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Home My WebLink About95-02384 . ....:!I '7 . ..~ , ...k. o n .~ - :t- OO rf) n , l!1 1 a-\ ; 'I 01 <: .:+;. :. .:.:. .:+:. ':.:. .:.:. .:+:. .:+:. .:c- ... ... '-;' . '.' ......".,,',.., 8 ~ 8 ~ 8 8 8 8 8 8 8 8 8 8 w I~ I: i tll iM ! : IN I' i8 i* i' iw J'" ) ~ I' 18 -~--~~.*-*.~_.~***.~..~** ~ I" " . --,,, " ~\ MI , , ~\ ,I , \ ~ 8 ~ IN THE COURT OF COMMON PLEAS ~i ~ 8 8 8 8 8 8 8 8 8 ~I ~I . i . 8 . . . * * 8 . . t . . . . t OF CUMBERLAND COUNTY STATE OF ~~I PENNA. \ ~ . .~T EHNES'!' n. ,JOIIW;ON, Plaintiff :\ II, 95-23B4 CIVIL 11)95 "'j'i CAHOLYN 1. Jt>>lNSON, Il:!fendant DECREE IN DIVORCE ').'( AND NOW, Jbs..:cml:.lll 1995 , It Is ordered and docreed that ICr/l!,,;5t Il. ,lpll/wOII , plaintiff. . defendant. and. Car:o I yn 1:. ,Ioll/HiOn are divorced from the bonds of matrimony The court retoHa jurlsdlctloll of the following c10lrm which hove been raised of record in this octioll for which a filial order has not vet been entered; I'jcmEl " \'.'. {'.II' (", "' I ..... (. l , I l \ ( .~, ';! ", l ~- t '. \. .), - .. . I ' A.ft., - -, I." "- _. .1 ~1k''''I(..'.,.... .' . I..> ,,fl../, /,..t. "..:t.J ';,.t~/If( /. /0:/,1., kp.r' . ..f /' 7 II.utlll<oil!.11 ~ -.: :.. ;.; .. ~.. '. . . '. :. -... ~ ~ ~ " " Ii ~ . . . !I . . .. ERNEST R. JOHNSON I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I V. I I I CAROLYN I. JOHNSON I 95-2384 CIVIL TERM I I DIVORCE AC'.l'ION - LAW ORDER OF COURT AND NOW, this 21st day of DECEMBER, 1995, the appointment of E. Robert Elicker, Esquire, as Master in the above case is vacated. Counsel for the plaintiff may have the record submitted to the court with an appropriate decree. No economic claims remain because the defendant has failed to raise any economic issues with Mr. Elicker prior to October 23, 1995, or after that time, as she was directed to do. By the Court, .- .-- , Ct.. \ L-.-- , a old E; ,,/ .J. ~;uRobert Elicker, Esquire ~rce Master Bradley L. Griffie, Esquire Carolyn I. Johnson, Pro Se Isld TRUE COPY FROM RECORD In T ottlmony whoreof, I huro unto sol my hand and tho seat of S<lit.l Cou al Call Ish!, Pa, }.t daya ~I ... N f: f': C> r' , , u4C! ' ..~ ),1 I ~ - I';. ' ll.. ! tl; , ,)(' [',r r'"J '.\" c' '" i.i:l' L:' I, , I : L. " 1"-, .1 t. ' , , () . .. .' ERNEST R. JOHNSON, plaintirr IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v.. NO. CIVIL 1995 CAROLYN I. JOHNSON, Derendant IN DIVORCE IIOTIC. or IHT.HTIOII TO RIlOU1l8T .HTRY or DIVO.C. D.C". TOI Carolyn I. Johnson Der.ndant You have been sued in an action ror divorce. You have railed to answer the complaint or rile a counterarridavit to the Plaintirr'. arridavit. Thererore, on or arter June 12, 1995, the PlaintiU can request the Court to enter a rinal deer.. in divorce. It you do not rile with the Prothonotary or the court, an answer with your signature notarized or veriried or a counterarridavit by the above date, the Court can enter a rinal decree in divorce. Unless you have already filed with the Court a written claim ror economic relier, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask ror economic relief. A COUNTERAFFIDAVIT WHICH YOU HAY FILE WITH THE PROTHONOTARY OR THE COURT IS ATTACHED TO THIS NOTICE. 