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Home My WebLink About02-4340 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 KATHLEEN A. JERIOSKl-YORN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 0;) ~4JL{O Gu~C/~ RICHARD K. YORN, Defendant CIVIL ACTION - LAW 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 and visitation of your children. When the grounds for a divorce is indignities or irretrievable breakdown ofthe marriage, you may request marriage counseling. A list of marriage counselors is available in the Domestic Relations Office at the County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE Carlisle, Pennsylvania 17013 (717) 249-3166 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 KATHLEEN A. JERIOSKI-YOHN, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA C;u~l~~ v. NO. C:.l-"IN6 RICHARD K. YOHN, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE I. Plaintiff is Kathleen A. Jerioski-Yohn, an adult individual residing at 33 Wobum Abbey Avenue, Camp Hill, Cumberland County, Pennsylvania 1701 I. 2. Defendant is Richard K. Yohn, an adult individual with a mailing address of P.O. Box 108, Summerdale, Cumberland County, Pennsylvania 17093. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months prior to filing this complaint. 4. The Plaintiff and Defendant were married on August 29, 1986 in Erie, Pennsylvania. 5. There is one minor child born ofthis marriage, being KaitIyn Elizabeth Yohn, bom August 19, 1987. 6. The parties separated on February 7, 2002. 7. There have been no prior actions for divorce or annulment between the parties. 8. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 9. Plaintiff has been advised that counseling is available and that Plaintiff has the right to request that the court require the parties to participate in counseling. COUNT I - DIVORCE NO FAULT 10. The averments in paragraphs I through 9, inclusive, of Plaintiff's Complaint are incorporated herein by reference thereto. II. The marriage is irretrievably broken and no possibility of reconciliation exists. INDIGNITIES 12. The averments in paragraphs I through 11, inclusive of Plaintiff's Complaint are incorporated herein by reference thereto. 13. Plaintiffis the innocent and injured party, and Defendant has offered such indignities to the person of the Plaintiff and has been mentally cruel to her so as to make her life burdensome 2 and her condition intolerable, including but not limited to abandoning the marital home, in violation of the marriage vows and of the laws of the Commonwealth. WHEREFORE, Plaintiff requests this Court to enter a decree in divorce in accordance with the Pennsylvania Divorce Code. COUNT II EOUlTABLE DISTRIBUTION 14. The averments in paragraphs 1 through 13 of Plaintiff's Complaint are incorporated herein by reference thereto. 15. The Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties in such proportion as the Court deems just after consideration of all relevant factors. WHEREFORE, Plaintiff requests this Court to equitably divide said property in accordance with Section 401(d) of the Pennsylvania Divorce Code. COUNT III SUPPORT, ALIMONY PENDENTE LITE AND ALIMONY 16. The averments in paragraphs 1 through 15, inclusive, of Plaintiff's Complaint are incorporated herein by reference thereto. 17. Plaintiff requires reasonable support to adequately sustain herself with the standard of 3 living established during the marriage. WHEREFORE, Plaintiff requests an award of Support, Alimony and Alimony Pendente Lite. COUNT IV ATTORNEY'S FEES AND COSTS 18. The averments in paragraphs 1 through 17, inclusive, of Plaintiff's Complaint are incorporated herein by reference thereto. 19. Plaintiff is unable to sustain herself during the course of this litigation and has employed Barbara Sump Ie-Sullivan, Esquire as counsel, but is unable to pay the necessary and reasonable attorney's fees for said counsel, and the necessary and reasonable costs and expenses. WHEREFORE, Plaintiff requests an award of counsel's fees and expenses. WHEREFORE, Plaintiff, Kathleen A. Jerioski-Yohn, prays this Honorable Court to enter judgment: A. Awarding Plaintiff a decree in divorce; B. Awarding Plaintiff support, alimony and alimony pendente lite; C. Awarding Plaintiff counsel fees, costs and expenses; 4 Dated: D. Equitably distributing the marital property; and E. A warding other relief as the Court deems just an ar ara Sumple-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, P A 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 5 Barbara Sump Ie-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 KATHLEEN A. JERIOSKI-YOHN, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. RICHARD K. YOHN, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT REGARDING COUNSELING I. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not require that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A Section 4904 relating to unsworn falsification to authorities. Dated: 8 J3/ /O:J-.. I ~p~shffpV thleen A. J . ski-Yohn Barbara Sump Ie-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 KATHLEEN A. JERIOSKl-YOHN, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. RICHARD K. YOHN, Defendant CIVIL ACTION - LAW IN DIVORCE VERIFICATION I, Kathleen A. Jerioski- Y ohn, hereby certify that the facts set forth in the foregoing COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Dated: '6.&,/!Jc?-- dit#d~~'fr. K hleen A, Jer' - ohn (J ~ (0 ~ ~ ~ ~ (') 0 () #- "\ll c f',) --'"1 G ") l1( , '/) ~;;:.1; '.q 2 8 ) r:.1 .~ ;' ,- "'U '- Q'- ~,;: ,'-' .\} 0 ~::.; C, , I r!: ..() ....... (y > ~ ~ W ;:'.) , ..0 :,;1 ~ b !'- ~l:i ~ en -< t -f-.-. '--(, ~ ~ Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 KATHLEEN A. JERIOSKl-YOHN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUJ\ITY, PENNSYLVANIA v. : NO. 02-4340 RICHARD K. YOHN, Defendant CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I, Nora F. Blair, Esquire, hereby accept service and acknowledge receipt of the above-captioned Complaint in Divorce on behalf of my client, Richard K. Y ohn, having received said Complaint on the 2.It!- day of 5:~t/. ~ '-' ,2002. I hereby indicate lam authorized by my clientto accept service on his behalf. . Blair, Esqu e .0. x 6216 Harrisburg, P A 17112-0216 Telephone (717) 541-1428 Supreme Court I.D. No. C) ce. C: .....0 2" ~)(< [\)I2-' _.~" (j;oJ \D ~~~ ,L ->r, > t:'~' ,~,) .1.:<... en =< (:; KATHLEEN A JERIOSKI- YOHN, Plaintiff : IN THE. COUHT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-4340 v. : CIVll.. ACTION - DIVORCE RICHARD K YOHN, Defendant 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 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, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO Nor 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 LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNor AFFORD ONE, GO TO OR ~T .'F.PHONE THE OFFICE SET FORTH BELOW'IU FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Assoeiation 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 KATHLEEN A JERIOSKI- YOHN, Plaintiff : IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-4340 v. : CIVIL ACTION - DIVORCE RICHARD K YOHN, Defendant ANSWER TO DIVORCE CC)MPLAINT AND COUNTERCLAIM FO,R CUSTODY And now comes Richard K Yohn and by and through his attorney, Nora F. Blair, Esquire files this Answer to Divorce Complaint and Counterclaim for Custody and in support thereof avers as follows: 1. Admitted. 2. Admitted. By way of further response, Defendant's residence is at 3614 Kohler Place, Apartment 2, Camp Hill, Pennsylvania. