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Home My WebLink About95-04916 , j; , ;# , - - '- 0) - - o ;..- ::~ \ , / I I , E: (,.. ~ J ~ ~<' ...,:, - , a- ::J- , / , ( *-----*----***-**---)---------~ ~ ",',~~,-'"--,--,-----"..--..--,..-.""'~.--,,. ..,"'"' .-""... '..'---...-........------'lii ','/ 7 8 ~;I ',') ~) . , ~I ':'! ~I ~I ~I ',-( ~I .1 :1 ~) ,,; ~I : i :1 ~I' w Vi ,',/ ~I ~, 'I ~! ,', ~ 8 8 81 ~I ~i 8 :1 8 8 8 8 8\ 8.' ~ ~' '0', .1 ~: IN THE COURT OF COMMON PLEAS COUNTY 8 ~ s 8 8 ~ ~ W '7 ~ ., ~ ~ ~ ,',' (~ I" !~ p; ~~ '.. ) . , . ;~ ) i~ '~ ..~ ;' . '~ ... \~ ~ I... ~ ~ ~ ~ '.' ~ ~ J. s ~ ~ *' ~ ~ OF CUMBERLAND ~ STATE OF ~ PENNA, ~ ~ ~ ~ .. .~ ~ :. .. . . . . . -.' ~ ~ ~, ~ ~: :~ ~ ~ ~ . ~ ~ .~ ~ .~. .*~, .~. ,~ .~ HARRY A. GILL, JR., 1\ 0, 95-.4916 CIVIL II) Plaintiff \' t'r~lI.... COLLEEN D. GILL, Defendant DECREE IN DIVORCE (9~ J I:J ['J. AND NOW, .....~__ ...... 1998 . . " it is ordered and decreed that. . Harry ,A.. .Gill, Jr. and... .CoUeeo.t>..GiU. are divorced from the bonds of matrimony, . '. plaintiff, defendant, The court retains jurisdiction of the following claims which have been raised of r.,c~rd in this action for which a final order has not yet been entered; ~"'4> TI1e. parties' Marital Settlement Agreement da.t.ed.July 16, 1998 ill. but not rrerged. // , Ii, .Thr C"~rl /" \JJ;-,(. t-v i ,\ tl.-'.If ~t./.., ,.:', ~1Y~ *~.....7:>- '/ Pt1#'J ,., r (k;k (J,7 / . rryl)rnthunol.,ry )')/1/,1'1 4d~/7/ ,;a.l'l./ ~ a:/t., .s/~e/ ~ - ~ ~/ /0 1'1" ~ '?#ita ,NI"Jp ~ //If 7..uev.-t . [ t l MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT. made this .l1L:day Of.0.....J'" _ , 19'11. by and between Harry (/-:=r- A. Gill, Jr., hereinafter called "Husband", and Colleen D. Gill, hereinafter called "Wife". WHEREAS, Husband and Wife were lawfully married on February 15. 1979; WHEREAS, differences have arisen between the parties and it is the intention of Wife and Husband to live separate and apart, and the parties hereto desire to settle fully and finally their respective financial and property rights and obligations as between each other including, without limitat/oll by specification: the settling of all matters between them relating to the ownership and equitable distinction of real and personal property; the settling of all mailers between them relating to the past. present and future support. alimony and/or maintenance or Wife by Husband or of Husband by Wife; and In general, the settling of any and all claims and possible claims by one against the other or against their respective estates. 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, Wife and Husband each. intending to be legally bound hereby covenant and agree as follows: 1. SEPARATION AND NON INTERFERENCE: It shall be lawful for each party at all times hereafter to live separate and apart from each other at such place as he or she from time to time shall choose or deem fit. The foregoing provision 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. Each party shall be free from interference, authority and control by the other. as fully as if he or she were single and unmarried. except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest or attempt to endeavor to molest the other. or in any way harass or malign the other. nor in any other way Interfere with the peaceful eXistence. separate and apart from the other Neither party shall say or do anythIng to negatively Influence or alienate the minor child from the other parent. r.1II.wpt ..'.... ,. Z. RECONCILIATION: This Agreement shall not be deemed to have been waived. extinguished, discharged, terminated, invalidated or otherwise affected by a reconciliation between the parties hereto, cohabitation between the parties, a living-together or resumption of marital relations between them. They shall not be deemed to have reconciled with the intention of vitiating or terminating this Agreement unless they make such actions through a written instrument, executed and acknowledged in the same manner as this Agreement. 3. ENFORCEMENT: The parties acknowledge that Husband filed to Cumberland County Court of Common Pleas,l(",~ Cuullly, Pennsylvania, Docket Number 95-4916 a no-fault divorce action pursuant to section 3301 (cl of the Pennsylvania Divorce Code and Wife filed a counterclaim raising various counts pursuant to Tille 23 of the Pennsylvania Divorce Code and amendments thereto. It is specifically understood and agreed by the parties that the prOVisions of this agreement relating to equitable distribution of property and all other matters contained herein including but not limited to support, alimony. alimony pendente lite. counsel fees. costs and/or expenses are accepted by each party as a final settlement for all purposes whatsoever. as contemplated by the Pennsylvania Divorce Code. Upon execution of this agreement, the parties agree to execute their respective Affidavit of Consent and Waiver of Notice and proceed with entering same to said docket for the purpose of finalizing the divorce action. Each party shall execute any and all documents which may require his or her signature for the purpose of effectuating all of the terms and conditions of this Agreement so as to give full force and effect to this Agreement. Should a decree. judgment or order of se;1aration or divorce be obtained by either of the parties in thiS or any other state. country or junsdictlon. each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be affected In any way by any such separation or divorce. and that nothing '" any such decree. Judgment. order or further modIfication or reviSion thereof shall alter amend or vary any term of thIS Agreement It IS CiII.wpl 2 specifically agreed, however, that a copy of this Agreement or the substance of the provisions thereof, may be Incorporated by reference Into any divorce, judgment or decree. This Incorporation, however, shall not be regarded as a merger, It being