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HomeMy WebLinkAbout05-6056HEATHER R. MATTSON, Plaintiff V. TODD G. MATTSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. aS 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 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 Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, PA 17013. 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 LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notifcacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o propiedad u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAIL SERICIO, VAYA EN PERSONA O LLAMA POR TELEFONO A LA OFICINA CUYA DIRECION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 HEATHER R. MATTSON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. TODD G. MATTSON, l Defendant IN DIVORCE COMPLAINT COUNTI Divorce Under 3301(c) of the Divorce Code 1. Plaintiff is Heather R. Mattson who currently resides at 2016 Milltown Road, Camp Hill, Pennsylvania 17011. 2. Defendant is Todd G. Mattson who currently resides at Cumberland County Prison, 1101 Claremont Road, Carlisle, Pennsylvania . 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on August 28, 1999 in Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The grounds on which the action for divorce is based are: a. Section 3301(a)(3): Endangered the life or health of the injured and innocent spouse. b. Section 3301(a)(5): Expect that Defendant will be sentenced to imprisonment for a term of two or more years upon conviction of having committed a crime. C. Section 3301(a)(6): Offered such indignities to the innocent and injured spouse as to render that spouse's condition intolerable and life burdensome. d. Section 3301(c): The marriage of the parties is irretrievably broken. 7. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce under Sections 3301(a)(3)(5)(6) or 3301(c) of the Divorce Code. COUNT II EQUITABLE DISTRIBUTION 8. Plaintiff incorporates by reference paragraphs I through 7 of this Complaint. 9. Plaintiff and Defendant possess various items of personal marital property, as well as marital debts, which are subject to equitable distribution by this Court. WHEREFORE, Plaintiff requests your Honorable Court to equitably distribute all property, both real and personal, owned by the parties, as well as all marital debts. McNEES WALLACE & NURICK LLC By J. Pa H I. 531 100 Pi Street P.O. Harrisburg, PA 17108-1166 (717) 232-8000 (717) 237-5300 (fax) Attorneys for Plaintiff Dated: I I lc-?) I IOS 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 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. / "/") /,/-) " Z? - He theR. Mattson Dated: 11111; R O z O ,-? 0 c FJ a Z C C McNEES WALLACE & NURICK LLC By: J. Paul Helvy Attorney ID No. 53148 100 Pine Street Harrisburg, PA 17108-1166 (717) 232-8000 (717) 237-5300 facsimile ohelvy(5mwn.com Attorney for Plaintiff HEATHER R. MATTSON, Plaintiff V. TODD G. MATTSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-6056 CIVIL TERM IN DIVORCE AFFIDAVIT OF ACCEPTANCE OF SERVICE I, Todd G. Mattson, Defendant herein, do hereby swear and affirm that have I accepted service of a true and correct copy of the Complaint in Divorce in the above- captioned action on ?ec . Q , 2005. 'T cL Y? r ? Todd G. Mattson _? ;. ??,_ Heather R. Mattson vs Case No. t)5-6o56 Todd G. Mattson Statement of Intention to Proceed To the Court: Heather R. Mattson intends to proceed with the above captioned matter. Print Name J. Paul Helvy Sign Name Date:9 J2iloR Attorney for eather R. Mattson, Plaintiff Explanatory Co e t The Supreme Court of Pennsylvania has promulgated new Rule of Civil Procedure 230.2 governing the termination of inactive cases and amended Rule of Judicial Administration 1901. Two aspects of the recommendation merit comment. 1. Rule of civil Procedure New Rule of Civil Procedure 230.2 has been promulgated to govern the termination of inactive cases within the scope of the Pennsylvania Rules of Civil Procedure. The termination of these cases for inactivity was previously governed by Rule of Judicial Administration 1901 and local rules promulgated pursuant to it. New Rule 230.2 is tailored to the needs of civil actions. It provides a complete procedure and a uniform statewide practice, preempting local rules. This rule was promulgated in response to the decision of the Supreme Court in Shop v. Eagle, 551 Pa. 360,710 A.2d 1104 (1998) in which the court held that "prejudice to the defendant as a result of delay in prosecution is required before a case may be dismissed pursuant to local rules implementing Rule of Judicial Administration 1901." Rule of Judicial Administration 1901(b) has been amended to accommodate the new rule of civil procedure. The general policy of the prompt disposition of matters set forth in subdivision (a) of that rule continues to be applicable. II Inactive Cases The purpose of Rule 230.2 is to eliminate inactive cases from the judicial system. The process is initiated by the court. After giving notice of intent to terminate an action for inactivity, the course of the procedure is with the parties. If the parties do not wish to pursue the case, they will take no action and "the Prothonotary shall enter an order as of course terminating the matter with prejudice for failure to prosecute." If a party wishes to pursue the matter, he or she will file a notice of intention to proceed and the action shall continue. a. Where the action has been terminated If the action is terminated when a party believes that it should not have been terminated, that party may proceed under Rule230(d) for relief from the order of termination. An example of such an occurrence might be the termination of a viable action when the aggrieved party did not receive the notice of intent to terminate and thus did not timely file the notice of intention to proceed. The timing of the filing of the petition to reinstate the action is important. If the petition is filed within thirty days of the entry of the order of termination on the docket, subdivision (d)(2) provides that the court must grant the petition and reinstate the action. If the petition is filed later than the thirty-day period, subdivision (d)(3) requires that the plaintiff' must make a show in to the court that the petition was promptly filed and that there is a reasonable explanation or legitimate excuse both for the failure to file the notice of intention to proceed prior to the entry of the order of termination on the docket and for the failure to file the petition within the thirty-day period under subdivision (d)(2). 8. Where the action has not been terminated An action which has not been terminated but which continues upon the filing of a notice of intention to proceed may have been the subject of inordinate delay. In such an instance, the aggrieved party may pursue the remedy of a common law non pros which exits independently of termination under Rule 230.2. rl? j McNees Wallace & Nurick LLC By: J. Paul Helvy, Esquire Attorney I.D. No. 53148 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 (717) 237-5300 (fax) Phelvv _mwn.com Attorneys for Plaintiff HEATHER R. MATTSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. TODD G. MATTSON, Defendant NO. 05-6056 IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Heather R. Mattson, Plaintiff, moves the court to appoint a master with respect to the following claims: ( x) Divorce () Annulment () Alimony () Alimony Pendente Lite and in support of the motion states: (x) Distribution of Property () Support (x) Counsel Fees (x) Costs and Expenses (1) Discovery is complete as to the claim(s) for which the appointment of a master is requested. (2) The defendant has appeared in the action personally. (3) The statutory grounds for divorce are 3301(a)(3), (a)(5), (a)(6) and (c). (4) The action is contested with respect to the following claims: all claims. (5) The action does not involve complex issues of law or fact. (6) The hearing is expected to take 1 day. (7) Additional information, if any, relevant to the motion: None. Date: ? z I y (0 8' Jelvy lain ORDER APPOINTING MASTER And now 2008, appointed master with respect to the following claims: Esquire, is BY THE COURT: J. MOVING PARTY NAME: Heather R. Mattson ATTORNEY'S NAME: J. Paul Helvy, Esquire ATTORNEY'S ADDRESS: 100 Pine Street Harrisburg, PA 17101 ATTORNEY'S TELEPHONE NO.: 717-237-5343 ATTORNEY'S E-MAIL: phelvya-mwn.com NON-MOVING PARTY NAME: Todd G. Mattson ADDRESS: SCI-Fayette, Inmate #GT4928 50 Overlook Drive LaBelle, PA 15450-1050 Telephone: (724) 364-2200 CERTIFICATE OF SERVICE The undersigned hereby certifies that on theT day of ?PwbeC. 2008, a true and correct copy of the foregoing document was served by first-class mail, postage prepaid, upon the following: Todd G. Matson SCI-Fayette, Inmate #GT4928 50 Overlook Drive LaBelle, PA 15450-1050 ifer L. Kee ,,'Paralegal ) t (6) The hearing is expected to take 1 day. (7) Additional information, if any, relevant to the motion: None. Date: -%'I/ 't Jey lain ORDER APPOINTING MASTER And now 9 , 2008, (f 1641ftt Esquire, is appointed master with respect tolthe following claims: _A- 00, MOVING PARTY .,,?NAME: Heather R. Mattson ATTORNEY'S NAME: J. Paul Helvylll ATTORNEY'S ADDRESS: 100 Pine Street Harrisburg, PA 17101 ATTORNEY'S TELEPHONE NO.: 717-237-5343 ATTORNEY'S E-MAIL: phelvyCa-mwn.com B HE CO T- qt"" J. _WON-MOVING PARTY NAME: Todd G. Mattson Esquire ADDRESS: SCI-Fayette, Inmate #GT4928 50 Overlook Drive LaBelle, PA 15450-1050 Telephone: (724) 364-2200 Ca +?` cri µ OM & LITULAKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 HEATHER R. MATTSON, Plaintiff V. TODD G. MATTSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA : NO. 05-6056 : IN DIVORCE Please enter my appearance on behalf of the Defendant, Todd G. Mattson, in the above- captioned matter. Respectfully submitted, Date 1 ?2lq ABOM & KUTULAKIS, L.L.P. QO- si Michelle L. Sommrtreet 36 South Hanover Carlisle, PA 17013 (717) 249-0900 Attorney ID No. 93034 cis r•., - 1 CZ) ? ;Y) . J HEATHER R. MATTSON, Plaintiff V. TODD G. MATTSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 05-6056 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE MOTION FOR WRIT OF HABEAS CORPUS AND NOW, this 6"' day of October, 2009, Defendant Todd G. Mattson moves for a Writ of Habeas Corpus directing Brian V. Coleman, Superintendent of State Correctional Institute Fayette, to deliver TODD G. MATTSON, INMATE NO. GT4928, Defendant in the above-captioned matter, to the Sheriff's Department of Cumberland County, Pennsylvania, for the purpose of a Divorce Hearing on December 21, 2009 at 9:00 a.m. at the Cumberland County Courthouse, Courtroom No. 5, before Divorce Master E. Robert Elicker. Respectfully submitted, z ULAKrs, L.L.P. (k &ww:? Michelle L. So r, Esquire Supreme Court ID. 93034 2 West High Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Defendant HEATHER R. MATTSON, Plaintiff V. TODD G. MATTSON, Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 05-6056 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE WRIT OF HABEAS CORPUS To: Brian V. Coleman, Superintendent of State Correctional Institute Fayette By an Act of Assembly of 1785, we command you to have the body of TODD G. MATTSON, Defendant in the above-captioned matter, before Divorce Master E. Robert Elicker, at the Court of Common Pleas of Cumberland County, at the Courthouse, in Carlisle, Pennsylvania, on Monday, the 21`t day of December, 2009, at 9:00 a.m. in Courtroom No. 5. WITNESS, the Honorable , Judge of our said Court, at Carlisle, Pennsylvania, this day of , 2009. Curtis R Long, Prothontary, Civil Division By: Deputy CERTIFICATE OF SERVICE AND NOW, this 6th day of October, 2009, I, Michelle L. Sommer, Esquire, of ABOM dam' KUTULAKIS, L.