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06-6476
Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 tbm@tbmesquire.com Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KIM KOPENHAVER HAIDET Plaintiff V. NO. 06- G V7L Civil Term KEITH R. HAIDET Defendant CIVIL ACTION - DIVORCE/CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE 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 2 Liberty Avenue, Carlisle, PA 17013 800-990-9108 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. BY THE COURT: J. 2 Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 tbm@tbmesquire.com Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KIM KOPENHAVER HAIDET Plaintiff V. NO. 06- L V7 L Civil Term KEITH R. HAIDET Defendant CIVIL ACTION - DIVORCE/CUSTODY COMPLAINT IN DIVORCE Count I - Divorce 1. Plaintiff is Kim Kopenhaver Haidet who currently resides at 13 Amherst Drive, Camp Hill, Cumberland County, Pennsylvania 17011 since in or around August, 2006. 2. Defendant is Keith R. Haidet who currently resides at 1048 Brookwood Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055 since in or around August 1997. 3. The parties have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The parties were married on August 18, 1984 in Hershey, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. Wherefore, Plaintiff requests the Court to enter a divorce decree under section 3301(c) of the Divorce Code. Count II - Equitable Distribution 8. Plaintiff incorporates by reference paragraphs 1 through 7. 9. During the marriage, Plaintiff and Defendant acquired real and personal property. Wherefore, Plaintiff requests the Court to enter an Order equitably dividing the marital estate. Count III - Alimony 10. Plaintiff incorporates by reference paragraphs 1 through 7. 11. Plaintiff lacks sufficient assets to provide for her reasonable needs and is unable to support herself fully through employment. 12. Defendant has sufficient assets and income to provide continuing support for Plaintiff. Wherefore, Plaintiff requests the Court to enter an Order granting her alimony. 2 Count IV - Alimony Pendente Lite, Counsel Fees, Costs and Expenses 13. Plaintiff incorporates paragraphs by reference paragraphs 1 through 7. 14. Plaintiff lacks sufficient assets to provide for her reasonable needs and is unable to support herself fully through employment. 15. Defendant has sufficient assets and income to provide continuing support for Plaintiff. 16. Plaintiff has retained counsel to pursue this action and has agreed to pay her attorney a reasonable fee. 17. Plaintiff lacks sufficient funds to meet the costs and expenses of pursuing this action, including counsel fees and the costs to retain experts to value the marital assets. 18. Defendant has sufficient assets and income to provide alimony pendente lite, counsel fees, costs and expenses for Plaintiff. Wherefore, Plaintiff requests the Court to enter an Order awarding her alimony pendente lite, counsel fees, costs and expenses. Count V - Custody 19. Plaintiff incorporates paragraphs by reference paragraphs 1 through 7. 20. Plaintiff seeks custody of the following child: Name Present Residence Date of Birth Jared Haidet 13 Amherst Drive 06/24/91 Camp Hill, PA 17011 The child was not born out of wedlock. 3 The child presently is in the custody of mother, who resides at 13 Amherst Drive, Camp Hill, Pennsylvania 17011. During the past five (5) years, the child has resided with the following persons at the following addresses: Name Address Dates Kim Kopenhaver Haidet 13 Amherst Drive 08/10/06 - present Camp Hill, PA Kim Kopenhaver Haidet 1048 Brookwood Drive 08/97 - 08/10/06 Keith R. Haidet Mechanicsburg, PA The mother of the child is Kim Kopenhaver Haidet, currently residing at 13 Amherst Drive, Camp Hill, Pennsylvania 17011. She is married. The father of the child is Keith R. Haidet, currently residing at 1048 Brookwood Drive, Mechanicsburg, Pennsylvania 17055. He is married. 21. The relationship of plaintiff to the child is that of Mother. The plaintiff currently resides with the following persons: her son, Jared. 22. The relationship of defendant to the child is that of Father. Defendant currently resides with the following persons: no one. 23. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or in another court. 4 Plaintiff does not have information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 24. The best interest and permanent welfare of the child will be served by granting the relief requested because Plaintiff has been the child's primary caregiver. 25. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. Wherefore, plaintiff requests the court grant her custody of the child. Theresa Barrett Male, Esquire Supreme Court # 46439 513 North Second Street Harrisburg, Pennsylvania 17101 (717) 233-3220 Counsel for Plaintiff Date: October 31, 2006 5 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 falsification to authorities. 4Kimope*nveraidet Date: **- W w tom; ? 04 CD ll?) KIM KOPENHAVER HAIDET IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 06-6476 CIVIL ACTION LAW KEITH R. HAIDET IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, November 14, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at MDJ Manlove, 1901 State St., Camp Hill, PA 17011 on Friday, December 22, 2006 at 12:30 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Melissa P. Gree Es q. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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, Pennsylvania 17013 Telephone (717) 249-3166 4W.3-Rc 4?v ?ev- /0?