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HomeMy WebLinkAbout99-03303 (2)¦ _._?_ .._? ?. .._ .. :'I' iJ .? f CURVIN M. DUBS, Plaintiff, VS. PATRICIA A. DUBS, Defendant. TO: Patricia A. Dubs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99.3303 CIVIL TERM : 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 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, Hanover and High Streets, Carlisle, PA 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: Lawyer Referral Service 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 COYNE & COYNE,11P.C. Date: ria /- 9 By; (ca+.c L[h .. LI ARIE COYNE, L'SQU E 3 1\4arket Street Camp Hill, PA 17011-4227 717) 737-0464 Pa. Supreme Ct. No. 53788 Annrireps f,r Plaintiff CURVIN M. DUBS, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 99. 3 303 CIVIL TERM PATRICIA A. DUBS, Defendant. : IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the Plaintiff, Curvin M. Dubs, Jr., by his attorneys, Coyne & Coyne, P.C., and files this Complaint In Divorce and avers the following in support thereof: 1. Plaintiff is, Curvin M. Dubs, Jr., an adult individual who currently resides at 277 Samples Bridge Road, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant, Patricia A. Dubs, is an adult individual who currently resides at 227 Samples Bridge Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on September 28, 1974, at Harrisburg, Dauphin County, Pennsylvania. 5. Neither party is on active duty as a member of the Armed Services of the United States or any of its Allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940, as amended. 6. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 7. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request the parties to participate in counseling. COUNT 1 - DIVORCE 8. The causes of action and sections of the Domestic Relations Code under which Plaintiff is proceeding are : Section 3301(a)(2). Defendant committed adultery continuously from 1995 to date with various men. Section 3301 (a)(6). Defendant has offered such indignities to Plaintiff, the innocent and injured spouse, as to render his condition intolerable and life burdensome. Section 3301( c). The marriage of the parties is irretriveably broken. After Ninety (90) days have elapsed from the date of the filing of this Complaint. Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an Affidavit. Section 3301(d). The marriage of the parties is irretrievably broken. The parties are living separate and apart and, at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two years. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree of Divorce divorcing Plaintiff from Defendant. COUNT II - EQUITABLE DISTRIBUTION 9. The prior paragraphs of this Complaint are incorporated by reference. 10. Plaintiff and Defendant have acquired property, both real and personal, and debt during their marriage. 11. Plaintiff and Defendant have been unable to agree as to the equitable division of said property and debt. 2 WHEREFORE, Plaintiff requests your Honorable Court to equitable divide all marital property and debt pursuant to Section 3502(d) of the Divorce Code. Respectfully submitted: COYNE & COYNE, P.C. Dated:_ &/-/- 0/9 PlMarket RIE COYNE, Esq Street l, PA 1 70 1 1-4227 (717) 737-0464 Pa. S. Ct. No. 53788 Attorney for Plainlif 3 VER?iCATION The facts set forth in the foregoing are true and correct to the best of the undersigned's knowledge, information and belief and are verified subject to the penalties for unswom falsification to authorities under 18 Pa. C.S.A. §4904. Dated: F- UJ C) U. i 9 10 ? 0 1 ° a ' cr _ cn s? a? V ao q CURVIN M. DUBS, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PA Vs. : NO. 99-3303 CIVIL TERM PATRICIA A. DUBS, Defendant : IN DIVORCE PROOF OF SERVICE Original service of the Complaint, dated June 1, 1999, was made upon Defendant on June 17, 1999 by First Class Certified Mail, Restricted Delivery, United States Postal Service. Dated: 99 ?