HomeMy WebLinkAbout99-067561
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF I - PEN NA.
ON fl. MCINIYR,E,
r D t 3:0 41-IV -
AND NOW, ZOOS IT IS ORDERED AND
VEF35US
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BRENDA L. MCINPYRE, - LI
DEF&NDANr
NO.
eLAINrIr•F ?
DECREE IN
DIVORCE
DECREED THAT
AND
JON H. %lcINrYRL•'
99-6756'
PLAINTIFF,
BRENDA L. McINTYRE
DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY,
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMF WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
NONE
BY THE C
ATTEST' J
PROTHONOTARY
13
JON H. McINTYRE,
Plaintiff
VS.
BRENDA L. McINTYRE,
Defendant
TO THE PROTHONOTARY:
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
I CIVIL ACTION - LAW
I
I NO. 99-6756
I
I IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
Transmit the record, together with the following information, to the Court for entry of a
divorce decree:
1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c).
2. Date and manner of service of the Complaint: Acceptance of Service filed by Plaintiff's
counsel indicating service on or about 13 December 1999.
3. Complete either Paragraph (a) or (b):
(a) Date of execution of the Affidavit of Consent required by Section 3301
(c) of the Divorce Code: By Plaintiff: 4 February 2003 By Defendant: 4 February
2003
(b) (1) Date of execution of the Affidavit required by Section 3301 (d) of the
Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit
upon the
Respondent:
4. Related claims pending: None.
5. Complete either (a) or (b):
(a) Date and manner of service of the Notice of Intention to File Praecipe to
Transmit Record, a copy of which is
attached:
(b) Date Plaintiff's Waiver of Notice in Section 3301 (c) Divorce was filed
with the Prothonotary: Dated 4 February 2003 filed contemporaneously herewith.
Date Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the
Prothonotary: Dated 4 February 2003, filed contemporaneously herewith.
Date: 4 February 2003
By Sam S
uel L. ndes
Attorney for Plaintiff
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JON H. McINTYRE,
Plaintiff
VS.
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99- ?,75G CIVIL TERM
BRENDA L. McINTYRE,
Defendant
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
foregoing 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 in 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:
Office of the Prothonotary
Cumberland County Court House
1 Courthouse Square
Carlisle, Pennsylvania 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S
I 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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone: (717) 249-31 66
JON H. McINTYRE,
Plaintiff
VS.
BRENDA L. McINTYRE,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99- [. %52 CIVIL TERM
1
IN DIVORCE
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
s 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
Gist. All necessary arrangements and the cost of counseling sessions are to be borne by you
'a'nd 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.
2
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JON H. McINTYRE,
Plaintiff
VS.
BRENDA L. McINTYRE,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
)
CIVIL ACTION - LAW
4 75'4 CIVIL TERM
NO. 99-
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, JON H. McINTYRE, by his attorney,
I L. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is JON H. McINTYRE, an adult individual who currently resides at 604
j Street, New Cumberland, Cumberland County, Pennsylvania.
2. The Defendant is BRENDA L. McINTYRE, an adult individual who currently resides
337 Bridge Street, New Cumberland, Cumberland County, Pennsylvania.
3. Both the Plaintiff and Defendant have been bona fide residents of the Common-
of Pennsylvania for at least six months immediately previous to the filing of this
mplaint.
4. The Plaintiff and Defendant were married on 15 May 1986 in Lower Allen
p, Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. This marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff
may have the right to request that the Court require the parties to participate in counseling.
8. The Plaintiff requests this Court to enter a Decree of Divorce.
WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to the
Divorce Code of Pennsylvania.
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:
JON'H. McINTYRE
?P
Sa el L. Andes
Attorney for Plaintiff
Supreme Court ID 17225
525 North 12th Street
Lemoyne, PA 17043
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JON H. McINTYRE,
VS.
PLAINTIFF
BRENDA L. McINTYRE,
DEFENDANT
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
1
CIVIL ACTION - LAW
NO. 99-6756
1
IN DIVORCE
AFFIDAVIT OF CONSENT
1 . A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on B
November 1999 and served upon the Defendant on or about 26 November 1999.
