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HomeMy WebLinkAbout03-6340 Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA CARL W. BILLET, JR., v. : CIVIL ACTION - LAW Defendant :NO. 03. ",~4/) : IN DIVORCE CIVIL TERM PAMELA A. BILLET, NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. Ajudgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown ofthe marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Streets, Carlisle. 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 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 CARL W. BILLET, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW PAMELA A. BILLET, Defendant : NO. 0:3-!; 3'-/b : IN DIVORCE CIVIL TERM COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Carl W. Billet, Jr., who currently resides at 117 Tower Circle, Carlisle, Cumberland County, Pennsylvania, since April 2003. 2. Defendant is Pamela A. Billet, who currently resides at 33 2nd Street, York Haven, York County, Pennsylvania, since 1992. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on March 22, 1980, in York County, York, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree of Divorce. 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. S 4904, relating to unsworn falsification to authorities. Date: /c9/1/W03 (If:8~~ ANDREWS & JOHNSON By: P. drews, Esq. eys for Plaintiff . Pomfret Street Carlisle, PA 17013 (717) 243-0123 () C) c~') ::(, ~ C (.." $:: r ~:., L'("'~' 1 ~C .-) ~ ~ Zr. 'J ~ '0 " ~~',.:. , --fl ~C. ?~.: ;?f-~'! "- -..:::. '" ZC" '. ~ :;po,J: :j ""' l--> L h "'\ -<:: "' ~ ,:.> '.i~ '" '" f'-' -<.. V\ '<;\ ~ ~ (r d CARL W. BILLET, JR., Plaintiff/Respondent, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA v. CIVIL ACTION - LAW PAMELA A. BILLET, Defendant/Petitioner No. 03-6340 ACTION IN DIVORCE PETITION FOR RELATED CLAIMS UNDER DIVORCE CODE The Petition of Pamela A. Billet, by her attorneys, CGA Law Firm (Countess Gilbert Andrews, P.C.), respectfully represents that: COUNT ONE EQUITABLE DISTRIBUTION 1. Petitioner is Pamela A. Billet, the Defendant above named, who currently resides at 33 2nd Street, York Haven, Pennsylvania. 2. Respondent is Carl W. Billet, Jr., the Plaintiff above named, who currently resides at 117 Tower Circle, Carlisle, Pennsylvania. 3. Petitioner and Respondent were married on March 22, 1980 in York County, Pennsylvania. 4. Respondent has heretofore filed a Complaint for Divorce on December 5, 2003 at the above caption. 5. Petitioner and Respondent have legally and beneficially acquired property, both real and personal, during their marriage until 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 marriage 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 filing ofthis Petition. 8. 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 II ALIMONY, ALIMONY PENDENTE LITE 9. All preceding and succeeding paragraphs are incorporated by reference. 10. Petitioner lacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment. 11. Petitioner requires reasonable support to adequately maintain herself in accordance with the standard ofliving established during the marriage. 12. Petitioner requests the Court to enter an award of reasonable temporary alimony and additional sums as they may become necessary from time to time hereafter until final hearing and permanently thereafter. COUNT III ATTORNEY'S FEES, COSTS AND EXPENSES 13. All preceding and succeeding paragraphs are incorporated by reference. 14. Petitioner has employed Joseph C. Adams, Esquire as counsel, but is unable to pay all ofthe necessary and reasonable attorney's fees for said counsel. 15. Petitioner has entered into a fee agreement with her attorney. 