^- v sa arie Coyne, Esquire RN AD®RFS8 completed on the reverse olds? o e & Coyne, P.C. 1 1. P • e •• w 3 1 Market Street s s Camp Hill, PA 17011-4227 . m (717) 737-0464 c? Pa. Supreme Ct. No. 53788 g t o 3 e l l? Attorney for Plaintiff Z 224 788 629 US Postal Service ,Receipt for Certified Mail No Insurance Coverage Provided. Do not use for Inlemationai Mail /Sea mvama) Tinmic!trw :ar *.aeit+rn ? e.evwrr ,'... f 7 q O u L- ?iv` /1?rr a ? _5 Strom a f Ot "' e. IP Co e„ i :.? Z4 4 7ldJ Postage $ ..5.5' Celled Fee . ya Speoal Delivery Fee hooted Defvmy Fee r 7c}? ' paMn Receol Rwwhp to Whom i Dale Defveiad _-' F PAW FW80 Rowe ID WUM Des I Afteeeet Wane 7 ? ? 101AL Post Fees '? r :' 3;y? ? PocWn i i CERTIFICATE OF SERVICE j i' i ,I I, Lisa Marie Coyne, Esquire, hereby certify that true copy of proof of Service of the Original Complaint was served this date upon the below-referenced individual by at the below listed address by way of First class mail, postage prepaid: Mrs. Patricia A. Dubbs 227 Samples Bridge Road Mechanicsburg, PA 17055 Dated:_ I j4 erc? V isa arie Coyne, Esquire rS?r c? - ? lJ "' CJ (o I CURVIN M. DUBS, Plaintiff VS. PATRICIA A. DUBS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3303 CIVIL TERM IN DIVORCE / ORDER p AND NOW, this day of X"14 kV ' is hereby appointed Master in Divorce. BY THE COURT: I l 1 fY CL, s? a CURVIN M. DUBS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Vs. : NO. 99-3303 CIVIL TERM PATRICIA A. DUBS, Defendant : IN DIVORCE MOTION FOR APPOINTMENT OF MASTER CURVIN M. DUBS, Plaintiff/Petitioner, moves the Court to appoint a Master with respect to the following claims: (X ) Divorce (X ) Distribution of Property ( ) Annulment () Support ( ) Alimony ( } Counsel Fees ( } Alimony Pendente Lite () Costs and Expenses and in support of the Motion states: 1. Discovery is complete as to the claims for which the appointment of a master is requested. 2. The Defendant has appeared in the action by counsel Arthur K. Dils, Esquire. 3. The statutory ground for divorce is the two year separation as of December 10, 1999. 4. The action is not contested and no agreement has been reached with respect to the disputed claims. 5. The action does not involve complex issues of law or fact. 6. 'flu hearing is expected to lake one (1) day. Dated:__/2 ,to - !! Camp Hill, PA 17011-4227 (717)737-0464 Pa. S. Ct. No. 53788 A MARIE COYNE, , QUIIcF, Coyne & Coyne,P.C. 3901 Market Street r: , ,, CURVIN M. DUBS, Plaintiff Vs. PATRICIA A. DUBS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3303 CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I, LISA MARIE COYNE, ESQUIRE, hereby certify that on December 10, 1999, I served a true and correct copy of the foregoing Motion for Appointment of Master upon Arthur K. Dils, Esquire, counsel for Defendant, by depositing same, postage prepaid, in the United States Mail, addressed as follows: Arthur K. Dils, Esquire Dils & Rupich 1017 North Front Street Harrisburg, PA 17102 Dated: / 2 -•o - 99 ? 14 MARIE COYNE SQUIRE oyne & Coyne,P.C. 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 n c• a, i? J ?u 5? ,::_ «? ? . 11.!??" N _ ??..r is _' ?.: (' ?_ . , r ? c:_I j` I n ?.? ;i???. L' L., ?r 'I J p_. L.: :.IIL L? ??'? G? ?? (J ?M ?®v CURVIN M. DUBS, Plaintiff VS. PATRICIA A. DUBS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3303 Civil IN DIVORCE TO THE PROTHONOTARY: Please enter my appearance on behalf of the Defendant, Patricia A. Dubs, in the above captioned divorce action. r BY: Arthur K. Dils, Esquire 1017 N. Front Street. Harrisburg, PA. 17102 (717) 232-9724 I.B. No. 07056 January 5, 2000 I& r- tia-. ` u,n r? C).G? Lid nh. CV ..J a? -acz O o a G U U 0 cJ rv Er a a w a w C a z e pq co s' w g O }a 4 H tr, ? ?, 4) C C Q >+ ?rq p E ro W UOOv?.' 3 ?¢ U ?? ?••I H • N U <. S H> H a c c a w a ON > ? ^ O U Cc N C E< w U fY H M G.