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Home My WebLink About07-4299PETER C. BUCH, Plaintiff vs. LISA L. BUCH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.2007- ~.~4Q l.. r,~ ~L~~Q, CIVIL ACTION -LAW 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 marriage, you must request marriage counseling. A list of marriage counselors is avail- able 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 FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANI 17013 y MAX J. SMITH, ., Esquire JARAD W. HANDELMAN, Esquire Attorney for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 PETER C. BUCH, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PE/rNNSYLVANIA vs. N0.2007- •~,r~99 C_ic~~l.~E2. l LISA L. BUCH, :CIVIL ACTION -LAW Defendant IN DIVORCE COMPLAINT 1N DIVORCE AND NOW comes the Plaintiff, PETER C. BUCH, by his attorney, MAX J. SMITH, JR., Esquire, and seeks to obtain a Decree in Divorce upon the grounds hereinafter more fully set forth: 1. The Plaintiff, PETER C. BUCH, is an adult individual and citizen of the United States of America, whose address is 1275 Windsor Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. The Defendant, LISA L. BUCH, is an adult individual and citizen of the United States of America, whose address is 1275 Windsor Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on or about November 22, 1995 in Mechanicsburg, Pennsylvania. 5. Plaintiff avers that there are three (3) children of the parties under the age of 18, namely: MADISON T. BUCH, born May 24, 1996, SYDNEY T. BUCH, born July 31, 1998 and CHASE A. BUCH, born November 18, 2003. 6. Neither Plaintiff nor Defendant is a member of the United States Armed Services. 7. Plaintiff and Defendant have both been advised of the availability of marital counseling and that each may have the right to request that the court require the parties to participate in counseling. 8. Plaintiff avers that there has been no prior action for divorce or annulment of the marriage filed by either party in this or any other jurisdiction. 9. Plaintiff avers that the marriage is irretrievably broken. WHEREFORE, Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. Respectfully submitted, Date: July Za , 2007 MAX J. SMITH, JR. squire I.D. No. 32114 JARAD W. HANDELMAN, Esquire I.D. No. 82629 James, Smith, Dietterick & Connelly LLP P.O. Box 650 Hershey, PA 17033 (717) 533-3280 I verify that the statements made in this Complaint are true and correct. I under- stand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. ..~' ~L G~/ - ^, b ~ ~ (~ \ ~ l r...: C? `~, ..r C._. .T~t -" 'y.~~. ~~ ;~ .-t ~~ -n~~- `• t -~ ~ i ~`, t7 f ,~ _ ...~ PETER C. BUCH, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. N0.2007-4299 CIVIL TERM LISA L. BUCH, :CIVIL ACTION -LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this 23rd day of July, 2007, I, MAX J. SMITH, JR., Esquire, Attorney for Plaintiff, hereby certify that I have this day sent a copy of Complaint in Divorce by depositing a certified copy of the same in the United States mail, postage prepaid, certified mail #7006 2150 0004 2693 5666 at Hummelstown, Pennsylvania, addressed to: Lisa L. Buch 1275 Windsor Road Mechanicsburg, PA 17050-0626 Mailing and return receipt cards attached hereto. MA J. SMITH, JR., quire I.D. No. 32114 JARAD W. HANDELMAN, Esquire I.D. No. 82629 James, Smith, Dietterick & Connelly LLP P.O. Box 650 Hershey, PA 17033 (717) 533-3280 C7 ~ G ~~ ~ ~.~n~ V ~~~ ~~' -~, ~ , ~ - ~ ~~ ' ~~ ~'~ ~ . :~~ ~ '~ G17 ~C } ~ I~rr J v'f m ~ ~.. ~~ ^~ ti ~ s ~ O Certlfied Fee ~~k~( ~` G ~rrdorearnent ~rdrede j ~ ~ +J~~ ~ Restricted DeYvery Fee f~Q '~ p (Endorsement Required) ~. j O LJ ~ t," ~ Total Postage & Fees ~ ~ .4g ~~~~ 'rj' f~, ;/ ~ tTo t ~~~~~ O t~ or PO BoxNo..~~"1S (,~~ti ~~ - .. 7Siis viii:. ~- 42'75 ~,~,cleo'~'~-~o~ ~• ~~~n ~a .~ ~ ~ -r~ ~:.x- " ~ ..._, ~ ~ ~r1 'f1 ""y i ; i -" y t.