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HomeMy WebLinkAbout06-0443SUZANNE THOMAS : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW CHARLES THOMAS NO. 2006 -y43 CIVIL TERM Defendant : 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 iI you fail to do so, the case maybe entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the 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, Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 249-3166 PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 3800 Market Street Camp Hill, PA 17011 (717)591-1755 Attorney for Plaintiff SUZANNE THOMAS : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW CHARLES THOMAS NO. 2006 - 'Yy3 CIVIL TERM Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) AND 3301(d) OF THE DIVORCE CODE AND NOW, COMES, the above-named Plaintiff by and through her attorney Peter J. Russo, and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff is an adult individual residing at 217 South 16'h Street, Camp Hill, Cumberland County, Pennsylvania and is a citizen of the United States. 2. Defendant is an adult individual residing at 895 York Road, Dover, York County, Pennsylvania, and is a citizen of the United States. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for twenty-six (26) years and has resided continuously therein for at least six (6) months prior to filing of this Complaint. 4. Defendant is a resident of the Commonwealth of Pennsylvania and has resided continuously therein for at least six (6) months prior to filing of this Complaint. 5. Plaintiff and Defendant were married on September 7,1991, in Cumberland County, Pennsylvania. PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 SUZANNE THOMAS Plaintiff v. CHARLES THOMAS Defendant Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2006 - 443 CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I, Janet E. Bush, hereby certify that I am on this day serving a copy of the foregoing documents upon the person (s) and in the manner indicated below; Service by First-Class Mail, Postage Prepaid, and Addressed as Follows AND by Certified Mail# 7001 2510 0006 5849 7225 CHARLES THOMAS 895 YORK ROAD DOVER, PA 17315 -~ et E. Bush, Paralegal Date: ~)/ ~ a~/ -Q Zp ~, - _~ ,. ':;>- 6. Plaintiff and Defendant sepazated on October 2,1998. 7. There aze no children of the parties under the age of eighteen (18). 8. Plaintiff desires to return to her maiden name of Suzanne Martin. COUNT I -DIVORCE 9. Plaintiff hereby incorporates by reference averments 1 through 8 of this Complaint as if each averment were set forth fully hereunder. 10. There have been two (2) prior actions for divorce by either party against the other. Both were dismissed. 11. Neither Plaintiff nor Defendant is in the Armed Forces of the United States or any of its allies. 12. Plaintiff suers that the marriage between the parties is irretrievably broken. 13. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling, but does not request the same. COUNT II - EQUITABLE DISTRIBUTION 14. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 15. Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties without regazd to marital misconduct in such proportion as the Court deems just after consideration of all relevant factors. WHEREFORE, Plaintiff, Suzauue Thomas, prays that a decree be entered in favor of the Plaintiff and against Defendant as follows: A. That a decree in divorce be entered dissolving the marriage between the two parties. B. The Court enter an order of equitable distribution of marital property pursuant to Section 3502(a) of the Divorce Code. Res~~ctfu subm~itte~;--~ i Peter J. Russo, Esquire 3800 Market Street Camp Hill, PA 17011 (717)591-1755 ID # 72897 Date: 1 ~ ~ ~ o ~' PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 3800 Market Street Camp Hill, PA 17011 (717)591-1755 SUZANNE THOMAS Plaintiff v CHARLES THOMAS Defendant Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2006 - IN DIVORCE VERIFICATION CIVIL TERM I, Suzanne Thomas, verify that the statements made in the foregoing document are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. §4904 relating to unswom Date: L 'L b(~7 .~' {~'~ ~ ~ ~ "1 -~ 0 0 "~ ~ ~ ~' ~~ ~5 ~. -c -~ s~... ~~ ~ ~' ~. 