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Home My WebLink About09-0242Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-b97-7050 (Phone) 717-697-7065 (Fax) KURTIS R. STROCK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW JILL M. STROCK, Og _O.ZyZ Cam,( ,~,,.,. 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 may proceed against 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 with 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 Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania, 17013-3387. 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, PENNSYLVANIA 17013 (717) 249-3166 ~~~ BY L~/"v Andrew C. Sheely; PA. I.D. No. 62469 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 717 697-7050 Attorney for Plaintiff Andrew C. Sheely, Esquire 127 S. Market Street ' P.O. Box 95 Mechanicsburg, PA 17055 PA ZD NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) KURTIS R. STROCK, Plaintiff vs. JILL M. STROCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 09 - IN DIVORCE NOTICE OF RIGHT TO COUNSELING YOU are one of the parties in the above-captioned action in divorce. By virtue of Section 202 of the Pennsylvania Divorce Code, it is a duty of the Court to advise both parties of the availability of counseling and upon request of either provide both parties with a list of qualified professionals who provide such services. Accordingly, if you desire counseling a list of marriage counselors if available in the office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013-3387 Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) KURTIS R. STROCK, Plaintiff vs. JILL M. STROCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 09 - 02 y2 ~/ 'T,~ IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is KURTIS R. STROCK, an adult individual who currently resides at 729 Williams Grove Road, Mechanicsburg, Upper Allen Township, Cumberland County, Pennsylvania. 2. Defendant is JILL M. STROCK, an adult individual who currently resides at 6285 Haydon Ct., Mechanicsburg, Hampden Township, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant were 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 in Mechanicsburg, Pennsylvania, on April 21, 2007. 5. There have been no prior actions of divorce or annulment between the parties. 6. Neither party is a member of the armed forces of the United States of America. 7. Plaintiff has been advised of the availability of marriage counseling and understands that he may have the right to request that the court require the parties hereto to participate in counseling. COUNT 1 - DIVORCE - IRRECONCILABLE DIFFERENCES 8. Paragraphs 1 - 7 are incorporated herein as if set forth at length. 9. The marriage between the parties is irretrievably broken. 10. After ninety (90) days have elapsed from the date of filing and service of the divorce complaint, Plaintiff intends to file an affidavit consenting to a divorce and Plaintiff believes Defendant may also file such an affidavit. 11. This divorce action is not collusive. 12. The parties separated on or about November 10, 2008. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from filing of this Divorce Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce pursuant to Section 3301(c) of the Pennsylvania Divorce Code. COUNT II - DIVORCE - 3301(d) 13. Paragraphs 1 - 12 are incorporated herein as if set forth at length. 2 14. After a period of two (2) years has elapsed from the date of separation, Plaintiff intends to file his affidavit of having lived separate and apart. WHEREFORE, if two (2) years have elapsed from the date of separation and Plaintiff has filed his affidavit of consent, Plaintiff respectfully requests the Court to enter a Decree of Divorce pursuant to Section 3301(d) of the Divorce Code. COUNT III. CLAIM FOR E UITASLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 OF THE DIVORCE CODE 15. The allegations in Paragraphs 1 - 14 are incorporated herein and made a part hereof. 16. Plaintiff and Defendant acquired various personal property, motor vehicles, bank accounts, retirement accounts, retirement assets and insurance policies acquired during their marriage. 17. Plaintiff and Defendant are the owners of real property acquired during their marriage. 18. Plaintiff and Defendant have acquired various marital debts during the period of their marriage, and paid off individual debt on behalf of the other party during marriage. WHEREFORE, Plaintiff requests your Honorable Court equitably distribute the parties marital property, including marital debt, and including any such further relief as the Court may determine equitable and just. 3 COUNT IV. ALIMONY/ALIMONY PENDENTE LITE 19. The allegations in Paragraphs 1 through and including 16 are incorporated herein and made a part hereof. 20. Plaintiff lacks sufficient property to provide for him reasonable means and is unable to support himself through appropriate employment in similar status as available during marriage. 21. Plaintiff requires reasonable support to adequately maintain himself in accordance with the standard of living established during the marriage. 22. Defendant is employed by the Cumberland Valley School District and has superior income, benefits and employment perquisites than Plaintiff. WHEREFORE, Plaintiff requests your Honorable Court to enter an award of alimony pendente lite until final hearing and hereafter enter an award of alimony permanently thereafter. Respectfully submitted, Date: January /~ 2009 Andrew C. Sheely, e Attorney for Plaintiff PA ID No. 62469 P.O. Box 95 127 S. Market Street Mechanicsburg, PA 17055 717-697-7050 4 VERIFICATION I verify that the statements made in this Divorce Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: January ~~ , 2009 ~~~ ~ ~~ ~ Kurtis R. Strock Andrew C. Sheely, Esquire _ 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Eax) KURTIS R. STROCK, Plaintiff vs. JILL M. STROCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 0 9 - ~'/ ~ IN DIVORCE AFFIDAVIT Kurtis R. Strock, being duly sworn according to law, deposes and says: (1) I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. (2) I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. (3) Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. January 17, 2009 ~~~ ~ ~~ ~. Kurtis R. 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