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HomeMy WebLinkAbout99-06918?:? JOI IN R. MORRISON, : IN TI1H COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUN'T'Y, PENNSYLVANIA v. : NO. 99-6918 CIVIL TERM SANDRA K. MORRISON, : CIVIL AC'T'ION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of' the Divorce Code was filed on November 19. 19'1'9. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry or a Final Decree of Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4909 relating to unsworn falsification to authorities. Dale: / -/`I -c/ .I01101. Morrison. Plaintiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE I consent to the entry or a Final Decree in Divorce without notice. 2 1 understand that I may lose rights concerning alimony. division of property, lawyer's fees or expenses if 1 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 a copy of the Decree uvill be sent to ne immediately after it is filed with the Prothonotary. I verily that the statements made in this affidavit au•e true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4909 relating to unsworn falsification to authorities. Date: / - / 9 loh 1. Morrison. Plaintiff' ? 1 IN THE COURT OF COMMON PLEAS OF I? 1 CUMBERLAND COUNTY, PENNSYLVANIA ?I CIVIL ACTION - LAW Vs. NO.??`''??91Q CIVIL 19 O1 J? ???? ? "y? ?? IN DIVORYCE STATUS SHEET DATE: ACTIVITIES: JOHN R. MORRISON, Plaintiff VS. SANDRA K. MORRISON, Defendant TO: Thomas S. Diehl James J. Kayer IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 6918 CIVIL IN DIVORCE M? F i Attorney for Plaintiff Attorney for Defendant DATE: Thursday, November 9, 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. OFFICE OF DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEAS 9 North Hanover Street Carlisle. PA 17013 (717) 2406535 E. Robert Elicker, II Divorce Master Traci Jo Colyer Office Manager/Reporter West Shore 6970371 Ext. 6535 January 17, 2001 Thomas S. Diehl, Esquire 401 East Louther Street Suite 103 Carlisle, PA 17013 James J. Kayer, Esquire KAYER & BROWN Liberty Loft 4 East Liberty Avenue Carlisle, PA 17013 RE: John R. Morrison vs. Sandra K. Morrison No. 99 - 6918 Civil In Divorce Dear Mr. Diehl and Mr. Kayer: Mr. Kayer has indicated on behalf of the Defendant that discovery is complete; Mr. Morrison filed his own certification document regarding discovery and indicated that discovery is complete. Consequently, I am going to proceed on the basis that we will not be dealing with any discovery issues as we proceed with the pretrial phase of the case. In accordance with P.R.C.P. 1920.33(b) I am directing each counsel to file a pretrial statement on or before Friday, February 23, 2001. Upon receipt of the pretrial statements, I will immediately schedule a pre-hearing conference with counsel to discuss the issues and, if necessary, schedule a hearing. Very truly yours, E. Robert Elicker, II Mr. Diehl and Mr. Kayer, Attorneys at Law 17 January 2001 Paae 2 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. I ? Y ? lr r i"1 ? . C M ` C: N O o N L E N N x 'a U, > r J r . CO o'- N?a?:x p m y ' ? o .Rya J :1 J'] t.. •CJ , q- n C'l -» h y (r C_.. W - r yr . • n r.: JOHN R. MORRISON, Plaintiff Vs. SANDRA K. MORRISON, Defendant TO THE PROTHONOTARY: IN THE COURT OP COMMON PLEAS Of CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-6918 CIVIL TERM IN DIVORCE PRAECIPE Please enter my appearance as counsel of record for the above-captioned Defendant. Respectfully submitted, Dated: !I James J. K#&,Esquire Liberty Lofl 4 E. Liberty Avenue Carlisle, PA 17013 (717) 243-7922 cc: Thomas Diehl JOHN R. MORRISON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99- 6913 aw- TERM SANDRA K. MORRISON, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORnER of call iRT AND NOW, this n7 I I(A `l q upon consideration of the attached Complaint it is hereby directed that the parties and their respective _ counsel appear before a r??X C^1?C(z` Esquire, the conciliator, at" ct'.