0 SUZANNE THOMAS : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW CHARLES THOMAS NO. 2006-CV- CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, Cesar L.Buono, being duly sworn according to law, that I am over 18 years of age and not a party to the above-captioned action, served and made known to Steve Brown on the 8th day of February, 2006 at 11:05 a.m. at 895 York Road, Dover, PA 17315 a Divorce Complaint, 20-Day Notice/Affidavit of Separation, Notice of Intent to Request Entry of Divorce, Counter Affidavit Under Section 3301 (d) of the divorce code issued in the above entitled case in the manner described below: [ ] Personally delivered them into the hands of the person to be served [X] Adult family member with whom that person resides. Relationship is brother . [ ] Agent or person in charge of person's office or usual place of business [ ] Other. Descriation of Reciaient Sex: male Skin Color: white Hair Color: dark blonde Facial Hair: no Height (approx.): 6' Weight (approx.): 170 Age: 43 -~'~ -- ~ -~ v7 -~ _ 1 Signature Title Badge/ID # (if any) 3800 Market Street, Camp Hill, PA 17011 Address 717-591-1755 Phone Number __, <-, -, r-~ __,, ~: -~=~, ~~ ~~, .. Attorneys for Plaintiff Law Offices of Peter J. Russo, P.C. By: Elizabeth J. Saylor, Esquire Attorney I.D. No. 200139 3800 Market Street Camp Hill, PA 17011 (717)591-1755 (717) 591-1756 Facsimile Isaylor@pjrlaw.com SU2:ANNE THOMAS IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW CHARLES THOMAS : NO. 2006 -443 CIVIL TERM Defendant IN DIVORCE PETITION FOR BIFURCATION Petitioner, her attorney, respectfully requests that this Honorable Court grant the Petition for Bifurcation, and in support thereof avers as follows: 1. Petitioner is Suzanne Thomas, the Plaintiff in the above-captioned divorce action. 2. Respondent is Charles Thomas, the Defendant in the above-captioned divorce action. 3. Petitioner and Respondent were married on September 7, 1991, in Cumberland County, Pennsylvania .They have no children. 4. On January 24, 2006, Petitioner commenced a divorce action by filing a Complaint in Divorce as of the above docket number seeking equitable distribution of marital property. 5. Petitioner will file an Affidavit pursuant to Section 3301 (d) of the Divorce Code alleging, inter alia, that the parties separated on October 2, 1998, and have continued to live separate and apart for at least two (2) years and that the marriage is irretrievably broken. 6. Petitioner will file an Inventory as required by the Rules of Court. 7. Petitioner will file aPre-Trial Statement pursuant to the Rules of Court. 8. No discovery has been requested by either party. 9. The parties file separate tax returns. 10. Both parties are in good health and there is little likelihood of a shortened lifespan. 11. The parties have their own separate health insurance coverage. 12. The Plaintiff filed a chapter 13 bankruptcy in or about January 2001 which is expected to close in October 2006. Defendant is not believed to have filed or be likely to fild for bankruptcy. 13. Neither party's property rights would be affected in any way by a bifurcation of the divorce from the pending economic issues. 14. The parties have maintained an economic status quo during the separation that Petitioner has no intention of disturbing. 15. Bifurcation would not disturb that economic status quo. 16. Petitioner agrees to waive the Deadman's Rule. 17. Petitioner believes and avers that the advantages of bifurcation of this divorce action are substantially greater than the disadvantages for the following reasons: (i) A speedy resolution of the divorce issue would allow the parties to restructure their personal lives. (ii) Bifurcation will accelerate the dissolution of the parties' marriage which has been acknowledged by both parties to be irretrievably broken. (iii) Bifurcation will further the policy behind Pennsylvania's Divorce Code in making the legal dissolution of marriage effective for dealing with the reality of matrimonial experience by taking into primary consideration the welfare of the family rather than the vindication of private rights. 23 Pa. C.S.A. Section 3102(a). (iv) Bifurcation of this divorce action wi11 also separate the dissolution of the marriage from the distribution of property so that the marriage and each party's personal life are not held hostage to economic demands. (v) Bifurcation of the divorce action will in no way prejudice, diminish or impair Respondent's economic claims under the Divorce Code. WHEREFORE, Petitioner respectfully requests that this Court grant her Petition for Bifurcation, reserving jurisdiction on the economic claims raised by the parties. Respectfully submitted, lAW OFFICES OF PETER J. RUSSO, P.C. Cam' /7 ~~ Attorneys for P aintiff Peter J. Russo, Esquire ID # 72897 Scott A. Stein, Esquire I D # 81738 Elizabeth J. Saylor, Esquire ID # 200139 Date: ~ ' 7'~~ Attorneys for Plaintiff Law Offices of Peter J. Russo, P.C. By: Elizabeth J. Saylor, Esquire Attorney LD. No. 200139 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 