HomeMy WebLinkAbout99-03548'I
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
LISA KAY MORRISON
i
PLAINTIFF
VERSUS
RICHARD LEE MORRISON,JR.
DEFENDANT
AND NOW,
N O. 99-3548 CTVi TF M
CIVIL ACTION - LAW
IN DIVORCE
DECREE IN
DIVORCE
-1>? 47
dot , IT IS ORDERED AND
DECREED THAT LISA KAY MORRISON , PLAINTIFF,
AND
RICHARD LEE MORRISON, JR
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
DEFENDANT,
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
NONE
ATTEST: J
PROTHONOTARY
LISA KAY MORRISON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
?'• CIVIL ACTION - LAW
RICHARD LEE MORRISON, JR., NO. 99-3548 CIVIL TERM
Defendant 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 complaint: A certified copy of the Complaint in Divorce was served
upon the defendant, Richard Lee Morrison, on June 14, 1999, by certified, restricted delivery mail, addressed to him
at 96 Bears Road, Carlisle, Pennsylvania, 17013, with Return Receipt Number Z 013 345 924.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce
Code: by plaintiff: December 26, 2001; by defendant: December 26, 2001.
(b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code:
(b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant:
4. Related claims pending: NONE.
5. Complete either (a) or (b).
(a) Date and manner of service of the Notice of Intention to file Praecipe to Transmit
Record, a copy of which is attached:
(b) Date plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: December 26, 2001.
Date defendant's Waiver of Notice in Section 3301(c) Divorc was filed with the
Prothonotary: December 26, 2001. If /1
A. IN
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Date: December 27, 2001
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LISA KAY MORRISON,
Plaintiff
V.
RICHARD LEE MORRISON, JR.:
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3548 CIVIL
IN DIVORCE
ORDER OF COURT
711 y?
AND NOW, this ; day of?D?o lk?a
2001, the parties and counsel having entered into an
agreement and stipulation resolving the economic issues on
December 26, 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 proccedings by the filing of a praecipe to
transmit the record with the affidvits of consent of the
parties so that a final decree in divorce can be entered.
BY THE COURT,
AyjAAVN__
Geor e H f r, P.J.
cc: Marcus A. McKnight, III - l b J ?/ ?£2??? `(Y 4? 1Uct-)
Attorney for Plaintiff
P. Richard Wagner
Attorney for Defendant ???
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LISA KAY MORRISON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-3548 CIVIL
RICHARD LEE MORRISON, JR.:
Defendant IN DIVORCE
THE MASTER: Today is Wednesday, December 26,
2001. This is the date set for a conference with counsel
and the parties. Present in the hearing room are Lisa Kay
Morrison and her counsel, Marcus A. McKnight, III, and the
Defendant, Richard Lee Morrison, and his counsel, P.
Richard Wagner.
This action was commenced by the filing of a
divorce complaint on June 10, 1999, raising grounds for
divorce of irretrievable breakdown of the marriage. No
economic claims were raised in the complaint.
On March 30, 2000, the Plaintiff filed a petition
raising economic claims of equitable distribution, alimony,
alimony pendente lite, and counsel fees and expenses.
The parties were married on December 14, 1991,
and separated June 15, 1999. They are the natural parents
of two children.
The Master has been provided affidavits of
consent and waivers of notice of intention to request entry
of divorce decree. The affidavits and waivers will be
filed with the Prothonotary by Mr. McKnight so the divorce
can conclude under Section 3301(c) of the Domestic
Relations Code.
After negotiations this afternoon the Master has
been advised that the parties have reached an agreement
with respect to the outstanding economic issues. The
agreement is going to be placed on the record in the
presence of the parties. The agreement that is placed 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. The parties and counsel
will return tomorrow to review the draft of the agreement
for typographical errors, make any corrections as required,
and then affix their signatures affirming the terms of
settlement as stated on the record. It is specifically
understood that the parties are bound by the terms of the
agreement when they leave the hearing room today even
though there may be no subsequent signing of the agreement
affirming the terms of the settlement.
upon receipt of the completed agreement, the
Master will prepare an order vacating his appointment and
counsel can then file a praecipe transmitting the record to
the Court requesting a final decree in divorce. Mr.
McKnight.
MR. MCKNIGHT: After discussion this morning, or
this afternoon, and negotiations, the parties have reached
the following settlement:
1. Each party will maintain all personal property in
their own possession. Each party waives all right, title,
and interest in the personal property in the possession of
the other party.
2. Wife agrees to waive all her right, title, and
interest in the marital real estate and in husband's 401K
retirement plan. In return husband agrees to pay wife the
sum of $25,000.00 by refinancing an existing loan to his
uncle, Robert Morrison, and until he does that will hold
wife harmless from any liability on payment of said loan to
his uncle. Husband will have 60 days to complete the
refinance and pay the sum of $25,000.00 to wife although it
is understood that if he can do it sooner than that, he
will do so. The wife agrees to execute and deliver a deed
conveying her interest in her share of the real estate to
husband upon receipt of the $25,000.00. Wife will convey
by deed her interest in the real estate to husband and it
will be placed in escrow pending receipt of the funds
although it could be released earlier, if need be, to
complete the refinance. Husband will provide to wife proof
that the obligation to the uncle has been satisfied in
full.
3. The parties agree that neither will seek any alimony
from the other after the finalization of the divorce and
that the current order for spousal support will end as of
the date of the divorce. The parties agree that wife shall
be entitled to use both children as income tax exemptions
for the year 2001 and in subsequent years thereafter.
4. Each party agrees to pay their own counsel fees and
costs to their respective counsel.
5. Each party agrees to execute whatever documents are
necessary to effectuate the terms of this agreement
including, but not limited to, husband's pension and such
other documents necessary to effectuate the lending of
money from a lending institution to the husband.
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 hereinafter 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 interests, rights, and claims.
THE MASTER: If you would go on the record
with your client, Mr. McKnight.
MR. MCKNIGHT: Lisa Morrison, you have heard
the terms of the settlement. Is that correct?
MS. MORRISON: Yes.
MR. MCKNIGHT: And are you in agreement that
it is a satisfactory resolution of all the issues
outstanding in this marital litigation?
MS. MORRISON: Yes.
MR. MCKNIGHT: And you're completely
satisfied with your representation and with all aspects of
this settlement?
MS. MORRISON: Yes.
MR. WAGNER: Rich, you've sat here as Mr.
McKnight dictated the terms of this purported agreement.
Did you hear those terms?
MR. MORRISON: Yes.
MR. WAGNER: Do you understand those terms?
MR. MORRISON: Yes.
MR. WAGNER: Do you have any questions about
any of those terms?
MR. MORRISON: No.
MR. WAGNER: Do you understand that this is
a contract, and that this will be the final agreement
between you and your wife as is related to any domestic
issues other than child support and custody?
MR. MORRISON: Yes.
MR. WAGNER: Knowing that and hearing what
Mr. McKnight said, is it your desire that this be entered
as a full and final agreement in your divorce action?
MR. MORRISON: Yes.
MR. WAGNER: Thank you.
