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HomeMy WebLinkAbout03-3062WAYNE F, SH/M~E Ailomey at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 PHYLLIS L. L1NE, Plaintiff DENNIS E. LINE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW . : NO. 2003- ,~o (,, ~ 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 ofdivome 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 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 F1ND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: 717-249-3166 A hearing on the issues of support or alimonypendente lite advanced in the within Complaint is demanded. Wayne Ff Shade, Esquire Supreme Court No, 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff WAYNE F. SHADE A~omey at Law 53 West pornfret Street Carlisle, Pennsylvania 17013 PHYLLIS L. LINE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW V. : NO. 2003- J'og, a~ CIVIL TERM DENNIS E. LINE, : Defendant : IN DIVORCE COMPLAINT COUNT I DIVORCE 1. Plaintiff in this Action in Divorce is PHYLLIS L. LINE, an adult individual who resides at 440 Barnstable Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is DENNIS E. LINE, an adult individual and citizen of the United States of America who resides at 8 Liberty Court, Carlisle, Cumberland County, Pennsylvania 17013. Defendant has been a bona fide resident of Cumberland County, Pennsylvania, for more than six months previously to the filing of this Complaint and continuing to the commencement of this Action in Divorce. 4. Plaintiff and Defendant were lawfully joined in marriage on August 21, 1971, in Carlisle, Pennsylvania. WAYNE F. SHADE A~torney at Law 53 West Po/nfl'et Street Carlisle, Pennsylvania 17013 The parties have been living separate and apart since April 20, 2003. 6. Plaintiff avers as the grounds on which this action is based that the marriage of the parties is irretrievably broken. In the alternative, Plaintiff avers as the grounds on which this action is based that Defendant has offered such indignities to the person of the Plaintiff, the innocent and injured spouse, as to render the condition of Plaintiff intolerable and the life of Plaintiff burdensome. 7. There have been no prior actions for divorce or annulment of this marriage in Pennsylvania or in any other jurisdiction. 8. This Action in Divorce is not collusive. 9. Both parties to this Action in Divorce are legally capable of managing their own concerns. 10. Defendant herein is not a member of the armed forces of the United States of America. -2- WAYNE F. SHADE 11. There were three children bom to the parties, namely, Abby Marie Burkholder, bom October 22, 1974, Joshua Christopher Line, bom May 16, 1978, and Jennifer Elizabeth Line, bom January 16, 1983. 12. Plaintiff has no adequate means of support. 13. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, Plaintiff demands judgment dissolving the marriage between the parties. COUNT II EQUITABLE DISTRIBUTION 14. The averments of Paragraphs 1 through 13 inclusive above are incorporated herein by reference as though fully set forth. 15. Plaintiff and Defendant possess various items of marital property which are subject to equitable distribution by the Court. -3- WHEREFORE, Plaintiff demands judgment equitably distributing all marital property owned by the parties and such further relief as the Court may deem equitable and just. COUNT III ALIMONY AND ALIMONY PENDENTE LITE 16. The averments of Paragraphs 1 through 13 inclusive above are incorporated herein by reference as though fully set forth. WHEREFORE, Plaintiff demands judgment compelling Defendant to pay to Plaintiff alimony and alimony pendente lite. COUNT IV COUNSEL FEES, EXPENSES AND COSTS 17. The averments of Paragraphs 1 through 13 inclusive above are incorporated herein by reference as though fully set forth. WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania -4- WHEREFORE, Plaintiff demands judgment compelling Defendant to pay counsel fees, expenses and costs of Plaintiff. Wayne F.~'~dhade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 -5- I verify that the statements made in this pleading 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: June 27, 2003 Phyllis~L. Line WAYNE F. SHADE PHYLLIS L. LINE, Plaintiff DENNIS E. LINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2003- CIVIL TERM IN DIVORCE OBDER OF COURT AND NOW, this day of.__ ,2003, upon consideration of the attached Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before RJ Shadday on at for a conference, at 13 North Hanover Street, Carlisle, Pennsylvania 17013, at'~r which the conference officer may recommend that an Order for Alimony Pendente Lite be entered You are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Reium, inc]udiag W-TS as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement aituchad to this Order, completed as required by Rule 1910 1 I(c) (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you If you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest BY THE COURT, George E. Hoffer, President Judge Date of Order: Conference Officer YOU HAVE THE RIGHT TO A LAWYER WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFF1CE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 Wayne F Shade, Artomey for Plaintiff DannisE. Line C~ WAYNE F. SHADE Attoraey at Law 53 West Pomfret Street Carlisle, Pennsylvania PHYLLIS L. LINE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DENNIS E. LINE, Defendant : NO. 2003-3062 CIVIL TERM : : IN DIVORC, E PRAECIPE FOR DISCONTINUANCE TO: Curtis R. Long, Prothonotary Please discontinue the above-captioned action. Date: June 30, 2003 WaynctF. Shade, Esquire Supreme Court No. 15712 53 West: Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attomey for Plaintiff In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION pHYLLIS L. LINE Plaintiff vs. DENNIS E. LINE Defendant ) Docket Number ) ) PACSES Case Number ) ) Other State ID Number 03-3062 CIVIL 974105601 ORDER AND NOW, to wit on this 3RD DAY OF JULY, 2003 IT IS HEREBY ORDERED that the O Complaint for Support or © Petition to Modify or (~) Other ALIMONY PENDENTE LITE filed on JULY 27, 2003 in the above captioned matter is dismissed without prejudice due to: THE DIVORCE BEING DISCONTINUED. O The Complaint or Petition may be reinstated upon written application of the plaintiff petitioner. DRO: RJ Shadday xc: plaintiff defendant S~i Andes, Esquire BY THE COURT: JUDGE Form OE-506 Service Type M Worker ID 21005