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Home My WebLink About09-2162McNEES WALLACE & NURICK LLC By: Debra D. Cantor Attorney ID No. 66378 100 Pine Street Harrisburg, PA 17108-1166 (717) 232-8000 (717) 260-1667 facsimile d cantorA mwn. com JANELLE L. HERSH, Plaintiff v. DANIEL W. HERSH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend agai forth in the following pages, you must take prompt action. You are warn do so, the case may proceed without you and a decree of divorce or ani entered against you for any other claim or relief requested in these pap( You may lose money or property or other rights important to you, includi visitation of your children. Est the claims set )d that if you fail to ulment may be rs by the Plaintiff. ig custody or 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 at the Cumberland County Courthouse, One ourthouse Square, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, D VISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THE U YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ON E. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TEL PHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET EGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 or (800),990-9108 McNEES WALLACE & NURICK L By Debra D. Cantor Attorney ID No. 6637 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 (717) 260-1667 (fax) dcantor(c -mwn.com Attorneys for Plaintiff Dated: ?I& Janelle L. Hersh I ?7G McNEES WALLACE & NURICK LLC By: Debra D. Cantor Attorney ID No. 66378 100 Pine Street Harrisburg, PA 17108-1166 (717) 232-8000 (717) 260-1667 facsimile dcantorO-mwn.com JANELLE L. HERSH, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, 13ENNSYLVANIA Plaintiff ?-n N O. 0 9- r L l .l?rcJC V. CIVIL ACTION - LAW DANIEL W. HERSH, IN DIVORCE Defendant COMPLAINT AND NOW comes Plaintiff, Janelle L. Hersh, by and through her ?ounsel, McNees Wallace & Nurick LLC, and files the following Complaint in Divorce. COUNTI 1. Plaintiff is Janelle L. Hersh, who currently resides at 419 (Mountain Street, Summerdale, Cumberland County, Pennsylvania, 17093. 2. Defendant is Daniel W. Hersh, who currently resides at 419 Mountain Street, Summerdale, Cumberland County, Pennsylvania, 17093. 3. Plaintiff and Defendant have been bona fide residents in tl?e Commonwealth of Pennsylvania for at least six months previous to the filing of this Com0aint. 4. Plaintiff and Defendant were married on September 21, 1 085 in Summerdale, Pennsylvania. 5. There have been no prior actions of divorce or for annulm6nt between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling Ond that she may have the right to request that the Court require the parties to participate in counseling. Plaintiff hereby waives her right to such counseling. 8. After 90 days have elapsed from the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defend?nt may also file such an affidavit. 9. In the alternative, Plaintiff will file a 3301(d) Affidavit and provide the appropriate notices two years from the date of separation. WHEREFORE, Plaintiff, Janelle L. Hersh, respectfully requests tl a Court to enter a decree of divorce under Section 3301(c) or (d) of the Divorce Code. 2 COUNT II EQUITABLE DISTRIBUTION 10. Plaintiff incorporates by reference paragraphs I through 1? of this Complaint. 11. Plaintiff and Defendant possess various items of personal marital property, as well as marital debts, which are subject to equitable distribution by this Court. WHEREFORE, Plaintiff, Janelle L. Hersh, requests your Honorable Court to equitably distribute all property, both real and personal, owned by the parties, as well as all marital debts McNEES WALLACE & NURICK LLO Debra D. Cantor Attorney ID No. 66378 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 (phone) (717) 260-1667 (fax) dcantor(c-mwn.com Attorneys for Plaintiff, Dated: /-I0R Janelle L. Hersh ? IUJ 3 VERIFICATION Subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unswo? falsification to authorities, I hereby certify that the facts set forth in the foregoing docum?nt are true and correct to the best of my information and belief. Dated: ??? ?'Qooq F1?t :=ICE OF THE PRO-1 ' t3TARY 2009 APR -b PEA 2: 53 PEi slr+5"t1..1941A kA-' 7 JANELLE L. HERSH, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : NO. 09-2162 V. CIVIL ACTION -LAW DANIEL W. HERSH, IN DIVORCE Defendant AFFIDAVIT OF ACCEPTANCE OF SERVICE I hereby accept service of the Divorce Complaint in the above matter. ov Daniel W. Hersh Dated: q / ? 