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Home My WebLink About08-2789ABRAHAM LAW OFFICES 45 East Main Street, Hummelstown, PA 17036 (717) 566-9380 DANIELLE E. RUDY : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 07 - x.181 JONATHAN A. RUDY : CIVIL ACTION - LAW Defendant : DIVORCE NOTICE 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 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 Court Administrator, 4t' Floor, Cumberland County Courthouse, Carlisle, Pennsylvania. 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: Court Administrator 4t` Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 DANIELLE E. RUDY : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. v r- -2 7,P'? &;,4 7e,.- JONATHAN A. RUDY : CIVIL ACTION - LAW Defendant : DIVORCE COMPLAINT AND NOW, comes Plaintiff, Danielle E. Rudy, by and through her attorney, James W. Abraham, Esquire, Abraham Law Offices, Hummelstown, Pennsylvania and files the following: COUNT I - NO-FAULT DIVORCE (Pursuant to 23 Pa.C.S. Section 3301(c)) 1. Plaintiff, Danielle E. Rudy, is an adult individual who resides at 2409 Rolling Hills Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant, Jonathan A. Rudy, is an adult individual whose current address is 1 Brittany Lane, Dillsburg, Pennsylvania, 17019. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 25, 2002 in Harrisburg, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. Y 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 and Defendant are not members of the Armed Forces of the United States. WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce dissolving the marriage. COUNT H - INDIGNITIES 9. Paragraphs 1 through 8 are incorporated herein by reference. 10. Defendant has caused such indignities against Plaintiff which has made life burdensome and intolerable for Plaintiff, the innocent and injured spouse. WHEREFORE, Plaintiff respectfully requests Your Honorable Court to enter a decree in divorce dissolving the marriage. COUNT III - EQUITABLE DISTRIBITION 11. Paragraphs 1 through 10 are incorporated herein by reference. 12. Plaintiff and Defendant have accumulated real and personal property and other assets during the course of the marriage, which are marital property and marital assets; as well as debts during the marriage which are marital debts. 13. Plaintiff is entitled to the fair and equitable distribution of Plaintiff's equitable share of said property and assets in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Plaintiff respectfully requests your Honorable Court to equitably distribute the marital property and debts hereto. COUNT IV - ALIMONY, ALIMONY PENDENTE LITE, COUNSEL FEES & COSTS 14. Paragraphs 1 through 13 are incorporated herein by reference. 15. Plaintiff's income and/or earning capacity through appropriate employment is substantially and significantly less than Defendant's income and/or earning capacity and has been substantially and significantly less throughout the marriage. 16. Plaintiff has insufficient funds to support herself in accordance with the standard of living and station of life which the parties established during the marriage through appropriate employment; and Defendant's substantially higher income enables Defendant to contribute to the support and maintenance of Plaintiff and to pay alimony in accordance with the Divorce Code of Pennsylvania. 17. Plaintiff is without sufficient funds to support herself and is unable to appropriately maintain herself during the course of this litigation and the pendency of this action; and Defendant's substantially higher income enables Defendant to pay alimony pendente lite to Plaintiff in accordance with the Divorce Code of Pennsylvania. 18. Plaintiff is without sufficient funds to retain and/or continue to retain counsel to represent her in this matter; and without competent counsel, Plaintiff cannot adequately prosecute her claims against Defendant and adequately litigate her rights in this matter; and Defendant's substantially higher income enables Defendant to pay Plaintiff's attorney fees and costs of the litigation hereto. WHEREFORE, Plaintiff respectfully requests Your Honorable Court to award Plaintiff alimony, alimony pendente lite, attorney fees and costs. Respectfully sub tted: James W. Abraham, Esq. Abraham Law Offices 45 East Main Street Hummelstown, PA 17036 (717) 566-9380 Attorney for Plaintiff, Danielle E. Rudy DATE: 4/30/08 .. VERIFICATION I, 14?k'i C= t-Lc y q / , the undersigned, hereby verify and confirm that the foregoing document and the statements made therein are true and correct to the best of my knowledge, information and belief. I further understand that any false statements made herein are subject to the penalties of Title 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. DATE: f ^ 0 Q ,I CERTIFICATE OF SERVICE I, James W. Abraham, Esquire, the undersigned, hereby certify that I have served a true and correct copy of the foregoing document, by certified mail, upon the following person at the following address on the date stated herein: Jonathan A. Rudy 1 Brittany Lane Dillsburg, PA 17019 DATE: 4/30/08 James W. Abraham, Esquire J Q ? 93 _U a CIA P x v- 7-^ cz> CD L..,J c: T. ABRAHAM LAW OFFICES 45 East Main Street, Hummelstown, PA 17036 (717) 566-9380 DANIELLE E. RUDY Plaintiff v. JONATHAN A. RUDY Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :NO. 08 - 2789 CIVIL ACTION - LAW DIVORCE PRAECIPE TO SETTLE AND DISCONTINUE TO THE PROTHONOTARY: Please mark the Complaint filed on April 30, 2008 in the above-captioned action settled, discontinued and withdrawn, without prejudice. Respectfully subrfted: James W. Abraham, Esquire Abraham Law Offices 45 East Main Street. Hummelstown, PA 17036 (717) 566-9380 Attorney for Plaintiff, Danielle E. Rudy DATE: 7/21/08 AW CERTIFICATE OF SERVICE I, James W. Abraham, Esquire, the undersigned, hereby certify that I have served a true and correct copy of the foregoing document by first class mail upon the following person(s) at the following address(es) on the date stated below: Jonathan A. Rudy 1 Brittany Lane Dillsburg, PA 17019 DATE: 7/21/08 James W. Abraham, Esquire r.? 7 ?, __ ""t ? .. , ;_ ?\? .-V-