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. 1 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. 1 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
Ii
il understand that false statements herein are made subject to the penalties of 18 Pa. C. S.
Section 4904 relating to unsworn falsification to authorities.
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j Date JON H, McINTYRE
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JON H. McINTYRE, 1 IN THE COURT OF COMMON
PLAINTIFF 1 PLEAS OF CUMBERLAND
1 COUNTY, PENNSYLVANIA
VS.
1 . A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 8
NO. 99-6756
BRENDA L. McINTYRE,
DEFENDANT
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
AFFIDAVIT OF CONSENT
November 1999 and served upon the Defendant on or about 26 November 1999.
have elapsed from the date of filing of the complaint and the date of service of the complaint
on the Defendant.
3. 1 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. 1 have been advised of the availability of marriage counseling and understand that
CIVIL ACTION . LAW
IN DIVORCE
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
BRENDA L. McINTYRE
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JON H. McINTYRE,
PLAINTIFF
VS.
BRENDA L. McINTYRE,
DEFENDANT
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-6766
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE
1 . I consent to the entry of a final decree in divorce without notice.
2. 1 understand that I may lose rights concerning alimony, division of property,
lawyer's fees, or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
court and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
,f
I verify that the statements made in this Waiver are true and correct. I understand
that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating
to unsworn falsification to authorities.
is
LA RNAA
Date U aON H. McINTYRE
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JON H. McINTYRE,
VS.
PLAINTIFF
BRENDA L. McINTYRE,
DEFENDANT
1 IN THE COURT OF COMMON
1 PLEAS OF CUMBERLAND
1 COUNTY, PENNSYLVANIA
1
1 CIVIL ACTION - LAW
1
1 NO. 99-6756
1
1 IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE
1 . I consent to the entry of a final decree in divorce without notice.
2. 1 understand that I may lose rights concerning alimony, division of property,
lawyer's fees, or expenses if I do not claim them before a divorce is granted.
3. 1 understand that I will not be divorced until a divorce decree is entered by the
court and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this Waiver are true and correct. I understand
that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4-904 relating
to unsworn falsification to authorities.
y Qbtiu "aOa3
Date BRENDA L. McINTYRE
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JON H. MCINTYRE, IN 'riffs COUaT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. N0. 99-6756
BRENDA L. MCINTYRE, CIVIL ACTION - LAW
Defendant IN DIVORCE
ACCEPTANCE OF SERVICE
I, Paige Macdonald-Matthes, Esquire, attorney for the
Defendant, Brenda L. McIntyre, received a copy of the Divorce
Complaint in the above captioned matter on November 22, 1999
and I am authorized to accept service on behalf of the
Defendant.
Date:
Paige Macdonald-Matthes, Esquire
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JON H. McINTYRE, 1 IN THE COURT OF COMMON PLEAS
PLAINTIFF 1 OF CUMBERLAND COUNTY,
I PENNSYLVANIA
I
VS. 1 CIVIL ACTION - LAW
1
I NO. 99-6756
BRENDA L. McINTYRE, I
DEFENDANT I IN DIVORCE
PRAECIPE TO WITHDRAW CLAIMS
TO THE PROTHONOTARY:
Please withdraw the economic claims previously raised in this matter on my behalf,
including claims for equitable distribution, alimony, alimony pendente lite, and counsel fees and
expenses.
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Date: YUQr'LI ar^03 t'i
Brenda L. McIntyre
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BRENDA L. i11C INTYRE, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Pelitioner CUMBERLAND COUNTY, IENNSYLVANIA
VS. CIVILACf1ON - DIVORCE
NO.99-6756 CIVILTERJI
JON B. MC INTYRE, IN DIVORCE
Defendant/Respondent DR# 29,654
1'acscs# S96102278
ORDER OF CQUR•r
AND NOW, this 12"day of Mac. 2000, upon consideration of the attached Petilion for Alintonr-
Pendenic Lite and/or counsel fees. it is hereby directed than llte parties and their respective, counsel appear
before R.J. Shadday on June /S. 2000 at I/I:30 A.DI for a confcrmec. at 13 N. I bmover St.. Carlisle. PA
17013, alter which the confcrcncc officer may recommend that an Order for Alinton Pcudenle Lite be
culcrcd.