` H s? a C O w o oz ocz o Qz z < z oz?c M aoraa N as t H cHzcr w x m. z U C7 a W W 4y xwv c. H H HQ Cw Hc > a z Ww z -, o zcw. o c c a HUa z U w u i CURVIN M. DUBS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. No. 99-3303 Civil 'I'erm PATRICIA A. DUBS„ CIVIL ACTION - CUSTODY Defendant NOTICE TO PLEAD TO: Curvin M. Dubs c/o Lisa Marie Coyne, Esquire 3901 Market Street Camp Hill, PA. 17011 You are hereby notified to plead to the within Counterclaim within twenty (20) days after date of service hereof. Respectfully tted, =Y. Arthur K. Dils, Esquire 1017 North Front Street Harrisburg, PA 17102 (717) 232-9724 I.D. No. 07056 Date: February 16, 2000 CURVIN M. DUBS, Plaintiff VS. PATRICIA A. DUBS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3303 Civil Term IN DIVORCE AND NOW, this l?Day of February, 2000, comes Arthur K. Dils, Esquire, the attorney for the Dekndant, Patricia A. Dubs, and respectfully requests the following: CLAIM FOR ALIMONY, ALIMONY PENDENTE L TE. COUNSEL FEES AND EXPENSES 1. Defendant, Patricia A. Dubs, has insufficient funds to proceed with the necessary appraisals and evaluations in connection with the divorce action, instituted by Plaintiff. 2. Plaintiff has refused to cooperate in the appraisal of the marital real estate and the valuation of certain antiques and marital items, which are necessary prior to a Master's hearing being held. 3. Plaintiff has refused to share the costs of the same. 4. Plaintiff has sufficient funds to pay for the necessary appraisals and valuations. 5. Defendant does not have sufficient funds to sustain herself after the divorce. 6. Plaintiff does have sufficient funds to sustain the Defendant upon the entry of a Decree in Divorce. 7. Defendant does not have sufficient funds to pay counsel fees in connection with the above captioned divorce action. 8. Plaintiff does have sufficient funds to pay Defendant's counsel fees incidental to the above captioned divorce action. WHEREFORE, Defendant, Patricia A. Dubs, through her attorney, Arthur K. Dils, Esquire, respectfully requests that Plaintiff, Curvin M. Dubs, be Ordered to pay all costs incidental to the valuation of the real estate, and all antiques, and personal property, and further, that the Plaintiff be required to pay Defendant's counsel fees in this matter. BY: submitted, ruuiur N. uns, esquire 1017 N. Front Street Harrisburg, Pa. 17102 (717) 232-9724 I.D. No. 07056 The undersigned, Arthur K. Dils, Esquire, hereby verifies and states that: 1. He is the attorney for Patricia A. Dubs. 2. He is authorized to make this verification on her behalf. 3. This verification is made by counsel pursuant to Pa. R.C.P., Rule 1024(c). 4. The statements set forth in the foregoing Counterclaim are true and correct to the best of his knowledge, information and belief. 5. He is aware that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relatin o worn falsification to authorities. Arthur K. Dils, Esquire Date: February 16, 2000 1, Arthur K. Dils, Esquire hereby certify that a true and correct copy of the within Counterclaim has been served upon the following individuals by depositing a copy of the same in the United States Mail, First Class Mail, on the day of February, 2000 to the following address: Lisa Marie Coyne, Esquire 3901 Market Street Camp Hill, PA, 17011 Res ly submitted, Arthur K. Dils, Esquire 1017 North Front Street Harrisburg, PA 17102 (717) 232-9724 I.D. No. 07056 Date: February 16, 2000 CURVIN M. DUBS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Vs. : NO. 99-3303 CIVIL TERM PATRICIA A. DUBS, : CIVIL. ACTION Defendant NOTICE OF SERVICE OF PLAINTIFF'S FIRST SET OF INTERROGATORIES AND REQUEST FOR DOCUMENTS TO DEFENDANT To the Prothonotary: Please be advised that on February 22, 2000, an original and two (2) copies of the Plaintiffs Interrogatories and Request for Documents of Defendant, Patricia A. Dubs, was served upon counsel for Defendant, Arthur K. Dils, Esquire, by ordinary mail to 1017 North Front Street, Harrisburg, PA 17102. COYNE & COYNE, P.C. Dated: -7 3 '--E-13 A 0 BY: t ?