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HomeMy WebLinkAbout02-4451MARY M. SHANKLE : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. MARK A. YOHE, Defendant CIVIL ACTION - LAW NO. 06Z IN DIVORCE NOTICE 7 4.5 i CIVIL TERM You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Streets, Carlisle. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone: (717) 249-3166 MARY M. SHANKLE : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW NO. CIVIL TERM MARK A. YOHE, Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Mary M. Shankle, an adult individual, who currently resides at 273 Plaza Drive, Boiling Springs, Cumberland County, Pennsylvania. 2. Defendant is Mark A. Yohe, an adult individual, who currently resides at 1601 York Road, Carlisle, Cumberland County, Pennsylvania, since 1997. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. The Plaintiff and Defendant are married by principals of common law, and have been married since at least October 1, 1980 when Plaintiff and Defendant lived in Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available, and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree of Divorce. COUNT II Request for Equitable Distribution Under Section 3502 of the Divorce Code 9. Paragraphs I through 8, of Plaintiff's Complaint are incorporated herein by reference. 10. Plaintiff and Defendant have acquired property, both real and personal during their marriage. 11. Plaintiff and Defendant have been unable to agree as to an equitable distribution of said property. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an Order distributing all of the aforementioned property, real and personal, as the Court may deem equitable and just, plus costs. COUNT III Request for Alimony Pendente Lite and Alimony Under Section 3701 and Section 3702 of the Divorce Code 12. Paragraphs 1 through 11 of Plaintiffs Complaint are incorporated herein by reference. 13. Plaintiff is unable to sustain herself during the course of this litigation. 14. Plaintiff lacks sufficient property to provide for her reasonable needs and is unable to sustain herself through appropriate employment. 15. Plaintiff requests the Court to enter an Award of Alimony Pendente Lite until final hearing, and thereupon to enter an Order of Alimony in her favor, pursuant to Section 3701 and Section 3702 of the Divorce Code. 16. Defendant requires reasonable support to adequately maintain herself in accordance with the standards of living established during the marriage. WHEREFORE, Defendant respectfully requests the Court to enter an award of Alimony Pendente Lite until final hearing, and thereupon to enter an Order of Alimony in her favor, pursuant to Section 3701 and Section 3702 of the Divorce Code. ANDREWS & JOHNSON By: for P. Andrews, Esq. >rney for Plaintiff 78 W. Pomfret Street Carlisle, PA 17013 (717) 243-0123 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 to unswom falsification to authorities. Date: / 02 Mary Y. Shankle, Plaintiff MARY M. SHANKLE : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. `'° - 7 `YS CIVIL TERM MARK A. YOHE, Defendant : IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Mary M. Shankle, Plaintiff, to proceed in forma an uperis. I, Taylor P. Andrews, attorney for the party proceeding in forma ap uperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The parry's affidavit showing inability to pay the costs of litigation is attached hereto. Date: (: -16 O ?yl P. Andrews, Esquire At rney for Plaintiff 8 West Pomfret Street Carlisle, PA 17013 (717) 243-0123 Supreme Court ID: 15641 FILE Na.448 00/13 '02 14:32 '.D:h'Pl.S CIPPLISLE OFFICE FAX:7172438028 PAGE 2 Mary M S 411 k (C- : IN THE COURT OF COMMON PLEAS OF Plaintiff ; CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION vs, Mask /? I/OAe Defendant APFIDAYIT IN SUPPORT OF PETITIQN FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am the plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding, 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. 1 represent that the information below relating to my ability to pay the fees and costs is true and correct. / (a) Name: _ ?/4,R M _ STIR ? /k fe I Address: 073 Pi4zq ,lfy 864/4?S ?cNfs f"?`/ 17607 (b) Social Security Number: If you are presently employed, state Employer; Address: Salary or wages per month: Type of work: If you are presently unemployed, state Date of last employment: . Somwe r ZOO f FILE No.448 09/13 '02 14:33 IU:I1PLS CARLISLE OFFICE FAU:7172438026 PAGE Salary or wages per month: v14K-'t0'"I--k Type of work: 4? kC55 D.5Irc bJ7 0 (? mss f? w Pa roc Y Q?tp?oy?te?? afe&tcy, - L,40rer (c) Other income within the past twelve months Business or profession: Other self-employment: /e4.1 a7[ Go ?5 St' s C4ape ( C4 ?rCk Cr-j P)r Z (.0?4eouitPr5 der ?)eek 7rbs. Interest: 0 Dividends: 0 Pension and annuities: Social Security benefits: O Support payments: C Disability payments: 0 Unemployment compensation and p supplemental benefits: Workman's compensation: Public Assistance: p Other: Q (d) Other contributions to household support (Wife)(Husband) Name: 1v ae- k A-- Yo4 e If your (husband) (wife) is employed, state Employer: &'1.1 /er t'a.1/ Oa) N?r Salary or wages per month: OCA k?CWJ Type of work: (2,(er(<?T?/1QST (? FILE No.448 09/13 '02 1433 ID:rPLS CARLISLE OFFICE Contributions from children: C? (e) Property owned Cash:E j- Checking Account: l 1.3 0_ ot) Savings Account: ZS 60 Certificates of Deposit: 0 // Real Estate (including home): ye5 - poi ?t Motor vehicle: Make GMKW Year FAX:7172438026 PAGE 4 (0,-(l., ho'kKd J4((Je o4-4,1U)y.. Cost - Amount owed I S-? cT-? P-e f- Stocks; bonds: d Other: Poo"-/-/4 (f) Debts and obligations / Mortgage: ?e-s - alwtav T Ije UK L 6 W Rent: 7/q? Per Ma.c??i - A/YQ S45eC4z Loans: /I- Monthly Expenses: rr //-Q )<Ce ?c 'a' -1 ej- ??Ob ct'r S? fay l As - P?°??-`? ?Te (g) Persons dependent upon you for support (Wife) (Husband) Name: Children, if any: Name: Age: FILE No.448 09/18 '02 14:84 ?D:MPS CAPLISLE OFFICE FAX:7172438026 PAGE 5 4, 1 understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein, 5. 1 verify that the statements made in this affidavit are true and correct. I understand that false statements heroin are made subject to the penalties of 18 Pa, C.S. 4904, relating to unsworn falsification to authorities, Date: q /? C9 r + ? C ?_ i -? .,J _ _ -i is i ?? _'? - `1 tJl -, MARY M. SHANKLE : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 02-4451 CIVIL TERM MARK A. YOHE, : Defendant : IN DIVORCE PRAECIPE I request that the attached Motion for processing of the claim of Alimony Pendente Lite, this claim be referred to the Cumberland County Domestic Relations Office for processing. & JOHNSON By: i) or P. Andrews, Esq., Attorney for Plaintiff 8 W. Pomfret Street Carlisle, PA 17013 (717) 243-0123 MARY M. SHANKLE : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 02-4451 CIVIL TERM MARK A. YOHE, Defendant : IN DIVORCE MOTION FOR HEARING AT DOMESTIC RELATIONS OFFICE ON CLAIM FOR ALIMONY PENDENTE LITE Mary M. Shankle, by her attorney, Taylor P. Andrews, Esq., respectfully represents: 1. A Divorce Complaint in the above captioned action was filed on September 17, 2002. 