HomeMy WebLinkAbout03-3939FRANKLIN H. BLOUCH, JR.,
Plaintiff
V.
BARBARA J. BLOUCH,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
CIVIL ACTION-FAMILY DIVISION
NO-
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 at the Office of the
Prothonotary at Cumberland County Courthouse, 1 Courthouse Square, 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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
Telephone: 717-249-3166
Jame Snell, Esquire
Attorney I.D. #18038
250 South Eighth Street
Lebanon, PA 17042
Telephone: 717-273-4555
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities 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.
FRANKLIN H. BLOUCH, JR.
Plaintiff
V.
BARBARA J.BLOUCH,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
CIVIL ACTION-FAMILY DIVISION
NO. 03- 3g3q
IN DIVORCE
COMPLAINT IN DIVORCE
UNDER §3301(c) OF THE DIVORCE CODE
The Plaintiff is Franklin H. Blouch, Jr., who currently resides at 2306 Marion View Drive,
Harrisburg, Dauphin County, Pennsylvania.
2. The Defendant is Barbara J. Blouch, who currently resides at 1195 Cross Creek Drive,
Mechanicsburg, Cumberland County, Pennsylvania.
3. The Plaintiff and Defendant have been bona fide residents in 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 February 8, 1986, in Cleona, Pennsylvania.
5. There have been no prior actions of divorce or for annulment of marriage between the
parties hereto in this or in any other jurisdiction.
COUNT I - DIVORCE
6. Paragraphs I through 5 above are incorporated herein by reference as if textually set forth
at length.
7. The marriage is irretrievably broken.
8. Plaintiff has been advised of the availability of counseling and is aware that she may have
the right to request that the Court require the parties to participate in counseling.
WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce.
COUNT II
EOUITABLE DISTRIBUTION
9. The allegations contained in paragraphs I through 8 are incorporated herein by reference
thereto as if textually set forth at length.
10. Plaintiff and Defendant have acquired property, both realty and personalty, during their
marriage which would constitute marital property for the purpose of equitable distribution.
WHEREFORE, Plaintiff requests your Honorable Court to make an equitable distribution of
the parties' marital property.
James A. Snel , Esquire
Attorney for Plaintiff
Attorney I.D. #18038
250 South Eighth Street
Lebanon, PA 17042
Telephone: 717-273-4555
VERIFICATION
I verify that the statements made in this Complaint 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 unworn
falsification to authorities.
Date: 2??7/IiLE- ?OD? Cnklin H. Blouch,
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FRANKLIN H. BLOUCH, JR.,
Plaintiff
V.
BARBARA J.BLOUCH,
Defendant
TO THE PROTHONOTARY:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
CIVIL ACTION-FAMILY DIVISION
NO. n3 -,3`T3P
IN DIVORCE
PRAECIPE
Ca c_ L `7a?
Please enter the appearance of James A. Snell, Esquire, whose address is 250 South Eighth
Street, Lebanon, Pennsylvania 17042, as attorney for the Plaintiff, Franklin H. Blouch, Jr., in the
above-referenced action.
J es A. Sn XlEs quire
Attorney for Plaintiff
Attorney I.D. #18038
250 South Eighth Street
Lebanon, PA 17042
Telephone: 717-273-4555
FRANKLIN H. BLOU H, JR., IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND CO., PENNSYLVANIA
CIVIL ACTION-FAMILY DIVISION
V. IN DIVORCE
BARBARA J.
NO. 03-3939
AFFIDAVIT OF SERVICE
JAMES A. SN LL, ESQUIRE, being duly sworn according to law, deposes and says that
he mailed or caused to be mailed a true and correct copy of the Complaint in the above-captioned
action to the Defendan , Barbara J. Blouch, by United States Certified Mail, No. 7099-3400-
0007-7319-7136, on gust 14, 2003, return receipt requested, and said return receipt is attached
hereto and made a part hereof.
JAMES A. SNELL, ESQ E
Attorney for Defendant
Attorney I.D. #18038
250 South Eighth Street
Lebanon, PA 17042
Telephone: 717-273-4555
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ay of 2003.
