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HomeMy WebLinkAbout09-4545w JOYCE A. NORRIS, Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. X-OK CIVIL TERM TIMOTHY R. NORRIS, Defendant 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 foregoing 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 in 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: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, Pennsylvania 17013 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 1 JOYCE A. NORRIS, Plaintiff VS. TIMOTHY R. NORRIS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 0 9 - gS?re CIVIL TERM IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. 2 JOYCE A. NORRIS, Plaintiff VS. TIMOTHY R. NORRIS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW N0. 0'J- US yJ? CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, JOYCE A. NORRIS, by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is Joyce A. Norris who is a resident of Cumberland County, Pennsylvania. 2. The Defendant is Timothy R. Norris, an adult individual who resides at 1038 Swarthmore Road, New Cumberland, Pennsylvania, 17070. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 30 September 1989 in Mechanicsburg, Pennsylvania. 5. Plaintiff commenced a divorce action in approximately 2004. The divorce action was abandoned and Plaintiff believes it was later dismissed by the court for inactivity. Other than that, there have been no prior actions of divorce or annulment between the parties. 6. This marriage is irretrievably broken. 3 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I 8. The Plaintiff requests this Court to enter a Decree of Divorce. WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to the Divorce Code of Pennsylvania. COUNT II - EQUITABLE DISTRIBUTION 9. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as marital property. COUNT III - ALIMONY 10. Plaintiff lacks sufficient property to provide for her reasonable needs in accordance with the standard of living of the parties established during the marriage. 11. Plaintiff is unable to support herself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 12. The Defendant is employed and enjoys a substantial income from which he is able to contribute to the support and maintenance of Plaintiff and to pay her alimony in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding Plaintiff from Defendant permanent alimony in such sums as are reasonable and adequate to support and maintain Plaintiff in the station of life to which she has become accustomed during the marriage. 4 . COUNT IV - ALIMONY PENDENTE LITE 13. Plaintiff is without sufficient income to support and maintain herself during the pendency of this action. 14. Defendant enjoys a substantial income and is well able to contribute to the support and maintenance of Plaintiff during the course of this action. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her reasonable alimony pendente lite during the pendency of this action. COUNT V - COUNSEL FEES AND EXPENSES 15. Plaintiff is without sufficient funds to retain counsel to represent her in this matter. 16. Without competent counsel, Plaintiff cannot adequately prosecute her claims against Defendant and cannot adequately litigate her rights in this matter. 17. Defendant enjoys a substantial income and is well able to bear the expense of Plaintiff's attorney and the expenses of this litigation. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay the legal fees and expenses incurred by Plaintiff in the litigation of this action. muel L. An es Attorney for Plaintiff Supreme Court ID 17225 P.O. Box 168 Lemoyne, PA 17043 i I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). DATE: (o TUkU i 2ooq JOYCE. RRIS F1LFt?-+ "i S'vtr 77 TH? Y Z0,9 JLJ` -8 [, H • 12 cil 3,3b •So `4 -2g? Go 1, .10 -3 eel /71 4 JV It 735Pq-- `` a?»e2 JOYCE A. NORRIS, ) IN THE COURT OF COMMON PLEAS OF Plaintiff ) CUMBERLAND COUNTY, PENNSYLVANIA vs. TIMOTHY R. NORRIS, Defendant NO. --e 94 j CIVIL TERM CIVIL ACTION - LAW IN DIVORCE MOTION FOR ALIMONY PENDENTE LITE AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, and moves the Court to refer her claim for alimony pendente lite to the Domestic Relations Office for a conference and, if necessary, a hearing to determine that claim. Plaintiff raised her claim for alimony pendente lite in her Complaint in Divorce, a copy of which is attached hereto. Dated: ? j uku-l 2007 _Sarfuel L. Andes Attorney for Plaintiff P.O. Box 168 Lemoyne, PA 17043 (717) 761-5361 JOYCE A. NORRIS, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. O9 `/-sys CIVIL TERM TIMOTHY R. NORRIS, Defendant 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 foregoing 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 in 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: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, Pennsylvania 17013 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 JOYCE A. NORRIS, Plaintiff VS. TIMOTHY R. NORRIS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. CIVIL TERM IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. 2 JOYCE A. NORRIS, Plaintiff VS. TIMOTHY R. NORRIS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW N0. (y 9-yss?? CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, JOYCE A. NORRIS, by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is Joyce A. Norris who is a resident of Cumberland County, Pennsylvania. 2. The Defendant is Timothy R. Norris, an adult individual who resides at 1038 Swarthmore Road, New Cumberland, Pennsylvania, 17070. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 30 September 1989 in Mechanicsburg, Pennsylvania. 