2. Count III of the Divorce Complaint requested Alimony Pendente Lite. (A copy of the Divorce Complaint is attached hereto as Exhibit 1). 3. The above referenced Divorce Complaint was served upon the Defendant, Mark A. Yohe, by certified mail, return receipt requested on September 23, 2002. 4. DRS attachment for APL proceedings is attached to this Motion as Exhibit 2. 5. Plaintiff now seeks to have the claim for Alimony Pendente Lite processed for enforcement by the Cumberland County Domestic Relations Office. WHEREFORE, Plaintiff prays that the claim for Alimony Pendente Lite expressed in the Complaint filed in the above captioned action be referred to the Cumberland County Domestic Relations Office for processing. ANDREWS By: Ta ArVkws, Esq., Attorney for Plaintiff 7 W omfret Street Carlisle, PA 17013 (717) 243-0123 MARY M. SHANKLE : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. MARK A. YOHE, Defendant : CIVIL ACTION - LAW NO. CIVIL TERM IN DIVORCE NOTICE 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 maybe entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary.at the Cumberland County Court House, High and Hanover Streets, Carlisle. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE-RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone: (717) 249-3166 n -?_ C7A n r, C'3 E EXHIBIT I n -r MARY M. SHANKLE : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION LAW : NO. CIVIL TERM MARK A. YOHE, Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Mary M. Shankle, an adult individual, who currently resides at 273 Plaza Drive, Boiling Springs, Cumberland County, Pennsylvania. 2. Defendant is Mark A. Yohe, an adult individual, who currently resides at 1601 York Road, Carlisle, Cumberland County, Pennsylvania, since 1997. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. The Plaintiff and Defendant are married by principals of common law, and have been married since at least October 1, 1980 when Plaintiff and Defendant lived in Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available, and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree of Divorce. COUNT II Request for Equitable Distribution Under Section 3502 of the Divorce Code 9. Paragraphs 1 through 8, of Plaintiffs Complaint are incorporated herein by reference. 10. Plaintiff and Defendant have acquired property, both real and personal during their marriage. 11. Plaintiff and Defendant have been unable to agree as to an equitable distribution of said property. WHEREFORE, Plaintiffrespectfully requests this Honorable Court to enter an Order distributing all of the aforementioned property, real and personal, as the Court may deem equitable and just, plus costs. COUNT III Request for Alimony Pendente Lite and Alimony Under Section 3701 and Section 3702 of the Divorce Code 12. Paragraphs 1 through 11 of Plaintiff's Complaint are incorporated herein by reference. 13. Plaintiff is unable to sustain herself during the course of this litigation. 14. Plaintiff lacks sufficient property to provide for her reasonable needs and is unable to sustain herself through appropriate employment. 15. Plaintiff requests the Court to enter an Award of Alimony Pendente Lite until final hearing, and thereupon to enter an Order of Alimony in her favor, pursuant to Section 3 701 and Section 3702 of the Divorce Code. 16. Defendant requires reasonable support to adequately maintain herself in accordance with the standards of living established during the marriage. WHEREFORE, Defendant respectfully requests the Court to enter an award of Alimony Pendente Lite until final hearing, and thereupon to enter an Order of Alimony in her favor, pursuant to Section 3701 and Section 3702 of the Divorce Code. ANDREWS & JOHNSON By: YAlor P. Andrews, Esq. /attorney for Plaintiff 78 W. Pomfret Street Carlisle, PA 17013 (717) 243-0123 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 to unsworn falsification to authorities. Date: q11 --3 /02 ajA.41 " NAUJ& Mary Y. Shankle, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARY M. SHANKLE CIVIL ACTION - LAW Plaintiff NO. 02-4451 CIVIL TERM vs MARK A. YOHE Defendant IN DIVORCE DRS ATTACHMENT FOR APL PROCEEDINGS PETITONER NAME Ma M. Shankle ADDRESS 273 Plaza Drive, 8 BIRTH DATE February 27, 1952 SOCIAL SECURITY NUMBER HOME PHONE 717-249-3273 WORK PHONE n/a EMPLOYER NAME n/a EMPLOYER ADDRESS n/a JOB TITLE/POSITION n/a DATE EMPLOYMENT COMMENCED n/a GROSS PAY receipts as cleani NET PAY OTHER INCOME ATTORNEY'S NAME Taylor P. Andrew ATTORNEY'S ADDRESS 78 West Pomfret ATTORNEY'S PHONE NUMBER 717-243-0123 PA 17007 woman PA 17013 EXHIBIT 7 BIRTH DATE SOCIAL SECURITY NUMBER HOME PHONE WORK PHONE EMPLOYER NAME EMPLOYER ADDRESS JOB TITLE/POSITION DATE EMPLOYMENT COMMENCED GROSS PAY NET PAY OTHER INCOME ATTORNEY'S NAME ATTORNEY'S ADDRESS ATTORNEY'S PHONE NUMBER RESPONDENT Mark A. Yohe 1601 York Road, CE December 27, 1957 unknown unknown 717-249-2929 Cumberland Couni 33 Westminister D unknown unknown none identified PA 17013 Board of Assistance re. Carlisle, PA 17013 MARRIAGE INFORMATION DATE OF MARRIAGE 1common law PLACE OF MARRIAGE Pennsylvania DATE OF SEPARATION June 1, 2002 ADDRESS OF LAST MARITAL HOME 1601 York Road, Cai DESCRIPTION OF DOCUMENT RAISINISeptember divorce com taint DATE APL DOCUMENT FILED 17, 2002 PA 17013 CD ?Tl MARY M. SHANKLE, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 2002-4451 CIVIL TERM MARK A. YORE, IN DIVORCE Defendant/Respondent Pacses# 550105322 ORDER OF COURT AND NOW, this 13`h day of February, 2003, upon consideration of the attached Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shaddav on Apri19, 2003 at 10:30 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11© (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, George E. Hoffer, President Judge Mail copies on Petitioner 3-13-03 to: < Respondent Taylor Andrew, Esquire Date of Order: March 13, 2002 el - . J. dda, Conference Officer YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 &Iel& ? cy `?' c A, _ <_ ?? ?- , . r, , l i ?_ ? ? y E? ?? .-? ?`? ?. -1 '? ?`_... ?.,ty .,+? ( ?? .? - -_ 1 -. %.? ?_ _ -^, '?' =? .? In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION MARY M. SHANKLE ) Docket: Number 02-4451 CIVIL Plaintiff ) VS. ) PACSES Case Number 550105322 MARK A. YOHE ) Defendant ) Other State ID Number ORDER OF COURT You, MARK A. YOHE plaintiff/defendant of 1601 YORK RD, CARLISLE, PA. 17013-9235-01 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the n -q JUNE 11, 2003 at 1: 3 O PM for a hearing. N 3 a Mme' You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, includin - filedtom,, 2. your pay stubs for the preceding six (6) months, 3. verification of child care expenses, and 4. proof of medical coverage which you may have, or may have available ? to you ctb. 5. information relating to professional licenses 6. other: Form CM-509 Service Type M Worker ID 21302 1,1 NV •U SHANKLE v. YOHE PACSES Case Number: 550105322 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: ,?