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Home My WebLink About95-03894 ';j 3 ~ J 'h " .Jj .7 L tV 1 a 0 [ c... ~ J ':t- ~ '. "'j;. *_.~*-~--*~-*-*~*~.~*~.~*.~.__.~-----~ $i ._~_v~_~,.______,__ .--. .-.'---."......,... _. _. - ... ........ ~-~_.---..i$ ",I I' ~I ~ ~: IN THE COURT OF COMMON PLEAS i* $1 I~ *1 ~l ~i ~' . , . -" .:.' ~ OF CUMBERLAND ~. STATE OF i~~~ PENNA, COUNTY ~ ~ JANET L,DARHOWER, Plaintiff ..... It) i\: (I, .9.5"..:Ut9.4 ~ ~, \' (.1....11:-; ~ MICHAEL E, DARHOWER, ~ Defendant ~ ',' " ~ ~ DECREE IN AND Now.~k~~ 1~'~~ :::d:'!. ~~ decreed that,.." " , "", .. ~,"'~Er. .1.. ,DARI;IOl'l,ER.,. . ",."" " plaintiff, and, "" " """., "'," ,., ,MICHAEL, E. ,DARHOWER. " .", ", defendant. are divorced from the bonds of matrimony, ~ Wi ... ~ :> ,. ,', ~ ~ 1i ", $ 8 $ s ~ .,' ,'~ ~ The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order hos not yet been entered; l'ieli!, ,S,t;ipJJ~a t ion ,of. ,the, parti.es, regard,ing. equi ta.ble, distr,ibuti~n ~I')tl'!.r,ec;l, N,Q~e01P,er, 8.,. .199.6. ,a t. ni vor.ce, Master, ,proceeding, , , . , , , , , , , ." ~ ~ iIr,lu/U, l~ tJdJ(,f, /?"'~)r...~..:/' /J ' I ~L 7' v ~71!6'A" ~~.: r ..J{elf:! 74 , ""PrntllOl1ol.\I')' ,', ~ ~ ,,' W <:' u r I : * ~ ~I ~I ~,";: '" .,. ,.... .{jf_, '::.1'.' ...... ..... ..... ..... ..... ..... ~.***~*-*~.***.~~,~.,*.~*.~,.~.~. ~ * ~ ~ :~ $ ~ '.' ~ .. ~ I~ /'.' I I' I~ I~ V i~ I~ (".' /W .. ~~ : ~ .~ ::i!! ~ I:i: }~ I' ;... I~ , :!. ~ ~ ~ .- ~ \~ ~ ~ ~ ~ ~ ~ -:.;. .. /;;.~).~tf. de-!, (0/7 /t,,~,,~ T aif /Jl~ /.;J ;)) ,'J ~'J~ - ..~".,!/ " yt: //V4'-<!.-" /~a...t'l:,,/ ;:$ <~., . '. -. , ".. . IN TIlE COURT OF COMtION PLEAS OF CU}WERLAND COUNTY, PENNSYLVANIA NO, 95-3894 CIVIL 19 Janet l, Darhowcr vs, Michael E. narhowcr PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: :J3D1 ' 1. Ground for divorce: irretrievable breakdown under Section (i9i(c)) lMfl( ~~cI)(l(llJ of the Divorce Code. (Strike out inapplicable section,) 2, Date and manner of service of the complaint: August 26, 1995 by Constable at Defendant's RpRi~pn~p 3. (Complete either paragraph (a) or (b) ,) '(a) Date of execution of the affidavit of consent required by Section 3Jbf' , ~(c) ~! the Divorce Code: by the plaintiff i' November B. 1996 b.r defendant " Novemte r 8, 1996 1b) (l),Date of execution of the plaintiff's affidavit required by , (,33C,1 Section':&l(d) of the Divorce Code: {. . n, (2) Date of service of the plaintiff's affidavit upon the defendant: 4, Related claims pending: 5, Indicate date and manner of service of the notice of intention to file 3.301 praecipe to transmit record, and attach a copy of said notice under section ~ (d) (1) (i) of the Divorce Code. N/'" /J//J.~~ Attorney for (Plainti ) X~l!K~ . ~ w ;- 0 . - ',," 16 N . ~1 od' t.")~": f:; - 'J~ -- ~. Co. I",!~ e- M :jfEJ r;. -ffi L, ". ll: (..l ',il f'.; LI.! .'1"- c:::> u, ~o ::5 0 0' u .. ,f ~ , . JANET L, DARHOWER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 95 - 3894 CIVIL vs, MICHAEL E, DARHOWER, Defendant IN DIVORCE ORDER OF COURT AND NOW, this C rff. day of I}J~ V A\j~, 1996, the parties and counsel having entered into an agreement and stipulation resolving the economic issues on November 8, 1996, the date set for a Master's hearing, the agreement and stipulation having been transcribed and subsequently signed by the parties and counsel, the appointment of the Master is vacated, and counsel can conclude the proceedings by the filing of a praecipe to transmit the record with the affidavits of consent of the parties so that a final decree in divorce can be entered, BY THE COURT, cc: RiChard L, Webber, Jr, Attorney for Plaintiff MiChael E, Darhower Pro Se f1...~,.. ()>~<L II( fr I 'H, .....~ ..s ~ P,J, ,.. \... ",;!:~ :'~:lJ ..:\-, ,'."- ". ,- ....~ , ""-' . J-" ('r, ~U.t' 'I'J' 8-;, .,.1", o 'v" ,., t\~I, '. , .,'J :. j,t. :;J , ,(Ji; ~~;~;j"u' :a:fll:l JWI.J_ \ ~ . . . " vs, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 95 - 3894 CIVIL JANET L, DARHOWER, Plaintiff . , MICHAEL E, DARHOWER, Defendant IN DIVORCE THE MASTER: Today is Friday, November 8, 1996, This is a date set for a hearing in the Darhower case, Present in the hearing room are the Plaintiff, Janet R, Darhower, and her counsel Richard L, Webber, Jr, and the Defendant, Michael E, Darhower, Mr, Darhower is not represented by counsel, This matter was before the Master on July 15, 1996, at which time we entered an agreement on the record which contained certain provisions of a contingent nature regarding Mr, Darhower's desire to purchase the marital real estate and mobile home which is the asset subject to equitable distribution, Following that agreement the Master vacated his appointment; however, Mr, Darhower, for whatever reason, was unable to follow through with the provisions regarding a payment of the funds to wife to take possession and ownership of the real estate and mobile home; therefore, Mr, Webber petitioned the Court which entered an order reappointing the Master which was done on September 23, 1996, The Master upon receiving notice of his reappointment scheduled the hearing for today to attempt to resolve the issues that have been previously discussed and have not been completed as a result of the prior , / . agreement, After discussion with counsel and the parties, the Master has been advised that the parties have come to an agreement with respect to the settlement on the real estate and mobile home, That agreement is going to be placed on the record in the presence of the parties and that agreement as stated on the record will be considered the substantive agreement of the parties, not subject to modification or changes except for correction of typographical errors which may be made during the transcription, The parties and Mr, Webber are going to return later this morning to review the draft of the agreement for any typographical errors which will be corrected after which the parties and Mr, Webber will sign by way of affirmation of the agreement which is being stated on the record at this time, Mr, Webber is also going to provide at the time that the parties return affidavits of consent and waiver of notice of intention to request entry of divorce decree so that the divorce can be concluded under Section 3301(c) of the Domestic Relations Code, Previously, the parties had intended to the conclude the divorce under Section 3301(d); however; at this time both parties are agreeable to executing the affidavits of consent and waivers, After the agreement has been reviewed and signed and the affidavits and waivers have been signed, the Master will , . I prepare an order vacating his appointment and Mr, Webber can proceed to request the Court to enter a final decree in divorce, Mr, Webber, MR, WEBBER: Good morning, Mr, Elicker. The parties stipulate and agree as follows: 1, The parties shall attempt to sell the marital real estate located at 601 Burgners Road, carlisle, pennsylvania, including the residence and shed situate on said real estate, 2, The parties shall first attempt to sell the property to their daughter, JoAnn Darhower for the sum of $26,500,00. 3, In the event that JoAnn Darhower does not purchase the property by December 31, 1996, the parties shall cooperate in attempting to sell the real estate to another prospective buyer, The parties shall cooperate in deciding whether or not to use a realtor to sell the property, the choice of a realtor if applicable, the establishment of a listing price and the establishment of the ultimate sales price, The parties shall be obligated to communicate any offers or counter-offers to the other party, 4, The washer and dryer that are located in the marital real estate are to be retained by the Defendant, JoAnn Darhower shall receive the refrigerator located in the trailer, The stove shall be included in the sale of the marital residence, 5, The Defendant shall vacate the premises on or before November 30, 1996, He shall ensure that the heat source remains intact for heating the premises for the winter season. He shall be obligated to drain the pipes and plumbing, The defendant shall be responsible for the taxes and maintenance on the premises until the day he vacates, subsequent to the date that the Defendant vacates the premises, the parties shall be equally responsible for any taxes and maintenance and any utilities to the premises. . 