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Home My WebLink About06-48936. HARRISON F. BINK, Plaintiff V. KATHLEEN BINK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, NO. UG- gJ'R3 ?',Lw:,Q_ IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Harrisburg, PA 17101. 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presenter una apariencia escrita o en persona o por abogado y archivar an la corte en forma escrita sus defenses o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notifcacion y por cualquier queja o alivio que es pedido an la peticion de demanda. Usted puede perder dinero o propiedad u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAIL SERICIO, VAYA EN PERSONA O LLAMA POR TELEFONO A LA OFICINA CUYA DIRECION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 HARRISON F. RINK, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, NO. vG - 4F93 6u id- -7;:,, KATHLEEN BINK, Defendant IN DIVORCE COMPLAINT COUNTI Divorce Under 3301(c) or 3301(d) of the Divorce Code 1. Plaintiff is Harrison F. Bink who currently resides at 111 North 17"' Street, Camp Hill, Pennsylvania 17011. 2. Defendant is Kathleen Bink who currently resides at 17 Stone Spring Lane, Camp Hill, Pennsylvania 17011. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 3, 1991 in the Virgin Islands. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The grounds on which the action for divorce is based are Section 3301(c) or 3301(d) of the Divorce Code. The marriage of the parties is irretrievably broken. 8. Plaintiff has been advised of the availability of counseling and that he may have the right to request that the Court require the parties to participate in counseling. Plaintiff hereby waives his right to such counseling. 9. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce under Section 3301(c) or (d) of the Divorce Code. COUNT II EQUITABLE DISTRIBUTION 10. Plaintiff incorporates by reference paragraphs I through 9 of this Complaint. 11. Plaintiff and Defendant possess various items of personal marital property, as well as marital debts, which are subject to equitable distribution by this Court. WHEREFORE, Plaintiff requests your Honorable Court to equitably distribute all property, both real and personal, owned by the parties, as well as all marital debts. McNEES WALLACE & NURICK LLC Dated: OMW Attorneys for Plaintiff Harrisburg, PA 17108-1166 (717) 237-5343 (717) 237-5300 (fax) RUG-22-2006 15 53 P.05/05 I verity that the statements made In this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities. ?r Karr on F. Bink Dated: ?I a4w" TOTAL P.05 °Q fA?J•? N C r': C G W G un 0 m tJ C) ? ? C7 I MCNEES WALLACE & NURICK LLC By: J. Paul Helvy Attorney ID No. 53148 100 Pine Street Harrisburg, PA 17108-1166 (717) 237-5343 (717) 237-5300 facsimile pheIvy0)mwn.com Attorney for Plaintiff HARRISON F. BINK, Plaintiff V. KATHLEEN BINK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-4893 IN DIVORCE PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Please substitute the within original Verification page for the facsimile copy on the Divorce Complaint filed on August 23, 2006. Respectfully submitted, MCNEES WALLACE & NURICK LLC Date: 8/25/06 By: Harrisburg, PA 17108-1166 (717) 237-5343 (717) 237-5300 (Fax) Attorney for Plainfff B .L Partnership Bins Partnership, Inc. PRINCIPALS Harrison E Bink, AIA Philip A Frey, AIA Douglas C. Tilley, AIA VERIFICATION PRO?ECT ARCHITECTS George E. Fleisher, AIA Stewart C. Cluck, AIA Larry E. Saylor, AIA EMERITUS PARTNERS James B. Bogar, R.A. Harry L. Bink, R.A. C. Kline Kuntz, RA I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. ar ison F. Bink? Dated: 47 Q 133 South 32nd Street • Camp Hill, Pennsylvania 17011 717-737-0402 • Fax: 717-737-0442 bink@bink.net • www.bink.net CERTIFICATE OF SERVICE AND NOW, on this 9544, day of 2006, I, Lynn B. Lowe, Secretary for J. Paul Helvy, Esquire, hereby certify that I have served a true and correct copy of the within document, via first class mail postage paid as follows: Ann Levin, Esquire 4431 North Front Street Harrisburg, PA 17110 McNEES WALLACE & NURICK LLC iu I i1 l ?Q By Lynn B. Lo e, Secretary for J. Paul Helvy, Esquire I.D. No. 53148 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 Phone: 717 237-5343 Attorneys for