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:
lllenti ? G 7 4 I
III isa Kay P rrison
for Pff
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Cha Wagner kichard Lee Morrison, Jr. /
Attorney for Defendant
LISA KAY MORRISON, IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
v CIVIL ACTION - LAW
99- CIVIL TERM
RICHARD LEE MORRISON, JR.,
Defendant IN DIVORCE
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take prompt action. You are warned that if you fail to do so, the case
may proceed without you and a decree in 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 divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the Office of
the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania 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, Pennsylvania 17013
717-249-3166
1-800-990-9108
AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduled conference or hearing.
LISA KAY MORRISON,
Plaintiff
V.
RICHARD LEE MORRISON, JR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
99- CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(c)
OF THE DIVORCE CODE
NOW comes the plaintiff, Lisa Kay Morrison, by her attorney, Marcus A. McKnight, III,
Esquire, and files this complaint in divorce against the defendant, Richard Lee Morison, Jr.,
representing as follows:
1. The plaintiff is Lisa Kay Morrison, an adult individual residing at 96 Bears Road,
Carlisle, Cumberland County, Pennsylvania 17013
2. The defendant is Richard Lee Morrison, Jr., an adult individual residing at 96 Bears
Road, Carlisle, Cumberland County, Pennsylvania 17013.
3. The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six
months prior to the filing of this action in divorce.
4. The plaintiff and the defendant were married on December 14, 1991 in Newville,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. There were two (2) children bom to this marriage, namely, Daniel Richard Morrison,
born September 2, 1992, age 6 years, and Mekayla Elizabeth Morrison, born October 27, 1994,
age 4 years.
7. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon
which this action is based that the marriage between the parties is irretrievably broken.
8. The plaintiff avers that she has been advised of the availability of counseling and that
said party has the right to request that the court require the parties to participate in counseling.
WHEREFORE, the plaintiff demands judgment dissolving the marriage between the
two parties.
Respectfully submitted,
By: :777
M c s A. Mc ight, , Esquire
A orn for Plaintiff
West Pomfret fessional u
60 West Pomfret St-rEet-I
Carlisle, Pennsylvania 17013
(717) 249-2353
Supreme Court I.D. No. 25476
Date: June 7 9 1999
VERIFICATION
The foregoing Complaint in Divorce is based upon information which has been gathered
by my counsel and me in the preparation of this action. I have read the statements made in this
Complaint and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unswom falsification to authorities.
LISA KAY M RRISON
Date: June, 1999
LISA KAY MORRISON,
Plaintiff
V.
RICHARD LEE MORRISON, JR.,
Defendant
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
99- CIVIL TERM
IN DIVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
The Plaintiff, being duly swom according to law, deposes and says:
1. I have been advised of the availability of marriage counseling and understand that I
may request that the court require that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the Prothonotary's
Office, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unswom falsification to authorities.
Date: June '1999
LISA KA ORRISON
LISA KAY MORRISON,
Plaintiff
V.
ROBERT LEE MORRISON, JR.,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
99-3548 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF SERVICE OF COMPLAINT
PURSUANT TO PA. R C P RULE NO 1920.4 (a)(1)(i)
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
AND NOW, Marcus A. McKnight, III, Esquire, being duly sworn according to law, does
depose and state:
1. That he is a competent adult and attorney for the plaintiff in the captioned action in
divorce.
2. That he served the Complaint in Divorce upon the defendant, Richard Lee Morrison, Jr.,
on June 14, 1999, by certified mail Z 013 345 924, restricted delivery, at the address of 96 Bears
Road, Carlisle, Pennsylvania 17013.
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. P7S. Sectio?904, relating to unsworn
falsification to authorities.
Marcus A. N K?j- , III
Attorney for aintrff
Date: December 27, 2001
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RICHARD LEE MORRISON JR
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LISA KAY MORRISON,
Plaintiff
V.
RICHARD LEE MORRISON, JR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
99-3548 CIVIL TERM
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June
10, 1999.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4. 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.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unswom falsification to authorities.
Date: December (?6, 2001 ??{ (11? I1(?N( /p/li/?/,?s?,,?
?f LISA Y MORRISON
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LISA KAY MORRISON, IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
99-3548 CIVIL TERM
RICHARD LEE MORRISON, JR.,
Defendant IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301fc1 OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court
and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: December C?/O, 2001
LISA Y MORRISON
Plaintiff
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LISA KAY MORRISON,
Plaintiff
V.
RICHARD LEE MORRISON, JR.,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
99-3548 CIVIL TERM
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June
10, 1999.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4. 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.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unswom falsification to authorities.
J ,-
Date: December aG , 2001 /t/1 (-el_n RICHAkfi LEE MORRISON,
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LISA KAY MORRISON, IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
99-3548 CIVIL TERM
RICHARD LEE MORRISON, JR.,
Defendant IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301fc1 OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court
and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unswom falsification to authorities.
Date: Decemberi , 2001 /?' l['/ (/ ,?G'LG e. ' ti
RICHARD LEE MORRISON, JR.
Defendant
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LISA KAY MORRISON,
Plaintiff
V.
RICHARD LEE MORRISON, JR.,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
99-3548 CIVIL TERM
IN DIVORCE
DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT
The defendant, being duly sworn according to law, deposes and says:
1. I have been advised of the availability of marriage counseling and understand that I
may request that the court require that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the Prothonotary's
Office, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down.
I verify that the statements made in this affidavit are true and co Tect. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unswom falsification to authorities.
Date: December _z;e, 2001
RICHARD LEE MORRISON, JR/
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SOCIAL SECURITY INFORMATION SHEET
PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1 (a) (3) ALL DIVORCES MUST
INCLUDE THE PARTIES SOCIAL SECURITY NUMBER
PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE
PROTHONOTARY'S OFFICE
DATE: DECEMBER 27, 2001
DOCKET NUMBER: 99-3548 CIVIL TERM
PLANTIFF/RRUjI'j g SSm 207-56-6329
NAME: LISA KAY MORRISON
DEFENDANT/R NW%TT SS 201-60-2970
NAME: RICHARD LEE MORRISON SR,
1
IN THE COURT OF COMMON PLEAS OF
LISA KAY MORRISON CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff CIVIL ACTION - LAW
VS. No•99.3548 CIVIL 19
IN DIVORCE
RICHARD LEE MORRISON, JR.
Defendant
STATUS SHEET
DATE: I '--? ACTIVITIES:
JUL 0 9 2001
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LISA KAY MORRISON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
Vs. NO. 99 - 3548 CIVIL
RICHARD LEE MORRISON, JR.,:
Defendant IN DIVORCE
TO: Marcus A. McKnight, III
P. Richard Wagner
Attorney for Plaintiff
Attorney for Defendant
DATE: Monday, July 9, 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.
(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.
