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Home My WebLink About01-0757 FX "',;,,, ,',," . .. . . .. "'''':to "''''''' '" ;f;'" "'Of. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. . . . LINDA KAY HURSON. Plaintiff Civil No. 01-757 . VERSUS . ARTHUR K. HURSON, Defendant . DECREE IN DIVORCE . . NOW:V~ "" , IT IS ORDERED AND . 2001 AND . . LINDA KAY HURSON , PLAINTIFF, . DECREED THAT . AND ARTHUR K. HURSON , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE . BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . . None. The Agreement entered into by the parties at the . . Office of the Divorce Master incorporated into, but shall on October 24, 2001 is , this Decree. . . . '" '" '" '" '" PROTHONOTARY . . '" "'''' '" '" . J. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . l Ii ~I i. II! I I: '-, , 0 ."" -,~l Id}cJl a/- ~ ~ ~ 4~ /.;?#-o/ ~ ~ ~ 4y1~ -' ~I III ",...~"'!"!'~- -' 1",. l\'if;l!I'~l!'tl~~@!~~~~~~\ti!l'l!l.n~~~W!lf,<=>-. ,~il'llfl;f~!l!fflL,~~ ":"'" . LINDA KAY HORSON, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01- 151 CIVIL TERM ARTHUR K. HORSON, Defendant : CIVIL ACTION - LAW : IN DIVORCE 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 will proceed without you and a decree in divorce or annulment may be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE TIDS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORm BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PelUlSylvania 17013 (717)249-3166 ."""-,, ---~,- ,..; -~-,:<. '",-:;" . LINDA KAY HURSON, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01- 'i:57 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE ARTHURK. HURSON, Defendant COMPLAINT IN DIVORCE 1. Plaintiff is Linda Kay Hurson, an adult individual, currently residing at 616 Hilltop Drive, New Cumberland, Cumberland County, Pennsylvania. 2. Defendant is Arthur K. Hurson, an adult individual, currently residing at 62 W. North Street, Apt. #3, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant are bonafide residents of the Commonwealth of Pennsylvania and have been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on June 26, 1993 ill Shiremanstown, Cunlberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America, or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, the Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties have lived separate and apart since September 2000 and continue to live separate and apart as of the date of this Complaint. ~ 1 "co ,-;,-.,,-., 0'."; ~ -"';"". ,',;-,',', .,;. -i--:-~- ." -~'" ',- ";~':""""i~:o~'-:" -,,' :-'~;.:"__,; ;_.';:: :~_, '<' .," ~ -', ~ ':'';:i: ;.::;" 1-~,:;-~'; -'; ,,' "" _;:-~>-,;} i:,;;';,...e;..:. _",,,,,-_c~_ , ~v ' 10. The parties' marriage is irretrievably broken. 11. Plaintiff desires a divorce based upon the belief that Defendant will, after ninety days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce. COUNT ill EQUITABLE DISTRIBUTION 12. Paragraphs 1 through 11 are incorporated herein by reference as if set forth in their full text. 13. Plaintiff and Defendant are joint owners of various items of personal property, furniture, and household furnishings acquired during their marriage which are subject to equitable distribution. 14. Plaintiff and Defendant have incurred debts and obligations during their marriage which are subject to equitable distribution. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree equitably dividing the parties' property and equitably apportioning the debts incurred by the parties. Respectfully Submitted, <p -F"eC:> L.a::J I Date C-.d~ ~0 . ROBERT P. KLINE, ESQUIRE 714 Bridge Street Post Office Box 461 New Cumberland, P A 17070-0461 (717) 770-2540 Attorney for Plaintiff , , c. ~ .,,~"^ ~ "~_,. " "~. '.' .J --,; ",_,. ,.___~. . . VERIFICATION I verify that the statements made in the foregoing Divorce Complaint are true and correct. I understand that false statements herein made are subject to the penalties of Pa.C.S. Section 4904 relating to unsworn falsification to authorities. r->~s\ OJ Dat ~ \1'<-,6 C\, \<..~ ~"--- LINDA KAY HURSON,' Plaintiff ~~~;2-tMi'i>\1.0l.:;>>W.'li.~~jJJW.4:~\S!lI;:b'i!~bii<IJ~.h1:>-;:"jfu~.H';"8i~'k>lili4iW-J;Jt-iil~illI&!futj}J", ~d ~=~._oo~___" ~." =~_~ _I .,__ "' 7_ d__~ , ~. .....- , "'.^- .~~ ~- ^ "~ .lc' '. . o ~ -or~-' mi-~ z~.: Zr,:: 0....'. ~-/ ~C~. ,,- .2:Z0 ~C >C Z --' -< -.~~~., .. -- - ~. c COO, ~";tl ..." '" OJ I .