-LP., hereby certify that I did serve a true and correct copy of the foregoing Motion for Writ of Habeas Corpus by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: J. Paul Helvy, Esquire McNees, Wallace & Nurick, L.L.C. 100 Pine Street P.O. Box 1166 Harrisburg, Pennsylvania 17108-1166 Attorney for Plaintiff E. Robert Elicker Office of Divorce Master Cumberland County Court of Common Pleas 9 North Hanover Street Carlisle, PA 17013 Cumberland County Divorce Master Respectfully submitted, BOM & KUTULAKnS L.L.P Michelle L. Somme, Esquire Supreme Court ID: 93034 2 West High Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Defendant E- LE rr OF TNc" 2609 OC T -6 PH 3: 52 r'k OCT 012009 HEATHER R. MATTSON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. 05-6056 CIVIL TERM TODD G. MATTSON, CIVIL ACTION - LAW Defendant IN DIVORCE ORDER OF COURT AND NOW, this I day of , 2009, it is hereby ORDERED and DIRECTED that the Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania issue a Writ of Habeas Corpus Ad Presquendum directing Brian V. Coleman, Superintendent of State Correctional Institute Fayette, to deliver the body of Defendant, Todd G. Mattson to the Sheriffs Department of Cumberland County, Pennsylvania for the purposes of a Divorce Hearing on December 21, 2009 at 9:00 a.m. at the Cumberland County Courthouse, Courtroom No. 5, before Divorce Master E. Robert Elicker. The Sheriffs Department of Cumberland County is hereby DIRECTED to serve the Writ of Habeas Corpus upon Brian V. Coleman, Superintendant of State Correctional Institute Fayette. For the purposes of the Defendant's release from State Correctional Institute Fayette and his return thereto following the disposition, unless otherwise ordered by this Honorable Court, this Order constitutes sufficient warrant. Distribution: ,,- J • Paul Helvy, Esquire, Attorney for Plaintiff McNees, Wallace & Nurick, L.L.C., 100 Pine Street, P.O. Box 1166, Harrisburg, PA 17108-1166 ? Michelle L. Sommer, Esquire, Attorney for Defendant Abom & Kutulakis, L.L.P., 2 West High Street, Carlisle, Pennsylvania 17013 Robert Elicker, Esquire, Cumberland County Divorce Master Cumberland County Court of Common Pleas 9 North Hanover Street Carlisle, PA 17013 Fs lU?SfUC? FIIFD-0, ,?CE OF THIE PP`)?"f- ` Nr-,TARY 2009 OCT -7 Pik ?- 28 n n in-r' u; 1T ,t HEATHER R. MATTSON, Plaintiff V. TODD G. MATTSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA : NO. 05-6056 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AND NOW, this 19t' day of November, 2009, Defendant Todd G. Mattson moves for a Writ of Habeas Corpus directing Brian V. Coleman, Superintendent of State Correctional Institute Fayette, to deliver TODD G. MATTSON, INMATE NO. GT4928, Defendant in the above-captioned matter, to the Sheriffs Department of Cumberland County, Pennsylvania, for the purpose of a Divorce Hearing on February 8, 2010, at 9:00 a.m. at the Cumberland County Courthouse, Courtroom No. 5, before Divorce Master E. Robert Elicker. This matter was rescheduled from the originally scheduled date of December 21, 2009 by Order of President Judge Edgar B. Bayley, dated November 17, 2009. (See Exhibit "A'? Respectfully submitted, ABOM & KUTUL4Kis, L.L.P. 1 U?tiO? Michelle L. Somm , Esquire Supreme Court ID. 93034 2 West High Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HEATHER R. MATTSON CIVIL ACTION - LAW V. 05 - 6056 NO. TODD G. MATTSON IN DIVORCE ORDER AND NOTICE SETTING HEARING Heather R. Mattson TO: J. Paul Helvy Todd G. Mattson Michelle L. Sommer , Plaintiff , Counsel for Plaintiff , Defendant , Counsel for Defendant You are directed to appear for a hearing to take testimony on the outstanding issues in the above captioned divorce proceedings at the-?P ^f *"° n ^?^P ?`'? ?tRth t*nth lleme; ,°- Street., Carlisle, Pennsylvania, on the February 2010 at 9:00 day of a.m., at which place and time you will be given the opportunity to present witnesses and exhibits in support of your case. By urt, C-'t ' 4 Edgar B. Bayley, President Ju e Date of Order anlAi 117109 Notice: By: 1. .: - Divorce Master IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET, CARLISLE, PA 17013 TELEPHONE (717) 249-3166 * HEARING WILL BE HELD IN JUDGE EBERT'S COURTROOM AT ONE COURTHOUSE SQUARE. EXHIBIT p N fil PD-OFFICE OF T F PPCTHIONDTARY 2009 NOV 19 P 3 51 CUVt?_ 'uINTY V HEATHER R. MATTSON, Plaintiff V. TODD G. MATTSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 05-6056 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE ORDER AND NOW, this T day of N , 2009, it is hereby ORDERED and DIRECTED that the Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania issue a Writ of Habeas Corpus Ad Presquendum directing Brian V. Coleman, Superintendent of State Correctional Institute Fayette, to deliver the body of Defendant, TODD G. MATTSON, INMATE NO. GT4928, to the Sheriffs Department of Cumberland County, Pennsylvania for the purposes of a Divorce Hearing on February 8, 2010, at 9:00 a.m. at the Cumberland County Courthouse, Courtroom No. 5, before Divorce Master E. Robert Elicker. This matter was rescheduled from the originally scheduled date of December 21, 2009, by Order of President Judge Edgar B. Bayley. The Sheriffs Department of Cumberland County is hereby DIRECTED to serve the Writ of Habeas Corpus upon Brian V. Coleman, Superintendent of State Correctional Institute Fayette. For the purposes of the Defendant's release from State Correctional Institute Fayette and his return thereto following the disposition, unless otherwise ordered by this Honorable Court, this Order constitutes sufficient warrant. J Distribution: J. Paul Helvy, Esquire, Attorney for Plaintiff McNees, Wallace & Nurick, L.L.C., 100 Pine Street, P.O. Box 1166, Harrisburg, PA 17108-1166 Michelle L. Sommer, Esquire, Attorney for Defendant Abom & Kutulakis, L.L.P., 2 West High Street, Carlisle, Pennsylvania 17013 E. Robert Elicker, Esquire, Cumberland County Divorce Master Cumberland County Court of Common Pleas 9 North Hanover Street Carlisle, PA 17013 n,,,? d 11-23 - 0Y FILL?L,-4 i # OF THE PR("Ji. 2009 NOY 23 Ali 9: 23 CtJM.a : Y PENNSYLVANIA HEATHER R. MATTSON, Plaintiff V. TODD G. MATTSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 05-6056 CIVIL TERN C ;' , CIVIL ACTION - LAW IN DIVORCE "OFT MOTION FOR WRIT OF HABEAS CORPUS u1 AND NOW, this 5`' day of March 2010, Defendant Todd G. Mattson moves for a Writ of Habeas Corpus directing Brian V. Coleman, Superintendent of State Correctional Institute Fayette, to deliver TODD G. MATTSON, INMATE NO. GT4928, Defendant in the above-captioned matter, to the Sheriff's Department of Cumberland County, Pennsylvania, for the purpose of a Divorce Hearing on May 10, 2010, at 9:00 a.m. at the Cumberland County Courthouse, Courtroom No. 2, before Divorce Master E. Robert Elicker. The Order and Notice Setting Hearing was issued by The Honorable Kevin A. Hess, President Judge, Cumberland County Court of Common Pleas, on February 19, 2010. (See Exhibit "A') Respectfully submitted, ABOM & KUTUL4Kis, L.L.P. r, um u9i ?-t - Michelle L. Somme ,Esquire Supreme Court ID. 93034 2 West High Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Defendant IN THE COURT OF COMMON PLEAS OF HEATHER R. MATTSON CUMBERLAI,,TD COUNTY, PENNSYLVANIA CIVIL ACTION -LAW V. 05 - 6056 NO. TODD G. MATTSON IN DIVORCE ORDER AND NOTICE SETTING HEARING Heather R. Mattson TO: , Plaintiff J. Paul Helvy Todd G. Mattson , Counsel for Plaintiff Defendant Michelle L. Sommer Counsel for Defen You are directed to appear for a hearing to take testimony on the outstanding issues in the above captioned divorce proceedings at the Office of the Divorce Master, 9 10th North Hanover Street, Carlisle, Pennsylvania, on the May 2010 at 9:00 day of a.m., at which place and time you will be given the opportunity to present witnesses and exhibits in support of your case. By the Court, Kevin A. Hess, President Judge Date of Order and Notice: 2/19/10 By: Divorce Master IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET, CARLISLE, PA 17013 TELEPHONE (717) 249-3166 ``HEARING WILL BE HELD D COUNTY COURTHOUSE, COURTROOM 42. EXHIBIT n ?? 131 A AND NOW, this 51h day of March, 2010, I, Michelle L. Sommer, Esquire, of ABOM & KUTULAKIS, LLP., hereby certify that I did serve a true and correct copy of the foregoing Motion for Writ of Habeas Corpus by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: J. Paul Helvy, Esquire McNees, Wallace & Nurick, L.L.C. 100 Pine Street P.O. Box 1166 Harrisburg, Pennsylvania 17108-1166 Attorney for Plaintiff E. Robert Elicker Office of Divorce Master Cumberland County Court of Common Pleas 9 North Hanover Street Carlisle, PA 17013 Cumberland County Divorce Master Ronny R. Anderson Cumberland County Sheriff 1 Courthouse Square Room 303 Carlisle, PA 17013 Respectfully submitted, 4BOM&KUTULAKI L.L.P Michelle L. Sommef, Esquire Supreme Court ID: 93034 2 West High Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Defendant HEATHER R. MATTSON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 05-6056 TODD G. MATTSON, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 28, 2005. 2. The marriage of the plaintiff and defendant is irretrievably broken. Ninety days have elapsed since the date of service of the Complaint. 3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Heather R. Mattson Date: N o o C9 FT? a? ? r-- cn `; :, r C3 <y CD 3 HEATHER R. MATTSON, Plaintiff V. TODD G. MATTSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-6056 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER Section 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. ?. 1 understand that i may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. He they R. Mattson Date: o C S o cn .. V, C L'' O & &U MOM LAKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 2 West High Street Carlisle, PA 17013 (717) 249-0900 HEATHER R. MATTSON, Plaintiff V. TODD G. MATTSON, Defendant FlLFD-Qri--ICE !)F iNE F30 i FPNOTARY 2010MAR -5 AM 11:23 - IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 05-6056 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under §3301(c) of the Divorce Code was filed on November 28, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of 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. §4904 relating to unsworn falsification to authorities. Date: O -J. TODD G. MATTSON T? OM CSC' &u i ULAKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 2 West High Street Carlisle, PA 17013 (717) 249-0900 HEATHER R. MATTSON, Plaintiff V. TODD G. MATTSON, Defendant {)F : Q N01\10T RY 2010 MAR -5 AM 11: 23 4f, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 05-6056 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE 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. §4904 relating to unsworn falsification to authorities. Date: -3 - ?;)Q/G ?0 . ?? TODD G. MATTSON V 10 MAR 0 8 2010 HEATHER R. MATTSON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. 