- ?- C E YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP: CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Service Type M Worker ID 21302 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION MARY M. SHANKLE ) Docket Number 02-4451 CIVIL Plaintiff ) VS. ) PACSES Case Number 550105322 MARK A. YOHE ) Defendant ) Other State ID Number ORDER OF COURT You, MARY M. SHANKLE plaintiff/defendant of 273 PLAZA DR, BOILING SPRINGS, PA. 17007-9433-73 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the Gv JUNE 11, 2003 at 1: 3 0 PM for a hearing. You are further required to bring to the hearing: ls,N, 1. a true copy of your most recent Federal Income Tax Return, including W- , . your pay stubs for the preceding six (6) months, 42 2 3. verification of child care expenses, and 4. proof of medical coverage which you may have, or may have available to you 5. information relating to professional licenses 6. other: Form CM-509 Service Type M Worker ID 21302 tr??J?r'P;?,?.?1N?d P?I,?i .., - ? - .ei »r?. SHANKLE v• YOHE PACSES Case Number: 550105322 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which parry initiated the support action. BY THE COURT: -? -03 „ ° a Date of Order: JUD E YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP: CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 2 4 0 - 6 2 2 s . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Service Type M Worker ID 21302 MARY M. SHANKLE : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. MARK A. YOHE, Defendant CIVIL ACTION - LAW NO. 02-4451 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 17, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Date: ?J Cd'a? Mary M. S le, Plaintiff C7 ? €? cY ? -? ?? ?.:! {_? . • 1 1? f ? ? ..? MARY M. SHANKLE : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. MARK A. YORE, Defendant CIVIL ACTION - LAW NO. 02-4451 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST 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 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. §4904, relating to unworn falsification to authorities. Date: - - d j Mary M. Sha le, Plaintiff „ ? ?i ? ? C c? ? - ? ? „? ?. ?? .rws L ? ?7 < ? ° PJ, 4 mar ??. yV MARY M. SHANKLE V. MARK A. YOHE, IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Defendant TO THE PROTHONOTARY: NO. 02-4451 IN DIVORCE PRECIPIE CIVIL TERM Please file the attached "Separation And Property Settlement Agreement" of record in the above captioned action. & JOHNS By Ta)lor p. Andrews, Esq. ttorney for the Plaintiff 78 W. Pomfret St. Carlisle, PA 17013 717 243-0123 SEPARATION AND PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT made this day of T 2005, by and between MARK A. YOHE, of 1601 York Road, Carlisle, Cumberland County, Pennsylvania, parry of the first part, hereinafter referred to as "Husband," AND MARY M. aSH41VKLE, of 273 Plaza Drive, Boiling Springs, Cumberland County, Pennsylvania, party of the second part, hereinafter referred to as "Wife," WITNESSETH: WHEREAS, Husband and Wife were married on October 1, 1980, in Dauphin County, Pennsylvania; and WHEREAS, Husband and Wife are residents of the Commonwealth of Pennsylvania and have been so for at least the past six months; WHEREAS, certain differences have arisen between the parties hereto which have made them desirous of living separate and apart from one another; and WHEREAS, Husband and Wife desire to settle and determine certain of their marital rights and obligations, and make an equitable distribution of their marital property, determine their rights to alimony and support and any other matters which may be considered under the Divorce Code; and WHEREAS, it is the intention and purpose of this Agreement to set forth the respective rights and duties of the parties while they continue to live apart from each other and to settle all financial and property rights between them; and --Page 1 of 15-- WHEREAS, the parties hereto have mutually entered into an agreement for the division of their jointly owned assets, the provisions for the liabilities they owe, and provisions for the resolution of their mutual differences, after both have had full and ample opportunity to consult with attorneys of their respective choice, the parties now wish to have that agreement reduced to writing. NOW, THEREFORE, the parties hereto in consideration of the mutually made and to be kept promises set forth hereinafter and for other good and valuable consideration, and intending to be legally bound and to legally bind their heirs, successors, assigns, and personal representatives, do hereby covenant, promise and agree as follows: ARTICLE I SEPARATION 1.1 It shall be lawful for Husband and Wife at all times hereafter to live separate and apart from each other and to reside from time to time at such place or places as they shall respectively deem fit free from any control, restraint, or interference, direct or indirect, by each other. Neither party shall molest the other or compel or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceedings. The foregoing provisions shall not be taken to be an admission on the part of either Husband or Wife of the lawfulness of the causes leading to them living separate and apart. ARTICLE II DIVORCE 2.1 This Agreement is not predicated on divorce. It is specifically understood and agreed by and between the parties hereto that each of the said parties does hereby warrant and represent to --Page 2 of 15-- the other that the execution and delivery of this Agreement is not predicated upon nor made subject to any agreement for institution, prosecution, defense, or for the non-prosecution or non- defense of any action for divorce; provided, however, that nothing contained in this Agreement shall prevent or preclude either of the parties hereto from commencing, instituting or prosecuting any action or actions for divorce, either absolute or otherwise, upon just, legal and proper grounds; not to prevent either party from defending any such action which has been, may, or shall be instituted by the other party, or from making any just or proper defense thereto. It is warranted, covenanted, and represented by Husband and Wife, each to the other, that this Agreement is lawful and enforceable and this warranty, covenant, and representation is made for the specific purpose of inducing Husband and Wife to execute the Agreement. Husband and Wife each knowingly and understandingly hereby waive any and all possible claims that this Agreement is, for any reason, illegal, or for any reason whatsoever of public policy, unenforceable in whole or in part. Husband and Wife do each hereby warrant, covenant and agree that, in any possible event, he and she are and shall forever be estopped from asserting any illegality or unenforceability as to all or any part of this Agreement. 