Pawlowicz, M. v. Pawlowicz, E.

CourtSuperior Court of Pennsylvania
DecidedMarch 3, 2025
Docket718 WDA 2024
StatusUnpublished

This text of Pawlowicz, M. v. Pawlowicz, E. (Pawlowicz, M. v. Pawlowicz, E.) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pawlowicz, M. v. Pawlowicz, E., (Pa. Ct. App. 2025).

Opinion

J-S06004-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

MARY E. PAWLOWICZ : IN THE SUPERIOR COURT OF : PENNSYLVANIA Appellant : : : v. : : : ELI D. PAWLOWICZ : No. 718 WDA 2024

Appeal from the Order Entered May 13, 2024 In the Court of Common Pleas of Butler County Civil Division at No(s): F.C. No. 2019-90290-D

BEFORE: PANELLA, P.J.E., LANE, J., and BENDER, P.J.E.

MEMORANDUM BY PANELLA, P.J.E.: FILED: March 3, 2025

Mary E. Pawlowicz appeals from the order of the Court of Common Pleas

of Butler County adopting the hearing officer’s report and recommendation as

an order of the court. Wife claims that the trial court erred in adopting the

hearing officer’s report and recommendation that precluded Wife from

presenting certain evidence because of her failure to file a pretrial statement.

After careful review, we affirm.

Mary E. Pawlowicz (Wife) and Eli D. Pawlowicz (Husband) were married

for 27 years and have three children. Two of the children were emancipated

prior to separation and Wife has sole custody of the third child.1

Wife initiated the instant divorce action on May 9, 2019. Both parties

sought claims of equitable distribution, alimony, and costs and fees. ____________________________________________

1 As of the date of the hearing before the hearing officer the child was 16 years

old. J-S06004-25

On April 27, 2021, the trial court issued an order requiring the parties

to file a pretrial statement before the pretrial conference. Subsequently, the

hearing officer issued three scheduling recommendations, adopted by the trial

court, continuing the hearing before the hearing officer. Each of these stated

that both parties “shall comply” with Pennsylvania Rule of Civil Procedure

1920.33(b), which requires the parties to file and serve a pretrial statement

before the hearing. Wife failed to file a pretrial statement through either of

her two attorneys.2

The hearing before the hearing officer was held on November 10, 2022.

The parties stipulated that the only marital property subject to equitable

distribution were the marital residence and Husband’s retirement assets.

Because Wife failed to file a pretrial statement, the hearing officer precluded

Wife from testifying and presenting evidence about the existence of any assets

or liabilities not included in Husband’s pretrial statements, the value of any

assets or liabilities identified in Husband’s pretrial statements, and her income

and expenses.

On November 30, 2022, the hearing officer issued its report and

recommendation. In its report, the hearing officer explained why it precluded

Wife’s above testimony for her failure to file a pretrial statement. The hearing

officer took notice that Wife was unable to work and that her monthly net

income was $1,298.00 from social security benefits. The marital property was ____________________________________________

2 Wife was represented by Attorney Victor Vouga until December 2021. Thereafter, and on appeal, Wife was represented by Attorney Nicole Thurner.

-2- J-S06004-25

distributed by splitting Husband’s retirement assets 50/50 and awarding Wife

the marital residence with the obligation to refinance and pay Husband

$45,000 upon refinancing. The hearing officer observed that it provided Wife

an appropriate disproportionate equitable distribution. Also, the hearing

officer rejected both parties claims for alimony and costs and fees. In

particular, the hearing officer rejected Wife’s alimony claim since Wife was

prohibited from providing testimony regarding her income and expenses as a

result of her failure to file a pretrial statement.

Wife filed exceptions to the hearing officer’s report and recommendation

which were argued before the trial court. On October 27, 2023, the trial court

issued an order denying Wife’s exceptions to the hearing officer’s report and

recommendation and requested the prothonotary to prepare the divorce

decree which was later issued on November 15, 2023. Wife appealed from this

order. We quashed the appeal because “there did not appear to be a final

order as to equitable distribution.” Order, 1404 WDA 2023 (per curiam)

(citations omitted). Thereafter, on May 13, 2024, the trial court issued an

order adopting the hearing officer’s report and recommendation which

disposed of all the claims. Wife appealed from this order. The trial court filed

a 1925(a) opinion.

Wife raises the following issues on appeal:

1. The trial court erred and/or abused its discretion when it confirmed the Hearing Officer’s ruling that [Wife] was barred from testifying regarding the existence of any assets or liabilities not included in any of [Husband’s] Pretrial Statement.

-3- J-S06004-25

2. The trial court erred and/or abused its discretion when it confirmed the Hearing Officer’s ruling that [Wife] was barred from testifying to the value of any assets or liabilities included in [Husband’s] Pretrial Statements.

3. The trial court erred and/or abused its discretion when it confirmed the Hearing Officer’s ruling that [Wife] was not permitted to testify as to her income and expenses, other than permitting her to testify as to her award of social security disability income.

4. The trial court erred and/or abused its discretion when it confirmed the Hearing Officer’s ruling that [Wife] was barred from entering any evidence regarding her expenses, counsel fees, costs, or expenses and thus did not address [Wife’s] claim for permanent alimony, counsel fees, costs or expenses.

Appellant’s Brief, at 22.

These issues all relate to the hearing officer limiting Wife’s testimony

and evidence because of her failure to file a pretrial statement, thus we will

address them together.

Our review of an equitable distribution order is limited as such awards are within the sound discretion of the trial court[] and will not be disturbed absent an abuse of discretion. An abuse of discretion will be found by this Court only if the trial court failed to follow proper legal procedures or misapplied the law.

Anderson v. Anderson, 822 A.2d 824, 827 (Pa. Super. 2003) (citation

omitted).

Wife argues that the underlying rationale for Rule 1920.33 “is to alert

the parties to all the possible issues, to eliminate surprise, and to allow the

[hearing officer] to effectuate the fairest possible distribution.” Appellant’s

Brief, at 24 (citing Anderson, 822 A.2d at 832). She argues that based on

the pleadings and discovery, Husband was aware of her claim for alimony and

-4- J-S06004-25

thus would not be surprised by evidence related to her income for her to

establish alimony. See id. at 26-29. Wife argues that precluding her testimony

was a sanction that should only be imposed when the violation is willful, and

the opposing party has been prejudiced. See id. at 29-30.

Rule 1920.33 sets forth the requirement of filing an inventory and

pretrial statement. See Pa.R.C.P. 1920.33(a)-(b). If either one is not filed,

“the court may make an appropriate order under Pa.R.C.P. No. 4019(c)

governing sanctions.” Pa.R.C.P. 1920.33(c). Alternatively, Rule 1920.33(d)

provides:

(d) (1) A party who fails to comply with a requirement of subdivision (b) may be barred from offering testimony or introducing evidence in support of or in opposition to claims for the matters omitted.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Anderson v. Anderson
822 A.2d 824 (Superior Court of Pennsylvania, 2003)

Cite This Page — Counsel Stack

Bluebook (online)
Pawlowicz, M. v. Pawlowicz, E., Counsel Stack Legal Research, https://law.counselstack.com/opinion/pawlowicz-m-v-pawlowicz-e-pasuperct-2025.