YOU are further ordered to bring to the conference:
(1) a me copy of.your most recent Federal Income Tax Return. including W-2's as filed
(2) your pap stubs for the preceding six (6) months
(3) the Intone and Expense Statement attached to this order. completed as required by Rule
1910.111,
(3) vcriftcaliolofchild care cxpcnses
(5) proof of medical coverage which you may have, or mac have available to you
IF you fail to appear for ale conference or bring the required documents, the Court may issue a
warrant for vourarrest.
BY TIIE COURT.
George E. Holler. President Judge
Mail topics on Petitioner
5-12-00 to: < Respondent
Jordan Cunningham. Esquire
Sam Andes. Esquire
Date of Order: Mav 12, 2000
\ R. !
v. Confcrcncc Ofl ccr l
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 TIIE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY CET
LEGAL ItELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVE.
CARLISLE. PENNSYLVANIA 17013
(717) 2+9-3 166
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BRENDA L. McINTYRE,
Plaintiff
v.
JON H. NCINTYRE,
Defendant
IN THE COURT OP CCMMION PLEAS
C'Ut.jp-RT TD COUNTY, PENNSYLVANIA
NO. 99-6756 CIVIL TERN
DIVORCE
PETITION FOR ALIMONY PENDENTE LITE
TO THE HONORABLE, THE JUDGES OF SAID COURT,
AND NOW, comes Plaintiff/Petitioner Brenda L. NcIntvre,
by and through her counsel Cunningham & Chernicoff, P.C. and
files her Petition for Alimony Pendente Lite and in support
thereof avers as follows:
Petitioner is Brenda L. McIntyre, an adult
individual residing at 1715 Locust Street, New Cumberland,
Cumberland County, Pennsylvania 17070.
2. R°:;condant is ion H. McIntyre, an adult individual
residing at 604 Second Street, New Cumberland, Cumberland
County, PerinsvIvania 17070.
;. P-titione_ and Respondent were :Harried on May 15,
1986 in New Cumberland, Pennsylvania and separated on or about
March, 1999
4. Respondent has not sufficiently provided support for
the Petitioner. Respondent has also removed Petitioner from
his health insurance policy.
5. Petitioner believes and therefore avers that
Respondent is employed by Mac's-N-PC's located at 3804
Rosemont Avenue, Camp Hill, Pennsylvania. Petitioner believes
and therefore avers that Respondent's net monthly income,
exclusive of his side computer business is $2,387.00. The
Respondent's social security number is 191-46-1111.
6. Petitioner is currently employed by George's
Cleaners and earns approximately $1,01.9.90 monthly net.
Petitioner's social security number is 177-52-7365.
7. Petitioner is not receiving public assistance.
8. The amount asked for by the Petitioner for Alimony
Pendente Lite is the maximum amount allowable by law.
WHEREFORE, Petitioner, Brenda L. McIntyre, respectfully
requests `hat this Honorable Court grant her Petition and
enter an Order of Alimony Pendente L ite against Respondent, as
well as recquire the Respondent to provide health insurance for
Petitioner , and further award Petitioner all such other relief
as is prop -er and just.
Respectfully submitted,
CUNNINGHA.M & CHERNICOFF, P.C.
Date: By;? a n .:.?•.nsn? „n_ v .1?'u;`}I ha. ,1
Paige Macdonald-Mat thes, Esquire
I.D. #66266
2320 North Second Street
P.O. Box 60457
Harrisburg, PA 17106-0457
(717) 238-6570
(Attorneys for Petitioner)
VERIFICATION
I, Brenda L. McIntyre, verify that the statements made in
the foregoing Petition are 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 unsworn
falsification to authorities.
