HomeMy WebLinkAbout99-03603
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THERESA L. PAXTON,
Plaintiff
VS.
CRAIG A. PAXTON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3603 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
ORDER OF COURT
AND NOW, this day of jj:? 199,
pon
review of the attached Motion filed by Robert L. O'Brien, Esquire, Attorney for the
Plaintiff in the above-captioned action the appointment of E. Robert Elicker, II as
Divorce Master is hereby VACATED.
BY THE COURT,
1-y-00
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THERESA L. PAXTON,
Plaintiff
VS.
CRAIG A. PAXTON,
Defendant
MOTION TO VACATE MASTER'S APPOINTMENT
1. Movant is Robert L. O'Brien, Esquire, attorney for the Plaintiff in the
above-captioned matter.
2. On or about August 4, 1999, the Honorable George E. Hoffer appointed
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E. Robert Elicker, II as Divorce Master.
3. Subsequent to Master's appointment, the parties negotiated a settlement.
WHEREFORE, Movant respectfully requests that the Master's appointment be
vacated.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3603 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
By
Robert L. O'Brien, Esquire
Attorney for Plaintiff
I. D. # 28351
17 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
THERESA L. PAXTON,
Plaintiff
VS.
CRAIG A. PAXTON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3603 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
ORDER 0 COURT
AND NOW, this day of upon -34 review of the attached Motion filed by Robert L. O'Brien, Esquire, Attorney for the
Plaintiff in the above-captioned action the appointment of E. Robert Elicker, II as
Divorce Master is hereby VACATED.
BY THE COURT,
THERESA L. PAXTON,
Plaintiff
VS.
CRAIG A. PAXTON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3603 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
MOTION TO VACATE MASTER'S APPOINTMENT
Movant is Robert L. O'Brien, Esquire, attorney for the Plaintiff in the
above-captioned matter.
2. On or about August 4, 1999, the Honorable George E. Hoffer appointed
E. Robert Elicker, II as Divorce Master.
3. Subsequent to Master's appointment, the parties negotiated a settlement.
WHEREFORE, Movant respectfully requests that the Master's appointment be
vacated.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
Robert L. O'Brien, Esquire
Attorney for Plaintiff
1. D. #28351
17 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
OFC ?,g 7999
01,
IN
:
THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
TF?RESA.L...PX%11W,
Plaintiff
Versus
CRAIG A.. PAXIM,
Defendant
N ()....99-36B3..CMLAMM W
DECREE IN
DIVORCE
AND NOW,... J.4 M! ?-?.-I ..Q........ W.200Qit is ordered and
decreed that ........ Tberesa.I,, .Paxton • .. • . • . • . • . • . • ... • ...... , plaintiff,
and ............... Craig. A.. Paxton........................... , 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;
Nor? .....................................................................
By The Court: oz
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Prothonotary ?
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THERESA L. PAXTON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
Vs. : CIVIL ACTION - LAW
CRAIG A. PAXTON, NO. 99-3603
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:
Code. Ground for divorce: irretrievable breakdown under Section 3301(C) of the Divorce
2. Date and manner of service of the Complaint: Defendant aknowledged receipt and
accepted service of the Complaint on June 16, 1999.
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 on December 10, 1999; and Defendant on November 23,
1999.
B. (1) date of execution of the Plaintiffs Affidavit required by Section 3301(d)
of the Divorce Code: N/A
(2) date of service of the Plaintiffs Affidavit upon the Defendant: N/A
4. Related claims pending: None.
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)(1)(i) of the Divorce
Code: None served as the parties signed the Waiver of Notice. (Defendant on November 23,
1999 and Plaintiff on December 10, 1999).
Respectfully submitted,
Robert L. O'Brien, Esquire
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THERESA L. PAXTON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Vs. CIVIL ACTION - LAW
NO. 99-360JCIVIL TERM
CRAIG A. PAXTON,
Defendant 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 may proceed without you and a decree of divorce or annulment
maybe entered against you by the court. A judgment may also be entered against you
for any other claim or relief requested in these papers by the Plaintiff. You may lose
money or property or other rights important to you, including custody or visitation of
your children.
When the ground for the divorce is indignities or irretrievable breakdown
of the marriage, you may request marriage counseling. A list of marriage counselors is
available in the Office of the Prothonotary at the Cumberland County Court House,
Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR
ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF
YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
Court Administrator
Cumberland County Court House
Fourth Floor
Carlisle, PA 17013
Telephone: (717) 240-6200
THERESA L. PAXTON,
Plaintiff
VS.
CRAIG A. PAXTON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99- 360 3 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT UNDER SECTIONS 3301(C)
AND 3301(D) OF THE DIVORCE CODE
1. Plaintiff is Theresa L. Paxton, an adult individual with a current mailing
address of P.0. Box 458, Boiling Springs, Cumberland County, Pennsylvania.