2.2 It is further specifically understood and agreed that the provision of this Agreement relating to the equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever. Should either of the parties obtain a decree, judgment or order of separation or divorce in any other state, country, or jurisdiction, each of the parties to this Agreement hereby consents and agrees that this Agreement and all its covenants shall not be affected in any way by any such separation and divorce. --Page 3 of 15-- Z3 This Agreement shall survive any decree in divorce and shall be forever binding and conclusive on the parties. It is understood by and between the parties that this Agreement shall be incorporated into any decree, divorce or separation, but it shall not be deemed merged in such decree. ARTICLE III EQUITABLE DISTRIBUTION OFMARITAL PROPERTY 3.1 The parties have attempted to divide their marital property in a manner which conforms to the criteria set forth in the Pennsylvania Divorce Code, and taking into account the following considerations: the length of the marriage; the prior marriages of the parties; the age, health, station, amount and sources of income, vocational skills, employability; estate, liabilities, and needs for each of the parties; the contribution of one party to the education, training or increased earning power to the other party; the opportunity of each party for future acquisition of capital assets and income; the sources of income of both parties, including but not limited to medical, retirement, insurance or other benefits; the contribution or dissipation of each part in the acquisition, preservation, depreciation, or appreciation of marital property, including the contribution of a party as a homemaker; the value of the property set apart to each party; the standard of living of the parties established during their marriage; the economic circumstances of each party, including federal, state and local tax ramifications, at the time of the division of the property is to become effective; and whether the parties will be serving as the custodian of any dependent minor children. --Page 4 of 15-- 3.2 The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets and the division is being effected without the introduction of outside funds or other property not constituting marital property. The division of property under this Agreement shall be in full satisfaction of all rights of equitable distribution of the parties. 3.3 Personal Property. The parties acknowledge that they have divided their personal property, tangible and intangible, to their mutual satisfaction. The parties acknowledge that they have the cash, accounts, furniture, appliances, guns, and other personal property, tangible and intangible, in their possession that they wish to have and retain from this time forward. Neither parry shall make any claim whatsoever against the personal property in the other party's possession or assets in that other party's possession from the time of execution of this Agreement forward. 3.4 Life Insurance. Each party agrees that the other party shall have sole ownership and possession of any life insurance policies owned by the other. Each party shall have the right to borrow against, cash in policies, change beneficiaries, an exercise any other incidents of ownership of the respective policies free of any right or claim by the other party. Each party agrees to sign any documents necessary to waive, relinquish or transfer any rights in such policies to the respective party who presently owns such policies. 3.5 Subsequently Acquired Property. Husband and Wife agree to waive and relinquish any and all right that he or she may now have or hereafter acquire in any real or tangible personal --Page 5 of 15-- property subsequently acquired by the other parry. Husband and Wife specifically agree to waive and relinquish any right in such property that may arise as a result of the marriage relationship. 3.6 Real Estate. The parties are joint owners of real estate located at 1601 York Road, Carlisle, Cumberland County, Pennsylvania. This property is encumbered with a mortgage due and owing to USDA Rural Housing Service. Wife agrees that contemporaneously with the execution of this Agreement, she will execute a Deed conveying all of her right, title and interest in the aforesaid real estate to Husband by fee simple general warranty deed. Wife shall then make no claim of any nature whatsoever relative to any legal or equitable interest in the aforesaid real estate. From the date of execution and delivery of the Deed forward, Husband shall be solely and exclusively responsible for the repayment of the aforesaid mortgage due and owing to USDA Rural Housing Service and shall make each such monthly payment due hereunder when and as payments are due, including any and all interest, late charges, and the like. Husband shall indemnify Wife and hold him harmless from and against any and demands for payment or collection activity of any nature whatsoever on account of the aforesaid mortgage from the date of signing and delivery of the aforesaid Deed forward. Currently the aforesaid mortgage account is in foreclosure. Husband agrees to be responsible for any and all charges that may arise from the aforesaid foreclosure and shall indemnify Wife from the same. 3.7 Pension, Retirement. Pror -Sharing. Wife agrees to waive, relinquish or transfer any and all of her right, title and interest she has or may have in Husband's retirement account, deferred compensation account, IRA, pension and the like through his employment with --Page 6 of 15-- Pennsylvania State Department of Public Welfare. Wife hereby waives, relinquishes and transfers any and all right, title and interest she has in this retirement account, as well as any other accounts that Husband may have in his individual name or may have secured through his present or prior employment. Husband agrees to waive, relinquish or transfer any and all of his right, title and interest he has or may have in Wife's present retirement account, as well as other accounts that Wife may have in her individual name or may have secured through her present or prior employment. 