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Home My WebLink About97-01931 i I I I ~\ ~ I ~ ' ~: I .. tl ~ ~ Q ~ < ~ .. o \ " -"" .......... , .....--' J (' ~ ~ :--. , ::) - ~ ~ 21 ~ , . I *~ OFFICE OF DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEAS 9 North Hanover Slreet Carlisle, PA 17013 (717) 240.6535 E. Robert Elicker, II Divorce Master Tracl Jo Colyer 011 Ice Manager/Reporter West Shoro 697.0371 Ex\. 6535 February 3, .1998 Michael A. Gruin, Esquire PANNEBAKER & JONES, P.C. 4000 Vine street Middletown, PA 17057 Deborah Nicholson Attorney at Law 124 Vannear Avenue Greensburg, PA 15601 Re: Ernest W. O'Connor vs. Marilyn M. O'Connor No. 97 - 1931 Civil In Divorce Dear Mr. Gruin and Ms. Nicholson: By order of Court of President Judge George E. Hoffer dated February 2, 1998, the full-time Master has been appointed in the above referenced divorce proceedings. A divorce complaint was filed on April 14, 1997, raising grounds for divorce of irretrievable breakdown of the marriage and indignities and the economic claim of equitable distribution. I am unable to determine from the pleadings whether or not the parties are willing to sign affidavits of consent to conclude the divorce under section 3301(c) of the Domestic Relations Code or if the parties have been separated for a period in excess of two years. If the parties will not consent or have not been separated for a period in excess of two years, please advise and I will immediately schedule a hearing on the grounds of indignities. I note that counsel for wife is in Westmoreland county. She has accepted service of the motion for appointment of Master; however, I request that she enter her appearance of record in the action. I am going to proceed on the assumption that grounds for divorce are not an issue. I am directing each counsel in accordance with P.R.C.P. 1920.33(b) to file a pre-trial '.~: .., ~ " E~ W. O'CXlNOOR, Plaintiff . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 97 - 1931 CIVIL . . vs. , MARILYN M. O'CXlNOOR, Defendant CIVIL ACTION - LAW IN DIVORCE ORDER AND NOTICE SETTING HEARING TO: El:nest W. O'Connor Plaintiff , Michael A. Groin , Counsel for Plaintiff Marilyn M. O'Connor , Defendant Deborah Nicholson , Counsel for Defendant You are directed to appear for a hearing to take * testimony on the outstanding issues in the above captioned divorce proceedings at the Office of the Divorce Master, 9 North Hanover Street, Carlisle. Pennsylvania on the 21st day of May , 1998, at 9:00 a.m., at which place and time you will be given the opportunity to present witnesses and exhibits in support of your case. By t rge E. Hoff r, President Judge Date of Order and Notice: 2/12/98 By: Divorce Master 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 TELEPHONE (717) 249-3166 * Testimony will be limited to grounds for divorce of indignities to the person. LAW OFFICES of MATTHEW A. CURIALE ATTORNEY AT LAW 124 Vannoat Avenue Green'burg, Penn,ylvenla 15601 (412) 836.6006 FAX (412) 836,8007 MATTHEW A, CURIALE DEBRA M, NICHOLSON July 26, 1996 E. Robert Eliker, II Divorce Master Cumberland County Court of Common Pleas 9 North Hanover Street Carlisle, PA 17013 Re: Ernest W. O'Connor vs. Marilyn O'Connor No. 97-1931 Civil in Divorce Dear. Mr. Eliker: I wanted to advise you that my client, Marilyn O'Connor, does not wish to pursue her counterclaim and has no objections to the vacation of the appointment of the master. If you need anything further from me please advise. Very truly yours, , . ,-lOr!:/' /); )k/itl", ~ . Debra M. Nicholson DMN/kh 1 C;.