-- 41) 9o• 51.11 Los/ -/f p ? r ?r ? { C-) 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 KIM KOPENHAVER HAIDET Plaintiff V. KEITH R. HAIDET Defendant NO.06- Fax: (717) 240-6248 Civil Term CIVIL ACTION - DIVORCE/CUSTODY DRS ATTACHMENT FOR APL PROCEEDINGS PETITIONER'S INFORMATION: Name: Kim Kopenhaver Haidet Address: 13 Amherst Drive, Camp Hill, PA 17011 SSN: 181-54-4626 DOB: 07/16/61 Telephone: 717-975-5551 Physical Description:Ht. 57' Wt. 185lbs Eyes Blue Hair Blond Race Caucasian Email Address: KKH1@psu.edu Employer: Penn State University Employer's Address: 1300 Academic Support Building, Hershey, PA 17033 Phone: 717-531-1332 Title/Position: Ass't Professor Gross Pay: $60,192.00 Net Pay: $3,529.61 Petitioner's Attorney: Theresa Barrett Male, Esquire Petitioner's Attorney's Address: 513 North 2nd Street, Harrisburg, PA 17101 Phone: 717-233-3220 Medical Insurance Carrier: PPHN/Quantum Imaging and Therapeutics Assoc Medical Insurance Carrier Address: 409 S. 2nd St, Suite 3F, Harrisburg, PA 17104 Phone: 1-800-6367632 Policy Number: DHE1001486 Group Number: QI RESPONDENT'S INFORMATION: Name: Keith R. Haidet Address: 1048 Brookwood Drive, Mechanicsburg, PA 17055 SSN: 187-54-1243 DOB: 01/17/57 Physical Description: Ht.5'8" Wt. 155lbs Eyes Brown Email Address: krhaidet@paonline.com Telephone: 717-766-1675 Hair Brown Race Caucasian Employer: Quantum Imaging & Therapeutic Associates Employer's Address: 405 St. Johns Church Road, Camp Hill, PA 17011 Phone: 717-761-7470 Title/Position: Radiologist and Gross Pay: $400,000 Net Pay: Dir. of Capital Outpatient Imaging Respondent's Attorney: Sandra L. Meilton, Esquire Respondent's Attorney's Address: 1029 Scenery Drive, Harrisburg, PA 17109 Phone: 717-657-4795 Medical Insurance Carrier: PPHN/Quantum Imaging and Therapeutics Assoc Medical Insurance Carrier Address: 409 S. 2nd St, Suite 3F, Harrisburg, PA 17104 Phone: 1-800-6367632 Policy Number: DHE1001486 Group Number: QI MARRIAGE INFORMATION: Date Married: 08/18/84 Date of Separation: 08/10/06 Place of Marriage: Hershey, PA Address of last Marital Domicile: 1048 Brookwood Drive, Mechanicsburg, PA Description of Document Raising APL Claim: Plaintiff's Complaint in Divorce Date APL Document Filed**: 11/06/06 **Please note: A copy of the filed document MUST be enclosed with this form.** 2 c??"-' O ,? ' -n `? --? ?. .? t ?? ' _ ??:?. ;.. - .` ,?, _ j ?'' ? ? ?? '?c -- c? Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 tbm@tbmesquire.com Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KIM KOPENHAVER HAIDET Plaintiff V. KEITH R. HAIDET Defendant NO. 06- 0-7? Civil Term : CIVIL ACTION - DIVORCE/CUSTODY PLAINTIFF'S PETITION REQUESTING HEARING ON CLAIM FOR ALIMONY PENDENTE LITE 1. Concurrently with filing this petition, Plaintiff is filing a Complaint in Divorce, which raises economic claims, including a claim for alimony pendente lite. 2. Concurrently with filing this petition, Plaintiff is filing the "DRS Attachment for APL Proceedings" with the Court's Domestic Relations Section. Wherefore, Plaintiff requests the Court to set a hearing on her alimony pendente lite claim, and thereafter to award her alimony pendente lite. _ , I. Respectfully submitted, lLattz? Theresa Barrett Male, Esquire Supreme Court # 46439 513 North Second Street Harrisburg, Pennsylvania 17101 (717) 233-3220 Counsel for Defendant Date: November 6, 2006 2 LAS ?-' ? '" l C ° f ? -t j ,` . ..t - 14..? Y..a ? .. 4.,', ? ? - : KIM K. HAIDET, THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 06-6476 CIVIL TERM KEITH R. HAIDET, IN DIVORCE Defendant/Respondent . PACSES CASE NO: 370108757 ORDER OF COURT AND NOW, this 20th day of November, 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 December 18, 2006 at 9:00 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.110 (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. Copies mailed to: Petitioner Respondent Theresa Barrett-Male, Esq. Sandra L. Meilton, Esq. Date of Order: November 20, 2006 BY THE COURT, Edgar B. Bayley, President Judge i . S day, onference Officer YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND %" I 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 t.?? ?"? ?`? r ?? C- c4? ??-, "t1 ? ? ? z=-? _ -i T_ -r? ; -? ? ?_? ?a ? ? ?-? ? ? - ) 'Q-. - _.y '.?j't1 (,?l _-.I Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 tbm@tbmesquire.com Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KIM KOPENHAVER HAIDET Plaintiff 0(0- loy?(o v. NO. -66-6446-Civil Term KEITH R. HAIDET Defendant CIVIL ACTION - DIVORCE/CUSTODY ACCEPTANCE OF SERVICE I accept service of the Complaint in Divorce. I certify that I am authorized to accept service on behalf of defendant. 14A Date: November , 2006 __} t I-^i C.aJ KIM K. HAIDET, THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 06-6476 CIVIL TERM KEITH R. HAIDET, IN DIVORCE Defendant/Respondent PACSES CASE NO: 370108757 ORDER OF COURT - RESCHEDULE A CONFERENCE AND NOW, this 12th day of December 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. Shadday on February 22. 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. This date replaces the prior conference date of December 18, 2006. 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 1910.110 (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you (6) 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 Date of Order: December 12, 2006 Copies mailed to: Petitioner Respondent Sandra L. Meilton, Esq. Theresa Barrrett-Male, Esq. . Sha y, C ference 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 N K7 CO ? In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION KIM K. HAIDET ) Docket Number 06-6476 CIVIL Plaintiff ) VS. ) PACSES Case Number 370108757 KEITH R. HAIDET ) Defendant ) Other State ID Number ORDER AND NOW, to wit on this 22ND DAY OF JANUARY, 2007 IT IS HEREBY ORDERED that the Q Complaint for Support or Q Petition to Modify or ® Other ALIMONY PENDENTE LITE REQUEST filed on NOVEMBER 7, 2007 in the above captioned matter is dismissed without prejudice due to: THE PLAINTIFF WITHDRAWING HER REQUEST FOR AN ALIMONY PENDENTE LITE CONFERENCE. THE CONFERENCE SCHEDULED FOR FEBRUARY 22, 2007 IS CANCELLED. O The Complaint or Petition may be reinstated upon written application of the plaintiff petitioner. BY THE COURT: N -L ?? ? M. L. Ebert, Jr., JUDGE DRO: R.J. Shadday Form OE-506 Service Type M Worker ID 21005 r-? rU =' ; 0 Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 