-i?,?°? Co•.x ate YzP. Pennsylvania, on the J_ day of C3(1 9?9?4?-at ??.?? -M. for a Pre-hearing Custody Conference At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a temporary order. All children age five or older may be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: By: -tL v? J Custody Conciliator YOU SHOULD TAKE TI4IS PAPER TO YOUR LAWYER AT ONCE. II' YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPI-ZONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 1-300-990-9103 ..y /;7. ?JU . ?y^ /_ ??. aL?;?t:? :.Gtr ?• J`?il?? ?? _ i JOHN R. MORRISON, Plaintiff V. SANDRA K. MORRISON, Defendant IN TI IE COURTOFCOMMON PLEAS OF CUMBERLAND COUNTY, PI3NNSYLVANIA NO. 99-6918 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CON1PL,AIN1' Fnli CUSTODY 1. Plaintiff is John R. Morrison, an adult individual currently residing at I I West Butler Street, Mount Holly Springs, Cumberland County, Pennsylvania 17065. 2. Defendant is Sandra K. Morrison, an adult individual currently residing at 25 Trine Avenue, Mount Holly Springs, Cumberland County, Pennsylvania 17065. 3. "rhe Defendant is the natural mother of the child, Zachary Eli Morrison, born November 2, 1988. 4. 'rhe child was not born in wedlock. 5. For the past five years the child has resided with the following persons at the following addresses for the following lengths of time: NAMI ADnRr-SS DATES Sandra Morrison 25 Trine Avenue November 30,1995 to Mount Holly Springs, PA present John Morrison 25 Trine Avenue November 2, 1988 to Sandra Morrison Mount I lolly Springs, PA November 30, 1995 6. The natural mother of the child is Sandra K. Morrison, who resides as foresaid. She is married. 7. The natural father of the child is John R. Morrison, who resides as foresaid. He is married. 8. 'fhe relationship of the Plaintiff to the child is that of natural Father. The Plaintiff currently resides alones. 9. The relationship of the Defendant to the child is that of natural Mother. The Defendant currently resides with the child. lo. 'rhe Plaintiff has no information of a custody proceeding concerning the child pending in any Court of this Commonwealth. 1 I. The best interest and permanent welfare of the child will be best served by granting primary physical custody of the child to the Plaintiff who is better suited to provide a stable environment to foster the child's well being. 12. The Plaintiff does not know of any person not a party to the proceedings who claim to have custody or visitation rights with respect to the child. WHERE=FORE, the Plaintiff, John R. Morrison, respectfully requests this Honorable Court to enter an Order scheduling the Panics for a Custody Conciliation. Respectfully submitted, 1 Dale: DECETIBER 9s 1999 Thomas S. Dichl Attorney for the Plaintiff 401 East Louther Street, Suite 103 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FA\ JOHN R. MORRISON, : IN TI1E COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 99- 6918 CIVILTERM SANDRA K. MORRISON, : CIVIL ACTION - LAW Defendant : IN CUSTODY VF.RIRI('ATION 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 unswom falsification to authorities. JF HN R. MORRISON, Plaintiff JOHN R. MORRISON, Plaintiff V. SANDRA K. MORRISON, Defendant IN "'1117 COURT OF COMMON 13LI-AS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- CIVILT'ERM CIVIL ACTION - LAW IN DIVORCE \'n'I'l( 1., rn r?rr r\'D A1'r) C 1 A1M1 U 11l You have been sued in Court. If you wish to defend against the claims set forth in the IOllowing pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. 