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MARGARET H. SMITH,
Plaintiff
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965 CIVIL
1<)94
No,
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IRA F. SMITH,
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DECREE IN
DIVORCE
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ANI) NOW. "','," ,lt~~.,ft:., ""~?, ~~" 19 ,~'!.," it is ordered and
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ore divorcAd from the bonds of matrimony,
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The court retains iurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet
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Theresa Barrett Male
Supreme Court 146439
10 South Market Square
Suite 500
Harrisburg, PA 17101
(717) 233-3220
Attorney For Plaintiff
MARGARET H. SMITH,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 965 Civil 1994
v.
IRA F. SMITH,
Defendant
CIVIL ACTION - DIVORCE
PRAECIPE TO TRANSMIT RECORD
1. Ground for divorce: irretrievable breakdown under section
3301(c) of the Divorce Code.
2.
1994 by
delivery
Date and manner of service of the Complaint: March 11,
certified mail, return receipt requested, restricted
per the verification of service by mail filed of record.
(Complete either paragraph (a) or (b).)
3.
(a) Date of execution of the affidavit of consent required by
section 3301(c) of the Divorce Code: by Plaintiff: June 8, 1994;
by Defendant: June 29, 1994.
(b) (1) Date of execution of Plaintiff's Affidavit required
by section 3301(d) of the Divorce Code: N/A
(2) Date of service of Plaintiff's Affidavit upon
Defendant: N/A
4. Related claims pending: No claims were raised of record.
5. Indicate date and manner of service of the notice of
intention to file praecipe to transmit record, and attach a copy of
said notice under section 3301(d)(1)(i) of the Divorce Code: N/A
fi:~~Ll~)jt~
Attorney For Plaintiff
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Theresa Barrett Male
Supreme Court #46439
10 South Market Square
Suite 500
Harrisburg, PA 17101
(717) 233-3220
Attorney For Plaintiff
MARGARET H. SMITH,
Plaintiff
.
.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
NO. 9~5
civil 1994
v.
IRA F. SMITH,
Defendant
.
.
CIVIL ACTION - DIVORCE
NOTICB TO DBFBND 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, South Hanover Street,
Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER I 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.
Court Administrator
Cumberland County Courthouse - 4th Floor
'1 Courthouse Square
CarliSle, PA 17013-3387
(717) 240-6200
Theresa Barrett Hale
Supreme Court #46439
10 South Harket Square
suite 500
Harrisburg, PA 17101
(717) 233-3220
Attorney For Plaintiff
MARGARET H. SMITH,
Plaintiff
.
.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
:
v.
.
.
NO.
civil 1994
.
.
IRA F. SMITH,
Defendant
.
.
.
.
CIVIL ACTION - DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Margaret H. Smith, who currently resides at
410 Allegheny Drive, Mechanicsburg, Cumberland County, Pennsylvania
17055.
2. Defendant is Ira F. Smith, who currently resides at 410
Allegheny Drive, Mechanicsburg, Cumberland County, Pennsylvania
17055.
3. Plaintiff and Defendant 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 28, 1976.
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.
WHBRBFORB, Plaintiff requests the court to enter a Decree in
Divorce.
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Theresa Barrett Male, Esquire
Supreme Court #46439
10 South Market Sq., suite 500
Harrisburg, Pennsylvania 17101
(717) 233-3220
Attorney For Plaintiff
Date: 2/25/94
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VERIFICATION
I, Margaret H. smith, state upon personal knowledge or
information and belief that the averments set forth in the
foregoing document are true.
I understand that false statements herein are made subject to
the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsifica-
tion to authorities.
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Margar H. smith
Date: .<'/-<.5/11-
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Theresa Barrett Male
Supreme Court 146439
10 South Market Square
suite 500
Harrisburg, PA 17101
(717) 233-3220
Attorney For plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 965 civil 1994
MARGARET H. SMITH,
Plaintiff
.
.
.
.
IRA F. SMITH,
Defendant
.
.
