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HomeMy WebLinkAbout03-6040ANTOINETTE J. PARSONS, Plaintiff RAYMOND J. PARSONS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2003 - /~t94/~ CIVIL TERM : CIVIL ACTION - LAW : 1N DIVORCE LAW OFFICES SNELBAKER, BRENNEMAN & SParE 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 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 divorce is indignities or irretrievable breakdown of the marriage, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the court. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. 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 LOST 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 WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 SNEL~/E-~~_~AN & SPARE, Ely ~~ ANTOINETTE J. PARSONS Plaintiff RAYMOND J. PARSONS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003 ~ o 5/0 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE LAW OFFICES SNELBANER, BRENNEMAN & Spare COMPLAINT IN DIVORCE COUNT I - GROUNDS FOR D1VORCE 1. Plaintiff ANTOINETTE J. PARSONS is an adult individual residing at 5 Red Oak Drive, Boiling Springs (South Middleton Township), Cumberland County, Pennsylvania 17007. 2. Defendant RAYMOND J. PARSONS is an adult individual residing at 417 Folsom Street, Baltimore, Maryland 21237. 3. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on June 8, 1963 in Harrisburg, Dauphin County, Pennsylvania. 5. There have been no prior actions of divome or for annulment between the parties hereto in this or any other jurisdiction since the date of the marriage averred in Paragraph 4, above, except an action in this Court terminated on November 8, 2002 for inactivity, captioned as follows: Antoinette J. Parsons vs. Raymond J. Parsons, No. 316 Civil 1993. 6. Neither party is a member of the armed forces of the United States of America. 7. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. 8. The Plaintiff has been advised that counseling is available and that Plaintiff may have SNELBAKER. BRENNEMAN SPARE the right to request that the Court require the parties to participate in counseling. 9. The Plaintiff requests this Court to enter a decree of divorce. COUNT I1 - EOUITABLE DIVISION OF PROPERTY 10. The Plaintiff and Defendant have legally and beneficially acquired property both real and personal during their marriage from June 8, 1963. 11. The Plaintiff requests the Court to equitably divide all marital property pursuant to 23 Pa. C.S. § 3502 of the Pennsylvania Divorce Code. COUNT III - ALIMONY AND ALIMONY PENDENT ELITE 12. The Plaintiff requires reasonable support and alimony to adequately maintain herself in accordance with the standard of living established during the marriage. 13. The Plaintiff requests the Court to allow alimony and alimony pendent elite as it deems reasonable pursuant to 23 Pa. C.S. §§ 3701 and 3702 of the Pennsylvania Divorce Code. COUNT IV - COUNSEL FEES, COSTS AND EXPENSES 14. The Plaintiffhas employed Snelbaker, Brenneman & Spare, P.C., as counsel and, because of the anticipated protracted litigation expenses and her limited income, is unable to pay for the expenses of counsel and litigation. 15. The Plaintiff requests the Court to allow her reasonable counsel fees, costs and expenses pursuant to 23 Pa. C.S. § 3702 of the Pennsylvania Divorce Code. to: WHEREFORE, the Plaintiff, ANTOINETTE J. PARSONS, prays your Honorable Court (a) enter a decree of divorce, divorcing the Plaintiff from the bonds of matrimony (b) (c) (d) (e) heretofore existing between the plaintiff and the Defendant; order equitable distribution of marital property; order alimony and alimony pendent lite as the Court deems just and reasonable; order payment of counsel fees, costs and expenses as the Court deems just and reasonable; and order such other relief as the Court deems just and reasonable. SNELBAKER, BRENNEMAN & SPARE, P.C. By: ~ er, Esquire 44 West Main Street Mechanicsburg, PA 17055-0318 (717) 697-8528 Attorneys for Plaintiff Antoinette J. Parsons Date:November 14 ,2003 LAW OFFICES SNELBaKEr, BRENNEMAN & SPARE VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §49049 relating to unsworn falsification to authorities. ANTOINETTE (J/'~.t~RSONS Date: November 14 , 2003 LAW OFFICES SNELBAK~R, BrENNEMAN & SPARE ANTOINETTE J. PARSONS Plaintiff RAYMOND J. PARSONS, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2003 CIVIL TERM : CIVIL ACTION - LAW : : IN DIVORCE AFFIDAVIT ANTOINETTE J. PARSONS, being duly sworn according to law, deposes and says: 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 Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do NOT request that the court require 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. ANTOINETTE J. PARSONS SNELBAKER, BRENNEMAN & SPARE Date: November 14.2003