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. Admitted. 9. Defendant is not aware of what advise Plaintiff may or may not have been given. by way of further response, Defendant has been advised of his right to request that the Court require the parties to p.articipate in counseling and Defendant waives that right. COUNT I - DIVORCE NO FAULT 10. The prior paragraphs of this pleading and of the Complaint in Divorce are incorporated herein by reference thereto. 11. Admitted. INDIGNITlliS 12. The prior paragraphs of this pleading and of the Complaint in Divorce are incorporated herein by reference thereto. 13. Denied. It is specifically denied that plaintiff is the innocent and injured spouse or that Defendant has offered such indignities to the person of Plaintiff and has been mentally cruel to her so as to make her life burdensome and her condition intolerable or that Defendant violated his marriage vows by leaving the marital residence. To the contrary, Plaintiff through her conduct and treatment of Defendant as the gardener, the pool maintenance person, the handyman and anything else other than a husband and a father has made Defendant's life burdensome and his life intolerable. Further Plaintiff abandoned the marriage many years ago. When Defendant left the marital residence:. there was no marriage to abandon. WHEREFORE, Defendant respectfully requests that Your Honorable Court enter a divorce pursuant to 3301(c) or 3301(d). COUNT II EQUITABLE DISTRIBUTION 14. The prior paragraphs of this pleading and of the Complaint in Divorce are incorporated herein by reference thereto. 15. Defendant requests that the marital property be equitably divided, distributed or assigned between the parties. WHEREFORE, Defendant respectfully requests that Your Honorable Court enter an Order equitably distributing the marital property pursuant to Section 3502 of the Divorce Code. COUNT III SUPPORT, ALIMONY PENDENTE LI'rE AND ALIMONY 16. The prior paragraphs of this pleading and of the Complaint in Divorce are incorporated herein by reference thereto. 17. Denied. It is specifically denied that Plaintiff requires reasonable support to adequately sustain herself with the standard of living established during the marriage. To the contrary, Plaintiffs earning capacity is higherthan that of Defendant. The life style established by the parties was based on Plaintiffs higher earnings. WHEREFORE, Defendant respectfully requests that Your Honorable Court deny Plaintiffs request for support, alimony pendente lite and alimony. COUNT IV A'ITORNEY'S FEES AND COSTS 18. The prior paragraphs of this pleading and of the Complaint in Divorce are incorporated herein by reference thereto. 19. Denied. It is specifically denied that Plaintiff is unable to sustain herself during the course of litigation and is unable to pay the necessary and reasonable attorney's fees and costs and expenses. To the contrary, Plaintiff is working at far below her earning capacity and could provide for all of her own expenses if she were employed at her earning capacity or worked twelve months out of the year. WHEREFORE, Defendant respectfully request.s that Your Honorable Court deny Plaintiffs request for attorney's fees and costs. COUNT V CUSTODY OF MINOR C:mT .n 20. The prior paragraphs of this pleading and of t.he Complaint in Divorce are incorporated herein by reference thereto. 21. The parties are the parents of one child, Kaitlyn Elizabeth Y ohn, born August 19, 1987. 22. The parties have been unable to agree upon the best interest of the child with respect to custody, partial custody and visitation. Defendant has not had any opportunities to visit with the minor child since Defendant moved out of the marital residence. 23. The child is presently in the custody of Kathleen A. Jerioski-Yohn. 24. During the last five years, the minor child has resided with the following persons and at the following addresses: NAMES ADDRESSES DATES Mother Father (until 2-8-02) 33 Wobum Abbey Avenue Camp Hill, PA 1994 to present 25. Defendant has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of this minor child in this or another court. 26. Defendant has no information of a custody proceeding concerning this minor child pending in a court of this Commonwealth or in another state or commonwealth. 27. Defendant does not know of a person not a party to the proceedings who has physical custody of the minor child or claims to have custody or visitatiotr rights with respect to the minor child. 28. Each parent whose parental rights to the minor child have not been terminated and the person who has physical custody of the minor child have been named as parties to this action. 29. Defendant believes and therefore avers that it is the best interest of the minor child for him to have reasonable periods of partial physical custody of the minor child. WHEREFORE, Defendant respectfully requests that Your Honorable Court enter an Order granting him reasonable periods of partial physical custody and shared legal custody of the parties' minor child. DATED: C ~ t? ..~ I It" 2()()7-- h)/--f~ I Respect~lly submitt ;- l/ __~ . ~~) ./ L---? ~ - or F. Blair Supreme Court ID #45513 5440 Jonestown Road Post Office Box 6216 Harrisburg, PA 17112-0216 (717) 541-1428 VERIFICATION I verify that the statement made .in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that the statements therein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. ~jk 1- KATHLEEN A JERIOSKI- YOHN, Plaintiff : IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-4340 v. : CIVIL ACTION - DIVORCE RICHARD K YOHN, Defendant CERTIFICATE OF SE:RVICE I hereby certify that I have this date served a copy of the Answer to Divorce Complaint and Counterclaim for Custody on the person in the manner stated below which service satisfies the requirement ofPa.R.C.P. No. 440. SERVICE BY FIRST CLASS MAIL TO: Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 Date: I 2 - I '7 ' 0 :l ~~ ~ ~ ~ ~ (j ~ fi o 0- o C' ,<;P l.'l:t igj ~~' ~ ~~~ (-., !:"" ('-, P' C "7' ~ ~e 11- bJ ~ C:l T. " ..... C) "j, ~-,l o ,-"1 c"'"} 0) i'..) ...~~ ') ~D KATHLEEN A. JERIOSKI-YOHN PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 02-4340 CIVIL ACTION LAW RICHARD K. YOHN DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, December 23, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before _ Dawn S. Sunday, Esq. at 39 West Main Street, Mechanicsburg, P A 17055 on Thursday, January 16, 2003 , the conciliator, at 1:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Dawn S. Sunday, Esq. ~ Custody Conciliator I The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court, You must attend the scheduled conference or hearing, YOU SHOULD TAKE THIS PAPER TO YOUR ATIORNIN AT ONCE. IF YOU DO NOT HAVE AN ATIORNEY 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 Telephone (717) 249-3166 I ~~ ~ -? ~ ~ '(',;1- (l['-ef ~ ~ fP ~ ~?!P/4 i0cJE"-r:! - ~ P;Z ~ ~ -T'l ~(1.(1E-e! 'IINV/'ilASNN3d AlNnaJ ON\f1H:?8Vvno is :8 Hd Of; J30 GO AU\.IIC)t,!ty"":;' ( ,"...; -f('J OYJ.., I '~~.! '..:..'1.-...'....1_.. -.l 3JI:!;I('-031i.j KATHLEEN A. JERlOSKI -YOHN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLMfD COUNTY, PENNSYLVANIA vs. 02-4340 CNIL ACTION LAW RICHARD K.YOHN Defendant IN CUSTODY ORDER OF COURT AND NOW, this ~ day of ~?J)'-' 2.)1 ' 2003, upon consideration ofthe attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Kathleen Jerioski-YoOO, shall have primary physical custody of Kaitlyn Elizabeth YoOO, born August 19, 1987. 