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,I IN THE COURT OF COMMON PLEAS '
81 ,
8 OF CUMBERLAND COUNTY ~
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DECREE IN A'
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OOWAS A. RUSSELL,
Defendant
AND NOW, .
decreed that ........ .SUSANA. .RUSSELL. . . . . . . . . . . . . . . . .. . . . . , " plaintiff.
and. , , .. , , .. . . . . . . . . . , , . DOUGLAS A., RUSSELL. , . . , .. . . , . .. . . '" defendant.
are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which have
been raised of record in this action for which 0 final order has not yet
been entered;
None
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MAXINE KAY LEWIS, ESQUIRE
Attorney I.D. #33085
1101 North Front Street
Harrisburg, PA 17102
(717 234-3136
Attorney for Defendant
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96-1599
CIVIL ACTION - LAW
IN DIVORCE
SUSAN A. RUSSELL,
Plaintiff
DOUGLAS A. RUSSELL,
Defendant
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
other rights important to you, inclUding custody or visitation of
your children.
When the ground for divorce
irretrievable breakdown of the marriage, you
counseling. A list of marriage counselors
Office of the Prothonotary at:
is indignities or
may request marriage
is available in the
Cumberland County Courthouse
1 Courthouse square
CarliSle, PA 17013
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, 4TH FLOOR
CARLISLE, PA 17013
(717) 240-6200
.
distribute or assign the marital property between the parties and
the marital debts of the parties without regard to marital
misconduct in such proportions as the Court deems just after
consideration of all relevant factors.
WHEREFORE, Defendant respectfully requests that this
Honorable Court enter an Order of Equitable Distribution of marital
property and marital debts pursuant to 53502 of the Domestic
Relations Code.
COUNT II
Reauest for Alimonv/Alimonv Pendente Lite Under ~~ 3701 & 3702
of the Domestic Relations Code
12. Defendant hereby incorporates Paragraphs 1 through
11 of his Answer and Counterclaims as if fully set forth herein.
13. Defendant lacks sufficient property to provide for
his reasonable needs and is unable to fully support himself through
appropriate employment.
14. Defendant requests the Court to enter an award of
reasonable temporary alimony so that Defendant may be on par with
Plaintiff in litigating his claims.
WHEREFORE, Defendant respectfully requests that this
Honorable Court enter an Order of temporary and final alimony in
his favor pursuant to 553701 and 3102 of the Domestic Relations
Code.
Count III
Reauest for Interim and Final Counsel Fees. Costs
and EXDenses Under ~3702 of the Domestic Relations Code
15. Defendant hereby incorporates Paragraphs 1 through
..
14 of his Answer and counterclaim as if fully set forth htirein.
16. Defendant has employed Maxine Kay Lewis, Esquire to
represent him in this matrimonial cause.
17. Defendant is unable to pay all the expected counsel
fees, costs and expenses in this action and avers that Plaintiff is
more able to pay these fees, costs and expenses.
18. Defendant avers that he cannot be on par with
Plaintiff in this litigation unless this Court orders Plaintiff
to pay Defendant's reasonable interim and final counsel fees, costs
and expenses.
WHEREFORE, Defendant respectfully requests that this
Honorable Court enter an Order directing Plaintiff to pay
Defendant's reasonable interim and final counsel fees, costs and
expenses pursuant to 53702 of the Domestic Relations Code.
COUNT IV
Reauest for Health Insurance under Section 35021dl
of the Domestic Relations Code
19. Defendant hereby incorporates Paragraphs 1 through 18 of
his Answer and Counterclaim as if fully set forth herein.
20. Defendant has no health insurance and is unable to obtain
health insurance through his employment.
Plaintiff is able to
obtain health insurance and is more financially able to provide
this insurance for Defendant.
WHEREFORE, Defendant respectfully requests this Honorable
Court to enter an Order directing Plaintiff to provide health
insurance for Defendant.
