debt: Husband and Wife acknowledge and agree that there are no outstanding debts and obligations which are marital or for which the other might be liable incurred prior to the signing of this Agreement. B: Post Separation Debt: In the event that either party contracted or incurred any debt since the date of separation on February 14, 2000, the party who incurred said debt shall be 2 responsible for the payment thereof regardless of the name in which the debt may have been incurred. C: Future Debt: From the date of this agreement neither party shall contract or incur any debt or liability for which the other party or his or her property or estate might be responsible and shall indemnify and save the other party harmless from any and all claims or demands made against him or her by reason of debts or obligations incurred by the other party. (5) MOTOR VEHICLES: Each party relinquishes any right, title and interest he or she may have to any and all motor vehicles currently in possession of the other party. Each party shall assume full responsibility of any encumbrance on the motor vehicle received by said party, and shall hold harmless and indemnify the other party from any loss thereon. (6) TANGIBLE PERSONAL PROPERTY: The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, tools and other household personal property between them, and they mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such property presently in his or her possession whether said property was heretofore owned jointly or individually by the parties hereto. This agreement shall have the effect of an assignment or bill of sale from each party to the other for such property as may be in the individual possession of each of the parties hereto. Wife has been storing at her home Husband's personal property. On May 4, 2008 or within fifteen (15) days of the date of this Agreement, Husband will remove all of the property located in the garage at Wife's home. For such removal, he will employ a third party and will not come on Wife's property in order to assist. Further, Husband will provide Wife at least three days' notice as to the time of the move so that she can arrange to have a person oversee the move on her behalf. 3 (7) INTANGIBLE PERSONAL PROPERTY: Each party hereby relinquishes any right, title or interest he or she may have in or to any intangible personal property currently titled in the name of or in the possession of the other party, including, but not limited to, stocks, bonds, insurance, bank accounts, individual retirement accounts, employment benefits including retirement accounts, savings plans, pension plans, stock plans, 401 K plans and the like. Wife will retain all of her premarital intangible personal property and the two IRAs at The Bank of Hanover. In the course of their marriage and subsequently thereto, the parties have been joint owners of certain accounts and certificates of deposit at Fulton Bank, Jennison Dryder Investment account, Prudential and Englewood Bank. All of those accounts and certificates of deposit shall be Husband's sole and separate property and Wife waives any claim she has thereon. Simultaneously with the execution of this Agreement or within ten (10) days thereafter, Wife shall execute all documents provided by Husband necessary to relinquish any and all right, title and ownership to said accounts. Immediately upon execution of all such forms, but in any case within ten (10) days of the date of this agreement provided Wife has signed the forms presented, Husband will pay to Wife $28,775.00 in full satisfaction of her interest therein. Furthermore, by Qualified Domestic Relations Order prepared by Husband's counsel, Husband will transfer to Wife an interest in his Teamsters' Pension Plan in the initial amount of $225.00 per month together with any pro-rata cost of living increases awarded on Husband's pension by the Teamsters' Plan. Further a Qualified Domestic Relations Order will confirm Wife as the survivor annuitant of the joint and 50% survivor annuity presently elected by Husband. Wife waives any interest she has in the remainder of Husband's Teamsters' Pension. All IRAs owned by either party and secured during the marriage shall be the sole property of the IRA holder and the other spouse waives any claims thereto. 4 (8) WAIVER OF ALIMONY: The parties acknowledge that each has income and assets satisfactory to his and her own reasonable needs. Each party waives any claim he or she may have one against the other for alimony, spousal support or alimony and alimony pendente lite. (9) ADVICE OF COUNSEL: The parties hereto acknowledge that each has been notified of his or her right to consult with counsel of his or her choice, and have been provided a copy of this agreement with which to consult with counsel. Wife is represented by Carol J. Lindsay, Esquire and Husband is represented by Barbara Sumple-Sullivan, Esquire. 