2. The Father, Richard K. Y 000, shall have periods of custody with the Child as arranged by agreement of the parties. 3. The parties and their counsel shall attend a second custody conciliation conference in the office of the conciliator, Dawn Sunday, on Thursday, March 20,2003 at 3:00 pm. The purpose of the conference shall be to review the ongoing partial custody arrangements. BY THE COURT, J. cc: Barbara Sumple-Sullivan, Esquire, Counsel for Mother Nora F. Blair, Esquire,Counsel for Father - .A.~ ,~ 1_ 30, 03 ~ \fIN'iA?ASNN3d I It."nn:; f\'1~'i\-Il.ll-Pp."\'n" .l\..LP. ~"'" "'. -'h, ,...r If V ru :8 ~!d DE; Nvr 80 )\!:JVIOifC, ';.J:,.,... 3~)Jj'~}(J-C;',:.j "'}/ j -In -v KATHLEEN A. JERlOSKI-YOHN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 02-4340 CIVIL ACTION LAW RICHARD K.YOHN Defendant IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kaitlyn Elizabeth Y 000 August 19, 1987 Mother 2. A Conciliation Conference was held on January 20,2003, with the following individuals in attendance: The Mother, Kathleen A. Jerioski-YoOO, with her counsel, Barbara Sumple-Sullivan, Esquire, and the Father, Richard K. YoOO, with his counsel, Nora F. Blair. 3. The parties agreed to entry of an Order in the form as attached. ()(~ d-l, ;;.003 ~,J..-~ Dawn S. Sunday, Esquire Custody Conciliator Date MAY 2 3 Z003 r KATHLEEN A. JERIOSKI -YOHN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 02-4340 CIVIL ACTION LAW RICHARD K.YOHN Defendant IN CUSTODY ORDER AND NOW, this 20th day of Mav 2003 , the conciliator, being advised by counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction. The Custody Conciliation Conference scheduled for June 12,2003, is cancelled, FOR THE COURT, 61.--~- Dawn S. Sunday, Esquire Custody Conciliator v\N'V!\"V.SNN3d }J.Nf'\OC) e.)\;'j'li13t1\~nO 9 \ :f, \\.1 82 ^~~ SO ^'tNl.C)\'iC,-.j)";:j jO 3'JUY::JUJ\d HI THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHLEEN A. JERIOSKI-YORN Plaintiff vs. RICHARD K. YORN NO. 4340 .n "i~2002 MOTION Kathleen A. Jerioski-Yolui a master with respecC to che (X) Divorce ( ) Annulment ( X) Alimony ( X) Alimony Pendente FOR APPOINTMENT OF MASTER (Plainciif) (~), following claims: moves the court to appoint Lice ( X) ( X) ( X) ( X) Distribution of Property Support Counsel Fees Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claims(s) for which the appointment of a master is requested. (2) The defendant (has) ~) appeared in (by his attorney, Nora F. Blair. (3) The staturory ground(s) for divorce (~) 3301 (d) 3301 (e) the action ~y) ,Esquire) . (are) 3301 (a) (6), (4) Delete the inapplicable paragraph(s): (a) The action is not contested. (b) An agreement has been reached with respect to the following claims: (~) The action is ~ontested with resp~ct to the follow~g claims: Equitable DistriJoution, Support, Alimony, APL, Couns~l Fees, Costs ana txpense s, (5) The action (~) (does not involve cOm?lex issues of law Date: ~ /;("Ic) (Plain tiff) ~ ORDER APPOINTING" TER Barbara Sumple-Sullivan, Esquire ~ (days). otion: None. or fact:. (6) The hearing is expected to (7) Additional info~tion, if AND NOW ,19 , is appointed master with respect t'Othe following claims: Esquire, By the Court: J --d ~ Q. ~~ (1 'rr' :bt"? {).b ';;::J ::~;~ (~~\ y ~ '21, '3' ceu :;;,;~ - ....1 (~-. :~ ..4. \,,' .' r:- :r. 'vJY' 111 TIiB COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHLEEN A. JERIOSKI-YOHN Plaintiff vs. RICHARD K. YOHN NO. 4340 . i~200Z'. MOTION Kathleen A. Jerioski-Yohri a master with respect to the ( X ) Divorce ( ) Annulment ( X) Alimony (X) Alimony Pendente Lite FOR APPOINTI1ENT OF MASTER (Plaintiff) (~), following claims: moves the court to appoint ( X) ( X) ( X) ( X) Distribution of Property Support Counsel Fees Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claims(s) for which the appointment of a master is requested. (2) The defendant (has) :XilaaxmUc) appeared in (by his attorney, Nora F. Blair. (3) The staturory ground(s) for divorce (~) 3301 (d) 3301 (el the action~y) ,Esquire) . (are) 3301 (a) (6), (4) Delete the inapplicable paragraph(s): (a) The action is not contested. (b) An agreement has been reached with respect to the following claims: (c) The action is contested with resp~ct to the following claims: Equitable DistrilDution, support, Alirrony, APL, Counsel Fees, Costs ancI EXPeJlSe s. (5) The action (~) (does not involve complex issues of law (6) (7) The hearing is expected Additional information, or fact. Date: ~ IJ/,,!c ) ey for (Plaintiff) ~ ORDER APPOINTING ~ STER Barbara Sumple-SUllivan, Esquire AND NOW ~/J( 0 ,.2 I) ,..9 ~,..s ;::: h-kh r ~ ~ A ~< ' Esquire, is appointed ma er with respect to the following claims: Q( 4.~Q~ 'y "~ ~J ~~\ L\) : \ \ \.\'\l (l'Z ~\\(' l)~~1. H:\';i.O;.\0r'1LCidd?~ -!:-O - 3':)\:100-03\\:1 ~ ~ 'e. -;;::::,. - -' ""'" ::;:. ~ ~ S;. '''~. q. ~ ",'e #ofD "?~ -...'"'1 , ._.."f\ ("/-" "'.'~ ..1 . :0 ::-\ ~ - .ll:/U\>/ZUU\> 1;'5:0;'5 "AX 7174320426 The Wiley Group IN THE, COURT OF COMMON PLEAS CUMBERI,AND COUNTY, PENNSYLVANIA III 003/003 KATHLEF'I A. .mRJOSKI-YOHN, Plaintiff vs. RICHARD K. YOHN, Defendant . . NO. 02-4340 CIVIL TERM . . * Civil Action - Law to Divorce . . WITHDRA W.AL AND ENTRY OF APPEARANCE TO THE PROTHONOTARY OF SAID COURT, PU' \SE withdraw my appearance as attorney of record for the Defendant, RlCHARD K YOHN. at the ahove-cal tiolled docket Dated . L2=_'S-=_ u:{' PU ASE enter my appcaraoc.e as a!tomey ofreeord for the Delendallt, RICHARD K YOHN. at the abovc--eapti( 1Cd docket Dated.....l..a.J.y /o~___ Rcspcctfijlly submItted hy Bradley 1'\. W. IUliek Esquire 1D#7 13 WILEY, ,NOX, COLGAN & MARZZACCO, PC I}O W Church Street Dillsburg, PAl '10 19 (717)432-9(,(,(; i'- '. ~ Barbara Sump1e-Sullivan, Esquire Supreme Court # 32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 KATHLEEN A. JERIOSKI-YOHN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 02-4340 RICHARD K. YOHN, Defendant : CIVIL ACTION-LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 10, 2002. 2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days have elapsed since the filing and service of the Complaint. 3. I consent to the entry ofa fmal decree of divorce after service of notice of intention to request entry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unswom falsification to authorities. DATE: (p/'ii;J()((J c.W~~~~ '''""(J \ " , o ~; '::3, '~ d' (.,.,~. <-::;: ~,,,- t.n S1~ -I -:t -l'l h1c: -cr:t\ .':),,'" i,i~< '..j., :.;:~)y). .::::...-;. ,e. ::< 5: CO w c' Barbara Sumple-Sullivan, Esquire Supreme Court # 32317 549 Bridge Street New Cumberland, PA 17070 (717)774-1445 KATHLEEN A. JERIOSKI-YORN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 02-4340 RICHARD K. YORN, Defendant CIVIL ACTION-LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~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 concerning 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 statement herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. DATE: It / '6 !O(P , . ~~a~~ THLEEN- JERIOSKI HN Q C,"", "..:> c.:; ~-. ~ .-\ -r:.-r\ l:'nc:, -=?!C') ..- c.J~ ;..;;' > Yl>,. :::;~ c/.'? uJ c' Barbara Sump1e-Sullivan, Esquire Supreme Court # 32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 KATHLEEN A. JERIOSKI-YORN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. : No. 02-4340 RICHARD K. YORN, Defendant CIVIL ACTION-LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 10, 2002. 2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days have elapsed since the 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. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unswom falsification to authorities. DATE: tlf/t'C' I K;;Jd ~ RICHARD K. YO "-' 1...