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HomeMy WebLinkAbout08-6129 1+ WILLIAM L. FEUCHTENBERGER, Plaintiff vs. CARLA A. FEUCHTENBERGER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. ak"111;1 ?T Civil Term ACTION 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. Where the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY- LAWYER'S LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 St. Carlisle, Pa. 17013 (717) 249-3166 WILLIAM L. FEUCHTENBERGER, Plaintiff vs. CARLA A. FEUCHTENBERGER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. of -61a4 Civil Term ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is William L. Feuchtenberger, a competent adult individual, who resides at 131 Beetem Hollow Road, Newville, Cumberland County, Pennsylvania, 17241. 2. Defendant is Carla A. Feuchtenberger, a competent adult individual, who resides at 131 Beetem Hollow Road, Newville, Cumberland County, Pennsylvania, 17241. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on August 24, 1991 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have two children together, namely, Garrett Feuchtenberger, born January 23, 1992, and Travis Feuchtenberger, born May 3, 1997. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of America or any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in 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. §4904 relating to unsworn falsification to authorities. William L. Feuchtenbi-rder, 'Plaintiff Respectfully sub Date: [ o•i'I•() 3 O a Adams, Esquire I. . No. 79465 1 W. South St. arlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF n I R y 3 ca CD WILLIAM L. FEUCHTENBERGER, Plaintiff vs. CARLA A. FEUCHTENBERGER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. Q R' WcX l Civil Term ACTION IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this October 28, 2008, I, Jane Adams, Esquire, hereby certify that on or about October 21, 2008, 1 served a copy of the NOTICE TO DEFEND AND DIVORCE COMPLAINT on Defendant, via certified mail, restricted delivery, at the following address: - - - Carla A. Feuchtenberger 131 Beetem Hollow Road 'complete (tams 1, 2, and 3. Also complete Newville, Pa. 17241 item 4 if Restricted Delivery is desired, ¦ Print your and address on the reverse DEFENDANT so that rn the card to you. ¦ Attach this card to the hack of the mallpiece, or on the front If space permits. 1. Article Addressed to: "W - V e'uAei??, t-?k 99-r-?M w ?ewultie'f# > +? by 1 C. Efate of Delivery ,?la A e n? Ai 1 /D-.2 /-G& D. Is delivery address different from item ? 0 Yes M YES, enter delivery adtsss below: 0 No 3. Service Type U-cer"W Mail 0 Bpess Mail 0 Registered 0 Retum Receipt for Merchandise 0 Insured Mail 0 C.O.D. 2, Arlicis Number 7008 1140 0001 6165 2358 (ftma o sovw AoP _ Ps Form 3811, Februwy 2W4 Do WA* NAlufn 1M080 102595-02-M-1540 Respectfully Sub Adams, Esquire I.D No. 79465 1 West South St. arlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF cn ::z (??) ?BOM & LITLILAKIS Kara W. Haggerty, Esquire Attorney I.D. #: 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 WILLIAM L. FEUCHTENBERGER, Plaintiff V. CARLA A. FEUCHTENBERGER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 08-6129 CIVIL TERM CIVIL ACTION -LAW : IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE Please enter my appearance on behalf of the Defendant, Carla A. Feuchtenberger, in the above- captioned matter. Respectfully submitted, ABOM & KUTULAKIS, LLP . I Date: 0 jb2_jDj LCD ' Kara W. Haggerty, Es u!M 36 South Hanover Stre Carlisle, PA 17013 (717) 249-0900 ID #86914 CERTIFICATE OF SERVICE AND NOW, this 2- r) day of January, 2009, I, Kara W. Haggerty, Esquire of ABOM & KUTULAKIS, LLP, hereby certify that I did serve or cause to be served a true and correct copy of the foregoing Entry of Appearance by First Class U.S. Mail addressed to the following: Jane Adams, Esquire 17 West South Street Carlisle, PA 17013 k wv1 c ?W' Kara W. Haggerty, Es , } t: . ? .-, = ?i r z `? ?- '? ? 4 { ,? . ?'? ?,a ?Wt WILLIAM L. FEUCHTENBERGER, Plaintiff vs. CARLA A. FEUCHTENBERGER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 08 - 6129 Civil Term ACTION IN CUSTODY/DIVORCE CUSTODY COMPLAINT 1. Plaintiff is William L. Feuchtenberger, who currently resides at 131 Beetem Hollow Road, Newville, Cumberland County, Pennsylvania, 17241. 2. Defendant is Carla A. Feuchtenberger, whose current address is: 139 Virginia Ave., Carlisle, Pa. 17013. 