Pete -

Now, I am a lawyer, but on inactive status with the State Bar of California. So I'm unable to give legal advice under California law, much less that of the Commonwealth of Pennsylvania. That said, here are some "common sense observations":

First of all, assuming the report of the master is only that, it may require the entry of a court before it can be executed on. Check that out ASAP.

That said, my principle concern is that if you take an appeal and/or contest the report of the master, then the reviewing court, presumably the Court of Common Pleas has only the evidentiary record that was before the master: UNLESS YOU ARE ENTITLED TO A HEARING DE NOVO ON THE MASTER'S REPORT. (Meaning from the start.)

Therefore, unless you are entitled to a hearing de novo, WITH THE ABILITY TO SUBMIT NEW EVIDENCE, it is also vital that you find out what the time limits are for bringing A MOTION FOR REHEARING before the master and then break your posterior to get a copy of the pre-nup and your relavent medical in advance of the filing date. The motion must explain why you used reasonable diligence in attempting to get this before the master at the first hearing (you thought your lawyer was taking care of it, etc.) and then ask for reconsideration based upon the pre-nup and medical records, the pre-nup at least you would attach as an exhibit to your affidavit, which would also address, under oath, your prior reliance upon counsel, etc. As far as medical records are concerned, you want to include copies of what you believe are the most relevant medical records, including corespondance you got from Schwartzman as well as the notes of your current treating physician. And where s/he is in a better position to authenticate his/her medical records than you are, you want his/her affidavit as well. (And see if s/he can authenticate Schwartzman's letters as records that appear and are regularly maintained in his/her medical files; otherwise, authenticate and attach it/them to your own.)

The reason this is so important, is that if the motion for reconsideration is denied, then you can seek review, either by way of appeal or contesting the approval of the master's report, from BOTH the initial ruling and the denial of the motion for reconsideration: that way the copies of your pre-nup and your medical records are in the record and before the reviewing court.

Good luck, Man.

Mike

ps I wish I could offer more, but my only contact with the Municipal Court or the Court of Common Pleas in Philadelphia was in 1973 when I lived in Center City, shortly after taking a leave of absence with terminal incompletes from my college, that place between 30th and 40th Streets, Chestnut and Spruce. I first got busted for putting my trash out a few minutes after pick up, and had to appear in the "rat control" muni court, where everyone was duly and individually admonished and the charges were dismissed. More significantly, I was the complaining witness in a holdup case, where they kept putting the matter at the end of the calendar so that it would have to be continued, in hopes that I wouldn't show up at some point so it could be dismissed. Finally, after six months of this, when it became clear that I wouldn't go away, trial went forward, the court denied a defense motion to suppress the lineup because the defendant was wearing the same clothes he had on at the holdup and subsequent arrest a few hours earlier (little did the defense know that I had been given a ride to the police station by the arresting officers). In any event, it didn't make any difference, half way through my testimony the judge announced that he was entering a judgment of acquittal for the defendant: apparently, where the kid (18) had already spent 8 months in county jail, unable to post bond, the court didn't want to hand him his first adult felony conviction for what was in essence a kid-upon-kid robbery. Only problem was that a few days later the guy who had been the alibi witness at trial, and someone else I couldn't see clearly from my first floor apt. window, tried to break down the front door of the building. The guy at the front door split as the cops showed up, and while they picked up and verified the identity of the alibi witness who was starring in from the car, they had no basis to hold him. A few hours later, the phone rang, breathing, no one there. My girlfriend and I left ASAP for the apt. of a former roommate, and we spent the most of the night with him in South Jersey. By the next day, my 19 year old, bearded long haired gnome of a self, was officially under the wing of the Witness Protection Program of the Philadelphia Police Dept., along with my girlfriend, until our parents heard about it a few days later, at which point our chains were jerked but good, and we moved into her family’s good sized home in Croton on Hudson NY, commuting by train a couple of times a week so she could finish up her art school classes and I could see my shrink, before she transferred schools and we moved to Minneapolis a few months later.

Funny part was, a few months after our move to Minnesota, someone gave me an MMPI and when I got to "There are people who want to kill me," I had to answer truthfully: Yes!