6. Upon the sale of the marital real estate, the proceeds shall be distributed as follows: a) Plaintiff shall receive the sum of $657,28, representing delinquent taxes which she paid in September 1996 to prevent the property from being sold at a tax sale. b) Plaintiff shall receive a sum equal to the amount of real estate taxes for the property that were incurred from the date of separation to the date that Defendant vacates the property, c) Plaintiff shall be entitled to the sum of $100,00 for each month that Defendant lives in the premises subsequent to November 30, 1996, if applicable, Said sum represents 1{2 of what the parties agree is the fair rental value of the property, d) The remaining net proceeds shall be split equally between the parties, 7, The Court shall have jurisdication to modify this agreement in the event that any conflicts arise between the parties that cannot be resolved by them, 8, The parties will sign affidavits of consent and waivers of notice of intention to request entry of divorce decree and counsel for wife shall be authorized to immediately file a praecipe transmitting the record to the Court requesting a final decree in divorce, 9, Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship including without limitation, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate, Each will at the request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights, and claims. MR, WEBBER: Ms. Darhower, were you present here today when I read the stipulation that purports to be the agreement between you and your husband the Defendant, Michael E, Darhower? MS, DARHOWER: Yes, MR, WEBBER: And did you understand the terms of that stipulation and agreement that I read? MS. DARHOWER: Yes, MR, WEBBER: Are you satisfied with those terms for purposes of equitable distribution of the marital assets? MS, DARHOWER: Yes, MR, WEBBER: And satisfaction of all of the various issues that have arisen between the two of you as a result of your relationship as husband and wife? MS, DARHOWER: Yes, MR, WEBBERT: And as a result of my reading those terms, are you willing, in fact, to sign an agreement containing those exact terms? MS, DARHOWER: Yes, MR, WEBBER: will you also agree to sign an affidavit of consent and waiver of notice under Section 3301(c) of the Domestic Relations Code? MS, DARHOWER: Yes, THE MASTER: Mr. Darhower, you've been present during the statement of the agreement; is that correct? \i . ". MR, DARHOWER: Yes, THE MASTER: Do you have any questions about it? MR, DARHOWER: No, sir, THE MASTER: Do you understand it? MR, DARHOWER: Yes, THE MASTER: You heard the questions that Mr, Webber asked of your wife, do you understand that this a final agreement to settle and resolve all issues outstanding between you and your wife with respect to the marital relationship? MR, DARHOWER: Yes, sir, THE MASTER: And you're satisfied to conclude all of the issues by this agreement? MR, DARHOWER: Yes, I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations Code, WITNESS: DATE: "J'./'I /""<< Richard L, Webber, Jr, Attorney for Plaintiff ~rJ ~ tt:;-,,,h'U net L" arliowe //-S'-y~ -7-//-k( %~~l;;~~- Michael E, Darhower , J~ ) ,~ ~ Q:5vi ". ~ a ~ ~ ~ \e., v; 0 h g' ',; ; .,J..... ~--.. - - .. ~ .J l:li ! ~ e ::R - :-r.: ..... ,.., "> N - '" ~ ~ - , . , ... ~ r- ~ ..J l"\ T' . . . . . . ; ..' '; .. ,. ~ . IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA JANET L, DARHOWER, PLAINTIFF CIVIL ACTION - LAW v, NO, 95- 3./'fi'l CIVIL TERM MICHAEL E, DARHOWER, DEFENDANT IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action, You are warned that if you fail to do so, the case may proceed without you 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 visitation of your children, When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, 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. Court Administrator Cumberland County Courthouse I Courthouse Square Carlisle, Pennsylvania 17013 Phone (717) 240-6200 .. , . IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA JANET L. DARHOWER, PLAINTIFF CIVIL ACTION - LAW v. NO. 95- IN'1 CIVIL TERM MICHAEL E, DARHOWER, DEFENDANT IN DIVORCE COMPLAINT IN DIVORCE COUNT I GROUNDS FOR NO-FAULT DIVORCE UNDER SECTION 3301(c) or 3301(d) OF DIVORCE CODE 1. Plaintiff is Janet L. 184B Big Spring Terrace, Pennsylvania, since August 26, Darhower, who Newville, 1992, currently resides at Cumberland County, 2. Defendant is Michael E. Darhower, who currently resides at 601 Bursners Road, Cumberland County, Pennsylvania, since September 3, 1987. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 28, 1961 in Newville, Cumberland County, Pennsylvania. 5. The parties separated on or about August 26, 1992, which is the date of final separation. 6. There have been no prior actions of divorce or for annulment between the parties. 7. 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. 9. Neither Plaintiff nor Defendant is in the naval service of the United States or its allies provisions of the Soldiers' . Sailors' Civil Relief Congress of 1940 and its amendments. military or within the Act of the , , 10. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff respectfully requests that a divorce decree be issued. COUNT II REQUEST FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTIONS 3104 AND 3502(a) OF THE DIVORCE CODE 14. The prior paragraphs of this Complaint are incorporated herein by reference. 15. real and marriage Plaintiff and Defendant have acquired property, personal during their marriage from the date of until the date of their separation. both said 16, Plaintiff and Defendant have been unable to agree as to an equitable distribution of said property. WHEREFORE, Plaintiff respectfully request equitably distribute the marital property of pursuant to 3104 and 3502(a) of the Divorce Code. the Court to the parties, ... Richard L. Webber, J . Attorney for Plaintiff 366 Green Spring Road P.O, Box 40 Newville, PA 17241-0040 (717) 776-6566 ...' \ - . , I verify that the statements made in this Complaint and correct. I understand that false statements herein subject to the penalties of 18 Pa.C.S,A. Section 4904, to unsworn falsification to authorities. are true are made relating Date: J-'-/7 leI) fl'iS- ~~ i~.t//,,~.J et L. lJar ower, lainti rf '- N ~-- ~:; ..:z ...~ l1 lU~.' )~- C-). "'.) If! ; .:-~,J ,~ . . l.- ,::.: 9: .,~ c' c.... ';..) ll:'. ;. ~:, G:I c- . '~;J roo , , ..... 1.'- -.:') ._J L, .... v ~ 0 .' , ... ; ~ ,; , , ,t ~ , ,. . ...' IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA JANET L. DARHOWER, PLAINTIFF CIVIL ACTION - LAW v, : NO. 95-3894 CIVIL TERM MICHAEL E. DARHOWER, DEFENDANT IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : SS Donald L. Flagle II, Constable, being duly sworn according to law, deposes and says that he served the Reinstated Complaint in Divorce on the Defendant, Michael E. Darhower by personally handing it to him on August 26, 1995 at 7:30 p.m. at Defendant's residence located at 601 Burgners Road, CarliSle, PA 17013, My official return of service is attached hereto. (' //JrJ 'f'. /"1. .<- C? 'b ~L_ ,( ,"" ,;. ~t Donald L. Flagle II, Constable 65 South High Street NeWville, PA 17241 (717) 776-6789 Sworn to and subscribed before me this IS' I ~ day of frh""L l., , 1996. -yV/l, vv~ Notary Public 1_-, . R' ':0iA'~I"i.-sr~L - ._-~,,~ ,d,,, ! l \"!JI, N ' ' . . .r. Jr., NO'.ry 'uLlte .."",11. 8"" C ' M co, "me"Iend Counf~ ~_"'_,":.I~~U:I. E.Pl,., Apli' 20. "" I.... .' NOTICE I, Donald L, Flagle, II, served _ p~_n!/ , , -4Y /g</JJl name of person to of address of person served 049, ~ . /9~1" j 7,: ~O-YJ'-rl . ~te and ttme served r- on ,'~~:."