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Reauest for ADDroval of anv Settlement Aareement
and IncorDoration Thereof in Divorce Decree
21. Defendant hereby incorporates Paragraphs 1 through
20 of his Answer and Counterclaims as if fully set forth herein.
22. The public policy of the Commonwealth of
Pennsylvania encourages parties to a marital dispute to negotiate
a settlement of their differences.
23. While no settlement has been reached as of the date
DATED: (, I). fr~
of the filing of this Answer and Counterclaims, Defendant is
willing to negotiate a fair and reasonable settlement of all
matters with Plaintiff and is hopeful that Plaintiff may also be
willing to enter into a marital settlement agreement.
24. To the extent that a written settlement agreement
might be entered into between the parties, Defendant desires that
such written agreement be approved by the Court and incorporated in
any divorce decree which may be entered dissolving the marriage
between the parties.
WHEREFORE, if a written settlement agreement is reached
between the parties prior to the time of hearings, Defendant
respectfully requests that this Honorable Court approve and
incorporate any agreement in the final Divorce Decree.
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MAXINE KAY LEWIS, tSQUIRE
Attorney for Defendant
.
V!lRII'ICATION
I hereby verify that the statements made in the foregoing
document 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.
Oated:
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ATTClfINEY AT LAW
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1101 NOfml ffIOHT 8TRE1T
HARfUS8URG.. PENNSYLVANIA 11102
TELEPHONE (711) 2:14-3131
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A. Denied for the reasons given above in answer to paragraph
3.
B. It is admitted only that Defendant, since he has left the
marital home, has not participated in the maintenance of the home
financially or otherwise; tor reasons given in Defendant's New
Matter below it is denied that Defendant is not financially
responsible.
c. It is denied that Defendant is erratic in his conduct and
behavior or that he has been violent "on occasion" toward other
people (there was one incident in self-def.ense 16 years ago; there
has been no violence in the presence of Plaintiff or the Child).
D. It is vehemently denied that Defendant has ever been
verbally abusive to Plaintiff (there were very rare occasions when
he used profanity outside the presence of the child) .
E. It is admitted only that Defendant has been staying witb
his parents in Wormleysburg. However, his parents are awaiting
placement at Bethany Village and after their move, Defendant will
no longer have housing.
6. The allegations of paragraph 6 are denied. Plaintiff and
the minor child's security and the ability to maintain the property
will be more assured if Defendant is not deprived of possession of
the marital home.
7. It is denied that Plaintiff and the minor child do not have
a suitable place to live and that Defendant's conduct threatens the
security of the marital residence or that Defendant is
irresponsible or in anyway threatens the security of the marital
,
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residence and, on the contrary, Plaintiff and the child can live in
the marital residence without being awarded exclusive poesession.
Wherefore, Defendant respectfully requests that Plaintiff's
Petition be d~nied.
NEW MATTER
8. Defendant's answers to paragraphs 1-7 are incorporated
herein as if fully set forth herein.
9. From April 1990 - August 1995, Defendant provided all
money for mortgage payments for taxes and utilities for the marital
residence.
10. Defendant provided all material and labor to paint entire
house interior; installed Shelving, had house rewired, paid for new
air conditioner condenser, new gae furnace, new gas water heater.
and new gas dryer, paid all costs, labor and materials to build
second floor storage area; paid all materials and labor to insulate
bedrooms, bath and attic.
11. While Defendant was in marital home, he cut grass,
trimmed bushes, dug gardens and shovelled snow.
12. Defendant and Plaintiff are jointly and severally
responsible for mortgage payments.
13. The marital home was put into Plaintiff's name solely to
protect the family from losing the property if Defendant expensive
major business reversals.
14. It was not unti 1 Defendant suffered financial
,
3
SUSAII A. RUSSELL, I 111 THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND COUNTY.
) PENNSYLVANIA
I
VB. I CIVIL ACTION - LAW
) IS11 CIVIl.