~_ ... ~' s~: 'r} a ~ n t~ ~ i' ~ ~' c..: h? '~ -•C 4~ N SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. Paige Macdonald-Matthes, Esquire Attorneys for Defendant. Pa. Attorney I.D. No. 66266 2080 Linglestown Road, Suite 201 Harrisburg, PA 17110 (717) 540-9170 (717) 635-2952 (facsimile) --------------------------------------------------------------------------------------------------------------------- PETER C. BUCH :THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . N0.2007-4299 CIVIL TERM v. LISA L. BUCH, . CIVIL ACTION- LAW Defendant. : IN DIVORCE ----------------------------------------------------------------------------------------------------- DEFENDANT'S ANSWER TO DIVORCE COMPLAINT TOGETHER WITH COUNTERCLAIM AND NOW, comes Defendant, Lisa L. Buch, by and through her counsel, Serratelli, Schiffman, Brown & Calhoon, P.C., and files her Answer To Plaintiffls Complaint In Divorce and Counterclaim, and in support thereof avers as follows: 1. Admitted in part and denied in part. It is admitted that Plaintiff has an address located at 1275 Windsor Road, Mechanicsburg, Cumberland County, Pennsylvania. It is denied that Peter C. Buch lives at that address. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. Y 7. Admitted in part and denied in part. It is admitted that Defendant has been advised of the availability of marital counseling. Defendant is without knowledge sufficient to form a belief as to what Plaintiff may or may not been advised of regarding marital counseling and strict proof of the same is demanded at the time of hearing. 8. Admitted. 9. Admitted. WHEREFORE, Defendant requests that the Court enter a decree of divorce. COUNTERCLAIM FOR DIVORCE UNDER SECTIONS 3301(c) or 3301(d) OF THE DIVORCE CODE 10. The averments set forth in paragraphs 1 through 9 are incorporated herein by reference as if more fully set forth at length. 11. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Counterclaim. 12. The Plaintiff and Defendant were married on November 22, 1995, in Mechanicsburg, Pennsylvania. 13. There have been no prior actions of divorce or for annulment between the parties. 14. The marriage is irretrievably broken. 15. Defendant/Counterclaim Plaintiff (hereinafter "Defendant") has been advised that counseling is available and that Defendant may have the right to request that the Court require the parties to participate in counseling. 16. Defendant avers that there are children of the parties under the age of 18, namely: a. Madison T. Buch born 5/24/96 b. Sydney T. Buch born 7/31/98 c. Chase A. Buch born 11/18/03 WHEREFORE, Defendant requests the Court to enter a decree of divorce. COUNTERCLAIM FOR ALIMONY 17. The averments set forth in paragraphs 1 through 16 are incorporated herein by reference as if more fully set forth at length. 18. Defendant is unable to adequately support herself through appropriate employment. 19. Defendant lacks sufficient property, including but not limited to, any property distributed pursuant to the Divorce Code of 1980, as amended, to provide for her reasonable needs. WHEREFORE, Defendant respectfully requests that this Honorable Court issue an Order directing Plaintiff to pay alimony to Defendant. COUNTERCLAIM FOR ALIMONY PENDENT LITE, COUNSEL FEES AND COSTS 20. The averments set forth in paragraphs 1 through 19 are incorporated herein by reference as if more fully set forth at length. 21. By reason of the institution of this divorce action, Defendant will be and has been put to considerable expense in the preparation of her case, in the employment of counsel and the payment of costs. 22. Defendant's income is disproportionately lower than Plaintiff's income, or available income resources, and Defendant is without adequate funds to pay the costs and expenses of this litigation, and is likewise without adequate funds to maintain herself during the pendency of the litigation. 23. The Plaintiff is employed by Grudi Associates, Inc. Defendant is without knowledge as to Plaintiff s current gross monthly income but believes and therefore avers that it is in excess of $12,000. 24. The Defendant is unemployed. WHEREFORE, Defendant respectfully requests that this Honorable Court issue an Order directing Plaintiff to pay Defendant alimony pendent lite, counsel fees and costs of litigation. COUNTERCLAIM FOR EQUITABLE DISTRIBUTION 25. Paragraphs 1 through 24 are hereby incorporated by reference herein. 26. Plaintiff and Defendant possess various items of both real and personal marital property which is subject to equitable distribution by the court. 