{.r rN5:)(-1( V0i1'V1 .I ' /I f' {'J;y{f OA~f, .b (lSA16M '2;~\ tYr~ , '--' cc: James B. Pannebaker, Esq. Marilyn O'Connor .,.;.---=----. - ----- - .- - -- k~<I' ! I IIANNNIIAIUllll AND .IONNH, II, (J. FOUR THOUlAND VINE STREET MIDDLETOWN, PENNSYLVANIA 17057-3596 TELEPHONE E'MAIL ADDRESS nuCOPIER 717,944,1333 pjpc.cpl.,." 717'944'4004 CARMEN CMTINI OCUMAN PntR R. HENN'INCUI. JR. DON&o L JONES IAMB a PmHEMXfJt, July 30/ 1998 Office of the Divorce Master Cumberland County 9 North Hanover Street Carlisle, PA 17013 ATTN. Tracy RE: O'Connor v. O'Connor No. 97-1931-In Divorce Our File No, 15157 Dear Tracy: Please be advised that my client and I have no objection to have the master withdrawn and have the above-captioned matter returned to the Court. If you have any questions please feel free to give me a call. cc: Ernest O'Connor :sls O'CONNOR ltr73098 #15157 VISIT OUR WEB SIn AT: www.pannebaker-jones.com LAW OFFICES 01 MATTHEW A. CURIALE ATTORNEY AT LAW 124 Van,.,., Avenue GrHnsburg, Pennsylvania 15601 (412) 836-8006 FAX (412) B36-eoo7 MATTHEW A. CURIAlE HOUY L STABILE DAVIS ~X21Dt-u Yl&r- July 13, 1998 James B. Pannebaker, Esq. Panrebaker and Jones, P.C. 4000 Vine Street Middletown, PA 17057 RE: O'CONNOR V. O'CONNOR NO. 97-1931 Dear Mr. Pannebaker: I want to advise you that my client Marilyn O'Connor does not wish to pursue an indignities hearing and has no objections to the vacation of the appointment of the Master. If your client concurs to drop the hearing I will report to Mr. Elicker that my client does not wish to pursue the indignities hearing or her economic claims. The last issue would be whether to withdraw the complaint and counterclaim. To save the parties money in reconciliation circumstances I usually let the pleadings stay on record instead of withdrawing the case, but you can let me know your thoughts on the matter. Very truly yours, Debra M. Nicholson DMN/kh cc: Marilyn O'Connor OFFICE OF DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEAS 9 North Hanover Street Carlisle, PA 17013 (717) 240.6535 E. Robert Elicker, II Divorce Masler Tr.cl do Colyer Office Manager/Reporter West Shore 697-0371 Ex!. 6535 April 17, 1998 Michael A. Gruin, Esquire PANNEBAKER & JONES, P.C. 4000 Vine Street Middletown, PA 17057 Debra M. Nicholson Attorney at Law 124 Vannear Avenue Greensburg, PA 15601 RE: Ernest W. O'Connor vs. Marilyn M. O'Connor No. 97 - 1931 civil In Divorce Dear Mr. Gruin and Ms. Nicholson: I am writing in r.esponse to letters from counsel indicating that the O'Connor's may be working out a reconciliation and that the Master's hearing on the grounds for divorce of indignities should be continued pending the possible reconciliation of the parties. Consequently, the hearing scheduled for Thursday, May 21, 1998, is continued. I ask counsel to give me a status report on this case by Monday, June 29, 1998, so I know whether to reschedule the case for hearing or to ask the Court to vacate my appointment. Obviously, if the parties reconcile or in the alternative if there is a settlement of the economic claims and the divorce proceeds by agreement, there is no need for me to remain in this case. I will look forward to hearing from counsel with a status report as requested. Very truly yours, E. Robert