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HomeMy WebLinkAbout06-1868CHERYL L. KLEEMAN, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 010 - /P?p ?iv?l??1Lh? RAYMOND G. HOLLOWAY, JR., CIVIL ACTION - LAW 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 within twenty (20) days. You are warned that if you fail to do so, the case may proceed without and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for 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, One Courthouse Square, 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 LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 CHERYL L. KLEEMAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. RAYMOND G. HOLLOWAY, JR., CIVIL ACTION - LAW Defendant IN DIVORCE NOTICIA 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 a viso o notification, y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 CHERYL L. KLEEMAN, Plaintiff vs. RAYMOND G. HOLLOWAY, JR Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 0(o - / ?F6 8 CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Cheryl L. Kleeman, an adult individual who resides at 319 Turnpike Road (Hopewell Township, Cumberland County) Newburg, PA 17240. 2. Defendant is Raymond G. Holloway, Jr., an adult individual, who resides at 4005 Riders Lane, (Upper Allen Township, Cumberland County) Mechanicsburg, PA 17055. 3. The Defendant has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 11, 1998, in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions in divorce or annulment between the parties. 6. The Defendant is not a member of the armed forces of the United States or any of its allies. 7. The Plaintiff avers that the marriage is irretrievably broken. 8. 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. The Plaintiff does not desire counseling. 9. Plaintiff requests the Court to enter a Decree of Divorce. Respectfully submitted, Dated: ?_ t( 2006 CALDWELL & KEARNS By: Carl G. Wass, quire I. D. #07268 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 Attorney for Cheryl L. Kleeman VERIFICATION I, Cheryl L. Kleeman, verify that the averments made in this Complaint are true and correct to the best of my knowledge, information and belief. 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: 4ry le an 05-790/97510 N ? O F1 /// T{ / R? ? C ? ',== III`\? in s Cr 1 CHERYL L. KLEEMAN, Plaintiff, VS. RAYMOND G. HOLLOWAY, JR., Defendant TO THE PROTHONOTARY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 06-1868 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE. Please enter the appearance of the undersigned as attorney for the Defendant, Raymond G. Holloway, Jr. Date: r 4Shana M. ug h, Es u re ffice of Patric F. Lauer, Jr., LLC 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011 (717) 763-1800 - Office ID # 200952 05-790/101590 N 4 tl? cm CHERYL L. KLEEMAN, Plaintiff, VS. RAYMOND G. HOLLOWAY, JR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 06-1868 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE. ACCEPTANCE OF SERVICE I accept service of, and acknowledge receipt of, a certified, true and correct copy of the Complaint in Divorce under Section 3301(c) or 3301(d) of the Divorce Code. I further certify that I am authorized to accept service on behalf of the Defendant. Date: Shana M. Pugh, Es 're Law Office of Patric F. Lauer, Jr., LLC 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011 (717) 763-1800 - Office ID # 200952 05-790/101589 o c AT - . t5 , D N W r v e Carl G. Wass, Esquire Attorney I.D. No. 07268 CALDWELL & KEARNS 3631 North Front Street Harrisburg, PA 17110 717-232-7661 Attorney for Plaintiff CHERYL L. KLEEMAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 06-1868 CIVIL TERM RAYMOND G. HOLLOWAY, JR., Defendant CIVIL ACTION LAW - IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action finally separated on or about November 23, 2005, and have continued to live separate and apart for a period of two years or more. 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 I do not claim them before a divorce is granted. 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. Date: Jo,? ,Z.oo 1;?' (SEAL .r . .v CERTIFICATE OF SERVICE AND NOW, this k S 4 day of , 2007, I hereby certify that I have served a copy of the within document on the followm y depositing a true and correct copy of the same in the U.S. Mails at Harrisburg, Pennsylvania, postage prepaid, addressed to: Raymond G. Holloway, Jr. 4005 Riders Lane Mechanicsburg, PA 17055 Raymond G. Holloway, Jr. c/o: Mr. and Mrs. Raymond G. Holloway 39 Mountain Road Carlisle, PA 17013 Shanna M. Pugh, Esquire Law Office of Nora F. Blair 5440 Jonestown Road PO Box 6216 Harrisburg, PA 17112-0216 CALDWELL & KEARNS By 126649 <a -t CHERYL L. KLEEMAN, IN THE COURT OF COMMON PLEASE Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 2006-1868 Civil Term RAYMOND G. HOLLOWAY, JR, CVIL ACTION -LAW Defendant IN DIVORCE MOTION TO WITHDRAW APPEARANCE AND NOW comes Shana M. Pugh, Esquire, and files the following Motion to Withdraw Appearance, and in support thereof avers as follows: 1. Undersigned Counsel was retained by Defendant Raymond G. Holloway, Jr. in this matter on or about March, 2006 while employed by the Law Offices of Patrick F. Lauer, Jr., LLC. 2. Undersigned Counsel also represented Defendant in a custody action docketed at 06-668. 3. Following litigation pertaining to the aforementioned custody action, Defendant no longer desired to be represented by your undersigned counsel. 4. Undersigned counsel signed a Preacipe to Withdraw on May 18, 2006. 5. Undersigned counsel has not had any meaningful contact with Defendant since that date. 6. Undersigned counsel has not been employed by the Law Offices of Patrick F. Lauer, Jr., LLC since on or about October 2006. 7. Undersigned counsel was unable to contact Defendant by telephone. 8. Undersigned counsel is not in a position to litigate the divorce matter as counsel is currently employed by MidPenn Legal Services. WHERFORE, Shana M. Pugh, Esquire, respectfully requests this Court allow her to withdraw as counsel of record for Raymond G. Holloway, Jr. Respectfully submitted, 01W&IM I 94-wwj??/ Date Shana M. Pugh, Esquire Supreme Ct. ID 200952 MidPenn Legal Services, Inc. 230 Lincoln Way East, Suite A Chambersburg, PA 17201 (717) 264-5354 ext. 2307 Attorney for Defendant CHERYL L. KLEEMAN, IN THE COURT OF COMMON PLEASE Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 2006-1868 Civil Term RAYMOND G. HOLLOWAY, JR, CVIL ACTION - LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Shana M. Pugh, Esquire, hereby certify that I served a true and correct copy of Motion to Withdraw as Counsel, via regular first-class mail, postage pre-paid to counsel for Plaintiff and to Defendant at his last known address, on this 23'' day of 2008, as follows: Raymond G. Holloway, Jr. 4005 Rider Lane Mechanicsburg, PA 17055 Carl G. Wass, Esquire 3631 North Front Street Harrisburg, PA 17110 Respectfully submitted, Date Shana M. Pugh, Esquire Supreme Ct. ID 200952 MidPenn Legal Services, Inc. 230 Lincoln Way East, Suite A Chambersburg, PA 17201 (717) 265-5354 ext. 2307 Attorney for Defendant T ri? ~ flo ?: F. i CHERYL L. KLEEMAN, IN THE COURT OF COMMON PLEASE Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 2006-1868 Civil Term RAYMOND G. HOLLOWAY, JR, CVIL ACTION -LAW Defendant IN DIVORCE AMENDED MOTION TO WITHDRAW APPEARANCE AND NOW comes Shana M. Pugh, Esquire, and files the following Amended Motion to Withdraw Appearance, and in support thereof avers as follows: 1. Undersigned Counsel was retained by Defendant Raymond G. Holloway, Jr. in this matter on or about March, 2006 while employed by the Law Offices of Patrick F. Lauer, Jr., LLC. 2. Undersigned Counsel also represented Defendant in a custody action docketed at 06-668. 