HomeMy WebLinkAbout99-04094h
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF r PENNA.
ROSEMARIE L. ARMSTEAD,
Plaintiff
VERSUS
Defendant
N O. 99-4094 Civil Term
DECREE IN
DIVORCE a?`?o 17Q
AND NOW, ' , IT IS ORDERED AND
DECREED THAT ROSEMARTF, 1- ARM T AD , PLAINTIFF,
AND FREDDIE ARMSTEAD SR. ,DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
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ROSEMARIE ARMSTEAD, :IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
V. :CIVIL ACTION -LAW
FREDDIE ARMSTEAD, SR. :NO. 99-4094 CIVIL TERM
Defendant :IN DIVORCE
QUALIFIED DOMESTIC RELATIONS ORDER
WHEREAS, Rosemarie L. Armstead, hereinafter referred to as Former Spouse, and
Freddie Armstead, hereinafter referred to as Retiree, have entered into a comprehensive
property settlement agreement dated May 30, 2001; and
WHEREAS, as part of the settlement agreement Retiree agrees that the Former
Spouse receive fifty (50%) percent of his U.S. Army Pension that was earned from the date
of marriage (March 14, 1983) until the mutually agreed date of termination of entitlement
(March 14, 1998); and
WHEREAS, counsel for Retiree and counsel for Former Spouse have
acknowledged that this Qualified Domestic Relations Order is being made pursuant to the
Domestic Relations Laws of the Commonwealth of Pennsylvania as it relates to the
provisions being made by the Former Spouse relating to her marital property rights; and
WHEREAS, it is intended that this Order will qualify as a Qualified Domestic
Relations Order, as defined in Section 414(p)(1) of the Internal Revenue Code of 1986 and
the provisions hereof shall be administered and interpreted in conformity with the Code.
Pursuant to Section 414(p)(2) of the Code, the following facts are hereby specified:
1. The Act to which this Order applies is the Uniform Services Former Spouse
Protection Act of September 8, 1982.
2. The name of the Service member is Freddie Armstead, whose current
mailing address is 12822 Isle Royale Drive, DeWitt, Michigan 48820, and whose social
security number is 337-54-8714.
3. The name and address of the alternate payee is Rosemarie L. Armstead
vhose current mailing address is 195 Fries Mill Road, Building Carlton #15, Turnersville,
Jew Jersey and whose social security number is 179-64-0329.
4. Military Retired/Retainer Pay. Former Spouse shall be awarded a monthly
percentage share of her Retiree's U.S. Army Retired/Retainer pay upon Retiree's
retirement from the United States Army. Set award shall be in accordance with and
construed by the Uniform Services Former Spouse Protection Act of September 8, 1982
(Public Law 97-252). Former Spouse's monthly percentage share shall be determined by
the following formula:
15 (Years of marriage to mutually
agreed date of termination of entitlement
while Retiree on active duty)
1/2 X = 37.5% (Former Spouse's
20 (No. of years of Monthly Percentage Share)
Retiree's active duty at
time of Retirement)
Disposable Military Retired/Retainer pay as used herein means Retiree's gross
Military Retired/Retainer pay less only those amounts deducted for the Survivor Benefit
Plan premium, if any for Former Spouse. The sharing of Disposable Military
Retired/Retainer pay shall commence upon July 1,2001 and shall continue until the death
of either party. Pending the implementation of this Order by the Naval Finance Service,
the Retiree shall pay the Former Spouse's entitlement directly.
Retiree shall elect the maximum Survivor's Benefit Plan annuity.
Under the terms of the Uniform Services Former Spouse Protection Act, the
Defense Finance and Accounting Service, as the paying authority is required to directly pay
Former Spouse her monthly percentage share of Retiree's monthly disposable Military
Retired/Retainer pay because of the following. In the course of the parties' marriage,
Retiree formed at least ten years of service credible and determining his eligibility for
Retired/Retainer pay. The parties were married on March 14, 1993 and were divorced on
. Retiree began service credible and detei;nined his eligibility
for Retired/Retainer pay with the United States Army in February 28, 1980, has performed
active duty of 20 years service until his retirement from active duty on February 29, 2000
Neither Retiree nor Former Spouse will do or cause to be done any act which will
cause this provision to become null and void, and each party agrees that this will be the
final Order pertaining to the division of the Retiree's disposable Military Retired/Retainer
pay.
Retiree and Former Spouse agree that the Retiree's Military Retired/Retainer pay
is and shall be accruing as a result of his service in the United States Army and that the
Military Retired/Retainer pay is marital property subject to equitable distribution by the
Court of Common Pleas of Cumberland County, Commonwealth of Pennsylvania. Retiree
and Former Spouse further agree that the Court of Common Pleas of Cumberland County,
Commonwealth of Pennsylvania, is competent to divide the parties' marital property
incident to their divorce pursuant to Section 201(c), of the Divorce Code. Retiree and
Former Spouse finally agree that the Court of Common Pleas of Cumberland County,
Commonwealth of Pennsylvania has jurisdiction over the Retiree for the purpose of dividing
his disposable Military Retired/Retainer pay because Retiree specifically consents to the
Court's jurisdiction to divide his disposable Military Retired/Retainer pay.
Retiree acknowledges and agrees that he has been afforded his rights under the
Soldiers and Sailors Civil Relief Act of 1940 (50 U.S.S. Appendix 501-591).
The Court shall retain jurisdiction over Retiree's Military Retired/Retainer pay for as
long as the parties both shall live. The Court shall also have the authority to make every
just and equitable Order not inconsistent with the other provisions hereof. The Court shall
also have the specific authority to make any Orders it deems just and equitable as a result
of the income tax consequences which flow from the division and distribution of the
Retired/Retainer pay.
The Court shall also have continuing jurisdiction to make every Order reasonably
necessary to implement and accomplish the direct payment to the Former Spouse by the
United States Army of her percentage share of Retiree's disposable Military
Retired/Retainer pay, including the right to advise the United States Army of the precise
amount or percentage of Retiree's disposable Military Retired/Retainer pay to be payable
to the Former Spouse.
BY THE COURT:
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ROSEMARIE L. ARMSTEAD, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99 - 4094 CIVIL
FREDDIE ARMSTEAD, SR.,
Defendant IN DIVORCE
ORDER OF COURT
AND NOW, this lla'?_ day of
2001, the parties and counsel having entered into an
agreement and stipulation resolving the economic issues on
May 30, 2001, the date set for a four-party conference, the
agreement and stipulation having been transcribed, and
subsequently signed by the parties and counsel, the
appointment of the Master is vacated, and counsel can
conclude the proceedings by the filing of a praecipe to
transmit the record with the affidavits of consent of the
parties so that a final decree in divorce can be entered.
BY THE COURT,
CC: James J. Kayer
Attorney for Plaintiff
Robert J. Mulderig
Attorney for Defendant
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FENNSYLVANA
Y
ROSEMARIE L. ARMSTEAD
Plaintiff
Vs.
FREDDIE ARMSTEAD, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 4094 CIVIL
IN DIVORCE
THE MASTER: Today is Wednesday, May 30,
2001. This is the date set for a conference with counsel and
the parties with the intention to trying to resolve the
outstanding economic issues. Present in the hearing room
are the Plaintiff, Rosemarie L. Armstead, and her counsel
James J. Kayer, and the Defendant, Freddie Armstead, Sr., and
his counsel Robert J. Mulderig.
This action was commenced by the filing of a
divorce complaint on July 2, 1999, raising grounds for divorce
of irretrievable breakdown of the marriage. No economic
claims were raised in the complaint.