~ J .tem served ,.";'...., I' ..h : J fA j.."L....~........ served 0J9J~ Donald ~ Flagle, II pennsylvania state Constable ~ 80.00 c"U-\:.u, FeE, J.LJ ,'Fr L ~1);AI!.H['h,/r:() _.__ .t.~~_. ....l.__________U~I.J.:..___._...__~ ) d~, _'1, .(,f ------------------------._----~-------- -- [a dill Coun 01 Commoa Plaa 01 CumbcriaDd CoUllcy, PCIIIIIY"'" VI. 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S61 ~~ 1111 0\ pZ anv (f) !' , .--- " JANET L, DARHOWER, I PLAINTIFF I I VS, I : MICHAEL E, DARHOWER, : DEFENDANT : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - NO, 95-3894 LAW (, ," CIVIL TERM" .,_,; r..: , ,; IN DIVORCE l NOTICE TO THE DEFENDANT . ~.. ',. - c- :J; tfiis (20) the If you wish to deny any of the statements set forth 1n Affidavit, you must file a Counter-Affidavit within twenty days after this Affidavit has been served upon you or statements will be admitted, PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(0) OF THE DIVORCE CODE 1. The parties to this action separated on August 26, 1992 and have continued to live separate and apart for a period of at least two years, 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if 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, Date: l' - /.6- t? (.# I ~~/ ~"~Il/r"-e~/ Janet L~ rhower , Plaintiff , , , , . , , ... : ' . .. .: .~ - " l~ /. k't" l.~ ~ 9: ,.... !T/:~. Ct: L. r. I., \..J '-, V"; ( :~ j , . '. ~ -- '. '-':j ,'] . J(" c,-, o. ) u <- "'" ~ -.. . , I~ THE COURT OF COMMON PLEAS OF CL~ERl..AND COUNTY, PENNSYLVANIA JANET L, DARHOWER, Plaintiff vs. MICHAEl. F.. nARI-fOWF.R. Defendant: NO. Qti_':IAQd 19 MOTION FOR APPOnl~T OF MASTER (Plaintiff) ~>><<~, following claims: Janet: L. narhowpr a master with respsct to the ( X ) Divorce ( ) !.nnulmsnt ( ) Alimony ( ) Alimony Pendente moves the court to appoint or fact, (X) ( ) ( ) ( ) Distribution of Property SuPPOrt Counsel Fees Costs and Expenses Lite 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 lClC~ (has not) appeared in the action; (personally) (by his attorney, howpver, Ronald E, Johnson, ESQuire is ~~X represenfiiM? (3) The staturory ground(s) for divorce ~ (are) Sections 3301(c) and/or 3301(d) of the Divorce Code. (4) Delete the inapplicable paragraph(s): (a) The action is not 'contested, (b) An agreement has been reached with respect to the fOllowing claims: None (c) The action is contested with respect :0 the following claims: Distribution of orooertv (5) The action ~M~ (does not involve) complex issues of law (6) The hearing is expected to take 2 (hours) XOcboltlrX, (7) Additional information, if any. relevant to the motion: Date: .} f }.S/7(, " /f1j ;1.~?Lf Attornev for (Plaintiff) Richard L, Webber, Jr, lC~~x~ ORDER AP!'OImL~G l1ASTER .-\NIl :101.' 1'1\.'-<, I, 1.( , ,19'1(, , , I -- r,~ 1-3.>, l -( I~- is appointed ~ster ~th respect to the following claims: ~I, '- . L I (/..---,- /1:squire, (l CLL.",....\ Bv the Court: ( "; h . ,//--. :Y ..,-- J , "' , \, , " 1 - : r~ .' ; , to. , . ,.., L \..:> l;J 'e:, , - , :." ''''q \~) ;;.- U' I ,j :".~i , -, ::1 . " .', (,J -. , ~ JANET L, DARHOWER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 95 - 3894 vs, MICHAEL E, DARHOWER, Defendant IN DIVORCE ORDER OF COURT AND NOW, this :; ( ,)I~' day of r-Jl 1996, the parties and counsel for Plaintiff having en into an agreement and stipulation resolving the economic issues on July 15, 1996, the date set for a conference with the Master, the agreement and stipulation having been transcribed and subsquently signed by the parties and counsel for the Plaintiff, the appointment of the Master is vacatedr and counsel can conclude the proceedings by the filing of a praecipe to transmit the record, based on Plaintiff's affidavit under section 3301(d) of the Domestic Relations Code averring a separation of at least two years, so that a final decree in divorce can be entered, H cc: Richard L, Webber, Jr. Attorney for Plaintiff Michael E, Darhower Pro Se - ~41F'-'''' "'~~((.( '7 J~I) 'if., , .J\. t', ... . ,,1' .-... r " :., .. \..J I...... '" ~I. ! ........ ' , , JANET L, DARHOWER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs, NO. 3894 civil 1995 MICHAEL E, DARHOWER, Defendant IN DIVORCE THE MASTER: Today is Monday, July 15, 1996, This is the date set for a conference in the Darhower case to determine if the parties can reach an accord with respect to the real estate and mobile horne, Following the last meeting on June 3, 1996, Mr. Webber had an appraisal done of the real estate and mobile home by Sailhamer Real Estate and Mr. Sailhamer filed a report indicating that in his opinion the property had a market value of $26r500,OO, Present today are the Plaintiff, Janet L, Darhower and her counsel Richard L, Webber, Jr, Also present is the Defendant, Michael E. Darhower who is representing himself, Mr, Webber filed today an affidavit under Section 3301(d) averring that the parties separated on August 26, 1992, and have been living apart for a period of at least two years, The divorce, therefore, will be concluded under the 3301(d) section of the code. The Master allowed counsel and the parties some time to discuss the appraisal to see if they could corne to some agreement with respect to the land and mobile home. Mr. Darhower had previously indicated that he wished to remain on ~ r - the property and the negotiations went forward in an effort to allow that to occur. The Mastar has been informed that the parties have reached an agreement which will provide for a full settlement of this case; however, there are certain contingencies in the agreement which if not met will require that the Master schedule a hearing and take testimony and make findings and recommendations with respect to the outstanding issues, Mr, Webber has advised that if certain requirements of the agreement are not met by Auqust 19, 1996, then the agreement will not be able to be completed as worked out today and the matter will be reevaluated and scheduled for hearing, Mr, Webber is going to place on the record the understanding of the parties today, The Master will not take any action to vacate his appointment until he has been advised either that the matter has been finally resolved and settlement achieved or in the alternative the contingencies have not been met that have been set out in the agreement and the parties need to have the case scheduled for hearing. Mr, Webber, MR. WEBBER: For the record, Richard L, Webber, Jr" for the Plaintiffr Janet L, Darhower -- the parties hereto agree as follows: 1, Defendant, Michael E, Darhower, shall pay to the Plaintiff, Janet L, Darhower, the sum of $12,250,00 no later than August 19, 1996, .. -- 2, Defendant shall pay the delinquent real estate and mobile home taxes as well as the 1996 county township and 1996 - 1997 school taxes, all of said delinquent and current taxes to be paid by August 19, 1996, 3, Upon Defendant's fulfillment of the above obligations, Plaintiff shall release her interest in the marital real estate and mobile home. Plaintiff shall cooperate in signing a quitclaim deed and any other documents of transfer. 4, Defendant releases any rights that he may have to the furniture and any other marital ussets that are in the possession of Plaintiff. 5, This agreement is contingent upon Defendant's fulfillment of his obligations as stated in Paragraph 1 and 2 above. If he does not do so, a hearing to resolve equitable distribution shall be scheduled by the Divorce Master, THE MASTER: Mr, Darhower, you've been present while Mr, Webber stated the agreement on the record? MR, DARHOWER: Yes. THE MASTER: And do you understand what he stated on the record? MR. DARHOWER: Yes, THE MASTER: Do you agree with what he has stated as the terms of settlement with respect to the issue of equitable distribution? MR, DARHOWER: Yes. THE MASTER: Do you have any questions? MR, DARHOWER: No, sir. MR. WEBBER: Ms, Darhower, were you present when I read the agreement? ,- MS, DARHOWER: Yes, I was. MR, WEBBER: And is that an accurate reflection of the terms that we have discussed with Mr, Darhower immediately prior thereto? MS, DARHOWER: Yes, MR, WEBBER: And is this, in fact, what you intend to be your agreement to resolve these various equitable distribution issues? I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by law and in particular section 3105 of the Domestic Relations Code, WITNESS: DATE: -/!:,t1........1 d__/'J R chard L, Webber, Jr, Attorney for Plaintiff '1/ - /{/- ~!