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 OFnCE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland county Court Administrator Cumberland County Courthouse South Hanover Street Carlisle, Pennsylvania 17013 (717) 240-6200 , ERNEST R. JOHNSON, Plaintirf IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. NO. CIVIL 1995 CAROLYN I. JOHNSON, Defendant IN DIVORCE COUHTZR-AFFIDAVIT UNDZR SICTION 3301 (Dl OF Ta. DIVORCZ COD. 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry ot a divorce decree becauee (Check (i), (ii), or both): (i) The parties to this action have not lived separate and apart for a period of at least two year.. (ii) The marriage is not irretrievably broken. Z. Check either (a) or (b): (a) I do not wish to mllke any claillls for econollic relief. I understand that I lIIay 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 verify that the statements made in this counter-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: CAROLYN I. JOHNSON, DEFENDANT NOTICE: If you do not wiah to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file this counter-affidavit. (.: N .~ .' CJ Ie: ~.:: .. ~:_i tLlr-! - .- f }... , L't. .- --;.1 u_ .; (<1',_ 6~-~ ~.;) '!, ~ IJ I'~- 1" _._J u.;ll L' I.: , -. " .' ". 11-) ---) l.J t.-' U ERNEST R. JOHNSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. , -'-'-"" NO. ;. ..' ,,'/ CIVIL -19%- CAROLYN I. JOHNSON, Defendant IN DIVORCE MOTICI TO DIPIND AND CLAIM RIOHTS 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 will proceed without you and a decree in 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 many lose money or property or other rights important to you, inclUding custody or visitation of your children. When the ground for the divorce ie indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A I ist of marriage counsel ore is available in the Office of the Prothonotary at the First Floor, Cumberland county Courthouse, South Hanover street, carlisle, Cumberland county, Pennsylvania, 17013. Ir YOU DO NOT rILl A CLAIM rOR ALIMONY, DIVISION or MARITAL .ao.IRTY, LAWYIR'S rll, OR IX'INSIS BI'ORI A DIVOROI IS OaANTID, YOU KAY LOSI THI RIOHT TO CLAIM ANY or THIM. yOU SHOULD TA.. THI' 'A'IR TO YOUR LAWYIR AT ONOI, IP YOU DO NOT HAV' A LAWY'. OR CANNOT ArrORD aNI, 00 TO OR TILI'.O.I f.. orrIO' liT rORTH BILOW TO rIND OUR WHBRI YOU CAN Olf LIOAL HIL.. cumberland county court Admlnlutrator Cumburland County courthaull Routh Ilanovur /it-reet Carlllllu, Pennsylvllnia 1'1013 (717) 240-6200 .. " ERNEST R. JOHNSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAllD COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. CAROLYN I. JOHNSON, Defendant NO. CIVIL 1995 IN DIVORCE COM'LAINT IN DIVORCB 1. Plaintiff is Ernest R. Johnson, an adult individual currently residing at J Strawberry Lane, Carlisle, Cumberland County, Pennsylvania 17013. Plaintiff has resided at this address since May 1, 1992. 2. Defendant is Carolyn I. Johnson, an adult individual currently residing at P.O. BOle 923, Portland, Tennessee 37148. Defendant has resided at this address since 1992. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filinq of this Complaint. 4. Plaintiff and Defendant were married on November 17, 1987 in Dillon, South Carolina. 