3. Plaintiff is the Father of the following children and seeks a custody order regarding the following children: NAME DOB/AGE ADDRESS Garrett Feuchtenberger 1/23/92 (16) 131 Beetem Hollow Road Newville, Pa. 17241. Travis Feuchtenberger 5/3/97 (11) 131 Beetem Hollow Road Newville, Pa. 17241. Mother and Father were married on August 24, 1991. They separated on December 31, 2008 and a divorce is pending under the above-captioned docket number. Father currently has primary physical custody of the children. During the past five years, the child has resided with the following persons and at the following addresses: NAME William Feuchtenberger ADDRESSES 131 Beetem Hollow Rd Newville, Pa. 17241 DATES 12/31/08 - present William Feuchtenberger 131 Beetem Hollow Rd. 2003 - 12/31/08 Carla A. Feuchtenberger Newville, Pa. 17241 The mother of the children is Carla A. Feuchtenberger. She currently resides at: 139 Virginia Ave., Carlisle, Pa. 17013. She is married to William L. Feuchtenberger. The father of the children is William L. Feuchtenberger. He currently resides at 131 Beetem Hollow Road, Newville, Pa. 17241. He is married to Carla A. Feuchtenberger. 4. The relationship of plaintiff to the children is that of Father. The plaintiff currently resides with the children. 5. The relationship of defendant to the children is that of Mother. The defendant currently lives with her boyfriend. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: The parties separated on December 31, 2001 when Mother left the marital home. Father remained in the marital home with the children. Father is seeking a custody Order which confirms that he retains primary physical custody provide the parties with shared legal custody and provides Mother with periods of partial physical custody This request is the m the best interest of the children because it would provide stability for the children and ensure contact with both parents 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children has been named as parties to this action. WHEREFORE, Plaintiff requests the court to enter a custody order regarding the children. Respectfully submitted, oar a?jo/9 J e Adams`, Esquire " No. 79465 7 W. South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF VERIFICATION I verify that the statements made in this Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: ?- 1 6 William L. Feuchtenberger, Iintiff 9 ,.... C J rri Y"?. l:,,a WILLIAM L. FEUCHTENBERGER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. CARLA A. FEUCHTENBERGER DF,FENDANT 2008-6129 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, February 17, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at_4th Floor, Cumberland County Courthouse, Carlisle on Monday, March 16, 2009 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: ls/ ac ueline M, Verne Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 r,a;Z S MAR 1.8 2oN c4 WILLIAM L. FEUCHTENBERGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2008-6129 CIVIL ACTION - LAW CARLA A. FEUCHTENBERGER, : Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 1 R day of M o& 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, William L. Feuchtenberger and the Mother, Carla A. Feuchtenberger, shall have shared legal custody of Garrett Feuchtenberger, born January 23, 1992 and Travis Feuchtenberger, born May 3, 1997. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to medical, dental, religious or school records, the residence address of the children and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor children. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 2. Father shall have primary physical custody of the children. Mother shall have the following periods of partial physical custody of the children: A. Beginning March 20, 2009, alternating weekends from Friday at 4:30 p.m. to Sunday at 7:00 p.m. In the event that the children have a school holiday on the Monday after Mother's weekend, then Mother's weekend shall be extended to Monday at 7:00 p.m. B. Every Tuesday and Thursday from 4:30 p.m. to 8:00 p.m. C. In the event that Father is away from home overnight, then Mother shall have physical custody of the children. D. Such other times as the parties agree. 4. The parties shall have liberal telephone contact with the children. 5. Easter shall be shared as agreed by the parties. 6. Transportation shall be shared such that the receiving party shall transport. 7. Neither party may say or do anything or permit a third party from saying or doing anything that may estrange the children from the other parry, or injure the opinion of the children as to the other party, or may hamper the free and natural development of the children's love and affection for the other parry. 8. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Another Custody Conciliation Conference is scheduled for May 18, 2009 at 8:30 a.m. BY THE COURT, 3. c:tara a Adams, Esquire, Counsel for Father W. Haggerty, Esquire, Counsel for Mother 4 R??'? ?3, t'? ? ? ?.:?'??? ?tiii? ? '? ?, ? ' ? ? ?? ? ? ??? U?1?Z ?? ? ?J MAR 18 2009 WILLIAM L. FEUCHTENBERGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2008-6129 CIVIL ACTION - LAW CARLA A. FEUCHTENBERGER, Defendant : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Garrett Feuchtenberger January 23, 1992 Father Travis Feuchtenberger May 3, 1997 Father 2. A Conciliation Conference was held in this matter on March 16, 2009, with the following in attendance: The Father, William L. Feuchtenberger, with his counsel, Jane Adams, Esquire, and the Mother, Carla A. Feuchtenberger, with her counsel, Kara W. Haggerty, Esquire. 