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Home My WebLink About97-03268 ~ u 3 qj 11 I/) '::> - - \l 3 ~ 11 I I I j 1 \ \ '-... ',----- , / t ... ~ - . . .:) 0- ..J ~ "') , t"- \)" o <- IN TilE COURT OF COMMON PLEAS OF ClIMBERLAND COUNTY, PENNSYLVANIA PlaintilT vs CIVIL ACTION - LAW NUMBER: Q'l-3,{l..r) CIVIL TERM IN DIVORCE Defendant I I ! You have been sued in court, If you wish to defend against the claims set forth in the following i: pages, you must take prompt action, You arc warned that if you fail to do so, the case may i ! proceed without you and a decrec of divorcc or annulment may 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 NOTICE TO DEFEND AND CLAIM RIGIITS When the ground for the 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 the Cumberland County Courthouse, One South Hanover Street, Carlisle, ; Pennsylvania, 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. (7(7) SU-.N7'6' Court Administrator Fourth Floor Cumberland County Courthouse Carlisle, PA 17013 Telephone: (717) 240-6200 By _SZL/JLIl-_Ji1) .,'-t[<- Sally J. Win/fr Attorney for Plain tilT 701 E. King Street Shippensburg, PA 17257 :1.., ~ff'" 'f ,1/,//, r>f "11;'...1.. ""f-,,_,),,~, .'It...... .'4,;0-./_.., ,:'.'.( Ob, PATRICIA A. FARWELL. II , IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA Plaintiff vs CIVIL ACTION - LAW NUMBER:97.J..U.~ CIVIL TERM I I DANIEL C. FARWELL. I I I I , I I IN DIVORCE Defendant COMPLAINT IN DIVORCE COMES NOW. the Plaintiff. PATRICIA A. FARWELL, by and through her counsel, I ! Sally J. Winder. Esquire, and rcpresents as follows I. PlaintilTis PATRICIA A. FARWELL, who currently resides at, and whose mailing I' , , address is, 1750 Walnut Bottom Road, Newville, Penn Township, Cumberland County, : Pennsylvania, sincc 1984, 2. Defendant is DANIEL C. FARWELL. who currently resides at, and whose mailing , , . address is, 1750 Walnut Bottom Road, Newville, Penn Township, Cumberland County. Pennsylvania. since 1984, 3, Both PlaintilTand Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint 4 TIle Plamtlff and Defendant were married on February IS, 1971, at Hagerstown, Maryland, 5, There have been no pri..r actions of divorce or for annulment between the parties, 6 The marri~ge is irretricvably broken II 'I 7, PlaintilTavers that she has been advised of the availability of counseling sessions for ] both parties upon request of either party or by order of court, and that a list of qualified , I professionals who provide such counseling service is available at the Domestic Relations Ofiice : I upon request. By the filing of this Complaint, the PlaintilT acknowledges having been advised by I ! her attorney llfrecord of the availability of counseling sessions and ofa list of qualified I i professionals, PlaintilT further avers that she has been advised that the choice of a qualified I professional shall be a, the option of the PlaintilTand Defendant and need not be selected from the i ! : list available upon request and, further, that arrangements for and the payment of the services of i : the qualified professional shall be the responsibility of the parties and will not be included in the ; : docket costs of this proceeding .: 8, PlaintilT requests the Court to enter a decree of divorce, COUNT II " CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER THE DIVORCE CODE 9, PlaintilTand defendant are owners of various tracts of real estate in Penn Township, , : Cumberland County, Pennsylvania, which is subject to equitable distribution by this Court, 10, Plaintifl"and defendant are the owners of various items of personal property, furniture and household furnishings acquired during their marriage which are subject to equitable distribution by this Court II. Plaintiff and defendant are the owners of various motor vehicles acquired during their marriage which are subject to equitable distribution by this Court. I WHEREFORE, Plaintiff requests the Court to enter a decree dissolving the marriage I between plaintiff and defendant and equitable distributing property owned by the parties hereto, II and for such other relief as the Court may determine equitable and just, I, II COlJNT III !i II CLAIM FOR ALIMONY PENDENTE LITE, ALIMONY, COlJNSEL FEES. EXPENSES i II AND COSTS il !i i i 12, Plaintiff by reason of defendant's conduct has been put and will be put to considerable II " f ! expense in the employment of counsel, and the payment of expenses and costs as a result of this action, II I , " ~ ! :r 13, PATRICIA A. FARWELL is employed at present but is without sufficient funds to i i meet the costs and expenses of this litigation, including filing fees and the required deposit for I ' appointment of a Master and counsel fees for representation in connection with equitable I : distribution, counsel fees, expenses, costs, :: i I 14, Plaintiff, PATRICIA A, FARWELL, has incurred and will incur extraordinary ;i " i expenses at the instigation of defendant. Plaintiff, PATRICIA A. FARWELL, has now been , required to retain counsel in order to assert her rights pursuant to the Divorce Code, 15, Defendant, DANIEL C. FARWELL is presently self-employed in a fann partnership , in Penn Township, Cumberland County, Pennsylvania, Defendant has sufficient income and assets to assist in the support and maintenance of plaintiff as well as pay legal fees and costs, VERIFICATION [ veritY that the statements made in this complaint are true and correct to the best of my personal knowledge and belief. [understand that false statements herein are made subject to the penalties of [8 Pa. C.S, Section 4904, relating to unsworn falsification to authorities, I Date: (./"/11 ( I --A~1:-z..4'~_ II, "=1-c'-l-{,<-~c.e PATRICIA A. FARWELL I I ,I II Ii :1 'I I i ,I I' 'I " , i , , II 'I I " " :! Ii I' I i, :! " , FIJ'II.E!NIATAfll.E\t.iENIXX''l1\1I1101PRA IlIdw ('lUled M&'9111 ~91S AM Reviled 0lYlr.'9111 5101 AM PATRICIA A, FARWELL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, NO, 97-3268 CIVIL ACTION - LAW DANIEL C, FARWELL, Defendant IN DIVORCE PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTSON, DEARDORFF, WILLIAMS & OTTO in behalf of Defendant Daniel C. Farwell in the above matter. MARTS ON, DEARDORFF, WILLIAMS & OTTO By -rL)~~ Thomas 1. Wilr.ams, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Dated: June 27, 1997