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Home My WebLink About09-5814STEPHANIE QUIRIN, Plaintiff V. FRANCIS QUIRIN, JR. Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 9° 5 -I y Civil Term CIVIL ACTION - LAW 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY„ LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 St. Carlisle, Pa. 17013 (717) 249-3166 STEPHANIE QUIRIN, Plaintiff V. FRANCIS QUIRIN, JR. Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. D q- ?Pl y Civil Term CIVIL ACTION - LAW DIVORCE COMPLAINT IN DIVORCE COUNT I - DIVORCE 1. Plaintiff is Stephanie Quirin, a competent adult individual, who resides at 711 Hanover Manor, Apt. 204, Carlisle, Pa., 17013. 2. Defendant is Francis Quirin, Jr., a competent adult individual, whose last known address is believed to be 3550 Grandview Parkway, Apt 238, Birmingham, Alabama, 35243. 3. Plaintiff has been a bona fide resident of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on May 20, 1978 in Blair County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have two children together, however both are adults. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: (a) that the marriage is irretrievably broken pursuant to 23 Pa.C.S. 3301(c); (b) that Plaintiff has suffered such indignities as to render her condition intolerable and life burdensome pursuant to 23 Pa.C.S. 3301(a)(6). WHEREFORE, Plaintiff requests the court to enter a decree in divorce. COUNT II - EQUITABLE DISTRIBUTION OF PROPERTY 11. Paragraphs 1 - 10 are herein incorporated by reference. 12. 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. 13. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. 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 PENDENTE LITE 14. Paragraphs 1 - 13. are herein incorporated by reference. 15. Plaintiff lacks sufficient property to provide for her reasonable means and is unable to support herself adequately through appropriate employment. 16. Plaintiff requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. 17. Plaintiff has a need for assistance with her living expenses and legal expenses during the pendency of this action. 18. 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, the Plaintiff requests that this Honorable Court enter an award of Alimony Pendente Lite until final hearing. COUNT IV - ALIMONY 19. Items 1- 18 are herein incorporated by reference. 20. Wife lacks sufficient property or income to provide for her reasonable needs in accordance with the standard of living of the parties established during the marriage. 21. Wife is unable to support herself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 22. Husband is self-employed and enjoys a substantial income from which he is able to contribute the support and maintenance of Defendant and pay her alimony in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Wife prays this Honorable Court to enter an Order awarding her from Husband 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 Respectfully submitted, Date: g/aylo da a NAdams, Esquire 1. o.79465 South Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF VERIFICATION I verify that the statements made in this Complaint are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. ALhmq?v Date: ?a V/OT Stephanie Quirin, Plaintiff ILA r?''?'?f r f ; "- A'O 1009 A UG 24 PM !2: ? 0 Cuily A( ` YFI5-0 'T' A , a2 lac -? ?39d.?? C ?? C'?- a i/ STEPHANIE QUIRIN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 2009 - 5814 Civil Term FRANCIS QUIRIN, JR. : CIVIL ACTION - LAW Defendant : DIVORCE PETITION FOR ALIMONY PENDENTE LITE 1. Petitioner, Stephanie Quirin, is a competent adult individual, who resides at 711 Hanover Manor, Apt. 204, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Petitioner's date of birth is December 31, 1959, and her social security number will be provided to Domestic Relations in a separate document. 3. Respondent, Francis Quirin, Jr believed to have recently moved to India Lafayette, Indiana, 47906. , is a competent adult individual, whose is ia. His address is: P.O. Box 2012, West 4. Respondent's date of birth is September 13, 1957 and his social security number will be provided to Domestic Relations in a separate document. 5. A Divorce Complaint which included counts for Divorce, Equitable Distribution, and Alimony, and Alimony Pendente Lite was filed under the above-captioned docket number on August 24, 2009. WHEREFORE, Petitioner requests that the Court Order alimony pendente lite. Respectfully submitted, Date: <Kl,?-716 9 J04 Adams, Esquire YD. No. 79465 17 )N. South St. ,C.drlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PETITIONER VERIFICATION I verify that the statements made in this PETITION are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Dater a? Steph nie Quirin, PLAINTIFF 2609 AUG 28 AM ILI: 39 CO 0 1"a GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR SAXON ASSET SECURITIES TRUST 2007-2 4708 Mercantile Drive North Fort Worth, TX 76137 Plaintiff IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY vs. CALVIN W. WILLIAMS III 1508 Simpson Ferry Road New Cumberland, PA 17070 Defendant(s) CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-5813civilterm PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. By: GOLDBECK McCAFFERTY & McKEEVER MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF 0 FiLED._,,:!€:riCE OF THE Pr "Ill'IJ;ONOTARY 2009 SEP 16 PH 3: 22 CU 1+ ;'{ C•r-, ia`r?? ? ?.Vr? ,-•??? 