HomeMy WebLinkAbout98-00526
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:: IN THE COURT OF COMMON PLEAS I
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OFCUMBERLANDCOUNTY
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PENNA.
SHERRY LEE EHRISMAN, Plaintiff
No. 98 - 526 Civil
VERSUS
TIM:YI'HY JOHN EHRISMAN, Defendant
,
,
.
.
.
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DECREE IN
DIVORCE
AND NOW,
OAo!tL '2J
. IT IS ORDERED AND
'71Jo?
DECREED THAT
Sherry Lee Ehrisman
. PLAINTIFF.
AND
Timothy John Ehrisman
. DEFENDANT.
.
.
.
,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
.
.
.
.
.
.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
.
None.
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SHERRY LEE EIIRISMAN.
PlaintifT
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,PENNSYLVANIA
V.
: NO 98 - 526 CIVIL TERM
TIMOTHY JOHN EHRISMAN,
Defendant
: IN DIVORCE
PRAECIPE TO TRANSMIT RECOR!)
TO THE PROTHONOTARY:
Trnnsmit the record, together with the following information to the Court for entry of a
divorce decree:
I. Ground for divorce: irretrievable breakdown under &330J(e) of the Divorce Code.
2. Date and manner of the service of the Complaint: Delivered bv certified mail.
restricted deliverv. return receipt reauested. delivered on: February 4, 1998.
3. Date of execution of the affidavit of consent required by 3301(e) of the Divorce Code:
By PlaintifT:
March 28, 2000
By Defendant:
October 4, 2003
4. Related claims pending: None.
5. Date Defendant's Waiver of Notice in *3301(c) Divorce was filed with the
Prothonotary: October 7,2003.
*3301(c) Divorce was filed with the
Date: 16. I L( a 3
Ja e Adams, Esquire
I.D No. 79465
3 S. Pitt Street
Carlisle, Pa. 17013
(717) 245-8508
Attorney lor Plaintiff
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SHERRY LEE EHRISMAN,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
Plaintiff
VB.
TIMOTHY JOHN EHRISMAN,
NO. 98 - !Cl. {,
CIVIL TERM
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
SHERRY LEE EHRISMAN, Plaintiff, by her attorneys, FLOWER, MORGENTHAL, FLOWER
& LINDSAY, P.C., respectfully represents:
1. The Plaintiff is Sherry Lee Ehrlsman, who currently resides at 233 Richland Road,
Carlisle, Cumberland County, Pennsylvania, where she has resided since November, 1995.
2. The Defendant is Timothy John Ehrisman, who currently resides at R. R. 1, Box 197, I
,
I
McAlisterville, Juniata County, Pennsylvania, where he has resided since at least 1987.
3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth
of Pennsylvania for at least six months immediately prior to the filing of this Complaint.
4. The Plaintiff and Defendant were married on May 20, 1994, at Juniata County,
Pennsylvania.
5. That there have been no prior actions of divorce or for annulment between the parties
in this or in any other jurisdiction.
6. The Plaintiff avers that she is entitled to a divorce on the ground that the marriage is
irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce
Code.
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7. Plaintiff has been advised of the availability of marriage counseling and of the right to
request that the Court require the parties to participate In marriage counseling, and does not
request counseling.
8. Plaintiff requests the Court to enter a decree of divorce.
FLOWER, MORGENTHAL FLOWER & LINDSAY, P.C.
Attorneys for Plaintiff
By:
.'-' O)~ J/)III/V~J-
Roger M/ Morgenthal, Esquire
ID # 17143
11 East High Street
Carlisle, PA 17013
(717) 243-5513
Date: ~ I 5 I (c; ~ if
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l':\WI1.~I\rmm\ehtiln1un.lJlv file N:IW..~.IJ1.f11 .Il1nUIlJ)' 12,(l)'JH
VERIFICATION
I, the undersigned, hereby verify that the statements made herein are true and correct.
understand that false statements herein are made subject to the penalties of 18 Pa. e.s. ~ 4904,
relating to unsworn falsification to authorities.
/1 de I' .
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Sh Lee Ehrisman
Date:
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file #5465.97-01
VB.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 98.526 CIVIL TERM
IN DIVORCE
SHERRY LEE EHRISMAN,
Plaintiff
TIMOTHY JOHN EHRISMAN,
Defendant
AFFIDAVIT OF CONSENT
1. A Complaint In Divorce under ~ 3301(c) of the Divorce Code was filed on January 29, 199B.
2. The marriage of plaintiff and defendanlls Irretrievably broken and ninety days have elapsed from
the date of filing and service of the Complaint.
3. I consent to the entry of a final Decree In Divorce after service of notice of Intention to request
entry of the Decree.
I verify that tho statements made in this Affidavit are true and correct to the best of my knowledge.
Information and belief. I understand that false statements herein are made subject to the penalties of 1 B
Pa.C.S. 4904 relating to unsworn falsification to"authorities.
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1 Sherry Lee Ehrlsman, Plaintiff
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Date:
fl'/Mc[, ?.f. 2000
,
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 Ills filed with the Prothonotary.