tbm@tbmesquire.com Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KIM KOPENHAVER HAIDET Plaintiff . O!p-1oy71'.o V. NO. -A6-64 therm KEITH R. HAIDET Defendant CIVIL ACTION - DIVORCE/CUSTODY PRAECIPE To the Prothonotary: Please withdraw Plaintiff's claim for custody. zo- Theresa Barrett Male, Esquire Supreme Court # 46439 513 North Second Street Harrisburg, Pennsylvania 17101 (717) 233-3220 Counsel for Plaintiff Date: January 19, 2007 y = z. Law Office of Theresa Barrett Male Theresa Barrett Male, Esquire, ID # 46439 Andrea Hudak Duffy, Esquire, ID # 60910 513 North Second Street Harrisburg, PA 17101-1058 (717) 233-3220 tbmC?tbmesQuire.com Attorneys for Plaintiff COURT OF COMMON OF PLEAS CUMBERLAND COUNTY, PENNSYLVANIA KIM KOPENHAVER HAIDET Plaintiff V. NO. 06-6476 Civil Term KEITH R. HAIDET Defendant CIVIL ACTION - DIVORCE/CUSTODY PLAINTIFF'S PETITION REQUESTING HEARING ON CLAIM FOR ALIMONY PENDENTE LITE 1. Plaintiff initiated this proceeding on November 7, 2006 by filing a Complaint in Divorce, which raised economic claims, including a claim for alimony pendente lite (" apl). 2. Concurrently with filing her complaint, Plaintiff filed the "DRS Attachment for APL Proceedings". 3. Based on an interim agreement of the parties, Plaintiff subsequently CJ withdrew her request for the apl conference. 4. Defendant has breached the interim agreement. Wherefore, Plaintiff requests the Court to set a hearing on her alimony pendente lite claim, and thereafter to award her alimony pendente lite. Law Office of Theresa Barrett Male //Z? By: Theresa Barrett Male, Esquire, ID #46439 Andrea Hudak Duffy, Esquire, ID # 60910 513 North Second Street Harrisburg, Pennsylvania 17101 (717) 233-3220 Attorneys for Plaintiff Date: October, 2008 2 t , PROOF OF SERVICE I hereby certify that I am this day serving a copy of the foregoing document upon the persons and in the manner indicated below which service satisfies the requirements of Pa. R.C.P. 440: Service by first-class mail addressed as follows: Sandra L. Meilton, Esquire Daley, Zucker, Meilton, Miner & Gingrich, LLC 1029 Scenery Drive Harrisburg, PA 17109 Attorneys for Defendant v Theresa Barrett Male, Esquire, ID # 46439 Andrea Hudak Duffy, Esquire, ID # 60910 513 North Second Street Harrisburg, Pennsylvania 17101 (717) 233-3220 Attorneys for Plaintiff Date: October 22, 2008 a. " s. 0+ v D E HIM K. HAIDET, THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 06-6476 CIVIL TERM KEITH R. HAIDET, IN DIVORCE Defendant/Respondent : PACSES NO: 370108757 ORDER OF COURT AND NOW, this 30th day of October, 2008, 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 December 12, 2008 at 9:00 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.110 (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 Theresa Barrett Male, Esq. Sandra L. Meilton, Esq. Date of Order: October 30, 2008 lt. . Sh- day, C nference Officer ,x 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 Cz, i _ KIM K. HAIDET, THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 06-6476 CIVIL TERM KEITH R. HAIDET, IN DIVORCE Defendant/Respondent : PACSES CASE NO: 370108757 ORDER OF COURT - RESCHEDULE A CONFERENCE AND NOW, this 8th day of December 2008, 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 January 26, 2009 at 1:30 P.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. This date replaces the prior conference date of December 12, 2008. 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 (6) 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 Date of Order: December 8, 2008 Copies mailed to: Petitioner Respondent Theresa Barrett Male, Esq. Sandra L. Meilton, Esq. ,R.'`J. Sh 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 713" ';i Q t ° CT7 C°3 A P ? "' r 1 ' CO C J LJ KIM K. HAIDET, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 06-6476 CIVIL TERM KEITH R. HAIDET, IN DIVORCE Defendant/Respondent : PACSES Case No: 370108757 ORDER OF COURT AND NOW, this 25th day of February 2009, based upon the Parties' agreement that the Petitioner's monthly net income/earning capacity is $ 3,801.77 and the Respondent's monthly net income/earning capacity is $ 17,003.2 1, it is hereby ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit FiveThousand Two Hundred Sixty-eight and 58/100 Dollars ($ 5,268.58) per month payable monthly as follows: $ 5,268.58 per month for Alimony Pendente Lite and $ 0.00 per month on arrears. First payment due: March 1, 2009. The effective date of the order is March 1, 2009. Arrears set at $ 0.00 as of February 25, 2009. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C.S.§ 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and, at its discretion, make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the PA SCDU to: Kim K. Haidet. 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 name with their PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. cc360 ?a°1 Y? Y q spry .r rt ?. ." l.I w KIM K. HAIDET : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff Vs. KEITH R. HAIDET Docket No. 06-6416 (Civil Term) Defendant MOTION IN FOR APPOTMENT OF MASTER Keith R . Hai de t 1 " (Defendant), moves the court to appoint a master with respect to the following claims: ( Divorce (k) Distribution of Property () Annulment () Support (J§ Alimony () Counsel Fees (c) Alimony Pendente Lite () Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claims (s) for which the appointment of a master is requested. (2) The defendant (has) appeared in the action (pumuft (by his attorney, Theresa Barrett Male -,Esquire). (3) The Staturory ground (s) for divorce (is) ) Sec. 3301(c) of the Divorce Code. (4) Delete the inapplicable paragraph(s): a. The action is not contested. b. An agreement has been reached with respect to the following claims: c. The action is contested with respect to the following claims: Alimony, Alimony Pendente Lite and Distribution of Property . (5) The action *mbroo (does not involve) complex issues of law or fact (6) The hearing is expected to take one ) (days). (7) Additional information, if any, relevant to the motion: Date: 3/25/09 aorney for (D fendant) Print Attorney Name ......... -Sandra L Mei ton ORDER APPOINTING MASTER AND NOW, .20-09--p Esquire is appointed master with respect to the following claims: By the Court: J. i 4"? i cr' `a C?l Sandra L. Meilton, Esquire DALEY ZUCKER MEILTON MINER & GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA 17109 smeilton@dzmmglaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KIM K. HAIDET, Plaintiff No. 06-6446 (Civil Term) V. CIVIL ACTION - LAW KEITH R. HAIDET, Defendant (In Divorce) INCOME AND EXPENSE STATEMENT Attached hereto is the Income and Expense Statement of Defendant submitted pursuant to Pa. R.C.P. No. 1920.31. z andra L. Meilton', Attorney for Defendant INCOME AND EXPENSE STATEMENT OF KEITH R. HAIDET INCOME Employer: Lancaster Radiology Associates Address: 555 N. Duke Street, P.O. Box 3555, Lancaster, PA 17604 Type of Work: Radiologist Payroll Number: Pay Period (weekly, biweekly, etc.): Monthly Gross Pay per Pay Period: Itemized Payroll Deductions: Federal Withholding FICA - SS FICA - Med Local Wage Tax State Income Tax Retirement PA SUI Life Insurance Health Insurance other (specify) Business expenses Net Pay per Pay Period: (see attached pay stub) Other Income: $ 7,692.91 $ 27,083.33 1,679.17 392.71 270.83 831.46 16.25 Week Month (Fill in Appropriate Interest/Dividends Pension/Annuity/Soc.Sec. Rents/Royalties Expense Account/Gifts Unemployment Comp. Workmen's Comp. Total $ TOTAL INCOME $ 16,200.00 Year Column) $ 16,200.00/month * - Dr. Haidet is reimbursed for business expenses but his gross pay is then reduced dollar for dollar for any business expenses for which he is reimbursed. Therefore, there is no payroll deduction noted since business expenses are itemized on the following Expense pages. It is important to note, however, that while his monthly gross income is $27,083.33, that amount is reduced by monthly unreimbursed business expenses totaling approximately $2,500. LANCASTER RADIOLOGY ASSOCIATES, LTD 555 N DUKE STREET, P.O. BOX 3555 Check date: 3/412008 LANCASTER, PA 17604-3555 Pay to the order of: KEITH R HAIDET $ 16,200.00 "Sixteen Thousand Two Hundred And 00/100 Dollars KEITH R HAIDET 1048 BROOKWOOD DRIVE MECHANICSBURG, PA 17055 60 KEITH R HA/DE7 XXX-XX-1243 Salaried Wages 0.00 Life Ins >5DK 0.00 Salaried Wages 0.00 Life Ins >50K 0.00 27,083.33 FICA-SS 0.00 FICA-Mod Federal W/H State W/H Lancaster W/H INSURANCE 401-k Section 125 PA SUI Year to Date 54,166.66 FICA-SS 0.00 FICA-Med Federal W/H State W/H Lancaster W/H INSURANCE 401-k Section 125 PA SUI Check date: 31412009 1,679.17 392.71 7,692.91 831.46 270.83 0.00 0.00 0.00 16.25 Net Pay 16,200.00 Net Pay 3,358.33 785.42 15,385.83 1,662.92 541.66 0.00 0.00 0.00 32.50 32,400.00 EXPENSES Weekly Monthly Yearly (Fill in Appropriate Co lumn) Home Mortgage $ $ 2,212.12 $ ** Maintenance 4,331.51 51,978.10 # Lawn Care 915.72 10,988.68 Electric 169.21 2,030.46 ## Non-Building & Labor 69.47 833.66 Gas - Propane 37.07 444.85 Telephone/Cable/Internet 149.77 1,797.19 with Comcast Cell phone 51.68 620.18 37.33 mo. Sewer 112/qtr. 448.00 Trash 14.50 174.00 Internet (Paonline) 8.32 99.23 Taxes Real Estate $ $ 511.79 $ 6,141.32 Personal Property 141.71 1,700.57 Insurance Homeowners 105.92 1,271.00 Automobile 48.58 583.00 ** - Maintenance included painting, patio redo, work to pool ho use/basement floors; pool deck. # - Lawn care included deck fence repair of $3, 000; tree removal of $3,000- $4,000 ## - Non-building and labor expenses; materials used in projects at marital residence, i.e., doors, etc. § - Defendant subscribed initially to Paonline for six months; then switched to Comcast. Weekly Monthly Yearly (Fill in Appropriate Column) Life $ $ $ Accident 371.06 4,452.73 Health Excess Coverage 18.75 225.00 Automobile Extended Warranty $ $ 117.66 $ (100,000 mile coverage) Fuel 408.10 4,897.25 Repairs 277.52 3,330.19 Memberships 12.50 150.00 Car Wash 5.25 63.00 Medical Doctor $ $ $ Dentist/Eye 134.83 1,618.00 Orthodontist Hospital Medicine Special needs (glasses, braces, orthopedic devices) 13.25 159.00 Education Parochial school 400.00 4,800.00 Conferences & Travel 1,892.54 22,710.45 Dance & Golf lessons 103.50 ($80/mo for dance; $282 per year for golf) Personal Clothing/retail Groceries & restaurants Haircare (Keith and Son) Personal care Hobbies Laundry/Dry Cleaning Professional dues and Licenses Philmont Boy Scout Ranch (Keith & Son) Tax preparation Postage Miscellaneous Household help Household items Pool Professional books and memberships Entertainment Vacation Gifts Weekly Monthly Yearly (Fill in Appropriate Column) C r $ 1,194.47 $14,333.58 699.71 8,396.52 30.00 73.17 878.00 266.67 3,200.00 203.33 2,440.00 13.32 159.82 $ 137.50 $ $ 90.87 $ 1,090.41 71.89 862.72 160.14 1,921.69 125.05 1,500.55 ** ** - Most of Defendant's travel is attached to conferences. Legal fees Charitable contributions, Church Alimony/child support Payments Other TOTAL EXPENSES Weekly Monthly Yearly (Fill in Appropriate Column) $ $ 772.29 $ 9,267.50 158.67 1,904.00 5,259.00 $ $21,815.74 $ PROPERTY OWNED Description See Inventory and Checking accounts Appraisement See Inventory and Savings accounts Appraisement See Inventory and Credit Union A praisement See Inventory and Stocks/bonds Appraisement See Inventory and Real estate Appraisement See Inventory and Other Ap raisement TOTAL *H=Husband; W=Wife; J=Joint ownership* Value H W J INSURANCE Policy Coverage* Company No. H W C Hospital Blue Cross Other Medical Blue Shield Other Highmark 02976751 X Health/Accident Disability Income New England Financial 2D301548 X Dental Other H=Husband; W=Wife; C=Child I understand that the statements made herein are subject to the penalties of 18 Pa.C.S. §4904 related to unsworn falsification to authorities. Keith R. Haidet I verify that I have reviewed this form with my client and to the best of my knowledge the answers herein are true and correct. andra L. Meilt Attorney for Defendant CERTIFICATE OF SERVICE AND NOW, this day of 2009, Owe 4 I, Gloria M. Rine, Paralegal to Sandra L. Meilton, Esquire, for the firm, Daley Zucker Meilton Miner & Gingrich, LLC., hereby certify that I have, this day, served the within document on counsel for Plaintiff, by depositing a copy of the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Theresa Barrett Male, Esquire 513 North Second Street Harrisburg, PA 17101 J-"' W W1. Gloria M. Rine ,? F ?? = `?: q??