5. There have been no prior actions for divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and the Plaintiff may have the right of request that the Court requires the parties to participate in counseling. WHEREFORE, Plaintiff requests the court to enter a decree of divorce pursuant to Section 3301 (c) of the Divoroe Code. COUNT II 8. Paragraphs 1 through 7 are incorporated herein by reference as it set forth in their full text. 9. The parties have lived separate and apart since May 1, 1992, and have remained separated since that time. WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce under Section 3301(d) of the Divorce Code of 1980, as am~nded. Respectfully SUbmitted, GRIFFIE & ASSOCIATES By: .', I/"~~~A Barbara J. Y n, re 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 Date I 04//;:.)/q)- VIIRII'ICATIOII I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING COMPLAINT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN HADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: 15 ~~\ 95 ~'Jit~,:f~J ERNEST R. JOHNSON, PLAINTIFF ERNEST R. JOIlNSON, Plaint! ff IN 'l'IlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. CAROLYN I. JOIlNSON, Defendant NO, IN DIVORCE CIVIL 1995 NOTICI TO THE DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a Counter-affidavit twenty (20) days after this Aff idav i t has been served on you or the statements will be admitted. PLAINTIrr'B ArrIDAVIT UKDIR UNDIR SIOTION 3301 (dl or TH' DIVORCI CODI 1. The parties to this aotion separatsd on May 1, 1992, and have oontinued to live separate and apart for a period of at least two years, 2. The marriage is irretrievably broken. J. I understand that I may lose my rights oonoerning alimony, division of property, lawyers fees or expenses if I do not claim them before a divorce ie granted, IllU.rIOATlON I VEIUFY 'l'IlAT 'I'llI'. 6'l'ATt:MEN'I'S MADE IN 'I'llI'. FOREGOING COMPLAINT ARE TRUE ANIl COllllEc'r. 1 UNDER5'1'ANlJ 'l'IIA'l' FALSE STATEMENTS HEREIN MADE ARE BUIlJF.C'I' 'I'D TilE I'I'.NAI.'I'IUI OF' 18 I'A.C,S. SECTION 4904 RELATING TO UNBWOIlN F'AWIt'!CA'l'ION 'J'O AIlTIlOlll'l'lES, DATEI &~~~.~~_,. ,~~..~.u~ 'n~- ~RN~BT R, JOHN~tltt ,'... ~n ~ ,} ~\~ ~ ~ \\ ~\j I \) r.!' " 'I r7 ~ ~ ~ fJ } t ~ ~ <....1 ~ ~ :z: i . .... .., IJl B~ .... I': U '... III p: ..., .'0 ~ ~B :Z:I': ~@ ~ t; 0,... H ~~ lJl.... 0 ~ ... ~~~ ~(l) :z: ~Jl' 8 ~ oil< 00 H B ~ .., . .., d~ ~ - . ~ ~ ,... VI : . R z . e~i II: H H E z Q. ~ ~ ~ ~ ~ j '" ~~ ~ H~ ~ ~ . ... ::; Ul ~ ~~Il< ~ 8 ~ < z 3 ... z ~ n: 8 I ~ l!) N U ',':"'I...tl"'I' , tnfl'llll......'lI .nl""." "ntl,!"",. ,/, .. . ERNEST R. JOHNSON, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. :23~"'1 CIVIL 1995 IN DIVORCE vs. CAROLYN I. JOHNSON, Defendant ArrIDAVIT or SIRVIC. I HEREBY CERTIFY THAT I served a copy of the Notice of Intention to Request Entry of Decree in Divorce and the Counter- Affidavit Under section 3301)d) of the Divorce Code ufon carolyn I. Johnson, and received on May ;:6, 1995, by cert fled lIIail, restricted delivery at the following addressl Carolyn I. Johnson 3416 Highway 109 S. portland, TN 37148 I verify that the statement. made in the foregoing Affidavit of Service are true and correct to the best of my knowledge, information, and belief. I understand that any false state.ents herein lIIade are subject to the penalties of Pa.R.civ. P 404 relatinq to unsworn falsification to authorities. iJl-f)/91/ D E r IE , ASSOCIATES J1/)) l -(i ~~ M. LeCla r, Secretary 2 0 North Henover street C rlisle, PA 17013 (717) 243-5551 (800) 347-5552 ERNEST R. JOHNSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 95-2384 CIVIL TERM IN DIVORCE CAROLYN I. JOHNSON, Defendant ~FrIDAVIT or SZRVICB AND NOW, this 19th day of october, 1995, comes Bradley L. Griffie, Esquire, Attorney for Plaintiff, Ernest R. Johnson, and states that he personally mailed a copy of correspondence and notice from the Master dated September 27, 1995 to the Defendant 3416 Highway 109S, portland, TN 37148, by certified and restricted mail, return receipt requested. A copy of said receipt is attached hereto indicating service was made on october 13, 1995. /'/ ../~ , '.. ~ ' (' t/).' /,,/ A ,/ / B d~e '';Ly r ff e, EBqU re RIF ~ ASSOCIATES 200. i:lrth Hanover street C~61isle, Pennsylvania 71013 (717) 243-5551 Sworn and subscribed to this 19 (i.J day of october, 1995, - ) ;'1' 0, A \ I , , , 1/ .. -' A~" /. ,'L 1'1 Noln~al 5881 Robin J. Go.hom, Nolnry Publlo CarUale Ooro, Cumherland County My Comml..lon EII".' April 17, 1999 Z 069 875 596 4 _ Receipt for 4L ~,~~~~~~,~~~, ~~.I,I'I!ll' ;>'''\1111,<1 .~"J'a'~'J:t'i ':1)' (lIllIii' 111I 11111'11',II'UII.11 Moil _..._ (...'1' R4'\l!f"I') -..4i;.~:~'Iu.l;tJ.... .. ;J'II'f-' . t~J pdkiJ.Jl..TtJ ,/1'1.1-' I _...,- $ l..i.' IJ(). ;J~ ~- 1.10 --.'1. ~._- " , i! ~ I "" (.", i " l" i r .... ~ i '...,,2":. , . '; , . l I \ l \ ( .. ERNEST R. JOHNSON, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. ,) \~? 'I CIVIL 1995 IN DIVORCE vs. CAROLYN I. JOHNSON, Defendant COUNiiTiBR-ArrID~VIT UNDER BBCTION 3~__ 101 or THE DIVORCB COD. 1. Check either (a) or (b): ~ 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 claims 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. I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. '\ t..' . ~ J;"'(9' ".. , ~ (b I verify that the statements made in this counter-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. D t r') y' a e I "... ; Jj/ .I . i. C~Ro'~~~t. ;~1~8ot1;DtF~NDANT NOTICEI If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file this counter-affidavit. ........---' .". ERNEST R. JOHNSON, Plaintitr vs. : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CAROLYN I. JOHNSON, Defendant NO. IN DIVORCE CIVIL 1995 COUNTBR-ArrIDAVIT UNDIR 810TIO. 3301 (DI or TBI DIVORCI COD. 1. Check either (a) or (b): ~ I do not oppose the entry of a divorce decree. Cb) I oppose the entry of a divorce decrse becaus. (Check (i), (ii), or both): (i) The parties to this action have not lived separate and apart for a period of at le..t two years. (ii) The marriage is not irretrievably broksn. Z. Check either (a) or (b)l (a) I do not wish to make any claims tor econosic rsl ief. I understand that I say lose rights concerning alimony, division of property, lawyer'. fees or expenses if I do not claim thelll before a divorce is granted. I wish to claim economic relief which may include alimony, division of property, lawyer's tees or expenses or other important right.. c..-- \ J ~e I verify that the statements made in this counter-aftidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 490.. relating to unsworn falsification to authorities. " Datel ~~ //~ ~ r4 ' Y]L ' ~~ ~ iiii ---- CARO I. JO bN, DEFENDANT NOTICE. If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for econolllic relief, you need not file this counter-affidavit, ~, ERNEST R. JOHNSON, Plaintiff I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. /r:. ,))'.