On November 29, 2000, a petition was filed by
the Plaintiff raising related economic claims of equitable
distribution, alimony, and counsel fees and costs.
With respect to grounds for divorce of
irretrievable breakdown of the marriage, the master has been
provided by counsel today affidavits of consent and waivers of
notice of intention to request entry of divorce decree signed
by the parties. The affidavits and waivers will be filed
with the Prothonotary by the Master's office so that the
divorce can conclude under Section 3301(c) of the Domestic
Relations Code.
The parties were married on March 14, 1983,
and separated August 1998. They are the natural parents of
three children. The oldest child has graduated this May from
high school; the other two children are still in school and
are 14 and 12 years of age. The child that graduated is 17
years of age. The children at this time are in the custody
of the husband although there has been some discussion today
about the possibility that the children may be moving with the
mother. However, this Court will take no notice of the
custody issues involved with respect to the children between
the parties. Those matters will have to be resolved if there
are issues either in Michigan or New Jersey.
The Master has been advised that the parties
have reached an agreement with respect to the outstanding
economic claims raised in the proceedings. After extensive
negotiations the agreement has been reached and is going to be
placed on the record by counsel in the presence of the
parties. The agreement as 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. Later this morning counsel and the parties
are going to return to the Master's office to review the draft
of the agreement for typographical errors, make any
corrections as required, then affix their signatures affirming
the terms of settlement as stated on the record. In any
event, when the parties leave the hearing room today, they
will be bound by the terms of the agreement as stated on the
record even though there is no subsequent affirmation of the
agreement containing the signatures of the parties.
After the Master has been provided a
completed copy of the agreement, he will prepare an order
vacating his appointment. Counsel will then be in a position
to file a praecipe transmitting the record to the Court
requesting a final decree in divorce. Mr. Kayer.
MR. KAYER:
1. The parties agree that the issues of alimony and
counsel fees will be waived by both parties, that neither will
make any claim with regard to alimony or counsel fees and
costs.
2. With regard to the equitable distribution of property,
the parties agree that the MasterCard debt that is titled to
the wife shall be the sole responsibility of the wife to pay.
The other liabilities that include a Visa account
titled to the husband, the IRS debt which is titled joint, the
lien on the 1996 GMAC conversion van shall all be the sole
responsibility of the husband.
Each party agrees to indemnify and hold harmless the
other party with regard to these liabilities.
3. Regarding the distribution of the assets, husband shall
maintain possession and sole title to the 1996 GMAC conversion
van. The wife shall maintain sole title and possession of the;;;;}
1997 Honda Accord and her thrift savings plan that she has
acquired through her employment with the federal government.
4. With regard to the husband's military pension, the
parties agree that this shall be distributed through a
Domestic Relations Order that shall be prepared by husband's
counsel to allow for the deduction of 37.5% of the monthly
pension fund to be distributed directly to the wife. The SBP
election shall remain in full effect as it has currently been
elected. The parties reached the figure of 37.5% by
calculating that the marital portion of the pension was 75%
and that the wife was entitled to one-half of that marital
portion.
5. The parties also agree that the husband shall pay to
wife a lump sum of $12,500.00 within thirty (30) days of the
date of the divorce decree.
6. The parties further agree that the wife shall be able
to collect the pots and pans that are in the husband's
possession in his residence in Michigan and she shall be
solely responsible for picking these pots and pans up at her
convenience.
7. Except as herein otherwise provided, each party may
dispose of his or her property in any way and each party
hereby waives and relinquishes any and all rights he or she
may now have or hereafter acquire under the present or future
laws of any jurisdiction to share in the property or the
estate of the other as a result of the marital relationship
including without limitation, statutory allowance, widow's
allowance, right of intestacy, right to take against the will
of the other, and right to act as administrator or executor in
the other's estate. Each will at the request of the other
execute, acknowledge, and deliver any and all instruments
which may be necessary or advisable to carry into effect this
mutual waiver and relinquishment of all such interest, rights,
and claims.
MR. KAYER: Rose, have you heard my
description of the agreement that you have reached today with
Freddie?
MS. ARMSTEAD: Yes.
MR. KAYER: Do you understand that agreement?
MS. ARMSTEAD: Yes.
MR. KAYER: And is this agreement acceptable
to you?
MS. ARMSTEAD: Yes.
MR. MULDERIG: Fred, did you hear the
agreement as read by Mr. Kayer?
MR. ARMSTEAD: Yes, I did.
MR. MULDERIG: Did you understand the
agreement?
MR. ARMSTEAD: Yes, I did.
MR. MULDERIG: Are you in agreement with
that?
MR. ARMSTEAD: Yes, I am
MR. MULDERIG: And that is your full and free
choice?
MR. ARMSTEAD: Yes, it is.
THE MASTER: And you both understand that
when you leave the hearing room today, even if you do not
subsequently sign the agreement, you are bound by the terms of
the agreement as stated on the record?
MS. ARMSTEAD: Yes.
MR. ARMSTEAD: Yes.
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:
J es Kay Rosemarie L. Armstead
A for y fo Plaintiff
Robert J. ulderig
Freddie Armstead Sr.
Attorney for r Defendant '
ROSEMARIE L. ARMSTEAD,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS. : CIVIL ACTION - LAW
: NO. 99 - 4094 CIVIL TERM
FREDDIE ARMSTEAD, SR.,
Defendant : IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Please transmit the record, together with the following information to the court for entry of a
divorce decree:
1. Ground for divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code.
2. Date and manner of service of the complaint: Certified Mail, Restricted Delivery,
July 12, 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 the Plaintiff 5/30/01; By the Defendant 5130101.
B. (1) Date of execution of the Plaintiffs affidavit required by Section 3301 (d) of the
Divorce Code: none.
(2) Date of service of the Plaintiffs affidavit upon the Defendant: none
3. Related claims pending: None
4. 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: none
B. Date Plaintiffs Waiver of Notice in 3301(c) Divorce was filed with the
Prothonotary: 5130101; Date Defendant's Waiver of Notice in 3301(c) Divorce was filed with the
Prothonotary 5/30/01. /
for
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ROSEMARIE L. ARMSTEAD,
Plaintiff
VS.
FREDDIE ARMSTEAD, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 -//,,,g CIVIL TERM
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 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may
request marriage counselling. A list of marriage counselors is available in the Prothonotary's Office at the
Cumberland County Courthouse, Carlisle, Pennsylvania.
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
Telephone (717) 249-3166
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.
James J. Kayer, Esquire
Attorney for Plaintiff
Liberty Loft
4 East Liberty Avenue
Carlisle, PA 17013
(717) 243-7922
ROSEMARIE L. ARMSTEAD,
Plaintiff
VS.
FREDDIE ARMSTEAD, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 -foq?CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE
COMES NOW, Plaintiff ROSEMARIE L. ARMSTEAD, through her attorney, James J. Kayer,
Esquire and avers as follows:
COUNT I - DIVORCE
1. Plaintiff is ROSEMARIE L. ARMSTEAD, an adult individual who resides at 539
Cascade Court, Sewell, New Jersey, 08080
2. Defendant is FREDDIE ARMSTEAD, SR., an adult individual whose address is P O Box
243, New Cumberland, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six
months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on March 14, 1983 in Manila Philippines.
5. A divorce complaint filed in Dauphin County by the husband has been withdrawn and
discontinued by the husband effective March 1999.
6. Defendant is an active member of the United States Armed Forces.
7. The marriage is irretrievably broken, and the parties are proceeding under Section 3301(c) of
the Divorce Code.
8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to
request that the court require the parties to participate in counseling.
x
WHEREFORE, Plaintiff requests the court to enter a decree of divorce.