the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties. ~ SPOUSAL SUPPORT/ALIMONY/ALIMONY PENDENTE LITE IAPLI. COSTS AND EXPENSES: Husband and Wife hereby acknowledge that they have been advised that each may have the right to assert a claim for spousal support, alimony, alimony pendent lite, costs and/or expenses. Further, Husband and Wife acknowledge that they understand that said rights are available in the divorce action. Husband and Wife further acknowledge that they are aware of the income. education, income potential, and assets and holdings of tile other or have had full and ample opportunity to become familiar with such items. Husband hereby agrees to provide to Wife in the form of non-modifiable alimony the sum of $154.00 per month which shall be enforceable through Cumberland County Domestic Relations Section. The parties hereto acknowledge that Wife instituted an action in supportlAPL against Husband to DRO docket number 26.381. Husband's obligation to pay Wife APL pursuant to the February 28, 1996, Order of Court, Cumberland County Court of Common Pleas. docket number 95-4916 shall terminate upon the execution of this agreement. Husband shall take the appropriate action to terminate such obligation and Wife shall cooperate to any reasonable extent necessary. Wife shall not however be required to repay any APL sums paid by Husband beyond Husband's obligation pursuant to this agreement. In the event Husband is not successful in immediately terminating the APL award through Domestic Relations. Wife shall not thereafter be penalized to any extent. Husband's alimony obligation in the amount of 5154.00 per month shall be Immediately due and payable upon the execution of this agreement and shall continue each and every month thereafter for a penod of thirty six (36) consecutive GIIl.wpt ~ months with payments due and payable on the same day (date) each month; said day being the date upon which this agreement Is executed. It is understood and agreed upon by the parties that Wife's health Insurance provided by Husband shalltennlnate with the entry of a final decree in divorce In this case. Therefore, at Husband's sole cost and expense, Husband hereby agrees to provide for Wife continuing COBRA coverage through the end of January 1999. Husband and Wife shall cooperate and take all necessary steps In order to ensure that such coverage continues from the date of the entry of the final decree in divorce through the end of January, 1999. Thereafter, Husband's alimony obligation at the rate of $154.00 per month shall commence and continue until he has made a total of thirty six (36) consecutive payments in the amount of $154.00 either to Wife or on her behalf. This payment shall calculate into the equation any and all COBRA payments Husband is required to make on behalf of Wife. Each party shall be responsible fot their own fees. expenses and costs associated with this case excepting anything provided in this agreement to the contrary. 5.. EQUITABLE DISTRIBUTION: A. REAL ESTATE: 2745 Ritner Hiohwav Carlisle Cumberland Countv Pennsvlvania Husband and Wife were the owners of 2745 Ritner Highway, Carlisle. Cumberland County, Pennsylvania, which was sold and the settlement proceeds were placed in an escrow account with the settlement agent, Christopher C. Houston. Esquire. 52 West Pomfret Street. Carlisle. Pennsylvania. 17013 Upon the execution of this agreement. the parties hereto agree that Wife shall become the sole owner of the escrow account proceeds with Husband forever waiving. relinquishing and abandOning whatever right. htle and/or interest he may have thereto. The partIes hereto further agree that Mr Houston shall upon receIpt of a copy of thIS agreement release unto Wife Siaid proceeds by submItting an escrow account check made payable to Wife's counsel for the entire balance while namIng said counsel as agent for Wife CIII.wpt 4 B. WAIVER OF PERSONAL 1) MARITAL, TANGIBLE AND INTANGIBLE, ASSETS AND 2) NON-MARITAL, TANGIBLE AND INTANGIBLE, ASSETS: Husband and Wife do hereby acknowledge that they have heretofore divided to their mutual satisfaction all non-marital and marital assets including, but without limitation, business interests, partnershlp(s), inheritance(s), jewelry, clothing, pensions, brokerage accounts, stocks, bonds, life insurance policies or other securities, Individual Retirement Accounts, checking and savings accounts. mutual funds, and other assets whether real, personal or mixed. tangible or intangible. Husband and Wife further acknowledge and agree that the assets in the possession of the other spouse shall be that spouses sole and separate property, each party hereto specifically waiving, releasing, renouncing and forever abandoning whatever claim, if any, he or she may have with respect to any of the foregoing items which are the sole and separate property of the other. C. INTENT: This Agreement is intended to distribute all property of the parties, whether real or personal. and whether determined to be separate or marital property. In the event that any property may be omitted from this Agreement, it is understood and agreed that the person having possession andlor title to such property following the execution of this Agreement shall be deemed the owner thereof and each of the parties will execute any and all legal documents without any charge therefor to evidence title to such property in the other party. ADDITIONAL DOCUMENTS: Each of the parties shall on demand execute and deliver to the other any deeds, documents. records or closing statements relating to the sale of real estate under this Agreement, bills of sale, assignment. consents to change of beneficiary on insurance policies. tax retums and other documents and do or caused to be done any other act . or thing that may be necessary or desirable to the provisions and purposes of this Agreement. TAXES: Husband hereby agrees to pay all income taxes assessed against him, if any. as a result of the division of the property of the parties hereunder Wife hereby agrees to pay all GiII.wpc 5 income taxes assessed against her, if any, as a result of the division of the property of the parties hereunder. 