3. Following litigation pertaining to the aforementioned custody action, Defendant no longer desired to be represented by your undersigned counsel. 4. Undersigned counsel signed a Preacipe to Withdraw on May 18, 2006. 5. Undersigned counsel has not had any meaningful contact with Defendant since that date. 6. Undersigned counsel has not been employed by the Law Offices of Patrick F. Lauer, Jr., LLC since on or about October 2006. 7. Undersigned counsel was unable to contact Defendant by telephone. 8. Undersigned counsel is not in a position to litigate the divorce matter as counsel is currently employed by MidPenn Legal Services. 9. Undersigned counsel contacted Carl Wass, Esquire, counsel for Plaintiff and received his concurrence in this Motion. 10. This matter has not been ruled upon, however, a Custody Complaint was filed by Raymond G. Holloway, Jr., docketed at number 06-668, and ruled upon by Judge M.L. Ebert, Jr. WHERFORE, Shana M. Pugh, Esquire, respectfully requests this Court allow her to withdraw as counsel of record for Raymond G. Holloway, Jr. D to Respectfully submitted, 54 (D K ri Shana M. Pugh, Esquire Supreme Ct. ID 200952 MidPenn Legal Services, Inc. 230 Lincoln Way East, Suite A Chambersburg, PA 17201 (717) 264-5354 ext. 2307 Attorney for Defendant CHERYL L. KLEEMAN, : IN THE COURT OF COMMON PLEASE Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 2006-1868 Civil Term RAYMOND G. HOLLOWAY, JR, CVIL ACTION - LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Shana M. Pugh, Esquire, hereby certify that I served a true and correct copy of Motion to Withdraw as Counsel, via regular first-class mail, postage re-paid to c unsel for Plaintiff and to Defendant at his last known address, on this day of 14 11/) N1 1) 2008, as follows: 19 0 Raymond G. Holloway, Jr. 4005 Rider Lane Mechanicsburg, PA 17055 Carl G. Wass, Esquire 3631 North Front Street Harrisburg, PA 17110 Respectfully submitted, Date and M. Pugh, Esquire Supreme Ct. ID 200952 MidPenn Legal Services, Inc. 230 Lincoln Way East, Suite A Chambersburg, PA 17201 (717) 265-5354 ext. 2307 Attorney for Defendant ? ° ?- i ? M1 ? c.... ? ??. "?j ???,y W - ?? ^? ?~ i ,! ter ?? 1VJ-j0 . ' ??? ii? ?? ?,.a CHERYL L. KLEEMAN, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. RAYMOND G. HOLLOWAY, JR., : NO. 06-1868 CIVIL ORDER OF COURT AND NOW, this 7th day of February, 2008, upon consideration of the Motion to Withdraw Appearance filed by Shana M. Pugh, Esquire, on January 23, 2008, and her Amended Motion to Withdraw Appearance filed January 31, 2008, IT IS HEREBY ORDERED AND DIRECTED that Petitioner's Motion to Withdraw as Counsel of Record for Raymond G. Holloway, Jr., is GRANTED. By the Court, Xhana M. Pugh, Esquire Petitioner Xarl G. Wass, Esquire Attorney for Plaintiff ?faymond G. Holloway, Jr. Defendant bas M. L. Ebert, Jr., J. N9d C 0 M d C- 03.E $08Z EHI AO IN THE COURT OF COMY-ON PLEAS OF CL'MBERLAND COUNTY, PENNSYLVANIA C dt-- kL a m,4,&j Plaintiff VS. -T11 A y b?l(?ks X'?) SQL: DE T?- -T No. IS`P 19 :MOTION FOR APPOINM= OF MASTER (Plaintiff) (Defendant), moves the court to appoint a master with respect to the following claims: ( ) Divorce (X Distribution of Property ( ) Annulment ( ) Support ( ) Alimony ( ) Counsel Fees ( ) Alimony Pendente Lite ( ) Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claims(s) for which the appointment of a master is requested. (2) The defendant (has) (has not) appeared in the actin (personal ) (by his attorney, Esquire (3) The staturory ground(s) for divorce (is) (are) Liu rz 1,46C J:-s ZL2 ?tl TrL?E` y ?+8? tz0&&/N (4) Delete the inapplicabl 4 paiagraph(s): (a) The action is not contested. (b) An agreement has been reached with respect to the following claims: (c) The action is contested with respect to the following claims : G o t^ z c Q .- / te e 'F ) The action (involves) (does not involve) complex issues of law or fact. (6) The hearing is expected to take (7) Additional information, if any. (hours) (days). relevant to the motion: Date : 91.3 -7 Attornev for (Plaintiff) (Defendant) ORDER APPOINTING ASTER AND NOW ,19 Esquire, is appointed master with respect to the following claims: By the Court: i N ?"? -?c-t a , 1 y a. •+ . 't x ' '? --r^g ?'7 . ? S;k ,..r. ' ..,?.Z 1 -. ...a. ,• , 'S't ...? ??;?:.:. ("? ice-`. :.•# ? ?. CHERYL L. KLEEMAN, Plaintiff vs. RAYMOND G. HOLLOWAY, JR., Defendant : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA No. 06-1868 CIVIL TERM CIVIL ACTION - AT LAW DIVORCE DEFENDANT'S PETTTION FOR RELATED CLAIMS PURSUANT TO PA.R.C.P.1920.15(b) AND NOW, comes the Defendant, Raymond G. Holloway, Jr., and respectfully represents as follows in support of this Petition: 1. The Petitioner is the Defendant above-named, Raymond G. Holloway, Jr., currently residing at 4005 Rider Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The Respondent is the Plaintiff above-named, Cheryl L. Kleeman, currently believed to be residing in Halifax, Dauphin County, Pennsylvania. 3. The Plaintiff and Defendant were married on July 11, 1998. 4. Plaintiff filed a Complaint in Divorce to the above caption and number on March 30, 2006. EQUITABLE DISTRIBUTION OF PROPERTY 5. Paragraphs 1 through 4 above are hereby incorporated herein be reference as though fully set forth. 6. The parties acquired "marital property" as defined under the Divorce Code during the course of their marriage. 7. In order to effectuate economic justice between the parties, Petitioner requests this Honorable Court to enter a fair and just determination and settlement of the parties' property rights. WHEREFORE, Petitioner requests this Honorable Court to equitably divide and distribute the "marital property" of the parties in accordance with the Divorce Code. RESPECTFULLY SUBMITTED: Raymond G. Holloway, Jr. 4005 Riders Lane Mechanicsburg, PA 17055 Phone: (717) 623-4913 DEFENDANT, pro se Dated: 3 s" 8 VERIFICATION I, Raymond G. Holloway, Jr., Defendant in the above-captioned case, hereby swear and affirm that the statements contained in the foregoing Petition are true and correct to the best of my knowledge, information and belief. I understand that false statements herein and are made subject to the penalties of 18 Pa.C.S. 4904 relating to unworn falsification to authorities. Raymond G. Holloway, Jr. 4005 Riders Lane Mechanicsburg, PA 17055 Phone: (717) 623-4913 DEFENDANT, pro se /'VY5-/0 ' DATED: 3 CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Petition to the person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of the same with the United States Post Office at Camp Hill, Pennsylvania, through first ctass mail, prepaid, and addressed as follows: Carl G. Wass, Esquire CALDWELL & KEARNS 3631 North Front Street Harrisburg, PA 17110-1533 Raymond G. Holloway, Jr. 4005 Riders Lane Mechanicsburg, PA 17055 Phone: (717) 623-4913 DEFENDANT, pro se Dated: 3 AS 1-0 9 Y a ftl _-" ? C) fi CHERYL L. KLEEMAN, Plaintiff vs. RAYMOND G. HOLLOWAY, JR., Defendant THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 06-1868 CIVIL TERM : CIVIL ACTION - AT LAW : DIVORCE COUNTER AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): ? (a) I do not oppose the entry of a divorce 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 at least two years. ? (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): ? (a) I do not wish to make any claim for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees, or expenses or other important rights. I hereby verify that the statements made in this Counter-affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: o? S Signature://` 1 RAYM D G. HOLLOWAY, J . ? rx? p ,_ y t k.: ?t ,?i IN THE COURT OF COMMON PLEAS OF O? CUi-fBERLAND COUNTY, PENNSYLVANIA C&ieq _ i-,kL.e(- (o,4 /,j Plaintiff VS. NO. a( - 181.g 19 MOTION FOR APPOINT.