-J 1" "(h, ~J~~ ts1Ti :r;! ~ -0 ~ (v ~ f f e . I,' :'' I t) I' ,:, i:i ti i'l j'i .!..~; 1= I.U. ~ --- --, J f LINDA KAY HURSON, IN THE COURT OF COM:MON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. NO.OI- 70) ARTHUR K. HURSON, Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Linda Kay Hurson, Plaintiff, to proceed in forma pauperis. I, Robert P. Kline, Esquire, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party, The party's affidavit showing inability to pay the costs of litigation is attached hereto. Respectfully submitted, Co ~ Cot"ll DATE c ~~O _ ROBERT PETER KLINE, ESQUIRE" 714 Bridge Street Post Office Box 461 New Cumberland, PA 17070-0461 (717) 770-2540 Attorney for Plaintiff _~~i[ -- b~'~41;!<j!!illfi!lfi6~liOO~.mH~L~I!i#:litk,~~iil.&e;'L"lhJ''''_f.\!Ii~!~",~i:W#li\t''~~iliill"""'" -"'" " . h~" '"' "' , , ~,L,b"'m. '" ~ 1 "::'1Jl' .~'- - - .. , .., '-- ~ ." , ,-~ 0 0 0 C -'1"1 s:: ..." ._, '"DOC rr1 ::~ ~'J mrr; CO Z:1:'} ..~, : '1-, Z. c',t:~ ~2C: -.J ~J:b KC V _~,_i >'" ...4 :,::::C) Z---' )>0 r;? Of'f": C. -1 ~ [;o- f\,) :0 -< \ \'1 i:i IU 1;1 'II ,j Ij \1] ! I.,:J :: ~I II ~ t .;"_."'~ . --"'..,. ,I' ~_ . ..., I , t ..' -' f LINDA KAY HURSON, IN THE COURT OF COM:MON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. NO.01- 7"'-1 ARTHUR K. HURSON, Defendant AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am the plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding, 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. Name: ~\uDA \.<H~l-\ -ttur.:5Cl\\.J I Address: (91 \Q \-\..d~ tA. 'l\)e.,v..:> (~\"Y'lb~ "'(:A,ndJ {la \ 107('y \ ,,,,)0 Social Security Number: \ to ~ A'6 -.G\ ') 7 Cj (b) If you are presently employed, state: (a) Salary or wages per month: Type of work: If you are presently unemployed, state: Employer: Address: I,',.. > .. Date of last employment: \ ~ \ ~D Salary or wages per month: $(~ ,00 Ji+R I Type of work: Ra.'('<'lc\'d,c.. Y~,L (c) Other income within the past twelve months Business or profession: Other self-employment: Interest: Dividends: Pension and annuities: Social Security benefits: ~;a lo . c:,c Support payments: Disability payments: ~J(!l.. ~Jp. . Unemployment compensation and supplemental benefits: tJ/A- , Workman's compensation: ~J A . Public Assistance: t-lj ^ Other: NJ A (d) Other contributions to household support (Wife~ame: ~-\,.hl:),\Z ~r5(5\..:) If your (husband) (wife) is employed, state: lA() tu.... 'M\O-SePil::l'n(-!,6'f2- 2-OUD Employer: CJ:>.'('\\o\-z. ~""'-\ ~,~ ~",",,\5S\D.."~ ~""-..a_ Salary or wages per month:~ ,DD\\\~ Type of work: ~tl\<:.ex-. Contributions from children: c:::, Property owned Cash: (e) ~J^ . Checking account: ~ ~I"I . 0 e:. Savings account: ~ \"6 Go, . C, <;;. "', .' ;.c, ',j"" " ;--,-i!;'; '" ,',,',_".-I~;_'~__;-<_, ,C'',, ,-, " '~',.: Certificates of Deposit: Real estate (including home): Motor vehicle: Make t=l.oftn~ Cos~ 3. :<>C6 I ~/A , tJjA. In 5h-AA.F Year /AV)1<'n0/U1 mM-E (rY1tJOai'f' Amount Owed NfA. NJk Stockslbonds: Other: (t) Debts and obligations Mortgage: Rent: Loans: ~~ Monthly expenses: l\I\Ebltfn8' /t5D.J!!.. ""0. t u. BiLLS/ 37!!> mo tJtJt,prrAc./56E Ml>IT ~ /;;SE:.. MO. I (g) Persons dependent upon you for support (Wife) (Husband) Name: Children, if any: ~/~ I Name: ~J~ I Age: MA I 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Date: \\,,;;,,<t;\ d,C>O \ \ \ d- ~O-....~CVv\ ~\ \ '..DC\.~ LINDA KAY HUR'sON !ll!Il:iIi\li'1;'!jjl;lj'jl,f,!I"~..t~rfi i(,."~:&"'il<1>;gJ)j~-<S~illr.l~1"'i.ihJ~'iIil_"~1ffi:U!i!:M;.j('!ii,:,~'"w""l\J0!jg,m:'1~''"."""'"...""- ,JL "'\Iil~~Li '% o C" "'" "0 .., ff1jf!;;' "C:>' J, ?x- z.-.- 0;'> rs ,;S~- ::::;-l_j p.---., 2\,; __r'-, >-c: ?.: =< H~ ~ .~ o ~~ "TJ ~"'1 C'J I ...,j v S:! (~') ::-':::! -.:>() (Ojrn 'hi SO -< 1;:' Tv , , I, i.:;; ! - "" ~. ~ " "",', ~ ,~ ,-, ," ,~,~, ,,", ,,~- ~', ~', ~ ,--,' '- , >-'0, ""'~':'-"'~':;;'~;;-'~'i ;,~-.:{;',:, q.",',.- ^,.;>.-.).:, ,.> '; .;,,';"--"" ',- ',:-;:X::C;';", <;;i:;~<,i ,~,0,'> ' ':"; A LINDA KAY HURSON, Plaintiff v. : IN THE COURT OF COM:MON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-757 CIVIL TERM : CIVIL ACTION - LAW : IN DNORCE ARTHUR K. HURSON, Defendant AFFIDAVIT OF SERVICE I HEREBY CERTIFY THAT I served a certified copy of the Divorce Complaint filed in the above captioned case upon Defendant, Aurthur K. Hurson, by certified mail, return receipt requested on February 8, 2001, addressed to: Arthur K. Hurson 62 W. North Street, Apt. #3 Carlisle, PA 17013 and did thereafter receive same as evidenced by the attached Post Office receipt card dated February 20, 2001. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, lNFORMATION AND BELIEF. I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AU1HORlTlES. 2.1 FeG. 2.001 Date K-o, ROBERT P. KLINE, ESQUIRE 714 Bridge Street Post Office Box 461 New Cumberland, PA 17070-0461 (717) 770-2540 Attorney for Plaintiff .,,_............~ . ,~ ~ :,';'., " .",'" I' '~. j,:"'- ..,-,,-"",, ,~. =' w,~! ,< , , " w ~ -=SI~l -0., \'" {: C Efn'lf~tJJ jVI.~\d H'~ t I ' (Domestic Mail Only; No Insurance Cove/age Plovlded) ["- Return Receipt Fee (Endorsement Required) CJ o Restricted Delivery Fee o (Endorsement Required) CARLISLE PA 11013 IlJ ...0 U') 3' t'- IT' '" CJ Postage $ Certlfled Fee Total Postage & Fees . $ $1.15 CJ IlJ ru Name (Please Pi'lnt Clearly) (To be completed by mailer) rn ...8.B:J:J::\:!.i.g::___:k~____h\.uJS.s.Q..0.___________._...._............... IT"' Street. Apt. No.; or PO Sox No. g:; ......&..?:.....0.-:?:___._b:Lg..~I!L..S.1:_..____._A_rr...!...~........ ~ CIty,;>rate,ZIP+4 IlJl ,..-, ~ ' ,- Ck!Q..LISLt' rfr<, .OJ..::. , . 69~pl~te items 1, 2, and 3. Also corh~l~t~ item 4 if Restricted Delivery is desired. . Print YClur f18Tne and address on the reverse 50 that we can return the card to you. . Attach this card to the back of the mail piece, or on the front if space permits. 1. Article Addressed to: o Agent ,ssa.. fl--R-n+uR... -K. l.kt ~ So D Ioz l-0. t>,\o R;n+ sr. APt: ~ CA-ltL.ISl..Er fA- liD I~ D. s delivery add. different from item 1? If YES, enter delivery address below: DYes D No 3; Service Type ...e:rc;rtified Ma!1 o Registered o Insured Mail o Exp~ss Mail o Return Receipt for Merchandise DC.a.D. 4. Restricted Delivery? (Extra Fee) ~ 2. Article NUf'lb,ef rqopy i'{',m ~eryice fapeQ ! ' , ' ,',',;..j. "". "'_' ,'., t]' , ',',;' ...." ".' "1oQitJ:f i ~Ud:> ! 'C;(!>(:J>-'1' , '-'0"1 "fc,," c... PS Form 3811. July 1999, Domestic Retum Receipt 102595-00-M-0952 , ~~,.~ "'Hf~tm~~~~\M;?&--&;<*,"i;-Mllii:l';"];h",-~j,lf,i!-il'iJ;i~t';';"",~~ ~ I_~~ ~ ~ ~ -~ -" .L ," o C <:.' u(:.:: rnr,': ~~:~- ~t' -:r>C-"" ;-:-;:.....:.: Pc: :z -J ~- ~~ '. t c c) ...., ~ C'O \'-..) cr, N c=) "'J , (:: ;;~::;'Iq .:~:! :':1.) -< ,- Iv "" ." ~.-", '.," '.' , " - ,,. .;,"',..:' . ~',l"";i_,;';;;~,,,', ;i.-c'_,-;," , ~" '~, _''':;__,,;''~: . , . LINDA KAY HURSON, Plaintiff vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL TERM - LAW : NO. 01 - 757 CIVIL TERM ARTHUR K. HURSON, Defendant : DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~ 3301 (c) of the Divorce Code was filed on February 7, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. 6,~&~ ~~ '\\~ Linda Kay H rson, Plaintiff- Date: \0 \cl4\ C') \ \ \ ~~lii-w.lb~~~'if!tt!Ii&Il;I-~{!~iili"~~fu&!~~jJ;t1~;;;\>'ii#J~illi!i!Ml'iii~f[n'" ,'c ,;",~'''' '" ~ , iiIi.!!IIlMlJJ..tiiii,itl~~l.ul ~ .- ~~. ," n~,c , . 2 0 ,0 '-'--'1 s:: 0 -OeD " -n mfTl -I .j\~ Z:X" N :Z:C en};:; .~ -< -'- <;20 -0 ,'- ': 1:-11 -,' ~f~ :ZCl ......,.. --0 i:? '::::'t >c "'f':;' ~ ~ :P (:0 -< ! = ." - " '.: ~ ,j,- ",". ,~'< ~,"",', ;~,i-W~;i''';':'"...j' ~ ',i- i'i . . . LINDA KAY HURSON, Plaintiff V5. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL TERM - LAW : NO. 01 - 757 CIVIL TERM ARTHUR K. HURSON, Defendant : DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. ~ ~C^-.. \z. ~~\ \.1..N"'-^.r--- Linda Kay Hurson, Plaintiff Date: \<::1 \d.A \ (') ( \ \ :.:.,,k:;'~~~eJ~'I;>.~rj~@iliil:l!~;w,~i>J~~~'~Il:~il'WIM.~,,',"m~jf,,;~,,;iiiifu~:t>>t ,J ~ ^' '" '~". ,,,,.', '"",,- , '..Jiii~_ ~"'.I, ~ ~ .~~^ ,-- " Cd I' II II 11 " i.~ II " I ,! II I, I i I I , . 0 c:;> 0 c - s: "T1 rii}-fl 0 n Z:t.i -/ :Z:c I',) "C::; "j.....,., (/)2'",:,' .r-- ",,"'C::I ;::s 2: ':~() ;<C --0 ~c; ~..",~ ~;;~ ~ _'i... ;)>0 ~) c: OI'T~ 2: ~ =< "'" Q) ::0 -:; ~" ~,,'~.~'"~'" ~., ~ ". - ,~" -.. . ~..~~~'" . ,~ < J',', ;': ,"", :':',' -")i ,,,,,) ,;" {;';~:d';""~,,;,~, " ,--' " .'",,~, ,. . LINDA KAY HURSON, Plaintiff V5. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL TERM~LAW : NO. 01 - 757 CIVIL TERM ARTHUR K. HURSON, Defendant : DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~ 3301 (c) of the Divorce Code was filed on February 7, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. j)(e ~'<>ii""""i1l~}-t!l,~fvb'"~iEll!ilJ1<iltl~,~..i!f'd~w:m>l%J3,*,~i"'("'~~lOOIWci~~1IiMi1!"#~imJ!l!~.i'~' ili' __M .~ .,~~" -~ "" .." -, ~ ., , "" . 0 0 G C -n s: a ...j -0 eo '" m,.,-, --I ,~c:.:;:D z-;" .,-..-' z~ N .~-;~~9 ~.;~: .t;:- ~CI -0 ~~~ ~o :24 >8 ':;) brn ~ ::- o;! ();) 31 =~-- 'f . II .- ",;; '. '_ - ',."" ,', _'O""^""' ". ,",~:,',__," 0'" '- '_ " '.' , . . . LINDA KAY HURSON, Plaintiff VS. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL TERM - LAW : NO. 01 - 757 CIVIL TERM ARTHUR K. HURSON, Defendant : DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. li~'r iii' l",~ \1r l!WWl~t'~",liG!j\_~~Mi\t!ii~'Hii~."Uffi'ii~"""~1,'\ffiI~~i-;j-$\J 1~;lU.:' l~ - - oi.f'"., ., ". ~a~,~ . =~, -~ - l'lltill1~"" ~" > V" '...w, . o !;;; -offi QJ fll ~'::n 2:;:- Cf).,E> 2i~' ~'-"" 2:8 Pc 2: :< "-~ ~ ,,-, ~ o o C") "'"' ,N ,','7'" o .'n ,-~.o;;":i "'P::: H!~~ 2;~;~ 'Of :n -< " ,'i:J ::;:s;: N .. c- eo y,' II I: t It Ii I~ "';T'_,!,,, -, '"'-"-X,,:..c',' -'Co"; <, LINDA KAY BURSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01 - 757 CIVIL ARTHUR K, HURSON, Defendant IN DIVORCE ORDER OF COURT AND NOW, this cJ ISf day of ~ tuJ., 2001, the parties and counsel having entered into an agreement and stipulation resolving the economic issues on October 24, 2001, the date set for a four-party conference, the agreement and stipulation having been transcribed, and subsequently signed by the parties and counsel, the appointment of the Master is vacated, and counsel can conclude the proceedings by the filing of a praecipe to transmit the record with the affidavits of consent of the parties so that a final decree in divorce can be entered. BY THE COURT, cc: Robert Peter Kline Attorney for Plaintiff Michael J. Hanft Attorney for Defendant ~~ /1. :2/-cl 9,. '".;,- ""'~lirk~*,~;Mit.ll~l~~irJffi~$.1i'W~&"-'t&!i\ii'-\t'*~"bj'J>&!I~~,j;;HJ"!l:'lf~,'dl'r ' j'~"~ "." - ,~ j~-'J". ,; VlNWI1ASNN3d AINnOO C!f'P!~Uj81~nJ I c. :6 fJ\i v ;.\,J I Z I\ON 10 )U\.jl'V"'" "'" \u~' v 'I"" I'~'!J' ,'. - . '-'", ,--'-',,~ 30t+::O" :iO ~ "' >~~ - '~~ - 'j i ~ . . I ,,:,"^-'. , ',' ~, 'ji; . ' ~ LINDA KAY HURSON, pla.intiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 01 - 757 CIVIL ARTHUR K. HURSON, Defendant IN DIVORCE (WHEREUPON THE FOLLOWING PROCEEDINGS WERE INTERPRETED BY CHUCK SNYDER AND JENICE WOLGEMUTH.) THE MASTER: Today is Wednesday, October 24, 2001. This is the date set for a conference with counsel and the parties. Present in the hearing room are the Plaintiff, Linda Kay Hurson, and her counsel Robert Peter Kline, and the Defendant, Arthur K. Hurson, and his attorney Michael J. Hanft. Also present in the hearing are two interpreters who are interpreting English into sign language inasmuch as the parties are hearing impaired. I will ask both of the interpreters to identify themselves on the record by their name. MR. SNYDER: Chuck Snyder. MS. WOLGEMUTH: Jenice Wolgemuth. First name, J-e-n-i-c-e, last name, W-o-l-g-e-m-u-t-h. THE MASTER: Also present is Lindsay Gingrich, who is here with Mr. Hanft's office. She is a clerk currently in his office. This action was commenced by the filing of a . divorce complaint on February 7, 2001, averring grounds for divorce of irretrievable breakdown of the marriage and the economic claim of equitable distribution. The parties have provided the Master with affidavits of consent and waivers of notice of intention to request entry of divorce decree, both documents having been signed today by the parties. The Master will file the documents with the Prothonotary's office so that the divorce can conclude under Section 3301(c) of the Domestic Relations Code. As previously stated, the economic claim raised in the complaint is equitable distribution. There have been no claims raised for alimony or counsel fees and costs. The Master has been advised that the parties have reached an agreement with respect to the economic claim of equitable distribution. The agreement is going to be placed on the record in the presence of the parties and the interpreters. The agreement as stated on the record will be considered the substantive agreement of the parties not subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. When the agreement has been transcribed it will be sent to counsel to review for typographical errors, the corrections can be made of any errors in the ;.. . ". __~.' c ~ ~ _ _.. ~ , " - H' t transcription, and then the parties will be asked to sign the agreement