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 01' PROPERTY, LAWYER'S FEES OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT" TO CLAIM ANY OT' THEM. YOU SHOULD TAKE 'T'HIS 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 I-IND OUT WHERE YOU CAN GET LEGAL KELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-;166 JOHN R. MORRISON, Plaintiff V. SANDRA K. MORRISON, Defendant IN THE COURT OF COMMON PLEAS OI' CUMBERLAND COUNTY, PENNSYLVANIA Np 99- rv 9 / F CIVIL TERM CIVIL ACTION - LAW IN DIVORCE l AI 'T 1 ` DIVn12Cl II [DER 4FC1In\`4 i illl(cl or 341(d) OF "I U Il YO CF COO The Plaintiff, John R. Morrison, through his attorney, Thomas S. Diehl, makes the following Complaint in Divorce, and, in support thereof, avers as follows: The Plaintiff, John R. Morrison, is an adult individual who currently resides at I 1 West Butler Street. Mount Holly Springs, Cumberland County, Pennsylvania 17065. 2. The Defendant, Sandra K. Morrison, is an adult individual who currently resides at 25 Trine Avenue, Mount Holly Springs, Cumberland County, Pennsylvania 17065. 3. The Defendant and the Plaintiff have been bona Fide residents of the commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on January 20, 1989 in Hagerstown, Maryland. 5. Therc have been no prior actions for annulment between the parties. 6. There has been one prior action in divorce between the parties, which was tiled in Cameron County and discontinued on October 27, 1998. 7. The marriage is irretrievably broken. i i IL 8. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff, John R. Morrison, respectfully requests this Honorable Court to enter a decree in divorce pursuant to 23 P.S. § 3301(c) or 3301(d) of the Divorce Code. Respectfully submitted, Date: / ( 1 (a ` Attorney for the Plaintiff 401 East Louther Street, Suite 103 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 249-2407 - FAX I JOIIN R. MORRISON, : IN'I'IIf- COURTOF COMMON PLEAS OF Plaintiff : CUMBERLANUCOUNTY, PENNSYLVANIA V. : NO. 99- SANDRA K. MORRISON, : CIVIL ACTION - LAW Defendant : IN DIVORCE VERIFICATION 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 13 Pa.C.S. § 4904, relating to unscvorn falsification to authorities. Ox Lt- tie KI N R. MORRISON, Plaintiff JAN 31, 2D0a(1)01 JOHN R. MORRISON, IN THE COURTOF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION-LAW SANDRA K. MORRISON, NO. 99-6918 CIVIL Defendant IN CUSTODY COURT ORDER AND NOW, this day of cc 2000, upon consideration of the attached Custody Conciliation Report, it is ordered a and directed as follows: The Father, John R. Morrison, and the Mother, Sandra K. Morrison, shall enjoy shared legal custody of Zachary Eli Morrison, born November 2, 1988. This provision shall allow all school officials, health officials and other professionals to deal with both parents and provide all pertinent information concerning the minor child to both parents. 2. The Mother shall enjoy primary physical custody of the minor child. 3. The Father shall enjoy periods of physical custody with the minor child as follows: A. On alternating weekends from Friday at 6:30 p.m. until Sunday at 4:00 p.m. B. For a period of three (3) weeks in the summer which shall be consecutive and take place in August. Father shall give Mother at least thirty (30) days notice as to when he shall exercise his three (3) week period of custody. During this three week timeframe, the _ minor child shall be afforded the opportunity to spend a short period of time with the Mother if the minor child requests that opportunity. 