-.3 ?? ? . ..- r ,. ? , ?' ?".t ?_ :-+:. ?...,?. _ _;z Sandra L. Menton, Esquire Lindsay Gingrich Maciay, Esquire DALEY ZUCKER MEILTON MINER & GINGRICH, LLC 1029 Scenery Drive Harrisburg, Pennsylvania 17109 smeiltonrdzmmglaw. com Imacia10dzmmulaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KIM K. HAIDET, Plaintiff Docket No. 06-6486 (Civil Term) V. CIVIL ACTION - LAW KEITH R. HAIDET, Defendant (In Divorce) INVENTORY AND APPRAISEMENT OF KEITH R. HAIDET I, Keith R. Haidet, file the following inventory and appraisement of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. I verify that the statements made in this inventory and appraisement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. "? A F Defendant ASSETS OF PARTIES Defendant marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. If an item has been appraised, a copy of the appraisal report is attached. (x) 1. Real property (x) 2. Motor vehicles (x) 3. Stocks, bonds, securities and options () 4. Certificates of deposit (x) 5. Checking accounts, cash () 6. Savings accounts, money market and savings certificates () 7. Contents of safe deposit boxes () 8. Trusts () 9. Life Insurance policies (indicate face value, cash surrender value and current beneficiaries) () 10. Annuities () 11. Gifts () 12. Inheritances () 13. Patents, copyrights, inventions, royalties () 14, Personal property outside the home (x) 15. Businesses (list all owners, including percentage of ownership, and officer/director positions held by a party with company) () 16. Employment termination benefits - severance pay, workman's compensation claim/award (} 17. Profit sharing plans () 18. Pension plans (indicate employee contribution and date plan vests) (x) 19. Retirement plans, Individual Retirement Accounts () 20. Disability payments () 21. Litigation claims (matured and unmatured) () 22. MilitaryN.A. benefits (} 23. Education benefits (} 24. Debts due, including loans, mortgages held (x) 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute) () 26. Other MARITAL PROPERTY'" Defendant lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced: Item Number Description of Property Amount Names of all Owners 1. 1048 Brookwood Drive Appraised Value- $557,000.00 Joint Mechanicsburg, PA 17055 Mortgage- $132,631.00 (June 7, 2007) Equity- 416,000.00 2a. 2005 Volvo XC90 TBD Husband 2b. 2005 Volvo S60 TBD Wife 3a. Vanguard Acct # 9282 As of February 19, 2009 Money Market $98,754.94 Total Bond Index $104,685.36 PA Tax Exempt $110,766.15 Total Stock Index $181,999.67 Total $496,206.12 3b. Clipper Fund Acct # 8858 $51,332.55 3c. Dodge & Cox Acct # 9005 Stock Fund $80,470.97 Balanced Fund $52,046.19 Total $132,517.16 3d. Gabelli Acct # 8470 Gabelli Asset $53,974.79 Gamco Westwood $25,670.05 Total $79,644.84 3e. Muhlenkamp Acct # 0543 $39,028.17 3f. T. Rowe Price Acct # 0400 $50,074.78 3g. Harbor Funds Acct # 0413 Capital Appreciation $53,604.89 International $70,517.54 Total $124,123.43 3h. Janney Acct # 1512 $496,666.94 5. Wachovia Bank Acct #5578 $1,141,942.01 Joint 15a. MRI Enterprises $36,853.00 (February 2, 2009) 15b. Quantum Imaging $166,765.54 (June 20, 2008) -Payable in 8 installments of $20,845.69 each 15c. Quantum Affiliates $90,000.00 (approximate) 19a. State Retirement Valuation $136,986.00 (June 7, 2007) 19b. Janney IRA Acct # 4551 $56,656.95 19c. Janney SEP Acct # 5057 $3,433.85 19d. Janney IRA Acct # 3538 $37,230.56 19e. Quantum Imaging Fidelity $698,485.81 Acct # 3757 19f. Quantum Imaging Vanguard $74,500.16 Acct # 1318 25. Household Goods TBD *All accounts must be adjusted to reflect non-marital portions. Wife Wife Husband NON-MARITAL PROPERTY Defendant lists all marital property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property: Name of Reason for Item Number Description of Property all Owners Exclusion PROPERTY TRANSFERRED Defendant lists all property in which either or both spouses had a legal or equitable interest individually or with any other person and which has been transferred within the preceding three years: Item Number Description of Property Names of all Owners 5. Wachovia Bank Acct # 5578 Joint -Wife withdrew $571,981.00 on August 1, 2006 -Wife withdrew $5,000.00 cash on August 1, 2006 -Wife made a check payable to Karen Madiera in the amount of $3,417.39 on August 1, 2006 LIABILITIES OF PARTIES Defendant lists all liabilities of either or both spouses alone or with any person as of the date action was commenced: Name of Description of Debt Creditor Names of All Debtors Mortgage Sovereign Bank Acct # 0043 Joint CERTIFICATE OF SERVICE AND NOW, this ?S day of G , 2009, I, Gloria M. Rine, Paralegal to Sandra L. Meilton, Esquire, for the firm of Daley Zucker Meilton Miner & Gingrich, LLC, hereby certify that I have, this day, served the within Inventory and Appraisement on counsel for Plaintiff, by depositing a copy of the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Theresa Barrett Male, Esquire 513 North Second Street Harrisburg, PA 17101 Gloria M. Rine C`i ??... > ?::3 ??? ..?s """( ?".? ?? ?? ?