HomeMy WebLinkAbout10-33691r) V
RICHARD JAMES HALL
Plaintiff
V.
MELISSA ANN HALL
Defendant
2010 VIM 20 AM
F COMMON PLEAS
COUNTY, PENNSYLVANIA
NO. lU 33? I t4/
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 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, 1 Courthouse Square, Carlisle, PA.
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, PA 17013
1-800-990-9108
717-249-3166
Jqf? .King, Esquire ?n
71. GU
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JOHN F. KING LAW, P.C.
John F. King, Esq.
ID#61919
4076 Market Street
Camp Hill, PA 17011
717-695-2222 / 717-695-2207 FAX
RICHARD JAMES HALL
Plaintiff
V.
MELISSA ANN HALL
Defendant
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. /0-336(7 C ?vi-l
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT UNDER SECTION 3301(c) OR SECTION 3301(d)
OF THE DIVORCE CODE
1. Plaintiff is Richard James Hall, who currently resides at 904 Haven Ridge Road,
Ceres, VA 24318, April 14, 2010.
2. Defendant is Melissa Ann Hall, who currently resides at 2267 Newville Road,
Car1We- , PA 11015
Cumberland County, PA, since May 2008.
3. The Defendant has been a bona fide resident in the Commonwealth for at least six
(6) months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on February 29, 2008, in Tennessee.
5. The parties separated on March 19, 2010.
6. There have been no prior actions of 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.
COUNT 1
REQUEST FOR EQUITABLE DIVISION OF MARITAL PROPERTY
PURSUANT TO 23 Pa.C.S.A. & 3502(a)
8. The prior paragraphs of this Complaint are incorporated herein by reference thereto.
9. The Plaintiff and Defendant have legally and beneficially acquired property, both
real and personal, during their marriage.
10. The Plaintiff and Defendant have been unable to agree as to equitable distribution
of the said property to the date of the filing of this Complaint.
WHEREFORE, the Plaintiff, Richard James Hall, requests this Court to equitably divide
all marital property.
COUNT2
REQUEST FOR ALIMONY PENDENTE LITE
UNDER SECTION 3702 OF THE DIVORCE CODE AND
ALIMONY UNDER SECTION 3701(a) OF THE DIVORCE CODE
11. The prior paragraphs of this Complaint are incorporated herein by reference hereto.
12. Plaintiff lacks sufficient property or income to provide for his reasonable needs and
legal expenses during the course of this litigation.
13. Plaintiff requests the Court to enter an award of alimony pendente lite until final
hearing, pursuant to Section 3702 of the Divorce Code.
WHEREFORE, the Plaintiff respectfully requests the Court to enter an award of
alimony pendente lite until final hearing, pursuant to Section 3702 of the Divorce Code, and upon
entry of divorce, to enter an award of alimony, pursuant to Section 3701(a) of the Divorce Code.
Dated: May , 2010
Respectfully submitted,
JOHN F. KING LAW, P.C.
By:
,john F. King, Esq.
ID #61919
4076 Market Street
Camp Hill, PA 17011
717-695-2222 / 717-695-2207 FAX
VERIFICATION
I, Richard James Hall, hereby acknowledge that I am the Plaintiff in the foregoing action;
that I have read the foregoing Complaint in Divorce; and the facts stated therein are true and
correct to the best of my knowledge, information and belief.
I understand that any false statements herein are made subject to penalties of 18 Pa. C.S.
Section 4904, relating to unsworn falsification to authorities.
---?Lk -1 &-)'? ??Sga
Richard Jame Hall
DATE: May , , 2010
of cu4,
David 1D. Buell a P enee X Simpson
Prothonotary 15` Deputy Prothonotary
r "" o
rkS. Sohonage, E,SQ V +\ Irene E. 911orrow
Solicitor ,750 2nd Deputy Prothonotary
Office of the Prothonotary
Cum6erCand County, cennsylvania
4 -334,9 CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 29TH DAY OF OCTOBER, 2013,AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE—THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH
PA R.C.P.230.2.
BY THE COURT,
DAVID D. BUELL
PROTHONOTARY
One Courthouse Square • Suite 100 • Carlisle, PA 17013 • (717)240-6195 • 'Fax(717)240-6573