3. The parties agreed to an Order in the form as attached. Date acq line M. Verney, Esquire Custody Conciliator MAY. 18 20090 L. FEUCHTENBERGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2008-6129 CIVIL ACTION - LAW A. FEUCHTENBERGER, . Defendant : IN CUSTODY ORDER OF COURT AND NOW, this o)il day of _, 2009, upon :ration of the attached Custody Conciliatio eport, it is ordered and directed as 1. A Hearing is scheduled in Court Room No._, of the Cumberland Count Court House, on the day of , 2009, at J_15,D- 0'cloc , M., at which time testimony will be t cen. For purposes of this Hearing, the Fat ei shall be deemed to be the moving party and shall proceed initially with testim ny. Counsel for each party shall file with the Court and opposing counsel a Memo andum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least five days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the prior Order of Co dated March 19, 2009 shall remain in full force and effect with the following 3. The parties shall cooperate with therapeutic family counseling provided it is reas ably priced or covered by insurance. Beginning the first Sunday after the last day of school, the physical custody arrangement shall be week on/week off, with Sunday at 7:00 p.m. being the time and day of the exchange. Mother shall have the first week. the The parties may modify the provisions of this Order by mutual consent. In of mutual consent, the terms of this Order shall control. BY THE COURT, Zytt J?, U) - M.L. Ebert, Jr., J. cc: e Adams, Esquire, counsel for Father Kara W. Haggerty, Esquire, counsel for Mother G-5 IEs /?2-V t LCL G aI a-woo q 1 •6 tiv ! z AN 60oz L. FEUCHTENBERGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2008-6129 A. FEUCHTENBERGER, . Defendant : IN CUSTODY JUDGE: M.L. Ebert, Jr., J. CIVIL ACTION - LAW CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this liti ation is as follows: DATE OF BIRTH CURRENTLY IN CUSTODY OF Garrett?Feuchtenberger January 23, 1992 Father Travis euchtenberger May 3, 1997 Father 2. A Conciliation Conference was held May 18, 2009 with the following individuals in attendance: The Father, William L. Feuchtenberger, with his counsel, Jane Adams Esquire, and the Mother, Carla A. Feuchtenberger, with her counsel, Kara W. Haggerty, Esquire. The Honorable M.L. Ebert, Jr. previously entered an Order of Court dated March 9, 2009 providing for shared legal custody, Father having primary physical custody and Mother having alternating weekends, Friday to Sunday and every Tuesday and Thursday from 4:30 p.m. to 8:00 p.m. Father's position on custody is as follows: Father seeks shared legal and primary physical custody. Mother has requested the summer schedule be week on/week off. Fa her opposes this suggestion, asserting that it would be disruptive to the children. Father ,will cooperate with co-parenting counseling if it is reasonably priced or covered by insurance. Mother's position on custody is as follows: Mother seeks shared legal custody with Father having primary physical custody during the school year, but requests week o week off during the summer. Mother proposed co-parenting counseling. 6. The Conciliator recommends an Order in the form as attached scheduling a He ing and changing the summer schedule to week on/week off. It is expected that the Hearing will require one-half day. i k Date jj=' ine M. Verney, Esquire Custody Conciliator I i I r; OM & &U ULAKIS Kara W. Haggerty, Esquire attorney I.D. #: 86914 2 West High Street Carlisle, PA 17013 (717) 249-0900 WILLIAM L. FEUCHTENBERGER, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. 08-6129 CIVIL TERM CIVIL ACTION -LAW CARLA A. FEUCHTENBERGER, . Defendant : IN CUSTODY MOTION TO CONTINUE HEARING AND NOW, this 215` day of August, 2009, comes the Defendant, by and through her attorney, Kara W. Haggerty, Esquire, of ABOM & KUTULAKIS, L.L.P., who files this Motion to Continue Hearing and, in support thereof, avers as follows: 1. A Custody hearing is scheduled in the above-referenced matter for August 27, 2009 at 1:30 p.m. in Courtroom No. 5 of the Cumberland County Courthouse. 2. The Order scheduling the above-referenced hearing also provided a provision that the parties cooperate with therapeutic family counseling. 3. To date, the parties have not enrolled in therapeutic family counseling, but would like to have the opportunity to attend prior to having a custody hearing in this matter. 4. A continuance is requested to allow the parties the opportunity and time to enroll and participate in therapeutic family counseling. 5. Undersigned counsel contacted Plaintiff s attorney, Jane Adams, Esquire, who concurs with the continuance of this hearing. 