05-6056 CIVIL TERM TODD G. MATTSON, CIVIL ACTION - LAW Defendant IN DIVORCE AND NOW, this day of/jAd2010, it is hereby ORDERED and DIRECTED that the Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania issue a Writ of Habeas Corpus Ad Presquendum directing Brian V. Coleman, Superintendent of State Correctional Institute Fayette, to deliver the body of Defendant, TODD G. MATTSON, INMATE NO. GT4928, to the Sheriff's Department of Cumberland County, Pennsylvania for the purposes of a Divorce Hearing on May 10, 2010, at 9:00 a.m. at the Cumberland County Courthouse, Courtroom No. 2, before Divorce Master E. Robert Elicker. 41" d-/*.. oA.,- "" 4aa4 ca. -?Ca -f-.,w?M? /?? _dw r,'p" iw tc c?rrd ?+.?. w' f4 d ?•ac c/+, The Sheriff's Department of Cumberland County is hereby DIRECTED to serve the Writ of Habeas Corpus upon Brian V. Coleman, Superintendanp of ?State'- Correctional Institute Fayette. ?rn 3a 4'_ V3 ? S'T°3 < co y For the purposes of the Defendant's release from State Correctional Institute Fayette and his return thereto following the disposition, unless otherwise ordered by this Honorable Court, this Order constitutes sufficient warrant. Distribution: /Paul Helvy, Esquire, Attorney for Plaintiff McNees, Wallace & Nurick, L.L.C., 100 Pine Street, P.O. Box 1166, Harrisburg, PA 17108-1166 Xchelle L. Sommer, Esquire, Attorney for Defendant Abom & Kutulakis, L.L.P., 2 West High Street, Carlisle, Pennsylvania 17013 /K Robert Elicker, Esquire, Cumberland County Divorce Master Cumberland County Court of Common Pleas 9 North Hanover Street 1 Carlisle, PA 17013 /#-onny R. Anderson, Cumberland County Sherii? 1 Courthouse Square Room 303 Carlisle, PA 17013 BY THE C(-)T TRT- IN THE COURT OF COMMONPLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Heather R. Mattson Plaintiff File No. 05-6056 VS. Todd G. Mattson Defendant WRIT OF HABEAS CORPUS To the Superintendent of State Correctional Institute Fayette By an Act of Assembly of 1785, we command you to deliver the body of Todd G. Mattson to the Sheriff Department of Cumberland County, Pennsylvania for the purpose of a Divorce Hearing before the Honorable Kevin A. Hess of the Court of Common Pleas Civil Division of said County, on May 10, 2010 at 9:00 O'clock AM, in Courtroom Number 4, at the Courthouse in the Borough of Carlisle. WITNESS THE HONORABLE KEVIN A. HESS, PRESIDENT JUDGE of our said Court, at Carlisle, the 10th day of May A.D. 2010. Q AV-ut L 41?A - - David D. Buell, P THONOTARY ? d ^A A & "Ikl A D PUTY HEATHER R. MATTSON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA ' n V. NO. 05-6056 o `n TODD G. MATTSON, r Defendant IN DIVORCE v, C AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 28, 2005. 2. The marriage of the plaintiff and defendant is irretrievably broken. Ninety days have elapsed since the date of service of the Complaint. 3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Heather R. Mattson Date: i/ HEATHER R. MATTSON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYG/AMA V. : NO. 05-6056 TODD G. MATTSON, Defendant : IN DIVORCE co WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER Section 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of 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 I do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. H ater R. Mattson '- sate: °? °/U HEATHER R. MATTSON, Plaintiff vs. TODD G. MATTSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0. 05 - 6056 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this ~~ ~ day of , 2010, counsel and the parties having entered into an agreement and stipulation resolving the economic issues on May 10, 2010, the date set for a Master's hearing with counsel and the parties, the agreement and stipulation having been transcribed, and agreed to on the record by the parties, the appointment of the Master is vacated and counsel can conclude the proceedings by the filing of a praecipe to transmit the record with the affidavits of consent of the parties so that a final decree in divorce can be entered. BY THE COURT, Kev' A. Hess, P.J. ~-.' H9 cc: ~J. Paul Helvy c.-. ~ `T; Attorney for Plaintiff -..~:=-~:--. --' '. f~ C ~~ V Michelle L. Sommer _.~l -- Attorney for Defendant - r (.~p;es ~a.led ~l~~f~o E_~ ;._ .,. =::~ ,°- ~~~ HEATHER R. MATTSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS NO. 05-6056 CIVIL TERM TODD G. MATTSON, Defendant IN DIVORCE THE MASTER: Today is Monday, May 10, 2010. This is the date set for a hearing in the above-captioned divorce proceedings. Present in the hearing room are the Plaintiff, Heather R. Mattson, and her counsel J. Paul Helvy, and the Defendant, Todd Mattson, and his counsel Michelle R. Sommer. This action was commenced by the filing of a complaint in divorce on November 28, 2005. The complaint raised grounds for divorce of irretrievable breakdown of the marriage, imprisonment for a term in excess of 2 years, and indignities. With respect to the grounds for divorce, we are going to proceed under Section 3301 (c) of the Domestic Relations Code. Both parties have signed affidavits of consent and waivers of notice of intention to request entry of divorce decree. Heather Mattson's affidavit and waiver were signed on March 10, 2010, and filed with the Prothonotary on March 16, 2010. Husband's affidavit and waiver were signed on March 2, 2010, and filed with the Prothonotary on March 5, 2010. As noted, the divorce can, therefore, conclude under Section 3301(c) of the Domestic 1 Relations Code. The complaint also raised the claim for equitable distribution. After negotiations today and previously over the matters relating to the distribution of the marital estate, the Master has been advised that counsel and the parties have reached an agreement which is going to be placed on the record. The agreement as placed on the record will be considered the substantive agreement of the parties not subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. The agreement is going to be transcribed and sent to counsel for review or correction of typographical errors, if any, and then the parties and counsel will be asked to sign the agreement affirming the terms of settlement as stated on the record. It is understood that when the parties leave the hearing room today they are bound by the terms of the agreement as stated on the record even though there was no subsequent signing of the agreement affirming the terms of settlement. Upon receipt by the Master of a completed agreement, the Master will prepare an order vacating his appointment and counsel can then file a praecipe transmitting the record to the Court requesting a final decree in divorce. 2 The Master understands that there may be an issue remaining with respect to tangible personal property. Mr. Helvy and Ms. Sommer have reached an understanding with regard to how that is going to be dealt with as far as the transfer of property and identification of items of property which may require at some point another hearing. The Master understands that counsel can at that point ask that the Master be reinstated and appointed to specifically hear testimony on the disposition of the tangible personal property. The parties were married August 28, 1999, and separated October 12th, 2005. The parties are the natural parents of one minor child that is currently in the custody of wife. There is an understanding that the agreement that is going to be sent to counsel to review and after correction of typographical errors, if any, will be returned to the Master signed by the parties within 60 days of the Master sending the agreement. If the agreement has not been returned within 60 days signed by parties, the Master will then simply proceed to ask that his appointment be vacated and that counsel then can ask the Court by praecipe to enter a final decree in divorce. As indicated, there is no necessity that the parties sign the agreement, but I do like to have them review it and have them affirm the terms if we 3 can get them to do that before we send it to the Court. Is that all right, Mr. Helvy? MR. HELVY: Yes, sir. THE MASTER: Ms. Sommer, you okay with that? MS. SOMMER: That's fine. THE MASTER: Mr. Helvy? MR. HELVY: I will endeavor to put the agreement on the record. THE MASTER: All right. MR. HELVY: 1. The parties' marital residence located at 2016 Milltown Road, Camp Hill, Pennsylvania, which is currently titled in joint names, shall become the property of wife. There is a mortgage encumbering that property which wife shall within 90 days of today's date either refinance or satisfy in order to remove husband's name. At the time of refinancing, wife shall pay $7,500 in cash to husband. With regard to the deed to the marital residence,' within 21 days of receipt by husband's attorney of a deed transferring title to the house from joint names to wife's name alone, husband will execute this deed, have the signature notarized, and return it to wife's counsel who will hold said deed in escrow pending refinancing. 2. Wife's 401 (k) plan which she acquired as a result of her employment during the course of the marriage shall be wife's and husband shall waive any claim to said asset. 3. Husband's Smith Barney IRA which was accumulated during the course of the marriage shall be husband's, and wife shall waive any claim to that asset. 4. the parties shall possession of the accounts. 5. shall deliver to Camry. Any and all other bank accounts owned by be from this point forward the sole party who is the titled owner of said bank Within 30 days of today's date, wife '~usband's parents husband's 1998 Toyota 6. Except for the mortgage previously 4 discussed, any debt incurred by the parties shall be responsibility of the party incurring said debt. It is specifically understood that wife has assumed responsibility in excess of $11,500 for marital debt that was incurred during the course of the marriage, and she shall continue to bear the sole responsibility for that debt. This was one of the factors that was taken into consideration in determining the ultimate resolution of the marital estate. 7. With regard to personal property it is understood that there are certain items of personal property that continue to be located in the marital residence located at 2016 Milltown Road, Camp Hill, Pennsylvania. Within 60 days of husband's attorney providing wife's attorney the name and contact information of a professional bonded mover, wife shall schedule a time with said mover to come to the house to remove those items of personal property contained on husband's personal property list that are acceptable to wife. Within 60 days of the date the mover comes to the house, husband or his designee shall have the right to specifically identify the property that is in dispute (which he feels he is entitled to from the marital residence) and to request the reappointment of the Master to hold a hearing regarding the distribution of the items of personal property that have been identified as being in dispute. 