I NO. 96- TERM
DOUGLAS A. RUSSELL, )
De fenelan t I [N DIVORCE
IIOTIC2 'm DUnn An r.t AIM RI~HT!l
You have been sued In court. If you wish to defend aaalnBt the clat.s set forth in
, the foreaolna paaes, you .ust take pro.pt act ion. You are warned that if you fail to do
la, the case .ay proceed without you and a decree in divorce or annul.ent .ay be
entered aaainst you by the court, A juda.ent .ay also be entered aaainst you for any
,other clai. or relief requested in these papers by the plaintiff. You .ay lose .oney or
,property or other riaht. i.portant to you, includina custody or visitation of your
" chi ldren,
, When the around for the divorce is indianities or irretrievable breakdown ot the
ii.arriaae, you .ay request .arriaae counselina. A list of .arriaae counselors is
:,available in the Office of the Prothonotary at:
Office of the Prothonotary
Cu.berland County Court House
Carlisle, Pennsylvania 11013
IF YOU DO NO'f FILE A CLAIM FOR ALIMONY. DIVISION OF PROPERTY, LAWYf,R'S FEES OR
,EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY
'OF THEM,
YOU SHOULD TAKF. THIS PAPER TO YOllR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
I CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Court Ad.inistrator. Fourth Floor
Cu.berland Cou~ty Court House
Carlisle, Pennsylvania 11013
Telephone: (111) 240-6200
1
SUSAN A. RUSSELL. ) IN tHE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND COUN1'Y.
1 PENNSYLVANIA
1
vs. 1 CIVIL ACTION - LAW
)
) NO. q6- CIVIL TERM
DOUGLAS A. RUSSELL. )
Defendant ) IN DIVORCE
WYneR or lV'11 ABILITY OP r.mnUIPJ.IMC
,TO THE WITHIN-NAMED DEPENDAN1':
You have been na.ed as the Defendant in a Co.plaint in a divorce proceeding filed
in the Court of Co.mon Pleas of Cu.berland County. This notice is to advise you that in
accordance with Section 3302(d) of the Divorce Code. you may request that the court
require you and your spouse to attend .arriage counseling prior to a div~rce beinl
banded do~n by the court. A list of professional marriale counselors Is available at
the Domestic Relations Office. 13 North Hanover Street. Carlisle. Pennsylvania. You are
advised that this list is kept as a convenience to you and you are not bound to cboose
a counselor from. this list. All necessary arranle.ents and the cost of counsellnl
.essions are to be borne by you and your spouse,
If you desire to pursue counselinl, you .ust make your request for counselina
within twenty days of the date on ~hich you receive this notice. Failure to do so will
constitute a ~aiver of your rilht to request counselinl.
2
SUSAH A. RUSSEll., ) IN THE COIJRT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND COUNTY.
) PENNSYLVANIA
)
vs, ) CIVIL AC'rION - LAW
J
) NO. <)6- / >'if CIVIL TERM
DOUGLAS A, RUSSELL, )
Defend.iRt ) IN DIVORCE
CDIfl'I.UIIT II DIVORCB
iIlII MOW com.u the above-named PlaintiH. SUSAN A. RUSSELL, by her attorney. Suuel
L. Andes, and makes the following Complaint in Divnrce:
1. The Plaintiff is SUSAN A. RUSSELL. an adult Individual who currently resides
:at 2808 Launl Lane. Camp Hill. Cusberland County, Pennsylvania,
2, The Defendant is DOUGLAS A. RUSSELL. an adult individual who currently residea
at 93 Greenwood Circle. Wor.leysburg, Cumberland County, Pennsylvania.
3. Botb the Plaintiff and Defendant have been bona fide residents of the Common~
I
'wealth of Pennsylvania for at least si~ sonths i.mediately previous to the filinl 0'
this Coapla int .
