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Home My WebLink About01-2680LINDA S. DARLING, : COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 01 -e2a6 Chit ,? : CIVIL ACTION-LAW ROBERT G. DARLING Defendant IN DIVORCE NOTICE TO DEFENDANT AND CLAIM OF 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 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's office at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FH.E 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUR WHERE YOU CAN GET LEGAL HELP. Office of the Court Administrator Cumberland County Courthouse, 4th Floor Carlisle, PA 17013 (717) 240-6200 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. Michael I. Kane Reg. No. 46215 Kane and Mackin, LLP 3300 Trindle Rd. Camp HiQ, PA 17011 (717) 214-3700 Attorney for Plaintiff LINDA S. DARLING, : COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. . NO. 0/- : G SD (?;;, ( Tr o.- CIVIL ACTION-LAW ROBERT G. DARLING, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(C) AND 3301(D) OF THE DIVORCE CODE COMES NOW, Linda S. Darling, through her attorney, Michael J. Kane, Esquire, and avers as follows: COUNT ONE - DIVORCE 1. Plaintiff, Linda S. Darling is an adult individual, whose current address is 68 Sunset Dr., Mechanicsburg, Cumberland County Pennsylvania 17055. 2. Defendant is Robert Darling, who resides at 68 Sunset Dr., Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married in August 29, 1970 in Enola, PA. 5. There have been no prior actions of divorce filed in this matter. 6. Neither Plaintiff nor Defendant is a member of the Armed Forces of the United States. 7. The marriage is irretrievably broken and the parties are proceeding under Section 3301 (c) and 3301 (d) of the Divorce Code. 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 enter a decree of divorce. COUNT II REQUEST FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502(a) OF THE DIVORCE CODE 9. Plaintiff and Defendant have acquired marital property as defined by the Divorce Code, which is subject to equitable distribution pursuant to Section 3502(a) of the Divorce Code. 10. Plaintiff and Defendant have been unable to agree as to the equitable division of said property as of the date of filing of this Complaint. 11. Defendant requests that this Court equitably divide, distribute or assign the marital property between the parties. WHEREFORE, Defendant respectfully requests that the Court enter an order of equitable distribution of marital property pursuant to Section 3502(a) of the Divorce Code. Respectfully submitted, 4J.&-a ? Y.? Michael J. KaneJkeg. No. 46215 Kane and Mackin, LLP 3300 Trindle Rd. Camp Hill, PA 17011 (717) 214-3700 Attorney for Plaintiff VERIFICATION I verify that the statements made in this complaint are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 P. S. § 4904 relating to unsworn falsification to authorities. '1--+,3A -O/ Date PI ntiff ?, h O n:r• r • :?i i n C49N LINDA S. DARLING, Plaintiff V. ROBERT G. DARLING Defendant : COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001-2680 : CIVIL ACTION-LAW IN DIVORCE PRAECIPE TO FILE RETURN OF SERVICE TO THE PROTHONOTARY: Please accept for filing this proof of service of the Complaint on the Defendant in the above- captioned case. Respectfully submitted, Michael J. Kane R`eg. No. 46215 Kane and Mackin, LLP 3300 Trindle Rd. Camp Hill, PA 17011 (717) 214-3700 Attorney for Plaintiff Y i.o•11lplela 1. = I. 1•1:.0 )1 111plete el l':..II jJI:r l.dli':i•al:•.. ?.._ .. ?. ?.11..?•,:\•ef53 •w tll.lt \•., {..:fI 141: 11 u11: "::I'.l ¦illacl 1. An:.:,v Addl..: J t. Ale ?y £f 3Gi fr( !? ?1\CSBUgG /l/?'_ ??,?.,_: 'u -s '? •?' 26^1 MAY 1t 70 5 S A. Received by (Please Print Clearly) B. Date of Delivery C. Signature X ? Agent ? Addressee U. Is dclo-arl addle... dlflerent from item 19 ? Yes If YES. enter delivery address below: 13 No rJECSnlOadlMail 0 Express Mail C3 R? at t7 Return Receipt for Merchandise O'In M Mail ? C.O.D. _ 4. Restricted Delivery! ilSdrs Fee) p Yes VArlicle Number (Copy hom service label) 7099 3Yov soot 3YY?/ ?1/f t ff11 I t ! PS Forrn 3811, July 1999 Domestic Return Receipt 102595-wed-lies If e (.7 r.:_? ? ...__ _? _?? r_.