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Home My WebLink About05-1596N THE COURT OF COMMON PLEAS OF :UMBERLAND COUNTY, PENNSYLVANIA ' 1.1 1n. OS -159t? C 11 CIVIL ACTION - AT LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS BRETT A. GRAHAM, Defendant 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, 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 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 800-990-9108 THERINE R. GRAHAM, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. A. GRAHAM, : CIVIL ACTION-AT LAW Defendant : IN DIVORCE IN DIVORCE UNDER SECTIONS 3301(c) or 3301(d) OF THE DIVORCE CODE The Plaintiff, Catherine R. Graham, by and through his attorneys, The Law Offices of F. Lauer, Jr., makes the following Complaint in Divorce: COUNT I - NO-FAULT DIVORCE 1. The Plaintiff, Catherine R. Graham, is an adult individual who currently resides at 131 West Big Spring Avenue, Newville, Cumberland County, Pennsylvania 17241. 2. The Defendant, Brett A. Graham, is an adult individual who currently resides at 854 e Road, Newville, Cumberland County, Pennsylvania 17241. 3. The Parties have been bona fide residents of the Commonwealth of Pennsylvania for least six months immediately prior to the filing of this Complaint. 4. The parties were married on July 31, 1999, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff and 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. 8. This action is not collusive. WHEREFORE, the Plaintiff requests this Honorable Court to enter a Decree of Divorce in this matter. COUNT H - EQUITABLE DISTRIBUTION 9. Paragraphs one (1) through eight (8) of this Complaint are incorporated herein by reference as if set forth specifically below. 10. During the course of the marriage, the parties acquired property and incurred debt, titled either solely or jointly between them, and enjoyed the increase in value of pre-marital property, all of which constitute a marital estate. WHEREFORE, the Plaintiff respectfully requests the Court to enter an order of equitable of marital property pursuant to § 3502(a) of the Divorce Code. COUNT III - ALIMONY AND ALIMONY PENDENTE LITE - § 3702 11. Paragraphs one (1) through ten (10) of this Complaint are incorporated herein by ,e as if set forth specifically below. 12. The Plaintiff is the dependent spouse and Plaintiff lacks sufficient property to provide her reasonable means and is unable to support herself completely through appropriate 13. Plaintiff requires reasonable support to adequately maintain herself in accordance with standard of living established during the marriage. WHEREFORE, the Plaintiff requests your Honorable Court to enter an aware of reasonable alimony upon final hearing and permanently thereafter. ??? I z??s Date: Respectfully submitted, arl n . Markley, Esquire Law 01fices of Patrick F. Lauer, Jr., LLC 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 R. GRAHAM, Plaintiff VS. A. GRAHAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. CIVIL ACTION - AT LAW IN DIVORCE Yi'?il lQ.r111i/ 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 Pa. C.S. § 4904, relating to unworn falsification to authorities. Signature: CATHERINE R. G M ?? Date: 3/1 c? N 0 F\FILMDATAFILB\GenmACumn 11579.1.paI Created: 9120104 0.06PM Re,ued. 422/05 3 35PM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff CATHERINE R. GRAHAM, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 05-1596 : CIVIL ACTION - LAW BRETT A. GRAHAM, Defendant JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTSON DEARDORFF WILLIAMS & OTTO on behalf of Defendant in the above matter. MARTSON DEARDORFF WILLIAMS & OTTO By knnife4 L. S ears, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant s Dated: April , 2005 CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Marlin L. Markley, Esquire Law Offices of Patrick F. Lauer, Jr., LLC 2108 Market Street, Aztec Building Camp Hill, PA 17011 MARTSON DEARDORFF WILLIAMS & OTTO 4) Y? ri is D. Eckenroad Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: 0?j d5' 000,5' C7 ?i '`--'> -i ? C: ? __? ,`n?. r?a u ??';. _ ; ??