6. AFTER ACQUIRED 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 unmarried. The parties hereby agree that as to all assets not specifically mentioned herein which are presently titled in the sole name of one of the parties hereto or. if untitled, are presently in the sole possession of one of the parties hereto, the party not having title thereto or possession thereof hereby waives, releases, relinquishes and forever abandons any and all claims therein, and acknowledges that the party haVIng title or possession of such items shall be the sole and exclusive owner thereof. 1.. DEBTS: A. Wife's Debts: Wife represents and warrants to Husband that since the parties' separation she has not and in the future she will not contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save hannless Husband from any and all claims or demands made against him by reason of debts or obligations incurred by her. B. Husband's Debts: Husband represents and warrants to Wife that since the parties' separation he has not and in the future he will not contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save hannless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. C. Marital Debts: The parties hereto acknowledge that neither are aware of any outstanding mantal or joint debts, In the event there are any mantal debts for whIch the parties are obligated, Husband GiII.1oIp1 6 hereby agrees to indeminfy Wife to the same extent as provided hereinbelow in subsection D as if fully set forth herein. n. Indemnification: All further debts incurred by the parties shall be their individual responsibility. Each party represents and warrants to the other that he or she has not incurred any debt, obligation. or other liability, other than described in this Agreement, on which the other party is or may be liable. Each party covenants and agrees that if any claim, action or proceeding is hereinafter initiated seeking to hold the other party liable for any other debts, obligations, liability, act or omission of such party, such party will at his or her sole expense, defend the other against any such claim or demand, whether or not well.founded, and that he or she will indemnify and hold harmless the other party in respect of all damages as resulting therefrom. Damages as used herein shall include any claim, action, demand, loss, cost, expense, penalt~, and other damage, including without limitation, counsel fees and other costs and expenses reasonably incurred in investigating or attempting to avoid same or in opposing the imposition thereof or enforcing this indemnity, resulting to Husband or Wife from any inaccurate representation made by or on behalf of either Husband or Wife to the other in this Agreement, any breach of any of the warranties made by Husband or Wife in this Agreement, or breach or default in performance by Husband or Wife of any of the obligations to be performed by such party hereunder. The Husband or Wife agrees to give the other prompt written notice of any litigation threatened or instituted against either party which might constitute the basis for a claim for indemnity pursuant to the terms of this Agreement. I. FULL DISCLOSURE: The parties aCknowledge that each of them have had a full and ample opportunity to consult with counsel of their choice regan:ting their claims arising out of the marriage and divorce and that they have specifically reviewed their rights to the eqUitable distribution of mantal property, including rights of discovery, the tight to compel a filing of an Inventory and Appraisement. and the right to have the court review the assets and claims of the parties and GiII.wpt 7 decide them as part of the divorce action. Being aware of those rights, and being aware of the marital property owned by each of the parties, the parties hereto, in consideration of the other terms and provisions of this agreement, do hereby waive, release and quilcJaim any further right to have this court or any other tribunal equitably distribute or divide their marital property. The parties acknowledge that they have been fully advised and informed of the wealth, real and/or personal property, estate and assets, eamings and income of the other and are familiar with and cognizant of such and the value thereof, or has knowingly waived such advice and/or information. The parties hereto have been fully advised and informed of all rights and interests which, except for the execution and delivery hereof, have been conferred upon or vested in each of them by law with respect to the property or estate of the other by reason of their marital status, or has knowingly refused or waived such advice or information. i. RELEASES: Except as otherwise herein provided, each party releases and discharges completely and forever the other from any and all right, tille, interest or claim or past. present or future support, division of property including income or gain from property hereafter accruing, right of dower and . courtesy. light to act as administrator or executor in the estate of the other, right to distributive share in the other's estate, right of exemption in the estate of the other. or any other property rights, benefits or privileges accruing to either party by virtue of said marriage relationship, or otherwise, and whether the same are conferred by the statutory law or by the common law of the Commonwealth of Pennsylvania, or any other state, or of the common law of the United States of America. It is further specifically understood and agreed by and between the parties hereto, that each party accepts the prOVisions herein made ,n lieu of and m full settlement and satisfaction of any and all of said