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HomeMy WebLinkAbout06-7285RAMONA L. DEVLIN, Plaintiff vs. SCOTT P. DEVLIN, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the foregoing 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 in 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: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 010- -7a8-S- cA.,,i IN DIVORCE Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 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 Telephone: (717) 249-3166 RAMONA L. DEVLIN, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. ) CIVIL ACTION - LAW SCOTT P. DEVLIN, ) NO. Defendant ) IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, RAMONA L. DEVLIN, by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is.RAMONA L. DEVLIN, an adult individual who currently resides at 233 Wood Street in Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is SCOTT P. DEVLIN, an adult individual who currently resides at 233 Wood Street in Camp Hill, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 21 October 2000 in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I - IRRETRIEVABLE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the Divorce Code of Pennsylvania. COUNT H.- EQUITABLE DISTRIBUTION 9. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as marital property. COUNT III -ALIMONY 10. Plaintiff lacks sufficient property to provide for her reasonable needs in accordance with the standard of living of the parties established during the marriage. 11. Plaintiff is unable to support herself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 12. The Defendant is employed and enjoys a substantial income from which he is able to contribute to the support and maintenance of the Plaintiff and pay her alimony in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding Plaintiff from Defendant permanent alimony in such sums as are reasonable and adequate to support and maintain Plaintiff in the station of life to which she has become accustomed during the marriage. COUNT IV - ALIMONY PENDENTE LITE 13. Plaintiff is without sufficient income to support and maintain herself during the pendency of this action. 14. Defendant enjoys a substantial income and is well able to contribute to the support and maintenance of Plaintiff during the course of this action. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her reasonable alimony pendente lite during the pendency of this action. COUNT V - COUNSEL FEES AND EXPENSES 15. Plaintiff is without sufficient funds to retain counsel to represent her in this matter. 16. Without competent counsel, Plaintiff cannot adequately prosecute her claims against Defendant and cannot adequately litigate her rights in this matter. 17. Defendant enjoys a substantial income and is well able to bear the expense of Plaintiff's attorney and the expense of this litigation. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay the legal fees and expenses incurred by Plaintiff in this litigation of this action. Samuel L. Andes Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). 2 q ?? ??? 1 Date: -At RAMONA L. DEVLIN ?__V N ? C C ? U+ F" O o O IN ? sa Q CIS 0 c fiJ r7 -1 FY RAMONA L. DEVLIN, PLAINTIFF VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2006-7285 SCOTT P. DEVLIN, DEFENDANT IN DIVORCE ACCEPTANCE OF SERVICE AND ENTRY OF APPEARANCE I hereby enter my appearance for the Defendant, Scott P. Devlin, in the above-captioned action. I acknowledge receipt of a true and correct copy of the Complaint in Divorce filed in the above action on behalf of the Defendant. Date: 2 9 a y d S Wayne . Shade Attorney for Defendant Supreme Court ID # / 3`? /? --..s _ ?""" "?T ...n ''? ? F ?{ ?1._ i ?4 4 .. _, ' ? --? ?? °C RAMONA L. DEVLIN, PLAINTIFF VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2006-7285 SCOTT P. DEVLIN, DEFENDANT IN DIVORCE MOTION FOR HEARING ON REQUEST FOR ALIMONY PENDENTE LITE AND NOW comes the above-named Plaintiff, by her attorney, and moves the court to schedule a proceeding before the Domestic Relations Office on her request for alimony pendente lite, which was raised in her divorce complaint, which was filed on 27 December 2006. A copy of her divorce complaint is attached hereto. above-captioned action. I acknowledge receipt of a true and correct copy of the Complaint in Divorce filed in the above action on behalf of the Defendant. Sam-ae1-L. Andes V _ Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 RAMONA L. DEVLIN, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. d6 " 7?r5 SCOTT P. DEVLIN, Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the foregoing 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 in 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: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 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-Y"OU NO N'6T HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFIE FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue 3 Carlisle, PA 17013 - + c n Telephone: (717) 249-3166 RAMONA L. DEVLIN, Plaintiff vs. SCOTT P. DEVLIN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302 (d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. RAMONA L. DEVLIN, Plaintiff VS. SCOTT P. DEVLIN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, RAMONA L. DEVLIN, by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: The Plaintiff is RAMONA L. DEVLIN, an adult individual who currently resides at 233 Wood Street in Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is SCOTT P. DEVLIN, an adult individual who currently resides at 233 Wood Street in Camp Hill, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 21 October 2000 in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I - IRRETRIEVABLE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the Divorce Code of Pennsylvania. COUNT II - EQUITABLE DISTRIBUTION 9. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as marital property. COUNT III - ALIMONY 10. Plaintiff lacks sufficient property to provide for her reasonable needs in accordance with the standard of living of the parties established during the marriage. 11. Plaintiff is unable to support herself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 12. The Defendant is employed and enjoys a substantial income from which he is able to contribute to the support and maintenance of the Plaintiff and pay her alimony in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding Plaintiff from Defendant permanent alimony in such sums as are reasonable and adequate to support and maintain Plaintiff in the station of life to which she has become accustomed during the marriage. COUNT IV - ALIMONY PENDENTE LITE 13. Plaintiff is without sufficient income to support and maintain herself during the pendency of this action. 14. Defendant enjoys a substantial income and is well able to contribute to the support and maintenance of Plaintiff during the course of this action. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her reasonable alimony pendente lite during the pendency of this action. COUNT V - COUNSEL FEES AND EXPENSES 15. Plaintiff is without sufficient funds to retain counsel to represent her in this matter. 16. Without competent counsel, Plaintiff cannot adequately prosecute her claims against Defendant and cannot adequately litigate her rights in this matter. 17. Defendant enjoys a substantial income and is well able to bear the expense of Plaintiff's attorney and the expense of this litigation. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay the legal fees and expenses incurred by Plaintiff in this litigation of this action. Samuel L. Andes Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date : RAMONA L. DEVLIN I Yj J. 0, V V RAMONA L. DEVLIN, THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 06-7285 CIVIL TERM SCOTT P. DEVLIN, IN DIVORCE Defendant/Respondent PACSES CASE NO: 184108902 ORDER OF COURT AND NOW, this 17th day of January, 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 February 12, 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 W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11© (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you. If you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, Edgar B. Bayley, President Judge Copies mailed to: Petitioner Respondent Samuel L. Andes, Esq. Wayne F. Shade, Esq. Date of Order: Jan ual7, 2007 _ T. Sh ay, C 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 ?'? ?., ? ? y, i ?; f ? } _ _. ri ,_ ?' , ? ? y'i .., ?..,? .? Ab RAMONA L. DEVLIN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW V. NO. 06-7285 CIVIL TERM SCOTT P. DEVLIN, Defendant : IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Defendant moves the Court to appoint a Master with respect to the following claims: Divorce Alimony Counsel Fees and Expenses Distribution of Property Alimony Pendente Lite and in support of the motion states: 1. Discovery is complete as to the claims for which the appointment of a Master is requested. 2. Defendant has appeared in this action by his attorney, Wayne F. Shade, Esquire. 3. The statutory grounds for divorce are irretrievable breakdown of the marriage. 4. The action is not contested with respect to all economic issues. WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take one-half day. , 7. Additional information, if any, relevant to the motion: None. Date: February 12, 2007 Wa3,ne . Shade, Esquire Supreme Court No. 15712 53 `'Vest Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Defendant ORDER APPOINTING MASTER AND NOW, February , 2007, E. Robert Elicker, II, Esquire, is appointed Master with respect to the foregoing claims. By the Court, J. WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 F5' Aft ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT CIVIL State Commonwealth of Pennsylvania L U S LOO (2) Original Order/Notice Co./City/Dist. of CUMBERLAND / j? t,., Q Amended Order/Notice Date of Order/Notice 02/12/07 15 Sv?`' Q Terminate Order/Notice Case Number (See Addendum for case summary) RE: DEVLIN, SCOTT P. Employer/Withholder's Federal EIN Number Employee/Obligor's Name (Last, First, MI) 159-38-3783 Employee/Obligor's Social Security Number STRATEGIC COMMUNICATION SERVIC 5652101747 516 INDUSTRIAL DR Employee/Obligor's Case Identifier LEWISBERRY PA 17339-9534 (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, MI) See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 1, 547. 00 per month in current support $ 0.00 per month in past-due support Arrears 12 weeks or greater? Qyes (9) no $ 0. 00 per month in current and past-due medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ 1, 547.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 357.10 per weekly pay period. $ 714. 0.2 per biweekly pay period (every two weeks). $ 773.51 per semimonthly pay period (twice a month). $ 1. 547. oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. Date of Order: FEB 13 2007 Service Type M BY THE COURT: OMB No.: 0970-0154 Form EN-028 Rev. " Worker ID $IATT I 4 ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If heck you are required to provide a opy of this form to your m loyee. If yo r employee orks in a state that is di4erent from the state that issued this order, a copy must be providedpto your emproyee even if tie box is not checked. 1. Priority: Withholding under this Omer/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3.