-.:.1 .;:~..::> -n :j~ ~ -,..,.' ..-,-~ en Ct? c'c' c~:.. Barbara Sump Ie-Sullivan, Esquire Supreme Court # 32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 KATHLEEN A. JERIOSKI-YOHN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 02-4340 RICHARD K. YOHN, Defendant : CIVIL ACTION-LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 93301(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 concerning 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 statement herein are made subject to the penalties of 18 Pa.C.S. ~904 relating to unsworn falsification to authorities. DATE: C/ydt: ( , ~~t:~ RICHARD K. YOHN 0 "'" (J C'.o c: c--=:> -n ..:;- c~ (J"l ~ co w C> KATHLEEN A. JERIOSKI-YOHN,: Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 02 - 4340 CIVIL RICHARD K. YOHN, Defendant IN DIVORCE ORDER OF COURT 2006, the (5'dv ~ AND NOW, this day of , economic claims raised in the proceed ngs havlng been resolved in accordance with a marital settlement agreement dated June 8, 2006, 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, Q~~ Edgar B. Bayley, P,J. cc: ~arbara Sumple-Sullivan Attorney for Plaintiff ..{ Dip \ij 6w ~radley A. Winnick Attorney for Defendant (') ,..., (') C? c; .c::r '~n ,;:;".,.. , (.n :Z;.? ~:;".. - 0 "0 r "< .J MARITAL SETTI.EMENT AGREEMENT g~" S MARITAL SETILEMENT AGREEMENT, made this day of 2006, by and between KATHLEEN A. JERIOSKI-YOHN, of Camp Hill, County, Pennsylvania (hereinafter referred to as "WIFE"), and RICHARD K. YOHN, of New Cumberland, Cumberland County, Pennsylvania (hereinafter referred to as "HUSBAND"): WITNESSETH: WHEREAS, the parties were married on August 29, 1986, in Erie, Pennsylvania; WHEREAS, HUSBAND and WIFE are the parents of one (1) adult child: Kaitlyn Elizabeth YoM, born on August 19,1987; WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of WIFE and HUSBAND to live separate and apart, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation by specification: the settling of all matters between them in relation to the ownership and equitable distribution of real and personal property; settling of all matters between them relating to the past, present and future support, alimony and/or maintenance of WIFE by HUSBAND or of HUSBAND by WIFE; settling of custody matters and in general, the settling of any and all claims and possible claims by either party against the estate of the other party. NOW, THEREFORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE, each intending to be legally bound hereby covenant and agree as follows: 1. INTERFERENCE: Each party shall be free from interference, authority, and contact by the other, as fully as though he or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfure with the peaceful existence, separate and apart from the other. 2. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS: This Agreement shall not affect or bar the right of HUSBAND or WIFE to a divorce on lawful grounds or to any defense as may be available to either party. This Agreement is not intended to condone and shall not be deemed to be a condonation on the part of either party hereto of any act or acts on the part of the other party which have occasioned the disputes or unhappy differences. 3. SlJBSEOlTENT DIVORCE: The parties hereby acknowledge that WIFE filed a Complaint in Divorce in Cumberland County, Pennsylvania, claiming that the marriage is irretrievably broken under Section 3301(c) of the Pennsylvania Divorce Code. The parties hereby express their agreement that the marriage is irretrievably broken and agree to, simultaneously with the execution of this Agreement, execute any and all Affidavits or other documents necessary for the parties to obtain an absolute divorce pursuant to Section 3301(c) of the Divorce Code. The parties hereby waive all rights to request court ordered counseling under the Divorce Code. It is further specifically understood and agreed by the parties that the provisions of this Agreement as to equitable distribution of property of the parties are accepted by each party as a full and final settlement for all purposes whatsoever, as contemplated by the Pennsylvania Divorce Code. Should a decree, judgment or order of divorce be obtained by either of the parties in this or any other state, country or jurisdiction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be atfected in any way by such separation or divorce; and that nothing in any such decree, judgment, order or further modifica1ion or revision thereof shall alter, amend or vary any term of this Agreement. It is the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties. 4. INCORPORA nON OF DIVORCE DECREli'.: It is further agreed, covenanted and stipulated that this Agreement, or the essential parts hereof, shall be incorporated in any decree hereinafter entered by any court of competent jurisdiction in any divorce proceedings that have been or may be instituted by the parties for the purpose of enforcing the contractual obligations of the parties. This agreement sha1l not be merged in any such decree but sha1l in all respects survive the same and be forever binding and conclusive upon the parties. 5. EFFEC.TIVE DATE: The effective date of this Agreement shall be the "date of ex:ecution" or "execution date," defined as the date upon which it is executed by the parties if they have each executed this Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement sha1l be defined as the date of execution by the party last ex:ecuting this Agreement. 6. DI!ilTRTRTTTION DATES: The transfer of property, funds and/or documents provided for herein, sha1l only take place on the "distribution" dates which shall be specifically prescribed within this Agreement, including spousal support and/or alimony payments. 7. MUTUAL REl.1i'.A.SE: HUSBAND and WIFE each do hereby mutually remise, release, quit-claim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and interest, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situated, which he or she now has or at any time hereafter may have against the other, the estate of such other or any part hereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or curtesy, or claims in the nature of dower or curtesy or widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as a testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania, (b) any State, Commonwealth or territory of the United States, or (c) any country or any rights which either party may have or at any time hereafter sha1l have for past. present or future support or maintenance, alimony, alimony pendente lite, counsel fees, division of property, costs or expenses, whether arising as a result of the marital relations or otherwise, except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provisions thereof. It is the intention of HUSBAND and WIFE to give each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is further agreed that this Agreement shall be and constitute a full and final resolution of any and all claims which each of the parties may have against the other for equitable division of property, alimony, counsel fees and expenses, alimony pendente lite or any other claims pursuant to the Pennsylvania Divorce Code or the divorce laws of any other jurisdiction. 