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Home My WebLink About09-3843w w IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Dale R. Guyer, Civil Action - Law Plaintiff V. No: 2009- 38g3 Misty K. Guyer, Defendant In Divorce a.v.m. 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 the Cumberland County Courthouse, first floor, 1 Courthouse Square, Carlisle, Pennsylvania. 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Pennsylvania Bar Association, Lawyer Referral Service 100 S Street, P.O. Box 186, Harrisburg, PA 17108 1-800-692-7375 (PA only); (717) 238-6715 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Dale R. Guyer, Civil Action - Law Plaintiff : V. No: 2009- 3 8 `'3 Misty K. Guyer, Defendant In Divorce a.v.m. COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. The Plaintiff is Dale R. Guyer, who currently resides at 1 West Creek Road, Newburg, Cumberland County, Pennsylvania since 2005. 2. The Defendant is Misty K. Guyer, who currently resides at 1 West Creek Road, Newburg, Cumberland County, Pennsylvania since 2005. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 22, 2000 Franklin County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that marital counseling may be requested and that a list of marriage counselors is available in the office of the Cumberland County Prothonotary. Plaintiff has further been advised of the right to request that the Court require the parties to participate in marital counseling. 8. Plaintiff requests the Court to enter a Decree of Divorce. Respectfully submitted, r? O Q ?I Carol A. Redding, #82041 Attorney for Plaintiff Dale R. Guyer REDDING LAW OFFICE 19 North Main Street Chambersburg, PA 17201 (717) 267-1440 VERIFICATION I verify that the statements in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to authorities. DATE: % U - A h -; e z 4 v--,: ? -q Dale R. Guyer r OF T? i 2009 JUN 10 P1l 1: 17 *338 . So PO ATrY alet a" 4 AT* aou. 5'I 3 /?, o Co-d, 17 2 YO- 910V IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Dale R. Guyer, Civil Action - Law Plaintiff, V. F.R. 2009-3843 Misty K. Guyer, ; Defendant, In Divorce a.v.m. NOTICE TO PLEAD To: Misty K. Guyer: You are hereby notified to file a written response to the enclosed Amended Divorce Complaint within twenty (20) days from service hereof or a judgment may be entered against you. CQAno C- L,A-_-1 Carol A. Redding, Esquire, #82041 Attorney for Plaintiff REDDING LAW OFFICE 19 North Main Street Chambersburg, PA 17201 (717) 267-1440 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Dale R. Guyer, : Civil Action -Law Plaintiff V. : F.R. 2009-3843 Misty K. Guyer, Defendant : In Divorce a.v.m. AMENDED DIVORCE COMPLAINT NUNC PRO TUNC NOW COMES the Plaintiff, Dale R. Guyer, and amends the divorce complaint filed in the above captioned matter on June 10, 2009, as follows: COUNTI EQUITABLE DISTRIBUTION 9. Paragraphs 1 through 8 of this complaint in Divorce are incorporated herein by reference thereto. 10. The parties have been unable to determine and equitably dispose of their respective rights and interest in the marital property. 10 11. Plaintiff will, within 60 days after service of this Complaint upon the Defendant, cause to be filed an Inventory and Appraisement of all property owned or possessed at the time this Complaint is filed. WHEREFORE, Plaintiff requests the Court to equitably divide and distribute and assign the marital property pursuant to the provisions of Section 3502 of the Divorce Code. COUNT II ALIMONY 12. Paragraphs 1 through 11 of this complaint in Divorce are incorporated herein by reference thereto. 13. The Plaintiff is without sufficient property to provide for himself reasonable needs, and is unable to adequately support himself through his employment. 14. The Plaintiff cannot support and maintain himself in the style he was maintaining prior to the separation of the Plaintiff and Defendant without continued financial assistance from the Defendant. WHEREFORE, pursuant to Section 3701, et seq., of the Divorce Code, Plaintiff respectfully requests your Honorable Court to order Defendant to file within 30 days of service of this Complaint upon Defendant, a complete income and expense statement and to require the scheduling of a hearing to determine Plaintiffs entitlement to alimony, and if so, the amount. COUNT III ALIMONY PENDENTE LITE, COUNSEL FEES AND EXPENSES 15. Paragraphs 1 through 14 of this complaint in Divorce are incorporated herein by reference thereto. 16. The Defendant has refused to enter into any reasonable and fair property and separation agreement, and Plaintiff will incur substantial legal fees in that regard. 17. Furthermore, the resolution of the issues raised by this Complaint will require Plaintiff to incur considerable additional expenses and costs. 18. The Plaintiff is without sufficient means to adequately support himself and to meet the costs and expenses of this litigation and is unable to maintain himself during the pendency of this action. 19. The Defendant is presently employed at Citi Bank, Hagerstown, Maryland and her income is unknown to Plaintiff. WHEREFORE, pursuant to Section 3702, et seq., of the Divorce Code, Plaintiff respectfully requests your Honorable Court to order Defendant to file within 30 days of service of this Complaint upon Defendant, a complete income and expense statement, and to require the scheduling of a hearing to determine Plaintiffs entitlement to alimony pendente lite, counsel fees and expenses and if so, the amount. Respectfully Submitted, C `_ n \ Carol A. Redding, Esquire Attorney #82041 Attorney for Plaintiff Dale R. Guyer REDDING LAW OFFICE 19 North Main Street Chambersburg, PA 17201 (717) 267-1440 VERIFICATION I verify that the statements set forth in the foregoing document 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. DATE:;' CCarol A. Redding, Esquire RLEC 'r"4CE OF THE PRP-OHIO APY 2009 JUN 26 PM ! 05 PENNS 'W" M .* 18 00 po AT" 3