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HomeMy WebLinkAbout94-01023 -5 V) Q) 3 ~ Qj 3 4 \~ ~....... -.,...,.,.... . Law Offices of Craig A. Diehl 3464 Trindle Road Camp Hill, Pennsylvania 17011 Telephone (7171 763.7613 Telecopier (7171 763.8293 Craig A, Diehl, Esquire, C,P,A, Thomas J. Rounan, Esquire Jeffrey C, Goss, Esquire In Spring Grove, Pennsylvania 119 West Hanover Road Spring Grove, P A 17362 Telepbone: (7171 225-1929 August 19, 1997 The Honorable Kevin A, Hess Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Re: Welsch v. Welsch CivU Acdon 94-1023 Dear Judge Hess: Please be advised that I am in receipt of your letter dated August 18, 1997, wherein you made note that I have yet to appear in this action. Let me apologize for my lack of appearance, as I had taken over this case from a previous Attorney from our finn who had made an appearance in the custody action, but not the divorce action. I have enclosed a copy of the appearance I have just filed with the Prothonotary, along with the simultaneous withdrawal of Carl Wass, previous counsel. With respect to the QDRO, I am under the impression from my client, Karen Welsh, Defendant, that she had never acceded to the initial QDRO. I am in the midst of attempting to confinn this fact against the court record, Currently, I have ceased correspondence with Plaintiff until I have confinnation that the initial attorney handling his divorce action has withdrawn. Therefore, it may be some time before we resolve this matter between the two parties, Again, I apologize for any inconvenience and will forward you an amended QDRO when the two parties have come to an Agreement. If you have any infonnation regarding my client's acceding to the initial QDRO, please forward me the same or call me at our Camp Hill office, Thank You, Page 1Wo. Judge Kevin A, Hess August 19. 1997 If you have any further questions or concerns please do not hesitate to call me at our Camp Hill Office, JCG:py Enclosures COMMONWEALTH OF PENNSYLVANIA COURTHOUSE , COURTHOUSE SOUARE CARLISLE, PA 17013 KEVIN A. HESS JUDOE (717) 240,6296 August 18, 1997 Jeffrey C. Goss, Esquire 3464 Trindle Road Camp Hill, PA 17011 Re: Welsch v, Welsch Dear Mr, Goss: The Prothonotary has forwarded to me your recent correspondence proposing the entry of an amended Qualified Domestic Relations Order, Your proposed order purportedly corrects certain discrepancies in the QDRO initially entered on September 6, 1996, In looking through the divorce file, I was unable to find when you had entered your appearance on behalf of a party to this action, Your letter inferred that the amended QDRO is being proposed by the defendant. I did not, however, see any indication that the entry of the order had been acceded to by the plaintiff. Provided I have some evidence that both parties agree, I will be happy to sign the proposed amended order. Very truly yours, ~ . /i. ;-1.. KAHlrlm KAREN R. WELSCH, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. JEFFREY K. WELSCH, Defendant NO. 1023 - 1994 CIVIL ACTION - DIVORCE NOTICE OF ENTRY OF APPEARANCE TO THE COURT: Please enter my appearance on behalf of Plaintiff. Koren R, Welsch in the above-captioned matter, Respectfully submitted, LAW OFFICES OF CRAIG A. DIEHL AVol/.,r 1"/ ,QQ1 (717) 763-7613 vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 94-1023 CIVIL ACTION - LAW JEFFREY KENT WELSCH, Plaintiff KAREN RUTH WELSCH, Defendant PRAECIPE TO THE PROTHONOTARY: Please withdraw my appearance on behalf of the Defendant in the above matter. Date: ~~~\ ,qq,i CALDWELL & KEARNS By "'" > Q ,~ J:"^-,, Carl G. Wass, Esquire 3631 North Front Street Harrisburg, PA 17110 (7171 232-7661 I.D. #07268 Attorney for Defendant KAREN R. WELSCH, Plaintiff I IN THE COURT OP COMMON PLEAS OP CUMBBRLAND COUNTY, PENNSYLVANIA VB. JEPPREY X. WELSCH, Defendant . . NO. 1023 - 1994 I I CIVIL ACTION - DIVORCB CBRTIPICATB OP SBRVICB The undersigned hereby certifies that on the date hereof, a copy of the foregoing "Notice of Entry of Appearance" and Praecipe for withdrawal of appearance for Carl Wass were served on all parties of interest by way of United States mail, first class, postage prepaid, addressed as follows: Jeffrey K. Welsch/Counsel 521 57th Street Altoona, PA 16602 Date: A\JG\Joc;r 19 ,QCf1 I By: Gss- e C. Goss, Esquire. FFICES OF CRAIG A. DIEHL Trindle Road Camp Hill, PA 17011 (7171 763-7613 ..... .. ~ 11') b c::: Q .. z ") ~Q ..:r ?)~ .~ '~.J~.~ ~~ .... t-') ::} n .~. ..... ~. 0 " - I c-~~ N -. ".'; ...'. -., ~ '...' :- u:l'! - . " :11) f.':: Ci ~..r~u. u. ..., .... :..> o. c~ U . . vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 1023 Civil 1994 JEFFREY KENT WELSCH, Plaintiff KAREN RUTH WELSCH, Defendant DIVORCE ENTRY OP APPEARANCE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please enter my Appearance on behalf of Defendant, Karen Ruth Welsch, in the above-captioned matter. By: Carl G. Wass, Esquire Attorney I.D. 07268 3631 North Front Street Harrisburg, PA 17110 (7171 232-7661 Attorney for Defendant Karen Ruth Welsch Dated: \Jl\.~J.O. ~ ( I ,q 91 28136 f$"'~~~''''~~ " ""I'f. ......'--il'.,~N>1'!~~ f,Y'~~".1~'~i'~'"'l!' _..._-~ ", "'-j" '<--:; CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing document upon the person (sl in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, Harrisburg, Pennsylvania, with first-class postage prepaid, as follows: Arthur K. Dils, Esquire DILS & DIXON Executive House, Suite #1 101 South Second Street Harrisburg, PA 1710~ Attorney for Plaintiff By: Carl G. Wass, Esquire Attorney I.D. 07268 3631 North Front Street Harrisburg, PA 17110 (7171 232-7661 Attorney for Defendant Karen Ruth Welsch Dated: U"He ,~ I C\ q \of , 28137 ~ en ~ ~'1 N e >->- '"'... 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JEFFREY KENT WELSCH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 1023 Civil, 1994 KAREN RUTH WELSCH, Defendant CIVIL ACTION - LAW IN DIVORCE ORDER OF COURT AND NOW, this Lt ~-t day of f, l:, I v :'J 7 of the within 1995, upon , Peti tion for presentation and consideration Bifurcation, it is hereby Ordered that a hearing shall be held on ~~ 1995 at q:Ob 11 .M. '-rn~ , thef~ day of in Courtroom No. :r- , of the Cumberland County Carlisle, Court House, One Court House Square, Pennsylvania 17013, where it is Ordered the Respondent, Karen Ruth Welsch, shall appear and show cause why, if any, the Petition for Bifurcation shall not be granted. serrvice 01 the within hearing date may be made upon () rU..:)d Attorney on behalf of the Respondent, Karen Ruth Welsch. " ~l BY THE COURT: ~J /fl ~~ ;U ;;;lr'/~ " H' ., f'n 2/ 3 29 PH, '95 r it.l(,'Of"FICE or THt f'?OTIIONOTAr.'t' CUHaE~LANO Cr,IJNTY PEHH$ tL VANIA JEFFREY KENT WELSCH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 1023 Civil, 1994 IN DIVORCE vs. KAREN RUTH WELSCH, Defendant PETITION FOR BIFURCATION AND NOW, this ;I~day of February, 1995, comes the Plaintiff, Jeffrey Kent Welsch, and respectfully requests the following: 1. Your Petitioner, Jeffrey Kent Welsch, is the Plaintiff in the above captioned divorce action, and is represented by Attorney Arthur K. Dils, whose office is located at 101 South Second Street, The Executive House, Suite Ll, Harrisburg, Pennsylvania 17101. 2. The Respondent, Karen Ruth Welsch, is the Defendant in the above captioned divorce action and is represented by Attorney Carl G. Wass, whose office is located at 3631 North Front Street, Harrisburg, pennsylvania 17110. 3. Your Petitioner and the Respondent were married on August 16, 1980 and separated on January 10, 1994. , --- 4. Your Petitioner instituted an action in divorce under the no-fault grounds that the marriage is irretrievably broken. 5. The parties, through their counsel, have attempted to address the economic issues. 6. Support is being paid for the parties' three children in the amount of $220.00 per week and spousal support in the amount $100.00 per week. 7. The parties own no real estate and your Petitioner has a pension and other retirement benefits and full disclosure has been furnished to counsel for the Respondent, Carl G. Wass, Esquire. 8. All issues of personal property have basically been resolved in that the wife has obtained all the personal property which she desires, except for some musical recordings. 9. The wife I s Attorney through a letter, requested a settlement; see copy of said letter dated December 12, 1994 which is attached hereto and made apart hereof and marked Exhibit "A". -2- -.- ~~-~-~.- 10. Your Petitioner and his Attorney believe that there has been a full and complete settlement in that an acceptance has been made basically to the offer of settlement. See copy of letter dated December 29, 1994 attached hereto and marked Exhibit "Bit. 11. Since the letter of acceptance has been communicated to the wife's Attorney, there has been no action taken to finalize the divorce. 12. Your Petitioner, through this Petition, avers that he is being held economic captive and there is no reason why there should not be a bifurcation of the proceedings. 13. The continued stagnation of this action and the fact that it has not been finalized has worked a detrimental hardship upon the emotional life and general well being of your Petitioner. Your Petitioner is in a position that he deals with serious matters involving his parishioners and must have the ability to have his life on an even keel so that he can be a benefit and service to his parishioners and others. WHEREFORE, your Petitioner prays Your Honorable Court to grant a bifurcation of the divorce action permitting the -3- ,"-"""";"" divorce to become finalized at this time, and the economic issues to be resolved at a later time, and further, to Order that the Support Order entered to No. 195 of 1994, DR 22,378 remain in full force and effect. Respectfully submitted, DILS & ON BY: 1 _ ~~~~ hur K. Di s, Esquire 101 South Second Street Executive House, Ste. L1 Harrisburg, PA 17101 (7171 232-9724 I.D. No. 07056 -4- CAI.OWEI.I. & KEARNS lit PNO' l ~!:aIOHAL (.O""UHII., ION t HO"'''5 0 CALDWELL..IR RICHARD L KCARNS CARL a WA55 .JANtt. R CLIPPINGtH CHARLES... DittA"'. III .JAM[S 0 CAMflOtLl....N .JAMes L GOl.D5MITH "MontY I. MAR" .J.UoH.!. 0 HtAlON, III MAT THEW A COytR prOONAH A CAVAelHI TIMOTHY W ROMO'_AG[H ATTORNEYS AT LAW 30.31 NORTtI fRONT !;offl[[1 HARRISBURG, PENNSYLVANIA 17110-1533 111 ~3l 7661 'A.., '17.I.JZ.Z7t)6 December 12, 1994 " I \1 L l " ,\1 I ' U, v Arthur K. Dils, Esquire Oils & Dixon Executive House, Suite #1 101 South Second Street Harrisburg, PA 17101 Re: Jeffrey K. Welsch vs. Karen R. Welsch Dear Art: I have met with Mrs. Welsch and have discussed with her, in depth, her position with regard to the divorce action filed by her husband, her economic needs, the economic capability of her husband, the "contributions made by either" to the marriage, etc., etc., etc. The bottom line is that my client will be amenable to signing a Consent to have a divorce entered; however, she insists upon the provision of certain economic security for herself and the children of the parties. Mrs. Welsch will be willing to sign an Affidavit of Consent if the two parties enter into a Marriage Settlement Agreement which will include the items, separately numbered, and set forth hereafter. 1. The pension and benefit plan accounts of Jeffrey Welsch, based upon the status of those accounts as of June 30, 1994 (highlighted copy enclosed I , is to be allocated equally between the parties, as follows: (al The personal contributions and salarv reduction contributions totaling $26,696, shall be divided equally, into two separate accounts, one for Karen, one for Jeffrey. Either party will then be free to maintain his or her account as a retirement account, or remove the money (with penalty) as each sees fit _ This can De accomplished by a QDRO. (bl By means of the same QDRO, applicable to the penSion contributions provided by the Church, both prior to and subsequent to January 1, 1982, there will be established Exhibit "A" , . ,_..""""......_~~"- Arthur K. Oils, Esquire Page 2 December 12, 1994 a division of the payment of the retirement benefits, based on the coverture fraction, at the time of Jeffrey's retirement. The coverture fraction of the entirety of the retirement benefit will be established, and sot of the amount represented by the coverture fraction is to be paid to Karen (or, if she predeceases Jeffrey, the lump sum represented by her coverture fraction is to be paid to her beneficiaries). There is to be an irrevocable designation of a joint and survivor annuity in order to protection Karen's interest in the event of the death of Jeffrey prior to retirement. 2. We request that Jeffrey provide medical and hospitalization insurance for the benefit of Karen for a period of three years following divorce or, if su~oner occurs, until Karen is awarded a permanent professional teaching contract which provides the medical and hospitalization coverage to her at no cost. In the alternative, if Jeffrey pays to Karen, upon the entry of a Divorce Decree, the sum of $6,000, she will waive her claim for medical coverage and will secure her own coverage. 3. Karen desires to have alimony paid to her at the sum of $100 per week for a period of three years following the entry of the Divorce Decree (the $100 per week is the same as the present Order of Support).,.. v~.\,\ 1.'\ \"" :'~ 4. The Order for the support of the children has been established and no change is proposed. However, with regard to the matter of claiming the children as exemptions for 1994, Karen will agree that Jeffrey may claim the two older children; she will claim Andrea. 5. If either of the parties shold die before all of the children attain adulthood, the survivor I of course, would be the guardian of the minor children. However, in the event of the deaths of both of the parties while any of the children are still minors, Karen would desire a provision in the Agreement which provides that her sister, Donna Kulinski, shall be the guardian of those minor children. 