Loading...
HomeMy WebLinkAbout94-05335 /) I'. - J 'i , I , I C <1... '::P ~ { <C ~ I I I I J I ! I l1) I I , , fY) I ~ , I I I i ~! cr,l I ~ \II ~ 1- Ii ... ~ <l - t ... @ , ~~. , a; ~ t ~l . :.~: .. :t: l:1_ , .. ~ r- " III , '.' I.''') ~ It) co., .... e. ~ VI " . . , " . . '. '- r RONALD D. ANTHONY, I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNT'i, PENNSYLVANIA plaintitt I I CIVIL ACTION - LAW v. I NO. '14 -,5 ~ ~ S- e" ;,( ;.Jtll>." I VIRGINIA E. ANTHONY, I I Defendant I IN DIVORCE HOTICI TO DI~IHD 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. rou are warned that if you fail to do so, the case may proceed w thout 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. 'iou may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse in carlisle, Pennsylvania [telephone number (717) 697-0371 or (717) 240-6100] . IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPf:RTY, LAW'iER'S Ff:ES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKf: THIS PAPER TO 'iOUR LAW'iER AT ONCE. IF 'iOU 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 Hf:LP. Court Administrator 4th Floor, Cumberland County Courthouse carlisle, pennsylvania 17913 Telephone: (717) 697-0371 or (717) 240-6100 . '- RONALD D. ANTHONY, I IN THE COURT or COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA plaintiff I I CIVIL ACTION - LAW v. I .. (1 .( OJ I NO. 74. .., ':~ ..~ ~ " " 0 t "'0.... VIRGINIA E. ANTHON'i , I I Defendant I IN DIVORCf: COMPLAINT IN DIVORCE 1. Plaintiff is RONALD D. ANTHON'i, who currently resides at 1810 Lambs Gap Road, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is VIRGINIA E. ANTHONY, who currently resides 503 South 20th Street, camp Hill, Cumberland County, Pennsylvania. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. July 5, 1987, The Plaintiff and Defendant were married on the in Camp Hill, Pennsylvania. 5. There are no pending actions for divorce or annulment between the parties. 6. The marriage ia irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that this Honorable Court require the parties to participate in counseling. . .. . RONALD D. ANTHONY, I IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA Plaintitt I I v. I NO. 94-5335 civil Term I VIRGINIA E. ANTHONY I I Detltndant I IN DIVORCE CIlRTIrICATB or BIRVICI I, Thomas M. Kutz, Esquire, do hereby certify that I served a true and correct copy of the Complaint in Divorce for the above captioned matter on the Defendant, VIRGINIA E. ANTHONY, by depositing a copy of the same in the United states mail, certified, restricted delivery, return receipt requested and postage prepaid. The r.eceipt for s~id certified mailing and the return receipt bearing the Defendant's signature and showing a delivery date of september 20, 1994, is attached. / , / /:" ';;{" // / ' 't /: . ,'<' / ~. ~ ;'~",fv' -< ~ ;It' ",) Thomas M. Xutz, Esquire At~rneY,tor Defendant ~9 Bast Main street Mechanicsburg, PA 17055 Attorney 1.0. NO. 38887 d ~; '\"'''I''!" ',j l~" .1'1 - ,I~ I . ~til:"l'""" 1:1:,'1,11 , j.\'h\j'H~~~n~~tt_l*l~irrj , ),~(;ri":i'- '- J ,,' ,./. ;,i',l,l _ tJ_:_.,', -'w~~*lt't1jIMltlJi r.tlhti.....,..i. Ocr " , " ~'I I IIJr!1 '95 'I , :',1' ., '\11\ 'i j~ I. ill 1',. I , , , " ','i' I ij " 'i ,i RONALD D. ANTHONY, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO 94-533!. CIVIL TERM VIRGINIA E. ANTHONY, Defendant IN DIVORCE AFFIDAVIT OF CONSENT TO DIVORCE (1) A Complaint in divorce under Section 3301 (e) of the Divorce Code was filed on "','I.\n.b., ";, \'~"','I (2) Defendant acknowledges that service of the Complaint was made by certified mail on ". ,\\" ~,I" "', ,<'1""'1 (3) The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. (4) I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. (5) I consent to the entry of a final decrep. of divorce. (6) I understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not been filed with the court before the entry of a final decree in divorce, the right to claim any of them will be loat, (7) I have been advised of the availability of marriage counselling and understand that I may request that the court require that my spouse and 1 participate in counselling. Being so advised, I do not request that the Court require that my spouse and I participate in counselling prior to a divorce decree being handed down by the Court. I verify tLat the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C.S. Section 4904 relating to unsworn falsification to authorf~ie~. . DATED: Ou: ~)L~ \'oc,~ 'tVv<,,\~ t., Q..::::o;L'J'~ Virginia E. Anthony, Defen~nt " ;1, Oct 'i. j I 4J ('Ii '95 i,'/ (;-i1 ill. ',i. 