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Home My WebLink About02-0395MARY ELIZABETH RIEDER, Plaintiff v. WILLIAM LEROY RIEDER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 0o7-3¢( CIVIL : : 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 at the Cumberland County Courthouse, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GP~%NTED, 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 LAW~ER 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 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 MARY ELIZABETH RIEDER, Plaintiff WILLIAM LEROY RIEDER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION LAW IN DIVORCE COMPLAINT IN DIVORCE COUNT I 1. The plaintiff in this action is MARY ELIZABETH RIEDER, an adult individual, who currently resides at 424 Shelley's Lane, Etters, York County, Pennsylvania, 17319-9414. 2. The defendant in this action is WILLIAM LEROY RIEDER, an adult individual, who currently resides at 424 Shelley's Lane, Etters, York County, Pennsylvania, 17319-9414. 3. Both the plaintiff and the defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. The plaintiff and defendant were lawfully joined in marriage on June 27, 1970, in West Milton, Union County, Pennsylvania. 5. The plaintiff avers as to the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. -1- W~EREFORE, the plaintiff requests a decree in divorce pursuant to Section 3301(c) of the Divorce Code. COUNT II - ADULTERY 7. Paragraph numbers one through six are incorporated by refer- ence as if fully set forth herein. 8. The defendant in this action has committed adultery during the course and term of the marriage. 9. The alleged adulteress' name is Jerri Taylor and she resides at an unknown address in Carlisle, Pennsylvania, 17013. 10. The grounds upon which this action is based is 23 Pa. C.S.A. §3301(a) (2) as the defendant has committed adultery pursuant to that Section of the Divorce Code. W~EREFORE, the plaintiff requests a decree in divorce pursuant to Section 3301(a) (2) of the Divorce Code. COUNT III - INDIGNITIES 11. Paragraph numbers one through ten are incorporated by reference as if fully set forth herein. 12. The grounds upon which this action is based are indignities pursuant to Section 3301(a) (6) of the Divorce Code. During this -2- marriage, the defendant has committed such indignities against the plaintiff so as to make her life burdensome and intolerable. 13. The plaintiff requests the Court issue a decree in divorce based upon indignities pursuant to Section 3301(a) (6) . 14. The plaintiff has been advised that counseling is available and that the plaintiff may have the right to request that the court require the parties to participate in counseling. W~EREFORE, plaintiff respectfully requests this Honorable Court to issue a Decree in Divorce divorcing her from the bonds of matrimony pursuant to Section 3301(a) (6) of the Divorce Code. COUNT IV - EQUITABL~ DIVISION OF PROPERTY 15. Paragraph numbers one through 14 are incorporated by reference as if fully set forth herein. 16. The plaintiff, MARY ELIZABETH RIEDER, and the defendant, WILLIAM LEROY RIEDER, have lawfully and beneficially acquired property, both real and personal, during their marriage from June 27, 1970 until the present. 17. The plaintiff, MARY ELIZABETH RIEDER, requests the Court to equitably divide all marital property pursuant to Section 3502 of the Pennsylvania Divorce Act. W~R~FOR~, plaintiff respectfully requests this Honorable Court to award equitable distribution of the marital property. -3- COD-NT V - ALIMONY 18. Paragraph numbers one through 17 are incorporated by reference as if fully set forth herein. 19. The plaintiff, MARY ELIZABETH RIEDER, birth date July 13, 1951, currently lives at 424 Shelley's Lane, Etters, York County, Pennsylvania, 17319-9414. The defendant, WILLIAM LEROY RIEDER, birth date October 15, 1950, currently receives mail at 424 Shelley's Lane, Etters, York County, Pennsylvania, 17319-9414. 20. The plaintiff, MARY ELIZABETH RIEDER, requires reasonable support and alimony to adequately maintain herself in accordance with the standard of living established during the marriage. 21. The plaintiff, MARY ELIZABETH RIEDER, requests the Court to allow alimony as it deems reasonable pursuant to Sections 3701 and 3702 of the Pennsylvania Divorce Act. WI4EREFORE, the plaintiff requests this Honorable Court to award alimony to the plaintiff in such amount as this Court deems just and reasonable. -4- COUNT VI - ALIMONY PENDENTE LITE, COUNSEL FEES, AND EXPENSES 22. Paragraph numbers one through 21 are incorporated by reference as if fully set forth herein. 22. The plaintiff, MARY ELIZABETH RIEDER, has retained Elizabeth B. Stone as counsel and because of the anticipated protracted litigation expenses and her limited income is unable to pay for the expenses of counsel and litigation. 23. The plaintiff, MARY ELIZABETH RIEDER, has engaged the services of counsel on a time basis by which her attorney charges fees based at a rate of $150.00 per hour. 24. The plaintiff, MARY ELIZABETH RIEDER, requests the Court to allow her reasonable counsel fees, costs and expenses pursuant to Section 3702 of the Pennsylvania Divorce Act. WHEREFORE, the plaintiff prays your Honorable Court to require the defendant to pay just and reasonable counsel fees, costs and expenses incurred by plaintiff and such other relief as this Court deems just and reasonable. -5- I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 P.C.S. §4904, relating to unsworn falsification to authorities. Date: ~~zabet~ Riede Respectfully Submitted, STONE LaFAVER/~'"SHEKLETSKI Eliz~th ~ Ston~{ Esquire Su~f~me CoUrt NQ¥ 60251 ~ Brid~ St~%t /New Cumberland, PA 17070 / Tel.# ~7.7~4.7435 ~to~/for the Plaintiff / -6- ~TONE, LAFAYER & SHEKLETSKI ATTO[~N[KY$ AT [.AW NEW CUMBERLAND, PA 170?O NO. In the Court of Common Pleas of Cumberland County, Pennsylvania To Prothonotary No, Filed Term, 19 ~ *eS, PRAECIPE RETURN OF SERVICE On the IX day of I verify that the statements in this return of service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Date: ,~1/ 2/~ ~,.~0 ?. £6.