CIVIL ACTION - DIVORCE
VERIPICATION OP SERVICE BY MAIL
I verify that, on March 1, 1994, I mailed a certified copy of
the complaint In Divorce filed in the above-referenced action by
certified mail, restricted delivery, return receipt requested to
Defendant Ira F. Smith at 410 Allegheny Drive, Mechanicsburg, PA
17055.
Defendant acknowledged receipt on March 11, 1994, as
evidenced by the return receipt card attached as Exhibit "A".
I further verify that the above statements are true and
correct.
I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn
falsification to authorities.
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Theresa Barrett Male, Esquire
supreme Court #46439
10 South Market sq. - suite 500
Harrisburg, Pennsylvania 17101
(717) 233-3220
Attorney for Plaintiff
Date: March 14, 1994
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_ DOMES~I~ RETU~~'~~E.'W;fI
BXHIBIT "A"
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Theresa Barrett Hale
Supreme Court #46439
10 South Harket Square
Suite SOD
Harrisburg, PA 17101
(717) 233-3220
Attorney For Plaintiff
MARGARET H. SMITH,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 965 Civil 1994
v.
IRA F. SMITH,
Defendant
CIVIL ACTION - DIVORCE
AFPIDAVIT OP CONSENT
1. A Complaint in Divorce under section 3301(c) of the
Divorce Code was filed on February 28, 1994/;
2. The marriage of plaintiff and defendant is irretrievably
broken and ninety days have elapsed from the date of filing the
Complaint.
3. I consent to the entry of a final decree of divorce.
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.
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. S 4904 relating to unsworn
falsification to authorities.
Date: -!tJ>oo.. .J 8, Iljtj.f.
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Marg et H. Smith
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Theresa Barrett Male
Supreme Court #46439
10 South Market Square
Suite 500
Harrisburg, PA 17101
(717) 233-3220
Attorney For Plaintiff
MARGARET H. SMITH,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 965 Civil 1994
.
.
IRA F. SMITH,
Defendant
.
.
CIVIL ACTION - DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under section 3301(c) of the
Divorce Code was filed on February 28, 1994/;
2. The marriage of plaintiff and defendant is irretrievably
broken and ninety days have elapsed from the date of filing the
Complaint.
3. I consent to the entry of a final decree of divorce.
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.
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. S 4904 relating to unsworn
falsification to authorities.
Date:
/, /21/'11(
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Ira F. sm.tdl
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
MARGARET H. SMITH,
Plaintiff
.
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v.
NO. 965 civil 1994
IRA F. SMITH,
Defendant
CIVIL ACTION - DIVORCE
APPROVED DOMESTIC RELATIONS ORDER
AND NOW, l>larch
z......, 1995, it appearing to the Court that:
1. The parties formerly were husband and wife, and were
divorced from the bonds of matrimony by this court's decree dated
December 23, 1994. A true and correct copy of the certified decree
is attached as Exhibit "A".
2. Pr ior to entry of the divorce decree, the parties entered
into a Memorandum of Understanding, pursuant to which they
stipulated to the entry of an approved domestic relations order
distributing husband's State Employes' Retirement System pension
benefits. A true and correct copy of the StipUlation for Entry of
"Domestic Relations Order" is attached as Exhibit "B" and is
incorporated herein by reference.
3. Defendant Ira F. Smith (hereinafter referred to as
"Member") is a member of the Commonwealth of Pennsylvania, State
Employes' Retirement System (hereinafter 'referred to as "SERS").
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Member's date of birth is December 22, 1941. His Social Security
number is 189-32-7509.
4. SERS, as a creature of statute, is controlled by the
State Employes' Retirement Code, 71 Pa. C.S. S S 5101-5956
("Retirement Code").
5. Plaintiff Margaret H. smith (hereinafter referred to as
"Alternate Payee") is the fomer spouse of Member.
Alternate
Payee's date of birth is August 29, 1949. Her Social Security
number is 108-38-9411.
6. Member's current and last-known address is: 410 Alle-
gheny Drive, Mechanicsburg, PA 17055.
7. Alternate Payee's current and last-known address is: 482
Brighton Place, Mechanicsburg, PA 17055. It is the responsibility
of Alternate Payee to keep a current mailing address on file with
SERS at all times.