` <,r°? r? ' _? _ Lf' J7 _ W CATHERINE R. GRAHAM, Plaintiff vs. BRETT A. GRAHAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2005-1596 CIVIL ACTION - AT LAW IN DIVORCE TO THE HONORABLE JUDGES OF SAID COURT: AND NOW, comes Petitioner, Marlin L. Markley, Esquire, and in support of his Petition to Withdraw Appearance, respectfully represents as follows: 1. Petitioner is Marlin L. Markley, Esquire, an attorney with offices located at 2108 Market Street, Camp Hill, Pennsylvania. 2. Respondent is Catherine R. Graham resides at 33 Vine Street, Newville, Pennsylvania. 3. Petitioner was retained by Respondent on or about February 11, 2005, to represent her in connection with her domestic relations matters. 4. A Complaint in Divorce was filed with this Honorable Court on or about March 24, 2005 thereby instituting the above-captioned action. 5. Petitioner anticipates that there will be prolonged proceedings in the above matters. 6. On or about September 26, 2005 Petitioner received a voice mail from Respondent terminating his legal services to Respondent. 7. Petitioner has at all times attempted to represent Respondent effectively and vigorously to the best of his ability. 8. Petitioner asks to withdraw his appearance for Catherine R. Graham because, inter alia: a. Respondent has requested that Petitioner terminate all further legal services regarding Respondent's case. b. Continued representation will result in an unreasonable financial burden on Petitioner. WHEREFORE, Petitioner respectfully requests that his appearance be withdrawn for Respondent and that he be removed from the docket as the attorney of record for Catherine R. Graham. Respectfully Submitted: BY: MarliVkke-t -'Markley, Esquire 2108 Street, Aztec Building Cap , Pennsylvania 17011-4706 Date: October 25, 2005 ID# 84745 Tel. (717) 763-1800 Attorney for Plaintiff CATHERINE R. GRAHAM, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 2005-1596 BRETT A. GRAHAM, CIVIL ACTION - AT LAW Defendant IN DIVORCE I, Marlin L. Markley, verify that the statements made in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: October 25, 2005 M n L. Markley CATHERINE R. GRAHAM, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 2005-1596 BRETT A. GRAHAM, CIVIL ACTION - AT LAW Defendant IN DIVORCE I, Marlin L. Markley, Esquire, hereby certify that on the below-noted date 1 served the foregoing Petition to Withdraw Appearance by depositing a true and exact copy thereof in the United States Mail, first class, postage prepaid, addressed as follows: Catherine R. Graham 33 Vine Street Newville, PA 17241 Jennifer L. Spears, Esquire 10 East High Street Carlisle, PA 17013 Respectfully Submitted: i7, ?--_ //Marls . Markley, Esquire 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 Date: October 25, 2005 ID# 84745 Tel. (717) 763-1800 OCT 2 7 Zm r CATHERINE R. GRAHAM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Vs. : No. 2005-1596 BRETT A. GRAHAM, CIVIL ACTION - AT LAW Defendant : IN DIVORCE AND NOW, this 34 day of 2005, upon consideration of the foregoing Petition to Withdraw Appearance of Petitioner, Marlin L. Markley, Esquire, it is hereby ORDERED AND DECREED that Marlin L. Markley, Esquire is permitted to withdraw as counsel for Respondent, Catherine R. Graham. J. BY THE COURT h L, . Gfa :L J to 1 ?0 CATHERINE R. GRAHAM, Plaintiff, VS. BRETT A. GRAHAM, Defendant, TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2005-1596 CIVIL CIVIL ACTION -- AT LAW IN DIVORCE Kindly withdraw my appearance on behalf of Catherine R. Graham, the Plaintiff in the above-captioned matter. Date: November 8, 2005 Respectfully submitted, M L. Markley, Esquire Law ffices of Patrick F. Lauer, Jr., LLC 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 r? ry C7 i` ! c4?' tv Curtis R. Long Prothonotary office of the Protbonotarp Cumberralab Cauntp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor l 944 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER 2008 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 0 Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573