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Home My WebLink About09-1733RICHARD S. FRIEDMAN, P.C. Richard S. Friedman, Esquire ID #07176 300 N. 2nd Street, Suite 402 Harrisburg, PA 17101 Tel.: (717) 234-3441/Fax: (717) 232-9946 Attorney for Plaintiff NICOLE A. POWERS, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTYnPENNSY~L~VANIA v. NO. C'Q - ~~1.3~ 1, ~ U t,~ [ '~ ~ 1_' _ - ~ BRANDON C. POWERS, CNIL ACTION -LAW Defendant IN DNORCE 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, Cumberland County Courthouse, 1 Courthouse Squaze, Cazlisle, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DNISiON OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DNORCE 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 Telephone (717) 249-3166 By: Respectfully submitted, RICHARD S. ~1tIEDMAN..-P.C. Rich S. Friedman, Es 300 .2nd Street, Suite Harrisburg, PA 17101 (717) 234-3441 NICOLE A. POWERS, Plaintiff v. BRANDON C. POWERS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. D 9 - !'~ 33 C` cup:,( ~~ CIVIL ACTION -LAW IN DIVORCE 1. Plaintiff is Nicole A. Powers, who currently resides at 383 N. 26th Street, Camp Hill, Cumberland County, Pennsylvania 17011, since February 17, 2007. 2. Defendant is Brandon C. Powers, who currently resides at 383 N. 26th Street, Camp Hill, Cumberland County, Pennsylvania 17011, since February 17, 2007. 3. The parties have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 7, 2008, in Camp Hill, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. COUNTI 8. The prior pazagraphs of this Complaint are incorporated herein by reference thereto. 9. The Plaintiff and Defendant have legally and beneficially acquired property, both real and personal, during their marriage. 10. The Plaintiff and Defendant have been unable to agree as to equitable distribution of the said property to the date of the filing of this Complaint. WHEREFORE, the Plaintiff, Nicole A. Powers, requests this Court to equitably divide all marital property. COUNT II REQUEST FOR ALIMONY PENDENTE LITE UNDER SECTION 3702 OF THE DIVORCE CODE 11. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 12. Plaintiff lacks sufficient property or income to provide for her reasonable needs and legal expenses during the course of this litigation. 13. Plaintiff requests the Court to enter an award of alimony pendente lite until final hearing, pursuant to Section 3702 of the Divorce Code. WHEREFORE, the Plaintiff respectfully requests the Court to enter an award of alimony pendente lite until final hearing, pursuant to Section 3702 of the Divorce Code. COUNT III 14. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 15. Plaintiff has employed Richard S. Friedman, Esquire to represent her in this matrimonial cause. 16. Plaintiff is unable to pay her counsel fees, costs and expenses, and Defendant is more than able to pay them. 17. Defendant is employed and has the ability to pay Plaintiff's counsel fees, costs and expenses. 18. Reserving the right to apply to the Court for temporary counsel fees, costs and expenses prior to final hearing, Plaintiff requests that, after final hearing, the Court order Defendant to pay Plaintiff s reasonable counsel fees, costs and expenses. WHEREFORE, Plaintiff respectfully requests that pursuant to Sections 3104(a)(1), 3323(b), 3702 and 4351(a) of the Divorce Code, the Court enter an order directing Defendant to pay Plaintiff s reasonable counsel fees, costs and expenses. Respectfully submitted, RICHARD S. FRIEDMAN, P.C. Date: ( _ 300 N,~,'nd Street, Suite Harrisburg, PA 17101 (717) 234-3441 VERIFICATION I; Nicole A. Powers, hereby acknowledge that I am the Plaintiff in the foregoing action; that I have read the foregoing Complaint in Divorce; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Nicole A. Po rs Dated~(',~~ `3i o- w ~ o ~t C ~ 1 C`? C <.:. ~ r`. r __ `.. }~ x~ C.J L'"3 -~7 r~ ~~'-_. ~? c i ~s :r.~ ("!j f=7t+i ~'~~ "S7 n