enda L. McIntyre
Date: ?uDv
CERTIFTCATF. OF SERVFCE
I, Paige Macdonald-Matthes, Esquire, do hereby certify
that a true and correct copy of the Petition for Alimony
Pe ndente Lire in the above-captioned matter was placed in the
United States Mail, first class delivery, in Harrisburg,
Pennsylvania on March 7, 2000, on the following:
Samuel L. Andes, Esquire
525 N. 12th Street
P. 0. Bor. 168
Lemoyne, PA 170,13
Respectfully submitted,
CUNNINGHAM & CHERNICOFF, P.C
Date: March 7, 2000 Bv:J\ L•.. PX i•:_n .. ,.'1_Yi: r:.. - lv, Yr-r(tL
Paige Macdonald-Matthes, Esquire
I.D. #66266
2320 North Second Street
P.O. Box 60457
Harrisburg, PA 17106-0457
(717) 238-6570
.. .-. .??,:.revv..,e?'eergex?vu!nvevccrn,ee-.?'.?>S_^_.x_,•"lt?C_'S -
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
BRENDA L. MCINTYRE ) Docket Numher 99-6756 CIVIL
Plaintiff )
VS. ) PACSES Case Number 596102278/D29,654
JON H. MCINTYRE )
Defendant ) Other State ID Number
ORDER
AND NOW, to wit on this 15TH DAY OF JUNE, 2000 IT IS HEREBY
ORDERED that the Q Complaint for Support or Q Petition to Modify or ® Other
ALIMONY PENDENTE LITE filed on MARCH 9, 2000 in the above captioned
matter is dismissed without prejudice due to:
DUE TO HUSBAND HAVING THE CARE AND CUSTODY OF THE PARTIES' SON AND PURSUANT
TO RULE 1910 .16-4 (1) (e) .
O The Complaint or Petition maybe reinstated upon written application of the plaintiff
petitioner.
BY
DRO: RJ Shadday
xC:
xc plaint.iff
defendant
Jordan Cunningham, Esquire Edward E. Guido
Samuel Andes, Esquire
t)i2a[:c! G ;i6 Db (,-)
Farm OE-506
Service Type M Worker ID 21005
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JON H. McINTYRE,
Plaintiff.
V.
BRENDA L. McINTYRE,
Defendant
!N THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6756
CIVIL ACTION-LAW
IN DIVORCE
DEFENDANT'S ANSWER TO PLAINTIFF'S AMENDED COMPLAINT IN
DIVORCE, TOGETHER WITH COUNTERCLAIM
AND NOW, comes the Defendant, Brenda L. McIntyre, by and
through her counsel, Cunningham & Chernicoff, P.C., and files
her Answer and Counterclaim to the Complaint in Divorce filed
by Plaintiff, Jon H. McIntyre, and in support thereof avers as
follows:
1. Admitted.
2. Admitted.
3. Admitted.
4. Admitted.
5. Admitted.
6. Admitted.
,.
7. Defendant is without knowledge sufficient to form a
belief as to the truth of the averments set forth in Paragraph
7 of the Plaintiff's Complaint, and strict proof, if relevant,
is demanded at the time of trial.
8. Admitted.
WHEREFORE, Defendant requests that this Honorable Court
enter a Decree in Divorce dissolving the marriage between the
parties pursuant to Section 3301(c) of the Divorce Code of
1980, as amended.
COUNTERCLAIM
9, The answers set forth in Paragraphs 1-8 are
incorporated herein as more fully set forth in length.
10. Plaintiff and Defendant were married on May 15, 1986
in Lower Allen Township, Cumberland County, Pennsylvania.
11. There has been no prior action for divorce or
annulment between the parties.
2
12. Defendant has been advised of the availability of
counselin g and the right to request that the Court require the
parties to participate in counseling.
13. Defendant/Counterclaim Plaintiff is not a member of
the Armed Services.
14. Defendant/Countercla.im Plaintiff avers that the
ground on which the action is based is an irretrievable
breakdown of the marriage.
15. Defendant/ Counterclaim Plaintiff further avers that
the parties have been living separate and apart since March,
1999.
WHEREFORE, Defendant/Counterclaim Plaintiff respectfully
requests that this Honorable Court enter a Decree of Divorce
dissolving the marriage between the parties pursuant to
Section 3301(c) of the Divorce Code of 1980, as amended.
3
COUNT II- EQUITABLE DISTRIBUTION
16. The averments in Paragraphs 1 through 15, inclusive,
are incorporated herein by reference thereto.