* it. paydate/date of withholdii ir, is the date oi i wl dcl i amount was withheld from the employee's. wages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 9432100218 EMPLOYEE'S/OBLIGOR'S NAME: DEVLIN, SCOTT P. EMPLOYEE'S CASE IDENTIFIER: 5652101747 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employeelobligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employeelobligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 Service Type M Page 2 of 2 Form EN-028 Rev. 1 Worker ID $IATT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT OMB NO.: 0970-0154 ADDENDUM Summary of Cases on Attachment Defendant/Obligor: DEVLIN, SCOTT P. PACKS Case Number 184108902 Plaintiff Name RAMONA L. DEVLIN Docket Attachment Amount 06-7285 CIVIL$ 510.00 Child(ren)'s Name(s): DOB ® If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. Service Type M PACSES Case Number 226108690 Plaintiff Name RAMONA L. DEVLIN Docket Attachment Amount 00915 S 2006 $ 1,037.00 Child(ren)'s Name(s): DOB JACOB D. DEVLIN 02/15/01 SARA A.DEVLIN 09/28/02: ® If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACKS Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. Addendum OMB No.: 0970-0154 Form EN-028 Rev. 1 Worker I D $ IATT ? N ? c ?. -n ? -?? ?-:.> x;r??;? I ?- ? "' rn ? <- ?=;; -? -? ,,, --N? RAMONA L. DEVLIN, Plaintiff/Petitioner VS. SCOTT P. DEVLIN, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 06-7285 CIVIL TERM IN DIVORCE PACSES Case Number 184108902 ORDER OF COURT AND NOW, this 12th day of February, 2007, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $2196.76 and Respondent's monthly net income/earning capacity is $5243.82, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $540.00 per month payable as follows: $510.00 per month for alimony pendente lite and $30.00 per month on arrears. First payment due next pay date. Arrears set at $510.00 as of February 12, 2007. The effective date of the order is February 1, 2007. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C.S.§ 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the PA SCDU to: Ramona L. Devlin. Payments must be made by check or money order. All checks and money orders must be made payable to PA SCDU and mailed to: PA SCDU P.O. Box 69110 Harrisburg, PA 17106-9110 Payments must include the Respondent's PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. cc360 Unreimbursed medical expenses that exceed $250.00 annually are to be paid as follows 0% by Respondent and 100% by Petitioner. The Petitioner is responsible to pay the first $250.00 annually in unreimbursed medical expenses. (X) Respondent ( ) Petitioner O Neither party to provide medical insurance coverage. Within thirty (30) days after the entry of this Order, the (X) Respondent ( ) Petitioner shall submit written proof that medical insurance coverage has been obtained or that application for coverage has been made. Proof of coverage shall consist, at minimum, of: 1) the name of the health care coverage provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims should be made; 5) a description of any restrictions on usage, such as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms. This Order considers that the Respondent has a child support obligation under PACSES Case #226108690, docketed at 915 S 2006. This Order shall become final twenty days after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary for a hearing de novo before the Court. Consented: Petitioner Respondent Mailed copies on: F_ ebruary 13, 2007 to: Petitioner Respondent Samuel L. Andes, Esq. Wayne F. Shade,, Esq. Petitioner's Attorney Respondent's Attorney BY TH URT, Edward E. Guido J. DRO: R.J. Shadday r= -n zz j3T t ;t ' ty j 3 c- W y r o m FEB 1 3 2007 RAMONA L. DEVLIN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW V. NO. 06-7285 CIVIL TERM SCOTT P. DEVLIN, Defendant : IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Defendant moves the Court to appoint a Master with respect to the following claims: Divorce Alimony Counsel Fees and Expenses Distribution of Property Alimony Pendente Lite I and in support of the motion states: 1. Discovery is complete as to the claims for which the appointment of a Master is requested. 2. Defendant has appeared in this action by his attorney, Wayne F. Shade, Esquire. 3. The statutory grounds for divorce are irretrievable breakdown of the marriage. 4. The action is not contested with respect to all economic issues. WAYNE F. SHADE Attorney at Law 53 West Pomfret Streel Carlisle, Pennsylvania 17013 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take one-half day. 7. Additional information, if any, relevant to the motion: None. Date: February 12, 2007 Wayne . Shade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Defendant ORDER APPOINTING MASTER AND NOW, February JC' , 2007, E. Robert Elicker, II, Esquire, is appointed Master with respect to the foregoing claims. By the urt, llk-N J. WAYNE F. SHADE Att orney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 C ":,3 rs 679 ? PR `•s ? I cL- > ,. Lr) LA- w N I S4IVB 9oz . ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 0(0-72'75 C11111- State Commonwealth of Pennsylvania As la / V 9&17 0 0 Original Order/Notice Co./City/Dist. of CUMBERLAND 200to XO Amended Order/Notice Date of Order/Notice 03/01/07 O Terminate Order/Notice Case Number (See Addendum for case summary) RE: DEVLIN, SCOTT P. Employer/Withholder's Federal EIN Number Employee/Obligor's Name (Last, First, MI) STRATEGIC COMMUNICATION SERVIC 516 INDUSTRIAL DR LEWISBERRY PA 17339-9534 159-38-3783 Employee/Obligor's Social Security Number 5652101747 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, MI) See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 1, 547.00 per month in current support $ 30. 