4. The Plaintiff and Defendant were aarried on 20 March 1<)83 in Harri.bura.
Pennsylvania,
S. There have been no prior actions of divorce or annulment between the partiel.
6. Tbis marriage is irretrievably broken,
7. Plaintiff bas been advised of tbe availability of aarriage counlelina snd tbe
Plaintiff may bave the right to request that the Court require tbe parties to partici~
pate in counseling,
8, Tbe Plaintiff requests this COIllt to enter a Decree of Divorce,
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DOUGLAS A, RUSSELL,
Defendant
NO, 96.1599 CIVIL TERM
IN DIVORCE
AFFIDA VIT OF CONSENT
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNA.
SUSAN A. RUSSELL,
Plaintiff
vs.
CIVIL ACTION . LAW
1. A Complaint in Divorce under Section 3301(c) ofthe Divorce Code was filed on March
25, 1996 and was served upon the Defendant on or about March 28, 1996.
2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing of the complaint and the date of service of the complaint on the
Defendant.
3. I consent to the entry of a tinal decree in divorce either after service of a Notice of
Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to
Request Entry of the Decree.
. 4. l have been advised of the availability of marriage counseling and understand that the
Court maintains a list of marriage counselors and that I may request the Court to require my spouse
and I to participate in counseling and, being so advised, do not request that the Court require that
my spouse and! participate in .;ounsding prior to till: divorce becoming final.
I verify that the statements made in this Affidavit are true and correct and 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,
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DATE
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SUSAN A. RUSSELL.
Plaintiff
IN THE COURT OF' COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Vii.
CIVIL ACTIO~ - LAW
NO. 96-IS91 CIVIL TERM
DOUGLAS A. RUSSELL,
Defendant
IN DIVORCE
ORDER OF COURT
AND NOW, this .).b -rk--day of )/~
. 1996, upon
consideration of the attached Petition for Exclusive Possession of
Residence, we hereby schedule a hearing in this
9'~3u o'clock ff.m., if'. Court Room No.3
Court House, on /Jr..nti,uy ,the / Y
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11996.
matter commencing at
of the Cumberland County
day of
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Pll1-0UO-WAAA"NTY
lNO 01' COAP
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COPVAtGMT 19180 bv ALL. STATE LEGAL SUFtPt,tCORP
m ~ is it e ell, made the / [-I- day of 7l/M& II
Urlwun LEAH M. WALKER, unmarried, fotllleo:ly known a~
of Camp Hill, Pennsylvania, Cumberland County
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Leah ~I. Zil1111erman
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herein df!.'ji!Jllut~d Wi the G,'u"to1."
Anll SUSAN A. RUSSELL, married, of Camp Hill, Pennsylvania, Cumberland County
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herei'l desigllated a3 the Gl'alltee.'; ,
milnflnl~, that the Grantors, for and in consideration of One Hundred Twenty-Four
Thousand Five Hundred (S124,500.00) Dollars
lawful money of the United States of ..I mericll, to the Grantors in hand u'ell alld truly paid by the Gralltees,
at or before the sealing and delivery of these presents, the receipt whereof is hel'eby ackllulrledged (lIId the
Grantors being therewith fully satisfied, do by these presents grant, barJJaill, sell alld cunrey llnto the
Grantees forever,
All that certain trcu:t or parcel of land and premises, situate, lying und beillg in tile
Borough of Camp Hill ill tile Cuunty uf
Cumberland and Commonwealth of Per.nsylvanill, more particularly described as follou.'s:
BEGINNING at a point on the western side of a fifteen (15) foot
alley and at the northern line of Lot No.8, on hereinafter
mentioned Plan of Lots; thence along the northern lines of Lots Nos.