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 as each has sought from counsel, and the execution of this agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal agreement or agreements. Each party shall pay his or her own attorney for all legal services rendered or to be rendered on his or her behalf. Wife will reimburse Husband $50.00 for one-half of the cost of the Fulton Bank report of CD activity. (10) 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 that may be reasonably required to give full force and effect to the provisions of this Agreement. (11) INCOME TAX: The parties have heretofore filed joint Federal and State Tax returns. Both parties agree that in the event any deficiency in Federal, state or local income tax is proposed, or assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally 5 determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns. (12) BANKRUPTCY: The parties hereby agree that the provisions of this Agreement shall not be dischargeable in Bankruptcy and expressly agree to reaffirm any and all obligations contained herein. In the event a party files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party shall have the right to declare this Agreement to be null and void and to terminate this Agreement in which event the division of the parties' marital assets and all other rights determined by this Agreement including alimony shall be subject to court determination the same as if this Agreement had never been entered into. (13) COMPLETE DISCLOSURE: The parties do hereby warrant, represent, acknowledge and agree that each is fully and completely informed of, and is familiar with, the wealth, real and personal property, estate and assets, earnings and income of the other and has made any inquiry he or she desires into the income or estate of the other and received any such information requested. Each has made a full and complete disclosure to the other of his and her entire assets, liabilities, income and expenses and any further enumeration or statement thereof in this Agreement is specifically waived. (14) RIGHTS AND RESPONSIBILITIES: Husband and Wife acknowledge that each of them has read and understand his and her rights and responsibilities under this Agreement and that they have executed this Agreement under no compulsion to do so but as a voluntary act. (15) FULL SETTLEMENT: Except as herein otherwise provided, each party hereby releases the other from any and all claims, or demands up to the date of execution hereof. It is further specifically understood and agreed by and between the parties hereto that each party accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all of said party's rights against the other for past, present and future claims on account of support, 6 maintenance, alimony, alimony pendente lite, counsel fees, costs and expenses, equitable distribution of marital property and any other claims of the party, including all claims which have been raised or may be raised in an action for divorce. (16) RELEASE OF ALL CLAIMS: Except as may be otherwise specifically provided in this Agreement, Husband and Wife, for themselves, their heirs, representatives and assigns, each hereby forever releases, remises, discharges and quitclaims the other, and such other's heirs, representatives, assigns and estate, from and with respect to the following: A. All liability, claims, causes of action, damages, costs, contributions and expenses or demands whatsoever in law or in equity; B. All rights, title, interest or claims in or to any property of the other, whether real, personal or mixed and whether now owned or hereafter acquired; C. All rights of courtesy and dower and all claims or rights in the nature of courtesy and dower; D. All widow or widower's rights; E. All right, title, interest or claim in or to the other's estate, whether now owned or hereafter acquired, including but not limited to all rights or claims: (1) to take against the other's will; (2) under the laws of intestacy; (3) to a family exemption or similar allowance; and (4) all other rights or authority to participate or intervene in a deceased spouse's estate in any way, whether arising under the laws of Pennsylvania or any other country, territory, state or political subdivision. F. All rights or claims to any accounting; G. All rights, claims, demands, liabilities and obligations arising out of or in connection with the marital relationship or the joint ownership of property, whether real, personal or mixed; H. All rights, claims, demands, liabilities and obligations arising under the provisions of the Pennsylvania Divorce Code, as the same may be amended from time to time, and under the provisions of any similar statute enacted by any other country, state, territory or political subdivision; 1. All rights, claims, demands, liabilities and obligations each party now has, or may hereafter have, against or with respect to the other. (17) GOVERNING LAW: This Agreement shall be construed under the law of the Commonwealth of Pennsylvania. If any provision of this Agreement is determined to be invalid or unenforceable, all other provisions shall continue in full force and effect. (18) INCORPORATION INTO DECREE: In the event that either of the parties shall recover a final judgment or decree of absolute divorce against the other in a court of competent jurisdiction, the provisions of this Agreement may be incorporated by reference or in substance but shall not be merged into such judgment or decree and this Agreement shall survive any such final judgment or decree of absolute divorce and shall be entirely independent thereof. (19) BREACH: In the event that either party breaches any provision of this Agreement, he or she shall be responsible for any and all costs incurred to enforce the Agreement, including, but not limited to, court cost and counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election; to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. (20) COSTS: The parties agree to equally share the $100.00 cost incurred by Husband to secure the Fulton Bank account records. 