parties' nghts against the other for any past. present and future claims on account of support. mamtenance. alimony. alimony pendente lite. counsel fees. costs and expenses, eqUitable distnbution of mantal property and any other cl8lms of each party, mcluding all claims raised by them ,n the divorce action pending between the parties GIII.wpt ~ ~ 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. The party breaching this contract shall be responsible for the payment of legal fees and costs incurred by the other in enforcing his or her rights under this Agreement, or seeking such other remedy or relief as may be available to him or her. 11. REPRESENTATION: Bath parJes have been given the opportunity to obtain the advice of counsel regarding the provisions of this Agreement and their legal effect in advance of the date set forth above to pem1it such independent review. In the event either party elects to execute this agreement without the advice of counsel, he/she shall nevertheless be bound hereby and he/she specifically and knowingly waives hiS/her right, if any, to utilize hiS/her lack of legal representation as a basis to attack the validity of this Agreement. Each party acknowledges that he or she has had the opportunity to receive independent legal advice from counsel from his or her selection, and that each fully understands the facts and has been fully informed as to his or her legal rights and legal obligations, and each party acknowledges and accepts that this Agreement is, and the circumstances, fair and equitable, and that it is being entered into freely and voluntarily, after having had the opportunity to receive such advice and with such knowledge, 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 improper or illegal agreement or agreements. 11. VOLUNTARY EXECUTION: The provisions of this Agreement are fully understood by both parties ana each party acknowledges that this Agreement is fair and equitable, that it is being entered into voluntarily and that it is not the result of any duress or undue influence. Further. each party acknowledges that he or she has the mental capaCity to understand the terms provided herein and has not been placed under duress, coercion or any physical or mental stress CiII.wpl 9 11. 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. jj. PRIOR AGREEMENT: It is understood and agreed that any and all property settlement agreements which may or have been executed prior to the date and time of this Agreement are null and void and of no effect. 11. MODIFICATION AND WAIVER: Any modification or waiver of any provision of this Agreement shall be effective only if made in writing and executed with the same fonnalily as this Agreement. The failure of either party to Insist upon strict perfonnance 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. 1L GOVERNING LAW: This Agreement shall be govemed by and shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 1L INDEPENDENT SEPARATE COVENANTS: It is specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 11. VOID CLAUSES: If any tenn. condition. clause, or provision of this Agreement shall be delennined 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. 11. CONSENTS TO DIVORCE: ~. ro The parties agree that they shall execute Affidavits 01 Consent and their Waivers 01 Notice which shall be filed with the court along with a Praecipe to Transmit the Record In order thaI a Decree In Divorce Incorporating the herein agreemont can be Issued In due course. ZD. DISTRIBUTiON DATE: The parties hereto acknowledge and agree that lor purposes 01 distribution 01 property al provided lor in this agreement, the date 01 execution 01 this agreement shall be known as the Distribution Date. Z1.. DATE OF EXECUTION: The parties hereto acknowledge and agree that the date 01 execution relerred to herein shall be known as the last date upon which either party executes this agreement. IN WITNESS WHEREOF. the parties hereto, Intending to be legally bound hereby, have hereunto set their hands and seals the day and year lirst above WIillen. WITNESS: j t1-Ja. a ~. Harry A~i Jr !J&1-- () d,1;d Colleen 0 Gdl rolll.Wllt II . . Commonwealth of Pennsylvania COUNTY OFr.L ntb.uJ ()A1tl ss. On this, the J1J!!.day of , 1992:: before me, a Notary Public, personally appeared Ha A. ill, Jr., known to me to be the person whose name is subscribed to the within Settlement Agreement and acknowledged that he executed the same for the purposes therein contained. lIC IN WITNESS WHEREOF, I hereunto set my hand and official seal. <}?~ ~L~~ NOTARY PU C , ' My Commission Expires: Notal1aJ Seal RobIn J. Goshorn, NolaIy PublIc Carffsle Boto, Cumberland County . , . <::ommlsslon e.p1n;s Aprtl17, 1999 .. Commonwealth of Pennsylvania .......... J. COUNTY OF I/.':} 4.....:... ss. On this, the J!1 day of J~ ' 19~efore me, a Notary Public, personally appeared Colleen Gill, known to me to be the person whose name is subscribed to the within Settlement Agreement and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. i w - ~ \ L---.-: . ..~ ......w,.,.,!! .."- '" .~- GlII,wpt IZ >- C'l ; n; C": -, . ,. , ,'~ L ~ I:' ~ :' f, L C)' C '.:' l I .' , I,j.' , I L L .. L; .:; U IN THE COURT OF COMMON PLEAS HARRY A. GILL, JR.. Plaintiff CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION VS, COLLEEN D. GILL, Defendant NO. 95-4916 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under ~3301 (c) _"'...nr_IJ.-~ (Strike out inapplicable section). 2. Date and manner of service of the complaint: First cIa"" mal I tn I1Pfpn<'!..nt '" lIHnrnpy of Record, James A. Miller, Esq., on or about SeDtember 22. 1995. 3, Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by ~3301 (c) of the Divorce Code: byplainliff July 16, 1998 ; by defendant JUly 21, 1998 (b) (1) Date of execution of the affidavit required by ~3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: None 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date of plaintiff's Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: July 21. 