27. Defendant requests that this Court grant equitable distribution. WHEREFORE, Defendant respectfully requests that this Honorable Court: (a) Equitably distribute all property, personal and real owned by the parties; and (b) Grant such further relief as the Court may deem equitable and just. Respectfully submitted, Te~~ `~~~ Paige Macdonald-Matthes, Esquire Attorney ID No. 66266 SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road, Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorneys for Defendant/Counterclaim Plaintiff Date: November ~ , 2007 r vEiur~cATxort I verify that the statements made in the foregoing Answer To Complaint in Divorce and Countexclaim are true and correct. I understand that false statements herein are made subject to the penalties of l8 Pa. C.S. Section 49Q4, relating to unsworn falsification to authorities. Date: ,~J- ~- 0 ~ Lisa L. Buch CERTIFICATE OF SERVICE I, Paige Macdonald-Matthes, Esquire, counsel for the Defendant/Counterclaim Plaintiff in the above captioned matter, certify that I this day served a copy of the foregoing Answer To Complaint in Divorce together with Counterclaim upon the person(s) indicated below by United States First Class Mail, postage prepaid, at Harrisburg, Pennsylvania and addressed as follows: Jeffrey S. Shank, Esquire Gingrich Smith Klingensmith & Dolan 222 S Market, Suite 201 P.O. Box 267 Elizabethtown, PA 17022 Date: November ~, 2007 ~_au~ ~,~:-ae~e-o~,~~.~' Paige acdonald-Matthes, Esquire t-~ r•.~ ~` ; : -- ~~ ~~ '.,' ~ ~~ ~ M. ~~ ( _.~.-. ,~~ :~ ~ . ~fi. __- .~ '_'s _ ~~ ! .~ .. ~_,_ ,~ PETER C. BUCH, Plaintiff vs. LISA L. BUCH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.2007-4299 CIVIL ACTION -LAW IN DIVORCE PRAECIPE TO WITHDRAW APPEARANCE TO THE PROTHONOTARY: Please withdraw the appearance of Max J. Smith, Jr., Esquire as counsel for Peter C. Buch, Plaintiff in the above-captioned matter Date: November 12, 2007 Max J. Smith, Jr., Esq re I.D. No. 32114 James, Smith, Dietterick & Connelly LLr P.O. Box 650 Hershey, PA 17033 (717) 533-3280 PRAECIPE TO ENTER APPEARANCE TO 'THE PROTHONOTARY: Please enter the appearance of Jeffrey S. Shank, Esquire, as counsel for Peter C. Buch, Plaintiff in the above-captioned matter. Date: November ~ 2007 e y S. Shank, Esquire . .. No. 74471 Gingrich, Smith, Klingensmith &Dolan 222 South Market Street, Suite 201 Elizabethtown, PA 17022 (717) 367-1370 N b O ..~ ~;.n; 1;~ ;., " ' ~ r7 _, _ ~ ,, CT7 T t- _ r rj ~ -C7 l'1'2 :) '~A , ` J r .,. ~ .Cl I~I~ \J ~~i ~~ ~ ~ O '^G ~^ PETER C. BUCH Plaintiff v. LISA L. BUCH, Defendant. THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.2007-4299 CIVIL TERM CIVIL ACTION- LAW IN DIVORCE PRAECIPE TO WITHDRAW APPERANCE AND ENTER APPEARANCE ON BEHALF OF DEFENDANT, LISA L. BUCH TO THE PROTHONO"TARY: Kindly withdraw the appearance of Serratelli, Schiffman, Brown &Calhoon, P. C. and Paige Macdonald-Matthes, Esquire as counsel for Defendant, Lisa L. Buch, and enter the appearance of the Law Office of Samuel L. Andes and Samuel L. Andes, Esquire as counsel for Defendant, Lisa L. Buch. Respectfully submitted, Samuel L. Andes, Esq ire Attorney I.D. # 17225 Law Office of Samuel L. Andes 525 N. 12th Street. Lemonye, PA 17043 717-761-5361 phone 717-761-1435 fax Respectfully submitted, u ._o ~ t ~ ~~..r~ ~.o~iLd Paige Macdonald-Matthes, Esquire Attorney I.D. # 66266 Serratelli, Schiffman, Brown &Calhoon, P.C. 2080 Linglestown Road Harrisburg, PA 17110 717-540-9170 phone 717-540-5481 fax ,~' CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Plaintiffs Praecipe to Withdraw Appearance and Enter Appearance has been served upon all parties of interest by placing the same in the United States Mail, first-class, postage pre-paid, at Harrisburg, Pennsylvania on this 26'" day March, 2008, and addressed as follows: Jeffrey S. Shank, Esquire Gingrich Smith Klingensmith & Dolan 222 S Market, Suite 201 P.0. Box 267 Elizabethtown, PA 17022 Samuel L. Andes, Esquire Law Office of Samuel L. Andes 525 N 12th Street PO Box 168 Lemoyne, PA 17043 r Paig acdonald-Matthes, Esquire - _ t.-~ ~::~ ",~ -~~ :rte ---s ~ _~, r:z -..~ =;- ._ ~~ c.,.~ t~ ..y ~. .