6. Defendant, through her counsel, requests that This Honorable Court reschedule the hearing for the next available court date. [THEREFORE, the Defendant's attorney, Kara W. Haggerty, requests that This Honorable Court grant a continuance for the hearing scheduled in the above- referenced matter. DATE Z t C Respectfully submitted, ABom&KUTULA s, L.L.P. Kara W. Haggerty, s e Attorney ID No. 86 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney for Defendant CERTIFICATE OF SERVICE AND NOW, this 21`t day of August, 2009, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Motion to Continue Hearing, upon the Plaintiff by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Jane Adams, Esquire 17 West South Street Carlisle, PA 17013 Respectfully submitted, Abom & Kutulalas, L.L.P. Kara W. Haggerty, Attorney ID No. 81 2 West High Street Carlisle, PA 17013 (717) 249-0900 f i?4.1•/?1.i i???r?6.. OF TH R 0TF 'V-, 0-TA,RY 2009 AUGJ 2! 1 F 1 2. 5 Cuts 1 ?+ ui CY WILLIAM L. FEUCHTENBERGER, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. 08-6129 CIVIL TERM CIVIL ACTION - LAW CARLA A. FEUCHTENBERGER, . Defendant : IN CUSTODY ORDER OF COURT AND NOW, this c W'?'-day of 2009, the Hearing presently scheduled for August 27, 2009, is hereby continued. The matter is - L511--day of 2009, at rescheduled to be heard on the o a2-.m. in Courtroom No. '-? of the Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court: M? cI p M.L. Ebert, Jr., J. ra W. Haggerty, Esquire, Counsel for the Plaintiff Jane Adams, Esquire, Counsel for the Defendant (26P 1'e-9 rylatc FILE:C-_ -=i 1F OF THC i ,-. CTARY 2009 AUG 2b AM 9: 02 r l`J ?;S` lLvAio T OM CSC Nu UL.AKIS Kara W. Haggerty, Esquire Attorney I.D. #: 86914 2 West High Street Carlisle, PA 17013 (717) 249-0900 WILLIAM L. FEUCHTENBERGER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PA V. NO. 08-6129 CIVIL TERM CIVIL ACTION -LAW CARLA A. FEUCHTENBERGER, Defendant IN CUSTODY MOTION TO CONTINUE HEARING AND NOW, this 4' day of November, 2009, comes the Defendant, by and through her attorney, Kara W. Haggerty, Esquire, of ABOM & KUTULAKIS, L.L.P., who files this Motion to Continue Hearing and, in support thereof, avers as follows: 1. A Custody hearing is scheduled in the above-referenced matter for November 25, 2009 at 2:30 p.m. in Courtroom No. 5 of the Cumberland County Courthouse. 2. The prior Order scheduling the above-referenced hearing also provided a provision that the parties cooperate with therapeutic family counseling. 3. The parties have made contact with a service provider for therapeutic family counseling, but due to waiting lists have not yet attended any sessions. 4. The parties would like to have the opportunity to attend their co- parenting counseling prior to having a custody hearing in this matter. 5. A continuance is requested to allow the parties the opportunity and time to participate in therapeutic family counseling. 6. Undersigned counsel contacted Plaintiff s attorney, Jane Adams, Esquire, who concurs with the continuance of this hearing. 7. Defendant, through her counsel, requests that This Honorable Court reschedule the hearing for the next available court date. [THEREFORE, the Defendant's attorney, Kara W. Haggerty, requests that This Honorable Court grant a continuance for the hearing scheduled in the above- referenced matter. DATE I o- o Respectfully submitted, AaOM & KUTUTLA"S, L.L.P. Kara W. Haggerty, Es e Attorney ID No. 8 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney for Defendant CERTIFICATE OF SERVICE AND NOW, this 4`h day of November, 2009, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Motion to Continue Hearing, upon the Plaintiff by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Jane Adams, Esquire 17 West South Street Carlisle, PA 17013 Respectfully submitted, Abom & Kutulk&(s, L.L.P. 10. Lowe( Kara W. Haggerty, s e Attorney ID No. 8 2 West High Street Carlisle, PA 17013 (717) 249-0900 FILED- : i-CE THE -,, ?.. OF TNc F?E,,_,T -: rC.NOTARY 2009 NOV -4 Pit 4: CO J NOV 0 5 2009 WILLIAM L. FEUCHTENBERGER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PA V. NO. 08-6129 CIVIL TERM CIVIL ACTION - LAW CARLA A. FEUCHTENBERGER, . Defendant : IN CUSTODY ORDER OF COURT AND IVOi, this ` day of 2009, the Hearing presently scheduled for November 25, 2009, is hereby continued. The matter is rescheduled to be heard on the aZ"'S day of Az-'-C'` , 2010 , at q?in Courtroom No. 0- of the Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court: ?k -?' ?a A\ M.L. Ebert, Jr., J. t./ara W. Haggerty, Esquire, Counsel for the Plaintiff ,?'ane Adams, Esquire, Counsel for the Defendant 2009 N01V -9 P?, 3, 3 1 CL`s;' Flt.Et)-i:: i-i E THE P€ ?`Ti?-" ! )T'*y 2010 FEB 1 I Aft 8, 44 P. Richard Wagner, Esquire PA Supreme Court ID# 23103 Mancke, Wagner & Spreha 2233 North Front Street Harrisburg, PA 17110 Telephone (717) 234-7051 Fax (717) 234-7080 Attorney for Plaintiff WILLIAM L. FEUCHTENBERGER, V. Plaintiff, CARLA A. FEUCHTENBERGER, Defendant. TO THE PROTHONOTARY: CW;J;.? NTY ?'vIW4 n; , : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO: 2008-6129 : CIVIL ACTION - LAW PRAECIPE Please withdraw the appearance of the undersigned as counsel for the Plaintiff, William L. Feuchtenberger, in the above-captioned action. Date: C? Je#?s? D ??. 