00 per month in past-due support Arrears 12 weeks or greater? Oyes ® no $ 0. 00 per month in current and past-due medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ 1, 577.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 363.92 per weekly pay period. $ 727. s5 per biweekly pay period (every two weeks). $ 788.50 per semimonthly pay period (twice a month). $ 1.577. oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: Date of Order: MAR 0 2 2007 Form EN-028 Rev. " Service Type m OMB No.: 0970-0154 Worker I D $ IATT 17- ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS If is ? heck you are required to pr vide a opy of this form to your em loyee. If yo r employee works in a state that dit?ferent from the state that issued this order, a copy must be proviato your empYoyee even if the box is not checked. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3.* Reporting the Paydateffiate of Withholdii is. You must reportthe paydateldate of withholding 6 paydateidate of withholding is t i ie date on vvl-,iF-h arnount was wit' il ield froin the employee's wages-. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employeelobligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 9432100218 EMPLOYEE'S/OBLIGOR'S NAME: DEVLIN, SCOTT P. EMPLOYEE'S CASE IDENTIFIER: 5652101747 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Antidiscrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employeelobligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of. 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11.Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 Service Type M If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6241L- or by internet www.childsupport.state.pa.us Page 2 of 2 OMB No.: 0970-0154 Form EN-028 Rev. 1 Worker ID $IATT ADDENDUM Summary of Cases on Attachment Defeadant/Obligor: DEVLIN, SCOTT P. PACSES Case Number 184108902 Plaintiff Name RAMONA L. DEVLIN Docket Attachment Amount 06-7285 CIVIL$ 540.00 Child(ren)'s Name(s): DOB PACSES Case Number 226108690 Plaintiff Name RAMONA L. DEVLIN Docket Attachment Amount 00915 S 2006 $ 1,037.00 Child(ren)'s Name(s): DOB JACOB D. DEVLIN 02 /15/01 S.M A. >DEVLIN , 0Vtt/0 ® If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ..:..: . . ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ® If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available identified above in any health insurance coverage available through the employee's/obligor's employment. through the employee's/obligor's employment. Addendum Form EN-028 Rev. 1 Service Type M Worker ID $IATT OMB No.: 0970-0154 r-a -?A?'^" ?/ t A ?? ? ? , ?? ? ? '1 W M ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 184108902 06-7285 CIVIL State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 03/30/07 Case Number (See Addendum for case summary) Employer/Withholder's Federal EIN Number STRATEGIC COMMUNICATION SERVIC 516 INDUSTRIAL DR LEWISBERRY PA 17339-9534 O Original Order/Notice O Amended Order/Notice O Terminate Order/Notice Employee/Obligor's Name (Last, First, MI) 159-38-3783 Employee/Obligor's Social Security Number 5652101747 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, MI) See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 1, 547. 00 per month in current support $ o. oo per month in past-due support Arrears 12 weeks or greater? Oyes ® no $ 0.00 per month in current and past-due medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ 1, 547.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 357. oo per weekly pay period. $ 714. o0 per biweekly pay period (every two weeks). $ 773.50 per semimonthly pay period (twice a month). $ 1.547. oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ?D (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. Date of Order: APR 0 2 2007 DRO: R.J. Shadday Service Type m 226108690 915 S 2006 RE: DEVLIN. SCOTT P. BY THE COURT Edward E. Guido, Judge Form EN-028 Rev. " OMB No.: 0970-0154 n i,..l,,... 1 n $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS F-1 If heck you are required to provide a opy of this form to your mployee. If yo r employee works in a state tha is di erent from the state that issued this or?er, a copy must be provi?ed to your emproyee even if the box is not chec?ed. 1. Priority: Withholding under this order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3.* payment. Reporting the Paydate/Date of Withholding.- You must report the paydate/date of vvithholding when sending the paydate/date of wit! d ioldii ig is tl ie date on wl i6ch an iou, it was wit' il ield fron it' ie employee's vvages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 9432100218 EMPLOYEE'S/OBLIGOR'S NAME: DEVLIN, SCOTT P. EMPLOYEE'S CASE IDENTIFIER: 5652101747 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employeelobligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of. 