The URL can be used to link to this page

Home My WebLink About02-3345 JERRY L. WILSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL DIVISION - LAW NO. 02 - 3316 CIVIL ROXANE P. WILSON, Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 JERRY L. WILSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL DIVISION - LAW NO. 02 -33'15' CIVIL ROXANE P. WILSON, Defendant IN DIVORCE COMPLAINT Plaintiff, Jerry L. Wilson, by his attorneys, Brol\ios & Gilroy, P.C., sets forth the following: 1 Plaintiff, Jerry L. Wilson, is an adult individual residing at 2 Central Street, Newville, Cumberland County, Pennsylvania 17241. 2 Defendant, Roxane P. Wilson, is an adult individual residing at 2119 Pine Road, Newville, Cumberland County, Pennsylvania 17241. 3 The parties were married on July 19, 1993, in Winchester, Virginia. 4 Plaintiff and Defendant have lived continuously in the Commonwealth of Pennsylvania for at least six months prior to the Commencement of this action. 5 Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling 6 There have been no prior actions for divorce or annulment in this or any other jurisdiction within the knowledge of the Plaintiff. 7 In accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is irretrievably broken. WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendant. By P.C. Hubert . Gilroy, Esqui Attorn for Plaintiff Broujos & Gilroy, P.C. 4 North Hanover Street Carlisle, PA 17013 717 - 243-4574 I verify that the statements in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to unsworn falsification to authorities. b 0 .:::J c C f"'.) .' :c"'" '-n rrC , ~ ~ - C.t~ c= ~ zq~ .- Ze w" ~.".._,. u. ~C) fj 'fl P -'0 ~ -....,.(') ::I: :C-=() '1l -0 )>C ~ C:> cl Z ~ >4 ~ :J1 :-; ?- -'1-1 ..... ~ ~ 1- cp 0() ~- vJ W C) V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE JERRY L. WILSON, Plaintiff ROXANE P. WILSON, Defendant : NO. 02-3345 CIVIL TERM RELATED CLAIMS AND NOW, comes the defendant, Roxane P. Wilson, by and through her attorney, Jacqueline M. Verney, Esquire and respectfully represents that: COUNT II EQUITABLE DISTRIBUTION I. During the marriage, the parties accumulated certain property which is subject to distribution. 2. During the marriage, the parties incurred debt which is subject to distribution. WHEREFORE, Defendant requests this Honorable Court determine marital property and to order equitable distribution thereof. COUNT III COUNSEL FEES AND EXPENSES 3. The averments set forth in paragraphs 1-2 are incorporated herein by reference. 4. Defendant lacks sufficient funds to pay counsel fees and expenses incidental to this action. 5. Plaintiff works full time and receives an adequate salary. 6. Defendant works part-time, and attends school full time. 7. Plaintiff is in a better economic position to pay counsel fees and expenses. 8. Defendant requests the Court to enter an Order requiring Plaintiff to pay Defendant's counsel fees and expenses. WHEREFORE, Defendant requests this Honorable Court to enter an order requiring Plaintiff to Defendant's counsel fees and expenses. COUNTIV SUPPORT/ALIMONY/ALIMONY PENDENTE LITE 9. The averments set forth in paragraphs 1-8 are incorporated herein by reference. 10. Defendant lacks sufficient property and income to provide her with a reasonable income and cannot adequately support herself. 11. Plaintiff has a far more economic superior position than Defendant and Defendant requires reasonable support to adequately maintain herself. WHEREFORE, Defendant respectfully requests this Honorable Court to enter an Order granting Defendant spousal support, alimony and/or alimony pendente lite Respectfully submitted, Date: 1-lfe -(J ~ cJr;. ~ ac eline M. Verney, Esquire 44 South Hanover Street Carlisle, P A 17013 (717) 243-9190 Attorney for Defendant Supreme Ct. ID. 23167 VERIFICATION I verify that the facts included in the within Pleasding are true and correct based on information known to me or received from reliable sources. 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: ct- q-o ~ .~ p. lA)~) Roxane P. Wilson CERTIFICATE OF SERVICE I, Jacqueline M. Verney, Esquire, hereby certifies that a true and correct copy of the foregoing Pleading was served upon the following by First Class US Mail, postage prepaid by placing the same in the United States mail on the date indicated Hubert X. Gilroy, Esquire 4 North Hanover Street Carlisle, P A 17013 Date: ,- ((" --02--- acq eline M. Verney, Esquire #231 44 South Hanover Street Carlisle, P A 17013 (717) 243-9190 Attorney for Defendant \N~~ ~~01 ~ 'A.l ~ ~ Vv ..t::.-. <::J1 ~ (') 0 (-) C 1'0) -T; ~: V) ,-' I;: ..., m E: V -? Z [,- (n 0.'1 -< ~~ V C ....,.... ?; C. :J> C~ ~. n. ~:::.... ')1 ~ ( ) i ll~S ~:rrAC''''M~1: fQl\ 6-rJ. P~EEO~ ...' "rrn',oHIiR: I)()Q: 2-7-60 Roxanne Wilson 40DItE."'... 211 9 - ""ONe: 717-776-9383 "T1'ORHF.V:Jac~ueline M. Verney Esq. , Full-time Student PI':1mONI'.Jl'5 ~1'I.oYMI,;"NT: Lanmore Twp. NET,,,v: $500.00 PER: Mo. ISN: 427-11-4077 Pine Road' Newville, PA. 17241 JOB TI1U: . 9 ..0W',()Ne;: Treasurer ~part-t:Lme) , mos. onrClllNCoMt ("MOUNT. SOUR('E); o kl!SI'OHDENT: DOO: Jerry Wilson 3-2-57 SSN: Newville, PA, 17241 2 Centr9-l Str'eet ^DDRI~: P~Nt; 717-385-7296 "'ITORN~V. Huoert Gilroy JU!$PONUtNT'S I!MP,.oV.,ENl: u. S. Army War College 1I0W,.oN(;: 20 yrs. HI.",^y. 2,500.00 _'D., mo. , fire. fighter r..... JOG TiTLe: ()n'&;ItIN"c.lMt(AMOUHT.SOURC~);2 other jobs approx. 150.00/week WIIUN MI\IUl'ED: 7 -19-9 3 :WtIERE: Winchester VA. DI\TE 51;1'^k41l~ljilec 5, 2001 .Wl/tlU! IAS'J LfVfD loomlER: 2119 Pine Road Newville, PA. 17241 FOR DRS INFORMATION ONLY -0-'" nl:~r -,. ..T ~~t: <--, CO :','~ r> ~,' ~_e:C: ...,::--- ~>- Z~,' ~() - C- z =<! (') ~; r:;'; :/) ;-'1 "0 -.::' <-! 0'. , ~.~~ j n .'!"'l -lJ ""';'>~ , ' " ~~) _'; =f-J ~-;: (OS ~3f'fl -. ;r:.: :n -< f'..j :.n co JERRY L. WILSON, PlaintifI/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA VS. CIVIL ACTION .. DIVORCE ROXANE P. WILSON, DefendantJPetitioner NO. 2002-3345 C:IVIL TERM IN DIVORCE DR# 32148 PacseS# 0171049,'6 ORDER OF COURT AND NOW, this 12th day of December, 2002, upon consideration of the Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties Bind their respective counsel appear before RJ. Shaddav on Januarv 14. 2003 at 9:00 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (I) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by RuIe I91O.II({;) (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, George E. Hoffer, President Judge Date of Order: December 12, 2002 ,3 (l, ;:Jl~~ ~LddaY, Conference Officer ( ./ YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR C:ANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIN]) OUT WHERE YOU MAY GET LEGAL HELP. Petitioner Respondent Jacqueline Verney, Esquire Mail copies on 12-12-02 > CUMBERLAND COUNTY BAR ASSOCIATION 2 LffiERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 O{IG? ({~~ / (') c <.'~ "D LXi nln" ;~:r ~....... c7J ~?, -<L !:::c) ~n ",-0 """c z ::;! o N CJ .., ~J ...,._,~ -rl , . "--".-' ""t:' , , -.--- ~:-l ~ .- . '" ',->-"::' (i~ ~:=J -,~ 5J -< r:- (,.;) JERRY L. WILSON, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2002-3345 CIVIL TERM ROXANE P. WILSON, Defendant/Petitioner : CIVIL ACTION - LAW : IN DIVORCE PETITION FOR SPECIAL RELIEF AND NOW, comes the Petitioner, Roxane P. Wilson, by and through her attorney, Jacqueline M. Verney, Esquire and in support thereof represents the following: 1. Petitioner is Roxane P. Wilson, the defendant in the above captioned divorce action who resides at 2119 Pine Road, Newville, Cumberland County, Pennsylvania. 2. Respondent is Jerry L. Wilson, plaintiff in the above captioned divorce who resides at 2 Central Street, Newville, Cumberland County, Pennsylvania. 3. Plaintiff/Respondent filed the within divorct~ action on July 15,2002. 4. The parties have lived separate and apart since December 5, 2001. 5. Defendant/Petitioner's natural daughter, Jerula Furby, lived with the Plaintiff/Respondent for a time in 2002. 6. Jenna Furby recently returned to live with Defendant/Petitioner. Jenna Furby and Defendant/Petitioner have made several attempts to retrieve certain furniture, personal property and clothing belonging to Mrs. Wilson and the child that she left at Mr. Wilson's residence. 7. Mr. Wilson has retained a signature stamp with Mrs. Wilson's signature. Mrs. Wilson believes and therefore avers that Mr. Wilson has used the signature stamp without Mrs. Wilson's authorization. 8. Mr. Wilson refuses to return the personal property or to permit the removal of the personal property. 9. Since separation, Mrs. Wilson has retained possession of the couples' two dogs. 10. Over the Thanksgiving holiday, Mrs. Wilson requested her other daughter, Jessica Furby, who continues to live with Mr. Wilson, to care for the dogs while Mrs. Wilson was away for four days. 11. Upon Mrs. Wilson's return, Mr. Wilson refused and continues to refuse to return the dogs to Mrs. Wilson. 12. One of the dogs suffers from cancer and has not had its medication. 12. As a result of Mr. Wilson's unreasonable withholding of the personal property and the dogs, Mrs. Wilson has incurred legal fees. Petitioner requests this Honorable Court levy attorney's fees against Mr. Wilson. WHEREFORE, the Petitioner requests a hearing on the within Petition and requests this Honorable Court to Order Mr. Wilson to return the furniture and personal belongings to Jenna Furby and return the couple's dogs and signature stamp to Mrs. Wilson. Petitioner also requests this Honorable Court assess Mr. Wilson attorney's fees. Respectfully submitted, 1;)--/7 -oZ-- h.~ acq line M. Verney, Esquire # 23 - 44 South Hanover Street Carlisle, PAl 7013 (717) 243-9190 Attorney for Petitioner VERIFICATION I verify that the facts included in the within Petition are true and correct based on information known to me or received from reliable sources. I understand that false statements herein are made subject to the penalties of 18 Pa" C. S.A. S 4904 relating to unsworn falsification to authorities. Dated: ,~- \<1-c.")