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Home My WebLink About02-4216 WILLIAM P. CONRAD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. KAREN CONRAD : NO.O;2.- '.p.lt.. CIVIL TERM 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 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, Cumberland County Courthouse, High and Hanover Streets, 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 TIllS PAPER TO YOUR LA WYER 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, Pennsylvania 17013 (717) 249-3166 NOTlCIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo aI partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 a1ivio que es pedido en la peticion do demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importanates para usted. LLEVE ESTA DEMANDA A UN ABODAGO lNMEDlATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE P AGAR TAL SERVICIO, VA Y A EN PERSONA 0 LLAME POR TELFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 WILLIAM P. CONRAD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. KAREN CONRAD NO.~- .1.[:/'1,," CML TERM Defendant : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 (a) OR 3301(c) OF THE DIVORCE CODE AND NOW comes the above Plaintiff, William P. Conrad, by his attorney, Cara A. Boyanowski, Attorney at Law, and seeks to obtain a decree in divorce from the above-named Defendant, upon the grounds hereinafter set forth: 1. The Plaintiff, William P. Conrad, is an adult individual who resides at 73 Greenmont Drive, Enola, Cumberland County, Pennsylvania, 17025. 2. The Defendant, Karen Conrad, is an adult individual who resides at 73 Greenmont Drive, Enola, Cumberland County, Pennsylvania, 17025. 3. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 15, 1992, in Marysville, Perry County, Pennsylvania. 5. The Plaintiff and Defendant are both citizens of the United States of America. 6. There have been no prior actions in divorce between the parties. 7. The Plaintiff and Defendant are not members of the Armed Services of the United States or any of its allies. 8. Plaintiff avers that he and Defendant are the parents of four children, namely, Katelyn Conrad, born April 28, 1991, Nathan Conrad, born February 14, 1993, Spencer Conrad, born May 20, 1994, and Natalie Conrad, born September 28,2000. 9. Plaintiff has been advised of the availability of counseling and that he may have the right to request that the Court require the parties to participate in counseling. 10. The causes of action and sections of Divorce Code under which Plaintiffis proceeding are: A. Section 3301(a) (2). Plaintiff avers that Defendant, in violation of marriage vows and the laws ofthe Commonwealth of Pennsylvania, specifically under Section 3301 (a)(2) of the Pennsylvania Divorce Code, Act 26 of 1980, did commit adultery with various persons at various times throughout the course of the parties' marriage until and including the present time. B. Section 3301(c). The marriage of the parties is irretrievably broken. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an Affidavit. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony. I verifY that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. ~4904 relating to unsworn falsification to authorities. By: /J)iJJd (l~ William P. Conrad, Plaintiff Date:-9 - ~-O.c.. L By. Cara A. Boyanows , Esquire Attorney No, 68736 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 Attorney for Plaintiff N(:)~ it- ~ ~ ~6 ~~ -1 ...... It.> -() ......... ~ 0 C::J 0 c- ,"...1 -n eJ iT Ij') "'1 ,-,..., .-:; ~ , I r, "' .r ~~ ;~) , ~~-..,. ~- " <;;,. ~-) ):; -. ~-; :',~ :"-! r:-- :h -< ( ::J ~, WILLIAM P. CONRAD, PLAINTIFF IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 02-4216 CIVIL TERM KAREN CONRAD, DEFENDANT : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE FOR ENTRY OF APPEARAN~ Please enter my appearance on behalf of the Defendant, Karen Conrad. Respectfully submitted, LAW FIRM OF SUSAN KAY CANDIELLO, P.c. Dated: September jQ, 2002 Susan Kay C PA 1.0. # 64 8 5021 East Trin Suite 100 Mechanicsburg PA 17050 (717) 796-1930 0 0 0 C r'0 ,1 :?: (n u lJ} P1 n, I' --0 Z t: '7 0 ~.:. -0 ~'O" ...~ :.0 ).0 'V ~ WILLIAM P. CONRAD, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYL VANIA v. :CIVIL ACTION - LAW :IN DIVORCE KAREN CONRAD, Defendant :NO.02-4216 PRAECIPE FOR WITHDRAW OF APPEARANCE To the Prothonotary: Kindly withdraw my appearance on behalf of the Plaintiff, William P. Conrad, in the above-captioned matter. DATED: 1~-\L,"0l.. Cara A. Boyanows i, Esquire 1029 Scenery Drive Harrisburg, PAl 71 09 (717) 657-4795 PRAECIPE FOR ENTRY OF APPEARANCE To the Prothonotary: Kindly enter the appearance of Thomas A. Beckley, Esquire, Elizabeth S. Beck ley, Esquire and Beckley & Madden, of Counsel, on behalf of the Plaintiff, William P. Conrad, in the above-captioned matter. Of Counsel DATED: J- J-oJ BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, Pennsylvania 17108 (717) 233-7691 CERTIFICATE OF SERVICE I, Elizabeth S. Beckley, Esquire, hereby certify that a true and correct copy of the foregoing document was this day served upon the person and in the manner indicated below. SERVICE BY FIRST CLASS MAIL: Susan Kay Candiello, Esquire 5021 East Trindle Road Suite 100 Mechanicsburg, P A 17050 DATED: /-J~c[) o C :?"' ""'06~:i rrJn'.i 7~. ~..." ::?:,,' 02~; 2(::~-, "- ~Q """"(_I Pc Z ~ ." o W L- ~ "'"""""" ~'- o -n ::.! ',i:g ~'" i '.;0 -:'-, ._..:- -ro', ~~~~ '-, 5i :::0 -< I (...) :? -- ", => \0 WILLIAMP. CONRAD, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA .lj;l.Il.. NO. 02 -~ CIVIL TERM KAREN CONRAD, Defendant : CIVIL ACTION - LAW : IN DIVORCE PETITION FOR ALIMONY PENDENTE LITE AND COUNSEL FEES AND EXPENSES AND NOW, comes the Defendant, Karen Conrad, by her attorney, John J. Connelly, Jr., Esquire, and petitions this Honorable Court for alimony pendente lite, counsel fees and expenses relevant to the Complaint in Divorce and Petition for Economic Relief, and in support thereof, respectfully represents as follows: I. By reason of this action, Defendant has incurred considerable expense in the preparation of her case and the employment of counsel and the payment of costs. 2. The Defendant is without sufficient funds to support herself and to meet the costs and expenses of this litigation. 3. Defendant is to provide for her reasonable needs and to pay her attorneys' fees and the cost of this litigation and she is unable to appropriately maintain herself during the pendency of this action. 4. Plaintiff has adequate earnings to provide for the Defendant's support and to pay her counsel fees, costs and expenses. WHEREFORE, Defendant prays this Honorable court enter an Order awarding her alimony pendente lite, counsel fees, costs and expenses. Respectfully submitted, JAMES, SMITH, DIEITERICK & CONNELLY LLP Date: 0) 1'610) By: '" J~. (Jo . 1. onne Iy, Jr., Esquire \b.jtome for Defendant ( Post Office Box 650 Hershey, P A 171033 (717) 533-3280 PA LD. No. 15615 VERIFICATION I verify that the statements made in this Pleading 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: L, ]1"3 } 0 3 ~0JcuJ~. ~ff)1AJuJ _ WILLIAM P. CONRAD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 02-4226 CIVIL TERM KAREN L. CONRAD, Defendant : CIVIL ACTION - LAW : IN DIVORCE CERTWICATE OF SERVICE I, John J. Connelly, Jr., Esquire, of James, Smith, Dietterick & Connelly, LLP attorney for the Defendant, Karen Conrad, hereby certify that I have served a copy of the foregoing Petition for Alimony Pendente Lite and Counsel Fees and Expenses on the following on the date and in the manner indicated below: V.S MAIL. FIRST CLASS. PRE-PAID Elizabeth S. Beckley, Esquire 212 North Third Street Harrisburg, P A 17101 JAMES, SMITH, DIETTERICK & CONNELLY LLP Date: fo ~I 03 t (;;j "'Q ::8 if' (J "0.. ~ ~ \l. J:; D ~~ ~f 1- (') c ;? 0::( t:~'~ ~~~ '- ......: ..J. " ~~ ~~...: / =2 ~ U'\ <-:-j (,.) "... (::> .0 () -,:jj~ :'0 -< ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of pennsvlvania Co.lCity/Dist. of CUMBERLAND Date of Order/Notice 08/22/03 Tribunal/Case Number (See Addendum for case summary) o Original Order/Notice o Amended Order/Notice o Terminate Order/Notice NORFOLK SOUTHERN CORP 110 FRANKLIN RD SE ROANOKE VA 24042-0002 ~ ~. f>l{" (!I/)/~ A'I~s:t. S n'l/() 1)/,0,/ RE: CONRAD, WILL,IAM P. JR Employee/Obligor's Name (last, First, Ml) 197-46-7834 Employee/Obligor's Sodal Security Number 2089101010 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, Mil EmployerMlithholder's Federal EIN Number See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 1,258.56 per month in current support $ 100.00 per month in past-due support Arrears 12 weeks or greater? (S)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 $ 1, 358 .56 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: $ 313.51 per weekly pay period. $ 627.03 per biweekly pay period (every two weeks). $ 679.28 per semimonthly pay period (twice a month). $ 1.358.56 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 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 S5% 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. :tP- ,.o-16ES. fl961.$ oUt>;>- 9711~ 174/3 Make Remittance Payable to: PA SCOU Send check to: Pennsylvania SCOU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown ,,",w M'" ,",,,.,wlObl,,w~:~fiW "Cu.m NU"'" '" 0,"," ro " "'X",m :~::~:';:A:~ '~'"?Jc ~l1 e~Y ~~e or';; E)I-028 Service Type M OM'No.0970.0154 Worker 10 $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If (hecked you are required. to provisle a copy of this form to your. employee. If your 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 Federaily recognized Indian tribes, tribaily-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.' Rep6,t;"g tl.G Pa,Jak':OaK or ':"itl,I,~I~::\~ YOu ",uS\ ,<p,"),t 11.< p.,d.t....'ddk vi ";tl.l,~I~;;,!,"l.c,, 'e1 ,d;"g II" pa,,,.'e1't. TI,e , , h' "ages. You must comply "11th 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 ail support Order/Notices due to Federal or State withholding limits, you must foilow the law of the state of employee's/obligor's principal place of employment. You must honor ail 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: 5211880140 EMPLOYEFS/OBLlGOR'S NAME: EMPLOYEE'S CASE IDENTIFIER: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: coNRAD, WILLIAM P. JR 2089101010 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. B. 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 dischalCging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because oof 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 ail owed by the Federal Consumer Credit Protection Act (15 U.s.c. 91673 (b)l; or 2) the amounts ail owed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (AOWE). AOWE 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 tz.I7) 240-6248 or by internet ~vww.childsupport.state.pa.us Page 2 of 2 Form EN-02B Worker 10 $IATT Service Type M OMBNo.:0970-0154 ADDENDUM Summary of Cases on Attachment Defendant/Obligor: coNRAD, WILLIAM P. JR PACSES Case Number 174105607 Plaintiff Name KAREN L. CONRAD Docket Attachment Amount 02~ CIVIL$ 400.00 Child(ren)'s Name(s): DaB PACSES Case Number 971104743 Plaintiff Name KAREN L. CONRAD Docket Attachment Amount 006928 2002 $ 958.56 Child(ren)'s Name(s): KATELYN MICHE~E.c:9NRl\.D NATltANPAUliCONRAD SPENCER NOl,AN CONRAD NATAL!j;j........!SAIlELLA...CbNllAD DOB 04/28/91 02/14/93 OS/20/94 09/28/00 If 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) above in any health insurance coverage available ernployee's/obligor's employment. PACSES Case Number Plaintiff Name PACSES Case Number Plaintiff Naml~ Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DaB Docket Attachment Amount $ 0.00 Child(ren)', 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): DaB If you are required to enroll the child(ren) above in any health insurance coverage available employee's/obligor's employment. 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 10 $IATT Service Type M OMBNo., 0970-0154 WILLIAM P. CONRAD, JR., Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE KAREN L. CONRAD, Defendant/Petitioner NO. 2002-4216 CIVIL TERM IN DIVORCE Pacses# 174105607 ORDER OF COVRT AND NOW, this nnd day of August, 2003, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $728.89 and Respondent's monthly net income/earning capacity is $3,411.84, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $425.00 per month payable monthly as follows; $400.00 for alimony pendente lite and $25.00 on arrears. First payment due next pay date. Arrears set at $1,200.00 as of August 22, 2003. The effective date of the order isJune 16,2003. 