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Home My WebLink About96-06040 q" \. " ~ ~ 'i) r \. \) ~ ~ \I). (: f. '"', ~ - . I ! I I . .' - () o :r o " -t 0'" v. I I I I I I IN THE COURT OF COMMON PLBAlJ CUMBERLAlfD COUNTY, PEIOlSYLVAlfIA NO. 96 - ~Oyb CIVIL TERM IN DIVORCE LINDA CAROL STRAYBR, PLAINTIFF BDWARD HARRY STRAYER, DBFBNDAlfT . . COMPLAINT UNDER SECTION 3301(0) OR 3301(4) OF THE DIVORCE CODE IN DIVORCE 1. The plaintiff is Linda Carol strayer who resides at 5505- 1 Moreland Court, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is Edward Harry strayer who resides at 6203 Locust Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 10, 1981 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The Defendant is not a member of the Armed Services of the united States or any of its Allies. 8. The Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. Claim II 9. Paragraphs 1-8 are incorporated herein by reference hereto. 10. The Plaintiff and Defendant are owners of certain jointly owned property or other property which constitutes marital property. 11. Wherefore, Plaintiff requests this Court to enter an Order equitably dividing or assigning the marital property between the parties. Claim III 12. Pal'agraphs 1-11 are hereby incorporated by reference hereto. 13. Plaintiff is without sufficient income and/or assets to support herself or pay attorney fees and is unable to fully support herself through appropriate employment. 14. Plaintiff requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. WHEREFORE, Linda Carol Strayer requests this Honorable court to enter an award of alimony, alimony pendente lite, counsel fees and expenses. Plaintiff also requests the court to enter a decree of divorce. '1Xmlc,// p. &d~ Thomas D. Gould Attorney for Plaintiff LD. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 Fax 761-1974 - . - DM ~") ,1\ \ \ PLAINTIFF: IN TI-IE COURT OF COMMON PLEAS OF . : CUMBERLAND COUNlY, PENNSYLVANIA LINDA C. STRAYER, V : CIVIL ACTION 96- hOl{O EDWARD H. STRA YEll DEFENDANT: ORDER OF COURT And now, this..lAlJl.. day of N"v~mh~r . 1 QQ6 . upon consideration of the attached petition for Alimony Pendente Lite and/or counsel fees, ilis hereby directed that the parties and their respective counsel appear before R. J. Shadday ,on December 4. 1996 at 9:00 a.m. for a conference, afier which the conference officer may recommend that an order for Alimony Pendente Lite be entered. You arc further ordered to bring to the conference: (I) a true copy of your most recent Federal Income Tax Retum, including W-2's as filed. (2) your pay stubs for the preceding six (6) months (3) Ihe Income and Expense Statement attached to this order, completed as required by Rule 1910.II(c) (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you If you fail to appear for the conference or bring the required documents, the court may issue a warrant for you arrest. BY TI-IE COURT, Harold E. Sheely, President Judge Date of Order. November 14. 1996 ~...;, . . _:":'-t..,_. CoitterencfOfficer. R. J. Shadday / /' YOU HA VB TIlE RIGHT TO A LAWYER, WHO MAY ATIEND TI-IE CONFERENCE\k.m REPRESENT YOU. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE TIlE OFFICE SET FORm BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP. Court Administrator Fourth Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 (717) 240-6200 AMERICANS WITH DISABILITIES ACT OF 1990 The COUll of Common Pleas of Cumberland County Is required by law to comply with the AmertcMs with Disabilities ACl of 1990. For Infonnalion about accessible facilities Md reasonable accommodations available to disabled individuals having businm before the court, plea.se contact our office. Ail arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hewg. ,:,v :~ II \ f\ ' I,.,. .,~: '1)7 :~'( \'f\Clcl.....\ \\-\lU... ~'-' ~\\ t.-:'-\\)..;I"-,,d 0.. (t\\,\ €::. \ \ II . ')'-\ I " I ~" ! ~/ ; ) ;;: I 'J ; Li..: ",Il', ". ,1,\ . { - ~ LINDA CAROL STRAYER, PLAIIlTIr, I I I I I I I IN THE COURT or COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 96 - '''1/0 CIVIL TERM . v. EDWARD IlARRY STRAYlR, DEL"ENDANT IN DIVORCE PETITION rOR ALIMONY PENDENTE LI~E AND NOW comes the Plaintiff, Linda Carol Strayer, by and through her attorney, Thomas D. Gould, and files this petition seeking alimony pendente lite and alleges. 