8. REPRESENTATION BY COUNSEl.: WIFE has been represented by Barbara Sumple-SuIlivan, Esquire, and WIFE acknowledges that she has signed this Agreement freely and voluntarily after full consultation with her counsel. HUSBAND has been represented by Bradley A. Winnick, Esquire, and HUSBAND acknowledges that he has signed this Agreement freely and voluntarily after full consultation with his counsel. The parties acknowledge that this Agreement is not the result of any duress, undue intluence, coercion, collusion and/or improper or illegal agreement. The parties further acknowledge that they have each made to the other a full and complete disclosure of their respective assets, estate, liabilities, and sources of income and that they waive any specific enumeration thereof for the purposes of this Agreement. 9. W ARRAN1Y AS TO EXISTING OBUGA TIONS: Each party represents that they have not heretofore incurred or contracted for any debt or liability or obligation for which the estate of the other party may be responsible or liable except as may be provided for in this Agreement. Each party agrees to indemnitY and hold the other party harmless from and against any and all such debts, liabilities or obligations of every kind which may have heretofore been incurred by them, including those for necessities, except for the obligations arising out of this Agreement. 10. WARRANTY AS TO FUTlTRE OBLIGATIONS: HUSBAND and WIFE covenant, warrant, represent and agree that, with the exception of obligations set forth in this Agreement, neither of them shall hereafter incur any liability whatsoever for which the estate of the other may be liable. Each party shall indemnitY and hold harmless the other party from and against any and all debts, charges and liabilities incurred by the other after the execution date of this Agreement, except as may be otherwise specifically provided for by the terms of this Agreement. 11. PERSONAL PROPERTY: Except as otherwise provided herein, the parties have divided between them, to their mutual satisfaction, the personal effects, household furniture and furnishings, and all other articles of personal property which have heretofore been used by them in common, and neither party will make any claim to any such items which are now in the possession or under the control of the other. It is specifica1ly agreed that the parties shall cooperate in selling their various pieces of artwork in accordance with the procedures set forth in ExIn'bit "An. Further, the parties acknowledge that they are the joint owners of a safe deposit box and the contents therein. It is agreed that HUSBAND shall retain possession of: a) 100 Silver Round Coins; b) 1 Platinum Noble Coin; c) 1 Kruggerand; and d) 1 Gold Liberty. All other contents of the safe deposit box shall be retained by WIFE. By these presents, each of the parties hereby specifica1ly waives, releases, renounces and forever abandons whatever claims he or she may have with respect to any personal property which is in the possession of the other, and which shall become the sole and separate property of the other from the date of execution hereof. 12. DWlSION OF MARITAL Rll'SmENc.E: The parties were joint owners of the former marital residence situate at 33 Wobum Abbey Avenue, Camp Hill, Cumberland County, Pennsylvania. The parties acknowledge that this property was sold by them subsequent to their separation, and they agree that the proceeds of said sale have been divided between them to their mutual satisfaction in consideration of the other promises contained herein. 13. PENSIONS. A NNTl'1TIF.S AND/OR RETIREMENT BENEFITS: The parties are the owners of the following retirement accounts: IllJSBAND a) Conrail Employees' Savings Plan; b) AG Edwards IRA Account; c) AG Edwards Roth IRA Account; d) Norfolk Southern Thoroughbred Retirement Account; and e) Tier II Railroad Retirement Defined Benefit Plan. IDEE. a) Catholic Diocese 401(k) Account; b) AG Edwards IRA Account; c) AG Edwards Roth IRA Account; d) State Employees' Retirement System Defined Benefit Plan; JOINT a) AG Edwards IT Ten Account. It is agreed that WIFE shall retain ownership and possession of the jointly held AG Edwards IT Ten Account, and that IllJSBAND shaI1, simultaneously with the execution of this Agreement, execute any documents necessary to transfer ownership accordingly. Upon full disclosure of all of the accounts listed herein, and the values thereot: it is agreed that esch party shall retain possession of all accounts in their individual name, subject to the following: a) IllJSBAND shall cause $46,450.00 from his Conrail Employees' Savings Plan account to be transferred to WIFE via a Qualified Domestic Relations Order (QDRO), with such proceeds to be retained by WIFE. It is also agreed that WIFE shall receive any gains or losses which mayaccme from the effective date of this Agreement to the date of distrtibution. The QDRO shall be submitted to the 401(k) Plan Administrator within thirty (30) days for pre-approval. b) WIFE shall receive 58% of the marital value of IllJSBAND's Tier II Railroad Retirement Benefits via QDRO. The marital value shall be determined by the use of a coverture fraction as defined by 23 Pa. C.S.A ~3501(c)(1); and c) WIFE shall retain her rights as divorced spouse under the Railroad Retirement Act 5t ~ subject to the provisions of said Act. HUSBAND shall be responsible for the preparation ofany QDRO's necessary to give effect to the provisions of this paragraph. 14. BANK ACCOUNTS: HUSBAND and WIFE acknowledge that they do not possess any bank accounts or the like in both of their names. They hereby agree that the proceeds in any marital accoWlts have been divided between them to their mutual satisfaction, each shall become sole owner of their respective accounts and they each hereby waive any interest in, or claim to, any funds held by the other in any accounts. 15. MOmR vn:rrn .ES: It is acknowledged and agreed that HUSBAND retained the Subaru Legacy owned by the parties during their maniage, and that WIFE retained the Buick Century owned by the parties during their marriage. Each party shall retain sole and exclusive possession and ownership of those vehicles as well as any vehicles obtained subsequent to separation in their individual name. Further, each party shall remain solely responsible for any and all payments related to their vehicles, including loans, insurance and maintenance. Hi. AFfER-ACOIJIRED PROPERTY: Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of property, be they real, personal or mixed, tangible or intangible, which are hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes as though he or she were unmanied. 17. 1.ll4'E INSURANCE: HUSBAND is the owner of two (2) whole life insurance policies with Ohio National Life Insurance, and WIFE is the owner of one (I) whole life insurance policy with Ohio National Life Insurance. Each shall retain ownership of their separate policies and shall keep their daughter as beneficiary thereof at least until her thirtieth (30th) birthday. 18. ~T: Effective JulY.l,~06, HUSBAND ~ p~,to WlFE alimony~of f}{..t fin 611 a./ ~ . JJI7J1M. /lJ..ltl.lJiiZJ ~/[f $250.00 per month.1 S paymen( ~ ~ue to e p~f un~e ~er 0 hte following events: 17, ,dJ /\. ~Jf7~ ~~ a) WIFE's cohabitation as that term is defined in the Pennsylvania Divorce Code; b) WIFE's death; c) Kaitlyn's completion of the program she is currently enrolled in at Temple University; or d) The date upon which Kait1yn is currently expected to complete her course of study at Temple University, as descnoed above, assuming she does not discontinue her studies. The alimony prescribed by this paragraph shaI1 not be modifiable, except for the provisions for the termination thereof detailed above. The payments made pursuant to this Paragraph shaI1 be includable as income to WIFE and shall be allowable as a deduction from HUSBAND's income. The parties hereby agree that the foregoing provisions for WIFE's individual benefit are satisfactOl)' with regard to her support and maintenance. The parties release and discharge the other absolutely and forever for the rest of their lives for all claims and demands, past, present or future, for alimony or for any provision for support or maintenance, except as specifically provided for herein. The parties further acknowledge that in consideration of the transfers made herein each completely waives and relinquishes any and all claims and/or demands they may now have or hereafter have against the other for alimony, alimony pendente lite and spousal support, except as specifically provided for herein. 