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¦ A mailing receipt
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important Reminders: ?1I
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¦ For an additional fee, a Return Receipt may be requested to rovide proof of
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¦ For an additional fee, delivery may'ne«stricted to the addressee or
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IMPORTANT: Save this receipt and present it when making an Inquiry.
P6 Fomi3800. Ally 1999 (Reverse) 102595-99-M-2087
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item 4 if Restrict d Delivery is desired.
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¦ Attach this card the back of the mailpiece,
or on the front if pace permits.
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Revised'. 59/05 2.02PM
ennifer L. Spears, Esquire
4ARTSON DEARDORFF WILLIAMS & OTTO
D. 87445
0 East High Street
arlisle, PA 17013
717) 243-3341
.ttornevs for Defendant
H. BLOUCH, JR., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 03-3939
CIVIL ACTION - LAW
J. BLOUCH,
Defendant JURY TRIAL DEMANDED
PRAECIPE
THE PROTHONOTARY OF CUMBERLAND COUNTY:
Enter the appearance of MARTSON DEARDORFF WILLIAMS & OTTO on behalf of
in the above-captioned matter.
MAR N EARDORFF WILLIAMS & OTTO
By
ennifer L. pears, Esquire
10 East High Street
Carlisle, PA 17013
(717) 243-3341
May 3, 2005 Attorneys for Defendant
CERTIFICATE OF SERVICE
I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby
that a copy of the foregoing Praecipe was served this date by depositing same in the Post
at Carlisle, PA, first class mail, postage prepaid, addressed as follows:
James A. Snell, Esquire
250 South Eighth Street
Lebanon, PA 17042
MARTSON DEARDORFF WILLIAMS & OTTO
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Ten East High Street
Carlisle, PA 17013
(717) 243-3341
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FRANKLIN H. BLOUCH, JR.
vs Case No. 03-3939
BARBARA J. BLOUCH
Statement of Intention to Proceed
To the Court:
Defendant, Barbara Blouch, intends to pr ceed with the above captioned matter.
A)%L---7
Print Name Jennifer L. Spears, Esq. Sign Name
Date: September 22 2008 Attorney for Defendant
Explanatory Comment
The Supreme Court of Pennsylvania has promulgated new Rule of Civil Procedure 230.2 governing the termination of
inactive cases and amended Rule of Judicial Administration 1901. Two aspects of the recommendation merit
comment.
1. Rule of civil Procedure
New Rule of Civil Procedure 230.2 has been promulgated to govern the termination of inactive cases within the
scope of the Pennsylvania Rules of Civil Procedure. The termination of these cases for inactivity was previously
governed by Rule of Judicial Administration 1901 and local rules promulgated pursuant to it. New Rule 230.2 is
tailored to the needs of civil actions. It provides a complete procedure and a uniform statewide practice, preempting
local rules.
This rule was promulgated in response to the decision of the Supreme Court in Shop v. Eagle, 551 Pa. 360,710 A.2d
1104 (1998) in which the court held that "prejudice to the defendant as a result of delay in prosecution is required
before a case may be dismissed pursuant to local rules implementing Rule of Judicial Administration 1901."
Rule of Judicial Administration 1901(b) has been amended to accommodate the new rule of civil procedure. The
general policy of the prompt disposition of matters set forth in subdivision (a) of that rule continues to be applicable.
11 Inactive Cases
The purpose of Rule 230.2 is to eliminate inactive cases from the judicial system. The process is initiated by the
court. After giving notice of intent to terminate an action for inactivity, the course of the procedure is with the parties.
If the parties do not wish to pursue the case, they will take no action and "the Prothonotary shall enter an order as of
course terminating the matter with prejudice for failure to prosecute." If a party wishes to pursue the matter, he or she
will file a notice of intention to proceed and the action shall continue.
a. Where the action has been terminated
If the action is terminated when a party believes that it should not have been terminated, that party may proceed
under Rule230(d) for relief from the order of termination. An example of such an occurrence might be the termination
of a viable action when the aggrieved party did not receive the notice of intent to terminate and thus did not timely file
the notice of intention to proceed.