'll ~ 'II . , , , I, 1 " ,,' , , .. 'q ,'J; , , -'lJ'-'-- J ' i " ,; 1 , " ',' \ I, .' .' " .. ..~,_. , ~,j 5rr ZO q uu'I'Il'95 I.: , .1'. , , " " , '/~,~t) ~. I (!tJe.J' Ii"" /CJt't/ pt:ff ~q413 , , I I I I I I ,: I ! '\ I I; " tfI '" .' , ,\ \. .. - ..- HAR 30 2 lG PH '95 I' :U ":l "!to,': r.H.~' I. " '~;!i I Y 1'.\ ", l)r >,', r,IJliI ,'I,. I.' NIl " c, , " " !', , , !, 1'1; MAN 30 2 16 PH '95 ',t ',1'11'1' !"-ll,"',, :1 r I (T I' , " " " I' I' 11./ J ) li-, " -" I"" ","""'" f,i' t I I' .~ " . , I .. 1-1 .. ---~ RONALD D. ANTHON'i, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBf:RLAND COUNT'i, PENNSYLVANIA v. VIRGINIA E. ANTHONY, Defendant NO. 94-5335 CIVIL TERM BOUITABLE DISTRIBUTION AND NOW, comes the Plaintiff Ronald D. Anthony by and through his attorneys Saidis, Guido, Shuff & Masland and avers the following: 1. The Plaintiff is Ronald D. Anthony, an adult individual currently residing at 1810 Lambs Gap Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is Virginia E. Anthony, an adult individual currently residing at 503 S. 20th Street, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The Plaintiff filed a Complaint in Divorce to the above term and number on or about September 19, 1994. SAlOIS, GUIDO. SHUFF &: MASLAND 26 W, HISh Sire., Carlisle. PA 4. The Plaintiff and Defendant possess various items of both real and personal marital property which is subject to equitable distribution by this Court. WHEREFORE, Plaintiff requests this Honorable Court to equitably distribute the marital property. Respectfully submitted, SAlOIS, SHUFF & MASLAND Dated: }- 3/ .. 9S- ./"1... Robert . Saidis, Esquire 26 West High Street CarliSle, PA 17013 (717) 243-6222 Attorney for the Plaintiff (, I ,.\ , " ',1' I" -I, \j .n...."............ .,'hn___~...."_,...._ . , -~~~.I,1 '.!,ij;;...,~I_tt~M>';hi":~l~i-kt,'tIWl.Ii-~t.I~JNWfij"fI~'-r ""., Aua 3 12 Olf rH '95 Ill;! i~ I 'I, I.J~ l,h'( ',1)1 , /, ,n ill,' , fils. ad ,A. d:t4 ~ ~: c!* I07U, ~~ -1~303 " .,................~\,~~IJ.,. ~' ~, , \, , '. " " #' .j ..,-........pnjri . , r'--" f i , I ! , . . jf'll " t .' ,) .' . , .,1 I 'l "'I' ',.\ r'" . -- ,', .. III .. 0 ~ ~ ....j ~!! ~~\~ .". "() ~ -* "0 ~ i ~ I ,. ~ ~, " . ;E \ .,., I 'E~ ..... ~ . ~ - Do n ~ '"'\ ~ Ii ci .., ~ ~..Z ") ~~ ...... ,'/., ~ ~ -" ~ ei -1..1") \.~ ~,~; II: ID C::." 0( J ...:) - V . I..r') CD 8 ~ . ~ vs. : IN THE COURT OF COMMON PLEAS t CUMBERLAND, COUNTY PENNSYLVANIA : : CIVIL ACTION - LAW NO. 94-5335 CIVIL TERM RONALD D. ANTHONY, PLAINTIFF . VIRGINIA E. ANTHONY, DEFf:NDANT IN DIVORCf: ANSWER AND COUNTERCLAIM 1. Denied. It is denied that Plaintiff resides at the mentioned address. Is is believed he resides on the Carlisle Pike, Mechanicsburg. ,2. Admitted 3. Admitted 4. Admitted 5. Admitted 6. Denied. After reasonable investifation, Defendant is without sufficient knowledge to determine whether the marriage is irretrievably broken. 7. Admitted ~- ,', JUI Jt IU 110 ,lit' '95 , " t'l ,I , ~ , , I \1, ~ " it) i- (1 j--" c' " I, ';.,\ , , , , " I, j" " -'if ; 1 i.1;;.,,-,t,'tt,. " '. 1;1 ,,' ~ " ,\ l, .. -.,-- \~ f .\w 5l\U~",'~\jO\rCB\antholly.