Plaintiff Ca q p Say ' c, nor m Q n `? c7 N McNEES WALLACE & NURICK LLC By: J. Paul Helvy Attorney ID No. 53148 100 Pine Street Harrisburg, PA 17108-1166 (717) 237-5343 (717) 237-5300 facsimile phelvv(&mwn.com Attorney for Plaintiff HARRISON F. RINK, Plaintiff V. KATHLEEN B1NK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, NO. 2006-4893 IN DIVORCE AFFIDAVIT OF ACCEPTANCE OF SERVICE I, Ann V. Levin, Esquire, counsel for Defendant herein, do hereby swear and affirm that have I accepted service of a true and correct copy of the Complaint in Divorce in the above-captioned action on k "023 2006. V 20?? - Ann V. Levin, Esquire N ? ? ? ' --A n l f G? ? -r, ? ?:: ? McNEES WALLACE & NURICK LLC By: J. Paul Helvy Attorney ID No. 53148 100 Pine Street Harrisburg, PA 17108-1166 (717) 237-5343 (717) 237-5300 facsimile phelvyA-mwn.com KATHLEEN BINK, Plaintiff V. HARRISON BINK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 00418 S 2007 PACSES NO. 660109217 HARRISON F. BINK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006-4893 KATHLEEN BINK, Defendant IN DIVORCE PETITION TO WITHDRAW APPEARANCE J. Paul Helvy, Esquire, counsel at McNees Wallace & Nurick LLC, respectfully petitions this Honorable Court for leave to withdraw his appearance as counsel for Harrison F. Bink, and, in support thereof, avers as follows: 1. Harrison F. Bink, an adult individual, currently resides at 111 North 17th Street, Camp Hill, PA 17011. 2. Petitioner J. Paul Helvy has determined that he is unable to continue the representation of Harrison F. Bink for a variety of reasons which, if necessary, will be addressed at a hearing regarding this Petition. WHEREFORE, Petitioner J. Paul Helvy respectfully requests leave to withdraw his appearance as attorney for Harrison F. Bink. B, Dated: April 15, 2008 McNEES WALLACE & NURICK LLC CERTIFICATE OF SERVICE The undersigned hereby certifies that on this date a true and correct copy of the foregoing document was served by first-class mail upon the following: Ann Levin, Esquire 4431 North Front Street Harrisburg, PA 17110 Harrison F. Bink, 111 North 17th Street Camp Hill, PA 17011 Micelle Armour, Secretary Dated: April 16, 2008 `'? ,.'?Y s '"f7 C` ?? --? 1 tY ?,.1 ..--y ? ?_,.? r i" "..' -?= L:.) Harrison F. Bink ..?? , vs Case No. Kathleen Bink Statement of Intention to Proceed To the Court: Plaintiff Print Name Maria P. Cog Date: ( I// f 06-4893 intends proceed t the above captioned matter. netti Attorney for Plainti Explanatory Comment The Supreme Court of Pennsylvania has promulgated new Rule of Civil Procedure 230.2 governing the termination of inactive cases and amended Rule of Judicial Administration 1901. Two aspects of the recommendation merit comment. 1. Rule of civil Procedure New Rule of Civil Procedure 230.2 has been promulgated to govern the termination of inactive cases within the scope of the Pennsylvania Rules of Civil Procedure. The termination of these cases for inactivity was previously governed by Rule of Judicial Administration 1901 and local rules promulgated pursuant to it. New Rule 230.2 is tailored to the needs of civil actions. It provides a complete procedure and a uniform statewide practice, preempting local rules. This rule was promulgated in response to the decision of the Supreme Court in Shop v. Eagle, 551 Pa. 360,710 A.2d 1104 (1998) in which the court held that "prejudice to the defendant as a result of delay in prosecution is required before a case may be dismissed pursuant to local rules implementing Rule of Judicial Administration 1901." Rule of Judicial Administration 1901(b) has been amended to accommodate the new rule of civil procedure. The general policy of the prompt disposition of matters set forth in subdivision (a) of that rule continues to be applicable. lI Inactive Cases The purpose of Rule 230.2 is to eliminate inactive cases from the judicial system. The process is initiated by the court. After giving notice of intent to terminate an action for inactivity, the course of the procedure is with the parties. If the parties do not wish to pursue the case, they will take no action and "the Prothonotary shall enter an order as of course terminating the matter with prejudice for failure to prosecute." If a party wishes to pursue the matter, he or she will file