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: Karen L. Conrad. 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: PA SCDU P.O. Box 69110 Harrisburg, PA 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 $250.00 annually in unreimbursed medical expenses. Respondent to provide medical insurance coverage. Within thirty (30) days after the entry of this order, the Respondent shall submit written proof that medical insurance coverage has been obtained or that application for coverage has been made. Proof of coverage shall consist, at a minimum, of: I) the name of the health care coverage provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims should be made; 5) a description of any restrictions on usage, such as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms. This Order shall become final ten days after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary for a hearing de novo before the Court. DRO: R, J. Shadday Mailed lpies on 17-;) .~ to: < Petitioner Respondent John Connelly, Jr., Esquire Elizabeth Beckley, Esquire BY THE COURT, Q:lJ.'1~ Edgar B. Bayley J. . .,J::i': . , , ,~. -,~. a ;--;1 r:;, .~~ c.~.i ,>.. " ,. "~. t-..J. ". [2 """ ~,;;;;: N'Cc ~rr', ~':t V) Z~ rsp ~. i/-~ ,r';' ~ ~;.., -....::: S> r::- C.v EJ ,.. c- r$ f\~ C:> ?, .:;'f Ii ~-r-I "" .',;h, '..'c', _J {' :j~.J :_~::B -'C) (':)",'11 ;:'~ .:t; " ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsvlvania Co.lCity/Dist. of CUMBERLAND Date of Order/Notice 08/25/03 Tribunal/Case Number (See Addendum for case summary) o Original Order/Notice CD Amended Order/Notice o Terminate Order/Notice NORFOLK SOUTHERN CORP 110 FRANKLIN RD SE ROANOKE VA 24042-0002 'J:/!I. <<P()1. - 'IN/' f III/t., ;t;1C$ES 17~/()fi'~'7 W ~9" S oUt)'- "A~$ts 911/t; Y7V3 RE: CONRAD, WILLIAM P. JR Employee/Obligor's Name (last, First, Mil 197-46-7834 Employee/Obligor's Social Security Number 2089101010 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, Mil EmployerlWithholder'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'sfobligor's income until further notice even if the Order/Notice is not issued by your State. $ 1,258.56 per month in current support $ 125.00 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 $ 1,383.56 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: $ 319.28 per weekly pay period. $ 638.57 per biweekly pay period (every two weeks). $ 691.78 per semimonthly pay period (twice a month). $ 1.383.56 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 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'sf 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. , .':. "';''l'i1' ~""7'j~ lnn~ ~;~~:::'riI.";.,'~'lsy THE C Date of Order: ~G 2 7 e G, Service Type M OMB No.: 0970-{l154 Form E -028 Worker 10 $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If checked you are required to provide a ,opy of this form to your employee. If yoW employee works in a state that is different 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 prOCE~SS 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,t;hg the r'8yd&te/D8te of'NitLLoldil,g. You IIIUst lepOlt tLe pay daLe/date of ~~itl,Loldihg nllel1 ;;e"dit,g ll,e p8Ylllellt. The payelatc/date of vvitl,L6ldillg i& tile dale Oil vvl,;c11 81t10ul,t vv....~ vvitLLeld flOIl. tile ell.ployee's vvago. 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 #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 ID: 5211880140 EMPLOYEE'S/OBlIGOR'S NAME: EMPLOYEE'S CASE IDENTIFIER: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: CONRAD, WILLIAM P. JR 20B9101010 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 (1 5 U.s.c. ~1673 (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. 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 5T 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 www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Worker 10 $IATT Service Type M OMBNo.:0970-0154 ADDENDUM Summarv of Cases on Attachment Defendant/Obligor: CONRAD, WILLIAM P. JR PACSES Case Number 174105607 Plaintiff Name KAREN L. CONRAD Docket Attachment Amount 02:::rn6 CIVIL$ 425.00 Child(ren)'s Name(s): DaB PACSES Case Number 971104743 Plaintiff Name KAREN L. CONRAD Docket Attachment Amount 006928 2002 $ 958.56 Child(ren)'s Name(s): KATELYN MICHELE CONRAD NATIlAit....Mtlt......CONi.lAJ) SPENCER NOLAN CONRAD NATiWtEtSASELLACONRAIl DOB 04/28/91 02/14/93 OS/20/94 09/28/00 If you are required to enroll the child(ren) in any health insurance coverage available through the employee's/obligor's employment. If checked, 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): DaB Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DaB you are required to enroll the child(ren) in any health insurance coverage available employee's/obligor's employment. If checked, 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): DaB Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DaB 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 10 $IATT Service Type M OMBNo.:0970-0154 ~S:t!~~,:.rft fji\ti~~(1J:! (") C ~ "OG mrTl Z::r-' -/r- Cf.1-'>. =<:.c ,<::C 2?c; 2('- :;;;~ Z ::! c:.-' w po c:: '" 1'.) CO - o -,., -Q :r. 'f1 "'" l" "1 r en (~-) o -r, '-, :!J "'0 :'::":')f"1\ -~=--t '5:j "< ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 08/09/04 Tribunal/Case Number (See Addendum for case summary) o Original Order/Notice @ Amended Order/Notice o Terminate Order/Notice NORFOLK SOUTHERN CORP 110 FRANKLIN RD SE ROANOKE VA 24042-0002 )1(-/ '?OOJ.1;)/(;, (if t//C ;.J;(!SES 17 '1/ {!:Juo7 RE: CONRAD, WILLIAM P. JR Employee/Obligor's Name (Last, First, MJ) 197-46-7834 Employee/Obligor's Social Security Number 2089101010 Employee/Obligor's Case Identifier (See Addendum for plaintiH names associated with cases on attachment) Custodial Parent's Name (Last, First, MI) EmployeriW"ithholder's Federal EIN Number off. H/C'':;,[S f C;;; S ;Ie>,).) C)7//D Yl'l5 See Addendum for dependent names and birth dates associal'ecJ 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. $ 1,258.56 per month in current support $ 25.00 per month in past-due support Arrears 12 weeks or greater? Qyes (Xl 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 $ 1,283.56 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the SUPPOlt order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 296.21 per weekly pay period. $ 592.41 per biweekly pay period (every two weeks). $ 641.78 per semimonthly pay period (twice a month). $ 1.283.56 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 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/EDI, please call Pennsylvania State Collections and Disbul'sement 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, Harrisbur:g, 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 C'!f$&4cieRt;f.' 0 ,~OClAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. ii/',!! "'! "tj'" Date of Order: AUG 1 0 2004 Evfdl-1f Service Type M OMB No.: 0970-0154 Form EN-028 Worker 10 $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If ~hecked you are required to provide a copy of this form to your employee. If your 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.* ~~~7.;:~g ~'~'::'Zd~~..,'D'I' vfWilI,l,old;"g. 'Iv" ,,,",t 'e;~:~ tl,~~.~:~~~;~:~ ~1~ahh,Oldi"A ..1.0" ""d;',g tl,,, po, ".'o"t. TI,e payjateJdate uf- ultl.IIOIJlllg d ti,e dat~ 0.. HIllel. ArllOul,t nA I hI. I II :{{;~ 5 nagc3. 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. S. * 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: 5211880140 EMPLOYEE'S/OBlIGOR'S NAME: EMPLOYEE'S CASE IDENTIFIER: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: CONRAD, WILLIAM P. JR 2089101010 DATE OF SEf'ARATION: 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 aI/owed by the Federal Consumer Credit Protection Act {15 U.S.c. 91673 (bJ1; 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. Additionallnlo: *NOTE: II 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 Il17) 240-6225 or by FAX at (7171 240-6248 or by internet ~hildsupport.state.pa.us Service Type M Page 2 of 2 Form EN-028 Worker 10 $IATT OMBNO.:0970_0154 ADDENDUM Summary of Cases on Attachme'nt Defendant/Obligor: CONRAD, WILLIAM P. JR PACSES Case Number 174105607 Plaintiff Name KAREN L. CONRAD Docket Attachment Amount 02=42i'6CIVIL$ 425.00 Child(ren)'s Name(s): DOB PACSES Case Number 971104743 Plaintiff Name KAREN L. CONRAD Docket Attachment Amount 006928 2002 $ 858.56 Child(ren)'s Name(s): KATELYN mCHELE CONRAD NA'l'iIiili/:ii,;!,ut...CdNRJilj SPENCER NOLAN CONRAD NATAtifE......:eSASlitiili\:...CI:lNRAb DOB 04/28/91 02/14}93 OS/20/94 09/28/00 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 Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Nam'~ Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB If checked, you are 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 Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): PACSES Case ~Iumber Plaintiff Name DOB Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB you are required to enroll the chi/d(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. Service Type M Addendum Form EN-028 Worker 10 $IATT OMBNo.:097().(}154 ~i~~"oIlI!JiUi, -:'.1- :"~:: ~-? ~n c.:; ~:? '" C::--;:-:J C':::;, ..c'- o -" :? nl::J.J r"-' -"n-l - '5-' ._',1 ..: " _.,1 , ~ .-:-:i(_) ??i!~ '-, :~.~ s-;: (,,0.,1 ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 12/09/04 Case Number (See Addendum for case summary) o Original Order/Notice @ Amended Order/Notice o Terminate Order/Notice NORFOLK SOUTHERN CORP 110 FRANKLIN RD SE ROANOKE VA 24042-0002 )Yj, cVK/fJ.-4f~f..p (!J PIl. P~SiS /7f//os-r,07 ))Jcf, IRq d. ...s ;;..oOd ;J4fJ5[5 97/ I t;,/7Y3 RE: CONRAD, WILLIAM P. JR Employee/Obligor's Name (Last, First, Mil 197-46-7834 Employee/Obligor's Social Security Number 2089101010 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, MI) EmployerMlithholder's Federal EIN Number See Addendum for dependent names and birth dates associatE'CI 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 unti I further notice even if the Order/Notice is not issued by your State. $ 1,258.56 per month in current support $ 125.00 per month in past-due support Arrears 12 weeks or greater? Oyes (X) no $ 0 . 00 per month in current and past-due medical support $ 0 . 00 per month for genetic test costs $ per month in other (specify) for a total of $ 1,383. S6 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: $ 319.28 per weekly pay period. $ 638.57 per biweekly pay period (every two weeks). $ 691.78 per semimonthly pay period (twice a month). $ 1.383.56 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 paydateld,ate of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed .55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If 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, Harrisbu.,~, 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 SO l SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAil. Date of Order: DEe 1 0 200%. eo BY THE COUR . ) ~~~ Worker ID $IATT Service Type M OMB No.: 0970.01 S4 ~'. Sc <3- rl ne C.j .. ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If ~hecked you are required to provide a (:opy of this form to your employee. If YOl,Jr 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. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3. * Repolting tI,e PaydateJDate of 'v'v'ithl,oldil ,g. You must lepolt tl,e paydateJdate of witl,l,olding wl,el, sending the payn,el't. The paydate/date of vvitl,',oldir,g is ti,e date Oil \IV I rich amount vvas vvithl,eld flolr, tI,e elllployee's vvages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 5211880140 EMPLOYEPS/OBLlGOR'S NAME: CONRAD, WILLIAM P. JR EMPLOYEE'S CASE IDENTIFIER: 2089101010 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an 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. 9. * Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.c. S 1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who reCl~ive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11 . Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at ill!) 240-6225 or by FAX at (717) 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.: 0970-01 S4 Sea t1 t, e d ADDENDUM Summary of Cases on Attachment Defendant/Obligor: CONRAD, WILLIAM P. JR PACSES Case Number 174105607 Plaintiff Name KAREN L. CONRAD Docket Attachment Amount 02=42i6 CIVIL $ 425.00 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. PACSES Case Number Plaintiff Name 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. PACSES Case Number Plaintiff Name 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. Service Type M Addendum OMB No.: 0970-0154 PACSES Casl~ Number 971104743 Plaintiff Name KAREN L. CONRAD Docket Attachment Amount 00692S 2002 $ 958.56 Child(ren)'~, Name(s): ~~~p~~~~~~ SPENCE~ NOLAN CONRAD. ..... " NATALtiii>I;SABBtitACONRAIi' , DOB , O~12131~:I. '.'.' , "'<<021::L41$:i OS/20/94 <09428/00 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. PACSES Case Number Plaintiff Name: Docket Attachment Amount $ 0.00 Child(ren)'s l\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. PACSES Case I'Jumber Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB >..;.... ;.> .:::.. ..... ;"';':" '.'.' ',;..' . '';::. .;', tJ If ~h~cked, you are requir~d~~e~rollthe childire~) identified above in any health insurance coverage available through the employee's!obligor's employment. Form EN-028 Worker ID $IATT ~ t~~!'t rf:i~t~ f~1 C) ........, (".:.."1 c., .,r:.- if, c.") <..) ....'~ (-) "'II --...; :. L -1\ \ 11 ,'"' "1-' ,.'~l:: ,.: .~ i -'" , " ;:..C - ~.;, ; . ..\ r:: C,) -~_! WILLIAM P. CONRAD, Plaintiff :IN THE COURT OF' COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYL VANIA v. :CIVIL ACTION - LAW :IN DIVORCE KAREN CONRAD, Defendant :NO.02-4216 INCOME AND EXPENSE STATEMENT OF W][LLIAM P. CONRAD I verify that the statements made in this Income aIlld Expense Statement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to author:ities. DATED: I)-/}-oy Ul$1 ~ William P. Conrad INCOME AND EXPENSE STATI~MENT OF WILLIAM P. CONRAn SS# 197-46-7834 EMPLOYER & ADDRESS: Norfolk Southern 218 Enola Road Enola, P A 17025 JOB DESCRIPTION: Carman - Welder INCOME: Pay Period (bi-weekly) Gross Pay per Pay Period Itemized Payroll Deductions: Federal Withholding Social Security - Tier 1 RRT Retirement Local Wage Tax State Income Tax Retirement - Tier 2 RRT Tax Savings Bonds Credit Union Life Insurance Health Insurance OASDI/DIS Medicare - Tier 1 RRT Medicare Union Dues Child Support Process Fee Child Support Net Pay per Pay Period: OTHER INCOME: Week Interest Dividends Pension Annuity Social Security Rents Royalties Expense Account Gifts Unemployment Compo Workmen's Compo Other TOTAL MONTHLY INCOME (Gross): Month Year $2,486.26 263.52 154.15 39.78 76.33 121.83 o o o o o 36.05 41.00 12.54 592.41 $ 1,148.65 o o o o o o o o o o o o ~ EXPENSES: Week Month Year Mortgage/rent $650.00 Maintenance 0 Utilities Electric 60.00 Gas 110.00 Oil 0 Telephone 100.00 Water 55.00 Sewer 0 AOL 30.00 Employment Public Transportation 0 Lunch 0 Taxes Real estate 0 Personal Property 5.00 Income 0 Other (per capita) 0 Insurance Homeowners/Renters Automobile 100.00 Life 0 Accident 0 Health 100.00 Other 0 Automobile Payments 170.00 Fuel 100.00 Repairs 300.00 Medical Doctor 0 Dentist 0 Orthodonist 0 Chiropractor 0 Hospital 0 Medicine * 125.00 *prescriptions, Special Needs (glasses, co-pay office braces, etc.) visits, therapy co-pay Week Month Year Education Private school $ 0 Parochial school 0 College 0 Religious 0 Other 0 Personal Clothing 200.00 Food 425.00 Barber/hairdresser 30.00 Credit payments 0 creditcards 0 charge accounts 0 Memberships 0 Loans Credit Union 0 Other 0 Miscellaneous Household help 0 Child care 0 Paperslbooks/etc. 23.00 Entertainment 200.00 Pay TV 45.00 Vacation 500.00 Gifts 2,000.00 Legal Fees 0 Charitable contributions 80.00 Other 0 Loan 0 TOTAL EXPENSES: $. PROPERTY OWNED: Description Value Ownership Checking accounts $200.00 Wm. Conrad Savings accounts 100.00 Wm. Conrad Credit Union 0 Stocks/Bonds 100.00 Wm. Conrad Real estate 0 Other 0 TOTAL VALUE OF PROPERTY $ INSURANCE: Company Hospital Blue Cross- Other Aetna Healthcare Policy # Coverage 699000-010-00001 husband, wife & 6 children Medical Blue Shield Other Health! Accident Disability Income Dental Vision Other Same Aetna SUPPLEMENTAL INCOME STATEMENT (a) This form is to be filed out by a person (check one): (1) who operates a business or practices a profession, or (2) who is a member of a partnership or joint venture, or (3) who is a shareholder in and is salaried by a closed corporation or similar entity. (b) Attach to this statement a copy of the following documents relating to the partnership, joint venture, business, profession, corporation or similar entity: (1) the most recent Federal Income Tax Return, and (2) the most recent Profit and Loss Statement. Name of business: Address: Telephone Number: Nature of business (check one) (1) partnership (2) joint venture (3) profession (4) closed corporation (5) other (e) Name of accountant, controller or other person in charge of financial records: (t) (1) (2) (3) (4) (c) (d) Annual income from business: Gross income per pay period: Net income per pay period: Specified deductions, if any: CERTIFICATE OF SERVICE I, Elizabeth S. Beckley, Esquire, hereby certify that a true and correct copy of the foregoing document was this day served upon the person and in the manner indicated below. SERVICE BY FIRST CLASS MAIL: John J. Connelly, Esquire James, Smith, Dietterick & Connelly, LLP P.O. Box 650 Hershey, PA 17033 DATED: 1).--)}-4-/ Form . . n IVI ua ncome ax eum (99) IRS Use Only - Do not write or staple in this space. For the year Jan 1 - Dee 31, lOO3, or other tax year beginning , lOO3, ending ,20 OMB No. 1545.0074 label Your first name MI Last name YOIII1 social security number (See instructions.) Will i am P Conrad 197-46-7834 If a joint return, spouse's first name MI Last name Spouse's social security number Use the L Conrad 176-52-5792 IRS label. Karen Otherwise, Home address (number and street). If you have a P.O. box, see instructions. Apartment no. ! Important! ! please print or type. 138 Wvomine: Avenue You must enter your social City, town or post office. If you have a foreign address, see instructions. State ZIP code security number(s) above. Presidential Enola PA 17025 - 1040 Election Campaign (See instructions.) Filing Status Check only one box. Exemptions If more than five dependents, see instructions. Income Attach Fonns W-2 and W-2G here. Also attach Fonn(s) 1099-R if tax was withheld. If you did not get a W-2, see instructions. Enclose, but do not attach, any payment. Also, please use Fo"" 1040-V. Adjusted Gross Income e e Department of the Treasury - Internal Revenue Service US I d""d II T R t 2003 ... Note: Checking 'Yes' will not change your tax or reduce your refund. You ,.. Do ou, or our s use if filin a 'oint return, want $3 to 0 to this fund? .......... ~ Yes X No Yes 1 Single Head of household (with qualifying person). (See 2 Married filing jointly (even if only one had income) instruc:tions.) If the qualifying person is a child but not your dependent, enter this child's 3 Married filing separately. Enter spouse's SSN above & full name here ~ name here . . ~ 5 Oualifymg widow(er) with dependent child. (See instructions.) 6a Yourself. If your parent (or someone else) can claim you as a de,pendent on his or 1- No.ofboxes her tax return, do not check box 6a .............................................. ~.:"'s:~ . . . b IK] Sse.. . . . . . . . . . .. .. . . . .. . . . . . . . . . . . . . . .. . .. .. . . . . . . . . . . . .. ... . . . . . . . . . . . . . .- ~:.:... (2) Der:ndent's (3) De~ndent's (4) if on Ie who: cDepen~: . socia security rela ionshlp qualifying. lived number to you ch: f~~~i1d withyou . . . . . (see instrs) . cIid not 161-72-0849 Son ~~~ 197-72-9052 Dau'hter MM~ (_ Instrs) . . . 179-74-6418 Son ~. 206-74-1295 Son :::..c.nc:bove. 162-80-0751 Dau,~hter I, ,I Acid numbers ......................................................~....~I No 2 5 (1) First name Zacker M Ma berr Katel n M Conrad Nathan P Conrad S encer N Conrad Natalie I Conrad d Total number of exemptions claimed 7 Wages, salaries, tips, etc. Attach Form(s) W-2 .. . . . . . . . . . . . . . . . .. .................... 7 8a Taxable interest. Attach Schedule B if required. . . . . . . . . . . . . . . . . ., .................... 8a b Tax-exempt interest. Do not include on line 8a ............. ~7;:C 9a Ordinary dividends. Attach Schedule B if required ................ , . . . . . . . . . . . . . . . . . . . . 9a b~If~~~................................................l!!!l V{;f~~ 10 Taxable refunds, credits, or offsets of state and local income taxes (see instructions) . , . . . . . . . . . . . . . . . . . . .. 10 11 Alimony received .................................................................. 11 12 Business income or (loss). Attach Schedule C or C-EZ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 12 13a Capital gain or (loss). Att Sch 0 if reqd. If not reqd, ck here . . . . . . . . . . . . . . . . . . . . . . . . . ~ 0 13a b ~~\~~~~~ . . . .. . " . . . . . . . . . . . . . . . . . . . . . . . . . . . .1 13bl (.;~,:,; 14 Other gains or (losses). Attach Form 4797 . . . . . . . . . . . . . . . . .. . . .. . . . . . . . . . . . . . . . . . . . . .. 14 15a IRA distributions ......... .1 15al I b Taxable amount (see instrs) .. 15b 16a Pensions and annuities ....11681 b Taxable amount (see instrs) .. 16b 17 Rental real estate, royalties, partnerships, S corporations, trusts, etc. Attach Schedule E .. 17 18 Farm income or (loss). Attach Schedule F ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 18 19 Unemployment compensation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 19 20a Social security benefits. . . . . . . . . ~I I b Taxable amount (see instrs) .. 20b 21 Other income 21 22 Add the amo~tS ~ 'ij,; fui""rlOht co~mn- tOr lines 7-throuah-21. ~s-Is-vour totaliriCOiM -~ 22 23 Educator expenses (see instructions) . . . . . . . . . . . . . . . . . . . . .. 23);'''.' 2A IRA deduction (see instructions) . . . . . . . . . . . . . . . . . . . . . . . . . .. 2A '':, 25 Student loan interest deduction (see instructions) ..... . . . . .. 25 " 26 Tuition and fees deduction (see instructions) ............... 26 i';~' Z1 Moving expenses. Attach Form 3903. . . . . . . . . . . . . . . . . . . . . .. Z1 i,\' ' 28 One-half of self-employment tax. Attach Schedule SE . . . . . .. 28 :'/'!< 29 Self-employed health insurance deduction (see instrs) . . . . . .. 29'" , 30 Self-employed SEP, SIMPLE, and qualified plans. . . . . . . . . .. 30;' 31 Penalty on early withdrawal of savings . . . . . . . . . . . . . . . . . . . .. 31 '; 32a Alimony paid b Recipient's SSN . . . . ~ .. 32a I', 33 Add lines 23 through 32a ................................................................ 33 34 Subtract line 33 from line 22. This is your adjusted gross income ..... . . . . . . . . . . . . . . . . ~ 34 Last name 71 51,876. 21. 2. 4,614. 56 513. BAA For Disclosure, Privacy Act, and Paperwork Reduction Act Notice, see instructions. FOIA0112 01116104 56.513. Form 1040 (2003) ~~mi' 1040 (2003) Tax and Credits Standard Deduction for- . People who checked any box on line 36a or 36b or who can be claimed as a dependent, see instructions . . All others; Single or Married filing separately, $4,750 Married filing jointly' or Qualifying widow(er), $9,500 Head of household, $7,000 Other Taxes Payments If you have a qualifying child, attach Schedule EIC. Refund Direct deposit? See instructions and fill in 70b, 7Oc, and 70<1. Amount You Owe Third Party Designee Sign Here Joint return? See instructions. Keep a copy for your records. Paid Prepilrer's Use Only William P & Ka~ L Conrad ~ 197-46-7834 35 Amount from line 34 (adjusted gross income) ......................................... 36a Check r 0 You were born before January 2, 1939, 0 Blind, Total boxes if: 1 0 Spouse was born before January 2, 1939, 0 Blind. checked · 36a I b If you are married filing separately and your spouse itemizes deductiOns, _ or you were a dual-status alien, see instructions and check here . . . . . . . . . . . . .. 36b 0 31 Itemized deductions (from Schedule A) or your standard deduction (see left margin) .................... 38 Subtract line 37 from line 35 ........................................................ 39 If line 35 is $104,625 or less, multiply $3,050 by the total number of I~xemptions claimed on line 6d. If line 35 is over $104,625, see the worksheet in the instructions. .. . . . . . . . . . .. 39 40 Tauble income. Subtract line 39 from line 38. If line 39 is more than line 38, enter -0- . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 40 41 Tax (see instrs). Oleck if any tax is from a 0 Form(s) 8814 b 0 Form 4972 ....................... 41 42 AItemative minimum tax (see instructions). Attach Form 6251 .....,.................... 42 43 Add lines 41 and 42 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. ................... 43 44 Foreign tax credit. Attach Form 1116 if required. . . . . . . . . . . .. 44 45 Credit for child and dependent care expenses. Attach Form 2441 .......... 45 46 Credit for the elderly or the disabled. Attach Schedule R . . . .. 46 ~ Education credits. Attach Form 8863 . . . . . . . . . . . . . . . . . . . . . .. ~ 48 Retirement savings contributions credit. Attach Form 8880 . .. 48 49 Child tax credit (see instructions) . . . . . . . . . . . . . . . . . . . . . . . . .. 49 50 Adoption credit. Attach Form 8839 . . . . . . . . . . . . . . . . . . . . . . . .. 50 51 Credits from: a 0 Form 8396 b 0 Form 8859 '" . . . . . . . . . . . .. 51 52 Other credits. Check applicable box(es); a 0 Form 31m b 0 ~nr c Dspecify 52 53 Add lines 44 through 52. These are your total credits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ., 53 54 Subtract line 53 from line 43. If line 53 is more than line 43, enter -0- . . . . . . . . . . . . . . . . . .. 54 55 Self-employment lax. Attach Schedule SE . . . . . . . . . . . . . . . . . . . . .. . . . . . . .. . . . . . . . . . . . . . . .. . . . . . ., 55 56 Social security and Medicare tax on tip income not reported to employer. Attach Form 4137 ................. 56 57 Tax on qualified plans, including IRAs, and other tax-favored accounts. Attach Form 5329 if required . . . . . . . . . .. 57 58 Advance earned income credit payments from Form(s) W-2 ............................ 58 59 Household employment taxes. Attach Schedule H ..................................... 59 60 Add Jines 54-59. This is ur total tax . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . · 60 61 Federal income tax withheld from Forms W-2 and 1099 . . . . .. 61 5 , 022 . 62 2003 estimated tax payments and amount applied from 2002 return . . . . . . .. 62 63 Earned income credit(ElC) ............................... 63 I 64 Excess social security and tier 1 RRT A tax withheld (see instructions) ...... 64 65 Additional child tax credit. Attach Form 8812 ............... 65 66 Amount paid with request for extension to file (see instructions) . . . . . . . . .. 66 fi1 Other pmts from: a 0 Form 2439 b 0 Form 4136 c 0 Form 8885 fi1 68 Add lines 61 through 67. These are your total payments .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 68 69 If line 68 is more than line 60, subtract line 60 from line 68, This is the amount you overpaid. . . . . . . . . . . . . . .. 69 70a Amount of line 69 you want refunded to ou . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 70a ~ b Routing number ....... XXXXXXXXX ~ c T Checking 0 Savings ~ d Account number . . . . . . . XXXXXXXXXXXXXXXXX 71 Amount of line 69 you want applied to your 2OlI4 estimated tax . . . . . . . .. 71 72 Amount you owe. Subtract line 68 from line 60. For details on how to pay, see instructions ............... · 73 Estimated tax penalty (see instructions) . . . . . . . . . . . . . . . . . . . .l..z!.l Do you want to allow another person to discuss this return with the IRS (see instructions)? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 0 Yes. Complete the following. Designee's Phone Personal identification name ~ no. ~ number (pIN) ~ Under penalties of perjury, I declare that I have examined this return and accompanying schedules and statements, and to the best of my knowledge and belief, they are true, correct, and complete. Declaration of preparer (other than taxpayer) is based on all information of which preparer has any knowledge. Your signature Date Your oc<:upation Daytime phone number Pa e 2 56 513. 9 500. 47 013. 21,350. 25 663. 3 151. 3 151. 3 000. 3 000. 151. 151. 5,022. 4 871. 4 871. fK] No ~ Spouse's signature. If a joint return, balh must sign. ~ Date Railroad Welder Spouse',; occupation Homemaker Date Preparer's .. signature ,.. Firm'sname Sel f-Prepared (or yours if .. self -employed),'" address, and ZIP code Check if seIf.employed EIN Phone no. Form 1040 (2003) FDIA0112 01116104 WILLIAM P. CONRAD, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYL VANIA v. :CIVIL ACTION - LAW :IN DIVORCE KAREN CONRAD, Defendant :NO.02-4216 INVENTORY OF WILLIAM P. CONRAD Plaintiff, William P. Conrad, files the following inventory of all property owned or possessed by either party at the time this action was I::ommenced and all property transferred within the preceding three years. DATED: 1)~I}--{jL) (j) Altl otvt! William P. Conrad ASSETS OF THE PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. -1L 1. Real Property -1L 2. Motor vehicles -1L 3. Stocks, bonds, securities and options 4. Certificates of deposit 5. Checking accounts, cash -1L 6. Savings accounts, money market and savings certificates 7. Contents of safe deposit boxes 8. Trusts 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) 10. Annuities 11 . Gifts 12. Inheritances 13. Patents, copyrights, inventions, royalties 14. Personal property outside the home 15. Business (list all owners, including percentage of ownership, and officer/director positions held by a party with company) 16. Employment termination benefits -- severancc~ pay, worker's compensation claim/award 17. Profit sharing plans 18. Pension plans (indicate employee contribution and date plan vests) -1L 19. Retirement plans, Individual Retirement Accounts 20. Disability payments 21. Litigation claims (matured and unmatured) 22. MilitaryN.A. benefits 23. Education benefits 24. Debts due, including loans, mortgages held -1L 25. Household furnishings and personalty (include as a total category and attached itemized list if distribution of such assets is in dispute) 26. Other (Jewelry) MARITAL PROPERTY Plaintiff lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced: Item Number 2 6 Description of Property 1993 Grand Am $21,857 + interest* 19 3 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 Railroad retirement 3 shares of Norfolk Southern couch, loveseat, end tables aquarium stand broken TV w/stand wooden lamps filing cabinet - oak personal stuff in attic railroad art ~ CDs & videos CD racks mattresses from bunk beds Bill's bed family room VCR 2 dressers, night stand gas grill/microwave hutch 1 child's desk Natalie's tent extension ladder Sears mower weed wacker tools ice tea mIxer electric frying pan old nebulizer shop vac black vacuum cleaner step ladder mower grass seed spreader ,Names of all Owners Karen Conrad .J oint *being held in Beckley & Madden's escrow account Bill Conrad Bill Conrad Bill Conrad Bill Conrad Bill Conrad Bill Conrad Bill Conrad Bill Conrad Bill Conrad Bill Conrad Bill Conrad Bill Conrad Bill Conrad Bill Conrad Bill Conrad Bill Conrad Bill Conrad Bill Conrad Bill Conrad Bill Conrad B ill Conrad B:lll Conrad Bdl Conrad Bill Conrad Bill Conrad Bill Conrad Bill Conrad Bill Conrad Bill Conrad Karen Conrad KSlfen Conrad Karen Conrad 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25* 25* 25* swing set flower pots freezer Christmas stuff toaster blender coffee maker crock pot ? new nebulizer flower cart from deck deck furniture shelves family room sofa & reclining chair blue & white dishes cookware aquarIum 2 filing cabinets lf2 CDs/videos Karen's bed kids' bed step ladder end tables - family room table & chairs - kitchen refrigerator Sue's TV hall table/seat dresser in basement computer/desk 1 child's desk pIano Y2 towelslblankets lf2 Natalie's stuff family portraits family photos both farm art pictures Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad Karen Conrad *Bill wants the camera lens, both farm art pictures, Y2 the family portraits, and lf2 the family photos. NON-MARITAL PROPERTY Plaintiff lists all property in which spouse has a legal or equitable interest which is claimed to be excluded from marital property: Item Number 25 Description of Property camera lens Reason for Exclusion Bill's prior to marriage but in Karen's possession PROPERTY TRANSFERRED Item L 2 Description of Property 1984 Ford Van Date of Transfer 4-11-03 Person to Whom Transferred Junkyard Value at date of aquisition ? 73 Greenwood Drive Enola, P A 17025 Boyd & Dana Shepler $129,900.00 Item Value as of Date L of Transfer 2 0 1 $160,000.00 LIABILITIES Item Number Description of Property Names of All Creditors Chase Visa Americhoice Fred Roberts Hilton Dinimich Wilda Berden Dotty Hoke Horn Hospital Names of All Debtors Amount of Debt $4,258.00 2,973.12 8,056.50 2,519.30 190.00 669.00 79.00 CERTIFICATE OF SERVICE I, Elizabeth S. Beckley, Esquire, hereby certify that a true and correct copy of the foregoing document was this day served upon the person and in the manner indicated below. SERVICE BY FIRST CLASS MAIL: John J. Connelly, Esquire James, Smith, Dietterick & Connelly, LLP P.O. Box 650 Hershey, PA 17033 DATED: I)--rr-&-f WILLIAM P. CONRAD, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION - LAW :IN DIVORCE KAREN CONRAD, Defendant :NO.02-4216 PETITION FOR EQUITABLE DISTRIBVTION VNDER SECTION 3502 OF THE DIVORCE CODE AND NOW comes the Plaintiff, William P. Conrad, who, by and through his attorneys, Thomas A. Beckley, Esquire, Elizabeth S. Beckley, Esquire, and Beckley & Madden, of Counsel, files this Petition for Equitable Distribution under Section 3502 of the Divorce Code, in which he avers that: 1. Plaintiff, William P. Conrad, is an adult individual residing at 138 Wyoming Avenue, Enola, Cumberland County, Pennsylvania 17025. 2. Defendant, Karen Conrad, is an adult individual residing at 108 Scrignoli Lane. Enola, Cumberland County, Pennsylvania 17025. 3. Plaintiff filed a Divorce Complaint in this matter on September 4,2002. 4. Plaintiff and Defendant have acquired property, both real and personal, during the marriage which constitutes marital property subject to equitable distribution under the Divorce Code. 5. Plaintiff and Defendant each owned, prior to the marriage, both real and personal property which has increased in value during the marriage, and/or which has been exchanged for other property which has increased in valm, during the marriage, all of which property is marital property, subject to equitable distribution under the Divorce Code. 6. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Plaintiff, William P. Conrad, respectfully requests the Court to divide all marital property equitably between the parties. DATED: ;;~JJ{.-rr- RespectfLllly submitted, of Counsel ~7 / ~ V~~_____ ~\.. Beckl BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg. PA 17108 (717) 233-7691 ?~t: ~S. 2 CERTIFICATE OF SERVICE I, Elizabeth S. Beckley, Esquire, hereby certify that 8 true and correct copy of the foregoing document was this day served upon the person 1md in the manner indicated below. SERVICE BY FIRST CLASS MAIL: John J. Connelly, Jr., Esquire James Smith Durkin & Connelly P.O. Box 650 Hershey, PA 17033 DA TED: :;~I/'1J) -l.<:\. P ~ -,q l'fr C> 1l \\- c> ~ 0 ~ - -J <3c~~ ~ l:?- ~ ~ r fJ). , -....-.') , . r-,.! ----- WILLIAM P. CONRAD, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 02 - 42]6 CIVIL TERM KAREN CONRAD, Defendant : CIVIL ACTION - LAW : IN DIVORCE INCOME AND EXPENSE STATEMENT OF: KAREN CONRAD I INCOME I Employer: Homemaker I Address: 108 Sgrignoli Lane, Enola, P A 17025 Type of Work: Payroll Number: Pay Period (weekly, biweekly, etc.): Ioross Pay per Pay Period: $0 , Itemized Payroll Deductions: Federal Withholding Social Security Local Wage Tax State Income Tax Retirement Savings Bonds Credit Union Life Insurance Health Insurance Unemployment Tax Other - Medicare Net Pay per Pay Period: $0 MONTHLY YEARLY (Fill in appropriate column) OTHER INCOME Interest Dividends ! Pension Annuity ! Social Security Rents Royalties Expense Accounts Gifts Unemployment Compo Worker's Compo Alimony Pendente Lite Child Support TOTAL NET INCOME $400.00 $858.56 $1,258.56 $4,800.00 $10,302.72 $15,102.72 EXPENSES Home Mortgage/Rent Maintenance ! V tilities Electric Gas Oil Telephone Water Sewer $690.00 $8,280.00 $50.00 $50.00 $600.00 $600.00 $115.00 $25.00 $15.00 $1,380.00 $300.00 $180.00 MONTHLY YEARLY (Fill in appropriate column) Employment Public Transportation Lunch Taxes Real Estate $104.20 $1,250.40 Personal Property Income Insurance Homeowners $14.70 $176.40 Automobile $63.50 $762.00 Life Accident Health Other i Automobile Payments $200.00 $2,400.00 Fuel $150.00 $1,800.00 Repairs $100.00 $1,200.00 Medical Doctor $15.00 $180.00 Dentist Orthodontist $20.00 $240.00 Hospital Medicine $10.00 $120.00 Special Needs (glasses,contacts, braces, orthopedic devices) . . MONTHLY YEARLY (Fill in appropriate column) Education Private School Parochial School College Religious Personal Clothing $50.00 $600.00 Food $100.00 $1,200.00 Barber/Hairdresser $15.00 $180.00 Credit Payments $500.00 $6,000.00 Charge Accounts Memberships . Loans Credit Union Miscellaneous Household Help Child Care Paper/Books/Magazines $5.00 $60.00 Entertainment $50.00 $600.00 Pay TV $40.00 $480.00 Vacation . Gifts Legal Fees $50.00 $600.00 Charitable Contributions Other Child Support TOTAL EXPENSES $2,432.40 $29,188.80 . VERIFICATION I verify that the statements made in this Income and Expense Statement are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: S /6-/06 ) kc\. u (\ (! IJ(\...'