8 (21) ENTIRE UNDERSTANDING: This Agreement constitutes the entire understanding between the parties and there are no covenants, conditions, representations, or agreements, oral or written, of any nature whatsoever, other than those herein contained. (22) AGREEMENT BINDING ON PARTIES AND HEIRS: This Agreement shall bind the parties hereto, their respective heirs, executors and assigns. IN WITNESS WHEREOF, the parties hereto intending to be legally bound have hereunto set their hands and seals the day and year first written above. WITNESS: Natalie S. Stare Ronald L. Stare 9 tC` UJ ,e ) NATALIE S. STARE, Plaintiff V. RONALD L. STARE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-5958 IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant's counsel accepted service of the Complaint on December 8, 2006. An Acceptance of Service was filed with the Court on December 14, 2006. 3. Date Affidavit of Consent required under Section 3301(c) of the Divorce Code was signed: By Plaintiff: June 3, 2008 contemporaneously herewith. By Defendant: May 27, 2008 contemporaneously herewith. and filed with the Prothonotary and filed with the Prothonotary 4. Related claims pending: The terms of the Property Settlement and Separation Agreement dated May 27, 2008 are incorporated, but not merged, into the Decree in Divorce. 5. Date Waiver of Notice under Section 3301(c) of the Divorce Code was signed: By Plaintiff: June 3, 2008 and filed with the Prothonotary contemporaneously herewith. By Defendant: May 27, 2008 and filed with the Prothonotary contemporaneously herewith. SAIDIS, LINDSAY 26 West High Street Carlisle, PA SAIDIS, FLOWER 4 LINDSAY Carol J. Li say Esquire Supreme ou No. 44693 26 West High Street Carlisle, PA 17013 717-243-6222 Attorney for Plaintiff C'? t i 5 C- . K, F co w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. NATALIE S. STARE VERSUS RONALD L. STARE No. 06-5958 DECREE IN DIVORCE AND NOW, S/tlna?, /O' 2008 , IT IS ORDERED AND NATALIE S. STARE DECREED THAT AND , PLAINTIFF, RONALD L. STARE , 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 terms of the Separation and Property Settlement Agreement dated May 27, 2008 are incorporated, but not merged, into this Decree in Divorce. BY THE COURT: ATT ST: J PROTHONOTARY ?? s2 ?????? ???? .. ,.. , . .- ?' 0? ' sf ?O•?l-? JUN 2 0 2008 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 NATALIE S. STARE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. RONALD L. STARE, Defendant : NO. 06-5958 CIVIL ACTION -LAW IN DIVORCE QUALIFIED DOMESTIC RELATIONS ORDER This Order is intended to be a qualified domestic relations order ("QDRO"), as that term is defined in Section 206(d) of the Employee Retirement Income Security Act of 1974 ("ERISA") and Section 414(p) of the Internal Revenue Code of 1986 ("Code"). Section 1. Identification of Plan This Order applies to benefits under The Central Pennsylvania Teamsters Defined Benefit Plan ("Plan"). Section 2. Identification of Participant and Alternate Payee a. Ronald L. Stare is hereafter referred to as the "Participant." The Participant's address is 1947 Wyoming Avenue, Englewood, Florida 34224. The Participant's Social Security Number is 206-32-0448. b. Natalie S. Stare is hereafter referred to as the "Alternate Payee." The Alternate Payee's address is 1405 Goodyear Road, Gardners, Cumberland County, Pennsylvania 17324. The Alternate Payee's Social Security Number is 205-36-7506. The Alternate Payee is the former spouse of the Participant. C. It is the responsibility of the Alternate Payee to keep a current mailing address on file with the Plan at all times. Section 3. Amount of Benefit to be Paid to Alternate Payee The Plan shall pay to the Alternate Payee the sum of Two Hundred Twenty-five Dollars and 00/100 ($225.00) per month of the Participant's monthly benefit, which benefit is currently in pay status. -1- rygell 77 -17c"S 'a ?ftv Lvl:? sg?tc6p 00 .2 R ?Zi?' BDQZ `114 4. Benefits Start The Plan shall start payments to the Alternate Payee as soon as administratively feasible upon receipt of this Order. Section 5. Form of Benefit The Plan shall pay the Alternate Payee's benefit in this form for the life of the Participant. Section 6. Death of Participant The Plan shall stop payments to the Alternate Payee in accordance with the form of payment specified in Section 5 upon the death of the Participant but shall continue payment in accordance with Section 8 of the Order. Section 7. Death of Alternate Payee If the Alternate Payee dies before Participant, the Alternate Payee's interest specified herein shall revert to the Participant. Section 8. Spousal Rights of Former Spouse as Alternate Payee The Plan shall treat the Alternate Payee as the Participant's spouse for purposes of the Participant's joint and survivor annuity. The Alternate Payee's right to the spousal survivor annuity shall apply to 50% joint and survivor annuity elected by Participant at the time of retirement. Section 9. Compliance with Applicable Laws The parties to this Order intend that it comply with the applicable provisions of ERISA and the Code. Nothing in this Order shall require the Plan: a. to pay any benefits not permitted under the Code or ERISA; b. to provide any type or form of benefit or any option not provided by the Plan; or c. to pay benefits to the Alternate Payee that are required to be paid to another Alternate payee under another QDRO that is in effect prior to this Order. -2- v ' Section 10. Reservation of Jurisdiction The Court reserves jurisdiction to amend this Order to establish or maintain its status as a QDRO under ERISA and the Code. IT IS SO ORDERED: Dated: rte. Z V Zoo t ---/ (4, 4XI J. Ronald L. Stare, Plan Participant's Signature Supreme Court I.D. # 32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Natalie S. Stare, Alternate Payee's Signature -3- Barbara Sumple-Sullivan, Esquire Attorney for Participant 26 West High Street Carlisle, PA 17013 (717) 243-6222