The URL can be used to link to this page

Home My WebLink About09-1099A DANIEL L. FEASER, Plaintiff, V. DANA M. FEASER, Defendant To: Dana Marie Feaser: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 09 - 099 a1v i I lE'•Y'm CIVIL ACTION -LAW 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. 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 Cumberland County Courthouse, 1St Floor, 1 Courthouse Square, Carlisle, Pennsylvania 17103. 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. v 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY COURTHOUSE 4TH FLOOR CARLISLE, PA. 17013 #717-240-6200 DANIEL L. FEASER, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : DOCKET NO: 0 9 - 14) 9 y &x., j 7z-,-.. CIVIL ACTION -LAW DANA M. FEASER, IN DIVORCE Defendant COMPLAINT IN DIVORCE UNDER SECTION 3301 (C) OR (D) OF THE DIVORCE CODE AND NOW, this Lday of February, 2009, comes the Plaintiff, Daniel L. Feaser, by and through his undersigned attorney, Joseph L. Hitchings, Esquire and avers in support of his Divorce Complaint as follows: 1. Plaintiff, Daniel L. Feaser, is an adult individual currently residing at 237 Constitutional Court, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. Defendant, Dana M. Feaser, is an adult individual currently residing at 4115 Carrington Court West, Mechanicsburg, Cumberland County, Pennsylvania, 17050 3. Both parties have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to filing of this Complaint. 4. Plaintiff and Defendant were married on November 15, 1997, in Enola, Cumberland County, Pennsylvania, and separated on December 19, 2008. 5. There have been no prior actions of divorce or annulment between the parties. 6. The ground on which the divorce action is based is that the marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling 8. Plaintiff requests the court to enter a decree of divorce. 9. One child has been born of this marriage, Corey Christopher Feaser, born March 13, 2004. WHEREFORE, pursuant to 23 Pa. C.S.A. §3301 (c) or (d), Plaintiff, Daniel L. Feaser, respectfully requests this Court grant a Decree of Divorce, divorcing the parties from the bonds of matrimony. Respectfully Submitted, Law Office of Joseph L. Hitchings o ph L. Hitch ngs, quir Attorney ID No. 65551 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 (717) 458-8123 (717) 790-6019 (fax) Attorney for Plaintiff VERIFICATION I, Daniel L. Feaser, verify that the statements made in this Divorce Complaint are true and correct to the best of my knowledge. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. ,z:2-l3 -og Date D L. Feaser ?- ? r?? ? r _7 ? A? O - '? ?' _ ?, ` U1 ? ? _ ., 6 c.,; ? - - . , ?_: LAW OFFICES OF PETER J. RUSSO, P.C. BY: Elizabeth J. Saylor, Esquire PA Supreme Court ID: 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: Isaylor@pjrlaw.com Attorneys for Defendant DANIEL L. FEASER., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 07-1 tA9 DANA M. FEASER, NO. 094M CIVIL TERM Defendant IN DIVORCE ANSWER AND COUNTERCLAIM IN DIVORCE AND NOW comes the above-named Defendant, DANA M. FEASER, by and through her attorneys, The Law Offices of Peter J. Russo, P.C., and makes the following Answer and Counterclaim in Divorce: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Denied. Defendant is without knowledge or information sufficient to forma belief as to the truth of this averment and, therefore, such allegation is deemed to be (\I J denied and strict proof thereof is demanded. .. w 8. Denied. Defendant is without knowledge or information sufficient to form a belief as to the truth of this averment and, therefore, such allegation is deemed to be denied and strict proof thereof is demanded. 9. Admitted. Defendant denies all other allegations in paragraphs 1 through 9 of Plaintiff's Complaint under Section 3301 (c) of the Divorce Code that are not specifically admitted. COUNTERCLAIM 10. The prior paragraphs of this Answer and Counterclaim are incorporated by reference as though fully set forth herein. 11. The marriage of the parties is irretrievably broken. 12. Plaintiff and Defendant separated on December 19, 2008. 13. Defendant avers that there are children under the age of eighteen (18) years born of the marriage. 14. Defendant has been advised that counseling is available and the Defendant may have the right to request that the court require the parties to participate in counseling. WHEREFORE, Defendant prays that a decree be entered in favor of the Defendant and against Plaintiff as follows: That a decree in divorce be entered dissolving the marriage between the two parties. 2 COUNT II EQUITABLE DISTRIBUTION 15. The prior paragraphs of this Answer and Counterclaim are incorporated by reference as though fully set forth herein. 16. Plaintiff and Defendant have acquired marital property as defined by the Divorce Code, which is subject to equitable distribution pursuant to Section 3502 (a) of the Divorce Code. 17. Plaintiff and Defendant have been unable to agree to the equitable distribution of said property, as of the date of filing this Answer and Counterclaim. 18. Defendant requests the Court to equitably divide, distribute or assign the marital property between the parties without regard to marital misconduct in such proportion as the Court deems just after consideration of all relevant factors. WHEREFORE, Defendant prays that a decree be entered in favor of the Defendant and against Plaintiff as follows: The Court enter an order of equitable distribution of marital property pursuant to Section 3502(a) of the Divorce Code. LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys fo efendant Peter J. Russo, Esquire ID # 72897 Elizabeth J. Saylor, Esquire ID # 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 PH: (717) 591-1755 FX: (717) 591-1756 Date: y' ?'? 3 VERIFICATION I, DANA M. FEASER, verify that the statements made in the foregoing document(s) are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: ?- DDA A M. FEA R 4 CERTIFICATE OF SERVICE I, Amber L. Southard, hereby certify that I am on this day serving a copy of the foregoing Answer and Counterclaim in Divorce upon the person(s) and in the manner indicated below: US Regular Mail addressed as follows: Joseph L. Hitchings, Esquire 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Counsel for Plaintiff Amber L. Southard, Paralegal Date: 45109 2QQI APR 16 fz? 7 f i ? ?? 9 :„ $616.00 PO A7rY eico 3Isf . fa bl e e aaa8l3