The URL can be used to link to this page

Home My WebLink About00-04955 <,- ~ w - - "':y, , CATHY C, KLINGER COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff No. ,Qcm- Y q 5"S o~11 v, RODNEY L. KLINGER Defendant CIVIL ACTION - LAW IN DNORCE NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you, You are warned that if you fail to do so the case may proceed without you and ajudgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you, YOU SHOULD TAKE TillS 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, Cumberland County Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 (717) 240-6200 "-- . , - ,"- ~"<~ri KATHY C. KLINGER Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. (yf)~ 1.1950' ~-r~ v, RODNEY L. KLINGER Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding fIled in the Court of Common Pleas of Cumberland 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 marriage counseling prior to a divorce being handed down by the court. A list of professional marriage 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 choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. - ,." , ~, . , ". .' ~.~-. :"0 CATHY C. KLINGER Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No, 1J1)- '/9SS 0;.z1 /..u- v. RODNEY L. KLINGER Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 330HC) OF THE DIVORCE CODE COUNT I 1. Plaintiff is CATHY C, KLINGER, who currently resides at 3802 Candlelight Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 2, Defendant is RODNEY L. KLINGER, who currently resides at 3802 Candlelight Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on April 26, 1975 in Millersburg, Dauphin County, Pennsylvania. 5, There have been no prior actions of divorce or for annulment between the parties. ":", " , ~ .. '"' 6, Plaintiff and Defendant are both citizens of the United States of America, 7. Neither party is a member of the Armed Forces of the United States or any of its allies. 8, Plaintiff avers as the grounds on which this action is based are that the marriage is irretrievably broken. 9, Plaintiff avers that there are no children of the Parties under the age of 18. 10, The Plaintiff has been advised of the availability of counseling and that either party may compel the other by Order of the Court to attend counseling sessions. 11. Plaintiff and Defendant separated on January 1, 1998. 12, Plaintiff asks the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests that your Honorable Court enter a Decree in Divorce under Section 3301(c) of the Divorce Code. . tIC,-1 COUNT II - EOUITABLE DISTRIBUTION 13. The Plaintiff incorporates by reference Paragraphs 1 through 12 of this Complaint for Divorce as fully set forth herein, 14, During the marriage, Plaintiff and Defendant have acquired various items of marital property, which are subject to equitable distribution under Section 3502 of the Pennsylvania Divorce Code of 1980, as amended, as will be fully set forth in the Plaintiff's Inventory and Appraisement to be filed pursuant of the Pennsylvania Rules of Civil Procedure, 15, Plaintiff and Defendant have been unable to agree as to an equitable distribution of marital property. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital property . COUNT III - PERMANENT ALIMONY 16. The Plaintiff incorporates by reference Paragraphs 1 through 15 of this Complaint for Divorce as fully set forth herein, ~ "c 'J"_, ~-th1, " 17, The Plaintiff has insufficient income and assets to provide for her needs. 18, The Defendant is well able to provide for Plaintiffs needs but has refused or otherwise failed to provide for same on a voluntary basis. WHEREFORE, Plaintiff requests your Honorable Court to award Plaintiff permanent alimony. COUNT IV - ALIMONY PENDENTE LITE. COUNSEL FEES. COSTS AND EXPENSES 19, The Plaintiff incorporates by reference Paragraphs 1 through 18 of this Complaint for Divorce as fully set forth herein, 20. The Plaintiff has retained an attorney to represent her in this action and has agreed to pay him a reasonable fee, 21. The Plaintiff is not financially able either to meet the expenses and costs of this action or the fees to which her attorney will be entitled in this case. 22. The Plaintiff has insufficient income and assets to provide for her needs. " , :-;0-1 23, The costs and expenses incurred in this litigation have become and will in the future become onerous, making it difficult for Plaintiff to maintain and support herself during the pendency of this action. 24, The costs and expenses incurred in this litigation have become and will in the future become onerous, making it difficult for Plaintiff to maintain and support herself. WHEREFORE, Plaintiff requests your Honorable Court to award Plaintiff alimony pendente lite, counsel fees, costs and expenses, Respectfully submitted, By: Richard C. Rupp, Esquire Attorney ID #34832 355 North 21" Street, Suite 205 Camp Hill, PA 17011 (717)761-3459 Attorney for Plaintiff Dated: /' 1/ ./ 00 , 0 -' l&!~t VERIFICATION I, CATHY C, KLINGER, verify that the statements in the foregoing Complaint in Divorce are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to penalties of 18 Pa, C,S, ~ 4904 relating to unsworn falsification to authorities. (itd; Co /d.r CATHY C, KLINGER, Plaintiff 7 - / /- fllJ Date: , ~ ,-,u;;-'~ $,? Z ~~ ('1 r", t2J tf"< 4 ~, .:JJia~.1 '. """"iIlillliliti~.!W/irj~~~,,",~I~j_~" n'_ >- st i::'~ -b '3 0 ~, '-' 2' r-- >- ~-Sl ...e. '" ...... ,- l- ~ '- z & ~ t~ t~~~ \\J <65 V) <t::, ~ e, % ~ .0 ::r W- ~,3 ~ 0<> -, -',- ~ <.A a- Cr') :~~~l~ VJ V) ~ r:CZ )- T..'-_~ LiJ - ~ ~ ~ -. :.)0- V eo,,( - -, -, ~ C) -, Cl 0 ~:-5 w. ~ ~ '"~~-~- . - *. ~ - - , .." ~ ,".1 '~_L_ , i__I,~ . ,- ... CATHY C. KLINGER COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff No, 2000-4955 CIVIL v, RODNEY L. KLINGER Defendant CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I, RODNEY L. KLINGER, the Defendant in the above referenced Divorce Action, do hereby accept service of the Complaint in Divorce filed by my wife. DATE: 7/'r!Joo .~"'.=' "',. -".~. ." "~,~, -~, T~ '" ~ ~"" ~~-""""""-~'''""'''~ .' . ~. ",'- .. ~-.. - -, 0 0 0 ~ 0 ~ C ,.-'. -oOJ --=-::.-n 2t.f\ '"' ,..\~? :z~ - ".""~t;.:\ 0 --0',...1 ~% 9(~ 'L:.o -'0 __,.4"\ __-<I :-.> o~~~ z;O :::::.~ yg I:-? S' ~ (.oJ 5:J ~ ::< ,0\6\00