/ , >' ~4/fj; t ,J2 ~~atu' Jan L. D rh'ower , ,1- RS.7'.c f{;.~~b~ M chael E, Darhower , .. ' . .., . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JANET L, DARHOWER, Plaintiff , , v. No, 95-3894 CIVIL ACTION - LAW , . MICHAEL E, DARHOWER, Defendant In Divorce AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on July 21, 1995, 2. The marriage of the Plaintiff and Defendant is irretrievably broken and more than ninety (90) days have elapsed from the date of the filing of the Complaint in Divorce, 3, I consent to the entry of a final decree in divorce, 4, 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, 5, I understand that the costs of these proceedings will be paid for by Plaintiff. . ., . , ,. 6, I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy ot the decree will be sent to me immediately after it is tiled with the Prothonotary, I verify that the statements made in this affidavit are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa. C, S, section 4904 relating to unsworn falsification to authorities. Date: IA //-$ -f'( .;/<<l (dJ/Aaru-! -J ne L, D' r er (~ ('I "". C". '. >- - ~-< u,r' - .,-;.# 0"" I ~.~~ u:~ ...,;..:. "\~ ~~. ..~ 0:' ....n .,..:: ,- I .:::../ ~\' -;- .1\'U u:" c. ~ r.: ~ - \', ~O 0 U cr, ... . , " . l ' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JANET L, DARHOWER, Plaintiff v. No, 95-3894 CIVIL ACTION - LAW MICHAEL E. DARHOWER, Defendant In Divorce ~~~~~~VIT OF CONSENT AND WAIVER OF NOTICE OF I ON TO REOUEST ENTRY OF A DIVORCE DECREE 1, A complaint in divorce under section 3301(C) of the Divorce Code was filed on July 21, 1995, 2. The marriage of the plaintiff and Defendant is irretrievably broken and more than ninety (90) days have elapsed from the date of the filing of the Complaint in Divorce, 3. I consent to the entry of a final decree in divorce, 4. 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, 5, I understand that the costs of these proceedings will be pajd for by Plaintiff. . t. . . . , If" " 6, I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary, I verify that the statements made in this affidavit are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa, C, S, section 4904 relating to unsworn falsification to authorities, ~/~G- /J ' Date: 1/.... ~~ ?,6 . W'~ v ~ ~~~~~ M chael ,Darhower . ,.. '.. , . " Co v:> ,.., r-< (;... 'I, .. ;.~ cJ ""'G ::~ .i;TI Q.:i_ <1> .' I .,~ Vi r.o .\ - :~ r:: ~~ "-\1 :!.:' j:" , , - .)~ /, .. ., ~" ,. ,,, ~ ::.... a; r:; ~1i~ ~$i! c it -!-j? r.:.; II. o . . i ,4 " " I.D - ~ c. .. (" >.:0 -I..... '-~ -" :... ~- .~'52 :';;,1 '.. ....- '1',:::': [,.'1,:: -" ::.J (J ,,- (l: <::> C\,/ n. 4, Cr. <0 0, , , c 1 rryfJs If c~ t- ," .'" \,; JANET L, DARHOWER, PLAINTIFF/PETITIONER v, I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I I NO, 95-3894 CIVIL TERM I I I IN DIVORCE MICHAEL E, DARHOWER, DEFENDANT/RESPONDENT AND NOW, this ORDER OF COURT ~ 2, '7) ILL day of (pi J .',,? _ ~ L- T[ VV'lh c/c 1996 upon consideration of the attached Petition, it is ORDERED that the Divorce Master schedule a hearing for the purposes of resolving the equi table distribution claim raised by Plaintiff, Janet L, Darhower, BJ7;:TX~ J~ I t...-- fJ. Michael E.Darhower, Defendant E, Robert Elicker, II, Divorce Master I:....,.;hl " .:.i Richard L, Webber, Jr" Attorney for Plaintiff , l:\lI.~ fl"W....L'<L ~/.:J'fl% Af ',' " :~': '1,; '-'" . ~ . - .. -' '~;':.';':J ~ .~ l '-. . .~. , .,_..1, ~ ','." -" ..., ,'~ ;:',j :::~O-{J~l::1 JANET L, DARHOWER, PLAINTIFF/PETITIONER I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I I NO. 95-3894 CIVIL TERM v, MICHAEL E. DARHOWER, DEFENDANT/RESPONDENT I I IN DIVORCE PETITION TO SCHEDULE DIVORCE MASTER HEARING AND NOW comes the plaintiff/Petitioner, Janet L, Darhower, by her Counsel, Richard L, Webber, Jr" and petitions your Honorable Court to schedule a Divorce Master hearing, averring the followlng: 1, plaintiff/Petitioner is Janet L, Darhower, of 184 B Big Spring Terrace, Newville, PA 17241, 2. Defendant/Respondent is l4ichael E. Darhower, of 601 Burgners Road, Carlisle, PA 17013. 3, On or about August 24, 1995, Plaintiff/Petitioner filed a Complaint in Divorce, 4, On or about March 19, 1996, Plaintiff/Petitioner HIed a Motion for Appointment of Divorce Master 5. A conference with the Divorce Master was attended by the undersigned counsel and Defendant/Respondent (pro se) on June 3, 1996, 6, A second conference was held by the Divorce Master on July 15, 1996, which both parties attended along with plaintiff/Petitioner's counsel, 7. At the second conference, the parties entered a Stipulation, a copy of which is attached heretor labeled as Exhibit "A" and incorporated by reference herein. 8, The Stipulation, among other terms, states as follows: "1. Defendant, Michael E, Darhower, shall pay to the Plaintiff, Janet L, Darhower, the sum of $12,250.00 no later than August 19, 1996. 2, Defendant shall pay the delinquent real estate and mobile home taxes as well as the 1996 county and township and 1996- 1997 school taxes, all of said delinquent and current taxes to be paid by August 19, 1996," 9. Paragraph 5 of the Stipulation states as follows: "5, This agreement is contingent upon Defendant's fulfillment of his obligations as stated in Paragraph 1 and 2 above, If he does not do so, a hearing to resolve equitable distribution shall be scheduled by the Divorce Master," 10. To date, Defendant has not fulfilled the obligations as set forth in Paragraphs 1 and 2, 11. On August 7, 1996, Plaintiff/Petitioner's counsel, Richard L. Webber, Jr" telephoned Defendant/Respondent to inquire as to the status of his financing efforts and to otherwise 1etermine whether Defendant/Respondent intended to fulfill his obligations, Plaintiff's counsel left a message on Defendant/Respondent's answering machine. 12, Defendant/Respondent did not respond to said message, 15. During the telephone conversation, Defendant/Respondent refused to indicate whether he was ready, able and willing to settle. He indicated that he felt that he was being harassed and hung up the telephone, 13. On August 19, 1996, Plaintiff's counsel again telephoned Defendant/Respondent and left a message on his answering machine, Defendant/Respondent did not respond to said message, 14, On August 23, 1996, Plaintiff's counsel contacted Defendant/Respondent for a third time, 16, There has been further response from no Defendant/Respondent, 17. The contingency as stated in paragraph 5 of the Stipulation has not been met, WHEREFORE, Plaintiff/Petitioner respectfully requests that a hearing before the Divorce Master be scheduled, Respectfully submitted, Date: f((I)~t <VU! r7 ,~~1 Richard L. WebbertJr. Attorney for Plaintiff/Petitioner 366 Green Spring Road P.O. Box 40 Newville, PA 17241 (717) 776-6566 I verify that the statements made in this Petition are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa.C.S,A. Section 4904 relating to unsworn falsification to authorities. Date: Cf(lj~t &utlhumu mful iElItUtf 494 EAST KING STREET SHIPPENSBURG, PA 17257 532.80511 MR RT"ua.Rn T. WFRnFR. .1R ROM ~AJ~V~M~D (aDnu~D.Ow~VO) ,"T V 1 CO':;' FOR PROFESSIONAL SERVICES RENDERED ON AN APPRAISAL FOR MICHAEL AND JANET DARHOWER, AMOUNT DUE $ 75.00 , I RICHARD L, WEBBER, JR. Anorney at Law 366 Green Spring Road P.O, Box. 40 Newville.PA 17241-0040 Telephone (717) 776.6566 FAX (7\7) 776.6086 April 12, 1996 Robert E. Elicker, II, Divorce Master 9 North Hanover Street Carlisle, PA 17013 RE: Darhower v, Darhower No. 95-3894 Civil In Divorce Dear Mr. Elicker: I have enclosed a Pretrial Statement filed on behalf of my client, Janet Darhower, the Plaintiff. By copy of this correspondence, I have served opposing counsel, Ronald E, Johnson, Esquire, with a copy of the Pretrial Statement. Sincerely, NA'v:.