8. Note that there is a pending agreement regarding the possession of certain nonmarital guns. 9. Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all right he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship including without limitation statutory allowance, widow's allowance, right of intestacy, right to take against the with of the other, and the right to act as administrator or executor in the other's estate. Each will at the request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interest, rights, and claims. MR. HELVY: Ms. Mattson, have you had the opportunity to listen to me place the agreement on the record? 5 MS. MATTSON: Yes. MR. HELVY: And do you understand that agreement? MS. MATTSON: Yes. MR. HELVY: And is the agreement that we placed on the record today acceptable to you? MS. MATTSON: Yes. MS. SOMMER: Mr. Mattson, have you heard the record that Mr. Helvy has read and placed on record today? MR. MATTSON: Yes. MS. SOMMER: Do you understand the record that was placed on the record? MR. MATTSON: Yes, I do. THE MASTER: And you're satisfied to have this entered as a final agreement with respect to all of the issues identified in this case? MR. MATTSON: Yes. THE MASTER: With the understanding that there is still some pending inquires that may be made regarding the tangible personal property. MR. MATTSON: Correct. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to 6 the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations Code. WITNESS: J. Paul Helvy Attorney for Plaintiff Michelle R. Sommer Attorney for Defendant DATE: Heather R. Mattson Todd G. Mattson 7 HEATHER RAE MATTSON :IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. NO. 05-6056 CIVIL TODD GREGORY MATTSON, Defendant IN CUSTODY IN RE: PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS ORDER AND NOW, this ?'' day of December, 2010, there being no right to the appointment of counsel in this matter and the defendant, in any event, having failed to attach any proposed pleading in the captioned divorce matter, the petition for leave to proceed in forma pauperis is DENIED. BY THE COURT, J. Paul He1vy, Esquire For the Plaintiff ?dd Mattson GT4928 SCI Fayette P. O. Box 9999 LaBelle, PA 15450-0999 Defendant :rlm (2oa c cx m2 LLE4" i -J-f-V i V Hess, J. ? p r -y C Z < °- 7)0 ^ m o C:) -, , C:) C:) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION HEATHER R. MATTSON . IN DIVORCE VS. CASE NO. 05-5056 TODD G. MATTSON MOTION FOR REAPPOINTMENT OF MASTER Defendant, Todd G. Mattson, moves this Court to reappoint a Master with respect to the following blaims of unresolved property and in support of his motion states: 1. On May 14th, 2010, a hearing was held with Divorce Master E. Robert Elicker II Esq.. 2. There are several items in dispute that have not been returned or compensated for, from the plaintiff. 3. Defendant requested his attorney, Michelle Sommer, to motion the Court for a hearing with the Divorce Master, to resolve above stated remaining issues. 4. Counsel failed-to comply to said request by Defendant, which was done in the allotted time given. 5. Divorce Master was subsequently terminated by this Court. Wherefore, Defendant, Todd G. Mattson, respectfully requests that this Court re-appoint the Master with respect to his claims for unresolved marital equitable distribution of property. ?1" %]& % 4Q P?A 64 C)*t,%' aoi1 OCT- (O 1'P 4'?w?wdQAUt? v? V Respe'ct``fulll{y Submitted, VERIFICATION I, verify that the statements made in this motion 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. Defendant Pro-Se PROOF OF SERVICE I, Verify that I am this day serving the foregoing motion in manner listed below which satisfies the requirements of Pa.R.C.P. 440. This service also satisfies the requirements of the Prisoner's Mailbox Act; (Com. v. Jones 700 A.2d 423; Houston v. Lack 108 S.Ct. 2379). Service by First Class Mail: office of the Prothonotary Cumberland County Courthouse 9 North Hanover St. Carlisle, Pa 17013 N Pro-Se Defendant Todd G. Mattson #GT4928 SCI FAYETTE Box 9999 Labelle, Pa 15450-0999 cc* ?.% 10-4 -11 12 September 2011 Mr. Mattson This has to be filed with the Prothonotary's office. SCI oa MCC DoE } `stTra4A-n4vr y To: CU?rb?r ,d C*&Al y (o,., 4AaAx ?e?.r S: r a ? VYl adaYr , : ?Yer been JrYi 1 nl r- 11a- Yfc-c now Cr 7? Z rna 4, -A- Address: 49 46141. 14AAoYeo- ST • "? ?- ocur'esS YA le &Is 06 City: tr- r S? State: ?n t'IY. )?*TO T ko rAa l-A-r' y 3 Zip Code: 1 7U l 3 Date: - 7 11 i` -?- 0 t'1Yi ?2 ?w !emu re 6 c.? i r L(?X? Mark an (x) for the service requested Sir.- , ??- Ylasrli' aeArh First Class - Letters, Flats, Parcels not over 13 oz. IASI OArYtIO Priority Mail -Letters, Flats, Panels `Express Mai -Letters, Flats, Parcels (1 ?L,/? ? ??? _ ? ? S ?i? a ? 1 ? ? I d Parcel Post - Parcels / Media Mail - Hard Bound Books, CD's, Videos (')d± rn' Canada ? Mexico Airmail (Overseas) 10 Ae- orry EXTRA SERVICES O ? ??`{Ge, ??ea.1e exCt?Se I?Y 'Certified Mail - First class/Priority only ( ) I' / Return Receipt - (with Certified) ( ) i S (? fn? // ,.` Certificate of Mailing Restricted Delivery ( ) r-., ?; ? e ? ?,?1? I! e ? m `Return Receipt for Merchandise - Parcels only { 'Delivery Confirmation - Priority Mai, Parcels only ( ) C ! 'Signature Confirmation - Priority Mail, Parcels only ( ) rt VtQS 'Insurance (must prove value for claim) $ ( ) ? (, ?>?IC ?r r%11'le 'Traceable through www.us ? i w.com or 1-800-222-1811 N ? Inmate Signature _Jodo? na -ice, Cell K a04?- I Inst. No. & % W -2 tlf ef't° / t0 tF Unit Stamp or Witness Signature } l o4P? ?? ?,- ( : - ' \fLClL d1/?Q.A? . C A Pt&l iL. - .-C ??w _.-.. 1 1-;Jam w w ?• ?_ LI4. Sir a&vi LA a xt?l,? n CC s ?, !e h _ ttr _ Jem if 1: 4tA46r Gavel's' ??,y??_4. t?? ?'? ??? _?#?.=-il??? f-k_-__- 1% C. T . G ?u.rS1?:A/f / A/17T ?n ` i TZGwlf7il ? _? C? C - 1:`, IQ- ?V-0S 410, ? I Su l SCI FAYEIT6 P sr o??lc.? o? on-?r TO: Address:--?Yf City: cz"r li sk State: ? ` Zip Code: 1 701 Date: Mark an (x) for the service requested First Class - Letters, Flats, Parcels notover 13 oz. Priority Mail Letters, Flats, Parcels ( ) *Express Mail - Letters, Flats, Parcels ( ) Parcel Post - Parcels Media Mail - Hard Sound Books, CD's, Videos Canada ( (v\ Mexico ( ) Airmail (Overseas) (>> / o ?s ?l t- .? P O SU, i'1 C EXTRA SERVICES s-- *Certified Mail - First class/Priority only d tifi i h C ( ) ( ) " ) er e t Return Receipt - (w Certificate of Mailing ( ) Restricted Delivery (/? N *Return Receipt for Merchandise - Parcels only *Delivery Confirmation - Priority Mail, Parcels only *Signature Confirmation - Priority Mail, Parcels only *Insurance (must prove value for claim) $ ( ) t--- '?" *Traceable through www.u=.com or 1-800-222-1811 Inmate Signature Cell Inst. No. 6TYU 1B Unit Stamp or Witness Signati e. l A) t; ?1 n A^ boc-L-vv)ev4 A MS. MATTSON: Yes. MR. HELVY: And do you understand that agreement? MS. MATTSON: Yes. MR. HELVY: And is the agreement that we placed on the record today acceptable to you? MS. MATTSON: Yes. MS. SOMMER: Mr. Mattson, have you heard the record that Mr. Helvy has read and placed on record today? MR. MATTSON: Yes. MS. SOMMER: Do you understand the record that was placed on the record? MR. MATTSON: Yes, I do. THE MASTER: And you're satisfied to have this entered as a final agreement with respect to all of the issues identified in this case? MR. MATTSON: Yes. THE MASTER: With the understanding that there is still some pending inquires that may be made regarding the tangible personal property. MR. MATTSON: Correct. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to 6 .IJ0C LA.YY%e-A? 3 eUTTom- ULAKIS ATTORNEYS AT LAW June 18, 2010 LEGAL AiT Todd Mattson SCI-Fayette Inmate No. #GT4928 P. O. Box 9999 La Belle, PA 15450-0999 Re. Heather R. Mattson v. Todd G. Mattson Docket No.: 05-6056 Out File No.. 09-025 Dear Todd: OFFICE i p 611M CARLISLE OFFICE (717) 249-0900 HARRISBURG OFFICE (717) 232-9511 CHAMBERSBURG OFFICE (717) 267-0900 YORK OFFICE (717) 846-0900 Enclosed please find a copy of my letter to Attorney Helvy requesting an answer as to where the $7,500 is that Heather was supposed to provide to you and where the firearm issue stands. I will be in touch with you as soon as I have a response. Also, according to Paragraph 7 of the Agreement it states that "within 60-days of the date the movers come to the house, husband or his designee shall have the right to specifically identify the property that is in dispute (which he feels he is entitled to from the marital residence) and to request the reappointment of the Master to hold a hearing regarding the distribution of the items of personal property that have been identified as being in dispute." You have 60-days to put a list together from the time your Mother retrieved those items to put a list together. However, it was my understanding based on conversations that I had with your Mother, that she would not be disputing any items. We need to have some clarification either from your Mother or from you about the items that are in dispute, if in fact there are any. Enclosed is a letter from Attorney Helvy and a copy of the Praecipe to Transmit the Record. You will see that he has filed the final divorce documents and is requesting that the divorce now be finalized. I will let you know when I receive the final Divorce Decree. Should you have questions or concerns regarding this or anything else, please do not hesitate to contact me. Sincerely, ZKU S, L.L.P. i Mic e e F:U ommer MLS/dlr Enclosure cc: Joyce Mattson Reply To: 2 WEST HIGH STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-0900 k)IBOM uTULAKIs Ar'roarvEn AT taw August 16, 2010 T -AGALMAIL Todd Mattson SCI-Fayette Inmate No. #GT4928 P. O. Box 9999 La Belle, PA 15450-0999 Re: Heatber R. Mattson v. Todd G. Mattson Docket No.: 05-6056 Our File No.: 09-025 Dear Todd: Enclosed please find a copy of the Order of Court signed by judge Hess vacating the appointment of a Divorce Master in order to move forward to finalize the divorce proceedings. Should you have questions or concerns regarding this or anything else, please do not hesitate to contact me. Sincerely, MLS/dlr Enclosure Mi a L. So OFFICE LOCA110N5 AB f? KUTU , L.L.P. CARLISLE OFFICE (717) 249-0900 HARRISBURG OFFICE (717) 232-9511 CHAMBERSBURG OFFICE (717) 267-0900 YORK OFFICE (717) 846-0900 ?y Reply To: l A%7-,, U-" GTRFFT eu Ol . i OFFICE LOCATI NS CARLISLE OFFICE (717) 249-09 R RISBURG OFFI G OFFI00 HARRISBURG (717) 232-9511 ATTORNEYS AT LAW CHAMBERSBURG OFFICE (717) 267-0900 YORK OFFICE (717) 846-0900 August 19, 2010 Joyce Mattson 600 Charles Street Mechanicsburg, PA 17055 .Re: Heather R. Mattson v. Todd G. Mattson Docket No.: 05-6056 OurFt7e No.: 09-025 Dear joyce: Fsnclosed please find a copy of my letter to Attorney Helvy requesting an answer as to why Todd has not received the $7,500 check as required by the Agreement issued on May 10d. I have also requested the information as to the firearms, so I can fully prepare the Affidavit for yours and Mr. Mattson's signature. I will be back in touch with you and Todd as soon as I have an answer. I also neeal to know if you are going to contest any items that were retrieved from the marital home. If so, we will need to schedule a hearing before the Divorce Master. Should you have questions or concerns regarding this or anything else, please do not hesitate to contact me immediately. Sincerely, ABOff & %UTULAUS, L.L.P. Michelle L. Sommer MLS/dlr Enclosures Reply To: 2 WEST HIGH STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-0900 FAx(717) 249-3344 ?h?i?; 1 h? n Crd + - ncr jc?mc' r- a"m e rl 4vl butt-.