07 FILE.. ?Jr =fC?E OF THE FPi 'l',I TARY 2009 APP 20 PH 55 cu'';L 1n ! . A Jay R. Braderman, Esquire Attorney I.D. No. 07047 Lavery, Faherty, Young & Patterson, P.C. 225 Market Street, Suite 304 P. O. Box 1245 Harrisburg, PA 17108-1245 Tel: 717-233-6633 Fax: 717-233-7003 E-mail: jbraderman@laverylaw.com Attorneys for Defendant JANELLE L. HERSH, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-2162 Civil DANIEL W. HERSH, Defendant CIVIL ACTION - LAW : IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter my appearance as attorney for Defendant, Daniel W. Hersh, in the above-captioned action. Respectfully submitted, Date: q By: Lavery, Fpbejb,)Young & Patterson, P.C. an, Esquire Jay FE o I.D.: 07047 Suite 304 22.arket et, P. Box 1245 Harrisburg, PA 17108-1245 Tel: 717-233-6633 Fax: 717-233-7003 Attorneys for Defendant I Vk CERTIFICATION I hereby certify that I am this day serving a true and correct copy of the attached Praecipe For Entry Of Appearance on the following individual by First Class U.S. Mail addressed as follows: Debra D. Cantor, Esquire McNEES WALLACE & NURICK 100 Pine Street Harrisburg, PA 17108-1166 Date: lul3x'9 By: Respectfully submitted, Laveryjiatterty, Young & Patterson, P.C. Jay R. d an, Esquire A e I. . No.: 07047 _W y 25 ark Street, Suite 304 P. Box 1245 5 Harrisburg, PA 17108-1245 Tel: 717-233-6633 Fax: 717-233-7003 Attorneys for Defendant, Daniel W. Hersh r. FILBD-CHCE F THE P - " 1"ARY 2009 MAY 27 P 1 * 26 McNEES WALLACE & NURICK LLC By: Debra Denison Cantor Attorney ID No. 66378 100 Pine Street Harrisburg, PA 17108-1166 (717) 232-8000 (717) 260-1667 facsimile dcantor(a)-mwn.com Attorneys for Plaintiff JANELLE L. HERSH, Plaintiff V. DANIEL W. HERSH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09-2162 CIVIL ACTION -LAW IN DIVORCE PLAINTIFF'S PETITION FOR ALIMONY, ALIMONY PENDENTE LITE COUNSEL FEES, COSTS AND EXPENSES PURSUANT TO PA R C P 1920.15 AND NOW, comes Plaintiff Janelle L. Hersh, by and through her counsel, McNees Wallace & Nurick LLC, and files the within Petition for Alimony, Alimony Pendente Lite, Counsel Fees, Costs and Expenses, and in support thereof, avers as follows: 1. The Plaintiff, Janelle L. Hersh, filed a Complaint in Divorce on April 6, 2009 docketed at the above-captioned number raising the following claims: Divorce and Equitable Distribution. 2. By reason of this divorce action, Plaintiff Janelle L. Hersh will be put to considerable expense in the preparation of her case in the employment of counsel and the payment of costs. 3. Plaintiff lacks sufficient assets to provide for her reasonable needs and is unable to fully support herself through appropriate employment. 4. Plaintiff requests the Court to determine and to allow her alimony pursuant to Section 3701 of the Divorce Code. 5. Plaintiff lacks sufficient funds to support herself and to meet the costs and expenses of this divorce action, including the necessary counsel fees, and is unable to appropriately maintain herself during this action. 6. Plaintiff requests the Court to award her the payment of counsel fees, and costs and expenses incurred by her in this action, such costs to be paid by Defendant. 7. Defendant has adequate earnings to provide alimony and Alimony Pendente Lite for Plaintiff and to pay her counsel fees, costs and expenses. 8. Plaintiff requests your Honorable Court to schedule a hearing at the Cumberland County Domestic Relations Office on Plaintiffs claim for Alimony Pendente Lite. WHEREFORE, Plaintiff respectfully requests this Honorable Court to award Alimony Pendente Lite, Alimony, Counsel Fees, Costs, and Expenses to Plaintiff. McNEES WALLACE & NURICK LLC By. / Deb ni Cantor Attorney-TD No. 66378 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 237-5297 (phone) (717) 260-1667 (fax) Attorneys for Plaintiff Dated: June 23, 2009 CERTIFICATE OF SERVICE The undersigned hereby certifies that on the 91+ day of June, 2009, a true and correct copy of the foregoing document was served by first-class mail, postage prepaid, upon the following: Jay R. Braderman, Esquire Lavery Faherty Young & Patterson PC 225 Market Street, Suite 304 P.O. Box 1245 Harrisburg, PA 17108 J fifer Kee Woodford, Paralegal FILE' :!'CE OF THEE 2009 JUL -6 Aii 9: G3 $ 5a. oo Pn A7W Cc* isigsl /!81518 P-,-t* aa'l s39