- ~~~. Roxane P . WIlson . lU~ CERTIFICATE OF SERVICE I, Jacqueline M. Verney, Esquire, hereby certifies that a true and correct copy of the foregoing Petition was served upon the following on the date indicated by the following means: United States First Class Mail, Postage Prepaid Hubert X. Gilroy, Esquire 4 North Hanover Street Carlisle, PA 17013 Date: I), -/9 -0 ")/ }J, . cqu ine M. Verney, Esquire # 167 44 South Hanover Street Carlisle, PAl 7013 (717) 243-9190 Attorney for Petitioner 0 C-) C:J ~:; c, .' '["1 -:-~~+.. .. ., -r) , ~, q. r~. "') ..r..._ U~ \.C' - . ~ "- ...~~-~ S-~; - , (:.; ""- J> C:. rv eel Z ;:~ --{ :-\.) SJ -< -< In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION ROXANE P. WILSON ) Docket Number 02-3345 CIVIL Plaintiff ) vs. ) PACSES Case Number 017104946 JERRY L. WILSON ) Defendant ) Other State ID Number ORDER OF COURT - RESCHEDULE A CONFERENCE You, JERRY L. WILSON plaintiff/defendant of 2 CENTRAL ST, NEWVILLE, PA. 17241-9493-02 are ordered to appear at CUMBERLAND CO DRS f"..." ,-- J {....-.) l__.~J 13 NORTH HANOVER STREET, CARLISLE, PA. 17013 before a conference officer of the Domestic Relations Section, on the '-.-'.J 5TH DAY OF FEBRUARY, 2003 at 9 : 30AM for a conference, after which'the __ : ,) conference officer may recommend that an order be entered. This date replaces the rptior conference date of JANUARY 14, 2003 You are further required to bring to the conference: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income and Expense Statement attached to this order as required by Rule 1910.11 ( c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. information relating to professional licenses 7. other: Service Type M Form CM-513 Worker ID 21205 tl)& WILSON V. WILSON PACSES Case Number: 017104946 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: DAN - 8 2003- JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP: CUMBERLAND CO BAR ASSOCIATION 2 LIBERTY AVE CARLISLE PA 17013-3308-02 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the sched~l~d conference. --zt [; ( Ye:f~ ~, ~ Service Type M Form CM-513 Worker ID 21205 o c ~-: -'1(', · C.)ff' ~1: (f!) ~..'..... .- r::::..:.. ):;<:-1 ,.c._ /-1 ~~; '(::: 7' :2 ,--~ '-' (.;;, C,) ~ -. --0 :"1: C" :::' \0 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION ROXANE P. WILSON ) Docket Number 02-3345 CIVIL Plaintiff ) vs. ) PACSES Case Number 017104946 JERRY L. WILSON ) Defendant ) Other State ID Number ORDER OF COURT - RESCHEDULE A CONFERENCE You, ROXANE P. WILSON plaintiff/defendant of 2119 PINE RD, NEWVILLE, PA. 17241-9203-19 f""---,., are ordered to appear at CUMBERLAND CO DRS ..,-_.:) t..__-.J 13 NORTH HANOVER STREET, CARLISLE, PA. 17013 w before a conference officer of the Domestic Relations Section, on the 5TH DAY OF FEBRUARY, 2003 at 9 : 30AM for a conference, after which tli~ [',) conference officer may recommend that an order be entered. This date replaces the prior conference date of JANUARY 14, 2003 You are further required to bring to the conference: 1. a true copy of your most recent Federal Income Tax Return, including W -2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income and Expense Statement attached to this order as required by Ru1e 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. information relating to professional licenses 7. other: Service Type M Form CM-513 Worker ID 21205 t.-')l!/Cr WILSON v. WILSON PACSES Case Number: 017104946 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: TolAN - 8 2003. JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATIEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP: CUMBERLAND CO BAR ASSOCIATION 2 LIBERTY AVE CARLISLE PA 17013-3308-02 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference. )(e. 9A{~ 71~ ~ Service Type M Form CM-513 Worker ID 21205 (") C "':';: -0 e;: ~i}' ~.; r~:: c 4~8 ~ " ~.., '-"' w (") ~-;l"1 (..l:' -0 r- :.:> \0 - State Commonwealth of Pennsylvania Co.lCity/Dist. of CUMBERLAND Date of Order/Notice 02/28/03 Tribunal/Case Number (See Addendum for case summary) ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT t>I:f ~, - 3 ~~S- C, vI (.", ~S ()} 7/1>l/1Y{, o Original Order/Notice @ Amended Order/Notice o Terminate Order/Notice DFAS CLEVELAND CENTER* C/O DFAS CODE L GARNISHMENT OPS PO BOX 998002 CLEVELAND OH 44199-8002 RE: WILSON, JERRY L. Employee/Obligor's Name (last, First, Mil 182-46-2150 Employee/Obligor's Social Security Number 2559000022 Employee/Obligor's Case Identifier (See Adckndum for plaintiff names associated with cases on attachment) Custodial Parent's Name (last, First, Mil EmployerMithholder's Federal EIN Number See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMA nON: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee'sfobligor's income until further notice even if the Order/Notice is not issued by your State. $ 733.33 per month in current support $ 0.00 per month in past-due support Arrears 12 weeks or greater? (29yes 0 no $ 0.00 per month in medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ 733.33 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 169.23 per weekly pay period. $ 338 .46 per biweekly pay period (every two weeks). $ 366.67 per semimonthly pay period (twice a month). $ 733.33 per monthly pay period. REMITTANCE INFORMA nON: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee'sf obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #1 Oon pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: P A SCDU Send check to: Pennsylvania SCDU,P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTSMUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. Date of Order: (lI/ 'bC--4 (..1. ) 00 :s- f :;: vUL)&,E; Form EN-028 Worker 10 $IATT Service Type M "~~' :<",,:~. '. i'W ." .: 0970-0154 ._.,i;.,.~'''1...iiA..,~ ::;- & '03 ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If c.,hecked you are required to prpvide a ~opy of this form to your. ~mployee. If YOl,lr employe~ works in.a state that is ditterentfrom the state that issued this order, a copy must be provided to your employee even If the box IS not checked. 1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned businesses located on a reservation that choose to withhold in accordance with this notice. 2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 3. Combining Payments: You can combinewithheld amounts from more than one employee/obligor's income ina single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 4.' ::::.:s :: f,;;:='" 01 Wftl,holdl".. Y", must rep~~ ~:~a::~ :;;:~I~::I,., .."din. the ..,,,,.,'l The pay ;t. . is tl,e date on ..I,id, alllount vvas ..itht.eld fron. the emptoyee''5 vvages. You must comply with the law ofthe state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 5. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #1 0 below) 6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S 10: 2491016300 EMPLOYEE'S/OBLlGOR'S NAME: EMPLOYEE'S CASE IDENTIFIER: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: WILSON, JERRY L. 2559000022 DATE OF SEPARATION: 7.. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. Antkliscrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 10. * Withholding Limits: . You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (1 5 U .S.c. 91673 (b)1; or 2) the amounts allowed by the State of the employee's1obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 11. Additional Info: * NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at. (71 7) 240-6248 or . by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Worker ID $IATT Service Type M OMB No.: 0970-0154 ADDENDUM Summary of Cases on Attachment Defendant/Obligor: WILSON, JERRY L. PACSES Case Number 017104946 Plaintiff Name ROXANE P. WILSON Docket Attachment Amount 02=33'4"5 CIVIL$ 469.00 Child(ren)'s Name(s): DaB you are required to enroll the child(ren) above in any health insurance coverage available employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DaB o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee'slobligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DaB .. .' ..b.I~..~~.~~~~~;..~~.~...~;~...;~~~i.~~...~~..~n.;~11...t~.:..~~;.I~.~;;~)..................... ..... ..... identified above in any health insurance coverage available through the employee's/obligor's employment. Service Type M OMB No.: 097()..()154 PACSES Case Number 928000044 Plaintiff Name HEIDI J. MCLAUGHLIN Docket Attachment Amount 10990F 93 $ 264.33 Child(ren)'s Name(s): DaB ...... ".' ....... ......... ......... .... .c'.... .... ............................ .. Dlf ~h~~k~d,;~~;;~;~q~ir~d t~ ~~~~II. th~~l1ild(~~~)" ..... ........ .. identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number . Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DaB you are required to enroll the child(ren) above in any health insurance coverage available employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DaB If checked, you are required to enroll the child(ren) above in any health insurance coverage available employee's/obligor's employment. Addendum Form EN-028 Worker ID $IATT . C) ~ ..::: "l:.. (0, rnf; -'-:;,;or -_, ....:.~... . ;:;~. C ~J' r:2C :..~ ...).".r"- 2(...., )>e: Z =< 'n:> t. .-...>.; ;:::;1- .r) ,t') F:~: t~,~ C':'.' c,; :.,~~ ""'J --,..,,' ""11 .-:- ,"V (J') / ~- r" "1 '.:! '-:--~ :0 -< JERRY L. WILSON, Plaintiff/Respondent: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE ROXANE P. WILSON, DefendanUPennoner NO. CIVIL TERM IN DIVORCE Pacses# 017104946 ORDER OF COURT AND NOW, this 28th day of February, 2003, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $1,469.04 and Respondent's monthly net income/earning capacity is $3,129.02, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $469.00 per month payable monthly as follows; $469.00 for alimony pendente lite and $0.00 on arrears. First payment due next pay date @ $216.46 bi-weekly. Arrears set at $2,553.67 as of Febraury 28,2003. The effective date of the order is September 16, 2002. Respondent is given credit in the amount of $260.00 from PACSES C#340104741. Both parties are to report any direct payments since the date of filing and the account will be adjusted accordingly. Respondent is to report to the Domestic Relations Office within five days upon receipt of this order with a payment plan for the retroactive arrears. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C.S.s 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the P A SCDU to: Roxane P. Wilson. Payments must be made by check or money order. All checks and money orders must be made payable to P A SCDU and mailed to: P A SCDU P.O. Box 69110 Harrisburg, P A 17106-9110 Payments must include the defendant's P ACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. Unreimbursed medical expenses that exceed $250.00 annually are to be paid 0% by the respondent and 100% by petitioner. The petitioner is responsible to pay the first $250.00 annually in unreimbursed medical expenses. Respondent to provide medical insurance coverage. Within thirty (30) days after the entry of this order, the Respondent shall submit written proof that medical insurance coverage has been obtained or that application for coverage has been made. Proof of coverage shall consist, at a minimum, of: 1) the name of the health care coverage provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims should be made; 5) a description of any restrictions on usage, such as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms. This Order shall become final ten days after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary for a hearing de novo before the Court. DRO: R. J. Shadday Mailed copies on .J--?~ to: < BY THE COURT, Petitioner Respondent Jacqueline Verney, Esquire J. n c <: "\1 ," r1"d' , -/'" .- ~..- '/: ", ~! ~.~ ~\: J::. , /-.. (~ >c: ;-.:: ~ () ~::;:;1 ,~l.li; ','0 I -Q ..,") "',..\> ...-:..... -. ( ) L~,rn ,-j '"':";.- 5:) -< r;.~"" .'....) r1" JERRY L. WILSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LA W ROXANNE P. WILSON, Defendant NO. 02-3345 CIVIL TERM ORDER OF COURT AND NOW, this 18th day of March, 2003, upon consideration of the attached letter from Hubert X. Gilroy, Esq., attorney for Plaintiff, the hearing previously scheduled for March 20, 2003, is rescheduled to Thursday, June 12, 2003, at 1 :30 p.m., in Courtroom No.1, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, Hubert X. Gilroy, Esq. Attorney for Plaintiff Jacqueline M. Verney, Esq. Attorney for Defendant .~ ~ .3-Jl),{)3 0-1 :rc r- ~ VINVi\l),SNi{Jd ) 'r I r-, [' '-'I ...,' ,-v-: '. ^",n f"'\ .\J.\J' \,1) . ",-1""1\[ h.; D I :i; t~ I ~ ,.', .:"., re \1 JOHN H. BROUJOS HUBERT X. GILROY BROUJOS & GILROY, P.c. ATIORNEYS AT LAw 4 NORlH HANOVER SlREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 243-4574 FACSIMILE: (717) 243-8227 jbroujos@broujosgilroy.com hgilroy@broujosgilroy.com NON-ToLL FOR HARRISBURG AREA 717-766-1690 March 17, 2003 The Honorable J. Wesley Oler, Jr. Cumberland County Courthouse One Courthouse Square Carlisle, P A 17013 Re: Wilson v Wilson Dear Judge Oler: A hearing in the above matter is scheduled before you on Thursday, March 20, 2003 at 9:30 a.m. This is a Petition for Special Relief filed by Attorney Jacqueline Verney on behalf of Mrs. Wilson. I am representing Mr. Wilson. I just developed a conflict for Thursday morning, and I am requesting the hearing be rescheduled. I spoke with Jackie this morning and she indicated she had no objection to the request. I am enclosing a proposed Order to reschedule the hearing, and I spoke with Ruth of your office this morning indicating this request would be submitted via a letter. Thank you for your consideration. Sincerely yours, MAR 1 J 2003 4. Gilroy dca Enclosure cc: Jacqueline M. Verney, Esquire Jerry L. Wilson JERRY L. WILSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : PACSES NO. 017104946 O:t- 33Y)" C-I'VI-/ ROXANNE P. WILSON, Defendant DEMAND FOR HEARING DATE OF ORDER: February 28, 2003 AMOUNT: $469.00 per month FOR: Alimony Pendente Lite REASONS: 1. DRO miscalculated the income of Jerry L. Wilson. 2. DRO miscalculated the income/income potential of Roxanne P. Wilson. 3. The parties had a comprehensive Property Settlement Agreement which implicitly included a waiver of any claims for spousal support, alimony pendente lite and alimony. Date: ) ((3( 6 ]. a Hubert X. Gilroy, quire Attorney for Plai tiff Broujos & Gilroy, P.c. 4 North Hanover Street Carlisle, P A 17013 ---.. \,._.J -" .,-.., =< AJoJ /\ 01 Q{)u l~S J ':1' c;\\N3d .-. VH\j'\ I\:~>'" :-", DC'; ;(\1 n,J p ("'o.r" t,I' ";) ':l tv ; ~.. ~ .., [Ion 1 -; \\, I;", t, ',( ~ {.; d;..; r_ ~i~i JERRY L. WILSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v : NO. 2002 - 3345 CIVIL TERM ROXANNE P. WILSON, Defendant : CIVIL ACTION - LAW : IN DIVORCE PETITION FOR SPECIAL RELIEF IN THE NATURE OF DECLARATORY JUDGMENT Plaintiff, Jerry L. Wilson, by his attorneys, Broujos & Gilroy, P .c., sets froth the following: 1 Plaintiff and Defendant in the above matter were married on July 19, 1993. 2 Plaintiff and Defendant separated on or about September 5, 2001. 3 Defendant prepared what the parties intended to be a coml~rehensive Property Settlement Agreement with respect to all economic issues relating to the parties marriage, a copy of said Agreement is attached hereto and marked Exhibit "A". The parties executed said Agreement on March 12, 2002. 4 In reliance upon the Agreement, Plaintiff proceeded with fulfilling the terms of the Agreement and conveyed the marital real estate of the partit~s to the Defendant. Defendant had retained legal counsel to prepare a deed, and Plaintiff went to Defendant's attorney's office and signed the deed to convey the real estate pursuant to the terms of the Agreement. 5 The Agreement contemplated a final resolution of all ec~onomic issues, including any support obligations, and contemplated the parties obtaining a divorce with no further claims being asserted by either party against the other even though explicit language to that effect was not included in the Agreement as drafted by Defendant. 6 Defendant has now instituted an alimony pendente lite claim against Plaintiff which alimony pendente lite claim is docketed at P ACSES Number 017104946. The APL claim is currently scheduled for a hearing de novo before the Support Master. 7 Plaintiff asserts that the Agreement prohibits Defendant from filing an alimony pendente lite claim. 8 Defendant has also filed an Answer to the Divorce Complaint filed in this matter in which Answer Defendant raises various economic issues. 9 Plaintiff asserts that Defendant is not entitled to raise any economic issues in the divorce action based upon the comprehensive settlement between the parties as set forth in the Agreement. WHEREFORE, Plaintiff requests your Honorable Court to declare that the Agreement is a valid comprehensive Property Settlement Agreement between the parties, and that the terms of the Agreement prohibits the Defendant from asserting any alimony pendente lite claim or asserting any other economic claims in the divorce adion. Respectfully submitted, As per agreement between Roxane P. Wilson & Jerry L. Wilson on 12 M2lrch 2002, 1. Roxane is the plaintiff in the divorce proceedings. 2. Roxane will pay Jerry $1,000.00 within 3 years of the sale date of the house located at 2119 Pine Road, Newville, P A. 3. Roxane will obtain a mortgage to cover current 1st mortgage at USAA and 2nd mortgage at Member's 1st FCU. Jerry willing to sign any necessary paper work required. my new mortgage company to remove his name from the house located 2119 Pine Road, Newville, P A. 4. The sale of the frame shop will go to paying the Visa Credit Card at Members 1st and any e:>.1ra will go towards payment of Jenna's car. 5, Roxane and Jerry will use the same divorce attorney, Hubert Gilroy, for an uncontested divorce and split the cost of attorney fees 50/50. 6. Roxane can use the riding lawn mower thru the sununer of 2005 at which time Jerry will take possession of. '" J' t7 fl-A-</f ~ (e~ ~-N-.L-~' W~ 3-lrl-O~ /~ p1~ ~dZ Subscribed and sworn ~~ me, this ~ day of ., 8 Notary Public in and for County. State of NOTARiAl SEAl SHIRLEY A. KENNEDY NOTARY PU PENN TWP" COUNTY OF CUMBER~g MY COMMISSION EXPIRES JULY 18, 2005 EXHIBIT I IIA" I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA.C.S. Section 4904 relating to unsworn falsification to authorities. DATE: a ( m M.--O 3 e()~ '"TJ [;:i -::::-:-. ~'- - (jj .. ~ . ~; ~,~:~ ("" ..... ( (~*'~ '~... :"-..) CJ, "j r.....,) '-) 0..J JERRY L. WILSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LA W ROXANNE P. WILSON, Defendant NO. 02-3345 CIVIL TERM ORDER OF COURT AND NOW, this 2nd day of April, 2003, upon consideration of Plaintiff's Petition for Special Reliefin the Nature ofDec1aratory Judgment, it is ordered that: 1. A Rule is issued upon Defendant to show cause why Plaintiff is not entitled to the relief requested; 2. Defendant shall file an answer to the petition within 21 days of the date of this order; 3. The petition shall be decided under Pa, R.C.P~ 206.7; 4. Depositions shall be completed within 49 days of the date of this order; 5. Argument shall be held on Monday, June 23, 2003, at 3:30 p.m., in Courtroom No.1, Cumberland County Courthouse, Carlisle, Pennsylvania. 6. Briefs shall be submitted at least seven days prior to argument. BY THE COURT, Hubert X. Gilroy, Esq. Attorney for Plaintiff 1"'. I f r I I l / //)" { ,/ ~ i__~-o x:~ / :~ J.fWesley Oler~ Jr., J. V.... - ~ ~ 'I_/}3,-03 9- 1,...'" J'-" 1 I ("~I~ [i I V n\ ~'/ \ i,\.'::f \ t \-:JC ALi-]nn" 'T'.':_':- ;:::~I~Jno i1 t.: ~ ! J , G ~. Jacqueline M. Verney, Esq. Attorney for Defendant :rc In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION ROXANE P. WILSON ) Docket Number 02-3345 CIVIL Plaintiff ) vs. ) P ACSES Case Number 017104946 JERRY L. WILSON ) Defendant ) Other State ID Number ORDER OF COURT - RESCHEDULE A HEARING You, JERRY L. WILSON of 2 CENTRAL ST, NEWVILLE, PA. 17241-9493-02 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 on the 28TH DAY OF MAY, 2003 at 10: 30AM for a hearing. This date replaces 1. a true copy of your most recent Federal Income Tax Return, including W-2s,: as filed, ". 