2. Defendant is Craig A. Paxton, an adult individual who currently
resides at 140 Old State Road, Gardners, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents in the
Commonwealth of Pennsylvania for at least six months immediately previous to the
filing of this Complaint.
4. The Plaintiff and Defendant were married on July 28, 1980 in
Cumberland County, Pennsylvania.
COUNT I - DIVORCE
Plaintiff hereby incorporates by reference averments 1 through 4 as if
each averment were set forth fully hereunder.
5. There have been no prior actions of divorce or for annulment between
the parties as to their current marriage.
6. Neither Plaintiff nor Defendant is in the Armed Forces of the United
States.
7. Plaintiff avers that the marriage between the parties is irretrievably
broken.
8. The Plaintiff has been advised of the availability of counseling and that
she may have the right to request that the court require the parties to participate in
counseling.
9. Plaintiff avers in the alternative that Defendant, in violation of his
marriage vows and of the Laws of the Commonwealth of Pennsylvania, has offered
such indignities to the person of the Plaintiff, the injured and innocent spouse, as to
render the condition of the Plaintiff intolerable and life burdensome.
10. This action is not collusive.
COUNT II - DIVISION OF PROPERTY
Plaintiff hereby incorporates by reference all of the averments contained
in Count I of this Complaint.
11. The parties have acquired real estate during the course of their
marriage located at:
140 Old State Road, Gardners, PA 17324
12. The parties have acquired home furnishings, motor vehicles, bank
accounts, and miscellaneous items of personal property.
13. The aforesaid items are marital property and the Plaintiff requests
that they be equitably divided.
COUNT III - PAYMENT OF FEES
14. Plaintiff requests alimony, alimony pendente lite, costs and counsel
fees.
WHEREFORE, Plaintiff prays that a decree be entered in favor of the
Plaintiff and against the Defendant as follows:
a) That a decree in divorce be entered;
b) That the herein described marital property owned by the Plaintiff and
Defendant be distributed according to law;
c) Such other additional relief as the Court deems necessary.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
Robert L. O'Brien, Esquire
Attorney for Plaintiff
17 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
I verify that the statements made in this Complaint 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.
THERESA L. PAXTON
Date: C- ?-x 19
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THERESA L. PAXTON,
Plaintiff
V.
CRAIG A. PAXTON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3603 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT, ACCEPTANCE OF
SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE
1. A complaint in divorce under Section 3301(C) of the Divorce Code was
filed on June 14, 1999.
2. Defendant acknowledged receipt and accepted service of the Complaint
on June 16, 1999.
3. The marriage of the Plaintiff and Defendant is irretrievably broken and
ninety days have elapsed from the date of the filing of the Complaint.
4. 1 consent to the entry of a final decree in divorce without notice.
5. 1 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.
6. 1 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.
7. 1 have been advised of the availability of marriage counseling and
understand that I may request that the court require counseling. I do not request that
the court require counseling.
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.
Section 4904 relating to unsworn falsification to authorities.
,
Date: 1_?,- lc,-Ii
)1? L?.x. • ??L?
THERESA L. PAXTON
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THERESA L. PAXTON,
Plaintiff
V.
CRAIG A. PAXTON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3603 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT, ACCEPTANCE OF
SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE
1. A complaint in divorce under Section 3301(C) of the Divorce Code was
filed on June 14, 1999.
2. Defendant acknowledged receipt and accepted service of the Complaint
on June 16, 1999.
3. The marriage of the Plaintiff and Defendant is irretrievably broken and
ninety days have elapsed from the date of the filing of the Complaint.
4. 1 consent to the entry of a final decree in divorce without notice.
5. 1 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.
6. 1 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.
7. 1 have been advised of the availability of marriage counseling and
understand that I may request that the court require counseling. I do not request that
the court require counseling.
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.
Section 4904 relating to unsworn falsification to authorities.
Date: 14 -2 3-q?
RAIG A. PAXTON
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THERESA L. PAXTON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99- 3603 CIVIL TERM
CRAIG A. PAXTON, CIVIL ACTION - LAW
Defendant IN DIVORCE
CERTIFICATE OF SERVICE
I, Robert L. O'Brien, Esquire, attorney for the Plaintiff in the above-captioned
divorce action, do hereby certify that I served a certified copy of the Complaint in
Divorce to the Defendant, as per the attached U.S. Postal Service Certified Mail, return
receipt card.