- ?, ., i.i 1" ..? MAR 2 7 2008 KIM K. HAIDET Plaintiff Vs. KEITH R. HAIDET Keith R. Haidet respect to the following claims: (x) Divorce Distribution of Property () Annulment () Support ( Alimony () Counsel Fees (c) Alimony Pendente Lite () Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claims (s) for which the appointment of a master is requested. (2) The defendant (has) *mnnM appeared in the action 4owneiW (by his attorney, Theresa Barrett Male, Esquire). (3) The Staturory ground (s) for divorce (is) ) Sec. 3301(c) of the Divorce Code. (4) Delete the inapplicable paragraph(s): a. The action is not contested. b. An agreement has been reached with respect to the following claims: c. The action is contested with respect to the following claims: Alimony, Alimony Pendente Lite and Distribution of Property (5) The action (dnvnhrs* (does not involve) complex issues of law or fact (6) The hearing is expected to take one ) (days). (7) Additional information, if any, relevant to the motion: Date: 3/25/09 homey for ftmoo endant) Print Attorney Name ......... Sandra L. Me i It on _ ORD APPO R ? I AND NOW, ? 30 , Z0 , F-1 IV416yla .2f Esquire is appointed master with respect to the following claims:_/,*,a ' --f aztezd° : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Docket No. 06-6416 (Civil Term) Defendant M_ OTTON FOR &?ZQ 11TMENT OF MASTER M -(Defendant), moves the court to appoint a master with ra r Q3 } c? , ? .? jft q Z *01 v 02 AN 60OZ !. i . sH -R-J r - bv1p4' G Law Office of Theresa Barrett Male Theresa Barrett Male, Esquire, ID # 46439 Andrea Hudak Duffy, Esquire, ID # 60910 513 North Second Street Harrisburg, PA 17101-1058 (717) 233-3220 tbm(&tbmesguire.com Attorneys for Plaintiff COURT OF COMMON OF PLEAS CUMBERLAND COUNTY, PENNSYLVANIA KIM KOPENHAVER HAIDET Plaintiff V. NO. 06-6476 Civil Term KEITH R. HAIDET Defendant CIVIL ACTION - DIVORCE INVENTORY OF PLAINTIFF Plaintiff files the following inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. ASSETS OF THE PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. x _I 1 Real Property x- 2 Motor Vehicles _ x _ 3 Stocks, bonds, securities and options 4 Certificates of deposit x- 5 Checking accounts, cash 1 6 Savings accounts, money market and savings certificates 7Contents of safe deposit boxes - _ I 8 (Trusts Life insurance policies (indicate face value, cash surrende 9 beneficiaries) 10 Annuities 11 Gifts 12 Inheritance 13 Patents, copyrights, inventions, royalties 14 Personal property outside the home x -?- 1 Businesses (list all owners, including percentage of owner 15 officer/director positions held by a party with a company) - Employment termination benefits - severance pay, workm; 16 claim/award 17 Profit sharing plans x 18 - Pension plans (indicate employee contribution and date pl x 19 Retirement plans, Individual Retirement Accounts 20 Disability payments 21 Litigation claims (matured and unmatured) -- 22M . benefits ilitary/V.A 23 Education benefits 24 Debts due, including loans, mortgages held Household furnishings and personalty (include as a total category and attach x 25 itemized list if distribution of such assets is in dispute) - -_ - ---- - ------------------ 26 TOther value and current iip, and - --- i's compensation i vests) Assets of the Parties 2 MARITAL PROPERTY Plaintiff lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced: Item Number Description of Property Name of All Owners 1 1048 Brookwood Dr., Mechanicsburg, PA _ J - Additional real estate H et al. 2 2005 Volvo XC90 - H - - 2005 Volvo S60 W 3 _ .Vanguard Acct # 9282 -- H Clipper Fund Acct # 8858 H Cox Acct # 9005 j Dodge & H - Gabelli Acct # 8470 H Muhlenkamp Acct # 0543 - - H - - T. Rowe Price Acct # 0413 H Janney Acct # 1512 H 5 Wachovia Bank Acct # 5578 J 15 MRI Enterprises, Inc. H et al. Quantum Imaging _- - ?- H et al. -- Quantum Affiliates H et al. - 18 SE_RS - --- - tI --- --- -W W 19 Acct # 4551 RA ? SEP IRA # 5057 _ W IRA # 3538 H Fidelity - Quantum Imaging H Vanguard - Quantum Imaging H 25 1114413F J Marital Property 3 NON-MARITAL PROPERTY Plaintiff lists all property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property: Item Number Description of Property Reason for Exclusion- 25 Furniture/furnishings Family heirlooms Non marital property 4 PROPERTY TRANSFERRED Item Number Description of Property Date of Transfer Consideration Transferee 5 Cash 8/1/2006 Wife Property Transferred 5 LIABILITIES Item Number j Description of Property Names of All Creditors Names of All Debtors ---------- - -- 1 Marital Residence mortgage sovereign Bank J Liabilities 6 PROOF OF SERVICE I hereby certify that I am this day serving a copy of the foregoing document upon the persons and in the manner indicated below which service satisfies the requirements of Pa. R.C.P. 440: Service by first-class mail addressed as follows: Sandra L. Meilton, Esquire Daley, Zucker, Meilton, Miner & Gingrich, LLC 1029 Scenery Drive Harrisburg, PA 17109 Attorneys for Defendant Law Office of Theresa Barrett Male Theresa Barrett Male, Esquire, ID # 46439 Andrea Hudak Duffy, Esquire, ID # 60910 513 North Second Street Harrisburg, Pennsylvania 17101 (717) 233-3220 Attorneys for Plaintiff Date: May 15, 2009 r? `-- 1 ?? f O ,p w Law Office of Theresa Barrett Male Theresa Barrett Male, Esquire, ID # 46439 Andrea Hudak Duffy, Esquire, ID # 60910 513 North Second Street Harrisburg, PA 17101-1058 (717) 233-3220 tbm@tbmesQuire.com Attorneys for Plaintiff COURT OF COMMON OF PLEAS CUMBERLAND COUNTY, PENNSYLVANIA KIM KOPENHAVER HAIDET Plaintiff V. : NO. 06-6476 Civil Term KEITH R. HAIDET Defendant CIVIL ACTION - DIVORCE INCOME AND EXPENSE STATEMENT OF PLAINTIFF PENNSTATE CONFIDENTIAL KIM HAIDET PAY DATE GROSS PAY NET PAY TAXING AUTHORITY 12/31/2008 $5,259.00 $3,692.90 LOWER ALLEN TWP. BUDGET RATE SHIFT/OC REG HRS OT HRS HOL HRS HOL OT AMOUNT 0402398 UP $0.00 0.00 0.0 0.0 0.0 0.0 $5,259.00 TAXABLE SALARY TAX WITHHELD FEDERAL $4,909.44 FEDERAL $571.57 FICA $5,238.12 FICA $324.76 MEDICARE $5,238.12 MEDICARE $75.95 STATE $5,238.12 STATE $160.81 LOCAL $5,238.12 LOCAL $75.95 UNEMPLOYMENT $3.16 EMST $4.34 EMPLOYEE DEDUCTIONS / REDUCTIONS RETIREMENT $328.68 MEDICAL $0.00 DENTAL $18.84 VISION $2.04 Date Pdnted:January 17, 2009 PENNSTATE CONFIDENTIAL KIM HAIDET 2008 Year to Date Tax Information Medicare Salary YTD $62,219.28 FICA Salary YTD $62,219.28 Federal Salary YTD $58,314.48 State Salary YTD $62,219.28 Wage Tax Salary YTD $62,219.28 Retirement Salary YTD $62,478.00 TIAA Salary