1. plaintiff, Linda Carol Strayer, is an adult individual living at 5505-1 Moreland Court, Mechanicsburg, pennsylvania, date of birth of 7/17/49, SSI 172-40-7184.. 2. Defendant, Edward Harry strayer, is an adult individual living at 6203 Locust Lane, Mechanicsburg, Pennsylvania, date of birth 9/20/43, ssl 162-36-7674. 3. The Plaintiff and Defendant were married on July 10, 1981. 4. The Plaintiff filed a complaint in divorce on November 4, 1996 with the Court of Common Pleas, Cumberland County, PA. 5. Plaintiff filed a request for support with the Cumberland County Domestic Relations office on November 1, 1996. 6. Plaintiff is without sufficient income and/or assets to support herself and bring this legal action and is unable to fully support herself through appropriate employment. -- 6. Plaintiff requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. WHEREFORE plaintiff requests that this honorable court enter an appropriate order for alimony pendente lit~ against the Defendant. It is also requested that this request for alimony pendente lite be consolidated with Plaintiff's request for support previously filed with the Cumberland County DRO. fhn-r/ad V). ~ Thomas D. Gould Attorney for Plaintiff 1.0. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 Fax 761-1974 >. ..:r u; - '-. .. ....~ .. , i,., c. - g~; - J.- . :r..: .;rl~ ~t': l ~:j . - fiI[, ..:1' -';r) , J.:--:.... -'" :;.. -.) LL;' 'Ii') ~. C', ,. '- :'-''-1. -. lI. ~ :'~'j 0 V - ~ ... DR 25.911 LINDA C. STRA YER , Pl.^ INTI FF/PETITIONER IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. I'ENNSYLV ANIA VS CIVIL ACTION. LA W mWARD II. STRAYER. DEFENDANT/RESPONDENT: NO. 96. 6040 CIVIL TERM ORnER OF COllRT AND NOW. this 4th day of December. 1996. based upon Ihe Court's determinalion Ihal Petiliuner's monthly net income/earning capacity is $.lliA. per month and Respondent's monthly nel income/earning capacity is .$ N/ A per month. il is hereby Ordered that the Rcspondent pay to Ihe Dumestie Rclatiuns Seetiun. CuurtufCommon Pleas. $ 1.000.00 u month payable $ 1.000.00 per munth as alimony pendente lite. etlective 12/1/96. Arrears sel at $ 1.000.00 as of 1214/96. shall be payable at $l1L!l... First payment due un or beliJre 12/15/96. and each monlh Ihereaner. This order is bused upun an UL!reement of the purties. Fuilure tUl11uke each paymenl on time and in full will cause all arrears to become subjecllo immediate cullection by all of the means as provided by 23 Pa.C.S.* 3703. Further. if the Court linds, aner hearing. that the Respondent hus willfully failed to comply with this Order. it may declare the Respondent in civil conlempt of Court and its discretion muke un appropriate Order. including. but nut limited tu. commitment of the Respondent to prisunlor a periud nut to exceed six months. Payments must be made by cash, check or muney order. Cush payments must be made in person. All checks and money orders must be made puyuble to Domestic Relations Sectionund delivered or mailed to Domestic Relations Section. 13 North Hanowr Slreet. 1'.0. Bux 320. Carlisle, Pennsylvunia. 1701 J. Each puymentmust bear your Domestic Rclalions number (DR _) in urder to be processed. Respondent is respunsible liJr service lees of 2.0() tu be paid within thirtv duvs as delennincd by the Domestic Relations Section. In the Court of Commou Picas of CUMBERLAND Couuty, Pennsylvllnlll DOMESTIC RELATIONS SECTION LINDA C. STRAYER DII<:kel NUlllher 96 CV 6040 Plaintiff VS. PACSES Case NUlllher 480000027 BOWARD H. STRAYBR :{ '.)'111 Delimdalll Olher Slale ID NUlllher CONSENT ORDER AND NOW, to wit. on this 26TH DAY OF OCTOBER, 1998 IT IS HEREBY ORDERED that the support order in this case be 0 Vacated or 1$1 Suspended or o Terminated without prejudice. effeclive /D,/.2{"/ YY . due to: ~~.oh. /) ~"<(-7',,:cZ.;&ff";, ) Consented: .~n;b.) C ~~ ~ (/ Attorney/Witness Defendant ORa: R.J. Shadday cc: Pet It I.oner and Respondent .""i",,, {~lt.;.tl-::""" 1';*'''1~ Edward E. Gu I do. October 26. 1998 JUDGE Date Servke Type M Fllrm OE-503 . : \, I Wm!:er ID 21504 fr, ("I (; C': '" .. ::.:. -" ~~; - ;~): ;; ~., ~' :r.: .):.,. c.~.; ~'i' .~ , .~ ~-J ~c ej\ ".'1 .. !::~ i., N [i:iU ..... !l1,.;j ,!:. '-' .!r>_ c ::5 II. ce 0 0' U