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CINDY L. WICKARD,
PLAINTIFF
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
dl . .:l ,)(. 9 ('4....I""Lb-
NO. ,..
JOHN C. WICKARD,
DEFENDANT
CIVIL ACTION - LAW
IN DIVORCE
CONPLAI.T
AND NOW, this~day Of~, 19'1C. ,
comes the Plaintiff, CINDY L. WICKARD, by her attorney,
DIANE G. RADCLIFF, ESQUIRE, and files this Complaint in
Divorce of which the following is a statement:
COUJIT II DIVORCE
1. The Plaintiff, CINDY L. WICKARD, is an adult
individual residing at 416 Mumper Lane, Dillsburg, York
County, Pennsylvania, since OctOber, 1994.
2. The Defendant, JOHN C. WICKARD, is an adult
individual residing at 15 Burgners Mill Road, CarliSle,
Cumberland County, Pennsylvania, since October 1992.
3. Plaintiff and/or Defendant have been bona fide
residents of the Commonwealth for at least six (6)
months previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on August
21, 1992 at Mt. Holly Springs, Pennsylvania.
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D1ANl G. RADCLIfF
A'lTOIlNEY.AT.UW
S44I 'fa.NDLI &OAn
('..AM' HILL. PA 17011
!'lAN! G. RADCLIfF
ATTOIlNlY.AT.UW
. _ nlNnl.l ROAn
CAM' HILL. ,A. 17011
5. There have been no prior actions of divorce or
annulment between the parties.
6. Plaintiff hall been advised of the availability
of counseling and the right to request that the Court
require the parties to participate in counseling.
7. The Defendant is not II member of the Armed
Services of the United States or any of its Allies.
8. The Plaintiff avers that the grounds on which
the action is based are:
(a) That the marriage is irretrievably
broken.
Or in the alternative,
(b) That
Defendant
has
offered
such
indignities to the person of the Plaintiff, the innocent
and injured spouse, as to render her condition
intolerable and life burdensome, and that this action is
not collusive.
Or in the alternative,
(c) That the parties have lived separate and
apart since October 19, 1994, and at the appropriate
time, Plaintiff will submit an Affidavit alleging that
the parties have lived separate and apart for at least
two (2) years and that the marriage is irretrievably
broken.
3
DIANE G. RADCLIff
A'lTOIlNEY.AT.l.AW
...... TaINDl.l ROAD
CAMP HILI.. PA 11011
COU.T 1111 ALIMa.' '..DI:.TI: LIT.. ALIMa.'
13. Paragraphs 1 through 12 are incorporated by
reference hereto as fully as though the same were set forth at
length.
14. Plaintiff lacks sufficient property to provide for
her reasonable means and is unable to support herself though
appropriate employment.
15. Plaintiff requires reasonable support to adequately
maintain herself in accordance with the standard of living
established during the marriage.
WHEREFORE, Plaintiff requests this Honorable Court to
enter an award of alimony pendente lite until final hearing
and hereafter enter an award of alimony permanently
theraafter.
COU.T IVI COU.SEL PIIS
16. Paragraphs 1 through 15 are incorporated by
reference hereto as fully as though the same were set forth at
length.
17. Plaintiff has employed Diane G. RadCliff, Esquire,
as counsel but is unable to pay the necessary and reasonable
attorney's fees for said counsel.
5
I
18. The Plaintiff is in need of hiring various experts
to appraise the parties' marital assets and does not have the
funds to pay the necessary and reasonable fees.
WHEREFORE, Plaintiff requests this Honorable Court to
;'
enter an award of interim counsel fees, costs and expenses and
to order such additional sums hereafter as may be deemed
necessary and appropriate and at final hearing to further
award such additional counsel fees, costs and expenses as are
deemed necessary and appropriate.
Respectfully submitted,
.- - I 2 t f)
-------- SQUI;;:-t
DIANE G. RAIlCLlFF
A'lTOIlN[y.AT.I.AW
,.... TIINDLI ROAD
('AMP HlH, 'A 17011
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