2. your pay stubs for the preceding six (6) months, 3 . the Income and Expense Statement attached to this order as required by Rille 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may havle available to you 6. information relating to professional licenses 7. other: the prior hearing date of MAY 21, 2003 You are further required to bring to the hearing: Service Type M Form CM-514 Worker ID 21302 WILSON V. WILSON PACSES Case Number: 017104946 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: ~3 YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND TJIE HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET }10RTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP: CUMBERLAND CO BAR ASSOCIATICN 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to , comply with the Americans with Disabilities Act of 1990. For inform~tion about accessible facilities and reasonable accommodations available to disabled individluals having business before the court, please contact our office at: {717} 240--6225. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-514 Worker ID 21302 Service Type M ,-. \.~. ':",",' " j'('j c..~ (") c:: ?:.. -ocr' C91J~ ~ ~~;~ ",~t <nY, ~ "17.'. ~~~I,(--i ):;-'s~ ~ .-j -- ...../ .......,. c:> (..0.) v '-0 ;;::0 \ -- o -n ....J -r: \'" . ,-r~ ',CJ ), (;~!. '\ r-=~~i .:~ (-) .'~nl '- ) :-"A 11 -<:.:. ~ :::: --1 ::> c> In the Court of Common Pleas of CUMBERLAND, County, Pennsylvania DOMESTIC RELATIONS SECTION ROXANE P. WILSON ) Docket Number 02-3345 CIVIL Plaintiff ) vs. ) PACSES Case Number 017104946 JERRY L. WILSON ) Defendant ) Other State ID Number ORDER OF COURT - RESCHEDULE A HEARING You, ROXANE P. WILSON of 2119 PINE RD, NEWVILLE, PA. 17241-9203-19 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 on the 28TH DAY OF MAY, 2003 at 10: 30AM for a hearing. This date replaces the prior hearing date of MAY 21, 2003 You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, lIS filed, 2. your pay stubs for the preceding six (6) months, '. 3. the Income and Expense Statement attached to this order as re:quired by Rule i 910 .11 (c);' 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. information relating to professional licenses 7. other: Service Type M Form CM-514 Worker ID 21302 WILSON V. WILSON PACSES Case Number: 017104946 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: · JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP: CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For informaJtion about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of2 Form CM-514 Worker ID 21302 Service Type M g ~.-... -0 (i~ fT'"\ n -;; ~., z{ tit" 2:'" ,_.. b(-" J:'" c~ ?~, -<: ,.::.:,.,'.-', ..~ ...... ~J r-LVJ ti:j CJ (..) ~ -;;Cl \ o "" ~: "!d Sj; ;"f' C"j "1 (~) 'II --n (') ,II -1 :::> JERRY L. WILSON, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - DIVORCE ROXANE P. WILSON, Defendant/Petitioner : NO. 2002-3345 CIVIL : PACSES NO. 017104946 PETITION TO MODIFY ALIMONY PENDENT LITE AND NOW, comes Petitioner, Roxane P. Wilson, by and through her attorney, Jacqueline M. Verney, Esquire and represents the following in support of her Petition to Modify Alimony Pendente Lite: 1. Petitioner, Roxane Wilson was awarded alimony pendente lite at the above P ACSES number in the amount of 469.00 per month. 2. Said amount included an offset for a child support payment to Respondent in the amount of$195.25 per month. 3. The basis of the offset was that Petitioner's child, Jessica Furby resided with Respondent. 4. On March 31,2003, Jessica Furby relocated to North Carolina to live with her Father. 5. The change in residence of Jessica Furby constitutes changed circumstances requiring a modification of the alimony pendente lite award. WHEREFORE, your Petitioner requests that a support conference be scheduled to recalculate the APL award. Respectfully submitted, ~-17-03 acq line M. Verney, Esquire 44 South Hanover Street Carlisle, PA 17013 (717) 243-9190 Attorney for Petitioner VERIFICATION I verify that the facts included in the within Petition are true and correct based on information known to me or received from reliable sources. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S.A. S 4904 relating to unsworn falsification to authorities. Dated: if -/7 -0.3 --r7 () - -=--K~ r. Roxane P. Wilson w~ CERTIFICATE OF SERVICE I, Jacqueline M. Verney, Esquire, hereby certifies that a true and correct copy of the foregoing Petition was served upon the following on the date indicated by the following means: Postage prepaid, US Mail: Hubert X. Gilroy, Esquire 4 North Hanover Street Carlisle, P A 17013 Date: [/-1 f/v 3 .tI~ acq ine M. Verney, Es~:D1167 44 South Hanover Street Carlisle, PA 17013 (717) 243-9190 Attorney for Petitioner :f 0 CJ C '-~;' 2" ""oj" :-- t Q)f -':1 ~' :::'j ...-:"- (j) ._J -...... ~ ~:2 --"J .:.- t> ~~~~ ~ :.::i r:- . ::~ --~ -..... -h J.. -1 , e JERRY L. WILSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2002-3345 CIVIL TERM ROXANE P. WILSON, Defendant : CIVIL ACTION - LAW : IN DIVORCE ANSWER TO PETITION FOR SPECIAL RELIEF/RULE TO SHOW CAUSE AND NOW, comes the Defendant, Roxane P. Wilson, by and through her attorney, Jacqueline M. Verney, Esquire and in support thereof represents the following: 1. Admitted. 2. Denied. It is specifically denied that the parties separated on September 5, 2001. By way of further answer, Defendant believes and therefore avers that the parties separated December 5, 2001. Strict proof is therefore demanded of said averment. 3. Denied in part and admitted in part. It is admitted that Exhibit "A" was executed on March 12,2002. By way of further answer, Defendant was the scrivener of the provisions set forth in Plaintiffs Exhibit "A", which Plaintiff dictated. It is denied that the "Agreement" was intended to be a comprehensive property settlement agreement. The limited purpose of Exhibit "A" was to effectuate the transfer of the marital home and refinance the mortgage in Defendant's name alone because Plaintiff threatened to force Defendant out of the home. By way of further answer, several provisions ofthe so-called "Agreement" have not been followed by Mr. Wilson. 4. Denied in part and admitted in part. Defendant admits that the marital real estate was transferred to the Defendant and that Defendant retained legal counsel to transfer the deed to Defendant. Defendant is without sufficient knowledge to admit or deny whether or what Plaintiff relied upon and strict proof is demanded thereof. By way of further response, several provisions of the "Agreement" have not been complied with. 5. Denied. It is specifically denied that the "Agreement" was intended to be a final resolution of all economic issues, including support obligations. To the contrary, the document was written at the insistence of the Plaintiff who threatened to force Defendant out of the house if she did not agree to refinance it in her individual name. By way of further answer, the "Agreement" does not equitably divide other marital assets, i.e., personal property, vehicles, bank accounts, investments, or include a waiver of retirement assets, spousal support, APL or alimony. 6. Admitted. 7. Denied. It is specifically denied that the "Agreement" prohibits Defendant from filing an APL claim and strict proof thereof is demanded. By way of further answer, the "Agreement" is silent as to APL. 8. Admitted. 9. Denied. It is specifically denied that the "Agreement" prohibits Defendant from raising any economic issues in the divorce action. Defendant further denies that the "Agreement" is a comprehensive settlement agreement. By way of further answer, the "Agreement" is silent as to the economic issues of equitable distribution, alimony, APL and spousal support, and counsel fees and expenses. No waiver of those economic issues is included therein. WHEREFORE, the Defendant requests this Honorable Court to deny Plaintiffs request to declare the Agreement a comprehensive property settlement agreement of the divorce action and permit the APL claim and the request for equitable distribution, counsel fees and expenses to proceed. Respectfully submitted, L/ / .1--;) - D3 W J1(< ;i, acq line M. Verney, Esquire # 23 ~ 44 South Hanover Street I Carlisle, P A 17013 (717) 243-9190 Attorney for Defendant VERIFICATION I verify that the facts included in the within pleading are true and correct based on information known to me or received from reliable sources. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S.A. S 4904 relating to unsworn falsification to authorities. Dated: L} -Jd. -03 . '~~ ~. W~ Roxane P. Wilson CERTIFICATE OF SERVICE I, Jacqueline M. Verney, Esquire, hereby certifies that a true and correct copy of the foregoing pleading was served upon the following on the date indicated by the following means: Postage prepaid, US Mail: Hubert X. Gilroy, Esquire 4 North Hanover Street Carlisle, PA 17013 Date: L/_"J.";J,, -03 _ ~\l ~r Jacq line M. V emey ,ES:;' #23167> v44 South Hanover Street Carlisle, PA 17013 (717) 243-9190 Attorney for Defendant () c, (') c: C4,J ,1 ..~~;..... :7-.... i ... J [', --".l rTi (, ":'J ~ "- .) ~ ., (; , r', r' '. ~~.". ...::::.. s:~ ~) >',J - '~I - ~ .