~ Richard L. Webber, Jr. RLW,JR/tw Enclosure cc: Ronald E. Johnson, Esquire lDlPARABLB SALES USED IN nas ESTIMATION OF FAIR MARKET VALUB Subjeot PropertYI 601 Burgner. Road, Carli.le, Pennsylvania ADDRESS DAm OF BALE SBl.I,1 NG PRI CIS 7 1f;yri ok Avenue 06/03/96 Shippensburg, PA 126,000.00 20' North Penn Street Shippensburg, PA 12/0B/95 ~28,OOO.00 1128 Mainavil1e Road 06/30/95 Shippenaburg, PA 116,000.00 v, I IN THB COURT OF COMMON PLBAS OF I CUMBERLAND COUNTY, PBNNSYLVANIA I I NO. 95-3894 CIVIL TERM I I I IN DIVORCE ": ,-, ? ': 1Qq6~ JANBT L, DARHOWER, PLAINTIFF/PETITIONER MICHAEL E, DARHOWER, DBFENDANT/RESPONDENT ORDER OF COURT AND NOW, this ~~.JW:t day of ~F,.,k.v 1996 upon consideration of the attached Petition, it is ORDERED that the Divorce Master schedule a hearing for the purposes of resolving the equitable distribution claim raised by Plaintiff r Janet L, Darhower. BY THE COUR'l': 1.51 ""'J.h u-I!d.... l.', --JI~.tL (J J, Michael E.Darhower, Defendant E. Robert Elicker, II, Divorce Master Richard L, Webber, Jr., Attorney for Plaintiff JANET L. DARIIOWER, Plaintiff IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs, CIVIL ACTION - LAW NO, CIVIL 19 MICHAEL E, DARHOWER, Defendant IN DIVORCE ORDER AND NOTICE SETTING HEARING To: Janet L, Darhower Richard L, Webber, Jr, Michael E. Darhower , Plain tiff , Counsel for Plaintiff , Defendant , Counsel for Defendant You are directed to appear for a hearing to take testimony on the outstanding issues in the above captioned divorce proceedings at the Office of the Divorce Master, 9 North Hanover Street Carlisle, Pennsylvania, on the Rth day of November ,1996, at 9:00 a.m, at which place and time you will be given the opportunity to present witnesses and exhibits in support of your case. By the Court, ~a~ 0 J \= , Harold E, Sheely, presi n Judge Date of Order and Notice: 9/25/96 By: Divorce Master IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Court Administrator Fourth Floor, East Wing Cumberland County Courthouse Carlisle, PA 17013 Telephone (717) 240-6200 RICHARD L. WEBBER, JRo Allomcy at Law 366 Grecn Spring Road P,O, Box 40 Ncwvlllc, PA 17241-0040 Tclcphonc (717) 776-6SG6 FAX (717)776-6086 September 20, 1996 E, Robert Elicker, II, Divorce Master 9 North lIanover Street Carlisle, PA 17013 RE: Darhower v, Darhower Dear Mr, Elicker: I have enclosed a copy of a proposed Order of Court and Petition to Schedule Divorce Master Hearing. I filed the original today in the Office of the Cumberland County Prothonotary, Sincerely, ~ /!'h-./;tL( Richard L, Webber, Jr, RLW,JR/jdl cc: Mr. Michael Darhower JANET L, DARHOWER, PLAINTIFF/PETITIONER I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA : v, I NO, 95-3894 I I I IN DIVORCE CIVIL 'l'ERM MICHAEL E, DARHOWER, DEFENDANT/RESPONDENT ORDER OF COURT AND NOW, this day of 1996 upon consideration of the attached Petition, it is ORDERED that the Divorce Master schedule a hearing for the purposes of resol ving the equitable distribution claim raised by Plaintif f, Janet r., Darhower, BY THE COURT: J. Michael E.Darhower, Defendant E, Robert Elicker, II, Divorce Master Richard L, Webber, Jr" Attorney for Plaintiff JANET L. DARHOWER, PLAINTIFF/PETITIONER I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNT~, PENNS~LVANIA I I NO. 95-3994 CIVIL TERM I I I IN DIVORCE v. MICHAEL E. DARHOWER, DEFENDANT/RESPONDENT PETITION TO SCHEDULE DIVORCE MASTER HEARING AND NOW comes the Plaintiff/Petitioner, Janet L, LJarhower, by her Counsel, Richard L, Webber, Jr" and petitions your Honorable Court to schedule a Divorce l'laster hearing, averring the following: 1, Plaintiff/Petitioner is Janet L, Darhower, of 184 B Big Spring Terrace, Newville, PA 17241, 2. Defendant/Respondent is IHchael E. Darhower, of. 601 Burgners Road. Carlisle, PA 17013, 3. On or about August 24. 1995, Plaintiff/Petitioner filed a Complaint in Divorce, 4, On or about March 19,1996, Plaintiff/Petitioner filed a Motion for Appointment of. Divorce Master 5. A conference with the Divorce Master was attended by the undersigned counsel and Defendant/Respondent (pro se) on June 3, 1996. 6, A second conference was held by the Divorce Master on July 15, 1996, which both parties attended along with Plaintiff/Petitioner's counsel, 7. At the second conference, the parties entered a Stipulation, a copy of which is attached hereto, labeled as Exhibit "A" and incorporated by reference herein, 8, The Stipulation, among other terms, states as follows: "1, Defendant, Michael E, Darhower, shall pay to the Plaintiff, Janet L, Darhower, the sum of $12,250,00 no later than August 19, 1996, 2, Defendant shall pay the delinquent real estate and mobile home taxes as well as the 1996 county and township and 1996- 1997 school taxes, all of said delinquent and current taxes to be paid by August 19, 1996," 9. Paragraph 5 of the stipulation states as follows: "5, '1'his agreement is contingent upon Defendant's fulfillment of his obligations as stated in Paragraph 1 and 2 above, If he does not do so, a hearing to resolve equitable distribution shall be scheduled by the Divorce Master," 10, To date, Defendant has not fulfilled the obligations as set forth in Paragraphs 1 and 2, 11. On August 7, 1996, Plaintiff/Petitioner'R counsel, Richard L. Webber, Jr" telephoned Defendant/Respondent to inquire as to the status of his financing efforts and to otherwise determine whether Defendant/Respondent intended to fulfill his obligations, Plaintiff's counsel left a message on Defendant/Respondent's answering machine. 12. Defendant/Respondent did not respond to said message. 13, On August 19, 1996, Plaintiff's counsel again telephoned Defendant/Respondent and left a message on his answering machine. Defendant/Respondent did not respond to said message. 14, On August 23, 1996, Plaintiff's cOllnsel contacted Defendant/Respondent for a third time. 15, During the telephone conversation, Defendant/Respondent refused to indicate whethel" he was ready, able and willing to settle. He indicated that he felt that he was being harassed and hung up the telephone. I 1 J I 16. There been from further has response no Defendant/Respondent. 17, The contingency as stated in paragraph 5 of the Stipulation has not been met, WHEREFORE, Plaintiff/Petitioner respectfully requests that a hearing before the Divorce Master be scheduled, Respectfully submitted, Date: q (I ,}(~" .?1:J /I-~~ Richard L. Webber, r, Attorney for Plaintiff/Petitioner 366 Green Spring Road P.O. Box 40 Newville, PA 17241 (717) 776-6566 I verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C,S,1\. Section 4904 relating to unsworn falsification to authorities. Date: ,'If ./..: ,." .. . , 1~ ~. 'f-If.. -"N. ?e '~_.... ......,.....,....; ~* -:J.~~'" ,~.~. -". ~ . -. ~ ,.,.. '"' '. . . "'--' ." -~..~ -' '\.:;. ~.#" .- ""---- - '. JANET L. DARHOWER, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO, 95-3894 CIVIL TERM V. MICHAEL E, DARHOWER, DEFENDANT IN DIVORCE PLAINTIFF'S PRETRIAL STATEMENT PURSUANT TO Pa.R,C,P. 1920.33(b) 1. IiI Marital Assets .1J&J!! Value/Date of valuation Portion nonmarital Encumbrance A. Real estate, together with mobile home thereon, located at 601 Burgners Road, Carlisle, Lower Frankford Township, Cumberland County, Pennsylvania, more fully described in Cumberland County Deed Book "X", Volume 32, at Page 449, Fair Market Value unknown, County assessment value $ 1,970.00. None 1993-95 Real Estate and Mobile Home Taxes 1. Iii). Nonmarital assets NONE. 2. Exnert witnesses None at this time. To be supplemented, 3. Other witnesses None at this time. To be supplemented. 4. Exhibits A. Deed B. 1995 Federal Income tax return C, 1995 State Income tax return ,. 