Respectfully submitted,
jLibeAve er, + qu'
e
1 13
(717) 243-7922
VERIFICATION OF PLEADINGS
The foregoing document is based upon infnrmation which has heen gathered by my
counsel and myself in the preparation of this action. The language of the document may, in part,
be the language of my counsel and not my own. I have read the statements made in this
document and to the extent that it is based upon information which I have given to my counsel,
it is true and correct to the best of my knowledge, information and belief. To the extent that the
contents of the statements are that of counsel, I have relied upon counscd in inakiue this
Verification. 1 understand that false statements herein are made subject to the penalties of 18 PA.
C.S. § 4904, relating to unsworn falsification to authorities.
Date: & - / `/ - 9 9 , 1999 7ZZ" ? / Q , ?r .,c.
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ROSEMARIE L. ARMSTEAD,
Plaintiff
VS.
FREDDIE ARMSTEAD, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 - 4094 CIVIL TERM
IN DIVORCE
PETITION FOR RELATED CLAIMS UNDER DIVORCE CODE
COMES NOW, Plaintiff Rosemarie L. Armstead, through her attorney, James J. Kayer, Esquire
and avers as follows:
COUNT 1- EQUITABLE DISTRIBUTION
1. Petitioner is the Plaintiff above named, who currently resides at195 Fries Mill Road, Building
Carleton 415, Turnersville, New Jersey.
2. Respondent is the Defendant above named, who currently resides at 12822 Isle Royale Drive,
Dewitt, Ml.
3. Petitioner and Respondent were married on March 14, 1983 in Manila, Philippines.
4. Petitioner has heretofore filed a complaint for divorce as of the above caption.
5. Petitioner and respondent have legally and beneficially acquired property, both real and personal
during their marriage from March 14, 1983 until August 15, 1998, the date of their separation, which
property is "marital property."
6. Petitioner and respondent may have owned, prior to the marriage, property, both real and
personal, which property has increased in value during the manage and/or which has been exchanged for
other property, which has increased in value during the marriage, all of which property is "marital property."
7. Petitioner and respondent have been unable to agree as to an equitable division of said property
to the date of the tiling of this petition and substantial portions of said property are in the exclusive control
of respondent.
WHEREFORE, the Petitioner requests the Court to equitably divide all marital property and to
enjoin petitioner and respondent from the removal, disposition, alienation, or encumbering of all real and
personal property of the parties.
COUNT' Il - COUNSEL FEES AND COSTS
in full. Paragraphs I through 8 of this petition are incorporated herein by reference as though set forth
9. Petitioner has employed James J. Kayer, Esquire as counsel, but is unable to pay the necessary
and reasonable attorney's fees for said counsel
10. Petitioner has entered into a fee agreement with her attorney, a true and correct copy of which
is attached hereto, made a part hereof and marked Exhibit ["A"].
12. Petitioner is required to employ various experts: an accountant, appraiser(s) and actuary, to
review various records of respondent and appraise various properties, requests reasonable expenses to retain
such experts.
WHEREFORE, the Petitioner requests your Honorable Court to enter an award of temporary counsel
fees, costs and expenses.
COUNT III - ALIMONY
13. Paragraphs 9 through 13 of this petition are incorporated herein by reference as though set
forth in full.
14. Petitioner lacks sufficient property to provide for her reasonable means and is unable to
support herself through appropriate employment.
15. Petitioner requires reasonable support to adequately maintain herself in accordance with the
standard of living established during the marriage.
assets.
16. Respondent's income is higher than Petitioner's income and respondent owns significant
WHEREFORE, the Petitioner requests the Court to enter an award of reasonable temporary
alimony and additional sutras as they may become necessary from time to time hereafter until final
hearing and permanently thereafter.
Respectfully submitted,
Date: ( ? ( I 1 /0 Q
Janis J. KOer, %
4 Liberty enue
Carlisle, P 17013
(717) 243-7922
I verify that the statements made in this complaint are true and correct. 1 understand that false
statements herein are made subject to the penalties of 13 Pa. C.S. § 4904, relating to unswom
falsification to authorities.
/V /71019
James J. yer,
4 Liberty venue
Carlisle,'P 170
(717) 243-p922
CERTIFICATE OF SERVICE
I hereby certify that a true copy of the foregoing PETITION FOR RELATED CLAIMS
UNDER DIVORCE CODE was served on the following persons by First-class mail, postage prepaid,
by forwarding a true and correct copy unto:
Robert J. Mulderig, Esq.
28 South Pit Street
Carlisle PA 17013
Date ]1/17/06
James Jl Kayer,
4 East Liberty E
Liberty I-oft
Carlisle) PA 171
(717) 243-7922
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ROSEMARIE L. ARMSTEAD, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
Vs. NO. 99 - 4094 CIVIL
FREDDIE ARMSTEAD, SR.,
Defendant IN DIVORCE
RE: Pre-Hearing Conference Memorandum
DATE: Monday, April 9, 2001.
Present in the hearing room is the
Plaintiff's counsel James J. Kayer, and the Defendant and his
counsel Robert J. Mulderig. Mrs. Armstead has not appeared,
but for the record, it is noted, she was not required to be
present today.
The Master has raised an issue with respect
to this county's venue. Mr. Armstead indicated that at the
time the complaint was filed and service was made, he was a
member of the United States Army at the base in New Cumberland
which would be Fairview Township, York County, Pennsylvania.
He also indicated that he was living in Harrisburg,
Pennsylvania, which is in Dauphin County. Consequently, the
Master does not find that there is any connection of either of
the parties in Cumberland County. Wife, when she filed the
complaint, was living in New Jersey.
With that having been said, however, the
Master has indicated to counsel that he is willing to try to
resolve the issues between these parties by scheduling a
settlement conference before returning the file to the Court
and indicating that Cumberland County is not the correct
venue.
If the case cannot be resolved in this office
through settlement negotiations, then the Master has indicated
to counsel today that the case in Cumberland County should be
discontinued and an action should either be brought in New
Jersey where wife is residing or in Michigan where husband is
residing.
The parties where married on March 14, 1983,
and separated in August 1998. There are three children of
this marriage and at present the children are residing with
husband in Michigan. Mr. Armstead indicated that the oldest
child will be graduating from high school in a few months; the
other children are 14 and 12.
Wife is currently residing at 195 Fries Mill
Road, Building Carleton #15, Turnersville, New Jersey 08012.
Husband is residing at 12822 Isle Royale Drive, Dewitt,
Michigan 48820.
The Master has pretrial statements filed by
counsel, but after some off the record discussions there
appears to be some information which needs to be gathered in
order to discuss settlement. It is noted that the economic
claims have been raised by petition filed by wife on November
29, 2000, those claims being equitable distribution, alimony,
and counsel fees and costs.
The Master is going to ask each counsel to go
on the record and indicate what information needs to be
provided so that we can have all of the facts available at a
settlement conference which the Master will set.
Mr. Kayer, if you would speak on behalf of
your client and then Mr. Mulderig.
MR. KAYER: The documentation or information
we still seek are closing statements or 1099s from the Janus
Mercury Fund and American Century to confirm the balances that
were withdrawn from those accounts. A settlement sheet from
the purchase of Mr. Armstead's home in Michigan. His most
recent leave and earning statement that confirms the current
pension benefit as well as the SBP premium, and a completed
income and expense statement that would include the most
recent pay stubs from his current employer.
THE MASTER: Mr. Mulderig.