- .)r 4? t?,r et, xyl?? a _ L t fe 40 ex cap . -_ ._?, _ , elf. Jot Y, t:•) ?. ADom U7T KUULAKIS Arroxnen A. I.Aw August 24, 2010 LECUU.MAIL Todd Mattson SCI-Fayette Inmate No. #GT4928 P. O. Box 9999 La Belle, PA 15450-0999 Re: Heather R. Mattson v. Todd G. Mattson Docket No.: 05-6056 Our File No.: 09-025 Dear Todd: OFFICE 1 T oNt CARLISLE OFFICE (717) 249-0900 HARRISBURG OFFICE (717) 232-9511 CHAMBERSBURG OFFICE (717) 267-0900 YORK OFFICE (717) 846-0900 I would like to respond to your recent letter dated August 19''. First, you did not receive a letter from judge Hess. What you received was an Order of Court signed by judge Hess stating that the Agreement that the parties entered into on May 10`h, was an Agreement before the Divorce Master in which the parties entered into a Stipulation resolving the economic issues. Therefore; the Master then removed himself from this case. This then allowed Counsel to continue with the proceedings and allowed Attorney Helvy to file the Praecipe to Transmit the Record, the Affidavits of Consent and the Waivers of Notice so that a Divorce Decree could be entered. As I stated, this Order was signed by judge Hess on August 10'h, based upon the Stipulation that was entered into when you were before the Divorce Master on May 10th. I am enclosing a copy of that Stipulation and Agreement for your review. To be clear, I never indicated that there would be something in the fall that would deal with the property. If you will refer to the Agreement, specifically, paragraph 7, it states "...within 60-days of the date the movers come to the house, husband or his designee shall have the right to specifically identify the property that is in dispute (which he feels he is entitled to from the marital residence) and to request the reappointment of the Master to hold a hearing regarding the distribution of the items of personal property that have been identified as being in dispute." I am assuming that that is what you are referring to regarding dealing with the personal property in the fall. I need to be very clear that you cannot write to judge Hess, he will not accept a letter from you, nor will he respond to you in anyway. As I stated above, you did not receive a letter from judge Hess, you received an Order from him regarding the Stipulation that you entered into on May 10ffi. I have had a conversation with you Mother regarding the property and was informed that there would be no Hearing on the property. I have never received any indication from you or your family, that any property that was retrieved from the home was in dispute and a Hearing would be needed. Reply To: 2 WEST HIGH STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-0900 FAx(717) 249-3344 off,/--- S I OL4_npw-. - II 'C?T_ =._I?ISD?-Y1_ 8.t3...-_??;?,s?l _r?_._?t? rn _te_c?±cec1 a-_s3_?_?tot??_QS--le_c?- a: /?e rt.rf ? - aw E_- 7 71M j 736 _MT 1 r I as- . law: __. ? rr?e t.??_w ? y reeac ot?Oaa _Ora L_ ?/ Ll ( ? l _?j ? Q4'X9 • _. _ -_Yf\ . ? 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J i Y1 erie J NTru?- cc: (,fit a ? AL. ?'t'L? ?D . _ _ - t -.._ lrY?_'?._.?± ?? ???.!^ ...Ti% ?l? . _!',' _• L_zt "fr!'? r.+4.'? 1.???_ ?, L..a!%?!! _ lI l4C/ m tit, ?'nl4t?1 l? 1 "4L ?N, can 1I 5, ijte l T.. 7 LAS e ?? _'---1-Ltd' .. ?- ? ?? ? p ?_ ? _ ?• ... ........ ...... .]mac _ ;.r r Mada_&-T_.____ _- s c can 1 11 ? ?- _....._.__Si?r__.__Y1'?____?1e_ipL1-_ ____?t1p___?,r_1 _ ___ .. ??-;_?n ,- s? ,y, cam; ??__.r? ?.__..??. ___.?.?__. ???e.___.??..__ _?'_?r?s.?_. ??n ?_._t?%? __. . Wilk HEATHER RAE MATTSON :IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. NO. 05-6056 CIVIL TODD GREGORY MATTSON, Defendant IN CUSTODY IN RE: MOTION FOR REAPPOINTMENT OF MASTER ORDER AND NOW, this day of October, 2011, a rule is issued on the Plaintiff to show cause, if any, why the relief requested in the within Motion for Reappointment of Master ought not to be granted. This rule returnable thirty (30) days after service. BY THE COURT, Kevin .Hess, J. / J. Paul Helvy, Esquire / For the Plaintiff V Todd Mattson GT4928 ? ' -== SCI Fayette ? P. O. Box 9999 r LaBelle, PA 15450-0999 Defendant (C' P L. HEATHER RAE MATTSON : IN THE COURT OF COMMON PLEASE OF CUMBERLAND Plaintiff : COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW C) Vs. N0. 05-6056 CIVIL = ~ : rnco -03 --i 2 rn Q ~'Ti . X= .c -om TODD G. MATTSON : IN CUSTODY I CO ov Defendant ~C7 A~ -0 3-n ~CD 3~, C N CD r ~ IN RE: MOTION FOR REAPPOINTMENT OF MASTER ORDER a~o ~ Plaintiff, Heather Rae Mattson, in response to the motion moves this court to deny defendant Todd G. Mattson reappointment of master. On May 14, 2010, a hearing was held with Divorce Master E. Robert Elicker II. 1. Plaintiff agreed and paid Defendant $7500. 2. Plaintiff refinanced shared mortgage to remove the defendant from the mortgage. 3. Plaintiff returned Toyota Camry to defendant's parents. 4. Professionai movers came to piaintiffs home and removed defendant's personal property. The movers refused to take anything flammabie or the building material that where located outside because they were infested with bugs and rodents. 5. Plaintiff has read over defendant's motion and finds it disturbing that the defendant continues to blame judges, attorneys, his parents and myself for his current state. The defendant refuses to take responsibility for his actions and that is why he remains incarcerated. 6. Defendant had 60 days to dispute any personal property items. Wherefore, Piaintiff, Heather Rae Mattson, respectfully requests that this court deny reappointment of master. 1 have been tormented by the defendant for six years and wish to move on with my life. Respectfuily Submitted, ~ s- ~ OFFICE OF DIV'ORGE: MASTER CUMBERLAND CCiUNTY COURT OF CC)MMCN PLEAS 9 North Hanover Si:raet Carlisie, PA 17013 (717) 240-6535 E. Rpbert Elfcker, 11 west shore D'+vorce Master 1-888-697-0371 Ext. 6535 1Ysei Jo colyer. Offioe Manager/Reporter May 19:, 2010 J. Paul Helvy Michelle L. Sommer Attorney at Law Attorney at Law McNEES, WALLACE & NURICK A.BOM & KUTULAKIS, LLP 100 Pine Street 2 West High Street Harrisburg, PA 17108 Carlisle, PA 17013 RE: Heather R. b4attson vs. Todd G. Mattson No. 05 - 6056 Civil In Divorce Dear Mr. Helvy and Ms. Sommer.: Enclosed is a draft oi: the agreement which you put on the record on May 10, 2010. Please review the draft for any corrections with the understanding that no substantive changes can be made. After you have reviewead th.e draft, give us a call so we can make appropriate corrections. We will send the corrected original to the Plaintiff's attorney for signature who then can transmit the original to the Defendant's attorney for signature. When I receive a signed copy of the document, I will then obtain a Court order vacating my appointment. Thank you for your continuing cooperation in bringing this matter to settlement. Ve~truly you s, E. Robert Elicker, II Divorce Master HEATHER R. MATTSON, : IN THE COURT OF COIrMON PLEAS OF Plaintiff : CUMBERi,AND COUNTY, PENNSYLVANIA VS : NO. 05-6056 CIVIL TERM TODD G. MATTSON, . Def_endant : IN DIVORCE THE MASTER: Today is Monday, May 10, 2010. This is the date set for a hearing in the above-captioned divorce proceedings. Present in the hearing room are the Plaintiff, Heather R. Mattson, and her counsel J. Paul Helvy, and the Defendant, Todd Mattson, and his counsel Michelle R. Sommer. , This action was commenced by the filing of a I complaint in divorce on November 28, 2005. The complaint raised grounds for divorce of irretrievable breakdown of the marriage, imprisonment for a term in excess of 2 years, and indi nities. with res 9 pect Lo the grounds ior divorce, we are going to proceed under Section 3301(c) of the Domestic Relations Code. Both parties have signed affidavits of consent and waivers of notice of intention to request entry of divorce decree. Heather Mattson's affidavit and waiver were signed on March 10, 2010, and filed with the Prothonotary on March 16, 2010. Husband's affidavit and waiver were signed on March 2, 2010, and filed with the Prothonotary on March 5, 2010. As noted, the divorce can, therefore, conclude under section 3301(c) of the Domestic 1 Relations Code. The complaint also raised the claim for equitable distribution. After negociations today and previously over the matters relating to the distribution of the marital estate, the Master has been advised that counsel and the parties have reached an agreement which is going to be placed on the record. The agreement as placed on the record will be considered the substantive agreement of the parties not subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. The agreement is going to be transcribed I and sent to counsel for review or correction of typographical errors, if any, and then the parties and counsel will be asked to sign the agreement affirming the terms of settlement as stated on the record. It is understood that when the parties leave the hearing room toda the ar e bound b th Y Y y e terms of the agreement as stated on the record even thaugh there was no subsequent signing of the agreement affirming the terms of settlement. Upon receipt by the Master of a completed agreement, the Master will prepare an order vacating his appointment and counsel can then file a praecipe transmitting the record to the Court requesting a final decree in divorce. 2 can get them to do that before we send it to the Court. Is that all right, Mr. Helvy? MR. HELVY: Yes, sir. THE MASTER: Ms. Sommer, you okay with that? MS. 301rIIKER: That's fine. THE MASTER: Mr. Helvy? MR. HELVY: I will endeavor to put the agreement on the record. THE MA3TER: All right_ MR. fIELVY : 1. The parties' marital residence located at 2016 Milltown Road, Camp Hill, Pennsylvania, which is currently titled in joint names, shall become the property of wife. There is a mortgage encumbering that property which wife shall within 90 days of today's date either ; refinance or satisfy in order to remove husband's name. At ' the time of refinancing, wife shall pay $7,500 in cash to I husband. With regard to the deed to the marital residence, within 21 days of receipt by husband's attorney of a deed transferring title to the house from joint names to wife's name alone, husband will execute this deed, have the signature notarized, and return it to wife's counsel who will hold said deed in escrow pending refinancing. 2. Wife's 401(k) plan which she acquired as a result of her employment during the course of the marriage shall be wife's and husband shall waive any claim to said asset. 