17. During the course of the marriage, the parties
acquired marital property.
WHEREFORE, the Defendant /Counterclaim Plaintiff requests
the Court to equitably determine, divide, distribute and
assign the marital property of the parties pursuant to Section
3501 of the Divorce Code.
COUNT III - ALIMONY, ALIMONY PENDENTE LITE AND COUNSEL FEES
18. Paragraphs 1 through 17, inclusive, are incorporated
herein by reference thereto.
19. Defendant/Counterclaim Plaintiff lacks sufficient
property to provide and pay for expenses of this action,
including her reasonable counsel fees, nor to provide for her
maintenance and support.
WHEREFORE, Plaintiff requests the Court to enter an Order
granting Defendant /Counterclaim Plaintiff reasonable counsel
fees and expenses, alimony pendente lite and alimony.
Respectfully submitted,
CUNNINGHAM & CHERNICOFF, P.C.
Date:
Paige Macdonald -Mat thes, Esquire
I.D. #66266
2320 North Second Street
P.O. Box 60457
Harrisburg, PA 17106-0457
(717) 238-6570
(Attorneys for Defendant)
5
VERIFICATION
I, Brenda L. McIntyre, verify that the statements made in
the foregoing Answer and Counterclaim are 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.A. Section 4901, relating to
unsworn falsification to authorities.
Date:
3kenda L. McIntyre
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AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA :
COUNTY OF DAUP11IN
ss;
I, Brenda L. McIntyre, being duly sworn according to law,
depose and say:
(1) I have been advised of the availability
of marriage counseling and understand that I may
request that the Court require that my spouse and I
participate in counseling.
(2) I understand that the Court maintains a
list of marriage counselors in the Domestic
Re'_at;cns Office, which list is available to me
upon request.
(3) Being so advised, I do not request that
the Court require that my spouse and I participate
in counseling prior to a Divorce Decree being
handed down by the court.
I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. §4904 relating to
unsworn falsification to authorities.
Brenda L. McIntyre /
SWORN and Subscribed to
Before( me this / day
of -?J-e(1 1999.
vot'IY n! seal
/ C, rm J ?'1? Lo, Notary Public
LCmoyrr Boro Cumberland County
M1'y Comm t r c I r, es FeU 25, 2002
L?NOTA. I ?,-i3BLIC -
AFFIDAV?'f Oi__.??=•._?._rr,_•?quy SERVICE
COMMONWEALTH OF PENNSYLVANIA
ss;
COUNTY OF DAUPHIN
The Defendant, being duly sworn according to law, deposes
and says that she is the Defendant in the above captioned
matter and that she personally knows that the Plaintiff is
over the age of eighteen (18) years.
The Defendant further avers that the Plaintiff is not in
the Military Service or in any branch of the Armed Forces of
the un it-d States of America o! _ts Allies or otherwise within
the provisions of the Soldiers' and Sailors' Civil Relief Act
of Congress of 1940 and its Amendments.
Brenda L. McIntyre
SWORN and subscribed to
Before me this day
of /)cC 1999
. - Notarial M, '
Carrnrs J. ClauUio, Notary Pudic
L,moyne Ebro. Cumberland County
Cxvniis E%PIraS F011.25, 2002
CERTIFICATE OF SERVICE
I, Paige Macdonald-Matthes, Esquire, do hereby certify
that a true and correct copy of the Defendant's Answer to
Plaintiff's Complaint in Divorce and Counterclaim in the
above-captioned matter was placed in the United States Mail,
first class delivery in Harrisburg, Pennsylvania on this date,
on the following:
Samuel L. Andes, Esquire
525 North Twelfth Street
P.O. Box 168
Lemoyne, PA 17043
Respectfully submitted,
CUNNINGHAM & CHERNICOFF, P.C.
Date: By:4li:no •.na?1, ,,r.1 -1: _,.:,.... ,>
Paige facdonald-Matthes, Esquire
I.D. #66266
2320 North Second Street
P.O. Box 60457
Harrisburg, PA 17106-0457
(717) 238-6570
7