MR. MULDERIG: We request the blue book
values on the two automobiles. We will get the one on the
conversion van in his possession. Copies of the marital debt
that the wife claims was had. I will have him furnish copies
of the marital debt which he has referenced, that includes the
liens on the respective vehicles. I am told that the wife has
been a federal employee since 1993 and it is believed that she
has either a pension plan or a thrift savings plan. We would
like to have statements about that plan, and we would like to
have copies of her income tax for the year 2000 and we will
provide that also.
THE MASTER: A conference with counsel and
the parties is scheduled for Wednesday, May 30, 2001, at 9:00
a.m. Notices will be sent to counsel and the parties.
CC: James J. Kayer
Attorney for Plaintiff
Robert J. Mulderig
Attorney for Defendant
?,??n ?/-
ROSEMARIE L. ARMSTEAD
Plaintiff
V.
FREDDIE ARMSTEAD, SR.
Defendant
AN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:CIVIL ACTION - LAW
:NO. 99 - 4094
:IN DIVORCE
PRE-TRIAL STATEMENT OF DEFENDANT PURSUANT TO
RULE 1920.33(B)
1. Personal Data:
A. Date of Marriage: March 14, 1983
B. Date of Separation: August 1998
C. CHILDREN:
I. Karisha Armstead DOB December 5, 1983
ii. Freddie Armstead, Jr. DOB September 14, 1986
iii. Joshua Jordan Armstead DOB November 3, 1988
2. List of Marital Assets:
A. Janus Mercury Fund 849.056 shares @ $22.74 per share
$19417.91
B. Military Pension $1,500.00 per month
C. Security Service Federal Credit Union $34.83
D. American Century $20,646.52
E. Members First $580.00
F. Wife's Pension - Unknown
3.
4.
to testify.
5.
6.
8.
9.
G. 1996 GMC Van $25,000.00
Experts Testifying: No experts will be called to testify.
All Other Testimony by Witnesses:
No other witnesses will be called
Exhibits: None known at this time.
Gross Income of the Parties:
Husband's gross income: $50,000.00
Wifes gross income: Unknown
Any Disputed Items: Unknown
Marital Debts:
A. Husband's credit cards $10,000.00
B. Wife's credit cards $9,000.00
C. Lien on GMC Van $18,500.00
10. Proposed Resolution: Defendant has custody of the three (3) minor
children, he is not receiving and has not received any child support for these children.
Therefore, he should be rewarded 60% of the assets.
Date
Respectfully Submitted
TURO LAW OFFICES
46/,Robert : Mulderig, Esquire
28 South Pitt Street
Carlisle, PA 17013
(717) 245-9688
Attorney for Defendant
ROSEMARIE L. ARMSTEAD, : IN THE COURT OF COMMON PLEAS OF rn
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS.
FREDDIE ARMSTEAD, SR.,
Defendant
: CIVIL ACTION - LAW
:NO. 99 - 4094 CIVIL TERM
IN DIVORCE
PRETRIAL STATEMENT BEFORE THE DIVORCE MASTER
PURSUANT TO Pa. RULE OF CIVIL PROCEDURE 1920.33
BACKGROUND
The Plaintiff, Rosemarie L. Armstead, filed a motion for appointment of the Divorce Master to address
issues that were initially raised by her including equitable distribution of the property, alimony and counsel fees. The parties
were married on March 14, 1983 in Manila, Philippines. They have three children who live with the defendant, Karisha
Armstead, born December 5, 1983, Freddie Armstead, Jr., born September 14, 1986 and Joshua Jordan Armstead, born
November 3, 1988. The parties separated in August 1998. At that time, the Defendant was just finishing his tour of duty in
the United States Army. The parties resided in Carlisle, Pennsylvania and owned real estate in Sacramento, California. At
that time it was agreed between the parties that the Plaintiff would relocate with the children to New Jersey so that she could
move closer to ajob opportunity and that the Defendant would join her upon his retirement from the military which was
scheduled for November 1999. However, the Defendant upon completing his military service relocated to Dewitt, Michigan.
The Plaintiff, since the parties' separation has continued to reside in new Jersey. The Plaintiff is 40 years old, and is
employed as a Window/Distribution Clerk for the United States Postal Service. She has received a bachelor's degree in
education. The Defendant is 40 years old and earned a Master's degree while serving in the Army. He commenced his
service with the Army on February 28, 1978 and retired at an unknown date in November 1999. He was an E-8 when he
retired. Plaintiff is unaware of the Defendant's current employment and earnings.
II. LIST OF MARITAL ASSETS - REAL ESTATE
The Parties purchased a home at 5851 Rightwood Way, Sacramento, California during the marriage. This house was
foreclosed upon by the lender and ultimately sold in a short sale on or about June 22, 1998. As the Defendant was solely
responsible for the couple's finances, the Plaintiff was unaware of the fact that the house was in jeopardy due to non-payment or
was actually was foreclosed upon until well after the foreclosure occurred. The Plaintiff currently lives in a rented apartment.
The Defendant has purchased a home in Michigan and utilized the parties' joint funds that had been invested in a number of
different accounts for the down payment on that home.
Ill. INTANGIBLE PERSONAL PROPERTY
The parties possessed significant sums in savings and a number of investment accounts at the
time of the parties separation. These accounts included an IRA with American Century Services, an IRA with
Janus Mercury Fund as well as accounts with Members First Credit Union, Security Service Federal Credit Union
and PNC Bank. To the best of the Plaintiffs knowledge the total funds in these accounts were at least $32,000.00.
Since his retirement from the military the Defendant has received monthly pension benefits in the amount of at
least $1400.00 per month and will continue to receive this benefit for the remainder of his life. As the Defendant's
military service commenced in 1978 and the parties were married in 1983, the vast majority of this pension was
earned while the parties were married and that that portion is therefore marital property.
IV. TANGIBLE PERSONAL PROPERTY
A. 1997 GMC Conversion Van -This vehicle, currently in the husband's possession was purchased new
at a cost of approximately $40,000.00. It is unknown what the present value of this vehicle is currently as
the Plaintiff is unaware of the mileage or condition of the vehicle.
B. 1997 Honda Accord - The wife has maintained possession of this vehicle, which was purchased for
approximately $20,000.00 new. The Plaintiff has not done a valuation of the vehicle at the time of the parties'
separation.
C. Household possessions -The husband has maintained possession of the majority of the household
possessions between the parties. It is unknown at this time whether the husband is asserting any claims as to the value
of those possessions that the wife took with her. In the event that such a claim is pursued, it will be necessary to
independently establish the value of all items possessed by each party.
V. MARITAL DEBTS
The Plaintiff is aware of the existence of an unidentified Bank card account in the husband's name at the
time of the separation. She is unaware of any balance that was owed on that card. The Plaintiff possessed a Master Card of
her own that had a balance of approximately $9,000.00 at the time of separation. Additionally, the parties also were paying
on their respective vehicle loans at the time of separation and have continued to do so since that date.
VI. EXPERT WITNESSES
It is not anticipated that the Plaintiffwill call any expert witnesses. it will not be necessary to establish a
present value of the military pension as it is currently in pay status and can be readily divided based upon the appropriate
coverture fraction.
VII. FACT WITNESSES
A. Plaintiff
B. Parties' children -The children will testify as to their observations and the significant abuse both
verbal and physical that the Defendant caused upon the Plaintiff. The Plaintiff reserves the right to present rebuttal
witnesses at the time of the hearing.
Vlll. EVIDENCE AND EXHIBITS
A. Appropriate statements pertaining to the value of the parties' IRA accounts bank accounts and savings
accounts.
B. Records pertaining to the parties' marital debts.
C. Appraisal of the Defendant's current residence, if necessary.
D. HUD-I Form documenting cash down payment made by husband at the time of the purchase of his
home.
