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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
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Michael P. Lujanac
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Plaintiff
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VERSUS
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Melanie J. Luianac
Defendant
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PENNA.
NO.
?()()()
6927
DECREE IN
DIVORCE
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,,00, IT IS ORDERED AND
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AND NOW,
DECREED THAT Michael P. Lujanac
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AND
Melanie J. Luianac
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, PLAI NTI FF,
, 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;
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Melanie J. Lujanac shall resume her prior sur-name and sh~ll
hereinafter be known as Melanie J. Eslinger
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PROTHONOTARY
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Michael p, Lujanac,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: NO. 00-6927
CIVIL TERM
Melanie J. Lujanac,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information to the court for entry
of a Divorce Decree:
1, Ground for divorce: irretrievable breakdown under 9 (3301 (c)) of the
Divorce Code.
2, Date and manner of service of the complaint: Certified, Returned Receipt
mail delivered on or about October 12, 2000,
3. Date of execution of the Affidavit of Consent required by 93301 (c) of the
Divorce Code.
By Plaintiff: November 20, 2003 By Defendant: November 20, 2003
4. Related claims pending: None.
Date the Waiver of Notice in 93301 (c) divorce was filed with the
Prothonotary:
By Plaintiff: November 20, 2003
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MICHAEL P. LUJANAC,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: NO. 00 - !PtJc21 ~
: CIVIL ACTION - LAW
: IN DIVORCE
MELANIE J, LUJANAC,
Defendant
,
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the
claims set forth in the following pages, you must take prompt action. You are
warned that if you fail to do so, the case may proceed without you and a decree
of divorce or annulment may be entered against you by the court. A judgment
may also be entered against you for any other claim or relief 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 Iistof marriage
counselors is available in the Office of the Prothonotary, Cumberland County
Courthouse, Hanover and High Streets, Carlisle, PA 17013.
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
(717) 249-3166
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MICHAEL P. LUJANAC,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
:NO,
MELANIE J. LUJANAC,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
NOTICIA
Le han Demando a usted en la corte. Si usted quiere defenderse de estas
demand as expuestas en las paginas siguientes, usted tiene viente (20) dias de
plazo al partir de la fecha de la demand a y la notificacion. Usted deve presentar
una apariencia excrita 0 en persona 0 por abogado y archivar en ta corte en
forma escrita sus defensas 0 sus objeciones alas demandas en contra de su
persona, Sea avisado que si usted no se defiende, la corte tomara medidas y
puede entrar una orden contra usted sin previa aviso 0 notificacion y por
cualquier queja 0 alivio que es pedido en la peticion do demanda. Usted puede
perder dinero 0 sus propiedades 0 otros derechos importanates para usted
LLEVE ESTA DEMANDAA UN ABODAGO IMMEDIATAMENTE. SI NO TIENE
ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL
SERVICIO, VAYA EN PERSONA 0 LLAME POR TELFONO A LA OFICINA
CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR
DON DE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
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MICHAEL P. LUJANAC,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
~ NO. (jf)- ~~:M ~ ~
MELANIE J. LUJANAC,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
COMPLAINT IN DIVORCE
DIVORCE
AND NOW, comes the Plaintiff, MICHAEL P. LUJANAC, by his attorney,
Mindy S. Goodman, Attorney at Law, and seeks to obtain a decree in divorce
from the above-named Defendant, upon the grounds hereinafter set forth:
1. The Plaintiff, MICHAEL P. LUJANAC, is an adult individual who
currently resides at 1777 Sheepford Road, Mechanicsburg, Cumberland County,
Pennsylvania 17055.
2. The Defendant, MELANIE J. LUJANAC, is an adult individual who
currently resides at 272 Walton Street, Lemoyne, Cumberland County,
Pennsylvania 17043.
3. The Plaintiff and Defendant are sui juris, and both have been bona
fide residents of the Commonwealth of Pennsylvania for a period of more than
six months immediately preceding the filing of this Complaint.
4. The Plaintiff and Defendant were married May 20, 1995 in
Cumberland County, Pennsylvania.
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5. The Plaintiff avers that there are no children born of the parties
under the age of 18.
6. Neither Plaintiff nor Defendant is in the military or naval service of
the United States or its allies within the provisions of the Soldiers' and Sailors'
Civil Relief Act of the Congress of 1940 and its Amendments.
7. The cause of action and section of the Divorce Code under which
the Plaintiff is proceeding is:
23 Pa. Cons. Stat. ~ 3301 (c) or, in the alternative, 23 Pa. Cons,
Stat. ~ 3301 (d). The marriage of the parties is irretrievably broken.
8. There have been no prior actions of divorce or annulment between
the parties in this or any other jurisdiction.
9. Plaintiff has been advised of the availability of counseling and that
Plaintiff may have the right to request the parties to participate in counseling.
WHEREFORE, Plaintiff requests This Court enter a Decree of Divorce in
his favor.
Respectfully submitted,
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Mindy S. Goodman
Attorney at Law
Attorney I.D, No. 78407
2080 Linglestown Road
Harrisburg, PA 17110
(717) 540-8742
Attorney for Plaintiff
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VERIFICATION
I verify that the statements made in this Complaint in Divorce are true and
correct. I understand that false statements herein are made subject to the
penalties of 18 Pa. Cons, Stat. ~ 4904, relating to unsworn falsification to
authorities,
DATE:
16/3/00
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Michael P. Lujanac,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-6927
CIVIL TERM
Melanie J. Lujanac,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
ANSWER TO COMPLAINT IN DIVORCE
~ COUNTER COM..fI;bINT
1. Admitted.
2. Admitted.
3. Admitted,
4. Admitted.
5. Admitted.
6. Admitted.
7. Admitted.
8. Admitted.
9. Admitted.
NEW MATTER
1. On or about May 27, 2000 the Plaintiff, Michael Lujanac signed as co-
applicant and co-maker for a "second mortgage" in the amount of $21,570.03
subject to interest and finance charges,
2. A settlement was held May 27,2000 at Members 1st Federal Credit Union, At
3512 Market Street, Camp Hill 17011. Michael P. Lujanac along with thEl
defendant Melanie J. Lujanac signed the settlement sheet evidencing the
principle amount of new loan in the amount of $21,567,64.
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3, Michael P. Lujanac was a co-applicanUco-maker for a loan to Members 1 st
Federal Credit Union and the money that was subject of that loan was
disbursed to Mr. Lujanac and Melanie Lujanac on May 27,2000,
Counter Complaint
1. Based upon the new matter contained herein and Michael Lujanac as a co-
applicant for a loan from Members 1st Federal Credit Union, 500 Louse Drive,
P.O, Box 40 Mechanicsburg, PA 17055, the defendant is counterclaiming a
cause for action in equitable distribution of the aforesaid factual claims.
Wherefore, the defendant request that Master Elicker appointed in this
matter find that the plaintiff is liable for one half of the total debt occurred as a
result of his application on May 27, 2000 to Members 1 st Federal Credit Union.
and receipt of funds thereto and that Mr. Lujanac be ordered to reimburse the.
defendant for one half of the total indebtedness.
Respectfully Submitted,
Galen R. Waltz, Esq
Turo Law Offices
28 South Pitt Street
Carlisle, PA 17013
(717) 245-2165
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VERIFICATION
I verify that the statements made in the foregoing Answer to Complaint in Divorce
and Counter Complaint are true and correct. I understand that false statements herein
are made subject to the penalties of 18 Pa.C.S, S4904 relating to unsworn falsification
to authorities.
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Melanie Lu ana
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CERTIFICATE OF SERVICE
I hereby certify that I served a true and correct copy of the Answer to Complaint
in Divorce and Counter Complaint upon Michael p, Lujanac by depositing same in the
United States Mail, first class, postage pre-paid on the ~t(J:l, day of October, 2003,
from Carlisle, Pennsylvania. addressed as follows:
Michael p, Lujanac
1777 Sheepsford Road
Mechanicsburg, PA 17055
Galen R. Waltz, Esquir
28 South Pitt Street
Carlisle, PA 17013
(717) 245-9688
Attorney for Defendant
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MICHAEL P. LUJANAC,
Plaintiff
vs,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00 - 6927 CIVIL
MELANIE J. LUJANAC,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Cornplaint in Divorce under Section 3301(c) of the Divorce Code was
f1led on October 10,2000,
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed frorn the date of the filing of the Complaint.
3, 1 consent to the entry of the final Decree in Divorce after service of notice
of intention to request entry of the decree,
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING
AFFIDAVIT ARE TRUE AND CORRECT, I UNDERSTAND THAT FALSE
STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18
PA.C.S, SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO
AUTHORTIES.
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MICHAEL p, LUJANAC
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MICHAEL p, LUJANAC,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs,
NO, 00 - 6927 CIVIL
MELANIE J, LUJANAC,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 330I(c) of the Divorce Code was
filed on October 10, 2000.
2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of the fIling of the Complaint.
3, I consent to the entry of the final Decree in Divorce after service of notice
of intention to request entry of the decree,
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING
AFFIDAVIT ARE TRUE AND CORRECT, I UNDERSTAND THAT FALSE
STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18
PA.C,S, SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO
AUTHORTIES,
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DATE:
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MELANIE J, NAC \J
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MICHAEL P. LUJANAC,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs,
NO, 00 - 6927 CIVIL
MELANIE J, LUJANAC,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 33011C\ OF THE DIVORCE CODE
1. I consent to the entry of a fmal decree of divorce without notice.
2. I understand that I may lose rights conceming alimony, division of
property, lawyer's fees or expenses if! do not claim them before a divorce is
granted.
3, I understand tnat 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 THE FOREGOING
AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE
STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18
PA,C,S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO
AUTHORTIES,
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MICHAEL p, LUJANAC,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs,
NO, 00 - 6927 CIVIL
MELANIE J, LUJANAC,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301lCl OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice,
2, I understand that I may lose rights concerning alimony, division of
property, lawyer's fees or expenses if! do not claim thern 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 rne immediately after
it is f1led with the Prothonotary,
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING
AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE
STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18
PA.C.S, SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO
AUTHORTIES,
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DATE:
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MELANIE J, LU NAC \
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MICHAEL P. LUJANAC,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00 - 6927 CIVIL
MELANIE J. LUJANAC,
Defendant
IN DIVORCE
ORDER OF COURT
AND NOW, this
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2003, the economic claim of equitable distribution raised in
the proceedings on behalf of the Defendant having been
withdrawn by praecipe filed by the Defendant's counsel on
November 20, 2003, and affidavits of consent and waivers having
been signed by the parties so the divorce can conclude under
Section 330l(c), the appointment of the Master is vacated.
BY THE COURT,
cc:
~chael P. Lujanac
Plaintiff
.J.
~len R. Waltz
Attorney for Defendant
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MELANIE J. LUJANAC
(ESLINGER) ,
Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
MICHAEL P. LUJANAC,
Respondent
CIVIL ACTION - LAW
NO. 00-6927 CIVIL TERM
ORDER OF COURT
AND NOW, this 30th day of January, 2004, it
appearing that Mr. Elicker is unavailable, hearing in this
matter is continued to March 1, 2004, at 11:00 a.m.
Petitioner is directed to make service of this order
upon Respondent by first class mail and certified mail,
return receipt requested, addressed to 1777 Sheepsford,
Road, Mechanicsburg, PA 17055.
By the Court,
Edward E. Guido, J.
alen R. Waltz, Esquire
F the Petitioner
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Melanie J. Lujanac (Eslinger),
Petition er
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL V ANL\.
v.
: NO, 00-6927
Michael P. Lujanac,
Respondent
: CIVIL ACTION - LAW
: IN DIVORCE
ORDER FOR PETITION FOR SPECIAL RELIEF
AND NOW this ~ 3~ day of ~ ~ ' 2004 after reviewing the
Petition for Special Relief it is ordered that a he;;Xng in this matter shall be held on the
3 o~ day of -J". . 6 , 2004, in Courtroom number ~ before
the HonorableJudge .. \A" 4.0 , "o1/0:t)D A. M .
J.
c,cAichael p, Lujanac, Pro Se
::".Galen R, Waltz, Esquire
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Melanie J, Lujanac (Eslinger),
Petition er
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VAN1\.