6. The two jointly-owned automobiles are to be transferred: The 1986 Chevrolet Celebrity to Karen, The 1988 Dodge Colt to Jeffrey. Arthur K. Oils, Esquire Page 3 December 12, 1994 7. There exists a Nationwide Life Insurance Company universal life policy upon the life of husband. In order to assure that sufficient assets are available for the support of the children in the event of Jeffrey's untimely death, we insist that Jeffrey establish a trust agreement, name a corporate trustee of his choice, and provide in that trust agreement that the trust monies shall be utilized to provide for the health, comfort, support, education and well-being of his children, until the youngest of those children has attained the age of 23 years. The trust would be funded in three fashions: (a) The trustee would be named the irrevocable beneficiary of the proceeds of the Nationwide Life Insurance Company universal life policy, and (b) The three certificates of deposit held by the Central Pennsylvania Conference of the United Methodist Church, in which one or the other of our clients is named the custodian for one or more of the children, shall be retitled in the name of the trustee and held in accordance with the terms of that trust, i.e., for the benefit of the children, and (c) The trustee would also be named the irrevocable beneficiary of the proceeds of the term life insurance policy maintained upon Jeffrey's life by the Central Pennsylvania Conference. The trust agreement would contain a provision that any funds remaining in the trust after the youngest child attains 23 years of age would be paid equally to the three children. Apart from the trust, and for the benefit of the children, there is to be a contingent beneficiary designation upon the Nationwide policy and the Conference term policy which would provide that the proceeds of the policies, in the event Jeffrey dies after the youngest child attains 23 years, would be paid directly and equally to the three children. 8. For the most part, each party will retain whatever personal property he or she may presently have in his or her possession. However, Karen does desire to have the items of personal property identified on the attached list entitled "Karen's Property." In addition, for a period of one year ,.,'- Arthur K. Oils, Esquire Page 4 December 12, 1994 following the divorce, Jeffrey will continue to store the car roof carrier and Karen's exercise bicycle. 9. Jeffrey is to turn over to Karen approximately 15 video tapes depicting the family history and growth of the children so that Karen may copy them, after which she will return the originals to Jeffrey. Further, as to any musical recordings and tapes which the parties do not agree are to be turned over to Karen as her property shall, nevertheless, be temporarily turned over to Karen so that she may make copies of them as well, after which, she will return the originals back to Jeffrey. Please consider this proposal with your client and let me know if he is agreeable to this proposal. If so, I will take the responsibility of drafting a Marriage Settlement Agreement for your review. Very truly yours, ~..- Carl G. Wass ...... CALDWELL & KEARNS CGW:1f Encls. cc: Karen R. Welsch G:\DATA\CGW\01371\9387\20922.1 ,to. ..._-.- l"".;,"_._" ~:r~-:' ~;r::': ,. . Decembe~ 2~, 1994 carlO. w.s., Esquire 3631 Nortb .ront street Hudsburg, PA 17110-1533 RBI Jeffrey K. Welsch v. Xaren R. Welech No. 1023 CiVil, 19~4 Dear C.rll Your letter of Decelllber 12, 1~94 18 baeicallyagre.able. W. .re working out tbe bealth coverage. It mey well be tbat _ will .ek you to accept $2,000.00 pel' year, in.t..d of a $6,000.00 lUlllp 8U111 paYlll8nt. If you want to proceed with the preparetion of a Property Settlement Agreement, putting in tbe flexibility of the $6,000.00 paYlll8nt .s inetaU.ent payaent. of $2,000.00 eaCh, JeU wUl .ign it. Very truly youre, Arthur K. DUe AKOlkjll I . i Exhibit "B" . VERIFICATION I verity that the statements made in this Bifurcation Petition for are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. ~4904, relating to unsworn fals fication to Dat.d, dH'15 1 i '1 I 'i i . . CERTIFICATE OF SERVICE I, Arthur K. Oils, Esquire, hereby certify that a true and correct copy of the Petition for Bifurcation has been served upon the following individual, on this/~;5day of February, 1995, by depositing said copy at the Post Office at Harrisburg, Pennsylvania, First Class Mail, postage pre-paid, addressed as follows: Carl G. Wass, Esquire 3631 North Front street Harrisburg, PA 17110-1533 ~~,r. 101 South Second street Executive House, Ste.L1 Harrisburg, PA 17101 (717) 232-9724 I.D. No. 07056 BY: Date: February 13, 1995 .~ .~ Iv,. ~"'l .a.~ '1 . ~ }. .~~ ~J ~ < H <> (.:l..:l Z ..:l>< 0 "'Ul H Z :I: E-< ZZ.... U < ;; O~'" III :I: u t;E :E"'''' ..:l u g; .i :E ... (.:l ..:l ~ w~ ~- 0 ~ ~ III ~ t;!l~ u>< ~ (.:l H ~ ~ E-tr-i E-t ~ III ~Z''''' Z . E .wSlI 00> (.:l In :I: ~ 'II> ~~i~ 0..... :.: > E-t 0 ~ ~ E-tUU 0 ~ s ~ >< ~ I:l !5 oeM (.:l Z _II OZN ~ Z 0 0- _c u<o ~ ~ H i ..:l... ~ ~ E-< (.:l~ (.:l < H :I:(.:l I':l :.: E-t E-tlll (.:l :E . '" zoo HUZ , J .. .. FEB 1 r.. 1(;'1" 1.1. \( ~rt'1'\ R.. Wl'ISc ~ 11"1 tllr- [(;1.<'''''' r- (.p,..,.,..p,., P"~ G..."" ~t"-rl...."cl {""JIlf Cfh\ .:r....JiC.iC.J O.-s+ric..i-- .. ',. :::rc->f-r.lr-y t.. Wp I St ~ (I) N17. 91./ - 1rY:J 3. QUALIFIED DOMESTIC RELATIONS ORDER This cause coming on for hearing pursuant to the law of this State governing the division of marital propeny incident to the dissolution of marriage (divorce), the Coun, being fully advised in the premises, FINDS: A. (1) ::rffl~'t ,k. ~~ ~ (the "Panicipant") is enrolled in the Ministerial Pension Plan ("MPP") administered by THE BOARD OF PENSIONS OF THE UNITED METIlODIST CHURCH, INCORPORATED IN ILLINOIS (the "Board"), the address of which is 1201 Davis Street, Evanston, llIinois 60201. The Board is the operational ann of the General Board of Pension and Health Benefits, an administrative general agency of The United Methodist Church. The Panicipant has an account balance, a right to receive benefits, allocated funding or an aMuity (collectively, "Pension Benefits") in, or arising from, one or more of the following pension accounts: MPPIIIIDI93 .. .. .' e' ~,\ ;:i)-O~f'\c.::' ~ ' _ \,17_",.-....,..:!""I,.,'r\\1?3 O~ ','" \.... :',' ' (\. ' oC <,Cn ~G '(,\ ;,: \:;: :,J"l ~\.\ . ,.-.' , ,. " CIS;":.'.... . ;.;,"" .,..,,' "':\' , ' .,) rC"~I",j,\,o.1 ~ ..'" I: I; , . ! ~ t:. ". Qualified Domestic Relations Order Page 2 (I) The "Pre-1982 Service Benefit," which represents the benefit provided by each applicable Annual Conference through Supplement One ofMPP, being the greater of (a) the Participant's pre-1982 service annuity accumulation (i.e., pre-1982 church contributions and accumulated earnings thereon), and, if the applicable annual conference requires pre-1982 personal contributions to be used as funding for the pre-1982 service benefit, the Participant's pre-1982 personal contributions accumulation (i.e., pre-I 982 personal contributions and accumulated earnings thereon); or (b) the Participant's Fonnula Benefit. The Fonnula Benefit is a benefit based upon a Panicipant's number of years ofpre-1982 service with pension credit and the pension rates established each year by the applicable annual conferences. (2) The "Church Account," which consists of contributions made by a church or employer to the credit of the Participant after 1981, as adjusted for earnings and losses. (3) The "Personal Account," which consists of after-tax contributions made by the Participant, except pre-1982 contributions which are required by the applicable annual conference to be used as funding for the pre-1982 service benefit, as adjusted for earnings and losses. (4) The "Salary-Reduction Account," which consists of contributions made by IoIPPIOIDI93 ~ Qualified Domcstic Rclations Order Page 3 a church or employer to the credit of the Participant pursuant to a salary- reduction agreement, as adjusted for earnings and losses. (5) The "QVEC Account," which consists of contributions made by the Participant pursuant to Internal Revenue Code ~219(e)(2) as it existed prior to the enactment of the Tax Refonn Act of 1986, as adjusted for earnings and losses. (6) The "Rollover Account," which consists of funds transferred to MPP for the benefit of the Participant, from, or attributable to, another retirement income plan, as adjusted for earnings and losses. B. The Participant's current or last known address is (l) -E /-kMa) PA It; (PO;).. ~J . 57th sf) C. The person to whom the award of Pension Benefits is made herein is (4) ka H!/J R,^ 11, /~(c, ch (the "Alternate Payee"), whose current or last known address is (I) 7/0:3 ~'pm ~rt eli-qF) Hec.f.amcstJu.~.. PI} noS.$" and whose Social Security number is (0) ..J C;'i(' - 'I" - S;JsQ The Alternate Payee is the Participant's: (7) 0 Spouse -etFormer spouse: Date of Divorce - 'f /3/q 5 o Child 0 Other dependent. D. It is in conformity with law and in accordance with the principles of equity that the Alternate Payee be awarded a portion of the Participant's Pension Benefits, as set forth hereinbelow. MPPIOIDI93 .,.,...~,..,-_..., <..,~,,- Qualified Domestic Relations Order Page 4 IT Is THEREFORE ORDERED: A. The Alternate Payee is hereby awarded the following portion of any annuity which the Participant is cu"enlly receiving from the Board in payment of the Participant's Pension Benefits, such award to commence thirty days after the Board's receipt of this Order and to continue in effect for as long as the Participant continues to have the right to receive said annuity: (check one of the following boxes) II) !l(The Participant is not currently receiving an annuity from the Board. I') 0 The Participant is currently receiving an annuity from the Board, but the Alternate Payee is awarded no part thereof. (101 0 $ per monthly payment, without increase or decrease; III) 0 $ per annual payment, without increase or decrease; II2lD percent of each monthly payment otherwise payable to the Participant, as said amount may increase or decrease from time to time in accordance with the provisions of the Ministerial Pension Plan. B. The Alternate Payee is hereby awarded (U) l)o~ percent of the Participant's Pre-1982 Service Benefit in the Ministerial Pension Plan, effective (14)_ ~, 19~ (the "Date of Division"), to be calculated, valued, and divided as of that date. At all times after said transfer is made: (a) The Alternate Payee shall have no further claim to any benefit based on the Participant's Formula Benefit, and (b) The Participant's Pre-1982 Service Benefit shall be reduced by the percentage awarded to the Alternate Payee. MPPIOIOI93 Qualilied Domestic Relations Order Page 5 C. The Altemate Payee is awarded the following Pension Benefits from the Participant's Pension Benefits in the Ministerial Pension Plan, effective (Ill ~r~ \ :; , 19.92- (the "Date of Division"), to be calculated, valued, and divided as of that date: (I) The sum of (16) $ 9 33(" ;9;).. from the Participant's Church Account. (2) The sum of (11) $ from the tax-paid portion of the Participant's Personal Account, to be drawn from the pre-1987 tax-paid portion and the post-1986 tax-paid portion on a pro-rata basis, if applicable. (3) The sum of (II) $ r;.Y7/,3'1 I from the taxable portion of the Participant's Personal Account. The sum of(l91 $ r;, I 5? 7), 't!; from the Participant's Salary-Reduction , (4) Account. (5) The sum of(20) $ (6) The sum of(2I) $ from the Participant's QVEC Account. from the Participant's Rollover Account. D. Pension Benefits hereby awarded to the Alternate Payee from any account which consists of investment in more than one of the Diversified and Special Funds maintained by the Board shall be drawn from each such fund pro-rata. The Alternate Payee shall have the right to change the funds in which such Pension Benefits are invested in accordance with the investment election provisions ofMPP, but no such change shall be effective until the next regular date so provided for implementing investment election changes. MPP/DIDI9l Qualified Domestic Relations Order Page 6 E. If Pension Benefits are hereby awarded to an Alternate Payee from the participant's Pre-1982 Service Benefit, and if on the Date of Division the Participant's balance in that account contained contributions for pre-1982 selVice from more than one annual conference, then the percentage awarded to the Alternate Payee of the Participant's contributions and earnings arising from each such conference shall equal the percentage of the Participant's total Pre-1982 Service Benefit awarded to the Alternate Payee. F. Any transfer from one Diversified or Special Fund to another Diversified or Special Fund which was or is made between the Date of Division and the time of the actual transfer of Pension Benefits to the credit of the Alternate Payee pursuant to this Order shall be deemed to include the Participant's and the Alternate Payee's Pension Benefits therein in shares which are proportionate to their respective interests in the Fund from which the transfer was made immediately prior to the transfer. G. Earnings and losses which accrue after the Date of Division on Pension Benefits hereby awarded to the Alternate Payee shall be allocated to the Alternate Payee. Distributions to the Participant after the Date of Division shall be deemed to be made from Pension Benefits other than those hereby awarded to the A1ternale Payee. H. (I) Neither the Alternate Payee nor any person claiming through the Alternate Payee shall have the right by virtue of this Order to: (a) Make contributions to the Plan(s); (b) Transfer benefits to another alternate payee; (c) Receive a surviving spouse benefit arising from the Participant's pre-1982 service; or MPflOIOl91 Qualified Domestic Relations Order Page 7 (d) Receive Pension Benefits in the fonn ofa joint and survivor annuity with respect to the Alternate Payee and any subsequent spouse. (2) In all other respects the Pension Benefits herein awarded to the Alternate Payee shall be administered in accordance with the Ministerial Pension Plan, as it may be amended from time to time. The Alternate Payee shall have all the rights and duties of a fully vested "tenninated participant" (as that tenn is defined in the Plan), but only for the purpose of determining eligibility to receive benefits. The Participant shall have no claim to Pension Benefits hereby awarded to the Alternate Payee. I. All rights of the Alternate Payee in lhe Ministerial Pension Plan shall be subject to the conditions, restrictions, limitations, and requirements applicable to "terminated participants" as provided by the Plan as it may be amended from time to time, including the non-alienation provisions thereof. J. All Pension Benefits and other rights, benefits, assets and interest in the Participant's P~an not hereby awarded to the Alternate Payee shall be the property of the Participant, to tbe exclusion ofany present or future claim thereto on the part of the Alternate Payee. K. Nothing contained in this Order shall be construed to require the Ministerial Pension Plan or the Board: MPPIOIDI9l " Qualified Domesllc Relallons Order Page 8 (I) To provide any type or fonn of benefit, or any option, not otherwise provided under that Plan; (2) To provide increased benefits (detennined on the basis of actuarial value); or (3) To pay any benefits to the Alternate Payee which are required to be paid to another Alternate Payee under another order previously determined by the Board to be a qualified domestic relations order (uQDROU) as thattenn is defined with respect to church plans by ~4 14(P) of the Internal Revenue Code of 1986. L. The Participant shall promptly execute and deliver to the Board an Assignment of Pension Benefits (using the fonn provided by the Board), assigning to the Alternate Payee the Pension Benefits hereby awarded to lhe Alternate Payee. M. The Alternate Payee shall promptly execute and deliver to the Board an Acceptance of AssiiJIl11le1l1 of Pension Benefits with respect to the assigrunent of Pension Benefits hereby ordered, using the fonn provided by the Board. N. The Board, upon receipt of the AssliJIlme1l1 of Pension Benefits and the Acceptance of Assignment of Pension Benefits, within a reasonable time thereafter which is administratively feasible, shall effect the transfer of benefits contained herein. O. The Participanl and the Alternate Payee shall fully cooperate toward the goal of qualifYing and giving full effect 10 Ihis Order as a QDRO, seeking any amendment hereof as may be necessal)' for thaI purpose. IdPPIOIOI9J ... . ..... - . Qualified Domestic Relations Order Page 9 IT Is So ORDERED, this llJ day of s,..,..