The timing of the filing of the petition to reinstate the action is important. If the petition is filed within thirty days of
the entry of the order of termination on the docket, subdivision (d)(2) provides that the court must grant the petition and
reinstate the action. If the petition is filed later than the thirty-day period, subdivision (d)(3) requires that the plaintiff
must make a show in to the court that the petition was promptly filed and that there is a reasonable explanation or
legitimate excuse both for the failure to file the notice of intention to proceed prior to the entry of the order of
termination on the docket and for the failure to file the petition within the thirty-day period under subdivision (d)(2).
B. Where the action has not been terminated
An action which has not been terminated but which continues upon the filing of a notice of intention to proceed may
have been the subject of inordinate delay. In such an instance, the aggrieved party may pursue the remedy of a
common law non pros which exits independently of termination under Rule 230.2.
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FRANKLIN H. BLOUCH, JR.,
vs
Plaintiff Case No. 03-3939
BARBARA J. BLOUCH, Defendant
Statement of Intention to Pro0ed
To the Court:
Franklin H. Blouch, Jr., Plaintiff intends to proceed with the above captioned matter.
Print Name James A. Snell
Sign Name Q K.[r
Date: October 7, 2008 Attorneyfor Franklin H Blouch, Jr.
Explanatory Comment
The Supreme Court of Pennsylvania has promulgated new Rule of Civil Procedure 230.2 governing the termination of
inactive cases and amended Rule of Judicial Administration 1901. T;o aspects of the recommendation merit
comment.
1. Rule of civil Procedure
New Rule of Civil Procedure 230.2 has been promulgated to govern th termination of inactive cases within the
scope of the Pennsylvania Rules of Civil Procedure. The termination of these cases for inactivity was previously
governed by Rule of Judicial Administration 1901 and local rules promulgated pursuant to it. New Rule 230.2 is
tailored to the needs of civil actions. It provides a complete procedure and. a uniform statewide practice, preempting
local rules.
This rule was promulgated in response to the decision of the Supreme Court in Shop v. Eagle, 551 Pa. 360,710 A.2d
1104 (1998) in which the coup: held that "prejudice to the defendant as a result of delay in prosecution is required
before a case may be dismissed pursuant to local rules implementing Rule of judicial Administration 1901."
Rule of Judicial Administration 1901(b) has been amended to accommodate the new rule of civil procedure. The
general policy of the prompt disposition of matters set forth in subdivision (a of that rule continues to be applicable.
II Inactive Cases
The purpose of Rule 230.2 is to eliminate inactive cases from the judicial system. The process is initiated by the
court. After giving notice of intent to terminate an action for inactivity, the course of the procedure is with the parties.
If the parties do not wish to pursue the case, they will take no action and "the Prothonotary shall enter an order as of
course terminating the matter with prejudice for failure to prosecute." If a party wishes to pursue the matter, he or she
will file a notice of intention to proceed and the action shall continue.
a. Where the action has been terminated
If the action is terminated when a party believes that it should not have been terminated, that party may proceed
under Rule230(d) for relief from the order of termination. An example of such an occurrence might be the termination
of a viable action when the aggrieved party did not receive the notice of intent to terminate and thus did not timely file
the notice of intention to proceed.
The timing of the filing of the petition to reinstate the action is important. f the petition is filed within thirty days of
the entry of the order of termination on the docket, subdivision (d)(2) provide that the court must grant the petition and
reinstate the action. If the petition is filed later than the thirty-day period, s division (d)(3) requires that the plaintiff
must make a show in to the court that the petition was promptly filed and that there is a reasonable explanation or
legitimate excuse both for the failure to file the notice of intention to pr ceed prior to the entry of the order of
termination on the docket and for the failure to file the petition within the thin -day period under subdivision (d)(2).
B. Where the action has not been terminated
An action which has not been terminated but which continues upon the Eiji g of a notice of intention to proceed may
have been the subject of inordinate delay. In such an instance, the aggri ved party may pursue the remedy of a
common law non pros which exits independently of termination under Rule 2 0.2.
i
FRANKLIN BLOUCx JR. : Lti THE COURT OF CO-NMON PLEAS OF
: CU_% BERL:\ti-D COUNTY, PE:.tiSYLN,'AN'IA
Plaintiff
Vs.