17 W. South Street Carlisle, PA 17013 Please enter the appearance of the William L. Feuchtenberger, in the above-caption{ as counsel for the Plaintiff, Wagner, Esquire Harrisburg, PA 17110 (717) 234-7051 Date: d ?! I.D. #23103 2233 North Front Street WILLIAM L. FEUCHTENBERGER, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. CARLA A. FEUCHTENBERGER, : DEFENDANT : NO. 08-6129 CIVIL ORDER OF COURT AND NOW, this 18th day of February, 2010, upon consideration that the parties are to be in counseling, IT IS HEREBY ORDERED AND DIRECTED that the hearing scheduled for Tuesday, February 23, 2010, shall now be a status conference with counsel only. By the Court, ?o'u' M. L. Ebert, Jr., J. ? P. Richard Wagner, Esquire Counsel for Plaintiff Kara Haggerty, Esquire Counsel for Defendant bas ?V L-^ T ?. M WILLIAM L. FEUCHTENBERGER, PLAINTIFF V. CARLA A. FEUCHTENBERGER, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-6129 CIVIL ORDER OF COURT AND NOW, this 21St day of June, 2010, the Court being in a receipt of a report from Paul Clements, Counselor with Mock-Mays Associates, which indicates that no progress has been made regarding co-parenting, IT IS HEREBY ORDERED AND DIRECTED that a custody hearing in this matter will held on Wednesday, October 13, 2010, at 1:30 p.m. in Courtroom No. 2 of the Cumberland County Courthouse, Carlisle, Pennsylvania. IT IS FURTHER ORDERED AND DIRECTED that pending further Order of Court, this Court's previous Order of March 19, 2009, will remain in effect. By the Court, ? P. Richard Wagner, Esquire Counsel for Plaintiff Kara Haggerty, Esquire Counsel for Defendant bas LL M. L. Ebert, Jr., J. c o ? f K d cn ,?: -S cv tv r Cj b``) _ o WILLIAM L. FEUCHTENBERGER, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. CARLA A. FEUCHTENBERGER, : DEFENDANT : NO. 08-6129 CIVIL ORDER OF COURT AND NOW, this 12th day of October, 2010, pursuant to the agreement of the parties that they are satisfied with the current custody status, IT IS HEREBY ORDERED AND DIRECTED that the custody hearing set for Wednesday, October 13, 2010, is CANCELLED. P. Richard Wagner, Esquire Counsel for Plaintiff ?ra Haggerty, Esquire Counsel for Defendant bas P ?"rY1 By the Court, M. L. Ebert, Jr., J. 73 M :7- .F WILLIAM L. FEUCHTENBERGER : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTS PFNNS7YLVANIA C: CIVIL ACTION - LAW -'a,= C= V. ? rco --r o f ; NO. 08-6129 CIVIL TE? ?c N r -` CARLA A. FEUCHTENBERGER Defendant : IN DIVORCE iG 3 - ' PRAECIPE FOR WITHDRAWAL OF CON L TO THE PROTHONOTARY: Please enter the withdrawal of the undersigned as counsel for Defendant in the above-captioned matter. Date: 47 ? .20(( 14,11 Lot, U Kara W. Haggerty, Supreme Court No? Abom & Kutulakis, LLP 2 West High Street Carlisle, Pennsylvania 17013 Telephone: 717-249-0900 PRAECIPE FOR APPEARANCE OF COUNSEL TO THE PROTHONOTARY: Please enter the appearance of the undersigned on behalf of Defendant in the WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 above-captioned matter. Date: 11-21--11?_? f Wayne . Shade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 WILLIAM L. FEUCHTENBERGER : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW V. NO. 08-6129 CIVIL TERM CARLA A. MINICH, formerly CARLA A. FEUCHTENBERGER Defendant : IN DIVORCE ORDER OF COURT t?? AND NOW, this Q day of January, 2012, upon consideration of the within Petition, it is hereby ordered, as follows: (1) A Rule is issued upon Husband to show cause why this Petition to Compel Discovery should not be granted and Husband be ordered to file his Answers to Wife's written discovery or suffer sanctions; (2) Husband shall file an Answer to the Petition within *kO days of the date of service of this Order; and (3) Argument shall be held thereon on j" , WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 2012, at JIr?UD o'clockA_.M. in Court oo N07, - , G _a `c3 Yj?' Cumberland County Courthouse, Carlisle, Pennsylvania. rnx ?P• ? N By the Court, -,- -, ? ? A C) "'ra v c-) _ 2 C CD ... ?p f M. L. Ebert, Jr., J. F Y P. Richard Wagner, Esquire Mancke, Wagner & Spreha Attorneys for Plaintiff Wayne F. Shade, Esquire Attorney for Defendant 'p es ?a • /eW /1?31/,? AW. WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 WILLIAM L. FEUCHTENBERGER, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. CARLA A. MINICH, FORMERLY r-rj CARLA A. FEUCHTENBERGER,`t DEFENDANT NO. 08-6129 CIVIL; - ,, IN RE: WIFE'S PETITION FOR BIFURCATION ORDER OF COURT AND NOW, this 2"d day of February, 2012, upon consideration of Wife's Petition for Bifurcation, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule shall be issued upon William Feuchtenberger to show cause why the relief requested should not be granted; 2. William Feuchtenberger will file and Answer to the Petition on or before February 24, 2012; 3. Briefs supporting each party's position will be filed on or before March 23, 2012; 4. Argument on the matter will be held on Thursday, April 