O'BRIEN, BARIC & SCHERER
BY:
Robert L. O'Brien, Esquire
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Office of Divorce Master
9 North Hanover Street
Carlisle, Pennsylvania 17013
ROBERT L. O'BRIEN, ESQURIE
O'BRIEN, BARIC & SCHERER
17 WEST SOUTH STREET
CARLISLE, PA 17013
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LV THE COURT OF COMlION PLEAS OF
CUMERLAND COUNTY, PMSYLVANIA
THERESA L. PAXTON,
Plaintiff
VS.
CRAIG A. PAXTON.
Defendant
No. 99-3603 19 99
, moves the court to appoint
a master with respect to the following claims:
( X) Divorce (X ) Distribution of Property
( ) Annulment ( ) Support
( ) Alimony (X ) Counsel Fees
( ) Alimony Pendente Lite (X ) Costs and Expenses
and in support of the motion states:
(1) Discovery is complete as to the claims(s) fcr which the
appointment of a master is requested.
(2) The defendant QM) (has not) appeared in the action (personally)
(by his attorney, Esquire).
(3) The staturory ground(s) for divorce XXXX (are) INDI •NTTTp.C
AND IRRETRIEVABiF BREAKDOWN
(4) Delete the inapplicable paragraph(s):
(b) Aix agreement has been reached with respect to the
following claims: NONE
(c) The action is contested with respect to the following
claims: ALL
(5) The action O MXOMMk (does not involve) complex issues of law
or fact.
(6) The hearing is e_--cpected to take A (hours) f(kWs) .
(7) Additional information, if any. relevant co the motion:
Date:
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THERESA L. PAXTON,
Plaintiff
VS.
CRAIG A. PAXTON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 3603
CIVIL ACTION - LAW
IN DIVORCE
ORDER AND NOTICE SETTING HEARING
TO: Theresa L. Paxton
Robert L. O'Brien
Plaintiff
Counsel for Plaintiff
Craig A. Paxton
Defendant
Counsel for Defendant
You are directed to appear for a hearing to take
testimony on the outstanding issues in the above captioned
divorce proceedings at the Office of the Divorce Master, 9 North
Hanover Street, Carlisle, Pennsylvania on the day
of at _ a.m., at which
place and time you will be given the opportunity to present
witnesses and exhibits in support of your case.
Date of Order and
Notice:
By t e C rt,
rgelE. Hoff r, President Judge
By:
Divorce Master
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
TELEPHONE (717) 249-3166
THERESA L. PAXTON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99- 3603 CIVIL TERM
CRAIG A. PAXTON, CIVIL ACTION - LAW
Defendant IN DIVORCE
CERTIFICATE OF SERVICE
I, Robert L. O'Brien, Esquire, attorney for the Plaintiff in the above-captioned
divorce action, do hereby certify that I served a certified copy of the Complaint in
Divorce to the Defendant, as per the attached U.S. Postal Service Certified Mail, return
receipt card.
O'BRIEN, BARIC & SCHERER
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THERESA L. PAXTON,
Plaintiff
VS.
CRAIG A. PAXTON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 - 3603 CIVIL 19
IN DIVORCE
STATUS SHEET
DATE:
8/5/99 ACTIVITIES:
PRETRIAL STATEMENTS DUE 9/10/99.
AUG. 23, 1999 INDIGNITIES HEARING SET FOR 1/25/00. at 2;oo a
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OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240-6535
E. Robert EUcker, 11
Divorce Master
West Shore
697.0371 Ext. 6535
Traci Jo Colyer
Office Manager/Reporter
August 5, 1999
Robert L. O'Brien, Esquire
OrBRIEN, BARIC & SCHERER
17 West South Street
Carlisle, PA 17013
Craig A. Paxton
140 Old State Road
Gardners, PA 17324
RE: Theresa L. Paxton v¦
No. 99 - 3603 Civil
In Divorce
Dear Mr. O'Brien and Mr. Paxton:
Craig A. Paxton
By order of Court of President Judge George E. Hoffer
dated July 30, 1999, the full-time Master has been appointed in
the above referenced divorce proceedings.
The only document in the file, other than the motion for
appointment of Master, is the divorce complaint. The complaint
was filed on June 14, 1999. I have no affidavit of service or
acceptance of service of the complaint in the file but I am
assuming that Mr. Paxton received a certified copy.
I am unable to determine whether or not there is any
agreement between the parties to consent to the divorce or that
the parties have been separated for a period in excess of two
years. If the parties will not consent and the period of
separation as not been the statutory two year period, please
advise and I will immediately schedule a hearing on the
alternative grounds of indignities.
I am going to proceed, however, on the assumption that
grounds for divorce are not an issue. The complaint did raise
the economic claim of equitable distribution. Consequently, I
am directing Mr. O'Brien as counsel for the Plaintiff, and Mr.