BARBARA J BLOUCH Docket No. 03-3939
Defendant
MOTION FOR APPOINTMENT OF MASTER
BARBARA J. BLOUCH ( (Defendant), moves the court to appoint a master with
respect to the following claims:
Divorce fix) Distribution of Property
O Annulment O Support
)kX) Alimony Counsel Fees
() Alimony Pendente Lite Costs and Expenses
and in support of the motion states:
(1) Discovery is complete as to the claims (s) for which the appointment of a master is
requested. Plaintiff
(2) The do t (has) Omxm* appeared in the action ( 10 (by his attorney,
James A. Snell , Esquire).
(3) The Staturory ground (s) for divorce (is) (are)
Irretrievable breakdown
(4) Delete the inapplicable paragraph(s):
a. The action is not contested.
$KX An agreement has been reached with respect to the following claims:
c. The action is contested with respect to the following claims:
All of the above.
(S) The action (hrm#%Wdoes not involve) complex issues of law or fact
(6) The hearing is expected to take 1 (b n Xdays).
(7) Additional information, if any, relevant to the motion:
None.
Date: November 18, 2008
do r?yo r(tctt(Defendant?
Print Attorney Name ......... Jennifer L. Spears, Esquire
ORDER APPOINTING MASTER
,kND NOW, , 20 ------Esquire
is appointed master with respect to ,he fol owing claims:
By the Court:
C7 C `
F1
.A+
NOV 2 '1 Z008A
FRANKLIN BLOUCH JR.
Plaintiff
Vs.
RARRARA J BLOUCH
Defendant
THE COURT OF CO-NLN10:N PLEAS OF
CUMBERLAN-D OLNTY, PENNSYL`"ANIk
Docket No. 03-
BARBARA J BLOUCH (M&M (Defendant), moves tk
respect to the following claims:
Divorce Distribution of
(} Annulment ( ) Support
Alimony IE? Counsel Fees
(} Alimony Pendente Lite Costs and Expc
and in support of the motion states:
(1) Discovery is complete as to the claims (s) for whi,
requested. Plaintiff
(2) The dot (has) Omxm* appeared in the act
James A. Snell , Esquire).
(3) The Staturory ground (s) for
Irretrievable breakdown
(4) Delete the inapplicable paragraph(s):
a. The action is not contested.
XXX An agreement has been reached with re ect to the following claims:
c. The action is contested with respect to the following claims:
All of the above.
(5) The action (hw#v4VKdoes not involve) complex issu of law or fact
(6) The hearing is expected to take s (yhe?days).
(7) Additional information, if any, relev t to the motion:
Date: November 18, 2008_-
A orn y or (fl( efendant)
Print Attorney Name ......... Jennifer L. S ears Esquire
ORDER APPOINTiltiGjKSTE
A -7-
NOW, `I??-URIC QC/, 20OA_, squire
AND
is appointed master with respect to tl:e following claims:
By th ourt:
court to appoint a master with
the appointment of a master is
(p asoc dbA (by his attorney,
divorce (is) (are)
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F:\F1LES\C1ients\11595 Blouch\11595.1.mventory.wpd
Revised: 11/20/08 11:25AM
Jennifer L. Spears, Esquire
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
I.D. No. 87445
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Defendant
FRANKLIN H. BLOUCH, JR.,
Plaintiff
V.
BARBARA J. BLOUCH,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03-3939
CIVIL ACTION - LAW
IN DIVORCE
INVENTORY OF BARBARA J. BLOUCH. DEFENDANT
PURSUANT TO Pa. R.C.P. 1920.33(a)
Barbara J. Blouch, Defendant files the following Inventory of all property owned or possessed
by either party at the time this action was commenced and all property transferred within the
preceding three years.
Defendant verifies that the statements made in this inventory are true and correct.
Defendant understands that false statements herein are made subject to the penalties of 18 Pa.