: NO, 00-6927
v,
Michael p, Lujanac,
Respondent
: CIVIL ACTION - LAW
: IN DIVORCE
ORDER FOR PETITION FOR SPECIAL RELIEF
AND NOW, this day of , 2004 after a hearing on the
Petition for Special Relief and after review of all the facts in the instant matter, Michael p,
Luj anac is hereby ordered to execute all documents necessary to transfer the motor vehicle
ownership of the two motor vehicles within 10 days from the date of this order; furthermore, Mr.
Michael p, Lujanac is ordered to pay the cost and attorney fees for the Petitioner for total amount
of to be paid within 10 days from the date of this order,
By the Court,
J.
c,c, Michael P. Lujanac, Pro Se
Galen R. Waltz, Esquire
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Melanie J. Lujanac (Eslinger),
Petition er
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL V ANV\
v.
: NO, 00-6927
Michael P. Lujanac,
Respondent
: CIVIL ACTION - LAW
: IN DIVORCE
Petition For Special Relief
AND NOW Comes the Petitioner, Melanie J. Eslinger (formerly Lujanac) represented by
attorney Galen R. Waltz, Esquire pursuant to Rule 1920.43 special relief avers the following:
1. Melanie J, Eslinger (formerly Lujanac) is an adult individual who resides at
272 Walton Street, Lemoyne, P A, 17043.
2, The Respondent Michael Lujanac is an adult individual who resides at 1777
Sheepsford Road, Mechanicsburg, P A 17055.
3. On November 20, 2003 before the Divorce Master E, Robert Elicker, II,
Esquire, Respondent agreed to eliminate all property claims against the
Petitioner for the consideration of the Petitioner assuming the second
mortgage that exists on the 272 Walton Street, Lemoyne, PA property.
4, At the November 20, 2003 conference, the respondent agreed to relinquish
his claims for Petitioner's retirement, automobile and all other claims.
S. Both Petitioner and Respondent signed the necessary waivers and consents for
the divorce, '
6, The Decree in Divorce was granted on December 9, 2003 at 5:12pm,
7, On December 5, 2003 a letter was mailed to the Respondent attempting to
establish a time and place to execute the requested documents needed to
successfully transfer each motor vehicle to the current possessor.
(Exhibit 1)
8. The Respondent neither kept the appointment at AM that was made for the
purpose of transferring the title of both vehicles nor did the respondent's
contact the attorney for the Petitioner to advise about the Respondent,
unavailability.
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9. Subsequently, a second letter dated December 18, 2003 was mailed to the:
Respondent and it requested that the Respondent contact Petitioner's attorney
in order to develop a date and time to execute the proper transfer for title of
the two motor vehicles, (Exhibit 2)
10, The Respondent failed to acknowledge receipt of the December 18, 2003
letter and the Respondent failed to contact the attorney for the Petitioner,
11. Finally a letter on December 30, 2003 containing the two previously mailed
letters was provided to the Respondent certified return receipt (Exhibit 3); the
letter requested that the respondent contact the Petitioners attorney on or
before January 9,2004, (Exhibit 4)
12. The Respondent failed to contact the Petitioners attorney relative to the
December 30, 2003 written request.
13, The Petitioner is ready, willing and able to execute the necessary documents
for the transfer of the motor vehicles and as a result of the nnsuccessful
attempts to have the Respondent complete the transaction that would fulfill
the representation made before Master Elicker, the Petitioner has incurred
additional expenses through attorney fees and costs due to the Respondents
slothful, non-communicative behavior.
14, Petitioner and Respondent agreed that Petitioner would eliminate
Respondent's liability with the 2nd mortgage which, in part, was used to
finance the purchase of Petitioner's automobile
Wherefore, Petitioner requests that this Honorable Court Order the
Respondent to execute all necessary document regarding the transfer of the title of
the Petitioner's automobile in to her name as well as the transfer of the
Respondent motor vehicle solely into his name; in addition, the Petitioner requests
that this Honorable Court levy the additional costs and attorney fees that
Petitioner has incurred as a result ofthe Respondent's inaction,
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Turo Law Offices
RON TURO, Esquire
ROBERT J, MULDE RIG, Esquire
GALEN R. WALTZ, Esquire
JAMES M. ROBINSON, Esquire
DANIEL D, WORLEY, Esquire
JAMES G. GAULT, Esquire
Michael Lujanac
1777 Sheepsford Road
Mechanicsburg, PA 17055
Dear Mr. Lujanac:
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www.TuroLaw.com
28 South Pitt Street
Carlisle, Pennsylvania 17013
(717) 245-9688
(800) 562-9778
Fax (717) 245-2165
December 5, 2003
Re: Transfer Title of Motor Vehicles
It is my understanding that the truck that is in your possession and the
automobile that is in Melanie's possession are titled in both of your names, Also, this
matter of the mortgage and release thereto can be resolved subsequent to the
successful transfer of title of the motor vehicles in the respective possessors hands.
To make the transfer title of the truck solely into your name and motor vehicle
solely in the name of Melanie's name an appointment has been made at AAA located at
Trindle Road in Camphill for you to appear during the day between the opening hour of
AAA to its 5:00pm closing time on December 16, 2003, Tuesday for you to appear and
contact Mr. Lou Lore who will have all of the documents ready for your signature.
It is our attention to make this experience the least time consuming and most
beneficial to each party as possible, Subsequent to your appearing at AAA on
December 16, 2003 and signing the necessary papers, the truck in your possession will
be titled solely in your name and the automobile will be titled solely in Melanie's name;
thereafter Melanie shall make and appointment at the mortgage company and remove
your name and release you from any and all liability as was pledged before the hearing
Master, E Robert Elicker, II, Esquire,
GRW/jge
c,c, Melanie Lujanac
Sincerely,
GALEN R. WALTZ, Esquire
Gwaltz@TuroLaw,com
. PLAINTIFF'S
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RON TURO, Esquire
ROBERT J. MULDERIG, Esquire
GALEN R. WALTZ, Esquire
JAMES M, ROBINSON, Esquire
DANIEL D. WORLEY, Esquire
JAMES G. GAULT, Esquire
Michael Lujanac
1717 Sheepsford Road
Mechanicsburg, PA 17055
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www.TuroLaw.com
28 South Pitt Street
Carlisle, Pennsylvania 171013
(717) 245-91688
(800) 562-9778
Fax (717) 245-2165
December 18, 2003
Re: Motor Vehicl.e Transfer Title
Dear Mr. Lujanac:
I am providing you a courtesy copy of the letter mailed to you Oecember 5, 2003 that
scheduled you for a December 16, 2003 appointment at AM located on Trindle Road in
Camphill. You failed to meet that appointment. As you will recollect before Master Elicker, you
agreed to eliminate your claims in return for Ms. Lujanac assuming the liability of the mortgage
on the house.
You specifically mentioned the automobile and truck as part of the claim before the
Master.
Only two outstanding issues are the removal of your name from the mortgage and all
liability related thereto along with proper transfer of title of the truck solely into your name and
the transfer of title of the motor vehicle solely in Melanie's name, These two activities can be
accomplished rather quickly upon your appearance at AM located at Trindle Road in
Camphill. Please contact me to let me know the day and time that you will be appearing at
AM in order that I can direct Ms. Lujanac to execute the proper mortgage document for the
removal of your name.
GRW~ah
C.c. Melanie Lujanac
Sincerely,
GALEN R. WALTZ, Esquire
Gwaltz@TuroLaw.com
PLAINTIFF'S
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ROBERT J. MULDERIG, Esquire
GALEN R. WALTZ, Esquire
JAMES M. ROBINSON, Esquire
DANIEL D. WORLEY, Esquire
JAMES G. GAULT, Esquire
Michael Lujanac
1777 Sheepsford Road
Mechanicsburg, PA 17055
Dear Mr. Lujanac:
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www.TuroLaw.com
28 South Pitt Street
Carlisle, Pennsylvania 17013
(717) 245-9688
(800) 562-9778
Fax (717) 245-2165
December 30, 2003
Re: Transfer of Motor Vehicle Title
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Enclosed for your benefit are copies of the December 5 and December 18, 2003
letters previously mailed to and received by you.
I shall attempt to keep this letter simplistic and direct for ease of understanding,
You sat before Master Elicker and agreed to eliminate all of your proprietary
interest in Melanie's home as well as her motor vehicle in order that your liability under
the Members First Federal Credit Union loan would be eliminated. You agreed and both
sides signed the appropriate consent/waiver forms which permitted the finalization of
the Divorce,
Through the December 5 and December 18 letters, Ms. Lujanac attempted to
resolve the last proprietary matter which involves the transfer of the title of the truck into
your name and the transfer of the automobile title into Melanie's name,
As you can determine from the enclosed letters, appointments have been made
at AM in Camp Hill for you to appear during the day for execution of the proper paper
work; unfortunately, and for what ever reason, you failed to keep those appointments
and to fulfill the agreement made before Master Elicker.
I recommend that you contact the undersigned within 10 days of the day of this
letter to arrange for a mutually agreed appointment to make the final transfer of Motor
Vehicles so that your liability can be eliminated from the mortgage on the house,
PLAINTIFF'S
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ShblJld you choose not to resp,ond o~ not to respond favorably to this request on
or before January 9, 2004, I shall file the necessary petition with the court seeking costs
and legal fees to be assessed against you for reimbursement to Melanie as a result of
your lack of cooperation; in addition, I shall request that the court order your signing of
transfer of title or its equivalent.
Sincerely,
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GALEN R. WALTZ, Esquire
Gwaltz@TuroLaw,com
GRW/jge
c.c, Melanie LUjanac
Certified Return Receipt
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Melanie J, Lujanac (Eslinger),
Petitioner
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: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO, 00-6927
Michael p, Lujanac,
Respondent
: CIVIL ACTION - LAW
: IN DIVORCE
VERIFICATION
I verify that the statements made in the foregoing Petition For Special Relief are
true and correct. I understand that false statements herein are made subject to the
penalties of 18 Pa,C,S, 94904 relating to unsworn falsification to authorities,
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I hereby certify that I served a true and correct copy of the Petition For Special
Relief upon Michael P. Lujanac, by depositing same in the United States Mail, first
class, Certified Return Receipt on the ":<0 day of 30.),)110, ' 2004, from
Carlisle, Pennsylvania, addressed as follows:
Michael Lujanac
1777 Sheepsford Road
Mechanicsburg, PA 17055
TURO LAW OFFICES
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28 South Pitt Street
Carlisle, PA 17013
(717) 245-9688
Attorney for Petitioner
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Michael P. Lujanac,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 00-6927
v,
Melanie J. Lujanac,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
Melanie J. Lujanac, Defendant, by and through her attorney, Galen R. Waltz, moves the
Court to appoint a Master with respect to the following claims: divorce, alimony pendente lite,
distribution of property, counsel fees, costs and expenses and in support of the motion states:
1. Discovery appears to be complete as to the claims for which the appointnnent of
a Master is requested,
2. The Defendant has appeared in the action by her attorney, Galen Waltz, Esquire, '
3. The statutory ground for divorce is 3301 (c)/(d).
4. The action is contested with respect to the following claims: the Def<endant
believes and therefore avers that the brevity of marriage (5 years), the substantial lack of
contribution to the marital estate by the Plaintiff, the Plaintiff's extra-marital indulgencl~s, the
Plaintiff's "daytrading" squandering of marital assets, the Plaintiff's consistent lack of
employment during the brief marital years, and the Plaintiff's waiver of interest towclrd the
Defendant's pension serve to negate any presumed validity of the Plaintiff's spurious claims to
the Defendant's real property, pension or other property,
5, The action does not involve complex issues of law or fact.
