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Home My WebLink About04-3967RICHARD J. BEISHLINE, Plaintiff V. LEAHANN BEISHLINE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04 - -391,,7 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 in 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. 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 By: Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 (717)236-8515 Attorney for Plaintiff Dated: //t// V RICHARD J. BEISHLINE, Plaintiff V. LEAHANN M. BEISHLINE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. OL4 -.3'74.7 r /LUI?Eru? CIVIL ACTION-LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW, this 10`s of August, 2004, comes the Plaintiff, Richard Beishline, by and through his attorney, Joseph J. Dixon, Esquire, who respectfully avers as follows: The Plaintiff, Richard Beishline, is an adult individual who resides at, 16 Landsdowne Road, East Brunswick, New Jersey 08816. 2. The Defendant, Leahann Beishline, is an adult individual who resides at 6 E. North Avenue, Enola, Cumberland County, Pennsylvania, 17025. The Defendant has been a bone fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 24, 2000 in Hummelstown, Dauphin County, Pennsylvania. 5. The parties separated on March 4, 2004. 6. There have been no prior actions for divorce or annulment between the parties. There are two (2) children bom of this marriage, Benjamin James Beishline born 11/13/01 and Jacob Richard Beishline born 04/16/03. 8. The Plaintiff and Defendant are both citizens of the United States of America. 9. The Plaintiff has been advised of her right to seek marriage counseling in this divorce action, but waives the right to do so. VERIFICATION I verify that the statements made in this CIJG~2???, are true and correct. I understand that false statements herein are made subject to the penalty of I8 Pa. C.S. §4904, relating to unsworn falsification to authorities. Dated: 7 r.,i ? ._ ? _ 1 RICHARD J. BEISHLINE, Plaintiff V. LEAHANN BEISHLINE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 04-3967 Civil Term CIVIL ACTION - LAW IN DIVORCE REQUEST FOR COUNSELING PURSUANT TO SECTION 3302 OF THE DIVORCE CODE Defendant Leahann Beishline through her attorneys, the Family Law Clinic, respectfully requests that this Court enter an Order requiring counseling pursuant to Section 3302(b) of the Divorce Code and Pa.R.Civ.P. 1920.45. In support of her Petition, Defendant avers the following: 1. Leahann Beishline is the defendant in a divorce action brought on the grounds of mutual consent under Section 3301(c) of the divorce code. 2. Despite the averments contained in the complaint, Defendant believes and thus avers that the marital differences are not irreparable. 3. Defendant also avers that there is a reasonable prospect of reconciliation. WHEREFORE, Defendant requests that the Court direct the parties to participate in a maximum of three counseling sessions with a qualified professional as provided under Section 3302(b) of the Divorce Code and that the parties share equally the costs of the counseling sessions. Date: Q 13104 4 Amy I!) Kruzel Certified Legal Intern G ARO INS THOMASPLACE LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Counsel for Defendant Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 VERIFICATION Understanding that the making of any false statement would subject me to the penalties of 18 Pa.C.S § 4904, I verify that I am the Defendant in the present action, and that the facts and statements contained in the above Request for Counseling Pursuant to Section 3302 of the Divorce Code are true and correct, to the best of my knowledge, information and belief. Z- 31-0q $qq?amA!?An.z Date Leahann Beishline Defendant `1 1 RICHARD J. BEISHLINE, Plaintiff V. LEAHANN BEISHLINE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 04-3967 Civil Term CIVIL ACTION-LAW IN DIVORCE PRAECIPE TO PROCEED IN FOR1 A PA_ U_ PERIS To the Prothonotary: Kindly allow Leahann Beishline, Defendant, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies the that we believe the party is unable to pay the costs and that we are providing free legal serv party, ice to Respectfully submitted, Date: Q 13104 Q. Amy L. Kruzel Legal Intern 444 N4?_ LUCYJ STON-WA S ANNE MACDONALD-FOX Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ("? N r... c°a C" f . ?? s- T} _ij.., Cw7 ?i r-. ` ?_ ' ri _ t7 ? g? TIn1 ' GJ J ? " ? ? ?) -?_a (_? , ;' i _ ' C ??i ? A . . C J ?? - Crrt =a ?' ? i CY) -.. RICHARD J. BEISHLINE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 04-3967 Civil Term LEAHANN BEISHLINE, CIVIL ACTION -LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Amy L. Kruzel, a Certified Legal Intern at the Family Law Clinic, hereby certify that I am serving a true and correct copy of Defendant's Request for Counseling Pursuant to Section 3302 of the Divorce Code on Joseph J. Dixon, Esquire, the attorney of record for the plaintiff, Richard J. Beishline. I am doing so by depositing a copy of same in the United States mail, First Class, postage prepaid, this P day of September, 2004, addressed as follows: Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 717-236-8515 Q Date 13104 Q' 4KA Q i D Amy LgKruzel Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 o C7 -• ro f .. ,J Renee K. Simpson Deputy Prothonotary Curtis R. Long Prothonotary cc Of tb e priatbanotaim Q?fft (Cumberlaub Countr John E. Slike Solicitor CIVIL TERM _----- 4 ER OF TERM ATION OF COURT CASES ORD EMBER 2007 AFTER MAILIN HE°BOV OF NOW THIS 5TH DAY OF NOVEMBER 2007 NO RESPONSE ANCE WITH PA AND INAT WITH PRE?ICE IN ACCORD INTENTION TO PROCEED AND D CASE IS HEREB R C P 230.2. BY THE COURT, CUR,TIS R. LONG PROTHONOTARY nns lvania 17013 (717) 240"6]95 • Fax (717) 240-6573 tine Courthouse Square 'Carlisle, Pe Y