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Home My WebLink About97-02779 J -q ( .\) ... ~ , ~ \ I ~ 4- --Q ( .\J ... . ~ 0'" ( "'\ \ ! / I i i I I - I ! i I i I i ! , , i I MAXINE KAY LEWIS, ESQUIRE Attorney I.D. #33085 1101 North Front Street Harrisburg, PA 17102 (717 234-3136 Attorney for Plaintiff BEVERLY D. ZIEMBA, , IN THE COURT OF COMMON PLEAS , Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . v. , No,e17r )- T1:.1vil , STANLEY C. ZIEMBA, Defendant , CIVIL LAW - DIVORCE , 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, a~d 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 is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at: Cumberland County Courthouse One 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'S OFFICE FOURTH FLOOR CUMBERLAND COUNTY COURTHOUSE One Courthouse Square carlisle, PA 17013 (717) 240-6200 5, There have been no prior actions of divorce or for annulment between the parties. 6, The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling, WHEREFORE, Plaintiff respectfully requests this Court to enter a Decree of Divorce pursuant to S 3301(a) of the Domestic Relations Code, COUNT II Reauest for a Fault Divorce under ~ 3301(al of the Domestic Relations Code 8, Plaintiff hereby incorporates Paragraphs 1 through 7 of her Complaint as if fully set forth herein, 9, Defendant has offered such indignities to Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome, WHEREFORE, Plaintiff respectfully requests this Court to enter a Decree of Divorce pursuant to S 3301(a) of the Domestic Relations Code, COUNT III Reauest for Eauitable Distribution of Marital Procertv Under ~3502 of the Domestic Relations Code 10. Plaintiff hereby incorporates Paragraphs 1 through 9 of her Complaint as if fully set forth herein. -2- 11, The parties are owners of marital property subject to equitable distribution. 12, Plaintiff requests the Court to equitably divide, 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, Plaintiff 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 IV Reouest for Alimonv/Alimonv Pendente Lite Under ~~ 3701 & 3702 of the Domestic Relations Code 13, Plaintiff hereby incorporates Paragraphs 1 through 12 of her Complaint as if fully set forth herein, 14, Plaintiff lacks sufficient property to provide for her reasonable needs and is unable to fully support herself through appropriate employment. 15, Plaintiff requests the Court to enter an award of reasonable temporary alimony in the event the parties cannot resolve their marital disputes so that Plaintiff may be on par with Defendant in litigating her claims. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order of temporary and final alimony in -3- her favor pursuant to 553701 and 3702 of the Domestic Relations Code, Count V Reouest for Interim and Final Counsel Fees. Costs and Excenses Under ~3702 of the Domestic Relations Code 16, Plaintiff hereby incorporates Paragraphs 1 through 15 of her Complaint as if fully set forth herein. 17, Plaintiff has employed Maxine Kay Lewis, Esquire to represent her in this matrimonial cause, 18. Plaintiff is unable to pay all the expected counsel fees, costs and expenses in this action and avers that Defendant is more able to pay these fees, costs and expenses, 19, Plaintiff avers that she cannot be on par with Defendant in this litigation unless this Court orders Defendant to pay Plaintiff's reasonable interim counsel fees, costs and expenses, WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order directing Defendant to pay Plaintiff's reasonable interim and final counsel fees, costs and expenses pursuant to 53702 of the Domestic Relations Code, COUNT VI Reouest for Accroval of anv Settlement Aoreement and Incorcoration Thereof in Divorce Decree 20, Plaintiff hereby incorporates Paragraphs 1 through 19 of her Complaint as if fully set forth herein, -4- (~ , ....... "----- ~ 0 ,- p . , ("' .:;. ~.-,: UI... t.)' r' -' L' -' .> ,I. " C,l ~. I ~;~ It. ' CY ,-, rfJ UJ ,. "" ft~: : ~.. "',; i _-0" j !~)J - :;0.: ,u.. 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