affirming the terms of settlement as stated on the record. It is specifically noted, however, that when the parties leave the hearing room today, even though there is no signed document, they are bound by the terms of the agreement as stated on the record. Upon receipt by the Master of a completed agreement the Master will prepare an order vacating his appointment so that counsel can file a praecipe transmitting the record to the Court along with the affidavits and waivers requesting a final decree in divorce. The parties were married on June 26, 1993, and separated in September 2000. There were no children born of this marriage. Mr. Kline. MR. KLINE: The parties agree to resolve the equitable distribution issues as follows: 1. Within two (2) weeks of today's date the parties shall arrange for a time to meet to review and divide their collection of photographs. Wife shall contact husband to arrange a time which shall then be confirmed with wife's counsel who will then confirm that time with husband's counsel. 2. At the time the parties meet for the purpose to divide the photographs referred to above, husband shall deliver to wife her Noah's ark set with all accompanying animals in his possession, her engagement ring, and wedding ring. Paragraphs one and two resolve all issues regarding tangible personal property presently located in Pennsylvania. 3. In regard to the tangible personal property presently in storage in the state of Florida, all property located there , t shall be the property of husband and husband shall bear the responsibility for any expense involved in storing or transporting said property with the exception that any pieces of the Noah's ark set referred to above which remain in the storage unit as of this date shall be delivered by husband to wife at husband's expense no later than June 30, 2002. That resolves all the tangible personal property in Florida. 4. In exchange for the agreements contained herein by the parties, wife agrees, upon entry of a divorce decree, to withdraw her claim for spousal support, docketed at No. 704 Support 2001. 5. The parties agree to indemnify and hold each other harmless from any and all credit card obligations for which they are the primary responsible party. The parties agree to sign any and all documents required to effectuate same. 6. Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship including without limitation, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate. Each will at the request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interest, rights, and claims. MR. KLINE: Linda, you heard the agreement stated primarily by myself and also part of it by Mr. Hanft. It was interpreted for you by Chuck. Did you understand everything that was stated? MS. HURSON: Yes. Very clear. MR. KLINE: Is it your intention to enter into this as an agreement to finally resolve your divorce ~'-""" " ",: _'G "" , ~ ' , <.", iii, . ' >' > . . t action? MS. HURSON: Yes. Officially, yes. MR. HANFT: Arthur, you were present while Mr. Kline and I read the agreement and it was interpreted to you by Jenice? MR. HURSON: Completely. Absolutely. MR. HANFT: It is your intention to agree to that agreement, be bound by that agreement, and accept that agTeement as a final resolution of the divorce matter in this case? MR. HURSON: Yes, indeed. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations Code. WITNESS: DATE: ~?l{o Robert Peter Kline Attorney for Plaintiff 4~.~ Attorney for Defendant //-fj-()( d ~c.\C>...\zo-),\ ':\\\JJ\bC\,"-. Linda Kay Hurs6n &!e-Ji ~ )IJdU, ZC[) \ Arthur K. Burson r--"';~;'- ~= ',"' ""'. ,,' ,~ . :'::';''';'''1 "\~~I LINDA KAY HURSON Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. NO. 01 -757 CIVIL 19 ARTHUR K. HURSON IN DIVORCE Defendant STATUS SHEET DATE: AUG 3 0 2001 (J~f~:ITIES: ~~ I~ ~ '- It (a, 1-uOf , ~ ,^'~~o.IJ , "- "'l'i ~ y; Dr THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSn VANIA LINDA KAY HURSON Plaintiff vs. ARTHUR K. HURSON NO. 01-757 JOOx: LINDA KAY HURSON a master with .respect to.the ( X) Divorce ( ) Annulment ( ) Alimony ( ) Alimony Pendente MOTION FOR APPO INTIffi.'lT OF MASTER (Plaintiff) ~~, following claims: moves the court to appoint Lite (X ) ( ) ( ) ( ) Distribution of Property Support Counsel Fees Costs and Exp~nses and in support of the motion states: (1) Discovery is complete as to the claims(s) for which the appointment of a master is requested. (2) The defendant ikltsQ (has not) appeared in ~lldr.s1:=~xx (3) the action ~x~i)r) ,Esquire) . The staturory ground(s) for divorce (is) ,(JixeQx 3301 (c) (4) Delete the inapplicable paragraph(s): (il):XXllb:ex:l<KlXi;OlIlXXscl!tOl:Xao:t:M:lellXS1ir. J(1li~X:xo\1fiK.llg1<-"1I[~k~X'l!l!Ol:!mdxJlQ'::ttm: Jt::e.lIltEllXlctJllXmac 1iOJUl!