4. The parties shall alternate custody on major holidays to include New Year's Day, Easter. Memorial Day, July 4"', Labor Day and Thanksgiving. For Christmas, the parties shall alternate custody of the minor child between two timeframes, the first one being Christmas Eve at 2:00 p.m. until Christmas Day at 2:00 p.m. and the second timeframe being from Christmas Day at 2:00 p.m. until December 26'h at 2:00 p.m. Nothing in this provision shall restrict the parties from agreeing to modify this provision pursuant to an agreement reached by the parties. 5. Both parents shall ensure that adequate supervision is provided for the minor child when the minor child is in their custody. 6. Neither party shall drive an automobile with the minor child while that party is under the influence of alcohol. Furthermore, neither party shall become intoxicated when they have custody of the minor child. This Order is entered pursuant to an agreement reached by the parties at a Custody Conciliation Conference. In the event either party desires to modify this Order, that party may petition the Court to have the case again scheduled for a Conference with the Custody Conciliator. cc: Thomas S. Diehl, Esquire James J. Kayer, Esquire BY "I'l IE COURT. a-,3-00 R K.5 JOHN R. MORRISON, Plaintiff SANDRA K. MORRISON, Defendant Prior Judge: : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION-LAW NO. 99-6918 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the child who is the subject of this litigation is as follows: Zachary Eli Morrison, bom November 2, 1988. 2. A Conciliation Conference was held on January 28, 2000, with the following individuals in attendance: The Father, John R. Morrison. with his counsel, Thomas S. Diehl, Esquire; and the Mother, Sandra K. Monson, with her counsel, James J. Kayer, Esquire. The parties agree to the entry of an order in the form as attached. 1 a Z/ 00 DATE Hubert X. Gilroy, Esquire Custody Conciliator 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 November 14, 2000 E. Robert Elicker, III Divorce Master 9 North Hanover Street Carlisle PA 17013 RE: Morrison vs. Morrison - In Divorce Dear Mr. Elicker: FAX: (717) 243-0946 Please find enclosed the Certification for Discovery in the above referenced matter. JJK/vjg Encls. cc: Sandra Morrison (w/encls) Thomas Diehl, Esq. (w/encls) Very truly yours. it Janikr Ka} r JOHN R. MORRISON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUM BERLAND CO UNTY, PENNSYLVANIA VS. NO. 99 - 6918 CIVIL SANDRA K. MORRISON, Defendant IN DIVORCE ``. ?S I; FY TO: Thomas S. Diehl Attorney for Plaintiff } n James J. Kayer Attorney for. Defendant i DATE: Thursday, November 9, 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 FO PAINTIFF ( ) COUNSEL FOR EFENDANT (?) i NOTE: PRETRIAL DIRECTIVES WIL 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. , ?' t?OV 1012?a? i? JOHN R. MORRISON, Plaintiff VS. SANDRA K. MORRISON, Defendant TO: Thomas S. Diehl James J. Kayer IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 6918 CIVIL IN DIVORCE , Attorney for Plaintiff , Attorney for Defendant DATE: Thursday, November 9, 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 r SEL FOR PLAINTIFF ( ) SEL FOR DEFENDANT ( ) OUN 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. r - 3 _ rL': ' ? r 1 ! Y 1 w , C L C?j C m t r rr,, U Nr 7 T .:.. ( t N ? r% ? CO O .?