SUZANNE THOMAS Plaintiff v. CHARLES THOMAS Defendant Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2006 - 443 IN DIVORCE CIVIL TERM VERIFICATION I, Suzanne Thomas, verify that the statements made in the foregoing document are trne and correct. I understand that false statements made herein aze subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date: ~,~ 9 "d~ A Attorneys for the Plaintiff Law Offices of Peter J. Russo, P.C. By: Elizabeth J. Saylor, Esquire Attomey I.D. No. 200139 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 SUZANNE THOMAS Plaintiff v CHARLES THOMAS Defendant Attomey for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2006 - 443 CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I, Janet E. Bush, hereby certify that I am on this day serving a copy of the foregoing documents upon the person (s) and in the manner indicated below; Service by First-Class Mail, Postage Prepaid, and Addressed as Follows: CHARLES THOMAS 895 YORK ROAD DOVER, PA 17315 E. Bush, Paralegal Date: 3 ~ ~ ~ _, SUZANNE THOMAS IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -DIVORCE CHARLES THOMAS DEFENDANT 06-443 CIVIL ORDER OF COURT AND NOW, this 17`h day of March, 2006, upon consideration of the foregoing petition, IT IS HEREBY ORDERED AND DIRECTED that: 1. A rule is issued upon the defendant to show cause why the plaintiff is not entitled to the relief requested; 2. The defendant will file an answer to this petition on or before April 10, 2006; 3. The petition shall be decided under Pa. R. C. P. No. 206.7; 4. If the Defendant files an answer to this Rule to Show Cause, and the answer raises disputed issues of material fact, an evidentiary hearing shall be held on the 19"' day of April, 2006, at 1:30 p.m. in Courtroom No. 5 of the Cumberland County Courthouse. If no answer to the Rule to Show cause is filed by the required date, the relief requested by Plaintiff shall be granted. By the Court, ~w Office of Peter J. Russo, P.C. A/ttorneys for Plaintiff Charles Thomas 895 York Road Dover, PA 17315 ~~ bas ^~ ~~-d" `,, M. L. Ebert, Jr., J. -~ ~ii';v',~; i,:~;~;,.i 3 ,lth,in'v~ '; = r~r;~ L 0 ~ 114~~ L l ~'a!~ 9DDZ Tbtl'_V''~ ~-'~'~d 'rli ~G~ ~~L.1` ~. {:1:7'I~ LAW OFFICES OF PETER J. RUSSO, P.C. ELIZABETH J. SAYLOR, ESQUIRE PA Supreme Court ID: 200139 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 SUZANNE THOMAS : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW CHARLES THOMAS NO. 2006 - NO. 2006 - 443 Defendant CIVIL TERM IN DIVORCE MOTION TO MAKE RULE ABSOLUTE AND NOW, comes The Law Offices of Peter J. Russo, P.C., and sets forth the following: 1. On the 17th day of March, 2006, the Honorable M.L. Ebert, Jr. issued a Rule upon the Defendant to show cause why plaintiff is not entitled to the bifurcation requested. Defendant was to file an answer to the petition on or before April 10, 2006. 2. As of April 21, 2006, Defendant has failed to file an answer to said petition. WHEREFORE, Plaintiff Suzanne Thomas,. by and through her counsel, requests this Court make the Rule Absolute and grant Plaintiff's Petition for Bifurcation. Respectfully submitted, Law Offices of Peter J. Russo, P.C. Date: ` -~l-U b gy; Elizabeth J. Saylor, Esquire Attorney ID No. 200139 3800 Market Street Camp Hill, PA 17011 LAW OFFICES OF PETER J. RUSSO, P.C. BY: ELIZABETH J. SAYLOR, ESQUIRE PA Supreme Court ID: 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 SUZANNE THOMAS IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW CHARLES THOMAS NO. 2006 - NO. 2006 - 443 Defendant CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that I have on this day served a true and correct copy of the foregoing documents upon the following persons, in the manner indicated: FIRST CLASS MAIL Charles Thomas 895 York Road Dover, PA 17315 LAW OFFICE OF PETER J. RUSSO, P.C. BY: ~ 4 ~ - ~V uy~ Date: L~ _ -~~ ~~ SUZANNE THOMAS IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY. PENNSYLVANIA v. :CIVIL ACTION -DIVORCE CHARLES THOMAS DEFENDANT 06-443 CIVIL ORDER OF COURT AND NOW, this 25"' day of April, 2006, after consideration of the Plaintiff's Petition for Bifurcation, and noting that the Defendant has filed no answer to the Rule to Show Cause issued by this Court on March 17, 2006, IT IS HEREBY ORDERED AND DECREED that: 1. The divorce action is bifurcated from the pending ancillary economic claims. 2. The Court retains jurisdiction of any pending economic claims raised by either party. 