6. The hearing is expected to take 11, to % days.
Respectfully Submitted
TURO LAW OFFICES
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a en R. Waltz, Es
28 South Pitt Stree
Carlisle, PA 17013
(717) 245-9688
Attorney for Defendant
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CERTIFICATE OF SERVICE
I hereby certify that I served a true and correct copy of the Motion For Appointment
Of Master upon Mindy S, Goodman, Esquire, by depositing same in the United States
Mail, first class, postage pre-paid on the 16th day of November, 2001, from Carlisle,
Pennsylvania, addressed as follows:
Mindy S. Goodman
Attorney at Law
2080 Linglestown Road
Harrisburg, PA 17110
TURO LAW OFFICES
en R. Waltz, Esquir
28 South Pitt Street
Carlisle, PA 17013
(717) 245-9688
Attorney for Defendant
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Defendant
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: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 00-6927
: CIVIL ACTION - LAW
: IN DIVORCE
ORDER APPOINTING MASTER
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AND NOW, this IX day of
? ~.JAr f(b~,,) , is appointed Master wi
claims: divorce, , alimony pendente lite, distribution of property,
expenses.
c.c:r.1Aichael P. Lujanac
Aalen R. Waltz, Esquire
(attorney for Defendant)
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BY THE COURT,
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counsel fees, costs and
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Michael P. Lujanac,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 00-6927
v.
Melanie J. Lujanac,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
Melanie J. Lujanac, Defendant, by and through her attorney, Galen R. Waltz. moves the
Court to appoint a Master with respect to the following claims: divorce, alimony pendente lite,
distribution of property, counsel fees, costs and expenses and in support of the motion states:
1. Discovery appears to be complete as to the claims for which the appointment of
a Master is requested.
2. The Defendant has appeared in the action by her attorney, Galen Waltz, Esquire.
3. The statutory ground for divorce is 3301 (c)/(d).
4. The action is contested with respect to the following ciaims: the Defendant
believes and therefore avers that the brevity of marriage (5 years), the substantial Ilack of
contribution to the marital estate by the Plaintiff, the Plaintiff's extra-marital indulgencl9s, the
Plaintiff's "daytrading" squandering of marital assets, the Plaintiff's consistent lack of
employment during the brief marital years, and the Plaintiff's waiver of interest toward the
Defendant's pension serve to negate any presumed validity of the Plaintiff's spurious claims to
the Defendant's real property, pension or other property.
5. The action does not involve complex issues of law or fact.
6. The hearing is expected to take Yo to % days.
7. Former counsel of record, Mindy S. Goodman was granted permis!;ion to
withdraw as counsel for plaintiff on June 7,2002
8. To the best of Defendant's knowledge Plaintiff is "pro se."
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CERTIFICATE OF SERVICE
I hereby certify that I served a true and correct copy of the Motion For Appoil1tment
Of Master upon Michael P. Lujanac, by depositing same in the United States Mail, first
class, postage pre-paid on the 24th day of July, 2003, from Carlisle, Pennsylvania,
addressed as follows:
Michael P. Lujanac
1777 Sheeps Ford Road
Mechanicsburg, PA 17055
TURO LAW OFFICES
C'
. Ga en R. Waltz, Es
28 South Pitt S
Carlisle, PA 17013
(717) 245-9688
Attorney for Defendant
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MICHAEL P. LUJANAC,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Vs.
NO. 00- 6927 CIVIL
MELANIE J. LUJANAC,
Defendant
IN DIVORCE
ORDER OF COURT
AND NOW, this
/(, 7'.
day
of ~U.7
th discovery is
2002, Plaintiff's counsel having indicated
incomplete and Defendant's counsel not having responded to
the Master's inquiry regarding certification of discovery,
and neither counsel having responded to the Master's letter
dated December 13, 2001, regarding the status of the divorce
and economic claims, the appointment of the Master is
vacated.
BY THE COURT,
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cc: Mindy S. Goodman
Attorney for plaintiff
Galen R. Waltz
Attorney for Defendant
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MICHAEL P. LUJANAC,
Plaintiff
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00 - 6927 CIVIL
MELANIE J. LUJANAC,
Defendant
IN DIVORCE
TO:
Michael P. Luzanac
, 1';L LULlle:y [or Plaintiff
Galen R. Waltz I.!<<fo. Defendant
DATE: Monday, August 11, 2003
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
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(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
DATE
COUNSEL FOR PLAINTIFF
COUNSEL FOR DEFENDANT
NOTE:
PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
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MICHAEL P. LUJANAC,
Plaintiff
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00 - 6927 CIVIL
MELANIE J. LUJANAC,
Defendant
IN DIVORCE
TO:
Michael P. Luzanac
, ..."".ttO.L!h"'l for Plaintiff
Galen R. Waltz
~~
Defendant
DATE: Monday, August 11, 2003
CERTIFICATION
---- ,:.C?-~::--- --_____
----I certify that discovery is complete as to the Claim~)
for which the Master has been appointed.
--
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
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(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
NOTE:
0~A~
DATE
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PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
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MICHAEL P. LUJANAC, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v. : NO. 00-6927
MELANIE J. LUJANAC, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
PRAECIPE TO WITHDRAW AS COUNSEL FOR DEFENDANT
TO THE PROTHONOTARY:
Kindly withdraw the Appearance of Mindy S. Goodman, Attorney at Law,
as counsel for the Plaintiff pursuant to the Court's Order of June 7, 2002
permitting withdrawal.
Date: (". - I c> 'oz..-
~'SG~
Mindy S. Goodman
Attorney at Law
10 No. 78407
2215 Forest Hills Drive - Suite 35
Northwood Office Center
Harrisburg,PA 17112
(717) 540-8742
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MICHAEL P. LUJANAC,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-6927
: CIVIL ACTION - LAW
: IN DIVORCE
MELANIE J. LUJANAC,
Defendant
~ ORDER
AND NOW, this X- day Of~, 2002, upon showing
of good and sufficient reason for permission to withdraw, this Honorable Court
hereby grants the Petition on behalf of Mindy S. Goodman, Attorney at Law, for
allowance to withdraw as counsel for Plaintiff.
BY THE COURT:
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MICHAEL P. LUJANAC,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-6927
: CIVIL ACTION - LAW
: IN DIVORCE
MELANIE J. LUJANAC,
Defendant
PETITION TO MAKE RULE ABSOLUTE
1. On April 9, 2002, Plaintiff's counsel filed a Petition to Wtihdraw
Appearance as Counsel for Plaintiff. Attached hereto and marked
as Exhibit "A" and incorporated herein by reference is a copy of
said Petition.
2. On April 12, 2002, this Court, by the Honorable George E. Hoffer,
issued a Rule on Plaintiff to show cause, if any there be, why
counsel's petition should not be granted. The Rule was returnable
twenty (20) days after service of the Order. Attached hereto and
marked as Exhibit "B" and incorporated herein by reference is a
copy of said Rule.
3. On April 14, 2002, undersigned counsel forwarded to Defendant's
counsel and Plaintiff a copy of the executed Rule to Show Cause.
The green return receipt indicated that the same was delivered to
Plaintiff on May 8, 2002. Attached hereto and marked as Exhibit
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"C" and incorporated herein by reference is the green return receipt
card.
4. To date, which is more than twenty (20) days after service of the
Rule, neither Defendant nor Plaintiff have raised any opposition to
the Petition to Withdraw.
WHEREFORE, undersigned counsel respectfully requests that this
Honorable Court make the Rule on April 12, 2002 absolute and grant the Petition
allowing Mindy S. Goodman, Attorney at Law, to withdraw as counsel for Plaintiff.
By: ~~~.~.,jL____
Mindy S. Goodman
Attorney at Law
10 No. 78407
2215 Forest Hills Drive - Suite 35
Northwood Office Center
Harrisburg, PA 17112
(717) 540-8742
. Date: :5' l. 'I ' 0 z..
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MICHAEL P. LUJANAC,
Plaintiff
v.
: IN THE COURT OF COMMOt;J.PL~AS ....
: CUMBERLAND COUNTY, PENN~J...V-,\~IA
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: NO. 00-6927
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MELANIE J. LUJANAC,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
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PETITION OF MINDY S. GOODMAN, ESQUIRE
TO WITHDRAW APPEARANCE AS COUNSEL FOR PLAINTIFF
Mindy S. Goodman, Esquire, hereby respectfully petitions this Honorable
Court for leave to withdraw her appearance as counsel for Plaintiff and in support
thereof avers as follows:
1. Petitioner is Mindy S. Goodman, Attorney at Law.
2. Respondent is Michael P. Lujanac, an adult individual who currently
resides at 1777 Sheepford Road, Mechanicsburg, Pennsylvania
17055.
3. Petitioner was retained by Respondent on or about ,September 20,
2000 to represent Respondent in the above-captioned divorce
matter.
4. Petitioner has undertaken representation but is unable to continue
because Respondent has failed to pay Petitioner's fees as billed in
accordance with their Representation Agreement.
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5. Pursuant to the Representation Agreement entered into between
the Petitioner and the Respondent, a copy of which is attached
hereto as Exhibit "A," Respondent agreed to remit payments on a
current basis. In spite of attorney's reduced hourly rate and bills
being sent on a monthly basis, Respondent has made not payment
toward Petitioner's fees for a period of five months.
6. Pursuant to the Representation Agreement, Petitioner reserved the
right to terminate the attorney-client relationship for non-payment of
fees if no alternate payment arrangements could be made.
7. No alternate arrangements have been made for billing and
Petitioner does not believe that Respondent will pay the required
trial retainer as this case will likely be listed for a hearing in the next
few months.
8. Presently, billings have been outstanding for significantly more than
thirty (30) days and the Respondent has ignored Petitioner's efforts
to collect payment for services rendered.
9. Petitioner has notified Respondent of the overdue account balance
on a monthly basis and said notices have included a warning by
Petitioner that she would be withdrawing from this matter if
Respondent's account was not brought current.
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WHEREFORE, counsel for Defendant respectfully requests this
Honorable Court to grant the Petition to Withdraw Appearance and allow Mindy
S. Goodman, Esquire to withdraw as counsel.
Date: '1- 4 -"Z-
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Mindy S. Goodman
Attorney at Law
2215 Forest Hills Drive - Suite 35
Northwood Office Center
Harrisburg, PA 17112
(717) 540-8742
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September 27,2000
Mr. Michael P. Lujanac
1777 Sheepford Road
Mechanicsburg, PA 17055
Re: Divorce
Dear Mr. Lujanac:
It was a pleasure meeting you in my office yesterday afternoon. Thank you for
your confidence in retaining me to represent you in your domestic relations
matters. Understandably, the matter of legal fees and expenses is of utmost
importance to you. Because of the complexities inherent in our legal system, it is
Impossible to give you an exact idea as to what the total fees and expenses will
be. Nevertheless, I think it is important to set forth this letter outlining the basis
on which fees and expenses will be charged in the future.
1. Basis for Charging Legal Fees: The minimum fee will be based on
the time charges that I spend working on your case, including but not limited to
telephone calls, research, drafting documents, and court appearances. My
charges are on an assigned hourly rate, whether in or out of court. My fees will
be billed at a reduced hourly rate of $115.00, and each hour will be broken into
tenths for billing purposes.
2. Costs: You will be responsible for all out-of-pocket expenses
incurred on your behalf. This would include, but not be limited to, filing fees,
transcripts, depositions, photocopies, service of subpoenas and witness fees,
long-distance telephone calls, FAX transmittals, express mail, certified mail,
investigative expenses, accounting expenses, costs of legal research by
computer (Lexis/Nexis & Westlaw), photographs, and notes of testimony from
hearings. It will be necessary for you to advance the money for those costs upon
request. Should I advance costs on your behalf, you will be expected to remit a
check each month for costs advanced.
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3. Billing: For your information and records, I will be sending you a
periodic statement, approximately monthly, reflecting my time charges, costs
advanced, and other charges through the given date. Costs advanced will be
reflected as a separate item on your bill and payment of same is expected
monthly, If you have any questions concerning the bill, do not hesitate to
communicate with me, If payments on my bills are not made on a current basis, I
reserve the right to charge interest on any outstanding past due balance of legal
fees and costs at a rate of 2% per month. In addition it is the policy of this office
to suspend activity in those cases where outstanding balances are more than 30
days overdue, unless other arrangements for payment have been agreed in
writing. I reserve the right to terminate our attorney-client relationship for non-
payment of fees for services. I will under no circumstance continue
representation if your balance exceeds $300.00 and is not paid within 30 days of
demand unless other arrangements have been agreed to in writing.