C.S. 4904 relating to unswom falsification to authorities.
Date Barbara J. Blou , Defendant
??,
ASSETS OF PARTIES
Barbara J. Blouch, Defendant, marks on the list below those items applicable to the case at bar
and itemizes the assets on the following pages.
( X) 1. Real property
( X ) 2. Motor vehicles
( X) 3. Stocks, bonds, securities and options
( X) 4. Certificates of deposit
( X) 5. Checking accounts, cash
( X) 6. Savings accounts, money market and savings certificates
( ) 7. Contents of safe deposit boxes
( ) 8. Trusts
( ) 9. Life insurance policies
( ) 10. Annuities
( ) 11. Gifts
( X) 12. Inheritances
( ) 13. Patents, copyrights, inventions, royalties
( ) 14. Personal property outside the home
( X) 15. Businesses
( ) 16. Employment termination benefits-severance pay, workers' compensation
claim/award
( ) 17. Profit-sharing plans
( X) 18. Pension plans (indicate employee contribution and date plan vests)
( X) 19. Retirement plans, Individual Retirement Accounts
( ) 20. Disability payments
( ) 21. Litigation claims (matured and unmatured)
( ) 22. MilitaryN.A. benefits
( ) 23. Education benefits
( ) 24. Debts due, including loans, mortgages held
( ) 25. Household furnishings and personalty
( ) 26. Other
LIABILITIES OF PARTIES
Barbara J. Blouch, Defendant, marks on the list below those items applicable to the case at bar
and itemizes the liabilities on the following pages.
SECURED
( ) 1. Mortgages
() 2. Judgments
() 3. Liens
() 4. Other secured liabilities
UNSECURED
O 5. Credit card balances
() 6. Purchases
() 7. Loan payments
() 8. Notes payable
() 9. Other unsecured liabilities
CONTINGENT OR DEFERRED
() 10. Contracts or agreements
O 11. Promissory notes
() 12. Lawsuits
O 13. Options
() 14. Taxes
() 15. Other contingent or deferred liabilities
MARITAL PROPERTY
Barbara J. Blouch, Defendant, lists all marital property in which either or both spouses have a legal or
equitable interest individually or with any other person as of the date this action was commenced:
Item Number Description of Property
Names of all Owners
1 Sandhill Road - rental property Husband & Wife
2 Antique cars Husband
3 AFLAC stock Husband & Wife
3 EXELON stock Husband
3 FULTON stock Husband
3 HERSHEY stock Husband
3 INTEL stock Husband & Wife
3 MOTOROLA stock Husband & Wife
3 WACHOVIA stock (to become Wells Fargo) Husband & Wife
3 NORTHWEST BANCORP Wife
3 USAA Cornerstone Husband & Wife
3 USAA S&P 500 Husband & Wife
3 USAA Asset Management Husband & Wife
3 Savings bonds Husband & Wife
5 Commerce checking Husband & Wife
6 Commerce savings Husband & Wife
6 NCFCU (rental property) Husband
15 Travel Agency- Carlson Wagonlit Husband & Wife
18 Military pension (In pay status) Husband
19 Edward Jones Husband & Wife
19 MFS Wife
19 American Funds Wife
19 USAA SEP IRA Wife
19 Greystone IRA Wife
NON-MARITAL PROPERTY
Defendant Barbara J. Blouch lists all property in which a spouse had a legal or equitable interest which is
claimed to be excluded from marital property:
Item Number Description of Property
3 EXELON stock ($6,121 inherited)
3 FULTON stock ($6,272 inherited)
3 HERSHEY stock ($5,075 inherited)
3 WACHOVIA stock ($1,615 inherited)
Names of all Owners
Husband
Husband
Husband
Husband (but put into joint names)
LIABILITIES
Item Description Names of all Balance at
Number of Liabilities Creditors Separation
n/a
CERTIFICATE OF SERVICE
I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby
certify that a copy of the foregoing Inventory was served this date by depositing same in the Post
Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows:
James A. Snell, Esquire
250 South Eighth Street
Lebanon, PA 17042
MARTSON DEARDORFF WILLIAMS & OTTO
Y
ricia D. Eckenroad
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: November 24, 2008
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Created: 9/20/04 0:06PM
Revised: 11118/08 3:31PM
Jennifer L. Spears, Esquire
MARTSON DEARDORFF WILLIAMS & OTTO
I.D. 87445
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Defendant
FRANKLIN H. BLOUCH, JR.,
Plaintiff
V.
