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1 -" LAW OFFICES:) ,'-.:t'- "t'f/'t"';~f~"_;"~' ..(.L ',- :~;:' ,,~~~,_; ~T' ?:).
.~lP~INSON, DUFFIE, STEW ^R:T ~ WE1D~R. .~,',l',~,
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Td.phon. (717)16l.,+j40
T.lc<opt., (711) 161.JOU
PAMELA D. TRIMMER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
v.
NO. 98-218 CIVIL TERM
IRA JA Y TRIMMER.
IN DIVORCE
Defendant
DEFENDANT'S PRE. TRIAL STATEMENT
AND NOW. comes the Defendanl, Ira Jay Trimmer, by his attorneys. Johnson, Duffie, Stewart &
Weidner, and submits the following Pre-Trial Statement pursuant to Pa. R.C.P 1920.33Ib):
1. Au"t~. Attached hereto and marked as Exhibit . A. is an inventory of the marital and
nonmarital assets of the parties as they are known to the Defendant.
2.
~ WitfHIU"~.
At this time the Defendant intends to call the fOllowing expert
witness:
A. L.G. Connor Real Estate Appraisers
2159 Market Street
Camp Hill, PA 17011
B. Robert A. Ensminger
3557 Elmerton Avenue
Harrisburg, PA 16191
C, Greg Rothman. Associate Broker and Certified General Appraiser
335 North 21" Street
Camp Hill. PA 17011
Defenda~t reserves the right to call such additional experts as may be necessary to respond to
evidence submitted by Plaintiff. The expert witnesses will be called to testify to the value of the real
property and personal property comprising the marital estate.
"
PAMELA D. TRIMMER,
Plaintiff
: IN THF; COURT OF COMMON PI,l<;AS
: CUMBERLAND COUNTY, Pl<:NNSYI.YANIA
: NO. 96-216 CIVIL TERM
v.
IRA JAY TRIMMER,
Defendant
: IN DIVORCE
MOTION TO COMPEL ANSWER TO INTERROGATORIES AND
COMPLIANCE WITH REQUEST FOR PRODUCTION OF DOCUMENTS
COMES NOW, the Plaintiff in the above-captioned action, by her attorney,
Samuel W. Milkes, Esq., Jacobsen & Milkes, and requests of this Honorable Court that
it direct the Defendant, Ira Jay Trimmer, to answer and respond to the fll'st set of
Interrogatories and Request for Production of Documents. These Interrogatories and
Request for Production of Documents were served upon counsel for the Defendant on
April 18, 1996. No reply was received. By correspondence from Plaintiffs counsel, a
reply to these Interrogatories and Request for Production of Documents was requested
on June 20, 1996. To date, there has been no reply.
WHEREFORE, for the above-referenced reasons, Plaintiff respectfully requests
of this Court that it direct the Defendant to answer and respond to the Interrogatories
and Request for Production of Documents.
Respectfu y subll)i~d;'--
./, -./
$/~/:-"
"BY: SBinuel W. Milkes, Esq.
JACOBSEN & MILKES
52 E. High Street
Carlisle, PA 17013
(717) 249-6427
Attorney No. 30130
I \
l\
PAMELA D. TRIMMER,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96 - 216 CIVIL
vs.
IRA JAY TRIMMER,
Defendant
IN DIVORCE
AND NOW,
ORDER OF ~
this ~~ day
,
ofRJr
1998, it appearing that both parties reside in York County,
Pennsylvania, the appointment of the Master in Cumberland
county, Pennsylvania, is vacated and the case is transferred to
the Court of Common Pleas Ot York County, Pennsylvania.
The Prothonotary of Cumberland County should make
the appropriate transfer of any documents necessary to expedite
the transfer of jurisdiction of this case to York county,
Pennsylvania.
BY THE COURT,
er, P.J.
co:
Samuel W. Milkes
Attorney for Plaintiff
Mark c. Duffie
Attorney for Defendant
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