a notice of intention to proceed and the action shall continue. a. Where the action has been terminated If the action is terminated when a party believes that it should not have been terminated, that party may proceed under Rulc230(d) for relief from the order of termination. An example of such an occurrence might be the termination of a viable action when the aggrieved party did not receive the notice of intent to terminate and thus did not timely file the notice of intention to proceed. The timing of the filing of the petition to reinstate the action is important. If the petition is filed within thirty days of the entry of the order of termination on the docket, subdivision (d)(2) provides that the court must grant the petition and reinstate the action. If the petition is filed later than the thirty-day period, subdivision (d)(3) requires that the plaintiff must make a showing to the court that the petition was promptly filed and that there is a reasonable explanation or legitimate excuse both for the failure to file the notice of intention to proceed prior to the entry of the order of termination on the docket and for the failure to file the petition within the thirty-day period under subdivision (d)(2). B. Where the action has not been terminated An action which has not been terminated but which continues upon the filing of a notice of intention to proceed may have been the subject of inordinate delay. In such an instance, the aggrieved party may pursue: the remedy of a common law non pros which exits independently of termination under Rule 230.2. 1 ?n . Sign Nam t- HARRISON F. BINK IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA vs. KATHLEEN BINK NO. 2006-4893 DEFENDANT ENTRY OF APPEARANCE AS A SELF-REPRESENTED PARTY 1. I am the ❑ Plaintiff ® Defendant in the above-captioned(MARK ONE) ❑ custody, ® divorce, ❑ support, ❑ protection from abuse, ❑ paternity case. 2. ❑ This(MARK ONE) ❑ is ❑ is not a new case and I am representing myself in this case and have decided not to hire an attorney to represent me. OR(check only one box) ❑ This is NOT a new case and �previguqly (Name of Attorney) represented me in this case. I have decided not to be represented by that attorney and direct the Proff�)otary to remove that attorney as my counsel of record in this case. C3 ' I have provided a copy of this form to that attorney listed above at the following address: CQ 'c' .�_cD OR(check only one box) c-r ® 1 am entering my appearance as a self-represented party(sign) My attorney acknowledges is/her withdrawal as my ttorney in this case. (Attorney signature) Esq. - - 3. My address for the purpose of receiving all future pleadings and other legal notices is: 17 Stone Spring Lane, Camp Hill PA 17011. 1 understand that this address will be the only address to which notices and pleadings in this case will be sent,�and that 1 am responsible to regularly check my mail at this address to ensure that I do not miss important deadlines or proceedings. ® This is my home address. ❑ This is not my home address. 4. My telephone number where I can be reached during normal business hours(8:00 a.m.—4:30 p.m. Monday—Friday) is 717-576-0650. My email address is dabinkssteragmail.com. ❑ My telephone number and email address are confidential pursuant to a Protection From Abuse Order. 5. 1 UNDERSTAND I MUST FILE A NEW FORM EVERY TIME MY ADDRESS OR TELEPHONE NUMBER CHANGES. G. I ha��e pmvided a cony of thisforrin to all other attorneys or other serf-repTeserded parties at the fullowL,y addresses listed below: (Use reverse side if you need more space). Name: Maria P. Cognetti, Esquire Address: 3304 Market Street,Camp Hill, PA 17011 7. 