\'1' CIVIL '~I IN DIVORCE VS. CAROLYN I. JOHNSON, Defendant AFFIDAVIT OF 8ZRVICB AND NOW, this day of May, 1995, comes Barbara J. Yunis, Esquire, Attorney for Plaintiff, and states that she personally mailed a certified and true copy of a Complaint in Divorce, to Carolyn 1. Johnson, at 3416 Highway 109 s., Portland, TN 37148, by certified mail, return receipt requested. A copy of said receipt is attached hereto indicating service was made on May 12, 1995. /.1111 1 n B, Esquire , A SOCIATES 200 North Hanover street Carlisle, PA 17013 Sworn and subscribed before m. this II day of May, 1995. ...... ,I I ,,-_L.L_, --'-'--1 Il, !.lIlal ',- ill 1 l', . 'j I..,,, Pul'!" llit I; ,,-.\.1,1 ,- ,-,.., - ~ t"til~ 10m Ll.llt,lH./L}lld! (~lll ~ _ ; C~llIllifl ~_ ~JJlIf1" _~,~I~.ol~_~I~.... EI1NEST U. ,JOIINBON. I IN TilE COURT OF COMMON PLEAS OF I'lainlll t : CUMBEI1LAND COUNTY, PENNSYLVANIA I I CIVIL ACT ION - LAW I VB. : NO. 2 JIl4 CIVIL 19 95 CAUOLYN J. ,JOIINHON. : lJel'endilnl : IN DIVORCE STATUS SIlEE1' DATE: ACTIVITIES: 1)/27/1)5 . t' ' ! " F,~~;v~}i;k.~6/:f{r/~t~~~t~1 ClL-~l l./t _~l,.........mR# ,.........:(- T~r~;;,'./ ,. ~7~'---:7-;T~7;-;---~'T;---;~~. ;~----:./fyd.11 ~/W~~-;J"'J. 'J; ','/ , . r ,/".,.J' ,. /1,(.'/,. "'/";,'" 'if., .)~'" (II f<111 F<' ( i I:" "fl(..1I/(f.,I(), ,-",,;..,-:1 '1 , '.I..,lu,1 .{ ,-h'li ro~Ar,- I :"(U;(! '* OFFICE OF DIVORCE MASTER CUMIlERLAND COUNTY COURT OF COMMON PLEAS 9 North Hanover Street Carlisle, PA 17013 (7171240.6535 E. Robert Elicker, II Divorce Master Tracl .10 Col~er Olllee Manager/Reporter West Ihore 697,0371 Ex.. 6535 September 27, 1995 Bradley L. GriffiE, Esquire GRIFFIE & ASSOCIATES 200 North Hanover street Carlisle, PA 17013 carolyn I. Johnson 3416 Highway 109 S. Portland, TN 37148 REI Ernsst R. Johnson vs, Carolyn I. Johnson No. 95 - 2384 In Divorce Dear Mr. Griffie and Ms. Johnson: By order of Court of President Judge Harold E. sheely dated September 21, 1995, the full-time Master has been appointed in above referenced divorce proceedings. A divorce complaint was filed on May 3, 1995, averring grounds for divorce of irretrievable breakdown of the marriage and specifically averring that the parties separated on May 1, 1992, a period in excess of two years. The Defendant filed a counter-affidavit under Section 3301(d) on June 15, 1995, indicating that she did not oppose the entry of a divorce decree but that she wished to raise economic relief. However, to date, the Defendant, Carolyn I. Johnson, has not filed any pleadings or petitions with the court raising economic claims, I am going to give Ms, Johnson until Monday, October 23, 1995, to raise the economic claims which she indicated she wished to raised so that a pre-trial directive can be iesued for the filing of a pre-trial statement and subsequently a hearing scheduled on those issues, If Ms, Johnson does not raise economic claims by October 23, 1995, 1 will consider her rights waived in this action and will submit the matter to the Court requesting that my appointment be vacated allowing Mr. Griffie, on behalf of Mr, Johnson, to rile a praecipe transmitting the record to the Court requesting a final decree in divorce without , Mr. Griffie, Attorney at Law and Ms. Johnson, Defendant 27 September 1995 Page 2 preservation of any economic issues. Very truly yours, E. Robert Elicker, II Divorce Master BMDu y l. GRI"IE McH'UI R. CAl-WAf GRIFFIE & ASSOCIATES A TTORNEYS AND COUNSelORS AT lAW 200 NORlli HANJWR 9"'ln C...,OU, PA 17013 (717) 243-5551 1(8001347-5552 