5. Plaintiff commenced a divorce action in approximately 2004. The divorce action was abandoned and Plaintiff believes it was later dismissed by the court for inactivity. Other than that, there have been no prior actions of divorce or annulment between the parties. 6. This marriage is irretrievably broken. 3 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNTI 8. The Plaintiff requests this Court to enter a Decree of Divorce. WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to the Divorce Code of Pennsylvania. COUNT II - EQUITABLE DISTRIBUTION 9. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as marital property. COUNT 111- ALIMONY 10. Plaintiff lacks sufficient property to provide for her reasonable needs in accordance with the standard of living of the parties established during the marriage. 11. Plaintiff is unable to support herself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 12. The Defendant is employed and enjoys a substantial income from which he is able to contribute to the support and maintenance of Plaintiff and to pay her alimony in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding Plaintiff from Defendant permanent alimony in such sums as are reasonable and adequate to support and maintain Plaintiff in the station of life to which she has become accustomed during the marriage. 4 COUNT IV - ALIMONY PENDENTE LITE 13. Plaintiff is without sufficient income to support and maintain herself during the pendency of this action. 14. Defendant enjoys a substantial income and is well able to contribute to the support and maintenance of Plaintiff during the course of this action. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her reasonable alimony pendente lite during the pendency of this action. COUNT V - COUNSEL FEES AND EXPENSES 15. Plaintiff is without sufficient funds to retain counsel to represent her in this matter. 16. Without competent counsel, Plaintiff cannot adequately prosecute her claims against Defendant and cannot adequately litigate her rights in this matter. 17. Defendant enjoys a substantial income and is well able to bear the expense of Plaintiff's attorney and the expenses of this litigation. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay the legal fees and expenses incurred by Plaintiff in the litigation of this action. muel L. An es Attorney for Plaintiff Supreme Court ID 17225 P.O. Box 168 Lemoyne, PA 17043 verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). DATE: ?0 5l?l`i 2 00cl JOYCE RRIS FLED-t_??IC; Nz OF THE 2009 Jul, --6 A`# l i f CUPS _ ??r Lv, * I( W-4 zw_ei je 0711, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOYCE A. NORRIS, Vs. Plaintiff TIMOTHY R. NORRIS, Defendant NO. CIVIL TERM CIVIL ACTION - LAW IN DIVORCE DRS ATTACHMENT FOR APL PROCEEDINGS PETITIONER NAME JOYCE A. NORRIS ADDRESS P.O. Box 411, 717 Market Street, Lemoyne, PA 17043 BIRTH DATE 15 September 1958 SOCIAL SECURITY NUMBER 190-50-8678 HOME PHONE 717-443-1747 WORK PHONE none EMPLOYER NAME none EMPLOYER ADDRESS n/a JOB TITLE/ POSITION n/a DATE EMPLOYMENT COMMENCED n/a GROSS PAY n/a NET PAY n/a OTHER INCOME n/a ATTORNEY'S NAME Samuel L. Andes ATTORNEY'S ADDRESS P.O. Box 168, Lemoyne, PA 17043 ATTORNEY'S PHONE NUMBER 1717-761-5361 f ' ',-i. DEFENDANT NAME TIMOTHY R. NORRIS ADDRESS 1038 Swarthmore Road, New Cumberland, PA 17070 BIRTH DATE 9 March 1959 SOCIAL SECURITY NUMBER 227-94-0106 HOME PHONE 717-774-1035 WORK PHONE 717-774-3319 EMPLOYER NAME Norris Child Care Consultants, Inc. EMPLOYER ADDRESS 206 Bridge Street, New Cumberland, PA 17070 JOB TITLE/ POSITION Owner/President DATE EMPLOYMENT COMMENCED 1984 GROSS PAY $200,000 (in 2007) NET PAY OTHER INCOME $50,000 (rent and real estate sales) ATTORNEY'S NAME John J. Connelly, Jr., Esquire ATTORNEY'S ADDRESS P.O. Box 650, Hershey, PA 17033 ATTORNEY'S PHONE NUMBER 717-533-3280 MARRIAGE INFORMATION DATE OF MARRIAGE 30 September 1989 PLACE OF MARRIAGE Mechanicsburg, PA DATE OF SEPARATION June, 2009 ADDRESS OF LAST MARITAL HOME 1038 Swarthmore Road, New Cumberland DESCRIPTION OF DOCUMENT RAISING APL CLAIM Divorce Complaint DATE APL DOCUMENT FILED July 2009 J-1% FILED 'DFF!ur !1 it fI_ !' 2009 JUL -8 Aid 11: 16 JOYCE A. NORRIS, THE COURT OF CO1?VI?fii)t;?S a Plaintiff/Petitioner CUMBERLAND COUNT Y??,PF ?NS; I3,V41 IA VS. CIVIL ACTION - DIV ?E NO. 09-4545 CIVIL TERM TIMOTHY R. NORRIS, IN DIVORCE Defendant/Respondent PACSES NO: 046110995 ORDER OF COURT AND NOW, this 13th day of July, 2009, upon consideration of the Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R. J. Shadday on Aueust 11, 2009 at 9:00 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11© (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you. If you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, Edgar B. Bayley, President Judge Copies mailed to: Petitioner Respondent Samuel L. Andes, Esq. John J. Connelly, Jr., Esq. Date of Order: July 13, 2009 2, f -10 J. Sh ay, APL Coordinator 1/7 YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 cc361 CF THE F ; cr _-) TAI dY 2C, 99 Sk,'L ! 3 t i'-1 "'3: (-'! "S rte.; t s ? 1 t Sheriffs Office of Cumberland County R Thomas Kline ?? - y Sheri v•' { . .. . ?ittitr of 4u+rabr?? Ronny R Anderson c.° Tab 2009 vi'r Chief Deputy Jody S Smith "3i_ . _. , , Civil Process Sergeant o?F t <-,E --RIP w Edward L Schorpp Solicitor Joyce A. Norris vs. Case Number Timothy R. Norris 2009-4545 SHERIFF'S RETURN OF SERVICE 07/09/2009 04:20 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on July 9, 2009 at 1620 hours, he served a true copy of the within Complaint in Divorce, upon the within named defendant, to wit: Timothy R. Norris, by making known unto himself personally, defendant at 1038 Swarthmore Road New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $43.74 July 10, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF D puty Sheri f