3.8 Vehicles. The parties acknowledge that Wife has and shall retain a 1996 Pontiac vehicle which was originally titled in the parties' names jointly. The aforesaid vehicle is encumbered with a loan due and owing to . From the date of execution of this Agreement forward, Wife be solely and exclusively responsible for the repayment of the aforesaid loan ad shall make each monthly payments due hereunder when and as payments are due, including any and all late charges and the like. Wife shall indemnify Husband and hold him harmless from and against any and all demands for payment or collection activity or any nature whatsoever on account of the aforesaid loan from the date of execution of this Agreement forward. Husband shall transfer title of this vehicle to Wife's name individually when Wife satisfies this loan in fully or at such time as the vehicle is sold. From the date of execution of this Agreement forward, Husband shall make no claim whatsoever relative to access to or use of the aforesaid vehicle and shall make no ownership claims of any nature whatsoever to the aforesaid vehicle. --Page 7 of 15-- 3.9 Intangible Personal Property. The parties have already transferred or waived rights and interest in other intangible personal property, including their various bank accounts, credit union accounts, and the like. Each party agrees to sign any documents necessary to close any joint accounts within fifteen (15) days of signing this Agreement. Neither party shall make any claim of any nature whatsoever against the other party relative to the financial accounts or other investments or intangible personal property that have already been retained by that party as described herein. ARTICLE IV DEBTS OF THE PARTIES 4.1 The parties agree to each maintain sole and exclusive responsibility and obligation for the repayment of any debt listed in their individual names. The parties are not aware of any debts listed in their names jointly. In the event any debt exists which lists both parties as responsible parties, Husband and Wife shall share equally in the responsibility for the repayment of the debt such that each party shall assume responsibility for half of the debt balance as of the date of execution of this Agreement. The parties shall refinance their half of the debt to an account in their individual names within thirty (30) days of discovering said debt. 4.2 Each party represents to the other that except as is otherwise set forth in this Agreement, and more particularly as set forth in subparagraph 4.1 above, there are no major outstanding obligations of the parties; that since the separation neither party has contracted or any debts for which the other will be responsible and each party indemnifies and holds harmless the other for all obligations separately incurred or assumed under this Agreement. --Page 8 of 15-- ARTICLE V ALIMONY, APL, SPOUSAL SUPPORT AND MAINTENANCE 5.1 Alimony. Husband shall pay to Wife as alimony the sum of ONE HUNDRED THIRTY- EIGHT AND 501100 ($138.50) DOLLARS per month beginning with the month following the date of the entry of a Decree in Divorce, for twenty-four (24) consecutive months, at which time all such payments shall cease if they have not previously terminated as provided herein. Husband's obligation to pay under this paragraph will end and he will be released from the obligation of payment upon the death of either party, the cohabitation or remarriage of Wife or upon the twenty-fourth (24th) payment of ONE HUNDRED THIRTY-EIGHT AND 501100 ($138.50) DOLLARS, which ever occurs first. Wife's estate, successors, or heirs shall have no rights to payments to be made subsequent to Wife's death. 5.2 The parties herein acknowledge that except for the provisions set forth above, they have each secured and maintained substantial and adequate funds with which to provide themselves with sufficient resources to provide for their own comfort, maintenance and support in the station in life to which they are accustomed as well as to provide for the appropriate needs of their children. Husband and Wife do hereby waive, release and give up any rights they may have respectably against the other for alimony, alimony pendent lite, spousal support, and maintenance except as otherwise provided for herein. --Page 9 of 15-- ARTICLE VI MISCELLANEOUS PROVISIONS 6.1 Advice of Counsel. The parties acknowledge that they have either received independent legal advice from counsel of their own selection, that they fully understand the facts and have been fully informed as to their legal rights an obligation or otherwise understand those legal rights and obligations. They acknowledge and accept that this Agreement is, in the circumstances, fair and equitable, that it is being entered into freely and voluntarily, after having received such advice and with such knowledge that execution of this Agreement is not the result of any duress or undue influence, and further that it is not the result of any collusion or improper or illegal agreement or agreements. 6.2 Mutual Release. Husband and Wife each do hereby mutually remise, release, quitclaim, and forever discharge the other and the estate of such other, for all times to come and for all purposes whatsoever, of and from any and all right, 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 situate, which he or she now has or at any time hereafter may have against such other, the estate of such other, or any part thereof, whether arising out of any former acts, contracts, engagements, or liabilities of such other as 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 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 --Page 10 of 15-- States, or (c) any other country, or any rights which either party may have or at any time hereafter have for past, present, or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof. It is the intention of Husband and Wife to give to each other by execution of this Agreement a full, complete, and general release with respect to any and all property of any kind or nature, real or personal, not 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 thereof. 6.4 Warranties. 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 indemnify or hold the other party harmless from and against any and all such debts, liabilities or obligations of every kind, including those for necessities, except for the obligations arising out of this Agreement. Husband and Wife each warrant, covenant, represent and agree that each will, now and at all times hereafter, save harmless and keep the other indemnified from all debts, charges, and liabilities incurred by the other after the execution date of this Agreement, except as is otherwise specifically provided for by the terms of this Agreement and that neither of them hereafter incur any liability whatsoever for which the estate of the other may be liable. --Page 11 of 15-- 6.5 No waiver or modification of any of the terms of this Agreement shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 6.6 Husband and Wife covenant and agree that they will forthwith execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper implementation of this Agreement, and as their respective counsel shall mutually agree should be so executed in order to carry fully and effectively the terms of this Agreement. 