Elicker, II Divorce Master ~w ~ </' PANNEU4\.KIOR A...'VI) .JONJaH, II, C. FOUR TIlOUI^ND VINf. 51R[[t MIDDLETOWN, PENN~YLV^NI^ 17057'3596 THENIONI I. M^'l ^OORE~1 mfCOPIIR 117.944'I3J) pJpcGephc,ner 71/941-400.1 M/(IIAlt ^ CRUlN PCllA II. HlNNINGER. Ill. DONALD l IONL\ JAMU B rANNEMKlR April 15, 1998 E, Robert Elicker, II Office of the Divorce Master Cumberland County 9 North Hanover Street Carlisle, PA 17013 Re: O'Connor v O'Connor No. 97-1931- In Divorce Our File No, 15157 Dear Mr. Elicker: I represent Ernest O'Connor in the above captioned divorce matter. Mr. O'Connor has informed me that the parties have reached a tentative reconciliation, and that therefore, they would like to cancel the upcoming Indignities Hearings and other Master's hearings, I would, therefore, ask for a general continuance of this matter in the hopes that the parties can maintain their reconciliation. Debra Nicholson, the attorney for Mrs, O'Connor has no objection to this continuance request. Please advise me if there are any problems with this continuance request. Thank you for your cooperation in this matter, If you have any questions. please feel free to Contact me, cc: Debra Nicholson, Esquire Sincerely, M6:.~;,L~( M^G:Clr O'Connor L041598 VISIT OUR WEB SITE AT: www.pannebakor-jones.com ~ ~<I' ~ y P..'-NNJCII..'ltRIt ..'NJ) .JONRH, l~. C. FOUR TtlOU\^NO VINI. SrRl!T MIDDLETOWN, PfNN~YLVANIA 17057.3596 HLlP/lONf ['MAIL ^DDRi~~ mrCOPI[R 11/-94.HJ3J pJpcOcpix.nu lll9M.Soot IotJOWl ^ CRUIN rOEk R mt.'NINGlR, IR. DONALD l IONB IM.m B PAHNlBAklR April 15, 1998 E. Robert Elicker, II Office of the Divorce Master Cumberland County 9 North Hanover Street Carlisle, PA 17013 Re: O'Connor v O'Connor No. 97-1931- In Divorce Our File No. 15157 Dear Mr. Elicker: I represent Ernest O'Connor in the above captioned divorce matter. Mr, O'Connor has informed me that the parties have reached a tentative reconciliation, and that therefore, they would like to cancel the upcoming Indignities Hearings and other Master's hearings, I would, therefore, ask for a general continuance of this matter in the hopes that the parties can maintain their reconciliation, Debra Nicholsun, the at!orney for Mrs. O'Connor has no objection to this continuance request. Please advise me if there are any problems with this continuance request. Thank you for your cooperation in this matter, If you have any questions. please feel free to contact me. cc: Debra Nicholson, Esquire MAG:Clr O'ConMr L041598 VISIT OUR WEB SITE AT: www.pannebaker-jones.com i I ERNEST W. O'CONNOR. Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. q 7 - ) q.3 I c......';'i 7:1",,,- MARILYN M. O'CONNOR. Defendant CIVIL ACTION - t NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the fOllowing pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other.claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courhouse, 1 Courthouse Square, 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 Cumberland County Courthouse 4th Floor, Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6200 .,! 8. The marriage is irretrievably broken. 9. Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 10. Plaintiff avers that there are no children of the parties under the age of 18 namely. COUNT NO. 2 23 Pa. C.S.A. 330l(a) (6) 11. Averments one (1) through (10) above are herein incorporated by reference thereto and made a part of this Count. 