16. Petitioner may be in need of hiring an accountant, a business appraiser, a real estate appraiser and other experts, and does not have the funds necessary to pay the necessary and reasonable fees. Respectfully submitted, CGA Law Firm Countess Gilbert Andrews, P.C. By: Jo C. Adams, Esquire preme Court No. 70218 29 North Duke Street York, Pennsylvania 1740 I Tel.: (717) 848-4900 VERIFICATION I, the undersigned, Pamela A. Billet, hereby affirm that the facts contained in the foregoing Petition for Related Claims are true and correct to the best of my knowledge, information, and belief. This statement is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. " Dated: /~/21Io~ ,~~ 9-, f3JJ-xt Pamela A. Billet CERTIFICATE OF SERVICE I hereby certify that on this date a copy of the foregoing Petition for Related Claims Under Divorce Code was served on counsel in the manner indicated below: FIRST -CLASS MAll., POSTAGE PREPAID THEREON ADDRESSED AS FOLLOWS: Taylor P. Andrews, Esquire 78 West Pomfret Street Carlisle, PA 17013-3216 CGA Law Firm Countess Gilbert Andrews, P.C. ca~ C. Adams, Esquire Dated: 'I ~ 10, )J () #-1 - ~ " ~ ~ - ..t::: ~ t "ig, 6"- () D D p:!0v J~ r' ~ ~. ~~~ , )> I(~-:"': :~ (") F ", (.::7;"-1 C;,;) ...l~- o -II .-l ., Ai :!J r- 'Jrn ::oc:;::1 f-j 1 ~:;':i~~ , " j:,;;~~~ :-4 .S~J <- ~::,.. Z (.,) -n ':;' Defendant i I : IN THE COURT OF COM' ION PLE S OF : CUMBERLAND COUNT';'! PENNS LV ANIA : CIVIL ACTION - LAW I : NO. 03-6340 CIVIL TJRM : IN DIVORCE i I I I i CARL W. BILLET, JR., Plaintiff v. PAMELA A. BILLET, AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) ..J AND NOW, this z,j'~ day of December 2003 I, Taylor P. Andr s, Esqu re, attorney for Carl W. Billet, Jr., Plaintiff in the above-captioned action, hereby swear that I ve serve a true copy of the Complaint in Divorce, with Notice to Defend and Claim Rights, executed y the PI intiff in the above- captioned matter, upon the Defendant at her residence at 33 2nd Street, York aven, PA 17370 by depositing the same in the U.S. Mail, postage prepaid, certified, deliver to addressee on ,return eceipt requested. A copy of the return receipt card signed by the Defendant on December II, 2003, in icating service was effected, is marked Exhibit nA", attached hereto and made a part hereof. ANDREWS & JOHNSON By: T yl P. Andrews, Es A rney for Plaintiff NOTARiAl SEAl. SHELLY SEXTON, Notary Public Carlisle Boro, Cumberland County My Commission Expires April 26, 2007 Complete items 1,2, and 3. Also complete Item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . A1tach this card to tile back of the mail piece, or on the tront it space permits. c. :dti;~;l;SedA R, (l.~ t k3 ~he(s;:t'I'l'C T 'lor k H.6luen PA . , I oU;/ t (SI'D o Express Mail .,::fReturn Receipt f r Merchandis OC,O.D, 4. Restricted De\i\lery? (Extra Fee) 2. Article Number {Copy from service label) IOCj~~'iDD 001!: S"i/.f<;;"7, PS Form 3811, July 1999 Domestic Return Receipt ld2595.DO.M-0952 Exhibit A \ , / ! " --- '. r::?'t (~... '~::;, \ .~. " ~.;;" .:' ~. .) .{~: / ,- CARL W. BILLET, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW PAMELA A. BILLET, Defendant : NO. 03-6340 CIVIL TERM : IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this Affidavit, you m~st file a counter-affidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 330Hd) OF THE DIVORCE CODE 1. The parties to this action separated on March 30, 2003, and have continred to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division ofpro~erty, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this Affidavit are true and correct. I uJilderstand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating tp unsworn falsification to authorities. Date: / L(/ / /os . ( , . Lz" I J. Carl W. Billet, Jr., Plaint ff CARL W. BILLET, JR. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW Defendant : NO. 03-6340 CIVIL TERM : IN DIVORCE PAMELA A. BILLET COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce ~ecree. (b) I oppose the entry of a divorce decree ibecause Check (I), (ii) or both): (i) The parties to this action have not liv~d separate and apart for a period of at least two years! (ii) The marriage is not irretrievably brok~n. 2. Check either (a) or (b): (a) ! I I do not wish to make any claims for ~conomic relief. I understand that I may lose rights conqerning alimony, division of property, lawyer's fees or ~xpenses if! do not claim them before a divorce is grante~. (b) I wish to claim economic reliefwhiclj may include alimony, division of property, lawyer's fees or expenses or other important rights. ' I verify that the statements made in this counter-affidavit are true and ~orrect. I understand that false statements herein are made subject to the penalties of 18 l'a. C.S. ~ 4904 relating to unsworn falsification to authorities. Date: Defendant 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 ~Ie this counter- affidavit. NOTICE: (." l~~?, .:.:,:" -::... > '':' j ,..'