6.7 This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date of the execution of this Agreement. 6.8 This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 6.9 This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. 6.10 Severability. If any term, condition, clause, section, or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, --Page 12 of 15-- 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. Likewise, the failure of any party to meet his or her obligation under any one or more of the articles and sections herein shall in no way void or alter the remaining obligations of the parties. 6.11 It is specifically understood and agreed that this Agreement constitutes the equitable distribution of property, both real and personal, which was legally and beneficially acquired by Husband and Wife, or either of them, during the marriage as contemplated by the Divorce Code of the Commonwealth of Pennsylvania. 6.12 Disclosure. The parties each warrant and represent to the other that he or she has made a full and complete disclosure to the other of all assets of any nature whatsoever in which party has an interest, of the sources, and amount of the income of such party of every type whatsoever, and all other facts relating to the subject matter of this Agreement. 6.13 Enforceability and Consideration. This Agreement shall survive any action for divorce and decree of divorce and shall forever be binding and conclusive on the parties; and any independent action may be brought, either at law or in equity, to enforce the terms of the Agreement by either Husband or Wife until it shall have been fully satisfied and performed. The consideration for this contract and agreement is the mutual benefits to be obtained by both of the parties hereto and the covenants and agreements of each of the parties to the other. The adequacy of the consideration for all agreements herein contained is stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound hereby. In the event either party breaches --Page 13 of 15-- the aforesaid Agreement and it is determined through appropriate legal action that the alleged party has so breached the Agreement, the breaching party shall be responsible for any and all attorney's fees as well as costs and expenses associated with litigation incurred by the non- breaching party to enforce this Agreement against the breaching parry. In the event of breach, the non-breaching party shall have the right, at his or her election, to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her including equitable enforcement of this Agreement. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. WITNESSED BY: Date MARK A. YOHE 6 -,g -d JM a.A4 JL&U &? Date MARY . SHANKLE --Page 14 of 15-- COMMONWEALTH OF PENNSYLVANIA COUNTY OF P i (ja On this. a??day of 2005, before me, the undersigned officer, personally appeared Mark A. Yohe, known to me (or satisfactory proven) to be the person whose name is subscribed to the within document and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. v- ? Notary Public NOTARIAL SEAL "BIN J. GOSHORN, NOTARY PUBLIC CARLISLE BORO., CUMBERLAND COUNTY MY COMMISSION EXPIRES APRIL 17 2001 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CC. Oi ? T On this F day of I1 Ung.- 2005, before me, the undersigned officer, personally appeared Mary M. Shankle, known to me (or satisfactory proven) to be the person whose name is subscribed to the within document and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. NOTARIAL SEAL SHELLY SEXTON, Notary Public Carlisle Eioro, Cumberland County My Commission Expires April 26, 2007 --Page 15 of 15-- .? ,. T ?--, e? .?. -; <_?_ - C.:.% -?, ,ti :f:. __ V.? -n .? . -,-, _'?„ +'4 ??r -3,"; •_-{ tY ,._-.y .-C; MARY M. SHANKLE : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. MARK A. YOHE, Defendant CIVIL ACTION - LAW NO. 02-4451 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(r.) of t;ie Divorce Code was filed on September 17, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unworn falsification to authorities. Date: ?'oZ y U5 ? zx Mark A. Yohe, Defend i?l C N °0 0 V1 m N MARY M. SHANKLE : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION LAW NO. 02-4451 CIVIL TERM MARK A. YOHE, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST 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 I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorcee 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. §4904, relating to unsworn falsification to authorities. Date: (!5%2yl-05 '/ 4 4a Mark A Yohe, Defend o ? r. ? ? 'C7 OJ -j3 ? C7 - ' ' N J RECEIVED JUL 15 2005 MARY M. SHANKLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Vs. CIVIL ACTION - LAW MARK A. YORE, NO. 02-4451 CIVIL TERM Defendant IN DIVORCE ORDER OF COURT AND NOW, this 2 day of 2005, upon presentation and consideration of the within Motion, it is hereby ordered and decreed that the action for declaratory judgment filed by Plaintiff is hereby dismissed. Cc: LT- ylor P. Andrews, Attorney for Plaintiff Arylou Matas, Esquire Attorney for Defendant C`` \'l ? r =- .r C, `'_ :f ???? i y:. )? ? ?v= ? ? u` y Y an U+- ° ( J C3 c-+ MARY M. SHANKLE : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Domestic Relations Section NO. 02-4451 CIVIL TERM PACSES NO: 550105322 MARK A. YORE, Defendant PRAECIPE On behalf of the Plaintifff, Mary M. Shankle, I hereby withdraw the claim for Alimony Pendente Lite filed to the above referenced docket. By:, Ta or . Andrews, Esq., Attorney for Plaintiff 7,9)Y. Pomfret Street arlisle, PA 17013 (717) 243-0123 cc: Mary Lou MatA Esquire Michael R. Rundle, Support Master !1 hT ?-? t"' ?? CJ ,_,.. ca-? `/1 t t._ ,? ,?3 ? ?: ?_J `^ ..7 .,... ? 'ii C':+ _{ M. Shankle vs Case No. 02-4451 Mark A. Yohe Statement of Intention to Proceed To the Court: M. Shankle intends to proceel3?i thafl v aptioned matter. Print Name Taylor P. Andrews Sign Name Date: 9/29/05 Attorney for _ P-raintiff Explanatory Comment The Supreme Court of Pennsylvania has promulgated new Rule of Civil Procedure 230.2 governing the termination of inactive cases and amended Rule of Judicial Administration 1901. Two aspects of the recommendation merit comment. I. Rule of civil Procedure New Rule of Civil Procedure 230.2 has been promulgated to govern the termination of inactive cases within the scope of the Pennsylvania Rules of Civil Procedure. The termination of these cases for inactivity was previously governed by Rule of Judicial Administration 1901 and local rules promulgated pursuant to it. New Rule 230.2 is tailored to the needs of civil actions. It provides a complete procedure and a uniform statewide practice, preempting local rules. This rule was promulgated in response to the decision of the Supreme Court in Shop v. Eagle, 551 Pa. 360,710 A.2d 1104 (1998) in which the court held that "prejudice to the defendant as a result of delay in prosecution is required before a case may be dismissed pursuant to local rules implementing Rule of Judicial Administration 1901." Rule of Judicial Administration 1901(b) has been amended to accommodate the new rule of civil procedure. The general policy of the prompt disposition of matters set forth in subdivision (a) of that rule continues to be applicable. If Inactive Cases The purpose of Rule 230.2 is to eliminate inactive cases from the judicial system. The process is initiated by the court. After giving notice of intent to terminate an action for inactivity, the course of the procedure is with the parties. If the parties do not wish to pursue the case, they will take no action and "the Prothonotary shall enter an order as of course terminating the matter with prejudice for failure to prosecute." If a party wishes to pursue the matter, he or she will file a notice of intention to proceed and the action shall continue. a. Where the action has been terminated If the action is terminated when a party believes that it should not have been terminated, that party may proceed under Rulc230(d) for relief from the order of termination. An example of such an occurrence might be the termination of a viable action when the aggrieved party did not receive the notice of intent to terminate and thus did not timely file the notice of intention to proceed. The tuning of the filing of the petition to reinstate the action is important. If the petition is filed within thirty days of the entry of the order of termination on the docket, subdivision (d)(2) provides that the court must grant the petition and reinstate the action. If the petition is filed later than the thirty-day period, subdivision (d)(3) requires that the plaintiff must make a show in to the court that the petition was promptly filed and that there is a reasonable explanation or legitimate excuse both for the failure to file the notice of intention to proceed prior to the entry of the order of termination on the docket and for the failure to file the petition within the thirty-day period under subdivision (d)(2). B. Where the action has not been terminated An action which has not been terminated but which continues upon the filing of a notice of intention to proceed may have been the subject of inordinate delay. In such an instance, the aggrieved party may pursue the remedy of a common law non pros which exits independently of temvnation under Rule 230.2. cc: Mary Lou Matas, Esquire Attorney for Defendant C? (XI MARY M. SHANKLE : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 02-4451 CIVIL TERM MARK A. YOHE. Defendant : IN DIVORCE ADDENDUM TO SEPARATION AND PROPERTY SETTLEMENT AGREEMENT AGREEMENT, made this P-7 day of 44t1f, 2005, between MARK A. YOHE (hereinafter called "Husband") and MARY M. SHANKLE (hereinafter called "Wife"). WITNESSETH: The parties signed a SEPARATION AND PROPERTY SETTLEMENT AGREEMENT that was filed of record in the above captioned divorce action; Article V of the agreement provides that Husband will pay Wife alimony of $138.50 per month for 24 consecutive months, but the agreement did not provide that the payments would be made through the Cumberland County Domestic Relations Office; Both parties desire that the alimony payment be paid by wage attachment through the Cumberland County Domestic Relations Office, and Wife agrees to pay all associated administrative fees imposed by the Domestic Relations Office. NOW THEREFORE. in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter set forth, Husband and Wife, each intending to be legally bound hereby, covenant and agree that the SEPARATION AND PROPERTY SETTLEMENT AGREEMENT of the parties dated June & 2005 is hereby amended to provide in Article V. that the alimony payments from Husband to Wife shall be paid by wage attachment and administered through the Domestic Relations office Cumberland County. Wife shall pay all associated administrative fees imposed by the Domestic Relations Office. IN WITNESS WHEREOF, the parties hereto have set their hands the day and year first above written. This Agra:entent is _secuted ir. duplicate, and in coun:.:marts. and Hwhand apd Wife, as parties hereto. acknowledge the receipt of a duly executed copy hereof. I MARY M. SHANKLE : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 02-4451 CIVIL TERM MARK A. YOHE, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND AND NOW, this '71 day of September 2002, I, Taylor P. Andrews, Esquire, attorney for Mary M. Shankle, Plaintiff in the above-captioned action, hereby swear that I have served a true copy of the Complaint in Divorce, with Notice to Defend and Claim Rights, executed by the Plaintiff in the above- captioned matter, upon the Defendant at his residence at 1601 York Road, Carlisle, PA 17013, by depositing the same in the U. S. Mail, postage prepaid, certified, deliver to addressee only, return receipt requested. A copy of the return receipt card signed by the Defendant on September 18, 2002, indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. ANDREWS & JOHNSON By: Sworn and subscribed to before me this j ! day of September, 002. NOTARIAL SEAL SHELLY SEXTON, Notary Public Carlisle Bore, Cumberland County My Commission Expires April 26, 2007 P. Andrews, Esq. ;Y for Plaintiff I -, ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, orlon the front if space permits. 1. A icle Addressed to: M • t1'la ? k y?he. Ccw lJSQ UA F?c A. Received by (Please Receipt of Delivery ) )-d 2. Article Number (Copy from service C. Signature M n p (? El Agent X El Addre D. Is delivery address differe from item 1? ? Yes If YES, enter delivery address below. C;No 3. Service Type A Certified Mail ? Express Mail ? Registered Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) yes PS Form 3811, July 1999 Exhibit A I I V AAA" W A,' AAJA i I MARY M. SHANKLE : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. MARK A. YOHE, TO THE PROTHONOTARY: CIVIL ACTION - LAW NO. 02-4451 CIVIL TERM Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2 Date and manner of service of the complaint: September 23, 2002 restricted, certified, return receipt requested. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff June 8, 2005; by Defendant June 24. 2005. 4. Related claims pending: None. 5. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: June 10, 2005 Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: July 8, 2005 ANDREWS & JOHNSON Date: October3i , 2005 for P. Andrews, Esq. West Pomfret Street Carlisle, PA 17013 (717) 243-0123 Supreme Court ID No. 15641 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. 'Pt MARY M. SHANKLE Plaintiff VERSUS MARK A. YOHE Defendant N 0. 