E. LES documenting the amount of the Defendants military pension.
IN. ATTORNEYS FEES AND COSTS
Due to the Defendant's failure to properly respond to discovery requests and due to the
disparity in incomes between the parties, the Plaintiff seeks reimbursement for her attorney's fees.
X. PROPOSED RESOLUTION OF THE ECONOMIC ISSUES AND DISTRIBUTION
A. ALIMONY - Wife should receive alimony based upon the disparate incomes between the parties.
This marriage was a long term marriage and one in which the wife sacrificed everything including leaving her native
home land in order to allow the husband to continue his career in the military. The wife sacrificed all possibility of
establishing a stable career so as to allow the family to remain as a unified unit and follow the husband to his various
duty stations. Additionally, wife intends to present evidence and testimony that confirm that she was the subject of
significant physical abuse and that the husband engaged in multiple extramarital affairs. It was the pursuit of such
extramarital affairs that caused the husband to separate from the wife.
B. EQUITABLE DISTRIBUTION
It is the Plaintiff's belief that distribution should be 60% her favor and 40% to the husband. Said
distribution shall consist not only of the marital interest of the military pension but shall also take into account the
significant marital assets that were unilaterally withdrawn from the parties' accounts to purchase the husband's
current home. The husband is in a position to refinance the obligation on his home sufficiently for him to make a
lump sum payment to the wife in consideration for the equitable interest in the marital property, with the exception of
the military pension which should be divided between the parties based upon the appropriate coverture or fraction
and with an allowance made for the provision for survivor benefits for the wife.
Respectfully submitted,
KAYER AND BROWN
Date: // (//d
CERTIFICATE OF SERVICE
I hereby certify that a true copy of the foregoing Pretrial Statement Pursuant to Pa. Rule of Civil Procedure 1920.33 was
served on the following person(s), First class mail, postage prepaid, by forwarding a true and correct copy unto:
Robert I Mulderig, Esq.
Turo Law Offices
28 S. Pitt Street
Carlisle PA 17013
and
E. Robert Elicker, Divorce Master
9 North Hanover Street
Carlisle PA 17013
Dated: 0 r
and
J. K
Carh le, P 17013
(717 243- 2
ROSEMARIE ARMSTEAD, :IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
V. :CIVIL ACTION -LAW
:NO. 99-4094 CIVIL TERM
FREDDIE ARMSTEAD, SR.
Defendant :IN DIVORCE
PRAECIPE
Please enter my appearance on behalf of the defendant in the above captioned case.
September 21. 2000
Date
_?///A.e
Robert J. MYlderig, Esq
Turo Law Offices
28 S. Pitt St.
Carlisle, PA 17013
Attorney for Defendant
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ROSEMARIE L. ARMSTEAD,
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FREDDIE ARMSTEAD, SR.,
Defendant
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO.99-4094 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF SERVICE BY MAIL
PURSUANT TO Pa. R.C.P. 1920.4(a)(1)(ii)
COMMONWEALTH OF PENNSYLVANIA
: SS.
COUNTY OF CUMBERLAND
I, James J. Kayer, Esquire, being duly sworn according to law, deposes and says that he is
the attorney for Plaintiff, ROSMARIE L. ARMSTEAD, and that he did serve a true and correct copy
of the Notice to Defend and Complaint in Divorce that was filed in the above matter, by U.S.
Mail, postage prepaid, certified with restricted delivery, return receipt requested, unto the Defendant,
FREDDIE ARMSTEAD, on July 3, 1999. The return receipt is attached hereto.
Sworn to and subscribe efore me
tMt`s- ay o 1 9
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NOTARIAL SEAL I also wish to receive the
.CompeteIt=1 6W& 2 for addlaw services for an
DENISE PINAMONTI, Notary Public •C;omoste hens 3,N, and eb- folkyMng aerv
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ROSEMARIE L. ARMSTEAD, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : CIVIL ACTION - LAW
:NO. 99 - 4094 CIVIL TERM
FREDDIE ARMSTEAD, SR.,
Defendant : IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVOI
UNDER & 3301(c) OF THE DIVORCE CODE
1. 1 consent to the entry of a final decree of divorce without notice.
2. 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.
3. 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.
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on July 2, 1999.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from
the date of filing the Complaint.
3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry
of the decree.
4. 1 understand that 1 may lose rights concerning alimony, division of property, lawyer's fees or
expenses if 1 do not claim them before a divorce is granted.
I verify that the statements made in this Waiver and 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 unswom
falsification to authorities.
DATE: 5 30 2001 o{ a. L c
ROSEMARIE ARMSTEAD
1
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ROSEMARIE ARMSTEAD, :IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
V. :CIVIL ACTION -LAW
:NO. 99-4094 CIVIL TERM
FREDDIE ARMSTEAD, SR.
Defendant :IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on
July 2, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of the filing of the Complaint.
3. 1 consent to the entry of the final Decree in Divorce after service of Notice
of Intention to request entry of the decree.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT
ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN
ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO
UNSWORN FALSIFICATION TO AUTHORITIES.
30 Ll Lgol 4, /"t - yZ12/ YW.
Date I Freddie Armstead, Sr.
. -?
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ROSEMARIE ARMSTEAD,
Plaintiff
V.
FREDDIE ARMSTEAD, SR.
Defendant
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:CIVIL ACTION -LAW
:NO. 994094 CIVIL TERM
IN DIVORCE
WAIVER OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
S 3301(c) OF THE DIVORCE CODE
1. 1 consent to the entry of a final Decree of Divorce without notice.
2. 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.
3. 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.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT
ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN
ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO
UNSWORN FALSIFICATION TO AUTHORITIES.
30 Mast Zoo,
Date
Freddie Armstead, Sr.
'_.. J
Husband Wife
Assets
Members 1st IRA x
American Century IRA x
Janus Mercury Fund x
1996 GMC Conversion Van x
1997 Honda Accord x
Security Service Checking Account x
Security Service Savings Account x
Member's 1 st Checking Account x
Member's 1st Savings Account x
Thrift Savings Plan x
Total Assets
$13,200.00
$20,546.52
$19,417.91
$7,430.00
$7,810.00
$34.83
$7.20
$79.40
$72.63
$770.33
$69,368.82
Husband Wife
Liabilities
Mastercard x $9,000.00
Visa x $10,000.00
IRS x $29,583.44
lien on van x $18,500.00
Total Debt $67,083.44
Military Pension Fund x $1414.99/month
0.375
net assets $2,285.38
50-50 split 1142.69
possesion assets $60,788.49 $8,580.33
possession liabilities $58,083.44 $9,000.00
subtotals $2,705.05 ($419.67)
husband to wife ($1,562.36) $1,562.36
totals $1,142.69 $1,142.69
ROSEMARIE L. ARMSTEAD,
Plaintiff
VS.
FREDDIE ARMSTEAD, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 - 4094 CIVIL
IN DIVORCE
CONFERENCE WITH
COUNSEL AND THE PARTIES
TO: James J. Kayer
Rosemarie L. Armstead
Robert J. Mulderig
Freddie Armstead, Sr.
Counsel for Plaintiff
Plaintiff
Counsel for Defendant
Defendant
A conference has been scheduled at the Office of
the Divorce Master, 9 North Hanover Street, Carlisle,
Pennsylvania, on the 30th day of May, 2001, at 9:00 a.m.,
with counsel and the parties to discuss the outstanding
economic issues to determine if there is a basis of
settlement of claims. If issues remain after the
conference, a hearing will be scheduled at another date.