~ PETER C. BUCH IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF , Plaintiff Vs. LISA L. BUCH Docket No. 2007-4299 DEFENDANT Defendant . MOTION FOR APPOINTMENT OF MASTER PETER C. BUCH (Plaintiff) ~~ moves the court to appoint a master with respect to the following claims: (x) Divorce (x) Distribution of Property (j Annulment ()Support ~ (~ Alimony ()Counsel Fees (~ Alimony Pendente Lite {x) Costs and Expenses and in support of the motion states: (1) Discovery i~&~mplete as to the claims (s) for which the appointment of a master is requested. (2} The defendant (has) ~asx~t) appeared in the action ~~ (by his attorney, Samuel L. Andes ,Esquire). (3) The Staturory ground (s) for divorce (is) (are) 3301(d) .Irretrievable breakdown (4) Delete the inapplicable paragraph(s): a. b. An agreement has been reached with respect to the following claims: c. The action is contested with respect to the following claims: Alimony, Alimony Pendente Lite, Distribution of Property, Costs and (5) The action (involves) (does not involve) complex issues of law or fact Expenses . (6) The hearing is expected to take 1 day ~~a~ms~ (days). (7) Additional information, if any, relevant to the motion: Date: A mey fof/(Plaintiff) {dam Print Attorney Name ......... of f rey S . Shank, Esquire ORDER APPOINTING MASTER AND NOW, , 20 Esquire is appointed master with respect to the following claims: By the Court: `%~L~.J` ..Svc 2Q~9 A~1G ~~ w~ 4 i C~.}}~_~~ _ wfpp~.~"~~;Y ~~.%~`f~ °J.~l~~~~lJ'~~~~p~Y. IN 'THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Docket No. 2007-4299 Defendant MOTION FOR APPOINTMENT OF MASTER (Plaintif fl ~1~~ moves the court to appoint a master with respect to the following claims ~~li ~~ l~! Late PETER C. BUCH PLAINTIFF Plaintiff Vs. LISA L. BUCH DEFENDANT PETER C. BUCH (~ Divorce (x) Distribution of Property () Annulment ()Support (~ Alimony OCounsel Fees (~ Alimony Pendente Lite (x) Costs and Expenses and in support of the motion states: (1) Discovery i~~~mplete as to the claims (s) for which the appointment of a master is requested. (2) The defendant (has) cwt) appeared in the action ~ (by his attorney, Samuel L. Apdes ,Esquire). (3) The Staturory ground (s) for divorce (is) (are) 3301(d) ;Irretrievable breakdown (4) Delete the inapplicable paragraph(s): a. b. An agreement has been reached with respect to the following claims: a c. The action is contested with respect to the following claims: Alimony~~;Alimony Pendente Lite, Distribution of Property, hosts and (5) The action (involves) (does not involve) complex issues of law or fact Expenses . (6) The hearing is expected to take 1 day (days), (7) Additional information, if any, relevant to the motion: Date: ~Il.~'a~ ~ A mey fofl(Plaintiff) (iE3e~eR~az~ Print Attorney Name ......... of frey S . Shank, Esquire ORDER APPOINTING TER ~ AND NOW, 20 D ~ Esquire is appointed master respect to the following claims: ~i,ei~tt~0 ~~l'~r' By th Curt: v 1~ /tom ~G i J. 2x09 AUG 26 Phi ~~ 3 t ~u~~r~~as~k~v^s~~ ~,~.i~ ids m5i~'K~ ~. ~~ ~~.~~ ~3~~~~t~~~~ E~ TNc P~ ~ ; ~;:'~!~~'ARY 2009 A€!G 2S A~1 i 1 ~ 34 Cl!}Vt~ ~ .,,~ ~~ v;.,j~J~ ~:~ J~~~.I~r~SV~F! ~. Jeffrey S. Shank, Esquire, ID #74471 No. 2007-4299 Gingrich, Smith, Klingensmith & Dolan 222 South Market Street, Suite 201 Elizabethtown, PA 17022 717-367-1370 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW PETER C. BUCH, Plaintiff ) vs. ) LISA L. BUCH, ) Defendant ) NO. 2007-4299 CIVIL TERM ACTION IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file aCounter- affidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(D) OF THE DIVORCE CODE 1. The parties to this action separated on or about July 23, 2007, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees Gi" c~~Giisi;5 If 1 dG nUt i;ldiii3 ti~e11I bCfurC a di v VrCG is grdiitZd. I verify that the statements made in this Affidavit 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. Section 4904 relating to unswo falsification to authorities. ~~ Date: 8/10/09 Peter C. Buch 2f~~~ ~~~ 25 ~~-~ I { ~ u Pri` ~~`~ ~'`LV~~~4 PETER C. BUCH, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION -LAW NO. 2007-4299 CIVIL TERM LISA L. BUCH, Defendant IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(D) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a Divorce Decree. (b) I oppose the entry of a Divorce Decree because (check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least 2 years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in this Counter-Affidavit 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 unsworn falsification to authorities. t~~ Date: f = ~~ __ ~~ /`` LISA L. BUCH NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU NEED NOT FILE THIS COUNTER-AFFIDAVIT. _ ~ft>~y L. 2~~9 ~~~' 23 ~f°~ ~~ ~.~ y. ~~~