12, 2012, at 11:00 a.m. in Courtroom No. 2 of the Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, ,A --i ?jl I , M. L. Ebert, Jr., J. P. Richard Wagner, Esquire Attorney for Plaintiff v Wayne F. Shade, Esquire Attorney for Defendant bas ?' ?'S rx c? l ( &72 l: iLED_OFt" ivy:. OF THE PROTNONOT +RY 2612 FEB 14 PM 4= 04 O PNN Y VAN A TY WILLIAM L. FEUCHTENBERGER :IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW V. NO. 08-6129 CIVIL TERM CARLA A. MINICH, formerly CARLA A. FEUCHTENBERGER Defendant :IN DIVORCE ANSWER TO WIFE'S PETITION TO COMPEL DISCOVERY AND NOW, comes the Plaintiff and files the following Answer: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Husband began working on answers to the Discovery and now has them complete as of the date of the filing of this Answer. 8. Admitted. Except that the Husband has been working on both the Production of Documents and the Interrogatories since the filing. 9. No answer is required. 10. Husband is not aware of any notification concerning the filing of this Motion. WHEREFORE, the Plaintiff requests the Court to dismiss the Rule as the answers have now been provided. Respectfully submitted, MANCKE, WAGNER & SPREHA P. Richard er, Esquire Supreme rt No. 23103 2233 N. Front Street Harrisburg, PA 17110 717-234-7051 Attorneys for Plaintiff Dated: ??`?/ j z. I , VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Date: 2 -"--1 - 1 Z FILED-OFF iCE OF THE PROTHONOTARY 2012 FEB 24 PM 12: 2 7 CUMBERLAND COUNTY PENNSYLVANIA WILLIAM L. FEUCHTENBERTER, :IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :CIVIL ACTION - LAW CARLA A. MINICH, formerly :NO. 08-6129 CIVIL TERM CARLA A. FEUCHTENBERGER Defendant :IN DIVORCE ANSWER TO WIFE'S PETITION FOR BIFURCATION AND NOW, comes the Plaintiff and files the following answer: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. The Plaintiff has filed the answers to the Discovery requested by the Defendant. 7. No copy of any 3301(d) affidavit was provided to Plaintiff. 8. Denied. It is denied that no prejudice would occur by bifurcating the divorce. 9. Admitted. 10. Admitted. 11. Denied. There is no need to have an argument on either petition in that discovery has now been completed and there is no right to have bifurcation of the . N - V . divorce. WHEREFORE, Plaintiff requests the Court to dismiss the Petition for Bifurcation. Respectfully submitted, MANC , WAGNER & WAGNER P. agner, Esquire I.D.# 23103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorney for Petitioner Dated: VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Date: WILLIAM L. FEUCHTENBERGER, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CARLA A. MINICH, FORMERLY CARLA A. FEUCHTENBERGER, DEFENDANT NO. 08-6129 CIVIL ORDER OF COURT AND NOW, this 12th day of April, 2012, after argument in the above captioned matter and the Court having determined that additional testimony will be required in order to render a proper decision regarding Defendant's Request for Bifurcation; IT IS HEREBY ORDERED AND DIRECTED that a hearing shall be held on Wednesday, May 23, 2012, at 2:00 p.m. in Courtroom No. 2 of the Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, \xc? M. L. Ebert, Jr., J. P. Richard Wagner, Esquire Attorney for Plaintiff -a 11 Wayne F. Shade, Esquire Attorney for Defendant bas eop'i 1-3 /'rta, ltA 1211L . , WILLIAM L. FEUCHTENBERGER, PLAINTIFF V. CARLA A. MINICH, FORMERLY CARLA A. FEUCHTENBERGER, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-6129 CIVIL ORDER OF COURT AND NOW, this 12th day of April, 2012, after argument, IT IS HEREBY ORDERED AND DIRECTED that Plaintiff will disclose the following information to Defendant within forty-five (45) days of the date of this Order: 1. A statement of Plaintiff's §401(k) defined contribution retirement plan as of the August 24, 1991, date of the marriage, to enable Defendant to calculate the marital portion of the account. 2. A copy of the pension plan booklet for Plaintiff's defined benefit retirement plan to enable Defendant to obtain an actuarial calculation of the lump sum date of distribution value of the coverture portion of the account. 3. An accounting of the funds in the Edward Jones investment account that is in Plaintiff's name and that Plaintiff maintains belongs to the boys, including, as to the funds that Plaintiff states belongs to the boys, the source of the funds, when they were deposited in the account, and documents establishing the ownership of the boys. 4. Copies of documents establishing the existence of Plaintiff's asserted $38,000 in marital credit card debt as of the date of separation. 5. Plaintiff's 2009 and 2011 federal income tax returns. . 