LISA KAY MORRISON, : IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA
V. 99-3548 CIVIL TERM
CIVIL ACTION - LAW
RICHARD LEE MORRISON, JR., IN DIVORCE
Defendant/Respondent
PETITION FOR ECONOMIC RELIEF
AND NOW, this 29th day of March 2000, comes the plaintiff/petitioner, Lisa Kay
Morrison, by her attorneys, IRWIN, McKNIGHT & HUGHES, and makes the following Petition
for Economic Relief against the defendant/respondent, Richard Lee Morrison, Jr., as follows:
The petitioner is Lisa Kay Morrison who is the plaintiff in a divorce action filed at 99-
3548 in Cumberland County, Pennsylvania. Her address is 4 West Main Street, Apartment 2,
Newville, Cumberland County, Pennsylvania 17241.
The respondent is Richard Lee Morrison, Jr., who is the defendant in this divorce action.
His address is 96 Bears Road, Newville, Cumberland County, Pennsylvania 17241.
3.
The petitioner seeks the following relief from the Court:
a. Equitable distribution of the marital assets;
b. Spousal support;
C. Alimony pendente lite;
d. Alimony;
e. Costs and expenses; and
f. Counsel fees.
WHEREFORE, the petitioner, Lisa Kay Morrison, requests the relief set forth above.
Respectfully submitted,
By:
Date: March 29 2000
IRWIN, McKNIGHT & HUGHES
60 West Po fret Street
Carlisle, PA
717-249-2353
Supreme Court I.D. No: 25476
Attorney for the plaintiff/petitioner,
Lisa Kay Morrison
7
VERIFICATION
The foregoing Petition for Economic Relief is based upon information which has been
gathered by counsel and myself in the preparation of this action. I have read the statements made
in this document and they are true and correct to the best of my knowledge, information and
belief. I understand that false statements herein made are subject to the penalties of 18 Pa.
C.S.A. Section 4904, relating to unsworn falsification to authorities.
r?
I A KAY MORMON
Date: MARCH 29 2000
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LAW OFFICES
MANCKE, WAGNER, HERSHEY a TULLY
JOHN B. MANCKE 2233 NORTH FRONT STREET
P. RICHARD WAGNER HARRISBURG. PA 17110
DAVID E. HERSHEY
WILLIAM T. TULLY
August 21, 2001
E. Robert Elicker, II, Divorce Master
Office of Divorce Master
9 North Hanover Street
Carlisle, PA 17013
PHONE 17171 234-7051
FAX 17171 234.7080
Re: Lisa Kay Morrison v. Richard Lee Morrison, Jr. - Docket # 99-3548 Civil
Dear Mr. Elicker:
Enclosed is Defendant's Pretrial Memorandum relative to the above-captioned matter. We
are this date serving a copy of this Memorandum upon counsel for Plaintiff, Marcus McKnight.
If you have any questions or comments, please feel free to contact me.
Thank you for your consideration.
P. Richard
PRW:tlk
Enclosure
cc: Marcus McKnight, III, Esquire
kl?vry
LISA KAY MORRISON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
RICHARD LEE MORRISON, JR.,
Defendant
NO. 99-3548 CIVIL
IN DIVORCE
DEFENDANT'S PRETRIAL MEMORANDUM
TO THE HONORABLE JUDGES OF THE ABOVE-SAID COURT:
1. FACTS
The parties were married on December 21, 1991 in Newville, Pennsylvania and separated
June 15, 1999.
The Husband works at the Lear Corporation, Carlisle (formerly Masland's). Wife works for
D&L Systems.
The parties are the parents of two children, Daniel bom September 2, 1992; and Mekayla
bom October 27, 1994.
Currently, there is a child support only order in place for $703 per month payable by
Husband to Wife.
If. ASSETS
The parties have a property situated at 96 Bears Road, Carlisle. It is owned by the parties
along with the father of the Husband.
Husband estimates the value of the property to be approximately $140,000 with
approximately $40,000 owed on the home.
Husband has a pension through his place of employment at Lear that currently has a value
of approximately $30,600, with his date of hire of February 27, 1989.
III. INCOME
The income of the Husband as determined by the most recent Domestic Relations
conference dated July 27, 2000 was a net income of the Husband of $2,525 per month; and Wife
of $1,204.10 per month. Husband is paying 75% of the court-ordered counseling expenses for the
children related to a custody action in Cumberland County.
IV. PENSION
Husband has a pension through the Lear Corporation, a copy of which is attached and
marked as Exhibit "A".
V. ESTIMATED LENGTH OF TRIAL
A half day is estimated by the Husband.
VI. PROPOSED RESOLUTION
Husband proposes that the assets be valued and that 50% be paid unto Wife by Husband
and he retain ownership of the home and his pension.
Although Wife has requested an agreement for purposes of college education on behalf of
the children, that issue is not recognizable under Pennsylvania law and, therefore, Husband
respectfully requests that no order be entered concerning college education.
Respectfully submitted,
Mancke Wagner Hershey & Tully
. Ri and r, Esquire
2233 IVOfffi Front Street
Date: 08/21/01 Harrisburg, PA 17110
717/234-7051
CERTIFICATE OF SERVICE
I, P. Richard Wagner, Esquire, of the law fine of Mancke Wagner Hershey & Tully, hereby
certify that I am this day serving a copy of the foregoing document to the attorneys or parties of
record in the manner indicated below, which service satisfies the requirements of the Pennsylvania
Rules of Civil Procedure, by depositing a copy of same in the United States Mail, postage prepaid
at Harrisburg, Pennsylvania, on the 2V day of August, 2001.
Marcus McKnight, III, Esquire
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, PA 17013
By:
r Wagner, Esquire
Mancke Wagner Hershey & Tully
Lear Link
P.O. Box 420
Little Falls, NJ 07424-0420
RICHARD L MORRISON
96 BEARS RD
CARLISLE PA 17013
Closing Balance Vested Balance
Employee Balance $ 11
3
Company Prior Balance
$ ,
85.19
15
5
$
11,385.19
Company Balance $ ,
28.21
3
6 $ 15,528.21
,
87.40 $ 3,687.40
Total Balance
$ 30, 600.80
$
30,600.80
Important Notes
- As of the closing date of this statement, the price of Lear Corporation Common Stock was
$34.9000 per share.
Lear Common Stock Share Equivalent: 0.000 shares. The Share Equivalent is equal to your
closing balance in the Lear Stock Fund divided by the price of Lear Common Stock as of the
statement ending date. Please remember that you own an interest in the fund that invests in
Lear Common Stock and it holds a small portion in cash or cash equivalents. It is this
interest in the fund that determines the dollar value of your account.
- The Rates of Return reflect the net investment experience of each fund, and do not account
for the timing of transactions. The measurement of these Rates of Return is for the period
covered by the dates of the statements issued to you.
- The dates on this statement are based on our current records. Please review them. If your
records indicate different dates, please call Lear Link and we will investigate the differences.
- Service for determining your company match percent is measured from 02/27/89
- Please make sure that you have provided Lear Link with your most updated beneficiary
information. To find out your most recent beneficiary information on file or to request a new
beneficiary form, please call Lear Link.
- Please note the amount of tax paid credit in your account is $ 0.00
Lear Link Reminder
If you have a question about your account:
Information about your account is available through Lear Link, an automated voice response
system. Lear Link may be reached by calling 1-888-333-LEAK (1-888-333-5327) and is
available 24 hours a day, seven days a week. You may also access your account through
Lear Link Online at https://www2.benefitsweb.com/lear.html.