Very truly yours,
Date of Notice:
April 9, 2001
E. Robert Elicker, II
Divorce Master
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a
ROSEMARIE L. ARMSTEAD, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99 - 4099 CIVIL
FREDDIE ARMSTEAD, SR.,
Defendant IN DIVORCE
TO: James J. Kayer Attorney for Plaintiff
Robert J. Mulderig Attorney for Defendant
DATE: Wednesday, October 18, 2000
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.
Plaintiff awaits bank statements from three (3) PNC
bank accounts held by the defendant at the time of separation.
These statements were requested in formal discovery previously
submitted to the defendant.
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
A motion to compel has been filed regarding the out-
standing discovery and a conference has been scheduled
for Thursday, November 9, 2000 at 10:00 a.m., before
Judge Hess.
I o/zs /oo /
DATE COUN SEL FO L4,INTIFF (?()
COU EL F DF ENDANT ( )
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.
?Fo
N
...' CJ
(C'? eH
U '
?7 O
f7 ..
.J
ROSEMARIE L. ARMSTEAD,
Plaintiff
VS.
FREDDIE ARMSTEAD, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 4094 CIVIL
IN DIVORCE
TO: James J. Kayer Attorney for Plaintiff
Robert J. Mulderig Attorney for Defendant
DATE: Wednesday, October 18, 2000
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 ncomplete discovery.
/ I RGui2GrL1 ..CO ?,(?1.?/(/cE1?' ?.ZOao 6++. ?i? .
DATE COUNSEL R PLAINTIFF )
COUNSEL FOR DEFENDANT (k-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.
ROSEMARIE L. ARMSTEAD, IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
FREDDIE ARMSTEAD, SR. NO. 99-4094 CIVIL TERM
Defendant IN DIVORCE
IN RE: PLAINTIFF'S MOTION TO COMPEL
ORDER OF COURT
AND NOW, this 9th day of November, 2000, in light of
the defendant's compliance in this case, the within discovery
motion is deemed moot.
James J. Kayer, Esquire
For the Plaintiff
Robert Mulderig, Esquire
For the Defendant
:bg
By the Court,
(xu1
A. Hess, J.
Ke7,
? ? -0],?Lu
11-13-00
A-5
.pY.' ' 1I •IJ
CU;:::_..._
Kayer and Brown
Attorneys At Law
A Professional Corporation
Liberty Loft
4 E. Liberty Avenue
Carlisle, Pennsylvania 17013
e-mail: jkayer®epix.net
Telephone: (717) 243-7922 FAX: (717) 243-0946
January 4, 2001
Robert J. Mulderig, Esq.
Turo Law Offices
28 S. Pitt Street
Carlisle PA 17013
RE: Armstead vs. Armstead
Dear Bob:
Please find enclosed the Master's Pretrial Memorandum that I have prepared. I made a
point of attaching those other items including recent pay information from my client to this
document as I know that you have been seeking financial information from her for quite
sometime.
Please let me know if there is any other information that you require.
Very truly yours,
JJK/vjg
cc: Rosemarie Armstead
[ql-/O)??
INCOME AND EXPENSE STATEMENT OF
-"_,?Q,y_{"1'•7 ci. rPet- LOpc I_ /1 r mry -,4 -,,d
SSAI-/72 •4--q• C932 9 DR4 DATE
THIS STATEMENT MUST BE FILLED OUT
(II You are self-employed or it you are salaried by a business of which you are owner in whole or in part, you must
also It:( cut the Supplemental Income Statement which appears on the last page of this Income and Expense
Statement.)
INCOME
(a) WagesiSalary
Employer &Address Y1tle-d ??r o Ya?Jn? s•.-y,?
Job TilleirDescription W,nglg? C/o L
Payy Period (weekly, biweekly, monthly) /99
Grdss Pay per Pay Period ............. ;.......................................................
Payroll Deductions:
Federal Withholding ..................5 /87 . Gq
Social Security ........................... S_ ft&•Ae
Local Wage Tax ..........................S
State Income Tax .......................S a7X,, TI
Retirement ..................................S /.S- Cr 1 19 Health Insurance ........................S ?J •O I
Other (specily).:% :;+,•, ??G;3_ (? 3, 7C
f,((?{mtn?........... S ah?.CO (fir
Net Pay per Pay Pe)i88 . ..............
(b) Other Income Week
Interest/Dividends
Pension/Annuity ..
Social Security ....
Rents/Royal ties ...
Expense Account
Gifts ......................
..S
..5C
.5 / y
.S
S
Unemployment Compensation.S
Workmen's Compensation ........ S_
Total, Other Income .......................S
C _
.t9????•?CwrocN /v./V Off'
J ., 141," ''.3f .?aoo
Month
S
5
S
S
5
5
5
V
INCOME AND EXPENSE SE STATEMENT OF
// O
I verify I)aI the slat emen is made in this Income and Expense state.
ment are true and correct. I understand that (also statements herein
are made subject to the penalties of 18 Pa.C.S. 4$(14 relating to
unsworn falsification to authorities.
Plaintiff or Defendant
s Y7a. A1o
Year
.S I
S
S
5
5 ?
__o -
Household
Week
EXPENSES
H-.,._
Mort;age. Rent .................................... .... S _
t.ta:ntenance ........................................ ... S -
Utilities (telephone, heating
electric, etc.) .................................... :... S_
Er-plcyment (transportation,
lunches) ............................................ ... S _
TaAes
Real Estate .............................................. S
Personal Property ................................... S _
Income ..................................................... S
Insurance n.
'
i? .........................
Homeowners ..( . S
Automobile .............................................. S _
if AccidenliHealth .............................. S
Other ........................................................ S -
Automobile (payments, fuel, -1 1"F'5
repairs) ...... ?1?0..:.?°.:
............... . S -
?
?.Soc _N, 3 _r
J
Medical
't of I v
Doctor. Dentist, Orthodontist...'.......... $_
Hospital ................................................... S _
Special (glasses, braces, etc.) ............... S _
Education
Pri•.ate, Parochial School ....................... S
College ..................................................... S _
Personal
Clothing ................................................... S _
Food ......................................................... S
Other(household supplies,
barber, etc.) .......................................... S _
Credit payments and loans .................... S _
Miscellaneous
Household help/child care ..................... S _
Entertainment (inc. papers,
books, vacation, pay TV, etc.)............ S _
Gifts/Charitable contributions .............. S _
Legal Fees ............................................... $_
Other child support/alimony
payments ............................................. S -
...
Other (specif " ....`P4w M ? ... ?.....
.
Y).....:??...... S _
4
?
Total Expenses ............................................. S -
Child Household Child
Week Mcnth Month
S_ S -115" 0v S
S 5 S
S S 500.00 S
S S / 00,00 S
S S S
S S S
5 ?gc7f . joo ?l"r'
5" S
g S 00
L2 4, S
S S 1,00 S
S S ?' 0 S
S S S
S S S
S S - S
S S - 5
S S - S
S S - S
S - S 100-„200 S
S
S
T S
S S S`On S
S g 5 -0,00 S
S 5 - S
) ov, oy
$
S
g - S ico,co g <
S Zi-?O.B? -? Ste"
S S S
S S
S S
S -
PROPERTY OWNED
Checking Accounts ...
Savings Accounts ..........
...........
Credit Unicn ....................
Stocksreonds .............
..................
Rea! Estate ......................
......................
Other ................................
................................
Total, Property .....................
INSURANCE
Company
Ownership'
Value H W J
S 6'0,00
S _
? $ cc, 00 -
$ - - --
S -
S
S
$ - -
S - -
Coverage'
Potlcy No. H W C
Hospital ..
...............
Medical ........?? k.?.. ?r / 6 /Hi ?S ?ricl/
Health/Accident ..............