Paxton, who apparently is not represented, to each file a
pretrial statement in accordance with P.R.C.P. 1920.33(b) on or
Mr. O'Brien and Mr. Paxton
5 August 1999
Page 2
before Friday, September 10, 1999. Upon receipt of the pretrial
statements, I will immediately schedule a prehearing conference
with counsel for wife and Mr. Paxton, if he remains
unrepresented, 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': APPOINTMENT BEING
VACATED.
THERESA L. PAXTON,
Plaintiff
Vs.
CRAIG A. PAXTON,
Defendant
TO: Robert L. O'Brien
Craig A. Paxton
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 3603 CIVIL
IN DIVORCE
Attorney for Plaintiff
Defendant
DATE: Wednesday, December 29, 1999
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.
THERESA L. PAXTON,
Plaintiff IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 3603
Vs.
CIVIL ACTION - LAW
CRAIG A. PAXTON,
Defendant IN DIVORCE
ORDER AND NOTICE SETTING HEARING
TO: Theresa L. Paxton Plaintiff
Robert L. O'Brien Counsel for Plaintiff
Craig A. Paxton Defendant
----------- Counsel for Defendant
You are directed to appear for a hearing to take
testimony on the grounds for divorce of indignities to
the person at the Office of the Divorce Master, 9 North
Hanover Street, Carlisle, Pennsylvania on the 25th day
of January , 2000, at 9:00 a.m., at which
place and time you will be given the opportunity to present
witnesses and exhibits in support of your case.
By t e C rt,
rge E. Hoff r,
Date of Order and
Notice: 8/23/99
By:
President Judge
vorce Master
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
TELEPHONE (717) 249-3166
THERESA L. PAXTON,
Plaintiff
VS.
CRAIG A. PAXTON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3603 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
MOTION TO WITHDRAW ECONOMIC CLAIMS
1) Movant is Robert L. O'Brien, Esquire, attorney for Plaintiff in the above-
captioned matter.
2) Movant, on behalf of his client, Theresa L. Paxton, Plaintiff in the above-
captioned matter, filed a Motion for Appointment of Master on July 30, 1999, for the
division of property and the awarding of counsel fees, costs and expenses.
3) Movant hereby withdraws the request made in the aforementioned motion
for distribution of property, counsel fees, costs and expenses.
`n
Respectfully submitted,
O'BRIEN, BARIC & SCIORER;Z
By, Dc w
Robert L. O'Brien, Esquir F
I. D. # 28351
17 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
91
K
Law Offices
O'BRIEN, BARIC A SCHERER
17 West Sonde Street
Carlisle, Pennsylvania 17013
Robert L. O'Brien
David A. Baric
Michael A. Scherer
August 17, 1999
E. Robert Elicker
Divorce Master
9 North Hanover Street
Carlisle, Pennsylvania 17013
Re: Paxton vs. Paxton
Dear Mr. Elicker:
(717) 249-6873
Fax (717) 249-5755
E-mail: obs@obslaw.com
Mr. Paxton will not indicate whether or not he will consent to the entry of a
divorce decree. Therefore, my client wishes you to schedule a hearing for the
indignities claim. In addition, pursuant to the enclosed motion, my client is withdrawing
her request for a hearing on any other matter other than the fault divorce.
very truly yours,
O'BRIEN, BARIC & SCHERER
t
Robert L. O'Brien, Esquire
RLO/af
Enc.
cc: Theresa L. Paxton
Craig A. Paxton
file
reMetlerelelicker.kr
THERESA L. PAXTON,
Plaintiff
VS.
CRAIG A. PAXTON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3603 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
MOTION TO WITHDRAW ECONOMIC CLAIMS
1) Movant is Robert L. O'Brien, Esquire, attorney for Plaintiff in the above-
captioned matter.
2) Movant, on behalf of his client, Theresa L. Paxton, Plaintiff in the above-
captioned matter, filed a Motion for Appointment of Master on July 30, 1999, for the
division of property and the awarding of counsel fees, costs and expenses.
3) Movant hereby withdraws the request made in the aforementioned motion
for distribution of property, counsel fees, costs and expenses.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
Robert L. O'Brien, Esquire
I. D. # 28351
17 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
THERESA L. PAXTON,
Plaintiff
VS.
CRAIG A. PAXTON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3603 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
MOTION TO WITHDRAW ECONOMIC CLAIMS
1) Movant is Robert L. O'Brien, Esquire, attorney for Plaintiff in the above-
captioned matter.
2) Movant, on behalf of his client, Theresa L. Paxton, Plaintiff in the above-
captioned matter, filed a Motion for Appointment of Master on July 30, 1999, for the
division of property and the awarding of counsel fees, costs and expenses.
3) Movant hereby withdraws the request made in the aforementioned motion
for distribution of property, counsel fees, costs and expenses.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
Robert L. O'Brien, Esquire
I. D. # 28351
17 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
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