3. Husband's Smith Barney IRA which was accumulated during the course of the marriage shall be husband's, and wife shall waive any claim to that asset. 4. Any and all other bank accounts owned by the parties shall be from this point forward the sole possession of the party who is ttie titled owner of said bank accounts. 5. Within 30 days of today's date, wife shall deliver to husband's parents husband's 1998 Toyota Camry. 6. Except for the mortgage previously 4 discussed, any debt incurred by the parties shall be responsibility of the party incurring said debt. It is specifically understood that wife has assumed responsibility in excess of $11,500 for marital debt that was incurred during the course of the marriage, and she shall continue to bear the sole responsibility for that debt. This was one of the factors that was taken into consideration in determining the ultimate resolution of the marital estate. 7. With regard to personal property it is understood that there are certain items of personal property that continue to be located in the marital residence iocated at 2016 Milltown Road, Camp Hill, Pennsylvania. Withir. 60 days of husband's attcrney providing wife's attorney the name and contact information of a professional bonded mover, wife shall schedule a time with said mover to come to the house to remove those items of personal property contained on husband's personal property list that are acceptable to wife. Within 60 days of the date the mover comes to the house, husband or his designee shail have the right to s ecificall identif the ro ert tha t is in dis ute whi P Y Y P P Y P ( ch he feels he is entitled to from the marital residence) and , to request the reappointment of the Master to hold a hearing ' regarding the distribution of the items of personal property that have been identified as being in dispute. 8. Note that there is a pending agreement regarding the possessian of certain nonmarital guns. 9. Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all right he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship including without limitation statutory allowance, widow's allowance, right of intestacy, right to take against the with of the other, and the right to act as administrator or executor in the other's estate. Each will at the request af the other execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interest, rights, and claims. MR. HELVY: Ms. Mattson, have you had the opportunity to listen to me place the agreement on the record? 5 MS. MATTSON: Yes. MR. HELVY: And do you understand that agreement? MS. MATTSON: Yes. MR. HELVY: And is the agreement that we placed on the record today acceptable to you? MS. MATTSON: Yes. MS. SOMMER: Mr.. Mattson, have you heard the record that Mr. Helvy has read and placed on record today? MR. MATTSON: Yes. MS. SOMMER: Do you understand the record that was placed on the record? MR. MATTSON: Yes, I do. THE MASTER: And you're satisfied to have this entered as a final agreement with respect to all of the issues identified in this case? MR. MATTSON: Yes_ TIiT MASTER: With the understanding that there is still some pending inquires that may be made regarding the taiigible personal property. MR. MATTSON: Correct. I acknowiedge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to 6 the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations Code. WITNESS: DATE: J. Paul Helvy Heather R. Mattson Attorney for Plaintiff 'Michelle R. Sommer Todd G. Mattson Attorney for Defendant 7 HEATHER RAE MATTSON JN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA,- H CIVIL ACTION - LAW rnCo VS NO. 05-6056 CIVIL 2-M - . TODD GREGORY MATTSON, c7 Defendant IN CUSTODY z`? IN RE: MOTION FOR REAPPOINTMENT OF MASTER t> ORDER AND NOW, this 7' day of November, 2011, in consideration of the within m otion and the answer filed thereto, action on the Motion for Reappointment of Master is DEFERRED. r, n? (Z) ,.a 1're The defendant is granted leave to file an amended motion setting forth, with specificity, the items of personal property as to which issues remain unresolved. BY THE COURT, Hess, J. J. Paul Helvy, Esquire For the Plaintiff Heather Mattson 2016 Milltown Road Camp Hill, PA 17011 Todd Mattson GT4928 SCI Fayette P. O. Box 9999 LaBelle, PA 15450-0999 Defendant ie-0, :rlm IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION HEATHER R. MATTSON -T I. IN DIVORCE -41 ?? - VS. CASE NO. 05-6056 U,;= C? ":D TODD G. MATTSON '- AMENDED MOTION FOR REAPPOINTMENT OF MASTER Defendant, Todd G. Mattson, moves this Court to reappoint a Master with respect to the following claims of unresolved property and in support of his motion states: 1. On May 14th, 2010, a hearing was held with Divorce Master E. Robert Elicker II Esq.. 2. There are several items in dispute that have not been returned or compensated for, from the plaintiff. see pages 2,3 and 4. 3. Defendant requested his attorney, Michelle Sommer, to motion the Court for a hearing with the Divorce Master, to resolve above stated remaining issues. 4. Counsel failed to comply to said request by Defendant, which was done in the allotted time given. 5. Divorce Master was subsequently terminated by this Court. Wherefore, Defendant, Todd G. Mattson, respectfully requests that this Court re-appoint the Master with respect to his claims for unresolved marital equitable distribution of property. Respectfully Submitted, ?,6" b. nmA , ITEMS IN QUESTION (1) Reimbursed for my clothes that Plaintiff threw away. (she claims she called my parents, for them to pick them up, but my parents had never received a phone call or message left on the machine- $4K). (2) Reimbursed for half of the cost of the bedroom ($5K) and living room ($4,500.00) furniture, which was purchased together using our income tax return and payments by both parties. * Items missing that were on pages previously submitted @ Master's Hearing (see record). (3) Dell computer with web cam, speakers, keyboard, modem, flat screen, HP printer, disks and my files on hard drive. (I bought for myself). (4) Nikon cool pix digital camera with extra battery, battery charger and more than a dozen flash cards. (I bought for myself before my Alaska trip). (5) Panasonic camcorder with extra battery, battery charger, 2 dozen tapes. (wedding gift to me from Plaintiff). I was only one who used it. (6) Pictures I took from Cow Parade, trip to London, Florida vacations, underwater pics of our daughter Maggie. (7) Portable DVD player (my parents bought me for father's day). (8) 2 Ned Smith prints (given to me by Plaintiff's mother when she moved after her divorce. (9) Brand new Weber grill with 2 201b. propane bottles (my parents bought me a month before I was arrested, for my birthday. Plaintiff 2 "claims" they were stolen, even though supposed thief would have had to break into the house to steal the one propane bottle. "No police report filed", Strange ? (10) 18' Old Towne canoe Plaintiff "claims" this was stolen as well. Still "no" police report was filed. (had this before we married). (11) Tiffany lamp in living room (a wedding gift from friend of my family). (12) Oneida flatware (wedding gift from members of my family). (13) Mickey mouse clock in kitchen or Goofy coat hanger (items we purchased together on trips to Disney). (14) Disney Prints I purchased= Animal Kingdom, Mickey Mouse-and others. (15) Gold mirror in living room (of mine, which I found in someone's trash in Camphill, then repainted). (16) Star Wars collection, over 50 action figures (had since I was a child). (17) Cherry trifold picture frame (birthday gift from my sister). (18) Jewelery= diamond and sapphire bracelet (found at Disney before married), amber pieces and necklace (gifts from my grandparents). (19) 2 Mickey mouse watches (gold= gift from my parents and silver= gift from Plaintiff's mother), Green Malachite necklace (gift from my grandmother), diamond earings with gold studs (gift I bought for Maggie, that I was waiting to give her). 3 (20) Russian black bear hat (gift from my uncle before married= $500.00). (21) 4 Waterford crystal glasses (wedding gift from my father's friend). (22) Tools= edger, leaf blower, hedge trimmer, circular saw, cordless reciprocating saw (just received as a birthday gift from Plaintiff), cordless drill, chainsaw, weed wacker (these tools and others were gifts to me from family members at holidays or birthdays). (23) PVC pipes and fittings in back yard. (24) Ten Points crossbow, Remington 30-06 rifle (both acquired before marriage) and my father's 5 guns ** I am aware that I am not allowed to posses these weapons, but I would like to give to my father or to my nephews), these 5 guns are: Marlin 22cal. Rifle, 22 Marlin shotgun, Remington 20 guage shotgun, 308 German Mauser rifle and a 12 guage semi-automatic shotgun. (25) Reimbursed for damage done to my 1998 Toyota Camry (damage that the Plaintiff caused, no-one has driven since returned. Wherefore, in this AMENDED motion, Defendant also requests for a Video or Telephone conference Hearing in this matter. 4 VERIFICATION I, verify that the statements made in this motion 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. X) ?alu 1h, fynlta?? Defendant Pro-Se PROOF OF SERVICE I, Verify that I am this day serving the foregoing motion in manner listed below which satisfies the requirements of Pa.R.C.P. 440. This service also satisfies the requirements of the Prisoner's Mailbox Act; (Com. v. Jones 700 A.2d 423; Houston v. Lack 108 S.Ct. 2379). Service by First Class Mail: Date: Office of the Prothonotary Cumberland County Courthouse One Courthouse Square Carlisle, Pa 17013 Pro-Se Defendant Todd G. Mattson #GT4928 SCI FAYETTE Box 9999 Labelle, Pa 15450-0999 5 HEATHER RAE MATTSON Plaintiff VS. TODD GREGORY MATTSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 05-6056 CIVIL IN CUSTODY IN RE: MOTION FOR REAPPOINTMENT OF MASTER ORDER AND NOW, this 2 d* day of December, 2012, it appearing that the agreement of the parties entered into on August 10, 2010, which agreement was ratified by the Court, provides for the "reappointment" of the Master in the event of a dispute over the personal property, the motion of the defendant for reappointment of Master is granted for the purpose of dealing with the issues in the defendant's amended motion filed December 6, 2012. BY THE COURT, Kevin J. Paul Helvy, Esquire For the Plaintiff E. Robert Elicker, II, Esquire - in bin ??gd Master Ma Todd Mattson GT4928 SCI Fayette P. O. Box 9999 LaBelle, PA 15450-0999 Defendant DP iala°'us 4 3 tld ? 