12. The Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render his condition intolerable and his life burdensome. 13. Plaintiff requests the Court to enter a Decree of Divorce. COUNT NO. 3 CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER 23 Pa. C.S.A. SECTION 3501 14. The Plaintiff and Defendant are owners of various items of personal property, furniture and household furnishings acquired during their marriage which are subject to equitable distribution by the Court. 2 , .. : t:; I i '! ! " I f 15. The Plaintiff and Defendant are owners of various motor vehicles acquired during their marriage which are subject to equitable distribution by the Court. 16. The Plaintiff and Defendant singly or jointly have interests in various bank accounts and insurance policies acquired during their marriage which are subject to equitable distribution by the Court. 17. The Plaintiff and Defendant have acquired during the term of this marriage other marital property which is subject to equitable distribution by the Court. WHEREFORE, the Plaintiff requests the Court to enter a Decree: (a) Dissolving the marriage between Plaintiff and Defendant; (b) Equitable distribution all marital property owned by the parties hereto; (c) Such further relief as the Court may determine equitable and just. Dated: i\ 11\-1-1 PANNEBAKER AND JONES, P.C. Attorneys for Plaintiff By: ALnl (_. Michael A. GruM-~squire 1.D. #78625 4000 Vine Street Middletown, PA 17057 Telephone: (717) 944-1333 3 I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made . -., , ~'.... . VERIFICATION I " I: I , . subject to the penalty of 18 Pa. C.S.A. ~4904, relating to unsworn falsification to authorities. ri . ~. ,.,.( OC" .../ Ernest W. O'connor, ~intiff PRHlsls O'Connor OCONDIV 4 (; ,{;> (') ...' -...J 'II - "'. -, ~... . .." l-i7J r':-:, ; .' r _.~ .' :8 ..' ,.J., I "'-:';, ':0 :. !(-, ,:..:; ,Ill :::> :":j '<) (;:) " , . .,.-\.-, ,j:..1 ~. 'j . ~ ' '" ,. JJ " :;u :;1,) 0"-- , ...,-,_.. ::\ ,.... CERTIFICATE OF SERVICE A copy of the foregoing Motion for Appointment of Master has been duly served upon the Defendant, Marilyn M. O'Connor, by sending a copy to the Attorney of record: Deborah Nicholson, Esquire 124 Vannear Avenue Greensburg, PA 15601 by depositing same in the United States ') J<t Middletown, Pennsylvania, this /1 mail, postage prepaid, in day of ;-((.ol",~ 1997. PANNEBAKER & JONES, P.C. Attorneys for Plaintiff By )Vlt.~~~D~ Michael A. Gruin 1.0. #78625 4000 Vine Street Middletown, PA 17057 Telephone: (717) 944-1333 :sls OCONNOR certl229 .' . n ,,., ~1 I ;:.:.J .. I ; ., 'r'. "1 .1.1 t:....' t_) .~ r') ."1". - I I ;,") :..? " I :n '. ~'11 '(1 - No. .J1.:!2J.UOiY.J..LI!!J:IIlTerm, 19..____ ERNEST W. O'CONNOR ---------------------------------------.- VI. MARILYN M. O'CONNOR ----------------------------------------- PR...ECIPE F"lled ___________________________ 19______ _~~~b~~_l_6~_~ui1L______________. ."try, ----------------------------------------- ~ r f; -.-,\ Q2~ . /.- ~'<r ~: .. r:' . 0- rl:: ~'.. ~-. '" n -' -n .- -! -~'; <] I N _,''1 :C:J (~, ) (l, ::1: ,- :~~ J',- .-' -( ) _".;ITt .. -', , , ~ ., (1) -. ;;": ,;.~ '. ~,;..::>;.~ ':;:',:./;I? .~.,.~~.::..~'.::~: ::;\~.(.:f;~';.;~l:f.:~.:'.,;.~~.. ~:; :..~~,i.:..~"'l.;.:::;\ .:...~;}~;:.!~;;:\;~-..~.:;.=::~.. .::,.:~...::.: ~.,\)::; :.;..;:.~: ~;':.,:'::~:;..:.":~ ... \::.(;:.::-:', ';::. ....: ." .~..'~' .'.:.:::::.::~-.7:: ...... r,," .' ~. 1" " .:. ......