19. INCOME TAX: HUSBAND and WIFE agree to file separate tax returns beginning with the tax year 2005. Both parties agree that in the event any deficiency in F ederai, State or local income tax is proposed, or any assessment of any such tax is made against either of them, each will indemniJY 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. 20. APPL!C'ARrr.ITV OF TAX LAW TO PROPERTY TRANSFER..I;!: The parties hereby agree and express their intent that any transfer of property pursuant to this Agreement shaI1 be within the scope and applicability of the Deficit Reduction Act of 1984 (hereinafter the "Act"), specifically, the provisions of said Act pertaining to the transfers of property between spouses and former spouses. The parties agree to sign and cause to be tiled any elections or other documents required by the Intemal RevemJe Service to render the Act applicable to the transfers set forth in this Agreement without recognition of gain on such transfer and subject to the carry-over basis provisions of said Act. 21. MARITAL DERT: Each party shal1 remain sole and exclusive responsibility for the payment of any and aD debt in his or her individual name. The parties specifically represent that they are aware ofno outstanding debt in the joint names of both parties. To the extent that any such joint debt may exist, said debt shall be assumed by the party to whom request for payment has been sent up to the effective date of this Agreement. The party assuming any such debt shal1 indemnitY and hold the other party hannless against any liability resulting therefrom. 22. EFFECT OF nlVORCE DECRll'.E: The parties agree that, except as otherwise specifically provided herein, this Agreement shal1 continue in full force and effect after such time as a final Decree in Divorce may be entered with respect to the parties. 23. 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 or seek such other remedies or relief as may be available to him or her, and the party breaching this contract shal1 be responsible for payment of reasonable legal fees and costs incurred by the other in enforcing their rights under this Agreement. 24. WAIVER OF CLAIMS: Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she shal1 now have or hereafter acquire, under the present and future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory aDowance, widow's allowance, right to take in intestacy, right to take against the Will of the other, and the right to act as administrator or executor of the other's estate, and each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to cany into effect this mutual waiver and relinquishment of such interests, rights and claims. 25. 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. 26. AGREEMENT BINDING ON RF.lR~: This Agreement shall be binding on and shall inure to the benefits of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 27. ADDmONAL INSTRIJMF.NTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. 28. VOID CLAlTSES: If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. 29. INDEPENDENT SEP AKA TE COVENANTS: It is specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be separate and independent Agreement. 30. FINANCIAl. DISCLOSTTRE: The parties confirm that they have relied on the completeness and substantial accuracy of the finandal disclosure of the other as an inducement to the execution of this Agreement. The parties acknowledge that there has been no fonnal discovery conducted in their pending divorce action and that neither party has filed an inventory and appraisement as required by Section 3505(b) of the Pennsylvania Divorce Code. Notwithstanding the foregoing, the rights of either party to pursue a claim for equitable distribution, pursuant to the Pennsylviwia Divorce Code, of any interest owned by the other party in an asset of any nature at any time prior to the date of execution of this Agreement that was not disclosed to the other party or his or her counsel prior to the date of the within Agreement is expressly reserved. In the event that either party, at any time hereafter, discovers such an undisclosed asset, the party shall have the right to petition the Court of Common Pleas of Cumberland County to make equitable distribution of said asset. The non-disclosing party shall be responsible for payment of counsel fees, costs or expenses incurred by the other party in seeking equitable distribution of said asset. Notwithstanding the foregoing this Agreement shall in all other respects remain in full force and effect. 31. MODIFICATION AND WAIVER: A modification or waiver of any of the provisions of this Agreement shall be effective only ifmade in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent defiwlts of the same or similar nature. 32. DEsnlTPTlVF. IIF.ADINGS: The descriptive he.t1ings used herein are for convenience only. They shall have no affect whatsoever in determining the rights or obligations of the parties. 33. APPLICABU" LAW: This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania and more specifically under the Divorce Code of 1980 and any amendments thereto. EXH1R1T "A" Regarding the artwork: Step One: The parties will place the entire Losch collection, plus any individual artwork in either party's possession acquired during the marriage, on consigmnent to the Heartland Gallery to sell within twenty-four (24) months of consigmnent. HUSBAND will include pre-marital art by George Losch to comoplete the Losch collection and, jfit selIs, will keep the pre-marital value of the pieces. Heartland can consider all offers for either the entire lot, or sub-lots, or individual pieces but, of course, will need to get both of the parties' approvals prior to selling anything. For each sale, the Gallery will divide the proceeds 50150, sending each party a separate check, respectively. WIFE shall be copied on all correspondence to or from Heartland. Mrs. Losch shall be instructed to these specific instructions and ultimate liquidation prior to consignment. Step Two: Any artwork that is still not sold within twenty-four (24) months of consignment wilI be divided equally between the parties by each of the parties selecting pieces alternately. Pre-marital artwork will be considered HUSBAND's property and will not be part of this division process. L___ IN WITNESS WHEREOF, the parties hereto have set their hands and seals the date and year first above written. /iJffJ ~ ) ~r-' 1& {~!< YL RICHARD K. YOHff (SEAL) ~ Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (7]7) 774-1445 KATHLEEN A. JERIOSKI-YOHN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 02-4340 RICHARD K. YOHN, Defendant CIVIL ACTION-LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: l. Ground for Divorce: Irretrievable breakdown under 3301(c) ofthe Divorce Code. 2. Date and manner of service of the complaint: via Acceptance of Service dated September 20, 2002, 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: by Plaintiff June 8, 2006; by Defendant June 8, 2006. 