The URL can be used to link to this page

Home My WebLink About09-0022WALKER, CONNOR & JOHNSON LLC 247 Lincoln Way East Chambersburg PA 17201 (717) 262-2185 (717) 262-2187 -Fax IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNSYLVANIA Kimberly S. Doyle, Plaintiff, ) ) Defendant, ) Civil Action -Law vs. Ralph E. Doyle, No. OQ - Oda a c~vi t Terw In Divorce a v.m. 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 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 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 marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary of the Cumberland County Courthouse, First Floor, 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABAOUT 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. Pennsylvania Bar Association Lawyer Referral Service 1-800-692-7375 (PA Only) or (717) 238-6715 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 arrangement must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Kimberly S. Doyle, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNSYLVANIA vs. Ralph S. Doyle, WALKER, CONNOR 8c JOHNSON LLC 247Lincoln Way East Chambersburg PA 17201 (7l7) 262-2185 (717) 262-2187 -Fax Plaintiff, ) Defendant, ) Civil Action -Law No. G9 „ ~2 In Divorce a v.m. GTv 1 ~ ~"ulw COMPLAINT UNDER SECTION 3~01(a) OR 3301(c) OR 3301(d) OF THE DIVORCE CODE COUNT 1 DIVORCE 1. Plaintiff is Kimberly S. Doyle, a sui juris adult, who currently resides at 310 East Orange Street, Shippensburg, Cumberland County, Pennsylvania, since February 25, 2008. 2. Defendant is Ralph E. Doyle, a sui juris adult, who currently resides at 327 East Garfield Street, Shippensburg, Cumberland County, Pennsylvania, since 1987. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 26, 1983 in Shippensburg, Franklin County, Pennsylvania. 5. There have been no prior actions of divorce or annulment of marriage between the parties except the action represented by this Complaint. 6. The marriage is irretrievable broken. 7. Neither the Plaintiff nor Defendant is a minor or incompetent. 8. 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. 9. Plaintiff requests the court to enter a decree of divorce. 2 COUNT II DIVORCE 10. The allegations of Paragraphs 1 through 8 hereof aze incorporated herein as fully as though set out at lazge. 11. In violation of his marriage vows and laws of the Commonwealth, the Defendant, Ralph E. Doyle, has offered such indignities to the person of the injured and innocent spouse, the Plaintiff, as to render her condition intolerable and life burdensome. WHEREFORE, Plaintiff respectfully requests your Honorable Court to enter a decree of divorce. COUNT III EQUITABLE DISTRIBUTION -SECTION 3502 12. The allegations of Pazagraphs 1 through 8 hereof aze incorporated herein as fully as though set out at lazge. 13. The parties have been unable to determine and equitably dispose of their respective rights and interests in the martial property. 14. Plaintiff will, within 60 ~3ays after service of this Complaint upon Defendant, cause to be filed an inventory and appraisement of all property owned or possessed at the time this Complaint is filed. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide, distribute and assign the martial property pursuant to the provision of Section 3502 of the Divorce Code. COUNT IV ALIMONY 15. The allegations of Pazagraphs 1 through 8 hereof are incorporated herein as fully as though set at lazge. 16. The Plaintiff is without sufficient property to provide for her reasonable needs, and is unable to adequately support herself. 17. The Plaintiff cannot support and maintain herself in the style she was maintaining prior to the separation of the Plaintiff and Defendant without continued financial assistance from the Defendant. WHEREFORE, pursuant to Sections 3701, et seq., of the Divorce Code, "Alimony", Plaintiff respectfully requests your Honorable Court to order Defendant to file within 30 days of 3 service of this Complaint upon Defendant, a complete income and expense statement and to require the scheduling of a hearing to determine Plaintiff's entitlement to alimony, and if so, the amount. COUNT V ALIMONY PENDENTE LITE COUNSEL FEES AND EXPENSES 18. The allegations of Pazagraphs 1 through 8 hereof aze incorporated herein as fully as though set out at large. 19. The resolution of the issues raised by this Complaint will require Plaintiff to incur considerable additional expenses and costs. 20. The Plaintiff is without sufficient means to adequately support herself and to meet the costs and expenses of this litigation and is unable to maintain herself during the pendency of this action. WHEREFORE, pursuant to Section 3702, et. Seq., of the Divorce Code, "Alimony Pendente Lite, Counsel Fees and Expenses", Plaintiff respectfully requests your Honorable Court to order Defendant to file within 30 days of service of this Complaint upon Defendant, a complete income and expense statement, and to require the scheduling of a hearing to determine Plaintiff's entitlement to alimony pendente lite, counsel fee and expenses, and if so, the amount. WALKER, CONNOR & JOHNSON, LLC By: e S. John n, Esquire Attorney I.D. # 78039 247 Lincoln Way East Chambersburg, PA 17201 (717) 262-2185 Attorney for Plaintiff 4 VERIFICATION I verify that the statements made in this Complaint aze true and correct. I understand that false statements herein aze made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. >~~ ~:-Q . Kimberly S oyle, Plainti 5 ~ 6' ~ ,.' -~ " ~..., ~c W 4~"'~ ~~ h,~ V7 _'~'! J: ~. ~° 1' ~yi (""' ' T ~.."., G'7 ? C,? '~-r , r i ` ~°e? ., ,ti, ... =.~