\i.ll! Karen Conrad, Defendant - r-"'i \:.:~) \.J" ....', ...--< \ 0-\ _:-\ -::\~ <.:? -- ...:. j.,;- , WILLIAM P. CONRAD, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 02 - 4216 CIVIL TERM KAREN CONRAD Defendant CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S PRE-TRIAL STATEMENT Date of Marriage: Date of Separation: Divorce Complaint filing date: February 15, 1992 September 10,2002 September 4, 2002 1. ASSETS A. Marital Property VaTue 1. 73 Greenmont Drive Enola, PA 17025 Proceeds from sale are held in escrow by counsel for Plaintiff, William P. Conrad, Jr. $22,000.00 (approx.) (actual balance to be determined prior to hearing) 2. Husband's Railroad Retirement Tier II To be determined 3. Vehicles A. 1984 Ford Van - junked $50.00 B. 1993 Pontiac Grand Am (hasn't run in two years) $0 4. Miscellaneous personal property owned by the parties was previously divided. Husband removed from the marital residence property of comparable value to the property retained by Wife. Each party should retain the property in their possession. In January of 2004, Husband removed a number of items from the marital residence when Wife was away, leaving the remainder of the items to be moved by Wife prior to the sale of their residence in April of 2003. 2. EXPERT WITNESSES Defendant knows of no expert witnesses at this time. However, Defendant reserves the right to supplement this answer should such become available. 3. NON-EXPERT WITNESSES William P. Conrad, Plaintiff Karen Conrad, Defendant Defendant knows of no non-expert witness at this time with exception to the parties. However, Defendant reserves the right to supplement this answer should such become available. 4. EXlllBITS Defendant's Income and Expense Statement. (Exhibit "A") is. NET INCOME A. Plaintiff - See Plaintiff's Income and Expense Statement. B. Defendant - See Defendant's Income and Expense Statement. (Exhibit "A") \6. EXPENSES A. Plaintiff - See Plaintiff's Income and Expense Statement. B. Defendant - See Defendant's Income and Expense Statement. (Exhibit "A") 7. PENSIONS/RETIREMENT A. Plaintiff - Railroad Retirement Tier II B. Defendant - None 8. COUNSEL FEES Plaintiff: Plaintiff has not made a claim for counsel fees. Defendant: Defendant has not made a claim for counsel fees. 9. PERSONAL PROPERTY DISPUTE Unknown at this time. 10. DEBTS Amount 1. Chase Visa $4,258.00 2. Arnerichoice $2,973.12 3. Fred Roberts $8,056.50 4. Hilton Dinimich $2,519.30 5. Wilda Berden $190.00 6. Dotty Hoke $669.00 7. Horn Hospital $79.00 8. Kohl's $378.22 All of the above debts with the exception of the Kohl's bill were paid from the proceeds of the sale of the marital residence either on the settlement sheet or subsequently by counsel for Husband through the previously mentioned escrow account. 11. PROPOSED RESOLUTION The assets in this matter are limited to the actuarial determination of the value of Husband's Tier II Pension with Railroad Retirement and the escrow proceeds remaining from the sale of the marital residence. The Defendant has made no claim for alimony although she is receiving alimony pendente lite in the amount of $400.00 per month until all of the economic issues are resolved. Because of the significant disparity in the earnings of the parties, the Defendant is requesting that the net assets as determined by the Master be distributed seventy (70%) percent to Wife and thirty (30%) percent to Husband with Wife receiving the cash in the escrow account as part of her equitable distribution. Respectfully submitted, JAMES, SMITH, DIETTERICK & CONNELLY Date: 5/5/'6 , ('i ( By: "j.,,/\\., \ \.I ' '.;.. John J. Connelly, Jr., Es Atto\-.qey fdr Defendant , P.O. Box 650 Hershey, PA 17033 (717) 533-3280 PA I.D. No. 15615 Exhibit "A" WILLIAM P. CONRAD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 02-4216 CIVIL TERM KAREN CONRAD, Defendant CIVIL ACTION - LAW IN DIVORCE INCOME AND EXPENSE STATEMENT OF: KAREN CONRAD INCOME Employer: Homemaker Address: 108 Sgrignoli Lane, Enola, P A 17025 Type of Work: Payroll Number: Pay Period (weekly, biweekly, etc.): Gross Pay per Pay Period: $0 Itemized Payroll Deductions: Federal Withholding Social Security Local Wage Tax State Income Tax Retirement Savings Bonds Credit Union Life Insurance Health Insurance Unemployment Tax Other - Medicare Net Pay per Pay Period: $0 MONTHLY YEARLY (Fill in appropriate column) OTHER INCOME Interest Dividends Pension Annuity Social Security Rents Royalties Expense Accounts Gifts Unemployment Compo Worker's Compo Alimony Pendente Lite Child Support TOT AL NET INCOME $400.00 $858.56 $1,258.56 $4,800.00 $10,302.72 $15,102.72 EXPENSES Home Mortgage/Rent Maintenance Utilities Electric Gas Oil Telephone Water Sewer $690.00 $8,280.00 $50.00 $50.00 $600.00 $600.00 $115.00 $25.00 $15.00 $1,380.00 $300.00 $180.00 I MONTHLY YEARLY (Fill in appropriate column) Employment Public Transportation Lunch Taxes Real Estate $104.20 $1,250.40 Personal Property Income Insurance Homeowners $14.70 $176.40 Automobile $63.50 $762.00 Life Accident Health Other Automobile Payments $200.00 $2,400,00 Fuel $150.00 $1,800.00 Repairs $100.00 $1,200.00 Medical Doctor $15.00 $180.00 Dentist Orthodontist $20.00 $240.00 Hospital Medicine $10.00 $]20.00 Special Needs (glasses,contacts, braces, orthopedic devices) MONTHLY YEARLY (Fill in appropriate column) Education Private School Parochial School College Religious Personal Clothing $50.00 $600.00 Food $100.00 $1,200.00 Barber/Hairdresser $15.00 $180.00 Credit Payments $500.00 $6,000.00 Charge Accounts Memberships Loaus Credit Union Miscellaneous Household Help Child Care Paper/Books/Magazines $5.00 $60.00 Eutertainment $50.00 $600.00 Pay TV $40.00 $480.00 Vacation Gifts Legal Fees $50.00 $600.00 Charitable Contributions Other Child Support TOTAL EXPENSES $2,432.40 $29,188.80 VERIFICATION I verify that the statements made in tlus Income and Expense Statement are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: S /6-/06' I kCLLU\ (11J1'\jlRd . Karen Conrad, Defendant - .. , ~ WILLIAM P. CONRAD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 02 - 4216 CIVIL TERM KAREN CONRAD Defendant : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE I, John J. Connelly, Jr., Esquire, of James, Smith, Dietterick & Connelly, LLP, attorney for the Defendant, Karen Conrad, hereby certify that I have served a copy of the foregoing Pre-Trial Statement on the following on the date and in the manner indicated below: VPS OVERNIGHT DELIVERY E. Robert Elicker, III, Esquire Cumberland County Divorce Master 9 North Hanover Street Carlisle, PAl 7013 VIA FACSIMILE (717) 233-3740 AND V.S. MAIL. FIRST CLASS. PRE-PAID Elizabeth S. Beckley, Esquire Beckley & Madden 2 I 2 North Third Street P.O. Box 11998 Harrisburg, PAl 71 08-1998 JAMES, SMITH, DIETTERICK & CONNELLY LLP Date: S;5- As- . By:C '_ ~Q.< .' JoIiV J. Co elly, Jr., Esq 'r J A.~ey for efendant ' Post Office Box 650 Hershey, PAl 7033 (71 7) 533-3280 PA J.D. No. 15615 ~-,.~ \ C' -'r: (.;\' ~<- J-~~ State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 08/05/05 Case Number (See Addendum for case summary) ORDER/NOTICE TO WITHHOLD INCOME FOIR SUPPORT CI\\ 10\- 1'-\3 l.tA2 S 2002. o Original Order/Notice CD Amended Order/Notice o Terminate Order/Notice EmployerAVithhoJder's Federal fiN Number RE: CONRAD, WILLIAM P. JR Employee/Obligor's Name (Last, First, Ml) NORFOLK SOUTHERN CORP 110 FRANKLIN RD SE ROANOKE VA 24042-0002 \\L\lo'StcOl 02- 42\\D C\\JtI 197-46-7834 Employee/Obligor's Social Security Number 2089101010 Employee/Obligor's Case Identifier (See Addendum fOf plaintiH names associated with cases on attachment) Custodial Parent's Name (last, First, MI) See Addendum for dependent names and birth dates associat,w 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. $ 1,258.56 per month in current support $ 25 . 00 per month in past-due support Arrears 12 weeks or greater? 0 yes <Xl no $ 0.00 per month in current and past-due medical support $ 0.00 per month for genetic test costs $ per month in other (specify) for a total of $ 1,283.56 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the SUPPOlt order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 296 . 21 per weekly pay period. $ 592.41 per biweekly pay period (every two weeks). $ 641.78 per semimonthly pay period (twice a month). $ 1.283.56 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 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 #9 on page 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, Harrisbuirg, 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 SO~1 CU~' ~N aRDER ro" ",a,,",,", DO NOT SEND CASH BY MAIL. , T OU~T: b... AUG 0 8 Z005 V' ~ o.~_\ Date of Order: ~ 'b. -bD~1\~~1 OMS No.; 0970-0154 Form tJ~ Worker I;;'VIATT Service Type M ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If. checked you are required. to provi(le a copy of this form to your. employee. If your employee works in.a state that is different from the state that ISSUed this order, a copy must be provided to your employee even If the box IS not checked. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3.* Repo.I;1I5ll.e PayddldDate of'v'V;~,l.vldjltg. Yvu IIlu:>l.epo.llln: (layddt'C:ldak vi yvitl,IIVIJ;lIo 'Vvln:1I 5elld;lIg till;; fJaYlllellL Ti,e p..1yddldJare of yy;ll,llvIJ;lIg;5 tin: Jette 0" nl';LI. C1Illvl....t VVd3 yv;t1,I.eld flail. lit..:: flllptovee', VYdl5fS. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.' Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must hOllor all OrdersINotices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 5211880140 EMPLOYEE'S/OBlIGOR'S NAME: CONRAD, WILLIAM P. JR EMPLOYEE'S CASE IDENTIFIER: 2089101010 DATE OF SEI'ARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the OrderlNotice 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 govems unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking discipiinal)' 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 govems. 9.' Withholding limits: You may not withhold more than the lesser of: 1) the amounts aHowed by the Federal Consumer Credit Protection Act (15 U.s.c. ~1673 (b)); 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 'eft after making mandatoI)' deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. ) O. Additional Info: 'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATIACHMENT UNIT by telephone at (717) 240-6225 or by FAX at l.ZlZl....<'40-&248 or by internet www.childsupport.state.pa.us Page 2 of 2 Form E N-028 Worker ID $IATT Service Type M OM6No.:0970-0154 ADDENDUM Summary of Cases on Attachment Defendant/Obligor: CONRAD, WILLIAM P. JR PACSES Case Number 174105607 Plaintiff Name KAREN L. CONRAD Docket Attachment Amount 02~ CIVIL$ 425.00 Child(ren)'s Name(s): DOS PACSES Case Number 971104743 Plaintiff Name KAREN L. CONRAD Docket Attachment Amount 00692 S 2002 $ 858.56 Child(ren)'s Name(s): KATELYN MICHELE CONRAD NJ\.TI!lINPA'iJI.i CONRAD ~PENC~R .NOLAN C9N~D NATALrEI:,ABELLACoNRAD DOB 04/28/91 02/14/93 OS/20/94 09/28/00 you are required to enroll the child(ren) 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. Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOS PACSES Case Number Plaintiff Nam'~ Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name 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 P ACSES 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 Dlf checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. 