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Home My WebLink About08-7546ARTHUR E. SHREVE, JR., Plaintiff, vs. DEBORAH A. SHREVE, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. f -'15?{(p L?IVi l TPxM CIVIL ACTION - LAW IN DIVORCE N O T I C E 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 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 Domestic Relations Office, 13 North Hanover Street, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (71 ) 249-3166 ARTHUR E. SHREVE, JR., Plaintiff, vs. DEBORAH A. SHREVE, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with § 3302(d) of the Divorce Code, you may request the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania 17013. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQ. ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 (beam@kopelaw.com ARTHUR E. SHREVE, JR., Plaintiff, vs. DEBORAH A. SHREVE, Defendant. Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. O F- ? s CPC, l-lc -? 7_r,L?- CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, ARTHUR E. SHREVE, JR., by and through his attorney, LESLEY J. BEAM, ESQ., and makes the following Complaint in Divorce: 1. Plaintiff is ARTHUR E. SHREVE, JR., an adult individual who currently resides at 442 Mt. Rock Road, Newville, Cumberland County, Pennsylvania 17241 (hereinafter referred to as "Plaintiff'). Plaintiff will be relocating consistently with the initiation of this action to 50 Bonnybrook Road, Lot #16, Carlisle, Pennsylvania 17013. All legal papers may be served on the Plaintiff through his counsel at 4660 Trindle Road, Suite 201, Camp Hill, Pennsylvania 17011. 2. Defendant is DEBORAH A. SHREVE, an adult individual who currently resides at 442 Mt. Rock Road, NewvFille, Cumberland County, Pennsylvania 17241 (hereinafter referred to as "Defendant").III I 3. Both Plaintiff and Defendant have been bona fide residents of 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 October 16, 1999, in Newville, Cumberland County, Pennsylvania. 5. The parties separated consistently with the filing of this complaint, as Defendant has indicated to Plaintiff that she wants the divorce, and has begun an extramarital relationship prior to this filing. 6. Neither Plaintiff nor Defendant is in the military service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. There have been no prior actions for divorce or for annulment instituted by either of the parties in this or any other jurisdiction. 8. Plaintiff has been advised of the availability of marriage counseling. And that Plaintiff has the right to request that the Court require the parties to participate in counseling. !COUNTI REQUEST FOR A NO-FAULT DIVORCE UNDER § 3301(c) OF THE DIVORCE CODE 9. Paragraphs one through 'eight are hereby incorporated by reference as though fully set forth herein. 10. The marriage of the r parties is irretrievably broken. III WHEREFORE, if both parties 'file affidavits consenting to a divorce after ninety days (90) have elapsed from the date of service of this Complaint, Plaintiff respectfully requests that the Court enter a Decree of Divorce pursuant to § 3301(c) of the Divorce Code COUNT II REQUEST FOR A NO-FAULT DIVORCE UNDER § 3301(d) OF THE DIVORCE CODE 11. Paragraphs one through ten are hereby incorporated by reference as though fully set forth herein. 12. The marriage of the parties is irretrievably broken. 13. The parties are living separate and apart and at the appropriate time Plaintiff will submit an affidavit alleging 'that the Parties have lived separate and apart for at least two (2) years as specified in Section 3301 (d) of the Divorce Code. WHEREFORE, Plaintiff respectfully requests that the Court enter a Decree of Divorce pursuant to § 3301(d) of the Divorce Code. COUNT III REQUEST FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER § 3502(a) OF'THE DIVORCE CODE 14. Paragraphs one through thirteen are hereby incorporated by reference as though fully set forth herein. 15. Plaintiff and Defendant hove acquired marital property as defined by the Divorce Code, which is subject to equitable distribution pursuant to § 3502(a) of the Divorce Code. 16. Plaintiff and Defendant have been unable to agree to the equitable distribution of said property, as of the date of filing of this Complaint. 17. Plaintiff requests that the Court equitably divide, distribute, or assign the marital property between the parties. WHEREFORE, Plaintiff respectfully requests that the Court enter an order of equitable distribution of marital property pursuant to § 3502(a) of the Divorce Code. COUNT IV ALIMONY 18. Paragraphs one through eighteen are hereby incorporated by reference as though fully set forth herein. 19. Defendant does not have the means through his own earning capacity to maintain a reasonable standard of living, nor the standard the parties established during the marriage. 20. Defendant lacks sufficient property, including, but not limited to, any property distributed pursuant to the Divorce Code of 1980, as amended, to provide for his reasonable needs. 21. Plaintiff is enjoying a substantial income from which she is able to contribute to the support and maintenance of the Defendant and pay him alimony in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Defendant respectfully requests that the Court enter an Order awarding Defendant alimony from Plaintiff in such sums as are reasonable and adequate to support and maintain Defendant. COUNT V ALIMONY PENDENTE LITE, COUNSEL FEES AND COSTS 22. Paragraphs one through twenty-one are hereby incorporated by reference as though fully set forth herein. 23. By reason of the institution of the action to the above term and number, Plaintiff will be and has been put to considerable expense in the preparation of his case, in the employment of counsel, and the payment of costs. 24. Defendant's income is disproportionately higher than Plaintiff's income. Plaintiff is without adequate income to pay the costs and expenses of this litigation, and is, likewise, without adequate income to maintain him during the course of the litigation. WHEREFORE, Plaintiff respectfully requests that the Court grant an order upon Defendant compelling Defendant to pay Plaintiff alimony pendente lite, counsel fees and/or costs of litigation. Date: 440- ? Respectfully Submitted, VgRIFICATION I, Arthur E. Shreve, Jr., the plaintiff in this matter, have read the foregoing Complaint. I verify that my averments in this Complaint are true and correct and based upon my personal knowledge. I understand that any false statements herein are made subject to the penalties of 18 Pa.d.S. § 4904 relating to unsworn falsifications to authorities. J Dated: oe> JO? Arthur E.. Shreve, Jr. ?? r-..a C? ?°? `? ?? T G.? r '.. . _ Y (? pcT O -'' W v ?? }y ?,.??3 v fy. . : ? . D ? ,?-' ?? ARTHUR E. SHREVE, JR. IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2008-7546 DEBORAH SHREVE, CIVIL ACTION - LAW Defendant. IN DIVORCE PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please enter the Plaintiff's voluntary discontinuance of the within action pursuant to Pennsylvania Rule of Civil Procedure 229. Date: ?- Respectfully Submitted, kA-? l J Beam, Esq. ZIT s T EY I.D. 91175 395 St. Johns Church Road, Suite 101 Camp Hill, PA 17011 (717) 761-7573 (beam@kopelaw.com Attorney for Plaintiff VERIFICATION I, Arthur E. Shreve, Jr., the Plaintiff in this matter, have read the foregoing Praecipe to Discontinue. I verify that the statement made in this Praecipe is true and correct, and based upon my personal knowledge. I understand that any false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsifications to authorities. I further assert that my decision to discontinue this action is not the result of any duress, coercion or fraud by any person. My attorney has advised me that should I choose to refile a divorce complaint in the future, I will be responsible for all costs as if the within-cited divorce action had never been filed. Dated..... , f Arthur E. Shreve, Jr. -` i•s p Tt RLEIIr, in C Dr- 2 0I9 ?' I -3 P1"1 !f. 2?,