\:JOP , SAlOIS, GUIDO, SHUFF & MASLAND 26 W. HiM,h Sln:ct ClU"lisl.... PA RONALD D. ANTHONY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNT'i, PENNSYLVANIA CIVIL ACTION - LAW NO 94-5335 CIVIL TERM v. VIRGINIA E. ANTHONY, Defendant IN DIVORCE ~ILL OF PARTICULARS AND NOW comes the Plaintiff by his attorneys, Saidis, Guido, Shuff and Masland, and submits the following Bill of particulars: 1. In July of 1990, Plaintiff went to work with Morrison and Knunsen as a Foreman at IBM in Mechanicsburg, Pennsylvania. In early 1991, Plaintiff (hereinafter Husband), was requested by his employer on two separate occasions to get further training. Husband attended the training as requested by his employer to advance his career and fulfill work-related obligations. The training sessions required Husband to travel out of town and stay overnight for several nights. Husband told Defendant (hereinafter Wife) of these work-related trips. Wife refused to talk to Husband for two weeks thereafter. This "silent t.reatment" happened on each occasion. Husband was promoted to Supervisor and thereafter told Ilis employer not to include him in further training. Husband was denied opportunities for advancement at work because of his refusal to accept out-of-town training. 2. In 1992, Wife's daughter then approximately 21 years of age moved back into the residence with Husband and wif.e. Wife permitted daughter to return over Husband's objections. Husband 1 (1/",' v /,.1 J ..: . 1i1'~5 ',j "i . 'I, '. .' , , '.1...... ,d ~: .:i '. .j " , ., I, ',1: ~;1. .. ...... '-- \' there has not been a separation in excess of two years, a hearing is scheduled to take testimony on the grounds for divorce of indignities before getting into the economic issues. However, the Master has been advised that after negotiations this morning, counsel and the parties have reached an agreement as to the outstanding economic claims and to grounds for divorce. The parties will sign and file affidavits of consent within the next few days allowing the divorce to proceed under section 3301(C) of the Domestic Relations Code. Therefore, we will not need to take any testimony on the fault grounds of indignities to the person. Inasmuch as an agreement has been reached with respect to the outstanding economic issues, counsel are going to place an agreement on the record in the presence of the parties. The agreement as stated on the record will be considered the substantive agreement of the parties and not subject to any modifications after it is placed on the record except for correction of errors which may be made in the typographical transcription of the agreement. The parties and counsel are going to return later this morning to review the agreement for any typographical errors and after any errors have been corrected, the parties and counsel will affix their signatures. It is understood that the signing of the agreement is simply an affirmation of the terms of settlement that have already been agreed to as placed on the record by counsel in the presence of the parties. After the agreement has been reviewed for typographical errors and signed by counsel and the parties the Master will prepare an order vacating his appointment after which counsel can prepare a praecipe transmitting the record to the Court requesting a final decree in divorce. Mr. Saidis. MR. SAlOIS: Thank you, Mr. Elicker. Our agreement today resolves all the issues between the parties starting with alimony. 1. The Plaintiff Ronald D. Anthony has agreed to pay alimony of $650.00 per month commencing November 1, 1995, with the last payment at $650.00 per mon~h on April 1, 1996. Thereafter for nine months, he will pay alimony at $500.00 per month starting on May 1, 1996, and ending with January 1, 1997, payment. There will be 6 more months of alimony at $400.00 per month commencing February I, 1997, and ending July 1, 1997, which will be the last payment of alimony. Mr. Anthony is currently under a wage attachment for spousal support. The Domestic Relations office will be notified to convert that to alimony and to continue the wage attachment pursuant to the terms of this agreement. The alimony hereinbefore provided for is nonmodifiable except it will terminate upon the death of husband, death of wife, remarriage of wife, or cohabitation by wife with a male not within the degrees of consanguinity. 