4. Related claims pending: All matters have been resolved between the parties pursuant to the Marital Settlement Agreement dated June 8, 2006 and incorporated, but not merged, into the Decree. See paragraph 3, page 2 of the Agreement. 5. Date Plaintiffs Waiver of Notice in 3301(c) Divorce was filed with Prothonotary: June 8, 2006, Date Defendant's Waiver of Notice in 3301(c) . 0 e was filed with Prothonotary: June 8, 2006, Dated: June L, 2006 Barbara Sumple-Sullivan, EsqUire 549 Bridge Street New Cumberland, P A 17070-1931 (717) 774-1445 Supreme Court ID #32317 Attorney for Plaintiff Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland. P A 17070 (717)774-1445 KATHLEEN A. JERIOSKI-YOHN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : No. 02-4340 RICHARD K. YOHN, Defendant CIVIL ACTION-LAW IN DIVORCE CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certifY that on this date, I served a true and correct copy of the foregoing Praecipe to Transmit Record, in the above-captioned matter upon the following individual by first class mail, postage prepaid, addressed as follows: Bradley A. Winnick, Esquire Wiley, Lenox, Colgan & Marzzacco, P.C. 130 West Church Street Dillsburg, PA 17019 Dated: June L, 2006 arbara Sumple-Sullivan 549 Bridge Street New Cumberland, P A 17070-1931 (717) 774-1445 Supreme Court ID #32317 Attomey for Plaintiff f'. _~ .-, r-,:.' c:) .' .. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA KATHLEEN A. JERIOSKI-YOHN, Plaintiff * * NO. 02-4340 CIVIL TERM * VI. * * CIVIL ACTION - LAW IN DIVORCE RICHARD K. YOHN, Defendant * * ~nAT.TFlED DOMESTIC RF.IATIONS ORDER Plaintiff and Defendant were divorced on , and their property was divided pursuant to the Marital Settlement Agreement dated June 8, 2006, and incorporated into the Divorce Decree. And This Court, being duly advised under the circumstances, now issues this Qualified Domestic Relations Order (QDRO) and reserves continuing jurisdiction over the implementation of this Order. 1. Identification of "Participant'" The Participant is Richard K. Y ohn, Social Security Number 202-46-6257, born December 9, 1954, whose last known address is P.O. Box 429, New Cumberland, Pennsylvania 17070, and who is a Participant under the Consolidated Rail Corporation Agreement Employees' Savings Plan. 2. Identification of" Alternate Pl\Yee'" The Ahemate Payee is Kathleen A. Jerioski- Y ohn, Social Security Number 209-50-1448, born December 1, 1957, whose last known address is 2944 Yale Avenue, Camp Hill, Pennsylvania 17011. The Alternate Payee is the former spouse of the Participant, married on August 29, 1986. 3. TclP.l1tifi..Jrtinn of"PJan'" The Alternate Payee will receive payment from the following retirement plan, hereafter referred to as "the Plan", as provided in this Order: / , ~ Consolidated Rail Corporation Agreement Employees' Savings Plan Plan Administrator' Conrail Agreement Employees' Savings Plan Conrail 200 1 Market Street Philadelphia, PA 19103 4. State Order' This Order is issued pursuant to the laws of the Commonwealth of Pennsylvania relating to provisions of child support, alimony payments or marital property rights between spouses and former spouses and actions for dissolution of marriage pursuant to the Pennsylvania Divorce Code. 5. A!L~iDment of Benefits to Alternate PlIYee' The Alternate Payee is hereby assigned a portion of the benefit that would otherwise be payable to the Plan Participant. The Plan is to make payment of the Alternate Payee's benefit directly to the Alternate Payee. 6. Formula for Determining Alternate Payee Benefit. The Plan shall determine the Altemate Payee's portion of Participant's benefit as follows: $46,450.00 as of June 8, 2006, with any gains or losses which may accrue from that date until the date of distribution. 7. Form and Tune ofPayrnent to Alternate P/Wee: The amounts assigned to the Alternate Payee shall be placed in a separate account. When the Participant has attained the Qualified Earliest Retirement Age (QERA), as defined in Section 414(pXl)(B) of the Internal Revenue Code, the Alternate Payee may request a distnbution of the separate account. Such a request must be made in writing by the Alternate Payee to the Plan's Administrator, who will advise the Plan's Trustee and Recordkeeper to distribute the Alternate Payee's benefit as soon as administratively practicable after receiving such request. 8. Rlection ofBenP.fida\)" The Alternate Payee names Kaitlyn Elizabeth Yohn, whose , " last known address is 2944 Yale Avenue, Camp Hill, Pennsylvania 17011, as beneficiary of the separate account. 9. Fonn of Payment for Participant: The Participant may elect any fonn of payment available under the Plan for the portion of the benefit not assigned to the Alternate Payee under this Order. This includes the right to elect a Surviving Spouse fonn of payment for a subsequent spouse. 10. Federal Tax Re.portini: For Federal Income Tax Purposes, the Alternate Payee and not the Plan Participant shall be treated as the recipient of all benefits made by the Plan to the Alternate Payee pursuant to this Order. The Plan will issue a 1099-R to the Alternate Payee at the end of the calendar year in which the distnbution occurs and report such income to the IRS under the Alternate Payee's name and Social Security Number. 11. RiiPrt to Amend: The Court retains jurisdiction over this matter to amend this Order if necessary to establish or maintain its qua1i1ication as a QDRO under the Retirement Equity Act and the rules of the Consolidated Rail Corporation Agreement Employees' Plan. All of which is Ordered this _ day of ~ - OlIN 2006. BARBARASUMPLE-SULLIV AN,ESQUlRE , Attorney for Ka Ierioski- YolIn EY A WINNICK, ESQUIRE for Richard K. Y 000 ~ Ie 9L- RI K. YOllN f Defendant / Employee ,J. ~ , '1tl/f/l.. ItJ.lhV ~ I, I' , ! 1 :'1 !l! ","J rF' i'I'\(' (;'"<'7 ,.v <_"I )".,J... .. " IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA KATHLEEN A. JERIOSKI-YOBN, PlaintitT * * NO. 02-4340 CIVIL TERM VS. * * CIVIL ACTION - LAW IN DIVORCE RICHARD K. YOBN, Defendant * * * ORDER DIVIDING RA" .ROAD RETIREMENT BENEFITS 1. The purpose of this Order is to divide Richard K. Y 000' s (hereinafter ''Employee") non-tier I benefits under the Railroad Retirement Act as part of a final distribution of property between the parties. The parties in this action were divorced by Order of This Court entered 2. This Court finds in accord with the laws of the Commonwealth of Pennsylvania that Employee's non-tier I benefits under the Railroad Retirement Act are marital property between the parties and may be allocated by Order of This Court. The Railroad Retirement Act prohibits any allocation of Employee's tier I benefits. The Railroad Retirement Board administers the Railroad Retirement Act. 3a. The name, address and social security number of the Employee are: Name: Richard K. Y 000 Address: P.O. Box 429 New Cumberland, P A 17070 Social Security #: 202-46-6257 3b. The name, address and social security number of the Spouse are: Name: Kathleen A. Jerioski- Y 000 ,. .. Address: 2944 Yale Avenue Camp Hill, PA 17011 Social Security #: 209-50-1448 4. It is therefore Ordered that: Spouse is awarded, and the Rai1road Retirement Board is directed to pay, an interest in the portion of Employee's benefits under the Railroad Retirement Act (45 U.S.C. ~~231-231v) which maybe divided as provided by Section 14 of that Act (45 U.S.C. ~231m. Employee's non-tier I diviSible benefits under the Railroad Retirement Act shall be allocated between the marital and non- marital portions thereof by use of a coverture fraction. The denominator of the coverture fraction sha1l be the nmnber of months the Employee worked to earn the total benefit. The numerator of the coverture fraction shall be the number of such months during which the parties were manied and not finally separated. The parties were manied on August 29, 1986, and were finally separated on September 10, 2002. The benefit to which the coverture fraction is applied shall include all post-separation enhancements except for enhancements arising from post-separation monetary contributions made by the Employee, including the gain or loss on such contributions. Spouse is awarded, and the Railroad Retirement Board is directed to pay, fifty-eight percent (58%) of the marital portion of Employee's non-tier I benefits under the Railroad Retirement Act, as the marital portion thereof is defined herein. 