5. Income Plaintiff is employed at Kinney Shoe (Bedford Plant), She earns $ 7.50 per hour and works 36 hours per week. 6. Expenses Not applicable. 7. Pension or retirement benefit Not applicable, 8. Counsel fees Not applicable. 9. Personal property Not applicable, 10. Marital debts 1993-95 County/township and School taxes totalling $ 656.20, 11. Proposed resolution Plaintiff proposes that the real estate and mobile home be sold and the proceeds divided equally. She further proposes that Defendant be responsible for all real estate and mobile home taxes through the date of the sale since he had possession of the real estate from the date of separation. Respectfully submitted, ,/[/-4'-1-->-;/1 / Richard L. Webber~r" Esquire Attorney for Plaintiff 366 Green Spring Road P,O, Box 40 Newville, PA 17241-0040 Phone (717) 776-6566 I verify that the statements made in this Pretrial Statement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: 111'.1 'f)/1~~ <~~r/ (,~<< k//J'PI ) ANET L ( DARHO J:':R /Plaintiff .. . \. , \ .,...-- -. - ,..... ..,.... "",,, ...... .... ,........ 'I. ! tlCb i~ 1!letll, MADE THE 3rd dOli 0' September .,.., Lord OIl' IA."...." .1., h.d"" eighty-.even (19871. IN IAt II"'" I I I BETWEEN JIMMIII C. aBORGII and ROSALIB D. aBORGII, hu.band and wite, of the Borough of C.rli.le, Cumberland County, P.nn.ylvania, partie. of the fir.t part, ..d a... lor a, MICBABL B. DARRONIIR and JAKIIT L. DARRONIIR, huaband and wife, of Lower Frankford Township, Cumberlsnd County, Pennsylvenia, parties of the aecond part, a...,,,s : WITNESSETH, IAAI i. ,...ld,..llo..' TWo Thousand and no/lOO--------------- ----------------------- ($2,000.00) ------------______________ Dollar., i. ""lid paid, ''', ",<(pIIC"""" u ",,,1111 .,lcHoll'"dg,d, Ih, 'Rid gm.'nr S do h",bU g..'" ..d '0."'/110 ''', .ald gro.,..s, their heirs and assigns, as tenants by the entirety, ALL that certain tract of Township, Cumberland County, bouhded and described as follows, land situate in Lower Frankford Pennsylvania, more particularly to-wit I BEGINNING at a railroad spike in the center of Township Road No. 457 at corner of lands now or formerly of John B. Wright; thence along Township Road No. 457, North 89 degrees 36 minutes 50 seconds East 209.58 feet to a railroad spike near the North edge of road; thence through lands now or formerly of Oscar Barrick, Sr., South 07 degrees 00 minutes 00 seconds West 209.58 feet to an iron pin at corner of lands now or formerly of Oscar Barrick, Sr.; thence through same, South 89 degrees 36 minutes 50 seconds West 209.58 feet to an iron pin on line of lands now or formerly of John B. Wright;. thence along line of lands now or formerly of John B. Wright, North 07 degrees 00 minutes 00 seconds East 209.58 feet to a railroad spike at the Place of BEGINNING. CONTAINING 1.000 acres. The foregoing description taken from survey map entitled "PINAL PLAN, OSCAR BARRICK SR." drawn by Price and Associates, Inc., which said map is recorded in the Office of the Cumberland County Recorder of Deeds in Deed Book "N", Volume 27, Page 365, etc. SUBJECT, HOWEVER, to the following building and use restric- tions and conditions with which the Grantees, for themselves, their heirs and assigns, agree to comply by the acceptance of this deedl 1. Said lot shall be used for residential purposes only. 2. No unlicenaed motor vehicle a or accumulation of trash, rubbish or junk shall be stored or permitted on aaid lot. BEING all of the property which Oscar R. Berrick, Sr., and Marie P. BarriCk, husband and wife, by deed dated October 18, 1977, and recorded November 16, 1977, in the Office of the Recorder of Deeda in and for Cumberland county at Carli.le, Pennsylvania, in Deed Book "N", Volume 27, Page 365, granted and conveyed to Jimmie C. George, who ia joined by hia wife, Roaalie B. George, aa the Grantora herein. e~i~ 32'leE 449 ..--..- - . . .. ....... ................... I \.- '......... ._J ., ~ . ......... 1!..~'" . ({2.,r:~~'~:,~' OSJP J~rJ ~c x~oo~ r ). ,~ "a .,,,.& 11I1 'IlJ.lIlllllV I1lIWllIIIIOlnlJlI'lOO "Jl . ~ .......... ....................y..'WlnClOQNY1lIJIRII:I'I'l..'IlIYOlln.IWAlIY.lllII ~'..,. ,. . .\;.,~..;..:;./........i::N.:e;....~o/ ".;.~................. .. . / .,." f'IIoIJ6a ,n ,IlDV A... '" o;..,..~ I '.iO:JN:JHM SS:JN.&IM NI '''.'0'.'' .,,,,,~, .....,.." ,,, .., ...... ,~, ,.'OU... b'A ,WIt, '.11,.'....."'. ,... .,..........,..., .,V"" ,~, II "~"IN' u. . ...... 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Figure your adjusted gross Income AttKh Copy B o' your Form. W.2 _I_A...... " ~ didn't oet . W.2. _ page 27. EncIoH. but do not att.lCh. any payment - - == ~ == U1 ....- )> ::::: ~= = -= = = -= ~ IRS U.. Only-Do nol wnt. or Itaple tn thIS apKe. OMS No. 1 54~.008~ Your IOdlllecunty number ~!..(Jl}.!!./~:!- [)epM1menl ollhll Tf..turY~nlemll Revenue ServiCe U,S, Individual Income Tax Return lHl 1995 ~~...,. L- It . pone ,.IUfn, IPQU.... tllll namtI and It'Ilt~ UI,I name h ~t. "w<t'" LMl ..... ....... For Privacy Act and Plperworil RBductlon Act Notice, ... page 11, Notl: Checking oYes. WIll nol change your lex or reduce ur refund. 1+ ode. Presidential Elactlon Campaign Fund (See pagl 19.) Do you want $3 to go to this fund? . . . . . . . . If a oint return, does our s use want $3 to 0 to this fund? 1 'IiCI Single 2 tJ Married filing joint return (evan If only one had Income) 3 0 Married filing separate return, Enter spouse's social security number above and full name here, ~ 4 0 Head of household (with qualifying person). (See page 21.) If the qualifying person Is a child but not your dependent, enter this child's name here. ~ 5 0 Quail Ing wldow(er) with dependent child ( ear spouse died ~ 19 6a Youne". II your parent (or someone "se) con c1l11m you II . dependent on nis or I1ar tax retum. do nol cneck box 6a. But be sure to cneck the box on Ii.. 18b on page 2. Ve. No b 0 UH C Dependenls: ). (See a e 22.) } No. of boa.. _on 1 Ie encI.. _ No. 01 row . _on ea_ . _ with rou (2) Dependenl's social socurt1y number. If born In lQQ5, _ page 25. (31 Dependenl'. rolatJonshlp to you (41 No. ot monlhs lived In your nom. In IQQ5 \:.... 'of ':.",. b Souse's IRA deduction see a e 3 15b c Add lines 15a and 15b. Thesa are our total ad ustment8. 16 Subtract line 15c from line 14. This Is your adjusted gross Income, II less than $26,673 and a child lived with you (lass than $9,230 II a child didn't live with ou), see oEarned Income credit" on pa a 47. ~ 16 (11 Fltst name l.aa1name d If your child didn't live with you but Is claimed as your dapendent under a pre-1985 agreement, check hera . , , . . . . ~ 0 e Total number of exem tlons claimed. 7 Wages, salaries, tips, etc. This should be shown In box 1 of your W-2 form s . Attach Form s W-2. Sa Taxable Interest Income (see page 28). If over $400, attach Schedule 1. b Tex-e.em t Inl8lest. DO NOT Include online 80. 9 Dividends. II over $400, allach Schedule 1. 10a Total IRA distributions. 11a Total pensions' and annuities. 11 a 12 Unem 10 ment com ensatlon see a e 32. 138 Social security benefils. 8b - 10b lOa - - 11b 13a -' 13b 14 168 our total Income. 15a -- '-" CoL No. I '32M ._~1Ivo with you d\Io 10_... J P ,don __211 D 11:11 MMnta on Ie not __e_ Add....bofs D _on __" 7 II 8a - 9 -- 10b ---- .....- 11b 12 0 13b ..- ~ 14 lP59 lie 15c w-- 1'-1 (,59 I~ lUl16 F~ flMOA pallO 1 18aO 1995 Form 1040A page 2 17 Enter the amount from line 16. Figure your standard deduction, exemption amount, and taxable Income Figure your tax, credits, and payments It you want the IRS 10 figure your tax. see the Instructions lor line 22 on pag.41. Figure your refund or amount you owe - === === - ~ Z ~= >= ~= = - = = -= = 17 Ii 1o~'1 ~ 18a Check {O You were 65 or older 0 Blind } Enter number 01 if: 0 Spou.e was 65 or older 0 Blind boxe. checked ~ b If your parent (or someone else) can claim you as a dependent, check here. . . . . . . . . . . . . . . . . . ~ 18b c If you are married filing separately and your spouse itemizes deductions, see page 40 and check here.. . . . . . . ~ 18c 19 Enter the standard deduction shown below lor your filing status. But If you checked any box on line 18a or b. ilo to page 40 to lind your standard deduction. II you checked box 18c, enter -0-. . Slngle-$3,900 . Married filing jointly or Qualifying widow(er)-$6,550 . Head 01 household-$5,750 . Married lIilng separately-$3,275 19 Subtract line 19 lrom line 17. If line 19 Is more than IIns 17, enter -0-. 