2. The parties are obligated to Factory Finance jointly on an encumberance on a 1987 chevrolet S-10 truck which is titled in husband's name. Husband, within sixty (60) days, will either have wife released from liability on the Factory Finance obligation or refinance the truck or sell the truck and provide acceptable evidence to counsel that this has been accomplished. 3. The Plaintiff agrees to pay $2,000.00 to wife's attorney, Barbara Sumple-Sullivan, as legal fees. This amount will be paid $50.00 per month and in any event, the total sum of $2,000.00 paid in full by March 31, 1996. 4. The parties are obligated on a Sears oredit oard with a balance of $1,747.21 as of october 23, 1995. The Plaintiff agrees that within sixty (60) days he will do one of the following things: a) b) Pay the credit card in full. Transfer to wife the sum of $3,000.00 from his 401(k) by reason of a Qualified Domestic Relations Order. The 401(k) plan is provided by his employer, Morrison Knudsen. f:vidence of payment or the execution of the Qualified Domestic Relations Order will be provided to counsel for wife within sixty (60) days. The balance in the 401(k) will then be husband's property free of any claim by wife as well as any other employment benefits he has by reason of his work with Morrison Knudsen. 5. Wife is the owner of real estate located at 503 South 20th Street, Camp Hill, Pennsylvania. The Plaintiff releases any and all rights, title, claim, or interest he may have to that real estate and agrees upon the request of wife and upon preparation by wife's counsel to execute a quit claim deed if desired. 6. The parties have filed the divorce action and will execute affidavits of consent immediately follow this hearing which will be submitted to the Master. 7. Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship including without limitation, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate. Each will at the request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights, and claims. . MR. SAIDISI I believe that fully states our agreement. MS. SUMPLE-SULLIVANI I would just like to add specifically as another item the IRS obligations, which are being handled by husband's bankruptcy and that husband agrees to indemnify and save and hold wife harmless from any potential claim for those debts as declared to that bankruptcy and through the IRS. MR. SAlOIS: That's agreeable. Mr. Anthony, you were present as we put on the record the agreement of the parties. Have you heard everything that was placed on the record? MR. ANTHON'i: 'lies, I have. MR. SAlOIS: And do you understand it? MR. ANTHON'i: 'lies, I do. MR. SAlOIS: 00 you have any questions? MR. ANTHONY: No, I don't. MR. SAlOIS: Is that your agreement? MR. ANTHON'i : Yes. MS. SUMPLE-SULLIVAN: Mrs. Anthony, you're heard the terms of the agreement as put on the record by Mr. saidis. Is that your understanding of the agreement? MRS. ANTHONY: 'lies, it is. MS. SUMPLE-SULLIVAN: Do you understand the effect of that agreement? '" E. Robert Elicker, II Divorce Mester OFFICE OF DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEAS 66 West Church Avenue Carlisle, PA 17013 (717) 240.6635 Wnt Shore 697.0371 Ex\. 6535 Trecl Jo Bleck OfflCR Manager/Repone, August 16, 1995 Robert C. Saidis, f:squire SAlOIS, GUIDO, SHUFF & MASLAND 26 West High Street Carlisle, PA 17013 Barbara Sumple-Sullivan Attorney at Law 549 Bridge Street New Cumberland, PA 17070 RE: Ronald D. Anthony vs. Virginia E. Anthony No. 94 - 5335 In Divorce Dear Mr. saidis and Ms. Sumple-Sullivan: By order of Court of President Judge Harold E. Sheely dated August 1, 1995, the full-time Master has been appointed in the above referenced divorce proceedings. The motion for appointment of Master indicates that grounds for divorce and equitable distribution are the matters at issue. A divorce complaint was filed on September 19, 1994, raising grounds for divorce of irretrievable breakdown of the marriage. No economic claims were raised in the complaint. However, on August 3, 1995, the Plaintiff raised the economic claim of equitable distribution; on August 9, 1995, the Defendant, by way of a counterclaim, raised the economic