If you have a question about your account which cannot be answered through Lear Link,
the automated voice response system:
You can reach a Lear Customer Service Representative by choosing option 7 from the
Lear Link main menu any business day between the hours of 9:00 a.m. and 6:00 p.m. Eastern
Time.
If YOU have a question.about the Plan's investment alternatives:
Representatives'from'PaineWebber, which assists in the Plan's investment strategy, may be
reached by choosing option '8' from the Lear Link main menu any business day between the
hours of 9:00 a.m. and 5:00 p.m. Eastern Time. While PaineWebber Representatives cannot
offer specific investment advice, they can provide you with information that may help you
determine which fund - or combination of funds - best meets your needs.
•i EXHIBIT
LISA KAY MORRISON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 99 - 3548 CIVIL
RICHARD LEE MORRISON, JR.,:
Defendant IN DIVORCE
CONFERENCE WITH
COUNSEL AND THE PARTIES
TO: Marcus A. McKnight, III , Counsel for Plaintiff
Lisa Kay Morrison , Plaintiff
P. Richard Wagner , Counsel for Defendant
Richard Lee Morrison, Jr. , Defendant
A conference has been scheduled at the office of
the Divorce Master, 9 North Hanover Street, Carlisle,
Pennsylvania, on the 26th day of December 2001, at 2:00
p.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: E. Robert Elicker, II
December 5, 2001 Divorce Master
LISA KAY MORRISON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 99 - 3548 CIVIL
RICHARD LEE MORRISON, JR.
Defendant IN DIVORCE
NOTICE OF PRE-HEARING CONFERENCE
TO: Marcus A. McKnight, III
P. Richard Wagner
Attorney for Plaintiff
Attorney for Defendant
A pre-hearing conference has been scheduled
at the office of the Divorce Master, 9 North Hanover Street,
Carlisle, Pennsylvania, on the 26th of October, 2001, at
9:30 a.m., at which time we will review the pre-trial
statements previously filed by counsel, define issues,
identify witnesses, explore the possibility of settlement
and, if necessary, schedule a hearing.
Very truly yours,
Date of Notice: 8/23/01 E. Robert Elicker, II
Divorce Master
LISA KAY MORRISON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 99 - 3548 CIVIL
RICHARD LEE MORRISON, JR.,:
Defendant IN DIVORCE
BANSCHEDULED PRE-HEARING CONFERENCE
TO: Marcus A. McKnight, III , Attorney for Plaintiff
P. Richard Wagner , Attorney for Defendant
A pre-hearing conference has been scheduled at the
Office of the Divorce Master, 9 North Hanover Street,
Carlisle, Pennsylvania, on the 5th day of December, 2001, at
9:30 a.m., at which time we will review the pre-trial
statements previously filed by counsel, define issues,
identify witnesses, explore the possibility of settlement
and, if necessary, schedule a hearing.
Very truly yours,
Date of Notice: 10/25/01 E. Robert Elicker, II
Divorce Master
LAW OFFICES
MANCKE, WAGNER, HERSHEY & TULLY
3233 NORTH FRONT STREET MANCKE P. JOHN p. RICHARD WAG WAGNER HARRISBURG. PA ITIIO
DAVID E. HERSHEY
WILLIAM T. TULLY
July 17, 2001
E. Robert Elicker, Esquire
9 North Hanover Street
Carlisle, PA 17013
Re: Morrison v. Morrison
No: 99-3548
Dear Mr. Elicker:
PHONE 17171234-7051
FAX 17171234.7080
Enclosed herein please the Certification verifying that discovery is complete
on behalf of my client, Richard Morrison.
Your attention is appreciated. -?
PRW/dks
Enclosure
Sincerely,
i
P. Richard Wabmer---?
cc: Marcus A. McKnight, III, Esq.
JUL 1 8 2001 r
LISA KAY MORRISON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99 - 3548 CIVIL
RICHARD LEE MORRISON, JR.,:
Defendant IN DIVORCE
TO: Marcus A. McKnight, III
P. Richard Wagner
Attorney for Plaintiff
Attorney for Defendant
DATE: Monday, July 9, 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.
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
DATE COUN -76'R 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.
LAW OFFICES
IRWIN MCKNIGHT & HUGHES
ROGER B. IRWIN
MARCUS A. MCKNIGHT. N1
JAMESD. HUGHES
REBECCA R. HUGHES
MARK D. SCHIPAR77
DOUGLAS G. MILLER
WEST POMFRET PROFESSIONAL BUILDING
60 WEST POMFRET STREET
CARLISLE, PENNSYLVANIA 17013.3222
(717) 249.2353
FAX (717) 249-054
E-MAIL! IMHLAWOSUPERNETCOM
July 16, 2001
E. Robert Elicker, II, Esquire
Office of the Divorce Master
9 North Hanover Street
Carlisle, PA 17013
Re: Lisa Kay Morrison v.
Richard Lee Morrison, Jr.
99-3548
Dear Bob:
HAROLD S. IRWIN (1915.1977)
HAROLD S. IRWIN, JR. (1954-1986)
IRWIN. IRWIN&IRWIN (1956-1986)
IRWIN, IRWIN & A&KNIGIIT (1986-1994)
IRWIN MCKNIGHT & HUGHES (1994. )
I have enclosed the response to the Discover Certification on behalf of my client, Lisa
Kay Morrison. Please proceed with the scheduling of this case.
Very truly yours,
IRWIN, McKNI T & HU S
Marcus A. Mc fight, III, Es .
MAM/min
Encl.
cc: Ms. Lisa Kay Morrison
P. Richard Wagner
AL 17111
LISA KAY MORRISON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99 - 3548 CIVIL
RICHARD LEE MORRISON, JR.,:
Defendant IN DIVORCE
TO: Marcus A. McKnight, III
P. Richard Wagner
Attorney for Plaintiff
Attorney for Defendant
DATE: Monday, July 9, 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.
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
A .1 ?r
CIO DAVE COUNSEL F R PLAIN FF (?
COUNSEL FO EFEND T ( )
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.
i.
LISA RAY MORRISON,
Plaintiff
vs.
RICHARD LEE MORRISON, JR.,
De endant :
a master with respect to th
( % ) Divorce
( ) Annulment
( % ) Alimony
IN THE COURT OF COMS!ON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Looa e o Inr6F
Np. 99-3548 19
IN DIVORCE
claims:
( % ) Alimony Pendente Lite
and in support of the motion states:
, moves the court to appoint
(R) Distribution of Property
( % ) Support
(g ) Counsel Fees
(R ) Costs and Fxpenses
(1) Discovery is complete as to the claims(s) for which the
appointment of a master is requested.
(2) The defendant (has) Q appeared in the action
(by his attorney, P. RICHARD WAGNER Esquire).
(3) The statutory ground(s) for divorce (is) (are)
(4) Delete the inapplicable paragraph(s):
(a) The action is not contested.
(b) An agreement has been reached with respect to the
following claims: DIVORCE
(c) The action is contested with respect to the following
claims: ALL OTHERS
(5) The action I a: (does not involve) complex issues of law
or fact.
