Loading...
HomeMy WebLinkAbout04-0418 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Richard Leatherman, v. Defendant CIVIL ACTION Ii LAW NO. 04- U ( 0 CIVIL TERM IN DIVORCE Mary Leatherman, NOTICE TO DEFEND 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 wamed 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 in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Streets, Carlisle, P A. lF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA WYER'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 LA WYER 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 32 South Bedford Street Carlisle, P A 17013 Phone: (717) 249-3166 or (800) 990-9108 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. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Richard Leatherman, v. Defendant CIVIL ACTION - LAW NO. 04- '-( It! CIVIL TERM IN DIVORCE Mary Leatherman, COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE . . 1. Plaintiff is Richard Leatherman, an adult individual, who currently resides at 493 Highland Court, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Mary Leatherman, an adult individual, who resides at 67 Wright Road, York Springs, Adams County, Pennsylvania 17372. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on May 15, 1982 in York Springs, Adams County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, ,f' - Jd - 0 l-/ Date: I ....'_. ", ~ .' Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court 10 # 81924 Attomey for Plaintiff 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, S4904, relating to unswom falsification to authorities. Date: )-;;;0-0 L; ~d~ Richard Leatherman, Plaintiff I' i' Q R '-.- ---- ~ ~ """ C> ~ CX\ - ~ ~I '6;' ~ ~ ~. e:% - <:><") <....J"U'\, <A, c- '7' I l/: ..-_ C'.__ '<":""" ~":~C) ~~~ ~ Q\ ("~ ...., = => ~- ""T1 ,." GO o N o -n ~~ nlr- -om '00 O~S =?-r, -"--n <::,'n "Si'ri ~--i ~ -0 ::-i: - " :0:- .&'" Richard Leatherman, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v, No, 04-418 CIVIL TERM Mary Leatherman, Defendant IN DIVORCE TO THE PROTHONOTARY OF SAID COURT: PRAECIPE OF ENTRY OF APPEARANCE Please enter my appearance on behalf of the Defendant, Mary Leatherman, in the above-captioned matter, Respectfully submitted, ABOM & KUTULAKIS, L.L.P DATE oz-l WI 04- I ~W. Kara W. Haggerty, re 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Defendant ID #86914 ....., c~.) C.::l J,,- -,., rq W r-.) _I C) -n ::;:! h.:~ 1---.-1 ,--, ,> , CJ :r:, ('5 IT! -:,] U1 CO Richard Leatherman, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, P A v. No. 04-418 CIVIL TERM Mary Leatherman, Defendant IN DIVORCE DEFENDANT'S CLAIMS FOR ECONOMIC RELIEF AND NOW, comes the Defendant, Mary Leatherman, by and through her attorney, Kara W. Haggerty, Esquire, of Abom & Kutulakis, LLP, and ftles these Claims for Economic Relief as follows: COUNT I - EOUlTABLE DISTRIBUTION 1. Plaintiff and Defendant have acquired property, both real and personal, during their marriage from May 15, 1982, until present, which property is "marital property", 2, Plaintiff and Defendant may have owned, prior to marriage, property which has increased in value during the marriage and/or which has been exchanged for other property, which has increased in value during the marriage, all of which property is "marital property". 3. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, the Defendant requests this Honorable Court to equitably divide all marital property, COUNT II - ALIMONY PENDENTE LITE AND ALIMONY 4, Paragraphs 1 through 3 are incorporated herein by reference as though set forth in full. 5. Defendant lacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment, 6. Defendant requires reasonable support to maintain herself adequately in accordance with the standard of living established during the marriage. WHEREFORE, Defendant requests this Honorable Court to enter an award of alimony pendent elite until final hearing and thereafter to enter an award for alimony, COUNT III - COUNSEL FEES AND COSTS 7, Paragraphs 1 through 6 are incorporated herein by reference as though set forth in full, 8, Defendant has retained the law offices of ABoM & KUTULAI<lS, L.L.P" but is unable to pay the necessary and reasonable attorney's fees for said counseL 9, Defendant may need to hire experts to appraise the marital property but she lacks funds to pay the necessary and reasonable fees, WHEREFORE, Defendant requests this Honorable Court to enter an award of interim counsel fees, costs and expenses and to order such additional sums hereafter as may be deemed necessary and appropriate, and at final hearing to award such additional counsel fees, costs and expenses as are deemed necessary and appropriate, Respectfully submitted, ABOM & KUTULAKIS, LLP Date: M) Zh t 04:- ~w Kara W. Haggerty Attorney for Defendant Attorney LD, # 86914 36 South Hanover Street Carlisle, P A 17013 CERTIFICATE OF SERVICE AND NOW, this ~ay Of~, I, Kara W, Haggerty, Esquire, of Abom & Kutulakis, L.L.P" hereby certify that I did serve a true and correct copy of the foregoing DEFENDANT'S CLAIMS FOR ECONOMIC RELIEF upon the following: Via First-Class Mail Karl E, Rominger, Esquire 155 South Hanover Street Carlisle, P A 17013 Attorney for Plaintiff Respectfully submitted, ABOM & KUTULAKIS, LLP Date: ~ / 1<M1t [)), Kara W. Haggerty Attorney for Defendant Attorney LD. # 86914 36 South Hanover Street Carlisle, P A 17013 r % w __ 00 -l:.. 0 -<: ~ o f C) ~~ "~; ] .,1;. , ",__-, r~.- .. C'- ':i' g w t r -~ I '" c::-., C~ ~~- o -n ::;j hl~' r- -n r:: :2 ~? C?o ;-.~:.u (Ai~';~ 5;~ :.(1 -< -" PI c:> "-0 -.J :::'1':1 U1 CO ,- Richard Leatherman, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, P A v. No. 04-418 CIVIL TERM Mary Leatherman, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) 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! 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 ftled with the Prothonotary. 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: sA.Ul) 1 [\}- \l 0 8[)()~ \ ~~ta ~cm,O~GW MA Y ~ ERMAN (") c: <',. '"1} ()~j ,....r"(,.I, 7:~' ~~)'~~ ~t~: ~~;Z~ ,,~ C- . ~-$ :3 ~ ...., "'" "'" """ f:<< -U ~ ~:n :g~ 00 Cf" -:.:-t_I"'; +11 Q. ,C') C'5t/l _.~ o ~ .r:- -u :s: s:: Richard Leatherman, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, P A v. No. 04-418 CIVIL TERM Mary Leatherman, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under ~3301 (c) of the Divorce Code was filed on February 2, 2004, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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: A,l (j 1St- Ilo;::},N)'S I ~ ~ :t ~,,-rru ft NO n 0 MA L TPIERMAN (') G ~3~ ?-t ti..,.c -.,"" " fil:., -, (' ~-~~- ..,v'C ~\ -< .- ~ = "-'"' ~ '"'0 ~ :t f\~~ -o~ -n C-' :) '::2:'.R <2B .",- "'~... ~l ~ - '" -0 ::,.; .c:- o C> .&'" RICHARD LEATHERMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. MARY LEATHERMAN, Defendant CIVIL ACTION - LAW NO. 04-418 IN DIVORCE PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please discontinue the action at the above captioned docket by agreement ofthe parties. Date: AJ Go' V. .3, L(}(}J- I Respectfully submitted, ROMINGER, BAYLEY & WHARE ;/ , Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court 10 # 81924 Attorney for Plaintiff s; '5'- - ~ ~ \ '-'" <;(, -' :I:..,-, ("\=C. -Ot::) ~_~1 ]... Lie) ...:..\...." --.'....-,... :~CJ 7~lr(1 '.:::'-\ 1.0 :e<;; -::J '> q: o 0'