• C t - ?' W rv ? ` Sl am 6 x ( ? ? ` \ ,y T 3 J r 6 ?. _', 1 % + tit + cl? .U Cl) tL J- C3 tu r JOHN R. MORRISON. Plaintiff vs. SANDRA K. MORRISON, Defendant IN TI IE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 99-6918 CIVIL TEIZM IN DIVORCr MOTION FOR APPOINTMENT OF MASTER claims. K. Morrison, Defendant, moves the court to appoint a master with respect to the following (X) Divorce ( ) Annulment ( ) Alimony ( ) Alimony Pendente Lite (X) Distribution ol'Property, ( ) Support ( ) Counsel fees ( ) Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claim(s) for which the appointment ol'a master is requested. (2) The defendant has appeared in the action by her attorney, (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: Equitable Distribution. (5) The action does not involve complex issues of law or fact. (6) The hearing is expected to take three to five (3 to 5) hours. (7) Additional infornnation, if any, relevant to the motion: None. Date: 1./''':'I i. , '- I ?i [lies J. I yert-sq. East Libx'rty Xvenue irlisle,03A 17013 17) 243-7922 torney for Defendant ORDER APPOINTING MASTER AND NOW,/n'?% p 000, cLf V?1sgilire, is appointed master with respect to the following claims: /,X 13Y TIME OURT: Z" J. O?ta.?, ..<,Yt 11-3-00 RKS .; i JOHN R. MORRISON, Plaintiff SANDRA K. MORRISON, Defendant IN THE COURT OP COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW NO. 99 ?;Y/,'CIVIL TERM IN DIVORCE AITIDAVI'1' t]NI)ER SEC'PION 33Q1(d) OP'TIIE DIVORCE CODE The parties of this action separated on November 30, 1995, and have continued to live separate and apart for a period of at least two years. 2. 'fhe marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or CNpenses if I do not claim them before a divorce is granted. I verily that the statements made in this Affidavit are true and correct. 1 understand that false statements herein are made subject to the penalties of] 8 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: II S-Q`J (2? PL??r?- -- JO N R. MORRISON L Gi` f_ C: 4?. C J u +?^v?rv?acFiR?-n.'-a uy7 r iw .i ? r ?.?'t a`Y'. kC J ti? e a11r ?y° ? t??7a''?Q+'x'PZ .?`? ;9twXl j[ '? ¢ •s .:K?v?•Y?'.Y??i,i Y'.tL.:.4•tlf(1.h_...,_.,._t9c. ,[t m..,, •). LVi..,. .? +..._.4.. Jrsd_ while v44@'Ga JOHN R. MORRISON, Plaintiff V. SANDRA K. MORRISON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW NO. 99-6918 CIVILTERM IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this 29°i day of November 1999, comes Thomas S. Diehl, Esquire, Attorney for the Plaintiff, John R. Morrison, and states that he personally mailed a certified copy of a Complaint in Divorce to the Defendant, Sandra K. Morrison, at 25 Trine Avenue, Mount Holly Springs, Pennsylvania by certified, restricted delivery, return-receipt requested. A copy of said receipt is attached hereto indicating service was made on November 11, 1999. Respectfully s i/ / C Thomas S. Diehl Attorney for the Plaintiff 401 East Louther Street, Suite 103 Carlisle, PA 17013 (717) 240-0833 (717) 340-0893 - FAX 1 Z 339 067 E62 US Postal Service Receipt for Certified Mail Ne Insuranco Coverage Provided. Do not use for Inleucdional Mail (See reverse) .1 C r n C c a n f li v n &-nl In SANDRA K. MORRISON stet A number 25 'T'RINE AVENUE Pnsl olhca, Stine. A ZIP, coda MOUNT HOLLY SPRGS, PA 170 rn,I.Ip. $ .55 CrWind IC. ^ . 1.40 Sproal(. y?{Zr. LTS? finn7?d I or' my r• y 75 14!Im Iner I Shov sIy va,i a. par Uclin, Ml ll St T .25 • un e rt A pnte,h MD !re' tornl.resw9e S 5.95 frnstamil, or Uatn u SENDER: U . CI Idelo amrg lnuM1'er.^Inr nAAmonal sarvi ut •Camplrlnncur, j..ln. unrI'll, r u •IUnlywn lrurranerd mhlmss on lhn d rovr'I:'R I r:udlo yan at • AII;1,11 llne luurr lu lhn bnre0111 mailpr,? I1nurul •I'hln•F6•Iwn fill 't rl nilBeyur• 11) %nll n,lppn it w •Illn llnluur llrn"pl i SllJrv In h onm ?e)u i tlnLVnuvl o :1. Nlirln Addmecou n SANDRA K. MORRISON 0 25 'T'RINE AVLNUE 1-fOUN'Tr IIOLr.Y SPRINGS, PA 17065 X a , f 1, December 199.1 S wish to receive the 119 services (for an 4b. S - ervice Type ` ? Registered ? Express Mail ? Insured ? Relmnlleceipt for Merchandise ? COD 7. Dale of Delivery ? ??-ice 9 o {3. Addressee's Address (Only 11 requested 0 cord too is paid) c n t IOMS 911 13 DI29 .'