FAX 717-243.5063 TRACY L C.uu luw.AIIlITA"'T RoliN J _ GolHORN OFfICI MA.....GE:R October 26, 1995 CHAMIfRIIURG TRull BuIlOIPf3 Sun. 550, 14 NeATH MA", Sm," C.........IIURO, PA 17201 (717) 257,1350 RIPLY ro. CAIUSlI E. Robert Elicker, II, Esquire 9 North Hanover street Carlisle, PA 17013 RE: Johnson v. Johnson No. 95-2384 In Divorce Dear Mr. Elicker: Pursuant to your directive of September 27, 1995, which was served by certified mail/restricted delivery by my office upon the defendant, I nots that Monday, October 23, 1995 has passed. To my knowledge, Ms. Johnson, the defendant, has not raised any economic issues. Therefore, pursuant to your directive, I r..pectfully request that you so notify the court that Ms. Johnson has failed to advance her case, and further, as Master, that you indicate Ms. Johnson has, through her inactivity, abandoned her claims for economic relief. Your attention and cooperation in this regard is appreciated. Very truly yours, ( .'~~~~J~:)ASSOCIATES ,-,' I/", ,// / LEY L. GRIFFIE BLG/lac CCI Ernest R. John~on Carolyn I. Johnson ERNEST R. JOHNSON I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I V. I I I CAROLYN I. JOHNSON I 95-2384 CIVIL TERM I I DIVORCE ACTION - LAW OIDIR 0.. COURT AND NOW, this 21st day of DICIHBIR, 1995, the appointment of E. Robert Elicker, Esquire, as Master in the above case is vacated. Counsel for the plaintiff may have the record submitted to the court with an appropriate decree. No economic claims ~emain because the defendant has failed to raise any economic issues with Mr. Elioker prior to Ootober 23, 1995, or after that time, as she was direoted to do. By the Court, , C t. ~ l a old E. / .J. E. Robert Elicker, Esquire Divorce Master . tjt~"", ;n'-A.tiui Bradley L. Griffie, Esquire iJ.)J.:J}lS' ._ i2.t.-- Carolyn I. Johnson, Pro Se IBld mEn ,Co.-nCE 0: i1'~ r"", :rp,]T''''( Jj I.,., ,I -.i, II\.' SI:J r~~ ~ I Pi! 3: na C'J"'" , ..", I~' ~ 1 '. ,'. :'j i '.! " J \ ~., 1_ I __ I I PI~":,\:~; "~ ~,/", 1""1 ....... L o.w.. ........... R CALVI.,. '-" M s......., GRIFFIE & ASSOCIATES A TTORNEYS AND COUNSELORS AT LAW 200 NOftTlf HAN)..... S""fT C.~..., PA 17013 (717) U3,1l551 1 (1001347.5552 FAX 717.2.".5013 Roo.. J. 00,,,,,,,,, c..a ""'..... December 11, 1995 CtWlIIIIIIN\.N TMJIT ~1N) IIooTt 150, 1. Norm< """" S",u' C_........., PA 17201 (717)217'1350 At"., ro. CAfI...;llJ The Honorable Harold E. Sheely President Judge Fourth Floor, Judges' Chambers Cumberland County Courthouse Carliele, PA 17013 RE: Ernest R. Johnson VB. carolyn I. Johnson No. 2384 civil 1995 In Divorce Dear Judge SheelYI Enolosed i. a photocopy of correepondence that wae forwarded to you by the etanding Master, E. Robert Elicker, II, Eequire on October 30, 1995. As indicated in thie Memorandum, the Defendant filed a Counter-Affidavit Pursuant to Section 3301(d) of the Do.eetic Relatione Code. In that Counter-Affidavit she lIIade indication that there were economic iseuee to be claillled by her. However, ehe ha. failed and refused to take part in any aspeot of the Maeter'. proceedings, inclUding even making contact with the Ma.t.r'. offlce. Based upon that and ba.ed upon prior .imilar c.s.., it i. my underst.nding that the Maeter has reco..ended the Court authorile our proceeding to finalile the divorce under Section 3301(d). In reviewing the docket, I note that there has been no action teken on this