IT IS ORDBRBD, ADJUDGBD AND DBCRBBD AS POLLOWS:
1. The Alternate Payee's share (also known as the equitable
distribution portion) of Member's retirement benefit is as follows:
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Age (last birthday)
of Member
Lump Sum Amount
pavable to Alternate Pavee
Before Age 60
$68,000 discounted with
interest at the rate of
4% per annum compounded
annually
$68,000
$71,000
$74,000
$77,000
$80,000
$83,000
$83,000 accumulated with
interest at the rate of
4% per annum compounded
annually
Alternate Payee's lump sum amount is to be based upon the
Member's age as of his last birthday plus completed months since
his last birthday. For example, if on the date of Member's death
before his retirement benefits commenced or on the date his
retirement benefits commence, Member was age 60 on his last
birthday and if at least six but less than seven months lapsed
since his 60th birthday, the lump sum payable to the Alternate
Payee would be $69,500 ($68,000 + 7/12 [$71,000-$68,000]).
60
61
62
63
64
65
After Age 65
2. Member's retirement benefit is defined as all monies paid
to or on behalf of Member of SERS, including any lump sum withdraw-
als or scheduled or ad hoc increases, but excluding the disability
portion of any disability annuities paid to Member by SERS or any
deferred compensation benefits paid to Member by SERS. The
equitable distribution portion of the marital property component of
Member's retirement benefit, as set forth in Paragraph Seven, shall
be payable to alternate Payee and shall commence as soon as
administratively feasible on or about the date the Member actually
enters pay status and SERS approves a Domestic Relations Order
incorporating these terms, whichever is later.
3
3. Member shall nominate Alternate Payee as a beneficiary to
the extent of Alternate payee's equitable distribution portion in
Member's retirement benefit for any death benefits payable by SERS.
In addition, Member shall execute and deliver to Alternate Payee an
authorization, in a form acceptable to SERS, which will authorize
SERS to release to Alternate Payee all information concerning
Member's retirement account including but not limited to Member's
current Nomination of Beneficiaries form for death benefits.
Alternate Payee shall deliver the authorization to SERS which will
allow the Alternate Payee to check that she has been and continues
to be properly nominated under this paragraph.
4. The term and accounts of Member's retirement benef its
payable to the Alternate payee after SERS approves a Domestic
Relations Order is dependent upon which option(s) is (are) selected
by Member upon retirement. Member and Alternate Payee expressly
agree that, at the time that the Member files a retirement
application with SERS, the Member:
a) Shall elect to receive all of his accumulated
deductions, and
b) May elect any option offered by the SERS based upon
the balance of his retirement benefits (the Member's
retirement benefits less the refund of all his accumu-
lated deductions under paragraph 4a).
5. Alternate Payee may not exercise any right, privilege or
option offered by SERS. SERS shall issue individual tax forms to
Member and Alternate Payee for amounts paid to each.
6. If the Member becomes disabled and receives a disability
retirement benefits from SERS, the Alternate Payee's share of the
Member's disability retirement benefits shall be paid to the
Alternate Payee during the Member's lifetime, by deduction $500.00
4
from the early retirement portion of the Member's monthly disabili-
ty retirement benefit and paying this amount to the Alternate Payee
until and only until the Alternate Payee's share as defined in
Paragraph Seven has been fully paid.
7. If the Alternate Payee dies prior to receipt of all of
her payments payable to her from SERS under this Order, any death
benefit or retirement benefit payable to Alternate Payee by SERS
shall be paid to Alternate Payee's Estate to the extent of
Alternate Payee's equitable distribution portion of Member's
retirement benefit as set forth in Paragraph Seven.
8. In no event shall Alternate Payee have greater benefits
or rights other than those which are available to member.
Alternate Payee is not entitled to any benefit no otherwise
provided by SERS. The Alternate Payee is only entitled to the
specific benefits offered by SERS as provided in this Order. All
other rights, privileges and options offered by SERS not granted to
Alternate Payee by this Order are preserved for Member.
9. It is specifically interested that this Order does not
require SERS to provide any type or form of benefit, or any option
not otherwise provided under the Retirement Code.