%= OF MASTER (Plaintiff) (Defendant), moves the court to appoint a master with respect to the following claims: ( ) Divorce (X Distribution of Property ( ) Annulment ( ) Support ( ) Alimony ( ) Counsel Fees ( ) Alimony Pendente Lite ( ) Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claims(s) for which the appointment of a master is requested. (2) The defendant (has) (has not) appeared in --""? the actin (personally) (by his attorney, Esquire (3) The staturory ground(s) for divorce-(is) (are) M,jg 121,466' -rS ?i21t1 TrL ?E' ?+8? U :?2& c, - (4) Delete the inapplicabl paragraph(s): (a) The action is not contested. (b) An agreement has been reached with r espect to the following claims: (c) The action is contested with respect to the following claims: ?G v -,'b A ZC 04/ -vcET (5) The action (involves) (does not involve) complex issues of law or fact. (6) The hearing is expected to take (hours) (days). (7) Additional information, if any. relevant to the motion: Date: 3137 Attorney for (Plaintiff) (Defendant) ORDER APPOINTING MASTER AND :TOW ?6-AmJ q _, 04 Esquire, is appointed master with respect to the following claims: a It ?? V W J ~ CHERYL L. KLEEMAN Plaintiff THE COURT OF COMMON PLEAS OF CUMBRELAND COUNTY, PENNSYVANIA : No.06-1868 CIVIL TERM vs RAYMOND G. HOLLOWAY, JR., Defendant : CIVIL ACTION - AT LAW : DIVORCE DEFENDANT'S PETITION FOR EQUITABLE DISTRIBUTION OF PROPERTY PURSUANT TO P.R.C.P.1920.33 Q?j AND NOW, comes the Defendant, Raymond G. Holloway, Jr. pro se, and moves this Honorable Court to award him the following claims 1. Copies of all photos taken during marriage July 11,1998 and March 30,2006 To include (couple, children, family, and vacations) 2. Equal distribution of moneys contributed to Cheryl Kleeman's retirement during course of marriage July 11, 1998 -November 23, 2005. (Amount to be determined) 3. Remaining balance of 1 year lease signed by Cheryl Kleeman on May 11, 2005; 7 months remaining on lease. Total $7875.00. Cheryl's Y2=$3937.50 4. Attorney fees for custody case involving Hannah Rose Kleeman (During course of marriage, Cheryl promised that Hannah would never be taken away from Defendant). Amount of $ 14,982.23 with additional fees forthcoming in continued case. Defendant proposed resolution: A. Partial custody of Hannah Rose Kleeman B. Copies of all photos listed above. C. Forgiveness of all monetary obligations above. Dated RESPECTFULLY SUBMITTED: By? I ------- 7_? --- Xr Raymond G.Holloway,Jr. 116 Front St. Enola, Pa. 17025 Phone: (717) 623-4913 DEFENDANT, pro se r-? C"a ? ? ?,?- ? -erg' ? .}??.; w t?- „.. --? ;, {'> ?, - ;.?+, ,.r?is? %' t:,:". ?. Carl G. Wass, Esquire Attorney I.D. No. 07268 CALDWELL & KEARNS 3631 North Front Street Harrisburg, PA 17110 717-232-7661 Attorney for Plaintiff CHERYL L. KLEEMAN, Plaintiff vs. RAYMOND G. HOLLOWAY, JR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06-1868 CIVIL TERM CIVIL ACTION LAW - IN DIVORCE INVENTORY AND APPRAISEMENT OF CHERYL L. KLEEMAN Plaintiff, Cheryl L. Kleeman, files the following inventory and appraisement 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 and appraisement 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. Dated: e . KI a an, Plaintiff ASSETS OF PARTIES Plaintiff, Cheryl L. Kleeman, marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. If an item has been appraised, a copy of the appraisal report is attached. () 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. Patents, copyrights, inventions, royalties () 14. Personal property outside the home () 15. Businesses (list all owners, including percentage of ownership, and officer/director positions held by a party with company) () 16. Employment termination benefits--severance pay, workman's compensation claim/award () 17. Profit sharing plans (x) 18. Pension plans (indicate employee contribution and date plan vests) () 19. Retirement plans, individual retirement accounts () 20. Disability payments () 21. Litigation claims (matured and unmatured) () 22. MilitaryN.A. benefits () 23. Education benefits () 24. Debts due, including loans, mortgages held () 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute () 26. Other -l O U7 A W N 7- Z -i o m 0 G) CD nm ?? C co - acfl N 3 m 3 M 0 -o CD m m N toil - ? m - ?S . ? ? fl ? 3 Ov w n cQ 0 5 o tQ °? fA m m0 m m ao W 0 T n -n N N j- n -0 ?n Ul I o c C7 O n o m 0 29 -0-0 C C 00 Q Q N ; . . - O ?z ? v x V/ m Z 90 90 m Xm O o?? o 0 o mm 0 0 ?nm yam vv ?v ?v -a3 v 0y c a3 N ?a3 7m 0 SM Ynm CD 4) -1 v N O , r« fl ? O w cG O Q: (D O `< co OD m Q q o o m OD (p O o (a ? O O :3 7 . (p Z ? v v v o .69 =L =L ? ?? 00 O o rt r-+ r O O n n n C/) D O - O - O - 0c zm N N v v N D m {fig m m ° -' 0 T cn o + OD 3 D -1 c 0 N -69 ?? 3 3 n O? N mzz> 0 + & way o a 0 0 0 Ln 0 o Zo o 0 0 0 0 0 -n c z -I D r c 0 0 0 0 0 0 o m? Zm O T Ox v O D O O O O O O O rrr ; mmm z ;o 90 CO) N N Efl CO) e O O CA N O 0 = O m O O OD O m (J C? O O O O) W --4 m z ?m + Q a -i a v N c' T m v ~. v 0 O N o 3 su m 3 M. m_0 a? O -a CD CD m 0 O 3 N D N CD O ? r N m ? O m ? (O m R ;u O m .Q C v (D CD m CA. 5' a c v O v 0 CD v m a N O O N o, CD W N ? m Z O O m :3 ;o CD 7 ;o Om v (n o' = != ? 0 0) mom mm3 o? 0 3 ;o 5 3 m? < S' mo CD CD ?O CCD N N? ?z c ? C < C < C < m m O m D A v N CD N 3-0 C 0-o N %< cn m =1 O Ai fl1 (D O m (o z O O OD co O 0<0 cu ANN 2 m o o C m O =ii 0 O?? z 0 CD 0 ¢ O -690 o ^ 0) m 490 3 w C O N-1 m 0)N^ ° ? CD CDD0 v ^* DD v n r N 0= l N o S 3 -DiOm - < -, N O 3(D M < N 1 t0O =4 0 ODIC.. (D ? M Z -Dj O O- 6`< Q W? N v O) a? 0 CL CD O c CD - •.• CJ1 D 0 O p r OO j -n C Z - -? z rD z ?D 5 O O O rC :3 o mz zm 0 - 0 9C ? OQv - D 3m v o O O :r mmm o' o0i « C z 90 ? - sv » U) N cn N = CD O xD y N 3 w cn II1 S1 C C Cl) cn -n O N sy .v 0 a (D n sv cn -v 0 C N (D O cn N (D f0 O O N s= v CY (D CCD rn 0 S N' 0 T 3 (D 0. O a (D (D X 0 c Q (D Q 0 3 w v .0 0 CD z O z D D r T X "0 D m X -? z =i Om O N 00 =T CD -n m < -0 C/) m n < m - v ;o o ?z c? S (D O rnm D n O p C) to m N ?O OT Z 10 Q O -1 n O? n z m D ? r o czn m -n D m? O m D O C Z Z O C (D D a rC p M o zm O O T n S a1 CD O ? O? 2 N ?i m O O O M n O (Q O (D N a ?. ? N (D v .O CD A CD N N CD ? CD 3 O CD S CD I O S O N O c CO) CD W S O a O cD cfl N O m c C1 Q CD R. N O a CL C N 'G O S O O (D CD N O D) 7 a S n S S O CO) S (D (D O LIABILITIES OF PARTIES Plaintiff, Cheryl L. Kleeman, marks on the list below those items applicable to the case at bar and itemizes the liabilities on the following page. SECURED () 1. Mortgages (x) 2. Judgments () 3. Liens () 4. Other secured liabilities UNSECURED (x) 5. Credit card balances ( ) 6. Purchases (x) 7. Loan payments () 8. Notes payable (x) 9. Other unsecured liabilities CONTINGENT OR DEFERRED () 10. Contracts or Agreements () 11. Promissory notes () 12. Lawsuits () 13. Options () 14. Taxes () 15. Other contingent or deferred liabilities 9) p W N ' Q ? < ? m c -4 CD w v ' 3 C- c Vi 0 fn D -0 0 2) w0 =r 00 -ncn N or D C CL co r- m O w n o" Q m m ?? mOrr 3 O Cl) cCL mv- i Q CD .? 2 = ._« CY c O O O O = ?Z 7 m O Q 7 O 7 CL CCD N D CD D 3 m -"I' m M 3 ai co m O 0 m 'a] , -? m m m 0 m 0 O z 0 T r« .