8 and 7 in a westerly direction one hundred nineteen and twenty-one
one-hundredths (ll9.21) feet to a point; thence in a southerly
direction one hundred forty-five (145) feet to the northern side of
Laurel Lane; thence along the northern side of Laurel Lane in an
easterly direction seventy and seventy-four one-hundredths (70.74)
feet to a point at a curve; thence by a curve to the right with a
radius of thirty (30.00) feet and arc distance of forty-eight and
thirty-three (48.33) one hundredths feet to the western side of a
fifteen (15) foot alley; thence along the west side of said fifteen
(15) foot alley in a northerly direction one hundred fifty-four and
fifty-four one hundredths (154.54) feet to the place of BEGINNING.
BEING all of Lot No. 8 and the eastern thirty-five and fifty-six
one-hundredths (35.56) feet of Lot No.7, on a Plan of Lots laid out
by Richard T. Tyner, said Plan being recorded in the Recorder I s
Office at Carlisle, Pennsylvania, in Plan Book 4, Page 22.
HAVING thereon erected a brick and stone ranch home known as 2808
Laurel Lane, Camp Hill, Pennsylvania.
BEING the same premises which George E. Gresham and Nancy Marie
Gresham, his wife, granted and conveyed to Leah M. Zimmerman, by
their Deed dated May 23, 1960 and recorded in the Off ice of the
Recorder of Deeds in and for Cumber~and County, Pennsylvania on May
23, 1960 in Deed Book@1 Vol. 19, Page 248. Leah M. Zimmerman
married David Walker on\1 , and said David Walker died
on so Leah M. Zimmerman is now known as Leah M.
Nalker.
BGOK 234 rACE 639
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1. 'lI. Real EIIa/eltanefar Tax
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Cumb, Co. Ohlt. Co!. Aet- ~ ~
Irall't~ er wtlh all and jingular the bUIldings, improl'ements, u'''ys, ,,'oods, !Cute,", ",,,terel,,,,>es, ri!Jltt."
liberties, prit,lN!}es, hereditar.tents 0'101 '.lppurtenutlees to the same belotl!}itl!} or i'l atly,..i.,. al/pertaitlina; atld
the ret',rsion atld reeersi",ls. remainder and remaInders, relltS, issues alld profits thereuJ; atld of ecery part
and parcel thereoJ: Ana also all the e.Hale, righi, litle, itl teres t, use, possessio'l, p"'perty, claim and
dema,td whatsoeel!1' of Ihe Grantors both i'llaw alld in equily, oJ; in 01101 to the premi.,e., herein described and
eef?rlJ part atld para/thereof u:ith the applirtena'lces. Ira ~au, ana 10 ~ola all IlIld SltI!}ular the premises
herein described together wIth the hereditanltmts and appurtenatlces UlltO the Grantee., a'lIlto Gruntees' proper
""e and benefit Joreeer.
Ana the Gralltors coeenant tltat, except as may be herein jet Jorth, they do and u:iIl larruer warrant
0.101 atftna the lands atld prem;.,es, hereditaments and appurtenances hereby eon l'eyed, u{/uillst the Grantors
and all ather persolls lawfully claimitl!} the same or to claim the same.
In all relere1Ku herfllrt to allU partie$. person$, entities or corporation", the u.!e of any purticulur ye'lder or the
plural or si71QulCU" number t.'i Irttfl1ldert to include the appropnate gender or J1umber as the tezt of the witllil, ill:Jtnouerat lUall
,eq uire.
Whnever in thi.t i,..ttrument any partll shall be deJiQnated or referred to b~ flame or generrJl reJ~rettce. :luch de:n'r.mla~
hon i.t int,nded to and .thall hat:' the same effect rl8 II thff u;orda "heirs, executors, admnu:Jtrutor!l, per~orlUl or eflal
rrpre!entativej, .:Iucceuors and auig7l3" had been inserted oJler ecu:h and el..'Io-y such designation.
