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Home My WebLink About09-7374Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 DIANNE P. TYLER, IN THE COURT OF COMMON PLEAS Plaintiff V. JOHN L. TYLER, Defendant : CUMBERLAND COUNTY, PENNSYLVANIA NO. 09 - 737y Civ, l 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 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 and visitation of your children. When the grounds for a 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 County Courthouse. 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 2 LIBERTY AVENUE Carlisle, Pennsylvania 17013 (717) 249-3166 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 DIANNE P. TYLER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 0 9- 7 3 7 y ?? ?i.? JOHN L. TYLER, CIVIL ACTION -LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Dianne P. Tyler, an adult individual residing at 125 West Vine Street, Shiremanstown, Cumberland County, Pennsylvania 17011. 2. Defendant is John L. Tyler, an adult individual whose current address is unknown. Defendant's last known residence was 125 West Vine Street, Shiremanstown, Cumberland County, Pennsylvania 17011. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months prior to filing this complaint. 4. The Plaintiff and Defendant were married on February 18, 2006 in Raleigh, North Carolina. 5. There are no minor children born of this marriage. 6. The parties separated on September 5, 2009. 7. There have been no prior actions for divorce or annulment between the parties. 8. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 9. Plaintiff has been advised that counseling is available and that Plaintiff has the right to request that the court require the parties to participate in counseling. COUNT I - DIVORCE NO FAULT 10. The averments in paragraphs 1 through 9 of Plaintiffs Complaint are incorporated herein by reference thereto. 11. The marriage is irretrievably broken and no possibility of reconciliation exists. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with §3301 of the Pennsylvania Divorce Code. INDIGNITIES 12. The averments in paragraphs 1 through 11, inclusive of Plaintiffs Complaint are incorporated herein by reference thereto. 13. Plaintiff is the innocent and injured party, and Defendant has offered such indignities to the person of the Plaintiff and has been mentally cruel to her so as to make her life burdensome and her condition intolerable, in violation of the marriage vows and of the laws of the Commonwealth. WHEREFORE, Plaintiff requests this Court to enter a decree in divorce in accordance with Pennsylvania Divorce Code. COUNT II SUPPORT, ALIMONY PENDENTE LITE AND ALIMONY 14. The averments in paragraphs 1 through 13 of Plaintiffs Complaint are incorporated in by reference thereto. 15. Plaintiff requires reasonable support to adequately sustain herself with the standard of iving established during the marriage. WHEREFORE, Plaintiff requests an award of Support, Alimony and Alimony Pendente Lite. WHEREFORE, Plaintiff, Dianne P. Tyler, prays this Honorable Court to enter judgment: A. Awarding Plaintiff a decree in divorce; B. Awarding Plaintiff support, alimony and alimony pendente lite; and C. Awarding other relief as the Court deems just and reasonable. Dated: October 27, 2009 Barbara Sumple-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 DIANNE P. TYLER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. JOHN L. TYLER, CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT REGARDING COUNSELING 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not require that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A Section 4904 relating to unsworn falsification to authorities. Dated: 2009 DIANNE P. TYLER Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 DIANNE P. TYLER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. JOHN L. TYLER, Defendant NO. CIVIL ACTION -LAW IN DIVORCE VERIFICATION I, Dianne P. Tyler, hereby certify that the facts set forth in the foregoing Pleading are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. DatedN'l 2009 DIANNE P. TYLER RE}" a OF THE PROrrfO NOTARY 2H9 OCT 21 AM 9= 44 CUP BEI d i COUNTY PENNSYLVANIA 4&04.50 Po hni CKI yo-7o ?? M4 23..V.&q k- "a% Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 DIANNE P. TYLER, : IN THE COURT OF COMMON PLEAS Plaintiff V. JOHN L. TYLER, Defendant CUMBERLAND COUNTY, PENNSYLVANIA NO. b9-7374 CivilTr" : CIVIL ACTION -LAW IN DIVORCE DRS ATTACHMENT FOR APL PROCEEDINGS PE TITIONER NAME Dianne P. Tyler ADDRESS 125 West Vine Street, Shiremanstown, PA BIRTH DATE 3/4/1966 SOCIAL SECURITY NUMBER 119-62-3003 HOME PHONE 717-737-0606 WORK PHONE 717-691-1300 EMPLOYER NAME Hampton Inn EMPLOYER ADDRESS 4950 Ritter Road, Mechanicsburg, PA JOB TITLE/POSITION Housekeeper DATE EMPLOYMENT COMMENCED September 25, 1994 GROSS PAY $10.85/hr NET PAY Various OTHER INCOME None ATTORNEY'S NAME Barbara Sum le-Sullivan, Esquire ATTORNEY'S ADDRESS 549 Bride Street, New Cumberland, PA 17070 ATTORNEY'S PHONE NUMBER (717) 774-1445 RESPONDENT NAME John L. Tyler ADDRESS Unknown BIRTH DATE 8/9/1965 SOCIAL SECURITY