^"^ LI ARIE COYNE, QUIRE 3901 Market Street Camp Hill, PA 17011-4227 (717)737.0464 Pa. S. Ct. No. 53788 Attorney for Plaintiff %,43 1 o - W Cl O CURVIN M. DUBS, Plaintiff, VS. PATRICIA A. DUBS, Defendant. TO: Patricia A. Dubs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-33 0. CIVIL TERM : 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 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, Hanover and High Streets, Carlisle, PA 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: Lawyer Referral Service 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 COYNE & COYNE, P.C. Date: w `, " 9 r LI ARIE COYNE, ESQU 3 Market Street Camp Hill, PA 17011-4227 717) 737-0464 Pa. Supreme Ct. No. 53788 Attorneys for Plaintiff CURVIN M. DUBS, JR., Plaintiff VS. PATRICIA A. DUBS, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99. 3 30 3 CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the Plaintiff, Curvin M. Dubs, Jr., by his attorneys, Coyne & Coyne, P.C., and files this Complaint In Divorce and avers the following in support thereof: 1. Plaintiff is, Curvin M. Dubs, Jr., an adult individual who currently resides at 277 Samples Bridge Road, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant, Patricia A. Dubs, is an adult individual who currently resides at 227 Samples Bridge Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on September 28, 1974, at Harrisburg, Dauphin County, Pennsylvania. 5. Neither party is on active duty as a member of the Armed Services of the United States or any of its Allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940, as amended. 6. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 7. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request the parties to participate in counseling. 1 COUNT 1 - DIVORCE 8. The causes of action and sections of the Domestic Relations Code under which Plaintiff is proceeding are : Section 3301(a)(2). Defendant committed adultery continuously from 1995 to date with various men. Section 3301(a)(6). Defendant has offered such indignities to Plaintiff, the innocent and injured spouse, as to render his condition intolerable and life burdensome. Section 3301( c). The marriage of the parties is irretriveably broken. After Ninety (90) days have elapsed from the date of the filing of this Complaint. Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an Affidavit. Section 3301(d). The marriage of the parties is irretrievably broken. The parties are living separate and apart and, at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two years. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree of Divorce divorcing Plaintiff from Defendant. COUNT II - EQUITABLE DISTRIBUTION 9. The prior paragraphs of this Complaint are incorporated by reference. 10. Plaintiff and Defendant have acquired property, both real and personal, and debt during their marriage. 11. Plaintiff and Defendant have been unable to agree as to the equitable division of said property and debt. 2 WHEREFORE, Plaintiff requests your Honorable Court to equitable divide all marital property and debt pursuant to Section 3502(d) of the Divorce Code. Respectfully submitted: COYNE & COYNE, P.C. Dated: "if V- t-40k? -- I A MARIE COYNE, Esqu' e 3 1 Market Street -Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 Attorney for Plaintiff VERMCATION The facts set forth in the foregoing are true and correct to the best of the undersigned's knowledge, information and belief and are verified subject to the penalties for unswom falsification to authorities under 18 Pa. C.S.A. §4904. Dated: C ` / - 9 9 ?