4. Retainer Fee: The retainer fee for undertaking your legal
representation Is $500.00 plus filing fees. The filing fee for a divorce In
Cumberland County is $185.50. Said retainer fee will be placed in a client trust
account, and will be applied against any time and fees expended on your behalf.
Your periodic billing will reflect any balance remaining. At such time as there is
no longer a credit balance, you will be expected to make payment of any
amounts due upon receipt of my bill. If your matter is concluded and a balance
remains, said balance will be refunded to you promptly. As previously indicated,
I am not able to anticipate or estimate at this time what the total fees and
expenses may be at the end of your case. In the event that your divorce matter
would go to a full hearing or trial, and I see absolutely no reason that it should
come to that, I reserve my right to require an additional hearing or trial retainer of
at least $1500.00 to cover our preparation time.
5. Cancellation of Contract: In addition to my right to cancel my
representation of you as discussed in Paragraph 3, I retain the right to cancel this
contract if you become uncooperative or for any other reasonable circumstance.
Similarly, you have the right to cancel this contract if, for any reason, you are
dissatisfied with my representation of you. If you do cancel this contract, you
remain obligated to pay any outstanding balance for services rendered on your
behalf, as well as to compensate me for any out-of-pocket expenses expended
on your behalf. If I am forced to pursue a collection action for the outstanding
balance owed, you agree to pay all costs incurred with regard to such collection,
including but not limited to attorney's fees.
You acknowledge that I have made no guarantees as to the disposition of
any phase of this matter or matters for which I have been retained, and that
statements made by me are opinions only, based on my experience in the
practice of law.
Please acknowledge receipt of this letter and your acceptance of its terms and
conditions by signing the original fee agreement and returning it to me, along with
the $685.50 retainer fee, in the envelope provided. You may retain the copy of
this letter for your personal records.
Very truly yours,
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Mindy S. Goodman
I have read the foregoing letter and I agree to its terms.
Date: q/;< ~t Q
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Signature:
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APR 11 2002 1)
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MICHAEL P. LUJANAC,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-6927
MELANIE J. LUJANAC,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
RULE
) :Z-M day of ~ t'\ ~\)
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is hereby issued on Plaintiff and Defendant to show cause, if any there be, why
AND NOW, this
, 2002, a Rule
Plaintiffs counsel, Mindy S. Goodman, Esquire, should JO~ be^gra~ed leave to .
withdrawascounse~ ~ :<.0 ~~~J
BY THE COURT:
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. -Compiet~ ltQms 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
.' Print your nanie' and address on the reverse
so that we can ret\,!m the card to you.
.. Attach this card to ~he back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
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3. Service Type
. 0 Certified Mail 0 Express Mail
o Registered 0 Return Receipt for Merchandise
o Insured Mail 0 C.O.D.
4. Restricted Delivery? (Extra Fee) 0 Yes
2. Article N.ulTJber (Qopy frp{T1 servil?f! lap~Q , .. . . , . . , . . . .. .
At6 'i1 \!"i!,l./Jb>::doiiT~' ,{': ~:41~H
PS Form 3811. July 1999 Domestic Relurn Receipt
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MICHAEL P. LUJANAC,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 00-6927
MELANIE J. LUJANAC,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
PLAINTIFF'S OBJECTIQNS TO MOTION FOR
AND APPOINTMENT OF MASTER
AND NOW, comes the Plaintiff, Michael P. Lujanac, by and through his
attorney, Mindy S. Goodman, Attorney at Law, and files these objections to the
Motion for Appointment of and Appointment of Master filed on behalf of
Defendant, and avers as follows:
1. Plaintiff was never informed by telephone or correspondence, nor
was Plaintiff served a copy of the Motion for Appointment of Master
filed by Defendant on November 19, 2001. Plaintiff first received
notice of the Motion for Appointment and the Order Appointing
Master on November 26, 2001, when copies were sent to Plaintiff
via facsimile. (A copy of the fax is attached hereto as Exhibit A.)
2. This matter is not yet ready for a hearing before a Master because:
(a) Defendant has not filed her Inventory and Appraisement;
and
(b) While Defendant did initially file the divorce action under
Sections 3301 (c) and 3301 (d) of the divorce codes, he now
contents the finalization of this divorce and since the parties
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have not been separated for two years, this case is not ripe
for a Master's hearing; and
(c) No appraisal of the marital residence has been done and
therefore discovery is not complete.
3. Until such time as Defendant files and Inventory and Appraisement,
the marital residence has been appraised, and until the parties
have been separated for two years, said matter should not be
referred to and heard by the Master.
WHEREFORE, for the reasons set forth herein, Plaintiff respectfully
objects to the Motion for Appointment of Master and Order Appointing Master
and requests that the Order be vacated and the matter not yet referred until an
Inventory and Appraisement is filed by Defendant, the marital residence is
appraised, and until the parties have been separated for two years.
Respectfully submitted,
\~~~-
Mindy S. Goodman
Attorney at Law
10 NO. 78407
2215 Forest Hills Drive - Suite 35
Harrisburg, PA 17112
(717) 540-8742
Attorney for Plaintiff
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MICHAEL P. LUJANAC,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-6927
MELANIE J. LUJANAC,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
RULE
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AND NOW, this JV day of
.
, 2002, a Rule
is hereby issued on Plaintiff and Defendant to show cause, if any there be, why
Plaintiff's counsel, Mindy S. Goodman, Es uire, should not be gran~ ~~ve to
withdraw as counsel. 2....0 ~.r
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CUIVi8EiiLi!1'iC COUNlY
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MICHAEL P. LUJANAC,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-6927
MELANIE J. LUJANAC,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
PETITION OF MINDY S. GOODMAN. ESQUIRE
TO WITHDRAW APPEARANCE AS COUNSEL FOR PLAINTIFF
Mindy S. Goodman, Esquire, hereby respectfully petitions this Honorable
Court for leave to withdraw her appearance as counsel for Plaintiff and in support
thereof avers as follows:
1. Petitioner is Mindy S. Goodman, Attorney at Law.
2. Respondent is Michael P. Lujanac, an adult individual who currently
resides at 1777 Sheepford Road, Mechanicsburg, Pennsylvania
17055.
3. Petitioner was retained by Respondent on or about September 20,
2000 to represent Respondent in the above-captioned divorce
matter.
4. Petitioner has undertaken representation but is unable to continue
because Respondent has failed to pay Petitioner's fees as billed in
accordance with their Representation Agreement.
1
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5. Pursuant to the Representation Agreement entered into between
the Petitioner and the Respondent, a copy of which is attached
hereto as Exhibit "A," Respondent agreed to remit payments on a
current basis. In spite of attorney's reduced hourly rate and bills
being sent on a monthly basis, Respondent has made not payment
toward Petitioner's fees for a period of five months.
6. Pursuant to the Representation Agreement, Petitioner reserved the
right to terminate the attorney-client relationship for non-payment of
fees if no alternate payment arrangements could be made.
7. No alternate arrangements have been made for billing and
Petitioner does not believe that Respondent will pay the required
trial retainer as this case will likely be listed for a hearing in the next
few months.
8. Presently, billings have been outstanding for significantly more than
thirty (30) days and the Respondent has ignored Petitioner's efforts
to collect payment for services rendered.
9. Petitioner has notified Respondent of the overdue account balance
on a monthly basis and said notices have included a warning by
Petitioner that she would be withdrawing from this matter if
Respondent's account was not brought current.
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WHEREFORE, counsel for Defendant respectfully requests this
Honorable Court to grant the Petition to Withdraw Appearance and allow Mindy
S. Goodman, Esquire to withdraw as counsel.
Date: t1 - 4 -., z..
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Mindy S. Goodman
Attorney at Law
2215 Forest Hills Drive - Suite 35
Northwood Office Center
Harrisburg, PA 17112
(717) 540-8742
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September 27, 2000
Mr. Michael P. Lujanac
1777 Sheepford Road
Mechanicsburg, PA 17055
Re: Divorce
Dear Mr. Lujanac:
It was a pleasure meeting you in my office yesterday afternoon. Thank you for
your confidence in retaining me to represent you in your domestic relations
matters. Understandably, the matter of legal fees and expenses is of utmost
importance to you. Because of the complexities inherent in our legal system, it is
impossibleto give you an exact idea as to what the total fees and expenses will
be. Nevertheless, I think it is important to set forth this letter outlining the basis
on which fees and expenses will be charged in the future.
1. Basis for Charging Legal Fees: The minimum fee will be based on
the time charges that I spend working on your case, including but not limited to
telephone calls, research, drafting documents, and court appearances. My
charges are on an assigned hourly rate, whether in or out of court. My fees will
be billed at a reduced hourly rate of $115.00, and each hour will be broken into
tenths for billing purposes.
2. Costs: You will be responsible for all out-of-pocket expenses
incurred on your behalf. This would include, but not be limited to, filing fees,
transcripts, depositions, photocopies, service of subpoenas and witness fees,
long-distance telephone calls, FAX transmittals, express mail, certified mail,
investigative expenses, accounting expenses, costs of legal research by
computer (Lexis/Nexis & Westlaw), photographs, and notes of testimony from
hearings. It will be necessary for you to adlvance the money for those costs upon
request Should I advance costs on your behalf, you will be expected to remit a
check each month for costs advanced.
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3. Billing: For your information and records, I will be sending you a
periodic statement, approximately monthly, reflecting my time charges, costs
advanced, and other charges through the given date. Costs advanced will be
reflected as a separate item on your bill and payment of same is expected
monthly. If you have any questions concerning the bill, do not hesitate to
communicate with me. If payments on my bills are not made on a current basis, I
reserve the right to charge interest on any outstanding past due balance of legal
fees and costs at a rate of 2% per month. In addition it is the policy of this office
to suspend activity in those cases where outstanding balances are more than 30
days overdue, unless other arrangements for payment have been agreed in
writing. I reserve the right to terminate our attorney-client relationship for non-
payment of fees for services. I will under no circumstance continue
representation if your balance exceeds $300.00 and is not paid within 30 days of
demand unless other arrangements have been agreed to in writing.
4. Retainer Fee: The retainer fee for undertaking your legal
representation is $500.00 plus filing fees. The filing fee for a divorce in
Cumberland County is $185.50. Said retainer fee will be placed in a client trust
account, and will be applied against any ti~e and fees expended on your behalf.
Your periodic billing will reflect any balanc~ remaining. At such time as there is
no longer a credit balance, you will be exp~cted to make payment of any
amounts due upon receipt of my bill. If your matter is concluded and a balance
remains, said balance will be refunded to you promptly. As previously indicated,
I am not able to anticipate or estimate at this time what the total fees and
expenses may be at the end of your case. In the event that your divorce matter
would go to a full hearing or trial, and I see absolutely no reason that it should
come to that, I reserve my right to require an additional hearing or trial retainer of
at least $1500.00 to cover our preparation time.
5. Cancellation of Contract: In addition to my right to cancel my
representation of you as discussed in Par~graph 3, I retain the right to cancel this
contract if you become uncooperative or for any other reasonable circumstance.
Similarly, you have the right to cancel this Gontract if, for any reason, you are
dissatisfied with my representation of you. If you do cancel this contract, you
remain obligated to pay any outstanding balance for services rendered on your
behalf, as well as to compensate me for any out-of-pocket expenses expended
on your behalf. If I am forced to pursue a collection action for the outstanding
balance owed, you agree to pay all costs incurred with regard to such collection,
including but not limited to attorney's fees.
You acknowledge that I have made no guarantees as to the disposition of
any phase of this matter or matters for which I have been retained, and that
statements made by me are opinions only, based on my experience in the
practice of law.
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Please acknowledge receipt of this letter and your acceptance of its terms and
conditions by signing the original fee agreement and returning it to me, along with
the $685.50 retainer fee, in the envelope provided. You may retain the copy of
this letter for your personal records.
Very truly yours,
~3~
Mindy S. Goodman
I have read the foregoing letter and I agree to its terms.
