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HomeMy WebLinkAbout05-4016BONNIE L. PEYSER, Plaintiff VS. RICHARD PEYSER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 05-- '1016 C',"I CIVIL ACTION - LAW DIVORCE 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 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 South Bedford Street Carlisle, PA 17013-3308 (717) 249-3166 BONNIE L. PEYSER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA (J? ?f C??a G!*-Q' VS. :No. RICHARD PEYSER, : CIVIL ACTION -LAW Defendant : DIVORCE AND NOW comes the Plaintiff, Bonnie L. Peyser, by and through her attorney, Jeanne B. Costopoulos, Esquire, and avers the following: 1. The Plaintiff, Bonnie L. Peyser, is an adult individual who currently resides at 1640 Williams Grove Road, Dillsburg, Cumberland County, Pennsylvania, 17019. 2. The Defendant, Richard Peyser, is an adult individual whose current residence is unknown. 3. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on December 12, 1998, in Mechanicsburg, Cumberland County, Pennsylvania. 5. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. 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. 9. This action is not collusive. WHEREFORE, the Plaintiff respectfully requests this Honorable Court grant the Plaintiff relief from the bonds of matrimony and order a Decree in Divorce. 10. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 11. Plaintiff lacks sufficient funds to support himself and pay counsel fees and expenses related to this action. 12. Defedant is able to pay Plaintiff alimony pendente lite, counsel fees and expenses related to this action. 13. Plaintiff requires reasonable support to adequately maintain himself in accordance with the standard of living established during the marriage. WHEREFORE, Plaintiff requests this Honorable Court to enter an award of alimony pendente lite, alimony, counsel fees and costs. 14. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 15. While no settlement has been reached as of the date of the filing of this Complaint, Plaintiff is and has always been willing to negotiate a fair and reasonable settlement of all matters with Defendant to the extent that a written Settlement Agreement might be entered into between the parties prior to the time of hearing on this Divorce Complaint, Plaintiff desires that such written Agreement be approved by the Court and incorporated, but not merged, in any Divorce Decree which might be entered dissolving the marriage between the parties. 16. Plaintiff and Defendant are the owners of various items of real and personal property, furniture and household furnishings acquired during their marriage which are subject to equitable distribution by this court. 17. Plaintiff and Defendant are the owners of various motor vehicles, bank accounts, investments, insurance policies and retirement benefits acquired during their marriage which are subject to equitable distribution by this court. WHEREFORE, Plaintiff requests the Court to enter a Decree: A. Dissolving the marriage between Plaintiff and Defendant; B. Equitably distributing all property owned by the parties hereto; C. In the event that a written Separation Agreement is reached between the parties hereto prior to the time of the hearing on this Complaint, Plaintiff respectfully requests that pursuant to the Divorce Code the Court approve and incorporate, but not merge such Agreement in the Final Divorce Decree; D. For such further relief as the Court may determine equitable and just. RESPECTFULLY SUBMITTED: BY: ,,ifflKid B. Costopoulos, Esquire 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 PA Supreme Court ID No. 68735 Telephone: (717) 790-9546 Dated: 4? BS ATTORNEY FOR PLAINTIFF BONNIE L. PEYSER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Vs. : No. RICHARD PEYSER, : CIVIL ACTION -LAW Defendant : DIVORCE I, Bonnie L. Peyser, hereby verify that the statements made in the foregoing Complaint in Divorce 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. Date: - y Q 5 Signature: Bonnie L. Peyser (:?i) tea` 41A 7' ?bl =c t BONNIE L. PEYSER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 05-4016 CIVIL RICHARD PEYSER, : CIVIL ACTION -LAW Defendant : DIVORCE The undersigned hereby verifies and states that on the date and time indicated below I personally hand-delivered upon Richard Peyser, Defendant, true and correct copies of the following documents: 1) Complaint in Divorce filed August 5, 2005. 2) Letter from Jeannd B. Costopoulos, Esquire, dated August 19, 2005. I further hereby swear and affirm that the above statement is true and correct and is made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date: 49-'a-1-0 ?_ By: ?` .L.. e.i Leo F. Luciano Luciano Investigative Services, LLC P.O. Box 9 Shermansdale, PA 17090 Telephone: (717) 215-5793 Time: t - (O . M BONNIE L. PEYSER, Plaintiff VS. RICHARD PEYSER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 05-4016 CIVIL : CIVIL ACTION -LAW : DIVORCE STATEMENT OF INTENTION TO PROCEED TO THE COURT: Plaintiff, Bonnie L. Peyser, intends to proceed with the above captioned matter. By: Jefd& B. Costopoulos, Esquire Attorney for Plaintiff, Bonnie L. Peyser 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Phone: (717) 221-0900 PA S.Ct. ID No. 68735 Dated: 7 /64 '?P a it r~; rri m PO x 1Jr+ _j rr, l P.-, / Ai t,°Q L- pQS- To the Court: ZQ�s-ar vs Case No. ; ' -_t > � c� r— X. —a c--:, STATEMENT OF INTENTION TO PROCEED =c) 7:-70 Print Name intends to proceed with the above captioned matter. Sign Name Date: 1 D lzy / Attorney for i}'1/IT e � /at f sv.- IMPORTANT NOTE In the event that this is a second or subsequent filing of a Statement of Intention to Proceed, this matter will be referred to the President Judge for the purpose of conducting a status conference involving all counsel. The goal of the status conference will be to set the matter for trial or other final disposition within a time certain. Prior to the status conference, Counsel will be expected to submit to the court, in writing, a proposed schedule for the completion of discovery, the filing of dispositive motions and a reportas to whether alternative dispute resolution has been used or discussed.