3. The parties are enjoined from encumbering, dissipating, selling, or otherwise alienating any and all marital assets. By the Court, M. L. Ebert, Jr., J. lizabeth J. Saylor, Esquire Attorney for Plaintiff ' ;,,eharles Thomas Defendant bas ~~ tr ~ ~~ ~,~ SUZANNE THOMAS Plaintiff v CHARLES THOMAS Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2006 - NO. 2006 -443 CIVIL TERM IN DIVORCE INVENTORY OF SUZANNE THOMAS Plaintiff files the following inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Plaintiff verifies that the statements made in this inventory are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904~relating to unsworn falsification to authorities. ASSETS OF THE PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. (X) 1. Real property {X) 2. Motor vehicles ( ) 3. Stocks, bonds, securities and options ( ) 4. Certificates of deposit ( ) 5. Checking accounts, cash ( ) 6. Savings accounts, money market and savings certificates ( ) 7. Contents of safe deposit boxes ( ) 8. Trusts ( ) 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) () 10. Annuities ( ) 11. Gifts ( ) 12. Inheritances () 13. Patent, copyrights, inventions, royalties (X) 14. Personal property outside the home (X) 15. Business (list all owners, including percentage or ownership, and officer/director positions held by a party with company) (} 16. Employment termination benefits --- severance pay, worker's compensation claim/award ( ) 17. Profit sharing plans () 18. Pension plans (indicate employee contribution and date plan vests} ( ) 19. Retirement plan, Individual Retirement Accounts ( ) 20. Disability payments ( ) 21. Litigation claims (matured and unmatured) ( ) 22. MilitarylV.A. benefits ( ) 23. Education benefits (X) 24. Debts due, including loans, mortgages held (X) 25. Household furnishings and personality (include as a total category and attach itemized list if distribution of such assets is in dispute) ( ) 26. Other MARITAL PROPERTY Plaintiff lists all martial property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced: Item Number Description of Progerty 1 1622 Catherine Street Harrisburg, PA 1 256 Juniper Drive Etters, PA 2 1998 Oldsmobile Bravada 2 1997 Chevy S-10 14 1998 Sea-doo Jet Ski 14 Kawasaki Jet Ski Name of All Owners Plaintiff and Defendant Plaintiff and Defendant Plaintiff and Defendant Plaintiff and Defendant Plaintiff and Defendant Plaintiff and Defendant 14 1994 Sunbird Boat Plaintiff and Defendant 14 2 Boat trailers Plaintiff and Defendant 15 C. Thomas Financial Defendant 24 GMAC for Etters Home Plaintiff and Defendant $30,000.00 24 NCFCU for Bravada (now paid off) Plaintiff and Defendant 24 NCFCU Home Equity (now paid off) Plaintiff and Defendant 25 Black leather couch/love seat Plaintiff and Defendant 25 Black coffee table and end tables Plaintiff and Defendant 25 Dining table with 6 chairs Plaintiff and Defendant 25 Refrigerator Plaintiff and Defendant 25 Pfaltzgraff 16 piece dishware Plaintiff and Defendant 25 T-fal cookware Plaintiff and Defendant 25 Serving set (16 piece) Plaintiff and Defendant 25 32" RCA color TV Plaintiff and Defendant 25 Black Lacquier TV/Stereo stand Plaintiff and Defendant 25 Desk Plaintiff and Defendant 25 Computer Plaintiff and Defendant 25 Filing Cabinet Plaintiff and Defendant 25 Office chairs Plaintiff and Defendant 25 Day bed Plaintiff and Defendant 25 27° RCA color TV Plaintiff and Defendant 25 Green micro-fiber couch/love Plaintiff and Defendant seat/overstuffed chair/ottoman 25 Stereo equipment/bose speakers Plaintiff and Defendant 25 Rod Iron patio furniture seating for 6 Plaintiff and Defendant 25 King size bed Plaintiff and Defendant 25 Oversized bureau/end tables/armoire Plaintiff and Defendant 25 Washer and Dryer Plaintiff and Defendant 25 Nordic Track Plaintiff and Defendant 25 Christmas decorations Plaintiff and Defendant 25 Clothing (Suzanne's) Plaintiff and Defendant 25 Grill Plaintiff and Defendant NON-MARITAL PROPERTY Plain tiff lists all property in which a spouse has a legal or equitable interest which is cla imed to be excluded from marital property: {tem No. Description of Property Reason Excluded N/A PROPERTY TRANSFERRED Item Description Transfer Consid- Transferred No. of Property Date eration to Property transferred by Defendant: 2 Ghevy S-10 unknown unknown unknown 14 Sea-doo Jet ski unknown unknown unknown 14 Kawasaki Jet ski unknown unknown unknown 14 Sunbird Boat unknown unknown unknown 14 2 Boat Trailers unknown unknown unknown Property transferred by Plaintiff 2 Oldsmobile Bravada Item Description Number of Property 256 Juniper Dr 2000 $5,000 LIABILITIES Names of All Creditors GMC VA Dealership Names of All Debtors Plaintiff and Defendant SUZANNE THOMAS IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW CHARLES THOMAS NO. 2006 - NO. 2006 - 443 Defendant CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I, Janet