02-4451 DECREE IN DIVORCE AND NOW, IT IS ORDERED AND DECREED THAT AND MARK A. YOHE ARE DIVORCED FROM THE BONDS OF MATRIMONY. PLAINTIFF, ,DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD I, N?THION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; ??\`/J-l? The parties Marital Settlement Agreement dated June 8 2005 and the Addendum dated October 27, 20 is incorporated but not merged. BY TH•,? EOU RT:;j ,i ATTEST: J, • PROTHONOTARY MARY M. SHANKLE ??p 1"V j?; i.)/ ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 12/01/05 Case Number (See Addendum for case summary) Employer/Withholder's Federal [IN Number COMMONWEALTH OF PA C/O PAYROLL OPERATIONS ATTACHMENTS RESEARCH UNIT 55DI D53 ?;? 0,1 -Z44,51 0'ul (D D Original Order/Notice O Amended Order/Notice O Terminate Order/Notice RE: YORE, MARK A. Employee/Obligor's Name (Last, First, MI) 201-50-7674 Employee/Obligor's Social Security Number 5468101126 Employee/Obligor's Case Identifier (See Addendum for plaintiff names PO BOX 8006 associated with cases on attachment) HARRISBURG PA 17105-8006 Custodial Parent's Name (Last, First, MI) See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 138.50 per month in current support $ 0. oo per month in past-due support Arrears 12 weeks or greater? Oyes ® 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 $ 138.50 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: $ 31.96 per weekly pay period. $ 63 .92 per biweekly pay period (every two weeks). $ 69.25 per semimonthly pay period (twice a month). $ 138. 50 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. Date of Order: DEC O 5 2005 Service Type M BY THE Form N-028 OMB NO.: 0970-0154 WorkerlD $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If hecked you are required to provide a copy of this form to your employee. If your employee works in a state that is different from the state that issued this order, a copy must be provided to your employee even if the box is not checked. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3.* Reporting the Paydate/Dateef-Withha}ding:"Yvu-must7eport the-paydate/date of withha}dingwherrsending -the payment. The- pagdate/date of withholding is the-date omrohich amount was withheldfronrthe employee' 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 information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2321722990 EMPLOYEE'S/OBLIGOR'S NAME: YORE, MARK A. EMPLOYEE'S CASE IDENTIFIER: 5468101126 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who 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. I ].Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 Service Type M If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at 717 40-624_ or by internet www.chiIdsupport.state.pa.us Page 2 of 2 OMB No 0970 0154 Form EN-028 Worker ID $TATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: YoHE, MARK A. PACSES Case Number 550105322 PACSE5 Case Number Plaintiff Name Plaintiff Name MARY M. SHANKLE Docket Attachment Amount Docket Attachment Amount 02-4451 CIVIL$ 138.50 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB ? 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) 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) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSE5 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) 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) ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available identified above in any health insurance coverage available through the employee's/obligor's employment. through the employee's/obligor's employment. Addendum Form EN-028 Service Type M Worker ID $IATT OMB No. oe7o-oi sa S l ?t ?? : i ? ' ` ' S (.. _ . t ?: % 5*50 I v 5 3;.a ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT Qa - L?4 51 CI V I r`. O Original Order/Notice State Commonwealth of Pennsylvania CO./City/Dist. of CUMBERLAND O Amended Order/Notice Date of Order/Notice 12/03/07 XO Terminate Order/Notice Case Number (See Addendum for case summary) RE: YOHE, MARK A. Employer/Withholder's Federal EIN Number Employee/Obligor's Name (Last, First, MI) BUREAU OF COMMONWEALTH C/O WAGE ATTACHEMENT SECTION PO BOX 8006 HARRISBURG PA 17105-8006 201-50-7674 Employee/Obligor's Social Security Number 5468101126 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, Mp See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 0 . oo per month in current support $ o . oo per month in past-due support Arrears 12 weeks or greater? Dyes ® no $ o . 00 per month in current and past-due medical support $ 0 . oo per month for genetic test costs $ 0.00 per month in other (specify) for a total of $ 0.00 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: $ o . o o per weekly pay period. $ o. oo per biweekly pay period (every two weeks). $ o. oo per semimonthly pay period (twice a month). $ o. o0 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. Date of Order: DEC 2 6 2007 BY T OURT: G Form EN-028 Rev. . Service Type M OMB No.: 0970-0154 Worker ID $IATT ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If hheckefd you are required to provide a copy of this form to your mloyee. If yo r employee works in a state that is di erent from the state that issued this order, a copy must be provideeTto your employee even if the box is not checed. 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.* 1% wncn acnuu% uic Pay11w11a. You must comply with the law of the paydate/date of withholding is the date on which arn tii,tvvanwffit'i'ie'df.-oiiit'.eeii,p Is wages. 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 employeelobligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2321722990 EMPLOYEE'S/OBLIGOR'S NAME: YOHE. MARK A. EMPLOYEE'S CASE IDENTIFIER: 5468101126 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act 0 5 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who 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: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 Service Type M by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT Page 2 of 2 OMB No.: 0970-0154 Form EN-028 Rev. 1 Worker ID $ IATT ADDENDUM Summary of Cases on Attachment Defendant/Obligor: YORE, MARK A. PACSES Case Number 550105322 Plaintiff Name MARY M. SHANKLE Docket Attachment Amount 02-4451 CIVIL$ 0.00 Child(ren)'s Name(s): DOB ? 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) 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) 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 PACKS 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) identified above in any health insurance coverage available through the employee's/obligor's employment. PACKS 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) ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available identified above in any health insurance coverage available through the employee's/obligor's employment. through the employee's/obligor's employment. Addendum Form EN-028 Rev. 1 Service Type M Worker I D $ IATT OMB No.: 0970-0154 CD ,, ... r*i C'1 P77 ? C7l , rn