HomeMy WebLinkAbout09-7601
Nicole Benner, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
IN DIVORCE
Michael Rittle,
Defendant : NO. 09 - 7?? CIVIL TERM
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, Cumberland County Courthouse, 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, 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
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.
Nicole Benner,
Plaintiff
V.
Michael Rittle,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
NO. 09 - 760 J CIVIL TERM
DIVORCE COMPLAINT
The plaintiff, Nicole Benner, by her attorneys, the Family Law Clinic, sets forth the
following cause of action in divorce:
DIVORCE UNDER 23 Pa.C.S. §43301(c) AND 3301(d) OF THE DIVORCE CODE
1. Plaintiff is Nicole Benner, who currently resides at 206 Valley Road, Box 325
Summerdale, Cumberland County, PA 17093, since August of 2008.
2. Defendant is Michael Riffle, who currently resides at 485 Slaseman Dr., York, York
County, PA 17070, since January 2009.
3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months
immediately previous to the filing of this complaint.
4. Plaintiff and Defendant were married on September 17, 2005 at 71 Dugansmill Rd.,
Duncannon, Perry County, Pennsylvania.
5. Plaintiff and Defendant have lived separate and apart since July 22, 2008.
6. There have been no prior actions for divorce or for annulment between the parties.
7. The marriage is irretrievably broken.
8. 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.
WHEREFORE, Plaintiff requests the court to enter a decree of divorce.
r
A. Luke Smith
Certified Legal Intern
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RkbBEIVf E. RAINS 04
THOMAS M. PLACE
ANNE MACDONALD-FOX
LUCY JOHNSTON-WALSH
MEGAN RIESMEYER
Supervising Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
4
VERIFICATION
I verify that the statements made in the foregoing complaint are true and correct, to the
best of my knowledge, information and belief. I understand making any false statement
would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to
authorities.
Date 150 /1,49 Plaintiff
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Nicole Benner,
Plaintiff
V.
Michael Rittle,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
: NO. 09- 7061 CIVIL TERM
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow Nicole Benner, Plaintiff, to proceed in forma pauperis.
The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies
that we believe the party is unable to pay the costs and that we are providing free legal service to
the party.
Date l
Res tfully s mitted,
c
Luke Smith
Certified Legal Intern
kw&- ?W?
ROBE E. RAINS
THOMAS M. PLACE
ANNE MACDONALD-FOX
LUCY JOHNSTON-WALSH
WILLIAM G. MARTIN
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
717-243-3639
FILED-OFFICE
r HE M? "'NOTARY
2009140Y -4 AM 9: 5 5
NICOLE BENNER, : IN THE COURT OF COMMON PLEAS
Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION-LAW
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MICHAEL RITTLE :DIVORCE ,'' ~
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No. 09-7601 CIVIL TERM
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PRAECIPE TO REINSTATE COMPLAINT `~ ~~'
To The Prothonotary: x r~
Please reinstate the Divorce Complaint at the above-captioned docket.
Date: Z I U
Andrew H
Certified Legal Intern
Thomas/ lace ~G~
Megan Riesmeyer
Anne MacDonald-Fox
Supervising Attorneys
Family Law Clinic
45 N. Pitt St.
Carlisle, PA 17013
a~R s o zoo ~,
Nicole Benner, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. :CIVIL ACTION -LAW
IN DIVORCE
Michael Rittle,
Defendant : NO. 09 - 7601 CIVIL TERM
ORDER OF COURT
AND NOW, this ~ day of ~ ~l L , 2010 upon consideration
of the attached petition, it is hereby ordered that:
(1) a Rule is issued upon Nicole Benner to show cause why the Family Law Clinic
should not be granted leave to withdraw as counsel of record;
(2) Nicole Benner shall file an answer to the petition within twenty days of service
upon him;
(3) the petition shall be decided under Pa.R.C.P. No. 206.7;
(4) notice of the entry of this order shall be provided to all parties by the Family Law
Clinic.
BY THE COURT:
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