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HomeMy WebLinkAbout08-3529r- JUSTIN TODD MAURICE Plaintiff V. LAURA RAI MAURICE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. De" 3SSa IN DIVORCE CIVIL TERM 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 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. 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 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 JUSTIN TODD MAURICE : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW LAURA RAI MAURICE : NO. ?'y - 3.5'2 q CIVIL TERM Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Justin Todd Maurice who currently resides at 392 West Pine Street, Mt. Holly Springs, Cumberland County, Pennsylvania, 17065. 2. Defendant is Laura Rai Maurice who currently resides at 1422 Bradley Drive, Carlisle Cumberland County, Pennsylvania 17013. 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 December 30, 2004, at Carlisle, Cumberland 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. Neither Plaintiff nor Defendant are in the armed services of the United States. 9. Plaintiff requests the Court to enter a Decree of Divorce. ANDREWS & JOHNSON By: ?lor P. Andrews, Esq. Attorneys for Plaintiff 78 W. Pomfret Street Carlisle, PA 17013 (717) 243-0123 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. § 4904, relating to unsworn falsification to authorities. Date: O Y Justin Todd Maurice, Plaintiff x`11 D 4! ?.l Y r-a 0 a tV IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff Vs File No. .? a IN DIVORCE Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x" J prior to the entry of a Final Deem in Divorce, or after the entry of a Final Decree in Divorce dated hereby elects to resume the prior susna me of "S e i1o T Z- , and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. 744. Date: a - a o Signium >kawa Ll?& gnature of name ' g resumed COMMONWF,AL?H OF PENNSYLVANIA ) COUNTY LF " foregoing for the purpose therein contained On the day of 200,ibefore me, the Prothonotary or the notary public, personally appearod the above affiant known to me to be the person whose name is subscrifJed to the within document and acknowledged that he / she executed the In Witness Whereof, I have hereunto set my hand here t+unt set my hand and official seal. i. (j, Notary Public NVARIAL SK PROTHONOTARY, NOTARY PUBLIC CARLISLE CUMBERLAND COUNTY CaIRTHM MY COMMISSION E PIAES JANUARY 4, 2010 (V N \?ri V d 4M1? Justin Todd Maurice, 392 West Pine Street Mount Holly Springs, PA 17065 Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-3529 CIVIL TERM Laura Rai Maurice n/k/a Laura Rai Bentz 1422 Bradley Drive, Apt. C114 Carlisle, PA 17013 : CIVIL ACTION - LAW Defendant : 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 will proceed without you and a decree in 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 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 First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Justin Todd Maurice, 392 West Pine Street Mount Holly Springs, PA 17065 Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-3529 CIVIL TERM Laura Rai Maurice n/k/a Laura Rai Bentz: 1422 Bradley Drive, Apt. C114 Carlisle, PA 17013 : CIVIL ACTION - LAW Defendant : IN DIVORCE COUNTERISUPPLEMENTAL DIVORCE CLAIMS COUNT II ALIMONY AND COUNSEL FEES 1. Plaintiff is presently employed and receiving substantial income and benefits and is able to pay for counsel fees, expenses and costs, as well as alimony, and alimony pendente lite for Plaintiff. 2. Defendant receives substantially less income then Plaintiff and Defendant is in process of receiving an advanced education degree for a LPN license. 3. Defendant seeks rehabilitative alimony to finish her advance degree education. WHEREFORE, Defendant requests your Honorable Court to appoint a Master with respect to the following claims: divorce, alimony, equitable distribution of property, counsel fees, costs. COUNT III EQUITABLE DISTRIBUTION 4. Paragraphs 1 through 3 are incorporated herein by reference as if set forth in their full text. 5. Plaintiff and Defendant are joint owners of various items of personal ? property, furniture and household furnishings acquired during their marriage, which are subject to equitable distribution. 6. Plaintiff and Defendant have incurred debts and obligations during their I marriage, which are subject to equitable distribution. WHEREFORE, Defendant requests your Honorable Court to appoint a Master with respect to the following claims: divorce, alimony, equitable distribution of property, counsel fees, costs. Date Respectfully Submitted TURO LAW OFFICES alen R. Waltz, E r 28 South Pitt S Carlisle, PA 17013 (717) 245-9688 Attorney for Defendant VERIFICATION I verify that the statements made in the foregoing Counter/Supplemental Divorce Claims are true and correct. I understand that false statements herein made are subject to the penalties of Pa.C.S. §4904 relating to unsworn falsification to authorities. /,0- 7- 0 9- /dxi Date L u a Rai Maurice n/k/a Laura ai Bentz CERTIFICATE OF SERVICE I, Galen R. Waltz, Esquire hereby certify that I served a true and correct copy of the within Defendant's Counter/Supplemental Divorce Claims, by depositing same in the United States Mail, first class, postage pre-paid on the 7 day of ©CAV bex-- , 2008, from Carlisle, Pennsylvania, addressed as follows: Taylor Andrews, Esquire 78 W. Pomfret Street Carlisle, PA 17013-3216 TURO LAW OFFICES alen R. Waltz, ire 28 South Pitt St t Carlisle, PA 17013 (717) 245-9688 Attorney for Defendant C- x A N Q IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Justin Todd Maurice V. Laura Rai Maurice n/k/a Laura RaiBentz : NO. 08-3529 DIVORCE DECREE AND NOW, L.a , it is ordered and decreed that Justin Todd Maurice , plaintiff, and Laura Rai Maurice n/k/a Laura RaiBentz 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.") The Marital Settlement Agreement dated September 12, 2011 is incorporated herein by reference but not merged into this decree. By the Court, ?(/ofi?ed c?pJc El ?50 vSO,02