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. I 1.Submitted By: If you or your employee/obligor have any questions, DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT 13 N. HAN V R T P.O. BOX 320 CARLISLE PA 17013 Service Type m by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 OMB No.: 0970-0154 Form EN-028 Rev. 1 Worker I D $ IATT J ADDENDUM Summary of Cases on Attachment Defendant/Obligor: DEVLIN, SCOTT P. PACKS Case Number 184108902 Plaintiff Name RAMONA L. DEVLIN Docket Attachment Amount 06-7285 CIVIL$ 510.00 Child(ren)'s Name(s): DOB PACSES Case Number 226108690 Plaintiff Name RAMONA L. DEVLIN Docket Attachment Amount 00915 S 2006 $ 1,037.00 Child(ren)'s Name(s): DOB JACOB D. DEVLIN 02/15/01 SARA A. DLVLIN 09/ 8/02. El If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. [] If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available identified above in any health insurance coverage available through the employee's/obligor's employment. through the employee's/obligor's employment. Addendum Form EN-028 Rev. 1 Service Type M Worker ID $IATT OMB No.: 0470.0154 n ? o rte':. ? -n ?Ci F'71? -Z7 i'S"L -t7 ri t RAMONA L. DEVLIN, Plaintiff VS. . SCOTT P. DEVLIN, Defendant THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06 - 7285 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this day of , 2007, the economic claims raised in the proceedings having been resolved in accordance with a property settlement agreement dated July 13, 2007, the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. BY THE COURT, Q WC"'?CA Edgar B. Bayley, P.J. cc: ?muel L. Andes Attorney for Plaintiff t./ayne F. Shade Attorney for D A ta 7. co D e C? N LLI ?cL ?1 GV PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, made this 13"'? day of , 2007, is by and between: I C) SCOTT P. DEVLIN of 233 Wood Street in Camp Hill, Cumberland County, Pennsylvania, hereinafter referred to as "Husband"; and RAMONA L. DEVLIN of 100 South St. John's Road in Shiremanstown, Cumberland County, Pennsylvania, hereinafter referred to as "Wife." WITNESSETH: WHEREAS, the parties hereto are Husband and Wife, having been married on 21 October 2000 and are the legal parents of two children: Jacob D. Devlin, now age 6, born 15 February 2001, and Sara A. Devlin, now age 4, born 28 September 2002 (hereinafter referred to as "children°); and WHEREAS, certain difficulties have arisen between the parties hereto which have made them desirous of living separate and apart from one another and Wife has initiated an action in divorce filed to No. 20067285 before the Court of Common Pleas of Cumberland County, Pennsylvania; WHEREAS, the parties hereto, Wife being represented by Samuel L. Andes, Esquire, and Husband by Wayne F. Shade, Esquire, have each exchanged full and complete information as to the property, assets, and liabilities owned and owed by each and have disclosed to each other and to their respective attorneys full information as to the financial status of both parties hereto; and WHEREAS, the parties hereto have mutually entered Into an agreement for the division of their assets, the provision for the liabilities they owe, and provision for the resolution of their mutual differences, after both parties have had full and ample opportunity to consult with their respective attorneys, and the parties now wish to have that agreement reduced to writing. Page 1 of 8 NOW, THEREFORE, the parties hereto, in consideration of the above recitals, the mutually made and to be kept promises set forth hereinafter, and for other good and valuable considerations, and intending to be legally bound and to legally bind their heirs, successors, assigns, and personal representatives, do hereby covenant, promise, and agree as follows: 1. CHILD CUSTODY. This agreement makes no provision for the custody of the parties' children which the parties anticipate they will resolve privately outside the terms of this agreement. Each of the parties reserves onto themselves all of their rights, remedies, defenses, and claims regarding the custody of their children. 2. CHILD SUPPORT. Husband and Wife are parties to an action for support filed by Wife against Husband before the Court of Common Pleas of Cumberland County to Docket No. 915 S 2006 (PACSES No. 226108690), in which action an order has been entered which obligates Husband to pay Wife support for their children in the amount of $1,057.00 per month and to provide certain health insurance and related benefits for the children. This agreement makes no other provision for financial support of the children and the parties agree to resolve matters involving the financial support of their children through that action and the orders entered in that action, as such orders may be modified in the future. 3. MARITAL RESIDENCE. The parties acknowledge that, during their marriage, they owned the property at 233 Wood Street in Camp Hill, Hampden township, Cumberland County, Pennsylvania, and that Wife conveyed her Interest in the property to Husband in November of 2006. The parties further acknowledge that, at or near the time the title to the property was transferred to him, Husband refinanced the debt against the property and borrowed additional funds from which he paid Wife $10,000.00 as an advance against her share of the equitable distribution of the marital property. The parties further represent that an additional sum of approximately $20,000.00 remains from the refinancing of the property and that said sum is held in an interest-bearing escrow account with Husband's attorney. The parties agree that they shall divide and distribute the funds remaining In that escrow account as follows: A. $15,000.00 of those funds shall be distributed to Wife immediately upon the execution and delivery of this agreement; and Page 2 of 8 B. The balance of the funds in the escrow account, including all interest earned thereon, shall be distributed to Husband immediately upon the execution and delivery of this agreement. Husband shall be responsible to report and pay income tax on the interest generated by the funds while held in escrow. 