BARBARA J. BLOUCH,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03-3939
CIVIL ACTION - LAW
: IN DIVORCE
PETITION RAISING ECONOMIC CLAIMS
AND NOW, comes the Petitioner, Barbara J. Blouch, by and through her attorneys,
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, and sets forth the following
in conjunction with the above captioned divorce action:
1. Petitioner is Defendant in the above captioned divorce action.
2. Petitioner requests the Court to equitably divide, distribute or assign the marital
property between the parties without regard to marital misconduct in such proportion as the Court
deems just after consideration of all relevant factors.
3. Petitioner is unable to sustain herself during the course of litigation.
4. Petitioner has employed Jennifer L. Spears, Esquire to represent her in this
matrimonial cause.
5. Petitioner is unable to pay her counsel fees, costs and expenses and Plaintiff is more
than able to pay them.
6. Plaintiff is employed and has the ability to pay Petitioner's counsel fees, costs and
expenses.
7. Reserving the right to apply to the Court for temporary counsel fees, costs and
expenses prior to final hearing, Petitioner requests that, after final hearing, the Court order Plaintiff
to pay Petitioner's reasonable counsel fees, costs and expenses.
8. Petitioner lacks sufficient property to provide for her reasonable needs and is unable
to sustain herself through appropriate employment.
9. Petitioner requests the Court to enter an award of spousal support and/or alimony
pendente lite until final hearing and thereupon to enter an order of alimony in her favor pursuant to
Sections 3701(a) and 3702 of the Divorce Code.
WHEREFORE, Petitioner respectfully requests the Court:
a. To enter an award of spousal support, alimony pendente lite until final
hearing and thereupon to enter an order of alimony in her favor pursuant to
Sections 3701(a) and 3702 of the Divorce Code;
b. To enter an order directing Defendant to pay Plaintiffs reasonable counsel
fees, costs, and expenses; and
c. To enter an Order of equitable distribution of marital property pursuant to
Section 3502(a) of the Divorce Code.
MARTSON LAW OFFICES
Date: Ito
By
Jennifer L ears,
10 East Hi Street
Carlisle, PA 17013
(717) 243-3341
Esquire
Attorneys for Petitioner, Barbara J. Blouch
VERIFICATION
The foregoing Petition is based upon information which has been gathered by my counsel
in the preparation of the lawsuit. The language of the document is that of counsel and not my own.
I have read the document and to the extent that the document is based upon information which I have
given to my counsel, it is true and correct to the best of my knowledge, information and belief. To
the extent that the content of the document is that of counsel, I have relied upon counsel in making
this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities, which provides that if I make knowingly false
averments, I may be subject to criminal penalties.
?QIL?-Qn .1:1YOt??
Barbara J. Blo ch
CERTIFICATE OF SERVICE
I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby
certify that a copy of the foregoing Petition Raising Claims was served this date by depositing same
in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows:
James A. Snell, Esquire
250 South Eighth Street
Lebanon, PA 17042
MARTSON DEARDORFF WILLIAMS & OTTO
By P.-, 44A- -
ri is D. Eckenroad
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: November 24, 2008
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Created: 9/20/04 0:06PM
Rcvised: 1/27/09 10:02AM
Jennifer L. Spears, Esquire
MARTSON DEARDORFF WILLIAMS & OTTO
I.D. 87445
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Defendant
FRANKLIN H. BLOUCH, JR., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 03-3939
CIVIL ACTION - LAW
BARBARA J. BLOUCH,
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on
August 12, 2003.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention
to request entry of the decree.