< `. n N C C H O - C Q O n C ai vm y C C C G C G C < O 0O ?m 0 o 0 CD K c O (a cQ cQ z r N n 3 O O O O C03 42 O ? = a- ? a ;a m N O W 6 p C) N 2 n' U 0 0 0 v a v O i OD Q a Q 0) m m? m? o m co) 0 CD m 7 0 4010 N 4A :3 O O 9J .69 ?ZC C N N) D a -& ZZ a- O< S11 3 .. C O N O O ( W O O c M OD O O OZCO -4 020 -n ?tU m n OQ -? -A -A dJ -4 O CO pr.m? M .n m m O .r ? O O W + U7 "? O 0 Z >!p C0°"° (D O .60 ?N Opz C: ? C 0 0 O Cn U1 -A O `O T O Ut N N N na0 n 00 n00 D O Wv : cn O O rn cn O O m cv O m av O N cv z - C mom :3 -69 -Al Z Z Z < M O o O 3 f' p W <m m ? ? ? O 3 cn m cz0 CD m m 17 3: 3 c =F o Z?C O !!1 M 0 ED s CD I O 1 cr 0 3 CO O C O CD O O 0 O CD O m v CD O O 73 O O O 3 CD Q 0 m 3 CO) N 0 O N O O 3 3 m n CD O- r D m cn "hs COMMONWEALTH OF PENNSYLVANIA STATE EMPLOYEES' RETIREMENT SYSTEM HARRISBURG REGIONAL COUNSELING CENTER 30 NORTH THIRD STREET, ROOM 319 HARRISBURG, PA 17101 TELEPHONE: (717) 783-9065 FAX: (717) 783-9599 TOLLFREE: 1-800-633-5461 www.sers.state paxs June 26, 2008 CHERYL L. KLEEMAN PERSONAL AND CONFIDENTIAL 301 N SECOND ST. HALIFAX PA 17032 Dear Ms. Kleeman: W SSN: XXX-XX-1989 Responding to your inquiry regarding the value of your retirement account with the State Employees' Retirement System, I provide you with the following summary of member contributions and interest: Value of Account as of July 11,1998* Total Contributions and Interest $10,262.01 Years of Credited Service _ 8.8222 rs *Since you were not vested in our System as of the above date, the only value to your account is our accumulated contributions plus the interest the have earned. Value of Account as of January 19, 2001: Total Contributions and Interest $15,024.61 Present Value $46,530.28 Final Average Sala $27,001.37 Maximum Single Life Annuity _ $184.65 Years of Credited Service 11.3361 rs Value of Account as of December 4 2004: Total Contributions and Interest $26,738.80 Present Value $107,724.90 Final Average Sala $37,359.38 Maximum Single Life Annuity $427.76 Years of Credited Service 15.2028 rs Value of Account as of November 24, 2005: Total Contributions and Interest $30,434.88 Present Value $127,585.37 Final Average Sala $39,991.78 Maxmum Sin le Life Annuity $510.56 Years of Credited Service 16.1833 yrs Value of Account as of June 28 2008: Total Contributions and Interest $41,685.25 Present Value $193,657.30 Final Average Sala $46,897.91 Maximum Single Life Annuity $792.37 Years of Credited Service 18.8454 rs Sincerely, Jane Kuklish Regional Manager Enclosures: divinf.mem; sample DRO; SERS-157 cc: SERS Region active files; Scanned - DRO Correspondence/historical Scanned - DRO correspondence/historical I I 5v t.. 2(c, 00 (..2 is r.1 Z..-,. i A,4 A15- \?._/ A /O ?( - l 01 ?24+.90 i `4S, g(.(o, -73 ; XD -M 1%Ok, e`f'Q.JTT?C? QRV? \00.94 Q1? i '?KgM a? ?lE 5??. ?f }t! l if, ?? c? e.? ", -,h t'" ids --d .? t__- - t : -r} ? . ' ...- t ? ,. ...? l , s" ?. «-, .. } ? ? ,?, . ? . 'r . . -?-" :. r g,,,' Carl G. Wass, Esquire Attorney I.D. No. 07268 CALDWELL & KEARNS 3631 North Front Street Harrisburg, PA 17110 717-232-7661 Attorney for Plaintiff CHERYL L. KLEEMAN, VS. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA RAYMOND G. HOLLOWAY, JR, Defendant : NO. 06-1868 CIVIL TERM : CIVIL ACTION LAW - IN DIVORCE INCOME AND EXPENSE STATEMENT OF PLAINTIFF CHERYL L. KLEEMAN Plaintiff, Cheryl L. Kleeman, files the following Income and Expense Statement and verifies that the statements made herein 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. Dated: ZP-AO-08) Chery . Kleem n, Plaintiff 1 INCOME: Employer: Commonwealth of Pennsylvania Address: Labor & Industry Building Harrisburg, PA 17120 Type of Work: Manager, Procurement Division Payroll Number: 00127019 Pa Period (Weekly, Biweekly, etc.: Biweekly Gross Pa Per Pa Period: $1,863.00 Itemized Payroll Deductions: Federal Withholding 210.14 Social Security 114.92 Local Wage Tax 18.54 State Income Tax 56.91 Retirement 116.44 Savings Bonds 50.00 Credit Union Life Insurance Health Insurance MEDICARE 26.88 Unemployment Compensation 1.12 "Local Services Tax" 2.00 Deferred Compensation 25.00 SECA (Charity) 8.00 Miscellaneous 9.32 NET PAY PER PAY PERIOD: $1,223.73 OTHER INCOME: WEEK MONTH YEAR Interest estimated average) $23.00 Dividends estimated average) Pension estimated average) Annuity Social Security Rents Royalties Expense Account Gifts Unemployment Comp. Workmen's Comp. TOTAL INCOME $23.00 EXPENSES: WEEK MONTH YEAR HOME Mortgage/Rent 200.00 Maintenance Utilities Electric Gas Oil 100.00 Telephone 53.00 Water Sewer EMPLOYMENT Public Transportation Lunch 50.00 TAXES Real Estate Personal Property 25.00 Income INSURANCE Homeowners Automobile 116.00 Life Accident Health Other AUTOMOBILE Payments 450.00 Fuel 270.00 Repairs 25.00 MEDICAL Doctor 15.00 Dentist Orthodontist Hospital Medicine Special Needs (glasses, braces, orthopedic devices EXPENSES: WEEK MONTH YEAR EDUCATION Private School Parochial School College Religious PERSONAL Clothing 80.00 Food 228.00 Barber 19.00 CREDIT PAYMENTS Credit Card Charge Account Memberships 6.00 LOANS PSECU - PSL Members 1St 60.00 255.20 Interest on Invest. Margin MISCELLANEOUS Household Help Child Care 42.00 Papers/Books/Magazines Entertainment 16.00 Pa TV Vacation 85.00 Gifts 25.00 Le al Fees 383.00 Charitable Gifts 66.00 Spousal Support Storage Unit 45.00 TOTAL EXPENSES $2,614.20 PROPERTY OWNED: Description Value Ownershi * H W J Checking Accounts $760.00 X Savings Accounts 109.83 X Credit Union Stocks/Bonds Real Estate Other TOTAL $869,83 INSURANCE: Company Policy No. Ownership* H W C Hospital Blue Cross Capital Blue Cross Group No. PFP361 X X Other Medical Blue Cross Other Health/Accident Disability Income Dental Via Commonwealth of Penns Ivania x X Other-Life/Eye *H=Husband; W=Wife; J=Joint; C=Child 134977 2008-`06-27 08:03 >> 7172340857 P 2/3 Commonwealth of Pennsylvania EMPLOYEE PAY STATEMENT jCheryl L haeeman Personnel Number_.. 00127019 1301 N 2nd Street (Labor & Industry Pyri Area 2 ]Halifax PA 17032 IPay Period.. 0$/31/2008 - 06/13/2008 ] IFed Tax Status: Single ] IFed Tax Allowances: 02 Period: 13/2008 IB/U:A3 Group-07 Level:10 I I 'I- I Ray Date Payment Amount - Gross + Reim_ - Taxes - Dada. ] 06/27/2008 1,223.73 = 1,863.00 -4 0.00 - 430.51 - 208.76 I ]Gross current Pay Rate Firs/unt Amount Year To Date INormal working hours 24.84 74.00 1,638.16 20,092.14 I ]Annual Leave Pay 1,333.80 I IPaid-Office Closing 49.66 I6ick Leave Pay 1,602.18 ]Personal Leave Pay 24.84 1.00 24.84 134.10 ] (Holiday/Comp lieu Holiday 923.10 ] ]Total Gross I 1,863.00 24,135.00 j I ]Taxes Amount Year To Date IFederal Tederal ]TX Withholding Tax 210.14 2.712.24 I JTX EG Social Security Tax 114.92 1,488.88 I ]TX BE Medicare Tax 26.88 346.21 I Istate Pennsylvania I ITX Withholding Tax 56.91 737.27 I ITX 88 Unemployment Tax 1.12 14.48 I (Local Halifax Township ITX Withholding Tax 18.54 240.18 I (Local Harrisburg ITX Local Services Tax 1 2.00 26.00 I I IEE Taxes I 430.51 5,567.26 I ] IDeductions I Amount Year To Date i IEE PreTx M/H Pct 9.32 120.74 I IDeferred compensation 25.00 325.00 ] ISeries T Bonds 50.00 650.00 Ist Emp Comb Appeal (SECA) S.OD 104.00 I ]Full Cov Class AA/Cat 0 I 116.4& 1,508.46 ] I ITotal Deductions I 208.76 2,708.20 I I INon cash compensation Amount Year To Date I I i 2008-06-27 08:03 >> 7172340857 P 3/3 Commonwealth of Pennsylvania EMPLOYEE PAY STATEMENT I I IReimbuxsementS Amount I I I I I IDirect Deposit Bank / Check Amount I I i (Net Payment 130.00 I INet Payment I 1,093.73 I i (State Paid Benefits Amount I I ITx ER Social Security Tax 114.92 ITX ER Medicare Tax 26.88 IER Basic Life 5.19 I (Annuitant Med Hospital 240.00 I IER Workers Comp Benefit 35.26 I IPR Slue Cross PPO 330.00 IER-sER6 l 61.11 I I (Federal Taxable Wages Amount I I I ICurrent Period Results 1,712.24 I I I IGarnishment Type Beg Balance Total To Date Remain Balance I I I I IPayroll Area Z2 I I I t-- l? Carl G. Wass, Esquire Attorney I.D. No. 07268 CALDWELL & KEARNS 3631 North Front Street Harrisburg, PA 17110 717-232-7661 Attorney for Plaintiff CHERYL L. KLEEMAN IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 06- 1868 - CIVIL RAYMOND G. HOLLOWAY, JR. IN DIVORCE Defendant CIVIL ACTION - LAW PETITION REQUESTING BIFURCATION OF CIVIL ACTION IN DIVORCE AND NOW comes Cheryl L. Kleeman, Plaintiff, by and through her attorney, Carl G. Wass, Esquire, Caldwell & Kearns, P.C., and respectfully petitions Your Honorable Court to bifurcate the present action in divorce so as to separate the status of the continued marriage of the parties to each other from the resolution of the single claim of "Equitable Distribution" of marital property raised by the Defendant and to permit, upon request, the entry of a Decree in Divorce, but retaining jurisdiction over the economic issue of Equitable Distribution, and, in support thereof, Plaintiff avers as follows: Plaintiff filed her "Complaint Under Section 3301(c) or 3301(d) of the Divorce Code" on March 30, 2006. 