4. SPOUSAL SUPPORT, ALIMONY, AND ALIMONY PENDENTE LITE. The parties acknowledge that, pursuant to an order dated 12 February 2007 entered In the divorce action between them, 1 Husband is obligated to pay Wife alimony pendente lite in the amount of $510.00 per month, plus $30.00 per month on any arrears and, in addition, Is obligated to continue health insurance on Wife during the pendency of that order. The parties agree that that order shall remain In full force and effect, as alimony pendente lite or, if the parties conclude a divorce prior to that date, as alimony, through 31 December 2007. As of 31 December 2007 the order, and Husband's obligation to make payments to Wife pursuant to that order, either as alimony pendente lite or as alimony, shall terminate and Husband shall, within ten (10) days thereafter, pay in full any and all arrearages or further payments due under the order. Upon that payment by Husband, that further obligation to pay spousal support, alimony, or alimony pendente lite shall terminate. The partles acknowledge that they are aware of the income, education, income potential, and assets and holdings of the other or have had full and ample opportunity to become familiar with such Items. Both parties acknowledge that they are able to support and maintain themselves comfortably, without contribution from the other beyond that as provided for in this Properly Settlement Agreement, upon the income and assets owned by each of them. The parties hereby accept the mutual covenants and terms of this Agreement and the benefits and properties passed to them hereunder in lieu of any and all further rights to support or alimony for themself, counsel fees, and alimony pendente lite at this time and during any and all further or future actions of divorce brought by either of the parties hereto and the parties do hereby remise, release, quit claim, and relinquish forever any and all right to support, alimony, alimony pendente lite, counsel fees and expenses beyond those provided for herein, during the pendency of or as a result of any such actions, as provided by the Divorce Code of Pennsylvania or any other applicable statute, at this time and at any time in the future. 5. PERSONAL PROPERTY. The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, and other household and personal property between them and they mutually agree that each party shall, from Page 3 of 8 and after the date hereof, be the sole and separate owner of all such tangible personal property presently in his or her possession, whether said property was heretofore owned jointly or individually by the parties hereto, and this agreement shall have the effect of an assignment or receipt from each party to the other for such property as may be in the individual possessions of each of the parties hereto, the effective date of said bill of sale to be contemporaneous with the date of the execution of this Agreement. 6. WAIVER OF EQUITABLE DISTRIBUTION. The parties acknowledge that each of them have had a full and ample opportunity to consult with counsel of their choice regarding their claims arising out of the marriage and divorce and that they have specifically reviewed their rights to the equitable distribution of marital property, including rights of discovery, the right to compel a filing of an Inventory and Appraisement, and the right to have the court review the assets and claims of the parties and decide them as part of the divorce action. Being aware of those rights, and being aware of the marital property owned by each of the parties, the parties hereto, In consideration of the other terms and provisions of this agreement, do hereby waive, release and quitclaim any further right to have a court or any other tribunal equitably distribute or divide their marital property and do hereby further waive, release and quitclaim any and all claim against or interest in assets now currently in the possession or held in the name of the other, it being their intention to accept the terms and provisions of this agreement in full satisfaction of all of their claims to the marital property of the parties and the equitable distribution of the same. 7. WAIVER OF ESTATE RIGHTS. Husband releases his inchoate intestate rights in the estate of Wife and Wife releases her inchoate intestate rights in the estate of Husband, and each of the parties hereto by these presents for himself or herself, his or her heirs, executors, administrators, or assigns, does remise, release, quit claim, and forever discharge the other party hereto, his or her heirs, executors, administrators, or assigns, or any of them, of any and all claims, demands, damages, actions, causes of action or suits of law or in equity, of whatsoever kind or nature, for or because of any matter or thing done, omitted, or suffered to be done by such other party prior to the date hereof; except that this release shall in no way exonerate or discharge either party hereto from the obligations and promises made and Imposed by reason of this agreement and shall in no way affect any cause of action in absolute divorce which either parry may have against the other. Page 4 of 8 8. WAIVER OF PROPERTY CLAIMS AND ESTATE CLAIMS. Except as herein otherwise provided, each party hereto may dispose of his or her property in any way, and each party hereby expressly waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including, without limitation, the right to equitable division of marital property, alimony, alimony pendente lite, and counsel fees, except as provided for otherwise in this Agreement, dower, curtesy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the will of the other, and right to act as administrator or executor of the other's estate, and each will, at the request of the other, execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights, and claims. 