\? : .r . t ,tn a CURVIN M. DUBS, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PA VS. : NO. 99-3303 CIVIL TERM PATRICIA A. DUBS, Defendant : IN DIVORCE PROOF OF SERVICE Original service of the Complaint, dated June 1, 1999, was made upon Defendant on June 17, 1999 by First Class Certified Mail, Restricted Delivery, United States Postal Service. Dated: I d 9 9 Is yaxmRETURN ADDRESS completed on the revs?se side? R -I ?"I DavnnIM01 v 3 r? C, ?o m c rn v i. M m M M m Thank you for using Return Receipt Service. Ysa 'arie Coyne, Esquire) o e & Coyne, P.C. f 39-01 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. Supreme Ct. No. 53788 Attorney for Plaintiff Z 224 788 1,29 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Do not use for International Mail See reverse t to ?W'11;c Street & N ber i' , Postage $ v Certified Fee y? Special Delivery Fee Restricted Delivery Fee 7?J LO Co))) Retum Receipt Showing to Whom & Date Qebeted CL Q Retum Receipt fO pptt6in; Date, & Addressee's /-? TOTAL t?osta Fees a G $: Postmark o E E o a CERTIFICATE OF SERVICE I, Lisa Marie Coyne, Esquire, hereby certify that true copy of Proof of Service of the Original Complaint was served this date upon the below-referenced individual by at the below listed address by way of First class mail, postage prepaid: Mrs. Patricia A. Dubbs 227 Samples Bridge Road Mechanicsburg, PA 17055 c Dated: isa )arie Coyne, Esquire CURVIN M. DUBS, Plaintiff VS. PATRICIA A. DUBS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3303 CIVIL TERM IN DIVORCE MOTION FOR APPOINTMENT OF MASTER CUR`1IN M. DUBS, Plaintiff/Petitioner, moves the Court to appoint a Master with respect to the following claims: ( X ) Divorce ( ) Annulment ( ) Alimony ( ) Alimony Pendente Lite ( X ) Distribution of Property ( ) Support ( ) Counsel Fees ( ) Costs and Expenses and in support of the Motion states: 1. Discovery is complete as to the claims for which the appointment of a master is requested. 2. The Defendant has appeared in the action by counsel Arthur K. Dils, Esquire. 3. The statutory ground for divorce is the two year separation as of December 10, 1999. 4. The action is not contested and no agreement has been reached with respect to the disputed claims. 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take one (1) day. Dated: A MARIE COYNE, QUIRE Coyne & Coyne, P.C. 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 CURVIN M. DUBS, Plaintiff VS. PATRICIA A. DUBS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3303 CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I, LISA MARIE COYNE, ESQUIRE, hereby certify that on December 10, 1999, I served a true and correct copy of the foregoing Motion for Appointment of Master upon Arthur K. Dils, Esquire, counsel for Defendant, by depositing same, postage prepaid, in the United States Mail, addressed as follows: Arthur K. Dils, Esquire Dils & Rupich 1017 North Front Street Harrisburg, PA 17102 Dated:_ / Z -110 MARIE COYNE SQUIRE oyne & Coyne, P.C. 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 t _ ,. ??'? `- i?? t, - .. CURVIN M. DUBS, Plaintiff VS. PATRICIA A. DUBS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3303 CIVIL TERM IN DIVORCE ORDER .10 r, / /r AND NOW, this day of L? is hereby appointed Master in Divorce. i BY THE COURT: ? . .. -? '. ,.- /'.1??,.... .... CURVIN M. DUBS, Plaintiff vs. PATRICIA A. DUBS, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3303 Civil IN DIVORCE PRAECIPE Please enter my appearance on behalf of the Defendant, Patricia A. Dubs, in the above captioned divorce action. BY: ' Arthur K. Dils, Esquire 1017 N. Front Street Harrisburg, PA. 17102 (717) 232-9724 I.D. No. 07056 January 5, 2000 i. _.._ r ? "'Y? ?p?l l i F ? ? ? , r ?s?.? ` " } f ? ., i _ i _. . .?? ._ m ? ? , t ii ; om ? .? CURVIN M. DUBS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. No. 99-3303 Civil Term PATRICIA A. DUBS„ CIVIL ACTION - CUSTODY Defendant NOTICE TO PLEAD TO: Curvin M. Dubs c/o Lisa Marie Coyne, Esquire 3901 Market Street Camp Hill, PA. 17011 You are hereby notified to plead to the within Counterclaim within twenty (20) days after date of service hereof. Respectfull y fled, BY. Arthur K. Dils, Esquire 1017 North Front Street Harrisburg, PA 17102 (717) 232-9724 I.D. No. 07056 Date: February 16, 2000 1 CURVIN M. DUBS, Plaintiff vs. PATRICIA A. DUBS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA. NO. 99-3303 Civil Term IN DIVORCE COUNTERCLAIM ON BEHALF OF PATRICIA A. DUBS AND NOW, this f Day of February, 2000, comes Arthur K. Dils, Esquire, the attorney for the Defendant, Patricia A. Dubs, and respectfully requests the following: CLAIM FOR ALIMONY, ALIMONY PENDENTE LITE. COUNSEL FEES AND EXPENSES 1. Defendant, Patricia A. Dubs, has insufficient funds to proceed with the necessary appraisals and evaluations in connection with the divorce action, instituted by Plaintiff. 