1998 Date defendant's Waiver of Notice in ~3301 (C) Divorce was filed with the Prothonotary: Jul v 29. 1998 . -JJiA!~jl/J~i~ / Ann.> Sheparo. Esq, Marney ,,f Pla,nlifJl ~:,.~~ '- \"1 l:~ a: co: j':= t.',~ ,.. , I ). : \ ~: , , - .' '- .. ( " :> .. , [ I U ,.-. :i.l.i "..- L' "- c: , U~ c:.J l U (P 0 HARRY A. GILL, JR., Plaintiff v. : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 95- i.ftf/fp CIVIL TERM . . COLLEEN D. GILL, Defendant IN DIVORCE NOTICE TO DEPEND 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 counselling. A list of marriage counselors is available in the Office of the Prothonotary at Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Fourth Floor Cumberland County Courthouse CarliSle, PA 17013 (717) 240-6200 HARRY A. GILL, JR., Plaintiff . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . . : v. NO. 95- CIVIL TERM COLLEEN D. GILL, Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(0) or 3301(4) OP THE DIVORCE CODE 1. The Plaintiff is Harry resides at 2745 Ritner Highway, Pennsylvania, since 1991. 2. The Defendant is Colleen at 2745 Ritner Highway, Carlisle, Pennsylvania, since 1991. 3. Plaintiff and Defendant have been bona fide the Commonwealth for at least six months immediately the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 15, 1979. A. Gill, Jr., who currently Carlisle, Cumberland County, D. Gill, who currently Cumberland County, resides residents in previous to 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of marriage counselling and that the Plaintiff may have the right to request that the court require the parties to participate in counselling. 8. Plaintiff requests the court to enter a decree of divorce. I verify and correct. that the statements made in this Complaint are true I understand that false statements herein are made . subject to the penalties of 18 Pa. C.S. 54904, relating to unsworn falsification to authorities. DATE: q~ I 5-'75 }~ C\. vCc~..v~ ' Ha Y A. G 11, Jr. FOWLER, ADDAMS, SHUGHART & RUNDLE By: ) , \\v LlJ...#..LC k)~ll-'- Michael R. Rundle supreme court I.D. No. 27768 Attorneys for plaintiff 28 south pitt street P.O. BOX 208 carlisle, PA 17013 (717) 249-8300 ~ - :e: ..."1: ..' ~ II> .. ~ . t >~ i"]~Ii. i-~ ~ \ ~ e,8~ip , _' ,.:,. I' JI ::p -~./) ~. '_ .so - ~ ,. .:1:-;: ~ u.I (/'l c4 \" ..., - r-- :J I:t- 00'-")' ~~ ~-d .tlr I HARRY A. GILL, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA vs. : CIVIL ACTION - LAW COLLEEN D. GILL , Defendant : 95-4916 CIVIL TERM : IN DIVORCE ACCEPTANCE OF SERVICE I hereby acknowledge that I am authorized to accept service on behalf of the Defendant, COLLEEN D. GILL, a certified and true copy of a NOTICE TO DEFEND AND CLAIM RIGHTS and COMPLAINT IN DIVORCE in the above-captioned action. DATE~ 11- 7 f \ ~ I /L-- James . Miller, Esquire 122 Ltlcust St., Suite 100 Harrisburg, PA 17101 ----/" /,/. Harry A. Gill, Jr., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION. LAW : No. 95-4916 CIVIL TERM Colleen D. Gill, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September IS, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the tiling 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 decrees. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERST AND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF Pa.C.S. 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. ~Q~. HARRY A. ILL, JR PLAINTIFF DATE: ....J,~/q8 , HARRY A, GILL, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW : No. 95-4916 CIVIL TERM COLLEEN D. GILL, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301l!:) OF THE DIVORCE CODE 1, I consent to the entry of a final decree in divorce without notice. 2. 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. 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. Section 4904 relating to unsworn falsification to authorities, DATE:~ ~o~ HARRY . GILL, JR, Plaintiff ..I i..:. ~::.: ' " HARRY S. GILL, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs, : CIVIL ACTION - LAW : 95-49 I 6CIVIL TERM COLLEEN D. GILL, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code wu filed on September IS, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing ofthe Complaint. 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the decrees. I VERIFY THAT THE STATEMENTS MADE IN TIlE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTffiS OF Pa.C.S. 4904 RELATING TO UNSWORN F ALSIFICA TlON TO AUTHORITIES. DATE7'd/-9~ ~ /Y. diL b{f.EEN D. GILL Defendant . -:'"..... >- ,.... ~ q; C'\: ~ :5 :J.~ l-~' "::)::) W.':. ~i', :t: '..J~ l~~. ~ ")~ '.,1_~ ~r ~, . .>- en ~-~!Q (\J .-l~ -J ::! 15 eLl' - LOa. I -, ~- ~ ". CO ::; l) en u HARRY A. GILL, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V5. : CIVIL ACTION - LAW : No. 95-4916 CIVIL TERM COLLEEN D. GILL, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301~ OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice, 2. 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. 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 I. Pa.C.s. s.ction 4"4 relating to......orn fabUioatian to :,nri~. . DATE:707/q~ d/LL . .{), ~ tof~ILL Defendant :>- ex, r:: $ cv -, ..== ~- ~, r5 ..J..... t,L.' ~. ()~ ~:!r \ ~ ~..):? Lr..... ..q; - I, ..1 "~i2 (?~- 0') c". ...~~ -, ~.. <'\I 1-1,1 "-=:1[, , r.:2 Ci:, 5 'U'jJ j.:' .all. -, ~ 1,1... OJ ..:l 0 0. U . . t . , . . . LAw CFF1CES OF .lAMES A. MILLE" , 112 LOcuaT 'fIIRT, IIurYI lea. I1.....Uuttflo...,. ''7IDI 171'" 11"."1 ,... f'71'71 1:1....,..., ~.\ ,. "'f " HARRY A. GILL, JR" Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 95 - 4916 v. COLLEEN D. GILL, Defendant CIVIL ACTION - LAW IN DIVORCE ANSWER AND COUNTERCLAIM TO COMPLAINT IN DIVORCE Defendant, Colleen D, Gill, by and through her counsel James A. Miller, Esquire, hereby files this Answer and Counterclaim to Plaintiff Harry A. Gill, Jr's Complaint in Divorce and respectfully avers the following: ANSWER 1-8. Pursuant to Pa,R.C,P. 1920,14, an answer to the allegations of an action for divorce is not required. COUNTERCLAIM COUNT 1- EQUITABLE DISTRIBUTION OF PROPERTY 9, The prior paragraphs of this Answer and Counterclaim are incorporated herein by reference thereto. 