4,_ T^.J a"'7 O Am HEATHER RAE MATTSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V CIVIL ACTION - LAW NO. 05-6056 CIVIL TODD GREGORY MATTSON, Defendant IN DIVORCE IN RE: MOTION FOR REAPPOINTMENT OF MASTER ORDER OF COURT AND NOW, this 15th day of March, 2013, this matter having been called for hearing, after a brief argument, the within petition is dismissed with prejudice . By the Court, Kevi Hess, P. J. J. Paul Helvy, Esquire For the Plaintiff Michelle Sommer, Esquire For the Defendant E. Robert Elicker, II, Esquire Master ^' ^v3 w - Todd Mattson z Co x . c/o Joyce Mattson z =o 600 Charles Street Mechanicsburg, PA 17055 rte• °� b � g D� E'S /ytGt F� � 3�/�'�3 =" feW HEATHER RAE MATTSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V CIVIL ACTION - LAW NO. 05-6056 CIVIL TODD GREGORY MATTSON, Defendant IN DIVORCE ORDER OF COURT AND NOW, this 15th day of March, 2013, the appearance of Michelle Sommer, Esquire, as attorney for the defendant, is deemed withdrawn. By the Court, ✓/ ,oe Kevin Hess, P. J. J. Paul Helvy, Esquire For the Plaintiff Michelle Sommer, Esquire For the Defendant C-) `4'. y� E. Robert Elicker, II, Esquire rnCD _ Master XM Z"' M :;n r _ x Todd Mattson rM CO —i c/o Joyce Mattson .ccs x,. =r; 600 Charles Street =C) Mechanicsburg, PA 17055 y © v� :bg // `�— ISO^ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA //_`� Plaintiff Vt T ►(k1��5Q71 NO. Cs"4Q to jyi 20 Defendant . MOTION FOR APPOINTMENT OF MASTER Defendant ,moves the court to appoint a master with respect to the following claims: ❑Divorce N Distribution of Property _�a ❑Annulment ❑ Support C= ❑Alimony ❑Counsel Fees ❑Alimony Pendente Lite ❑Costs and Expenses Moo =r. 'm- t and in support of the motion states: 1. Discovery is complete as to the claims(s)for which the appointment of a master is ru*Xed. 2. The defendant has appeared in the action ersonall y (by his attorney,_ z �., © :_ �uirC :—:-- 3. The staturory ground(s)for divorce SELECT ONE r r --+ JovolrCe W&S �t�nal�LP,.c� iYX 4. Delete the inapplicable paragraph(s): A.9< B Z' C❑ a. The action is not contested. b. An aereement has been reached with resnect to the followine claims: C. The action is contested with respect to the followin claims: PC-IrS IDA �vv-�-edy JAI ivy Questiaki , see l�s� anclud�d 5. The action SELECT ONE complex issues of law o fact. 6. The hearing is expected to take .1,' a {y1n1 V'S SELLECT ONES 7. �A�ddditiotnal information,if any,relevant to the motion:iYYles"'o^r' c r R�.tr�a✓"���� f„(-St @r a ng C0VAeSAMen4 o� c�;S1'ci laiR�iCri ©T -pro Attorney for SELECT ONE (add Grejory 1�YI0. Sir Print Name Af ORDER APPOINTING MASTER AND NOW ,20 Esquire, is appointed master with respect to the following claims: By the Court, J. HEATHER RAE MATTSON, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V CIVIL ACTION-LAW NO.05-6056 CIVIL TODD GREGORY MATTSON, DEFENDANT IN DIVORCE IN RE: MOTION FOR REAPPOINTMENT OF MASTER ' . . ' Dear Sir: |want ho apologize for missing the hearing^ on March ^5t».As you are aware, |have been trying for Reappointment of the Master since May 2, 2011. If|would have been aware that such a hearing was scheduled,you better believe I would have been there, unfortunately I was unaware that there was a - � hearing. I would still like to be given the opportunity to present my'side so that I can reclaim or be compensated for my property that was thrown away, lied about,"stolen",or given to Heather's family members. |amnot sure why Michelle Sommer is still involved,as[fired her in November of 2010.The contract between her and | became null and void when she failed to act on her c|ient's/being me) requests, Reappointment of the Master,and also allowed Heather/Hemthe/s attorney to attempt tm b|ook'nmaU noe during a property settlement hearing via phone conference while |was a1 SCI Fayette. My parole officer, Eric Cleland, informed me that I missed the hearing on March 15th. He also informed me that Heather's attorney called him,stating that my attempts for Reappointment of the Master are only endeavors of harassment. I assure you,this is not my intentions. if Heather would have handed over what iy rightfully nmypropertyandK4icheUevvou|dhavedmneher' bprofessiona|kyxxe would not bein this predicament. Because of the unstabUityof Heather; reference from Dr.Stanley E.Schne|dar's psychological report | " on July 2, 2OO7, Heather's perception of reality is\nnpaired.",as well as the hearing for the letters|sent to our daughter,Maggie,in December 2006,where Heather expressed that they were written in"code." On top of that,the habitual telling of falsehoods; reference from when my parents,Gene and Joyce Mattson,were trying for partial custody rights of Maggie. Heather committed perjury with her detailed story of an incident in Target involving herself, Maggie,and my parents—a story,Yes—som,ething that actually happened|n reality, No.Then there are the lies she told during a Worker's Compensation hearing for mmy wrist.This came about because she was informed she would not getanyofnny settlement money, if|even got any. The lies Heather told during my criminal process and then to the parole board whenever I came up for ' parole-were all an attempt to willfully keep me away from Maggie,to keep a father and his daughter � separate. Like when she stated,during a hearing involving custody rights with my parents,I will do everything to make sure that Todd never sees Maggie again, in person or by picture." And now her most recent entry,she informed my parole officer that I was at church.Yes, I was there,and I was allowed to be there.This is.merely an attempt tm send nne back tojail. Asaresult of all these factors and the wild card that lays within,my parole officer feels dwould be wise to delay the Reappointment mftheK8asterunti|ofterOutoberl2, 2D}3,the day| amn off parole. Wishful thinking kn that with a delay Heothe r'sattmrneyxvmu|dnmtennoymnyparo|eofOcerxvith frivolous information and or lies. Even if the Reappointment of the Master is put off until after October, the inevitable is there and |know it is not going to change or delay Hea1her's behavior. ' � � I ask you to take all this into consideration before you schedule a hearing. All I want is what is rightfully mine, to have this finally behind me,and Heather out of my life. My new address: Todd Mattson 46 N. 101h St. Lemoyne, Pa. 17043. Thank you for your time. Sincerely, Pro. Se Defendant Todd G. Mattson Date: ' 1 CC: Kevin A Hess, P.J. E. Robert Elicker, II, Esquire Master J. Paul Helvy, Esquire For Plaintiff File IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION HEATHER R. MATTSON IN DIVORCE VS. CASE NO. 05-6056 TODD G. MATTSON AMENDED MOTION FOR REAPPOINTMENT OF MASTER Defendant, Todd G. Mattson, moves this Court to reappoint a Master with respect to the following claims of unresolved property and in support of his motion states: 1 . On May 14th, 2010, a hearing was held with Divorce Master E. Robert Elicker II Esq. . 2. There are several items in dispute that have not been returned or compensated for, from the plaintiff. see pages 2,3 and 4. 3. Defendant requested his attorney,, Michelle Sommer,. to motion the Court for a hearing with the Divorce Master, to resolve above stated remaining issues. 4. Counsel failed- to comply to said request by Defendant, which was done in the allotted time given. 5."",Divorce Master was subsequently terminated by this Court. ,Wherefore, Defendant, Todd G. Mattson, respectfully requests that this Court re-appoint the Master with respect to his claims for unresolved marital equitable distribution of property. Respectfully Submitted,. ITEMS IN QUESTION ( 1 ) Reimbursed ..for my clothes that Plaintiff threw away. ( she claims she called my parents, for them to pick them up, but my parents had never received a phone call or message left on the machine- $4K) . (2) Reimbursed for half of the cost of the bedroom ($5K). and living room ($4, 500.00 ) furniture, which was purchased together using our income tax return and payments by both parties. * Items missing that .were on pages previously submitted @Master' s Hearing (see record) . (3) Dell computer with web cam, speakers, keyboard, modem, flat screen, HP printer, disks and my files on hard drive. (I bought for myself) . (4) Nikon cool pix digital camera with extra battery, battery ' charger and more than a dozen flash cards. ( I bought for myself before my Alaska trip) . ( 5) Panasonic camcorder with extra battery, battery charger, 2 dozen tapes. (wedding gift to me from Plaintiff) . I was only one who used it. ( 6) Pictures I took from Cow Parade, trip to London, Florida vacations, underwater pics of our daughter Maggie. (7) Portable DVD player (my parents bought me for father' s -.day) . (8) 2 Ned Smith prints (given to me by Plaintiff' s mother when she moved after her divorce. (9) Brand new Weber grill with 2 201b. propane bottles (my parents bought me a month before I was arrested, for my birthday. Plaintiff 2 "claims" they were stolen, even though supposed thief would have had to break into the house to steal the one propane bottle. "No police report filed", Strange ? (10) 181 Old Towne canoe Plaintiff "claims" this was stolen as well. Still "no" police report was filed. (had this before we married) . ( 11 ): Tiffany lamp in living room (a wedding gift from friend of my family) . ( 12) Oneida flatware (wedding gift from members of my family) , ( 13) Mickey mouse clock in kitchen or Goofy coat hanger ( items we purchased together on trips to Disney) . ( 14) Disney Prints I purchased= Animal Kingdom, Midkey--.Mouse..-,-.attds-ix ., ,, . others. (15) Gold mirror in living room (of mine, which I found in someone' s trash in Camphill, then repainted) . ( 16) Star Wars collection, over 50 action figures (had since I was a child) . (17) Cherry trifold picture frame (birthday gift from my sister) . (18) Jewelery-_ diamond and sapphire bracelet (found at Disney before married) , amber pieces and necklace (gifts from my grandparents) . (19) 2 Mickey mouse watches (gold= gift from my parents and silver= gift from Plaintiff' s mother) , Green Malachite necklace (gift from my grandmother) , diamond earings with gold studs (gift I bought for Maggie, that I was waiting to give her) . .3 (20) Russian black bear hat (gift from my uncle before married= $500.00) . (21 ) 4 Waterford crystal glasses (wedding gift from my father' s friend) . (22) Tools= edger, leaf blower, hedge trimmer, circular saw, cordless reciprocating saw (just received as a birthday gift from Plaintiff) , cordless drill, chainsaw, weed wacker (these tools and others were gifts to me from family members at holidays or birthdays) . (23) PVC pipes and fittings in back yard. (24) Ten Points crossbow, Remington 30-06 rifle (both acquired before marriage) and my father' s 5 gun's ** I am aware that I am not allowed to posses these weapons, but I would like to give. to my father or to my nephews) , these 5 guns are: Marlin 22cal. Rifle, 22 Marlin shotgun, Remington 20 guage shotgun, 308 German Mauser rifle. and a 12 guage semi-automatic shotgun. (25) Reimbursed for damage done to my 1998 Toyota Camry (damage that the Plaintiff caused, no-one has driven since returned. 4 VERIFICATION I, verify thatthe statements made in this motion are true and Correct. I understand that false statements herein are made subject. to the penalties of 18 Pa.C.S. §4904, relating to uhsworn falsification to authorities. Defendant Pro-Se PROOF OF SERVICE I. Verify that I am this day serving the foregoing motion in .manner listed below which satisfies the requirements of Pa.R.C.P. 440. This service also satisfies the requirements of. the Prisoner' s Mailbox Act; (Com. v. Jones 700 A.2d 423; Houston v. Lack 108 S.Ct. 2379) .. Service by First Class Mail: Office of the .Prothonotar'y Cumberland County Courthouse one -Courthouse Square Carlisle, Pa 17013 Iy Date: 1q, DOI Pro-Se Defendant Todd G. Mattson q4 go,+k, 104, street 5 "JllSorg IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Plaintiff vY1(1c�� NO.