In lIIIitn,.. m~'not, the Grantors have hereunto set their hatld~ and seals, or if a corporation, it has
ca!Ued these presents to be signed by its proper corporate officers and its corporate seal to be o.ffixed
hereto, the day and year first above written,
.ign,ZI, "II,a Ina Ihliu,rta
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Leah M. Walker
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personall"J appeared Leah M. Walker / hi,..~,,(y /,;q,( 71/.2".,-:tN,.,...-
known to me (or sati3fadorily proeen) to be the peJson whose name is subacribed
to the within deed and acknowledged that s he executed the same for the purpos.s th.r.ill cUlltailled.
mitnt.. my hand and seal the day and year riforesa~'d. ;/ /' .~\,~.~..(~.
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A. Denied for the reasons given above in answer to Paragraph
3.
B. It is admitted only that Defendant, since he has left the
marital home, has not participated in the maintenance of the home
financially or otherwise; for reasons gillen in Defendant's New
Matter below it is denied that Defendant is not financially
responsible.
c. It is denied that Defendant is erratic in his conduct and
behavior or that he has been violent "on occasion" toward other
people (there was one incident in self-defense 16 years ago; there
has been no violence in the presence of Plaintiff or the child).
D. It is vehemently denied that Defendant has ever been
verbally abusive to Plaintiff (there were verv rare occasions when
he used profanity outside the ~resence of the child).
E. It is admitted only that Defendant has been staying with
his parents in Wormleysburg. However, his parents are awaiting
placement at Bethany Village and after their move, Defendant will
no longer have housing.
6. The allegations of paragraph 6 are denied. Plaintiff and
the minor child's security and the ability to maintain the property
will be more assured if Defendant is not deprived of possession of
the marital home.
7. It is denied that Plaintiff and the minor child do not have
a suitable place to live and that Defendant's conduct threatens the
security of the marital residence or that Defendant is
irresponsible or in anyway threatens the security of the marital
2
residence and, on the contrary, Plaintiff and the child can live in
the marital residence without being awarded exclusive possession.
Wherefore, Defendant respectfully requests that Plaintiff's
Petition be denied.
NEW MATTER
8. Defendant's answers to paragraphs 1-7 are incorporated
herein as if fully set forth herein.
9. From April 1990 - August 1995, Defendant provided all
money for mortgage payments for taxes and utilities for the marital
residence.
10. Defendant provided all material and labor to paint entire
house interior; installed Shelving, had house rewired, paid for new
air conditioner condenser, new gas furnace, new gas water heater
and new gas dryer, paid all costs, labor and materials to build
second floor storage area; paid all materials and labor to insulate
bedrooms, bath and attic.
11. While Defendant was in marital home, he cut grass,
trimmed bushes, dug gardens and shovelled snow.
12. Defendant and Plaintiff are jointly and severally
responsible for mortgage payments.
13. The marital home was put into Plaintiff's name solely to
protect the family from losing the property if Defendant expensive
major business reversals.
14. It was not until Defendant suffered financial
3
difficulties beginning October 1994 and culminating in August 1995,
that plaintiff wanted Defendant to leAve the marital residence.
15. Defendant has in the past been actively involved in his
daughter's activities (assistant coach of soccer team, assistant
coach of softball team) attended swim meets, Indian Princesses,
swimming, computer.
16. Defendant has committed no acts that should deprive him
of his residence prior to the equitable distribution of the
property.
17. Defendant left the marital residence in the belief that
a limited separation would bring about a reconciliation with
Plaintiff.
18. Defendant has worked since he left the house to have
better financial security for his family.
19. The parties can live separate and apart within the
marital residence without infringing on each other's privacy and
coparent the parties' daughter.
Respectfully submitted,
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
SUSAN A. RUSSELL,
Plaintiff
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:,.1 DOUGLAS A. RUSSELL,
Defendant
NO. 96-1599
IN DIVORCE
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PRAECIPE
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Sir:
11 Please withdrawal all economic claims filed in this matter on behalf of the Defendant,
"
II ,Douglas Russell, including, but not limited to, claims for equitable distribution, alimony, alimony
II,
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Ii 'pendente lite, counsel fees and expenses.
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Maxine Lewis --
Attorney for Defendant
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