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HomeMy WebLinkAbout01-03808 ,.,> - > ' t'__, L: ,=, Q~ ~ . TINA L. QUENNEVILLE PLAINTIFF V. DAVID J. QUENNEVILLE DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 01-3808 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, Juue 26, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on Tuesday, Jnly 31, 2001 at 9:15 A.M for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to defme and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abnse orders, Special Relief orders, and Custody orders to the couciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Melissa P. Greevy. EsqfJJ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 17013 Telephone (717) 249-3166 ~ ~-'~"it; (, 'j'~T -"f1!il(K~'f ~-':"J-T~'ITI-iL't~:w~;';~"'--; ,>,.,,, ,"" '~-<' :~ ~t"1"ufrij~ll'''tr'~--E ''}'''-; (;)'J.~ - 0/ ? ",)1 -0/ Ii -J-v .tJ / ,,:j'~,.;J ,^",' ""X'", ,,,,"~ _',:.;., '_,",,';"_",' ,~, _'>", , "'''-''~4-~'''_ - ,':'; . ,.i; ,.., ('- ..1 ",I \ j 1 ,; ~ ~ (~ . ht'ld. rq'I", \...rU ,;:J:.:;"LJ"',i\:-) l':O; i~FV I')C"""'VI.\!I'-~";:' " L..r~I'i01 t....'r\i\J,h. w- &n ~ it a1 ~:~ ::::::: ::( ~ - __~~"m;f~J!Ii;,~__~~~iiW . _'. .~IJI!i~lli\tlfl1lf,l;l~"!!'!>,~-!r...%""",;:.;,q~" "'''1'_:;'i:'~l''';~C,-;?, "~"~,-Fi"$;;l1'!\"~ll:'_'7-"_'f)"lt1fS"'!!"'K"'l')"I'''l~iri~IV,!,i\\!!~!'' . ''''''''~' " ~ -, '- -',~. ,- , - '" . , -I" '-'" e - -,; " TINA 1. QUENNEVILLE, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. OI-JP6[' G"o,L~~ DAVID 1. QUENNEVILLE, Defendant : CIVIL ACTION - LAW : CHILD CUSTODY ORDER AND NOW, this _ day of ,2001, in consideration ofthe attached Complaint, it is hereby directed that.the parties and their respective counsel, shall appear before , the Conciliator, on the _ day of ,200l,at_,m.,at for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a Temporary Order. All children age five and older may also be present at the conference. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT: Date: By: Custody Conciliator 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, PAl 70 13 Telephone: (717) 249-3166 ,- ~ '"..~. I.. .." .- .' .,'i j,,--. l v. ", : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. TINA L. QUENNEVILLE, Plaintiff DAVID 1. QUENNEVILLE, 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 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 marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Room 101, Dauphin County Courthouse, Front and Market Streets, Harrisburg, 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 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, P A 17013 Telephone: (717) 249-3166 " TINA 1. QUENNEVILLE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ~ NO. 0 J- 3 go d' e..;;;..t. T~ v. DAVID J. QUENNEVILLE, Defendant : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE 1. The Plaintiff is Tina 1. Quenneville, an adult individual currently residing at 2155 Canterbury Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The Defendant is David J. Quenneville, an adult individual residing at 342 Southwick Road, Apartment 70, Westfield, MA 01085. 3. Defendant has been bona fide resident in the Commonwealth of Pennsylvania, for a period in excess of six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 19, 1995 in Richmond, Virginia. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. This action is not collusive. r. ~ <~ ..I~., . ~ - , ~' .., 7. Plaintiff and Defendant separated on or about December 1 1,2000. 8. The causes of action and sections of the Divorce Code under which Plaintiff is proceeding are: A. Section 330I(c) - The marriage of the parties is irretrievably broken. B. Section 330I(d) - The marriage of the parties is irretrievably broken. The parties separated on or about December 11,2000. C. Section 330I(a)(6) - The Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and her life burdensome. 9. Plaintiff and Defendant have two children under the age of eighteen, namely Trevor Anthony Quenneville, born March 13, 1994, and KaitIyn Marie Quenneville, born August 9,1997. 10. Plaintiff has been advised of the availability of marriage counseling and understands that she may request that her spouse and she participate in counseling. 11. Plaintiff does not request that the Court require that her spouse and she participate in counseling prior to a divorce decree being handed down by this Court. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter a fmal decree in divorce. . ~ ,--, "- ""I ',;' ,- - , - ~, COUNT I CIDLD CUSTODY 12. Paragraphs one through eleven are incorporated herein by reference. 13. The subject children are Trevor Anthony Quenneville, born March 13, 1994, and Kaitlyn Marie Quenneville, born August 9,1997. 14. The relationship of the Plaintiff to the subject minor children is that of natural mother. 15. The relationship of the Defendant to the subject minor children is that of natural father. 16. The minor children have resided at the following addresses, in the custody of the following individuals: a. From April, 1994 to December, 1995 -the subject minor child, Kaitlyn Marie Quenneville, resided at 2411 Hillandale Drive, Midlothian, Virginia, in the care and custody of the Plaintiff and Defendant. b. From December, 1995 to November, 1996 -the subject minor child, Kaitlyn Marie Quenneville, resided at 45 Leslie Lane, Danville, Virginia, in the care and custody of the Plaintiff and Defendant. c. From November, 1996 to April, 1998 - the subject minor children resided at 2626 Broad Street, NW, Roanoke, Virginia, in the care and custody of the Plaintiff and Defendant. d. From April, 1998 to March, 2000 - the subject minor children resided at 1452 Overton Lane, Knoxville, Tennessee, in the care and custody of the Plaintiff and Defendant. ..~ -~ , j"~wk, e. From March, 2000 to December 2000 - the subject minor children resided at 9618 Ashton View Drive, Chattanooga, Tennessee, in the care and custody of the Plaintiff and Defendant. f. From December, 2000 to June 15,2001 - the subject minor children reside at 2155 Canterbury Drive, Mechanicsburg, Cumberland County, Pennsylvania, in the care and custody of the Plaintiff as well as their maternal grandparents, Rita and Don Sherer. g. From June 15,2001 to present, the subject minor children have resided at 5207 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania, in the care and custody of Plaintiff Tina L. Quenneville. 17. There have been no prior actions for custody of the subject minor children in this or any other jurisdiction. 18. The Plaintiff is not aware of the existence of any other individuals who have any type of claim whatsoever regarding the custody of the subject minor children. 19. The Plaintiff believes and therefore avers that she is much better able to meet the needs of the subject minor children than the Defendant. 20. The Plaintiff believes and therefore avers that it is in the best interest of the subject minor children that they be placed in her legal and physical custody. WHEREFORE, Plaintiff requests this Honorable Court award her custody of the subject minor children. - ,_ L~. " "".' ~- > - ~-- ".,~ -'I ~, ALIMONY 21. Paragraphs one through twenty are incorporated herein by reference. 22. Plaintiff lacks sufficient property to provide for her reasonable needs. 23. Plaintiff is unable to sufficiently support herself through appropriate employment. 24. Defendant has sufficient income and assets to provide continuing and indefinite support for the Plaintiff. WHEREFORE, Plaintiff respectfully requests this Honorable Court compel the Defendant to pay alimony to the Plaintiff. {j ,. ~'~,~..l-~' 'I ' _,->,,- _, "'''., ~-.L'~~ "i< ALIMONY PENDENTE LITE. COUNSEL FEES. COSTS AND EXPENSES 25. Paragraphs one through twenty-four are incorporated by reference herein. 26. By reason of the institution of the action to the above term and number, Plaintiff will be and has been put to considerable expense in the preparation of her case, in the employment of counsel, and the payment of costs. 27. The Plaintiff is without sufficient funds to support herself and to meet the costs and expenses of this litigation and is unable to appropriately maintain herself during the pendency ofthis action. 28. The Plaintiff's income is not sufficient to provide for her reasonable needs and pay her attorney's fees and the costs of this litigation. 29. The Defendant has adequate earnings to provide support for the Plaintiff and to pay her counsel fees, costs and expenses. ." , L__ WHEREFORE, Plaintiff respectfully requests this Honorable Court compel the Defendant to pay alimony pendente lite to the Plaintiff and pay her counsel fees, costs and expenses of this action. Date: "/J:J /0 I / / ' Respectfully submitted, THE LAW OFF ES OF SILLIKER & INHOLD Attorney for Plaintiff ,-, ",- AFFIDA VIT I, --=r;" G - C)u P 1\ 'l\1?vi Il~, hereby certifY that the aforegoing is true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. 4909 relating to unsworn falsifications to authorities. Dated: :f.'Af"le 14 ~ QOOI ~h. . Q.. /'to. M..DA}: Lto... ",; I ~ .. '<it; , ~','~-- -- ,,' '< , ,,', ~-,", ,-,..,- -",l ,- -:.fc "." Plaintiff AUG 0 6 2~~\ IN THE COURT OF COMMON PLEAS o~JYvi\ CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3808 .. TINA L. QUENNEVillE, vs. DAVID J. QUENNEVillE, Defendant CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this -?.t- day of August, 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, Tina L. Quenneville and David J. Quenneville, shall have shared legal custody of the minor Children, Trevor Anthony Quenneville, born March 13, 1994, and Kaitlyn Marie Quenneville, born August 9,1997. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of Pa. C. S. 9 5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. Mother shall have primary physical custody of the Children. Father shall have periods of partial custody arranged as follows: A. On two weekends per month, Father shall have custody from 9:00 a.m. until 8:00 p.m. Saturday and from 9:00 a.m. until 4:00 p.m. on Sunday. Father will arrange for Trevor to attend mass on Sunday mornings. When Trevor is able to tolerate separation from his Mother, the parties contemplate that Father's periods of partial custody will be altered to run from Saturday at 9:00 a.m. until Sunday at 4:00 p.m. Father's periods of custody shall occur two weekends per month. The parents will pfan together when those will occur with at least five days notice to Mother. Father shall have additional time with the Children as the parties may agree. Specifically, the parties contemplate a flexible plan for those times when Father may be in town on business. 3. Vacation. To commence 2002, each party shall be entitled to seven continuous days of custody for the purpose of summer vacation. These periods shall run from Saturday to Saturday. As with the weekend and Christmas holiday time, any periods of overnight for Trevor to be away from his Mother shall not be scheduled until there has been sufficient "'" """ ;'--j -" " _ ; -..~:f. ',_ :-,; l ",0,", ~-,- "~~_,'-- . *"~ . No. 01-3808 Civil Term improvement in his anxiety at times of separation from Mother. 4. Christmas. To commence Christmas 2001 and continuing each year thereafter, Father shall have custody for Christmas from December 25th at 11 :00 a.m. until December 27th at 4:00 p.m. 5. This Order is temporary in nature and may be modified upon the agreement of the parties. In the event that the parties cannot agree, the terms of this Order shall control, pending further Order of Court. J. Dist: Kristin Reinhold, Esquire, 5922 Linglestown Road, Harrisburg, PA 17112 "'""". Q","",,",". '" - -. ^""'"'"'''. W"",". MA:;s. ~,1 ',IT 1~'" .-~~,~ ..> n"" "'""'~"'->."'-"',"'~"U ' ., .0 "'..;:-%."..,d "v..;j" ,,'<.',,;. _">O"_X ""^,,',,,' '--""-=,-, o-'>--H,," '''''''''''-',',~'~''~'-'--'''~~'""_""~~",,,,,,,,'" -,.', u"=-_.""->"">>(_,<-,,,,~,,,,,,'_~w._~__,,_ .,~- 1IflIiiIIlIJ~. ~-~- " ,. ~,~~ -,^ ~, c r',,_.(\',:FCE ,U ,,'. ' ,,'r'Rv .'!'" "-'-'~"~1.\~"""I~,h.)\f\\ ,1 , "i'.' '~\''''_] M'I g:t.i 0\ p,\,;h ^ ,<'''It,.,,.) CO\J\-.\Tl v\.kj'?E.NNS'iL\I~N\'" , ~," ,_~iI!';l~r,;"-~i~iW"'1'>e:'i-'!""'C"_"'!'c:('t--"'''''''iHI';rfo'f!~ff',Ifl_~~>J~tlU\_'iii1l\lI"..~~)',\iil\<!t~~i'~t;'~~_' . ""...,;. ,,- ,~ . ',~ <"'_-::tt ,1-;, .I.. , , TINA L. QUENNEVILLE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3808 vs. DAVID J. QUENNEVillE, Defendant CIVIL ACTION - LAW CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Trevor Anthony Quenneville Kaitlyn Marie Quenneville March 13, 1994 August 9,1997 Mother Mother 2. A Custody Conciliation Conference was held on July 31,2001, with the following individuals in attendance: the Mother, Tina L. Quenneville, and her counsel, Kristin R. Reinhold, Esquire; the Father, David J. Quenneville, pro se. 2. The parties reached an agreement in the form of an Order as attached. {~ Dat Melissa Peel Greevy, Esquire Custody Conciliator ." "',,, "" -, 1 ..-" llW.]" j:!;li> TINA L. QUENNEVILLE Plaintiff : THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : DIVORCE DAVID J. QUENNEVILLE : NO. 01-3808 Defendant DEFENDANT'S ANSWER TO PLAINTIFF'S DIVORCE COMPLAINT AND NOW comes Defendant, David J. Quenneville, by and through his attorneys, Charles O. Barto, Jr. and Associates, and answers the Complaint in Divorce as follows: 1. ADMITTED. 2. DENIED. Defendant is an adult individual residing at 440 North Street, Apt. 21, Pittsfield, MA 01201. 3. ADMITTED. 4. ADMITTED. 5. ADMITTED. 6. ADMITTED. 7. ADMITTED. 8. DENIED. This paragraph contains conclusions of law to which no responsive pleading is required. To the extent this paragraph is deemed to contain factual averments, they are specifically DENIED. Strict proof at trial demanded. ~.- > - . . -.! ~~,'" , - ,,"-, , ".rr~",:""",""""",'f,, -. h~~. "'llli; 9. ADMITTED. 10. Defendant is without sufficient information or belief as to the truth of this averment and it is therefore denied. Strict proof at trial demanded. 11. Defendant is without sufficient information or belief as to the truth of this averment and it is therefore denied. Strict proof at trial demanded. The WHEREFORE clause is a request for relief based on conclusions of law to which no response is required. To the extent that a response is deemed necessary, Defendant denies that Plaintiff is entitled to the relief requested. 12. Responses one (1) through eleven (11) are incorporated herein by reference as set forth in full. 13. Paragraph's thirteen (13) through seventeen (17) of Plaintiffs complaint are ADMITTED. 14. Defendant is without sufficient information or belief as to the truth of this averment, Plaintiffs 1118, and it is therefore denied. Strict proof at trial demanded. 15. Plaintiffs paragraphs nineteen (19) and twenty (20) are DENIED. Strict proof at trial demanded. The WHEREFORE clause is a request for relief based on conclusions of law to which no response is required. To the extent that a response is deemed necessary, Defendant denies that Plaintiff is entitled to the relief requested. 16. Responses one (1) through fifteen (15) are incorporated herein by reference as set forth in full. -, , '-,,' '--'""i' -.,- . '0; "" ""i --,'~,L"",w, ~di; 17. Paragraph's twenty-two (22) through twenty-four (24) are specifically DENIED. Strict proof at trial demanded. The WHEREFORE clause is a request for relief based on conclusions of law to which no response is required. To the extent that a response is deemed necessary, Defendant denies that Plaintiff is entitled to the relief requested. 18. Responses one (1) through seventeen (17) are incorporated herein by reference as set forth in full. 19. Paragraph's twenty-six (26) through twenty-nine (29) are specifically DENIED. Strict proof at trial demanded. The WHEREFORE clause is a request for relief based on conclusions of law to which no response is required. To the extent that a response is deemed necessary, Defendant denies that Plaintiff is entitled to the relief requested. Respectfully submitted, CHARLES O. BARTO, JR. AND ASSOCIATES Date: <;?- J. b- 0 ') BY:~Th tv /~ ~ Peter W. Kociolek, Jr., Esquire (Attorney for Defendant) 608 North Third Street Harrisburg, Pennsylvania 17101 (717) 236-6257 Attorney I.D. No. 67597 , " "~" ' , ~'~ 0<' >"_,",, _ , . ", ,'-" """"~ ;"" ",,,::',,U VERIFICATION I verify that the statements made in this Answer are true and correct. I understand that false statement$ herein are made subject to the penalties of 18 Pa.C. S. Section 4904. relating to unsworn falsification to authorities. ~~. 09- David J. Quenneville Date:~ fJ~0~J. PeterW. Kociolek. Jr., EsqUire Attorney for Defendant 608 North Third Street Harrisburg, Pennsylvania 17101 (717) 236-6257 Attorney 1.0. No. 67597 ,~ - ..c, , ~"' ,'." - - , ;;;'ii";' . I" -~,: TINA L. QUENNEVILLE : THE COURT OF COMMON PLEAS : CUMBERI,..AND COUNTY, PENNSYLVANIA Plaintiff v. : CIVIL ACTION - LAW : DIVORCE DAVID J. QUENNEVILLE NO. 01-3808 Defendant CERTIFICATE OF SERVICE I, Peter W. Kociolek, Jr., Esquire, hereby certify that I have this 26th of August, 2003, served in the manner set forth below, a true and correct copy ofthe Answer to Petition to Request Counseling to the following: U.S. REGULAR MAIL: Kristen R. Reinhold, Esquire 5922 Linglestown Road Harrisburg, PA 17112 CHARLES O. BARTO, JR. AND ASSOCIATES g~:~~ (Attorney for Defendant) 608 North Third Street Harrisburg, PA 17101 (717) 236-6257 Attorney 1.0. No. 67597 ".""_0' C"k'-"""- ,-~,._'"", '''~;'3,"",,,,~_,,iI'W~~~~,,,,,,hiiJ.~'1b;;'~"l\i!!l%!~!lljI-- r-.... ~ _ ~ \:::_0 ;::;;-.....: ~ ~~ ~~ ~~ \~ ~~. ~ E Cl. ............ ~~~ ~ ~ -_"""'"'~~""_':0'_[lfL" ,,,,<~.",,,-.._,_,.,k.,,",,,,,._! '",PC'kJl , JlJJ."J~L~""".-"".,)1..",Ml),,,,!,~,~..;l:f,",,,,et If",~:~,;/;1l~,,.;!>>~g,,,- -.Ll. '. I_<:r. ,{. d, !~~"~;)"iPf''."=:-<::;,, '-",~F ,~ _, '>i;",'.t".~"~)HrL~,,~,!"',,,:~!L~.,!",L ;""{,,",.-~~.J.,,,",u, J;,l, ~,~ ',,_ ~P>_U;:" l~r , ~'_<;;1 , . , L '."~~ ,.L_""':':)<j,.! TINA l. QUENNEVILLE : THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : CIVIL ACTION - LAW : DIVORCE DAVID J. QUENNEVILLE : NO. 01.3808 Defendant DEFENDANT'S ANSWER TO PLAINTIFF'S DIVORCE COMPLAINT AND NOW comes Defendant, David J. Quenneville, by and through his attorneys, Charles O. Barto, Jr. and Associates, and answers the Complaint in Divorce as follows: 1. ADMITTED. 2. DENIED. Defendant is an adult individual residing at 440 North Street, Apt. 21, Pittsfield, MA01201. 3. ADMITTED. 4. ADMITTED. 5. ADMITTED. 6. ADMITTED. 7. ADMITTED. 8. DENIED. This paragraph contains conclusions of law to which no responsive pleading is required. To the extent this paragraph is deemed to contain factual averments, they are specifically DENIED. Strict proof at trial demanded. ""- ," . l~>.~, ~-_.j; 9. ADMITTED. 10. Defendant is without sufficient information or belief as to the truth of this averment and it is therefore denied. Strict proof at trial demanded. 