-5°405/ cy,1 20 Defendant MOTION FOR APPOINTMENT OF MASTER Defendant ,moves the court to appoint a master with respect to the following claims: ❑Divorce M Distribution of Property , ,, � c� c.� ❑Annulment ❑ Support C ❑Alimony ❑Counsel Fees ❑Alimony Pendente Lite ❑Costs and Expenses rmoo and in support of the motion states: 4%e '.0 1. Discovery is complete as to the claims(s)for which the appointment of a master is red. 2. The defendant has appeared in the action ersonally (by his attorney, CZ= -i-In+, CD xM �uirT 3. The staturory ground(s)for divorce SELECT ONE Tr Ji 01rCe- WOWS ','^017-e! irn solo c 4. Delete the inapplicable paragraph(s): A.Z B e C❑ a. The action is not contested. b. An aereement has been reached with resnect to the followinP claims: C. The action is contested with respect to the followin�j claims: Per �,��,,eC4� S-�1� �✓� Qu.�Sti��1 , See 1., Inc 5. The action SELECT ONE complex issues of law o fact. 6. The hearing is expected to take � Y\p uj-S SELECT ONE ] f r n .�O Qy��r/tE'I'�T cT 7. Additional information,if any,relevant to the motion: YYlc 4-,.o^ ' or R�`� Date: ` ro J°L Attorney for SELECT ONE (ocld Gregory YY10-4140^ Print Name -= ORDER APPOINTING MASTER NOW .31 ,20L3 -,AzJ Esquire, `t is apil�ed master with respect to the following claims: 4A? Cz::� By the Court, COW _ - CL 17&'&CL 944y "T `r. m�. HEATHER RAE MATTSON, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V CIVIL ACTION-LAW NO.05-6056 CIVIL TODD GREGORY MATTSON, DEFENDANT IN DIVORCE IN RE: MOTION FOR REAPPOINTMENT OF MASTER Dear Sir: I want to apologize for missing the hearing on March 15th.As you are aware, I have been trying for Reappointment of the Master since May 2, 2011. If I would have been aware that such a hearing was scheduled,you better believe I would have been there, unfortunately I was unaware that there was a hearing. I would still like to be given the opportunity to present my side so that I can reclaim or be compensated for my property that was thrown away, lied about, "stolen", or given to Heather's family members. I am not sure why Michelle Sommer is still involved,as I fired her in November of 2010.The contract between her and I became null and void when she failed to act on her client's(being me) requests, Reappointment of the Master,and also allowed Heather/Heather's attorney to attempt to black-mail me during a property settlement hearing via phone conference while I was at SCI Fayette. My parole officer, Eric Cleland, informed me that I missed the hearing on March 15th. He also informed me that Heather's attorney called him, stating that my attempts for Reappointment of the Master are only endeavors of harassment. I assure you,this is not my intentions. If Heather would have handed over what is rightfully my property and Michelle would have done her job professionally,we would not be in this predicament. Because of the unstability of Heather; reference from Dr.Stanley E.Schneider's psychological report on July 2, 2007, "Heather's perception of reality is impaired.", as well as the hearing for the letters I sent to our daughter, Maggie, in December 2006,where Heather expressed that they were written in "code." On top of that,the habitual telling of falsehoods; reference from when my parents, Gene and Joyce Mattson,were trying for partial custody rights of Maggie. Heather committed perjury with her detailed story of an incident in Target involving herself, Maggie, and my parents—a story,Yes—something that actually happened in reality, No.Then there are the lies she told during a Worker's Compensation hearing for my wrist.This came about because she was informed she would not get any of my settlement money, if I even got any. The lies Heather told during my criminal process and then to the parole board whenever I came up for parole•were all an attempt to willfully keep me away from Maggie,to keep a father and his daughter separate. Like when she stated, during a hearing involving custody rights with my parents, "I will do everything to make sure that Todd never sees Maggie again, in person or by picture." And now her most recent entry, she informed my parole officer that I was at church.Yes, I was there, and I was allowed to be there.This is merely an attempt to send me back to jail. As a result of all these factors and the wild card that lays within, my parole officer feels it would be wise to delay the Reappointment of the Master until after October 12, 2013,the day I am off parole. Wishful thinking is that with a delay Heather/Heather's attorney would not annoy my parole officer with frivolous information and or lies. Even if the Reappointment of the Master is put off until after October, the inevitable is there and I know it is not going to change or delay Heather's behavior. I ask you to take all this into consideration before you schedule a hearing. All I want is what is rightfully mine,to have this finally behind me, and Heather out of my life. My new address: Todd Mattson 46 N. 10t"St. Lemoyne, Pa. 17043. Thank you for your time. Sincerely, Pro.Se Defendant Todd G. Mattson Date: ' 1 CC: Kevin A Hess, P.J. E. Robert Elicker, II, Esquire Master J. Paul Helvy, Esquire For Plaintiff File IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION HEATHER R. MATTSON . IN DIVORCE VS. CASE NO. 05-6056 TODD G. MATTSON AMP-LADED MOTION FOR REAPPOINTMENT OF MASTER Defendant, Todd G. Mattson, moves this Court to reappoint a Master with respect to the following claims of unresolved property and in support of his motion states: 1 . On May 14th, 2010, a hearing was held with Divorce Master E. Robert Elicker II Esq. . 2. There are several items in dispute that have not been returned or compensated for, from the plaintiff. see pages 2, 3 and 4. 3. Defendant requested his attorney,. Michelle Sommer, to motion the Court for a hearing with the Divorce Master, to resolve above stated remaining issues. 4. Counsel failed to comply to said request by Defendant, which was done in the allotted time given. 5. Divorce Master was subsequently terminated by this Court. Wherefore, Defendant, Todd G. Mattson, respectfully requests that this Court re-appoint the Master with respect to his claims for unresolved marital equitable distribution of property. Respectfully Submitted, ITEMS IN QUESTION ( 1 ) Reimbursed .for my clothes that Plaintiff threw away. ( she claims she called my parents, for them to pick them up, but my parents had never received a phone call or message left on the machine- $4K) . (2) Reimbursed for half of the cost of the bedroom ($5K) and living room ($4,500. 00) furniture, which was purchased together using our income tax return and payments by both parties. * Items missing that were on pages previously submitted @Master's Hearing (see record) . (3) Dell computer with web cam, speakers, keyboard, modem, flat screen, HP printer, disks and my files on hard drive. (I bought for myself) . ( 4) Nikon cool pix digital camera with extra battery, battery ' charger and more than a dozen flash cards. ( I bought for myself before my Alaska trip) . (5) Panasonic camcorder with extra battery, battery charger, 2 dozen tapes. (wedding gift to me from Plaintiff) . I was only one who used it. ( 6) Pictures I took from Cow Parade, trip to London, Florida vacations, underwater pics of our daughter Maggie. (7) Portable DVD player (my parents bought me for father':s '.day) . (8) 2 Ned Smith prints (given to me by Plaintiff ' s mother when she moved after her divorce. (9) Brand hew Weber grill with 2 201b. propane bottles (my parents bought me a month before I was arrested, for my birthday. Plaintiff 2 "claims" they were stolen, even though supposed thief would have had to break into the house to steal the one propane bottle. "No police report filed" , Strange ? (1 0) 18' Old Towne canoe Plaintiff "claims" this was stolen as well. Still "no" police report was filed. (had this before we married) . ( 11 )i Tiffany lamp in living room (a wedding gift from friend of my family) . ( 12) Oneida flatware (wedding gift from members of my family) . ( 13) Mickey mouse clock in kitchen or Goofy coat hanger ( items we purchased together on trips to Disney) . (1 4) Disney Prints I purchased= Animal Kingdom, Mickey:-.Mouse-,and--. others. ( 15) Gold mirror in living room (of mine, which I found in someone' s trash in Camphill, then repainted) . ( 16) Star Wars collection, over 50 action figures (had since I was a child) . (17) Cherry trifold picture frame (birthday gift from my sister) . ( 18) Jewelery-- diamond and sapphire bracelet (found at Disney before married) , amber pieces and necklace (gifts from my grandparents) . (19) 2 Mickey mouse watches (gold= gift from my parents and silver= gift from Plaintiff' s mother) , Green Malachite necklace (gift from my grandmother) , diamond earings with gold studs (gift I bought for Maggie, that I was waiting to give her) . 3 (20) Russian black bear hat (gift from my uncle before married= $500.00) . (21 ) 4 Waterford crystal glasses (wedding gift from my father' s friend) . (22) Tools= edger, leaf blower, hedge trimmer, circular saw, cordless reciprocating saw (just received As a birthday gift from Plaintiff) , . cordless drill, chainsaw, weed wacker (these tools and others were gifts to me from family members at holidays or birthdays) . (23) PVC pipes and fittings in back yard. (,24) Ten Points crossbow, Remington 30-06 rifle (both acquired before marriage) and my father' s 5 guns ** I am aware that I am not allowed to posses these weapons, but I would like to give- to my father or to my nephews) , these 5 guns are: Marlin 22cal. Rifle, 22 Marlin shotgun, Remington. 20 guage shotgun, 308 German Mauser rifle and a 12 guage semi-automatic shotgun. (25) Reimbursed for damage done to my 1998 Toyota Camry (damage that the Plaintiff caused, no-one has driven since returned. 4 VERIFICATION I, verify that the statements made in this motion 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. Defendant Pro-Se PROOF OF SERVICE I, Verify that I am this day serving the foregoing motion in manner listed below which satisfies the requirements of Pa.R.C.P. 440. This service also satisfies the requirements of. the Prisoner' s Mailbox Act; (Com. v. Jones 700 A.2d 423; Houston v. Lack 108 S.Ct. 2379) . Service by First Class Mail: Office of the Prothonotar`y, , Cumberland County Courthouse One .Courthouse Square Carlisle, Pa 17013 a_ Date: �� - Pro-Se Defendant Todd G. Mattson . (404k t0*k SE ec� Le►�►►�yv�e. ,1?�l ,71 (3 5 HEATHER RAE MATTSON IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION—LAW VS. NO. 05-6056 CIVIL TODD GREGORY MATTSON, Defendant IN CUSTODY IN RE: MOTION FOR APPOINTMENT OF MASTER ORDER AND NOW,this �� day of June, 2013, our order of May 31, 2013, is VACATED as having been improvidently entered. BY THE COURT, �--� , A / Kevin ess, J. ✓ J. Paul Helv Y, Esquire For the Plaintiff Todd Mattson 46 N. 10" Street Lemoyne, PA 17043 Defendant E. Robert Elicker, II, Esquire — LacC Z6 42i Master :rim nn -<> _