(6) The hearing is expected to take ONE (1) (days).
(7) Additignal information, if any. relev,plt to.,the motion:
Date: JUNE. 29, 2001
Attorney
UaULi( arrVL.X1':ZUlnx
APID N04i ?t9?; _?of1Zc1 l ?i?f?Lc Esquire,
is appointed ma ter th respect to the following claims:
By the Court:
V V1 lei
,,
r
•, ., ?
_:,
?,: ?:,
,, ,
?,:
.. v
LISA KAY MORRISON, IN THE COURT OF COMMON PLEAS OF
Petitioner
CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
99-35LWCIVIL TERM
RICHARD LEE MORRISON, JR.,
Respondent IN CUSTODY
ORDER OF COURT
AND NOW, this /.S- day of rLtr1L 1999, upon consideration of the
attached Petition, it is hereby directed that the parties and their respective counsel appear
beforeh G\\1 ` Esquire, the conciliator, at
AA Aylyj
fldlt p7/AO, on the ? day of _ .1999
at R. M. for a Pre-Hearing Custody Conference. At such conference, an e rt will be made
to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues
to be heard by the Court and to enter into a temporary order. All children age five or older may
also be present at the conference. Failure to appear at this conference may provide grounds for
entry of a temporary or permanent order.
By the Court,
By: ga'L 11 // dv' , ACustody Conciliator
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, Pennsylvania 17013
(717) 249-3166
1-800-990-9108
ARY
n JU'! 1 3 ..: i t I: 5Ci
' 'r ,
LL.'S .1Jv.t?
/? ?i eel
AMERICANS WITH DISABH,ITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduling conference or hearing.
LISA KAY MORRISON, IN THE COURT OF COMMON PLEAS OF
Petitioner
CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
99- CIVIL TERM
RICHARD LEE MORRISON, JR.,
Respondent IN CUSTODY
PETITION FOR CUSTODY
AND NOW, this A?day of June 1999, comes the Petitioner, Lisa Kay Morrison, by her
attorneys, Irwin, McKnight and Hughes, and presents the following Petition for Custody.
The petitioner is Lisa Kay Morrison, an adult individual residing at 4 West Main Street,
Apt. #2, Newville, Cumberland County, Pennsylvania 17241.
2.
The respondent is Richard Lee Morrison, Jr., an adult individual residing 96 Bears Road,
Carlisle, Cumberland County, Pennsylvania, 17013.
3.
The parties are the natural parents of two minor children, namely, Daniel Richard
Morrison, born September 2, 1992, age 6 years, and Mekayla Elizabeth Morrison, bom October
27, 1994, age 4 years.
4.
The parties were residents of the Commonwealth of Pennsylvania since birth.
5.
Petitioner desires primary physical custody of the children and joint legal custody with
periods of visitation to respondent as can be mutually arranged between the parties.
6.
The best interest of the children requires that the court grant the petitioner's request as set
forth above.
WHEREFORE, petitioner respectfully seeks the entry of an Order of Court seeking
primary physical custody of the children and joint legal custody with periods of visitation to
respondent as can be mutually arranged between the parties.
Respectfully submitted,
IRWIN, IGHT & HUGHES
By:
Ma us A. McKnight, III, Esquire
Attorney for Petitioner,
Lisa Kay Morrison
60 West Pomfret Street
Carlisle, Pennsylvania 17013
(717) 249-2353
Supreme Court I. D. No. 25476
Date: June qt--, 1999
VERIFICATION
The foregoing Petition is based upon information which has been gathered by my counsel
and me in the preparation of this action. I have read the statements made in this Petition and they
are true and correct to the best of my knowledge, information and belief. I understand that false
statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to
unswom falsification to authorities.
6 LISA I{A ORRISON
Date: June 1999
JUL 16 199
LISA KAY MORRISON, IN THE COURT OF COMMON PLEAS OF
Plaintiff' CUMBERLAND COUNTY, PENNSYLVANIA
v : CIVIL ACTION - LAW
RICHARD LEE MORRISON, JR., NO. 99-3548 CIVIL
Defendant IN CUSTODY
COURT ORDER
AND NOW, this Ih (•`day of July, 1999, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
The Mother, Lisa Kay Morrison, and the Father, Richard Lee Morrison, Jr., shall
enjoy shared legal custody of Daniel Richard Morrison, bom September 2, 1992;
and Mekayla Elizabeth Morrison, bom October 27, 1994.
2. The Mother shall enjoy primary physical custody of the minor children.
3. The Father shall enjoy liberal periods of temporary physical custody of the minor
children at such times as agreed upon by the parties.
4. The Christmas holiday shall be handled such that Mother shall always have the
children from Christmas Eve from 3:00 p.m. until Christmas Day at 3:00 p.m. with
the Father having the children on Christmas Day at 3:00 p.m. until at least December
26th at 3:00 p.m.
5. This order is entered pursuant to an agreement reached by the parties at a Custody
Conciliation Conference. In the event either party desires to modify this order, that
party may petition the court to have the case again scheduled with the Custody
Conciliator for a Conciliation Conference.
BY TH OURT
J.
cc: Marcus A. McKnight, III, Esq.
Dale F. Shugart, Jr., Esq.
9!UL 19 f'Ii 2:27
PLNiJ5 f L??'?(?J1
LISA KAY MORRISON,
Plaintiff
RICHARD LEE MORRISON, JR.,
Defendant
Prior Judge:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
N0.99-3548 CIVIL
IN CUSTODY
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
19153-8(b), the undersigned Custody Conciliator submits the following report:
The pertinent information pertaining to the children who are the subject of this litigation is
as follows:
Daniel Richard Morrison, bom September 2, 1992; and Mekayla Elizabeth Morrison, bom
October 27, 1994.
2. A Conciliation Conference was held on July 16, 1999, with the following individuals in
attendance:
The Mother, Lisa Kay Morrison, with her counsel, Marcus A. McKnight, III, Esquire; and
the Father, Richard Lee Morrison, Jr., with his counsel, Dale F. Shugart, Jr., Esquire.
3. The parties agree to the entry of an order in the form as attached.
' 4 l2
DATE Hubert X. Gilroy, Es "ire
Custody Conciliato
LISA KAY MORRISON, : IN THE COURT OF COMMON PLEAS OF
PLAINTIFF/PETITIONER : CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
RICHARD LEE MORRISON, JR., IN CUSTODY
DEFENDANT/RESPONDENT NO. 99-3548
ORDER OF COURT
AND NOW, this -']\ day of Mf(C h , 2000, on consideration of the
attached petition, it is hereby directed that the parties and their respective counsel appear before
Hubert X. Gilroy, Esquire, the conciliator, on the 4th Floor, Cumberland County Courthouse, on
the a^°L day of ,, T?2000, at 1o:,3 p. M. for a Pre-Hearing Custody Conference.
At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be
accomplished, to define and narrow the issues to be heard by the Court and to enter
into a temporary order. Failure to appear at this conference may provide grounds for entry of a
temporary or permanent order.