E. Bush, hereby certify that I am on this day serving a copy of the foregoing documents upon the person(s) and in the manner indicated below: US Mail addressed as follows: Charles Thomas 895 York Road Dover, PA 17315 Date: a1 CX~ ~. Ja t E. Bush ~ ', , ~; SUZANNE THOMAS IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW CHARLES THOMAS NO. 2006 -443 Defendant CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE AND NOW, COMES, Elizabeth J. Saylor, Attorney for Plaintiff, Suzanne. Thomas, and certifies that on 1 ` ~4~~ ~~ o~Qd~ she did serve the Defendant, Charles Thomas, via certified and regular mail at 895 York Road, Dover, PA 17315 with the following: a) Cover letter to Defendant b) Plaintiff's Affidavit c) Defendant's Counter-Affidavit d) Notice of Intent to Enter Divorce. Elizabeth J. Saylor, Esquire 3800 Market Street Camp Hill, PA 17011 Date: ~ ~ 1 Q ~D C} ~ O Y ~ -;7 i: s ~r s_ ~ ~ .T..s ~ rrz' ~ , _ _ }Q ~ ~; ~~ ~~.._ L- _ _ ~ __.: -r. ~. ~ ' . ` ~~ ~ ' ~ `. ~y~ ~ -< SUZANNE THOMAS Plaintiff v CHARLES THOMAS Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2006 - 443 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under 3301(d)(1) of the Divorce Code. 2. Defendant was served with the Complaint via personal service on February 8, 2006. 3. Affidavit required by § 3301(d) of the Divorce Code was executed on May 17, 2006. The Plaintiffs affidavit was filed on May 19, 2006 and served on the Defendant on May 17, 2006. 4. There are no other related claims pending except for the Plaintiffs Petition for Bifurcation that was granted by the Honorable Judge M.L. Ebert, Jr., on April 25, 2006. I 5. The notice of intention to request entry of a divorce decree was mailed to the defendant on May 17, 2006, a copy of which is attached hereto. LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys'for Plaintiff/ / Peter J. Russo, Esquire ID # 72897 Scott A. Stein, Esquire ID # 81738 Elizabeth J. Saylor, Esquire ID # 200139 Date: (~-~y"06 w c? -:~ ~ -s, :. _, ~-~ ~ ~ ....- _ t 1 i.;=-; ~_. O _ . a:' J 'S r i C'~ _ .. ,~ J p C= '- C SUZANNE THOMAS IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIV1L ACTION -LAW CHARLES THOMAS NO. 2006 - 443 Defendant CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I, Janet E. Bush, hereby certify that I am on this day serving a copy of the foregoing documents upon the person(s) and in the manner indicated below: Regular US Mail, and addressed as follows: Charles Thomas 895 York Road Dover, PA 17315 Date: I ' ~ ~ J 6 ~~ .~. c ~ ^~ ; > C_." a 57 C~ .~ c~ _ - ._. ~,. -z~:' h) '~c, _ .. ~ :-[ SUZANPJE THQMAS IN THE COURT 6F COIVIIVION PLEG,S ®F PEaintifff :CUMBERLAND COUNTY, PEYdNSYLVANlA tr. :CIVIL ACTION -LAIN _, ^~ ,, CHARLES TiiOIi~AS NO. 2006 - 443 = - DeferMdant CIVIL TERIVi I!~ E7ivORCE GEF~TEFlCATE OF SEP.VICE ANLl NOlltr, CONES, Elizabeth J. Saylor, Attorney for Piaintifii, Suzanne. Thomas, and certifies that on ~ ` ~ ,i she did serve the Defendant, Charles Thomas, via certified and regular mail at 895 York Road, Dover, PA 17315 with the following: a) Cover letter to Defendant b) Plaintiff's Affidavit c) Defendant's Counter-Affidavit d) Notice of Intent to Enter Divorce. ~/, .., Elizabeth J. Saylor, Esquire 3800 Niarket Street Camp Hili, PA 17011 Date: r ~. SUZANNE THOMAS IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW CHARLES THOMAS NO. 2006 - 443 Defendant CIVIL TERM IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file acounter-affidavit within twenty days after this affidavit has been served on you or the statement will be admitted. AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVVRCE CODE 1. The parties to this action separated on October 2, 1998 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if 4 do not claim them before a divorce is granted. I verify that the statement 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. r r: i _ ~ Date: ~ .~~ i ~ ~ ~ ~ , c~ ~,. ,.,~' Susanne Tfiomas, Plaintiff __._, j SUZANNE THOMAS IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW CHARLES THOMAS N0. 