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. Addendum Form EN-02B Worker ID $IATT Service Type M OMB NQ.: 0970-01 54 -r.J'.: rnr:_, ;;~-.., ' ~~." --. > () c ~-: t-> g c.n :t'" C~ ,,-, N ~; ~~~2 2-= :.=2 -0 :-.:: '-:? <J1 o ~ ~ "'~ m ::J3i:? OL'> ::~~~ '\:) C) drn -" r:: :5!. , ~5- Lf~{u ~ PROPERTY SETTLEMENT AGREEMENT This is a Property Settlement Agreement entered into this r day o~ 2005, by and between WILLIAM P. CONRAD, of Enola, Pennsylvania (hereinafter referred to as "Husband"), and KAREN CONRAD, of Enola, Pennsylvania (hereinafter referred to as "Wife"). WITNESSETH: WHEREAS, Husband and Wife were lawfully married on February 15, 1992, and; WHEREAS, the parties are the parents of four minor children: Katelyn Conrad born April 28, 1991, Nathan P. Conrad born February 14,1993, Spencer N. Conrad born May 20, 1994 and Natalie I. Conrad born September 28,2000; and WHEREAS, unhappy differences have arisen between Husband and Wife in consequence of which they are now living separate and apart from each other; and WHEREAS, Husband and Wife are now in the process of obtaining a divorce, and, consequently, they desire to settle and determine finally and for all time both their respective financial and property rights, including any and all claims which either of them may have against the other. NOW THEREFORE, in consideration of this Property Settlement Agreement, and of the mutual promises, covenants and undertakings set forth herein, and incorporating the above "WHEREAS" clauses herein by reference, the parties hereto, each intending to be legally bound, hereby agree as follows: 1. SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place as he or she may from time to time choose or deem fit. The foregoing provisions shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of the causes leading to their living apart. 2. INTERFERENCE: Each party shall be free from interference, authority and contact by the other, as fully as ifhe 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 or 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 other's peaceful existence, separate and apart from the other. 3. WIFE'S DEBTS: Wife represents and warrants to Husband that since the separation she has not and in the future she will not contract or incur any debt or liability for which Husband or his estate might be responsible, and that she shall indemnifY and save hannless Husband from any and all claims or demands incurred by her. 4. HUSBAND'S DEBTS: Husband represents and warrants to Wife that since the separation he has not and in the future he will not contract or incur any debt or liability for which Wife or her estate might be responsible, and that he shall indemnifY and save hannless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. 5. OUTSTANDING JOINT DEBTS: All debts, obligations or liabilities incurred at any time in the past by either of the parties will be paid promptly by the party which incurred such debt, obligation or liability, unless except as otherwise specifically set forth in this Agreement. Each of the parties hereto further promises, covenants and agrees that each will now and at all times hereafter save harmless and keep the other or 2 his or her estate indemnified and saved harmless from ail debts or liabilities incurred by him or her, as the case may be, and from ail actions, claims and demands whatsoever with respect thereto, and from ail costs, legal or otherwise, and counsel fees whatsoever appertaining to such actions, claims and demands. Neither party shaIl, after the date of this Agreement, contract or incur any debt or liability for which the other or his or her property might be responsible, and shaIl indemnity and save harmless the other from any and ail claims or demands made against her or him by reason of debts or obligations incurred by her or him, and from ail costs, legal costs and counsel fees incurred in connection therewith unless provided to the contrary herein. Wife agrees to be solely and separately responsible for ail debts which have arisen or which may in the future arise from her Kohl's creditcard, and Wife agrees to indemnity and save harmless Husband from any and ail claims or demands made against him by reason of such debt or obligation and from ail costs, legal costs and counsel fees incurred by Husband in connection therewith. 6. BANK ACCOUNTS AND RETIREMENT ACCOUNTS: Husband and Wife are owners of individual savings, checking and pension accounts at various institutions including Husband's pension with the United States Railroad Retirement Board. Husband hereby releases ail claims in and to ail accounts in the name of Wife, and Wife hereby releases ail claims in and to ail accounts in the name of Husband including his pension with the United States Railroad Retirement Board, and each party shaIl retain as his or her separate property each account currently titled to that party. Husband and Wife agree to sign, upon request and after execution of this Agreement, any titles or any other docwnents reasonably necessary to give effect to this Section. 3 7. HUSBAND'S RELEASE: Husband does hereby release, remIse, quitclaim, and forever discharge Wife and the Estate of Wife from any and all claims that he now has or may hereafter have against Wife, or in, to, or against her Estate or any part thereof, whether arising out of any former contracts, agreements, engagements, or liabilities of Wife, or by way of dower or claim in the nature of dower, spouse's right or under any intestate laws or the right to take against Wife's Will, or for equitable distribution, support, alimony, alimony pendente lite, or maintenance of any other nature whatsoever, excepting only those rights accruing to Husband under this Postnuptial Agreement. 8. WIFE'S RELEASE: Wife does hereby release, remise, quitclaim, and forever discharge Husband and the Estate of Husband from any and all claims that she now has or may hereafter have against Husband, or in, to, or against his Estate or any part thereof, whether arising out of any former contracts, agreements, engagements, or liabilities of Husband, or by way of dower or claim in the nature of dower, spouse's right or under any intestate laws or the right to take against Husband's Will, or for equitable distribution, support, alimony, alimony pendente lite, or maintenance of any other nature whatsoever, excepting only those rights accruing to Wife under this Postnuptial Agreement. 9. MUTUAL INDEMNIFICATION: Each party represents that no debts, liabilities, or obligations have been incurred or contracted for for which the other party or the Estate of the other party may be responsible or liable, except those specifically identified in this Agreement. Each party hereto shall hereafter keep the other and his or her heirs and personal representatives indemnified and saved hannless against and from all debts and liabilities contracted for or incurred by or on behalf of the indemnifYing party, and against and from 4 all actions, proceedings, claims, demands, costs, attorneys' fees and expenses incurred in respect to any such debts or liabilities, excepting, however, obligations of the parties hereto to each other under this Agreement. 10. DIVISION OF REAL PROPERTY: Husband and Wife did own jointly the marital residence, situated at 73 Greenmont Drive, Cumberland County, Pennsylvania. Husband and Wife sold the marital residence and currently have approximately $22,269.32 in Beckley & Madden's Escrow Account. Husband and Wife agree that Wife will receive this money and any interest earned thereon as Wife's share of the equitable distribution of the parties' assets at the time of execution of this agreement. II. DIVISION OF PERSONAL PROPERTY: The parties have divided between them, to their mutual satisfaction, their personal property and the personal effects, household furniture and furnishings, and all other articles of personal property which have theretofore been used by them in common, and neither party will make any claim to any items of personal property which are now in the possession or under the control of the other. Should it become necessary, the parties each agree to sign any titles or documents necessary to give effect to this paragraph upon request. 12. AUTOMOBILES: Husband and Wife agree that Wife shaIl be the sole and separate owner of the 1993 Grand Am. Wife agrees to assume all responsibility for any outstanding debt balance on the vehicle, indemnifYing and holding Husband harmless from any financial responsibility arising from nonpayment thereon. Husband and Wife agree to execute any and all instruments and documents necessary in order to effectuate the transfer of title to said automobile. 5 13. INCOME TAX: The parties have filed joint federal, state and local tax returns up to and including 2003. Both parties agree that, in the event any deficiency in federal, state or local income tax is proposed or any assessment of any such tax is made against either of them, each will indemnity and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns. Should it be determined that neither party is at fault for any of the foregoing, the parties agree that they will be equally responsible for payment of any tax, interest, penalty or expense which is determined to be due and owmg. 14. LIFE INSURANCE POLICIES: Husband and Wife agree to waive any and all claims and relinquish all rights and interest they may have in any and all life insurance policies of the other. ] 5. COUNSEL FEES: Husband and Wife agree to be solely and separately responsible for hislher own counsel fees. ]6. BREACH: If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, to sue for specific performance, and to seek such other remedies or relief as may be available to him or her, and the party breaching this contract shall be responsible for payment of ]egal fees and costs incurred by the other in enforcing their rights under this Agreement. 6 17. ADDITIONAL INSTRUMENTS: 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 that may be reasonably required to give full force and effect to the provisions of this Agreement. 18. VOLUNTARY EXECUTION: Wife has employed and had the benefit of counsel from John J. Connelly, Jr., Esquire, as her attorney. Husband has employed and had the benefit of counsel from Elizabeth S. Beckley, Esquire as his attorney. Each party acknowledges that he or she fully understands the facts and has been fully informed as to his or her legal rights and obligations, and each party acknowledges and accepts that this Agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and/or with such knowledge as each party desires, and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. Also, each party hereto acknowledges that under the Pennsylvania Divorce Reform Act, the Court has the right and duty to determine all marital rights of the parties, including divorce, alimony, alimony pendente lite, equitable distribution of all marital property or property owned or possessed individually by the other, counsel fees and costs of litigation and, fully knowing the same and being advised of his or her rights thereunder, each party hereto still desires to execute this Agreement, acknowledging that the terms and conditions set forth herein are fair, just, and equitable to each of the parties, and each party waives their respective right to have the Court of Common Pleas or any Court of competent jurisdiction make any determination or order affecting the respective parties' right to a alimony, alimony pendente lite, equitable distribution of all marital property, counsel fees and costs of litigation. 7 19. ENTIRE AGREEMENT: This Agreement contains the entire understanding of the parties, and there are no representations, warranties, covenants, or undertakings other than those expressly set forth herein. This Agreement shall be binding upon the parties hereto, and there respective heirs, executors, administrators and assigns. 20. MODIFICATION AND WAIVER: A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed by both parties with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 2 I. SEVERABILITY: If any provision of this Agreement is held by a court of competent jurisdiction to be void, invalid or unenforceable, the remaining provisions hereof shall nevertheless survive and continue in full force and effect without being impaired or invalidated in any way. 22. DATE OF EXECUTION/EFFECTIVE DATE: The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which the parties signed the Agreement if they did so on the same date, or if not on the same date, then the date on which the Agreement was signed by the last party to execute this Agreement. This Agreement shall become effective and binding upon both parties on the execution date. 23. DESCRIPTIVE HEADINGS: The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in detennining the rights or obligations of the parties. 