~ . ' ..... , i' I I i I:': " ERNEST W. O'CONNOR, ) IN THE COURT OF COMMON PLEAS ) CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff ) ) VS. ) No. 97-1931 ) MARILYN M. O'CONNOR, ) CIVIL ACTION - ) Defendant. ) ANSWER AND COUNTERCLAIM IN DIVORCE FILED ON BEHALF OF: MARILYN H. O'CONNOR, Defendant COUNSEL OF RECORD FOR THIS PARTY: DEBRA M. NICHOLSON, Esquire Sup. Ct. I.D. #44795 Law Offices of Matthew A. Curiale 124 Vannear Avenue Greensburg, PA 15601 (412) 836-8006 , ERNEST W. O'CONNOR, ) IN THE COURT OF COMMON PLEAS ) CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff ) ) vs. ) No. 97-1931 ) MARILYN M. O'CONNOR, ) CIVIL ACTION - ) Defendant ) ANSWER COUNT I - DIVORCE AND NOW, COMES the Defendant Marilyn M. O'Connor, by and through her attorney, Debra M. Nicholson, of the Law Offices of Matthew A. Curiale, files the following Answer and in support thereof avers as follows: 1. paragraph 1 is denied that the address given is Plaintiff's current address. 2. Paragraph 2 is admitted that the address given is Defendant's current mailing address. Her current residence is 736 Pennsylvania Avenue, Irwin, Westmoreland County, Pennsylvania. 3. Paragraph 3 is admitted. 4. Paragraph 4 is admitted. 5. Paragraph 5 is admitted. 6. Paragraph 6 is admitted. 7 . paragraph 7 is admitted. 8. Paragraph 8 is denied and on the contrary it is averred that the marriage is not irretrievably broken and strict proof thereof is demanded at the time of the trial. 9. Paragraph 9 is admitted. 10. Paragraph 10 is admitted. .. .' ANSWER COUNT NO. 2 23 Pa. C.S.A. 3301(a) (6) 11. Paragraph 11 does not require a response. 12. Paragraph 12 is denied. 13. Paragraph 13 does not require an Answer, but by way of response, Defendant would request that the Court dismiss the Complaint in Divorce. ANSWER COUNT NO. 3 EQUITABLE DISTRIBUTION 14. Paragraph 14 is admitted. 15. Paragraph 15 is admitted. 16. Paragraph 16 is admitted. 17. Paragraph 17 is admitted. WHEREFORE, Defendant requests this Honorable Court to equitably divide all marital property in accordance with the provisions of the Divorce Code. COUNTERCLAIM COUNT I - ALIMONY AND ALIMONY PENDENTE LITE AND NOW, COMES the Defendant/Counterclaim Plaintiff, Marilyn M. O'Connor, who makes the following Counterclaim and in support thereof avers as follows: 1. Defendant/Counterclaim Plaintiff lacks sufficient property to provide for her reasonable means and is unable to support herself during the pendency of this action, in the standard of living established during the course of the marriage, through appropriate employment. 2. Defendant/Counterclaim Plaintiff requires reasonable ... I f alimony pendente lite to adequately maintain herself during the pendency of this action in the standard of living established during the marriage. 3. Plaintiff/Counterclaim Defendant's earnings are substantially higher than Defendant/Counterclaim Plaintiff's earnings and he is financially able to provide for the reasonable needs of Defendant/Counterclaim Plaintiff during the pendency of this action in accordance with the standard of living established during the marriage. 