~X~ : claims: (c) The action is contested with respect to the following divorce, distribution of property (5) The action ~~ (does not involve) complex issues of law or fact. Date: 20 ~rJ>...~ ~ \ (6) The hearing is e."q)ected to take two (2) (hours) ~:l!i~X (7) Additional information, if any. relevant to the motion: Plaintiff and Defendant are deaf. <~} ~~~Q -- Attorney for (Plaintiff) X:M~KJCX ORDER APPOINTING 11ASTER AND NOw 411~ ~-:J... ,ti-.Jel"'< E. ~ f'b/cu.J is appointed maste nth respect to the following claims: 6Ll>l . ~y eh. Co=, l~~' GY\ ~.?~O' ifq~ Esquire, ~ J , #1!~.j;;,~~~'jM,;!~Jl~iM-""ljlL"~;''-'\o,;b!;-L<"!''''Bi~~'~'"'i!tSIlii!i~LJI "~.. _,1,_ ,'~~~'",,,,, ," ~~ \!1~Ni\l^SNN:Jd , 1'\"1(V1 ,.,;," n'I~~""n') ^.U iI ,"-0''.,,' _"''- /-,-n,I,~1 '~I \ : '1 :t: .~~(..~ 8;'Pd In i ),(:1\/lC,,1 ",. . ,.1..,,_,..~1I! I ' ' ~ .',- Ii! 1!1 II w i;1 i!' "I Ii! I;' :!i 'Ii " !1 i: Ii 11 " 0 0 0 C -n g ",. -OeD c: Ti mrr G') p z~~. .~ N ..;,,;:~ zc (/)d:.J.' ('-) ~:~I,~':? ~.r---:-;. c:::.c; -c> )?: ::::;:--T\ 0 -.;,.' ",.)(:~ z (J r'n ~ C) C .. ;-::: /c. "" =< :D ,,0 -<:: ~ . , , ".~ . " "';;,', ;" , .. ->-,~-- 0"'., , , . .. " I~ THE COURT OF COMMON PLEAS OF CUMllERL\J.'lD COUNTY, PENNSnVANIA LINDA KAY HURSON Plaintiff vs. ARTHUR K. HURSON LINDA KAY HURSCN a master with resoect to the ( X) . Divorce ( ) Annulment ( ) Alimony ( ) Alimony Pendente c) 0 C 0 ~ :~; 'i ;2 F- .J} en,>, f'\.) ~''!h1 " " 1\.) ':Jl::J MOTION FOR APPOI~TI1L'lT OF MASTER ~C'Cl (Plaintiff) ~~, moves the ~~h ii& ap~~t following claims: >;:: - ;.::,'6 _ -. "--.J Distribution of~ro~rt:~ Support 10 ~ Counsel Fees Costs and Exp~nses NO. 01-757 Lite (X ) ( ) ( ) ( ) and in support of the motion states: (1) Discovery is complete as to the claims(s) for which the appointment o~ a master is requested. (2) The defendant xk~sQ (has not) appeared in ~xll1:soaJO:c{~xx (3) The staturory ground(s) the action 6!rnx=}l.j];X) ,Esquire). for divorce (is) XilXU 3301 (c) (4) Delete the inapplicable paragraph(s): (ii):xxmrexa:cw.i:otlXis' =J::xa:on1:)es:l:e:d:'~ .l(15}:x~l!~I1JZ:~xJj:~X'~a:ahed{wil1h: ;r:e5p:e:ot:{]tCilx~ tloJt!i!f~.li:l:a:t&iIs : claims: (c) The action is contested with respect to the following divorce, distribution of property (5) Toe action ~C{~ (does not L.volve) complex issues of law or fact. (6) The hearing is e.~ected to take two (2) (hours) ~;S~:l( (7) Additional informat~on, if any. relevant to the motion: Plaintiff and Defendant are deaf. Date: 20 ~1.L'}...?t- 2.cXl\ <: ~+ ('~\4Q -. Attorney for (PlaL.tiff) XlleMnaan/iJ:X Ai'll) NOW is appointed master with ORDER APPOINTING ~L~STER ,19 , respect to the following claims: Esquire, By the Court: , " .Jl~"""","'~~ . , ~ .J,' . IN THE COURT OF COM:MON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LINDA KAY HURSON, Plaintiff v. NO. 01-757 CIVIL TERM CIVIL ACTION - LAW ARTHUR K. HURSON, Defendants IN DIVORCE PRAECIPE TO: PROTHONOTARY Please enter my appearance on behalf of the Defendant, ARTHUR K. HURSON. Respectfully submitted, LAW OFFICE OF MICHAEL J. HANFT Date: 1./ ~ / " ichael J. Hanft, quire Attorney ill No. 57976 19 Brookwood Avenue, Suite 106 Car1isle,PA 17013 (717) 249-5373 Attorney for Arthur K. Hurson, Defendant F:\Uscr Folder\Firm Docs\Gendocs2001\2365-1cl1try.appear.wpd ~,' ~;.nSJ!3'!'l'hn:~'f~'ii~ik~~,;~til~<:Jl;~*'18"J':""i,~;,,,'.oi";"':;'i';i,:l';''''i~''n.If;W;;';'~L;;';-ffiWl~~~' ""1... ,~ .. 'i (') C~-' C < (.1') -oci: 0"1 rnn -'0 Z:-r. Z ," '''.. (j) +=-, " -< / ," C /- " > C1 ~ (-', C ~.,) 2..: {.n )::-: :::! =r~ r",) "". ~J ......~ ~, ~ "'" ----- , ,', --~ ,~, "c__,',. -' "'~,": '"'^, ;-, ~" ~,__ ~ ,~j ~: ~";""':~ ,;,.,;'":,,, ";' ','.," "';..~,li;,,,,~-:c ,,;;,;-.(. , LINDA KAY BURSON, Plaintiff : IN THE COURT OF COM:MON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-757 CNIL TERM ARTHUR K. HURSON, Defendant : ClVIL ACTION - LAW : IN DNORCE NOTICE OF ELECTION TO RETAKE FORMER NAME NOTICE IS HEREBY GIVEN that the Plaintiff in the above matter, having been granted a Final Decree in Divorce from the bonds of matrimony on Ul;.C-E.M.l!::.'