~ ,19 fL -J(t.. ,-A/I1- / Presiding Judge MPPIOIDI91 1~.'.r..".4~" _:.:..s.-_..:.-,.. ~ \I) ,.. ~~ .:; , c;, .J." ,. ~~i:~ c', - ~. -r - ._~~j ," .~~:h 0' a- w.... I ~ -.'" -'. -:;? r.: - : ~ c ,,:) r.. ....' ..,~~b- (I, u ,..: () '-'=' :...:.-" o~ u .~ 'll ~~ ~ 0;: i ~ ~ '1 ~ ~ ...... Law Offlces of Craig A. Diehl 3464 Trlndle RCla. Camp Hili, Pennsylvania 17011 4IJS 0 /J Iyn ..'I Telephone (717) 763.7613 Telecopier (717) 763.8293 August 4, 1997 In Spring Grove, Pennsylvania 119 Wesl Hanover Road Spring Grove, P A 17362 Telephone: (717) 225.1929 Craig A. Diebl, Esquire, C.P.A. Thomas J. Rozman, Esquire Jeffrey C. OOSl, Esquire Cumberland County Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Re: Welsch V5. Welsch No. 94-1023 Amended QDRO Dear Prothonotary: Please find enclosed one original and two copies of the amended QDRO in the above captioned case. Also enclosed please find a copy of the Marital Litigation Benefit Statement which states the values of the pension accounts as of the Date of Division. The QDRO initially entered as an Order on September 6, 1996 has several errors which this amended QDRO corrects. The original order had April 3, 1995 as the Date of Division. The actual Date of Division as per the Separation Agreement is June 30, 1994, Furthennore, the original order split the pension accounts in varying percentages so that the overall split came out to a 50/50 split. However, the defendant believes a split of each of the pension accounts on a 50/50 basis is the most equitable (see page 5 of QDRO). If the presiding judge finds the QDRO appropriate please forward the signed and time stamped copies to Mr. Jeffrey K. Welsch and Karen R. Welsch in the postage prepaid envelopes provided, If you have any questions or concerns regarding this mailer please feel free to call me at our Camp Hill office. JCG:py Enclosures (II ,JEFFREY K. WELSCH, Plaintiff/Respondent IN THE COURT OF CQMlo[)N PLEAS OF CUMBERLAND COUNl'Y, PENNSYLVANIA VB. NO. 94-1023 KAREN R. WELSCH, Defendant/Petitioner CIVIL ACTION QDRO QUAUFIED DOMESTIC REIATIONS ORDER 111ls cause coming on for hearing pursuant to the law of this State governing the divisIon of marital property incident to the dissolution of marriage (divorce), the Court. being fully advised In the premises, FINDS: A (2) Jeffrey Kent Welsch (the "Participant") is enrolled In the Minlsterial Pension Plan ("MPP") administered by the GENERAL BOARD OF PENSION AND HEALTH BENEFITS OF THE UNITED METHODIST CHURCH. INCORPORATED IN IlliNOIS (the "Board"). the address of which is 1201 Davis Street, Evanston.ll1Inois 60201. The Board is the operational ann of the General Board of Pension and Health Benefits. an administrative general agency of The United Methodist Church. The Participant has an account balance. a right to receive benefits, allocated funding or an annuity (collectively. "pension benefits") In. or arising from. one or more of the following pension accounts: MPP.QORCW70.0' Qualified Dornatic: Relations Order Page 2 (I) The "Pre.1982 Service Benefit,. which represenu the benefit provided by each applicable Annual Conference through Supplement One of MPP. being the greater of (a) the Participant's pre.1982 service annuity acc:wnulation (i.e., prc-1982 church contributions and acc:wnulatcd earnings thereon), and, if the applicable annual conference requires pre. 1982 personal contributions to be used as funding for the pre.1982 service benefit, the Participant's pre-1982 personal contributions acc:wnulation (i.e.. pre.1982 personal contributions and acc:wnulated earnings thereon); or (b) the Participanes Formula Benefit. The Formula Benefit is a benefit based upon a Participanes number of years of prc-1982 service with pension credit and the pension rates established each year by the applicable annual conferences. (2) The "Church Account,. which consisu of contributions made by a church or employer to the credit of the Participant after 1981. as adjusted for earnings and losses, (3) The "Personal Account,. which consists of after-tax contributions made by the Participant, except prc-1982 contributions which are required by the applicable annual conference to be used as funding for the pre-1982 service benefit, as adjusted for earnings and losses, (4) The "SaIary.Reduction Account," which consists of contributions made by a chwch or employer to the credit of the Participant pursuant to a salazy-reduction agreement, as adjusted for earnings and losses. MPP.QORQ'D7019S Qualified Domeatlc RdatlON Order Page 3 5) The "QVEC Account," which consists of contributions made by the Participant pursuant to Intmlal Revenue Code 5219(e)(2) as It existed prior to the enactment of the Tax Refonn Art of 1986, as adjusted for earnings and losses. (6) The "Rollover Account," which consists of funds tralUferred to MPP for the benefit of the Participant, from, or attributable to, another retirement Income plan, as adjusted for earnings and losses. B. The Participant's current or last known address Is (3) 521 57th Street Altoona, PA 16602 C. The person to whom the award of pelUlon benefits is made herein Is (4) Karen Ruth Welsch (the "Alternate Payee"), whose current or last known address Is (S) 7103 Salem Park Circle Mechanicshurg, PA 17055 and whose Social Security number Is (6) Is the Participant's: (7) 0 Spouse o Child 158-46-5230 . The Alternate Payee ~ Fonner spouse: Date of Divorce o Other dependent. 4/3/95 D. It Is in confonnitywith law and In accordance with the principles of equity that the Alternate Payee be awarded a portion of the Participant's pension benefits, as set forth hereinbelow. IT Is THEREFORE ORDERED: A The Alternate Payee Is hereby awarded the following portion of any annuity which the Participant Is nlrrent{y receiving from the Board In payment of the Participant's pelUlon MPP.QDAQ'070.9' Qualified Domatlc RelatioN Order Page 4 benefits. such award to commence thirty days after the Board's receipt of this Order and to continue in effect for as long as the Participant continues to have the right to receive said annuity: (check only one of the following boxes) (') iii The Participant is not CUITCntly receiving an annuity from the Board. (9) 0 The Participant is currently receiving an annuity from the Board, but the Alternate Payee is awarded no part thereof. (10) 0 $ per monthly payment. without increase or decrease: (11) 0 $ per annual payment, without increase or decrease: (12) 0 percent of each monthly payment otherwise payable to the Participant, as said amount may increase or decrease from time to time in accordance with the provisions of the Ministerial Pension Plan, B. The Alternate Payee is hereby awarded (13) 50% percent of the Participant's Pre-1982 Service Benefit in the Ministerial Pension Plan, effective (14) June 30 , 19....2L (the "Date of Division"), to be calculated, valued, and divided as of that date. At all times after said tnInsfer is made: (a) The Alternate Payee shall have no further claim to any benefit based on the Participant's Fonnula Benefit, and (b) The Participant's Pre.1982 Service Benefit shall be reduced by the percentage awarded to the Alternate Payee, C. The Alternate Payee is awarded the following pension benefits from the Participant's pension benefits in the Ministerial Pension Plan, effective (IS) June 30. , 19..2L (the "Date of Division"), to be calculated, valued, and divided as of that date: Mf'P.QD1lO'070195 Qualified Domestic Relations Order Page 5 (I) The sum of 1161 $ 27 , 336.22 from the Participant's Church Account. (2) The sum of (17) $ 1,657.54 from the tax-paid portion of the Participant's Personal Account, to be drawn from the prc-1987 tax-paid portion and the post-1986 tax-paid portion on a pro-rata basis, If applicable. (3) The sum of 1111 $ 1. 411. 34 from the taxable portion of the Participant's Personal Account. (4) The sum of 1191 $ 6,875.95 from the Participant's Saiaxy- Reduction Account. (5) The sum of (201 $ 3,402.46 from the Participant's QVEC Account. (6) The sum of (21) $ nla from the Participant's Rollover Account. D. Pension benefits hereby awarded to the Alternate Payee from any account which consists of Invcsttnent In more than one of the Diversified and Special Funds maintained by the Board shall be drawn from each such fund pro-rata. The Alternate Payee shall have the right to change the funds In which such pension benefits are Invested In accordance with the Investtnent election provisions of MPP, but no such change shall be effective until the next regular date so provided for implementing Investtnent election changes. E. If pension benefits are hereby awarded to an Alternate Payee from the Participant's Pre-1982 Service Benefit, and If on the Date of Division the Participant's balance In that account contained contributions for pre-1982 service from more than one annual conference, then the percentage awarded to the Alternate Payee of the Participant's contributions and earnings arising MPP.QDRQ'070195 Qualified Domestic Relations Order Page 6 from each such conference shall equal thc percentagc of the Participant's total Pre-1982 Senrice Benefit awarded to the Alternate Payee. F. Any transfer from one Diversified or Special Fund to another Diversified or Special Fund which was or is made betwecn the Date of Division and the time of the actual transfer of pension benefits to the credit of the Alternate Payee pursuant to this Order shall be deemed to include the Participant's and the Alternate Payee's pension benefits therein in shares which are proportionate to their respective interests in the Fund from which the transfer was made immediately prior to the transfer. G. Earnings and losses which accrue after the Date of Division on pension benefiu hereby awarded to the Alternate Payee shall be allocated to the Alternate Payee. Distributions to the Participant after the Date of Division shall be deemed to be made from pension benefiu other than those hereby awarded to the Alternate Payee. H. (1) Neither the Alternate Payee nor any person claiming through the Alternate Payee shall have the right by virtue of this Order to: (a) Make contributions to the Plan(s); (b) Transfer benefits to another alternate payee; (c) Receive a surviving spouse benefit arising from the Participant's pre- 1982 senrice; or (d) Receive pension benefits in the form of a joint and survivor annuity with respect to the Alternate Payee and any subsequent spouse. (2) In all other respects the pension bcnefits herein awarded to the Alternate Payee shall be administered in accordance with the Ministerial Pension Plan, as it may be amended from time to time. The Alternate Payee shall have all the righu MPP.QDRC\'070195 ,-... .'~._'" ,~~-- Quallfled Domelltic Relations Order Page 7 and duties of a fully vested "terminated participant" (as that term is defined in the Plan). but only for the pwpose of determining eligibility to receive benefits. The Participant shall have no cIahn to pension benefits hereby awarded to the Alternate Payee. I. All rights of the Alternate Payee In the Ministerial Pension Plan shall be subject to the conditions, restrictions, limitations, and requirements applicable to "terminated participants" as provided by the Plan as it may be amended from time to time, Including the non-alienation provisions thereof. J. All pension benefits and other rights, benefits, assets and Interest In the Participant's Plan not hereby awarded to the Alternate Payee shall be the property of the Participant, to the exclusion of any present or future claim thereto on the part of the Alternate Payee. K. Nothing contained In this Order shall be construed to require the Ministerial Pension Plan or the Board: (I) To provide any type or form of benefit, or any option, not otherwise provided under that Plan; (2) To provide Increased benefits (determined on the basis of actuarial value); or (3) To pay any benefits to the Alternate Payee which are required to be paid to another Alternate Payee under another order previously determined by the Board to be a qualified domestic relations order ("QDRO") as that term is defined with respect to church plans by HI4(p) of the Internal Revenue Code of 1986, MPP.QDRQ'07019S Qualified Domatic Relations Order Page 8 L. The Participant shall promptly execute and deliver to the Board an Assignment of Pension Bmeftts (wing the fonn provided by the Board), assigning to the Alternate Payee the pension benefiu hereby awarded to the Alternate Payee. M. The Alternate Payee shall promptly execute and deliver to the Board anAaqltAna! 0/ Assignment o/Penslon Bmeftts with respect to the asslgrunent of pension benefiu hereby ordered, wing the fonn provided by the Board. N. The Board. upon receipt of the Assignment 0/ Pension Benefits and the AaqltAna! of Assignment o/Penslon Bentftts. within a reasonable time thereafter which Is administratively feasible. shall effect the transfer of benefits contained herein. O. The Participant and the Alternate Payee shall fully coopemte toward the goal of qualifying and giving full effect to this Order as a QDRO, seeking any amendment hereof as may be neceJSary for that purpose. IT Is So ORDERED. this day of ,19_. Presiding Judge MPl'QDRQ'07019S (I) .mFFRE'l K. WEISCH, plaintiff/Respondent IN THE COURT OF CC>>M>N PLEAS OF CUMBERLAND COUNl"i, PENNSYLVANIA 00. 94-1023 VB. . . KAREN R. WEISCH, Defendant/Petitioner CIVIL ACTION QDRO QUALIFIED DOMESTIC RElATIONS ORDER 11Ii.s cause coming on for hearing pursuant to the law of tllls State governing the division of marital property incident to the dissolution of marriage (divorce), the Court, being fully advised in the premises, FINDS: A 121 Jeffrey Kent Welsch (the "Participant") is enrolled in the Ministerial Pension Plan ("MPP") administ.cred by tlle GENERAL BOARD OF PENSION AND HEALTH BENEFITS OF THE UNITED METHODIST CHURCH, INCORPORATED IN ILLINOIS (the "Board"). the address of which is 1201 Davis Street, Evanston, Illinois 60201. The Board is the operational arm of the General Board of Pension and Health Benefits, an administrative general agency of The United Methodist Church. The Participant has an account balance, a right to rcceive benefits, allocated funding or an alU\uity (collectively, "pension benefits") in, or arising from. one or morc of tIle following pension accounts: MPP.QCIlQ'07DI9S Qualified Domestic Relations Order Page 2 (1) The .Pre-1982 ScIVice Benefit.. which represents the benefit provided by each applicable Annual Conference through Supplement One of MPP, being the greater of (a) tile Participant's pre-1982 scIVice annuity accumulation (i.e., pre-1982 church contributions and accumulated earnings thereon), and, if the applicable annual conference requires pre-1982 personal contributions to be used as funding for the pre-1982 seIVice benefit. the Participant's pre-1982 personal contributions accumulation (i,e., pre-1982 personal contributions and accumulated earnings thereon); or (b) the Participant's Formula Benefit. The Formula Benefit is a benefit based upon a Participant's number of years of pre-1982 seIVice with pension credit and the pension rates established each year by the applicable annual conferences, (2) The .Church Account," which consists of contributions made by a chureh or employer to the credit of the Participant after 1981, as adjusted for earnings and losses. (3) The .Personal Account,. which consists of after-tax contributions made by the Participant. except pre-I 982 contributions which are required b)' the applicable annual conference to be used as funding for tile pre-1982 seIVice benefit, as adjusted for earnings and losses. (4) The .Sa1aIy-Reduction Account,. which consists of contributions made by a church or employer to the credit of tile Participant pursuant to a salaty-reduction agreement. as adjusted for earnings and losses, MPP.QD1\Q'07019S . Qualified Domestic Relations Order Page 3 5) The "QVEC Accown," which consists of contributions made by the Participant pursuant to Intcma1 Revenue Code ~219(e)(2) as it existed prior to the enactment of the Tax Refonn Act of 1986. as adjusted for earnings and losses. (6) The "Rollover AccoWlt, " which consists of funds transferred to MPP for tlle benefit of the Participant, from. or attributable to, another retirement income plan, as adjusted for earnings and losses. B. The Participant's current or last known address is (3) 521 57th Street Altoona, PA 16602 and whose Social Security number is (0) 158-46-5230 . The Alternate Payee is the Participant's: 171 o Spouse o Child ~ Fonner spouse: Date of Divorce o Other dependent. 4/3/95 D. It is in conformity willl law and in accordance with the principles of equity that the Alternate Payee be awarded a portion of the Participant's pension benefits. as set forth hereinbelow. IT Is THEREFORE ORDERED: A The Alternate Payee is hereby awarded tlle following portion of any annuity which tlle Participant is ,""tll'lY receiving from the Board in payment of tlle Participant's pension MPP.QDJICV01019S Qualified Domealle Relallons Order Page 4 benefits, such award to commence thirty days after tIle Board's receipt of this Order and to continue in effect for as long as the Participant continues to have the right to receive said annuity: (elleck only one of tIle following boxes) (I) [i) The Participant is not currentIy receiving an annuity from the Board. (9) 0 The Participant is currently receiving an annuity from the Board, but tIle Alternate Payee is awarded no part tIlereof. (10) 0 $ per monthly payment, without increase or decrease; (II) 0 $ per annual payment, witllout increase or decrease; (12) 0 percent of eaell montIuy payment otherwise payable to tIle Participant, as said amount may increase or decrease from time to time in accordance with the provisions of the Ministerial Pension Plan. B. The Alt.emate Payee is hereby awarded (13) 50% percent of the Participanes Pre-1982 Service Benefit in the Ministerial Pension Plan, effective (14) June 30, 19-2L (the "Date of Division"), to be ealcuiated, valued, and divided as of tIlat date. At all times after said transfer is made: (a) TIle Alternate Payee shall have no further claim to any benefit based on the Participant's Fonnuia Benefit, and (b) The Participant's Pre-1982 Service Benefit shall be reduced by the percentage awarded to tlle Alternate Payee. C. The Alternate Payee is awarded tlle following pension benefits from tIle Participanes pension benefits in the Ministerial Pension Plan, effective (IS) June 30. , 19.2i.. (the "Date of Division"), to be calcuiatcd, valued, and divided as of that date: MPP.QDIlQ'07019S (1) The swn of (16) $ 27 , 336.22 from the Participant's Church Qualified DomestIe Relations Order Page 5 AccOWlt. (2) The swn of (17) $ 1,657.54 from the tax-paid portion of the Participant's Personal AccoWlt, to be drawn from tlle pre-19B7 tax-paid portion and the post-19B6 tax-paid portion on a pro-ratA basis, if applicable. (3) The swn of (I') $ 1.411. 34 from tlle taxable portion of tile Participant'sPenonaIAccoWlt. (4) The swn of (19) $ 6,875.95 from the Participant's Salal)'- Reduction AccOWlt. (5) The swn of (20) $ 3,402.46 from tile Participant's QVEC AccoWlt. (6) The swn of (21) $ n/n from tlle Participant's Rollover AccOWlt. D. Pension benefits hereby awarded to tile Alternate Payee from any accoWlt which consists of investment in more tIlan one of tlle Divenified and Special Funds maintAined by the Board shall be drawn from each such fund pro-ratA. The Alternate Payee shall have tile right to change the funds in which such pension benefits are invested in accordance with the investment election provisions of MPP, but no such change shall be effective Wltil tile next regular date so provided for implementing investment election changes. E. If pension benefits are hereby awarded to an Alternate Payee from tile Participant's Prc-19B2 ScMce Benefit, and if on tlle Date of Division tile Participant's balance in tIlat accoWlt contAined contributions for pre-19B2 service from more tIlan one annual conference, tIlen tile pcn:cntAge awarded to the Alternate Payee of tile Participant's contributions and earnings arising MPl'QDRQ'070lU ,." I. . Qualified Domestie: Relations Order Page 6 from each such conference shall equal the percentage of tlle Participant's total Prc-1982 Service Benefit awarded to tlle Alternate Payee. F, Any transfer from one DivCISified or Special Fund to another Diversified or Special Fund which was or Is made between tlle Date of Division and the time of tlle actual trarufer of pemion benefiu to the credit of the Alternate Payee pU1'5uant to this Order shall be deemed to include the Participant's and the Alternate Payee's pension benefiu tllerein in shares which arc proportionate to their respective interesu in tlle Fund from which tlle trarufer was made immediatcly prior to tlle tramfer. G. Earnings and losses which accrue after tlle Date of Division on pension benefiu hereby awarded to the Alternate Payee shall be allocated to tlle Alternate Payee. Distributiom to the Participant after tlle Date of Division shall be deemed to be made: from peruion benefiu otller than those hereby awarded to the Alternate Payee. H. (1) Ncither the Alternate Payce nor any person claiming tluough tlle Alternate Payee shall have the right by virtue of tllls Order to: (a) Make contributiom to tlle Plan{s}; (b) Tramfer benefiu to anothcr alternate payee; (e:) Receive a surviving spouse benefit arising from the Participant's pre- 1982 service; or (d) Reedve pension bcnefiu in tlle fonn of a joint and survivor annuity witll respect to tlle Alternate Payee and any subsequent spouse. (2) In all other respects the peruion benefiu herein awarded to tlle Alternate Payee shall be administered ill accordance witll tlle Ministerial Pension Plan, as it may be amended from time to time. The Alternate Payee shall have all tlle righu MPP.(jORQ'07019S Quallflcd Domestic Relations Order Page 7 and duties of a ful1yvested "tcnninated participant" (as that tcnn is defined in the Plan), but only for the purpose of detennining eligibility to receive benefits. The Participant shall have no c1aim to pension benefits hereby awarded to the Alternate Payee. I. AIl rights of the Alternate Payee in tlle Ministerial Pension Plan shall be subject to the conditions, restrictions, limitations, and requirements applicable to "tenninated participants" as provided by the Plan as it may be amended from time to time, including tlle non-alienation provisions thereof. J. AIl pension benefits and otller rights, benefits, assets and interest in tlle Participant's Plan not hereby awarded to the Alternate Payee shall be the property of the Participant, to tile exclusion of any present or future claim thereto on the part of tlle Alternate Payee. K. Nothing contained in tllis Order shall be construed to require the Ministerial Pension Plan or the Board: (1) To provide any type or fonn of benefit, or any option, not othcrwise provided under tllat Plan; (2) To provide increased benefits (detcnnined on tile basis of actuarial value); or (3) To pay any benefits to tile Alternate Payee which arc required to be paid to anotller Alternate Payee under anotller order previously detennined by the Board to be a qualified domestic relations order ("QDRO") as that tenn is defmed with respect to cllUrch plans by ~414(p) oftlle Internal Revenue Code of 1986. MPl'Q.DIlQ'll7019J . Qualified Domestic RelatioN Order Page 8 L. The Participant shall promptly execute and deliver to the Board anAsslgnmellt of PellSlolI Benef/ts (using the form provided by tlle Board), assigning to tlle Alternate Payee the pension benefits hereby awarded to the Alternate Payee. M. TheAlt.cmatc Payee shall promptly execute and deliver to the Board an Acrepllllla of Asslgnmmt of Pension Benef/ts with rcspeet to the assignment of pension benefits hereby ordered, using the form provided by the Board. N. The Board, upon receipt of tlleAsslC'.ment of PellSlon Bellef/ts and the Acreplllna of Assignment ofPmslon Benefits, within a reasonable time thereafter which is administratively feasible, shall effect the transfer of benefits contained herein. O. The Participant and the Alternate Payee shall fully cooperate toward the goal of qualifying and giving full effcet to this Order as a QDRO, seeking any amendment hereof as may be necessary for that purpose. IT Is So ORDERED. this day of ,19_. Presiding Judge MPl'QDRQ'07019S ~.\f;t"' -e' .. '~. )'~1 :~((! Ii [. I ... . . j .. . "-~ ..". "';-'- "~",-~-",.,._.-""",-.,...,.."",,,-.,,,.-,.,,~,,....,,,.,,.----'_.."-!""'. "'''''-',-''f,'''~ ~"._._<""""..":_~,:.,_..",<"_i__'...,,,~ ''''''''''''''n'''''*",,~~Ct~._''''; .~.~'. .~.. ,.~~... _'\Jt_~. ::.J .:,'l'(""'",';''';:~Y>r~~,~ <W Law OJfices oj Craig A. Diehl 3464 Trlndlc Road Camp Hili. PA 17011 ", . \ , C--C',/ I .I . ".: n:""; . ';~J \ '.1 Mr. Jeffrey K, Welsch 521 - 57th Slreet Altoona. PA 16602 ... .,- _'.~~.,........,~.,~_......"",~---....,--..._",.............>->-....--. - .. , '. -- (I) ,JEFFREY K. WELSCH, Plaintiff/Respondent IN THE COURT OF CC>>M>N PLEAS m' CUMBERLAND COUNl'Y, PENNSYLVANIA VB. NO. 94-1023 KAREN R. WELSCH, Defendant/Petitioner CIVIL ACTION QDRO QUALIFIED DOMESTIC RElATIONS ORDER nus cawc coming on for hcaring pursuant to thc law of tlus Sute govcrning thc division of mariul property incidcnt to thc dissolution of marriagc (divorcc), tllC Court, bcing fully adviscd in thc premises. FINDS: A. (2) Jeffrey Kent \~e1sch (tllC "Participant") is cnrollcd in tllC Minist.crial Pension Plan ("MPP") administercd by tllC GENERAL BOARD OF PENSION AND HEALTH BENEFITS OF THE UNITED METHODIST CHURCH. INCORPORATED IN ILUNOIS (tllC "Board"), tllC address ofwluch is 1201 Davis Street, Evanston, Illinois 60201. Thc Board is thc operational ann of thc Gencral Board of Pension and Hcalth Bencfits, an administrative general agency ofThc United MctllOdist Church. The Participant has an account balance, a right to receivc benefits. allocated funding or an arulUity (collectively, "pension benefits") in, or arising from, one or more of tlle following pension accounts: MPP.Q01lQ'07019S Qualified Domestic Relations Order Page 2 (I) The .Pre-1982 Service Benefit,. which represents the benefit provided by each applicable Annual Conference duough Supplement One of MPP, being the greater of (a) die Participant's pre-1982 service alU\Uity accumulation (i,e., pre-1982 chureh contributions and accumulated earnings thereon), and, if the applicable alUlual conference requires pre-1982 personal contributions to be used as funding for die pre-1982 service benefit, the Participant's pre-1982 personal contributions accumulation (i.e.. pre-1982 personal contributions and accumulated earnings thereon); or (b) die Participan~s Formula Benefit. The Formula Benefit is a benefit based upon a Participan~s number of years of pre-1982 service with pension acditand the pension rates established each year by the applicable alUlual conferences. (2) The .Church Account,. which consists of contributions made by a church or employer to die acditofthe Participantaftcr 1981, as adjusted for earnings and losses. (3) The .PcrsonalAccount," which consists of after-tax contributions made by the Participant, except pre. 1982 contributions which are required by die applicable annual conference to be used as funding for die pre-1982 service benefit. as adjusted for carnings and losses, (4) The .SaIary-Reduction Account,. which consists of contributions made by a church or employer to the acdit of die Participant pursuant to a salaty-reduction agreement, as adjusted for earnings and losses. MPJ>.Q01lQ'070195 .