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Home My WebLink About09-6319• 16, EILEEN M. POWELL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. WILLIAM D. POWELL, Defendant NO. 2009 - 4,317 CIVIL TERM CIVIL ACTION-LAW 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 foil 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 Court House; Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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. 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 i EILEEN M. POWELL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009 - G 3?9 CIVIL TERM WILLIAM D. POWELL, CIVIL ACTION-LAW Defendant IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is Eileen M. Powell, an adult individual who currently resides at 3271 Shatto Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is William D. Powell, an adult individual who currently resides at Apartment 507 Elwood Gardens, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff and Defendant have been bona fide residents in 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 July 21, 1990 in Pittsburgh, Allegheny County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of counseling and that she 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 requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant. COUNT II -EQUITABLE DISTRIBUTION 9. Plaintiff hereby incorporates by reference paragraphs 1 through 8 above. 10. The parties have acquired real estate, personal property, including automobiles, bank accounts and other items of miscellaneous property during the course of their marriage, some of which is marital property. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree which effects an equitable distribution of marital property. COUNT III - ALIMONY & ALIMONY PENDENTE LITE 11. Plaintiffs income is very modest in relation to the income of Defendant. 12. Plaintiff is in need of alimony pendente lite during the course of this litigation in order to hire counsel and sustain herself during the course of the litigation. 13. Defendant's income is much higher than Plaintiffs income and Plaintiff is entitled to alimony pursuant to the factors set forth in 23 PA.C.S.A. section 3701. WHEREFORE, Plaintiff respectfully requests that this Honorable Court award her alimony pendente lite at this time and alimony following the entry of a divorce decree. Date: 0? L? 0 ? Respectfully submitted, O'BRIEN, BARIC & SCHERER l isA. chK f?-l erer, Esquire I.D.# 61974 19 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff mas.dir/domestic/powell/divorcecomplaint.pid VERIFICATION I 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 unsworn falsification to authorities. oate r Eileen M. Powell R ELF ' E OF THE ('n 2009 S ED 2:3 Ali ! It : G 6 1339.96 Tip 9c-)- ?5a3 O-K---0 l2? EILEEN M. POWELL, Plaintiff V. WILLIAM D. POWELL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2009-6319 CIVIL TERM IN DIVORCE PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of the Defendant, William D. Powell, in the above captioned case. Respectfully submitted. SAIDIS, LINDSAY nnoWEts-ff-uw 26 West High Street Carlisle, PA Dated: October 9, 2009 SAIDIS, FLOWER & LIND50?Y y C rol indsay,,,I='s r Supreme Cou D o. 44693 26 West High et Carlisle, PA 17013 717-243-6222 ¦ CERTIFICATE OF SERVICE I hereby certify that on this 91h day of October, 2009, a true and correct copy of the foregoing document was served upon the party listed below, via First Class Mail, postage prepaid, addressed as follows: Michael A. Scherer, Esquire 19 West South Street Carlisle, PA 17013 SAIDIS, FLOWER & LINDSAY CaroT J-Linds - , Itoife Supreme Co rt ID o. 44693 26 West Hig reet Carlisle, PA 17013 717-243-6222 SAIDIS, FLOWER &z LINDSAY A770RNErWX-1Aw 26 West High Street Carlisle, PA OF THE `,=":0 "AllY 2009 OCT -9 h ?: 14 CU r MOM & LILAKIS Michelle L. Sommer, Esquire Attorney LD. #: 93034 2 West High Street Carlisle, PA 17013 (717) 249-0900 EILEEN M. POWELL, Plaintiff V. WILLIAM D. POWELL, Defendant r?+ W IN THE COURT OF COMMON PLEAS5-? 'c" CUMBERLAND COUNTY, PA NO. 2009-6319 CIVIL ACTION - LAW : IN DIVORCE C7*1 -0 ha Please enter my appearance on behalf of the Defendant, William D. Powell, in the above- captioned matter. Respectfully submitted, Date 1611( ill ABOM & KUTULAKIS, L.L.P. Michelle L. Somm , Esquire 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney ID No. 93034 f C,? cry AND NOW, this 16th day of October, 2012, I, Michelle L. Sommer, Esquire, of Abom & Kutulakis, L.L.P., hereby certify that I did serve a true and correct copy of the foregoing Entry of Appearance, upon Counsel for Plaintiff by depositing, or causing to be deposited, same in the United States Mail, postage prepaid addressed to the following: Michael A. Scherer, Esquire Baric & Scherer, LLC 19 West South Street Carlisle, PA 17013 Attorney for the Plaintiff Respectfully submitted, Abom & %utulakis, L.L.P. -6f?? ?4- ?'? Michelle L. Sommer, squire Attorney ID No.: 93034 2 West High Street Carlisle, PA 17013 (717) 249-0900 1i EILEEN M. POWELL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2009 — 6319 CIVIL TERM WILLIAM D. POWELL, CIVIL ACTION -LAW Defendant : IN DIVORCE PRAECIPE TO WITHDRAW DIVORCE COMPLAINT TO THE PROTHONOTARY: Kindly withdraw the Divorce Complaint filed in this matter. Respectfully submitted, BARIC SCHERER LLC Date: September 2, 2014 Michael A. cherer, Esquire I.D. # 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Attorney for Plaintiff CD CERTIFICATE OF SERVICE I hereby certify that on September 2, 2014, I, Jennifer S. Lindsay, secretary at Baric Scherer LLC, did serve a copy of the Praecipe To Withdraw Divorce Complaint, by first class U.S. mail, postage prepaid, to the party listed below, as follows: William D. Powell 271 Shatto Drive Carlisle, Pennsylvania 17013