10. This Court shall retain jurisdiction to amend this
Domestic Relations Order, but only for purpose of establishing it
or maintaining it as a Domestic Relations Order; provided, however,
that no such amendment shall require SERS to provide any type or
form of benefit, or any option not otherwise provided by SERS, and
further provided that no such amendment or right of the Court to so
amend will invalidate this existing Order.
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11. Upon entry, a certified copy of the Domestic Relations
Order andy any attendant documents shall be served upon SERS
immediately. The Domestic Relations Order shall take effect
immediately upon SERS approval and SERS approval of any attendant
documents and then shall remain in effect until further Order of
the Court.
BY THE COURT:
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
tt-
STATE OF . PENNA,
MARGARET H. SMITH,
plaintiff
VCI',<US
IRA F. SMITH,
Defendant
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965 CIVIL (94
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DECREE IN
DIVORCE
AND NOW. .. ~~, ?~!, ......... .., " 19 ..9~. ... it is ordered and
Margaret H. Smith, I ' .
decreed that """"""""",."""""",.",."""",,'. p amtlff,
Ira F. Smith,
and, ""."""", ,.""""" """""., ""','," """'" defendant,
are divorced from the bonds of matrimony.
The court retains iurisdiction of the following claims which have
been roised of record in this action for which a final order has not yet
been entered;
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Dy Th.. Court:
/5/ Kevin A. Hess
p. ... '" .
AlIesl: Lclwrence E. Welker. Prothonotcu:y
: ',~~;:'~
Deputy Prnlhonolnry
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-
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Mnrvnrot H. Smith
Plaintiff
FAMILY DIVISION
NO, 965 Civil 1994
vs,
Ira F. Smith
Defendant
IN DIVORCE
STIPULATION FOR THE ENTRY OF "DOMESTIC RELATIONS ORDER"
AND NOW, this day of , 19_, the parties, Margaret H,
Smith, Plaintiff, and Ira F, Smith, Defendant, do hereby Agree and Stipulate as follows:
1, The Defendant, Ira F, Smith (hereinafter referred to as "Member") is a member of
the Commonwealth of Pennsylvania, State Employes' Retirement System (hereinafter referred
to as "SERS"),
2, SERS, as a creature of statute, is controlled by the State Employes' Retirement
Code, 71 Pa, C,S, ~~5101-5956 ("Retirement Code"O,
3, Member's date of birth is December 22, 1941, and his Social Security number is
189-32-7509,
4, The Plaintiff, Margaret H, Smith (hereinafter referred to as "Alternate Payee") is
the former spouse of Member, Alternate Payee's date of birth is August 29, 1949, and her
Social Security number is 108-38-9411,
5, Member's last known mailing address in:
410 Allegheny Drive
Mechanicsburg, PA 17055
6, Alternate Payee's current mailing address is:
III
482 Brighton Place
Mechanicsburg. PA 17055
It is the responsibility of Alternate Pnyee to keep n current mlliling address on file
with SEHS lit 1111 times,
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7, The Alternate Payee's share (also known as the equitable distribution portion) of
the Member's retirement benefit is as follows:
Age (\ast birthday)
of Member
Lump Sum Amount
Pavable to Alternate Payee
00
61
62
63
64
65
After Age 65
$68,000 discounted with interest
at the rate of 4% per annum
compounded annually
$68,000
$71,000
$74,000
$77,000
$80.000
$83,000
$83,000 accumulated with interest
at the rate of 4% per annum
compounded annually
Before Age 60
Alternate Payee's lump sum amount is to be based upon the Member's age as of
his last birthday plus completed months since his last birthday, For example, if on the date of
Member's death before his retirement benefits commenced or on the date his retirement
benefits commence, Member was age 60 on his last birthday and if at least six but less than
seven months lapsed since his 60th birthday, the lump sum payable to the Alternate Payee
would be $69,500 ($68,000 + 6/12 [$71,000 - $68,000)),
8, Member's retirement benefit is defined as all monies paid to or on behalf of
Member by SERS, including any lump sum withdrawals or scheduled or ad hoc increases, but
excluding the disability portion of any disability annuities paid to Member by SERS or any
deferred compensation benefits paid to Member by SERS, The equitable distribution portion of
the marital property component of Member's retirement benefit, as set forth in Paragraph
Seven, shall be payable to Alternate Payee and shall commence as soon as administratively
feasible on or about the date the Member actually enters pay status and SERS approves a