Date: ~~-o
Signature:
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MICHAEL P. LUJANAC,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 00-6927
MELANIE J. LUJANAC,
Defendant
: CIVIl:.. ACTION - LAW
: IN DIVORCE
ORDER
AND NOW, this
day of
, 2001 . after
reviewing Plaintiff's Objections to Motion for and Appointment of Master, the
Order Appointing Master dated November 21, 2001 is VACATED until Defendant
files her Inventory and Appraisement, the marital residence has been appraised,
and the parties have been separated two years. After these matters have been
completed, a Master will be appointed.
BY THE COURT:
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MICHAEL P. LUJANAC,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 00-6927
MELANIE J. LUJANAC,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
PLAINTIFF'S OBJECTIONS TO MOTION FOR
AND APPOINTMENT OF MASTER
AND NOW, comes the Plaintiff, Michael P. Lujanac, by and through his
attorney, Mindy S. Goodman, Attorney at Law, and files these objections to the
Motion for Appointment of and Appointment of Master filed on behalf of
Defendant, and avers as follows:
1. Plaintiff was never informed by telephone or correspondence, nor
was Plaintiff served a copy of the Motion for Appointment of Master
filed by Defendant on November 19, 2001. Plaintiff first received
notice of the Motion for Appointment and the Order Appointing
Master on November 26, 2001, when copies were sent to Plaintiff
via facsimile. (A copy of the fax is attached hereto as Exhibit A.)
2. This matter is not yet ready for a hearing before a Master because:
(a) Defendant has not filed her Inventory and Appraisement,
and
(b) While Defendant did initially file the divorce action under
Sections 3301 (c) and 3301(d)ofthe divorce codes, he now
contents the finalization of this divorce and since the parties
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have not been separated for two years, this case is not ripe
for a Master's hearing; and
(c) No appraisal of the marital residence has been done and
therefore discovery is not complete.
3. Until such time as Defendant files and Inventory and Appraisement,
the marital residence has been appraised, and until the parties
have been separated for two years, said matter should not be
referred to and heard by the Master.
WHEREFORE, for the reasons set forth herein, Plaintiff respectfully
objects to the Motion for Appointment of Master and Order Appointing Master
and requests that the Order be vacated and the matter not yet referred until an
Inventory and Appraisement is filed by Defendant, the marital residence is
appraised, and until the parties have been separated for two years.
Respectfully submitted,
~.~~~=-SL '--
Mindy S. Goodman
Attorney at Law
10 NO. 78407
2215 Forest Hills Drive - Suite 35
Harrisburg, PA 17112
(717) 540-8742
Attorney for Plaintiff
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CERTIFICATE OF SERVICE
A true and correct copy of the foregoing document was delivered to the
person or office listed below by first class mail on the date indicated, as follows:
Galen R. Waltz, Esquire
Turo Law Offices
28 S. Pitt Street
Carlisle, PA 17013
Date: I/-Z"i',-, I
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Mindy S. Goodman
Attorney at Law
2215 Forest Hills Drive - Suite 35
Harrisburg, PA 17112
(717) 540-8742 ,
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(717) 245-9808
(800) 562.9778
Fax (717) 245-2165
RON TURO, Esquire
ROBERT J, MULDERIG, ES<lulre
GALEN R. WALTZ, Esquire
JAMES M, ROBINSON. Esqvire
CAROL L.. CINGRANELLI, Efquire
GERARD J FOULKE, Esquire
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FAX COVER SHEET
PLEASE DELIVER THE FOLLOWING PAGES TO:
FAX# 5~o-f743
DATE:
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PLEASE CALL OUR OFFICE AT (717) 245-9688 IF YOU DID NOT RECEIVE THE
COMPLETE FAX TRANSMISSION. THANK YOU.
....................--..........................................**............................**....
CONFIDENTIALITY NOTICE: This facsimile contains confidential information, which
may be legally privileged and which is intended only for the use of the Addressee(s)
named above. If you are not the Intended recipient, or the employee or agent
responsible for delivering it to the intended recipient, you are hereby notified that any
dissemination or copying of this facsimile, or the taking of any action in reliance on the
contents of this telecopied information may be strictly prohibited. If you have received
this facsimile in error, please notify us immediately by phone and return the entire
facsimile to us via the U.S. Postal Service. Thank you.
...............................**...................,........................................**.....
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ORDER APPOINTING MASTER
AND NOW, this ol/A-i day of I~ 2001,
f eJ.,. oJ , Is appointed Master with respect to the following
claims: dlvort:e, , alimony pendente lite, distribution of property, counll81 fees, costs arid
expenses.
BY THE COURT.
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Michael P. Lujanac,
Plaintiff
Melanie J. Lulanac,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
: IN THE COURT OF COMMO"HlL~ Qf?,
: CUMBERLAND COUNTY, PE~S'fWANIA
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: NO. 00-6927 z:)
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" MQTIQ~R APPOINTMENT 01: MASTeR \
Melanie J. Lujanac, Defendant, by and through her attorney. Galen R. Waltz, moves the i
Court to appoint a Master with respect to the follOWIng daims: divorce, alimony pendente Iilll.
dl6trlbutlon of property, counsel fees, costs and expenses and In support of the motion states:
i 1. Discovery appears to be complete as to the claims for whiCh the appointment (If I
I a Master is requested.
i 2. The Defendant has appeared In the action by her attorney, Galen Waltz. ESQUirE'. I
I 3. The statutory ground for divorce is 3301 (c)/(d). I
, 4. The action is contested with respect to the following claimll: the Defender!t
believes and therefore avers that the brevity of marriage (6 years), the substantial lack cof
contribution to the marital estate by the PlalnUff. the Plaintiff's extra-marital indulgences. thle
Plaintiff's "daytrading" SQuandering of marital assets, the Plaintiff's consistent lack elf I
,
employment during the brief marital years, and the Plaintiff's waiver of Interest toward the
Defendant's pension serve to negate any presumed validity of the Plaintlff's spurious claims II)
the Defendant!& real property, pension or other property.
5. The action does not Involve complex Issues of law or fact.
6. The hearing Is expected to take 'AI to % days.
Respectfully Submitted
TURO LAW OFFICES
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n R. Waltz, Eli
28 South Pitt Stree
Carlisle, PA 17013
(717) 245-9688
Attorney for Defendant
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CERTIFICATE OF SERVI(t~
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I hereby certify that I served a true and correct copy of the Molion For Appointmet~t II
Of Master upon Mindy S. Goodman, Esquire, by depositing same In the United States
Mail, first class, postage pre-paid on the 1611I day of November, 2001. from C8niShl.1
Pennsylvania, addressed as follows: I
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Mindy S. Goodman
Attorney at Law
2080 L1nglestown Road
Harrisburg, PA 17110
TURO LAW OFFICES
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en R. Waltz, squl
28 South Pitt Street
Car1lsle. PA 17013
(717) 245-9888
Attomey for Defendant
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MICHAEL P. LUJANAC,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 00-6927
MELANIE J. LUJANAC,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
ORDER
AND NOW, this
day of
, 2001 , after
reviewing Plaintiff's Objections to Motion for and Appointment of Master, the
Order Appointing Master dated November 21,2001 is VACATED until Defendant
files her Inventory and Appraisement, the marital residence has been appraised,
and the parties have been separated two years. After these matters have been
completed, a Master will be appointed.
BY THE COURT:
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MICHAEL P. LUJANAC,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY. PENNSYLVANIA
vs.
: NO. 00~6927
MELANIE J. LUJANAC,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
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AND NOW, comes the Plaintiff, Michael P. Lujanac, by and thro~li'his t:?
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attorney, Mindy S. Goodman, Attorney at Law. and files these objections ~ the"" ?;;1
PLAINTIFF'S OBJECTIONS TO MOTION FOR
AND APPOINTMENT OF MASTER
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Motion for Appointment of and Appointment of Master filed on behalf of
Defendant, and avers as follows:
1. Plaintiff was never informed by telephone or correspondence, nor
was Plaintiff served a copy of the Motion for Appointment of Master
filed by Defendant on November 19, 2001. Plaintiff first received
notice of the Motion for Appointment and the Order Appointing
Master on November 26, 2001, when copies were sent to Plaintiff
via facsimile. (A copy of the fax is attached hereto as Exhibit A.)
2. This matter is not yet ready for a hearing before a Master because:
(a) Defendant has not filed her Inventory and Appraisement,
and
(b) While Defendant did initially file the divorce action under
Sections 3301 (c) and 3301 (d) of the divorce codes, he now
contents the finalization of this divorce and since the parties
." 1!ilIlll.';:il'I'
have not been separated for two years, this case is not ripe
for a Master's hearing; and
(c) No appraisal of the marital residence has been done and
therefore discovery is not complete.
3. Until such time as Defendant files and Inventory and Appraisement,
the marital residence has been appraised, and until the parties
have been separated for two years, said matter should not be
referred to and heard by the Master.
WHEREFORE, for the reasons set forth herein, Plaintiff respectfully
objects to the Motion for Appointment of Master and Order Appointing Master
and requests that the Order be vacated and the matter not yet referred until an
Inventory and Appraisement is filed by Defendant, the marital residence is
appraised, and until the parties have been separated for two years.
Respectfully submitted,
~~~=-!2- "-
Mindy S. Goodman
Attorney at Law
10 NO. 78407
2215 Forest Hills Drive - Suite 35
Harrisburg, PA 17112
(717) 540-8742
Attorney for Plaintiff
~"
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CERTIFICATE OF SERVICE
A true and correct copy of the foregoing document was delivered to the
person or office listed below by first class mail on the date indicated, as follows:
Galen R. Waltz, Esquire
Turo Law Offices
28 S. Pitt Street
Carlisle, PA 17013
Date: / ( - z., - ...., 1
i~S-z;.~ ",--,
Mindy S. Goodman
Attorney at Law
2215 Forest Hills Drive - Suite 35
Harrisburg, PA 17112
(717) 540-8742
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28 South Pill $treei
Carlisle. Pennsylvania 1701<\
(717) 245-9688
(800) 562.9778
Fax (717) 245-216"
RON TURD, Esquire
ROBERT J. MULDERIG. Esquire
GAlEN R WAlTZ, Esquire
JAMES M. ROBINSON, Esquire
CAROL L. CINGRANEI.LI, Esquire
GERARO J. FOULKE. Esquire
",'-,"
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FAX COVER SHEET
PLEASE DELIVER THE FOLLOWING PAGES TO:
FAX # :5 ~o-f 7 tj3
DATE:
<))~hJOI
f ,
PLEASE CALL OUR OFFICE AT (717) 245-9688 IF YOU DID NOT RECEIVE THE
COMPLETE FAX TRANSMISSION. THANK YOU.
...*.~....*.*..................*.......*......*........................*...*..................t.***.
CONFIDENTIALITY NOTICE: This facsimile contains confidential information, which
may be legally privileged and which is intendlild only for the use of the Addressee(s)
named above. ' If you are not the Intende~ recipient, or the employee or agent
responsible for delivering it to the intended reeipient, you are hereby notified that any
dissemination or copying of this facsimile, or th taking of any action in reliance on the
contents of this telecopied information may be, strictly prohibited. If you have received
this facsimile in error, please notify us immE!diately by phone and return the entire
facsimile to us via the U.S. Postal Service. Thank you.
.....................~...*...._................*..........................................*..-_....
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ORDER A.PPOINTlNG MASTER
NOW. this ,,)1..-...1 day of IL.-t~,___ 2001,
, Is appointed Master with respect to the followins
alimony pendente lite, distribution of property, counsel fees, costs and I
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BY THE COURT, I
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TRUE COpy FROM RECORD
In TrntlrN\:'!'fVfhl:r~I,1 herl1l)1110 s.,"t my hand
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Michael P. Lujanac,
Plaintiff
Melanie J. luJanac,
Defendant
; CIVIL ACTION - LAW
; IN DIVORCE
: IN THE COURT OF COMMO"H'LEi;AS OF,
: CUMBERLAND COUNTY, PE~S~WAN'IA
. .~ 14 ,"I
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; NO. 00-6927 9-. \}' ':': -
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Melanie J. Lujanac. Defendant, by and through her attorney, Galen R. Waltz. moves the !
Court to appoint a Master with respect to the following Claims: divorce, alimony pendente lite, I
distribution of property, counsel fees, oasts and expenses and in support of the molion states:
I
i 1. Discovery appears to be complete as to the claims for which the appointment of I
a Master is requested.