~'~ -< OFFICE OF SUPPORT MASTER Domestic Relations Section Cumberland County, Pennsylvania 9 North Hanover Street P.O. Box 320 Carlisle, Pennsylvania 17013 (717) 240-6245 FAX (717) 240-7777 Michael R. Rundle Support Master Vicky A. Stephenson Office Manager/Stenographer April 25, 2003 Hubert X. Gilroy, Esquire BROUJOS & GILROY, P.C. 4 North Hanover Street Carlisle, PA 17013 Jacqueline M. Verney, Esquire 44 South Hanover Street Carlisle, PA 17013 Jerry L. Wilson v. Roxanne P. Wilson No. 2002-3345 CIVIL PASCES #017104946 Dear Counsel: In the interests of judicial economy I believe the proper course of action is to continue the alimony pendente lite hearing scheduled before me for May 28, 2003 pending the outcome of the Declaratory Judgement action initiated by Mr. Gilroy on behalf of Mr. Wilson.. Please note, however, that a continuance of the hearing does not relieve Mr. Wilson of his obligation to pay the interim order pending the final outcome of this case. I have no authority to stay the APL order. It appears that Judge Oler has impliedly refused to grant Mr. Wilson's request for a stay by the absence of a stay in the order of April 2, 2003. Argument in the Declaratory Judgement action has been scheduled by Judge Oler for June 23, 2003. I will tentatively schedule the APL hearing for late July. Very truly yours,." (1 \ . . ,;) , ) , ,\, \.l L ~,<\_,'--C I, /c:c,-.,-,.t "- Michael R. Rundle Support Master CCIOL MRR/vas cc: Honorable J. Wesley Oler, Jr. (") ~ "1:) Q~ ml' ~/ C/) ',. rSf~ ~'--' -"","- ~C~ ,,-0 .....C z ::< I:-~' ,::"''IC a r'lTlf.: d ('"" c.' 1:".... ",) cc ..-:.-.,. ... .,;. ~ ~~) r:- (.0 . " ,~~~! 1;:1' :< JERRY L. WILSON, PlaintifflRespondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2002-3345 CIVIL TERM ROXANE P. WILSON, DefendantlPetitioner : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO WITHDRAW PETITION FOR SPECIAL RELIEF TO THE PROTHONOTARY OF SAID COURT: Please withdraw Defendant/Petitioner's Petition for Special Relief. Respectfully submitted, & -/:;1-03 cq ine M. vernt~Es~~7 44 South Hanover Stre:et Carlisle, PA 17013 (717) 243-9190 Attorney for Defendant/Petitioner cc: Honorable J. Wesley Oler, Jr. Hubert X. Gilroy, Esquire 0 co C) c: w:: , 1 '" '- -rJt<) ~- nln Z~i ~ '; L ~ l""J C) !;::: -c> ~1"1 ~ ( ) ,.~:::: Z I~ j )> c N ;~;1 C~ ~ 2~ :,.) .c.c_~ ::;! "n <:) :<: JERRY L. WILSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW ROXANNE P. WILSON, Defendant NO. 02-3345 CIVIL TERM ORDER OF COURT AND NOW, this 13th day of June, 2003, upon consideration of Defendant's Praecipe To Withdraw Petition for Special Relief, the hearing previously scheduled for June 12, 2003, is cancelled. BY THE COURT, J. Hubert X. Gilroy, Esq. Attorney for Plaintiff Jacqueline M. Verney, Esq. Attorney for Defendant ~.~ l.,./7.03 C+-. :rc VINV/ilASNN=Jd r I!\;fi,......,;-. (."~ './""";:. "."Arnl'"\ l\J..I,; ,',..'", ,I '.. "., ;;..', ."l.'~llv i '1 :8 ! i'/ f. I i,liI' CO Jt... ,d;j:,/ JERRY L. WILSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW ROXANNE P. WILSON, Defendant NO. 02-3345 CIVIL TERM ORDER OF COURT AND NOW, this 23rd day of June, 2003, upon consideration of the attached letter from Hubert X. Gilroy, Esq., attorney for Plaintiff, the hearing previously scheduled for June 23, 2003, is cancelled. BY THE COURT, ({ J. Hubert X. Gilroy, Esq. Attorney for Plaintiff Jacqueline M. Verney, Esq. Attorney for Defendant ~ ~ - J. t.f-Oj :)/<:; :rc - ..... IJINV^lASNN3d ^-lJ"lnOJ m.IJ"!Y38iflflO 2<: :6 i1V i-JZ Imr CO Al:IVlOI\Ohi:Ckki :;\11 jO 3::ll::l:io-<Bl\:l JOHN H. BROUJOS HUBERT X. GILROY BROUJOS & GILROY, P.c. ATTORNEYS Ar LAW 4 NORTH HANOVER STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 243-4574 FACSIMILE: (717) 243-8227 jbroujos@broujosgilroy.com hgilroy@broujosgilroy.com NON-Toll FOR HARRISBURG AREA 717-766-1690 June 20, 2003 The Honorable J. Wesley OIer, Jr. Cumberland County Courthouse One Courthouse Square Carlisle, P A 17013 Re: Wilson v Wilson I No. 2002 - 3345 Dear Judge Oler: This letter confinns our advice to Ruth that the parties have settled the case and the hearing in the above matter scheduled before you on Monday, June 23, 2003 can be cancelled. Thank you for your cooperation. Sincerely yours, dI Hubert X. Gilroy dca cc: Jerry Wilson Jacqueline M. Verney, Esquire JllIY 2 3 (00) State Commonwealth of Pennsvlvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 08/05/03 Tribunal/Case Number (See Addendum for case summary) q~ OO'.)Y../4 IOqq%q~ on IDY Q410 o'2.-~345 ~ o Original Order/Notice @ Amended Order/Notice o Terminate Order/Notice ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT DFAS CLEVELAND CENTER' C/O DFAS CODE L GARNISHMENT OPS PO BOX 998002 CLEVELAND OH 44199-8002 RE: WILSON, JERRY L, Employee/Obligor's Name (Last, First. MIl 182-46-2150 Employee/Obligor's Social Security Number 2559000022 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (last, First, MI) EmpJoyerNVithholder's Federal EIN Number See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's!obligor's income until further notice even if the Order/Notice is not issued by your State. $ 714.33 per month in current support $ 86 . 67 per month in past.due support Arrears 12 weeks or greater? @yes 0 no $ 0.00 per month in medical support $ 0 . 00 per month for genetic test costs $ per month in other (specify) for a total of $ 801.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 184,85 per weekly pay period. $ 369.69 per biweekly pay period (every two weeks). $ 400.50 per semimonthly pay period (twice a month). $ 801.00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate!date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's! obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #10 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAil. Date of Order: AU6 06 2003 EN-028 Worker 10 $IATT Service Type M OMB No.: 0970-0154 (") C :?' "'tl;:=r cpn Z-:! 21 Ui,t -<., r<c. 2::(" ~C )>{o. ~ c~ (.~; :t-.... () Cl :~J I 0::;, ,-" l.) -~ (> 'r-. ,:L-:! ~~5f'~ ~~ =< :;..' ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If, checked you are required. to provi(le a copy of this form to YOUc employee, If your employee whorkbs in.a state hthat iSd different from the state that Issued thIs order, a copy must be provIded to your employee even If t e ox IS not c ecke . 1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned businesses located on a reselVation that choose to withhold in accordance with this notice. 2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax: levies in effect please contact the requesting agency listed below. 3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 4. * Repo.lil,g tLe r'aydate!D3ll:: of 'l/;thltold;l,g. You lllu~t lepolt tll~ p8ydAleldate of nitl,"oldil,g nl,~h .3t!.IIJihg tI,e p8yweht. Ti,l:: pa,datciddt. or ..itl,1 ,,,Idi,,g ;, iI,. dale 0', ..I,;cl, '",,,u,,1 .."' ..itl,kld f,,,,,, tl,. .,,,ple,..', ,,'ge'. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 5.' Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #10 below) 6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S ID: 2491016300 EMPLOYEE'S/0811GOR'S NAME: EMPLOYEE'S CASE IDENTIFIER: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: WILSON, JERRY L. 2559000022 DATE OF SEPARATION: 7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 8. liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to emptoy, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 10.' Withholding limits: You may not withhold more than the lesser of: 1 I the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.c. 91673 (bI1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWEI. ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 11. Additional Info: 'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (7171240-6248 or by internet www.childsupport.state.pa.us Service Type M Page 2 of 2 Form EN-028 Worker ID $IATT OMB No.: 0970-0154 ADDENDUM Summary of Cases on Attachment Defendant/Obligor: WILSON, JERRY L. PACSES Case Number 017104946 Plaintiff Name ROXANE p, WILSON Docket Attachment Amount 02-3345 CIVIL$ 450.00 Child(ren)'s Name(s): DOB PACSES Case Number 928000044 Plaintiff Name HEIDI J. MCLAUGHLIN Docket Attachment Amount 1099 OF 93 $ 351. 00 Child(ren)'s Name(s): DOB you ore required to enroll the child(ren) in any health insurance coverage available through the employee's/obiigor's employment. If you are required to enroll the child(ren) in any health insurance coverage available employee's/obligor's employment. PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. you are required to enroll the child(ren) in any health insurance coverage available employee's/obligor's employment. PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name{s): DOB Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. you are required to enroll the child(ren) in any health insurance coverage available employee's/obligor's employment. Addendum Form EN,028 Worker ID $IATT Service Type M OMB No., 0970-0154 JERRY L. WILSON, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COmiTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE ROXANE P. WILSON, Defendant/Petitioner NO. 2002-3345 CIVIL TERM IN DIVORCE Pacses# 0171 04946 ORDER OF COURT AND NOW, this 12th day of August, 2003, based upon the Parties' Property Settlement Agreement of June 20, 2003, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $450,00 per month payable monthly as follows; $450.00 for alimony pendente lite and $0.00 on arrears. First payment due next pay date. Arrears set at $212.15 as of August 12, 2003. The effective date of the order is June I, 2003. This Order is based upon the Parties' Property Settlement Agreement of June 20, 2003. A total of $2,960.96 in arrears is remitted pursuant to the Parties' Agreement. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C.S.s 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the P A SCDU to: Roxane P. Wilson. Payments must be made by check or money order. All checks and money orders must be made payable to P A SCDU and mailed to: P A SCDU P.O. Box 69110 Harrisburg, P A 17106-9110 Payments must include the defendant's P ACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. This Order shall become final ten days after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary for a hearing de novo before the Court. DRO: R. J. Shadday Mailed copies on Sl-lC; ..03 to: < BY THE COURT, Petitioner Respondent Hubert Gilroy, Esquire Jacqueline Verney, Esquire J. J. . . S;66. a neeci (') c: < .1:J[;' rnj' -;;>--[ 71 (fJ: E?i c -',~ "'::'-,- .,-:' 5:;:' C'!t '-'.) ~ c:: ~") o " -n I""":'; ;Tl {.J, " ,-~, ',.1 CJ , "'I 5F~ ."ml J..". ~_.a -< ''0 ...J State Commonw..alth of Pennsvlvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 08/05/03 Tribunal/Case Number (S..e Add..ndum for cas.. summary) q2<60~4 IOqQc.