claims of equitable distribution, alimony, alimony pendente lite, and counsel fees and expenses. The Defendant's counterclaim also raised ~dditional grounds for divorce of indignities, desertion, and adultery. I assume that all economic claims are at issue even though the motion for appointment of Master indicates that the issues are the grounds for divorce and equitable distribution only. If the parties are not agreeable to consenting to a divorce under Section 3301(c) of the Domestic Relations Code, please advise me immediately so I can schedule a hearing on the fault grounds as raised in Defendant's counterclaim. RONALD D. ANTHONY, I IN THf: COURT OF COMMON PLEAS 01-' Plaintiff : CUMBERLAND COUNT'i, PENNSYLVANIA : VS. I CIVIL ACTION - LAW : I NO. 5335 CIVIL ly94 VIRGINIA E. ANTHON'i , I Defendant : IN DIVORCE ORDER AND NOTICE SET'l'ING IlEAIUNG ,~ Tot Ronald D. Anthony Robert C. Saidis Virginia E. Anthony Barbara Sumple-Sullivan Plaintiff , Counsel for. Plaintiff , Defendant , Counsel for Defendant 'iou are directed to appear for a hearing to take testimony on the grounds for divorce of indignities tn the person at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 24th day of October , 1995, at 9:00 a.m., at which place and time you will be given tne uppo~tunity to present witnesses and exhibit~ in suppnrt of your case. By the Court, ~~ ~:::: Harold f:. Sheely, presi n Judge Da te of Order and Notice: 9/28/95 By: Divorce-Master IF YOU DO NOT HAVE A LAW'iER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FINO OUT WHERE YOU CM GET LEGAL HELP. , Court Administrator Fourth Floor. East Wing Cumberland County Courthouse Carlisle, PA 17013 Telephone (717) 240-6200 '---.. .) LAW O,'ICII BARBARA SUMPL.E.SUL.L.IVAN uo ""1001 U"Ilt' NEW CUMBERLAND. PENNSYLVANIA 17070.1D31 "'HONE 1,.,.774...4. ,Ak (7.7'7"'.7011 THII II T"UI CO""ICT COI'Y 0' THI O"IOI/l"~ " . __......_..___1__..___..._.___ RONALD D. ANTHONY, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND, COUNT'i PENNSYLVANIA CIVIL ACTION - LAW NO. 94-5335 CIVIL TERM VIRGINIA E. ANTHONY, Defendant IN DIVORCE NOTICE OF INTENTION TO RESUME PRIOR NAME NOTICE is hereh~' given thnt Defenclilnt matter, h~ving been day of tf/t/Ci,(j/ '- granted a final decree in in the ahove-cpptinnecl divorce on the ~ /.9'.9J-, hereby intends to resume and hereafter use the previous name of VIRGINIA C. EVERTTS and gives this written notice avowing her intention in accordance with the provisions of the Act of 54 Pa, C.S. 5704. \ . ' V~~~~~~;: t C, "rL.,,,, E . ANTHONY .\ TO BE KNOWN AS: \ VI,..: \/,'.(". (', VIRGINIA C. ~', ,,< ~\:t.) EVERTTS COMMONWEALTH OF PENNSYLVANIA COUNTY OF '-.., <> \, \ '." , '-,: SS. On this, the \-,', day of \\"""\' ,1995 before me, a Notary Public, the undersigned officer, personally appeared Virginia E. Anthony known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowlenged that he executed the foregoing Notice of Intention to Resume Prior Name for the purposes contained therein. IN WITNESS WHEREOF, I hereunto set my hand and official seal. \- ~I+'t ~'. NOTARY PUBLIC .). ". ~) ~, My Commission Expires: (~) NO TAAIAL SEAL DIANNE lENIG, Nolarl f'liO!": lemovne Borough Cumben,,1I11 I" My Commission ElpirP.." Dee,;'! 1 !I' I' .---.... . . _..~.. 'p)'" _Il.,.t~"lnl....,~.wl- ,,~ " Hi lI'lllt) " Nov 9 3 ~lj ,III '95 . " 1':11 IIFF" l L,Jr'1i , Iii. I, lUI~' CUI'IJ ,," ,) ',"Jhrr P~~k~rL'lMi14 " "'i,, " , , I, " I ..~. 1'F."....~..'I'.,...,.;...."'''''u.......n'...I/.i1,)ol.#.,,\l.., ~....~..w>J ii-1 ,,4' ".. !~ ~',\ ,:i "',",,"'\t ,', '"" ' . ,\t.,." ': 1-' .' ",.',.;.,..,','. .' I~",' -';'1'-".,"':--, ',C' ;', . . - .', 'l_"~"I\;Wiio'tF.....,,.,,t;.lI'l't',,~ 11>'\~,..h..~ I, (it"7 (:1 >.J" "'f-" "I ),clltt,,:__ ,I ....~,,,...~M..,........;~if."'-J;.Jl,I....H"h..,;~"'~....,.,...-I-..... ,.., ,...."--.--~' , ~ , f ' , " , I . , ." " " " 1"1....' I . ~,,....--- .. " , (il , , , . , I" ,I, I' 'I ,.., ,I " Ii " ti N j,' 11 , . . ~; " ~/f.5'l F'" , I .. " " . . .' - 'f I m ~~ '. DR2H14 VS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION CIVIL ACTION - DIVORCE VIRGINIA E ANTHONY, PLAINTIFF RONALD ANTHONY, DEFENDANT NO, 5335 OF 1994 ORDER OF ATTACHMENT OF INCOME TO: Morrison-Knudscn Corp,. 