HomeMy WebLinkAbout00-06845
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BRENDA K. ALLANDER,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 2000-6PJ,(S Civil Term
RONALD L. ALLANDER,
Defendant
: CIVIL ACTION - LAW
: IN 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 and a decree of divorce or aunulment may
be entered against you by the court. Ajudgment 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 the divorce is indignities or irretrievable breakdown of
marriage, you must request marriage counseling, A list of marriage counselors is available
in the Office of the Prothonotary at
CUMBERLAND COUNTY COURTHOUSE
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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA l7013
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MAX J. SMITH, JR., squire
Attorney for Plaintiff
P.O, Box 650
Hershey, P A l7033
(7l7) 533-3280
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BRENDA K. ALLANDER,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
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: NO. 2000- (. t $'1> Civil
RONALD L. ALLANDER,
Defendant
CIVIL ACTION - LAW
: IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the Plaintiff, BRENDA K, ALLANDER, by her attorney, MAX J.
SMITH, JR., Esquire, and seeks to obtain a Decree in Divorce upon the grounds hereinafter more
fully set forth:
l, The Plaintiff, BRENDA K. ALLANDER, is an adult individual and citizen of the
United States of America, whose address is 12 Windsor Way, Camp Hill, Cumberland County,
Pennsylvania 17011.
2, The Defendant, RONALD L. ALLANDER, is an adult individual and citizen of the
United States of America, whose address is 143 Lee Ann Court, Enola, Cumberland County,
Pennsylvania 17025,
3. Plaintiff and Defendant have been bona fide residents in 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 or about May 6, 1989 in Hershey,
Pennsylvania.
5, Plaintiff avers that there are three children of the parties under the age of l8,
namely: Taryn L. Allander, born August 30, 1993, Trevor L. Allander, born August 25, 1994 and
Kiersten L. Allander, born July 2l, 1997.
6, Neither Plaintiff nor Defendant is a member of the United States Armed Services,
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7, Plaintiff and Defendant have both been advised of the availability of marital
counseling and that each may have the right to request that the court require the parties to
participate in co unseling,
8, Plaintiff avers that there has been no prior action for divorce or annulment of
the marriage med by either party in this or any other jurisdiction.
9, Plaintiff avers that the marriage is irretrievably broken, pursuant to Section
330l(c) of The PelU1sylvania Divorce Code Act 206 of 1990,
10. Defendant has offered such indignities to the Plaintiff, the innocent and injured
spouse, as to render her condition intolerable and life burdensome, pursuant to SteCtion 330l(a)(6)
of The PelU1sylvania Divorce Code Act 206 of 1990.
ll. This action is not collusive.
WHEREFORE, Plaintiff prays your Honorable Court to enter a Decree of Divorce from
the bonds of matrimony,
COUNT II - EQUITABLE DISTRIBUTION
12. Paragraphs one (I) through eleven (11) are incorporated herein by reference as
though set forth in full.
13. Plaintiff and Defendant have legally and beneficially acquired property, both real
and personal, during their marriage, which property is "marital property" ,
14, Plaintiff and Defendant may have owned prior to the marriage property, both real
and personal, which property has increased in value during the marriage and/or which has been
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exchanged for other property, which has increased in value during the marriage, all of which is
"marital property",
15, Plaintiff and Defendant have been unable to agree as to an equitable division of
said property to the date of the filing of this Complaint.
WHEREFORE, Plaintiff requests the Court to equitably divide all marital property.
COUNT III - ALIMONY
16, Paragraphs one (l) through fifteen (l5) are incorporated herein by reference as
though set forth in full,
l7. Plaintiff lacks sufficient property to pro vide for her reasonable means and is unable
to adequately support herself through appropriate employment.
l8, Plaintiff requests reasonable support to adeqnately maintain herself in accordance
with the standard of living established during the marriage,
WHEREFORE, Plaintiff requests the Court to enter an award of reasonable temporary
alimony and additional sums as they may become necessary from time to time hereafter until final
hearing and permanently thereafter.
COUNT IV - ALIMONY PENDENTE LITE. COUNSEL FEES AND EXPENSES
19. Paragraphs one (1) through eighteen (18) are incorporated herein by reference as
though set forth in full,
20. Plaintiff is without adequate funds to pay the costs and expenses of this litigation,
and is, likewise, without funds to maintain herself during the pendency of this litigation.
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WHEREFORE, Plaintiff requests the Court to enter an Order requiring Defendant to pay
Plaintiff alimony pendente lite, counsel fees an~~(~=' of "" J;ti"tinn.
Dated: October -=L, 2000 UJ f/H
MAX J. SMITH, ., Esqurre
James, Smith, Durkin & Connelly LLP
P,O. Box 650
Hershey, P A l7033
(717) 533,3280
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I verify that the statements made in this Complaint are true and correct. I under-
stand that false statements herein are made subject to the penalties of 18 Pa, C,S, Section
4904, relating to unsworn falsification to authorities.
Pm Jtfl 11) j{, () J J 0-fI.-dJA)
BRENDA K. ALLANDER
Hl05,157 REV. 5-91
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COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF HEALTH
VITAL RECORDS
COUNTY
STATE FILE NUMBER
Cumberland
DIVORCE
[K]
RECORD OF
OR ANNULMENT
(CHECK ONE) 0
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STATE ALE DATE
1, NAME
HUSBAND
3. RESIDENCE:
5. NUMBER
OFTHIS
MARRIAGE
8, MAIDEN NAME
Benner
10, RESIDENCI:
(First)
Ronald
StreetorR.O.
1
(Rrst)
Brenda
Street or R.O.
12 Windsor
12. NUMBER
OFTHIS
MARRIAGE
15. PLACE OF
THIS
MARRIAGE
17A. NUMBER OF
CHILDREN THIS
MARRIAQE 3
20. NUMBER OF
CHILDREN TO
CUSTODY OF
22. . DATE OF DECREE
24. SIGNATURE OF
TRANSCRI'BING CLERK
Way,
1
(Middfej
L.
(Last)
Allander
(Month)
09
City, Boro. or Twp. County
SIBle
2. DATE
OF
BIRTH
4. PLACE
OF
BIRTH
7. USUAL OCCUPATION
(State or Foreign Country)
Pennsylvania
City, Bora. or Twp.
(Middle)
K.
(County)
Perry
7B. NUMBER OF DEPENDENT
CHILDREN UNDER 18.
BLACK
o
BLACK
o
Account Executive
(Osy)
03
(Year)
1965
(Dsy)
11
(Sf1iIte or Foreign Count/}';I
(Vear)
1964
HUSBAND
o
(Month)
3
WIFE
o
(Dsy)
WIFE
(Last)
(Month)
Penns Ivania
(Day)
(Year)
County
State
9, DATE
OF
BIRTH
11. PLACE
OF
BIRTH
14. USUAL OCCUPATION
12
06:0 1989
WlFE
51
OTHEH (Specify)
o
Allander
Cumberland,
PA
(Dsy)
-I;~ni ti es
fYea
Registered Nurse
(Sf1iIte or Foreign Country) 16. DATE OF (Month)
THIS
MARRIAGE 05
9. DECREE GRANTED TO
HUSBAND
o
Pennsylvania
PLAINTIFF
HUSBAND
o
WIFE
~
OTHER (Specify)
o
OTHER (Specify)
21. LEGAL GROUNDS FOR
DIVORCE OR ANNULMENT
o
o
23. DATE REPORT seNT
TO VITAL RECORDS
(Month)
(Yssr)
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