HomeMy WebLinkAbout97-00863
ROSEMARIE C. HOLLAND,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. .i'/ Ji ~ fit, (/1,..
JOHN HOLLAND,
Defendant
CIVIL ACTION - LAW
IN DIVORCE AND CUSTODY
COMPLAINT IN DIVORCE AND CUSTODY
1. Plaintiff Is ROSEMARIE C. HOLLAND, an adult Individual whose current mailing
address Is 305 Hertzler Road, Mechanlcsburg, Cumberland County, Pennsylvania 17055.
2. Defendant is JOHN HOLLAND, an adult Individual whose current mailing address Is
305 Hertzler Road, Mechanlcsburg, Cumberland County, Pennsylvania 17055.
3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months
immediately previous to the filing of this complaint.
4. Plaintiff and Defendant were married on September 23, 1984 in Lackawana County,
Pennsylvania.
COUNT I
5. The averments of Paragraphs 1 through 4 ara incorporated herain in full.
6. There has been no prior action for divorce or annulment between the parties.
7. Plaintiff has been advised of the availability of counseling and the right to request that
the Court require the parties to participate in counseling.
8. Defendant is not a member of the Armed Services.
9. Plaintiff avers that the ground on which the action is based is irretrievable breakdown
of the marriage.
WHEREFORE, Plaintiff requests the court to enter a Decree in Divorce dissolving the
marriage between the parties pursuant to Section 3301(c) of the Divorce Code of 1980, as
amended.
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 97.863 CIVIL TERM
CIVIL ACTION. LAW
IN DIVORCE AND CUSTODY
ROSEMARIE C. HOLLAND,
Plaintiff
JOHN HOLLAND,
Plaintiff
CERTIFICATE OF SERVICE
I, Elizabeth A. Hoffman, Esquire, do hereby certify that a true and correct copy of the
Plaintiffs Answer to Defendant's Counterclaim was sent to the following person by certified mail,
postage prepaid:
John Holland, Esquire
305 Hertzler Road
Mechanicsburg, PA 17055
beth A, Ho man,
At mey for Plaintiff
Supreme CI. ID #71000
2201 North Second Street
Harrisburg, PA 17110
717.236-2956
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13. Paragraph 13 is admitted.
14. Paragraph 14 is admitted.
15. Paragraph 15 is admitted in part that the Plaintiff has for
certain periods served as the child's primary caretaker and
generally tends to scheduling doctor and dentist visits.
Paragraph 15 is admitted further in part that Plaintiff generally
tends to oversee the child's nutritional needs and that
Defendant's job requires his being out of town. Paragraph 15 is
denied in part to the extent that it states a legal conclusion to
which no answer is required. To the extent that an answer is
required, paragraph 15 is denied that the best interests of the
child will be served by granting primary physical custody to the
Plaintiff.
WHEREFORE, The Defendant, John Holland, requests that the
Court grant shared, legal and physical custody to the Defendant.
COUNTERCLAIM
COUNT III - CUSTODY
16. Paragraphs 1 through 15 are incorporated herein by reference
as though set forth in full.
17. Defendant, since the birth of his child has served a
significant role as care-giver of the child, and tended to his
physical care, emotional, psychological, spiritual and
educational needs and well-being.
18. Defendant has provided and continues to provide significant
financial contribution to support his child since his birth.
19. Defendant, for the first two years of his child's life
served as primary care-giver of his child's needs.
20. The bests interest and welfare of the child would best be
served by granting shared, legal and physical custody to the
Defendant.
21. The paramount interest of the child would best be served by
the continuity, stability and security of hi~ needs and
well-being nourished and nurtured by his close relationship with
his father.
WHEREFORE, Defendant requests this Honorable Court to grant
shared, legal and physical custody of the child to the Defendant.
17108-1513
CERTIFICATE OF SERVICE
Tn~ undersigned hereby cercifles that on this 7th day of
April, 1997, a true and correct copy of the foregoing Answer and
Counterclaim was mailed by United States Certified Mail, Return
Receipt Requested, postage prepaid to the following;
Elizabeth A. Hoffman, Esquire
Attorney for Plaintiff
2201 North Second Street
Harrisburg, PA 17110
J. Holl nd,
P. O. Box 11 13
H rrisburg, PA 17108-1513
(717) 774-2331
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