.C (") ~;i\ .---' -,." ~- ~."..., "\;:. ',C' .~ '-;~/ Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CARL W. BILLET, JR., v. : CIVIL ACTION - LAW Defendant : NO. 03-6340 : IN DIVORCE CIVIL TERM PAMELA A. BILLET, MOTION FOR APPOINTMENT OF MASTER Carl W. Billett, Plaintiff, moves the court to appoint a master with respect to the following iclaims: (X) Divorce ( ) Annulment (X) Alimony ( ) Alimony Pendente Lite (X ) Distribution of Property ( ) Support (X) Counsel Fees (X) Costs and Expenses Md in support of the motion states: 1. requested. Discovery is complete as to the claim(s) for which the appointment of a master is 2. The defendant has appeared in the action by her attorney, Joseph C. Adams, Esquire, 29 North Duke Street, York, P A 17401. The Plaintiff has appeared in the action by his attorney, Taylor P. Andrews, Esquire, 78 West Pomfret Street, Carlisle, PA 17013. 3. The statutory ground(s) for divorce is an irretrievably broken marriage and a 2-year ~eparation as per 23 Pa.C.S.A. g3301(d). 4. The action is contested with respect to the following claims: all economic claims. 5. The action does not involve complex issues oflaw or fact. 6. The hearing is expected to take 4 hours. 7. Additional information, if any, relevant to the motion: None. Oate: May 6, 2005 Ta or P. ws, Esquire At for Plaintiff Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CARL W. BILLET, JR., v. : CIVIL ACTION - LAW Defendant : NO. 03-6340 : IN DIVORCE CIVIL TERM PAMELA A. BILLET, CERTIFICATE OF SERVICE I hereby certifY that on this date, May12005, I mailed a copy of Ordering Appointing Master and Motion for Appointment of Master to the following person at the following address by U.S. Mail, to addressee onjy: Joseph C. Adams, Esquire 29 North Duke Street York, PA 17401 I verifY that the statements made in the foregoing Certificate of Service are true and correct. I ,understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904, relating to iunsworn falsification to authorities. ANDREWS & JOHNSON By: ------ ay P. Andrews, Esq. ttorneys for Plaintiff 78 W. Pomfret Street Carlisle, PA 17013 (717) 243-0123 '. c '>', (;..::;> .:.J" - (", .:0(. "", \ ,-0 ': --." :....... ,-, ":';' r)'1 \..0 .. RECEIVED MAY 10 ZlJf:/ J , CARL W. BILLET, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW PAMELAA. BILLET, Defendant : NO. 03-6340 : IN DIVORCE CIVIL TERM ORDER APPOINTING MASTER AND NOW,~!) , 2005, E. Robert Elicker, Esquire is appointed master with respect to the following claims: Alimony, Counsel Fees, Costs and Expenses, Divorce, and Distribution of Property. ~\~ ,,BY THE COU~~/ . ~. '.........- . "' . \~ ' -l J. "one ',' "," I, 0 L ~,J U~" / hi 3: 54 Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA CARL W. BILLET, JR., v. : CIVIL ACTION - LAW Defendant : NO. 03-6340 : IN DIVORCE CIVIL TERM PAMELA A. BILLET, AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 5, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry ofthe 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. S 4904, relating to unsworn falsification to authorities. Date: \..~n'J /(." ,).00..$ ~.1~ () ~ Pamela A. Billet, Defendant ~, r:~~ '.:;:r. (2:. , r-) ~ :::?-c fn~:;..~ ".'1',___., )'-i "j (-) " ~~~.- ~:;: C.) -' - CARL W. BILLET, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW PAMELA A. BILLET, Defendant : NO. 03-6340 : IN DIVORCE CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if] do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verifY that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S4904, relating to unsworn falsification to authorities. , Date: \f) '0 / ~ ( ~OOS ;~ 0 CMW- Pamela A. Billet, Defendant ------ (] ,.., 0::= 5~ c.