~-, -r-".'''~~--C''''~o;, Qualified Domestic R.cIations Order Page 3 5) The "QVEC AccoWlt," which consists of contributions madc by thc Participant pursuant to Internal Revenuc Codc ~219{c)(2) as it existed prior to thc enactmcnt of thc Tax Refonn Act of 1986, as adjusted for carnings and losses. (6) Thc "Rollover AccoWlt," which consists of funds transfcrrcd to MPP for tIlC benefit of thc Participant, from, or attributablc to, anothcr retiremcnt incomc plan, as adjusted for earnings and losses, B. The Participant's current or last known address is (3) 521 57th Street Altoona, PA 16602 C. Thc person to whom thc award of pcnsion bcnefits is madc herein is (4) Karen Ruth Welsch {thc "Alternate Paycc") , whosccurrcnt or last known address is (5) 7103 Salem Park Circle Mechanicshurg, PA 17055 and whosc Social Sccurity numbcr is (6) 158-46-5230 . TIlc Alternate Paycc is thc Participant's: (7) 0 Spousc o Child IX] Fonncr spousc: Date of Divorcc o Othcr dcpendcnt. 4/3/95 D. It is in conformity with law and in accordance witIl tIlC principles of cquity that thc Alternate Paycc bc awardcd a portion of tIlC Participant's pension bcncfits, as sct forth hcreinbelow. IT Is THEREFORE ORDERED: A Thc Alternate Paycc is hereby awardcd tIlC following portion of any annuity which thc Participant is eumnt{y rccciving from tIlC Board in paymcnt of thc Participant's pcnsion MPP-QDRQ'070195 .'.' ,~/,,,,~ ~ .... .....-..... Qualified Domestic Relations Order Page 4 bcncfiu. such award to commcncc tlli.rty days after tllC Board's reccipt of tllis Ordcr and to continue in effcct for as long as tllC Participant continues to havc tllC right to reccivc said annuity: (chcck only one of thc following boxes) (I) [i) Thc Participant is not currcntly rccciving an annuity from tllC Board. (9) 0 Thc Participant is currcntly rccciving an annuity from tllC Board. but tllC Alternate Paycc is awardcd no part thereof, (10)0$ (1110$ (1210 per monthly payment, witllout increasc or dccrcase; per annual paymcnt, witllout incrcasc or decrcasc; perccnt of cach montIuy paymcnt otIu:IWisc payablc to tIlC Participant, as said amoWlt may incrcasc or dccrcasc from timc to timc in accordancc with thc provisions of thc Ministerial Pcnsion Plan, B. Thc Alternate Paycc is hcreby awardcd (13) 50'/; perccnt of tllC Participant's Prc.1982 Servicc Benefit in thc Ministerial Pcnsion Plan, cffcctivc (141 ,June 30, 19....2L (thc "Date of Division"). to bc calculated, valued, and dividcd as of tllat date. At all times after said transfcr is madc: (a) TIlc Alternate Paycc shall havc no furtllcr claim to any bcnefit based on tIlC Participanes Formula Bencfit, and (b) Thc Participant's Pre.1982 Servicc Benefit shall bc rcduced by tllC perccntagc awardcd to the Alternate Paycc. C. Thc Alternate Payec is awardcd tllc following pension benefits from tIlC Participant's pension bencfiu in thc Ministerial Pension Plan, effectivc (IS) June 30. , 19..2i.. (tlIC "Date of Division"), to bc calculatcd. valucd. and divided as of tllat date: MPP.Q01lQ'07019S Qualified Domestic: Relations Order Page 5 (1) The swn of (16) $ 27 , 336.22 from the Participan~s Church Account. (2) The swn of (17) $ 1,657.54 from the tax-paid portion of the Participan~s Personal Account, to be dmwn from ll1e pre-1987 tax-paid portion and the post-19B6 tax-paid portion on a pro-rata basis. if applicable. (3) The swn of (18) $ 1. 411. 34 from ll1e taxable portion of ll1e Participan~s Personal Account. (4) The swn of (19) $ 6,875.95 from the Participan~s Salary- Reduction Account. (5) The swn of (20) $ 3,402.46 from ll1e Participan~s QVEC Account. (6) The swn of (21) $ from the Participan~s Rollover n/a Account. D. Pension benefits hcreby awarded to the Alternate Payee from any account which consists of invcstment in more than one of ll1e Diversified and Special Funds maintained by the Board shall be drawn from each such fund pro-rata. The Alternate Payee shall have the right to change the funds in which such pension benefits are invcsted in accordance willI the invcstment election provisions of MPP, but no such change shall be effective until tile next regular date so provided for implementing invcstment election ellangcs, E. If pension benefits arc hereby awardcd to an Alternate Payee from ll1e Participant's Pre-19B2 ScIVicc Benefit, and if on 111e Date of Division 111e Participan~s balance in ll1at account contained contributions for pre-1982 service from more than one annual conference, ll1en ll1e percentage awarded to tlle Alternate Payee of tlle Participant's contributions and earnings arising MPP.QDIlQ'070IU ..._. ....~."-...---"OO Qualified Domestic Relations Order Page 6 from cach such confercncc shall cqual thc percentagc of tllC Participant's total Prc-1982 Scrvicc Bcncfit awardcd to thc Alternate Paycc. F. Any tzansfer from onc Diversificd or Spcclal Fund to anothcr Divcrsificd or Spcclal Fund which was or is madc bctwccn thc Date of Division and thc timc of thc actual transfcr of pcnslon bcnefits to tllC credit of thc Alternate Payce pursuant to this Ordcr shall bc dccmcd to Includc thc Participant's and thc Alternate Paycc's pcnslon bcncfits tllcreln in shares which arc proportionate to tllCir respectivc Interests in thc Fund from which tllC transfcr was madc immcdiately prior to tllC transfcr. G. Earnings and losses which accruc after thc Date of Division on pcnslon bcncfits hereby awardcd to tllcAlternate Paycc shall bc allocated to tllC Alternate Paycc. Distributions to the Participant after thc Date of Division shall bc dccmcd to bc madc from pcnslon bcncfits othcr than thosc hcreby awardcd to thc Alternate Paycc, H. Nclther tIlC Alternate Paycc nor any pcrson claiming tIU'Ough tIlC Alternate (I) Paycc shall havc thc right by vlrtuc of tltis Ordcr to: (a) Make contributions to tllC Plan(s); (b) Transfer bcncfits to anothcr alternate paycc; (c) Reccivc a surviving spowc benefit arising from tllC Participant's pre- 1982 servicc; or (d) Reccivc pension benefits in tIlC fonn of a joint and survivor alUlul~ witll respcct to thc Alternate Paycc and any subscqucnt spousc. (2) In all otllcr respects thc pension bcncfits hcrein awarded to tlle Alternate Payce shall be administered in accordance with the Ministerial Pension Plan, as It may be amended from time to time. The Alternate Payee shall have all tlle rights MPP-llDRQ'070195 Qualified Domestic Relations Oeder Page 7 and duties of a fu1Iy vested "tcnninated participant" (as dlat tcnn Is defined in the Plan), but only for the purpose of determining eligibility to receive benefiu. The Participant shall have no c1aim to pension benefiu hereby awarded to die Alternate Payee. I. All righu of the Alternate Payee in die Ministerial Pcnsion Plan shall be subject to the conditiollS, restrictiollS, IimitatiOllS, and requircmenU applicable to "terminated participanu" as provided by the Plan as it may be amended from time to time, including die non-alienation provlsiollS thereof. J. All pension benefiu and odler rights, benefits, assets and interest in the Participant's Plan not hereby awarded to the Alternate Payee shall be die property of the Participant, to the exclusion of any present or future claim thereto on die part of die Alternate Payee. K. Nothing contained in drls Order shall be construed to require the Ministerial Pension Plan or the Board: (1) To provide any type or form of benefit, or any option, not otherwise provided under dlat Plan: (2) To provide increased benefiu (detcnnined on the basis of actuarial value); or (3) To pay any benefits to the Alternate Payee wlrlcll are required to be paid to another Alternate Payee under anodler order previously determined by die Board to be a qualified domestic relations order ("QDRO") as dlat term Is defined with respect to chuccll plallS by ~414(p) of die Intemal Revenue Code of 1986. MPl'QDRQll701" Qualified Domestic Relations Order Page 8 L. The Participant shall promptJy execute and deliver to the Board anAsslgnmmt of Pe/lSlon Benejlts (using the form provided by the Board), assigning to the Alternate Payee the pension benefits hereby awarded to the Alternate Payee. M. TheAltemate Payee shall promptJy execute and deliver to the Board anAcaptlllll:e of Assignment of Pension Benejlts witJl respect to the assigrunent of pension benefits hereby ordered, using the form provided by tJle Board. N. The Board, upon receipt of the Assignment of Pe/lSlon Bmejlts and tJle Acaptllnce of Assignment of Pension Benefits, within a reasonable time tJlereaftcr which is administratively feasible, shall effect tJle transfer of benefits contained hcrein. O. The Participant and the Alternate Payee shall fully cooperate toward tJlC goal of qualifying and giving full cffect to this Order as a QDRO, secking any amendment hereof as may be necessary for that purpose. IT Is So ORDERED, this day of ,19_. Presiding Judge MPP-QDJlQ'07019S " .' . .' ---.~. I .. .~~ ,~ .:",~ . I,..' , . - . I " , .. ,. " ~~. ~"._--~..........~._--..-............"",,,,...,,,, ,.., ,.......~-^'-,,~.,--~._,,"-"---- .,.....~........ -,-,..'~...... Law Offices 0/ Craig A. Diehl 3464 Trindle Road Camp Hill. PA 17011 ". . '" '\ \ ) '. !,l.;~.: .." . ~I ., -; n r:,;; L.-' v ,.: .' .:. ~ / . ...: Ms. Karen Welsch c/o Law Offices of Craig A. Diehl 3464 Trindle Road Camp Hill, PA 17011 , . . . '. -- Cf:Nt:IIAI.llo,\1I11 Ot'l'f:NSIO:,/ ANI) 11f:AI.TII Df:Nf:t'ITS Ot' Tllr. UNITt:1I Mt:TIIIIIlIST CUllllr.1I /.llll U \) 1997 @~~.m . MARITAL LITIGATION ~FIT STATEMENT 1::",""u".SIr"' ':llflllll,,".lllilll.i..1oI1:!",-IIIII "'':.Ht,'I..'.;.,.tI Pnrticipant Name: (I) JelTrey Welsch Participant Number: (I) 0698290 Annual Confcrence: (I) Centrnl Pennsvlvnnia Valuntion Dote: (') June 30. 1994 . nUs form n:por1S tllC tolaI of the Pnrticipant's Pension Benefits in the Ministerial Pension Plan lIS of the above-named Valuotion Date, unless otherwise specified below. . A Participant may have pension benefits in one or more of the sections of this sllltcmenL Each section pertains to a scpnrote portion of the Participant's pension benefits, . Infonnation provided hcrein is subject to tile definitions, qualifications and conditions set forth in the pamphlct entitled Transfer a/Pension Benefits Pursuant To A Qualified Domestic Relations Order, which is available upon request from the General Board of Pension and Health Benefits, Legal Dcplll1ml:nL No reliance should be made on this Statement except lIS interpreted in accordance with the infonnation provided therein. ------------------------------------------------------------------------------------------------------------------------ 1. PRE-198Z SERVtCEDENEFIT AS OF (') June 30.1994 The benefit provided by Supplcment One of the Ministerial Pcnsion Plan, whieh is the greater of the benelit provided by the Participant's pre-1982 service annuity accumulation or the Fonnula Benefit, has been dctcnnincd for the (I) Cartral Pennsylpania Annual Conference to be the pre-1982 scrvice annuity accumulation in tile amount of(')'$2,316.36, which represents the account aceumulation. The bencfit provided by Supplement One of the Ministcrial Pension Plan, which is the grcater of the benefit provided by the Pnrticipnnt's pre-1982 service annuity accumulation or the Fonnula Benefit, hIlS . been dClcnnined for the (S) Annual Conference to be the (pre-19H2 service annuity accumulation)/(Fonnula Benefit) in the amount of $I" . which represents the (nccount accumulotion)/(bcnefit per month). ........ '" '~ ,~ Marital Litillation Benefit Statement PartieipllRl: JefI'rcy Welsch PartieiplIRt Number: 0698290 Page 2 '.:..:. II. DEFINED CONTRlDtrrlON ACCOUNT TOTALS AS OF (., June 30, 1994 Church Account $0' 54,672.44 Personal Account Taxable Sl" 3.315.08 $1" 2.823.68 $00' 6,138,76 $01113,751.91 $112) 6,804.93 Tax-Paid rff Sallll}'-Rcduction Account (j.\& u!~ ~ QVEC Account QI1?...1" - I YJi~"'y Rollover Account '\fIl7J' Cr" $O'Inla PART II TOTAL $O~ 81,368.04 ------------------------------------------------------------------------------------------------------------------------ III. ANNUITY ~ORMATION (lSI ~e ParticipllRt WlIS not receiving IIR annuity on the Valuation Dale. (16) 0 The PlIrticiplIRt WlIS receiving an annuity on the Valuation Date in the sum of $ . o per month 0 perycar in the following form: , . .:+:. .:.:. .:.:. .:+> ',:+> -:+:.'.:+:-:'.:C"-<CO"':.:'- .....:.:. .:+:- .:+:.'.:+:. .:+> .:+:-',:+> .:c- ':.:":-~:.:c.:~.:.x:<.:.::.:c.:.<e.:.::.:.>::.:~.:..;<e<:~ '. - ~ ~ 8 ~ IN THE COURT OF COMMON PLEAS i $ ~ ~ ~ '.' ~ '.' ~ * ~ * ~ '.' ~, ~ '.' $ * .' ~ OF CUMBERLAND COUNTY STATE OF '* PENNA. JEFFREY KENT WELSCH, Plaintiff :1 N (),l..o.~~............ .g.~.y'.p.... 19 94 Verslls KAREN RUTH WELSCH .. ..... .... ........ . .. ,. Defendant s DECREE IN DIVORCE ;i '.' ~I "I ~ AND NOW, ... ..R.F,r.,.l..?............, 19 .9.~..., it is ordered and decreed that ..,.....,.... ~~.f.~~7r. .~~~~. .I?~~.s.c:~. . . . .. . ... . .., plaintiff, and. . . . . ~~~~~. .~1;1~~. .I'!~~.s.<:~. . . . . . . .. . . . , . . .. . . . . . . .. . ... .., defendant, are divorced from the bonds of matrimony. ,'. ~ ,'. ~ ~ ~.' ~ '.' ~ The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; None ~ '.' ~ ... ,;: <, s .. .................. ........... ... .... .... .... ............................. s ............... .... ............ .......... ,... ........... ~ '.' Dy Th~W~It-- CJ.~J ~.. Allesl: ~Q.~"(O; E' ~j(~~'7 6, :l/<'J~I~L K M-A! ~J,;.4 f (/ '7P~lhonOlnrY M .' ~ ~. ~ <, ~ ..:; ,.. ~I ~I ~'--- . '.~:- .=-~. -:+:. .: ,', * ~ " .'~ ~ ~ " ~ '. ~ ~ '.' ~ '.' .', * ~ .' ~ ., ~ '.' I, ~ '.' 8 a '.' ~ ~ '.' ~ '.' w ~,' * * $ ~ ~ * i~ I':' I~ ~ S I*. I.,' I J. (~ ! ' I~ /",' , . ':b' /",' i.', I~ , , ' .-,,'- -. ~, . - .-, ---~-- -,.- -. ~ -,- ..." - ~ ~~.~~~**~*********~.***~. ?"/1/;5 ad 4?- /11~ ~ dt iU #?