6. Statements of the cash surrender values of Plaintiff's employee life insurance policy and Plaintiff's ING Life Insurance policy as of the December 31, 2008, date of separation or, if there are no cash values, written confirmation from the employer and ING Life Insurance Company that the policies do not have cash values. By the Court, i/ P. Richard Wagner, Esquire Attorney for Plaintiff ? Wayne F. Shade, Esquire Attorney for Defendant bas ODD" e5 hwjed N?l?lr a M. L. Ebert, Jr., Y? ? m t ?. N t: r r WILLIAM L. FEUCHTENBERGER : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVAN CIVIL ACTION -LAW V. c? ,? NO. 08-6129 CIVIL TERM CARLA A. MINICH, formerly er w cnr- CARLA A. FEUCHTENBERGER, Defendant : IN DIVORCE ?a 3 STIPULATION FOR BIFURCATION -< AND NOW, this .?3`?day of , 2012, come Plaintiff' WILLIAM L. FEUCHTENBERGER and Defendant CARLA A. MINICH, by and through their respective attorneys, P. Richard Wagner, Esquire, of Mancke, Wagner & Spreha and Wayne F. Shade, Esquire, and stipulate and agree to bifurcation of the abov captioned divorce proceedings, with preservation of the economic issues, upon the following terms and conditions: 1. This divorce action shall be bifurcated so that a divorce decree under § 33010 of the Divorce Code can be entered with reservation of jurisdiction over all claims by either party prior to the entry of said decree. 2. The parties agree that their marriage is irretrievably broken and that they been separated from marital cohabitation for more than two years. Upon entry of the Order bifurcating this divorce action, Defendant shall prepare and file all documents necessary to secure the entry of the bifurcated divorce decree. 3. The parties authorize the court to enter an Order incorporating the terms of thi c? Q, ..n Stipulation. r l 4. The court retains jurisdiction of any claims raised or to be raised by the to this action for which a final Order has not yet been entered, including, without limitation, claims for equitable distribution of marital property, spousal support, ali pendente lite, alimony, counsel fees, costs, and expenses. 5. In the event of the death of either party prior to the entry of a final Order resolving all of the economic claims herein, such claims shall be deemed to be in accordance with the provisions of 23 Pa.C.S. § 3323(d.1), and neither the surviving party nor the personal representative of the estate of the deceased party shall be prohibited from introducing any relevant and otherwise admissible evidence in support or in opposition to such claims by the provisions of the Dead Man's Act, 42 Pa.C.S. § 5930. 6. In the event of the death of either party hereto prior to resolution of the economic claims herein, this action for divorce shall continue as if both parties were surviving. The personal representative of the estate of the deceased spouse shall act on behalf of the estate in the divorce action until its conclusion. 7. Pending final economic resolution, neither party shall alienate, assign, convey, dissipate, encumber, hypothecate, pledge, secrete, transfer, or otherwise of any property, excluding only post-separation earnings from employment. 8. If either party remarries prior to the final economic resolution, the marrying party shall enter into a premarital agreement with his or her intended spouse in which intended spouse shall waive any and all rights to the property of the parties hereto. i 1 9. Prior to remarriage, either party shall enter into a written agreement with his her future spouse which preserves and protects any and all marital rights of the former spouse herein and under which the intended spouse shall waive any and all rights to property of the parties hereto. 10. All property of the parties hereto, including all real estate, shall be held in custodia degis after entry of the Divorce Decree until resolution of the economic issues Order of Court. Any entireties real estate shall be converted to and held by the parties tenants in common with no right of survivorship to the surviving party. 11. This Bifurcation Order of Court shall continue in full force and effect until further Order of Court or amended agreement in writing between the parties. 12. Within sixty (60) days of the date of this Order, all discovery in the divorce proceedings shall be complete. 13. With thirty (30) days of the date of this Order, the Faster shall be MANCKE, '4AGNER & SPREHA -W gner, Esquire for Plaintiff Waynef. Shade, Esquire Attorney for Defendant WILLIAM L. FEUCHTENBERGER : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW V. : NO. 08-6129 CIVIL TERM CARLA A. MINICH, formerly CARLA A. FEUCHTENBERGER, Defendant : IN DIVORCE ORDER OF COURT AND NOW, this 3 s? day of , 2012, upon consideration of the within Stipulation, it is hereby ordered and decreed that the terms of the within Stipulation for Bifurcation are incorporated herein by reference as though fully set forth and this case is hereby bifurcated. By the Court, ?? -A, qm\.