~q~ Dn tOY qy/o o2-~':!>4!:l ~ o Original Order/Notice (8) Amended Order/Notice o Terminate Order/Notice ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT DFAS CLEVELAND CENTER' C/O DFAS CODE L GARNISHMENT OPS PO BOX 998002 CLEVELAND OH 44199-8002 ~:WILSON, JERRY L, Employee/Obligor's Name {Last, First, MI} 182-46-2150 Employee/Obligor's Social Security Number 2559000022 Employee/Obligor'S Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (last, First, MI) EmployerJWithholder's Federal E1N Number Se.. Add..ndum for d..pend..nt names and birth dat..s associated with cases on attachm..nt. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee'sJobligor's income until further notice even if the Order/Notice is not issued by your State. $ 714,33 per month in current support $ 86.67 per month in past-due support Arrears 12 weeks or greater? <Xlyes 0 no $ 0.00 per month in medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ 801.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 184.85 per weekly pay period. $ 369.69 per biweekly pay period (every two weeks). $ 400.50 per semimonthly pay period (twice a month). $ 801.00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (101 working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydateldate of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #10 on pg. 2). If remitting by EFT/ED\, please call Pennsylvania State Collections and Disbursement Unit (SCDUl Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown abov.. as th.. Employ..../Obligor's Cas.. Id..ntifi..r) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. Date of Order: AVa 06 2003 EN-028 Worker 10 $IATT Service Type M OMBNo.:0970-0154 (') C...:.) () C (.~'~ f'l ~~ ;r...'"IM -nt"r.:; (Jlf) , S Z_, Z r:; , (j) (:e; -< r:::: t.. :2:(- L.; C~ .>c:: .~,) ~:j "' ~ ~u -< Sc,;;u-'nll<d ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If checked you are required to provide a Copy of this form to your ~mployee. If your employe~ works in.a state that is ditterent from the state that issued this order, a copy must be provided to your employee even ,f the box ,s not checked. 1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned businesses located on a reservation that choose to withhold in accordance with this notice. 2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency iisted below. 3. Combining Payments: You can combine withheid amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 4.' :;,~~:~g ~:'~.~~I~;/~~;e ~1';;;.;II,I,0Idi:'5'L YOu ",dSt "po,t Il.e p.ydatu'dalc of "ill,I,?ldi"g "I.e" ,,,,,di,,g II,e pay".'e"t. TI,. ".y I Ii,,, tl te 0" "l"d, a,,,ou,,t "as ",tl,I,<ld f,o,,, t1,e e",ploya, ",ge'. You must comply With the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 5. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See ill 0 below) 6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S ID: 2491016300 EMPLOYEE'S/OBlIGOR'S NAME: EMPLOYEE'S CASE IDENTIFIER: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: WILSON. JERRY L. 2559000022 DATE OF SEPARATION: 7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 10, * Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.c. ~l 673 (b)l; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 1 1. Additional Info: 'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: DOMESTiC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 if you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet ~ww.childsupport.state.pa.us Page 2 of 2 Form E N-028 Worker ID $IATT Service Type M OMB No_: 0970.Q154 ADDENDUM Summary of Cases on Attachment Defendant/Obligor: WILSON, JERRY L, PACSES Case Number 017104946 Plaintiff Name ROXANE P. WILSON Docket Attachment Amount 02~ CIVIL $ 450.00 Child(ren)'s Name(s): DOB PACSES Case Number 92B000044 Plaintiff Name HEIDI J. MCLAUGHLIN Docket Attachment Amount 10990F 93 $ 351. 00 Child(ren)'s Name(s): DOB If you are required to enroll the child(ren) above in any health insurance coverage available the employee'slobligor's employment. you are required to enroll the child(ren) in any health insurance coverage available employee's/obligor's employment. PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child!ren)'s Name(s): DOB Docket Attachment Amount $ 0.00 Child!ren)'s Name!s): DOB you are required to enroll the child(ren) in any health insurance coverage available employee's/obligor's employment. you are required to enroll the child(ren) in any health insurance coverage available employee's/obligor's employment. PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Docket Attachment Amount $ 0.00 Child!ren)'s Name(s): DOB If checked, you are required to enroll the child(ren) in any health insurance coverage available employee's/obligor's employment. you are required to enroll the child(ren) in any health insurance coverage available employee's/obligor's employment. Addendum Form EN-028 Worker ID $IATT Service Type M OMB No.: 0970-0154 " " . , S >:::: .P"HH~ ct e ~ -oO"i mrr, Z:J~" &5~- ~O "'c Zc'i :i>c ~ , ,. .'; ,. o (.AJ ". t-:= t:;') N N o -n .-, f1i:n -O~.. "n (5 '-'-:" )):ri _,0 orn ~ ~ -u :x ~ c- tv ~\\ .~U State Commonwealth of Pennsvlvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 08/05/03 Tribunal/Case Number (See Addendum for case summary) q2<60~4 IOqQ%q~ D n IDY q LJIo c"2 - ~ ~Y-l':> c.:........;Jl o Original Order/Notice @ Amended Order/Notice o Terminate Order/Notice ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT DFAS CLEVELAND CENTER' C/O DFAS CODE L GARNISHMENT OPS PO BOX 998002 CLEVELAND OH 44199-8002 RE: WILSON, JERRY L. Employee/Obligor's Name (Last, First, MI) 182-46-2150 Employee/Obligor's Sodal Security Number 2559000022 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, Mil Employer/Withholder's Federal fiN Number See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's!obligor's income until further notice even if the Order/Notice is not issued by your State. $ 714.33 per month in current support $ 86,67 per month in past-due support Arrears 12 weeks or greater? @yes 0 no $ 0.00 per month in medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ 801 .00 per month to be forwarded to payee below.. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold; $ 184,85 per weekly pay period. $ 369,69 per biweekly pay period (every two weeks). $ 400.50 per semimonthly pay period (twice a month). $ 801.00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's! obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #10 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. Date of Order: AUB 06 2003 BY THE COURT: Jd/ ~OLE EN-028 Worker ID $IATT Service Type M OMB No., 0970-0154 (') c ",- '"'tJCP" rn'"i ZLJ L.t en.:!" -< t< '.l>.. :Z:l...; cC ..-:;; ~ Scanned , ... C_, (.,'~ "'" .:~-) 1 (:;c. () fl I" C) -~ =L~ c: () ~:::i i " --, iiJ -< ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o Iflihecked you are required to prpvide a copy of this form to your employee. If yo~r employee works in a state that is di erent from the state that issued this order, a copy must be provided to your employee even if the box is not checked. 1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned businesses located on a reseNation that choose to withhold in accordance with this notice. 2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 4.* Repolt;llg tLe F'aydatefDale of'N;thLold;llg. YOu nllBt JepOIt'the paydcil'C/date ofwitLLoldil,g VVLl.Il selld;llo ti,e pay I Ilellt. TI,e- p21ydale/dal( vf vvitl.l.oldil,g;~ ll,e dale 01, nl,;d, cl.llloUltt vvd.:J nitl,l,eld fro". the el"ployee's n&ges. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withhold ing order and forward the support payments. 5.' Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #10 below) 6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S ID: 2491016300 EMPLOYEE'S/OBLlGOR'S NAME: EMPLOYEE'S CASE IDENTIFIER: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: WILSON, JERRY L. 2559000022 DATE OF SEPARATION: 7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the Statf! in which he or she is employed governs. 10.' Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. 91673 (bl1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 11. Additional Info: 'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARliSLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at 1717) 240-6225 or by FAX at LZ1Z1..240-6248 or by internet www.childsupport.state.pa.us Service Type M Page 2 of 2 Form E N-028 Worker ID $IATT OMS No.: 0970-0154 ADDENDUM Summary of Cases on Attachment Defendant/Obligor: WILSON, JERRY L. PACSES Case Number 017104946 Plaintiff Name ROXANE P. WILSON Docket Attachment Amount 02=3345 CIVIL$ 450.00 Child(ren)'s Name(s): DOB PACSES Case r-lumber 928000044 Plaintiff Name HEIDI J. MCLAUGHLIN Docket Attachment Amount 10990F 93 $ 351. 00 Child(ren)'s ~'ame(s): DOB If you .re required to enroll the child(ren) above in any health insurance coverage available the employee's/obligor's employment. you are required to enroll the child(ren) in any health insurance coverage available employee's/obligor's employment. PACSES Case Number Plaintiff Name PACSES Case \lumber Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Docket Attachment Amount $ 0.00 Child(ren)'s I,ame(s): DOB o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. If you are required to enroll the child(ren) in any health insurance coverage available ernployee's/obligor's employment. PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Docket Attachment Amount $ 0.00 Child(ren)'s \lame(s): DOB o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. you are required to enroll the child(ren) in any health insurance coverage available employee's/obligor's employment. Addendum Form EN-028 Worker 10 $IATT Service Type M OMB No.: 0970-0154 . , 'S.;c~~.