NUMBER 131-64-3794 HOME PHONE 919-669-3306 WORK PHONE 919-669-3306 EMPLOYER NAME Lobar Associates MPLOYER ADDRESS 4 Barlo Circle, Dillsbur , PA 17019 In% JOB TITLE/POSITION Mason DATE EMPLOYMENT COMMENCED August, 2004 GROSS PAY Unknown NET PAY Unknown OTHER INCOME Self-Employed Mason ATTORNEY'S NAME Unverified ATTORNEY'S ADDRESS Unverified ATTORNEY'S PHONE NUMBER Unverified MORTGAGE INFORMATION DATE OF MARRIAGE February 18, 2006 PLACE OF MARRIAGE Raleigh, North Carolina DATE OF SEPARATION September 5, 2009 ADDRESS OF LAST MARITAL HOME 125 West Vine Street Shiremanstown, PA DESCRIPTION OF DOCUMENT RAISING APL CLAIM Divorce Complaint DATE APL DOCUMENT FILED October 27, 2009 r of AM60ARY. 2009OCT 27 AM 9:46 PENNSYLV941A. Cope 6 up -0 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 DIANNE P. TYLER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09-7374 JOHN L. TYLER, CIVIL ACTION -LAW Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Thomas D. Gould, Esquire, hereby accept service and acknowledge receipt of the above- captioned Divorce Complaint on behalf of Defendant, John L. Tyler, having received said Complaint on the 20 day of Ap 1),tl' , 2009. Thomas D. Gould, Esquire 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 Attorney for Defendant FILED--Cli=-Y E OF THE PIP )`:oo, OTAAY 2009 NOV -5 AM 9: 29 PENNSYL'VAN0. Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 DIANNE P. TYLER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09-7374 PACSES NO. 999111196 JOHN L. TYLER, CIVIL ACTION -LAW Defendant IN DIVORCE PETITION REQUESTING HEARING ON ALIMONY PENDENTE LITE 1. Petitioner is Dianne P. Tyler, Plaintiff, residing at 125 West Vine Street, Shiremanstown, Cumberland County, PA 17011 2. Respondent is John L. Tyler, Defendant, whose current address is unknown. Defendant's last known residence was 125 West Vine Street, Shiremanstown, Cumberland County, Pennsylvania 17011. 3. On October 27, 2009, Plaintiff filed a claim for Alimony Pendente Lite as part of her Divorce Complaint. 4. Petitioner will need financial support pending the divorce proceedings and thereafter. 5. Respondent has sufficient assets to provide alimony pendente lite for Petitioner. 6. A Domestic Relations Section Attachment for APL Proceedings is attached hereto as Exhibit "A" which was filed with the Prothonotary on October 27, 2009. 7. It is requested that the hearing on Alimony Pendente Lite be held simultaneously with the support conference scheduled between the parties on Thursday, November 12, 2009 at 9:00 a.m. to Domestic Relations Docket Dianne P. Tyler v. John L. Tyler, Docket No. 00865 S 2009, PACSES No. 999111196 before Conference Officer Shadday. WHEREFORE, Petitioner requests a hearing be scheduled on her alimony pendente lite claim. Respectfully submitted, DATE: November 9, 2009 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 Exhibit A • Barbara Sumple-Sullivan, Esquire Supreme Court 432317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 DIANNE P. TYLER, Plaintiff V. JOHN L. TYLER, Defendant • IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CA - '737q O-A v i t C -00c o = n r zy : CIVIL ACTION - LAW p,- -' s.,, rv m3 IN DIVORCE c w DRS ATTACHMENT FOR APL PROCEEDINGS C7, 4 PE TITIONER NAME Dianne P. Tyler ADDRESS 125 West Vine Street, Shiremanstown, PA BIRTH DATE 3/4/1966 SOCIAL SECURITY NUMBER 119-62-3003 HOME PHONE 717-737-0606 WORK PHONE 717-691-1300 EMPLOYER NAME Hampton Inn EMPLOYER ADDRESS 4950 Ritter Road, Mechanicsburg, PA JOB TITLE/POSITION Housekeeper DATE EMPLOYMENT COMMENCED September 25, 1994 GROSS PAY $10.85/hr NET PAY Various OTHER INCOME None ATTORNEY'S NAME Barbara Sum le-Sullivan, Esquire ATTORNEY'S ADDRESS 549 Bride Street, New Cumberland, PA 17070 ATTORNEY'S PHONE NUMBER (717) 774-1445 RESPONDENT NAME John L. Tyler ADDRESS Unknown BIRTH DATE 8/9/1965 SOCIAL SECURITY NUMBER 131-64-3794 HOME PHONE 919-669-3306 WORK PHONE 919-669-3306 EMPLOYER NAME Lobar Associates EMPLOYER ADDRESS 4 Barlo Circle, Dillsbur , PA 17019 . , ? . 1 0 0 JOB TITLE/POSITION Mason DATE EMPLOYMENT COMMENCED August, 2004 GROSS PAY Unknown NET PAY Unknown OTHER INCOME Self-Employed Mason ATTORNEY'S NAME Unverified ATTORNEY'S ADDRESS Unverified ATTORNEY'S PHONE NUMBER Unverified MORTGAGE INFORMATION DATE OF MARRIAGE February 18, 2006 PLACE OF MARRIAGE Raleigh, North Carolina DATE OF SEPARATION September 5, 2009 ADDRESS OF LAST MARITAL HOME 125 West Vine Street Shiremanstown, PA DESCRIPTION OF DOCUMENT RAISING APL CLAIM Divorce Complaint DATE APL DOCUMENT FILED October 27, 2009 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 DIANNE P. TYLER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09-7374 PACSES NO. 999111196 JOHN L. TYLER, CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing Petition Requesting Hearing On Alimony Pendente Lite in the above-captioned matter upon the following individual(s) by first class mail, postage prepaid, addressed as follows: DATED: November 9, 2009 Thomas D. Gould, Esquire 2 East Main Street Shiremanstown, PA 17011 Barbara Sumple-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 Ty