180 Kost Road, Mechllllicsburg, PA 17055 AND NOW, this 9th day' of Novcmbcr, 1995, pursulllltto laws ofthc Commonwcalth of PcnnsylvllIIia. thc incomc of Ronald Anthony. dcfcndant/obligor. social sccurity number, 208-42-6836 of 181ll Lambs Gap Road. Mcchanicsburg, PA 17055. is hereby attached to the following cxtent. You are directed to pay to the Domcstic Relations Section of the Court of Common Pleas of Cumberland County. the sum ofS17S.00 per week out ofthc income duc the dcfcndant/obligor. within ten days aftcr thc datc of the dcfcndllllt/obligor is paid, " ~ ... MAKE CHECKS PAYABLE TO: DOMESTIC RELATIONS SECTION P.O. BOX 320 CARLISLE, PA 17013 IDENTIFY THIS PAYMENT BY PLACING NUMBER DR 23S14 ON YOUR" CHECK/PAYMENT, t.O c..n Upon receipt ofthc support paymcnt, the Domestic Relations Officer will distributc thc paymcnt as follows: AMOUNT OWED $15(),00 pcr wcck SUPPORT $----pcr ARREARAGE DUE DPA $ $25,()() pcr weck ARREARAGE DUE PLAINTIFF $1,016,80 $----pcr BLOOD TESTS/COSTS $ $ _pcr SERVICE FEES/COSTS $35,00 This Ordcr of attachmcnt of support is binding upon you until further notice IlIId shall have priority ovcr any attachmcnt. cxccution. garnishmcnt or wage attachmcnt undcr statc or local law cxccpt one relating to a prior support Ordcr. You must commcncc thc attachmcnt of the dcfendllllt/obligor's income as soon as possiblc but no latcr tllll fourtcen ( 14) days from thc date of thc issullllcc of this Order of Attachmcnt. You nr~ notificd turthcr that pursulIlltto law: I, Thc dcti:ndanllobligor has bccnnotificd thatllll Ordcr of Attachmcnt for Support would bc issucd" 2 Willful failurc to comply with this Ordcr may rcsult in (I) your being adjudgcd in contcmpt of Court and committcd to jnil or fincd by thc Court; (II) your bcingliablc for nny wlIountnot withheld or withhcld but not forwnrdcd to thc Domcstic Rclations Scction; lIlld (III) nttachmcnt of your funds or propcrty, 3, TIIC nttnchmcnt of incomc or thc possibility thcrcof ns a basis, in wholc or in part, for thc dischargc of WI cmploycd or wlY disciplinary action against or dcmotion of WI cmploycc is prohibited, Violation may rcsult in (I) your being adjudgcd in contcmptlllld committcd to jail or tinncd by thc Court; and (II) WI action against you by thc cmploycc for damagcs, 4, Ifthcrc arc in your cmploymcnt, onc or morc additional cmplo)'ccs whosc incomcs arc subjcct to Ordcr ofthc Court ofConllllon PlcB.~ ofCumbcrlwld Court for attachmcnt for support; you may combinc thc attachmcnt paymcnts into a singlc paymcnt to thc Domcstic Relations Scction Wid scparatcly idcntify thc portion attributablc to cach obligor, 5. You must notify thc Domcstic Rclations Scction whcnthc dcfcndant/obligor tcnllinatcs cmploymcnt and providc thc Domcstic Relations Scction with thc cmploycc's last known addrcss and thc namc lIlld addrcss ofthc ncw cmploycr if known, 6, Thc maximum amount ofthc attachmcnt shaUnot cxcccd 50% ofthc dcfcndant's disposablc camings, 7, Thc tCOll "incomc" as dcfincd by law includes compcnsation for scrviccs, including but not limited to wagcs, salarics, fecs, compcnsation in kind, commissions. lIlld similar itcms, incomc dcrivcd from busincss. gain dcrivcd from d\~alings in property, intcrcst. rents, royaltics. dividends. annuitics. incomc from Iifc insurancc lIlld cndowmcnt contracts. aU foOlls of rctircmcnt, pcnsions. incomc from dischargc of indcbtedness, distributive sharc of partnership of gross incomc, incomc in rcspcct of dcccdcnt. incomc from an intcrcst in an cstatc or trust. military rctircmcnt bcncfits, railroad cmploymcnt rctircmcnt bcncfits, social sccurity bcncfits. tcmporary Wid pCOllancnt disability bcncfits, workman compcnsation and uncmploymcnt compcnsation, YOU MAY DEDUCT FROM THE BALANCE DUE THE DEFENDANT AN AMOUNT EQUAL TO lWO PERCENT (2%) OF THE AMOUNT PAID FOR CLERICAL WORK AND EXPENSE INVOLVED IN COMPLYING WITH THE ORDER, (SEE PENNSYLVANIA LAW 1985- 66 SECTION 4348) BY THE COURT. DRO: W. Gold, Jr..lbjh 0&. . JR.. JUDGE VIRlilNIA E. ANTHONY. Pl.AINTlFF DR 23514 IN TlII~ ('011 In 01' ('OMMON PI.I~AS OF ('IIMIIU{l.AND ('OIlNTY. PI'NNSYl.V ANIA VS DOMESTI(' IWI AII( INS SH 'Ill IN ('IVIl. A('TION . DlvoRn: RONAl.D D. ANTHONY. DEFENDANT NO, 5.B5 ('IV 1')1)4 ORnER ()Io' A'J'TAnIM.:NT (W INCOM.: TO: Fluor Dunid. 