~ ., I I f',] 25 Co,) -, "--", ~_/ -n :=! i;-;~ CARL W. BILLET, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW PAMELA A. BILLET, Defendant : NO. 03-6340 : IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on December 5,2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of 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. 9 4904, relating to unsworn falsification to authorities. / WC0~ Carl W. Billet, Jr., Plaintiff Date: (P;; /or ('-) ,.., : ~~~; ~'__n () -n :::1 rii N c....) _.._~ Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CARL W. BILLET, JR., v. : CIVIL ACTION - LAW PAMELA A. BILLET, Defendant : NO. 03-6340 : IN DIVORCE CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verifY that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S4904, relating to unsworn falsification to authorities. Date: G}/>5' . C1f (}J ~ 'l Carl W. Billet, Jr., Plaintiff' ....' c.;:. ,,~ c:./"I ~ :::J \ 1''''; C-) {>.) ._J Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CARL W. BILLET, JR., v. : CIVIL ACTION - LAW PAMELA A. BILLET, Defendant : NO. 03-6340 : IN DIVORCE CIVIL TERM PRAECIPE TO THE PROTHONOTARY: On behalf ofthe Defendant, I hereby withdraw the economic claims filed at the above caption in a "Petition for Related Claims under Divorce Code" expressing claims in Count I for Equitable Distribution, Count II for Alimony and Alimony Pendente Lite, and Count III for attorneys fees, costs and expenses. Date: /Y)~ J3, )00\ C. aJ.. Jo e C. Adams, Esquire Supreme Court ID: 70218 29 North Duke Street York, PA 17401 (717) 848-4900 ( ",",", ~::? ,-'.Il (P.' C:: l~0 c,) C'l () -11 - CARL W. BILLET, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW PAMELA A. BILLET, Defendant : NO. 03-6340 CIVIL TERM : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2 Date and manner of service of the complaint: December 11,2003 bv restricted, certified mail, return receiot requested. 3. Date of execution ofthe affidavit of consent required by Section 330 I (c) ofthe Divorce Code: by the Plaintiff June I. 2005; by Defendant Mav 16. 2005. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: S"v1<Z....- 7.. \ 200:>" Date Defendant's Waiver of Notice m ~3301(c) Divorce was filed with the Prothonotary: .:::r tJ..e.. Z. 'L (Jf);;;- ( ANDREWS & JOHNSON Date: June' 2005 By: Ta or . Andrews, Esq. 7 W. t Pomfret Street Carlisle, PAl 70 13 (717) 243-0123 Supreme Court 10 No. 15641 (') c: :;;: -oi:r! t:pq', ~~"2 r:::.c. )>c Zl-,.' >c L_ =< ....., = = ..... E % I (j\ ~ ~~ ~~ b ::::ii ;t<> 9i5;Q ~c hi - -"l Z, ~ C> CARL W. BILLET, JR., Plaintiff Vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03 - 6340 CIVIL PAMELA A. BILLET, Defendant IN DIVORCE ORDER OF COURT AND NOW, this y.d day of ~ withdr/~n by praecipe and 2005, all economic claims having been both parties having signed affidavits of consent and waivers of notice of intention to request entry of divorce decree, there being no matters pending before the Master, the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. BY THE COURT, .J. cc: Taylor P. Andrews Attorney for Plaintiff Joseph C. Adams Attorney for Defendant ~'~ ~--'- {, - 03 0 s:' c;L Q.-~.~ I:f!N'1'^lJ..SNN3d A!.NnCO m.iiflfJJ8I1n;J G~ :01 W\1 ~- Nor snnl Al:J'IilONOH10tJd 3Hl .:10 3~J:J:lO-CJ3lI:l . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PEN NA. Carl W. Billet, Jr. Plaintiff No. 03-6340 VERSUS Pamela A. Billet Defendant DECREE IN DIVORCE AND NOW, - \ 'l\\.Q. ~ ~ ~, IT IS ORDERED AND DECREED THAT Carl W. Billet, Jr , PLAINTIFF, Pamela 1>.. Billet AND , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE / PROTHONOTARY . . .. . . . --- 'fi;!; if' +-;+: OJ; :f . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . . . . . . .' ~ fr' 5' AfT"" ~p? j,I "l ~ Jr ~ ~6W-Pf7 50' j,! < '. _. ...,-. t ,"~. ", ,''''', "." .. " " -