YTD $0.00 Actual Gross Salary YTD $62,478.00 No Tax Gross YTD $0.00 Perquisite YTD $0.00 Alien Salary YTD $0.00 Medicare Paid YTD $902.20 FICA Deduction YTD $3,857.58 Federal Paid YTD $6,769.00 State Paid YTD $1,910.16 Wage Tax YTD $902.20 Retirement Paid YTD $3,904.80 Employer Share YTD $3,504.90 Federal Retirement Paid YTD $0.00 403B Annuity YTD $0.00 457B Annuity YTD $0.00 Earned Income Credit YTD $0.00 Tips FICA, not deducted YTD $0.00 Date Printed:January 17, 2009 The following is a summary of your benefits as of January 17, 2009. Changes may be made to your benefits using the Update Benefits function within ESSIC, the Employee Self-Service Information Center. You may make changes, such as adding dependents to your Penn State benefits plan, under the following circumstances: • Within 30 days of the date that you acquire a new dependent through marriage, birth or adoption. • During the annual November "Time to Choose" open enrollment period. Changes made during open enrollment become effective on January 1st of the following year. • You may delete, at any time, a dependent who no longer is eligible for coverage under your plan. If you have other types of changes or questions regarding qualifying events, contact the Employee Benefits Division at (814) 865-1473 or by email at benefits@psu.edu 101 s C' S! JARED HAIQET 204-72-4915 CHILD 06/24/1991 The University may conduct random audits requiring proof of dependent eligibility. Individuals who misrepresent or falsify the eligibility of a dependent are subject to disciplinary action by the University BerCefit }?larrte 8efz8lft ription, 77 Q ' C 9e ?00, fOdAmbunt Medical ... _.._ ...._..__ .... HIGHMARK PPO BLUE EMPLOYEE AND CHILD(REN) .__._.._...__._ ? __.., _. .. µ ?..._.._ .._ F$247.62 ....... ,... _ ....... Dental UNITED CONCORDIA?' EMPLOYEE AND CHILD(REN) $19 46 Vi sion HIGHMARK BLUE SHIELD EMPLOYEE AND CHILD(REN) $2.04 Long Term Disability COVERAGE REFUSED Group Life Insurance FREE $5 000 $5 000 00 Accidental Death & Dismemberment - NIA No coverage Voluntary 5?{ , - s :.' F?,. hl~'ay A Y Enrollment in 403(b) tax deferred annuity and/or 457(b) deferred compensation plans can be done at any time. Similarly change to the deduction amounts may be made at any time. Enrollment forms and/or voluntary salary reduction agreements must be received in the Employee Benefits Division office by the first business day of the month in which the deduction is to be effective. 'A valid nine-digit social security number is essential for proper claims processing. For further information regarding Penn State's policy on social security numbers refer to policy AD-19 at hftp://guru.psu.edu/policies/AD19.html IMPORTANT:You may wish to review and update your beneficiary designations for life insurance, retirement, ADD and tax-deferred annuities at this time. Changes can be made at anytime during the year. Beneficiary forms are available for download from the Employee Benefits Division web site at http:/A~.ohr.psu.edu/Benefits/benefits.htm t:7?ENt ES WEEK MONTH YEAR EVEN m WEEK MONTH YEAR Hone Education MartgaigisJ tent ? ? I Private Sch-W I Maintonsnce _ 1 ? Parochial Sc tmw Re1r U3. ......._. ,.. .. ,..._.. ......._..... _.. Gas j < t Renona4 al ..,...... ?.. __.....____ ti?q Clot , .. t Telept,one 9 _ Food Water trberA?asinirmsaer $8N1MlL ?i5?J, ? CrBm Piryrftents 6 Emp3a?rtnent r'; ? Credit Gast RubHc Tsanaportatiatt Charge Luwtrcfi .. r; MambershsRs Taxes Loans RAW Estate Credit Union !insurance , morneowmS s , .. ................ ate +^ 1 r : , Miscallaneous Life Household tied Accident ! Child Care __ _.,_ Hearth i tvesl6c,katrnag - . Other tt y .. tlttlrINtcltettt Automobile Psy P"nk ri a? V ` $El7f R"irs 3? Legal to" ?S medical Chi coflttUMOM Dentist' <f ; _ my: t3rthoctotNiBt C?ttier _ Hospital g Y Is f . Medicine s , Special Needs y 1 y OrthoWic devices ( .° Sufi .. ?}YVbVtai ITotsf Mm" f S ' L' PROOF OF SERVICE I hereby certify that I am this day serving a copy of the foregoing document upon the persons and in the manner indicated below which service satisfies the requirements of Pa. R.C.P. 440: Service by first-class mail addressed as follows: Sandra L. Meilton, Esquire Daley, Zucker, Meilton, Miner & Gingrich, LLC 1029 Scenery Drive Harrisburg, PA 17109 Attorneys for Defendant Law Office of Theresa Ba ett Male Theresa Barrett Male, Esquire, ID # 46439 Andrea Hudak Duffy, Esquire, ID # 60910 513 North Second Street Harrisburg, Pennsylvania 17101 (717) 233-3220 Attorneys for Plaintiff Date: May 15, 2009 o u f ' 15 A, i J. o" -h Law Office of Theresa Barrett Male Theresa Barrett Male, Esquire, ID # 46439 513 North Second Street Harrisburg, PA 17101-1058 (717) 233-3220 tbrnAtbmesquire.com Attorneys for Plaintiff COURT OF COMMON OF PLEAS CUMBERLAND COUNTY, PENNSYLVANIA KIM KOPENHAVER HAIDET Plaintiff V. KEITH R. HAIDET Defendant NO. 06-6476 Civil Term CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on November 7, 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 of divorce after service of notice of intention to request entry of the decree. T I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Kim Ko aver Haidet Date: November 19, 2009 2 I- It BLED-Q FICE ')P THE PROTHOC, MARY 2009 NOY 23 AM 9_ 14 CUM8-P. E??IZOAN A # At-- Law Office of Theresa Barrett Male Theresa Barrett Male, Esquire, ID # 46439 513 North Second Street Harrisburg, PA 17101-1058 (717) 233-3220 tbm _tbmesguire.com Attorneys for Plaintiff COURT OF COMMON OF PLEAS CUMBERLAND COUNTY, PENNSYLVANIA KIM KOPENHAVER HAIDET Plaintiff V. NO. 06-6476 Civil Term KEITH R. HAIDET : Defendant CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 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. t - ?K" I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Kim Kope aver Haidet Date: November 19, 2009 2 FILED-OWICE OF THE P?CTHOC NOTARY 2009 NOV 23 AM 9: 14 CUI .... GiJUNTY PENNSYLVANIA I Law Office of Theresa Barrett Male Theresa Barrett Male, Esquire, ID # 46439 513 North Second Street Harrisburg, PA 