9. REPRESENTATION AS TO NO DEBTS. The parties hereto mutually represent to the other than neither of them has Incurred any debts In the name of the other not previously disclosed or provided for in this agreement. Each of the parties hereby represents to the other that neither one of them have incurred or contracted for debts In the name of the other or for which the other Is or would be legally liable from and after the date of the parties' separation. Both parties hereto mutually agree and promise that neither will contract or otherwise incur debts in the other's or joint names without the prior permission and consent of the other party hereto. Both parties hereto represent and warrant to the other party that they have not so contracted any debts unbeknownst to the other up to the time and date of this Agreement. 10. DISCLOSURE. Both of the parties hereto represent to the other that they have made full disclosure of the assets and income sources owned, controlled, or enjoyed by either of them and that neither party hereto has withheld any financial information from the other. Each of the parties represents that they have reviewed such information, as well as the law of Pennsylvania as it relates to their rights, obligations, and claims arising out of their marriage and of any divorce action which has or may be filed between the parties with an attorney of their choice, or had the opportunity to review such matters with an attorney of their choice and voluntarily decide not to do so. Further, the parties each acknowledge that they are aware that they have the right to compel the other party to provide full financial information about all assets owned by either party and all liabilities owned by either party and have the right to have a court force such disclosure in a divorce action. Being aware of those rights, the parties expressly waive the right to further disclosure or discovery regarding marital assets, Page 5 of 8 liabilities, incomes, and finances and agree that they are satisfied with their understanding of their legal rights and obligations. Being so aware and satisfied, the parties mutually accept the terms and provisions of this agreement in full satisfaction of any and all rights or obligations arising of their marital status or the divorce action now pending or to be filed between them. 11. CONCLUSION OF DIVORCE. The parties acknowledge that this agreement is made in contemplation of the conclusion by both of them of an action in divorce which has been filed or will be filed shortly by one of the parties hereto. Both of the parties hereto agree that they shall, upon the request of Wife's attorney and timed so that the parties can conclude their divorce in the second half of December of 2007, execute and deliver to their respective attorney or attorneys, an Affidavit of Consent under Section 3301(c) of the Divorce Code, consenting to the entry of a final decree In divorce, and a Waiver of further notice for the entry of such decree. Both parties agree that they shall accept the terms and provisions of this agreement in full satisfaction of any claims they may have under the Divorce Code of the Commonwealth of Pennsylvania, including, but not limited to, alimony, alimony pendente lite, counsel fees, equitable distribution, and the like. The parties agree that they may delay the entry of the final decree In divorce until a later date, to enable Husband to continue the insurance coverage on Wife as Is now available through his employer, but that the decision as to the date the documents are filed with the court to conclude the divorce shall be Wife's sole decision to make. Provided, nevertheless, that Husband shall not be required to make health insurance available to Wife after December 31, 2007, except as may be available to her through the COBRA plan. Under no condition, however, shall Husband be required to provide at his expense, or contribute to the cost of, health insurance for Wife after 31 December 2007. 12. RELEASE. The parties acknowledge that the purpose of this agreement is to divide all of their marital property, resolve all of the economic claims between them, and terminate and conclude any and all claims one party may have against the other. The parties acknowledge that each of them has had ample opportunity to consult with an attorney of their choice and to obtain legal representation with regard to this agreement and to the claims which they are terminating hereby. Consequently, each of the parties, for themselves, their heirs, successors, and assigns, does hereby accept the terms and provisions of this agreement in full satisfaction of any claims, of any nature, they may have, or may ever have had, against the other party and each of the parties does hereby waive, relinquish, release, and surrender forever any claim they have against the other party, arising out of their marital relationship, or any other dealing between the parties prior to the date of Page 6 of 8- this agreement, provided, however, that this release shall not exonerate either of the parties from the obligations they expressly make in this agreement, which shall survive the date of this agreement until such obligations are fully performed. 13. CHOICE OF LAW. This Agreement shall be Interpreted, applied and enforced in accordance with the laws of, and by the courts of, the Commonwealth of Pennsylvania. 14. SEVERABILITY. If for any reason whatsoever any part of this Agreement shall be declared void or invalid, only such part shall be deemed void and in all other respects this Agreement shall remain valid and fully enforceable. 15. NON-WAIVER. The waiver of any term, condition, clause, or provision of this Agreement shall in no way be deemed or considered a waiver of any other term, condition, clause or provision of this Agreement. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. W"SS Ali rtness kM-$GE EVL ONA L. DEVLIN Page 7 of 8 COMMONWEALTH OF PENNSYLVANIA ( SS.. COUNTY OF CUMBERLAND On this, the day of , 2007, before me, the undersigned officer, personally appeared SCOTT P. DEVU cno to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that said person executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. My Com fission Expires: COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL CONNIE J. TRITT, Notary Public Carlisle Boro., Cumberland County M Commission Expires October 5, 2008 COMMONWEALTH OF PENNSYLVANIA ( SS.. COUNTY OF CUMBERLAND On this, th J74 day of , 2007, before me, the undersigned _ tz-j" I officer, personally appeared RAMONA L. IN kno me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that said person executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. OxQ yn, (-//" -t My Com ion Expires: NOTANK Oft AMY M. WARM, NOTARY PUSUC Page 8 of 8 MOMNESM.,CUMBERLAND MY COMMIB&ON EXPIRES FEB. 4,20M RAMONA L. DEVLIN, PLAINTIFF ) VS. ) SCOTT P. DEVLIN, ) DEFENDANT ) PRAECIPE TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS ` OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2006-7285 IN DIVORCE Please withdraw all economic claims previously filed in this matter by the Plaintiff, Ramona L. Devlin, including, without limitation, claims for equitable distribution, alimony, alimony pendente lite, and counsel fees and expenses. 6 December 2007 L. Andes Attorney for Plaintiff Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 ?::' CII) RAMONA L. DEVLIN, Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-7285 CIVIL TERM SCOTT P. DEVLIN, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 27, 2006 and was served upon the Defendant within thirty days thereafter. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. 1 consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree in divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a divorce decree is entered by the court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated; RAMONA L. ?nr-XlLIN a ? C3 v -? V. - 4 11 RAMONA L. DEVLIN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW V. NO. 06-7285 CIVIL TERM SCOTT P. DEVLIN, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF CUMBERLAND ) 1. A Complaint in Divorce under §3301(c) of the Divorce Code with Notice of Availability of Counseling was filed on December 27, 2006, and served on December 29, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) WAYNE F. SHADE Attorney at Law days have elapsed from the date of filing and service of the Complaint. Pomfret S 53 West treet Carlisle, Pennsylvania 17013 . 4- 3. I consent to the entry of a Final Decree of Divorce without notice. 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 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. 6. I have been advised of the availability of marriage counseling and of my right to counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 7. I understand that the Court maintains a list of marriage counselors in the Domestic I Relations Office, which list is available to me upon request. 8. Being so advised, I do not request that the Court require that my spouse and I WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 participate in counseling prior to a Divorce Decree's being handed down by the Court. -2- • t Aft 9. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: December 5, 2007 Scott P. Devlin WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 -3- a ? 6 t' 4 Z-v RAMONA L. DEVLIN, Plaintiff VS. SCOTT P. DEVLIN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-7285 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c). 2. Date and manner of service of the Complaint: Acceptance of Service filed by Plaintiff's counsel indicating service on or about 3 January 2007 3. Complete either Paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code: By Plaintiff: 10 December 2007 By Defendant: 10 December 2007 (b) (1) Date of execution of the Affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: 4. Related claims pending: None. 5. Complete either (a) or (b): (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: Dated 10 December 2007 and filed contemporaneously herewith. Date Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: Dated 10 December and filed contemporaneously herewith. fiber 2007 B Samuel L. An s Attorney for Plaintiff C +?.s c° 4 rnn ,.` N orn s , -,., c? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. - - RAMONA L. DEVLIN., Plaintiff N 2006-7285 CIVIL TERM O. VERSUS SCOTT P. DEVUN, Defendant DECREE IN DIVORCE 3sg.#. 2007 1 ?? , AND NOW, IT IS ORDERED AND RAMONA L. DEVLIN DECREED THAT SCOTT P. DEVLIN AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE PROTHONOTARY ?° ??? ??? ?? a L??7? ,.: , i ? 1.. gyp. )?' _ ?? gyp: /?'? ?? RAMONA L. DEVLIN, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE SCOTT P. DEVLIN, Defendant/Respondent NO. 06-7285 CIVIL TERM IN DIVORCE PACSES Case No: 184108902 ORDER OF COURT AND NOW to wit, this 2nd day of January 2008, it is hereby Ordered that the Alimony Pendente Lite order be terminated effective December 20, 2007 pursuant to the parties' Decree in Divorce. Arrears in the amount of $833.14 will be paid by the existing wage attachment until paid in full This Order shall become final twenty (20) days after the mailing of the notice of the entry of the order to the parties unless either parry files a written demand with the Domestic Relations Section for a hearing de novo before the Court. BY THE C W Edward E. Guido, J. DRO: R.J. Shadday xc: Petitioner Respondent Wayne F. Shade, Esq. Samuel L. Andes, Esq. Form OE-001 Service Type: M Worker: 21005 C`) ? ?? p ? ? ?- ? ??? = ; _.? ? ?' ?'?