Disability Income ....a.......
Other (dental, etc.) ..F!:S-?"?,??'%+- SLR
('H - Husband, W -Wife. J - Joint, C - Child)
l79 bL/ cJ d?r_ ?? ? ? ..
SUPPLEMENTAL INCOME STATEMENT
A. This form must be filled out by a person who (check one):
(1) operates a business or practices a profession; or
(2) is a member of a partnership or joint venture; or
(3) 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 business, profession, partnership,
joint venture, corporation or similar entity.
(1) the most recent Federal Income Tax Return, and
(2) the most recent Profit and Loss Statement.
C. Name and Address of business:
Telephone Number
D. Name and Address (if different than C) of accountant, controller or other person in charge of financial
records:
E. (1) Annual income from business .............................................................................................
(2) How often is income received? ............................................................................................
(3) Gross income per pay period ...............................................................................................
(a) Net income per pay period ...................................................................................................
(5) Specific deductions if any ....................................................................................................
Description
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UNITEDSTATES
J POSTAL SERVICE
BLACKWOOD POST OFFICE
200 DAV STOWN ROAD
BLACKWOOD, NJ 08012-9998
December 1, 2000
TO WHOM IT MAY CONCERN:
This letter certifies that Rose Armstead, Part-time Flexible clerk works for the Blackwood Post Office.
Mrs. Armstead is guaranteed only two hours per pay period which is biweekly. Mrs. Armstead has
been working 40 or more hours per week because we are currently working shorthanded.
If you have any questions, please contact me or Ed Delesandro at 856-227-1710.
Sinc ely yours,
tin-ru.'' 4n??
ermenma P. Whitt*on Of
ficer-in-Charge
CC: file
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ROSEMARIE L. ARMSTEAD, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : CIVIL ACTION - LAW
NO. 99 - 4094 CIVIL TERM
FREDDIE ARMSTEAD, SR.,
Defendant : IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
claims. L. Armstead, Plaintiff, moves the court to appoint a master with respect to the following
(X) Divorce (X) Distribution of Property
( ) Annulment ( ) Support
(X) Alimony (X) Counsel Fees
( ) Alimony Pendente Lite
( ) Costs and Expenses
and in support of the motion states:
(1) Discovery is nearly complete as to the claim(s) for which the appointment of a master is requested.
(2) The defendant has appeared in the action, and is represented by Robert J. Mulderig, Esq.
(3) The statutory grounds for divorce is 3301(d).
(4) Delete the inapplicable paragraph(s):
(a) The action is contested with respect to the following claims: Distribution of property
(5) The action does not involve complex issues of law or fact.
(6) The hearing is expected to take six to eight (6 to 8) hours.
(7) Additional information, if any, relevant to the motion: None.
Date: October 6, 2000
James . Kafir, Esq.
4 E Li rty Avenue
% Carl le, A 17013
(71 243-7922
Attorney for Plaintiff
ORDER APPOINTING MASTER
?GiTC11? ?L
Attorneys Fees and Costs
Alimony
AND NOW, 2000, 21L- Esquire, is appointed master with respect to the
following claims:
BY THE COURT:
J. '0C
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.,..;: „t
CERTIFICATE OF SERVICE
I hereby certify that a true copy of the foregoing Appointment for Master was served on the
following person by First-class mail, postage prepaid addressed to:
Robert J. Mulderig, Esq.
Turo Law Offices
28 S. Pitt Street
Carlisle PA 17013
Date: October 6, 2000
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4 E. ibertk Avenue
C sle, PA 17013
(717)243-7922
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ROSEMARIE L. ARMSTEAD, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
99-4094 CIVIL
FREDDIE ARMSTEAD, SR.,
Defendant IN DIVORCE
IN RE: PLAINTIFF'S MOTION TO COMPEL
ORDER
AND NOW, this r day of September, 2000, a brief argument on the plaintiffs
motion to compel answers is set for Thursday, November 9, 2000, at 10:00 a.m. in Courtroom
Number 4, Cumberland County Courthouse, Carlisle, PA.
BY THE COURT,
James J. Kayer, Esquire
For the Plaintiff
Freddie Armstead, Sr.
Pro Se
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AUG z s 2000P-
ROSEMARIE L. ARMSTEAD, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
Vs. : CIVIL ACTION - LAW
NO. 99 - 4094 CIVIL TERM
FREDDIE ARMSTEAD, SR.,
Defendant : IN DIVORCE
ORDER OF COURT
RULE TO SHOW CAUSE IN RE: MOTION TO COMPEL ANSWERS TO
INTERROGATORIES AND PRODUCTION OF DOCUMENTS IN RESPONSE TO
REQUEST FOR PRODUCTION OF DOCUMENTS
AND NOW, this day of
2000, a Rule is issued upon the
Defendant to show cause why he should not be held in contempt for failing to Answer the
Interrogatories and for failing to supply documents in response to the Plaintiffs Request for
Production of Documents.
This Rule is returnable as follows:
BY THE COURT,
J.
}
ROSEMARIE L. ARMSTEAD,
Plaintiff
VS.
FREDDIE ARMSTEAD, SR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO.99-4094 CIVIL TERM
IN DIVORCE
MOTION TO COMPEL ANSWERS TO INTERROGATORIES
AND PRODUCTION OF DOCUMENTS IN RESPONSE TO REQUEST
FOR PRODUCTION OF DOCUMENTS
COMES NOW, the Plaintiff in the above matter, by her attorney, James J. Kayer, Esquire, and
request of this Honorable Court that it direct the Defendant to respond to the Interrogatories and to
produce documents in relationship to the Request for Production of Documents request. In support of this
request, Plaintiff avers as follows:
1. On June 28, 2000, the Defendant was served with the attached Interrogatories and
Request for Production of Documents, by U.S. Mail, through her attorney, James J. Kayer, Esq.
2. To date, there has been no response to this discovery.
3. Because the Defendant resides out of state, there are few opportunities to attempt to
resolve the matters at issue in this divorce and resolution of any economic issues is impossible absent full
disclosure by the defendant.
WHEREFORE, Plaintiff respectfully requests of this Honorable Court that it enter a Rule
upon the Defendant to show cause why he should not be held in contempt for failing to respond to the
attached discovery request.
Respectfully submitted,
James J. Kayer, sq re
Liberty Loft /
4 Liberty Ave46
Carlisle, PA 17013
(717) 243-7922
Date:
CERTIFICATE OF SERVICE
I hereby certify that a true copy of the foregoing Motion to Compel Answers to
Interrogatories and Production of Documents in Response to Request for Production of
Documents was duly served upon the Defendant by First-class mail, postage prepaid, by
forwarding a true and correct copy unto:
Mr. Freddie Armstead, Sr.
12822 Isle Royale
Dewitt MI 48820
Date (?? 5?°vUJ
Jam J. Ka r, quire
4 East Lib y enue
Libirty L7ftr
Carlisle, PA 17013
(717) 24'3-7922
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ROSEMARIE L. ARMSTEAD, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : CIVIL ACTION - LAW
NO. 99 - 4094 CIVIL TERM
FREDDIE ARMSTEAD, SR.,
Defendant : IN DIVORCE
SUBPOENA TO PRODUCE
DOCUMENTS OR THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.22
TO: Freddie Armstead, Sr.