I
2. The Defendant has appeared In the action by her attorney, Galen Waltz, Esquire. I
3_ The statutory ground for divorce is 3301 (c}/(d). I
,
4. The action is contested with respect to the following claims: the Defendant
believes and therefore avers that the brevity of marriage (5 years), the substantial lack of
contribution to the marital estate by the PlalnU<<, the Plaintiff's extra-marital indulgences, the
Plaintiff's "daytreding" squandering of marital assets, the Plaintiff's consistent lac!< of,
,
employment during the brief marital years. and the Plaintiff's waiver of interest toward the
Defendant's pension serve to negate any presumed validity of the Plaintiff's spurious claims to
the Defendant. resl property, pension or other property.
5. The setton does not Involve complex Issues of law or fact.
6. The hearing Is expected to take Y.. to ~ days.
MOTION FOR APPOINTMENT OF: MUTER
Respectfully Submitted
TURO LAW OFFICES
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Date
n R. Waltz, Es
28 South Pitt StreB .
Carlisle. PA 17013
(717) 245.9688
Attorney for Defendant
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I hereby certify that I served a true and correct copy of the Mollon For Appointml~nl I
Of Master upon Mindy S. Goodman, Esquire, by depositing same In the United States
Mall, first class, postage pre-paid on the 16th day of November, 2001. from Cartisile.
I Pennsylvania, addressed as follows:
II Mindy S. Goodman
, AtlomeyatLaw
I
: 2080 Linglestown Road
Harrisburg, PA 17110
-
TURO LAW OFFICES
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28 South Pitt Street
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Attorney for Defendant
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MICHAEL P. LUJANAC,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 00-6927
MELANIE J. LUJANAC,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
ORD.ER
AND NOW, this
day of
, 2001, after
reviewing Plaintiffs Objections to Motion for and Appointment of Master, the
Order Appointing Master dated November 21,2001 is VACATED until Defendant
files her Inventory and Appraisement, the marital residence has been appraised,
and the parties have been separated two years. After these matters have been
completed, a Master will be appointed.
BY THE COURT:
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MICHAEL P. LUJANAC,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 00-6927
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MELANIE J. LUJANAC,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
PLAINTIFF'S OBJECTIONS TO MOTION FOR
AND ApPOINTM8NT;OF MASTER
AND NO,W, comes the Plaintiff, Michael P. Lujanac, by and through his
attorney, Mindy S. Goodman, Attorney at Law, and files these objections to the
Motion for ApPQintment of and Appointment of Master filed on behalf of
,
Defendant, and 'avers as follows:
1. Plaintiff was never informed by telephone or correspondence, nor
was Plaintiff served a copy of the Motion for Appointment of Master
filed by Defendant on November 19, 2001. Plaintiff first received
notice of the Motion for Appointment and the Order ApPointing
Master on November 26, 2001, when copies were sent to Plaintiff
via facsimile. (A copy of the fax is attached hereto as Exhibit A.)
2. This matter is not yet ready for a hearing before a Master because:
(a) Defendant has not filed her Inventory and Appraisement,
and
(b) While Defendant did initially file the divorce action under
Sections 3301 (c) and 3301(d) of the divorce codes, he now
contents the finalization of this divorce and since the parties
,
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have not been separated for two years, this case is not ripe
for a Master's hearing; and
(c) No appraisal of the marital residence has been done and
therefore discovery is not complete.
3. Until such time as Defendant files and Inventory and Appraisement,
the marital residence has been appraised, and until the parties
have been separated for two years, said matter should not be
referred to and heard by the Master.
WHEREFORE, for the reasons set forth herein, Plaintiff respectfully
objects to the Motion for Appointment of Master and Order Appointing Master
and requests that the Order be vacated and the matter not yet referred until an
Inventory and Appraisement is filed by Defendant, the marital residence is
appraised, and until the parties have been separated for two years.
Respectfully submitted,
~ ';2;, ~.2>=> iL ~
Mindy S. Goodman
Attorney at Law
10 NO. 78407
2215 Forest Hills Drive - Suite 35
Harrisburg, PA 17112
(717) 540-8742
Attorney for Plaintiff
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CERTIFICATE OF SERVICE
A true and correct copy of the foregoing document was delivered to the
person or office listed below by first class mail on the date indicated, as follows:
Galen R. Waltz, Esquire
Turo Law Offices
28 S. Pitt Street
Carlisle, PA 17013
Date: /1-2'1''-> I
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Mindy S. Goodman
Attorney at Law
2215 Forest Hills Drive - Suite 35
Harrisburg, PA 17112
(717) 540-8742
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28 South Pitl Street
CarliSle, PennSylvania 1701a.
(717) 245-eeee
(800) 562-977e
Fax (717)245-2165
RON TURO, Esquire
ROBERT J, MULOERIG, Esquire
GAlEN R. WA!. TZ, Esquire
JAMES M, ROBINSON, Esquire
CAROL L. CINGRANELi.i. Esquire
GERARD J FOULKE, Esquire
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FAX COVER SHEET
PLEASE DELIVER THE FOLLOWING PAGES TO:
FAX" 5 Yo-p 7 L/3
DATE:
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PLEASE CALL OUR OFFICE AT (717) 245-9688 IF YOU DID NOT RECEIVE THE
COMPLETE FAX TRANSMISSION. THANK YOU.
...*...~........*.............*................*..........................*.*........*.............*
CONFIDENTIALITY NOTICE: This facsimile. contains confidential information, which
may be legally privileged and which is Intendbd only for the use of the Addressee(s)
named above. If you are not the IntendfKI recipient, or the employee or 8gent
responsible for delivering It to the intended (Ejciplent, you are hereby notified that any
dissemination or copying of this facsimile, or the taking of any action in reliance on the
contents of this telecopied information may bei strictly prohibited. If you have received
this facsimile in error, please notify us immediately by phone and return the entire
facsimile to us via the U.S. Postal Service. Thank you.
....................................................................................................
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ORDER APPOINnNG MASTER
NOW, this .II""" day of /I....,"'~....... 2001,
, Is appointed Master with respect to the following
, alimony pendente lite, distribution of property, counsel fees. costs and,
I
BY THE COURT.
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TRUE COpy FROM RECORD
'n Tll;IIr.'j):JYINlnzr<>ct.' hero ut1lo S<lt my hand
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Michael P. Lujanac,
Plaintiff
Melanie J. Lulanac.
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
: IN THE COURT OF COMMOItfLEiA'S OF,
: CUMBERLAND COUNTY. PE~S'f.wAN'~A
, ~~, ~ 'I
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: NO. 00-6927 ~1'.'
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". MOnON FOR APPOINTMENT OF ptIASTER I
Melanie J. Lujanac, Defendant, by and through her attomey, Galen R. Waltz, moves the I
Court to appoint a Master with respect to the following claims: divorce, alimony pendente lite,
distribution of property, counsel fees. costs and expenses and in support of the motion stetes:
I 1. Discovery appears to be complete as to the claims for which the appointment of I
I a Master IS requested,
I ,
. 2. The Defendant has appeared In the action by her attorney, Galen Waltz, Esquil'e. i
3. The statutory ground for divorce is 3301 (c)/(d). I
4. The action is contested with respect to the following claims: the DefendSlnt
believes end therefore evers that the brevlly of marriage (6 years), the substantial lack of
contribution to the marital estate by the Plaintiff. the Plaintiffs extra-marital Indulgences, the
Plaintiffs "daytrading" squandering of marital assets, the Plaintiff's consistent lack of
,
employment during the brief marital years. and the Plaintiffs waiver of interest toward tile
Defendant's pension serve to negate any presumed validity of the Plalnllffs spurious claims to
the Defendant. resl property, penSion or other property.
5. The action does not Involve complex issues of law or fact.
6. The hearing Is expected to take % to ~ days.
Respectfully Submitted
TURO LAW OFFICES
II hr, hL__
Date
n R. Waltz, Eli
28 South Pitt Stree
Carllsle,PA 17013
(717) 245-9688
Attorney for Defendant
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CERTIFICATE OF ~ERVI(f~
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I hereby certify that I served a true and correct copy of the Mollon For Appointment II
Of Master upon Mindy S. Goodman, Esquire, by depositing same In the United States
Mail, first class, postage pre-paid on the 16th day of November, 2001, from Carlisle. I
I
Pennsylvania, addressed as follows: I
Mindy S. Goodman
Attorney at Law
2080 Llnglestown Road
Harrlsburg,PA 17110
-
TURO LAW OFFICES
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,-a; en R. Waltz, squi . .
28 South Pitt Street
Car1isle, PA 17013
(717) 245-9688
Attorney for Defendant
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MICHAEL P. LUJANAC,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - LAW
NO. 00 - 6927 CIVIL
MELANIE J. LUJANAC,
Defendant
IN DIVORCE
CONFERENCE WITH
COUNSEL AND PARTIES
TO: -----------------
Michael P. Lujanac
Counsel for Plaintiff
, Plaintiff
Galen R. Waltz
Melanie J. Lujanac
, Counsel for Defendant
, Defendant
A conference has been scheduled at the Office of
the Divorce Master, 9 North Hanover Street, Carlisle,
Pennsylvania, on the 20th day of November 2003, at 9:00 a.m.,
with counsel and the parties to discuss the outstanding
economic issues to determine if there is a basis of settlement
of claims. If issues remain after the conference, a hearing
will be scheduled at another date.
Very truly yours,
Date of Notice: 10/30/03
E, Robert Elicker, II
Divorce Master
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Plaintiff
: CIVIL ACTIOllT LAW
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NO. 00 - 6927
CIVIL
19
MELANIE J. LUJANAC
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IN DIVORCE
STATUS SHEET
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MICHAEL P. LUZANAC,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00 - 6927 CIVIL
MELANIE J. LUZANAC,
Defendant
IN DIVORCE
TO: Mindy S. Goodman
Attorney for Plaintiff
Galen R. Waltz Attorney for Defendant
DATE: Friday, December 7, 2001
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
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(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
DATE
COUNSEL FOR PLAINTIFF
COUNSEL FOR DEFENDANT
NOTE:
PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
,'>
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MICHAEL P. LUZANAC,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00 - 6927 CIVIL
MELANIE J. LUZANAC,
Defendant
IN DIVORCE
TO: Mindy S. Goodman
Attorney for Plaintiff
Galen R. Waltz Attorney for Defendant
DATE: Friday, December 7, 2001
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
~utline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
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(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
/ ?--/2--0 I
DATE
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,
COUNSEL FOR PLAINTIFF ()<)
COUNSEL FOR DEFENDANT ( )
NOTE:
PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
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RON TURO, Esquire
ROBERT J. MULDERIG, Esquire
GALEN R WALTZ, Esquire
JAMES M. ROBINSON, Esquire
DANIEL D. WORLEY, Esquire
JAMES G. GAULT, Esquire
E. Robert Elicker, II, Esquire
Office of the Divorce Master
9 North Hanover Street
Carlisle, PA 17013
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www. TuroLaw.c()m
28 South Pitt Street
Carlisle, Pennsylvania 17'013
(717) 245-S1688
(800) 562-SI778
Fax (717) 245-2165
October 10, 2003
Re: Lujanac v. Lujanac
No. 00-6927 Civil in Divorce
Dear Mr. Elicker:
In response to your letter of October 1, 2003, the defendant, Melanie J. Lujanac, by and
through her attorney, Galen R. Waltz encloses two documents exhibiting an existing liability
that Mr. Lujanac has towards my client, Melanie J. Lujanac,
It is our position that we are exhibiting a proper claim coming from a second mort~lage
in the amount of $21 ,567.64. Of which it is our belief the Mr. Lujanac is liable to my clienll for
one half of that amount. The last paragraph of your letter indicated willingness for Ms. Lujanac
to raise an economic claim.
Pi ease allow this claim in the amount of one half of the second mortgage to satisfy your
directive.
Should more information be deemed necessary, please advise and I will provide the
same to you.