- M.L. Ebert, Jr., J. P. Richard Wagner, Esquire Mancke, Wagner & Spreha Attorneys for Plaintiff ? Wayne F. Shade Esquire ro ^? Z_ -: , Attorney for Defendant WILLIAM L. FEUCHTENBERGER : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY , PENNSYLVAN , CIVIL ACTION -LAW V. NO. 08-6129 CIVIL TERM ' CARLA A. MINICH, formerly m ' CARLA A. FEUCHTENBERGER, G-, -, Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD v C-;, ?. . To the Prothonotary: - Y' Please transmit the record, together with the following information, to the for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under § 3301(d) of the Code. 2. The date and manner of service of the Complaint were October 21, 2008, by certified United States mail. 3. Date of execution of Defendant's Affidavit required by § 3301(d) of the Divorce Code was January 27, 2012, and the dates of service of the § 3301(d) upon Plaintiff were February 8, 2012, and, again, on April 12, 2012. 4. Related claims pending: All claims raised or to be raised in the Decree by parties to this action for which a final order has not yet been entered, including, wi limitation, claims for equitable distribution of marital property, spousal support, al pendente lite, alimony, counsel fees, costs, and expenses, in accordance with the Stipulation for Bifurcation of July 23, 2012, all of which is incorporated herein by reference as though fullyset forth. V I 5. Entry of a bifurcated Divorce Decree is stipulated by the parties in ¶ 2 of the Stipulation for Bifurcation of July 23, 2012. Date: August 3, 2012 Way T . Shade, Esquire Supreme Court I.D. # 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Defendant : IN THE COURT OF COMMON PLEA OF WILLIAM L. FEUCHTENBERGER : CUMBERLAND COUNTY, PENNSYL ANIA V. CARLA A. FEUCHTENBERGER NO. 08-6129 CIVIL TERM DIVORCE DECREE AND NOW, it is ordered and decreed WILLIAM L. FEUCHTENBERGER , plaintiff, and CARLA A. FEUCHTENBERGER , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this for which a final order has not yet been entered. Those claims are as follows: (If claims remain indicate "None.") The court retains jurisdiction of any claims raised or to be raised by the parties to this action for which a final order has not yet been entered, including, without limitation, claims for equitable distribution of marital property, spousal support, alimony pendente lite, alimony, counsel fees, costs, and expenses, in accordance with the Stipulation for Bifurcation of July 23, 2012, all of which is incorporated herein by reference as though fully set forth. By the Court, ?* I U, ( Aft st: J. 45rothonotary y doil Con ,at9' a ' ?l WILLIAM L. FEUCHTENBERGER : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. CARLA A. MINICH, formerly Plaintiff CARLA A. FEUCHTENBERGER : NO. 08-6129 2008 Defendant MOTION FOR APPOINTMENT OF MASTER WILLIAM L. FEUCHTENBERGER Plaintiff [3, moves the court to appoint a master with respect to the following claims: 0 Divorce ❑ Annulment 0 Alimony 0 Alimony Pendente Lite and in support of the motion states: 1. Discovery is complete as to the claims (s) for which the appointment of a master is requested. 2. The defendant has appeared in the action (personally) (by his attorney,_ Wayne F. Shade, Esq. ❑X Distribution of Property 0 Support ❑ Counsel Fees 0 Costs and Expenses 3. The staturory ground (s) for divorce are 3301(c) and 3301(d) 4. Delete the inapplicable paragraph (s): A BO C ❑ a. The action is not contested. b. An agreement has been reached with respect to the following claims: None C. The action is contested with respect to the following claims: equitable distribution 5. The action does not involve 6. The hearing is expected to take Ei complex issues of law or fact. 7. Additional information, if anv, relevant to the motion: Date: gi'6M AND NOW days , Esquire). C/) A orneyQ' Plaintiff Print Name ORDER APPOINTING MASTER , 20 , Esquire, is appointed master with respect to the following claims: By the Court, 7. WILLIAM L. FEUCHTENBERGER VS. CARLA A. MINICH, formerly Plaintiff CARLA A. FEUCHTENBERGER : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-6129 2008 Defendant MOTION FOR APPOINTMENT OF MASTER WILLIAM L. FEUCHTENBERGER Plaintiff EL moves the court to appoint a master with respect to the following claims: ❑ Divorce X❑ Distribution of Property ❑ Annulment ❑ Support ❑ Alimony ❑ Counsel Fees ❑ Alimony Pendente Lite ❑ Costs and Expenses and in support of the motion states: 1. Discovery is complete as to the claims (s) for which the appointment of a master is requested. 2. The defendant has appeared in the action (personally) (by his attorney,_ Wayne F. Shade, Esq. Esquire). 3. The staturory ground (s) for divorce are 3301(c) and 3301(d) 4. Delete the inapplicable paragraph (s): A ❑X B ❑X C ❑ a. The action is not contested. b. An agreement has been reached with resnect to the following claims: None c. The action is contested with respect to the following claims: equitable distribution 5. The action does not involve 6. The hearing is expected to take 0 complex issues of law or fact. 1 days 7. Additional information, if anv, relevant to the motion: Date: V)6//` CID rn A orney *. Plain Print Name ORDER APPOINTING MASTER AND NOW -C'I/w6tr z3 , 20 1 Y , is appointed master with respect to the following claims: isort- abe...4 C.-, 91 N A. f 'I-. C= 4' ---4 < N,) Esquire,