1 fully understand that by deciding to represent myself,the Court will hold me to the same standards of knowledge regarding the statutory law, evidence law, Local and State Rules of Procedure and applicable case law as a Pennsylvania licensed attorney, and that I must be fully prepared to meet those responsibilities. !,verify that the statements made in this Entry of Appearance as a Self-Represented Party are true and correct. .I understand that if I make false statements herein, that I am subject to the criminal penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities which could result in a fine and/or prison term. Date Signature(Your Signature) n ti COGNETTI&ASSOCIATES MARIA P.COGNETTI,ESQUIRE Attorney I.D.No.27914 3304 Market Street Camp Hill,PA 17011 Telephone No. (717)909-4060 Attorneys for Plaintiff HARRISON F. BINK, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA v. : NO. 06-4893 CIVIL : CIVIL ACTION—LAW KATHLEEN BINK, : IN DIVORCE Defendant : ASSIGNED JUDGE: MASLAND 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 separated on December 18, 2005 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, attorney'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. §4904 relating to unsworn falsification to authorities. ,�f �� Or_ Date: 1/ /i'� --i a • •ISON BINK J l F i 3 DEC -6 PM 1: 4 4 CUMBERLAND COUNTY PENNSYLVANIA HARRISON F. BINK, THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : No 06-4893 CIVIL TERM KATHLEEN BINK, CIVIL ACTION-AT LAW Defendant DIVORCE DEFENDANT'S PETITION FOR RELATED CLAIMS PURSUANT TO PA.R.C.P. 1920.15(b) AND NOW comes Defendant, Kathleen Bink,pro se, and represents as follows in support of this Petition: 1. Petitioner is Defendant above, Kathleen Bink, an adult individual currently residing at 17 Stone Spring Lane, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. Respondent is Plaintiff above, Harrison F. Bink, hereinafter referred to as Husband, an adult individual currently residing at 765 Lancaster Avenue, Enola, Cumberland County, Pennsylvania, 17025. 3. Husband and Wife were married on May 3, 1991, in the Virgin Islands. 4. Husband filed a Complaint in Divorce at the above term and docket number on August 23, 2006. COUNT I-EOUITABLE DISTRIBUTION 5. While no settlement has been reached as of the date of the filing of this Complaint, Wife is willing to negotiate a fair and reasonable settlement of all matters with Husband. To the extent that a written Settlement Agreement might be entered into between the parties prior to the time of hearing on this Divorce Complaint, Wife desires that such written e5, ()0 Agreement be approved by the Court and incorporated, but not merged, in any Divorce Decree which might be entered dissolving the marriage between the parties. 6. The parties are the owners of various items of real and personal and tangible and intangible property acquired during their marriage, which are subject to equitable distribution by this court. COUNT II -ATTORNEY'S FEES AND COSTS 7. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 8. By reason of this action, Defendant will be put to considerable expense in the preparation of her case in the employment of counsel and other experts and the payment of costs. 9. Defendant is without sufficient funds to meet the costs and expenses of this litigation. 10. Defendant's income is not sufficient to pay attorney's fees and costs of this litigation. 11. Plaintiff has adequate earnings and assets to provide for Defendant's counsel fees, costs and expenses. COUNT III—ALIMONY 12. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 13. Defendant lacks sufficient property to provide for her reasonable needs. 14. Defendant is unable to sufficiently support herself through appropriate employment. 15. Plaintiff has sufficient income and assets to provide continuing support for Defendant after the entry of a Decree in Divorce. WHEREFORE, Defendant, Kathleen Bink, requests this Honorable Court: a. Equitably distribute all property owned by the parties; b. Compel Plaintiff to pay Defendant's attorney's fees and costs of litigation; c. Compel Plaintiff to pay post-divorce alimony to Defendant; d. Grant such further relief as the Court may deem equitable and just. By: HLEEN BINK Defendant,pro se 17 Stone Spring Lane Camp Hill, PA 17011 Telephone No. (717) 576-0650 Date: 2/EzK_0_62 VERIFICATION I, Kathleen Bink, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. Date: 2 � athleen Bink r # DEC —6 PM 1: 1,Ea HARRISON F. BINI17,UMSERLAND ;U114 i,,THE COURT OF COMMON PLEAS OF Plaintiff PENNSYLVANIA CUMBERLAND COUNTY,PENNSYLVANIA VS. : No 06-4893 CIVIL TERM KATHLEEN B1NK, CIVIL ACTION-AT LAW Defendant 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: f L201z, Signature: K Teen Bink, Defendant r CERTIFICATE OF SERVICE I,Kathleen Bink,hereby certify that this day I personally served a copy of the foregoing document