By the Court,
By: 1 )CA CLAD o I
Custody Conciliator (J C?.l
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, Pennsylvania 17013
717-249-3166
1-800-990-9108
?? •c? cam- ?? ,? ? ? ??'?'?`;?`
AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our
office. All arrangements must be made at least 72 hours prior to any hearing or business before the court.
You must attend the scheduled conference or hearing.
LISA KAY MORRISON, : IN THE COURT OF COMMON PLEAS OF
PLAINTIFF/PETITIONER : CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
RICHARD LEE MORRISON, JR., IN CUSTODY
DEFENDANT/RESPONDENT NO. 99-3548
PETITION FOR CUSTODY
AND NOW, comes the Plaintiff/Petitioner, Lisa Kay Morrison, by her attorneys, Irwin,
Irwin & McKnight, and presents the following Petition for Custody:
1.
The Petitioner is Lisa Kay Morrison, an adult individual residing at 4 West Main Street,
Apartment 2, Newville, Pennsylvania 17241.
2.
The Respondent is Richard Lee Morrison, Jr., an adult individual residing at 96 Bears
Road, Newville, Pennsylvania 17241.
3.
The parties are the natural parents of Daniel Richard Morrison, age seven (7) born
September 2, 1992, and Mekayla Elizabeth Morrison, age five (5) born October 27, 1994.
4.
The parties currently enjoy an indefinite schedule which the petitioner seeks to make
more specific. A copy of the current Order of Court is attached hereto and marked as Exhibit
A"
5.
Petitioner desires primary physical custody of the children and joint legal custody with
periods of visitation to respondent as can be mutually arranged between the parties.
6.
The best interest of the children requires that the court grant the petitioner's request as set
forth above.
WHEREFORE, petitioner respectfully seeks the entry of an Order of Court seeking
primary physical custody of the children and joint legal custody with periods of visitation tG
respondent as can be mutually arranged between the parties.
Respectfully submitted,
IRWIN, IRWIN & McKNIGHT
By:
Mar s A. M fight, III, Esq.
60 West Pomfret Street
Carlisle, Pennsylvania 17013
(717) 249-2353
Attorney for Petitioner
Supreme Court I.D. No. 25476
Date: March 29, 2000
EXHIBIT A
JUL 16 199
LISA KAY MORRISON, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v : CIVIL ACTION - LAW
RICHARD LEE MORRISON, JR., NO. 99-3548 CIVIL
Defendant IN CUSTODY
COURT ORDER
AND NOW, this day of July, 1999, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
1. The Mother, Lisa Kay Morrison, and the Father, Richard Lee Morrison, Jr., shall
enjoy shared legal custody of Daniel Richard Morrison, bom September 2, 1992;
and Mekayla Elizabeth Morrison, bom October 27, 1994.
2. The Mother shall enjoy primary physical custody of the minor children.
3. The Father shall enjoy liberal periods of temporary physical custody of the minor
children at such times as agreed upon by the parties.
4. The Christmas holiday shall be handled such that Mother shall always have the
children from Christmas Eve from 3:00 p.m. until Christmas Day at 3:00 p.m. with
the Father having the children on Christmas Day at 3:00 p.m. until at least December
20 at 3:00 p.m.
5. This order is entered pursuant to an agreement reached by the parties at a Custody
Conciliation Conference. In the event either party desires to modify this order, that
party may petition the court to have the case again scheduled with the Custody
Conciliator for a Conciliation Conference.
BY THE COURT,
cc: Marcus A. McKnight, III, Esq.
Dale F. Shugart, Jr., Esq.
141 d S. -d r J.
In' ; n r. Ur: s.. ay hand
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This../Q ...day o`.......M.., 193.1.
,??,2 ......,..a°?p..._ __.
l/_, Prothonotary
LISA KAY MORRISON,
Plaintiff
v
RICHARD LEE MORRISON, JR.,
Defendant
Prior Judge:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 99-3548 CIVIL
: IN CUSTODY
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the following report:
The pertinent information pertaining to the children who are the subject of this litigation is
as follows:
Daniel Richard Morrison, born September 2, 1992; and Mekayla Elizabeth Morrison, born
October 27, 1994.
2. A Conciliation Conference was held on July 16, 1999, with the following individuals in
attendance:
The Mother, Lisa Kay Morrison, with her counsel, Marcus A. McKnight, III, Esquire; and
the Father, Richard Lee Morrison, Jr., with his counsel, Dale F. Shugart, Jr., Esquire.
The parties agree to the entry of an order in the form as attached.
DATE Hubert X. Gilroy, Es uhr-
Custody Conciliato
VERIFICATION
The foregoing Petition for Custody is based upon information which has been gathered
by counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unsworn falsification to authorities.
r
?v
AIAY MO ISON
Date: March 29 2000
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AUG 2 12001
LISA KAY MORRISON,
Plaintiff/Petitioner
V.
RICHARD LEE MORRISON, JR.,
Defendant/Respondent
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
99-3548 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
PRE-TRIAL MEMORANDUM
AND NOW comes the plaintiff, Lisa Kay Morrison, by and through her attorneys, Irwin,
McKnight & Hughes, Esquires, and files this Pre-Trial Memorandum as required by Rule
1920.33 of the PA Rules of Court, setting forth as follows:
1.
MARITAL ASSETS:
A. Real Estate:
1. 96 Bear's Road, Carlisle, Pennsylvania
(No mortgage) .................................$100,000.00
50% interest in the marital home
(also titled to Richard Morrison, Jr.
and Evelyn Morison)
B. Personal Property:
Vehicle of Husband
1996 Ford Pickup ................................$8,000.00
2. Wife's Automobile
1996 Volkswagon Jetta
3. Husband's Pension
Lear Corporation 401(k)
H.
EXPERT WITNESSES:
Real Estate Appraisal if necessary.
........$8,000.00
.......$15,000.00
2. Pension Appraisal if necessary.
III. WITNESSES:
Lisa Kay Morrison
IV. EXHIBITS:
A. Income and Expense Statement will be supplied.
(See attached)
B. Appraisals as necessary.
VI. PROPOSED RESOLUTION:
Wife desires a cash payment in return for conveying to her interest in the real
estate and pension of the Husband. Wife also desires alimony for three years
following the entry of the Divorce Decree. She also desires the children as
future income tax deductions.
Respectfully submitted,
IRWIN, McKNIGHT & HUGHES
By:
Marcus/A. Mc I, Esq.
60 West Pomfre eet
Carlisle, Pennsylvania 17013
(717) 249-2353
Supreme Court I.D. No. 25476
Attorney for Plaintiff
Date: August 21, 2001
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JUN 0 7 2000tp
LISA KAY MORRISON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
RICHARD LEE MORRISON, JR., NO. 99-3548 CIVIL
Defendant IN CUSTODY
COURT ORDER
AND NOW, this day of June, 2000, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
The parties shall submit themselves to a custody evaluation to be performed by
Guidance Associates. The evaluation shall be an independent evaluation and the
evaluation shall have the ability to share the results of the evaluation with legal
counsel for both parties. Costs of the evaluation shall be paid 75% by Father and
25% by Mother. Upon the conclusion of the evaluation and in the event the parties
are unable to reach an agreement on the entry of an order at that time, counsel for
either party may contact the Conciliator directly to have another Conciliation
Conference scheduled.