10. The parties have acquired certain property and assets which constitute marital property, 11, This Honorable Court is authorized to equitably divide, distribute or assign marital property between the parties in such proportion as the Court deems just after consideration of all relevant factors. COUNT II - ALIMONY 12, The prior paragraphs of this Answer and Counterclaim are incorporated herein by reference thereto. 13, Defendant Colleen D. Gill is unable to sustain herself during the course of litigation and to defend the divorce action. 14. Defendant Colleen D. Gill lacks sufficient income and property to provide for her reasonable needs and is unable to sustain herself through appropriate employment. COUNT III - ALIMONY PENDENTE LITE AND COUNSEL FEES, COSTS AND EXPENSES 15, The prior paragraphs of this Answer and Counterclaim are incorporated herein by reference thereto. 16, Defendant Colleen D. Gill is unable to pay her counsel fees, costs and expenses and Plaintiff Harry A. Gill, Jr. is able to pay them, WHEREFORE, Plaintiff requests this Honorable Court to enter a decree: 1. dissolving the marriage between Plaintiff and Defendant; 2, equitably distributing all marital property pursuant to section 3502 of the Divorce Code, 3, awarding Defendant alimony pandente lite until final hearing and thereupon to enter an order of alimony in her favor pursuant to sections 3701 and 3702 of the Divorce Code and ordering Plaintiff, Harry A Gill, Jr., to pay the reasonable counsel fees, costs and expenses of Defendant. Respectfully submitted, . &')-;;' '1C- Date: -;j,,{ IL James A Miller, Esquire Attome 'for Defendant 122 cust Street, Suite 100 isburg, Pennsylvania 17101 (717) 236-5161 I, COLLEEN D. GILL, hereby swear and affirm that the facts contained in the foregoing ANSWER AND COUNTERCLAIM TO COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and belief and are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsYtOm falsification authorities. I!& J) Date: 1 1- L .~ U Colleen D. Gill HARRY A. GILL, JR., Plaintiff v. COLLEEN D. GILL, Defendant . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 95.4916 CERTIFICATE OF SERVICE CIVIL ACTION. LAW IN DIVORCE I, James A. Miller, Esquire, hereby certify that I have forwarded a copy of the foregoing Answer and Counterclaim to counsel for Plaintiff, Michael Rundle, Esq" 28 S, Pitt Street, P,O, Box 208, Carlisle, PA 17013-0208, on the date indicated below by U.S. First Class Mail. Date: '- -1. -z -7'", _.- JilL / James A. Miller, Esquire / Attorney for Defendant L- 122 Locust Street, Suite 100 J:tarrisburg, Pennsylvania 17101 (717) 236.5161 / r >- .' ~; (T) f,: ~~ Lt, w~.~ M , .'~ l.)~ .... .-:,: IP C~ " , 0':' ", ::i @' (T) , , J....... N : Ef::.: " co' ..~!~ ~: 4J L.. 1._ \0 ~) <.:.; C' <..l t " 'G "-) 'C) ~J '- ~ p ~ '\~ - ('() ':.L "" 'n \'-.... .... ~ C) ~ ....... ~~~ ~~~ . . . . - ~ m i FowLER, ADDAMS, SHUGHART lit. RUNDLE' ATTORNEYS AT LAW as SOUTH PITT SlJlEET CARUSLE. PENNsYLVANIA 17013 TELEPHONE (717) 24U300 ~B 2.61996~ " :. ,I , v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-4916 CIVIL TERM HARRY A. GILL, JR., Plaintiff COLLEEN D. GILL, Defendant : IN DIVORCE AND NOW, this ORDER OF COURT :) ('f't J day of It(.\.\.,\ Col'] , 1996, Esquire, and James A. Miller, upon Motion of Michael R. Rundle, '1 I I I I I Esquire, and pursuant to the Stipulation of the parties, attached hereto, it is ordered and directed that the Plaintiff, Harry A. Gill, Jr. shall pay to the Defendant, Colleen D. Gill, the sum of Four hundred fifty ($450.00) Dollars per month as alimony pendente lite commencing with the month of February, 1996, to be paid directly by the Plaintiff to the Defendant, and not through the cumberland County Domestic Relations Office, said payments to be made on or about the first day of each month, with the February and March, 1996 payments made on or about March 1, 1996. Provided, however, that should the Plaintiff fail to make any monthly payment on or before the tenth day of the month, the Defendant shall have the right to have this obligation enforced through the Domestic Relations Office by means of a wage attachment. By the Court, 1ft" ( ~j l , .)/------ J. HARRY A. GILL, JR., Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-4916 CIVIL TERM COLLEEN D. GILL, Defendant IN DIVORCE STIPULATION AND NOW, come the Plaintiff, Harry A. Gill, Jr., and the Defendant, Colleen D. Gill, together with their respective counsel, Michael R. Rundle, Esquire and James A. Miller, Esquire, and stipulate as follows: 1. The parties are husband and wife, having been lawfully joined in marriage on February 15, 1979, in Carlisle, Pennsylvania. 2. On September 15, 1995, the plaintiff, Harry A. Gill, Jr., filed an action in divorce against the Defendant, Colleen D. Gill, with the Court of Common Pleas of Cumberland County, Pennsylvania docketed to the above term and number. 3. Since the filing of said Complaint in divorce the parties have each continued to reside in the marital residence situate at 2745 Ritner Highway, Carlisle, Pennsylvania. 4. The defendant intends to leave the marital residence and to aake a claim against the plaintiff for alimony pendente lite. 5. The partie. agree that the plaintiff shall pay to the defendant as alimony pendente lite the sum of Four hundred fifty ($450,00) Dollars per month commencing with the month of ~ February, 1996, to be paid directly by plaintiff to the defendant, and not through the cumberland County Domestic Relations Office, said payments to be made on or about the first day of each month, with the February and March, 1996, payments made on or about March 1, 1996. provided, however, that should the plaintiff fail to make any monthly payment on or before the tenth day of the month, the parties agree that the Defendant shall have the right to have this obligation enforced through the Domestic Relations Office by means of a wage attachment. 