/~- 71~ I1f'~ # 4" ~ , . . JEF~REY ~ENT WELSCH, Plaintiff IN THE COURT OF COr~ON PLEAS : CUMBERLANDCOUNTY, PENNSYLVANIA Va. : : : : : NO. 1023 Civil, 1994 CIVIL ACTION - LAW KAREN RUTH WELSCH, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit. the record, together with the followin9 information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown 3301 (c) under Section (xi iiiXl(leX ( ) 201 (d) (1) of the Divorce Code. (Check.-' applicable .ection) . 2. Date and manner of ..rvico of the complaint: March 21, 1994 _ Acceptance of service on behalf of Defendant, Karen Rl . Welsch by her Attorney, Carl G. Wass, Esquire 3. (Complete eithe~ para;raph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 201 (c) of the Divorce Code: by plaintiff March 22, 1995 1 by defendant March 13, 1995 . (b) (1) Date of execution of the plaintiff's affidavit required by Section 201 (d) of the Divorce Code: 1 (2) date of service of the Plaintiff's affidavit upon the Defendant;' .... . 4. Related claims pendin;: None Arthur K. Oils, Esquire (717) 232-9724 ~ luk~ Attorney for I ) Plaintiff ( ) Defendant \ . :\ ""'. ""', .. :0::: - 0'1 ~ ~,.. .f I- u.jr~ (:".1 Q',,~ _d c:or..:S ~:; ;r: :-/ ".~ ::.., :.~> ~'" ..... l... _.:~:~ '..j .,,) z. ~_ :t: I~):......o ~. :r. a.. ::> 0<"'1 r- '" "" ~ . JEFFREY KENT WELSCH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 10 a3 Civil, 1994 KAREN RUTH WELSCH, Defendant 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 following pages, you must take prompt action. You are warned that if you fail to do so, the case may 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 di vorce is indigni ties or irretrievable breakdown of the marriage, you may request marriage counseling 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. Office of the Court Administrator Cumberland County Court House One Court House Square Carlisle, PA 17013 (717) 240-6200 JEFFREY KENT WELSCH, plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. IOJ3 Civil, 1994 KAREN RUTH WELSCH, Defendant DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF DIVORCE CODE 1. The Plaintiff is Jeffrey Kent Welsch, an adult individual, who currently resides at 5513 Silver Creek Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is Karen Ruth Welsch, an adult individual, who currently resides at 5513 Silver Creek Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff and Defendant were married on August 16, 1980 in Roselle park, New Jersey. 4. Plaintiff and Defendant have resided in the Commonwealth of Pennsylvania for a period of at least six (6) months prior to this filing. 5. Defendant is not a member of the Armed Services of the United States or ics allies. r,"""':'-::~' ., 6. Plaintiff and Defendant are both citizens of the United states. 7. There has been no prior action for divorce or annulment in any jurisdiction. 8. Plaintiff has been advised of the availability of marriage counseling, and has waived said right. 9. Plaintiff avers that the grounds on which this action is based are: (a) That the marriage is irretrievably broken. WHEREFORE, Plaintiff respectfully requests your Honorable Court to grant a Decree in Divorce. Respectfully submitted, B..(;;2/})d Arthur K. Oils, Esquire 101 S. Second st.,ste. L1 Harrisburg, Pa. 17101 (717) 232-9724 I.D. No. 07056 . .. <. '. VBUPICA'l'IOfi I verify that the statements made in this Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A.~4904, relating to unsworn falsification to authorities. Dated: d~/q Y .' , , -.. < .... tIl< <> Czl..:l ..:1>< c..tIl'" :Il ZOI U :Il ZZOI tIl U a OCzl... ..:I tIl tiE :Ec.. Czl ..:I .~ :E ~ Czl ~ w. 0 ' , ~ =~ u><~ E-t ~ ~ lli!!t E-t..... Z :Il Czl t..z> Czl E-t U l! wwBI 0:;)..... :.: tIl :;) P: ~ >~IX w ~- w ou > P: 0 ~ . il.' E-tU >< > ~ E H P: Czl Z .... :;)0 P: Czl 0 . . ~ 0:: t.. P: a- .E u< t.. < i ..:I Czl :.: CzlP: '":l :IlCzl E-tlQ :E . z:;)o . . J. vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 1023 Civil, 1994 CIVIL ACTION - LAW IN DIVORCE JEFFREY KENT WELSCH, Plaintiff KAREN RUTH WELSCH, Defendant ORDER OF COURT AND NOW, this ~r~ day of Apr~l , 1995, upon presentation and consideration of the within Marriage Settlement Agreement, it is hereby Ordered that said Agreement and the Addendum attached thereto is hereby made an Order of Court. BY THE COURT ,"". "i''; 1 1\' " 1 10;; 4PR 3 3 12 PH '95 , ". ;')rflC! or 'Ilt ""':HON~iAr.y CU1.t!J~I'UI~!J C{1Ui1iV I'EU11~"'L;:'."iI: '^''''''-''''''''', MARRIAGE SETTLEMENT AGREEMENT / U, THIS AGREEMENT, made this {p day of 1995, by and between KAREN R. WELSCH, of Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred to as "Wife", and JEFFREY K. WELSCH, of Wormleysburg, Cumberland County, Pennsylvania, hereinafter referred to as "Husband." ;11 ardv WITNESSETH: WHEREAS, Husband and Wife were lawfully married on August 16, 1980; and WHEREAS, differences have arisen between Husband and Wife in consequence of which they are living separate and apart from each other; and WHEREAS, Husband and Wife have made a full disclosure of their assets to each other; and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations with respect to each other, including the disposition and distribution of property rights and interests between them; and WHEREAS, Husband and Wife are the parents of three minor children, to wit: Michelle Louise Welsch, born November 21, 1983, Charlene Elizabeth Welsch, born June 16, 1985, and Andrea Christine Welsch, born October 14, 1988, and Husband and Wife desire to settle and determine the matters of custody and support with regard to those minor children. NOW, THEREFORE, the parties intending to be legally bound hereby, do covenant and agree: 1. SEPARATION. It shall be lawful for each party at all times hereafter to continue to live separate and apart from the other party at such places as he or she may from time to time choose or deem fit. The foregoing provisions shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of the causes leading to their living apart. 2. INTERFERENCE. Each party shall be free from interference, authority, and contact by the other, as fully as if he or she were single and unmarried except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 3. WIFE' S DEBTS. Wife represents and warrants to Husband that since the separation she has not and in the future she will not contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save harmless Husband from any and all claims or demands made against him by reason of debts and obligations incurred by the Wife prior to the date of the delivery of this Agreement, and all further 2 debts incurred by the Wife from and after the date of delivery hereof, shall be the Wife's individual responsibility. 4. HUSBAND'S DEBTS. Husband represents and warrants to Wife that since the separation he has not and in the future he will not contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. Husband acknowledges and agrees that all debts and obligations incurred by the Husband prior to the date of the delivery of this Agreement, and all further debts incurred by the Husband from and after the date of delivery hereof, shall be the Husband's individual responsibility. 5. MUTUAL RELEASE. Subj ect to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself, and his or her heirs, legal representatives, executors, administrators, and assigns, release and discharge the other of and from all causes of action, claims, rights, or demands, whatsoever in law or equity, which either of the parties ever had or now has against the other, except any or all cause or causes of action for divorce and except for any or all causes of action for breach of any provision of this Agreement. 6. DISCLOSURE OF PROPERTY. Husband and Wife acknowledge and agree that they have made a full and ccmplete disclosure to the 3 other of all information pertaining to the parties' separate and marital property owned, possessed and/or controlled by the other at the time of the separation of the parties and do hereby waive the formality and necessity of filing an Inventory and Appraisement with the pending action in divorce. 7. DIVISION OF PERSONAL PROPERTY. Attached hereto, identified as Exhibit A, and incorporated herein by reference is a list of items of personal property, entitled "Karen's Property." The parties agree that the items of property set forth on Exhibit A, as well as other items of personal property presently in the possession of Wife, shall be and hereafter continue to be the sole and exclusive property of Wife. Those items of personal property presently in the possession of Husband, and not identified on Exhibit A, shall be and hereafter remain the sole and exclusive property of Husband. Husband agrees that he will continue to provide a storage space to Wife for a period of one (1) year following the date of this Agreement for "Karen's exercise bicycle" and the "car roof carrier." In addition, both parties agree to share with the other all video tapes depicting family history and all musical recordings and tapes of personal and sentimental value to either so that the party out-of-possession shall have the ability to duplicate such tapes and/or recordings. 4 . . 8. BANK ACCOUNTS AND INVESTMENTS. The parties acknowledge that they have already, to their mutual satisfaction, made a division and allocation of their banking accounts in a fashion mutually acceptable to both of them. 9. AUTOMOBILES. The parties are the joint owners of two automobiles, neither of which is encumbered, and agree to the dispostion thereof as follows: the 1986 Chevrolet Celebrity shall be transferred to the sole name of Wife; and, the 1988 Dodge Colt shall be transferred to the sole name of Husband. Both parties agree to execute any document required for the purpose of effecting the change of ownership/title as herein provided. 10. RETIREMENT BENEFITS. Husband is a vested participant in certain pension and benefit plans maintained for his benefit by the General Board of Pension and Health Benefits of the United Methodist Church, being Participant Account No. 0698290 of the Central Pennsylvania Conference. The parties acknowledge that a pension and benefit plan statement of account for the period January 1, 1994, through June 30, 1994, reflects that the accumulated total value of the personal contributions account of Husband is in the sum of $12,943.69, and that the salary reduction contributions account had a total value of $13,751.91. For convenience, the parties agree that the total of the two said accounts is $26,696. In addition, the aforementioned pension statements reflects also the existence of a pension account which 5 has an accumulated balance of $54,672.44, as well as a "pre-1982 service" account having a value of $2,316.36. The parties agree that all of the aforementioned accounts constitute marital property and agree to a division or allocation thereof as hereinafter set forth. A. Personal Contributions and Salarv Reduction Contributions Accounts. The parties agree that the sum of $26,696 contained in the aforementioned accounts shall be divided equally between them (and any accrued interest prior to the division shall also be divided equally) by means of the issuance of a Qualified Domestic Relations Order of the Court of Common Pleas of Cumberland County which shall result in the establishment of two (2) equal and separate accounts, one of Husband and one of Wife, with the General Board of Pensions. B. Pension Contributions Provided Bv The Church Or Salarv-Pavinq Unit. The parties agree also that there shall be established a Qualified Domestic Relations Order with regard to Husband's pension account which shall include all accumulated earnings both prior to and subsequent to January 1, 1982, which Order shall require that, at the time of Husband's retirement, there shall be established a coverture fraction and a non-coverture fraction, based upon coverture having terminated on June 30, 1994, and further providing that whatever pension option may be selected by Husband, the coverture portion thereof shall be divided equally between the 6 parties, and the non-coverture portion thereof shall be paid entirely to Husband. Such coverture/non- coverture allocation shall be applicable not only to the payment of any pension but, shall also be applicable to any distribution of any cash resulting from Husband's selection of any retirement option which may be available to him. The parties further agree that the Order shall also provide for the irrevocable designation of the pension as a joint and survivor annuity and shall also provide that the coverture portion of either which may be paid in a lump sum pursuant to the provisions of the plan may be. paid to the designated beneficiaries of Husband or Wife, as the case may be. 11. SPOU~AL SUPPORT. ALIMONY. ALIMONY PENDENTE LITE. COUNSEL FEES AND EXPENSES. A. In consideration of the mutual agreement of the parties to all of the terms of this Agreement, both parties agree that each of them has and does hereby waive and relinquish any right to claim from the other any contribution to or any payment of any form of alimony pendente lite or any payment of counsel fees and/or expenses incurred, it being the intent of this paragraph that each party shall pay his or her own counsel fees and expenses. B. Husband presently is paying spousal support to Wife in the allocated sum of $100 per week, pursuant to an Order of Court entered in the Court of Common Pleas of CUmberland County, 7 _........;. Pennsylvania, at No. 195 Support Docket 1994. Upon the entry of a Decree in Divorce, both parties agree that the aforementioned Order shall be modified to provide that the sum of $100 per week, thereafter, shall continue to be paid to Wife, shall be termed alimony, and shall continue to be paid to Wife for a period of five (5) years from the date of the entry of a Decree in Divorce between the parties, subject, nevertheless, to the following conditions and limitations: (1) The amount of alimony shall not be subject to any modification for any reason; and, (2) The aforementioned alimony payments are contingent only upon, and will terminate only upon: (a) The remarriage of Wife; (b) The death of Wife; or, (c) The death of Husband. C. In recognition of the fact that, upon the entry of a Decree in Divorce, Wife shall no longer be entitled to the benefit of medical and hospitalization benefits currently provided to her pursuant to a plan maintained by Husband's employer, Husband hereby agrees to pay to Wife the cash sum of $2,000 per year, for a period of three (3) years from the date of the entry of the Decree in Divorce, for the purpose of enabling Wife to secure and pay the cost of appropriate medical and hospitalization insurance for her benefit. Husband's obligation to contribute to Wife's medical insurance costs shall terminate in the event of Wife's subsequent 8 '. . remarriage and entitlement to coverage as a dependent of her new husband, in which case, any payments already made hereunder, or yet to be paid hereunder, shall be pro-rated as of the effective date of Wife's ~ marital coverage. 