17101-1058 (717) 233-3220 tbm@tbmesauire.com Attorneys for Plaintiff COURT OF COMMON OF PLEAS CUMBERLAND COUNTY, PENNSYLVANIA KIM KOPENHAVER HAIDET Plaintiff V. : NO. 06-6476 Civil Term KEITH R. HAIDET Defendant CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on November 7, 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 of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Keith R. Haidet Date: November 19, 2009 2 RLED-') =FK E OF THr PPSC??1 TAPY 2009 NOY 23 Ate 9: 13 CumbElIL- , tlb oullm PEl?Nv VANiA 1 f Law Office of Theresa Barrett Male Theresa Barnett Mate, Esquire, ID # 46439 513 North Second Street Harrisburg, PA 17101-1058 (717) 233-3220 tbm _tbmesquire.com Attorneys for Plaintiff COURT OF COMMON OF PLEAS CUMBERLAND COUNTY, PENNSYLVANIA KIM KOPENHAVER HAIDET Plaintiff V. NO. 06-6476 Civil Term KEITH R. HAIDET Defendant CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 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. if I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. fut Mfiax? Keith R. aidet Date: November 19, 2009 2 FILED-OFFICE OF THE PFCTHONK)TARY 2009 NOV 23 AM 9. 14 PENNSYLVANIA I . 4 KIM K. HAIDET, Plaintiff/Petitioner VS. . KEITH R. HAIDET, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 06-6476 CIVIL TERM IN DIVORCE PACSES CASE: 370108757 ORDER OF COURT AND NOW to wit, this 15th day of December, 2009, it is hereby Ordered that the Order for Alimony Pendente Lite is terminated, effective December 1, 2009, pursuant to the parties' settlement agreement. The parties agree that the case is closed with no balance due to the Petitioner. This Order shall become final twenty (20) after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary's Office for a hearing de novo before the Court. BY THE COURT: It,\ I ??? y- M. L. Ebert, Jr., J. DRO: R.J. Shadday xc: Petitioner Respondent Theresa Barrett Male, Esq. Sandra L. Meilton, Esq. Service Type: M Form OE-001 Worker: 21005 THERESA BARRETT MALE COUNSELOR AT LAW December 15, 2009 Rickie J. Shadday, Conference Officer Cumberland County Domestic Relations Office 13 North Hanover Street Carlisle, PA 17013 Re: Haidet v. Haidet (# 06-6276; PACSES # 3V0108757) Dear Ms. Shadday: SUSAN C. APPLEBY, PARALEGAL. sca@tbmesquire.com JONATHAN J. MALE, LEGAL ASSISTANT - A Pursuant to the parties' comprehensive settlement agreement, please terminate with prejudice the above-referenced action effective December 1, 2009. There are no arrears. If you have any questions or need any additional information, please advise. Sincerely, heresa Barrett Male TBM/ Cc: Sandra L. Meilton, Esquire Kim Kopenhaver Haidet 513 NORTH SECOND STREET, HARRISBURG, PENNSYLVANIA 17101-1058 TEL: 717-233-3220 - FAX: 717-233-6862 - WWW.TBM@TBMESQUIRE.COM •TBM@TBMESQUIRE.COM 2009 DEC 17 Pfd 3-- C J CUM- _ ? ?? KIM K. HAIDET, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 06 - 6476 Civil KEITH R. HAIDET, Defendant IN DIVORCE ORDER OF COURT AND NOW, this Zr` day of 2009, an agreement having been reached between the parties resolving all claims raised in the proceedings, the agreement, at the request of counsel (see counsel's letter of December 18, 2009, attached hereto), is not to be made part of the record. The appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court, along with the affidavits of consent and waviers of notice of intention to request entry of divorce decree signed by the parties, requesting a final decree in divorce. BY THE COURT, cc: Theresa Barrett Male Attorney for Plaintiff Sandra L. Meilton Attorney for Defendant COP Its '714 Edgar. Bayley, P.J. 2009 DEC 21 A 10: 22 cumi- +r. - t 41 Law Office of Theresa Barrett Male Theresa Barrett Male, Esquire Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101-1058 (717) 233-3220 tbmO-tbmesquire.com Attorneys for Plaintiff COURT OF COMMON OF PLEAS CUMBERLAND COUNTY, PENNSYLVANIA KIM KOPENHAVER HAIDET Plaintiff V. KEITH R. HAIDET Defendant TO THE PROTHONOTARY: NO. 06-6476 Civil Term CIVIL ACTION - DIVORCE PRAECIPE Please withdraw the economic claims raised of record. T eresa Barrett Male, Esquire Supreme Court # 46439 513 North Second Street Harrisburg, Pennsylvania 17101-1058 (717) 233-3220 Attorneys for Plaintiff Date: December 22, 2009 r Fig Ut'-- Law Office of Theresa Barrett Male Theresa Barrett Male, Esquire Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101-1058 (717) 233-3220 tbmO-tbmesquire.com Attorneys for Plaintiff COURT OF COMMON OF PLEAS CUMBERLAND COUNTY, PENNSYLVANIA KIM KOPENHAVER HAIDET Plaintiff V. NO. 06-6476 Civil Term KEITH R. HAIDET Defendant CIVIL ACTION - DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under § (3301(c)) (3301(d)(1)) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: November 16, 2006 by first- class mail. Defendant's counsel accepted service on November 17, 2006 per the acceptance of service filed of record. L 4, 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by plaintiff: November 19, 2009; by defendant: November 19, 2009. (b)(1) Date of execution of the affidavit required by § 3301(d) of the Divorce Code: N/A. (2) Date of filing and service of the plaintiffs affidavit upon the respondent: N/A. 4. Related claims pending: There are no economic claims pending. 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe a copy of which is attached: N/A. (b) Date plaintiffs Waiver of Notice was filed with the prothonotary: 11/23/09. Date defendant's Waiver of Notice was filed with the prothonotary: 11 /23/09. 14 tee-44,1 (2_ Attorney for Plaintiff Date: December 22, 2009 2 TH fj . 2904 DEC 22 Ah 10: 10 vL t, H Y r.? 1 !-11t C'Crr ? .-01 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KIM KOPENHAVER HAIDET V. KEITH R. HAIDET DIVORCE DECREE AND NOW, z-7- , Zaa 9 , it is ordered and decreed that KIM KOPENHAVER HAIDET , plaintiff, and KEITH R. HAIDET , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None. NO. 06-6476 Civil Term By the Court, .."4 Alt/, J. Prothonotary ?a 3o 1, 99 /a 30 •Of cx,4j ??? /I 1214 Au 1141-q AI&JOI-m-