20 Multi I $2500 b the total number 01 exem tlons claimed on line 6e. 21 Subtrect line 21 lrom line 20. II line 21 Is more than line 20, enter -0-. This Is our taxable Income. ~ 22 23 FI the tax on the amount on line 22. Check If from: Tax Table a es 65-70 or 0 Form 8615 see a e 42. 24a Credit for child and dependent care expenses. Attach Schedule 2. b Credit for the elderiy or the disabled. Attach Schedule 3. 24b c Add lines 24a and 24b. These are our total credits, 25 Subtract line 24c lrom line 23. II line 24c Is more than line 23, enter -0-. 26 Advance earned Income credit a menis lrom Form W-2. - 27 Household em 10 ment taxes. Attach Schedule H. 28 Add lines 25, 26, and 27. This Is your totall:ix. 298 Total Federal income tax withheld. If any Is lrom Form s 1099, check here. ~ 0 b 1995 estimated tax payments and amount 8 lied from 1994 return. o Eamed Income credit. Attach . Schedule Elc II ou have a uall Nontaxable earned income: amount ~ I and type ~ d Add lines 29a, 29b, and 29c (don't Include nontaxable earned Income). These are our total a ments. ~ 29d 30 If line 29d Is more than line 28, subtract line 28 lrom line 29d. This Is the' amount ou ove ald. Amount 01 line 30 ou want refunded to ou. Amount 01 line 30 you want applied to your 1996 estimated tax. 32 33 II line 28 Is more than line 29d, subtrect line 29d from line 28. This Is the amount you owe, For details on how to pay, Including what to write on your payment, see page 55. M Estlmatecj tax penalty (see page 55). Also, Include on line 33. 34 51 Under penaItieI of p8f1UfY. I dec'-t, lhII I hlft examined this retum and eccompanVVlClSChedules and ItIttrnlnll, and to IhI gn your bIIt at my knowledge and betiel. they .,.lNe, comet, and accurallty lisl an amounts and sources 01 inClOIM I t'lCeNMI dUMg return tho IU yoar.llocl&rallonolproparorColhotlhlntho _yorlllbuod on all Inlonna',," 01 wtloch tho _ha any_. ~ Your $lQnlturl 01;'1 & Y occupahon , _;).-7 rt.... ~ Spou.... ttgnAtUte, It JOInt ,.Ium, BOTH mUSISlgn. Oil' o o 20 21 22 23 24a - - 24c 25 26 27 ~ 28 - 00 - 29a D f ?-5 29b - 29c 31 32 30 31 33 Keep . copy of this retum for your records. Paid pre parer's use only Spouse', OCCuPll1On _or'a .. liQr\ltU" , Finn'. n.me IOf yourw ~ " M1'.emplQyedland addt"s 011. Chock " 0 ...- [IN ,,-"<'a SSN lift ('1')(1" 1995 F_104OA page 2 :J:iOl ....1-\-&+\lI:.L. lI~wV'V'1;, .""'^ nL.' un... ,. ... YOU MUST FILE BY MIDNIGHT MONDAY. APRIL 1&'18116'" .:..J ....1 Commonweallh 01 Ponn.ylvan,a PA Department 01 Aevenue .......b $ $ Bd Tu Fo.;lVtn...'.om PA Schldule SP. Pan III............................................................................. Bd $ $ 10 TAX DUE. II LIn' 5 il mar, than Llnl 9. Inl" Ihl dln.r.nc...." ..............................."........... 10 $ $ ................................121 $ 12b Amount of Une U you Wlnl Cnd/fld 10 your 10M PI""sylvania Eatknaled TII Account........... ,2b $ 12c Amount 01 Lint" you .1"110 Don." 10 thl Wild RllOurCl Con..NaltOn Fund........................ t2c $ t2d Amount 01 UM " you wlnt 10 Oonall 10 thl US OlympiC Commltt... Plnnlytvania ~"...2d $ The TOTAL or L1n.. '2.. 'lb. 12c AND 12d MUST Equal Llnl 11. ". ,"" 'OUR _.fU." U........... at .....,. II........ ...-1IW1.....lkllll..jIlM....... ...."1............ n~'''' "III..'...... .1II....,... "IN "It II., 1'''1 WIt. I" hi. unlet ""' ....... ~ur S'gnalur. Dati Your Occupthon MAKE CORRECTIONS BELOW YoYf SociI! hewII1, Number []ill] liB I:WIillI ,..... f..I....II~1 '- I ."r"'I,-<,. ,"~r '- IIMC....."... I NloIlnbefl iIrImiIiIr'''~ tpoy..,. HIIM ...... .. AtJA.Ho. ,. GtOIl PA ComplnNUon trom Formt(l) W.2. ,on. and othar .tattmtnll..................................... ,. lb Unltlmbu,lId Employe Bull"'" Elpen.a. horn PA Schedule UE_. 1c NeI PA Taubll Compennlion. 6ubUact Lln. 1b horn L1n. 11..................................................... 1c 2 PA Ta..ble Inl"e.1 AlIleh PA Sch.dull A il over 11.000.. . .......................................2 3 PA T....... Dividend. AlllCh PA ScIIIdule B " ...' 11.000........................................................ 3 ~ Tol,l PA Tluble Income. Add LIRI. 1c. 2 .nd 3. . . ..............................,............4 S "" TAX LIASIUn Mu"ply Ltn. 4 by 2B~ IGD2B).................................................................... 5 6 Tolll PA Incom. Tu.. WIlhheld from ForlTlC') W.2 . ......B 7 1011I ElIlmalld Paymlnta and Oldl'" SH InllluC:bOnl ............................................................... 7 ea HouHhold Mlmblfllrom PA SChIdull SP. Part II...................................................... rn 81:1 EhQlblllly Income flam PA Schedule SP. PI" III. Be TOllllncome 'rom Slep $, Line 21. SP WofklhHI........-..... ........",.,............................................ Be B TOIII CIodIIl end PoymInlo. Md U... B, 7 end Bd................................................................... ; II OVERPAYMENT. II Una ; I. mora ....n Una B, ..... .... dilfor.nce ............................................ II 121 Amounl at LIRe n you wlnl II a R,fund Check milled 10 you.... Spou'''' StOnllu,e IE SUIlE YOU tAND YOUIl SPOUSEI SIGN CHECK All MATH ATTACH ALL SCHEDULES AND fORM I rep.,,,'e Name: T"'PE nllR ICt\e<.... ()f\I, On., s ,\ M J F .-, ,- .MIIl. 11II' ..... N...utl ..t.. "IV" S! BUR! TO COIIPLET! TNII &BCTIOH NAME OF ttiE. SCHOOl DIStRICT _hII. 'fCN II,," o.t.mDI' n 1M5 SCHOOL DISTAlCT COOl )1c.5l> H_ CHECK IF 'tOU !hIlL NOT 'IUDA'. PA TAX RETURN ...Ib $ If..., 5'l'{; o 0 , , " $ t- O 0 , , " $ 1<.." 5fC o 0 , , " $ 0 o 0 , , " $ (\ " o 0 , , $ I;" 5 yo" o 0 , , $ '14' o 0 , , ., , " $ ., :;[ 00 , , , ~, " $ (\ o 0 . , . () , 00 o 0 00 ;:)7' " 0 0 o 00 . o 0 00 o 0 o 0 o 0 " , (l L' " , , . , , , , , , " , , " , , . , , " Oil' spou.... OccupllIon Oa"'hme Tol,phOne Numbef par" I IlephOne ber ANDREWS & JOHNSON Attorneys at Law 78 West Pomfret Street Carlisle, PA 17013-3216 TAYLOR P. ANDREWS RONALD E. JOHNSON Telephone (717) 243-0123 Telefax (717) 243-0061 April 22, 1996 E. Robert Elicker II, Divorce Master Office of Divorce Master 9 North Hanover Street Carlisle. PA 17013 RE: Darhower Divorce Action Dear Mr. Elicker: In accordance with your request, I am writing to advise that I have not been retained by Mr. Darhower to represent him in captioned divorce action for which a master's hearing has been requested. My prior involvement on behalf of Mr. Darhower was simply to write a letter on his behalf. I am not his attorney of record nor have I ever entered an appearance for him. Should you have any questions. please feel free to contact me. Very truly yours, REJ:blb cc: Michael Darhower JANET L. DARIIOWER, Plaintiff IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVI L ACTION - I.AW VS, MICHAEL E. DARHOWER, Defendant NO. 3894 19 95 CIVIL . . IN DIVORCE STATUS SHEET DATE: ACTIVITIES: 3/26/96 c-:u-.' C:~~" Confer / . ) . ".r:-J' .,,"' /~ . t--.j1 ~k,1 '_j t. (,.....- I .......t, ~ '\ -c.d (/ ~ (e;, 0...- . <'t{ iP., />- o-ff4....uI ~"'.J 'f1.L~~o...-:C~..J'-lC (. .~ '~ft..