="t -4 ,2001, hereby elects to retake and hereafter use her previous name of LINDA KAY WARNER. 6. ~C>-.. \z~ \\\,NI..l:>C7\r-... LINDA KAY HURSON :#-.~'^- \(~\}0~ LINDA KAY W R COMMONWEALTH OF PENNSYLVANIA: : SS COUNTY OF CUMBERLAND On the t~'1'q- day of 'lk("~ , 2001, before me, the undersigned officer, a Notary Public, personally appeared Linda Kay Hurson, known to me or satisfactorily proven to be the person whose name is subscribed to the within instrument, and acknowledge that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I \W' h_~oowi" "'" \ ~(] , NOTARY PUBLIC NOTARIAL SEAL ROBERT PETER KLINE. Notary Public New Cumberland Bora., Cumberland Co. My Commission Expires June 21. 2004 ;";y; "ir';' I (-:-.\.i-.Ilillillliiliiiii ~,,' "0""/'" . ' ~ '-,' '~ ,,;,;!:. ';'-'~.., ""'-,~~~~ ;,;,,",,;~,~ ", .;;;"" ';._.Ii.' ;;, '-"'"';;';''' ',,', ~ ~ ;J (') 0 d ~ C "T1 ;g:" c::l .-4 "UOJ rrI ;r:3! 'i mm t") "'r- '\ Z:r.~ N -om zr :gy ~ ro:J2: CO ':..~C) ~ ';\ ~";;; .. ~' "j" f :C::::'--' :no O~ ~ )>8 ::n: -....... ,,- ~ z ; ;:':..)fn >c ~- 91 :z ~ :< Ul f. " ~-,~-. ~~ , .~ "I ~ --~. ~ '~,,'"' , ^ ',,'"0', .. '"""''''~--'-''''o "~'':''''';>'>",,",:.\, , , ',.' _ --'.'/ j"",'" ~;.',;;"-'''''>;:';;,];;'''''",':;;',-:';,:~:,;;''',~,.;-"',":-;-:,:: ;i.:;',,',-, ',;L''';'~::'<,~~,;:;':",: "" ',;--.,.c"",_>, ~I LINDA KAY HURSON, Plaintiff v. IN THE COURT OF COM:MON PLEAS CUMBERLAND COUNTY, PENNSYL V ANlA NO. 01-757 CIVIL TERM ARTHUR K. HURSON, 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 Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified mail on February 20, 2001, 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: By Plaintiff: October 24,2001; By Defendant: October 24, 2001. 4. Related claims pending: None. All related claims have been resolved pursuant to an agreell1ent reached at the Office of the Divorce Master on October 24, 2001, which has been filed of record and which shall be incorporated into, but shall not merge with the divorce decree. 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301(d) of the Divorce Code: Waiver of notice executed by Plaintiff on October 24, 2001, and by Defendant on October 24, 2001, and both were filed of record by the Divorce Master. Respectfully submitted, Zt~}.bSI.J Ztts()( Date C~1- y~o ROBERT P. KLINE, ESQUIRE 714 Bridge Street Post Office Box 461 New Cumberland, P A 17070-0461 (717) 770-2540 Attorney for Plaintiff ~ .:,;", -).~ :' ,,: ' ~, ,L ".' ~ ,~,-: ~ llfii; ~ ' """,,,"' ~, _foi~"""'~~' I......,j;';.~ .. " .1,,' n"'," ",,' o c ~ -,::-:'''' uJ::D mn"" .~-I-, ~- 63:?: -( ,," ~c :12:n z-" pO c: z: =< ,,'" '~ I o (~-) -on z g "~ -"-~ 1 :::.:.-, N Q.) :~~ \;(,?, >",i ~ ::D -< ""T) -"- ~ ^"'i'r"""'O.....-. '.' -, , '"' LAw OFFICE OF MICHAEL J. HANFT ATTORNEYS & COUNSELLORS AT LAW WI LLlAM A. ADDAMS MICHAEL J. HANFT GREGORY H. KNIGHT RICHARD L. WEBBER, JR. November 9, 2001 Robert P. Kline, Esquire KLINE LAW OFFICE 714 Bridge Street P.O. Box 461 New Cumberland, PA 17070 Re: Hurson v. Hurson Our File No. 2365.1 Dear Rob: Enclosed please find a copy of the fully executed Agreement, the original of which 1 forwarded to Robert Elicker today. Denise, my secretary, spoke to Arthur when he came into my office to sign the Agreement and he indicated that he and Linda plan to meet Saturday, November 9,2001, to divide the pictures. This information coincides with the information you relayed to me via emai1 earlier today. Assuming this meeting occurs as scheduled, it should finalize any and all outstanding Pennsylvania property distribution issues. As soon as Arthur obtains access to the storage space in Florida, he will give Linda any of the Noah's Ark animals he finds therein. I thank you for your assistance in resolving this matter in an expeditious fashion. Should you have any questions or should you wish to discuss this matter further, please do not hesitate to contact me. Very truly yours, MJH/ldg Enclosures cc: E. Robert Elicker, II, Esquire Arthur Hurson F:\User FolJer\Firm Docs\Genltr200 I \2365* l.rk,2. wpd 19 BROOKWOOD AVENUE SUITE 106 CARLISLE. PA 17013-9142 717.249.5373 FAX 717.249.0457 WWW.HANFTLAWFIRM.COM - ,".