2. Pending further order of this Court, this Court's prior Order of July 19, 1999 shall
remain in effect subject to the modification that Father's periods of temporary
custody shall be on alternating weekends from Friday evening after work until
Monday morning. On those weekends when Father is working on Saturday, Father
shall take the children back to Mother on Friday evening and pick the children up
Saturday afternoon after his work. Father shall also enjoy liberal periods of
temporary custody as agreed to by the parties in addition to his alternating
weekends. Additionally, the paternal grandmother shall continue to be the primary
childcare provider for the minor children with the Father having the opportunity to
see the minor children at his mother's home.
BY T O
Edward E. Guido
cc: Marcus A. McKnight, III, Esquire
P. Richard Wagner, Esquire
J.
U
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CU;?1c_ :-) COUNly
%
iLVfu IA
PEN" L
ti
LISA KAY MORRISON,
Plaintiff
v
RICHARD LEE MORRISON, JR.,
Defendant
Prior Judge: Edward E. Guido
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-3548 CIVIL
IN CUSTODY
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the following report:
1. The pertinent information pertaining to the children who are the subject of this litigation is
as follows:
Daniel Richard Morrison, born September 2, 1992 and Mekayla Elizabeth Morrison, born
October 27, 1994.
2. A Conciliation Conference was held on June 2, 2000, with the following individuals in
attendance:
The Mother, Lisa Kay Morrison, with her counsel, Marcus A. McKnight, III, Esquire; and
the Father, Richard Lee Morrison, Jr., with his counsel, P. Richard Wagner, Esquire.
3. The parties agree to the entry of an order in the form as attached.
?,/IT(
DA Hubert X. Gilroy, quire
Custody Concili r
JUL 0 3 20, 01
LISA KAY MORRISON. IN 'rl IE COIJR'1' OI-'COMMON PLEAS OF
Plaintill' CIJMB1 RLAND C'OUN'rY, PENNSYLVANIA
CIVIL ACTION - LAW
RICIIARD LEE MORRISON. JR.. NO. 99-3548 CIVIL
Defendant IN CUSTODY
COURT ORDER
AND NOW, this ? day, of 2001, upon consideration of the attached
Custody Conciliation Report. it is ordered and directed that the prior custody orders entered in this
case shall remain in effect subject to the modifications as follows:
During the summer of' 2001, Father shall exercise temporary custody with the minor
children as follows:
A. July 2"d in the morning through July 8d' in the evening: July 12°i in the
morning through Jul), 13"' at 6:00 p.m.: July 19°i in the morning through July
22nd in the evening: July 26"' in the mominy, through July 271h at 6:00 p.m.:
August 2nd in the morning through August 611 at 6:00 p.m.: August 13d' in the
morning through August 151h at 6:00 p.m.: August 18"' in the evening
through August 22nd at 6:00 p.m. Father's delivery time of the children back
to the Mother in the evening shall be 8:00 p.m. and Father shall attempt to be
punctual in returning the children.
B. Assuming this summer schedule works out the summer of the year 2001, the
parties will communicate in advance of future summers and attempt to work
out a similar schedule. The parties may contact the Conciliator directly
through their attorneys if there are any issues that need to be worked out with
respect to fine-tuning the schedule above.
2. The parties shall give the other parent at least one month notice with respect to
exercising vacation time, with the understanding that each parent has at least a one
week vacation time with the children during the year.
cc: Marcus A. McKnight. Esquire
P. Richard Wagner
BY' I46ui QGdward
?L 6
C,
c..
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LISA KAY MORRISON.
Plaintiff
v
RICHARD LEE MORRISON. JR.,
Defendant
Prior Judge: Edward E. Guido
IN THE. COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO.99-3548 CIVIL
IN CUSTODY
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the following report:
The parties met for the third conciliation in three years and reached an agreement in the
nature of the Order that is attached.
DAT Hubert X. Gilro , Esquire
Custody Concfiator
A .
In the Court of Common Pleas of CUMBERLAND
DOMESTIC RELATION'S
P.O. BOX 720, CARLISLE, PA. 17013
Phone: (7t7) 240-622S
County, Pennsylvania
Fax: (717) 240.6248
Plaintiff Name: % ! V O R Cti
Defendant Name: 5T'eY 5
Docket Number: Ul-
PACSES Case Number:
Other State ID Number:
Rene Soto AD Correspondence mast Include the PACSFS Cave Number.
Income and Expense Statement
THIS FORM MUST BE FILLED OUT
(If you are self-employed or if you are salaried by a business of which you are owner in whole or pan, you must
also fill out the Supplemental Income Statement which appears on the last page of this income and expense
statement.)
INCOME STATEMENT OF LISA K. MORRISON
I verify that the statements made in this Income and Expense Statement are true and correct. I understand that
false Statements herein are Subject to the criminal penalties of 18 Pa. C.S. § 4904, relating to unswom
h1sifiation to authorities. A - _
Date CV9dff or Defetulant v
INCOME:
Employer D 6 L SYSTEMS
Address 55 N. WEST ST., PO BOX 95, NEWVILLE, PA 17241
Type of Work OFFICE CLERICAL
Payroll No. Gross Pay per Pay Period $ 320.00 Pay Period (wkly., bi-wkly., etc.) WEEKLY
Itemized Payroll Deductions:
Federal Withholding $ 31.00 Social Security $
19.84 Local Wage Tax
$1,20
State Income Tax $ 8.96 Retirement $ Savings Bonds $
Credit Union $ Life Insurance $ Health Insurance $
Otter Deductions (specify) MEDICARE $4.64 $
Net Pay per Pay Period $ 252.36
Service Type M Form IN-008
Worker lD 21205
Income and Expense Statement
OTHER
INCOME (Fill in Appropriate Column)
WEEK MONTH YEAR
Interest $ $ $
Dividends
Pension
Annuity
Social Security
Rents
Royalties
Expense Account
Gifts
Unemployment
Compensation
Wodmien's
Compensation
1RS Refund
Oder
Other
TOTAL $ $ $
TOTAL INCOME $
PACSES Case Number 3481006ae
(Fill in Appropriate Column)
EXPENSES
WEEK
MONTH
YEAR
Home RENT)
$300.00
$3,600.00
Mortgage/Rent $ $ $
Maintenance
Utilities (LAUNDROMAT) 40.00 480.00
Electric
50.00
600.00
Gas
Oil
Telephone 70.00
840.00
Service Type M
Page 2 of 6
Form IN-008
Worker ID 21205
Income and Expense Statement
PACSES Case Number 348100635
EXPENSES (Fill in Appropriate Column)
(continued) WEEK MONTH YEAR
Water $ $ 22.00 $ 64. 0
Sewer
Employment
Public Tram;ponadon $ $ $
Lunch
Taxes
Real Estate $ $ $
Personal Property
Income
PERSONAL-SCHOOL 275.00
Insurance
Homeowners $ $ $
Automobile 9R67 704
00
Life 13.66 .