4. Defendant/Counterclaim Plaintiff requires reasonable alimony to adequately maintain herself in the standard of living established during the marriage after the divorce. WHEREFORE, Defendant/Counterclaim Plaintiff requests your Honorable Court to enter an award of reasonable alimony pendente lite, and alimony after a divorce is granted in this case. COUNTERClAIM COUNT II - ATTORNEY'S FEES, COSTS AND EXPENSES 5. Paragraphs 1 through 4 of this Counterclaim are incorporated herein by reference as though set forth in full. 6. Defendant/Counterclaim Plaintiff has employed Debra M. Nicholson as counsel but is unable to pay the necessary and reasonable attorney's fees for said counsel. 7. The legal fees and court costs to Defendant/Counterclaim Plaintiff in this matter for legal representation will be both substantial and continuing throughout the course of this litigation. 8. Defendant/Counterclaim Plaintiff is without sufficient funds, income or assets to pay the counsel fees, costs and expenses , AFFIDAVIT I certift that the statements made in this document are true I ,j , , . and correct. I understand that false statements made herein are subject to the penalties under 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. ~ Z/} (I) '{!. /Y('7~~ O'CONNOR " >J Cx\ P -- (') 1.0 0 rU r: :::. -l') .... .- ~n 0\ 0--. ...-- .." , ' c;.l nil; ,." ~." >L ~..:: J UJ i:;'TJ .....-:-1 ,-- ~ ~:.." ", .; ,I'll ~ <:) ~ ,'" In ~ r~ i~ ~ ','6 ~ .- ~ ", -'" ;'~ ~H - - ( 'I :.A: 1 '" ~. ~". , . , -;;.c) .....,.. ~." ~ )rn '" Vv . ,,-' '^' C\l :::! <n ~ ..........Yv -< "" a l'--- <"'0 c:.<0 c ~ ~ ,:.-, r..~' .' ..:;.....~ C\ ~I '- ' 0 <.0 0 c: ;;n ." ... ...., -''I ~ -, fTl :~ FI :!] [11tl' '~-:l %" r;; , 'i' ""J {/~.' ('0> :;"'1 r;: ':':::0 ""'" -"II ";Ci ,-.'):Q ;--:{ ] -......() ),.l.~_: W i.jrn " :':J 0\ ~ -, '. I ..L:,,, 4"/u.! ,y P.\.N.NRII.\.U,JCU ,"NU ,JOSJOH. I', C. FlJllR rlt(;IJ~.."~I() Vl~f SrRHr ~IIDDlET0~'''', PI';"'~YlV,~'JIA 17057,3596 1fI11'1l0'[ I ",Ill ,'DDR!'~ ![l[C01'1IR /1/ lJ's.I-lJj J pjpcOrplx,nl:'t ill ';'!-' ,100.' \lKIlML ^ GRUlN plflllll H(t'OMNCllt, I~ CL' ~LD L "''''U I~M!j a rANN(~nR. l) I March 31, 1998 Debra Nicholson, Esquire 124 Vannear Avenue Greensburg, PA 15601 VIA: Telefax (412) 836-8007 RE: O'Connor v, O'Connor No. 97-1931 Dear Debbie: I had earlier requested an extension until April 1, 1998 to file a Bill of Particulars, because the parties in this matter were exploring a reconciliation. I have not had a chance to discuss the reconciliation attempt with my client, and therefore, I would request an additional fifteen (15) days to file a Bill of Particulars if one will be necessary. I will advise you as soon as possible on the progress that the parties are making, and whether or not this matter can be withdrawn. If the parties would like more time, I would be agreeable to continue the Indignities Hearing until a later date. If the parties are truly making progress in the reconciliation talks, the last thing they need is an Indignities Hearing to rehash old problems. Again, this is all assuming that the reconciliation is actually succeeding. I will notify you and the Master as soon as possible regarding the necessity of a continuance. For now, I wi~l still assume that the Indignities Hearing is scheduled for Thursday, May 21, 1998 at 9:00 am, and that we are required to file a pre- tLial statement at least a month prior to that date. VISIT OUR WEB SITE AT: www.pannebaker-jones.com Thank you for your ongoing cooperation in this matter. If you have any questions, please feel free to contact me. Sincerely yours, ~ ~ Mi :dkm OCONNOR L033198 cc: Robert Elicker, II Office of the Divorce Master Cumberland County 9 North Hanover Street Carlisle, PA 17013