upon the person indicated below by depositing a copy of the same with the United States Post Office through first class mail,prepaid,and addressed as follows: Maria P. Cognetti, Esquire Cognetti&Associates 3304 Market Street Camp Hill,PA 17011 By: THLEEN BINK Defendant,pro se 17 Stone Spring Lane Camp Hill, PA 17011 Telephone No. (717) 576-0650 Date: 2 713 THE PP.OTHCNO't' 2014JAIL27 PM 2: !d CUMBERLAND COUNTY PENNSYLVANIA COGNETTI& ASSOCIATES MARIA P. COGNETTI,ESQUIRE Attorney I.D. No. 27914 3304 Market Street Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Plaintiff HARRISON F. BINK, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-4893 CIVIL : CIVIL ACTION—LAW KATHLEEN BINK, : IN DIVORCE Defendant : ASSIGNED JUDGE: MASLAND MOTION FOR APPOINTMENT OF MASTER Harrison F. Bink, Plaintiff, moves the court to appoint a Master with respect to the following claims: (x) 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 for which the appointment of a master is requested. (2) The Defendant, Kathleen Bink, has appeared in the action personally. (3) The statutory grounds for divorce are: 3301(c) and 3301(d). (4) The action is contested with respect to the following claims: ALL CLAIMS. (5) The action does involve complex issues of law or fact. (6) The hearing is expected to take one (1) day. (7) Additional information, if any, relevant to the motion: No additional information at this time. Respectfully Submitted, COGNETTI SSOCIATES f Date: January24, 2014 BY 411-4/ MARIA P. ,OG' DTTI,ESQUIRE Attorney I.D. No. 914 3304 Market Street Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff CERTIFICATE OF SERVICE I, Maria P. Cognetti, Esquire, hereby certify that I served a true and correct copy of the foregoing Motion for Appointment of Master at the address indicated below: Kathleen Bink 17 Stone Spring Lane Camp Hill, PA 17101 Service by: Personal service via hand delivery X Service by First Class, United States Mail,postage pre-paid, mailed at Camp Hill, Pennsylvania, addressed as indicated above Overnight delivery Facsimile service Certified/Registered Mail COGNETTI ASSOCIA ES /. Date: January24, 2014 By: MARIA P. CO NI, TTI ESQUIRE Attorney I.D.No. 27914 3304 Market St. Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff OF THE P ZOTHON11; AR-.11 20,14 AN 29 PM 3 7 CUMBERLAND COUNTY PENNSYLVANIA HARRISON F. BINK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-4893 CIVIL CIVIL ACTION—LAW KATHLEEN BINK, IN DIVORCE Defendant ASSIGNED JUDGE: MASLAND ORDER APPOINTING MASTER AND NOW, 02 , 2014, Esquire is appointed master with respect to the following claims: BY THE COURT: J. MOVING PARTY: Harrison F.Bink NON-MO/ING R TY:Kathleen Bink L,-'Maria P.Cognetti,Esquire ro Se COGNETTI&ASSOCIATES 3304 Market St. 17 Stone Spring Lane Camp Hill,PA 17011 Camp Hill,PA 17011 Phone: 717.909.4060 Phone: 717.576.0650 Fax: 717.909.4068 Fax: Email: mcoanetti a,cognettilaw.com Email: dabinksstern,!mai1.com Co ,�,q fi2;at'4C4 r ',lily r ff MARIA P. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIRE Attorney I.D. No. 27914 3304 Market Street Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Plaintiff HARRISON F. BINK, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. KATHLEEN BINK, Defendant : NO. 06-4893 CIVIL : CIVIL ACTION — LAW : IN DIVORCE : ASSIGNED JUDGE: MASLAND MOTION TO VACATE APPOINTMENT OF DIVORCE MASTER AND NOW, comes Plaintiff, Harrison F. Bink, by and through his attorney, Maria P. Cognetti, Esquire, who files this Motion to Vacate Appointment of Divorce Master and in support thereof avers as follows: 1. Movant is Harrison F. Bink, Plaintiff in the above -referenced action hereinafter referred to as "Husband." 2. Respondent is Kathleen Bink, Defendant in the above -referenced action hereinafter referred to as "Wife." 3. Wife is a self -represented party. 4. Husband filed a Motion for Appointment of Divorce Master on January 27, 2014. 5. E. Robert Elicker, II, Esquire, was appointed Divorce Master by Order dated January 29, 2014. 