The URL can be used to link to this page

Home My WebLink About09-0742 SCOTT A. BODINE, Plaintiff vs. CAREN BODINE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 611' 71-/a Civil Term ACTION 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 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 St. Carlisle, Pa. 17013 (717) 249-3166 SCOTT A. BODINE, Plaintiff vs. CAREN BODINE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. O9 - '1-'12- Civil Term ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Scoff A. Bodine, a competent adult individual, who resides at 170 Oakville Road, Shippensburg, Cumberland County, Pennsylvania, 17257. 2. Defendant is Caren Bodine, a competent adult individual, who resides at 30 Old Cabin Hollow Road, Dillsburg, York County, Pennsylvania, 17019. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on May 20, 2000, in Carlisle, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of America or any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I veo ify 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. Scott A. Bodine, Plaintiff Respectfully submitted, Date: ® J an Adams, Esquire I.D. 0. 79465 17 South St. riisie, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF Q 4 J w w 1 r 5 - rO ?= Li SCOTT A. BODINE, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 09 - 742 Civil Term CAREN BODINE, : ACTION IN DIVORCE Defendant ACCEPTANCE OF SERVICE I, Karen Miller, Esquire, represent Caren Bodine, in the above- captioned matter; I hereby accepted service of the Notice to Defend, and Complaint in Divorce, on or about the date listed below, which was filed by Plaintiff's Attorney under the above-captioned number and I hereby affirm I was authorized to do so. Date: C-fit?& aren Miller, Esquire 3631 North Front St. Harrisburg, Pa. 17110 (717) 232-7661 ATTORNEY FOR DEFENDANT r-? ;? ??. Q ? =?? --a :- --? --? ,??'. C*? . ??? ;? -- t ?.,3 ?? Karen W. Miller, Esquire Attorney I.D. No. 200037 Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 (717) 232-2766 (fax) Attorneys for Defendant, Caren Bodine SCOTT A. BODINE, Plaintiff VS. CAREN BODINE, Defendant To: Scott A. Bodine c/o: Jane Adams, Esquire 17 West South Street Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 09-742 CIVIL ACTION - LAW IN DIVORCE NOTICE TO PLEAD YOU ARE HEREBY NOTIFIED to file a written response to the enclosed Answer and Counterclaims within twenty (20) days from service thereof or a judgment may be entered against you. Respectfully submitted, CALDWELL & KEARNS Date: "WN \ 31 10 By: Kare n W. o?.? Miller, Esquire Attorney I.D. #200037 3631 North Front Street Harrisburg, PA 17110-1533 (717)232-7661 Karen W. Miller, Esquire Attorney I.D. No. 200037 Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 (717) 232-2766 (fax) Attorneys for Defendant, Caren Bodine SCOTT A. BODINE, Plaintiff VS. CAREN BODINE, Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 09-742 CIVIL ACTION - LAW : IN DIVORCE DEFENDANT'S ANSWER TO COMPLAIl?TT IN DIVORCE WITH COUNTERCLAIMS AND NOW comes Defendant, Caren Bodine, by and through her attorney, Karen W. Miller, Esquire, Caldwell & Kearns P.C., and files the following Answer to the Complaint with Counterclaim in Divorce. 1. Admitted, upon information and belief. 2. Denied as stated. It is admitted that Caren Bodine is a competent adult individual who resides at 30 Old Cabin Hollow Road, Dillsburg, York County, Pennsylvania, 17019. By way of further answer, Defendant resides at that address at Apt. 101 3. Admitted. 4. Admitted. 5. Admitted. 6. No response required. 7. Admitted. 8. Admitted. 9. Admitted. 10. Denied. WHEREFORE, the Defendant, Caren Bodine, respectfully requests that Your Honorable Court enter a Decree in Divorce. COUNTERCLAIM (COMPLAINT OF DEFENDANT) FOR DIVORCE UNDER SECTION 3301(c) AND NOW comes Defendant, Caren Bodine, by and through her attorney Karen W. Miller, Esquire, Caldwell & Kearns P.C., and files the following Counterclaim against the Plaintiff, Scott A. Bodine: 11. The admissions to averments in this Complaint are incorporated herein by reference as if set forth at length. 12. Caren Bodine has been advised of the availability of marriage counseling and that she has the right to request that the Court require the parties to participate in counseling. Caren Bodine declines such right or opportunity. COUNTI REQUEST FOR EQUITABLE DISTRIBUTION 13. The prior paragraphs of this Answer and Counterclaim are incorporated herein by reference thereto. 14. During the course of their marriage, the Plaintiff, Scott A. Bodine, and the Defendant, Caren Bodine, have acquired property and have incurred indebtedness, which 2 property and indebtedness qualifies as marital property and marital debt in accordance with the provisions of the Pennsylvania Divorce Code. 15. Pursuant to the provisions of the Pennsylvania Divorce Code, this Court when requested to do so, is obliged to make provision for the equitable distribution of the marital property of the parties and to make allocation of the marital indebtedness of the parties. WHEREFORE, Defendant, Caren Bodine, respectfully prays Your Honorable Court to distribute all marital assets and indebtedness. COUNT II REQUEST FOR ALIMONY. ALIMONY PENDENTE LITE. COUNSEL FEES, COSTS & EXPENSES 16. The prior paragraphs of this Answer and Counterclaim are incorporated herein by reference thereto. 17. Defendant, Caren Bodine, hereby avers that she does not have sufficient funds in which to support herself upon the finalization of a divorce action. 18. Defendant, Caren Bodine, hereby avers that Plaintiff, Scott A. Bodine, does have sufficient funds in which to support the Defendant upon finalization of the divorce action. 19. Defendant, Caren Bodine, hereby avers that she does not have sufficient funds in which to support herself during the pendency of the divorce action. 20. Defendant, Caren Bodine, hereby avers that Plaintiff, Scott A. Bodine, does have sufficient funds in which to support her during the pendency of the divorce action. 21. Defendant, Caren Bodine, hereby avers that she does not have sufficient funds to pay counsel fees, costs and expenses incidental to this divorce action. 3 22. Defendant, Caren Bodine, hereby avers that Plaintiff, Scott A. Bodine, does have sufficient funds in which to pay Defendant's counsel fees, costs and expenses incidental to this divorce action. WHEREFORE, Defendant, Caren Bodine, respectfully prays Your Honorable Court to Order the Plaintiff, Scott A. Bodine, to pay her alimony, alimony pendent elite, counsel fees, costs and expenses incidental to this divorce action. Respectfully submitted, CALDWELL & KEARNS Dated: 3 2? 08456-001/145237 B w 1?" Y• Karen W. Miller Attorney I.D. #200037 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 Attorney for Defendant 4 03-03-09;08:29AM; VERIFICATION ;7174328688 # 2/ 2 The undersigned hereby verifies that the facts set forth in the foregoing document are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 Pa.C.S § 4904 relating to unswom falsification to authorities. Dated:- Ckreft Bodine CERTIFICATE OF SERVICE AND NOW, this 3rd day of March, 2009, I hereby certify that I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U.S. Mail at Harrisburg, Pennsylvania, postage prepaid, addressed to: Jane Adams, Esquire 17 West South Street Carlisle, PA 17013 CALDWELL & KEARNS By: 6 0 42 a ? W w a 0 S?-