6. The parties desire that the terms of this stipulation be incorporated into an Order of Court. IN WITNESS WHEREOF, the parties hereto set their and seals .A this"ZS day of February, 1996. witness: (\ " 1 \ ,^^\.lu~~) Q ~ \l Michael R. Rundle, ~B~ re ~Q,~~, Harry A. Gil , Jr. {Whp" /d dj} Colleen D. Gill [SEAL] ~./L [SEAL] /~ . .~ -Q . 0-'1 ~ - r{ i t ~ ~ .... N ;- i.. ~ C'J ~ '-,- t:, " ll.!. . <.' - - .' . l ~; . , _. ,- : .J c; , ,~ .., : j ~ .....' . L. ~ -: ':! , L. c , :) .., " , , ) HARRY A. GILL, JR., plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-4916 CIVIL TERM v. COLLEEN D. GILL, Defendant IN DIVORCE MUTUAL PRAECIPE TO WITHDRAW AND ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please withdraw my appearance on behalf of Plaintiff Harry A. Gill, Jr. in the above captioned matter. FOWLER, ADDAMS & RUNDLE Date: March 5 , 1997 \\'v' LtM,-& ~ Qv-Q~ Michael R. Rundle Supreme Court I.D. No. 27768 28 South Pitt Street P.O. Box 208 Carlisle, PA 17013 (717) 249-8300 By: Please enter my appearance on behalf of Plaintiff Harry A. Gill, Jr. in the above captioned matter. GRIFFIE & ASSOCIATES Date: March 5 , 1997 By: -Jtx-J , i'J e M. Sh ar Supreme Court I.D. . 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 '>.. ('J f" .~-.; . 1.1: ( ) L.:.: '1.....,- L~ 0 I (, I.. ; L - .j ~ I. - r-. . . .;.- 0 Ij- ;);).<1, PJ..^ t::.'-ACl'M v.A~ll l<onruJi fY1~ld NliG...u on 4.r)1-91 ~ oo.{h Qtl'1 ~ p-\'\ t Dt4, ':H':" ,,__.~_ t"",- . ',<':"j .'''1: -, ,-." , .'1.'."1" C'" ro...... . !. .'. . , (,:::1 " , (i,- ("....1'.....;1,'.' ;" """'.\ .. DR 26..18 I I'I.AINTIFF IN TilE COllin OF COMMON PLEAS OF ClIMIIEIU.AND ('OlINTY.I'ENNSYI.V ANIA COLLEEN D. 011,1., VS D( IMISIK I{UAIIONS SITTION l'IV11. A('IION. SIIl'I'ORT IIARRY A, (ill.1.. JR.. DEFENDANT NO. '15 (,(VII. 0\'116 ORDER (II' ATlAl'IlMENT (>F INCOME TO: PI'(i Intlnstries,lne.. 11'I'(i Phlce. 0\ N. Carlisle l'hnll, Pillshnr~h,l'ennsylvllnia 15272 AND NOW, this JJ!!L tlay Ill' Mav, 1'1'17, pursnant tlllhe 11IIVs Ill' the CllnllllllnlVelllth nr I'ennsylvania, the incllllle Ill' I 111m A, (iill, Jr.. tleli:ntlanVohlil!or. sllcial seenrily nUllIber 1'I6-48-405J ,nf 2745 Ritner Ilil!lmav, ('arlisle. Pennsvlvania 170 I J , is herehy allaehed tn Ihe fllllolVinl! extent. Y llU arc directed II' pay Illlhe Illlllleslic Relatillns Sectilln or Ihe ('nun Ill' ('llllllllon Pleas Ill' ('ulllberlallll ('llIl1lty. Ihe sum Ill' $ 5{1(UIO pCI' Illllnlh llulllr Ihe incnllle due the deli:ntlant/"hlil!"r. I\ithinlen ( (0) da) s alicr Ihc dale Ihe tleli:nd,mVllhlil!nr is paid. MlIke ch.,ck.s 1'1I)'lIbl., 10: UORll'!llic RcllllioRs Sc.-clioR I', O. 11,,\ J211 ('lIrUslc, l'eRRsyh'lInill 17111J Im:NnFY TillS I'A YMt:NT IIY l'I.AnN(; UR 26.381 ON YOUR ('m:CKII'A YMENT IIpon re<:eiplllHhc supporl paYlllelll.IIIl'Dllmeslic Relalilllls Ollke "ill distrihute lhe 11:I)lI1ellllls 1I.1I1111S: $ -150.00 $- $ 5(J.(lO $- $- PCI' llI11lllh per _ PCI' mllnlh PCI' _ PCI' _ Alimllll) Arreaml!c due I>I'A Arrcaml!e ,Iue Illainlil'f IIh.d I cst Cllsls Serl ke F<:I'sf( 'llsls $- $ 2.7U1UHI $- $- I his or,ler Ill' 1I11l1chmenlll.r sUPl'ol1 is hilllliul! IIpOIl )lluuutil flll1her lI11tice 1I11t1 shall Imle prior it) llvcr any ,1l1.lclullelll. escculillll.l!anllshlllelllllr I\ul!e ullucllllleuluntler st.lle or Illcalla\\ cscellllllle n:latilll! Illllllrill' sUl'llurlllrder. Y llll mllst cnllllllcn<:c Ihe 1I1111c1l1l1el1l11f the delCndal1lfllhlil!or's incllme as Sllon as 11IlSsihk hut nil hller Ihllnlimneen ( 1-1 I days lillllllhe date Ill' issu;lIlce Ill' Ihis llnler Ill' anuclllllcnl. Yuu arc lIulilil~llurlhl'r thut l'Uhllanl h. 1;1\\: I Ill' ,lckmlm'tfuhlil!ul has hl'l'n nulllk.lllml ,munkl III allaclnnellllill' SUllpll11 \\1,tlMI",' j"'h.',I. ~ , Wilrlllli,ilme 10 COlli pi) II ilh Ihis order l1Iay resllll ill II) your heillj! mljlldj!ed ill eOlllel1ll11 or wllrl ami eOl1ll1lilted lojnil or lilled h) Ihe ('Ollrl: III) )Ollr hcillj! held liahle Ii II 111I) a11l01l1l11l,,1 lIilhheld or Ililhheld hlllllollillll'artled 10 Ihe DOl1leslie 1{e1aliolls Seelioll, ami (III) altllclllllelll or )Ollr rllmb or pmperly. .1. ., he altaehl1lelll or illWllle or Ihe po"ihilil) Iherel1r ns n has is. ill whole I1r ill pari, tilr Ihe discharj!e 111' 111I el1lpll1yee or 111I) diseilllillnry aelioll nj!nillsl or del1ll1liolll1f all e11l11111)ee is pmhihiled. Violnlil1l1l11ay reslIlI ill (I) your hcillj! ndjlldj!cd ill wlllel1lpl nmt cOl1ll1liltcd III jail or lilled hy Ihe ('l1l1rl. nml (II) all nclioll nj!aillsl YIIlI hy Ihe el1lpl,,)ee 1i1l11:1II1n!!es. .1. Iflhere me ill your el1lpIO)l1Ielll. olle or I1Il1re mlllilil1l1nl el1lpll1)ees whose illcomes arc sllhieell" I1nler of Ihe ('l1l1rII1ITI1I11111011 PlellS I1ITul1lherlnlld ('I1UIII) lill nllnchl1lelll lill supp"rl. YOllma) cl1l11hille Ihe nll:1chl1lelll pnYl1lellls inlo n sinj!le pn)menl 1I1lhe 1>"l1Ieslic 1{e1alions Seclion nml seplllUlely idenlify Ihe porlil1n nltrihlllnhle 10 each I1hlij!or. 5. YI1U I1Il1sl nolil~ Ihc DOl1lcslk Kelnliolls Seclion \!hen Ihe dclcndmll/ohlij!l1r lerl1linales emlllo) menl mill prill ide Ihe DOl1leslic 1{c1ali"ns Seclil1n \\ ilh Ihe el1lplo)ee's lasl ~nll\\n addre" alld Ihe lIal1le nnd mldre" I1rlhe nel\ el1lpll1)er ir~II""I1. fl. I he l1Iasil1lul1l al1lollnl ollhe nltnchl1lenl shall nl1l cscc" 50% orlhe delcndanl's dislll1Sllhle enminj!s. 7. lhe Ie rill "incol1le" ns dclined h) 1:11\ includes comllClNllioll lill services, illcludillj! hlllllollimiled I,,; lIa!!CS, salmies. Ices, wmpellslllioll in ~ind. '-='ll1lmis\illll', and similar ilcllt'.: iUl.:\\Il1l' dcri\'cd fnl11l hll~inc": gains dcri\cd 1i-1111l delllillj!s in l"ollCrl): illleresl: rellts: r"Yllllies: dividends: llllnuilies: incol1le 1i-"l1Ililc insnrllllce mlll endolll1lcnl conlracls: alllillllls or relirel1lenl: pensions: inc"l1Ie rml1l discharj!e or indchlcdlle,,: dislrihuliw shllle or parlnership 111' j!lIlSS illCl1l11e: inwl1Ie in respecll1r decendelll: incl1l11e rr111111111 inleresl in nn eslale I1r Irllsl: l1Iilillll) relirel1lenlllCnclils: milmllll el1lployment reliremenl henelils: ""ial securil) IlCllelils: 1I:l1IpOIlIl) nnd IlCIIllllllent diSllhility henetits: \Hlr~men's cl1mpensali"n amlunemplo)l1Ienl eUl1IllClIsntiun: or olher enlitlemellls lomone) or IUIIlp s1II11 a'\ilnt..., \\ ilhulIl rCl!al'tllo ,Ulln:C. H. ^n lUder or nltnchl1lenllilr suppurl shnll hn\e l"iurilY Iller 111I) nltnclullenl. c:\l'\:utiun. llarni,llIn\.'nl. ",lillt..' ,'r Inc~III~" \\ ithhnldint.!. or "Hil"' all,u..:hmcnl. \'uu mllY' dl'dud from lhl' hlllllncl' due lhl' dl'fl'ndllnllln amounl l'lIUal 10 1"'0 percl'nl UO/oloflhl'amounlllaid for e1l'rical "ork and l'\IK'n!lt' in\ul\l'd in Cllmply'inK ,,'ilh lhl' onll'r jSl't' I'l'nnsy'hanill I..." 19H~, St'Clion ,U.&HI. c= ".J. , , I )KO K J 'shn,May cc I"my ,\. ("II. .Ii . lll-knllanl [)i'IJ "'. . \ \ \..\........"" l \ \'" L \,~ .. ell \('"~\'-'i-l ~- U) i.:t: lr. ;:..... " ,-. N 11-':- ,-) .- I . . '~-l t~4 '. -'j , I C , , '.:} ." r..' u I' - , --, , . Ij C:~ - -- ') " ,... U 0' d ~ . .. \ In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION COLLEEN D. GILL ) Ducket Number 95 CV 4916 Plaintiff ) VS. ) P ACSES Case Number 214000025 HARRY A. GILL ) Defendant ) Olher Stale ID Number Gl103~ I PETITION FOR MODIFICATION OF AN EXISTING SUPPORT ORDER 1. The petition of HARRY A. GILL respectfully represents that on MAY 12. 1997 , an Order of Coun was entered for the suppon of COLLEEN D. GILL A true and correct copy of the order is attached to this petition. Servke TYJle M Fonn OM.SOI Worker ID :nS04 , . J GILL v. GILL PACSES Case Numl>c:r: 214000025 2, Petitioner is entitled to 0 increase 0 decrease e-rermination 0 reinstatement o other of this Order because of the following material and substantial change(s) in circumstance: C\?v 10 ~ed WHEREFORE, Petitioner requests that the Coun modify the existing order for suppon, ~~it~' Anorney for Petitioner 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, ~ 4904 relating 10 unsworn falsification to authorities. "/1/# I f8 Date ~'-Q Q.~ ~. Petitioner Servile Tyrc: M Pa~e lilt 1 Film. ()M-~Ol Wilner II> 21504 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION COLLEEN D, GILL ) Dockel Number 95 c:v 4916 Plaintiff ) vs, ) PACSES Case Number 214000025 HARRY A, GILL ) Defendant ) Olher Slale ID Number ; .. -::-./ Order AND NOW to wit, this DECEMBER 7, 1998 it is hereby Ordered that: COLLEt"l'ION AND ENFORCEMENT OF THE ALIMONY ORDER IS SUSPENDED THROUGH THE DOMESTIC RELATIONS SECTION, PURSUANT TO THE PLAINTIFF'S WHEREABOUTS IS UNKNOWN AT THIS TIME. UPON PLAINTIFF REPORTING AN ADDRESS TO THE DRS, SHE MAY REQUEST THAT THE MATTER BE REVIEWED AND REOPENED FOR COLLECTION. DRO: R,J, ShddddY CC: pldlntlff & defenddnt EDWARD E, GUIDO, JUDGE Scrvke Type M Flinn OE.()()\ Wilner 10 21005 0 -r ~ N ~ -j f. 4 u-: /. ~ .. ~ J ;r ~ (.:_;~ ~ t5~" :-c r ',-'., - 'J it~ U- ");j :2 C:1C ..:.>- '0 _:T ., ...{) ~ Of;. .17.: 6 u..: ~. - .. , ~t" W :.~li:i ~ c: .' W 'Jel- i:" c:::: '':~; LL CAJ -5 a- 0 0' U c: In the Court of Cmulllon 1)lea.~ of IT:\IlIERL.\:"i1> County, Pennsylvania I>O:\lESTIC REL.\ TIO:-;S SECTJO:"i Defendant Name: HARRY A. GILL Member ID Number: 9141000025 l'Iealll: nnte: All torn."pnndl'IKC IUll\t lncludc the ~h.1JIber IJ) 7\uwhcr. PPG INDUSTRIES, INC. 1 PPG PLACE 4N CARLISLE PLANT PITTSBURGH PA 15272-0001 ORDER - TERMINATION OF INCOME ATIACHMENT Plaintiff Name COLLEEN D. GILL Financial Break Down of Multiole Cases on Allaehmenl PACSES Do<kel C... Number t!l!m!!g 214000025 95 CV 4916 Attachment Amount/FreQuencv S 154. 00 IMONTH S ~ ~ 1 S 1 S I ~ ~ S 1 S I TOTAL ATTACH\IE:\T A\lOt::\T: S 1134.00 TO: PPG INDUSTRIES, INC. AND NOW, this 7TH DAY OF DECEMBER, 1998 the Income Attachment Order dated in the amount of $ 154 .00 for MAY 13, 1997 HARRY A. GILL , 196-48-4053 is hereby TERMINATED, Effective immediately, you are directed to cease all payments and collections from the income of Defendant which were authorized by said Order, BY THE COURT: Date of Order: Edward E. G~ld" JUDGE DRO: R.J. Shadday X~: . d.u~nd..nl ~(t';:.( Type 'M Fnnll EN'()32 Wnrk(r ID H005 ,r >- .d 0 ~ N 8: It: r::; ~ ~ :-j .,--r" ~~-) C'"; . . ~ :. ; 1 ::: ...) ~;~ -;? --r_t ~;. a.. ~ -::! . ~ ~ , ..:J' en v L: "I.>: [j . '':~':' .~ Q:l! ' c..o JUJ Lt.. ~1 c... ~ Co i--- I.L. lI) .:.> <:> cr. u ~ In the Court or Common Pleas or CUMBERLAND County, Pennsylvania DOMESTIC REl.A T10SS SECTION P,O, BOX 310, CARl.1Sl.E, PA. 11013 Phone: (1171 %40-6225 Fax: (717) 140-6248 Derendanl Name: HARRY A. GILL Member ID Number: 9141000025 Pleue D".: AD CDmspoadeact ....I IDdad. Iht Mooabor 1D Soaabor, ORDER TO VACATE ATTACHMENT OF UNEMPLOYMENT BENEFITS Financial Break Down of Multlole Cases on Altachment Plaintitr N.me COLLEBN D. GILL PACSES else Number 214000025 Dock<! ~ 95 CV 4916 i $ $ I $ 35.44 IWBU ~ I 1 ~ 7 I 1 AUlchmenl Amoun1lFreauencv D26,38l TOTAL ATIACHME.'T AMOUm': $ 35.44 The prior Order or this Court directing the Department of Labor and Industry. Bureau of Unemployment Compensation Benefits and Allowances (BUCBA), to attach $ 35.44 or 55 % per week of the Unemployment Compensation benefits of HARRY A, GILL . Social Security Number 196-48-4053 , Member ID Number 9141000025 is hereby vacated, This Order to Vacate shall be effective upon receipt by the Department and shall remain in effect until a further Order of the Court is filed, BY THE COURT Date of Order: 12-22-98 JUDGE Edw,Hd E. GJldu Sc:rvkc TyJ'C M Form EN'()J~ Worker to $IATT 11 \l'I/T!! , '-'I'~" ,-~-, \ hI ..., >- C} - t'r" (= , " , t: ,! " , u' - .-.t H-~: < C): .-. i \ a (:, 1.:...1. ("') . ;:-~~ L' i"Li w- I' , c: ;1. l' c: -) 1_..-' CP 0