('"\n~d 8 g: -oeD mrr, Z::l"' ~5!; ~c~; ~Q ~E ~ " . ,. .; r. o w x- C G") l'.) N ~ .-1 ff\:D .,..'D,..~r- Q :.) ~,(-!i '_.,-(.C') 75fn .~ ~ ::i! -u ::II: ~ "'" r" (( II '~\J ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsvlvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 10/30/03 Tribunal/Case Number (See Addendum for case summary) o Original Order/Notice (8) Amended Order/Notice o Terminate Order/Notice DFAS CLEVELAND CENTER< C/O DFAS CODE L GARNISHMENT OPS PO BOX 998002 CLEVELAND OH 44199-8002 RE, WILSON, JERRY L. Employee/Obligor's Name (Last, First, MI) 182-46-2150 Employee/Obligor's Social Security Number EmployerMtithholder's Federal EJN Number 1>#. ;;za;:z. -!5::1 Jls- ell/Ie ~~'>C-s O/7/c'!9Ytp W. /C?9 $' /"193 l'1fa~g. f~'3''' 'I OLJyr 2559000022 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associatPd with cases on attachment) Custodial Parent's Name (last, First, MI) See Addendum tpr dependent names and birth dates associated with cases on attachment. ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 714.33 per month in current support $ 0 . 00 per month ih past-due support Arrears 12 weeks or greater? 0 yes @ no $ 0.00 per month ih medical support $ 0 . 00 per month for genetic test costs $ per month in other (specify) for a total of $ 714. 3~ per month to be forwarded to payee below. You do not have to vary your f!lay cycle to be in compliance with the SUPPOlt order. If your pay cycle does not match the ordered support payment dycle, use the following to determine how mu.ch to withhold: $ 164.85 per weekly pay period. $ 329.69 per biweekly pay period (every two weeks). $ 357.17 per semimonthly pay period (twice a month). $ 714.33 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment 1Vithin seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost 'of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total ""ithheld amount, and your fee, cannot exceed 55% of the employee's! obligor's aggregate disposable weekly e~rnings. For the purpose of the limitation on withholding, the following information is needed (See #10 on pg. 2). If remitting by EFT/EDI, pleaselcall Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payabl~ to: PA SCOU Send check to: Pennsylvar.ia SCOU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS M,"-,ST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligolr's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAtt..." ,~" _.. ~J.J.lFl;P r~'.'.B. YTHECOURT:~ 4 --~S_!;'!!!JU;.;_J'.,:,,; , Date of Order: OCT 3 1.- / / - y- p ~ -=- (....p t:) .J ~.r::>L Form E N-028 Service Type M OM8 No.; 0970-0154 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If (;hecked you are required to provide a Copy of this form to your employee. Ifyo~r employee works in a state that is ditterent from the state that issued this order, a copy must be provided to your employee even if the box is not checked. 1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned businesses located on a reservation that choose to withhold in accordance with this notice. 2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 4.* RepOltil,g II,,, PArdate/Dal" af Witl,l ,aiding. 'tau I,,".t "'pM tl.e pardareldate of ..ithl.aldil.g ..11"" "",di"g tl,e PAri,,",,!. TI,e payd6.tu'date of n;ll,I,oldil,g;~ tl,o.;. Jate 01, vv!,;d. al"oUlft n6.;, nitl,lrdd {,O". tl,e elllployee's nage.3. You must comply with the law of the state of the employee's/obligor's prin~ipal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 5. * Employee/Obligor with Multiple ~upport Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are u~able to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #10 below) 6. Termination Notification: You m~st promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information reque~ted and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S ID: 2491,016300 EMPLOYEE'S/OBLIGOR'S ~AME: EMPLOYEE'S CASE IDENTI IER: LAST KNOWN HOME AD RESS: NEW EMPLOYER'S NAME/ADDRESS: WILSON. JERRY L. 2559000022 DATE OF SEPARATION: 7. Lump Sum Payments: You may b$ required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 8. Liability: If you fail to withhold in~ome as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor'Si income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. Anti-discrimination: You are subj~ct to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 10. * Withholding Limits: You may n<!>t withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.5.c. ~1673 (b)l; pr 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxesi Social Security taxes; and Medicare taxes. 11. Additional Info: * NOTE: If you or your agent are *erved with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: DOMESTIC RELATIONS SEctiON 13 N. HANOVER ST ' P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at !ZlZL'40-6248 or by internet www.childsupport.state.pa.us Service Type M Page 2 of 2 Form E N-028 Worker ID $IATT OMB No.: 0970-0154 ADDENDUM Summary of Cases on Attachmen! Defendant/Obligor: WILSON, JERRY L. PACSES Case Number 017104946 Plaintiff Name ROXANE P. WILSON Docket Attachment Amount 02-3345 CIVIL$ 450.00 Child(ren)'s Name(s): DOB PACSES Case Number 928000044 Plaintiff Namg HEIDI J. l~CLAUGHLIN Docket Attachment Amount 10990F 9.3 $ 264.33 Child(ren)'s Name(s): DOB you are required to in any health employee's/obligor's the child(ren) coverage available you are required to enroll the child(ren) in any health insurance coverage available employee's/obligor's employment. PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB If checked, you are required to above in any health the employee's/obligor's you are required to enroll the child(ren) in any health insurance coverage available ernployee's/obligor's employment. PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff Name Docket Attach ment Amou nt $ 0.00 Child(ren)'s Name(s): DOB Docket Attachment Amount $ 0.00 Child(ren)'s I'ame(s): DOB you are required to in any health employee's/obligor's o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. Service Type M Addendum Form E N-028 Worker 10 $IATT OMBNo.:0970.0154 ",.. ':~\'fljll.tW~-.<'Z.i1' g z -o(~\ rn\"1 2:;\. Z~ ~~.. ':2'- ?iC =L .,v~j. L_ 2 c:> w ~ :.,? ..-;: \ CP ..~, ::.~: '. o -n --n ~ N o 'f:'"; -, '1' Q ~.\ l) p' ~ ? ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Jerry L. Wilson Plaintiff Vs File No. 2002-3345 IN DIVORCE Roxane P. Wilson Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking ''x''] ~ prior to the entry of a Final Decree in Divorce, or _ after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of ~a.c.e..... , and gives this written notice avowing his / her intention pursuant to the provisions of 54 P .S. 704. Date: ~- 11- 0<-\ ~CLv-.>'- ~CJ..U-- \,o~~ Signature COMMONWEALTH OF PENNSYLVANIA COUNTY oFtu WI bulJ-.) On the ~ day of ~+- , 2001, befon: me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. ,: WHn~' Wh<=, I Imv''''''''''''' ," ~yr h~d offici. -U~ .- Notary ~) lie ~Q,\O-~ ~QUL..- Signature of name being resumed "Ko y a.n e. P IH!. e.... ) [4 N01lMLIEAL \IW ..A....~NIiI CIIIIII.... ~.il ..,c...... . ... eM. c:& -t '" c:::;, c;::~ ~ ~ -1;:.- ;;.,""" (::::: r G') "- ~ -.J \l., "" 1\ ..., ~ -.""" .. & C:) C;"l r ' j!.i ...".n;-' J if ~*..r\,!,",~ .~.JJ M!W. i .i\":'~~lt.!~,Ilt.'4l<<loh:) I ... :~JIO~~~"" .1 3301 (c ).not JERRY L. WILSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : 02-3345 CIVIL TERM ROXANNE P. WILSON, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OI<' INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of th.~ Divorce Code was filed on July 15,2002. 2. Defendant acknowledges receipt and accepts service of the Complaint on or about July 17,2002. 3. The marriage of the Plaintiff and Defendant is irretdevably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. 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. 6. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is fIled with the Protbonotary. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. 1 verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa"C.S. ~4904 relating to unsworn ::uti~::s- ~ ~ JERRY L. '~ON/Plaintiff ,~ ,,) ;--:'.1 \~:,::) i.A '-- c! -on ~_.:~ N ,'-.) c.....:.' - 3301(c).001 JERRY L. WILSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v 02-3345 CIVIL TERM ROXANNE P. WILSON, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECRJ~E UNDER SECTION 330I(c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on July 15,2002. 2. Defendant acknowledges receipt and accepts servil:e of the Complaint on or about July 17,2002. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. 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. 6. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is fded with the Prothonotary. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counselhig. I do not request that the Court require counseling. I verify that the statements made in this affidavit are trul~ and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: \ - 1\ - 05 ~ n . \""\(~ r Cl~ \0.J..w".,; ROXi E P. WILSON/Defendant -, t.."_ (-:-- {-) C;?j c~ 'Z';'" ...