5600 ('ullle I~ond. Mail Stup 1'1) 1111021. Snn.luse. ('A '15193 AND NOW.lhis llllh duy ufMny. I '1,/(). pursuant III laws uflhe ('ummunwenllh uf Pcnnsylvllniu. thc incumc uf RllIllIld D. I\nlhun}. dcfcndnnliuhligur. sucilll security numhcr 20K.42. 6K36 of IKIO l.umhs (j'IP Ruad. Mechnnicshurg.I'" 17055. is hcrchy lI11nched tu lhc lillluwinl! cxtcnt. Y uu arc dircctcd tu pay IU Ihe I )umeslic Rdaliuns Scctiun uf the (, 'llllrt of ('ummun Plcus of ('umhcrland ('ounty. thc sum ofS500.00 lIer mo"Ih uut uflhc incullle duc thc dclcndunt/uhlil!ur. wilhinlen duys aftcr the datc uflhe dclcndunt/uhligur is paid, MAKE CUECKS I' A Y AIJU: TO: I)OMESTIC RELATIONS SECTION I' .0. no x 320 CARUSU:,I'A 17013 mENTI..Y TIllS PAYMENT ny I'LACIN(; NlIMnER nR 23514 YOUR CUECK/PA YMENT, Upun rcceipt uf thc suppurt paymcnt. the Dumcslic Relatiuns Ofliccr will distribute thc puyment us tilllmvs: AMOllNT OWED $500.00 per month ALIMONY $ ,___.per ARRI:ARA(jE Dill; PI.AINTlFF $933.40 $ _per ARRI:ARA(jF DIll, DPA $ $ _per BLOOD TESTS/('OSTS $ -- $ _,pCI' SERVI('E I'I,ES/('OSTS $ ---.--- This Order uf allachmcnl uf support is hinding upun yuuuntil furthcr nUlice und shall have priority o\Cr any allachmenl. executiun, garnishmenl ur \\agc allachmcntundcr stale ur lucalluw CXCCpl unc rdating to a prior snpporl Ordcr, Yon must cummcncc thc allachmcnl uflhe , , . delclldmll/uhllgur's illcume us SOOIlUS pusslhle hut 110 Iutcr tUlllillll'lcell ( 14) duys fmllllhe dUle uf the Issuullce uf lhls Ordcr of Alluchmcllt. Yllllurc 1I01lticd furlhcr thut pursuulltto luw: I. Thc dclcndallt/uhligor Ims bCClllllHilicd thutun (lrdcr of Alluchmcntlilr Support would hc issucd" 2. Willful ruilul'c tu cllmply \\ ilh this (lrdcr muy rcsult ill (I) your bclng lIdjudgcd ill cOlllcmpt or Cuurtalld cUllunillcd to juil or lincd by thc Conrl: (II) your being Ilublc tilr ullY umuulll Ilut withheld or wilhheld butlllltlill'\\Ul'lled to lhc Il,llncstic Relutions Scclilln: und (III) ulluchmCIl( of yuur lill1ds or propcrty, J. Thc ullachmclltorlncomc or thc possibility lhcrcorus U busls. in wholc or in purt. IiII' the dischurge uf an employ cd or any disciplinary uctionuguinsl or dcmotion orun cmpluyec Is pmhihitcd, ViolutionlllllY rcsult in (I) your being udjudgcd ill cOlllcmptund cllmmillcd tu jailur tinncd hy thc Court: ulld (II) unuctiollagainst you by thc cmploycc IiII' dumllgcs, 4. I rthcrc arc in your cmploymcnt. onc Ill' morc addllional cmployccs \Ihosc incumcs arc suhjccttu Ordcr orthc Courl ol'<.'omnllln l'lcas orCumbcrland Courtlilr allachmcnt till' support: yuumuy comhinc thc ulluchmcnt paymcnts into a singlc paymcntto thc Domcstlc Relatiuns Scction und scparutely identily thc portion allributable to cach obligor, 5. Yuumust nutil); thc Domcstic Relations Scction whcn thc dclcndllnt/obligor terminates cmpluyment and pmvide thc Domcstic Relmions Scction \Iith thc cmpluycc's lust ~nll\vn uddress and thc Ilamc and addl'l:ss ofthc ncw cmploycr ir~llIl\ln, 6. Thc maximum mnounlorthc allachmcnt shall not cxcccd 50'!", of thc dclcndant's disposablc cumings, 7. Thc tcrm "incomc" as dclincd by law ineludcs compcnsalion Jill' scrviccs. including but notlimitcd to wugcs. salarics. rccs. compcnsation in kind. conullissi'1I1S. and similur itcms. incomc derived from husincss. gain dcrivcd Ihllll dcalings in propcrty. inlcrcst. rcnts. rllyaltics. dividcnds. annuitics. incomc from lifc insurancc and cndO\\mcnt contracts. allli1l'l11S orrctircmcnt. pcnsions. incomc rrom discbargc of indcbtcdncss. distributivc sharc or partncrship or gross incomc. incomc in rcspcc( uf dcccdcnt. incomc rroman inlcrcst in an cstatc or trust. military rClircmcnt hcndits. railroad cmploymcnt rctircmcnl bcnclits. soeial sccurily hcnclits. tcmporary and pcrmancnt disahility bcnclils. \Iorkman compcnsmion and uncmplllymcnl compcnsatillll, YOU MA Y DEDUCT FROM Till: BALANn: DUE TilE DU'TNDANT AN AMOUNT EQUAl. TO TWO PI:RCI':NI (2%) OF TilE AMOllNT PAID FOR CI.I,RI(,AL WORK AND EXPENSE INVOLVI'I) IN COMPI.YIN(i WllIIlIlI': ORDl'lt (SI':!': PI:NNSYLV ANIA LAW 1985-66 SECTION 4J411,) BY TilE COllin. DRO: W, Gold. Jr..Ibjh " cr 1111'1) r:I'I(I': I - . I' '1,1' i~TY , 'i %r1HI:j " "9 11.11.) " (;\.j,'" , 11_, . i,I_; 1'" PLtiiJ;j','LV,~\l'\' . I' ,'I " ;r- " , i :1 , " " " , '1\ " Ii "i " :' ,,' '. , , I " II' " ;;,, , I ,. .....