GRW/jah
c.c. Melanie Lujanac
Michael Lujanac
~A
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Gwaltz@TuroLaw.com
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MINDY S. GOODMAN
ATIORNEY AT LAW
NORTHWOOD OFFICE CENTER
22 I 5 FOREST HILLS DRIVE. SUITE 35
~SBURG,PAI7112
(7 I 7) 540-8742 . (7 I 7) 540-8743 FAX
December 12, 2001
E. Robert Elicker, II, Esquire
Office of Divorce Master
9 North Hanover Street
Carlisle, PA 17013
RE: Lujanac v. Lujanac
Divorce
Docket No. 00-6927
Dear Mr. Elicker:
I understand that you have been appointed Special Master in the above-
referenced case. Unfortunately, I did not receive the Defendant's Motion for
Appointment of Master prior to the appointment having been made. Had I
received notice of the Motion, I would have objected to the appointment of the
Master at this time.
In addition to discovery being incomplete, neither the Plaintiff nor Defendant have
filed Inventories and Appraisements in this case, nor have they filed income and
expense statements. I have filed Objections the Motion and Appointment of
Master, but unfortunately have not received a ruling on that Motion. A copy of
the Motion is enclosed for your review. I will provide you with a copy of the Order
once signed by the Judge.
Thank you for your attention to this matter. If you have any questions or need
additional information, please do not hesitate to contact me.
Very truly yours,
~ ~S[, =,.,Q... -
Mindy S. Goodman
MSG/bsg
Enclosure
cc: Mike Lujanac
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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 Master
Traci Jo COlyer
Office Manager/Reporter
West Shore
697-0371 Ex!. 6535
December 13, 2001
Mindy S. Goodman
Attorney at Law
Northwood Office Center
2215 Forest Hills Drive, Suite 35
Harrisburg, PA 17112
Galen R. Waltz, Esqurie
TURO LAW OFFICES
28 South Pitt Street
Carlisle, PA 17013
RE: Michael P. Luzanac vs. Melanie 1. Luzanac
No. 00 - 6927 Civil
In Divorce
Dear Ms. Goodman and Mr. Waltz:
I am writing in response to a motion and attached order filed by attorney
Goodman with Judge Hoffer. The Court has returned the motion to me for my review
and I have determined that I do not think it is appropriate at this time for me to vacate my
appointment. I point out that it was Ms. Goodman who filed the divorce complaint on
October 10, 2000. She is now complaining that my appointment is premature and that
her client will not sign an affidavit of consent. My suggestion would have been that she
should not have filed the divorce action if she did not want the matter to proceed. Mr.
Waltz has asked that I proceed with the case by filing motion appointing me on
November 16,2001.
It appears as if the issue currently is whether or not there are grounds for divorce.
Mr. Waltz has not raised any alternative grounds but I am writing to determine if he
intends to raise a claim for indignities or if the parties can establish a date of separation
which most likely would be at least tied into the date of the filing of the divorce
complaint on October 10, 2000. We can then determine who we need to proceed with
grounds for divorce. If the parties separated before that date, perhaps we do not have as
long to wait for the two years to expire although currently it is less than another year to
wait until wife can proceed with a 3301(d) request from the date of the filing ofthe
complaint.
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Ms. Goodman and Mr. Waltz, Attorneys at Law
13 December, 2001
Page 2
I also point out that counsel have not filed any economic claims in the action and I
will give them an opportunity to do so. Once I determine if there are issues regarding
grounds for divorce and if there are economic claims that I need to address, then I will
decide whether or not it is appropriate for me to vacate my appointment. I also point out
that Mr. Waltz filed a request for production of documents but I do not see any response
in the file to that request. That request was filed in February 2001.
I will await a response from counsel to my inquiries regarding grounds for
divorce and economic claims before deciding how to proceed with the request for my
appointment to be vacated.
Very truly yours,
E. Robert Elicker, II
Divorce Master
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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 Master
Traci Jo Colyer
Office Manager/Reporter
West Shore
697-0371 Ex!. 6535
October 1, 2003
Michael P. Lujanac
1777 Sheepsford Road
Mechanicsburg, PA 17055
Galen R Waltz
Attorney at Law
TURO LAW OFFICES
28 South Pitt Street
Carlisle, PA 17013
RE: Michael P. Lujanac vs. Melanie J. Lujanac
No. 00 - 6927 Civil
In Divorce
Dear Mr. Lujanac and Mr. Waltz:
I was reappointed Master on July 25,2003. Mr. Waltz, as counsel for the
Defendant, has certified that discovery is complete. I have not heard from Mr. Lujanac.
This matter needs to move forward as I was previously appointed and then had
my appointment vacated, one of the reasons being that the Plaintiff's attorney at the time
felt my appointment was premature. The complaint was filed on October 2000 which
would certainly have allowed counsel plenty of time to complete discovery in this case.
However, I point counsel and Mr. Lujanac to my letter of December 13, 2001,
wherein I stated that there were no economic claims raised in the action. In checking the
docket I do not find any claims raised to date. I cannot proceed with a directive for pre-
trial statements since there are no economic claims pending.
I will allow the Plaintiff, who is apparently representing himself, and Mr. Waltz
two weeks in which to raise any economic claims they wish to raise or advise that there
.10 -
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Mr. Lujanac and Mr. Waltz
1 October 2003
Page 2
are issues with respect to grounds for divorce. If I have not heard from counselor Mr.
Lujanac in two weeks, I will prepare another order vacating my appointment.
Very truly yours,
E. Robert Elicker, II
Divorce Master
-.
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',.-~'J'-u",' " "-"'~''''---~''",, ,,-.,
'.,' ., ".~~}~,
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 Master
Traci do Colyer
Office Manager/Reporter
West Shore
697-0371 Ex!. 6535
October 1, 2003
Michael P. Lujanac
1777 Sheepsford Road
Mechanicsburg, P A 17055
GalenR. Waltz
Attorney at Law
TURO LAW OFFICES
28 South Pitt Street
Carlisle, P A 17013
RE: Michael P. Lujanac vs. Melanie 1. Lujanac
No. 00 - 6927 Civil
In Divorce
,
Dear Mr. Lujanac and Mr. Waltz:
I was reappointed Master on July 25,2003. Mr. Waltz, as counsel for the
Defendant, has certified thllt discovery is complete. I have not heard from Mr. Lujanac.
This matter needs to move forward as I was previously appointed and then had
my appointment vacated, one of the reasons being that the Plaintiffs attorney at the time
felt my appointment was premature. The complaint was filed on October 2000 which
would certainly have allowed counsel plenty of time to complete discovery in this case.
However, I point counsel and Mr. Lujanac to my letter of December 13,2001,
wherein I stated that there were no economic claims raised in the action. In checking the
docket I do not find any claims raised to date. I cannot proceed with a directive for pre-
trial statements since there are no economic claims pending.
I will allow the Plaintiff, who is apparently representing himself, and Mr. Waltz
two weeks in which to raise any economic claims they wish to raise or advise that there
"
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Mr. Lujanac and Mr. Waltz
I October 2003
Page 2
are issues with respect to grounds for divorce. If I have not heard from counselor Mr.
Lujanac in two weeks, I will prepare another order vacating my appointment.
Very truly yours,
f'/2Lffd~
E. Robert Elicker, II
Divorce Master
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Cumberland County Prothonotary's Ottice
Case Entries
2000-06927 LUJANAC MICHAEL P (vs) LUJANAC MELANIE J
Filed Date: 10/10/2000 Time: 11:42 Case Type: COMPLAINT - DIVORCE
Search Date: Page 3 of 3
FIRST ENTRY
10/10/00 COMPLAINT - DIVORCE
-------------------------------------------------------------,------
2/23/01 DEFENDANT'S REQUEST FOR PRODUCTION OF DOCUMENTS FOR RESPONSE BY
THE PLAINTIFF - BYBY GALEN R WALTZ ESQ
-------------------------------------------------------------..-----
11/19/01 MOTION FOR APPOINTMENT OF DIVORCE MASTER - BY GALEN R WALTZ ESQ
FOR DEFT
11/21/01 ORDER APPOINTING MASTER 11/21/01 E ROBERT ELICKER IS APPOINT
MASTER GEORGE E HOFFER P JUDGE- COPIES MAILED 11/21/01
12/04/01 PLAINTIFF'S OBJECTIONS TO MOTION FOR AND APPOINTMENT OF MASTER BY
MINDY S GOODMAN ATTY FOR PLFF
1/16/02 ORDER OF COURT - DATED 1/16/02 - PLFFS COUNSEL HAVING INDICATED +
F2=Done FIO=Print F12=Cance1 F17=Top F18=Bot
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PYS510D
Cumberland County Prothonotary's Ottice
Case Entries
2000-06927 LUJANAC MICHAEL P (vs) LUJANAC MELANIE J
Filed Date: 10/10/2000 Time: 11:42 Case Type: COMPLAINT - DIVORCE
Search Date: Page 3 of 3
THAT DISCOVERY IS INCOMPLETE AND DEFT'S COUNSEL HAVING INDICATED
THAT DISCOVERY IS INCOMPLETE AND DEFT'S COUNSEL NOT HAVING
RESPONDED TO THE MASTER'S INQUIRE REGARDING CERTIFICATION OF
DISCOVERY AND NEITHER COUNSEL HAVING RESPONDED TO THE MASTER'S
LETTER DATED 12/13/01 REGARDING STATUS OF THE DIVORCE AND ECONOMIC
CLAIMS THE APPOINTMENT OF THE MASTER IS VACATED - BY THE COURT
GEORGE E HOFFER PJ COPIES MAILED 1/16/02
4/09/02 PETITION OF MINDY S GOODMAN ESQ TO WITHDRAW APPEARANCE AS COUSEL
FOR PLFF - BY MINDY S GOODMAN ESQ
4/15/02 RULE - DATED 4/12/02 - IN RE PETITION FOR MINDY S GOODMAN ESQ TO
WITHDRAW APPEARANCE AS COUNSEL FOR PLFF - A RULE IS ISSUED ON
PLFF AND DEFT TO SHOW CAUSE IF ANY THERE BE WHY PLFFS COUNSEL
MINDY S GOODMAN ESQ SHOULD NOT BE GRANTED LEAVE TO WITHDRAW AS
COUNSEL - RULE RETURNABLE 20 DAYS FROM SERVICE - BY THE COURT +
F2=Done F10=Print F12=Cance1 F17=Top F18=Bot
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Cumberland County Prothonotary's Office
Case Entries
2000-06927 LUJANAC MICHAEL P (vs) LUJANAC MELANIE J
Filed Date: 10/10/2000 Time: 11:42 Case Type: COMPLAINT - DIVORCE
Search Date: Page 3 olE 3
GEORGE E HOFFER PJ COPIES MAILED 4/15/02
5/30/02 PETITION TO MAKE RULE ABSOLUTE BY MINDY S GOODMAN ESQ
6/07/02 ORDER - DATED 6/7/02 - UPON SHOWING OF GOOD AND SUFFICIENT REASON
FOR PERMISSION TO WITHDRAW THIS HONORABLE COURT HEREBY GRANTS THE
PETITION ON BEHALF OF MINDY S GOODMAN ESQ FOR ALLOWANCE TO
WITHDRAW AS COUNSEL FOR PLFF - BY THE COURT GEORGE E HOFFER P.J
COPIES MAILED 6/7/02
6/18/02 PRAECIPE TO WITHDRAW AS COUNSEL FOR DEFT - BY MINDY S GOODMAN ESQ
7/24/03 MOTION FOR APPOINTMENT OF DIVORCE MASTER - BY GALEN R WALTZ ESQ
FOR DEFT
- LAST ENTRY
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MICHAEL P. LUJANAC,
. Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00 - 6927 CIVIL
vs.
MELANIE J. LUJANAC,
. Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVOR€E DECREE UNDER
SECTION 33011CI OF THE DIVORCE CODE
1. I consent to the entry of a [mal 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
i
grant~d.
3. I understand that I will not be divorced until a divorce decree is entered
by th~ Court and that a copy of the decree will be sent to me immediately after
,
iUs filed with the Prothonotary.
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i I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING
AFFIqAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE
STATrtMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18
PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO
AUTHORTIES.
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MICHAEL P. LUJANAC,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY , PENNSYLVANIA
NO. 00 - 6927 CIVIL
MELANIE J. LUJANAC,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was
filed on October 10, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of the filing of the Complaint.