2. Service of the Complaint in Divorce was accepted by the attorney representing the Defendant, to wit: Shana M. Pugh, Esquire, on April 10, 2006, said ACCEPTANCE OF SERVICE having been filed of record on May 15, 2006. Thereafter, pursuant to an Order of Your Honorable Court, dated February 7, 2008, leave was granted to the said Shana M. Pugh, Esquire, to withdraw her appearance and such withdrawal has been accomplished. 3. The Plaintiff and Defendant were married on July 11, 1998. From the date of their marriage to the date of the filing of this Petition, the parties have been separated for a longer period of time then that period of time during which they cohabited with each other. More specifically, the periods of cohabitation and separation are set forth as follows: a. The parties resided together from 7/11/1998 to 1/19/2002; b. The parties were separated from 1/19/2002 to 12/4/2004; C. The parties cohabited from 12/4/2004 to 11/23/2005; and, d. The parties have remained separated from 11/23/2005 to the date of the filing of the within Petition. In summary, the parties have been in a married state to and with each other for a period of time slightly less then eleven years; have cohabited for a period of time slightly less then three and one-half years; and, have been separated for almost seven and one-half of those years, finally separating from each other on November 23, 2005, more then three and one-half years ago. 4. During the lengthy period of separation of the parties which occurred between January 19, 2001 and December 4, 2004, the Plaintiff became pregnant to an unidentified male and gave birth to her only child, Hannah Rose Kleeman, who was born on March 25, 2002. 5. Following the final separation of the parties, the Defendant, knowing that he was not, and could not be, the natural father of Hannah Rose Kleeman, filed a Complaint seeking 4 custody of the minor child, Hannah Rose Kleeman, said Complaint being docketed to the Court of Common Pleas of Cumberland County, No. 06-668 Civil Term. 6. Following several hearings before the Honorable M. L. Ebert, Jr., the Judge entered a final Order which placed full legal and physical custody of Hannah Rose Kleeman in the hands of her natural mother, the Plaintiff in this case, Cheryl L. Kleeman, and denied any partial physical custody of the minor child to Raymond Halloway. 7. An appeal from the Order entered by Judge Ebert on June 21, 2006 was filed with the Superior Court of Pennsylvania and, thereafter, a Memorandum Order of the Superior Court was filed on April 18, 2007 which AFFIRMED the Order entered by Judge Ebert. 8. During the period of time while the parties were involved in the litigation regarding the custody of Hannah Rose Kleeman, there was no activity whatsoever taken by either party pertaining to the pending action in divorce, the only documents appearing of record being the Complaint in Divorce and the Acceptance of Service. 9. On November 29, 2007, the attorney for the Plaintiff corresponded with the Defendant and his attorney and sent to both the Defendant and his attorney a standard form of "Consent to the Divorce", seeking the consent of the Defendant to the entry of a Divorce Decree in the within case. A copy of the aforementioned correspondence, together with a copy of the form of "Affidavit of Consent" is attached hereto, identified as Exhibit "A" and incorporated herein by reference. 10. There was no response to the aforementioned correspondence nor was there any action taken by either party until January 17, 2008. 11. On January 17, 2008, the Plaintiff caused to be filed in the within divorce action an Affidavit Under Section 3301(d) of the Divorce Code, alleging that the final separation 5 between the parties had occurred on November 3, 2005, a period of time greater then two years prior to the date of filing of the Affidavit. 12. On or about March 27, 2008, the Defendant, acting "pro se", prepared and filed in the within divorce action the following documents: a. A "Counter Affidavit Under Section 3301(d) of the Divorce Code" which did not indicate any opposition to the entry of a Divorce Decree, but did indicate the Defendant's "wish to claim economic relief"; b. "Defendant's Petition for Related Claims Pursuant to Pa.R.C.P. 1920.15(b)" which requested that there be made by Your Honorable Court an equitable distribution of marital property of the parties; and, c. A "Motion for Appointment of Master". 13. A Master in Divorce was appointed by Your Honorable Court, to wit: E. Robert Elicker, II, Esquire, Divorce Master and Mr. Elicker issued a NOTICE of the scheduling of a conference with the Plaintiff and her counsel, and the Defendant, to occur in his Office on July 1, 2008 at 1:30 p.m. 14. On July 1, 2008, at the conference before the Master, the Defendant indicated that he was represented by counsel (namely Jeanne Costopoulos, Esquire), but that counsel was unable to be present with the Defendant at the Master's Conference. The Master thereupon identified that the single, significant marital asset arising out of the marriage of the parties was the vested retirement interest of the Plaintiff in her Pennsylvania State Employees Retirement System pension account and he insisted that a valuation thereof be made, that the marital and non-marital portions thereof be determined and that a present value thereof be determined. Prior to the scheduling of any hearing, the Master 6 thereupon directed counsel for the Plaintiff to communicate with Jeanne Costopoulos, Esquire, to ascertain if she was or was not in fact representing the Defendant and, he also directed that the cost of the securing of the pension evaluation be equally shared by the parties. 15. On July 9, 2008, counsel for the Plaintiff directed a letter to the Defendant informing the Defendant of the cost of a valuation of Plaintiff's pension account and requesting that the Defendant send a check to said counsel for his equal contribution ($225) to the total cost ($450) of the pension evaluation. A copy of the aforementioned correspondence of July 9, 2008, is attached hereto, identified as Exhibit "B" and incorporated herein by reference. 16. No response has been received from the Defendant to Exhibit "B". 17. Acting upon the request of the Master, counsel for the Plaintiff also did contact Jeanne Costopoulos, Esquire, who, in a return telephone call indicated that she did not represent the Defendant and had not entered her appearance on his behalf. 18. As a result of that telephone response from Jeanne Costopoulos, counsel for the Plaintiff, on July 16, 2008, again communicated with the Defendant offering the suggestion that the granting of the divorce by the Court, could be granted by the mutual consent of both of the parties, with the issue of the equitable distribution of the PSERS pension account of the Plaintiff being bifurcated, set apart, and preserved for a subsequent disposition by the Divorce Master and the Court. A copy of the correspondence of July 16, 2008, as well as a copy of the "Affidavit of Consent" accompanying that correspondence, is attached hereto, identified as Exhibit "C" and incorporated herein by reference. 