~lf~~trItJ+~~~lil'(.I.',-'."TI;~joI........-'._j....".....-..,_.._---I.,.... or ! '1 V Ii '# " ,I i! P 433 L47 794 US Po.'1II S.""<u Receipt for Certified Mall Nu IUtilltllllCO C')\ilml~'t1 Ph''vllJl'tl gy'!"'1 ,u_''''U'!t!J!.''''Q~~l!'''''J!!!!:-'!':''JL 5l"~ _ . 'lI.A-. .. IM- ..._ ,I/It . NIJmrlm 'iI.o.L'U 1....\ .\1( ("'~r,.1 '1~-~~.~~J.J.4.:_.LU. '~J I. \J; L. __.. ... ~ I'l~t 0111"" ~ln!ll ^ .~I/J ('~Jl! ,~~->:\C_J_~'tc_.~.~\__.'hJ~J... _ ____.-.. F')I;III!I" S ". -.- -__"__ __on _.._ Cnruh'lIlfl!u --.--..--..____u_.__ _. '''',__. __~...._.__ _."._ Sjll!OllllJl!hlll)'I;'JIJ ._~_._--_.._.- --,-_., ---'-.----."... Hltlltnrtltll Dtlh....el~ hm ~ R-~l:);;ai;;- -----.-----..--- ..... Whom&lJnllfl}lth...ont,' J Rt't\JInRIH1jll~~I{l'Qwh.;; --.---.-- 8 ~:~:t:,::;:.~:::: $ :t IJlllmlUto:l)t Dllllt E ,2 g> I .. ..,..,......;..,-...,.,-_. DR 23,514 .CaIftjlIoIo_I............. , I .Print vow nwne and Iddrwa on the rlveral 0' tN. form 10""1 we can,.um IN. conlloiOll. -Aneoh 1hI, bm 10 the front of the m111p6ece, 01' on the '** It IC>lct do.- not _,. I -Wrtt'"RIIUm R<<>>I1It R<<1UM~' on lhe malIpIece below th,.rtldI number. -The Altum A.-pt 1M. Ihow to whom thlarUcI. w.. dII'NId Ind lhe dal. 1-' J 3. 11110 wllIh to recelv. th. following "Mee. (for lII1 .lIlIal..): 1. CJ Add"...... Add".. 2. CJ Rlltncllld D.llv.ry Conault poIlma.llr 'or I... .... Ar1I . Number P 433 147 794 4b. 'Me. Typ. o R.gl.'erod Xfl c.r1Inlld o Exp".. Mill 0 InlUrlld o Rllum Rocelpllor Mln:hIndI.. 0 COD 7. 0.11 01 D.II..ry j f j f .. /1- I rlllld to: Flour Daniel 5600 Cottle Road Mail Stop FD #1/021 San Jose, CA 95193 bj 12.-/11 '11 B. Add"....'. Add".. (Only If roqu.. """ ,-.1. paid) I B. Ign'IIl..: (....<!!I-.. or ....g.ny. X I'I./.L( (1 ,~dJI...i,..d~' I PS Form 3111, o.c'mIler 1884 . VIlHiINIA I:, ANTIIONY. I'I.AINTlI'l IJI~ 1,'~ I~ IN TIII'COI JRI OI'COMMON PI.I:AS OF VS Clll\lIl1:RI.ANIJ ('( HINTY. PI:NNSYl.V ANIA I)()I\II'SIH' RI'IAII()NS SI'lTII)N CIVil, ACTION .IJIVOIU'I': NO,~.B~CJVII.JI)I)~ RONAI.D D, ANIIIONY. 1)Io:F1.:NIJANT AMEN!)":!) OIWEI( OF ATTM'II I\H:NT OF IN('OME TO: F1l1ul' lJullid. 5600 Clllll~ RllUd. Muil SIllpl'IJIIJI021, SUIl .I11S~. ('A I)~ JliJ ANI) NOW. Ihis hlll du~ Ill' I k,~lllh~l'. 11)%. JllII'SLHIIlII'1 I(I\IS III' lh~ l'lllllllllll1\wlIltll III' P~nllsylvllnill. lh~ ()I'J~I' III' ulludlln~1l1 ~nl~l'~d lllll\lu~ 10. 11)1)(,. agaillsl RlIlluld IJ, Allthllny. J~Ii:lldlllll/lIhliglll'. slldal S~,lIl'ily 1l1l1llh~1' 10K.~1.l>lnl> is lll11dili~d llllh~ ~xl~1l11hlll YllU 1I1'~ dil'~et~d III PllY llllJllllleSli.: JklulillllS S~,lilllllll' ClIlllh~r1ulld CllUIlI~ lh~ sU1ll1l1' $115JK I'l~r week IIUIIlI' lh~ ill,lIl1l~ du~ lh~ deli:lldullllllhligllr. ~1'1'~~lil~ ilnlll~diuldy, AlIlIlh~1' ClllldilillllS ulld pl'llI isilllls S~ll'll'lh illlh~ I )l'd~1' ~Ill~r~d 1111 Muy 10. 11)%. shull I'cnmill ill d'1i:cl. BY TilE COllRT. ce: I>RO: W, Ollld. Jr.lBJII ';' . I' 1'1\ r!l,OrW;r-,. " ' r-" 'II ,,' I ' / i' I II" j t. 1;,1 ; ( \Ji' 'I, IJCdl':T,\ \ r'\ (11 ",:; '\1 \ ~ . , OJ 1'11\" , "... \-,.. .' .' \'_1,' \ ,\/I,"'.i \ H:.h\,:)ll.",l,i ,1\ (' t~i~~d ('flo.:..O. ~ ~~\)v..I" D~ (.1~, ., '\0 ~"O&d D,~~~Ol'~ I 1 " I 01 "! 1'1.1 I,"~ " I '1 I I,' " I, ,L'lt'(l! " '_11"1"","_'''01'._ --'''-''''''\'; , ,.,;1'..;>.'1".,,,,0-+.....,"*")....-"" , I , ,-, l,f'," f'q,i ",,~ , .( , !()i\ r j . \ " I 1 ',I .. . " " ~"-' " (.' ~ " ,. (':\". , I; " , I"; ,., " \',.1', .. q') Ii" , 11" , i, 1'- " " , , , , ' , , .,!, "., ;1,.' ,I' " . . j i~ \ .. .. _.