-," ~~:: '. '- ?': ::;.... -- c:> c'> .;.. PROPERTY SETTLEMENT AGREEMENT THIS IS AN Agreement made this -;x,11 day of d c......,. , 2003, by and between JERRY L. WILSON, (hereinafter referred to as Hus and) and ROXANE P. WILSON, (hereinafter referred to as Wife). WHEREAS, Husband and Wife were married on July 19, 1993; and WHEREAS, various differences have arisen between Husband and Wife, whereby they have been living separate and apart; and WHEREAS, the Husband hils commenced a divorce action against Wife docketed at No. 2002-3345 in Cumberland County, Pennsylvania; and WHEREAS, the parties desire to enter into an amicable settlement to provide for all of the property rights of the parties and to dispose of the rights and obligations of each to the other in respect to support, maintenance, alimony, counsel fees, equitable distribution, and all other rights and obligations under the Divorce Code of 1980, as amended, and it is the intention and agreement of the parties that this Agreement be a full, complete and final settlement of all of those rights and obligations under said Divorce Code; and NOW, THEREFORE, for and in exchange of mutual considerations, and intending to be bound by the provisions hereof, the parties agree that their recitals fonn a part of this Agreement and waive any right to counseling under the Divorce Code of 1980, as amended, and right to counsel fees, costs, alimony, support, maintenance, and any other rights under the said Divorce Code not provided for herein and agree as follows: 1 The parties agree that it shall be lawful for each party, at all times hereafter, to live separate and apart from the other, at such place or places as he or she may, from time to time, choose or deem fit. Each party shall be free from interference, authority or 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. Additionally, neither party shall initiate any harassing or inappropriate contact with relatives of the parties. 2 The parties agree that the APL Claim filed by Wife against Husband at the Cumberland County Domestic Relations Office at PACSES No. 017104946 shall be modified as follows: A. The monthly payment from Husband to Wife shall be $450.00 per month effective June 1,2003. B. All arrearages shall be eliminated effective June 1,2003. C. The payments shall continue through December 2004 with the last payment being due for the month of December 2004 on December 1, 2004. The Order shall be terminated December 31, 2004. D. The Order shall not be subject to modification by either party during the timeframe as set forth in this paragraph. E. The parties agree that the monies paid pursuant to the Order shall not be deemed to be spousal support or alimony but shall be deemed for tax purposes to be a payment from Husband to Wife in the nature of distribution of marital property. Regardless, the parties agree that the payments shall continue to be made through DRO by a wage attachment issued through Husband's employment. F. The parties agree to execute all documentation necessary to effectuate the above with the Cumberland County Domestic Relations Office. 3 Husband shall pay to Wife the sum of $2,000.00. Said payment shall be made with a payment ofSl,OOO.OO upon signing of this agreement and a payment ofSl,OOO.OO within thirty (30) days of tbe date of signing of this agreement. Said payment shall represent distribution of marital property. 4 The parties shall remain married through December 2004. On January 1, 2005, the parties agree that each of them will execute a Consent Affidavit and all other necessary documentation in order for Husband to proceed with and finalize the divorce of the parties. have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or courtesy of claims in the nature of dower or courtesy, or widow's or widower's rights, family exemption or similar allowance or under the intestate laws; or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary or all or other rights of the surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory of the United States, or any other country or any right which either party may now have or at anytime hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is the intention of Husband and Wife to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. 18 Each party individually covenants and agrees that he or she will individually assume the full and sole responsibility for legal expenses for his or her attorney and court costs in connection with any divorce action which may be brought by either party and shall make no claim against the other for such costs or fees. 19 Each of the parties shall, from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments or documents that may be reasonably required to give full force and effect to the provisions of this Agreement. 20 A 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 the 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. 21 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. 22 It is specifically understood and agreed by and between the parties thereto that each paragraph hereof shall be deemed to be a separate and independent agreement. 23 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 or seek such other remedies or relief as may be available to him or her and the party breaching this Agreement shall be responsible for payment of legal fees and costs incurred by the other in enforcing the rights under this Agreement, or in seeking such other remedies or relief as may be available to him or her. 24 This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 2S If any tenn, condition, clause or provision of this Agreement shall be detennined or declared to be void or invalid in law or otherwise, then only that tenn, 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. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written. WITNESS h..J ~ k.Vo -\Z0--.\-CvvJ-- ~. \0: \ ^ ^- ") ROXANEP. WILSON ...., C';) <,.;:;,l cJ' <- -,. ~ (,') c.>" -v '41 9--" f"il i~:, "'nr~l "cr :j( ~ 1.. (, '-'-.-n (' ')::"'- -'.- '-) >.~, In ~~'1~ -- '-!? C) (..i'\ ":'1 -< JERRY L. WILSON, Plaintiff, :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v NO. 02 - 3345 CIVIL ROXANNE P. WILSON, Defendant, IN DIVORCE AFFIDAVIT OF SERVICE I, Hubert X. Gilroy, being duly sworn according to law do depose and state that a copy of the Complaint and Notice to Plea filed in the above referenced matter was served on Defendant Roxanne P. Wilson, by certified mail on July 17,2002. A copy of the Certified Mail- Return Receipt Requested, Restricted Delivery, is attached hereto and marked Exhibit A. !~)C-D r- DATE Hubert X. Gilroy, squire Attorney for PI . tiff Broujos & Gilroy, P.c. 4 North Hanover Street Carlisle, PA 17013 717 - 243-4574 Sworn and subscribed before me this ~ / day o()v-\A.O"j , 20~ C, CcJ cv- ' Notarial S~al ,. Bridget Ann Corcoran. Notary Public Carlisle Boro, Cumberland County My Commission Ex-pires June 10, 2{}O6 \ Member, Pp,nn3',""/:1n:a Association of NotanG~~ . , . Complete Items 1, 2, and 3. Also complete item 4 jf Re~trjcted Delivery Is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on ~he front if space permits. 1. ~icle Addressed to: 'RoXC,JH'k, P. Olson ~ I I "lP'f1~K"e..cR Newvl/l...,PA 17:;41 .. 2. Article Number (Copy from service. /aOOO PS Form 3811, July 1999 D. Is delivery address different from item 1? If YES, enter delivery address below: o Agent Addressee DYes DNa 3. Service Type Ci! Cert~led Mail o Registered o Insured Mail O' Express Mail t8 Return Receipt for Merchandise 0(').0.0. 4. Restricted Delivery? (Extra Fee) I5a Yes '1011 3,!oQ oo/~ So<t, 330'-/ Domestic Return Receipt 102595-00-M.0952 EXHIBIT IA t',., ~.~~:~ LJ'" '- ~::-c-'" 2': -( r" u' C) ~n .-j ".:.-L....f1 '1.1 f-'" .-"1(1"l -:ill? I" ,,:~t~) . ~;'~ :,~"r{ <;f~ , 'l> "~J :-< -:J c.) C) (..Ii JERRY L. WILSON, Plaintiff, :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v NO. 02 - 3345 CIVIL ROXANNE P. WILSON, Defendant, IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for Divorce: Irretrievable breakdown under Section (x )3301(c) ()3301(d)(I) of the Divorce Code. (Check applicable section.) 2. Date and manner of service of the Complaint: July 17,2002, First Class Mail, Return Receipt Requested. 3. (Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By Plaintiff: January 6,2005; Defendant: January 11,2005. (b) (1) Date of execution of the Plaintiff's affidavit required by Section 3301(d) of the Divorce Code:_; (2) Date of service ofthe Plaintiff's affidavit upon the Defendant:_. 4. Related claims pending: None. 5. Complete either (a) (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: January 12, 2005. (c) Date Defendant's Waiver of Notice in ~3302(c) Divorce was filed with the Prothonotary: January 18, 2005. Hub X. i1roy, quire Attorney for Plai Iff Broujos & Gilro , PC 4 North Hanover Street Carlisle, P A 17013 717-243-4574 "",,; ".,.,"1 (;-;-' ':":) <:~ c.... t) -,;1 "" p...) (,.... r<} ---------- ~, , . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . , . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .. . 1f.'" :+;;F. . .. :+:;F.;F. ;F.;F.;F.~ ;F.;F.~:+:;F.~;F.;F. ;F. :+::+; :+.:+::+::+::+::+: :f. '" :Ii:+::+: . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Jerry L. Wilson Plaintiff No. 02 - 3345 VERSUS Roxanne P. Wilson Defendant DECREE IN DIVORCE AND NOW, Fd". l - , 2.0""':': IT IS ORDERED AND DECREED THAT Jerry L. Wilson , PLAINTIFF, Roxanne P. Wilson AND , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAtMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT VET BEEN ENTERED; Property Settlement Agreement dated June 20, 2003 is incorporated into this Order. ~ ~ i .., -..:--~ Bv THE COURT: tiI- CTt~! PROTHONOTARY ";"- -~... .,- ".\..-' - -.- -~- ,- 7, , , . - '" , ... ~ .. . .-J..... '-' .' ,- . ./ ......... .......::. "- . ./:" '. ...~:..\-\~,'. .... ~~. . ... '- ...-........... :+. '+::+::f.:+: . . . . . . . . . . . . . . . . . . . . . . . . . . , . , . . . , . . . . , . . . , . . , . . . , . . , . , . , . , . . . . , , . , . , . , . , , . . . . . , . . . . J. , . . . , . . . , . . , 00.0.0.0.0.0.0.0.0.0.00.0.0.0.0.0.0.0.0. . ... . :+: :+::+: :+::+: ;,;'" :f.:+::+' :+::+: Of. . .. . . . . ~1'1 b- z r~' 77/" ~k ~ jjzv .2 /"'rwv ~? ~":) . , <,,\ .,c7 <::' t<' 5V I:'.: e In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION ROXANE P. WILSON ) Docket Number 02-3345 CIVIL Plaintiff ) vs. ) PACSES Case Number 017104946 JERRY L. WILSON ) Defendant ) Other State ID Number Order AND NOW to wit, this FEBRUARY 23, 2005 it is hereby Ordered that: THE THE WAGE WITHHOLDING ORDER FOR THE ABOVE MENTIONED CASE IS TERMINATED, EFFECTIVE IMMEDIATELY, AS THE CASE IS CLOSED AND THE ARREARS HAVE BEEN PAID IN FULL. DRO: RJ ShClddClY xc: defenddnt D F AS Cleveli::1nd BY THE COURT: Edw=d E'~~ JUDGE Service Type M Form OE-520 Worker ID 21005