7 19. No response to the correspondence represented by Exhibit "C" (despite the inclusion therewith of a self-addressed stamped, return envelope) has been received from the Defendant. 20. In view of the fact that the parties have been separated from each other since November 23, 2005, a period of time now in excess of three and one-half years, Plaintiff continues to persist in her averment, as set forth in her Affidavit filed on January 17, 2008, that the marriage is irretrievably broken. Additionally, the lengthy and costly litigation surrounding the Defendant's efforts to seek custody of the minor daughter of the Plaintiff is averred to have been a ploy or an effort on the part of the Defendant to entice the Plaintiff to enter into a reconciliation, and was not a bona fide effort on the part of the Defendant to have custodial rights with regard to Plaintiff's minor daughter. Furthermore, Plaintiff avers that the Defendant knew, at the time that he filed the Complaint for Custody, and throughout the entire litigation, that the minor child was not his child and that he could not have fathered that child or any other child. 21. Plaintiff believes, and therefore avers that the only reason that Defendant has exhibited for delaying the entry of a Divorce Decree is his persistent and ongoing effort to try to cajole, entice, or otherwise intimidate the Plaintiff into a reconciliation with the Defendant. 22. Defendant has not, in any document filed in the within action by him, disputed the accuracy of the claim of the Plaintiff that the parties have been separated since November 23, 2005, nor has he disputed that the marriage is irretrievably broken. 23. Finally, Plaintiff believes and therefore avers that the sole purpose of the obstinate and obdurate conduct of the Defendant is to prevent, for as long as possible, the ability of 8 the Plaintiff to be freed from the ties of her marriage to the Defendant and her ability to be able to lead a life of her own, with her daughter, free and clear of any continuing ties with the Defendant. WHEREFORE, Plaintiff prays Your Honorable Court issue a Rule upon the Defendant to show cause, if any he has, why the within, pending action in divorce should not be bifurcated, thereby permitting the Plaintiff to request that a Decree in Divorce be issued by this Court, SUBJECT NEVERTHELESS, to the retained jurisdiction of this Honorable Court to enter a separate and final Order thereafter, upon recommendation of the Divorce Master, as to a subsequent disposition of the claim herein made by the Defendant for equitable distribution of any marital property of the parties. Date: \\ '5 , -c O Respectfully submitted: Carl G. Wass, E re Attorney I.D. No. 07268 CALDWELL & KEARNS 3631 North Front Street Harrisburg, PA 17110 717-232-7661 Attorney for Plaintiff 9 VERIFICATION I verify that the statements made in this document are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaC.S. § 4904 relating to unsworn falsification to authorities. JAMES R. CLIPPINGER CHARLES J. DEHART, III JAMES L. GOLDSMITH P. DANIEL ALTLAND JEFFREY T. MCGUIRE' STANLEY J. A. LASKOWSKI DOUGLAS K. MARSICO BRETT M. WOODBURN RAY J. MICHALOWSKI 'BOARD CERTIFIED CIVIL TRIAL ADVOCATE CALDWELL & KEARNS A PROFESSIONAL CORPORATION ATTORNEYS AT LAW 3631 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17110-1533 November 29, 2007 Raymond G. Holloway, Jr. c/o: Mr. and Mrs. Raymond G. Holloway 39 Mountain Road Carlisle, PA 17013 Re: Cheryl L. Kleeman v. Raymond G. Holloway, Jr. Cumberland County Divorce Action No. 06-1868 Civil Term Dear Mr. Holloway: OF COUNSEL RICHARD L. KEARNS CARL G. WASS JAMES D. CAMPBELL. JR. THOMAS D. CALDWELL, JR. (1928 - 20011 717-232-7661 FAX: 717-232-2766 thefirm®caldwellkearns.com As you know, two years and more have now passed from the date when you and your wife, Cheryl, finally separated from each other. The length of that period of separation would entitle Cheryl to pursue the entry of a Decree in Divorce based upon "no fault" standards. However, even the securing of a "no fault" divorce involves an expenditure of money on Cheryl's part which, to be perfectly honest with you, she would prefer to avoid. Consequently, before we would take any further steps towards securing a -'two-year no fault divorce", we are communicating with you with the thought in mind that, after this lengthy period of' separation you may very well have "moved forward" with you life and might be willing simply to give your consent to the entry of a Divorce Decree. at a The identified grounds for the divorce in the Complaint were that "the marriage is irretrievably broken". I think that fact is true. I think that, by this time, you also know that it is true. And, you may (or may not) at this point in time be willing to acknowledge that the marriage is in fact at an end. I am enclosing two copies of a standard form of Consent to the Divorce, with the request that you sign and date one of those copies and return it to me by use of the enclosed, self-addressed, stamped envelope. The extra copy of the form of Consent is for you to retain for your own records. ovembcr 29, 2 0 0 7 Page 2 If you will give your consent, please sign one of the enclosed forms, date it, and return it to me. If it is your wish not to sign the form of Consent, please let me know that such is your wish by mailing back to me the Consent form unsigned and undated. Please note that a copy of this letter and a copy of the form of Consent to Divorce, is being forwarded to Shana Pugh, the attorney who had initially represented you in the divorce action and in the trial stage of the custody issues. Very truly yours, i QJ?? Carl G. Wass CALDWELL & KEARNS 'i CGW:th Enclosure cc: Cheryl L. Kleeman Shana M. Pugh, Esquire ??? 125891 CI tI`:RYL L. KLEFMAN, Plaintiff vs. RAYMOND G. HOLLOWAY, JR., Defendant IN "I HE COIJR"I'OF COMMON PI.1,AS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-1868 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ? 3301(C) OF THE DIVORCE CODE I. A Complaint in Divorce under Section 3301(c) or 3301(d) of the Divorce Code was filed on March 30, 2006. 2. Defendant acknowledges that a copy of the Complaint was served on April 10. 2006. 3. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 4. I consent to the entry of a Final decree of divorce without notice. 5. 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. 6. 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. § 4904 relating to unsworn falsification to authorities. Dated: - ------ ----- Raymond G. Holloway, Jr., Defendant SS4 163-60-1416 JAMES R. CLIPPINGER CHARLES J. DEHART, III JAMES L. GOLDSMITH P. DANIEL ALTLAND JEFFREY T. Mc GUIRE• STANLEY J. A. LASKOWSKI DOUGLAS K. MARSICO BRETT M. WOODBURN DAVID J. LANZA ELIZABETH H. FEATHER KAREN W. MILLER -BOARD CERTIFIED CIVIL TRIAL ADVOCATE CALDWELL & KEARNS A PROFESSIONAL CORPORATION ATTORNEYS AT LAW 3631 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17110-1533 July 9, 2008 Raymond Holloway, Jr. 116 Front Street Enola, PA 17025 Re: Kleeman vs. Holloway Dear Raymond: OF COUNSEL RICHARD L. KEARNS CARL G. WASS JAMES D. CAMPBELL. JR. THOMAS D. CALDWELL. JR. (192 8- 2001) 717-232-7661 FAX'. 