12. CUSTODY OF CHILDREN. The parties acknowledge that there presently exists an Order of the Court of Common Pleas of Cumberland County, dated July 15, 1994, entered to No. 94.2389 Civil Term, which provides for custody of their three minor children. Both parties reaffirm the validity of such Order and agree to continue to abide by the terms thereof. 13. SUPPORT OF CHILDREN. Both parties acknowledge that the aforementioned Order of Support entEored in the Court of Common Pleas of Cumberland County, Pennsylvania, at No. 195 Support Docket 1994 provides for an allocated Order for the support of their three minor children. Both parties hereby reaffirm that Order and agree to abide by its terms, as the same may hereafter be modified, from time to time, by any change in the circumstances of the children or respective parties. 14. EDUCATION AND SECURITY FOR CHILDREN. Husband agrees that he shall execute an irrevocable trust agreement, and shall name a corporate trustee of his choice, said trust agreement being designed to provide for the future education of the minor children of the parties, to provide security in the event of the untimely 9 " . death of Husband, and, ultimately, to provide a permanent benefit to the said children. The trust agreement shall be funded in the following respects: A. Trustee shall be named the irrevocable beneficiary of the proceeds of a Nationwide Life Insurance Company universal life policy presently maintained by Husband upon his life; B. Three certificates of deposit presently held by the Central Pennsylvania Conference of the United Methodist Church, heretofore held by Husband or Wife as custodian for one or more of the chidren, shall be transferred to the name of trustee and shall form part of the corpus of the said trust; and, C. Husband shall name trustee the irrevocable beneficiary of the proceeds of any term life insurance policy maintained upon the life of Husband by virtue of his employment with the Central Pennsylvania Conference of the United Methodist Church. The beneficiary provisions of the trust agreement shall, at a minimum, contain the following provisions: A. All income generated by the trust assets shall be utilized solely for the purpose of providing for the support, health, comfort, education and general welfare of the three children of the parties, and, in the discretion of the corporate trustee, such sums of principal of the trust shall be utilized, when deemed necessary, for the purpose of 10 .....' ',.....".~...!J~ ,', ',. providing for the support, health, comfort, education and general welfare of the three children of the parties; B. Upon the attainment of the youngest of the three children of the parties to the age of 23 years, and in the event Husband shall have died prior to that time, the trust shall thereupon terminate and any remaining assets of the trust shall be divided equally among the three children of the parties; and, C. In the event the youngest child of the parties has attained the age of twenty-three (23) years and Husband continues to be living, the trust shall terminate, and any assets therein shall be paid equally to the three children of the parties; sng, Husband shall thereupon irrevocably designate the three children, equally, as beneficiaries upon the Nationwide Life Insurance Company universal life policy and any then-existing term life insurance policy maintained upon his life by the Central Pennsylvania Conference of the United Methodist Church. 14. BREACH. If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, and the party breaching this contract should be responsible for payment of legal fees and costs incurred by the other in enforcing their rights 11 under this Agreement, or seek such other remedies or relief as may be available to him or her. 15. ENTIRE AGREEMENT. This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 16. MODIFICATION AND WAIVER. The modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 17. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 18. INDEPENDENT SEPARATE COVENANT. It is specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 19. APPLICABLE LAW. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 12 20. VOID CLAUSE. If any term, condition, clause, or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement, and in all other respects this Agreement shall be valid and continue in full force, effect and operation. 21. ENTRY AS PART OF THE DECREE. Husband has initiated an action in divorce under Section 3301 (c) of the Pennsylvania Domestic Relations Code, filed in Dauphin County to No. 1023 Civil 1994 in the Court of Common Pleas of Cumberland County, Pennsylvania. It is the intention of the parties that the within Agreement shall survive the aforementioned action for divorce, and that no order, judgment or decree, temporary or interlocutory, final or permanent, shall affect or modify the financial terms of this Agreement. Both parties agree to execute Affidavits of Consent for the purpose of entry of a Divorce Decree under Section 3301(c) of the Pennsylvania Domestic Relations Code. This Agreement shall be made part of any such judgment or decree of final divorce, but shall not be merged therein. Husband agrees to' provide to Wife, at his expense, a certified copy of the final Decree in Divorce. 22. VOLUNTARY EXECUTION. Wife acknowledges that Carl G. Wass, Esquire, has acted as legal counsel to her in connection with the negotiation and preparation of this Marriage Settlement 13 Agreement. Husband acknowledges that Arthur K. Oils, Esquire, has acted as legal counsel to him in connection with the negotiation and preparation of this Marriage Settlement Agreement. Both parties acknowledge and represent that they have thoroughly read the provisions of this Marriage Settlement Agreement, have discussed the same with their respective attorneys, and do understand the full legal effect thereof, especially with regard to the fairness and equitable nature of the distribution of marital property between them and the disclaimer of any alimony by either party. Both parties acknowledge that their execution of this Agreement has been done voluntarily and knowingly and their execution is not the result of any duress or undue influence. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written. WITNESS; 14 ~ '. KAREN'S PROPERTY Karen's ice skates Karen's exercise bicycle Car roof carrier Chevrolet repair manual Some of the collections of recordings and taped music the parties acquired during marriage Her grandmother's artificial Christmas tree Box of Sunday school materials and supplies Christmas tree ornaments made by her mother Christmas dishes which were a gift from Karen's sister Swimming pool filter (on loan from Karen's sister) which, however, Jeffrey may continue to use as long as he maintains a swimming pool but, upon cessation of such use, the filter is to be returned to Karen's sister The following Christmas decorations: bells/bloCks door hanger, reindeer door knob cover, stained glass nativity shelf decoration, girls' snow globes, Santa climber, wind up toys, ice skating pond with bear, green garland with apple/berries and matching oval-like candle ring, Nana's ornaments - pink with silver, silver, blue with inserts, others, Santa Claus shapes, angel shapes, et cetera. Small stained glass window ornaments with suction cups Lights and decorations which accompany grandmother's artificial Christmas tree Small gold color sled, white ceramic reindeer, gray mouse Girls' stockings and mantel sto~king holders. EXHIBIT A G:\DATA\CCW\02D02\941D2\42076.1 '. AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF 1J II (J P f.{ I,J tu. SS: On this, the day of f'1 t7A. c.-I._ , 1995, before me, a Notary Public, the undersigned officer, personally appeared KAREN R. WELSCH, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. 7~ c K~ .Il _ . tary Public NOTARIAL SEAL TillY C. KOLUS. Nolary Public l1ilrf isburg. Dauphin Counly My Commission Expires Nov. 28, 1996 15 '. AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY o~;A.J On this, the /J. l/6 , SS: day of , 1995, officer, personally before me, a Notary Public, appeared JEFFREY K. WELSCH, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. NclllMI Seal ow.eM~~~ My~=~ir.11l97 G,\oATA\CGW\o2oo2\94102\45a16.1 16 . ' ADDENDUM TO MARRIAGE SETTLEMENT AGREEMENT ......, -, ,^,_:d THIS ADDENDUM, made this c ~ day of March, 1995, by and between KAREN R. WELSCH, of Mechanicsburg, CUmberland County, Pennsylvania, hereinafter referred to as "Wife", and JEFFREY K. WELSCH, of Wormleysburg, CUmberland County, pennsylvania, hereinafter referred to as "Husband," WHEREAS, the parties have heretofore entered into a Marriage Settlement Agreement dated March 6, 1995; and, WHEREAS, Husband and Wife have informally agreed to include a provision dealing with the guardianship of their children in the event any of their children shall still be minors at the time when both of the parties are deceased, NOW, THEREFORE, the parties hereby agree that the within Addendum shall be attached to and made a part of the aforementioned Marriage Settlement Agreement, by the adding of a new paragraph 12.A., to read as follows: 12. A. GUARDIANSHIP OF CHILDREN. Both parties agree that, in the event of the deaths of both of them at a time when any of their children shall still be under the age of eighteen (18) years, they agree that the sister of Wife, to wit: Donna Kulinski, shall be the guardian of any such child or children who may be a minor; . . .' and, each of them hereby agrees that in the event either of them shall execute a Will, such designation of guardianship of their minor child or children shall be included as a provision in said Will. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written. WITNESS, ~ -Q<<:l..N.~~ ~,U. ~t? V V (/')://-((/1-/ G:\DATA\CGW\02002\94102\47295.1 .. . . , . 11' ~'I ~~,.., .......~,.... .~ :~;:.., )', .;:,;.;.:.\,).'...... """ """ - ....... .r =: -..:: en ;r '.-' -' ^.-.+ r- ,~ "" ~, :.t.: Ulz Zo~ 0:;<( c(=.J 11l~... ~ < <( o l('j ~ ~ I .J~I&I -Aoz 11l~1I: ~~O O~... o ... ....<<( <( ~ U Q E ~ <( ... - ... z . <( ~ ~ ~ >- z III o Z · Z .. III x 0. ~ . · Cl o II: z :> - m Mill III _ M II: II: <( J: . . . , , JEFFREY KENT WELSCH, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 1023 Civil 1994 DIVORCE KAREN RUTH WELSCH, Defendant ACCEPTANCE OF SERVICE The undersigned hereby accepts service of the Complaint in Divorce in the within matter on behalf of the Defendant, Karen Ruth Welsch. By: ~ Carl G. Wass, Attorney I.D. #07268 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 Attorney for Defendant Karen Ruth Welsch UJ l~..l Dated: A,( l\.A ~f c f . (rtf/v 28129 ...,., Q") - ;;;>- ~~- 4'~('''~ ~;!:.;._,:_l" lLO').- h...::- - '..: ~)...: ~i,:: ':!:;,,; ...:.c.... u.~ ."'~ ::c: --= a> .:r - - r- ..... "" ~ . . ., . ...... .. ." JEFFREY KENT WELSCH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 1023 Civil, 1994 : CIVIL ACTION - LAW IN DIVORCE vs. KAREN RUTH WELSCH, Defendant AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS: I, Karen Ruth Welsch, being duly sworn according to law, deposes and says: 1. A Complaint in Divorce under Section 3301 (c) of the Domestic Relations Code was filed on March 2, 1994. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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. 5. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling; I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request; and, being so advised, I do not request that the Court require that my : ~ '. . . .. . _. -, . spouse and I engage in counseling prior to a Divorce Decree being handed down by the Court. 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. Date: UC).htE>~ ~2 l IQ'1S ~enR.I1)~ ( )' Plaintiff (X) Defendant U"> en = -:x ~~ .... ': ~.. ,j.:,<, ., c., .,.. .' . .' r-- ,,-, I~ .... = .<)-"' 1JI . Z 0 O:~~ <:.. 1l.I~1- ~oc o ~ulll . )0- J ~ lIS .JOZ ll.Iiiill: ~"O O~I- o I- .JoC < ~ U .... ~. . - ....'h '."'1\" "'Ul""'>'~';"'~ " """-'.""1'11"" . .. . Q E: .. C '" - '" Z II: C :n?; .. >- Z III Oz II: Z .. I&l X 0.. .. . II: ~ o II: Z :;) - m ~1Il M it II: C J: -.0.- . . r .-_.... . 41 _.. . ., .. JEFFREY KENT WELSCH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 1023 Civil, 1994 CIVIL ACTION - LAW IN DIVORCE vs. KAREN RUTH WELSCH, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 2, 1994 . 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final Decree in 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. 5. I have been advised of the availability of counseling, and being so advised, I do not request Court require my spouse and myself to participate in counseling. marriage that the marriage I verify that the statements made in this Affidavit are true and correct. I understand that false statements made herein are made subject to the penaltie 'of 18 Pa. C.S. Section 4904, relating to unsworn falsification 0 au horities. DATED: I ! , / '; ! . -, , /.' I " / I t,C; I , ...; ~ ... :5 >"''Jil,. ;.::'..... ..f" ~ ~~ ., ~:~'~.': \:, c - en .;Z' ".. .-. I ~. '""'; .; ~ ...... ('.,J ". ~ ~. c..';"" = i I I I I It . . . . .- . . , JEFFREY KENT WELSCH, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . v. . CIVIL ACTION - LAW . . . KAREN RUTH WELSCH, . . Defendant . NO. 94-1023 CIVIL TERM . AND NOW, ORDER OF COURT this ~iiday of May, 1995, upon consideration of the attached letter from Arthur K. Oils, Esq., attorney for Plaintiff, the hearing previously scheduled for May 5, 1995, on Plaintiff's Petition for Bifurcation, is CANCELLED and the Petition for Bifurcation is DEEMED MOOT. BY THE COURT, J Arthur K. oils, Esq. 101 South Second Street Executive House, Ste. Ll Harrisburg, PA 17101 Attorney for Plaintiff . ~::,-I'l/yr ~ .J.