2. Plaintiff has refused to cooperate in the appraisal of the marital real estate and the valuation of certain antiques and marital items, which are necessary prior to a Master's hearing being held. 3. Plaintiff has refused to share the costs of the same. 4. Plaintiff has sufficient funds to pay for the necessary appraisals and valuations. 5. Defendant does not have sufficient funds to sustain herself after the divorce. b. Plaintiff does have sufficient funds to sustain the Defendant upon the entry of a Decree in Divorce. 7. Defendant does not have sufficient funds to pay counsel fees in connection with the above captioned divorce action. 8. Plaintiff does have sufficient funds to pay Defendant's counsel fees incidental to the above captioned divorce action. WHEREFORE, Defendant, Patricia A. Dubs, through her attorney, Arthur K. Dils, Esquire, respectfully requests that Plaintiff, Curvin M. Dubs, be Ordered to pay all costs incidental to the valuation of the real estate, and all antiques, and personal property, and further, that the Plaintiff be required to pay Defendant's counsel fees in this matter. Respectfully submitted, BY: Arthur K. Dils, Esquire 1017 N. Front Street Harrisburg, Pa. 17102 (717) 232,9724 I.D. No. 07056 VERIFICATION The undersigned, Arthur K. Dils, Esquire, hereby verifies and states that: 1. He is the attorney for Patricia A. Dubs. 2. He is authorized to make this verification on her behalf. 3. This verification is made by counsel pursuant to Pa. R.C.P., Rule 1024(c). 4. The statements set forth in the foregoing Counterclaim are true and correct to the best of his knowledge, information and belief. 5. He is aware that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relatin o unworn falsification to authorities. r Arthur K. Dils, Esquire Date: February 16, 2000 CERTIFICATE OF SERVICE 11 Arthur K. Dils, Esquire hereby certify that a true and correct copy of the within Counterclaim has been served upon the following individuals by depositing a copy of the same in the United States Mail, First Class Mail, on the day of February, 2000 to the following address: Lisa Marie Coyne, Esquire 3901 Market Street Camp Hill, PA. 17011 Res ly submitted, .1 / Bt Arthur K. Dils, Esquire 1017 North Front Street Harrisburg, PA 17102 (717) 232-9724 I.D. No. 07056 Date: February 16, 2000 r. i r k 1 t C F 1f. C] ? O iT1 > ?TJ Ll Fa ;? n > Lt 1 7 X700 J1 H L? l `d H H by w7 m? (D a 14 ?f I? 1 1 C C rd • N N• rt N- M z O I w w 0 w n r- C N• N rl 53 ?MM W . 1 CURVIN M. DUBS, Plaintiff VS. PATRICIA A. DUBS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3303 CIVIL TERM CIVIL ACTION NOTICE OF SERVICE OF PLAINTIFF'S FIRST SET OF INTERROGATORIES AND REQUEST FOR DOCUMENTS TO DEFENDANT To the Prothonotary: Please be advised that on February 22, 2000, an original and two (2) copies of the Plaintiff's Interrogatories and Request for Documents of Defendant, Patricia A. Dubs, was served upon counsel for Defendant, Arthur K. Dils, Esquire, by ordinary mail to 1017 North Front Street, Harrisburg, PA 17102. COYNE & COYNE, P.C. Dated: --? 3 -'?E X-3 A BY: LI ARIE COYNE, QUIRE 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 Attorney for Plaintiff m t? tea a Ow CURVIN M. DUBS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99 - 3303 CIVIL PATRICIA A. DUBS, Defendant IN DIVORCE ORDER OF COURT AND NOW, this j day of 0eA'(YA., , 2006, counsel having failed to complete discovery in response to Master's request in December 1999, and the case having been purged from the docket, the appointment of the Master is vacated. BY THE COURT, Q, " wic'. Edgar B. Bayley, P.J. Cc: sa Marie Coyne Attorney for Plaintiff ,,,,YYthur K. Dils Attorney for Defendant _iL 1 C ti N