case. My client was extremely hopeful of being able to conolude this divorce before the end of II1IUI. I advi.ed him that I would contact your offlce to determlne whether we can expedite this in any fashion so ae to allow me to file a Praeolpe to Tran.mit the Record and other appropriate doouments concluding this divorce in prompt fashion. Your attention and conelderation in thie matter would be appreoiated. Very truly youre, QarFFIE , ASSOCIATES pr.dley t, Griftie 8Ul/r1lJ CCI Ernest R. Johnson " OFFICE OF DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEAS 9 Nonh Hanover Slreet Carlisle, PA 17013 (717) 240.6535 I. 1I.1Ie,. I"ck.r, 1/ Oivo,ce Mas.e, Treel .I. C.I"., Ofllce Manlllle"Repone, WOIt ah.ro 697.0371 Ext, 6535 TOI Thft Honorable Harold E. Sheely, President Judge FROM: E. Robert Elicker, II, Divorce Master DATE: Monday, October ]0, 1995 RE: Ernest R. Johnson vs. Carolyn I. Johnson No. 2384 civil 1995 In Divorce A divorce complaint was filed on May], 1995, and attached to the complaint waG an affidavit under Section ]301(d) of the Divorce Code averring that the parties separated on May 1, 1992. No economic claims were raised in the complaint. On June 15, 1995, the Def.ndant filed a counter-aftidavit indicating sh. did not oppose the entry of a divorce decree but that she wished to raise economic relief. After the Master was appointed and noted that no economic issues have been raised in the case by appropriate pleadings, the Master sent a letter to Mr. Oriffie and directly to Ms, Johneon who ie not represented by counsel dated September 27, 1995. The letter is attached with this memo. The third paragraph of the letter advisee Me. Johnson that she has until October 23, 1995, to raise economic claims and that if she does not raise claime that the Master would consider her rights waived in the action and would submit the matter to the Court requesting the vacation of the Master's appointment. On october 26, 1995, Mr, Griffie wrote a letter to the Master requesting that the Master proceed with the conclusion of the file inasmuch as the Defendant has not raised economic issues. This iseue is somewhat similar to the MacGregor case as previously submitted to the Court by d memo last week. The , . Judge Sheely 2 30 October 1995 Master believes under the circumstances it is appropriate that hi. appointment be vacated; however, the remaining matter is whether or not the Court is inclined to include in its order of vacation ot the Master's appointment a termination of any rights to subsequently raise economic claims. The Master did indicate in the letter to Ms. Johnson that he would consider her rights to raise claims waived if she did not file the appropriate pleadings specifically raising economic issues. However, I thought it appropriate that I should submit this matter to the Court by melllo as I did in the MacGregor case previously. For the Court's information, the Master requested that Mr. Gritfie send a copy of the Master's letter by certitied mail, restricted delivery to Carolyn I. Johnson. Hr. Griffie's Office filed an affidavit of service indicating that the correspondence from the Master dated September 27, 1995, was received by the Defendant on October 13, 1995. A copy of this memo is being sent to attorney Griffie and Ms. Johnson. E. Robert Elicker, II Divorce Master cc: B~~~iffie A~~ a ntiff Carolyn I. Jo son Pro Se