8 IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above-written. I;) db! (lyf) William P. Conrad _dAOJ\. ~ fR;\Rcl Karen Conrad COMMONWEALTH OF PENNSYLVANIA COUNTY OFOflt.LfiHJ ) ) SS.: ) On this the 1* day o~ ~ ,2005, before me, the undersigned officer, personally appeared William P. Conrad, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. ,LaL<-.V j-/~"-LA;dSEAL) Notary Public My Commission Expires: NOTARIAL SEAL GERALDINE J. SCRBACIC, Notary I"ubIlc City of Harrisburg, Dauphin County My Commission Expires Nov. 20, 2006 9 COMMONWEALTH OF PENNSYLVANIA COUNTY OF ~V). ) ) SS.: ) On this the,)if-J'1\ day of ~~~ , 2005, before me, the undersigned officer, personally appeared Karen Conrad, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. "--)~~'t t~/vi (SEAL) Notary Public My Commission Expires: TI1 OF PENNSYLVANIA ~~~l.A~'y PUBLIC MY -.. I iIIOH """...... COUNTY exPlltES JUNE 9, 2007 10 ..' n " , C. r"::', " (.."-1 .-1 ( ~ T ,-r fTl 'D J- r. .-.. en '-, " ,-," WILLIAM P. CONRAD, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION - LAW : IN DIVORCE KAREN CONRAD, Defendant :NO.02-4216 AFFIDAVIT OF CONSENT I. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on September 4, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. Dated: i - r{)) wAfA/ U William P. Conrad () "-' c:-,~ ~ c- '~".:";) '-, .;;;." <-) (/) :",:,1 ~ I '-C ::? - c;:> WILLIAM P. CONRAD, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYL VANIA v. :CIVIL ACTION - LAW : IN DIVORCE KAREN CONRAD, Defendant :NO.02-4216 AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on September 4, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verifY that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 9 4904 relating to unsworn falsification to authorities. Dated: flufjU{).1. ;;..{P ~oo5 J/~~ Karen Conrad "'> L-_'"J z;; C) -0 :;:' 1"0 (~...., 1-.1 -;:) I l...l:l -) C.;) WILLIAM P. CONRAD, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION - LAW : IN DIVORCE KAREN CONRAD, Defendant :NO.02-4216 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concernmg alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 9 4904 relating to unsworn falsification to authorities. Dated: 1- f-lJ) u)AlM U William P. Conrad n (,~. r'"'.) ~~~ i;?i1 C) -n :::.! (/i in -'U \ I.D I\-~ (,0 Ul C) WILLIAM P. CONRAD, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYL VANIA v. :CIVIL ACTION - LAW : IN DIVORCE KAREN CONRAD, Defendant :NO.02-4216 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE I. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concernmg alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verifY that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. Dated: au~LCJl. :2& Jj)o5 kMLfL ~flwuL Karen Conrad ," ., (- ~,::~ f:::.:_"'I U' ,~ ~ , \J" (-...:: CFI C' :'.L~, .-<.. WILLIAM P. CONRAD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW : IN DIVORCE KAREN CONRAD, Defendant : NO. 02-4216 PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following infonnation, to the Court for the entry of a Decree of Divorce. I. Ground for divorce: irretrievable breakdown of the marriage under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: the complaint was served on Karen Conrad, on September 9, 2002, by certified mail. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by plaintiff on September 7, 2005; by defendant on August 26, 2005 . 4. Related claims pending: None. 5. (a) Date plaintiff's Waiver of Notice September 7, 2005, and it is being filed contemporaneously herewith. (b) Date defendant's Waiver of Notice September 7, 2005, and it is being filed contemporaneously herewith. DATED: (/-9~O) ~''','tfull' '"bmiU~~ ~'J / 74 ,;// f1 Eli beth S. / Attorney for Plainti f // of Counsel BECKLEY & MADDEN 212 North Third Street P.O. Box J 1998 Harrisburg, PA 17108 (717)233-769] CERTIFICATE OF SERVICE I, Elizabeth S. Beckley, Esquire, hereby certify that a true and correct copy of the foregoing document was this day served upon the person and in the manner indicated below. SERVICE BY FIRST CLASS MAIL: John 1. Connelly, Esquire James, Smith, Dietterick & Connelly, LLP P.O. Box 650 Hershey, P A 17033 DATED: '(. (i (I')" r-' '~::::~ ~~':l ,~J'" ji-i w C'.} <1' ",] -- State Commonwealth of pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 09/08/05 Case Number (See Addendum for case summary) ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 47 IID'+ 7Lt-3 0'7), _S 02 1741C5uD-7 O-:J.. -1.f.!:Lllp e.v o Original Order/Notice o Amended Order/Notice o Terminate Order/Notice NORFOLK SOUTHERN CORP 110 FRANKLIN RD SE ROANOKE VA 24042-0002 RE: CONRAD, WILLIAM P. JR Employee/Obligor's Name (last, First, MI) 197-46-7834 Employee/Obligor's Social Security Number 2089101010 Employee/Obligor's Case Identifier (See Addendum for plaintiff nam('s associated with cases on attachment) Custodial Parent's Name (Last, First, Ml) EmployerlWithholder'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. 6y 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. $ 858.56 per month in current support $ 25. 00 per month in past-due support Arrears 12 weeks or greater? @yes 0 no $ 0.00 per month in current and past-due medical support $ 0 . 00 per month for geneti c test costs $ per month in other (specify) for a total of $ 883.56 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: $ 203.90 per weekly pay period. $ 407.80 per biweekly pay period (every two weeks). $ 441.78 per semimonthly pay period (twice a month). $ 883.56 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 paydateJdate of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's! obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-677-676-9580 for instructions. Make Remittance Payable to: PA SCOU Send check to: Pennsylvania seou, 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: SEP 0 9 2005 Service Type M OMBNQ.:0970-01S4 Form E N-028 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If (hecked you are required to provi(le a copy of this form to you~ employee. If yo~r employe~fwhorks in.a state hthat ieds different from the state that issued thIs order, a copy must be provided to your employee even I t e box IS not c eck . 1. priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3. * RC!Jvlt;lIg tlu:::: Pdyddle/Date v{VJitl.l,uIJ;lt5. Yuu IlIu;lICI-'vlllllc paydab'Jdte of vvitl,l,old;"5 vvllell ;'Clld;llg llle tJciylI leI It. Tile paydak1Jate vi vv;t'"Lv~d;hg;;:> lIlt:: J",te 011 vvl.;.....L dlllUUlIl vv<.t::> vv;tl.l.dJ (IVIII llu;:; t::'IlIJJlvycc'S vvdges. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.' Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 5211880140 EMPLOYEE'S/OBLlGOR'S NAME: CONRAD. WILLIAM P. JR EMPLOYEE'S CASE IDENTIFIER: 2089101010 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State Jaw 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. B. 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. 9.' Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.s.c. ~ 1673 ib)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 (ADWEI. ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not witl1l1old more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: 'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. l1.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) 240-6748 or by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Worker 10 $IATT Service Type M OMB No.: 0970-0154 ADDENDUM Summary of Cases on Attachment Defendant/Obligor: CONRAD, WILLIAM P. JR PACSES Case Number 174105607 Plaintiff Name KAREN L. CONRAD Docket Attachment Amount 02=4216 CIVIL$ 25.00 Child(ren)'s Name(s): DOB PACSES Case Number 971104743 Plaintiff Name KAREN L. CONRAD Docket Attachment Amount 00692 S 2002 $ 858.56 Child(ren)'s Name(s): KATELYN MICHELE CONRAD NATHAN PAUL CONRAD SPENCER NOLAN CONRAD NATALIE ISABELLA CONRAD DOB 04/28/91 02/14/93 OS/20/94 09/2B/oo If you are required to enroll the child(ren) in any health insurance coverage available through the employee's/obligor's employment. o If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the "mployee'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) 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 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 E~mployee's/obligor's employment. Addendum Form EN-028 Worker ID $IATT Service Type M OMBNo.:0970-0154 ~ ~ \ ~ (J ~ ...., c' ~ tf) I.-r~ -0 I ...0 -, o -n -. ::r;:-n (n~~, " c::) -;:::; o ~~~~ ~~ ~~~~~~~ ~~~~~~~ +.~~~~~.~~++++++~~+++~+++~ +. ++++++++ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. +~:f. "'+ . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY DIVORCE ~~kJ- ~1 . . . . STATE OF . . WILLIl'M P. CONRAD, . . Plaintiff . VERSUS KAREN CONRAD, Defendant . . . . . . . . AND NOW, PENNA. No. 02-4216 DECREE IN ~ .--- J..&D) , IT IS ORDERED AND DECREED THAT WILLIl'M P. COORAD , PLAINTIFF, . . KAREN COORAD AND , DEFENDANT, . ARE DIVORCED FROM THE BONDS OF MATRIMONY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A. FINA.L ORDER HAS NOT . YET BEEN ENTERED; NONE . By . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ++++.++.+++++:+::+:+++? . The Property Settlement l\greanent between the parties shall be incorporated into the final decree for purposes of enforCEment, but shall not merge with the final Decree in Divorce. :+: :+: :f. +++++'+:f. +'1' +:+: +.+:+:'1'+'1':+:'1'+'1'+'1' . . . . . ~ ,.. , " , '- -.... . '. ..... , , . , , , , .' - , - , . . . . . . . . . . '. . .: ",' .. .......--- .- "'- - ... .--/", . v / .,.......:.~. , ""/:--,0; "t, ~--=-....... OOo.oo.~ooo. OOo.oo~oo~ J. -h ':?- ~ ~ 5()- 8~'p ~ fr5 ~kKl.P'J 5IJ~b ........" . .' .. ; .' ~~ ~ WILLIAM P. CONRAD, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 02 - 4216 CIVIL TERM KAREN CONRAD, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO WITHDRAW CLAIMS TO THE PROTHONOTARY: Please withdraw the claims for Equitable Distribution, Alimony Pendente Lite, Counsel Fees and Expenses in the above-captioned divorce action. Respectfully submitted, JAMES, SMITH, DIETTERICK & CONNELLY, LLP Dated: September /5, 2005 By: Attorneys for Defendant () C ?:. ""'r~' g~s':' Zl wJ< ~.~: ~c ~c\ ~L )>c: -:;..>'. ~ ...., = = en <.n ...., -0 ~ :r1 ." n- h1 :g9 l)6 :.:i-T1 _J_--n 90 t.;:;:-,m ,~ :r;! ~ CT\ "" :x N .. U1 \D WILLIAM P. CONRAD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 02 - 4216 CIVIL KAREN CONRAD, Defendant IN DIVORCE ORDER OF COURT AND NOW, this 1'^ 020 day Of~~' ./ 2005, the economic claims raised in the proceedings having been resolved in accordance with a property settlement agreement dated September 7, 2005, the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. BY THE COURT, Ge cc: .,.z1izabeth S. Beckley Attorney for Plaintiff vd6hn J. Connelly, Jr. Attorney for Defendant "rf; O~'d\ ~ v- o Vi% C} ''t'-~ .~o (>~ ()- ~\.~ tr.~ '5 -g g. !i ~ ~ (fl ~ ~ -r \:' ~l~ ',.t;:::;' 'i\:,t.: '5 u PROPERTY SETTLEMENT AGREEMENT . h _ C.,Li. This is a Property Settlement Agreement entered into this L day o~/ 2005, by and between WILLIAM P. CONRAD, of Enola, Pennsylvania (hereinafter referred to as "Husband"), ( " ---> and r..'-.c- KAREN CONRAD, of Enola, Pennsylvania (hereinafter referred to as "Wife"), ....;::.. WITNESSETH: (,."' WHEREAS, Husband and Wife were lawfully married on February 15;(19~Z; .....; ., and; WHEREAS, the parties are the parents of four minor children: Katelyn Conrad born April 28, 1991, Nathan P. Conrad born February 14, 1993, Spencer N. Conrad born May 20, 1994 and Natalie I. Conrad born September 28,2000; and WHEREAS, unhappy differences have arisen between Husband and Wife in consequence of which they are now living separate and apart from each other; and WHEREAS, Husband and Wife are now in the process of obtaining a divorce, and, consequently, they desire to settle and determine finally and for all time both their respective financial and property rights, including any and all claims which either of them may have against the other. NOW THEREFORE, in consideration of this Property Settlement Agreement, and of the mutual promises, covenants and undertakings set forth herein, and incorporating the above "WHEREAS" clauses herein by reference, the parties hereto, each intending to be legally bound, hereby agree as follows: 1. SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place as he or she may from time to time choose or deem fit. The foregoing provisions shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of the causes leading to their living apart. 