3. I consent to the entry ofthe final Decree in Divorce after service of notice
of intention to request entry of the decree.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING
AFFIDAVIT ARE TRUE AND CORRECT. 1 UNDERSTAND THAT FALSE
STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18
PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO
AUTHORTIES.
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MICHAEL P. LUJANAC,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00 - 6927 CIVIL
MELANIE J. LUJANAC,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVOR€:E DECREE UNDER
SECTION 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 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
iUs fIled with the Prothonotary.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING
AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE
STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18
PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO
AUTHORTIES.
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MICHAEL P. LUJANAC,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00 - 6927 CIVIL
MELANIE J. LUJANAC,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was
flied on October 10, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of the fIling of the Complaint.
3. I consent to the entry of the fmal Decree in Divorce after service of notice
of intention to request entry of the decree.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING
AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE
STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18
PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO
AUTHORTIES.
DATE:
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MICHAEL P. LUJANCA,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 00-6927
v.
MELANIE J. LUJANAC
Defendant
: DIVORCE
DEFENDANT'S REQUEST FOR PRODUCTION OF DOCUMENTS
FOR RESPONSE BY THE PLAINTIFF
TO: Michael P. Lujanac, Defendant
c/o Mindy S. Goodman, Esquire
2080 Linglestown Road
Harrisburg, PA 17110
Dear Mr. Lujanac:
Pursuant to Rule 4009.11 of the Pennsylvania Rules of Civil Procedure, the
above-named Plaintiff, by and through her attorney, Galen R. Waltz, Esquire, hereby
demands that the party to whom these Requests for Production of Documents are
addressed answer fully, in writing, and under oath, with the signed Verification attached
hereto, the following Documents Requests, and make available for inspection and
copying all documents responsive to these Document Requests, within thirty (30) days
as prescribed by Rule 4009.12 of the Pennsylvania Rules of Civil Procedure.
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DEFINITIONS AND INSTRUCTIONS
Unless negated by the context of the Document Request, the following
definitions are to be considered to be applicable to all requests contained herein:
(A) "Documents" is an all-inclusive term, referring to any writing andor
recorded or ~raphic matter, however produced or reproduced. The term
"documents" includes without limitation, correspondence, memoranda, interoffice
communications, minutes, reports, notes, schedules, analyses, drawings,
diagrams, invoices, purchase orders, pleadings, questionnaires, contracts, bills,
checks, drafts, diaries, logs, proposals, print-outs, recordings, telegrams, films,
tax returns, and financial statements, and all other such documents, tangible or
retrievable of any kind. "Documents" also include any preliminary notes and
drafts of all the foregoing, in whatever form, for exampl~, printed, types,
longhand, shorthand, on paper, paper tape, tabulating picture film, phonograph,
records, or other form.
(B) With respect to documents, the term "identify" means to give the
date, title, author, and addresses; "identify" with respect to documents further
means:
(1) To describe a document sufficiently well to enable the
individual making the request to know what such document is and to retrieve it
from a file or wherever it may be located;
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(2) To describe it in a manner suitable for use as a description in
a subpoena; and
(3) To give the name, address, position, or title of the person(s)
who has custody of the document and/or copies thereof.
(C) Whenever the expression "and/or" is used in these Requests for
Documents, the information called for should be set out both in the conjunctive
and disjunctive, and wherever the information is set out in the disjunctive, it
should be given separately for each and every element sought.
(D) No answer is to be left blank. If the answer to a Document Request
or a subparagraph of a Document Request is "none" or "unknown," such
statement must be written in the answer.
(E)
These Document Requests are continuing, and any information
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secured subsequent to the filing of your answers that would have been
includable in the answers had it been known or available, are to be supplied by
supplemental answers.
(F) If additional space is required for an answer, attach supplemental
answer sheets that clearly identify the Document Request number.
(G) If you object to any Document Request or if any information
responsive to any Document Request is withheld based on any claim of privilege
or protection from discovery of any kind, describe generally the information
withheld, state the privilege being relied upon, and identify all persons or entities
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who have or have had access to said information. If you refuse to provide any
document on the basis of a claim of privilege or protection from discovery of any
kind, with respect to each such document, set forth the following information:
(a) the date of the document;
(b) its author(s);
(c) all recipients of the document;
(d) the present location and custodian of the document; and
(e) the basis for the claim of privilege or protection from
discovery.
To the extent that the claim of privilege or protection applies only to a
portion of the responsive documents, all portions for which privilege or protection
are not claimed must be produced.
(H) The terms "you" and "your" include, without limitation, Plaintiff, and
her agents or other representatives aCting or purporting to act on his behalf or at
his direction.
DOCUMENT REQUESTS
1. Copies of the federal and state income tax returns filed by you for
the past three years, together with accompanying worksheets including W-2
forms; copies of federal and state income tax returns and profit and loss
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statements for any and all corporations, joint ventures, partnerships or other
corporate or business associations in which you hold an interest.
2. All documents and statements, issued by any bank, savings
institution, or other financial institution from a date six months prior to August 25,
2000, through the present.
3. All documents and financial statements prepared by you or on your
behalf since the date of separation, August 25, 2000.
4. All loan applications and loan documents pertaining to any sums of
money borrowed or to be borrowed by you, individually or jointly with any other
person, or as guarantor from a date two years prior to August 25, 2000.
5. All brokerage statements and documents pertaining to any
accounts in which you individually, or with others, had Clfly interest from two
years prior to August 25, 2000.
6. AU documents and securities, including tax-free bonds and funds, in
which you individually, or jointly with any other person, had any interest as of
August 25, 2000.
7. All documents and stock certificates, not in house accounts, in
which you individually, or jointly with any other person, had any interest as of
August 25, 2000.
8. AU mutual funds statements and documents received by you since
July 31,2000.
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9. All treasury notes, treasury bills, U.S. Savings Bonds, corporate
bonds, and municipal bonds, presently owned or in which you, individually or with
any other person, had any interest as of August 25, 2000.
10. All savings certificates or certificates of deposit, or other depository
receipts presently owned or in which you had any interest on August 25,2000.
11. All documents including, but not limited to, any individual retirement
account, pension or profit sharing plan, savings plan, Keogh, 401 (k) Plan, annuity
benefits, retirement plan, stock bonus plan, stock option plan, thrift plan
(excluding social security benefits), with your present employer, or any previous
employer, or regarding any other retirement benefits in which you, individually or
with others, have or had any interest with benefits still due, including the
summary plan description, and other such information r~garding the terms of the
retirement plan, as well as annual statements for the past four years, plus the
statement closest to the date of marriage and the statements immediately
preceding and immediately following the date of separation.
12. All financial statements or documents referring to any deferred
compensation plan, to which you were or are entitled by reason of any present or
past employment.
13. All documents sufficient to show your income and earnings records,
including but not limited to payroll stubs or wage statements, any commission
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statements issued by any employer, or any 1099s issued by any person or entity
for which you have performed services for the past thirty-six rnonths.
14. Any employment contracts or commission contracts with either your
current or previous employer to which you were a party in the past four years.
15. Documentation verifying the sale by you of any asset having a
value in excess of $250.00 from two years prior to August 25, 2000.
16. The lease or deed for the premises where you are presently
residing and/or the deed for any and all real property titled in your name
individually or jointly with someone else.
17. If you have been involved in litigation as a Plaintiff in the past five
(5) years, a copy of the Complaint. and a copy of any written correspondence or
other documentation memorializing any settlement offe~s made by your or on
your behalf.
18. If you have been involved in litigation as a Defendant in the past
five (5) years, a copy of the Complaint, and a copy of any written correspondence
or other documentation memorializing any settlement offers made by your or on
your behalf.
19. All mortgages and mortgage notes and/or bonds relating to any real
estate you presently own, and current statements showing balances on such
obligations.
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20. All documents relating to the purchase of a motor vehicle presently
owned by you, or in which you had an interest during the past four years,
including a copy of the title to the vehicle.
21. All life insurance and annuity policies in which you have any
interest as an owner, insured, or beneficiary, including any change of beneficiary
forms executed by you within the past six years.
22. All appraisals of real estate or personalty performed in the past five
I
years.
23. A prospectus of all investments in which you had any interest for
the past five years.
24. All correspondence received by you from the Internal Revenue
Service or state revenue office during the past three years, except the
,
submission of income tax returns.
c-
Galen R. Waltz
Turo Law Offi es
28 South Pitt Street
Carlisle, PA 17013
(717t 245-9688
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CERTIFICATE OF SERVICE
I hereby certify that on this ~5 day of rei,. "".....1.. , 2001, a true and
correct copy of the foregoing Request for Production of Do~ments was served upon
the following by depositing same into the United States Mail, first-class mail, postage
prepaid to:
Mindy S. Goodman
2080 Lingelstown Road
Harrisburg, PA 17110
Respectfully Submitted
TURO LAW OFFICES
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Date
en R. Waltz, Esqui
28 South Pitt Street
Carlisle, PA 17013
(717) 245-9688
Attorney for Defendant
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Michael P. Lujanac,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 00-6927
v.
Melanie J. Lujanac,
Defendant
: CIVIL ACTION - IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME
NOTICE IS HEREBY GIVEN that the Defendant in the above matter, having
been granted a Final Decree in Divorce on the r-A day of AChnk.., 2003, hereby
elects to resume the prior surname of Melanie Jane Eslinger, and gives this written
notice pursuant to the provisions of 54 P.S. 9704.
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Date
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Melanie J. Luj ac
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Melanie J. Eslin r
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF CUMBERLAND
On the 3r"\ day of Dece..-n&f, 2003, before me, a Notary PUblic,1
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personally appeared Melanie Jane Eslinger formally known as Melanie J. LUjanac,1
known to me or satisfactorily proven to be the person whose name is subscribed to thel
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within instrument, and acknowledge that she executed the foregoing for the purposel
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therein contained. '
IN WITNESS WHEREOF, l have hereunto set my hand and official seal.
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Notari21 Seal
James {\1. Robinson. Notary Public
Carlisle Bora, Cumberland County
My Commission Expiret_ June 6. 2005
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MELANIE J. LUJANAC
(ESLINGER) ,
Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
MICHAEL P. LUJANAC,
Respondent
CIVIL ACTION - LAW
NO. 00-6927 CIVIL TERM
ORDER OF COURT
AND NOW, this 30th day of January, 2004, it
appearing that Mr. Elicker is unavailable, hearing in this
matter is continued to March 1, 2004, at 11:00 a.m.
Petitioner is directed to make service of this order
upon Respondent by first class mail and certified mail,
return receipt requested, addressed to 1777 Sheepsford,
Road, Mechanicsburg, PA 17055.
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By the Court,
Edward E. Guido, J.
vGalen R. Waltz, Esquire -r~ \
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MELANIE J. LUJANAC
(ESLINGER) ,
Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
MICHAEL P. LUJANAC,
Respondent
CIVIL ACTION - LAW
NO. 00-6927 CIVIL TERM
ORDER OF COURT
AND NOW, this 1st day of March, 2004, after
hearing, we find that the parties had entered into an agreement
in front of the divorce master which provided, inter alia, that
wife would remove husband from any liability on the second
mortgage and that the parties would cooperate in transferring the
1992 Ford truck into husband's name alone and the 1999 Ford sedan
into wife's name alone. We further find that despite repeated
requests to do so, husband has refused to cooperate. Therefore,
we enter the following Order:
1. Wife shall take steps to forthwith remove husband
from any liability on the second mortgage.
2. Wife is granted a limited power of attorney to
sign husband's name on the titles and any other documents
required by Penn DOT to effectuate the transfer of a 1992 Ford
truck, Vehicle Identification Number IFTCRIOA3NTA30732, to
husband's name alone and to transfer the title of the 1999 Ford
sedan, Vehicle Identification Number 1FAFP53S9XA286571, into
wife's name solely.
3. Husband shall pay wife the sum of $550.00 to
reimburse her for legal fees incurred in these proceedings.
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Galen Waltz, Esquire
For the Petitioner
Michael P. Lujanac
1777 Sheepsford Road
Mechanicsburg, PA 17055
Respondent, Pro se
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