I verify that the statements made in this affidavit 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: 1Ln ?? d q &2IZIL)IL Barbara J. Blouch, efendant
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Jennifer L. Spears, Esquire
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
I.D. No. 87445
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Defendant
FRANKLIN H. BLOUCH, JR., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 03-3939
CIVIL ACTION - LAW
BARBARA J. BLOUCH,
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on or about
June 27, 2003.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing and 'service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention
to request entry of the decree.
I verify that the statements made in this affidavit 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.
21 1 f
Date:
Barbara J. Blo ch, Defendant
f tir,
ALE 1 1fivy
rip
OF THEE ;,
2009 APR 20 AM 9: 03
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Jennifer L. Spears, Esquire
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
I.D. No. 87445
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Defendant
FRANKLIN H. BLOUCH, JR.,
Plaintiff
V.
BARBARA J. BLOUCH,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03-3939
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
&3301(c) AND § 3301(d) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I 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.
I verify that the statements made in this waiver 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: WJ2 1 `7,? ,l / d ry, -
Barbara J. B Ouch, Defendant
FILED-C - G=
OF i-l ppCk7?. (?No ARY
2009 APR 20 AM 91:04
FRANKLIN H. BLOUCH, JR.,
Plaintiff
VS.
BARBARA J. BLOUCH,
Defendant
CIVIL DIVISION
2003-3939
CIVIL
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PRAECIPE TO TRANSMIT RECORD
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To the Prothonotary:
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Transmit the record, together with the following information to the court for entry of a divo ce n~>
decree:
1. Ground for divorce:
Irretrievable breakdown under 3301 (c)
~&Itlof the Divorce Code.
(Strike out inapplicable section)
2. Date and manner of service of the complaint:
U.S. Certified Mail No. 7099-3400-0007-7319-7136, on August 14, 2003, return receipt filed October 24, 2003.
3. Complete either paragraph (a) or (b).
a. Date of execution of the affidavit of consent required by 3301 (c) of the
Divorce code:
by plaintiff June 28, 2010 ; by defendant July 12, 2010
b. (1) Date of execution of the affidavit required by 3301 (d) of the Divorce Code:
(2) Date of filing and service of the plaintiff's 3301 (d) affidavit upon the
respondent opposing party:
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:
Date of plaintiffs Waiver of Notice in 3301 (c) Divorce was filed with the
Prothonotary: July 27, 2010
Date defendant's Waiver of Notice in 3301 (c) divorce was filed with the
Prothonotary: July 27, 2010
Atto ey for Plaints fendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
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dUL 2 9 2010
FRANKLIN H. BLOUCH, JR., THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. N0. 03 - 3939 CIVIL
BARBARA J. BLOUCH,
Defendant IN DIVORCE
ORDER OF COURT
AND NOW, this day of ~ ,
2010, the economic claims raised in the proceedings having been
resolved in accordance with a marital settlement agreement
dated October 27, 2009, the appointment of the Master is
vacated and counsel can file a praecipe transmitting the record
to the Court requesting a final decree in divorce.
BY THE COURT,
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K in A. Hess, P.J.
cc: games A. Snell
Attoyney for Plaintiff .
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Jennifer L. Spears ~-• ~ ''
Attorney for Defendant ~ ~ - - ;=--
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FRANKLIN H. BLOUCH, JR.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
_ V,
BARBARA J. SLOUCH
NO.
2003-3939
DIVORCE DECREE
AND NOW, f / ~ 9 ~.1 ~ ~~, ~ ~ l U , it is ordered and decreed that
FRANKLIN H. SLOUCH, JR. plaintiff, and
BARBARA J. BLOUCH ,defendant, are divorced from the
bonds of matrimony.
Any existing spousal support order shall hereafter be deemed an order for
alimony pendente lite if any economic claims remain pending.
The court retains jurisdiction of any claims raised by the parties to this action
for which a final order has not yet been entered. Those claims are as follows: (If no
claims remain indicate "None.")
None. The agreement between the Plaintiff and the Defendant, dated October 27, 2009, a
copy of which is attached hereto, is incorporated but not merged into this Divorce Decree.
By the Court,
Attest: J.
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Pro onotary
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