_? ? v? ?' , _ , s ., , ._ ?? r. /?' ? r,, :: ' ? : - .v V ^ -'? '- ':li_1 ,; (.: Cn i) rc I.j 4 I. 4 f F7 O o :q, R;N.. L O ..0-C 0. c, G):,. W y O , , A O ( o ? p ? r t r Z rn N x7C7 ? C 0 I -A JOHN R. MORRISON, Plaintiff VS. SANDRA K. MORRISON. Defendant IN TI"IE COUR•f of, COMMON PLEAS OF C'Ufvll3ER1.AND COUNTY. PENNSYLVANIA CIVIL ACTION - LAW NO.99-6f3-f-S VII, TERM ?F- 01/ IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER Check either (a) or (b): SECTION 330 1 (d) OF THE DIVORCE CODE (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry ofa divorce decree because (Check (i),(ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief: I understand that Inlay lose rights concerning alimony, division or property, lawyer's fees or expenses if 1 do not claim them before a divorce is granted. (b)1}vish to claim economic relief' which may include alimony, division ofproperty. la lame s or expenses or other important rights. I Understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Deercc, the divorce decree may be entered without further delay. I verify that tie statements made in this counter-affidavit are true and correct. I understand that false statements herein a made subject to the penalties off 8 Pa. C.S. § 4904 relating to unswom falsif ication to authorities. / i llala November lj 1999 "• 1, . SANDRA K. MORRISON NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file this counter-affidavit. 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 February 15. 2001 E. Robert Elicker, III Divorce Master 9 North Hanover Street Carlisle PA 17013 RE: Morrison vs. Morrison - In Divorce Dear Mr. Elicker: FAX: (717) 243-0946 The parties have agreed to resolve their differences with regard to the outstanding economic issues in this matter and we can anticipate the filing of a motion to vacate your appointment in the near future. By copy of this correspondence I am advising Torn Dichl, Esq., counsel for Mr. Morrison of the fact that 1 have notified your oil-ice of our agreement and that he has concurred in vacating your appointment. JJK/vjg Encls. cc: Sandra Morrison Thomas Diehl. Esq. Very truly yours, A, n .James J. laycr? I I 1 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 FAX: (717) 243.0946 February 21. 2001 E. Robert Elicker. III Attn: Traci 9 North Hanover Street Carlisle PA 17013 RE: Morrison vs. Morrison - In Divorce Dear Traci: This will confirm my telephone conversation of February 20, 2001 in which I advised you that the parties in this matter will not be executing a Marital Settlement Agreement. After consultation between Tom Diehl and me, it has been confirmed that the parties have decided to allow the divorce decree to extinguish any and all claims that each might have and property solely titled or possessed by the other spouse. I am forwarding a copy of this correspondence to Mr. Dichl as well so that he is aware of our conversation and he can independently confirm that this is acceptable to Mr. Morrison and himself. Thank you for your attention to this matter. Very truly yours. i l .lahicO. Kayer JJK/vjg ' Encls. cc: Sandra Morrison Thomas Dichl, Esq. JOHN R. MORRISON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99 - 6918 CIVIL SANDRA K. MORRISON, Defendant IN DIVORCE ORDER OF COURT AND NOW, this 4 day of , 2002, counsel having advised the Master's office by correspondence on February 21, 2001, that the above captioned case settled and that the parties were not anticipating entering into a written agreement, the appointment of the Master is vacated. BY THE COURT, Ge g o f L, P J. cc: Thomas J. Diehl Attorney for Plaintiff James J. Kayer Ca?.rro nom, + ( )/ d? Attorney for Defendant =,;, ..... .. i , ...u• .., G. ., ,: t ,: