Loading...
HomeMy WebLinkAbout99-00942 ~ l!) f::: cr, C\; '>, ,- r.-- N 5~~ U.! ~:~..! (.J c '".J ;i( G: L~ , :.L. "-~\ ::J (~.\ '.::J -<F;) C.... <:'") .:'j ;,: I , , 'c;:;.. , '-' "hD '-, lu :{In... ,-- a ~-:f I~- N ::> C) ':::J () KAREN E, HOLLINGER, Plaintiff ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. '11, '1'/'lJ CIVIL TERM IN DIVORCE BRADFORD L. HOLLINGER, Defendant NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. i I i I ! I i I I I f I I , I , ./ :1 ' I ! ,i ;(. KAREN E. HOLLINGER, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND ) COUNTY, ) PENNSYLVANIA vs. ) ) CIVIL ACTION - LAW ) BRADFORD L. HOLLINGER, ) NO. C)q, 'l'/.2.- CIVIL TERM Defendant ) IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, KAREN E. HOLLINGER, by her attorney, Samuel L Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is KAREN E. HOLLINGER, an adult individual who currently resides at 500 Arlington Road in Camp Hill, Cumberland County, Pennsylvania. 2, The Defendant is BRADFORD L. HOLLINGER, an adult individual who resides in Camp Hill, Cumberland County, Pennsylvania. 3. Both the Plaintiff and 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. The Plaintiff and Defendant were married on 24 September 1977 in Washington, D.C. 5, There have been no prior actions of divorce or annulment between the I Ii parties. 6. This marriage is irretrievably broken. II 12. The Defendant is employed and enjoys a substantial income from which he is able to contribute to the support and maintenance of Plaintiff and to pay her alimony in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding Plaintiff from Defendant permanent alimony in such sums as are reasonable and adequate to support and maintain Plaintiff in the station of life to which she has become accustomed during the marriage. COUNT IV - ALIMONY PENDENTE LITE 13. Plaintiff is without sufficient income to support and maintain herself during the pendency of this action. 14. Defendant enjoys a substantial income and is well able to contribute to the support and maintenance of Plaintiff during the course of this action. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her reasonable alimony pendente lite during the pendency of this action. COUNT V - COUNSEL FEES AND EXPENSES 15. Plaintiff is without sufficient funds to retain counsel to represent her in this matter. 16. Without competent counsel, Plaintiff cannot adequately prosecute her claims against Defendant and cannot adequately litigate her rights in this matter. 17. Defendant enjoys a substantial income and is well able to bear the expense of Plaintiff's attorney and the expenses of this litigation. . , , . WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay the legal fees and expenses incurred by Plaintiff in the litigation of this action. I verify that the statements made in this Complaint are true and correct, I understand that any false statements in this Complaint are subject to the penalties of 18 Pa, C.S, 4904 (unsworn falsification to authorities). DATE: /)- R-qq c~ -'" d Samuel L. An es Attorney for Plaintiff Supreme Court 10 17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 6: '0 (" . ' " u c.... 01 ) ( , , , J' , " , ., , . , (' " , j c- (n - I.'.. , (.') , LI~ " ; , CO >:9 l. " , " 'IU j--.. L.... ltl... I ~ . en U '-:J (" U ~ ~, ' ~~, \1 \ \~ . '> .~ ' :~ . IJ J,,\ ~{i ,,~ ~~ \f~ ! ',~: :i; 12~\ I '. f \'~ o \:. . ,~~ "- r~ ,\ ~ '.I) (~ ' \ ' \, .\:r v^o \J f< \; '.. . \ 'v, ): ~t" . (, 'r \ \ ,'" \1) (. ,"I, 'T. .....~ '\h .t".l \~'- ,'-\ """:':j ~; !' . ~ ,\ '~" <R; ~ ':1,. '-" ~ M <1 o .. /f) .. ~ ~ ~ 3, ~ < Z ~ III % < f-o = . ~ . ~ t s o-l H ~ ~ Yo >- ;.,J ~ 0 {fj ...:I z I-- ~ :.-; W a:: _ 0 Z ~ 0;: . ;.,J ~ I-< ~ ll. 0. ~ I-< 0 .. ... ~ z "' ., Z [J) ~ >< r~ 0 :>: "' o-l KAREN E, HOLLINGER, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW BRADFORD L. HOLLINGER, DEFENDANT NO. 99-942 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 18 February 1999 and served upon the Defendant within thirty days thereafter. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant. 3. I consent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct and 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. Date I ~ d-...lfl /0 d-, , /I >- Lt, (.:: a; '" 'c I- S UJ ~~~ N <{ U () :"2 ,- f...J f~': "~ ~~... ..' C- .", (~) :.~~ ;:j ,- , C) <-" ,.... 1 M ;;-: L'",; .' -, u.:.. ~; u i:i ~- U-' " lJ_: ~: 0- c.:.::.:: ..~. l,_ ", :J U 0 U KAREN E. HOLLINGER, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND ) COUNTY, PENNSYLVANIA ) vs. ) CIVIL ACTION - LAW ) BRADFORD L. HOLLINGER, ) NO. 99-942 CIVIL TERM Defendant ) ) IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service of the Divorce Complaint and acknowledge receipt of a copy of the same, DATE:~ ,qqq & COMMONWI;AI:1'I1 OF i'ENNSYI.VANIA 1l1';POAlfrMI;NT OF I II;AI.TI I VITAl. RICCOI{()S COUNTY CUMBERLAND RECORD OF DIVORCE State File Number State File Date HUSBAND NAME FIRST MIDDLE BRADFORD L, RESIDENCE STREET OR R,D, CITY, BORO. OR TWP, 2129 B. MARKET STREET CAMP HILL NUMBER RACE OI'THIS WHITE BLACK MARRIAGE xx DATE MONTll DAY YEAR 01' I3lRTH OCTOBER 8 1954 PLACE (STATE OR FOREIGN COUNTRYI 01' BIRTH PENNSYLVANIA I.AST IIOLLlNGER COUNTY STATE CUMBERLAND PA USUSAL OCCUPATION OTH ER (SPECII'Y) ACCOUNTANT WIFE MAIDEN NAME JOHNSON fiRST MIDDLE DATE 01' BIRTH MONTH DAY YEAR LAST KAREN E, II0LLlNGER MAY 31 1955 RESIDENCE STREET OR R,D, CITY, BORO, OR TWP, COUNTY PLACE (STATE OR FOREIGN COUNTRY} 01' BIRTH PENNSYLVANIA STATE 500 ARLINGTON ROAD CAMP HILL CUMBERLAND PA NUMBER OF THIS MARRIAGE RACE WHITE USUSA!. OCCUPATION BLACK OTHER (SPECII'Y) xx TEACHER PLACE OF THIS MARRIAGE COUNTY (STATE OR FOREIGN COUNTRY) WASHINGTON, D.C. DATE OF' THIS MARRIAG E MONTH DAY YEAR SEPTEMBER 24 1977 NUMBER OF CHILDREN THIS MARRIAGE NUMBER 01' DEPENDENT CHILDREN UNDER 18 PLAINTIFF HUSBAND WIFE X DECREE GRANTED TO HUSBAND WIFE X 3 2 NUMBER OF CHILDREN TO CUSTODY OF HUSBAND WIFE SPLIT CUSTODY OTHER ISPECII'YI LEGAL GROUNDS FOR DIVORCE OR ANNULMENT 3301 (DI DIVORCE CODE DATE OF DECREE MONTH DAY DATE REPORT SENT MONTH DAY YEAR TO VITAL RECORDS Y8AR SIGNATURE OFTRANSCRIBING CLEI<K KAREN E. HOLLINGER BRADFORD L, HOLLINGER 215-52-5812 174-38-3847 DEe 3 0 2002 \Y KAREN E. HOLLINGER, PLAINTIFF ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 99-942 CIVIL TERM BRADFORD L. HOLLINGER, DEFENDANT IN DIVORCE ORDER AND NOW this 3,'; rL. day of .\) ," ,.. ,_ L :, I , 2002, upon consideration of the attached Motion and the Property Settlement Agreement between the parties which is attached thereto, we hereby order and direct that the Defendant, Bradford L. Hollinger pay to the Plaintiff, Karen E. Hollinger, through the Domestic Relations Office of Cumberland County, alimony as set forth in the Property Settlement Agreement, including Paragraph 13 of that Agreement and Schedule F which is attached to that Agreement. The Domestic Relations Office is directed to open and administer an account in the collection and payment of such alimony. BY THE COURT, ,. ),/1 l Y / I I / ./ , ;' / / .' / / l. l .'-) ( ,\ ) J. ~ DISTRIBUTION: Samuel L. Andes, Esquire (Attorney for Plaintiff) 525 North 12th Street, Lemoyne, Pa 17043 Sandra L. Meilton, Esquire (Attorney for Defendant) 111 North Front Street, Harrisburg, PA 17101 Domestic Relations Office of Cumberland County P.O. Box 320, Carlisle, PA 17013 >- Ln ~ 9:; "" 1:"-: :5 IU (~-; t:'<J c> ::?; () -;- ~.- ;:.) ...:" c:- e:.... :::;: (i : :-.~ ~ , <::1 ,'(j r_, h:: l' , C,,": ~ '.C ~- --'. '_:: I ~ J :.u -- ~ :...1 'l.. C:.l .~:: ~.l r.-_l :J ' ; ...., w () ,~ ..; 'ltJ2..