~. -. '* OFFICE OF DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEAS 9 North Hanover Street Carlisle, PA 17013 (717) 240-6535 E. Robert Elicker, II Divorce Masler Tr.cl .10 Col~er Ofllce Manager/Reporter Richard L. Webber, Jr., 366 Green Spring Road P.O. Box 40 Newville, PA 17241-0040 West Shore 697-0371 Ex!. 6535 March 26, 1996 Esquire Ronald E. Johnson, Esquire ANDREWS & JOHNSON 78 West Pomfret Street Carlisle, PA 17013 RE: Janet L. Darhower vs. Michael E. Darhower No. 95 - 3894 In Divorce Dear Mr. Webber and Mr. Johnson: By order of Court of President Judge Harold E. Sheely dated March 20, 1995, the full-time Master has been appointed in the above referenced divorce proceedings. A divorce complaint was filed on July 21, 1995, raising grounds for divorce of irretrievable breakdown of the marriage and the economic claim of equitable distribution. The complaint does aver that the parties separated on or about August 26, 1992; however, no affidavit under Section 3301(d) has been filed. The motion for appointment of Master indicates that although Mr. Johnson has not entered his appearance on behalf of Mr. Darhower, that he has been acting as his legal representative. Therefore, unless Mr. Johnson advises otherwise, I will proceed on the basis that he is representing the Defendant. I do request that Mr. Johnson enter his appearance if he is going to continue with his representation of Mr. Darhower. I also assume that there is no issue with respect to grounds for divorce although the pleadings do not indicate whether or not Mr. Darhower agrees with the alleged date of separation being August 26, 1992. Based on my assumption that grounds for divorce are not at issue and that Mr. Johnson is going to be entering his appearance and representing Mr. '. . Mr. Webber and Mr. Johnson, Attorneys at Law 26 March 1996 Page 2 Darhower, 1 am directing each counsel to file a pre-trial statement in accordance with P.R.c.P. 1920.33(b) on or before Monday, April 15, 1996. Upon receipt of the pre-trial statements 1 will immediatelY schedule a pre-hearing conference with counsel to discusS the issues and, if necessary, schedule a hearing. - Very truly yours, E. Robert Elicker, 11 Divorce Master NOTE: sanctions for failure to file the pre-trial statements are set forth in subdivsion (c) and (d) of Rule 1920.33. THE ORIGINAL PRE-TRIAL STATEMENT SHOULD BE FILED IN THE MASTER'S OFFICE AND A COpy SENT DIRECTLY TO OPPOSING COUNSEL. JANET L. DARHOWER, Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 95 - 3894 MICHAEL E. DARHOWER, Defendant IN DIVORCE NOTICE OF PRE-HEARING CONFERENCE TO: Richard L. Webber, Jr. Michael E. Darhower Counsel for Plaintiff , Defendant A pre-hearing conference has been scheduled at the Office of the Divorce Master, 9 North Hanover street, carlisle, Pennsylvania, on the 3rd day of June, 1996, at 9:30 a.m., at which time we will review the pre-trial statements previously filed by counsel, define issues, identify witnesses, explore the possibility of settlement and, if necessary, schedule a hearing. Very truly yours, Date of Notice: 4/22/96 E. Robert Elicker, II Divorce Master Richard J. Webber, Jr., Attorney for Plaintiff, filed a pre-trial statement on April 16, 1996. Michael E. Darhower, Defendant, has not filed a pre-trial statement as of the date of this notice, CC: Ronald E. Johnson. Esquire JANET L. DARHOWER, Plaintiff . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 95 - 3894 IN DIVORCE . . VS. . . . . MICHAEL E. DARHOWER, Defendant CONFERENCE WITH COUNSEL AND PARTIES TO: Janet L. Darhower Richard L. Webber, Jr. Michael E. Darhower , Plaintiff , Counsel for Plaintiff , Defendant A conference has been scheduled at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 15th day of July, 1996, at 9:00 a.m., with counsel and the parties to discuss the outstanding economic issues to determine if there is a basis of settlement of claims. If issues remain after the conference a hearing will be scheduled at another date. Very truly yours, Date of Notice: 6/3/96 [lfk-fL~~ E. Robert Elicker, II Divorce Master JANET L. DARHOWER, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95 - 3894 vs. MICHAEL E, DARHOWER, Defendant IN DIVORCE RE: pre-Hearing Conference Memorandum DATE: Monday, June 3, 1996 Present for the Plaintiff, Janet L. Darhower, was attorney Richard L. Webber, Jr. Also present was the Defendant, Michael E, Darhower. Mr. Darhower is not represented by counsel and has indicated that he does not, at the present time, intend to engage counsel. A divorce complaint was filed on July 21, 1995, raising grounds for divorce of irretrievable breakdown of the marriage and the economic issue of equitable distribution. Mr, Darhower has indicated that he does not wish to sign any consents to a divorce; therefore, Mr. Webber is going to file an affidavit under section 3301(d) of the Domestic Relations Code within the next two weeks averring that the parties have been separated in excess of two years. The parties were married on october 28, 1961, and separated on August 26, 1992. They are the natural parents of four children, all of whom are emancipated. Wife is 53 years of age and resides at 184 B Big spring Terrace, Newville, pennsylvania, where she lives with one of the daughters of the marriage and a male friend, Paul Mentzer. Mr, Darhower believes that Mr. Mentzer has been living with wife since a few days following the separation of the parties. Mr. Webber, however, was not certain as to Mr. Mentzer's living arrangements with wife and he will verify whether or not the information provided by Mr. Darhower is correct. Wife is a high school graduate and is employed at Kinney Shoe (Bedford Plant). She works approximately 36 hours a week and is paid at the rate of $7,50 per hour, She has not raised any health issues. Husband is 53 years of age and resides at 601 Burgners Road, Carlisle, pennsylvania, where he lives alone. He completed the 11th grade and is employed at Kinney Shoe (Anderson Building) where he runs the box plant. He usually works 40 hours a week and is paid $8.85 per hour. He has not ~, raised any health issues. Both parties are covered by health insurance through their employer. The only marital asset at issue here is a parcel of real estate of approximately one acre and a mobile home located on the real estate. This is where Mr. Darhower is living. The real estate is titled in the names of husband and wife; however, Mr. Darhower indicated that the title of the mobile home has not been processed since receiving the title from Mr. George, The real estate is subject to some delinquent real estate taxes and according to counsel the amount presently owed is around $656.20. If the real estate taxes are not resolved, the property may be subject to a Sheriff's sale in September 1996. Neither party has an opinion presently as to what the real estate and mobile home are worth; however, Mr. Webber is going to arrange to have the property appraised. Mr. Darhower will cooperate with the appraiser and Mr. Webber will notify Mr. Darhower when the appraiser is going to visit the property so Mr. Darhower can be present. After the appraisal has been completed, we will then review the opinion of the appraiser to allow Mr. Darhower an opportunity to make an offer to purchase his wife's interest in the property based on the appraisal. As the Master has indicated, he would per fer to allow Mr. Darhower an opportunity to remain in the property by purchasing wife's interest; however, if Mr. Darhower is unable to do so or chooses not to remain on the premises, then the property will have to be listed for sale and the proceeds subsequently divided between the parties. It is important, however, that the issue regarding the moble home be resolved in a fairly expeditious manner because the property may be subject to a Sheriff's sale in September, and the property could be lost via the Sheriff's sale which would eliminate any interest of the parties in the premises. Therefore, the Master has asked Mr. Webber to try to have an appraisal done as quickly as possible so we can return here for a conference to discuss the possibility of Mr. Darhower purchasing the property. A conference will be scheduled with Mr. Darhower and Mr. Webber and his client to review the appraisal and discuss the possibility of trying to resolve the marital interest in the mobile home for Monday, July 15, 1996, at 9:00 a.m. Notices will be sent to counsel and the parties. E. Robert Elicker, II Divorce Master cc: Richard L. Webber, Jr. Attorney for Plaintiff Michael E. Darhower Pro Se