717-232-2766 thefirm@caldwellkearns.com At the time of our conference with Robert Elicker, the Divorce Master, he indicated that he wished to have both of the parties participate in the securing of a formal evaluation of the pension interest of Cheryl and that he wanted that valuation to reflect also the "coverture fraction" (the percentage of the entire value which would be attributable to the period of your marriage to each other). I have contacted Jonathan D. Cramer, F.S.A., of Conrad Siegel Actuaries, and he informs me that the deposit which that firm requires for the performance of such a valuation is $450. The Master indicated he expected both parties to contribute equally to that cost; therefore, I am requesting you send me your check in the amount of $225, payable to "Conrad Siegel, Actuaries". I have Cheryl's check and will make the request of Mr. Cramer, sending the two checks in full payment to him. Thank you for your expected cooperation. Very truly yours, Carl G. Wass CALDWELL & KEARNS CGW:th cc: Cheryl Kleeman 135377 JAMES R. CLIPPINGER CHARLES J. DEHART. III JAMES L. GOLDSMITH P. DANIEL ALTLAND JEFFREY T. MCGUIRE- STANLEY J. A. LASKOWSKI DOUGLAS K. MARSICO BRETT M. WOODBURN DAVID J. LANZA ELIZABETH H. FEATHER KAREN W. MILLER -BOARD CERTIFIED CIVIL TRIAL ADVOCATE Raymond G. Holloway, Jr. 116 Front Street Enola, PA 17025 CALDWELL & KEARNS A PROFESSIONAL CORPORATION ATTORNEYS AT LAW 3631 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17110-1533 July 16, 2008 Re: Cheryl L. Kleeman vs. Raymond G. Holloway, Jr. Dear Raymond: OF COUNSEL RICHARD L. KEARNS CARL G. WASS JAMES D. CAMPBELL. JR. THOMAS D. CALDWELL. JR. (19 2 8- 2 001) 717-232-7661 FAX: 717-232-2766 thefirm@caldwelikearns.com As requested by the Divorce Master I called Jeanne Costopoulos. She returned my call on July 14 and indicated that, though she had had a single conversation with you by telephone, she does not represent you in this divorce action and, of course, has not entered her appearance on your behalf. A bifurcation of the severance of the marital relationship (the "divorce") will not in anyway impact your ability or Cheryl's ability to raise and pursue any economic issues which have arisen as a result of your marriage to each other. Those economic issues raised by you, have been properly laid before the Master, and will be heard and addressed by the Master. Thus, neither you nor Cheryl gain anything or lose anything if a "bifurcated" Decree in Divorce should be entered. I am enclosing two copies of a form of Affidavit of Consent to the divorce. You will note that I have prefaced the Consent form with some very specific language which makes it clear that, by giving consent, there is no waiver on your part (or on Cheryl's part) of the continued ability to dispute over the economic issues until they are resolved following a hearing by the Master. I request that you sign, date, and return to me one of those enclosed forms of Affidavit of Consent to the divorce so that I may file it (together with an identical form signed by Cheryl) with the Cumberland County Court so as to secure the "bifurcated" Decree in Divorce. A self-addressed, stamped envelope is enclosed with this letter for your use. Very truly yours, Carl G. Wass CALDWELL & KEARNS CGW:th Enclosure cc: Cheryl Kleeman 135573 CHERYL L. KLEEMAN, vs. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06-1868 CIVIL TERM RAYMOND G. HOLLOWAY, JR., Defendant CIVIL ACTION LAW - IN DIVORCE AFFIDAVIT OF CONSENT UNDER ? 3301(c) OF THE DIVORCE CODE The following Affidavit of Consent is given solely for the purpose of enabling the Court of Common Pleas of Cumberland County to Bifurcate the within action in Divorce by the issuance of a Decree in Divorce, severing the bonds of matrimony, but retaining jurisdiction over the economic issues raised in the within action in Divorce, which have already been referred to the Divorce Master, E. Robert Elicker, II, Esquire, who conducted a Conference on July 1, 2008 regarding said economic issues. 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 30, 2006. J!`•W ' • f 2. An Acceptance of Service signed by Shana M. Pugh, Esquire, which acknowledged receipt of the Complaint in Divorce, was filed with the Prothonotary of Cumberland County on May 15, 2006. 3. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a Decree of Divorce and waive any further notice of the intent to request the entry of such a 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. Dated: RAYMOND G. HOLLOWAY, JR., Defendant 135570 CERTIFICATE OF SERVICE AND NOW, this e day of , 2009, I hereby certify that I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U.S. Mails at Harrisburg, Pennsylvania, postage prepaid, addressed to: Raymond G. Holloway, Jr. 6 Sheeley Lane Boiling Springs, PA 17007 CALDWELL & KEARNS By 4F TFEE 1`.:01 "IFFY 2039 MAT E 1 -1 'i1 3: c U Ali, CHERYL L. KLEEMAN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. : RAYMOND G. HOLLOWAY, JR. DEFENDANT NO. 06-1868 CIVIL ORDER OF COURT AND NOW, this 15th day of May, 2009, upon consideration of the Petition Requesting Bifurcation of Civil Action in Divorce, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Defendant to show cause why the relief requested should not be granted; 2. The Defendant will file an answer on or before June 5, 2009; 3. If no answer to the Rule to Show cause is filed by the required date, the relief requested by Plaintiff shall be granted upon the Court's receipt of a Motion requesting Rule be made Absolute. If the Defendant files an answer to this Rule to Show Cause, the Court will determine if further order or hearing is necessary. 4. The Prothonotary is directed to forward said Answer to this Court. By the Court, ,?? Q? ?4 M. L. Ebert, Jr., J. Carl G. Wass, Esquire Attorney for Plaintiff - - Raymond G. Holloway, Jr. Defendant bas c 1 F.S s/esjo? 200q ml?.Y 15 f'4 1 ? 3 Carl G. Wa s, Esquire Attorney I. L. No. 07268 CALDWEL & KEARNS 3631 North ront Street Harrisburg, A 17110 717-232-76(l Attorney for Plaintiff CHERYL Lj KLEEMAN, Plaintiff VS. RAYMOND G. HOLLOWAY, JR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-1868 CIVIL TERM CIVIL ACTION LAW - IN DIVORCE AFFIDAVIT OF SERVICE the within REQUES depositing a postage Raymond 6 Sh( Boiling Spi 148792 NOW this kR+t-,_ of May, 2009, I hereby certify that I have served a copy of of Court dated May 15, 2009, as well as a copy of the PETITION G BIFURCATION OF CIVIL ACTION IN DIVORCE, on the following, by and correct copy of the same in the U.S. mails at Harrisburg, Pennsylvania, addressed to the following three addresses: . Holloway, Jr. Raymond G. Holloway, Jr. Raymond G. Holloway, Jr. ,ley Lane 4005 Riders Lane 116 Front Street ngs, PA 17007 Mechanicsburg, PA 17055 Enola, PA 17025 CALDWELL & KEARNS BY (N_xA Carl G. Wass, squire IL.i.. OF ?ry i I F 2009 iil'i ' 2- 0 Pt,i* i ' I v t3 CU 1"il Carl G. Wass, Esquire Attorney I.D. No. 07268 CALDWELL & KEARNS 3631 North Front Street Harrisburg, PA 17'.10 717-232-7661 Attorney for Plaintiff CHERYL L. KLEEMAN IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 06- 1868 - CIVIL RAYMOND G. HOLLOWAY, JR. IN DIVORCE Defendant CIVIL ACTION - LAW MOTION TO MAKE ABSOLUTE RULE TO SHOW CAUSE The undersigned, Carl G. Wass, Esquire, Caldwell & Kearns, P.C., respectfully moves Your Honorable Court to make Absolute the Rule to Show Cause heretofore issued by Your Honorable Court on May 15, 2009, and in support thereof, avers the following: On May 11, 2009, the undersigned filed on behalf of the Plaintiff in the within divorce action, a PETITION REQUESTING BIFURCATION OF CIVIL ACTION IN DIVORCE. 2. On May 15, 2009, Your Honorable Court entered an Order which issued a Rule upon the Defendant "... to show cause why the relief requested should not be granted ..." and directed that the Defendant was required to file an Answer on or before June 5, 2009. 3. The undersigned, recognizing that the pleadings in the within Action in Divorce identify three locations of residency of the Defendant having existed during the pendency of this Action, made provision to serve copies of the PETITION, and the ORDER OF COURT, upon the Defendant at all three locations of residence identified in the pleadings. 4. An Affidavit of Service reflecting first class, U.S. mail service, upon the Defendant at all three referenced residence locations was filed in the Office of the Prothonotary on May 20, 2009. 