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HomeMy WebLinkAbout09-2841Natalie M. Walls Plaintiff V. Matt D. Walls Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2009- AM CIVIL TERM 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, Carlisle, PA 17101. 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. 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, Pennsylvania, 17013 (717) 249-3166 (800) 990-9108 i Natalie M. Walls Plaintiff V. Matt D. Walls Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2009- -2 8 y/ CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(C) AND (D) OF THE DIVORCE CODE COUNT 1 IRRETRIEVABLY BROKEN AND NOW, comes the Plaintiff, Natalie M. Walls, by and through his/her attorneys, The Law Offices of Pratz & Wallace, LLC, and files this complaint in Divorce against the Defendant, Matt D. Walls, representing as follows: 1. Plaintiff is Natalie M. Walls, an adult individual who currently resides at 32 Colgate Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Matt D. Walls, who currently resides at 2414 New York Avenue, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff and Defendant) have been bona fide residents in the Commonwealth, specifically Cumberland County, for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on August 26, 2006 at Harrisburg, Pennsylvania, Dauphin County. 5. There have been no prior actions of divorce or for annulment between the parties. i 6. Pursuant to the Divorce Code, Sections 3301 (c) and 3301 (d), the Plaintiff avers as the grounds upon which this action is based that 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. 8. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, the Plaintiff respectfully requests judgment dissolving the marriage between the two parties. COUNT 2 ALIMONY PENDENTY LITE, COUNSEL FEES, COSTS AND EXPENSES 9. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference as though set forth in full. 10. Plaintiff has employed counsel, but is unable to pay the necessary and reasonable attorney's fees for said counsel. 11. Plaintiff is unable to sustain herself during the course of this litigation. 12. Plaintiff lacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment. WHEREFORE, Plaintiff requests your Honorable Court to enter an award of interim counsel fees, alimony pendente lite, costs, and expenses until final hearing and thereupon award such additional counsel fees, costs and expenses as deemed appropriate. COUNT 3 EQUITABLE DISTRIBUTION 13. Paragraphs 1 through 14 of this Complaint are incorporated herein by reference as though set forth in full. 14. Plaintiff and Defendant have acquired property, during their marriage from August 26, 2006, until the date of their separation. 15. Plaintiff and Defendant own property which has appreciated in value during the course of the marriage. 16. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital property. Respectfully submitted, THE LAW OFFICES OF PRATZ & WALLACE C4 4 ?45- By: J ffrey Robert Pratz, Esquire Supreme Court I.D. No. 208934 24 North 32°d Street Camp Hill, Pennsylvania 17011- 2900 (717) 761-2312 Dated: ?00 VERIFICATION I, Natalie M. Walls, verify 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 unworn falsification to authorities. IN ? :!M • ?)S?- S> (Natalie M. Walls) Dated: (.D OF 1W, OMTHONbTA* 2009 MAY -6 PM 3: 33 CtJmpx':P ?? K c.Wm PENNSYLVANIA IF P , aZ 4,d-( Natalie M. Walls IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW Matt D. Walls 2009- oZ84 ( CIVIL TERM Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Natalie M. Walls, (Plaintiff), to proceed in forma pauperis. I, Jeffrey Robert Pratz, Esq., attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal service to the party. Respectfully submitted, Attorney for the Plaintiff THE LAW OFFICES OF PRATZ & WALLACE By: 4Je obert Pratz, WEs?quire Supreme Court I.D. No. 208934 24 North 32nd Street Camp Hill, Pennsylvania 17011- 2900 (717) 761-2312 Dated:. Fil OF n? n rnav 219 MAY -6 PM 3: 33 CUM&Rj4,4b OWNTY PENNSYLVANIA. NATALIE M. WALLS, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 09-2841 CIVIL TERM MATT D. WALLS, IN DIVORCE Defendant/Respondent : PACSES Case No: 631110847 ORDER OF COURT AND NOW, this 17th day of June 2009, based upon the Court's determination that the Petitioner's monthly net income/earning capacity is $ N/A and the Respondent's monthly net income/earning capacity is $ N/A, it is hereby ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit Two Hundred and 00/100 Dollars ($ 200.00) per month payable bi-weekly as follows: $ 200.00 per month for Alimony Pendente Lite and $ 0.00 per month on arrears. First payment due: in accordance with Respondent's pay schedule. The effective date of the order is May 1, 2009. Arrears set at $ 400.00 as of June 17, 2009. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C.S.§ 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and, at its discretion, make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the PA SCDU to: Natalie M. Walls. Payments must be made by check or money order. All checks and money orders must be made payable to PA SCDU and mailed to: PA SCDU P.O. Box 69110 Harrisburg, PA 17106-9110 Payments must include the Respondent's name with their PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. cc360 This Order is based upon an agreement of the parties on June 16, 2009. The Alimony Pendente Lite is effective for three (3) months, commencing May 1, 2009. This Order shall become final twenty (20) after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary for a hearing de novo before the Court. Consented: Petitioner Respondent Petitioner's Attorney Respondent's Attorney Mailed copies on: June 4, 2009 to: Petitioner Respondent Timothy E. Kane, Esq. Jeffrey R. Pratz, Esq. BY THE COURT, ;,?- og `14 Kev' Hess, J. DRO: R.J. Shadday T;' Apy 2099 JUI 1 19 PM S- 3 tJPn?:', ?:fy NATALIE M. WALLS, Plaintiff VS. MATT D. WALLS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNT~c', PENNSYLVANIA CIVIL ACTION -DIVORCE NO. 09-2841 CIVIL TERM IN DIVORCE PACSES CASE: 631110847 ORDER OF COURT AND NOW to wit, this 10th day of August, 2009, it is hereby Ordered that the Alimony Pendente Lite has been paid in full pursuant to the parties Stipulation and Agreement. The Cumberland County Domestic Relations Section dismissed their interest in the above captioned matter. This Order shall become final twenty (20) days after the mailing of the notice of the entry of the order to the parties unless either party files a written demand with the Domestic Relations Section for a hearing de novo before the Court. BY THE COURT: /~ K n A. Hess, J. DRO: R.J. Shadday xc: Petitioner Respondent Jeffrey R. Pratz, Esq. Timothy E. Kane., Esq. Form 0E-001 Service Type: M Worker: 21005 }~!( t f~: Jt' r fi_. t .T~, ,~ t ^r~i. ~~.~, ~ ~~, ;r, L u:: ~ r. a .~ s t3 ~ i L. • ,; ~~ai~~'~; - ;~.., r4 "~.~,'