2006 -443 Defendant CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301 (c) AND § 3301(d) 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 f 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 statement 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 falsific tion to authorities. <: Date: ~ ~ ~ (, i . ~ . ; --- ::::.S~anne'T1iomas, Plaintiff Date: Charles Thomas, Defendant SUZANNE THOMAS IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW CHARLES THOMAS NO. 2006 -443 Defiendant CIVIL Ti ERM IN DIVORCE COUNTER-AFFIDAVIT UNDER § 3301 (d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (I), (ii), or both): (i) The parties to this action have not lived separate and apart for a period of a t least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do no claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) ABOVE, I MUST ALSO FILE ALL OF MY ECONOMIC CLAIMS WITH THE PROTHONOTARY IN WRITING AND SERVE THEM ON THE OTHER PARTY. If I fail to do so before the date set forth on the Notice of Intention to request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims I verify that the statement made in this counter-affidavit are true and correct. I understand that false statement herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Date: Charles Thomas, Defendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claims for economic relief, you should not file this counter-affidavit. .-. ~? ~` ` ~ n C.: v^ :-' ~.;Y it ~w.y : t3. .? -: ,~i.r -~ L»~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. 2006-443 ,c ~~ Plaintiff VERSUS CHARLF~ THOMAS, Defendant NO. DECREE IN DIVORCE AND NOW, DECREED THAT AND SUZANNE THOMAS CHARLES THOMAS ~.~~ IT IS ORDERED AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. PLAINTIFF, DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; Equitable Distribution pursuant to order of bifurcation dated April 25, 2006 BY THE COURT: ATTEST: . ,P ~(,ysic J. ~LU~ .~! ~ _.f~lj~ ROTHONOTARY 7~~,L ~.~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff q f- Vs File No. oLddlU -~`~ ~n ~/~~~~ C INDIVORCE tdL efen~dant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/ defendant in the above matter, [select one by marking `5c" J prior to the entry of a Final Decree in Divorce, or _,/ after the entry of a Final Decree in Divorce dated ~ (yl f „z7~(,~„ hereby elects to resume the prior surname ofd A7 h~0 ~~~~~ and gives this written notice avowing hi her tention pur; to the pr 'lions of 54 P.S. 704. Date: Signature >gna of name being resumed COMMONWE TH OF PE SYLVANIA ) COUNTY OF ~h bP ~ 1 .~ On the ~ day of ~i~-, 200, before mo, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he /she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA / d~( Notarial Seal , Linda M. 8eezub, Notary Public Notary Pu lic Hampden Twp., Cumbenancs County My Canmresion Expires Oct 2t, 2008 Member, Pennaylvanla Ae6oclatlon of Notedea v c ~ ti ~ ~ `~ ~-> `=, ~:.: s; ~;, .~; .;__;: 'v LAW OFFICES OF PETER J. RUSSO, P.C. BY: Elizabeth J. Saylor, Esquire PA Supreme Court ID: 200139 3800 Market Street Camp Hill, PA 17011 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: Isaylor@pjrlaw.com SUZANNE THOMAS, Plaintiff v. CHARLES THOMAS, Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2006 - 443 CIVIL TERM IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Plaintiff Suzanne (Thomas) Martin, by and through her counsel, moves the court to appoint a master with respect to the following claims: ( )Divorce (~ )Annulment ( )Alimony ( ) Alimony Pendente Lite (X) Distribution of Property ( )Support ( )Counsel Fees ( )Costs and Expenses and in support of the motion states: (1 }Discovery is not complete as to the claims for which the appointment of master is requested. (2) The non-moving party has not appeared in the action personally. (3) The statutory ground for divorce is that the marriage is irretrievably broken. (4) The action is contested with respect to the following claims: Equitable Distribution (5) The action does not involve complex issues of law or fact. (6) The hearing is expected to take'/2 days. (7) There is no additional information relevant to the motion. Date: ~~ ~' / -a~ THE LAW OFFICE OF PETER J. RUSSO, P.C. Peter J. Russ squire lj Attorney I.D. o. 72897 John N. Papoutsis, Esquire Attorney I.D. No. 70312 Scott A Stein, Esquire Attorney I.D. No. 81738 36Elizabeth J. Saylor, Esquire Attorney I.D. No. 20013 Attorneys for Plaintiff 3800 Market Street Camp Hill, PA 17011 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff BY: Elizabeth J. Saylor, Esquire PA Supreme Court ID: 200139 3800 Market Street Camp Hill, PA 17011 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: fsaylor@pjrlaw.com SUZANNE THOMAS, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW CHARLES THOMAS, NO. 2006 - NO. 2006 - 443 Defendant CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE 1, Janet E. Bush, hereby certify that I am on this day serving a copy of the Motion for Appointment of Master and Order Appointing Master upon the person(s) and in the manner indicated below: US Mail addressed as follows: Charles Thomas 895 York Road Dover, PA 17315 ~~ J et E. Bush Date: ~d"~~ d~ ~~ ~::_'~ C _. c'Y.. (lil t°] z 1l_ ,. 