~ ~., ',' >' ,,-',","~ '~o." .,;,'. ",,'^ ~,' - . ',:,,-;-' /,~~,..,G<"','" ' , :'-""ji,j 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 .10 Colyer Office Manager/Reporter West Shore 697-0371 Ex!. 6535 October 24, 2001 Robert Peter Kline, Esquire 714 Bridge Street P.O. Box 461 New Cumberland, PA 17070-0461 Michael J. Hanft, Esquire 19 Brookwood Avenue Suite 106 Carlisle, PA 17013 RE: Linda Kay Hurson vs. Arthur K. Hurson No. 01 - 757 civil In Divorce Dea~ Mr. Kline and Mr. Hanft: Enclosed is a draft of the agreement which you put on the record on October 24, 2001. please review the draft for any corrections with the understanding that no substantive changes can be made. After you have reviewed the draft, give us a call so we can make appropriate corrections. We will send the corrected original to the Plaintiff's attorney for signature who then can transmit the original to the Defendant's attorney for signature. When I receive a signed copy of the document, I will then obtain a Court order vacating my appointment. Thank you for your continuing cooperation in bringing this matter to settlement. Very truly yours, E. Robert Elicker, II Divorce Master '9IliliIIIIl!l ,',~ ,~,~:"",':i',,"'" ;' 'F~':;;',' "":,"-:i:~:';',+," :__\~~" 'o",:;;,~",,,' -'(::i; LINDA KAY HURSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 01 - 757 CIVIL ARTHUR K. HURSON, Defendant IN DIVORCE CONFERENCE WITH COUNSEL AND PARTIES TO: Robert Peter Kline Linda K. Hurson , Counsel for Plaintiff , Plaintiff Arthur K. Hurson Counsel for Defendant , Defendant A conference has been scheduled at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 24th day of October, 2001, at 9:30 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: 8/30/01 E. Robert Elicker, II Divorce Master ~ "' "i.~' ". _ '";'_~','~___"_~ '"",,;:;, ," ~~,~"""-- ""';,~'''''''r.' '.i..'. .", ---'-, '.,__>"0',', 0"' ,\>i \",.;,-, ,':'~"'__--"~:'::'h', .~~ ;: '~j" ROBERT P. KLINE, ESQ. KIRSTIN M. SWEIGARD, ESQ. August 28,2001 E. Robert Elicker, II, Esquire Office of Divorce Master 9 N. Hanover Street Carlisle, PA 17013 Re: Linda K. Hurson v. Arthur K. Hurson No, 01-757 Dear Bob: I have filed a Motion for the Appointment of the Divorce Master in the above-captioned matter. This is the case that I discussed with you by telephone a month or so ago involving the deaf client that I am representing on a pro bono basis. Her husband is also deaf The husband has not responded to any correspondence that I have provided to him and, to the best of my knowledge, is not represented by counseL There is certain personal property that my client claims belongs to her which is either in the possession of her husband or is located in a storage unit rented by the husband in Florida, where the parties had once resided together. I am hopeful that a resolution of this matter can be reached by means of a conference, although a hearing may be necessary. Obviously, arrangements will need to be made for a sign language interpreter to accommodate the court and counsel in this matter at either a conference or a hearing. As this is a pro bono matter, I will make every effort to make those arrangements with the assistance of Mid Penn Legal Services. ~:!YOU" Robert P. Kline, Esquire RPKlsrf Enclosure 714 Bridge Street P.O. Box 461 New Cumberland, PA 17070 (717) 770-2540 (717) 243-5940 Fax (717) 770-2553 ","--hU~ ~; ""-"L """.. ' "y(-. ",,~,,~~ I-,",~,;;~;"i:__ '_'~' e__;;:; ROBERT P. KLINE, ESQ. KIRSTIN M. SWEIGARD, ESQ. November 6, 2001 Michael J. Hanft, Esquire 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 > t:L o o Re: Hurson Divorce Dear Mike: I am forwarding to you the original Agreement executed by Linda Hurson on this date. Please arrange for Mr. Hurson to sign this Agreement at your earliest opportunity and then forwardiUo the Divorce Master's office. .. 'Linda has confirmed with me that she has received her Noah's Ark set and the rings from your client. However, your client, as of this date, has refused to cooperate in regard to the photographs. Linda would like the matter handled this week and is available to meet with your client at his apartment either Wednesday, Thursday or Saturday of this week in the afternoon. Please advise your client of the need to cooperate in regard to this matter. I thank you again for your cooperation in reaching a resolution to this matter at the Divorce Master's office in October. Very truly yours, Robert P. Kline, Esquire RPKlsrf EnclosJlre: cc: Linda Hurson . E. Robert Elicker, II, Esquire , ',' I',) !', ,;!,' \,;,. ('iL ",','11, ",1,1'\ --", ~..!.i' ")41' F:L \ r -; -, -71 '" ;:-. ~