-. ? iri,_: t:i , r ? =? ? _ :: r in -. LINDA S. DARLING, Plaintiff ROBERT G. DARLING, Defendant v IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01 - 2680 CIVIL ACTION - LAW IN CUSTODY INCOME AND EXPENSE OF PLAINTIFF. LINDA S. DARLING Plaintiff files the following Income and Expense Statement. Plaintiff verifies that the statements made in this Income and Expense Statement are true and correct. Defendant understands that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. LINDA S. DAR LING INCOME AND EXPENSE STATEMENT OF LINDA S., DARLING INCOME Employer: Rite Aid Commation Address: P. O. Box 3165. Hartisbur¢ PA 17105 Type of Work: Office Payroll Number: 831079 Pay Period (weekly, biweekly, etc.): Bi-weekly Gross Pay per Pay Period: $ 1 464.12 Itemized Payroll Deductions: Federal Withholding $ 142.26 FICA & Medicare $ 106.32 Local Wage Tax $ 1390 State Income Tax $ 42.67 Unemployment $ 1.32 Retirement $__0-92 (401k1 Savings Bonds $ Credit Union $ 50.00 Life Insurance $__U.24 Health Insurance & Dental $--2-4,14 Other - (United Way) $ 5.00 Net pay per Pay Period: $ 973. Other Income: NIA Year: Interest - Individual $ Joint $ Dividends $ Pension $ Annuity $ Social Security $ Rents $ Royalties $ Expense Account $ Gifts $ Unemployment Comp. $ Workmen's Comp. $ Total $ TOTAL MONTHLY NET INCOME $ 973 - 8 - gINR'/ I Mont Year Personal Clothing $ 80.00 $ Groceries $ 300. 00 $ Other (household supplies, barber, etc) $ 75.00 $ Credit pmts/loans $ 100.00 $ Miscellaneous Household help and child care $ $ - Entertainment (Pay TV, papers, 00 $ 75 $ _ Vacation, etc.) . Gifts/Charitable $ Contributions $ 260.00 Other (specify) Membership (Exercise) $ 29.00 $ - Legal Fees $ - $ Washer, TV, appliance repairs $ 91 $ 8 - $ 107.00 AAA Membership (both) . TOTAL EXPENSES $ 2 093.4 - 10 - 908821 n N C- c.> - : G Tl I .?. O --1 1 ,.. T _ -F7 fll? -!-! G1 ''fir L j'; ?`- ICJ ; y. i,'l ^ LINDA S. DARLING, Plaintiff ROBERT G. DARLING, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 01 - 2680 CIVIL ACTION - LAW IN CUSTODY INVENTORY AND APPRAISEMENT OF PLAINTIFF, LINDA S DARLING Plaintiff files the following Inventory and Appraisement of all property owned or possessed by either party at the date of separation and all property transferred within the preceding three years. Plaintiff verifies that the statements made in this Inventory and Appraisement are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C. S. §4904 relating to unsworn falsification to authorities. Lc?I. LINDA S. DARLING ASSETS OF PARTIES (x (x ( ( (x ( ( ( ( ( ( ( ( ( 6. Savings accounts, money market and savings certificates 7. Contents of safe deposit boxes 8. Trusts 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) 10. Annuities 11. Gifts 1. Real property 2. Motor vehicles 3. Stocks, bonds, securities and options 4. Certificates of deposit 5. Checking accounts, cash 12. 13. 14. 15. ) 16. ( ) 17. ( x ) 18. ( x ) 19. ( ) 20. ( ) 21. ( ) 22. ( ) 23. (x ) 24. (x ) 25. ( ) 26. Inheritances Patents, copyrights, inventions, royalties Personal property outside the home Business (list all owners, including percentage of ownership, and officer/director positions held by a party with company Employment termination benefits - severance pay, workman's compensation claim/award Profit sharing plans Pension plans (indicate employee contribution and date plan vests) Retirement plans, Individual Retirement Accounts Disability payments Litigation claims (matured and unmatured) MilitaryN.A. benefits Education benefits Debts due, including loans, mortgages held Household furnishings and personalty Other MARITAL PROPERTY List all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced: Description of Property Names of All Owners 68 Sunset Drive $80,000 to $90,000 H & W Mechanicsburg, PA 17050 HEL Credit Union Account joint $2,558 Rite Aid 401k $15,983.00 W Rite Aid Pension W Railroad pension H 96 Chevy Lumina 4 door H & W 52,000 miles power windows and locks GMAC 3 years are left on it $216 1988 Buick LeSabre 4 door H sold for a 200,000 miles `98 Mitsubishi Eclipse 2 burial plots from Rolling Green Rolling Green Cemetary Salomon Smith Barney IRA H $10,177 as of March 30, 2003 State Farm insurance H State Farm IRA H Household furnishings LIABILITIES Creditor Fulton Bank Visa 4756 2100 0012 9588 Debtor DOS value Pavor h & w 2,550 Wife Chase 5222 7630 5011 0422 W 1,750 Marital 40-01-8013266930 PNC Bank -Home Equity Loan Marital .(H & W) Both Paid Off (Fulton and Chase) Loan for `98 Mitsubishi Eclipse H $222/month N - cn ?? n^ Fn SC -fl f\l CA s r Curtis R. Long Prothonotary Offire of the Protbonotarp CUmberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor n I - .2& PA CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 5TH DAY OF NOVEMBER 2007 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, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573