Domestic Relations Order incorporating this Stipulation and Agreement, whichever is later,
9, Member shall nominate Alternate Payee as a beneficiary to the extent of Alternate
Payee's equitable distribution portion in Member's retirement benefit for any death benefits
payable by SERS, In addition, Member shall execute and deliver to Alternate Payee an
authorization, in a form acceptable to SERS, which will authorize SERS to release to Alternate
Payee all information concerning Member's retirement account including but not limited to
Member's current Nomination of Beneficiaries form for death benefits, Alternate Payee shall
deliver the authorization to SERS which will allow the Alternate Payee to check that she has
Imen and continues to be JlroJlerly nominated under this pllra~rnph,
10, The term and accounts of Member's retirement benefits payable to the Alternate
Payee after SERS approves a Domestic Relations Order incorporating this Stipulation and
Agreement is dependent upon which option(s) is (are) selected by Member upon retirement,
Member and Alternate Payee expressly agree that. at the time that the Member liles a
retirement application with SERS, the Member:
a. Shall elect to receive all of his accumulated deductions, and
b, May elect any option offered by the SERS based upon the balance of his
retirement benefits (the Member's retirement benefit less the refund of all his
accumulated deductions under Paragraph lOa),
The Alternate Payee shall be paid her equitable distribution portion in accordance
with Paragraph Seven out of the accumulated deductions under Paragraph lOa.
11. Alternate Payee may not exercise any right, privilege or option offered by SERS,
SERS shall issue individual tax forms to Member and Alternate Payee for amounts paid to
each,
12, The Member and Alternate Payee agree that if the Member becomes disabled and
receives a disability retirement benefit from SERS, the Alternate Payee's share of the
Member's disability retirement benefits shall be paid to the Alternate Payee during the
Member's lifetime, by deducting $500,00 from the earlv retirement Dortion of the Member's
monthly disability retirement benefit and paying this amount to the Alternate Payee until and
only until the Alternate Payee's share as defined in Paragraph Seven has been fully paid,
13, In the event of the death of Alternate Payee prior to receipt of all of her payments
payable te her from SERS under this Order, any death benefit or retirement benefit payable to
Alternate Payee by SERS shall be paid to Alternate Payee's Estate te the extent of Alternate
Payee's equitable distribution portion of Member's retirement benefit as set forth in Paragraph
Seven,
14, In no event shall Alternate Payee have greater benefits or rights other than those
which are available to member, Alternate Payee is not entitled to any benefit not otherwise
provided by SERS, The Alternate Payee is only entitled to the specific benefits offered by SERS
as provided in this Order, All other rights, privileges and options offered by SERS not granted
to Alternate Payee by this Order are preserved for Member,
15, It is specifically intended and agreed by the parties hereto that this Order docs not
require SERS to provide any type or form of benefit, or any option not otherwise provided under
the Retirement Code,
16, The parties intend and agree that the terms of this Stipulation and Agreement
shall be approved, adopted and entered as a Domestic Relations Order,
17, The Court of Common Pleas of Cumberland County, Pennsylvania, shall retain
jurisdiction to amend any Domestic Relations Order incorporating this Stipulation and
Agreement, but only for the purpose of establishing it or maintaining it as a Domestic
Relations Order; provided, however, that no such amendment shall require SERS to provide
any type or form of benefit, or any option not otherwise provided by SERB, and further provided
that no such amendment or right of the Court to so amend will invalidate this existing Order,
18, Upon entry as a Domestic Relations Order, a certified copy of the Domestic
Relations Order and this Stipulation and Agreement and any attendant documents shall be
served upon SERB immediately, The Domestic Relations order shall take effect immediately
upon SERB approval and SERB approval of any attendant documents and then shall remain in
effect until further Order of the Court,
WHEREFORE, the parties, intending to be legally bound by the terms of this Stipulation
and Agreement, do hereunto place their hands and seals,
BY THE COURT
CONSENTED TO:
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