2. INTERFERENCE: Each party shall be free from interference, authority and contact by the other, as fully as ifhe 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 or 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 other's peaceful existence, separate and apart from the other. 3. WIFE'S DEBTS: Wife represents and warrants to Husband that since the separation she has not and in the future she will not contract or incur any debt or liability for which Husband or his estate might be responsible, and that she shall indemnify and save harmless Husband from any and all claims or demands incurred by her. 4. HUSBAND'S DEBTS: Husband represents and warrants to Wife that since the separation he has not and in the future he will not contract or incur any debt or liability for which Wife or her estate might be responsible, and that he shall indemnify and save harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. 5. OUTSTANDING JOINT DEBTS: All debts, obligations or liabilities incurred at any time in the past by either of the parties will be paid promptly by the party which incurred such debt, obligation or liability, unless except as otherwise specifically set forth in this Agreement. Each of the parties hereto further promises, covenants and agrees that each will now and at all times hereafter save harmless and keep the other or 2 his or her estate indemnified and saved harmless from all debts or liabilities incurred by him or her, as the case may be, and from all actions, claims and demands whatsoever with respect thereto, and from all costs, legal or otherwise, and counsel fees whatsoever appertaining to such actions, claims and demands. Neither party shall, after the date ofthis Agreement, contract or incur any debt or liability for which the other or his or her property might be responsible, and shall indemnifY and save harmless the other from any and all claims or demands made against her or him by reason of debts or obligations incurred by her or him, and from all costs, legal costs and counsel fees incurred in connection therewith unless provided to the contrary herein. Wife agrees to be solely and separately responsible for all debts which have arisen or which may in the future arise from her Kohl's creditcard, and Wife agrees to indemnifY and save harmless Husband from any and all claims or demands made against him by reason of such debt or obligation and from all costs, legal costs and counsel fees incurred by Husband in connection therewith. 6. BANK ACCOUNTS AND RETIREMENT ACCOUNTS: Husband and Wife are owners of individual savings, checking and pension accounts at various institutions including Husband's pension with the United States Railroad Retirement Board. Husband hereby releases all claims in and to all accounts in the name of Wife, and Wife hereby releases all claims in and to all accounts in the name of Husband including his pension with the United States Railroad Retirement Board, and each party shall retain as his or her separate property each account currently titled to that party. Husband and Wife agree to sign, upon request and after execution of this Agreement, any titles or any other documents reasonably necessary to give effect to this Section. 3 7. HUSBAND'S RELEASE: Husband does hereby release, remise, quitclaim, and forever discharge Wife and the Estate of Wife from any and all claims that he now has or may hereafter have against Wife, or in, to, or against her Estate or any part thereof, whether arising out of any former contracts, agreements, engagements, or liabilities of Wife, or by way of dower or claim in the nature of dower, spouse's right or under any intestate laws or the right to take against Wife's Will, or for equitable distribution, support, alimony, alimony pendente lite, or maintenance of any other nature whatsoever, excepting only those rights accruing to Husband under this Postnuptial Agreement. 8. WIFE'S RELEASE: Wife does hereby release, remise, quitclaim, and forever discharge Husband and the Estate of Husband from any and all claims that she now has or may hereafter have against Husband, or in, to, or against his Estate or any part thereof, whether arising out of any former contracts, agreements, engagements, or liabilities of Husband, or by way of dower or claim in the nature of dower, spouse's right or under any intestate laws or the right to take against Husband's Will, or for equitable distribution, support, alimony, alimony pendente lite, or maintenance of any other nature whatsoever, excepting only those rights accruing to Wife under this Postnuptial Agreement. 9. MUTUAL INDEMNIFICATION: Each party represents that no debts, liabilities, or obligations have been incurred or contracted for for which the other party or the Estate of the other party may be responsible or liable, except those specifically identified in this Agreement. Each party hereto shall hereafter keep the other and his or her heirs and personal representatives indemnified and saved harmless against and from all debts and liabilities contracted for or incurred by or on behalf of the indemnifYing party, and against and from 4 all actions, proceedings, claims, demands, costs, attorneys' fees and expenses incurred in respect to any such debts or liabilities, excepting, however, obligations of the parties hereto to each other under this Agreement. 10. DIVISION OF REAL PROPERTY: Husband and Wife did own jointly the marital residence, situated at 73 Greenmont Drive, Cumberland County, Pennsylvania. Husband and Wife sold the marital residence and currently have approximately $22,269.32 in Beckley & Madden's Escrow Account. Husband and Wife agree that Wife will receive this money and any interest earned thereon as Wife's share of the equitable distribution of the parties' assets at the time of execution of this agreement. 11. DIVISION OF PERSONAL PROPERTY: The parties have divided between them, to their mutual satisfaction, their personal property and the personal effects, household furniture and furnishings, and all other articles of personal property which have theretofore been used by them in common, and neither party will make any claim to any items of personal property which are now in the possession or under the control of the other. Should it become necessary, the parties each agree to sign any titles or documents necessary to give effect to this paragraph upon request. ]2. AUTOMOBILES: Husband and Wife agree that Wife shall be the sole and separate owner of the 1993 Grand Am. Wife agrees to assume all responsibility for any outstanding debt balance on the vehicle, indemnifying and holding Husband harmless from any financial responsibility arising from nonpayment thereon. Husband and Wife agree to execute any and all instruments and documents necessary in order to effectuate the transfer of title to said automobile. 5 13. INCOME TAX: The parties have filed joint federal, state and local tax returns up to and including 2003. Both parties agree that, in the event any deficiency in federal, state or local income tax is proposed or any assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns. Should it be determined that neither party is at fault for any of the foregoing, the parties agree that they will be equally responsible for payment of any tax, interest, penalty or expense which is determined to be due and owmg. 14. LIFE INSURANCE POLICIES: Husband and Wife agree to waive any and all claims and relinquish all rights and interest they may have in any and all life insurance policies ofthe other. 15. COUNSEL FEES: Husband and Wife agree to be solely and separately responsible for his/her own counsel fees. 16. BREACH: If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, to sue for specific performance, and to seek such other remedies or relief as may be available to him or her, and the party breaching this contract shall be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement. 6 17. ADDITIONAL INSTRUMENTS: 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 that may be reasonably required to give full force and effect to the provisions of this Agreement. 18. VOLUNTARY EXECUTION: Wife has employed and had the benefit of counsel from John J. Connelly, Jr., Esquire, as her attorney. Husband has employed and had the benefit of counsel from Elizabeth S. Beckley, Esquire as his attorney. Each party acknowledges that he or she fully understands the facts and has been fully informed as to his or her legal rights and obligations, and each party acknowledges and accepts that this Agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and/or with such knowledge as each party desires, and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. Also, each party hereto acknowledges that under the Pennsylvania Divorce Reform Act, the Court has the right and duty to detennine all marital rights of the parties, including divorce, alimony, alimony pendente lite, equitable distribution of all marital property or property owned or possessed individua\1y by the other, counsel fees and costs oflitigation and, fully knowing the same and being advised of his or her rights thereunder, each party hereto still desires to execute this Agreement, acknowledging that the terms and conditions set forth herein are fair, just, and equitable to each of the parties, and each party waives their respective right to have the Court of Common Pleas or any Court of competent jurisdiction make any determination or order affecting the respective parties' right to a alimony, alimony pendente lite, equitable distribution of all marital property, counsel fees and costs of litigation. 7 19. ENTIRE AGREEMENT: This Agreement contains the entire understanding of the parties, and there are no representations, warranties, covenants, or undertakings other than those expressly set forth herein. This Agreement shall be binding upon the parties hereto, and there respective heirs, executors, administrators and assigns. 20. MODIFICATION AND WAIVER: A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed by both parties with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 21. SEVERABILITY: If any provision of this Agreement is held by a court of competent jurisdiction to be void, invalid or unenforceable, the remaining provisions hereof shall nevertheless survive and continue in full force and effect without being impaired or invalidated in any way. 22. DATE OF EXECUTION/EFFECTIVE DATE: The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which the parties signed the Agreement if they did so on the same date, or if not on the same date, then the date on which the Agreement was signed by the last party to execute this Agreement. This Agreement shall become effective and binding upon both parties on the execution date. 23. DESCRIPTIVE HEADINGS: The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 8 IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above-written. / !. ,/}j~!(.tJ 1;7 IJ ; (/ ~'L l!t~ William P. Conrad /_.--/" \ .~. . . '-.C~. ,-"]','\ .,. . -----..~.-.--" '. -' J,ohn J. Connel1y, Jr., ESq~ir~ \ '. , ../' U".uU\jl n"--,~ Karel\. Conrad COUNTY OF J.. .-1 ," ) ) SS.: ) COMMONWEALTH OF PENNSYL VANIA On this the ~ day of J,.j,J:w...! _ I , 2005, before me, the undersigned officer, personally appeared William P. Conrad, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. - . , . .0'>' A';Z:A.<.--L-(SEAL) Notary Public My Commission Expires: NOTARIAL SEAL GERALDINE J. SCRBACIC, Notary Public City of Harrisburg, Dauphin County My Commission Expires Nov. 20, 2006 9 ~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF .:~"C' G. "J',i r\ 'j" I ) ) SS.: ) . IIJil/1 . :.f On thIS the~",0! , day of. "(l <. , 200S, before me, the undersigned officer, personally appeared Karen Conrad, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. r '- . iit:~1"-".1 c, (SEAL) Notary Public My Commission Expires: COMMON\"IEAL1'H. OF PENNSYLVANIA NOTAAW. MICHELLe EI.l.IOTT NOTARY PVBLIC DEFtitv TOWNSHII' IlI\UPtIIN co\)lffi' MY COMIIIISSION EXPIRES JUNE 9, 2007 10