tion for Hearing Before Permanent Master in Divorce

proposed form for pre-Hearing memorandum
pursuant to pa.r.c.p. no. 1920.33(b)
caption
pre-hearing memorandum
I.	History and/or background information of the parties and the marriage (in narrative form):
A.	Date of marriage;
B.	Date of separation (if a dispute exists, so indicate);
C.	Prior marriages of the parties;
D.	Children of the marriage (names, ages and dates of birth, special needs);
E.	Age of each party;
F.	Education, history of employment and earnings of each of the parties with emphasis on any particular skill and needs;
G.	Health of each of the parties;
H.	Contribution of either to the education, training or increased earning power of the other party;
I.	Opportunity of each party for future acquisition of capital assets and income;
J.	Any other background factors counsel believes necessary to bring to the Master’s attention relative to the criteria set forth under § 3502 of the Divorce Code.
II.	Schedule of marital assets in columnar form.
A.	Marital home and other real estate;
B.	Financial accounts (with balances as of date of separation);
C.	Motor vehicles;
D.	Pensions (with attached evaluations) and other retirement accounts (provide statements for IRA and 401k accounts as of time of hearing);
E.	All other types of marital assets.
	Where feasible all marital assets shall have current appraisals and/or evaluations attached as exhibits. This is so whether the parties agree or disagree as to value.
III.	Schedule of assets that the parties claim to be non-marital. List in columnar form with their respective value.
IV.	List in columnar form all marital debts and/or liens against marital assets with an explanation of how and when acquired, i.e.:
A.	Mortgages and home equity loans with balances as of the date of hearing;
B.	Car loan;
C.	Judgments;
D.	Credit cards (attach copies of statements as close as possible to date of separation);
E.	Tax liabilities;
F.	Any other obligation.
V.	Any legal issues involved that require a finding by the Master, i.e.:
A.	Pre-marital agreements;
B.	Date and manner of acquisition of non-marital assets;
C.	Any other issues to be determined by the Master;
D.	Citation of legal precedents if necessary.
VI.	Proposed distribution to each of the parties with specific recommendations.
VII.	Reasons for proposed distribution and which factors listed under § 3502 are applicable with explanation.
VIII.	Alimony:
A.	The applicability of the criteria set forth under § 3701 to justify alimony;
B.	Citation of legal precedents if necessary.
IX.	Counsel fees and costs:
A.	Facts to justify award of counsel fees and costs;
B.	Affidavit of counsel fees incurred supplemented with retainer letter and breakdown of hours.
X.	Estimate of time necessary to present case.
This Pre-Hearing Memorandum must be filed with the Permanent Divorce Masters Unit ten (10) days prior to the scheduled hearing date.