12822 Isle Royale
Dewitt MI 48820
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following documents or things: Any Statements, records, invoice or other
documentation that reflects the account balances as of August 1998 of the following accounts:
1. Members First Credit Union, Acct.: 33350-10
2. Chase Manhattan Bank American Century Services Corporate Agent (IRA Acct)
3. Janice Mercury Fund, Janice Service Corporation Acct.: JSCJM04800202407878
4. PNC Bank National Association - Acct.: 60300000031700063561
5. PNC Bank National Association - Acct.: 60200000005000761929
6. PNC Bank National Association - Acct.: 699000010110 0320130
7. PNC Bank National Association - Acct.: 699000010110 1380801
8. Homeside Lending Inc. Acct.: 13662326
9. Security Service Federal Credit Union (Savings Account)
at: 4 East Liberty Avenue, Carlisle, Pennsylvania 17201.
You may deliver or mail legible copies of the documents or produce things requested by
this subpoena, together with the certificate of compliance, to the party making this request at the
address listed above. You have the right to seek in advance the reasonable cost of preparing the
copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within'twenty
(20) days after its service, the party serving this subpoena may seek a court order compelling to
you to, comply with it.
This subpoena was issued at the request of the following person:
A
Ja es J. squire
At rney r th,L Plaintiff
Iii 1: 50$ 8
4`Liberty Avenue
Carlisle, PA 17013
(717) 243-7922
Date:
Kayer and Brown
Attorneys At Law
A Professional Corporation
Liberty Loft
4 E. Liberty Avenue
Carlisle, Pennsylvania 17013
e-mail: ikayer@epix.net
Telephone: (717) 243-7922
June 28, 2000
Mr. Freddie Armstead, Sr.
12822 Isle Royale
Dewitt MI 48820
RE: Armstead vs. Armistead - In Divorce
Dear Mr. Armstead:
FAX: (717) 243-0946
As you may recall, this office represents Rosemarie Armistead in her legal
affairs.
Please find enclosed a request for Production of Documents, which has
been filed, and now being served upon you with regard to your divorce.
Based upon my review of my predecessor's file, I am aware of the fact
that you have not always responded to formal discovery request of this kind in a
timely manner. Please note that I will seek all relief available to me including the
impositions of sanctions of cost if you do not comply with this discovery inquiry.
I PS Form 3800, April 1995
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Very truly yours,
Ja esj.K er
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Kayer and Brown
Attorneys At Law
A Professional Corporation
Liberty Loft
4 E. Liberty Avenue
Carlisle, Pennsylvania 17013
e-mail: jkayer0epix.net
Telephone: (717) 243-7922
Mr. Freddie Armstead, Sr.
12822 Isle Royale
Dewitt MI 48820
August 29, 2000
RE: Armstead vs. Armstead - In Divorce
Dear Mr. Armstead:
This letter is a follow-up to our telephone conversation of August 25,
2000.
FAX: (717) 243-0946
During that conversation you advised me that you do not have a copy of
the subpoena to produce documents and things for discovery that I have
previously forwarded to you in June. I am enclosing another copy of that
Subpoena for your reference. I anticipate receiving shortly from the Courthouse
an order arising from the Motion to Compel Discovery that I have filed due to the
fact that we did not receive a timely respunse to our original Subpoena Request.
Based upon the conversation that 1 shared with you, it is my understanding
that you will be contacting all of the relevant financial institutions to obtain
documentation of what account balances existed at the time that you separated in
August 1998. Once you have obtained those documents, please forward them to
me so that you will satisfy your obligations under the subpoena. In the event that
a financial institution indicates that that documentation is no longer available,
please provide me with written confirmation of this fact. Quite frankly, I do not
believe that this will be the case as financial institutions of this type usually has a
records retention policy that would be well in excess of 2 years in duration.
I look forward to obtaining these documents from you in the near future.
JJK/vjg
Enclosures
cc: Rosemarie L. Annstead
Very truly yours,
Jad1e, T Kay r
J
46
OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 Nonh Hanover Street
Carlisle, PA 17013
(717) 2406535
E. Robert Elicker, 11
Divorce Master
West Shore
697-0371 Ext. 6535
Traci Jo Cotyer
Office Manager/Reporter
December 4, 2000
Jomes J. Kayer, Esquire
KAYER & BROWN
Robert J. Mulderig, Esquire
TORO LAW OFFICES
Liberty Loft Noble Mansion
4 East Liberty Avenue 28 South Pitt Street
Carlisle, PA 17013 Carlisle, PA 17013
RE: Rosemarie L. Armstead vs. Freddie Armstead, Sr.
No. 99 - 4094 Civil
In Divorce
Dear Mr. Kayer and Mr. Mulderig;
I have received a petition filed by the Plaintiff Rosemarie Armstead raising
the economic claims of equitabie distribution, alimony, and counsel fees and costs.
The petition was filed with the Prothonotary's office on November 29, 2000.
Consequently, I am going to issue a directive for the filing of pretrial
statements. In accordance with P.R.C.P. 1920.33(b) I am directing each counsel to
file a pretrial statement on or before Tuesday, January 2, 2001. Upon receipt of
the pretrial statements, I will immediately schedule a pre-hearing conference with
Mr. Kayer and Mr. Mulderig, Attorneys at Law
4 December 2000
Page 2
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.
4h
OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240-6535
E. Robert Elicker, 11
Divorce Master
Traci Jo Colyer
Office Manager/Reporter
November 15, 2000
West Shore
697-0371 Ext. 6535
James J. Kayer, Esquire Robert J. Mulderig, Esquire
KAYER & BROWN TURO LAW OFFICES
Liberty Loft Noble Mansion
4 East Liberty Avenue 28 South Pitt Street
Carlisle, PA 17013 Carlisle, PA 17013
RE: Rosemarie L. Armstead vs. Freddie Armstead, Sr.
No. 99 - 4094 Civil
In Divorce
Dear Mr. Kayer and Mr. Mulderig:
I presume that the argument before Judge Hess scheduled for November 9,
2000, has been completed and that you are now in the process of complying with
whatever directive the judge made regarding discovery.
I am, therefore, wanting to move this case forward to conference and
hearing; however, a review of the file indicates that although a divorce complaint
was filed on July 2, 1999, raising grounds for divorce of irretrievable breakdown of
the marriage, no economic claims have been raised by either party.
Consequently, I will not issue a directive for pretrial statements until
counsel have advised as to their intentions regarding the filing of economic claims.
I will allow counsel two (2) weeks to raise any economic claims which they wish to
raise on behalf of either party; if no claims are raised within that time period, I will
prepare an order vacating my appointment.
Mr. Kayer and Mr. Mulderig, Attorneys at Law
15 November 2000
Page 2
I assume that grounds for divorce are not an issue and that the parties will
sign affidavits of consent. No fault grounds have been raised.
Very truly yours,
E. Robert Elicker, II
Divorce Master
VS.
DATE:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION- LAW
NO. N A? L{?CIVIL 19
IN DIVORCE
STATUS SHEET
ACTIVITIES:
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ROSEMARIE L. ARMSTEAD, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99 - 4094 CIVIL
FREDDIE ARMSTEAD, SR.,
Defendant IN DIVORCE
TO: James J. Kayer Attorney for Plaintiff
Robert J. Mulderig Attorney for Defendant
DATE: Wednesday, October 16, 2000
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.
ROSEMARIE L. ARMSTEAD, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 99 - 4094 CIVIL
FREDDIE ARMSTEAD, SR.,
Defendant IN DIVORCE
NOTICE OF PRE-HEARING CONFERENCE
TO: James J. Kayer
Robert J. Mulderig
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 9th day of April, 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: 1/31/01
E. Robert Elicker, II
Divorce Master
James J. Kayer, Attorney for Plaintiff, filed a pre-trial
statement on January 12, 2000.
Robert J. Mulderig, Attorney for Defendant, has not filed a
pre-trial statement as of the date of this notice.