5. As of the date of the filing of the within Motion, the Defendant has filed no Answer to the above-referenced PETITION. WHEREFORE, Plaintiff prays Your Honorable Court to make Absolute the Rule to Show Cause heretofore issued on May 15, 2009, and to direct that the merits of the termination of the marriage by a Decree in Divorce be bifurcated from the economic issue of equitable distribution raised by the Defendant but RETAINING JURISDICTION of this Court to make a subsequent determination and Order as to the claim made by the Defendant for equitable distribution of any marital property. Date: V "K v\K \ Z , zv d C?( Respectfully submitted: Carl G. Wass, Esqui Attorney I.D. No. 07268 CALDWELL & KEARNS 3631 North Front Street Harrisburg, PA 17110 717-232-7661 Attorney for Plaintiff FfLEL'-??j??IL? OF THE FED'rr, )) OTMY 2099 J NI 12 PN 19 JUN 15 2009 6 CHERYL L. KLEEMAN vs. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA RAYMOND G. HOLLOWAY, JR. Defendant NO. 06- 1868 - CIVIL IN DIVORCE CIVIL ACTION - LAW ORDER AND NOW, this I Ltd day of 2009, a Rule to Show Cause having been issued by this Court on May 15, 2009, directing the Defendant to file an Answer to Plaintiff's Petition Requesting Bifurcation of Civil Action in Divorce on or before June 5,'2009, and, no Answer to said Petition having been filed, IT IS HEREBY ORDERED AND DIRECTED that: 1. The issue of the Plaintiff's request to be divorced from the Defendant is hereby bifurcated from the economic issue of equitable distribution heretofore raised by the Defendant; 2. The Master in Divorce, heretofore appointed, shall conduct a hearing and make a recommendation to the Court limited solely to the entitlement of Plaintiff to have a Decree in Divorce issued; and, 3. In the event, upon recommendation of the Master in Divorce, a Decree in Divorce should be issued, such Decree shall be SUBJECT, NEVERTHELESS, to the retained jurisdiction of this Court to enter a separate and final Order as to the claim made by the Defendant for equitable distribution of any marital property of the parties. BY THE COURT: M. L. Ebert, Jr. J. Distribution List: Carl G. Wass, Esquire, Caldwell & Kearns, 3631 North Front Street, Harrisburg, PA 17110 717-232-7661 ?kaymond G. Holloway, Jr., 116 Front Street, Enola, PA 17025 ??14 /Uq FILLED C.E; 2009 X ls 16 N 10* 19 CLJVJ.- .,-,1, ; l A z CHERYL L. KLEEMAN, Plaintiff VS. . RAYMOND G. HOLLOWAY, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06 - 1868 CIVIL IN DIVORCE NOTICE OF FILING OF MASTER'S REPORT The report of the Master has been filed this date and copies have been sent with this notice to counsel of record and the parties. In accordance with P.R.C.P. 1920.55 within ten (10) days after the mailing of this notice and report exceptions may be filed to the report by any party. If no exceptions are filed within the ten (10) day period, the Court shall receive the report, and if approved, shall enter a final decree in accordance with the recommendations contained in the report. Date: 9/3/09 E. Robert Elicker, II Divorce Master NOTE: If exceptions are filed, file the original with the Prothonotary and a copy with the Master's office. At that time, the party filing the exceptions should notify the court reporter in the Master's office so arrangements can be made for a transcript. Upon completion of the transcript and receipt of payment, the entire file will be returned to the Prothonotary's office for transmittal to the Court at time of argument on the exceptions. If no exceptions are filed, counsel shall prepare an order of Court consistent with the recommendations and provide a proposed order of Court to the Master. Counsel shall also prepare and provide with the proposed order of Court a praecipe* to the .Al Prothonotary directing the Prothonotary to submit the case to the Court for final disposition. The Master will then transfer the file with the proposed order of Court and praecipe to the Prothonotary's Office for docketing and transmittal by the Prothonotary to the Court. * Form available in the Prothonotary's office and the Master's office. (NOT the praecipe to transmit the record form as set out in P.R.C.P. 1920.73(b).) EliEu)- r , w F OF THE PMY+ s ^ OTARY 1009 SEP -3 PH 1* 36 -1- 4 CUNT, ? CHERYL L. KLEEMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 06 - 1868 CIVIL RAYMOND G. HOLLOWAY, JR.,: Defendant IN DIVORCE THE MASTER: Today is Thursday, September 3, 2009. This is the date set for a hearing to determine whether or not the wife is entitled to a divorce decree. Present in the hearing room are the Plaintiff, Cheryl L. Kleeman, and her counsel Carl G. Wass, and the Defendant, Raymond G. Holloway, Jr., who is not represented by counsel. Also present is Karen Miller, the associate of Mr. Wass. Judge Ebert entered an order June 16, 2009, bifurcating the divorce action but directed the Master to have a hearing to recommend whether or not the Plaintiff is entitled to a divorce. The hearing today has been scheduled for that purpose; the Plaintiff filed an affidavit under Section 3301(d) averring the parties separated on November 23, 2005. Both parties today have acknowledged that they agree to that date of separation. Therefore, the parties have been separated for a period in excess of two years and wife would be entitled to a divorce under Section 3301(d) of the Domestic Relations Code. Although the Defendant filed a 1 counter-affidavit to wife's 3301(d) affidavit, he did not dispute the grounds for divorce but rather indicated that he wished to raise economic claims. The Defendant has raised an economic claim of equitable distribution by petition filed on March 27, 2008. Consequently, the Master recommends that wife be granted a decree in divorce based on a separation in excess of two years from November 23, 2005. A hearing on the economic claim raised by husband of equitable distribution has been scheduled for Wednesday, September 23, 2009 at 9:00 a.m. We are going to provide notices to counsel and the parties today before they leave indicating the date and time of the hearing. The claim of equitable distribution should be noted as a claim pending in the divorce decree. RECOOGMATION The Master recommends that wife be granted a decree in divorce under Section 3301(d) based on a separation of the parties of more than two years, from 2 .40 November 23, 2005. The claim of equitable distribution is preserved for further adjudication. Respectfully submitted, E. Robert Elicker, II Divorce Master 3 FILE i OF THE PP0 -`l,"lNc Ppy 2009 SET - 3 Phi (: 3 6 CHERYL L. KLEEMAN, Plaintiff VS. RAYMOND G. HOLLOWAY, JR., Defendant THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06 - 1868 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this aSLl day of , 2009, after review of the status of the claim for equitable distribution filed by the Defendant, as related on the record by the Master in the presence of the parties and counsel for wife, the appointment of the Master is vacated. The memorandum placed on the record by the Master is attached to this order setting forth the reasons the claim for equitable distribution was not heard by the Master. BCTH RT , nla? cc: ? Carl G. Wass Att rney for Plaintiff ond G. Holloway, Jr. Raym Pro Se clor I . .-. LL 1? I.AJIC 1 ` ' J Edgar B. Bayley, P.J. OF TH 2009 SEE 24 AM 1C: 20 Cj;f r t T j l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CRF-R-1L L.4C rEtv \ AN : V. ? yMo t3 b G • t? OL1 X W (-\Y, iZ DIVORCE AND NOW, zau ,\Aey,a G. k-? o? 1 o w 0.u bonds of matrimony. CtV?I, NO. OGo - k5 GS - ;DECREE 1.00 , it is ordered and decreed that plaintiff, and J r, defendant, are divorced from the Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") By the Court, N ? Attest: J. 7L, ell rothonotary ? ? r . 4, 'S; ?. . 4 ._