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Home My WebLink About03-2049ANGELA M. FASICK, PLAINTIFF DAVIE W. FASICK, DEFENDANT IN THE COURT OF COI~ON PLEAS CE~EPJ~%~) COUNTY, PENNSYLVANIA NO. 2003 - ~0Vq CIVIL TEI~M 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 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 is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator's Office, Fourth floor, Cumberland County Courthouse, Hanover and High Streets, Carlisle, Pennsylvania. 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 ANGELA M. FASICK, PLAINTIFF DAVIE W. FASICK, DEFENDANT IN THE COURT OF COt~)N PLEAS C~EPJ~d~D COUNTY, PENNSYLVANIA NO. 2003 - ~o~ CIVIL TERM IN DIVORCE C0t~PLAINTUNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE 1. The Plaintiff is Angela M. Fasick who resides at 51 Spur Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Davie W. Fasick who resides at 519 St Marys Drive, Steelton, Dauphin County, Pennsylvania 17113. 3. The Plaintiff and Defendant have been bonafide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 24, 1981 in Hagerstown, Maryland. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. Plaintiff requests the court to enter a decree of divorce. CLAIM I Claim for Equitable Distribution of Marital Property Paragraphs 1-9 are incorporated herein by reference The Plaintiff and Defendant are owners of certain jointly or other property which constitutes marital 10. hereto. 11. owned property property. WHEREFORE, Angela M. Fasick requests this Court to enter an Order equitably dividing or assigning the marital property between the parties. 12. hereto. 13. CLAIM II Claim for Alimony, Alimony Penclente Lite, Spousal Support Paragraphs 1-11 are incorporated herein by reference Angela M. Fasick is without sufficient income and/or assets to support herself or pay attorney fees and is unable to fully support herself through appropriate employment. 14. Angela M. Fasick requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. WHEREFORE Angela M. Fasick requests this Honorable court to enter an award of reasonable temporary or permanent support, alimony, APL and additional sums as they may become necessary from time to time hereafter until final hearing and permanently thereafter for costs related to this action. Thomas D. Gould Attorney for Plaintiff I.D. 9 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Date: ~/~0\0~ Angel~M. Fasick ANGELA M. FASICK, PLAINTIFF Ve DAVIE W. FASICK, DEFENDANT IN THE COURT OF COI~)N PLEAS CE~ERLAI~D COUNTY, PENNSYLVANIA NO. 2003 - ~0~9 CIVIL TERM IN DIVORCE pETITION FoR ALII~ONY PENDENTE LITE 1. The Petitioner is Angela M. Fasick who resides at 51 Spur Road, Carlisle, cumberland County, Pennsylvania 17013. 2. The Respondent is Davie W. Fasick who resides at 519 St Marys Drive, Steelton, Dauphin County, Pennsylvania 17113. 3. The Petitioner was born on April 6, 1964 and her social security number is 020-48-8752. 4. The Respondent was born on July 10, 1962 and his social security number is 201-50-1451- 5. Petitioner filed a Complaint in Divorce on April 30, 2003 in which she claimed a right to APL. WHEREFORE, Petitioner requests that Respondent be order to pay her APL as required by the laws of Pennsylvania- Thomas D. Gould Attorney for Petitioner I.D. % 36508 2 East Main Street shiremanstown, PA 17011 (717) 731-1461 VERIFICATION I verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Date:~O~ Angela M. Fasick ANGELA M. FASICK, PLAINTIFF DAVIE W. FASICK, DEFENDANT IN THE COURT OF CO~ON P?.~-~S CUMBERLAND COUNTY, PENNSFLVANIA NO. 2003 IN DIVORCE PETITION FOR ALIMONX PENDENTE LITE CML TERM The Petitioner Angela M. Fasick who resides at ~1 ~ur~ is Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Respondent is Davie W. Fasick who resides at 519 St Marys Drive, Steelton, Dauphin County, Pennsylvania 17113. 3. The Petitioner was born on April 6, 1964 and her social security number is 020-48-8752. 4. The Respondent was born on July 10, 1962 and his social security number is 201-50-1451. 5. Petitioner filed a Complaint in Divorce on April 30, 2003 in which she claimed a right to APL. WHEREFORE, Petitioner requests that Respondent be order to pay her APL as required by the laws of Pennsylvania. Thomas D. Gould Attorney for Petitioner I.D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 7211-1461 DARYL STRICK, Appellant Vo COMMONWEALTH OF PENNSYLVANIA, PENNSYLVANIA DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING, Appellee : IN THE COUR~I' OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 02-5049 : : LICENSE SUSPENSION APPEAL SECOND PETITION FOR GRANT OF SUPERSEDEAS AND NOW, comes Daryl Strick by and through his privately retained counsel, Karl E. Rominger, Esquire and in support of his Petition for Grant of Supersedeas avers as follows: 1. Your Petitioner filed an appeal from a December 17, 2002, Order quashing his appeal in the above captioned matter. 2. The Honorable Wesley J. Oler produced a Rule 1925 (b) Opinion explaining why the Court granted the quash. 3. On February 7, 2003, the Commonwealth Court issued an Opinion in Waterson v. Commonwealth of Pennsylvania Department of Transportation, 1055 CD 2002, a copy of which is attached as Exhibit "A". 4. This authority of the Commonwealth Court is in direct opposition to the Trial Judge's Opinion and reasoning for the quash. 5. It is now extremely likely that Petitioner will win his appeal in the Commonwealth Court. 6. Your Petitioner continues to be without a driver's license because of the conditions imposed by Penn DOT and previously complained of. 7. Equity requires that this Court grant a Supersedeas which it is empowered to do, by the Pennsylvania Rules of Appellate Procedure, pursuant to Rule 1701(1). 8. The first Order of Supersedeas was granted on Marc]h 25, 2003. 9. The Department of Transportation interprets the Order as not requiring an issuance of a driver's license. 10. Petitioner now seeks a Court Order clarifying the original Order and an Order directing the Department of Transportation to forthwith reissue a regular driver's license to Petitioner. WHEREFORE, Defendant respectfully requests that this Honorable Court grant an Order of Supersedeas and order that Penn DOT provide Defendant with a Pennsylvania driver's license without the ignition interlock requirements pending disposition of his appeal on the above captioned matter now pending in front of the Commonwealth Court. Respectfully submitted, ROMINGER & BAYLEY Karl E. Rorainger, Esquire 155 South Hanover Street Carlisle, PAL 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Petitioner Date: 6/26/03 DARYL STRICK, Appellant COMMONWEALTH OF PENNSYLVANIA, PENNSYLVANIA DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING, Appellee IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 02-5049 LICENSE SUSPENSION APPEAL CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Defendant, do hereby certify that I this day served a copy of the Second Petition for Grant of Supersedeas upon the following by depositing same in the United States Mail, first class postage prepaid, at C~arlisle, Pennsylvania, addressed as follows: George Kabusk, Esquire PA Department of Transportation, Office of Chief Cotmsel, Third Floor, Riveffront Office ,Center, Harrisburg, PA 17104-2516 Dated: 6/26/03 Karl E. Re,minger, Esquire Attorney for Petitioner