~' Carl G. Wass, Esq. 3631 North Front Street Harrisburg, PA 17110-1533 Attorney for Defendant :rc '.; - " , ;. '. ., A'r-'" j'; '. ,t ", 55, ~'" r./j 13 G A1'J "-..... . g)tiJ ~ ~~ ATTORNEYS AT LAW EXECUTIVE HOUSE SUITE ., 101 SOUTH SECOND STREET HARRISBURG. PENNSYLVANIA 11101 ARTHUR K. OILS JOSEPH J. DIXON DIANE M. RUPICH PHONE: (717) 233.a743 May 5, 1995 The Honorable J. Wesley Oler, Jr. Cumberland County Court House One Court House square Carlisle, PA. 17013 RE: Jeffrey Kent Welsch v. Karen Ruth Welsch No. 1023 Civil, 1994 Dear Judge Oler: On behalf of my client, Jeffrey Kent Welsch, a Petition for Bifurcation was filed on February 21, 1995, and your Honorable Court scheduled a hearing in this matter for May 5, 1995 at 9:00 a.m. Since that time, the parties have reached an Agreement and Consents have been executed by both parties; hence, there is no need for a hearing on the Petition to Bifurcate. Thank you for your assistance in matter. i;;ltAIL rthur K. ~ AKD:dmr ,11# , "I ~ A'L J~~~ " '. , JEFFREY It. WELSCH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VB. KAREN R. WELSCH, Defendant NO. 1023 - 1994 CIVIL ACTION - DIVORCE AMENDED ODRO THIS AMENDED QDRO is made this ~9 day of ...,.I' ~ 1997, by and between: JEFFREY KENT WELSCH, hereinafter referred to as the "Participant"; and KAREN RUTH WELSCH, hereinafter referred to as the "Alternate Payee" . WHEREAS, the parties have given serious consideration to the terms of the Amended ODRO and agree to the Amended QDRO attached as Exhibit "A". IN WITNESS WHEREOF, the parties hereto set their hands to this Agreement to Amend ODRO on the date above mentioned. WITNESS: A/)/)n.~--/j$#<,:/ 'i!fb" F:lUJ.(;cF.I'.1: O. ,,-" .,. .-' ....,." ;- I,':'" ,- -, "1't',l en nCi -:: ;;', \I: L5 CU'" " ""( ,. _.,. . i .,'1 ..n. ."., ' .~. "..,'.,..\ p~t.~,,-~,'~..\:" '~:" '. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. On this RCJIh day of t3fPTflll,,>c.e. , 1997, before me, the undersigned officer, personally appeared KAREN R. WELSCH, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement as to Amended QDRO, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. '~~Tfk{(((1 NOTARIAL SEAL HELEN E. RASMUSSEN. NDI8ty Public CImP Hill Borough. Cumbe~.nd County My COOlml..IDn Expire. Aug. 2. 1999 COMMONWEALTH OF PENNSYLVANIA COUNTY OF -.dkh;, ss. On this ,:19 day of ~I , 1997, before me, the undersigned officer, personally appeared JEFFREY K. WELSCH, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement as to Amended QDRO, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. _~n~ctl-~~.1 NOTARY PUBLI NolMaJ GeaJ ShalTo. L. Allchoy. NO!DIY PublIc AIloona, 8131r County My Commlselon 1!Jcpi,t1 May 2~, 1999 Mrr6li,~~c1Nctrteo r.c (I) .mpJ"REY K. WELSCII, Plaintiff/Renpondent IN TIlE COURT OF' COMMON PLE1\S OF' CUMIlERL1\ND COUNTY, PENNSYLV/lNIJ\ vs. NO. 94-1023 KJ\REN R. WELSCH, Defendant/Petitioner CIVIL ^CTION ODRO / J\MFIDID . QUALIFIED IJ)OMESTIC REIATIONS ORDER Tlus cause coming on for hcaring pursuant to thc law of tllis St.~te govcrning tlle division of marit.~l propcrty incident to the dissolution of marriage (divorce), tlle Court, being fully advised in tlle premises, FINDS: A. (') Jeffr.ey Kent Welnch (tlle "Participant") is enrolled in tlle // Ministerial Pension Plan ("MPP") administercd by tlle GENERAL BOARD OF PENSION AND HEALTH BENEFITS OF THE UNITED METHODIST CHURCH, INCORPORATED IN ILLINOIS (the "Board"), the address ofwluch is 1201 Davis Street, Evnnston, Illinois 60201. The Board is tlle opcrational amI of tlle Gencral Board of Pension and Hcaltll Bcncfits, an admil\i.~tmtivc gencrnl agcncy of The United Mctllodist Church. Thc Participant has an account balance, a right to receive benefits, alloc.~ted funding or an annuity (collectively, "pension bcncfits") in, or arising from, one or more of tlle following pension accounts: Mrr.QD1lC\'07019l '. ., ,. Qualificd Domestic Relations Ordcr Pagc 2 (1) Thc .Prc-1982 SClVicc Bcncfit," which rcprescnts thc bcncfit providcd by cnch nppllcnblc Annunl Confcrcncc through Supplcmcnt Onc of MPP, bcing tllC grcn tcr of (n) thc Pnrticipnnt's prc-1982 sClVicc nnnuity nccumulntion (i. c., prc-1982 church contributions nnd nccumulntcd cnmings tllcrcon), nnd, if tllC npplic.1blc lIIulUnl confcrcncc requircs prc-1982 pcrsonnl contributions to bc uscd ns funding for tllC prc-1982 sClVicc bcncfit, the P3rticipnnt's prc-1982 personnl contributions nccumulntion (i.e., pre-1982 person31 contributions nnd nccumulnted cnmings tllcreon); or (b) tlle Pnrticipllllt's Fonnuln Bencfit. Thc Fonnuln Bcncfit is n benefit bnsed upon n Pnrticipnnl's nwnbcr of ycnrs of pre-1982 service witll pcnsion credit nnd tllC pension rntcs cst.1blishcd cnch ycnr by tlle nppllc.1ble nnnunl confercnces. (2) TIlc "Church Account," which consists of contributions mnde by n church or cmploycr to tlle credit of tllC Pllrticipnnt nfter 1981, ns ndjusted for C3mings 3nd losscs, (3) TIlc "PcrsonnlAccoullt,' which consists of nftcr-t.1X contributions mndc by the Pnrticipllllt, cxcept prc-1982 contributions which nre rcquircd by thc npplic.1ble nnnunl confercnce to bc used ns funding for tlle pre-1982 scrvice bcncflt, ns ndjustcd for enmings nnd losscs. (4) TIlc .Snlmy-RcductionAccount," which consists of contributions mnde by n church or employer to tlle credit of tlle Pnrticipnnt pursunnt to n snlnry-reduction ngrcement, ns ndjustcd for cnmings nnd losses. MPP.QDRQ'07019S '. Qunlificd Domestic Rclntions Ordcr Pngc 3 5) Thc "QVEC Account," which consists of contributions madc by thc Participant pursuant to Intem.ll Revcnuc Codc ~219( c)(2) as it existed prior to thc enactmcnt of thc T:L"( Reform Aet of 1996, as adjustcd for carnings and losscs. (6) TIIC "Rollover Account," which consists of funds trnnsfcrrcd to MPP for thc bcnefit of tllC Participant, from, or attribut.1blc to, anotllcr rctircmcnt incomc plan, as adjustcd for carnings amllosscs. B. Thc Participant's current or last known address is (3) 52l 57th Str.eet /\ltoonn , P/\ lliG02 C. The pcrson to whom tllC award of pcnsion bencfits is madc hercin is (~) Karen nuth Welsch (tllC "Altem.1te Paycc"). whosc current or last known addrcss is (S) 7103 Salem Park Cir.cle Mechanicshurg, PA l7055 and whosc Social Security nwnber is (6) 158-46-5230 . TIIC Alternatc Payee is the Participnnt's: (7) D Spouse IX] Fonner spouse: Date of Divoree D ChUd D Otller dependent. 4/3/95 D, It is in confOnnitywitll law and in accordance witll tlle principles of equity tllat tlle Alternatc Payec bc nwardcd a portion of tllC Participant's pcnsion bcncfits, ns set forth hereinbelow. IT Is THEREFORE ORDERED: A. TIle Alternate Payee is herebyawnrdcd tlle following portion of any nlU\uity which tlle Participant is cllrrtllt{y rcceiving from tllc Board in pnymcnt of tlle Participant's pcnsion Mrr.QDI\tV0701.S . . " " Qunlified Domestic Relntions Order Pnge 4 benefits, such award to commcnce thirty days after the Board's reccipt of this Order and to continue in cffect for as long as the Participant continues to have tlle right to reccive said annuity: (cheek only olle of tlle foIlowing boxes) (I) @ The Participant is not currently receiving an annuity from the Board. (9) 0 The Participant is currently receiving nn annuity from tlle Board, but the Altcrnate Pnyee is awarded no part tllercof. (10) 0 $ per montluy payment, witllout increase or decre:lSe; (II) 0 $ per annual payment. witllout increase or decrease; (12) 0 perccnt of each montluy payment otherwise payable to tlle Pnrticipant, as said amount may increase or decrease from time to time in nccordance witll tIlc provisions of tIlc Ministerial Pcnsion Plan. B. Thc Altcnlatc Pnyec is hcreby awarded (13) 50'1: perccnt of tllC Participant's Pre-1982 Servicc Benefit in tlle Ministcrial pcnsion Plan. effcctivc (14) June 30, 19~ (tIlC "Datc of Division"), to be calculated, valucd, nnd dividcd ns of tIlnt dnte. At nll timcs after snid t.r:Insfer is made: (a) TIlcAlternnte Pnycc shall hnvc no furtllcrcIaim to any bencfit bascd on tllC Participant's Formula Benefit, nnd (b) Thc Participnnt's Prc-1982 Service Benefit shall bc rcduced by tllC perccnt.~gc awarded to tlle Altcrnatc Paycc. C. TIIC Alternate Payce t~ awardcd tIlC foIlowing pension bcncfits from tIlC Participant's pcnsion benefits in tllC Ministcrinl Pcnsion Plnn, effective (IS) June 30, ,19.2..1- (tlle "Datc of Division"), to bc c.~lculated. valucd, nnd divided as of tIlat date: Mrr.QDltO'07ol?S '. '. Qualificd Domestic Rclations Ordcr PagcS (1) Thc swn of (16) $ 27,336.22 from tIlC Participant's Church Account. (2) Thc sum of (17) $ 1,657.54 from tIlC tllx-paid portion of tIlC PnrticiplIIlt's PcrsonnlAccount, to bc dmwn from tIlC pre-19B7 tnx.paid portion and tI1C post.19BG tlUc:.paid portion on a pro-rot:1 basis, if applicablc. (3) Thc sum of (II) $ 1.411.34 from tIlC tlU,ablc portion of tIlC Participant's Pcrsonal Account. (4) Thc sum of (19) $ 6,875.95 from tIlC Participant's Salaxy. Rcduction Account. (S) Thc swn of (20) $ 3,402.46 from tIlC Participant's QVEC Account. (6) Thc sum of (21) $ from tIle Participant's Rollovcr n/n Account. . D. Pcnsion bcncfits hereby awarded to tIle Alternate Payee from any account which consists of investmcnt in more tImn one of tlle Diversified and Special Funds maint.,ined by tIle Doard shall bc drown from cach such fund pro-rot.,. Thc Altcrnate Paycc shall have tlle right to chllIlgc tIle funds in which such pension bcnefits arc invested in accordance Witll tllC invcstment election provisions of MPP, but no such ellange shall be effcctive until tlle next rcgular date so providcd for implcmcnting invcstmcnt clection changes. E. If pension benefits nrc hereby awardcd to an Alternatc Payee from tlle Participant's Pre-19B2 Scrvice Dencfit, IIIld if on tIle Date of Division tIle Participant's balance in tIlat account containcd contributions for pre-19B2 scrvicc from more tIUIIl onc annual confcrcnce, tIlen tllC perccntllgc lIwarucd to thc Altcrnate PlIyce of tllC Participant's contributions lInd carnings arising MM'.QDl\CV07019S . . ". .. Qunlificd Domestic Rclntions Ordcr Pngc 6 {rom cach such confcrcncc shall cqual tllc pcrecnt.'1gc o{ tllC Participant's tot.'11 Prc-1982 Scrvicc Bcncnt awardcd to tllC Alternatc Paycc. F. Any trnns{cr {rom onc Divcrsincd or Special Fund to nnotllcr Divcrsifled or Spccial Fund which W:lS or is madc bctwccn tllC Date o{ Division :Ind tllc timc o{ tllc :Ictual trnns{cr o{ pcnsion bcnenu to tllC credit o{ tllC Alternatc Paycc pursuant to tillS Ordcr shall bc dccmcd to include tllC Participant's and tllC Alternate Paycc's pcnsion bencnu tllcrcin in sharcs whicll are proportionatc to tllcir respcctivc intcrcsU in tllC Fund {rom wlllch tllC trnns{cr WlIS m:ldc immcdiately prior to tllC lIans{cr. G. Ean\ings and losscs which accruc n{tcr tllC Date of Division on pcnsion bcncnu hcreby aw:udcd to tllC Alternate Paycc sll:lll bc alloc:.'1ted to tllc Alternntc Paycc. Distributions to thc P:lrticipant after tllc Date o{ Division sh:lll bc dccmcd to bc m:ldc {rom pcnsion bcncnu otllcr tllan tllose hcrcby awardcd to tllC Altcrna te Paycc. H. (I) NcilIlcr IIlcAltenl:lte Payee nor any pcrson claiming tllrough tllc Altcrnatc Paycc shall h:lvc tllC right by virtuc of tillS Ordcr to: (a) Makc conlIibutions to tllc Plan(s); (b) Trans{cr bcncnu to anothcr altcrnatc paycc: (c) Reccivc a surviving spowc bencnt :Irising from thc P:lrticipnnt's pre- 1982 servicc: or Cd) Reccivc pension bcncnu in tllC Conn o{ n joint :Ind survivor nnnuity willi respcct to tllC Alternatc Pnyec and :Iny subscqucnt spousc. (2) In all otllcr rcspccu tllC pcnsion bcncnu hcrein awardcd to tllC Altcrnatc Paycc shall bc administercd in nccordancc witl\ tllC Ministerial Pcnsion Plan, as it m:lY bc :unendcd {rom timc to timc. Thc Altcrnatc Paycc shall havc all tllC righu MI'I'.QDRQ'07019S ,....-""''''_..,.. ~ Qualified Domestic Relations Order Page 7 and duties of a fullyvcsted "tenninated participant" (as that term is dermed in the Plan), but only for tlle purpose of determining eUgibility to receive benefits. The Participnnt sh:ill hnve no clnim to pension benc1its hereby nwnrded to tlle Alternate Pnyee. I. All rights of the Alternate Payee in the Ministerial Pension Plnn shall be subject to the conditions, restrictions, limit.'1tions, nml rcquircments appUcnble to "terminated participnnts" as provid!ld by the Plnn ns it mny be amendcd from time to time, including tlle non-nlienation provisions tllereof. J. All pension bcnc1its and olller rights, bellcfits, nssets and interest in tlle Pnrticipnnt's Plan not hereby awarded to tlle Alternate Payee shall be the property of the Participant, to tlle exclusion of nny present or future clnim thereto on tlle pnrt of the Alternnte Pnyee. K. Notlung contained in tlUs Order shall be construed to require tlle Ministerial Pension Plnn or tlle Bonrd: (I) To provide nny type or fonn of benefit, or any option, not otllerwise provided under tllat Plan; (2) To provide increased benefits (determined on tlle bnsis of actunrial value); or (3) To pny anybcnc1its to tIleAlterIl.'Ite Pnyee Whiell are required to be paid to MOtIler Alternate Pnyee under another order prcviowly determined by tIle Board to be n qualified domestic relntions order ("QDRO") ns tI\lIt term is dermed with respect to cllUreh plnns by ~414(p) of tIle Intem.'11 Revenue Code of 1986. . MI'l'.QO:lC.\'D7DI9S . . \ . Qunlined Domestic Relntions Order Pngc: B L, The Pnrticipnnt shnll promptly execute nnd deliver' to tlle Bonrd nnAsl/gl/lllmt of Pmslol/ Dmrjits (using the fonn provided by tJle Bonrd), nsslgnlng to tJle Altemnte Pnyee tJle pension benefits hereby nwnrded to tlle Alternnte Pnyee. M. 111eAlternnte Pnyce shnl1 promptly execute nnd deliver to tJle Bonrd nnAcclptal/ll of AsslglI/lllllt of Pmslol/ Dmrjits witll rC.'lpect to tJle nssignrnent of pension benefits hereby ordered, using tlle fornl provided by tJle Bonn!. N. The Bonrd, upon receipt of tJle Asslgllmmt of Pml/ol/ Dmtjlls nnd tJle Amptal/te of Asslgnllllllt ojPlIulol/ DlIIrjits, witllin a rc:\sonable time tJlerenfterwhlch Is ndmlnlst.rntlvely fenslble, shnll effect the trnnsfer of benefits cont:lined herein. O. The Pnrticipnnt nnd tJle Alternnte Pnyee shnll fully coopernte townrd tJle gonl of qunlifying and giving full effect to tJlis Order ns n QDRO, seeking nny nmendment hereof ns mny be necessnI)' for tJlnt purpose. IT Is So ORDERED, this q. day of Ot..s, , c< , 19.!!... Presiding Judge t1 MI'I'.QDtu:vo7019S .C4. 1:;'" ~'1 ..S( 1;) - ~ -1 ~ t: !i! Iii ~ !!! ~ if a c u1- C Z 15 a Cl ~ III '" Ci9~E.! II: .. ~ u ... III II. t- o '" l/l - W ~ _ E::. U 0 ~ ~ Ii: a: - .. Ii; III if ie o ~-l~ ~ ~!i! 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