163.92
Accident
Health
Other
Automobile
Payments $ $ 199.80 $ 2.397.60
Fuel
Repairs
Medical
Doctor $ $ $ 292.34
Dentist
Orthodontist
Page 3 of 6 Form IN-008
Service Type M Worker ID 21205
Income and Expemse Statement
PACSES Case Number 348100635
EXPENSES (Fill in Appropriate Column)
(continued) WEEK MONTH
YEAR
Hospital
Medicine
Special needs (Slams,
braces, orthopedic
devices)
110.00
Education
Private school $ 3 $
Parochial School
College
Religious
Personal
Clothing $ s S
Food
Barber/Hairdresser
266.83
Credit Payments:
Credit Card
Charge Account
171.00
2,052.00
Memberships
Loans
Credit union $ $ $
Miscellaneous
Household Help $. $ $
Child Care
Papers/Books/Magazine
Entertainment
Pay TV 34.57 414.84
Vacation
Page 4 of 6 Form IN-008
Service Type M Worker ID
21205
Income and Expense Statement
PACSES Case Number 348100635
EXPENSES (Fill in Appropriate Column)
(continued) WEEK MONTH YEAR
Gifts
Legal Fees
Charitable Contributions
Other Child Support
Alimony Payments
Other
s s a
TOTAL EXPENSES $ $ 959.70 6
OOW ED ership •
DESCRIPTION VALUE MH W J
Checking Accounts F&M TRUST 5100.
Savings Accounts
Credit Union
Stocks/Bonds
Real Estate
Other
TOTAL
a
INSURANCE COMPANY POLICY p Coverage'
H W C
Hospital
Blue Cross
Other
Medical
Blue Shield
Other
W - Wtte C - Combined J - Joint
Page 5 of 6 Form IN-008
Service Type M Worker ID 21205
Income and Expanse Statement
PACSES Case Number 348100638
Coverage
INSURANCE COMPANY POLICY N H W C
Health/Accident
Disability Income
Dental
Other
* LJ _ U...k.-A III 111:z_
--.- ,. - ?,uc . - t VIIIVIIIGV J - JumE
Supplemental Income Statement
a. This form is to be filled out by a person
1 who operates a business or practices a profession, or
2 who is a member of a partnership or joint venture, or
(3) who is a shareholder in and is salaried by a closed corporation or similar entity.
b. Attach to this statement a copy of the following documents relating to the partnership, joint
venture, business, profession, corporation or similar entity:
(1) the most recent Federal Income Tax Return, and
(2) the most recent Profit and Loss Statement
C. Name of business:
Address and telephone number:
d. Nature of business (check one)
- (1) partnership
- (2) joint venture
- (3) profession
- (4) closed corporation
(5) other
e. Name of accountant, controller or other person in charge of financial records:
f. Annual income from business:
(1) How often is income received?
(2) Gross income per pay period:
(3) Net income per pay period:
(4) Specified deductions, if any:
Page 6 of 6 Form IN-008
Service Type M Worker ID
21205
LAW OFncES
MANCY.E, WAGNER, HERSHEY & TULLY
JOHN B. MANCNE 2233 NOPT14 FRONT STREET
P. RICHARD WAGNER HARRISBURG, RA 17110
DAVID E. HERSHEY
WILLIAM T. TULLY
September 10, 2001
E. Robert Elicker, Esquire
9 North Hanover Street
Carlisle, PA 17013
Re: Morrison v. Morrison
No: 99-3548
Dear Mr. Elicker:
PHONE 17171 234.7001
FAX 17171 234.7080
Please accept this letter as a request for a continuance of the above-captioned
matter which is scheduled for a pre-hearing conference on October 26, 2001, at 9:30
a.m. as I am scheduled for a Master's hearing in Chambersburg on that date which
has already been postponed once.
Your attention is appreciated.
Sincerely
PRW/dks
cc: Marcus A. McKnight, III, Esq.
OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240-6535
E. Robert Elleker, 11
Divorce Master
Traci Jo Colyer
Office Manager/Reporter
July 19, 2001
West Shore
697-0371 Ext. 6535
Marcus A. McKnight, III, Esquire P. Richard Wagner, Esquire
IRWIN, McKNIGHT & HUGHES MANCKE, WAGNER, HERSHEY
60 West Pomfret Street & TULLY
Carlisle, PA 17013 2233 North Front Street
Harrisburg, PA 17110
RE: Lisa Kay Morrison vs. Richard Lee Morrison, Jr.
No. 99 - 3548 Civil
In Divorce
Dear Mr. McKnight and Mr. Wagner:
Both counsel have certified that discovery is complete. Therefore, I am going to
proceed on the basis that we will not deal with any discovery issues at the pre-hearing
conference and that the case will be able to proceed for trial without any delay because of
discovery matters.
The action was commenced by the filing of a divorce complaint on June 10, 1999,
raising grounds for divorce of irretrievable breakdown of the marriage. No economic
claims were raised in the complaint. I assume that the parties will either sign affidavits of
consent so that the divorce can be concluded under Section 3301(c) of the Domestic
Relations Code or have been separated for a period in excess of two years.
On March 30, 2000, a petition raising the economic claims of equitable
distribution, alimony, alimony pendente lite, and counsel fees and expenses was filed on
behalf of the Plaintiff, Lisa K. Morrison.
In accordance with P.R.C.P. 1920.33(b) I am directing each counsel to file a
pretrial statement on or before Monday, August 20, 2001. Upon receipt of the pretrial
Mr. McKnight and Mr. Wagner, Attorneys at Law
19 July 2001
Pave Two
statements, I will immediately schedule a pre-hearing conference with counsel to discuss
the issues and, if necessary, schedule a hearing.
Very truly yours,
E. Robert Elicker, II
Divorce Master
NOTE: Sanctions for failure to file the pretrial statements are set
forth in subdivision (c) and (d) of Rule 1920.33.
THE ORIGINAL PRETRIAL STATEMENT SHOULD BE FILED
IN THE MASTER'S OFFICE AND A COPY SENT DIRECTLY
TO OPPOSING COUNSEL.
FAILURE TO FILE PRETRIAL STATEMENTS AS DIRECTED
BY THE MASTER MAY RESULT IN THE MASTER'S
APPOINTMENT BEING VACATED.
LISA KAY MORRISON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 99 - 3548 CIVIL
RICHARD LEE MORRISON, JR.,:
Defendant IN DIVORCE
RESCHEDULED PRE-HEARING CONFERENCE
TO: Marcus A. McKnight, III , Counsel for Plaintiff
P. Richard Wagner , Counsel for Defendant
A pre-hearing conference has been scheduled at the
Office of the Divorce Master, 9 North Hanover Street,
Carlisle, Pennsylvania, on the 6th day of November, 2001, at
9:30 a.m., at which time we will review the pre-trial
statements previously filed by counsel, define issues,
identify witnesses, explore the possibility of settlement
and, if necessary, schedule a hearing.
Very truly yours,
Date of Notice: 9/13/01 E. Robert Elicker, II
Divorce Master