4 ~ _~ ~ t' ~~ r) ~ - ~`~= _'rr -~ _ .. »-- 7,, `~~ C:~ t OCT 0 9 20D~ LAW OFFICES OF PETER J. RUSSO, P.C. BY: Elizabeth J. Saylor, Esquire PA Supreme Court ID: 200139 3800 Market Street Camp Hill, PA 17011 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: Isaylor@pjrlaw.com Attorneys for Plaintiff SUZANNE THOMAS, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, :PENNSYLVANIA v. :CIVIL ACTION -LAW CHARLES THOMAS, NO. 2006 - 443 Defendant CIVIL TERM IN DIVORCE ORDER APPOINTING MASTER AND NOW, QG~P~- /~C' , 2006, ~. ~ ~~~'er-.1~ Esquire, is appointed master with respect to the following claims: MOVING PARTY Name: Suzanne Thomas Attorney: Elizabeth J. Saylor, Esquire Attorney's Address: 3800 Market Street Camp Hill, PA 17011 Attorney's Phone#: 717-591-1755 Attorney's Fax#: 717-591-1756 Attorney's Email: IsaylorCa~pjrlaw.com Attorney's Phone: N/A Attorney's Fax#: N/A Attorney's Email: N/A Party's Address and Phone# if Not represented by Counsel: 895 York Road Dover, PA 17315 (717) 932-8035 NON-MOVING PARTY Name: Charles Thomas Attorney: N/A Attorney's Address: N/A y A '~ ~ .. ,,~.Y=~~ 1 J ~~-J~ ~ ~ ~ ~r~ S~?c~L~ ~'~ , _ _ rtiisf, ~ , :; .:~~ft LAW OFFICES OF PETER J. RUSSO, P.C. ELIZABETH J. SAYLOR, ESQUIRE PA Supreme Court ID: 200139 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 SUZANNE THOMAS, now, SUZANNE MARTIN v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW CHARLES THOMAS Defendant NO. 2006 - 443 CIVIL TERM IN DIVORCE PETITION FOR COURT APPROVAL TO WITHDRAW AS COUNSEL FOR PLAINTIFF AND NOW, comes the Law Offices of Peter J. Russo, PC, attorneys for the Plaintiff, Suzanne Martin, and files this Petition for Court Approval to Withdraw, and in support thereof, states the following: 1. Plaintiff, Suzanne Martin, is currently represented by The Law Offices of Peter J. Russo, PC. 2. On or about January 24, 2006, Plaintiff filed a Complaint in Divorce that was served on Defendant on February 8, 2006. 3. On or about March 13, 2006, Plaintiff by and through her counsel filed a Petition to Bifurcate, which upon an Order to show cause issued by the Honorable Judge M.L. Ebert, Jr and a Rule to Make Absolute filed by Plaintiff, was granted by the Honorable Judge M.L. Ebert, Jr. by Order dated Apri125, 2006. 4. Plaintiff filed an Inventory on April 26, 2006. 5. On or about June 27, 2006 a Decree in Divorce was entered by the Honorable Judge M.L. Ebert, Jr., with the Court maintaining jurisdiction over equitable distribution pursuant to Order of Bifurcation dated Apri125, 2006. 6. Upon Plaintiff s petition, on October 16, 2006, the Honorable Judge Ebert appointed E. Robert Elicker II, Esquire as master. 7. A master's hearing was scheduled for November 29, 2006 and was thereafter postponed to a later date yet to be determined. 8. On or about March 5, 2007, Plaintiff informed her Counsel that she wished to precede pro se. 9. Petitioner wishes to withdraw its representation of Plaintiff in the above captioned matter. Petitioner has informed Plaintiff that she will petition the Court to withdraw her appearance. 10. Under the Rules of Professional Responsibility Rule 1.16, Petitioner may withdraw its appearance as counsel for Plaintiff but must get Court approval. 11. It is unknown whether Defendant is represented and Defendant is currently incarcerated, thus Petitioner is unable to request concurrence for the relief requested in this Petition. 12. Petitioner is of the belief and therefore avers that the withdrawal of her representation in this matter will not delay the proceedings. WHEREFORE, Elizabeth J. Saylor, Esquire respectfully requests this Honorable Court to grant her Petition to Withdraw as Counsel for Plaintiff in the above matter. Date: ~ j ~~ Respectfully submitted, THE LAW OFFICES OF Elizabeth J. S lor,~qu: 3800 Market reet Camp Hill, PA 17011 (717) 591-1755 Attorney for the Plaintiff TER J. RUSSO, P.C. LAW OFFICES OF PETER J. RUSSO, P.C. ELIZABETH J. SAYLOR, ESQUIRE PA Supreme Court ID: 200139 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 SUZANNE THOMAS, : IN THE COURT OF COMMON PLEAS OF now, SUZANNE MARTIN :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW CHARLES THOMAS NO. 2006 - 443 Defendant CIVIL TERM IN DIVORCE VERIFICATION I, Suzanne Martin, verify that the statements made in the Petition for Court Approval to Withdraw as Counsel for Plaintiff 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. Dated: LAW OFFICES OF PETER J. RUSSO, P.C. ELIZABETH J. SAYLOR, ESQUIRE PA Supreme Court ID: 200139 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 SUZANNE THOMAS, IN THE COURT OF COMMON PLEAS OF now, SUZANNE MARTIN :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW CHARLES THOMAS NO. 2006 - 443 Defendant CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that I have on this day served a true and correct copy of the Petition for Court Approval to Withdraw as Counsel for Plaintiff upon the following persons, in the manner indicated: FIRST CLASS MAIL Suzanne Martin 217 S. 16th Street Camp Hill, PA 17011 Plaintiff Charles Thomas #GZ6476 SCI Camp Hill Box 8837 Camp Hill, PA 17001 LAW OFFICE OF PETER J. RUSSO,._P.C. BY: iza~eth J. SUZANNE THOMAS, IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-0443 CIVIL CHARLES THOMAS, DEFENDANT :CIVIL ACTION -LAW ORDER OF COURT AND NOW, this 16th day of April, 2007, upon consideration of the Petition to Withdraw as Counsel filed by the Petitioner, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Plaintiff to show cause why the Petitioner should not be granted permission to withdraw as counsel of record; 2. The Plaintiff will file an answer on or before May 7, 2007; 3. If no answer to the Rule to Show cause is filed by the required date, the relief requested by Petitioner shall be granted upon the Court's receipt of a Motion requesting Rule be made Absolute. If the Plaintiff files an answer to this Rule to Show Cause, and the answer raises disputed issues of material fact, an evidentiary hearing will then be scheduled. The Prothonotary is directed to forward said Answer to this Court. By the Court, M. L. Ebert, Jr., J. Elizabeth J. Saylor, Esquire Petitioner Suzanne Thomas Martin Plaintiff Charles Thomas Defendant ~~~~ y"7~ -~ 7 bas ,,; -;ci ~ ;~ ~,t~ 9i ti~~l~~ L~~~~ ... ~ '_ . `~.~`~h? LAW OFFICES OF PETER J. RUSSO, P.C. ELIZABETH J. SAYLOR, ESQUIRE PA Supreme Court ID: 200139 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 SUZANNE THOMAS, now, SUZANNE MARTIN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CHARLES THOMAS Defendant CIVIL ACTION -LAW NO. 2006 -443 CIVIL TERM IN DIVORCE MOTION TO MAKE RULE ABSOLUTE AND NOW, comes Elizabeth J. Saylor, Esquire, attorney for Plaintiff, Suzanne Martin, and files this Motion to Make Rule Absolute, and in support thereof, states as follows: 1. Petitioner-Attorney filed a Petition to Withdraw as Counsel on or about April 10, 2007, requesting this Court to withdraw her appearance as counsel for Plaintiff Suzanne Martin. 2. In a Rule to Show Case entered on April 16, 2007, the Honorable Judge M.L. Ebert, Jr. g:•~+nted the Defendant and Plaintiff until May 7, 2007, to file a response to Petitioner-Attorney's Petition. 3. To date, neither Plaintiff nor Defendant have filed an Answer to the undersigned counsel's petition. 4. Petitioner has not sought the consent of either the Plaintiff or Defendant as this Motion has been made in accordance with the April 16, 2007, Order of Court. WHEREFORE, Elizabeth J. Saylor, Esquire, attorney for Plaintiff Suzanne Martin, respectfully requests this Honorable Court to grant her Motion to Make Rule Absolute to allow her to withdraw as counsel of record for Plaintiff in the above matter. THE LAW OFFICES OF PETER J. RUSSO, P.C. ~~-~- 0~ Peter J.'Russo,~uire Attorney I.D. No. 72897 John N. Papoutsis, Esquire Attorney I.D. No. 70312 Scott A Stein, Esquire Attorney I.D. No. 81738 ~~ Elizabeth J. Saylor, Esquire Attorney I . D. No. 20013 Attorneys for Plaintiff 3800 Market Street Camp Hill, PA 17011 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 CERTIFICATE OF SERVICE I, Janet E. Bush, hereby certify that I am on this day serving a copy of the Motion to Make Rule Absolute upon the person(s) and in the manner indicated below: US Mail addressed as follows: Suzanne Martin 217 S. 16th Street Camp Hill, PA 17011 Plaintiff Charles Thomas #GZ6476 SCI Camp Hill Box 8837 Camp Hill, PA 17001 Date: ~ ~ ~~ ~ ~~> 7 ~a ~;"i C.. __. _~ T"?~~ ; F, ~ ~, y - ~ ....- f~",`, t ~_ -- i"ii ;~.^ ..~ ~~ ~` ~-}~ ;~ .. 5 ~IAY S 1.2001 SUZANNE THOMAS, IN THE COURT OF COMMON PLEAS OF now, SUZANNE MARTIN :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW CHARLES THOMAS NO. 2006 -443 Defendant CIVIL TERM IN DIVORCE IN RE: PETITION FOR COURT APPROVAL TO WITHDRAW AS Cf)UNSEL FOR PLAINTIFF ORDER OF COURT o~ AND NOW, this ~3 day of ~_, 2007 upon consideration of the Petitioner-Attorney's Motion to Make Rule Absolute, it is hereby ORDERED that Petitioner, Elizabeth J. Saylor, Esquire is granted leave to withdraw as counsel for Plaintiff Suzanne Martin. BY THE COURT, ~w Offices of Peter J. Russo, P.C. Elizabeth J. Saylor, Esquire 3800 Market Street Camp Hill, PA 17011 Petitioner C ~zanne Martin ~ 217 S. 16th Street Camp Hill, PA 17011 Plaintiff ~iarles Thomas #GZ6476 SCI Camp Hill Box 8837 Camp Hill, PA 17001 ~ .S ~ ~, ~! 4., Cr 1 I l.~~tr ~, i~~