5. This Order sha1l not impact or affect in any manner any entitlement Spouse may have under the Railroad Retirement Act to receive Railroad Retirement Divorced Spouse Benefits. Payment of this benefit is controlled by Federa1law and cannot be altered by This Court. - .... 6. A certified copy of this Order shall be served upon: Deputy General Counsel U.S. Railroad Retirement Board 844 North Rush Street Chicago, IL 60611-2092 7. The Court retains jurisdiction over this matter to amend this Order if necessary to implement the award to Spouse provided for herein. 8. So Ordered this _ day of ,2006. '- PI' . /Sp ~ /L r/L RICHARD K. YOHN { Defendant / Employee BARBARASUMPLE-SULLIV AN,ESQUIRE '""'T""om-YoIm BRADLEY A. WINNICK., ESQUIRE Attorney for Richard K. Y ohn BY THE COURT: , J. Attorney for Employee Bradley A. Winnick, Esquire 130 W. Church Street, Dillsburg, PA 17019 Attorney for Spouse Barbara Sumple-Sullivan, Esquire 549 Bridge Street, New Cumberland P A 17070-1931 "')c7/f:!1.. Pff-:' ~ , .': \ \. '~ .1 '.n) ",." I'C" (\i'\\,' \ \ ~ \ \! \ I' c.> '",,. !,.' (, ~\\ ':Y-\l !;,!~,'; ". IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . STATE OF PENNA. KATHLEEN A. JERIOSKI-YOIlN , . Plaintiff NO, 02 - 4340 . . VERSUS . RICHARD K. YOIlN, Defendant . . DECREE IN DIVORCE . . . . AND NOW, :I., 17' 2 '1 2006 IT IS ORDERED AND . DECREED THAT KATHLEEN A. JERIOSKI-YOIlN , PLAINTIFF, . . RICHARD K. YOIlN . . 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 FINAL ORDER HAS NOT YET BEEN ENTERED; All matters have been resolved between the parties pursuant to the Marital Settlement Agreement dated June 8, 2006 and incorporated, but not merged, into the Decree. . . ~./AI<IL . . J. . A .~~ #,. ~, 9? PROTHONOTARY . . . . . ~('1 ~ r ~ ~/L.. ')0' E.t. ~ P .L.-pp?- ~,(,b, ~f!'l -,d- EL ... ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 07/03/06 Case Number (See Addendum for case summary) 1032 \01-\-25'6 02 - L\-~ C\\i~ \ o Original Order/Notice o Amended Order/Notice o Terminate Order/Notice NORFOLK SOUTHERN CORP 110 FRANKLIN RD SE ROANOKE VA 24042-0002 RE: YOHN, RICHARD K. Employee/Obligor's Name (Last, First, MI) 202-46-6257 Employee/Obligor's Social Security Number 5377100923 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, MI) EmployerlWithholder's Federal EIN Number See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMA nON: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 250.00 per month in current support $ 0.00 per month in past-due support Arrears 12 weeks or greater? 0 yes (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 $ 250.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 57.69 per weekly pay period. $ 115.38 per biweekly pay period (every two weeks). $ 125.00 per semimonthly pay period (twice a month). $ 250.00 per monthly pay period. REMITTANCE INFORMA nON: You must begin withholding no later than the first pay period occurring ten (10) working days after the date ofthis Order/Notice, Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's! obligor's aggregate disposable weekly earnings, For the purpose of the limitation on withholding, the following information is needed (See #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, 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. DRO: RJ Shadday Service Type M OMB No.: 0970-01 S4 Juige Form EN-02lf Worker ID $IATT Date of Order: LJ'7 ~, )0b ... - ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS o If {;hecked you are required to provi~e a (:opy 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. * Repoltillg tl,e Pay date/Date of '...'itl" ,oldillg. You I"ust n~port tl,e paydateldate of vvitl" ,oldillg vvl,en sellding ti,e paYI"el't. Ti,e paydateldate of vvitl,I,old;I,g is ti,e date Oil vvl,icl, al"obnt V'Vas witl,l,eld fIOJ', ti,e en,ployee's wages. 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 infonnation 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: YOHN , RICHARD K. EMPLOYEE'S CASE IDENTIFIER: 5377100923 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 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, 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. 91673 (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, 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, 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: If you or your employee/obligor have any questions, DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT 13 N. HANOVER ST by telephone at (717) 240-6225 or P.O. BOX 320 by FAX at (7171 240-6248 or CARLISLE PA 17013 by internet www.childsupport.state.pa.us Service Type M Page 2 of 2 Form EN-028 Worker ID $IATT OMB No.: 097().()154 .' ADDENDUM Summary of Cases on Attachment Defendant/Obligor: YOHN, RICHARD K. PACSES Case Number 632104258 Plaintiff Name KATHLEEN A. JERIOSKI-YOHN Docket Attachment Amount 02=-4340 CIVIL $ 250.00 Child(ren)'s Name(s): IC1\:r:TLYli...:E ,YOHN D 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 D 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 D If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee'slobligor's employment. Service Type M Addendum OMB No,: 0970-0154 PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ..... ."... .. D 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 D 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 If checked, you are required to enroll the child(ren) above in any health insurance coverage available the employee's/obligor's employment. Form EN-028 Worker JD $IATT 1'<' () -;'1 rn ... ,-" ( JERIOSKI-YOHN, KATHLEEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION -DIVORCE NO. 02-4340 CIVIL TERM YOHN, RICHARD K., IN DIVORCE Defendant PACSES CASE: 632104258 ~ o ORDER OF COURT ~` o ' i _ r--- r1 Z ~ _ _ ,._, r i=, ~• -~ w~ FTl ~i ., a ~ _ y-T, AND NOW to wit, this 6th da of Jul 2010 it is hereb Ordered that the #xmb`~~+lan F~' Y y, y ~ ~ d=, r-~ County Domestic Relations Section dismiss their interest in the above captioned Alimonpmat fir, pursuant to the parties' Marital Settlement Agreement of June 8, 2006 and the Defendant satisfying his obligation. There is no balance due to the Plaintiff. This Order shall become final twenty (20) days after the mailing of the notices of the entry of the Order to the parties unless either party files a written demand with the Office of the Prothonotary for a hearing de novo before the Court. BY THE COURT: DRO: R.J. Shadday xc: Petitioner Respondent Nora Blair, Esq.. Barbara Sumple-Sullivan, Esq.. Form 0E-001 Service Type: M Worker: 21005