6. Husband has decided he is not interested in pursuing a divorce at this time. 7. The Honorable Albert H. Masland has previously heard matters involving these parties. WHEREFORE, Husband requests that the Appointment of E. Robert Elicker, II, Esquire as Divorce Master be revoked. Date: May 13, 2014 By: COGNETTI & ASSOCIATES MARIA P CO r TTI, ESQUIRE Attorney I.D. No. 27914 3304 Market Street Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Plaintiff CERTIFICATE OF SERVICE I, Maria P. Cognetti, Esquire, hereby certify that I served a true and correct copy of the foregoing Motion to Revoke Appointment of Divorce Master at the address indicated below: Service by: Kathleen Bink 17 Stone Spring Lane Camp Hill, PA 17101 Personal service via hand delivery X Service by First Class, United States Mail, postage pre -paid, mailed at Camp Hill, Pennsylvania, addressed as indicated above Overnight delivery Facsimile service Certified/Registered Mail Date: May 13, 2014 By: COGNETTI & ASSOCIATES MARIA '.CO N TTI, ESQUIRE Attorney I.D. No. 7914 3304 Market Street Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Plaintiff iii PENNSYLVANIA HARRISON F. BINK, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. KATHLEEN BINK, Defendant : NO. 06-4893 CIVIL : CIVIL ACTION — LAW : IN DIVORCE : ASSIGNED JUDGE: MASLAND ORDER OF COURT AND NOW, to wit, this /V day of in 47 , 2014, upon consideration of the attached Motion to Revoke Appointment of Divorce Master, it is hereby ORDERED and DECREED that the appointment of E. Robert Elicker, Esquire, II, is hereby REVOKED. BY THE COURT: //Distribution: /Maria P. Cognetti, Esquire, Cognetti & Associates, 3004 Market Street, Camp Hill, PA 17011 /Kathleen Bink, 17 Stone Spring Lane, Camp Hill, PA 17011 /E. Robert Elicker, II, Esquire, Divorce Master, 9 North Hanover Street, Carlisle, PA 17013 n / ct- J. Harrison F. Bink PLAINTIFF vs. Kathleen Bink DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DOCKET NO. 2006-4893 IN DIVORCE ENTRY OF APPEARANCE AS A SELF -REPRESENTED PARTY 1. I am the ® Plaintiff ❑ Defendant in the above -captioned (MARK ONE) ❑ custody, ® divorce, ❑ support, ❑ protection from abuse, ❑ paternity case. 2. ❑ This (MARK ONE) ❑ is ❑ is not a new case and I am representing myself in this case and have decided not..to hire an attorney to represent me. ❑ This is NOT a new case and OR (check only one box) this case. I have decided not to be represented by that attorney and direct as my counsel of record in this case. I have provided a copy of this form to that attorney listed above at the following /$„ rz rn crt— -:7 previouslyserited the Prothonotary to rerwS4that attoroey , address: OR (check only one box) ® I am entering my appearance as a self -represented party (sign My attorney acknowledehis/her withawal as m j;,r;rney in this case. (Attorney signature) , Esquire. My address for the purpose of receiving all fut!''- pleadings and other legal notices is: 765 Lancaster Avenue, Enola, PA 17025. . I understand that this address will be the only address to which notices and pleadings in this case will be sent, and that I am responsible to regularly check my mail at this address to ensure that I do not miss important deadlines or proceedings. ® This is my home address. ❑ This is not my home address. 3. My telephone number where I can be reached during normal business hours (8:00 a.m. — 4:30 p.m. Monday — Friday) is 717-512-9105 . My email address is Harrison(a)Bink.net ❑ My telephone number and email address are confidential pursuant to a Protection from Abuse Order. 4. I UNDERSTAND I MUST FILE A NEW FORM EVERY TIME MY ADDRESS OR TELEPHONE NUMBER CHANGES. 5. I have provided a copy of this form to all other attorneys or other self -represented parties at the following addresses as listed below: (Use reverse side if you need more space) Name Kathleen Bink Address 17 Stone Spring Lane. Camp Hill, PA 17011 Name Address 6. I fully understand that by deciding to represent myself, the Court will hold me to the same standards of knowledge regarding the statutory law, evidence law, Local and State Rules of Procedure and applicable case law as a Pennsylvania licensed attorney, and that I must be fully prepared to meet those responsibilities. I verify that the statements made in this Entry of Appearance as a Self -Represented Party are true and correct. I understand that if I make false statements herein, that I am subject to the criminal penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities� /� yo i result in a fi n ter Date4000000,_ / ig tur(Your Signatur