11. Defendant is without sufficient information or belief as to the truth of this averment and it is therefore denied. Strict proof at trial demanded. The WHEREFORE clause is a request for relief based on conclusions of law to which no responSe is required. To the extent that a response is deemed necessary, Defendant denies that Plaintiff is entitled to the relief requested. 12. Responses ,one (1) through eleven (11) are incorporated herein by reference as set forth .in full. 13. Paragraph's thirteen (13)through seventeen (17) of Plaintiffs complaint are ADMITTED. 14. Defendant is without sufficient information or belief as to the truth of this averment, Plaintiffs 1118, and it is therefore denied. Strict proof at trial demanded. 15. Plaintiffs paragraphs nineteen (19) and twenty (20) are DENIED. Strict proof at trial demanded. The WHEREFORE clause is a request for relief based on conclusions of law to which no response is required. To the extent that a response is deemed necessary, Defendant denies that Plaintiff is entitled to the relief requested. 16. Responses one (1) through fifteen (15) are incorporated herein by reference as set forth in full. =~~ ',~l 17. Paragraph's twenty-two (22) through twenty-four (24) are specifically DENIED. Strict proof at trial demanded. The WHEREFORE clause is a request for relief based on conclusions of law to which no response is required. To the extent that a response is deemed necessary, Defendant denies that Plaintiff is entitled to the relief requested. 18. Responses one (1) through seventeen (17) are incorporated herein by reference as set forth in full. 19. Paragraph's twenty-six (26) through twenty-nine (29) are specifically DENIED. Strict proof at trial demanded. The WHEREFORE clause is a request for relief based on conclusions of law to which no response is required. To the extent that a response is deemed necessary, Defendant denies that Plaintiff is entitled to the relief requested. Respectfully submitted, CHARLES O. BARTO, JR. AND ASSOCIATES Date: <is -:2 b- 0 ') By:_gilAtv/~ ~ Peter W. Kociolek, Jr., Esquire (Attorney for Defendant) 608 North Third Street Harrisburg, Pennsylvania 17101 (717) 236-6257 Attorney 1.0. No. 67597 "~, VERIFICATION I verifY that the statements made in this Answer are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ~~..O9- David J. Quenneville Date: sf -zxl 0-'( fJ~0~J. Peter W. Kociolek. Jr., EsqUire Attorney for Defendant 608 North Third Street Harrisburg, Pennsylvania 17101 (717) 236-6257 Attorney 1.0. No. 67597 ..,-' , ~.~ "~""" I,___",j_ TINA L. QUENNEVILLE : THE COURT OF COMMON PLEAS : CUMBERtAND COUNTY, PENNSYLVANIA Plaintiff v. : CIVIL ACTION - LAW : DIVORCE DAVID J. QUENNEVILLE : NO. 01-3808 Defendant CERTIFICATE OF SERVICE I, Peter W. Kociolek, Jr., Esquire, hereby certify that I have this 26th of August, 2003, served in the manner set forth below, a true and correct copy of the Answer to Petition to Request Counseling to the following: U.S. REGULAR MAIL: Kristen R. Reinhold, Esquire 5922 Linglestown Road Harrisburg, PA 17112 CHARLES O. BARTO, JR. AND ASSOCIATES e.~L_~ J eter W. Kociolek, Jr., Esquire (Attorney for Defendant) 608 North Third Street Harrisburg, PA 17101 (717) 236-6257 Attorney 1.0. No. 67597 :~~__~~.-:!lltiibiJ-i~,j!i1\lf'OOOl!!!ofuiB';iiu;[1!-""!i'-f""':;;"f'<,jIH--:"-""r"'h"iwwj!licii~ii'""><~~"~--l ,J., '''H",,''~''l.,. >' f"- IiltlW'til!1i&lr~~~' ~ o ~ -o~~ 9.2['r, "") zE"- (/')d;: -C,_ 1':'.'-' ~~\_.J ):":,--- ~~~ ~:::i ~.-c ~ , ,,~,',," ,_~" ~ ,'~ '~':,,"_"" ""'".." ,,,,,,,,,,.,~ ,"- ,",~~,_"!"",,,,~,,.,'''',',~'''~/t,,,,,~,; ':'; '<"~_~:" ~.~ ~'C~ f,,'_,,"',,_c,'~f'f"t' :'h. ff_r'" "'.'C:::C:~-,'ii-,'~" ,', _'"_,,',,_~r_',_~__,''' ~ '~~" .'_,,=~_'~~ r, o -(,,) ~ a=) f') co o -n ":;:.1 , " "'i:;-";;: _fTi J? ()" -) i~~ --, p 3! ~~:, -',,~ r:y (1\ - ---,-,~.,.