I verify that the statements made In this Affidavit are true and correct to the best of my knowledge.
information and belief. I understand that false statements herein are made subJect to the penalties of 18
Pa.C.S. 4904 relating to unsworn falsification to authorities.
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V 'Ijl'.r ,II 1. / /r~ cl./ IlI';( I U
, sherryJee Ehrisman, Plaintiff
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SHERRY LEE EHRISMAN,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
vs.
CIVIL ACTION. DIVORCE~"
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NO. 98 - 526 CIVIL TE~M
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TIMOTHY JOHN EHRISMAN,
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Defendant
IN DIVORCE
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CERTIFICATE OF SERVICE
,} t; day of h [m,;{/U/_,
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MORGENTHAL, Esquire, of the law firm of FLOWER, MORGENTHAL, FLOWER & LINDSAY, P.C"
AND now, this
, 1998, I, ROGER M.
Attorneys, hereby certify that I served the Defendant, Timothy John Ehrisman, on February 4, 1998,
with the Complaint for Divorce by Certified Mail, Return Receipt Requested, Restricted Delivery,
Addressee Only, addressed to:
Mr. Timothy John Ehrisman
R. R. 1, Box 197
McAlisterville, PA 17049
and proof thereof, the signed Return Receipt Card, is attached hereto.
FLOWER, MORGENTHAL, FLOWER & LINDSAY
Attorneys for PlaIntiff
By
Roger M.' orgenthal, Esquire
ID # 17143
11 East High Street
Carlisle, PA 17013
(717) 243-5513
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SHERRY LEE EHRISMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V5.
CIVIL ACTION - DIVORCE
NO. 98 - 526 CIVIL TERM
TIMOTHY JOHN EHRISMAN,
Defendant
IN DIVORCE
PROOF OF SERVICE
i eeomp"llt;nw 1 andIOf 2 lor additional Mme...
.. 'Competelt.ms 3. "., and "b.
I .Ptlnt your name and add,.... on tM "VI,.. ollNt form 10 thai we can retum thl.
card t. you.
'Attach thl, form to the front of the malrplece, or on the bad( If tpace dot. not
p.,mlt.
t: 'Wrt!.-R.tum R<<>>Ipt Requnted"on the mallplece below the erUd. number.
'Ii IThe Rltum Receipt wiD Ihow 10 whom the 8I11cl, WI' delivered and the datI
Ii dIllvorld.
I 3. Article Addressed to:
Mr. Tinothy John Ehrisman
R. R. 1, Box 197
MclUisterville, PA 17049
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XI Certified I
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c:\wp~l~rmm\eli~sman.div file #5465-97-01 January 13,1998
SHERRY LEE EHRISMAN,
VS.
TIMOTHY JOHN EHRISMAN,
Plaintiff :
.-
.,
..
Defendant :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 98 - ~J-/-- 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 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, Carlisle, Pennsylvania, 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR
EXPENSES BEFORE A DECREE OF 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 ASSOCIA'rlON
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
FLOWER, MORGENTHAL FLOWER & LINDSAY, P.C.
Attorneys for Plaintiff
Date:
By.'
Roger M. Morgenthal, Esquire
ID # 17143
11 East High Street
Carlisle, PA 17013
(717) 243-5513
c:\wp51\rmm\ehrisman.div file #5465-97-01 January 12,1998
SHERRY LEE EHRISMAN,
VS.
TIMOTHY JOHN EHRISMAN,
Plaintiff
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 98- ~'~-/-,, CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCF
SHERRY LEE EHRISMAN, Plaintiff, by her attorneys, FLOWER, MORGENTHAL, FLOWER
& LINDSAY, P.C., respectfully represents:
1. The Plaintiff is Sherry Lee Ehrisman, who currently resides at 233 Richland Road,
Carlisle, Cumberland County, Pennsylvania, where she has resided since November, 1995.
2. The Defendant is Timothy John Ehrisman, who currently resides at R. R. 1, Box 197,
McAlisterville, Juniata County, Pennsylvania, where he has resided since at least 1987.
3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth
of Pennsylvania for at least six months immediately prior to 'Ihe filing of this Complaint.
4. The Plaintiff and Defendant were married on May 20, 1994, at Juniata County,
Pennsylvania.
5. That there have been no prior actions of divorce or for annulment between the parties
in this or in any other jurisdiction.
6. The Plaintiff avers that she is entitled to a divorce on the ground that the marriage is
irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce
Code.
e:\wpSl\~nm\ehfisman.div file #5465-97-0~ Janua~ 12,19~8
7. Plaintiff has been advised of the availability of marriage counseling and of the right to
request that the Court require the parties to participate in marriage counseling, and does not
request counseling.
8. Plaintiff requests the Court to enter a decree of divorce.
FLOWER, MORGENTHAL FLOWER & LINDSAY, P.C.