4 10.00 Pty AT1'i et-* N-724p a R:F* a 3O(o 59 STEPHANIE QUIRIN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V : NO. Civil Term FRANCIS QUIRIN, JR. : CIVIL ACTION - LAW Defendant : DIVORCE AFFIDAVIT OF SERVICE I, Jane Adams, Esquire, do hereby certify that on this date, I served a true and correct copy of the NOTICE TO DEFEND AND DIVORCE COMPLAINT in the above- captioned matter upon the following individual(s) by first class mail, postage prepaid, addressed as follows: ¦ Complete Items 1, 2, and 3. Also complete Frances Q u i ri n , Jr. Item 4 If Restricted Dellyery Is desired. P.O. BOX 2012 ¦ Print your name and address on the reverse so that we can return the card to you. West Lafayette, IN 47906 ¦ Attach this card to the back of the mailpiece, DEFENDANT or on the front if space permits. 1. Article Addressed to: yo ?d X 2e ?2 2. Art 011 PS Fc DATED: /,?q 169 A. X;r Ci ? Addressee Bby (Pifnted li/mne) C o D. Is delivery address ditent from Rom 1 ? If YES, enter delivery address below: ? No 3. Servlce'type ft Certified" D ames Mail ? Repl %ftd ? Ream FteoeO for Merdraridlae D homw mail ? C.O.D. 4. 111 Mal D~(Extra Fee) tQ Yes ,awe- I J ne Adams, Esquire 7 W. South St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff 2609 SIEP 24 F'?? ., STEPHANIE QUIRIN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 2009 - 5814 Civil Term FRANCIS QUIRIN, JR. : CIVIL ACTION - LAW Defendant : DIVORCE PACSES Case: 549111172 ORDER OF COURT AND NOW, this 25th day of September 2009, upon consideration of the attached 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 , the 14th day of October , 2009, at 10:30 A.M. o'clock for a Conference, after which the hearing officer may recommend that an order for Alimony Pendente Lite be ordered. 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(c) 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. FOR THE COURT, By. X4 K in A. Hess, J. 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 St. Carlisle, Pa. 17013 (717) 249-3166 xc: Petitioner Respondent Jane Adams, Esq. CC363 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. FILED- I- ;E 20.99 SA=P 28 A11 I0': 14 6 STEPHANIE R. QUIRIN, Plaintiff/Petitioner VS. FRANCIS QUIRIN JR, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 09-5814 CIVIL TERM IN DIVORCE PACSES CASE: 549111172 ORDER OF COURT AND NOW to wit, this 2nd day of November, 2009, it is hereby Ordered that the Petition for Alimony Pendente Lite is dismissed, without prejudice, pursuant to the Petitioner withdrawing her claim. 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. BY THE COURT: 74? * AZ Ke ' A. Hess, J. DRO: R.J. Shadday xc: Petitioner Respondent Jane Adams, Esq. Hannah Herman-Snyder, Esq. Form OE-001 Service Type. M Worker: 21005 ALED-C:I + 1, uE OF THE PROn-1 NOTARY 2009 NOV -2 PM 2: 49 r E-Mi NS f 4.VANIIA 1ANE ADAMS ATTORNEY AT LAW Attorney I.D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 esgadams ~~ gmal.com STEPHANIE QUIRIN, Plaintiff V. FRANCIS QUIRIN, JR. Defendant I•i~_irl.~ fit .~i~~~ ,,;;- -; ~ ~ F , , l ;;-~ ;:~T~1AY 2010 FEG 22 ~~`~ ~: ~ I ~~f~~ CUt~f~ ~. ;~ ~; ~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09 - 5814 Civil Term CIVIL ACTION -LAW DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on August 24, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. - ~ , Date: ,~ l J~~~ l ep nie Quirin, Plainti WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER $33011c) AND ~3301(d) OF THE DIVORCE CODE 1. I consent to entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. . , Date: a I / ~~ 1 ~ Steh nie Quirin, P ainti FILED-a~~==; iC`` t„- ~~~Yr Lam„--,--f ~-~,~,~r,-n~,~~J ZOlO FFB 26 P! ! ~ ! 7 ,. fir"°;`~ i ~ ~;~', STEPHANIE QUIRIN, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 09 - 5814 Civil Term FRANCIS QUIRIN, JR. :ACTION IN DIVORCE Defendant PRAECIPE TO WITHDRAW CLAIMS TO THE PROTHONOTARY: Please withdraw Plaintiff's claims for Equitable Distribution, Alimony Pendente Lite, and Alimony. Dare ~~~s~l~ Respectfully Submitted: J e Adams, Esquire . No. 79465 1 W. South St. arlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff STEPHANIE QUIRIN, IN THE COURT OF COMMON Plaintiff :CUMBERLAND COUNTY, PEZ v. No.2009-5814 ~ ~ • ~ t+~ FRANCIS QUIRIN, JR., :CIVIL ACTION -LAW Defendant IN DIVORCE w cn AFFIDAVIT OF CONSENT ^'' 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on August 24, 2009, and served on September 8, 2009, by certified mail, restricted delivery. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. J~ ,-. ~` ~ DATE: 3~/ ~o?D/0V~~`/ FRANCIS QUIRIN, JR., Plaintiff STEPHANIE QUIRIN, Plaintiff v FRANCIS QUIRIN, JR., Defendant 1 2 3 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2009-5814 CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REO1 THE ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE I consent to the entry of a final decree in divorce without notice. N a 0 ee -~, z cn I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: _ .3~/ ~o?O/,Q ~ ~ `` FRANCIS QUIRIN, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEPHANIE QUIRIN, V. FRANCIS QUIRIN, JR. NO. 2009 - 5814 Civil Term DIVORCE DECREE AND NOW, /-i~a ~ 1 La ~~ ~ , it is ordered and decreed that STEPHANIE QUIRIN, ,plaintiff, and FRANCIS QUIRIN, JR. ,defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None. By the Court, ~~ Attest/1 P J. Prothonotary Lj - ~ ~s- i o ~ce~ tma..~ ~ -~ ~-o F}daxns ~ ~ S n~c~e.~-