Attorneys for Plair3tiff
By:
Roger M.' Morgenthal, Esquire
ID # 17143
11 East High Street
Carlisle, PA 17013
(717) 243-5513
c:\wp51¥mm\ehfisman.div file #5465-974}1 Janua~ 12,1998 · ·
VERIFICATION
I, the undersigned, hereby verify that the statements made herein 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.
Lee Ehrisman
Date:
SHERRY LEE EHRISMAN,
VS.
TIMOTHY JOHN EHRISMAN,
CERTIFICATE OF SERVICF ~ -- ~
AND now, this ~ ~ day of ['~.r.~.¢¢~ 1998, I, ROGER M.
MORGENTHAL, Esquire, of the law firm of FLOWER, MORGENTHAL, FLOWER & LINDSAY, P.C.,
Attorneys, hereby certify that I served the Defendant, Timothy John Ehrisman, on February 4, 1998,
with the Complaint for Divorce by Certified Mail, Return Receipt Requested, Restricted Delivery,
: IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNT~, PENNSYLVANIA
: CIVIL ACTION - DIVORCE~
: NO. 98- 526 ~IVlL TE~
Defendant : IN DIVORCE
Addressee Only, addressed to:
Mr. Timothy John Ehrisman
R. R. 1, Box 197
McAlisterville, PA 17049
and proof thereof, the signed Return Receipt Card, is attached hereto.
FLOWER, MORGENTHAL, FLOWER & LINDSAY
Attorneys for Plaintiff
By
g . g hal, Esquire
ID # 17143
11 East High Street
Carlisle, PA 17013
(717) ;!43-5513
SHERRY LEE EHRISMAN,
VS.
TIMOTHY JOHN EHRISMAN,
Pla ntiff
Defendant :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL. ACTION - DIVORCE
NO. 98- 526 CIVIL TERM
IN DIVORCE
PROOF OF SERVICE
file #5465-97-01
SHERRY LEE EHRISMAN,
Plaintiff
VS.
TIMOTHY JOHN EHRISMAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 98.526 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on January 29, 1998.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from
the date of filing and service of the Complaint.
3. I consent to the entry of a final Decree in 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 to the best of my knowledge,
information and belief. I understand that false statements herein are made subject to the penalties of 18
Pa.C.S. 4904 relating to unsworn falsification to.,,authorities.
·
,:/'Sherry Lee Ehrisman, Plaintiff
Date:
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
§33011c) 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 allimony, 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 to the best of my knowledge,
information and belief. I understand that false statements herein are made subject to the penalties of 18
Pa.C.S. 4904 relating to unsworn falsification to authorities.
' Sherry~.C'ee Ehrisman, P~aintiff
SHERRY LEE EHRISMAN,
Plaintiff
V.
TIMOTHY JOHN EHRISMAN,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO 98 - 526 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on January 29, 1998.
2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety days have elapsed fi.om the
date of the filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of
the decree.
I verify that the statements made in this affidavit are true and correct. I also understand that false
statements herein are made Subject to the penalties of 18 Pa.C.S. 4904, relatirtg to unswom falsification to
authorities.
Timothy JolffFEhrisman, Defendant
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER .~3301(c) AND §3301(d) OF THE DIVORCE CODE
1. 1 consent to ento, ora final decree of divorce without notice.
2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses
ill 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. 1 understand that false statements
herein are made subject to th* penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities.
Date:/O "/-/~ O'"~
Timothy Joh~ Ehrisman, Defendant
SHERRY LEE EHRISMAN,
Plaintiff
V.
TIMOTHY JOHN EHRISMAN,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO 98 - 526 CIVIL TERM
:
: IN DIVORCE
PRAECIPE TO TRANSMIT RECORn
· TO THE PROTHONOTARY:
Transmit the record, together with the following information to the Court for entry of a
divorce decree:
1. Ground for divorce: irretrievable breakdown under ~301(c) of the Divorce Code.
2. Date and manner of the service of the Complaint: Delivered by certified maik
restricted deliver~, retuln receipt requested, delivered on: February 4, 1998.
3. Date of execution of the affidavit ofconsem required by 3301(c) of the Divorce Code:
By Plaintiff:
March 28,2000
By Defendant:
October 4, 2003
4. Related claims pending:.None
5. Date D
efendant s Waiver of Not~ce in §3301(c) Divorce was filed with the
Prothonotary: October 7, 2003.
Date Plainti~] Waiver §3301 (c) Divorce was filed with the
Prothonotary: q !"~,t-~'!(~:~) of Noticein
, Esquire
65
eet
17013
(717) 245-8508
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOIJNTY
STATE OF PENNA.
SHERRY LEE EHRISMAN, Plaintiff
VERSUS
TIMOTHY JOHN ~HRISMAN, Defendant
N o. 98 - 526 Civil
AND NOW,
DECREED THAT
AND
DECREE IN
DIVORCE
Sherry Lee Ehrisman
Timothy John Ehrisman
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
IT IS ORDERED AND
, PLAINTIFF,
, DEFENDANT,
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
None o
BY TH C IrT:
ATTEST: j.
P OTHONOTAR